Ezel / IRS Rulings / 200934039

CCA 200934039: Audits and exams are administrative tax proceedings for disclosure purposes

Number
200934039
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Disclosure to Federal Employees for Tax Administration Purposes
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
July 23, 2009
Publicly released
August 21, 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 states the IRS position that all audits and examinations are administrative proceedings pertaining to tax within the meaning of IRC section 6103(h)(4). The statement addresses when tax information may be disclosed in connection with such a proceeding.

Ruling snapshot

  • Question: Are all audits and examinations administrative proceedings pertaining to tax under IRC section 6103(h)(4)?
  • Outcome: Advice given
  • Key authorities: IRC § 6103(h)(4)

Full text (IRS public release)

ID: CCA_2009072318034332 Number: 200934039
Release Date: 8/21/2009
Office: --------------
UILC: 6103.08-00

From: --------------------
Sent: Thursday, July 23, 2009 6:04:14 PM
To: ------------------
Cc:
Subject: RE: Transaction Relationships

It is our position that all audits/exams are administrative proceedings pertaining to tax within the meaning
of 6103(h)(4).

Please let me know if you have any more questions.

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