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The following comments on the temporary and proposed regulations under section 4958 (REG-246256-96),¹ are the individual views of the members of the Section of Taxation and the Health Law Section and do not represent the position of the American Bar Association, the Section of Taxation, or the Health Law Section. Those who have contributed to these comments may not necessarily agree in all respects with the conclusions and recommendations expressed.

These comments were prepared by individual members of the Subcommittee on Intermediate Sanctions of the Committee on Exempt Organizations of the Section of Taxation and members of the Tax and Accounting Interest Group of the Health Law Section. Principal responsibility was exercised by Robert H.M. Ferguson, Victoria B. Bjorklund, Bernadette Broccolo, Frederick J. Gerhart, and Michael A. Clark. These comments were reviewed on behalf of the Section of Taxation by Carolyn M. Osteen for the Section of Taxation’s Committee on Government Submissions and by Douglas M. Mancino, the Council Director for the Committee on Exempt Organizations. The comments were reviewed by Bonnie Brier and Gregory L. Pemberton on behalf of the Health Law Section.

Although the individuals who participated in the preparation of these comments have clients who would be affected by, or have advised clients on the application of, the temporary and proposed regulations, no participant (or the firm or organization to which such participant 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:

Michael A. Clark
Sidley & Austin
Bank One Plaza
10 S. Dearborn, Suite 4400
Chicago, IL 60603
(312) 853-2173
mclark@Sidley.com

Date: April 10, 2001

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