Ezel / IRS Rulings / 201313026

CCA 201313026: IRS identifies obsolete jeopardy-levy guidance

Number
201313026
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Collection Due Process - Levy
Topics
Procedure, penalties, and administration
Code sections
§ 6330, § 6110
Ruling dated
March 4, 2013
Publicly released
March 29, 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

An IRS attorney advised that a note in Internal Revenue Manual section 5.11.3.3(3) appeared to be obsolete. The memo states that the delegation of authority to approve jeopardy levies is instead found in Chief Counsel Directives Manual section 30.3.2.4.3.1(3)j and Division Order 2009-03. The document is a short internal guidance note and does not decide a taxpayer-specific levy dispute.

Ruling snapshot

  • Question: Which internal guidance governs the delegation of authority to approve jeopardy levies?
  • Outcome: Advice given that the referenced IRM note was obsolete and other delegation authorities applied.
  • Key authorities: IRC § 6330; IRM § 5.11.3.3(3); CCDM § 30.3.2.4.3.1(3)j; Division Order 2009-03

Full text (IRS public release)

-

ID: CCA_2013030409092250 Number: 201313026
Release Date: 3/29/2013
Office: ----------
UILC: 6330.00-00

From: -----------------------
Sent: Monday, March 04, 2013 9:09:23 AM
To: --------------------------------------
Cc:
Subject: FW: International Jeopardy Levy

I think the note in 5.11.3.3(3) is obsolete. The delegation of authority to approve
jeopardy levies is in CCDM 30.3.2.4.3.1(3)j. and Division Order 2009-03.

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