Industry Issue Resolution Pilot Program under Notice 2000-65
Financial Services Issues To return to the Discussion text, close this window. Endnotes 1 2000-52 I.R.B. 1. 2 See General Explanation of the Tax Reform Act of 1986 (JCT Bluebook) p. 532, where the Congress directed the Secretary of the Treasury to study and issue a report concerning "under what circumstances a rule providing for a conclusive or rebuttable presumption of the worthlessness of an indebtedness is appropriate." See also the Treasury Department response, Report to the Congress on the Tax Treatment of Bad Debts by Financial Institutions, (Treasury study) dated September 1991 which addressed both bad debts and non-accruals. 3 See e.g. FSA 20001817. 4 See e.g. Chief Counsel Advice 200027036, where the National Office spells out the three bases under which the conformity election can be revoked by the IRS, but specifically does not limit the inquiry of IRS agents to those three points. 5 See Coordinated Issue Paper dated June 21, 1993. 6 See Treasury study pp. 24–28. 7 ILM 200045030 (September 27, 2000). 8 212 F. 3d. 822 (3d Cir. 2000), rev’g 110 T.C. 349 (1998). BACK TO TOP |