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Number of Chief Counsel Advice Emails

2026-03-24

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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 sent. The report for 2025 was released yesterday.

During 2025, a total of 1,413 emails were sent, with only 26 being released to the public. The IRS claimed attorney work product or attorney-client privilege on the vast majority of the emails.

The number of emails sent by the Office of Chief Counsel in 2025 was the lowest on record.

Below are charts showing the total emails sent and the number of emails released to the public for the years 2013 to 2025. No data could be found for 2019.

chart of CCA emails sent
Tags: Statistics