Ezel / IRS Rulings / 201321020

CCA 201321020: IRS gives internal routing guidance for IRC § 6110 petitions

Number
201321020
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Public Inspection of Written Determinations
Topics
Procedure, penalties, and administration
Code sections
§ 6110
Ruling dated
May 1, 2013
Publicly released
May 24, 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 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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