IRS expands preliminary pointers for figuring out litigation

The IRS has expanded the guidelines for employee naming of disputes and reiterated the agency’s position that such naming should only be done in “limited circumstances.”

According to the memo released Thursday and signed by Douglas O’Donnell, the IRS Assistant Commissioner for Services and Enforcement, cases should rarely be designated for litigation, requiring careful consideration at all levels of the process.

  • The provisional guidelines, which were first published in August 2020, should provide for cases of litigation in cases where “sound tax administration is best achieved through setting a precedent …

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