Bloomberg Quotes Christopher Rizek on Facebook's IRS Appeal Denial
Facebook Inc. lost a fight against the IRS when a U.S. district court judge denied it an independent review of a tax bill related to its Irish assets.
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The key holding is the finding that the TBOR didn't create an independent basis for a substantive right to appeal, he said. “If there wasn't a substantive right to appeal elsewhere in the code, the TBOR provision didn't create a new one,” Rizek said. “Once that holding is made, all of the plaintiff's legal claims fall aside because they don't have an enforceable right to appeals elsewhere in the code.”
The TBOR, instead, is an interpretive guide for the commissioner and IRS employees to be cognizant of taxpayers’ rights, Rizek added.
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Excerpt taken from the article “Facebook Doesn't Have Right to Take Case to IRS Appeals: Judge” by Sony Kassam for Bloomberg BNA, Tax Management Transfer Pricing Report.