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This according to a private letter ruling. He enphasized this was not a guarantee.

A word about private letter rulings:

A private letter ruling applies only to the particular taxpayer asking for the ruling and is not applicable to all taxpayers.

If you want definitive interpretations on the matter, seek a Treasury Regulation. For a TR, The Secretary of the Treasury has been authorized by Congress to prescribe and issue regulations needed for enforcement of the IRC. A regulation explains and interprets a particular code section.

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