Okay, I'm back.
Re what you must prove in order to get an order to the IRS to take action, without reviewing the court's decision and your original complaint, I'm engaging in a bit of speculation here.
The “modern” zone of interests formulation originated as a limitation on the cause of action for judicial review under the Administrative Procedure Act (APA). Lexmark Int'l, Inc. v. Static Control Components, Inc., 134 S.Ct. 1377, 1388 (2014) (citing Association of Data Processing Service Organizations, Inc. v. Camp, 397 U.S. 150 (1970). The APA grants federal court standing to any “person suffering legal wrong because of agency action, or adversely affected or aggrieved by agency action within the meaning of a relevant statute.” 5 U.S.C. § 702.
The Supreme Court has interpreted the APA standing language to require that the “interest sought to be protected by the complainant is arguably within the zone of interests to be protected or regulated by the statute or constitutional guarantee in question.” Association of Data Processing Service Organizations, Inc. v. Camp, supra, 397 U.S. at 153.
In the APA context, use of the word “arguably” indicates “the benefit of any doubt goes to the plaintiff” and the zone of interests test “forecloses suit only when a plaintiff's interests are so marginally related to or inconsistent with the purposes implicit in the statute that it cannot reasonably be assumed that Congress authorized that plaintiff to sue.” Lexmark Int'l, Inc. v. Static Control Components, Inc., supra, 134 S.Ct. at 1389; see also Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians v. Patchak, 132 S.Ct. 2199, 2210 (2012) (zone of interests test in APA contexts is not “especially demanding”).
In short, if you can show that the IRS has not followed the law, and that you are injured by the IRS's failure, then you have made out a complaint for which relief may be granted.
Concerning what you must show on appeal, if you raised the above-described issues in the trial court, and the matter was decided against you, then you are entitled to appeal the decision.
Concerning my reviewing your brief, you need to contact me via email. Do not ask the question in this forum, because I will be unable to assist. I assume you still have the address. If not, I will send you an additional services offer, so that I can provide it to you again.
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