Regularly cited by the IRS, this treatise has also been cited as authority over 100 times by the courts, including twice by the U.S. Supreme Court and 21 times by the U.S. circuit courts of appeal. In the past two years alone, it was relied on and cited by the Tenth Circuit, by federal district courts in Mississippi, Connecticut, Florida, and Pennsylvania, as well as on three separate occasions by the Court of Federal Claims, twice by the Tax Court, and by bankruptcy appellate panels in both the Sixth and Tenth Circuits.
IRS Practice & Procedure provides analysis, commentary, and strategies for all types of practitioners who have dealings with the IRS, and includes among other things discussion concerning the making of ruling requests, imposition and avoidance of civil and criminal penalties, the scope of the IRS’s investigative powers, navigating the IRS's tax collection procedures, resolving tax issues through offers in compromise, and more. Its approach is to provide detailed and thorough integration of authorities relating to how the IRS operates in its various functions, to ensure that practitioners understand the IRS’s limits on powers, and the rights that taxpayers enjoy at all stages of their interactions with the IRS.
Updated three times annually, IRS Practice & Procedure includes coverage of areas of increasing importance, including expanded powers of the Office of Professional Responsibility, a revised summary and analysis of the TEFRA partnership proceedings, discussion of deference afforded various administrative authorities, requirements on corporations to disclose uncertain tax positions, and limits on evidentiary privileges.