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F. Francis (613)957-3498
July 14, 1988
Dear Sirs:
This is in reply to your letter of June 23, 1988, wherein you requested a technical interpretation with respect to an employee benefit plan (the "Plan").
Since the Plan represents a factual completed transaction involving specific taxpayers, we suggest that you consult with the local District Taxation Office to discuss the tax implications.
Yours truly,
for Director Financial Industries Division Rulings Directorate