Ezel / IRS Rulings / 200029005

CCA 200029005: Bankruptcy and lien advice is largely redacted

Number
200029005
Outcome
Other outcome
Document type
Chief Counsel Advice
IRS subject
LIENS: Removal: Release; BANKRUPTCY CODE CASES: Automatic stay (Sec. 362)
Topics
Income and deductions
Code sections
§ 6325
Ruling dated
March 2, 2000
Publicly released
July 21, 2000
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2000, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2000
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel pre-reviewed a district counsel memorandum involving debtors in a bankruptcy case. The visible facts say the debtors filed individual income tax returns without payment shortly before a redacted event, and the bankruptcy court later converted the case. The release's issue, conclusion, and most analysis are redacted, so it does not disclose the advice's substantive result. A visible footnote quotes section 6325(f)(1)(A) on the effect of a certificate releasing a tax lien.

Ruling snapshot

  • Question: The specific question is redacted in the IRS release.
  • Outcome: The conclusion is redacted.
  • Key authorities: IRC § 6325(f)(1)(A), the only visible Code provision cited in the text.

Full text (IRS public release)

DEPARTMENT OF THE TREASURY
I N T E R N AL R E V E N U E S E R V I C E WASHINGTON, D.C. 20224
March 2, 2000

Number: 200029005
GL-100228-00/CC:EL:GL:BR:1
Release Date: 7/21/2000
UILC: 51.49.03-00
09.08.00-00
9999.98-00

MEMORANDUM FOR ASSISTANT DISTRICT COUNSEL, PENNSYLVANIA DISTRICT, PHILADELPHIA

FROM: Chief, Branch 1
(General Litigation)

SUBJECT:

This responds to your request that we pre-review your memorandum regarding the
above subject matter. This document is not to be cited as precedent.

ISSUE:

CONCLUSION:

FACTS:

The debtors’ bankruptcy case was commenced on
. Shortly before
, the debtors filed their individual income tax
returns (Forms 1040) for the years
without remittance. On
GL-100228-00
-2-

, the bankruptcy court converted the case to a bankruptcy.

LAW AND ANALYSIS

1/

1/
GL-100228-00
-3-

If you have any further questions, please call the branch.

cc: Assistant Regional Counsel (GL) NER

2/ I.R.C. § 6325(f) (1)(A) provides that a certificate of release shall be conclusive that the lien referred to in such certificate is extinguished.

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