News and Insights

United States District Court Rules in Favor of Ryan Principal in Suit Against IRS Challenging Circular 230 Restrictions on Contingent Fees

Tax Development Jul 17, 2014

Judge Christopher R. Cooper of the United States District Court for the District of Columbia has ruled in favor of Ryan Executive Vice President and Vice Chairman Gerry L. Ridgely, Jr. in his suit against the United States Secretary of the Treasury and the Commissioner of the Internal Revenue Service (IRS) challenging certain 2007 regulations enacted by the IRS, commonly known as Circular 230. The order, rendered July 16, 2014, invalidates and permanently enjoins the IRS from enforcing the Circular 230 restrictions prohibiting the use of contingent fee arrangements for ordinary refund claims and amended returns.

The suit was filed in 2012 to challenge the Circular 230 provisions generally prohibiting attorneys, certified public accountants (CPAs), and other practitioners from entering into contingent fee arrangements for services rendered in connection with certain matters before the IRS, including the preparation and filing of claims for refunds after a taxpayer has filed its original tax return, but before the IRS has initiated an audit of the return. 

For more information about this ruling, please see the Order and Memorandum Opinion.


G. Brint Ryan
Chairman and CEO