Ezel / IRS Rulings / 201825030

Taxpayer seizure required following Sections 6335 and 6337

Number
201825030
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Sale of Seized Property
Topics
Procedure, penalties, and administration
Code sections
§ 6335, § 6337
Ruling dated
June 7, 2018
Publicly released
June 22, 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 a redacted question involving property seized from a taxpayer. The advice stated that the IRS should follow Sections 6335 and 6337 because the seizure was from the taxpayer. The released email does not describe the property, the proposed sale, or the underlying dispute. It provides no further analysis of how those provisions apply.

Ruling snapshot

  • Question: Which statutory procedures should the IRS follow after seizing property from the taxpayer?
  • Outcome: Advice given: follow Sections 6335 and 6337.
  • Key authorities: IRC §§ 6335 and 6337

Full text (IRS public release)

ID:          CCA_2018060712370551
UILC:        6335.00-00

Number: 201825030
Release Date: 6/22/2018
From:
Sent: Thursday, June 07, 2018 12:37:06 PM
To:
Cc:
Bcc:
Subject: seizure/sale question


----- and I discussed your question, and we agree that in your case, the Service should follow
6335 and 6337 due to the seizure from the taxpayer. Let me know if you want to discuss
further.

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

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace