United States:
IRS Memo Sheds Light On Process For Designating Cases For Litigation
01 November 2020
Ropes & Gray LLP
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The IRS recently published a memorandum that provides guidance on the
process of designating certain cases or issues for litigation (the
"IRS Memo"). When a case or
issue is designated for litigation, a taxpayer's ability to try
to resolve that issue through the IRS Independent Office of Appeals
("Appeals") is foreclosed.
While IRS guidance on the process of designating cases or issues
for litigation existed previously, the IRS Memo provides more
transparency on certain details of the process, and clarifies the
procedure if a taxpayer wishes to challenge a designation for
litigation.
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