1. this disclosure requirement applied to foreign tax credits as well as other tax credits, and thus to transactions such as that in Compaq. Foreign tax credit transactions were removed from the list by reason of the amendment of the foreign tax credit rules to require a 15-day holding period;Prop. Regs. �,2006
2. The Diophantine equation x 2−(t 2+t)y 2−(4t+2)x+(4t 2+4t)y=0
3. the IRS provided that the provision of "tax result protection that insures some or all of the tax benefits of a reportable transaction" may cause one to be subject to the material advisor disclosure rules, described below;See Logue;proposed regulations issued on,2006