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Ezel / IRS Rulings / 202125011
Chief Counsel Advice 202125011 Released June 25, 2021 Advice

Restitution matched the plea agreement

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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

A plea agreement authorized restitution, and the court ordered the same amount stated in that agreement. The IRS advised that the case therefore did not fall under the Westbrooks rule for restitution imposed only as a supervised-release condition.

Ruling snapshot

  • Question: Did restitution equal to the plea-agreement amount fall under the Westbrooks limitation?
  • Outcome: Advice given: no, the plea agreement supported the order.
  • Key authorities: IRC § 6201(a)(4); Westbrooks restitution analysis

Full text (IRS public release)

ID: CCA_2020021910060444
UILC: 6201.01-06

Number: 202125011
Release Date: 6/25/2021
From:
Sent: Wednesday, February 19, 2020 10:06:04 AM
To:
Cc:
Bcc:
Subject: RE: Possible Westbrooks Case-------

This is not a Westbrooks case. There’s a plea agreement and restitution is ordered in
an amount equal to the amount shown in the plea agreement. Please call if you have
further questions.

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