Ezel / IRS Rulings / 1329017
Chief Counsel Advice 1329017 Released July 19, 2013 Advice

CCA says a legal opinion is likely protected by attorney-client privilege absent waiver

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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 whether a legal opinion would be protected by attorney-client privilege. On the limited information provided, the advice says it would likely be privileged unless there is a reason to believe the privilege was waived. The short memorandum does not identify additional facts or analyze a different privilege doctrine.

Ruling snapshot

  • Question: Would the legal opinion be subject to attorney-client privilege?
  • Outcome: Advice given. The opinion would likely be privileged absent waiver.
  • Key authorities: Attorney-client privilege; IRC § 7602 appears in the UILC classification.

Full text (IRS public release)

                                                                                                          -

ID: CCA_2013070112114803
Office: ------------
UILC: 7602.00-00
Number: 201329017
Release Date: 7/19/2013
From: ---------------------
Sent: Monday, July 01, 2013 12:11:51 PM
To: ------------------------
Cc:
Subject: RE: Privilege Question

Without anymore information, I would think the legal opinion would be subject to attorney-client privilege,
unless you have any reason to believe that the privilege is waived.

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