Press Room

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

Press Release Jul 17, 2014

Dallas, Texas – Ryan, a leading global tax services firm with the largest indirect and property tax practices in North America, today announced that 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.

“This is a tremendous result in a long-fought battle to protect taxpayers and their representatives from the IRS’s efforts to limit their ability to pursue valid claims,” said Gerry L. Ridgely, Jr., Executive Vice President and Vice Chairman of Ryan.  “We believe the Court reached the correct result, and we are very gratified that taxpayers, and not the IRS, have the right to determine the fee arrangement between themselves and their representatives.”

“Ryan is very pleased with the ruling and proud to have led the charge against these overreaching regulations that improperly restricted the ability of taxpayers with bona fide refund claims to obtain representation to pursue their statutory right to a tax refund,” said G. Brint Ryan, Chairman and CEO of Ryan. “We will continue to aggressively defend the rights of our clients, as well as taxpayers everywhere, from unlawful and burdensome tax regulations.  As James Madison so famously said in 1788, ‘There are more instances of the abridgment of the freedom of the people by gradual and silent encroachments of those in power than by violent and sudden usurpations.’”

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

About Ryan

Ryan, an award-winning global tax services and software provider, is the largest Firm in the world dedicated exclusively to business taxes. With global headquarters in Dallas, Texas, the Firm provides an integrated suite of federal, state, local, and international tax services on a multijurisdictional basis, including tax recovery, consulting, advocacy, compliance, and technology services. Ryan is an 11-time recipient of the International Service Excellence Award from the Customer Service Institute of America (CSIA) for its commitment to world-class client service. Empowered by the dynamic myRyan work environment, which is widely recognized as the most innovative in the tax services industry, Ryan’s multidisciplinary team of more than 4,800 professionals and associates serves over 30,000 clients in more than 80 countries, including many of the world’s most prominent Global 5000 companies. More information about Ryan can be found at


Melodie Elliott
Director, Content and Communications Marketing