Ezel / IRS Rulings / 200912023

CCA 200912023: A stated value for a special estate-tax lien was a ceiling

Number
200912023
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Special Lien for Estate Tax Deferred Under Section 6166
Topics
Procedure, penalties, and administration
Code sections
§ 6324A
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 clarified an amount stated in earlier, unidentified advice concerning the special lien for estate tax deferred under IRC § 6166. The amount was a ceiling rather than a mandatory requirement. The email explained that the statute is permissive because it describes the maximum value the Secretary may require. The released text does not disclose the amount or the underlying estate's facts.

Ruling snapshot

  • Question: Was the amount stated in prior advice a required value or merely the maximum the Secretary could require?
  • Outcome: Advice given: the amount was a ceiling.
  • Key authorities: IRC § 6324A.

Full text (IRS public release)

ID: CCA_2009022314552053 Number: 200912023
Release Date: 3/20/2009
Office: ----------------------------
UILC: 6324A.00-00

From: --------------------
Sent: Monday, February 23, 2009 2:55:25 PM
To: ---------------------
Cc:
Subject: RE: did -------talk to you??

Hi ------ The amount stated in the advice is the ceiling. If you look at the statute,
it is permissive: "The maximum value the Secretary may require..." I think if you
reread the memo that comes through. Let me know if that makes sense to you.
Thanks.
ps Did not see ----- today either.

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