02/01/2022
https://congress.gov...
"We still have not satisfied the public that they have had adequate input in this process."
"I do believe that there are things that are done at the IRS that need maybe a second look."
"And, it just keeps getting to that point where had you started with a rulemaking process, you would have a firmer foundation for this whole structure that you have created."
"It looks and reads to me like guidance is being used as 'rulemaking light.'"