Ezel / IRS Rulings / 200935031

CCA 200935031: Summons to a record keeper for another taxpayer is third-party summons

Number
200935031
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Special Procedures for Third-Party Summonses
Topics
Procedure, penalties, and administration
Code sections
§ 7609, § 6110
Ruling dated
July 7, 2009
Publicly released
August 28, 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

This Chief Counsel Advice addresses a summons issued to a record keeper concerning another taxpayer. It concludes that, on the stated facts, the summons is a third-party summons. The Advice asks for additional facts if there are other factors to consider.

Ruling snapshot

  • Question: Is a summons directed to a record keeper concerning another taxpayer a third-party summons?
  • Outcome: Advice given
  • Key authorities: IRC § 7609.

Full text (IRS public release)

ID: CCA_2009070711034859 Number: 200935031
Release Date: 8/28/2009
Office: -------------
UILC: 7609.00-00

From: ------------------
Sent: Tuesday, July 07, 2009 11:03:49 AM
To: ------------------------
Cc:
Subject: Question re: Third Party Record Keeper Summons ---------

If the summons is to --------------------, in the matter of X taxpayer, the summons is a third party summons.

If there are other factors to consider, please let me know.

Thanks,
-------

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