Ezel / IRS Rulings / 201202022

CCA 201202022: CCA addresses disclosure of taxpayer return information

Number
201202022
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Disclosure in Judicial or Administrative Tax Administration Proceedings
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
December 14, 2011
Publicly released
January 13, 2012
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 2012, 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 2012
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 information about a taxpayer's position in two audits could be disclosed. Because the same taxpayer was involved in both audits, the advice concluded that the information was the taxpayer's return information. It stated that the information could be disclosed to the taxpayer under IRC section 6103(h)(4)(A).

Ruling snapshot

  • Question: Could the taxpayer receive information about its position in two audits under IRC section 6103?
  • Outcome: Advice given
  • Key authorities: IRC § 6103(h)(4)(A)

Full text (IRS public release)

ID: CCA_2011121411061953 Number: 201202022
Release Date: 1/13/2012
Office: --------------
UILC: 6103.08-04

From: ----------------
Sent: Wednesday, December 14, 2011 11:06:27 AM
To: ------------------------
Cc: ----------------
Subject: RE: 6103 question

Since the same taxpayer is the taxpayer in both audits, the information about the taxpayer's position as to
the proper definition of units of property in the two audits is the return information of the taxpayer. This
information can be disclosed to the taxpayer under 6103(h)(4)(A).
--------------------------------------------------------------------------------------------------------------------------------------------
--------------------------------------------------------------------------------------------------------------------------------------------
----------------

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace