Vons Companies, Inc. v. United States

ORDER REGARDING DISCOVERY

ALLEGRA, Judge.

Owing to its interaction with more than 250 million taxpayers annually, the Internal Revenue Service (Service or IRS) has a robust administrative practice, characterized by a panoply of multi-faceted and multi-purposed administrative pronouncements and positions. Among these are Treasury regulations (both interpretative and legislative), revenue rulings, private letter rulings, technical advice memoranda and General Counsel Memoranda. A recurring issue in federal tax litigation involves the extent to which a taxpayer may rely on these IRS statements and…