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Communications from the Institute do not constitute, and should not be considered a substitute for, legal advice.
[20699]
December 19, 2006
TO: TAX COMMITTEE No. 45-06
RE: DRAFT INSTITUTE LETTER TO IRS REQUESTING DELAY OF REIT TMP
GUIDANCE
Attached for your review is a draft letter from the Institute to the Internal Revenue Service
requesting a delay in the implementation of Notice 2006-97 regarding the taxation and reporting of
excess inclusion income.1 The draft letter describes the burdens and impracticalities raised by
application of the Notice to current and prior tax years. It then asks that the Service delay the effective
date until appropriate guidance is provided.
Please provide any comments to Karen Gibian (202/371-5432 or kgibian@ici.org) by 12:00 pm
on Friday, December 22nd.
Karen Lau Gibian
Assistant Counsel
Attachment (in .pdf format)
1 See Institute Memorandum (20515) to Tax Members No. 39-06, dated October 30, 2006.