Section 7 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.
Highlights of the Data
- In Fiscal Year (FY) 2016, Chief Counsel received 75,834 cases and closed 77,744 cases, including some received in prior years (Table 26).
- Approximately 68.9 percent of closed cases were received from the Small Business/Self-Employed Division (Table 26).
- Of the new cases received and cases closed, 86.1 percent and 86.6 percent, respectively, 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 26).
- In FY 2016, Chief Counsel received 29,748 Tax Court cases involving a taxpayer contesting an IRS determination that he or she owed additional tax. During the fiscal year, Counsel closed 32,621 cases involving roughly $8.2 billion in disputed taxes and penalties (Table 27).