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Ezel / IRS Rulings / 201728022
Chief Counsel Advice 201728022 Released July 14, 2017 Advice

Information received in determining tax liability is return information

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This page covers one taxpayer's ruling from 2017, 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 2017
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 considered whether information received by the IRS was return information under IRC § 6103. The advice states that return information includes information the IRS gathers, collects, or creates as part of determining an actual or possible tax liability. Because the IRS received the information as part of such a determination, it qualified as return information. The released email does not identify the underlying information.

Ruling snapshot

  • Question: Was information received during an actual or possible tax-liability determination return information?
  • Outcome: advice given, it was return information
  • Key authorities: IRC § 6103

Full text (IRS public release)

ID: CCA_2017062907434643
UILC: 6103.02-00, 6103.02-02

Number: 201728022
Release Date: 7/14/2017
From:
Sent: Thursday, June 29, 2017 7:43:46 AM
To:
Cc:
Bcc:
Subject: RE: Review of WA191 BA

Section 6103. Return information is any information gathered, collected, or created by
the IRS as part of a determination of liability (or possible liability) under the Code. We
receive the information as part of a determination of liability (or possible liability) under
the Code. Thus, return information.

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