WASHINGTON -- Fred T. Goldberg, commissioner of the Internal Revenue Service, is expected to be nominated soon to replace Kenneth W. Gideon as the Treasury's assistant secretary for tax policy, colleagues said yesterday.

Mr. Gideon is leaving to return to private law practice, they said.

Neither Mr. Goldberg nor Mr. Gideon would confirm the move. However, Mr. Goldberg told tax practitioners attending a Commissioner's Advisory Group meeting last Wednesday that if nominated he would be flattered and happy to serve in the Treasury post.

The new post would give Mr. Goldberg further opportunity to continue his longtime mission of simplifying tax laws and regulations, colleagues said. They added that Mr. Goldberg has close ties with members of both parties in Congress and is considered a strong mediator in resolving tough issues.

Mr. Goldberg had little experience in municipal bonds when he was at the law firm of Skadden, Arp, Slate, Meagher & Flom before joining the IRS. But he has worked closely with IRS and Treasury officials as commissioner and would not be expected to make major changes in bond regulations if he moves to the Treasury, according to agency officials.

Shirley D. Peterson, an assistant attorney general who heads the Justice Department's tax division and has a reputation as a good administrator, is rumored to be the leading candidate to replace Mr. Goldberg. Officials at the department declined to comment.

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