511. Restrictions on Disclosures, 26 U.S.C. 6103(i)(6)
This paragraph prohibits IRS from making all but one disclosure described in this Manual at 506 through 510 if a determination is made that disclosure "would identify a confidential informant or seriously impair a civil or criminal tax investigation." In the case of an application for a court order under either 26 U.S.C. § 6103(i)(1) or (i)(5), IRS must certify the making of this determination to the court.
These restrictions are administered solely by IRS; they do not require any action by applicants or requesters.
The exception to their application is an IRS-initiated disclosure under 26 U.S.C. § 6103(i)(3)(B) to prevent death, physical injury, or flight to avoid federal prosecution.
[cited in Criminal Resource Manual 506; Criminal Resource Manual 507; Criminal Resource Manual 508; Criminal Resource Manual 510]