us-irs-announcements-irb-1997-26-pdf•Internal Revenue Bulletin 1997-26 (PDF rendition): IRS Announcements
Internal Revenue Bulletin 1997-26 (PDF rendition): IRS Announcements
us-irs-announcements-irb-1997-26-pdfInternal Revenue Bulletin 1997-26 (PDF rendition): IRS AnnouncementsGuidance
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 Notice 97–36, page 6. Net operating losses; specified liability losses.Taxpay- ers are informed that the characterization of certain net operating losses as specified liability losses under Code section 172(f) is improper, and that the Ser vice will closely scrutinize claims for refund and applications for tentative carr yback adjustments that are attributed to specified liability losses. EXEMPT ORGANIZATIONS Announcement 97–63, page 8. A list is given of organizations now classified as private foundations. Announcement 97–65, page 9. The Christian Home Endowment Foundation, Wilmington, DE, no longer qualifies as an organization to which contributions are deductible under section 170 of the Code. Announcement 97–66, page 9. Announcement 97–54, 1997–22 I.R.B. 23, regarding the names of organizations that no longer qualify as organi- zations described in section 170(c)(2) of the Code, is corrected. EMPLOYMENT TAX T.D. 8721, page 4. Final regulations under section 3406 of the Code relate to the establishment of Taxpayer Identification Number (TIN) matching programs and remove the temporar y regulations pertaining to the establishment of the TIN matching program. ADMINISTRATIVE Rev. Proc. 97–31, page 6. TIN matching; backup withholding.Procedures are provided under which federal agencies may submit the payee name and taxpayer identification number combina- tions. The Ser vice will inform the agency whether the names and TINs match the information in the Ser vice’s database for this program. Announcement 97–64, page 9. This announcement clarifies the 1997 Form W–2 instruc- tions for reporting employer-provided adoption benefits. Finding Lists begin on page 14. Announcement of Disbarments and Suspensions begins on page 10. Bulletin No. 1997–26 June 30, 1997 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. Mission of the Service The purpose of the Internal Revenue Ser vice is to collect the proper amount of tax revenue at the least cost; ser ve the public by continually improving the quality of our products and ser vices; and per form in a manner warranting the highest degree of public confidence in our integrity, efficiency, and fairness. Statement of Principles of Internal Revenue Tax Administration The function of the Internal Revenue Ser vice is to administer the Internal Revenue Code. Tax policy for raising revenue is determined by Congress. With this in mind, it is the duty of the Ser vice to carr y out that policy by correctly applying the laws enacted by Congress; to determine the reasonable meaning of various Code provisions in light of the Congressional purpose in enacting them; and to per form this work in a fair and impartial manner, with neither a government nor a taxpayer point of view. At the heart of administration is interpretation of the Code. It is the responsibility of each person in the Ser vice, charged with the duty of interpreting the law, to tr y to find the true meaning of the statutor y provision and not to adopt a strained construction in the belief that he or she is ‘‘protecting the revenue.’’ The revenue is properly protected only when we as- certain and apply the true meaning of the statute. The Ser vice also has the responsibility of applying andadministeringthelawinareasonable, practical manner. Issues should only be raised by examining of ficers when they have merit, never arbitrarily or for trading purposes. At the same time, the examining officer should never hesitate to raise a meritorious issue. It is also important that care be exercised not to raise an issue or to ask a court to adopt a position inconsistent with an established Ser vice position. Administration should be both reasonable and vigorous. It should be conducted with as little delay as possible and with great cour tesy and considerateness. It should never tr y to overreach, and should be reasonable within the bounds of law and sound administration. It should, however, be vigorous in requiring compliance with law and it should be relentless in its attack on unreal tax devices and fraud. 2 Introduction The Internal Revenue Bulletin is the authoritative instru- ment of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Inter- nal Revenue Ser vice and for publishing Treasur y Deci- sions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It is published weekly and may be obtained from the Superin- tendent of Documents on a subscription basis. Bulletin contents of a permanent nature are consolidated semi- annually into Cumulative Bulletins, which are sold on a single-copy basis. It is the policy of the Ser vice to publish in the Bulletin all substantive rulings necessar y 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. Proce- dures relating solely to matters of internal 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 Ser- vice 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 Ser vice field offices, identifying details and information of a confidential nature are deleted to prevent unwar- ranted invasions of privacy and to comply with statutor y requirements. Rulings and procedures reported in the Bulletin do not have the force and effect of Treasur y Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Ser vice personnel in the disposition of other cases. In applying published rulings and proce- dures, the effect of subsequent legislation, regulations, court decisions, rulings, and procedures must be consid- ered, and Ser vice 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.—1986 Code. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1986. Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions, and Subpart B, Legislation and Related Committee Reports. Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Subparts. Also included in this part are Bank Secrecy Act Administrative Rulings. Bank Secrecy Act Administra- tive Rulings are issued by the Department of the Treasur y’s Office of the Assistant Secretar y (Enforce- ment). Part IV.—Items of General Interest. With the exception of the Notice of Proposed Rulemak- ing and the disbarment and suspension list included in this part, none of these announcements are consoli- dated in the Cumulative Bulletins. 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 quarterly and semiannual basis, and are published in the first Bulletin of the succeeding quarterly and semi- annual period, respectively. 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, D.C. 20402. 3 Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 Section 3406.—Backup Withholding 26 CFR 31.3406(j)–1: Taxpayer Identification Number (TIN) matching program. T.D. 8721 DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Parts 31 and 35a Taxpayer Identification Number (TIN) Matching Program AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Final and temporary regula- tions. SUMMARY: This document contains fi- nal regulations on the establishment of Taxpayer Identification Number (TIN) matching programs and removes the temporary regulations on the establish- ment of a TIN matching program. These regulations reflect changes to the law made by the Interest and Dividend Tax Compliance Act of 1983. They affect payors, brokers, and payees of certain reportable payments and provide guid- ance necessary to comply with the law. DATES: These regulations are effective June 18, 1997. FORFURTHERINFORMATION CONTACT: Renay France, (202) 622– 6232 (not a toll-free call). SUPPLEMENTARY INFORMATION: Background On March 22, 1994, the Internal Revenue Service (IRS) published pro- posed (IA–8–92[1994–1 C.B. 795]) and temporary regulations (T.D. 8523 [1994– 1 C.B. 271]) in theFederal Register (59 FR 13470 and 13455, respectively) for the establishment of a TIN matching program (the matching program) by the Commissioner. The proposed regulations would allow payors to check the accu- racy of a name/TIN combination before filing the related information return. The proposed regulations solicited written comments and set a date for a public hearing on the regulations. No one re- quested to speak at the hearing; there- fore, none was held. The proposed regulations provide that a payor’s decision whether to participate in the matching program and any match- ing details received through the match- ing program are not taken into account in determining whether a payor has reasonable cause under section 6724(a) that will avoid a penalty under section 6721(a) for the failure to file a correct information return or under section 6722 for the failure to furnish a correct payee statement. Several commentators sug- gested that if a payor submits a name/ TIN combination under the matching program and is not informed by the IRS that the TIN is incorrect, the payor will have established reasonable cause under section 6724(a) should the IRS later determine that the same TIN filed on a subsequent information return is incor- rect. In response to the comment, the final regulations provide that neither a payor’s nonparticipation in a matching program nor the results obtained from participating in a matching program will adversely affect the payor’s reasonable cause defense and that the extent to which a payor may establish reasonable cause by participating in a TIN match- ing program will be set forth in the guidance establishing the program. Additional comments suggested modi- fication of IRS information returns (Forms 1099). A modified form would allow a payor to indicate that it con- tacted the IRS for matching of the name/TIN combination on the informa- tion return and was not informed that the name/TIN combination was incor- rect. The IRS will consider the feasibil- ity of adopting this suggestion when a TIN matching program is established. The Prototype On May 9, 1994, the IRS instituted a two-year prototype of an online TIN matching program to test its operational feasibility on a nationwide basis. The prototype permitted a maximum of 200 payors of reportable payments, as de- fined in section 3406(b)(1), to volunteer to participate in the prototype and have their payees’ name/TIN combinations matched with records of the IRS prior to filing the related information return. The prototype operated for only eleven months; a fire destroyed the computer system dedicated to this project. During the operation of the prototype approxi- mately 120 payors made 55,795 name/ TIN inquiries. Due to fiscal constraints, the IRS has no current plans to implement a TIN matching program that will be available to all payors of reportable payments and has no current plans to replace the destroyed computer system needed to implement an online TIN matching pro- gram. Explanation of Provisions The final regulations permit the IRS to establish varied matching programs by published guidance as circumstances warrant. In general, under a matching program, a participating payor of a reportable payment (as defined in sec- tion 3406(b)(1) of the Internal Revenue Code) may, prior to filing an informa- tion return, contact the IRS concerning the TIN furnished by a payee. Upon receiving the inquiry, the IRS will in- form the payor whether or not the name/TINcombinationfurnished matches any name/TIN combination maintained by the IRS. (Informing a payor of a nonmatch will not constitute a notice to commence backup withhold- ing under section 3406(a)(1)(B) due to an incorrect name/TIN combination.) If the name/TIN combination does not match, the payor has the opportunity to contact the payee for correction before filing an information return, thus reduc- ing the likelihood that the payor will be notified to start backup withholding un- der section 3406(a)(1)(B). In order to assist a payor to obtain correct name/ TIN combinations, a particular matching program may categorize nonmatching name/TIN combinations. For example, the matching program may indicate that the TIN is assigned to another name in the data base being used or that the TIN is not assigned in the data base being used. Pursuant to the authority contained in the final regulations, the IRS will imple- ment a TIN matching program for fed- eral agencies. This program will allow federal agencies to request that the IRS match the name/TIN combinations of vendors to whom the agencies make payments reportable under section 6041. The operational details of this matching program are set forth in Revenue Proce- dure 97–31, appearing in the Internal Revenue Bulletin 1997–26, dated June 30, 1997. Special Analyses It has been determined that this Trea- sury decision is not a significant regula- tory action as defined in EO 12866. Therefore, a regulatory assessment is not required. It also has been determined June 30, 1997 41997–26 I.R.B. that section 553(b) of the Administrative Procedure Act (5 U.S.C. chapter 5) does not apply to these regulations, and be- cause the notice of proposed rulemaking preceding the regulations was issued prior to March 29, 1996, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not apply. Pursuant to section 7805(f) of the Internal Revenue Code, the IRS submitted the notice of proposed rulemaking preceding these regulations to the Chief Counsel for Advocacy of the Small Business Administration for comment on their impact on small busi- ness. Drafting Information The principal author of these regula- tions is Renay France, Office of the Assistant Chief Counsel (Income Tax and Accounting), IRS. However, other personnel from the IRS and Treasury Department participated in their devel- opment. ***** Adoption of Amendments to the Regula- tions Accordingly, 26 CFR parts 31 and 35a are amended as follows: PART 31—EMPLOYMENT TAXES AND COLLECTION OF INCOME TAX AT SOURCE Paragraph 1. The authority citation for part 31 is amended by adding the following entry in numerical order to read as follows: Authority: 26 U.S.C. 7805 * * * Section 31.3406(j)–1 also issued under 26 U.S.C. 3406(i). * * * Par. 2. Section 31.3406(j)–1 is added to subpart E to read as follows: § 31.3406(j)–1 Taxpayer Identification Number (TIN) matching program. (a)The matching program.Under section 3406(i), the Commissioner has the authority to establish Taxpayer Iden- tification Number (TIN) matching pro- grams. The Commissioner may prescribe in a revenue procedure (see § 601.601- (d)(2) of this chapter) or other appropri- ate guidance the scope of and the terms and conditions of participating in any TIN matching program. In general, un- der a matching program, prior to filing information returns with respect to re- portable payments as defined under sec- tion 3406(b)(1), a payor of those report- able payments who is entitled to participate in the matching program may contact the Internal Revenue Service (IRS) with respect to the TIN furnished by a payee who has received or is likely to receive a reportable payment. The IRS will inform the payor whether or not a name/TIN combination furnished by the payee matches a name/TIN com- bination maintained in the data base utilized for the particular matching pro- gram. (b)Notice of incorrect TIN.No matching details received by a payor through a matching program will constitute a notice regarding an in- correct name/TIN combination under § 31.3406(d)–5(c) for purposes of im- posing backup withholding under sec- tion 3406(a)(1)(B). (c)Application of section 3406(f). The provisions of section 3406(f), relat- ing to confidentiality of information, apply to any matching details received by a payor through the matching pro- gram. A payor may not take into ac- count any such matching details in de- termining whether to open or close an account with a payee. (d)Reasonable cause.The IRS will not use either a payor’s decision not to participate in an available TIN matching program or the results received by a payor from participation in a TIN matching program implemented under the authority of this section as a basis to assert that the payor lacks reasonable cause under section 6724(a) for the failure to file an information return under section 6721 or to furnish a correct payee statement under section 6722. If the establishment of reasonable cause may be relevant to a substantial number of the participants in a TIN matching program implemented under the authority of this section, the extent to which, if any, a payor may establish reasonable cause by participating in the TIN matching program will be set forth in the guidance establishing the pro- gram. (e)Definition of account.Account means any account, instrument, or other relationship with a payor and with re- spect to which a payor has made or is likely to make a reportable payment as defined in section 3406(b)(1). (f)Effective date. The provisions of this section are effective on and after June 18, 1997. PART 35a—TEMPORARY EMPLOYMENT TAX REGULATIONS UNDER THE INTEREST AND DIVIDEND TAX COMPLIANCE ACT OF 1983 Par. 3. The authority citation for part 35a is amended by removing the entry for § 35a.3406–3 to read in part as follows: Authority: 26 U.S.C. 7805. * * * § 35a.3406–3 [Removed] Par. 4. Section 35a.3406–3 is re- moved. Margaret Milner Richardson, Commissioner of Internal Revenue. Donald C. Lubick, Acting Assistant Secretary of the Treasury. (Filed by the Office of the Federal Register on June 18, 1997, 8:45 a.m., and published in the issue of the Federal Register for 62 F.R. 33008) 1997–26 I.R.B.5June 30, 1997 Part III. Administrative, Procedural, and Miscellaneous Specified Liability Losses Notice 97–36 This notice addresses the improper characterization by some taxpayers of net operating losses as specified liability losses under § 172(f)(1)(B)(i) of the Internal Revenue Code. In addition, this notice informs taxpayers that the Inter- nal Revenue Service will closely scruti- nize claims for refund and applications for tentative carryback adjustments un- der § 6411(a) that the taxpayer at- tributes to a specified liability loss under § 172(f)(1). Claims for refund filed on Form 1120X, Amended U.S. Corpora- tion Income Tax Return, after June 11, 1997, must identify the specific type of specified liability loss claimed. Section 172(a) permits a deduction for a taxpayer’s net operating loss car- ryovers and carrybacks. Section 172(b)- (1)(A)(i) generally allows a net operat- ing loss to be carried back up to 3 taxable years preceding the taxable year of the loss (the ‘‘loss year’’). However, § 172(b)(1)(C) generally allows the por- tion of a net operating loss qualifying as a specified liability loss to be carried back up to 10 taxable years preceding the loss year. Section172(f)(1)(B)(i)includes within the term ‘‘specified liability loss’’ the portion of a net operating loss attributable to an amount allowable as a deduction under Chapter 1 of the Code with respect to a liability arising out of a federal or state law if the act (or failure to act) giving rise to the liability occurs at least 3 years before the begin- ning of the loss year (the ‘‘3-year act requirement’’). The Service has received income tax refund claims based on the carryback of amounts purported to be specified liabil- ity losses that rely on incorrect interpre- tations of § 172(f)(1)(B)(i). These claims inappropriately treat as specified liability losses amounts attributable to routine current year costs. For example, some taxpayers interpret the 3-year act requirement to be satisfied if they can identify a connection between the liabil- ity and any act (or failure to act) occurring at least 3 years before the loss year, no matter how remote the connec- tion between the liability and the act. Thus, they claim that current year costs, such as auditing fees incurred to comply with federal securities law requirements to file independently certified annual financial statements, are specified liabil- ity losses. The premise of the claim is that the act giving rise to these annual fees was the corporation’s first public stock offering, which caused the corpo- ration to become subject to federal secu- rities laws, and this act occurred at least 3 years before the loss year. The Service believes that interpreting the specified liability loss provisions in this manner is plainly contrary to the intent and purpose of § 172(f)(1)(B)(i), and that expenses such as those de- scribed above do not give rise to speci- fied liability losses. The Treasury De- partment and the Service intend to issue regulations that will address the require- ments of § 172(f)(1)(B). In addition, the Service will closely scrutinize claims for refund and applications for tentative carryback adjustments under § 6411(a) that the taxpayer attributes to a specified liability loss under § 172(f)(1)(B). A taxpayer that files Form 1120X after June 11, 1997, to claim a refund based, in whole or in part, on the carryback of any specified liability loss must identify, in Part II of the form, the portion of the loss attributable to a product liability and the portion attributable to a federal or state law or tort liability. DRAFTINGINFORMATION: The principal author of this notice is Forest Boone of the Office of Assistant Chief Counsel (Income Tax and Accounting). For further information regarding this notice, contact Mr. Boone at (202) 622– 4960 (not a toll-free call). 26 CFR 601.602: Tax forms and instructions. (Also Part I, Section 3406; 31.3406(d)–5.) Rev. Proc. 97–31 SECTION 1. PURPOSE This revenue procedure sets forth pro- cedures for the Federal Agency TIN Matching Program (Program). Under the Program, a participating federal agency may, prior to filing an information re- turn with respect to a payee, submit to the Internal Revenue Service the Tax- payer Identification Number (TIN) fur- nished by the payee. The Service then will inform the agency whether or not the name/TIN combination furnished by the payee matches a name/TIN combi- nation maintained by the Service in the data base utilized for the Program. The Program is intended to reduce the num- ber of notices of an incorrect name/TIN combination issued under § 31.3406(d)– 5(c) of the Employment Tax Regulations for backup withholding purposes under section 3406(a)(1)(B) of the Internal Revenue Code. SECTION 2. BACKGROUND .01 Section 3406(a)(1) provides that backup withholding applies when a re- portable payment is made to an account if either: (1) the payor has not received the payee’s TIN at the time of the payment, or (2) the TIN furnished by the payee to the payor has been determined to be incorrect and the payee has not fur- nished the correct TIN in a timely manner. .02 Section 31.3406(j)–1(a) provides that the Commissioner has the authority to establish TIN matching programs and may prescribe by revenue procedure or other guidance the terms and conditions for participating in such a program. .03 Section 31.3406(j)–1(b) provides that no matching details received by a payor through a TIN matching program will constitute a notice regarding an incorrect name/TIN combination under § 31.3406(d)–5(c). .04 Section 31.3406(j)–1(c) provides that § 3406(f), relating to confidentiality of information, applies to any matching details received by a payor through a TIN matching program. A payor may not take into account any such matching details in determining whether to open or close an account with a payee. SECTION 3. DEFINITIONS .01 The term ‘‘agency’’ means a fed- eral agency that files information returns reflecting reportable payments made by that agency. .02 The term ‘‘participant’’ means an agency that has been accepted to partici- pate in the Program. .03 The term ‘‘payee’’ means a per- son with respect to whom a reportable payment (as defined in § 3406(b)(1)) has been made or is likely to be made by an agency. .04 The term ‘‘account’’ means any account, instrument, or other relation- ship with a payee (such as a contract) with respect to which an agency has made or is likely to make a reportable payment.See§ 31.3406(j)–1(e). .05 For purposes of this revenue pro- cedure, the term ‘‘TIN’’ means the Tax- June 30, 1997 61997–26 I.R.B. payer Identification Number of a payee that is either an Employer Identification Number (EIN), a Social Security Num- ber (SSN), or an IRS Individual Tax- payer Identification Number (ITIN). SECTION 4. SCOPE This revenue procedure applies only to agencies that have applied and been accepted to participate in the Program under section 5 of this revenue proce- dure. Agencies may submit data only after being accepted as participants in the Program. Further, participants may submit name/TIN data only with respect to account payments made on or after January 1, 1997. Publication 2108, Specifications for Federal Agencies, TIN Matching Program, contains the format and processing specifications for trans- mitting the name/TIN data and the pro- cedures for operation of the Program. The Program does not permit online or other direct access by a participant to Service or Social Security Administra- tion databases. SECTION 5. APPLICATION AND ACCEPTANCE .01Memorandum of Understanding. To apply to participate in the Program, an agency must submit two completed copies of the form Memorandum of Understanding (MOU), as provided in Publication 2108, setting forth its under- standing of, and agreement to comply with, the requirements of section 6 of this revenue procedure. The completed MOU must include the name of the agency and the name, address, and tele- phone number of a contact person. The MOU must be signed by a duly autho- rized representative of the agency. .02Address for submitting MOU.The completed copies of the MOU must be submitted by the agency to: Internal Revenue Service Office of Payer Compliance CP:EX:ST:PC 1111 Constitution Ave., NW Washington, DC 20224 .03Acceptance.If an agency is ac- cepted to participate in the Program, the Service will return one signed copy of the MOU to the agency and assign the agency a Transmitter Control Code (TCC). Upon receipt of the accepted MOU, the agency may begin submitting name/TIN data in accordance with the instructions in Publication 2108 and the MOU. SECTION 6. REQUIREMENTS FOR PARTICIPATION Participants in the Program must: .01 comply with all requirements of this revenue procedure, Publication 2108, and the MOU; .02 transmit for matching only name/ TIN combinations relating to accounts (as defined in section 3.04 of this rev- enue procedure) with respect to which a reportable payment is made, or likely to be made, on or after January 1, 1997; .03 transmit only name/TIN combina- tions that have not been previously transmitted for matching by that partici- pant; .04 use information obtained from the Program only for backup withholding purposes, and not disclose or use this information for any unauthorized or pro- hibited purpose.See§ 3406(f); .05 use only the TCC provided by the Service; and .06 cooperate fully in providing to the Service necessary information so the Service can measure the effectiveness and correct use of the Program. SECTION 7. EFFECTIVE DATE The Service intends that the Program will be operational beginning on the later of July 1, 1997, or the date the necessary updates to the relevant sys- tems of records are effective. However, the Service will accept an MOU from an agency wishing to participate in the Program and name/TIN data transmitted by a participant beginning on June 18, 1997. DRAFTING INFORMATION The principal authors of this revenue procedure are Luetta Donalds of the Office of Payer Compliance and Nancy Rose of the Office of Assistant Chief Counsel (Income Tax and Accounting). For further information regarding this revenue procedure, contact Ms. Donalds at (202) 622–8753, or Ms. Rose at (202) 622-4910 (not toll-free calls). 1997–26 I.R.B.7June 30, 1997 Part IV. Items of General Interest Foundations Status of Certain Organizations Announcement 97–63 The following organizations have failed to establish or have been unable to maintain their status as public chari- ties or as operating foundations. Accord- ingly, grantors and contributors may not, after this date, rely on previous rulings or designations in the Cumulative List of Organizations (Publication 78), or on the presumption arising from the filing of notices under section 508(b) of the Code. This listing doesnotindicate that the organizations have lost their status as organizations described in section 501(c)(3), eligible to receive deductible contributions. Former Public Charities. The follow- ing organizations (which have been treated as organizations that are not private foundations described in section 509(a) of the Code) are now classified as private foundations: Alternative Lifestyle Scholarship Organization, Inc., Los Angeles, CA American Association for the Advance of Atheism, Inc., San Diego, CA American Association of Center Cancer Registries, Inc., Santa Barbara, CA American Educational Development Agency, Oakland, CA American Homeowners Resource Center, San Juan Capistrano, CA American Therapeutic Recreation, Hattiesburg, MS Anaktuvuk Pass Health Corporation, Anaktuvuk Pass, AK Angelica Group Homes Thomas & Williams Foundation, La Verne, CA Animal Support Foundation of Lewis County, Winlock, WA Another Helping Hand, Los Angeles, CA Barrow-Civic Theatre Foundation, Pittsburgh, PA Bedford Historical Foundation Inc., Bedford, TX Boyertown Wrestling Demons, Boyertown, PA Breakfast Optimist Club of Dundalk Foundation, Inc., Dundalk, MD Broken Heart Ministries, Newport, TN CAPRA Inc., Charlottesville, VA Catoctin Foundation, Waterford, VA Central Florida Alliance of the SE Consortium Minorities Engineering, Merritt Island, FL Central Pecos Valley Jim Wilson Crusade, Inc., Hope, NM Child Development and Training Centers of Virginia, Inc., Virginia Beach, VA Coalition Against Substance Abuse for Jefferson Cocasa, Inc., Madison, IN Colorado Aquarium Inc., Denver, CO Community Service Corporation, Washington, DC Compassionate Ministries Inc., Tulsa, OK Coral Springs City Centre Inc., Coral Springs, FL Creative Housing Resources Inc., Berkley, MI Demand-Side Management Training Institute, Bala Cynwyd, PA Free Flyght Gym Comet Gymnastics, Commerce City, CO Friends & Family Inc., Washington, MI Friends of the American Pilgram Chorus, Los Angeles, CA Friends of the Cape Canaveral Library, Inc., Cape Canaveral, FL Friends of the College Park Airport, Inc., College Park, MD Galveston Central Little League, Galveston, TX Grand Rapids Scottish Society, Grand Rapids, MI Greater Morris County Junior School Coaches Association, Inc., Dover, NJ Greensboro Childrens Museum, Greensboro, NC Guatemalan-Maya Center Inc., Lake Worth, FL Harrison County Historic Preservation, Inc., Marshall, TX Hollywood & Vine Recovery Center, Inc., Los Angeles, CA Horizons Repertory Theatre Inc., Miami, FL Hotba Fire Safety House Project, Waco, TX Housing Our People Inc., Washington, DC Industries for the Blind and Visually Impaired Payne George, Delhi, LA International Catacomb Society, Inc., Boston, MA Islandview Village Development Corporation, Detroit, MI Joy of Downs Camp Many Stars, Spanish Fork, UT Kelly Memorial Geriatric Transporation, Inc., Kerrville, TX Koinonia Ministries and Christian Counseling Center, Ann Arbor, MI Neighborhood Leadership Council, Jacksonvile, FL North Alabama Disabilities Coalition, Huntsville, AL North Texas Child Nutrition Corporation, Plano, TX Northwest Area Health Education Center, Charlottesville, VA Northwest Indiana World Trade Council, Incorporated, Portage, IN Ohana Group, Highland Park, MI Oklahoma Youth Unlimited Incorporated, Tulsa, OK Orange Youth Baseball, Orange, TX Pacific Rim Media Company, Honolulu, HI Parents & Friends for Better Education, Inc., Houma, LA Parents as Partners in Education, Inc., Pueblo, CO Parkway High School Baseball Dugout Club, Bossier City, LA Partnership for the Saginaw Bay Watershed, University Center, MI Pawnee Express Club, Pawnee, OK Pennsylvania Scouters Museum & Activity Center, Pittsburgh, PA Pottsburg Park Resident Management Corporation, Inc., Jacksonville, FL Precious Children Child Care Center, Inc., Columbia, SC Project Win-Winning in Neighborhoods, Inc., Athens, GA Public Park and Recreation Board of Limestone County, Athen, AL Safe Toys for Kids Foundation, Edmond, OK Sarasota Heart Foundation Inc., Sarasota, FL Save Historic Palatka Inc., Palatka, FL School Clothes Make a Difference, Inc., Orlando, FL Spirit of Carver Chorale, Houston, TX Tag Tenn, Nashville, TN Tejano Center for Community Concerns, Inc., Houston, TX UBW Inc., New York, NY United Til Coalition of Harlem Inc., New York, NY Upshur County Senior Citizens Board of Directors, Inc., Gilmer, TX Utah Vascular Access Network-UVAN, Salt Lake City, UT Utica Kiwanis Michael Monicatti Scholarship Foundation, Clinton Twp, MI Val Harrop Foundation, Houston, TX Venue Theatre Collective Inc., St. Petersburg, FL Veterans Workshop of Texas Inc., Dallas, TX Victims of Hurting Childhood Inc., Portland, TN Volusia County Cooperative Health Group, Inc., Daytona Beach, FL June 30, 1997 81997–26 I.R.B. Washington County Child Development Corporation, Hudson Falls, NY Wee-Do-Care Inc., Marks, MS Wellington Kiwanis Foundation Inc., Wellington, FL Wellington Senior Citizens Bus Association, Inc., Wellington, OH Western Colorado Early Childhood Educators, Inc., Grand Junction, CO Youthbuild-Dekalb Inc., Decatur, GA If an organization listed above sub- mits information that warrants the re- newal of its classification as a public charity or as a private operating founda- tion, the Internal Revenue Service will issue a ruling or determination letter with the revised classification as to foundation status. Grantors and contribu- tors may thereafter rely upon such rul- ing or determination letter as provided in section 1.509(a)–7 of the Income Tax Regulations. It is not the practice of the Service to announce such revised classi- fication of foundation status in the Inter- nal Revenue Bulletin. Clarification of 1997 Form W–2 Instructions for Reporting Employer-Provided Adoption Benefits Announcement 97–64 This announcement is to clarify the instructions for reporting the 1997 employer-provided adoption benefits un- der code T in box 13 of Form W–2. Report the total amount paid or reim- bursed by an employer for qualified adoption expenses furnished to an em- ployee under an adoption assistance pro- gram. Also include adoption benefits paid or reimbursed from the pre-tax contributions made by the employee to a section 125 (cafeteria) plan. However, do not include adoption benefits for- feited from a section 125 (cafeteria) plan. Report in box 13 the total benefits paid or reimbursed, including any in excess of the $5,000 or $6,000 exclu- sion. Deletions From Cumulative List of Organizations Contributions to Which Are Deductible Under Section 170 of the Code Announcement 97–65 The name of an organization that no longer qualifies as an organization de- scribed in section 170(c)(2) of the Inter- nal Revenue Code of 1986 is 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 declaratory 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 de- claratory judgment has been timely filed, contributions from individuals and organizations described in section 170(c)(2) that are otherwise allowable will continue to be deductible. Protec- tion under section 7428(c) would begin on June 30, 1997, and would end on the date the court first determines that the organization 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 who was responsible, in whole or in part, for the acts or omissions of the organization that were the basis for revocation. Christian Home Endowment Foundation, Wilmington, DE Correction to Announcement 97–54 Announcement 97–66 Announcement Number 97–54, pub- lished in Internal Revenue Bulletin Number 1997–22, dated June 2, 1997, contained a notice stating that Loving Spirit Foundation, Inc. of Tampa, FL no longer qualified as an organization de- scribed in section 170(c)(2) of the Inter- nal Revenue Code. This notice has been cancelled and Loving Spirit Foundation, Inc. continues to be recognized as an organizationdescribedinsection 170(c)(2) of the Internal Revenue Code. 1997–26 I.R.B.9June 30, 1997 Announcement of the Disbarment, Suspension, or Consent to Voluntary Suspension of Attorneys, Certified Public Accountants, Enrolled Agents, and Enrolled Actuaries From Practice Before the Internal Revenue Service Under 31 Code of Federal Regula- tions, Part 10, an attorney, certified pub- lic accountant, enrolled agent, or en- rolled actuary, in order to avoid the institution or conclusion of a proceeding for his disbarment or suspension from practice before the Internal Revenue Ser- vice, may offer his consent to suspension from such practice. The Director of Practice, in his discretion, may suspend an attorney, certified public accountant, enrolled agent, or enrolled actuary in accordance with the consent offered. Attorneys, certified public accoun- tants, enrolled agents, and enrolled actu- aries are prohibited in any Internal Rev- enue Service matter from directly or indirectly employing, accepting assis- tance from, being employed by or shar- ing fees with, any practitioner disbarred or suspended from practice before the Internal Revenue Service. To enable attorneys, certified public accountants, enrolled agents, and en- rolled actuaries to identify practitioners under consent suspension from practice before the Internal Revenue Service, the Director of Practice will announce in the Internal Revenue Bulletin the names and addresses of practitioners who have been suspended from such practice, their designation as attorney, certified public accountant, enrolled agent, or enrolled actuary and date or period of suspen- sion. This announcement will appear in the weekly Bulletin at the earliest practi- cable date after such action and will continue to appear in the weekly Bulle- tins for five successive weeks or for as many weeks as is practicable for each attorney, certified public accountant, en- rolled agent, or enrolled actuary so suspended and will be consolidated and published in the Cumulative Bulletin. The following individuals have been placed under consent suspension from practice before the Internal Revenue Service: NameAddressDesignationDate of Suspension Bert Jr., Earol L.Severna Park, MDCPAFebruary 1, 1997 to July 31, 1997 Bernard, Lucius P.Corte Medera, CAAttorneyMarch 10, 1997 to March 9, 2000 Parker, David A.Willmar, MNCPAApril 13, 1997 to April 12, 2000 Sheldon, DonaldNashville, TNCPAApril 24, 1997 to September 23, 1997 Grandt, Lawrence E.Barrington, ILCPAApril 24, 1997 to January 23, 1998 Reese, Rex E.Alexandria, VAAttorneyMay 1, 1997 to April 30, 1999 Glasl, John E.Emporium, PACPAMay 1, 1997 to September 30, 1997 Coulter, Diane E.Monroeville, PACPAMay 1, 1997 to April 30, 1998 Groves, J. RandallMatthews, NCAttorneyMay 1, 1997 to October 31, 1998 Lupiloff, StevenBloomfield, MIAttorneyIndefinite from May 6, 1997 Wilson, Robert L.Spring Hill, FLCPAMay 7, 1997 to October 6, 1998 Sloop, Wayne F.Winston-Salem, NCCPAIndefinite from May 7, 1997 Wilnewic, Mark V.Crystal Lake, ILCPAMay 8, 1997 to November 7, 1997 Lenihan, MichaelCincinnati, OHCPAMay 14, 1997 to July 13, 1997 Bergmann, FrederickTampa, FLCPAJune 1, 1997 to May 30, 1999 Farmer, CraigArlington Hghts, ILCPAJune 1, 1997 to August 31, 1997 Denny, RichardPine Bluff, ARCPAJune 1, 1997 to July 31, 1997 June 30, 1997 101997–26 I.R.B. Announcement of the Expedited Suspension of Attorneys, Certified Public Accountants, Enrolled Agents, and Enrolled Actuaries From Practice Before the Internal Revenue Service Under title 31 of the Code of Federal Regulations, section 10.76, the Director of Practice is authorized to immediately suspend from practice before the Inter- nal Revenue Service any practitioner who, within five years, from the date the expedited proceeding is instituted, (1) has had a license to practice as an attorney, certified public accountant, or actuary suspended or revoked for cause; or (2) has been convicted of any crime under title 26 of the United States Code or, of a felony under title 18 of the United States Code involving dishonesty or breach of trust. Attorneys, certified public accoun- tants, enrolled agents, and enrolled actu- aries are prohibited in any Internal Rev- enue Service matter from directly or indirectly employing, accepting assis- tance from, being employed by, or shar- ing fees with, any practitioner disbarred or suspended from practice before the Internal Revenue Service. To enable attorneys, certified public accountants, enrolled agents, and en- rolled actuaries to identify practitioners under expedited suspension from prac- tice before the Internal Revenue Service, the Director of Practice will announce in the Internal Revenue Bulletin the names and addresses of practitioners who have been suspended from such practice, their designation as attorney, certified public accountant, enrolled agent, or enrolled actuary, and date or period of suspen- sion. This announcement will appear in the weekly Bulletin at the earliest practi- cable date after such action and will continue to appear in the weekly Bulle- tins for five successive weeks or for as many weeks as is practicable for each attorney, certified public accountant, en- rolled agent, or enrolled actuary so suspended and will be consolidated and published in the Cumulative Bulletin. The following individuals have been placed under suspension from practice before the Internal Revenue Service by virtue of the expedited proceeding pro- visions of the applicable regulations: NameAddressDesignationDate of Suspension Dally, Candace L.Winston-Salem, NCCPAIndefinite from April 16, 1997 Mellor, Gary D.Norton, KSAttorneyIndefinite from April 16, 1997 Gottesman, MiltonNew York, NYCPAIndefinite from April 16, 1997 Wiener, JamesGermantown, NYAttorneyIndefinite from April 16, 1997 Lunblad, GeraldSacramento, CACPAIndefinite from April 16, 1997 Driscoll, Robert J.Denver, COAttorneyIndefinite from April 16, 1997 Alico, Kenneth N.Orchard Park, NYCPAIndefinite from April 16, 1997 Mack, Roland G.Hyattsville, MDCPAIndefinite from May 1, 1997 Newman, Harry J.Covington, VACPAIndefinite from May 16, 1997 Sehnert, FredDallas, TXCPAIndefinite from May 16, 1997 Gaskins, John D.Valdosta, GACPAIndefinite from May 16, 1997 Turner, Charles L.Goshen, KYAttorneyIndefinite from May 16, 1997 Thornton Jr., Kenneth W.Murrells Inlet, SCAttorneyIndefinite from May 16, 1997 Kellogg, RichardWhite Hall, ARCPAIndefinite from May 16, 1997 Stec, Albert J.Schereville, INCPAIndefinite from May 16, 1997 Huff Jr., James G.Raleigh, NCCPAIndefinite from May 16, 1997 Seall, WilliamDayton, OHAttorneyIndefinite from May 16, 1997 Brunner, L. KeithCenterville, OHAttorneyIndefinite from May 16, 1997 Bart, David R.Oakwood, OHAttorneyIndefinite from May 16, 1997 Shafer, David A.Franklin, OHCPAIndefinite from May 16, 1997 Schouman, JamesMilford, MIAttorneyIndefinite from May 16, 1997 Jones, Milo A.Greensboro, NCCPAIndefinite from May 16, 1997 Dolan, Gary L.Lincoln, NEAttorneyIndedinite from May 16, 1997 Coorey, Edward T.Hampton, NHEnrolled AgentIndefinite from May 16, 1997 Sheehan, Thomas J.Maggie Valley, NCCPAIndefinite from May 16, 1997 Millonig, Arthur F.Dayton, OHAttorneyIndefinite from May 16, 1997 McHaffie, Richard T.St. Paul, MNAttorneyIndefinite from June 4, 1997 Rigler, MichaelGainesville, TXCPAIndefinite from June 4, 1997 1997–26 I.R.B. 11June 30, 1997 NameAddressDesignationDate of Suspension Hopkins, Diane E.St. Paul, MNAttorneyIndefinite from June 4, 1997 Adae, F. BrianBarrington, RIAttorneyIndefinite from June 4, 1997 Announcement of the Consent Suspension of Attorneys, Certified Public Accountants, Enrolled Agents, and Enrolled Actuaries From Practice Before the Internal Revenue Service Under 31 Code of Federal Regula- tions, Part 10, an attorney, certified pub- lic accountant, enrolled agent, or en- rolled actuary, in order to avoid the institution or conclusion of a proceeding for his disbarment or suspension from practice before the Internal Revenue Ser- vice, may offer his consent to suspension from such practice. The Director of Practice, in his discretion, may suspend an attorney, certified public accountant, enrolled agent, or enrolled actuary in accordance with the consent offered. Attorneys, certified public accoun- tants, enrolled agents, and enrolled actu- aries are prohibited in any Internal Rev- enue Service matter from directly or indirectly employing, accepting assis- tance from, being employed by or shar- ing fees with, any practitioner disbarred or suspended from practice before the Internal Revenue Service. To enable attorneys, certified public accountants, enrolled agents, and en- rolled actuaries to identify practitioners under consent suspension from practice before the Internal Revenue Service, the Director of Practice will announce in the Internal Revenue Bulletin the names and addresses of practitioners who have been suspended from such practice, their designation as attorney, certified public accountant, enrolled agent, or enrolled actuary, and date or period of suspen- sion. This announcement will appear in the weekly Bulletin at the earliest practi- cable date after such action and will continue to appear in the weekly Bulle- tins for five successive weeks or for as many weeks as is practicable for each attorney, certified public accountant, en- rolled agent, or enrolled actuary so suspended and will be consolidated and published in the Cumulative Bulletin. The following individuals have been placed under consent suspension from practice before the Internal Revenue Service: NameAddressDesignationDate of Suspension Padgett, JohnOrleans, MAAttorneyMay 22, 1997 to October 21, 1998 Crisp, Jerry W.Dallas, TXCPAJune 1, 1997 to May 31, 2000 Kessel, Donald K.Export, PACPAJune 1, 1997 to November 30, 1998 Klimchak, JosephAliquippa, PACPAJune 1, 1997 to February 28, 1998 Steele, Lewis M.Pittsburgh, PACPAJune 1, 1997 to May 31, 1998 Castleberry, Gene A.Oklahoma City, OKAttorneyJune 4, 1997 to August 3, 1997 O’Connor, Paul J.Hanover, MACPAJune 6, 1997 to June 5, 2000 Olshan, Robert M.Washington, DCCPAJune 10, 1997 to December 9, 1998 Johnson, Kirk L.Ann Arbor, MICPAJuly 1, 1997 to June 30, 1999 Mattutat, StephenEllicott City, MDCPAJuly 1, 1997 to March 31, 1998 Trenary, Lloyd R.Oklahoma City, OKCPAAugust 1, 1997 to March 31, 1998 Ritchey Jr., FerrisBirmingham, ALAttorneyAugust 1, 1997 to July 31, 2000 Gold, Howard G.Hamden, CTCPAAugust 1, 1997 to July 31, 1999 Womack, KathleenHammond, LACPAAugust 1, 1997 to July 31, 1999 June 30, 1997 121997–26 I.R.B. 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 de- scribe the effect: Amplifieddescribes a situation where no change is being made in a prior published 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 ampli- fied. (Compare withmodified, below). Clarifiedis 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 es- sential 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 pub- lished position. (Compare withamplified andclarified, above). Obsoleteddescribes a previously pub- lished ruling that is not considered de- terminative with respect to future trans- actions. This term is most commonly used in a ruling that lists previously published rulings that are obsoleted be- cause of changes in law or regulations. A ruling may also be obsoleted because the substance has been included in regu- lations subsequently adopted. Revokeddescribes situations where the position in the previously published ruling is not correct and the correct position is being stated in the new ruling. Supersededdescribes 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 previ- ously published over a period 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,modifiedandsuper- sededdescribes a situation where the substance of a previously published rul- ing 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 su- perseded. 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 ruling has been supplemented several times, a new ruling may be published that includes the list in the original ruling and the additions, and supersedes all prior rulings in the series. Suspendedis 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 formerly 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 Contribution 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. 13 Numerical Finding List 1 Bulletins 1997–1 through 1997–25 Announcements: 97–1, 1997–2 I.R.B.63 97–2, 1997–2 I.R.B.63 97–3, 1997–2 I.R.B.63 97–4, 1997–3 I.R.B.14 97–5, 1997–3 I.R.B.15 97–6, 1997–4 I.R.B.11 97–7, 1997–4 I.R.B.12 97–8, 1997–4 I.R.B.12 97–9, 1997–5 I.R.B.27 97–10, 1997–10 I.R.B.64 97–11, 1997–6 I.R.B.19 97–12, 1997–7 I.R.B.55 97–13, 1997–8 I.R.B.38 97–14, 1997–8 I.R.B.38 97–15, 1997–9 I.R.B.23 97–16, 1997–9 I.R.B.23 97–17, 1997–9 I.R.B.23 97–18, 1997–10 I.R.B.67 97–19, 1997–10 I.R.B.68 97–20, 1997–11 I.R.B.22 97–21, 1997–11 I.R.B.23 97–22, 1997–12 I.R.B.47 97–23, 1997–11 I.R.B.23 97–24, 1997–11 I.R.B.24 97–25, 1997–12 I.R.B.47 97–26, 1997–12 I.R.B.48 97–27, 1997–13 I.R.B.30 97–28, 1997–14 I.R.B.15 97–29, 1997–14 I.R.B.16 97–30, 1997–14 I.R.B.16 97–31, 1997–14 I.R.B.16 97–32, 1997–14 I.R.B.17 97–33, 1997–15 I.R.B.8 97–34, 1997–15 I.R.B.8 97–35, 1997–15 I.R.B.9 97–36, 1997–15 I.R.B.10 97–37, 1997–15 I.R.B.10 97–38, 1997–15 I.R.B.10 97–39, 1997–16 I.R.B.27 97–40, 1997–16 I.R.B.28 97–41, 1997–16 I.R.B.28 97–42, 1997–17 I.R.B.19 97–43, 1997–17 I.R.B.19 97–44, 1997–17 I.R.B.19 97–45, 1997–17 I.R.B.20 97–46, 1997–18 I.R.B.53 97–47, 1997–19 I.R.B.94 97–48, 1997–20 I.R.B.8 97–49, 1997–20 I.R.B.8 97–50, 1997–20 I.R.B.8 97–51, 1997–20 I.R.B.9 97–52, 1997–21 I.R.B.22 97–53, 1997–21 I.R.B.22 97–54, 1997–22 I.R.B.23 97–55, 1997–22 I.R.B.23 97–56, 1997–23 I.R.B.17 97–57, 1997–23 I.R.B.18 97–58, 1997–24 I.R.B.13 97–59, 1997–24 I.R.B.13 97–60, 1997-24 I.R.B.14 97–62, 1997–25, I.R.B.34 Delegation Orders: 232 (Rev. 3),21 Notices: 97–1, 1997–2 I.R.B.22 97–2, 1997–2 I.R.B.22 97–3, 1997–1 I.R.B.8 Notices—Continued 97–4, 1997–2 I.R.B.24 97–5, 1997–2 I.R.B.25 97–6, 1997–2 I.R.B.26 97–7, 1997–1 I.R.B.8 97–8, 1997–4 I.R.B.7 97–9, 1997–2 I.R.B.35 97–10, 1997–2 I.R.B.41 97–11, 1997–2 I.R.B.50 97–12, 1997–3 I.R.B.11 97–13, 1997–6 I.R.B.13 97–14, 1997–8 I.R.B.23 97–15, 1997–8 I.R.B.23 97–16, 1997–9 I.R.B.15 97–17, 1997–10 I.R.B.34 97–18, 1997–10 I.R.B.35 97–19, 1997–10 I.R.B.40 97–20, 1997–10 I.R.B.52 97–21, 1997–11 I.R.B.9 97–22, 1997–13 I.R.B.9 97–23, 1997–14 I.R.B.8 97–24, 1997–16 I.R.B.6 97–25, 1997–16 I.R.B.8 97–26, 1997–17 I.R.B.6 97–27, 1997–17 I.R.B.7 97–28, 1997–18 I.R.B.45 97–29, 1997–20 I.R.B.6 97–30, 1997–20 I.R.B.6 97–31, 1997–21 I.R.B.5 97–32, 1997–21 I.R.B.8 97–33, 1997–22 I.R.B.22 97–34, 1997–25 I.R.B.22 97–35, 1997–25 I.R.B.32 Proposed Regulations: REG–209332–80, 1997–14 I.R.B.9 REG–209040–88, 1997–7 I.R.B.34 REG–209121–89, 1997–11 I.R.B.15 REG–208288–90, 1997–11 I.R.B.14 REG–209494–90, 1997–8 I.R.B.24 REG–208172–91, 1997–10 I.R.B.59 REG–209672–93, 1997–6 I.R.B.15 REG–209709–94 1997–13 I.R.B.12 REG–209729–94, 1997–11 I.R.B.19 REG–209762–95, 1997–3 I.R.B.12 REG–209785–95, 1997–18 I.R.B.46 REG–209817–96, 1997–7 I.R.B.41 REG–209824–96, 1997–11 I.R.B.19 REG–254394–96, 1997–14 I.R.B.14 REG–209823–96, 1997–18 I.R.B.47 REG–209828–96, 1997–6 I.R.B.15 REG–209830–96, 1997–15 I.R.B.7 REG–209834–96, 1997–4 I.R.B.9 REG–209837–96, 1997–23 I.R.B.8 REG–209839–96, 1997–8 I.R.B.26 REG–242996–96, 1997–9 I.R.B.18 REG–246018–96, 1997–8 I.R.B.30 REG–247678–96, 1997–6 I.R.B.17 REG–247862–96, 1997–8 I.R.B.32 REG–248770–96, 1997–8 I.R.B.33 REG–249819–96, 1997–7 I.R.B.50 REG–251703–96, 1997–25 I.R.B.5 REG–252231–96, 1997–7 I.R.B.52 REG–252233–96, 1997–9 I.R.B.19 REG–252487–96, 1997–25 I.R.B.9 REG–252665–96, 1997–12 I.R.B.46 REG–253578–96, 1997–19 I.R.B.93 REG–105299–97, 1997–23 I.R.B.8 Public Law: 105–2, 1997–18 I.R.B.14 Railroad Retirement Quarterly Rate: 1997–21 I.R.B.4 Revenue Procedures: 97–1, 1997–1 I.R.B.11 97–2, 1997–1 I.R.B.64 97–3, 1997–1 I.R.B.84 97–4, 1997–1 I.R.B.96 97–5, 1997–1 I.R.B.132 97–6, 1997–1 I.R.B.153 97–7, 1997–1 I.R.B.185 97–8, 1997–1 I.R.B.187 97–9, 1997–2 I.R.B.56 97–10, 1997–2 I.R.B.59 97–11, 1997–6 I.R.B.13 97–12, 1997–4 I.R.B.7 97–13, 1997–5 I.R.B.18 97–14, 1997–5 I.R.B.20 97–15, 1997–5 I.R.B.21 97–16, 1997–5 I.R.B.25 97–17, 1997–9 I.R.B.15 97–18, 1997–10 I.R.B.53 97–19, 1997–10 I.R.B.55 97–20, 1997–11 I.R.B.10 97–21, 1997–12 I.R.B.44 97–22, 1997–13 I.R.B.9 97–23, 1997–17 I.R.B.7 97–24, 1997–16 I.R.B.10 97–24A, 1997–20 I.R.B.7 97–25, 1997–17 I.R.B.8 97–26, 1997–17 I.R.B.17 97–27, 1997–21 I.R.B.10 97–28, 1997–23 I.R.B.9 97–29, 1997–24 I.R.B.9 97–30, 1997–25 I.R.B.20 Revenue Rulings: 97–1, 1997–2 I.R.B.10 97–2, 1997–2 I.R.B.7 97–3, 1997–2 I.R.B.5 97–4, 1997–3 I.R.B.6 97–5, 1997–4 I.R.B.5 97–6, 1997–4 I.R.B.4 97–7, 1997–5 I.R.B.14 97–8, 1997–7 I.R.B.4 97–9, 1997–9 I.R.B.4 97–10, 1997–10 I.R.B.31 97–11, 1997–10 I.R.B.5 97–12, 1997–11 I.R.B.5 97–13, 1997–16 I.R.B.4 97–14, 1997–11 I.R.B.5 97–15, 1997–12 I.R.B.42 97–16, 1997–13 I.R.B.4 97–17, 1997–14 I.R.B.5 97–18, 1997–15 I.R.B.4 97–19, 1997–18 I.R.B.11 97–20, 1997–19 I.R.B.4 97–21, 1997–18 I.R.B.8 97–22, 1997–20 I.R.B.5 97–23, 1997–22 I.R.B.18 97–24, 1997–22 I.R.B.17 97–25, 1997–23 I.R.B.4 97–26, 1997–24 I.R.B.4 Social Security Domestic Coverage Threshold: 1997–9, I.R.B.17 Tax Conventions: 1997–17 I.R.B.5 14 1 See footnote at end of list. Numerical Finding List—Continued Bulletins 1997–1 through 1997–25 Treasury Decisions: 8688, 1997–3 I.R.B.7 8689, 1997–3 I.R.B.9 8690, 1997–5 I.R.B.5 8691, 1997–5 I.R.B.16 8692, 1997–3 I.R.B.4 8693, 1997–6 I.R.B.9 8694, 1997–6 I.R.B.11 8695, 1997–4 I.R.B.5 8696, 1997–6 I.R.B.4 8697, 1997–2 I.R.B.11 8698, 1997–7 I.R.B.29 8699, 1997–6 I.R.B.4 8700, 1997–7 I.R.B.5 8701, 1997–7 I.R.B.23 8702, 1997–8 I.R.B.4 8703, 1997–8 I.R.B.18 8704, 1997–8 I.R.B.12 8705, 1997–8 I.R.B.16 8706, 1997–9 I.R.B.11 8707, 1997–7 I.R.B.17 8708, 1997–10 I.R.B.14 8709, 1997–9 I.R.B.5 8710, 1997–13 I.R.B.4 8711, 1997–12 I.R.B.35 8712, 1997–12 I.R.B.4 8713, 1997–14 I.R.B.4 8714, 1997–15 I.R.B.5 8715, 1997–18 I.R.B.5 8716, 1997–19 I.R.B.5 8717, 1997–24 I.R.B.5 8718, 1997–22 I.R.B.4 8719, 1997–23 I.R.B.4 8720, 1997–23 I.R.B.6 1 A cumulative list of all Revenue Rulings, Revenue Procedures, Treasury Decisions, etc., published in Internal Revenue Bulletins 1996–27 through 1996–53 will be found in Internal Revenue Bulletin 1997–1, dated January 6, 1997. 15 Finding List of Current Action on Previously Published Items 1 Bulletins 1997–1 through 1997–25 *Denotes entry since last publication Delegation Orders: 232 (Rev. 2) Modified by 232 (Rev. 3), 1997–25 I.R.B.21 Revenue Procedures: 66–3 Modified by 97–11, 1997–6 I.R.B.13 87–21 Modified by 97–11, 1997–6 I.R.B.13 92–20 Modified by 97–1, 1997–1 I.R.B.11 92–20 Modified by 97–10, 1997–2 I.R.B.59 92–90 Superseded by 97–1, 1997–1 I.R.B.11 94–52 Revoked by 97–11, 1997–6 I.R.B.13 96–1 Superseded by 97–1, 1997–1 I.R.B.11 96–2 Superseded by 97–2, 1997–1 I.R.B.64 96–3 Superseded by 97–3, 1997–1 I.R.B.84 96–4 Superseded by 97–4, 1997–1 I.R.B.96 96–5 Superseded by 97–5, 1997–1 I.R.B.132 96–6 Superseded by 97–6, 1997–1 I.R.B.153 96–7 Superseded by 97–7, 1997–1 I.R.B.185 96–8 Superseded by 97–8, 1997–1 I.R.B.187 96–24 96–24A Superseded by 97–24, 1997–16 I.R.B.10 96–37 Obsoleted by 97–26, 1997–17 I.R.B.17 Revenue Procedures—Continued 97–2 Amplified by 97–21, 1997–12 I.R.B.44 97–3 Amplified by 97–23, 1997–17 I.R.B.7 97–27 Superseded by 97–30, 1997–25 I.R.B.20 Revenue Rulings: 70–480 Revoked by 97–6, 1997–4 I.R.B.4 72–527 Obsoleted by 8704, 1997–8 I.R.B.12 74–59 Revoked by 8708, 1997–10 I.R.B.14 86–73 Obsoleted by TD 8717, 1997–24 I.R.B.5 87–50 Obsoleted by TD 8717, 1997–24 I.R.B.5 87–51 Obsoleted by TD 8717, 1997–24 I.R.B.5 88–42 Obsoleted by TD 8717, 1997–24 I.R.B.5 92–19 Supplemented in part by 97–2, 1997–2 I.R.B.7 93–90 Obsoleted by TD 8717, 1997–24 I.R.B. 5 96–12 Superseded by 97–3, 1997–1 I.R.B.84 96–13 Modified by 97–1, 1997–1 I.R.B.11 96–22 Superseded by 97–3, 1997–1 I.R.B.84 96–34 Superseded by 97–3, 1997–1 I.R.B.84 96–39 Superseded by 97–3, 1997–1 I.R.B.84 96–43 Superseded by 97–3, 1997–1 I.R.B.84 96–56 Superseded by 97–3, 1997–1 I.R.B.84 1 A cumulative finding list for previously published items mentioned in Internal Revenue Bulletins 1996–27 through 1996–53 will be found in Inter- nal Revenue Bulletin 1997–1, dated January 6, 1997. 16 NOTES 17 NOTES 18 INTERNAL REVENUE BULLETIN The Introduction on page 3 describes the purpose and content of this publication. The weekly Internal Revenue Bulletin is sold on a yearly subscription basis by the Superintendent of Documents. Current subscribers are notified by the Superintendent of Documents when their subscriptions must be renewed. CUMULATIVE BULLETINS The contents of this weekly Bulletin are consolidated semiannually into a permanent, indexed, Cumulative Bulletin. These are sold on a single copy basis andare notincluded as part of the subscription to the Internal Revenue Bulletin. Subscribers to the weekly Bulletin are notified when copies of the Cumulative Bulletin are available. Certain issues of Cumulative Bulletins are out of print and are not available. Persons desiring available Cumulative Bulletins, which are listed on the reverse, may purchase them from the Superintendent of Documents. HOW TO ORDER Check the publications and/or subscription(s) desired on the reverse, complete the order blank, enclose the proper remittance, detach entire page, and mail to the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402. Please allow two to six weeks, plus mailing time, for delivery. Superintendent of Documents First Class Mail Postage and Fees Paid GPO Permit No. G–26 U.S. Government Printing Office Washington, DC 20402 Official Business Penalty for Private Use, $300 INTERNAL REVENUE BULLETIN The Introduction on page 3 describes the purpose and content of this publication. The weekly Internal Revenue Bulletin is sold on a yearly subscription basis by the Superintendent of Documents. Current subscribers are notified by the Superintendent of Documents when their subscriptions must be renewed. CUMULATIVE BULLETINS The contents of this weekly Bulletin are consolidated semiannually into a permanent, indexed, Cumulative Bulletin. These are sold on a single copy basis andare notincluded as part of the subscription to the Internal Revenue Bulletin. Subscribers to the weekly Bulletin are notified when copies of the Cumulative Bulletin are available. Certain issues of Cumulative Bulletins are out of print and are not available. Persons desiring available Cumulative Bulletins, which are listed on the reverse, may purchase them from the Superintendent of Documents. HOW TO ORDER Check the publications and/or subscription(s) desired on the reverse, complete the order blank, enclose the proper remittance, detach entire page, and mail to the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402. Please allow two to six weeks, plus mailing time, for delivery. WE WELCOME COMMENTS ABOUT THE INTERNAL REVENUE BULLETIN If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we would be pleased to hear from you. You can e-mail us your suggestions or comments through the IRS Internet Home Page (www.irs.ustreas.gov) or write to the IRS Bulletin Unit, T:FP:F:CD, Room 5560, 1111 Constitution Avenue NW, Washington, DC 20224. You can also leave a recorded message 24 hours a day, 7 days a week at 1–800–829–9043. Internal Revenue Service Washington, DC 20224 Official Business Penalty for Private Use, $300
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