On July 13, 2007, TEI President David L. Bernard submitted a letter to Assistant Secretary of the Treasury for Tax Policy Eric Solomon and Acting IRS Commissioner Kevin Brown relating to the treatment of transaction costs incurred in connection with the acquisition, creation, or disposition of a trade or business in a taxable or tax-free stock or asset transaction. The comments respond to a request by the IRS in Notice 2004-18. TEI's comments were prepared under the aegis of TEI's Federal Tax Committee whose chair is Susan A. Bauer of Moore Investment Group. Contributing substantially to the development of TEI's comments were Steven Solinga and Philip G. Cohen of Unilever ...