Ezel / IRS Rulings / 1319020
Chief Counsel Advice 1319020 Released May 10, 2013 Advice

CCA 1319020: Appeals testimony is covered by the CCDM

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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 Advice points to a provision in the IRS Chief Counsel Directives Manual concerning testimony in appeals proceedings. The message identifies CCDM section 35.6.2.18.2 as covering appeals testimony. It does not provide further analysis or a taxpayer-specific conclusion.

Ruling snapshot

  • Question: Which internal IRS provision covers testimony in appeals proceedings?
  • Outcome: Advice given.
  • Key authorities: CCDM § 35.6.2.18.2; UILC 6330.00-00

Full text (IRS public release)

ID: CCA-419822-13 Number: 201319020
Release Date: 5/10/2013
Office: -------------
UILC: 6330.00-00

From: ---------------------
Sent: Thursday, January 31, 2013 2:58
To: -----------------------------------------------
Cc: ----------------------------
Subject: SO Testimony Questions

FYI, we have a CCDM provision covering appeals testimony: 35.6.2.18.2.

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