Jasper Cummings has published his article, “When the IRS Disagrees With a Court.” The summary is as follows:

In this report, Cummings investigates the IRS’s long-standing practice of issuing acquiescences and non-acquiescences to court decisions. He concludes that although a non-acquiescence to an unappealed adverse holding seems unfair to other taxpayers who want the same good result, the practice is reasonable (albeit waning), given the difficulties faced by the IRS in tax litigation.

See full article at Tax Notes (subscription required).

Posted by Quinton Weinstein, Associate Editor, Wealth Strategies Journal