SECTION 4. EFFECTIVE DATE

This notice applies for taxable years ending on or after December 31, 2006.

With respect to taxable years ending before December 31, 2006, the interim rules provided in Notice 2007–19 are still effective if a taxpayer so chooses. Consequently, a “non-covered person” within the meaning of Notice 2007–19 may choose to apply the interim rules of that notice to a taxable year ending before December 31, 2006, by filing U.S. Form 1040 with the IRS as provided in the notice. A “covered person” within the meaning of Notice 2007–19 who chooses to apply the interim rules of that notice to a taxable year ending before December 31, 2006, need only provide the documentation specified in the notice upon examination.