a-04-29.pdf

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Part IV - Items of General Interest

Application of Municipal Circular 230 to Municipal Bond Opinions

Announcement 2004-29

On December 30, 2003, the Treasury Department published a notice of proposed
rulemaking in the Federal Register (REG-122379-02) proposing modifications to rules
governing practice before the Internal Revenue Service (Circular 230). Section 10.35
(Requirements for certain tax shelter opinions) of the proposed regulations is proposed
to be effective for opinions rendered after the date that final regulations are published in
the Federal Register.

The Treasury Department and the IRS are continuing to consider all comments
on the proposed regulations. In the meantime, the Treasury Department and the IRS
announce that, in final regulations, the definition of tax shelter opinion for purposes of
section 10.35 will not apply, if at all, to written advice concerning municipal bonds
rendered less than 120 days after the publication of such final regulations in the Federal
Register. Conforming changes, if necessary, will be made to section 10.36(b).

The principal author of this notice is Heather L. Dostaler of the Office of the
Associate Chief Counsel (Procedure and Administration), Administrative Provisions and
Judicial Practice Division, but other personnel from the IRS and Treasury Department
participated in its development. For further information regarding this notice, contact
Heather L. Dostaler at (202) 622-4940 (not a toll-free number).