Ezel / IRS Rulings / 200911013

CCA 200911013: Chief Counsel forwarded an earlier determination for a gaming case

Number
200911013
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Deductions
Topics
Tax-exempt organizations
Code sections
§ 512
Ruling dated
January 13, 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 sent a link to written determination 9941043 for use in a gaming case. The writer thought the linked document would clarify the issue. The released email contains no substantive analysis or conclusion and says that further discussion would follow.

Ruling snapshot

  • Question: What guidance might help address the unidentified issue in a gaming case?
  • Outcome: Advice given: consult written determination 9941043, with further discussion to follow.
  • Key authorities: IRC § 512; written determination 9941043.

Full text (IRS public release)

ID: CCA-113103-09 Number: 200911013
Release Date: 3/13/2009
Office: --------------------
UILC: 512.08-00

From: ----------------
Sent: Tuesday, January 13, 2009 10:37:27 AM
To: ----------------------
Cc: ----------------------------------------------
Subject: Emailing: 9941043

--------------- - This link should help with your gaming case. ------ and I will discuss it
tomorrow and get back to you, but I think the document attached will clarify the issue. I'll
try giving you a call this afternoon.
Thanks, ------

The message is ready to be sent with the following file or link attachments:

Shortcut to: http://www.irs.treas.gov/pub/irs-wd/9941043.pdf

------------------------------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------------------------------
--------------------------------------------------------

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace