The Appellate Section of the Tax Division handles all appeals in all tax cases, whether or not adverse to the Government, including summons cases. See JM 6-5.700, et seq. The Assistant Attorney General of the Tax Division must approve exceptions to this policy.

The United States Attorney’s Office should immediately notify the local IRS counsel and the Chief of the appropriate Civil Trial Section of all adverse decisions, and of an adverse party's notice of appeal or cross-appeal. The Tax Division treats a court’s limited enforcement of a summons as an adverse decision. See JM 6-5.710.

[updated February 2018]