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Another 409A Extension
Rackemann, Sawyer & Brewster 
[Opinion] Oct. 23, 2007
Excerpt: How do companies comply when the government can't finish rules in more than three years? Too much intellect, and not enough wisdom, has made this whole process as silly as that which surrounded the ill-fated Section 89. Old hands recall that Congress finally repealed Section 89, but not before industry had invested millions in a multi-year regulatory and compliance effort which is chillingly similar to the 409A process today.
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