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Can You Stop IRS Interest During Tax Court? The § 6603 Deposit Guide

A § 6603 deposit stops IRS interest on disputed tax without costing you the Tax Court. How it works, what it earns, and the deadline to keep it a deposit.

Liam Williams

Liam Williams

— 21 min read
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Interest on the tax you are disputing has run since your return's original due date, compounding daily. The rate for October to December 2026 is 7% a year. Filing a Tax Court petition does not pause it, and a case typically takes 6-18 months.

A deposit under IRC § 6603 can stop it. You send the IRS money, labeled in writing as a deposit, not a payment. If you lose, interest stops on the tax the deposit pays, as of the day the IRS received it.

The deposit concedes nothing and does not cost you the Tax Court. Until the IRS uses it, you can generally take it back with a letter. If you win, it comes back with interest at a lower rate (4% for October to December 2026) on the part you identified as disputed.

The deadline: a deposit the IRS already holds when a notice of deficiency (the "90-day letter") arrives becomes a payment, up to the deficiency and interest, when your 90-day period to petition ends, unless before then you petition and ask in writing that it stay a deposit.

Where To Start, Depending on Where You Are

What a Section 6603 Deposit Is

Congress added § 6603 in the American Jobs Creation Act of 2004, for deposits made after October 22, 2004. The working rules are in Rev. Proc. 2005-18, the IRS's published procedure for deposits, and in its staff manual, the Internal Revenue Manual (IRM). Where the sources leave a question open, this guide says so.

The statute does five things:

  • Allows the deposit (§ 6603(a)): cash toward income, estate, gift, generation-skipping or certain excise tax "which has not been assessed at the time of the deposit." Assessed means formally recorded by the IRS as owed.
  • Stops interest (§ 6603(b)): "To the extent that such deposit is used by the Secretary to pay tax, for purposes of section 6601 (relating to interest on underpayments), the tax shall be treated as paid when the deposit is made."
  • Returns it on request (§ 6603(c)): the IRS must return any unused amount "which the taxpayer requests in writing," unless it determines that collecting the tax is in jeopardy (at risk).
  • Pays some interest on a returned deposit (§ 6603(d)): only on the part that was "disputable tax," at the federal short-term rate, compounded daily.
  • Sets an order (§ 6603(e)): several deposits are used in the order made, unless you say otherwise, and returned last in, first out.

Congress's conference report on the 2004 Act puts the core idea in one line: "A deposit is not a payment of tax prior to the time the deposited amount is used to pay a tax" (H.R. Conf. Rep. No. 108-755, at 649 (2004)).

In its example, an individual deposits $20,000 on May 15, 2005, for a disputed item on the 2004 return, which was due April 15, 2005. On April 15, 2007, the examination ends with agreement that $25,000 is owed: the deposit pays $20,000 and the taxpayer pays the other $5,000. Interest on the $5,000 runs for two years, but on the $20,000 only for one month, to the May 15 deposit.

What a deposit does not do. It stops interest and nothing else: § 6603(b) treats the tax as paid early only "for purposes of section 6601," the interest provision. It does not reduce or concede the tax and penalties in dispute. And the IRS's manual says "IRC 6603 does not apply to employment taxes" (IRM 20.2.4.9.2).

Nor can a deposit cover tax already assessed. In Ahmed v. Commissioner, T.C. Memo. 2021-142, the petitioner sent $625,000 with a letter calling it a deposit, toward trust fund recovery penalties (TFRP) the IRS had already assessed. The petitioner conceded § 6603 did not apply, and the Court noted that these penalties are not among the taxes § 6603 lists. It held: "Because petitioner's TFRP liabilities had been assessed before he made his $625,000 remittance, it constituted payment of those liabilities."

The tax in a 30-day letter, a CP2000 or a notice of deficiency, though, is only proposed. Unless you agree to it or pay it, the IRS generally cannot assess it until the period to petition has run or, if you petition, until the Court's decision is final (IRC § 6213(a)).

Deposit or Payment: Why the Label Matters

A Tax Court case over a notice of deficiency needs a deficiency to decide: the extra tax the IRS says you owe. Under IRC § 6211(a), amounts "previously assessed (or collected without assessment) as a deficiency" are subtracted in working it out. So money the IRS treats as a payment, and assesses before it mails the notice, shrinks the deficiency the Court can hear or wipes it out. A deposit is not assessed, so it does not.

Before the notice, unlabeled money is generally a payment. Money sent without a written designation "will be treated as a payment," goes first to "the earliest taxable year for which there is a liability," which may not be the year you are disputing, and "may be assessed" (Rev. Proc. 2005-18 § 4.01(2)). The exception: money sent during an audit, before the IRS proposes a liability in writing, is treated as a deposit if you owe nothing else (§ 4.04(1)).

If unlabeled money covers the full amount an examiner proposed, "a notice of deficiency will not be mailed and the taxpayer will not have the right to petition the Tax Court" (§ 4.03; Treas. Reg. § 301.6213-1(b)(3) is to the same effect).

Two Tax Court cases show how the label plays out:

  • A cover letter saved the case. In Peacock v. Commissioner, T.C. Memo. 2020-63, one of the petitioners hand-delivered a check for the full amount an examiner proposed, with "payment" on the memo line. But his cover letter said he did "respectfully disagree completely" and that a request for Appeals review would follow. After an evidentiary hearing on the IRS's motion to dismiss, the Court held: "Petitioner husband properly designated the remittance as a deposit, respondent treated it as such, and the deficiency was never extinguished by a payment."
  • "Advance payment" lost it. In Bedrosian v. Commissioner, T.C. Memo. 2007-376, the petitioners sent about $4.28 million with a statement calling it an "advance payment," then argued it was a deposit. The Court read their words: the statement "states that the check is for an 'advance payment', not a deposit." The money was assessed before the notice they challenged, and the Court said: "We lack jurisdiction to consider deficiencies that have been paid before the issuance of a statutory notice of deficiency."

Hyde v. Commissioner, T.C. Memo. 2011-131 went the same way as Peacock, because the IRS had treated money sent before the notice as deposits and had not assessed it when it mailed the notice. Peacock left open whether a letter of disagreement alone would be enough. What the revenue procedure asks for is a written statement calling the money a deposit.

After the notice is mailed, paying no longer costs you the Court. Under IRC § 6213(b)(4), a payment made after the notice "shall not deprive the Tax Court of jurisdiction over such deficiency." Unlabeled money sent then is a payment you cannot take back on request (Rev. Proc. 2005-18 § 4.05(1)), but your case goes on. How IRC § 6213 Protects You While Your Tax Court Case Is Pending explains the rest.

What a Deposit Earns and What It Costs

For individuals, the underpayment and overpayment rates are both the federal short-term rate plus 3 percentage points (IRC § 6621(a)); a returned deposit earns the short-term rate alone. All three compound daily and are set each calendar quarter.

Annual rate October to December 2026
Underpayment: what you are charged on unpaid tax 7%
Overpayment: what the IRS pays an individual on tax overpaid 7%
§ 6603 deposit: what a returned deposit earns 4%

The IRS quarterly interest rates page lists the current rates, and How Interest Works on Your IRS Tax Debt explains how underpayment interest is figured.

Interest Only on the Disputed Part

A returned deposit earns interest only on its "disputable tax": your "reasonable estimate of the maximum amount of any tax attributable to disputable items," named when you make the deposit (§ 6603(d)(2)(A)). An item is disputable if you have a reasonable basis for your treatment of it and reasonably believe the IRS has a reasonable basis for disallowing it.

A 30-day letter sets a floor. It is "the first letter of proposed deficiency which allows the taxpayer an opportunity for administrative review in the Internal Revenue Service Independent Office of Appeals" (§ 6603(d)(3)(B); the audit guide explains it). Once you have one, your disputable tax is at least the deficiency it proposes (§ 6603(d)(2)(B)), and the IRS's manual counts its penalties and interest too (IRM 20.2.4.9.2).

No source this guide relies on says a notice of deficiency counts as a 30-day letter. Without a 30-day letter, you need the written statement described in What Your Letter Must Say.

The Trade-Off

If you lose, a deposit and a payment work the same way: both stop interest on what they cover from the day the IRS receives the money (Rev. Proc. 2005-18 § 8). The differences show if you win, or if you need the money back first.

Deposit Payment
Interest if you win 4% for October to December 2026, on the disputable part only 7% for October to December 2026, as an overpayment
Getting it back before the case ends A letter, any time before the IRS uses it, unless it finds collection in jeopardy Not on demand
Applied to other tax you owe (offset) The IRS cannot apply an excess deposit to it without your written request The IRS can apply an overpayment to it
Made before a notice of deficiency Keeps the Tax Court open Can cost you the Tax Court

In the conference report's words, amounts paid "generally cannot be recovered by the taxpayer on demand, but must await final determination of the taxpayer's liability." The IRS's manual sets out the two offset rules (IRM 20.2.4.9.2.2).

Once the notice has been mailed, paying no longer costs you the Tax Court, so the choice is about money. If you will not need the money back, a payment earns more if you win; if you might, only a deposit can be taken back with a letter. Sending nothing keeps the money in your hands, but if you lose, interest at the underpayment rate keeps compounding daily on what you owe until you pay (IRC § 6601(a); § 6622). Neither the statute nor the IRS's guidance picks one for you.

Before 2004 the choice was harsher. The Sixth Circuit said the old IRS procedures "forced taxpayers to choose: immediate access without interest, or interest without immediate access" (Ford Motor Co. v. United States, 768 F.3d 580 (6th Cir. 2014)). Section 6603 narrowed that gap but did not close it.

Hill v. Commissioner, T.C. Memo. 2021-121 shows the gap in dollars. The petitioner's representative sent about $10.26 million, designated as a § 6603 deposit, toward an expected gift tax. The Court's decision, agreed by both sides, found a $6.79 million deficiency, and the IRS returned the $3,473,750 excess without interest.

The IRS then conceded interest at the short-term rate, which it computed at $218,122 through September 30, 2021. The petitioner, now calling the money a payment, claimed $1,267,323 at the overpayment rate. The Court computed neither figure: it held it had no power to redetermine the interest, because its decision had found no overpayment (see below).

Interest the IRS pays you is generally taxable interest income (IRS Topic No. 403).

How To Make a Deposit

How Much To Deposit

A deposit can be "for all or part of the amount you think you will owe" (Publication 3498), but it stops interest only on what it covers, and interest also runs on interest. To stop all of it, the IRS's Appeals manual says the money you send must cover "all accrued interest as of the date of remittance as well as the entire amount of the underlying tax and penalty (if applicable)" (IRM 8.7.17.5.3). Otherwise, as Publication 3498 says, "interest will continue to accrue on accrued interest, even though you have paid the underlying tax."

Interest on the accuracy-related penalty, the civil fraud penalty and the late-filing penalty runs from the return's due date, including extensions (IRC § 6601(e)(2); see the accuracy penalty guide). On most other penalties, interest starts only if you have not paid within 21 days of the IRS's bill (10 business days if it is $100,000 or more), and then runs from the bill's date. The late-payment penalty on a deficiency is triggered the same way (the § 6651 guide).

To estimate the interest, ask the examiner, the Appeals officer or, once your case is filed, the IRS attorney for a computation. For a rough figure first, the interest guide's table shows how daily compounding adds up. The IRS lawyers' manual, written for settlement payoffs, has them give a computation "including tax, penalties and estimated interest" in certain settlements and "whenever requested by the petitioner" (CCDM 35.5.2.8).

A reasonable estimate of accrued interest counts as disputable tax, but any part of a deposit beyond your disputable tax generally earns no interest if it comes back (IRM 20.2.4.9.2 and its subsections).

If the IRS claims a larger deficiency during the case, interest on the increase also runs from the return's original due date (the § 6214 guide), and you can deposit more to cover it.

What Your Letter Must Say

Rev. Proc. 2005-18 § 4.01(1) calls for "a check or a money order accompanied by a written statement designating the remittance as a deposit," and the statement "also must include: (a) The type(s) of tax; (b) The tax year(s); and (c) The statement described in section 7.02 identifying the amount of and basis for the disputable tax." So the letter covers:

  1. That it is a deposit, in so many words: a deposit under IRC § 6603 and Rev. Proc. 2005-18, not a payment of tax. The IRS's Appeals manual lists "Pursuant to IRC 6603" and "Rev. Proc. 2005-18" as wording that is enough (IRM 8.7.17.5.1). The old label is out: a deposit made since § 6603 took effect "cannot be designated as a deposit in the nature of a cash bond" (IRM 20.2.4.9.2.1).
  2. The type of tax and the year, such as income tax for 2023.
  3. The disputable tax. A copy of your 30-day letter will do (§ 7.03). Without one, or if your disputable tax is more than it proposed, § 7.02 requires a statement with your calculation of the disputable tax (it allows "any reasonable method"), a description of each disputed item, and why you have a reasonable basis for your treatment and believe the IRS has one for disallowing it.
  4. Who you are, a practical addition the revenue procedure does not list: the name and taxpayer identification number on the return in dispute (both spouses, for a joint return), and your docket number once your case is filed.
  5. Any split you want. No source this guide relies on sets how a designated deposit is divided among tax, penalty and interest, though the IRS's manual shows one can post to each (IRM 20.2.4.9.2.1). If you want a split, say so.

As a practical step, write on the check's memo line that it is an IRC 6603 deposit, with the year, and never "payment": in Peacock, the Court looked past that word only because of what the cover letter said.

Where and How To Send It

By check or money order, to the right office: the IRS service center where you are required to file your return, or the office examining it (Rev. Proc. 2005-18 § 4.01(1)). Keep copies and proof of mailing.

Once your case is filed, no source this guide relies on names a different office, so the service center where you are required to file your return is still the one a source names. A practical step, not a rule: once the IRS has filed its Answer, which it has 60 days to do after the Court serves your petition, ask the IRS attorney who signed it, or the Appeals officer if Appeals has your case, where to send the deposit, and send the attorney a copy of your letter.

Appeals does process deposits, but not cash: "Because Appeals does not have a teller function, cash payments cannot be accepted" (IRM 8.7.17.2). And the deposit goes to the IRS, not to the Tax Court.

Not through IRS Direct Pay. It has no deposit option. Its "Proposed tax assessment (e.g. CP 2000 or a Notice of Deficiency)" choice is described as a way to "Make a full or initial payment for a proposed amount" (Direct Pay payment types). That is a payment; made in full before a notice of deficiency, it risks losing the Tax Court (§ 4.03).

EFTPS (the Electronic Federal Tax Payment System) only with care. The IRS's own lawyers advised in 2007 that taxpayers "are not legally precluded from using EFTPS to electronically remit section 6603 deposits," and recommended sending the written designation to the examining office before the transfer (CCA 200709062, legal advice that is not precedent). The sources do not confirm that the EFTPS screens individuals use offer a deposit choice.

If your case began with a CP2000, Publication 5181 says you can stop interest by paying the full proposed tax, penalties and interest and "designating your payment as a '6603 deposit'," with a copy of the notice or a statement giving the same information. See How To Respond to a CP2000 Notice. If a notice of deficiency follows, take the steps in If You Deposited Before the Notice of Deficiency.

Then check your transcript. A deposit posts as transaction code 640, which a transcript may label an advance payment even for a deposit (IRM 20.2.4.9.2.1; IRM 8.7.17.5.3). In Peacock, the Court found that code "not inconsistent with the treatment of the remittance" as a deposit. How To Read IRS Transcript Codes explains the codes, and How To Get and Read Your IRS Transcripts how to get a transcript.

If You Deposited Before the Notice of Deficiency

A deposit made before the notice does not stay a deposit on its own once a notice of deficiency is mailed. Under Rev. Proc. 2005-18 § 4.02(2), it is posted as a payment, up to the deficiency plus accrued interest, when your 90-day period to petition ends (150 days if the notice was addressed to you outside the United States), "unless the taxpayer files a petition with the Tax Court and requests in writing before the expiration of that period that the deposit continue to be treated as a deposit during the applicable Tax Court proceeding."

The revenue procedure words the rule for a deposit made during an audit; the IRS's Appeals manual applies it to any deposit received before the notice (IRM 8.7.17.5.3). So a deposit made after a CP2000 needs the same steps.

Two steps, both before that period ends:

  1. File your petition. How To File Your Tax Court Petition walks through it, and You Just Got a 90-Day Letter From the IRS explains the notice.
  2. Ask in writing that the deposit stay a deposit during the case. The revenue procedure says nothing more about the request. Practical steps, not rules: give the deposit's date and amount, the tax and the year, say you have petitioned, and send it to the office holding the deposit. Send it well before the period ends, and keep proof of mailing.

Petitioning alone is not enough. If you do not write, the deposit becomes a payment when the period ends, though the tax is assessed "subject to the restrictions imposed by section 6213," so your case goes on (IRM 8.7.17.5.3 says the same).

If it becomes a payment, you can no longer take it back with a letter (Rev. Proc. 2005-18 § 6.01), so the money stays with the IRS until the case ends. If you win, the excess is an overpayment: under the IRS's manual, it earns the deposit rate on its disputable part until it became a payment, then the overpayment rate until it is refunded (IRM 20.2.4.9.2.1). But "the IRS may offset the overpayment on its own accord" against other tax you owe (IRM 20.2.4.9.2.2).

So keeping it a deposit keeps the money within reach and away from your other debts, while letting it become a payment earns a higher rate on any excess if you win. The rules leave that choice to you.

During and After Your Tax Court Case

You can deposit at any time before the decision is final. A deposit covers tax "which has not been assessed at the time of the deposit," and once you petition, the IRS cannot assess the deficiency "until the decision of the Tax Court has become final" (IRC § 6213(a)). Tell the IRS attorney, and Appeals if it has your case, about any deposit you have made; What Happens After You File Your Tax Court Petition explains who they are.

When the decision is final, the deficiency the Court decides "shall be assessed" (IRC § 6215(a)), and your deposit is applied to it as a payment, up to the deficiency plus accrued interest (IRM 20.2.4.9.2.1). Interest on the part it covers stops as of the day the IRS received the deposit, "regardless of when the liability is assessed or the remittance is actually applied against the taxpayer's account" (Rev. Proc. 2005-18 § 8).

Any excess stays a deposit and comes back with interest at the deposit rate on its disputable part. The IRS "may not, on its own accord, offset an excess 6603 deposit to an outstanding tax liability" (IRM 20.2.4.9.2.2); moving it to another year takes your written request.

The Court's interest power is narrow. On a motion filed within a year after a regular-case decision is final, the Tax Court can reopen the case to redetermine interest of two kinds: interest on the deficiency assessed after the decision, once you have paid that deficiency and the interest the IRS claims, and interest on an overpayment it "finds under section 6512(b)" (IRC § 7481(c)). So if you lose and the IRS charges interest past the day it received your deposit on what the deposit paid, you can ask the Court by motion to redetermine it (the § 7481(c) motion).

The statute counts that year from finality under § 7481(a); a small tax case decision becomes final under § 7481(b) instead, and no source this guide relies on says whether a small case can use the motion.

Interest the IRS owes you on a deposit it returns is another matter: in Hill the decision had found no overpayment, because "petitioner had not made a payment of tax for any relevant year at the time our decision was entered," so the Court could not reach it. That left the deposit interest to the IRS.

A deposit is not an appeal bond. It "is not a substitute for a bond to stay assessment and collection described in section 7485" (Rev. Proc. 2005-18 § 4.05(2)); What Happens After Your Tax Court Decision explains the bond. If you lose and owe more than the deposit covers, How To Set Up an IRS Installment Agreement covers paying over time.

Getting Your Deposit Back

Ask in writing, at any time before the IRS has used the deposit for a payment of tax (Rev. Proc. 2005-18 § 6.01). Write to the office you sent it to (the revenue procedure names the service center or examining office), giving the date and amount of each deposit, the type of tax and the tax year (§ 6.02). The IRS must return it unless it determines that collecting the tax is in jeopardy (§ 6603(c)).

No refund claim is needed. In Hill, the Court said the deposit designation "provided petitioner with an important benefit, as his advisers surely knew: He could demand the immediate return of his deposit at any time." A payment, by contrast, comes back only through a refund claim (IRM 8.7.17.5.4) or as an overpayment at the end of the case.

Withdrawing mid-case has a cost. If the tax is later assessed after all, "the running of interest will not be suspended during the period for which the remittance was held as a deposit" (Rev. Proc. 2005-18 § 8).

Check the interest. It runs on the disputable part from the deposit date to a date "not more than 30 days preceding the date of the check" (§ 6.03), and the IRS computes it by hand: "There is no systemic means to identify and allow a Master File calculation of allowable interest on 6603 deposits" (IRM 20.2.4.9.2.1). It posts as transaction code 770.

In Hill, the IRS returned the excess without interest and said it had not erred because "it does not appear that petitioner has made a formal claim for this interest other than the Motion filed in this case." If yours arrives without interest, ask for it in writing.

If the IRS will not return it, the Tax Court is not the place to sue. A footnote in Hill said in passing that the route would be a suit in federal district court or the Court of Federal Claims.

Refund suits. Suing for a refund in another court instead means paying the tax in full first, under Flora v. United States, 362 U.S. 145 (1960) (the forum guide explains). No court decision or IRS guidance this guide relies on says whether an unused deposit counts toward that; the sources say only that a deposit is not a payment until it is used.

Common Mistakes

  1. Leaving out the word "deposit." Unlabeled money is a payment, applied to your earliest year with a balance (Rev. Proc. 2005-18 § 4.01(2)). An "advance payment" label cost the petitioners in Bedrosian.
  2. Paying the full proposed amount, unlabeled, before a notice of deficiency. No notice, no Tax Court (§ 4.03).
  3. Using Direct Pay. It has no deposit option.
  4. Leaving out the 30-day letter or disputable-tax statement. The money is still a deposit, since disputable tax "is relevant only in determining whether the taxpayer is entitled to interest on his deposit" (Hill). But it earns no interest if returned until you supply the statement, and then only from that date (§ 7.04).
  5. Covering the tax but not the interest. Interest keeps compounding on what you left out.
  6. Missing the written request when a notice of deficiency arrives after you deposited (above).
  7. Depositing for the wrong bill. A deposit cannot cover tax already assessed (Ahmed) or employment taxes, and it does not stop collection of assessed debts (Collection Due Process Hearings).
  8. Using the wrong name. In Dillon Trust Co. LLC v. United States, No. 2024-1314 (Fed. Cir. May 14, 2026), the Federal Circuit upheld the IRS's refusal to apply successor trusts' deposits to the original trusts' tax, holding that § 6603(a) "explicitly grants the IRS discretion in choosing whether to apply a deposit as a payment against a taxpayer's liability." Deposit in the name and taxpayer identification number of whoever owes the tax.
  9. Expecting to relabel it later. In Hill, the Court knew of no authority "that the IRS can unilaterally overrule a taxpayer's designation of a remittance as a 'deposit.'" The IRS's lawyers say a taxpayer can convert a deposit into a payment only "by agreeing to the assessment of the specific liability that the deposit was made to satisfy" (PMTA 2010-23, legal advice that is not precedent), and its current manual says no provision of § 6603 or Rev. Proc. 2005-18 "permits a taxpayer to convert a designated deposit to a payment" (IRM 20.2.4.9.2.4).
  10. Waiting for the IRS to mention it. It need not. In Verghese v. Commissioner, T.C. Memo. 2021-70, the IRS had long published guidance on deposits, so the Court, granting the IRS partial summary judgment, held that "petitioners' failure to make a deposit to halt interest accrual cannot be attributed to delay or failure of the IRS to advise them personally of this information," and it was no ground to remove interest (the § 6404 guide).

What To Do Now

  1. Add up the exposure: tax, penalties and interest to the day you will send the money, or ask the IRS for a computation.
  2. Decide whether you might need the money back before the case ends. Only a deposit comes back with a letter.
  3. Get your disputable-tax support: a copy of your 30-day letter, or a statement of the disputed items, the amount and your reasons.
  4. Write the letter: a deposit under IRC § 6603 and Rev. Proc. 2005-18, not a payment; the tax and year; your name and taxpayer identification number; your docket number if you have one.
  5. Send a check or money order, not Direct Pay, to the service center or examining office (in a filed case, ask the IRS attorney or Appeals officer once you know who they are). Keep proof of mailing.
  6. If the deposit came before a notice of deficiency, petition and send the written request before the 90-day period ends.
  7. Check your transcript for transaction code 640 (even if it reads "advance payment"), and later for code 770 when interest is paid.
  8. When the case ends, ask in writing for any excess and check the interest.
  9. For help with the letter or the numbers, a Low Income Taxpayer Clinic may be able to assist.

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This article is for informational purposes only and does not constitute legal or tax advice. For advice specific to your situation, consult a qualified tax professional or attorney.

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