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DEPARTMENT OF THE TREASURY
I N T E R N AL R E V E N U E S E R V I C E
WASHINGTON, D.C. 20224March 12, 2001
OFFICE OF
CHIEF COUNSELNumber: 200123047
Release Date: 6/8/2001
Index Number: 61.1501
CAM10167698/CC:ITA:B7
MEMORANDUM
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