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 2021. There were 19,199 Tax Court cases closed, 1,577 nondocketed cases closed, and 187 refund cases closed. Graphic on the right shows the amount of tax and penalty by type of case in fiscal year 2021. Tax court cases closed in fiscal year 2021 resulted in $1.3 billion in taxes and penalty. Refund cases closed in fiscal year 2018 protected $714.0 million in taxes and penalty.

View chart detailsXLSX. For additional graphs from this section, download the PDF of this year’s Data BookPDF.

Highlights of the Data

  • In Fiscal Year (FY) 2021, Chief Counsel received 60,869 cases and closed 50,665 cases, including some received in prior years (Table 28XLSX).
  • Approximately 59.4 percent of closed cases were from the Small Business/Self-Employed Division (Table 28XLSX).
  • In Fiscal Year 2021, Chief Counsel received 28,387 Tax Court cases involving a taxpayer contesting an IRS determination that he or she owed additional tax. During the fiscal year, Chief Counsel closed 18,199 cases involving almost $4.3 billion in disputed taxes and penalties (Table 29XLSX).

Index of Data Book Tables

Chief Counsel: Tables 28 & 29

Table 28: Chief Counsel Workload: All Cases, by Office and Type of Case, Fiscal Year 2021XLSX
Table 29: Chief Counsel Workload: Tax Litigation Cases, by Type of Case, Fiscal Year 2021XLSX

Data for all years

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