Friend2Friend, Inc, a social network provider,is cited by an Internal Revenue Service (IRS) representative for an underpayment of federal income tax. Friend2Friend's accountants believed that the agency overlooked some of the firm's legitimate tax deductions and credits. Erin, Friend2Friend's chief executive officer, wants to challenge the assessment. What are Erin and Friend2Friend's next steps?
Friend2Friend cannot ask a court for an injunction to stop the en-forcement of the regulation until it has exhausted its administrative remedies.
Friend2Friend's first step would be to appeal the IRS representa¬tive's order to the agency. After investigating, the agency might negoti¬ate a settlement with Friend2Friend. If a settlement cannot be reached, and the agency still considers Friend2Friend in violation of the rule, the agency might is¬sue a complaint against the firm. This would be an attempt to bring the firm into compliance and may be accompanied by a press release. Friend2Friend can respond by filing an answer to the charge, and may also re¬spond with its own press release. If there is no settlement, there may be a hearing before an administrative law judge (ALJ). After the hearing, the ALJ will issue an initial order, and if Friend2Friend is still dissatisfied, the firm can appeal to the commission that governs the agency. If Friend2Friend is dis¬satisfied with the commission's decision, it may appeal to a federal court of appeals. If there is no appeal, or if the commission and the court re¬fuse to review the case, the ALJ's order becomes final. Ultimately, Friend2Friend may appeal adverse rulings to the United States Supreme Court.
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