The IRS's Tax Determination Authority

36 Pages Posted: 11 Jan 2018

See all articles by Allen Madison

Allen Madison

University of South Dakota Law School

Date Written: December 31, 2017


This paper discusses the IRS's procedures for reviewing and examining tax returns, negotiating tax liabilities after an audit, and the IRS's final determination subject to judicial review.

Keywords: administrative review, audit, examination, privilege, appeal, negotiation, determination, deficiency notice, notice of disallowance, refund claim

JEL Classification: K00, K01, K34, M48, H00, H1, H10, H11, H19, H2, H20, H22, H24, H26, H29, H83, K4, K40, K41, K42, K49

Suggested Citation

Madison, Allen, The IRS's Tax Determination Authority (December 31, 2017). 71 Tax Law. 143 (2017). Available at SSRN:

Allen Madison (Contact Author)

University of South Dakota Law School ( email )

414 E. Clark Street
Vermillion, SD 57069
United States


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