Ezel / IRS Rulings / 201114031

IRS explains when an invoice must be paid after a summons

Number
201114031
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Fees and Costs for Witnesses
Topics
Procedure, penalties, and administration
Code sections
§ 7610, § 6110
Ruling dated
March 7, 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 when the Service must pay an invoice related to a summons. The advice states that payment is not required until the party complies with the summons by providing the requested documents and the Service reviews the submission to determine whether it satisfies the request. The document gives a short answer on the timing issue and does not state a ruling for a particular taxpayer.

Ruling snapshot

  • Question: When must the Service pay an invoice after issuing a summons?
  • Outcome: Advice given
  • Key authorities: IRC § 7610

Full text (IRS public release)

ID: CCA_2011030710260743 Number: 201114031
Release Date: 4/8/2011
Office: --------------

UILC: 7610.00-00

From: --------------------
Sent: Monday, March 07, 2011 10:26:09 AM
To: ------------------
Cc:
Subject: RE: Section 7610 Issue

The Service is not required to pay the invoice until the party has complied with the summons, meaning
until the party has provided the documents and the Service has reviewed the submission to see whether
it is what was requested.

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