Since sections 211 and 212 of Public Law 104-193 were effective upon enactment and section 215 required the Commissioner to issue regulations to carry out the amendments within 3 months after enactment, the Commissioner found that it would be impracticable and contrary to congressional intent to follow the NPRM procedures.
363962
Sections 211 and 212 are about public law.
363963
The Commissioner thinks it will be easy to follow the procedures.