The Internal Revenue Service ("IRS") issued a memorandum (PDF) that provides interim guidance to the agency's compliance staff on requests to designate issues for litigation.
Designation of issues for litigation, a decision that is made with the Office of Chief Counsel, limits a taxpayer's opportunity to administratively resolve their case with the IRS Independent Office of Appeals. Disputes between the IRS and taxpayers over designated issues must be resolved through litigation. The IRS took this step to update and clarify its designation procedures as part of its implementation of the Taxpayer First Act (TFA) enacted in July 2019.
For any questions or assistance, please contact the Tax Attorneys atFazzio Law, we are in your corner!
Link to full announcement here: https://www.irs.gov/newsroom/irs-updates-procedures-for-designating-taxpayer-disputes-for-litigation-implementing-provisions-of-taxpayer-first-act