The Treasury Department issues two types of regulations "interpretative" and "legislative". Compare and contrast "interpretative" and "legislative" regulations and briefly discuss why the courts are less likely to invalidate a legislative regulation.

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The U.S. Tax Court issues both regular and memorandum decisions. Assume that you are a Tax Practitioner and one of your client's poses the following query: "If we take my case to the U.S. Tax Court I have heard that they could render either a "regular" or a "memorandum" decision - what is the difference between the two and are there any similarities?" Discuss "regular" and "memorandum" U.S. Tax Court decisions as a response to your client's query.