Ezel / IRS Rulings / 1239007
Chief Counsel Advice 1239007 Released September 28, 2012 Advice

CCA 1239007: CCA addresses notice requirements for nominee and alter-ego levies

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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 collection notices when the IRS files a notice of federal tax lien in the name of a nominee or alter ego, or plans to levy property titled in that name. It stated that the taxpayer must receive a notice under IRC § 6320 if the nominee or alter ego filing is the first notice of lien for the listed tax periods. It also stated that the taxpayer is entitled to a § 6330 notice before a levy if no § 6330 notice was previously issued for those periods.

Ruling snapshot

  • Question: What collection due process notices are required for nominee or alter-ego liens and levies?
  • Outcome: Advice
  • Key authorities: IRC §§ 6320 and 6330

Full text (IRS public release)

ID: CCA_2012080712595162 Number: 201239007
Release Date: 9/28/2012
Office: ----------------------------
UILC: 6330.00-00

From: -------------------------
Sent: Tuesday, August 07, 2012 1:00:03 PM
To: ------------------------
Cc: ---------------------------------------
Subject: RE: CDP in alter ego situations

If the filing of NFTL in the name of the nominee or alter ego is the first NFTL filed for the tax periods listed
on the NFTL, then the taxpayer must be given a section 6320 notice (Letter 3172). If the Service intends
to levy property legally titled in the name of a nominee or alter ego to collect certain tax periods, then the
taxpayer would be entitled to a section 6330 notice before the levy is made if a section 6330 has not been
previously issued for those tax periods.

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