Ezel / IRS Rulings / 1321020
Chief Counsel Advice 1321020 Released May 24, 2013 Advice

CCA 1321020: IRS gives internal routing guidance for IRC § 6110 petitions

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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 provides internal procedural guidance for petitions under IRC § 6110. It states that an IRC § 6110 petition receives a “D” after the docket number. It also states that all IRC § 6110 cases are handled by National Office Chief Counsel, Procedure & Administration, citing the Chief Counsel Directives Manual.

Ruling snapshot

  • Question: How are IRC § 6110 petitions identified and routed within Chief Counsel's office?
  • Outcome: Advice given.
  • Key authorities: IRC § 6110; CCDM 37.1.1.5.

Full text (IRS public release)

ID: CCA_2013050112592153
Office: --------------
UILC: 6110.00-00
Number: 201321020
Release Date: 5/24/2013
From: ----------------
Sent: Wednesday, May 01, 2013 12:59:41 PM
To: ------------------
Cc: -------------------
Subject: RE: 6110 petitions

IRC 6110 petitions get a "D" after the docket number. Also, please note that all IRC 6110 cases are
handled in National Office Chief Counsel (Procedure & Administration). See CCDM 37.1.1.5.

If you have further questions, please feel free to contact me.

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