Christopher Rizek to Moderate Panel at 2012 ABA Joint Fall Meeting
Program: Litigating Section 7408 Actions
Event Sponsor: American Bar Association, 2012 Joint Fall CLE Meeting
Taxpayers have historically relied heavily on the published position of the IRS in structuring their transactions and taking positions on tax returns. That reliance has occasionally been misplaced in situations where the IRS seeks to change its position in litigation or its position is found by a court to be inconsistent with the law. Increasingly, the IRS (often at taxpayers' request) is issuing guidance through FAQs, industry directives and other "informal" procedures. This panel will examine the historical authorities governing taxpayer reliance on the published position of the IRS and discuss how those authorities might apply in the expanded context of FAQs and other informal guidance.