This announcement revises Revenue Procedure 2007-65, 2007-45 I.R.B. 967, by adding the following language to Section 3: “The requirements set forth in this revenue procedure that must be satisfied in order to qualify for the Safe Harbor, however, are not intended to provide substantive rules and are not to be used as audit guidelines,” and replacing “will not challenge” with “will respect” in Section 6.
The principal authors of this announcement are Vishal R. Amin and Richard T. Probst of the Office of Associate Chief Counsel (Passthroughs and Special Industries). For further information regarding this announcement, contact Vishal R. Amin or Richard T. Probst at (202) 622-3060 (not a toll-free call).
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