Ezel / IRS Rulings / 201711011
Chief Counsel Advice 201711011 Released March 17, 2017 Advice

No objection to excluding tribal death-related payments from 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

An IRS office asked Chief Counsel for assistance with refund claims filed by individuals who received payments from an Indian tribal government when a tribal member died. The responding Chief Counsel office stated that it had no objection to allowing the claims and excluding the payments from the recipients' income. The document is a brief email classified under section 139E and provides no additional facts or legal analysis.

Ruling snapshot

  • Question: Could individuals exclude payments received from an Indian tribal government upon a tribal member's death?
  • Outcome: advice given
  • Key authorities: IRC § 139E

Full text (IRS public release)

ID: CCA_2017011012441051
UILC: 139E.00-00

Number: 201711011
Release Date: 3/17/2017
From:
Sent: Tuesday, January 10, 2017 12:44:10 PM
To:
Cc:
Bcc:
Subject: POSTU-107509-15

You requested our assistance on this matter in the above named case. This e-
mail informs you that CC:ITA has no objection to your office allowing the claims
for refund made by individuals to exclude from income payments they received
from an Indian tribal government upon the death of a member of the tribe.

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