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A transaction that IRS and Treasury believe has a potential for tax avoidance, but for which they lack enough information to determine whether the transaction should be identified specifically as a tax avoidance transaction. The AJCA revised Sections 6111 and 6112, thereby modifying regulations under Reg. Sec. 1.6011-4 and elsewhere.

Synonyms: TOI, transactions of interest
Synonyms list (a comma-separated list)
TOI, transactions of interest