Ezel / IRS Rulings / 201248019

CCA 201248019: Chief Counsel says proceeds for unwanted medical procedures qualify for exclusion

Number
201248019
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Damages
Topics
Income and deductions
Code sections
§ 104
Ruling dated
June 4, 2012
Publicly released
November 30, 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 advised that proceeds received by individuals who underwent unwanted medical procedures qualify for exclusion from gross income under section 104(a)(2). The memorandum based that conclusion on its review of the materials provided.

Ruling snapshot

  • Question: Could proceeds received for unwanted medical procedures be excluded from gross income?
  • Outcome: Advice
  • Key authorities: IRC § 104(a)(2)

Full text (IRS public release)

ID: CCA-6041153-12 Number: 201248019
Release Date: 11/30/2012
Office: ----------------
UILC: 104.03-00

From: -------------
Sent: Monday, June 4, 2012, 11:53 AM
To: ---------------------
Cc: --------------- ----------
Subject: Hello

Our review of the materials provided revealed that the recipients underwent unwanted medical
procedures. Accordingly, we conclude that the proceeds qualify for exclusion under section 104(a)(2) of
the Code.

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