Ezel / IRS Rulings / 200851051

CCA 200851051: Brief response on ownership interests in capital assets

Number
200851051
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Right or Obligation With Respect to Personal Property
Topics
Property transactions and exchanges
Code sections
§ 1234A
Ruling dated
October 27, 2008
Publicly released
December 19, 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

The released email contains only the sentence fragment, "Not to ownership interests in capital assets." Its subject is redacted, and the message does not identify the question or give a reason. The IRS classified it under UILC 1234A.01-00, but the text itself does not mention section 1234A or explain how that section applies.

Ruling snapshot

  • Question: The question is not visible in this release.
  • Outcome: Advice given as a sentence fragment: "Not to ownership interests in capital assets."
  • Key authorities: None cited in the message.

Full text (IRS public release)

ID: CCA_2008102716262250 Number: 200851051
Office: ---------------- Release Date: 12/19/2008

UILC: 1234A.01-00

From: --------------------
Sent: Monday, October 27, 2008 4:26:23 PM
To: ----------------------
Cc:
Subject: RE: ---------

Not to ownership interests in capital assets.

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