Chief Counsel

 

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.

Graphic on the left shows the number of tax litigation cases closed by type of case in fiscal year 2024. Chief Counsel closed 25,505 Tax Court cases, 1,939 nondocketed cases, and 286 refund cases. Graphic on the right shows the amount of tax and penalty by type of case in fiscal year 2024. Tax court cases closed in fiscal year 2024 resulted in $1.8 billion in taxes and penalty. Refund cases closed in fiscal year 2024 protected more than $2.0 billion in taxes and penalty

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) 2024, Chief Counsel received 51,704 cases and closed 53,191 cases, including those received in prior years (Table 30 XLSX).
  • Of the cases closed in FY 2024, 60.4 percent were from the Small Business/Self-Employed Division (Table 30 XLSX).
  • Of the 53,191 cases closed, Chief Counsel closed 9.1 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 80.2 percent of new cases received and about 82.2 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 2024, Chief Counsel received 23,093 Tax Court cases involving a taxpayer contesting an IRS determi­nation that they owed additional tax. During the fiscal year, Chief Counsel closed 25,505 cases involving $4.7 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 2024 XLSX
Table 31: Chief Counsel Workload: Tax Litigation Cases, by Type of Case, Fiscal Year 2024 XLSX

Data for all years

Other Data Book Sections:

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

Page Last Reviewed or Updated: 29-May-2025