Ezel / IRS Rulings / 200933028

CCA 200933028: Summons authority for credit reports after assessment

Number
200933028
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Use of Summons
Topics
Procedure, penalties, and administration
Code sections
§ 7602, § 6110
Ruling dated
August 18, 2008
Publicly released
August 14, 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 Advice addressed whether a revenue officer could summon a credit report. The advice stated that current practice allowed a revenue officer to summon a credit report when an assessment existed, but Exam could not do so before an assessment had been made.

Ruling snapshot

  • Question: Could Exam summon a credit report before an assessment existed?
  • Outcome: Advice given
  • Key authorities: IRC § 7602

Full text (IRS public release)

ID: CCA-818228-08 Number: 200933028
Release Date: 8/14/2009
Office: ----------
UILC: 7602.08-00

From: --------------------
Sent: August 18, 2008 2:28pm
To: ---------------
Cc:
Subject: Question

I believe the current practice is if there is an assessment the RO can summons a
credit report. So I don't think Exam can do it because no assessment yet.

-----------------------------------
-------------------

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace