Ezel / IRS Rulings / 201916002

Brief email confirming a Tax Court signature-block point

Number
201916002
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Restrictions Applicable to Deficiencies; Petition to Tax Court
Topics
Procedure, penalties, and administration
Code sections
§ 6213
Ruling dated
December 14, 2018
Publicly released
April 19, 2019
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 2019, 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 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 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

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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