Florida State University College of Law Scholarship Repository Scholarly Publications 2013 Auer/Seminole Rock Deference in the Tax Court Steve R. Johnson Florida State University College of Law Follow this and additional works at: https://ir.law.fsu.edu/articles Part of the Administrative Law Commons, Taxation-Federal Commons, and the Tax Law Commons Recommended Citation Steve R. Johnson, Auer/Seminole Rock Deference in the Tax Court, 11 PITT. TAX REV. 1 (2013), Available at: https://ir.law.fsu.edu/articles/235 This Article is brought to you for free and open access by Scholarship Repository. It has been accepted for inclusion in Scholarly Publications by an authorized administrator of Scholarship Repository. For more information, please contact
[email protected]. Volume 11 (2013) | ISSN 1932-1821 (print) 1932-1996 (online) DOI 10.5195/taxreview.2013.19 | http://taxreview.law.pitt.edu AUER/SEMINOLE ROCK DEFERENCE IN THE TAX COURT Steve R. Johnson This work is licensed under a Creative Commons Attribution-Noncommercial-No Derivative Works 3.0 United States License. This journal is published by the University Library System of the University of Pittsburgh as part of its D-Scribe Digital Publishing Program, and is cosponsored by the University of Pittsburgh Press. ARTICLES AUER/SEMINOLE ROCK DEFERENCE IN THE TAX COURT Steve R. Johnson* Table of Contents Introduction ................................................................................................... 3 I. ASR Deference Generally .....................................................................