Ezel / IRS Rulings / 201614033
Chief Counsel Advice 201614033 Released April 1, 2016 Advice Transcribed from scan

Unidentified revenue ruling is compatible with the proposed approach

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This page covers one taxpayer's ruling from 2016, 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 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 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.
Transcribed from a scanned original: the IRS released this determination as an image-only PDF. The full text below is a machine transcription, proofread against the scan. Check the original PDF before quoting exact language.
View official IRS release (PDF)

Plain-English summary

The released Chief Counsel email is extremely brief. It addresses an unidentified revenue ruling in connection with an approach that is not described in the public release. The author says the ruling is not inconsistent with that approach and merely adds another layer. The redacted text does not provide enough information to identify the underlying transaction, analysis, or practical effect.

Ruling snapshot

  • Question: Is the unidentified revenue ruling inconsistent with the recipient's approach?
  • Outcome: Advice given: no, the ruling is compatible but adds another layer.
  • Key authorities: IRC § 301; unidentified revenue ruling

Full text (IRS public release)

ID: CCA_2016022915423523
UILC: 301.00-00

Number: 201614033
Release Date: 4/1/2016

From:

Sent: Monday, February 29, 2016 3:42:35 PM
To:

Cc:

Bcc:

Subject: RR

The RR is not inconsistent with your approach. Just adds another layer.

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