Part 36. Chief Counsel Directives Manual – Appellate Litigation and Actions on Decision

Table of Contents

36.1 Guiding Principles for Appeals

• 36.1.1 Guiding Principles for Appeals

36.2 Appeal/Certiorari Recommendations

• 36.2.1 Appeal Recommendations in General
• 36.2.2 Petition for Writ of Certiorari
• 36.2.3 Conflicts in Appeal or Certiorari Recommendations and Settlement Offers
• 36.2.4 Closing Appeal Cases
• 36.2.5 Appeals of Tax Court Cases
• 36.2.6 Area Counsel and Associate Chief Counsel Responsibilities in Tax Court Cases on Appeal

36.3 Actions on Decision

• 36.3.1 Actions on Decision

36.4 Litigation Exhibits

• 36.4.1 Litigation Exhibits