IRS 3rd party suits 26 USC 7609

Federal civil · Tax · 3,578 cases filed and closed (1988–present).

3,578

Cases filed

78.4%

Ended before a merits judgment

2,804 of 3,578 cases

14.1%

Plaintiff win

of 774 merits judgments

76.5%

Defendant win

of merits judgments

Most cases never reach a ruling on the merits. Of 3,578 filed, 78.4% closed without one — settled, dismissed, transferred, or remanded. The win rates above describe only the 774 that a judge actually decided.

How they closed

Dismissed61.8%
Defendant win16.5%
Settled13.6%
Plaintiff win3%
Decided — other1.3%
Transferred1.3%
Remanded1.1%
Mixed0.7%
Other0.5%
Affirmed0.1%

Where you file matters

The same claim resolves differently across districts. Plaintiff-win rate among merits judgments, busiest courts first.

Read the law behind irs 3rd party suits 26 usc 7609

Source: FJC Integrated Database (public domain), via CourtListener — federal civil cases filed and terminated, 1988–present. Figures are descriptive statistics about how cases of a given type have closed in a given court. They describe the historical record — not a prediction or assessment of any specific case. Not legal advice.