Did the IRS guidance on ERC violate the law?

Exploring whether the IRS complied with the Administrative Procedures Act

Last week, a new court case in the Employee Retention Credit community made the rounds. This case (Stenson Tamaddon LLC v. IRS) asks the Court (in part) to set aside Notice 2021-20. This is not the first case to do so. Last December, Southern California Emergency Medicine filed a similar suit. Both cases rely heavily on the Administrative Procedure Act …