The Tax Division is responsible for defending tax refund suits brought pursuant to 28 U.S.C. § 1346(a)(1) and 26 U.S.C. § 7422(a), and petitions for readjustment of final partnership administrative adjustments (FPAA) brought pursuant to 28 U.S.C. § 1346(e) and 26 U.S.C. § 6226 and 6228. When a taxpayer serves the United States Attorney with a tax refund suit or readjustment petition, the United States Attorney’s Office should immediately notify both the Chief of the appropriate Civil Trial Section and the appropriate IRS counsel.

[added February 2018]