Ezel / IRS Rulings / 1350035
Chief Counsel Advice 1350035 Released December 13, 2013 Advice

CCA 1350035: peaceful videotaping of an IRS seizure is not prohibited

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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 considers whether a taxpayer may videotape an IRS seizure occurring in the taxpayer's home. The advice identifies no statutory, regulatory, or other provision known to bar peaceful videotaping of the seizure. It notes that federal law and IRC § 7212 criminalize assaulting, resisting, impeding, intimidating, or interfering with federal employees, but concludes that peaceful videotaping would not violate those provisions on the stated facts.

Ruling snapshot

  • Question: May a taxpayer peacefully videotape an IRS seizure occurring in the taxpayer's home?
  • Outcome: Advice given
  • Key authorities: IRC § 7212; 18 U.S.C. § 111

Full text (IRS public release)

ID: CCA_2013080211135852
UILC: 6335.00-00

Number: 201350035
Release Date: 12/13/2013
From:
Sent: Friday, August 02, 2013 11:13:58 AM
To:
Cc:
Bcc:
Subject: RE: Request for Informal Advice -- Taxpayers Intend to Videotape Seizure

Hi,-------

The consensus among the folks you emailed (who were in the office yesterday) does not differ
from what we discussed. There is nothing that we are aware of that would bar a taxpayer from
videotaping a seizure occurring in his home. As promised though, I did email the Br ------
practice group asking if anyone knows of any statutory provision (Code or otherwise), reg or
whatnot that prohibits the videotaping of a seizure on the taxpayer’s property. I’ve gotten no
affirmative responses. But if something comes up between now and Monday, I’ll definitely let
you know.

There is one thing worth mentioning. There are provisions that criminalize forcibly assaulting,
resisting, opposing, impeding, intimidating, or interfering with a federal employee engaged in
the performance of official duties (18 USC 111) and corruptly or by force or threats of force
endeavoring to intimidate or impede any federal employee acting in an official capacity
under the Code (IRC 7212). But peacefully videotaping the seizure would not fun afoul of
these provisions. And there is nothing indicated thus far that suggests that the tp is not
going to act peacefully.

If you would like to discuss this further, please contact me. Have a good weekend.

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