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Attach to the Form 8038-GC a letter briefly stating why Form 8038-GC was not submitted to the IRS on time. Each such separate return should specify the calendar year in which the issue was issued. An issuer of a tax-exempt bond used to finance construction expenditures must file a separate Form 8038-GC for each issue to give notice to the IRS that an election was made to pay a penalty in lieu of arbitrage rebate see line 9 instructions. In the ca.

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