Ezel / IRS Rulings / 200946046

CCA 200946046: Taxpayer copy of a technical advice memorandum

Number
200946046
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Disclosure of Technical Advice Memorandum
Topics
Estate tax
Code sections
§ 2055, § 6110
Ruling dated
October 1, 2009
Publicly released
November 13, 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 states that the requesting office should send the taxpayer a copy of a technical advice memorandum, but not the transmittal memorandum. The writer recommends submitting the technical advice memorandum to the taxpayer. The short email does not address the substantive tax issue behind the inquiry.

Ruling snapshot

  • Question: Which documents should a requesting office send to a taxpayer after technical advice?
  • Outcome: Advice given
  • Key authorities: IRC § 2055

Full text (IRS public release)

ID: CCA_2009100111365665 Number: 200946046
Release Date: 11/13/2009
Office: ----------------
UILC: 2055.00-00

From: ---------------------
Sent: Thursday, October 01, 2009 11:36:58 AM
To: -----------------------
Cc:
Subject: RE: Query

I believe that the requesting office of a TAM is supposed to send a copy of the TAM, but not the
transmittal memo, to the taxpayer. I believe that you should submit a copy to them.

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