Ezel / IRS Rulings / 200945065

The IRM may be cited, but CCAs and NSARs should not be cited

Number
200945065
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Limitations on assessment and collection
Topics
Procedure, penalties, and administration
Code sections
§ 6501
Ruling dated
September 23, 2009
Publicly released
November 6, 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

Counsel advised that the Internal Revenue Manual may be cited, but Chief Counsel Advice and NSARs should not be cited. The message offered no further substantive analysis and invited the recipient to call if additional discussion was needed.

Ruling snapshot

  • Question: Which IRS materials may be cited?
  • Outcome: Advice given
  • Key authorities: Internal Revenue Manual; CCAs; NSARs

Full text (IRS public release)

ID: CCA_2009092313574436 Number: 200945065
Release Date: 11/6/2009
Office: ----------------------------
UILC: 6501.00-00

From: --------------------
Sent: Wednesday, September 23, 2009 1:57:47 PM
To: ------------------
Cc:
Subject: ---------------------------------------

Go ahead and cite to the IRM if you want but not to the CCAs or the NSAR. If you want
to speak with me, feel free to give me a call.

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

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