Comments Concerning IRS
Notice 200110
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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 Committees on Employee
Benefits, Insurance Companies, Estate and Gift Taxes and Small Law Firms and Closely Held
Businesses of the Section of Taxation. Principal responsibility was exercised by Andrew
Liazos. Substantive contributions were made by Diane J. Fuchs, Alan Jensen, Robert
Abramowitz, Susan Harmon, Tom Quinn and Mike Gunter. The comments were reviewed by Diane
J. Fuchs, Chair of the Committee on Employee Benefits. The comments were reviewed by David
Raish, as a member of the Sections Committee on Government Submissions and as a
member of the Sections Council.
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:
Andrew Liazos
McDermott, Will & Emery
28 State Street, 34th Floor
Boston, MA 02109-1775
(617) 535-4038
aliazos@mwe.com
CC:
Diane J. Fuchs, Seth H. Tievsky, Thomas R. Hoecker, Kyle N. Brown, Taina E. Edlund,
Pamela Baker, Susan Harmon, Wayne Luepker, James Mulder, Robert Abramowitz, Alan Jensen,
Tom Quinn, Mike Gunter
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