Next week is the deadline for submitting comments regarding the controversial IRC Section 2704 regulations. The due date is November 2, and the IRS website has a tally of over 4,000 comments so far. Yes, this is a lot, but it’s important that everyone put in his or her two cents because the more the comments, the less likely the Treasury will be able to finalize the proposed regs as written.

Wide array: While a lot of the comments are long on emotion and light on substance, others are very comprehensive. For example, The S Corporation Association submitted formal comments (available here) that do a great job at laying out the problematic issues. Also, the group has spent the month of October on the Hill building support for the two bills introduced in the House and the Senate to block the proposed regs. “With Congress coming back in mid-November, the challenge will be to build sufficient support on this issue to compel the House and Senate to take action before the end of the year,” the association says in a blog post.

The American Society of Appraisers has released talking points and a template comment letter (a prior issue of BVWire with the links is here). The ASA has also posted a video in which valuation expert Bruce Johnson (Munroe, Park & Johnson) gives a succinct explanation of the proposed regs. Johnson is part of the ASA task force assembled to study the regs and submit formal comments.

Voices still need to be heard on this matter, and you can submit comments by clicking here. A public hearing will be held at the IRS on December 1, and BVWire will be there.