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.