Part 36. Chief Counsel Directives Manual – Appellate Litigation and Actions on Decision
Table of Contents
36.1 Guiding Principles for Appeals36.2 Appeal/Certiorari Recommendations- 36.2.1 Appeal Recommendations in General
- 36.2.2 Petition for Writ of Certiorari
- 36.2.3 Conflicts in Appeal or Certiorari Recommendations and Settlement Offers
- 36.2.4 Closing Appeal Cases
- 36.2.5 Appeals of Tax Court Cases
- 36.2.6 Area Counsel and Associate Chief Counsel Responsibilities in Tax Court Cases on Appeal