Ezel / IRS Rulings / 200947051

CCA 200947051: Limits on disclosure in a spouse's tax case

Number
200947051
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Disclosure in Judicial or Administrative Tax Administration Proceedings
Topics
Procedure, penalties, and administration
Code sections
§ 6103, § 6110
Publicly released
November 20, 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 answers two proposed questions about disclosures in a spouse's tax case. It answers both questions affirmatively and states that disclosures should be limited to information directly related to an issue in the spouse's case. The release does not include the underlying questions.

Ruling snapshot

  • Question: What limit applies to disclosures related to an issue in a spouse's tax case?
  • Outcome: Advice given
  • Key authorities: IRC § 6103

Full text (IRS public release)

ID: CCA_2009100713225532 Number: 200947051
Release Date: 11/20/2009
Office: ----------
UILC: 6103.08-04

From: ----------------------
Sent: Wednesday, October 07, 2009 1:22:57 PM
To: -------------------
Cc:
Subject: Question

Yes to both of your proposed answers. Disclosures should be limited to that which is
directly related to an issue in the spouse's case.

What does the Code say today, for your facts?

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