Ezel / IRS Rulings / 201411030
Chief Counsel Advice 201411030 Released March 14, 2014 Advice

FSA citations removed from revised Form 886A

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This page covers one taxpayer's ruling from 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 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 advised that Field Service Advice could not be cited as authority. After those citations were removed, the Form 886A had to be revised so the text made sense. Counsel recommended using the attached revised document, which is redacted from the public release.

Ruling snapshot

  • Question: How should a Form 886A be revised after impermissible Field Service Advice citations are removed?
  • Outcome: Advice given, use the revised attachment
  • Key authorities: IRC § 165

Full text (IRS public release)

ID: CCA-418350-13
Office: ---------------
UILC: 165.00-00
Number: 201411030
Release Date: 3/14/2014
From: --------------------
Sent: Monday, April 1, 2013 8:35 AM
To: ------------------
Cc: -----------------------
Subject: RE: Echols Rationale

FSA cannot be cited as authority. When those citations were removed, the Form 886A had to be altered
to make more sense. We recommend that the attached be used. Please call me if you have any
questions.

Attachment: [REDACTED]

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