Ezel / IRS Rulings / 201017055

CCA 201017055: IRS should verify authority for a section 6103(c) consent

Number
201017055
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Disclosure to Taxpayer’s Designee
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
March 9, 2010
Publicly released
April 30, 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 advised that the IRS should seek proof of authority when it has reason to question whether someone may execute a section 6103(c) consent for a taxpayer. The message stated that this was the recommended approach.

Ruling snapshot

  • Question: What should the IRS do when it questions a signer’s authority to execute a section 6103(c) consent?
  • Outcome: advice given
  • Key authorities: IRC § 6103(c)

Full text (IRS public release)

ID: CCA-390948-10 Number: 201017055
Release Date: 4/30/2010
Office: --------------
UILC: 6103.03-00

From: ---------------------
Sent: March 09, 2010 9:48 am
To: ------------------------------------------
Subject: [ ------- ]

This is exactly what I would recommend. If the IRS has reason to question
someone's authority to execute a 6103(c) consent on behalf of a taxpayer, the
IRS should seek proof of that authority.

Let me know if you have any more questions.

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