[Code of Federal Regulations]
[Title 26, Volume 18]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR301.6103(a)-2]

[Page 38-39]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 301_PROCEDURE AND ADMINISTRATION--Table of Contents
 
                         Information and Returns
 
Sec. 301.6103(a)-2  Disclosures after December 31, 1976, by attorneys of 

the Department of Justice and officers and employees of the Office of the 
Chief Counsel for the Internal Revenue Service of returns and return 
          information (including taxpayer return information) disclosed 
          to such attorneys, officers, and employees by the Service 
          before January 1, 1977, for a purpose involving tax 
          administration.

    (a) General rule. Except as provided by paragraph (b) of this 
section and subject to the requirements of this paragraph, a return or 
return information (including taxpayer return information), as defined 
in section 6103(b) (1), (2), and (3), of the Internal Revenue Code 
disclosed by the Internal Revenue Service before January 1, 1977, to an 
attorney of the Department of Justice (including a United States 
attorney) or to an officer or employee of the Office of the Chief 
Counsel for the Service for a purpose involving tax administration (as 
defined in section 6103(b)(4)) pursuant to the authority of section 6103 
(or any order of the President under section 6103 or rules and 
regulations thereunder prescribed by the Secretary or his delegate and 
approved by the President) before amendment of such section by section 
1202 of the Tax Reform Act of 1976 (Pub. L. 94-455, 90 Stat. 1667) may 
be disclosed by, or on behalf of, such attorney, officer, or employee 
after December 31, 1976, for any purpose authorized by such section (or 
such order or rules and regulations) before such amendment.
    (b) Exception. Notwithstanding the provisions of paragraph (a) of 
this section, a return or return information (including taxpayer return 
information) disclosed before January 1, 1977, by the Service to an 
attorney of the Department of Justice or to an officer or employee of 
the Office of the Chief Counsel for the Service for a purpose related to 
tax administration as described in paragraph (a) may, after December 31, 
1976, be disclosed by, or on behalf of, such attorney, officer, or 
employee in an administrative or judicial proceeding only if such 
proceeding is one described in section 6103(h)(4) of

[[Page 39]]

the Code and if the requirements of section 6103 (h)(4) have first been 
met.

(Secs. 6103 and 7805 of the Internal Revenue Code of 1954 (90 Stat. 
1667, 68A Stat. 917; 26 U.S.C. 6103 and 7805))

[T.D. 7723, 45 FR 65567, Oct. 3, 1980]