CCA 200848058: Economic stimulus answer refers to earned income

Number
200848058
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Citizens or Residents of the United States Living Abroad
Topics
Code sections
§ 911
Ruling dated
July 28, 2008
Publicly released
November 28, 2008

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This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2008, 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 2008
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 clarified that an earlier reference was to “earned income.” The email added that, to the author's understanding, the economic stimulus payment applied only to types of income such as wages and salaries. The released text does not disclose the underlying question or provide further legal analysis.

Ruling snapshot

  • Question: What income concept applied to the redacted economic stimulus payment question?
  • Outcome: Advice given. The response referred to earned income, including income such as wages and salaries.
  • Key authorities: No authority is cited in the released email.

Full text (IRS public release)

ID: CCA_2008072812342216 Number: 200848058
Office: ------------------
Release Date: 11/28/2008

UILC: 911.00-00

From: --------------
Sent: Monday, July 28, 2008 12:34:24 PM
To: --------------------
Cc:
Subject: RE: Economic Stimulus Payment Question ---------

-------------

I'm referring to "earned income". Also, if I'm not mistaken, the economic stimulus payment only applies to
types of income such as wages, salaries, etc.

------

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