CCA 201104035: A summons need not include the payer's Social Security number

Plain-English summary

Chief Counsel advised that the Code does not require a summons to include a payer's Social Security number. The advice recommended using other identifying information, such as the payer's address, on the summons instead of the Social Security number. If a bank needs the number to identify the relevant account records, the information could be provided to the bank by phone or letter so it is not disclosed to everyone entitled to notice.

Ruling snapshot

• Question: Should a payer's Social Security number appear on a summons notice copy sent to the taxpayer?
• Outcome: Advice given.
• Key authorities: IRC § 7602.

Full text (IRS public release)

ID: CCA-151214-11 Number: 201104035
Release Date: 1/28/2011
Office: ----------------------------
UILC: 7602.07-02

From: ---------------------------
Sent: Friday, November 12, 2010 4:19 PM
To: ---------------------
Cc: ----------------------
Subject: Redacting SSN on Summons Question

------------

I've looked into your question of whether to redact the payer's SSN on the notice copy sent to the taxpayer. As the Code does not require the inclusion of a SSN on a summons, I would use other identifying information, such as the address of the payer, on the summons instead of the SSN. If the bank requires the payer's SSN to identify the relevant account records, you could communicate that information to the bank in a phone call or letter, in order to avoid disclosing this information to everyone entitled to notice.

Please let me know if you have any questions or concerns. I can be reached at ---------------------.

Thanks,
-----------------------------