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NOCLKDBTypewritten TextIRB No. 2016-16 April 18, 2016
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THIS DOCUMENT IS NOT TO BE RELIED UPON OR
OTHERWISE CITED AS PRECEDENT BY TAXPAYERS
Recommendation: Nonacquiescence.
Sue-Jean Kim Attorney (Income Tax & Accounting)
Reviewers:
Approved: WILLIAM J. WILKINS Chief Counsel Internal Revenue Service
By: SCOTT K. DINWIDDIE Acting Associate Chief Counsel (Income Tax & Accounting)
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