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In ILM 201146017 (10/14/11), here,
the IRS concludes that it may summons a taxpayer's electronic data
files (or backup files) in order to obtain associated metadata. That is
the bottom-line conclusion, but the ILM applies the rule in several
The ILM defines metadata as and the need for it succinctly:
Generally, metadata is information that
describes how, when, and by whom a particular item or set of electronic
information was collected, created, accessed, modified, and formatted.
The questions above arise in the context of examinations of taxpayers
that keep their business records electronically with metadata
automatically created as an integral part of the records. In many
instances, the Service's examinations would be advanced by accessing
metadata that identifies the original date a transaction was entered in
the electronic records, the dates of any changes to the entries, and the
username of the person who made the entries. The value inherent in an
examiner's ability to obtain the date and source of recorded entries is
self-evident; the information tends to support or undermine the
credibility of the entries in the business records.
See also for types of metadata, the Wikipedia entry on Metadata, here. ...
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