The comments listed represent the views of the ABA Section of Taxation. They have not been approved by the House of Delegates or the Board of Governors of the American Bar Association and should not be construed as representing the policy of the Association. Documents are provided in Adobe Acrobat format unless otherwise indicated.
November 30, 2007
2007 Regulatory and Legislative Submissions
U.S. Treasury Department & IRS
- Proposed Regulations Relating to Limitation on Estates or Trusts Deductions (REG-128224-06) (Oct. 23, 2007)
I.R.C.§: 67(e)
- Comments in Response to IRS Notice 2007-39, on the Application of Monetary Penalties in Disciplinary Procedure under Section 822 of the American Jobs Creation Act of 2004 (Oct. 5, 2007)
I.R.C.§: 822
- Comments Concerning Discussion Draft of Redesigned Form 990 for Tax-Exempt Organizations (Oct. 4, 2007)
I.R.C.§: n/a
- Comments Concerning Low-Income Housing Qualified Contract Proposed Regulations (Sep. 28, 2007)
I.R.C.§: n/a
- Comments Concerning Internal Revenue Code Section 409A Relating to Compliance Deadline (Sep. 21, 2007)
I.R.C.§: 409A
- Survey Report on Independence of IRS Appeals (Sep. 19, 2007)
I.R.C.§: n/a
- Comments Concerning Proposed Regulations Under Section 152(e) of the Internal Revenue Code (Sep. 19, 2007)
I.R.C.§: 152(e)
- Comments on Proposed Regulations under Section 1367 of the Internal Revenue Code regarding the Treatment of Open Account Debt of S Corporations (Aug. 31, 2007)
I.R.C.§: 1367
- Comments in Response to Notice and Request for Comments on Form 709, United States Gift (and Generation-Skipping Transfer) Tax Return (Aug. 20, 2007)
I.R.C.§: n/a
- Comments in Response to IRS Notice 2007-21 on Treasury Study on Donor Advised Funds and Supporting Organizations (Aug. 1, 2007)
I.R.C.§: n/a
- Comments Concerning Proposed Regulations Relating to Deductions for Claims Against an Estate under Section 2053 (July 24, 2007)
I.R.C.§: 2053
- Comments on Proposed Regulations Relating to Payment In Lieu of Taxes under Section 1.141-4 of the Treasury Regulations (July 10, 2007)
I.R.C.§: n/a
- Comments on Proposed Regulations Related to the Payment of Tax Liabilities in Installments (July 2, 2007)
I.R.C.§: 6159
- Recommendations for 2007-2008 Guidance Priority List (June 18, 2007)
I.R.C.§: n/a
- Recommendations for Improved Tax Administration Related to Section 409A (June 14, 2007)
I.R.C.§: 409A
- Comments on Final Regulations Defining the Term “Statutory Merger or Consolidation” (T.D. 9242) (June 11, 2007)
I.R.C.§: n/a
- Comments in Response to IRS Notice 2006-109 on the Application of the Pension Protection Act of 2006 to Donor Advised Funds and Supporting Organizations (June 4, 2007)
I.R.C.§: n/a
- Comments under Internal Revenue Code Section 409A Concerning Calculation and Timing of Income Inclusion, Reporting, and withholding (April 25, 2007)
I.R.C.§: 409A
- Comments Concerning Notice 2006-14 (April 25, 2007)
I.R.C.§: n/a
- Comments on Temporary and Proposed Section 482 Regulations on Services and Other Issues (April 23, 2007)
I.R.C.§: 482
- ABA Section of Taxation Proposed Revision of Rev. Proc. 86-42 (April 10, 2007)
I.R.C.§: n/a
- Comments Concerning Proposed Revisions to Form 8857 and Related Instructions (March 30, 2007)
I.R.C.§: n/a
- Comments on Proposed Regulations Regarding the Identity of the Taxpayer for Purposes of Section 901 and 903 (March 22, 2007)
I.R.C.§: 901 and 903
- Comments Concerning the Proposed Regulations Under Sections 6011, 6111, and 6112 (March 5, 2007)
I.R.C.§: 6011, 6111, 6112
- Comments on Procedures for Requesting Accounting Method Changes (Feb. 27, 2007)
I.R.C.§: n/a
- Comments on Proposed Regulations under Section 1221(a)(4) (Feb. 22, 2007)
I.R.C.§: 1221(a)(4)
- Comments Concerning a New Category of Reportable Transaction Covering Patented Tax Strategies (Feb. 21, 2007)
I.R.C.§: n/a
- Comments Concerning Proposed Regulations Relating to Exchanges of Property for an Annuity (Feb. 15, 2007)
I.R.C.§: n/a
- Comments Concerning Section 4965 of the Internal Revenue Code of 1986 (Feb. 5, 2007)
I.R.C.§: 4965
- Comments Concerning Temporary and Proposed Regulations Relating to Application of Separate Limitations to Dividends From Noncontrolled Section 902 Corporations (Jan. 16, 2007)
I.R.C.§: 902
Other
- Proposed Amendments to the Rules of the United States Tax Court Concerning Revisions to Form 2 (April 13, 2007)
To: U.S. Tax Court - Comments Concerning the Tax Court’s Proposed Amendments Regarding Privacy and Public Access to Electronic Case Files (April 13, 2007)
To: U.S. Tax Court - Comments on Proposed Amendments to the Rules of the US Court of Federal Claims Concerning Assignment and Processing of Indirectly Related Tax Cases (March 21, 2007)
To: U.S. Court of Federal Claims