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Instructions for Form 8264 2006 Tax Year

General Instructions

This is archived information that pertains only to the 2006 Tax Year. If you
are looking for information for the current tax year, go to the Tax Prep Help Area.

Purpose of Form

Organizers of certain tax shelters, including confidential corporate tax shelters in which interests were offered after February 28, 2000, are required to file Form 8264 to register the tax shelters with the IRS. Organizers of tax shelters under section 6111(c) must complete Parts I, II, and III of Form 8264. Organizers of a confidential corporate tax shelter must complete Parts I and IV of Form 8264. If a confidential corporate tax shelter also meets the definition of a tax shelter under section 6111(c), the organizer must complete all parts of the form. Organizers filing a properly completed Form 8264 will receive a tax shelter registration number from the IRS. They must furnish the tax shelter registration number to investors in the tax shelter. Investors must report the tax shelter registration number on their tax returns using Form 8271, Investor Reporting of Tax Shelter Registration Number.

Caution
For purposes of the registration requirement for tax shelters under section 6111(c) and confidential corporate tax shelters, the term organizer includes any person who participates in the organization, management, or sale of the tax shelter. See Who Is Required To Register a Tax Shelter? below. For purposes of this form, “promoter” as defined under section 6111 and the regulations will be referred to as “organizer.

What Is a Tax Shelter?

Tax Shelters Under Section 6111(c)

An investment that meets the following two requirements is considered a tax shelter under section 6111(c) for registration purposes, regardless of whether it is marketed or customarily designated as a tax shelter.

1.   The investment is one with respect to which a person could reasonably infer from representations made or to be made in connection with the offering for sale of an interest in the investment that the tax shelter ratio (defined on page 5) may be greater than 2 to 1 for any investor at the close of any of the first 5 years ending after the date on which the investment is offered for sale; and

2.   The investment is one that is required to be registered under a Federal or state law regulating securities, or that is sold under an exemption from registration requiring the filing of a notice with a Federal or state agency regulating the offering or sale of securities, or that is a substantial investment (defined on page 4).

Confidential Corporate Tax Shelters

An investment that meets each of the following three requirements is considered a “confidential corporate tax shelter” under section 6111(d).

1.   A significant purpose of the structure of the investment is the avoidance or evasion of Federal income tax for a direct or indirect corporate participant. Avoidance or evasion of tax is considered a significant purpose if the investment consists of either of the following:

  
  • Listed transactions. This category includes transactions (defined on page 5) that are the same as or substantially similar to one of the types of transactions that the IRS has determined to be a tax avoidance transaction identified by notice, regulation, or other form of published guidance as a listed transaction. See Regulations section 301.6111-2(b)(2). There may be subsequent guidance identifying additional tax avoidance transactions. For existing guidance see Notice 2003-76, 2003-49 I.R.B. 1181.

  • Other tax-structured transactions. Generally, this includes transactions (a) that are structured to produce Federal income tax benefits as an important part of the intended results of the transaction and (b) that the organizer or other persons responsible for registration reasonably expect to be presented to more than one potential participant in the same or substantially similar form. See Exception for confidential corporate tax shelters on page 2.

2.   The investment is offered to any potential participant under conditions of confidentiality. Generally, an offer is considered confidential if:

  
  • An offeree's disclosure of the structure or tax aspects of the transaction is limited in any way by express or implied understanding or agreement (whether or not legally binding) with or for the benefit of the organizer or

  • The organizer knows or has reason to know that the offeree's use or disclosure of information relating to the structure or tax aspect of the transaction is limited for the benefit of any person other than the offeree.

3.    Fees in excess of $100,000 (in the aggregate) may be received by organizers of the tax shelter and any person related to such person under sections 267 and 707. For this purpose, substantially similar transactions are treated as part of the same tax shelter and the fees from the transaction must be combined. The fees include all consideration such persons may receive, including contingent fees, equity interests, and fees for other transactions received as consideration for promoting the tax shelter.

See Regulations sections 301.6111-2(b), (c), and (d) for details.

Tip
An investment may be a tax shelter under section 6111(c), a confidential corporate tax shelter, or both.

Who Is Required To Register a Tax Shelter?

Generally, tax shelters under section 6111(c) and confidential corporate tax shelters (under section 6111(d)) must be registered by a tax shelter organizer. If a principal organizer, defined on page 4, does not register the shelter by the day interests in the shelter are first offered for sale, any of the following persons may be treated as a tax shelter organizer.

  • A person who participated in the organization of the shelter.

  • A person who participates in the management of the shelter when it is not properly registered.

  • A person who participates in the sale of the shelter at a time when that person knows, or has reason to know, that the shelter has not been properly registered.

If all organizers of a confidential corporate tax shelter are foreign persons, any person who discusses participation in the transaction may be required to register the tax shelter (see Regulations section 301.6111-2(g)(2) for details).

A group of persons who may be treated as tax shelter organizers may enter into a written agreement designating one person to be responsible for registering the tax shelter. This designated organizer must have participated in the organization of the tax shelter and may not be a resident of a foreign country. Those who sign the agreement, other than the designated organizer, will not be subject to a penalty unless they know or have reason to know that the designated organizer has failed to register the tax shelter as required. In that case, a person, other than the designated organizer, will be subject to a penalty if he or she does not register the tax shelter as soon as practicable. For more detailed information concerning designation agreements and their consequences, see A-34 through A-39 of Temporary Regulations section 301.6111-1T.

If a tax shelter is not registered on time and there is no designation agreement, each person required to register the tax shelter will be subject to a penalty unless he or she has reasonable cause for failure to file a registration statement. For information about the applicable penalty and the circumstances in which a person required to register has reasonable cause for failure to register, see Penalties on page 4, and Temporary Regulations section 301.6707-1T, relating to penalties for failure to furnish information regarding tax shelters.

Exemptions From Registration

Exemptions for tax shelters under section 6111(c).   The following investments are not subject to tax shelter registration under section 6111(c). These exceptions do not apply to confidential corporate tax shelters.

1.   Sales of residences primarily to persons who are expected to use the residences as their principal place of residence.

2.   Sales or leases of tangible personal property (other than master sound recordings, motion picture or television films, videotapes, lithograph plates, or other property relating to a literary, musical, or artistic composition) by the manufacturer of the property (or a member of an affiliated group, within the meaning of section 1502, including the manufacturer) primarily to persons who are expected to use the property in their principal active trade or business.

3.   Sales or leases of tangible personal property (other than collectibles, master sound recordings, motion picture or television films, videotapes, lithograph plates, or other property that includes or relates to a literary, musical, or artistic composition) by a person in the ordinary course of that person's trade or business will be exempt if the purchaser or lessee is reasonably expected to use the property either for a personal use or in the purchaser's or lessee's principal active trade or business.

4.   Performance of services in connection with the recipient's principal active trade or business or for the recipient's personal use.

  See A-24 and A-24A of Temporary Regulations section 301.6111-1T for additional information on investments exempt from registration as a section 6111(c) tax shelter.

Exception for confidential corporate tax shelters.   Generally, if the organizer of a confidential corporate tax shelter reasonably determines that there is no reasonable basis under Federal tax law for denial of any significant portion of the expected income tax benefits from the transaction, tax avoidance or evasion of taxes is not considered a significant purpose of the structure of the transaction and registration is not required. This exception does not apply to transactions that are the same as or substantially similar to listed transactions. See Regulations sections 301.6111-2(b)(3) and (4) for details.

  Registration is not required if the IRS makes a determination by published guidance that the transaction is not subject to the registration requirements.

  The taxpayer may request the IRS make a determination by individual ruling that a specific transaction is not subject to the registration requirements. See Request for Ruling beginning on page 3.

Suspension of Registration Requirements for Projected Income Investments

These rules apply only to section 6111(c) tax shelters.

The registration requirements may be suspended for a tax shelter if investors are told in a written statement made in good faith and based on reasonable economic and business assumptions that their investment is expected to produce net income and not to provide net tax benefits (a projected income investment). A tax shelter does not qualify for suspension if there is a projection (whether oral or written) of a net loss or other tax benefit (determined on a cumulative basis) in any of its first 5 years or if the tax shelter invests beyond an incidental amount in any interest in a collectible (as defined in section 408(m)(2)), a master sound recording, motion picture or television film, videotape, lithograph plate, copyright, or a literary, musical, or artistic composition.

The suspension ends if the tax shelter subsequently reduces the cumulative tax liability of an investor during the 5-year period. In that case, the tax shelter must be registered within 30 days after the end of the tax shelter's year in which the reduction is generated and before a Schedule K-1 or similar form is sent to the investor. Once the tax shelter is registered, registration numbers must be provided to investors.

For more detailed information concerning the suspension of the registration requirements as a section 6111(c) tax shelter for projected income investments, see A-57A through A-57J of Temporary Regulations section 301.6111-1T.

When To File

In general, file Form 8264 no later than the day on which an interest in the tax shelter is first offered for sale.

Special rules for confidential corporate tax shelters.   If a transaction becomes subject to the registration requirements as a confidential corporate tax shelter after its first offering of sale (e.g., because of a change in the law or factual circumstances), it must be registered by the date of its next offering for sale. If a transaction becomes a listed transaction after its first offering, it was not previously required to be registered, and interests were offered for sale within the previous 6 years, the confidential corporate tax shelter must be registered within 60 days of the published guidance identifying it as a listed transaction. See Regulations section 301.6111-2(e)(ii) for details.

Where To File

File Form 8264 with the Internal Revenue Service Center, Ogden, UT 84201.

Furnishing a Tax Shelter Registration Number

In general, any person who sells (or otherwise transfers) an interest in a tax shelter must furnish that tax shelter's registration number to each investor. For purposes of furnishing tax shelter registration numbers, the term investors includes both original purchasers of tax shelter interests and persons who acquire their interests from prior purchasers.

The registration number must be furnished to the investor at the time of sale or transfer of the interest. If the seller or transferor has not received the registration number at this time, a written statement must be given to the investor stating that the number has been applied for and will be furnished when available. It then must be given to the investor within 20 days after the seller or transferor receives it.

For information about furnishing the number, the required content of the written statement, and the required legend stating that the tax shelter has not been approved, etc., by the Internal Revenue Service, see A-51 through A-54 of Temporary Regulations section 301.6111-1T.

The registration number must be included on any return on which an investor claims any deduction, loss, credit, or other tax benefit, or reports any income relating to the tax shelter.

Requirement to Keep Lists

Generally, each material advisor (defined below) must prepare and maintain a list of certain persons to whom (or for whose benefit) the material advisor makes or provides a tax statement with respect to a transaction that is a potentially abusive tax shelter. A separate list must be maintained for each transaction or group of substantially similar transactions. The lists must be maintained for 7 years and, upon written request, must be furnished to the IRS within 20 days. See Regulations section 301.6112-1 for more information.

Material advisor.   A material advisor is (a) any person required to register the transaction under section 6111 or (b) any person who receives or expects to receive a minimum fee (defined below) with respect to the transaction and makes a tax statement (defined below) to or for the benefit of any of the following:

1.   A taxpayer who is required to disclose the transaction because it is a listed transaction under Regulations sections 1.6011-4, 20.6011-4, 25.6011-4, 31.6011-4, 53.6011-4, 54.6011-4, or 56.6011-4 or who would have been required to disclose the transaction if it had become a listed transaction within the statute of limitation period;

2.   A taxpayer whom the potential material advisor (at the time the transaction is entered into) knows is or reasonably expects to be required to disclose the transaction because it is or is reasonably expected to become a reportable transaction under Regulations section 1.6011-4(b)(3) through (7);

3.   A person who is required to register the transaction under section 6111;

4.   A person who purchases (or otherwise acquires) an interest in a section 6111 tax shelter; or

5.   A transferee of an interest in a transaction if the potential material advisor knows or reasonably expects that (a) the interest will be sold or transferred to a subsequent participant and (b) it is either a listed transaction or a reportable transaction under Regulations section 1.6011-4(b)(3) through (7) if the relevant thresholds are met.

A material advisor does not include a person who makes a tax statement solely in the person's capacity as an employee, shareholder, partner, or agent of another person. However, a person that forms or avails of an entity with the purpose of avoiding the rules of section 6111 or 6112 or the penalties under section 6707 or 6708 will be treated as a material advisor.

Minimum fee.   The minimum fee is $250,000 for a transaction if each person to whom or for whom a tax statement is made is a corporation (other than an S corporation). The minimum fee is $50,000 if the tax statement is made to a partnership or trust (unless all owners or beneficiaries are corporations in which case the fee is $250,000). The minimum fee for all other transactions is $50,000. In the case of listed transactions, the minimum fee is reduced from $250,000 to $25,000 and from $50,000 to $10,000. The minimum fee threshold must be met independently by each transaction (fees from other transactions are not aggregated) and includes all fees for a tax strategy or for services for advice or for the implementation of a transaction that is a potentially abusive tax shelter. See Regulations section 301.6112-1(c)(3) for more details.

Tax statement.   A tax statement is any statement, either written or oral, that relates to a tax aspect of a transaction that causes the transaction to be a reportable transaction as defined in Regulations section 1.6011-4(b) or a tax shelter as described in section 6111.

Potentially abusive tax shelter.   For purposes of the requirement to keep lists, potentially abusive tax shelters include any transaction that is required to be registered under section 6111 or any transaction that has a potential for tax avoidance or evasion. Transactions that have a potential for tax avoidance or evasion include:
  • Any listed transaction,

  • Any transaction that a potential material advisor (at the time the transaction is entered into) knows is or reasonably expects will become a reportable transaction under Regulations section 1.6011-4(b)(3) through (7), and

  • Any transaction with respect to which an interest has been transferred and the transferor knows or reasonably expects that (a) the interest will be sold or transferred to a subsequent participant and (b) it is either a listed transaction or a reportable transaction under Regulations section 1.6011-4(b)(3) through (7) if the relevant thresholds are met.

Persons required to be on lists.   The term person includes an individual, trust, estate, partnership, association, company, corporation, or affiliated group of corporations that join in filing a consolidated return. A material advisor is required to list.
  • Each person described in items 1 through 4 in the definition of material advisor (above) to whom (or for whose benefit) the material advisor made a statement with respect to a transaction that is a potentially abusive tax shelter.

  • Any subsequent investor in a transaction that must be disclosed under Regulations section 1.6011-4(b) if the material advisor knows the identity of that person.

  • Each person that purchases an interest in a transaction that the material advisor is required to register.

Contents of the list.   Each list must contain the following information.
  • The name, registration number (if any), and identifying number (if any) of the transaction.

  • The name, address, and identifying number of each person required to be on the list.

  • The number of units acquired by each person (if known by the material advisor).

  • The date each person entered into the transaction (if known by the material advisor).

  • The amount invested by each person in the transaction (if known by the material advisor).

  • A detailed description of the transaction that describes both the tax structure and its expected tax treatment.

  • A summary or schedule of the tax treatment that each person is intended or expected to derive from participation in the transaction (if known by the material advisor).

  • For each person required to be on the list, the name of the person from whom the interest was acquired (if other than the material advisor).

  • Copies of any additional written materials, including tax analyses or opinions related to the transaction that are material to an understanding of the purported tax treatment or tax structure of the transaction, that have been shown or provided to any person who acquired or may acquire an interest in the transaction (or to their representatives, tax advisors, or agents) by the material advisor or any related party or agent of the material advisor.

Request for Ruling

A tax shelter organizer, or other person responsible for registration or maintaining a list, may request a ruling from the IRS to determine whether a transaction must be registered as a confidential corporate tax shelter or is subject to the list keeping requirements. The request for ruling must be submitted to the IRS on or before the date registration is otherwise required. Send the request to Internal Revenue Service, Attn: CC:PA:LPD:DRU, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. However, if a private delivery service is used, send the request to Internal Revenue Service, Attn: CC:PA:LPD:DRU, Room 5336, 1111 Constitution Avenue, NW, Washington, DC 20224. See Rev. Proc. 2004-1, 2004-1 I.R.B. 1 or subsequent IRS guidance for more details. If the request fully discloses all relevant facts relating to the transaction, the potential obligation to register the transaction or to maintain the list is suspended during the period the ruling is pending. If the IRS determines that the transaction is a confidential corporate tax shelter subject to registration, the due date for registration is extended for sixty days from the date of the ruling or the date of the withdrawal of the ruling request. The requirement to make lists available for inspection is suspended for sixty days from the date of the ruling or the date of the withdrawal of the ruling request. However, if the transaction is found to be subject to the list keeping requirements, then the pending of the ruling request shall not affect the persons required to be on the list (even those who acquired interest during the pending of the ruling request). See Regulations sections 301.6111-2(b)(5) and 301.6112-1(i) for details.

Penalties

If a tax shelter organizer is required to register a tax shelter under section 6111(c) and fails to do so when required, or files false or incomplete information, a penalty may be charged equal to the greater of $500 or 1% of the aggregate amount invested in the shelter. No penalty will be charged if the organizer has reasonable cause for failing to comply with the registration requirements.

If a confidential corporate tax shelter organizer required to register fails to do so when required, or files false or incomplete information, a penalty may be charged equal to the greater of $10,000 or 50% of the fees paid to all organizers before the date the shelter is registered. In the case of an intentional disregard of the requirement to register a confidential corporate tax shelter, the penalty is increased to 75% of the fees. No penalty will be charged if the organizer has reasonable cause for failing to comply with the registration requirements.

Any person who is required to furnish a tax shelter registration number to investors in the tax shelter and who fails to do so will be charged a penalty of $100 for each failure.

A person required to keep a list may be charged a penalty for each investor who is required to be on the list but is omitted. The penalty is $50 for each omission, limited to a maximum of $100,000 per year per shelter. No penalty will be charged if the omission was due to reasonable cause and not due to willful neglect.

An additional civil penalty is imposed against any person who directly or indirectly organizes, participates in the sale of, or promotes an abusive tax shelter. The penalty also applies to persons who cause other parties to make or furnish false or fraudulent statements or gross valuation overstatements that promote the abusive tax shelter. The penalty is equal to the lesser of $1,000 or 100% of the gross income derived (or to be derived) by that person from that activity.

Penalties are also imposed against persons who knowingly aid and abet in the understatement of the tax liability of another person. The penalty is $1,000 ($10,000 for corporate tax returns and documents).

Criminal penalties for failure to file on time and for filing a false or fraudulent return are provided by sections 7203, 7206, and 7207.

Preparing the Form

A registration number may not be issued if an incomplete application is filed. You must make an entry on Form 8264 whenever an item is applicable. If you need more space, attach a statement or use the Explanation of Items in Part V of the form. You may incorporate information contained in other documents. If you do, attach copies of the documents and specify the page number of the incorporated material. When dollar amounts are called for, use whole dollar amounts.

If an item does not apply or you do not know the requested information, leave the item blank and explain in Part V of the form why it does not apply or why you do not know the requested information.

Amended Forms 8264

If a single Form 8264 is filed with respect to an aggregated confidential corporate tax shelter, an amended Form 8264 must be filed to reflect material changes and to include any additional or revised written materials presented in connection with an offer to participate in the shelter (see Regulations section 301.6111-2(e)(2) for details). Otherwise, amendments may be made to Form 8264 in certain cases. If there is any material change in facts occurring after the initial registration, you may, but are not required to, file an amended form. The following are examples of a material change in facts.

  1. A change in the identifying information relating to the tax shelter or tax shelter organizer.

  2. The acquisition or construction of a principal asset not reported on the initial application for registration.

  3. A change in the method of financing a minimum investment unit.

  4. A change in the principal business activity.

  5. A change in any tax shelter ratio reported on the initial application for registration that increases or decreases the reciprocal of the tax shelter ratio by 50% or more. The reciprocal of the ratio is the fraction in which the amount of the applicable investment base is the numerator and the amount of the applicable deductions and credits is the denominator. For example, if the tax shelter ratio changes from 2 to 1 to 4 to 1, the reciprocal of the tax shelter ratio decreases from ½ to ¼, a 50% decrease. Similarly, if the tax shelter ratio changes from 6 to 1 to 4 to 1, the reciprocal of the tax shelter ratio increases from ⅙ to ¼, a 50% increase. Both examples would be a material change in facts.

  6. A tax shelter transaction is the same or substantially similar to a listed transaction that was identified by the IRS after the initial application was filed (see Listed transactions on page 1).

To amend Form 8264, enter in the space provided above Part I the tax shelter registration number previously issued to the tax shelter. If the tax shelter has not yet received the registration number, enter “Applied for” in the space. Complete the top portion of Part I above Item 1a, but only show in the remainder of Parts I through Part IV the information that has changed since the tax shelter was registered. In addition, you should include any other information that you did not know at the time the tax shelter was registered but have since learned. Complete the signature area on page 2. For further information, see A-45A of Temporary Regulations section 301.6111-1T.

The filing of an amended application will not affect the determination whether the initial application would be subject to any applicable penalty. In addition, if the initial application was timely filed and contained complete and accurate information, the penalty under section 6707 will not be imposed as a result of the information in an amended application.

Definitions

Principal organizer.   A person principally responsible for organizing a tax shelter is any person who discovers, creates, investigates, or initiates the investment, devises the business or financial plans for the investment, or carries out those plans through negotiations or transactions with others.

Participation in the organization of a tax shelter.   Participation in the organization of a tax shelter includes the performance of any act (directly or through an agent) related to the establishment of the tax shelter.

Participation in the management of a tax shelter.   Participation in the management of a tax shelter includes managing the assets of the tax shelter or directing or having supervisory authority for its business activities.

Participation in the sale of a tax shelter.   Participation in the sale of a tax shelter includes any marketing activities (directly or through an agent) with respect to an investment.

  For more detailed information concerning the terms defined above, see A-25 through A-33 of Temporary Regulations section 301.6111-1T.

Substantial investment.   A substantial investment is one in which the total amount that may be offered for sale to all investors exceeds $250,000 and at least five investors are expected. The total amount offered for sale is the total amount to be received from the sale of interests in the investment. It includes all cash, fair market value of property contributed, and indebtedness received in exchange for interests. For the purpose of determining whether five or more investors are expected in an investment involving real property (and related personal property) used as a farm for farming purposes, interests in the investment expected to be held by a husband and wife, their children and parents, and the spouses of their children will be treated as held by one investor.

Aggregation of similar plans or arrangements.   Generally, for purposes of determining whether investments are parts of a substantial investment, investments offered by the same person or related persons that involve similar business assets and similar plans or arrangements are aggregated. However, investments exempt from registration (see paragraphs 3 and 4 under Exemptions for tax shelters under section 6111(c) on page 2) because they are sold or leased to or involve rendition of services to persons who are reasonably expected to use the property or services for either personal use or in their principal active trade or business are not aggregated with similar investments by persons who are expected to use the property or services for other purposes. See A-22 and A-24A of Temporary Regulations section 301.6111-1T.

Tax shelter ratio.   The tax shelter ratio with respect to any year for any investor is the ratio that the aggregate amount of deductions and 350% of the credits that are represented or that will be represented as potentially allowable to an investor under subtitle A of the Internal Revenue Code, for all periods up to (and including) the close of the year, bears to the investment base for the investor as of the close of the year. Use the Tax Shelter Ratio Computation on page 2 of Form 8264 to compute tax shelter ratios.

  For purposes of computing the tax shelter ratio for a year, general partners in a limited partnership will not be treated as investors in the partnership if the general partners' aggregate interest in each item of partnership income, gain, loss, deduction, and credit for the year is not expected to exceed 2%. For purposes other than the computation of the tax shelter ratio, however, general partners will be treated as investors.

  The term year means the tax year of a tax shelter, or if the tax shelter has no tax year, the calendar year.

Potentially allowable deduction or credit.   A deduction or credit is considered to be represented as being potentially allowable to an investor if any oral or written statement is made in connection with the offering for sale of an interest in an investment indicating that a tax deduction or credit is available or may be used to reduce Federal taxable income or Federal income tax. Representations may be made, for example, as advertisements, written offering materials, prospectuses, or tax opinions, and include general representations that tax benefits are available. For example, an advertisement stating that “purchase of a restaurant includes trade fixtures (5-year write-off)” is considered an explicit representation of tax benefits. In addition, if any explicit representation is made regarding any tax benefit, all deductions or credits typically associated with the investment will be treated as having been represented as potentially allowable. See A-8 through A-12 of Temporary Regulations section 301.6111-1T and the instructions for Part III for additional information about potentially allowable deductions or credits.

Investment base.   The investment base for any year is the cumulative amount of money and the adjusted basis of other property (reduced by any liability to which the other property is subject) that is unconditionally required to be contributed or paid directly to the tax shelter by the investor before the close of the year. Amounts which reduce the investment base are listed in the instructions on page 7 for line 24 of Part III.

Transaction.   A transaction includes all of the factual elements relevant to the expected tax treatment of any investment, entity, plan, or arrangement, and includes any series of steps carried out as part of a plan. See Regulations sections 301.6111-2(a)(3) and 301.6112-1(b) for details.

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