Comment on FR Doc # E9-03069

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.