NCLC seeks to ensure that rules adopted by the IRS speed the transition to clean vehicles by encouraging the production of efficient and affordable vehicles and enable and promote the use of clean vehicles by middle and lower income Americans. These comments contain our recommendations in response to this Notice of Proposed Rulemaking, urging the Treasury Department and the IRS to amend the rules addressing the Manufacturer’s Suggested Retail Price to ensure that it actually reflects the sale price of the vehicle when purchased by consumers. We also urge that the vehicle classification standards employed by the Environmental Protection Agency (EPA) under 40 CFR 600.002 to define vehicles as Vans, Sport Utility Vehicles (SUVs), light trucks or passenger cars be used to determine vehicle classifications under the rule, as these classifications are clear and well defined and based upon the physical characteristics of the vehicle.
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