Ezel / IRS Rulings / 200913026

CCA 200913026: Two matters with the same subject line could be netted

Number
200913026
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Reports of Refunds and Credits
Topics
Procedure, penalties, and administration
Code sections
§ none cited
Ruling dated
July 14, 2008
Publicly released
March 27, 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 addressed an apparent mix-up caused by two inquiries arriving with the same subject line. The writer believed the two matters could be netted and offered to discuss the conclusion further. The brief, redacted release provides no facts about the taxpayers, amounts, or mechanics of the proposed netting.

Ruling snapshot

  • Question: Could two inquiries that had been confused because they shared a subject line be netted?
  • Outcome: Advice given: the writer believed they could be netted.
  • Key authorities: No authority cited in the released message.

Full text (IRS public release)

ID: CCA-714101-08 Number: 200913026
Release Date: 3/27/2009
Office: --------------
UILC: 6405.00-00

From: --------------------------
Sent: 7/14/2008
To: ------------------------------------------------------------------------------
Cc: ----------------------------
Subject: Definition of a Taxpayer

Looks like two inquiroies came in with the same subject line, hence the mix up. I think this can be netted,
but am happy to discuss further if you don't agree.

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