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Ezel / IRS Rulings / 201818012
Chief Counsel Advice 201818012 Released May 4, 2018 Advice

Technical advice request could be returned unanswered after consultation

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This page covers one taxpayer's ruling from 2018, 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 2018
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 discussed the procedure for ending a technical advice request involving a variable annuity. The referenced revenue procedure required a director to notify the taxpayer before withdrawing a request. It also allowed the Associate office to return a request unanswered after consulting field counsel and the requesting field office. Because an earlier meeting had not included the field office, Counsel needed to determine whether the consultation requirement had been met before closing the case that way.

Ruling snapshot

  • Question: Could the Associate office close the technical advice case by returning the request unanswered?
  • Outcome: Advice given: possibly, but Counsel needed to confirm that the required field-office consultation had occurred.
  • Key authorities: The unidentified revenue procedure’s withdrawal rule and section 11.03.

Full text (IRS public release)

ID: CCA_2017062013153042
UILC: 01.07.00-00

Number: 201818012
Release Date: 5/4/2018
From:
Sent: Tuesday, June 20, 2017 1:15:31 PM
To:
Cc:
Bcc:
Subject: RE: Variable Annuity Tech Advice

According to the Rev Proc, withdrawal must be done by a Director after notifying the
taxpayer. However, section 11.03 allows the associate office to return the request
unanswered after consultation with field counsel and the requesting field office. The
meeting on June 5 did not include the field office, so I am not sure whether we have
satisfied the requirements of the procedure, but let me find out whether we can close
our case by returning the request unanswered.

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