Within most areas of administrative law, courts review decisions of the administrative agency for abuse of discretion, based on the administrative record. This is generally not the case when final decision of the Internal Revenue Service regarding collection actions are subject to judicial...

Since enactment of the Taxpayer First Act (TFA) in July 2019, the IRS has issued subregulatory guidance to implement the major new provisions affecting appeals, including a memorandum on taxpayer access to the appeals office and a memorandum on taxpayer access to case files prior to scheduled...