In 2017, Jun Yi was the sole owner and operator of Advantage…
In 2017, Jun Yi was the sole owner and operator of AdvantageTech, Inc., an S Corporation located in Dallas, TX. A few years later AdvantageTech was insolvent and entered into voluntary bankruptcy proceedings in June of 2023. At that time, Yi relinquished his interest in AdvantageTech and turned over all of his books and records to the United States Trustee overseeing the bankruptcy case. Simultaneously, the IRS began examining AdvantageTech related to its tax return filings for taxable years 2019-2022. During the exam, Revenue Agent Augustus Martin received a request from Yi for AdvantageTech’s tax returns for taxable years 2019 and 2020. Revenue Agent Martin agreed and transmitted the tax returns via secured mail to Yi. Did Revenue Agent Martin violate IRC § 6103 when it turned over the returns to Yi?