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Guest ESOPwizard
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According to an article in yesterday's Wall Street Journal (which I don't have in front of me; so I can't quote it),

the proposal is in response to aggressive marketing of tax shelters(?) by accounting firms. Its the same idea that

Forbes starts with in its article on tax hustlers. The government could end the abuses by properly enforcing the

1361 regs, but it decided to go for overkill instead.

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