Proposed Rule2025-22825
Updating Regulation References To Reflect Reorganizations at the Department of Justice and the Internal Revenue Service
Primary source
Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.
Published
December 15, 2025
Issuing agencies
Treasury DepartmentInternal Revenue ServiceAlcohol and Tobacco Tax and Trade Bureau
Abstract
This document contains proposed regulations that would update points of contact within the Department of Justice and the IRS. The proposed regulations are necessary to reflect a reorganization within the Department of Justice to identify new points of contact for matters involving the internal revenue laws. The proposed regulations would also update points of contact at the IRS for administrative claim submissions from taxpayers seeking civil damages for certain unauthorized collection actions or awards of administrative costs with respect to certain administrative proceedings.
Full Text
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<title>Federal Register, Volume 90 Issue 238 (Monday, December 15, 2025)</title>
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[Federal Register Volume 90, Number 238 (Monday, December 15, 2025)]
[Proposed Rules]
[Pages 57937-57941]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-22825]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 301
Alcohol and Tobacco Tax and Trade Bureau
27 CFR Part 70
[REG-110519-25]
RIN 1545-BR65
Updating Regulation References To Reflect Reorganizations at the
Department of Justice and the Internal Revenue Service
AGENCY: Internal Revenue Service (IRS), Alcohol and Tobacco Tax and
Trade Bureau (TTB), Treasury.
ACTION: Notice of proposed rulemaking.
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SUMMARY: This document contains proposed regulations that would update
points of contact within the Department of Justice and the IRS. The
proposed regulations are necessary to reflect a reorganization within
the Department of Justice to identify new points of contact for matters
involving the internal revenue laws. The proposed regulations would
also update points of contact at the IRS for administrative claim
submissions from taxpayers seeking civil damages for certain
unauthorized collection actions or awards of administrative costs with
respect to certain administrative proceedings.
DATES: Written or electronic comments and requests for a public hearing
must be received by January 14, 2026.
ADDRESSES: Commenters are strongly encouraged to submit public comments
electronically via the Federal eRulemaking Portal at https://
[[Page 57938]]
www.regulations.gov (indicate IRS and REG-110519-25) by following the
online instructions for submitting comments. Requests for a public
hearing must be submitted as prescribed in the ``Comments and Requests
for a Public Hearing'' section. Once submitted to the Federal
eRulemaking Portal, comments cannot be edited or withdrawn. The
Department of the Treasury (Treasury Department) and the IRS will
publish for public availability any comments submitted to the IRS's
public docket. Send paper submissions to: CC:PA:01:PR (REG-110519-25),
Room 5503, Internal Revenue Service, P.O. Box 7604, Ben Franklin
Station, Washington, DC 20044.
FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations,
Shikha K. Patel at (202) 317-6306; concerning submissions of comments
or a public hearing, the Publications and Regulations Section at (202)
317-6091 (not toll-free numbers) or by email at <a href="/cdn-cgi/l/email-protection" class="__cf_email__" data-cfemail="5c2c293e30353f34393d2e35323b2f1c352e2f723b332a">[email protected]</a>
(preferred).
SUPPLEMENTARY INFORMATION:
Authority
This document contains proposed amendments to the Procedure and
Administration Regulations (26 CFR part 301) under sections 6103, 6402,
7430, and 7433 of the Internal Revenue Code (Code) previously issued
under sections 6103(q) and 7805(a) of the Code. This document also
contains a proposed amendment to the Procedure and Administration
Regulations (27 CFR part 70), which governs taxpayer claims for credit
or refund to the Alcohol and Tobacco and Trade Bureau (TTB) for certain
excise taxes assessed under the Code. Section 6103(q) authorizes the
Secretary of the Treasury or the Secretary's delegate (Secretary) ``to
prescribe such other regulations as necessary to carry out the
provisions of [section 6103].'' Section 7805(a) of the Code authorizes
the Secretary to ``prescribe all needful rules and regulations for the
enforcement of [the Code], including all rules and regulations as may
be necessary by reason of any alteration of law to internal revenue.''
Background
I. Changes in References to Department of Justice Organization
Civil and criminal litigation relating to the Internal Revenue laws
has historically been handled or authorized by the Tax Division of the
Department of Justice. The Treasury Department, IRS, and the TTB have
been made aware that the Department of Justice has modified its
organizational structure to divide the responsibilities of the Tax
Division between the Civil Division and Criminal Division of the
Department of Justice. References to the Tax Division appear in 26 CFR
301.6103(h)(2)-1 and 301.6402-2, and 27 CFR 70.123.
Section 301.6103(h)(2)-1 of Title 26 of the Code of Federal
Regulations (Title 26) regulates the requirements and grounds for
disclosures of returns and return information to and by officers and
employees of the Department of Justice in Federal grand jury
proceedings involving tax administration, including preparation for and
investigation of those proceedings. These regulations provide that,
pursuant to section 6103(h)(2), such disclosures must be duly
authorized by or on behalf of the Assistant Attorney General for the
Tax Division of the Department of Justice.
Section 301.6402-2 of Title 26 regulates the requirements, grounds,
and form for a taxpayer to file a claim for credit or refund as well as
methods of refund. In the event that the refund is based on a claim
that has been reduced to judgement, or settled in or as a result of
litigation, 26 CFR 301.6402-2 provides that the check is to be mailed
to the Department of Justice, Tax Division, which will then deliver the
check to the taxpayer or the counsel of record.
Section 70.123 of Title 27 sets forth the requirements, grounds,
and form for filing claims for credits or refunds, as well as methods
of refunds. It provides that checks in payment of claims which have
been reduced to judgment or settled in the course or as a result of
litigation, will be drawn in the name of the person or persons entitled
to the money and will be sent to the Assistant Attorney General, Tax
Division, Department of Justice, for delivery to the taxpayer or the
counsel of record in the court proceeding.
II. Changes in the Processing of Certain Claims at the IRS
Section 7433 provides for civil damages for certain unauthorized
collection actions and was enacted as part of the Technical and
Miscellaneous Revenue Act of 1988, Public Law 100-647, 102 Stat. 3746
(November 10, 1988). The Internal Revenue Service Restructuring and
Reform Act of 1998 (RRA 98), Public Law 105-206, 112 Stat. 685 (July
22, 1998), mandated fundamental reorganization of the IRS.
Additionally, the RRA 98 amended section 7433(e) to require an
exhaustion of administrative remedies. On March 25, 2003, the Treasury
Department and the IRS published final regulations (TD 9050) in the
Federal Register (68 FR 14316) under section 7433 that require, for
collection actions that do not relate to section 362 or section 524 of
title 11, United States Code (Bankruptcy Code), an administrative claim
to first be sent in writing to the ``Area Director, Attn: Compliance
Technical Support Manager'' of the area in which the taxpayer currently
resides in order to exhaust administrative remedies. In contrast, for
collection actions related to violations of section 362 or section 524
of the Bankruptcy Code, an administrative claim must first be sent to
the ``Chief, Local Insolvency Unit,'' for the judicial district in
which the bankruptcy petition that is the basis for the asserted
automatic stay or discharge violation was filed.
As part of that reorganization mandated by the RRA 98, the IRS
shifted from a geographically focused organizational system to one that
focuses on specific categories of taxpayers with similar needs. Since
the regulations were published in 2003, there have been numerous
changes to which IRS offices are responsible for the processing of
these claims. The Internal Revenue Manual (IRM) 1.4.51.2 (June 25,
2025) sets forth the role of processing such claims to the Field
Insolvency Manager and the Centralized Insolvency Operation Manager.
The Insolvency function is now comprised of two operations, Field
Insolvency (FI) and the Centralized Insolvency Operation (CIO). These
two operations work together to provide customer service while
addressing employee satisfaction in delivering improved business
results. Pursuant to IRM 1.4.51.2.5 (2) and (3) (February 12, 2020),
the CIO provides initial clerical processing and sends complex issues
to FI to work. Addressing administrative claims for damages to the CIO
ensures the efficient routing of these claims to the FI office best
suited to address those claims. References to Compliance Technical
Support appear in 26 CFR 301.7433-1. References to Local Insolvency
Units appear in 26 CFR 301.7430-1, 301.7430-2, and 301.7433-2.
Section 301.7430-1(e) of Title 26 defines the manner in which a
party seeking damages for actions involving willful violations of the
automatic stay under section 362 of the Bankruptcy Code or the
discharge provisions under section 524 of the Bankruptcy Code can meet
the exhaustion of administrative remedies requirement of section
7433(d)(1). It provides that a party must file an administrative claim
for damages or for relief from a violation of section 362 or section
524 of the Bankruptcy Code with the Chief, Local Insolvency
[[Page 57939]]
Unit, for the judicial district in which the bankruptcy petition that
is the basis for the asserted automatic stay or discharge violation was
filed. It also refers to actions for damages for willful violation of
the automatic stay as section 362(h) claims. The Bankruptcy Abuse
Prevention and Consumer Protection Act of 2005 (BAPCPA), Public Law
109-8, 119 Stat. 23 (April 20, 2005) recodified section 362(h) of the
Bankruptcy Code in its entirety at section 362(k)(1) of the Bankruptcy
Code.
Section 301.7430-2(c) of Title 26 describes the procedures that a
party must follow to recover reasonable administrative costs regarding
administrative proceedings within the IRS. It provides that
administrative claims with respect to requests for administrative costs
incurred in damage actions for violations of section 362 or section 524
of the Bankruptcy Code should be made to the Chief, Local Insolvency
Unit.
Section 301.7433-1(e) of Title 26 describes the procedures that a
party must follow to file an administrative claim for damages for
unauthorized collection actions to fulfill the exhaustion of
administrative remedies requirement of section 7433(d)(1).
Specifically, an administrative claim for damages shall be sent to the
Area Director, Attn: Compliance Technical Support Manager, of the area
in which the taxpayer currently resides.
Section 301.7433-2(a) of Title 26 describes the civil cause of
action for violation of section 362 or section 524 of the Bankruptcy
Code. Section 301.7433-2(a)(2) of Title 26 clarifies that while section
7433 constitutes the exclusive remedy under the Code for violations of
section 362 or section 524 of the Bankruptcy Code, such exclusivity
does not preclude a cause of action under the Bankruptcy Code relating
to willful violations of the stay formerly codified at section 362(h).
The BAPCPA recodified this cause of action under section 362(k) of the
Bankruptcy Code. Section 301.7433-2(e) of Title 26 describes the
procedures that a party must follow to file an administrative claim for
damages for violations of section 362 or section 524 of the Bankruptcy
Code to fulfill the exhaustion of administrative remedies requirement
of section 7433(d)(1). It provides that an administrative claim for
damages shall be sent to the Chief, Local Insolvency Unit, for the
judicial district in which the taxpayer filed the underlying bankruptcy
case giving rise to the alleged violation.
Explanation of Provisions
These proposed regulations would amend 26 CFR 301.6402-2,
301.6103(h)(2)-1, and 27 CFR 70.123 by updating references to the
``Assistant Attorney General for the Tax Division of the Department of
Justice'' to reflect the Assistant Attorneys General who will supervise
civil and criminal tax functions after the reorganization of the
Department of Justice. Specifically, references in 26 CFR 301.6402-2
and 27 CFR 70.123, which relate to civil matters, would be amended to
read ``Assistant Attorney General for the Civil Division of the
Department of Justice.'' References in 26 CFR 301.6103(h)(2)-1, which
relate to criminal matters, would be amended to read ``Assistant
Attorney General for the Criminal Division of the Department of
Justice.'' Amending these regulations to reflect the correct point of
contact at the Department of Justice will ensure that communications
are sent to the appropriate Assistant Attorney General with supervisory
authority over the appropriate civil or criminal tax function.
Additionally, these proposed regulations would amend 26 CFR
301.7433-1(e)(1) by updating references to ``Area Director, Attn:
Compliance Technical Support Manager'' to reflect that those matters
are currently handled by Collection Advisory Groups. These proposed
regulations would amend 26 CFR 301.7430-1(e), 301.7430-2(c)(2), and
301.7433-2(e)(1) by updating references to ``Chief, Local Insolvency
Unit'' to reflect the shift to the Centralized Insolvency Operation.
Specifically, the reference in 26 CFR 301.7433-1(e)(1) to ``Area
Director, Attn: Compliance Technical Support Manager'' would be amended
to read ``Collection Advisory Group of the area in which the taxpayer
currently resides.'' The references in 26 CFR 301.7430-1(e)(1),
301.7430-1(e)(2), 301.7430-2(c)(2), and 301.7433-2(e)(1) to ``Chief,
Local Insolvency Unit'' would be amended to read ``Centralized
Insolvency Operation.'' Amending these regulations to reflect the
current points of contact within the IRS Collection function will
ensure that claim submissions are sent to the appropriate Collection
contact.
Finally, these proposed regulations would update references to
actions under Bankruptcy Code section 362(h) in 26 CFR 301.7430-1(e)(2)
and 301.7433-2(a)(2) to reflect the revision to the Bankruptcy Code
under the BAPCPA. Amending these regulations to reflect the current
version of the Bankruptcy Code would decrease confusion around
application of that title.
Proposed Effective Date
The changes to the organizational structure of the Department of
Justice and the IRS are already in effect. It would be unnecessary and
contrary to the public interest for the regulations to continue to
reference Department of Justice divisions and IRS business units that
have been reorganized as points of contact. To ensure that
communications are sent to the appropriate Assistant Attorney General
with supervisory authority over the appropriate civil or criminal tax
function at the Department of Justice for matters involving the
internal revenue laws and that administrative claims submitted from
taxpayers seeking civil damages for certain unauthorized collection
actions or awards of administrative costs with respect to certain
administrative proceedings are sent to the appropriate IRS collection
contact, the Treasury Department, the IRS, and TTB find that there is
good cause to dispense with a delayed effective date pursuant to 5
U.S.C. 553(d)(3). The regulations under 26 CFR part 301, as proposed,
and 27 CFR part 70, as proposed, would be effective as of the date of
publication of a Treasury decision adopting these proposed rules with
any necessary modifications as final in the Federal Register.
Proposed Applicability Date
For proposed applicability dates see 26 CFR 301.6402-2(h),
301.6103(h)(2)-1(c), 301.7430-1(h), 301.7430-2(f), 301.7433-1(i); and
301.7433-2(i).
Special Analyses
I. Regulatory Planning and Review
These proposed regulations are not subject to review under section
6(b) of Executive Order 12866 pursuant to the Memorandum of Agreement
(July 4, 2025) between the Treasury Department and the Office of
Management and Budget regarding review of tax regulations.
II. Regulatory Flexibility Act
The Secretary of the Treasury hereby certifies that these proposed
regulations would not have a significant economic impact on a
substantial number of small entities pursuant to the Regulatory
Flexibility Act (5 U.S.C. chapter 6). The proposed regulations would
provide updated points of contact within the Department of Justice and
the IRS, and would not impose any new requirements or obligations upon
small entities. Accordingly, a regulatory
[[Page 57940]]
flexibility analysis under the Regulatory Flexibility Act is not
required.
III. Unfunded Mandates Reform Act
Section 202 of the Unfunded Mandates Reform Act of 1995 (UMRA)
requires that agencies assess anticipated costs and benefits and take
certain other actions before issuing a final rule that includes any
Federal mandate that may result in expenditures in any one year by a
State, local, or Tribal government, in the aggregate, or by the private
sector, of $100 million in 1995 dollars, updated annually for
inflation. These proposed regulations do not include any Federal
mandate that may result in expenditures by State, local, or Tribal
governments, or by the private sector in excess of that threshold.
IV. Executive Order 13132: Federalism
Executive Order 13132 (Federalism) prohibits an agency from
publishing any rule that has federalism implications if the rule either
imposes substantial, direct compliance costs on State and local
governments, and is not required by statute, or preempts State law,
unless the agency meets the consultation and funding requirements of
section 6 of the Executive order. These proposed regulations do not
have federalism implications and do not impose substantial direct
compliance costs on State and local governments or preempt State law
within the meaning of the Executive order.
V. Small Business Administration
Pursuant to section 7805(f) of the Code, this notice of proposed
rulemaking will be submitted to the Chief Counsel for the Office of
Advocacy of the Small Business Administration for comment on its impact
on small business.
Comments and Request for a Public Hearing
Before these proposed regulations are adopted as final regulations,
consideration will be given to any comments that are timely submitted
to the IRS as prescribed in this preamble under the ADDRESSES heading.
The Treasury Department, the IRS, and TTB request comments on all
aspects of the proposed regulations. Any comments submitted will be
available at <a href="https://www.regulations.gov">https://www.regulations.gov</a> or upon request. A public
hearing will be scheduled if requested in writing by any person who
timely submits electronic or written comments. Requests for a public
hearing are also encouraged to be made electronically. If a public
hearing is scheduled, notice of the date and time for the public
hearing will be published in the Federal Register.
Drafting Information
The principal author of these regulations is Shikha K. Patel of the
Office of Associate Chief Counsel (Procedure and Administration).
However, other personnel from the Treasury Department participated in
the development of the regulations.
Lists of Subjects
26 CFR Part 301
Employment taxes, Estate taxes, Excise taxes, Gift taxes, Income
taxes, Penalties, Reporting and recordkeeping requirements.
27 CFR Part 70
Administrative practice and procedure, Claims, Excise taxes,
Freedom of information, Penalties, Reporting and recordkeeping
requirements, Surety bonds.
Proposed Amendments to the Regulations
Accordingly, the IRS proposes to amend 26 CFR part 301 and the
Treasury Department proposes to amend 27 CFR part 70 as follows:
PART 301--PROCEDURE AND ADMINISTRATION
0
Paragraph 1. The authority citation for 26 CFR part 301 continues to
read, in part, as follows:
Authority: 26 U.S.C. 7805.
0
Par. 2. Section 301.6402-2 is amended by revising paragraphs (f)(2) and
(h) to read as follows:
Sec. 301.6402-2 Claims for credit or refund.
* * * * *
(f) * * *
(2) Checks in payment of claims which have either been reduced to
judgment or settled in the course or as a result of litigation will be
drawn in the name of the person or persons entitled to the money and
will be sent to the Assistant Attorney General for the Civil Division
of the Department of Justice, or such person's designee, for delivery
to the taxpayer or the counsel of record in the court proceeding.
* * * * *
(h) Applicability dates. This section applies on or after December
15, 2025. For periods before December 15, 2025, see this section as in
effect and contained in 26 CFR part 301, revised as of April 1, 2025.
0
Par. 3. Section 301.6103(h)(2)-1 is amended by revising paragraph
(a)(2)(ii) and adding paragraph (c) to read as follows:
Sec. 301.6103(h)(2)-1 Disclosure of returns and return information
(including taxpayer return information) to and by officers and
employees of the Department of Justice for use in Federal grand jury
proceeding, or in preparation for proceeding or investigation,
involving tax administration.
(a) * * *
(2) * * *
(ii) In connection with any Federal grand jury proceeding, or
preparation for any proceeding (or with an investigation which may
result in such a proceeding), described in paragraph (a)(1) of this
section which also involves enforcement of a specific Federal criminal
statute other than one described in paragraph (a)(1) of this section to
which the United States is or may be a party, provided such matter
involves or arises out of the particular facts and circumstances giving
rise to the proceeding (or investigation) described in paragraph (a)(1)
of this section and further provided the tax portion of such proceeding
(or investigation) has been duly authorized by or on behalf of the
Assistant Attorney General for the Criminal Division of the Department
of Justice, pursuant to the request of the Secretary, as a proceeding
(or investigation) described in paragraph (a)(1) of this section. If,
in the course of a Federal grand jury proceeding, or preparation for a
proceeding (or the conduct of an investigation which may result in such
a proceeding), described in this paragraph (a)(2)(ii), the tax
administration portion thereof is terminated for any reason, any
further use or disclosure of such returns or taxpayer return
information in such Federal grand jury proceeding, or preparation or
investigation, with respect to the remaining portion may be made only
pursuant to, and upon the grant of, a court order as provided by
section 6103(i)(1)(A), provided, however, that the returns and taxpayer
return information may in any event be used for purposes of obtaining
the necessary court order.
* * * * *
(c) Applicability date. This section applies on or after December
15, 2025. For periods before December 15, 2025, see this section as in
effect and contained in 26 CFR part 301, revised as of April 1, 2025.
0
Par. 4. Section 301.7430-1 is amended by revising paragraphs (e) and
(h) to read as follows:
Sec. 301.7430-1 Exhaustion of administrative remedies.
* * * * *
(e) * * * (1) Section 7433 claims. A party has not exhausted
administrative remedies within the Internal Revenue
[[Page 57941]]
Service with respect to asserted violations of the automatic stay under
section 362 of title 11, United States Code (Bankruptcy Code) or the
provisions under section 524 of the Bankruptcy Code unless it files an
administrative claim for damages or for relief from a violation of
section 362 or section 524 of the Bankruptcy Code with the Centralized
Insolvency Operation or successor function and satisfies the other
conditions set forth in Sec. 301.7433-2(d) prior to filing a petition
under section 7433.
(2) Section 362(k) claims. A party has not exhausted administrative
remedies within the Internal Revenue Service with respect to asserted
violations of the automatic stay under section 362 of the Bankruptcy
Code unless it files an administrative claim for relief from a
violation of section 362 of the Bankruptcy Code with the Centralized
Insolvency Operation pursuant to Sec. 301.7433-2(e) and satisfies the
other conditions set forth in Sec. 301.7433-2(d) prior to filing a
petition under section 362(k) (formerly 362(h)) of the Bankruptcy Code.
* * * * *
(h) Applicability date. This section applies to court proceedings
described in section 7430 filed in a court of the United States
(including the Tax Court and the Court of Federal Claims) after
December 15, 2025. For such court proceedings on or before December 15,
2025, see this section as in effect and contained in 26 CFR part 301,
revised as of April 1, 2025.
0
Par. 5. Section 301.7430-2 is amended by revising paragraph (c)(2) and
adding paragraph (f) to read as follows:
Sec. 301.7430-2 Requirements and procedures for recovery of
reasonable administrative costs.
* * * * *
(c) * * *
(2) Where request must be filed. A request required by paragraph
(c)(1) of this section must be filed with the Internal Revenue Service
personnel who have jurisdiction over the tax matter underlying the
claim for costs, except that requests with respect to administrative
proceedings defined by Sec. 301.7430-8(c) should be made to the
Centralized Insolvency Operation. However, if those persons are unknown
to the taxpayer making the request, the taxpayer may send the request
to the Internal Revenue Service office that considered the underlying
matter.
* * * * *
(f) Applicability date. This section applies on or after December
15, 2025. For periods before December 15, 2025, see this section as in
effect and contained in 26 CFR part 301, revised as of April 1, 2025.
0
Par. 6. Section 301.7433-1 is amended by revising paragraphs (e)(1) and
(i) to read as follows.
Sec. 301.7433-1 Civil cause of action for certain unauthorized
collection actions.
* * * * *
(e) * * *
(1) Manner. An administrative claim for the lesser of $1,000,000
($100,000 in the case of negligence) or actual, direct economic damages
as defined in paragraph (b) of this section shall be sent in writing to
the Collection Advisory Group of the area in which the taxpayer
currently resides.
* * * * *
(i) Applicability dates. This section applies on or after December
15, 2025. For periods before December 15, 2025, see this section as in
effect and contained in 26 CFR part 301, revised as of April 1, 2025.
0
Par. 7. Section 301.7433-2 is amended by revising paragraphs (a)(2),
(e)(1), and (i) to read as follows.
Sec. 301.7433-2 Civil cause of action for violation of section 362 or
524 of the Bankruptcy Code.
(a) * * *
(2) An action under this section constitutes the exclusive remedy
under the Internal Revenue Code for violations of sections 362 and 524
of title 11, United States Code (Bankruptcy Code). In addition,
taxpayers injured by violations of section 362 of the Bankruptcy Code
may maintain actions under section 362(k) (formerly section 362(h)) of
the Bankruptcy Code (relating to an individual injured by a willful
violation of the stay). However, any administrative or litigation costs
in connection with an action under section 362(k) (formerly section
362(h)) may be awarded, if at all, only under section 7430 of the
Internal Revenue Code.
* * * * *
(e) * * * (1) Manner. An administrative claim for the lesser of
$1,000,000 or actual, direct economic damages as defined in paragraph
(b) of this section shall be sent in writing to the Centralized
Insolvency Operation.
* * * * *
(i) Applicability date. This section is applicable to actions taken
by Internal Revenue Service officials after December 15, 2025. For
actions taken by Internal Revenue Service officials on or before
December 15, 2025, see this section as in effect and contained in 26
CFR part 301, revised as of April 1, 2025.
PART 70--PROCEDURE AND ADMINISTRATION
0
Par. 8. The authority citation for 27 CFR part 70 continues to read in
part as follows:
Authority: 5 U.S.C. 301 and 552; 26 U.S.C. 4181, 4182, 5123,
5203, 5207, 5275, 5367, 5415, 5504, 5555, 5684(a), 5741, 5761(b),
5802, 6020, 6021, 6064, 6102, 6109, 6155, 6159, 6201, 6203, 6204,
6301, 6303, 6311, 6313, 6314, 6321, 6323, 6325, 6326, 6331-6343,
6401-6404, 6407, 6416, 6423, 6501-6503, 6511, 6513, 6514, 6532,
6601, 6602, 6611, 6621, 6622, 6651, 6653, 6656-6658, 6665, 6671,
6672, 6701, 6723, 6801, 6862, 6863, 6901, 7011, 7101, 7102, 7121,
7122, 7207, 7209, 7214, 7304, 7401, 7403, 7406, 7423, 7424, 7425,
7426, 7429, 7430, 7432, 7502, 7503, 7505, 7506, 7513, 7601-7606,
7608-7610, 7622, 7623, 7653, 7805.
0
Par. 9. Section 70.123 is amended by revising paragraph (e)(2) to read
as follows:
Sec. 70.123 Claims for credit or refund.
* * * * *
(e) * * *
(2) Checks in payment of claims which have either been reduced to
judgment or settled in the course or as a result of litigation will be
drawn in the name of the person or persons entitled to the money and
will be sent to the Assistant Attorney General for the Civil Division
of the Department of Justice, or such person's designee, for delivery
to the taxpayer or the counsel of record in the court proceeding.
Frank J. Bisignano,
Chief Executive Officer.
Approved: October 14, 2025
Kenneth J. Kies,
Assistant Secretary of the Treasury (Tax Policy).
[FR Doc. 2025-22825 Filed 12-12-25; 8:45 am]
BILLING CODE 4831-GV-P
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