2025-03-28
Each year the IRS Office of Chief Counsel releases a report describing the number of emails containing legal advice that lawyers in the Office of Chief Counsel send to Office of Chief Counsel or IRS field personnel (“emailed Chief Counsel Advice” or “emailed CCA”). The report for 2024 was released yesterday.
During 2024, the total number of emailed CCA sent was 1,642. The vast majority of these emails are not released to the public. The IRS claimed attorney work product or attorney-client privilege on 1,528 of the emails. An additional 89 of the emails were excluded from public inspection for various reasons. Only 25 of the emailed CCA sent were released to the public.
Below are two charts showing data for the years 2013 to 2024. The first chart shows the total number of emailed CCA sent, and the second chart shows the number of emails released to the public. No data could be found for 2019.
