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Chief Counsel Advice 201850020 Released December 14, 2018 Advice

IRC 6103(h)(1) authorizes disclosing return information to agency employees

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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

This is a brief, informal Chief Counsel Advice sent as an email answering a
"need to know" disclosure question. Federal law generally keeps tax returns and
return information confidential under Code Section 6103, but there are specific
exceptions. Here Chief Counsel advised that, based on the facts provided, Code
Section 6103(h)(1) applies to authorize disclosing return information to the
questioner's employees. Section 6103(h)(1) permits return information to be made
available to officers and employees of the Department of the Treasury whose
official duties require it in connection with tax administration. No further legal
analysis is provided; it is a short confirmation that the disclosure is permitted.

Ruling snapshot

  • Question: Does Code Section 6103(h)(1) authorize disclosing return information to the questioner's employees?
  • Outcome: Advice given (yes, 6103(h)(1) applies)
  • Key authorities: IRC § 6103(h)(1)

Full text (IRS public release)

ID: CCA_2018101214595853
UILC: 6103.08-01

Number: 201850020
Release Date: 12/14/2018
From:
Sent: Friday, October 12, 2018 2:59:58 PM
To:
Cc:
Bcc:
Subject: RE: Need to know question - TPP/APMA

Hi ------------

Thanks for the clarification. Based on the information you provide below, IRC
6103(h)(1) applies here to authorize the disclosure of return information to your
employees.

Hope that helps. If you have further questions, please feel free to contact me.


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