amelioratory

3) This amelioratory rule would seem especially appropriate in the case of taxpayers continually audited under the IRS's Coordinated Examination Program (where any necessary supplemental information can be made available on audit).

An amelioratory notice should be issued clarifying that Notice 89-84 does not apply to foreign sales corporations.

Although this can prove frustrating -- the technical people advise us to discuss the matter with the Forms Division which in turn tells us that technical rules prevent amelioratory action -- we understand and appreciate the need for tax forms to implement the law as currently interpreted by the Treasury Department and IRS.