e705ab40_osure_and_Telephone_Procedures__Disclosures_NOT_Permitted
[Stakeholder] Trustee [Disclosures Permitted] In a bankruptcy proceeding pertaining to tax administration, prepetition returns and return information pertaining to the debtor or bankruptcy estate may, upon written request, be disclosed to the trustee. Also, in cases where the trustees have fiduciary responsibility, hence a material interest, to prepare returns and pay taxes (tax administration purposes), they have authority for access to the same, irrespective of whether the return is pre or postpetition. (See IRC § 6103(e)(4), (5), and (7);IRC § 6103(h)(4); and IRM 11.3.2.4.12, Bankruptcies. ) Note: In involuntary bankruptcies, no disclosure may be made to the trustee until the order for relief has been entered or unless the court finds that such disclosure is necessary for purposes of determining whether an order for relief should be entered ( IRC § 6103(e)(5)(C)). [Disclosures NOT Permitted] 
Trustees are not allowed to receive information on any tax returns for periods after the petition date unless the debtor has given oral or written consent, except for claims filed in Chapter 13 cases under § 1305, or for tax obligations incurred postpetition, while the trustee is operating the debtor’s business. IRC § 6103(e) generally does not permit disclosures to the United States Trustee or the standing Chapter 13 trustee; however, such disclosures may be permitted in the context of a judicial proceeding if the bankruptcy case pertains to tax administration.
Internal Revenue Manual - 5.9.19 Insolvency Disclosure and Telephone Procedures
Disclosures NOT Permitted