In recent years, the IRS has taken a more defensive posture as it seeks to have federal courts validate its guidance. Indeed, many federal courts have overruled such guidance on procedural grounds, ...
The IRS Independent Office of Appeals (Appeals) issued internal guidance reminding employees that they should share a copy of the Appeals case memorandum (ACM) with taxpayers who make an informal ...
Tax Court denies constitutional challenge to IRS Appeals officers’ and supervisors’ appointments
The Tax Court rejected a taxpayer’s arguments that officers and team managers in the IRS Independent Office of Appeals are officers of the United States under the U.S. Constitution’s Appointments ...
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