Government Submissions



October 27, 2017
Comments on Proposed Amendments to 34 Tex. Admin. Code Section 3.588, concerning margin: cost of goods sold


August 11, 2017
Comments on Proposed Regulations Regarding Implementing Centralized
Partnership Audit Regime



August 7, 2017
Comments in Response to Notice 2017-38 Regarding Final Regulations
Under Section 7602 on the Participation of a Person Described in Section
6103(n) in a Summons Interview


Comments in Response to Notice 2017-38 Regarding Proposed Regulations
Under Sections 2704 and 6035



August 1, 2017
Comments on Proposed Regulations Regarding Implementing Centralized Partnership Audit Regime


June 23, 2017
Comments on Notice Issued April 24, 2017, Document Number 2017-08155, 82 FR 18969


June 2, 2017
Comments on Proposed Amendments to 34 Tex. Admin. Code
Section 3.585, “Margin: Annual Report Extension”



May 19, 2017
Comments on Proposed Amendments to 34 Tex. Admin.
Code Section 1.29, “Motion for Rehearing”


Comments on Proposed Amendments to 34 Tex. Admin.
Code Section 1.28, “Comptroller’s Decisions and Orders”


Comments on Proposed Amendments to 34 Tex. Admin.
Code Section 1.8, “Resolution Agreements”


Comments on Proposed New 34 Tex. Admin. Code
Section 1.41, “Ex Parte Communications”



January 24, 2017
Comments on Limits on Availability of In-Person Appeals Conferences
Texas Society of Certified Public Accountants and the Tax Section of the State Bar of Texas


December 16, 2016
Comments on Proposed Amendments to 34
Tex. Admin. Code Section 1.41, “Ex Parte Communications”


Comments on Proposed Amendments to 34
Tex. Admin. Code Section 1.32, “Service of Documents on Parties”


Comments on Proposed Amendments to 34
Tex. Admin. Code Section 1.29, “Motion for Rehearing”


Comments on Proposed Amendments to 34
Tex. Admin. Code Section 1.28, “Decisions and Orders”


Comments on Proposed Amendments to 34
Tex. Admin. Code Section 1.18, “Filing Documents”


Comments on Proposed Amendments to 34
Tex. Admin. Code Section 1.8, “Resolution Agreements”


Comments on Proposed Amendments to 34
Tex. Admin. Code Section 1.4, “Representation and Participation”



November 2, 2016
Discussion Topics for Public Hearing on Proposed Regulations
Regarding Estate, Gift and Generation-Skipping Transfer
Taxes; Restrictions on Liquidation of an Interest


Comments on Proposed Regulations Regarding Estate,
Gift, and Generation-Skipping Transfer Taxes;
Restrictions on Liquidation of an Interest

Estate and Gift Tax Committee


October 24, 2016
Comments on Proposed Regulations for Deferred Compensation
Plans of State and Local Governments and Tax-Exempt Entities
and the Application of Section 409A to Nonqualified Deferred
Compensation Plans



September 28, 2016
Comments on Proposed Amendments to 34 Tex. Admin. Code
Section 3.292, “Repair, Remodeling, Maintenance,
and Restoration of Tangible Personal Property”



June 17, 2016
Comments on Consistent Basis Reporting
Estate & Gift Tax Committee


June 15, 2016
Comments on Franchise Tax, Proposed Rule 3.584
State & Local Tax Committee


May 17, 2016
Comments on Form 706-GS(D-1)
Estate & Gift Tax Committee


April 27, 2016
Comments on U.S. Tax Courts, Rules of Practice and Procedure
Tax Controversy Committee


March 11, 2016
Comments Regarding Innocent Spouse Regulations
Tax Controversy Committee


February 8, 2016
Comments on U.S. Tax Court’s Rules of Practice and Procedure
Tax Controversy Committee


February 5, 2016
Comments regarding changes to the determination letter program for individually designed plans
Employee Benefits Committee


December 3, 2015
Comments on Proposed Regulations Regarding Amount of Penalty Under Section 6707A, IRS REG-103033-11
Tax Controversy Committee
General Tax Issues Committee


November 6, 2015
Comments on IRS Notice 2015-72 Regarding Proposed Revenue Procedure to Update Rev. Proc. 87-24
Tax Controversy Committee


October 30, 2015
Comments on U.S. Tax Court's Rules of Practice and Procedure
Tax Controversy Committee
Pro Bono Committee


July 31, 2015
Comments on Economic Development Rules
State and Local Tax Committee


April 24, 2015
Comments on De Minimis Safe Harbor of Treas. Reg. § 1.263(a)-1(f)
General Tax Issues Committee


January 29, 2015
Comments Pertaining to The Texas Comptroller's Proposed Rule 3.13 Relating to Timely Filing and Payment
State and Local Tax Committee


January 7, 2015
Comments on Texas Department of Insurance Draft Rules Regarding Professional Employer Organizations and Self-Funded Health Benefit Plans
Employee Benefits Committee


December 19, 2014
Comments on Proposed Texas Comptroller Rule 3.286 (Sales & Use Tax Responsibilities and Nexus)
State and Local Tax Committee


December 3, 2014
Comments on Proposed Texas Comptroller Rules 3.280 (Aircraft) and 3.285 (Sale for Resale)
State and Local Tax Committee


September 16, 2014
Comments on Proposed Regulations Concerning Summons Interviews
Tax Controversy Committee


June 26, 2014
Comments Suggesting Revision of Circular 230 Concerning Contingent Fees
Tax Controversy Committee
Solo and Small Firm Committee 



June 25, 2014
Comments on Discrimination Testing Standards for Softly Frozen Defined Benefit Plans
Employee Benefits Committee


June 20, 2014
Comments on Proposed Regulations Concerning Reimbursement for Preformation Capital Expenditures
Corporate Tax Committee



May 5, 2014
Comments on Proposed Regulations Concerning Contributions of Built-in-loss Property
Energy and Natural Resources Committee



January 7, 2014
Comments on Proposed Regulations Relating to Relief From Joint and Several Liability
Tax Controversy Committee
General Tax Issues Committee



September 19, 2013
Comments on Proposed Regulations Under Section 6708 Relating to Failure to Maintain List of Advisees
Tax Controversy Committee
Energy and Natural Resources Committee 



May 31, 2013
Comments on Proposed Regulations Regarding Net Investment Income Tax Under Section 1411
Corporate Tax Committee
Partnership and Real Estate Committee 


Comments on Form 706-GS(D)
Estate and Gift Tax Committee



April 12, 2013
Comments Concerning Proposed Ammendments to Comptroller Rule 3.588 (cost of goods sold)
State and Local Tax Committee



April 9, 2013
Comments on Proposed Regulations Under Section 4980H of the Internal Revenue Code of 1986
Employee Benefits Committee



March 4, 2013
Comments on Proposed Regulations Regarding Net Investment Income Tax Under Section 1411 of the Internal Revenue Code
Estate and Gift Tax Committee



January 25, 2013
Comments on Proposed Regulations Relating to Incentives for Nondiscriminatory Wellness Programs in Group Health Plans
Employee Benefits Committee



December 14, 2012
Comments on Proposed Regulation relating to Circular 230 (REG-138367-06)
Tax Controversy Committee
Energy and Natural Resources Committee



September 26, 2012
Comments on Proposed Regulation relating to property transferred in connection with the performance of service under Section 83 of the Internal Revenue Code
Corporate Tax Committee
Employee Benefits Committee



August 23, 2012
Response to Comptroller Request for Comments Concerning proposed Amendments to Rules 3.1 and 3.10
State and Local Tax Committee


Response to Comptroller Request for Comments Concerning Proposed Amendments to Rule 3.325
State and Local Tax Committee



February 27, 2012
Proposed Amendments to U.S. Tax Court Rules
Tax Controversy Committee



January 30, 2012
Response to Announcement 2011-78 Request for Comments Regarding Proposed Guidance Concerning Governmental Plan Status Under Section 414(d) of the Internal Revenue Code of 1986, as amended
Employee Benefits Committee



January 26, 2012
Request for the Issuance of Additional Guidance Regarding the Application of Section 197(f)(9) of the Internal Revenue Code of 1986, as amended
Corporate Tax Committee



September 23, 2011
Comments Regarding Nondiscrimination Requirements of Section 105(h) to Fully-Insured Plans
Employee Benefits Committee



August 15, 2011
Comments Regarding Proposed Revenue Procedure on Ex Parte Communications by Appeals
Tax Controversy Committee



May 11, 2011
Comments on Suggested Amendments to Texas Property Code § 42.0021, Concerning Exemption of Retirement Funds and Inherited IRAs
Employee Benefits Committee


March 30, 2011
Comments Concerning Texas Franchise Tax
State and Local Tax Committee



March 28, 2011
Comments Proposed Regulations – Series LLCs and Cell Companies
Partnership and Real Estate Committee


February 22, 2011
Comments Regarding Proposed Changes to Comptoller Rule 1.9 Concerning Position Letters
State and Local Tax Committee



October 6, 2010
Comments on Proposed Amendments to Treasury Circular 230
Tax Controversy Committee



May 28, 2010
Comments on Proposal Regarding Uncertain Tax Positions
Tax Controversy Committee



November 25, 2009
Comments on Comptroller Proposed Rule 3.582(e)
State and Local Tax Committee


December 1, 2008
Request for Deadline Extension for Documentary Compliance with Section 409A
Employee Benefits Committee


October 16, 2008
Comments on Notice 2008-20, Intermediary Transaction Tax Shelter
Corporate Tax Committee


June 10, 2008
Comments on Treasury Regulations Under Section 401(a)(9)
Employee Benefits Committee


April 11, 2008
Comments on Proposed Regulations Concerning Marketing of Refund Anticipation Loans
Pro Bono Committee


April 10, 2008
Comments on Proposed Taxation of Carried Interests
Partnership and Real Estate Committee
Energy and Natural Resources Committee


February 21, 2008
Testimony at IRS Public Hearing, Regarding Tax Strategy Patents


January 11, 2008
Comments on Proposed Comptroller Rule 3.588(c)(2)(A), Cost of Goods Sold
State and Local Tax Committee


December 21, 2007
Comments on Proposed Regulations, Disclosure of Reportable Transactions
Tax Controversy Committee


October 12, 2007
Comments on Proposed Comptroller’s Margin Tax Rules
State and Local Tax Committee


September 14, 2007
Comments Regarding Tax Strategy Patents


January 23, 2007
Comments Regarding Texas Margin Tax
State and Local Tax Committee


September 06, 2007
Comments Regarding Taxation of Carried Interests


January 29, 2007
Comments on Proposed Regulations, Disclosure of Reportable Transactions
Tax Controversy Committee


June 6, 2006
Comments Regarding Circular 230


December 31, 2005
Comments on Proposed Regulations Under Section 409A
Employee Benefits Committee


August 22, 2005
Comments on Proposed Regulations Concerning Transfers of Partnership Equity
Partnership and Real Estate Tax Committee




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