Ezel / IRS Rulings / 201409006

IRS advice permits sharing an unredacted Form 886-A within the IRS

Number
201409006
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Disclosure within the Department of Treasury
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
November 12, 2013
Publicly released
February 28, 2014
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 2014, 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 2014
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 advised that an unredacted Form 886-A could be shared with another IRS examination team under IRC § 6103(h)(1). The advice also required the document to identify its source so it could later be excluded as third-party return information if the other taxpayer requested a copy of its examination file.

Ruling snapshot

  • Question: Could an unredacted Form 886-A be shared with another IRS examination team?
  • Outcome: Advice given
  • Key authorities: IRC § 6103(h)(1)

Full text (IRS public release)

ID: CCA_2013111209201564
[Third Party Communication:

UILC: 6103.08-01
Date of Communication: Month DD, YYYY]

Number: 201409006
Release Date: 2/28/2014
From:
Sent: Tuesday, November 12, 2013 9:20:15 AM
To:
Cc:
Bcc:
Subject: RE: disclosure question

The unredacted 886-A may be shared with the -------- Exam Team pursuant to IRC
6103(h)(1). However, make sure its source is properly indicated on the document so
that it can be later excluded as third party return information in the event that the --------
taxpayer requests a copy of its exam file.

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