SECTION 3. SCOPE

This revenue procedure applies to a nonrequesting spouse who appeals the preliminary determination granting full or partial relief from joint and several liability to a requesting spouse.

tion of final regulations addressing this issue in the Federal Register. Note, however, that it is clear under current law that such a plan amendment is prohibited under § 411(d)(6) and § 411(a) (which provides vesting requirements for accrued benefits and prohibits forfeiture of a vested accrued benefit) if the amendment is adopted or effective after the occurrence of the contingent event.

V. COMMENTS REQUESTED

Comments regarding the anticipated proposed regulations described in this notice are requested, including comments on the guidance that should be provided regarding early retirement benefits and retirementtype subsidies. In addition, comments are requested on the extent to which such proposed regulations should include relief for amendments that eliminate or reduce early retirement benefits or retirement-type subsidies that are contingent on unpredictable events, that create significant burdens or complexities for the plan and plan participants, and that affect the rights of any participant in no more than a de minimis manner. Comments should be submitted by May 5, 2003, to CC:ITA:RU (Notice 2003– 10), Room 5226, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, D.C. 20044. Comments may be hand delivered between the hours of 8 a.m. and 5 p.m., Monday through Friday to CC:ITA:RU (Notice 2003–10), Courier’s Desk, Internal Revenue Service, 1111 Constitution Ave., NW, Washington D.C. Alternatively, comments may be submitted via the Internet at Notice.Comments @irscounsel.treas.gov . All comments will be available for public inspection.

VI. EFFECT ON OTHER DOCUMENTS

Notice 2002–46 is modified.

DRAFTING INFORMATION

The principal authors of this notice are Preston Rutledge of the Office of the Associate Chief Counsel (Tax Exempt and Government Entities) and Diane S. Bloom of the Employee Plans, Tax Exempt and Government Entities Division. For further information regarding this notice, contact the Employee Plans taxpayer assistance telephone service between the hours of 8:00 a.m. and 6:30 p.m. Eastern Time, Mon

day through Friday by calling 1–877–829– 5500 (a toll-free number). Mr. Rutledge can be reached at (202) 622–6090 and Ms. Bloom can be reached at (202) 283– 9888 (not toll-free numbers).

26 CFR 601.106: Appeals functions. (Also Part I, §§ 6015; 1.6015–6.)

Rev. Proc. 2003–19