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In Loper Bright and Relentless, the Supreme Court expressly overruled Chevron U.S.A. v. National Resources Defense Council, Inc., which had required federal courts to defer to reasonable regulatory interpretations of ambiguous statutory provisions. Now, when an interpretive regulation is challenged, courts will be required to apply traditional canons of statutory construction to arrive at their own interpretations of the underlying provisions of the Internal Revenue Code rather than deferring to what’s reflected in the regulation.
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