Ezel / IRS Rulings / 1218013
Chief Counsel Advice 1218013 Released May 4, 2012 Advice

Chief Counsel advice treats listed site-access items as 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 addressed whether items listed in an email about a tour and other site access would constitute return information under IRC § 6103. The response said that the items would constitute return information if collected by the Service in connection with the taxpayer’s potential liability. The advice is limited to the question and facts described in the email.

Ruling snapshot

  • Question: Would the listed tour and site-access items constitute return information?
  • Outcome: advice given
  • Key authorities: IRC § 6103

Full text (IRS public release)

ID: CCA_2012040516072032 Number: 201218013
Release Date: 5/4/2012
Office: --------------
UILC: 6103.01-00

From: ----------------------
Sent: Thursday, April 05, 2012 4:07:26 PM
To: --------------------
Cc: ---------------------
Subject: RE: Confirmation Needed for Tour and Other Site Access

-------------I see nothing objectionable with confirming for them that the
items they list would constitute return information as they would be
collected by the Service with respect to the taxpayer's potential
liability.

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