Ezel / IRS Rulings / 201502011
Chief Counsel Advice 201502011 Released January 9, 2015 Advice

Taxpayer disclosure authorization must identify information and recipient

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This page covers one taxpayer's ruling from 2015, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

Currency note: this determination was released in 2015
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 said taxpayer authorizations to disclose return information are case-specific and offered suggested starting language. The authorization should identify the taxpayer, the designated recipient, and the return information to be disclosed. It must include taxable-year information required by the regulations. The taxpayer must also sign and date the authorization in accordance with the applicable regulation.

Ruling snapshot

  • Question: What information should a taxpayer's authorization to disclose return information contain?
  • Outcome: Advice given on required identifying, scope, signature, and date information
  • Key authorities: IRC § 6103(c); Treas. Reg. §§ 301.6103(c)-1(b) and 301.6103(c)-1(e)(4)

Full text (IRS public release)

ID: CCA_2014112610151117
UILC: 6103.03-00

Number: 201502011
Release Date: 1/9/2015
From:
Sent: Wednesday, November 26, 2014 10:15:11 AM
To:
Cc:
Bcc:
Subject: RE: Disclosure question pertaining to the examination of -------------------------------

No sample – every one I’ve dealt with was case-specific. However something like this
would be a start:

[Name, address, and EIN of taxpayer] authorizes disclosure of the information
described below to [name and address of designated recipient]:
Then describe the return information, including taxable year information as
required by the regs (26 CFR 301.6103(c)-1(b)).

The letter must be signed and dated in accordance with 26 CFR 301.6103(c)-1(e)(4).

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