Ezel / IRS Rulings / 201216036

CCA 201216036: Advice addresses Treasury access to tax return information

Number
201216036
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Disclosure to Federal Employees for Tax Administration Purposes
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
March 27, 2012
Publicly released
April 20, 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 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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