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The Tax Increase Prevention and Reconciliation Act of 2005 Avoiding Excise Taxes and Making Proper Disclosures By Brian C. Bernhardt Darren GygiThe Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA), Pub. L. No. 109-222, 120 Stat. 345, was enacted on May 17, 2006. Section 516 of TIPRA imposes excise taxes and disclosure rules on certain types of tax-exempt entities (“Entities”) and entity managers (“Entity Managers”) who enter into or approve certain potentially abusiiv tax shelter...

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