Ezel / IRS Rulings / 201818014

Exam teams may share information needed for tax administration

Number
201818014
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Disclosure within the Department of Treasury; Disclosure in Judicial or Administrative Tax Administration Proceedings
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
February 7, 2018
Publicly released
May 4, 2018
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2018, 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 2018
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 addressed whether IRS examination teams could share information and documents with one another. It advised that Section 6103(h)(1) permits internal disclosure when the receiving examination team needs the material to perform its tax administration duties. The advice was limited by that need-based standard.

Ruling snapshot

  • Question: May IRS examination teams disclose tax information and documents to one another?
  • Outcome: Advice given: yes, to the extent the receiving team needs them for tax administration duties.
  • Key authorities: IRC § 6103(h)(1).

Full text (IRS public release)

ID: CCA_2018020712040453
UILC: 6103.08-01, 6103.08-04

Number: 201818014
Release Date: 5/4/2018
From:
Sent: Wednesday, February 07, 2018 12:04:04 PM
To:
Cc:
Bcc:
Subject: RE: Are you available for a quick 6103 consult?

Hello ------

Under 6103(h)(1), the exam teams can disclose information and documents among
themselves to the extent that it is needed by the recipient exam team for their tax
administration duties.

Let me know if you have further questions.

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