Ezel / IRS Rulings / 202019001

Chief Counsel accepted the taxpayer's income treatment

Number
202019001
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Underwriting Income
Topics
Other topics
Code sections
§ 832
Ruling dated
October 1, 2019
Publicly released
May 8, 2020
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 2020, 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 2020
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 brief advice concerns a heavily redacted examination matter indexed by the IRS under underwriting income. The taxpayer maintained that it did not have to include certain amounts in income for two redacted years and could deduct in a later year an amount it had previously included in income for another redacted year. Chief Counsel stated that it had no objection to those positions. The release contains no factual or legal analysis explaining the amounts or the reason for the conclusion.

Ruling snapshot

  • Question: May the taxpayer exclude the redacted amounts in two years and later deduct another amount that it previously included in income?
  • Outcome: advice given (Chief Counsel had no objection to the taxpayer's positions)
  • Key authorities: The released text cites no statute, regulation, or other authority

Full text (IRS public release)

ID: CCA_2019100111443843
UILC: 832.04-00

Number: 202019001
Release Date: 5/8/2020
From:
Sent: Tuesday, October 01, 2019 11:44:38 AM
To:
Cc:
Bcc:
Subject: Request for assistance - POSTU-106985-19

You requested our assistance on a matter with respect to the examination of --------------
--------------------------------. As discussed, we have no objection to the taxpayer’s position that (i) it is not required to include in income the amounts at issue for ------- and ------- and (ii) it may deduct in a later year the amount at issue that it previously included in income for -------.

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