Transactions Between Related Persons and Partnerships; Correction, 20371 [2024-06136]
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Federal Register / Vol. 89, No. 57 / Friday, March 22, 2024 / Proposed Rules
column, by correcting the fifth line of
the heading to read ‘‘1545–BL51’’.
DEPARTMENT OF THE TREASURY
Internal Revenue Service
Oluwafunmilayo A. Taylor,
Section Chief, Publications and Regulations
Section, Associate Chief Counsel, (Procedure
and Administration).
26 CFR Part 1
[REG–131756–11]
[FR Doc. 2024–06136 Filed 3–21–24; 8:45 am]
BILLING CODE 4830–01–P
RIN 1545–BL51
Transactions Between Related
Persons and Partnerships; Correction
Internal Revenue Service (IRS),
Treasury.
AGENCY:
Notice of proposed rulemaking;
correction.
ACTION:
This document corrects a
notice of proposed rulemaking (REG–
131756–11) published in the Federal
Register on November 27, 2023,
containing proposed regulations that
would update regulations regarding
whether persons are treated as related
persons who are subject to certain
special rules pertaining to transactions
with partnerships.
SUMMARY:
Written or electronic comments
were to be received by February 26,
2024.
DATES:
Commenters were strongly
encouraged to submit public comments
electronically.
ADDRESSES:
FOR FURTHER INFORMATION CONTACT:
Concerning the proposed regulations,
relating to section 267, Livia Piccolo,
(202) 317–7007 (not a toll-free number);
concerning the proposed regulation
relating to section 707, Charles D. Wien,
(202) 317–5279 (not a toll-free number);
concerning submissions of comments or
the public hearing, Vivian Hayes, (202)
317–6901 (not toll-free number) or by
email to publichearings@irs.gov
(preferred).
SUPPLEMENTARY INFORMATION:
Background
The notice of proposed rulemaking
(REG–131756–11) that is the subject of
this correction is under sections 267 and
707 of the Code.
ddrumheller on DSK120RN23PROD with PROPOSALS1
Need for Correction
As published, the notice of proposed
rulemaking (REG–131756–11) contains
an error that needs to be corrected.
Correction of Publication
Accordingly, the notice of proposed
rulemaking (REG–131756–11) that is the
subject of FR Doc. 2023–25715,
published on November 27, 2023, is
corrected on page 82792, in the third
VerDate Sep<11>2014
18:08 Mar 21, 2024
Jkt 262001
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 301
[REG–117542–22]
RIN 1545–BQ96
Advance Notice of Third-Party
Contacts
Internal Revenue Service (IRS),
Treasury.
ACTION: Notice of proposed rulemaking.
AGENCY:
This document contains
proposed regulations relating to the
notice that the IRS must provide to a
taxpayer in advance of IRS contact with
a third party with respect to the
determination or collection of the
taxpayer’s tax liability, to reflect
amendments made to the applicable tax
law by the Taxpayer First Act of 2019.
The regulations would affect taxpayers
to whom the IRS must provide advance
notice of IRS contact with such third
parties.
SUMMARY:
Electronic or written comments
and requests for a public hearing must
be received by May 21, 2024.
ADDRESSES: Commenters are strongly
encouraged to submit public comments
electronically. Submit electronic
submissions via the Federal
eRulemaking Portal at https://
www.regulations.gov (indicate IRS and
IRS REG–117542–22) by following the
online instructions for submitting
comments. Requests for a public hearing
must be submitted as prescribed in the
‘‘Comments and Requests for Public
Hearing’’ section. Once submitted to the
Federal eRulemaking Portal, comments
cannot be edited or withdrawn. The
Department of the Treasury (Treasury
Department) and the IRS will publish
any comments submitted electronically
or on paper to the public docket. Send
paper submissions to: CC:PA:01:PR
(REG–117542–22), Room 5203, Internal
Revenue Service, P.O. Box 7604, Ben
Franklin Station, Washington, DC
20044.
DATES:
FOR FURTHER INFORMATION CONTACT:
Concerning the proposed regulations,
Brittany Harrison of the Office of the
PO 00000
Frm 00018
Fmt 4702
Sfmt 4702
20371
Associate Chief Counsel (Procedure and
Administration), (202) 317–6833 (not
toll-free number); concerning the
submission of comments and requests
for a public hearing, Vivian Hayes, (202)
317–6901 (not toll-free number) or by
sending an email to publichearings@
irs.gov (preferred).
SUPPLEMENTARY INFORMATION:
Background
This document contains proposed
regulations that would amend the
Procedure and Administration
Regulations (26 CFR part 301) relating to
the advance notice of IRS contact with
third parties that must be provided to
taxpayers under section 7602(c) of the
Internal Revenue Code (Code).
Generally, the Federal tax system
relies upon taxpayers’ self-assessment
and reporting of their tax liabilities. The
expansive information-gathering
authority that Congress has granted to
the Secretary of the Treasury or her
delegate (Secretary) under the Code
includes the IRS’s broad examination
and summons authority, which allows
the IRS to determine the accuracy of
that self-assessment. See United States
v. Arthur Young & Co., 465 U.S. 805,
816 (1984). Section 7602(a) provides
that, for the purpose of ascertaining the
correctness of any return, making a
return in cases in which none has been
made, determining the liability of any
person for any internal revenue tax, or
collecting any such liability, the
Secretary is authorized to examine
books and records, issue summonses
seeking documents and testimony, and
take testimony from witnesses under
oath as may be relevant or material.
Section 7602(b) further provides that the
purposes for which the Secretary may
examine books and records, issue
summonses, and take testimony under
oath include the purpose of inquiring
into any offense connected with the
administration or enforcement of the
internal revenue laws.
Section 7602(c) was added to the
Code by section 3417 of the Internal
Revenue Service Restructuring and
Reform Act of 1998, Public Law 105–
206, 112 Stat. 685 (RRA 98). Section
7602(c)(1), as added by RRA 98,
required that the IRS provide the
taxpayer ‘‘reasonable notice in advance’’
before it contacted a third party with
respect to the determination or
collection of the tax liability of such
taxpayer. Final regulations interpreting
and implementing section 7602(c) as
enacted by RRA 98 were promulgated in
2002. TD 9028 (67 FR 77419). Section
301.7602–2(d)(1) of the Procedure and
Administration Regulations provides
that the pre-contact notice may be given
E:\FR\FM\22MRP1.SGM
22MRP1
]]>Agencies
[Federal Register Volume 89, Number 57 (Friday, March 22, 2024)]
[Proposed Rules]
[Page 20371]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2024-06136]
[[Page 20371]]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[REG-131756-11]
RIN 1545-BL51
Transactions Between Related Persons and Partnerships; Correction
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice of proposed rulemaking; correction.
-----------------------------------------------------------------------
SUMMARY: This document corrects a notice of proposed rulemaking (REG-
131756-11) published in the Federal Register on November 27, 2023,
containing proposed regulations that would update regulations regarding
whether persons are treated as related persons who are subject to
certain special rules pertaining to transactions with partnerships.
DATES: Written or electronic comments were to be received by February
26, 2024.
ADDRESSES: Commenters were strongly encouraged to submit public
comments electronically.
FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations,
relating to section 267, Livia Piccolo, (202) 317-7007 (not a toll-free
number); concerning the proposed regulation relating to section 707,
Charles D. Wien, (202) 317-5279 (not a toll-free number); concerning
submissions of comments or the public hearing, Vivian Hayes, (202) 317-
6901 (not toll-free number) or by email to [email protected]
(preferred).
SUPPLEMENTARY INFORMATION:
Background
The notice of proposed rulemaking (REG-131756-11) that is the
subject of this correction is under sections 267 and 707 of the Code.
Need for Correction
As published, the notice of proposed rulemaking (REG-131756-11)
contains an error that needs to be corrected.
Correction of Publication
Accordingly, the notice of proposed rulemaking (REG-131756-11) that
is the subject of FR Doc. 2023-25715, published on November 27, 2023,
is corrected on page 82792, in the third column, by correcting the
fifth line of the heading to read ``1545-BL51''.
Oluwafunmilayo A. Taylor,
Section Chief, Publications and Regulations Section, Associate Chief
Counsel, (Procedure and Administration).
[FR Doc. 2024-06136 Filed 3-21-24; 8:45 am]
BILLING CODE 4830-01-P
