In short
When the Internal Revenue Service loses a case, it may announce acquiescence, meaning it accepts the decision and will follow it, or nonacquiescence, meaning it disagrees and may continue to litigate the issue in other cases.
Key takeaways
- Announcements are published in the Internal Revenue Bulletin.
- A nonacquiescence warns that relying on the decision may lead to a dispute.
- Researchers check acquiescence status when weighing a case's authority.
Where it's tested
TCP: Tax Research & Documentation — study notes, a five-minute revision sheet and practice questions.
Practise: 3 questions
Question 1 of 3 · 0 answered
A tax practitioner finds a Private Letter Ruling issued to another taxpayer that directly supports the client's intended position. How should the practitioner treat it?