[Federal Register Volume 74, Number 149 (Wednesday, August 5, 2009)]
[Proposed Rules]
[Pages 39003-39007]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E9-18659]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 301
[REG-112756-09]
RIN 1545-BI60
Amendments to the Regulations Regarding Questions and Answers
Relating to Church Tax Inquiries and Examinations
AGENCY: Internal Revenue Service (``IRS''), Treasury.
ACTION: Notice of proposed rulemaking.
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SUMMARY: This document contains proposed regulations amending the
questions and answers relating to church tax inquiries and
examinations. These proposed regulations replace references to
positions that were abolished by the Internal Revenue Service
Restructuring and Reform Act of 1998 with references that are
consistent both with the statute and the IRS's current organizational
structure.
DATES: Written or electronic comments and requests for a public hearing
must be received by November 3, 2009.
ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG-112756-09), Room
5205, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station,
Washington, DC 20044. Submissions may be hand-delivered Monday through
Friday between the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR (REG-
112756-09), Courier's Desk, Internal Revenue Service, 1111 Constitution
Avenue, NW., Washington, DC, or sent electronically, via the Federal
eRulemaking Portal at http://www.regulations.gov (IRS-REG-112756-09).
FOR FURTHER INFORMATION CONTACT: Concerning these proposed regulations,
Benjamin Akins at (202) 622-1124 or Monice Rosenbaum at (202) 622-6070;
concerning submission of comments and requests for a public hearing,
Richard Hurst, [email protected], (202) 622-7180
(not a toll-free numbers).
SUPPLEMENTARY INFORMATION:
Background
Restrictions on Church Tax Inquiries and Examinations
This document contains amendments to the regulations on Procedure
and Administration (26 CFR part 301) under section 7611 of the Internal
Revenue Code. Section 7611 was enacted by section 1033 of the Deficit
Reduction Act of 1984 (Pub. L. 98-369, 98 Stat. 1034-1039) (``DRA
1984'').
Prior to the enactment of section 7611, section 7605(c) imposed
special requirements that the IRS had to meet before it could examine
church books of account, but there were no special requirements imposed
before the IRS could commence an investigation or inquiry into a
church's tax liabilities. As explained in the Conference Report
accompanying DRA 1984, H.R. Rep. No. 98-861, 98th Cong., 2d Sess. 1101
(1984), 1984-3 CB Vol. 2 355, Congress sought to address certain
problems that arise when the IRS examines the records of a church.
Thus, Congress expanded the requirements relating to IRS interactions
with churches. Although prior law imposed limitations on the
examination of church records, those limitations were somewhat vague
and relied on internal IRS procedures to protect the rights of a church
in the examination process. Additionally, there was some uncertainty
regarding the scope of the investigations to which prior law applied
and the nature of the
[[Page 39004]]
records protected by the law. The enactment of section 7611 attempted
to resolve these competing considerations by providing detailed rules
for the IRS to follow in making tax inquiries to churches, both as to
tax-exempt status and as to the existence of unrelated business income.
Section 7611(a)(2) permits the IRS to begin an inquiry into whether
a church qualifies for exemption from income tax as an organization
described in section 501(c)(3) or whether a church has a liability for
unrelated business income tax only if an appropriate high-level
Treasury official first reasonably believes on the basis of facts and
circumstances, recorded in writing, that the church may not be exempt
under section 501(a), or that the church may be carrying on an
unrelated trade or business, or may be otherwise engaged in activities
subject to tax. Section 7611(h)(7) provides that the term ``appropriate
high-level Treasury official'' means the Secretary of the Treasury or
any delegate of the Secretary whose rank is no lower than that of a
principal Internal Revenue officer for an internal revenue region. The
legislative history of section 7611 interprets the term ``appropriate
high-level Treasury official'' to mean an IRS Regional Commissioner (or
higher official). H.R. Rep. No. 98-861, 98th Cong. 2d Sess. 1101
(1984), 1984-3 CB Vol. 2 355. Final regulations under section 7611,
which were published on February 21, 1986, 50 FR 6219, also interpret
the term to mean an IRS Regional Commissioner. See Treas. Reg. Sec.
301.7611 Q1-A1.
Section 7611(b)(2)(A) provides that at least 15 days before the
beginning of a church tax examination, the IRS must provide notice of
the examination to both the church and the appropriate regional
counsel. Section 7611(b)(3)(C) provides that any regional counsel who
receives notice under section 7611(b)(2)(A) may submit to a regional
commissioner an advisory objection to the examination within 15 days
after the notice of examination is provided.
Section 7611(c)(1)(A) provides that the IRS must make a final
determination as to any church tax inquiry or examination within two
years of the date the notice of examination is provided to the church
under section 7611(b). In instances where no examination follows a
church tax inquiry, section 7611(c)(1)(B) requires the IRS to make a
final determination as to the inquiry no later than 90 days after the
date the notice of inquiry is provided to the church under section
7611(a). Section 7611(c)(2) suspends the periods described in section
7611(c)(1) (that is, 2 year period and 90 day period) while certain
judicial proceedings are pending or being appealed, including
proceedings brought by the IRS against a church seeking to compel
compliance with a reasonable request to examine church records or
religious activities.
Section 7611(d)(1) prohibits the IRS from making certain final
determinations (that is, revocation of tax-exempt status, notice of
deficiency, or assessment) regarding a church until after the
appropriate regional counsel determines in writing that there has been
substantial compliance with the requirements of section 7611. Section
7611(d)(1) further requires the appropriate regional counsel's written
approval of such final determination before the IRS can make the
determination.
Section 7611(e)(1) provides that if the IRS has not substantially
complied with the requirements of section 7611, any proceeding to
compel compliance with a summons shall be stayed until the court finds
that the IRS has taken all practicable steps to correct the
noncompliance. Section 7611(e)(2) states that the remedy provided in
subsection (e)(1) shall be the exclusive remedy for a church in regard
to any noncompliance by the IRS with the requirements of section 7611.
Under section 7611(f), the IRS may not commence an inquiry or
examination of a church if, within the previous five years, the IRS
completed an inquiry or examination regarding the church that did not
result in a revocation, notice of deficiency, assessment, or a request
for a significant change in the church's operating practices. An
exception exists where the Secretary or his delegate approves the
second inquiry or examination in writing. There is also an exception
where the issues involved in the subsequent inquiry or examination are
not the same or similar to issues involved in the preceding inquiry or
examination. Prior to the Internal Revenue Service Restructuring and
Reform Act of 1998, Public Law 105-206 (``RRA 1998''), discussed below,
section 7611(f) required the Assistant Commissioner (Employee Plans and
Exempt Organizations), instead of the Secretary or his delegate, to
approve subsequent inquiries and examinations for the exception to
apply.
Reorganization of the IRS
Section 1001 of RRA 1998 requires the Commissioner of Internal
Revenue to develop and implement a plan to reorganize the IRS. The
congressional mandate provides that the plan shall ``eliminate or
substantially modify the existing organization of the IRS which is
based on a national, regional, and district structure; [and] establish
organizational units serving particular groups of taxpayers with
similar needs * * *.'' Under the reorganized IRS, four nationwide
operating divisions were established to serve different types of
taxpayers. One of these operating divisions serves tax exempt and
government entities, including churches.
Section 1102(e)(3) of RRA 1998 amended section 7611(f)(1), relating
to second inquiries and examinations within five years of a previous
inquiry or examination, by replacing Assistant Commissioner (Employee
Plans and Exempt Organizations) with Secretary. Under section
7701(a)(11)(B), Secretary is defined to refer to the Secretary of the
Treasury or his delegate. RRA 1998 did not amend other portions of
section 7611, such as references to ``appropriate high-level Treasury
official'' and ``appropriate regional counsel.''
In mandating the restructuring of the IRS under RRA 1998, Congress
realized that certain positions within the IRS would be eliminated as a
result of transitioning from a geographic structure to a structure
based on nationwide jurisdiction of similar types of taxpayers.
Accordingly, Congress included a savings provision in RRA 1998. Section
1001(b) provides, ``All orders, determinations, rules, regulations * *
* and other administrative actions * * * which are in effect at the
time this section takes effect * * * shall continue in effect according
to their terms until modified, terminated, superseded, set aside or
revoked in accordance with law by * * * the Secretary of the Treasury
[or] the Commissioner of Internal Revenue * * *.'' This provision keeps
in effect regulations that make reference to officers whose positions
no longer exist. The legislative history of RRA 1998 at H.R. Conf. Rep.
No. 105-599, 105th Cong., 2d Sess. 195 (1998) explains that ``[t]he
legality of IRS actions will not be affected pending further
appropriate statutory changes relating to such a reorganization (e.g.,
eliminating statutory references to obsolete positions).'' Accordingly,
the Treasury Regulations under section 7611 have remained in effect
notwithstanding their references to the positions of Regional
Commissioner, Regional Counsel, and Assistant Commissioner (Employee
Plans and Exempt Organizations), positions that were eliminated by the
reorganization. Delegation Order 193 (Rev. 6) (11/08/2000) provides in
part that actions previously delegated to
[[Page 39005]]
Regional Commissioners by Treasury Regulations (par. 7) are now
delegated to ``Assistant Deputy Commissioners, Division Commissioners;
Chiefs; and Directors, Submission Processing Field, Compliance Services
Field, and Accounts Management Field.'' In the Internal Revenue Manual
(``IRM''), the IRS designated the Director, Exempt Organizations
Examinations as the appropriate high-level Treasury official for
purposes of section 7611. See IRM Sec. 4.76.7.
Recent litigation has challenged the IRS's interpretation of the
term ``appropriate high-level Treasury official'' following the
reorganization. See United States v. Living Word Christian Center,
Civil No. 08-mc-37, D.C. Minn. (Jan. 30, 2009) (``LWCC''). In
particular, concern has been expressed about the need for an update to
the regulations in light of the statutorily mandated reorganization and
the elimination of internal revenue regions.
In LWCC, the District Court for the District of Minnesota ruled
that the Director, Exempt Organizations Examinations is not an
appropriate high-level Treasury official to make the ``reasonable
belief'' determination required before the IRS may commence a church
tax inquiry under section 7611. LWCC at 2. The district court concluded
that the Director, Exempt Organizations Examinations is not an
appropriate high-level Treasury official within the meaning of section
7611(h) because that official does not have a comparable breadth of
responsibility to a regional commissioner nor as high a position within
the IRS. Although the IRS disagrees with the district court's reasoning
and conclusion in LWCC, the IRS acknowledges that it would be
beneficial to revise the regulations in light of the changes in IRS
organization made in the wake of RRA 1998 to clarify who is an
appropriate high-level Treasury official for purposes of section 7611.
Further, the IRS recognizes the significance of the special procedural
requirements for church tax inquiries and examinations. These proposed
regulations assign responsibility for making the determinations
required under section 7611(a) to the Director, Exempt Organizations.
Explanation of Provisions
These proposed regulations eliminate references to the positions of
Regional Commissioner and Regional Counsel under the existing
regulations and give responsibilities formerly assigned to these now
defunct positions to the Director, Exempt Organizations and the
Division Counsel/Associate Chief Counsel, Tax Exempt and Government
Entities, respectively. In addition, these proposed regulations
eliminate references to the position of Assistant Commissioner
(Employee Plans and Exempt Organizations) under the existing
regulations and give responsibilities formerly assigned to that
position to the Commissioner, Tax Exempt and Government Entities or the
Deputy Commissioner, Tax Exempt and Government Entities.
Reasonable Belief and Inquiry Notice Requirement
With respect to the initiation of the church tax inquiry process,
Treas. Reg. Sec. 301.7611-1 Q1-A1 provides that a ``Regional
Commissioner (or higher Treasury official)'' is the appropriate high-
level Treasury official for purposes of this reasonable belief
requirement. Similarly, Treas. Reg. Sec. 301.7611-1 Q7-A7 states,
``Repeated (two or more) failures by a church or its agents to reply to
routine requests * * * will be considered by the appropriate Internal
Revenue Service Regional Commissioner to be a reasonable basis for
commencement of a church tax inquiry under the church tax inquiry and
examination procedures of section 7611.'' In addition, Treas. Reg.
Sec. 301.7611 Q9-A9 requires a Regional Commissioner to provide
written notice to the church of the beginning of an inquiry.
These proposed regulations eliminate references to the Regional
Commissioner and instead provide that the Director, Exempt
Organizations is the ``appropriate high-level Treasury official'' for
purposes of the reasonable belief and inquiry notice requirements of
Treas. Reg. Sec. 301.7611-1 Q1-A1, Q7-A7, and Q9-A9. The Director,
Exempt Organizations is a senior executive who reports to the
Commissioner/Deputy Commissioner, Tax Exempt and Government Entities
Division, and who is responsible for planning, managing, directing and
executing nationwide activities for Exempt Organizations. See IRM Sec.
1.1.23.5 for a comprehensive description of these activities.
Examination Notice Requirement
Under section 7611(b)(2) and Treas. Reg. Sec. 301.7611-1 Q10-A10,
a church tax examination cannot be commenced without first providing
written notice of such examination to the church and to the
``appropriate Regional Counsel'' at least 15 days before the IRS begins
the church tax examination. The regulation allows the Regional Counsel
to file an advisory objection to the examination within this same 15-
day period.
These proposed regulations amend Treas. Reg. Sec. 301.7611-1 Q10-
A10 by substituting Division Counsel/Associate Chief Counsel, Tax
Exempt and Government Entities, for each occurrence of Regional
Counsel. These proposed regulations further specify that before the
notice of examination is provided to the church, a copy of the notice
must be provided to the Division Counsel/Associate Chief Counsel, Tax
Exempt and Government Entities.
Revocation of Exemption or of Church Status
Section 7611(d)(1) and Treas. Reg. Sec. 301.7611-1 Q11-A11 require
the Regional Counsel to approve, in writing, certain final
determinations that are within the scope of section 7611 and adversely
affect the tax-exempt status or increase any tax liability of a church.
Further, prior to such adverse action, section 7611(d) requires
Regional Counsel to determine, in writing, that there has been
substantial compliance with the requirements of section 7611, when
applicable.
These proposed regulations amend Treas. Reg. Sec. 301.7611-1 Q11-
A11 by providing that the Division Counsel/Associate Chief Counsel, Tax
Exempt and Government Entities, is the official responsible for
complying with the written determination and approval requirements of
section 7611(d)(1).
Limitations on Period of Assessment
Section 7611(d)(2) and Treas. Reg. Sec. 301.7611-1 Q15-A15 provide
special limitation periods for church tax liabilities. These special
rules are not to be construed to increase an otherwise applicable
limitation period. Treas. Reg. Sec. 301.7611-1 Q15-A15 states that,
for purposes of section 7611(d)(2)(A), that is, the statute of
limitations applicable to liabilities arising from church tax
examinations, a church is determined not to be a church exempt from tax
when the appropriate Regional Commissioner approves, in writing, the
completed findings of the examining agent that the organization is not
a church exempt from tax for one or more of the three most recently
completed taxable years ending before the examination notice date. The
regulation also states that the Regional Commissioner cannot delegate
this approval to a subordinate official. Further, the completed
findings of the examining agent, which are approved by the appropriate
Regional Commissioner, are not considered a final revenue agent's
report (defined in section 7611(g)).
These proposed regulations substitute the Director, Exempt
Organizations for the appropriate Regional Commissioner
[[Page 39006]]
for purposes of Treas. Reg. Sec. 301.7611-1 Q15-A15.
Multiple Examinations
Consistent with the language of section 7611(f)(1) prior to
enactment of RRA 1998, Treas. Reg. Sec. 301-7611-1 Q16-A16 provides
that the Assistant Commissioner (Employee Plans and Exempt
Organizations) is responsible for providing the written approval
necessary to begin a second inquiry or examination of a church. These
proposed regulations provide that the Commissioner, Tax Exempt and
Government Entities or the Deputy Commissioner, Tax Exempt and
Government Entities is responsible for approving second inquiries and
examinations under section 7611(f).
Remedies for Violation of Section 7611
Section 7611(e) and Treas. Reg. Sec. 301.7611-1 Q17-A17 provide
that, if there has not been substantial compliance with certain
requirements in section 7611, including the notice requirements of
section 7611(a) and (b), the exclusive remedy for such noncompliance is
a stay in an enforcement proceeding to compel compliance with a summons
with respect to the inquiry or examination. The stay continues until
the court finds that all practicable steps to correct the noncompliance
have been taken. Treas. Reg. Sec. 301.7611-1 Q17-A17 further states
that failure of the Regional Commissioner to approve an inquiry may not
be raised as a defense or as an affirmative ground for relief in a
summons proceeding or any other judicial proceeding other than as
specifically set forth in the regulation.
These proposed regulations amend Treas. Reg. Sec. 301.7611-1 Q17-
A17 to replace each reference to Regional Commissioner with Director,
Exempt Organizations.
Special Analyses
It has been determined that this notice of proposed rulemaking is
not a significant regulatory action as defined in Executive Order
12866. Therefore, a regulatory assessment is not required. It has also
been determined that section 553(b) of the Administrative Procedure Act
(5 U.S.C. chapter 5) does not apply to these proposed regulations and
because the regulation does not impose a collection of information on
small entities, the Regulatory Flexibility Act (5 U.S.C. 601) does not
apply.
Pursuant to section 7805(f) of the Code, these proposed regulations
have been submitted to the Chief Counsel for Advocacy of the Small
Business Administration for comment on its impact on small business.
Comments and Requests for a Public Hearing
Before these proposed regulations are adopted as final regulations,
consideration will be given to any written comments (a signed original
and eight (8) copies) or electronic comments that are submitted timely
to the IRS. Comments are requested on all aspects of the proposed
regulations. All comments will be available for public inspection and
copying. A public hearing will be scheduled if requested in writing by
any person that timely submits written or electronic comments. If a
public hearing is scheduled, notice of the date, time, and place for
the public hearing will be published in the Federal Register.
Drafting Information
The principal authors of these proposed regulations are Benjamin
Akins and Monice Rosenbaum of the Office of Division Counsel/Associate
Chief Counsel (Tax Exempt and Government Entities). However, other
personnel from the IRS and the Treasury Department participated in
their development.
List of Subjects 26 CFR Part 301
Administrative practice and procedure, Bankruptcy, Courts, Crime,
Employment taxes, Estate taxes, Excise taxes, Gift taxes, Income taxes,
Investigations, Law enforcement, Penalties, Pensions, Statistics,
Taxes, Disclosure of information, Filing requirements.
Amendments to the Regulations
Accordingly, 26 CFR part 301 is proposed to be amended as follows:
PART 301--PROCEDURE AND ADMINISTRATION
Paragraph 1. The authority citation for part 301 continues to read
in part as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. In Sec. 301.7611-1, each entry in the table, undesignated
paragraphs in the ``Old Paragraph'' column are designated as new
paragraphs in the ``New Paragraph'' column to read as follows:
------------------------------------------------------------------------
Old paragraph New paragraph
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Sec. 301.7611-1 A-5 first undesignated Sec. 301.7611-1 A-5
paragraph. paragraph (a).
Sec. 301.7611-1 A-5 second undesignated Sec. 301.7611-1 A-5
paragraph. paragraph (b).
Sec. 301.7611-1 A-6 first undesignated Sec. 301.7611-1 A-6
paragraph. paragraph (a).
Sec. 301.7611-1 A-9 first undesignated Sec. 301.7611-1 A-9
paragraph. paragraph (a).
Sec. 301.7611-1 A-9 second undesignated Sec. 301.7611-1 A-9
paragraph. paragraph (b).
Sec. 301.7611-1 A-10 first undesignated Sec. 301.7611-1 A-10
paragraph. paragraph (a).
Sec. 301.7611-1 A-10 second undesignated Sec. 301.7611-1 A-10
paragraph. paragraph (b).
Sec. 301.7611-1 A-10 third undesignated Sec. 301.7611-1 A-10
paragraph. paragraph (c).
Sec. 301.7611-1 A-10 fourth undesignated Sec. 301.7611-1 A-10
paragraph. paragraph (d).
Sec. 301.7611-1 A-10 fifth undesignated Sec. 301.7611-1 A-10
paragraph. paragraph (e).
Sec. 301.7611-1 A-11 first undesignated Sec. 301.7611-1 A-11
paragraph. paragraph (a).
Sec. 301.7611-1 A-11 second undesignated Sec. 301.7611-1 A-11
paragraph. paragraph (b).
Sec. 301.7611-1 A-11 third undesignated Sec. 301.7611-1 A-11
paragraph. paragraph (c).
Sec. 301.7611-1 A-13 first undesignated Sec. 301.7611-1 A-13
paragraph. paragraph (a).
Sec. 301.7611-1 A-13a first undesignated Sec. 301.7611-1 A-13a
paragraph. paragraph (a).
Sec. 301.7611-1 A-14 first undesignated Sec. 301.7611-1 A-14
paragraph. paragraph (a).
Sec. 301.7611-1 A-14 second undesignated Sec. 301.7611-1 A-14
paragraph. paragraph (b).
Sec. 301.7611-1 A-15 first undesignated Sec. 301.7611-1 A-15
paragraph. paragraph (a).
Sec. 301.7611-1 A-15 second undesignated Sec. 301.7611-1 A-15
paragraph. paragraph (b).
Sec. 301.7611-1 A-15 third undesignated Sec. 301.7611-1 A-15
paragraph. paragraph (c).
Sec. 301.7611-1 A-15 fourth undesignated Sec. 301.7611-1 A-15
paragraph. paragraph (d).
Sec. 301.7611-1 A-15 fifth undesignated Sec. 301.7611-1 A-15
paragraph. paragraph (e).
Sec. 301.7611-1 A-15 sixth undesignated Sec. 301.7611-1 A-15
paragraph. paragraph (f).
Sec. 301.7611-1 A-15 seventh Sec. 301.7611-1 A-15
undesignated paragraph. paragraph (g).
Sec. 301.7611-1 A-16 first undesignated Sec. 301.7611-1 A-16
paragraph. paragraph (a).
Sec. 301.7611-1 A-17 first undesignated Sec. 301.7611-1 A-17
paragraph. paragraph (a).
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[[Page 39007]]
Sec. 301.7611-1 [Amended]
Par. 3. For each section listed in the table, remove the language
in the ``Remove'' column and add in its place the language in the
``Add'' column as set forth below:
------------------------------------------------------------------------
Section Remove Add
------------------------------------------------------------------------
Sec. 301.7611-1 A-1 first appropriate Regional Director, Exempt
sentence. Commissioner (or Organizations.
higher Treasury
official).
Sec. 301.7611-1 A-7 first appropriate Internal Director, Exempt
sentence. Revenue Service Organizations.
Regional
Commissioner.
Sec. 301.7611-1 A-9 first appropriate Regional Director, Exempt
sentence. Commissioner. Organizations.
Sec. 301.7611-1 A-10 first appropriate Regional Division Counsel/
sentence. Counsel. Associate Chief
Counsel, Tax Exempt
and Government
Entities.
Sec. 301.7611-1 A-10 At the time the Before the notice of
paragraph (b) first notice of examination (second
sentence. examination (second notice) is provided
notice) is provided to the church, a
to the church, a copy of the same
copy of the same notice will be
notice will be provided to the
provided to the Division Counsel/
appropriate Associate Chief
Regional Counsel. Counsel, Tax Exempt
and Government
Entities.
Sec. 301.7611-1 A-10 Regional Counsel.... Division Counsel/
paragraph (b) second Associate Chief
sentence. Counsel, Tax Exempt
and Government
Entities.
Sec. 301.7611-1 A-11 Regional Counsel.... Division Counsel/
paragraph (c) first, second Associate Chief
and third sentences. Counsel, Tax Exempt
and Government
Entities.
Sec. 301.7611-1 A-15 appropriate Regional Director, Exempt
paragraph (c) first and Commissioner. Organizations.
third sentences.
Sec. 301.7611-1 A-15 Regional Director, Exempt
paragraph (c) second Commissioner. Organizations.
sentence.
Sec. 301.7611-1 A-16 first Assistant Commissioner, Tax
sentence. Commissioner Exempt and
(Employee Plans and Government Entities
Exempt or the Deputy
Organizations). Commissioner, Tax
Exempt and
Government
Entities.
Sec. 301.7611-1 A-16 Assistant approval of the
second sentence. Commissioner's Commissioner, Tax
approval. Exempt and
Government Entities
or the Deputy
Commissioner, Tax
Exempt and
Government
Entities.
Sec. 301.7611-1 A-16 Assistant Commissioner, Tax
paragraph (a) second Commissioner Exempt and
sentence. (Employee Plans and Government Entities
Exempt or the Deputy
Organizations). Commissioner, Tax
Exempt and
Government
Entities.
Sec. 301.7611-1 A-17 first Regional Director, Exempt
sentence. Commissioner. Organizations.
Sec. 301.7611-1 A-17 Regional Director, Exempt
paragraph(a) third sentence. Commissioner. Organizations.
Sec. 301.7611-1 A-17 appropriate Regional belief of the
paragraph (a) fourth Commissioner's Director, Exempt
sentence. belief. Organizations.
------------------------------------------------------------------------
Linda E. Stiff,
Deputy Commissioner for Services and Enforcement.
[FR Doc. E9-18659 Filed 7-31-09; 4:15 pm]
BILLING CODE 4830-01-P