Ezel / IRS Rulings / 201117033

CCA 201117033: Mailing to a recipient's current residence was not a disclosure violation

Number
201117033
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Confidentiality and Disclosure of Returns and Return Information
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
March 31, 2011
Publicly released
April 29, 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 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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