Ezel / IRS Rulings / 201710024
Chief Counsel Advice 201710024 Released March 10, 2017 Advice

Hardship was not relevant to a lien discharge request

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This page covers one taxpayer's ruling from 2017, 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 2017
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 followed up on a certificate of discharge request concerning a buyer's status as a purchaser. It agreed with the recipient's stated position regarding both an income tax assessment and a trust fund recovery penalty assessment. The released email does not reproduce that position or its reasoning, so the precise substantive conclusion is unclear. It separately states that hardship was not an issue.

Ruling snapshot

  • Question: How should a buyer's purchaser status affect a certificate of discharge request involving income tax and trust fund recovery penalty assessments?
  • Outcome: advice given, but the agreed position is not stated in the released text
  • Key authorities: IRC § 6325

Full text (IRS public release)

ID: CCA_2016121213252620
UILC: 6325.03-00

Number: 201710024
Release Date: 3/10/2017
From:
Sent: Monday, December 12, 2016 1:25:26 PM
To:
Cc:
Bcc:
Subject: RE: Certificate of Discharge Request - Status of Buyer as "Purchaser"

--------. Here is the email follow-up to the voice message. We agree with what you
stated with respect to both the income tax assessment and the TFRP
assessment. Also, as we discussed, hardship is not an issue.

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

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