Office of the Secretary, Treasury.
This document contains corrections to (TD 9165), which were published in the Federal Register on Monday, December 20, 2004 (69 FR 75839) revising the regulations governing practice before the Internal Revenue Service (Circular 230).
This correction is effective December 20, 2004.Start Further Info
FOR FURTHER INFORMATION CONTACT:
Heather L. Dostaler at (202) 622-4940 or Brinton T. Warren at (202) 622-7800 (not toll-free numbers).End Further Info End Preamble Start Supplemental Information
The final regulations (TD 9165) that are the subject of these corrections are under 31 CFR sections 10.33, 10.35, 10.36, 10.37, 10.38, 10.52 and 10.93.
Need for Correction
As published, TD 9165 contains errors that may prove to be misleading and are in need of clarification.Start List of Subjects
List of Subjects in 31 CFR Part 10
- Practice before the Internal Revenue Service
Correction of PublicationStart Amendment Part
Accordingly, 31 CFR Part 10 is corrected by making the following correcting amendments:End Amendment Part Start Part
PART 10—PRACTICE BEFORE THE INTERNAL REVENUE SERVICEEnd Part Start Amendment Part
Paragraph 1. The authority citation for 31 CFR, part 10 continues to read in part as follows:End Amendment Part
Par. 2. Section 10.35 is amended by revising paragraphs (b)(2)(ii)(B) introductory text and (b)(4)(i) to read as follows:End Amendment Part
(b) * * *
(2) * * * (ii) * * *
(A) * * *
(B) Written advice, other than advice described in paragraph (b)(2)(i)(A) of this section (concerning listed transactions) or paragraph (b)(2)(i)(B) of this section (concerning the principal purpose of avoidance or evasion) that—
(4) Reliance opinion—(i) Written advice is a reliance opinion if the advice concludes at a confidence level of at least more likely than not (a greater than 50 percent likelihood) that one or more significant Federal tax issues would be resolved in the taxpayer's favor.
Dated: April 11, 2005.
Richard S. Carro,
Senior Advisor to the General Counsel (Regulatory Affairs).
[FR Doc. 05-7552 Filed 4-14-05; 8:45 am]
BILLING CODE 4830-01-P