IRS Devising Guidance to Address Section 336(e) Rules, Official Says

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Oct. 16 — The IRS has started a “clean-up” guidance project to address some narrow issues raised in 2013 final rules (T.D. 9619) on taxpayer elections for treatment of stock sales, an IRS attorney said.
Mark Weiss, an attorney in the Office of Associate Chief Counsel (Corporate), said the guidance project was recently added to the IRS 2014-15 priority guidance plan after officials became aware of certain issues with the rules.
The guidance will take a “Band-Aid” approach to address issues in “some narrow instances that can be fixed fairly quickly and where the result of our actions would help a lot of people,” he said.
Weiss spoke Oct. 15 at a session on taxable transactions at a Practising Law Institute tax strategies program.

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