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Chief Counsel Advice 202118020 Released May 7, 2021 Advice

Mandatory restitution order makes Westbrooks inapplicable

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This page covers one taxpayer's ruling from 2021, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

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 brief Chief Counsel email addresses whether a criminal restitution case was subject to Westbrooks. The district judge's restitution order expressly stated that the defendant was subject to mandatory restitution under the Mandatory Victims Restitution Act. The advice therefore concludes that Westbrooks did not apply. The public release provides no additional facts or legal analysis.

Ruling snapshot

  • Question: Was the restitution case subject to Westbrooks?
  • Outcome: Advice given: no.
  • Key authorities: The court's mandatory restitution order under the MVRA; UILC 6201.01-06

Full text (IRS public release)

ID: CCA_2020103013451744
UILC: 6201.01-06

Number: 202118020
Release Date: 5/7/2021
From: ----------------------
Sent: Friday, October 30, 2020 1:45:17 PM
To: -----------------------
Cc: --------------------------------------
Bcc:
Subject: RE: RBA Status Question - ------

This case is not subject to Westbrooks. In the restitution order (ECF #-----), the district
judge writes “----------------is subject to an order of mandatory restitution under the
MVRA.”

Please call if you have any further questions about this matter.

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