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SISTER NOT ALLOWED REFUND FOR CLAIMED BUSINESS BAD DEBT DEDUCTION.

OCT. 30, 2001

Fuscaldo, Kathryn v. U.S.

DATED OCT. 30, 2001
DOCUMENT ATTRIBUTES
  • Case Name
    KATHRYN FUSCALDO v. UNITED STATES OF AMERICA
  • Court
    United States District Court for the Eastern District of Pennsylvania
  • Docket
    No. 00-CV-2486
  • Judge
    Surrick, R. Barclay
  • Parallel Citation
    2001-2 U.S. Tax Cas. (CCH) P50,780
    88 A.F.T.R.2d (RIA) 2001-6833
    2001 WL 1519684
    2001 U.S. Dist. LEXIS 18830
  • Code Sections
  • Subject Area/Tax Topics
  • Index Terms
    refunds, taxpayer suits
    bad debt deduction
  • Jurisdictions
  • Language
    English
  • Tax Analysts Document Number
    Doc 2001-28828 (14 original pages)
  • Tax Analysts Electronic Citation
    2001 TNT 223-77

Fuscaldo, Kathryn v. U.S.

                 IN THE UNITED STATES DISTRICT COURT

 

              FOR THE EASTERN DISTRICT OF PENNSYLVANIA

 

 

                    MEMORANDUM DECISION AND ORDER

 

 

                           OCTOBER 30,2001

 

 

SURRICK, J.

I. INTRODUCTION

[1] Plaintiff Kathryn Fuscaldo filed this action on May 11, 2000, seeking a tax refund of $27,511 for the 1993 tax year which she claims Defendant has wrongfully withheld. Plaintiff alleges that she is entitled to the refund by virtue of a $130,000 business bad debt deduction claimed on her Form 1040x Amended U.S. Individual Income Tax Return for 1993. A non-jury trial was held on September 28, 2001. Based upon the evidence and testimony presented and after review of the parties' submissions, we make the Findings of Fact and Conclusions of Law set forth below. See Fed.R.Civ.P. 52(a). In accordance therewith, we find in favor of Defendant and against Plaintiff and order that judgment be entered in favor of Defendant.

[2] II. FINDINGS OF FACT

1. Phoenix Safety Associates, Ltd. ("PSA") was a corporation created by Plaintiff's brother, Anthony Fuscaldo. PSA was in business of environmental consulting with offices in Phoenixville, Pennsylvania and New York, It was primarily involved in asbestos removal. (Tr. at 44)

2. The original shareholders in PSA were Anthony Fuscaldo and two other individuals. At some point, the other two individuals ceased being involved in PSA and Anthony Fuscaldo became the sole shareholder. Anthony Fuscaldo was also the president of PSA. Essentially, he was the company. (Tr. at 4, 6, 44).

3. Anthony Fuscaldo's salary as a full-time employee of PSA was $125,000 per year. Anthony Fuscaldo's wife Dolores was employed by PSA at an annual salary of $40,000. A friend of Anthony Fuscaldo's, Barbara Raskoff, was also employed by PSA. Her salary was $85,000 to $90,000 per year.

4. From 1986 through 1993, Plaintiff was employed full time by Hahnemann University. During this time, she held positions as Dean of the School of Health Services, Professor of Medicine, Oncology and Pathology, Associate Director of the Hahnemann Cancer Institute and Director of the Genetics Laboratory. Her salary during this time was approximately $125,000-$130,000 per year. (Tr. at 44-47).

5. From 1986 on, Plaintiff's role with respect to PSA primarily consisted of obtaining loans for PSA. From 1991 to 1993, Plaintiff performed some services for PSA, organizing its books. (Tr. at 46).

6. Plaintiff was never employed by PSA, she did not receive a salary from PSA, she was not on PSA's payroll and she did not have an office at PSA. (Tr. at 46).

7. During the relevant time period, PSA experienced severe financial difficulties and operated with an accumulated deficit ranging from approximately $160,000 in 1986 to more than $400,000 in 1991.

8. By 1986, PSA was in "serious financial straits," had no credit and could not borrow money. Plaintiff and/or Anthony Fuscaldo attempted to secure loans for PSA from several banks. These banks were unwilling to extend credit to PSA. PSA also owed the Internal Revenue Service ("IRS") approximately $92,000. (Tr. at 51-52)

9. In 1986, Plaintiff became sole shareholder and secretary/treasurer of PSA. Plaintiff became sole shareholder because banks were unwilling to make loans to PSA with Plaintiff as guarantor unless she had something to do with the corporation. (Tr. at 6).

10. In 1986, Plaintiff obtained a loan from Citicorp Homeowners, Inc. secured by a mortgage on her residence. Plaintiff used proceeds of that loan to pay the IRS $92,408 owed by PSA. (Tr. at 22; Exh. P- 11).

11. Plaintiff received a "promissory note" on PSA letterhead, signed by her brother Anthony A. Fuscaldo as PSA President which stated: "At the close of Fiscal Year 4/30/87 Phoenix Safety Associates, Ltd. owes Dr. Kathryn Fuscaldo Ninety Two Thousand Four Hundred and Eight dollars ($92,408.00) payable on demand. The balance of $88.289.00 @ 10.5% and $4,119.00 @ 7.75%." (Exh. P-11).

12. Other than the note itself, no documentation was offered at trial to support a loan from Plaintiff to PSA in the amount of $92,408. PSA carried the $92,408 on its books as a capital contribution. 1 (Tr. at 38-39). Plaintiff's 1992 tax return refers to this payment as an "investment." 2 (Exh. P-1).

13. Plaintiff received no security from PSA for the $92,408 and PSA never made any payments to Plaintiff for this advance. (Tr. at 22).

14. In or about March of 1988, after several banks had refused to extend credit to PSA, Plaintiff sought to obtain a loan for PSA from Fidelity Bank, where she had an account, Plaintiff secured a loan on behalf of PSA in the amount of $250,000, which she personally guaranteed. (Exh. P-14)

15. According to Plaintiff, "the only way that [Fidelity] would make the loan was if I guaranteed the loan personally since Phoenix had no credit, which I did, and I guaranteed it against my house, which was the security that I provided, both my personal guarantee and my house." (Tr. at 32).

16. In 1989, Plaintiff obtained a loan for $50,000 from First General. Plaintiff provided $35,000 of those proceeds to PSA. The only documentary evidence of this advance is a May 1989 check from Plaintiff to PSA for $35,000, which indicates "loan" in the memo portion of the check. Plaintiff testified that the balance of the $50,000 was also paid to PSA "at different times." No documentation of these payments was offered. (Tr. at 25-26, 30; Exh. P-12).

17. Also in 1989, Plaintiff took an early distribution of $43,650 from her Hahnemann University pension fund, which she provided to PSA. (Tr. at 25, 30). Plaintiff presented no credible evidence that this advance constituted a loan to PSA.

18. Plaintiff did not recoup from PSA any of the money she provided from her pension withdrawal. (Tr. at 25-26; Exh. P-13).

19. In connection with the funds from Plaintiff's First General loan and pension distribution, Plaintiff offered a copy of a purported promissory note dated May 1, 1988, which states that PSA promises to pay Kathryn E. Fuscaldo $114,148.69. However, Plaintiff could not be certain which of her claimed advances to PSA the note is alleged to reflect. The note is not signed or executed by PSA and contains no provision for interest, security or a maturity date. Plaintiff also testified that the date of the document is incorrect and that she believes it was given to her in 1989. (Exh. P-12; Tr. at 24, 30).

20. As of April 23, 1990, PSA's $250,000 loan from Fidelity Bank had been transferred to the Bank's Commercial Asset Recovery Unit. (Exh. P-14)

21. At some point in 1990, Plaintiff made a $5,000 payment to Fidelity Bank for the PSA loan she had guaranteed. (Tr. at 31). Plaintiff produced a copy of a purported promissory note dated December 31, 1990, which states that PSA promises to pay Kathryn E. Fuscaldo $5,000. (Exh. P-14). This document is not signed or executed and contains no provision for interest, security or a maturity date.

22. In 1991, Plaintiff gave $10,400 to PSA. The only documentary evidence of this advance is another unsigned "promissory note" dated May 1, 1991. Again, this note contains no provision for interest, security or a maturity date. (Exh. P-15).

23. On June 28, 1991, Plaintiff paid $5,908.90 to American Express for PSA expenses charged by Anthony Fuscaldo on her American Express account. (Tr. at 34). The only documentation of this advance is Plaintiff's check to American Express, which includes the notation "PSA" in the memo portion of the check. (Exh. P-16).

24. On or about July 10, 1991. Plaintiff wrote a check to PSA for $3,000. (Exh. P-17). The check does not reflect the nature or purpose of this advance and there is no documentation to indicate that it was a loan.

25. On October 18, 1991, Plaintiff took out another mortgage on her residence with Commerce Bank in the amount of $75,000. (Exh. P- 18)

26. Plaintiff testified that she provided $40,960 of the mortgage proceeds to PSA. (Tr. at 35). This advance to PSA is reflected in yet another unsigned "promissory note" dated October 1, 1991. (Tr. at 35; Exh. P-18). This note, which appears to pre-date Plaintiff's mortgage with Commerce Bank, also contains no provision for interest, security or a maturity date.

27. On or about November 1, 1991, Plaintiff gave PSA another $15,215, purportedly from the remaining proceeds of the Commerce Bank mortgage. (Tr. at 36) The only documentation of this advance is another unsigned "promissory note." (Exh. P-19).

28. On or about December 31, 1991, Plaintiff gave $26,000 to PSA "in order for it to pay some of its bills." (Tr. at 36), Plaintiff offered another unsigned "promissory note" as evidence of this advance. (Exh. P-20),

29. Plaintiff produced two additional unsigned "promissory notes" from PSA dated May 31, 1992. According to Plaintiff, these notes reflect separate advances she made to PSA of $11,000 for costs associated with PSA's bankruptcy filing (Exh. p-21) and $8,000 (Exh. P-22). 3

30. Plaintiff claims that between 1986 and 1992, she made a series of advances to PSA as loans, totaling almost $300,000. Plaintiff's 1992 tax return and 1993 amended tax return claim business bad debts totaling only $260,000. Plaintiff offered no explanation for this inconsistency. The advances Plaintiff testified to also differed significantly from those reflected on a purported loan summary Plaintiff offered as evidence. (Exh. P-10).

31. When Plaintiff made the first advance to PSA in 1986, PSA had already lost significant sums of money, had no credit rating, owed the IRS more than $90,000 and was unable to obtain loans independently. (Tr. at 51-52).

32. Advances made by Plaintiff to PSA were made without formal loan documentation or any provision for security or a repayment schedule. With the exception of the note for the $92,408 that Plaintiff contributed to pay the IRS debt, none of the various promissory notes@ purportedly given to Plaintiff were signed by a representative of PSA and there is no evidence of any provision for interest on any of the advances. (Tr. at 49, 59-64).

33. No evidence was offered at trial that PSA had authorized borrowing from Plaintiff.

34. Plaintiff knew that PSA was never in a position to repay her the money she advanced. (Tr. at 50) Plaintiff funded FSA for her brother in the hope that he would be able to turn the company around and make it profitable. (Tr. at 55-56). Plaintiff had no unconditional right to be repaid, "[o]ther than the agreement with the president of the corporation, my brother, that he was going to pay back the money that I loaned him. . ." (Tr. at 59).

35. Plaintiff never recouped the money she provided to PSA. (Tr. at 79).

36. PSA filed for bankruptcy in June of 1992. (Govt. Exh. U). Plaintiff, along with Anthony Fuscaldo, prepared the schedule of creditors for PSA's bankruptcy and signed the petition on behalf of PSA. (Tr. at 66).

37. The bankruptcy petition did not include Plaintiff or other Fuscaldo family members among the secured creditors, unsecured priority claims or unsecured creditors of PSA. (Govt. Exh. U; Tr. at 68-69, 79). According to Plaintiff, the Fuscaldo family members were not included among PSA's creditors because they "were hoping to reorganize the company to keep it in business. Therefore, we were listing those that -- which absolutely had to be paid in order . . . to keep the company in business." (Tr. at 79).

38. In 1993, Plaintiff submitted to the IRS her 1992 tax return in which she claimed a business bad debt deduction of $130,000 and requested a refund of 28,393. (Exh. P-1). Plaintiff's 1992 tax return stated that the $130,000 represented half of the $260,000 she claimed to have loaned to PSA on a demand basis.

39. Plaintiff 1992 tax return was not audited and she received the refund claimed on that return, (Tr. at 10, 129).

40. Plaintiff timely filed a 1993 tax return which claimed a refund of $297. On or about March 31, 1995, Plaintiff submitted to the IRS's Form 1040x Amended U.S. Individual Income Tax Return for 1993, in which she claimed a bad debt deduction of $130,000, representing the other 50 percent of the money she claimed to have loaned PSA. The amended return sought a refund of $27,511. (Tr., 11- 12; Exh. P-2).

41. On or about December 17, 1999, Plaintiff filed with the IRS a Form 843 Claim for Refund and Request for Abatement, with a copy of her 1993 amended tax return attached, seeking the refund of $27,511 claimed in her 1993 amended return and requesting an administrative conference. (Exh. P-7).

42. Plaintiff has not received the refund claimed on her 1993 amended tax return.

43. On May 11, 2000, Plaintiff filed this lawsuit seeking judgment against the United. States in the amount of $27,511.

44. Plaintiff's brother, Anthony Fuscaldo, did not testify at trial.

III. DISCUSSION

[3] Plaintiff seeks a $27,511 tax refund for 1993 based on a deduction of $130,000 for an alleged business bad debt. Plaintiff bears the burden of proving her entitlement to the tax deduction and refund that she claims. "An income tax deduction is a matter of legislative grace and . . . the burden of clearly showing the right to the claimed deduction is on the taxpayer." Interstate Transit Lines v. Comm'r of Internal Revenue, 319 U.S. 590, 593, 63 S.Ct. 1279, 87 L.Ed. 1607 (1943). See also PNC Bancorp, Inc. v. Comm'r of Internal Revenue, 212 F.3d 822, 828 (2000). Plaintiff has failed to meet her burden in this case.

[4] Section 166(a) of the Internal Revenue Code (the "Code") provides that a taxpayer may deduct from her taxable income "any debt which becomes worthless within the taxable year." 26 U.S.C. § 166(a). The general rule of deductibility for bad debts is limited by Section 166(d), which provides that "nonbusiness" debts owed to taxpayers other than corporations are deductible only when they become worthless and then only as short-term capital losses. 26 U.S.C. § 166(d)(1). A "nonbusiness" debt is defined in the negative as: "a debt other than -- (A) a debt created or acquired (as the case may be) in connection with a trade or business of the taxpayer; or (B) a debt the loss from the worthlessness of which is incurred in the taxpayer's trade or business." 26 U.S.C. § 166(d)(2).

[5] The deduction provided for in Section 166 is limited to bona fide debts. "ONLY A BONA FIDE DEBT QUALIFIES FOR PURPOSES OF SECTION 166. A bona fide debt is a debt which arises from a debtor- creditor relationship based upon a valid and enforceable obligation to pay a fixed or determinable sum of money. . . . A GIFT OR CONTRIBUTION TO CAPITAL SHALL NOT BE CONSIDERED A DEBT FOR PURPOSES OF SECTION 166." 26 C.F.R. § 1.166-1(c) (emphasis added). Accordingly, in order for a loss to be deductible as a business bad debt, the taxpayer must show (1) the existence of a bona fide debt; and (2) that the debt was created or acquired in the course of the taxpayer's trade or business or that the bad debt loss is "proximately related" to the conduct of that trade or business. See 26 C.F.R. § 1.166-5(b); Litwin v. U.S., 983 F.2d 997 (10th Cir. 1993). As noted above, the taxpayer bears the burden of establishing the bona fide nature of a claimed debt. Diamond Bros. Co. v. Comm'r of Internal Revenue, 322 F.2d 725, 730 (3d Cir. 1963).

[6] In considering Plaintiff's claim that she is entitled to a business bad debt deduction, the threshold question is whether the sums she advanced to PSA were, in fact, bona fide debts as opposed to capital contributions or equity investments. Courts look to a number of factual criteria in determining whether a taxpayer's advances are contributions to capital or bona fide loans. 4 As the Court explained in Fischer v. United States, 441 F.Supp. 32, 36 (E.D.Pa. 1977), aff'd, 582 F.2d 1274 (3d Cir. 1978) (table), the various criteria fall into three general categories: "(1) the form of the instruments; (2) the intent of the parties, and (3) the objective economic reality as it relates to the risks taken by investors." 5 Applying the relevant criteria to the evidence and testimony presented in the instant case, it is apparent that Plaintiff's advances to PSA were not bona fide loans. Rather, they were contributions to capital or equity investments.

A. FORM

[7] With one possible exception, the only documentary evidence of the "loans" Plaintiff claims to have made are unsigned "promissory notes" and, in two instances, Plaintiff's checks referencing "PSA" or "loan." None of these documents contains any provision for interest, security, a maturity date or an enforceable obligation on the part of PSA to repay Plaintiff. "The absence of an unconditional right to demand payment is practically conclusive that an advance is an equity instrument." Fischer 441 F.Supp. at 36.

[8] Although the "promissory note" for the $92,408 IRS payment is signed by Anthony Fuscaldo and purports to provide for interest, Plaintiff did not receive security for this advance, not did the note fix any kind of repayment schedule. The absence of a repayment schedule or fixed maturity date suggests that repayment of the advances was dependent on the fortunes of the business, which is more typical of a capital contribution. Price v. Comm'r of Internal Revenue, 1999 WL 234520, *2 (7th Cir. May 6, 1998). Of course, this conclusion is consistent with Plaintiff s testimony that the "promissory notes" indicate "the amount Phoenix was to pay me if and when Phoenix ever got the money." (Tr. at 62). Moreover, the $92,408 advance was treated as a capital contribution or investment both on PSA's books and in Plaintiff s 1992 and 1993 (amended) tax returns.

B. Intent

[9] Plaintiff testified that she considers the advances she made to be loans. However, Plaintiff's "conclusory declaration that the parties intended to create debts should carry little weight." Fischer, 441 F.Supp. at 37. This is particularly true in cases involving a closely-held corporation, "where the parties may create whatever appearance may be of tax benefit to them despite the economic reality of the advance." Id. The real nature of Plaintiff's advances is illustrated by her testimony that repayment was contingent upon the company's success and by the fact that Plaintiff never demanded or received any repayment. In addition, Plaintiff's advances were clearly subordinated to PSA's obligations to other creditors. These factors, combined with the absence of formalities typically associated with bona fide loans, compel the conclusion that Plaintiff's advances were intended to be investments in a family business,

C. Economic Reality

[10] Finally, the economic reality of Plaintiff's advances to PSA provides further conclusive evidence that they were not loans. "The acid test of the economic reality of a purported debt is whether an unrelated outside party would have advanced funds under like circumstances." Fischer, 441 F.Supp. at 38. Plaintiff acknowledged that she advanced money to PSA when banks would not. Plaintiff also conceded that she made additional advances in spite of the fact that PSA was never in a position to repay her and had made no payments on previous advances. (Tr. at 50-55). We are quite certain that no prudent lender would have loaned any money to PSA, much less made the series of advances provided by Plaintiff,

[11] Other indicators that the advances were capital contributions include the absence of any collateral or other security and the fact that Plaintiff's only hope of repayment depended on PSA becoming profitable. See Fischer, 441 F.Supp at 39 (advances were equity not debt if it would be unrealistic to expect them to be repaid from cash flow or funds obtained from outside lender.); Scriptomatic, Inc. v United States, 397 F.Supp. 753 (E.D.Pa. 1975), aff'd 555 F.2d 364 (3d Cir. 1977) (advances are not debt where repayment "can only be assured by the chance of profits or from the liquidation of the business . . ."). In summary, Plaintiff has failed to establish that any of the sums she advanced to PSA were bona fide debts.

[12] Because Plaintiff has failed to establish that the monies advanced by her constituted bad debts, we need not discuss whether Plaintiff's advances would qualify as business bad debts, under 26 U.S.C. § 166. We would note, however, that even if one were to somehow conclude that Plaintiffs advances to PSA constituted bad debts. Plaintiff has nevertheless failed to establish that those advances were created or acquired in the course of, or proximately related to, Plaintiff's trade or business. Hence they could not qualify as business bad debts.

[13] IV. CONCLUSIONS OF LAW

1. The sums that Plaintiff provided to or paid on behalf of PSA were not loans but were contributions to capital.

2. Plaintiff's contributions to PSA do not constitute debts under 26 U.S.C. § 166 and 26 C.F.R. § 1.166-1(c).

3. Plaintiff is not entitled to a bad debt income tax deduction under 26 U.S.C. § 166 for the sums that she provided to or paid on behalf of PSA.

4. Plaintiff's advances to PSA do not constitute business bad debts.

5. Plaintiff is not entitled to the $27,511 income tax refund claimed on her Form 1040x Amended U.S. Individual Income Tax Return for 1993.

[14] An appropriate order follows.

 

FOOTNOTES

 

 

1 Plaintiff testified that the $92,408 was originally carried on PSA's books as a loan but, on the advice of an accountant, it was redesignated as a capital contribution because "it would make the books look better because it would not be carried on the books as a debt." (Tr. at 58).

2 Plaintiff's 1992 tax return states that she invested $90,000 (not $92,408) in PSA and subsequently loaned PSA $260,000 on a demand basis. Plaintiff's 1992 return and her 1993 amended return each claim a deduction for $130,000 -- 50 percent of the $260,000 she claimed to have loaned PSA. (Exh. P-1, P-2).

3 We would note that the unsigned "promissory notes" are of questionable significance. That significance is further undermined by the fact that they are not contemporaneous with the alleged corresponding advances.

4 The Code identifies a number of factors that may be included by the Secretary of the Treasury in prescribing regulations governing whether an advance is within a debtor-creditor or a corporation- shareholder relationship. 26 U.S.C. § 385. Although such regulations have not been prescribed, the factors set forth in Section 385 are reflected in the criteria applied by the courts.

5 In Fin Hay Realty Co. v. U.S., 398 F.2d 694, 696 (3d Cir. 1968), the Third Circuit Court of Appeals identified sixteen factors relevant to the debt versus capital contribution analysis: 1) the intent of the parties; (2) the identity between creditors and shareholders; (3) the extent of participation in management by the holder of the instrument; (4) the ability of the corporation to obtain funds from outside sources; (5) the 'thinness' of the capital structure in relation to debt; (6) the risk involved; (7) the formal indicia of the arrangement; (8) the relative position of the obligees as to other creditors regarding the payment of interest and principal; (9) the voting power of the holder of the instrument; (10) the provision of a fixed rate of interest; (11) a contingency on the obligation to repay; (12) the source of the interest payments; (13) the presence or absence of a fixed maturity date; (14) a provision for redemption by the corporation; (15) a provision for redemption at the option of the holder; and (16) the timing of the advance with reference to the organization of the corporation. However, no single criterion or group of criteria is determinative and "where not all criteria are pertinent, an analysis of a lesser number will suffice." Fischer v. United States, 441 F.Supp. 32, 36 (E.D.Pa. 1977), citing, Joseph Lupowitz Sons, Inc. v. Comm'r of Internal Revenue, 497 F.2d 862 865-66 (3d Cir. 1974); Trans-Atlantic Co. v. Comm'r of Internal Revenue, 469 F.2d 1189 (3d Cir. 1972). See also Jensen v. Comm'r of Internal Revenue, 2000 WL 300208, *2 (10th Cir. March 23, 2000) (considering thirteen factors); Price v. Comm'r of Internal Revenue, 1998 WL 234520, *2 (7th Cir. May 6, 1998) (considering ten factors).

 

END OF FOOTNOTES

 

 

* * * * *

ORDER

[15] AND NOW, this 30th day of October, 2001, after a non-jury trial, and in accordance with the attached findings of fact and conclusions of law, this Court finds in favor of Defendant the United States of America and against Plaintiff Kathryn Fuscaldo. It is ORDERED that judgment is entered in favor of Defendant and against Plaintiff.

BY THE COURT:

                                   R. Barclay Surrick, Judge

DOCUMENT ATTRIBUTES
  • Case Name
    KATHRYN FUSCALDO v. UNITED STATES OF AMERICA
  • Court
    United States District Court for the Eastern District of Pennsylvania
  • Docket
    No. 00-CV-2486
  • Judge
    Surrick, R. Barclay
  • Parallel Citation
    2001-2 U.S. Tax Cas. (CCH) P50,780
    88 A.F.T.R.2d (RIA) 2001-6833
    2001 WL 1519684
    2001 U.S. Dist. LEXIS 18830
  • Code Sections
  • Subject Area/Tax Topics
  • Index Terms
    refunds, taxpayer suits
    bad debt deduction
  • Jurisdictions
  • Language
    English
  • Tax Analysts Document Number
    Doc 2001-28828 (14 original pages)
  • Tax Analysts Electronic Citation
    2001 TNT 223-77
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