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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 Employee Benefits of the Section of Taxation (the "Committee"). Principal responsibility was exercised by Avery E. Neumark. Substantive contributions were made by Cheryl R. Hughes, Judith L. McMillin, and Carol A. Weiser. The Comments were reviewed by Taina E. Edlund, Committee Vice Chair and Diane J. Fuchs, Committee Chair. They were also reviewed by James R. Raborn of the Section’s Committee on Government Submissions and by Stuart M. Lewis, Council Director for the Committee on Employee Benefits

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:

Avery E. Neumark
(212) 303-9035
aneumark@rssmcpa.com

Date: November 20, 2000

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