Chief Counsel’s Subtle Impact on Revenue: Regulations, Litigation, and Administrative Guidance
65 National Tax Journal 889-98 (December 2012)
This essay examines the Chief Counsel’s role in the tax system and attempts to assess the ways in which it may affect revenue. The essay specifically discusses the revenue impacts of regulations and litigation led by the Office of Chief Counsel. Ultimately, the essay calls on Congress to systematically require analyses of revenue impacts of tax legislation and the administrative response to such legislation.