Ezel / IRS Rulings / 200931048

CCA 200931048: Administrative provisions, including summons procedures, apply in possessions

Number
200931048
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Administration and Collection of Taxes in Possessions
Topics
Procedure, penalties, and administration
Code sections
§ 7651
Ruling dated
November 12, 2008
Publicly released
July 31, 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 advised that under IRC § 7651, the administrative provisions of the Code, including summons procedures, apply in the possession in the same way they apply on the mainland. The advice recommends coordinating with the local IRS collection office about service if necessary.

Ruling snapshot

  • Question: Do the Code's administrative and summons provisions apply in the possession?
  • Outcome: Advice given
  • Key authorities: IRC § 7651

Full text (IRS public release)

ID: CCA-111295-08 Number: 200931048
Office: ---------------------------- Release Date: 7/31/2009

UILC: 7651.00-00

From: -----------------------
Sent: Wednesday, November 12, 2008 9:51 Am
To: -------------------------
Cc: --------------
Subject: Summons Question

-- - Under section 7651, all administrative provision
of the IRC (including summons procedures) apply as the
IRC applies on the mainland --I suggest you call IRS
collection office in -----------and coordinate service,
if necessary.

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