Ezel / IRS Rulings / 9943004

CCA 9943004: Advice on enforcing an IRS summons

Number
9943004
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
SUMMONSES: Def. to compliance:Other
Topics
Income and deductions
Ruling dated
July 16, 1999
Publicly released
October 29, 1999
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 1999, 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 1999
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

A district counsel asked whether the Department of Justice should petition to enforce an administrative summons served on a taxpayer. The publicly released memorandum states the question, but the conclusion, facts, and case development are redacted. Its answer and reasoning cannot be determined from the released text.

Ruling snapshot

  • Question: Should the Justice Department be asked to enforce the IRS summons?
  • Outcome: Advice given; the conclusion is redacted.
  • Key authorities: None identified in the released text.

Full text (IRS public release)

DEPARTMENT OF THE TREASURY
I N T E R N AL R E V E N U E S E R V I C E WASHINGTON, D.C. 20224
July 16, 1999

Number: 199943004
CC:EL:GL:Br3
Release Date: 10/29/1999
GL-704489-99

UILC: 75.04.06-00
9999.98-00

MEMORANDUM FOR REID M. HUEY
DISTRICT COUNSEL,

FROM: Lawrence H. Schattner
Chief, Branch 3 (General Litigation)

SUBJECT:

This responds to your memorandum dated July 1, 1999. This document is not to
be cited as precedent.

Issue

Whether the Department of Justice should be requested to file a petition to enforce
the administrative summons served on the taxpayer?

Conclusion

Facts
2

.

Case Development
3

.

If you have any questions, please call (202) 622-3630.

Attachments:
As stated

cc: Assistant Regional Counsel (GL), Midstates Region

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