Ezel / IRS Rulings / 201526010

Related issue could be disclosed in referred taxpayer case

Number
201526010
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Disclosure to the Department of Justice
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
April 29, 2015
Publicly released
June 26, 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 saw no disclosure problem with addressing an additional issue involving the same taxpayer in a case already referred to the Department of Justice. The brief advice relied on section 6103(h)(2)(A). The underlying subject and facts were redacted from the public release.

Ruling snapshot

  • Question: Could an additional issue involving the same taxpayer be handled in an already referred case?
  • Outcome: Advice given that the disclosure was permissible.
  • Key authorities: IRC § 6103(h)(2)(A).

Full text (IRS public release)

ID: CCA_2015042909310017 [Third Party Communication:

UILC: 6103.08-02 Date of Communication: Month DD, YYYY]

Number: 201526010
Release Date: 6/26/2015
From:
Sent: Wednesday, April 29, 2015 9:31:01 AM
To:
Cc:
Bcc:
Subject: RE: ---------------------------------------------------------------------------------------------------------------

I see no problem. This is just another issue pertaining to the same taxpayer in a
referred case. 6103(h)(2)(A).

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