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Chief Counsel Advice 202417016 Released April 26, 2024 Advice

Public Tax Court docket access differs from access through IRS systems

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This page covers one taxpayer's ruling from 2024, 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

Chief Counsel identified a disclosure distinction between viewing filed documents on the Tax Court's public docket and viewing them through an IRS system. Public docket documents can be accessed through DAWSON or in person at the Tax Court. The email also suggests that filed Tax Court documents may already be viewable by all users of the IRS's eTCS system. The brief advice does not provide further facts or a detailed legal analysis.

Ruling snapshot

  • Question: Is viewing a Tax Court document on the public docket different from viewing it through an IRS system?
  • Outcome: advice given
  • Key authorities: UILC 6103.08-01

Full text (IRS public release)

 ID:        CCA_2024032913462248                            [Third Party Communication:

 UILC:      6103.08-01                                      Date of Communication: Month DD, YYYY]

Number: 202417016
Release Date: 4/26/2024
From: --------------------
Sent: Wednesday, January 10, 2024 9:32:22 AM
To: ----------------------------------------------------
Cc: -----------------------------------------------------
Bcc:
Subject: RE: Notes RE 0109 Sprint Demo


Ah. That makes more sense. There is a distinction between viewing documents from the public docket
(at the Tax Court—either through DAWSON or in person) and through an IRS system. But, I think filed
Tax Court documents are already viewable by all eTCS users?

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