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As of October 8, 2026, the IRS is barred from making further disclosures under the challenged Data-Exchange Procedure unless it strictly follows federal law and notifies the court about future requests. The D.C. Circuit affirmed that injunction on September 8, finding that the procedure did not meet the requirements for sharing tax information. The ruling blocks this particular process; it does not eliminate every legal route for disclosing an address to law enforcement.
What the September 2026 ruling stopped
In Center for Taxpayer Rights v. IRS, the U.S. Court of Appeals for the D.C. Circuit affirmed a preliminary injunction against the IRS Data-Exchange Procedure used to process ICE’s mass address request. The court held that the procedure did not comply with Internal Revenue Code section 6103(i)(2), which sets conditions for certain disclosures in nontax criminal matters. The injunction means the IRS cannot continue disclosures under that procedure unless statutory requirements are strictly followed and the court is notified of future requests. Read the September 8, 2026 opinion.
The court’s holding is about the challenged procedure, not a categorical ban on every possible address disclosure. Section 6103(i)(2) can permit disclosure to specified government officials for qualifying nontax criminal investigations when the request satisfies the statute. A separate D.C. Circuit case addressed that legal route in February 2026.
How the IRS matched ICE’s requests
ICE Acting Director Todd Lyons asked on June 27, 2025, for the last-known addresses of 1.28 million people. The IRS began processing the requests in July and developed the Data-Exchange Procedure for the mass request. The D.C. Circuit’s September 2026 opinion says the IRS disclosed 47,289 records; more than 90% of the disclosed records resulted from matching taxpayer identification numbers (TINs).
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When ICE supplied a TIN
A TIN could be a Social Security number or an Individual Taxpayer Identification Number (ITIN). The IRS searched its records and returned the latest address associated with a matching TIN. Under the procedure, a match could be returned even if ICE’s address field did not contain a complete address. The court said the process accepted a five- or nine-digit value in that field without requiring a ZIP code or street, city, and state information.
When ICE did not supply a TIN
The IRS instead searched using the name and address ICE provided. It returned information only when ICE supplied a complete matching address. This route differed from TIN matching because an incomplete address did not produce a result.
Why the validation process mattered
The court also objected to how the procedure checked the ICE point-of-contact field. A nonempty field could be accepted without confirming that it identified an ICE employee personally and directly involved in the particular criminal investigation. The court found these safeguards inadequate to ensure that requests met section 6103(i)(2)’s requirements.
Why the February and September rulings are not contradictory
Both cases came from the D.C. Circuit, but they considered different challenges and records. The February decision addressed the governing memorandum of understanding (MOU); the September decision examined how the IRS implemented the mass request through the Data-Exchange Procedure.
| Decision | What it addressed | Posture and result | Practical effect |
|---|---|---|---|
| Centro de Trabajadores Unidos v. Bessent, February 24, 2026 | A challenge to the April 7, 2025 MOU between the IRS and DHS setting out procedures for ICE requests under section 6103(i)(2). | The D.C. Circuit affirmed denial of a preliminary injunction. It concluded that the statute can authorize address disclosures on a valid request. | The decision did not approve every later request or the specific mechanics of the mass-request procedure challenged in September. |
| Center for Taxpayer Rights v. IRS, September 8, 2026 | The IRS Data-Exchange Procedure used to handle the mass request and its matching and validation steps. | The D.C. Circuit affirmed a preliminary injunction after finding that the procedure failed to ensure statutory requirements were met. | Further disclosures under that procedure are halted unless the law is strictly followed and the court is notified of future requests. |
In February, the court stated that section 6103(i)(2) “authorizes IRS to disclose address information, to specific government officials, for use in nontax criminal investigations, and only in response to a valid request.” That ruling concerned the MOU challenge and its preliminary-injunction record. In September, the court found the implemented procedure did not adequately ensure that a request was valid. The two decisions address different questions: whether the statute provides a limited disclosure path, and whether this particular process complied with it. Read the February 24, 2026 opinion.
What the ruling does not establish
The September decision does not resolve every question about taxpayer records or immigration enforcement. The available court record does not establish how every record already transferred to ICE is being handled, whether a materially different future request would satisfy the statute, or the outcome of every other lawsuit.
The district court record described plaintiffs’ concerns that address sharing could undermine trust and deter people from filing taxes. Those concerns are not a quantified finding about filing behavior. The available decisions do not measure whether the policy changed tax filing rates.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What this means for people who file with an ITIN
An ITIN is a type of TIN, and the procedure used TIN matches to retrieve addresses associated with IRS records. But the ruling does not say that an ITIN automatically exposes a filer’s address to ICE, nor does it establish that addresses can never be disclosed. The legal question is whether a particular request and disclosure meet section 6103(i)(2), and the injunction targets the challenged procedure’s failures to verify those requirements.
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