Premise: 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.

Hypothesis: The laws involved are all convoluted and impossible for a layman to understand.
Relation: neutral