8 pages, but a possibly long download (about 1 Mb in size). Excerpt: The issue relates to the Service's decision to treat the amendments made by ... the Community Renewal Tax Relief Act of 2000 [to the definition of compensation for purposes of Code section 415] as 'disqualifying provisions,' terminating the (and, as discussed below, we believe inappropriately shortening the otherwise applicable) remedial amendment period with respect to such changes ...