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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. 20224
January 16, 2001
OFFICE OF
CHIEF COUNSEL
Number: 200107035
Release Date: 2/16/2001
CC:PA:APJP:1:AJKeyso
TL-N-4417-00
UIL
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