INCOME TAX

REG–144620–04, page 1141. Proposed regulations under section 704(b) of the Code provide rules for testing the substantiality of an allocation where the partners are look-through entities or members of a consolidated group, provide additional guidance on the effect of other provisions, such as section 482, upon the tax treatment of a partner with respect to the partner’s distributive share under section 704(b), and revise the existing rules for determining the partners’ interests in the partnership. A public hearing is scheduled for February 15, 2006.

Finding Lists begin on page ii.