How would the settlement initiative affect an Executive who filed a qualified amended return that reported compensation income related to the Transaction?
A-3.9. If an Executive filed a qualified amended return for a Notice 2003-47 transaction and the Executive is otherwise eligible for the settlement initiative, the Executive may participate in the settlement initiative. See Treas. Reg. ยงยง1.6664-2(c)(3), 1.6664-2T, and Notice 2004-38, 2004-21 I.R.B. 949 (May 24, 2004), for the definition of qualified amended return.
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