NOL

Future After having focused on past events and activities, a look to the future is in order. The activities leading up to the Notice 2008-83 are well known and documented. Some of the reasoning behind the issuance of the Notice are known, but it is unlikely all of the reasoning will ever be fully known.

Court Support While the question of the Service’s authority and ability to issue Notices that change the interpretation of the Statute, taxpayers have the ability to rely on this Notice during the time period between its release and Congress’s response.

Congressional Response P.L. 111-5 Apart from the letters from various Congressional members to the Treasury and the Inspector General, there seemed to be no official response from Congress to the Notice.

Treasury’s Response In December, the Treasury formerly responded to Schumer’s letter. Eric Solomon, an Assistant Secretary of the Treasury, in a written response to Senator Schumer, attempted to address each of Schumer’s concerns.