Leslie Book (Villanova), Abbott Labs and Appeals: What Is It Good For (Absolutely Nothing)? (Tax Notes, Aug. 13, 2026, 2026 TNTF 156-10)

The case of Abbott Laboratories v. Commissioner, Docket No. 20193-24, raises important procedural issues concerning access to the IRS Independent Office of Appeals. The case involves Abbott’s 2020 tax year, with a key substantive issue concerning the foreign derived intangible income deduction under section 250 as well as a loss carryback.

In this post, I will discuss the posture of the case and procedural issues that Abbott has raised. In a follow-up post, I will discuss the points made by amici the Chamber of Commerce and the Center for Taxpayer Rights….

Leslie Book (Villanova), Should the IRS Be Able to Cut Off Appeals in a Docketed Tax Court Case? (Tax Notes, Aug. 14, 2026, 2026 TNTF 156-10)

In my initial post discussing Abbott Laboratories v. Commissioner, Docket No. 20193-24, I addressed how Abbott has asked the Tax Court to ensure that the IRS Independent Office of Appeals has an opportunity to consider a disallowed foreign-derived intangible income deduction under section 250. The IRS filed a summary judgment motion after it rejected Abbott’s request to have Appeals consider the merits of the issues in dispute.

Access to Appeals in docketed Tax Court cases raises fundamental issues of tax administration. The case has drawn the interest of two amici: the U.S. Chamber of Commerce and the Center for Taxpayer Rights. Each of their briefs argues that the IRS’s action was improper. As the briefs tackle the issue from differing perspectives, I discuss highlights from both below….