Ezel / IRS Rulings / 200947060

CCA 200947060: Email as a potentially disclosable Jenks Act document

Number
200947060
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Criminal Tax Multifunctional Coordination
Topics
Other topics
Code sections
§ 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 concerns documents related to the Jenks Act. The writer reports that the IRS has not produced documents regarding the Act and states that an email could be considered a “document” for disclosure purposes. The short email does not provide further analysis or identify the records at issue.

Ruling snapshot

  • Question: Could an email be considered a document for disclosure purposes under the Jenks Act?
  • Outcome: Advice given
  • Key authorities: No specific Code section stated in the release

Full text (IRS public release)

ID: CCA-325163-09 Number: 200947060
Release Date: 11/20/2009
Office: ---------
UILC: 9999.50-00

From: ---------------------
Sent: Wednesday, March 25, 2009 4:34 PM
To: ----------------------------
Cc:
Subject: Jenks Act

----------I spoke with -------- who confirmed that we have not produced any documents regarding the Jenks
Act and she believes that email could be considered a "document" for purposes of disclosure. That is
about all I have, but feel free to contact me if you need any more information. Thanks.

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace