Ezel / IRS Rulings / 1319019
Chief Counsel Advice 1319019 Released May 10, 2013 Advice

CCA 1319019: Case markings may show how authorities were used in advice

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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.
View official IRS release (PDF)

Plain-English summary

Chief Counsel Advice asks whether markings on cases in a legal file could show which portions were cited in advisory memoranda. The message specifically asks about highlighted, bracketed, or handwritten notations. It states that the documents could be withheld only if they would reveal the nature of the advice they helped shape. The release does not identify the underlying cases or reach a further conclusion.

Ruling snapshot

  • Question: When might markings on cases in a legal file reveal the nature of Chief Counsel advice?
  • Outcome: Advice given.
  • Key authorities: The release identifies no Internal Revenue Code section beyond UILC 9999.00-00.

Full text (IRS public release)

ID: CCA_2013041907200207 Number: 201319019
Release Date: 5/10/2013
Office: --------------
UILC: 9999.00-00

From: -------------------------------
Sent: Friday, April 19, 2013 7:20:17 AM
To: ---------------------
Cc:
Subject: RE: Westlaw printouts in the legal file

What do the cases from WL reveal? Are there portions that have been highlighted, bracketed or which
have handwritten notations that would indicate what portions of the cases were being cited in Counsel's
advisory memos? I think we can only withhold these documents if they would reveal the nature of the advice they were instrumental in shaping.

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