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.

Chart 1 shows the number of tax litigation cases closed by type of case in fiscal year 2018. There were over 26,341 cases closed for tax court cases. Chart 2 shows the amount of tax and penalty by type of case in fiscal year 2018. Tax court cases closed in fiscal year 2018 resulted in almost $7.5 billion in taxes and penalty. Refund cases closed in fiscal year 2014 protected $2.8 billion in taxes and penalty.

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

Highlights of the Data

  • In Fiscal Year (FY) 2018, Chief Counsel received 66,531 cases and closed 66,886 cases, including some received in prior years (Table 26).
  • Approximately 68.1 percent of closed cases were from the Small Business/Self-Employed Division (Table 26).
  • In FY 2018, Chief Counsel received 25,463 Tax Court cases involving a taxpayer contesting an IRS determination that he or she owed additional tax. During the fiscal year, Chief Counsel closed 26,341 Tax Court cases involving more than $7.5 billion in disputed taxes and penalties (Table 27).

Index of Data Book Tables

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