Lesson From The Tax Court: The Law Of Unintended Consequences

(TaxProf Blog) - To say the Internal Revenue Code is complex is like saying a virus is hard to see. It understates the obvious. NSS. Today the Tax Court teaches us one consequence of that complexity: the meaning and scope of one statute (§6103) can be altered by the later addition of another statute (§7623(b)). The former is the statute that requires the IRS to keep taxpayer information confidential. The latter is the statute that allows whistleblowers to obtain Tax Court review of a denial.

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