The interpretation of a statute that an agency administers can come under scrutiny by the court if a lawsuit is filed against the agency. This was the case of Loving v. Internal Revenue Service (IRS). The IRS decided to regulate tax-return preparers because of some concerns about their performance. The new rule required “tax-return preparers to pass an initial certification exam, pay annual fees, and complete at least fifteen hours of continuing education each year” (Miller, Pg. 854).
Three independent preparers challenged this rule in a federal district court. The court ruled in their favor and the IRS appealed to the United States Court of Appeals, District of Columbia Circuit. The court affirmed the decision