These comments are presented on behalf of the Section of Taxation of the State Bar of Texas. The principal drafters of these comments were M. Todd Welty, Robert D Probasco. Brandy N .. Williams, and Stephen A.. Beck.. The Committee on Government Submissions ("COGS") of the Section of Taxation of the State Bar of Texas has approved these comments. Patrick O'Daniel is the Chair of COGS and the other members of COGS include Paul Asofky, Stanley Blend, Vester Hughes, Emily Parker and Steve Salch.

Although many of the people who participated in preparing, reviewing and approving these comments have clients who will be affected by the federal tax law principles addressed by these comments and frequently advise clients on the application of such principles, none of the participants (or the firms or organizations to which such participants belong) has been engaged by a client to make a government submission with respect to, or otherwise to influence the development or outcome of, the subject matter of these comments.

The following comments are submitted in response to a request for comments made by the Department of the Treasury ("Treasury") and the Internal Revenue Service (the "Service") in the notices of proposed rulemaking issued on November 2, 2006, regarding sections 6011, 6111 and 6112 of the Internal Revenue Code (the "Code"). Treasury and the Service requested comments by January 31, 2007.