Let's talk 6103 Violations when it comes to filing of 'Notice of Lien' and subsequent Levy. Here is a pertinant part of § 6103:
(a) General rule
Returns and return information shall be confidential, and except as authorized by this title—
(1) no officer or employee of the United States,
shall disclose any return or return information obtained by him in any manner in connection with his service as such an officer or an employee or otherwise or under the provisions of this section.
Questions/Areas of Study:
1. Since the term “return information” definately includes what is sent on a NOL, does a SFR (when a tax return is NOT filed) meet the definition of a "return"?
(1) Return
The term “return” means any tax or information return, declaration of estimated tax, or claim for refund required by, or provided for or permitted under, the provisions of this title which is filed with the Secretary by, on behalf of, or with respect to any person, and any amendment or supplement thereto, including supporting schedules, attachments, or lists which are supplemental to, or part of, the return so filed.
2. If the answer to number 1 is 'no', would not the W-2's/1099's sent to the service meet the definition of taxpayer return information, and therefore be subject to non-disclosure?
TIGTA violations specifically mention 6103.
Here is the link for 6103. I scanned it a couple of times but could not find anything that would allow for furnishing taxpayer return info as it relates to NOL's. What have I missed?
http://www4.law.cornell.edu/uscode/h...3----000-.html
Comments please.
