The IRS closed more than 72,000 appeals last year, and its Chief Counsel’s Office received more than 65,000 cases.

That’s a lot of disputes. Safe to say they are about rules. Following rules. Not following rules. Questioning rules. Then, there are rules about rules that the IRS must follow.

The Administrative Procedure Act (APA) is such a beast. The APA places requirements on federal agencies when engaged in a “rule-making” that has the force and effect of law. The APA has become a focal point in tax litigation, due in large part to the IRS’s record of refusing to comply with the law’s notice-and-comment mandate. In his article for the Journal on Emerging Issues in Litigation, our guest, Jeffrey S. Luechtefeld, shareholder at Chamberlain Hrdlicka, wrote about challenging the IRS, recent trends in tax litigation, and the future of APA challenges. And now, he’s here on our humble podcast.

Jeff is a tax controversy and litigation attorney with a strong technical tax background and a deep understanding of the inner workings of the agency. Jeff advocates on behalf of clients in IRS examinations, appeals, and litigation. Previously, he led the regional tax controversy practice for a Big Four accounting firm. He began his career with the IRS Office of Chief Counsel as a litigator, eventually becoming a Special Trial Attorney in the Large Business and International Division. Jeff received his JD from the University of Missouri, Columbia School of Law.

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Tom Hagy
Litigation Enthusiast and
Host of the Emerging Litigation Podcast
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FILED UNDER: Complex Litigation | Regulations + Compliance​​
TAGS: Appeals | Compliance | Internal Revenue Service (IRS) | Litigation & appeals