Comments Concerning
Proposed Treasury Regulation 301.7430-7
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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 Court Procedure
and Practice of the Section of Taxation. Principal responsibility was exercised by Charles
J. Lavelle, Louisville, Kentucky, and Philip N. Jones, Portland, Oregon. Substantive
contributions were made by Robin L. Greenhouse, Washington, D.C., and Robert T. Duffy,
Charlotte, North Carolina. The Comments were reviewed by Professor Michael Mulroney,
Philadelphia, Pennsylvania, of the Section’s Committee on Government Submissions, and
by Karen L. Hawkins, San Francisco, California, Council Director for the Committee on
Court Procedure and Practice.
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.
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Date: April 2, 2001
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