The ABA Tax Section has submitted comments to the IRS on the proposed § 199 regs.  Here is the opening of the Executive Summary:

On October 19, 2005, the IRS issued a Notice of Proposed Rule Making (Reg-105847-05) proposing regulations (the “Proposed Regulations”) under Section 199 of the Internal Revenue Code. Section 199 was enacted as part of the American Jobs Creation Act of 2004.

The Section of Taxation of the ABA commends Treasury and the IRS for the prompt issuance of the Proposed Regulations. We further commend Treasury and the IRS for providing safe harbors, simplified methods and de minimis rules to facilitate compliance with this new provision.