Archive for January, 2010
What are we to make of the Mysteryboy case recently handed down by the Tax Court (Mysteryboy Incorporation v. Commissioner, filed January 26, 2010)?
1 – EO Revenue Procedures Updated
The annual updating of the basic EO revenue procedures has taken place with few changes.
Rev. Proc. 2010-4, on TE/GE letter ruling requests, has mostly minor revisions. An additional circumstance under which EO Technical will not issue letter rulings is added as section 6.18.
Last Friday ABA tax attorneys met in San Antonio. As part of the gathering, EO practitioners had their usual daylong meeting. For those of us not in attendance, my transcriber is already working on the first session. Now you know why she hates me.
Yesterday I had Marc Owens’ testimony at Wednesday’s hearing on the proposed section 7611 regulations. Today I have the testimony of Pennsylvania attorney David Epstein.
A hearing on the proposed section 7611 regulations was held yesterday, featuring three commenters. For the proposed regulations, see EOTJ, vol. 14, no. 4, p. 158. For written comments on the proposed regulations, see EOTJ, vol. 14, no. 6, pp. 145-171. What follows is the prepared testimony of Marc Owens for the hearing. Joining Owens in commenting were Pennsylvania attorney David Epstein and Erik Stanley, senior legal counsel, Alliance Defense Fund.