This article analyzes the 35-year evolution of the section 355 regulations from the perspectives of the jurisprudential dichotomy between general principles and detailed rules and administrative law theory as to agency discretion.
44 Tax Notes 1029-1048 (1989)
Lee, John W., "The Art of Regulation Drafting: Structured Discretionary Justice Under Section 355" (1989). Faculty Publications. 1399.