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It's my understanding that it would be the simplest route to take by using your remedy. Just send them a CPN and be certain to have it notarized. This discharges the whole enchilada. Then you can move on to bigger and better things by freeing up your valuable time.
Just a thought on the matter.
Doc
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Doc,
I am in agreement with Rushpat. It is not that simple. A friend of mine has tenderd around 8 BoEs for the same claim from the IRS and all has been ignored. We are now in the process of getting the stipulation that the BoEs are sufficient. Once that is done the Chief Counsel of the IRS will be drafted with the evidence of the stipulation.
iamfreeru2