[Federal Register Volume 79, Number 147 (Thursday, July 31, 2014)]
[Rules and Regulations]
[Pages 44282-44286]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2014-17932]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 301
[TD 9686]
RIN 1545-BF59
Material Advisor Penalty for Failure To Furnish Information
Regarding Reportable Transactions
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Final regulations and removal of temporary regulations.
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SUMMARY: This document contains final regulations relating to the
assessment of penalties against material advisors who fail to timely
file a true and complete return. The regulations implement amendments
made by the American Jobs Creation Act of 2004. These regulations
affect material advisors responsible for disclosing reportable
transactions.
DATES: Effective Date: These regulations are effective on July 31,
2014.
Applicability Date: For dates of applicability, see Sec. 301.6707-
1(f).
FOR FURTHER INFORMATION CONTACT: James G. Hartford at (202) 317-6844
(not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
This document contains amendments to the Procedure and
Administration Regulations (26 CFR Part 301) under section 6707. On
December 22, 2008, a notice of proposed rulemaking (REG-160872-04) was
published in the Federal Register (73 FR 78254) relating to the penalty
under section 6707 of the Internal Revenue Code imposed on material
advisors for failure to furnish information regarding reportable
transactions (the proposed regulations). No comments were received from
the public in response to the notice of proposed rulemaking. No public
hearing was requested or held. The proposed regulations are adopted by
this Treasury decision with revisions as discussed in this preamble.
Section 6707 was originally added to the Code by section 141(b) of
the Tax Reform Act of 1984, Public Law 98-369, 98 Stat. 494 (July 18,
1984). At that time, section 6707 imposed a penalty for failing to
timely register a tax shelter or for filing false or incomplete
information with respect to the tax shelter registration. Section
301.6707-1T of the temporary regulations implementing the penalty was
published shortly after section 6707 became law.
The American Jobs Creation Act of 2004, Public Law 108-357, 118
Stat. 1418 (AJCA), was enacted on October 22, 2004. As amended by AJCA,
section 6707 imposes a penalty on a material advisor required to file a
return under section 6111(a) with respect to a reportable transaction
who fails to timely file such a return or who files the return with
false or incomplete information. Section 6707, as amended, is effective
for returns due after October 22, 2004.
In 2007, the Treasury Department and the IRS issued Rev. Proc.
2007-21, 2007-1 CB 613 (February 26, 2007), (see Sec.
601.601(d)(2)(ii)(b)), of this chapter, to provide procedures for
requesting rescission of a penalty assessed under section 6707 for
failure by a material advisor to disclose a reportable transaction and
under section 6707A for failure by a taxpayer to disclose a reportable
transaction. For each penalty, the revenue procedure provides the
deadline by which a person must
[[Page 44283]]
request rescission; the information the person must provide in the
rescission request; where the person must submit the rescission
request; and the rules governing requests for additional information
from the person requesting rescission. In addition, the revenue
procedure sets forth the factors that weigh in favor of and against
granting rescission. For example, one factor described in the revenue
procedure as weighing in favor of rescission of the section 6707
penalty is filing a Form 8918, ``Material Advisor Disclosure
Statement,'' after the due date but before the taxpayer files a Form
8886, ``Reportable Transaction Disclosure Statement,'' identifying the
material advisor as an advisor with respect to the transaction or
before the IRS contacts the material advisor concerning the reportable
transaction.
On December 22, 2008, proposed regulations implementing the penalty
under section 6707 were published. The proposed regulations set forth
the rules for application of the penalty under section 6707, including
examples and relevant definitions such as the definition of incomplete
information, false information, and when a failure is intentional so
that the higher penalty with respect to listed transactions will apply.
The proposed regulations also adopted the factors described in Rev.
Proc. 2007-21 that will be considered when determining whether a
request for rescission of a section 6707 penalty with respect to a non-
listed reportable transaction will be granted. In addition, the
proposed regulations generally restated the existing authority of the
Secretary to prescribe procedures for requesting rescission by revenue
procedure or other guidance published in the Internal Revenue Bulletin.
The proposed regulations did not address the procedures for requesting
rescission in Rev. Proc. 2007-21, such as the deadline, the information
provided, where to submit the request, and requests for additional
information.
Explanation of Revisions
These regulations remove temporary regulations Sec. 301.6707-1T
(TD 7964), 49 FR 32712, which implement section 6707 as enacted in
1984. Amendments to section 6707 made by section 816 of AJCA render
temporary regulations Sec. 301.6707-1T obsolete.
The final regulations make several substantive changes to the
proposed regulations. First, a new paragraph (iii) has been added under
Sec. 301.6707-1(a)(1)(B) regarding the penalty in the case of listed
transactions. This new paragraph clarifies that only one section 6707
penalty will apply in the case of a transaction that is both a listed
transaction and a reportable transaction other than a listed
transaction, and that the penalty that applies in these cases is the
higher penalty for listed transactions under Sec. 301.6707-1(a)(1)(B).
Section 301.6707-1(a)(1) of the final regulations has also been
clarified to provide that if there is a failure with respect to more
than one reportable or listed transaction, a material advisor will be
subject to a separate penalty for each transaction.
In addition, Sec. 301.6707-1(a)(2), which describes gross income
derived from a transaction for purposes of determining the penalty in
the case of a listed transaction, has been clarified to provide that
only fees from a listed transaction for which the advisor is a material
advisor are taken into account for purposes of computing the penalty. A
new example 4 has been added to illustrate this clarification.
Finally, Sec. 301.6707-1(e) of the proposed regulations is
modified to provide additional guidance on rescission of the penalty
under section 6707. Under Rev. Proc. 2007-21 and Sec. 301.6707-
1(e)(3)(i) of the proposed regulations, filing a Form 8918, ``Material
Advisor Disclosure Statement,'' after the due date will be a factor
weighing strongly in favor of rescission unless the form is filed after
the taxpayer files a Form 8886, ``Reportable Transaction Disclosure
Statement,'' identifying the material advisor as an advisor with
respect to the transaction or after the IRS contacts the material
advisor concerning the reportable transaction. The final regulations
modify this rule to also consider whether circumstances indicate that
the material advisor delayed filing the Form 8918, recognizing that the
mere filing of a Form 8886 before filing the Form 8918, alone, is not
indicative of whether rescission is appropriate. Accordingly, the final
regulations provide that if a material advisor unintentionally failed
to file a Form 8918, but then files a properly completed form with the
IRS, that filing will be a factor that weighs in favor of rescission of
the section 6707 penalty if the facts suggest that the material advisor
did not delay filing the form until after the IRS had taken steps to
identify that person as a material advisor with respect to that
particular transaction. The final regulations further provide that the
late filing will not weigh in favor of rescission if the facts and
circumstances suggest that the material advisor delayed filing the Form
8918 until after the material advisor's client filed its Form 8886 (or
successor form) disclosing the client's participation in the particular
reportable transaction.
In addition, the final regulations clarify the language of the
proposed regulations in a few other ways not intended to be
substantive, including clarification of examples.
Effect on Other Documents
Sections 4.04, 4.05, and 4.06 of Revenue Procedure 2007-21,
relating to the factors for rescission of the section 6707 penalty, are
superseded as of July 31, 2014.
Special Analyses
It has been determined that this Treasury Decision is not a
significant regulatory action as defined in Executive Order 12866, as
supplemented by Executive Order 13563. Therefore, a regulatory
assessment is not required. The IRS has determined that sections 553(b)
and (d) of the Administrative Procedure Act (5 U.S.C. chapter 5) do not
apply to these regulations and because the regulations do not impose a
collection of information on small entities, the Regulatory Flexibility
Act (5 U.S.C. chapter 6) does not apply. Pursuant to section 7805(f) of
the Internal Revenue Code, the notice of proposed rulemaking preceding
these regulations was submitted to the Chief Counsel for Advocacy of
the Small Business Administration for comment on its impact on small
business. No comments were received on the proposed regulations.
Drafting Information
The principal author of these regulations is James G. Hartford of
the Office of the Associate Chief Counsel (Procedure and
Administration).
List of Subjects in 26 CFR Part 301
Employment taxes, Estate taxes, Excise taxes, Gift taxes, Income
taxes, Penalties, Reporting and recordkeeping requirements.
Adoption of Amendments to the Regulations
Accordingly, 26 CFR part 301 is amended as follows:
PART 301--PROCEDURE AND ADMINISTRATION
0
Paragraph 1. The authority citation for part 301 continues to read in
part as follows:
Authority: 26 U.S.C. 7805. * * *
0
Par. 2. Section 301.6707-1 is added to read as follows:
[[Page 44284]]
Sec. 301.6707-1 Failure to furnish information regarding reportable
transactions.
(a)(1) In general. A material advisor who is required to file a
return under section 6111(a) of the Internal Revenue Code (Code) with
respect to any reportable transaction who fails to file a timely return
in accordance with Sec. 301.6111-3(e) or who files a return with false
or incomplete information with respect to the reportable transaction
will be subject to a penalty. A material advisor who fails to file a
timely return or who files a false or incomplete return with respect to
more than one reportable transaction will be subject to a separate
section 6707 penalty for each transaction.
(i) Reportable transactions. The amount of the penalty for failing
to timely file a return under section 6111(a), or filing the return
with false or incomplete information with respect to any reportable
transaction other than a listed transaction is $50,000.
(ii) Listed transactions. (A) In general. The amount of the penalty
for failing to timely file a return under section 6111(a), or filing
the return with false or incomplete information with respect to a
listed transaction is the greater of $200,000 or 50 percent of the
gross income derived by the material advisor with respect to aid,
assistance, or advice that is provided with respect to the listed
transaction before the date the return is filed under section 6111.
(B) Intentional action or failure. If the failure or action subject
to the penalty is with respect to a listed transaction and is
intentional, the penalty is the greater of $200,000 or 75 percent of
the gross income derived by the material advisor with respect to aid,
assistance, or advice that is provided with respect to the listed
transaction before the date the return is filed under section 6111.
(C) Transaction that is both a listed transaction and reportable
transaction other than a listed transaction. In the case of a penalty
imposed under section 6707 with respect to a transaction that is both a
listed transaction and a reportable transaction other than a listed
transaction, the penalty under this paragraph (a)(1)(ii), and not the
penalty under paragraph (a)(1)(i) of this section, will apply.
(2) Gross income derived by the material advisor. For purposes of
calculating the amount of the penalty with respect to a listed
transaction, the gross income derived by the material advisor will be
determined in accordance with Sec. 301.6111-3(b)(3)(ii) of this
chapter. If a person is a material advisor with regard to more than one
type of listed transaction, the gross income derived from each type of
listed transaction will be considered separately and will not be
aggregated to determine the amount of any section 6707 penalty for
failing to make a proper return under section 6111(a). Further, only
gross income derived from listed transactions for which the advisor is
a material advisor under section 6111 is taken into account for
purposes of computing the penalty.
(b) Definitions--(1) Derive. The term ``derive'' is defined in
Sec. 301.6111-3(c)(3).
(2) False information. For purposes of this section, the term
``false information'' means information provided on a Form 8918,
``Material Advisor Disclosure Statement'' (or successor form), filed
with the Internal Revenue Service (IRS) that is untrue or incorrect
when the Form 8918 (or successor form) was filed. False information
does not include information provided on a Form 8918 (or successor
form) filed with the IRS that is immaterial or that is untrue or
incorrect due to a mistake or accident after the exercise of reasonable
care.
(3) Incomplete information. For purposes of this section, the term
``incomplete information'' means a Form 8918 (or successor form) filed
with the IRS that does not provide the information required under Sec.
301.6111-3(d). A Form 8918 (or successor form) filed with the IRS will
not be considered incomplete when the information not provided on the
form is immaterial or was not provided due to mistake or accident after
the exercise of reasonable care. Whether information is immaterial will
be determined based upon the facts and circumstances surrounding each
failure to file or filing of an incomplete return. A material advisor
who completes the form to the best of the material advisor's ability
and knowledge after the exercise of reasonable effort to obtain the
information will not be considered to have filed incomplete information
within the meaning of this section. A Form 8918 (or successor form)
will be considered to provide incomplete information when it omits
information required to be provided under Sec. 301.6111-3(d) or
contains a statement that the omitted information will be provided upon
request.
(4) Intentional. For purposes of this section, the failure to
timely file a return or the submission of a return with false or
incomplete information is intentional if--
(i) The material advisor knew of the obligation to file a return
and knowingly did not timely file a return with the IRS; or
(ii) The material advisor filed a return knowing that it was false
or incomplete.
(5) Listed transaction. The term ``listed transaction'' is defined
in section 6707A(c)(2) of the Code and Sec. 1.6011-4(b)(2) of this
chapter.
(6) Material Advisor. The term ``material advisor'' is defined in
section 6111(b)(1) of the Code and Sec. 301.6111-3(b).
(7) Reportable transaction. The term ``reportable transaction'' is
defined in section 6707A(c)(1) of the Code and Sec. 1.6011-4(b)(1) of
this chapter.
(c) Assessment of penalty--(1) Intentional failure determined based
on all the facts and circumstances. Whether a material advisor
intentionally failed to timely file a return or intentionally filed a
false or incomplete return will be determined based upon all the facts
and circumstances surrounding the non-filing or filing of a false and/
or incomplete return. The higher penalty under the flush language of
section 6707(b)(2) will not apply to any material advisor whose failure
to timely file or whose furnishing of false or incomplete information
was unintentional. The failure to timely file a return, or filing a
return with false or incomplete information, will be considered
unintentional if the material advisor subsequently files a true and
complete return prior to the earlier of the date that any taxpayer
files a Form 8886, ``Reportable Transaction Disclosure Statement'' (or
successor form) identifying the material advisor with respect to the
reportable transaction in question, or the date the IRS contacts the
material advisor concerning the reportable transaction.
(2) Individual liability in the case of more than one material
advisor. If there is more than one material advisor who is responsible
for filing a return under section 6111 with respect to the same
reportable transaction, a separate penalty under section 6707 may be
assessed against each material advisor who fails to timely file or
files a return with false or incomplete information. The determination
of whether the failure or action subject to the penalty is intentional
will be made individually for each material advisor.
(3) Designation agreements. A material advisor who is required to
file a return under section 6111 and who is a party to a designation
agreement within the meaning of Sec. 301.6111-3(f) is subject to a
penalty under section 6707 if the designated material advisor fails to
file a return timely or files a return with false or incomplete
information. In the case of a listed transaction, if the designated
material advisor fails to file a return timely, or files a return with
false or incomplete information, the nondesignated material advisor who
is a
[[Page 44285]]
party to the designation agreement will not be treated as intentionally
failing to file the return, or intentionally filing a return with false
or incomplete information, unless the nondesignated material advisor
knew or should have known that the designated material advisor would
fail to file a true and complete return timely.
(d) Examples. The rules of paragraphs (a) through (c) of this
section are illustrated by the following examples:
Example 1. Advisor A becomes a material advisor as defined
under section 6111(b)(1) and Sec. 301.6111-3(b) in the fourth
quarter of 2014 with respect to a reportable transaction other than
a listed transaction, and Advisor B also becomes a material advisor
in the same quarter with respect to the same reportable transaction.
Advisors A and B fail to timely file the Form 8918 with respect to
the reportable transaction. Under paragraph (a)(1)(ii) of this
section, the penalty for failure by a material advisor to timely
disclose a reportable transaction other than a listed transaction is
$50,000. Because the section 6707 penalty applies to each material
advisor independently under paragraph (c)(2) of this section,
Advisors A and B each are subject to a section 6707 penalty of
$50,000.
Example 2. Same as Example 1, except that Advisor B timely
files the Form 8918. Advisors A and B did not enter into a
designation agreement. Accordingly, paragraph (c)(3) of this section
does not apply and only Advisor A is subject to a $50,000 section
6707 penalty.
Example 3. Advisor C becomes a material advisor to Client X on
January 5, 2015, with respect to a listed transaction. Advisor C
derives $400,000 in gross income from his advice to Client X because
he expects to receive that amount from Client X, even though he has
not yet received that amount. On January 5, 2016, Advisor C becomes
a material advisor to Client Y with respect to the same type of
listed transaction. Advisor C derives $100,000 in gross income from
his advice to Client Y because he expects to receive that amount
from Client Y, even though he has not yet received that amount. At
no time did Advisor C file a Form 8918 to disclose the listed
transaction. For purposes of this example, assume that Advisor C's
failure to file a Form 8918 was unintentional. Therefore, under
paragraph (c)(2) of this section, Advisor C is subject to a section
6707 penalty based on the gross income derived from Client X and
Client Y. Accordingly, Advisor C is subject to a penalty of $250,000
(50 percent of $500,000, the gross income derived from Clients X and
Y).
Example 4. Same as Example 3, except that the gross income
Advisor C expects to receive from his advice to Client Y (a C
corporation) is $20,000. Because the material advisor fee threshold
is not satisfied with respect to Client Y, Advisor C is not a
material advisor to Client Y with respect to the listed transaction.
Advisor C is, however, a material advisor with respect to Client X
with respect to the same listed transaction. Therefore, Advisor C is
subject to a section 6707 penalty with respect to the failure to
timely file a Form 8918 disclosing the listed transaction. Although
Advisor C provided advice with respect to two transactions that are
the same type of listed transaction, Advisor C was only a material
advisor with respect to advice provided to Client X. Therefore,
under paragraph (c)(2) of this section Advisor C is subject to a
section 6707 penalty based only on the gross income derived from
Client X. Accordingly, Advisor C is subject to a penalty of $200,000
(50 percent of $400,000, the gross income derived from Client X).
Example 5. Same as Example 3, except that Advisor C files a
Form 8918 disclosing the listed transaction on November 16, 2015.
Because Advisor C becomes a material advisor to Client X on January
5, 2015, the Form 8918 is required to be filed on or before April
30, 2015 (the last day of the month that follows the end of the
calendar quarter in which the advisor became a material advisor with
regard to the reportable transaction). See Sec. 301.6111-3(e).
Therefore, Advisor C did not timely file the Form 8918. Advisor C is
subject to a $200,000 penalty under section 6707 for his
unintentional failure because, as of the date he filed the Form
8918, the gross income Advisor C had received or expected to receive
with respect to advice relating to a listed transaction that was not
disclosed only included $400,000 of gross income for advice to
Client X. By the time that Advisor C provides advice to Client Y on
January 5, 2016, Advisor C has disclosed the listed transaction.
Example 6. Same as Example 3, except that Advisor C files the
Form 8918 on February 16, 2016, disclosing the listed transaction.
Because Advisor C first becomes a material advisor with respect to
the listed transaction on January 5, 2015, the Form 8918 is required
to be filed on or before April 30, 2015 regardless of the fact that
Advisor C is also a material advisor to a second client, Client Y,
with respect to the same listed transaction. This is because under
the facts of Example 3, Advisor C ``becomes'' a material advisor on
January 5, 2015. The date on which a material advisor ``becomes'' a
material advisor is determinative of the due date for the Form 8918
under Sec. 301.6111-3(e). Therefore, when Advisor C files the Form
8918 on February 16, 2016, the form is not timely filed under
section 6111. Under paragraph (c)(2) of this section, Advisor C is
subject to a penalty under section 6707 of $250,000 (50 percent of
$500,000) because, as of the date that the Form 8918 was filed, the
gross income that Advisor C received or expected to receive as a
material advisor with respect to a listed transaction that was not
disclosed included gross income for advice to both Client X
($400,000) and Client Y ($100,000).
Example 7. Advisor D becomes a material advisor as defined
under section 6111(b)(1) and Sec. 301.6111-3(b) in the first
quarter of 2016 with respect to a reportable transaction other than
a listed transaction. Advisor D does not file a Form 8918 by April
30, 2016. The transaction is then identified as a listed transaction
in published guidance on July 7, 2016. Advisor D knew that he had a
new obligation to file a Form 8918 by October 31, 2016, and
intentionally fails to file the Form 8918. Advisor D is subject to
only one penalty, in the amount of the greater of $200,000, or 75
percent of the gross income he derived from the transaction, for
intentionally failing to disclose the listed transaction in
accordance with Sec. 301.6111-3(d)(1) and (e).
Example 8. Same as Example 7, except that Advisor D filed a Form
8918 disclosing the listed transaction on October 15, 2016. As a
result of that disclosure, Advisor D is not subject to the section
6707 penalty amount described in Sec. 301.6707-1(a)(1)(ii).
However, because Advisor D did not timely file a Form 8918 by April
30, 2016, the due date for the Form 8918 with respect to the
reportable transaction for which Advisor D became a material advisor
in the first quarter of 2016, Advisor D is subject to a section 6707
penalty of $50,000 as described in Sec. 301.6707-1(a)(1)(i). The
disclosure of the listed transaction does not correct Advisor D's
initial failure to disclose the reportable transaction by April 30,
2016.
(e) Rescission authority--(1) In general. The Commissioner (or the
Commissioner's delegate) may rescind the section 6707 penalty if--
(i) The violation relates to a reportable transaction that is not a
listed transaction; and
(ii) Rescinding the penalty would promote compliance with the
requirements of the Code and effective tax administration.
(2) Requesting rescission. The Secretary may prescribe the
procedures for a material advisor to request rescission of a section
6707 penalty by guidance published in the Internal Revenue Bulletin.
(3) Factors that weigh in favor of granting rescission. In
determining whether rescission would promote compliance with the
requirements of the Code and effective tax administration, the
Commissioner (or the Commissioner's delegate) will take into account
the following list of factors that weigh in favor of granting
rescission. This is not an exclusive list, and no single factor will be
determinative of whether to grant rescission in any particular case.
Rather, the Commissioner (or the Commissioner's delegate) will consider
and weigh all relevant factors, regardless of whether the factor is
included in this list.
(i) The material advisor, upon becoming aware of the failure to
disclose a reportable transaction in accordance with section 6111 and
the regulations thereunder, filed a complete and proper, albeit
untimely, Form 8918 (or successor form). This factor weighs in favor of
rescission if circumstances suggest that the material advisor did not
delay in filing an untimely but properly completed Form 8918 (or
successor form) until after the IRS had taken steps
[[Page 44286]]
to identify the person as a material advisor with respect to the
reportable transaction. For instance, this factor will weigh strongly
in favor of rescission if the material advisor files the Form 8918 (or
successor form) prior to the date the IRS contacts the material advisor
concerning the reportable transaction. However, this factor will not
weigh in favor of rescission if the facts and circumstances indicate
that the material advisor delayed filing the Form 8918 (or successor
form) until after a taxpayer files a Form 8886 (or successor form)
identifying the material advisor with respect to the reportable
transaction in question.
(ii) The material advisor's failure to disclose the reportable
transaction properly was due to an unintentional mistake of fact that
existed despite the material advisor's reasonable attempts to ascertain
the correct facts with respect to the transaction.
(iii) The material advisor has an established history of properly
disclosing other reportable transactions and complying with other tax
laws, including compliance with any requests made by the IRS under
section 6112, if applicable.
(iv) The material advisor demonstrates that the failure to include
on any return or statement any information required to be disclosed
under section 6111 arose from events beyond the material advisor's
control.
(v) The material advisor cooperates with the IRS by providing
timely information with respect to the transaction at issue that the
Commissioner (or the Commissioner's delegate) may request in
consideration of the rescission request. In considering whether a
material advisor cooperates with the IRS, the Commissioner (or the
Commissioner's delegate) will take into account whether the material
advisor meets the deadlines described in guidance published in the
Internal Revenue Bulletin for complying with requests for additional
information.
(vi) Assessment of the penalty weighs against equity and good
conscience, including whether the material advisor demonstrates that
there was reasonable cause for, and the material advisor acted in good
faith with respect to, the failure to timely file or to include on any
return any information required to be disclosed under section 6111. An
important factor in determining reasonable cause and good faith is the
extent of the material advisor's efforts to determine whether there was
a requirement to file the return required under section 6111. The
presence of reasonable cause, however, will not necessarily be
determinative of whether to grant rescission.
(4) Absence of favorable factors weighs against rescission. The
absence of facts establishing the factors described in paragraph (e)(3)
of this section weighs against granting rescission. The presence or
absence of any one of these factors, however, will not necessarily be
determinative of whether to grant rescission; rather the determination
will be made in consideration of all of the factors and any other facts
and circumstances.
(5) Factors not considered. In determining whether to grant
rescission, the Commissioner (or the Commissioner's delegate) will not
consider doubt as to collectability of, or liability for, the penalties
(except that the Commissioner (or the Commissioner's delegate) may
consider doubt as to liability to the extent it is a factor in the
determination of reasonable cause and good faith).
(f) Effective/applicability date. The rules of this section apply
to returns the due date for which is after July 31, 2014.
Sec. 301.6707-1T [Removed]
0
Par. 3. Section 301.6707-1T is removed.
John Dalrymple,
Deputy Commissioner for Services and Enforcement.
Approved: June 26, 2014.
Mark J. Mazur,
Assistant Secretary of the Treasury (Tax Policy).
[FR Doc. 2014-17932 Filed 7-30-14; 8:45 am]
BILLING CODE 4830-01-P