Federal Tax Day - Current, L.9, Chief Counsel Email Guidance Released (CCAE 202634012-202634014), (Aug 24, 2026)

The IRS has released email advice prepared in less than two hours by attorneys in the IRS's Office of Chief Counsel. In Tax Analysts, CA-DC, 2007-2 USTC ¶50,553, the Court of Appeals for the D.C. Circuit ruled that the IRS could not rely on its so-called "two-hour" rule to avoid disclosure of email sent to IRS field personnel. The documents constituted Chief Counsel Advice, which the IRS is required to publicly disclose under Code Sec. 6110. The items listed below were released as a result.

Chief Counsel Advice Memorandum 202634012

Chief Counsel Advice Memorandum 202634013

Chief Counsel Advice Memorandum 202634014