Ezel / IRS Rulings / 1216036
Chief Counsel Advice 1216036 Released April 20, 2012 Advice

CCA 1216036: Advice addresses Treasury access to tax return information

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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 confirms that the Treasury Department's Alcohol and Tobacco Tax and Trade Bureau is part of Treasury and may access returns and return information for official tax administration purposes under IRC § 6103(h)(1). The message states that the statute does not require a written request for those disclosures. The remainder of the communication is redacted.

Ruling snapshot

  • Question: May the Treasury Department's Alcohol and Tobacco Tax and Trade Bureau access returns and return information for official tax administration without a written request?
  • Outcome: Advice
  • Key authorities: IRC § 6103(h)(1).

Full text (IRS public release)

ID: CCA_2012032717502053 Number: 201216036
Release Date: 4/20/2012
Office: --------------
UILC: 6103.08-00

From: ----------------
Sent: Tuesday, March 27, 2012 5:50:22 PM
To: ------------------
Cc:
Subject: TTB and 6103(h)(1)

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

Just to confirm our conversation - Treasury's Alcohol and Tobacco Tax and Trade Bureau (TTB) is part
of Treasury and has access to returns and return information for official tax administration purposes under
IRC 6103(h)(1). The statute does not require a written request for such disclosures, ----------------------------
-----------------------------------------------------------------------------------.

Hope that's clear.

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