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Taxpayers should continue to rely on the expired temporary regulations under the signing date rule as they seek to satisfy the continuity of interest requirement for reorganization purposes, a senior IRS attorney says. Lee A. Kelley, IRS's deputy associate chief counsel (Corporate), says revising the temporary regulations under the signing date rule remains a priority. At the same time, Kelley stresses that there are still several issues the service must sort through before issuing a final regulation.
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