Ezel / IRS Rulings / 201710026
Chief Counsel Advice 201710026 Released March 10, 2017 Advice

Tribal settlement distributions were taxable income

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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 considered payments made to tribal members from a settlement of contract litigation between the federal government and certain tribes. Based on the facts provided and the applicable law, the advice found no legal basis to exclude the distributions from the recipients' gross income. It therefore treated the payments as taxable. The email stated that a later memorandum would provide a fuller legal analysis.

Ruling snapshot

  • Question: Could tribal members exclude distributions from a government contract-dispute settlement from gross income?
  • Outcome: advice given
  • Key authorities: IRC § 61

Full text (IRS public release)

ID: CCA_2017013014491696
UILC: 61.32-01

Number: 201710026
Release Date: 3/10/2017
From:
Sent: Monday, January 30, 2017 2:49:16 PM
To:
Cc:
Bcc:
Subject: Tribal Settlement Distributions / 1099 Issuance issue

You asked whether certain payments to tribal members, made out of a settlement of
litigation between the government and certain tribes related to a contract dispute, are
taxable. Based on the information provided and a review of the applicable law, we do
not believe there is any legal basis to exclude the payments from the tribal members’
income. We will follow up this email with a memorandum with a fuller discussion of the
relevant law and analysis.

Let me know if you have any additional questions.

Thanks,

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