Abstract
This Note examines the collapse of Chevron deference and its profound implications for federal tax law, where complexity and ambiguity are the rule rather than the exception. For decades, Chevron allowed courts to defer to the Internal Revenue Service’s reasonable interpretations of ambiguous statutes, promoting uniformity, predictability, and administrability across the tax system. In Loper Bright Enterprises v. Raimondo, the U.S. Supreme Court dismantled that framework, shifting interpretive authority decisively to the judiciary. This Note argues that the loss of Chevron destabilizes tax administration by inviting inconsistent judicial interpretations, increasing taxpayer challenges, and undermining reliance on agency guidance. It further contends that, absent meaningful legislative clarification or a functional replacement doctrine, the IRS must adapt by strengthening its statutory reasoning and rethinking its approach to rulemaking in an era defined by judicial, rather than administrative, supremacy.
Recommended Citation
Reagan Honn,
The Fall of Chevron: What It Means for Irs Authority and Tax Law,
50
S. Ill. U. L.J.
378
(2026).
Available at:
https://opensiuc.lib.siu.edu/siulj/vol50/iss2/8