Ezel / IRS Rulings / 201916002
Chief Counsel Advice 201916002 Released April 19, 2019 Advice

Brief email confirming a Tax Court signature-block point

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This page covers one taxpayer's ruling from 2019, 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 2019
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

This is a brief, informal Chief Counsel email that is part of an exchange about recent amendments to the United States Tax Court's Rules of Practice and Procedure. In a one-line reply, the author confirms that the requested information may be included "if you have that information for the signatory," which fits the amended Rule 23(a)(3) requirement that signature blocks list an e-mail address if one exists. The message contains no legal analysis and resolves nothing beyond confirming that point; nearly all identifying content was redacted before release.

Ruling snapshot

  • Question: May the requested signature-block information be included for the signatory (in connection with amended Tax Court Rule 23(a)(3))?
  • Outcome: advice (yes, if that information exists for the signatory)
  • Key authorities: Tax Court Rules of Practice and Procedure, Rule 23(a)(3)

Full text (IRS public release)

ID:          CCA_2018121413244544
UILC:        6213.00-00

Number: 201916002
Release Date: 4/19/2019
From:
Sent: Friday, December 14, 2018 1:24:45 PM
To:
Cc:
Bcc:
Subject: RE: Amendments to Tax Court Rules of Practice and Procedure

Yes, if you have that information for the signatory.

Signed,

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