U.S. Court of Appeals for the D.C. Circuit
Center for Taxpayer Rights v. IRS
September 8, 2026
Summary
The D.C. Circuit affirmed the district court's preliminary injunction staying the IRS's Data-Exchange Procedure, holding that the procedure constitutes final agency action subject to APA review, that the Center for Taxpayer Rights has standing, and that the Internal Revenue Code does not preclude APA review. The court found the plaintiffs likely to succeed on the merits and that the equitable factors favored injunctive relief.