Ezel / IRS Rulings / 201443017

Court filing removes section 6103 concern

Number
201443017
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
General Rule
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
October 1, 2014
Publicly released
October 24, 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 confirmed that IRC § 6103 would no longer present a concern once the document at issue was filed in court. The released email does not describe the document or the underlying matter. The advice is limited to that brief disclosure conclusion.

Ruling snapshot

  • Question: Does IRC § 6103 remain a concern after a document is filed in court?
  • Outcome: Advice given
  • Key authorities: IRC § 6103

Full text (IRS public release)

ID: CCA_2014100109105006 [Third Party Communication:

UILC: 6103.01-00 Date of Communication: Month DD, YYYY]

Number: 201443017
Release Date: 10/24/2014
From:
Sent: Wednesday, October 01, 2014 9:10:50 AM
To:
Cc:
Bcc:
Subject: RE: Request for Advice from -------- Sharepoint/Disclosure/Privilege Issues

Correct. Once the document is filed in court, there would not be a 6103 concern.

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