Censure Issued by Consent

Under Title 31, Code of Federal Regulations, Part 10, in lieu of a proceeding being instituted or continued, an attorney, certified public accountant, enrolled agent,

or enrolled actuary, may offer his or her consent to the issuance of a censure. Censure is a public reprimand.

The following individuals have consented to the issuance of a Censure:

Name Address Designation Date of Censure

Pugno, Thomas Rockwood, MI Enrolled Agent June 29, 2005

Barrett, Richard Tyler, TX CPA August 1, 2005

Kelly, Michael G. Odessa, TX Attorney August 1, 2005

Volstad, Paul S. Plymouth, MN CPA August 18, 2005

Quackenbush, Gary A. San Diego, CA Attorney September 2, 2005

Flores, Fred A. Laredo, TX CPA September 2, 2005

Velasquez, Felix Laredo, TX CPA September 2, 2005

the meaning of § 267(b) (other than § 267(b)(1)) or § 707(b) is an ineligible person.

3. TEFRA partners of promoters . A partner in a disqualified entity in which (a) an ineligible partner claimed more than two percent of the improper tax benefits from the transaction at issue, or (b) ineligible partners in the aggregate claimed five percent or more of the improper tax benefits from the transaction, is an ineligible person. An “ineligible partner” is a person who is an ineligible person other than by reason of this paragraph 3. A “disqualified entity” is an entity that (i) is subject to the unified partnership audit and litigation provisions of §§ 6221 through 6234, as enacted by the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA partnership), (ii) engaged in a transaction described in section 3 of this announcement, and (iii) includes one or more ineligible partners. However, a partner who is

Settlement Initiative

Announcement 2005–80