Ezel / IRS Rulings / 1117033
Chief Counsel Advice 1117033 Released April 29, 2011 Advice

CCA 1117033: Mailing to a recipient's current residence was not a disclosure violation

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This page covers one taxpayer's ruling from 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 resolved one taxpayer's situation on its specific facts, 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 addressed whether mail could continue to be sent to a person's home address when the mail was apparently forwarded to the person's current residence. The advice stated that using the address the person requested would not violate the disclosure rules. It also suggested asking the person where they preferred to receive mail and using the current residence if that was the address provided.

Ruling snapshot

  • Question: Could mail continue to be sent to a home address that appeared to forward mail to the recipient's current residence?
  • Outcome: Advice given.
  • Key authorities: IRC § 6103.

Full text (IRS public release)

ID: CCA_2011033115205432 Number: 201117033
Release Date: 4/29/2011
Office: --------------
UILC: 6103.00-00

From: ----------------------
Sent: Thursday, March 31, 2011 3:20:55 PM
To: ----------------------
Cc:
Subject: RE:

You could continue to send mail to his home address, since it obviously is forwarded to
his current "residence." You could also ask him, in a letter, where he would prefer that
you send mail to him. If he lists his current abode, then send it there. We can assume
that he knows that some, if not all, of his mail is opened by the authorities. There
would be no disclosure violation for using the address that he requests.

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