I think one of my concerns--and it goes back to what I said, longstanding agency interpretation and deference.
I want to bring you back into this discussion, Mr. Shelanski.
I have long maintained that I think guidance can be extraordinarily helpful.
I do believe that there are things that are done at the IRS that need maybe a second look.
Yes, we settled those cases, but it is still guidance documents.
And, it just keeps getting to that point where had you started with a rulemaking process, you would have a firmer founda...
There has to be some flexibility that they have because they have to make those determinations.
It looks and reads to me like guidance is being used as 'rulemaking light.'
We still have not satisfied the public that they have had adequate input in this process.
I could see doing something where you say, well, you might consider this, you might consider that; here are some things ...
I think that the overtime as it relates to on-call is very problematic.
Yes, and this is a problem because we give deference--and I do not mean to give the Chairman any more ammunition than wh...
I think you did less than what was required.
I think that guidance is extraordinarily valuable.
Is that really the kind of relationship we want with the public as it relates to an interpretive change?
When we change how we interpret either rules or statutes, and the change has a dramatic impact on the livelihood of busi...
I do not think, given what we know right now, a delay to the end of the year is asking too much.
It should be not on scoring political points.
