Ezel / IRS Rulings / 1312037
Chief Counsel Advice 1312037 Released March 22, 2013 Advice

CCA 1312037: consents were needed for the proposed disclosure

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This page covers one taxpayer's ruling from 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 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.
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Plain-English summary

Chief Counsel advised that consents would be needed for the disclosure discussed in a request concerning testimony authorization. The short advice confirmed that the proposed disclosure required taxpayer consents under the applicable confidentiality rules.

Ruling snapshot

  • Question: Were consents required for the proposed testimony-related disclosure?
  • Outcome: Advice given, consents were required.
  • Key authorities: IRC § 6103

Full text (IRS public release)

ID: CCA_2013010409161353 Number: 201312037
Release Date: 3/22/2013
Office: --------------
UILC: 6103.03-00

From: ----------------
Sent: Friday, January 04, 2013 9:16:21 AM
To: --------------
Cc:
Subject: RE: Testimony Authorization

Hi --------

Interesting. You're right that they'll need consents for this. If you want to discuss it, let me know.

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