[Federal Register Volume 81, Number 233 (Monday, December 5, 2016)]
[Rules and Regulations]
[Pages 87444-87448]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-28993]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Parts 1 and 602
[TD 9799]
RIN 1545-BN61
Tax Return Preparer Due Diligence Penalty Under Section 6695(g)
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Final and temporary regulations.
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SUMMARY: This document contains temporary regulations that modify
existing regulations related to the penalty under section 6695(g) of
the Internal Revenue Code (Code) relating to
[[Page 87445]]
tax return preparer due diligence. These temporary regulations
implement recent law changes that expand the tax return preparer due
diligence penalty under section 6695(g) so that it applies to the child
tax credit (CTC), additional child tax credit (ACTC), and the American
Opportunity Tax Credit (AOTC), in addition to the earned income credit
(EIC). The temporary regulations affect tax return preparers. The
substance of the temporary regulations is included in the proposed
regulations set forth in the notice of proposed rulemaking on this
subject in the Proposed Rules section in this issue of the Federal
Register.
DATES: Effective Date: These regulations are effective on December 5,
2016.
Applicability Date: For dates of applicability, see Sec. 1.6695-
2T(e).
FOR FURTHER INFORMATION CONTACT: Rachel L. Gregory, 202-317-6845 (not a
toll-free number).
SUPPLEMENTARY INFORMATION:
Paperwork Reduction Act
The collection of information contained in these temporary and
final regulations is in Sec. Sec. 1.6695-2(b) and 1.6695-2T(b) and is
reported on Form 8867, ``Paid Preparer's Due Diligence Checklist.''
Responses to this collection of information are mandatory. The
collection of information in current Sec. 1.6695-2 was previously
reviewed and approved under control number 1545-1570. Control number
1545-1570 was discontinued in 2014, as the burden for the collection of
information contained in Sec. 1.6695-2 is reflected in the burden on
Form 8867 under control number 1545-1629.
Background
This document contains amendments to 26 CFR parts 1 and 602 under
section 6695(g) of the Code, imposing a penalty on tax return preparers
who fail to comply with the due diligence requirements imposed by the
Secretary by regulations with respect to determining the eligibility
for, or the amount of, the EIC. Section 6695(g) was added to the Code
because Congress believed more thorough efforts by tax return preparers
are important to improving EIC compliance. H.R. Rep. No. 105-148, 105th
Cong. 1st Sess., p. 512 (June 24, 1997).
Enacted by section 1085(a)(2) of the Taxpayer Relief Act of 1997,
Public Law 105-34 (11 Stat. 788, 955 (1997)), and effective for taxable
years beginning after December 31, 1996, section 6695(g) originally
imposed a $100 penalty on an income tax return preparer who failed to
meet the EIC due diligence requirements set forth in regulations
prescribed by the Secretary. Section 8246 of the Small Business and
Work Opportunity Tax Act of 2007, Public Law 110-28 (121 Stat. 112, 200
(2007)) amended the penalty to apply to all tax return preparers.
Section 501(a) of the United States-Korea Free Trade Agreement
Implementation Act, Public Law 112-41 (125 Stat. 428, 459 (2011)),
amended section 6695(g) to increase the amount of the penalty to $500,
effective for returns required to be filed after December 31, 2011.
Section 208(c), Div. B of the Tax Increase Prevention Act of 2014,
Public Law 113-295 (128 Stat. 4010, 4073 (2014)) (2014 Act), added
section 6695(h), which indexes the penalty amount for inflation,
effective for returns or claims for refund filed after December 31,
2014.
Section 1.6695-2 implements section 6695(g) by imposing due
diligence requirements on persons who are tax return preparers under
section 7701(a)(36) with respect to determining eligibility for, or the
amount of, the EIC. The due diligence requirements set forth in Sec.
1.6695-2(b) are that the preparer must: (1) Complete and submit Form
8867, ``Paid Preparer's Earned Income Credit Checklist;'' (2) complete
the Earned Income Credit Worksheet (Worksheet), as contained in the
Form 1040 instructions or record the preparer's computation of the
credit, including the method and information used to make the
computation; (3) not know or have reason to know that any information
used by the preparer in determining eligibility for, and the amount of,
the EIC is incorrect and make reasonable inquiries when required,
documenting those inquiries and responses contemporaneously (knowledge
requirement); and (4) retain, for three years from the applicable date,
the Form 8867, the Worksheet (or alternative records), and the record
of how and when the information used to determine eligibility for, and
the amount of, the EIC was obtained by the preparer, including the
identity of any person furnishing information and a copy of any
document relied on by the preparer.
To comply with the knowledge requirement under Sec. 1.6695-
2(b)(3), the tax return preparer may not ignore the implications of
information furnished to, or known by, the tax return preparer, and
must make reasonable inquiries if the information furnished to the tax
return preparer appears to be incorrect, inconsistent, or incomplete.
Examples in Sec. 1.6695-2(b)(3)(ii) illustrate this requirement. This
knowledge requirement is consistent with the verification requirement
imposed on all tax return preparers with respect to preparation of any
tax return or claim for refund under the accuracy-related standards set
forth in Sec. 1.6694-1(e).
A tax return preparer is required to submit the Form 8867 to the
IRS when the preparer electronically files the tax return. If a tax
return preparer required to complete the Form 8867 is not
electronically filing the taxpayer's return with the IRS, Sec. 1.6695-
2(b)(1) provides rules for submission of the form. If the tax return
preparer required to complete the Form 8867 is not the signing tax
return preparer, the preparer satisfies the submission requirement by
providing a copy of the completed Form 8867 to the signing tax return
preparer. If the tax return preparer required to complete the Form 8867
is the signing tax return preparer but the taxpayer is not
electronically filing the return, the preparer must provide a copy of
the completed Form 8867 to the taxpayer to be attached to the return
being filed with the IRS.
Section 1.6695-2(c) provides that a firm that employs a tax return
preparer subject to a penalty under section 6695(g) is also subject to
a penalty if certain conditions apply. Under this rule, a firm will be
subject to a penalty if and only if one or more members of principal
management (or principal officers) of the firm or branch participated
in, or prior to the time the return was filed, knew of the failure to
comply with the due diligence requirements; the firm failed to
establish reasonable and appropriate procedures to ensure compliance
with the due diligence requirements; or, through willfulness,
recklessness, or gross indifference (including ignoring facts that
would lead a person of reasonable prudence and competence to
investigate or ascertain) the firm disregarded its own reasonable and
appropriate compliance procedures. A firm subject to a section 6695(g)
penalty under this section is not eligible for the exception to the
penalty in Sec. 1.6695-2(d). Under this exception, the penalty will
not be applied if the tax return preparer can demonstrate to the
satisfaction of the IRS that, considering all of the facts and
circumstances, the tax return preparer's normal office procedures are
reasonably designed and routinely followed to ensure compliance with
the due diligence requirements, and the failure to meet the due
diligence requirements with respect to the particular tax return or
claim for refund was isolated and inadvertent.
Section 207, Div. Q of the Protecting Americans from Tax Hikes Act
of 2015, Public Law 114-113 (129 Stat. 2242, 3082 (2015)) (PATH Act)
amended section 6695(g) by expanding the scope
[[Page 87446]]
of the due diligence requirements to also include claims of the CTC/
ACTC under section 24 and the AOTC under section 25A(a)(1), effective
for taxable years beginning after December 31, 2015.
These temporary regulations reflect the changes made to section
6695(g) by the PATH Act by expanding the due diligence requirements to
the CTC/ACTC and the AOTC. These temporary regulations also conform the
regulation to the 2014 Act, reflecting that the penalty is to be
adjusted for inflation.
Explanation of Provisions
The temporary regulations amend Sec. 1.6695-2 to implement the
changes made by the PATH Act that extend the preparer due diligence
requirements to returns or claims for refund including claims of the
CTC/ACTC and/or AOTC in addition to the EIC. As a result of these
changes, one return or claim for refund may contain claims for more
than one credit subject to the due diligence requirements. Pursuant to
the statute, each failure to comply with the due diligence requirements
set forth in regulations prescribed by the Secretary results in a
penalty. The section 6695(g) requirements apply to each credit claimed,
meaning more than one penalty could apply to a single return or claim
for refund. The temporary regulations provide examples to show how
multiple penalties could apply when one return or claim for refund is
filed.
The Form 8867 has been revised for the 2016 tax year and is a
single checklist to be used for all applicable credits (EIC, CTC/ACTC,
and/or AOTC) on the return or claim for refund subject to the section
6695(g) due diligence requirements. The Form 8867 was streamlined to
eliminate unnecessary redundancy with other forms and schedules. These
changes were intended to reduce burden while increasing the utility of
the Form 8867 as a checklist for tax return preparers to more
accurately determine taxpayer eligibility for credits, thereby reducing
errors and increasing compliance by preparers and taxpayers. The
temporary regulations clarify Sec. 1.6695-2(b)(1)(ii) to illustrate
that the completion of Form 8867 can be based on information provided
by the taxpayer to the preparer or otherwise reasonably obtained or
previously known by the preparer.
The examples provided in Sec. 1.6695-2(b)(3)(ii) have been updated
to provide more insight into when a tax return preparer has satisfied
the due diligence knowledge requirement, including for purposes of the
CTC and AOTC. The updates to the examples in Sec. 1.6695-2T(b)(3)(ii)
illustrate that the knowledge requirement for purposes of due diligence
can be satisfied in conjunction with a tax return preparer's
information-gathering activities done for the purpose of accurately
completing other aspects of a tax return or claim for refund. New
examples, Example 2 and Example 4, have also been added to illustrate
that in certain circumstances a tax return preparer may satisfy the
knowledge requirement based on existing knowledge without having to
make additional reasonable inquiries. Another new example, Example 7,
provides an example of due diligence for purposes of the AOTC.
Section 1.6695-2(a) is amended by the temporary regulations to
reflect the changes made by section 208(c) of the 2014 Act, requiring
the IRS to index the penalty for inflation for returns or claims for
refund filed after December 31, 2014. In addition, Sec. 1.6695-
2T(c)(3) clarifies the parenthetical therein by removing the words ``or
ascertained.''
Special Analyses
Certain IRS regulations, including this one, are exempt from the
requirements of Executive Order 12866, as supplemented and reaffirmed
by Executive Order 13563. Therefore, a regulatory assessment is not
required. For applicability of the Regulatory Flexibility Act, please
refer to the cross-reference notice of proposed rulemaking published
elsewhere in this issue of the Federal Register. Pursuant to section
7805(f) of the Code, these regulations have been submitted to the Chief
Counsel for Advocacy of the Small Business Administration for comment
on the impact on small businesses.
Drafting Information
The principal author of this regulation is Rachel L. Gregory,
Office of the Associate Chief Counsel (Procedure & Administration).
List of Subjects
26 CFR Part 1
Income taxes, Reporting and recordkeeping requirements.
26 CFR Part 602
Reporting and recordkeeping requirements.
Adoption of Amendments to the Regulations
Accordingly, 26 CFR parts 1 and 602 are amended as follows:
PART 1--INCOME TAXES
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Paragraph 1. The authority citation for part 1 is amended by adding a
new entry in numerical order to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Section 1.6695-2T is also issued under 26 U.S.C. 6695(g).
* * * * *
0
Par. 2. Section 1.6695-2 is amended by revising the section heading and
paragraphs (a), (b)(1)(i) introductory text, (b)(1)(ii), (b)(2),
(b)(3)(i) and (ii), (b)(4)(i)(B) and (C), and (c)(3) to read as
follows:
Sec. 1.6695-2 Tax return preparer due diligence requirements for
certain credits.
(a) [Reserved]. For further guidance regarding the penalty for
failure to meet due diligence requirements with respect to certain
credits, see Sec. 1.6695-2T(a).
(b) * * *
(1) * * *
(i) [Reserved]. For further guidance regarding the completion of
Form 8867, see Sec. 1.6695-2T(b)(1)(i).
* * * * *
(ii) [Reserved]. For further guidance regarding the information
used to complete the Form 8867, see 1.6695-2T(b)(1)(ii).
(2) [Reserved]. For further guidance regarding computation, see
Sec. 1.6695-2T(b)(2).
(3) * * *
(i) [Reserved]. For further guidance regarding the knowledge
requirement, see Sec. 1.6695-2T(b)(3)(i).
(ii) [Reserved]. For current examples, see Sec. 1.6695-
2T(b)(3)(ii).
(4) * * *
(i) * * *
(B) [Reserved]. For further guidance on the retention of records,
see Sec. 1.6695-2T(b)(4)(i)(B).
(C) [Reserved]. For further guidance on the retention of records,
see Sec. 1.6695-2T(b)(4)(i)(C).
* * * * *
(c) * * *
(3) [Reserved]. For further guidance on the special rule for firms,
see Sec. 1.6695-2T(c)(3).
* * * * *
0
Par. 3. Section 1.6695-2T is added to read as follows:
Sec. 1.6695-2T Tax return preparer due diligence requirements for
certain credits (Temporary).
(a) Penalty for failure to meet due diligence requirements--(1) In
general. A person who is a tax return preparer (as defined in section
7701(a)(36)) of a tax return or claim for refund under the Internal
Revenue Code with respect to determining the eligibility for, or the
amount of, the child tax credit (CTC) and additional child tax credit
(ACTC) under section 24, the American
[[Page 87447]]
opportunity tax credit (AOTC) under section 25A(i), or the earned
income credit (EIC) under section 32 and who fails to satisfy the due
diligence requirements of paragraph (b) of this section will be subject
to a penalty as prescribed in section 6695(g) (indexed for inflation
under section 6695(h)) for each failure. A separate penalty applies
with respect to each credit claimed on a return or claim for refund for
which the due diligence requirements of this section are not satisfied
and for which the exception to penalty provided by paragraph (d) of
this section does not apply.
(2) Examples. The provisions of paragraph (a)(1) of this section
are illustrated by the following examples:
Example 1. Preparer A prepares a federal income tax return for
a taxpayer claiming the CTC and the AOTC. Preparer A did not meet
the due diligence requirements under this section with respect to
the CTC or the AOTC claimed on the taxpayer's return. Unless the
exception to penalty provided by paragraph (d) of this section
applies, Preparer A is subject to two penalties under section
6695(g): One for failure to meet the due diligence requirements for
the CTC and a second penalty for failure to meet the due diligence
requirements for the AOTC.
Example 2. Preparer B prepares a federal income tax return for
a taxpayer claiming the CTC and the AOTC. Preparer B did not meet
the due diligence requirements under this section with respect to
the CTC claimed on the taxpayer's return, but Preparer B did meet
the due diligence requirements under this section with respect to
the AOTC claimed on the taxpayer's return. Unless the exception to
penalty provided by paragraph (d) of this section applies, Preparer
B is subject to one penalty under section 6695(g) for the failure to
meet the due diligence requirements for the CTC. Preparer B is not
subject to a penalty under section 6695(g) for failure to meet the
due diligence requirements for the AOTC.
(b) [Reserved]. For further guidance, see Sec. 1.6695-2(b).
(1) Completion and submission of Form 8867. (i) The tax return
preparer must complete Form 8867, ``Paid Preparer's Due Diligence
Checklist,'' or such other form and such other information as may be
prescribed by the Internal Revenue Service (IRS), and--
(A) through (C) [Reserved]. For further guidance, see Sec. 1.6695-
2(b)(1)(i)(A) through (C).
(ii) The tax return preparer's completion of Form 8867 must be
based on information provided by the taxpayer to the tax return
preparer or otherwise reasonably obtained or known by the tax return
preparer.
(2) Computation of credit or credits. (i) When computing the amount
of a credit described in paragraph (a) of this section to be claimed on
a return or claim for refund, the tax return preparer must either--
(A) Complete the worksheet in the Form 1040, 1040A, 1040EZ, and/or
Form 8863 instructions or such other form including such other
information as may be prescribed by the IRS applicable to each credit
described in paragraph (a) of this section claimed on the return or
claim for refund; or
(B) Otherwise record in one or more documents in the tax return
preparer's paper or electronic files the tax return preparer's
computation of the credit or credits claimed on the return or claim for
refund, including the method and information used to make the
computations.
(ii) The tax return preparer's completion of an applicable
worksheet described in paragraph (b)(2)(i)(A) of this section (or other
record of the tax return preparer's computation of the credit or
credits permitted under paragraph (b)(2)(i)(B) of this section) must be
based on information provided by the taxpayer to the tax return
preparer or otherwise reasonably obtained or known by the tax return
preparer.
(3) Knowledge--(i) In general. The tax return preparer must not
know, or have reason to know, that any information used by the tax
return preparer in determining the taxpayer's eligibility for, or the
amount of, any credit described in paragraph (a) of this section and
claimed on the return or claim for refund is incorrect. The tax return
preparer may not ignore the implications of information furnished to,
or known by, the tax return preparer, and must make reasonable
inquiries if a reasonable and well-informed tax return preparer
knowledgeable in the law would conclude that the information furnished
to the tax return preparer appears to be incorrect, inconsistent, or
incomplete. The tax return preparer must also contemporaneously
document in the files any inquiries made and the responses to those
inquiries.
(ii) Examples. The provisions of paragraph (b)(3)(i) of this
section are illustrated by the following examples:
Example 1. In 2018, Q, a 22 year-old taxpayer, engages Preparer
C to prepare Q's 2017 federal income tax return. Q completes
Preparer C's standard intake questionnaire and states that she has
never been married and has two sons, ages 10 and 11. Based on the
intake sheet and other information that Q provides, including
information that shows that the boys lived with Q throughout 2017,
Preparer C believes that Q may be eligible to claim each boy as a
qualifying child for purposes of the EIC and the CTC. However, Q
provides no information to Preparer C, and Preparer C does not have
any information from other sources, to verify the relationship
between Q and the boys. To meet the knowledge requirement in
paragraph (b)(3) of this section, Preparer C must make reasonable
inquiries to determine whether each boy is a qualifying child of Q
for purposes of the EIC and the CTC, including reasonable inquiries
to verify Q's relationship to the boys, and Preparer C must
contemporaneously document these inquiries and the responses.
Example 2. Assume the same facts as in Example 1 of this
paragraph (b)(3)(ii). In addition, as part of preparing Q's 2017
federal income tax return, Preparer C made sufficient reasonable
inquiries to verify that the boys were Q's legally adopted children.
In 2019, Q engages Preparer C to prepare her 2018 federal income tax
return. When preparing Q's 2018 federal income tax return, Preparer
C is not required to make additional inquiries to determine the boys
relationship to Q for purposes of the knowledge requirement in
paragraph (b)(3) of this section.
Example 3. In 2018, R, an 18 year-old taxpayer, engages
Preparer D to prepare R's 2017 federal income tax return. R
completes Preparer D's standard intake questionnaire and states that
she has never been married, has one child, an infant, and that she
and her infant lived with R's parents during part of the 2017 tax
year. R also provides Preparer D with a Form W-2 showing that she
earned $10,000 during 2017. R provides no other documents or
information showing that R earned any other income during the tax
year. Based on the intake sheet and other information that R
provides, Preparer D believes that R may be eligible to claim the
infant as a qualifying child for the EIC and the CTC. To meet the
knowledge requirement in paragraph (b)(3) of this section, Preparer
D must make reasonable inquiries to determine whether R is eligible
to claim these credits, including reasonable inquiries to verify
that R is not a qualifying child of her parents (which would make R
ineligible to claim the EIC) or a dependent of her parents (which
would make R ineligible to claim the CTC), and Preparer D must
contemporaneously document these inquiries and the responses.
Example 4. The facts are the same as the facts in Example 3 of
this paragraph (b)(3)(ii). In addition, Preparer D previously
prepared the 2017 joint federal income tax return for R's parents.
Based on information provided by R's parents, Preparer D has
determined that R is not eligible to be claimed as a dependent or as
a qualifying child for purposes of the EIC or CTC on R's parents'
return. Therefore, for purposes of the knowledge requirement in
paragraph (b)(3) of this section, Preparer D is not required to make
additional inquiries to determine that R is not her parents'
qualifying child or dependent.
Example 5. In 2018, S engages Preparer E to prepare his 2017
federal income tax return. During Preparer E's standard intake
interview, S states that he has never been married and his niece and
nephew lived with him for part of the 2017 tax year. Preparer E
believes S may be eligible to claim each of these children as a
qualifying child for purposes of the EIC and the CTC. To meet the
[[Page 87448]]
knowledge requirement in paragraph (b)(3) of this section, Preparer
E must make reasonable inquiries to determine whether each child is
a qualifying child for purposes of the EIC and the CTC, including
reasonable inquiries about the children's parents and the children's
residency, and Preparer E must contemporaneously document these
inquiries and the responses.
Example 6. W engages Preparer F to prepare her federal income
tax return. During Preparer F's standard intake interview, W states
that she is 50 years old, has never been married, and has no
children. W further states to Preparer F that during the tax year
she was self-employed, earned $10,000 from her business, and had no
business expenses or other income. Preparer F believes W may be
eligible for the EIC. To meet the knowledge requirement in paragraph
(b)(3) of this section, Preparer F must make reasonable inquiries to
determine whether W is eligible for the EIC, including reasonable
inquiries to determine whether W's business income and expenses are
correct, and Preparer F must contemporaneously document these
inquiries and the responses.
Example 7. Y, who is 32 years old, engages Preparer G to
prepare his federal income tax return. Y completes Preparer G's
standard intake questionnaire and states that he has never been
married. As part of Preparer G's client intake process, Y provides
Preparer G with a copy of the Form 1098-T Y received showing that
University M billed $4,000 of qualified tuition and related expenses
for Y's enrollment or attendance at the university and that Y was at
least a half-time undergraduate student. Preparer G believes that Y
may be eligible for the AOTC. To meet the knowledge requirements in
paragraph (b)(3) of this section, Preparer G must make reasonable
inquiries to determine whether Y is eligible for the AOTC, as Form
1098-T does not contain all the information needed to determine
eligibility for the AOTC or to calculate the amount of the credit if
Y is eligible, and contemporaneously document these inquiries and
the responses.
(4) Retention of records. (i) [Reserved]. For further guidance, see
Sec. 1.6695-2(b)(4)(i).
(A) [Reserved]. For further guidance, see Sec. 1.6695-
2(b)(4)(i)(A).
(B) A copy of each completed worksheet required under paragraph
(b)(2)(i)(A) of this section (or other record of the tax return
preparer's computation permitted under paragraph (b)(2)(i)(B) of this
section); and
(C) A record of how and when the information used to complete Form
8867 and the applicable worksheets required under paragraph
(b)(2)(i)(A) of this section (or other record of the tax return
preparer's computation permitted under paragraph (b)(2)(i)(B) of this
section) was obtained by the tax return preparer, including the
identity of any person furnishing the information, as well as a copy of
any document that was provided by the taxpayer and on which the tax
return preparer relied to complete Form 8867 and/or an applicable
worksheet required under paragraph (b)(2)(i)(A) of this section (or
other record of the tax return preparer's computation permitted under
paragraph (b)(2)(i)(B) of this section).
(ii) through (iii) [Reserved]. For further guidance, see Sec.
1.6695-2(b)(4)(ii) through (iii).
(c) [Reserved]. For further guidance, see Sec. 1.6695-2(c).
(1) through (2) [Reserved]. For further guidance, see Sec. 1.6695-
2(c)(1) through (2).
(3) The firm disregarded its reasonable and appropriate compliance
procedures through willfulness, recklessness, or gross indifference
(including ignoring facts that would lead a person of reasonable
prudence and competence to investigate) in the preparation of the tax
return or claim for refund with respect to which the penalty is
imposed.
(d) [Reserved]. For further guidance, see Sec. 1.6695-2(d).
(e) Applicability date. This section applies to tax returns and
claims for refund prepared on or after December 5, 2016 with respect to
tax years beginning after December 31, 2015. For returns and claims for
refund prepared before December 5, 2016 with respect to tax years
beginning before January 1, 2016, the rules that apply are contained in
Sec. 1.6695-2 in effect prior to December 5, 2016. (See 26 CFR part 1
revised as of April 2016).
(f) Expiration date. This section will expire on December 5, 2019.
PART 602--OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT
0
Par. 4. The authority citation for part 602 continues to read as
follows:
Authority: 26 U.S.C. 7805.
Sec. 602.101 [Amended]
0
Par. 5. In Sec. 602.101, paragraph (b) is amended by removing the
entry for Sec. 1.6695-2 from the table.
John M. Dalrymple,
Deputy Commissioner for Services and Enforcement.
Approved: November 21, 2016.
Mark J. Mazur,
Assistant Secretary of the Treasury (Tax Policy).
[FR Doc. 2016-28993 Filed 12-2-16; 8:45 am]
BILLING CODE 4830-01-P