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.
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