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.
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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