IRS letters need not show a taxpayer's full TIN

Number
201610018
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Identifying Numbers
Code sections
§ 6109
Ruling dated
February 17, 2016
Publicly released
March 4, 2016

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2016, 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 2016
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 no legal requirement compels the IRS to include a taxpayer's full taxpayer identification number on a letter sent to that taxpayer. The advice did not say that the number should always be truncated or omitted. It left the operational choice open despite the absence of a legal requirement to display the full number.

Ruling snapshot

  • Question: Must an IRS letter to a taxpayer include the taxpayer's full TIN?
  • Outcome: Advice given: no, but the TIN need not always be truncated or omitted.
  • Key authorities: IRC § 6109

Full text (IRS public release)

~~~
ID: CCA-02171105-16
UILC: 6109.00-00

Number: 201610018
Release Date: 3/4/2016
From: -------------------
Sent: Wednesday, February 17, 2016 11:05 AM
To: --------------
Cc: ------------------
Bcc: -------------------
Subject: TINs Masking

-------,

There is no legal requirement to include the taxpayer’s full TIN on a letter sent from the Service to the
taxpayer. This does not mean that the TIN should always be truncated or omitted.

Please feel free to contact me with any questions or concerns at --------------------

Thank you,


~~~

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