Ezel / IRS Rulings / 200923047

CCA 200923047: Explanation of items need not mention self-dealing

Number
200923047
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Excise Taxes on Taxable Expenditures
Topics
Private foundations
Code sections
§ 4945
Ruling dated
May 7, 2009
Publicly released
June 5, 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 gave brief advice about the explanation of items for a statutory notice. The advice says there was no reason for that explanation to mention self-dealing. The released email does not provide the underlying facts or further analysis.

Ruling snapshot

  • Question: Should the explanation of items mention self-dealing?
  • Outcome: Advice given
  • Key authorities: IRC § 4945

Full text (IRS public release)

ID: CCA_2009050708053853 Number: 200923047
Release Date: 6/5/2009
Office: -----------------------------
UILC: 4945.00-00

From: -------------------------
Sent: Thursday, May 07, 2009 8:05:41 AM
To: ------------------------------------------------
Cc: -------------------
Subject: RE: L case Stat notice

For the explanation of items, there is no reason to mention self-dealing. ---------------------------------------------
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