n-05-32.pdf

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Part III - Administrative, Procedural, and Miscellaneous

Interim Rules and Procedures for Partnerships Under Section 833 of the American Jobs
Creation Act of 2004

Notice 2005-32

Section 1. PURPOSE
The American Jobs Creation Act of 2004, P.L. 108-357, 118 Stat. 1418 (the Act),
was enacted on October 22, 2004. The Treasury Department and the Internal Revenue
Service intend to issue regulations implementing §§ 833 and 834 of the Act, which
amended §§ 704, 734, 743, and 6031 of the Internal Revenue Code. This notice
provides interim procedures for partnerships and their partners to comply with the
mandatory basis provisions of §§ 734 and 743, as amended by the Act. This notice
also provides interim procedures for electing investment partnerships (EIPs) and their
partners to comply with §§ 743(e) and 6031(f), as provided in § 833(b) of the Act.
Section 2. BACKGROUND
Section 833(c) of the Act requires basis adjustments to be made following certain
distributions from partnerships for which no § 754 election is in effect. As amended by
§ 833(c) of the Act, § 734(a) and (b) requires a partnership to reduce its basis in
partnership property upon a distribution of partnership property after October 22, 2004 if
there is a “substantial basis reduction.” Under § 734(d), there is a substantial basis
reduction if a downward adjustment of more than $250,000 would be made to the basis

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of partnership assets if a section 754 election were in effect at the time of the
distribution. EIPs, like other partnerships, are required to make any basis adjustments
that are required under § 734 upon the distribution of partnership property.
Section 833(b) of the Act requires basis adjustments to be made following
certain transfers of interests in partnerships for which no § 754 election is in effect. As
amended by § 833(b) of the Act, § 743(a) and (b) requires a partnership to reduce the
basis of partnership property upon a transfer after October 22, 2004 of an interest in the
partnership by sale or exchange or upon the death of a partner, if, at the time of the
relevant transfer, the partnership has a “substantial built-in loss.” Section 743(d)(1)
provides that, for purposes of § 743, a partnership has a substantial built-in loss with
respect to a transfer of a partnership interest if the partnership’s adjusted basis in the
partnership’s property exceeds by more than $250,000 the fair market value of the
property.
Section 833(b) of the Act also provides that an EIP is not treated as having a
substantial built-in loss, and thus is not required to make basis adjustments to
partnership property, with respect to any transfer of a partnership interest occurring
while an election to be treated as an EIP is in effect. In lieu of the partnership basis
adjustments otherwise required under § 743, a partner-level loss disallowance rule
applies. Section 743(e)(2) provides that, in the case of a transfer of an interest in an
EIP, the transferee partner’s distributive share of the losses, without regard to gains,
from the sale or exchange of partnership property is not allowed, except to the extent
that it is established that the losses exceed the loss recognized on the transfer of the

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partnership interest by the transferor partner (or by a prior transferor to the extent not
fully offset by a prior disallowance under § 743(e)(2)). Under § 743(e)(3), losses
disallowed under this rule do not decrease the transferee partner’s basis in its
partnership interest. Section 743(e) is to be applied without regard to any termination of
the partnership under § 708(b)(1)(B). In the case of a basis reduction to property
distributed to the transferee partner in a nonliquidating distribution, § 743(e)(5) provides
that the amount of the transferor’s recognized loss taken into account under § 743(e)(2)
is reduced by the amount of the basis reduction under § 732(a)(2).
Section 743(e)(6), as added by the Act, provides that an EIP means any
partnership if (A) the partnership makes an election to have § 743(e) apply, (B) the
partnership would be an investment company under section 3(a)(1)(A) of the Investment
Company Act of 1940 but for an exemption under paragraph (1) or (7) of section 3(c) of
such Act, (C) the partnership has never been engaged in a trade or business,
(D) substantially all of the assets of the partnership are held for investment, (E) at least
95 percent of the assets contributed to the partnership consist of money, (F) no assets
contributed to the partnership had an adjusted basis in excess of fair market value at
the time of contribution, (G) all partnership interests of the partnership are issued by the
partnership pursuant to a private offering before the date which is 24 months after the
date of the first capital contribution to the partnership, (H) the partnership agreement of
the partnership has substantive restrictions on each partner’s ability to cause a
redemption of the partner’s interest, and (I) the partnership agreement of the
partnership provides for a term that is not in excess of 15 years. However, in the case

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of an EIP which is in existence on June 4, 2004, § 743(e)(6)(H) does not apply to the
partnership, and § 743(e)(6)(I) is applied by substituting “20 years” for “15 years”.
Section 743(e)(7) provides that the Secretary shall prescribe regulations as may
be appropriate to carry out the purposes of § 743(e), including regulations for applying
§ 743(e) to tiered partnerships.
Section 6031(f) provides that in the case of any EIP, the information required
under § 6031(b) to be furnished to any partner to whom § 743(e)(2) applies shall include
information as is necessary to enable the partner to compute the amount of losses
disallowed under § 743(e).
Section 3. INTERIM PROCEDURES RELATING TO BASIS ADJUSTMENTS
REQUIRED UNDER § 833 OF THE ACT
Sections 1.734-1(d) and 1.743-1(k) of the Income Tax Regulations require
partnerships and partners to provide certain statements following distributions with
respect to partnership interests, and transfers of partnership interests, in partnerships
for which an election under § 754 is in effect. The Treasury Department and the
Service intend to amend the regulations under §§ 734 and 743 to require partnerships
and partners to provide statements, similar to those contained in §§ 1.734-1(d) and
1.743-1(k), following any distributions and transfers that trigger basis adjustments under
§ 833(b) or (c) of the Act.
Until further guidance is provided, partnerships that are required to reduce the
bases of partnership properties under § 833(c) of the Act must comply with § 1.734-1(d)
as if an election under § 754 were in effect at the time of the relevant distribution.

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Partnerships that are required to reduce the bases of partnership properties under
§ 833(b) of the Act must comply with § 1.743-1(k)(1) as if an election under § 754 were
in effect at the time of the relevant transfer. The transferee of an interest in a
partnership that is required to reduce the bases of partnership properties under § 833(b)
of the Act must comply with § 1.743-1(k)(2), within the time prescribed under § 1.743-
1(k)(2) (or, if later, by May 19, 2005), as if an election under § 754 were in effect at the
time of the relevant transfer. In addition, partnerships that are required to reduce the
bases of partnership properties under § 833(b) of the Act may rely on, and must comply
with, § 1.743-1(k)(3), (4), and (5) as if an election under § 754 were in effect at the time
of the relevant transfer.
Section 4. INTERIM PROCEDURES FOR EIP ELECTION
Until further guidance is provided, a partnership must make the election to be
treated as an EIP by attaching a written statement to an original or amended
partnership return for the taxable year for which the election is effective. The statement
must (i) set forth the name, address, and tax identification number of the partnership
making the election, (ii) contain a representation that the partnership is eligible to make
the election under § 743(e)(6)(A), and (iii) contain a declaration that the partnership
elects under § 743(e) to be treated as an EIP. If a partnership has filed a return with
respect to a taxable year that includes October 22, 2004, and desires to elect to be
treated as an EIP for transfers after October 22, 2004, but did not attach a statement
satisfying the requirements of this paragraph, then the partnership must file an
amended return with a statement satisfying those requirements.

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For the election to be valid, the original or amended return must be filed not later
than six months after the time prescribed by § 1.6031(a)-1(e) of the Procedure and
Administration Regulations (excluding extensions thereof) for filing the return for the
taxable year for which the election is effective. Once an election is made, it is effective
for all succeeding taxable years, unless terminated or revoked, as described below. In
the case of an election filed for the partnership’s taxable year that includes October 22,
2004, the election is effective for all transfers occurring after October 22, 2004. In all
other cases, the election is effective for all transfers during the partnership’s taxable
year for which the election is effective. A partnership that has an election under § 754
in effect is ineligible to make an election to be treated as an EIP. If the partnership is
not otherwise required to file a partnership return, the election to be an EIP shall be
made in accordance with the rules of §1.6031(a)-1(b)(5).
The election to be treated as an EIP shall terminate if the partnership fails to
meet the definition of an EIP. In this case, the partnership will become subject to the
mandatory basis adjustment rules with respect to the first transfer of a partnership
interest that occurs after the partnership ceases to meet the definition of an EIP and to
each subsequent transfer. An EIP also may terminate its election to be treated as an
EIP without the consent of the Commissioner by filing an election under § 754. In this
case, the partnership will become subject to the mandatory basis adjustment rules with
respect to the first transfer of a partnership interest that occurs after the effective date of
the election under § 754. In all other cases, except as provided in future guidance, a
partnership having an election in effect to be treated as an EIP may revoke the election

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only with the consent of the Commissioner. The application for consent to revoke the
election must be submitted to the Service in the form of a letter ruling request. If an
election to be treated as an EIP is terminated, any losses that are subsequently
allocated to a partner to whom a partnership interest was transferred while the EIP
election was in effect shall remain subject to disallowance under § 743(e)(2).
Section 5. INTERIM REPORTING REQUIREMENTS
A. Transferor Partner Required to Provide Information to Transferee Partner

and Partnership

Until further guidance is provided, if a partnership interest in an EIP is transferred
in a sale or exchange or upon the death of a partner, the transferor (or, in the case of a
partner who dies, the partner’s executor, personal representative, or other successor in
interest) must notify the transferee and the EIP in writing. The notice must be provided
within 30 days after the date on which the transferor partner (or the executor, personal
representative or other successor in interest) receives Schedule K-1 from the EIP for
the partnership’s taxable year in which the transfer occurred (or, if later, by May 19,
2005). The notice must be signed under penalties of perjury and must include (i) the
name, address, and tax identification number of the transferor, (ii) the name, address,
and tax identification number of the transferee (if ascertainable), (iii) the name of the
partnership, (iv) the date of the transfer (and, in the case of the death of a partner, the
date of the death of the partner), (v) the amount of loss, if any, recognized by the
transferor on the transfer of the interest, together with the computation of the loss,
(vi) the amount of losses, if any, recognized by any prior transferors to the extent the

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losses were subject to disallowance under § 743(e)(2) in the hands of a prior transferee
and have not been offset by prior loss disallowances under § 743(e)(2), and (vii) any
other information necessary for the transferee to compute the amount of loss disallowed
under § 743(e)(2). If the transferor is a nominee (within the meaning of §1.6031(c)-1T),
then the nominee, and not the beneficial owner of the transferred interest, must supply
the information to the transferee of the interest and to the EIP.
The transferee and the EIP shall retain the notice described in this Section 5.A as
long as the contents thereof may become material in the administration of any internal
revenue law.
B. Distributive Shares of Partnership Items of EIP

Because the amount of losses disallowed under § 743(e) is determined without
regard to gains, an EIP is required to separately state on Schedule K and K-1 of the
partnership’s return (Form 1065) all allocations of losses to all of its partners under
§ 1.702-1(a)(8)(ii), including losses that, in the absence of § 743(e), could be netted
against gains at the partnership level. If a partnership has filed a return with respect to
a taxable year that includes October 22, 2004 in which gain and losses were not
separately stated, the EIP must, prior to the expiration of the period for making an EIP
election for that year, file an amended return in which gains and losses are separately
stated. If a partnership’s election to be treated as an EIP is terminated, the partnership
must continue to state such gains and losses separately in future returns relating to any
period during which the partnership has one or more transferee partners that are
subject to § 743(e)(2). If an EIP is not required to file a partnership return, the

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transferee of a partnership interest in the EIP may be required to provide to the Service
similar information regarding the partner’s distributive share of gross gains and losses of
the EIP under § 1.6031(a)-1(b)(4).
C. Partnership Required to Provide Annual Statements to Partners

Until further guidance is provided, an EIP must provide the following statement to
all of its partners. The statement shall be attached to every statement provided to a
partner or nominee under § 6031(b) that is issued with respect to any taxable year for
which an election to be treated as an EIP is in effect (whether or not the election is in
effect for the entire taxable year). If an EIP has provided statements under § 6031(b)
with respect to a taxable year that includes October 22, 2004, and elects to be treated
as an EIP for that year, but did not include the statements required by this section 5.C.,
then the EIP must provide amended statements under § 6031(b), prior to the expiration
of the period for making an EIP election for that year, which do include the required
statements.
Notice of Election. This partnership has elected to be treated as an
electing investment partnership under section 743(e) of the Internal
Revenue Code.

Information for Transferors. If you transfer an interest in this
partnership to another person, Notice 2005-32, 2005-16 I.R.B. __,
provides that you must, within 30 days after receiving a Schedule K-1
from this partnership for the taxable year that includes the date of
the transfer, provide the transferee with certain information,
including the amount, if any, of loss that you recognized on the
transfer of the partnership interest, and the amount of losses, if any,
recognized by prior transferors with respect to the same interest.
See Notice 2005-32 for more information.

Information for Transferees. If an interest in this partnership is
transferred to you, section 743(e)(2) requires that you reduce your

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distributive share of losses from this partnership, determined
without regard to gains from this partnership, to the extent of any
losses recognized by the transferor partner when that partner
transferred the partnership interest to you (and to the extent of other
losses recognized on prior transfers of the same partnership interest
that have not been offset by prior loss disallowances). Each year,
you must reduce your share of losses as reported to you by this
partnership by the amount of any loss recognized by the transferor
partner (or any prior transferor to the extent not already offset by
prior loss disallowances) until you have reduced your share of
partnership losses by the total amount of losses required to be
disallowed. If the transferor partner, or its legal representative in the
case of a transfer by death, fails to provide you with the required
statement, you must treat all losses allocated from the EIP as
disallowed under § 743(e)(2) unless you obtain, from the EIP or
otherwise, the information necessary to determine the proper
amount of losses disallowed under § 743(e)(2). See Notice 2005-32
for more information.

D. Effects of Failure to Notify Transferee Partner

If the transferor partner, or its legal representative in the case of a transfer by
death, fails to provide the transferee partner with the statement required by Section 5.A
of this notice with respect to a transfer of an interest in the EIP, the transferee partner
must treat all losses allocated from the EIP as disallowed under § 743(e)(2) unless the
transferee partner obtains, from the EIP or otherwise, the information necessary to
determine the proper amount of losses disallowed under § 743(e)(2). If the transferee
does not have the information necessary to determine the proper amount of losses
disallowed under § 743(e)(2), but does have information sufficient to determine the
maximum amount of losses that could be disallowed, then the transferee may treat the
amount of losses disallowed under § 743(e)(2) as being equal to that maximum amount.
For example, if the transferee is able to ascertain the adjusted basis that a prior
transferor had in its partnership interest, but is not able to ascertain the amount realized

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by that transferor, the transferee may assume, for purposes of calculating the amount of
losses disallowed under § 743(e)(2), that the sales price when the prior transferor sold
its interest was zero. If, following the filing of a return pursuant to the previous
sentence, the transferor partner or the EIP provides the required information to the
transferee partner, the transferee partner should make appropriate adjustments in an
amended return for the year of the loss allocation from the EIP in accordance with
§ 6511 or other applicable rules.
Section 6. CHARACTER OF LOSSES DISALLOWED UNDER § 743(e)(2)
Until further guidance is issued, if an EIP allocates losses with a different
character from the sale or exchange of property to the transferee (such as ordinary or
§ 1231 losses and capital losses) and the losses allocated to that partner are limited by
§ 743(e)(2), then a proportionate amount of the losses disallowed under § 743(e)(2)
shall consist of each loss of a separate character that is allocated to the transferee
partner.
Section 7. TRADES OR BUSINESSES OF LOWER-TIER PARTNERSHIPS
As noted above, a partnership that is engaged in a trade or business, or that has
previously engaged in a trade or business, is not eligible to elect to be treated as an
EIP. The Treasury Department and the Service are studying the conditions under which
a partnership (“upper-tier partnership”) that holds interests in one or more partnerships
(“lower-tier partnerships”) that are engaged in a trade or business should be treated as
engaged in a trade or business.

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Until further guidance is issued, an upper-tier partnership will not be treated as
engaged in the trade or business of a lower-tier partnership if, at all times during the
period in which the upper-tier partnership owns an interest in the lower-tier partnership,
the adjusted basis of its interest in the lower-tier partnership is less than 25 percent of
the total capital that is required to be contributed to the upper-tier partnership by its
partners during the entire term of the upper-tier partnership. This notice does not
address the situation in which the upper-tier partnership’s adjusted basis in its lower-tier
partnership interest is, at any time, 25 percent or more of the total capital that is
required to be contributed to the upper-tier partnership by its partners during the entire
term of the upper-tier partnership.
The Treasury Department and the Service specifically request comments on
rules that may be appropriate for future guidance. Factors that may be relevant in
future guidance in determining whether an upper-tier partnership is treated as engaged
in a trade or business that is conducted by a lower-tier partnership include (i) the
relative amount of the upper-tier partnership’s investment in the lower-tier partnership
as compared to the total capital that is required to be contributed to the upper-tier
partnership by its partners during the entire term of the upper-tier partnership, (ii) the
degree to which the upper-tier partnership participates in the management of the lower-
tier partnership’s activities, and (iii) the motivations for the formation of the upper-tier
partnership in making the investments in the lower-tier partnership.
The Treasury Department and the Service may adopt rules in future guidance
that are more restrictive than the safe harbor provided for above. If a partnership that

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qualifies as an EIP under the safe harbor does not qualify as an EIP under future
guidance, the partnership’s election to be treated as an EIP will terminate for transfers
occurring on or after the date on which such future guidance becomes effective.
Section 8. EXAMPLES

A. Transfer of Partnership Interest

PRS
is a partnership which does not have an election under § 754 in effect. PRS
has no liabilities. The fair market value of PRS’s assets is $4 million and the adjusted
basis of PRS
’s assets is $4.3 million. Under § 743(d), PRS has a substantial built-in
loss because the adjusted basis of the partnership property exceeds the fair market
value of the partnership property by more than $250,000. A, a partner of PRS, sells a
25 percent partnership interest in PRS
to B for its fair market value of $1 million. Under
§ 743(b), an adjustment is required to the adjusted basis of PRS
’s assets with respect
to B. Under Section 3 of this notice, B must provide the written notice described in
§ 1.743-1(k)(2) to PRS within 30 days after the sale, and PRS must attach the
statement described in § 1.743-1(k)(1) to the partnership return for the year of the
transfer.

B. Distribution of Partnership Property

A and B each contribute $2.5 million and C contributes $5 million to a newly
formed partnership, PRS, which does not have an election under § 754 in effect. PRS
has no liabilities. PRS
purchases LMN stock for $3 million and XYZ stock for $7 million.
The value of each stock declines to $1 million. PRS distributes LMN stock to C in
complete liquidation of C’s interest in PRS. Under § 732(b), the basis of LMN stock in
C’s hands is $5 million and C would recognize a loss of $4 million if the LMN stock were
sold for $1 million. There is a substantial basis reduction within the meaning of
§ 734(d), because the $2 million increase in the adjusted basis of LMN
stock (described
in § 734(b)(2)(B)) is greater than $250,000. Under § 734(b), PRS is required to
decrease the basis of XYZ
stock by $2 million (the amount by which the basis of LMN
stock was increased), leaving a basis of $5 million remaining in the XYZ stock. Under
Section 3 of this notice, PRS
must attach the statement described in § 1.734-1(d) to the
partnership return for the year of the distribution.

C. EIP

(i) PRS
is a domestic partnership with a calendar year taxable year that desires
to elect to be treated as an EIP for 2004 and all succeeding taxable years. PRS
and all
of its partners have a calendar year taxable year. PRS
has no liabilities. Other than the
making of the election, PRS meets all other requirements to be an EIP under

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§ 743(e)(6). PRS elects to be treated as an EIP by attaching a statement to its income
tax return for 2004 in accordance with Section 4 of this notice.

(ii) Between October 22 and December 31, 2004, the only transfer of a
partnership interest in PRS
occurred on November 30, 2004, when A transferred a 10
percent partnership interest to C
. The purchase price for the 10 percent partnership
interest was $3,000,000. A’s adjusted basis in A’s partnership interest on December
31, 2003 was $3,000,000. In 2004, the partnership’s only items of income, gain, loss,
and deduction are $3 million of long-term capital gain and $2 million of long-term capital
loss. Because PRS
has elected to be treated as an EIP, PRS must separately state this
gain and loss on its return in accordance with Section 5.B of this notice.

(iii) If A
had remained a partner for the entire year, A’s distributive share of the
partnership’s items would have been $300,000 of long-term capital gain and $200,000
of long-term capital loss. Assume that under § 706, A’s distributive share of these items
are properly determined to be 334/365 of each of these amounts, or $274,521 of long-
term capital gain and $183,014 of long-term capital loss, and that C’s distributive shares
of these items are properly determined to be 31/365 of each of these amounts, or
$25,479 of long-term capital gain and $16,986 of long-term capital loss.

(iv) PRS must provide a statement to all of its partners in accordance with
Section 5.C of this notice. The statement must be attached to each partner’s Schedule
K-1 for PRS
’s taxable year ending December 31, 2004. Assume that A receives A’s
Schedule K-1 on March 12, 2005. Within 30 days after receiving this Schedule K-1, A
must provide statements to C and EIP as described in Section 5.A of this notice.

(v) The adjusted basis in A
’s partnership interest on November 30, 2004,
$3,091,507, equals A’s adjusted basis on December 31, 2003, $3,000,000, plus A’s
distributive share of partnership gain in 2004, $274,521, less A’s distributive share of
partnership loss in 2004, $183,014. The amount of loss recognized by A on the sale of
A’s partnership interest is $91,507, which equals the adjusted basis in A
’s partnership
interest on the date of the sale, $3,091,507, less the amount realized by A, $3,000,000.
Thus, the first $91,507 of gross loss allocated to C
is disallowed under §743(e)(2). The
entire amount of C
’s long-term capital loss in 2004, $16,986, is disallowed under
§743(e)(2). The first $74,521 of any gross loss allocated to C in future years will also be
disallowed under §743(e)(2), regardless of whether PRS is an EIP in those future years.

(vi) C
’s adjusted basis as of December 31, 2004 is $3,025,479, the sum of C’s
purchase price paid for A’s interest, $3,000,000, plus the distributive share of gain
allocated to C
, $25,479. Under § 743(e)(3), the $16,986 loss allocated to C, but
disallowed under §743(e)(2), does not reduce the basis of C
’s partnership interest.

Section 9. REQUEST FOR COMMENTS

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The Treasury Department and the Service intend to issue further guidance
implementing §§ 833 and 834 of the Act, including guidance addressing the application
of these provisions to tiered partnership structures. Comments are requested
concerning the scope and content of this guidance. In particular, comments are
requested concerning the application of these provisions to tiered partnerships and the
reporting obligations that should be imposed on tiered partnerships and their partners.
As stated earlier, comments are also requested on the rules provided in Section 7 of
this Notice. Comments should be submitted in writing on or before July 19, 2005 and
should include a reference to Notice 2005-32. Comments may be submitted to
CC:PA:LPD:PR (Notice 2005-32), Room 5226, Internal Revenue Service, PO box 7604,
Ben Franklin Station, Washington, DC 20044. Alternatively, comments may be
submitted electronically via the following e-mail address:
Notice.Comments@irscounsel.treas.gov
. Please include “Notice 2005-32” in the
subject line of any electronic communications.
Submissions may be hand delivered Monday through Friday between the hours
of 8 a.m. and 5 p.m. to CC:PA:LPD:PR (Notice 2005-32), Courier’s Desk, Internal
Revenue Service, 1111 Constitution Avenue, NW, Washington, DC 20224.
PAPERWORK REDUCTION ACT
The collections of information contained in this notice have been reviewed and
approved by the Office of Management and Budget in accordance with the Paperwork
Reduction Act (44 U.S.C. 3507) under control number 1545-1939.

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An agency may not conduct or sponsor, and a person is not required to respond
to, a collection of information unless the collection of information displays a valid OMB
control number.
The collections of information in this notice are in Sections 3, 4, and 5. This
information is required, and will be used, to assure compliance with the new provisions
of the American Jobs Creation Act of 2004. The collections of information are required
to obtain a benefit or are mandatory. The likely respondents are individuals and
businesses or other for-profit institutions.
The estimated total annual reporting burden and/or recordkeeping burden is
552,100 hours.
The estimated annual average burden per respondent/recordkeeper varies from
is 0.05 hours to 3 hours, depending on individual circumstances, with an estimated
average of 2.07 hours.
The estimated number of respondents and/or recordkeepers is 266,400.
The estimated annual frequency of responses (used for reporting requirements
only) is various.
Books or records relating to a collection of information must be retained as long
as their contents may become material in the administration of any internal revenue law.
Generally, tax returns and tax return information are confidential, as required by 26
U.S.C. 6103.
DRAFTING INFORMATION

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The principal author of this notice is Sean I. Kahng of the Office of Associate
Chief Counsel (Passthroughs & Special Industries). However, other personnel from the
Treasury Department and the Service participated in its development. For further
information regarding this notice, contact Mr. Kahng at (202) 622-3050 (not a toll-free
call).