Taxpayer disclosure authorization must identify information and recipient

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).