Overruling of Chevron Doctrine May Lead to More Attacks on the Validity of Tax Regulations
The Chevron deference doctrine (originating from a 1984 Supreme Court case) provided that if a statute was ambiguous, administrative actions (including regulations) involving that statute would be valid as long as they were “permissible” (i.e., reasonable), even if courts would have reached a different result as to the best interpretation of the statute’s intent. The Supreme Court in Loper Bright overruled that doctrine, making legal challenges of the validity of regulations more likely to succeed. The Chevron doctrine has been controversial, and Loper Bright will dramatically impact administrative law (regulations and administrative actions by federal agencies).
