7.2.1  Closing Agreements Originating in EP Technical

Manual Transmittal

August 27, 2015

Purpose

(1) This transmits revised IRM 7.2.1, TE/GE Closing Agreements, Closing Agreements Originating in EP Technical.

Background

IRM 7.2.1 provides guidelines for closing agreements originating in the EP Technical function under the Office of the Director, Employee Plans Rulings & Agreements, Tax Exempt and Government Entities Division (TE/GE).

Material Changes

(1) In this revision of IRM 7.2.1, the content was significantly rearranged and updated for clarity. Since the changes were significant, the subsection dates were only changed where the content changes were substantive.

(2) Updated this IRM to reflect the transfer of ruling responsibilities (except for some closing agreements) from Tax Exempt and Government Entities to Division Counsel or Associate Chief Counsel, as appropriate.

(3) IRM 7.2.1.3.3, Processing Rulings Accompanied by Closing Agreement Requests. Updated the annually revised Rev. Proc. number.

(4) IRM 7.2.1.4.2, Preparing for Negotiations. Updated and clarified to include procedures for calculating the sanction.

(5) IRM 7.2.1.4.3, Information Exchange at Negotiations. Updated and clarified the pre-negotiation procedures.

(6) IRM 7.2.1.4.4, Bargaining Over Terms of Closing Agreement. Updated to include the requirement to discuss sanction amount with group manager.

(7) IRM 7.2.1.5, Drafting and Processing Closing Agreements. Updated and clarified the procedures including adding a requirement to contact Chief Counsel.

(8) IRM 7.2.1.7, Procedures for Executed Closing Agreements, clarified check mailing procedures.

(9) IRM 7.2.1.8, Processing Remittances, clarified check mailing procedures.

(10) IRM 7.2.1.9, Modification of Closing Agreement. Updated and clarified the rules for determining when a closing agreement becomes final.

(11) Exhibit 7.2.1-1, Closing Agreement on Final Determination Covering Specific Matters. Updated to include revisions to the closing agreement statement.

(12) IRM 7.2.1.10, Modification of Closing Agreements. Updated and clarified adding a reference to Policy Statement P-4-3. Exhibit 7.2.1-1, Closing Agreement on Final Determination Covering Specific Matters. Updated and clarified the closing agreement language.

(13) Edited this IRM for plain language.

Effect on Other Documents

This document supersedes IRM 7.2.1 dated September 17, 2014.

Audience

Tax Exempt and Government Employees
Employee Plans
Technical Employees

Effective Date

(08-27-2015)

Robert S. Choi
Director, Employee Plans
Tax Exempt and Government Entities

7.2.1.1  (09-17-2014)
Overview

  1. The specific procedures in this IRM 7.2.1 apply only to closing agreements originating in the office of the Manager, Employee Plans (EP) Technical, Tax Exempt and Government Entities Division (TE/GE).

  2. See these other IRMs for other closing agreement procedures for all EP employees:

    1. Procedures relating to closing agreements entered into under the Employee Plans Compliance Resolution System (EPCRS). See IRM 7.2.2, Employee Plans Compliance Resolution System (EPCRS).

    2. Procedures relating to closing agreements under the Employee Plans Determination Letter Program. See IRM 7.11.8, EP Determinations Closing Agreement Program.

    3. Procedures relating to closing agreements entered into in connection with an unagreed Form 5500, Annual Return/Report of Employee Benefit Plan, return examination. See IRM 4.71.3, Employee Plans Examination of Returns, Unagreed Form 5500 Examination Procedures and Delegation Order 8-3 (DO 8-3) Closing Agreements.

    4. Procedures relating to closing agreements entered into in connection with a Form 5330, Return of Excise Taxes Related to Employee Benefit Plans, examination with respect to excise taxes. See IRM 4.71.5, Employee Plans Examination of Returns - Form 5330 Examinations.

  3. EP uses closing agreements when we can’t satisfactorily resolve cases using other existing and available standard procedures. This IRM explains:

    • Authority for closing agreements.

    • When a closing agreement is appropriate.

    • The difference between a single and mass closing agreement.

    • How to obtain approval to pursue a closing agreement.

    • How to negotiate a closing agreement.

    • How to draft and process a closing agreement.

    • How to obtain proper signatures for a closing agreement.

    • How to process remittances under a closing agreement.

    • How to set aside or clarify a closing agreement.

7.2.1.2  (09-17-2014)
Authority for Closing Agreements

  1. The IRS Commissioner may enter into and approve a written closing agreement with any person relating to the liability of such person with respect to any internal revenue tax for any taxable period ending prior or subsequent to the date of such an agreement (IRC 7121 and regulations).

    • The Commissioner delegates to the Commissioner, Tax Exempt and Government Entities Division (TE/GE) in cases under his or her jurisdiction to enter into and approve a written agreement with any person relating to the internal revenue tax liability of such person, or the person or estates for whom he or she acts (Delegation Order 8-3, IRM 1.2.47.4).

    • This authority to enter into a closing agreement is further delegated to the Director, Employee Plans and the Director, EP Rulings and Agreements (EP R&A). The authority delegated does not, however, include the authority to set aside any closing agreement, which is retained by the Commissioner (see IRM 7.2.1.10Modification of Closing Agreements, below).

7.2.1.3  (09-17-2014)
Entering Into Closing Agreements

  1. A closing agreement may be appropriate when the interests of the Government will be served by having the case permanently and conclusively closed, and no other method is adequate for such result. This may occur, for example:

    1. When there is ambiguity regarding a technical matter and no specific treatment is the only reasonable outcome given the facts.

    2. Upon a taxpayer’s request, a showing of good and sufficient reasons for desiring a closing agreement and it is determined that the interests of the Government will not be prejudiced.

  2. Do not use a closing agreement to:

    1. Circumvent a tax liability, regardless of the type or amount of tax.

    2. Allow a taxpayer to just reduce the amount of a tax or penalty.

    3. Bypass an existing standard procedure (e.g., IRC 7805(b) relief).

7.2.1.3.1  (09-17-2014)
Single Versus Mass Closing Agreements

  1. Closing agreements involving the same issue may impact a single taxpayer or a number of taxpayers.

    1. In single taxpayer cases, a taxpayer may request closing agreements for up to and including 25 taxpayers. See IRM 7.2.1.4, Obtaining Approval to Pursue a Closing Agreement.

    2. If the issues and holdings are identical for all of the taxpayers and there are more than 25, then use the procedure for a "Mass Closing Agreement." See IRM 7.2.1.3.2, Mass Closing Agreements.

7.2.1.3.2  (09-17-2014)
Mass Closing Agreements

  1. The "Mass Closing Agreement" is a closing agreement in which one agreement is prepared on behalf of a group of taxpayers. It’s similar to a single taxpayer closing agreement except that the first paragraph doesn’t typically contain the names, addresses and EINs of all parties to the agreement.

  2. The names and addresses of the taxpayers who are to authorize the principal taxpayer to execute the agreement on their behalf are ordinarily unknown. Ask the taxpayer to prepare a list in triplicate, identifying each affected taxpayer, and attach one copy to each copy of the agreement when it’s executed and returned for approval.

7.2.1.3.3  (08-27-2015)
Processing Rulings Accompanied by Closing Agreement Requests

  1. The procedure for processing a taxpayer’s request for a ruling accompanied by a request for a closing agreement is the same as that described in Rev. Proc. 2015–4 , 2015-1 IRB 144 (revised annually).

  2. The EP Technical employee prepares the closing agreement. It must accompany the ruling letter.

  3. See Exhibit 7.2.1-1, Closing Agreement on Final Determination Covering Specific Matters, for help preparing the closing agreement.

  4. Inform the taxpayer of the procedures for executing the agreement and returning it for approval.

  5. Prepare the ruling letter for the group manager's signature.

    1. If the proposed ruling is not in accordance with the taxpayer’s request, a closing agreement is not necessary and the adverse ruling letter is signed according to established procedures.

    2. If the proposed ruling is in accordance with the taxpayer’s request but denies the request for a closing agreement, the ruling letter must be signed at a level no lower than the Director, EP R&A.

    3. Refer the closing agreement and the letter ruling, etc., on which it is based to the Division Counsel or Associate Chief Counsel, as appropriate.

  6. For closing agreements based on a proposed ruling requiring EP Technical’s determination of an important question of tax policy (and not a statement of the IRS position on a tax matter) and EP Technical must obtain the Assistant Secretary for Tax Policy’s views, include a reference to the closing agreement in your memo for the proposed ruling:

    1. Prepare a memo for the signature of the Commissioner, TE/GE, to refer the policy question.

    2. State the policy question involved and the proposed interpretation, and request concurrence.

    3. Obtain the concurrence of the Division Counsel or Associate Chief Counsel, as appropriate.

7.2.1.4  (09-17-2014)
Obtaining Approval to Pursue a Closing Agreement

  1. Before considering a closing agreement:

    1. Assess the technical aspects of the case.

    2. Ascertain the IRS position.

    3. Discuss the IRS position on the issue(s) with the taxpayer.

    4. Establish the taxpayer’s position on the issue(s).

    5. Determine the effect adverse action(s) would have on the public interest.

    6. Clarify whether the plan can correct organizational and/or operational deficiencies.

    7. Decide if the IRS will sustain any disadvantage(s) by entering into a closing agreement.

  2. Consult with your group manager. Determine whether a closing agreement is worth pursuing.

  3. Talk to the taxpayer to see if they would consider a closing agreement. However, don’t guarantee that a closing agreement will be offered, nor that it would resolve all issues on any case, because it may not be approved.

  4. If the taxpayer agrees, consult your manager. If your manager concurs with you that a closing agreement is warranted, obtain approval to negotiate.

  5. The Director of EP R&A must approve any closing agreement negotiations and resolutions.

  6. Write a short memo to the Director, EP R&A explaining:

    • The facts.

    • The technical analysis.

    • The taxpayer's proposal, if any.

    • Issues that will be the subject of negotiations.

    • Why it’s in the IRS’s and the taxpayer’s best interests to enter into a closing agreement.

  7. Prepare a Routing Sheet on which the following individuals may initial and date their concurrence:

    1. Group manager

    2. Manager, EP Technical

    3. Director, EP, R&A

  8. Once you’ve received all of the above approvals, you may begin to negotiate the closing agreement.

7.2.1.4.1  (09-17-2014)
Overview of Closing Agreement Negotiations

  1. In negotiations, the goal is collaboration, not just compromise. Consider taking the Interest Based Conflict Management Skills Workshop for TEGE (ELMS Catalog number 11294) before negotiating with the taxpayer. Find additional information at http://talkfirst.web.irs.gov/.

  2. Negotiation is a four-step process:

    1. Preparation

    2. Information exchange

    3. Bargaining

    4. Commitment

7.2.1.4.2  (08-27-2015)
Preparing for Negotiations

  1. Determine:

    • Who should be present for the negotiation (for example, within the scope of a power of attorney or appointment). The taxpayer’s representative(s) may be present. In some situations, the entire board of an organization may be present during negotiations. Many practitioners try to negotiate without their client present, which can prolong the negotiation process.

    • Whether you’ll call or meet in person.

  2. These other employees may take part, or be invited to take part in the negotiations:

    • Manager of EP Technical

    • Director, EP R&A

    • Chief Counsel

    • Personnel from other divisions or functions that may be impacted by the negotiations

  3. Determine the time, location and method of negotiation. Consider the following issues:

    • Are the negotiations in person or by conference call?

    • If negotiating in person, who is physically attending the negotiation?

    • How long should each negotiation session last?

    • When should subsequent sessions be held?

    • Should taxpayer records be on hand for the negotiations?

  4. Determine any ground rules and agree on them.

  5. Prepare a checklist of issues. Make notes of items you’ll address in the negotiation.

  6. Review the case information, including documents secured from the taxpayer, correspondence, and any memoranda or other documents in the case file.

  7. Calculate the sanction based on the maximum payment amount. The maximum payment amount approximates the amount of tax the IRS could collect as a result of the disqualification of the plan. See Rev. Proc. 2013-12, 2013-4 IRB 313, sections 4, 13, and 14 for provisions relating specifically to Audit CAP.

  8. Determine our best alternative to a negotiated agreement if we can’t arrive at a closing agreement.

7.2.1.4.3  (08-27-2015)
Information Exchange at Negotiations

  1. Determine whether you need additional information and, if so, request it.

  2. During the negotiation, either side may request additional items. If the taxpayer asks for additional information, promptly provide it, unless prohibited by disclosure laws (i.e., confidential informant identity, other taxpayer’s tax return information, etc.).

    Example:

    During the negotiation, the taxpayer asks what the tax consequences would be of taking a particular action. Perform the tax computation(s) and give it to the taxpayer.

  3. Set mutually agreed deadlines to provide/receive information. If the taxpayer requests extensions of time, document the request and the reason.

7.2.1.4.4  (08-27-2015)
Bargaining Over Terms of Closing Agreement

  1. The manager is generally the lead negotiator. At the start of negotiations, the lead negotiator advises the taxpayer:

    1. A closing agreement is an attempt to fashion an evenhanded resolution of the differences.

    2. The parties are under no obligation to continue the process if they can’t reach an agreement.

    3. The taxpayer doesn’t waive any rights under any applicable appeals procedure should the parties fail to reach an agreement.

  2. Document all sessions held with the taxpayer and their representative. Track each issue discussed. Document agreed issues.

  3. For issues that you can’t agree: determine whether you must include them. Consider conceding on some proposals if not critical to the agreement.

  4. When both parties agree to issue resolutions, begin drafting the closing agreement.

  5. Regardless of whether or not the case results in a closing agreement, include these in the administrative case file:

    1. Negotiations with the taxpayer and/or representative.

    2. Terms offered if the negotiations are not successful.

    3. The reason a closing agreement is/isn’t in our best interest.

  6. Discuss sanction amount with group manager and determine acceptable payment ranges you’ll consider in negotiation.

    Note:

    The payment or "consideration" may be a percentage of the tax liability that the taxpayer would have owed if no agreement was entered into.

7.2.1.5  (08-27-2015)
Drafting and Processing Closing Agreements

  1. Use these guidelines when drafting a closing agreement.

    1. Fully develop the facts of the case. State issues clearly, so that they are reasonably interpreted only one way. Although the material in the file may adequately explain the intent of the agreement, the agreement itself is the legal document.

    2. Carefully assess the legal aspects of the case. Don’t overlook essentials. The agreement should state to whom the income pertains and clearly identify property. To avoid ambiguity in descriptive terms, use statutory terms where applicable.

    3. Ensure that you protect the statute of limitations on all affected returns. Carefully consider your determination’s direct/ indirect impact on other years or related cases.

    4. Determine the taxability of the various parties.

    5. After negotiating the specific terms of the closing agreement, prepare a draft closing agreement for review by all parties.

  2. Generally, in accordance with the closing agreement, the payer must send a certified or cashier’s check made to the U.S. Treasury in return for the plan or organization not having its qualified status revoked. The payment is not deductible for federal tax purposes and must be made at the time the agreement is executed.

  3. Section 3468 of the IRS Restructuring and Reform Act of 1998 provides that the closing agreement shouldn't contain any taxpayer release of any right of action against the Internal Revenue Service or its employees for:

    • Civil rights violations

    • Any other action taken in connection with the federal tax laws

  4. If the taxpayer does not have representation, EP personnel should not ask the taxpayer to waive his/her right to bring a civil or other non-tax action against the government. In the case of a taxpayer with a power of attorney (POA). If the taxpayer’s representative doesn’t have a valid Form 2848 or it’s limited, explain why Form 2848 isn’t valid to the taxpayer. This should be included in the case history sheet.

  5. The file should include signed and dated documentation from the taxpayer or the taxpayer’s representative, and complete notes on the case history sheet evidencing the process used to obtain any waiver subject to this provision.

  6. If such a release is the subject of discussion, contact Chief Counsel who will discuss the matter with EP Technical. If they agree the waiver request is appropriate, include in the file:

    • Signed and dated documentation from the taxpayer or the taxpayer's representative.

    • Complete notes on Form 5464, Case Chronology Record, evidencing the process used to obtain any such waiver.

7.2.1.5.1  (09-17-2014)
Preparing the Closing Agreement Document

  1. Prepare the closing agreement. See Exhibit 7.2.1-1, Closing Agreement on Final Determination Covering Specific Matters for the format.

    1. The opening paragraph states that the agreement, pursuant to IRC 7121, is made between the taxpayer(s) and the Commissioner. This paragraph contains the taxpayer’s name, address and identifying number (EIN) of each taxpayer that is a party to the agreement.

    2. The "Whereas" paragraphs describe the facts you and the taxpayer agreed to.

    3. Following "Now it is Hereby Determined and Agreed for Federal Tax purposes," list the items to which the parties are agreeing, including the amount of consideration.

    4. The execution paragraph is the last paragraph in the agreement.

    5. The date and signature lines follow the execution paragraph.

  2. Prepare four originals if the POA requests an original.

  3. Place this header on the original and all copies of each page other than page 1, in the upper left corner as "Closing Agreement - (name of taxpayer)."

  4. Number each additional page in the center of the bottom as (Page_ of _).

  5. For cases where separate closing agreements are requested by or on behalf of a number of taxpayers (less than 25) and the agreements will be identical except for the names and addresses of the taxpayers, consider preparing a closing statement for only one of them, requesting the other taxpayers or their representatives to prepare similar agreements for the others.

7.2.1.6  (09-17-2014)
Obtaining the Taxpayer's Signature

  1. When the draft closing agreement is ready for signature, send a letter to the taxpayer with instructions on executing the closing agreement - see IRM 7.2.1.6.1, Taxpayer Instructions. Enclose three copies of the closing agreement. If the POA requests an original, enclose four copies.

7.2.1.6.1  (09-17-2014)
Taxpayer Instructions

  1. Provide instructions on the proper procedure for executing the agreement and returning it to the appropriate office for approval under the following circumstances:

    Circumstances: Actions:
    Taxpayer’s current address unknown at the time the agreement is prepared Leave a space for that address in the first paragraph of the agreement and the taxpayer (or the taxpayer’s representative) is instructed to insert their current address.
    Taxpayer is a corporation Enter the corporate name on the agreement, followed by the signature and title of an authorized officer, or officers, or by the signature of an authorized representative.
    Agreement is signed by an authorized representative for the taxpayer Attach to the original agreement a properly executed power of attorney which specifically authorizes the representative to enter into such an agreement on behalf of the taxpayer.
    Mass Closing Agreement Ask taxpayer designated to sign for the group to date and sign all copies of the agreement.
    • Ask the taxpayer (or representative) to prepare and attach to each copy of the agreement a list of the names and addresses of the taxpayers in the group on behalf of whom the designated taxpayer is executing the agreement.

    • Attach to the original agreement, if applicable, properly executed powers of attorney for all listed taxpayers, authorizing the designated taxpayer (or representative) to execute the agreement on their behalf.

    • Instruct the taxpayer to date and sign all copies of the closing agreement.

7.2.1.7  (08-27-2015)
Procedure for Executed Closing Agreements

  1. When a taxpayer or authorized representative executes and returns the closing agreement, you can’t change or add anything to the agreement.

    1. If the taxpayer or authorized representative made additions or corrections, ensure that they’ve initialed the changes. Any additions or corrections should be limited to clerical or typographical deficiencies.

    2. If the taxpayer or authorized representative substituted a new page, they must initial and date the bottom of the page.

  2. The group manager determines if other TE/GE officials and/or any other any office should review the agreement before all parties finalize it.

  3. Ensure the closing agreement is executed by the applicable taxpayer(s) and secure the total amount due.

    1. All payments must be certified check(s) or cashier’s check(s) and made payable to the U.S. Treasury.

    2. All check(s) must be delivered to the EP/EO Processing Unit at the Covington Service Center when received. See IRM 7.2.1.8, Processing Remittances.

  4. Send a signature package containing the closing agreement(s) executed by the taxpayer(s) to the Director, EP R&A.

  5. When you receive the signed closing agreement and are satisfied that the file is in proper order, document the case history sheet and prepare the case for closing.

7.2.1.7.1  (09-17-2014)
Signature and Closing Procedures

  1. Use these procedures to obtain the Director, EP R&A’s signature:

    1. Prepare a signature package per EP office procedures.

    2. Forward the signature package to the group manager.

    3. Group Manager: review the agreement, sign and date on the signature of the sign-off copy as Reviewing Officer, and forward the signature package to the Director, EP R&A.

  2. Use these procedures to obtain the Director, EP R&A’s signature:

    1. Prepare a signature package per EP office procedures.

    2. Forward the signature package to the group manager.

    3. Group Manager: review the agreement, sign and date on the signature line of the sign-off copy as Reviewing Officer, and forward the signature package to the Director, EP R&A.

  3. After the Director, EP R&A, signs all copies of the closing agreement, follow these procedures:

    1. Group manager: sign and date the letter transmitting an original closing agreement to the taxpayer (and/or the taxpayer’s representative) and the memo transmitting an original closing agreement to the Director, EP R&A.

    2. Group manager: send to the Director, EP R&A with original closing agreement and a copy of each of the following: taxpayer’s request for ruling and closing agreement, related ruling letter (if applicable), and transmittal letter to taxpayer.

    3. Director EP R&A office: keep the original closing agreement and copies of: the related ruling, transmittal letter.

    4. Director EP R&A Office: return the signature package to the group to mail the closing agreement and/or letter ruling.

    5. EP Technical employee: close the case file according to closing procedures.

7.2.1.8  (08-27-2015)
Processing Remittances

  1. For closing agreements processed by EP Technical, any remittance should be forwarded for deposit to the EP/EO Processing Unit at the Covington Service Center.

7.2.1.9  (08-27-2015)
Finality of Closing Agreements

  1. Once Director, EP R& A approves an agreement, it's final and conclusive. We can't reopen the closing agreement as to the matters agreed upon or modified. We may not annul, modify, set aside or disregard the closing agreement (or any legal action in accordance with it) in any suit, action or proceeding unless there is a showing of fraud, malfeasance or misrepresentation of material fact.

  2. However, any change in or modification of applicable statutes will render an agreement originating in Employee Plans ineffective to the future compliance is dependent upon those statutes.

  3. Because of the finality of these agreements, they must be carefully drafted.

7.2.1.10  (08-27-2015)
Modification of Closing Agreements

  1. The Commissioner may set aside agreements made under IRC 7121(b) upon a showing of fraud or malfeasance, or misrepresentation of a material fact. The Commissioner's authority in this respect hasn't been delegated; therefore, the Commissioner must approve any such actions.

    Note:

    We don't treat simple unintentional errors as fraud, malfeasance, or misrepresentation that allow reopening of an agreement. (Policy Statement P-4-3 ( IRM 1.2.13.1.1)).

  2. If a provision of a closing agreement is reasonably subject to more than one interpretation and the parties have reasonably differed in their interpretation of the provision, the Commissioner may execute a new agreement restating more clearly, in terms acceptable to all parties, the intended meaning of the disputed provision.

Exhibit 7.2.1-1 
Closing Agreement on Final Determination Covering Specific Matters


CLOSING AGREEMENT ON FINAL DETERMINATION
COVERING SPECIFIC MATTERS
Under IRC 7121 of the Internal Revenue Code (the “Code”), [Name of Taxpayer, Tax Identification Number, address],] (the "Taxpayer" ), and the Commissioner of Internal Revenue make the following agreement (the "Closing Agreement" ):
WHEREAS, and
WHEREAS, and
WHEREAS, the Taxpayer has determined that this Closing Agreement set forth herein is in the Taxpayer’s best interests; and
WHEREAS, $______ will be paid by the Taxpayer to the United States Treasury in consideration of this Closing Agreement; and
WHEREAS, the Service, on behalf of the Secretary of the Treasury, through its authorized representative, has determined that this Closing Agreement is also in its best interest and in the best interests of the Taxpayer;
NOW IT IS HEREBY DETERMINED AND AGREED for Federal income tax purposes that the above representations are material to this Closing Agreement that and:
  1. [state conditions]

  2. This agreement constitutes a resolution under the Code solely of the specific matters discussed herein. No inference shall be made as to the application of the Code under any facts and circumstances outside this Closing Agreement. No inference shall be made with respect to whether this resolution satisfies other Federal law, including Title I of the Employee Retirement Income Security Act of 1974.

This Closing Agreement is final and conclusive except:
  1. the matter it relates to may be reopened in the event of fraud, malfeasance, or misrepresentation of material fact;

  2. it is subject to the Code sections that expressly provide that effect be given to their provisions notwithstanding any other law or rule of law; and

  3. if it relates to a tax period ending after the date of this agreement, it is subject to any law, enacted after the agreement date, that applies to that tax period.

By executing this Closing Agreement, the above parties certify that they have read and agreed to the terms of this document

[Name of Taxpayer, SSN]
By: ___________________________________ Date: ____________________
Commissioner of Internal Revenue on behalf of the Secretary of the Treasury
By: ___________________________________ Date: ____________________

Director, Employee Plans Rulings and Agreements
Tax Exempt and Government Entities

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