Internal Revenue Bulletin: 2006-10
March 6, 2006
Proposed regulations under section 330 of title 31 of the U.S. Code provide proposed amendments to the provisions of Circular 230 relating to various non-shelter items. This document proposes amendments reflecting the Treasury Department and the IRS consideration of the comments received in response to the 2002 advance notice of proposed rulemaking and reflecting amendments to section 330 of title 31 made by the American Jobs Creation Act of 2004. The regulations also include conforming amendments to reflect the final regulations relating to best practices, covered opinions and other written advice published as T.D. 9165, 2005-4 I.R.B. 357, and as T.D. 9201, 2005-23 I.R.B. 1153, but do not otherwise address those final regulations. A public hearing is scheduled for June 21, 2006.
This notice states that the deadline to make an election under section 165(i) of the Code to deduct in the preceding taxable year certain losses attributable to Hurricane Katrina, Rita, or Wilma is postponed until October 16, 2006.
This notice supplements Notice 2005-73, 2005-42 I.R.B. 723, News Release IR-2005-112, Notice 2005-81, 2005-47 I.R.B. 977, and Notice 2005-66, 2005-40 I.R.B. 620, which, under the authority of section 7508A, postponed until February 28, 2006, deadlines for certain taxpayers affected by Hurricane Katrina to perform the acts described in Notice 2005-73 (e.g., filing returns and other documents, payment of taxes), and for the Internal Revenue Service (IRS) to perform the acts described in Notice 2005-81 (e.g., assessment, collection). The notice further postpones those deadlines through August 28, 2006, for the IRS and for affected taxpayers in the parishes in Louisiana and the counties in Mississippi and Alabama that the Federal Emergency Management Agency (FEMA) determined were eligible for individual assistance. Notices 2005-66, 2005-73, and 2005-81 supplemented.
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