Disclosure in Judicial or Administrative Tax Administration Proceedings

ID:
Office:
UILC:
CCA_2009033015395553
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6103.08-04
Number: 200938027
Release Date: 9/18/2009
From: ---
Sent: Monday, March 30, 2009 3:39:56 PM
To: ---
Cc:
Subject: RE: IMT Loss Importation Reports ---
Hi --- --
I suggest reading CC Notice 2006-003 carefully. The second paragraph under Section III of that Notice explains the relationships and transactions needed to be able to use "pattern evidence". Section V reminds everyone that third party privacy must be considered and appropriately protected whenever third party return information is used in a proceeding. You might also find CC Notice 2006-006 (Q&A style) helpful.
If you have any questions, feel free to contact me.
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