These comments are presented on behalf of the Section of Taxation of the State Bar of Texas. The principal drafters of these comments were Robert D. Probasco, Mark Horowitz and Bruce Bemstien. Additional contributors were Val J. Albright, David E. Colmenero, Joel N. Crouch, Brian Dethrow, Kenneth M. Horwitz and Ronald D. Kerridge. The Committee on Government Submissions (COGS) of the Section of Taxation of the State Bar of Texas has approved these comments. Daniel G. Baucum is the Chair of COGS, and Emily Parker and Daniel J. Micciche reviewed the comments on behalf of COGS.

The following comments are submitted in response to a request for comments made by the Service in Announcements 2010-9 and 2010-17, issued on January 26, 2010 and March 5, 2010, respectively, regarding a proposal to require certain taxpayers disclose uncertain tax positions. The Service requested comments by June 1, 2010. On April 19, 2010, the Service issued the draft schedule and instructions with Announcement 2010-30.