Ezel / IRS Rulings / 200912022

CCA 200912022: Collection issues could be handled through several agreement procedures

Number
200912022
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Policy
Topics
Procedure, penalties, and administration
Code sections
§ 7122
Ruling dated
February 23, 2009
Publicly released
March 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 identified several procedures through which collection issues could be addressed. The options included collateral agreements, offers in compromise, installment agreements, and Appeals settlements. The email pointed to the relevant Internal Revenue Manual provisions for each option. The released text does not describe the taxpayer, the collection issue, or the surrounding discussion about closing agreements.

Ruling snapshot

  • Question: What procedures could be used to address collection issues?
  • Outcome: Advice given: collateral agreements, offers in compromise, installment agreements, and Appeals settlements were available examples.
  • Key authorities: IRC § 7122; IRM 5.6, 5.8, 5.14, 8.6, and 8.23.

Full text (IRS public release)

ID: CCA_2009022307455052 Number: 200912022
Release Date: 3/20/2009
Office: -----
UILC: 7122.13-00

From: --------------------
Sent: Monday, February 23, 2009 7:45:58 AM
To: --------------------
Cc: -------------------------------------
Subject: RE: closing agreements

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

Examples of where collection issues can be addressed include Collateral Agreements (see IRM 5.6),
Offers-in-Compromise (see IRM 5.8), Installment Agreements (see IRM 5.14), and Appeals settlements
(see IRM 8, particularly 8.6 and 8.23).

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