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ac ac Al Ullman amendment amount approved assets benefits billion bonds capital gains carryover basis charitable Code Commissioner costs deduction deferred depreciation distribution dividends earnings employees energy estate tax exclusion exempt expenses filed firm foreign tax credit Fund holding company income tax increase individual retirement account inflation interest investment IRS RULINGS issued letter liability loss Means Committee Notes Microfiche Edition partnership payments pension percent premiums prior ruling proposed regulations purchase qualify received Revenue Senate Finance Committee Service has held Service has ruled shareholders social security subsidiary T.C. Memo tax cut tax free Tax Notes Microfiche tax rate taxation taxpayer technical advice transfer Treasury Secretary trust UJ UJ UJ value-added tax vote Wall Street Journal Washington Washington Star windfall profits tax windfall tax