Ezel / IRS Rulings / 201114030

IRS explains disclosure of responsible-person information for trust fund penalties

Number
201114030
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Disclosure to Persons Having Material Interest
Topics
Procedure, penalties, and administration
Code sections
§ 6103, § 6672, § 6110
Ruling dated
March 4, 2011
Publicly released
April 8, 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 addresses disclosure when more than one person may be liable for a trust fund recovery penalty. It states that if the Service determines that one person is liable under IRC section 6672(a), the Service will disclose, upon that person's written request, the name of another person determined liable, whether collection was attempted from that person, and the amount collected. The advice refers to the disclosure authority in section 6103(e)(9).

Ruling snapshot

  • Question: What information may be disclosed to a person found liable for a trust fund recovery penalty?
  • Outcome: Advice given
  • Key authorities: IRC §§ 6103(e)(9), 6672(a)

Full text (IRS public release)

ID: CCA_2011030408264524 Number: 201114030
Release Date: 4/8/2011
Office: --------------

UILC: 6103.05-00, 6672.00-00

From: ---------------
Sent: Friday, March 04, 2011 8:26:47 AM
To: --------------------------
Cc:
Subject: RE: TFRP and disclosure

--------------the person is entitled to the information found in section 6103(e)(9). If we determine that one person is liable for the penalty under 6672(a), upon request in writing, we will disclose to that person the name of any other person whom the Secretary has determined to be liable for the penalty and whether we have attempted to collect from that person and the amount collected.

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