​NRECA filed comments with the Internal Revenue Service (IRS) on proposed regulations stemming from the Tax Cuts and Jobs Act of 2017 that could be detrimental to co-ops. We argue that it is not appropriate to subject co-ops to the same basis allocation approach and market rate assumptions as other electric utilities. We also suggest that the tax basis associated with grants and contributions in aid of construction should be allocated to non-excepted utility operations.FULL FILING