CCA 1125029: IRS practice was to omit TINs from summonses and other mailed documents

Plain-English summary

Chief Counsel Advice addressed whether employer or taxpayer identification numbers should be listed on summonses. The advice stated that there was no formal policy on the issue, but that IRS practice was not to include TINs on mailed documents, filed Notices of Federal Tax Lien, or summonses. It explained that this practice reflected the general trend among courts to guard against identity theft, rather than concerns about disclosures under IRC § 6103(k)(6). The advice recommended using other identifying information, such as a payer's address, on a summons.

Ruling snapshot

• Question: Should a taxpayer identification number be included on a summons?
• Outcome: Advice given.
• Key authorities: IRC § 6103(k)(6).

Full text (IRS public release)

ID: CCA_2011052410181560 Number: 201125029
Release Date: 6/24/2011
Office: ----------------------------
UILC: 6103.00-00

From: ---------------------------
Sent: Tuesday, May 24, 2011 10:18:16 AM
To: -----------------------------------
Cc:
Subject: TIN Question

There is not a formal policy on listing EINs or TINs on summonses, but it is our practice to not include
TINs on mailed documents, on filed Notices of Federal Tax Lien, or on a summons. Our concern is based
on the general trend with the court systems to take steps to guard against identity theft, rather than on the
section 6103(k)(6) disclosure concerns. I would use other identifying information, such as the address of
the payer, on a summons instead of the TIN. --------------------------------------------------------------------------------

--------------------------------------------------------------------------------------------------------------------------------------------

Please let me know if you have any additional questions. I can be reached at ---------------------.
Thanks,