EXCISE TAX

REG–100841–97, page 763. Proposed regulations under section 6159 of the Code govern the acceptance and rejection of installment agreements, the terms of those agreements and when they may be modified or terminated by the Service, and appeal procedures when the Service makes a rejection or termination decision. The principal purpose of this project is to update the regulations to reflect various amendments to section 6159 and related statutes.

Rev. Proc. 2007–25, page 761. This procedure provides additional guidance regarding the disclosure of certain penalties under section 6707A(e) of the Code on forms filed with the U.S. Securities and Exchange Commission. Rev. Proc. 2005–51, 2005–2 C.B. 296, provides that a person who files SEC Form 10–K, Annual Report, must disclose in Item 3 (Legal Proceedings) of Form 10–K the requirement to pay any penalty specified in section 2.05 of Rev. Proc. 2005–51. This procedure describes how persons who are required to file periodic reports under section 13 or 15(d) of the Securities Exchange Act of 1934, or required to be consolidated with another person for purposes of those reports, but that file these periodic reports on a form other than a Form 10–K, must make the appropriate disclosures on these other reports in order to avoid additional penalties. Rev. Proc. 2005–51 amplified.

(Continued on the next page)

March 19, 2007 2007–12 I.R.B.