Section of Taxation
Submission to the Internal Revenue Service

Comments on Proposed Regulations Under Section 121

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These 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.

These comments were prepared by individual members of three Committees of the ABA Section of Taxation: Domestic Relations; Real Estate; and Sales, Exchanges & Basis. Principal responsibility was exercised by Annette Nellen, Chair of the Sales, Exchanges & Basis Committee. Substantive contributions were made by Kevin Thomason, Donald H. Read, and Jack Ross. The Comments were reviewed by Laurence Reich of the Section’s Committee on Government Submissions and by Stanley Blend, Council Director for the Committee on Sales, Exchanges & Basis.

Although 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:

Annette Nellen
(408) 924-3508
nellen_a@cob.sjsu.edu

Date: May 1, 2001

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