NYC Tax Advocates

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Specializing in IRS and NYS Tax Representation. Workers Compensation Audits, Payroll, Sales and Income Tax representation for Businesses, Individuals, Restaurants and Construction Companies. Civil and Criminal Workers Comp Audit representation includes: NYSIF Examinations, Premium Disputes, Employee Misclassification, Underreporting, Unreported Income, and Failure to Keep Accurate Payroll Records.

Friday, December 6, 2019

We Solve Tax Problems So You Can Get On With Your Life





Working with Energy and Determination
Free Consultation Federal Tax Practitioner and Attorney. We provide our Clients with successful Tax Representation, Advocacy and Consulting Services. Practicing before the Internal Revenue Service, New York State Department of Taxation and Finance, and all major Tax Tribunals. Free legally privileged consultations are available in our conveniently located New York City office. 

Proven Results We solve Tax Problems so you can get on with your life. Specializing in unpaid Income, Sales and Payroll taxes. We negotiate excellent Payment Plans, Offers in Compromise, Audits and all other tax matters. 

Expedited Service Do you have unfiled Tax Returns? We can have up to 10 years of missing Tax Returns prepared and filed in just 48 hours, guaranteed. Emergency appointments are available upon request. 

E-Books and Self Help

   

Solve Your IRS Tax Problem in just 7 Minutes.  For only $3.99 we can help you solve your IRS tax problem in the shortest amount of time and at the least possible cost. The information provided in this E-Book is easy to use and straight to the point. By following the easy to understand instructions, you will be able to prepare and file all of your Missing Tax Returns; establish an IRS Payment Plan; file an Offer in Compromise, request a Penalty Abatement or apply for Currently Not Collectable status. Click here to buy the Book

How to get a Mortgage (when you owe the IRS).  If you have been turned down for a mortgage because you owe money to the IRS, you’re about to discover an amazing “loophole” that will allow you to borrow the money you need to buy the house of your dreams (without having to fully payoff your tax debt). For only $3.99 this E-Book can help you get an FHA mortgage in the shortest amount of time and at the least possible cost. Click here to buy the Book

Need a little Help? For just $59.99 I will contact the IRS and (without raising any red flags) find out if you’re missing any tax returns and how much (if anything) you owe. If any of your tax returns are missing, I will get your wage and income transcripts directly from the IRS, and with this information, all of your missing tax returns can be prepared, either by yourself, or by the Tax Return Preparer of your choice. 


Knowledge is Power For an additional $49.99 I will review your information (obtained from the IRS) and tell you (in writing) what your options are. You can use this information to solve your own tax problem (DIY) or alternatively, you can hire the Tax Professional of your choice. 

Fraudster Pleads Guilty to False Tax Return Scheme


More Than 200 Stolen Identities in His Backpack   A Las Vegas resident pleaded guilty today to aggravated identity theft, wire fraud, theft of government property, and access device fraud, relating to a stolen identity tax fraud, announced Principal Deputy Assistant Attorney General Richard E. Zuckerman of the Justice Department’s Tax Division and U.S. Attorney Nicholas A. Trutanich for the District of Nevada. 

SELIG & ASSOCIATES Free Consultation Federal Tax Practitioner and Attorney. We provide our Clients with successful Tax Representation, Advocacy and Consulting Services. Practicing before the Internal Revenue Service, New York State Department of Taxation and Finance, and all major Tax Tribunals. Free legally privileged consultations are available in our conveniently located New York City office. 


According to court documents and statements made in court, Josiah Ntekume was involved in a scheme to file false tax returns using stolen identities in order to obtain tax refunds. Coconspirators provided Ntekume with names, addresses, dates of birth, and social security numbers, and Ntekume used these stolen identities to establish prepaid debit card accounts. The coconspirators then caused fraudulently obtained federal tax refunds to be deposited into those accounts.
SELIG & ASSOCIATES  Proven Results We solve Tax Problems so you can get on with your life. Specializing in unpaid Income, Sales and Payroll taxes. We negotiate excellent Payment Plans, Offers in Compromise, Audits and all other tax matters. 

When Ntekume was arrested on March 13, 2012, he had in his backpack approximately 250 prepaid debit cards in others people’s names on which more than more than $200,000 in fraudulent tax refunds had been loaded. The backpack also contained several pages of paper listing stolen identities for nearly 200 individuals that were used either to file false tax returns or to establish additional prepaid debit cards. 
Sentencing is scheduled for March 4, 2020. At sentencing, Ntekume faces a statutory maximum sentence of up to 20 years in prison on the wire fraud count, as well as up to ten years in prison on each count of theft of government property and fraud in connection with access devices. He also faces a mandatory minimum of two years for aggravated identity theft. In addition to a prison sentence, Ntekume faces a period of supervised release, restitution, and monetary penalties.
Principal Deputy Assistant Attorney General Zuckerman and U.S. Attorney Trutanich thanked special agents of IRS Criminal Investigation, who conducted the investigation, and Tax Division Trial Attorneys Thomas W. Flynn, Stephen K. Moulton, and Arthur Ewenczyk who are prosecuting the case.

Selig & Associates
Working with Energy and Determination
Expedited Service Do you have unfiled Tax Returns? We can have up to 10 years of missing Tax Returns prepared and filed in just 48 hours, guaranteed. Emergency appointments are available upon request. 


Free Consultation Federal Tax Practitioner and Attorney. We provide our Clients with successful Tax Representation, Advocacy and Consulting Services. Practicing before the Internal Revenue Service, New York State Department of Taxation and Finance, and all major Tax Tribunals. Free legally privileged consultations are available in our conveniently located New York City office. 

Proven Results We solve Tax Problems so you can get on with your life. Specializing in unpaid Income, Sales and Payroll taxes. We negotiate excellent Payment Plans, Offers in Compromise, Audits and all other tax matters. 

Expedited Service Do you have unfiled Tax Returns? We can have up to 10 years of missing Tax Returns prepared and filed in just 48 hours, guaranteed. Emergency appointments are available upon request. 


Case No. 2:17-CR-63 JCM (NJK) 
10-02-2019 
UNITED STATES OF AMERICA, Plaintiff(s), v. JOSIAH N. NTEKUME, Defendant(s).

ORDER 
Presently before the court is defendant Josiah Ntekume's ("defendant") motion to dismiss counts 2 and 4 of the indictment as time-barred. (ECF No. 49). The United States of America ("the government") filed a response (ECF No. 50), to which defendant replied (ECF No. 51). 

I. Background

The government alleges that defendant "fraudulently obtained[ed] and falsely possess[ed] social security numbers and other personal information" and used that information "to obtain money by filing false and fraudulent state and federal income tax returns claiming refunds." (ECF No. 1 at 1). At the time of his arrest, defendant had approximately 250 pre-paid debit cards and roughly 50 sheets of paper containing the personal identification information of 195 people. Id. at 2. The debit cards had been loaded with over $200,000 from federal tax refunds, much of which had been spent. Id
In a nine-count indictment, defendant is charged with one count of fraud in connection with access devices in violation of 18 U.S.C. § 1029(a)(3), six counts of theft of public money in violation of 18 U.S.C. § 641, and one count of wire fraud in violation of 18 U.S.C. § 1343Id. The indictment was returned on February 22, 2017. (ECF No. 1). 
Defendant moves to dismiss counts two and four, both of which are theft-of-public-money charges, as time-barred. (ECF No. 49). Because the indictment alleges that the federal tax refund money was deposited onto pre-paid debit cards on February 1, 2012, for count two, and February 17, 2012, for count four, defendant argues that the claims became time-barred on February 1 and February 17, 2017, respectively. Id

II. Legal Standard

In order to protect defendants from unfairly facing criminal liability for conduct in the distant past, "a statute of limitations . . . limit[s] exposure to criminal prosecution to a certain fixed period of time following the occurrence of those acts . . ." Toussie vUnited States397 U.S. 112, 114-15 (1970). Congress sets the limitation period by statute, which "should not be extended 'except as otherwise expressly provided by law.'" Id. at 115 (quoting 18 U.S.C. § 3282). 
"Statutes of limitations normally begin to run when the crime is complete." Pendergast vUnited States317 U.S. 412, 418 (1943). "A crime is complete when each element of the crime has occurred." United States vSmith740 F.2d 734, 736 (9th Cir. 1984) (citing United States vDrebin557 F.2d 1316, 1332 (9th Cir. 1977)). Determining when a crime is completed depends on whether the offense is "continuing" or not. The Ninth Circuit has held that: 
[A] criminal offense is typically completed as soon as each element of the crime has occurred. For example, a larceny is completed as soon as there has been an actual taking of the property of another without consent, with the intent permanently to deprive the owner of its use. The offense does not "continue" over time. The crime is complete when the act is complete. A "continuing offense," in contrast, is an unlawful course of conduct that does perdure.... The classic example of a continuing offense is conspiracy.
United States vMorales11 F.3d 915, 921 (9th Cir. 1993) (quoting United States vMcGoff831 F.2d 1071, 1078 (D.C.Cir.1987)). "Thus, the Court in Toussiedistinguished between offenses that involve a 'continuing process' and those that occur as 'instantaneous events.'" Id. (citing Toussie397 U.S. at 122). 
Finally, "criminal limitations statutes are 'to be liberally interpreted in favor of repose.'" Toussie397 U.S. at 115 (quoting United States vHabig390 U.S. 222, 227(1968) (quoting United States vScharton285 U.S. 518, 522 (1932))). 

Discussion

The parties agree on two things. First, 18 U.S.C. § 641 charges must be brought within five years. See 18 U.S.C. § 3282. Second, the five-year limitation period begins to run from the time the offense is completed. Toussie vUnited States397 U.S. 112, 115 (1970). The parties do not agree on when the offense conduct underlying counts two and four was completed. If counts two and four are continuing offenses, they are timely. If they are not continuing offenses, they are time-barred. 
Counts two and four allege violations of 18 U.S.C. § 641, which "criminalizes two distinct acts. . . . In short, paragraph one covers stealing from the United States and paragraph two covers knowingly receiving stolen United States property." United States vFairley880 F.3d 198, 204 (5th Cir. 2018) (citing Milanovich vUnited States365 U.S. 551, 554 (1961)). 
Defendant is charged with violating paragraph two of § 641. (ECF No. 1). The Ninth Circuit has not expressly decided whether violations of § 641 paragraph two are continuing offenses. Seee.g., United States vNeusom, 159 Fed. Appx. 796, 799 (9th Cir 2005) (explaining that there is no controlling Supreme Court or Ninth Circuit precedent and the other circuits are split on this issue)). 
A court should not conclude that an offense is a continuing offense "unless the explicit language of the substantive criminal statute compels such a conclusion, or the nature of the crime involved is such that Congress must assuredly have intended that it be treated as a continuing one." Toussie397 U.S. at 115. Statutory language explicitly compels a continuing-offense conclusion when it "clearly contemplates a prolonged course of conduct." Id. at 120. Therefore, the court must first consider the explicit language of the statute: 
Whoever embezzles, steals, purloins, or knowingly converts to his use or the use of another, or without authority, sells, conveys or disposes of any record, voucher, money, or thing of value of the United States or of any department or agency thereof, or any property made or being made under contract for the United States or any department or agency thereof; or
Whoever receives, conceals, or retains the same with intent to convert it to his use or gain, knowing it to have been embezzled, stolen, purloined or converted—

Shall be fined under this title or imprisoned not more than ten years, or both; but if the value of such property in the aggregate, combining amounts from all the counts for which the defendant is convicted in a single case, does not exceed the sum of $1,000, he shall be fined under this title or imprisoned not more than one year, or both.

The word "value" means face, par, or market value, or cost price, either wholesale or retail, whichever is greater.
18 U.S.C. § 641
Here, defendant is accused of "conceal[ing] and retain[ing] money belonging to the United States Treasury in the form of federal tax refunds, with intent to convert the same to his use and gain, knowing the money to have been stolen, purloined, and converted." (ECF No. 1 at 4). However, the statute requires that defendant receive, conceal, or retain the federal tax refunds at issue "with the intent to convert it to his use or gain." 18 U.S.C. § 641. Thus, under the plain language of the statute, "concealing" or "retaining" the money is an ongoing offense with a purpose: conversion to the defendant's use and gain. Id. Therefore, the continuing offense of concealing or retaining necessarily ends with the conversion of public funds to the defendant's use or gain. 
Conversion under § 641 paragraph one is not a continuing offense. Seee.g., United States vBeard713 F.Supp. 285, 291 (S.D. Ind. 1989); United States vReynolds, No. 1:16-CV-0081-LJO-SKO, 2018 WL 1071303 (E.D. Cal. Feb. 23, 2018); United States vCrary, No. CR 13-35-M-DLC, 2013 WL 6054607 (D. Mont. Nov. 15, 2013); United States vPease, No. CR-07-757-PHX-DGC, 2008 WL 808683 (D. Ariz. Mar. 24, 2008). Thus, once the elements of conversion are met, the statute of limitations begins running. United States vLopez484 F.3d 1186, 1192 (9th Cir. 2007) ("A crime is complete when each element of the crime has occurred."). Indeed, the parties agree that the first paragraph consists of a series of discrete criminal acts—that is to say, the statute of limitations begins to run the moment the defendant  embezzles, steals, purloins, converts, sells, conveys, or disposes of anything of value belonging to the United States. 18 U.S.C. § 641; (see also ECF Nos. 49 at 6 (collecting cases); 50). 
Defendant converted the tax refunds when—as the government alleges in the indictment—"[t]his money was deposited onto pre-paid debit cards registered to the individuals . . . on or about the '[d]ate of [d]eposit." (ECF No. 1 at 4). Because defendant converted the refund to his use, defendant no longer concealed or retained the federal tax refund in count two as of the date of deposit: February 1, 2012. Because defendant converted the refund to his use, defendant no longer concealed or retained the federal tax return in count four as of the date of deposit: February 17, 2012. 
Thus, the limitations period began under paragraph one when the defendant converted his ill-gotten gains to his use on February 1 and February 17, 2012. 
As a result, counts two and four are time-barred. 

III. Conclusion

Accordingly, 
IT IS HEREBY ORDERED, ADJUDGED, and DECREED that defendant's motion to dismiss counts 2 and 4 of the indictment as time-barred (ECF No. 49) be, and the same hereby is, GRANTED. 
DATED October 2, 2019. 
/s/ James C. Mahan 
UNITED STATES DISTRICT JUDGE


SELIG & ASSOCIATES Free Consultation Federal Tax Practitioner and Attorney. We provide our Clients with successful Tax Representation, Advocacy and Consulting Services. Practicing before the Internal Revenue Service, New York State Department of Taxation and Finance, and all major Tax Tribunals. Free legally privileged consultations are available in our conveniently located New York City office. 

Saturday, November 30, 2019

DIY IRS Tax Help starting at $3.99


E-Books and Self Help
   

Solve Your IRS Tax Problem in 7 Minutes  For only $3.99 we can help you solve your IRS tax problem in the shortest amount of time and at the least possible cost. The information provided in this E-Book is easy to use and straight to the point. By following the easy to understand instructions, you will be able to prepare and file all of your Missing Tax Returns; establish an IRS Payment Plan; file an Offer in Compromise, request a Penalty Abatement or apply for Currently Not Collectable status. Click here to buy the Book

How to get a Mortgage when you owe the IRS  If you have been turned down for a mortgage because you owe money to the IRS, you’re about to discover an amazing “loophole” that will allow you to borrow the money you need to buy the house of your dreams (without having to fully payoff your tax debt). For only $3.99 this E-Book can help you get an FHA mortgage in the shortest amount of time and at the least possible cost. Click here to buy the Book

Need a little Help? For only $50 I will contact the IRS and (without raising any red flags) find out if you’re missing any tax returns and how much (if anything) you owe. If any of your tax returns are missing, I will get your wage and income transcripts directly from the IRS, and with this information, all of your missing tax returns can be prepared, either by yourself, or by the Tax Return Preparer of your choice. 


Knowledge is Power For an additional $50 I will review your information (obtained from the IRS) and tell you (in writing) what your options are. You can use this information to solve your own tax problem (DIY) or alternatively, you can hire the Tax Professional of your choice. 

Thursday, November 28, 2019

Topic No. 205 Innocent Spouse Relief



Take Advantage of Selig's Intelligence, 
Integrity and Ingenuity    
Free Consultation Federal Tax Practitioner and Attorney. We provide successful Tax Representation before the Internal Revenue Service and New York State Department of Taxation and Finance. Schedule a Free Legally Privileged consultation today. Meet personally in our conveniently located New York City office. 

Proven Results We solve Tax Problems so you can get on with your life. Specializing in unpaid Income, Sales and Payroll taxes. We negotiate excellent Payment Plans, Offers in Compromise, Audits and all other tax matters. 

Expedited Service Do you have un-filed Tax Returns? We can prepare and file all of your missing tax returns in just 48 hours, guaranteed. Same day and emergency appointments are available Monday through Friday. 

Many married taxpayers choose to file a joint tax return because of certain benefits this filing status allows them. When filing jointly, both taxpayers are jointly and severally liable for the tax and any additions to tax, interest, or penalties that arise from the joint return even if they later divorce. Joint and several liability means that each taxpayer is legally responsible for the entire liability. Thus, both spouses on a married filing jointly return are generally held responsible for all the tax due even if one spouse earned all the income or claimed improper deductions or credits. This is also true even if a divorce decree states that a former spouse will be responsible for any amounts due on previously filed joint returns. In some cases, however, a spouse can get relief from being jointly and severally liable.

Types of Relief

There are three types of relief from the joint and several liability of a joint return:
  1. Innocent Spouse Relief provides you relief from additional tax you owe if your spouse or former spouse failed to report income, reported income improperly or claimed improper deductions or credits.
  2. Separation of Liability Relief provides for the separate allocation of additional tax owed between you and your former spouse or your current spouse you're legally separated from or not living with, when an item wasn't reported properly on a joint return. You're then responsible for the amount of tax allocated to you.
  3. Equitable Relief may apply when you don't qualify for innocent spouse relief or separation of liability relief for something not reported properly on a joint return and generally attributable to your spouse. You may also qualify for equitable relief if the amount of tax reported is correct on your joint return but the tax wasn't paid with the return.

Note: You must request innocent spouse relief or separation of liability relief no later than 2 years after the date the IRS first attempted to collect the tax from you. For equitable relief, you must request relief during the period of time the IRS can collect the tax from you. If you're looking for a refund of tax you paid, then you must request it within the statutory period for seeking a refund, which is generally three years after the date the return is filed or two years following the payment of the tax, whichever is later. See Publication 971, Innocent Spouse Relief for additional restrictions on refunds available under innocent spouse relief, equitable relief, and relief based on community property laws. Refunds aren't available under separation of liability relief.

Innocent Spouse Relief

You must meet all of the following conditions to qualify for innocent spouse relief:
  • You filed a joint return that has an understatement of tax that's solely attributable to your spouse's erroneous item. An erroneous item includes income received by your spouse but omitted from the joint return. Deductions, credits, and property basis are also erroneous items if they're incorrectly reported on the joint return
  • You establish that at the time you signed the joint return you didn't know, and had no reason to know, that there was an understatement of tax and
  • Taking into account all the facts and circumstances, it would be unfair to hold you liable for the understatement of tax

Separation of Liability Relief

To qualify for separation of liability relief, you must have filed a joint return and must meet one of the following requirements at the time you request relief:
  • You're divorced or legally separated from the spouse with whom you filed the joint return
  • You're widowed, or
  • You haven't been a member of the same household as the spouse with whom you filed the joint return at any time during the 12-month period ending on the date you request relief

If you had actual knowledge of the item that gave rise to the deficiency at the time you signed the joint return, you don't qualify for separation of liability relief.

Equitable Relief

If you don't qualify for innocent spouse relief or separation of liability relief, you may still qualify for equitable relief. To qualify for equitable relief, you must establish that under all the facts and circumstances, it would be unfair to hold you liable for the deficiency or underpayment of tax. In addition, you must meet the other requirements listed in Publication 971, Innocent Spouse Relief. See Revenue Procedure 2013-34 (PDF) for information about how the IRS will take into account abuse and financial control by the nonrequesting spouse in determining whether equitable relief is warranted.

Form to File

To seek innocent spouse relief, separation of liability relief, or equitable relief, you should submit to the IRS a completed Form 8857, Request for Innocent Spouse Relief (PDF) or a written statement containing the same information required on Form 8857, which you sign under penalties of perjury. You may also refer to Publication 971, Innocent Spouse Relief for more information. If you request relief from the joint and several liability of a joint return, the IRS is required to notify the spouse you filed jointly with of your request and allow him or her to provide information for consideration regarding your claim.

Community Property States

If you lived in a community property state and didn't file as married filing jointly, you might qualify for relief from the operation of state community property law. Community property states are Arizona, California, Idaho, Louisiana, Nevada, New Mexico, Texas, Washington, and Wisconsin. Refer to Publication 971 for more details.

Injured Spouse vs. Innocent Spouse

An injured spouse claim is for allocation of a refund of a joint refund while an innocent spouse claim is for relief or allocation of a joint and several liability reflected on a joint return. You're an injured spouse if all or part of your share of a refund from a joint return was or will be applied against the separate past-due federal tax, state tax, child or spousal support, or federal non-tax debt (such as a student loan) owed by your spouse. If you're an injured spouse, you may be entitled to recoup your share of the refund. For more information, see Form 8379, Injured Spouse Allocation (PDF) or refer to Topic No. 203.

Wednesday, November 27, 2019

IRC § 601.201 Rulings and Determinations Letters



Take Advantage of Selig's Intelligence, 
Integrity and Ingenuity    
Free Consultation Federal Tax Practitioner and Attorney. We provide successful Tax Representation before the Internal Revenue Service and New York State Department of Taxation and Finance. Schedule a Free Legally Privileged consultation today. Meet personally in our conveniently located New York City office. 

Proven Results We solve Tax Problems so you can get on with your life. Specializing in unpaid Income, Sales and Payroll taxes. We negotiate excellent Payment Plans, Offers in Compromise, Audits and all other tax matters. 

Expedited Service Do you have un-filed Tax Returns? We can prepare and file all of your missing tax returns in just 48 hours, guaranteed. Same day and emergency appointments are available Monday through Friday. 


§ 601.201  Rulings and  determinations letters.
(a) General practice and definitions.
(1) It is the practice of the Internal Revenue Service to answer inquiries of individuals and organizations, whenever appropriate in the interest of sound tax administration, as to their status for tax purposes and as to the tax effects of their acts or transactions. One of the functions of the National Office of the Internal Revenue Service is to issue rulings in such matters. If a taxpayer's request for a  rulingconcerns an action that may have an impact on the environment, compliance by the Service with the requirements of the National Environmental Policy Act of 1969 (Pub. L. 91-190) may result in delaying issuing the  ruling. Accordingly, taxpayers requesting  rulings should take this factor into  account. District directors apply the statutes, regulations, Revenue  Rulings, and other precedents published in the Internal Revenue Bulletin in the  determination of tax liability, the collection of taxes, and the  issuance of  determination letters in answer to taxpayers' inquiries or requests. For purposes of this section any reference to district director or district office also includes, where appropriate, the Office of the Director, Office of International Operations.
(2) A ruling is a written statement issued to a taxpayer or his authorized representative by the National Office which interprets and applies the tax laws to a specific set of facts.  Rulings are issued only by the National Office. The  issuance of  rulings is under the general supervision of the Assistant Commissioner (Technical) and has been largely redelegated to the Director, Corporation Tax Division and Director, Individual Tax Division.
(3) A determination letter is a written statement issued by a district director in response to a written inquiry by an individual or an organization that applies to the particular facts involved, the principles and precedents previously announced by the National Office. A determination letter is issued only where a  determination can be made on the basis of clearly established rules as set forth in the statute, Treasury decision, or regulation, or by a  ruling, opinion, or court decision published in the Internal Revenue Bulletin. Where such a determination cannot be made, such as where the question presented involves a novel issue or the matter is excluded from the jurisdiction of a district director by the provisions of paragraph (c) of this section, a  determination letter will not be issued. However, with respect to determination letters in the pension trust area, see paragraph (o) of this section. 
(4) An opinion letter is a written statement issued by the National Office as to the acceptability of the form of a master or prototype plan and any related trust or  custodial account under sections 401 and 501(a) of the Internal Revenue Code of 1954.
(5) An information letter is a statement issued either by the National Office or by a district director which does no more than call attention to a well-established interpretation or principle of tax law, without applying it to a specific set of facts. An information letter may be issued when the nature of the request from the individual or the organization suggests that it is seeking general information, or where the request does not meet all the requirements of paragraph (e) of this section, and it is believed that such general information will assist the individual or organization.
(6) A Revenue Ruling is an official interpretation by the Service which has been published in the Internal Revenue Bulletin. Revenue Rulingsare issued only by the National Office and are published for the information and guidance of taxpayers, Internal Revenue Service officials, and others concerned.
(7) A closing agreement, as the term is used herein, is an agreement between the Commissioner of Internal Revenue or his delegate and a taxpayer with respect to a specific issue or issues entered into pursuant to the authority contained in section 7121 of the Internal Revenue Code. Such a  closing agreement is based on a  ruling which has been signed by the Commissioner or his delegate and in which it is indicated that a  closing agreement will be entered into on the basis of the holding of the  ruling letter. Closing agreements are final and conclusive except upon a showing of  fraud, malfeasance, or misrepresentation of material fact. They may be entered into where it is advantageous to have the matter permanently and conclusively closed, or where a taxpayer can show good and sufficient reasons for an agreement and the Government will sustain no disadvantage by its consummation. In appropriate cases, taxpayers may be required to enter into a  closing agreement as a condition to the  issuance of a  ruling. Where in a single case, closing agreements are requested on behalf of each of a number of taxpayers, such agreements are not entered into if the number of such taxpayers exceed 25. However, in a case where the issue and holding are identical as to all of the taxpayers and the number of taxpayers is in excess of 25, a Mass  Closing Agreement will be entered into with the taxpayer who is authorized by the others to represent the entire group. See, for example, Rev. Proc. 78-15, 1978-2 C.B. 488, and Rev. Proc. 78-16, 1978-2 C.B. 489.
(b) Rulings issued by the National Office.
(1) In income and gift tax matters and matters involving taxes imposed under Chapter 42 of the Code, the National Office issues rulings on prospective transactions and on completed transactions before the return is filed. However,  rulings will not ordinarily be issued if the identical issue is present in a return of the taxpayer for a prior year which is under active examination or audit by a district office, or is being considered by a  branch office of the Appellate Division. The National Office issues  rulings involving the exempt status of organizations under section 501 or 521 of the Code, only to the extent provided in paragraph (n) of this section, Revenue  Procedure 72-5, Internal Revenue Bulletin No. 1972-1, 19, and Revenue  Procedure 68-13, C.B. 1968-1, 764. The National Office issues  rulings as to the foundation status of certain organizations under sections 509(a) and 4942(j) (3) of the Code only to the extent provided in paragraph (r) of this section. The National Office issues  rulings involving qualification of plans under section 401 of the Code only to the extent provided in paragraph (o) of this section. The National Office issues  opinion letters as to the acceptability of the form of master or prototype plans and any related trusts or custodial accounts under sections 401 and 501(a) of the Code only to the extent provided in paragraphs (p) and (q) of this section. The National Office will not issue  rulings with respect to the replacement of involuntarily converted property, even though replacement has not been made, if the taxpayer has filed a return for the taxable year in which the property was converted. However, see paragraph (c)(6) of this section as to the authority of district directors to issue  determination letters in this connection.
(2) In estate tax matters, the National Office issues rulings with respect to transactions affecting the estate tax of a decedent before the estate tax return is filed. It will not rule with respect to such matters after the estate tax return has been filed, nor will it rule on matters relating to the  application of the estate tax to property or the estate of a living  person.
(3) In employment and excise tax matters (except taxes imposed under Chapter 42 of the Code), the National Office issues rulings with respect to prospective transactions and to completed transactions either before or after the return is filed. However, the National Office will not ordinarily rule with respect to an issue, whether related to a prospective or a completed transaction, if it knows or has reason to believe that the same or an identical issue is before any field office (including any  branch office of the Appellate Division) in connection with an examination or audit of the liability of the same taxpayer for the same or a prior period.
(4) The Service will not issue rulings to business, trade, or industrial associations or to other similar groups relating to the  application of the tax laws to members of the group. However,  rulings may be issued to such groups or associations relating to their own tax status or liability provided such tax status or liability is not an issue before any field office (including any  branch office of the Appellate Division) in connection with an examination or audit of the liability of the same taxpayer for the same or a prior period.
(5) Pending the adoption of regulations (either temporary or final) that reflect the provisions of any Act, consideration will be given to the issuance of  rulings under the conditions set forth below.
(i) If an inquiry presents an issue on which the answer seems to be clear from an application of the provisions of the statute to the facts described, a  ruling will be issued in accordance with usual procedures.
(ii) If an inquiry presents an issue on which the answer seems reasonably certain but not entirely free from doubt, a ruling will be issued only if it is established that a business emergency requires a  ruling or that unusual hardship will result from failure to obtain a  ruling.
(iii) If an inquiry presents an issue that cannot be reasonably resolved prior to the issuance of regulations, a  ruling will not be issued.
(iv) In any case in which the taxpayer believes that a business emergency exists or that an unusual hardship will result from failure to obtain a ruling, he should submit with the request a separate letter setting forth the facts necessary for the Service to make a determination in this regard. In this connection, the Service will not deem a “business emergency” to result from circumstances within the control of the taxpayer such as, for example, scheduling within an inordinately short time the closing date for a transaction or a meeting of the board of directors or the shareholders of a corporation.
(c) Determination letters issued by district directors.
(1) In income and gift tax matters, and in matters involving taxes imposed under Chapter 42 of the Code, district directors issue determination letters in response to taxpayers' written requests submitted to their offices involving completed transactions which affect returns over which they have audit jurisdiction, but only if the answer to the question presented is covered specifically by statute, Treasury Decision or regulation, or specifically by a  ruling, opinion, or court decision published in the Internal Revenue Bulletin. A  determination letterwill not usually be issued with respect to a question which involves a return to be filed by the taxpayer if the identical question is involved in a return or returns already filed by the taxpayer. District directors may not issue  determination letters as to the tax consequence of prospective or proposed transactions, except as provided in subparagraphs (5) and (6) of this paragraph.
(2) In estate and gift tax matters, district directors issue determination letters in response to written requests submitted to their offices affecting the estate tax returns of decedents that will be audited by their offices, but only if the answer to the questions presented are specifically covered by statute, Treasury Decision or regulation, or by a  ruling, opinion, or court decision published in the Internal Revenue Bulletin. District directors will not issue  determination letters relating to matters involving the  application of the estate tax to property or the estate of a living  person.
(3) In employment and excise tax matters (except excise taxes imposed under Chapter 42 of the Code), district directors issue determination letters in response to written requests from taxpayers who have filed or who are required to file returns over which they have audit jurisdiction, but only if the answers to the questions presented are specifically covered by statute, Treasury Decision or regulation, or a  ruling, opinion, or court decision published in the Internal Revenue Bulletin. Because of the impact of these taxes upon the business operation of the taxpayer and because of special problems of administration both to the Service and to the taxpayer, district directors may take appropriate action in regard to such requests, whether they relate to completed or prospective transactions or returns previously filed or to be filed.
(4) Notwithstanding the provisions of subparagraphs (1), (2), and (3), of this paragraph, a district director will not issue a determination letter in response to an inquiry which presents a question specifically covered by statute, regulations, rulings, etc., published in the Internal Revenue Bulletin, where  (i) it appears that the taxpayer has directed a similar inquiry to the National Office,  (ii) the identical issue involving the same taxpayer is pending in a case before the Appellate Division,  (iii) the  determination letter is requested by an industry, trade association, or similar group, or  (iv) the request involves an industrywide problem. Under no circumstances will a district director issue a determination letter unless it is clearly indicated that the inquiry is with regard to a taxpayer or taxpayers who have filed or are required to file returns over which his office has or will have audit jurisdiction. Notwithstanding the provisions of subparagraph (3) of this paragraph, a district director will not issue a  determination letter on an employment tax question when the specific question involved has been or is being considered by the Central Office of the Social Security Administration. Nor will district directors issue determination letters on excise tax questions if a request is for a  determination of a constructive sales price under section 4216(b) or 4218(e) of the Code. However, the National Office will issue  rulings in this area. See paragraph (d)(2) of this section.
(5) District directors issue determination letters as to the qualification of plans under sections 401 and 405(a) of the Code, and as to the exempt status of related trusts under section 501 of the Code, to the extent provided in paragraphs (o) and (q) of this section. Selected district directors also issue  determination letters as to the qualification of certain organizations for exemption from Federal income tax under sections 501 and 521 of the Code, to the extent provided in paragraph (n) of this section. Selected district directors also issue  determination letters as to the qualification of certain organizations for foundation status under sections 509(a) and 4942(j)(3) of the Code, to the extent provided in paragraph (r) of this section.
(6) District directors issue determination letters with regard to the replacement of involuntarily converted property under section 1033 of the Code even though the replacement has not been made, if the taxpayer has filed his income tax return for the year in which the property was involuntarily converted.
(7) A request received by a district director with respect to a question involved in an income, estate, or gift tax return already filed will, in general, be considered in connection with the examination of the return. If response is made to such inquiry prior to an examination or audit, it will be considered a tentative finding in any subsequent examination or audit of the return.
(d) Discretionary authority to issue rulings and determination letters.
(1) It is the practice of the Service to answer inquiries of individuals and organizations, whenever appropriate in the interest of sound tax administration, as to their status for tax purposes and the tax effect of their acts or transactions.
(2) There are, however, certain areas where, because of the inherently factual nature of the problem involved, or for other reasons, the Service will not issue rulings or  determination letters. A  ruling or  determination letter is not issued on alternative plans of proposed transactions or on hypothetical situations. A specific area or a list of these areas is published from time to time in the Internal Revenue Bulletin. Such list is not all inclusive since the Service may decline to issue  rulings or  determination letters on other questions whenever warranted by the facts or circumstances of a particular case. The National Office and district directors may, when it is deemed appropriate and in the best interest of the Service, issue  information letters calling attention to well-established principles of tax law.
(3) The National Office will issue rulings in all cases on prospective or future transactions when the law or regulations require a  determinationof the effect of a proposed transaction for tax purposes, as in the case of a transfer coming within the provisions of sections 1491 and 1492 of the Code, or an exchange coming within the provisions of section 367 of the Code. The National Office will issue  rulings in all cases involving the  determination of a constructive sales price under section 4216(b) or 4218(e) of the Code.
(e) Instructions to taxpayers.
(1) A request for a ruling or a  determination letter is to be submitted in duplicate if  (i) more than one issue is presented in the request or  (ii)a  closing agreement is requested with respect to the issue presented. There shall accompany the request a declaration, in the following form: “Under penalties of perjury, I declare that I have examined this request, including accompanying documents, and to the best of my knowledge and belief, the facts presented in support of the requested  ruling or  determination letter are true, correct, and complete”. The declaration must accompany requests that are postmarked or hand delivered to the Internal Revenue Service after October 31, 1976. The declaration must be signed by the person or  persons on whose behalf the request is made.
(2) Each request for a ruling or a  determination letter must contain a complete statement of all relevant facts relating to the transaction. Such facts include names, addresses, and taxpayer identifying numbers of all interested parties; the location of the district office that has or will have audit jurisdiction over the return or report of each party; a full and precise statement of the business reasons for the transaction; and a carefully detailed description of the transaction. In addition, true copies of all contracts, wills, deeds, agreements, instruments, and other documents involved in the transaction must be submitted with the request. However, relevant facts reflected in documents submitted must be included in the taxpayer's statement and not merely incorporated by reference, and must be accompanied by an analysis of their bearing on the issue or issues, specifying the pertinent provisions. (The term “all interested parties” is not to be construed as requiring a list of all shareholders of a widely held corporation requesting a  ruling relating to a reorganization, or a list of employees where a large number may be involved in a plan.) The request must contain a statement whether, to the best of the knowledge of the taxpayer or his representative, the identical issue is being considered by any field office of the Service in connection with an active examination or audit of a tax return of the taxpayer already filed or is being considered by a  branch office of the Appellate Division. Where the request pertains to only one step of a larger integrated transaction, the facts, circumstances, etc., must be submitted with respect to the entire transaction. The following list contains references to revenue  procedures for advance  ruling requests under certain sections of the Code.
(i) For ruling requests under section 103 of the Code, see Rev. Proc. 79-4, 1979-1 C.B. 483, as amplified by Rev. Proc. 79-12, 1979-1 C.B. 492. Revenue  Procedure 79-12 sets forth  procedures for submitting  ruling requests to which sections 103 and 7478 of the Code apply.
(ii) For ruling requests under section 367 of the Code, see Rev. Proc. 68-23, 1968-1 C.B. 821, as amplified by Rev. Proc. 76-20, 1976-1 C.B. 560, Rev. Proc. 77-5, 1977-1 C.B. 536, Rev. Proc. 78-27, 1978-2 C.B. 526, and Rev. Proc. 78-28, 1978-2 C.B. 526. Revenue  Procedure68-23 contains guidelines for taxpayers and their representatives in connection with issuing  rulings under section 367. Revenue  Procedure76-20 explains the effect of Rev. Rul. 75-561, 1975-2 C.B. 129, on transactions described in section 3.03(1)(c) of Rev. Proc. 68-23. Revenue  Procedure 77-5 sets forth  procedures for submitting  ruling requests under section 367, and the administrative remedies available to a taxpayer within the Service after such  rulings have been issued. Revenue  Procedure 78-27 relates to the notice requirement set forth in the section 367(b) temporary regulations. Revenue  Procedure 78-28 relates to the timely filing of a section 367(a)  ruling request.
(iii) For ruling requests under section 351 of the Code, see Rev. Proc. 73-10, 1973-1 C.B. 760, and Rev. Proc. 69-19, 1969-2 C.B. 301. Revenue  Procedure 73-10 sets forth the information to be included in the  ruling request. Revenue  Procedure 69-19 sets forth the conditions and circumstances under which an advance  ruling will be issued under section 367 of the Code that an agreement which purports to furnish technical know-how in exchange for stock is a transfer of property within the meaning of section 351.
(iv) For ruling requests under section 332, 334(b)(1), or 334(b)(2) of the Code, see Rev. Proc. 73-17, 1973-2 C.B. 465. Revenue  Procedure73-17 sets forth the information to be included in the  ruling request.
(v) See Rev. Proc. 77-30, 1977-2 C.B. 539, and Rev. Proc. 78-18, 1978-2 C.B. 491, relating to rules for the issuance of an advance  rulingthat a proposed sale of employer stock to a related qualified defined contribution plan of deferred compensation will be a sale of the stock rather than a distribution of property.
(vi) For ruling requests under section 302 or section 311 of the Code, see Rev. Proc. 73-35, 1973-2 C.B. 490. Revenue  Procedure 73-35 sets forth the information to be included in the  ruling request.
(vii) For ruling requests under section 337 of the Code (and related section 331) see Rev. Proc. 75-32, 1975-2 C.B. 555. Revenue Procedure 75-32 sets forth the information to be included in the  ruling request.
(viii) For ruling requests under section 346 of the Code (and related sections 331 and 336), see Rev. Proc. 73-36, 1973-2 C.B. 496. Revenue  Procedure 73-36 sets forth the information to be included in the  ruling request.
(ix) For ruling requests under section 355 of the Code, see Rev. Proc. 75-35, 1975-2 C.B. 561. Revenue  Procedure 75-35 sets forth the information to be included in the  ruling request.
(x) For ruling requests under section 368(a)(1)(E) of the Code, see Rev. Proc. 78-33, 1978-2 C.B. 532. Revenue  Procedure 78-33 sets forth the information to be included in the  ruling request.
(xi) For ruling requests concerning the classification of an organization as a limited  partnership where a corporation is the sole general partner, see Rev. Proc. 72-13, 1972-1 C.B. 735. See also Rev. Proc. 74-17, 1974-1 C.B. 438, and Rev. Proc. 75-16, 1975-1 C.B. 676. Revenue  Procedure 74-17 announces certain  operating rules of the Service relating to the  issuance of advance  ruling letters concerning the classification of organizations formed as limited partnerships. Revenue  Procedure 75-16 sets forth a checklist outlining required information frequently omitted from requests for  rulings relating to classification of organizations for Federal tax purposes.
(xii) For ruling requests concerning the creditability of a foreign tax under section 901 or 903 of the Code, see Rev. Rul. 67-308, 1967-2 C.B. 254, which sets forth requirements for establishing that translations of foreign law are satisfactory as evidence for purposes of determining the creditability of a particular foreign tax.
Original documents should not be submitted because documents and exhibits become a part of the Internal Revenue Service file which cannot be returned. If the request is with respect to a corporate distribution, reorganization, or other similar or related transaction, the corporate balance sheet nearest the date of the transaction should be submitted. (If the request relates to a prospective transaction, the most recent balance sheet should be submitted.) In the case of requests for rulings or  determination letters, other than those to which section 6104 of the Code applies, postmarked or hand delivered to the Internal Revenue Service after October 31, 1976, there must accompany such requests a statement, described in paragraph (5) of this paragraph, of proposed deletions pursuant to section 6110(c) of the Code. Such statement is not required if the request is to secure the consent of the Commissioner with respect to the adoption of or change in accounting or funding periods or methods pursuant to section 412, 442, 446(e), or 706 of the Code. If, however, the person seeking the consent of the Commissioner receives from the Internal Revenue Service a notice that proposed deletions should be submitted because the resulting ruling will be open to public inspection under section 6110, the statement of proposed deletions must be submitted within 20 days after such notice is mailed.
(3) As an alternative procedure for the  issuance of  rulings on prospective transactions, the taxpayer may submit a summary statement of the facts he considers controlling the issue, in addition to the complete statement required for  ruling requests by subparagraph (2) of this paragraph. Assuming agreement with the taxpayer's summary statement, the Service will use it as the basis for the  ruling. Any taxpayer wishing to adopt this  procedure should submit with the request for ruling:
(i) A complete statement of facts relating to the transaction, together with related documents, as required by subparagraph (2) of this paragraph; and
(ii) A summary statement of the facts which he believes should be controlling in reaching the requested conclusion.
Where the taxpayer's statement of controlling facts is accepted, the ruling will be based on those facts and only this statement will ordinarily be incorporated in the  ruling letter. It is emphasized, however, that:
(a) This procedure for a “two-part”  ruling request is elective with the taxpayer and is not to be considered a required substitute for the regular  procedure contained in paragraphs  (a) through (m) of this section;
(b) Taxpayers' rights and responsibilities are the same under the “two-part” ruling request  procedure as those provided in paragraphs (a) through (m) of this section;
(c) The Service reserves the right to rule on the basis of a more complete statement of facts it considers controlling and to seek further information in developing facts and restating them for ruling purposes; and
(d) The “two-part” ruling request  procedure will not apply where it is inconsistent with other  procedures applicable to specific situations such as: Requests for permission to change accounting method or period;  application for recognition of exempt status under section 501 or 521; or  rulings on employment tax status.
(4) If the taxpayer is contending for a particular determination, he must furnish an explanation of the grounds for his contentions, together with a statement of relevant authorities in support of his views. Even though the taxpayer is urging no particular  determination with regard to a proposed or prospective transaction, he must state his views as to the tax results of the proposed action and furnish a statement of relevant authorities to support such views.
(5) In order to assist the Internal Revenue Service in making the deletions, required by section 6110(c) of the Code, from the text of rulingsand  determination letters, which are open to public inspection pursuant to section 6110(a) of the Code, there must accompany requests for such  rulings or  determination letters either a statement of the deletions proposed by the  person requesting the  ruling or  determination letterand the statutory basis for each proposed deletion, or a statement that no information other than names, addresses, and taxpayer identifying numbers need be deleted. Such statement shall be made in a separate document. The statement of proposed deletions shall be accompanied by a copy of the request for a  ruling or  determination letter and supporting documents, on which shall be indicated, by the use of brackets, the material which the  person making such request indicates should be deleted pursuant to section 6110(c) of the Code. The statement of proposed deletions shall indicate the statutory basis, under section 6110(c) of the Code, for each proposed deletion. The statement of proposed deletions shall not appear or be referred to anywhere in the request for a  ruling of  determination letter. If the  person making the request decides to request additional deletions pursuant to section 6110(c) of the Code prior to the time the  ruling or  determination letter is issued, additional statements may be submitted.
(6) If the request is with respect to the qualification of a plan under section 401 or 405(a) of the Code, see paragraphs (o) and (p) of this section. If the request is with respect to the qualification of an organization for exemption from Federal income tax under section 501 or 521 of the Code, see paragraph (n) of this section, Revenue  Procedure 72-5, Internal Revenue Bulletin No. 1972-1, 19, and Revenue  Procedure68-13, C.B. 1968-1, 764.
(7) A request by or for a taxpayer must be signed by the taxpayer or his authorized representative. If the request is signed by a representative of the taxpayer, or if the representative is to appear before the Internal Revenue Service in connection with the request, he must either be:
(i) An attorney who is a member in good standing of the bar of the highest court of any State, possession, territory, Commonwealth, or the District of Columbia, and who files with the service a written declaration that he is currently qualified as an attorney and he is authorized to represent the principal,
(ii) A certified public accountant who is duly qualified to practice in any State, possession, territory, Commonwealth, or the District of Columbia, and who files with the Service a written declaration that he is currently qualified as a certified public accountant and he is authorized to represent the principal, or
(iii) A person, other than an attorney or certified public accountant, enrolled to practice before the Service, and who files with the Service a written declaration that he is currently enrolled (including in the declaration either his enrollment number or the expiration date of his enrollment card) and that he is authorized to represent the principal. (See Treasury Department Circular No. 230, as amended, C.B. 1966-2, 1171, for the rules on who may practice before the Service. See § 601.503(c) for the statement required as evidence of recognition as an enrollee.)
(8) A request for a ruling or an  opinion letter by the National Office should be addressed to the Commissioner of Internal Revenue, Attention: T:FP:T. Washington, DC 20224. A request for a  determination letter should be addressed to the district director of internal revenue whose office has or will have audit jurisdiction of the taxpayer's return. See also paragraphs (n) through (q) of this section.
(9) Any request for a ruling or  determination letter that does not comply with all the provisions of this paragraph will be acknowledged, and the requirements that have not been met will be pointed out. If a request for a  ruling lacks essential information, the taxpayer or his representative will be advised that if the information is not forthcoming within 30 days, the request will be closed. If the information is received after the request is closed, the request will be reopened and treated as a new request as of the date of the receipt of the essential information. Priority treatment of such request will be granted only in rare cases upon the approval of the division director.
(10) A taxpayer or his representative who desires an oral discussion of the issue or issues involved should indicate such desire in writing when filing the request or soon thereafter in order that the conference may be arranged at that stage of consideration when it will be most helpful.
(11) Generally, prior to issuing the ruling or  determination letter, the National Office or district director shall inform the  person requesting such  ruling or  determination letter orally or in writing of the material likely to appear in the  ruling or  determination letter which such  personproposed be deleted but which the Internal Revenue Service determines should not be deleted. If so informed, the person requesting the ruling or  determination letter may submit within 10 days any further information, arguments or other material in support of the position that such material be deleted. The Internal Revenue Service will attempt, if feasible, to resolve all disagreements with respect to proposed deletions prior to the issuance of the  ruling or  determination letter. However, in no event shall the  person requesting the  ruling or determination letter have the right to a conference with respect to resolution of any disagreements concerning material to be deleted from the text of the  ruling or  determination letter, but such matters may be considered at any conference otherwise scheduled with respect to the request.
(12) It is the practice of the Service to process requests for rulings, opinion letters, and determination letters in regular order and as expeditiously as possible. Compliance with a request for consideration of a particular matter ahead of its regular order, or by a specified time, tends to delay the disposition of other matters. Requests for processing ahead of the regular order, made in writing in a separate letter submitted with the request or subsequent thereto and showing clear need for such treatment, will be given consideration as the particular circumstances warrant. However, no assurance can be given that any letter will be processed by the time requested. For example, the scheduling of a closing date for a transaction or a meeting of the Board of Directors or shareholders of a corporation without due regard to the time it may take to obtain a  ruling,  opinion letter, or  determination letter will not be deemed sufficient reason for handling a request ahead of its regular order. Neither will the possible effect of fluctuation in the market price of stocks on a transaction be deemed sufficient reason for handling a request out of order. Requests by telegram will be treated in the same manner as requests by letter. Rulings, opinion letters, and determination letters ordinarily will not be issued by telegram. A taxpayer or his representative desiring to obtain information as to the status of his case may do so by contacting the appropriate division in the office of the Assistant Commissioner (Technical).
(13) The Director, Corporation Tax Division, has responsibility for issuing rulings in areas involving the  application of Federal income tax to taxpayers; those involving income tax conventions or treaties with foreign countries; those involving depreciation, depletion, and valuation issues; and those involving the taxable status of exchanges and distributions in connection with corporate reorganizations, organizations, liquidations, etc.
(14) The Director, Individual Tax Division, has responsibility for issuing rulings with respect to the  application of Federal income tax to taxpayers (including individuals, partnerships, estates and trusts); areas involving the  application of Federal estate and gift taxes including estate and gift tax conventions or treaties with foreign countries; areas involving certain excise taxes; the provisions of the Internal Revenue Code dealing with  procedure and administration; and areas involving employment taxes.
(15) A taxpayer or the taxpayer's representative desiring to obtain information as to the status of the taxpayer's case may do so by contacting the following offices with respect to matters in the areas of their responsibility:

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