Keith Fogg, director of the Federal Tax Clinic at Harvard Law School’s Legal Services Center, has made available for download his article “Who Settles Cases–Appeals or Counsel (and Why?)”, published on the Procedurally Taxing blog. The abstract is as follows:
One of the many interesting charts in the National Taxpayer Advocate’s 2021 annual report displays who settled the case before Tax Court trial, Appeals or Counsel. The trends are not good for Appeals. They show that more and more settlements occur at Counsel. What the chart does not show is why. I would be very interested in a study of the cases that settled at Counsel and why they settled there instead of Appeals. I suspect the Chief Counsel would be interested in this as well as it reflects resource shifting.
Posted by Marin Larkin, Associate Editor, Wealth Strategies Journal.