Ezel / IRS Rulings / 200908028

CCA 200908028: Taxpayer could agree to a courthouse examination

Number
200908028
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Time and Place of Examination
Topics
Procedure, penalties, and administration
Code sections
§ 7605
Ruling dated
November 4, 2008
Publicly released
February 20, 2009
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 2009, 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 2009
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 answered a question about the permissible place for an examination associated with a summons. The email said a courthouse was an acceptable location if the taxpayer agreed. It did not describe the examination, the summons, or any alternative location. The taxpayer's consent was the only condition stated in the released advice.

Ruling snapshot

  • Question: Could the examination take place at a courthouse?
  • Outcome: Advice given: yes, as long as the taxpayer agreed.
  • Key authorities: IRC § 7605.

Full text (IRS public release)

ID: CCA_2008110408573351 Number: 200908028
Release Date: 2/20/2009
Office: -----------
UILC: 7605.00-00

From: --------------------
Sent: Tuesday, November 04, 2008 8:57:36 AM
To: ---------------------
Cc:
Subject: RE: Summons & Section 7605 Question

Hi ----------

Yes, the courthouse is acceptable as long as the taxpayer agrees.

Please let me know if you need anything else.

Thanks,
---------

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