The Treasury Department should draft reissuance regulations that go beyond the two previous notices on auction-rate securities, and they should clarify how reissuance rules pertain to other sections of the tax code and give issuers more flexibility in some areas, the National Association of Bond Lawyers said in a letter to Treasury.

The letter, dated July 10, and 13 pages of comments come as the Treasury Department begins to adopt two notices on reissuance, 2008-41 and 2008-15, into proposed regulations. The notices were released earlier this year in response to turmoil in the auction-rate securities and bond insurance market, but John J. Cross3d, an attorney with the Treasury's office of tax policy, said at a NABL conference in February that the department eventually planned to turn them into proposed Internal Revenue Service regulations.

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