Ezel / IRS Rulings / 200910043

CCA 200910043: The section 6015(f) litigating position remained unchanged

Number
200910043
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Innocent spouse (including Sections 66, 6013)
Topics
Procedure, penalties, and administration
Code sections
§ 6015
Ruling dated
January 14, 2009
Publicly released
March 6, 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 responded to an inquiry about section 6015(f) innocent-spouse cases. The email states only that the IRS's litigating position remained unchanged. The public release provides no facts, description of that position, or further analysis.

Ruling snapshot

  • Question: Had the IRS changed its litigating position in section 6015(f) cases?
  • Outcome: Advice given: no, the position remained unchanged.
  • Key authorities: IRC § 6015(f).

Full text (IRS public release)

ID: CCA_2009011414384152 Number: 200910043
Release Date: 3/6/2009
Office: -------------
UILC: 6015.00-00

From: ------------------------
Sent: Wednesday, January 14, 2009 2:38:44 PM
To: -------------
Cc:
Subject: 6015(f) Cases

Our litigating position remains unchanged.

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