Ezel / IRS Rulings / 201107022

CCA 201107022: IRS declines to accept real property in an unspecified collection matter

Number
201107022
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Administration of Real Estate Acquired by U.S.
Topics
Procedure, penalties, and administration
Code sections
§ 7506
Ruling dated
September 22, 2010
Publicly released
February 18, 2011
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 2011, 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 2011
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 gives a negative answer to a redacted collection question involving the acceptance of real property. The response identifies issues that would arise if the IRS accepted the property, including the amount credited against the tax liability and whether and how the property would have to be sold. The underlying facts and the precise question are redacted in the public release.

Ruling snapshot

  • Question: Should the IRS accept real property in the redacted collection matter?
  • Outcome: Advice given, answer no.
  • Key authorities: IRC § 7506.

Full text (IRS public release)

ID: CCA-922145-10 Number: 201107022
Release Date: 2/18/2011
Office: ----------
UILC: 7506.00-00

From: -----------------
Sent: Wednesday, September 22, 2010 1:24 PM
To: -------------------
Cc: -------------------------------------------------------------- Subject: Collection Question ---------

----------- I'm sorry no one got back to you. A member of our staff was to call you and advise that the answer is no. Accepting real property presents all sorts of issues paramount of which is the sum we credit the tax liability, do we have to sell, how do we sell (private sale v. auction) etc. -------------------------------------------------------------------------
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