The government is receptive to comments on its controversial new test for substantial business activity in rules (T.D. 9592, REG-107889-12) intended to stop abusive corporate inversions under tax code Section 7874, officials say. At the same time, IRS and the Treasury Department remain focused on the code section as one intended to prevent abuse, says John Merrick, special assistant to the IRS Associate Chief Counsel, International. Treasury and IRS closely scrutinized the legislative history of the 2004 statute and took into account a broad grant of authority when writing the regulations unveiled in June, according to both Merrick and Brenda Zent, a taxation specialist in Treasury's Office of Tax Policy.