Ezel / IRS Rulings / 201025071

IRS advised on disclosure of tax information to local law enforcement

Number
201025071
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Disclosure for use in Criminal Investigations
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
September 21, 2009
Publicly released
June 25, 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

The IRS advised that IRC § 6103(i) does not provide a mechanism for disclosing tax information to local law-enforcement officials. It noted that those officials might instead obtain some or all of the information from a state motor-vehicle office.

Ruling snapshot

  • Question: Does IRC § 6103(i) authorize disclosure of tax information to local law-enforcement officials?
  • Outcome: Advice given
  • Key authorities: IRC § 6103(i).

Full text (IRS public release)

ID: CCA-921850-09 Number: 201025071
Release Date: 6/25/2010
Office: ----------
UILC: 6103.09-01

From: ------------------
Sent: Monday, September 21, 2009 8:50 AM
To: ------------------------
Cc:
Subject: pmta01571_7396[1].pdf

-------you are correct that IRC 6103(i) does not provide a mechanism for disclosure of tax information to local law enforcement officials. But note the advice I’ve copied above; it suggests that the local law enforcement officials may be able to obtain some or all of the information from the state motor vehicle office.

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