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Ezel / IRS Rulings / 201652021
Chief Counsel Advice 201652021 Released December 23, 2016 Advice

Whistleblower claim material withheld as return information

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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

Chief Counsel reviewed material responsive to a Freedom of Information Act request. Pages tied to a specific whistleblower claim were treated as the taxpayer's return and were to be withheld in full under FOIA Exemption 3 and section 6103(a). References to that claim on the remaining pages were also to be redacted as return information.

Ruling snapshot

  • Question: How should records referring to a specific whistleblower claim be handled under FOIA and section 6103?
  • Outcome: advice given
  • Key authorities: IRC § 6103(a); FOIA Exemption 3

Full text (IRS public release)

ID: CCA_2016111014504906
UILC: 0099.07-00

Number: 201652021
Release Date: 12/23/2016
From:
Sent: Thursday, November 10, 2016 2:50:49 PM
To:
Cc:
Bcc:
Subject: RE: FOIA request

Eugene—based on my review of the e-mail you provided, pages 5-12 are related to a
specific whistleblower claim, and as such, are the return of the taxpayer in question.
These pages should be withheld in full pursuant to FOIA Exemption 3/ IRC 6103(a).
For the remaining pages, the specific references to a specific WB claim should also be
redacted as return information.

Melissa Avrutine
Senior Technician Reviewer
CC:PA:7

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