[Federal Register Volume 79, Number 90 (Friday, May 9, 2014)]
[Rules and Regulations]
[Pages 26616-26620]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2014-10661]
[[Page 26616]]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9664]
RIN 1545-BF80
Section 67 Limitations on Estates or Trusts
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Final regulations and removal of temporary regulations.
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SUMMARY: This document contains final regulations that provide guidance
on which costs incurred by estates or trusts other than grantor trusts
(non-grantor trusts) are subject to the 2-percent floor for
miscellaneous itemized deductions under section 67(a) of the Internal
Revenue Code. These regulations affect estates and non-grantor trusts.
DATES: Effective Date: These regulations are effective on May 9, 2014.
Applicability Date: For date of applicability, see Sec. 1.67-4(d).
FOR FURTHER INFORMATION CONTACT: Jennifer N. Keeney, (202) 317-6852
(not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
This document amends the Income Tax Regulations (26 CFR Part 1)
under section 67 of the Internal Revenue Code (Code) by adding Sec.
1.67-4 regarding which costs incurred by an estate or a non-grantor
trust are subject to the 2-percent floor for miscellaneous itemized
deductions under section 67(a).
Section 67(a) of the Code provides that, for an individual
taxpayer, miscellaneous itemized deductions are allowed only to the
extent that the aggregate of those deductions exceeds 2 percent of
adjusted gross income. Section 67(b) excludes certain itemized
deductions from the definition of ``miscellaneous itemized
deductions.'' Section 67(e) provides that, for purposes of section 67,
the adjusted gross income of an estate or trust shall be computed in
the same manner as in the case of an individual. However, section
67(e)(1) provides that the deductions for costs paid or incurred in
connection with the administration of the estate or trust that would
not have been incurred if the property were not held in such estate or
trust shall be treated as allowable in arriving at adjusted gross
income. Therefore, deductions described in section 67(e)(1) are not
subject to the 2-percent floor for miscellaneous itemized deductions
under section 67(a).
A notice of proposed rulemaking (REG-128224-06) was published in
the Federal Register (72 FR 41243) on July 27, 2007 (the 2007 proposed
regulations). The 2007 proposed regulations provided that a cost is
fully deductible to the extent that the cost is unique to an estate or
trust. If a cost is not unique to an estate or trust, such that an
individual could have incurred the expense, then that cost was subject
to the 2-percent floor. The 2007 proposed regulations also addressed
costs subject to the 2-percent floor that are included as part of a
comprehensive fee paid to the trustee or executor (bundled fees).
Written comments were received in response to the notice of proposed
rulemaking. A public hearing was held on November 14, 2007, at which
several commentators offered comments on the notice of proposed
rulemaking.
On January 16, 2008, the Supreme Court of the United States issued
its decision in Michael J. Knight, Trustee of the William L. Rudkin
Testamentary Trust v. Commissioner, 552 U.S. 181, 128 S. Ct. 782
(2008), holding that fees paid to an investment advisor by an estate or
non-grantor trust generally are subject to the 2-percent floor for
miscellaneous itemized deductions under section 67(a). The Court
reached this decision based upon an interpretation of section 67(e)
that differed from the 2007 proposed regulations. The Court held that
the proper reading of the language in section 67(e), which asks whether
the expense ``would not have been incurred if the property were not
held in such trust or estate,'' requires an inquiry into whether a
hypothetical individual who held the same property outside of a trust
``customarily'' or ``commonly'' would incur such expenses. Expenses
that are ``customarily'' or ``commonly'' incurred by individuals are
subject to the 2-percent floor.
After consideration of the Court's holding in Knight, the Treasury
Department and the IRS issued Notice 2008-32 (2008-11 IRB 593) (March
17, 2008) to provide interim guidance on the treatment of bundled fees.
Subsequent notices extended the interim guidance. (Notice 2008-116
(2008-52 IRB 1372) (December 29, 2008); Notice 2010-32 (2010-16 IRB
594) (April 19, 2010); Notice 2011-37 (2011-20 IRB 785) (May 16,
2011)). On September 7, 2011, a notice of proposed rulemaking and a
notice of public hearing (REG-128224-06) were published in the Federal
Register (76 FR 55322) (the 2011 proposed regulations) and the 2007
proposed regulations were withdrawn.
A public hearing on the 2011 proposed regulations was scheduled for
December 19, 2011, but later was cancelled because no one requested to
speak. However, comments responding to the 2011 proposed regulations
were received. After consideration of these comments, the 2011 proposed
regulations are adopted as revised by this Treasury decision. These
final regulations generally retain the provisions of the 2011 proposed
regulations with minor modifications.
Summary of Comments and Explanation of Revisions
A. Commonly or Customarily Incurred--In General
The proposed regulations provide that a cost is subject to the 2-
percent floor to the extent that it is included in the definition of
miscellaneous itemized deductions under section 67(b), is incurred by
an estate or non-grantor trust, and commonly or customarily would be
incurred by a hypothetical individual holding the same property. To
determine whether the cost commonly or customarily would be incurred by
a hypothetical individual owning the same property, it is the type of
product or service rendered to the estate or non-grantor trust that is
determinative. The proposed regulations also provide that costs that do
not depend on the identity of the payor (in particular, whether the
payor is an individual or, instead, is an estate or trust) are costs
that are incurred commonly or customarily by individuals.
One commentator stated that treating costs that do not depend on
the identity of the payor as costs that are commonly or customarily
incurred in all cases is overly broad, and that such treatment
effectively represents a disguised reassertion of the standard rejected
by Knight of making the 2-percent floor applicable to any expense that
could be incurred by an individual. In response to this comment, the
final regulations remove the reference to costs that do not depend on
the identity of the payor.
B. Ownership Costs
The proposed regulations provide that, for purposes of section
67(e), ownership costs are costs that are commonly or customarily
incurred by a hypothetical individual owner of such property.
Therefore, ownership costs are subject to the 2-percent floor. The
proposed regulations define ownership costs as costs that are
chargeable to or incurred by an owner of property simply by reason of
being the owner of the property, such as condominium
[[Page 26617]]
fees, real estate taxes, insurance premiums, maintenance and lawn
services, automobile registration and insurance costs, and partnership
costs deemed to be passed through to and reportable by a partner. One
commentator suggested that the final regulations adopt a rebuttable
presumption that ownership costs are not subject to the 2-percent
floor. The final regulations do not adopt this comment because the
Treasury Department and the IRS believe that ownership costs are costs
that commonly or customarily would be incurred by a hypothetical
individual holding the same property, and accordingly, should be
subject to the 2-percent floor.
Several commentators stated that the examples used to illustrate
ownership costs in the proposed regulations are problematic. First,
commentators correctly pointed out that real estate taxes are not a
miscellaneous itemized deduction because they are fully deductible
under section 62(a)(4) or section 164(a). Second, commentators
suggested that the final regulations clarify that costs incurred in
connection with a trade or business or for the production of rents or
royalties are fully deductible under section 162 or section 62(a)(4)
and thus are not miscellaneous deductions. Third, a commentator
requested that the final regulations clarify that the partnership costs
reportable by a partner are subject to the 2-percent floor only if
those costs are miscellaneous itemized deductions under section 67(b).
Thus, for example, a partnership cost that is fully deductible is not
subject to the 2-percent floor. The final regulations adopt these
clarifications.
C. Tax Return Preparation Costs
The proposed regulations provide that the application of the 2-
percent floor to the cost of preparing tax returns on behalf of the
estate, decedent, or non-grantor trust will depend upon the particular
tax return. The proposed regulations provide that all costs of
preparing estate and generation-skipping transfer tax returns,
fiduciary income tax returns, and the decedent's final individual
income tax returns are not subject to the 2-percent floor. However, the
proposed regulations also provide that costs of preparing other
individual income tax returns, gift tax returns, and tax returns for a
sole proprietorship or a retirement plan, for example, are costs
commonly and customarily incurred by individuals and thus are subject
to the 2-percent floor.
Several commentators pointed out that it would be very rare for a
trust to pay for the preparation of the tax return of an individual
other than the decedent. In the unlikely event that it did, such a cost
would either be a deemed beneficiary distribution or would represent a
breach of fiduciary duty. Furthermore, tax preparation fees for sole
proprietorships and retirement plans would be fully deductible as
business expenses under section 162.
To resolve these ambiguities in the proposed regulations, the final
regulations provide an exclusive list of tax return preparation costs
that are not subject to the 2-percent floor. Any other tax return
preparation cost that is included in the definition of miscellaneous
itemized deduction under section 67(b) is subject to the 2-percent
floor.
A few commentators suggested that the final regulations should
expressly provide that the cost of preparing all gift tax returns
should be exempt from the application of the 2-percent floor. However,
gifts are made by individuals, and the gift tax returns required to
report those gifts are commonly and customarily required to be prepared
and filed by or on behalf of individuals. Therefore, the final
regulations do not adopt the recommendation to include gift tax returns
within the category of returns whose preparation costs are exempt from
the 2-percent floor.
D. Investment Advisory Fees
The proposed regulations provide that fees for investment advice
(including any related services that would be provided to any
individual investor as part of an investment advisory fee) are incurred
commonly or customarily by a hypothetical individual investor and,
therefore, are subject to the 2-percent floor. The proposed regulations
also provide guidance regarding a special type of investment advice
discussed by the Supreme Court in Knight. The Court noted that it is
conceivable ``that a trust may have an unusual investment objective, or
may require a specialized balancing of the interests of various
parties, such that a reasonable comparison with individual investors
would be improper.'' The Court further stated that, ``in such a case,
the incremental cost of expert advice beyond what would normally be
required for the ordinary taxpayer would not be subject to the 2-
percent floor.''
The proposed regulations provide that, to the extent that a portion
(if any) of an investment advisory fee exceeds the fee generally
charged to an individual investor, and that excess is attributable to
an unusual investment objective of the trust or estate or to a
specialized balancing of the interests of various parties such that a
reasonable comparison with individual investors would be improper, that
excess is not subject to the 2-percent floor. The preamble to the
proposed regulations explained that individual investors commonly have
investment objectives that may require a balancing between investing
for income and investing for growth and/or a specialized approach for
particular assets. The preamble requested comments on the types of
incremental charges, as described in this paragraph, that may be
incurred by trusts or estates, as well as a specific description and
rationale for any such charges. No response to this request was
received, and the final regulations retain this provision as proposed.
E. Appraisal Fees and Certain Other Fiduciary Expenses
One commentator suggested that the final regulations include
appraisal fees incurred by an estate or trust as a category of expense
that is not subject to the 2-percent floor. Although individuals
commonly or customarily would have assets appraised, estates and non-
grantor trusts are required to undertake valuations for the maintenance
and administration of these entities that an individual would not
undertake. For example, Form 5227, ``Split-Interest Trust Information
Return'', requires taxpayers to determine the fair market value of the
trust's assets for each taxable year.
Accordingly, in response to these comments, the final regulations
expressly provide that certain appraisal fees incurred by an estate or
non-grantor trust are not subject to the 2-percent floor. Those
appraisal fees are for appraisals needed to determine value as of the
decedent's date of death (or the alternate valuation date), to
determine value for purposes of making distributions, or as otherwise
required to properly prepare the estate's or trust's tax returns.
Appraisals for these purposes are not customarily obtained by
individuals (unlike, for example, appraisals to determine the proper
amount of insurance needed on certain property) and thus meet the
requirements for exemption from the 2-percent floor under section
67(e).
One commentator requested confirmation of the inapplicability of
the 2-percent floor to certain other fiduciary expenses. The final
regulations contain such a statement with regard to some examples of
fiduciary expenses that are not commonly or customarily incurred by
individuals.
[[Page 26618]]
F. Bundled Fees
The proposed regulations provide that a bundled fee (generally, a
fee for both costs that are subject to the 2-percent floor and costs
that are not) must be allocated between those two categories of costs.
However, the proposed regulations provide an exception to this
allocation requirement for a bundled fee that is not computed on an
hourly basis. Specifically, for such a fee, only the portion
attributable to investment advice (including any related services that
would be provided to any individual investor as part of the investment
advisory fee) will be subject to the 2-percent floor. Notwithstanding
this exception, payments made to third parties out of the bundled fee
that would have been subject to the 2-percent floor if they had been
paid directly by the estate or non-grantor trust, and any payments for
expenses separately assessed by the fiduciary or other service provider
that are commonly or customarily incurred by an individual owner of
such property will be subject to the 2-percent floor.
The proposed regulations contain an example to illustrate a type of
expense that is separately assessed: an additional fee charged by the
fiduciary for managing rental real estate owned by the estate or non-
grantor trust. Several commentators correctly noted that the expense in
this example is not a miscellaneous itemized deduction, but is instead
fully deductible. See sections 62(a)(4), 212, and 611. Therefore, the
final regulations delete this example.
Most commentators objected to the requirement that a fiduciary
commission be unbundled. They recommended that a single fiduciary
commission that is not computed on an hourly basis, or otherwise
separately stated, be entirely exempt from the 2-percent floor. The
primary reason that commentators gave for this recommendation is the
administrative difficulty and burden of the required calculations and
recordkeeping. At least one commentator, however, acknowledged that
unbundling a fiduciary commission is appropriate to provide the same
tax treatment to the same expenses, regardless of how those expenses
are billed.
Commentators also challenged the regulatory authority to require
this unbundling, arguing that there is no statutory ambiguity with
regard to a fiduciary commission and thus no authority to apply the 2-
percent floor to any portion of that commission.
The Treasury Department and IRS believe the authority to unbundle
rests with the authority to define expenses that ``would not have been
incurred if the property were not held in such trust or estate.''
Consistent with the Knight decision, these final regulations interpret
this statutory exception to the 2-percent floor to capture those
expenses that would not commonly or customarily be incurred by an
individual. In identifying these expenses, the Knight Court
specifically recognized that unbundling may be required in the case of
investment advisory fees, the costs of which exceed the costs charged
to an individual investor and which are incurred either because the
investment advice is being rendered to a fiduciary or because of an
unusual investment objective or the need for a specialized balancing of
interests of various parties. The final regulations adopt this
reasoning and, consistent with the Knight decision, provide that the
portion of such a fee in excess of what would have been charged to an
individual investor may be exempt from the 2-percent floor. Based upon
the Knight decision and the authority to promulgate interpretative
regulations, the Treasury Department and IRS believe that the final
regulations are within the scope of regulatory authority.
The Treasury Department and IRS also believe that retaining the
unbundling requirement in the final regulations is appropriate because
it provides equitable tax treatment to similarly situated taxpayers.
Taxpayers that pay investment fees to a third-party investment advisor
and those that pay investment fees as part of a bundled fee should
receive similar tax treatment.
The Treasury Department and IRS also believe that the limitations
to the unbundling requirement reduce administrative burdens. For
example, a fiduciary fee, an attorney's fee, or an accountant's fee
that is not computed on an hourly basis is fully deductible except for
(i) amounts allocable to investment advice; (ii) amounts paid out of
the bundled fee by the fiduciary to third parties if those amounts
would have been subject to the 2-percent floor if they had been paid
directly by the non-grantor estate or trust; and (iii) amounts that are
separately assessed (in addition to the usual or basic fiduciary fee or
commission) by the fiduciary or other service provider that are
commonly or customarily incurred by an individual owner of such
property. Because the latter two categories relate to amounts that are
traceable to separate payments, the Treasury Department and IRS believe
that the administrative burden associated with subjecting these amounts
to the 2-percent floor is insubstantial.
Furthermore, where amounts are allocable to investment advice but
are not traceable to separate payments, the final regulations retain
the flexibility of allowing the use of any reasonable method to make
the allocation to investment advice. The Treasury Department and the
IRS believe that the availability of any reasonable method mitigates
administrative burden. However, to provide additional guidance, these
final regulations provide non-exclusive factors to further reduce
administrative burden for both taxpayers and the IRS.
In the preamble to the proposed regulations, the Treasury
Department and the IRS requested comments on the types of methods for
making a reasonable allocation to investment advice, including possible
factors on which a reasonable allocation is most likely to be based,
and on the related substantiation needed to satisfy the reasonable
method standard. The Treasury Department and the IRS received only one
comment in response to this request, which explained that there is no
single standard that could be applied to multiple trusts or even to the
same trust in different years.
In finalizing these regulations, the Treasury Department and the
IRS reconsidered comments received in response to Notice 2008-32.
Although some comments supported a percentage safe harbor, the
percentages suggested assumed that all fees that are customarily
incurred by individuals (and not just investment advisory fees) would
be required to be unbundled. For this reason, the percentages that were
suggested are not readily applied to the framework of the final
regulations. The final regulations, however, permit the Treasury
Department and the IRS to provide safe harbors in future published
guidance.
Effective/Applicability Date
The final regulations apply to taxable years beginning on or after
May 9, 2014.
Availability of IRS Documents
The IRS notices cited in this preamble are available at
www.irs.gov.
Special Analyses
It has been determined that this Treasury decision is not a
significant regulatory action as defined in Executive Order 12866, as
supplemented by Executive Order 13563. Therefore, a regulatory
assessment is not required. It also has been determined that section
553(b) of the Administrative Procedure Act (5 U.S.C. chapter 5) does
not apply to these regulations, and because these
[[Page 26619]]
regulations do not impose a collection of information on small
entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not
apply. Pursuant to section 7805(f) of the Code, the notice of proposed
rulemaking that preceded these regulations was submitted to the Chief
Counsel for Advocacy of the Small Business Administration for comment
on its impact on small business, and no comments were received.
Drafting Information
The principal author of these regulations is Jennifer N. Keeney,
Office of the Associate Chief Counsel (Passthroughs and Special
Industries). However, other personnel from the Treasury Department and
the IRS participated in their development.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and recordkeeping requirements.
Adoption of Amendments to the Regulations
Accordingly, 26 CFR part 1 is amended as follows:
PART 1--INCOME TAXES
0
Paragraph 1. The authority citation for part 1 continues to read in
part as follows:
Authority: 26 U.S.C. 7805 * * *
0
Par. 2. Section 1.67-4 is added to read as follows:
Sec. 1.67-4 Costs paid or incurred by estates or non-grantor trusts.
(a) In general. Section 67(e) provides an exception to the 2-
percent floor on miscellaneous itemized deductions for costs that are
paid or incurred in connection with the administration of an estate or
a trust not described in Sec. 1.67-2T(g)(1)(i) (a non-grantor trust)
and that would not have been incurred if the property were not held in
such estate or trust. A cost is subject to the 2-percent floor to the
extent that it is included in the definition of miscellaneous itemized
deductions under section 67(b), is incurred by an estate or non-grantor
trust, and commonly or customarily would be incurred by a hypothetical
individual holding the same property.
(b) ``Commonly'' or ``Customarily'' Incurred--(1) In general. In
analyzing a cost to determine whether it commonly or customarily would
be incurred by a hypothetical individual owning the same property, it
is the type of product or service rendered to the estate or non-grantor
trust in exchange for the cost, rather than the description of the cost
of that product or service, that is determinative. In addition to the
types of costs described as commonly or customarily incurred by
individuals in paragraphs (b)(2), (3), (4), and (5) of this section,
costs that are incurred commonly or customarily by individuals also
include, for example, costs incurred in defense of a claim against the
estate, the decedent, or the non-grantor trust that are unrelated to
the existence, validity, or administration of the estate or trust.
(2) Ownership costs. Ownership costs are costs that are chargeable
to or incurred by an owner of property simply by reason of being the
owner of the property. Thus, for purposes of section 67(e), ownership
costs are commonly or customarily incurred by a hypothetical individual
owner of such property. Such ownership costs include, but are not
limited to, partnership costs deemed to be passed through to and
reportable by a partner if these costs are defined as miscellaneous
itemized deductions pursuant to section 67(b), condominium fees,
insurance premiums, maintenance and lawn services, and automobile
registration and insurance costs. Other expenses incurred merely by
reason of the ownership of property may be fully deductible under other
provisions of the Code, such as sections 62(a)(4), 162, or 164(a),
which would not be miscellaneous itemized deductions subject to section
67(e).
(3) Tax preparation fees. Costs relating to all estate and
generation-skipping transfer tax returns, fiduciary income tax returns,
and the decedent's final individual income tax returns are not subject
to the 2-percent floor. The costs of preparing all other tax returns
(for example, gift tax returns) are costs commonly and customarily
incurred by individuals and thus are subject to the 2-percent floor.
(4) Investment advisory fees. Fees for investment advice (including
any related services that would be provided to any individual investor
as part of an investment advisory fee) are incurred commonly or
customarily by a hypothetical individual investor and therefore are
subject to the 2-percent floor. However, certain incremental costs of
investment advice beyond the amount that normally would be charged to
an individual investor are not subject to the 2-percent floor. For this
purpose, such an incremental cost is a special, additional charge that
is added solely because the investment advice is rendered to a trust or
estate rather than to an individual or attributable to an unusual
investment objective or the need for a specialized balancing of the
interests of various parties (beyond the usual balancing of the varying
interests of current beneficiaries and remaindermen) such that a
reasonable comparison with individual investors would be improper. The
portion of the investment advisory fees not subject to the 2-percent
floor by reason of the preceding sentence is limited to the amount of
those fees, if any, that exceeds the fees normally charged to an
individual investor.
(5) Appraisal fees. Appraisal fees incurred by an estate or a non-
grantor trust to determine the fair market value of assets as of the
decedent's date of death (or the alternate valuation date), to
determine value for purposes of making distributions, or as otherwise
required to properly prepare the estate's or trust's tax returns, or a
generation-skipping transfer tax return, are not incurred commonly or
customarily by an individual and thus are not subject to the 2-percent
floor. The cost of appraisals for other purposes (for example,
insurance) is commonly or customarily incurred by individuals and is
subject to the 2-percent floor.
(6) Certain Fiduciary Expenses. Certain other fiduciary expenses
are not commonly or customarily incurred by individuals, and thus are
not subject to the 2-percent floor. Such expenses include without
limitation the following: Probate court fees and costs; fiduciary bond
premiums; legal publication costs of notices to creditors or heirs; the
cost of certified copies of the decedent's death certificate; and costs
related to fiduciary accounts.
(c) Bundled fees--(1) In general. If an estate or a non-grantor
trust pays a single fee, commission, or other expense (such as a
fiduciary's commission, attorney's fee, or accountant's fee) for both
costs that are subject to the 2-percent floor and costs (in more than a
de minimis amount) that are not, then, except to the extent provided
otherwise by guidance published in the Internal Revenue Bulletin, the
single fee, commission, or other expense (bundled fee) must be
allocated, for purposes of computing the adjusted gross income of the
estate or non-grantor trust in compliance with section 67(e), between
the costs that are subject to the 2-percent floor and those that are
not.
(2) Exception. If a bundled fee is not computed on an hourly basis,
only the portion of that fee that is attributable to investment advice
is subject to the 2-percent floor; the remaining portion is not subject
to that floor.
(3) Expenses Not Subject to Allocation. Out-of-pocket expenses
billed to the estate or non-grantor trust are treated as separate from
the bundled fee. In addition, payments made from
[[Page 26620]]
the bundled fee to third parties that would have been subject to the 2-
percent floor if they had been paid directly by the estate or non-
grantor trust are subject to the 2-percent floor, as are any fees or
expenses separately assessed by the fiduciary or other payee of the
bundled fee (in addition to the usual or basic bundled fee) for
services rendered to the estate or non-grantor trust that are commonly
or customarily incurred by an individual.
(4) Reasonable Method. Any reasonable method may be used to
allocate a bundled fee between those costs that are subject to the 2-
percent floor and those costs that are not, including without
limitation the allocation of a portion of a fiduciary commission that
is a bundled fee to investment advice. Facts that may be considered in
determining whether an allocation is reasonable include, but are not
limited to, the percentage of the value of the corpus subject to
investment advice, whether a third party advisor would have charged a
comparable fee for similar advisory services, and the amount of the
fiduciary's attention to the trust or estate that is devoted to
investment advice as compared to dealings with beneficiaries and
distribution decisions and other fiduciary functions. The reasonable
method standard does not apply to determine the portion of the bundled
fee attributable to payments made to third parties for expenses subject
to the 2-percent floor or to any other separately assessed expense
commonly or customarily incurred by an individual, because those
payments and expenses are readily identifiable without any discretion
on the part of the fiduciary or return preparer.
(d) Effective/applicability date. This section applies to taxable
years beginning on or after May 9, 2014.
Sec. 1.67-4T [Removed]
0
Par. 3. Section 1.67-4T is removed.
John Dalrymple,
Deputy Commissioner for Services and Enforcement.
Approved: April 1, 2014.
Mark J. Mazur,
Assistant Secretary of the Treasury (Tax Policy).
[FR Doc. 2014-10661 Filed 5-8-14; 8:45 am]
BILLING CODE 4830-01-P