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Introduction

SECTION 4. REQUEST FOR

Internal Revenue Bulletin 2006-46 · 2026-10-03 edition · updated 2026-10-04 · United States

COMMENTS

The Service and the Treasury Department invite comments containing suggestions for future guidance under § 170(f)(11), including regulations. In particular, comments are requested concerning the definition of the following terms: (1) “generally accepted appraisal standards” in § 170(f)(11)(E)(i)(II); (2) “appraisal designation from a recognized professional appraisal organization” in § 170(f)(11)(E)(ii)(I); (3) “minimum education and experience requirements” in § 170(f)(11)(E)(ii)(I); and (4) “verifiable education and experience in valuing the type of property subject to the appraisal” in § 170(f)(11)(E)(iii)(I). Comments also are requested on the potential impact any guidance under § 170(f)(11) may have on small businesses. Comments should refer to Notice 2006–96 and be submitted by January 17, 2007, to:

Internal Revenue Service P.O. Box 7604 Ben Franklin Station Washington, D.C. 20044 Attn: CC:PA:LPD:PR Room 5203

Alternatively, comments may be submitted electronically via

November 13, 2006 903 2006–46 I.R.B.

Taxation and Reporting of Excess Inclusion Income by REITs, RICs, and Other Pass-Through Entities

Notice 2006–97

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