Ezel / IRS Rulings / 1145022
Chief Counsel Advice 1145022 Released November 10, 2011 Advice

IRS cannot redesignate a payment made under taxpayer instructions

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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's Office advice addressed whether the IRS could transfer or redesignate a payment. The advice concluded that the Service could not do so when it applied the payment in accordance with the taxpayer's instructions. On the stated facts, the Service had acted consistently with those instructions.

Ruling snapshot

  • Question: Could the IRS transfer or redesignate a payment that it applied according to the taxpayer's instructions?
  • Outcome: Advice given.
  • Key authorities: IRC § 6302; 26 U.S.C. § 6110(k)(3)

Full text (IRS public release)

ID: CCA_2011110110054022 Number: 201145022
Release Date: 11/10/2011
Office: --------------
UILC: 6302.00-00

From: -----------------------------
Sent: Tuesday, November 01, 2011 10:05:41 AM
To: --------------------------
Cc:
Subject: RE: Designated Payments

The Service is not permitted to transfer or redesignate a payment when the Service has applied the payment in accordance with the taxpayer’s instructions. According to your facts, the Service merely acted in accordance with the taxpayer’s instructions.

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