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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