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Section 414(m) of the Internal Revenue Code. To obtain a full determination on this issue, send all information indicated in section 5.01 of Rev. Proc. 85-43, 1985-2 C.B. 501. Specifically, the information requested in section is needed. Send information showing, on the basis of all relevant facts and circumstances, whether or not the principal business of any of the organizations is the performance of management services, on a regular and continuing basis, for another organization (or organizat.

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