Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 28 APRIL 2025

IRS Appeals Is No Longer Appealing

Mayer Brown
Mayer Brown
Contributor
Mayer Brown

Mayer Brown

Mayer Brown is a leading international law firm positioned to represent the world’s major...

View firm profile
Explore more from Mayer Brown

Ten years ago, I would have easily agreed with Joel Cohen that the IRS Independent Office of Appeals is a "taxpayer favorite."

United StatesTax
Jenny A. Austin
Jenny A. Austin
Author LinkedIn connections

To the Editor:

Ten years ago, I would have easily agreed with Joel Cohen that the IRS Independent Office of Appeals is a "taxpayer favorite."1 Back then, taxpayers were almost always able to successfully resolve issues with IRS Appeals. It didn't matter whether it was a simple issue or the most complex of issues. We rarely had in-depth conversations about whether to bypass IRS Appeals and go straight to Tax Court. Instead, we would quickly move on to a meaningful discussion about our strategy to reach a successful outcome with IRS Appeals. Only rarely did we end up in Tax Court.

But over the last five to 10 years, something has changed with IRS Appeals. Now, what used to be a highly effective opportunity to resolve disputes without the expense of litigation is simply no longer the case. More often than not, tax practitioners now consider a very successful settlement at Appeals to be a 50-50 split of the issue. Mr. Cohen discusses the possibility of a "full

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

Visit us at mayerbrown.com

Mayer Brown is a global services provider comprising associated legal practices that are separate entities, including Mayer Brown LLP (Illinois, USA), Mayer Brown International LLP (England & Wales), Mayer Brown (a Hong Kong partnership) and Tauil & Chequer Advogados (a Brazilian law partnership) and non-legal service providers, which provide consultancy services (collectively, the "Mayer Brown Practices"). The Mayer Brown Practices are established in various jurisdictions and may be a legal person or a partnership. PK Wong & Nair LLC ("PKWN") is the constituent Singapore law practice of our licensed joint law venture in Singapore, Mayer Brown PK Wong & Nair Pte. Ltd. Details of the individual Mayer Brown Practices and PKWN can be found in the Legal Notices section of our website. "Mayer Brown" and the Mayer Brown logo are the trademarks of Mayer Brown.

© Copyright 2026. The Mayer Brown Practices. All rights reserved.

This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

GENIUS Act Crypto Tax Guide 2025-2026: What US Investors, Businesses, And Taxpayers Need To Know About The New Stablecoin Law, Form 1099-DA, And Digital Asset Regulation

The United States cryptocurrency regulatory landscape has undergone its most dramatic transformation in history. The signing of the GENIUS Act into law on July 18, 2025 — the first comprehensive federal crypto statute ever enacted — marks a before-and-after moment for American digital asset law.
United StatesTax
Rotfleisch & Samulovitch P.C.
Rotfleisch & Samulovitch P.C.
Article

A 5% Wealth Tax? Preparing Clients For California's Billionaire Tax Act

California's proposed Billionaire Tax Act would impose a onetime 5% excise tax on individuals and trusts with assets exceeding $1 billion, creating unprecedented challenges for estate planners. The retroactive application and anti-abuse provisions raise critical questions about the treatment of grantor trusts, non-grantor trusts, and beneficiary interests that deviate significantly from established federal wealth transfer tax principles.
United StatesTax
Withers LLP
Withers LLP
Article

IRS Proposes New Racial Nondiscrimination Regulations For Tax-exempt Private Schools

The US Treasury and IRS have proposed regulations that would eliminate longstanding exceptions allowing tax-exempt private schools to maintain race-conscious admissions and scholarship policies. Following the Supreme Court's decision in Students for Fair Admissions v. Harvard, these rules would apply to all private educational institutions, including K-12 schools not directly affected by that ruling, and could result in loss of tax-exempt status for noncompliance.
United StatesTax
McDermott Will & Schulte
McDermott Will & Schulte
Article

DOL Announces Enforcement Actions Against Employers In H-1B And PERM Fraud Probe

The Trump Administration has launched an unprecedented enforcement action suspending permanent labor certification processing for eight major employers, linking immigration sponsorship to layoff histories and recruitment practices. This development signals a fundamental shift in how the government evaluates employer access to H-1B and green card programs, with investigations already underway and subpoenas served.
United StatesEmployment and HR
Mayer Brown
Mayer Brown
Article

Trump Administration Announces New Enforcement Actions Against Employers In H-1B And PERM Fraud Probes

The Trump Administration has launched an unprecedented investigation into H-1B visa and PERM labor certification programs, with the Department of Labor's Office of Inspector General issuing dozens of subpoenas and suspending employers' ability to process applications. Federal agencies are deploying new enforcement tools including whistleblower programs and criminal prosecution threats...
United StatesImmigration
Mayer Brown
Mayer Brown
Article

SEC Staff Statement On Fair Value Measurement And Disclosure Considerations For Private Assets

The SEC Staff has issued new guidance addressing fair value measurement and disclosure practices for private credit and other illiquid assets held by registered funds and business development companies. As private credit portfolios have grown nearly 60% since 2020, reaching $270 billion, regulators emphasize the critical importance of robust valuation methodologies, transparent disclosure of significant judgments, and careful application of accounting standards when market prices are unavailable.
United StatesAccounting and Audit
Mayer Brown
Mayer Brown
Article

AI Regulation In Singapore And Hong Kong: A Mid-Year Checkpoint

Singapore and Hong Kong continue to regulate artificial intelligence through existing laws and voluntary frameworks rather than comprehensive AI statutes, but the first half of 2026 has brought sharper emphasis on practical controls including agentic AI governance, assurance and testing, financial-sector oversight and cyber resilience. Both jurisdictions are building concrete expectations around risk management, transparency, human accountability and operational safeguards while avoiding horizontal AI legis
GlobalStrategy
Mayer Brown
Mayer Brown
Article

European Union Adopts 21st Package Against Russia & Parallel Sanctions On Belarus

The European Union has adopted its 21st package of sanctions against Russia and Belarus, significantly expanding restrictions across finance, energy, crypto, and military-industrial sectors. This comprehensive package introduces 218 new designations, freezes the oil price cap, imposes stricter LNG controls, and closes loopholes while reinforcing measures to discourage third-party sanctions evasion. The sanctions also strengthen protections for EU operators and facilitate business exits from Russia.
European UnionInternational Law
Mayer Brown
Mayer Brown
Article

Russia/Ukraine Sanctions Update - Month Of August 2026

This monthly update tracks the latest developments in Russia/Ukraine sanctions across US, EU, and UK jurisdictions, covering new designations, general license extensions, legislative proposals, and enforcement actions. The update also examines Russia's countermeasures, including shadow fleet expansion and legal restrictions on foreign investors, while highlighting international coordination efforts by Switzerland, Canada, and New Zealand.
GlobalInternational Law
Mayer Brown
Mayer Brown
Article

DOL Announces New Enforcement Policy For Mental Health Parity Nonquantitative Treatment Limitation Requirements

The US Department of Labor has issued new guidance establishing a streamlined framework for enforcing mental health parity requirements under MHPAEA, focusing enforcement on three priority areas while maintaining nonenforcement of controversial 2024 rule provisions. This guidance aims to reduce compliance burdens on plan sponsors while ensuring participants maintain access to mental health and substance use disorder benefits comparable to medical and surgical coverage.
United StatesEmployment and HR
Mayer Brown
Mayer Brown
Article

EU AI Act News: Digital Omnibus On AI, New Guidance On Risk Classification, GPAI, And Transparency Obligations

The European Union's Artificial Intelligence Act continues to evolve with significant regulatory updates that reshape compliance timelines and clarify key obligations. Recent developments include the Digital Omnibus on AI, which extends implementation deadlines for high-risk systems and introduces new prohibitions on harmful AI applications, alongside comprehensive guidance from the European Commission on classification criteria, transparency requirements, and general-purpose AI model obligations.
European UnionIntellectual Property
Mayer Brown
Mayer Brown