Lawyer-regulation office cannot receive return information

Plain-English summary

Chief Counsel advised that IRS personnel could not disclose a taxpayer’s return information to a state lawyer-regulation office without the taxpayer’s consent. Section 6103 permits some disclosures to states, but only in limited circumstances and to specified state agencies. Those exceptions did not appear to cover this request. The office could instead check public state lien filings to determine whether the IRS had filed liens.

Ruling snapshot

• Question: May the IRS disclose return information to a state lawyer-regulation office without taxpayer consent?
• Outcome: Advice given
• Key authorities: IRC § 6103

Full text (IRS public release)

ID: CCA_2015101308282607 [Third Party Communication:

UILC: 6103.00-00, 6103.01-00, 6103.03-00 Date of Communication: Month DD, YYYY]
Number: 201545023
Release Date: 11/6/2015
From:
Sent: Tuesday, October 13, 2015 8:28:27 AM
To:
Cc:
Bcc:
Subject: RE: Disclosure to office of lawyer regulation

Hi -----------,

You can talk to me but you are correct that we cannot disclose this information without
the consent of the taxpayer whose return information would be disclosed. While section
6103 allows disclosure of return information to states, it only does so in limited
circumstances and to limited state agencies, none of which appear to be applicable to
your situation. The OLR could always check their state lien filings to see if we filed liens
but we cannot disclose information.

Thanks,

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