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Text of ABA Tax Section's Comments on 409A Issues re Timing of Income Reporting and Withholding (PDF)
Section of Taxation, American Bar Association 
Apr. 30, 2007
26 pages; submitted April 25, 2007. Excerpt: The following Comments pertain to Internal Revenue Service Notices 2005-1, 2005-94, and 2006-100 and Regulations sections 1.409A-1 through -6, addressing the application of section 409A of the Internal Revenue Code 1986 ... to nonqualified deferred compensation plans.
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