Ezel / IRS Rulings / 201526010
Chief Counsel Advice 201526010 Released June 26, 2015 Advice

Related issue could be disclosed in referred taxpayer case

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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 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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