Ezel / IRS Rulings / 201550039

IRS office may use an unredacted private letter ruling

Number
201550039
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Disclosure to Federal Employees for Tax Administration Purposes
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
November 6, 2015
Publicly released
December 11, 2015
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2015, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, 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 is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, 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 advised that the relevant IRS office should have an unredacted copy of a private letter ruling available for use in addressing a question about self-created goodwill. If that office had destroyed its copy under its records-retention schedule, the employee asking the question could provide another copy.

Ruling snapshot

  • Question: How could an IRS employee provide the relevant office with an unredacted private letter ruling?
  • Outcome: Advice given
  • Key authorities: IRC § 6103

Full text (IRS public release)

ID: CCA_2015110615112647
UILC: 6103.08-00

Number: 201550039
Release Date: 12/11/2015
From:
Sent: Friday, November 06, 2015 3:11:26 PM
To:
Cc:
Bcc:
Subject: RE: Question regarding use of plr for self-created goodwill?

I am in ------(Branch 7) and not in the ----------------------, and ------------ branch (------), but it is my understanding that ------ should have an un-redacted version available. If for some reason ------ has destroyed the PLR due to their retention schedule, you can provide ------ your copy.

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