Overview
(September 1, 2026, Washington, DC) – Steptoe LLP recently filed an amicus brief in the US Tax Court on behalf of the US Chamber of Commerce in Abbott Laboratories v. Commissioner of Internal Revenue. Filed in support of Abbott Laboratories, the brief argues that the IRS must provide Abbott the opportunity to challenge the agency's proposed adjustments before the Independent Office of Appeals under Internal Revenue Code section 7803(e), which states that the right to appeal "shall be generally available to all taxpayers."
Beyond the underlying tax dispute, the case raises a broader question with implications for businesses and taxpayers nationwide: whether the IRS can bypass the administrative appeals process and move directly to litigation without providing the procedural protections Congress established in the Taxpayer First Act of 2019. Administrative review by the IRS Independent Office of Appeals is vital to resolving federal tax disputes efficiently and without litigation. The brief urges the court to direct the IRS to either refer the case to the IRS Independent Office of Appeals or comply with the notice-and-protest requirements of section 7803(e)(5)(A) for denying Appeals' review.
As the world's largest business organization and the nation's leading advocate for business, the US Chamber of Commerce regularly participates in cases that have broad implications for the business community. The Chamber's brief argues that the case will help determine whether taxpayers have a judicially enforceable right to seek review by the IRS Independent Office of Appeals before disputed issues proceed to litigation.
The Steptoe team representing the US Chamber of Commerce includes partner Caitlin Tharp and associate Zain Devshi.
The brief has been covered by Law360 and Tax Notes.
About Steptoe
In more than 110 years of practice, Steptoe has earned an international reputation for vigorous representation of clients and innovative thinking before governmental agencies, successful advocacy in litigation and arbitration, and creative and practical advice in structuring business transactions. Steptoe has more than 500 lawyers and other professional staff across offices in Beijing, Brussels, Chicago, Hong Kong, Houston, London, Los Angeles, New York, San Francisco, and Washington, DC. For more information, visit www.steptoe.com.
