Internal Revenue Bulletin 1997-49 (PDF rendition): IRS Revenue Rulings

Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.

INCOME TAX
Rev. Rul. 97–48, page 5.
This ruling revokes Rev. Rul 75–7, 1975–1 C.B. 244, and
holds that the activities of a contract manufacturer cannot
be attributed to a controlled foreign corporation for pur-
poses of either section 954(d)(1) or section 954(d)(2) of the
Code to determine whether the income of a controlled for-
eign corporation is foreign base company sales income. The
ruling, however, provides section 7805(b) relief for taxable
years of a controlled foreign corporation beginning before
December 8, 1997. Rev. Rul. 75–7 revoked.
Rev. Rul. 97–50, page 5.
Federal rates; adjusted federal rates; adjusted federal
long-term rate, and the long-term exempt rate.For
purposes of sections 1274, 1288, 382, and other sections
of the Code, tables set forth the rates for December 1997.
Rev. Rul. 97–51, page 4.
Loan to community development corporation is eligi-
ble for general business credit. The full amount of the
loan made to a community development corporation (CDC)
is a “transfer of cash” to the CDC for purposes of the defini-
tion of a “qualified CDC contribution.”
EXEMPT ORGANIZATIONS
Announcement 97–117, page 12.
A list is provided of organizations now classified as private
foundations.
Announcement 97–118, page 13.
A list is provided of organizations that no longer qualify as
organizations for which contributions are deductible under
section 170 of the Code.
ADMINISTRATIVE
Notice 97–62, page 8.
This notice provides up to a 90-day extension of time to per-
form any act described in section 7508(a)(1) of the Code for
taxpayers located in Grand Forks County, North Dakota, and
Polk County, Minnesota, including filing and paying federal
income tax.
Notice 97–70, page 9.
This notice modifies Notice 97–9, 1997–2 I.R.B. 35, to
incorporate the amendment made to adoption credit rules
regarding the year(s) in which the credit for certain qualified
adoption expenses is allowed.
Notice 97–71, page 9.
This notice provides tables which show the amount of an indi-
vidual’s income that is exempt from a notice of levy used to
collect delinquent tax in 1998.
Internal Revenue
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Bulletin No. 1997–49
December 8, 1997
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
Department of the Treasury
Internal Revenue Service
Finding Lists begin on page 15.
Announcement of Declaratory Judgement Proceedings Under Section 7428 begins on page 13.

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 prod-
ucts and services; and perform in a manner warranting
the highest degree of public confidence in our integrity, effi-
ciency, and fairness.
2
Statement of Principles
of Internal Revenue
Tax Administration
The function of the Internal Revenue Service is to adminis-
ter 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 provi-
sions 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 “protect-
ing the revenue.” The revenue is properly protected only
when we ascertain 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 hesi-
tate 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, howev-
er, be vigorous in requiring compliance with law and it
should be relentless in its attack on unreal tax devices and
fraud.

The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing offi-
cial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
general interest. It is published weekly and may be obtained
from the Superintendent of Documents on a subscription
basis. Bulletin contents of a permanent nature are consoli-
dated semiannually into Cumulative Bulletins, which are sold
on a single-copy basis.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of in-
ternal management are not published; however, statements
of internal practices and procedures that affect the rights
and duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the
revenue ruling. In those based on positions taken in rulings
to taxpayers or technical advice to Service field offices,
identifying details and information of a confidential nature
are deleted to prevent unwarranted invasions of privacy and
to comply with statutory requirements.
Rulings and procedures reported in the Bulletin do not have
the force and effect of Treasury Department Regulations,
but they may be used as precedents. Unpublished rulings
will not be relied on, used, or cited as precedents by Service
personnel in the disposition of other cases. In applying pub-
lished rulings and procedures, the effect of subsequent leg-
islation, regulations, court decisions, rulings, and proce-
dures must be considered, and Service personnel and oth-
ers concerned are cautioned against reaching the same con-
clusions in other cases unless the facts and circumstances
are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal Revenue Code of 1986.
Part 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 Sub-
parts. Also included in this part are Bank Secrecy Act Admin-
istrative Rulings. Bank Secrecy Act Administrative Rulings
are issued by the Department of the Treasury’s Office of the
Assistant Secretary (Enforcement).
Part IV.—Items of General Interest.
With the exception of the Notice of Proposed Rulemaking
and the disbarment and suspension list included in this part,
none of these announcements are consolidated in the Cumu-
lative Bulletins.
The first Bulletin for each month includes a cumulative index
for the matters published during the preceding months.
These monthly indexes are cumulated on a quarterly and
semiannual basis, and are published in the first Bulletin of the
succeeding quarterly and semiannual period, respectively.
3
Introduction
The contents of this publication are not copyrighted and may be reprinted freely.A citation of the Internal Revenue Bulletin as the source would be appropriate.
For sale by the Superintendent of Documents, U.S.Government Printing Office, Washington, DC 20402.

December 8, 199741997–49 I.R.B.
Section 38.—General Business
Credit
Loan to community development
corporation is eligible forgeneral busi-
ness credit.The full amount of the loan
made to a community development cor-
poration (CDC) is a “transfer of cash” to
the CDC for purposes of the definition of
a “qualified CDC contribution.”
Rev. Rul. 97–51
ISSUE
What amount of a loan may a commu-
nity development corporation (CDC) treat
as a “transfer of cash” for purposes of the
definition of a “qualified CDC contribu-
tion”?
FACTS
Bank wishes to lend money to X, a
CDC, that Xwill use to provide employ-
ment and business opportunities for low-
income residents in its operational area.
In June 1994, the Secretary of Housing
and Urban Development (HUD) desig-
nated Xa “selected community develop-
ment corporation” under § 13311 of the
Omnibus Revenue Reconciliation Act of
1993, 1993–3 C.B. 144 (the Act). Bank
and Xhave negotiated an agreement that
Bank will lend X$2,000,000 on Decem-
ber 31, 1997, for 10 years at a stated rate
of interest. Under the terms of the loan, X
does not have to repay the loan before the
end of 10 years.
LAWAND ANALYSIS
Section 13311 of the Act provides a
business credit under § 38 of the Internal
Revenue Code for a qualified CDC con-
tribution made by a taxpayer to a CDC. A
qualified CDC contribution is any transfer
of cash (1) made to a CDC during the 5-
year period beginning June 30, 1994, (2)
that is available for use by the CDC for at
least 10 years, (3) that the CDC uses to
provide employment and business oppor-
tunities for low-income individuals who
are residents of the operational area of the
CDC, and (4) that the CDC designates as
a qualified CDC contribution. The Secre-
tary of HUD selects the 20 qualifying
CDCs and determines whether those
CDCs spend the money received appro-
priately.
Acontributing taxpayer may claim an
annual credit during a 10-year period
equal to 5 percent of its contribution that
is designated by the CDC as a qualified
CDC contribution. The aggregate amount
of contributions that a CDC can designate
as eligible for the credit may not exceed
$2,000,000. The credit period begins
with the taxable year during which the
taxpayer made the qualified CDC contri-
bution.
Aqualified contribution to a CDC need
not be in the form of an outright gift. A
qualified contribution may also be made
in the form of a loan, the principal of
which is to be returned to the lender tax-
payer after the 10-year period. H.R. Rep.
No. 2264, 103d Cong., 1st Sess. 801
n.196 (1993), 1993–3 C.B. 377.
In the present case, Bank is lending
$2,000,000 to Xfor 10 years. To the ex-
tent of the amount of the loan designated
by Xas a qualified CDC contribution,
Bank is eligible to claim the CDC credit.
HOLDING
The full amount of the loan made to a
CDC is a “transfer of cash” to the CDC
for purposes of the definition of a “quali-
fied CDC contribution.”
DRAFTING INFORMATION
The principal author of this revenue
ruling is Paul Handleman of the Office of
the Assistant Chief Counsel (Pass-
throughs and Special Industries). For fur-
ther information regarding this revenue
ruling contact Mr. Handleman on (202)
622-3040 (not a toll free number).
Section 42.—Low-Income
Housing Credit
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of December 1997. See Rev. Rul. 97–50, page 5.
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term
rates are set forth for the month of December 1997.
See Rev. Rul. 97–50, page 5.
Section 382.—Limitation on Net
Operating Loss Carryforwards
and Certain Built-In Losses
Following Ownership Change
The adjusted federal long-term rate is set forth for
the month of December 1997. Rul. 97–50, page 5.
Section 412.—Minimum
Funding Standards
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of December 1997. See Rev. Rul. 97–50, page 5.
Section 467.—Certain
Payments for the Use of
Property or Services
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of December 1997. See Rev. Rul. 97–50, page 5.
Section 468.—Special Rules
for Mining and Solid Waste
Reclamation and Closing Costs
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of December 1997. See Rev. Rul. 97–50, page 5.
Section 482.—Allocation of
Income and Deductions
Among Taxpayers
Federal short-term, mid-term, and long-term
rates are set forth for the month of December 1997.
See Rev. Rul. 97–50, page 5.
Section 483.—Interest on
Certain Deferred Payments
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of December 1997. See Rev. Rul. 97–50, page 5.
Section 642.—Special Rules for
Credits and Deductions
Federal short-term, mid-term, and long-term
rates are set forth for the month of December 1997.
See Rev. Rul. 97–50, page 5.
Section 807.—Rules for
Certain Reserves
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of December 1997. See Rev. Rul. 97–50, page 5.
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

Section 846.—Discounted
Unpaid Losses Defined
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of December 1997. See Rev. Rul. 97–50, on this
page.
Section 954.—Foreign Base
Company Income.
26 CFR 1.954-3: Foreign base company
sales income. (Also sections 7805,
301.7805–1.)
This ruling revokes Rev. Rul. 75–7,
1975–1 C.B. 244, and holds that the ac-
tivities of a contract manufacturer cannot
be attributed to a controlled foreign cor-
poration for purposes of either section
954(d)(1) or section 954(d)(2) of the
Code to determine whether the income
of a controlled foreign corporation is for-
eign base company sales income. The
ruling, however, provides 7805(b) relief
for taxable years of a controlled foreign
corporation beginning before December
8, 1997.
Rev. Rul. 97–48
In Rev. Rul. 75–7, 1975–1 C.B. 244, a
controlled foreign corporation entered
into an arm’s length contract with an un-
related contract manufacturer located out-
side of its country of incorporation.
Under the contract, the unrelated contract
manufacturer agreed to perform manufac-
turing services for the controlled foreign
corporation. Under the facts described in
Rev. Rul. 75–7, the processing activities
of the unrelated contract manufacturer
were considered to be performed by the
controlled foreign corporation outside its
country of incorporation through a branch
or similar establishment for purposes of
section 954(d)(1) and (2) of the Internal
Revenue Code.
In Ashland Oil Co. v. Commissioner,
95 T.C. 348 (1990), the Tax Court held
that a manufacturing corporation
unrelated to a controlled foreign corpora-
tion cannot be a branch or similar
establishment of the controlled foreign
corporation. See also, Vetco, Inc. v. Com-
missioner, 95 T.C. 579 (1990) (wholly-
owned subsidiary of a controlled foreign
corporation cannot be a branch or similar
establishment of the controlled foreign
corporation).
The Service will follow the Ashland
and Vetco opinions. The activities of a
contract manufacturer cannot be attrib-
uted to a controlled foreign corporation
for purposes of either section 954(d)(1) or
section 954(d)(2) of the Code to deter-
mine whether the income of a controlled
foreign corporation is foreign base com-
pany sales income. Accordingly, Rev.
Rul. 75–7 is revoked.
Pursuant to the authority of section
7805(b), for taxable years of a controlled
foreign corporation beginning before De-
cember 8, 1997, the principles of Rev.
Rul. 75–7 may be relied upon to attribute
the activities of a contract manufacturer to
the controlled foreign corporation. Atax-
payer that relies on Rev. Rul. 75–7 to at-
tribute the activities of a contract manu-
facturer to a controlled foreign
corporation for purposes of section
954(d)(1), however, must treat the con-
tract manufacturing activities as being
performed through a branch or similar es-
tablishment of the controlled foreign cor-
poration for purposes of section
954(d)(2). The Service has never been of
the view that Rev. Rul. 75–7 allows the
activities of a contract manufacturer per-
formed outside the controlled foreign cor-
poration’s country of incorporation to be
attributed to the controlled foreign corpo-
ration without treating those activities as
performed through a branch or similar es-
tablishment of the controlled foreign cor-
poration.
With the revocation of Rev. Rul. 75–7,
the Service’s position on the treatment of
contract manufacturing for purposes sec-
tion 954(d) is harmonized with its posi-
tion on the treatment of contract manu-
facturing for purposes of section 863(b)
(see § 1.863–3(c) of the Income Tax
Regulations (production activity limited
to activity conducted directly by tax-
payer)).
EFFECTON OTHER
REVENUE RULINGS
Rev. Rul. 75–7, 1975–1 C.B. 244, is re-
voked effective December 8, 1997.
The principal author of this revenue
ruling is Valerie Mark of the Office of the
Associate Chief Counsel (International).
For further information regarding this
revenue ruling, contact Ms. Mark at (202)
622-3840 (not a toll-free call).
Section 1274.—Determination
of Issue Price in the Case of
Certain Debt Instruments
Issued for Property
(Also Sections 42, 280G, 382, 412, 467, 468, 482,
483, 642, 807, 846, 1288, 7520, 7872.)
Federal rates; adjusted federal rates;
adjusted federal long-term rate, and
the long-term exempt rate.For purposes
of sections 1274, 1288, 382, and other
sections of the Code, tables set forth the
rates for December 1997.
Rev. Rul. 97–50
This revenue ruling provides various
prescribed rates for federal income tax
purposes for December 1997 (the current
month.) Table 1 contains the short-term,
mid-term, and long-term applicable fed-
eral rates (AFR) for the current month for
purposes of section 1274(d) of the Inter-
nal Revenue Code. Table 2 contains the
short-term, mid-term, and long-term ad-
justed applicable federal rates (adjusted
AFR) for the current month for purposes
of section 1288(b). Table 3 sets forth the
adjusted federal long-term rate and the
long-term tax-exempt rate described in
section 382(f). Table 4 contains the ap-
propriate percentages for determining the
low-income housing credit described in
section 42(b)(2) for buildings placed in
service during the current month. Table 5
contains the federal rate for determining
the present value of an annuity, an interest
for life or for a term of years, or a remain-
der or a reversionary interest for purposes
of section 7520. Finally, Table 6 contains
the 1998 interest rate for sections 846 and
807.
1997–49 I.R.B.5December 8, 1997

December 8, 199761997–49 I.R.B.
REV. RUL. 97-50 TABLE 1
Applicable Federal Rates (AFR) for December 1997
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-Term
AFR5.68%5.60%5.56%5.54%
110% AFR6.25%6.16%6.11%6.08%
120% AFR6.83%6.72%6.66%6.63%
130% AFR7.41%7.28%7.21%7.17%
Mid-Term
AFR6.02%5.93%5.89%5.86%
110% AFR6.63%6.52%6.47%6.43%
120% AFR7.25%7.12%7.06%7.02%
130% AFR7.86%7.71%7.64%7.59%
150% AFR9.10%8.90%8.80% 8.74%
175% AFR10.65%10.38%10.25%10.16%
Long-Term
AFR6.31%6.21%6.16%6.13%
110% AFR6.95%6.83%6.77%6.73%
120% AFR7.59%7.45%7.38%7.34%
130% AFR8.23%8.07%7.99%7.94%
REV. RUL. 97-50 TABLE 2
Adjusted AFR for December 1997
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
adjusted AFR3.92%3.88%3.86%3.85%
Mid-term
adjusted AFR4.37%4.32%4.30%4.28%
Long-term
adjusted AFR5.23%5.16%5.13%5.11%
REV. RUL. 97-50 TABLE 3
Rates Under Section 382 for December 1997
Adjusted federal long-term rate for the current month5.23%
Long-term tax-exempt rate for ownership changes
during the current month (the highest of the adjusted
federal long-term rates for the current month and the
prior two months.)5.27%
REV. RUL. 97-50 TABLE 4
Appropriate Percentages Under Section 42(b)(2) for December 1997
Appropriate percentage for the 70% present
value low-income housing credit8.45%
Appropriate percentage for the 30% present
value low-income housing credit3.62%

1997–49 I.R.B.7December 8, 1997
Section 1288.—Treatment of
Original Issue Discount on
Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of December 1997. See Rev. Rul. 97–50, page 5.
Section 6081.—Extension of
Time for Filing Returns
26 CFR 301.6081–1: Extension of time for filing re-
turns.
Up to a 6-month extension of time to file federal
tax returns is provided to taxpayers located in Grand
Forks County, North Dakota, and Polk County, Min-
nesota. See Notice 97–62, page 8.
Section 6161.—Extension of
Time for Paying Tax
26 CFR 1.6161–1: Extension of time for paying tax
or deficiency.
Up to a 6-month extension of time to pay federal
tax is provided to taxpayers located in Grand Forks
County, North Dakota, and Polk County, Minnesota.
See Notice 97–62, page 8.
Section 6601.—Interest on
Underpayment, Nonpayment, or
Extension of Time for Payment,
of Tax
26 CFR 301.6601–1: Interest on underpayments.
Interest is abated with respect to federal individ-
ual income tax returns for certain taxpayers located
in Grand Forks County, North Dakota, and Polk
County, Minnesota. See Notice 97–62, page 8.
Section 7508.—Time for
Performing Certain Acts
Postponed by Reason of Service
in Combat Zone
The time for performing certain acts under the In-
ternal Revenue laws is postponed for certain taxpay-
ers located in Grand Forks County, North Dakota,
and Polk County, Minnesota. See Notice 97–62,
page 8.
Section 7520.—Valuation Tables
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of December 1997. See Rev. Rul. 97–50, page 5.
Section 7872.—Treatment of
Loans with Below-Market
Interest Rates
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of December 1997. See Rev. Rul. 97–50, page 5.
REV. RUL. 97-50 TABLE 5
Rate Under Section 7520 for December 1997
Applicable federal rate for determining the present
value of an annuity, an interest for life or a term
of years, or a remainder or reversionary interest7.2%
REV. RUL. 97-50 TABLE 6
Rate under Sections 846 and 807
Applicable rate of interest for 1998 for purposes
of sections 846 and 8076.31%

December 8, 199781997–49 I.R.B.
Presidentially Declared
Disasters in North Dakota and
Minnesota
Notice 97-62
PURPOSE
This notice provides immediate addi-
tional federal tax relief under §§ 6081,
6161, and 7508Aof the Internal Revenue
Code for taxpayers located in Grand
Forks County, North Dakota, and Polk
County, Minnesota, which were declared
major disaster areas by the President on
April 7 and 8, 1997. This notice specifi-
cally provides up to a 90-day extension of
the time to perform any act described in §
7508(a)(1), and generally provides an ex-
tension through January 13, 1998 for fil-
ing and paying federal income tax. In ad-
dition, the Treasury Department intends
to issue regulations under § 7508Are-
garding the postponement of certain tax-
related deadlines by reason of a Presiden-
tially declared disaster.
SUMMARYOF RELIEF
As a result of this notice:
(1) Taxpayers located in Grand Forks
County, North Dakota, and Polk County,
Minnesota, will have an extension to Jan-
uary 13, 1998 to file certain federal tax re-
turns originally due on or after April 15,
1997, and to pay the amount (or any in-
stallments) of tax shown or required to be
shown on those returns, including — indi-
vidual income tax returns (Forms 1040,
1040A, 1040EZ, 1040NR, 1040NR–EZ,
or 1040PC), gift tax returns (Forms 709
and 709–A), partnership returns (Form
1065), corporate income tax returns
(Forms 1120, 1120–A, 1120–H, or
1120S), estate and trust income tax re-
turns (Form 1041), and annual returns
filed by tax-exempt organizations (Forms
990, 990–EZ, or 990–T).
(2) For any quarterly estimated tax
payment originally due on or after April
15, 1997 for taxpayers located in these
two counties, the payment deadline is ex-
tended to January 13, 1998 and no esti-
mated tax penalties will be assessed. This
extension includes estimated tax pay-
ments made by individuals, corporations,
estates, or trusts. The deadline for filing
or paying employment or excise taxes
cannot be extended.
(3) Interest (and penalties relating to
the failure to file or pay) will be abated
(and waived) through January 13, 1998
with respect to federal individual income
tax returns originally due on or after April
15, 1997 for individuals (not including es-
tates and trusts) located in these two
counties.
For additional details on the relief pro-
vided in this notice, see the portion below
headed “GRANTOF RELIEF.”
BACKGROUND
Section 6081 provides that the Secre-
tary may grant a reasonable extension of
time (generally not to exceed 6 months)
for filing any return, declaration, state-
ment, or other document required by the
Internal Revenue Code or by regulations
thereunder.
Section 6161 provides that the Secre-
tary may grant a reasonable extension of
time (generally not to exceed 6 months)
for paying the amount (or any install-
ments) of tax shown or required to be
shown on any return or declaration re-
quired by the Code or by regulations
thereunder.
Section 7508A, as added to the Code
by section 911 of the Taxpayer Relief Act
of 1997 (Act), Pub. L. No. 105-34, 111
Stat. 788 (August 5, 1997), provides the
Secretary with authority to postpone the
time for performing certain acts under the
internal revenue laws (as provided in §
7508(a)(1)) for a taxpayer affected by a
Presidentially declared disaster (as de-
fined in § 1033(h)(3)). Pursuant to §
7508A(a), the Secretary may prescribe
regulations under which a period of up to
90 days may be disregarded in determin-
ing, under the internal revenue laws and
in respect of any tax liability (including
any penalty, additional amount, or addi-
tion to the tax) of such taxpayer,
(1) whether any of the acts described in
§ 7508(a)(1) (including filing and paying
federal taxes) were performed within the
time prescribed therefor, and
(2) the amount of any credit or refund.
Section 7508Aapplies to any period for
performing an act that has not expired be-
fore August 5, 1997.
Section 915(a) of the Act further pro-
vides that under certain circumstances the
assessment of interest with respect to in-
come tax must be abated for any individ-
ual located in an area designated during
1997 as a Presidentially declared disaster
area. This abatement is applicable for any
period the Secretary has extended the
time for filing income tax returns under §
6081 and the time for paying income tax
with respect to such returns under § 6161
(and has waived any penalties relating to
the failure to so file or so pay). For this
purpose, the term “individual” does not
include any estate or trust.
Prior federal tax relief was provided to
taxpayers located in North Dakota, South
Dakota, and Minnesota in IRS News Re-
lease IR–97–21 dated April 8, 1997, and
in a News Release dated April 29, 1997
issued by the IRS North Central District
Office.
GRANTOF RELIEF
The Secretary, by the exercise of his
authority under § 7508A, has granted an
extension of time to perform any act de-
scribed in § 7508(a)(1) to all taxpayers lo-
cated in Grand Forks County, North
Dakota, and Polk County, Minnesota, for
which the period for performance of the
act (taking extensions into account) had
not expired by August 5, 1997 and had
commenced no later than November 2,
1997 (affected act). For affected acts for
which the period for performance com-
menced prior to August 5, 1997 (such as
the filing of a 1996 income tax return by
an individual calendar year taxpayer for
which the period for performance com-
menced on January 1, 1997), this exten-
sion is for 90 days. For affected acts for
which the period for performance com-
menced on or after August 5, 1997 and on
or before November 2, 1997, this exten-
sion is equal to the number of days from
that commencement date through Novem-
ber 2, 1997.
In addition, the Secretary, by exercise
of his authority under §§ 6081 and 6161,
further extends the time for filing and
Part III. Administrative, Procedural, and Miscellaneous

paying federal taxes through January 13,
1998 for those taxpayers located in these
two counties for whom the filing and pay-
ment date was originally on or after April
15, 1997 and would be before January 13,
1998 even with the applicable § 7508A
extension.
Further, pursuant to the authority pro-
vided in § 915 of the Act, the Secretary
will abate the assessment of any interest
prescribed under § 6601 (and waive any
penalties relating to the failure to file or
pay) through January 13, 1998 with re-
spect to federal individual income tax re-
turns originally due on or after April 15,
1997 for individuals (not including estates
and trusts) located in these two counties.
DRAFTING INFORMATION
The principal author of this notice is
Vincent G. Surabian of the Office of the
Assistant Chief Counsel (Income Tax and
Accounting). For further information re-
garding this notice, contact Mr. Surabian
at (202) 622-4940 (not a toll-free call).
Adoption Assistance
Notice 97-70
This notice modifies Notice 97–9,
1997–2 I.R.B. 35, which provides, in part,
general guidance concerning the income
tax credit under § 23 of the Internal Rev-
enue Code for qualified adoption ex-
penses paid or incurred by an individual.
Notice 97-9 is modified to incorporate the
amendment made to § 23(a)(2) (relating
to the year(s) in which the credit for cer-
tain qualified adoption expenses is al-
lowed) by § 1601(h)(2)(A) of the Tax-
payer Relief Act of 1997, Pub. L. No.
105-34, 111 Stat. 788, 1092 (1997), effec-
tive for taxable years beginning after De-
cember 31, 1996. Notice 97-9 will appear
in 1997–1 C.B. as modified by this notice.
Section I.E.1 and the first paragraph of
section I.E.2 of Notice 97–9 are modified
to read as follows:
E.Year of Credit.
1. Domestic adoptions.
The credit for qualified adoption ex-
penses paid or incurred to adopt an eligi-
ble child who is a citizen or a resident of
the United States at the time the adoption
commenced (including such amounts paid
or incurred in an unsuccessful effort to
adopt such a child) is allowed in the next
taxable year unless the expenses are paid
or incurred during or after the taxable
year the adoption becomes final. The
credit for qualified adoption expenses
paid or incurred during or after the tax-
able year in which an adoption becomes
final is allowed in the taxable year in
which the expenses are paid or incurred.
2. Foreign adoptions.
Aspecial rule applies in the case of the
adoption of an eligible child who is not a
citizen or resident of the United States at
the time the adoption commenced. The
credit is only available for adoptions that
become final. Qualified adoption ex-
penses paid or incurred in any taxable
year before the taxable year in which the
adoption becomes final are treated as paid
or incurred in the taxable year in which
the adoption becomes final. Therefore,
the credit for qualified adoption expenses
paid or incurred in the taxable year in
which the adoption is final, or in any ear-
lier taxable year, is allowed in the taxable
year the adoption becomes final. The
credit for qualified adoption expenses
paid or incurred after the taxable year in
which the adoption becomes final is al-
lowed in the taxable year in which the ex-
penses are paid or incurred.
The principal author of this notice is
Marilyn E. Brookens of the Office of the
Assistant Chief Counsel (Income Tax and
Accounting). For further information re-
garding this notice, contact Ms. Brookens
at (202) 622-4920 (not a toll-free call).
Filing Status: Single
Pay PeriodNumber of Exemptions Claimed on Statement
123456More Than 6
Daily26.7337.1247.5057.8868.2778.6516.35 plus 10.38 for each exemption
Weekly133.65185.58237.50289.42341.35393.2781.73 plus 51.92 for each exemption
Biweekly267.31371.15475.00578.85682.69786.54163.46 plus 103.85 for each exemption
Semi-monthly289.58402.08514.58627.08739.58852.08177.08 plus 112.50 for each exemption
Monthly579.17804.171029.171254.171479.171704.17354.17 plus 225.00 for each exemption
Tables for Figuring Amount Exempt From Levy on Wages, Salary, and Other Income
Notice 97–71
1. Table for Figuring Amount Exempt From Levy on Wages, Salary, and Other Income
(Forms 668-W, 668-W(c), & 668-W(c)(DO)) 1998
Publication 1494, shown below, provides tables which show the amount of an individual’s income that is exempt from a notice of
levy used to collect delinquent tax in 1998.
(Amounts are for each pay period.)
1997–49 I.R.B.9December 8, 1997

December 8, 1997101997–49 I.R.B.
Filing Status: Unmarried Head of Household
Pay PeriodNumber of Exemptions Claimed on Statement
123456More Than 6
Daily34.4244.8155.1965.5875.9686.3524.04 plus 10.38 for each exemption
Weekly172.12224.04275.96327.88379.81431.73120.19 plus 51.92 for each exemption
Biweekly344.23448.08551.92655.77759.62863.46240.38 plus 103.85 for each exemption
Semi-monthly372.92485.42597.92710.42822.92935.42260.42 plus 112.50 for each exemption
Monthly745.83970.831195.831420.831645.831870.83520.83 plus 225.00 for each exemption
Filing Status: Married Filing Joint (and Qualifying Widow(er)s)
Pay PeriodNumber of Exemptions Claimed on Statement
123456More Than 6
Daily37.6948.0858.4668.8579.2389.6227.31 plus 10.38 for each exemption
Weekly188.46240.38292.31344.23396.15448.08136.54 plus 51.92 for each exemption
Biweekly376.92480.77584.62688.46792.31896.15273.08 plus 103.85 for each exemption
Semi-monthly408.33520.83633.33745.83858.33970.83295.83 plus 112.50 for each exemption
Monthly816.671041.671266.671491.671716.671941.67591.67 plus 225.00 for each exemption
Filing Status: Married Filing Separate
Pay PeriodNumber of Exemptions Claimed on Statement
123456More Than 6
Daily24.0434.4244.8155.1965.5875.9613.65 plus 10.38 for each exemption
Weekly120.19172.12224.04275.96327.88379.8168.27 plus 51.92 for each exemption
Biweekly240.38344.23448.08551.92655.77759.62136.54 plus 103.85 for each exemption
Semi-monthly260.42372.92485.42597.92710.42822.92147.92 plus 112.50 for each exemption
Monthly520.83745.83970.831195.831420.831645.83295.83 plus 225.00 for each exemption

1997–49 I.R.B.11December 8, 1997
* ADDITIONALSTANDARD DEDUCTION claimed on Parts 3, 4, & 5 of levy.
Examples
These tables show the amount exempt from a levy on wages, salary, and other income.
For example:
1. Asingle taxpayer who is paid weekly and claims three exemptions (including one for the taxpayer) has $237.50 exempt from
levy.
2. If the taxpayer in number 1 is over 65 and writes 1 in the ADDITIONALSTANDARD DEDUCTION space on Parts 3, 4, & 5
of the levy, $257.69 is exempt from this levy ($237.50 plus $20.19).
3. Ataxpayer who is married, files jointly, is paid bi-weekly, and claims two exemptions (including one for the taxpayer) has
$480.77 exempt from levy.
4. If the taxpayer in number 3 is over 65 and has a spouse who is blind, this taxpayer should write 2 in the ADDITIONALSTAN-
DARD DEDUCTION space on Parts 3, 4, & 5 of the levy. Then, $546.15 is exempt from this levy ($480.77 plus $65.38).
Filing Status*DailyWklyBi-WklySemi-MoMonthly
Single or Head
of Household14.0420.1940.3843.7587.50
28.0840.3880.7787.50175.00
Any Other13.2716.3532.6935.4270.83
Filing Status26.5432.6965.3870.83141.67
39.8149.0498.08106.25212.50
413.0865.38130.77141.67283.33
2. Table forFiguring Additional Exempt Amount
forTaxpayers at Least 65 Years Old and/orBlind
Additional Exempt Amount

December 8, 1997121997–49 I.R.B.
Foundations Status of Certain
Organizations
Announcement 97–117
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 des-
ignations in the Cumulative List of Orga-
nizations (Publication 78), or on the pre-
sumption arising from the filing of notices
under section 508(b) of the Code. This
listing does notindicate that the organiza-
tions have lost their status as organiza-
tions described in section 501(c)(3), eligi-
ble to receive deductible contributions.
Former Public Charities.The following
organizations (which have been treated as
organizations that are not private founda-
tions described in section 509(a) of the
Code) are now classified as private foun-
dations:
100 Black Men of Indianapolis Inc.,
Indianapolis, IN
100 Black Men of Milwaukee Inc.,
Milwaukee, WI
100 Percent Charity Inc., Jonesboro, GA
100 Black Men Coalition,
Oklahoma City, OK
12 Miles West Theatre Company Inc.,
Montclair, NJ
14th ILACongress, Greenville, SC
1st District Adopt-A-Rec Center Fund,
Inc., Philadelphia, PA
2 Christ-The-Solution Inc.,
Marco Island, FL
4 Youngsters Inc., Sandy, UT
710 AAGroup, Midland, TX
Acorn Community Land Association of
Illinois, New Orleans, LA
Act Right Inc., Edmond, OK
Action Theatre Conservatory Inc.,
Clifton, NJ
Actors Community Theater of Naples,
Inc., Naples, FL
Actors Rep Company Inc., Ewing, NJ
Acts 29 Ministries Inc., Valdosta, GA
Admit Center, Devils Lake, ND
Adobe Theatre Inc., Corrales, NM
Adolescent Resource Center Inc.,
Longview, TX
Adopt-A-Family of Jefferson County,
Golden, CO
Adopt-A-Greyhound of Central Florida,
Inc., Melbourne, FL
Adopt-A-Pet—N.P.C.,
Houghton Lake, MI
Adult Attention Deficit Foundation,
Birmingham, MI
Adult Literacy Project of Sabinal,
Sabinal, TX
Advanced Data Control Inc.,
St. Clairsville, OH
Advertising Professionals of Des Moines
Scholarship FDN, Des Moines, IA
Advisory Board for the Spokane Indus-
trial Technologies Dept., Spokane, MO
Advocates for At-Risk Kids Inc–Child &
Adolescent Advocacy Bureau,
Baytown, TX
Advocates for Humanity Inc.,
Salt Lake City, UT
Affiliated Boards of Officials,
Colorado Springs, CO
Affiliation of Christian Disciples,
Colorado Springs, CO
Affordable Home Ownership Inc.,
Pataskala, OH
Affordable Homes Through Creative
Capitalism, Inc., Decatur, GA
Affordable Housing Alliance,
Farmington Hills, MI
Affordable Housing Corporation of Lake
County, Gurnee, IL
Affordable Housing Corporation of
Pinellas County, Inc.,
St. Petersburg, FL
Affordable Housing of East Tampa Bay,
Inc., Sun City Center, FL
Affordable Housing of Jennings Inc.,
Jennings, MO
Affordable Housing Solutions for
Florida, Inc., Miami, FL
Afghan Student Association Inc.,
Alexandria, VA
African American Cultural Center–The
American Youth Foundation,
Nashville, TN
African American Cultural Garden,
Cleveland, OH
African American Heritage Preservation
Society, Inc., Columbus, GA
African Christians Fellowship Interna-
tional, Inc., Charlotte, NC
African Family Inc., Archer, FL
Agape Christian Center Inc.,
Louisburg, KS
Agape Foundation, Chicago, IL
Agape Love Inc., Fort Lauderdale, FL
Agate Award Charitable Trust, Blooming-
ton, MN
Agency for International
Understanding, Inc., Spartanburg, SC
Agrape Missionary Association Interna-
tional, Inc., Toccoa, GA
Aid to Lithuania Inc., Chicago, IL
Aids Countrywide Testing Information
Act I, Kenner, LA
Aids Education Help Network Inc.,
Houston, TX
Aids Outreach of Northern Arizona, Inc.,
Flagstaff, AZ
Aids Prevention Foundation of America,
Kansas City, MO
Aikikai International Inc., Miami, FL
AIMOInc., Cleveland, OH
Airborne Police Assistance Group, Inc.,
Wilmington, DE
Airport Construction Scholarship Fund,
Inc., Miami, FL
Airway, Kingwood, TX
Aishlinn Womens Center,
Grosse Pointe Farms, MI
Alabama Citizens Coalition for
Enforcement of Support Services,
Duncanville, AL
Alabama Demolay Foundation Inc.,
Gadsden, AL
Alabama Nursing Home Association Ed-
ucation Foundation, Montgomery, AL
Alabama Power Service Organization,
Inc., Mobile, AL
Alabama Power Service Organization,
Inc., Eufaula, AL
Alabama Power Service Organization,
Inc., Tuscaloosa, AL
Alabama Power Service Organization,
Inc., Birmingham, AL
Alabama Power Service Organization,
Inc., Anniston, AL
Alabama Power Service Organization,
Inc., Parrish, AL
Alabama Power Service Organization,
Inc., Graysville, AL
Alabama Power Service Organization,
Inc., Montgomery, AL
Alabama Power Service Organization,
Inc., Birmingham, AL
Alabama Visual Arts Hall of Fame, Inc.,
Gadsden, AL
Part IV. Items of General Interest

1997–49 I.R.B.13December 8, 1997
Alabama Waterfowl Association Inc.,
Guntersville, AL
Alameda Theater Facilities,
San Antonio, TX
Albuquerques Finest Inc.,
Albuquerque, NM
Alcor Arizona Chapter Inc.,
Phoenix, AZ
Alexander Foundation Inc., Fremont, NE
Algonac-Clay Township Historical
Society, Algonac, MI
Algonac Fire Department Auxiliary,
Algonac, MI
Alice Avenue Church of Christ Child
Care Center, Memphis, TN
Alkebu-Lan Center for Martial Arts,
Detroit, MI
Alkebu-Lan Economic Development
Systems, Inc., Phoenix, AZ
All Aboard-The Training Junction, Inc.,
Provo, UT
All Animal Rescue Organization,
Wheat Ridge, CO
All Christian Center Ministry Bible Club
America, Inc., Wichita, KS
All Generations Inc., Monroe, LA
All Saints Foundation,
Pawleys Island, SC
All Souls Indoor-Outdoor Association,
Washington, DC
All Star Athletic Association Inc.,
Smyrna, GA
All-Star Scholarship Foundation,
Plano, TX
Allegheny Comprehensive Adolescent
Programs, Inc–ACAP,
Pittsburgh, PA
Allegheny County Alliance for Public
Schools, Pittsburgh, PA
Allen County Tenant Council, Lima, OH
Allen Road Mid-Rise Tenants
Association, Inc., Atlanta, GA
Alliance for Catholic Education An Okla-
homa Not for Profit Corporation,
Norman, OK
Alliance for Life Long Learning,
Detroit, MI
If an organization listed above submits
information that warrants the renewal of
its classification as a public charity or as a
private operating foundation, the Internal
Revenue Service will issue a ruling or de-
termination letter with the revised classi-
fication as to foundation status. Grantors
and contributors may thereafter rely upon
such ruling or determination letter as pro-
vided in section 1.509(a)–7 of the Income
Tax Regulations. It is not the practice of
the Service to announce such revised clas-
sification of foundation status in the Inter-
nal Revenue Bulletin.
Deletions from Cumulative List
of Organizations Contributions
to Which Are Deductible Under
Section 170 of the Code
Announcement 97–118
The names of organizations that no
longer qualify as organizations described
in section 170(c)(2) of the Internal Rev-
enue Code of 1986 are listed below.
Generally, the Service will not disallow
deductions for contributions made to a
listed organization on or before the date
of announcement in the Internal Revenue
Bulletin that an organization no longer
qualifies. However, the Service is not
precluded from disallowing a deduction
for any contributions made after an orga-
nization ceases to qualify under section
170(c)(2) if the organization has not
timely filed a suit for declaratory judg-
ment under section 7428 and if the con-
tributor (1) had knowledge of the revoca-
tion of the ruling or determination letter,
(2) was aware that such revocation was
imminent, or (3) was in part responsible
for or was aware of the activities or omis-
sions of the organization that brought
about this revocation.
If on the other hand a suit for declara-
tory judgment has been timely filed, con-
tributions from individuals and organiza-
tions described in section 170(c)(2) that are
otherwise allowable will continue to be de-
ductible. Protection under section 7428(c)
would begin on December 8, 1997, and
would end on the date the court first deter-
mines that the organization is not described
in section 170(c)(2) as more particularly
set forth in section 7428(c)(1). For indi-
vidual contributors, the maximum deduc-
tion protected is $1,000, with a husband
and wife treated as one contributor. This
benefit is not extended to any individual
who was responsible, in whole or in part,
for the acts or omissions of the organiza-
tion that were the basis for revocation.
Alpha Housing & Health Care, Inc.
New Castle, PA
Charles S. Meyer Family Fund
Chicago, IL
Muscular Dystrophy Aid Society, Inc.
Houston, TX
Muscular Dystrophy Aid Society Gout &
Arthritis Association
Houston, TX
Muscular Dystrophy Aid Society High
Blood Pressure Society
Houston, TX
Muscular Dystrophy Aid Society 111 Pull
for Youth, Houston, TX
Section 7428(c) Validation of
Certain Contributions Made
During Pendency of Declaratory
Judgment Proceedings
This announcement serves notice to po-
tential donors that the organization listed
below has recently filed a timely declara-
tory judgment suit under section 7428 of
the Code, challenging revocation of its
status as an eligible donee under section
170(c)(2).
Protection under section 7428(c) of the
Code begins on the date that the notice of
revocation is published in the Internal
Revenue Bulletin and ends on the date on
which a court first determines that an or-
ganization is not described in section
170(c)(2), as more particularly set forth in
section 7428(c)(1). In the case of individ-
ual contributors, the maximum amount of
contributions protected during this period
is limited to $1,000.00, with a husband
and wife being treated as one contributor.
This protection is not extended to any in-
dividual who was responsible, in whole or
in part, for the acts or omissions of the or-
ganization that were the basis for the re-
vocation. This protection also applies
(but without limitation as to amount) to
organizations described in section
170(c)(2) which are exempt from tax
under section 501(a). If the organization
ultimately prevails in its declaratory judg-
ment suit, deductibility of contributions
would be subject to the normal limitations
set forth under section 170.
The Children’s Learning Center, Inc.
Rockville, MD

December 8, 1997141997–49 I.R.B.
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus,
if an earlier ruling held that a principle
applied to A, and the new ruling holds
that the same principle also applies to B,
the earlier ruling is amplified. (Compare
with modified, below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously
published ruling and points out an essen-
tial difference between them.
Modified is used where the substance
of a previously published position is
being changed. Thus, if a prior ruling
held that a principle applied to Abut not
to B, and the new ruling holds that it ap-
plies to both Aand B, the prior ruling is
modified because it corrects a published
position. (Compare with amplified and
clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used
in a ruling that lists previously published
rulings that are obsoleted because of
changes in law or regulations. Aruling
may also be obsoleted because the sub-
stance has been included in regulations
subsequently adopted.
Revoked describes situations where the
position in the previously published rul-
ing is not correct and the correct position
is being stated in the new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a pe-
riod of time in separate rulings. If the
new ruling does more than restate the
substance of a prior ruling, a combination
of terms is used. For example, modified
and superseded describes a situation
where the substance of a previously pub-
lished ruling is being changed in part and
is continued without change in part and it
is desired to restate the valid portion of
the previously published ruling in a new
ruling that is self contained. In this case
the previously published ruling is first
modified and then, as modified, is super-
seded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and
that list is expanded by adding further
names in subsequent rulings. After the
original ruling has been supplemented
several times, a new ruling may be pub-
lished that includes the list in the original
ruling and the additions, and supersedes
all prior rulings in the series.
Suspended is used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current use and for-
merly used will appear in material published in the
Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C.—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance 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 Procedral Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Definition of Terms

1997–49 I.R.B.15December 8, 1997
Numerical Finding List
1
Bulletins 1997–27 through 1997–48
Announcements:
97–61, 1997–29 I.R.B. 13
97–67, 1997–27 I.R.B. 37
97–68, 1997–28 I.R.B. 13
97–69, 1997–28 I.R.B. 13
97–70, 1997–29 I.R.B. 14
97–71, 1997–29 I.R.B. 15
97–72, 1997–29 I.R.B. 15
97–73, 1997–30 I.R.B. 86
97–74, 1997–31 I.R.B.16
97–75, 1997–32 I.R.B. 28
97–76, 1997–32 I.R.B. 28
97–77, 1997–33 I.R.B. 58
97–78, 1997–34 I.R.B. 11
97–79, 1997–35 I.R.B. 8
97–80, 1997–34 I.R.B. 12
97–81, 1997–34 I.R.B. 12
97–82, 1997–34 I.R.B. 12
97–83, 1997–34 I.R.B. 13
97–84, 1997–34 I.R.B. 13
97–85, 1997–35 I.R.B. 8
97–86, 1997–35 I.R.B. 9
97–87, 1997–35 I.R.B. 9
97–88, 1997–35 I.R.B. 9
97–89, 1997–36 I.R.B. 10
97–90, 1997–36 I.R.B. 10
97–91, 1997–37 I.R.B. 25
97–92, 1997–37 I.R.B. 26
97–93, 1997–36 I.R.B. 11
97–94, 1997–36 I.R.B. 12
97–95, 1997–36 I.R.B. 12
97–96, 1997–39 I.R.B.15
97–97, 1997–38 I.R.B. 22
97–98, 1997–39 I.R.B. 15
97–99, 1997–40 I.R.B. 7
97–100, 1997–40 I.R.B. 8
97–101, 1997–41 I.R.B. 13
97–102, 1997–41 I.R.B. 15
97–103, 1997–41 I.R.B. 16
97–104, 1997–42 I.R.B. 39
97–105, 1997–42 I.R.B. 40
97–106, 1997–45 I.R.B. 11
97–107, 1997–43 I.R.B. 25
97–108, 1997–43 I.R.B. 25
97–109, 1997–45 I.R.B. 12
97–110, 1997–45 I.R.B. 14
97–111, 1997–47 I.R.B. 15
97–112, 1997–46 I.R.B. 20
97–113, 1997–46 I.R.B.21
97–114, 1997–46 I.R.B. 21
97–115, 1997–47 I.R.B. 17
97–116, 1997–48 I.R.B. 25
Court Decisions:
2061, 1997–31 I.R.B. 5
2062, 1997–32 I.R.B. 8
Delegation Orders:
97 (Rev. 34), 1997–41 I.R.B. 14
172 (Rev. 5), 1997–28 I.R.B. 6
Notices:
97–37, 1997–27 I.R.B. 4
Notices–Continued
97–38, 1997–27 I.R.B. 8
97–39, 1997–27 I.R.B. 8
97–40, 1997–28 I.R.B. 6
97–41, 1997–28 I.R.B. 6
97–42, 1997–29 I.R.B. 12
97–43, 1997–30 I.R.B. 9
97–44, 1997–31 I.R.B. 15
97–45, 1997–33 I.R.B. 7
97–46, 1997–34 I.R.B. 10
97–47, 1997–35 I.R.B. 5
97–48, 1997–35 I.R.B. 5
97–49, 1997–36 I.R.B. 8
97–50, 1997–37 I.R.B. 21
97–51, 1997–38 I.R.B. 20
97–52, 1997–38 I.R.B. 20
97–53, 1997–40 I.R.B. 6
97–54, 1997–41 I.R.B. 7
97–55, 1997–40 I.R.B. 6
97–56, 1997–43 I.R.B. 19
97–57, 1997–43 I.R.B. 19
97–58, 1997–45 I.R.B. 7
97–59, 1997–45 I.R.B. 7
97–60, 1997–46 I.R.B.8
97–61, 1997–48 I.R.B.8
97–63, 1997–47 I.R.B. 6
97–64, 1997–47 I.R.B. 7
97–66, 1997–48 I.R.B.8
97–67, 1997–48 I.R.B.10
97–68, 1997–48 I.R.B. 11
97–69, 1997–48 I.R.B. 12
Railroad Retirement Quarterly Rate:
1997–28 I.R.B. 5
Public Laws
105–35, 1997–43 I.R.B. 13
Proposed Regulations:
REG–104893–97, 1997–29 I.R.B. 13
REG–105160–97, 1997–37 I.R.B. 22
REG–105162–97, 1997–48 I.R.B. 13
REG–106043–97, 1997–37 I.R.B. 24
REG–107644–97, 1997–32 I.R.B. 24
REG–107872–97, 1997–47 I.R.B. 11
REG–114000–97, 1997–47 I.R.B. 13
REG–208151–91, 1997–38 I.R.B. 21
REG–246250–96, 1997–42 I.R.B. 30
REG–251985–96, 1997–48 I.R.B. 18
Revenue Procedures:
97–32, 1997–27 I.R.B. 9
97–32A, 1997–34 I.R.B. 10
97–33, 1997–30 I.R.B. 10
97–34, 1997–30 I.R.B.14
97–35, 1997–33 I.R.B. 11
97–36, 1997–33 I.R.B. 14
97–37, 1997–33 I.R.B. 18
97–38, 1997–33 I.R.B. 43
97–39, 1997–33 I.R.B. 48
97–40, 1997–33 I.R.B. 50
97–41, 1997–33 I.R.B. 5
97–42, 1997–33 I.R.B. 57
97–43, 1997–39 I.R.B. 12
97–44, 1997–41 I.R.B. 8
97–45, 1997–41 I.R.B. 10
97–46, 1997–42 I.R.B. 10
97–47, 1997–42 I.R.B. 19
97–48, 1997–43 I.R.B. 19
97–49, 1997–43 I.R.B. 22
97–50, 1997–45 I.R.B. 8
97–51, 1997–45 I.R.B. 9
97–52, 1997–46 I.R.B.17
97–53, 1997–47 I.R.B.10
Revenue Rulings:
97–27, 1997–27 I.R.B. 4
97–28, 1997–28 I.R.B. 4
97–29, 1997–28 I.R.B. 4
97–30, 1997–31 I.R.B.12
97–31, 1997–32 I.R.B.4
97–32, 1997–33 I.R.B. 4
97–33, 1997–34 I.R.B. 4
97–34, 1997–34 I.R.B. 14
97–35, 1997–35 I.R.B. 4
97–36, 1997–36 I.R.B. 5
97–37, 1997–37 I.R.B.15
97–38, 1997–38 I.R.B.14
97–39, 1997–39 I.R.B. 4
97–40, 1997–39 I.R.B. 8
97–41, 1997–40 I.R.B. 4
97–42, 1997–41 I.R.B. 4
97–43, 1997–42 I.R.B. 8
97–44, 1997–45 I.R.B. 5
97–45, 1997–46 I.R.B.4
97–46, 1997–46 I.R.B.7
97–47, 1997–47 I.R.B.4
97–49, 1997–48 I.R.B. 4
Treasury Decisions:
8722, 1997–29 I.R.B. 4
8723, 1997–30 I.R.B. 4
8724, 1997–36 I.R.B. 4
8725, 1997–37 I.R.B. 16
8726, 1997–34 I.R.B. 7
8727, 1997–34 I.R.B. 5
8728, 1997–37 I.R.B. 4
8729, 1997–38 I.R.B. 4
8730, 1997–38 I.R.B. 16
8731, 1997–42 I.R.B. 6
8732, 1997–42 I.R.B. 4
8733, 1997–43 I.R.B. 8
8734, 1997–44 I.R.B. 5
8735, 1997–43 I.R.B. 4
1
Acumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 1997–1 through 1997–26
will be found in Internal Revenue Bulletin 1997–27,
dated July 7, 1997.

December 8, 1997161997–49 I.R.B.
Finding List of Current Action on
Previously Published Items
1
Bulletins 1997–27 through 1997–48
*Denotes entry since last publication
Revenue Procedures:
82–36
Modified and superseded by
97–49, 1997–43 I.R.B. 22
96–36
Superseded by
97–34, 1997–30 I.R.B. 14
96–42
Superseded by
97–27, 1997–27 I.R.B. 9
97–32
Modified and amplified by
97–32A, 1997–34 I.R.B. 10
Revenue Rulings:
73–67
Revoked by
97–46, 1997–46 I.R.B. 7
89–42
Supplemented by
97–31, 1997–32 I.R.B. 4
93–76
Clarified, modified, partially
obsoleted, and superceded by
97–39, 1997–39 I.R.B 4
94–7
Clarified, modified, partially
obsoleted, and superceded by
97–39, 1997–39 I.R.B 4
1
Acumulative finding list for previously published
items mentioned in Internal Revenue Bulletins
1997–1 through 1997–26 will be found in Internal
Revenue Bulletin 1997–27, dated July 7, 1997.

Notes
1997–49 I.R.B.17December 8, 1997

Notes
December 8, 1997181997–49 I.R.B.

Notes
1997–49 I.R.B.19December 8, 1997

Notes
December 8, 1997201997–49 I.R.B.

Notes
1997–49 I.R.B.21December 8, 1997

Notes
December 8, 1997221997–49 I.R.B.

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