Confidentiality and Disclosure of Returns and Return Information

ID:
UILC:
CCA_2024120615483000
6103.00-00
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 202504018
Release Date: 1/24/2025
From: ---
Sent: Friday, December 6, 2024 3:48:30 PM
To: ---
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Subject: RE: 6103 information in resume
The flush language under section 6103(b)(2) (“. . . but such term does not include data in a form which cannot be associated with, or otherwise identify, directly or indirectly, a particular taxpayer”) applies to statistical studies and similar compilations of amalgamated data. The purpose of this language – commonly referred to as the “Haskell Amendment” – is to ensure that the Service can publicly disclose statistical studies and tax models for research purposes. The Haskell Amendment does not, however, allow the disclosure of otherwise confidential return information simply because the taxpayer(s) cannot be identified. The statute is more than an identity test.
The Supreme Court has addressed this issue and concluded that return information from which taxpayer identifiers have been deleted is still subject to the confidentiality requirements of section 6103. See Church of Scientology of Cal. v. IRS, 484 U.S. 9, 14-18 (1987).
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