Transcription of DEPARTMENT OF THE TREASURY INTERNAL REVENUE …
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OFFICE OFCHIEF COUNSELDEPARTMENT OF THE TREASURYINTERNAL REVENUE SERVICEWASHINGTON, 20224 August 2, 2001 Number: 200145010 Release Date: 11/9/2001CC:FIP:1/TL-N-2503-01 UILC: REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICEMEMORANDUM FOR FROM:LON B. SMITHACTING ASSOCIATE CHIEF COUNSEL (FINANCIALINSTITUTIONS AND PRODUCTS) CC:FIPSUBJECT: This Chief Counsel Advice responds to your memorandum dated May 2, 2001.
The swap entered into with Counterparty A (Swap C) required Taxpayer to pay the fixed rate of e%, with Counterparty A paying the floating rate, which was f% for the initial calculation period.
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