SECTION 2. EFFECTIVE DATE FOR

THE DISCLOSURE REGULATIONS UNDER § 6011

Treasury and the Service intend to revise the disclosure regulations under § 6011 to reflect the consideration of the comments received. Although the October 2002 temporary disclosure regulations under § 6011 will continue to apply to transactions entered into on or after January 1, 2003, the revised regulations under § 6011 will permit taxpayers who entered into transactions on or after January 1, 2003, and before the filing date of the revised regulations, to elect to apply the revised regulations instead of the October 2002 temporary disclosure regulations.