Jeffrey C. and Kelly O. Stone - Page 5

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          Revenue.  Petitioners point out that they were first notified by            
          a January 26, 1996, letter from James Moody, Revenue Agent,                 
          Income Tax Division, Montana Department of Revenue, that their              
          file had been referred for audit to the Department of Revenue in            
          conjunction with a joint project between the Department of                  
          Revenue and respondent.  Petitioners further contend that the               
          Department of Revenue did not make a written request to                     
          respondent to disclose petitioners' return information and that             
          this violates section 6103(d).1                                             


               1 Sec. 6103(a) and (d) provides as follows:                            
               SEC. 6103.  CONFIDENTIALITY AND DISCLOSURE OF RETURNS                  
               AND RETURN INFORMATION.                                                
                    (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,             
                         (2) no officer or employee of any State, any local           
               child support enforcement agency, or any local agency                  
               administering a program listed in subsection (1)(7)(D) who             
               has or had access to returns or return information under               
               this section, and                                                      
                         (3) no other person (or officer or employee                  
               thereof) who has or had access to returns or return                    
               information under subsection (e)(1)(D)(iii), paragraph (2)             
               or (4)(B) of subsection (m), or subsection (n), 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.  For purposes of this subsection, the term "officer           
               or employee" includes a former officer or employee.                    
               *       *       *       *       *       *       *                      
                    (d) Disclosure to State Tax Officials and State                   
                                                             (continued...)           




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