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Ezel / IRS Rulings / 201650016
Chief Counsel Advice 201650016 Released December 9, 2016 Advice

Information sent to IRS raises no disclosure issue

Apply this to your situation

This page covers one taxpayer's ruling from 2016, 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 2016
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

The underlying question and factual context are redacted from this brief Chief Counsel email. The advice states that a disclosure made to the IRS does not create a disclosure issue on that basis. It explains that the IRS may receive information from any lawful source. The memorandum does not address disclosures by the IRS or provide further facts.

Ruling snapshot

  • Question: Does sending information to the IRS create a disclosure problem?
  • Outcome: advice given
  • Key authorities: IRC § 6103

Full text (IRS public release)

ID: CCA_2016101109090606
UILC: 6103.00-00

Number: 201650016
Release Date: 12/9/2016
From:
Sent: Tuesday, October 11, 2016 9:09:06 AM
To:
Cc:
Bcc:
Subject: RE: quick question

----------—so long as the disclosures are TO the IRS, there is no disclosure issue. The
IRS is free to receive information from any lawful source. Please let me know if you
have any additional questions.

------------------------

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