Chief Counsel

 

This section of the Data Book provides an overview of the IRS Chief Counsel’s workload and activities. The IRS Chief Counsel is appointed by the President of the United States, with the advice and consent of the U.S. Senate, and serves as the chief legal advisor to the IRS Commissioner on all matters pertaining to the interpretation, administration, and enforcement of the Internal Revenue Code, as well as all other legal matters. Under the IRS Restructuring and Reform Act of 1998, the Chief Counsel reports to both the IRS Commissioner and the Treasury General Counsel.

Attorneys in the Chief Counsel’s Office serve as lawyers for the IRS. They provide the IRS and taxpayers with guidance on interpreting federal tax laws correctly, represent the IRS in litigation, and provide all other legal support required to carry out the IRS mission.

Graphic on the left shows the number of tax litigation cases closed by type of case in fiscal year 2025. Chief Counsel closed 20,313 Tax Court cases, 1,137 nondocketed cases, and 268 refund cases. Graphic on the right shows the amount of tax and penalty by type of case in fiscal year 2025. Tax court cases closed in fiscal year 2025 resulted in $3.7 billion in taxes and penalty. Refund cases closed in fiscal year 2025 protected $749.6 million in taxes and penalty.

View chart details XLSX. For additional graphs from this section, download the PDF of this year’s Data Book PDF.

Highlights of the data

  • In Fiscal Year (FY) 2025, Chief Counsel received 48,544 cases and closed 47,575 cases, including those received in prior years (Table 5-1 XLSX ).
  • Of the cases closed in FY 2025, 60.8% were from the Litigation and Advisory Office, which was created when the former Large Business & International and Small Business/Self-Employed Offices were merged. (Table 5-1 XLSX ).
  • Of the 47,575 cases closed, Chief Counsel closed 10.0 percent through guidance and assistance. This includes published guidance, advanced case resolution, treaties, legislation, congressional and execu­tive correspondence, training and public outreach, and prefiling legal advice to the IRS (Table 5-1 XLSX ).
  • More than 77.6 percent of new cases received and about 79.9 percent of cases closed were related to tax law enforcement and litigation, includ­ing Tax Court litigation; collection, bankruptcy, and summons advice and litigation; Appellate Court litiga­tion; criminal tax; and enforcement advice and assistance (Table 5-1 XLSX ).
  • In FY 2025, Chief Counsel received 21,588 Tax Court cases involving a taxpayer contesting an IRS determi­nation that they owed additional tax. During the fiscal year, Chief Counsel closed 21,718 cases involving $8.5 billion in disputed taxes and penalties (Table 5-2 XLSX ).

Index of Data Book tables

Chief Counsel: Tables 5-1 & 5-2

Table 5-1: Chief counsel workload: All cases, by office and type of case, fiscal year 2025 XLSX
Table 5-2: Chief counsel workload: Tax litigation cases, by type of case, fiscal year 2025 XLSX

Data for all years

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Page Last Reviewed or Updated: 05-Jun-2026