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IRS Notice 2001-69 Laudable But Legal and Administrative Issues Should Be Considered (PDF)
Katten Muchin Zavis Rosenman 
May 1, 2002
Excerpt: [T]he IRS has responded to the desires of many American workers to help those affected by the events of September 11, by adopting a rather remarkable enforcement position with respect to constructive receipt of certain employer-provided benefits.... Before implementing such a program, an employer will want to examine the state age and hour laws or secure labor counsel to ensure that it is not violating such laws to permit an employee to forgo the payment for guaranteed time off.
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