90 STAT. 1664
PUBLIC LAW 94-455—OCT. 4, 1976 "(B) within 30 days after the date on which a court decision under subsection (f)(3) becomes finaL " (2) POSTPONEMENT BY ORDER or COURT.—The court may extend the period referred to in paragraph (1)(B) for such time as the court finds necessary to allow the Secretary to comply with its decision. "(3)
POSTPONEMENT OF DISCLOSURE FOR UP TO 9O DAYS.—At the
written request of the person by whom or on whose behalf the request for the written determination was made, the period referred to in paragraph (1)(A) shall be extended (for not to exceed an additional 90 days) until the day which is 15 days after the date of the Secretary's determination that the transaction set forth in the written determination has been completed. "(4) ADDITIONAL I 8 0 DAYS.—If—
"(A) the transaction set forth in the written determination is not completed during the period set forth in paragraph (3), and "(B) the person by whom or on whose behalf the request for the written determination was made establishes to the satisfaction of the Secretary that good cause exists for additional delay in opening the written determination to public inspection, the period referred to in paragraph (3) shall be further extended (for not to exceed an additional 180 days) until the day which is 15 days after the date of the Secretary's determination that the transaction set forth in the written determination has been completed. "(5)
26 USC 412.
SPECIAL RULES FOR CERTAIN WRITTEN DETERMINATIONS,
ETC.—Notwithstanding the provisions of paragraph (1), the Secretary shall not be required to make available to the public— "(A) any technical advice memorandum and any related background file document involving any matter which is the subject of a civil fraud or criminal investigation or jeopardy or termination assessment until after any action relating to such investigation or assessment is completed, or "(B) any general written determination and any related background file document that relates solely to approval of the Secretary of any adoption or change of— "(i) the funding method or plan year of a plan under section 412, "(ii) a taxpayer's annual accounting period under section 442, "(iii) a taxpayer's method of accounting under section 446(e), or "(iv) a partnership's or partner's taxable year under section 706, but the Secretary shall make any such written determination and related background file document available upon the written request of any person after the date on which (except for this subparagraph) such determination would be open to public inspection. " (,h) DISCLOSURE OF PRIOR WRITTEN DETERMINATIONS AND RELATED BACKGROUND FILE DOCUMENTS.—
"(1) IN GENERAL.—Except as otherwise provided in this subsection, a written determination issued pursuant to a request made
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