Ezel / IRS Rulings / 201447035
Chief Counsel Advice 201447035 Released November 21, 2014 Advice

IRS may seize and sell a chose in action

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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 an IRS employee to rely on the Internal Revenue Manual rather than an earlier Chief Counsel Advice that the email described as incorrect. A chose in action, meaning an enforceable personal right such as a debt or claim, could be seized and sold at an IRS tax sale in the same manner as tangible property. The email did not provide the facts needed to draft the property description for the notice of seizure. Counsel offered to assist with that description if the employee supplied more details.

Ruling snapshot

  • Question: Can the IRS seize and sell a chose in action, and how should it be described in the seizure notice?
  • Outcome: Advice given that the property can be seized and sold, with further facts needed for the notice description
  • Key authorities: IRS levy, seizure, and tax-sale procedures

Full text (IRS public release)

ID: CCA_2014102009165719 [Third Party Communication:

UILC: 50.00.00-00 Date of Communication: Month DD, YYYY]

Number: 201447035
Release Date: 11/21/2014
From:
Sent: Monday, October 20, 2014 9:16:57 AM
To:
Cc:
Bcc:
Subject: FW: Request for assistance.

---------, rely on the IRM and not the CCA, which is incorrect. A chose in action can be seized and
sold at an IRS tax sale just like tangible property. As far as properly describing the property on
the notice of seizure, if you give us more details we can assist you on that.

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