DOJ Tax Division
This is the guide used by civil trial attorneys when they litigate tax cases for the US government.
Studying this manual will give you an idea of the behind the scenes tactics used by the IRS attorneys, and the methodology used to create offers in compromise and tax settlements.
The Tax Division endeavors to litigate when appropriate, to concede when appropriate, and also to compromise when appropriate on terms that are just and in the Government’s best interests.
Civil tax controversies in the courts are resolved either by settlement or by judicial decision. Litigation and settlement are twin aspects of the Tax Division’s role of contributing to the orderly and rational development of the tax law through the cases we litigate. This manual focuses on questions concerning resolution by settlement.
The term settlement includes both compromises, where both parties are giving up something, and concessions, where the United States is giving up the case, or an issue in the case, and is not receiving anything in return.
- Settlement Checklist
- Quick Reference Chart
- Flowchart of Compromise Process for Joint Committee
- Flowchart of Compromise Process for Associate A.G.
Download the DOJ manual to see the guide used by US trial attorneys for tax cases.