Ezel / IRS Rulings / 200953027

CCA 200953027: Advice on disclosing return information to the Justice Department

Number
200953027
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Disclosure
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
December 4, 2009
Publicly released
January 1, 2010
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 2010, 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 2010
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

Chief Counsel advice addressed whether return information could be disclosed to the Department of Justice and to Service personnel. It concluded that IRC § 6103(h)(1) permits disclosure to Service personnel whose official duties require inspection of return information. It stated that § 6103(h)(2) might also permit disclosure to the Justice Department, but that more information was needed for a definitive answer.

Ruling snapshot

  • Question: Could return information be disclosed to Service personnel and the Department of Justice?
  • Outcome: Advice given
  • Key authorities: IRC § 6103(h)(1) and (2)

Full text (IRS public release)

ID: CCA_2009120417315449 Number: 200953027
Release Date: 12/31/2009
Office: ----------------------------
UILC: 6103.02-08

From: ---------------------------
Sent: Friday, December 04, 2009 5:31:56 PM
To: ---------------
Cc:
Subject: Question regarding 6103

You asked our assistance regarding disclosure of return information to the Department of Justice and various Service personnel. You are correct that section 6103(h)(1) permits disclosure to Service personnel whose official duties require inspection of return information. Section 6103(h)(2) may also permit disclosure to Justice here, but without further information we are unable to provide a definitive answer at this time. Please contact me at the number below and we can discuss this matter further.

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