Disclosure to Taxpayer's Designee

ID:
Office:
UILC:
CCA_2012052311110603
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6103.03-00
Number: 201235012
Release Date: 8/31/2012
From: ---
Sent: Wednesday, May 23, 2012 11:11:23 AM
To: ---
Cc: ---
Subject: RE: 6103 - JCT Issue
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Because the Service is unsure whether the audit will definitely result in a refund over $2 million, and therefore require JCT review, the submission of the closing agreement to JCT before the completion of the Exam potentially violates section 6103. If the taxpayer consents, pursuant to section 6103(c), then the disclosure will not violate section 6103. Recipients of return information pursuant to section 6103(c) are not subject to the disclosure restrictions contained in section 6103(a). See Rev. Rul. 2004-53.
I hope this addresses the taxpayer’s concern. Please contact me if you have any questions.
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