This paper explores the possibility of subjecting such an administrative ruling to judicial review initiated either by a taxpayer not benefited by the regulation or by a nontaxpayer. For either party to prevail he must prove that he has standing, that judicial review is available, and that there is a remedy which he can obtain by judicial review
Paul E. Sullivan, Jr.,
Judicial Review of Treasury Regulations for Taxpaying and Nontaxpaying Citizens,
48 Wash. L. Rev.
Available at: https://digitalcommons.law.uw.edu/wlr/vol48/iss2/5