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Revenue. Petitioners point out that they were first notified by
a January 26, 1996, letter from James Moody, Revenue Agent,
Income Tax Division, Montana Department of Revenue, that their
file had been referred for audit to the Department of Revenue in
conjunction with a joint project between the Department of
Revenue and respondent. Petitioners further contend that the
Department of Revenue did not make a written request to
respondent to disclose petitioners' return information and that
this violates section 6103(d).1
1 Sec. 6103(a) and (d) provides as follows:
SEC. 6103. CONFIDENTIALITY AND DISCLOSURE OF RETURNS
AND RETURN INFORMATION.
(a) General Rule.--Returns and return information shall
be confidential, and except as authorized by this title--
(1) no officer or employee of the United States,
(2) no officer or employee of any State, any local
child support enforcement agency, or any local agency
administering a program listed in subsection (1)(7)(D) who
has or had access to returns or return information under
this section, and
(3) no other person (or officer or employee
thereof) who has or had access to returns or return
information under subsection (e)(1)(D)(iii), paragraph (2)
or (4)(B) of subsection (m), or subsection (n), shall
disclose any return or return information obtained by him in
any manner in connection with his service as such an officer
or an employee or otherwise or under the provisions of this
section. For purposes of this subsection, the term "officer
or employee" includes a former officer or employee.
* * * * * * *
(d) Disclosure to State Tax Officials and State
(continued...)
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