Ezel / IRS Rulings / 200946049

CCA 200946049: Revocable-trust tax lien issue may depend on state law

Number
200946049
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Federal Tax Liens and Revocable Trusts
Topics
Procedure, penalties, and administration
Code sections
§ 6321, § 6110
Ruling dated
November 17, 2008
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 comments on a federal tax lien issue involving a revocable trust. The writer states that a cited case may be helpful but that the question appears to depend on the law of each state. The underlying attachment referenced in the email is redacted and is not included in the one-page release text. The advice does not reach a definitive taxpayer-specific conclusion.

Ruling snapshot

  • Question: How should a federal tax lien issue involving a revocable trust be analyzed?
  • Outcome: Advice given
  • Key authorities: IRC § 6321

Full text (IRS public release)

ID: CCA-111774-08 Number: 200946049
Release Date: 11/13/2009
Office: ----------
UILC: 6321.01-00

From: --------------------
Sent: Monday, November 17, 2008 7:48 AM
To: --------------------
Cc: ----------------------------
Subject: TbyE and Revocable trust

I checked with the ---- folks. Take a look at the CJS footnote 3 case below. It may
help you, but it looks like it's a state by state matter. Good luck.

-----------------------------------
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Attachment: CJS_Husband_s_47_11-13-08_2004.doc

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