Ezel / IRS Rulings / 200848063

CCA 200848063: Section 6103 does not require the referenced notification

Number
200848063
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Disclosure of Individuals Return; Disclosure by NonFederal Employees
Topics
Procedure, penalties, and administration
Code sections
§ 6103, § 7431
Ruling dated
August 7, 2008
Publicly released
November 28, 2008
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 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 advised that IRC § 6103 clearly did not require a referenced notification. The released email does not identify what notification was under discussion. It also expressed the preliminary view that the Internal Revenue Manual did not require it as a matter of policy, while proposing to check and confirm that point.

Ruling snapshot

  • Question: Does IRC § 6103 require the notification discussed in the redacted correspondence?
  • Outcome: Advice given. The statute does not require it; the Internal Revenue Manual point remained to be confirmed.
  • Key authorities: IRC §§ 6103 and 7431.

Full text (IRS public release)

ID: CCA-871025-08 Number: 200848063
Office: --------------
Release Date: 11/28/2008

UILC: 6103.05-01, 7431.01-01

From: ---------------------------
Sent: Thursday, August 07, 2008 10:25 AM
To: ----------------------------------------------
Cc: -------------------------------------------------
Subject: RE: Emailing: search

Section 6103 clearly does not require such notification. As a matter of
policy, I don't believe the IRM requires it either. We can check and
confirm.

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