IRS Says No Universal Right To Appeal In Facebook Tax Bout

Law360, Los Angeles (March 26, 2018, 5:02 PM EDT) -- The government told a California federal court on Friday that Congress had not enacted a universal right of access to Internal Revenue Service appeals, disputing Facebook Inc.'s contention in a legal battle over whether the social media company can appeal an IRS decision that disallowed the business from adjusting its taxes for 2008 and 2010.

The IRS said that Facebook’s challenge is based on the plain meaning of a statute but that Internal Revenue Code § 7803(a)(3), which was enacted in 2015 as part of the PATH Act, does not create new taxpayer rights and does not guarantee a right of...

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