Ezel / IRS Rulings / 202053012
Chief Counsel Advice 202053012 Released December 31, 2020 Advice

The IRS should not sign another form after providing the required deed

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This page covers one taxpayer's ruling from 2020, 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 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 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

Counsel addressed a request involving a sales disclosure form after the IRS provided a deed. The short email states that the Service satisfied the statutory requirements when it provided the deed. Counsel advised that the IRS did not need to execute any additional documents and should not do so. The advice had been reviewed with a branch reviewer, Small Business/Self-Employed Division Counsel, and Compliance Policy. The public release does not describe the property, sale, deed, requested form, or the specific statutory analysis.

Ruling snapshot

  • Question: Must the IRS execute an additional document after providing the deed required by statute?
  • Outcome: Advice given: no, and the IRS should not execute additional documents
  • Key authorities: IRC § 6338

Full text (IRS public release)

ID: CCA_2020090314265496
UILC: 6338.00-00

Number: 202053012
Release Date: 12/31/2020
From: ---------------------
Sent: Thursday, September 3, 2020 2:26:54 PM
To: ----------------
Cc:
Bcc:
Subject: RE: sales disclosure form

As we discussed, the Service satisfied the statutory requirements when providing the
deed. It need not, and should not, execute additional documents. I ran this past a
branch reviewer and SB Division Counsel, as well as Compliance Policy.

If you would like to discuss this further, please contact me.

Have a great holiday weekend.

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