Gail Levin Richmond (Nova) has submitted comments to the House Ways and Means Committee on proposed technical amendments to section § 121(d)(11), also available on the Tax Analysts web site as Doc 2005-21077, 2005 TNT 201-26. The comments follow up on her article, Section 121(d)(10): An Article Addressing An Article, 106 Tax Notes 797 (Feb. 14, 2005) [blogged here]. Here is the opening to her comments:
The proposed change to § 121(d)(11) is an improvement over the version enacted in the American Jobs Creation Act of 2004. But, as I discuss below, it may not fully solve problems caused by the current statutory language.




