Ezel / IRS Rulings / 201916008

One-line approval that a proposed disclosure is permissible under § 6103(h)(1)

Number
201916008
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Confidentiality and Disclosure of Returns and Return Information
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
March 22, 2019
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 an extremely brief Chief Counsel email. In a single sentence, the author approves a proposed course of action as permissible under section 6103(h)(1), the provision that allows returns and return information to be disclosed to officers and employees of the Department of the Treasury (including the IRS) whose official duties require it for tax administration. The email contains no analysis or facts; essentially all identifying content was redacted before release.

Ruling snapshot

  • Question: Is the proposed disclosure permissible under section 6103(h)(1)?
  • Outcome: advice (yes; it "looks fine" under § 6103(h)(1))
  • Key authorities: IRC § 6103(h)(1)

Full text (IRS public release)

ID:        CCA_2019032212165053
UILC:      6103.08-01

Number: 201916008
Release Date: 4/19/2019
From:
Sent: Friday, March 22, 2019 12:16:50 PM
To:
Cc:
Bcc:
Subject: RE: Advice

Looks fine to me under 6103(h)(1).

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