Ezel / IRS Rulings / 200947061

CCA 200947061: National Office review of Internet-provider search warrants

Number
200947061
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Felony
Topics
Procedure, penalties, and administration
Code sections
§ 7201, § 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 one-page Chief Counsel advice concerns search warrants directed to Internet providers. In response to a forwarded question, the writer states that the National Office does not need to see “these.” The document does not identify what “these” refers to or provide further legal analysis.

Ruling snapshot

  • Question: Does the National Office need to review the referenced search warrants of Internet providers?
  • Outcome: Advice given
  • Key authorities: IRC § 7201

Full text (IRS public release)

ID: CCA-431338-09 Number: 200947061
Release Date: 11/20/2009
Office: ----------------------------
UILC: 7201.70-05

From: ----------------------------------
Sent: Friday, April 03, 2009 1:38 PM
To: --------------------------
Cc:
Subject: FW: Search warrants of Internet Providers

As I suspected, the NO does not need to see these...

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