Ezel / IRS Rulings / 201223017

CCA 201223017: IRS explains review of a supplemental CDP determination

Number
201223017
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Collection Due Process - Levy
Topics
Procedure, penalties, and administration
Code sections
§ 6330, § 6110
Ruling dated
May 15, 2012
Publicly released
June 8, 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 states that the attorney handling a remanded Collection Due Process case should review the supplemental notice of determination before it is issued to the taxpayer. The review is limited to ensuring compliance with the remand order. The advice cites Rev. Proc. 2012-18 and the CDP Handbook.

Ruling snapshot

  • Question: Who should review a supplemental notice of determination in a remanded CDP case?
  • Outcome: Advice given, identifying a limited attorney review before issuance.
  • Key authorities: IRC § 6330; Rev. Proc. 2012-18, § 2.03(10)(c)(iii)

Full text (IRS public release)

ID: CCA_2012051514060450 Number: 201223017
Release Date: 6/8/2012
Office: ----------
UILC: 6330.00-00

From: -----------------------
Sent: Tuesday, May 15, 2012 2:08:24 PM
To: -----------------
Cc: ------------------
Subject: RE: CDP Remanded Case

Take a look at Rev. Proc. 2012-18. It says the attorney handling the CDP case should
review the supplemental notice of determination before it is issued to the taxpayer, for
the limited purpose of ensuring compliance with the remand order. Rev. Proc. 2012-18,
Sec. 2.03(10)(c)(iii). The CDP Handbook says the same thing.

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