Internal Revenue Bulletin 2004-25 (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.

Bulletin No. 200
4-25
June 21, 2004
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.
INCOME TAX
Rev. Rul. 2004–61, page 1073.
LIFO; price indexes; department stores.The April 2004
Bureau of Labor Statistics price indexes are accepted for use
by department stores employing the retail inventory and last-in,
first-out inventory methods for valuing inventories for tax years
ended on, or with reference to, April 30, 2004.
Rev. Rul. 2
004–62, page 1072.
Business e
xpenses; timber fertilization.The costs
incurred b
y a timber grower for the post-establishment fer-
tilizati
on of an established timber stand are ordinary and
necessar
y business expenses deductible under section 162
of the Cod
e. This ruling also provides procedures for a
taxpayer
to automatically change its method of accounting for
post-est
ablishment fertilization costs to the method provided
in this r
uling. Rev. Proc. 2002–9 modified and amplified.
EMPLOYEE PLANS
Notice 2004–42, page 1075.
Weighted average interest rate update; corporate bond
indexes; 30-year Treasury securities.The weighted aver-
age interest rate for June 2004 and the resulting permissible
range of interest rates used to calculate current liability and to
determine the required contribution are set forth.
Announcements of Disbarments and Suspensions begin on page 1076.
Fi
nding Lists begin on page ii.

The IRS Mission
Provide America’s taxpayers top quality service by helping
them understand and meet their tax responsibilities and by
applying the tax law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, 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 compiled 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, mod-
ify, or amend any of those previously published in the Bulletin.
All published rulings apply retroactively unless otherwise indi-
cated. Procedures relating solely to matters of internal man-
agement 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 published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—19
86 Code.
This part i
ncludes rulings and decisions based on provisions of
the Intern
al Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B, Leg-
islation 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 Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Sec-
retary (Enforcement).
Part IV
.—Items of General Interest.
This par
t includes notices of proposed rulemakings, disbar-
ment an
d suspension lists, and announcements.
The last 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 last Bulletin of each semiannual period.
The c
ontents 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.
June 21, 20042004-25 I.R.B.

Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
Section 162.—Trade or
Business Expenses
26 CFR 1.162–1: Business expenses.
(Also §§ 263, 263A; 1.263(a)–1.)
Business expenses; timber fertil-
ization.The costs incurred by a timber
grower for the post-establishment fertil-
ization of an established timber stand are
ordinary and necessary business expenses
deductible under section 162 of the Code.
This ruling also provides procedures for
a taxpayer to automatically change its
method of accounting for post-estab-
lishment fertilization costs to the method
provided in this ruling. Rev. Proc. 2002–9
modified and amplified.
Rev. Rul. 2004–62
ISSUE
Whether costs incurred by a timber
grower for the post-establishment fertil-
ization of an established timber stand are
ordinary and necessary business expenses
deductible under § 162 of the Internal Rev-
enue Code or capital expenditures under
§ 263.
FACTS
Xowns and manages timberlands in
the United States on which it grows trees
for use in its lumber and wood prod-
ucts business. After the target species
of timber establishes dominance in an
area and becomes an established timber
stand,Xincurs costs to perform various
silvicultural practices for the purposes of
managing, maintaining, and protecting the
stand. These post-establishment silvicul-
tural costs include labor and materials for
fire, disease, insect, and brush control.X
performs these silvicultural practices to
maintain optimal growing conditions that
will promote healthy development and
maximize timber volume.
In 2004,Xincurs costs to apply fertil-
izer to a portion of its timberlands underly-
ing an established stand of trees. This ap-
plication, commonly referred to as “post-
establishment fertilization,” is performed
after the target species of timber has es-
tablished dominance in the stand.Xgen-
erally performs post-establishment fertil-
ization once during the long-term growth
cycle of a timber stand.Xperforms the
fertilization to supplement nutrients in the
soil to maintain optimal growing condi-
tions that will promote healthy develop-
ment and maximize timber volume.
LAW AND ANALYSIS
Section 162 and § 1.162–1(a) of the In-
come Tax Regulations allow a deduction
for all the ordinary and necessary expenses
paid or incurred during the taxable year in
carrying on any trade or business.
Section 263(a)(1) provides that no de-
duction is allowed for any amount paid
out for new buildings or for permanent
improvements or betterments made to in-
crease the value of any property.See also
§ 1.263(a)–1(a).
Section 1.263(a)–1(b) provides that
capital expenditures include amounts
paid or incurred to (1) add to the value,
or substantially prolong the useful life,
of property owned by the taxpayer, or
(2) adapt property to a new or different
use. However, amounts paid or incurred
for incidental repairs and maintenance
of property for purposes of § 162 and
§ 1.162–4 are not capital expenditures
under § 1.263(a)–1.
Section 263A generally provides that
the direct and indirect costs properly allo-
cable to real or tangible personal property
produced by the taxpayer must be capital-
ized. Section 263A(c)(5)(A) provides that
§ 263A shall not apply to trees raised, har-
vested, or grown by the taxpayer other than
trees bearing fruit, nuts, or other crops,
or ornamental trees (other than evergreen
trees more than 6 years old at the time sev-
ered from their roots).
Certain costs incurred by timber grow-
ers for silvicultural practices performed in
established timber stands are ordinary and
necessary business expenses deductible
under § 162. These costs include amounts
incurred for labor and materials for fire,
disease, insect, and brush control.See
Barham v. United States, 301 F. Supp. 43
(M.D. Ga. 1969),aff’d on other grounds,
429F.2d40(5
th
Cir. 1970); H.R. Conf.
Rep. No. 841, 99
th
Cong., 2d Sess. II–117
(1986); H.R. Rep. No. 426, 99
th
Cong., 1
st
Sess. 624 (1985). These costs are incurred
for the management, maintenance, and
protection of the timber stand. These costs
are not incurred to materially add value to
the timber stand, substantially prolong its
useful life, or adapt the timber stand to a
new or different use. Accordingly, these
costs are not required to be capitalized
under § 263.
Like fire, disease, insect, and brush
control, post-establishment fertilization
promotes healthy development and maxi-
mizes timber volume and is performed for
the management, maintenance, and pro-
tection of the timber stand. There are no
significant differences between post-es-
tablishment fertilization and the types of
post-establishment silvicultural practices,
such as brush control, that have previously
been held to be ordinary and necessary
business expenses deductible under § 162.
Therefore,X’s costs for post-establishment
fertilization are deductible as ordinary and
necessary business expenses under § 162.
Furthermore, becauseXis growing trees
for timber production,Xis not required
to capitalize the direct and indirect costs
allocable to producing such trees under
§263A.See§ 263A(c)(5).
HOLDING
Costs incurred by a timber grower for
the post-establishment fertilization of an
established timber stand are ordinary and
necessary business expenses deductible
under § 162.
CHANGE IN METHOD OF
ACCOUNTING
Any change in a taxpayer’s treatment
of post-establishment fertilization costs
to conform to this revenue ruling is a
change in method of accounting to which
the provisions of §§ 446 and 481 and
the regulations thereunder apply. A tax-
payer changing its method of accounting
to comply with this revenue ruling must
file a Form 3115 in accordance with the
automatic change in method of account-
ing provisions of Rev. Proc. 2002–9,
2002–1 C.B. 327, as modified and clari-
fied by Announcement 2002–17, 2002–1
2004-25 I.R.B.1072June 21, 2004

C.B. 561, modified and amplified by Rev.
Proc. 2002–19, 2002–1 C.B. 696, and
amplified, clarified, and modified by Rev.
Proc. 2002–54, 2002–2 C.B. 432, except
that the scope limitations in section 4.02
of Rev. Proc. 2002–9 are not applicable.
Forpurposesofline1aofForm3115,
the designated number for the automatic
accounting method change authorized by
this revenue ruling is “86.”
EFFECT ON OTHER DOCUMENTS
Rev. Proc. 2002–9 is modified and
amplified to include in the APPENDIX the
automatic change provided in this revenue
ruling.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Amy Pfalzgraf of the Office of
Associate Chief Counsel (Income Tax
and Accounting). For further informa-
tion regarding this revenue ruling, contact
Ms. Pfalzgraf at (202) 622–4950 (not a
toll-free call).
Section 263.—Capital
Expenditures
26 CFR 1.263(a)–1: Capital expenditures; in gen-
eral.
Whether the costs incurred for the post-establish-
ment fertilization of an established timber stand are
deductible business expenses or capital expenditures.
See Rev. Rul. 2004-62, page 1072.
Section 472.—Last-in,
First-out Inventories
26 CFR 1.472–1: Last-in, first-out inventories.
LIFO; price indexes; department
stores.The April 2004 Bureau of Labor
Statistics price indexes are accepted for
use by department stores employing the
retail inventory and last-in, first-out in-
ventory methods for valuing inventories
for tax years ended on, or with reference
to, April 30, 2004.
Rev. Rul. 2004–61
The following Department Store In-
ventory Price Indexes for April 2004 were
issued by the Bureau of Labor Statistics.
The indexes are accepted by the Inter-
nal Revenue Service, under § 1.472–1(k)
of the Income Tax Regulations and Rev.
Proc. 86–46, 1986–2 C.B. 739, for ap-
propriate application to inventories of
department stores employing the retail
inventory and last-in, first-out inventory
methods for tax years ended on, or with
reference to, April 30, 2004.
The Department Store Inventory Price
Indexes are prepared on a national basis
and include (a) 23 major groups of depart-
ments, (b) three special combinations of
the major groups — soft goods, durable
goods, and miscellaneous goods, and (c) a
store total, which covers all departments,
including some not listed separately, ex-
cept for the following: candy, food, liquor,
tobacco, and contract departments.
BUREAU OF LABOR STATISTICS, DEPARTMENT STORE
INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS
(January 1941 = 100, unless otherwise noted)
GroupsApril 2003April 2004
Percent Change
from April 2003
to April 2004
1
1. PieceGoods .............................................457.9491.07.2
2. DomesticsandDraperies..................................568.1539.7-5.0
3. Women’sandChildren’sShoes ............................646.4654.51.3
4. Men’sShoes.............................................844.7856.41.4
5. Infants’Wear ............................................597.8586.1-2.0
6. Women’sUnderwear......................................517.2493.2-4.6
7. Women’sHosiery ........................................347.1336.2-3.1
8. Women’sandGirls’Accessories ...........................552.1564.22.2
9. Women’sOuterwearandGirls’Wear .......................385.7389.20.9
10. Men’sClothing ..........................................569.0545.9-4.1
11. Men’sFurnishings........................................589.8592.70.5
12. Boys’ClothingandFurnishings............................465.5459.4-1.3
13. Jewelry..................................................876.5893.01.9
14. Notions .................................................794.1799.30.7
15. ToiletArticlesandDrugs..................................982.5987.50.5
16. FurnitureandBedding ....................................627.7618.0-1.5
17. FloorCoverings..........................................584.4598.82.5
18. Housewares..............................................730.3715.3-2.1
19. MajorAppliances.........................................215.3201.8-6.3
20. RadioandTelevision......................................46.442.7-8.0
21. Recreation and Education
2
.................................83.781.2-3.0
22. Home Improvements
2
.....................................125.1128.02.3
23. Automotive Accessories
2
..................................111.5112.10.5
June 21, 200410732004-25 I.R.B.

BUREAU OF LABOR STATISTICS, DEPARTMENT STORE
INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS
(January 1941 = 100, unless otherwise noted)
GroupsApril 2003April 2004
Percent Change
from April 2003
to April 2004
1
Groups1–15:SoftGoods .......................................573.8572.0-0.3
Groups16–20:DurableGoods...................................399.0385.6-3.4
Groups 21–23: Misc. Goods
2
....................................94.893.6-1.3
Store Total
3
..............................................510.0504.8-1.0
1
Absence of a minus sign before the percentage change in this column signifies a price increase.
2
Indexes on a January 1986 = 100 base.
3
The store t
otal index covers all departments, including some not listed separately, except for the following: candy, food, liquor,
tobacco and
contract departments.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Michael Burkom of the Office
of Associate Chief Counsel (Income Tax
and Accounting). For further informa-
tion regarding this revenue ruling, contact
Mr. Burkom at (202) 622–7924 (not a
toll-free call).
2004-25 I.R.B.1074June 21, 2004

Part III. Administrative, Procedural, and Miscellaneous
Weighted Average Interest
Rates Update
Notice 2004–42
This notice provides guidance as to the
corporate bond weighted average interest
rate and the permissible range of interest
rates specified under § 412(b)(5)(B)(ii)(II)
of the Internal Revenue Code. In ad-
dition, it provides guidance as to the
interest rate on 30-year Treasury securi-
ties under § 417(e)(3)(A)(ii)(II), and the
weighted average interest rate and permis-
sible ranges of interest rates based on the
30-year Treasury securities rate.
CORPORATE BOND WEIGHTED
AVERAGE INTEREST RATE
Sections412(b)(5)(B)(ii)and
412(l)(7)(C)(i), as amended by the Pen-
sion Funding Equity Act of 2004, provide
that the interest rates used to calculate cur-
rent liability and to determine the required
contribution under § 412(l) for plan years
beginning in 2004 or 2005 must be within
a permissible range based on the weighted
average of the rates of interest on amounts
invested conservatively in long term in-
vestment grade corporate bonds during the
4-year period ending on the last day before
the beginning of the plan year.
Notice 2004–34, 2004–18 I.R.B. 848,
provides guidelines for determining the
corporate bond weighted average interest
rate and the resulting permissible range
of interest rates used to calculate current
liability. That notice establishes that the
corporate bond weighted average is based
on the monthly composite corporate bond
rate derived from designated corporate
bond indices.
The composite corporate bond rate for
May 2004 is 6.19 percent. Pursuant to No-
tice 2004–34, the Service has determined
this rate as the average of the monthly
yields for the included corporate bond in-
dices for that month.
The following corporate bond weighted
average interest rate was determined for
plan years beginning in the month shown
below.
For Plan Years
Corporate
Bond90% to 100%
Beginning in:WeightedPermissible
MonthYearAverageRange
June20046.345.70 to 6.34
30-YEAR TREASURY SECURITIES
WEIGHTED AVERAGE INTEREST
RATE
Section 417(e)(3)(A)(ii)(II) defines
the applicable interest rate, which must
be used for purposes of determining the
minimum present value of a participant’s
benefit under § 417(e)(1) and (2), as the
annual rate of interest on 30-year Treasury
securities for the month before the date
of distribution or such other time as the
Secretary may by regulations prescribe.
Section 1.417(e)–1(d)(3) of the Income
Tax Regulations provides that the applica-
bleinterestrateforamonthistheannual
interest rate on 30-year Treasury securi-
ties as specified by the Commissioner for
that month in revenue rulings, notices or
other guidance published in the Internal
Revenue Bulletin.
Section 404(a)(1) of the Code, as
amended by the Pension Funding Eq-
uity Act of 2004, permits an employer
to elect to disregard subclause (II) of
§ 412(b)(5)(B)(ii) to determine the max-
imum amount of the deduction allowed
under § 404(a)(1).
The rate of interest on 30-year Treasury
securities for May 2004 is 5.42 percent.
Pursuant to Notice 2002–26, 2002–1 C.B.
743, the Service has determined this rate
as the monthly average of the daily deter-
mination of yield on the 30-year Treasury
bond maturing in February 2031.
The following 30-year Treasury rates
were determined for the plan years begin-
ning in the month shown below.
For Plan Years
30-Year
Treasury90% to 105%90% to 110%
Beginning in:WeightedPermissiblePermissible
MonthYearAverageRangeRange
June20045.174.65 to 5.434.65 to 5.68
Drafting Information
The principal authors of this notice
are Paul Stern and Tony Montanaro of
the Employee Plans, Tax Exempt and
Government Entities Division. For fur-
ther information regarding this notice,
please contact the Employee Plans’ tax-
payer assistance telephone service at
1–877–829–5500 (a toll-free number),
between the hours of 8:00 a.m. and
6:30 p.m. Eastern time, Monday through
Friday. Mr. Stern may be reached at
1–202–283–9703. Mr. Montanaro may
be reached at 1–202–283–9714. The tele-
phone numbers in thepreceding sentences
are not toll-free.
June 21, 200410752004-25 I.R.B.

Part IV. Items of General Interest
Announcement of Disciplinary Actions Involving
Attorneys, Certified Public Accountants, Enrolled Agents,
and Enrolled Actuaries — Suspensions, Censures,
Disbarments, and Resignations
Announcement 2004-49
Under Title 31, Code of Federal Regu-
lations, Part 10, attorneys, certified public
accountants, enrolled agents, and enrolled
actuaries may not accept assistance from,
or assist, any person who is under disbar-
ment or suspension from practice before
the Internal Revenue Service if the assis-
tance relates to a matter constituting prac-
tice before the Internal Revenue Service
and may not knowingly aid or abet another
person to practice before the Internal Rev-
enue Service during a period of suspen-
sion, disbarment, or ineligibility of such
other person.
To enable attorneys, certified public
accountants, enrolled agents, and enrolled
actuaries to identify persons to whom
these restrictions apply, the Director, Of-
fice of Professional Responsibility, will
announce in the Internal Revenue Bulletin
their names, their city and state, their pro-
fessional designation, the effective date
of disciplinary action, and the period of
suspension. This announcement will ap-
pear in the weekly Bulletin at the earliest
practicable date after such action and will
continue to appear in the weekly Bulletins
for five successive weeks.
Consent Disbarments From Practice Before the Internal
Revenue Service
Under Title 31, Code of Federal Regu-
lations, Part 10, an attorney, certified pub-
lic accountant, enrolled agent, or enrolled
actuary, in order to avoid institution or con-
clusion of a proceeding for his or her dis-
barment or suspension from practice be-
fore the Internal Revenue Service, may of-
fer his or her consent to disbarment from
such practice. The Director, Office of Pro-
fessional Responsibility, in his discretion,
may disbar an attorney, certified public ac-
countant, enrolled agent, or enrolled actu-
ary in accordance with the consent offered.
The following individuals have been
placed under consent disbarment from
practice before the Internal Revenue Ser-
vice:
NameAddressDesignationDate of Disbarment
Ranes III, Wesse C.Annapolis, MDCPAIndefinite
from
May 1, 2004
Consent Suspensions From Practice Before the Internal
Revenue Service
Under Title 31, Code of Federal Regu-
lations, Part 10, an attorney, certified pub-
lic accountant, enrolled agent, or enrolled
actuary, in order to avoid institution or con-
clusion of a proceeding for his or her dis-
barment or suspension from practice be-
fore the Internal Revenue Service, may of-
fer his or her consent to suspension from
such practice. The Director, Office of Pro-
fessional Responsibility, in his discretion,
may suspend an attorney, certified public
accountant, enrolled agent, or enrolled ac-
tuary in accordance with the consent of-
fered.
The following individuals have been
placed under consent suspension from
practice before the Internal Revenue Ser-
vice:
2004-25 I.R.B.1076June 21, 2004

NameAddressDesignationDate of Suspension
Montgomery, Goldie L.Lancaster, CAEnrolled AgentIndefinite
from
February 1, 2004
Frost, Charles L.San Antonio, TXEnrolled AgentIndefinite
from
February 1, 2004
Briggs, John W.Sayville, NYEnrolled AgentFebruary 10, 2004
from
August 8, 2004
Lahman, Gary M.Ft. Collins,COEnrolled AgentIndefinite
from
February 12, 2004
Stanny, Gertrude M.South Lyon, MIEnrolled AgentIndefinite
from
March 1, 2004
Millar, MarkTall Timbers, MDEnrolled AgentIndefinite
from
March 1, 2004
Mur
ray, Maureen E.
Nau
gatuck, CT
Enr
olled Agent
Ind
efinite
fro
m
Mar
ch 1, 2004
Keith, James S.Imperial Beach, CAEnrolled AgentMarch 2, 2004
from
June 30, 2004
Zelek, Linda S.Moultonboro, NHCPAIndefinite
from
March 4, 2004
Gilpin, Charles H.San Leandro,CAEnrolled AgentIndefinite
from
March 5, 2004
Smith, Sean M.Silver Spring, MDEnrolled AgentIndefinite
from
March 15, 2004
Morelini, Wayne C.Modesto, CAEnrolled AgentIndefinite
from
March 15, 2004
Bower, JayRedmond, OREnrolled AgentIndefinite
from
March 16, 2004
Lynn, Celia M.Locust Grove, VAEnrolled AgentIndefinite
from
April 1, 2004
Swantz Jr., H. E.San Diego, CAEnrolled AgentIndefinite
from
April 6, 2004
June 21, 200410772004-25 I.R.B.

NameAddressDesignationDate of Suspension
Hart, David A.Lake Zurich, ILEnrolled AgentIndefinite
from
April 8, 2004
Lau, Dennis K.M.Honolulu, HIEnrolled AgentIndefinite
from
April 20, 2004
Lentz, CaroleMastic, NYEnrolled AgentIndefinite
from
April 23, 2004
Goble, Dennis R.Valparaiso, INCPAIndefinite
from
April 26, 2004
Rivera, Eduardo M.Torrence, CAAttorneyMay 1, 2004
to
October 29, 2006
Grant, Elaine C.Woodway, WAEnrolled AgentMay 1, 2004
to
October 31, 2004
Bell, DonGrand Junction, COEnrolled AgentIndefinite
from
May 1, 2004
Cohick, Jeffrey S.Newville, PAEnrolled AgentMay 1, 2004
from
October 30, 2004
Expedited Suspensions From Practice Before the Internal
Revenue Service
Under Title 31, Code of Federal Regu-
lations, Part 10, the Director, Office of Pro-
fessional Responsibility, is authorized to
immediately suspend from practice before
the Internal RevenueService any practi-
tioner who, within five years from the date
the expedited proceeding is instituted (1)
has had a license to practice as an attor-
ney, certified public accountant, or actuary
suspended or revoked for cause or (2) has
been convicted of certain crimes.
The following individuals have been
placed under suspension from practice be-
fore the Internal Revenue Service by virtue
of the expedited proceeding provisions:
NameAddressDesignationDate of Suspension
Candelario, AlexanderCabins, WVCPAIndefinite
from
February 1, 2004
Riener, RichardSt. Paul, MNAttorneyIndefinite
from
March 1, 2004
Dunkle, ClarkCarlisle, PACPAIndefinite
from
March 15, 2004
2004-25 I.R.B.1078June 21, 2004

NameAddressDesignationDate of Suspension
Bailey, Donald D.Tucson, AZCPAIndefinite
from
March 18, 2004
Hill, Donald R.Clinchco, VACPAIndefinite
from
April 1, 2004
Bergeson, NancyInver Grove Hghts, MNCPAIndefinite
from
April 14, 2004
Reese, Kenneth J.Nebraska City, NECPAIndefinite
from
April 15, 2004
Coates, Marsden S.Baltimore, MDAttorneyIndefinite
from
April 15, 2004
Schaefer, Robert J.Moorhead, MNAttorneyIndefinite
from
April 20, 2004
Mills, Stuart B.Pender, NEAttorneyIndefinite
from
May 1, 2004
Harris-Smith, BridgetteSilver Spring, MDAttorneyIndefinite
from
May 3, 2004
Janousek, Donald R.Omaha, NEAttorneyIndefinite
from
May 3, 2004
Williams, Gary W.Diamond Bar, CACPAIndefinite
from
May 3, 2004
Demaio, Louis J.Bel Air, MDAttorneyIndefinite
from
May 3, 2004
Miller, Frederick C.Cedar Hill, TXCPAIndefinite
from
May 15, 2004
June 21, 200410792004-25 I.R.B.

Censure Issued by Consent
Under Title 31, Code of Federal Reg-
ulations, Part 10, in lieu of a proceeding
being instituted or continued, an attorney,
certified public accountant, enrolled agent,
or enrolled actuary, may offer his or her
consent to the issuance of a censure. Cen-
sure is a public reprimand.
The following individuals have con-
sented to the issuance of a Censure:
NameAddressDesignationDate of Censure
Friedman, Milton G.Ft. Lauderdale, FLCPADecember 30, 2003
Stevens, William E.Omaha, NECPAFebruary 13, 2004
Turner, Mark A.Cincinnati, OHCPAFebruary 25, 2004
Rath, Dorris A.Bradenton, FLEnrolled AgentMarch 9, 2004
Damiano, LisaSouth Windsor, CTEnrolled AgentMarch 9, 2004
Silbiger, Arnold R.Baltimore, MDAttorneyMarch 11, 2004
Farwell, Nancy K.Citrus Heights, CAEnrolled AgentApril 5, 2004
Dembrowski, Karen E.Encino, CACPAApril 13, 2004
2004-25 I.R.B.1080June 21, 2004

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the ef-
fect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is be-
ingextendedtoapplytoavariationofthe
fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that the
same principle also applies to B, the earlier
ruling is amplified. (Compare withmodi-
fied,below).
Clarifiedis used in those instances
where the language in a prior ruling is be-
ing made clear because the language has
caused, or may cause, some confusion.
It is not used where a position in a prior
ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis 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 applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
withamplifiedandclarified, above).
Obsoleteddescribes 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 rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
beingstatedinanewruling.
Supersededdescribes a situation where
the new ruling does nothing more than re-
state the substance and situation of a previ-
ously published ruling (or rulings). Thus,
the term is used to republish under the
1986 Code and regulations the same po-
sition published under the 1939 Code and
regulations. The term is also used when
it is desired to republish in a single rul-
ing a series of situations, names, etc., that
were previously published over a period of
time in separate rulings. If the new rul-
ing does more than restate the substance
of a prior ruling, a combination of terms
is used. For example,modifiedandsu-
persededdescribes a situation where the
substance of a previously published 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 pub-
lished ruling is first modified and then, as
modified, is superseded.
Supplementedis 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 rul-
ing has been supplemented several times, a
new ruling may be published that includes
the list in the original ruling and the ad-
ditions, and supersedes all prior rulings in
the series.
Suspendedis used in rare situations
to show that the previous published rul-
ings 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 fol
lowing abbreviations in current use
and for
merly used will appear in material
publis
hedintheBulletin.
A—Individual.
Acq.—A
cquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank
.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cu
mulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Coo
perative.
Ct.D.—Court Decision.
CY—County.
D—Decede
nt.
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—Emp
loyer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduc
iary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Fo
reign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Fed
eral Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grante
e.
GP—General Partner.
GR—Grantor.
IC—Insura
nce Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited
Partner.
LR—Lessor.
M—Minor.
Nonacq.—No
nacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Persona
l Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Pa
rtnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Re
al Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsi
diary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target
Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Trans
feree.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpay
er.
TR—Trust.
TT—Trustee.
U.S.C.—Uni
ted States Code.
X—Corporation.
Y—Corporation.
Z—Corporat
ion.
June 21, 2004i2004-25 I.R.B.

Numerical Finding List
1
Bulletins 2004–1 through 2004–25
Announcements:
2004-1, 2004-1 I.R.B.254
2004-2, 2004-3 I.R.B.322
2004-3, 2004-2 I.R.B.294
2004-4, 2004-4 I.R.B.357
2004-5, 2004-4 I.R.B.362
2004-6, 2004-3 I.R.B.322
2004-7, 2004-4 I.R.B.365
2004-8, 2004-6 I.R.B.441
2004-9, 2004-6 I.R.B.441
2004-10, 2004-7 I.R.B.501
2004-11, 2004-10 I.R.B.581
2004-12, 2004-9 I.R.B.541
2004-13, 2004-9 I.R.B.543
2004-14, 2004-10 I.R.B.582
2004-15, 2004-11 I.R.B.612
2004-16, 2004-13 I.R.B.668
2004-17, 2004-12 I.R.B.635
2004-18, 2004-12 I.R.B.639
2004-19, 2004-13 I.R.B.668
2004-20, 2004-13 I.R.B.673
2004-21, 2004-13 I.R.B.673
2004-22, 2004-14 I.R.B.709
2004-23, 2004-13 I.R.B.673
2004-24, 2004-14 I.R.B.714
2004-25, 2004-15 I.R.B.737
2004-26, 2004-15 I.R.B.743
2004-27, 2004-14 I.R.B.714
2004-28, 2004-16 I.R.B.818
2004-29, 2004-15 I.R.B.772
2004-30, 2004-17 I.R.B.833
2004-31, 2004-18 I.R.B.854
2004-32, 2004-18 I.R.B.860
2004-33, 2004-18 I.R.B.862
2004-34, 2004-19 I.R.B.895
2004-35, 2004-17 I.R.B.839
2004-36, 2004-20 I.R.B.932
2004-37, 2004-17 I.R.B.839
2004-38, 2004-18 I.R.B.878
2004-39, 2004-17 I.R.B.840
2004-40, 2004-17 I.R.B.840
2004-41, 2004-18 I.R.B.879
2004-42, 2004-17 I.R.B.840
2004-43, 2004-21 I.R.B.955
2004-44, 2004-21 I.R.B.957
2004-45, 2004-21 I.R.B.958
2004-46, 2004-21 I.R.B.964
2004-47, 2004-21 I.R.B.966
2004-48, 2004-22 I.R.B.998
2004-49, 2004-21 I.R.B.966
2004-50, 2004-22 I.R.B.1005
2004-51, 2004-23 I.R.B.1041
2004-52, 2004-24 I.R.B.1071
Announcements— Continued:
2004-54, 2004-24 I.R.B.1061
Court Decisions:
2078, 2004-16 I.R.B.773
2079, 2004-22 I.R.B.978
Notices:
2004-1, 2004-2 I.R.B.268
2004-2, 2004-2 I.R.B.269
2004-3, 2004-5 I.R.B.391
2004-4, 2004-2 I.R.B.273
2004-5, 2004-7 I.R.B.489
2004-6, 2004-3 I.R.B.308
2004-7, 2004-3 I.R.B.310
2004-8, 2004-4 I.R.B.333
2004-9, 2004-4 I.R.B.334
2004-10, 2004-6 I.R.B.433
2004-11, 2004-6 I.R.B.434
2004-12, 2004-10 I.R.B.556
2004-13, 2004-12 I.R.B.631
2004-14, 2004-9 I.R.B.526
2004-15, 2004-9 I.R.B.526
2004-16, 2004-9 I.R.B.527
2004-17, 2004-11 I.R.B.605
2004-18, 2004-11 I.R.B.605
2004-19, 2004-11 I.R.B.606
2004-20, 2004-11 I.R.B.608
2004-21, 2004-11 I.R.B.609
2004-22, 2004-12 I.R.B.632
2004-23, 2004-15 I.R.B.725
2004-24, 2004-13 I.R.B.642
2004-25, 2004-15 I.R.B.727
2004-26, 2004-16 I.R.B.782
2004-27, 2004-16 I.R.B.782
2004-28, 2004-16 I.R.B.783
2004-29, 2004-17 I.R.B.828
2004-30, 2004-17 I.R.B.828
2004-31, 2004-17 I.R.B.830
2004-32, 2004-18 I.R.B.847
2004-33, 2004-18 I.R.B.847
2004-34, 2004-18 I.R.B.848
2004-35, 2004-19 I.R.B.889
2004-36, 2004-19 I.R.B.889
2004-37, 2004-21 I.R.B.947
2004-38, 2004-21 I.R.B.949
2004-39, 2004-22 I.R.B.982
2004-40, 2004-23 I.R.B.1028
2004-42, 2004-25 I.R.B.1075
Proposed Regulations:
REG-106590-00, 2004-14 I.R.B.704
REG-116664-01, 2004-3 I.R.B.319
REG-129447-01, 2004-19 I.R.B.894
REG-106681-02, 2004-18 I.R.B.852
REG-122379-02, 2004-5 I.R.B.392
Proposed Regulations— Continued:
REG-139792-02, 2004-20 I.R.B.926
REG-139845-02, 2004-5 I.R.B.397
REG-140492-02, 2004-23 I.R.B.1031
REG-148399–02, 2004-24 I.R.B.1066
REG-165579-02, 2004-13 I.R.B.651
REG-166012-02, 2004-13 I.R.B.655
REG-115471-03, 2004-14 I.R.B.706
REG-116564-03, 2004-20 I.R.B.927
REG-121475-03, 2004-16 I.R.B.793
REG-126459-03, 2004-6 I.R.B.437
REG-126967-03, 2004-10 I.R.B.566
REG-128309-03, 2004-16 I.R.B.800
REG-128590-03, 2004-21 I.R.B.952
REG-149752-03, 2004-14 I.R.B.707
REG-153172-03, 2004-15 I.R.B.729
REG-156232-03, 2004-5 I.R.B.399
REG-156421-03, 2004-10 I.R.B.571
REG-167217-03, 2004-9 I.R.B.540
REG-167265-03, 2004-15 I.R.B.730
Revenue Procedures:
2004-1, 2004-1 I.R.B.1
2004-2, 2004-1 I.R.B.83
2004-3, 2004-1 I.R.B.114
2004-4, 2004-1 I.R.B.125
2004-5, 2004-1 I.R.B.167
2004-6, 2004-1 I.R.B.197
2004-7, 2004-1 I.R.B.237
2004-8, 2004-1 I.R.B.240
2004-9, 2004-2 I.R.B.275
2004-10, 2004-2 I.R.B.288
2004-11, 2004-3 I.R.B.311
2004-12, 2004-9 I.R.B.528
2004-13, 2004-4 I.R.B.335
2004-14, 2004-7 I.R.B.489
2004-15, 2004-7 I.R.B.490
2004-16, 2004-10 I.R.B.559
2004-17, 2004-10 I.R.B.562
2004-18, 2004-9 I.R.B.529
2004-19, 2004-10 I.R.B.563
2004-20, 2004-13 I.R.B.642
2004-21, 2004-14 I.R.B.702
2004-22, 2004-15 I.R.B.727
2004-23, 2004-16 I.R.B.785
2004-24, 2004-16 I.R.B.790
2004-25, 2004-16 I.R.B.791
2004-26, 2004-19 I.R.B.890
2004-27, 2004-17 I.R.B.831
2004-28, 2004-22 I.R.B.984
2004-29, 2004-20 I.R.B.918
2004-30, 2004-21 I.R.B.950
2004-31, 2004-22 I.R.B.986
2004-32, 2004-22 I.R.B.988
2004-33, 2004-22 I.R.B.989
2004-34, 2004-22 I.R.B.991
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2003–27 through 2003–52 is in Internal Revenue Bulletin
2003–52, dated December 29, 2003.
2004-25 I.R.B.iiJune 21, 2004

Revenue Procedures— Continued:
2004-35, 2004-23 I.R.B.1029
2004-36, 2004-24 I.R.B.1063
Revenue Rulings:
2004-1, 2004-4 I.R.B.325
2004-2, 2004-2 I.R.B.265
2004-3, 2004-7 I.R.B.486
2004-4, 2004-6 I.R.B.414
2004-5, 2004-3 I.R.B.295
2004-6, 2004-4 I.R.B.328
2004-7, 2004-4 I.R.B.327
2004-8, 2004-10 I.R.B.544
2004-9, 2004-6 I.R.B.428
2004-10, 2004-7 I.R.B.484
2004-11, 2004-7 I.R.B.480
2004-12, 2004-7 I.R.B.478
2004-13, 2004-7 I.R.B.485
2004-14, 2004-8 I.R.B.511
2004-15, 2004-8 I.R.B.515
2004-16, 2004-8 I.R.B.503
2004-17, 2004-8 I.R.B.516
2004-18, 2004-8 I.R.B.509
2004-19, 2004-8 I.R.B.510
2004-20, 2004-10 I.R.B.546
2004-21, 2004-10 I.R.B.544
2004-22, 2004-10 I.R.B.553
2004-23, 2004-11 I.R.B.585
2004-24, 2004-10 I.R.B.550
2004-25, 2004-11 I.R.B.587
2004-26, 2004-11 I.R.B.598
2004-27, 2004-12 I.R.B.625
2004-28, 2004-12 I.R.B.624
2004-29, 2004-12 I.R.B.627
2004-30, 2004-12 I.R.B.622
2004-31, 2004-12 I.R.B.617
2004-32, 2004-12 I.R.B.621
2004-33, 2004-12 I.R.B.628
2004-34, 2004-12 I.R.B.619
2004-35, 2004-13 I.R.B.640
2004-36, 2004-12 I.R.B.620
2004-37, 2004-11 I.R.B.583
2004-38, 2004-15 I.R.B.717
2004-39, 2004-14 I.R.B.700
2004-40, 2004-15 I.R.B.716
2004-41, 2004-18 I.R.B.845
2004-42, 2004-17 I.R.B.824
2004-43, 2004-18 I.R.B.842
2004-44, 2004-19 I.R.B.885
2004-45, 2004-22 I.R.B.971
2004-46, 2004-20 I.R.B.915
2004-47, 2004-21 I.R.B.941
2004-48, 2004-21 I.R.B.945
2004-49, 2004-21 I.R.B.939
2004-50, 2004-22 I.R.B.977
2004-51, 2004-22 I.R.B.974
2004-52, 2004-22 I.R.B.973
2004-53, 2004-23 I.R.B.1026
Revenue Rulings— Continued:
2004-54, 2004-23 I.R.B.1024
2004-56, 2004-24 I.R.B.1055
2004-57, 2004-24 I.R.B.1048
2004-58, 2004-24 I.R.B.1043
2004-59, 2004-24 I.R.B.1050
2004-60, 2004-24 I.R.B.1051
2004-61, 2004-25 I.R.B.1073
2004-62, 2004-25 I.R.B.1072
Tax Conventions:
2004-3, 2004-7 I.R.B.486
2004-52, 2004-24 I.R.B.1071
Treasury Decisions:
9099, 2004-2 I.R.B.255
9100, 2004-3 I.R.B.297
9101, 2004-5 I.R.B.376
9102, 2004-5 I.R.B.366
9103, 2004-3 I.R.B.306
9104, 2004-6 I.R.B.406
9105, 2004-6 I.R.B.419
9106, 2004-5 I.R.B.384
9107, 2004-7 I.R.B.447
9108, 2004-6 I.R.B.429
9109, 2004-8 I.R.B.519
9110, 2004-8 I.R.B.504
9111, 2004-8 I.R.B.518
9112, 2004-9 I.R.B.523
9113, 2004-9 I.R.B.524
9114, 2004-11 I.R.B.589
9115, 2004-14 I.R.B.680
9116, 2004-14 I.R.B.674
9117, 2004-15 I.R.B.721
9118, 2004-15 I.R.B.718
9119, 2004-17 I.R.B.825
9120, 2004-19 I.R.B.881
9121, 2004-20 I.R.B.903
9122, 2004-19 I.R.B.886
9123, 2004-20 I.R.B.907
9124, 2004-20 I.R.B.901
9125, 2004-23 I.R.B.1012
9126, 2004-23 I.R.B.1023
9127, 2004-24 I.R.B.1042
9128, 2004-21 I.R.B.943
9129, 2004-24 I.R.B.1046
June 21, 2004iii2004-25 I.R.B.

Findings List of Current Actions on
Previously Published Items
1
Bulletins 2004–1 through 2004–25
Announcements:
93-60
Obsoleted by
Rev. Proc. 2004-23, 2004-16 I.R.B.785
2003-56
Modified by
Ann. 2004-11, 2004-10 I.R.B.581
2004-38
Modified by
Ann. 2004-43, 2004-21 I.R.B.955
2004-43
Corrected by
Ann. 2004-51, 2004-23 I.R.B.1041
Notices:
98-5
Withdrawn by
Notice 2004-19, 2004-11 I.R.B.606
2000-4
Obsoleted by
T.D. 9115, 2004-14 I.R.B.680
2002-31
Modified by
Rev. Rul. 2004-60, 2004-24 I.R.B.1051
2003-76
Modified by
Notice 2004-19, 2004-11 I.R.B.606
2004–2
Modified by
Notice 2004–25, 2004–15 I.R.B.727
Proposed Regulations:
REG-110896-98
Corrected by
Ann. 2004-14, 2004-10 I.R.B.582
REG-115037-00
Corrected by
Ann. 2004-7, 2004-4 I.R.B.365
REG-138499-02
Partially withdrawn by
REG-106590-00, 2004-14 I.R.B.704
REG-143321-02
Withdrawn by
REG-156232-03, 2004-5 I.R.B.399
REG-146893-02
Corrected by
Ann. 2004-7, 2004-4 I.R.B.365
Proposed Regulations— Continued:
REG-163974-02
Corrected by
Ann. 2004-13, 2004-9 I.R.B.543
REG-166012-02
Corrected by
Ann. 2004-40, 2004-17 I.R.B.840
Revenue Procedures:
71-21
Modified and superseded by
Rev. Proc. 2004-34, 2004-22 I.R.B.991
85-35
Obsoleted by
Rev. Proc. 2004-26, 2004-19 I.R.B.890
87-19
Obsoleted in part by
Rev. Proc. 2004-18, 2004-9 I.R.B.529
93-15
Obsoleted in part by
Rev. Proc. 2004-18, 2004-9 I.R.B.529
94-41
Superseded by
Rev. Proc. 2004-15, 2004-7 I.R.B.490
94-55
Obsoleted in part by
Rev. Proc. 2004-18, 2004-9 I.R.B.529
98-16
Suspended by
Notice 2004-12, 2004-10 I.R.B.556
2000-38
Modified by
Rev. Proc. 2004-11, 2004-3 I.R.B.311
2000-50
Modified by
Rev. Proc. 2004-11, 2004-3 I.R.B.311
2001-10
Modified by
Ann. 2004-16, 2004-13 I.R.B.668
2001-23
Modified by
Ann. 2004-16, 2004-13 I.R.B.668
2002-9
Modified and amplified by
Rev. Rul. 2004-18, 2004-8 I.R.B.509
Rev. Rul. 2004-62, 2004-25 I.R.B.1072
Rev. Proc. 2004-23, 2004-16 I.R.B.785
Rev. Proc. 2004-30, 2004-21 I.R.B.950
Rev. Proc. 2004-32, 2004-22 I.R.B.988
Rev. Proc. 2004-33, 2004-22 I.R.B.989
Rev. Proc. 2004-34, 2004-22 I.R.B.991
Rev. Proc. 2004-36, 2004-24 I.R.B.1063
Revenue Procedures— Continued:
Modified by
Rev. Proc. 2004-11, 2004-3 I.R.B.311
Ann. 2004-16, 2004-13 I.R.B.668
2002-28
Modified by
Ann. 2004-16, 2004-13 I.R.B.668
2002-71
Superseded by
Rev. Proc. 2004-13, 2004-4 I.R.B.335
2003-1
Superseded by
Rev. Proc. 2004-1, 2004-1 I.R.B.1
2003-2
Superseded by
Rev. Proc. 2004-2, 2004-1 I.R.B.83
2003-3
As amplified by Rev. Proc. 2003-14, and as
modified by Rev. Proc. 2003-48 superseded by
Rev. Proc. 2004-3, 2004-1 I.R.B.114
2003-4
Superseded by
Rev. Proc. 2004-4, 2004-1 I.R.B.125
2003-5
Superseded by
Rev. Proc. 2004-5, 2004-1 I.R.B.167
2003-6
Superseded by
Rev. Proc. 2004-6, 2004-1 I.R.B.197
2003-7
Superseded by
Rev. Proc. 2004-7, 2004-1 I.R.B.237
2003-8
Superseded by
Rev. Proc. 2004-8, 2004-1 I.R.B.240
2003-23
Modified and superseded by
Rev. Proc. 2004-14, 2004-7 I.R.B.489
2003-26
Supplemented by
Rev. Proc. 2004-17, 2004-10 I.R.B.562
2003-29
Obsoleted, except as provided in section 5.02, by
Rev. Proc. 2004-24, 2004-16 I.R.B.790
2003-64
Modified by
Rev. Proc. 2004-21, 2004-14 I.R.B.702
2004-1
Corrected by
Ann. 2004-8, 2004-6 I.R.B.441
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2003–27 through 2003–52 is in Internal Revenue Bulletin 2003–52, dated December 29,
2003.
2004-25 I.R.B.ivJune 21, 2004

Revenue Procedures— Continued:
2004-4
Modified by
Rev. Proc. 2004-15, 2004-7 I.R.B.490
2004-5
Modified by
Rev. Proc. 2004-15, 2004-7 I.R.B.490
2004-6
Modified by
Rev. Proc. 2004-15, 2004-7 I.R.B.490
Revenue Rulings:
55-748
Modified and superseded by
Rev. Rul. 2004-20, 2004-10 I.R.B.546
92-19
Supplemented in part by
Rev. Rul. 2004-14, 2004-8 I.R.B.511
94-38
Clarified by
Rev. Rul. 2004-18, 2004-8 I.R.B.509
98-25
Clarified by
Rev. Rul. 2004-18, 2004-8 I.R.B.509
2004-38
Modified by
Rev. Proc. 2004-22, 2004-15 I.R.B.727
Treasury Decisions:
9088
Corrected by
Ann. 2004-39, 2004-17 I.R.B.840
June 21, 2004v2004-25 I.R.B.
*U.S. Government Printing Office: 2004—304–778/60140