Ezel / IRS Rulings / 1044009
Chief Counsel Advice 1044009 Released November 5, 2010 Advice

CCA 1044009: A case-law summary in the CDP handbook presents no problem

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This page covers one taxpayer's ruling from 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 resolved one taxpayer's situation on its specific facts, 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 states that a Collection Due Process handbook summary should not present a problem if it only summarizes case law, statutes, and regulations. The advice also notes that a recently enacted small-business law amended IRC § 6330 to exclude federal contractors from the requirement that the IRS provide Collection Due Process rights before a levy. It explains that the change would permit pre-CDP levies on federal contractors through the Federal Payment Levy Program.

Ruling snapshot

  • Question: What materials may be summarized in the CDP handbook, and what change affected levy procedures for federal contractors?
  • Outcome: Advice given
  • Key authorities: IRC § 6330

Full text (IRS public release)

ID: CCA_2010101507234855 Number: 201044009
Release Date: 11/5/2010
Office: ----------------------------
UILC: 6330.00-00

From: ---------------------
Sent: Friday, October 15, 2010 7:23:52 AM
To: -----------------------
Cc:
Subject: RE: CDP handbook

So long as it is just summary of case law, statutes and regulations there should not be any problem. Note
that there is a new development: in the Small Business legislation that Congress passed a few weeks
ago, they amended 6330 to exclude federal contractors from the requirement that the IRS give CDP
rights before levy. This will enable the IRS to do pre-CDP levies on federal contractors through the
Federal Payment Levy Program.

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