This document contains corrections to temporary regulations (T.D. 9186, 2005-13 I.R.B. 790) which were published in the Federal Register on Wednesday, March 2, 2005 (70 FR 10037). The temporary regulations modify the rules relating to qualified amended returns by providing additional circumstances that end the period within which a taxpayer may file an amended return that constitutes a qualified amended return.
The temporary regulations (T.D. 9186) that are the subject of these corrections are under section 6227 of the Internal Revenue Code.
As published, T.D. 9186 contains errors that may prove to be misleading and are in need of clarification.
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Accordingly, 26 CFR Part 1 is corrected by making the following correcting amendments:
Paragraph 1. The authority citation for part 1 continues to read in part as follows:
Authority: 26 USC 7805 * * *
1. Section 1.6664-2T(c)(3)(i)(B) is amended by removing “of an activity” and adding “for an activity” in its place.
2. Section 1.6664-2T(c)(3)(ii)(A) is amended by removing “§1.6664-2(c)(3)(i)” and adding “§1.6664-2T(c)(3)(i)” in its place.
3. Section 1.6664-2T(c)(3)(ii)(C) is amended by removing “who is a material advisor (within the meaning of section 6111)” and adding “from any person who gave the taxpayer material aid, assistance, or advice as described in section 6111(b)(1)(A)(i)” in its place.
4. Section §1.6664-2T(c)(5) Example 3., is redesignated as §1.6664-2T(c)(5) Example 3 (i).
5. Newly designated §1.6664-2T(c)(5) Example 3. (i) is amended by removing “2003” and adding “2004” each place it appears.
6. The undesignated text in §1.6664-2T(c)(5) Example 3. is designated as §1.6664-2T(c)(5) Example 3. (ii).
7. Section 1.6664-2T(c)(5) Example 4., the first sentence is amended by removing “2003” and adding “2004” in its place.
8. Section 1.6664-2T(c)(5) Example 7., is redesignated as §1.6664-2T(c)(5) Example 7. (i).
9. The undesignated text in §1.6664-2T(c)(5) Example 7. is designated as §1.6664-2T(c)(5) Example 7. (ii).
Cynthia E. Grigsby,The Internal Revenue Bulletin is produced and published by the Internal Revenue Service and contains IRS pronouncements affecting tax analysis under the Code and the Regulations, including but not limited to Revenue Procedures, Revenue Rulings, Notices and Announcements. Access the IRS site at https://www.irs.gov/help/irsgov-accessibility for information concerning accessibility of IRS materials. While every effort has been made to ensure that the IRB database files available through the TouchTax application are accurate, those using TouchTax for legal research should verify their results against the printed versions of the IRBs available from the IRS.