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Abstract: 

In PLR 200332020, the IRS granted a private foundation extra time to dispose of business holdings received from the estate of the foundation’s founder. The facts as stated in the ruling are confusing due to the use of letters to avoid disclosing the identity of the parties (for example, “In J you received additional shares of A which brought your ownership interest to F%.”) So let us make it easy by assuming that the foundation received a major share of the stock of three different golf clubs.

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