id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-459	Aprill, Ellen P.	Muffled Chevron: Judicial Review of Tax Regulations	2022	41	.pdf	application/pdf	18715	1098	56	452 U.S. 247, 253 (1981). 19961 Florida Tax Review The difference between the strong deference due legislative tax regulations and the serious deference owed to interpretive tax regulations is small; the distinction between legislative and interpretative regulations is often blurred in practice, and the supposedly diverse standards of judicial review tend to converge and even to coalesce.' Accordingly, both cases involving legislative regulations and those considering interpretive regulations cite National Muffler.45 Like any multiple factor test, the National Muffler standard is malleable, and the results of its application are uncertain.46 Some cases conclude that inconsistency with any one of its three factors merits invalidation of the regulation; others find consistency with any one sufficient grounds to uphold the validation. 3 That is, legislative tax regula- tions, like other legislative regulations, were to be given strong deference as compared to the serious deference given to interpretive tax regulations.	cache/ftr-459.pdf	txt/ftr-459.txt