Ezel / IRS Rulings / 200911012

CCA 200911012: The casino's tournament-based approach was correct

Number
200911012
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Extension of Withholding to Certain Gambling Winnings
Topics
Employment taxes
Code sections
§ 3402
Ruling dated
January 5, 2009
Publicly released
March 13, 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 a question involving Revenue Procedure 2007-57 and a casino. The writer thought the casino's position was correct. The email added that the matter was usually handled on a tournament basis but provided no facts or further analysis.

Ruling snapshot

  • Question: Was the casino's approach under Revenue Procedure 2007-57 correct?
  • Outcome: Advice given: yes, and the approach was usually applied on a tournament basis.
  • Key authorities: IRC § 3402; Rev. Proc. 2007-57.

Full text (IRS public release)

ID: CCA_2009010515401442 Number: 200911012
Release Date: 3/13/2009
Office: --------------
UILC: 3402.13-00

From: -------------------------
Sent: Monday, January 05, 2009 3:40:15 PM
To: ---------------------
Cc:
Subject: RE: Rev. Proc. 2007-57

I think the casino is correct. It's usually done on a tournament basis.

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