Industry Issue Resolution Pilot
Program under Notice 2000-65
Financial Services Issues
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The following comments are the individual views of the members of the Section of
Taxation who prepared them and do not represent the position of the American Bar
Association or the Section of Taxation.
These comments were prepared by individual members of the Committee on Banking and
Savings Institutions of the Section of Taxation. Principal responsibility was exercised by
Henry Ruempler. Substantive contributions were made by Ron Blasi, Hayden Brown, James
Dahlberg, David Grant, and Charles Wheeler. The Comments were reviewed by C. Ellen MacNeil
of the Sections Committee on Government Submissions and by Steven D. Conlon, Council
Director for the Committee on Banking and Savings Institutions.
Although many of the members of the Section of Taxation who participated in preparing
these Comments have clients who would be affected by the federal tax principles addressed
by these Comments or have advised clients on the application of such principles, no such
member (or the firm or organization to which such member belongs) has been engaged by a
client to make a government submission with respect to, or otherwise to influence the
development or outcome of, the specific subject matter of these Comments.
Contact:
Henry Ruempler
(202) 327-8383
henry.ruempler@ey.com
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