Tax Section Comments Concerning Proposed Realty Transfer Tax Regulations

November 13, 2000

Douglas A. Berguson, Esq.
Senior Assistant Counsel
Department of Revenue
Office of Chief Counsel
1133 Strawberry Square
Harrisburg, PA 17128-1100

Re: Comments and Suggestions Concerning Notice of Proposed Rulemaking, Department of Revenue, 61 Pa. Code, Chapter 91, Realty Transfer Tax ("RTT"), Realty Transfer Tax Amendments
(the "Proposed Regulations")

Dear Mr. Berguson:

The Tax Section of the Philadelphia Bar Association respectfully submits the following comments and suggestions regarding the Proposed Regulations.