Ezel / IRS Rulings / 201531018
Chief Counsel Advice 201531018 Released July 31, 2015 Advice

IRS could amend deed to correct wrong plat number

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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

An IRS deed for seized and sold real property referred to the wrong plat number. The certificate of sale and plat book showed that the IRS had sold plat 4, while the taxpayer had never owned the plat 7 named in the original deed. The purchaser also confirmed the error. Chief Counsel advised that the IRS could issue an amended deed identifying plat 4 and thereby correct the state property records.

Ruling snapshot

  • Question: Could the IRS amend a deed after the original deed identified the wrong plat?
  • Outcome: Advice that an amended deed could be issued
  • Key authorities: IRC § 6338

Full text (IRS public release)

ID: CCA_2015070110475261 [Third Party Communication:

UILC: 6338.00-00 Date of Communication: Month DD, YYYY]

Number: 201531018
Release Date: 7/31/2015
From:
Sent: Wednesday, July 01, 2015 10:47:52 AM
To:
Cc:
Bcc:
Subject: RE: Corrected Deed Question

--------,

Based on the facts of this case we conclude the Service can issue an amended deed to
the purchaser correcting the description of the property that was seized and sold to
indicate it was plat #4. Please see the Certificate of Sale of Seized Property. In the
description of the property the Service was selling the property identified as ----------------
-----------------------------------. It is the same plat that is identified as plat # 4 in the plat
book. The taxpayer was never the actual owner of plat #7 referenced in the Service’s
original deed. The purchaser attested to the same in his letter asking the Service to
correct the error, and the issuance of an amended deed will resolve the problems
caused by the erroneous plat numbers in the state records.

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