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To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or tax-related matter(s) addressed herein.

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Tuesday, June 29, 2010

Taxation of Business Development Companies: IRS Notice 2010-33 -frivolous positions under 6702(c)

Taxation of Business Development Companies: IRS Notice 2010-33 -frivolous positions under 6702(c):

"Part III – Administrative, Procedural, and Miscellaneous

Frivolous Positions – This notice lists positions identified as frivolous for purposes of section 6702(c) of the Code. Notice 2008-14, 2008-4 I.R.B. 310, modified and superseded.

Notice 2010-33"

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