Ezel / IRS Rulings / 201312046

CCA 201312046: only attorneys who entered an appearance could be contacted about a docketed case

Number
201312046
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Confidentiality and Disclosure of Returns and Return Information
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
February 25, 2013
Publicly released
March 22, 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 advised that, for a docketed case, the IRS was authorized to discuss the case only with individuals who had entered an appearance by signing the petition or filing separately with the court. The advice clarified that an attorney represented the taxpayer in the case, rather than the attorney's firm. The conclusion addressed confidentiality and disclosure of return information under IRC § 6103.

Ruling snapshot

  • Question: With whom could the IRS discuss a docketed case?
  • Outcome: Advice given, discussion was limited to individuals who had entered an appearance.
  • Key authorities: IRC § 6103

Full text (IRS public release)

ID: CCA_2013022517283753 Number: 201312046
Release Date: 3/22/2013
Office: --------------
UILC: 6103.00-00

From: ----------------
Sent: Monday, February 25, 2013 5:28:41 PM
To: ---------------------
Cc: ------------------
Subject: RE: 6103 Question

The only individual(s) with whom we are authorized to discuss a docketed case are those who have made
an entry of appearance (either by signing the petition or by a separate filing to the court). The individual
attorney(s) represent the TP in the case, not the firm.

Let me know if you have further questions.

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