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Ezel / IRS Rulings / 201916008
Chief Counsel Advice 201916008 Released April 19, 2019 Advice

One-line approval that a proposed disclosure is permissible under § 6103(h)(1)

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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

This is an extremely brief Chief Counsel email. In a single sentence, the author approves a proposed course of action as permissible under section 6103(h)(1), the provision that allows returns and return information to be disclosed to officers and employees of the Department of the Treasury (including the IRS) whose official duties require it for tax administration. The email contains no analysis or facts; essentially all identifying content was redacted before release.

Ruling snapshot

  • Question: Is the proposed disclosure permissible under section 6103(h)(1)?
  • Outcome: advice (yes; it "looks fine" under § 6103(h)(1))
  • Key authorities: IRC § 6103(h)(1)

Full text (IRS public release)

ID:        CCA_2019032212165053
UILC:      6103.08-01

Number: 201916008
Release Date: 4/19/2019
From:
Sent: Friday, March 22, 2019 12:16:50 PM
To:
Cc:
Bcc:
Subject: RE: Advice

Looks fine to me under 6103(h)(1).

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