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Office of Chief Counsel Internal Revenue ServiceMemorandum Release Number: 20070801F Release Date: 2/23/07 CC:SB:7:SJ:2:CS Hong POSTF13891106 UIL: 6324A.0000date: December 20, 2006, to: Device Huber Advisor,

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Begin by entering the digits "20070801" as the release date. This refers to the release date of the document, which may be important for tracking purposes.

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