摘要：

Form 13750 Election to Participate in Announcement 2005-80 OMB No. 1545-1970(October 2005)Settlement InitiativeYou must provide all the information required under this Election by January 23, 2006 (or as otherwiseNote stipulated in subsequent requests from the Service for additional information) to be eligible for the settlement.Section I Taxpayer DataI elect to participate in the settlement initiative as described in Announcement 2005-80 and as contained in InternalRevenue Bulletin 2005-46 dated November 14, 2005.1. Taxpayer name(s) (Include name of spouse if joint return) 2. Taxpayer(s) IdentificationNumber (EIN or SSN)3. Address (Street, City, State, ZIP code) 4. Telephone number( )5. FAX number( )6. Are you currently under examination or in Appeals 7. Are/were you (or your spouse) a partner in a TEFRA partnershipthat was a party to the arrangement(s) identified in Section IIYes (Please complete items 8a and 8b)Yes (Complete items 9a & 9b and Section III)No (Please provide copies of all relevant taxreturns with your election submission) No8a. Name and address (Street, City, State, ZIP Code) of 9a. Name and address (Street, City, State, ZIP Code) ofIRS contact for your current examination or Appeals IRS contact for the TEFRA Partnership examinationmatter (If applicable) or Appeals matter (If applicable)8b. Telephone number of IRS contact 9b. Telephone number of IRS TEFRA contact( ) ( )10. Have you received a Statutory Notice of Deficiency Yes No11. Has the TEFRA Partnership received a Notice of Final Partnership Administrative Adjustment Yes No12. Do you have a Power of Attorney (If Yes, attach a copy to this election) Yes No13. Have you filed an amended return(s) for any of the years in which you engaged inYes Nothis transaction(s) (If Yes, attach a copy or copies to this election)Settlement Initiative Transactions Elected by TaxpayerSection II(For each box checked below, complete a separate Form 13750, Schedule A and attach it to your election)Notice 2002-21 (20% penalty) Notice 2003-77 (5% penalty)Notice 2001-16 (20% penalty) Notice 2003-24 (5% penalty)Notice 2003-55 (10% or 20% penalty) Revenue Ruling 2003-6 (5% penalty)Notice 2003-54 (10% penalty) Revenue Ruling 2002-3 & 2002-80 (5% penalty)Notice 2003-81 (10% penalty) Notice 2000-60 (5% penalty)Notice 99-59 (10% penalty) Revenue Ruling 2000-12 (5% penalty)Revenue Ruling 2004-98 (5% penalty) Notice 95-34 (5% penalty)Revenue Ruling 2004-20 & 2004-21 (5% penalty) Treasury Regulation § 1.643(a)-8 (5% penalty)Notice 2004-8 (5% penalty) Notice 2004-41 (5% penalty)Revenue Ruling 2004-4 (5% penalty) Notice 2004-7 (5% penaltyManagement S Corporation ESOP Transactions (5% penalty)Catalog No. 47521K www.irs.gov Form 13750 (10-2005)Page 2 of 4Section III Ineligible Taxpayer Special Request for InclusionI am ineligible to participate in the Announcement 2005-80 settlement initiative because – (Check all that apply)I am a promoter as outlined in Section 2, paragraph 1 of the AnnouncementI am a person related to a promoter as outlined in Section 2, paragraph 2 of the AnnouncementI am a TEFRA partner or promoter as outlined in Section 2, paragraph 3 of the AnnouncementDespite my ineligibility, I request that the Service permit settlement under this initiative for the following reason(s)Section IV PenaltiesI may qualify for a 0% penalty under IRC § 6662 for the following reasons (Check all that apply)1. I filed a disclosure under Announcement 2002-22. I obtained a written tax opinion by an independent tax advisor (If box is checked, please complete a separateForm 13750, Schedule B for each issue to which the opinion applies and attach it to your election).Under penalties of perjury, I declare that I have examined these statements, accompanyingschedules, and attachments, and to the best of my knowledge and belief, they are true, correct,and complete.Signature of Taxpayer DateTaxpayerAttestationSignature of Taxpayer DateInstructions• Send your completed Form 13750 and all required • If you are under examination (or in Appeals) or if anyattachments to: TEFRA partnership in which you

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