Ezel / IRS Rulings / 200939029

CCA 200939029: Filed petition and attached SNOD could be sent as public records

Number
200939029
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Confidentiality and Disclosure of Returns and Return Information; Definitions
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
August 3, 2009
Publicly released
September 25, 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

An IRS attorney was asked whether a filed petition and its attached statutory notice of deficiency could be sent to another party. The attorney advised that the petition, as filed, and the attached SNOD were public records, so there was no problem sending them.

Ruling snapshot

  • Question: Could the IRS send a filed petition and attached SNOD because they were public records?
  • Outcome: Advice given.
  • Key authorities: IRC § 6103.

Full text (IRS public release)

ID: CCA_2009080310173253 Number: 200939029
Release Date: 9/25/2009
Office: --------------
UILC: 6103.00-00, 6103.02-00

From: ----------------
Sent: Monday, August 03, 2009 10:17:43 AM
To: ------------------------
Cc:
Subject: RE: question

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

The petition as filed, including attached SNOD, is public record; no problem sending it.

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