Reality Check

Overview


Bobbi Bierhals explained that a U.S. Tax Court judge could issue a ruling on IRA rollovers that is contrary to guidance published by the Internal Revenue Service because “IRS publications don’t have any legal significance. The court isn’t bound in any way by those pronouncements of the IRS. And the words of the Internal Revenue Code trump proposed regulations.” Ms. Bierhals added that the judge in the case looked to the exact wording of the relevant Revenue Code section as the basis for his ruling.