Ezel / IRS Rulings / 201302033

Advising a person about their own tax responsibilities may be authorized disclosure

Number
201302033
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Disclosure of Return Information
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
October 19, 2012
Publicly released
January 11, 2013
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 2013, 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 2013
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 stated that advising a person that the IRS believes the person has specified Title 26 responsibilities can constitute disclosure of that person's own return information. The advice concluded that this disclosure is authorized under sections 6103(e)(1) and 6103(e)(7).

Ruling snapshot

  • Question: Can the IRS tell a person that it believes the person has certain Title 26 responsibilities under the return-information disclosure rules?
  • Outcome: Advice given
  • Key authorities: IRC § 6103(e)(1), (7)

Full text (IRS public release)

ID: CCA_2012101913432853 Number: 201302033
Release Date: 1/11/2013
Office: -------------
UILC: 6103.05-00

From: ----------------
Sent: Friday, October 19, 2012 1:43:35 PM
To: ------------------------
Cc: ------------------------
Subject: RE: FATCA 6103 E-mail Issue

Hi ---------

I'd add one other thought to item 2 -- advising a person that we think he has certain T26 responsibilities is
disclosing his own return information to him, which is authorized under 6103(e)(1) and (7).

Otherwise - looks good.

--------

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