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IRS Corrects Proposed Regs on Disguised Sales of Partnership Interests

DEC. 21, 2004

REG-149519-03; 69 F.R. 76422

DATED DEC. 21, 2004
DOCUMENT ATTRIBUTES
  • Institutional Authors
    Internal Revenue Service
  • Cross-Reference
    For REG-149519-03, see Doc 2004-22588 [PDF]or 2004 TNT 228-

    3 Database 'Tax Notes Today 2004', View '(Number'.
  • Code Sections
  • Subject Area/Tax Topics
  • Jurisdictions
  • Language
    English
  • Tax Analysts Document Number
    Doc 2004-24021
  • Tax Analysts Electronic Citation
    2004 TNT 245-9
Citations: REG-149519-03; 69 F.R. 76422

 

[4830-01-P]

 

 

DEPARTMENT OF THE TREASURY

 

Internal Revenue Service

 

26 CFR Part 1

 

 

RIN 1545-BC63

 

 

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to notice of proposed rulemaking and notice of public hearing.

SUMMARY: This document contains a correction to proposed regulations which were published in the Federal Register on Friday, November 26, 2004 (69 FR 68838). The proposed regulations relates to the treatment of transactions between a partnership and its partners as disguised sales of partnership interests between the partners.

FOR FURTHER INFORMATION CONTACT: Deane M. Burke or Christopher L. Trump, (202) 622-3070 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

BACKGROUND

The proposed regulations that is the subject of this correction is under section 707(a)(2)(B) of the Internal Revenue Code.

Need for correction

As published, the notice of proposed rulemaking and notice of public hearing contain an error that may prove to be misleading and is in need of clarification.

Correction to Publication

Accordingly, the publication of the proposed regulations (REG- 149519-03), which was the subject of FR Doc. 04-26112, is corrected as follows:

On page 68843, column 3, in the preamble under the paragraph heading, "Review of Existing Regulations", line 5, the language "§§ 1.707-3, 1.707-4, and 1.707-5." is corrected to read "§§ 1.707-3, 1.707-4, 1.707-5 and 1.707-6.".

Cynthia E. Grigsby

 

 

Acting Chief, Regulations and

 

Publications Branch

 

Legal Processing Division

 

Associate Chief Counsel

 

(Procedure and Administration)
DOCUMENT ATTRIBUTES
  • Institutional Authors
    Internal Revenue Service
  • Cross-Reference
    For REG-149519-03, see Doc 2004-22588 [PDF]or 2004 TNT 228-

    3 Database 'Tax Notes Today 2004', View '(Number'.
  • Code Sections
  • Subject Area/Tax Topics
  • Jurisdictions
  • Language
    English
  • Tax Analysts Document Number
    Doc 2004-24021
  • Tax Analysts Electronic Citation
    2004 TNT 245-9
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