Boston’s Karl Fryzel, Co-Chair of Locke Lord’s Tax Department, was quoted in an article about a case in California federal court arguing whether tax payers are guaranteed access to an appeals process with the IRS. Fryzel said, “If [the court] rules in favor of the IRS, I think it’s probably going to be business as usual for the tax bar.” He also added that the Taxpayer Bill of Rights does not clearly mandate that the IRS is compelled to give taxpayers a hearing in the Office of Appeals in all cases. “I don’t believe that is something which is afforded by a provision of the Internal Revenue Code. That appeal function is set up by procedural rules that were issued by the Internal Revenue Service,” Fryzel said.
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