CCA 200851075: A post office box works on a Form 8821 if it is the taxpayer's mailing address

Plain-English summary

A narrow question with a short answer, and the answer is reached by following a definition through two provisions.

Form 8821 is the tax information authorization: a taxpayer uses it to let someone else receive their confidential tax information, without appointing that person to represent them. Because it opens a channel to protected information, the Service has to be able to tell that the person signing it is the taxpayer whose information will be released. That is why the form asks for identifying details, and why the question arose whether a post office box is good enough as the taxpayer's own address.

The writer sees no reason it is not. The route is that the regulations under section 6103(c), which governs disclosure to a taxpayer's designee, require the taxpayer to provide their identity, and identity is defined in section 6103(b)(6). That definition speaks of a mailing address. So if the box is in fact the taxpayer's mailing address, it satisfies the requirement.

The reasoning turns on a distinction that is easy to miss. The statute does not ask where the taxpayer lives, it asks how mail reaches them. A post office box fails a residence test and passes a mailing address test, and the definition that governs here is the second kind. The writer's phrasing keeps the factual condition attached: it is fine if the box is the taxpayer's mailing address, which leaves room for a box that is somebody else's or is not used for the taxpayer's mail.

This is a working answer in an email thread, framed as the writer not being aware of any reason the box cannot be used rather than as an affirmative holding, and it addresses only the address element. Nothing in it speaks to the other requirements for a valid authorization, and the closing block is redacted.

This is a clean digital release rather than a scan, so no OCR correction was needed. Kept as released: the contractions "I'm" and "it's"; the section cited as "IRC 6103(b)(6)" without a section symbol; and the stray dash left on its own line at the end.

Ruling snapshot

• Question: May a taxpayer give a post office box as their own address on a Form 8821?
• Outcome: Advice given. The writer is not aware of any reason it cannot be used. The regulations under IRC section 6103(c) require the taxpayer to provide their identity as defined in IRC section 6103(b)(6), and that definition refers to a mailing address, so a box that is the taxpayer's mailing address is acceptable.
• Key authorities: IRC section 6103(b)(6) and 6103(c); regulations under section 6103(c); Form 8821.

Full text (IRS public release)

ID: CCA_2008091113252153 Number: 200851075
Office: -------------- Release Date: 12/19/2008

UILC: 6103.03-00

From: ----------------
Sent: Thursday, September 11, 2008 1:25:28 PM
To: ----------------------
Cc: -------------------
Subject: RE: Disclosure Question - Partnerships

Hi ----- --

I'm not aware of any reason that the taxpayer completing the Form 8821 cannot use a P.O. Box as his
own address. The regulations under 6103(c) require the taxpayer to provide his identity, as defined in
IRC 6103(b)(6). Identity there says "mailing address", so if the box is the taxpayer's mailing address then
it's okay.

Let me know if you have further questions.

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