George Hani was quoted regarding Facebook Inc.'s lawsuit against the Internal Revenue Service (IRS) in which Facebook asserts that the IRS violated its rights to bring its case to IRS Appeals. Facebook argues that its right to an administrative settlement forum is provided by Congress in the Tax Bill of Rights, enacted in 2015. The company's position has some validity since the commissioner lacks the authority to provide the jurisdiction for cases to be heard in tax court, Hani said. "If the commissioner can't give a taxpayer a right to go to court that doesn't already exist elsewhere in the statue by Congress, then in my mind what would make that provision meaningful is it has to be an administrative independent appeal because that's what the commissioner can control," he said. "I don't think Facebook is stretching, certainly, and I do think that the statute could be drafted more clearly." Hani also commented that Rev. Proc. 2016-22 deserves consideration generally because it essentially created a new category of cases that could be denied access to Appeals without providing a procedure to ensure the taxpayer is fully heard and able to explain why an administrative appeal is in the interests of sound tax administration, Hani said. "The old revenue procedure had kind of a collaborative decision-making process where appeals was involved. Now appeals doesn't seem to be part of the decision. … This is still an important question for the independence of appeals and the function of appeals to try to keep our court systems from being clogged up," he said.