Internal Revenue Bulletin 1996-22 (PDF rendition): IRS Notices

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.

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Bulletin No. 1996–22
May 28, 1996
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.
SPECIAL ANNOUNCEMENTS
Announcement 96–48, page 10.
A public hearing will be held on June 24, 1996, on
proposed regulations relating to when amounts deferred
or paid from certain retirement plans are taken into
account as ‘‘wages’’ for FICA and FUTA purposes.
Announcement 96–49, page 10.
A public hearing will be held on June 28, 1996, on
proposed regulations relating to loans made from a
qualified employer plan to plan participants or
beneficiaries.
INCOME TAX
T.D. 8668, page 4.
Final regulations under section 7701 of the Code relate
to the classification of certain organizations as trusts
for federal tax purposes.
EMPLOYEE PLANS
Notice 96–32, page 7.
Guidelines are set forth for determining for May 1996,
the weighted average interest rate and the resulting
permissible range of interest rates used to calculate
current liability for purposes of the full funding
limitation of section 412(c)(7) of the Code as amended
by the Omnibus Budget Reconciliation Act of 1987 and
by the Uruguay Round Agreements Act (GATT).
EXEMPT ORGANIZATIONS
Announcement 96–52, page 12.
A list is provided of organizations that no longer qualify
as organizations to which contributions are deductible
under section 170 of the Code.
TAX CONVENTIONS
Notice 96–31, page 7.
This notice clarifies the application of the U.S.-Canada
Income Tax Convention, as revised by the Protocol
dated March 17, 1995, to Canadian Registered
Retirement Savings Plans, Canadian Registered Retire-
ment Income Funds and the beneficiaries of both.
ADMINISTRATIVE
Notice 96–33, page 8.
T.D. 8618, 1995–40 I.R.B. 4, relating to final
regulations governing the definitions of a controlled
foreign corporation, foreign base company income, and
foreign personal holding company income of a con-
trolled foreign corporation, is corrected.
Rev. Proc. 96–33, page 8.
Section 911(d)(4) waiver Rev. Proc. Guidance is
provided to individuals who fail to meet the eligibility
requirements of section 911(d)(1) of the Code because
adverse conditions in the foreign country preclude the
individual from meeting those requirements. A current
list of countries and the dates those countries are
subject to the section 911(d)(4) waiver is provided.
Announcement 96–47, page 10.
Form 3115, Application for Change in Accounting
Method, and its instructions are approved by the Office
of Management and Budget through May 31, 1999,
and are available.
Announcement 96–50, page 11.
T.D. 8658, 1996–13 I.R.B. 9, providing guidance on
the imposition of the accuracy-related penalty, is
corrected.
Announcement 96–51, page 11.
T.D. 8657, 1996–14 I.R.B. 4, final regulations relating
to the determination of effectively connected income;
and final and temporary regulations relating to the
branch-level interest tax, is corrected.
Finding Lists begin on page 16.
Announcement of Disbarments and Suspensions begins on page 13.

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Mission of the Service
The purpose of the Internal Revenue Service is to
collect the proper amount of tax revenue at the least
cost; serve the public by continually improving the
quality of our products and services; and perform 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 Service 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 Service to
carry 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
perform 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
Service, charged with the duty of interpreting the
law, to try to find the true meaning of the statutory
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 Service also has the responsibility of applying
and administering the law in a reasonable,
practical manner. Issues should only be raised by
examining officers 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 Service position.
Administration should be both reasonable and
vigorous. It should be conducted with as little
delay as possible and with great courtesy and
considerateness. It should never try 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.

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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 Conventions, legisla-
tion, court decisions, and other items of general
interest. It is published weekly and may be obtained
from the Superintendent of Documents on a subscrip-
tion basis. Bulletin contents of a permanent nature are
consolidated semiannually into Cumulative Bulletins,
which are sold on a single-copy basis.
It is the policy of the Service to publish in the Bulletin
all substantive rulings necessary to promote a uniform
application of the tax laws, including all rulings that
supersede, revoke, modify, or amend any of those
previously published in the Bulletin. All published
rulings apply retroactively unless otherwise indicated.
Procedures 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
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 proce-
dures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be
considered, and Service personnel and others con-
cerned 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 Admin-
istrative Rulings are issued by the Department of the
Treasury’s Office of the Assistant Secretary
(Enforcement).
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 an index for
the matters published during the preceding month.
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.

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Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
Section 911.—Citizens or Residents
of the United States Living Abroad
26 CFR 1.911–1: Partial exclusion for earned
income from sources within a foreign country
and foreign housing costs.
Guidance is provided to individuals who fail to
meet the eligibility requirements of section
911(d)(1) of the Internal Revenue Code because
adverse conditions in a foreign country preclude
the individual from meeting those requirements.
A current list of countries and the dates those
countries are subject to the section 911(d)(4)
waiver is provided. See Rev. Proc. 96–33, page
8.
Section 1441.—Withholding of Tax
on Nonresident Aliens
Notice 96–31 clarifies the application of the
U.S.-Canada Income Tax Convention, as revised
by the Protocol dated March 17, 1995 (‘‘Pro-
tocol’’), to Canadian Register Retirement Sav-
ings Plans, Canadian Registered Retirement
Income Funds and the beneficiaries of both.
Section 7701.—Definitions
26 CFR 301.7701–4: Trusts.
T.D. 8668
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Parts 1, 301, and 602
Environmental Settlement Funds-
Classification
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final Regulations.
SUMMARY: This document contains
final regulations relating to the classi-
fication of certain organizations as
trusts for federal tax purposes. The
final regulations provide guidance to
taxpayers on the proper classification
of trusts formed to collect and disburse
amounts for environmental remediation
of an existing waste site to discharge
taxpayers’ liability or potential liability
under applicable environmental laws.
DATES: These regulations are effective
May 1, 1996.
For dates of applicability, see
§301.7701–4(e)(5).
FOR FURTHER INFORMATION
CONTACT: James A. Quinn, (202)
622-3060 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Paperwork Reduction Act
The collection of information con-
tained in these final regulations has been
reviewed and approved by the Office of
Management and Budget in accordance
with the Paperwork Reduction Act (44
U.S.C. 3507) under control number
1545–1465. This information is required
by the IRS to ensure the proper
reporting of items of income and
expense of an environmental remedia-
tion trust in which a portion of the trust
is treated as owned by a grantor.
An agency may not conduct or
sponsor, and a person is not required to
respond to, a collection of information
unless the collection of information
displays a valid control number.
The estimated annual burden per
respondent is 4 hours.
Comments concerning the accuracy of
this burden estimate and suggestions for
reducing this burden should be sent to
the Internal Revenue Service, Attn: IRS
Reports Clearance Officer, T:FP, Wash-
ington, DC 20224, and to the Office of
Management and Budget, Attn: Desk
Officer for the Department of the Treas-
ury, Office of Information and Regula-
tory Affairs, Washington, DC 20503.
Books or records relating to this col-
lection of information must be retained
as long as their contents may become
material in the administration of any
internal revenue law. Generally, tax
returns and tax return information are
confidential, as required by 26 U.S.C.
6103.
Background
On August 4, 1995, the IRS pub-
lished in the Federal Register a notice
of proposed rulemaking (60 FR 39903
[PS–54–94, 1995–37 I.R.B. 48]) to
provide guidance on the classification
of certain organizations as trusts for
federal tax purposes. Written comments
responding to the notice were received,
and a public hearing was held on
October 26, 1995. After consideration
of the comments received, the proposed
regulations are adopted as revised by
this Treasury decision.
Summary of Significant Comments
and Revisions
The proposed regulations provide
that an environmental remediation trust
is considered a trust for purposes of the
Internal Revenue Code. Under the
proposed regulations, a trust is an
environmental remediation trust if the
primary purpose of the trust is collect-
ing and disbursing amounts for en-
vironmental remediation of an existing
waste site. One commentator suggested
that ‘‘response costs’’ should be con-
sidered amounts incurred for environ-
mental remediation. To address this
concern, the final regulations clarify
that environmental remediation includes
the costs of remedying and removing
environmental contamination. One
commentator also suggested that the
final regulations define the term exist-
ing waste site. The final regulations do
not adopt this comment. The term
existing waste site should be suffi-
ciently specific to allow taxpayers to
establish an environmental remediation
trust for any contaminated site that
currently requires remediation under
environmental laws.
The proposed regulations provide
that all contributors to an environmen-
tal remediation trust must have poten-
tial liability or a reasonable expectation
of liability under federal, state, or local
environmental laws for environmental
remediation of the waste site. A com-
mentator suggested that the final reg-
ulations be clarified to provide that
eligible contributors include contribu-
tors with ‘‘actual’’ as well as potential
liability and contributors who are re-
leased from liability upon their contri-
bution to the trust. The final regula-
tions clarify that contributors having
‘‘actual’’ liability are eligible contribu-
tors. The final regulations do not
address the treatment of contributors
that are released from liability by the
governmental authority upon contribu-
tion to the trust; the regulations are
intended only to address the tax treat-
ment of environmental remediation
trusts in which contributors continue to
have actual or potential liability (and
thus are treated as owners of the trust
under section 677). In situations where
one or more contributors are released
from liability by the governmental
authority upon contribution to the trust,
the rules for qualified settlement funds
may apply to the entire trust. See
§1.468B–1(c) and (h)(2). If such con-
tributors contribute amounts to a trust
that is separate from the environmental
remediation trust, however, the classi-

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fication of the environmental remedia-
tion trust as a trust will not be affected.
One commentator suggested that a
cross-reference to these regulations be
inserted in §1.671–4(a) and §1.677(a)–
1(d) because the proposed regulations
address reporting and grantor trust
issues. The final regulations include the
suggested cross-references.
Other commentators suggested that
the final regulations address the timing
of deductions for contributions to the
trust, the treatment of interest earned
by the trust, and other federal tax
consequences of the trust. The final
regulations do not adopt these sugges-
tions. The regulations are limited to the
classification of an environmental re-
mediation trust as a trust for purposes
of section 7701 and do not address or
affect the timing or amount of a
deduction for environmental remedia-
tion costs. Amounts contributed to an
environmental remediation trust and
interest earned on those amounts must
be taken into account under the appro-
priate federal tax accounting rules,
including the economic performance
rules of section 461(h). Under those
rules, taxpayers generally cannot de-
duct contributions to the trust at the
time of contribution or deduct earnings
at the time they are received by the
trust.
The proposed regulations provide
that the regulations will apply to trusts
formed on or after the date of publica-
tion of final regulations. One commen-
tator suggested that the final regula-
tions should be effective, at the
trustee’s option, to trusts meeting the
requirements of an environmental re-
mediation trust established prior to
such date, effective as of any date
designated by the trustee. The commen-
tator further suggested that, with re-
spect to amounts held in a fund,
account, or trust meeting the require-
ments of an environmental remediation
trust prior to the date of publication of
the final regulations, the IRS should
not challenge the classification of the
fund, account, or trust as a trust for
federal tax purposes.
The final regulations are effective for
trusts meeting the definition of an
environmental remediation trust that are
formed on or after May 1, 1996. The
final regulations may be relied on by
trusts formed before May 1, 1996, if
the trust has at all times met all
requirements of the final regulations
and the grantors reported items of
income and deduction consistent with
the final regulations on original or
amended returns. This provision allows
a trust and grantors that have met all of
the requirements of the final regula-
tions throughout the existence of the
trust to treat the trust as an environ-
mental remediation trust. The final
regulations also provide that, for trusts
formed before May 1, 1996, that are
not described by the preceding rule, the
Commissioner may permit by letter
ruling, in appropriate circumstances,
the final regulations to be applied
subject to appropriate terms and
conditions.
Special Analyses
It has been determined that this
Treasury decision is not a significant
regulatory action as defined in EO
12866. Therefore, a regulatory assess-
ment is not required. It has also been
determined that section 553(b) of the
Administrative Procedure Act (5 U.S.C.
chapter 5) and the Regulatory Flex-
ibility Act (5 U.S.C. chapter 6) do not
apply to these regulations, and, there-
fore, a Regulatory Flexibility Analysis
is not required. Pursuant to section
7805(f) of the Code, the notice of
proposed rulemaking preceding these
regulations was submitted to the Small
Business Administration for comment
on its impact on small business.
Drafting Information
The principal author of these regula-
tions is James A. Quinn of the Office
of Assistant Chief Counsel (Pass-
throughs and Special Industries). How-
ever, other personnel from the IRS and
Treasury Department participated in
their development.
******
Amendments to the Regulations
Accordingly, 26 CFR parts 1, 301,
and 602 are amended as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation
for part 1 continues to read in part as
follows:
Authority: 26 U.S.C. 7805 ** *
Par. 2. Section 1.671–4 is amended
by adding a sentence at the end of
paragraph (a) to read as follows:
§1.671–4 Method of reporting.
(a) ** * Section 301.7701–4(e)(2)
of this chapter provides guidance on
how these reporting rules apply to an
environmental remediation trust.
******
Par. 3. Section 1.677(a)–1 is
amended by adding a sentence at the
end of paragraph (d) to read as follows:
§1.677(a)–1 Income for benefit of
grantor; general rule.
******
(d) * ** See §301.7701–4(e) of this
chapter for rules on the classification of
and application of section 677 to an
environmental remediation trust.
******
PART 301—PROCEDURE AND
ADMINISTRATION
Par. 4. The authority citation for part
301 continues to read as follows:
Authority: 26 U.S.C. 7805 ** *
Par. 5. Section 301.7701–4(e) is
added to read as follows:
§301.7701-4 Trusts.
******
( e )E n v i r o n m e n t a l r e m e d i a t i o n
trusts. (1) An environmental remedia-
tion trust is considered a trust for
purposes of the Internal Revenue Code.
For purposes of this paragraph (e), an
organization is an environmental re-
mediation trust if the organization is
organized under state law as a trust; the
primary purpose of the trust is collect-
ing and disbursing amounts for en-
vironmental remediation of an existing
waste site to resolve, satisfy, mitigate,
address, or prevent the liability or
potential liability of persons imposed
by federal, state, or local environmental
laws; all contributors to the trust have
(at the time of contribution and thereaf-
ter) actual or potential liability or a
reasonable expectation of liability un-
der federal, state, or local environmen-
tal laws for environmental remediation
of the waste site; and the trust is not a
qualified settlement fund within the
meaning of §1.468B–1(a) of this chap-
ter. An environmental remediation trust
is classified as a trust because its
primary purpose is environmental re-
mediation of an existing waste site and

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not the carrying on of a profit-making
business that normally would be con-
ducted through business organizations
classified as corporations or part-
nerships. However, if the remedial
purpose is altered or becomes so
obscured by business or investment
activities that the declared remedial
purpose is no longer controlling, the
organization will no longer be classi-
fied as a trust. For purposes of this
paragraph (e), environmental remedia-
tion includes the costs of assessing
environmental conditions, remedying
and removing environmental con-
tamination, monitoring remedial ac-
tivities and the release of substances,
preventing future releases of sub-
stances, and collecting amounts from
persons liable or potentially liable for
the costs of these activities. For pur-
poses of this paragraph (e), persons
have potential liability or a reasonable
expectation of liability under federal,
state, or local environmental laws for
remediation of the existing waste site if
there is authority under a federal, state,
or local law that requires or could
reasonably be expected to require such
persons to satisfy all or a portion of the
costs of the environmental remediation.
(2)Each contributor (grantor) to the
trust is treated as the owner of the
portion of the trust contributed by that
grantor under rules provided in section
677 and §1.677(a)–1(d) of this chapter.
Section 677 and §1.677(a)–1(d) of this
chapter provide rules regarding the
treatment of a grantor as the owner of a
portion of a trust applied in discharge
of the grantor’s legal obligation. Items
of income, deduction, and credit at-
tributable to an environmental remedia-
tion trust are not reported by the trust
on Form 1041, but are shown on a
separate statement to be attached to
that form. See §1.671–4(a) of this
chapter. The trustee must also furnish
to each grantor a statement that shows
all items of income, deduction, and
credit of the trust for the grantor’s
taxable year attributable to the portion
of the trust treated as owned by the
grantor. The statement must provide the
grantor with the information necessary
to take the items into account in
computing the grantor’s taxable in-
come, including information necessary
to determine the federal tax treatment
of the items (for example, whether an
item is a deductible expense under
section 162(a) or a capital expenditure
under section 263(a)) and how the item
should be taken into account under the
economic performance rules of section
461(h) and the regulations thereunder.
See §1.461–4 of this chapter for rules
relating to economic performance.
(3)All amounts contributed to an
environmental remediation trust by a
grantor (cash-out grantor) who, pur-
suant to an agreement with the other
grantors, contributes a fixed amount to
the trust and is relieved by the other
grantors of any further obligation to
make contributions to the trust, but
remains liable or potentially liable
under the applicable environmental
laws, will be considered amounts con-
tributed for remediation. An environ-
mental remediation trust agreement
may direct the trustee to expend
amounts contributed by a cash-out
grantor (and the earnings thereon)
before expending amounts contributed
by other grantors (and the earnings
thereon). A cash-out grantor will cease
to be treated as an owner of a portion
of the trust when the grantor’s portion
is fully expended by the trust.
(4)The provisions of this paragraph
(e) may be illustrated by the following
example:
Example. (a) X, Y, and Z are calendar year
corporations that are liable for the remediation of
an existing waste site under applicable federal
environmental laws. On June 1, 1996, pursuant
to an agreement with the governing federal
agency, X, Y, and Z create an environmental
remediation trust within the meaning of para-
graph (e)(1) of this section to collect funds
contributed to the trust by X, Y, and Z and to
carry out the remediation of the waste site to the
satisfaction of the federal agency. X, Y, and Z are
jointly and severally liable under the federal
environmental laws for the remediation of the
waste site, and the federal agency will not
release X, Y, or Z from liability until the waste
site is remediated to the satisfaction of the
agency.
(b)The estimated cost of the remediation is
$20,000,000. X, Y, and Z agree that, if Z
contributes $1,000,000 to the trust, Z will not be
required to make any additional contributions to
the trust, and X and Y will complete the
remediation of the waste site and make addi-
tional contributions if necessary.
(c)On June 1, 1996, X, Y, and Z each
contribute $1,000,000 to the trust. The trust
agreement directs the trustee to spend Z’s
contributions to the trust and the income
allocable to Z’s portion before spending X’s and
Y’s portions. On November 30, 1996, the trustee
disburses $2,000,000 for remediation work per-
formed from June 1, 1996, through September
30, 1996. For the six-month period ending
November 30, 1996, the interest earned on the
funds in the trust was $75,000, which is
allocated in equal shares of $25,000 to X’s, Y’s,
and Z’s portions of the trust.
(d)Z made no further contributions to the
trust. Pursuant to the trust agreement, the trustee
expended Z’s portion of the trust before expend-
ing X’s and Y’s portion. Therefore, Z’s share of
the remediation disbursement made in 1996 is
$1,025,000 ($1,000,000 contribution by Z plus
$25,000 of interest allocated to Z’s portion of the
trust). Z takes the $1,025,000 disbursement into
account under the appropriate federal tax ac-
counting rules. In addition, X’s share of the
remediation disbursement made in 1996 is
$487,500, and Y’s share of the remediation
disbursement made in 1996 is $487,500. X and Y
take their respective shares of the disbursement
into account under the appropriate federal tax
accounting rules.
(e)The trustee made no further remediation
disbursements in 1996, and X and Y made no
further contributions in 1996. From December 1,
1996, to December 31, 1996, the interest earned
on the funds remaining in the trust was $5,000,
which is allocated $2,500 to X’s portion and
$2,500 to Y’s portion. Accordingly, for 1996, X
and Y each had interest income of $27,500 from
the trust and Z had interest income of $25,000
from the trust.
(5)This paragraph (e) is applicable
to trusts meeting the requirements of
paragraph (e)(1) of this section that are
formed on or after May 1, 1996. This
paragraph (e) may be relied on by
trusts formed before May 1, 1996, if
the trust has at all times met all
requirements of this paragraph (e) and
the grantors have reported items of
income and deduction consistent with
this paragraph (e) on original or
amended returns. For trusts formed
before May 1, 1996, that are not
described in the preceding sentence, the
Commissioner may permit by letter
ruling, in appropriate circumstances,
this paragraph (e) to be applied subject
to appropriate terms and conditions.
PART 602—OMB CONTROL
NUMBERS UNDER THE
PAPERWORK REDUCTION ACT
Par. 6. The authority citation for part
602 continues to read as follows:
Authority: 26 U.S.C. 7805.
Par. 7. In §602.101, paragraph (c) is
a m e n d e d b y a d d i n g t h e e n t r y
‘‘301.7701–4(e) .. . . 1545–1465’’ in
numerical order to the table.
Margaret Milner Richardson,
Commissioner of Internal Revenue.
Approved April 5, 1996.
Leslie Samuels,
Assistant Secretary of the Treasury.
(Filed by the Office of the Federal Register on
April 30, 1996, 8:45 a.m., and published in the
issue of the Federal Register for May 1, 1996,
61 F.R. 19189)

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Part III.Administrative, Procedural, and Miscellaneous
RRSPs and RRIFs Under 1995
Protocol to U.S.-Canada Income Tax
Treaty
Notice 96–31
This notice clarifies the application
of the Convention Between the United
States of America and Canada with
Respect to Taxes on Income and on
Capital, dated September 26, 1980, as
amended by the Protocols dated June
14, 1983, March 28, 1984, and March
17, 1995 (the ‘‘Convention’’) to divi-
dends and interest derived by, distribu-
tions from, and income accrued in
Canadian Registered Retirement Sav-
ings Plans (‘‘RRSPs’’) and Registered
Retirement Income Funds (‘‘RRIFs’’).
Article 9(1) of the Protocol of March
17, 1995 (the ‘‘Protocol’’), amended
paragraph 3 of Article XVIII (Pensions
and Annuities) of the Convention to
expand the definition of ‘‘pensions’’ to
include a retirement ‘‘arrangement.’’
Article 9(3) of the Protocol added
paragraph 7 to Article XVIII of the
Convention, allowing a citizen or re-
sident of one state to defer taxation in
that state on income accrued as the
beneficiary of a trust, company, organi-
zation or other arrangement that is a
resident of, and generally exempt from
income taxation in the other state, until
the income is distributed from the plan,
or any plan substituted therefor,
provided that the arrangement is oper-
ated exclusively to provide pension,
retirement or employee benefits. Under
Article 21(2)(a) of the Protocol, these
revisions of Article XVIII apply to
amounts paid or credited on or after
January 1, 1996.
Article 10(1) of the Protocol
amended paragraph 2 of Article XXI
(Exempt Organizations) of the Conven-
tion to provide an exemption from
taxation for dividends and interest
derived from one Contracting State by
certain trusts, companies, organizations
or other arrangements resident in the
other Contracting State. The trust,
company, organization or other ar-
rangement generally must be exempt
from income taxation in the taxable
year in the resident Contracting State,
and be operated exclusively either to
administer or provide pension, retire-
ment or employee benefits, or to earn
income for the benefit of an exempt
trust, company, organization or other
retirement arrangement providing such
benefits. The exemption does not apply
to income from carrying on a trade or
business or from certain related per-
sons. Under Article 21(2)(b) of the
Protocol, the revision of Article XXI
applies to taxable years of RRSPs or
RRIFs beginning on or after January 1.
1996.
The Treasury Department Technical
Explanation of the Protocol (‘‘Techni-
cal Explanation’’) states that RRSPs
and RRIFs, for example, are eligible
for benefits under paragraph 7 of
Article XVIII and paragraph 2 of
Article XXI provided that they are
‘‘operated exclusively to provide’’ or
‘‘administer,’’ in the case of Article
XXI(2), ‘‘pension, retirement, or
employee benefits.’’
The Technical Explanation was not
intended to imply that, under current
Canadian law, RRIFs and RRSPs might
not be eligible for benefits under
Articles XVIII(3) and (7) and XXI(2)
of the Convention because they might
not be operated exclusively to provide
pension, retirement or employee bene-
fits. It is the position of the Internal
Revenue Service that, under current
Canadian law, RRSPs and RRIFs are
examples of arrangements that meet the
conditions stated in the Protocol. Thus,
RRSPs and RRIFs qualify for the
benefits of Article XVIII of the Con-
vention, and paragraph 2 of Article
XXI of the Convention, as amended by
Articles 9(1) and 9(3), and Article
10(1) of the Protocol, respectively.
The principal author of this notice is
Kenneth Allison of the Office of the
Associate Chief Counsel (Interna-
tional). For further information regard-
ing this notice contact Mr. Allison at
(202)-622-3860 (not a toll-free call).
Weighted Average Interest Rate
Update
Notice 96–32
Notice 88–73 provides guidelines for
determining the weighted average inter-
est rate and the resulting permissible
range of interest rates used to calculate
current liability for the purpose of the
full funding limitation of §412(c)(7) of
the Internal Revenue Code as amended
by the Omnibus Budget Reconciliation
Act of 1987 and as further amended by
the Uruguay Round Agreements Act,
Pub. L. 103–465 (GATT).
The average yield on the 30-year
Treasury Constant Maturities for April
1996 is 6.79 percent.
The following rates were determined
for the plan years beginning in the
month shown below.
MonthYear
Weighted
Average
90% to 108%
Permissible
Range
90% to 110%
Permissible
Range
May19966.936.24 to 7.496.24 to 7.63

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Drafting Information
The principal author of this notice is
Donna Prestia of the Employee Plans
Division. For further information re-
garding this notice, call (202) 622-6076
between 2:30 and 4:00 p.m. Eastern
time (not a toll-free number). Ms.
Prestia’s number is (202) 622-7377
(also not a toll-free number).
Definition of a Controlled Foreign
Corporation, Foreign Base Company
Income and Foreign Personal Holding
Company Income of a Controlled
Foreign Corporation; Correction
Notice 96–33
AGENCY: Internal Revenue Service,
Treasury.
A C T I O N : C o r r e c t i o n t o f i n a l
regulations.
SUMMARY: This document contains a
correction to final regulations (TD
8618 [1995–40 I.R.B. 4]) which were
published in the Federal Register for
Thursday, September 7, 1995 (60 FR
46500). The final regulations govern
the definition of a controlled foreign
corporation and the definitions of for-
eign base company income and foreign
personal holding company income of a
controlled foreign corporation.
EFFECTIVE DATE: September 7,
1995.
FOR FURTHER INFORMATION
CONTACT: Valerie Mark, (202)
622-3840 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations which are the
subject of this correction are under
sections 954 and 957 of the Internal
Revenue Code.
Need for Correction
As published, TD 8618 contains an
error that is in need of clarification.
Correction of Publication
Accordingly, the publication of the
final regulations which are the subject
of FR Doc. 95–21838 is corrected as
follows:
§602.101 [Corrected]
On page 46530, column 3, under
amendatory instruction 1. of ‘‘Par.
11.’’, §602.101(c) is corrected in the
table by removing the entry for
‘‘§1.954A–2’’.
Cynthia E. Grigsby,
Chief, Regulations Unit,
Assistant Chief Counsel (Corporate).
(Filed by the Office of the Federal Register on
March 29, 1996, 8:45 a.m., and published in
the issue of the Federal Register for April 1,
1996, 61 F.R. 14248)
26 CFR 601.105: Examination of returns and
claims for refund, credit, or abatement;
determination of correct tax liability.
(Also Part I, §911, 1.911–1)
Rev. Proc. 96–33
SECTION 1. PURPOSE
01.This revenue procedure provides
information to any individual who
failed to meet the eligibility require-
ments of §911(d)(1) of the Internal
Revenue Code because adverse condi-
tions in a foreign country precluded the
individual from meeting those require-
ments for taxable year 1995.
02.The Internal Revenue Service
previously has listed countries for
which the eligibility requirements of
§ 911(d)(1) of the Code are waived
under §911(d)(4) because of adverse
conditions in those countries during the
time periods stated. See Rev. Proc. 95–
45, 1995–44 I.R.B. 22, Rev. Proc. 94–
31, 1994–1 C.B. 625, Rev. Proc. 94–
15, 1994–1 C.B. 575, and Rev. Proc.
92–63, 1992–2 C.B. 421. This revenue
procedure relists countries where the
adverse conditions are still in effect.
Rev. Proc. 95–45, Rev. Proc. 94–31,
Rev. Proc. 94–15, and Rev. Proc. 92–
63 remain in full force and effect; the
older periods listed therein are omitted
from this revenue procedure solely for
brevity.
SEC. 2. BACKGROUND
01. Section 911(a) of the Code
allows a ‘‘qualified individual,’’ as
defined in §911(d)(1), to exclude
foreign earned income and housing cost
amounts from gross income. Section
911(c)(3) allows a qualified individual
to deduct housing cost amounts from
gross income.
02.Section 911(d)(1) of the Code
defines the term ‘‘qualified individual’’
as an individual whose tax home is in a
foreign country and who is (A) a citizen
of the United States and establishes to
the satisfaction of the Secretary of the
Treasury that the individual has been a
bona fide resident of a foreign country
or countries for an uninterrupted period
that includes an entire taxable year, or
(B) a citizen or resident of the United
States who, during any period of 12
consecutive months, is present in a
foreign country or countries during at
least 330 full days.
03.Section 911(d)(4) of the Code
provides an exception to the eligibility
requirements of §911(d)(1). An indi-
vidual will be treated as a qualified
individual with respect to a period in
which the individual was a bona fide
resident of, or was present in, a foreign
country if the individual left the
country during a period for which the
Secretary of the Treasury, after con-
sultation with the Secretary of State,
determines that individuals were re-
quired to leave because of war, civil
unrest, or similar adverse conditions
that precluded the normal conduct of
business. An individual must establish
that but for those conditions the indi-
vidual could reasonably have been
expected to meet the eligibility
requirements.
04.For purposes of §911(d)(4) of
the Code, the Secretary of the Treasury
in consultation with the Secretary of
State, has determined that war, civil
unrest, or similar adverse conditions
that precluded the normal conduct of
business existed in the following coun-
tries during the specified periods:

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Date of Departure
CountryOn or AfterOn or Before
AfghanistanApril 23, 1979(still in effect)
Bosnia and HerzegovinaApril 7, 1992(still in effect)
CroatiaApril 7, 1992(still in effect)
IranSeptember 1, 1978(still in effect)
LebanonAugust 31, 1979(still in effect)
The Former Yugoslav Republic of MacedoniaJune 13, 1992(still in effect)
1)MontenegroJune 13, 1992(still in effect)
1)SerbiaJune 13, 1992(still in effect)
SomaliaDecember 21, 1990(still in effect)
1)Montenegro and Serbia, formerly part of the Socialist Federal Republic of Yugoslavia, have asserted the formation
of a joint independent state, but this entity has not been formally recognized as a state by the United States.
.05Accordingly, for purposes of
§ 911 of the Code, an individual who
left one of the foregoing countries
during the specified period shall be
treated as a qualified individual with
respect to the period during which that
individual was a bona fide resident of,
or present in, that foreign country if the
individual establishes a reasonable ex-
pectation of meeting the requirements
of §911(d) but for those conditions.
.06 To qualify for relief under
§ 911(d)(4), an individual must have
established residency or have been
physically present in the foreign coun-
try on or prior to the date that the
Secretary of the Treasury determines
that individuals were required to leave
the foreign country. Individuals who
establish residency or are first phys-
ically present in the foreign country
after the date that the Secretary pre-
scribes, but during the period for which
the Secretary determines that individ-
uals were required to leave the foreign
country, shall not be treated as
qualified individuals under §911(d)(4)
pursuant to §911(d)(4)(C). For exam-
ple, individuals who establish residency
or are first physically present in Iran
after September 1, 1978, are not
eligible to qualify for the exemption
prescribed in §911(d)(4). The same
holds true with respect to individuals
who move to Afghanistan after April
23, 1979, or Lebanon after August 31,
1979.
SEC. 3. INQUIRIES
A taxpayer who needs assistance on
how to claim this exclusion, or on how
to file an amended return, should
contact a local IRS Office or, for a
taxpayer residing or traveling outside
the United States, the nearest overseas
IRS office.
SEC. 4. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 91–29, 1991–1 C.B. 562
is obsoleted.
DRAFTING INFORMATION
The principal author of this revenue
procedure is Leslie B. van der Wal of
the Office of Associate Chief Counsel
(International). For further information
regarding this revenue procedure con-
tact Ms. van der Wal on (202)
622-3880 (not a toll-free call).

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101996–27 I.R.B.
Part IV. Items of General Interest
OMB Approval of Form 3115
Announcement 96–47
Form 3115, Application for Change
in Accounting Method, and the separate
Instructions for Form 3115, were
revised and have been approved by the
Office of Management and Budget
(OMB) through May 31, 1999. This
February 1996 revision is the current
Form 3115 and replaces the November
1992 version. Copies of the revised
form and instructions are available at
most IRS offices.
Applicants may order Form 3115 by
telephone or they may use other IRS
electronic information services to get
copies.
Request by—Number or Address
Telephone800-TAX-FORM
(800-829-3676)
Computer and
modem
703-321-8020
(modem settings are
N, 8, 1)
Internet:
World Wide
Web
FTP
Telnet
www.irs.ustreas.gov
ftp.irs.ustreas.gov
iris.irs.ustreas.gov
FUTA Taxation of Amounts Under
Employee Benefits Plans; FICA
Taxation of Amounts Under Employee
Benefits Plans; Hearing
Announcement 96–48
AGENCY: Internal Revenue Service,
Treasury.
ACTION: Notice of public hearing on
proposed regulations.
SUMMARY: This document provides
notice of a public hearing on proposed
Income Tax Regulations relating to
when amounts deferred under or paid
from certain nonqualified deferred
compensation plans are taken into
account as ‘‘wages’’ for purposes of
the employment taxes imposed by the
Federal Unemployment Tax Act and
the Federal Insurance Contributions
Act.
DATES: The public hearing will be
held on Monday, June 24, 1996,
beginning at 10:00 a.m. Requests to
speak and outlines of oral comments
must be received by Monday, June 3,
1996.
ADDRESSES: The public hearing will
be held in the Internal Revenue Service
Auditorium, Seventh Floor, 7400 Cor-
ridor, Internal Revenue Building, 1111
Constitution Avenue, NW, Washington,
DC. Requests to speak and outlines of
oral comments should be submitted to
the Internal Revenue Service, P.O. Box
7604, Ben Franklin Station, Attn:
CC:DOM:CORP:R [EE–55–95]; [EE–
142–87] Room 5228, Washington, DC
20044.
FOR FURTHER INFORMATION
CONTACT: Mike Slaughter of the
Regulations Unit, Assistant Chief
Counsel (Corporate), (202) 622-7190,
(not a toll-free number).
SUPPLEMENTARY INFORMATION:
The subject of the public hearing is
proposed amendments to the Income
Tax Regulations under sections 3306
and 3121 of the Internal Revenue Code
of 1986. These proposed regulations
(EE–55–95, 1996–12 I.R.B. 12; EE–
142–87, 1996–12 I.R.B. 13) appeared
in the Federal Register for Thursday,
January 25, 1996 (61 FR 2194; 2214).
The rules of §601.601 (a)(3) of the
‘‘Statement of Procedural Rules’’ (26
CFR part 601) shall apply with respect
to the public hearing. Persons who
have submitted written comments with-
in the time prescribed in the notice of
proposed rulemaking and who also
desire to present oral comments at the
hearing on the proposed regulations
should submit not later than Monday,
June 3, 1996, an outline of the oral
comments/testimony to be presented at
the hearing and the time they wish to
devote to each subject.
Each speaker (or group of speakers
representing a single entity) will be
limited to 10 minutes for an oral
presentation exclusive of the time
consumed by the questions from the
panel for the government and answers
to these questions.
Because of controlled access restric-
tions, attendees cannot be admitted
beyond the lobby of the Internal
Revenue Building until 9:45 a.m.
An agenda showing the scheduling
of the speakers will be made after
outlines are received from the persons
testifying. Copies of the agenda will be
available free of charge at the hearing.
Cynthia E. Grigsby,
Chief, Regulations Unit,
Assistant Chief Counsel (Corporate).
(Filed by the Office of the Federal Register on
May 7, 1996, 8:45 a.m., and published in the
issue of the Federal Register for May 8, 1996,
61 F.R. 20767)
Loans to Plan Participants; Hearing
Announcement 96–49
AGENCY: Internal Revenue Service,
Treasury.
ACTION Notice of public hearing on
proposed rulemaking.
SUMMARY: This document provides
notice of a public hearing on proposed
regulations relating to loans made from
a qualified employer plan to plan
participants or beneficiaries.
DATES: The public hearing will be
held on Friday, June 28, 1996, begin-
ning at 10:00 a.m. Requests to speak
and outlines or oral comments must be
received by Friday, May 31, 1996.
ADDRESSES: The public hearing will
be held in the Internal Revenue Service
Auditorium, Seventh Floor, 7400 Cor-
ridor, Internal Revenue Building, 1111
Constitution Avenue NW, Washington,
DC. Requests to speak and outlines of
oral comments should be mailed to the
Internal Revenue Service, P.O. Box
7604, Ben Franklin Station, Attn:
CC:DOM:CORP:R [EE 106–82], Room
5226, Washington, DC 20044.
FOR FURTHER INFORMATION
CONTACT: Christina Vasquez of Reg-
ulations Unit, Assistant Chief Counsel
(Corporate), (202) 622-6803 (not a toll-
free number).

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SUPPLEMENTARY INFORMATION:
The subject of the public hearing is
proposed amendments to the Income
Tax Regulations under section 72 of
the Internal Revenue Code of 1986.
The proposed regulations (EE–106–82,
1996–10 I.R.B. 31) appeared in the
Federal Register for Thursday, Decem-
ber 21, 1995 (60 FR 66233).
The rules of §601.601(a)(3) of the
‘‘Statement of Procedural Rules’’ (26
CFR Part 601) shall apply with respect
to the public hearing. Persons who
have submitted written comments with-
in the time prescribed in the notice of
proposed rulemaking and who also
desire to present oral comments at the
hearing on the proposed regulations
should submit not later than Friday,
May 31, 1996, an outline of the oral
comments/testimony to be presented at
the hearing and the time they wish to
devote to each subject.
Each speaker (or group of speakers
representing a single entity) will be
limited to 10 minutes for an oral
presentation exclusive of the time
consumed by the questions from the
panel for the government and answer
thereto.
Because of controlled access restric-
tions, attenders cannot be admitted
beyond the lobby of the Internal
Revenue Building until 9:45 a.m.
An agenda showing the scheduling
of the speakers will be make after
outlines are received from the persons
testifying. Copies of the agenda will be
available free of charge at eh hearing.
Cynthia E. Grigsby,
Chief, Regulations Unit,
Assistant Chief Counsel (Corporate).
(Filed by the Office of the Federal Register on
May 7, 1996, 8:45 a.m., and published in the
issue of the Federal Register for May 8, 1996,
61 F.R. 20766)
Section 6662—Imposition of the
Accuracy-Related Penalty; Correction
Announcement 96–50
AGENCY: Internal Revenue Service,
Treasury.
ACTION: Correction to final and tem-
porary regulations.
SUMMARY: This document contains
corrections to final and temporary
regulations [TD 8656 [1996–13 I.R.B.
9]] which were published in the Fed-
eral Register for Friday, February 9,
1996 (61 FR 4876). The regulations
provide guidance on the imposition of
the accuracy related penalty.
EFFECTIVE DATE: February 9, 1996.
FOR FURTHER INFORMATION
CONTACT: Carolyn D. Fanaroff of the
Office of Associate Chief Counsel
(International), (202) 622-3880 (not a
toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final and temporary regulations
that are the subject of these corrections
are under section 6662 of the Internal
Revenue Code.
Need for Correction
As published, TD 8656 contains
errors that are in need of clarification.
Correction of Publication
Accordingly, the publication of final
and temporary regulations which are
the subject of FR Doc. 96–2171 is
corrected as follows:
1.On page 4878, column 1, in the
preamble following the paragraph head-
ing ‘‘Reasonably Thorough Search for
Data’’, third full paragraph, line 8, the
language ‘‘expense a search for data
against (i) the’’ is corrected to read
‘‘expense of a search for data against
(i) the’’.
§1.6662–0 [Corrected]
2. On page 4879, column 2,
§1.6662–0, the entry for §1.6662–
5T(e)(4) and (e)(4)(i) are corrected to
read as follows:
§1.6662–0 Table of contents.
******
§1.6662–5T Substantial and gross
valuation misstatements under chapter
1 (Temporary).
******
(e)(4) Tests related to section 482.
(i) Substantial valuation misstatement.
******
§1.6662–5T [Corrected]
3. On page 4880, column 1,
§1.6662–5T, paragraph (e)(4)(iii), lines
5 through 9, the language ‘‘such as
land, buildings, fixtures and inventory.
Intangible property includes property
such as goodwill. Covenants not to
compete, leaseholds, patents, contract
rights, debts and choses in’’ is cor-
rected to read ‘‘such as money, land,
buildings, fixtures and inventory. Intan-
gible property includes property such
as goodwill, covenants not to compete,
leaseholds, patents, contract rights,
debts, choses in’’.
§1.6662–6 [Corrected]
4. On page 4882, column 3,
§1.6662–6, paragraph (d)(2)(iii)(A),
line 10, the language ‘‘provided the
most accurate measure of’’ is corrected
to read ‘‘provided the most reliable
measure of’’.
5. On page 4883, column 1,
§1.6662–6, paragraph (d)(2)(iii)(C),
line 2 from the bottom of the page, the
language ‘‘provided the most accurate
measure of’’ is corrected to read
‘‘provided the most reliable measure
of’’.
6. On page 4884, column 2,
§1.6662–6, paragraph (e), in the Exam-
ple., line 7, the language ‘‘which was
carried to taxpayer’s year 2 year’’ is
corrected to read ‘‘which was carried
to taxpayer’s year 2’’.
Cynthia E. Grigsby,
Chief, Regulations Unit,
Assistant Chief Counsel (Corporate).
(Filed by the Office of the Federal Register on
March 29, 1996, 8:45 a.m., and published in
the issue of the Federal Register for April 1,
1996, 61 F.R. 14248)
Regulations on Effectively Connected
Income and the Branch Profits Tax;
Correction
Announcement 96–51
AGENCY: Internal Revenue Service,
Treasury.
ACTION: Correction to final and tem-
porary regulations.

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SUMMARY: This document contains
corrections to final Income Tax Reg-
ulations (TD 8657 [1996–14 I.R.B. 4]),
which were published in the Federal
Register on Friday, March 8, 1996 (61
FR 9336), relating to the determination
of effectively connected income; and
final and temporary Income Tax Reg-
ulations relating to the branch-level
interest tax, respectively.
EFFECTIVE DATE: June 6, 1996.
FOR FURTHER INFORMATION
CONTACT: Gwendolyn A. Stanley,
(202) 622-3860 (not a toll-free
number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations that are the
subject of these corrections are under
sections 861, 864, 871, 884, and 897 of
the Internal Revenue Code.
Need for Correction
As published, the final regulations
(TD 8657) contain errors which may
prove to be misleading and are in need
of clarification.
Correction of Publication
Accordingly, the publication of the
final and temporary regulations (TD
8657) which are the subject of FR Doc.
96–5261 is corrected as follows:
§ 1.884–1 [Corrected]
1.On page 9338, column 3, in
amendatory instruction 11.b. under
‘‘Par. 5.’’, §1.884–1 (e)(5) Example 1.
the first entry in the table is corrected
to read as follows:
SentenceRemoveAdd
First, third, and
fifth sentence.
1993.....1997
*****
§ 1.884–5 [Corrected]
2. On page 9343, column 1,
§ 1.884–5 (e)(4)(ii) , line 7, the lan-
guage ‘‘country in its country of
residence’’ is corrected to read ‘‘corpo-
ration in its country of residence’’.
§ 1.897–1 [Corrected]
3.On page 9343, column 1, amenda-
tory instruction ‘‘Par. 10.’’ is corrected
by removing items 1. and 2. and
correcting ‘‘Par. 10.’’ to read as
follows:
Par. 10. Paragraph (f)(2)(i) in
§ 1.897–1 is revised to read as follows:
Cynthia E. Grigsby,
Chief, Regulations Unit,
Assistant Chief Counsel (Corporate).
(Filed by the Office of the Federal Register on
March 29, 1996, 8:45 a.m., and published in
the issue of the Federal Register for April 1,
1996, 61 F.R. 14247)
Deletions from Cumulative List of
Organizations Contributions to Which
Are Deductible Under Section 170 of
the Code
Announcement 96–52
The names of organizations that no
longer qualify as organizations de-
scribed in section 170(c)(2) of the
Internal Revenue Code of 1986 are
listed below.
Generally, the Service will not dis-
allow deductions for contributions
made to a listed organization on or
before the date of announcement in the
Internal Revenue Bulletin that an orga-
nization no longer qualifies. However,
the Service is not precluded from dis-
allowing a deduction for any contribu-
tions made after an organization ceases
to qualify under section 170(c)(2) if the
organization 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 determination letter, (2) was
aware that such revocation was immi-
nent, or (3) was in part responsible for
or was aware of the activities or
omissions of the organization that
brought about this revocation.
If on the other hand a suit for
declaratory 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 May 28, 1996, 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 ex-
tended 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.
Evangelism Outreach, Inc.
Franklin Springs, GA
Market Street Mission
Louisville, KY

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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
public accountant, enrolled agent or en-
rolled actuary, in order to avoid the in-
stitution or conclusion of a proceeding
for his disbarment or suspension from
practice before the Internal Revenue
Service, 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 account-
ants, enrolled agents and enrolled actu-
aries are prohibited in any Internal
Revenue Service matter from directly
or indirectly employing, accepting
assistance from, being employed by,
or sharing fees with, any practi-
tioner 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 attor-
ney, certified public accountant, en-
rolled agent or enrolled actuary and
date or period of suspension. This an-
nouncement will appear 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 or for as many weeks
as is practicable for each attorney,
certified public accountant, enrolled
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
Behrens, WilliamKenosha, WIEnrolled AgentMarch 6, 1996 to May 5, 1996
Warter, J. ChristopherSouth Bend, INAttorneyIndefinite from March 8, 1996
Leckie, Jerry B.Macon, GAEnrolled AgentMarch 9, 1996 to March 8, 1999
Retzlaff, GeneHortonville, WIEnrolled AgentMarch 18, 1996 to July 17, 1996
Cahill, DonalStratford, CTAttorneyApril 4, 1996 to April 3, 1997
Guidera, George C.Straford, CTAttorneyApril 11, 1996 to October 10, 1996
Kirk, Gregg T.Dallas, TXCPAIndefinite from May 1, 1996
Brock, Guy CharlesSpokane, WACPAIndefinite from May 1, 1996
Mathews, ThomasCincinnati, OHCPAMay 1, 1996 to August 31, 1996
Farnsworth Jr., HaroldStarke, FLCPAMay 1, 1996 to April 30, 1998
King, John C.Wichita, KSAttorneyMay 1, 1996 to August 31, 1996
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 account-
ants, enrolled agents, and enrolled ac-
tuaries are prohibited in any Internal
Revenue Service matter from directly
or indirectly employing, accepting as-
sistance from, being employed by, or
sharing 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 Serv-
ice, the Director of Practice will an-
nounce in the Internal Revenue Bulletin
the names and addresses of practition-
ers who have been suspended from such
practice, their designation as attorney,
certified public accountant, enrolled
agent, or enrolled actuary, and date or
period of suspension. This announce-
ment will appear in the weekly Bulletin
at the earliest practicable date after
such action and will continue to appear
in the weekly Bulletins for five succes-
sive weeks or for as many weeks as is
practicable for each attorney, certified
public accountant, enrolled 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
provisions of the applicable regulations:

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NameAddressDesignationDate of Suspension
Noske, Joan M.Richmond, MNCPAIndefinite from March 1, 1996
Wahl, Roger W.Martinez, GACPAIndefinite from March 1, 1996
Stojanov, DraganDetroit, MIAttorneyIndefinite from March 13, 1996
Gay, Randall D.Honolulu, HICPAIndefinite from March 13, 1996
Sheffey, RalphLaCrosse, WIAttorneyIndefinite from March 13, 1996
Doyle, RobertSacramento, CACPAIndefinite from March 19, 1996
Singer, Michael G.Minnetonka, MNAttorneyIndefinite from March 19, 1996
Mohme, Robert H.St. Louis, MOAttorneyIndefinite from March 20, 1996
Vogelei, George MacNovato, CAAttorneyIndefinite from March 20, 1996
Gaskins, Oscar N.Cherry Hill, NJAttorneyIndefinite from March 26, 1996
Gawel, Michael S.Niagara Falls, NYAttorneyIndefinite from March 29, 1996

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Definition of Terms
Revenue rulings and revenue proce-
dures (hereinafter referred to as ‘‘rul-
ings’’) that have an effect on previous
rulings use the following defined terms
to describe the effect:
Amplified describes a situation where
no change is being made in a prior
published position, but the prior posi-
tion 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 princi-
ple also applies to B, the earlier ruling
is amplified. (Compare with modified,
below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in
a prior ruling is being changed.
Distinguished describes a situation
where a ruling mentions a previously
published ruling and points out an
essential difference between them.
Modified is used where the substance
of a previously published position is
being changed. Thus, if a prior ruling
held that a principle applied to A but
not to B, and the new ruling holds that
it applies to both A and B, the prior
ruling is modified because it corrects a
published position. (Compare with am-
plified and clarified, above).
Obsoleted describes a previously
published ruling that is not considered
determinative with respect to future
transactions. This term is most com-
monly used in a ruling that lists
previously published rulings that are
obsoleted because of changes in law or
regulations. A ruling may also be
obsoleted because the substance has
been included in regulations subse-
quently adopted.
Revoked describes situations where
the position in the previously published
ruling is not correct and the correct
position is being stated in the new
ruling.
Superseded describes a situation
where the new ruling does nothing
more than restate the substance and
situation of a previously published
ruling (or rulings). Thus, the term is
used to republish under the 1986 Code
and regulations the same position pub-
lished under the 1939 Code and regula-
tions. The term is also used when it is
desired to republish in a single ruling a
series of situations, names, etc., that
were previously published over a
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, modified and superseded de-
scribes 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 published ruling is
first modified and then, as modified, is
superseded.
Supplemented is used in situations in
which a list, such as a list of the names
of countries, is published in a ruling
and that list is expanded by adding
further names in subsequent rulings.
After the original ruling has been
supplemented several times, a new
ruling may be published that includes
the list in the original ruling and the
additions, and supersedes all prior
rulings in the series.
Suspended is used in rare situations
to show that the previous published
rulings will not be applied pending
some future action such as the issuance
of new or amended regulations, the
outcome of cases in litigation, or the
outcome of a Service study.
Abbreviations
The following abbreviations in current use and
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.

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Numerical Finding List
1
Bulletins 1996–1 through 1996–21
Announcements:
96–1, 1996–2 I.R.B. 57
96–2, 1996–2 I.R.B. 57
96–3, 1996–2 I.R.B. 57
96–4, 1996–3 I.R.B. 50
96–5, 1996–4 I.R.B. 99
96–6, 1996–5 I.R.B. 43
96–7, 1996–5 I.R.B. 44
96–8, 1996–7 I.R.B. 56
96–9, 1996–8 I.R.B. 30
96–10, 1996–8 I.R.B. 30
96–11, 1996–9 I.R.B. 11
96–12, 1996–11 I.R.B. 30
96–13, 1996–12 I.R.B. 33
96–14, 1996–12 I.R.B. 35
96–15, 1996–11 I.R.B. 9
96–16, 1996–13 I.R.B. 22
96–17, 1996–13 I.R.B. 22
96–18, 1996–15 I.R.B. 15
96–19, 1996–15 I.R.B. 15
96–20, 1996–15 I.R.B. 15
96–21, 1996–15 I.R.B. 15
96–22, 1996–15 I.R.B. 16
96–23, 1996–18 I.R.B. 7
96–24, 1996–16 I.R.B. 35
96–25, 1996–17 I.R.B. 13
96–26, 1996–17 I.R.B. 13
96–27, 1996–17 I.R.B. 16
96–28, 1996–17 I.R.B. 16
96–29, 1996–17 I.R.B. 17
96–30, 1996–17 I.R.B. 17
96–31, 1996–17 I.R.B. 18
96–32, 1996–17 I.R.B. 18
96–33, 1996–18 I.R.B. 12
96–34, 1996–18 I.R.B. 13
96–35, 1996–18 I.R.B. 13
96–36, 1996–18 I.R.B. 13
96–37, 1996–18 I.R.B. 14
96–38, 1996–19 I.R.B. 84
96–39, 1996–19 I.R.B. 84
96–40, 1996–19 I.R.B. 85
96–41, 1996–20 I.R.B. 18
96–42, 1996–20 I.R.B. 18
96–43, 1996–20 I.R.B. 18
96–44, 1996–21 I.R.B. 10
96–45, 1996–21 I.R.B. 10
96–46, 1996–21 I.R.B. 10
Delegations Orders:
232 (Rev. 2), 1996–7 I.R.B. 49
236 (Rev. 2), 1996–21 I.R.B. 7
239 (Rev. 1), 1996–7 I.R.B. 49
247, 1996–21 I.R.B. 7
Notices:
96–2, 1996–2 I.R.B. 15
96–1, 1996–3 I.R.B. 30
See footnote at the end of list.
Notices—Continued
96–4, 1996–4 I.R.B. 69
96–5, 1996–6 I.R.B. 22
96–6, 1996–5 I.R.B. 27
96–7, 1996–6 I.R.B. 22
96–8, 1996–6 I.R.B. 23
96–9, 1996–6 I.R.B. 26
96–10, 1996–7 I.R.B. 47
96–11, 1996–8 I.R.B. 19
96–12, 1996–10 I.R.B. 29
96–13, 1996–10 I.R.B. 29
96–14, 1996–12 I.R.B. 11
96–15, 1996–13 I.R.B. 19
96–16, 1996–13 I.R.B. 20
96–17, 1996–13 I.R.B. 20
96–18, 1996–14 I.R.B. 27
96–19, 1996–14 I.R.B. 28
96–20, 1996–14 I.R.B. 30
96–21, 1996–14 I.R.B. 30
96–22, 1996–14 I.R.B. 30
96–23, 1996–16 I.R.B. 23
96–24, 1996–16 I.R.B. 23
96–25, 1996–17 I.R.B. 11
96–26, 1996–18 I.R.B. 4
96–27, 1996–18 I.R.B. 4
96–28, 1996–19 I.R.B. 7
96–29, 1996–19 I.R.B. 7
96–30, 1996–20 I.R.B. 11
Proposed Regulations:
DL–1–95, 1996–6 I.R.B. 28
EE–20–95, 1996–5 I.R.B. 15
EE–34–95, 1996–3 I.R.B. 49
EE–35–95, 1996–5 I.R.B. 19
EE–53–95, 1996–5 I.R.B. 23
EE–55–95, 1996–12 I.R.B. 12
EE–106–82, 1996–10 I.R.B. 31
EE–142–87, 1996–12 I.R.B. 13
EE–148–81, 1996–11 I.R.B. 29
GL–1–96, 1996–21 I.R.B. 7
IA–3–94, 1996–17 I.R.B. 12
IA–33–95, 1996–4 I.R.B. 99
IA–41–93, 1996–11 I.R.B. 29
INTL–3–95, 1996–6 I.R.B. 29
INTL–9–95, 1996–5 I.R.B. 25
INTL–54–95, 1996–14 I.R.B. 39
INTL–62–90; INTL–32–93;
INTL–52–86; INTL–52–94,
1996–19 I.R.B. 26
PS–2–95, 1996–7 I.R.B. 50
PS–4–96, 1996–18 I.R.B. 5
PS–6–95, 1996–16 I.R.B. 27
Revenue Procedures:
96–1, 1996–1 I.R.B. 8
96–2, 1996–1 I.R.B. 60
96–3, 1996–1 I.R.B. 82
96–4, 1996–1 I.R.B. 94
96–5, 1996–1 I.R.B. 129
96–6, 1996–1 I.R.B. 151
96–7, 1996–1 I.R.B. 185
Revenue Procedures—Continued
96–8, 1996–1 I.R.B. 187
96–8A, 1996–9 I.R.B. 10
96–9, 1996–2 I.R.B. 15
96–10, 1996–2 I.R.B. 17
96–11, 1996–2 I.R.B. 18
96–12, 1996–3 I.R.B. 30
96–13, 1996–3 I.R.B. 31
96–14, 1996–3 I.R.B. 41
96–15, 1996–3 I.R.B. 41
96–16, 1996–3 I.R.B. 45
96–17, 1996–4 I.R.B. 69
96–18, 1996–4 I.R.B. 73
96–19, 1996–4 I.R.B. 80
96–20, 1996–4 I.R.B. 88
96–21, 1996–4 I.R.B. 96
96–22, 1996–5 I.R.B. 27
96–23, 1996–5 I.R.B. 27
96–24, 1996–5 I.R.B. 28
96–24A, 1996–15 I.R.B. 12
96–25, 1996–8 I.R.B. 19
96–26, 1996–8 I.R.B. 22
96–27, 1996–11 I.R.B. 27
96–28, 1996–14 I.R.B. 31
96–29, 1996–16 I.R.B. 24
96–30, 1996–19 I.R.B. 8
96–31, 1996–20 I.R.B. 11
96–32, 1996–20 I.R.B. 14
Revenue Rulings:
96–1, 1996–1 I.R.B. 7
96–2, 1996–2 I.R.B. 5
96–3, 1996–2 I.R.B. 14
96–6, 1996–2 I.R.B. 8
96–4, 1996–3 I.R.B. 16
96–5, 1996–3 I.R.B. 29
96–7, 1996–3 I.R.B. 12
96–8, 1996–4 I.R.B. 62
96–9, 1996–4 I.R.B. 5
96–10, 1996–4 I.R.B. 27
96–11, 1996–4 I.R.B. 28
96–12, 1996–9 I.R.B. 4
96–13, 1996–10 I.R.B. 19
96–14, 1996–6 I.R.B. 20
96–15, 1996–11 I.R.B. 9
96–16, 1996–11 I.R.B. 4
96–17, 1996–13 I.R.B. 5
96–18, 1996–13 I.R.B. 4
96–19, 1996–14 I.R.B. 24
96–20, 1996–15 I.R.B. 5
96–21, 1996–15 I.R.B. 7
96–22, 1996–15 I.R.B. 9
96–23, 1996–15 I.R.B. 11
96–24, 1996–19 I.R.B. 5
96–25, 1996–19 I.R.B. 4
96–26, 1996–21 I.R.B. 9
Treasury Decisions:
8630, 1996–3 I.R.B. 19
8631, 1996–3 I.R.B. 7
8632, 1996–4 I.R.B. 6

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Numerical Finding List
1
—Continued
Bulletins 1996–1 through 1996–21
Treasury Decisions—Continued
8633, 1996–4 I.R.B. 20
8634, 1996–3 I.R.B. 17
8635, 1996–3 I.R.B. 5
8636, 1996–4 I.R.B. 64
8637, 1996–4 I.R.B. 29
8638, 1996–5 I.R.B. 5
8639, 1996–5 I.R.B. 12
8640, 1996–2 I.R.B. 10
8641, 1996–6 I.R.B. 4
8642, 1996–7 I.R.B. 4
8643, 1996–11 I.R.B. 4
8644, 1996–7 I.R.B. 16
8645, 1996–8 I.R.B. 4
8646, 1996–8 I.R.B. 10
8647, 1996–9 I.R.B. 7
8648, 1996–10 I.R.B. 23
8649, 1996–9 I.R.B. 5
8650, 1996–10 I.R.B. 5
8651, 1996–11 I.R.B. 24
8652, 1996–11 I.R.B. 11
8653, 1996–12 I.R.B. 4
8654, 1996–11 I.R.B. 14
8655, 1996–12 I.R.B. 9
8656, 1996–13 I.R.B. 9
8657, 1996–14 I.R.B. 4
8658, 1996–14 I.R.B. 13
8659, 1996–16 I.R.B. 4
8660, 1996–17 I.R.B. 4
8661, 1996–17 I.R.B. 7
8664, 1996–20 I.R.B. 7
8665, 1996–21 I.R.B. 4
8667, 1996–20 I.R.B. 4
1
A cumulative list of all Revenue Rulings,
Revenue Procedures, Treasury Decisions, etc.,
published in Internal Revenue Bulletins 1995–
27 through 1995–52 will be found in Internal
Revenue Bulletin 1996–1, dated January 2,
1996.

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Finding List of Current Action on
Previously Published Items
1
Bulletins 1996–1 through 1996–21
*Denotes entry since last publication
Delegation Orders:
232 (Rev. 1)
Superseded by
232 (Rev. 2), 1996–7 I.R.B. 49
236 (Rev. 1)
Superseded by
236 (Rev. 2), 1996–21 I.R.B. 7*
239
Amended by
239 (Rev. 1), 1996–7 I.R.B. 49
Revenue Procedures:
65–17
Modified by
96–14, 1996–3 I.R.B. 41
66–49
Modified by
96–15, 1996–3 I.R.B. 41
88–32
Obsoleted by
96–15, 1996–3 I.R.B. 41
88–33
Obsoleted by
96–15, 1996–3 I.R.B. 41
89–19
Superseded by
96–17, 1996–4 I.R.B. 69
89–48
Superseded in part by
96–17, 1996–4 I.R.B. 69
91–22
Modified by
96–1, 1996–1 I.R.B. 8
91–22
Amplified by
96–13, 1996–3 I.R.B. 31
91–23
Superseded by
96–13, 1996–3 I.R.B. 31
91–24
Superseded by
96–14, 1996–3 I.R.B. 41
91–26
Superseded by
96–13, 1996–3 I.R.B. 31
92–20
Modified by
96–1, 1996–1 I.R.B. 8
1
A cumulative finding list for previously
published items mentioned in Internal Revenue
Bulletins 1995–27 through 1995–52 will be
found in Internal Revenue Bulletin 1996–1, dated
January 2, 1996.
Revenue Procedures—Continued
96–31, 1996–20 I.R.B. 11
92–85
Modified by
96–1, 1996–1 I.R.B. 8
93–16
Superseded by
96–11, 1996–2 I.R.B. 18
93–46
Superseded in part by
96–17, 1996–4 I.R.B. 69
Superseded by
96–18, 1996–4 I.R.B. 73
94–16
Modified by
96–29, 1996–16 I.R.B. 24
94–18
Superseded in part by
96–17, 1996–4 I.R.B. 69
Superseded by
96–18, 1996–4 I.R.B. 73
94–59
Superseded in part by
96–17, 1996–4 I.R.B. 69
Superseded by
96–18, 1996–4 I.R.B. 73
94–62
Modified by
96–29, 1996–16 I.R.B. 24
94–77
Superseded by
96–28, 1996–14 I.R.B. 31
95–1
Superseded by
96–1, 1996–1 I.R.B. 8
95–2
Superseded by
96–2, 1996–1 I.R.B. 60
95–3
Superseded by
96–3, 1996–1 I.R.B. 82
95–4
Superseded by
96–4, 1996–1 I.R.B. 94
95–5
Superseded by
96–5, 1996–1 I.R.B. 129
95–6
Superseded by
96–6, 1996–1 I.R.B. 151
Revenue Procedures—Continued
95–66
Modified by
96–25, 1996–19 I.R.B. 4
95–7
Superseded by
96–7, 1996–1 I.R.B. 185
95–8
Superseded by
96–8, 1996–1 I.R.B. 187
95–13
Superseded by
96–20, 1996–4 I.R.B. 88
95–20
Superseded by
96–24, 1996–5 I.R.B. 28
95–50
Superseded by
96–3, 1996–1 I.R.B. 82
96–3
Amplified by
96–12, 1996–3 I.R.B. 30
Revenue Rulings:
66–307
Obsoleted by
96–3, 1996–2 I.R.B. 14
72–437
Modified by
96–13, 1996–3 I.R.B. 31
78–294
Obsoleted by
8665, 1996–21 I.R.B. 4
80–80
Obsoleted by
96–3, 1996–2 I.R.B. 14
82–80
Modified by
96–14, 1996–3 I.R.B. 41
92–19
Supplemented in part
96–2, 1996–2 I.R.B. 5
92–75
Clarified by
96–13, 1996–3 I.R.B. 31
95–10
Supplemented and superseded by
96–4, 1996–3 I.R.B. 16
95–11
Supplemented and superseded by
96–5, 1996–3 I.R.B. 29
96–24
Modified and amplified by
96–24A, 1996–15 I.R.B. 12