"Mark B. Weinberg and William J. Olson of the Free Speech Coalition, Inc., McLean, Va., have recommended changes to the proposed and temporary regulations under section 4958, which permits the IRS to impose excise taxes against disqualified persons who participate in excess benefit transactions with section 501(c)(3) and 501(c)(4) organizations.... Weinberg and Olson recommend that the final regs (1) provide a bright line standard for imposing intermediate sanctions that limits the IRS's discretion; (2) identify precisely what notice will be provided to disqualified persons following the IRS's identification of a potential excess benefit transaction; and (3) provide that the 200 percent excise tax won't be imposed during any period in which the 25 percent excise tax may be or is being contested by a taxpayer."