David Zimmerman commented on the recent IRS determination that taxpayers opting for significant issue rulings on the tax consequences of corporate stock distributions, such as spinoffs, need to make additional representations. That could be significant for taxpayers that know early they want a ruling because they have an active trade or business (ATB) issue but they don't know all the details of the transaction, Zimmerman said. It will be harder to make the broader representation if they're not exactly sure what they're going to do, he added.