The ABA Tax Section yesterday submitted this 65-page comment letter on Notice 2010-62 and Implementation of the Economic Substance Legislation:

In Notice 2010-62, the Treasury and the IRS requested comments on certain aspects of the economic substance legislation contained in the Health Care and Education Reconciliation Act of 2010. These comments, which have been prepared by members of the ABA Section of Taxation and by members of the AICPA,   generally address the need for prompt guidance on the implementation of the statutory provisions, comment on the interim guidance set forth in Notice 2010-62, and make recommendations to promote fair and consistent application of the economic substance legislation. Both of our organizations are separately submitting these comments to Treasury and the Service.