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Ezel / IRS Rulings / 201739011
Chief Counsel Advice 201739011 Released September 29, 2017 Advice

Federal tax liens upheld against both named entities

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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

An unincorporated division incurred a FICA tax liability. The requesting office asked whether the resulting federal tax lien attached to another entity's assets when that entity's charter authorized creation of business units intended to segregate the assets and liabilities of separate ventures despite common directorship. Based on the submitted facts, Chief Counsel advised that the notices of federal tax lien filed against both redacted parties were proper. The released advice does not provide the underlying analysis.

Ruling snapshot

  • Question: Are federal tax lien notices proper against both the division and the related entity despite the charter's asset-segregation provisions?
  • Outcome: advice given
  • Key authorities: UIL 7701.20-00

Full text (IRS public release)

ID:        CCA_2017060714192296
UILC:      7701.20-00

Number: 201739011
Release Date: 9/29/2017
From:
Sent: Wednesday, June 07, 2017 2:19:22 PM
To:
Cc:
Bcc:
Subject: Request for Technical Assistance: POSTS-117911-12


On 2/14/2017, you submitted a request for technical assistance that asked whether the federal
tax lien for the assessment of a FICA tax liability incurred by ----------------------------(an
unincorporated division of ------------------------------------------------------------------------------) attaches
to the assets of -----------------------------------------------------------------------------when ---------------------
----------------------------------------------------------- charter specifically empowers ---------------------------
-------------------------------------------------------- to create --------------------------------------for the
purpose of legally segregating the assets and liabilities of discrete business endeavors of ---------
----------------------------------------------------------------------------- regardless of common directorship.

Based upon the facts as presented in your request, the notices of federal tax lien filed against
--------------------------------------------------------------------------- are proper. Additionally, the notices
of federal tax lien filed against --------------------------------------are proper.


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