Comment on FR Doc # E9-03069

Document ID: IRS-2009-0006-0002
Document Type: Public Submission
Agency: Internal Revenue Service
Received Date: March 03 2009, at 12:01 PM Eastern Standard Time
Date Posted: March 5 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: February 13 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: May 14 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 808e84b3
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This is comment on Proposed Rule

Tax Avoidance Transactions

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The proposed rulemaking for Regulation section 6231 needs to add for the following: Add that transactions for converting partnership items to nonpartnership items should not be limited to "listed" transactions as defined by Reg. 1.6011-4(a)(2). It should also include nonlisted transactions or entities that involve economic substance issues. Add that IRS written notification to the partners that their partnership items are being converted to nonpartnership items may also be done at the key case partnership level in lieu of the lower tier entities or investors when the IRS does not have the correct direct or indirect investor information, there are indications of abusive or misleading taxpayer tactics, and the taxpayers have not been forthcoming with the correct investor information in a reasonable period.

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Comment on FR Doc # E9-03069

Title:
Comment on FR Doc # E9-03069

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Related Comments

   
Total: 3
Comment on FR Doc # E9-03069
Public Submission    Posted: 03/05/2009     ID: IRS-2009-0006-0002

May 14,2009 11:59 PM ET
Tax Avoidance Transactions
Public Submission    Posted: 12/10/2009     ID: IRS-2009-0006-0005

May 14,2009 11:59 PM ET
Tax Avoidance Transactions
Public Submission    Posted: 07/07/2009     ID: IRS-2009-0006-0004

May 14,2009 11:59 PM ET