Another Legal Victory For Trump In The Fight To Defend American Soil

A federal appeals court handed President Donald Trump another win Tuesday, allowing his administration to continue a policy permitting the Internal Revenue Service to share certain taxpayer address information with Immigration and Customs Enforcement for criminal investigations.

Immigration advocacy groups had sought a preliminary injunction to block the policy, arguing that the IRS was unlawfully disclosing protected taxpayer information. But the U.S. Court of Appeals for the D.C. Circuit affirmed a lower court’s decision denying that request, keeping the policy in place while the case moves forward.

The dispute traces back to early 2025, when reports surfaced that ICE was seeking the last known addresses of roughly 700,000 illegal immigrants from the IRS. On April 7, 2025, the IRS and the Department of Homeland Security formalized the arrangement through a Memorandum of Understanding outlining how ICE could request address information under federal law.

The agreement relies on a provision of tax law that allows the IRS to share certain information for non-tax criminal investigations. In the past, the IRS interpreted the statute as barring the disclosure of mailing addresses on their own. The new policy reversed that interpretation, permitting the agency to provide a taxpayer’s last known address if ICE submits a valid request tied to a criminal investigation.

Advocacy groups argued that mailing addresses qualify as protected “taxpayer return information,” which typically requires a court order before disclosure. They claimed the administration was sidestepping long-standing privacy safeguards.

The appeals court disagreed, concluding that the “best reading” of the statute allows the disclosure of address information in certain criminal investigations. The law permits the sharing of “return information” but explicitly excludes a taxpayer’s “identity” from the more heavily protected category of “taxpayer return information.” Because the statute defines “identity” to include a mailing address, the court found that addresses do not receive the heightened protections the challengers asserted.

The court also emphasized that other sections of the statute explicitly require a court order for disclosure, but this particular provision does not. Judges declined to “read into the statute words that aren’t there,” determining that the law clearly authorizes the IRS to provide address information in response to a proper administrative request.

Advocacy groups further argued that the IRS violated the Administrative Procedure Act by reversing its prior interpretation without sufficient explanation. The court rejected that claim as well, finding that the memorandum was not a binding final agency action but rather a policy clarification. Citing the Supreme Court’s 2024 decision in Loper Bright Enterprises v. Raimondo, the panel noted that courts no longer defer to agency interpretations of ambiguous statutes. Since the judges concluded the statute’s best reading permits address disclosure, sending the matter back to the IRS for further explanation would have been a “useless formality.”

With the preliminary injunction denied, the April 7, 2025 memorandum allowing ICE to request last-known taxpayer addresses remains in effect as litigation continues. For the Trump administration, the ruling marks another courtroom victory in its broader effort to strengthen immigration enforcement and prioritize the protection of American communities.