Ezel / IRS Rulings / 201543017
Chief Counsel Advice 201543017 Released October 23, 2015 Advice

Field office facts may support a technical advice request

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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 responded to a question about the statement of facts for a technical advice request. The email quoted Revenue Procedure 2015-2, which requires the field office to submit its declaration with the initial request. If the parties cannot agree on the facts, the Associate office may rely on the field office’s presentation. The writer said a further answer was still pending.

Ruling snapshot

  • Question: What factual statement may the Associate office rely on when the parties do not agree
  • Outcome: Preliminary procedural advice given
  • Key authorities: Rev. Proc. 2015-2, § 7.06

Full text (IRS public release)

ID:        CCA_2015091111591143                [Third Party Communication:

UILC:      513.00-00                           Date of Communication: Month DD, YYYY]

Number: 201543017
Release Date: 10/23/2015
From:
Sent: Friday, September 11, 2015 11:59:11 AM
To:
Cc:
Bcc:
Subject: RE: POP Statement


Good morning ---------,

I am waiting on answer as to this. However, In 7.06 of Rev. Proc. 2015-2 in the last two
sentences of the first paragraph it does state: The field office must submit this
declaration with the initial request for technical advice. If no agreement regarding the
facts is reached, the Associate office may rely on facts presented by the field office.

I will get to you on this.

Thanks,

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

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