3.21.261  Foreign Investment in Real Property Tax Act (FIRPTA) (Cont. 1)

3.21.261.16  (01-01-2014)
Computer Condition Codes (CCC) – Form 8288

  1. An entry is required in the CCC field. See paragraph (9) below.

  2. Only the following characters are valid: D, O, R, U, W, X, 3, 4 or 7.

  3. Edit the Computer Condition Code(s) in the Part I left margin of the last dotted line of Line 2 when editing Part I. Edit CCC in the Part II left margin of the last dotted line of Line 2 when editing Part II. See Exhibit 3.21.261-1 and Exhibit 3.21.261-2.

    Note:

    Use Computer Condition Codes (CCC) in lieu of Action Codes.

  4. CCC "D" is used when reasonable cause exists for waiver of the failure to pay penalty. However, C and E employees will not make this determination. If the taxpayer attaches correspondence with a reasonable cause explanation for failure to pay, then take the following steps:

    1. Detach the correspondence from the return.

    2. Forward the correspondence to Ogden Accounts Management (use local procedures).

    3. Prepare correspondence action sheet for IDRS Letter 1382C (use paragraphs "A" , "N" and "V" ).

    4. Continue processing the return.

    Note:

    Edit CCC D if the FTP box on Form 13596 is checked.

  5. Edit CCC "O" when there is an indication that a manual refund will be issued.

  6. CCC "R" is used on a delinquent return with reasonable cause. CCC "R" prevents the failure to file penalty to be assessed. However, C and E employees will not make this determination. If the taxpayer attaches correspondence with a reasonable cause explanation for failure to file, then take the following steps:

    1. Detach the correspondence from the return.

    2. Forward the correspondence to Philadelphia Accounts Management (use local procedures).

    3. Prepare correspondence action sheet for IDRS Letter 1382C (use paragraphs "A" , "N" and "V" ).

    4. Continue processing the return.

    Note:

    Edit CCC R if the FTF box on Form 13596 is checked.

  7. Edit CCC "U" (Unprocessable return) to reject unprocessable returns. If additional information is needed, use IDRS Letter 3104C.

  8. Edit CCC "W" when the return has been cleared by Statutes. See IRM 3.21.261.7.

  9. Always edit CCC "X" on Form 8288 returns. This will freeze all credits on the module and prevent erroneous systemic refunds from generating.

  10. Edit CCC "3" when there is no reply to correspondence. This bypasses the validation of the correspondence received date.

  11. Edit CCC "4" for IRS prepared returns under IRC § 6020(b).

  12. CCC "7" is used when denying the reasonable cause explanation for filing and paying late. However, C&E employees will not make this determination. This CCC will mainly be used by Accounts Management or Compliance employees when re-processing or re-inputting a return for processing, since they also have to issue IDRS Letter 854C.

    Caution:

    When using CCC" 7," do not use CCC "D or R."

3.21.261.17  (01-01-2014)
Editing Form 8288

  1. Use the following instructions when editing the described fields in subsequent sections.

  2. "EXCEPTION:" The Transferee (buyer) is not required to withhold or mail in a Form 8288 or Form 8288-A, if any of the following applies:

    • "Purchase of a Residence for $300,000.00 or less."
      One or more individuals acquire a U.S. real property interest (USRPI) for use as a residence and the amount realized (sales price) is not more than $300,000. A USRPI is acquired for use as a residence if the transferee (buyer) or a member of the transferee's family has definite plans to reside in the property for at least 50 percent of the number of days the property is used by any person during each of the first two 12-month periods following the date of transfer. Do not take into account the number of days the property will be vacant in making this determination.

      Reminder:

      This exception applies whether or not the transferor (seller) is an individual, partnership, trust, corporation, or other transferor.

      Caution:

      This exception does not apply if the actual transferee (buyer) is not an individual, even if the property is acquired for an individual.

    • "Transferor (seller) is not a Foreign Person."
      The transferee (buyer) receives a CERTIFICATION OF NONFOREIGN STATUS from the transferor (seller) signed under penalties of perjury stating that the transferor is not a foreign person and containing the transferor’s name, address, and identification number (social security number (SSN) or employer identification number (EIN).

      Caution:

      A disregarded entity may not certify that it is the transferor (seller) for U.S. tax purposes.

    • "Late Notice of False Certification."
      If, after the date of transfer, the transferee (buyer) is notified that the certification of nonforeign status is false, the transferee does not have to withhold on consideration paid before receiving the notice of False Certification.

      Caution:

      If possible, the transferee (buyer) must withhold 10% of the amount realized from any consideration that remains to be paid. The transferee must do this by withholding and paying over the entire amount of each successive payment of consideration until the full 10% has been withheld and paid to the IRS. These amounts must be reported and transmitted to the IRS by the 20th day following the date of each payment.

    • "Transferred property that is not a USRPI."

    • "Transferor’s (seller) nonrecognition of gain or loss."
      The transferee (buyer) receives a notice of "NONRECOGNITION OF GAIN OR LOSS" from the transferor signed under penalties of perjury stating that the transferor is not required to recognize gain or loss on the transfer because of a nonrecognition provision of the Internal Revenue Code (see Temporary Regulations section 1.897-6T(a)(2)) or a provision in a U.S. tax treaty.

      Note:

      No particular form is required for this notice. By the 20th day after the date of transfer, you must send a copy of the notice of nonrecognition (with a cover letter giving your name, address, and identification number) to the:
      Ogden Service Center
      P.O. Box 409101
      Ogden, UT 84409.

    • "Withholding Certificate issued by the IRS."
      The transferee (buyer) and/or transferor (seller) receive a withholding certificate from the IRS that excuses or exempts the transferor from withholding. The transferee is not required to file Form 8288 or Form 8288-A with the IRS.

    • "No Consideration Paid."
      The amount realized by the transferor (seller) is Zero.

      Example:

      The property is transferred as a gift and the recipient (transferee/buyer) does not assume any liabilities or furnish any other consideration to the transferor (seller).

    • "Property acquired by a governmental unit."
      The property is acquired by the United States, a U.S. state or possession or political subdivision, or the District of Columbia.

    • "Options to acquire USRPI."
      An amount is realized by the grantor on the grant or lapse of an option to acquire a USRPI.

      Caution:

      Withholding is required on the sale, exchange, or exercise of an option.

    :

  3. If the transferee (buyer) files a Form 8288 and Form 8288-A and discloses to the IRS that no withholding is required because they meet one of the filing "Exceptions" mentioned in IRM 3.21.261.17 (2), then take the following action:

    1. Pull the document (Form 8288 or Form 8288-A) from the batch.

    2. Is the document numbered?
      YES! If the document is numbered, have the DLN cancelled. Line through the cancelled DLN in red. Make sure the DLN is removed from the Service Center Control File (SCCF).
      NO! Go to the next step.

    3. Take the document and place a red "X" on the entire page, including any Form 8288-A's or attached correspondence. Destroy the document by following your local "Classified Waste" procedures.

      Reminder:

      Never enter the Form 8288-A's in the INTL WebApps Database nor correspond for any missing information, specifically a TIN number.

3.21.261.17.1  (01-01-2014)
Dates

  1. Use the following formats when editing dates:

    • MMDDYYYY for Received Dates

    • MMDDYYYY for Date of Transfer (DOT)

    • YYYYMM for Tax Periods

  2. The month value edited must be in the range 01-12.

  3. The day value edited must be in the range 01-31.

  4. Always edit the tax period.

    Example:

    200812, 200901,200909, etc.

    Note:

    Transcription under this program is permitted ONLY for those Form 8288 returns containing a "Date Of Transfer (line 3)" of December 13, 2005, and subsequent.

    See IRM 3.21.261.18.1 and IRM 3.21.261.18.8 (9).

3.21.261.17.2  (01-01-2014)
Entity Perfection - Name Control - Line 1

  1. The name control consists of the first four characters of the transferees (buyers) last name, or the first four characters of the business entity name.

    1. Valid characters are alpha, numeric, ampersand (&), hyphen (-) and blank. However, blanks are only valid in the last three positions. Blanks are valid only at the end of the name control.

    2. Disregard the word "THE" in the Name Control only when followed by more than one word.

      Note:

      If an individual and a trade name are present and it can be determined that the trade name is for a corporation or partnership, follow the Name Control procedures for corporations or partnerships. If other than a corporation or partnership, follow the Name Control procedures for individuals, regardless of which line the individuals owner’s name is listed.

      Example:

      The business name is The Green Parrot, underline the name control "Gree" . However, if the business entity name is The Flamingo, underline the name control "TheF" because the word "THE" was followed by one word and not more than one word.

      Reminder:

      Refer to the Name Control Job Aid, Document 7071,Name Control Job Aid for Individual Master File (IMF) Taxpayers and Document 7071A,BMF Name Control Job Aid - For Use Outside of the Entry Area for further guidance.

  2. All Name Controls are to be underlined.

  3. Edit the Name Control as follows:

    If... And... Then...
    The entity is not on an IRS label   Underline the Name Control.
    A second name is present and begins with "FKA" (formerly known as),   Continue editing the return.
    A second name is present and begins with "AKA" (also know as) or "DBA" (doing business as), etc.,   Circle the abbreviations.
    Unable to determine the Name Control, Unnumbered
    1. Research IDRS.

    2. If found, edit to the proper location.

    3. If not found, route to Entity Control following local procedures.

    Unable to determine the Name Control, Numbered
    1. Edit CCC "U"

    2. Prepare Form 4227 addressed to Entity Control Unit (ECU). Route to ECU.

  4. If the incorrect transferee (buyer) appears on Form 8288 Line 1 (e.g. Title Company) but the Form 8288-A or settlement agreement (if attached) contains the correct transferee, then edit the correct transferee name and TIN to Form 8288 Line 1. In addition, edit the Form 8288-A withholding agent box with the correct transferee information and enter or update the 8288-A record in the INTL WebApps with the correct transferee (buyer) information.

    Note:

    Research IDRS to see if the payment posted to the title company EIN account. If it did, then photocopy Form 8288 and any pertinent attachment. Prepare Form 3465 and staple it to the photocopied documents. Write on Form 3465 instructions for Philadelphia Accounts Management Campus (PAMC) to transfer the FIRPTA payment from the title company account, to the actual transferee (buyer) TIN account.

3.21.261.17.3  (01-01-2014)
Taxpayer Identifying Numbers

  1. Entries in this field may be either,

    • Employer Identification Number (EIN) (entered in NN-NNNNNNN format).

    • Social Security Number (SSN) (entered in NNN-NN-NNNN format).

    • Individual Taxpayer Identification Number (ITIN) (entered in 9NN-NN-NNNN format with 4th and 5th digit middle numbers ranging in between 70-88, 90-92, 94-99)

    • Internal Revenue Service Number (IRSN) (entered in 9NN-NN-NNNN* format with valid 4th and 5th digit ranges of 02, 04, 05, 06, 07, 08, 09, 10, 17, 18, 19, 28, 29, 37, 38, 39, 49, and 89; (e.g., 9NN-05–NNNN* (PSPC) 9NN-04–NNNN* (OSPC)).

      Note:

      For an IRSN to be valid the TIN in 4th and 5th positions need to include "01" , "03" , "11" , "16" , "40" .

    Reminder:

    Route the return to the BMF Entity unit on a Form 4227 if it doesn't have an SSN, ITIN or IRSN on Line 1, so Entity can establish the entity with TC 000. In the remarks area write: "Please establish the SSN, ITIN or IRSN number on the BMF via TC 000 for MFT 17." If TC 000 has been edited on the return (orange ink), then it has already been established.

  2. The valid characters are Numeric (0-9).

  3. Form 8288 Only: When the entered TIN is an SSN, ITIN or IRSN, then a TIN Type indicator of " 0" must be edited immediately to the right of the TIN. If the TIN entered is an EIN, the TIN Type field is to be left "blank" .

  4. If more than one TIN is entered in a field, then research the TIN to make sure it matches the name, and:

    1. Edit or perfect the first TIN entered, and

    2. Circle out the second or subsequent TIN(s) and the name(s) associated to the second or subsequent TIN.

      Note:

      If both an SSN and EIN are present, use the SSN and the individuals entity name associated with the SSN for transcription, unless the entity name is a business name, then use the EIN. Depending on the TIN you select, circle out the other TIN and name associated with it.

  5. Be sure to edit the correct TIN Type indicator after each TIN. See IRM 3.21.261.18.3.1

  6. If multiple TINs are listed on Form 8288 Line 1 because of multiple transferees (buyers) also being listed, then research the first TIN on IDRS to identify the correct TIN for the first listed transferee. Subsequently, circle out the TINs pertaining to the other transferees, leaving only the TIN number pertaining to the first listed transferee. Do not circle out or underline the remaining transferee's.

    Example:

    Gwen Gnu Advertising, Mildred Puma and Jeremiah Serval with TINs 000-00-5226, 900-00-0002, 00-5236855. IDRS research shows 00-5236855 belongs to Gwen, therefore circle out 000-00-5226 and 900-00-0002.

  7. An SSN with a "V" at the end is BMF and not IMF. In order to reduce the number of Unpostables, C&E FIRPTA employees will need to research IDRS to see if the "V" tape is established. If the "V" is not established, route the return to Entity.

3.21.261.17.4  (01-01-2014)
♦Entity Perfection - "In Care of" Name♦ Line 1

  1. An "in-care-of" name can be identified by the words "in care of" or the symbols "c/o" or "%" (percent).

  2. Ensure the "in-care-of" name is located above the street address.

    If... Then...
    The "in-care-of" name is located on the street address line preceding the street address No editing is required.
    The "in-care-of" name is located below the street address
    1. Arrow the "in-care-of" name above the street address.

    2. Continue editing the return.

    The "in-care-of" name is shown on an attachment Edit the "in-care-of" name above the street address in the first position.
    The street address of the "in-care-of" name is different from the street address of the Transferee (buyer)
    1. Arrow the "in-care-of" street address below the "in-care-of" name or edit the in-care-of street address below the "in-care-of" name if located on an attachment.

    2. Circle the transferee (buyer) street address.

    3. Continue editing the return.

    Note:

    Always circle out the "in-care-of" symbol (% or c/o) if it is present with an address. Do not use the ampersand (&) and the percent sign (%) when editing address information.

  3. A change in the "in-care-of" name can be determined by any of the following:

    • An indication that the "in-care-of" name is changed (i.e., the taxpayer crossed out the original "in-care-of" name and added the new name or has entered a new "in-care-of" name in brackets).

    • Information is attached showing a change to the "in-care-of" name or address.

    If... Then...
    An "in-care-of" name is changed but there is no indication of an address change,
    1. Edit the in-care-of name as shown above.

    2. Continue editing the return.

    An "in-care-of" name is present and there is an indication of an address change,
    1. Edit the in-care-of name as shown above.

    2. Correct the address.

    3. Continue editing the return.

3.21.261.17.5  (01-01-2014)
♦General Address Perfection♦

  1. Both domestic (U.S.) and foreign addresses should include:

    • The street number

    • The street name

    • Any appropriate room or suite designation (i.e., "Suite 2000" )

    • The City, State, and Zip Code (for domestic addresses)

    • If a foreign address, see IRM 3.21.261.17.7 (6).

  2. When editing either the mailing or location address information, remember the following guidelines:

    1. Ensure that a house or building number is present. Do not accept a building name in place of the numeric designation. Research for the correct address.

    2. Always edit the suite, apartment number, room number, etc. at the end of the street address line.

    3. If present, always edit the street suffix, such as street, drive, lane, terrace, etc.

    4. If present always edit the directional information, such as North, South, East, West, etc.

      Note:

      Use the appropriate abbreviations when necessary. See Document 7475 (State and Address Abbreviations, Major City Codes (MCCs), ZIP Codes and Countries)

      .

    5. If after research a street address or PO Box is not found, edit the word "Local" on the street address line.

      Note:

      This should only occur in very small towns.

3.21.261.17.6  (01-01-2014)
♦Entity Perfection - Domestic Addresses♦ Line 1

  1. Perfection of the address is necessary when the mailing address (Street or P.O. Box) is not easily identified.

    Exception:

    Do not perfect the address on amended returns (CCC "G" ).

  2. The procedures for perfection of an address are as follows:

    If... And... Then...
    The address contains information of a street address or P.O. Box   No perfection is necessary, ISRP will enter the complete address.
    There is an indication on an attachment that the address has been changed   Edit the new address in the Entity section of the return.
    Form 8822, Change of Address, is attached The information is the same as on the return Take no action
    Form 8822, Change of Address, is attached The information is different Detach Form 8822 and route to Entity Control following local procedures.
    Both a P.O. Box and a street address are shown  
    1. Circle out the P.O. Box.

    2. Underline the street address.

    Two street addresses are shown  
    1. Circle out the first street address.

    2. Underline the second street address.

    One street address is shown The taxpayer changed the address to a P.O. Box
    1. Circle out the street address.

    2. Underline the P. O. Box.

    The city and state are not shown on the return but are shown on an attachment,   Edit the city and state in the Entity section of the return.
    The ZIP Code is missing or illegible,   See Document 7475, State and Address Abbreviations, Major City codes (MCCs), ZIP Codes and Countries to determine the ZIP Code.

    Note:

    Edit the 3 digits followed by "01" of the first zip code listed for the applicable state (e.g., "99501" for Alaska).

    Only the first three digits of the ZIP Code can be determined,   Edit "01" for the fourth and fifth digits.
    The National Change of Address (NCOA) label is present,   Underline the Name Control.
    It is necessary to edit the street address   See Document 7475 for current Address/Street Abbreviations.

    Note:

    Always circle out the "in-care-of" symbol ("c/o" or "%" ) if it is present with an address. Do not use the ampersand (&) and the percent symbol (%) when editing address information.

  3. The U.S. Postal Service established new address requirements for Army Post Office (APO), Fleet Post Office (FPO), Diplomatic Post Office (DPO) addresses. If the old address appears (i.e., APO New York, NY 091XX), convert to the new state code abbreviation based on the ZIP Code (i.e., the previous example would be converted to APO AE 091XX). APO/FPO/DPO addresses are considered domestic addresses. Refer to conversion chart below:

    ZIP Code Address Country APO/FPO Address
    34000-34049 APO Americas APO AA [ZIP Code]
    34050-34099 FPO Americas FPO AA [ZIP Code]
    340XX-340XX DPO Americas DPO AA [ZIP Code]
    090XX-094XX
    096XX-098XX
    APO Europe APO AE [ZIP Code]
    095XX FPO Europe FPO AE [ZIP Code]
    090XX-098XX DPO Europe DPO AE [ZIP Code]
    962XX-965XX
    98700-98759
    APO Pacific APO AP [ZIP Code]
    966XX and
    98760-98799
    FPO Pacific FPO AP [ZIP Code]
    962XX-966XX DPO Pacific DPO AP [ZIP Code]

3.21.261.17.7  (01-01-2014)
♦General Information and Perfection of Foreign Address♦

  1. This is a 35 character field. Valid characters are alpha (a-z) and numeric (0-9).

  2. A foreign (international) address is any address that is not in the 50 states, the District of Columbia or any of the U.S. Possessions.

  3. Returns with APO, FPO or DPO addresses are considered domestic addresses.

  4. Route returns with a foreign address to Ogden Submission Processing Campus (OSPC) for processing. Prepare Letter 86C to inform the taxpayer that the return has been sent to OSPC.

  5. Returns with addresses in the following U.S. Possessions are considered to be a foreign address for processing purposes but are edited in the same way as domestic addresses.

    1. A two-character alpha code must be edited on Line 1 row 3 for the possession name.

      U.S. Possession Abbreviation
      American Samoa AS
      Federated States of Micronesia FM
      Guam GU
      Marshall Islands MH
      Northern Mariana Islands MP
      Palau PW
      Puerto Rico PR
      Virgin Islands (U.S.) VI

    2. A ZIP Code must be present. Edit the appropriate ZIP Code if one is not provided.

  6. All other foreign addresses are edited the same as a domestic address with the following exceptions:

    1. The foreign country must be the last entry in the address. See IRM 3.21.261.17.7.1 for procedures on editing the country code for returns with a Canadian address.

    2. Circle out the foreign country and edit the 2 letter country code preceded by a "/" and followed by "/$" as the last entry in the address.

      Note:

      Submission Processing BMF Foreign Address Job Aid (Number 2324–002) provides examples for editing foreign addresses.

    3. If the foreign address is from Australia, Brazil, Cuba, Italy, Mexico or The Netherlands, check if the address contains a province, state or territory name.

      If... Then...
      A province, state or territory name is present
      1. Circle out province, state or territory name.

      2. Enter appropriate abbreviation.

      A province, state or territory name is not present Continue editing the return.
      Province, state or territory is shown in abbreviated format, Continue editing the return.

    4. A ZIP code is not required on a foreign address. Foreign addresses use a postal code that is entered before the foreign country and is part of the address.

3.21.261.17.7.1  (01-01-2014)
♦Foreign Address – Canada Only♦

  1. In an effort to assist Compliance with workload assignment, returns filed with an address in Canada will be edited using a unique country code based on the province.

    If... Then...
    The foreign address contains a Canadian province name or abbreviation,
    1. See Figure 3.21.261-2 to ensure the correct Canadian province abbreviation is present or edited to the return.

    2. Edit the appropriate country code based on the province preceded by a "/" and followed by a "/$" as the last entry in the address.

    3. See the table below for a complete list of available codes.

    The foreign address does not contain a Canadian province name or abbreviation,
    1. Circle the country name.

    2. Edit the country code "/CA/$" as the last entry in the address.

    Figure 3.21.261-2

    Canadian Province Country Code Postal Codes begin with
    Alberta XA T
    British Columbia XB V
    Manitoba XM R
    New Brunswick XN E
    Newfoundland and Labrador XL A
    Northwest Territories XT X
    Nova Scotia XS B
    Nunavut XV X
    Ontario XO K, L, M, N, P
    Prince Edward Island XP C
    Quebec XQ G, H, J
    Saskatchewan XW S
    Yukon XY Y

3.21.261.17.8  (01-01-2014)
City

  1. This is a 22 position field for which an entry must be present.

  2. The valid characters are, alpha (a-z).

  3. Research the ZIP Code directory to determine the city and/or state if:

    • The address is a U.S. address.

    • The city and/or state is missing or incomplete.

  4. If the address is a foreign address which includes a Province designation.

    1. Circle out the name of the province.

    2. Edit the 2 position alpha abbreviation at the end of the city field.

    3. A two (2) position alpha code must be present for Canadian addresses.

3.21.261.17.9  (01-01-2014)
State

  1. A state must be present for all U.S. addresses.

  2. Valid characters are alpha (a-z.).

  3. If the State name is spelled out, do not edit the two digit state code. ISRP will enter the two digit state code.

  4. If the address is a foreign address ISRP will automatically enter a period blank in the state field.

    Note:

    If an entry, other than a state or province is present in the state field, then arrow it to its proper placement. If undetermined, circle it out.

  5. When the State is missing or illegible, research attachments and/or ZIP Code directory, if not found research IDRS.

    Note:

    See Document 7475.

3.21.261.17.10  (01-01-2014)
ZIP Code

  1. These are 12 position fields for which entries must be present for U.S. addresses.

  2. The valid characters are alpha (a-z) and numeric (0-9).

  3. The U.S. ZIP Code must contain at least five (5) and may contain up to twelve (12) characters.

  4. If the address is a U.S. address and the ZIP Code is missing or incomplete,

    1. Research the ZIP Code Directory.

    2. Edit the correct ZIP Code.

  5. A foreign postal code may include both alpha and numeric characters. See Job Aid 2324-002 for proper placement.

  6. U. S. and Australian addresses must include Numeric Postal Codes.

    Reminder:

    The Australian Postal Codes must be edited after the street address in the street address field.

    Figure 3.21.261-3
    State Territory Postal Codes
    New South Wales and A.C.T. 2000–2999
    Victoria 3000–3999
    Queensland 4000–4999
    South Australia 5000–5799
    Western Australia 6000–6799
    Tasmania 7000–7499
    Northern Territory 0800–0899

3.21.261.17.11  (01-01-2014)
Amounts

  1. These are 12 position fields for which entries may or may not be present.

  2. Valid characters are numeric (0-9) or blank.

  3. Entries must be zero ("0" ), or a significant entry. No negatives are allowed.

  4. Entries are to be transcribed in dollars and cents.

3.21.261.17.11.1  (01-01-2014)
♦Foreign Currency♦

  1. For returns completed in other than U.S. currency, process as filed. However, if corresponding for missing/incomplete item(s), include in the letter to resubmit in U.S. currency.

3.21.261.18  (01-01-2014)
Processing Form 8288, U.S. Withholding Tax Return for Dispositions by Foreign Persons of U.S. Real Property Interests

  1. The following subsections are to be used in the editing of Form 8288.

  2. Form 8288 is a 1 page income tax return. It is also considered the transmittal page to Form 8288-A.

  3. See IRM 3.21.261.1.

3.21.261.18.1  (01-01-2014)
Editing the Tax Period for Form 8288

  1. The tax period for a Form 8288 is based on the Month and Year of the Date of Transfer, found on Line 3 (Part I or Part II). Therefore, if the Date of Transfer is 07/05/2013, then the tax period will be 201307. See IRM 3.21.261.18.8 (9).

    Example:

    Edit the appropriate tax period in accordance to the Date of Transfer. Editing is required on EVERY RETURN.

    Caution:

    When processing Form 8288 deposits the "Date of Transfer" is used to determine the tax period, as well as distinguish a NMF Form 8288 from a BMF Form 8288. Review Form 8288 for a possible withholding certificate. When a withholding certificate is attached, edit the Withholding Certificate notice date to Line 3 (Part I or II) of Form 8288. This edited Date of Transfer will be the new date used for the tax period, as well as the new Date of Transfer.

    Reminder:

    The same transferee (buyer) withholding agent may file one or more Form 8288 in a month, or in every month of the year.

  2. The initial tax period being processed to the BMF under MFT 17 is tax period ending 12/31/2005. This tax period will be valid for any Form 8288 reflecting a Date of Transfer of 12/13/2005, or subsequent.

    Caution:

    Form 8288 is due to the IRS by the 20th day after the date of transfer, or, by the 20th day after the date on the withholding certificate, whether it is approved or denied.

  3. Edit the tax period in "YYYYMM" format on Form 8288, and to the right of the form title.

    Figure 3.21.261-4

    This image is too large to be displayed in the current screen. Please click the link to view the image.

    Editing the Tax Period

  4. A tax period should end on the last day of a month except, unless otherwise specified.

    Note:

    Ignore a minor discrepancy such as October 30, instead of October 31.

  5. Form 8288 is a withholding tax return filed by the transferee (buyer) when a USRPI is purchased from a foreigner. As a result of this uniqueness in processing, there will never be Filing Requirements appearing on INOLE for Form 8288, MFT 17.

  6. For additional instructions see IRM 3.21.261.17.1

3.21.261.18.2  (01-01-2014)
Editing the PART NUMBER

  1. The transferee (buyer) is required to complete Form 8288 and Form 8288-A after the USRPI transfer has taken place. This requires the transferee to complete either Part I or Part II of Form 8288. The Part number can be found above Line 1 of the part completed by the transferee. The editing of this field has an impact on the tax calculation.

    Note:

    Taxpayers are only to complete either Part I or Part II of Form 8288. In the event that both parts are completed, the default part to edit for transcription is Part I. "X" out Part II, and if necessary, transfer amounts from Part II to Part I.

  2. If Part I is completed, then edit a "1" in the outside left margin next to the Part I box. Also edit CCC "X" . See IRM 3.21.261.16 (3).

    Note:

    The "1" indicates to the computer that an amount realized should be present on Line 5 Part I for the computer to calculate the 10 percent withholding tax on the amount realized.

  3. If Part II is completed, then edit a "2" in the outside left margin on the middle of the page next to the Part II box. Also edit CCC "X" . See IRM 3.21.261.16 (3).

    Note:

    The " 2" indicates to the computer to look at Line 5a in Part II for the amount subject to withholding. The computer will systemically calculate the Withholding (W/H) tax at 35 percent on the amount on line 5a.

    Figure 3.21.261-5a

    This image is too large to be displayed in the current screen. Please click the link to view the image.

    Editing Part I

    Figure 3.21.261-5b

    This image is too large to be displayed in the current screen. Please click the link to view the image.

    Editing Part II

3.21.261.18.3  (01-01-2014)
Taxpayer Identifying Number (TIN) -- end of Line 1

  1. A nine character Taxpayer Identifying Number (TIN) must be included on Line 1 of all Form 8288 submitted for processing.

    Reminder:

    If Form 8288 Line 1b is an SSN, ITIN or IRSN number, then a TC 000 must be input by the BMF Entity Control Unit to establish the TIN on the BMF. If this action was completed, then the return will be edited with either a " TC 000," a "V" or "W" in orange ink at the end of the TIN, or the IRSN number written in orange ink on line 1b. If any of these indicators are present, then do not route the return to the ECU. Otherwise, edit CCC "U" and forward to Entity to establish the TIN on the BMF.

  2. The valid characters are numeric (0-9).

  3. The TIN may be either:

    • An Employer Identification Number (EIN)

    • A Social Security Number (SSN), or

    • An Individual Taxpayer Identification Number (ITIN)

    • or, an Internal Revenue Service Number (IRSN)

    See IRM 3.21.261.17.3

    Note:

    Generally, the deposit activity area would have resolved most of the TIN issues in order to process the withholding tax payment.

  4. Check attachments and/or initiate research if the Taxpayer Identifying Number (TIN) provided is other than 9 digits, missing, invalid, or indeterminate.

  5. Circle out an invalid or illegible TIN.

  6. If "pending" , "applied for" , etc. is indicated in the TIN area, research for the TIN.

  7. If no TIN is found, edit CCC "U" and forward to Entity for research.

  8. If multiple TINs are listed on Form 8288 Line 1 because of multiple transferees (buyers) also being listed, then research the first TIN on IDRS to identify the correct TIN for the first listed transferee. Subsequently, circle out the TINs pertaining to the other transferees, leaving only the TIN number pertaining to the first listed transferee. Do not circle out or underline the remaining transferees names.

    Example:

    Gwen Gnu Advertising, Mildred Puma and Jeremiah Serval with TINs 000-00-5226, 900-00-0002, 00-5236855. IDRS research shows 00-5236855 belongs to Gwen, therefore circle out 000-00-5226 and 900-00-0002

3.21.261.18.3.1  (01-01-2014)
Taxpayer Identifying Number Type, end of Line 1 (TIN TYPE)

  1. This is a one-position field which must be edited if the Filer's TIN is an SSN, IRSN or an ITIN.

  2. Valid characters are " 0" (zero) and "blank" .

    Figure 3.21.261-6

    This image is too large to be displayed in the current screen. Please click the link to view the image.

    Editing the Tin Type Indicator

  3. If the TIN entered on Line 1 is either an SSN, IRSN or an ITIN (NNN-NN-NNNN format), edit a " 0" (zero) immediately to the right of the TIN.

    Note:

    The SSN that appears on Line 1 of Form 8288 must be the full SSN. However, the SSN that appears in the withholding agent box on Form 8288-A can be masked for security purposes. If masked on the Form 8288-A, the SSN will appear in the following format NNN-NN-_ _ _ _ so only the last 4-digits are present on the Form 8288-A. This does not apply to an ITIN, IRSN or EIN number.

  4. If the TIN entered on Line 1 is an EIN (NN-NNNNNNN format), no editing is required.

3.21.261.18.4  (01-01-2014)
Name Control -- Line 1, Row 1

  1. For filers other than individuals , the name control consists of the first four characters of the filer's (corporation, partnership, trust, etc.) name. See IRM 3.21.261.17.2 and Name Control Job Aid Document 7071 (IMF) or Document 7071A (BMF).

    Note:

    A Japanese Corporation is known as a "Kabushiki Kaisha" and should be moved to the end of the Corporation name if present at the beginning of the name line.

  2. For individuals, the name control consists of the first four letters of the filers LAST name.

  3. Valid characters are:

    • Alpha (a-z).

    • Numeric (0-9).

    • Blanks are valid only at the end of the name control.

  4. Do not include THE in the name control when " THE" is followed by more than one word.

  5. Underline the name control.

    If... Then...
    Multiple Transferees (buyers) are listed on Form 8288 Line 1 Underline first name control and cross out the other transferees (buyers) information that is not being used.

3.21.261.18.5  (01-01-2014)
Transferee (buyer) Address -- Line 1 (row 2 and 3)

  1. Address information for the Transferee (buyer) is provided on Line 1.

  2. Research return attachments to complete or perfect the information provided by the filer if it is incomplete or illegible. Valid characters are alpha (a-z) and numeric (0-9).

  3. Refer to the following subsections to perfect the address.

    See IRM 3.21.261.17.4
    See IRM 3.21.261.17.5
    See IRM 3.21.261.17.6
    See IRM 3.21.261.17.7

3.21.261.18.6  (01-01-2014)
Transferee (buyer)Telephone Number-- Line 1 (row 3)

  1. This is a 10 position field for which an entry may or may not be present.

  2. Valid characters are, "Numeric 0-9 " , and "blank."

  3. If present, underline the complete telephone number (include area code). A toll free number is considered to be a valid number to underline.

    Note:

    If the telephone number is incomplete, do not underline it.

    Exception:

    Do not underline a foreign international telephone number, which appears in a format other than (NNN-NNN-NNNN).

    Reminder:

    Whenever any information is missing on Form 8288 or Form 8288-A, and a valid telephone number is present, call the taxpayer for the information in lieu of corresponding for the information.

3.21.261.18.7  (01-01-2014)
Property Description (USRPI) -- Line 2

  1. This is a 35 position field (including blank spaces) for which an entry must be present.

  2. Valid characters are Alpha (a-z), Numeric (0-9), Hyphen (-) and Slash (/).

  3. Underline the description of the USRPI appearing on Line 2. The description of the USRPI should appear in the format of a street address. Do not include the City, State and ZIP Code.

    Example:

    2300 Rosebud St

    Example:

    Timeshare weeks 18-20, circle out 18-20 and edit and underline 18 19 20 so ISRP can transcribe "Timeshare 18 19 20" .

    Note:

    If the property description is not present look at the attached Form 8288-A, or the copy of the withholding certificate (if any) for property description.

    Caution:

    Do not edit "Kabushiki Kaisha" (KK) if it appears as part of the property description, unless there is no other description available. KK is the Japanese word for "Corporation."

    Figure 3.21.261-7

    This image is too large to be displayed in the current screen. Please click the link to view the image.

    Editing the U. S. Real Property Description

    If Then
    the property description is too lengthy underline the complete street address.
    the property description is not present on Form 8288, Line 2, edit the property description from the attached Form 8288-A (Box 5) or attachments.
    the property description is no where to be found on Form 8288 or Form 8288-A, See "Reminder." in IRM 3.21.261.18.6. Correspond (IDRS Letter 3104C) with the transferee (buyer) for the information.
    1. Prepare correspondence action sheet 3104C.

    2. Edit CCC "U" .

    no street address is present for the property description, but a technical description is present (e.g. Lot 52 of parcel 2534 in mahogany county) underline the technical description on Line 2 (at least 35 characters).

    Example:

    Lot 52 of parcel 2534 in Mahogany CO

    Note:

    A space and punctuations count as characters.

    the only thing present for the property description is the name of the county where the property is located, underline the county information of the property location on Line 2.

3.21.261.18.8  (01-01-2014)
Date of Transfer (DOT) -- Line 3

  1. This is an 8 position field for which an entry must be present.

  2. Valid characters are Numeric 0-9.

  3. Edit in MMDDYYYY format. Editing is required on EVERY RETURN.

    Note:

    If the DOT on Line 3 is not in MMDDYYYY format, then circle out the incorrect DOT format in red ink and edit the DOT in the correct format on Line 3 using red ink.

  4. Will I ever have to edit a different DOT from what the taxpayer entered? Yes, you need to verify the DOT on Line 3 if the taxpayer attaches a withholding certificate to Form 8288.

    Why? The date on the withholding certificate (whether it is an approved or rejected certificate) becomes the NEW DOT to enter on Line 3 (Part I or II). The following table list the letter numbers of the withholding certificate.

    Withholding Certificate Letter Numbers
    • Letter 3307(SC/CG) Withholding Certificate - Approved Exempt

    • Letter 3308(SC/CG) Withholding Certificate - Approved Reduced

    • Letter 3309(SC/CG) Withholding Certificate - Approved Exempt

    • Letter 3310(SC/CG) Withholding Certificate - Approved Reduced

    • Letter 3311(SC/CG) Withholding Certificate - Approved Reduced

    • Letter 3497(SC/CG) Withholding Certificate - Approved Reduced

    • Letter 3312(SC/CG) Withholding Certificate - Approved Installment Plan

      Caution:

      Whenever Letter 3312 is attached the new DOT to edit will consist of the same Month and Day as on the letter, but with the current year (e.g. March 29, 2008 edit 03/29/2012). Do not edit a reduced withholding or bypass indicator.

      Example:

      Installment W/H Certificate is issued March 2, 2009, of which 10 percent ($2,275.00 x 10% = $227.50) FIRPTA tax is to be paid on the initial USRPI installment transfer. Subsequent installment transfer may take place on 03/02/2011 ($3,310.00 x 10% = $331.00), which means the tax period is 201103 and not 200903. The RDD would be 03/26/2011. As long as it is timely filed, no penalties or interest will be charged.

    • Letter 3313(SC/CG) Withholding Certificate - Disapproved Reject

    • Letter 3314(SC/CG) Withholding Certificate - Disapproved Reject

    • Letter 3315(SC/CG) Withholding Certificate - Filed Late Rejected

    • Letter 3316(SC/CG) Withholding Certificate - Disapproved Reject

    • Letter 3318(SC/CG) Withholding Certificate - Filed Late Rejected

  5. What do I do if a Withholding Certificate is attached? If a withholding certificate (approved or rejected) is attached, then the date on the withholding certificate letter is considered to be the "NEW Date of Transfer." Circle in RED the incorrect DOT on both the Form 8288 (line 3) and Form 8288-A (box 1), and EDIT the NEW corrected withholding certificate letter date on the Form 8288 (Line 3) and Form 8288-A (Box 1). However, if no withholding certificate is attached, do not change the DOT.

    Reminder:

    Do not forget to edit/assign the reduced withholding and bypass indicator "1" when one of the six"Approved" certificates are attached to Form 8288. See IRM 3.21.261.18.11 and IRM 3.21.261.18.12

  6. The tax period for a Form 8288 is based on the Month and Year of the Date of Transfer, found on Line 3 (Part I or II). See IRM 3.21.261.18.1

    Example:

    If the DOT is 01/07/2013, then the tax period will be 201301.

  7. The initial tax period being processed to the BMF under MFT 17 is tax period ending 12/31/2005. This tax period will be valid for any Form 8288 reflecting a Date of Transfer of 12/13/2005, or subsequent.

    Note:

    Form 8288 is due to the IRS by the 20th day from the DOT and the same transferee (buyer) withholding agent may file one or more Form 8288 in a month, or in every month of the year.

  8. If the Date of Transfer is not present on Line 3 or the DOT is a future date, then research the attached Form 8288-A, or other documents (settlement statement if present) for the date of transfer.

  9. If the DOT or correct DOT cannot be found and you do not have a telephone number for the transferee (buyer), then correspond (CAS 3104C) with the transferee (buyer) (withholding agent) for the DOT. If a telephone number is found call the taxpayer for the DOT.

    1. Prepare correspondence action sheet 3104C to request the DOT.

    2. Edit CCC "U."

    3. Edit the "Default DOT" only on copy B of Form 8288-A so that it can be entered in the INTL WebApps

      Note:

      The Default DOT is the first day of the month prior to the IRS received date on Form 8288.

      Example:

      The IRS received date is 09-19-2012, edit 08-01-2012 as the default DOT.

  10. If Form 8288 and Form 8288-A show different dates of transfers, then "line through" the DOT on Form 8288-A and edit the DOT from Form 8288 above it.

3.21.261.18.9  (01-01-2014)
Number of 8288-As filed -- Line 4

  1. This is a 3 position field for which an entry must be present.

  2. Valid characters are, Numeric 0-9. If count is written in alpha characters, change it to a numeric number. Maximum number to enter is "999."

  3. If entry is legible, accept as is.

    Exception:

    If the transferee (buyer) did not provide an Form 8288-A for each transferor (seller), and you have to create a set or sets of Form 8288-A for each transferor, then edit the correct number of Form 8288-A on Line 4.

  4. If the entry is not legible, or missing, or the counts don't match then check the Form 8288-A to see how many people are listed as the transferor (foreign seller) in the "Name of Person subject to withholding block" , and edit that count on Line 4.

  5. If you are unable to locate a "# of Form 8288-A filed" count on the document and its attachment, then edit the default number of "1" on Line 4 of Form 8288.

    Reminder:

    Correspond with the taxpayer using IDRS Letter 3104C, when the number of Form 8288-As shown on Line 4 of Form 8288, are not attached to the Form 8288, and/or the amounts from box 2, Form 8288-A do not add up to the amount shown on Line 7, and/or the amounts from box 3 or 4, Form 8288-A do not add up to the amount shown on Line 5.

3.21.261.18.10  (01-01-2014)
Amount Realized (Part I) -- Line 5 or Amount Subject to Withholding (Part II) -- Line 5a or 5b

  1. This is a 12 position field for which an entry must be present on Line 5, Part I, or Part II Line 5a or 5b of Form 8288. Only one entry is allowed in Part II, Line 5a or 5b.

  2. Valid characters are Numeric 0-9.

  3. The entry in Part I, Line 5 or Part II Line 5a, or 5b cannot be a negative entry.

    Reminder:

    Don't forget to edit your Part Number and the CCC X in the left margin next to Line 1.

  4. If Part I is completed, and Line 5 is blank, research the attached Form 8288-A for the amount realized. The amount realized can be found in box 3 of Form 8288-A, or the withholding certificate (if any). Edit this amount to Line 5.

  5. If Part II is completed, and Line 5a or 5b is blank, research the attached Form 8288-A for the recognized gain or amount realized amount. The recognized gain is located in box 4 and the amount realized in box 3 of Form 8288-A . Edit the gain amount to Line 5a and the amount realized to Line 5b.

  6. If you are unable to locate the "Amount Realized or the Amount Subject to Withholding" on Form 8288 or Form 8288-A or any other attachments, edit CCC "U" and prepare correspondence action sheet Letter 3104C to correspond for the missing information.

    Note:

    Before editing CCC "U" and corresponding, research Form 8288 and attachments for taxpayers phone number. If found call the taxpayer to obtain the amount realized

    .

3.21.261.18.11  (01-01-2014)
Reduced Withholding Amount -- Line 6b (Part I) or Line 5c (Part II)

  1. This is a 1 position field for which an entry may or may not be present.

  2. Valid characters are:

    • "1" = withholding certificate attached (See withholding certificate chart).

      Reminder:

      Edit the reduced withholding and bypass indicator "1" when one of the six"Approved" certificates are attached to Form 8288:

      Withholding Certificate Letter Numbers
      • Letter 3307(SC/CG) - Approved Exempt

      • Letter 3308(SC/CG) - Approved Reduced

      • Letter 3309(SC/CG) - Approved Exempt

      • Letter 3310(SC/CG) - Approved Reduced

      • Letter 3311(SC/CG) - Approved Reduced

      • Letter 3497(SC/CG) - Approved Reduced

      • Letter 3312(SC/CG) - Approved Installment Plan

        Caution:

        Whenever Letter 3312 is attached the new DOT to edit will be according to the date of payment. (e.g. payment date is April 1 2014 then DOT to edit would be 04012014 and the tax period to use would be 201404).

        Example:

        Installment W/H Certificate is issued March 2, 2010, of which 10% ($2,275.00 x 10% = $227.50) FIRPTA tax is to be paid on the initial USRPI installment transfer. Subsequent installment transfer may take place on 03/02/2013 ($3,310.00 x 10% = $331.00), which means the tax period is 201303 and not 200903. The RDD would be 03/19/2013. As long as it is timely filed, no penalties or interest will be charged.

      Otherwise, do not edit anything. The tax will be assessed at the full 10 percent or 35 percent amount for the rejected letters.

    • "blank" = withholding certificate not attached or required.

  3. Reduced Withholding when Form 8288 Part I is completed:

    If Then
    Line 6b checkbox is checked,
    1. Verify that an approved withholding certificate is attached. See withholding certificate letter number table in paragraph (2).

    2. If attached, edit reduced withholding indicator " 1" in the middle of Line 6b. See Exhibit 3.21.261-1.

      Note:

      If no withholding certificate is attached, circle (in red ink) the checkbox on Line 6b.

    Line 6b checkbox is not checked, but a withholding certificate is attached,
    1. Edit a red check mark inside the checkbox.

    2. Edit reduced withholding indicator "1" in the middle of Line 6b.

    Line 6b checkbox is checked, but no withholding certificate is attached, Circle (in red ink) the checkbox on Line 6b.

    Note:

    Do not edit a reduced withholding indicator.

    Line 6b checkbox is checked, and withholding certificate Letter 3312 is attached, Circle (in red ink) the checkbox on Line 6b.

    Note:

    Do not edit a reduced withholding indicator.

    Line 6b checkbox is not checked, and withholding certificate Letter 3312 (Installment Cert) is attached, Do not edit a reduced withholding indicator.

  4. Reduced Withholding when Form 8288 Part II is completed:

    If Then
    Line 5c is significant (an entry is present),
    1. Verify that an approved withholding certificate is attached. See withholding certificate letter number table in paragraph (2).

    2. If attached, edit reduced withholding indicator " 1" in the middle of Line 5c. See Exhibit 3.21.261-1.

      Note:

      If no withholding certificate is attached, arrow up the amount (in red ink) to Line 5b. However, if the checkbox on Line 5d is marked, then arrow up the amount to Line 5a.

    Line 5c is blank, but a withholding certificate is attached and the amount appears on Line 5a or 5b,

    Note:

    If no amount appears on lines 5a, 5b or 5c, then look at the Form 8288-A (box 3 or 4) for the amount realized or gain, and edit it on line 5c.

    1. Arrow down (in red) the amount to Line 5c.

    2. Edit reduced withholding indicator "1" in the middle of Line 5c.

    Line 5c is significant, but no withholding certificate is attached,
    • If no withholding certificate is attached, arrow up the amount (in red ink) to Line 5b.

      Note:

      Do not edit a reduced withholding indicator.

    • Arrow up (in red ink) the amount to Line 5a when Line 5d is marked.

      Note:

      Do not edit a reduced withholding indicator.

    Line 5c is significant, and withholding certificate Letter 3312 is attached, Arrow up the amount (in red ink) to Line 5b.

    Note:

    Do not edit a reduced withholding indicator.

    Line 5c is not significant, and withholding certificate Letter 3312 (Installment Cert) is attached, Do not edit a reduced withholding indicator.

    Reminder:

    DO NOT FORGET TO EDIT THE CORRECT DATE OF TRANSFER ON FORM 8288 LINE 3 AND FORM 8288-A LINE 1, IF A W/H CERTIFICATE IS ATTACHED. See IRM 3.21.261.18.8

3.21.261.18.12  (01-01-2014)
Bypass Indicator (BPI)

  1. This is a 1 position field for which an entry may or may not be present.

  2. The valid characters are 1 and Blank.

  3. The BPI is edited in the outside right margin of Part I, Line 5, or, is edited in the outside right margin of Part II, Line 6.

    Reminder:

    Always edit a Bypass Indicator "1" whenever you edit a reduced withholding indicator "1." Therefore, if no reduced withholding indicator is being edited, then no bypass indicator is to be edited.

  4. Definition:

    • "1" -- tax is less than 10 percent and a reduced withholding certificate is attached. No Math Error.

    • "1" -- tax is less than 35 percent and a reduced withholding certificate is attached. No Math Error.

    • "Blank" -- computer will systemically calculate the tax at 10 percent of the amount realized present in Part I Line 5, or Part II Line 5b.

      Exception:

      Do not edit a bypass indicator on Installment Sales Withholding Certificate Letter 3312 (SC/CG).

    • "Blank" -- computer will systemically calculate the tax at 35 percent of the amount subject to withholding present in Part II Line 5c.

    If Then
    Tax is at 10 percent.

    Note:

    No withholding certificate is attached.

    Leave BPI "blank"
    Tax is at 35 percent.

    Note:

    No withholding certificate is attached.

    Leave BPI "blank"
    Tax is less than 10 percent and a reduced withholding certificate is attached.

    Note:

    Part I Line 6b is checked, or has been checked by C and E.

    Edit a BPI "1"
    Tax is less than 35 percent and a reduced withholding certificate is attached.

    Note:

    Part II Line 5c is significant, or C and E has arrowed the amount to line 5c.

    Edit a BPI "1"
    Tax is less than 10 percent and no reduced withholding certificate is attached. Leave BPI "blank"
    Tax is less than 35 percent and no reduced withholding certificate is attached. Leave BPI "blank"

    Figure 3.21.261-8a

    This image is too large to be displayed in the current screen. Please click the link to view the image.

    Usage of Bypass and Reduced Withholding Indicator -- Substantiated

    Figure 3.21.261-8b

    This image is too large to be displayed in the current screen. Please click the link to view the image.

    No Withholding Certificate -- Not Substantiated

    Figure 3.21.261-8c

    This image is too large to be displayed in the current screen. Please click the link to view the image.

    Sample of a Reduced Withholding Certificate

3.21.261.18.13  (01-01-2014)
Total Tax -- Line 7, Part I or Line 6, Part II

  1. This is a 12 position field for which an entry must be present.

  2. Valid characters are, Numeric 0-9.

  3. The total tax line cannot be negative.

  4. If Form 8288, Part I is completed then Line 7, of Part I must be 10 percent of the amount on Line 5, unless a withholding certificate is attached (Line 6b). A withholding certificate reduces the 10 percent tax to an amount less than 10 percent (including "0" ).

    FIRPTA Tax Discrepancy - Part I

    If... And... Then...
    Line 7 is less than 10 percent of Line 5, Line 6b is "checked" or has been edited by C&E, A reduced withholding certificate is attached. See IRM 3.21.261.18.11 to edit a reduced withholding indicator and IRM 3.21.261.18.12 to edit a BPI.
    No reduced withholding certificate is attached Line 7 is less than 10 percent,
    1. If Line 6b is checked, Circle out the checkbox. Otherwise, do nothing.

    2. Do not edit a reduced withholding or Bypass Indicator so the computer can compute the tax at 10 percent.

    Line 6b is blank a withholding certificate is attached to Form 8288
    1. Edit the reduced withholding indicator "1" in the middle of Line 6b and edit a check mark in the checkbox.

    2. Edit the BPI "1" in the right outside margin of Line 7.

  5. If the entry is incorrect or not legible, do the following:

    1. Place a red "X" to the left of the incorrect entry.

    2. Write the correct entry (found on the withholding certificate, if any, towards the middle of the 2nd paragraph) to the left of the incorrect entry of Line 7, Part I.

  6. If Form 8288, Part II is completed then Line 6, of Part II must be either 10 percent of the amount on Line 5b, or 35 percent of the amount of Line 5a, unless a withholding certificate is attached (Line 5c is significant or C&E has arrowed the amount to line 5c). A withholding certificate reduces the 10 percent or 35 percent tax to an amount less than 10 percent or 35 percent (including "0" ).

    FIRPTA Tax Discrepancy - Part II

    If... And... Then...
    If Line 6 is less than 10 percent or 35 percent of the amount on line 5c, A reduced withholding certificate is attached. Edit a reduced withholding indicator ( See IRM 3.21.261.18.11) and edit a BPI. (Also see IRM 3.21.261.18.12.)
    No reduced withholding certificate is attached Line 6 is less than
    • 10 percent of line 5b, or

    • 35 percent of line 5a, or

    • a significant amount appears on line 5c.

    1. If Line 5c is significant, "arrow up" the amount to line 5b. Or, Arrow up (in red ink) the amount to Line 5a when Line 5d is marked.

    2. Do not edit a reduced withholding or Bypass Indicator so the computer can compute the tax at 10 percent or 35 percent.

    Line 5c is blank a withholding certificate is attached to Form 8288 and C&E has arrowed down the amount to line 5c
    1. Edit the reduced withholding indicator "1" in the middle of Line 5d, and

    2. Edit the BPI "1" in the right outside margin of Line 6.

  7. If the entry is incorrect or not legible, do the following:

    1. Place a red "X" to the left of the incorrect entry.

    2. Write the correct entry (found on the withholding certificate, if any, towards the middle of the 2nd paragraph) to the left of the incorrect entry of Line 6, Part II.

3.21.261.18.14  (01-01-2014)
Large Trust Election -- Line 5d, Part II

  1. This is a 1 position field for which an entry may or may not be present.

  2. No editing is necessary. ISRP will enter "1" if checkbox is checked.

  3. If the checkbox on Line 5d is marked, and a significant entry appears on Line 5c, but there is no withholding certificate attached, then arrow up the entry from line 5c to line 5a.

    Note:

    Large trust elections have over 100 people and are taxed at a 35 percent rate.

3.21.261.18.15  (01-01-2014)
♦Signature♦

  1. A signature (withholding agent/transferee (buyer), partner, fiduciary, or corporate officer) and jurat is required for all returns except the following:

    Note:

    If a signature does not appear on the designated line for the taxpayer's signature, follow the procedures in the "If/Then" table below.

    • Returns prepared under IRC § 6020(b). These returns must be signed by a Compliance Function Representative. See IRM 3.21.261.8.2 .

    • Returns prepared by Examination, for example SFR (Substitute for Return) or "SUBSTITUTE RETURN" .

      Note:

      Returns secured by Examination do require a signature and jurat. See IRM 3.21.261.8.5.

    • Dummy returns prepared by IRS.

    • Returns filed under IRC § 501(d) (Religious or Apostolic Organization).

    • Correspondence containing a signature and jurat is attached showing that the taxpayer is responding to an IRS letter or notice.

    • Re-entry returns originally filed electronically (E-File). These returns may be identified by the presence of Mode E-File printouts or "TRPRT Print Do Not Process" in lieu of an actual return.

      Note:

      If the TRPRT print states "TRPRT Print Do Not Process" in the top margin, circle the words "Do Not Process."

  2. Do not correspond for a signature on "CIS" returns that have Form 13596 attached. See IRM 3.21.261.9.1 Correspondence Imaging System (CIS) Returns, for processing instructions.

  3. If a signature is missing and:

    If... Then...
    The return is not signed on the line designated for the taxpayer's signature,
    1. Correspond using an approved correspondence action sheet.

    2. Edit CCC "U" if corresponding for signature only.

    3. Leave in batch and continue editing.

    The jurat is not present on the line designated for the taxpayer's signature (non-standard return),
    1. Correspond using an approved correspondence action sheet.

    2. Edit CCC "U" if corresponding for signature only.

    3. Leave in batch and continue editing.

  4. Follow the instructions in paragraph (3) above, when the Entity information is the only thing present on the form, and there are no attachments containing tax data.

    Note:

    Use Form 3696, or other approved Correspondence Action Sheet, for "Secured" or delinquent returns.

  5. If the jurat is altered or stricken (crossed-out), it may be a frivolous return. See IRM 4.10.12.1.1, Frivolous Arguments for potential frivolous arguments that must be referred to the Ogden Compliance Campus Examination Frivolous Return Program. Also see IRM 3.21.261.8.6 and/or Exhibit 3.21.261-6 .

  6. Accept a "signature declaration" (a signature with jurat obtained through IRS correspondence) if attached to the return.

    1. If the "signature declaration" is altered or stricken (crossed out), See IRM 4.10.12.1.1 for potential frivolous arguments that must be referred to the Ogden Compliance Campus Examination Frivolous Return Program. Also see IRM 3.21.261.8.6 and/or Exhibit 3.21.261-6 .

    2. If the taxpayer responds with a self-prepared "signature declaration" it must contain the same language as the jurat on the tax return; e.g. "UNDER PENALTIES OF PERJURY, I DECLARE THAT I HAVE EXAMINED THIS RETURN, INCLUDING ACCOMPANYING SCHEDULES AND STATEMENTS, AND TO THE BEST OF MY KNOWLEDGE AND BELIEF, IT IS TRUE, CORRECT AND COMPLETE."

  7. Since tax examiners are not expected to be handwriting experts, Section 301.6064-1 of the Regulations allows the service to presume that the signature on a return, statement or other document is the true signature of the person who actually signed the document.

    Note:

    A check mark or "X" used to designate where the taxpayer should sign the return is not considered a valid signature.

  8. Only one correspondence attempt is required for a signature. If you do not receive a reply after the prescribed suspense period, edit as follows:

    If... Then...
    The return has an overpaid condition or it is a Form 8288, Edit CCC "3" and CCC "X" and continue processing.
    The return is a balance due or zero condition, Edit CCC "3" and continue processing.

3.21.261.18.16  (01-01-2014)
♦Preparer Signature♦

  1. A signature may or may not be present; do not correspond if not present.

  2. Do not correspond for a missing signature on any return prepared by a Compliance function.

  3. Do not question any signature on the return. Internal Revenue (IR) Regulations Section 301.6064-1 allows the Service to presume that the signature on the return, statement or other document is the true signature of the person who actually signed the document.

  4. A constructive signature (that is, a signature on an accompanying check, letter, etc.) is not acceptable unless the signature follows a perjury statement containing the same language as the jurat of the tax return.

3.21.261.18.17  (01-01-2014)
♦Preparer's EIN or PTIN♦

  1. ISRP will transcribe the entry. The Preparer Tax Identification Number (PTIN) is located to the right of the Preparer's Signature at the bottom of Form 8288.

    Reminder:

    If the return is for 2009 or prior, then the PTIN box will be named Preparer's SSN or PTIN.

  2. A Preparer Tax Identification Number (PTIN) is a valid entry in the Preparer's PTIN area at the bottom of Form 8288. The PTIN is nine-digits beginning with the alpha "P" (e.g., PXXXXXXXX). and followed by eight numbers

  3. Valid characters are numeric (0-9) and alpha "P" only.

  4. If the entry in the PTIN area is an invalid number, or does not begin with a "P," , or is an SSN number, then circle-out the number.

    Caution:

    If the return is for 2009 or prior, and the entry on the line is an SSN number, do not circle it. Instead, remember to edit the TIN TYPE indicator.

  5. The Preparer's EIN must be a nine-digit numeric number. The EIN is entered in NN-NNNNNNN format. The EIN cannot be all zeroes or all nines.

  6. Circle the EIN if all zeroes or all nines

3.21.261.18.18  (01-01-2014)
Preparer's TIN TYPE

  1. If the Preparer's TIN is a PTIN, edit a "0" (zero) immediately to the right of it.

3.21.261.19  (01-01-2014)
NMF FIRPTA Form 8288 Penalty and Interest Assessment

  1. All Form 8288 returns with a Date of Transfer (DOT) prior to 12/13/2005 must be transshipped to the Cincinnati Submission Processing Campus (CSPC) for processing to the Automated Non Master File (ANMF) system. Once the return has been numbered accounting will coordinate with OSPC.

  2. CSPC NMF Accounting will fax Form 8288 and Form 8288-A to OSPC for recordation into the FIRPTA portion of the International Web Applications (INTL WebApps).

  3. Upon receipt of the fax from CSPC, OSPC will perform the following steps in the FIRPTA database portion of the INTL WebApps within 2 days of receipt.

    Caution:

    Review Form 8288 to see if it is an Installment Sales Return. If the return is an installment sales return, inform CSPC NMF accounting to transship the return to OSPC for BMF processing and take no further action. If it is not an installment sales return, continue with the following steps.

    1. Select Menu Option 2 "Form 8288 or Form 8288-A."

    2. Enter the Form 8288 data into the database (first screen).

    3. Document the generated penalty calculations (FTF and FTP) on Form 8288.

    4. Depress the Form 8288-A button and enter the Form 8288-A data into the database.

    5. Mail out Form 8288-A Copy B to the foreign taxpayer along with Quick Note 3296 SC/CG.

  4. The C&E FIRPTA unit will fax the Form 8288 to Ogden AM so they can calculate the interest assessment. Ogden AM will document the interest on Form 8288 and fax the Form 8288 with the penalty and interest calculations back to CSPC NMF Accounting for continued processing.

    Note:

    For assistance contact the Ogden AM Planning and Analysis (P&A) Staff Analyst on ext. 5214.

Exhibit 3.21.261-1 
Form 8288 "T" Lines Definition -- Part I

Exhibit3.21.261-1Form 8288 T Lines -- Part I
This image is too large to be displayed in the current screen. Please click the link to view the image.

Exhibit 3.21.261-2 
Form 8288 "T" Lines Definition -- Part II

Exhibit3.21.261-2Form 8288 T Lines -- Part II
This image is too large to be displayed in the current screen. Please click the link to view the image.

Exhibit 3.21.261-3 
Form 8288-A, "Statement of Withholding on Dispositions by Foreign Persons of U.S. Real Property Interests"

Exhibit3.21.261-3Form 8288-A, Statement of Withholding on Dispositions by Foreign Persons of U.S. Real Property Interests
This image is too large to be displayed in the current screen. Please click the link to view the image.

Exhibit 3.21.261-4 
Computer Condition Codes (CCC) -- Form 8288

Exhibit3.21.261-4Computer Condition Codes
Codes Explanation
D See IRM 3.21.261.16 (4) When reasonable cause exist for waiver of the failure to pay penalty.

Note:

Edit CCC "D" if the FTP box on Form 13596 is checked.

O A pre-settlement manual refund was paid.
R See IRM 3.21.261.16 (6) To indicate a delinquent return with reasonable cause. Do not assess a failure to file penalty (FTF).

Note:

Edit CCC "R" if the FTF box on Form 13596 is checked.

U Unprocessable Return:
a. to reject unprocessable return.
b. to issue a manual refund over $1 million
c. See IRM 3.21.261.13
W Return has been cleared by Statutes.
X Excess remittance with return or overpayment be applied to another account.

Note:

This code is used when it has been determined that an excess remittance should be applied to a different tax class or module (period). The CCC "X" will freeze the tax module from refunding or offsetting any monies by generating a TC 570 .00.

3 No Reply to Correspondence:
To bypass validation of the correspondence received date when the taxpayer fails to reply to IRS-generated correspondence.
4 Return is notated "Prepared under IRC § 6020(b)"
7 See IRM 3.21.261.16 (12) When denying the reasonable cause explanation for filing and paying late.

Caution:

When using " CCC 7" do not use "CCC D or R"

Exhibit 3.21.261-5 
♦U.S. Possessions ZIP Codes♦

Exhibit3.21.261-5♦U.S. Possessions ZIP Codes♦
American Samoa (AS)
City ZIP Code   City ZIP Code
Faga'itua 96799   Olosega Manua' 96799
Leone 96799 Pago Pago 96799
Federated States of Micronesia (FM)
City ZIP Code   City ZIP Code
Chuuk 96942   Pohnpei 96941
Kosrae 96944 Yap 96943
Guam (GU)
City ZIP Code   City ZIP Code
Agana 96910   Tamuning 96931
Inarajan 96917 Umatac 96915
Merizo 96916 Yona 96915
Marshall Islands (MH)
City ZIP Code   City ZIP Code
Ebeye 96970   Majuro 96960
Northern Mariana Islands (MP)
City ZIP Code   City ZIP Code
Capitol Hill 96950   Saipan 96950
Rota 96951 Tinian 96952
Palau (PW)
City ZIP Code   City ZIP Code
Koror 96940   Palau 96940
Puerto Rico (PR)
City ZIP Code   City ZIP Code
Adjuntas 00601   La Plata 00786
Aguada 00602 Lares 00669
Aguadilla 00603 Las Marias 00670
Aguas Buenas 00703 Las Piedras 00771
Aguirre 00704 Levittown 00950
Aibonito 00705 Loiza 00772
Anasco 00610 Loiza Street Station 00936
Angeles 00611 Luquillo 00773
Arecibo 00612 Manati 00674
Arroyo 00714 Maricao 00606
Bajadero 00616 Maunabo 00707
Barceloneta 00617 Mayaguez 00680
Barranquitas 00794 Mercedita 00715
Bo Obrero 00935 Minillas 00940
Bayamon 00956 Moca 00676
Boqueron 00622 Morovis 00687
Cabo Rojo 00623 Naguabo 00718
Caguas 00725 Naranjito 00719
Camuy 00627 Orocovis 00720
Canovanas 00729 Palmer 00721
Caparra Heights 00920 - 00922 Patillas 00723
Carolina 00979 - 00987 Penuelas 00624
Catano 00962 Ponce 00731
Cayey 00736 Puerta de Tierra 00906
Ceiba 00735 Puerta Real 00740
Ciales 00638 Quebradillas 00678
Coamo 00769 Rincon 00677
Comerio 00782 Rio Blanco 00744
Corozal 00783 Rio Piedras 00925, 00927, 00928
Coto Laurel 00780 Rosario 00636
Culebra 00775 Sabana Grande 00637
Dorado 00646 Sabana Hoyos 00688
Ensenada 00647 Sabana Seca 00952
Fajardo 00738 Salinas 00751
Fernandez Juncos 00909 - 00910 San Antonio 00690
Fort Buchanan 00934 San German 00683
Garrochales 00652 San Juan 00936
Guanica 00653 San Lorenzo 00754
Guayama 00784 San Sebastian 00685
Guayanilla 00656 Santa Isabel 00757
Guaynabo 00965 - 00971 Santurce 00907 - 00908
Gurabo 00778 Toa Alta 00953
Hatillo 00659 Toa Boa 00949
Hato Rey Station 00917 - 00919 Trujillo Alto 00976
Humacao 00791 Utuado 00641
Isabela 00662 Vega Alta 00692
Jayuya 00664 Vega Baja (box 1-9049) 00694
Juana Diaz 00795 Vieques 00765
Juncos 00777 Villalba 00766
Lajas 00667 Yabucoa 00767
    Yauco 00698
Virgin Islands - U.S. (VI - Entity Section) (VQ - Other than Entity Section)
City ZIP Code   City ZIP Code
Charlotte Amalie 00802   Saint Croix 00820
Christiansted 00820 Saint John 00830
Cruz Bay 00830 Saint Thomas 00805
Downtown 00840 Sunny Isle 00850
Frederiksted 00840 Veterans Annex 00820
Kingshill 00850      

Exhibit 3.21.261-6 
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

Exhibit3.21.261-6♦Frivolous Arguments Criteria♦
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≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ "≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ "
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ "≡ ≡ ≡ " ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ "≡ ≡ ≡ ≡ ≡ ≡ ≡ " ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ "≡ ≡ ≡ ≡ ≡ " ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ "≡ ≡ ≡ ≡ " ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ "≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ " ≡ ≡ ≡ "≡ ≡ ≡ ≡ ≡ ≡ " ≡ ≡ ≡

Note:

≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ "≡ ≡ ≡ ≡ ≡ " ≡ ≡ "≡ ≡ ≡ ≡ ≡ ≡ ≡ " ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

Note:

≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ "≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ " ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

≡ ≡

Exhibit 3.21.261-7 
Form 4442

Exhibit3.21.261-7Form4442
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