Internal Revenue Bulletin 2001-19 (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. 2001–22, page 1152.
Federal rates; adjusted federal rates; adjusted feder-
al long-term rate, and the long-term exempt rate. For
purposes of sections 382, 1274, 1288, and other sections
of the Code, tables set forth the rates for May 2001.
Notice 2001–33, page 1155.
Electricity produced from certain renewable
resources; calendar year 2001 inflation adjustment
factor and reference prices.This notice announces the
calendar year 2001 inflation adjustment factor and refer-
ence prices for the renewable electricity production credit
under section 45 of the Code.
Rev. Proc. 2001–27, page 1155.
Section 911(d)(4) waiver.Guidance is provided to individ-
uals who fail to meet the eligibility requirements of section
911(d)(1) of the Code because adverse conditions in a for-
eign country preclude the individual from meeting those
requirements. A current list of countries and the dates those
countries are subject to the section 911(d)(4) waiver is pro-
vided. Rev. Proc. 2000–14 supplemented.
EXEMPT ORGANIZATIONS
Announcement 2001–46, page 1165.
A list is provided of organizations that no longer qualify as
organizations to which contributions are deductible under
section 170 of the Code.
Announcement 2001–47, page 1165.
A list is provided of organizations now classified as private
foundations.
EXCISE TAX
Announcement 2001-48, page 1168.
The Service announces the availability of two new forms
and their instructions. Form 720-TO, Terminal Operator
Report, and Form 720-CS, Carrier Summary Report, are
information returns that will be used by terminal operators
and carriers to report their monthly receipts and disburse-
ments of liquid products.
ADMINISTRATIVE
Rev. Proc. 2001–28, page 1156.
Rulings; leveraged leasing transactions.This procedure
provides guidelines that the Service will use for advance rul-
ing purposes in determining whether certain transactions
purporting to be leases of property are, in fact, leases for
federal income tax purposes. Rev. Procs. 75–21, 76–30,
and 79–48 modified and superseded.
Rev. Proc. 2001–29, page 1160.
Rulings; leveraged leasing transactions; information
and representations.This procedure sets forth the infor-
mation and representations required to be furnished by tax-
payers in requests for advance rulings on leveraged lease
transactions within the meaning of Rev. Proc. 2001–28.
Rev. Procs. 75–28 and 79–48 modified and superseded.
Rev. Proc. 2001–30, page 1163.
Qualified fuel under section 29(c)(1)(C). This procedure
informs the public of the Service’s decision to issue private
letter rulings, under specified circumstances, regarding
whether a solid fuel produced from coal is a qualified fuel
under section 29(c)(1)(C) of the Code. Section 5.01 of Rev.
Proc. 2001–3 revoked.
Internal Revenue
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Bulletin No. 2001–19
May 7, 2001
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 January through April begins on page vi.

May 7, 20012001–19 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 1100.—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.

Section 29.—Credit for
Producing Fuel From a
Nonconventional Source
Under what circumstances may a taxpayer obtain
a private letter ruling under section 29(c)(1)(C) that
a solid fuel produced from coal is a qualified fuel?
See Rev. Proc. 2001–30, page 1163.
Section 38.—General Business
Credit
What guidelines will be used, and what informa-
tion and representations are required to be furnished
by taxpayers, in connection with obtaining an ad-
vance ruling from the Service as to whether certain
transactions purporting to be leases of property are,
in fact, leases for federal income tax purposes. See
Rev. Proc. 2001–28, page 1156, and Rev. Proc.
2001–29, page 1160.
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 May 2001. See Rev. Rul. 2001–22, beginning on
this page.
Section 61.—Gross Income
Defined
26 CFR 1.61–1: Gross income.
What guidelines will be used, and what informa-
tion and representations are required to be furnished
by taxpayers, in connection with obtaining an ad-
vance ruling from the Service as to whether certain
transactions purporting to be leases of property are,
in fact, leases for federal income tax purposes. See
Rev. Proc. 2001–28, page 1156, and Rev. Proc.
2001–29, page 1160.
Section 162.—Trade or
Business Expenses
26 CFR 1.162–1: Business expenses.
What guidelines will be used, and what informa-
tion and representations are required to be furnished
by taxpayers, in connection with obtaining an ad-
vance ruling from the Service as to whether certain
transactions purporting to be leases of property are,
in fact, leases for federal income tax purposes. See
Rev. Proc. 2001–28, page 1156, and Rev. Proc.
2001–29, page 1160.
Section 167.—Depreciation
26 CFR 1.167(a)–1: Depreciation in general.
What guidelines will be used, and what informa-
tion and representations are required to be furnished
by taxpayers, in connection with obtaining an ad-
vance ruling from the Service as to whether certain
transactions purporting to be leases of property are,
in fact, leases for federal income tax purposes. See
Rev. Proc. 2001–28, page 1156, and Rev. Proc.
2001–29, page 1160.
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term
rates are set forth for the month of May 2001. See
Rev. Rul. 2001–22, beginning 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 May 2001. See Rev. Rul.
2001–22, beginning 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 May 2001. See Rev. Rul. 2001–22, beginning on
this page.
Section 467.—Certain
Payments for the Use of
Property or Services
26 CFR 1.467–3: Disqualified leasebacks and long-
term agreements.
What guidelines will be used, and what informa-
tion and representations are required to be furnished
by taxpayers, in connection with obtaining an ad-
vance ruling from the Service as to whether certain
transactions purporting to be leases of property are,
in fact, leases for federal income tax purposes. See
Rev. Proc. 2001–28, page 1156, and Rev. Proc.
2001–29, page 1160.
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 May
2001. See Rev. Rul. 2001–22, beginning 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 May 2001. See
Rev. Rul. 2001–22, beginning 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 May
2001. See Rev. Rul. 2001–22, beginning 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 May 2001. See
Rev. Rul. 2001–22, beginning 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 May
2001. See Rev. Rul. 2001–22, beginning 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 May 2001. See Rev. Rul. 2001–22, beginning on
this page.
Section 1274.—Determination
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.)
May 7, 200111522001–19 I.R.B.
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

Federal rates; adjusted federal rates;
adjusted federal long-term rate, and
the long-term exempt rate.For
purposes of sections 382, 1274, 1288,
and other sections of the Code, tables set
forth the rates for May 2001.
Rev. Rul. 2001–22
This revenue ruling provides various
prescribed rates for federal income tax
purposes for May 2001 (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.
2001–19 I.R.B.1153May 7, 2001
REV. RUL. 2001–22 TABLE 1
Applicable Federal Rates (AFR) for May 2001
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-Term
AFR4.25%4.21%4.19%4.17%
110% AFR4.68%4.63%4.60%4.59%
120% AFR5.11%5.05%5.02%5.00%
130% AFR5.54%5.47%5.43%5.41%
Mid-Term
AFR4.77%4.71%4.68%4.66%
110% AFR5.25%5.18%5.15%5.12%
120% AFR5.73%5.65%5.61%5.58%
130% AFR6.21%6.12%6.07%6.04%
150% AFR7.19%7.07%7.01%6.97%
175% AFR8.41%8.24%8.16%8.10%
Long-Term
AFR5.43%5.36%5.32%5.30%
110% AFR5.99% 5.90%5.86%5.83%
120% AFR 6.53%6.43%6.38%6.35%
130% AFR 7.09%6.97%6.91%6.87%
REV. RUL. 2001–22 TABLE 2
Adjusted AFR for May 2001
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
adjusted AFR3.34%3.31%3.30%3.29%
Mid-term
adjusted AFR3.89%3.85%3.83%3.82%
Long-term
adjusted AFR4.89%4.83%4.80%4.78%

REV. RUL. 2001–22 TABLE 3
Rates Under Section 382 for May 2001
Adjusted federal long-term rate for the current month4.89%
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.)4.89%
May 7, 200111542001–19 I.R.B.
REV. RUL. 2001–22 TABLE 4
Appropriate Percentages Under Section 42(b)(2) for May 2001
Appropriate percentage for the 70% present value low-income housing credit8.19%
Appropriate percentage for the 30% present value low-income housing credit3.51%
REV. RUL. 2001–22 TABLE 5
Rate Under Section 7520 for May 2001
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 interest5.8%
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 May 2001. See Rev. Rul. 2001–22, page 1152.
Section 7520.—Valuation Tables
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 2001. See Rev. Rul. 2001–22, page 1152.
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 May 2001. See Rev. Rul. 2001–22, page 1152.

Renewable Electricity
Production Credit, Publication of
Inflation Adjustment Factor and
Reference Prices for Calendar
Year 2001
Notice 2001–33
This notice publishes the inflation ad-
justment factor and reference prices for
calendar year 2001 for the renewable
electricity production credit under § 45(a)
of the Internal Revenue Code. The 2001
inflation adjustment factor and reference
prices are used in determining the avail-
ability of the credit. The 2001 inflation
adjustment factor and reference prices
apply to calendar year 2001 sales of kilo-
watt-hours of electricity produced in the
United States or a possession thereof from
qualified energy resources.
BACKGROUND
Section 45(a) provides that the renew-
able electricity production credit for any
tax year is an amount equal to the product
of 1.5 cents multiplied by the kilowatt-
hours of specified electricity produced by
the taxpayer and sold to an unrelated per-
son during the tax year. This electricity
must be produced from qualified energy
resources and at a qualified facility during
the 10-year period beginning on the date
the facility was originally placed in ser-
vice.
Section 45(b)(1) provides that the
amount of the credit determined under
§ 45(a) is reduced by an amount that bears
the same ratio to the amount of the credit
as (A) the amount by which the reference
price for the calendar year in which the
sale occurs exceeds 8 cents bears to (B) 3
cents. Under § 45(b)(2), the 1.5 cents in
§ 45(a) and the 8 cents in § 45(b)(1) are
each adjusted by multiplying the amount
by the inflation adjustment factor for the
calendar year in which the sale occurs.
Section 45(c)(1) defines qualified en-
ergy resources as wind, closed-loop bio-
mass, and poultry waste. Section 45(c)(3)
defines a qualified facility as any facility
owned by the taxpayer that originally is
placed in service after December 31, 1993
(in the case of a facility using wind to pro-
duce electricity), December 31, 1992 (in
the case of a facility using closed-loop
biomass to produce electricity), or De-
cember 31, 1999 (in the case of a facility
using poultry waste to produce electric-
ity), and before January 1, 2002. See
§ 45(d)(7) for rules relating to the inap-
plicability of the credit to electricity sold
to utilities under certain contracts.
Section 45(d)(2)(A) requires the Secre-
tary to determine and publish in the Fed-
eral Register each calendar year the infla-
tion adjustment factor and the reference
prices for the calendar year. The inflation
adjustment factor and the reference prices
for the 2001 calendar year were published
in the Federal Register on April 18, 2001,
(66 Fed. Reg. 20032).
Section 45(d)(2)(B) defines the infla-
tion adjustment factor for a calendar year
as the fraction the numerator of which is
the GDP implicit price deflator for the
preceding calendar year and the denomi-
nator of which is the GDP implicit price
deflator for the calendar year 1992. The
term “GDP implicit price deflator” means
the most recent revision of the implicit
price deflator for the gross domestic prod-
uct as computed and published by the De-
partment of Commerce before March 15
of the calendar year.
Section 45(d)(2)(C) provides that the
reference price is the Secretary’s determi-
nation of the annual average contract
price per kilowatt-hour of electricity gen-
erated from the same qualified energy re-
source and sold in the previous year in the
United States. Only contracts entered
into after December 31, 1989, are taken
into account.
INFLATION ADJUSTMENT FACTOR
AND REFERENCE PRICES
The inflation adjustment factor for cal-
endar year 2001 is 1.1641. The reference
prices for calendar year 2001 are 2.57
cents per kilowatt-hour for facilities pro-
ducing electricity from wind energy re-
sources and 0 cents per kilowatt-hour for
facilities producing electricity from
closed-loop biomass and poultry waste
energy resources.
PHASE-OUT CALCULATION
Because the 2001 reference prices for
electricity produced from wind, closed-
loop biomass, and poultry waste energy
resources do not exceed 8 cents per kilo-
watt-hour multiplied by the inflation ad-
justment factor, the phaseout of the credit
provided in § 45(b)(1) does not apply to
electricity produced from wind, closed-
loop biomass, or poultry waste energy re-
sources sold during calendar year 2001.
CREDIT AMOUNT
As required by § 45(b)(2), the 1.5¢
amount in § 45(a)(1) is adjusted by multi-
plying such amount by the inflation ad-
justment factor for the calendar year in
which the sale occurs. If any amount as
increased under the preceding sentence is
not a multiple of 0.1¢, such amount is
rounded to the nearest multiple of 0.1¢.
Under the calculation required by
§ 45(b)(2), the renewable electricity pro-
duction credit for calendar year 2001 is
1.7¢ per kilowatt-hour on the sale of elec-
tricity produced from wind energy,
closed-loop biomass, and poultry waste
resources.
DRAFTING INFORMATION
CONTACT
The principal author of this notice is
David A. Selig of the Office of Associate
Chief Counsel (Passthroughs and Special
Industries). For further information re-
garding this notice, contact Mr. Selig at
(202) 622-3040 (not a toll-free call).
26 CFR 601.105: Examination of returns and
claims for refund, credit, or abatement;
determination of correct tax liability. (Also Part 1,
§ 911, 1.911–1)
Rev. Proc. 2001–27
SECTION 1. PURPOSE
01. This revenue procedure provides
information to any individual who failed
to meet the eligibility requirements of
§ 911(d)(1) of the Internal Revenue Code
because adverse conditions in a foreign
country precluded the individual from
meeting those requirements for taxable
year 2000.
02. The Internal Revenue Service has
previously listed countries for which the el-
2001–19 I.R.B.1155May 7, 2001
Part III. Administrative, Procedural, and Miscellanous

igibility requirements of § 911(d)(1) of the
Code are waived under § 911(d)(4) because
of adverse conditions in those countries on
and after the date stated. See Rev. Proc.
2000–14, 2000–18 I.R.B. 960, Rev. Proc.
99–20, 1999–1 C.B. 872, and Rev. Proc.
98–38, 1998–2 C.B. 28. This revenue pro-
cedure lists countries added to the list in
2000, for which the eligibility requirements
of § 911(d)(1) are waived. Rev. Proc.
2000–14, Rev. Proc. 99–20, and Rev. Proc.
98–38 remain in full force and effect.
SEC. 2. BACKGROUND
01. Section 911(a) of the Code allows
a “qualified individual,” as defined in
§ 911(d)(1), to exclude foreign earned in-
come and housing cost amounts from
gross income. Section 911(c)(3) of the
Code allows a qualified individual to
deduct housing cost amounts from gross
income.
02. Section 911(d)(1) of the Code de-
fines the term “qualified individual” as an
individual whose tax home is in a foreign
country and who is (A) a citizen of the
United States and establishes to the satis-
faction of the Secretary of the Treasury
that the individual has been a bona fide
resident of a foreign country or countries
for an uninterrupted period that includes
an entire taxable year, or (B) a citizen or
resident of the United States who, during
any period of 12 consecutive months, is
present in a foreign country or countries
during at least 330 full days.
03. Section 911(d)(4) of the Code pro-
vides an exception to the eligibility re-
quirements of § 911(d)(1). An individual
will be treated as a qualified individual
with respect to a period in which the indi-
vidual was a bona fideresident of, or was
present in, a foreign country if the indi-
vidual left the country during a period for
which the Secretary of the Treasury, after
consultation with the Secretary of State,
determines that individuals were required
to leave because of war, civil unrest, or
similar adverse conditions that precluded
the normal conduct of business. An indi-
vidual must establish that but for those
conditions the individual could reason-
ably have been expected to meet the eligi-
bility requirements.
04. For 2000, the Secretary of the
Treasury in consultation with the Secre-
tary of State, has determined that war,
civil unrest, or similar adverse condi-
tions that precluded the normal conduct
of business existed in the following
country beginning on or after the speci-
fied date:
Date of Departure
CountryOn or After
Eritrea May 19, 2000
05. Accordingly, for purposes of § 911
of the Code, an individual who left the
foregoing country on or after the specified
departure date shall be treated as a quali-
fied individual with respect to the period
during which that individual was present
in, or was a bona fideresident of, such
foreign country if the individual estab-
lishes a reasonable expectation of meeting
the requirements of § 911(d) but for those
conditions.
06. To qualify for relief under § 911
(d)(4) of the Code, an individual must
have established residency or have been
physically present in the foreign country
on or prior to the date that the Secretary of
the Treasury determines that individuals
were required to leave the foreign coun-
try. Individuals who establish residency
or are first physically present in the for-
eign country after the date that the Secre-
tary prescribes, shall not be treated as
qualified individuals under § 911(d)(4) of
the Code pursuant to § 911(d)(4)(C). For
example, individuals who are first physi-
cally present in Eritrea after May 19,
2000, are not eligible to qualify for the
exemption prescribed in § 911(d)(4) of
the Code for taxable year 2000.
07. In order to assist those individuals
who are filing prior year or amended tax
returns, the Internal Revenue Service is
republishing the countries listed for tax
years 1997, 1998, and 1999, for which the
eligibility requirements of § 911(d)(1) of
the Code are waived under §911(d)(4):
Tax Year 1997-
Date of Departure
CountryOn or After
AlbaniaMarch 12,1997
CambodiaJuly 9, 1997
Central African
RepublicMarch 28, 1997
Democratic Republic
of the CongoMay 3, 1997
Republic of the
CongoJune 7, 1997
Sierra LeoneMay 28, 1997
TajikistanNovember 26, 1997
Tax Year 1998-
Date of Departure
Country On or After
AlbaniaAugust 14, 1998
Democratic Republic
of the CongoAugust 5, 1998
EritreaJune 5, 1998
Guinea-BissauJune 10, 1998
IndonesiaMay 15, 1998
PakistanAugust 16, 1998
Sierra LeoneDecember 23, 1998
Serbia-
MontenegroOctober 11, 1998
Tax Year 1999-
Date of Departure
CountryOn or After
EritreaFebruary 12, 1999
EthiopiaFebruary 12, 1999
Serbia-
MontenegroMarch 20, 1999
SEC. 3. INQUIRIES
A taxpayer who needs assistance on
how to claim this exclusion, or on how to
file an amended return, should contact a
local IRS Office or, for a taxpayer resid-
ing or traveling outside the United States,
the nearest overseas IRS office.
SEC. 4. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2000–14, 2000–18 I.R.B.
960, is supplemented.
DRAFTING INFORMATION
The principal author of this revenue
procedure is Kate Y. Hwa of the Office of
Associate Chief Counsel (International).
For further information regarding this
revenue procedure, contact Ms. Hwa at
(202) 622-3840 (not a toll-free call).
26 CFR 601.201: Rulings and determination
letters.
(Also Part I, sections 38, 61, 162, 167, 467; 1.61–1,
1.162–1, 1.167(a)–1, 1.467–3.)
Rev. Proc. 2001–28
SECTION 1. PURPOSE
This revenue procedure provides
guidelines that the Internal Revenue Ser-
May 7, 200111562001–19 I.R.B.

vice will use for advance ruling purposes
in determining whether certain transac-
tions purporting to be leases of property
are, in fact, leases for federal income tax
purposes. This revenue procedure modi-
fies and supersedes Rev. Proc. 75–21,
1975–1 C.B. 715. Rev. Proc. 2001–29,
2001–19 I.R.B. 1160, sets forth the infor-
mation and representations required to be
furnished by taxpayers in requests for ad-
vance rulings on leveraged lease transac-
tions within the meaning of this revenue
procedure.
SECTION 2. BACKGROUND
Section 4.01 of Rev. Rul. 55–540,
1955–2 C.B. 39, sets forth certain condi-
tions that, in the absence of compelling
factors of contrary implication, would
warrant treatment of a transaction for fed-
eral income tax purposes as a conditional
sales contract rather than a lease of equip-
ment. See Rev. Rul. 55–541, 1955–2
C.B. 19; Rev. Rul. 55–542, 1955–2 C.B.
59; and Rev. Rul. 57–371, 1957–2 C.B.
214, for examples of transactions deter-
mined to be sales rather than leases. See
Rev. Rul. 60–122, 1960–1 C.B. 56, for
two transactions, one considered a lease
and the other considered a sale. See also
Rev. Rul. 72–408, 1972–2 C.B. 86, con-
cerning the federal income tax conse-
quences of a transaction cast in the form
of a lease subsequently determined to be a
sale.
SECTION 3. SCOPE
This revenue procedure applies in the
case of transactions commonly called
“leveraged leases.” Such leases gener-
ally involve three parties: a lessor, a
lessee and a lender to the lessor. In gen-
eral, these leases are net leases, the lease
term covers a substantial part of the useful
life of the leased property, and the lessee’s
payments to the lessor are sufficient to
discharge the lessor’s payments to the
lender.
The guidelines set forth in this revenue
procedure clarify the circumstances in
which an advance ruling recognizing the
existence of a lease ordinarily will be is-
sued solely to assist taxpayers in prepar-
ing ruling requests and the Service in is-
suing advance ruling letters as promptly
as practicable. These guidelines do not
define, as a matter of law, whether a trans-
action is or is not a lease for federal in-
come tax purposes and are not intended to
be used for audit purposes.
SECTION 4. GUIDELINES
Unless other facts and circumstances
indicate a contrary intent, for advance rul-
ing purposes only, the Service will con-
sider the lessor in a leveraged lease trans-
action to be the owner of the property and
the transaction a valid lease if all the
guidelines described below are met. If all
of these guidelines are not met, the Ser-
vice nevertheless will consider ruling in
appropriate cases on the basis of all the
facts and circumstances.
.01Minimum unconditional “at risk”
investment
The lessor must have made a minimum
unconditional “at risk” investment in the
property (the “Minimum Investment”)
when the lease begins, must maintain such
Minimum Investment throughout the en-
tire lease term, and such Minimum Invest-
ment must remain at the end of the lease
term. The Minimum Investment must be
an equity investment (the “Equity Invest-
ment”) that, for purposes of this revenue
procedure, includes only consideration
paid, and personal liability incurred, by the
lessor to purchase the property. The net
worth of the lessor must be sufficient to
satisfy any such personal liability. In de-
termining the lessor’s Minimum Invest-
ment, the following rules will be applied:
(1)Initial Minimum Investment.
When the property is first placed in ser-
vice or use by the lessee, the Minimum
Investment must be equal to at least 20
percent of the cost of the property. The
Minimum Investment must be uncondi-
tional. That is, after the property is first
placed in service or use by the lessee, the
lessor must not be entitled to a return of
any portion of the Minimum Investment
through any arrangement, directly or indi-
rectly, with the lessee, a shareholder of
the lessee, or any party related to the
lessee (within the meaning of § 318 of the
Internal Revenue Code) (the “Lessee
Group”). The lease transaction may in-
clude an arrangement with someone other
than the foregoing parties that provides
for such a return to the lessor if the prop-
erty fails to satisfy written specifications
for the supply, construction, or manufac-
ture of the property.
(2)Maintenance of Minimum In-
vestment.The Minimum Investment must
remain equal to at least 20 percent of the
cost of the property at all times through-
out the entire lease term. That is, the ex-
cess of the cumulative payments required
to have been paid by the lessee to or for
the lessor over the cumulative disburse-
ments required to have been paid by or for
the lessor in connection with the owner-
ship of the property must never exceed
the sum of (i) any excess of the lessor’s
initial Equity Investment over 20 percent
of the cost of the property plus (ii) the cu-
mulative pro rataportion of the projected
profit from the transaction (exclusive of
tax benefits).
(3)Residual Investment.The
lessor must represent and demonstrate
that an amount equal to at least 20 percent
of the original cost of the property is a
reasonable estimate of what the fair mar-
ket value of the property will be at the end
of the lease term. For this purpose, fair
market value must be determined (i) with-
out including in such value any increase
or decrease for inflation or deflation dur-
ing the lease term, and (ii) after subtract-
ing from such value any cost to the lessor
for removal and delivery of possession of
the property to the lessor at the end of the
lease term. In addition, the lessor must
represent and demonstrate that a remain-
ing useful life of the longer of one year or
20 percent of the originally estimated use-
ful life of the property is a reasonable esti-
mate of what the remaining useful life of
the property will be at the end of the lease
term.
.02Lease Term and Renewal Options
For purposes of this revenue procedure,
the lease term includes all renewal or ex-
tension periods except renewals or exten-
sions at the option of the lessee at fair
rental value at the time of such renewal or
extension.
.03Purchase and Sale Rights
No member of the Lessee Group may
have a contractual right to purchase the
property from the lessor at a price less
than its fair market value at the time the
right is exercised. When the property is
first placed in service or use by the lessee,
the lessor may not have a contractual right
(except as provided in section 4.01(1)
above) to cause any party to purchase the
property. The lessor must also represent
that it does not have any present intention
to acquire such a contractual right. The
effect of any such right acquired at a sub-
2001–19 I.R.B.1157May 7, 2001

sequent time will be determined at that
time based on all the facts and circum-
stances. A provision that permits the
lessor to abandon the property to any
party will be treated as a contractual right
of the lessor to cause such party to pur-
chase the property.
.04Investment by Lessee
(1) Permitted Investments. Except
as otherwise specifically provided in
paragraphs (2) and (3) below, no part of
the cost of the property or the cost of im-
provements, modifications, or additions
to the property (“Improvements”), may be
furnished by any member of the Lessee
Group. Property that could itself be sepa-
rately leased in a transaction eligible for
an advance ruling under this revenue pro-
cedure does not constitute an Improve-
ment. For example, assume Xleases a
chemical plant from Y. Assume further,
that after the plant is placed in service, X
wishes to erect and own additional tanks
that will be used to store the output of the
plant. Although the tanks will be used in
conjunction with X’s plant, they constitute
separate items of property that could be
used in conjunction with other facilities
and therefore do not constitute limited use
property under section 5.02 of this rev-
enue procedure. If a third party owned
the tanks, it could lease them to Xin a
transaction eligible for an advance ruling.
Thus, the tanks do not constitute an Im-
provement.
(2)Severable Improvements. A
member of the Lessee Group may furnish
amounts to pay for the cost of an Im-
provement that is owned by a member of
the Lessee Group, and is readily remov-
able without causing material damage to
the leased property (“Severable Improve-
ment”), provided that such Improvement
is not subject to a contract or option for
purchase or sale between the lessor and
any member of the Lessee Group at a
price other than fair market value at the
time of such purchase or sale. At the
commencement of the term of the lease, a
Severable Improvement to the leased
property must not be required in order to
render the leased property complete for its
intended use by the lessee. However,
property will be considered to be com-
plete even though the lessee may add as
Severable Improvements ancillary items
of equipment of a kind that customarily
are selected and furnished by purchasers
or lessees of property of the kind subject
to the lease. Thus, for example, to the ex-
tent an item of equipment such as the
boiler for a leased, steam powered vessel
otherwise constituted a Severable Im-
provement, the vessel would not, for pur-
poses of this section, be considered com-
plete without the boiler. On the other
hand, a leased airplane would be consid-
ered complete without items of equipment
such as aviation electronics and a leased
vessel would be considered complete
without such ancillary items such as
radar, lines, or readily removable fittings,
and will be eligible for an advance ruling
even though such items of equipment are
to be added by the lessee.
(3)Nonseverable Improvements.
A member of the Lessee Group may fur-
nish amounts to pay for the cost of Im-
provements that are not readily removable
without causing material damage to the
property (“Nonseverable Improvements”)
if they are described in subparagraph (a)
below and the conditions of subparagraph
(b) are met.
(a) A Nonseverable Improve-
ment is described in this subparagraph if
either:
(i) it is furnished in order
to comply with health, safety, or environ-
mental standards of any government or
governmental authority having relevant
jurisdiction (or any industry-wide stan-
dard recognized by such government or
governmental authority);
(ii) it does not increase
the productivity (or capacity) of the
leased property to more than 125 percent
of its productivity (or capacity) when first
placed in service, or modify the leased
property for a materially different use.
For this purpose, separate units that are
subject to one lease (e.g., ten boxcars sub-
ject to one lease) are each considered “the
leased property;” or
(iii) the cost of the Non-
severable Improvement, when added to
the cost of Nonseverable Improvements
that previously have been made to the
property (other than those described in
subparagraph (i) above) does not exceed
10 percent of the cost of the property. For
purposes of this subparagraph, the cost of
a Nonseverable Improvement will be con-
sidered to be the actual cost multiplied by
a fraction, the numerator of which is the
Implicit Price Deflator for Fixed Nonresi-
dential Investment (published by the De-
partment of Commerce in the Survey of
Current Business) for the year in which
the property was placed in service, and
the denominator of which is the Implicit
Price Deflator for Fixed Nonresidential
Investment for the year in which the Im-
provement is made. As indicated in sec-
tion 4.04(5) of this revenue procedure, or-
dinary maintenance and repair does not
constitute an Improvement.
(b) The following conditions
must be satisfied:
(i) At the commencement
of the term of the lease, a Nonseverable
Improvement must not be required in
order to complete the property for its in-
tended use by the lessee;
(ii) The Nonseverable Im-
provement must not cause the leased
property to become limited use property
within the meaning of section 5.02 of this
revenue procedure; and
(iii) The furnishing of the
cost of the Nonseverable Improvement
must not constitute an equity investment
by a member of the Lessee Group in the
property. For this purpose, the lessee’s
right to use the Improvement during the
lease term in which such improvement is
made does not constitute an equity in-
vestment in the property. The furnishing
of such cost will be considered an equity
investment in the property if a member
of the Lessee Group may receive com-
pensation, directly or indirectly, for its
interest in such Nonseverable Improve-
ment. A member of the Lessee Group
will be regarded as having made an eq-
uity investment in the property if, for ex-
ample:
– the lessor is obligated to pur-
chase the Nonseverable Improvement or
reimburse a member of the Lessee Group
for the cost or the fair market value of the
Nonseverable Improvement;
– any option price or renewal
rental rate to a member of the Lessee
Group is adjusted downward to reflect
any portion of the cost or fair market
value of the Nonseverable Improvement;
or
– the lessor is obligated to share
with a member of the Lessee Group a por-
tion of the proceeds of any sale or lease of
the property to a third party.
(4) Cost Overruns and Modifica-
tions. If the cost of property exceeds the
May 7, 200111582001–19 I.R.B.

estimate on which the lease was based,
the lease may provide for adjustments of
rent to compensate the lessor for such ad-
ditional cost.
(5) Maintenance and Repair. If
the lease requires the lessee to maintain
and keep the property in good repair dur-
ing the term of the lease, ordinary mainte-
nance and repairs performed by a member
of the Lessee Group will not constitute an
Improvement.
.05No Lessee Loans or Guarantees
No member of the Lessee Group may
lend to the lessor any of the funds neces-
sary to acquire the property, or guarantee
any indebtedness created in connection
with the acquisition of the property by the
lessor. A guarantee by any member of the
Lessee Group of the lessee’s obligation to
pay rent, properly maintain the property,
or pay insurance premiums or other simi-
lar conventional obligations of a net lease
does not constitute a guarantee of the in-
debtedness of the lessor.
.06Profit Requirement
The lessor must represent and demon-
strate that it expects to receive a profit
from the transaction, apart from the value
of or benefits obtained from the tax de-
ductions, allowances, credits, and other
tax attributes arising from such transac-
tion. This requirement is met if:
(1)Overall Profit. The aggregate
amount required to be paid by the lessee to
or for the lessor over the lease term plus
the value of the residual investment re-
ferred to in section 4.01(3) of this revenue
procedure exceed an amount equal to the
sum of the aggregate disbursements re-
quired to be paid by or for the lessor in
connection with the ownership of the prop-
erty and the lessor’s Equity Investment in
the property, including any direct costs to
finance the Equity Investment; and
(2) Positive Cash Flow. The ag-
gregate amount required to be paid to or
for the lessor over the lease term exceeds
by a reasonable amount the aggregate dis-
bursements required to be paid by or for
the lessor in connection with the owner-
ship of the property.
SECTION 5. OTHER
CONSIDERATIONS
.01Uneven Rent Test. Leveraged lease
transactions that satisfy the guidelines set
forth in section 4 of this revenue proce-
dure and that contain uneven rent pay-
ments may be subject to § 467 and the
regulations thereunder relating to the ac-
counting treatment for certain leases with
prepaid or deferred rent. In addition,
§ 1.467–3(c)(4) of the Income Tax Regu-
lations provides an uneven rent test. A
lease meeting this uneven rent test will
not be treated as a disqualified leaseback
or long-term agreement for purposes of
§ 467. How the lease is treated under
§ 467, including whether or not the un-
even rent test of § 1.467–3(c)(4) is met,
will not affect the ability of a taxpayer to
obtain an advance ruling under this rev-
enue procedure.
.02Limited Use Property.
(1) In General. Section 4.01(3) of this
revenue procedure requires the lessor to
represent and demonstrate certain facts
relating to the estimated fair market value
and estimated remaining useful life of the
property at the end of the lease term. This
requirement is intended, in part, to assure
that the purported lessor has not trans-
ferred the use of the property to the pur-
ported lessee for substantially its entire
useful life. In the case of such “limited
use” property, at the end of the lease term
there will probably be no potential lessees
or buyers other than members of the
Lessee Group. As a result, the lessor of
limited use property will probably sell or
rent the property to a member of the
Lessee Group, thus enabling the Lessee
Group to enjoy the benefits of the use or
ownership of the property for substan-
tially its entire useful life. See Rev. Rul.
55–541, 1955–2 C.B. 19, for an example
of a transaction in which property was de-
termined to be leased for substantially its
entire useful life and the conclusion that
such a transaction transfers equitable
ownership. Accordingly, the Service will
not issue advance rulings concerning
whether certain transactions purporting to
be leases of property are, in fact, leases
for federal income tax purposes when the
property is limited use property.
(2)Examples. The following exam-
ples illustrate the types of property the
Service considers to be limited use prop-
erty, and the types of property the Service
does not consider to be limited use prop-
erty.
(a) X builds a masonry smoke-
stack attached to a masonry warehouse
building owned by Y, and leases the
smokestack to Y for use as an addition to
the heating system of the warehouse. The
lease term is 15 years; the smokestack has
a useful life of 25 years, and the ware-
house has a remaining useful life of 25
years. It would not be commercially fea-
sible to disassemble the smokestack at the
end of the lease term and reconstruct it at
a new location. The smokestack is con-
sidered to be limited use property.
(b) X builds a complete chemical
production facility on land owned by Y
and leases the facility to Y, a manufac-
turer of chemicals. The lease term is 24
years, and the facility has a useful life of
30 years. The land is leased to X pursuant
to a ground lease for a term of 30 years.
The technical “know-how” and trade se-
crets Y possesses are necessary elements
in the commercial operation of the facil-
ity. At the time the lease is entered into,
no person who is not a member of the
lessee group possesses the technical
“know-how” and trade secrets necessary
for the commercial operation of the facil-
ity. The taxpayers submit to the Service
the written opinion of a qualified expert
stating it is probable that by the expiration
of the lease term of the facility third par-
ties who are potential purchasers or
lessees of the facility will have indepen-
dently developed such “know-how” and
trade secrets. The facility is considered to
be limited use property. In reaching this
conclusion, the Service will not take into
account such expert opinion because such
opinions are too speculative for advance
ruling purposes.
(c) The facts are the same as in
example (b) except X has an option, exer-
cisable at the end of the lease term of the
facility, to purchase from Y the “know-
how” and trade secrets necessary for the
commercial operation of the facility, and
it would be commercially feasible at the
end of such lease term for X to exercise
the option and operate the facility itself.
The facility is not considered to be limited
use property.
(d) The facts are the same as in ex-
ample (b) except it would be commercially
feasible for the lessor at the end of the
lease term to make certain structural modi-
fications of the facility that would make
the facility capable of being used by per-
sons not possessing any special technical
“know-how” or trade secrets. Further-
more, if such modifications were made, it
would be commercially feasible, at the end
2001–19 I.R.B.1159May 7, 2001

of the lease term, for a person who is not a
member of the lessee group to purchase or
lease the facility from X. The facility is not
considered to be limited use property.
(e) X builds an electrical generat-
ing plant on land owned by Y and leases
the plant to Y. The lease term is 40 years,
and the plant has an estimated useful life
of 50 years. The land is leased to X pur-
suant to a ground lease for a term of 50
years. The plant is adjacent to a fuel
source that it is estimated will last for at
least 50 years. Access to this fuel source
is necessary for the commercial operation
of the plant, and Y has recently obtained
the contractual right to acquire all fuel
produced from the source for 50 years. Y
will use the plant to produce and generate
electrical power for sale to a city located
500 miles away. The plant is synchro-
nized into a power grid that makes the
sale of electrical power to a number of po-
tential markets commercially feasible. It
would not be commercially feasible to
disassemble the plant and reconstruct it at
a new location. The electrical generating
plant is considered to be limited use prop-
erty because access to the fuel source held
exclusively by Y is necessary for the com-
mercial operation of the plant.
(f) The facts are the same as in
example (e) except X has an option, exer-
cisable at the end of the lease term of the
plant, to acquire from Y the contractual
right to acquire all fuel produced from the
fuel source for the 10-year period com-
mencing at the end of such lease term. It
would be commercially feasible at the end
of such lease term for X to exercise this
option. Furthermore, it would be com-
mercially feasible, at the end of such lease
term, for a person who is not a member of
the lessee group to purchase the contrac-
tual right to the fuel from X for an amount
equal to the option price and purchase or
lease the plant from X. The plant is not
considered to be limited use property.
SECTION 6. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 75–21, 1975–1 C.B. 715,
Rev. Proc. 76–30, 1976–2 C.B. 647, and
Rev. Proc. 79–48, 1979–2 C.B. 529, are
modified and, as modified, are superseded.
SECTION 7. EFFECTIVE DATE
This revenue procedure is effective
May 7, 2001.
SECTION 8. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Edward Schwartz of the Of-
fice of Associate Chief Counsel (Income
Tax and Accounting). For further infor-
mation regarding this revenue procedure,
contact Mr. Schwartz at (202) 622-4960
(not a toll-free call).
26 CFR 601.201: Rulings and determination
letters.
(Also Part I, sections 38, 61, 162, 167, 467; 1.61–1,
1.162–1, 1.167(a)–1, 1.467–3.)
Rev. Proc. 2001–29
SECTION 1. PURPOSE
This revenue procedure sets forth the
information and representations required
to be furnished by taxpayers in requests
for advance rulings on leveraged lease
transactions within the meaning of Rev.
Proc. 2001–28, 2001–19 I.R.B. 1156.
Rev. Proc. 2001–28 provides guidelines
to be used for advance ruling purposes in
determining whether such a transaction is,
in fact, a valid lease for federal income
tax purposes. The specific terms used in
this revenue procedure are defined in Rev.
Proc. 2001–28.
SECTION 2. BACKGROUND
.01 The checklist set forth in this rev-
enue procedure is designed to ensure the
inclusion and order of presentation of
necessary information in the initial ruling
request so that the Internal Revenue Ser-
vice can more promptly and efficiently
process the request. However, since the
information necessary for the issuance of
a ruling with regard to any particular
transaction depends upon all the facts and
circumstances of that case, information in
addition to that outlined in the checklist
may be required with respect to that trans-
action.
.02 In view of the complexity of a typ-
ical leveraged lease transaction and the
voluminous nature of the related docu-
mentation, the Service cannot accept the
responsibility for raising or considering
issues arising out of such provisions that
are not specifically brought to its atten-
tion.
SECTION 3. GENERAL
REQUIREMENTS
.01 The lessor, the lessee, and any other
party with an interest in the leasing trans-
action for which a specific ruling is re-
quested must join in the ruling request.
.02 The ruling request must include a
summary statement of the facts as de-
scribed in section 8 of Rev. Proc. 2001–1,
2001–1 I.R.B. 1 (or its successor).
.03 In addition to the information and
documents required by section 8 of Rev.
Proc. 2001–1, the ruling request must in-
clude detailed information required by
section 4 of this revenue procedure. If the
information requested is not applicable to
the parties or to the transaction, an ex-
press statement to that effect is required.
The response to each item of information
requested must include a reference to the
page number of any relevant document
containing the information that supports
the response. Furthermore, portions of
the relevant documents supporting a par-
ticular response should be underscored or
otherwise highlighted and cross-refer-
enced to the appropriate subsection of
section 4 of this revenue procedure. All
parties joining in the request for ruling are
jointly responsible for responses to each
item of information requested by section
4 of this revenue procedure, with the ex-
ception of section 4.02 for which only the
lessor is responsible.
.04 The lessor must also submit copies
of any offering circular, prospectus, eco-
nomic analysis, or other document used to
induce the lessor’s investment in the
leased property (the “Property”). These
documents must include an analysis of the
projected cash flow to the lessor from the
lease transaction including the projected
benefits from the tax attributes thereof.
SECTION 4. SPECIFIC
INFORMATION REQUIRED
.01In general
(1) Describe in detail the type and
quantity of the Property.
(2) Identify and describe all par-
ties to the leveraged lease transaction,
their respective interests in such transac-
tion, and the relationships that exist
between or among such parties.
(3) Submit a diagram of the trans-
action showing (a) the parties to the trans-
action, (b) the succession of ownership to
May 7, 200111602001–19 I.R.B.

the Property, and (c) the source, amounts,
and flow of the funds used to acquire the
Property (total acquisition cost within the
meaning of § 1012 of the Internal Rev-
enue Code).
(4) Indicate whether the Property
is to be temporarily or permanently af-
fixed to or installed on or in land, build-
ings, or other property. If so, indicate
who will own such land, buildings, or
other property.
(5) Indicate whether the Property
is new, reconstructed, used, or rebuilt.
(See§§ 1.48–2 and 1.48–3 of the Income
Tax Regulations; Rev. Rul. 68–111,
1968–1 C.B. 29; and Rev. Rul. 70–135,
1970–1 C.B. 10.)
(6) Indicate when, where, and
how the Property will be, or has been,
first placed in service or use.
.02Minimum Unconditional At Risk In-
vestment
The lessor must:
(1) Indicate the total acquisition
cost (within the meaning of § 1012) of the
Property.
(2) Indicate when and in what
amounts the lessor did or will make its
Equity Investment or incur personal lia-
bility for such Equity Investment.
(3) Indicate the conditions under
which the lessor would be entitled to a re-
turn of any portion of its Equity Invest-
ment or would be released from any
personal liability for such Equity Invest-
ment.
(4) Submit a representation of the
net worth of the lessor and financial data
to support the representation, including,
for example, audited balance sheets
or unaudited balance sheets with a repre-
sentation that the latter are prepared in ac-
cordance with generally accepted ac-
counting principles.
(5) Submit an analysis demon-
strating that the lessor’s Equity Invest-
ment will remain equal to at least 20 per-
cent of the cost of the Property at all times
throughout the lease term. This analysis
must demonstrate that throughout the
lease term the items designated as (a), (b),
(c), and (d) below solve the formula “(a)-
(b) never exceeds (c) + (d).”
(a) The projected cumulative
payments required to be paid by the lessee
to or for the lessor.
(b) The projected cumulative
disbursements required to be paid by or
for the lessor in connection with the own-
ership of the Property, excluding the
lessor’s initial Equity Investment, but
including any direct costs to finance the
Equity Investment.
(c) The excess of the lessor’s
initial Equity Investment over 20 percent
of the cost of the Property.
(d) A cumulative pro ratapor-
tion of the projected profits from the
transaction (exclusive of tax benefits).
Profit for this purpose is the excess of the
sum of (i) the amounts required to be paid
by the lessee to or for the lessor over the
lease term plus (ii) the value of the resid-
ual investment referred to in section
4.01(3) of Rev. Proc. 2001–28, over the
aggregate disbursements required to be
paid by or for the lessor in connection
with the ownership of the Property,
including the lessor’s initial Equity
Investment and any direct costs to finance
the Equity Investment.
(6) Furnish an opinion, from a
qualified expert who has professional
knowledge of the type of property sub-
ject to the lease, regarding:
(a) the fair market value of the
Property at the end of the lease term,
determined in accordance with section
4.01(3) of Rev. Proc. 2001–28, and the
manner in which such fair market value
was determined;
(b) the cost to the lessor, if any,
of the removal and delivery of possession
of the Property to the lessor at the end of
the lease term; and
(c) the remaining useful life of
the Property at the end of the lease term,
and the manner in which such useful life
was determined.
.03Lease Term and Renewal Options
Indicate the period for which the Prop-
erty will be leased initially, if there are any
provisions for the renewal or extension of
such period, and, if so, on what terms.
.04Purchase and Sale Rights
(1) Indicate whether any mem-
ber of the Lessee Group or any other party
has a contractual obligation or right to
purchase all or any part of the Property at
any time, and, if so, when, under what
conditions, and at what price.
(2) Indicate whether the lessor
or any other party has a contractual right
to cause any party to purchase the
Property, and if so, when and under what
conditions.
(3) Indicate whether the lessor,
a shareholder of the lessor, or a party
related to the lessor (within the meaning
of § 318), or any other party who has
joined in the request for a ruling has any
present intention to acquire a contractual
right to cause any party to purchase or sell
the Property, and, if so, when and under
what conditions.
(4) Indicate whether the lessor
may abandon the Property to any party at
any time, and if so, when, to whom, and
under what conditions.
.05No Investment by Lessee
(1) Indicate whether any mem-
ber of the Lessee Group may be required
to furnish any part of the cost of the
Property, and if so, when and under what
conditions.
(2) Submit a representation that
at the commencement of the term of the
lease neither a Nonseverable Improve-
ment, nor a Severable Improvepment
(other than a Severable Improvement of a
kind customarily furnished by purchasers
or lessees of property of the kind subject
to the lease) is required in order to com-
plete the property for its intended use by
the lessee.
(3) If Severable Improvements
may be made to the Property, indicate
who will own the Severable Improve-
ments and identify the parties who will
provide the funds necessary to purchase
them.
(4) Indicate whether any Sev-
erable Improvement is to be the subject of
a contract or option for purchase or sale,
and if so, describe the contract or option
terms.
(5) If Nonseverable Improve-
ments may be made to the Property, iden-
tify the parties who will provide the funds
necessary to purchase them.
(6) Indicate whether a member
of the Lessee Group may receive compen-
sation, directly or indirectly, for its inter-
est in any Nonseverable Improvement.
(7) Indicate whether the lease
states that the addition of any Nonseverable
Improvement will not cause the Property to
become limited use property.
(8) Indicate whether a member
of the Lessee Group may provide the cost
of a Nonseverable Improvement that is
not described in one of the subparagraphs
of section 4.04(3)(a) of Rev. Proc.
2001–28.
2001–19 I.R.B.1161May 7, 2001

(9) Indicate whether the lease
(or any document or other agreement)
requires a member of the Lessee Group
either to make a specific Nonseverable
Improvement, or to make Nonseverable
Improvements of a specific value or min-
imum value.
(10) Indicate whether the trans-
action contains any cost overrun provi-
sions, who must pay the cost overrun, and
whether the lease provides for an adjust-
ment to rents to compensate the lessor for
any additional cost incurred because of
cost overruns.
(11) If a member of the Lessee
Group may furnish amounts to pay for the
cost of a Nonseverable Improvement,
indicate which subparagraph of section
4.04(3)(a) of Rev. Proc. 2001–28
describes the Nonseverable Improvement.
.06No Lessee Loans or Guarantees
(1) Indicate whether any mem-
ber of the Lessee Group will guarantee an
indebtedness incurred in connection with
the acquisition of the Property by the
lessor and, if so, under what terms and
conditions.
(2) Indicate whether any mem-
ber of the Lessee Group directly or indi-
rectly made or will make any other guar-
antees as a part or result of the lease
transaction. If so, describe such guaran-
tees.
.07Profit Requirement
(1) Submit an analysis demon-
strating that the lessor will receive a prof-
it from the transaction exclusive of bene-
fits from the tax attributes thereof. This
analysis should demonstrate that the items
identified as (a), (b), and (c) below will
solve the formula “(a) + (b) exceed (c).’’
(a) The projected aggregate
payments required to be paid by the lessee
to or for the lessor over the lease term.
(b) The value of the residual
investment described in section 4.01(3) of
Rev. Proc. 2001–28.
(c) The projected sum of the
aggregate disbursements required to be
paid by or for the lessor in connection
with the ownership of the Property,
including the lessor’s initial Equity
Investment, and any direct costs to
finance the Equity Investment.
(2) Submit an analysis demon-
strating that the lessor will have a project-
ed positive cash flow from the lease trans-
action. This analysis must contain the
following information in order to demon-
strate that the items identified as (a) and
(b) will solve the formula “(a) exceeds (b)
by a reasonable minimum amount.”
(a) The projected aggregate
payments required to be paid by the lessee
to or for the lessor over the lease term.
(b) The projected aggregate dis-
bursements required to be paid by or for
the lessor in connection with the owner-
ship of the Property, excluding the
lessor’s initial Equity Investment, but
including any direct costs to finance the
Equity Investment.
.08 Other Considerations: Limited
Use Property
(1) Indicate whether the
Property is expected to be useful or usable
by the lessor at the end of the lease term
and capable of continued leasing or trans-
fer to any party. If such a representation
is made, demonstrate its commercial fea-
sibility.
(2) Indicate whether the Prop-
erty would be useful or usable at the end
of the lease term by a party other than a
member of the Lessee Group, and if so,
describe such use.
(3) Indicate whether the
Property needs to be dismantled, discon-
nected, or removed from any site on
which it was placed or installed in order
for possession thereof to be returned to
the lessor at the end of the lease term. If
so:
(a) Indicate whether and how
such dismantling, disconnection, or
removal will affect the value of the
Property for the purpose for which it was
originally intended to be used, and
(b) Demonstrate the commer-
cial feasibility of reassembling, recon-
necting, or installing the Property at
another location.
.09Other
(1) Set forth the details of the
repayment of the portion of the total
acquisition cost borrowed by the lessor
(debt service), including an analysis of the
anticipated repayment of principal and
interest on such debt by the lessor.
(2) List and explain all provi-
sions of the lease transaction relating to
indemnities, termination, obsolescence,
casualty, stipulated casualty value, and
insurance.
(3) State that if the Service
rules that the lessor is the owner of the
Property for federal income tax purposes
at the time that the Property is first placed
in service or use, the lessee will not claim
that it is such an owner at such time.
SECTION 5. OTHER INSTRUCTIONS
Documents that have been submitted
with the request for an advance ruling
may, as indicated below, be amended by
the parties, prior to the date on which the
Property is first placed in service or use.
A complete explanation of the changes
must be submitted together with specific
references to both the original and
amended documents. If, as a result of the
amended documents, the responses re-
quired by section 4 of this revenue proce-
dure are modified, the revised responses
must be brought to the attention of the
Service in such a fashion as to be readily
understandable. In situations where the
transaction is materially revised by the
amendments, the original request for ad-
vance ruling, together with all submis-
sions including the amended documents,
will be considered by the Service to be a
new request for advance ruling received
on the date that it receives the amended
documents. The Service ordinarily will
not rule on the consequences of a pro-
posed amendment that purports to relate
back to the time when the Property was
first placed in service, or purports to af-
fect the issue of the ownership of the
Property at that time.
SECTION 6. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 75–28, 1975–1 C.B. 752,
and Rev. Proc. 79–48, 1979–2 C.B. 529,
are modified, and as modified, are super-
seded.
SECTION 7. PAPERWORK
REDUCTION ACT
The collections of information con-
tained in this revenue procedure have
been reviewed and approved by the Of-
fice of Management and Budget (OMB)
in accordance with the Paperwork Reduc-
tion Act (44 U.S.C. § 3507) under control
number 1545–1738.
An agency may not conduct or sponsor,
and a person is not required to respond to,
a collection of information unless the col-
lection of information displays a valid
OMB control number.
May 7, 200111622001–19 I.R.B.

The collection of information is con-
tained in section 4 of this revenue proce-
dure. This information is required to es-
tablish the economic substance of the
transaction and its bona fidesas a true
lease. The likely respondents are individ-
ual taxpayers and corporations.
The estimated total annual reporting
burden is 800 hours.
The estimated annual burden per respon-
dent will vary from 60 hours to 100 hours,
depending on individual circumstances,
with an estimated average of 80 hours. The
estimated number of respondents is 10.
The estimated annual frequency of re-
sponses is on occasion.
Books and 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
return information are confidential, as re-
quired by § 6103.
SECTION 8. EFFECTIVE DATE
This revenue procedure is effective
May 7, 2001.
SECTION 9. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Edward Schwartz of the Of-
fice of Associate Chief Counsel (Income
Tax and Accounting). For further infor-
mation regarding this revenue procedure,
contact Mr. Schwartz at (202) 622-4960
(not a toll-free call).
26 CFR 601.201: Rulings and determination
letters.
(Also Part I, § 29.)
Rev. Proc. 2001–30
SECTION 1. PURPOSE
This revenue procedure informs the
public of the Internal Revenue Service’s
decision to issue private letter rulings re-
garding whether a solid fuel produced
from coal is a qualified fuel under
§ 29(c)(1)(C) of the Internal Revenue
Code under the circumstances described
in section 3 of this revenue procedure.
SECTION 2. BACKGROUND
Section 2.01 of Rev. Proc. 2001–3,
2001–1 I.R.B. 111, provides that when-
ever appropriate in the interest of sound
tax administration, it is the policy of the
Service to answer inquiries of individuals
and organizations regarding their status
for tax purposes and the tax effects of
their acts or transactions, prior to the fil-
ing of returns or reports that are required
by the revenue laws. There are, however,
certain areas in which, because of the in-
herently factual nature of the problems in-
volved, or for other reasons, the Service
will not issue rulings or determination let-
ters.
Section 4 of Rev. Proc. 2001–3 sets
forth those areas in which rulings or de-
termination letters will not ordinarily be
issued. “Not ordinarily” means that
unique and compelling reasons must be
demonstrated to justify the issuance of a
ruling or determination letter. Section
2.01 of Rev. Proc. 2001–3.
Section 4.02(1) of Rev. Proc. 2001–3
provides that the Service will not ordinar-
ily issue rulings or determination letters
regarding any matter in which the deter-
mination requested is primarily one of
fact, for example, market value of prop-
erty, or whether an interest in a corpora-
tion is to be treated as stock or indebted-
ness.
Section 5 of Rev. Proc. 2001–3 sets
forth those areas under extensive study in
which rulings or determination letters will
not be issued until the Service resolves
the issue through publication of a revenue
ruling, revenue procedure, regulations, or
otherwise.
Section 5.01 of Rev. Proc. 2001–3 pro-
vides that the Service will not issue rul-
ings or determination letters on whether a
solid fuel other than coke or a fuel pro-
duced from waste coal is a qualified fuel
under § 29(c)(1)(C). Waste coal for this
purpose is limited to waste coal fines
from normal mining and crushing opera-
tions and does not include fines produced
(for example, by crushing run-of-mine
coal) for the purpose of claiming the
credit.
Section 5.01 of Rev. Proc. 2001–3 su-
persedes Rev. Proc. 2000–47, 2000–46
I.R.B. 482. Rev. Proc. 2000–47 was pub-
lished because concern had been raised
that taxpayers were claiming the § 29
credit for processing coal in ways that
may not have been intended by the Con-
gress. Rev. Proc. 2000–47 requested
comments concerning the standard to be
applied in determining whether fuel pro-
duced from coal is a solid synthetic fuel.
The Service received extensive com-
ments.
Section 29 provides a credit against in-
come tax for the production and sale of
“qualified fuels” produced from a non-
conventional source. Section 29(c)(1)(C)
provides that qualified fuels include liq-
uid, gaseous, or solid synthetic fuels pro-
duced from coal (including lignite).
Rev. Rul. 86–100, 1986–2 C.B. 3,
adopts for purposes of § 29(c)(1)(C) the
definition of synthetic fuel in
§ 1.48–9(c)(5) of the Income Tax Regula-
tions. Section 1.48–9(c)(5)(ii) provides
that, to be “synthetic,” a fuel must differ
significantly in chemical composition, as
opposed to physical composition, from
the substance used to produce it. Rev.
Rul. 86–100 describes favorably
processes such as gasification, liquefac-
tion, and production of solvent refined
coal that result in substantial chemical
changes to the entire coal feedstock rather
than changes that affect only the surface
of the coal.
Section 29(f) provides that § 29 applies
to qualified fuels that are produced in a
facility placed in service after December
31, 1979, and before January 1, 1993, and
that are sold before January 1, 2003. Sec-
tion 29(g)(1)(A) provides that a facility
for producing qualified fuels described in
§ 29(c)(1)(C) is treated for this purpose as
being placed in service before January 1,
1993, if the facility is placed in service
before July 1, 1998, pursuant to a binding
written contract in effect before January
1, 1997. For a facility that meets this con-
dition and is originally placed in service
after December 31, 1992, § 29(g)(1)(B)
provides that the § 29 credit applies to
qualified fuels that are sold before Janu-
ary 1, 2008.
Property is “placed in service” in the
taxable year the property is placed in a
condition or state of readiness and avail-
ability for a specifically assigned func-
tion. See, for example, § 1.167(a)
–11(e)(1)(i). Thus, the § 29 credit is not
allowed for fuel produced in a facility that
was originally placed in service for a
function other than producing qualified
fuel under § 29(c)(1)(C) and was not con-
2001–19 I.R.B.1163May 7, 2001

verted into a facility for producing quali-
fied fuel until after June 30, 1998.
The Service interprets § 29(f) and (g) to
allow the § 29 credit for qualified fuel
produced in a facility after its modifica-
tion only if the modification was placed in
service before July 1, 1998, or does not
significantly increase the production ca-
pacity of the facility or significantly ex-
tend the life of the facility. For example,
a facility (including one of multiple facili-
ties located at the same site) may be relo-
cated without affecting the availability of
the credit if all essential components of
the facility are retained and the produc-
tion capacity of the relocated facility is
not significantly increased at the new lo-
cation. If, however, the essential compo-
nents of a single facility are combined
after June 30, 1998, with other compo-
nents that were not part of the facility on
June 30, 1998, to create multiple facilities
or significantly increase production ca-
pacity, the credit will not be allowed for
fuel produced at any of those facilities.
After reviewing the comments received
in response to Rev. Proc. 2000–47 and re-
considering its interpretation of
§ 29(c)(1)(C), the Service has decided
that the significant chemical change stan-
dard of Rev. Rul. 86–100 is the correct
standard. The Service has also decided to
resume the issuance of rulings under
§ 29(c)(1)(C), but only in the circum-
stances described below.
The Service is willing to issue rulings
that do not go beyond the processes ap-
proved in the rulings issued prior to 2000.
One procedure common to all of those
processes (other than processes for the
production of coke and similar products)
is the use of elevated temperature and
pressure to produce briquettes, pellets, or
an extruded fuel product. The Service is
also willing to rule with respect to a
process that omits this procedure if the
process is otherwise consistent with a
process approved in a pre–2000 ruling
and the omission of the procedure will not
significantly increase the production out-
put of the facility. Accordingly, the Ser-
vice will issue rulings regarding whether
a solid fuel (other than coke) is a qualified
fuel under § 29(c)(1)(C) under the cir-
cumstances described in section 3 of this
revenue procedure.
SECTION 3. PROCEDURE
The Service will issue rulings that a
solid fuel (other than coke) produced
from coal is a qualified fuel under
§ 29(c)(1)(C) if the conditions set forth
below are satisfied and evidence is pre-
sented that all, or substantially all, of the
coal used as feedstock undergoes a signif-
icant chemical change. The conditions
are that:
1. The feedstock coal consists entirely
of coal fines or crushed coal comprised of
particles no larger than 1/8 inch;
2. The feedstock coal is thoroughly
mixed in a mixer: (a) with styrene or
other monomers following an acid bath,
(b) with quinoline (C
9
H
7
N) or other or-
ganic resin and left to cure for several
days, (c) with ultra heavy hydrocarbons,
or (d) with an aluminum and/or magne-
sium silicate binder following heating to a
minimum temperature of 500 degrees
Fahrenheit; and
3. The treated feedstock is subjected to
elevated temperature and pressure that re-
sults in briquettes, pellets, or an extruded
fuel product, or the taxpayer represents
that the omission of this procedure will
not significantly increase the production
output of the facility over the remainder
of the period during which the § 29 credit
is allowable.
SECTION 4. EFFECTIVE DATE
This revenue procedure applies to all
ruling requests, including any pending in
the national office and any submitted after
the date of publication of this revenue
procedure.
SECTION 5. EFFECT ON OTHER
DOCUMENTS
Section 5.01 of Rev. Proc. 2001–3 is
revoked.
DRAFTING INFORMATION
The principal author of this revenue
procedure is David McDonnell of the Of-
fice of Associate Chief Counsel
(Passthroughs and Special Industries).
Other personnel from the IRS and Trea-
sury participated in its development. For
further information regarding this revenue
procedure contact Mr. McDonnell at
(202) 622-3120 (not a toll-free call).
May 7, 200111642001–19 I.R.B.

Deletions From Cumulative List
of Organizations Contributions
to Which are Deductible Under
Section 170 of the Code
Announcement 2001–46
The names of organizations that no
longer qualify as organizations de-
scribed in section 170(c)(2) of the Inter-
nal Revenue Code of 1986 are listed
below.
Generally, the Service will not disal-
low deductions for contributions made
to a listed organization on or before the
date of announcement in the Internal
Revenue Bulletin that an organization
no longer qualifies. However, the Ser-
vice is not precluded from disallowing a
deduction for any contributions made
after an organization ceases to qualify
under section 170(c)(2) if the organiza-
tion has not timely filed a suit for de-
claratory judgment under section 7428
and if the contributor (1) had knowledge
of the revocation of the ruling or deter-
mination letter, (2) was aware that such
revocation was imminent, or (3) was in
part responsible for or was aware of the
activities or omissions of the organiza-
tion that brought about this revocation.
If on the other hand a suit for declara-
tory judgment has been timely filed,
contributions from individuals and orga-
nizations described in section 170(c)(2)
that are otherwise allowable will con-
tinue to be deductible. Protection under
section 7428(c) would begin on May 7,
2001, and would end on the date the
court first determines that the organiza-
tion is not described in section 170(c)(2)
as more particularly set forth in section
7428(c)(1). For individual contributors,
the maximum deduction protected is
$1,000, with a husband and wife treated
as one contributor. This benefit is not
extended to any individual, in whole or
in part, for the acts or omissions of the
organization that were the basis for re-
vocation.
American Heart Foundation
Ankeny, IA
Career Guidance Foundation
San Diego, CA
Foundations Status of Certain
Organizations
Announcement 2001–47
The following organizations have failed
to establish or have been unable to maintain
their status as public charities or as operat-
ing foundations. Accordingly, grantors and
contributors may not, after this date, rely on
previous rulings or designations in the Cu-
mulative List of Organizations (Publication
78), or on the presumption arising from the
filing of notices under section 508(b) of the
Code. This listing does notindicate that the
organizations have lost their status as orga-
nizations described in section 501(c)(3), eli-
gible to receive deductible contributions.
Former Public Charities.The following
organizations (which have been treated as
organizations that are not private founda-
tions described in section 509(a) of the
Code) are now classified as private foun-
dations:
1st North Carolina Artillery Battery A,
Conowingo, MD
Abe Lincoln’s America, Inc., Jasper, GA
Aids Victims Fund, Philadelphia, PA
All in the Family Group Associates, Inc.,
Philadelphia, PA
Alston Jennings Foundation, Inc.,
Little Rock, AR
Amateur Soccer Funding Association -
Fairborn, Fairborn, OH
American Friends of the China National
Symphony Orchestra, Inc., Olathe, KS
American Rehabilitation Services,
Butler, PA
Americans United to Help, Inc.,
Doylestown, PA
A M L Leukemia Foundation Trust,
Dunellen, NJ
Anabaptist Deaf Ministries,
Lancaster, PA
Animal Shelter & Welfare Society
NHHA, Inc., Hollywood, FL
Annie Sisk Memorial Educational Trust,
Park Hills, MO
Anodos Foundation, Cambria, CA
Association of Special People Inspired to
Riding Excellence, Inc.,
Philadelphia, PA
Atlanta’s Extended Family, Inc.,
Atlanta, GA
Autism Society Stanley County Housing
Corporation #2, Raleigh, NC
Autism Society Wake County Housing
Corporation #3, Raleigh, NC
Bertha B. Blair Telephone Founders
Association, Ephrata, PA
Bethlehem Townhouse I Resident
Association, Bethlehem, PA
Better Community Development
Corporation, Plano, TX
Big Ben Foundation, Inc.,
Bethlehem, PA
Brandywine Valley Quilters,
Concordville, PA
Bravo Dance, Wilkes-Barre, PA
Brentwood Economic Development
Corporation, Pittsburgh, PA
Brian Scott Belson Parenting Foundation,
Inc., Turnerville, NJ
Brotherhood 2, Inc., of Connecticut,
W. Haven, CT
Burn Institute, San Diego, CA
Butler Township Playground & Athletic
Assn., Drums, PA
Caldwell Community Mosque,
Caldwell, NJ
Canal Center Housing Rehabilitation
Corporation, Trenton, NJ
Caring Generations, Inc.,
East Orange, NJ
Cats Haven, Inc., Norristown, PA
Cedar Lake Association, Inc.,
Faribault, MN
Center for Accelerating Literacy, Inc.,
Syosset, NY
Center for Intelligence Studies, Inc.,
Alexandria, VA
Center for Responsible Government, Inc.,
Wilkes Barre, PA
Central Point Comets, Central Point, OR
Central Valley Charitable Foundation,
Visalia, CA
Chalk Hill Festival for the Performing
Arts, Inc., Pittsburgh, PA
Challah Fund, Inc., New Brunswick, NJ
Child Association of Nigeria
Corporation, Hackensack, NJ
Children for Change, Inc., Salem, OR
Children of Colors, Houston, TX
Childrens Museum of Centre County,
Inc., Lemont, PA
Choyce Foundation, Riverside, CA
Chrysalis of Western Pennsylvania,
Keene, NH
Clark Wildcats, Inc., Clark, NJ
Clay Ambulance Assoc., Lititz, PA
Coalition of Food Pantries for the
Hungry, Pittsburgh, PA
2001–19 I.R.B.1165May 7, 2001
Part IV. Items of General Interest

May 7, 200111662001–19 I.R.B.
Coastal Aquasytems, Depoe Bay, OR
Columbus PHA Communities United,
Columbus, OH
Committee for the Support of Inter
Seminaries for the Biblical Faith,
Philadelphia, PA
Community Child Health Foundation,
Denver, CO
Community Outreach & Vocational
Training Center, Inc., East Orange, NJ
Concerned Christian Men, Inc.,
Dayton, OH
Corry Kids Wrestling, Inc., Corry, PA
Cosmic Learning Center,
Philadelphia, PA
Creative Fund Raisers Corporation,
Las Vegas, NV
Critical Mass Media Corp., Boston, MA
CSTR Tax Research Institute,
Washington, DC
Dailey Care, Inc., Philadelphia, PA
David Coleman Firearms Freedom
Foundation, Stratham, NH
David Pegel Childrens Cancer Fund, Inc.,
Wycoff, NJ
Delaware Valley Siberian Huskey
Rescue, Inc., Horsham, PA
Della N. Landes Foundation Charitable
TR, Souderton, PA
Doctor Rex A. Patterson Foundation,
Greensburg, PA
Donald E. Farber Jr., Memorial
Charitable Trust, State College, PA
Eco Environment & Community
Organized, Inc., Ottsville, PA
Economic Revitalization Corporation of
Chester, Philadelphia, PA
Education Fund for Israel,
Philadelphia, PA
Educational and Health Care Services
Network, Inc., Philadelphia, PA
Edward A. Zabielski Jr. Foundation, Inc.,
Wilmington, DE
Emanuel Lutheran Development
Corporation, Pittsburgh, PA
Empower Network, Inc.,
State College, PA
Energy Education Foundation, Inc.,
Canton, GA
Eortc USA Foundation, Inc.,
Washington, DC
Eurolink Charities, Inc.,
La Jolla, CA
E X A M S, Inc., West Orange, NJ
Family and Youth Benefit of Idaho, Inc.,
McCall, ID
Family Bridges Advocacy & Resource
Services, Inc., Cleveland, OH
Family Endeavors Assisted Living, Inc.,
Library, PA
Farmington Valley Band, Collinsville, CT
Fibromyalgia Association of Greensburg
PA, Greensburg, PA
First Church Community Development
Corporation, Paterson, NJ
Fly Art Ltd., New York, NY
Food and Emotions Foundation,
Franklin, MI
Foundation, Highlands, NJ
Fredericksburg Area Library-Kathryn
Richard Memorial, Fredericksburg, PA
Free Enterprise Foundation,
Princeton, NJ
Free People, Washington, DC
Friends Bettering Independence,
McAdoo, PA
Friends of the Library of Mount Vernon
and Knox County, Mt. Vernon, OH
Friends of the New Jersey Motion Picture
and Television Comm, Inc.,
Fairlawn, NJ
Friends Who Care, Inc., Garfield, NJ
Garden State Discovery Museum Ctr. for
Learning, Cherry Hill, NJ
Glenside Green, Inc., Glenside, PA
Golden Years Retirement Association,
St. Louis, MO
Good Providers Child Care Alliance, Inc.,
Randallstown, MD
Gratitude House, Inc., Newton, NJ
Greater Naples Babe Ruth Baseball
League, Naples, FL
Greater New York Association of
Holocaust Survivors, Inc.,
Woodburgh, NY
Grove Tree-Man Trust, Inc.,
Coconut Grove, FL
Groveton Endowment Fund,
Groveton, NH
Guardians of Big Beaver, Darlington, PA
Gujarati Samaj of Greater Philadelphia,
Philadelphia, PA
Harrison Bmx Parents Association,
Harrison, OH
Heads on Straight Support Group,
Bensalem, PA
Health for Humanity, Houston, TX
Healthco, Inc., Berlin, NJ
Hearts for Jesus Ministries,
Vintondale, PA
Heartwood Bus, Inc., Pittsburgh, PA
Helena Housing Development
Corporation, Helena, MT
Hepatitis C Foundation, Warminster, PA
Holocaust Survivors of the Desert,
Cathedral City, CA
Homeless Animal Adoption League, Inc.,
Bloomfield, NJ
Homeless Enrichment Liaison Program,
Seattle, WA
Hope Prison Ministry, Inc.,
Schenectady, NY
ICA USA, London, England
Inclusion, Inc., Metuchen, NJ
Indian Cultural Center, Yardley, PA
Indiana Area School District Pigskin
Club, Indiana, PA
International Association for Breast
Ultrasound, Freiburg, Germany
International Society for Krishna
Consciousness of Center City, Inc.,
Philadelphia, PA
International Ukramdas Bhudardas Patel
Organization, North Bergen, NJ
Irish Famine Curriculum Foundation,
Nutley, NJ
Jade Fastpitch, Inc, Phoenixville, PA
Jerusalem Community Development
Corp., Wichita Falls, TX
John Woodward Memorial Foundation,
Inc., Huntington Valley, PA
Judees Place, Inc., Coatesville, PA
Juliet Chris Foundation, Inc.,
Trexlertown, PA
Just Say No, Richmond, VA
Juvenation, Collegeville, PA
K-9 Search & Rescue Specialists, Inc.,
Temple, GA
Kairos Institute, Madison, NJ
Kendleton Community Action Group,
Kendleton, TX
Kids & Momma Wonda Bookgee
Projects, Houston, TX
Kings Ferry Apartments Resident
Association, Inc., Philadelphia, PA
Korean Youth Cultural Organization,
Philadelphia, PA
Koz Research & Development Ltd.,
Radnor, PA
Lehighton Area Soccer Club,
Lehighton, PA
Lillye’s Net Work, Maxton, NC
Little Lamb Nursery, Inc., Kenner, LA
Love Links Ministries, Forge, PA
Macedonia Housing and Development
Corporation, Lakewood, NJ
Madison Housing, Inc., Media, PA
Manville Soccer Club, Manville, NJ
Marian Anderson Award Foundation,
Inc., Danbury, CT
Mark Little Ministries, Elk City, OK
Mercer County Wildlife Center A New
Jersey Nonprofit Corporation,
Chalfont, PA

Merion Village Civic Association,
Columbus, OH
Metropolitan Ecumenical Ministry
Community Development Corporation,
Ventnor, NJ
Miami County Foster Parents
Association, Troy, OH
Miami Heights Volunteer Firemens
Association, Inc., North Bend, OH
Milford Youth Football, Milford, OH
Mobile VOA Home Development,
Mobile, AL
Monroeville Area Chamber Foundation,
Monroeville, PA
Morning Sun Foundation, Inc.,
Ridgewood, NJ
Morrisville Playground, Inc.,
Morrisville, PA
Mount Vernon Academy Alumni
Association, Inc., Mt Vernon, OH
Mt. Airy Community Development
Corp., Philadelphia, PA
Muskingum Area Aids Task Force,
Zanesville, OH
Napa County Fire Department Station
16-West Hills, Yountville, CA
National Black MBA Association
Columbus Chapter, Columbus, OH
N A T Neighbors About Town,
Natrona, PA
New Beginnings at Woods Mansion, Inc.,
Vineland, NJ
New Creations, Inc., of Phila,
Philadelphia, PA
New Horizons in Autism Foundation,
Inc., Neptune, NJ
New Jersey Food Council Foundation,
Inc., Trenton, NJ
New Jersey Intergenerational Network,
Inc., Eatontown, NJ
New Jersey State Law Enforcement
Officers Scholarship Fdn, Inc.,
Hillside, NJ
New Kensington Summer Youth
Programs, Inc., Pittsburgh, PA
Newark Yankees, Inc., Newark, NJ
NJ Car Charitable Foundation, Inc.,
Trenton, NJ
Norristown Area Fight Against Drugs,
Norristown, PA
Ocean Gate Improvement Association,
Inc., Ocean Gate, NJ
Operation Get Done, Inc., Fords, NJ
Oswayo Valley Memorial Library,
Shinglehouse, PA
Our Lady of Rivers and Bridges, Inc.,
Pittsburgh, PA
Pangea United, Inc., Maumelle, AZ
Paraclete Retreat Center, Pittsboro, IN
Parent Teacher Organization,
Kingman, AZ
Pawtucket Police Athletic League, Inc.,
Pawtucket, RI
Pennsylvania Battleship Monument,
Glen Mills, PA
Pennsylvania Made Crafts, Inc.,
Pittsburgh, PA
Pennsylvania School Age Child Care
Alliance, Broad Axe, PA
Peoples United Community
Organization, Inc., Philadelphia, PA
PerDev Perceptual Development Center,
Inc., New York, NY
Pet Recyclers, Inc., Cherry Hill, NJ
Phila Noma, Inc., Philadelphia, PA
Philadelphia Air & Space Museum,
Philadelphia, PA
Philadelphia Eight Icoc, Inc.,
Philadelphia, PA
Philadelphia-White Marsh Rugby
Football Club, Inc., Philadelphia, PA
Picc of New Jersey, Inc., New York, NY
Pittsburgh Shade Tree Commission,
Pittsburgh, PA
Pittsburgh West Hills Basketball,
McKees Rocks, PA
Port Neches Girls Softball League, Inc.,
Port Neches, TX
Presbyterian Ministries Foundation,
Wayne, PA
Present Help, Inc., Pittsburgh, PA
Project W I N, Inc., Cherry Hill, NJ
Quaker City Rowing Foundation,
Philadelphia, PA
Rainbows Unlimited, Inc.,
Morrisville, VT
Ralph Stover Climbers Coalition, Inc.,
Coopersburg, PA
Raven Centers, Inc., Bensalem, PA
Real Estate Consumer Council, Inc.,
Narberth, PA
Real World Computer Museum,
Glen Mills, PA
Return to Love Outreach Store, Inc.,
Fairfield, OH
Rimersburg Veterans Memorial Park,
Rimersburg, PA
Rockwell City Public Library
Foundation, Rockwell City, IA
Rosemary’s Barrier Free Country Inn,
Inc., Tampa, FL
Roxbury High School Baseball Parents
Club, Inc., Succasunna, NJ
Rufus W. Walden Scholarship
Association, Philadelphia, PA
Sail-Habilitation, Toms River, NJ
Sanberger, Inc., Rockville, MD
School of Spiritual Formation,
Franconia, PA
Servants of Jesus Christ, Inc.,
Estes Park, CO
Sewickleynet, Sewickley, PA
Shiloh Baptist Community Development
Corporation SBCDC, Bridgeport, CT
Signal 10-13, Inc., Pittsburgh, PA
Smicksburg Area Heritage Society,
Smicksburg, PA
South Shore Bay Band, Duxbury, MA
South Village Community Development
Corporation, Philadelphia, PA
Southwestern Alliance of the Navajo
Nation, Winslow, AZ
Spiritual Eldering Institute, Bolder, CO
Spiritual Renewal Minstries, Inc.,
Southeastern, PA
Springfield Township Emergency
Medical Services, Inc., Jobstown, NJ
St. Johns East European Cultural and
Information Center, Homestead, PA
Steps to Success, Inc., Leola, PA
Summit Urban Renewal Nonprofit
Corporation, Teaneck, NJ
Support our Communities’ Kids, Inc.,
Gainesville, FL
Susquehanna Aids Awareness Coalition,
Clifford, PA
Talent Plus Education, Albuquerque, NM
Target Youth, Inc., Morrisville, PA
Tele-Jazz, Inc., South Orange, NJ
Texas Midwest Communities, Inc.,
Abilene, TX
Threshold Foundation in Support of
Youth, Lancaster, PA
Township of Neptune Economic
Development Corporation,
Neptune, NJ
T P I Foundation, Pittsburgh, PA
Treasures Along the Trail,
West Newton, PA
Triumphant House Mission Homes,
Philadelphia, PA
Unionville-Chadds Ford Education
Foundation, Inc., Kennett Square, PA
Vision Quest Association, Inc.,
Atlanta, GA
Volunteer Center of Burlington County,
Inc., Westhampton, NJ
Wayne County Deputy Sheriffs
Association, Detriot, MI
Wayne County Housing Development
Corporation, Inc., Waymart, PA
Westlanco Love, Inc., Mount Joy, PA
Williamsburg Creative Education Fund,
Williamsburg, PA
2001–19 I.R.B.1167May 7, 2001

May 7, 200111682001–19 I.R.B.
Windber Centennial Committee 1997,
Windber, PA
Wings of Charity, East Orange, NJ
Woman of Color, Inc., Bala Cynwyd, PA
Womens Crisis Center of West
Philadelphia, Philadelphia, PA
World Disaster Aid, Inc., Nashville, TN
Yella Gal Productions, Huntsville, AL
Yes I Can, Inc., Cornwall, NY
Youth Development and Encouragement,
Inc., Philadelphia, PA
If an organization listed above submits
information that warrants the renewal of
its classification as a public charity or as a
private operating foundation, the Internal
Revenue Service will issue a ruling or de-
termination letter with the revised classi-
fication as to foundation status. Grantors
and contributors may thereafter rely upon
such ruling or determination letter as pro-
vided in section 1.509(a)–7 of the Income
Tax Regulations. It is not the practice of
the Service to announce such revised clas-
sification of foundation status in the Inter-
nal Revenue Bulletin.
New Form 720-TO, Terminal
Operator Report
, and New Form
720-CS,
Carrier Summary
Report
Announcement 2001-48
New Form 720-TO, Form 720-CS, and
the Instructions for Forms 720-TO and
720-CS are available. Forms 720-TO and
720-CS are information returns that will
be used by terminal operators and carriers
to report their monthly receipts and dis-
bursements of liquid products. A liquid
product is any liquid that is transported
into storage at a terminal or delivered out
of a terminal. For a list of products, see
the product code table in the Instructions
for Forms 720-TO and 720-CS.
Also available is new Publication 3536,
Excise Tax EDI Guide, which contains the
application requirements to electronically
file these forms. Electronic filing is avail-
able to all terminal operators and carriers.
You can obtain Forms 720-TO and
720-CS by telephone or by using IRS
electronic information services.
Request byNumber or address
Telephone 1-800-TAX-FORM
(1-800-829-3676)
Personal computer:
IRS Web Sitewww.irs.gov
File transfer protocolftp.irs.gov

2001–19 I.R.B.iMay 7, 2001
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”)
that have an effect on previous rulings
use the following defined terms to de-
scribe 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

May 7, 2001ii2001–19 I.R.B.
Numerical Finding List
1
Bulletins 2001–1 through 2001–18
Announcements:
2001–1, 2001–2 I.R.B. 277
2001–2, 2001–2 I.R.B. 277
2001–3, 2001–2 I.R.B. 278
2001–4, 2001–2 I.R.B. 286
2001–5, 2001–2 I.R.B. 286
2001–6, 2001–3 I.R.B. 357
2001–7, 2001–3 I.R.B. 357
2001–8, 2001–3 I.R.B. 357
2001–9, 2001–3 I.R.B. 357
2001–10, 2001–4 I.R.B. 431
2001–11, 2001–4 I.R.B. 432
2001–12, 2001–6 I.R.B. 526
2001–13, 2001–96 I.R.B. 752
2001–14, 2001–7 I.R.B. 648
2001–15, 2001–8 I.R.B. 715
2001–16, 2001–8 I.R.B. 715
2001–17, 2001–8 I.R.B. 716
2001–18, 2001–10 I.R.B. 791
2001–19, 2001–10 I.R.B. 791
2001–20, 2001–8 I.R.B. 716
2001–21, 2001–9 I.R.B. 752
2001–22, 2001–11 I.R.B. 895
2001–23, 2001–10 I.R.B. 791
2001–24, 2001–10 I.R.B. 793
2001–25, 2001–11 I.R.B. 895
2001–26, 2001–11 I.R.B. 896
2001–27, 2001–11 I.R.B. 897
2001–28, 2001–13 I.R.B. 975
2001–29, 2001–14 I.R.B. 1014
2001–30, 2001–15 I.R.B. 1065
2001–31, 2001–17 I.R.B. 1113
2001–32, 2001–17 I.R.B. 1113
2001–33, 2001–17 I.R.B. 1136
2001–34, 2001–16 I.R.B. 1087
2001–35, 2001–16 I.R.B. 1087
2001–36, 2001–16 I.R.B. 1089
2001–37, 2001–16 I.R.B. 1090
2001–38, 2001–17 I.R.B. 1137
2001–39, 2001–17 I.R.B. 1141
2001–40, 2001–17 I.R.B. 1141
2001–41, 2001–18 I.R.B. 1147
2001–42, 2001–18 I.R.B. 1147
2001–43, 2001–18 I.R.B. 1147
2001–44, 2001–18 I.R.B. 1148
2001–45, 2001–18 I.R.B. 1148
Notices:
2001–1, 2001–2 I.R.B. 261
2001–2, 2001–2 I.R.B. 265
2001–3, 2001–2 I.R.B. 267
2001–4, 2001–2 I.R.B. 267
2001–5, 2001–3 I.R.B. 327
2001–6, 2001–3 I.R.B. 327
2001–7, 2001–4 I.R.B. 374
2001–8, 2001–4 I.R.B. 374
2001–9, 2001–4 I.R.B. 375
2001–10, 2001–5 I.R.B. 459
2001–11, 2001–5 I.R.B. 464
2001–12, 2001–3 I.R.B. 328
2001–13, 2001–6 I.R.B. 514
2001–14, 2001–6 I.R.B. 516
2001–15, 2001–7 I.R.B. 589
2001–16, 2001–9 I.R.B. 730
2001–17, 2001–9 I.R.B. 730
2001–18, 2001–9 I.R.B. 731
2001–19, 2001–10 I.R.B. 784
Notices—Continued:
2001–20, 2001–11 I.R.B. 818
2001–21, 2001–11 I.R.B. 818
2001–22, 2001–12 I.R.B. 911
2001–23, 2001–12 I.R.B. 911
2001–24, 2001–12 I.R.B. 912
2001–25, 2001–13 I.R.B. 941
2001–26, 2001–13 I.R.B. 942
2001–27, 2001–13 I.R.B. 942
2001–28, 2001–13 I.R.B. 944
2001–29, 2001–14 I.R.B. 989
2001–30, 2001–14 I.R.B. 989
2001–31, 2001–17 I.R.B. 1093
2001–32, 2001–18 I.R.B. 1146
Proposed Regulations:
LR–230–76, 2001–13 I.R.B. 945
REG–209461–79, 2001–8 I.R.B. 712
REG–246256–96, 2001–8 I.R.B. 713
REG–251701–96, 2001–4 I.R.B. 396
REG–101520–97, 2001–15 I.R.B. 1057
REG–106030–98, 2001–11 I.R.B. 820
REG–106446–98, 2001–13 I.R.B. 945
REG–106542–98, 2001–5 I.R.B. 473
REG–121928–98, 2001–6 I.R.B. 520
REG–109481–99, 2001–13 I.R.B. 961
REG–111835–99, 2001–11 I.R.B. 834
REG–114998–99, 2001–14 I.R.B. 992
REG–115560–99, 2001–14 I.R.B. 993
REG–101739–00, 2001–14 I.R.B. 996
REG–103320–00, 2001–8 I.R.B. 714
REG–104683–00, 2001–4 I.R.B. 407
REG–104876–00, 2001–14 I.R.B. 998
REG–105801–00, 2001–13 I.R.B. 965
REG–105946–00, 2001–16 I.R.B. 1069
REG–106513–00, 2001–16 I.R.B. 1076
REG–106702–00, 2001–4 I.R.B. 424
REG–106791–00, 2001–6 I.R.B. 521
REG–106892–00, 2001–15 I.R.B. 1060
REG–107047–00, 2001–14 I.R.B. 1002
REG–107101–00, 2001–16 I.R.B. 1083
REG–107175–00, 2001–13 I.R.B. 971
REG–107176–00, 2001–4 I.R.B. 428
REG–107186–00, 2001–13 I.R.B. 973
REG–107566–00, 2001–3 I.R.B. 346
REG–110374–00, 2001–12 I.R.B. 915
REG–110659–00, 2001–12 I.R.B. 917
REG–114082–00, 2001–7 I.R.B. 629
REG–114083–00, 2001–7 I.R.B. 630
REG–114084–00, 2001–7 I.R.B. 633
REG–116468–00, 2001–6 I.R.B. 522
REG–119352–00, 2001–6 I.R.B. 525
REG–121109–00, 2001–15 I.R.B. 1064
REG–125237–00, 2001–12 I.R.B. 919
REG–126100–00, 2001–11 I.R.B. 862
REG–129608–00, 2001–14 I.R.B. 1011
REG–130477–00, 2001–11 I.R.B. 865
REG–130481–00, 2001–11 I.R.B. 865
Railroad Retirement Quarterly Rates:
2001–2, I.R.B. 258
2001–15, I.R.B. 1054
Revenue Procedures:
2001–1, 2001–1 I.R.B. 1
2001–2, 2001–1 I.R.B. 79
2001–3, 2001–1 I.R.B. 111
2001–4, 2001–1 I.R.B. 121
2001–5, 2001–1 I.R.B. 164
2001–6, 2001–1 I.R.B. 194
2001–7, 2001–1 I.R.B. 236
Revenue Procedures—Continued:
2001–8, 2001–1 I.R.B. 239
2001–9, 2001–3 I.R.B. 328
2001–10, 2001–2 I.R.B. 272
2001–11, 2001–2 I.R.B. 275
2001–12, 2001–3 I.R.B. 335
2001–13, 2001–3 I.R.B. 337
2001–14, 2001–3 I.R.B. 343
2001–15, 2001–5 I.R.B. 465
2001–16, 2001–4 I.R.B. 376
2001–17, 2001–7 I.R.B. 589
2001–18, 2001–8 I.R.B. 708
2001–19, 2001–9 I.R.B. 732
2001–20, 2001–9 I.R.B. 738
2001–21, 2001–9 I.R.B. 742
2001–22, 2001–9 I.R.B. 745
2001–23, 2001–10 I.R.B. 784
2001–24, 2001–10 I.R.B. 788
2001–25, 2001–12 I.R.B. 913
2001–26, 2001–17 I.R.B. 1093
Revenue Rulings:
2001–1, 2001–9 I.R.B. 726
2001–2, 2001–2 I.R.B. 255
2001–3, 2001–3 I.R.B. 319
2001–4, 2001–3 I.R.B. 295
2001–5, 2001–5 I.R.B. 451
2001–6, 2001–6 I.R.B. 491
2001–7, 2001–7 I.R.B. 541
2001–8, 2001–9 I.R.B. 726
2001–9, 2001–8 I.R.B. 652
2001–10, 2001–10 I.R.B. 755
2001–11, 2001–10 I.R.B. 780
2001–12, 2001–11 I.R.B. 811
2001–13, 2001–12 I.R.B. 898
2001–14, 2001–12 I.R.B. 898
2001–15, 2001–13 I.R.B. 922
2001–16, 2001–13 I.R.B. 936
2001–17, 2001–15 I.R.B. 1052
2001–18, 2001–17 I.R.B. 1092
2001–19, 2001–18 I.R.B. 1143
2001–20, 2001–18 I.R.B. 1143
2001–21, 2001–18 I.R.B. 1144
Treasury Decisions:
8910, 2001–2 I.R.B. 258
8911, 2001–3 I.R.B. 321
8912, 2001–5 I.R.B. 452
8913, 2001–3 I.R.B. 300
8914, 2001–8 I.R.B. 653
8915, 2001–4 I.R.B. 359
8916, 2001–4 I.R.B. 360
8917, 2001–7 I.R.B. 538
8918, 2001–4 I.R.B. 372
8919, 2001–6 I.R.B. 505
8920, 2001–8 I.R.B. 654
8921, 2001–7 I.R.B. 532
8922, 2001–6 I.R.B. 508
8923, 2001–6 I.R.B. 485
8924, 2001–6 I.R.B. 489
8925, 2001–6 I.R.B. 496
8926, 2001–6 I.R.B. 492
8927, 2001–11 I.R.B. 807
8928, 2001–8 I.R.B. 685
8929, 2001–10 I.R.B. 756
8930, 2001–5 I.R.B. 433
8931, 2001–7 I.R.B. 542
8932, 2001–11 I.R.B. 813
8933, 2001–11 I.R.B. 794
8934, 2001–12 I.R.B. 904
8935, 2001–8 I.R.B. 702
8937, 2001–11 I.R.B. 806
1
A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 2000–27 through
2000–52 is in Internal Revenue Bulletin 2001–1,
dated January 2, 2001.

Treasury Decisions—Continued:
8938, 2001–13 I.R.B. 929
8939, 2001–12 I.R.B. 899
8940, 2001–15 I.R.B. 1016
8941, 2001–14 I.R.B. 977
8942, 2001–13 I.R.B. 929
8943, 2001–15 I.R.B. 1054
8944, 2001–16 I.R.B. 1067
2001–19 I.R.B.iiiMay 7, 2001

May 7, 2001iv2001–19 I.R.B.
Finding List of Current Actions on
Previously Published Items
1
Bulletins 2001–1 through 2001–18
Announcements:
98–99
Modified by
Ann. 2001–9, 2001–3 I.R.B. 357
99–79
Superseded by
Ann. 2001–3, 2001–2 I.R.B. 278
2000–78
Obsoleted by
T.D. 8933, 2001–11 I.R.B. 794
2000–97
Corrected by
Ann. 2001–7, 2001–3 I.R.B. 357
Cumulative Bulletin:
1998–2
Corrected by
Ann. 2001–5, 2001–2 I.R.B. 286
Notices:
94–3
Modified by
T.D. 8933, 2001–11 I.R.B. 794
98–39
Modified by
Notice 2001–9, 2001–4 I.R.B. 375
98–40
Modified by
Notice 2001–9, 2001–4 I.R.B. 375
99–53
Modified and superseded by
Notice 2001–7, 2001–4 I.R.B. 374
2000–21
Superseded by
Notice 2001–1, 2001–2 I.R.B. 261
2000–22
Modified and superseded by
Notice 2001–8, 2001–4 I.R.B. 374
2000–26
Modified by
Notice 2001–22, 2001–12 I.R.B. 911
2000–43
Extended by
Notice 2001–13, 2001–6 I.R.B. 514
Proposed Regulations:
EE–130–86
Partially withdrawn by
REG–209461–79, 2001–8 I.R.B. 712
REG–106030–98
Corrected by
Ann. 2001–30, 2001–15 I.R.B. 1065
REG–106542–98
Corrected by
Ann. 2001–24, 2001–13 I.R.B. 793
REG–116733–98
Withdrawn by
Ann. 2001–11, 2001–4 I.R.B. 432
Proposed Regulations—Continued:
REG–116048–99
Withdrawn by
Ann. 2001–27, 2001–11 I.R.B. 897
REG–104683–00
Corrected by
Ann. 2001–42, 2001–18 I.R.B. 1147
REG–106702–00
Corrected by
Ann. 2001–28, 2001–13 I.R.B. 975
REG–110374–00
Corrected by
Ann. 2001–44, 2001–18 I.R.B. 1148
Revenue Procedures:
83–87
Superseded by
Rev. Proc. 2001–15, 2001–5 I.R.B. 465
90–18
Amplified and superseded by
Rev. Proc. 2001–18, 2001–8 I.R.B. 708
92–19
Superseded by
Rev. Proc. 2001–15, 2001–5 I.R.B. 465
96–15
Modified by
Ann. 2001–22, 2001–11 I.R.B. 895
96–17
Modified by
Rev. Proc. 2001–9, 2001–3 I.R.B. 328
99–18
Modified and superseded by
Rev. Proc. 2001–21, 2001–9 I.R.B. 742
99–47
Superseded by
Rev. Proc. 2001–16, 2001–4 I.R.B. 376
99–49
Modified and amplified by
Notice 2001–23, 2001–12 I.R.B. 911
Rev. Proc. 2001–10, 2001–2 I.R.B. 272
Rev. Proc. 2001–23, 2001–10 I.R.B. 784
Rev. Proc. 2001–24, 2001–10 I.R.B. 788
Rev. Proc. 2001–25, 2001–12 I.R.B. 913
Rev. Rul. 2001–8, 2001–9 I.R.B. 762
2000–1
Superseded by
Rev. Proc. 2001–1, 2001–1 I.R.B. 1
2000–2
Superseded by
Rev. Proc. 2001–2, 2001–1 I.R.B. 79
2000–3
Superseded by
Rev. Proc. 2001–3, 2001–1 I.R.B. 111
2000–4
Superseded by
Rev. Proc. 2001–4, 2001–1 I.R.B. 121
2000–5
Superseded by
Rev. Proc. 2001–5, 2001–1 I.R.B. 164
2000–6
Superseded by
Rev. Proc. 2001–6, 2001–1 I.R.B. 194
Revenue Procedures—Continued:
2000–7
Superseded by
Rev. Proc. 2001–7, 2001–1 I.R.B. 236
2000–8
Superseded by
Rev. Proc. 2001–8, 2001–1 I.R.B. 239
2000–16
Modified and superseded by
Rev. Proc. 2001–17, 2001–7 I.R.B. 589
2000–22
Modified and superseded by
Rev. Proc. 2001–10, 2001–2 I.R.B. 272
2000–23
Superseded by
Rev. Proc. 2001–26, 2001–17 I.R.B. 1093
2001–3
Corrected by
Ann. 2001–25, 2001–11 I.R.B. 895
2001–13
Clarified by
Notice 2001–12, 2001–3 I.R.B. 328
Revenue Rulings:
64–328
Modified by
Notice 2001–10, 2001–5 I.R.B. 459
66–110
Modified by
Notice 2001–10, 2001–5 I.R.B. 459
85–30
Clarified by
Rev. Rul. 2001–8, 2001–9 I.R.B. 762
88–95
Clarified by
Rev. Rul. 2001–8, 2001–9 I.R.B. 762
92–19
Supplemented in part by
Rev. Rul. 2001–11, 2001–10 I.R.B. 780
2000–56
Corrected by
Ann. 2001–19, 2001–10 I.R.B. 791
2001–4
Modified by
Notice 2001–23, 2001–12 I.R.B. 911
Treasury Decisions:
7530
Removed by
T.D. 8938, 2001–13 I.R.B. 929
8757
Revised by
T.D. 8941, 2001–14 I.R.B. 977
8889
Corrected by
Ann. 2001–14, 2001–2 I.R.B. 286
8913
Corrected by
Ann. 2001–26, 2001–11 I.R.B. 896
8916
Corrected by
Ann. 2001–41, 2001–18 I.R.B. 1147
1
A cumulative list of current actions on previously
published items in Internal Revenue Bulletins
2000–27 through 2000–52 is in Internal Revenue
Bulletin 2001–1, dated January 2, 2001.

Treasury Decisions—Continued:
8921
Corrected by
Ann. 2001–43, 2001–18 I.R.B. 1147
8931
Technically amended by
Ann. 2001–37, 2001–16 I.R.B. 1090
2001–19 I.R.B.vMay 7, 2001

INDEX
Internal Revenue Bulletins
2001–1 through 2001–18
The abbreviation and number in paren-
thesis following the index entry refer to
the specific item; numbers in roman and
italic type following the paranthesis
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
Advance letter rulings and determination
letters, areas which will not be issued
from:
Associates Chief Counsel & Division
Counsel/Associate Chief Counsel
(TE/GE) (RP 3) 1, 111; correction
(Ann 25) 11, 895
Associate Chief Counsel International
(RP 7) 1, 236
Cafeteria plans, tax treatment of (TD 8921)
7, 532; correction (Ann 43) 18, 1147;
(REG–209461–79) 8, 712
Defined benefit pension plan, transfer of
excess assets (REG–116468–00) 6,
522
Determination letters:
Issuing procedures (RP 6) 1, 194
Notice to interested parties requirement
(REG–129608–00) 14, 1011
Employee Plans Compliance Resolution
System (EPCRS), update (RP 2001–17)
7,589
Employee stock ownership plans,
deductibility of redemption proceeds
(RR 6) 6, 491
Full funding limitations:
Weighted average interest rate for:
December 2000 (Notice 3) 2, 267
January 2001 (Notice 15) 7, 589
February 2001 (Notice 20) 11, 818
March 2001 (Notice 28) 13, 944
April 2001 (Notice 32) 18, 1146
Group health plans:
Continuation coverage requirements
(TD 8928) 8, 685
HIPAA nondiscrimination:
Bona fide wellness programs
(REG–114084–00) 7, 633
Certain grandfathered church plans,
exception (REG–114083–00) 7,
630
Eligibility not limited by certain
health factors (TD 8931) 7, 542;
correction (Ann 37) 16, 1090
(REG–114082–00) 7, 629
GUST remedial amendment period, M&P
plans and volume submitter plans (Ann
12) 6, 526
Letter rulings:
Determination letters and information
letters issued by Associates Chief
Counsel (RP 1) 1, 1
Information letters, etc. (RP 4) 1, 121
Life insurance contracts, “split-dollar”
arrangements (Notice 10) 5, 459
Nondiscrimination rules, governmental and
church plans, relief from (Notice 9) 4, 375
Practice before the Internal Revenue
Service; Circular 230 (REG–111835–
99) 11, 834
Proposed Regulations:
26 CFR 1.125–1 Q&A–8, amended;
1.125–2 Q&A–6(a), amended;
1.125–2 Q&A–6(b), (c), and (d),
withdrawn; 1.125–2 Q&A–6(e),
redesignated as (b); tax treatment of
cafeteria plans (REG–209461–79) 8,
712
26 CFR 1.401(a)(9)–0 through –8, added;
1.403(b)–2, added; 1.408–8, added;
54.4974–2, added; required minimum
distributions (REG–130477–00 and
REG–130481–00) 11, 865
26 CFR 1.417(e)–1, amended; special
rule for written explanation by quali-
fied retirement plans provided after
annuity starting date (REG–109481–
99) 13, 961
26 CFR 1.420–1, added; defined bene-
fit pension plan, transfer of excess
assets (REG–116468–00) 6, 522
26 CFR 1.7476–2, amended; 601.201,
amended; advance determination let-
ter, notice to interested parties
requirement (REG–129608–00) 14,
1011
26 CFR 54.9802–1, amended; group
health plans, HIPAA nondiscrimina-
tion requirements, eligibility not lim-
ited by certain health factors
(REG–114082–00) 7, 629
26 CFR 54.9802–1(f), amended; group
health plans, HIPAA nondiscrimina-
tion requirements, bona fide well-
ness programs (REG–114084–00) 7,
633
26 CFR 54.9802–2, added; group
health plans, HIPAA nondiscrimina-
tion requirements for certain grand-
fathered church plans, exception
(REG–114083–00) 7, 630
31 CFR Part 10, amended; practice
before the Internal Revenue Service;
Circular 230 (REG–111835–99) 11,
834
Qualified retirement plans:
Required minimum distributions (Ann
18) 10, 791
Written explanation provided after
annuity starting date (REG–109481–
99) 13, 961
Regulations:
26 CFR 1.125–4, amended; 1.125–4T,
removed; tax treatment of cafeteria
plans (TD 8921) 7, 532; correction
(Ann 43) 18,1147
26 CFR 54.4980B–0 through –8,
amended; 54.4980B–9, –10, added;
group health plans, continuation
coverage requirements (TD 8928) 8,
685
26 CFR 54.9802–1, added; 54.9802–1T,
removed; group health plans, HIPAA
nondiscrimination requirements, eli-
gibility not limited by certain health
factors (TD 8931) 7, 542; correction
(Ann 37) 16, 1090
Required minimum distributions (REG–
130477–00 and REG–130481–00) 11, 865
Technical advice to:
Directors and chiefs, appeals offices,
from Associates Chief Counsel
& Division Counsel/Associate Chief
Counsel (TE/GE) (RP 2) 1, 79
IRS employees (RP 5) 1, 164
May 7, 2001vi2001–19 I.R.B.
EMPLOYEE PLANS—
Cont.
EMPLOYEE PLANS—
Cont.

User fees, request for letter rulings (RP 8)
1, 239
EMPLOYMENT TAX
Electronic filing, Form 940 (RP 9) 3, 328
Electronic furnishing of payee statements,
voluntary (TD 8942) 13, 929;
(REG–107186–00) 13, 973
Forms:
W-2, new code (Ann 7) 3,357
W-2, voluntary electronic furnishing of
payee statements (TD 8942) 13, 929;
(REG–107186–00) 13, 973
940, electronic filing (RP 9) 3, 328
1098-E, voluntary electronic furnishing
of payee statements (TD 8942) 13,
929; (REG–107186–00) 13, 973
1098-T, voluntary electronic furnishing
of payee statements (TD 8942) 13,
929; (REG–107186–00) 13, 973
Indian tribal governments under FUTA,
treatment of (Ann 16) 8, 715
Interest-free adjustments (REG–110374–
00) 12, 915; correction (Ann 44) 18,
1148
Practice before the Internal Revenue
Service; Circular 230 (REG–111835–
99) 11, 834
Proposed Regulations:
26 CFR 31.3406(g)–1(d), revised;
reporting requirements for interest
on deposits paid to nonresident
aliens (REG–126100–00) 11, 862
26 CFR 31.6051–1, amended; electron-
ic payee statements, voluntary
(REG–107186–00) 13, 973
26 CFR 31.6205–1, revised; interest-
free adjustments (REG–110374–00)
12, 915; correction (Ann 44) 18,
1148
26 CFR 31.6302–1, amended;
31.6302(c)–3, amended; removal of
Federal Reserve banks as federal
depositaries (REG–107176–00) 4,
428
31 CFR Part 10, amended; practice
before the Internal Revenue Service;
Circular 230 (REG–111835–99) 11,
834
Railroad retirement, rate determination,
quarterly:
January 1, 2001, 2, 258
April 1, 2001, 15, 1054
Regulations:
26 CFR 31.6051–1T, added; electronic
payee statements, voluntary (TD
8942) 13, 929
26 CFR 31.6053–1, –4, amended;
tips, tip reporting, employer estab-
lished electronic systems (TD
8910) 2, 258
Reporting requirements for interest on
deposits paid to nonresident aliens
(REG–126100–00) 11, 862
Statutory stock options (Notice 14) 6, 516
Tips:
Tips reporting:
Employer-designed tip reporting,
food and beverage industry
(EmTRAC) programs (Notice 1)
2, 261
Employer established electronic sys-
tems (TD 8910) 2, 258
Voluntary tip reporting agreements
proformas(TRDA and TRAC)
(Ann 1) 2, 277
ESTATE TAX
Art valuation requests, change of address
for submissions (Ann 22) 11, 895
Charitable deductions, guaranteed annuity
and unitrust interest (TD 8923) 6, 485
Definition of income, total return, equitable
adjustments (REG–106513–00) 16,
1076
Generation-skipping transfer tax and reten-
tion of exempt status (TD 8912) 5, 452;
correction (Ann 40) 17, 1141
Interest:
Rates:
Farm real property, special use value
(RR 21) 18, 1144
Practice before the Internal Revenue
Service; Circular 230 (REG–111835–99)
11, 834
Proposed Regulations:
26 CFR 20.2056(b)–5, –7, –10, amened;
20.2056A–5, amended; 20.2056A–13,
revised; definition of income for trust
purposes (REG–106513–00) 16, 1076
26 CFR 1.641(b)–3, amended;
1.642(c)–1, revised; 1.645–1, added;
1.671–4, amended; 1.6072–1, amend-
ed; 301.6109–1, amended; election to
treat trust as part of an estate
(REG–106542–98) 5, 473; correction
(Ann 24) 10, 793
31 CFR Part 10, amended; practice
before the Internal Revenue Service;
Circular 230 (REG–111835–99) 11,
834
Regulations:
26 CFR 20.2055–2, amended; charitable
deductions, guaranteed annuity and
unitrust interest (TD 8923) 6, 485
26 CFR 26.2601–1, amended; genera-
tion-skipping transfer issues (TD
8912) 5,452; correction (Ann 40) 17,
1141
Trusts, election to treat trust as part of an
estate (REG–106542–98) 5, 472; correc-
tion (Ann 24) 10,793
Valuation of art requests, change of address
for submissions (Ann 22) 11, 895
EXCISE TAX
Air transportation, mileage awards (Notice
6) 3, 327
Deposits of excise taxes (REG–106892
–00) 15, 1060
Excess benefit transactions (TD 8920) 8,
654; (REG–246256–96) 8, 713
Nonconventional source fuel, inflation
adjustment factor, reference price, CY
2000 (Notice 31) 17, 1093
Practice before the Internal Revenue
Service; Circular 230 (REG–111835–
99) 11, 834
Proposed Regulations:
26 CFR 40.0–1, amended; 40.6011(a)
–1, –2, amended; 40.6071(a)–1,
amended; 40.6071(a)–2, removed;
40.6091–1, amended; 40.6101–1,
revised; 40.6109(a)–1, revised;
40.6151(a)–1, revised; 40.6302(c)
–1, –2, revised; 40.6302(c)–3,
amended; 40.6302(c)–4, removed;
40.9999–1, removed; deposits of
excise taxes (REG–106892–00) 15,
1060
26 CFR 53.4958–0 through –8, added;
excise taxes on excess benefit trans-
actions (REG–246256–96) 8, 713
31 CFR Part 10, amended; practice before
the Internal Revenue Service; Circular
230 (REG–111835–99) 11, 834
Regulations:
26 CFR 53.4958–0T through –8T,
added; 53.4963–1, amended;
2001–19 I.R.B.viiMay 7, 2001
ESTATE TAX—Cont.EMPLOYMENT TAX—
Cont.
EMPLOYEE PLANS—
Cont.

301.6213–1, amended; 301.6501(e)
–1, amended; 301.6501(n)–1,
amended; 301.7422–1, amended;
301.7454–2, amended; 301.7611–1,
amended; 602.101, amended; excise
taxes on excess benefit transactions
(TD 8920) 8, 654
EXEMPT ORGANIZA-
TIONS
Advance letter rulings and determination
letters, areas which will not be issued
from Associates Chief Counsel &
Division Counsel/Associate Chief
Counsel (TE/GE) (RP 3) 1, 111; correc-
tion (Ann 25) 11, 895
Excise taxes on excess benefit transactions
(TD 8920) 8, 654; (REG–246256–96) 8,
713
Forms:
990, request for comments (Ann 33)
17, 1137
990–EZ, request for comments (Ann
33) 17, 1137
990–PF, request for comments (Ann
33) 17, 1137
Indian tribal governments treated as
states, list (RP 15) 5, 465
Letter rulings, information letters, etc.
(RP 4) 1, 121
List of organizations classified as private
foundations (Ann 35) 16, 1087; (Ann
45) 18, 1148
Plain language publications and voluntary
compliance programs (Ann 14) 7, 648
Practice before the Internal Revenue
Service; Circular 230 (REG–111835–
99) 11, 834
Proposed Regulations:
26 CFR 53.4958–0 through –8, added;
excise taxes on excess benefit trans-
actions (REG–246256–96) 8, 713
31 CFR Part 10, amended; practice before
the Internal Revenue Service; Circular
230 (REG–111835–99) 11, 834
Regulations:
26 CFR 53.4958–0T through –8T,
added; 53.4963–1, amended;
301.6213–1, amended; 301.6501(e)
–1, amended; 301.6501(n)–1,
amended; 301.7422–1, amended;
301.7454–2, amended; 301.7611–1,
amended; 602.101, amended; excise
taxes on excess benefit transactions
(TD 8920) 8, 654
Revocations (Ann 20) 8,716; (Ann 36)
16, 1089
Technical advice to:
Directors and chiefs, appeals offices,
from Associates Chief Counsel &
Division Counsel/Associate Chief
Counsel (TE/GE) (RP 2) 1, 79
IRS employees (RP 5) 1, 164
User fees, request for letter rulings (RP 8)
1, 239
Withholding, Voluntary Compliance on
Alien Withholding Program (VCAP)
(RP 20) 9,738
GIFT TAX
Art valuation requests, change of address
for submissions (Ann 22) 11, 895
Charitable deductions, transfers to chari-
table lead trust (TD 8923) 6, 485
Definition of income, total return, equi-
table adjustments (REG–106513–00)
16, 1076
Practice before the Internal Revenue
Service; Circular 230 (REG–111835–
99) 11, 834
Proposed Regulations:
31 CFR Part 10, amended; practice
before the Internal Revenue Service;
Circular 230 (REG–111835–99) 11,
834
Regulations:
26 CFR 25.2523(e)–1, amended;
25.2523(h)–2, amended; 26.2601–1,
amended; definition of income for
trust purposes (REG–106513–00)
16, 1076
26 CFR 25.2522(c)–3, amended; chari-
table deductions, lifetime charitable
lead trust (TD 8923) 6, 485
Valuation of art requests, change of address
for submissions (Ann 22) 11, 895
INCOME TAX
Advance letter rulings and determination
letters, areas which will not be issued
from:
Associates Chief Counsel & Division
Counsel/Associate Chief Counsel
(TE/GE) (RP 3) 1, 111; correction
(Ann 25) 11, 895
Associate Chief Counsel International
(RP 7) 1, 236
Advance Pricing Agreement program
(APA) (Ann 32) 17, 1113
Aircraft maintenance costs (RR 4) 3, 295
Appeals, extension of test of mediation
procedure (Ann 9) 3, 357
Archer MSA (Ann 21) 9, 752
Art valuation requests, change of address
for submissions (Ann 22) 11, 895
Asset acquisitions, deemed and actual,
purchase price allocations (TD 8940)
15, 1016
Attorney’s fees, recovery of (TD 8922) 6,
508; (REG–121928–98) 6, 520
Automobile owners and lessees, determi-
nation of correct tax liability, 2001
inflation adjustment (RP 19) 9, 732
Bureau of the Census, disclosure of return
information (TD 8943) 15, 1054;
REG–121109–00) 15, 1064
Business expenses, changes in method of
accounting (Notice 23) 12, 911
Case Resolution Pilot Program, extension
(Notice 13) 6, 514
Charitable deductions, transfers to chari-
table lead trust (TD 8923) 6, 485
Classification of certain business enti-
ties, check-the-box regulations
(REG–110659–00) 12, 917
Consumer Price Index (CPI) adjustments,
below-market loans (Ann 19) 10, 791
Contribution in aid of construction
(CIAC), regulated public utilities,
water or sewerage disposal (TD 8936)
9, 720
Conversion to the euro (TD 8927) 11, 807
Corporations:
Assumed liabilities (TD 8924) 6, 489;
(REG–106791–00) 6, 521
Consolidated groups, tentative carry-
back adjustments (TD 8919) 6, 505;
(REG–119352–00) 6,525
Distributions of stock or securities in
connection with an acquisition:
Purchase of 50% or greater interest
in the corporation making the
distribution or being distributed
(REG–107566–00) 3, 346
Withdrawal of REG–116733–98
(Ann 11) 4, 432
Recognition of gain on certain distrib-
utions of stock or securities (TD
8913) 3, 300; correction (Ann 26)
11, 896
May 7, 2001viii2001–19 I.R.B.
INCOME TAX—Cont.
EXEMPT ORGANIZA-
TIONS—Cont.
EXCISE TAX—Cont.

Tax shelter:
Contingent liability (Notice 17) 9, 730
Intermediary transactions (Notice
16) 9, 730
Cost-of-living adjustments for inflation,
2001 (RP 13) 3, 337; clarified (Notice
12) 3, 328
Credits:
Deemed-paid credit computations
(REG–104683–00) 4, 407; correc-
tion (Ann 42) 18, 1147
Foreign tax credit limitations:
Affiliated groups and interest expense
allocations (TD 8916) 4, 360; cor-
rection (Ann 41) 18, 1147
Income subject to separate limita-
tions (REG–104683–00) 4, 407
Increasing research activities, defini-
tion of qualified research (TD 8930)
5, 433
Low-income housing credit:
Resident population estimates, 2001
(Notice 21) 11, 818
Satisfactory bond; “bond factor”
amounts for the period:
October through December 2000
(RR 2) 2, 225;
January through March 2001 (RR
10) 10, 755
April through June 2001 (RR 19)
18, 1143
Research credits:
Comments requested on final regu-
lations (Notice 19) 10, 784
Computing for increasing research
activities that include suspension
periods (Notice 2) 2, 265
Extension of time to file, with
expired suspension periods
(Notice 29) 14, 989
Cumulative Bulletin 1998–2, numerical
finding list, finding list of current
actions on previously published items
and index; corrections (Ann 5) 2, 286
Dealers in securities futures contracts
(Notice 27) 13, 942
Debt instrument, annuity issued by insur-
ance company (REG–125237–00) 12,
919
Debt substitution, election to treat as real-
ization event (RP 21) 9, 742
Definition of income, total return, equi-
table adjustments (REG–106513–00)
16, 1076
Disclosure of returns or return informa-
tion to:
Bureau of the Census (TD 8943) 15,
1054; (REG–121109–00) 15, 1064
Designee of taxpayer (TD 8935) 8, 702;
(REG–103320–00) 8, 714
Disqualified person, definition of
(REG–107175–00) 13, 971
Earnings and profits adjustments, exercise
of stock option (RR 1) 9, 726
Electing small business trusts; ESBT:
Qualifications and treatments (REG–
251701–96) 4, 396
Tiered structures (TD 8915) 4, 359
Electronic filing; magnetic media, Form
W-4, Employee’s Withholding Allow-
ance Certificate, specifications (RP 16)
4, 376
Electronic furnishing of payee statements,
voluntary (TD 8942) 13, 929;
(REG–107186–00) 13, 973
Employee stock ownership plans, deduc-
tibility of redemption proceeds (RR 6)
6, 491
Entity classification rules, clarification of
(REG–101739–00) 14, 996
Equity options, qualified covered call
treatment (REG–115560–99) 14, 993
Federal tax deposits, removal of Federal
Reserve banks as depositaries (TD 8918)
4, 372; (REG–107176–00) 4, 428
Financial asset securitization investment
trusts (FASITs) (RP 12) 3, 335
Foreign corporations, requirements relat-
ing to certain exchanges (TD 8938) 13,
929; (LR–230–76) 13, 945
Foreign sales corporation transfer pricing,
grouping rules (TD 8944) 16, 1067
Forms:
W-2:
New code (Ann 7) 3, 357
Voluntary electronic furnishing of
payee statements (TD 8942) 13,
929; (REG–107186–00) 13, 973
W-2 and W-3, specifications for private
printing of paper substitutes (RP 26)
17, 1093
W-4, Employee’s Withholding Allow-
ance Certificate, specifications (RP
16) 4, 376
W-9, Request for Taxpayer Identifi-
cation Number and Certification
(Ann 15) 8, 715
990, request for comments (Ann 33)
17, 1137
990–EZ, request for comments (Ann
33) 17, 1137
990–PF, request for comments (Ann
33) 17, 1137
1042S, specifications for filing magnet-
ically or electronically (Ann 3) 2,
278
1098-E, voluntary electronic furnishing
of payee statements (TD 8942) 13,
929; (REG–107186–00) 13, 973
1098-T, voluntary electronic furnishing
of payee statements (TD 8942) 13,
929; (REG–107186–00) 13, 973
1120, Schedule N, Foreign Operations
of U.S. Corporations (Ann 13) 9, 752
7004, Application for Automatic Exten-
sion of Time to File Corporation
Income Tax Return, new (Notice 29)
14, 989
8875, Taxable REIT Subsidiary Elec-
tion, revised (Ann 17) 8,716
Hedging transactions (REG–107047–00)
14, 1002
Hyperinflationary currency, definition of
(TD 8914) 8, 653
Information reporting:
Discharges of indebtedness (Notice 8)
4, 374
Payments to attorneys (Notice 7) 4, 374
Payments of qualified tuition and pay-
ments of interest on qualified educa-
tion loans, magnetic media filing
requirements (Ann 10) 4,431
Installment sales; changes in method of
accounting (Notice 22) 12, 911
Insurance companies:
Interest rate tables (RR 11) 10, 780
Tentative differential earnings rate and
tentative recomputed differential
earnings rate (Notice 24) 12, 912
Interest:
Investment:
Federal short-term, mid-term, and
long-term rates for:
January 2001 (RR 3) 3, 319
February 2001 (RR 7) 7, 541
March 2001 (RR 12) 11, 811
April 2001 (RR 17) 15, 1052
Rates:
Farm real property, special use value
(RR 21) 18, 1144
Reserve rate tables, insurance com-
panies (RR 11) 10, 780
2001–19 I.R.B.ixMay 7, 2001
INCOME TAX—Cont.INCOME TAX—Cont.INCOME TAX—Cont.

Underpayments and overpayments,
quarter beginning April 1, 2001
(RR 16) 13, 936
Inventory:
Floor stocks payments (RR 8) 9, 726
LIFO:
Optional dollar-value LIFO invento-
ry computation method for used
vehicle dealers (RP 23) 10, 784
Price indexes, department stores for:
November 2000 (RR 5) 5, 451
December 2000 (RR 9) 8, 652
January 2001 (RR 14) 12, 898
February 2001 (RR 18) 17, 1092
Joint and several liability, relief from
(REG–106446–98) 13, 945
Korean mutual agreement (Ann 34) 16,
1087
Last known address (RP 18) 8, 708
Last known address, definition of (TD
8939) 12, 899
Letter rulings, determination letters, and
information letters issued by Associates
Chief Counsel (RP 1) 1, 1
Levied upon property; return of
(REG–101520–97) 15, 1057
Life insurance contracts, “split-dollar”
arrangements (Notice 10) 5, 459
Long-term contracts:
Accounting for (TD 8929) 10, 756
Mid-contract change in taxpayer
(REG–105946–00) 16, 1069
Methods of accounting:
General rule for 2001 (RP 24) 10, 788
Inventories, small taxpayers (RP 10) 2,
272
Short-term loans, stated interest, cash
method banks, automatic change (RP
25) 12, 913
Nonconventional source fuel, inflation
adjustment factor, reference price, CY
2000 (Notice 31) 17, 1093
Partnerships:
Corporate partner’s stock, partnership
termination (REG–106702–00) 4,
424; correction (Ann 28) 13, 975
Final short-year tax return, determina-
tion of basis (Notice 5) 3, 327
Mergers and divisions (TD 8925) 6,
496
Taxable year, partner and partnership,
foreign partners (REG–104876–00)
14, 998
Practice before the Internal Revenue
Service; Circular 230 (REG–111835–
99) 11, 834
Pre-filing agreement program:
Annual report, Large and Mid-Size
Business Division (Ann 38) 17, 1138
Pre-filing examinations (RP 22) 9, 745
Presidentially declared disaster areas:
Disaster and combat zone, tax-related
deadlines (TD 8911) 3, 321
Major disaster and emergency areas
(RR 15) 13, 922
Taxpayers affected by the Cerro Grande
Fire (Notice 30) 14, 989
Private foundations, organizations now
classified as (Ann 35) 16, 1087; (Ann
45) 18, 1148
Proposed Regulations:
26 CFR 1.263(g)–1 through –5, added;
1.1092(d)–1, amended; capitaliza-
tion of interest and carrying charges
properly allocable to straddles
(REG–105801–00) 13, 965
26 CFR 1.301–1, amended; liabilities
assumed in certain corporate transac-
tions (REG–106791–00) 6, 521
26 CFR 1.355–0, amended; 1.355–7,
added; recognition of gain on certain
distributions of stock or securities in
connection with an acquisition
(REG–107566–00) 3, 346
26 CFR 1.141–7, –8, added; 1.141–15,
amended; obligations of states and
political subdivisions (REG–114998
–99) 14, 992
26 CFR 1.381(c)(4)–1, revised;
1.460–0, –4, amended; 1.460–6(g),
revised; long-term contracts, mid-
contract change in taxpayer
(REG–105946–00) 16, 1069
26 CFR 1.444–4, added; 1.641(c)–0,
–1, added; 1.1361–0, –1, amended;
1.1362–6, –7, amended; 1.1377–1,
–3, amended; electing small business
trusts (REG–251701–96) 4, 396
26 CFR 1.642(c)–2, amended;
1.643(a)–3, revised; 1.643(b)–1,
revised; 1.651(a)–2, added;
1.661(a)–2, revised; 1.664–3,
revised; definition of income for
trust purposes (REG–106513–00)
16, 1076
26 CFR 1.705–1, amended; 1.705–2,
added; basis adjustments upon the
sale of a corporate partner’s stock
(REG–106702–00) 4, 424; correc-
tion (Ann 28) 13, 975
26 CFR 1.706–4, added; taxable years
of partner and partnership, foreign
partners (REG–104876–00) 14, 998
26 CFR 1.863–3, amended; 1.863–8,
–9, added; source of income from
space and ocean activities, communi-
cations activities (REG–106030–98)
11, 820
26 CFR 1.892–5, added; 1.892–5T,
amended; 301.7701–2, amended; clar-
ification of entity classification rules
(REG–101739–00) 14, 996
26 CFR 1.894–1, revised; treaty guid-
ance regarding payments with respect
to domestic reverse hybrid entities
(REG–107101–00) 16, 1083
26 CFR 1.902–0, –1, amended;
1.904–0, –4, –6, amended; 1.904–5,
revised; 1.904(b)–1, –2, revised;
1.904(b)–3, –4, removed; 1.904(j)–1,
added; application of section 904 to
income subject to separate limita-
tions and computations of deemed-
paid credit under section 902
(REG–104683–00) 4, 407; correc-
tion (Ann 42) 18, 1147
26 CFR 1.1031(k)–1, amended; defini-
tion of disqualified person
(REG–107175–00) 13, 971
26 CFR 1.1092(c)–1, amended;
1.1092(c)–2, –3, added; equity
options with flexible terms, qualified
covered call treatment (REG
–115560–99) 14, 993
26 CFR 1.1221–2, revised;
1.1256(e)–1, revised; hedging trans-
actions (REG–107047–00) 14, 1002
26 CFR 1.1271–0, amended;
1.1275–1, amended; debt instru-
ments with original issue discount,
annuity contracts (REG–125237
–00) 12, 919
26 CFR 1.1502–78, amended; corpo-
rations, consolidated groups, tenta-
tive carryback adjustments(REG
–119352–00) 6, 525
26 CFR 1.6013–4, added; 1.6015–0
through –9, added; relief from joint
and several liability (REG–106446–
98) 13, 945
26 CFR 1.6041–2, amended; 1.6050S–1,
–2, added; 301.6724–1, amended;
May 7, 2001x2001–19 I.R.B.
INCOME TAX—Cont.INCOME TAX—Cont.
INCOME TAX—Cont.

electronic payee statements, voluntary
(REG–107186–00) 13, 973
26 CFR 1.6049–4(b)(5), revised;
1.6049–6, amended; 1.6049–8,
revised; reporting requirements for
interest on deposits paid to nonresi-
dent aliens (REG–126100–00) 11, 862
26 CFR 1.6302–1, –2, amended;
removal of Federal Reserve banks
as federal depositaries
(REG–107176–00) 4, 428
26 CFR 7.367(c)–1, –2, withdrawn;
requirements relating to certain
exchanges involving a foreign corpo-
ration (LR–230–76) 13, 945
26 CFR 301.6103(c)–1, added; disclo-
sure of return and return infor-
mation to designee of taxpayer
(REG–103320–00) 8, 714
26 CFR 301.6103(j)(1)–1, amended;
disclosure of return information to the
Bureau of the Census (REG–121109
–00) 15, 1064
26 CFR 301.6343–3, added; levied upon
property, return of property in certain
cases (REG–101520–97) 15, 1057
26 CFR 301.7430–0, removed;
301.7430–7, added; attorney’s fees,
recovery of (REG–121928–98) 6, 520
26 CFR 301.7701–3, amended; clas-
sification of certain business enti-
ties, check-the-box regulations
(REG–110659–00) 12, 917
31 CFR Part 10, amended; practice before
the Internal Revenue Service; Circular
230 (REG–111835–99) 11, 834
Publications:
547, Casualties, Disasters, and Thefts,
revised (Ann 6) 3, 357
551, Basis of Assets, revised 2000 (Ann
2) 2, 277
575, changes in minimum required dis-
tributions (Ann 23) 10, 791
583, Starting a Businesss and Keeping
Records, revised (Ann 8) 3, 357
584-B, Business Casualty, Disaster, and
Theft Loss Workbook, new (Ann 39)
17, 1141
590, changes in minimum required dis-
tributions (Ann 23) 10, 791
1212, supplemental information on
short-term Treasury bills (2000 edi-
tion) (Ann 29) 14, 1014
1245, Specifications for Filing Forms
W-4, Employee’s Withholding
Allowance Certificate, magnetically
or electronically (RP 6) 4, 376
Qualified transportation fringe benefits
(TD 8933) 11, 794; correction (Ann 31)
17, 1113
Qualified zone academy bonds, limitation
for 2001 (RP 14) 3, 343
Real estate mortgage investment conduits
(REMICs), safe harbor (RP 12) 3, 335
Regulations:
26 CFR 1.41–0, –1, –4, revised;
1.41–2, amended; 1.41–3, redesig-
nated as 1.41–3A; 1.41–3, added;
1.41–5, redesignated as 1.41–4A,
amended; 1.41–6, redesignated as
1.41–5, amended; 1.41–7, redesig-
nated as 1.41–5A, amended; 1.41–8,
redesignated as 1.41–6, amended;
1.41–9, redesignated as 1.41–7;
1.41–8, added; 1.41–0A through
–8A, removed; 1.41–0A, added;
1.218–0, removed; 1.482–7, amend-
ed; credit for increasing research
activities (TD 8930) 5, 433
26 CFR 1.118–2, added; contribution in
aid of construction (CIAC), regulat-
ed public utilities, water or sewerage
disposal (TD 8936) 9,720
26 CFR 1.132–0, –5, amended;
1.132–9, added; 602.101, amended;
qualified transportation fringe bene-
fits (TD 8933) 11, 794: correction
(Ann 31) 17, 1113
26 CFR 1.141–0, amended; 1.141–7T,
–8T, –15T, revised; 1.141–15,
amended; 1.142(f)(4)–1, added;
1.142(f)(4)–1T, removed; 1.150–5,
added; 1.150–5T, removed; 601.101,
amended; obligations of states and
political subdivisions (TD 8941) 14,
977
26 CFR 1.163–7, amended; 1.1271–0,
amended; 1.1275–1(f), –2, revised;
1.1275–2T, removed; 1.1275–7,
added; reopenings of Treasury secu-
rities and other debt instruments,
original issue discount (TD 8934)
12, 904
26 CFR 1.170A–6, amended; lifetime
charitable lead trust (TD 8923) 6, 485
26 CFR 1.301–1, amended; 1.301–1T,
added; assumed liabilities (TD
8924) 6, 489
26 CFR 1.338–0 through –7, –10,
added; 1.338(h)(10)–1, added;
1.338(i)–1, added; 1.338–0T through
–7T, –10T, removed; 1.338(h)(10)
–1T, removed; 1.338(i)–1T, removed;
1.1060–1T, removed; 1.1060–1,
added; 1.1361–1, –4, amended;
1.1502–76, amended; 602.101,
amended; purchase price allocations
in deemed and actual asset acquisi-
tions (TD 8940) 15, 1016
26 CFR 1.355–0, amended; 1.355–6,
revised; recognition of gain on cer-
tain distributions of stock or securi-
ties (TD 8913) 3,300; correction
(Ann 26) 11, 896
26 CFR 1.367(b)–0, amended;
1.367(b)–12, added; 7.367(b)–12,
removed; stock transfer rules, transi-
tion rules (TD 8937) 11, 806
26 CFR 1.367(b)–3(b)(4), withdrawn;
stock transfer rules (Ann 27) 11, 897
26 CFR 1.444–4T, added; ESBT, elect-
ing small business trusts, tiered
structures (TD 8915) 4, 359
26 CFR 1.446–1, amended; 1.451–3,
removed; 1.451–5, amended;
1.460–0, –4, –6, amended; 1.460–1
through –3, revised; 1.460–5, added;
1.460–7, –8, removed; 1.471–10,
amended; 602.101, amended;
accounting for long-term contracts
(TD 8929) 10, 756
26 CFR 1.467–0, –1, amended; 1.467–2,
added; 1.467–3, revised; rental agree-
ments involving payments of
$2,000,000 or less (TD 8917) 7,538
26 CFR 1.468A–5, amended;
1.503(a)–1, amended; 1.547–2,
amended; 1.856–6, amended;
1.860–2, amended; 1.963–6, amend-
ed; 1.992–3, amended; 1.6081–2, –3,
–4, –6, –7, amended; 301.6110–4,
–5, –6, amended; 301.6212–2,
added; 301.6301–1, amended;
301.6305–1, revised; 301.6320–1T,
amended; 301.6325–1, revised;
301.6330–1T, amended; 301.6331–
2, amended; 301.6332–2, amended;
301.6335–1, amended; 301.6503(c)–
1, amended; 301.6672–1, amended;
301.6903–1, amended; last known
address, definition of (TD 8939) 12,
899
2001–19 I.R.B.xiMay 7, 2001
INCOME TAX—Cont.INCOME TAX—Cont.
INCOME TAX—Cont.

26 CFR 1.643(a)–8, added; 1.664–1, –2,
–3, amended; charitable remainder
trusts, deemed sale, trust distributions,
abusive transactions (TD 8926) 6, 492
26 CFR 1.708–1, amended; 1.752–1,
–5, amended; partnership mergers
and divisions (TD 8925) 6, 496
26 CFR 1.861–9, –11, –14, added;
1.861–9T, –11T, –14T, revised;
1.902–1, amended; 1.904–0, –4,
–5, amended; application of sec-
tion 904 to income subject to sepa-
rate limitations and section 864(e)
affiliated group expense allocation
and apportionment rules (TD
8916) 4, 360; correction (Ann 41)
18, 1147
26 CFR 1.894–1, amended; 1.894–1T,
removed; guidance regarding claims
for certain income tax convention
benefits (Ann 4) 2, 286
26 CFR 1.925(a)–1, added;
1.925(a)–1T, amended; 1.925(b)–1T,
amended; foreign sales corporation
transfer pricing, grouping rules (TD
8944) 16, 1067
26 CFR 1.985–1, –4, amended;
1.985–8, added; 1.985–8T, removed;
1.1001–5, added; 1.1001–5T,
removed; conversion to the euro (TD
8927) 11, 807
26 CFR 1.988–1, revised; hyperinfla-
tionary currency (TD 8914) 8, 653
26 CFR 1.1502–78T, added; corpora-
tions, consolidated groups, tentative
carryback adjustments (TD 8919) 6,
505
26 CFR 1.6041–2T, added; 1.6050S–
1T, –2T, added; 301.6724–1T, added;
602.101, amended; electronic payee
statements, voluntary (TD 8942) 13,
929
26 CFR 7.367(c)–1, –2, removed;
requirements relating to certain
exchanges involving a foreign corpo-
ration (TD 8938) 13, 929
26 CFR 301.6103(c)–1, removed;
301.6103(c)–1T, added; disclosure of
returns or return information to
designee of taxpayer (TD 8935) 8, 702
26 CFR 301.6103(j)(1)(1)–1T, added;
disclosure of return information to
the Bureau of the Census (TD 8943)
15, 1054
26 CFR 301.6302–1T, added; removal
of Federal Reserve banks as deposi-
taries (TD 8918) 4,372
26 CFR 301.7430–7T, added; attorney’s
fees, recovery of (TD 8922) 6, 508
26 CFR 301.7502–1, revised;
301.7502–1T, removed; 301.7502
–2, added; timely mailing treated as
timely filing (TD 8932) 11, 813
26 CFR 301.7508–1, added; 301.7508
A–1, added; for combat zone service
or Presidentially declared disasters,
tax related deadlines (TD 8911) 3, 321
Rental agreements (TD 8917) 7, 538
Reopenings, debt instruments, Treasury
securities, original issue discount (TD
8934) 12, 904
Reporting requirements for interest on
deposits paid to nonresident aliens
(REG–126100–00) 11, 862
Short-term leases, qualified lessee con-
struction allowances for (RR 20) 18,
1144
Short-term loans, stated interest, cash
method banks, automatic change (RP
25) 12, 913
Source of income from space and ocean
activities, communications activities
(REG–106030–98) 11, 820; correction
(Ann 30) 15, 1065
Standard Industry Fare Level (SIFL) for-
mula (RR 13) 12, 898
States and political subdivisions, obliga-
tions of (TD 8941) 14, 977;
(REG–114998–99) 14, 992
Stock transfer rules:
Supplemental rules (Ann 27) 11, 897
Transition rules (TD 8937) 11, 806
Straddles; capitalization of interest and
carrying charges (REG–105801–00)
13, 965
Substantial understatement penalty, ade-
quate disclosure (RP 11) 2, 275
Substitute forms, W-2 and W-3, specifica-
tions for private printing (RP 26) 17,
1093
Tax convention, claims for benefits (Ann 4)
2,286
Tax shelters, leasing transactions, excep-
tions (Notice 18) 9, 731
Technical advice to directors and chiefs,
appeals offices, from Associates Chief
Counsel and Division Counsel/ Associate
Chief Counsel (TE/GE) (RP 2) 1, 79
Timely mailing treated as timely filing
(TD 8932) 11, 813
Treaty benefits, eligibility of items of
income paid by a domestic reverse hybrid
entity (REG–107101–00) 16, 1083
Trusts:
Charitable remainder trusts, deemed
sale, trust distributions, abusive
transactions (TD 8926) 6, 492
Election to treat trust as part of an
estate (REG–106542–98) 5, 473;
correction (Ann 24) 10, 793
ESBTs, electing small business trusts,
estimated tax payments (Notice 25)
13, 941
Qualified revocable trust treated as part
of an estate (Notice 26) 13, 942
Valuation of art requests, change of
address for submissions (Ann 22) 11,
895
Withholdings:
Payments to financial institutions in
U.S. possessions (Notice 11) 5, 464
Qualified intermediary agreements,
clarifications (Notice 4) 2, 267
Voluntary Compliance on Alien
Withholding Program (VCAP) (RP
20) 9, 738
SELF-EMPLOYMENT
TAX
Practice before the Internal Revenue
Service; Circular 230 (REG–111835–
99) 11, 834
Proposed Regulations:
31 CFR Part 10, amended; practice
before the Internal Revenue Service;
Circular 230 (REG–111835–99) 11,
834
May 7, 2001xii2001–19 I.R.B.
INCOME TAX—Cont.INCOME TAX—Cont.INCOME TAX—Cont.

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