INTERNAL PROTOTYPE — NOT LEGAL ADVICE — DO NOT SEND

26 U.S.C. § 42

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26 U.S.C. § 42
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26 U.S.C. § 42

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by using a discount rate equal to 72 percent of the average of the annual Federal mid-term rate and the annual Federal long-term rate applicable under section 1274(d)(1) to the month applicable under clause (i) or (ii) of subparagraph (A) and compounded annually, and (iii)