501
Access to and Disclosure of Tax Returns in a Non-Tax
Criminal Case
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Section 6103 of the Internal Revenue Code (26 U.S.C. § 6103) is
designed to protect the confidentiality of tax returns and return
information and
establishes criteria for the disclosure of such material by the Internal
Revenue
Service and its use and further disclosure by the beneficiaries of
disclosure.
See this Manual at 502 and 503. Since January 1, 1977, disclosure of
returns
and return information has been prohibited except as specifically provided
in 26
U.S.C. § 6103, as amended, or other sections of the Code. Disclosure
in
violation of these provisions subjects the offender to possible criminal
penalties.
Among the disclosures authorized by the Act are those in 26 U.S.C.
§ 6103(i) concerning access to returns and return information by
certain
Department of Justice personnel for use in the investigation and prosecution
of
federal criminal statutory violations and related civil forfeitures not
involving
tax administration. The access procedures and use restrictions in such a
case
are set forth in this Manual at 505 et seq.
[cited in USAM 9-13.900] | |