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The following comments represent the individual views of the members of the Employee Benefits Committee of the Section of Taxation of the American Bar Association who were involved in their preparation, and do not represent the position of the Committee, the Section or the American Bar Association.

These comments were prepared and coordinated by Donald J. Myers. He was assisted by Michael B. Richman, Robert Musick and Sharon W. Vaino. The comments were reviewed by Diane J. Fuchs, Chair of the Committee on Employee Benefits, Thomas R. Hoecker and Seth H. Tievsky of the Committee on Employee Benefits. The comments were reviewed by Roberta Watson of the Section’s Committee on Government Submissions and by Stuart M. Lewis, Council Director for the Committee on Employee Benefits.

Although the members of the Committee who participated in preparing these comments have clients who may be affected by the program or may advise clients with respect to using the program, no such member (or 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:

Donald J. Myers
Reed Smith Shaw & McClay
(202) 414-9231

Date: March 19, 2001

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