Ezel / IRS Rulings / 1323018
Chief Counsel Advice 1323018 Released June 7, 2013 Advice

CCA recommends judicial approval under IRC § 6334

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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 addresses the procedure the Service should follow in the matter described in the memorandum. The advice records a consensus that the Service should seek judicial approval as provided in IRC § 6334. The short memorandum does not identify the property or explain the underlying facts, so no broader conclusion can be drawn from the released text.

Ruling snapshot

  • Question: What procedure should the Service follow under IRC § 6334 in the matter presented?
  • Outcome: Advice given. The Service should seek judicial approval.
  • Key authorities: IRC § 6334

Full text (IRS public release)

ID: CCA_2013052017345252
UILC: 6334.04-00

Number: 201323018
Release Date: 6/7/2013
From:
Sent: Monday, May 20, 2013 5:34:52 PM
To:
Cc:
Bcc:
Subject: RE: question

In case you did not get the voice message (belts and suspenders), the consensus is that
the Service should seek judicial approval as provided in section 6334. If you’d like to
discuss this, you can give me a call. This afternoon/evening, you can reach me at ---------

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