Section 5. Dispute Resolution Procedures

for Nonparticipants

Appeals Office consideration will not be available for Son of Boss transactions. For all taxpayers ineligible or not participating in this initiative, the Service will (a) develop the cases, (b) disallow all tax benefits and attributes claimed from the Son of

2004-21 I.R.B. 965 May 24, 2004

Correction of Publication

Accordingly, 26 CFR Part 1 is corrected by making the following correcting amendments:

PART 1 — INCOME TAXES

Paragraph 1. The authority citation for part 1 continues to read in part as follows:

Authority: 26 U.S.C. 7805 * * *

§1.1502–35T [Corrected]

Par. 2. Section 1.1502–35T(f)(1), the language “expired as of the day following the last” is removed and the language “expired as of the beginning of the day following the last”.

Par. 3. Section 1.1502–35T(f)(1), the language “shall be treated as expired as of the day” is removed and the language “shall be treated as expired as of the beginning of the day”.

LaNita Van Dyke, Acting Chief, Publications

and Regulations Branch, Legal Processing Division,

Associate Chief Counsel (Procedure and Administration) .

(Filed by the Office of the Federal Register on May 5, 2004, 8:45 a.m., and published in the issue of the Federal Register for May 6, 2004, 69 F.R. 25315)

with an estimated average of 5 hours. The estimated number of respondents is 1000.

The estimated frequency of responses is one time per respondent.

Books or records relating to a collection of information must be retained as long as their contents may become material in the administration of any internal revenue law. Generally tax returns and tax return information are confidential, as required by 26 U.S.C. 6103.

CONTACT INFORMATION

For additional information regarding this announcement, including answers to frequently asked questions, see www.irs.gov, or contact Paul Zamolo of the Office of Division Counsel (SB/SE) at (415) 744–9217 (not a toll-free number) or James Fee of the Office of Division Counsel (LMSB) at (215) 597–3442 (not a toll-free number).

Loss Limitation Rules; Correction

Announcement 2004–47

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendment.

SUMMARY: This document contains corrections to T.D. 9118, 2004–15 I.R.B. 718

[69 FR 12799], which was published in the Federal Register on Thursday, March 18, 2004, relating to certain aspects of the temporary regulations addressing the deductibility of losses recognized on dispositions of subsidiary stock by members of a consolidated group and to the consequences of treating subsidiary stock as worthless.

DATES: This correction is effective on March 18, 2004.

FOR FURTHER INFORMATION CONTACT: Mark Weiss (202) 622–7790 or Lola Johnson (202) 622–7550 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The temporary regulations (T.D. 9118) that are the subject of this correction is under 1502 of the Internal Revenue Code.

Need for Correction

As published, T.D. 9118 contains errors that may prove to be misleading and are in need of clarification.

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