D.C. Circuit Affirms the Block on the IRS Procedure That Sent Taxpayer Addresses to ICE (Center for Taxpayer Rights v. IRS)

A D.C. Circuit panel, in an opinion by Judge Cornelia Pillard, affirmed Judge Colleen Kollar-Kotelly’s order halting the IRS procedure for giving ICE taxpayer addresses. The court found the plaintiffs “likely to succeed on the merits” and wrote: “The procedure failed to ensure that ICE’s requests complied with statutory requirements.” By the time the district court acted, the IRS had already disclosed more than 47,000 records.

What the district court had found. The IRS’s disclosure of address information to ICE “was contrary to law because it violated several provisions of Internal Revenue Code Section 6103(i)(2)”. It also held that the IRS’s implementation of the policy “was arbitrary and capricious”. The rule at issue is the tax code’s confidentiality statute, not the Privacy Act.

Limits. This affirms preliminary relief, not a final judgment. The parties told the district court that a petition for rehearing is due by “October 23, 2026”. “ICE is not a party to this litigation.” The order restrains the IRS; it does not order ICE to return the records already sent.

Ledger class. FOUND in the district court; the appeals court affirmed. A separate D.C. Circuit panel reached the opposite result on the underlying IRS-ICE memorandum of understanding in an earlier case. That opinion is known here only through the government’s notice of supplemental authority; see the ledger note.