Ezel / IRS Rulings / 201050032

CCA 201050032: Disclosures may support the sale of seized assets

Number
201050032
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Disclosure for Investigative Purposes
Topics
Procedure, penalties, and administration
Code sections
§ 6103, § 6336
Ruling dated
November 15, 2010
Publicly released
December 17, 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 considered whether the IRS could disclose information needed to conduct a sale of seized assets. It concluded that IRC § 6103(k)(6) and Treas. Reg. § 301.6103(k)(6)-1(a)(1) permit disclosures necessary to carry out a sale under IRC § 6336. The advice stated that the disclosures must be limited to what is necessary and made according to IRS procedures. The conclusion applied to the sale described in the request.

Ruling snapshot

  • Question: May the Service disclose information necessary to accomplish the sale of seized assets under IRC § 6336?
  • Outcome: Advice given
  • Key authorities: IRC §§ 6103(k)(6) and 6336; Treas. Reg. § 301.6103(k)(6)-1(a)(1)

Full text (IRS public release)

ID: CCA_2010111517175047 Number: 201050032
Release Date: 12/17/2010
Office: --------------
UILC: 6103.11-06

From: ---------------------
Sent: Monday, November 15, 2010 5:17:54 PM
To: ------------------------
Cc:
Subject: RE: Disclosure Question

------------
Pursuant to IRC section 6103(k)(6) and Treas. Reg. 301.6103(k)(6)-1(a)(1), the Service may disclose the information necessary to accomplish a sale of seized assets under IRC section 6336. Disclosures must be limited to what is necessary to perform the sale, and should only be made in accordance with IRS procedures. As the RO explained that these types of disclosures are commonly made in connection with sales of seized property, it follows that the same disclosures would be allowed for the sale in question.

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