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Exhibit 8.7.1-3
(11-06-2007)
Partial Allowance Letter (L2602) for Administrative Costs
| Internal Revenue Service |
Department of the Treasury |
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Date: |
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Tax Year(s): |
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Form Number: |
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| (Name and Address) |
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Person to Contact: |
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Contact Telephone Number: |
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Badge # |
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| We've completed our review of your claim for administrative costs under Section 7430 of the Internal Revenue Code. We allowed
the following part of your claim:
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| [List items and costs allowed for each item separately.] |
| We disallowed your remaining costs because: |
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For costs incurred after January 18, 1999, you didn't incur the costs on the earliest of: (1) after the date on which we sent
the first letter of proposed deficiency which allows the taxpayer an opportunity for administrative review in the IRS Office
of Appeals, (2) after the date you received the Appeals decision letter, or (3) the date of the notice of deficiency.
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For costs incurred between November 11, 1988 and January 18, 1999, you didn't incur the costs on or after the date you received
the Appeals decision letter or the date of the notice of deficiency, whichever is earlier.
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You incurred the remaining costs before November 11, 1988. |
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You unreasonably prolonged that part of administrative proceeding that applied to the costs we didn't allow. |
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You didn't give us enough information to decide if you're entitled to your remaining costs. |
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Other (Explain) |
| You may appeal this decision by filing a petition with the Tax Court for reasonable administrative costs. If this letter is
sent to you by registered or certified mail you must file your petition with the Tax Court before the 91st day after it was mailed. For more information on how to file a petition, please contact the Clerk of the Tax Court.
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| If you have any questions, please contact the person whose name and telephone number are listed above. |
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Sincerely, |
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Signature |
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(Title) |
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Letter 2602 (Rev. 5–99) |
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