AICPA Asks IRS to Withdraw Proposed Section 752 Regs on Disregarded Entities 

    Published February 01, 2006

    The Honorable Eric Solomon

    Acting Assistant Secretary (Tax Policy)

    U.S. Department of Treasury


    1500 Pennsylvania Avenue, N.W.


    Washington, DC20220




    The Honorable Mark W. Everson


    Internal Revenue Service


    1111 Constitution Avenue, N.W.


    Washington, D.C.20224




    Re: Comments on REG-128767-04, Treatment of Disregarded Entities Under Section 752








    The American Institute of Certified Public Accountants (AICPA) offers the following comments on the above-mentioned proposed regulation project. These comments were drafted by the Partnership Taxation Technical Resource Panel and approved by the Tax Executive Committee.




    We believe the Proposed Regulations create (1) unnecessary complexity for taxpayers by providing two separate regimes for determining the allocation of partnership liabilities; (2) uncertainty for taxpayers by allowing a Disregarded Entity to potentially impact the allocation of partnership liabilities; and (3) significant and unnecessary compliance burdens for taxpayers the goals of which can better be addressed through application and/or amplification of the existing Section 752 Anti-abuse Rule. As a result, we recommend that the Proposed Regulations be withdrawn.




    If you or your staff have any questions, please contact me at; Debbie A. Fields, Chair of the AICPA Partnership Taxation Technical Resource Panel at; or Marc A. Hyman, AICPA Technical Manager at








    Thomas J. Purcell, Chair

    Tax Executive Committee

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