This section of the Data Book provides an overview of the IRS Chief Counsel’s workload and activities. The IRS Chief Counsel is appointed by the President of the United States, with the advice and consent of the U.S. Senate, and serves as the chief legal advisor to the IRS Commissioner on all matters pertaining to the interpretation, administration, and enforcement of the Internal Revenue Code, as well as all other legal matters. Under the IRS Restructuring and Reform Act of 1998, the Chief Counsel reports to both the IRS Commissioner and the Treasury General Counsel. Attorneys in the Chief Counsel’s Office serve as lawyers for the IRS. They provide the IRS and taxpayers with guidance on interpreting Federal tax laws correctly, represent the IRS in litigation, and provide all other legal support required to carry out the IRS mission. View chart details XLSX. For additional graphs from this section, download the PDF of this year’s Data Book PDF. Highlights of the data In Fiscal Year (FY) 2023, Chief Counsel received 54,979 cases and closed 65,603 cases, including those received in prior years (Table 30 XLSX). Of the cases closed in FY 2022, 68.8 percent were from the Small Business/Self-Employed Division (Table 30 XLSX). Of the 65,603 cases closed, Chief Counsel closed 7.2 percent through guidance and assistance. This includes published guidance, advanced case resolution, treaties, legislation, congressional and executive correspondence, training and public outreach, and prefiling legal advice to the IRS (Table 30 XLSX). More than 82.2 percent of new cases received and about 86.2 percent of cases closed were related to tax law enforcement and litigation, including Tax Court litigation; collection, bankruptcy, and summons advice and litigation; Appellate Court litigation; criminal tax; and enforcement advice and assistance (Table 30 XLSX). In FY 2023, Chief Counsel received 22,211 Tax Court cases involving a taxpayer contesting an IRS determination that they owed additional tax. During the fiscal year, Chief Counsel closed 34,907 cases involving $5.5 billion in disputed taxes and penalties (Table 31 XLSX). Index of Data Book Tables Chief Counsel: Tables 30 & 31 Table 30: Chief Counsel Workload: All Cases, by Office and Type of Case, Fiscal Year 2023 XLSX Table 31: Chief Counsel Workload: Tax Litigation Cases, by Type of Case, Fiscal Year 2023 XLSX Data for all years Table 30 Table 31 Additional applications may be needed to access linked content on this page. Get free Adobe Acrobat® reader or Excel® viewer. Return to the IRS Data Book home page Back to Top
