Ezel / IRS Rulings / 200914059

CCA 200914059: Appeals guidance addressed the Hoyle collection decision

Number
200914059
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Collection Due Process - Levy
Topics
Procedure, penalties, and administration
Code sections
§ 6330
Ruling dated
March 12, 2009
Publicly released
April 3, 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 voicemail concerning collection due process for a levy. The email directed the recipient to internal Appeals guidance issued in response to Hoyle v. Commissioner. It also noted that the guidance had been coordinated with several people whose identities were redacted. The released email does not state the underlying question or summarize the guidance's conclusions.

Ruling snapshot

  • Question: What guidance addressed the collection due process issue raised by Hoyle v. Commissioner?
  • Outcome: Advice given: consult the linked Appeals guidance and call back if it does not answer the question.
  • Key authorities: IRC § 6330; Hoyle v. Commissioner.

Full text (IRS public release)

ID: CCA_2009031210011350 Number: 200914059
Release Date: 4/3/2009
Office: ----------------------------
UILC: 6330.00-00

From: -----------------------
Sent: Thursday, March 12, 2009 10:01:22 AM
To: --------------------
Cc:
Subject: Your vm

Here is a link to the guidance that Appeals issued in response to Hoyle. This was coordinated with --------
--------------- and ------. If it doesn't answer your question please give me a call.
http://appeals.web.irs.gov/tech_services/collection/documents/HoyleVCommish.pdf

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