A Loose Standard For IRS Summons Enforcement

Law360, New York (August 16, 2016, 12:59 PM EDT) -- Kathleen Saunders Gregor

Gabrielle G. Hirz Taxpayers defending against IRS enforcement actions face an interesting quandary: the IRS is increasingly asking for document discovery during examinations in a manner that would not be permitted under the Federal Rules of Civil Procedure and Tax Court rules. This asymmetry has encouraged the IRS, particularly in large, high-profile suits, to actively push factual development of future litigation into the examination stage. While, on the one hand, this may encourage earlier resolution of issues, on the other, burdens are placed on taxpayers that, as a policy matter, have been rejected by federal courts.

A recent...

Stay ahead of the curve

In the legal profession, information is the key to success. You have to know what’s happening with clients, competitors, practice areas, and industries. Law360 provides the intelligence you need to remain an expert and beat the competition.


  • Access to case data within articles (numbers, filings, courts, nature of suit, and more.)
  • Access to attached documents such as briefs, petitions, complaints, decisions, motions, etc.
  • Create custom alerts for specific article and case topics and so much more!

TRY LAW360 FREE FOR SEVEN DAYS

Hello! I'm Law360's automated support bot.

How can I help you today?

For example, you can type:
  • I forgot my password
  • I took a free trial but didn't get a verification email
  • How do I sign up for a newsletter?
Beta
Ask a question!