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Submissions that do not qualify under 7623(b) will be processed under section 7623(a).
- These cases will continue to be considered through regulations appearing at 26 CFR 301.7623-1.
- The award is at the discretion of the Service, there is no requirement that an award be issued.
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The discretionary award is based on additions to tax, penalties, interest, and other amounts collected as a result of administrative or judicial action resulting from the information provided.
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No minimum statutory award percentage
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No appeal provisions