Ezel / IRS Rulings / 201538017
Chief Counsel Advice 201538017 Released September 18, 2015 Advice

Legal advice may be shared with Counsel staff who need it

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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

Counsel confirmed a disclosure decision reached during a telephone conversation. A PDF copy of legal advice could be sent to other Counsel personnel who had a need to know the information. The released email gives no additional facts or conditions.

Ruling snapshot

  • Question: Could a PDF of legal advice be shared with Counsel personnel who had a need to know?
  • Outcome: Advice given
  • Key authorities: IRC § 6103

Full text (IRS public release)

ID: CCA-08201013-15 [Third Party Communication:

UILC: 6103.08-01 Date of Communication: Month DD, YYYY]

Number: 201538017
Release Date: 9/18/2015
From: ------------------------------
Sent: Thursday, August 20, 2015 10:13 AM
To: -----------------
Cc:
Subject: -----------------------------------

----------,

This confirms the decision we agreed upon in our telephone conversation this morning
that it is permissible for you to send a pdf version of legal advice to Counsel personnel
who have a “need to know”.

Please contact me if I can be of further assistance.

-----------------------------

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