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Calianno of the Office of Associate Chief Counsel Corporate. For further information regarding this revenue ruling contact Ms. Rapaport at 202 622-7550 not a toll-free call or Mr. Calianno at 202 622-7930 not a toll-free call. Section 704 c. Contributed Property 26 CFR 1. 704 3 Contributed property. Can a Qualified Master Feeder-Structure aggregate built-in gains and losses from contributed securities for purposes of making section 704 c and reve...
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