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Internal Revenue Service Memorandum - IRS tax forms

Office of Chief CounselInternal Revenue ServiceMemorandumNumber: 201310028 Release Date: 3/8/2013CC:ITA:B07: --------------POSTF-125143-12 Third Party Communication: n/aDate of Communication: : October 9, 2012to:Attorney, CC:LB&I:RFPH:CH2 Mfrom: Branch Chief, Branch 7, CC:ITA:7(Income Tax & Accounting) subject: Qualified leasehold improvement property under 168(e)(6)This Chief Counsel Advice responds to your request for assistance. This advice may not be used or cited as the installation of an HVAC unit, either located on the roof of a building or located on a concrete pad adjacent to the building, constitutes qualified leasehold improvement property ( QLIP ) pursuant to 168(e)(6) of the Internal Revenue Code?

Office of Chief Counsel Internal Revenue Service Memorandum Number: 201310028 Release Date: 3/8/2013 CC:ITA:B07: -----POSTF-125143-12 Third Party Communication: n/a

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