Ezel / IRS Rulings / 1214029
Chief Counsel Advice 1214029 Released April 6, 2012 Advice

CCA 1214029: Chief Counsel advice explains what qualifies as Chief Counsel advice

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This page covers one taxpayer's ruling from 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 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 advice stated that IRC § 6110(i) defines Chief Counsel advice. The provision requires that this advice be prepared by a national office component of the Office of Chief Counsel. The short IRS response addressed the statutory definition rather than deciding a taxpayer's substantive tax liability.

Ruling snapshot

  • Question: What does IRC § 6110(i) require for Chief Counsel advice?
  • Outcome: Advice given
  • Key authorities: IRC § 6110(i)

Full text (IRS public release)

ID: CCA_2012031316524326 Number: 201214029
Release Date: 4/6/2012
Office: ----------
UILC: 6110.04-04

From: -------------------
Sent: Tuesday, March 13, 2012 4:52:45 PM
To: ---------------
Cc:
Subject: A statute

The definition of chief counsel advice is in section 6110(i)--who knew? I guess I should have. Anyway it
must be prepared by a national office component of the Office of Chief Counsel. Good luck with your
case.

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