IRS Issues Guidance on Designating Issues for Litigation

Aug. 24, 2020, 7:52 PM

The IRS issued interim guidance for agency personnel on how to designate issues for litigation, stressing that designation should be used infrequently.

Designating a case for litigation is an option agency employees may consider in certain situations, such as when they see widespread abusive tax transactions or significant non-compliance, according to the memo, released Monday.

“Examination personnel should request designation of an issue in a case in the limited circumstances where sound tax administration is best served by establishing a legal precedent on the issue and not merely to prevent Appeals’ review,” the memo said.

The exhaustive ...

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