Internal Revenue Bulletin 1996-15 (PDF rendition): IRS Revenue Rulings

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Bulletin No. 1996–15
April 8, 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 ANNOUNCEMENT
Announcement 96–22, page 16.
A public hearing will be held on April 24, 1996, on
proposed regulations that provide guidance concerning
the notice and consent requirements under section
411(a)(11) and the notice and election requirements of
section 417.
INCOME TAX
Rev. Rul. 96–22, page 9.
LIFO; price indexes; department stores. The February
1996 Bureau of Labor Statistics price indexes are
accepted for use by department stores employing the
retail inventory and last-in, first-out inventory methods
for valuing inventories for tax years ended on, or with
reference to, February 29, 1996.
EMPLOYEE PLANS
Rev. Rul. 96–20, page 5.
Additional funding requirements for certain plans. Ques-
tions and answers with respect to the establishment
and maintenance of amortization bases for certain
plans that have additional funding requirements de-
scribed in section 412(l) of the Internal Revenue Code
as amended by the Uruguay Round Agreements Act,
which includes the Retirement Protection Act of 1994,
are set forth.
Rev. Rul. 96–21, page 7.
Phase-in of increases in funding. Questions and answers
pertaining to the election to phase in increases in
additional funding requirements for certain plans under
section 412(l)(11) of the Internal Revenue Code as
amended by the Uruguay Round Amendments Act,
which includes the Retirement Protection Act of 1994,
are set forth.
Announcement 96–18, page 15.
This announcement describes two revenue rulings that
are being issued with respect to the additional funding
requirements under section 412(l) of the Internal
Revenue Code as they relate to the Form 5500
(Schedule B) for 1995.
EXEMPT ORGANIZATIONS
Announcement 96–21, page 16.
A list is given of organizations now classified as private
foundations.
ESTATE TAX
Rev. Rul. 96–23, page 11.
Special use value; farms; interest rates. The 1996
interest rates to be used in computing the special use
value of farm real property for which an election is
made under section 2032A of the Code are listed for
estates of decedents.
ADMINISTRATIVE
Rev. Proc. 96–24A, page 12.
General rules and specifications for private printing of
Forms W–2 and W–3. Specifications are set forth for the
private printing of paper substitutes for tax year 1996
Form W–2, Wage and Tax Statement, and Form W–3,
Transmittal of Wage and Tax Statements. Rev. Proc.
96–24 modified and amplified.
(Continued on page 4)
Finding Lists begins on page 21.
Announcement of Disbarments and Suspensions begin on page 18.

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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 Bulletin Index-Digest System, a research and
reference service supplementing the Bulletin, may be
obtained from the Superintendent of Documents on a
subscription basis. It consists of four Services: Service
No. 1, Income Tax; Service No. 2, Estate and Gift
Taxes; Service No. 3, Employment Taxes; Service No.
4, Excise Taxes. Each Service consists of a basic
volume and a cumulative supplement that provides (1)
finding lists of items published in the Bulletin, (2)
digests of revenue rulings, revenue procedures, and
other published items, and (3) indexes of Public Laws,
Treasury Decisions, and Tax Conventions.
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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HIGHLIGHTS
OF THIS ISSUE—Continued
ADMINISTRATIVE—Continued
Announcement 96–19, page 15.
T.D. 8634, 1996–3 I.R.B. 17, relating to the income
tax withholding requirement on distributions of profits
from certain gaming activities made to members of
Indian tribes, is corrected.
Announcement 96–20, page 15.
EE–24–93, 1995–41 I.R.B. 33, providing guidance
concerning the notice and consent requirements under
section 411(a)(11) and the notice and election require-
ments of section 417, is corrected.

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Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
Section 412.—Minimum Funding
Standards
Additional funding requirements for
certain plans. Questions and answers
with respect to the establishment and
maintenance of amortization bases for
certain plans that have additional fund-
ing requirements described in section
412(1) of the Internal Revenue Code as
amended by the Uruguay Round Agree-
ments Act, which includes the Retire-
ment Protection Act of 1994, are set
forth.
Rev. Rul. 96–20
PURPOSE
This revenue ruling provides ques-
tions and answers relating to the
establishment and maintenance of cer-
tain amortization bases under §412(l)
of the Internal Revenue Code, as
amended by the Retirement Protection
Act of 1994 (RPA ’94), which is part
of the Uruguay Round Agreements Act,
Pub. L. 103–65 (GATT).
BACKGROUND
Section 412 of the Code imposes
minimum funding requirements with
respect to defined benefit and money
purchase pension plans. Section 412(l)
sets forth additional funding require-
ments for certain underfunded defined
benefit pension plans that have more
than 100 participants and that are not
multiemployer plans.
The additional funding charge under
§ 412(l)(1) is determined as the sum of
(1) the excess (if any) of (A) the deficit
reduction contribution determined un-
der §412(l)(2) for the plan year over
(B) the sum of certain charges for the
plan year under §412(b)(2) reduced by
the sum of certain credits for the plan
year under §412(b)(3), and (2) the
unpredictable contingent event amount
(if any) for the plan year.
The deficit reduction contribution is
determined as the sum of the unfunded
new liability amount, the expected
increase in current liability due to
benefits accruing during the plan year,
and the amortization amounts for cer-
tain amortization bases. These amortiz-
ation bases (unfunded old liability,
unfunded existing benefit increase lia-
bility, additional unfunded old liability,
and the liability for unfunded mortality
increase) are collectively referred to in
this revenue ruling as ‘‘DRC amortiza-
tion bases.’’ The unfunded new lia-
bility amount is the applicable percent-
age of the unfunded new liability. The
applicable percentage is based upon the
plan’s funded current liability percent-
age. The unfunded new liability is the
excess, if any, of the unfunded current
liability for the plan year over the sum
of (1) the unamortized portions of the
DRC amortization bases, and (2) the
liability with respect to any unpredict-
able contingent event benefits for
which the unpredictable contingent
event has occurred.
The amortization base for the un-
funded old liability described in
§ 412(l)(3)(B) is established, if appro-
priate, for the plan year beginning in
1989. This unfunded old liability is
amortized over 18 years, beginning
with the 1989 plan year.
The amortization base for the un-
funded existing benefit increase lia-
bility described in §412(l)(3)(C)(ii) is
established, if appropriate, for the plan
year in which the benefit increase
relating to the liability becomes effec-
tive, or, at the election of the employer,
for the plan year beginning in 1989.
This unfunded existing benefit increase
liability is amortized over 18 years
beginning with the plan year for which
the base is established.
RPA ’94 amended §412(l), effective
for plan years beginning after Decem-
ber 31, 1994, to further specify the
actuarial assumptions used to determine
current liability for purposes of
§ 412(l). Section 412(l)(9)(A), added
by RPA ’94, provides that §412(l)
does not apply to plans with a funded
current liability percentage of at least
90 percent. Section 412(l)(9)(B)
provides a volatility rule under which
§ 412(l) also does not apply (for up to
a two-year period) to certain plans with
funded current liability percentages of
at least 80 percent.
Under RPA ’94, the amortization
base for the additional unfunded old
liability described in §412(l)(3)(D) is
established, if appropriate, for the 1995
plan year. Section 412(l)(3)(E) provides
an optional alternative calculation for
the additional unfunded old liability.
The additional unfunded old liability is
amortized over 12 years, beginning
with the 1995 plan year.
Under RPA ’94, the amortization
base for the unfunded mortality in-
crease described in §412(l)(10)(B) (the
increase in current liability resulting
from changes in the mortality table
used to determine current liability after
1999) is established, if appropriate, in
the first plan year a new mortality table
issued under §412(l)(7)(C)(ii)(II) or
(III) is used for the plan. This unfunded
mortality increase is amortized over a
period of 10 years beginning with the
plan year in which the base is
established.
Any plan year described above for
w h i c h a n a m o r t i z a t i o n b a s e i s
established, if appropriate, for purposes
of §412(l) is referred to in this
revenue ruling as a ‘‘DRC base year.’’
QUESTIONS AND ANSWERS ON
THE ESTABLISHMENT OF DRC
AMORTIZATION BASES
Q-1. If §412(l) applies to a plan for
a plan year that is a DRC base year,
must the appropriate DRC amortization
base be established for that plan year?
A-1. If §412(l) applies to a plan for
a plan year that is a DRC base year,
the appropriate DRC amortization base
must be established for that year. Thus,
for example, if §412(l) applies to a
plan for the 1995 plan year, the
increase in current liability resulting
from the required change in actuarial
assumptions must be included in the
additional unfunded old liability as
provided under §§ 412(l)(3)(D) or
412(l)(3)(E) and may not be included
in unfunded new liability.
Q-2. If §412(l) does not apply to a
plan for a plan year that is a DRC base
year, are any DRC amortization bases
established for that year to prepare for
the contingency that §412(l) may
apply to the plan in a future plan year?
A-2. If §412(l) does not apply to a
plan for a plan year that is a DRC base
year, then except as provided under
Q&A-3, no DRC amortization base is
established to prepare for the con-
tingency that §412(l) may apply to the
plan in a future plan year. For example,
if for the plan year beginning in 1989,
a plan had no unfunded current lia-
bility, was a multiemployer plan, or
had 100 or fewer participants within
the meaning of §412(l)(6), no amortiz-
ation base for unfunded old liability is

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established. Similarly, if for the plan
year beginning in 1995, a plan had a
funded current liability percentage (de-
termined under §412(l)(9)(C)) of 90
percent or greater, was a multiemployer
plan, or had 100 or fewer participants
within the meaning of §412(l)(6), no
amortization base for additional un-
funded old liability is established.
Q-3. In the case of a plan year that
is a DRC base year, if §412(l) does
not apply to a plan for that plan year
solely by reason of the application of
t h e e x c e p t i o n p r o v i d e d u n d e r
§ 412(l)(9)(B) (taking into account the
special rules of §412(l)(9)(D)), are any
DRC amortization bases established for
that plan year to prepare for the
contingency that §412(l) may apply to
the plan in a future plan year?
A-3. In the case of a plan year that
is a DRC base year, if §412(l) does
not apply to a plan for that plan year
solely by reason of the application of
t h e e x c e p t i o n p r o v i d e d u n d e r
§ 412(l)(9)(B) (taking into account the
special rules in §412(l)(9)(D)), the
appropriate DRC amortization base is
established for that plan year. Thus, for
example, if §412(l) does not apply to a
plan with a funded current liability
p e r c e n t a g e ( d e t e r m i n e d u n d e r
§ 412(l)(9)(C)) that is at least 80
percent but that is less than 90 percent
for the plan year beginning in 1995,
solely because of the exception under
§ 412(l)(9)(B) (taking into account the
special rules under §412(l)(9)(D)), an
additional unfunded old liability base is
established for that plan year. In such a
case, if the optional rule under
§ 412(l)(3)(E) is to be used to deter-
mine the additional unfunded old lia-
bility, an employer must make an
election which is reported on a timely
filed 1995 Form 5500.
Q-4. If §412(l) does not apply to a
plan for a plan year (other than by
reason of §412(l)(9)(B) and (D)) that
is a DRC base year (and, thus, no
amortization base is established for that
plan year in accordance with Q&A-2),
is the DRC amortization base that
would otherwise have been established
if §412(l) had applied to the plan for
that plan year established in any
subsequent year?
A-4. If §412(l) does not apply to a
plan for a plan year (other than by
reason of §412(l)(9)(B) and (D)) that
is a DRC base year (and, thus, no
amortization base is established for that
plan year in accordance with Q&A-2),
the DRC amortization base that other-
wise would have been established if
§ 412(l) had applied to the plan for that
plan year is not established or recreated
in any subsequent year. Thus, for
example, if a plan’s funded current
liability percentage (determined under
§ 412(l)(9)(C)) is at least 90 percent
for the 1995 plan year (and, thus,
§ 412(l) does not apply to the plan for
the 1995 plan year), and if §412(l)
applies to the plan for the 1996 plan
year, then for the 1996 plan year all of
the plan’s unfunded current liability
will be unfunded new liability (with the
possible exception of the liability with
respect to any unpredictable contingent
event benefits resulting from an unpre-
dictable contingent event that occurs in
1996).
QUESTIONS AND ANSWERS ON
THE MAINTENANCE OF DRC
AMORTIZATION BASES
Q-5. How is the unamortized portion
o f a D R C a m o r t i z a t i o n b a s e
determined?
A-5. For the plan year for which a
DRC amortization base is established,
the unamortized portion of that base is
the amount of the liability that gives
rise to the base, as determined under
§ 412(l)(3) or (10), as applicable. For
any subsequent plan year, the unamor-
tized portion of a DRC amortization
base is determined by reducing the
unamortized portion as of the valuation
date for the prior plan year by the
amortization amount for the prior plan
year, and adjusting the result with
interest to the valuation date in the
current plan year at the appropriate
current liability interest rate.
Q-6. How is the annual amortization
amount for a DRC amortization base
determined?
A-6. The annual amortization amount
for a DRC amortization base is deter-
mined by amortizing the unamortized
portion of the DRC amortization base
over the remainder of the statutory
amortization period using the appropri-
ate current liability interest rate for the
plan year. These annual amortization
amounts are included in the calculation
of the deficit reduction contribution
under §412(l)(2), until the DRC amor-
tization base is fully amortized or
considered to be fully amortized.
Q-7. When is a DRC amortization
base considered to be fully amortized
prior to the end of the scheduled
amortization period?
A-7. Except as otherwise provided in
this Q&A-7, a DRC amortization base
that was established in a prior DRC
base year is considered to be fully
amortized for the first plan year for
which §412(l) does not apply to the
plan. However, if §412(l) does not
apply to the plan for a plan year solely
by reason of the exception provided
under §412(l)(9)(B) (taking into ac-
c o u n t t h e s p e c i a l r u l e s i n
§ 412(l)(9)(D)), then any DRC amortiz-
ation bases are not considered to be
fully amortized for that plan year, but
are maintained in accordance with
Q&A-5 above. For example, under the
provisions of §412(l) as in effect prior
to amendment by RPA ’94, any DRC
amortization base is considered to be
fully amortized in the first plan year
after establishment of such base for
which (1) the plan’s funded current
liability percentage (determined under
§ 412(l)(8)(B)) is 100 percent or
greater, (2) the plan is reestablished as
a multiemployer plan, or (3) the plan
has 100 or fewer participants within the
meaning of §412(l)(6). Similarly, un-
der the provisions of §412(l) as in
effect after amendment by RPA ’94,
any DRC amortization base (whether or
not created prior to the effective date
of RPA ’94) is considered to be fully
amortized for the first plan year after
establishment of such base for which
(1) the plan’s funded current liability
p e r c e n t a g e ( d e t e r m i n e d u n d e r
§ 412(l)(9)(C)) is 90 percent or greater,
(2) the plan is reestablished as a
multiemployer plan, or (3) the plan has
100 or fewer participants within the
meaning of §412(l)(6).
DRAFTING INFORMATION
The principal author of this revenue
ruling is Martin L. Pippins of the
Employee Plans Division. For further
information regarding this revenue rul-
ing, please contact the Employee Plans
Division’s taxpayer assistance tele-
phone service between 2:30 p.m. and
4:00 p.m. Eastern Time, Monday
through Thursday on (202) 622-6076
(Actuarial Hotline) (not a toll-free
telephone number). Mr. Pippins’ tele-
phone number is (202) 622-6261 (also
not a toll-free number).

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(Also see, §7805; 26 CFR 301.7805–1.)
Phase-in of increases in funding.
Questions and answers pertaining to the
election to phase in increases in addi-
tional funding requirements for certain
plans under section 412(l)(11) of the
Internal Revenue Code as amended by
the Uruguay Round Amendments Act,
which includes the Retirement Protec-
tion Act of 1994, are set forth.
Rev. Rul. 96–21
PURPOSE
This revenue ruling provides ques-
tions and answers relating to the
transition rule of §412(l)(11) of the
Internal Revenue Code, as amended by
the Retirement Protection Act of 1994
(RPA ’94), which is part of the
Uruguay Round Agreements Act, Pub.
L. 103–465 (GATT).
BACKGROUND
Section 412 of the Code imposes
minimum funding requirements with
respect to defined benefit and money
purchase pension plans. Section 412(l)
sets forth additional funding require-
ments for certain underfunded defined
benefit pension plans that have more
than 100 participants and that are not
multiemployer plans. The additional
funding requirements are in the form of
an additional funding charge under
§ 412(l)(1) and are generally based on
a plan’s unfunded current liability, as
defined in §412(l)(8).
RPA ’94 amended §412(l) to mod-
ify the additional funding charge in
order to produce faster funding of a
plan’s unfunded current liability. The
amendments increased the unfunded
new liability amount, changed the way
in which the additional charge was
integrated with the charges and credits
under §412(b), and further specified
the actuarial assumptions used to deter-
mine current liability for purposes of
§ 412(l). RPA ’94 also provided certain
transition rules to be used in determin-
ing the amount of the additional
funding charge.
Section 412(l)(11) of the Code
provides a temporary transition rule
that allows employers to phase in
increases in the additional funding
charge due to changes made by RPA
’94. This transition rule applies for
plan years beginning after December
31, 1994, and before January 1, 2002.
Section 412(l)(11) provides that, at the
election of the employer, the additional
funding charge computed for a plan
year under §412(l)(1) shall not exceed
the greater of (1) the additional funding
charge for the plan year that would
have been required under §412(l)(1),
as in effect prior to amendment by
RPA ’94, or (2) the amount that, after
taking into account charges (other than
the additional funding charge) and
credits under §412(b), is necessary to
increase the funded current liability
percentage of the plan for the plan year
to the sum of the initial funded current
liability percentage and the applicable
number of percentage points deter-
mined under §412(l)(11)(B).
QUESTIONS AND ANSWERS ON
THE ELECTION UNDER
§ 412(l)(11)
Q-1. What is the election under
§ 412(l)(11)?
A-1. Under §412(l)(11), an election
may be made to limit the additional
funding charge under §412(l)(1) for a
plan year. If the transition rule under
§ 412(l)(11) is elected for a plan year,
the additional funding charge under
§ 412(l)(1) for the plan year is equal to
the lesser of (1) the additional funding
charge for the plan year determined
without regard to §412(l)(11), or (2)
the greater of (A) the additional fund-
ing charge that would have been
required for the plan year under
§ 412(l)(1) as in effect prior to amend-
ment by RPA ’94, and (B) the addi-
tional amount necessary to increase the
funded current liability percentage of
the plan to the ‘‘target percentage’’ (as
defined in Q&A-6) for that plan year.
Q-2. For what plans may the election
under §412(l)(11) be made?
A-2. An election under §412(l)(11)
may be made for any ‘‘eligible plan.’’
For this purpose, an ‘‘eligible plan’’ is
any plan to which §412(l) applies for
the plan year beginning in 1995, or any
plan to which §412(l) does not apply
for the plan year beginning in 1995
solely by reason of the exception
provided under §412(l)(9)(B) (taking
into account the special rules of
§ 412(l)(9)(D)). The election under
§ 412(l)(11) may not be made for a
plan that is not an ‘‘eligible plan.’’
Q-3. For what plan years may an
election under §412(l)(11) be made for
an ‘‘eligible plan?’’
A-3. For an ‘‘eligible plan,’’ an
election under §412(l)(11) may be
made for any plan year beginning after
December 31, 1994, and before January
1, 2002, regardless of whether an
election under §412(l)(11) has been
made for any prior plan year. An
election made under §412(l)(11) for a
plan year is irrevocable for that plan
year.
Q-4. Who makes the election under
§ 412(l)(11), and must the election be
reported?
A-4. Any election under §412(l)(11)
is made by the employer maintaining
t h e p l a n . A n e l e c t i o n u n d e r
§ 412(l)(11) for a plan year is effective
only if the first Form 5500 filed for the
plan year reports that the election has
been made for the plan year, and the
Form 5500 is filed not later than the
due date, including extensions.
QUESTIONS AND ANSWERS ON
THE CALCULATIONS UNDER
§ 412(l)(11)
Q-5. For purposes of applying
§ 412(l)(11) to a plan year, how is the
additional amount necessary to increase
the funded current liability percentage
of the plan to the ‘‘target percentage’’
determined for that plan year?
A-5. For purposes of applying
§ 412(l)(11) to a plan year, the addi-
tional amount (the ‘‘target amount’’)
necessary to increase the funded cur-
rent liability percentage of a plan to the
‘‘target percentage’’ for that plan year
is the excess, if any, of the product of
the ‘‘target percentage’’ and the ‘‘ad-
justed current liability’’ of the plan,
over the ‘‘adjusted assets’’ of the plan.
Q-6. How is the ‘‘target percentage’’
determined for purposes of computing
the ‘‘target amount’’ for a plan year?
A-6. For purposes of computing the
‘‘target amount’’ for a plan year, the
‘‘target percentage’’ for the plan year
is the plan’s initial funded current
liability percentage, plus the applicable
number of percentage points computed
under §412(l)(11)(B) for the plan year.
The plan’s initial funded current
liability percentage is the funded cur-
rent liability percentage of the plan for
the plan year beginning in 1995. This
percentage is calculated as of the
valuation date for that plan year, and is
equal to the actuarial value of assets
divided by the current liability of the
plan computed under §412(l)(7). For
purposes of computing the initial

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funded current liability percentage, the
actuarial value of assets is reduced by
any credit balance in the plan’s funding
standard account as of the end of the
prior plan year, adjusted with interest
to the valuation date (using the valua-
tion interest rate). Also, for this pur-
pose, the current liability does not
include the expected increase in current
liability due to benefits accruing during
the plan year beginning in 1995.
Q-7. How is the ‘‘adjusted current
liability’’ determined for purposes of
computing the ‘‘target amount’’ for a
plan year?
A-7. For purposes of computing the
‘‘target amount’’ for a plan year, the
adjusted current liability is equal to the
excess of (1) the current liability of the
plan for the plan year, including the
expected increase in current liability
due to benefits accruing during the plan
year, computed under §412(l)(7), over
(2) the expected release from current
liability on account of disbursements
(including single sum distributions)
from the plan expected to be paid after
the valuation date but prior to the end
of the plan year. The components of
this calculation are determined as of
the valuation date, and each is appro-
priately adjusted with interest to the
end of the plan year using the interest
rate used to determine current liability
under §412(l)(7).
Q-8. How are the ‘‘adjusted assets’’
determined for purposes of computing
the ‘‘target amount’’ for a plan year?
A-8. For purposes of computing the
‘‘target amount’’ for a plan year, the
‘‘adjusted assets’’ are equal to the
actuarial value of assets for the plan
year adjusted by (1) subtracting any
credit balance (or adding any debit
balance) in the plan’s funding standard
account as of the end of the prior plan
year, adjusted with interest to the
valuation date at the valuation interest
rate, (2) subtracting the disbursements
from the plan (including single sum
distributions) expected to be paid after
the valuation date but prior to the end
of the plan year, (3) adding the charges
to the funding standard account as
maintained under §412(b) for the plan
year (other than the additional funding
charge under §412(l)), and (4) sub-
tracting the credits to the funding
standard account as maintained under
§ 412(b) for the plan year (other than
credits under §§ 412(b)(3)(A) and
412(b)(3)(C)). The actuarial value of
assets and the adjustments described
above are determined as of the valua-
tion date, and each is appropriately
adjusted with interest to the end of the
plan year at the valuation interest rate.
The result of this calculation may be a
negative number, which would increase
the ‘‘target amount’’.
Q-9. How is the additional funding
charge that would have been required
under §412(l)(1), as in effect prior to
amendment by RPA ’94, determined?
A-9. The determination of the addi-
tional funding charge that would have
been required under §412(l)(1), as in
effect prior to amendment by RPA ’94,
is the same as the determination of the
additional funding charge required un-
der 412(l)(1), as amended by RPA ’94,
with the following exceptions:
(1) If the current liability under
§ 412(l), as amended by RPA ’94, is
determined using an interest rate that is
the highest rate in the permissible
range under §412(l)(7)(C), the current
liability under §412(l) as in effect
prior to amendment by RPA ’94 is
determined using the interest rate used
for purposes of §412(c)(7)(A). In such
a case, the latter interest rate must be
the interest rate under §412(l)(7)(C) or
any higher rate permitted under
§ 412(b)(5)(B). On the other hand, if
the current liability under §412(l), as
amended by RPA ’94, is determined
using an interest rate that is less than
the highest interest rate in the permissi-
ble range under §412(l)(7)(C), the
current liability under §412(l) as in
effect prior to amendment by RPA ’94
(and the current liability for purposes
of the full funding limitation under
§ 412(c)(7)(A)) is determined using the
same interest rate used to determine
current liability under §412(l), as
amended by RPA ’94.
(2) The mortality table used to
determine current liability is the mor-
tality table used to determine costs and
liabilities under the plan in accordance
with §412(c)(3).
(3) In determining the additional
funding charge, the deficit reduction
c o n t r i b u t i o n i s o f f s e t u n d e r
§ 412(l)(1)(A)(ii) solely by amortiza-
tion charges under § 412(b)(2)(B)
(other than clauses (iv) and (v) thereof)
and §412(b)(2)(C) and (D), reduced by
t h e s u m o f c r e d i t s u n d e r
§ 412(b)(3)(B)(i).
(4) The amount of the additional
funding charge is limited to the un-
funded current liability, rather than the
amount that, after taking into account
charges (other than the additional fund-
ing charge) and credits under §412(b),
is necessary to increase the funded
current liability percentage (taking into
account the expected increase in cur-
rent liability due to benefits accruing
during the plan year) of the plan to 100
percent.
(5) The deficit reduction contribution
under §412(l)(2) does not include the
expected increase in current liability
due to benefits accruing during the plan
year and the aggregate of the unfunded
mortality increase amounts.
(6) The unfunded old liability
amount under §412(l)(3) is determined
without including any amortization of
additional unfunded old liability under
§ 412(l)(3)(D) or (E).
(7) The applicable percentage under
§ 412(l)(4)(C) for computing the un-
funded new liability amount is equal to
30 percent reduced by the product of
.25 multiplied by the number of per-
centage points by which the funded
current liability percentage exceeds 35
percent.
(8) The unfunded new liability under
§ 412(l)(4)(B) is determined by sub-
tracting from the unfunded current
liability of the plan the unamortized
portion of the unfunded old liability,
the unamortized portion of the un-
funded existing benefit increase lia-
bility, and the liability with respect to
any unpredictable contingent event ben-
efits (without regard to whether the
event has occurred).
(9) In determining the deficit reduc-
tion contribution, any unfunded old
liability base or unfunded existing
benefit increase liability base continues
to be amortized for the duration of the
original amortization period, or until an
earlier time determined under Q&A-7
of Rev. Rul. 96–20 (as those rules
would be applied under §412(l) as in
effect prior to amendment by RPA
’94).
(10) The unpredictable contingent
event amount under §412(l)(5) is
d e t e r m i n e d w i t h o u t r e g a r d t o
§ 412(l)(5)(A)(iii) and §412(l)(5)(E).
( 1 1 ) S e c t i o n s 4 1 2 ( l ) ( 9 ) a n d
412(l)(11), as added by RPA ’94, are
not taken into account.
In addition, for purposes of computing
the additional funding charge that
would have been required under
§ 412(l)(1), as in effect prior to RPA
’94, the credit balance used should be
the actual credit balance of the plan for
the plan year.

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Q-10. How is the target amount computed given the following fact pattern?
General facts:
The employer elects the transition rule under §412(l)(11) for the 1995 plan year. The plan year is the calendar year, and
the valuation date is January 1, 1995. The valuation interest rate is 8.5 percent and the §412(l)(7)(C) interest rate is 7.93
percent.
The valuation results are as follows:
RPA ’94 current liability$1,000,000
Expected increase in current liability due to benefits accruing during the plan year$70,000
Actuarial value of assets$720,000
Prior year credit balance$20,000
Expected disbursements (expected to be paid on 12/31/95)$50,000
Expected release from current liability as a result of expected disbursements (valued as of
1/1/95)
$40,000
§ 412(b) charges (other than the additional funding charge), including interest to 12/31/95$100,000
§ 412(b) credits, including interest to 12/31/95$75,000
A-10. The ‘‘target amount’’ is the
excess, if any, of the product of the
‘‘target percentage’’ and the ‘‘adjusted
current liability’’, over the ‘‘adjusted
assets’’.
The ‘‘target percentage’’ for the plan
is the plan’s ‘‘initial funded current
liability percentage’’ plus the applica-
ble number of percentage points under
§ 412(l)(11)(B). The plan’s ‘‘initial
funded current liability percentage’’ is
equal to the actuarial value of assets
(reduced by the prior year credit
balance), divided by the plan’s current
liability as of the valuation date. Thus,
the plan’s ‘‘initial funded current lia-
bility percentage’’ is 70 percent
($720,000 minus $20,000, divided by
$1,000,000), and the ‘‘target percent-
age’’ is 73 percent (70 percent plus 3
percent, the applicable number of per-
centage points under §412(l)(11)(B)).
The ‘‘adjusted current liability’’ of
the plan is equal to the excess of
$1,070,000 (the sum of $1,000,000 and
$70,000) over $40,000, each adjusted
with interest to the end of the plan year
at the §412(l)(7)(C) interest rate. The
$1,070,000 is adjusted with a full
year’s interest ($1,070,000 times
1.0793, or $1,154,851) and the $40,000
is adjusted with a full year’s interest at
the same rate ($40,000 times 1.0793, or
$43,172). The resulting ‘‘adjusted cur-
r e n t l i a b i l i t y ’ ’ i s $ 1 , 1 1 1 , 6 7 9
($1,154,851 minus $43,172).
The ‘‘adjusted assets’’ of the plan
are equal to $720,000 minus $20,000,
minus $50,000, plus $100,000, minus
$75,000, each adjusted with interest
from the appropriate date to the end of
the plan year at the valuation interest
rate. The $720,000 and $20,000 as
adjusted with a full year’s interest at
the valuation interest rate equals
$759,500 ($720,000 minus $20,000,
times 1.085). The $50,000 receives no
interest adjustment, as benefit payments
are expected to be paid at the end of
the year. The charges and credits
already are calculated with interest to
the end of the year. The resulting
‘ ‘ a d j u s t e d a s s e t s ’ ’ i s $ 7 3 4 , 5 0 0
($759,500, minus $50,000, plus
$100,000, minus $75,000).
The ‘‘target amount’’ is equal to the
excess of the product of 73 percent (the
‘‘target percentage’’) and $1,111,679
(the ‘‘adjusted current liability’’), over
$734,500 (the ‘‘adjusted assets’’), or
$77,026.
APPLICATION OF §7805(b)
Pursuant to §7805(b), this revenue
ruling shall not be applied for purposes
of determining the amount of any
required installment under §412(m)(4),
if the due date for that required
installment is on or before April 15,
1996.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Martin L. Pippins of the
Employee Plans Division. For further
information regarding this revenue rul-
ing, please contact the Employee Plans
Division’s taxpayer assistance tele-
phone service between 2:30 p.m. and
4:00 p.m. Eastern Time, Monday
through Thursday on (202) 622-6076
(Actuarial Hotline) (not a toll-free
telephone number). Mr. Pippins’ tele-
phone number is (202) 622-6261 (also
not a toll-free number).
§ 472.—Last-in, First-out Inventories
26 CFR 1.472–1: Last-in, first-out inventories.
LIFO; price indexes; department
stores. The February 1996 Bureau of
Labor Statistics price indexes are ac-
cepted for use by department stores
employing the retail inventory and last-
in, first-out inventory methods for
valuing inventories for tax years ended
on, or with reference to, February 29,
1996.
Rev. Rul. 96–22
The following Department Store In-
ventory Price Indexes for February
1996 were issued by the Bureau of
Labor Statistics on March 15, 1996.
The indexes are accepted by the
Internal Revenue Service, under
§ 1.472–1(k) of the Income Tax Reg-
ulations and Rev. Proc. 86–46, 1986–2
C.B. 739, for appropriate application to
inventories of department stores
employing the retail inventory and last-
in, first-out inventory methods for tax
years ended on, or with reference to,
February 29, 1996.

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The Department Store Inventory
Price Indexes are prepared on a na-
tional basis and include (a) 23 major
groups of departments, (b) three special
combinations of the major groups —
soft goods, durable goods, and mis-
cellaneous goods, and (c) a store total,
which covers all departments, including
some not listed separately, except for
the following: candy, foods, liquor,
tobacco, and contract departments.
BUREAU OF LABOR STATISTICS, DEPARTMENT STORE
INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS
(February 1941 = 100, unless otherwise noted)
GroupsFeb. 1995Feb. 1996
Percent Change from
Feb. 1995 to Feb.
1996
1
1.Piece Goods....................................480.0505.15.2
2.Domestics and Draperies.........................645.9651.20.8
3.Women’s and Children’s Shoes...................633.8644.51.7
4.Men’s Shoes....................................925.5895.1–3.3
5.Infants’ Wear...................................617.3645.34.5
6.Women’s Underwear.............................518.2522.30.8
7.Women’s Hosiery...............................283.0289.32.2
8.Women’s and Girls’ Accessories..................542.0552.31.9
9.Women’s Outerwear and Girls’ Wear..............413.0402.0–2.7
10.Men’s Clothing.................................602.4619.52.8
11.Men’s Furnishings...............................560.5570.81.8
12.Boys’ Clothing and Furnishings...................488.9476.6–2.5
13.Jewelry........................................995.51003.40.8
14.Notions........................................750.7813.78.4
15.Toilet Articles and Drugs........................839.3871.03.8
16.Furniture and Bedding...........................654.9666.91.8
17.Floor Coverings.................................579.6563.4–2.8
18.Housewares.....................................771.1799.73.7
19.Major Appliances................................246.4249.21.1
20.Radio and Television............................85.679.0–7.7
21.Recreation and Education
2
........................114.7113.6–1.0
22.Home Improvements
2
............................121.3123.11.5
23.Auto Accessories
2
...............................107.0107.30.3
Groups 1—15: Soft Goods...........................586.4590.00.6
Groups 16—20: Durable Goods.......................465.1467.30.5
Groups 21—23: Misc. Goods
2
........................114.3113.8–0.4
Store Total
3
..................................545.8548.30.5
1
Absence of a minus sign before percentage change in this column signifies price increase.
2
Indexes on a January 1986=100 base.
3
The store total index covers all departments, including some not listed separately, except for the following: candy, foods,
liquor, tobacco, and contract departments.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Stan Michaels of the Office of
Assistant Chief Counsel (Income Tax
and Accounting). For further informa-
tion regarding this revenue ruling,
contact Mr. Michaels on (202)
622-4970 (not a toll-free call).
Section 2032A.—Valuation of Certain
Farm, Etc., Real Property
26 CFR 20.2032A–4: Method of valuing farm
real property.
Special use value; farms; interest
rates. The 1996 interest rates to be
used in computing the special use value
of farm real property for which an
election is made under section 2032A
of the Code are listed for estates of
decedents.

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Rev. Rul. 96–23
This revenue ruling contains a list of
the average annual effective interest
rates on new loans under the Farm
Credit Bank system. This revenue
ruling also contains a list of the states
within each Farm Credit Bank District.
Under §2032A(e)(7)(A)(ii) of the
Internal Revenue Code, rates on new
Farm Credit Bank loans are used
in computing the special use value of
real property used as a farm for which
an election is made under §2032A.
The rates in this revenue ruling may be
used by estates that value farmland
under §2032A as of a date in 1996.
Average annual effective interest
rates, calculated in accordance with
§ 2032A(e)(7)(A) and §20.2032A–4(e)
of the Estate Tax Regulations, to be
used under §2032A(e)(7)(A)(ii), are
set forth in the accompanying Table of
Interest Rates (Table 1). The states
within each Farm Credit Bank District
are set forth in the accompanying Table
of Farm Credit Bank Districts (Table
2).
Rev. Rul. 81–170, 1981–1 C.B. 454,
contains an illustrative computation of
an average annual effective interest
rate. The rates applicable for valuation
in 1995 are in Rev. Rul. 95–38, 1995–1
C.B. 184. For rate information for
years prior to 1995, see Rev. Rul. 94–
33, 1994–1 C.B. 235, and other reve-
nue rulings that are cited therein.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Lane Damazo of the Office of
Assistant Chief Counsel (Passthroughs
and Special Industries). For further
information regarding this revenue rul-
ing, contact Lane Damazo on (202)
622-3090 (not a toll-free call).
REV. RUL. 96–23 TABLE 1
TABLE OF INTEREST RATES
(Year of Valuation 1996)
Farm Credit Bank District in Which Property Is Located
Interest
Rate
Columbia.............................................................................8.98
Omaha...............................................................................8.38
Sacramento...........................................................................9.28
St. Paul..............................................................................8.73
Spokane..............................................................................8.48
Springfield............................................................................8.59
Texas................................................................................8.86
Wichita...............................................................................8.44
REV. RUL. 96–23 TABLE 2
TABLE OF FARM CREDIT BANK DISTRICTS
DistrictStates
Columbia....................Delaware, District of Columbia, Florida, Georgia, Maryland, North
Carolina, Pennsylvania, South Carolina, Virginia, West Virginia.
Omaha......................Iowa, Nebraska, South Dakota, Wyoming.
Sacramento..................Arizona, California, Hawaii, Nevada, Utah.
St. Paul.....................Arkansas, Illinois, Indiana, Kentucky, Michigan, Minnesota, Missouri,
North Dakota, Ohio, Tennessee, Wisconsin.
Spokane.....................Alaska, Idaho, Montana, Oregon, Washington.
Springfield...................Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New
York, Rhode Island, Vermont.
Texas.......................Alabama, Louisiana, Mississippi, Texas.
Wichita......................Colorado, Kansas, New Mexico, Oklahoma.
Sec. 7805.—Rules And Regulations
26 CFR 301.7805–1: Rules and regulations.
Whether §7805 of the Code will be applied
for purposes of determining the amount of any
required installment under §412(m)(4) that is
due on or before April 15, 1996. See Rev. Rul.
96–21, page 7.

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Part III.Administrative, Procedural, and Miscellaneous
General Rules and Specifications for
Private Printing of Form W-2, Wage
and Tax Statement and Form W-3,
Transmittal of Wage and Tax
Statements
Rev. Proc. 96–24A
This revenue procedure modifies and
amplifies Part A, Sections 2.03 and
2.07, Part B, Section 1.10 and 2.02,
and Part C, Section 1.02, of Revenue
Procedure 96–24, 1996–5 I.R.B. 5,
which provides the General Rules and
Specifications for Private Printing of
Form W-2, Wage and Tax Statement,
and Form W-3, Transmittal of Wage
and Tax Statements. The requirement
to place a barcode on copies B, C, 1,
and 2 of Form W-2, as stated in Part
A, Section 2.03, and Part B, Section
2.02, has been repealed for Tax Year
1996. However, this requirement may
be reinstated for Tax Year 1997.
In addition, the term OCRA Font
found throughout the text, has been
changed to OCR–A Font. The term
OCR–A Font was excluded from Part
A, Section 2.07, and Part C, Section
1.02. The revised language reads as
follows: The tax year must be printed
in black ink on Form W-3. The tax
year must also be printed in black ink
using OCR–A Font, only on Form
W-2, Copy A (See Exhibit A). The
form number and title must be printed
in red OCR drop-out ink on Form W-2,
Copy A, and Form W-3.
Also, the language in Part B, Section
1.10 has been revised because the
Social Security Administration’s ad-
dress was removed from the first page
of Form W-3. The revised language
reads as follows: The section ‘‘Where
to File’’ in the general instructions on
the employer’s copy of the official
Form W-3 must be printed in its
entirety on all substitute Forms W-3
(See Exhibit B).
EFFECT ON OTHER DOCUMENTS
Rev. Proc. 96–24 is modified and
amplified.

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151996–27 I.R.B.
Part IV. Items of General Interest
Guidance Issued for Computation of
Additional Funding Requirements
under §412(l) of the Internal
Revenue Code
Announcement 96–18
The Internal Revenue Service has
issued Rev. Rul. 96–20 and Rev. Rul.
96–21, to provide guidance on the
additional funding requirements under
§ 412(l) of the Internal Revenue Code,
as amended by the Retirement Protec-
tion Act of 1994 (RPA ’94). Section
412(l) provides additional funding re-
quirements for certain underfunded de-
fined benefit plans that have more than
100 participants and that are not
multiemployer plans.
Rev. Rul. 96–20 provides guidance
on the requirements for the establish-
ment and maintenance of certain amor-
tization bases under §412(l). The
guidance is needed, in part, because the
amortization base for additional un-
funded old liability is scheduled to be
established for the 1995 plan year. If
the optional rule under §412(l)(3)(E) is
used to determine the additional un-
funded old liability, an employer must
make an election which is reported on
a timely filed 1995 Form 5500 (see line
20a on Form 5500).
Rev. Rul. 96–21 provides guidance
for employers who desire to make
elections in certain years under
§ 412(l)(11) to phase in the increase in
the additional funding requirement un-
d e r R P A ’ 9 4 . E l e c t i o n s u n d e r
§ 412(l)(11) are made on line 20b of
the 1995 Form 5500.
Recently, the Service released the
1995 Forms 5500 and accompanying
instructions, including the 1995 Sched-
ule B (Actuarial Information). Instruc-
tions for several lines on the Schedule
B were reserved pending published
guidance. The guidance in Rev. Rul.
96–21 is used to complete line 14 of
the 1995 Schedule B. The ‘‘target
amount’’ computed under Q&A-5 of
Rev. Rul. 96–21 is entered on line 14d
of the 1995 Schedule B.
The amount in line 12o of the 1995
Schedule B (the contributions needed
to increase the funded current liability
percentage of the plan to 100 percent
under §412(l)(1)) is calculated in the
same manner as the ‘‘target amount’’,
except that 100 percent is substituted
for the ‘‘target percentage’’ (as defined
in Q&A-6 of Rev. Rul. 96–21).
Guidance relating to the calculations
of the amounts reported on lines 91(1),
91(2), and 91(3) of the 1995 Schedule
B is expected to be provided in
separate published guidance that is not
anticipated to apply to plan years
beginning in 1995.
COMMENTS REQUESTED
Public comments may be submitted
concerning issues arising under
§ 412(l), including issues related to the
topics addressed in these revenue rul-
ings. Comments should be sent to the
following address:
Internal Revenue Service
1111 Constitution Avenue, N.W.
Washington, DC 20224
Attn: CP:E:EP
DRAFTING INFORMATION
The principal author of this an-
nouncement is Martin L. Pippins of the
Employee Plans Division. For further
information regarding this announce-
ment, please contact the Employee
Plans Division’s taxpayer assistance
telephone service between 2:30 p.m.
and 4:00 p.m. Eastern Time, Monday
through Thursday on (202) 622-6076
(Actuarial Hotline) (not a toll-free
telephone number). Mr. Pippins’ tele-
phone number is (202) 622-6261 (also
not a toll-free number).
Withholding on Distributions of
Indian Gaming Profits to Tribal
Members; Correction
Announcement 96–19
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
8634 [1996–3 I.R.B. 17]] which were
published in the Federal Register for
Tuesday, December 19, 1995 (60 FR
65237). The final regulations relate to
the income tax withholding requirement
on distributions of profits from certain
gaming activities made to members of
Indian tribes.
EFFECTIVE DATE: December 19,
1995.
FOR FURTHER INFORMATION
CONTACT: Rebecca Wilson (202)
622-6040 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations that are the
subject to this correction are under
section 3402 of the Internal Revenue
Code.
Need for Correction
As published, TD 8634 contains an
error that is in need of clarification.
Correction of Publication
Accordingly, the publication of final
regulations which are the subject of FR
Doc. 95–30683, is corrected as follows:
On page 65237, column one, in the
heading, the ‘‘RIN’’ ‘‘1545–AT12’’ is
corrected to read ‘‘1545–AT11’’.
Cynthia E. Grigsby,
Chief, Regulations Unit, Assistant Chief
Counsel (Corporate).
(Filed by the Office of the Federal Register on
March 8, 1996, 8:45 a.m., and published in the
issue of the Federal Register for March 11,
1996, 61 F.R. 9639)
Notice, Consent, and Election
Requirements Under Sections
411(a)(11) and 417; Correction
Announcement 96–20
AGENCY: Internal Revenue Service,
Treasury.
ACTION: Correction to notice of pro-
posed rulemaking by cross-reference to
temporary regulations.
SUMMARY: This document contains a
correction to proposed regulations by

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cross-reference to temporary regula-
tions which were published in the
Federal Register for Friday, September
22, 1995 (60 FR 49236 [EE–24–93
1995–41 I.R.B. 33]). The proposed
regulations provide guidance concern-
ing the notice and consent requirements
under section 411(a)(11) and the notice
and election requirements of section
417.
FOR FURTHER INFORMATION
CONTACT: Thomas Foley, (202)
622-6050 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The notice of proposed rulemaking
by cross-reference to temporary regula-
tions that is the subject of this correc-
tion is under sections 411 and 417 of
the Internal Revenue Code.
Need for Correction
As published, the notice of proposed
rulemaking by cross-reference to tem-
porary regulations contains an error
that is in need of correction.
Correction of Publication
Accordingly, the publication of the
notice of proposed rulemaking by
cross-reference to temporary regula-
tions which is the subject of FR Doc.
95–23264, is corrected as follows:
On page 49236, in the heading, the
‘‘RIN’’ ‘‘1545–AT75’’ is corrected to
read ‘‘1545–AU05’’.
Cynthia E. Grigsby,
Chief, Regulations Unit Assistant Chief
Counsel (Corporate).
(Filed by the Office of the Federal Register on
March 8, 1996, 8:45 a.m., and published in the
issue of the Federal Register for March 11,
1996, 61 F.R. 9660)
Notice, Consent, and Election
Requirements Under Sections
411(a)(11) and 417; Hearing
Announcement 96–22
AGENCY: Internal Revenue Service,
Treasury.
ACTION: Notice of public hearing on
proposed rulemaking.
SUMMARY: This document provides
notice of a public hearing on proposed
Income Tax Regulations that provide
guidance concerning the notice and
consent requirements under section
411(a)(11) and the notice and election
requirements of section 417.
DATE: The public hearing will be held
Wednesday, April 24, 1996, beginning
at 10:00 a.m. Requests to speak and
outlines of oral comments must be
received by Wednesday, April 3, 1996.
ADDRESSES: The public hearing will
be held in the Commissioner’s Con-
ference Room, third floor, Room 3313,
Internal Revenue Building, 1111 Con-
stitution 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–24–93], room
5228, Washington, DC 20044.
FOR FURTHER INFORMATION
CONTACT: Christina Vasquez of the
Regulations Unit, Assistant Chief
Counsel (Corporate), (202) 622-6803
(not a toll-free number).
SUPPLEMENTARY INFORMATION:
The subject of the public hearing is
proposed amendments to the Income
Tax Regulations under sections 411
and 417 of the Internal Revenue Code
of 1986. The proposed regulations
appeared in the Federal Register for
Friday, September 22, 1995 (60 FR
49236).
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
within 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 Wednes-
day, April 3, 1996, an outline of the
oral comments/testimony to be pre-
sented 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 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
March 8, 1996, 8:45 a.m., and published in the
issue of the Federal Register for March 11,
1996, 61 F.R. 9659)
Foundations Status of Certain
Organizations
Announcement 96–21
The following organizations have
failed to establish or have been unable
to maintain their status as public
charities or as operating foundations.
Accordingly, grantors and contributors
may not, after this date, rely on
previous rulings or designations in the
Cumulative List of Organizations (Pub-
lication 78), or on the presumption
arising from the filing of notices under
section 508(b) of the Code. This listing
does not indicate that the organizations
have lost their status as organizations
described in section 501(c)(3), eligible
to receive deductible contributions.
Former Public Charities. The fol-
lowing 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:
Alliance For The Mentally Ill In
Ruston Louisiana Inc., Ruston, LA
Art League Of Bonita Springs Inc.,
Bonita Springs, FL
Beating The Odds Development
Corp., Greenville, MS
Brevard Heritage Council Inc.,
Indiatlantic, FL
Broward Independent Living Center
Inc., Fort Lauderdale, FL
Caddo Bossier Council For Self
Esteem, Shreveport, LA
Cenla Alcohol And Drug Abuse
Advisory Council, Pineville, LA
Choral Parents Association Of Nova
High School, Davie, FL

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Citizens For A Barrier Free Community
Inc., Port St Lucie, FL
Clemson University Tiger Band Assoc.,
Clemson, SC
Clinton Education Foundation For
Excellence Inc., Clinton, MS
Creative Learning Day Care Center,
Kentwood, LA
Creative Legal Solutions Inc., Miami
Beach, FL
Depression Initiative Inc., Wilson,
Wyoming
Dreher High School Athletic Booster
Club, Columbia, SC
East Cooper Community Theatre Inc.,
Isle Of Palms, SC
Ebony City Soccer Club And Youth
Development Program, Charleston,
SC
Florida Blueberry Festival And County
Fair Inc., Ocala, FL
Foster Angels Of Broward Inc.,
Hollywood, FL
Friends Alliance Housing Inc., New
Orleans, LA
Friends Of Bet Shira Congregation
Inc., Miami, FL
Friends Of The Pasco County Library
System Inc., Hudson, FL
Great Falls Economic Development
Commission Inc., Great Falls, SC
Green Bridge Fan Club Inc., Palmetto,
FL
Greenwood Youth Foundation Inc.,
Schlater, MS
Grimke Center, N Charleston, SC
Improvisational Composers Network
Inc., Miami, FL
Independent Educational Media Inc.,
Winter Park, FL
Irmo High School Academic Quiz
Team Booster Club, Columbia, SC
Johnny Tanner Foundation, Spartan-
burg, SC
Lake City Concert Series, Lake City,
SC
League, Inc., Longwood, FL
Lealman Avenue Elementary School
PTO, St Petersburg, FL
Little Star Helping Hands Inc., Sumter,
SC
Louisiana Bangladesh Society, New
Orleans, LA
Louisiana Sinfonietta Inc., Baton
Rouge, LA
Moultrie District Two Band Booster
Club, Mount Pleasant, SC
Mt Olive Family Training And
Counseling Center Corp., Slidell, LA
New Smyrna Beach High School Band
Parents Assoc., New Smyrna Beach,
FL
North Baton Rouge Tutorial Program
Inc., Baton Rouge, LA
NWR Cougar Booster Club Inc.,
Brandon, MS
Opera Charleston Inc., Charleston, SC
Plaquemines Council On Aging, Port
Sulphur, LA
Raiz Inc., Miami, FL
Renes Day Care And Preschool Inc.,
New Orleans, LA
R i v e r f r o n t F l o o d w a l l C o r r i d o r
Committee Inc., New Orleans, LA
Senior And Junior Services Inc., New
Orleans, LA
Service Through Economic Progress,
Pascagoula, MS
Singg Inc., Columbia, SC
Theophilus Community Living Corp.,
New Orleans, LA
Vineyards Elementary School Parent
Teacher Organization Inc., Naples,
FL
Wright For The Riverwalk Inc., Ft
Lauderdale, FL
If an organization listed above sub-
mits information that warrants the
renewal of its classification as a public
charity or as a private operating foun-
dation, the Internal Revenue Service
will issue a ruling or determination
letter with the revised classification as
to foundation status. Grantors and
contributors may thereafter rely upon
such ruling 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 classification of founda-
tion status in the Internal Revenue
Bulletin.

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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
Miller, Gorden A.Mineral Wells, WVCPAFebruary 1, 1996 to April 30, 1996
Barnes, Charles E.Louisville, KYEnrolled
Agent
Indefinite from February 1, 1996
Polizzi, Angelo J.Grosse Point, MIAttorneyIndefinite from February 6, 1996
Pegler, Charles R.Islandia, NYCPAIndefinite from February 7, 1996
Foster, David M.Birmingham, MIAttorneyIndefinite from February 9, 1996
Smith, Jerry A.Evansville, INCPAFebruary 9, 1996 to November 8, 1996
Penn, Michael J.Dearborn, MICPAFebruary 9, 1996 to February 8, 1997
Mueller, E. LairdSeal Beach, CACPAFebruary 12, 1996 to June 11, 1996
Zezima, Paul P.Norwalk, CTCPAApril 1, 1996 to May 31, 1996
Van Houten, Robert R.Danbury, CTCPAMay 1, 1996 to April 30, 1997
Under Section 330, Title 31 of the
United States Code, the Secretary of
the Treasury, after due notice and
opportunity for hearing, is authorized
to suspend or disbar from practice
before the Internal Revenue Service
any person who has violated the rules
and regulations governing the recogni-
tion of attorneys, certified public ac-
countants, enrolled agents or enrolled
actuaries to practice before the Internal
Revenue Service.
Attorneys, certified public account-
ants, enrolled agents, and enrolled
actuaries 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 under suspension from
practice before the Internal Revenue
Service.
To enable attorneys, certified public
accountants, enrolled agents and
enrolled actuaries to identify such
disbarred or suspended practitioners,
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 the date
of disbarment or period of suspension.
This announcement will appear in the
weekly Bulletin for five successive
weeks or as long as it is practicable for
each attorney, certified public account-
ant, enrolled agent or enrolled actuary
so suspended or disbarred and will be
consolidated and published in the
Cumulative Bulletin.
After due notice and opportunity
for hearing before an administrative
law judge, the following individuals
have been disbarred from further prac-
tice before the Internal Revenue
Service:

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NameAddressDesignationEffective Date
Gimbel, StephenColumbia, SCCPAJanuary 20, 1996
Tropsa, Donna C.Stamford, CTAttorneyJanuary 20, 1996
Seifert, Frank J.Birmingham, ALCPAJanuary 20, 1996
Hansen, Joe B.Lubbock, TXCPAMarch 2, 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:
NameAddressDesignationDate of Suspension
Ginsberg, Melvin R.Univ. Heights, OHAttorneyIndefinite from January 24, 1996
Lahey, Charles W.South Bend, INAttorneyIndefinite from January 24, 1996
DePiano, RobertVenice, CAAttorneyIndefinite from January 24, 1996
Kraig, Jerry B.Shaker Hgts, OHAttorneyIndefinite from January 29, 1996
Brown, David M.Los Angeles, CAAttorneyIndefinite from January 29, 1996
Hanke Jr., Dale L.Duluth, MNAttorneyIndefinite from February 1, 1996
Guillory, Patrick R.San Francisco, CAAttorneyIndefinite from February 1, 1996
Miller, Brian R.Grove, OKCPAIndefinite from February 23, 1996
McLeod, Timothy R.Saginaw, MIAttorneyIndefinite from February 26, 1996
Simone, Robert F.Philadelphia, PAAttorneyIndefinite from February 26, 1996
Bowen, David LeeFrisco City, ALCPAIndefinite from February 27, 1996
Lindley, ClarksonWayazata, MNAttorneyIndefinite from February 27, 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 1996–14
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, 1996–11 I.R.B. 4
96–17, 1996–13 I.R.B. 5
96–18, 1996–13 I.R.B. 4
Delegations Orders:
232 (Rev. 2), 1996–7 I.R.B. 49
239 (Rev. 1), 1996–7 I.R.B. 49
Notices:
96–2, 1996–2 I.R.B. 15
96–1, 1996–3 I.R.B. 30
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
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
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.
Proposed Regulations—Continued
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
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
PS–2–95, 1996–7 I.R.B. 50
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
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
96–25, 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
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
Revenue Rulings—Continued
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
Treasury Decisions:
8630, 1996–3 I.R.B. 19
8631, 1996–3 I.R.B. 7
8632, 1996–4 I.R.B. 6
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

SEQ 0022 JOB C48-053-006 PAGE-0022 NEW FINDING LIST
REVISED 30JUN96 AT 22:15 BY LR DEPTH: 65.01 PICAS WIDTH 41.11 PICAS
COMPOSITE COLOR
778/20054/30JUN96/C48-053
22
Finding List of Current Action on
Previously Published Items
1
Bulletins 1996–1 through 1996–14
*Denotes entry since last publication
Delegation Orders:
232 (Rev. 1)
Superseded by
232 (Rev. 2), 1996–7 I.R.B. 49
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
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
94–18
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
94–77
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
95–7
Superseded by
96–7, 1996–1 I.R.B. 185
95–8
Superseded by
96–8, 1996–1 I.R.B. 187
Revenue Procedures—Continued
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
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

SEQ 0023 JOB C48-053-006 PAGE-0023 NEW FINDING LIST
REVISED 30JUN96 AT 22:15 BY LR DEPTH: 65.01 PICAS WIDTH 32.10 PICAS
COMPOSITE COLOR
778/20054/30JUN96/C48-053
23
NOTES

SEQ 0024 JOB C48-053-006 PAGE-0024 NEW FINDING LIST
REVISED 30JUN96 AT 22:15 BY LR DEPTH: 65.01 PICAS WIDTH 32.10 PICAS
COMPOSITE COLOR
778/20054/30JUN96/C48-053
24
NOTES

SEQ 0025 JOB C48-053-006 PAGE-0025 NEW FINDING LIST
REVISED 30JUN96 AT 22:15 BY LR DEPTH: 65.01 PICAS WIDTH 32.10 PICAS
COMPOSITE COLOR
778/20054/30JUN96/C48-053
25
NOTES