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two previous sets of proposed regulations which the Commissioner
issued to define the word "activity". With respect to both sets
of proposed regulations, the Commissioner issued a notice of
proposed rulemaking that set forth (either in the document or by
cross-reference to another document) the substance of the
proposed regulations, including the subjects, issues, and rules
involved, and invited written comments and requests for a public
hearing.3 54 Fed. Reg. 20606 (May 12, 1989) (first set of
proposed regulations); 57 Fed. Reg. 20802 (May 15, 1992) (second
set of proposed regulations). The notice of proposed rulemaking
on the first set of proposed regulations stated that a public
hearing would be held, upon the request of any commentator, at a
time and place to be published in the Federal Register. 54 Fed.
Reg. 20606-20607. The notice of proposed rulemaking on the
second set of proposed regulations referenced a separate document
that stated that the Commissioner was holding a hearing on the
proposed regulations on July 24, 1992, at 1:30 p.m., in room
7400, Internal Revenue Service Building, 1111 Constitution
Avenue, N.W., Washington, D.C. 57 Fed. Reg. 20805. On June 15,
1992, the Commissioner announced that the hearing had been
3 When the Commissioner issued the notice of proposed
rulemaking on the first set of proposed regulations, he also
issued temporary regulations defining the word "activity". See
sec. 1.469-4T, Temporary Income Tax Regs., 54 Fed. Reg. 20527,
20542 (May 12, 1989). The text of the temporary regulations
served as the text of the proposed regulations. 54 Fed. Reg.
20527, 20606.
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