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You provide an initial notice to consumers who are your customers on July 1,2001, if, by that date, you have established a system for providing an initial notice to all new customers and have mailed the initial notice to all your existing customers. The IRS coordinates its audit of the partnership through the "tax matters partner," but is required by section 6223(a) to provide notice to all partners of (1) the beginning of an administrative proceeding at the partnership level, and (2) the final partnership administrative adjustment resulting from any such proceeding. |
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