Internal Revenue Bulletin: 2008-52
December 29, 2008
Table of Contents
This document contains a correction to temporary regulations (T.D. 7964, 1982-2 C.B. 263) that were published in the Federal Register on Wednesday, August 15, 1984 (49 FR 32712) relating to tax shelter registration. In addition, the text of the temporary regulations set forth in this document also serves as the text of the proposed regulations cross-referenced in the Notice of Proposed Rulemaking in the Proposed Rules section of that issue of the Federal Register. Changes to the applicable tax law were made by the Tax Reform Act of 1984. The regulations affect organizers, sellers, investors and certain other persons associated with investments that are considered tax shelters.
The temporary regulations that are the subject of this document are under sections 6707 and 6111 of the Internal Revenue Code prior to The American Jobs Creation Act of 2004, Public Law 108-357 (118 Stat. 1418), which was enacted on October 22, 2004.
As published, temporary regulations (T.D. 7964) contain an error that may prove to be misleading and is in need of clarification.
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Accordingly, 26 CFR part 301 is corrected by making the following correcting amendment:
Paragraph 1. The authority citation for part 301 continues to read, in part, as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 301.6111-1T A-30 is amended by revising the first sentence to read as follows:
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A-30. No. The performance of an act described in A-27 through A-29 of this section will not constitute participation in the organization or management of a tax shelter unless the person performing the act is related to the tax shelter (or any principal organizer of the tax shelter) or the person participates in the entrepreneurial risks or benefits of the tax shelter. * * *
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Acting Chief, Publications and Regulations Branch,
Legal Processing Division,
Associate Chief Counsel
(Procedure and Administration).
(Filed by the Office of the Federal Register on December 1, 2008, 8:45 a.m., and published in the issue of the Federal Register for December 2, 2008, 73 F.R. 73180)
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