Contractors or Other Persons

ID:
UILC:
CCA_2021070715020143
6103.01-00, 6103.01-03
Number: 202150015
Release Date: 12/17/2021
From: ---
Sent: Wednesday, July 7, 2021 3:02:01 PM
To: ---
Cc: ---
Bcc:
Subject: RE: ---
Hi ---,
I hope you are well! I wanted to follow up with an email after our previous phone call.
Thank you for reaching out for assistance with this question about whether ---
---. To briefly summarize, the ---
---. As stated during our call, the ---so long as there is not a separate confidentiality agreement that he signed.
As you know, I.R.C. § 6103(a) prohibits former employees from disclosing confidential return information obtained in the course of their employment. Because the ------after this employment ceased, the information was not obtained in connection with his employment. If the ------was made a contractor pursuant to section 6103(n), then the --- would be prohibited from disclosing any return information received during the course of the agreement. See Treas. Reg. §§ 301.103(n)-1(c); 301.6103(n)-2(c). Unless there is a separate binding confidentiality clause, ------. We are unaware of any other statute that would bar ---.
Please let me know if you have any further questions.
Best,
---
---
Legal Admin. Specialist, CC:PA:07
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