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Ezel / IRS Rulings / 201906005
Chief Counsel Advice 201906005 Released February 8, 2019 Advice

Advisor below fee threshold had no section 6112 duty

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This page covers one taxpayer's ruling from 2019, 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 2019
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 corrected an earlier email about a section 6112 list request. Based on the information supplied, the advisor did not meet the section 6111 fee threshold for material-advisor status. Because the advisor was not a material advisor, it did not have to provide section 6112 information for the transaction.

Ruling snapshot

  • Question: Did the advisor have to provide transaction information under section 6112?
  • Outcome: Advice given that no section 6112 duty applied because the material-advisor fee threshold was not met.
  • Key authorities: IRC §§ 6111 and 6112.

Full text (IRS public release)

ID: CCA_2018102507104743
UILC: 6112.01-00

Number: 201906005
Release Date: 2/8/2019
From:
Sent: Friday, February 08, 2019 10:30:49 AM
To:
Cc:
Bcc:
Subject: RE: IRC 6112 List Request Question

Oops, there was a typo in my earlier email. It should read as follows.

Based on the information that the advisor provided, it does not meet the fee threshold
to be considered a material advisor under section 6111, therefore, it does not need to
provide information pursuant to section 6112 with regard to this transaction.

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