Ezel / IRS Rulings / 201515031

Partnership return information may be disclosed to partners

Number
201515031
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Return Information
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
April 2, 2015
Publicly released
April 10, 2015
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 2015, 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 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 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 advised that partnership return information may be disclosed to any partner under section 6103(e). Once a TEFRA audit begins, partner information may also be disclosed to other partners under section 6103(h)(4)(A). The advice cites Abelein v. United States as support for the audit-related disclosure.

Ruling snapshot

  • Question: May partnership and partner information be disclosed to partners during a TEFRA audit?
  • Outcome: Advice given: yes, under both identified disclosure provisions.
  • Key authorities: IRC §§ 6103(e) and 6103(h)(4)(A); Abelein v. United States, 323 F.3d 1210 (9th Cir. 2003).

Full text (IRS public release)

ID: CCA_2015040210103901 [Third Party Communication:

UILC: 6103.02-02
Date of Communication: Month DD, YYYY]

Number: 201515031
Release Date: 4/10/2015
From:
Sent: Thursday, April 02, 2015 10:10:39 AM
To:
Cc:
Bcc:
Subject: RE: Disclosure & TEFRA question

The information can be disclosed both because partnership return information can be disclosed
to any partner under section 6103(e) and because, once a TEFRA audit begins, partner
information can be disclosed to other partners under section 6103(h)(4)(A) and Abelein v.
U.S., 323 F.3d 1210 (9th Cir, 2003)

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