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The views expressed herein are being presented on behalf of the Section of Taxation (the "Section"). These comments have not been approved by the Board of Governors or the House of Delegates of the American Bar Association and should not be construed as representing the policy of the American Bar Association.

These comments were prepared by a task force of individual members of the Committee on Standards of Tax Practice and the Special Projects Committee of the Section of Taxation. Principal drafting responsibility was exercised by Bryan Skarlatos, Frederic L. Ballard, Jr., and B. John Williams. Substantive contributions were made by Ian M. Comisky, Denis Conlon, James P. Holden, George C. Howell, III, Mona Hymel, Chad Muller, Charles Pulaski, Cecil A. Ray, Les Shapiro, and David E. Watts. The Comments were reviewed by Walter J. Russell of the Section’s Committee on Government Submissions, William M. Paul, Council Director for the Committee on Standards of Tax Practice, Paul J. Sax, Council Director for the Special Projects Committee, and Richard M. Lipton, Chair of the Section.

Although many of the members of the Section 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, and all would be affected in their capacity as practitioners, no such member (or the firm or organization to which such member belongs) has been engaged by a client to make, or has a specific individual interest in making, 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 23, 2001

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