Internal Revenue Bulletin 2000-45 (PDF rendition): IRS Revenue Rulings

Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.

INCOME TAX
Rev. Rul. 2000–50, page 462.
Federal rates; adjusted federal rates; adjusted federal
long-term rate, and the long-term exempt rate. For pur-
poses of sections 1274, 1288, 382, and other sections of
the Code, tables set forth the rates for November 2000.
ESTATE TAX
REG–106511–00, page 465.
Proposed regulations under sections 6075 and 6081 of the
Code provide guidance to executors of decedents’ estates
on how to properly file for an automatic 6-month extension of
time to file an estate tax return (Form 706). A public hearing
is scheduled for January 24, 2001.
TAX CONVENTIONS
Announcement 2000–89, page 467.
The United States recently exchanged instruments of ratifi-
cation for a new income tax treaty with Ukraine. This
announcement provides supplemental tables of withholding
tax rates and exempt personal service income for Publication
515, Withholding of Tax on Nonresident Aliens and Foreign
Corporations, and Publication 901, U.S. Tax Treaties.
Internal Revenue
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Bulletin No. 2000–45
November 6, 2000
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
Department of the Treasury
Internal Revenue Service
Finding Lists begin on page ii.
Index for July through October begins on page iv.

November 6, 20002000–45 I.R.B.
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing offi-
cial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
general interest. It is published weekly and may be obtained
from the Superintendent of Documents on a subscription
basis. Bulletin contents are consolidated semiannually into
Cumulative Bulletins, which are sold on a single-copy basis.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of in-
ternal management are not published; however, statements
of internal practices and procedures that affect the rights
and duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the
revenue ruling. In those based on positions taken in rulings
to taxpayers or technical advice to Service field offices,
identifying details and information of a confidential nature
are deleted to prevent unwarranted invasions of privacy and
to comply with statutory requirements.
Rulings and procedures reported in the Bulletin do not have
the force and effect of Treasury Department Regulations,
but they may be used as precedents. Unpublished rulings
will not be relied on, used, or cited as precedents by Service
personnel in the disposition of other cases. In applying pub-
lished rulings and procedures, the effect of subsequent leg-
islation, regulations, court decisions, rulings, and proce-
dures must be considered, and Service personnel and oth-
ers concerned are cautioned against reaching the same con-
clusions in other cases unless the facts and circumstances
are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions, and Subpart B, Legislation and Related
Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to
these subjects are contained in the other Parts and Sub-
parts. Also included in this part are Bank Secrecy Act Admin-
istrative Rulings. Bank Secrecy Act Administrative Rulings
are issued by the Department of the Treasury’s Office of the
Assistant Secretary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The first Bulletin for each month includes a cumulative index
for the matters published during the preceding months.
These monthly indexes are cumulated on a semiannual basis,
and are published in the first Bulletin of the succeeding semi-
annual period, respectively.
The IRS Mission
Provide America’s taxpayers top quality service by help-
ing them understand and meet their tax responsibilities
and by applying the tax law with integrity and fairness to
all.
Introduction
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402.

November 6, 20004622000–45 I.R.B.
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
Section 42.—Low-Income
Housing Credit
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2000. See Rev. Rul. 2000–50, on this
page .
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term
rates are set forth for the month of November 2000.
See Rev. Rul. 2000–50, on this page .
Section 382.—Limitation on Net
Operating Loss Carryforwards
and Certain Built-In Losses
Following Ownership Change
The adjusted applicable federal long-term rate is
set forth for the month of November 2000. See Rev.
Rul. 2000–50, on this page.
Section 412.—Minimum Funding
Standards
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2000. See Rev. Rul. 2000–50, on this
page.
Section 467.—Certain Payments
for the Use of Property or
Services
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2000. See Rev. Rul. 2000–50, on this
page.
Section 468.—Special Rules for
Mining and Solid Waste
Reclamation and Closing Costs
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2000. See Rev. Rul. 2000–50, on this
page.
Section 482.—Allocation of
Income and Deductions Among
Taxpayers
Federal short-term, mid-term, and long-term
rates are set forth for the month of November 2000.
See Rev. Rul. 2000–50, on this page.
Section 483.—Interest on
Certain Deferred Payments
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2000. See Rev. Rul. 2000–50, on this
page.
Section 642.—Special Rules for
Credits and Deductions
Federal short-term, mid-term, and long-term
rates are set forth for the month of November 2000.
See Rev. Rul. 2000–50, on this page.
Section 807.—Rules for Certain
Reserves
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2000. See Rev. Rul. 2000–50, on this
page.
Section 846.—Discounted
Unpaid Losses Defined
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2000. See Rev. Rul. 2000–50, on this
page.
Section 1274.—Determiation of
Issue Price in the Case of
Certain Debt Instruments Issued
for Property
(Also sections 42, 280G, 382, 412, 467, 468, 482,
483, 642, 807, 846, 1288, 7520, 7872.)
Federal rates; adjusted federal rates;
adjusted federal long-term rate, and
the long-term exempt rate.For purposes
of sections 1274, 1288, 382, and other
sections of the Code, tables set forth the
rates for November 2000.
Rev. Rul. 2000–50
This revenue ruling provides various
prescribed rates for federal income tax
purposes for November 2000 (the current
month). Table 1 contains the short-term,
mid-term, and long-term applicable fed-
eral rates (AFR) for the current month for
purposes of section 1274(d) of the Inter-
nal Revenue Code. Table 2 contains the
short-term, mid-term, and long-term ad-
justed applicable federal rates (adjusted
AFR) for the current month for purposes
of section 1288(b). Table 3 sets forth the
adjusted federal long-term rate and the
long-term tax-exempt rate described in
section 382(f). Table 4 contains the ap-
propriate percentages for determining the
low-income housing credit described in
section 42(b)(2) for buildings placed in
service during the current month. Finally,
Table 5 contains the federal rate for deter-
mining the present value of an annuity, an
interest for life or for a term of years, or a
remainder or a reversionary interest for
purposes of section 7520.

2000–45 I.R.B.463November 6, 2000
REV. RUL. 2000–50 TABLE 1
Applicable Federal Rates (AFR) for November 2000
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-Term
AFR6.15%6.06%6.01%5.98%
110% AFR6.78%6.67%6.62%6.58%
120% AFR7.40%7.27%7.21%7.16%
130% AFR8.04%7.88%7.80%7.75%
Mid-Term
AFR6.01%5.92%5.88%5.85%
110% AFR6.62% 6.51%6.46%6.42%
120% AFR7.23%7.10%7.04%7.00%
130% AFR7.85%7.70%7.63%7.58%
150% AFR9.08%8.88%8.78%8.72%
175% AFR10.63%10.36%10.23%10.14%
Long-Term
AFR6.09%6.00%5.96%5.93%
110% AFR6.71%6.60%6.55%6.51%
120% AFR7.33%7.20%7.14%7.09%
130% AFR7.95%7.80%7.73%7.68%
REV. RUL. 2000–50 TABLE 2
Adjusted AFR for November 2000
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
adjusted AFR4.39%4.34%4.32%4.30%
Mid-term
adjusted AFR4.63%4.58%4.55%4.54%
Long-term
adjusted AFR5.39%5.32%5.29%5.26%
REV. RUL. 2000–50 TABLE 3
Rates Under Section 382 for November 2000
Adjusted federal long-term rate for the current month5.39%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted
federal long-term rates for the current month and the prior two months.)5.41%
REV. RUL. 2000–50 TABLE 4
Appropriate Percentages Under Section 42(b)(2) for November 2000
Appropriate percentage for the 70% present value low-income housing credit8.42%
Appropriate percentage for the 30% present value low-income housing credit3.61%

November 6, 20004642000–45 I.R.B.
REV. RUL. 2000–50 TABLE 5
Rate Under Section 7520 for November 2000
Applicable federal rate for determining the present value of an annuity, an interest for life or a term
of years, or a remainder or reversionary interest7.2%
Section 1288.—Treatment of
Original Issue Discounts on Tax-
Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the
month of November 2000. See Rev. Rul. 2000–50,
page 462.
Section 7520.—Valuation
Tables
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the
month of November 2000. See Rev. Rul. 2000–50,
page 462.
Section 7872.—Treatment of
Loans With Below-Market
Interest Rates
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the
month of November 2000. See Rev. Rul. 2000–50,
page 462.

2000–45 I.R.B.465November 6, 2000
Notice of Proposed Rulemaking
and Notice of Public Hearing
Estate Tax Return; Form 706,
Extension To File
REG–106511–00
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of proposed rulemak-
ing and notice of public hearing.
SUMMARY: This document contains
proposed regulations relating to the filing
of an application for an automatic 6-
month extension of time to file an estate
tax return (Form 706). The proposed reg-
ulations provide guidance to executors of
decedents’ estates on how to properly file
the application for the automatic exten-
sion. This document also provides notice
of a public hearing on these proposed reg-
ulations.
DATES: Written and electronic com-
ments must be received by January 19,
2001. Outlines of topics to be discussed
at the public hearing scheduled for Janu-
ary 24, 2001, at 10 a.m., must be received
by January 3, 2001.
ADDRESSES: Send submissions to:
CC:M&SP:RU (REG–106511–00), room
5226, Internal Revenue Service, POB
7604, Ben Franklin Station, Washington,
DC 20044. Submissions may also be
hand delivered Monday through Friday
between the hours of 8 a.m. and 5 p.m. to:
CC:M&SP:RU (REG–106511–00),
Courier’s Desk, Internal Revenue Ser-
vice, 1111 Constitution Avenue, NW.,
Washington, DC. Alternatively, taxpayers
may submit comments electronically via
the internet by selecting the “Tax Regs”
option on the IRS Home Page, or by sub-
mitting comments directly to the IRS in-
ternet site at http://www.irs.gov/tax
regs/reglist.html. The public hearing will
be held in Room 4716, Internal Revenue
Service Building, 1111 Constitution Av-
enue, NW., Washington, DC.
FOR FURTHER INFORMATION CON-
TACT: Concerning the proposed regula-
tions, Mary A. Berman, (202) 622-3090;
concerning submissions of comments, the
hearing, and/or to be placed on the build-
ing access list to attend the hearing,
LaNita Van Dyke, (202) 622-7180 (not
toll-free numbers).
SUPPLEMENTARY INFORMATION:
Paperwork Reduction Act
The collection of information contained
in this notice of proposed rulemaking has
been submitted to the Office of Manage-
ment and Budget for review in accordance
with the Paperwork Reduction Act of 1995
(44 U.S.C. 3507(d)). Comments on the
collection of information should be sent to
the Office of Management and Budget,
Attn: Desk Officer for the Department of
the Treasury, Office of Information and
Regulatory Affairs, Washington, DC
20503, with copies to the Internal Rev-
enue Service,Attn: IRS Reports Clearance
Officer, W:CAR:MP:FP:S:O, Washington,
DC 20224. Comments on the collection of
information should be received by Decem-
ber 19, 2000. Comments are specifically
requested concerning:
Whether the proposed collection of in-
formation is necessary for the proper per-
formance of the functions of the Internal
Revenue Service, including whether the
information will have practical utility;
The accuracy of the estimated burden
associated with the proposed collection of
information (see below);
How the quality, utility, and clarity of
the information to be collected may be en-
hanced;
How the burden of complying with the
proposed collection of information may
be minimized, including through the ap-
plication of automated collection tech-
niques or other forms of information tech-
nology; and
Estimates of capital or start-up costs and
costs of operation, maintenance, and pur-
chase of service to provide information.
The collection of information in this
proposed regulation is in §20.6081–1(b).
To receive an extension of time to file an
estate tax return, the executor of a dece-
dent’s estate must file Form 4768, “Appli-
cation for Extension of Time To File a Re-
turn and/or Pay U.S. Estate (and
Generation-Skipping Transfer) Taxes.”
This information is required to obtain a
benefit (an automatic 6-month extension
of time to file an estate tax return). The
collection of information is mandatory if
the extension is requested. The likely re-
spondents are executors of decedents’ es-
tates.
The reporting burden contained in
§20.6081–1(b) is reflected in the burden
of Form 4768, “Application for Extension
of Time To File a Return and/or Pay U.S.
Estate (and Generation-Skipping Trans-
fer) Taxes.”
An agency may not conduct or sponsor,
and a person is not required to respond to,
a collection of information unless it dis-
plays a valid control number assigned by
the Office of Management and Budget.
Books or records relating to a collec-
tion of information must be retained as
long as their contents may become mater-
ial in the administration of any internal
revenue law. Generally, tax returns and
tax information are confidential, as re-
quired by 26 U.S.C. 6103.
Background
In 1970, Congress amended section
6075(a) to provide that the Federal estate
tax return is to be filed within 9 months
after the date of the decedent’s death.
Section 6081(a) provides that the Secre-
tary may grant a reasonable extension of
time for filing any return; however, ex-
cept in the case of taxpayers who are
abroad, no such extension may be for
more than 6 months.
Under the current regulations, the dis-
trict director or the service center has the
discretion to grant an extension of time to
file an estate tax return upon a showing
of “good and sufficient cause.” Except in
the case of executors who are abroad, the
extension may not be granted for more
than 6 months. Requests for an extension
of time to file are made by completing
Form 4768, “Application for Extension
of Time To File a Return and/or Pay U.S.
Estate (and Generation-Skipping Trans-
fer) Taxes.” Upon receipt of a Form
4768, the IRS reviews the application,
makes a determination, and notifies the
applicant as to whether an extension is
approved and, if so, the length of the ex-
tension.
Part IV. Items of General Interest

In 1998, 110,100 estate tax returns
were filed. In a significant number of
these cases, the executors requested an
extension of time to file. A majority of
the applications requested and received
the maximum 6-month extension allowed
by the statute and the regulations. The
IRS and the Treasury Department believe
that executors of decedents’ estates would
benefit from the certainty created by an
automatic 6-month extension of time to
file Form 706 and that it is appropriate to
provide for the extension.
Explanation of Provisions
Under the proposed regulations the ex-
ecutor of a decedent’s estate will be al-
lowed an automatic 6-month extension of
time to file Form 706, “United States Es-
tate (and Generation-Skipping Transfer)
Tax Return,” beyond the 9 months pro-
vided for by section 6075(a). The applica-
tion for the automatic extension must be
submitted on Form 4768 (or in any other
manner as may be prescribed by the Com-
missioner). The application must be filed
with the IRS on or before the date pre-
scribed by section 6075(a) for filing the
Form 706 and it must include an estimate
of the full amount of tax due. The auto-
matic extension of time does not apply to
filers of Forms 706-A, 706-D or 706-NA
who will continue to use Form 4768 to re-
quest extensions of time to file and pay es-
tate taxes. The automatic extension of
time also does not apply to filers of Form
706-QDT who will continue to request any
extension of time as provided in the in-
structions for Form 706-QDT. The pro-
posed regulations continue to permit ex-
ecutors who are abroad to request
extensions beyond the automatic 6-month
period.
A return as complete as possible must
be filed before the expiration of the auto-
matic 6-month extension period. The re-
turn as filed will be the return required by
section 6018(a)(1). An extension of time
for filing the return does not operate to
extend the time for payment of the tax.
The proposed regulations also revise
§20.6075–1 to conform to the changes
proposed in §20.6081–1.
Special Analysis
It has been determined that this notice
of proposed rulemaking is not a signifi-
cant regulatory action as defined in Exec-
utive Order 12866. Therefore, a regula-
tory assessment is not required. It also
has been determined that section 553(b)
of the Administrative Procedure Act (5
U.S.C. chapter 5) does not apply to these
regulations, and because these regulations
do not impose a collection of information
on small entities, the Regulatory Flexibil-
ity Act (5 U.S.C. chapter 6) does not
apply. Therefore, a Regulatory Flexibility
Analysis is not required. Pursuant to sec-
tion 7805(f) of the Internal Revenue
Code, the regulations will be submitted to
the Small Business Administration for
comment on their impact on small busi-
ness.
Comments and Public Hearing
Before these proposed regulations are
adopted as final regulations, considera-
tion will be given to any written (a signed
original and eight (8) copies) or electronic
comments that are submitted timely (in
the manner described in ADDRESSES) to
the IRS. Treasury and the IRS specifi-
cally request comments on the clarity of
the proposed regulations and how they
can be made easier to understand. All
comments will be available for public in-
spection and copying.
A public hearing has been scheduled
for January 24, 2001, at 10 a.m. in Room
4716, Internal Revenue Building, 1111
Constitution Avenue, NW., Washington,
DC. Due to building security procedures,
visitors must enter at the 10th Street en-
trance, located between Constitution and
Pennsylvania Avenues, NW. In addition,
all visitors must present photo identifica-
tion to enter the building. Because of ac-
cess restrictions, visitors will not be ad-
mitted beyond the immediate entrance
area more than 15 minutes before the
hearing starts. For information about
having your name placed on the building
access list to attend the hearing, see the
“FOR FURTHER INFORMATION
CONTACT” section of this preamble.
The rules of 26 CFR 601.601(a)(3)
apply to the hearing.
Persons that wish to present oral com-
ments at the hearing must submit com-
ments by January 3, 2001, and submit an
outline of the topics to be discussed and
the time to be devoted to each topic
(signed original and eight (8) copies) by
January 3, 2001. A period of 10 minutes
will be allotted to each person for making
comments. An agenda showing the
scheduling of the speakers will be pre-
pared after the deadline for receiving out-
lines has passed. Copies of the agenda
will be available free of charge at the
hearing.
Drafting Information
The principal author of these proposed
regulations is Mary A. Berman, Office of the
Associate Chief Counsel (Passthroughs and
Special Industries), IRS. However, other
personnel from the IRS and Treasury De-
partment participated in their development.
* * * * *
Proposed Amendments to the
Regulations
Accordingly, 26 CFR part 20 is pro-
posed to be amended as follows:
PART 20—ESTATE TAX; ESTATES OF
DECEDENTS DYING AFTER
AUGUST 16, 1954
Paragraph 1. The authority citation for
part 20 is amended by adding an entry in
numerical order to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Section 20.6081–1 also issued under 26
U.S.C. 6081(a). * * *
Par. 2. Section 20.6075–1 is revised to
read as follows:
§20.6075–1 Returns; time for filing estate
tax return.
The estate tax return required by sec-
tion 6018 must be filed on or before the
due date. The due date is the date on or
before which the return is required to be
filed in accordance with the provisions of
section 6075(a) or the last day of the pe-
riod covered by an extension of time as
provided in §20.6081–1. The due date,
for a decedent dying after December 31,
1970, is, unless an extension of time for
filing has been obtained, the day of the
ninth calendar month after the decedent’s
death numerically corresponding to the
day of the calendar month on which death
occurred, except that, if there is no nu-
merically corresponding day in such ninth
month, the last day of the ninth month is
the due date. For example, if the decedent
dies on July 31, 2000, the estate tax return
and tax payment must be made on or be-
fore April 30, 2001. When the due date
falls on Saturday, Sunday, or a legal holi-
November 6, 20004662000–45 I.R.B.

2000–45 I.R.B.467November 6, 2000
day, the due date for filing the return is
the next succeeding day that is not Satur-
day, Sunday, or a legal holiday. For the
definition of a legal holiday, see section
7503 and §301.7503–1 of this chapter. As
to additions to the tax in the case of fail-
ure to file the return or pay the tax within
the prescribed time, see section 6651 and
§301.6651–1 of this chapter. For rules
with respect to the right to elect to have
the property valued as of a date or dates
subsequent to the decedent’s death, see
section 2032 and §20.2032–1, and section
7502 and §301.7502–1 of this chapter.
This section applies to estates of dece-
dents dying after August 16, 1954.
Par. 3. Section 20.6081–1 is revised to
read as follows:
§20.6081–1 Extension of time for filing
the return.
(a) Extensions of time for good cause
shown. Where it is impossible or imprac-
ticable to file a reasonably complete re-
turn within the time prescribed by statute,
the person required to file the return may
request an extension of time for filing.
Except as provided in paragraph (b) of
this section, an extension of time for fil-
ing an estate tax return is not automatic
and is within the discretion of the Internal
Revenue Service. Unless the person re-
quired to file the return is abroad, an ex-
tension may not be granted for more than
6 months from the filing date prescribed
by statute. Requests for an extension of
time for filing are made by submitting
Form 4768, “Application for Extension of
Time To File a Return and/or Pay U.S. Es-
tate (and Generation-Skipping Transfer)
Taxes.” The application must contain a
full recital of the causes for the delay. It
should be filed with the Internal Revenue
Service office designated in the applica-
tion’s instructions (except as provided in
§301.6091–1(b) of this chapter for hand-
carried documents). The application
should, where possible, be filed suffi-
ciently early to permit the Internal Rev-
enue Service time to consider the matter
and reply before what otherwise would be
the due date of the return. Failure to file
the application before the expiration of
the time within which the return other-
wise must be filed may indicate negli-
gence and constitute sufficient cause for
denial of the extension.
(b) Automatic extension—(1) Applica-
tion for extension. Executors who are re-
quired to file Form 706, “United States
Estate (and Generation-Skipping Trans-
fer) Tax Return,” may request an auto-
matic 6-month extension of time beyond
the date prescribed in section 6075(a) for
filing the return by submitting Form
4768, “Application for Extension of Time
To File a Return and/or Pay U. S. Estate
(and Generation-Skipping Transfer)
Taxes.” An automatic extension will be
allowed if—
(i) The application is filed on or before
the date prescribed in section 6075(a) for
filing the return;
(ii) The application is filed with the In-
ternal Revenue Service office designated
in the application’s instructions (except as
provided in §301.6091–1(b) of this chap-
ter for hand-carried documents); and
(iii) The application includes an esti-
mate of the amount of estate and genera-
tion-skipping transfer tax liability with re-
spect to the estate.
(2) Executors who are abroad. If an
executor who is abroad has received an
automatic 6-month extension, the execu-
tor may request an additional extension of
time by following the procedures in para-
graph (a) of this section.
(c) Filing the return. A return as com-
plete as possible must be filed before the
expiration of the extension period. The
return thus filed will be the return re-
quired by section 6018(a), and any tax
shown on the return will be the amount
determined by the executor as the tax re-
ferred to in section 6161(a)(2), or the
amount shown as the tax by the taxpayer
upon the taxpayer’s return referred to in
section 6211(a)(1)(A). The return cannot
be amended after the expiration of the ex-
tension period although supplemental in-
formation may subsequently be filed that
may result in a finally determined tax dif-
ferent from the amount shown as the tax
on the return.
(d) Payment of the tax. An extension of
time for filing a return does not operate to
extend the time for payment of the tax. See
§20.6151–1 for the time for payment of the
tax, and §§20.6161–1 and 20.6163–1 for
extensions of time for payment of the tax.
(e) Effective date. This section applies to
estates of decedents dying after August 16,
1954, except for paragraph (b) of this sec-
tion which applies to estate tax returns due
after the date these regulations are pub-
lished as a final regulation in the Federal
Register.
Robert E. Wenzel,
Deputy Commissioner
of Internal Revenue.
(Filed by the Office of the Federal Register on Octo-
ber 19, 2000, 8:45 a.m., and published in the issue of
the Federal Register for October 20, 2000, 65 F.R.
63025)
New U.S.–Ukraine Income Tax
Treaty
(Addition to Publications 515
and 901)
Announcement 2000–89
The United States recently exchanged in-
struments of ratification for a new income
tax treaty with Ukraine. The provisions
for taxes withheld on interest, dividends,
and royalties are effective for amounts
paid or credited on or after August 1,
2000. For other taxes, the provisions are
effective for tax periods beginning on or
after January 1, 2001.
Previously, residents of Ukraine were
covered under the treaty between the
United States and the former Soviet
Union. A person entitled to benefits under
that treaty can elect to have that treaty
apply in its entirety for the first tax year
for which the new treaty would otherwise
apply. A person claiming benefits under
Article III(1)(d) of the treaty between the
United States and the former Soviet
Union can elect to have the treaty apply in
its entirety for the duration of the period
of benefits provided by that subpara-
graph.
This announcement provides additions to
Tables 1 and 2 in Publication 515, With-
holding of Tax on Nonresident Aliens and
Foreign Corporations (For Withholding
in 2000),and Publication 901, U.S. Tax
Treaties, to reflect the provisions of the
new treaty. The footnotes in Publication
515 that relate to the column headings in
these tables generally apply to this new
treaty.

November 6, 20004682000–45 I.R.B.

2000–45 I.R.B.iNovember 6, 2000
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus,
if an earlier ruling held that a principle
applied to A, and the new ruling holds
that the same principle also applies to B,
the earlier ruling is amplified. (Compare
with modified, below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously
published ruling and points out an essen-
tial difference between them.
Modified is used where the substance
of a previously published position is
being changed. Thus, if a prior ruling
held that a principle applied to A but not
to B, and the new ruling holds that it ap-
plies to both A and B, the prior ruling is
modified because it corrects a published
position. (Compare with amplified and
clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used
in a ruling that lists previously published
rulings that are obsoleted because of
changes in law or regulations. A ruling
may also be obsoleted because the sub-
stance has been included in regulations
subsequently adopted.
Revoked describes situations where the
position in the previously published rul-
ing is not correct and the correct position
is being stated in the new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a pe-
riod of time in separate rulings. If the
new ruling does more than restate the
substance of a prior ruling, a combination
of terms is used. For example, modified
and superseded describes a situation
where the substance of a previously pub-
lished ruling is being changed in part and
is continued without change in part and it
is desired to restate the valid portion of
the previously published ruling in a new
ruling that is self contained. In this case
the previously published ruling is first
modified and then, as modified, is super-
seded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and
that list is expanded by adding further
names in subsequent rulings. After the
original ruling has been supplemented
several times, a new ruling may be pub-
lished that includes the list in the original
ruling and the additions, and supersedes
all prior rulings in the series.
Suspended is used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current use and for-
merly used will appear in material published in the
Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign Corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statements of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Definition of Terms

November 6, 2000ii2000–45 I.R.B.
Numerical Finding List
1
Bulletins 2000–27 through 2000–44
Announcements:
2000–57, 2000–28 I.R.B. 115
2000–58, 2000–30 I.R.B. 135
2000–59, 2000–29 I.R.B. 120
2000–60, 2000–31 I.R.B. 149
2000–61, 2000–30 I.R.B. 136
2000–62, 2000–30 I.R.B. 137
2000–63, 2000–31 I.R.B. 149
2000–64, 2000–31 I.R.B. 149
2000–65, 2000–31 I.R.B. 150
2000–66, 2000–32 I.R.B. 160
2000–67, 2000–32 I.R.B. 160
2000–68, 2000–32 I.R.B. 161
2000–69, 2000–33 I.R.B. 183
2000–70, 2000–34 I.R.B. 204
2000–71, 2000–44 I.R.B. 456
2000–72, 2000–35 I.R.B. 226
2000–73, 2000–35 I.R.B. 230
2000–74, 2000–35 I.R.B. 230
2000–75, 2000–37 I.R.B. 268
2000–76, 2000–36 I.R.B. 260
2000–77, 2000–36 I.R.B. 260
2000–78, 2000–43 I.R.B. 428
2000–79, 2000–39 I.R.B. 303
2000–80, 2000–40 I.R.B. 320
2000–81, 2000–41 I.R.B. 348
2000–82, 2000–42 I.R.B. 385
2000–83, 2000–41 I.R.B. 348
2000–84, 2000–42 I.R.B. 385
2000–85, 2000–43 I.R.B. 429
2000–86, 2000–44 I.R.B. 456
2000–87, 2000–44 I.R.B. 457
2000–88, 2000–44 I.R.B. 460
Court Decisions:
2068, 2000–28 I.R.B. 109
Notices:
2000–33, 2000–27 I.R.B. 97
2000–34, 2000–33 I.R.B. 172
2000–35, 2000–29 I.R.B. 118
2000–36, 2000–33 I.R.B. 173
2000–37, 2000–29 I.R.B. 118
2000–38, 2000–33 I.R.B. 174
2000–39, 2000–30 I.R.B. 132
2000–40, 2000–30 I.R.B. 134
2000–41, 2000–33 I.R.B. 177
2000–42, 2000–39 I.R.B. 302
2000–43, 2000–35 I.R.B. 209
2000–44, 2000–36 I.R.B. 255
2000–45, 2000–36 I.R.B. 256
2000–46, 2000–37 I.R.B. 265
2000–48, 2000–37 I.R.B. 265
2000–49, 2000–37 I.R.B. 266
2000–50, 2000–38 I.R.B. 291
2000–51, 2000–38 I.R.B. 291
2000–52, 2000–38 I.R.B. 292
2000–53, 2000–38 I.R.B. 293
2000–54, 2000–42 I.R.B. 356
2000–55, 2000–43 I.R.B. 393
2000–56, 2000–43 I.R.B. 393
2000–57, 2000–43 I.R.B. 389
Proposed Regulations:
REG–209038–89, 2000–34 I.R.B. 191
Proposed Regulations—Continued
REG–246249–96, 2000–44 I.R.B. 439
REG–105316–98, 2000–27 I.R.B. 98
REG–110311–98, 2000–36 I.R.B. 258
REG–103805–99, 2000–42 I.R.B. 376
REG–105235–99, 2000–44 I.R.B. 447
REG–116495–99, 2000–33 I.R.B. 179
REG–103735–00, 2000–36 I.R.B. 258
REG–103736–00, 2000–36 I.R.B. 258
REG–108522–00, 2000–34 I.R.B. 187
REG–108553–00, 2000–44 I.R.B. 452
REG–112502–00, 2000–40 I.R.B. 316
REG–114697–00, 2000–43 I.R.B. 421
Railroad Retirement Quarterly Rate:
2000–28, I.R.B. 112
2000–29, I.R.B. 117
2000–42, I.R.B. 354
Revenue Procedures:
2000–28, 2000–27 I.R.B. 60
2000–29, 2000–28 I.R.B. 113
2000–30, 2000–28 I.R.B. 113
2000–31, 2000–31 I.R.B. 146
2000–32, 2000–33 I.R.B. 172
2000–33, 2000–36 I.R.B. 257
2000–34, 2000–34 I.R.B. 186
2000–35, 2000–35 I.R.B. 211
2000–36, 2000–37 I.R.B. 267
2000–37, 2000–40 I.R.B. 308
2000–38, 2000–40 I.R.B. 310
2000–39, 2000–41 I.R.B. 340
2000–40, 2000–42 I.R.B. 357
2000–41, 2000–42 I.R.B. 371
2000–42, 2000–43 I.R.B. 394
2000–43, 2000–43 I.R.B. 404
2000–44, 2000–43 I.R.B. 409
2000–45, 2000–43 I.R.B. 417
2000–46, 2000–44 I.R.B. 438
Revenue Rulings:
2000–32, 2000–27 I.R.B. 1
2000–33, 2000–31 I.R.B. 142
2000–34, 2000–29 I.R.B. 116
2000–35, 2000–31 I.R.B. 138
2000–36, 2000–31 I.R.B. 140
2000–37, 2000–32 I.R.B. 156
2000–38, 2000–32 I.R.B. 157
2000–39, 2000–34 I.R.B. 184
2000–40, 2000–35 I.R.B. 208
2000–41, 2000–36 I.R.B. 248
2000–42, 2000–39 I.R.B. 297
2000–43, 2000–41 I.R.B. 333
2000–44, 2000–41 I.R.B. 336
2000–45, 2000–41 I.R.B. 337
2000–46, 2000–41 I.R.B. 334
2000–47, 2000–37 I.R.B. 264
2000–48, 2000–42 I.R.B. 349
2000–49, 2000–44 I.R.B. 430
Treasury Decisions:
8886, 2000–27 I.R.B. 3
8888, 2000–27 I.R.B. 3
8889, 2000–30 I.R.B. 124
8890, 2000–30 I.R.B. 122
8891, 2000–32 I.R.B. 152
8892, 2000–32 I.R.B. 158
8893, 2000–31 I.R.B. 143
8894, 2000–33 I.R.B. 162
Treasury Decisions—Continued
8895, 2000–40 I.R.B. 304
8896, 2000–36 I.R.B. 249
8897, 2000–36 I.R.B. 234
8898, 2000–38 I.R.B. 276
8899, 2000–38 I.R.B. 288
8900, 2000–38 I.R.B. 279
8901, 2000–38 I.R.B. 272
8902, 2000–41 I.R.B. 323
8903, 2000–42 I.R.B. 352
8904, 2000–42 I.R.B. 350
8905, 2000–44 I.R.B. 435
1
A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 2000–1 through 2000–26
is in Internal Revenue Bulletin 2000–27, dated July
3, 2000.

2000–45 I.R.B.iiiNovember 6, 2000
Finding List of Current Actions on
Previously Published Items
1
Bulletins 2000–27 through 2000–44
Notices:
87–76
Obsoleted by
T.D. 8897, 2000–36 I.R.B. 234
88–24
Obsoleted by
T.D. 8897, 2000–36 I.R.B. 234
88–86
Obsoleted by
T.D. 8897 (section V), 2000–36 I.R.B. 234
2000–48
Superseded by
Rev. Proc. 2000–39, 2000–41 I.R.B. 340
Proposed Regulations:
LR–97–79
Partial withdrawal by
REG–103805–99, 2000–42 I.R.B. 376
FI–42–90
Withdrawn by
Announcement 2000–63, 2000–31 I.R.B. 149
IA–38–93
Withdrawn by
Announcement 2000–68, 2000–32 I.R.B. 161
REG–107644–98
Corrected by
Announcement 2000–66, 2000–32 I.R.B. 160
REG–108522–00
Corrected by
Announcement 2000–85, 2000–43 I.R.B. 428
Revenue Procedures:
88–23
Superseded by
Rev. Proc. 2000–35, 2000–35 I.R.B. 211
98–50
Modified and superseded by
Rev. Proc. 2000–31, 2000–31 I.R.B. 146
98–51
Modified and superseded by
Rev. Proc. 2000–31, 2000–31 I.R.B. 146
99–18
Modified by
Rev. Proc. 2000–29, 2000–28 I.R.B. 113
99–34
Superseded by
Rev. Proc. 2000–28, 2000–27 I.R.B. 60
99–49
Modified and amplified by
Rev. Proc. 2000–38, 2000–40 I.R.B. 310
2000–3
Amplified by
Rev. Proc. 2000–46, 2000–44 I.R.B. 438
2000–9
Superseded by
Rev. Proc. 2000–39, 2000–41 I.R.B. 340
Treasury Decisions:
8873
Corrected by
Announcement 2000–74, 2000–35 I.R.B. 230
8883
Corrected by
Announcement 2000–57, 2000–28 I.R.B. 115
8884
Corrected by
Announcement 2000–73, 2000–35 I.R.B. 230
8892
Corrected by
Announcement 2000–81, 2000–41 I.R.B. 348
1
A cumulative list of current actions on previously
published items in Internal Revenue Bulletins
2000–1 through 2000–26 is in Internal Revenue
Bulletin 2000–27, dated July 3, 2000.

November 6, 2000iv2000–45 I.R.B.
Index
Internal Revenue Bulletins
2000–27 Through 2000–44
The abbreviation and number in paren-
thesis following the index entry refer to
the specific item; numbers in roman and
italic type following the parenthesis refer
to the Internal Revenue Bulletin in which
the item may be found and the page
number on which it appears.
Key to Abbreviations:
AnnAnnouncement
CDCourt Decision
DODelegation Order
EOExecutive Order
PLPublic Law
PTEProhibited Transaction
Exemption
RPRevenue Procedure
RRRevenue Ruling
SPRStatement of Procedural
Rules
TCTax Convention
TDTreasury Decision
TDOTreasury Department Order
EMPLOYEE PLANS
Accrued benefits, involuntary cash-out of
(TD 8891) 32, 152
Cafeteria plans (Ann 65) 31, 150
Defined contribution retirement plans,
nondiscrimination requirements
(REG–114697–00) 43, 421
Determination letters:
Amendments by plan sponsors
(Ann 71) 44, 456
Volume submitter plans (Ann 77) 36, 260
Elective deferrals, section 403(b) plans (RR
35) 31, 138
Form 1099–R, 2001, distribution codes for
IRAs (Ann 86) 44, 456
Full funding limitations, weighted average
interest rate for:
July 2000 (Notice 40) 30, 134
August 2000 (Notice 46) 37, 265
September 2000 (Notice 42) 39, 302
October 2000 (Notice 55) 43, 393
Letter rulings, determination letters, and
information letters issued by the Office
of Chief Counsel (Notice 35) 29, 118
Loans to plan participants (TD 8894) 33,
162; (REG–116495–99) 33, 179
Minimum funding standards:
Change in funding method, by plan
administrators, approval
procedures (RP 41) 42, 371
Selected funding methods, changes to,
approved (RP 40) 42, 357
New technologies in retirement plans,
notices and consents (Ann 74) 35, 230
Nonqualified deferred compensation:
Cash or deferred arrangements (RR
33) 31, 142
State and local governments or tax-
exempt organizations (Notice 38)
33, 174
Proposed Regulations:
26 CFR 1.72(p)–1, amended; loans to
plan participants (REG–116495–99)
33, 179
26 CFR 1.401(a)(4)–8, revised;
1.401(a)(4)-9, amended; defined con-
tribution retirement plans, nondiscrim-
ination requirements
(REG–114697–00) 43, 421
Protected benefits, direct rollover (RR 36)
31, 140
Prototype plans, automatic enrollment fea-
tures (Ann 60) 31, 149
Qualified retirement plans, optional forms
of benefit (TD 8900) 38, 279
Regulations:
26 CFR 1.72–17A, amended; 1.72(p)–1,
added; loans to plan participants (TD
8894) 33, 162
26 CFR 1.411(d)–4, amended; qualified
retirement plans, optional forms of
benefit (TD 8900) 38, 279
26 CFR 31.3121(b)(7)–2, amended;
accrued benefits, involuntary cash-out
of (TD 8891) 32, 152
26 CFR 35.3405–1, correction; new
technologies in retirement plans (Ann
74) 35, 230
EMPLOYMENT TAX
Comprehensive case resolution program
(Notice 43) 35, 209
Electronically filed information returns, due
dates of (TD 8895) 40, 304
Information reporting, payments on behalf
of another person, to joint payees, and
payments of gross proceeds from sales
involving investment advisers
(REG–246249–96) 44, 439
Nonqualified deferred compensation, state
and local governments or tax-exempt
organizations (Notice 38) 33, 174
Proposed Regulations:
26 CFR 31.3406–0, amended;
31.3406(a)–2, revised; 31.3406(a)–4,
amended; 31.3406(b)(3)–2, amended;
31.3406(d)–4, amended;
31.3406(h)–1, –2, amended; pay-
ments on behalf of another person, to
joint payees, and payments of gross
proceeds from sales involving invest-
ment advisers (REG–246249–96) 44,
439
Railroad retirement, rate determination,
quarterly:
April 1, 2000, 28, 112
July 1, 2000, 29, 117
October 1, 2000, 42, 354
Regulations:
26 CFR 31.3402(q)–1, revised;
31.6053–3, revised; 31.6071(a)–1,
revised; electronically filed informa-
tion returns, due dates of (TD 8895)
40, 304
ESTATE TAX
Actuarial tables for valuation of annu-
ities, interests for life or term of years,
and remainder or reversionary interests
(TD 8886) 27, 3
Charitable remainder trusts sample
forms, revision (Notice 37) 29, 118
Regulations:
26 CFR 20.2031–0, –7, amended;
20.2031–7T, removed; 20.7520–1,
amended; 20.7520–1T, removed;
actuarial tables for valuation of
annuities, interests for life or term
of years, and remainder or rever-
sionary interests (TD 8886) 27, 3
EXCISE TAX
Taxable fuel, measurement of
(Notice 33) 27, 97
Taxable substances, polyether polyol,
determinations (Notice 54) 42, 356
EXEMPT
ORGANIZATIONS
Forms:
8870, Information Return for Transfers
EMPLOYEE PLANS—
cont.
EMPLOYMENT TAX—
cont.

2000–45 I.R.B.vNovember 6, 2000
Associated With Certain Personal
Benefit Contracts (Ann 82) 42, 385
8871, Political Organization Notice of
Section 527 Status (Notice 36) 33,
173
8872, Political Organization Report of
Contributions and Expenditures
(Notice 41) 33, 177
Internet usage (Ann 84) 42, 385
Letter rulings, determination letters, and
information letters issued by the Office
of Chief Counsel (Notice 35) 29, 118
List of organizations classified as private
foundations (Ann 61) 30, 136; (Ann
67) 32,160; (Ann 70) 34,204; (Ann
75) 37, 268; (Ann 79) 39, 303; (Ann
87) 44,457
Political organizations:
Contributions and expenditures, Form
8872 (Notice 41) 33, 177
Disclosure, notice, and reporting
requirements (RR 49) 44, 430
Notice of section 527 status, Form
8871 (Notice 36) 33, 173
Proposed revenue ruling on reporting
requirements (Ann 72) 35, 226
Revocations (Ann 62) 30, 137; (Ann 69)
33,183
GIFT TAX
Actuarial tables for valuation of annu-
ities, interests for life or term of years,
and remainder or reversionary interests
(TD 8886) 27, 3
Adequate disclosure, status of limitations
(RP 34) 34, 186
Regulations:
26 CFR 25.2512–0, –5, amended;
25.2512–5T, removed; 25.7520–1,
amended; 25.7520–1T, removed;
actuarial tables for valuation of annu-
ities, interests for life or term of years,
and remainder or reversionary inter-
ests (TD 8886) 27, 3
26 CFR 25.2702–3, amended; special
valuation rules, grantor retained
annuity trust (GRAT) and unitrust
(GRUT) (TD 8899) 38,288
Special valuation rules, grantor retained
annuity trust (GRAT) and unitrust
(GRUT) (TD 8899) 38, 288
INCOME TAX
Acquisition of corporate indebtedness
(RP 33) 36, 257
Actuarial tables for valuation of annu-
ities, interests for life or term of years,
and remainder or reversionary interests
(TD 8886) 27, 3
Appeals:
Ex partecommunication prohibition
(RP 43) 43, 404
Toll-free numbers (Ann 80) 40, 320
Bad debt reserves of thrift institutions
(Ann 63) 31, 149
Business expenses, traveling expenses,
per diemallowances (RP 39) 41, 340
Capital gains look-thru provisions for the
sale or exchange of interest in a pass-
thru entity; rules for dividing the hold-
ing period of a partnership interest
(TD 8902) 41, 323
Capitalization, business expenses, farm-
ing (Notice 45) 36, 256
Charitable remainder trusts sample
forms, revision (Notice 37) 29, 118
Claims for certain income tax convention
benefits, guidance on (TD 8889) 30,
124
Collateralized debt obligations (CDOs),
reporting requirements (TD 8888) 27,
3
Comprehensive case resolution program
(Notice 43) 35, 209
Consolidated returns:
Common parent, agent for sub-
sidiaries, tentative carryback adjust-
ments (REG–103805–99) 42, 376
Limitations on the use of certain cred-
its (Ann 73) 35, 230
Controlled foreign corporations
(REG–112502–00) 40, 316
Corporate reorganizations, continuity of
interest (TD 8898) 38, 276
Corporations, disposition of stock in a
taxable transaction (Ann 57) 28, 115
Credits:
Earned income; preparer due diligence
(TD 8905) 44, 435
Enhanced oil recovery credit, 2000
inflation adjustment (Notice 51) 38,
291
Low-income housing credit:
Carryovers to qualified states, 2000
National Pool (RP 36) 37, 267
Satisfactory bond; “bond factor”
amounts for the period July
through September 2000 (RR 48)
42,349
Renewable electricity production cred-
it, 2000 inflation adjustment (Notice
52) 38, 292
Targeted Jobs Tax Credit, settlement
initiative (Ann 58) 30, 135
Debt roll-ups, election to treat certain
debt substitutions as realization events
(RP 29) 28, 113
Deductions, travel expenses, per diem
rates (Notice 48) 37, 265
Depletion, applicable percentages, oil
and gas production (Notice 50) 38,
291
Distributor commissions (RP 38) 40, 310
Dual consolidated loss, dual resident cor-
poration (RP 42) 43, 404
Earned income credit, preparer due dili-
gence requirements (TD 8905) 44, 435
Electronically filed information returns,
due dates of (TD 8895) 40, 304
Exclusion of gain from the sale or
exchange of a taxpayer’s principal res-
idence (REG–105235–99) 44, 447
Foreign sales corporations, Form 1120-
FSC, Schedule P (Notice 49) 37, 266
Foreign trusts:
Transfers of:
Appreciated property to certain for-
eign trusts (REG–108522–00) 34,
187; correction (Ann 85) 43,429
Property to trusts with U.S. benefi-
ciaries (REG–209038–89) 34, 191
Forms:
1040, e-fileprogram (RP 31) 31, 146
1096, 1098, 1099, 5498, and W-2G,
substitute forms specifications (RP
28) 27, 60
1099-R, 2001, distribution codes for
IRAs (Ann 86) 44,456
1120-FSC, Schedule P, foreign sales
corporations (Notice 49) 37, 266
8869, Qualified Subchapter S
Subsidiary Election, new form
available (Ann 83) 41, 348
8870, Information Return for
Transfers Associated With Certain
Personal Benefit Contracts (Ann
82) 42, 385
8871, Political Organization Notice of
Section 527 Status (Notice 36) 33,
173
8872, Political Organization Report of
Contributions and Expenditures
(Notice 41) 33, 177
W-2, W-3; planned changes to (Ann
76) 36, 260
INCOME TAX—cont.
EXEMPT
ORGANIZATIONS—
cont.

November 6, 2000vi2000–45 I.R.B.
Fringe benefits, aircraft valuation formu-
la (RR 40) 35, 208
Gross income, de minimispremiums,
treatment of (RP 30) 28, 113
Individual retirement arrangements,
returned or recharacterized contribu-
tions, net income calculation (Notice
39) 30, 132
Information reporting:
Payments and reimbursements of qual-
ified tuition and related expenses
(REG–105316–98) 27, 98
Payments on behalf of another person,
to joint payees, and payments of
gross proceeds from sales involving
investment advisers
(REG–246249–96) 44, 439
Information returns, magnetic media fil-
ing requirements (REG–105316–98)
27, 98
Insurance companies:
Differential earnings rate and recom-
puted differential earnings rate for
mutual life insurance companies
(RR 37) 32, 156
Foreign companies, minimum effec-
tively connected net investment
income (RP 32) 33, 172
Loss payment patterns and discount
factors for the 2000 accident year
(RP 44) 43, 409
Salvage discount factors for the 2000
accident year (RP 45) 43, 417
Interest:
Investment:
Federal short-term, mid-term, and
long-term rates for:
July 2000 (RR 32) 27, 1
August 2000 (RR 38) 32,157
September 2000 (RR 41) 36, 248
October 2000 (RR 45) 41, 337
Rates:
Underpayments and overpay-
ments, quarter beginning October
1, 2000 (RR 42) 39, 297
Inventory:
Dollar-value LIFO and inventory price
index computation (IPIC) methods
(Ann 66) 32, 160
LIFO:
Price indexes, department stores,
for:
May 2000 (RR 34) 29, 116
June 2000 (RR 39) 34,184
July 2000 (RR 47) 37, 264
August 2000 (RR 46) 41, 334
Letter rulings, determination letters, and
information letters issued by the Office
of Chief Counsel (Notice 35) 29, 118
Like-kind exchanges, “parking” arrange-
ments (RP 37) 40, 308
Loss deductions, challenge of, Blue
Cross Blue Shield organizations
(Notice 34) 33, 172
Marginal properties, oil and gas produc-
tion, depletion, applicable percentages
(Notice 50) 38, 291
Model rabbi trust, contribution of parent
stock (Notice 56) 43, 393
Nonqualified perferred stock, exchanges
and distributions (TD 8904) 42, 350
Partnerships:
Addition to no-rule list (RP 46) 44,
438
Transactions between partner and part-
nership (RR 44) 41,336
Private foundations, organizations now
classified as (Ann 61) 30, 136; (Ann
67) 32,160; (Ann 70) 34,204; (Ann
75) 37,268; (Ann 79) 39,303; (Ann
87) 44, 457
Proposed Regulations:
26 CFR 1.121–1, –2, –3, –4, revised;
1.121–5, removed; 1.1398–3, added;
exclusion of gain from the sale or
exchange of a taxpayer’s principal
residence (REG–105235–99) 44,
447
26 CFR 1.679–1, –2, –3, –4, –5, –6,
–7, added; 1.958–1, –2, amended;
foreign trusts with U.S. beneficia-
ries (REG–209038–89) 34, 191
26 CFR 1.684–1, –2, –3, –4, –5,
added; tax on transfers of appreciat-
ed property to foreign trusts and
foreign estates (REG–108522–00)
34, 187; correction (Ann 85) 43,
429
26 CFR 1.702–1, amended; 1.952–1,
added; 1.954–1, –2, –3, –4, added;
1.956–2, added; controlled foreign
corporations (REG–112502–00) 40,
316
26 CFR 1.1502–77 redesignated as
1.1502–77A; 1.1502–77, added;
1.1502–77T(a) redesignated as
1.1502–77A(e); 1.1502–77T,
removed; 1.1502–78, amended; con-
solidated returns, common parent,
agent for subsidiaries, tentative car-
ryback adjustments
(REG–103805–99) 42, 376
26 CFR 1.6011–4, amended;
301–6111–2, amended;
301–6112–1, amended; tax shelters,
disclosure rules, registration and list
maintenance requirements, addi-
tional guidance of
(REG–110311–98,
REG–103735–00,
REG–103736–00) 36, 258
26 CFR 1.6041–1, –3, amended;
1.6045–1, –2, amended; 1.6049–4,
revised; 5f.6045–1, removed; pay-
ments on behalf of another person,
to joint payees, and payments of
gross proceeds from sales involving
investment advisers
(REG–246249–96) 44, 439
26 CFR 1.6050S–0, –1, –2, added;
301.6011–2, amended; information
reporting, payments and reimburse-
ments of qualified tuition and relat-
ed expenses (REG–105316–98) 27,
98
26 CFR 301.7701–7, amended; cer-
tain pension, employee benefit, and
certain investment trusts classified
as domestic trusts
(REG–108553–00) 44, 452
Publications:
515, changes in tables 1 and 2 for
Denmark treaty (Ann 59) 29, 120
901, changes in tables 1 and 2 for
Denmark treaty (Ann 59) 29, 120
1212, supplemental information on
short-term Treasury bills (Ann 64)
31, 149
Qualified transportation fringes, distrib-
ution of transit passes (Ann 78) 43,
428
Qualified zone academy bonds, guid-
ance (TD 8903) 42, 352
Real estate mortgage investment con-
duits (REMICs), reporting require-
ments (TD 8888) 27, 3
Regulations:
26 CFR 1.1(h)–1, added; 1.741–1,
amended; 1.1223–3, added; capital
gains look-thru provisons for the
sale or exchange of interest in a
pass-thru entity; rules for dividing
the holding period of a partnership
interest (TD 8902) 41, 323
26 CFR 1.110–1, added; 1.602.101,
amended; short-term leases, quali-
fied lessee construction allowances
for (TD 8901) 38, 272
INCOME TAX—cont.INCOME TAX—cont.INCOME TAX—cont.

2000–45 I.R.B.viiNovember 6, 2000
26 CFR 1.162–12, amended;
1.263A–0, –1, amended;
1.263A–0T, removed; 1.263A–4,
revised; 1.263A–4T, removed;
1.471–6, amended; uniform capital-
ization applied to farming business
(TD 8897) 36, 234; correction (Ann
88) 44, 460
26 CFR 1.170A–12, amended;
1.170A–12T, removed; 1.642(c)–6,
amended; 1.642(c)–6T, removed;
1.664–4, amended; 1.664–4T,
removed; 1.7520–1, amended;
1.7520–1T, removed; actuarial
tables for valuation of annuities,
interests for life or term of years,
and remainder or reversionary inter-
ests (TD 8886) 27, 3
26 CFR 1.351–2, amended; 1.354–1,
amended; 1.355–1, amended;
1.356–7, added; 1.1036–1, amend-
ed; nonqualified preferred stock,
exchanges and distributions (TD
8904) 42, 350
26 CFR 1.368–1, amended; 1.368–1T,
removed; corporate reorganizations;
continuity of interest (TD 8898) 38,
276
26 CFR 1.401(a)–20, amended;
1.401(a)(4)–4, amended; 1.401(a)
(26)–4, –6, amended; 1.411(a)–7,
–11, amended; 1.411(a)–7T, –11T,
removed; 1.411(d)–4, amended;
1.417(e)–1, amended; accrued bene-
fits, involuntary cash-out of (TD
8891) 32, 152
26 CFR 1.472–8, correction; dollar-
value LIFO regulations, inventory
price index computation (IPIC)
method (Ann 66) 32, 160
26 CFR 1.643(h)–1, amended;
1.671–2(e), revised; 1.671–2T,
removed; 1.672(f)–2, –3, –4, –5,
amended; definition of grantor (TD
8890) 30, 122
26 CFR 1.894–1, revised; guidance
regarding claims for certain income
tax convention benefits (TD 8889)
30, 124
26 CFR 1.1032–3, correction; disposi-
tion of stock in a taxable transaction
(Ann 57) 28, 115
26 CFR 1.1397E–1T redesignated as
1.1397E–1; 1.1397E–1, amended;
qualified zone academy bonds,
guidance (TD 8903) 42, 352
26 CFR 1.1502–3, correction; consoli-
dated returns, limitations on the use
of certain credits (Ann 73) 35, 230
26 CFR 1.6011–4T, amended; 301–
6111–2T, amended; 301–6112–1T,
amended; tax shelters, disclosure
rules, registration and list mainte-
nance requirements, additional guid-
ance on (TD 8896) 36, 249
26 CFR 1.6012–7T, removed;
1.6061–2T, removed; 1.6065–2T,
removed; 602.101(c), amended;
telefile voice signature test (TD
8892) 32, 158; correction (Ann 81)
41,348
26 CFR 1.6041–2, –6, revised;
1.6042–2, revised; 1.6043–2,
revised; 1.6044–2, revised;
1.6045–1, amended; 1.6045–2, –4,
revised; 1.6047–1, revised;
1.6049–4, amended; 1.6049–7,
revised; 1.6050A–1, revised;
1.6050D–1, revised; 1.6050E–1,
revised; 1.6050H–2, revised;
1.6050J–1T, revised; 1.6050P–1,
revised; 1.6052–1, revised; electron-
ically filed information returns, due
dates of (TD 8895) 40, 304
26 CFR 1.6049–7, amended; real
estate mortgage investment con-
duits; reporting requirements and
other administrative matters (TD
8888) 27, 3
26 CFR 1.6695–1, amended;
1.6695–1T, removed; requirement to
retain copy of return or claim signed
by preparer (TD 8893) 31, 143
26 CFR 1.6695–2, added; 1.6695–2T,
removed; earned income credit, pre-
parer due diligence requirements
(TD 8905) 44, 435
26 CFR 301.6651–1, amended; elec-
tronically filed information returns,
due date of (TD 8895) 40, 304
26 CFR 602.101, amended; capital
gains look-thru provisions for the
sale or exchange of interest in a
pass-thru entity; rules for dividing
the holding period of a partnership
interest (TD 8902) 41, 323
26 CFR 602.101, amended; earned
income credit, preparer due dili-
gence requirements (TD 8905) 44,
435
Retention of return or claim signed by
tax preparer (TD 8893) 31, 143
Revocations, exempt organizations (Ann
62) 30, 137; (Ann 69) 33,183
S corporations:
Charitable contributions, section
170(a)(2) (RR 43) 41, 333
Qualified Subchapter S Subsidiary
Election, new Form 8869 available
(Ann 83) 41, 348
Schedule P (Form 1120-FSC), foreign
sales corporations (Notice 49) 37, 266
Separate return limitation year (SRLY)
losses (Notice 53) 38, 293
Short-term leases, qualified lessee con-
struction allowances for (TD 8901) 38,
272
Substitute forms, 1096, 1098, 1099,
5498, and W-2G, rules and specifica-
tions (RP 28) 27, 60
Tax claims in bankruptcy court (CD
2068) 28, 109
Tax conventions, Dutch pension plans,
tax treaty benefits, Netherlands
(Notice 57) 43, 389
Tax shelters:
Avoidance using artificially high basis
(Notice 44) 36, 255
Disclosure rules, registration and list
maintenance requirements, addition-
al guidance on (TD 8896) 36, 249;
(REG–110311–98, REG–103735–00,
REG–103736–00) 36, 258
Telefile voice signature test:
Notice of proposed rulemaking with-
drawn (Ann 68) 32, 161
Temporary regulations removed (TD
8892) 32, 158; correction (Ann 81)
41, 348
Treaties:
Denmark, Publications 515 and 901
(Ann 59) 29, 120
Withholding rates, tax treaty benefits
(TD 8889) 30, 124
Trusts:
Certain pension, employee benefit, and
certain investment trusts classified
as domestic trusts
(REG–108553–00) 44, 452
Definition of grantor (TD 8890) 30,
122
Uniform captialization applied to farm-
ing business (TD 8897) 36, 234; cor-
rection (Ann 88) 44, 460
Withholding certificate, guidance for
obtaining (RP 35) 35, 211
INCOME TAX—cont.INCOME TAX—cont.INCOME TAX—cont.

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