Second, some definitions. “Return” means any tax return, or information return, filed with the Internal Revenue Service. “Return information” means any financial data or other information concerning a taxpayer, obtained by the I.R.S. from someone other than the taxpayer. “Taxpayer return information” is “return information” obtained from, or on behalf of, the taxpayer.
Section 6 1 03 (a) provides that all returns and return information shall be confidential, and government officers and employees are forbidden from disclosing any return or return information they have obtained in connection with their service as government officers.
Except....
It is, of course, these exceptions that concern us.
Under Section 6103(h) returns and return information, including tax-payer return information, are available to Treasury Department employees whose official duties require access for “tax administration purposes.” (A written request is not even necessary.)
What are “tax administration purposes?”
According to a past Justice Department Institute on Criminal Tax Trials, “tax administration”:. . . means the administration, management, conduct, direction, and supervision of the execution and application of the internal revenue laws or related statutes, and the development and formulation of federal tax policy relating to existing or proposed internal revenue laws, and related statutes. (Related statutes are those nontax statutes having an enforcement rather than a Lictual relationship to tax administration.more
