Ezel / IRS Rulings / 201350034

CCA 201350034: IRS may use a party's return information in a later examination of that party

Number
201350034
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Disclosure in Judicial or Administrative Tax Administration Proceedings
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
June 26, 2013
Publicly released
December 13, 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 addresses whether return information gathered in an earlier determination may be used in a later examination of the same party. The advice concludes that the party's own information may be disclosed in an examination of that party under IRC § 6103(h)(4)(A), regardless of the tax year under examination. It also states that IRC § 6103(h)(1) permits the IRS to use return information internally when needed for official duties.

Ruling snapshot

  • Question: May the IRS use a party's return information in a later examination of that party?
  • Outcome: Advice given
  • Key authorities: IRC §§ 6103(h)(1), 6103(h)(4)(A)

Full text (IRS public release)

ID: CCA_2013062611315743
Office: -----------------------------
UILC: 6103.08-04
Number: 201350034
Release Date: 12/13/2013
From: ---------------------
Sent: Wednesday, June 26, 2013 11:32:05 AM
To: ------------------------------
Cc: -------------------------------------------
Subject: RE: Quick disclosure question

------------

To the extent you wish to use -------- return information (i.e. information gathered as part of a determination of-------
liability under the Code) in a later examination of -----, you are free to do so. Section 6103(h)(4)(A) allows us to
disclose a party’s own info in an exam of that party, regardless of the year under exam. Additionally, section
6103(h)(1) allows us to use internally return information needed as part of our official duties.

Thanks,

-------

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