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Tax Coda

Court blocks IRS policy that shared taxpayer addresses with ICE

Center for Taxpayer Rights v. IRS, NO. 1:25-CV-00457. United States District Court For The District Of Columbia.

Nov 25, 2025
∙ Paid

A federal court halted the IRS’s new data-sharing policy after finding that the agency likely violated §6103 and the APA when it disclosed about 47,000 taxpayer addresses to ICE.

Holding

The court held that the IRS’s Address-Sharing Policy is final agency action subject to APA review and that plaintiffs showed a substantial likelihood of success on their claims that the policy was arbitrary, capricious, and contrary to §6103(i)(2).

The court granted preliminary relief and partially denied the government’s motion to dismiss.

Why It Matters

  • The decision restricts IRS information-sharing with immigration authorities under §6103.

  • The ruling signals that changes to IRS confidentiality policy must be explicit and well-explained in the administrative record.

  • The court identified narrow circumstances where taxpayer address information can be shared only for criminal enforcement, not civil immigration actions.

  • Agencies must consider reliance interests when altering long-standing confidentiality pract…

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