SECTION 5. SUBMISSION OF

COMMENTS

.01 Written comments should be submitted on or before December 26, 2025. Consideration will be given, however, to any written comment submitted after December 26, 2025, if such consideration will not delay the issuance of guidance. The subject line for the comments should include a reference to Notice 2025-70. Comments may be submitted in one of two ways:

(1) Electronically via the Federal eRulemaking Portal at www.regulations. gov (type IRS-2025-0466 in the search field on the regulations.gov homepage to find this notice and submit comments).

(2) Alternatively, by mail to: Internal Revenue Service, CC:PA:01:PR (Notice 2025-70), Room 5503, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. .02 All commenters are strongly encouraged to submit comments electronically. The Treasury Department and the IRS will publish for public availability any comment submitted electronically, or on paper, to its public docket on www.regulations.gov.