Ezel / IRS Rulings / 201139007

CCA 201139007: IRS advised against using IDRS for a non-tax-administration purpose

Number
201139007
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Disclosure within the Department of Treasury
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
September 15, 2011
Publicly released
September 30, 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 stated that the Integrated Data Retrieval System should not be used for a purpose that is not tax administration. It directed the recipient to IRC § 6103(h)(1) and invited further questions.

Ruling snapshot

  • Question: Could IDRS be used for the stated disclosure purpose?
  • Outcome: advice given
  • Key authorities: IRC § 6103(h)(1)

Full text (IRS public release)

ID: CCA_2011091517213653 Number: 201139007
Release Date: 9/30/2011
Office: --------------
UILC: 6103.08-01

From: ----------------
Sent: Thursday, September 15, 2011 5:21:39 PM
To: -----------------------
Cc:
Subject: FW: Disclosure question

Hi ------------

Great to talk with you today!

Since this isn't tax administration, IDRS should not be used for this purpose - see
6103(h)(1). -------------------------------------------------------------------------------------------------------------------------
------------------------------------------------------------------

Let me know if you have other questions.

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