“Proposed regulations offer guidance for taxpayers seeking to comply with statutory mandates. Taxpayers receive an opportunity to make written and oral comments before these regulations become final. Gail Richmond, Federal Tax Research: Guide to Materials and Techniques, p. 76 (5th ed. 1997)(Foundation Press). As their legal effect, courts have stated that proposed regulations “are merely suggestions made for comment” LeCroy Research Systems Corp. v. Commissioner, 751 F.2d 123, 127 (2d Cir. 1984) and “do not have the force of law.” Zinniel v. Commisioner, 89 T.C. 357, 369 (1989).
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