Internal Revenue Bulletin 2000-27 (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. 2000–32, page 1.
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 July 2000.
T.D. 8888, page 3.
Final regulations under section 6049 of the Code rescind the
requirement that certain information related to the accrual of
original issue discount (OID) be set forth on the face of certifi-
cates for a collateralized debt obligation (CDO) or regular inter-
est in a real estate mortgage investment conduit (REMIC).
REG–105316–98, page 98.
Proposed regulations under section 6050S of the Code re-
late to information reporting for payments of qualified tu-
ition and related expenses and payments of interest on
qualified education loans. In addition, proposed regula-
tions under section 6011(e) of the Code relate to mag-
netic media filing requirements for information returns.
ESTATE TAX
T.D. 8886, page 3.
Final regulations under section 7520 of the Code relate to
the use of actuarial tables in valuing annuities, interests
for life or terms of years, and remainder or reversionary
interests.
EXCISE TAX
Notice 2000–33, page 97.
Taxable fuel measurement.This notice provides infor-
mation under section 4081 of the Code relating to the
measurement of taxable fuel for the period July 1, 2000,
through June 30, 2001.
ADMINISTRATIVE
Rev. Proc. 2000–28, page 60.
Rules and specifications for private printing of sub-
stitute forms.This procedure provides requirements for
reproducing paper substitutes and for furnishing substi-
tute recipient statements for Forms 1096, 1098, 1099,
5498, and W-2G. It will be reproduced as the July 2000 re-
vision of Publication 1179. Rev. Proc. 99–34 superseded.
Internal Revenue
bbuulllleettiinn
Bulletin No. 2000–27
July 3, 2000
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 ii.
Index for January through June begins on page vi.

July 3, 20002000–27 I.R.B.
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 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 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.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
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 semiannual basis,
and are published in the first Bulletin of the succeeding semi-
annual period, respectively.
The IRS Mission
Provide America’s taxpayers top quality service by help-
ing them understand and meet their tax responsibilities
and by applying the tax law with integrity and fairness to
all.
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.

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 July 2000. See Rev. Rul. 2000–32, on this page.
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term
rates are set forth for the month of July 2000. See
Rev. Rul. 2000–32, on this page.
Section 382.—Limitation on Net
Operating Loss Carryforwards
and Certain Built-In Losses
Following Ownership Change
The adjusted applicable federal long-term rate is
set forth for the month of July 2000. See Rev. Rul.
2000–32, on this page.
Section 412.—Minimum Funding
Standards
The adjusted applicable federal short-term, mid-
term and long-term rates are set forth for the month
of July 2000. See Rev. Rul. 2000–32, on this page.
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 July 2000. See Rev. Rul. 2000–32, on this page.
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 July 2000. See Rev. Rul. 2000–32, on this page.
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 July 2000. See
Rev. Rul. 2000–32, on this page.
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 July 2000. See Rev. Rul. 2000–32, on this page.
Section 642.—Special Rules for
Credits and Deductions
Federal short-term, mid-term, and long-term
rates are set forth for the month of July 2000. See
Rev. Rul. 2000–32, on this page.
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 July 2000. See Rev. Rul. 2000–32, on this page.
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 July 2000. See Rev. Rul. 2000–32, on this page.
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 July 2000.
Rev. Rul. 2000–32
This revenue ruling provides various pre-
scribed rates for federal income tax purposes
for July 2000 (the current month.) Table 1
contains the short-term, mid-term, and long-
term applicable federal rates (AFR) for the
current month for purposes of section
1274(d) of the Internal Revenue Code.
Table 2 contains the short-term, mid-term,
and long-term adjusted 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 appro-
priate percentages for determining the low-
income housing credit described in section
42(b)(2) for buildings placed in service dur-
ing 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 remainder or a reversionary in-
terest for purposes of section 7520. Finally,
Table 6 contains the blended annual rate for
purposes of section 7872.
2000–27 I.R.B.1July 3, 2000
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

REV. RUL. 2000–32 TABLE 1
Applicable Federal Rates (AFR) for July 2000
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-Term
AFR6.60%6.49%6.44%6.40%
110% AFR7.27%7.14%7.08%7.04%
120% AFR7.94%7.79%7.72%7.67%
130% AFR8.62%8.44%8.35% 8.30%
Mid-Term
AFR6.62% 6.51% 6.46%6.42%
110% AFR7.29%7.16%7.10%7.06%
120% AFR7.96%7.81%7.74%7.69%
130% AFR8.64%8.46%8.37%8.31%
150% AFR10.01%9.77%9.65%9.58%
175% AFR11.71%11.39%11.23%11.13%
Long-Term
AFR6.40%6.30%6.25%6.22%
110% AFR7.05%6.93%6.87%6.83%
120% AFR7.70%7.56%7.49%7.44%
130% AFR8.36%8.19%8.11%8.05%
July 3, 200022000–27 I.R.B.
REV. RUL. 2000–32 TABLE 2
Adjusted AFR for July 2000
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
adjusted AFR4.88%4.82%4.79%4.77%
Mid-term
adjusted AFR5.12%5.06%5.03%5.01%
Long-term
adjusted AFR5.79%5.71%5.67%5.64%
REV. RUL. 2000–32 TABLE 3
Rates Under Section 382 for July 2000
Adjusted federal long-term rate for the current month5.79%
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.)5.79%
REV. RUL. 2000–32 TABLE 4
Appropriate Percentages Under Section 42(b)(2)
for July 2000
Appropriate percentage for the 70% present value low-income housing credit8.53%
Appropriate percentage for the 30% present value low-income housing credit3.66%

REV. RUL. 2000–32 TABLE 5
Rate Under Section 7520 for July 2000
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 interest8.0%
2000–27 I.R.B.3July 3, 2000
REV. RUL. 2000–32 TABLE 6
Blended Annual Rate for 2000
Section 7872(e)(2) blended annual rate for 20006.24%
Section 1288.—Treatment of
Original Issue Discounts on Tax-
Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of July 2000. See Rev. Rul. 2000–32, page 1.
Section 6049.—Returns
Regarding Payments of Interest
26 CFR 1.6049–7: Returns of information with
respect to REMIC regular interests and
collateralized debt obligations.
T.D. 8888
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
Real Estate Mortgage
Investment Conduits; Reporting
Requirements and Other
Administrative Matters
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations.
SUMMARY: This document eliminates
the regulatory requirement that the issuer
of a collateralized debt obligation (CDO)
or regular interest in a real estate mort-
gage investment conduit (REMIC) set
forth certain information on the face of
the CDO or regular interest. This action
eliminates a reporting burden imposed on
issuers of CDOs and regular interests.
EFFECTIVE DATE: These regulations
are effective June 16, 2000.
FOR FURTHER INFORMATION CON-
TACT: Kenneth Christman, (202) 622-
3950 (not toll-free numbers).
SUPPLEMENTARY INFORMATION:
Background
On May 19, 1999, the IRS published in
the Federal Register a notice of proposed
rulemaking (REG–100905–97, 1999–22
I.R.B. 10 [64 F.R. 27221]) intending to
eliminate the regulatory requirement that
certain information be set forth on the face
of a certificate representing a CDO or
REMIC regular interest.
The public hearing scheduled for Sep-
tember 13, 1999, was canceled because no
one requested to speak, and the only written
comment received supports finalizing the
regulations in the form proposed. This
Treasury decision, therefore, adopts the
proposed regulations with no change.
Special Analyses
It has been determined that this Treasury
decision is not a significant regulatory ac-
tion as defined in Executive Order 12866.
Therefore, a regulatory assessment is not
required. It has also been determined that
section 553(b) of the Administrative Proce-
dure Act (5 U.S.C. chapter 5) does not
apply to these regulations, and, because the
regulations do not impose a collection of
information on small entities, the Regula-
tory Flexibility Act (5 U.S.C. chapter 6)
does not apply. Pursuant to section 7805(f)
of the Internal Revenue Code, the notice of
proposed rulemaking preceding these regu-
lations was submitted to the Chief Counsel
for Advocacy of the Small Business Ad-
ministration for comment on its impact on
small business.
Drafting Information
The principal author of these regula-
tions is Kenneth Christman, Office of As-
sistant Chief Counsel (Financial Institu-
tions and Products). However, other
personnel from the IRS and Treasury De-
partment participated in their develop-
ment.
* * * * *
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR part 1 is amended
as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 continues to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
§1.6049–7 [Amended]
Par. 2. In §1.6049–7, paragraph (g) is
removed.
John M. Dalrymple,
Acting Deputy Commissioner
of Internal Revenue.
Approved June 1, 2000.
Jonathan Talisman,
Deputy Assistant Secretary
of the Treasury.
(Filed by the Office of the Federal Register on June
15, 2000, 8:45 a.m., and published in the issue of the
Federal Register for June 16, 2000, 65 F.R. 37701)
Section 7520.—Valuation Tables
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of July 2000. See Rev. Rul. 2000–32, page 1.
26 CFR Section 20.7520–1.—Valuation of annuities,
unitrust interests, interests for life or terms of years,
and remainder or reversionary interests.
T.D. 8886
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Parts 1, 20, and 25

Use of Actuarial Tables in
Valuing Annuities, Interests for
Life or Terms of Years, and
Remainder or Reversionary
Interests
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations.
SUMMARY: This document contains
final regulations relating to the use of ac-
tuarial tables in valuing annuities, inter-
ests for life or terms of years, and remain-
der or reversionary interests. These
regulations will effect the valuation of
inter vivos and testamentary transfers of
interests dependent on one or more mea-
suring lives. Section 7520 of the Internal
Revenue Code of 1986 (Code) was en-
acted by section 5031 of the Technical
and Miscellaneous Revenue Act of 1988
and was effective on May 1, 1989. These
regulations are necessary because section
7520(c)(3) directs the Secretary to revise
the actuarial tables used in valuing inter-
ests dependent on mortality experience
not less frequently than once each 10
years to take into account the most recent
mortality experience available as of the
time of the revision. This document con-
tains amendments to the regulations revis-
ing certain tables used for the valuation of
partial interests in property under section
7520 to reflect the most recent mortality
experience available.
DATES: These regulations are effective
June 12, 2000.
FOR FURTHER INFORMATION CON-
TACT: William L. Blodgett, (202) 622-
3090 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
On April 30, 1999, the IRS published in
the Federal Register(T.D. 8819,
1999–20 I.R.B. 5 [64 F.R. 23187 and 64
F.R. 23245]) temporary regulations and a
notice of proposed rulemaking by cross
reference to temporary regulations
(REG–103851–99, 1999–20, I.R.B. 93)
under sections 642, 664, 2031, 2512, and
7520 relating to the use of actuarial tables
in valuing annuities, interests for life or
terms of years, and remainder or rever-
sionary interests. No written comments
responding to the notice of proposed rule-
making by cross reference to temporary
regulations were received and, thus, no
hearing was held. This document adopts,
with no substantive changes, final regula-
tions with respect to this notice of pro-
posed rulemaking by cross reference to
temporary regulations.
The following chart summarizes the
applicable interest rates and the citations
to textual materials and tables for the var-
ious periods covered under the regula-
tions:
July 3, 200042000–27 I.R.B.
Cross Reference to Regulation Sections
ValuationInterestRegulation
PeriodRateSectionTable
Section 642:
Valuation, in general-1.642(c)–6
before 01/01/524%1.642(c)–6A(a)
01/01/52 - 12/31/703.5%1.642(c)–6A(b)
01/01/71 - 11/30/836%1.642(c)–6A(c)
12/01/83 - 04/30/8910%1.642(c)–6A(d)Table G
05/01/89 - 04/30/99§75201.642(c)–6A(e)Table S (05/01/89 - 4/30/99)
after 04/30/99§75201.642(c)–6(e)Table S (after 04/30/99)
Section 664:
Valuation, in general-1.664–4
before 01/01/524%1.664–4A(a)
01/01/52 - 12/31/703.5%1.664–4A(b)
01/01/71 - 11/30/836%1.664–4A(c)
12/01/83 - 04/30/8910%1.664–4A(d)Table E, Table F(1)
05/01/89 - 04/30/99§75201.664–4A(e)Table U(1) (05/01/89 - 4/30/99)
after 04/30/99§75201.664–4(e)(6)Table D and
Tables F(4.2) – F(14.0)
1.664–4(e)(7)Table U(1) (after 04/30/99)
Section 2031:
Valuation, in general-20.2031–7
before 01/01/524%20.2031–7A(a)
01/01/52 - 12/31/703.5%20.2031–7A(b)
01/01/71 - 11/30/836%20.2031–7A(c)
12/01/83 - 04/30/8910%20.2031–7A(d)Table A, Table B, Table LN
05/01/89 - 04/30/99§752020.2031–7A(e)Table S (05/01/89 - 4/30/99)
Life Table 80CNSMT

after 04/30/99§752020.2031–7(d)(6)Table B, Table J, Table K
20.2031–7(d)(7)Table S (after 04/30/99) and
Life Table 90CM
Section 2512:
Valuation, in general-25.2512–5
before 01/01/524%25.2512–5A(a)
01/01/52 - 12/31/703.5%25.2512–5A(b)
01/01/71 - 11/30/836%25.2512–5A(c)
12/01/83 - 04/30/8910%25.2512–5A(d)
05/01/89 - 04/30/99§752025.2512–5A(e)
after 04/30/99§752025.2512–5(d)
2000–27 I.R.B.5July 3, 2000
Effective Dates
These regulations are applicable in the
case of annuities, interests for life or terms
of years, and remainder or reversionary in-
terests created after April 30, 1999.
Special Analysis
It has been determined that this Treasury
decision is not a significant regulatory ac-
tion as defined in Executive Order 12866.
Therefore, a regulatory assessment is not
required. It also has been determined that
section 553(b) of the Administrative Proce-
dure Act (5 U.S.C. chapter 5) does not
apply to these regulations, and because
these regulations do not impose a collection
of information requirement on small enti-
ties, the Regulatory Flexibility Act (5
U.S.C. chapter 6) does not apply. There-
fore, a Regulatory Flexibility Analysis is
not required. Pursuant to section 7805(f) of
the Internal Revenue Code, the notice of
proposed rulemaking by cross reference to
temporary regulations was submitted to the
Chief Counsel for Advocacy of the Small
Business Administration for comment on
its impact on small business.
Drafting Information
The principal author of these regulations
is William L. Blodgett, Office of Assistant
Chief Counsel (Passthroughs and Special
Industries), IRS. However, other personnel
from the IRS and Treasury Department par-
ticipated in their development.
* * * * *
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR parts 1, 20, and
25 are amended as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 is amended by removing the entries
for 1.642(c)–6T, 1.664–4Tand
1.7520–1T to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 1.170A–12 is amended
by revising paragraphs (b)(2) and (b)(3)
to read as follows:
§1.170A–12 Valuation of a remainder in-
terest in real property for contributions
made after July 31, 1969.
* * * * *
(b) * * *
(2) Computation of depreciation factor.
If the valuation of the remainder interest
in depreciable property is dependent upon
the continuation of one life, a special fac-
tor must be used. The factor determined
under this paragraph (b)(2) is carried to
the fifth decimal place. The special factor
is to be computed on the basis of the inter-
est rate and life contingencies prescribed
in §20.2031–7 of this chapter (or for peri-
ods before May 1, 1999, §20.2031–7A)
and on the assumption that the property
depreciates on a straight-line basis over
its estimated useful life. For transfers for
which the valuation date is after April 30,
1999, special factors for determining the
present value of a remainder interest fol-
lowing one life and an example describ-
ing the computation is contained in Inter-
nal Revenue Service Publication 1459,
“Actuarial Values, Book Gimel,” (7-
1999). A copy of this publication is avail-
able for purchase from the Superintendent
of Documents, United States Government
Printing Office, Washington, DC 20402.
For transfers for which the valuation date
is after April 30, 1989, and before May 1,
1999, special factors for determining the
present value of a remainder interest fol-
lowing one life and an example describ-
ing the computation is contained in Inter-
nal Revenue Service Publication 1459,
“Actuarial Values, Gamma Volume,” (8-
89). This publication is no longer avail-
able for purchase from the Superintendent
of Documents. However, it may be ob-
tained by requesting a copy from:
CC:DOM:CORP:R (IRS Publication
1459), room 5226, Internal Revenue Ser-
vice, POB 7604, Ben Franklin Station,
Washington, DC 20044. See, however,
§1.7520–3(b) (relating to exceptions to
the use of prescribed tables under certain
circumstances). Otherwise, in the case of
the valuation of a remainder interest fol-
lowing one life, the special factor may be
obtained through use of the following for-
mula:
Where:
n=the estimated number of years of useful
life,
i=the applicable interest rate under sec-
tion 7520 of the Internal Revenue Code,
v=1 divided by the sum of 1 plus the ap-
plicable interest rate under section
7520 of the Internal Revenue Code,
x=the age of the life tenant, and
lx=number of persons living at age x as
set forth in Table 90CM of
§20.2031–7 (or, for periods before
May 1, 1999, the tables set forth under
§20.2031–7A) of this chapter.
(3) Example. The following example
illustrates the provisions of this paragraph
(b):
Example. A, who is 62, donates to Y University a
remainder interest in a personal residence, consist-

ing of a house and land, subject to a reserved life es-
tate in A. At the time of the gift, the land has a value
of $30,000 and the house has a value of $100,000
with an estimated useful life of 45 years, at the end
of which the value of the house is expected to be
$20,000. The portion of the property considered to
be depreciable is $80,000 (the value of the house
($100,000) less its expected value at the end of 45
years ($20,000)). The portion of the property con-
sidered to be nondepreciable is $50,000 (the value of
the land at the time of the gift ($30,000) plus the ex-
pected value of the house at the end of 45 years
($20,000)). At the time of the gift, the interest rate
prescribed under section 7520 is 8.4 percent. Based
on an interest rate of 8.4 percent, the remainder fac-
tor for $1.00 prescribed in §20.2031–7(d) of this
chapter for a person age 62 is 0.27925. The value of
the nondepreciable remainder interest is $13,962.50
(0.27925 times $50,000). The value of the deprecia-
ble remainder interest is $16,148.80 (0.20186, com-
puted under the formula described in paragraph
(b)(2) of this section, times $80,000). Therefore, the
value of the remainder interest is $30,111.30.
* * * * *
§1.170A–12T [Removed]
Par. 3. Section 1.170A–12T is re-
moved.
Par. 4. -5. Section 1.642(c)–6 is
amended by revising paragraphs (d), (e)
and (f) to read as follows:
§1.642(c)–6 Valuation of a remainder in-
terest in property transferred to a pooled
income fund.
* * * * *
(d) Valuation. The present value of the
remainder interest in property transferred
to a pooled income fund after April 30,
1999, is determined under paragraph (e)
of this section. The present value of the
remainder interest in property transferred
to a pooled income fund for which the
valuation date is before May 1, 1999, is
determined under the following sections:
July 3, 200062000–27 I.R.B.
Valuation DatesApplicable
AfterBeforeRegulations
01-01-521.642(c)–6A(a)
12-31-5101-01-711.642(c)–6A(b)
12-31-7012-01-831.642(c)–6A(c)
11-30-8305-01-891.642(c)–6A(d)
04-30-8905-01-991.642(c)–6A(e)
(e) Present value of the remainder in-
terest in the case of transfers to pooled in-
come funds for which the valuation date is
after April 30, 1999—(1)In general. In
the case of transfers to pooled income
funds for which the valuation date is after
April 30, 1999, the present value of a re-
mainder interest is determined under this
section. See, however, §1.7520–3(b) (re-
lating to exceptions to the use of pre-
scribed tables under certain circum-
stances). The present value of a
remainder interest that is dependent on
the termination of the life of one individ-
ual is computed by the use of Table S in
paragraph (e)(6) of this section. For pur-
poses of the computations under this sec-
tion, the age of an individual is the age at
the individual’s nearest birthday.
(2) Transitional rules for valuation of
transfers to pooled income funds. (i) For
purposes of sections 2055, 2106, or 2624,
if on May 1, 1999, the decedent was men-
tally incompetent so that the disposition
of the property could not be changed, and
the decedent died after April 30, 1999,
without having regained competency to
dispose of the decedent’s property, or the
decedent died within 90 days of the date
that the decedent first regained compe-
tency after April 30, 1999, the present
value of a remainder interest is deter-
mined as if the valuation date with respect
to the decedent’s gross estate is either be-
fore May 1, 1999, or after April 30, 1999,
at the option of the decedent’s executor.
(ii) For purposes of sections 170, 2055,
2106, 2522, or 2624, in the case of trans-
fers to a pooled income fund for which
the valuation date is after April 30, 1999,
and before July 1, 1999, the present value
of the remainder interest under this sec-
tion is determined by use of the section
7520 interest rate for the month in which
the valuation date occurs (see
§§1.7520–1(b) and 1.7520–2(a)(2)) and
the appropriate actuarial tables under ei-
ther paragraph (e)(6) of this section or
§1.642(c)–6A(e)(5), at the option of the
donor or the decedent’s executor, as the
case may be.
(iii) For purposes of paragraphs
(e)(2)(i) and (ii) of this section, where the
donor or decedent’s executor is given the
option to use the appropriate actuarial ta-
bles under either paragraph (e)(6) of this
section or §1.642(c)–6A(e)(5), the donor
or decedent’s executor must use the same
actuarial table with respect to each indi-
vidual transaction and with respect to all
transfers occurring on the valuation date
(for example, gift and income tax charita-
ble deductions with respect to the same
transfer must be determined based on the
same tables, and all assets includible in
the gross estate and/or estate tax deduc-
tions claimed must be valued based on the
same tables).
(3) Present value of a remainder inter-
est. The present value of a remainder in-
terest in property transferred to a pooled
income fund is computed on the basis
of—
(i) Life contingencies determined from
the values of lxthat are set forth in Table
90CM in §20.2031–7(d)(7) of this chapter
(see § 20.2031–7A of this chapter for cer-
tain prior periods); and
(ii) Discount at a rate of interest, com-
pounded annually, equal to the highest
yearly rate of return of the pooled income
fund for the 3 taxable years immediately
preceding its taxable year in which the
transfer of property to the fund is made.
For purposes of this paragraph (e), the
yearly rate of return of a pooled income
fund is determined as provided in para-
graph (c) of this section unless the highest
rate of return is deemed to be the rate de-
scribed in paragraph (e)(4) of this section
for funds in existence less than 3 taxable
years. For purposes of this paragraph
(e)(3)(ii), the first taxable year of a pooled
income fund is considered a taxable year
even though the taxable year consists of
less than 12 months. However, appropri-

ate adjustments must be made to annual-
ize the rate of return earned by the fund
for that period. Where it appears from the
facts and circumstances that the highest
yearly rate of return of the fund for the 3
taxable years immediately preceding the
taxable year in which the transfer of prop-
erty is made has been purposely manipu-
lated to be substantially less than the rate
of return that would otherwise be reason-
ably anticipated with the purpose of ob-
taining an excessive charitable deduction,
that rate of return may not be used. In
that case, the highest yearly rate of return
of the fund is determined by treating the
fund as a pooled income fund that has
been in existence for less than 3 preceding
taxable years.
(4) Pooled income funds in existence
less than 3 taxable years. If a pooled in-
come fund has been in existence less than
3 taxable years immediately preceding the
taxable year in which the transfer is made
to the fund and the transfer to the fund is
made after April 30, 1989, the highest rate
of return is deemed to be the interest rate
(rounded to the nearest two-tenths of one
percent) that is 1 percent less than the
highest annual average of the monthly
section 7520 rates for the 3 calendar years
immediately preceding the calendar year
in which the transfer to the pooled income
fund is made. The deemed rate of return
for transfers to new pooled income funds
is recomputed each calendar year using
the monthly section 7520 rates for the 3-
year period immediately preceding the
calendar year in which each transfer to the
fund is made until the fund has been in
existence for 3 taxable years and can
compute its highest rate of return for the 3
taxable years immediately preceding the
taxable year in which the transfer of prop-
erty to the fund is made in accordance
with the rules set forth in the first sen-
tence of paragraph (e)(3)(ii) of this sec-
tion.
(5) Computation of value of remainder
interest. The factor that is used in deter-
mining the present value of a remainder
interest that is dependent on the termina-
tion of the life of one individual is the fac-
tor from Table S in paragraph (e)(6) of
this section under the appropriate yearly
rate of return opposite the number that
corresponds to the age of the individual
upon whose life the value of the remain-
der interest is based (see §1.642(c)–6A
for certain prior periods). The tables in
paragraph (e)(6) of this section include
factors for yearly rates of return from 4.2
to 14 percent. Many actuarial factors not
contained in the tables in paragraph (e)(6)
of this section are contained in Table S in
Internal Revenue Service Publication
1457, “Actuarial Values, Book Aleph,”
(7-1999). A copy of this publication is
available for purchase from the Superin-
tendent of Documents, United States
Government Printing Office, Washington,
DC 20402. For other situations, see para-
graph (b) of this section. If the yearly rate
of return is a percentage that is between
the yearly rates of return for which factors
are provided, a linear interpolation must
be made. The present value of the re-
mainder interest is determined by multi-
plying the fair market value of the prop-
erty on the valuation date by the appropri-
ate remainder factor. This paragraph
(e)(5) may be illustrated by the following
example:
Example. A, who is 54 years and 8 months,
transfers $100,000 to a pooled income fund, and re-
tains a life income interest in the property. The
highest yearly rate of return earned by the fund for
its 3 preceding taxable years is 9.47 percent. In
Table S, the remainder factor opposite 55 years
under 9.4 percent is .17449 and under 9.6 percent is
.17001. The present value of the remainder interest
is $17,292.00, computed as follows:
Factor at 9.4 percent for age 55 . . . . . .17449
Factor at 9.6 percent for age 55 . . . . . . .17001
Difference . . . . . . . . . . . . . . . . . . . . . . .00448
Interpolation adjustment:
9.47% - 9.4%=x
0.2%.00448
x = .00157
Factor at 9.4 percent for age 55 . . . . . . . .17449
Less: Interpolation adjustment. . . . . . . .00157
Interpolated factor. . . . . . . . . . . . . . . . . .17292
Present value of remainder interest:
($100,000 X .17292) . . . . . . . . . $17,292.00
(6) Actuarial tables. In the case of
transfers for which the valuation date is
after April 30, 1999, the present value of a
remainder interest dependent on the ter-
mination of one life in the case of a trans-
fer to a pooled income fund is determined
by use of the following Table S:
2000–27 I.R.B.7July 3, 2000
TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0%
0.06752.06130.05586.05109.04691.04322.03998.03711.03458.03233
1.06137.05495.04932.04438.04003.03620.03283.02985.02721.02487
2.06325.05667.05088.04580.04132.03737.03388.03079.02806.02563
3.06545.05869.05275.04752.04291.03883.03523.03203.02920.02668
4.06784.06092.05482.04944.04469.04048.03676.03346.03052.02791
5.07040.06331.05705.05152.04662.04229.03845.03503.03199.02928
6.07310.06583.05941.05372.04869.04422.04025.03672.03357.03076
7.07594.06849.06191.05607.05089.04628.04219.03854.03528.03236
8.07891.07129.06453.05853.05321.04846.04424.04046.03709.03407
9.08203.07423.06731.06115.05567.05079.04643.04253.03904.03592

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0%
10.08532.07734.07024.06392.05829.05326.04877.04474.04114.03790
11.08875.08059.07331.06683.06104.05587.05124.04709.04336.04002
12.09233.08398.07653.06989.06394.05862.05385.04957.04572.04226
13.09601.08748.07985.07304.06693.06146.05655.05214.04816.04458
14.09974.09102.08322.07624.06997.06435.05929.05474.05064.04694
15.10350.09460.08661.07946.07303.06725.06204.05735.05312.04930
16.10728.09818.09001.08268.07608.07014.06479.05996.05559.05164
17.11108.10179.09344.08592.07916.07306.06755.06257.05807.05399
18.11494.10545.09691.08921.08227.07601.07034.06521.06057.05636
19.11889.10921.10047.09259.08548.07904.07322.06794.06315.05880
20.12298.11310.10417.09610.08881.08220.07622.07078.06584.06135
21.12722.11713.10801.09976.09228.08550.07935.07375.06866.06403
22.13159.12130.11199.10354.09588.08893.08260.07685.07160.06682
23.13613.12563.11612.10748.09964.09250.08601.08009.07468.06975
24.14084.13014.12043.11160.10357.09625.08958.08349.07793.07284
25.14574.13484.12493.11591.10768.10018.09334.08708.08135.07611
26.15084.13974.12963.12041.11199.10431.09728.09085.08496.07956
27.15615.14485.13454.12513.11652.10865.10144.09484.08878.08322
28.16166.15016.13965.13004.12124.11319.10580.09901.09279.08706
29.16737.15567.14497.13516.12617.11792.11035.10339.09699.09109
30.17328.16138.15048.14047.13129.12286.11510.10796.10138.09532
31.17938.16728.15618.14599.13661.12799.12004.11272.10597.09974
32.18568.17339.16210.15171.14214.13333.12520.11769.11076.10435
33.19220.17972.16824.15766.14790.13889.13058.12289.11578.10920
34.19894.18627.17460.16383.15388.14468.13618.12831.12102.11426
35.20592.19307.18121.17025.16011.15073.14204.13399.12652.11958
36.21312.20010.18805.17691.16658.15701.14814.13990.13225.12514
37.22057.20737.19514.18382.17331.16356.15450.14608.13825.13096
38.22827.21490.20251.19100.18031.17038.16113.15253.14452.13705
39.23623.22270.21013.19845.18759.17747.16805.15927.15108.14344
40.24446.23078.21805.20620.19516.18487.17527.16631.15795.15013
41.25298.23915.22626.21425.20305.19259.18282.17368.16514.15715
42.26178.24782.23478.22262.21125.20062.19069.18138.17267.16450
43.27087.25678.24360.23129.21977.20898.19888.18941.18053.17220
44.28025.26603.25273.24027.22860.21766.20740.19777.18873.18023
45.28987.27555.26212.24953.23772.22664.21622.20644.19724.18858
46.29976.28533.27179.25908.24714.23591.22536.21542.20606.19725
47.30987.29535.28171.26889.25682.24546.23476.22468.21518.20621
48.32023.30563.29190.27897.26678.25530.24447.23425.22460.21549
49.33082.31615.30234.28931.27702.26543.25447.24412.23434.22509
50.34166.32694.31306.29995.28756.27586.26479.25432.24441.23502
51.35274.33798.32404.31085.29838.28658.27541.26482.25479.24528
52.36402.34924.33525.32200.30946.29757.28630.27561.26547.25584
53.37550.36070.34668.33339.32078.30882.29746.28667.27643.26669
54.38717.37237.35833.34500.33234.32031.30888.29801.28766.27782
July 3, 200082000–27 I.R.B.

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0%
55.39903.38424.37019.35683.34413.33205.32056.30961.29918.28925
56.41108.39631.38227.36890.35617.34405.33250.32149.31099.30097
57.42330.40857.39455.38118.36844.35629.34469.33363.32306.31297
58.43566.42098.40699.39364.38089.36873.35710.34600.33538.32522
59.44811.43351.41956.40623.39350.38133.36968.35855.34789.33768
60.46066.44613.43224.41896.40624.39408.38243.37127.36058.35033
61.47330.45887.44505.43182.41914.40699.39535.38418.37347.36318
62.48608.47175.45802.44485.43223.42011.40848.39732.38660.37629
63.49898.48478.47115.45807.44550.43343.42184.41069.39997.38966
64.51200.49793.48442.47143.45895.44694.43539.42427.41357.40326
65.52512.51121.49782.48495.47255.46062.44912.43805.42738.41709
66.53835.52461.51137.49862.48634.47449.46307.45206.44143.43118
67.55174.53818.52511.51250.50034.48860.47727.46633.45576.44556
68.56524.55188.53899.52654.51452.50291.49168.48083.47034.46020
69.57882.56568.55299.54071.52885.51737.50627.49552.48513.47506
70.59242.57951.56703.55495.54325.53193.52096.51034.50004.49007
71.60598.59332.58106.56918.55767.54651.53569.52520.51503.50516
72.61948.60707.59504.58338.57206.56108.55043.54009.53004.52029
73.63287.62073.60895.59751.58640.57561.56513.55495.54505.53543
74.64621.63435.62282.61162.60073.59015.57985.56984.56009.55061
75.65953.64796.63671.62575.61510.60473.59463.58480.57523.56591
76.67287.66160.65063.63995.62954.61940.60952.59989.59050.58135
77.68622.67526.66459.65419.64404.63415.62450.61509.60590.59694
78.69954.68892.67856.66845.65858.64895.63955.63036.62140.61264
79.71278.70250.69246.68265.67308.66372.65457.64563.63690.62836
80.72581.71588.70618.69668.68740.67833.66945.66077.65227.64396
81.73857.72899.71962.71045.70147.69268.68408.67566.66741.65933
82.75101.74178.73274.72389.71522.70672.69840.69024.68225.67441
83.76311.75423.74553.73700.72864.72044.71240.70451.69678.68919
84.77497.76645.75809.74988.74183.73393.72618.71857.71110.70377
85.78665.77848.77047.76260.75487.74728.73982.73250.72530.71823
86.79805.79025.78258.77504.76764.76036.75320.74617.73925.73245
87.80904.80159.79427.78706.77998.77301.76615.75940.75277.74624
88.81962.81251.80552.79865.79188.78521.77865.77220.76584.75958
89.82978.82302.81636.80980.80335.79699.79072.78455.77847.77248
90.83952.83309.82676.82052.81437.80831.80234.79645.79064.78492
91.84870.84260.83658.83064.82479.81902.81332.80771.80217.79671
92.85716.85136.84563.83998.83441.82891.82348.81812.81283.80761
93.86494.85942.85396.84858.84326.83801.83283.82771.82266.81767
94.87216.86690.86170.85657.85149.84648.84153.83664.83181.82704
95.87898.87397.86902.86412.85928.85450.84977.84510.84049.83592
96.88537.88060.87587.87121.86659.86203.85751.85305.84864.84427
97.89127.88672.88221.87775.87335.86898.86467.86040.85618.85200
98.89680.89245.88815.88389.87968.87551.87138.86730.86326.85926
99.90217.89803.89393.88987.88585.88187.87793.87402.87016.86633
2000–27 I.R.B.9July 3, 2000

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0%
100.90738.90344.89953.89567.89183.88804.88428.88056.87687.87322
101.91250.90876.90504.90137.89772.89412.89054.88699.88348.88000
102.91751.91396.91045.90696.90350.90007.89668.89331.88997.88666
103.92247.91912.91579.91249.90922.90598.90276.89957.89640.89326
104.92775.92460.92148.91839.91532.91227.90924.90624.90326.90031
105.93290.92996.92704.92415.92127.91841.91558.91276.90997.90719
106.93948.93680.93415.93151.92889.92628.92370.92113.91857.91604
107.94739.94504.94271.94039.93808.93579.93351.93124.92899.92675
108.95950.95767.95585.95404.95224.95045.94867.94689.94512.94336
109.97985.97893.97801.97710.97619.97529.97438.97348.97259.97170
July 3, 2000102000–27 I.R.B.
TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0%
0.03034.02857.02700.02559.02433.02321.02220.02129.02047.01973
1.02279.02094.01929.01782.01650.01533.01427.01331.01246.01168
2.02347.02155.01983.01829.01692.01569.01458.01358.01268.01187
3.02444.02243.02065.01905.01761.01632.01516.01412.01317.01232
4.02558.02349.02163.01996.01846.01712.01590.01481.01382.01292
5.02686.02469.02275.02101.01945.01804.01677.01562.01458.01364
6.02825.02600.02398.02217.02053.01906.01773.01653.01544.01445
7.02976.02742.02532.02343.02172.02019.01880.01754.01640.01536
8.03137.02894.02675.02479.02301.02140.01995.01864.01744.01635
9.03311.03059.02832.02627.02442.02274.02122.01985.01859.01745
10.03499.03237.03001.02788.02595.02420.02262.02118.01987.01867
11.03700.03428.03183.02961.02760.02578.02413.02262.02125.02000
12.03913.03632.03377.03146.02937.02748.02575.02418.02275.02144
13.04135.03843.03579.03339.03122.02924.02744.02580.02431.02294
14.04359.04057.03783.03534.03308.03102.02915.02744.02587.02444
15.04584.04270.03986.03728.03493.03279.03083.02905.02742.02593
16.04806.04482.04187.03919.03674.03452.03248.03063.02892.02736
17.05029.04692.04387.04108.03855.03623.03411.03218.03040.02877
18.05253.04905.04588.04299.04036.03795.03574.03373.03187.03017
19.05484.05124.04796.04496.04222.03972.03742.03532.03339.03161
20.05726.05354.05013.04702.04418.04158.03919.03700.03498.03313
21.05980.05595.05242.04920.04625.04354.04105.03877.03667.03473
22.06246.05847.05482.05147.04841.04559.04301.04063.03844.03642
23.06524.06112.05734.05387.05069.04777.04508.04260.04032.03821
24.06819.06392.06001.05642.05312.05008.04728.04470.04232.04012

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0%
25.07131.06690.06285.05913.05570.05255.04964.04695.04447.04218
26.07460.07005.06586.06200.05845.05518.05215.04936.04677.04438
27.07810.07340.06907.06508.06140.05800.05485.05195.04925.04676
28.08179.07693.07246.06833.06451.06098.05772.05469.05189.04929
29.08566.08065.07603.07176.06780.06414.06075.05761.05469.05198
30.08973.08456.07978.07536.07127.06748.06396.06069.05766.05483
31.09398.08865.08372.07915.07491.07098.06733.06394.06078.05785
32.09843.09294.08785.08313.07875.07468.07089.06737.06409.06103
33.10310.09745.09220.08732.08279.07858.07466.07100.06759.06441
34.10799.10217.09676.09173.08705.08269.07862.07483.07129.06798
35.11314.10715.10157.09638.09155.08704.08283.07890.07522.07179
36.11852.11236.10662.10127.09628.09162.08726.08319.07938.07581
37.12416.11783.11193.10641.10126.09645.09194.08772.08377.08006
38.13009.12359.11751.11183.10652.10155.09689.09253.08843.08459
39.13629.12962.12338.11753.11206.10693.10212.09761.09337.08938
40.14281.13597.12955.12355.11791.11262.10766.10299.09860.09447
41.14966.14264.13606.12989.12409.11864.11352.10870.10417.09989
42.15685.14966.14291.13657.13061.12500.11972.11475.11006.10564
43.16437.15702.15010.14360.13747.13171.12627.12115.11631.11174
44.17224.16472.15764.15098.14469.13876.13317.12789.12290.11819
45.18042.17274.16550.15867.15223.14615.14040.13496.12982.12496
46.18893.18110.17370.16671.16011.15387.14796.14238.13708.13207
47.19775.18975.18220.17505.16830.16190.15584.15010.14466.13950
48.20688.19873.19102.18373.17682.17027.16406.15817.15258.14727
49.21633.20804.20018.19274.18568.17898.17262.16658.16084.15539
50.22612.21769.20969.20210.19490.18805.18155.17536.16948.16388
51.23625.22769.21955.21182.20448.19749.19084.18452.17849.17275
52.24669.23799.22973.22186.21438.20726.20047.19400.18784.18196
53.25742.24861.24022.23222.22461.21735.21043.20383.19753.19151
54.26845.25952.25101.24290.23516.22777.22072.21399.20756.20140
55.27978.27074.26212.25389.24604.23853.23136.22450.21793.21166
56.29140.28227.27355.26522.25725.24963.24233.23535.22867.22227
57.30333.29411.28529.27686.26879.26106.25365.24656.23976.23324
58.31551.30621.29731.28878.28061.27278.26528.25807.25116.24453
59.32790.31854.30956.30095.29269.28477.27716.26986.26284.25610
60.34050.33107.32202.31334.30500.29699.28929.28190.27478.26794
61.35331.34384.33473.32598.31757.30948.30170.29422.28701.28007
62.36639.35688.34772.33892.33044.32229.31443.30687.29958.29255
63.37974.37020.36101.35216.34363.33542.32750.31986.31250.30539
64.39334.38378.37456.36568.35711.34884.34087.33317.32574.31857
65.40718.39761.38838.37947.37087.36257.35455.34681.33932.33208
66.42128.41172.40249.39357.38496.37663.36858.36079.35326.34597
67.43569.42616.41694.40803.39941.39107.38299.37518.36761.36028
68.45038.44089.43170.42281.41419.40585.39777.38994.38235.37499
69.46531.45587.44672.43786.42927.42094.41286.40503.39743.39006
2000–27 I.R.B.11July 3, 2000

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0%
70.48040.47103.46194.45312.44456.43626.42820.42038.41278.40540
71.49558.48629.47727.46851.46000.45174.44371.43591.42832.42095
72.51082.50162.49268.48399.47554.46733.45934.45157.44401.43666
73.52607.51697.50813.49952.49114.48299.47506.46733.45981.45249
74.54139.53241.52367.51515.50686.49879.49092.48325.47578.46849
75.55683.54798.53936.53095.52276.51477.50698.49938.49197.48474
76.57243.56373.55524.54696.53888.53100.52330.51579.50846.50130
77.58819.57965.57132.56318.55523.54747.53988.53247.52523.51815
78.60408.59572.58755.57957.57177.56414.55668.54939.54225.53527
79.62001.61184.60385.59604.58840.58092.57360.56644.55943.55256
80.63582.62786.62007.61244.60497.59765.59048.58347.57659.56985
81.65142.64367.63608.62864.62135.61421.60721.60034.59361.58701
82.66673.65920.65182.64458.63748.63052.62368.61698.61041.60395
83.68175.67444.66728.66024.65334.64656.63991.63338.62696.62066
84.69657.68950.68256.67574.66904.66246.65599.64964.64340.63727
85.71128.70446.69775.69116.68467.67830.67204.66587.65982.65386
86.72576.71919.71272.70636.70010.69394.68789.68193.67606.67029
87.73981.73349.72726.72114.71511.70917.70333.69757.69190.68632
88.75342.74735.74137.73548.72968.72396.71833.71279.70732.70194
89.76658.76076.75503.74938.74381.73832.73290.72757.72231.71712
90.77928.77371.76823.76281.75748.75221.74702.74190.73684.73186
91.79131.78600.78075.77557.77046.76542.76044.75553.75068.74589
92.80246.79737.79235.78740.78250.77767.77290.76818.76353.75893
93.81274.80788.80307.79832.79363.78899.78441.77989.77542.77100
94.82232.81766.81306.80850.80401.79956.79517.79082.78653.78228
95.83141.82695.82254.81818.81387.80961.80539.80122.79710.79302
96.83996.83569.83147.82729.82316.81907.81503.81103.80707.80315
97.84787.84378.83973.83573.83176.82784.82396.82012.81632.81255
98.85530.85138.84750.84366.83985.83609.83236.82867.82502.82140
99.86255.85880.85508.85140.84776.84415.84057.83703.83353.83005
100.86960.86601.86246.85894.85546.85200.84858.84519.84183.83849
101.87655.87313.86974.86638.86305.85975.85648.85324.85003.84684
102.88338.88012.87689.87369.87052.86738.86426.86116.85809.85505
103.89015.88706.88399.88095.87793.87494.87197.86903.86611.86321
104.89737.89446.89157.88871.88586.88304.88024.87745.87469.87195
105.90443.90170.89898.89628.89360.89094.88830.88568.88307.88049
106.91351.91101.90852.90605.90359.90115.89873.89632.89392.89154
107.92452.92230.92010.91791.91573.91356.91141.90927.90714.90502
108.94161.93987.93814.93641.93469.93298.93128.92958.92790.92622
109.97081.96992.96904.96816.96729.96642.96555.96468.96382.96296
July 3, 2000122000–27 I.R.B.

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0%
0.01906.01845.01790.01740.01694.01652.01613.01578.01546.01516
1.01098.01034.00977.00924.00876.00833.00793.00756.00722.00691
2.01113.01046.00986.00930.00880.00834.00791.00753.00717.00684
3.01155.01084.01020.00962.00909.00860.00816.00775.00737.00702
4.01211.01137.01069.01008.00952.00900.00853.00810.00770.00733
5.01279.01201.01130.01065.01006.00952.00902.00856.00814.00775
6.01356.01274.01199.01131.01068.01011.00959.00910.00865.00824
7.01442.01356.01277.01205.01140.01079.01023.00972.00925.00881
8.01536.01446.01363.01287.01218.01154.01096.01041.00991.00945
9.01641.01546.01460.01380.01307.01240.01178.01120.01068.01019
10.01758.01659.01567.01484.01407.01336.01270.01210.01154.01103
11.01886.01781.01686.01598.01517.01442.01373.01310.01251.01196
12.02024.01915.01814.01721.01636.01558.01485.01419.01357.01299
13.02168.02054.01948.01851.01762.01679.01603.01533.01467.01407
14.02313.02193.02083.01981.01887.01801.01721.01646.01578.01514
15.02456.02330.02214.02107.02009.01918.01834.01756.01684.01617
16.02593.02462.02340.02229.02126.02030.01942.01860.01785.01714
17.02728.02590.02463.02346.02238.02138.02046.01960.01880.01806
18.02861.02717.02584.02462.02348.02243.02146.02056.01972.01894
19.02998.02847.02708.02580.02461.02351.02249.02154.02066.01984
20.03142.02984.02839.02704.02580.02465.02357.02258.02165.02079
21.03295.03130.02978.02837.02706.02585.02473.02368.02271.02180
22.03455.03283.03124.02976.02839.02712.02594.02484.02382.02286
23.03626.03446.03279.03124.02981.02847.02723.02608.02500.02400
24.03809.03620.03446.03283.03133.02993.02863.02741.02628.02522
25.04005.03808.03625.03456.03298.03151.03014.02887.02768.02656
26.04216.04010.03819.03641.03476.03322.03178.03044.02919.02802
27.04444.04229.04029.03843.03670.03508.03357.03217.03085.02962
28.04687.04463.04254.04059.03877.03708.03550.03402.03263.03133
29.04946.04712.04493.04289.04099.03922.03756.03600.03455.03318
30.05221.04976.04748.04534.04335.04149.03975.03812.03659.03515
31.05511.05255.05017.04794.04585.04390.04208.04037.03876.03725
32.05818.05551.05302.05069.04851.04647.04455.04276.04107.03948
33.06144.05866.05606.05363.05135.04921.04720.04532.04355.04188
34.06489.06200.05928.05674.05436.05212.05002.04805.04619.04444
35.06857.06555.06273.06007.05758.05524.05304.05097.04902.04718
36.07246.06932.06638.06361.06101.05856.05626.05409.05205.05012
37.07659.07332.07025.06737.06466.06210.05969.05742.05528.05325
38.08098.07758.07439.07138.06855.06588.06336.06099.05874.05662
39.08563.08210.07878.07565.07270.06992.06729.06480.06245.06023
40.09059.08692.08347.08021.07714.07423.07149.06889.06643.06411
41.09586.09206.08848.08509.08189.07886.07600.07329.07072.06828
42.10147.09753.09381.09029.08696.08381.08083.07800.07531.07277
43.10742.10334.09948.09583.09237.08909.08598.08304.08024.07758
44.11373.10950.10551.10172.09813.09472.09148.08841.08549.08272
2000–27 I.R.B.13July 3, 2000

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0%
45.12035.11599.11185.10792.10420.10066.09730.09410.09106.08817
46.12732.12281.11853.11447.11061.10694.10345.10013.09696.09395
47.13460.12995.12553.12133.11733.11353.10991.10646.10317.10004
48.14223.13743.13287.12853.12439.12046.11671.11313.10972.10646
49.15020.14526.14056.13608.13181.12774.12385.12015.11661.11322
50.15855.15347.14862.14401.13960.13540.13138.12754.12388.12037
51.16727.16205.15707.15232.14777.14344.13929.13532.13153.12789
52.17634.17098.16587.16097.15630.15183.14755.14345.13953.13577
53.18576 .18027.17501.16999.16518.16057.15616.15194.14789.14400
54.19552.18990.18451.17935.17441.16968.16514.16078.15661.15260
55.20564.19989.19437.18908.18402.17915.17449.17001.16571.16157
56.21613.21025.20461.19919.19400.18901.18422.17962.17519.17093
57.22698.22098.21522.20968.20436.19925.19434.18961.18507.18069
58.23816.23204.22616.22051.21507.20984.20481.19996.19530.19080
59.24962.24339.23740.23163.22608.22073.21558.21062.20584.20123
60.26136.25502.24892.24304.23738.23192.22666.22158.21669.21196
61.27339.26695.26075.25477.24900.24343.23806.23288.22787.22304
62.28578.27925.27295.26687.26100.25533.24985.24456.23945.23451
63.29854.29192.28553.27935.27339.26762.26205.25666.25145.24641
64.31164.30494.29846.29221.28615.28030.27463.26915.26384.25870
65.32508.31831.31177.30543.29930.29336.28761.28203.27663.27140
66.33891.33208.32547.31906.31285.30684.30101.29536.28987.28456
67.35318.34630.33963.33316.32689.32081.31491.30918.30363.29823
68.36785.36093.35422.34770.34138.33524.32928.32349.31787.31240
69.38290.37595.36920.36265.35628.35009.34408.33824.33256.32703
70.39823.39127.38450.37791.37151.36529.35924.35335.34762.34204
71.41378.40681.40003.39343.38701.38076.37467.36875.36298.35736
72.42950.42253.41575.40914.40271.39644.39034.38438.37858.37293
73.44535.43840.43162.42502.41858.41231.40619.40022.39440.38872
74.46139.45446.44771.44112.43469.42842.42230.41632.41049.40479
75.47769.47080.46408.45752.45111.44485.43874.43277.42693.42123
76.49430.48747.48079.47427.46790.46167.45558.44963.44380.43811
77.51123.50447.49786.49139.48506.47888.47282.46690.46111.45543
78.52845 .52177.51523.50884.50257.49645.49044.48457.47881.47317
79.54584.53926.53282.52650.52032.51426.50833.50251.49681.49122
80.56325.55678.55044.54423.53813.53216.52630.52056.51492.50939
81.58054.57419.56797.56186.55587.54999.54422.53856.53300.52754
82.59762.59140.58530.57931.57343.56766.56198.55641.55094.54557
83.61448.60840.60243.59657.59081.58515.57958.57411.56874.56346
84.63124.62531.61949.61376.60813.60259.59715.59179.58652.58134
85.64800.64224.63657.63099.62550.62010.61478.60955.60441.59934
86.66461.65902.65351.64810.64276.63751.63233.62724.62222.61728
87.68083.67541.67008.66483.65965.65455.64953.64458.63970.63489
88.69663.69140.68624.68116.67615.67121.66634.66154.65680.65213
89.71201.70696.70199.69708.69224.68747.68276.67811.67353.66900
July 3, 2000142000–27 I.R.B.

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0%
90.72694.72209.71730.71257.70791.70330.69876.69427.68984.68547
91.74117.73650.73190.72735.72286.71842.71404.70972.70545.70123
92.75439.74991.74548.74110.73678.73251.72829.72412.72000.71593
93.76664.76233.75806.75385.74969.74557.74150.73748.73350.72957
94.77809.77394.76983.76578.76177.75780.75388.75000.74616.74237
95.78899.78500.78106.77715.77329.76947.76569.76195.75826.75460
96.79928.79544.79165.78790.78418.78050.77686.77326.76970.76617
97.80883.80514.80149.79787.79430.79075.78725.78377.78033.77693
98.81781.81427.81075.80727.80382.80041.79703.79368.79036.78708
99.82661.82320.81982.81648.81316.80988.80662.80340.80020.79704
100.83519.83192.82868.82547.82228.81913.81600.81290.80982.80678
101.84368.84055.83744.83437.83131.82829.82529.82231.81936.81643
102.85203.84904.84607.84313.84021.83731.83444.83159.82876.82596
103.86034.85748.85465.85184.84906.84629.84355.84082.83812.83544
104.86923.86653.86385.86119.85855.85593.85333.85074.84818.84563
105.87792.87537.87283.87032.86782.86534.86287.86042.85799.85557
106.88918.88683.88450.88218.87987.87758.87530.87304.87079.86855
107.90291.90082.89873.89666.89460.89255.89051.88849.88647.88447
108.92455.92288.92123.91958.91794.91630.91468.91306.91145.90984
109.96211.96125.96041.95956.95872.95788.95704.95620.95537.95455
2000–27 I.R.B.15July 3, 2000
TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0%
0.01488.01463.01439.01417.01396.01377.01359.01343.01327.01312
1.00662.00636.00612.00589.00568.00548.00530.00513.00497.00482
2.00654.00626.00600.00576.00554.00533.00514.00496.00479.00463
3.00670.00641.00613.00588.00564.00542.00522.00502.00484.00468
4.00699.00668.00639.00612.00587.00563.00542.00521.00502.00484
5.00739.00706.00675.00646.00620.00595.00571.00550.00529.00510
6.00786.00751.00718.00687.00659.00633.00608.00585.00563.00543
7.00841.00803.00769.00736.00706.00678.00652.00627.00604.00582
8.00902.00863.00826.00791.00759.00730.00702.00675.00651.00628
9.00973.00931.00892.00856.00822.00790.00760.00733.00706.00682
10.01055.01010.00969.00930.00894.00861.00829.00799.00772.00746
11.01146.01099.01055.01014.00976.00940.00907.00875.00846.00818
12.01246.01196.01150.01106.01066.01028.00993.00960.00928.00899
13.01351.01298.01249.01204.01161.01121.01084.01049.01016.00985
14.01455.01400.01348.01300.01255.01213.01173.01136.01102.01069

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0%
15.01555.01497.01443.01392.01345.01300.01259.01220.01183.01148
16.01648.01587.01530.01477.01427.01380.01336.01295.01257.01220
17.01737.01673.01612.01556.01504.01455.01408.01365.01324.01286
18.01822.01754.01691.01632.01576.01525.01476.01430.01387.01347
19.01908.01837.01770.01708.01650.01595.01544.01495.01450.01407
20.01999.01924.01854.01788.01726.01669.01615.01564.01516.01471
21.02096.02017.01943.01874.01809.01748.01691.01637.01586.01539
22.02197.02114.02036.01963.01895.01830.01770.01713.01660.01610
23.02306.02218.02136.02059.01987.01919.01855.01795.01739.01686
24.02424.02331.02245.02163.02087.02016.01948.01885.01825.01769
25.02552.02455.02364.02278.02197.02122.02051.01984.01920.01861
26.02692.02589.02493.02403.02318.02238.02162.02091.02025.01961
27.02846.02738.02636.02541.02451.02367.02287.02212.02141.02074
28.03012.02898.02791.02690.02595.02506.02422.02342.02267.02196
29.03190.03070.02957.02851.02751.02656.02567.02483.02404.02329
30.03381.03254.03135.03023.02917.02817.02723.02634.02551.02471
31.03583.03450.03324.03206.03094.02989.02890.02796.02707.02623
32.03799.03659.03527.03402.03284.03173.03068.02968.02874.02785
33.04031.03883.03744.03612.03488.03371.03260.03155.03055.02961
34.04279.04123.03976.03838.03707.03583.03465.03354.03249.03149
35.04545.04382.04227.04081.03943.03812.03688.03571.03459.03354
36.04830.04658.04495.04341.04196.04058.03927.03803.03685.03573
37.05134.04953.04782.04620.04467.04321.04183.04052.03928.03809
38.05462.05272.05092.04921.04760.04606.04461.04322.04191.04066
39.05812.05613.05424.05245.05075.04913.04760.04614.04475.04343
40.06190.05981.05782.05594.05415.05245.05083.04929.04783.04643
41.06597.06378.06170.05972.05784.05605.05435.05272.05118.04970
42.07035.06806.06587.06380.06182.05994.05815.05644.05481.05326
43.07505.07265.07036.06818.06611.06414.06225.06045.05874.05710
44.08008.07757.07518.07290.07072.06865.06667.06478.06298.06125
45.08542.08279.08029.07791.07563.07346.07138.06940.06750.06569
46.09108.08834.08573.08324.08085.07858.07640.07432.07233.07043
47.09705.09419.09147.08886.08637.08399.08172.07954.07745.07545
48.10335.10038.09754.09482.09222.08973.08735.08507.08288.08078
49.10999.10690.10394.10111.09840.09581.09332.09093.08864.08644
50.11701.11380.11073.10778.10496.10225.09965.09716.09477.09247
51.12441.12108.11789.11482.11189.10907.10636.10376.10126.09886
52.13217.12871.12540.12222.11916.11623.11341.11071.10810.10560
53.14028.13670.13327.12997.12680.12375.12082.11801.11529.11268
54.14875.14505.14150.13808.13480.13163.12859.12566.12284.12012
55.15760.15378.15011.14657.14317.13989.13674.13370.13077.12794
56.16684.16290.15911.15546.15194.14855.14528.14213.13909.13615
57.17648.17242.16851.16474.16111.15760.15422.15096.14781.14477
58.18647.18229.17827.17438.17064.16702.16353.16015.15689.15374
59.19678.19249.18835.18435.18049.17676.17316.16968.16631.16305
July 3, 2000162000–27 I.R.B.

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0%
60.20740.20300.19875.19464.19066.18682.18311.17952.17604.17268
61.21837.21385.20949.20527.20119.19724.19341.18971.18613.18266
62.22973.22511.22064.21631.21212.20807.20414.20033.19664.19306
63.24152.23680.23222.22779.22350.21934.21530.21139.20760.20392
64.25372.24890.24422.23969.23529.23103.22690.22289.21899.21521
65.26633.26141.25664.25201.24752.24316.23893.23482.23083.22695
66.27940.27439.26953.26481.26023.25577.25145.24724.24316.23918
67.29299.28790.28296.27815.27348.26894.26453.26024.25606.25200
68.30709.30193.29691.29202.28728.28265.27816.27378.26952.26537
69.32166.31643.31134.30639.30157.29687.29230.28785.28351.27928
70.33661.33133.32618.32116.31628.31152.30688.30235.29794.29364
71.35188.34654.34134.33627.33133.32651.32181.31722.31275.30838
72.36742.36204.35679.35168.34668.34181.33706.33241.32788.32345
73.38317.37776.37248.36733.36229.35738.35257.34788.34330.33882
74.39923.39380.38849.38330.37823.37328.36844.36370.35908.35455
75.41566.41021.40489.39968.39459.38961.38474.37997.37531.37074
76.43254.42709.42176.41655.41144.40645.40156.39677.39208.38749
77.44988.44444.43912.43391.42880.42380.41891.41411.40940.40479
78.46765.46224.45694.45174.44665.44166.43677.43197.42726.42265
79.48574.48037.47510.46993.46487.45990.45502.45024.44554.44094
80.50397.49865.49343.48830.48327.47834.47349.46873.46406.45947
81.52219.51693.51176.50669.50171.49682.49201.48729.48265.47809
82.54029.53510.53000.52499.52007.51523.51047.50580.50120.49667
83.55826.55315.54813.54319.53834.53356.52886.52424.51969.51522
84.57624.57123.56629.56144.55666.55195.54732.54277.53828.53386
85.59435.58944.58460.57984.57516.57054.56599.56151.55710.55275
86.61241.60762.60289.59824.59365.58913.58468.58029.57596.57170
87.63015.62548.62087.61633.61185.60744.60309.59880.59456.59039
88.64753.64299.63851.63409.62973.62543.62118.61700.61287.60879
89.66454.66013.65579.65150.64726.64308.63895.63488.63086.62689
90.68115.67689.67268.66853.66442.66037.65637.65241.64851.64465
91.69706.69294.68887.68486.68089.67696.67309.66925.66547.66173
92.71190.70792.70399.70011.69627.69247.68872.68501.68134.67771
93.72569.72184.71804.71429.71057.70689.70326.69967.69611.69259
94.73861.73490.73123.72759.72400.72044.71692.71344.71000.70659
95.75097.74739.74384.74033.73686.73342.73002.72665.72331.72001
96.76267.75922.75579.75240.74905.74572.74243.73917.73595.73275
97.77356.77022.76691.76363.76039.75718.75399.75084.74772.74463
98.78382.78059.77740.77423.77110.76799.76491.76186.75884.75584
99.79390.79079.78771.78465.78162.77862.77565.77270.76978.76688
100.80376.80076.79779.79485.79193.78904.78617.78333.78051.77771
101.81353.81066.80780.80497.80217.79938.79662.79388.79117.78847
102.82318.82042.81768.81496.81227.80960.80694.80431.80170.79911
103.83278.83014.82752.82491.82233.81977.81723.81470.81220.80971
104.84310.84059.83810.83563.83317.83073.82831.82591.82352.82115
2000–27 I.R.B.17July 3, 2000

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0%
105.85318.85079.84843.84607.84374.84142.83911.83682.83455.83229
106.86633.86413.86193.85975.85758.85543.85329.85116.84904.84694
107.88247.88049.87852.87656.87460.87266.87073.86881.86690.86500
108.90825.90666.90507.90350.90193.90037.89881.89727.89572.89419
109.95372.95290.95208.95126.95045.94964.94883.94803.94723.94643
July 3, 2000182000–27 I.R.B.
TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE12.2%12.4%12.6%12.8%13.0%13.2%13.4%13.6%13.8%14.0%
0.01298.01285.01273.01261.01250.01240.01230.01221.01212.01203
1.00468.00455.00443.00431.00420.00410.00400.00391.00382.00374
2.00448.00435.00421.00409.00398.00387.00376.00366.00357.00348
3.00452.00437.00423.00410.00398.00386.00375.00365.00355.00345
4.00468.00452.00437.00423.00410.00397.00386.00375.00364.00354
5.00493.00476.00460.00445.00431.00418.00405.00393.00382.00371
6.00524.00506.00489.00473.00458.00444.00430.00418.00406.00394
7.00562.00543.00525.00508.00492.00477.00462.00449.00436.00423
8.00606.00586.00566.00548.00531.00515.00499.00485.00471.00458
9.00659.00637.00616.00597.00579.00561.00545.00529.00514.00500
10.00721.00698.00676.00655.00636.00617.00600.00583.00567.00552
11.00792.00767.00744.00722.00701.00682.00663.00645.00628.00612
12.00871.00845.00821.00797.00775.00754.00735.00716.00698.00681
13.00955.00928.00902.00877.00854.00831.00810.00790.00771.00753
14.01038.01009.00981.00955.00930.00907.00885.00864.00843.00824
15.01116.01085.01056.01028.01002.00977.00954.00932.00910.00890
16.01186.01153.01123.01094.01066.01040.01015.00992.00969.00948
17.01250.01215.01183.01152.01124.01096.01070.01045.01022.00999
18.01308.01272.01238.01206.01175.01147.01119.01093.01068.01044
19.01367.01329.01293.01259.01227.01196.01167.01140.01113.01088
20.01428.01388.01350.01314.01280.01248.01217.01188.01161.01134
21.01494.01451.01411.01373.01337.01303.01271.01240.01211.01183
22.01562.01517.01475.01435.01397.01361.01326.01294.01263.01233
23.01635.01588.01543.01501.01460.01422.01386.01351.01319.01287
24.01716.01665.01618.01573.01530.01489.01451.01415.01380.01347
25.01804.01751.01701.01653.01608.01565.01524.01485.01448.01413
26.01902.01845.01792.01741.01693.01648.01604.01563.01524.01487
27.02011.01951.01895.01841.01790.01742.01696.01652.01610.01571
28.02129.02066.02006.01949.01895.01844.01795.01748.01704.01662
29.02258.02191.02127.02067.02009.01955.01903.01853.01806.01762

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE12.2%12.4%12.6%12.8%13.0%13.2%13.4%13.6%13.8%14.0%
30.02396.02325.02257.02193.02132.02074.02019.01966.01916.01869
31.02543.02467.02396.02328.02263.02201.02143.02087.02034.01983
32.02701.02621.02545.02472.02404.02338.02276.02217.02160.02106
33.02871.02786.02706.02629.02556.02487.02420.02357.02297.02240
34.03054.02964.02879.02797.02720.02646.02576.02509.02445.02383
35.03253.03158.03067.02981.02898.02820.02745.02674.02606.02541
36.03467.03366.03269.03178.03090.03007.02928.02852.02779.02710
37.03697.03590.03488.03391.03298.03209.03125.03044.02967.02893
38.03947.03833.03725.03622.03524.03430.03340.03254.03172.03094
39.04217.04096.03982.03873.03768.03669.03573.03482.03395.03312
40.04510.04383.04262.04146.04035.03930.03828.03732.03639.03550
41.04830.04695.04567.04445.04327.04215.04108.04005.03907.03812
42.05177.05035.04900.04770.04646.04527.04413.04304.04200.04100
43.05553.05404.05261.05123.04992.04866.04746.04630.04520.04413
44.05960.05802.05651.05506.05368.05235.05107.04985.04867.04754
45.06395.06229.06069.05917.05770.05630.05495.05365.05241.05121
46.06860.06685.06517.06356.06202.06053.05911.05774.05643.05516
47.07353.07169.06992.06823.06660.06504.06353.06209.06070.05936
48.07877.07684.07498.07320.07149.06984.06826.06673.06527.06385
49.08433.08231.08036.07849.07669.07495.07329.07168.07013.06864
50.09026.08814.08609.08413.08224.08042.07867.07698.07535.07378
51.09655.09433.09219.09013.08815.08624.08440.08262.08091.07926
52.10318.10086.09863.09647.09439.09239.09046.08860.08680.08506
53.11017.10774.10541.10315.10098.09888.09686.09491.09302.09120
54.11750.11498.11254.11019.10792.10572.10361.10156.09958.09767
55.12522.12258.12005.11759.11522.11294.11072.10859.10652.10451
56.13332.13059.12794.12539.12292.12054.11823.11599.11383.11174
57.14183.13899.13624.13359.13102.12853.12613.12380.12154.11936
58.15070.14775.14490.14215.13948.13689.13439.13197.12962.12734
59.15990.15685.15389.15103.14826.14558.14298.14046.13801.13564
60.16942.16626.16321.16024.15737.15459.15189.14927.14673.14426
61.17929.17603.17287.16981.16684.16395.16115.15844.15580.15324
62.18960.18623.18297.17980.17673.17375.17085.16803.16530.16264
63.20035.19688.19352.19025.18708.18400.18100.17809.17525.17250
64.21154.20797.20451.20114.19787.19469.19159.18859.18566.18281
65.22318.21951.21595.21249.20912.20584.20265.19955.19652.19358
66.23532.23156.22790.22434.22088.21751.21422.21102.20791.20487
67.24804.24419.24044.23679.23324.22977.22640.22311.21990.21678
68.26133.25740.25356.24983.24618.24263.23917.23579.23250.22929
69.27516.27114.26723.26341.25969.25605.25251.24905.24567.24237
70.28945.28536.28137.27747.27367.26996.26633.26279.25934.25596
71.30412.29996.29590.29193.28806.28427.28057.27696.27343.26998
72.31913.31491.31078.30675.30281.29895.29519.29150.28790.28438
73.33444.33016.32597.32188.31788.31396.31013.30638.30271.29913
74.35012.34579.34155.33741.33335.32938.32549.32168.31795.31430
2000–27 I.R.B.19July 3, 2000

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE12.2%12.4%12.6%12.8%13.0%13.2%13.4%13.6%13.8%14.0%
75.36628.36190.35762.35343.34932.34530.34136.33750.33372.33001
76.38299.37858.37427.37004.36589.36183.35784.35394.35011.34636
77.40028.39585.39151.38725.38307.37898.37496.37103.36716.36337
78.41812.41368.40933.40506.40086.39675.39271.38874.38485.38103
79.43641.43198.42762.42334.41914.41502.41096.40698.40308.39924
80.45496.45054.44619.44192.43772.43360.42954.42556.42164.41779
81.47360.46920.46487.46061.45643.45231.44827.44429.44038.43653
82.49223.48785.48355.47932.47516.47106.46703.46307.45916.45532
83.51081.50648.50221.49802.49388.48982.48581.48187.47799.47416
84.52951.52523.52101.51686.51277.50874.50477.50086.49701.49321
85.54847.54425.54009.53600.53196.52798.52406.52019.51638.51262
86.56749.56335.55926.55523.55126.54734.54348.53966.53591.53220
87.58627.58221.57820.57425.57035.56650.56270.55895.55526.55161
88.60477.60079.59688.59301.58919.58542.58170.57802.57439.57081
89.62297.61909.61527.61149.60776.60408.60044.59685.59330.58979
90.64084.63707.63335.62968.62604.62246.61891.61540.61194.60851
91.65803.65437.65076.64719.64366.64017.63672.63330.62993.62659
92.67412.67058.66707.66360.66017.65678.65342.65010.64682.64357
93.68911.68567.68227.67890.67557.67227.66901.66578.66258.65942
94.70321.69988.69657.69330.69006.68686.68369.68055.67744.67437
95.71674.71351.71031.70713.70399.70088.69781.69476.69174.68875
96.72959.72646.72335.72028.71724.71422.71123.70828.70534.70244
97.74156.73853.73552.73254.72959.72666.72376.72089.71804.71522
98.75287.74993.74702.74413.74126.73842.73561.73282.73006.72732
99.76401.76117.75834.75555.75277.75002.74730.74459.74191.73926
100.77494.77219.76946.76676.76408.76142.75878.75616.75357.75099
101.78580.78315.78052.77791.77532.77275.77021.76768.76517.76268
102.79654.79399.79146.78894.78645.78397.78152.77908.77666.77426
103.80724.80479.80236.79994.79755.79517.79280.79046.78813.78582
104.81879.81646.81413.81183.80954.80726.80501.80276.80054.79832
105.83005.82782.82560.82340.82121.81904.81688.81474.81260.81049
106.84485.84277.84071.83866.83662.83459.83257.83057.82857.82659
107.86311.86124.85937.85751.85566.85382.85199.85017.84835.84655
108.89266.89114.88963.88812.88662.88513.88364.88216.88068.87922
109.94563.94484.94405.94326.94248.94170.94092.94014.93937.93860
July 3, 2000202000–27 I.R.B.
(f) Effective dates.This section applies
after April 30, 1999.
§1.642(c)–6T [Removed]
Par. 6. Section 1.642(c)–6T is re-
moved.
Par. 7. Section 1.664–4 is amended by:
1. Revising paragraphs (a)(1).
2. Removing existing paragraphs (d)
through (e)(5).
3. Adding paragraphs (d), (e) heading
and (e)(1) through (e)(5).
4. Adding paragraph (e)(7).
5. Revising paragraph (f).
The revisions and additions read as fol-
lows:
§1.664–4 Calculation of the fair market
value of the remainder interest in a chari-
table remainder unitrust.
(a) * * *
(1) Life contingencies determined as to
each life involved, from the values oflxset
forth in Table 90CM contained in
§20.2031–7(d)(7) of this chapter in the case
of transfers for which the valuation date is
after April 30, 1999; or from Table
80CNSMT contained §20.2031–7A(e)(4) of
this chapter in the case of transfer for which
the valuation date is after April 30, 1989, and
before May 1, 1999. See §20.2031–7A(a)

through (d) of this chapter, whichever is ap-
plicable, for transfers for which the valuation
date is before May 1, 1989;
* * * * *
(d) Valuation. The fair market value of a
remainder interest in a charitable remainder
unitrust (as described in §1.664–3) for
transfers for which the valuation date is
after April 30, 1999, is its present value de-
termined under paragraph (e) of this sec-
tion. The fair market value of a remainder
interest in a charitable remainder unitrust
(as described in §1.664–3) for transfers for
which the valuation date is before May 1,
1999, is its present value determined under
the following sections:
2000–27 I.R.B.21July 3, 2000
ValuationDatesApplicable
AfterBeforeRegulations
01-01-521.664–4A(a)
12-31-5101-01-711.664–4A(b)
12-31-7012-01-831.664–4A(c)
11-30-8305-01-891.664–4A(d)
04-30-8905-01-991.664–4A(e)
(e) Valuation of charitable remainder
unitrusts having certain payout sequences
for transfers for which the valuation date
is after April 30, 1999—(1) In general.
Except as otherwise provided in para-
graph (e)(2) of this section, in the case of
transfers for which the valuation date is
after April 30, 1999, the present value of a
remainder interest is determined under
paragraphs (e)(3) through (e)(7) of this
section, provided that the amount of the
payout as of any payout date during any
taxable year of the trust is not larger than
the amount that the trust could distribute
on such date under §1.664–3(a)(1)(v) if
the taxable year of the trust were to end
on such date. See, however,
§1.7520–3(b) (relating to exceptions to
the use of the prescribed tables under cer-
tain circumstances).
(2) Transitional rules for valuation of
charitable remainder unitrusts. (i) For
purposes of sections 2055, 2106, or 2624,
if on May 1, 1999, the decedent was men-
tally incompetent so that the disposition
of the property could not be changed, and
the decedent died after April 30, 1999,
without having regained competency to
dispose of the decedent’s property, or the
decedent died within 90 days of the date
that the decedent first regained compe-
tency after April 30, 1999, the present
value of a remainder interest under this
section is determined as if the valuation
date with respect to the decedent’s gross
estate is either before May 1, 1999, or
after April 30, 1999, at the option of the
decedent’s executor.
(ii) For purposes of sections 170, 2055,
2106, 2522, or 2624, in the case of trans-
fers to a charitable remainder unitrust for
which the valuation date is after April 30,
1999, and before July 1, 1999, the present
value of a remainder interest based on one
or more measuring lives is determined
under this section by use of the section
7520 interest rate for the month in which
the valuation date occurs (see
§§1.7520–1(b) and 1.7520–2(a)(2)) and
the appropriate actuarial tables under ei-
ther paragraph (e)(7) of this section or
§1.664–4A(e)(6), at the option of the
donor or the decedent’s executor, as the
case may be.
(iii) For purposes of paragraphs
(e)(2)(i) and (ii) of this section, where the
donor or decedent’s executor is given the
option to use the appropriate actuarial ta-
bles under either paragraph (e)(7) of this
section or §1.664–4A(e)(6), the donor or
decedent’s executor must use the same ac-
tuarial table with respect to each individ-
ual transaction and with respect to all
transfers occurring on the valuation date
(for example, gift and income tax charita-
ble deductions with respect to the same
transfer must be determined based on the
same tables, and all assets includible in
the gross estate and/or estate tax deduc-
tions claimed must be valued based on the
same tables).
(3) Adjusted payout rate. For transfers
for which the valuation date is after April
30, 1989, the adjusted payout rate is de-
termined by using the appropriate Table F
in paragraph (e)(6) of this section, for the
section 7520 interest rate applicable to the
transfer. If the interest rate is between 4.2
and 14 percent, see paragraph (e)(6) of
this section. If the interest rate is below
4.2 percent or greater than 14 percent, see
paragraph (b) of this section. The ad-
justed payout rate is determined by multi-
plying the fixed percentage described in
§1.664–3(a)(1)(i)(a) by the factor de-
scribing the payout sequence of the trust
and the number of months by which the
valuation date for the first full taxable
year of the trust precedes the first payout
date for such taxable year. If the govern-
ing instrument does not prescribe when
the distribution or distributions shall be
made during the taxable year of the trust,
see paragraph (a) of this section. In the
case of a trust having a payout sequence
for which no figures have been provided
by the appropriate table, and in the case of
a trust that determines the fair market
value of the trust assets by taking the av-
erage of valuations on more than one date
during the taxable year, see paragraph (b)
of this section.
(4) Period is a term of years. If the pe-
riod described in §1.664–3(a)(5) is a term
of years, the factor that is used in deter-
mining the present value of the remainder
interest for transfers for which the valua-
tion date is after November 30, 1983, is
the factor under the appropriate adjusted
payout rate in Table D of paragraph (e)(6)
of this section corresponding to the num-
ber of years in the term. If the adjusted
payout rate is an amount that is between
adjusted payout rates for which factors are
provided in Table D, a linear interpolation
must be made. The present value of the
remainder interest is determined by multi-
plying the net fair market value (as of the
appropriate valuation date) of the property
placed in trust by the factor determined
under this paragraph. For purposes of this
section, the valuation date is, in the case of
an inter vivos transfer, the date on which
the property is transferred to the trust by
the donor. However, if an election is made
under section 7520 and §1.7520–2(b) to
compute the present value of the charita-
ble interest by use of the interest rate com-
ponent for either of the 2 months preced-

ing the month in which the date of transfer
falls, the month so elected is the valuation
date for purposes of determining the inter-
est rate and mortality tables. In the case of
a testamentary transfer under section
2055, 2106, or 2624, the valuation date is
the date of death, unless the alternate valu-
ation date is elected under section 2032, in
which event, and within the limitations set
forth in section 2032 and the regulations
thereunder, the valuation date is the alter-
nate valuation date. If the decedent’s es-
tate elects the alternate valuation date
under section 2032 and also elects, under
section 7520 and §1.7520–2(b), to use the
interest rate component for one of the 2
months preceding the alternate valuation
date, the month so elected is the valuation
date for purposes of determining the inter-
est rate and mortality tables. The applica-
tion of this paragraph (e)(4) may be illus-
trated by the following example:
Example. D transfers $100,000 to a charitable re-
mainder unitrust on January 1. The trust instrument
requires that the trust pay 8 percent of the fair mar-
ket value of the trust assets as of January 1st for a
term of 12 years to D in quarterly payments (March
31, June 30, September 30, and December 31). The
section 7520 rate for January (the month that the
transfer occurred) is 9.6 percent. Under Table F(9.6)
in paragraph(e)(6) of this section, the appropriate
adjustment factor is .944628 for quarterly payments
payable at the end of each quarter. The adjusted
payout rate is 7.557 (8% X .944628). Based on the
remainder factors in Table D in paragraph(e)(6) of
this section, the present value of the remainder inter-
est is $38,950.30, computed as follows:
Factor at 7.4 percent for 12 years . . . . .397495
Factor at 7.6 percent for 12 years . . . . .387314
Difference . . . . . . . . . . . . . . . . . . . . . . .010181
Interpolation adjustment:
7.557% - 7.4%
= x
0.2%.010181
x = .007992
Factor at 7.4 percent for 12 years . . . . .397495
Less: Interpolation adjustment . . . . . . . .007992
Interpolated factor . . . . . . . . . . . . . . . . .389503
Present value of remainder interest:
($100,000 X .389503) . . . . . . . . . $38,950.30
(5) Period is the life of one individual.
If the period described in §1.664–3(a)(5)
is the life of one individual, the factor that
is used in determining the present value of
the remainder interest for transfers for
which the valuation date is after April 30,
1999, is the factor in Table U(1) in para-
graph (e)(7) of this section under the ap-
propriate adjusted payout. For purposes
of the computations described in this
paragraph, the age of an individual is the
age of that individual at the individual’s
nearest birthday. If the adjusted payout
rate is an amount that is between adjusted
payout rates for which factors are pro-
vided in the appropriate table, a linear in-
terpolation must be made. The present
value of the remainder interest is deter-
mined by multiplying the net fair market
value (as of the valuation date as deter-
mined in paragraph (e)(4) of this section)
of the property placed in trust by the fac-
tor determined under this paragraph
(e)(5). If the adjusted payout rate is be-
tween 4.2 and 14 percent, see paragraph
(e)(7) of this section. If the adjusted pay-
out rate is below 4.2 percent or greater
than 14 percent, see paragraph (b) of this
section. The application of this paragraph
(e)(5) may be illustrated by the following
example:
Example. A, who is 44 years and 11 months old,
transfers $100,000 to a charitable remainder unitrust
on January 1st. The trust instrument requires that
the trust pay to A semiannually (on June 30 and De-
cember 31) 9 percent of the fair market value of the
trust assets as of January 1st during A’s life. The
section 7520 rate for January is 9.6 percent. Under
Table F(9.6) in paragraph (e)(6) of this section, the
appropriate adjustment factor is .933805 for semian-
nual payments payable at the end of the semiannual
period. The adjusted payout rate is 8.404 (9% X
.933805). Based on the remainder factors in Table
U(1) in paragraph (e)(7) of this section, the present
value of the remainder interest is $10,109.00, com-
puted as follows:
Factor at 8.4 percent at age 45 . . . . . . .10117
Factor at 8.6 percent at age 45 . . . . . . .09715
Difference . . . . . . . . . . . . . . . . . . . . . . .00402
Interpolation adjustment:
8.404% - 8.4%=x
0.2%.00402
x = .00008
Factor at 8.4 percent at age 45 . . . . . . .10117
Less: Interpolation adjustment . . . . . . .00008
Interpolated Factor . . . . . . . . . . . . . . . .10109
Present value of remainder interest:
($100,000 X .10109) . . . . . . . . . . $10,109.00
* * * * *
(7) Actuarial Table U(1) for transfers
for which the valuation date is after April
30, 1999. For transfers for which the val-
uation date is after April 30, 1999, the
present value of a charitable remainder
unitrust interest that is dependent on the
termination of a life interest is determined
by using the section 7520 rate, Table U(1)
in this paragraph (e)(7), and Table F(4.2)
through (14.0) in paragraph (e)(6) of this
section. See, however, §1.7520–3(b) (re-
lating to exceptions to the use of pre-
scribed tables under certain circum-
stances). Many actuarial factors not
contained in the following tables are con-
tained in Internal Revenue Service Publi-
cation 1458, “Actuarial Values, Book
Beth,” (7-1999). A copy of this publica-
tion is available for purchase from the Su-
perintendent of Documents, United States
Government Printing Office, Washington,
DC 20402.
July 3, 2000222000–27 I.R.B.

TABLE U(1)
BASED ON LIFE TABLE 90CM
UNITRUST SINGLE LIFE REMAINDER FACTORS
APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999
ADJUSTED PAYOUT RATE
AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0%
0.06177.05580.05061.04609.04215.03871.03570.03307.03075.02872
1.05543.04925.04388.03919.03509.03151.02838.02563.02321.02109
2.05716.05081.04528.04045.03622.03252.02927.02642.02391.02170
3.05920.05268.04699.04201.03765.03382.03046.02750.02490.02260
4.06143.05475.04889.04376.03926.03530.03182.02876.02605.02366
5.06384.05697.05095.04567.04103.03694.03334.03016.02735.02487
6.06637.05933.05315.04771.04292.03870.03497.03168.02876.02618
7.06905.06183.05547.04987.04494.04058.03673.03332.03029.02761
8.07186.06445.05792.05216.04708.04258.03859.03506.03192.02914
9.07482.06722.06052.05460.04936.04471.04060.03694.03369.03079
10.07793.07015.06327.05718.05179.04700.04274.03896.03559.03259
11.08120.07323.06617.05991.05435.04942.04502.04111.03762.03450
12.08461.07645.06920.06277.05706.05197.04744.04339.03978.03655
13.08812.07976.07234.06574.05985.05461.04993.04576.04202.03867
14.09168.08313.07552.06874.06269.05729.05247.04815.04428.04081
15.09527.08652.07872.07176.06554.05999.05501.05055.04655.04296
16.09886.08991.08192.07478.06839.06267.05754.05294.04880.04508
17.10249.09334.08515.07782.07126.06537.06008.05533.05105.04720
18.10616.09680.08842.08090.07415.06809.06264.05774.05332.04933
19.10994.10037.09178.08407.07714.07091.06529.06023.05566.05153
20.11384.10406.09527.08737.08025.07383.06805.06283.05811.05384
21.11790.10790.09891.09080.08349.07690.07094.06555.06068.05626
22.12208.11188.10267.09436.08686.08008.07395.06839.06336.05879
23.12643.11601.10659.09808.09038.08342.07710.07138.06618.06146
24.13095.12031.11069.10197.09408.08692.08042.07452.06915.06427
25.13567.12481.11497.10605.09795.09060.08392.07784.07230.06726
26.14058.12950.11945.11032.10202.09447.08760.08134.07563.07042
27.14571.13442.12415.11481.10631.09856.09149.08505.07916.07379
28.15104.13953.12904.11949.11078.10284.09558.08895.08288.07733
29.15656.14484.13414.12438.11546.10731.09986.09304.08679.08106
30.16229.15034.13943.12946.12034.11198.10433.09732.09089.08498
31.16821.15605.14493.13474.12541.11685.10900.10179.09517.08909
32.17433.16196.15063.14023.13069.12193.11387.10647.09966.09339
33.18068.16810.15655.14595.13620.12723.11897.11137.10437.09791
34.18724.17446.16270.15189.14193.13275.12430.11650.10930.10265
35.19405.18107.16910.15808.14791.13853.12987.12187.11448.10764
36.20109.18791.17574.16451.15414.14456.13569.12749.11990.11287
37.20838.19500.18263.17120.16062.15083.14177.13337.12558.11835
38.21593.20236.18979.17816.16739.15739.14813.13953.13154.12412
39.22374.20998.19723.18540.17443.16423.15477.14597.13779.13017
40.23183.21789.20496.19294.18177.17138.16172.15272.14434.13653
41.24021.22611.21299.20079.18943.17885.16899.15980.15123.14322
42.24889.23463.22134.20896.19741.18665.17660.16721.15845.15025
43.25786.24344.23000.21744.20572.19477.18453.17496.16601.15762
44.26712.25257.23896.22625.21435.20322.19281.18305.17391.16534
2000–27 I.R.B.23July 3, 2000

TABLE U(1)
BASED ON LIFE TABLE 90CM
UNITRUST SINGLE LIFE REMAINDER FACTORS
APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999
ADJUSTED PAYOUT RATE
AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0%
45.27665.26196.24821.23534.22328.21198.20139.19145.18213.17338
46.28644.27163.25774.24472.23251.22105.21028.20018.19068.18174
47.29647.28155.26754.25438.24201.23040.21947.20919.19952.19041
48.30676.29173.27760.26431.25181.24004.22896.21852.20868.19941
49.31729.30217.28794.27453.26190.24999.23876.22817.21817.20873
50.32808.31289.29856.28505.27229.26026.24889.23814.22799.21839
51.33912.32387.30946.29585.28299.27083.25933.24845.23815.22840
52.35038.33507.32060.30691.29395.28168.27005.25904.24861.23872
53.36185.34651.33198.31821.30517.29280.28106.26993.25937.24934
54.37352.35815.34358.32976.31664.30418.29234.28110.27042.26026
55.38539.37002.35542.34155.32836.31583.30390.29256.28177.27149
56.39746.38209.36748.35358.34034.32774.31574.30431.29342.28303
57.40971.39437.37976.36584.35257.33992.32785.31634.30536.29488
58.42212.40682.39222.37829.36500.35231.34019.32862.31756.30699
59.43464.41939.40482.39090.37759.36488.35272.34109.32996.31932
60.44726.43207.41754.40364.39034.37761.36542.35375.34257.33186
61.45999.44488.43041.41655.40326.39053.37833.36662.35540.34463
62.47286.45785.44345.42964.41639.40367.39146.37974.36848.35767
63.48589.47098.45667.44293.42972.41703.40484.39311.38184.37100
64.49903.48426.47005.45638.44324.43060.41843.40671.39544.38458
65.51229.49766.48357.47001.45694.44435.43223.42054.40927.39841
66.52568.51121.49726.48381.47084.45833.44626.43461.42337.41252
67.53924.52495.51115.49784.48498.47256.46056.44898.43778.42696
68.55293.53883.52521.51205.49932.48701.47511.46360.45246.44169
69.56671.55283.53940.52640.51382.50165.48985.47844.46738.45666
70.58052.56687.55365.54084.52843.51639.50473.49342.48245.47181
71.59431.58091.56791.55529.54306.53118.51966.50847.49761.48707
72.60804.59490.58213.56973.55768.54598.53461.52357.51283.50239
73.62168.60881.59629.58411.57227.56076.54955.53866.52806.51774
74.63528.62268.61042.59848.58686.57555.56453.55380.54335.53316
75.64887.63657.62458.61290.60151.59041.57959.56904.55875.54872
76.66249.65049.63880.62739.61625.60538.59478.58443.57432.56446
77.67612.66446.65307.64194.63108.62046.61009.59995.59005.58037
78.68975.67843.66736.65654.64596.63561.62548.61558.60590.59643
79.70330.69233.68160.67109.66081.65074.64088.63123.62178.61253
80.71666.70605.69566.68548.67550.66573.65615.64676.63755.62853
81.72975.71950.70946.69961.68995.68047.67117.66205.65310.64433
82.74250.73263.72293.71342.70407.69490.68589.67705.66837.65984
83.75493.74542.73608.72690.71788.70902.70031.69175.68333.67506
84.76712.75798.74900.74016.73147.72292.71451.70624.69810.69010
85.77913.77037.76175.75326.74491.73668.72859.72061.71276.70503
86.79086.78248.77423.76610.75808.75019.74241.73474.72719.71974
87.80218.79418.78628.77850.77083.76326.75580.74844.74118.73402
88.81307.80544.79790.79047.78313.77589.76874.76169.75473.74786
89.82355.81628.80909.80200.79500.78808.78125.77450.76783.76125
July 3, 2000242000–27 I.R.B.

TABLE U(1)
BASED ON LIFE TABLE 90CM
UNITRUST SINGLE LIFE REMAINDER FACTORS
APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999
ADJUSTED PAYOUT RATE
AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0%
90.83360.82668.81985.81309.80642.79982.79330.78685.78048.77418
91.84308.83650.83000.82357.81721.81092.80470.79855.79246.78645
92.85182.84556.83937.83325.82718.82119.81525.80937.80356.79780
93.85985.85390.84800.84215.83637.83064.82497.81936.81379.80829
94.86732.86164.85601.85044.84491.83944.83402.82865.82333.81806
95.87437.86895.86359.85827.85300.84778.84260.83746.83237.82733
96.88097.87582.87070.86563.86060.85561.85066.84575.84088.83605
97.88708.88216.87727.87243.86762.86285.85811.85341.84875.84413
98.89280.88810.88343.87880.87420.86964.86511.86061.85614.85171
99.89836.89388.88943.88501.88062.87626.87193.86763.86336.85911
100.90375.89948.89525.89103.88685.88269.87856.87445.87037.86632
101.90905.90500.90097.89696.89298.88902.88509.88118.87729.87342
102.91424.91040.90658.90278.89900.89524.89150.88778.88408.88040
103.91939.91575.91214.90854.90496.90139.89785.89432.89081.88732
104.92485.92144.91805.91467.91131.90796.90463.90131.89800.89471
105.93020.92701.92383.92067.91751.91437.91125.90813.90502.90193
106.93701.93411.93122.92834.92546.92260.91974.91689.91405.91122
107.94522.94268.94013.93760.93507.93254.93002.92750.92499.92249
108.95782.95583.95385.95187.94989.94791.94593.94396.94199.94002
109.97900.97800.97700.97600.97500.97400.97300.97200.97100.97000
2000–27 I.R.B.25July 3, 2000
TABLE U(1)
BASED ON LIFE TABLE 90CM
UNITRUST SINGLE LIFE REMAINDER FACTORS
APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999
ADJUSTED PAYOUT RATE
AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0%
0.02693.02534.02395.02271.02161.02063.01976.01898.01828.01765
1.01922.01756.01610.01480.01365.01263.01171.01090.01017.00951
2.01975.01802.01650.01514.01393.01286.01190.01104.01028.00959
3.02056.01876.01717.01575.01449.01336.01235.01145.01064.00992
4.02155.01967.01800.01652.01520.01401.01296.01201.01116.01039
5.02266.02071.01896.01741.01603.01479.01368.01269.01179.01098
6.02389.02184.02003.01841.01696.01566.01450.01345.01251.01166
7.02522.02309.02120.01950.01799.01663.01540.01431.01332.01242
8.02665.02444.02246.02069.01910.01768.01640.01524.01420.01326
9.02821.02590.02384.02199.02033.01884.01750.01629.01520.01421
10.02990.02750.02535.02342.02169.02013.01872.01745.01631.01526
11.03172.02922.02698.02497.02316.02153.02006.01872.01752.01643
12.03365.03106.02872.02663.02474.02303.02149.02010.01884.01769
13.03566.03297.03054.02835.02638.02460.02299.02154.02021.01901
14.03770.03490.03237.03010.02804.02619.02450.02298.02159.02033

TABLE U(1)
BASED ON LIFE TABLE 90CM
UNITRUST SINGLE LIFE REMAINDER FACTORS
APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999
ADJUSTED PAYOUT RATE
AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0%
15.03973.03682.03419.03182.02968.02775.02599.02439.02294.02162
16.04173.03871.03598.03352.03129.02926.02743.02576.02424.02286
17.04372.04059.03775.03519.03287.03076.02884.02710.02551.02406
18.04573.04248.03953.03686.03444.03224.03024.02842.02676.02524
19.04780.04443.04137.03859.03607.03378.03169.02978.02804.02646
20.04997.04647.04329.04040.03778.03539.03321.03122.02940.02773
21.05226.04862.04532.04232.03958.03709.03481.03274.03083.02909
22.05465.05088.04745.04432.04148.03888.03650.03433.03234.03052
23.05716.05325.04969.04645.04348.04077.03830.03603.03394.03203
24.05983.05578.05208.04871.04562.04280.04021.03784.03566.03367
25.06266.05846.05463.05112.04791.04497.04227.03980.03752.03543
26.06566.06131.05734.05369.05035.04729.04448.04189.03951.03732
27.06887.06436.06024.05646.05298.04979.04686.04416.04168.03939
28.07225.06758.06331.05938.05577.05245.04940.04658.04398.04159
29.07581.07099.06656.06248.05873.05528.05210.04916.04645.04394
30.07956.07457.06998.06575.06186.05827.05495.05189.04906.04644
31.08348.07833.07358.06920.06515.06142.05797.05478.05182.04908
32.08761.08228.07736.07282.06863.06475.06116.05783.05475.05189
33.09195.08645.08136.07666.07231.06828.06454.06108.05786.05488
34.09651.09082.08557.08070.07619.07200.06812.06452.06117.05805
35.10131.09545.09002.08498.08030.07596.07193.06818.06469.06144
36.10635.10031.09470.08949.08465.08015.07596.07206.06842.06503
37.11165.10542.09963.09424.08923.08457.08022.07617.07238.06885
38.11722.11081.10484.09927.09409.08926.08475.08054.07661.07293
39.12308.11648.11032.10458.09922.09422.08955.08518.08109.07726
40.12925.12246.11612.11020.10466.09949.09465.09011.08587.08189
41.13575.12877.12225.11614.11043.10508.10007.09537.09097.08683
42.14259.13542.12871.12243.11654.11101.10583.10097.09640.09210
43.14977.14242.13552.12905.12298.11729.11193.10690.10217.09771
44.15731.14976.14269.13604.12979.12391.11838.11318.10828.10367
45.16516.15743.15017.14334.13691.13086.12516.11979.11472.10994
46.17334.16544.15800.15099.14438.13816.13228.12674.12150.11656
47.18184.17375.16613.15895.15217.14576.13972.13400.12860.12349
48.19066.18240.17461.16724.16029.15371.14749.14161.13604.13077
49.19981.19138.18342.17588.16875.16201.15562.14956.14383.13839
50.20931.20072.19259.18489.17759.17067.16412.15790.15199.14639
51.21917.21042.20212.19426.18679.17971.17299.16660.16054.15477
52.22933.22043.21198.20395.19633.18909.18220.17566.16943.16350
53.23981.23076.22216.21399.20621.19881.19176.18506.17867.17258
54.25060.24141.23267.22434.21642.20886.20166.19480.18826.18201
55.26171.25239.24351.23504.22697.21927.21192.20491.19821.19182
56.27313.26369.25468.24608.23787.23003.22254.21538.20854.20199
57.28487.27531.26618.25746.24912.24114.23351.22621.21923.21254
58.29688.28722.27798.26914.26067.25257.24481.23738.23025.22343
59.30913.29937.29002.28107.27249.26427.25639.24882.24157.23461
July 3, 2000262000–27 I.R.B.

TABLE U(1)
BASED ON LIFE TABLE 90CM
UNITRUST SINGLE LIFE REMAINDER FACTORS
APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999
ADJUSTED PAYOUT RATE
AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0%
60.32159.31175.30231.29325.28457.27623.26823.26055.25317.24608
61.33429.32437.31485.30571.29692.28848.28037.27257.26507.25786
62.34728.33730.32770.31847.30960.30106.29285.28495.27734.27001
63.36057.35053.34087.33157.32262.31400.30569.29769.28998.28255
64.37412.36404.35433.34498.33596.32726.31887.31078.30298.29545
65.38794.37783.36809.35868.34961.34085.33239.32422.31633.30871
66.40205.39193.38216.37272.36361.35479.34628.33804.33008.32238
67.41650.40639.39661.38715.37800.36915.36059.35230.34428.33651
68.43126.42117.41139.40193.39277.38390.37530.36697.35890.35108
69.44628.43622.42648.41703.40787.39898.39037.38201.37391.36604
70.46150.45149.44178.43236.42321.41433.40571.39735.38922.38132
71.47683.46689.45723.44785.43873.42987.42126.41290.40476.39685
72.49225.48238.47279.46346.45439.44556.43697.42862.42048.41257
73.50770.49793.48841.47915.47013.46135.45280.44447.43635.42844
74.52324.51358.50416.49498.48603.47731.46880.46051.45242.44454
75.53894.52939.52008.51100.50214.49349.48505.47681.46877.46092
76.55483.54543.53624.52728.51852.50996.50160.49344.48546.47766
77.57091.56167.55263.54380.53516.52671.51845.51038.50247.49475
78.58716.57809.56922.56053.55203.54372.53557.52760.51980.51216
79.60346.59459.58590.57738.56904.56086.55286.54501.53732.52978
80.61969.61102.60252.59419.58601.57800.57014.56243.55487.54745
81.63571.62726.61897.61082.60283.59499.58729.57974.57232.56503
82.65146.64324.63515.62722.61942.61176.60423.59683.58957.58242
83.66693.65893.65108.64335.63575.62828.62093.61371.60660.59962
84.68222.67447.66684.65934.65195.64468.63753.63049.62356.61674
85.69742.68993.68255.67528.66812.66106.65411.64727.64053.63389
86.71241.70517.69805.69102.68410.67727.67054.66390.65736.65091
87.72696.72000.71313.70635.69967.69307.68656.68014.67381.66756
88.74108.73438.72777.72125.71480.70845.70217.69597.68985.68380
89.75475.74832.74198.73571.72951.72339.71734.71137.70547.69963
90.76796.76180.75572.74971.74376.73788.73207.72633.72065.71503
91.78049.77460.76878.76302.75732.75168.74610.74058.73512.72972
92.79211.78647.78089.77537.76990.76449.75913.75383.74858.74338
93.80283.79743.79208.78679.78154.77634.77119.76610.76105.75604
94.81283.80765.80253.79744.79240.78741.78247.77756.77270.76789
95.82233.81737.81245.80757.80274.79795.79320.78849.78382.77918
96.83126.82651.82180.81712.81248.80788.80332.79880.79431.78985
97.83953.83498.83046.82597.82152.81710.81271.80836.80404.79976
98.84731.84294.83860.83429.83002.82577.82155.81737.81321.80908
99.85490.85071.84656.84243.83832.83425.83020.82618.82219.81822
100.86229.85828.85431.85035.84642.84252.83864.83478.83095.82714
101.86958.86575.86195.85818.85442.85069.84698.84329.83962.83597
102.87674.87310.86947.86587.86229.85873.85518.85166.84815.84466
103.88384.88038.87694.87351.87010.86671.86334.85998.85663.85331
104.89143.88817.88492.88169.87847.87526.87207.86889.86573.86258
2000–27 I.R.B.27July 3, 2000

TABLE U(1)
BASED ON LIFE TABLE 90CM
UNITRUST SINGLE LIFE REMAINDER FACTORS
APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999
ADJUSTED PAYOUT RATE
AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0%
105.89885.89578.89272.88967.88664.88361.88060.87760.87461.87163
106.90840.90559.90278.89999.89720.89442.89165.88888.88613.88338
107.91999.91750.91501.91253.91005.90758.90511.90265.90019.89774
108.93805.93609.93412.93216.93020.92824.92629.92434.92239.92044
109.96900.96800.96700.96600.96500.96400.96300.96200.96100.96000
July 3, 2000282000–27 I.R.B.
TABLE U(1)
BASED ON LIFE TABLE 90CM
UNITRUST SINGLE LIFE REMAINDER FACTORS
APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999
ADJUSTED PAYOUT RATE
AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0%
0.01709.01658.01612.01570.01532.01497.01466.01437.01410.01386
1.00892.00839.00791.00747.00708.00672.00639.00609.00582.00557
2.00896.00840.00790.00744.00702.00664.00629.00598.00569.00542
3.00926.00867.00814.00765.00721.00681.00644.00611.00580.00552
4.00970.00908.00851.00800.00753.00711.00672.00636.00604.00574
5.01026.00960.00900.00846.00796.00751.00710.00672.00637.00606
6.01089.01019.00956.00899.00846.00799.00755.00715.00678.00644
7.01161.01088.01021.00960.00905.00854.00808.00765.00726.00690
8.01241.01163.01093.01029.00970.00917.00867.00822.00781.00743
9.01331.01249.01175.01107.01045.00988.00936.00889.00845.00804
10.01432.01346.01268.01196.01131.01071.01016.00965.00918.00875
11.01543.01453.01370.01295.01226.01162.01104.01051.01001.00956
12.01664.01569.01482.01403.01330.01263.01202.01145.01093.01045
13.01791.01691.01600.01516.01440.01369.01304.01245.01190.01139
14.01918.01813.01717.01629.01548.01474.01406.01343.01285.01231
15.02041.01931.01831.01738.01653.01576.01504.01437.01376.01320
16.02160.02044.01938.01841.01752.01670.01595.01525.01460.01401
17.02274.02152.02041.01940.01846.01760.01680.01607.01539.01476
18.02386.02258.02142.02035.01936.01846.01762.01685.01613.01547
19.02500.02367.02245.02132.02029.01933.01845.01764.01689.01619
20.02621.02481.02353.02235.02126.02025.01933.01847.01768.01694
21.02749.02603.02468.02344.02229.02124.02026.01936.01852.01774
22.02884.02730.02589.02458.02338.02227.02124.02029.01940.01859
23.03028.02867.02718.02581.02454.02337.02229.02128.02035.01949
24.03183.03013.02857.02713.02580.02456.02342.02236.02138.02047
25.03350.03172.03008.02857.02717.02587.02467.02355.02251.02155
26.03530.03344.03172.03013.02865.02729.02602.02484.02375.02273
27.03727.03532.03351.03183.03028.02885.02751.02627.02511.02404
28.03937.03732.03543.03367.03204.03052.02911.02780.02658.02545
29.04162.03947.03748.03564.03392.03233.03084.02946.02818.02698
30.04401.04176.03967.03773.03593.03425.03269.03124.02988.02861
31.04654.04419.04200.03996.03807.03630.03466.03312.03169.03035
32.04923.04676.04447.04233.04034.03849.03676.03514.03363.03221
33.05210.04952.04711.04487.04278.04083.03901.03731.03571.03422

TABLE U(1)
BASED ON LIFE TABLE 90CM
UNITRUST SINGLE LIFE REMAINDER FACTORS
APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999
ADJUSTED PAYOUT RATE
AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0%
34.05515.05245.04993.04758.04538.04333.04142.03962.03794.03637
35.05841.05558.05295.05048.04818.04603.04401.04212.04035.03869
36.06187.05892.05616.05358.05116.04890.04678.04480.04293.04118
37.06555.06247.05958.05688.05435.05198.04975.04766.04570.04385
38.06949.06627.06325.06043.05777.05528.05295.05075.04868.04674
39.07368.07032.06717.06421.06143.05882.05637.05406.05189.04984
40.07816.07465.07137.06827.06537.06263.06006.05764.05535.05320
41.08295.07930.07587.07264.06960.06674.06405.06150.05910.05683
42.08807.08427.08069.07733.07415.07116.06833.06567.06315.06077
43.09352.08957.08585.08233.07902.07589.07294.07014.06750.06500
44.09932.09521.09134.08768.08423.08096.07787.07495.07218.06956
45.10543.10117.09715.09334.08974.08634.08311.08005.07716.07441
46.11189.10747.10329.09933.09559.09204.08867.08548.08245.07958
47.11866.11408.10974.10564.10174.09805.09454.09121.08805.08504
48.12577.12103.11654.11228.10823.10439.10074.09727.09397.09083
49.13323.12833.12368.11926.11506.11107.10728.10366.10022.09695
50.14107.13601.13120.12663.12228.11813.11419.11043.10685.10344
51.14928.14407.13910.13437.12987.12558.12149.11758.11386.11031
52.15785.15248.14735.14247.13781.13337.12913.12508.12122.11752
53.16678.16124.15597.15093.14612.14153.13714.13294.12893.12509
54.17606.17037.16493.15974.15478.15004.14550.14116.13700.13302
55.18570.17986.17428.16893.16382.15893.15424.14976.14546.14134
56.19573.18974.18400.17851.17325.16821.16338.15875.15430.15004
57.20613.20000.19412.18848.18307.17789.17291.16814.16355.15914
58.21688.21060.20458.19880.19325.18792.18280.17788.17316.16861
59.22793.22151.21535.20943.20374.19827.19301.18795.18309.17840
60.23927.23272.22642.22036.21454.20893.20354.19834.19334.18851
61.25092.24425.23782.23163.22567.21993.21440.20907.20393.19898
62.26295.25616.24961.24329.23721.23134.22568.22021.21494.20985
63.27538.26847.26180.25537.24916.24316.23738.23179.22639.22117
64.28817.28116.27438.26783.26150.25539.24949.24377.23825.23291
65.30134.29423.28735.28069.27426.26803.26201.25618.25054.24508
66.31493.30772.30075.29399.28746.28113.27500.26906.26331.25774
67.32899.32170.31464.30780.30118.29475.28852.28248.27663.27095
68.34349.33614.32901.32209.31538.30887.30256.29643.29047.28469
69.35841.35100.34381.33683.33005.32346.31707.31085.30481.29894
70.37366.36620.35896.35193.34509.33844.33197.32568.31957.31362
71.38916.38167.37440.36732.36043.35372.34720.34084.33466.32864
72.40486.39736.39006.38295.37602.36927.36270.35629.35005.34396
73.42074.41323.40591.39878.39182.38504.37843.37198.36568.35955
74.43685.42934.42202.41488.40791.40110.39446.38798.38165.37547
75.45326.44577.43846.43132.42435.41754.41088.40438.39802.39181
76.47004.46259.45530.44818.44122.43442.42776.42125.41488.40865
77.48718.47979.47255.46547.45853.45175.44511.43861.43225.42601
78.50467.49735.49017.48314.47626.46951.46290.45643.45008.44386
79.52239.51515.50806.50110.49427.48758.48102.47459.46828.46209
2000–27 I.R.B.29July 3, 2000

TABLE U(1)
BASED ON LIFE TABLE 90CM
UNITRUST SINGLE LIFE REMAINDER FACTORS
APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999
ADJUSTED PAYOUT RATE
AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0%
80.54018.53304.52603.51916.51242.50580.49930.49292.48666.48052
81.55788.55085.54396.53718.53053.52399.51757.51126.50507.49898
82.57540.56851.56173.55506.54851.54207.53574.52951.52339.51737
83.59274.58598.57933.57279.56635.56001.55378.54765.54161.53567
84.61002.60341.59690.59049.58418.57796.57184.56582.55988.55403
85.62734.62090.61454.60828.60211.59603.59004.58414.57832.57258
86.64455.63828.63210.62600.61999.61406.60821.60244.59675.59113
87.66139.65531.64930.64337.63752.63175.62605.62043.61488.60939
88.67783.67194.66612.66037.65469.64908.64354.63807.63267.62733
89.69387.68817.68254.67698.67148.66605.66068.65537.65012.64493
90.70947.70398.69855.69318.68786.68261.67742.67228.66719.66217
91.72437.71908.71385.70867.70354.69847.69345.68848.68357.67870
92.73823.73314.72810.72310.71816.71326.70841.70361.69886.69415
93.75109.74618.74132.73650.73173.72700.72232.71768.71308.70852
94.76312.75839.75370.74905.74445.73988.73536.73087.72643.72202
95.77459.77004.76552.76104.75660.75220.74783.74350.73920.73494
96.78543.78105.77670.77238.76810.76386.75964.75546.75131.74720
97.79550.79128.78709.78293.77880.77470.77063.76659.76258.75860
98.80498.80091.79687.79286.78888.78492.78099.77709.77322.76937
99.81428.81036.80647.80261.79877.79496.79117.78741.78367.77995
100.82336.81959.81586.81214.80845.80478.80113.79751.79390.79032
101.83234.82873.82515.82158.81804.81451.81101.80753.80406.80062
102.84119.83774.83431.83089.82750.82412.82076.81742.81409.81078
103.84999.84670.84342.84016.83691.83368.83046.82726.82408.82091
104.85944.85632.85321.85011.84703.84396.84090.83786.83483.83182
105.86866.86570.86276.85982.85690.85399.85109.84820.84532.84245
106.88065.87792.87520.87248.86978.86708.86440.86172.85905.85638
107.89530.89286.89042.88799.88557.88315.88073.87833.87592.87352
108.91849.91654.91460.91266.91072.90879.90685.90492.90299.90106
109.95900.95800.95700.95600.95500.95400.95300.95200.95100.95000
July 3, 2000302000–27 I.R.B.
TABLE U(1)
BASED ON LIFE TABLE 90CM
UNITRUST SINGLE LIFE REMAINDER FACTORS
APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999
ADJUSTED PAYOUT RATE
AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0%
0.01363.01342.01323.01305.01288.01272.01258.01244.01231.01219
1.00534.00512.00493.00474.00458.00442.00427.00414.00401.00389
2.00518.00495.00474.00455.00437.00421.00405.00391.00377.00365
3.00526.00502.00480.00459.00440.00422.00406.00391.00376.00363
4.00546.00521.00497.00475.00455.00436.00419.00402.00387.00373

TABLE U(1)
BASED ON LIFE TABLE 90CM
UNITRUST SINGLE LIFE REMAINDER FACTORS
APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999
ADJUSTED PAYOUT RATE
AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0%
5.00576.00549.00524.00501.00479.00459.00440.00423.00406.00391
6.00613.00584.00557.00532.00509.00488.00468.00449.00432.00415
7.00657.00626.00598.00571.00547.00524.00502.00482.00464.00446
8.00707.00675.00644.00616.00590.00565.00542.00521.00501.00482
9.00766.00732.00699.00669.00641.00615.00591.00568.00547.00527
10.00835.00798.00764.00732.00702.00675.00649.00624.00602.00580
11.00913.00874.00838.00804.00772.00743.00715.00689.00665.00642
12.01000.00959.00920.00884.00851.00819.00790.00762.00737.00712
13.01091.01048.01007.00969.00933.00900.00869.00840.00813.00787
14.01181.01135.01092.01052.01014.00979.00947.00916.00887.00860
15.01267.01218.01173.01130.01091.01054.01019.00987.00956.00928
16.01345.01294.01246.01201.01160.01121.01084.01050.01018.00988
17.01418.01364.01313.01266.01222.01181.01143.01107.01073.01041
18.01486.01429.01375.01326.01279.01236.01196.01158.01122.01088
19.01554.01494.01438.01385.01336.01291.01248.01208.01170.01135
20.01626.01562.01503.01448.01396.01348.01303.01260.01220.01183
21.01702.01635.01573.01514.01460.01409.01361.01316.01274.01235
22.01782.01711.01645.01584.01526.01472.01422.01374.01330.01288
23.01868.01793.01724.01658.01597.01540.01487.01437.01390.01345
24.01962.01883.01809.01740.01675.01615.01558.01505.01455.01408
25.02065.01981.01903.01830.01762.01698.01638.01581.01528.01478
26.02178.02089.02006.01929.01856.01789.01725.01665.01609.01556
27.02303.02209.02122.02040.01963.01891.01824.01760.01700.01644
28.02439.02339.02247.02160.02079.02002.01931.01863.01800.01740
29.02585.02480.02382.02290.02204.02123.02047.01976.01908.01845
30.02742.02631.02527.02430.02339.02253.02172.02096.02025.01957
31.02910.02793.02683.02579.02482.02391.02306.02225.02149.02077
32.03089.02965.02849.02739.02636.02540.02449.02363.02282.02206
33.03282.03151.03028.02912.02803.02701.02604.02513.02427.02346
34.03489.03350.03220.03097.02982.02873.02771.02674.02583.02497
35.03713.03567.03429.03299.03177.03061.02953.02850.02753.02661
36.03953.03798.03653.03515.03386.03263.03148.03039.02936.02838
37.04211.04048.03894.03748.03611.03481.03359.03243.03134.03030
38.04490.04318.04155.04001.03856.03719.03589.03466.03350.03239
39.04791.04609.04437.04274.04120.03975.03837.03707.03583.03466
40.05116.04924.04742.04571.04408.04254.04108.03970.03839.03714
41.05469.05267.05075.04894.04722.04559.04405.04258.04119.03987
42.05851.05638.05436.05245.05063.04891.04728.04573.04425.04285
43.06263.06039.05827.05625.05433.05252.05079.04915.04759.04610
44.06707.06472.06248.06035.05834.05642.05459.05286.05121.04963
45.07180.06933.06698.06474.06262.06059.05867.05684.05509.05342
46.07685.07425.07178.06943.06720.06507.06304.06110.05926.05750
47.08218.07946.07687.07440.07205.06981.06768.06564.06369.06183
48.08784.08499.08228.07969.07722.07487.07262.07047.06842.06646
49.09382.09085.08801.08530.08271.08024.07788.07562.07346.07140
2000–27 I.R.B.31July 3, 2000

TABLE U(1)
BASED ON LIFE TABLE 90CM
UNITRUST SINGLE LIFE REMAINDER FACTORS
APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999
ADJUSTED PAYOUT RATE
AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0%
50.10018.09707.09410.09127.08856.08597.08349.08112.07885.07667
51.10691.10367.10057.09761.09477.09206.08946.08697.08459.08231
52.11399.11061.10738.10429.10132.09849.09577.09316.09066.08826
53.12142.11791.11454.11132.10823.10526.10242.09969.09707.09456
54.12921.12556.12206.11870.11548.11239.10942.10657.10383.10120
55.13738.13359.12995.12646.12311.11989.11679.11382.11096.10820
56.14595.14202.13824.13462.13113.12778.12456.12146.11847.11560
57.15491.15084.14693.14317.13955.13607.13272.12949.12638.12338
58.16424.16004.15599.15209.14834.14473.14125.13789.13465.13153
59.17390.16955.16537.16134.15746.15371.15010.14662.14325.14001
60.18387.17939.17507.17091.16689.16302.15927.15566.15217.14880
61.19420.18958.18513.18084.17669.17268.16881.16506.16145.15795
62.20494.20020.19561.19119.18691.18277.17877.17490.17115.16753
63.21613.21126.20654.20199.19758.19331.18918.18518.18131.17757
64.22774.22274.21791.21322.20869.20429.20004.19592.19192.18805
65.23979.23467.22971.22490.22025.21573.21135.20710.20299.19899
66.25233.24709.24202.23709.23231.22767.22318.21881.21457.21045
67.26543.26009.25489.24985.24496.24021.23560.23111.22676.22252
68.27908.27363.26833.26319.25819.25332.24860.24400.23954.23519
69.29324.28769.28230.27705.27195.26699.26216.25746.25288.24843
70.30783.30219.29671.29137.28618.28112.27619.27139.26672.26216
71.32277.31706.31150.30608.30079.29564.29063.28573.28096.27631
72.33803.33225.32661.32112.31575.31052.30542.30044.29559.29084
73.35356.34772.34201.33645.33101.32571.32053.31547.31053.30571
74.36943.36354.35778.35215.34666.34129.33604.33091.32590.32100
75.38574.37980.37400.36833.36278.35735.35205.34686.34178.33681
76.40256.39660.39076.38505.37947.37400.36864.36340.35827.35324
77.41991.41394.40808.40235.39674.39124.38585.38056.37539.37032
78.43777.43180.42594.42020.41457.40906.40365.39834.39314.38803
79.45602.45007.44422.43849.43287.42735.42193.41661.41139.40627
80.47449.46856.46275.45704.45143.44592.44051.43519.42997.42484
81.49300.48712.48134.47566.47008.46460.45921.45391.44870.44357
82.51145.50563.49990.49427.48873.48328.47792.47265.46746.46235
83.52983.52407.51841.51284.50735.50195.49663.49139.48624.48116
84.54828.54261.53702.53151.52609.52075.51549.51030.50519.50015
85.56693.56135.55586.55044.54510.53983.53464.52952.52447.51949
86.58560.58013.57474.56943.56418.55901.55390.54886.54389.53898
87.60398.59864.59337.58817.58303.57795.57294.56799.56310.55828
88.62206.61685.61170.60662.60159.59663.59173.58688.58209.57736
89.63980.63474.62972.62477.61987.61503.61024.60551.60083.59620
90.65719.65227.64741.64259.63783.63312.62846.62385.61928.61477
91.67388.66912.66440.65973.65511.65053.64600.64152.63708.63269
92.68949.68487.68030.67577.67129.66685.66245.65809.65378.64950
93.70401.69954.69511.69072.68637.68205.67778.67355.66935.66519
94.71765.71332.70902.70477.70055.69636.69222.68810.68403.67998
July 3, 2000322000–27 I.R.B.

TABLE U(1)
BASED ON LIFE TABLE 90CM
UNITRUST SINGLE LIFE REMAINDER FACTORS
APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999
ADJUSTED PAYOUT RATE
AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0%
95.73072.72653.72237.71825.71416.71010.70608.70209.69813.69421
96.74311.73906.73504.73105.72709.72316.71926.71539.71155.70774
97.75465.75073.74684.74297.73914.73533.73155.72780.72407.72037
98.76555.76175.75798.75424.75052.74683.74317.73953.73591.73232
99.77626.77260.76895.76534.76174.75817.75462.75109.74759.74411
100.78676.78323.77971.77622.77274.76929.76586.76245.75906.75569
101.79719.79379.79040.78703.78368.78035.77704.77375.77048.76722
102.80749.80422.80096.79772.79450.79130.78811.78494.78178.77864
103.81775.81461.81149.80838.80529.80221.79914.79609.79306.79003
104.82881.82582.82284.81988.81693.81399.81106.80815.80525.80236
105.83959.83674.83391.83108.82826.82546.82267.81988.81711.81435
106.85373.85108.84844.84581.84319.84058.83797.83537.83278.83020
107.87113.86875.86636.86399.86161.85925.85689.85453.85218.84984
108.89913.89721.89529.89337.89145.88953.88762.88571.88380.88189
109.94900.94800.94700.94600.94500.94400.94300.94200.94100.94000
2000–27 I.R.B.33July 3, 2000
TABLE U(1)
BASED ON LIFE TABLE 90CM
UNITRUST SINGLE LIFE REMAINDER FACTORS
APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999
ADJUSTED PAYOUT RATE
AGE12.2%12.4%12.6%12.8%13.0%13.2%13.4%13.6%13.8%14.0%
0.01208.01197.01187.01177.01168.01159.01151.01143.01135.01128
1.00378.00367.00358.00348.00340.00331.00323.00316.00309.00302
2.00353.00342.00331.00322.00312.00304.00295.00288.00280.00273
3.00350.00339.00327.00317.00307.00298.00289.00281.00273.00265
4.00359.00347.00335.00324.00313.00303.00294.00285.00276.00268
5.00377.00363.00351.00339.00327.00317.00306.00297.00288.00279
6.00400.00386.00372.00359.00347.00335.00325.00314.00305.00295
7.00430.00414.00400.00386.00373.00360.00349.00338.00327.00317
8.00465.00448.00432.00417.00403.00390.00378.00366.00354.00344
9.00508.00490.00473.00457.00442.00428.00414.00402.00389.00378
10.00560.00541.00523.00506.00490.00475.00460.00446.00433.00421
11.00620.00600.00581.00563.00546.00529.00514.00499.00485.00472
12.00689.00668.00647.00628.00610.00593.00576.00560.00545.00531
13.00763.00740.00718.00698.00678.00660.00642.00626.00610.00595
14.00834.00810.00787.00766.00745.00726.00707.00689.00673.00657
15.00901.00875.00851.00828.00807.00786.00767.00748.00730.00714
16.00959.00932.00907.00883.00860.00839.00818.00799.00780.00762
17.01011.00983.00956.00930.00907.00884.00862.00842.00822.00804
18.01057.01027.00999.00972.00947.00923.00900.00879.00858.00839
19.01101.01070.01040.01012.00985.00960.00936.00914.00892.00871

TABLE U(1)
BASED ON LIFE TABLE 90CM
UNITRUST SINGLE LIFE REMAINDER FACTORS
APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999
ADJUSTED PAYOUT RATE
AGE12.2%12.4%12.6%12.8%13.0%13.2%13.4%13.6%13.8%14.0%
20.01148.01115.01083.01054.01026.00999.00974.00950.00927.00905
21.01197.01162.01129.01098.01068.01040.01014.00988.00964.00941
22.01249.01211.01176.01143.01112.01082.01054.01027.01002.00978
23.01304.01264.01227.01192.01159.01127.01098.01069.01042.01017
24.01364.01322.01283.01246.01210.01177.01145.01115.01087.01060
25.01431.01387.01345.01306.01268.01233.01199.01168.01137.01109
26.01506.01459.01415.01373.01333.01295.01260.01226.01194.01163
27.01591.01541.01494.01449.01407.01367.01329.01293.01259.01226
28.01684.01631.01580.01533.01488.01445.01405.01367.01330.01296
29.01785.01728.01675.01624.01577.01531.01488.01447.01408.01372
30.01893.01833.01776.01723.01672.01623.01578.01534.01493.01453
31.02010.01946.01885.01828.01773.01722.01673.01627.01582.01540
32.02134.02066.02002.01940.01883.01828.01776.01726.01679.01634
33.02270.02197.02128.02063.02002.01943.01887.01835.01784.01736
34.02415.02338.02265.02195.02130.02067.02008.01951.01897.01846
35.02574.02492.02414.02340.02270.02203.02140.02080.02022.01967
36.02746.02658.02575.02496.02422.02350.02283.02218.02157.02098
37.02932.02838.02750.02666.02586.02510.02438.02369.02303.02241
38.03135.03035.02941.02851.02766.02685.02608.02534.02464.02397
39.03355.03249.03149.03053.02962.02876.02793.02715.02640.02568
40.03596.03484.03377.03275.03178.03086.02998.02914.02833.02757
41.03861.03742.03628.03520.03416.03318.03224.03134.03048.02966
42.04152.04025.03903.03788.03678.03573.03473.03377.03285.03198
43.04468.04333.04205.04082.03965.03853.03746.03644.03546.03453
44.04813.04670.04533.04403.04278.04159.04045.03936.03832.03732
45.05183.05032.04887.04748.04616.04489.04368.04252.04141.04034
46.05582.05421.05267.05121.04980.04846.04717.04593.04475.04362
47.06006.05836.05673.05518.05369.05226.05089.04958.04832.04711
48.06459.06279.06107.05943.05785.05634.05488.05349.05216.05087
49.06942.06752.06571.06397.06230.06070.05916.05768.05626.05490
50.07459.07259.07068.06884.06708.06538.06376.06219.06069.05924
51.08012.07801.07599.07406.07220.07041.06869.06703.06544.06391
52.08596.08375.08163.07959.07763.07574.07392.07218.07049.06887
53.09214.08982.08759.08544.08338.08139.07948.07763.07586.07415
54.09867.09623.09389.09164.08946.08737.08536.08342.08154.07974
55.10556.10301.10055.09819.09591.09371.09159.08955.08757.08567
56.11283.11016.10759.10511.10272.10042.09819.09605.09397.09197
57.12050.11771.11502.11243.10993.10751.10518.10293.10075.09864
58.12852.12562.12281.12011.11749.11496.11252.11016.10787.10567
59.13687.13385.13092.12810.12537.12273.12017.11770.11531.11299
60.14554.14240.13935.13641.13356.13080.12813.12555.12305.12063
61.15457.15130.14813.14507.14210.13923.13644.13375.13113.12860
62.16402.16063.15734.15415.15107.14808.14518.14237.13964.13699
63.17393.17042.16700.16370.16049.15738.15437.15144.14860.14584
64.18429.18065.17712.17369.17036.16714.16400.16096.15800.15513
July 3, 2000342000–27 I.R.B.

TABLE U(1)
BASED ON LIFE TABLE 90CM
UNITRUST SINGLE LIFE REMAINDER FACTORS
APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999
ADJUSTED PAYOUT RATE
AGE12.2%12.4%12.6%12.8%13.0%13.2%13.4%13.6%13.8%14.0%
65.19511.19135.18769.18415.18070.17735.17410.17094.16787.16488
66.20645.20257.19880.19513.19157.18810.18473.18146.17827.17517
67.21841.21441.21052.20673.20305.19947.19599.19259.18929.18608
68.23096.22685.22284.21895.21515.21146.20786.20436.20094.19762
69.24409.23987.23575.23175.22784.22404.22033.21672.21320.20976
70.25772.25339.24918.24507.24106.23715.23333.22961.22598.22244
71.27178.26735.26304.25882.25471.25070.24679.24296.23923.23559
72.28622.28170.27729.27298.26877.26467.26065.25673.25290.24915
73.30100.29639.29189.28749.28320.27899.27489.27087.26694.26310
74.31621.31152.30694.30246.29807.29378.28959.28548.28146.27753
75.33195.32719.32253.31797.31351.30914.30486.30067.29657.29255
76.34832.34350.33877.33415.32961.32517.32082.31656.31238.30828
77.36535.36047.35570.35101.34642.34192.33750.33317.32892.32475
78.38302.37811.37329.36856.36392.35937.35490.35051.34621.34198
79.40124.39630.39145.38669.38201.37742.37291.36848.36413.35985
80.41980.41485.40998.40520.40050.39588.39134.38688.38249.37818
81.43854.43358.42871.42392.41921.41457.41001.40553.40112.39678
82.45733.45238.44752.44273.43802.43338.42881.42431.41989.41553
83.47616.47123.46638.46161.45690.45227.44770.44320.43877.43441
84.49519.49030.48548.48073.47604.47143.46688.46239.45797.45361
85.51458.50974.50496.50025.49560.49102.48650.48204.47763.47329
86.53413.52935.52463.51998.51538.51084.50636.50194.49758.49327
87.55351.54881.54416.53957.53503.53055.52613.52176.51744.51317
88.57268.56806.56349.55898.55451.55010.54574.54144.53718.53296
89.59162.58710.58262.57819.57382.56949.56520.56097.55678.55263
90.61030.60588.60151.59718.59290.58866.58447.58032.57621.57214
91.62834.62403.61977.61554.61136.60722.60312.59907.59505.59107
92.64527.64107.63692.63280.62872.62468.62068.61672.61279.60890
93.66107.65699.65294.64893.64495.64101.63711.63323.62940.62559
94.67597.67200.66806.66415.66027.65643.65262.64884.64509.64138
95.69031.68645.68262.67881.67504.67130.66759.66390.66025.65662
96.70396.70021.69648.69279.68912.68548.68186.67828.67471.67118
97.71670.71305.70943.70584.70227.69872.69520.69171.68824.68480
98.72875.72521.72169.71819.71472.71127.70784.70444.70106.69770
99.74065.73721.73379.73040.72703.72368.72035.71704.71375.71048
100.75234.74901.74570.74241.73914.73589.73265.72944.72625.72307
101.76399.76077.75757.75438.75122.74807.74494.74183.73873.73565
102.77552.77241.76932.76625.76319.76015.75712.75411.75111.74813
103.78703.78404.78106.77809.77514.77221.76929.76638.76348.76060
104.79948.79662.79377.79093.78810.78528.78248.77969.77691.77414
105.81159.80885.80612.80340.80069.79799.79530.79262.78995.78729
106.82763.82506.82250.81995.81741.81488.81235.80983.80732.80482
107.84749.84516.84283.84051.83819.83587.83356.83126.82896.82666
108.87999.87808.87618.87428.87238.87049.86859.86670.86481.86293
109.93900.93800.93700.93600.93500.93400.93300.93200.93100.93000
2000–27 I.R.B.35July 3, 2000

(f) Effective dates. This section applies
after April 30, 1999.
§1.664–4T [Removed]
Par. 8. Section 1.664–4T is removed.
Par. 9. Section 1.7520–1 is amended
by:
1. Revising paragraph (b)(2).
2. Revising paragraphs (c)(1) and
(c)(2).
3. Revising paragraph (d).
The revisions read as follows:
§1.7520–1 Valuation of annuities, unitrust
interests, interests for life or terms of
years, and remainder or reversionary in-
terests.
* * * * *
(b) * * *
(2) Mortality component. The mortality
component reflects the mortality data
most recently available from the United
States census. As new mortality data be-
comes available after each decennial cen-
sus, the mortality component described in
this section will be revised periodically
and the revised mortality component ta-
bles will be published in the regulations at
that time. For transactions with valuation
dates after April 30, 1999, the mortality
component table (Table 90CM) is con-
tained in §20.2031–7(d)(7) of this chap-
ter. See §20.2031–7A of this chapter for
mortality component tables applicable to
transactions for which the valuation date
falls before May 1, 1999.
(c) * * *
(1) Regulation sections containing ta-
bles with interest rates between 4.2 and
14 percent for valuation dates after April
30, 1999. Section 1.642(c)–6(e)(6) con-
tains Table S used for determining the
present value of a single life remainder in-
terest in a pooled income fund as defined
in §1.642(c)–5. See §1.642(c)–6A for ac-
tuarial factors for one life applicable to
valuation dates before May 1, 1999. Sec-
tion 1.664–4(e)(6) contains Table F (pay-
out factors) and Table D (actuarial factors
used in determining the present value of a
remainder interest postponed for a term of
years). Section 1.664–4(e)(7) contains
Table U(1) (unitrust single life remainder
factors). These tables are used in deter-
mining the present value of a remainder
interest in a charitable remainder unitrust
as defined in §1.664–3. See §1.664–4A
for unitrust single life remainder factors
applicable to valuation dates before May
1, 1999. Section 20.2031–7(d)(6) of this
chapter contains Table B (actuarial factors
used in determining the present value of
an interest for a term of years), Table K
(annuity end-of-interval adjustment fac-
tors), and Table J (term certain annuity
beginning-of-interval adjustment factors).
Section 20.2031–7(d)(7) of this chapter
contains Table S (single life remainder
factors), and Table 90CM (mortality com-
ponents). These tables are used in deter-
mining the present value of annuities, life
estates, remainders, and reversions. See
§20.2031–7A of this chapter for single
life remainder factors and mortality com-
ponents applicable to valuation dates be-
fore May 1, 1999.
(2) Internal Revenue Service publica-
tions containing tables with interest rates
between 2.2 and 22 percent for valuation
dates after April 30, 1999. The following
documents are available for purchase
from the Superintendent of Documents,
United States Government Printing Of-
fice, Washington, DC 20402:
(i) Internal Revenue Service Publica-
tion 1457, “Actuarial Values, Book
Aleph,” (7-1999). This publication in-
cludes tables of valuation factors, as well
as examples that show how to compute
other valuation factors, for determining
the present value of annuities, life estates,
terms of years, remainders, and rever-
sions, measured by one or two lives.
These factors may also be used in the val-
uation of interests in a charitable remain-
der annuity trust as defined in §1.664–2
and a pooled income fund as defined in
§1.642(c)–5. See §20.2031–7A of this
chapter for publications containing tables
for valuation dates before May 1, 1999.
(ii) Internal Revenue Service Publica-
tion 1458, “Actuarial Values, Book Beth,”
(7-1999). This publication includes term
certain tables and tables of one and two
life valuation factors for determining the
present value of remainder interests in a
charitable remainder unitrust as defined in
§1.664–3. See §1.664–4A for publica-
tions containing tables for valuation dates
before May 1, 1999.
(iii) Internal Revenue Service Publica-
tion 1459, “Actuarial Values, Book
Gimel,” (7-1999). This publication in-
cludes tables for computing depreciation
adjustment factors. See §1.170A–12.
(d) Effective date. This section applies
after April 30, 1989.
§1.7520–1T [Removed]
Par. 10. Section 1.7520–1T is re-
moved.
PART 20—ESTATE TAX; ESTATES OF
DECEDENTS DYING AFTER
AUGUST 16, 1954
Par. 11. The authority citation for part
20 is amended by removing entries for
sections 20.2031–7T and 20.7520–1T to
read in part as follows:
Authority: 26 U.S.C. 7805 * * *
§20.2031–0 [Amended]
Par. 12 Section 20.2031–0 is amended
by removing the entry for §20.2031–7T
from the contents listing.
Par. 13. Section 20.2031–7 is amended
by:
1. Removing existing paragraphs (c)
through (d)(5).
2. Adding paragraphs (c), (d) heading,
and (d)(1) through (d)(5).
3. Revising the introductory text of
paragraph (d)(6).
4. Adding paragraph (d)(7).
5. Revising paragraph (e).
The revisions and additions read as fol-
lows:
§20.2031–7 Valuation of annuities, inter-
ests for life or term of years, and remain-
der or reversionary interests.
* * * * *
(c) Actuarial valuations. The present
value of annuities, life estates, terms of
years, remainders, and reversions for es-
tates of decedents for which the valuation
date of the gross estate is after April 30,
1999, is determined under paragraph (d)
of this section. The present value of an-
nuities, life estates, terms of years, re-
mainders, and reversions for estates of
decedents for which the valuation date of
the gross estate is before May 1, 1999, is
determined under the following sections:
July 3, 2000362000–27 I.R.B.

(d) Actuarial valuations after April 30,
1999—(1) In general. Except as otherwise
provided in paragraph (b) of this section
and §20.7520–3(b) (pertaining to certain
limitations on the use of prescribed tables),
if the valuation date for the gross estate of
the decedent is after April 30, 1999, the fair
market value of annuities, life estates, terms
of years, remainders, and reversionary in-
terests is the present value determined by
use of standard or special section 7520 ac-
tuarial factors. These factors are derived by
using the appropriate section 7520 interest
rate and, if applicable, the mortality compo-
nent for the valuation date of the interest
that is being valued. For purposes of the
computations described in this section, the
age of an individual is the age of that indi-
vidual at the individual’s nearest birthday.
See §§20.7520–1 through 20.7520–4.
(2) Specific interests—(i) Charitable re-
mainder trusts. The fair market value of a
remainder interest in a pooled income fund,
as defined in §1.642(c)–5 of this chapter, is
its value determined under §1.642(c)–6(e)
of this chapter. The fair market value of a
remainder interest in a charitable remainder
annuity trust, as defined in §1.664–2(a) of
this chapter, is the present value determined
under §1.664–2(c) of this chapter. The fair
market value of a remainder interest in a
charitable remainder unitrust, as defined in
§1.664–3 of this chapter, is its present value
determined under §1.664–4(e) of this chap-
ter. The fair market value of a life interest
or term of years in a charitable remainder
unitrust is the fair market value of the prop-
erty as of the date of valuation less the fair
market value of the remainder interest on
that date determined under §1.664–4(e)(4)
and (5) of this chapter.
(ii) Ordinary remainder and reversion-
ary interests. If the interest to be valued is
to take effect after a definite number of
years or after the death of one individual,
the present value of the interest is computed
by multiplying the value of the property by
the appropriate remainder interest actuarial
factor (that corresponds to the applicable
section 7520 interest rate and remainder in-
terest period) in Table B (for a term certain)
or the appropriate Table S (for one measur-
ing life), as the case may be. Table B is
contained in paragraph (d)(6) of this section
and Table S (for one measuring life when
the valuation date is after April 30, 1999) is
contained in paragraph (d)(7) of this section
and in Internal Revenue Service Publica-
tion 1457. For information about obtaining
actuarial factors for other types of remain-
der interests, see paragraph (d)(4) of this
section.
(iii) Ordinary term-of-years and life in-
terests. If the interest to be valued is the
right of a person to receive the income of
certain property, or to use certain nonin-
come-producing property, for a term of
years or for the life of one individual, the
present value of the interest is computed by
multiplying the value of the property by the
appropriate term-of-years or life interest ac-
tuarial factor (that corresponds to the ap-
plicable section 7520 interest rate and term-
of-years or life interest period). Internal
Revenue Service Publication 1457 includes
actuarial factors for an interest for a term of
years in Table B and for the life of one indi-
vidual in Table S (for one measuring life
when the valuation date is after April 30,
1999). However, term-of-years and life in-
terest actuarial factors are not included in
Table B in paragraph (d)(6) of this section
or Table S in paragraph (d)(7) of this sec-
tion. If Internal Revenue Service Publica-
tion 1457 (or any other reliable source of
term-of-years and life interest actuarial fac-
tors) is not conveniently available, an actu-
arial factor for the interest may be derived
mathematically. This actuarial factor may
be derived by subtracting the correlative re-
mainder factor (that corresponds to the ap-
plicable section 7520 interest rate and the
term of years or the life) in Table B (for a
term of years) in paragraph (d)(6) of this
section or in Table S (for the life of one in-
dividual) in paragraph (d)(7) of this section,
as the case may be, from 1.000000. For in-
formation about obtaining actuarial factors
for other types of term-of-years and life in-
terests, see paragraph (d)(4) of this section.
(iv) Annuities. (A) If the interest to be
valued is the right of a person to receive an
annuity that is payable at the end of each
year for a term of years or for the life of one
individual, the present value of the interest
is computed by multiplying the aggregate
amount payable annually by the appropri-
ate annuity actuarial factor (that corre-
sponds to the applicable section 7520 inter-
est rate and annuity period). Internal
Revenue Publication 1457 includes actuar-
ial factors in Table B (for an annuity
payable for a term of years) and in Table S
(for an annuity payable for the life of one
individual when the valuation date is after
April 30, 1999). However, annuity actuar-
ial factors are not included in Table B in
paragraph (d)(6) of this section or Table S
in paragraph (d)(7) of this section. If Inter-
nal Revenue Service Publication 1457 (or
any other reliable source of annuity actuar-
ial factors) is not conveniently available, a
required annuity factor for a term of years
or for one life may be mathematically de-
rived. This annuity factor may be derived
by subtracting the applicable remainder
factor (that corresponds to the applicable
section 7520 interest rate and annuity pe-
riod) in Table B (in the case of a term-of-
years annuity) in paragraph (d)(6) of this
section or in Table S (in the case of a one-
life annuity when the valuation date is after
April 30, 1999) in paragraph (d)(7) of this
section, as the case may be, from 1.000000
and then dividing the result by the applica-
ble section 7520 interest rate expressed as a
decimal number.
(B) If the annuity is payable at the end of
semiannual, quarterly, monthly, or weekly
periods, the product obtained by multiply-
ing the annuity factor by the aggregate
amount payable annually is then multiplied
by the applicable adjustment factor as con-
tained in Table K in paragraph (d)(6) of this
section for payments made at the end of the
specified periods. The provisions of this
paragraph (d)(2)(iv)(B) are illustrated by
the following example:
Example. At the time of the decedent’s death, the
survivor/annuitant, age 72, is entitled to receive an an-
2000–27 I.R.B.37July 3, 2000
Valuation DateApplicable
AfterBeforeRegulations
01-01-5220.2031–7A(a)
12-31-5101-01-7120.2031–7A(b)
12-31-7012-01-8320.2031–7A(c)
11-30-8305-01-8920.2031–7A(d)
04-30-8905-01-9920.2031–7A(e)

nuity of $15,000 a year for life payable in equal
monthly installments at the end of each period. The
section 7520 rate for the month in which the decedent
died is 9.6 percent. Under Table S in paragraph (d)(7)
of this section, the remainder factor at 9.6 percent for
an individual aged 72 is .38438. By converting the re-
mainder factor to an annuity factor, as described
above, the annuity factor at 9.6 percent for an individ-
ual aged 72 is 6.4127 (1.00000 minus .38438, divided
by .096). Under Table K in paragraph (d)(6) of this
section, the adjustment factor under the column for
payments made at the end of each monthly period at
the rate of 9.6 percent is 1.0433. The aggregate annual
amount, $15,000, is multiplied by the factor 6.4127
and the product multiplied by 1.0433. The present
value of the annuity at the date of the decedent’s death
is, therefore, $100,355.55 ($15,000 x 6.4127 x
1.0433).
(C) If an annuity is payable at the begin-
ning of annual, semiannual, quarterly,
monthly, or weekly periods for a term of
years, the value of the annuity is computed
by multiplying the aggregate amount
payable annually by the annuity factor de-
scribed in paragraph (d)(2)(iv)(A) of this
section; and the product so obtained is then
multiplied by the adjustment factor in Table
J in paragraph (d)(6) of this section at the
appropriate interest rate component for
payments made at the beginning of speci-
fied periods. If an annuity is payable at the
beginning of annual, semiannual, quarterly,
monthly, or weekly periods for one or more
lives, the value of the annuity is the sum of
the first payment plus the present value of a
similar annuity, the first payment of which
is not to be made until the end of the pay-
ment period, determined as provided in this
paragraph (d)(2)(iv).
(v) Annuity and unitrust interests for a
term of years or until the prior death of an
individual. See §25.2512–5(d)(2)(v) of this
chapter for examples explaining how to
compute the present value of an annuity or
unitrust interest that is payable until the ear-
lier of the lapse of a specific number of
years or the death of an individual.
(3) Transitional rule. (i) If a decedent
dies after April 30, 1999, and if on May 1,
1999, the decedent was mentally incompe-
tent so that the disposition of the decedent’s
property could not be changed, and the
decedent dies without having regained
competency to dispose of the decedent’s
property or dies within 90 days of the date
on which the decedent first regains compe-
tency, the fair market value of annuities,
life estates, terms for years, remainders,
and reversions included in the gross estate
of the decedent is their present value deter-
mined either under this section or under the
corresponding section applicable at the
time the decedent became mentally incom-
petent, at the option of the decedent’s ex-
ecutor. For example, see
§20.2031–7A(e)(2).
(ii) If a decedent dies after April 30,
1999, and before July 1, 1999, the fair mar-
ket value of annuities, life estates, remain-
ders, and reversions based on one or more
measuring lives included in the gross estate
of the decedent is their present value deter-
mined under this section by use of the sec-
tion 7520 interest rate for the month in
which the valuation date occurs (see
§§20.7520–1(b) and 20.7520-2(a)(2)) and
the appropriate actuarial tables under either
paragraph (d)(7) of this section or
§20.2031–7A(e)(4), at the option of the
decedent’s executor.
(iii) For purposes of paragraphs (d)(3)(i)
and (ii) of this section, where the dece-
dent’s executor is given the option to use
the appropriate actuarial tables under either
paragraph (d)(7) of this section or
§20.2031–7A(e)(4), the decedent’s execu-
tor must use the same actuarial table with
respect to each individual transaction and
with respect to all transfers occurring on the
valuation date (for example, gift and in-
come tax charitable deductions with respect
to the same transfer must be determined
based on the same tables, and all assets in-
cludible in the gross estate and/or estate tax
deductions claimed must be valued based
on the same tables).
(4) Publications and actuarial computa-
tions by the Internal Revenue Service.
Many standard actuarial factors not in-
cluded in paragraphs (d)(6) or (d)(7) of this
section are included in Internal Revenue
Service Publication 1457, “Actuarial Val-
ues, Book Aleph,” (7-1999). Publication
1457 also includes examples that illustrate
how to compute many special factors for
more unusual situations. A copy of this
publication is available for purchase from
the Superintendent of Documents, United
States Government Printing Office, Wash-
ington, DC 20402. See §20.2031–7A for
publications containing actuarial factors for
valuing interests for which the valuation
date is before May 1, 1999. If a special fac-
tor is required in the case of an actual dece-
dent, the Internal Revenue Service may fur-
nish the factor to the executor upon a
request for a ruling. The request for a rul-
ing must be accompanied by a recitation of
the facts including a statement of the date
of birth for each measuring life, the date of
the decedent’s death, any other applicable
dates, and a copy of the will, trust, or other
relevant documents. A request for a ruling
must comply with the instructions for re-
questing a ruling published periodically in
the Internal Revenue Bulletin (see
§§601.201 and 601.601(d)(2)(ii)(b
) of this
chapter) and include payment of the re-
quired user fee.
(5) Examples. The provisions of this
section are illustrated by the following ex-
amples:
Example 1. Remainder payable at an individual’s
death.The decedent, or the decedent’s estate, was en-
titled to receive certain property worth $50,000 upon
the death of A, to whom the income was bequeathed
for life. At the time of the decedent’s death, A was 47
years 5 months old. In the month in which the dece-
dent died, the section 7520 rate was 9.8 percent.
Under Table S in paragraph (d)(7) of this section, the
remainder factor at 9.8 percent for determining the
present value of the remainder interest due at the death
of a person aged 47, the number of years nearest A’s
actual age at the decedent’s death, is .10317. The pre-
sent value of the remainder interest at the date of the
decedent’s death is, therefore, $5,158.50 ($50,000 X
.10317).
Example 2. Income payable for an individual’s life.
A’s parent bequeathed an income interest in property
to A for life, with the remainder interest passing to B at
A’s death. At the time of the parent’s death, the value
of the property was $50,000 and A was 30 years 10
months old. The section 7520 rate at the time of the
parent’s death was 10.2 percent. Under Table S in
paragraph (d)(7) of this section, the remainder factor at
10.2 percent for determining the present value of the
remainder interest due at the death of a person aged
31, the number of years closest to A’s age at the dece-
dent’s death, is .03583. Converting this remainder fac-
tor to an income factor, as described in paragraph
(d)(2)(iii) of this section, the factor for determining the
present value of an income interest for the life of a per-
son aged 31 is .96417. The present value of A’s inter-
est at the time of the parent’s death is, therefore,
$48,208.50 ($50,000 X .96417).
Example 3. Annuity payable for an individual’s
life.A purchased an annuity for the benefit of both A
and B. Under the terms of the annuity contract, at A’s
death, a survivor annuity of $10,000 a year payable in
equal semiannual installments made at the end of each
interval is payable to B for life. At A’s death, B was 45
years 7 months old. Also, at A’s death, the section
7520 rate was 9.6 percent. Under Table S in paragraph
(d)(7) of this section, the factor at 9.6 percent for de-
termining the present value of the remainder interest at
the death of a person age 46 (the number of years near-
est B’s actual age) is .10013. By converting the factor
to an annuity factor, as described in paragraph
(d)(2)(iv)(A) of this section, the factor for the present
value of an annuity payable until the death of a person
age 46 is 9.3736 (1.00000 minus .10013, divided by
.096). The adjustment factor from Table K in para-
graph (d)(6) of this section at an interest rate of 9.6
percent for semiannual annuity payments made at the
end of the period is 1.0235. The present value of the
annuity at the date of A’s death is, therefore,
July 3, 2000382000–27 I.R.B.

$95,938.80 ($10,000 X 9.3736 X 1.0235).
Example 4. Annuity payable for a term of years.
The decedent, or the decedent’s estate, was entitled to
receive an annuity of $10,000 a year payable in equal
quarterly installments at the end of each quarter
throughout a term certain. At the time of the dece-
dent’s death, the section 7520 rate was 9.8 percent. A
quarterly payment had just been made prior to the
decedent’s death and payments were to continue for 5
more years. Under Table B in paragraph (d)(6) of this
section for the interest rate of 9.8 percent, the factor
for the present value of a remainder interest due after a
term of 5 years is .626597. Converting the factor to an
annuity factor, as described in paragraph (d)(2)(iv)(A)
of this section, the factor for the present value of an
annuity for a term of 5 years is 3.8102. The adjust-
ment factor from Table K in paragraph (d)(6) of this
section at an interest rate of 9.8 percent for quarterly
annuity payments made at the end of the period is
1.0360. The present value of the annuity is, therefore,
$39,473.67 ($10,000 X 3.8102 X 1.0360).
(6) Actuarial Table B, Table J, and Table
K where the valuation date is after April 30,
1989. Except as provided in
§20.7520–3(b) (pertaining to certain limita-
tions on prescribed tables), for determina-
tion of the present value of an interest that
is dependent on a term of years, the tables
in this paragraph (d)(6) must be used in the
application of the provisions of this section
when the section 7520 interest rate compo-
nent is between 4.2 and 14 percent.
* * * * *
(7) Actuarial Table S and Table 90CM
where the valuation date is after April 30,
1999. Except as provided in
§20.7520–2(b) (pertaining to certain limita-
tions on the use of prescribed tables), for
determination of the present value of an in-
terest that is dependent on the termination
of a life interest, Table 90CM and Table S,
single life remainder factors applicable
where the valuation date is after April 30,
1999, contained in this paragraph (d)(7) (or
Table S and Table 80CNSMT contained in
§20.2031–7A(e)(4) for valuation dates after
April 30, 1989, and before May 1, 1999)
and Table J and Table K contained in para-
graph (d)(6) of this section, must be used in
the application of the provisions of this sec-
tion when the section 7520 interest rate
component is between 4.2 and 14 percent.
2000–27 I.R.B.39July 3, 2000
TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0%
0.06752.06130.05586.05109.04691.04322.03998.03711.03458.03233
1.06137.05495.04932.04438.04003.03620.03283.02985.02721.02487
2.06325.05667.05088.04580.04132.03737.03388.03079.02806.02563
3.06545.05869.05275.04752.04291.03883.03523.03203.02920.02668
4.06784.06092.05482.04944.04469.04048.03676.03346.03052.02791
5.07040.06331.05705.05152.04662.04229.03845.03503.03199.02928
6.07310.06583.05941.05372.04869.04422.04025.03672.03357.03076
7.07594.06849.06191.05607.05089.04628.04219.03854.03528.03236
8.07891.07129.06453.05853.05321.04846.04424.04046.03709.03407
9.08203.07423.06731.06115.05567.05079.04643.04253.03904.03592
10.08532.07734.07024.06392.05829.05326.04877.04474.04114.03790
11.08875.08059.07331.06683.06104.05587.05124.04709.04336.04002
12.09233.08398.07653.06989.06394.05862.05385.04957.04572.04226
13.09601.08748.07985.07304.06693.06146.05655.05214.04816.04458
14.09974.09102.08322.07624.06997.06435.05929.05474.05064.04694
15.10350.09460.08661.07946.07303.06725.06204.05735.05312.04930
16.10728.09818.09001.08268.07608.07014.06479.05996.05559.05164
17.11108.10179.09344.08592.07916.07306.06755.06257.05807.05399
18.11494.10545.09691.08921.08227.07601.07034.06521.06057.05636
19.11889.10921.10047.09259.08548.07904.07322.06794.06315.05880
20.12298.11310.10417.09610.08881.08220.07622.07078.06584.06135
21.12722.11713.10801.09976.09228.08550.07935.07375.06866.06403
22.13159.12130.11199.10354.09588.08893.08260.07685.07160.06682
23.13613.12563.11612.10748.09964.09250.08601.08009.07468.06975
24.14084.13014.12043.11160.10357.09625.08958.08349.07793.07284
25.14574.13484.12493.11591.10768.10018.09334.08708.08135.07611
26.15084.13974.12963.12041.11199.10431.09728.09085.08496.07956
27.15615.14485.13454.12513.11652.10865.10144.09484.08878.08322
28.16166.15016.13965.13004.12124.11319.10580.09901.09279.08706
29.16737.15567.14497.13516.12617.11792.11035.10339.09699.09109

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0%
30.17328.16138.15048.14047.13129.12286.11510.10796.10138.09532
31.17938.16728.15618.14599.13661.12799.12004.11272.10597.09974
32.18568.17339.16210.15171.14214.13333.12520.11769.11076.10435
33.19220.17972.16824.15766.14790.13889.13058.12289.11578.10920
34.19894.18627.17460.16383.15388.14468.13618.12831.12102.11426
35.20592.19307.18121.17025.16011.15073.14204.13399.12652.11958
36.21312.20010.18805.17691.16658.15701.14814.13990.13225.12514
37.22057.20737.19514.18382.17331.16356.15450.14608.13825.13096
38.22827.21490.20251.19100.18031.17038.16113.15253.14452.13705
39.23623.22270.21013.19845.18759.17747.16805.15927.15108.14344
40.24446.23078.21805.20620.19516.18487.17527.16631.15795.15013
41.25298.23915.22626.21425.20305.19259.18282.17368.16514.15715
42.26178.24782.23478.22262.21125.20062.19069.18138.17267.16450
43.27087.25678.24360.23129.21977.20898.19888.18941.18053.17220
44.28025.26603.25273.24027.22860.21766.20740.19777.18873.18023
45.28987.27555.26212.24953.23772.22664.21622.20644.19724.18858
46.29976.28533.27179.25908.24714.23591.22536.21542.20606.19725
47.30987.29535.28171.26889.25682.24546.23476.22468.21518.20621
48.32023.30563.29190.27897.26678.25530.24447.23425.22460.21549
49.33082.31615.30234.28931.27702.26543.25447.24412.23434.22509
50.34166.32694.31306.29995.28756.27586.26479.25432.24441.23502
51.35274.33798.32404.31085.29838.28658.27541.26482.25479.24528
52.36402.34924.33525.32200.30946.29757.28630.27561.26547.25584
53.37550.36070.34668.33339.32078.30882.29746.28667.27643.26669
54.38717.37237.35833.34500.33234.32031.30888.29801.28766.27782
55.39903.38424.37019.35683.34413.33205.32056.30961.29918.28925
56.41108.39631.38227.36890.35617.34405.33250.32149.31099.30097
57.42330.40857.39455.38118.36844.35629.34469.33363.32306.31297
58.43566.42098.40699.39364.38089.36873.35710.34600.33538.32522
59.44811.43351.41956.40623.39350.38133.36968.35855.34789.33768
60.46066.44613.43224.41896.40624.39408.38243.37127.36058.35033
61.47330.45887.44505.43182.41914.40699.39535.38418.37347.36318
62.48608.47175.45802.44485.43223.42011.40848.39732.38660.37629
63.49898.48478.47115.45807.44550.43343.42184.41069.39997.38966
64.51200.49793.48442.47143.45895.44694.43539.42427.41357.40326
65.52512.51121.49782.48495.47255.46062.44912.43805.42738.41709
66.53835.52461.51137.49862.48634.47449.46307.45206.44143.43118
67.55174.53818.52511.51250.50034.48860.47727.46633.45576.44556
68.56524.55188.53899.52654.51452.50291.49168.48083.47034.46020
69.57882.56568.55299.54071.52885.51737.50627.49552.48513.47506
70.59242.57951.56703.55495.54325.53193.52096.51034.50004.49007
71.60598.59332.58106.56918.55767.54651.53569.52520.51503.50516
72.61948.60707.59504.58338.57206.56108.55043.54009.53004.52029
73.63287.62073.60895.59751.58640.57561.56513.55495.54505.53543
74.64621.63435.62282.61162.60073.59015.57985.56984.56009.55061
July 3, 2000402000–27 I.R.B.

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0%
75.65953.64796.63671.62575.61510.60473.59463.58480.57523.56591
76.67287.66160.65063.63995.62954.61940.60952.59989.59050.58135
77.68622.67526.66459.65419.64404.63415.62450.61509.60590.59694
78.69954.68892.67856.66845.65858.64895.63955.63036.62140.61264
79.71278.70250.69246.68265.67308.66372.65457.64563.63690.62836
80.72581.71588.70618.69668.68740.67833.66945.66077.65227.64396
81.73857.72899.71962.71045.70147.69268.68408.67566.66741.65933
82.75101.74178.73274.72389.71522.70672.69840.69024.68225.67441
83.76311.75423.74553.73700.72864.72044.71240.70451.69678.68919
84.77497.76645.75809.74988.74183.73393.72618.71857.71110.70377
85.78665.77848.77047.76260.75487.74728.73982.73250.72530.71823
86.79805.79025.78258.77504.76764.76036.75320.74617.73925.73245
87.80904.80159.79427.78706.77998.77301.76615.75940.75277.74624
88.81962.81251.80552.79865.79188.78521.77865.77220.76584.75958
89.82978.82302.81636.80980.80335.79699.79072.78455.77847.77248
90.83952.83309.82676.82052.81437.80831.80234.79645.79064.78492
91.84870.84260.83658.83064.82479.81902.81332.80771.80217.79671
92.85716.85136.84563.83998.83441.82891.82348.81812.81283.80761
93.86494.85942.85396.84858.84326.83801.83283.82771.82266.81767
94.87216.86690.86170.85657.85149.84648.84153.83664.83181.82704
95.87898.87397.86902.86412.85928.85450.84977.84510.84049.83592
96.88537.88060.87587.87121.86659.86203.85751.85305.84864.84427
97.89127.88672.88221.87775.87335.86898.86467.86040.85618.85200
98.89680.89245.88815.88389.87968.87551.87138.86730.86326.85926
99.90217.89803.89393.88987.88585.88187.87793.87402.87016.86633
100.90738.90344.89953.89567.89183.88804.88428.88056.87687.87322
101.91250.90876.90504.90137.89772.89412.89054.88699.88348.88000
102.91751.91396.91045.90696.90350.90007.89668.89331.88997.88666
103.92247.91912.91579.91249.90922.90598.90276.89957.89640.89326
104.92775.92460.92148.91839.91532.91227.90924.90624.90326.90031
105.93290.92996.92704.92415.92127.91841.91558.91276.90997.90719
106.93948.93680.93415.93151.92889.92628.92370.92113.91857.91604
107.94739.94504.94271.94039.93808.93579.93351.93124.92899.92675
108.95950.95767.95585.95404.95224.95045.94867.94689.94512.94336
109.97985.97893.97801.97710.97619.97529.97438.97348.97259.97170
2000–27 I.R.B.41July 3, 2000

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0%
0.03034.02857.02700.02559.02433.02321.02220.02129.02047.01973
1.02279.02094.01929.01782.01650.01533.01427.01331.01246.01168
2.02347.02155.01983.01829.01692.01569.01458.01358.01268.01187
3.02444.02243.02065.01905.01761.01632.01516.01412.01317.01232
4.02558.02349.02163.01996.01846.01712.01590.01481.01382.01292
5.02686.02469.02275.02101.01945.01804.01677.01562.01458.01364
6.02825.02600.02398.02217.02053.01906.01773.01653.01544.01445
7.02976.02742.02532.02343.02172.02019.01880.01754.01640.01536
8.03137.02894.02675.02479.02301.02140.01995.01864.01744.01635
9.03311.03059.02832.02627.02442.02274.02122.01985.01859.01745
10.03499.03237.03001.02788.02595.02420.02262.02118.01987.01867
11.03700.03428.03183.02961.02760.02578.02413.02262.02125.02000
12.03913.03632.03377.03146.02937.02748.02575.02418.02275.02144
13.04135.03843.03579.03339.03122.02924.02744.02580.02431.02294
14.04359.04057.03783.03534.03308.03102.02915.02744.02587.02444
15.04584.04270.03986.03728.03493.03279.03083.02905.02742.02593
16.04806.04482.04187.03919.03674.03452.03248.03063.02892.02736
17.05029.04692.04387.04108.03855.03623.03411.03218.03040.02877
18.05253.04905.04588.04299.04036.03795.03574.03373.03187.03017
19.05484.05124.04796.04496.04222.03972.03742.03532.03339.03161
20.05726.05354.05013.04702.04418.04158.03919.03700.03498.03313
21.05980.05595.05242.04920.04625.04354.04105.03877.03667.03473
22.06246.05847.05482.05147.04841.04559.04301.04063.03844.03642
23.06524.06112.05734.05387.05069.04777.04508.04260.04032.03821
24.06819.06392.06001.05642.05312.05008.04728.04470.04232.04012
25.07131.06690.06285.05913.05570.05255.04964.04695.04447.04218
26.07460.07005.06586.06200.05845.05518.05215.04936.04677.04438
27.07810.07340.06907.06508.06140.05800.05485.05195.04925.04676
28.08179.07693.07246.06833.06451.06098.05772.05469.05189.04929
29.08566.08065.07603.07176.06780.06414.06075.05761.05469.05198
30.08973.08456.07978.07536.07127.06748.06396.06069.05766.05483
31.09398.08865.08372.07915.07491.07098.06733.06394.06078.05785
32.09843.09294.08785.08313.07875.07468.07089.06737.06409.06103
33.10310.09745.09220.08732.08279.07858.07466.07100.06759.06441
34.10799.10217.09676.09173.08705.08269.07862.07483.07129.06798
35.11314.10715.10157.09638.09155.08704.08283.07890.07522.07179
36.11852.11236.10662.10127.09628.09162.08726.08319.07938.07581
37.12416.11783.11193.10641.10126.09645.09194.08772.08377.08006
38.13009.12359.11751.11183.10652.10155.09689.09253.08843.08459
39.13629.12962.12338.11753.11206.10693.10212.09761.09337.08938
40.14281.13597.12955.12355.11791.11262.10766.10299.09860.09447
41.14966.14264.13606.12989.12409.11864.11352.10870.10417.09989
42.15685.14966.14291.13657.13061.12500.11972.11475.11006.10564
43.16437.15702.15010.14360.13747.13171.12627.12115.11631.11174
44.17224.16472.15764.15098.14469.13876.13317.12789.12290.11819
July 3, 2000422000–27 I.R.B.

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0%
45.18042.17274.16550.15867.15223.14615.14040.13496.12982.12496
46.18893.18110.17370.16671.16011.15387.14796.14238.13708.13207
47.19775.18975.18220.17505.16830.16190.15584.15010.14466.13950
48.20688 .19873.19102.18373.17682.17027.16406.15817.15258.14727
49.21633.20804.20018.19274.18568.17898.17262.16658.16084.15539
50.22612.21769.20969.20210.19490.18805.18155.17536.16948.16388
51.23625.22769.21955.21182.20448.19749.19084.18452.17849.17275
52.24669.23799.22973.22186.21438.20726.20047.19400.18784.18196
53.25742.24861.24022.23222.22461.21735.21043.20383.19753.19151
54.26845.25952.25101.24290.23516.22777.22072.21399.20756.20140
55.27978.27074.26212.25389.24604.23853.23136.22450.21793.21166
56.29140.28227.27355.26522.25725.24963.24233.23535.22867.22227
57.30333.29411.28529.27686.26879.26106.25365.24656.23976.23324
58.31551.30621.29731.28878.28061.27278.26528.25807.25116.24453
59.32790.31854.30956.30095.29269.28477.27716.26986.26284.25610
60.34050.33107.32202.31334.30500.29699.28929.28190.27478.26794
61.35331.34384.33473.32598.31757.30948.30170.29422.28701.28007
62.36639.35688.34772.33892.33044.32229.31443.30687.29958.29255
63.37974.37020.36101.35216.34363.33542.32750.31986.31250.30539
64.39334.38378.37456.36568.35711.34884.34087.33317.32574.31857
65.40718.39761.38838.37947.37087.36257.35455.34681.33932.33208
66.42128.41172.40249.39357.38496.37663.36858.36079.35326.34597
67.43569.42616.41694.40803.39941.39107.38299.37518.36761.36028
68.45038.44089.43170.42281.41419.40585.39777.38994.38235.37499
69.46531.45587.44672.43786.42927.42094.41286.40503.39743.39006
70.48040.47103.46194.45312.44456.43626.42820.42038.41278.40540
71.49558.48629.47727.46851.46000.45174.44371.43591.42832.42095
72.51082.50162.49268.48399.47554.46733.45934.45157.44401.43666
73.52607.51697.50813.49952.49114.48299.47506.46733.45981.45249
74.54139.53241.52367.51515.50686.49879.49092.48325.47578.46849
75.55683.54798.53936.53095.52276.51477.50698.49938.49197.48474
76.57243.56373.55524.54696.53888.53100.52330.51579.50846.50130
77.58819.57965.57132.56318.55523.54747.53988.53247.52523.51815
78.60408.59572.58755.57957.57177.56414.55668.54939.54225.53527
79.62001.61184.60385.59604.58840.58092.57360.56644.55943.55256
80.63582.62786.62007.61244.60497.59765.59048.58347.57659.56985
81.65142.64367.63608.62864.62135.61421.60721.60034.59361.58701
82.66673.65920.65182.64458.63748.63052.62368.61698.61041.60395
83.68175.67444.66728.66024.65334.64656.63991.63338.62696.62066
84.69657.68950.68256.67574.66904.66246.65599.64964.64340.63727
85.71128.70446.69775.69116.68467.67830.67204.66587.65982.65386
86.72576.71919.71272.70636.70010.69394.68789.68193.67606.67029
87.73981.73349.72726.72114.71511.70917.70333.69757.69190.68632
88.75342.74735.74137.73548.72968.72396.71833.71279.70732.70194
89.76658.76076.75503.74938.74381.73832.73290.72757.72231.71712
2000–27 I.R.B.43July 3, 2000

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0%
90.77928.77371.76823.76281.75748.75221.74702.74190.73684.73186
91.79131.78600.78075.77557.77046.76542.76044.75553.75068.74589
92.80246.79737.79235.78740.78250.77767.77290.76818.76353.75893
93.81274.80788.80307.79832.79363.78899.78441.77989.77542.77100
94.82232.81766.81306.80850.80401.79956.79517.79082.78653.78228
95.83141.82695.82254.81818.81387.80961.80539.80122.79710.79302
96.83996.83569.83147.82729.82316.81907.81503.81103.80707.80315
97.84787.84378.83973.83573.83176.82784.82396.82012.81632.81255
98.85530.85138.84750.84366.83985.83609.83236.82867.82502.82140
99.86255.85880.85508.85140.84776.84415.84057.83703.83353.83005
100.86960.86601.86246.85894.85546.85200.84858.84519.84183.83849
101.87655.87313.86974.86638.86305.85975.85648.85324.85003.84684
102.88338.88012.87689.87369.87052.86738.86426.86116.85809.85505
103.89015.88706.88399.88095.87793.87494.87197.86903.86611.86321
104.89737.89446.89157.88871.88586.88304.88024.87745.87469.87195
105.90443.90170.89898.89628.89360.89094.88830.88568.88307.88049
106.91351.91101.90852.90605.90359.90115.89873.89632.89392.89154
107.92452.92230.92010.91791.91573.91356.91141.90927.90714.90502
108.94161.93987.93814.93641.93469.93298.93128.92958.92790.92622
109.97081.96992.96904.96816.96729.96642.96555.96468.96382.96296
July 3, 2000442000–27 I.R.B.
TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0%
0.01906.01845.01790.01740.01694.01652.01613.01578.01546.01516
1.01098.01034.00977.00924.00876.00833.00793.00756.00722.00691
2.01113.01046.00986.00930.00880.00834.00791.00753.00717.00684
3.01155.01084.01020.00962.00909.00860.00816.00775.00737.00702
4.01211.01137.01069.01008.00952.00900.00853.00810.00770.00733
5.01279.01201.01130.01065.01006.00952.00902.00856.00814.00775
6.01356.01274.01199.01131.01068.01011.00959.00910.00865.00824
7.01442.01356.01277.01205.01140.01079.01023.00972.00925.00881
8.01536.01446.01363.01287.01218.01154.01096.01041.00991.00945
9.01641.01546.01460.01380.01307.01240.01178.01120.01068.01019
10.01758.01659.01567.01484.01407.01336.01270.01210.01154.01103
11.01886.01781.01686.01598.01517.01442.01373.01310.01251.01196
12.02024.01915.01814.01721.01636.01558.01485.01419.01357.01299
13.02168.02054.01948.01851.01762.01679.01603.01533.01467.01407
14.02313.02193.02083.01981.01887.01801.01721.01646.01578.01514

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0%
15.02456.02330.02214.02107.02009.01918.01834.01756.01684.01617
16.02593.02462.02340.02229.02126.02030.01942.01860.01785.01714
17.02728.02590.02463.02346.02238.02138.02046.01960.01880.01806
18.02861.02717.02584.02462.02348.02243.02146.02056.01972.01894
19.02998.02847.02708.02580.02461.02351.02249.02154.02066.01984
20.03142.02984.02839.02704.02580.02465.02357.02258.02165.02079
21.03295.03130.02978.02837.02706.02585.02473.02368.02271.02180
22.03455.03283.03124.02976.02839.02712.02594.02484.02382.02286
23.03626.03446.03279.03124.02981.02847.02723.02608.02500.02400
24.03809.03620.03446.03283.03133.02993.02863.02741.02628.02522
25.04005.03808.03625.03456.03298.03151.03014.02887.02768.02656
26.04216.04010.03819.03641.03476.03322.03178.03044.02919.02802
27.04444.04229.04029.03843.03670.03508.03357.03217.03085.02962
28.04687.04463.04254.04059.03877.03708.03550.03402.03263.03133
29.04946.04712.04493.04289.04099.03922.03756.03600.03455.03318
30.05221.04976.04748.04534.04335.04149.03975.03812.03659.03515
31.05511.05255.05017.04794.04585.04390.04208.04037.03876.03725
32.05818.05551.05302.05069.04851.04647.04455.04276.04107.03948
33.06144.05866.05606.05363.05135.04921.04720.04532.04355.04188
34.06489.06200.05928.05674.05436.05212.05002.04805.04619.04444
35.06857.06555.06273.06007.05758.05524.05304.05097.04902.04718
36.07246.06932.06638.06361.06101.05856.05626.05409.05205.05012
37.07659.07332.07025.06737.06466.06210.05969.05742.05528.05325
38.08098.07758.07439.07138.06855.06588.06336.06099.05874.05662
39.08563.08210.07878.07565.07270.06992.06729.06480.06245.06023
40.09059.08692.08347.08021.07714.07423.07149.06889.06643.06411
41.09586.09206.08848.08509.08189.07886.07600.07329.07072.06828
42.10147.09753.09381.09029.08696.08381.08083.07800.07531.07277
43.10742.10334.09948.09583.09237.08909.08598.08304.08024.07758
44.11373.10950.10551.10172.09813.09472.09148.08841.08549.08272
45.12035.11599.11185.10792.10420.10066.09730.09410.09106.08817
46.12732.12281.11853.11447.11061.10694.10345.10013.09696.09395
47.13460.12995.12553.12133.11733.11353.10991.10646.10317.10004
48.14223.13743.13287.12853.12439.12046.11671.11313.10972.10646
49.15020.14526.14056.13608.13181.12774.12385.12015.11661.11322
50.15855.15347.14862.14401.13960.13540.13138.12754.12388.12037
51.16727.16205.15707.15232.14777.14344.13929.13532.13153.12789
52.17634.17098.16587.16097.15630.15183.14755.14345.13953.13577
53.18576.18027.17501.16999.16518.16057.15616.15194.14789.14400
54.19552.18990.18451.17935.17441.16968.16514.16078.15661.15260
55.20564.19989.19437.18908.18402.17915.17449.17001.16571.16157
56.21613.21025.20461.19919.19400.18901.18422.17962.17519.17093
57.22698.22098.21522.20968.20436.19925.19434.18961.18507.18069
58.23816.23204.22616.22051.21507.20984.20481.19996.19530.19080
59.24962.24339.23740.23163.22608.22073.21558.21062.20584.20123
2000–27 I.R.B.45July 3, 2000

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0%
60.26136.25502.24892.24304.23738.23192.22666.22158.21669.21196
61.27339.26695.26075.25477.24900.24343.23806.23288.22787.22304
62.28578.27925.27295.26687.26100.25533.24985.24456.23945.23451
63.29854.29192.28553.27935.27339.26762.26205.25666.25145.24641
64.31164.30494.29846.29221.28615.28030.27463.26915.26384.25870
65.32508.31831.31177.30543.29930.29336.28761.28203.27663.27140
66.33891.33208.32547.31906.31285.30684.30101.29536.28987.28456
67.35318.34630.33963.33316.32689.32081.31491.30918.30363.29823
68.36785.36093.35422.34770.34138.33524.32928.32349.31787.31240
69.38290.37595.36920.36265.35628.35009.34408.33824.33256.32703
70.39823.39127.38450.37791.37151.36529.35924.35335.34762.34204
71.41378.40681.40003.39343.38701.38076.37467.36875.36298.35736
72.42950.42253.41575.40914.40271.39644.39034.38438.37858.37293
73.44535.43840.43162.42502.41858.41231.40619.40022.39440.38872
74.46139.45446.44771.44112.43469.42842.42230.41632.41049.40479
75.47769.47080.46408.45752.45111.44485.43874.43277.42693.42123
76.49430.48747.48079.47427.46790.46167.45558.44963.44380.43811
77.51123.50447.49786.49139.48506.47888.47282.46690.46111.45543
78.52845.52177.51523.50884.50257.49645.49044.48457.47881.47317
79.54584.53926.53282.52650.52032.51426.50833.50251.49681.49122
80.56325.55678.55044.54423.53813.53216.52630.52056.51492.50939
81.58054.57419.56797.56186.55587.54999.54422.53856.53300.52754
82.59762.59140.58530.57931.57343.56766.56198.55641.55094.54557
83.61448.60840.60243.59657.59081.58515.57958.57411.56874.56346
84.63124.62531.61949.61376.60813.60259.59715.59179.58652.58134
85.64800.64224.63657.63099.62550.62010.61478.60955.60441.59934
86.66461.65902.65351.64810.64276.63751.63233.62724.62222.61728
87.68083.67541.67008.66483.65965.65455.64953.64458.63970.63489
88.69663.69140.68624.68116.67615.67121.66634.66154.65680.65213
89.71201.70696.70199.69708.69224.68747.68276.67811.67353.66900
90.72694.72209.71730.71257.70791.70330.69876.69427.68984.68547
91.74117.73650.73190.72735.72286.71842.71404.70972.70545.70123
92.75439.74991.74548.74110.73678.73251.72829.72412.72000.71593
93.76664.76233.75806.75385.74969.74557.74150.73748.73350.72957
94.77809.77394.76983.76578.76177.75780.75388.75000.74616.74237
95.78899.78500.78106.77715.77329.76947.76569.76195.75826.75460
96.79928.79544.79165.78790.78418.78050.77686.77326.76970.76617
97.80883.80514.80149.79787.79430.79075.78725.78377.78033.77693
98.81781.81427.81075.80727.80382.80041.79703.79368.79036.78708
99.82661.82320.81982.81648.81316.80988.80662.80340.80020.79704
July 3, 2000462000–27 I.R.B.

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0%
100.83519.83192.82868.82547.82228.81913.81600.81290.80982.80678
101.84368.84055.83744.83437.83131.82829.82529.82231.81936.81643
102.85203.84904.84607.84313.84021.83731.83444.83159.82876.82596
103.86034.85748.85465.85184.84906.84629.84355.84082.83812.83544
104.86923.86653.86385.86119.85855.85593.85333.85074.84818.84563
105.87792.87537.87283.87032.86782.86534.86287.86042.85799.85557
106.88918.88683.88450.88218.87987.87758.87530.87304.87079.86855
107.90291.90082.89873.89666.89460.89255.89051.88849.88647.88447
108.92455.92288.92123.91958.91794.91630.91468.91306.91145.90984
109.96211.96125.96041.95956.95872.95788.95704.95620.95537.95455
2000–27 I.R.B.47July 3, 2000
TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0%
0.01488.01463.01439.01417.01396.01377.01359.01343.01327.01312
1.00662.00636.00612.00589.00568.00548.00530.00513.00497.00482
2.00654.00626.00600.00576.00554.00533.00514.00496.00479.00463
3.00670.00641.00613.00588.00564.00542.00522.00502.00484.00468
4.00699.00668.00639.00612.00587.00563.00542.00521.00502.00484
5.00739.00706.00675.00646.00620.00595.00571.00550.00529.00510
6.00786.00751.00718.00687.00659.00633.00608.00585.00563.00543
7.00841.00803.00769.00736.00706.00678.00652.00627.00604.00582
8.00902.00863.00826.00791.00759.00730.00702.00675.00651.00628
9.00973.00931.00892.00856.00822.00790.00760.00733.00706.00682
10.01055.01010.00969.00930.00894.00861.00829.00799.00772.00746
11.01146.01099.01055.01014.00976.00940.00907.00875.00846.00818
12.01246.01196.01150.01106.01066.01028.00993.00960.00928.00899
13.01351.01298.01249.01204.01161.01121.01084.01049.01016.00985
14.01455.01400.01348.01300.01255.01213.01173.01136.01102.01069
15.01555.01497.01443.01392.01345.01300.01259.01220.01183.01148
16.01648.01587.01530.01477.01427.01380.01336.01295.01257.01220
17.01737.01673.01612.01556.01504.01455.01408.01365.01324.01286
18.01822.01754.01691.01632.01576.01525.01476.01430.01387.01347
19.01908.01837.01770.01708.01650.01595.01544.01495.01450.01407
20.01999.01924.01854.01788.01726.01669.01615.01564.01516.01471
21.02096.02017.01943.01874.01809.01748.01691.01637.01586.01539
22.02197.02114.02036.01963.01895.01830.01770.01713.01660.01610
23.02306.02218.02136.02059.01987.01919.01855.01795.01739.01686
24.02424.02331.02245.02163.02087.02016.01948.01885.01825.01769

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0%
25.02552.02455.02364.02278.02197.02122.02051.01984.01920.01861
26.02692.02589.02493.02403.02318.02238.02162.02091.02025.01961
27.02846.02738.02636.02541.02451.02367.02287.02212.02141.02074
28.03012.02898.02791.02690.02595.02506.02422.02342.02267.02196
29.03190.03070.02957.02851.02751.02656.02567.02483.02404.02329
30.03381.03254.03135.03023.02917.02817.02723.02634.02551.02471
31.03583.03450.03324.03206.03094.02989.02890.02796.02707.02623
32.03799.03659.03527.03402.03284.03173.03068.02968.02874.02785
33.04031.03883.03744.03612.03488.03371.03260.03155.03055.02961
34.04279.04123.03976.03838.03707.03583.03465.03354.03249.03149
35.04545.04382.04227.04081.03943.03812.03688.03571.03459.03354
36.04830.04658.04495.04341.04196.04058.03927.03803.03685.03573
37.05134.04953.04782.04620.04467.04321.04183.04052.03928.03809
38.05462.05272.05092.04921.04760.04606.04461.04322.04191.04066
39.05812.05613.05424.05245.05075.04913.04760.04614.04475.04343
40.06190.05981.05782.05594.05415.05245.05083.04929.04783.04643
41.06597.06378.06170.05972.05784.05605.05435.05272.05118.04970
42.07035.06806.06587.06380.06182.05994.05815.05644.05481.05326
43.07505.07265.07036.06818.06611.06414.06225.06045.05874.05710
44.08008.07757.07518.07290.07072.06865.06667.06478.06298.06125
45.08542.08279.08029.07791.07563.07346.07138.06940.06750.06569
46.09108.08834.08573.08324.08085.07858.07640.07432.07233.07043
47.09705.09419.09147.08886.08637.08399.08172.07954.07745.07545
48.10335.10038.09754.09482.09222.08973.08735.08507.08288.08078
49.10999.10690.10394.10111.09840.09581.09332.09093.08864.08644
50.11701.11380.11073.10778.10496.10225.09965.09716.09477.09247
51.12441.12108.11789.11482.11189.10907.10636.10376.10126.09886
52.13217.12871.12540.12222.11916.11623.11341.11071.10810.10560
53.14028.13670.13327.12997.12680.12375.12082.11801.11529.11268
54.14875.14505.14150.13808.13480.13163.12859.12566.12284.12012
55.15760.15378.15011.14657.14317.13989.13674.13370.13077.12794
56.16684.16290.15911.15546.15194.14855.14528.14213.13909.13615
57.17648.17242.16851.16474.16111.15760.15422.15096.14781.14477
58.18647.18229.17827.17438.17064.16702.16353.16015.15689.15374
59.19678.19249.18835.18435.18049.17676.17316.16968.16631.16305
60.20740.20300.19875.19464.19066.18682.18311.17952.17604.17268
61.21837.21385.20949.20527.20119.19724.19341.18971.18613.18266
62.22973.22511.22064.21631.21212.20807.20414.20033.19664.19306
63.24152.23680.23222.22779.22350.21934.21530.21139.20760.20392
64.25372.24890.24422.23969.23529.23103.22690.22289.21899.21521
65.26633.26141.25664.25201.24752.24316.23893.23482.23083.22695
66.27940.27439.26953.26481.26023.25577.25145.24724.24316.23918
67.29299.28790.28296.27815.27348.26894.26453.26024.25606.25200
68.30709.30193.29691.29202.28728.28265.27816.27378.26952.26537
69.32166.31643.31134.30639.30157.29687.29230.28785.28351.27928
July 3, 2000482000–27 I.R.B.

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0%
70.33661.33133.32618.32116.31628.31152.30688.30235.29794.29364
71.35188.34654.34134.33627.33133.32651.32181.31722.31275.30838
72.36742.36204.35679.35168.34668.34181.33706.33241.32788.32345
73.38317.37776.37248.36733.36229.35738.35257.34788.34330.33882
74.39923.39380.38849.38330.37823.37328.36844.36370.35908.35455
75.41566.41021.40489.39968.39459.38961.38474.37997.37531.37074
76.43254.42709.42176.41655.41144.40645.40156.39677.39208.38749
77.44988.44444.43912.43391.42880.42380.41891.41411.40940.40479
78.46765.46224.45694.45174.44665.44166.43677.43197.42726.42265
79.48574.48037.47510.46993.46487.45990.45502.45024.44554.44094
80.50397.49865.49343.48830.48327.47834.47349.46873.46406.45947
81.52219.51693.51176.50669.50171.49682.49201.48729.48265.47809
82.54029.53510.53000.52499.52007.51523.51047.50580.50120.49667
83.55826.55315.54813.54319.53834.53356.52886.52424.51969.51522
84.57624.57123.56629.56144.55666.55195.54732.54277.53828.53386
85.59435.58944.58460.57984.57516.57054.56599.56151.55710.55275
86.61241.60762.60289.59824.59365.58913.58468.58029.57596.57170
87.63015.62548.62087.61633.61185.60744.60309.59880.59456.59039
88.64753.64299.63851.63409.62973.62543.62118.61700.61287.60879
89.66454.66013.65579.65150.64726.64308.63895.63488.63086.62689
90.68115.67689.67268.66853.66442.66037.65637.65241.64851.64465
91.69706.69294.68887.68486.68089.67696.67309.66925.66547.66173
92.71190.70792.70399.70011.69627.69247.68872.68501.68134.67771
93.72569.72184.71804.71429.71057.70689.70326.69967.69611.69259
94.73861.73490.73123.72759.72400.72044.71692.71344.71000.70659
95.75097.74739.74384.74033.73686.73342.73002.72665.72331.72001
96.76267.75922.75579.75240.74905.74572.74243.73917.73595.73275
97.77356.77022.76691.76363.76039.75718.75399.75084.74772.74463
98.78382.78059.77740.77423.77110.76799.76491.76186.75884.75584
99.79390.79079.78771.78465.78162.77862.77565.77270.76978.76688
100.80376.80076.79779.79485.79193.78904.78617.78333.78051.77771
101.81353.81066.80780.80497.80217.79938.79662.79388.79117.78847
102.82318.82042.81768.81496.81227.80960.80694.80431.80170.79911
103.83278.83014.82752.82491.82233.81977.81723.81470.81220.80971
104.84310.84059.83810.83563.83317.83073.82831.82591.82352.82115
105.85318.85079.84843.84607.84374.84142.83911.83682.83455.83229
106.86633.86413.86193.85975.85758.85543.85329.85116.84904.84694
107.88247.88049.87852.87656.87460.87266.87073.86881.86690.86500
108.90825.90666.90507.90350.90193.90037.89881.89727.89572.89419
109.95372.95290.95208.95126.95045.94964.94883.94803.94723.94643
2000–27 I.R.B.49July 3, 2000

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE12.2%12.4%12.6%12.8%13.0%13.2%13.4%13.6%13.8%14.0%
0.01298.01285.01273.01261.01250.01240.01230.01221.01212.01203
1.00468.00455.00443.00431.00420.00410.00400.00391.00382.00374
2.00448.00435.00421.00409.00398.00387.00376.00366.00357.00348
3.00452.00437.00423.00410.00398.00386.00375.00365.00355.00345
4.00468.00452.00437.00423.00410.00397.00386.00375.00364.00354
5.00493.00476.00460.00445.00431.00418.00405.00393.00382.00371
6.00524.00506.00489.00473.00458.00444.00430.00418.00406.00394
7.00562.00543.00525.00508.00492.00477.00462.00449.00436.00423
8.00606.00586.00566.00548.00531.00515.00499.00485.00471.00458
9.00659.00637.00616.00597.00579.00561.00545.00529.00514.00500
10.00721.00698.00676.00655.00636.00617.00600.00583.00567.00552
11.00792.00767.00744.00722.00701.00682.00663.00645.00628.00612
12.00871.00845.00821.00797.00775.00754.00735.00716.00698.00681
13.00955.00928.00902.00877.00854.00831.00810.00790.00771.00753
14.01038.01009.00981.00955.00930.00907.00885.00864.00843.00824
15.01116.01085.01056.01028.01002.00977.00954.00932.00910.00890
16.01186.01153.01123.01094.01066.01040.01015.00992.00969.00948
17.01250.01215.01183.01152.01124.01096.01070.01045.01022.00999
18.01308.01272.01238.01206.01175.01147.01119.01093.01068.01044
19.01367.01329.01293.01259.01227.01196.01167.01140.01113.01088
20.01428.01388.01350.01314.01280.01248.01217.01188.01161.01134
21.01494.01451.01411.01373.01337.01303.01271.01240.01211.01183
22.01562.01517.01475.01435.01397.01361.01326.01294.01263.01233
23.01635.01588.01543.01501.01460.01422.01386.01351.01319.01287
24.01716.01665.01618.01573.01530.01489.01451.01415.01380.01347
25.01804.01751.01701.01653.01608.01565.01524.01485.01448.01413
26.01902.01845.01792.01741.01693.01648.01604.01563.01524.01487
27.02011.01951.01895.01841.01790.01742.01696.01652.01610.01571
28.02129.02066.02006.01949.01895.01844.01795.01748.01704.01662
29.02258.02191.02127.02067.02009.01955.01903.01853.01806.01762
30.02396.02325.02257.02193.02132.02074.02019.01966.01916.01869
31.02543.02467.02396.02328.02263.02201.02143.02087.02034.01983
32.02701.02621.02545.02472.02404.02338.02276.02217.02160.02106
33.02871.02786.02706.02629.02556.02487.02420.02357.02297.02240
34.03054.02964.02879.02797.02720.02646.02576.02509.02445.02383
35.03253.03158.03067.02981.02898.02820.02745.02674.02606.02541
36.03467.03366.03269.03178.03090.03007.02928.02852.02779.02710
37.03697.03590.03488.03391.03298.03209.03125.03044.02967.02893
38.03947.03833.03725.03622.03524.03430.03340.03254.03172.03094
39.04217.04096.03982.03873.03768.03669.03573.03482.03395.03312
40.04510.04383.04262.04146.04035.03930.03828.03732.03639.03550
41.04830.04695.04567.04445.04327.04215.04108.04005.03907.03812
42.05177.05035.04900.04770.04646.04527.04413.04304.04200.04100
43.05553.05404.05261.05123.04992.04866.04746.04630.04520.04413
44.05960.05802.05651.05506.05368.05235.05107.04985.04867.04754
July 3, 2000502000–27 I.R.B.

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE12.2%12.4%12.6%12.8%13.0%13.2%13.4%13.6%13.8%14.0%
45.06395.06229.06069.05917.05770.05630.05495.05365.05241.05121
46.06860.06685.06517.06356.06202.06053.05911.05774.05643.05516
47.07353.07169.06992.06823.06660.06504.06353.06209.06070.05936
48.07877.07684.07498.07320.07149.06984.06826.06673.06527.06385
49.08433.08231.08036.07849.07669.07495.07329.07168.07013.06864
50.09026.08814.08609.08413.08224.08042.07867.07698.07535.07378
51.09655.09433.09219.09013.08815.08624.08440.08262.08091.07926
52.10318.10086.09863.09647.09439.09239.09046.08860.08680.08506
53.11017.10774.10541.10315.10098.09888.09686.09491.09302.09120
54.11750.11498.11254.11019.10792.10572.10361.10156.09958.09767
55.12522.12258.12005.11759.11522.11294.11072.10859.10652.10451
56.13332.13059.12794.12539.12292.12054.11823.11599.11383.11174
57.14183.13899.13624.13359.13102.12853.12613.12380.12154.11936
58.15070.14775.14490.14215.13948.13689.13439.13197.12962.12734
59.15990.15685.15389.15103.14826.14558.14298.14046.13801.13564
60.16942.16626.16321.16024.15737.15459.15189.14927.14673.14426
61.17929.17603.17287.16981.16684.16395.16115.15844.15580.15324
62.18960.18623.18297.17980.17673.17375.17085.16803.16530.16264
63.20035.19688.19352.19025.18708.18400.18100.17809.17525.17250
64.21154.20797.20451.20114.19787.19469.19159.18859.18566.18281
65.22318.21951.21595.21249.20912.20584.20265.19955.19652.19358
66.23532.23156.22790.22434.22088.21751.21422.21102.20791.20487
67.24804.24419.24044.23679.23324.22977.22640.22311.21990.21678
68.26133.25740.25356.24983.24618.24263.23917.23579.23250.22929
69.27516.27114.26723.26341.25969.25605.25251.24905.24567.24237
70.28945.28536.28137.27747.27367.26996.26633.26279.25934.25596
71.30412.29996.29590.29193.28806.28427.28057.27696.27343.26998
72.31913.31491.31078.30675.30281.29895.29519.29150.28790.28438
73.33444.33016.32597.32188.31788.31396.31013.30638.30271.29913
74.35012.34579.34155.33741.33335.32938.32549.32168.31795.31430
75.36628.36190.35762.35343.34932.34530.34136.33750.33372.33001
76.38299.37858.37427.37004.36589.36183.35784.35394.35011.34636
77.40028.39585.39151.38725.38307.37898.37496.37103.36716.36337
78.41812.41368.40933.40506.40086.39675.39271.38874.38485.38103
79.43641.43198.42762.42334.41914.41502.41096.40698.40308.39924
80.45496.45054.44619.44192.43772.43360.42954.42556.42164.41779
81.47360.46920.46487.46061.45643.45231.44827.44429.44038.43653
82.49223.48785.48355.47932.47516.47106.46703.46307.45916.45532
83.51081.50648.50221.49802.49388.48982.48581.48187.47799.47416
84.52951.52523.52101.51686.51277.50874.50477.50086.49701.49321
85.54847.54425.54009.53600.53196.52798.52406.52019.51638.51262
86.56749.56335.55926.55523.55126.54734.54348.53966.53591.53220
87.58627.58221.57820.57425.57035.56650.56270.55895.55526.55161
88.60477.60079.59688.59301.58919.58542.58170.57802.57439.57081
89.62297.61909.61527.61149.60776.60408.60044.59685.59330.58979
2000–27 I.R.B.51July 3, 2000

TABLE S
BASED ON LIFE TABLE 90CM
SINGLE LIFE REMAINDER FACTORS
APPLICABLE AFTER APRIL 30, 1999
INTEREST RATE
AGE12.2%12.4%12.6%12.8%13.0%13.2%13.4%13.6%13.8%14.0%
90.64084.63707.63335.62968.62604.62246.61891.61540.61194.60851
91.65803.65437.65076.64719.64366.64017.63672.63330.62993.62659
92.67412.67058.66707.66360.66017.65678.65342.65010.64682.64357
93.68911.68567.68227.67890.67557.67227.66901.66578.66258.65942
94.70321.69988.69657.69330.69006.68686.68369.68055.67744.67437
95.71674.71351.71031.70713.70399.70088.69781.69476.69174.68875
96.72959.72646.72335.72028.71724.71422.71123.70828.70534.70244
97.74156.73853.73552.73254.72959.72666.72376.72089.71804.71522
98.75287.74993.74702.74413.74126.73842.73561.73282.73006.72732
99.76401.76117.75834.75555.75277.75002.74730.74459.74191.73926
100.77494.77219.76946.76676.76408.76142.75878.75616.75357.75099
101.78580.78315.78052.77791.77532.77275.77021.76768.76517.76268
102.79654.79399.79146.78894.78645.78397.78152.77908.77666.77426
103.80724.80479.80236.79994.79755.79517.79280.79046.78813.78582
104.81879.81646.81413.81183.80954.80726.80501.80276.80054.79832
105.83005.82782.82560.82340.82121.81904.81688.81474.81260.81049
106.84485.84277.84071.83866.83662.83459.83257.83057.82857.82659
107.86311.86124.85937.85751.85566.85382.85199.85017.84835.84655
108.89266.89114.88963.88812.88662.88513.88364.88216.88068.87922
109.94563.94484.94405.94326.94248.94170.94092.94014.93937.93860
July 3, 2000522000–27 I.R.B.

LIFE TABLE
TABLE 90CM
APPLICABLE AFTER APRIL 30, 1999
Age xl(x)Age xl(x)Age xl(x)
(1)(2)(1)(2)(1)(2)
010000037959697462852
19906438957807560449
29899239955817657955
39894440953737755373
49890741951567852704
59887742949287949943
69885043946878047084
79882644944318144129
89880345941548241091
99878346938558337994
109876647935288434876
119875048931738531770
129873449927878628687
139871350923708725638
149868151919188822658
159863552914248919783
169857353908859017046
179849754902979114466
189840955896589212066
19983145688965939884
20982155788214947951
21981135887397956282
22980065986506964868
23978966085537973694
24977846184490982745
25976716283368991999
269755663821691001424
27974416480887101991
28973226579519102672
29971996678066103443
30970706776531104284
31969346874907105175
32967916973186106105
3396642707135710760
3496485716941110833
3596322726734410917
369615073651541100
2000–27 I.R.B.53July 3, 2000

(e) Effective dates. This section applies
after April 30, 1999.
§20.2031–7T [Removed]
Par. 13a. Section 20.2031–7T is re-
moved.
Par. 14. Section 20.7520–1 is amended
by revising paragraphs (a)(2), (b)(2),
(c)(1), (c)(2) and (d) to read as follows:
§20.7520–1 Valuation of annuities, uni-
trust interests, interests for life or term of
years, and remainder or reversionary in-
terests.
(a) * * *
(2) In the case of a transfer to a pooled
income fund with a valuation date after
April 30, 1999, see §1.642(c)–6(e) (or, for
certain prior periods, §1.642(c)–6A of this
chapter) of this chapter with respect to the
valuation of the remainder interest.
* * * * *
(b) * * *
(2) Mortality component. The mortal-
ity component reflects the mortality data
most recently available from the United
States Census. As new mortality data be-
comes available after each decennial cen-
sus, the mortality component described in
this section will be revised periodically
and the mortality component tables will
be published in the regulations at that
time. For decedents’ estates with valua-
tion dates after April 30, 1999, the mortal-
ity component table (Table 90CM) is in-
cluded in §20.2031–7(d)(7). See
§20.2031–7A for mortality component ta-
bles applicable to decedent’s estates with
valuation dates before May 1, 1999.
(c) * * *
(1) Regulation sections containing ta-
bles with interest rates between 4.2 and
14 percent for valuation dates after April
30, 1999. Section 1.642(c)–6(e)(6) of this
chapter contains Table S used for deter-
mining the present value of a single life
remainder interest in a pooled income
fund as defined in §1.642(c)–5 of this
chapter. See §1.642(c)–6A of this chapter
for single life remainder factors applica-
ble to valuation dates before May 1, 1999.
Section 1.664–4(e)(6) of this chapter con-
tains Table F (payout factors) and Table D
(actuarial factors used in determining the
present value of a remainder interest post-
poned for a term of years). Section
1.664–4(e)(7) of this chapter contains
Table U(1) (unitrust single life remainder
factors). These tables are used in deter-
mining the present value of a remainder
interest in a charitable remainder unitrust
as defined in §1.664–3 of this chapter.
See §1.664–4A of this chapter for unitrust
single life remainder factors applicable to
valuation dates before May 1, 1999. Sec-
tion 20.2031–7(d)(6) contains Table B
(actuarial factors used in determining the
present value of an interest for a term of
years), Table K (annuity end-of-interval
adjustment factors), and Table J (term cer-
tain annuity beginning-of-interval adjust-
ment factors). Section 20.2031–7(d)(7)
contains Table S (single life remainder
factors) and Table 90CM (mortality com-
ponents). These tables are used in deter-
mining the present value of annuities, life
estates, remainders, and reversions. See
§20.2031–7A for single life remainder
factors and mortality components applica-
ble to valuation dates before May 1, 1999.
(2) Internal Revenue Service publica-
tions containing tables with interest rates
between 2.2 and 22 percent for valuation
dates after April 30, 1999. The following
documents are available for purchase
from the Superintendent of Documents,
United States Government Printing Of-
fice, Washington, DC 20402:
(i) Internal Revenue Service Publica-
tion 1457, “Actuarial Values, Book
Aleph,” (7-1999). This publication in-
cludes tables of valuation factors, as well
as examples that show how to compute
other valuation factors, for determining
the present value of annuities, life estates,
terms of years, remainders, and rever-
sions, measured by one or two lives.
These factors may also be used in the val-
uation of interests in a charitable remain-
der annuity trust as defined in §1.664–2
of this chapter and a pooled income fund
as defined in §1.642(c)–5 of this chapter.
See §20.2031–7A for publications con-
taining tables for valuation dates before
May 1, 1999.
(ii) Internal Revenue Service Publica-
tion 1458, “Actuarial Values, Book Beth,”
(7-1999). This publication includes term
certain tables and tables of one and two
life valuation factors for determining the
present value of remainder interests in a
charitable remainder unitrust as defined in
§1.664–3 of this chapter. See §1.664–4A
of this chapter for publications containing
tables for valuation dates before May 1,
1999.
(iii) Internal Revenue Service Publica-
tion 1459, “Actuarial Values, Book
Gimel,” (7-1999). This publication in-
cludes tables for computing depreciation
adjustment factors. See §1.170A–12 of
this chapter.
(d) Effective date. This section applies
after April 30, 1989.
§20.7520–1T [Removed]
Par. 15. Section 20.7520–1T is re-
moved.
PART 25—GIFT TAX; GIFTS MADE
AFTER DECEMBER 31, 1954
Par. 16. The authority citation for part
25 is amended by removing the entries for
Sections 25–2512–5T and 25.7520–1T to
read in part as follows:
Authority: 26 U.S.C. 7805 * * *
§25.2512–0 [Amended]
Par. 17. Section 25.2512–0 is amended
by removing the entry for §25.2512–5T
from the contents listing.
Par. 18. Section 25.2512–5 is amended
by revising paragraphs (c), (d) and (e) to
read as follows:
§25.2512–5 Valuation of annuities, uni-
trust interests, interests for life or term of
years, and remainder or reversionary in-
terests.
* * * * *
(c) Actuarial valuations. The present
value of annuities, unitrust interests, life
estates, terms of years, remainders, and
reversions transferred by gift after April
30, 1999, is determined under paragraph
(d) of this section. The present value of
annuities, unitrust interests, life estates,
terms of years, remainders, and reversions
transferred by gift before May 1, 1999, is
determined under the following sections:
July 3, 2000542000–27 I.R.B.

(d) Actuarial valuations after April 30,
1999—(1) In general. Except as other-
wise provided in paragraph (b) of this sec-
tion and §25.7520–3(b) (relating to ex-
ceptions to the use of prescribed tables
under certain circumstances), if the valua-
tion date for the gift is after April 30,
1999, the fair market value of annuities,
life estates, terms of years, remainders,
and reversions transferred after April 30,
1999, is the present value of such interests
determined under paragraph (d)(2) of this
section and by use of standard or special
section 7520 actuarial factors. These fac-
tors are derived by using the appropriate
section 7520 interest rate and, if applica-
ble, the mortality component for the valu-
ation date of the interest that is being val-
ued. See §§25.7520–1 through
25.7520–4. The fair market value of a
qualified annuity interest described in
section 2702(b)(1) and a qualified unitrust
interest described in section 2702(b)(2) is
the present value of such interests deter-
mined under §25.7520–1(c).
(2) Specific interests. When the donor
transfers property in trust or otherwise
and retains an interest therein, generally,
the value of the gift is the value of the
property transferred less the value of the
donor’s retained interest. However, if the
donor transfers property after October 8,
1990, to or for the benefit of a member of
the donor’s family, the value of the gift is
the value of the property transferred less
the value of the donor’s retained interest
as determined under section 2702. If the
donor assigns or relinquishes an annuity,
life estate, remainder, or reversion that the
donor holds by virtue of a transfer previ-
ously made by the donor or another, the
value of the gift is the value of the interest
transferred. However, see section 2519
for a special rule in the case of the assign-
ment of an income interest by a person
who received the interest from a spouse.
(i) Charitable remainder trusts.The
fair market value of a remainder interest
in a pooled income fund, as defined in
§1.642(c)–5 of this chapter, is its value
determined under §1.642(c)–6(e) of this
chapter (see §1.642(c)–6A for certain
prior periods). The fair market value of a
remainder interest in a charitable remain-
der annuity trust, as described in
§1.664–2(a) of this chapter, is its present
value determined under §1.664–2(c) of
this chapter. The fair market value of a
remainder interest in a charitable remain-
der unitrust, as defined in §1.664–3 of this
chapter, is its present value determined
under §1.664–4(e) of this chapter. The
fair market value of a life interest or term
for years in a charitable remainder uni-
trust is the fair market value of the prop-
erty as of the date of transfer less the fair
market value of the remainder interest,
determined under §1.664–4(e)(4) and (5)
of this chapter.
(ii) Ordinary remainder and reversion-
ary interests. If the interest to be valued
is to take effect after a definite number of
years or after the death of one individual,
the present value of the interest is com-
puted by multiplying the value of the
property by the appropriate remainder in-
terest actuarial factor (that corresponds to
the applicable section 7520 interest rate
and remainder interest period) in Table B
(for a term certain) or the appropriate
Table S (for one measuring life), as the
case may be. Table B is contained in
§20.2031–7(d)(6) of this chapter and
Table S (for one measuring life when the
valuation date is after April 30, 1999) is
included in §20.2031–7(d)(7) of this
chapter and Internal Revenue Service
Publication 1457. See
§20.2031–7A(e)(4) of this chapter con-
taining Table S and Life Table 80CNSMT
for valuation of interests after April 30,
1989, and before May 1, 1999. For infor-
mation about obtaining actuarial factors
for other types of remainder interests, see
paragraph (d)(4) of this section.
(iii) Ordinary term-of-years and life in-
terests. If the interest to be valued is the
right of a person to receive the income of
certain property, or to use certain nonin-
come-producing property, for a term of
years or for the life of one individual, the
present value of the interest is computed
by multiplying the value of the property by
the appropriate term-of-years or life inter-
est actuarial factor (that corresponds to the
applicable section 7520 interest rate and
term-of-years or life interest period). Inter-
nal Revenue Service Publication 1457 in-
cludes actuarial factors for an interest for a
term of years in Table B and for the life of
one individual in Table S (for one measur-
ing life when the valuation date is after
April 30, 1999). However, term-of-years
and life interest actuarial factors are not in-
cluded in Table B in §20.2031–7(d)(6) or
Table S in §20.2031–7(d)(7) (or in
§20.2031–7A(e)(4)) of this chapter. If In-
ternal Revenue Service Publication 1457
(or any other reliable source of term-of-
years and life interest actuarial factors) is
not conveniently available, an actuarial
factor for the interest may be derived
mathematically. This actuarial factor may
be derived by subtracting the correlative
remainder factor (that corresponds to the
applicable section 7520 interest rate) in
Table B (for a term of years) in
§20.2031–7(d)(6) of this chapter or in
Table S (for the life of one individual) in
§20.2031–7(d)(7) of this chapter, as the
case may be, from 1.000000. For informa-
tion about obtaining actuarial factors for
other types of term-of-years and life inter-
ests, see paragraph (d)(4) of this section.
(iv) Annuities. (A) If the interest to be
valued is the right of a person to receive
an annuity that is payable at the end of
each year for a term of years or for the life
of one individual, the present value of the
interest is computed by multiplying the
aggregate amount payable annually by the
appropriate annuity actuarial factor (that
corresponds to the applicable section
7520 interest rate and annuity period). In-
ternal Revenue Service Publication 1457
includes actuarial factors in Table B (for
an annuity payable for a term of years)
2000–27 I.R.B.55July 3, 2000
TransfersApplicable
AfterBeforeRegulations
01-01-5225.2512–5A(a)
12-31-5101-01-7125.2512–5A(b)
12-31-7012-01-8325.2512–5A(c)
11-30-8305-01-8925.2512–5A(d)
04-30-8905-01-9925.2512–5A(e)

and in Table S (for an annuity payable for
the life of one individual when the valua-
tion date is after April 30, 1999). How-
ever, annuity actuarial factors are not in-
cluded in Table B in §20.2031–7(d)(6) of
this chapter or Table S in
§20.2031–7(d)(7) (or in
§20.2031–7A(e)(4)) of this chapter. If In-
ternal Revenue Service Publication 1457
(or any other reliable source of annuity
actuarial factors) is not conveniently
available, an annuity factor for a term of
years or for one life may be derived math-
ematically. This annuity factor may be
derived by subtracting the applicable re-
mainder factor (that corresponds to the
applicable section 7520 interest rate and
annuity period) in Table B (in the case of
a term-of-years annuity) in
§20.2031–7(d)(6) of this chapter or in
Table S (in the case of a one-life annuity)
in §20.2031–7(d)(7) of this chapter, as the
case may be, from 1.000000 and then di-
viding the result by the applicable section
7520 interest rate expressed as a decimal
number. See §20.2031–7(d)(2)(iv) of this
chapter for an example that illustrates the
computation of the present value of an an-
nuity.
(B) If the annuity is payable at the end
of semiannual, quarterly, monthly, or
weekly periods, the product obtained by
multiplying the annuity factor by the ag-
gregate amount payable annually is then
multiplied by the applicable adjustment
factor set forth in Table K in
§20.2031–7(d)(6) of this chapter at the
appropriate interest rate component for
payments made at the end of the specified
periods. The provisions of this paragraph
(d)(2)(iv)(B) are illustrated by the follow-
ing example:
Example. In July, the donor agreed to pay the an-
nuitant the sum of $10,000 per year, payable in
equal semiannual installments at the end of each pe-
riod. The semiannual installments are to be made on
each December 31st and June 30th. The annuity is
payable until the annuitant’s death. On the date of
the agreement, the annuitant is 68 years and 5
months old. The donee annuitant’s age is treated as
68 for purposes of computing the present value of
the annuity. The section 7520 rate on the date of the
agreement is 10.6 percent. Under Table S in
§20.2031–7(d)(7) of this chapter, the factor at 10.6
percent for determining the present value of a re-
mainder interest payable at the death of an individ-
ual aged 68 is .29691. Converting the remainder
factor to an annuity factor, as described above, the
annuity factor for determining the present value of
an annuity transferred to an individual age 68 is
6.6329 (1.00000 minus .29691 divided by .106).
The adjustment factor from Table K in
§20.2031–7(d)(6) of this chapter in the column for
payments made at the end of each semiannual period
at the rate of 10.6 percent is 1.0258. The aggregate
annual amount of the annuity, $10,000, is multiplied
by the factor 6.6329 and the product multiplied by
1.0258. The present value of the donee’s annuity is,
therefore, $68,040.29 ($10,000 X 6.6329 X 1.0258).
(C) If an annuity is payable at the be-
ginning of annual, semiannual, quarterly,
monthly, or weekly periods for a term of
years, the value of the annuity is com-
puted by multiplying the aggregate
amount payable annually by the annuity
factor described in paragraph
(d)(2)(iv)(A) of this section; and the prod-
uct so obtained is then multiplied by the
adjustment factor in Table J in
§20.2031–7(d)(6) of this chapter at the
appropriate interest rate component for
payments made at the beginning of speci-
fied periods. If an annuity is payable at
the beginning of annual, semiannual,
quarterly, monthly, or weekly periods for
one or more lives, the value of the annuity
is the sum of the first payment plus the
present value of a similar annuity, the first
payment of which is not to be made until
the end of the payment period, deter-
mined as provided in paragraph
(d)(2)(iv)(B) of this section.
(v) Annuity and unitrust interests for a
term of years or until the prior death of
an individual—(A) Annuity interests. The
present value of an annuity interest that is
payable until the earlier to occur of the
lapse of a specific number of years or the
death of an individual may be computed
with values from the tables in
§20.2031–7(d)(6) and (d)(7) of this chap-
ter as described in the following example:
Example. The donor transfers $100,000 into a
trust and retains the right to receive an annuity from
the trust in the amount of $6,000 per year, payable in
equal semiannual installments at the end of each pe-
riod. The semiannual installments are to be made on
each June 30th and December 31st. The annuity is
payable for 10 years or until the donor’s prior death.
At the time of the transfer, the donor is 59 years and
6 months old. The donor’s age is taken as 60 for
purposes of computing the present value of the re-
tained annuity. The section 7520 rate for the month
in which the transfer occurred is 9.8 percent. The
present value of the donor’s retained interest is
$35,709.13, determined as follows:
July 3, 2000562000–27 I.R.B.
TABLE S value at 9.8 percent, age 60 . . . . . . . . . . . . . . . . . . ..21669
TABLE S value at 9.8 percent, age 70 . . . . . . . . . . . . . . ..34762
TABLE 90CM value at age 70 . . . . . . . . . . . . . . . . . . . . .71357
TABLE 90CM value at age 60 . . . . . . . . . . . . . . . . . . . . .85537
TABLE B value at 9.8 percent, 10 years . . . . . . . . . . . . ..392624
TABLE K value at 9.8 percent . . . . . . . . . . . . . . . . . . . . .1.0239
Factor for donor’s retained interest at 9.8 percent:
(1.00000 - .21669) - (.392624 X (71357/85537) X (1.00000 - .34762))= 5.8126
.098
Present value of donor’s retained interest:
($6,000 X 5.8126 X 1.0239) ........... $35,709.13
(B) Unitrust interests. The present
value of a unitrust interest that is payable
until the earlier to occur of the lapse of a
specific number of years or the death of
an individual may be computed with val-
ues from the tables in §§1.664–4(e)(6)
and (e)(7) and §20.2031–7(d)(7) of this
chapter as described in the following ex-
ample:
Example. The donor who, as of the nearest birth-
day, is 60 years old, transfers $100,000 to a unitrust
on January 1
st
. The trust instrument requires that
each year the trust pay to the donor, in equal semian-
nual installments on June 30th and December 31st, 6
percent of the fair market value of the trust assets,
valued as of January 1st each year, for 10 years or
until the prior death of the donor. The section 7520
rate for the January in which the transfer occurred is
9.8 percent. Under Table F(9.8) in §1.664–4(e)(6)
of this chapter, the appropriate adjustment factor is
.932539 for semiannual payments payable at the end
of the semiannual period. The adjusted payout rate
is 5.595 percent (6% X .932539). The present value
of the donor’s retained interest is $40,848.00 deter-
mined as follows:

TABLE U(1) value at 5.6 percent, age 60 . . . . . . . . . . . ..35375
TABLE U(1) value at 5.6 percent, age 70 . . . . . . . . . . . .49342
TABLE 90CM value at age 70 . . . . . . . . . . . . . . . . . . . . .71357
TABLE 90CM value at age 60 . . . . . . . . . . . . . . . . . . . . .85537
TABLE D value at 5.6 percent, 10 years . . . . . . . . . . . . ..561979
Factor for donor’s retained interest at 5.6 percent:
(1.000000 - .35375) - (.561979 X (71357/85537) X (1.000000 - .49342)) = .40876
TABLE U(1) value at 5.4 percent, age 60 . . . . . . ..36542
TABLE U(1) value at 5.4 percent, age 70 . . . . . . ..50473
TABLE 90CM value at age 70 . . . . . . . . . . . . . . .71357
TABLE 90CM value at age 60 . . . . . . . . . . . . . . . .85537
TABLE D value at 5.4 percent, 10 years . . . . . . ..573999
Factor for donor’s retained interest at 5.4 percent:
(1.000000 - .36542) - (.573999 X (71357/85537) X (1.000000 - .50473)) = .39742
Difference.01134
Interpolation adjustment:
5.595% - 5.4%= x
0.2% .01134
x = .01106
Factor at 5.4 percent, age 60 . . . . . . . . . . . . . . . . . ..39742
Plus: Interpolation adjustment . . . . . . . . . . . . . . . ..01106
Interpolated Factor . . . . . . . . . . . . . . . . . . . . . . . . ..40848
Present value of donor’s retained interest:
($100,000 X .40848) . . . . . .$40,848.00
2000–27 I.R.B.57July 3, 2000
(3) Transitional rule. If the valuation
date of a transfer of property by gift is
after April 30, 1999, and before July 1,
1999, the fair market value of the interest
transferred is determined by use of the
section 7520 interest rate for the month in
which the valuation date occurs (see
§§25.7520–1(b) and 25.7520–2(a)(2))
and the appropriate actuarial tables under
either paragraph (d)(2) of this section or
§25.2512–5A(e), at the option of the
donor. However, with respect to each in-
dividual transaction and with respect to
all transfers occurring on the valuation
date, the donor must use the same actuar-
ial tables (for example, gift and income
tax charitable deductions with respect to
the same transfer must be determined
based on the same tables, and all transfers
made on the same date must be valued
based on the same tables).
(4) Publications and actuarial compu-
tations by the Internal Revenue Service.
Many standard actuarial factors not in-
cluded in §§20.2031–7(d)(6) or (d)(7) of
this chapter are included in Internal Rev-
enue Service Publication 1457, “Actuarial
Values, Book Aleph,” (7-1999). Internal
Revenue Service Publication 1457 also
includes examples that illustrate how to
compute many special factors for more
unusual situations. A copy of this publi-
cation is available for purchase from the
Superintendent of Documents, United
States Government Printing Office,
Washington, DC 20402. See
§25.2512–5A for publications containing
actuarial factors for valuing interests for
which the valuation date is before May 1,
1999. If a special factor is required in the
case of a completed gift, the Service may
furnish the factor to the donor upon a re-
quest for a ruling. The request for a rul-
ing must be accompanied by a recitation
of the facts including a statement of the
date of birth for each measuring life, the
date of the gift, any other applicable
dates, and a copy of the will, trust, or
other relevant documents. A request for a
ruling must comply with the instructions
for requesting a ruling published periodi-
cally in the Internal Revenue Bulletin (see
§§601.201 and 601.601(d)(2)(ii)(b) of
this chapter) and include payment of the
required user fee.
(e) Effective dates. This section applies
after April 30, 1999.
§25.2512–5T [Removed]
Par. 19. Section 25.2512–5T is re-
moved.
Par. 20. Section 25.7520–1 is amended
by revising paragraphs (b)(2), (c)(1),
(c)(2) and (d) to read as follows:
§25.7520–1 Valuation of annuities, uni-
trust interests, interests for life or term of
years, and remainder or reversionary in-
terests.
* * * * *
(b) * * *
(2) Mortality component. The mortal-
ity component reflects the mortality data
most recently available from the United
States Census. As new mortality data be-
comes available after each decennial cen-
sus, the mortality component described in
this section will be revised periodically
and the mortality component tables will
be published in the regulations at that
time. For gifts with valuation dates after
April 30, 1999, the mortality component
table (Table 90CM) is included in
§20.2031–7(d)(7) of this chapter. See
§20.2031–7A of this chapter for mortality
component tables applicable to decedent’s
estates with valuation dates before May 1,
1999.
(c) * * *
(1) Regulation sections containing ta-
bles with interest rates between 4.2 and 14
percent for valuation dates after April 30,
1999. Section 1.642(c)–6(e)(6) of this
chapter contains Table S used for deter-

mining the present value of a single life re-
mainder interest in a pooled income fund
as defined in §1.642(c)–5 of this chapter.
See §1.642(c)–6A for single life remainder
factors applicable to valuation dates before
May 1, 1999. Section 1.664–4(e)(6) of this
chapter contains Table F (payout factors)
and Table D (actuarial factors used in de-
termining the present value of a remainder
interest postponed for a term of years).
Section 1.664–4(e)(7) of this chapter con-
tains Table U(1) (unitrust single life re-
mainder factors). These tables are used in
determining the present value of a remain-
der interest in a charitable remainder uni-
trust as defined in §1.664–3 of this chapter.
See §1.664–4A for unitrust single life re-
mainder factors applicable to valuation
dates before May 1, 1999. Section
20.2031–7(d)(6) of this chapter contains
Table B (actuarial factors used in determin-
ing the present value of an interest for a
term of years), Table K (annuity end-of-in-
terval adjustment factors), Table J (term
certain annuity beginning-of-interval ad-
justment factors). Section
20.2031–7(d)(7) of this chapter contains
Table S (single life remainder factors) and
Table 90CM (mortality components).
These tables are used in determining the
present value of annuities, life estates, re-
mainders, and reversions. See
§20.2031–7A of this chapter for single life
remainder factors and mortality compo-
nents applicable to valuation dates before
May 1, 1999.
(2) Internal Revenue Service publica-
tions containing tables with interest rates
between 2.2 and 22 percent for valuation
dates after April 30, 1999. The following
documents are available for purchase
from the Superintendent of Documents,
United States Government Printing Of-
fice, Washington, DC 20402:
(i) Internal Revenue Service Publica-
tion 1457, “Actuarial Values, Book
Aleph,” (7-1999). This publication in-
cludes tables of valuation factors, as well
as examples that show how to compute
other valuation factors, for determining
the present value of annuities, life estates,
terms of years, remainders, and rever-
sions, measured by one or two lives.
These factors may also be used in the val-
uation of interests in a charitable remain-
der annuity trust as defined in §1.664–2
of this chapter and a pooled income fund
as defined in §1.642(c)–5 of this chapter.
See §25–2512–5A for publications con-
taining tables for valuation dates before
May 1, 1999.
(ii) Internal Revenue Service Publication
1458, “Actuarial Values, Book Beth,” (7-
1999). This publication includes term cer-
tain tables and tables of one and two life
valuation factors for determining the present
value of remainder interests in a charitable
remainder unitrust as defined in §1.664–3 of
this chapter. See §1.664–4A of this chapter
for publications containing tables for valua-
tion dates before May 1, 1999.
(iii) Internal Revenue Service Publica-
tion 1459, “Actuarial Values, Book
Gimel,” (7-1999). This publication in-
cludes tables for computing depreciation
adjustment factors. See §1.170A–12 of
this chapter.
(d) Effective date. This section applies
after April 30, 1989.
§25.7520–1T [Removed]
Par. 21. Section 25.7520–1T is re-
moved.
PARTS 1, 20 AND 25 [AMENDED]
Par. 22. In the list below, for each sec-
tion indicated in the left column, remove
the language in the middle column and
add the language in the right column:
July 3, 2000582000–27 I.R.B.
SectionRemoveAdd
1.170A–12(e)(2),§20.2031–7T§20.2031–7
following the formula
1.642(c)–6A(e)(2)(ii),§1.642(c)–6T(e)(3)(ii)§1.642(c)–6(e)(3)(ii)
last sentence
1.642(c)–6A(e)(3)§1.642(c)–6T(e)(4)§1.642(c)–6(e)(4)
1.642(c)–6A(e)(4),§1.642(c)–6T(e)(5)§1.642(c)–6(e)(5)
last sentence
1.664–1(a)(6),§§1.664–4T(e), §§1.664–4(e) and
introductory text1.664–4T(e) and1.664–4A(d) and (e)
1.664–4A(d) and (e)
1.664–4(e)(6),§1.664–4T(e)(7)paragraph (e)(5) of
second sentencethis section
1.664–4A(e)(4),§1.664–4T(e)(4)§1.664–4(e)(4)
fifth sentence
1.664–4A(e)(4),§1.664–4T(e)(4)§1.664–4(e)(4)
last sentence

SectionRemoveAdd
1.664–4A(e)(5),§1.664–4T(e)(5)§1.664–4(e)(5)
fourth sentence
1.664–4A(e)(5),§1.664–4T(e)(5)§1.664–4(e)(5)
last sentence
1.7520–1(a)(2)§1.642(c)–6T(e)§1.642(c)–6(e)
20.2031–7A(e)(1),§20.2031–7T(d)§20.2031–7(d)
first sentence
20.2055–2(f)(4)§20.2031–7T(d)§20.2031–7(d)
25.2512–5A(e)(1),§25.2512–5T(d)§25.2512–5(d)
first sentence
25.7520–1(a)(2)§1.642(c)–6T(e)§1.642(c)–6(e)
25.7520–3(b)(2)(v),§20.2031–7T(d)(7)§20.2031–7(d)(7)
Example 5 (iii)
2000–27 I.R.B.59July 3, 2000
Robert E. Wenzel,
Deputy Commissioner
of Internal Revenue.
Approved May 17, 2000.
Jonathan Talisman,
Deputy Assistant Secretary
of the Treasury (Tax Policy).
(Filed by the Office of the Federal Ragister on June
9, 2000, 8:45 a.m., and published in the issue of the
Federal Register for June 12, 2000, 65 F.R. 36908)
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 July 2000. See Rev. Rul. 2000–32, page 1.

26 CFR 601.602: Forms and instructions. (Also
Part 1, Sections 220, 408, 408A, 6041, 6041A, 6042,
6043, 6044, 6045, 6047, 6049, 6050A, 6050B,
6050D, 6050E, 6050H, 6050J, 6050N, 6050P,
6050Q, 6050R, 6050S, 1.408–5, 1.408–7, 1.408A–7,
1.6041–1, 7.6041–1, 1.6042–2, 1.6042–4, 1.6044–2,
1.6044–5, 1.6045–1, 5f.6045–1, 1.6045–2, 1.6045–4,
1.6047–1, 1.6049–4, 1.6049–6, 1.6049–7, 1.6050A–1,
1.6050B–1, 1.6050D–1, 1.6050E–1, 1.6050H–1,
1.6050H–2, 1.6050J–1T, 1.6050N–1, 1.6050P–1).
Rev. Proc. 2000–28
TABLE OF CONTENTS
PART 1 - GENERAL INFORMATION
Section 1.1 - Overview of Revenue Procedure 2000–28 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .61
Section 1.2 - General Requirements for Acceptable Substitute Forms 1096,
1098, 1099, 5498, and W-2G . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .62
Section 1.3 - Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .63
PART 2 - SPECIFICATIONS FOR SUBSTITUTE FORMS 1096 AND COPIES A OF FORMS 1098, 1099,
AND 5498 (ALL FILED WITH THE IRS)
Section 2.1 - Specifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .64
Section 2.2 - Instructions for Preparing Paper Forms That Will Be Filed With the
IRS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .66
PART 3 - SPECIFICATIONS FOR SUBSTITUTE FORM W-2G (FILED WITH THE IRS)
Section 3.1 - General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .68
Section 3.2 - Specifications for Copy A of Form W-2G . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .68
PART 4 - SUBSTITUTE STATEMENTS TO FORM RECIPIENTS AND FORM RECIPIENT COPIES
Section 4.1 - Specifications. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .69
Section 4.2 - Composite Statements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .71
Section 4.3 - Required Legends. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .72
Section 4.4 - Miscellaneous Instructions for Copies B, C, D 1, and 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . .73
PART 5 - ADDITIONAL INSTRUCTIONS FOR SUBSTITUTE FORMS 1098, 1099, 5498, AND W-2G
Section 5.1 - OMB Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .74
Section 5.2 - Reproducible Copies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .74
Section 5.3 - Effect on Other Revenue Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .75
PART 6 - EXHIBITS
Section 6.1 - Exhibits of Forms in the Revenue Procedure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .76
July 3, 2000602000–27 I.R.B.
Part III. Administrative, Procedural, and Miscellaneous

Part 1
General Information
Section 1.1 - Overview of Revenue Procedure 2000–28
1.1.1 PurposeThe purpose of this revenue procedure is to set forth the requirements for the year 2000 for:
•Using official Internal Revenue Service (IRS) forms to file information returns with the IRS,
•Preparing acceptable substitutes of the official IRS forms to file information returns with the IRS, and
•Using official or acceptable substitute forms to furnish information to recipients.
1.1.2 Which This revenue procedure contains specifications for these information returns:
Forms Are
Covered?
1.1.3 ScopeFor purposes of this revenue procedure, a substitute form or statement is one that is not printed by the IRS.
For a substitute form or statement to be acceptable to the IRS, it must conform to the official form or the
specifications outlined in this revenue procedure. Do not submit any substitute forms or statements listed
above to the IRS for approval. Privately printed forms may not state “This is an IRS approved form.”
Filers making payments to certain recipients during a calendar year are required by the Internal Revenue
Code (the Code) to file information returns with the IRS for these payments. These filers must also provide
this information to their recipients. In some cases, this also applies to payments received. See Part 4for
specifications that apply to recipient statements (generally Copy B).
In general, section 6011 of the Code contains requirements for filers of information returns. A filer must file
information returns on magnetic media, through electronic filing, or on paper. A filer who is required to file
250 or more information returns of any one type during a calendar year must file those returns by magnetic
media or electronic filing.
2000–27 I.R.B.61July 3, 2000
FormTitle
1096 Annual Summary and Transmittal of U.S. Information Returns
1098Mortgage Interest Statement
1098-EStudent Loan Interest Statement
1098-TTuition Payments Statement
1099-AAcquisition or Abandonment of Secured Property
1099-BProceeds From Broker and Barter Exchange Transactions
1099-CCancellation of Debt
1099-DIVDividends and Distributions
1099-GCertain Government and Qualified State Tuition Program Payments
1099-INTInterest Income
1099-LTCLong-Term Care and Accelerated Death Benefits
1099-MISCMiscellaneous Income
1099-MSADistributions From an MSA or Medicare+Choice MSA
1099-OIDOriginal Issue Discount
1099-PATRTaxable Distributions Received From Cooperatives
1099-RDistributions From Pensions, Annuities, Retirement or Profit-Sharing Plans,
IRAs, Insurance Contracts, etc.
1099-SProceeds From Real Estate Transactions
5498IRA Contribution Information
5498-MSAMSA or Medicare+Choice MSA Information
W-2GCertain Gambling Winnings

Exception.Filers are not required to use magnetic media or electronic filing when filing 250 or more
Forms 1098-Eor 1098-T.
Although not required, small volume filers (fewer than 250 returns during a calendar year) and Form 1098-E
and 1098-T filers may file the forms on magnetic media or electronically. See the legal requirements for fil-
ing information returns (and providing a copy to a payee) in the 2000 General Instructions for Forms 1099,
1098, 5498, and W-2G.In addition, see Pub. 1220,Specifications for Filing Forms 1098, 1099, 5498, and
W-2G Magnetically or Electronically.
1.1.4 For More The IRS prints and provides the forms on which various payments must be reported. Alternatively, filers may
Informationprepare substitute copies of these IRS forms and use such forms to report payments to the IRS.
•For copies of the official forms and the instruction booklet for the reporting year, call our toll-free num-
ber at 1-800-TAX-FORM (1-800- 829-3676).
•The IRS operates a central call site in Martinsburg, WV, to answer questions related to information
returns, penalties, and backup withholding. Call 304-263-8700 Monday through Friday 8:30 a.m. to
4:30 p.m. eastern time. The TTY/TDD number is 304-267-3367.
1.1.5 Changes The following changes have been made to this year’s Revenue Procedure:
to the Revenue •A new Part 4, made up of sections from other Parts, has been added to better address recipient
Procedurestatements. (Old Part 4 is now Part 5.)
•We have rearranged certain sections in the document for easier understanding. For instance, Section
1.4of last year’s Revenue Procedure is now Section 2.2.
•We are now providing general and specific form instructions as separate products for 2000. The 2000
General Instructions for Forms 1099, 1098, 5498, and W-2G contain general information for all
forms. Separate specific instructions provide information for specific 2000 forms. These new products
are referred to on the faces and in the notes on the backs of the forms.
•We slightly revised Section 5.1 (OMB Requirements).
•The form dimensions shown on the exhibits have been slightly revised to reflect the actual dimensions
of official IRS forms.
Section 1.2 - General Requirements for Acceptable Substitute Forms 1096, 1098, 1099,
5498, and W-2G
1.2.1 Paper substitutes for Form 1096 and Copy A of Forms 1098, 1099, 5498, and W-2G that totally conform to
Introductionthe specifications listed in this revenue procedure may be privately printed and filed as returns with the IRS.
The reference to the Department of the Treasury - Internal Revenue Service should be included on all such
forms. If you are uncertain of any specification and want it clarified, you may submit a letter citing the spec-
ification, stating your understanding and interpretation of the specification, and enclosing an example of the
form (if appropriate) to:
Internal Revenue Service
Attn: Substitute Forms Program
OP:FS:FP:F:CD
1111 Constitution Ave., NW
Room 5244 IR
Washington, DC 20224
Note:Allow at least 45 days for the IRS to respond.
Forms 1096, 1098, 1099, 5498, and W-2G are subject to annual review and possible change. Therefore, filers
are cautioned against overstocking supplies of privately printed substitutes. The specifications contained in
this revenue procedure apply to 2000 forms only.
1.2.2 Copy AProposed substitutes for Copy A that do not conform to the specifications in this revenue procedure are not
Specificationsacceptable. Further, if you file such forms with the IRS, you may be subject to a penalty for failure to file an
information return under section 6721 of the Code. Generally, the penalty is $50 for each failure to file a
form (up to $250,000) that the IRS cannot accept as a return because it does not meet the provisions in this
revenue procedure. No IRS office is authorized to allow deviations from this revenue procedure.
July 3, 2000622000–27 I.R.B.

1.2.3 Copy B Copies B and Copies C of the following forms must contain the information in Section 1.5to be considered a
and Copy C “statement” or “official form” under the applicable provisions of the Code. The format of this information is
Specificationsat the discretion of the filer with the exception of the location of the tax year, form number, form name, and
the information for composite Form 1099 statements as outlined under Section 4.2.
Copy B of the following forms are:
Copy C of the following forms are:
Note: On Copy C, Form 1099-LTC, you may reverse the locations of the policyholder’s and the
insured’s name, street address, city, state, and ZIP code for easier mailing.
Section 1.3 - Definitions
1.3.1 Form Form recipientmeans the person to whom you are required by law to furnish a copy of the official form or
Recipientinformation statement. The form recipient may be referred to by different names on various Forms 1099 and
related forms (“payer/borrower,” “borrower,” “student,” “debtor,” “policyholder,” “insured,” “transferor,”
“payment recipient,” “participant,” or, in the case of Form W-2G, the “winner”). See Section 1.2.3 earlier.
1.3.2 FilerFilermeans the person or organization required by law to file a form listed in Section 1.1.2with the IRS. As
outlined earlier, a filer may be a payer, creditor, recipient of mortgage or student loan interest payments, edu-
cational institution, broker, barter exchange, person reporting real estate transactions, trustee or issuer of any
individual retirement arrangement or medical savings account, or lender who acquires an interest in secured
property or who has reason to know that the property has been abandoned.
1.3.3 Substitute Substitute formmeans a paper substitute of Copy A of an official form listed in Section 1.1.2that totally
Formconforms to the provisions in this revenue procedure.
1.3.4 Substitute Substitute form recipient statement means a paper statement of the information reported on a form listed in
Form Recipient Section 1.1.2. This statement must be furnished to a person (form recipient), as defined under the applicable
Statementprovisions of the Code and the applicable regulations.
2000–27 I.R.B.63July 3, 2000
FormRecipient
1098For Payer/Borrower
1098-E; 1099-AFor Borrower
1098-TFor Student
1099-CFor Debtor
1099-LTCFor Policyholder
1099-R; W-2G(These forms may require Copy B to be attached to
the Federal income tax return.)
1099-SFor Transferor
All other Forms 1099For Recipient
5498; 5498-MSAFor Participant
Form Recipient
1099-LTCFor Insured
1099-RFor Recipient’s Records
W-2GFor Winner’s Records

1.3.5 Composite Composite substitute statementmeans one in which two or more required statements (e.g., Forms 1099-
Substitute INT and 1099-DIV) are furnished to the recipient on one document. However, each statement must be desig-
Statementnated separately and must contain all the requisite Form 1099 information except as provided under Section
4.2. A composite statement may notbe filed with the IRS.
Part 2
Specifications for Substitute Forms 1096 and Copies A of Forms
1098, 1099,and 5498 (All Filed With the IRS)
Section 2.1 - Specifications
2.1.1 General Form identifying numbers (e.g., 9191 for Form 1099-DIV) must be printed in nonreflective black carbon-
Requirementsbased ink in print positions 15 through 19 using an OCR A font. The checkboxes to the right of the form
identifying numbers must be 10-point boxes. The “VOID” checkbox is in print position 25. The “COR-
RECTED” checkbox is in position 33. Measurements are from the left edge of the paper, not including the
perforated strip. See Exhibits D and K.
The substitute form must be an exact replica of the official IRS form with respect to layout and content. To
determine the correct form measurements, see Exhibits A through Tat the end of this publication.
Hot wax and cold carbon spots are not permitted on any of the internal form plies. These spots are permitted
on the back of a mailer top envelope ply.
Use of chemical transfer paper for Copy A is acceptable.
The Government Printing Office (GPO) symbol must be deleted.
2.1.2 Color and Color and paper quality for Copy A (cut sheets and continuous pinfeed forms) as specified by JCP Code 0-25,
Paper Qualitydated November 29, 1978, must be white 100% bleached chemical wood, optical character recognition
(OCR) bond produced in accordance with the following specifications.
Note: Reclaimed fiber in any percentage is permitted provided the requirements of this standard are met.
•Acidity: Ph value, average, not less than . . . . . . . . . . . . . . . . . . . . . . . . . .4.5
•Basis Weight: 17 x 22-500 cut sheets . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18-20
Metric equivalent—g/m
2
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .75
A tolerance of +5 pct. is allowed.
•Stiffness: Average, each direction, not less than—milligrams . . . . . . . . . . .50
•Tearing strength: Average, each direction, not less than—grams . . . . . . . . .40
•Opacity: Average, not less than—percent . . . . . . . . . . . . . . . . . . . . . . . . . .82
•Thickness: Average—inch . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .0.0038
Metric equivalent—mm . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .0.097
A tolerance of +0.0005 inch (0.0127 mm) is allowed. Paper cannot vary more than 0.0004 inch (0.0102 mm)
from one edge to the other.
•Porosity: Average, not less than—seconds . . . . . . . . . . . . . . . . . . . . . . . . .10
•Finish (smoothness): Average, each side—seconds . . . . . . . . . . . . . . . . . .20-55
For information only, the Sheffield equivalent—units . . . . . . . . . . . . . . . . . . . . . . 170-100
•Dirt: Average, each side, not to exceed—parts per million . . . . . . . . . . . . .8
July 3, 2000642000–27 I.R.B.

2.1.3 Chemical Chemical transfer paper is permitted for Copy A only if the following standards are met:
Transfer Paper•Only chemically backed paper is acceptable for Copy A. Front and back chemically treated paper can-
not be processed properly by machine.
•Carbon-coated forms are not permitted.
•Chemically transferred images must be black.
All copies must be clearly legible.Hot wax and cold carbon spots are notpermitted for Copy A.
Interleaved carbonshould be black and must be of good quality to assure legibility on all copies and to
avoid smudging. Fading must be minimized to assure legibility.
2.1.4 Printing All print on Copy A of Forms 1098, 1099, 5498,and the print on Form 1096above the statement “Please
return this entire page to the Internal Revenue Service. Photocopies are NOT acceptable.”must be in Flint
J-6983 red OCR dropout ink or an exact match. However, the four-digit form identifying number mustbe in
nonreflective carbon-based blackink in OCR A font.
The shaded areas of any substitute form should generally correspond to the format of the official form.
The printing for the Form 1096statement and the following text may be in any shade or tone of black ink.
Black ink should only appear on the lower part of the reverse side of Form 1096 where it will not bleed
through and interfere with scanning.
Note: The instructions on the front and back of Form 1096, which include filing addresses, must be printed.
Separation between fields must be 0.1 inch.
Except for Form 1099-R, the numbered captions are printed as solid with no shaded background.
Other printing requirements are discussed below.
2.1.5 OCR The contractor must initiate or have a quality control program to assure OCR ink density. Readings will be
Specificationsmade when printed on approved 20 lb. white OCR bond with a reflectance of not less than 80%. Black ink
must not have a reflectance greater than 15%. These readings are based on requirements of the “Scan-Optics
Series 9000” Optical Scanner using Flint J-6983 red OCR dropout ink or an exact match.
The following testers and ranges are acceptable:
•MacBeth PCM-II.The tested Print Contrast Signal (PCS) values when using the MacBeth PCM-II
tester on the “C” scale must range from .01 minimum to .06 maximum.
•Kidder 082A. The tested PCS values when using the Kidder 082A tester on the Infra Red (IR) scale
must range from .12 minimum to .21 maximum. White calibration disc must be 100%. Sensitivity
must be set at one (1).
•Alternative testers.Alternative testers must be approved by the Government so that tested PCS values
can be established. You may obtain approval by writing to the following address:
Commissioner of Internal Revenue
Attn: OP:FS:M:T:M, Room 1225
Tax Products
1111 Constitution Avenue, NW
Washington, DC 20224
2.1.6 Type must be substantially identical in size and shape to the official form. All rules are either 1/2-point or
Typography3/4-point. Rules must be identical to that on the official IRS form.
Note:The form identifying number must be nonreflective carbon-based black ink in OCR A font.
2.1.7 Three Forms 1098, 1099, or 5498 (Copy A)are contained on a single page,
Dimensions8 inches wide (without any snap-stubs and/or pinfeed holes) by 11 inches deep.
Exception. Form 1099-Rcontains two documents per page.
There is a .33 inch top margin from the top of the corrected box, and a .25 inch right margin. There is a
1/32” (0.0313”) tolerance for the right margin. If the right and top margins are properly aligned, the left mar-
2000–27 I.R.B.65July 3, 2000

July 3, 2000662000–27 I.R.B.
gin for all forms will be correct. All margins must be free of print. See Exhibits A through Tin this publi-
cation for the correct form measurements.
These measurements are constant for all Forms 1098, 1099, and 5498.These measurements are shown only
once in this publication, on Form 1098 (Exhibit B). Exceptions to these measurements are shown on the rest
of the exhibits.
The depth of the individual trim size of each form on a page must be 32/3 inches, the same depth as the offi-
cial form.
Exception. The depth of Form 1099-Ris 51/2 inches.
2.1.8 Copy A (three per page; two per page for Form 1099-R) of privately printed continuous substitute forms
Perforationmust be perforated at each 11” page depth. No perforations are allowed between the 3_” forms (5_” for
Form 1099-R) on a single copy page of Copy A.
The words “Do NOT Cut or Separate Forms on This Page” must be printed in red dropout ink (as required by
form specifications) between the three forms (two for Form 1099-R).
Note: Perforations are required between all the other individual copies (Copies B and C, and Copies 1
and 2 for Forms 1099-Rand 1099- MISC,and Copy D for Forms 1099-LTCand 1099-R) in the set.
2.1.9 What You must include the OMB Number on Copies Aand Form 1096in the same location as on the official
To Includeform.
The words “For Privacy Act and Paperwork Reduction Act Notice, see the 2000 General Instructions for
Forms 1099, 1098, 5498, and W-2G”must be printed on Copy A; “For more information and the
Privacy Act and Paperwork Reduction Act Notice, see the 2000 General Instructions for Forms 1099,
1098, 5498, and W-2G” mustbe printed on Form 1096.
A postal indicia may be used if it meets the following criteria:
•It is printed in the OCR ink color prescribed for the form, and
•No part of the indicia is within one print position of the scannable area.
Printer’s symbol — The GPO symbol must not be printed on substitute Copy A. Instead, the employer iden-
tification number (EIN) of the forms printer must be entered in the bottom margin on the face of each indi-
vidual form of Copy A,or the bottom margin on the reverse side of each Form 1096.
The Catalog Number (Cat. No.) shown on the 2000 forms is used for IRS distribution purposes and need not
be printed on any substitute forms.
The form must notcontain the statement “IRS approved” or any similar statement.
Section 2.2 - Instructions for Preparing Paper Forms That Will Be Filed With the IRS
2.2.1 Recipient The form recipient’s name, street address, city, state, and ZIP code information should be typed or machine
Informationprinted in black inkin the same format as shown on the official IRS form. The city, state, and ZIP code
must be on the same line.
The following rules apply to the form recipient’s name(s):
•The name of the appropriate form recipient must be shown on the first or second name line in the area
provided for the form recipient’s name.
•No descriptive information or other name may precede the form recipient’s name.
•Only oneform recipient’s name may appear on the first name line of the form.
•If the multiple recipients’ names are required on the form, enter on the first name line the recipient
name that corresponds to the recipient taxpayer identification number (TIN) shown on the form. Place
the other form recipients’ names on the second name line (only 2 name lines are allowable).
Because certain states require that trust accounts be provided in a different format, generally filers should
provide information returns reflecting payments to trust accounts with the:
•Trust’s employer identification number (EIN) in the recipient’s TIN area,

2000–27 I.R.B.67July 3, 2000
•Trust’s name on the recipient’s first name line, and
•Name of the trustee on the recipient’s second name line.
Although handwritten forms will be accepted, the IRS prefers that filers type or machine printdata entries.
Also, filers should insert data in the middle of blockswell separated from other printing and guidelines, and take
measures to guarantee clear, dark black, sharp images. Carbon copies and photocopies are not acceptable.
2.2.2 Account You should use the account number box for an account number designation. This number must not appear
Number Boxanywhere else on the form, and this box may not be used for any other item.
Showing the account number is optional. However, it may be to your benefit to include the recipient’s
account number or designation on paper documents if your recordkeeping system uses, for identification pur-
poses, the account number or designation in conjunction with, or instead of, the name, social security number,
or employer identification number.
If you furnish the account number, the IRS will include it in future notices to you about backup withholding.
If you use window envelopes and a reduced rate to mail statements to recipients, be sure the account number
does not appear in the window. Otherwise, the Postal Service may not accept them for mailing.
2.2.3 Machine-printed forms should be printed using a 6 lines/inch option, and should be printed in 10 pitch pica
Specifications (10 print positions per inch) or 12 pitch elite (12 print positions per inch). Proportional spaced fonts are
and Restrictionsunacceptable.
Substitute forms prepared in continuous or strip form must be burst and stripped to conform to
the size specified for a single sheet before they are filed with the IRS. The size specified does not include
pinfeed holes.Pinfeed holes must notbe present on forms filed with the IRS.
DO NOT:
•Use a felt tip marker. The machine used to “read” paper forms generally cannot read this ink type.
•Use dollar signs ($), ampersands (&), asterisks (*), commas (,), or other special characters in the num-
bered money boxes.
Exception.Use decimal points to indicate dollars and cents (e.g., 2000.00 is acceptable).
•Fold Forms 1096, 1098, 1099, or 5498mailed to the IRS. Mail these forms flat in an appropriately
sized envelope or box. Folded documents cannot be readily moved through the machine used in IRS
processing.
•Staple Forms 1096 to the transmitted returns. Any staple holes near the return code number may impair
the IRS’s ability to machine scan the type of documents.
•Type other information on Copy A.
•Cut or separate the individual forms on the sheet of forms of Copy A (except Forms W-2G).
2.2.4 Where Mail completed paper forms to the IRS service center shown on the back of Form 1096 and in the 2000
To FileGeneral Instructions for Forms 1099, 1098, 5498, and W-2G.Specific information needed to complete
the forms mentioned in this revenue procedure are given in the specific form instructions. A chart is included
in the 2000 General Instructions for Forms 1099, 1098, 5498, and W-2Ggiving a quick guide to which
form must be filed to report a particular payment.

Part 3
Specifications for Substitute Form W-2G (Filed With the IRS)
Section 3.1 - General
3.1.1 PurposeThe following specifications give the format requirements for substitute Form W-2G (Copy A only), which
is filed with the IRS.
A filer may use a substitute Form W-2Gto file with the IRS (referred to as “substitute Copy A”).The sub-
stitute form must be an exact replica of the official form with respect to layout and content.
Section 3.2 - Specifications for Copy A of Form W-2G
3.2.1 Substitute You must follow these specifications when printing substitute Copy A of Form W-2G.
Form W-2G
(Copy A)
July 3, 2000682000–27 I.R.B.
ItemSubstitute Form W-2G (Copy A)
Paper Color and QualityPaper for Copy A must be white chemical wood bond, or equiva-
lent, 20 pound (basis 17 x 22-500), plus or minus 5 percent. The
paper must consist substantially of bleached chemical wood pulp.
It must be free from unbleached or ground wood pulp or post-
consumer recycled paper. It also must be suitably sized to accept
ink without feathering.
Ink Color and QualityAll printing must be in a high quality nongloss black ink.
TypographyThe type must be substantially identical in size and shape to the
official form. All rules on the document are either 1/2 point (.007
inch), 1 point (0.015 inch), or 3 point (0.045). Vertical rules must
be parallel to the left edge of the document, horizontal rules to the
top edge.
DimensionsThe official form is 8 inches wide x 3 2/3 inches deep,
exclusive of a 2/3 inch snap stub on the left side of the form. Any
substitute Copy A must be the same dimensions. The snap feature
is not required on substitutes. All margins must be free of print.
The top and right margins must be 1/4 inch plus or minus .0313.
If the top and right margins are properly aligned, the left margin
for all forms will be correct. If the substitute forms are in contin-
uous or strip form, they must be burst and stripped to conform to
the size specifiedfor a single form.
Hot Wax and Cold Carbon SpotsHot wax and cold carbon spots are not permitted on any of the
internal form plies. These spots are permitted on the back of a
mailer top envelope ply. Interleaved carbons, if used, should be
black and of good quality to avoid smudging.
Printer’s SymbolThe Government Printing Office (GPO) symbol must not be print-
ed on substitute Forms W-2G. Instead, the employer identifica-
tion number (EIN) of the forms printer must be printed in the bot-
tom margin on the face of each individual Copy A on a sheet. The
form must not contain the statement “IRS approved” or any simi-
lar statement.
Catalog NumberThe Catalog Number (Cat. No.) shown on Form W-2G is used for
IRS distribution purposes and need not be printed on any substi-
tute forms.

Part 4
Substitute Statements to Form Recipients and Form Recipient Copies
Section 4.1 - Specifications
4.1.1 IntroductionIf you do not use the official IRS form to furnish statements to recipients, you must furnish an acceptable
substitute statement. To be acceptable, your substitute statement must comply with the rules in this section.
In general, see Regulations sections 1.6042–4, 1.6044–5, 1.6049–6, and 1.6050N–1 to determine how certain
statements must be provided to recipients (statement mailing requirements for most Forms 1099-DIVand
1099-INT,all Forms 1099-OIDand 1099-PATR,and Form 1099-MISC or 1099-Sfor royalties).
Note: A trustee of a grantor-type trust may choose to file Forms 1099and furnish a statement to the
grantor under Regulations sections 1.671–4(b)(2)(iii) and (b)(3)(ii). The statement required by those
regulations is not subject to the requirements outlined in this section.
4.1.2 Substitute The rules in this section apply to Form 1099-INT(except for interest reportable under section 6041), 1099-
Statements to DIV(except for section 404(k) dividends), 1099-OID,and 1099-PATR only.You may furnish form recipi-
Recipients forents with Copy Bof the official Form 1099 or a substitute Form 1099 (form recipient statement) if it contains
Certain Forms the same language as the official IRS form (such as aggregate amounts paid to the form recipient, any backup
1099-INT and withholding, the name, address, and TIN of the person making the return, and any other information required
1099-DIV, and by the official form). Except for state income tax withholding information, information not required by the
for Forms official form should not be included on the substitute form.
1099-OID and
1099-PATRYou may enter a total of the individual accounts listed on the form only if they have been paid by the same
payer. For example, if you are listing interest paid on several accounts by one financial institution on Form
1099-INT, you may also enter the total interest amount. You may also enter a date next to the corrected box
if that box is checked.
A substitute form recipient statement for Forms 1099-INT, 1099-DIV, 1099- OID, or 1099-PATRmust com-
ply with the following requirements:
1.Box captions and numbers that are applicable must be clearly identified, using the same wording and
numbering as on the official form.
Note:For Form 1099-INT,if box 3 is not on your substitute form, you may drop “not included in
box 3” from the box 1 caption.
2.The form recipient statement must contain all applicable form recipient instructions provided on the front
and back of the official IRS form. Those instructions may be provided on a separate sheet of paper.
3.The form recipient statement must contain the following in bold and conspicuous type:
This is important tax information and is being furnished to the Internal Revenue Service. If you
are required to file a return, a negligence penalty or other sanction may be imposed on you if this
income is taxable and the IRS determines that it has not been reported.
4. The box caption “Federal income tax withheld”must be in boldface type on the form recipient statement.
5.The form recipient statement must contain the Office of Management and Budget (OMB) number as
shown on the official IRS form. See Part 5.
6.The form recipient statement must contain the tax year (e.g., 2000), form number (e.g., Form 1099-INT),
and form name (e.g., Interest Income) of the official IRS Form 1099. This information must be displayed
prominently together in one area of the statement. For example, the tax year, form number, and form name
could be shown in the upper right part of the statement. Each copy must be appropriately labeled (such as
Copy B, For Recipient). See Section 4.4for applicable labels and arrangement of assembly of forms.
Note:Do not include the words “Substitute for” or “In lieu of” on the form recipient statement.
7.Layout and format of the form is at the discretion of the filer. However, the IRS encourages the use of
boxes so that the statement has the appearance of a form and can be easily distinguished from other
nontax statements.
8.Each recipient statement of Forms 1099-DIV, 1099-INT, 1099-OID,and 1099-PATRmustinclude the
direct access telephone number of an individual who can answer questions about the statement.
Include that telephone number conspicuously anywhere on the recipient statement.
9.Until new regulations are issued, the IRS will not assess penalties for use of a logo (e.g., the name of
the payer in any typeface, font, or style, and/or a symbolic icon) or slogan on a recipient statement if
2000–27 I.R.B.69July 3, 2000

the logo or slogan is used by the payer in the ordinary course of its trade or business. In addition, use
of the logo or slogan must not make it less likely for a reasonable payee to recognize the importance of
the statement for tax reporting purposes.
10. A mutual fund family may state separately on one document (e.g., one piece of paper) the dividend
income earned by a recipient from each fund within the family of funds as required by Form 1099-
DIV.However, each fund and its earnings must be stated separately. The form must contain an
instruction to the recipient that each fund’s dividends and name, not the name of the mutual fund fami-
ly, must be reported on the recipient’s tax return. The form cannot contain an aggregate total of all
funds. In addition, a mutual fund family may furnish a single statement (as a single filer) for Forms
1099-INT, 1099-DIV,and 1099- OIDinformation. Each fund and its earnings must be stated separate-
ly. The form must contain an instruction to the recipient that each fund’s earnings and name, not the
name of the mutual fund family, must be reported on the recipient’s tax return. The form cannot con-
tain an aggregate total of all funds.
4.1.3 Substitute Statements to form recipients for Forms 1098, 1098-E, 1098-T, 1099-A, 1099-B, 1099-C, 1099-G, 1099-
Statements to LTC, 1099-MISC, 1099-MSA, 1099-R, 1099-S, 5498, 5498-MSA, W-2G, 1099-DIV(only for section
Recipients for404(k) dividends reportable under section 6047), and 1099-INT(only for interest of $600 or more made in
Certain Forms the course of a trade or business reportable under section 6041) can be copies of the official forms or an
1098, 1099, acceptable substitute. To be acceptable, a substitute form recipient statement must meet the following
5498, and requirements.
W-2G1.The tax year, form number, and form name must be the same as the official form and must be displayed
prominently together in one area on the statement. For example, they may be shown in the upper right
part of the statement.
2.The filer’s and the form recipient’s identifying information required on the official IRS form must be
included.
3.Each substitute recipient statement for Forms W-2G, 1098, 1098-E, 1098-T, 1099-A, 1099-B, 1099-
DIV, 1099-G(excluding state and local income tax refunds), 1099-INT, 1099-LTC, 1099-MISC
(excluding fishing boat proceeds), 1099-OID, 1099-PATR,and 1099-Smustinclude the direct access
telephone number of an individual who can answer questions about the statement.You may include
the telephone number conspicuously anywhere on the recipient statement. Although not required,
payers reporting on Forms 1099-C, 1099-MSA, 1099-R, 5498,and 5498-MSAare encouraged to fur-
nish telephone numbers.
4.All applicable money amounts and information, including box numbers, required to be reported to the
form recipient must be titled on the form recipient statement in substantially the same manner as those
on the official IRS form. The box caption“Federal income tax withheld” must be in boldface type on
the form recipient statement.
Exception. If you are reporting a payment as “Other income” in box 3 of Form 1099-MISC,
you may substitute appropriate language for the box title. For example, for payments of
accrued wages and leave to a beneficiary of a deceased employee, you might change the title
of box 3 to “Beneficiary payments” or something similar.
Note: You cannot make this change on Copy A.
5.You must provide appropriate instructions to the form recipient, similar to those on the official IRS
form, to aid in the proper reporting on the form recipient’s income tax return. For payments reported
on Form 1099-B,the requirement to include instructions substantially similar to those on the official
IRS form may be satisfied by providing form recipients with a single set of instructions for all Forms
1099-Bstatements required to be furnished in a calendar year.
Note: If Federal income tax is withheld and shown on Form 1099-Ror W-2G, Copy B and
Copy C must be furnished to the recipient. If Federal income tax is not withheld, only Copy C
of Form 1099-Rand W-2Gmust be furnished. However, for Form 1099-R,instructions simi-
lar to those on the back of the official Copy B and Copy C of Form 1099-Rmust be furnished
to the recipient. For convenience, you may choose to provide both Copies B and C of Form
1099-Rto the recipient.
6.If you use carbon to produce recipient statements, the quality of the carbon must meet the following
standards:
•All copies must beclearly legible,
•All copies must be able to be photocopied, and
•Fading must not diminish legibility and the ability to photocopy.
In general, black chemical transfer inks are preferred, but other colors are permitted if the above stan-
dards are met. Hot wax and cold carbon spots are not permitted on any of the internal form plies. The
July 3, 2000702000–27 I.R.B.

back of a mailer top envelope ply may contain these spots.
7.A mutual fund family may state separately on one document (e.g., one piece of paper) the Form 1099-
Binformation for a recipient from each fund as required by Form 1099-B. However, the gross pro-
ceeds, etc., from each transaction within a fund must be stated separately. The form must contain an
instruction to the recipient that each fund’s (not the mutual fund family’s) name and amount must be
reported on the recipient’s tax return. The form cannot contain an aggregate total of all funds.
8.You may use a Uniform Settlement Statement (under the Real Estate Settlement Procedures Act of
1974 (RESPA)) for Form 1099-S.The Uniform Settlement Statement is acceptable as the written
statement to the transferor if you include the legend for Form 1099-Sin Section 4.3.2and indicate
which information on the Uniform Settlement Statement is being reported to the IRS on Form 1099-S.
9.For reporting state income tax withholding and state payments, you may add an additional box(es) to
recipient copies as appropriate.
Note:You cannot make this change on Copy A.
10.On Copy C of Form 1099-LTC,you may reverse the location of the policyholder’s and the insured’s
name, street address, city, state, and ZIP code for easier mailing.
11.Logos are permitted on substitute recipient statements for the forms listed in this section (Section
4.1.3).
Section 4.2 - Composite Statements
4.2.1 Composite A composite form recipient statement is permitted for reportable payments of interest, dividends, original
Substitute issue discount, patronage dividends, and royalties (Forms 1099-INT(except for interest reportable under
Statements forsection 6041), 1099- DIV(except for section 404(k) dividends), 1099-MISCor 1099-S (for royalties only),
Certain Forms 1099-OID,or 1099-PATR) when one payer is reporting more than one of these payments during a calendar
1099-INT, year to the same form recipient. Generally, do not include any other Form 1099information (e.g., 1098 or
1099-DIV, 1099-A)on a composite statement with the information required on the forms listed in the preceding sentence
1099-MISC,
and 1099-S, Exception. A filer may include Form 1099-Binformation on a composite form with the forms listed above.
and for Forms
1099-OID and Although the composite form recipient statement may be on one sheet, the format of the composite form
1099-PATRrecipient statement must satisfy the following requirements in addition to the requirements listed earlier in
Section 4.1.2.
•All information pertaining to a particular type of payment must be located and blocked together on the
form and separate from any information covering other types of payments included on the form. For
example, if you are reporting interest and dividends, the Form1099-INTinformation must be presented
separately from the Form 1099-DIVinformation.
•The composite form recipient statement must prominently display the tax year, form number, and form
name of the official IRS form together in one area at the beginning of each appropriate block of infor-
mation.
•Any information required by the official IRS forms that would otherwise be repeated in each informa-
tion block is required to be listed only once in the first information block on the composite form. For
example, there is no requirement to report the name of the filer in each information block. This rule
does not apply to any money amounts (e.g., Federal income tax withheld) or to any other information
that applies to money amounts.
•A composite statement is an acceptable substitute only if the type of payment and the recipient’s tax
obligation with respect to the payment are as clear as if each required statement were furnished sepa-
rately on an official form.
4.2.2 Composite A composite form recipient statement for the forms specified in Section 4.1.3 is permitted when one filer is
Substitute reporting more than one type of payment during a calendar year to the same form recipient. A composite
Statements to statement is not allowed for a combination of forms listed in Section 4.1.3and forms listed in Section 4.1.2.
Recipients for
Forms Specified Exceptions. Form 1099-Binformation may be reported on a composite form with the forms specified in
in Section 4.1.3Section 4.1.2as described in Section 4.2.1.In addition, royalties reported on Form 1099-MISC or
1099-Smay be reported on a composite form only with the forms specified in Section 4.1.2.
2000–27 I.R.B.71July 3, 2000

Although the composite form recipient statement may be on one sheet, the format of the composite form
recipient statement must satisfy the requirements listed in Section 4.2.1 as well as the requirements in
Section 4.1.3. A composite statement of Forms 1098 and 1099-INT(for interest reportable under section
6049) is notallowed.
Section 4.3 - Required Legends
4.3.1 Required Form 1098recipient statements (Copy B) must contain the following legends:
Legends for•Form 1098
Forms 10981.“The information in boxes 1, 2, and 3 is important tax information and is being furnished to
the Internal Revenue Service. If you are required to file a return, a negligence penalty or other
sanction may be imposed on you if the IRS determines that an underpayment of tax results
because you overstated a deduction for this mortgage interest or for these points or because
you did not report this refund of interest on your return.”
2.“Caution: The amount shown may not be fully deductible by you. Limits based on the loan amount
and the cost and value of the secured property may apply. Also, you may only deduct interest to the
extent it was incurred by you, actually paid by you, and not reimbursed by another person.”
•Form 1098-E –“This is important tax information and is being furnished to the Internal Revenue
Service. If you are required to file a return, a negligence penalty or other sanction may be imposed on
you if the IRS determines that an underpayment of tax results because you overstated a deduction for
student loan interest.”
•Form 1098-T – “This is important tax information and is being furnished to the Internal Revenue
Service.”
4.3.2 Required Forms 1099 and W-2G recipient statements must contain the following legends:
Legends for•Forms 1099-A and 1099-C – Copy B
Forms 1099 “This is important tax information and is being furnished to the Internal Revenue Service. If you are
required to file a return, a negligence penalty or other sanction may be imposed on you if taxable
income results from this transaction and the IRS determines that it has not been reported.”
and W-2G
•Forms 1099-B, 1099-DIV, 1099-G, 1099-INT, 1099-MISC, 1099-OID, 1099-PATR, and W-2G –
Copy C
“This is important tax information and is being furnished to the Internal Revenue Service. If you are
required to file a return, a negligence penalty or other sanction may be imposed on you if this income is
taxable and the IRS determines that it has not been reported.”
•Form 1099-LTC
Copy B – “This is important tax information and is being furnished to the Internal Revenue Service. If
you are required to file a return, a negligence penalty or other sanction may be imposed on you if this
item is required to be reported and the IRS determines that it has not been reported.”
Copy C – “Copy C is provided to you for information only. Only the policyholder is required to report
this information on a tax return.”
•Form 1099-MSA – Copy B
“This information is being furnished to the Internal Revenue Service.”
•Form 1099-R –
Copy B – “Report this income on your Federal tax return. If this form shows Federal income tax with-
held in box 4, attach this copy to your return. This information is being furnished to the Internal
Revenue Service.”
Copy C – “This information is being furnished to the Internal Revenue Service.”
•Form 1099-S – Copy B
“This is important tax information and is being furnished to the Internal Revenue Service. If you are
required to file a return, a negligence penalty or other sanction may be imposed on you if this item is
required to be reported and the IRS determines that it has not been reported.”
•Form W-2G – Copy B
“This information is being furnished to the Internal Revenue Service. Report this income on your Federal
tax return. If this form shows Federal income tax withheld in box 2, attach this copy to your return.”
July 3, 2000722000–27 I.R.B.

4.3.3 Required Form 5498 recipient statements (Copy B)must contain the following legends:
Legends for•Form 5498 – “This information is being furnished to the Internal Revenue Service.”
Forms 5498Note: If you do not furnish another statement to the participant because no contributions were
made for the year, the statement of the fair market value of the account must contain this legend
and a designation of which information is being furnished to the Internal Revenue Service.
•Form 5498-MSA – “The information in boxes 1 through 6 is being furnished to the Internal Revenue
Service.”
Section 4.4 - Miscellaneous Instructions for Copies B, C, D, 1, and 2
4.4.1 CopiesCopies B, C,and in some cases, D, 1, and 2are included in the official assembly for the convenience of the
filer. You are not legally required to include all these copies with the privately printed substitute forms.
Furnishing Copies B and, in some cases, C will satisfy the legal requirement to provide statements of infor-
mation to form recipients.
Note: If an amount of Federal income tax withheld is shown on Form 1099- R or W-2G, Copy B(to
be attached to the tax return) and Copy Cmust be furnished to the recipient. Copy D (Forms 1099-R
and W-2G)may be used for filer records. Only Copy Ashould be filed with the IRS.
4.4.2 Copy A (“For Internal Revenue Service Center”) of all forms must be on top. The rest of the assembly
Arrangement must be arranged, from top to bottom, as follows. For:
of Assembly•Form 1098—Copy B “For Payer”; Copy C “For Recipient.”
•Form 1098-E—Copy B “For Borrower”; Copy C “For Recipient.”
•Form 1098-T—Copy B “For Student”; Copy C “For Filer.”
•Form 1099-A—Copy B “For Borrower”; Copy C “For Lender.”
•Forms 1099-B, 1099-DIV, 1099-G, 1099-INT, 1099-MSA, 1099-OID, and 1099-PATR—Copy B
“For Recipient”; Copy C “For Payer.”
•Form 1099-C—Copy B “For Debtor”; Copy C “For Creditor.”
•Form 1099-LTC—Copy B “For Policyholder”; Copy C “For Insured”; and Copy D “For Payer.”
•Form 1099-MISC—Copy 1 “For State Tax Department”; Copy B “For Recipient”; Copy 2 “To be
filed with recipient’s state income tax return, when required”; and Copy C “For Payer.”
•Form 1099-R—Copy 1 “For State, City, or Local Tax Department”; Copy B “Report this income on
your Federal tax return. If this form shows Federal income tax withheld in box 4, attach this copy to
your return”; Copy C “For Recipient’s Records”; Copy 2 “File this copy with your state, city, or local
income tax return, when required”; Copy D “For Payer.”
•Form 1099-S—Copy B “For Transferor”; Copy C “For Filer.”
•Form 5498—Copy B “For Participant”; Copy C “For Trustee or Issuer.”
•Form 5498-MSA—Copy B “For Participant”; Copy C “For Trustee.”
•Form W-2G—Copy 1 “For State Tax Department”; Copy B “Report this income on your Federal tax
return. If this form shows Federal income tax withheld in box 2, attach this copy to your return”; Copy
C “For Winner’s Records”; Copy 2 “Attach this copy to your state income tax return, if required.”;
Copy D “For Payer.”
4.4.3 Perforations are required between forms on all copies except Copy A to make separating the forms easier.
Perforations(Copy A of Form W-2G may be perforated.)
2000–27 I.R.B.73July 3, 2000

Part 5
Additional Instructions for Substitute Forms 1098, 1099, 5498, and W-2G
Section 5.1 - OMB Requirements
5.1.1 OMB The Paperwork Reduction Act of 1995 (Public Law 104-13) requires that:
Requirements•The OMB approves all IRS tax forms that are subject to the Paperwork Reduction Act.
•Each form shows the OMB approval number in or near the upper right corner. (The official OMB
numbers may be found on the official IRS printed forms and are also shown on the forms in the
exhibits in Part 6.)
•The form (or its instructions) states:
1.Why the IRS needs the information,
2.How it will be used, and
3.Whether or not the information is required to be furnished to the IRS.
Any users of official or substitute IRS forms or instructions must be provided with this information.
5.1.2 Substitute The OMB requirements for substitute IRS forms are:
Form •Any substitute form or substitute statement to a recipient must show the OMB number as it appears on
Requirementsthe official IRS form.
•For Copy A, the OMB number must appear exactly as shown on the official IRS form.
•For any copy other than Copy A, the OMB number must use one of the following formats.
1.OMB No. XXXX-XXXX (preferred) or
2.OMB # XXXX-XXXX
5.1.3 Required All substitute forms (Copy A only)must state “For Privacy Act and Paperwork Reduction Act Notice, see the
Explanation 2000 General Instructions for Forms 1099, 1098, 5498, and W-2G.”
to Users
If no instructions are provided to users of your forms, you must furnish them the exact text of the Privacy Act
and Paperwork Reduction Act Notice.
Section 5.2 - Reproducible Copies
5.2.1 The IRS does not take orders for reproducible and information copies of Federal tax materials. However,
Introductionother ways to get Federal tax material include:
•The Internet.
•CD-ROM.
•GPO Superintendent of Documents Bookstores.
Forms 1096, 1098, 1099 series, and 5498 series are provided electronically on the IRS home page and on the
Federal Tax Forms CD-ROM, but cannot be used for filing with the IRS when printed from a conventional
printer. These forms contain drop-out ink requirements as described in Part 2 of this publication.
5.2.2 InternetYou can download tax materials from the Internet.
5.2.3 IRSThe IRS also offers an alternative to downloading electronic files and provides current and prior-year access
Federal Tax to tax forms and instructions through its Federal Tax Forms CD-ROM. The CD will be available for the
Formsupcoming filing season. Order Pub. 1796, Federal Tax Products on CD-ROM, by using the IRS’s Internet
CD-ROMWeb Site at www.irs.gov/cdorders.
July 3, 2000742000–27 I.R.B.
You Can Access the Internet by...Using...
File Transfer Protocol (FTP)ftp.irs.gov
World Wide Webwww.irs.gov

5.2.4 GPO The Government Printing Office (GPO) Superintendent of Documents Bookstores also sell individual copies
Supt. of of tax forms, instructions, and publications.
Documents
Bookstores
Section 5.3 - Effect on Other Revenue Procedures
5.3.1 OtherRevenue Procedure 99–34, 1999–40 I.R.B. 450,which provides rules and specifications for private printing of
Revenue 1999 substitute forms and statements to recipients, is superseded.
Procedures
2000–27 I.R.B.75July 3, 2000

Part 6
Exhibits
Section 6.1 - Exhibits of Forms in the Revenue Procedure
6.1.1 Purpose Exhibits A through T illustrate some of the specifications that were discussed earlier in this revenue proce-
dure. The dimensions apply to the actual size forms, but the exhibits have been reduced in size.
Generally, the illustrated dimensions apply to all like forms. For example, Exhibit B shows 11.00” from the
top edge to the bottom edge of Form 1098 and .85” between the bottom rule of the top form and the top rule
of the second form on the page. These dimensions apply to all forms that are printed three to a page.
6.1.2 Keep in mind the following guidelines when printing substitute forms.
Guidelines•Closely follow the specifications to avoid delays in processing the forms.
•Always use the specifications as outlined in this revenue procedure and illustrated in the exhibits.
•Do not add the text line “Do NOT Cut or Separate Forms on This Page” to the bottom form. This will
cause inconsistency with the specifications.
July 3, 2000762000–27 I.R.B.

2000–27 I.R.B.77July 3, 2000

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2000–27 I.R.B.79July 3, 2000

July 3, 2000802000–27 I.R.B.

2000–27 I.R.B.81July 3, 2000

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2000–27 I.R.B.83July 3, 2000

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2000–27 I.R.B.85July 3, 2000

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2000–27 I.R.B.87July 3, 2000

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2000–27 I.R.B.89July 3, 2000

July 3, 2000902000–27 I.R.B.

2000–27 I.R.B.91July 3, 2000

July 3, 2000922000–27 I.R.B.

2000–27 I.R.B.93July 3, 2000

July 3, 2000942000–27 I.R.B.

2000–27 I.R.B.95July 3, 2000

July 3, 2000962000–27 I.R.B.

2000–27 I.R.B.97July 3, 2000
Taxable Fuel Measurement
Notice 2000–33
Section 48.4081–8(a) of the Manufac-
turers and Retailers Excise Tax Regula-
tions provides that volumes of taxable
fuel may be measured on the basis of ei-
ther actual volumetric gallons or gallons
adjusted to 60 degrees Fahrenheit. Sec-
tion 48.4081–8(a) also provides, however,
that beginning July 1, 2000, for each pe-
riod from July 1 through the following
June 30, a person liable for tax on a re-
moval may use only one of the two bases
of measurement with respect to taxable
fuel removed from any particular termi-
nal, refinery, or blending facility. This
rule also applies to taxable entries and
sales.
The Internal Revenue Service and the
Treasury Department have determined
that many taxpayers will have to change
their accounting systems to comply with
the rule applicable beginning July 1,
2000, and will be unable to complete the
necessary changes by that date. Accord-
ingly, taxpayers will not be required to
comply with the rule before July 1, 2001.
In the meantime, a taxpayer may use ei-
ther basis of measurement for each tax-
able removal, entry, or sale of taxable
fuel.
The principal author of this notice is
Frank Boland of the Office of Assistant
Chief Counsel (Passthroughs and Special
Industries). For further information re-
garding this notice, contact Mr. Boland at
(202) 622-3130 (not a toll-free call).

July 3, 2000982000–27 I.R.B.
Notice of Proposed Rulemaking
and Notice of Public Hearing
Information Reporting for
Payments of Qualified Tuition
and Payments of Interest on
Qualified Education Loans;
Magnetic Media Filing
Requirements for Information
Returns
REG–105316–98
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of proposed rulemak-
ing and requests to videoconference the
public hearing.
SUMMARY: This document contains pro-
posed regulations relating to the informa-
tion reporting requirements under section
6050S of the Internal Revenue Code for
payments of qualified tuition and related
expenses and interest on qualified educa-
tion loans, including the filing of informa-
tion returns on magnetic media. The regu-
lations reflect changes to the law made by
the Taxpayer Relief Act of 1997. The regu-
lations provide guidance to eligible educa-
tional institutions and insurers receiving
payments of, or making reimbursements or
refunds of, qualified tuition and related ex-
penses. The regulations also provide guid-
ance to payees receiving interest payments
on qualified education loans. This docu-
ment also announces that a public hearing
will be held on the proposed regulations
upon request and that persons outside the
Washington, DC, area who wish to testify
at the hearing may request that the IRS
videoconference the hearing to their sites.
DATES: Written or electronically gener-
ated comments must be received by Sep-
tember 14, 2000. Requests to videoconfer-
ence the hearing to other sites must be
received by August 15, 2000. AD-
DRESSES: Send submissions to:
CC:DOM:CORP:R (REG–105316–98),
room 5226, Internal Revenue Service, POB
7604, Ben Franklin Station, Washington,
DC 20044. Submissions may be hand de-
livered Monday through Friday between
the hours of 8 a.m. and 5 p.m. to:
CC:DOM:CORP:R (REG–105316–98),
Courier’s Desk, Internal Revenue Service,
1111 Constitution Avenue, NW., Washing-
ton, DC. Taxpayers may also submit com-
ments electronically via the internet by se-
lecting the “Tax Regs” option on the IRS
Home Page, or by submitting comments di-
rectly to the IRS internet site at
http://www.irs.ustreas.gov/prod/tax_regs/re
gslist.html. The IRS will publish the time
and date of the public hearing and the loca-
tions of any videoconferencing sites in the
Federal Register.
FOR FURTHER INFORMATION CON-
TACT: Concerning the regulations, Donna
Welch, (202) 622-4910; concerning sub-
missions of comments, the hearing, and/or
to be placed on the building access list to
attend the hearing, Guy Traynor, (202) 622-
7180; concerning the magnetic media filing
specifications, waivers for filing on mag-
netic media, and extensions of time, contact
the Internal Revenue Service, Martinsburg
Computing Center, (304) 263-8700 (not
toll-free numbers).
SUPPLEMENTARY INFORMATION:
Paperwork Reduction Act
The collection of information con-
tained in this notice of proposed rulemak-
ing has been submitted to the Office of
Management and Budget for review in ac-
cordance with the Paperwork Reduction
Act of 1995 (44 U.S.C. 3507(d)). Com-
ments on the collection of information
should be sent to the Office of Manage-
ment and Budget, Attn: Desk Officer for
the Department of the Treasury, Office of
Information and Regulatory Affairs,
Washington, DC 20503, with copies to
the Internal Revenue Service, Attn: IRS
Reports Clearance Officer, OP:FS:FP,
Washington, DC 20224. Comments on
the collection of information should be re-
ceived by August 15, 2000. Comments
are specifically requested concerning:
Whether the proposed collection of in-
formation is necessary for the proper per-
formance of the functions of the IRS, in-
cluding whether the information will have
practical utility;
The accuracy of the estimated burden
associated with the proposed collection of
information (see below);
How the quality, utility, and clarity of
the information to be collected may be en-
hanced;
How the burden of complying with the
proposed collection of information may
be minimized, including through the ap-
plication of automated collection tech-
niques or other forms of information tech-
nology; and
Estimates of capital or start-up costs
and costs of operation, maintenance, and
purchase of services to provide informa-
tion.
The collection of information in this pro-
posed regulation is in §§1.6050S–1 and
1.6050S–2. In general, eligible educational
institutions and insurers must file a Form
1098-T, “Tuition Payments Statement,”
with the IRS for each individual with re-
spect to whom payments of qualified tu-
ition and related expenses were received, or
reimbursements or refunds of such ex-
penses were made, and furnish an informa-
tion statement to such individual. This col-
lection of information is required in order
to assist the IRS and taxpayers in calculat-
ing the amount of any education tax credit
allowable under section 25A. In addition,
payees who receive from any payor interest
payments aggregating $600 or more on one
or more qualified education loans must file
a Form 1098-E, “Student Loan Interest
Statement,” with the IRS and furnish an in-
formation statement to the payor. This col-
lection of information is required in order
to assist the IRS and taxpayers in calculat-
ing the amount of any student loan interest
deduction allowable under section 221.
The likely respondents are businesses or
other for-profit institutions and nonprofit
institutions.
Estimated total annual reporting burden
for 1998 for Form 1098-T: 2,419,438
hours.
Estimated average annual burden hours
per response for
Form 1098-T: 7 minutes.
Estimated number of responses for 1998
for Form 1098-T: 20,738,039.
Estimated annual frequency of responses:
Once.
Estimated total annual reporting burden
for 1998 for Form 1098-E: 437,691
hours.
Estimated average annual burden hours
per response for
Form 1098-E: 3 minutes.
Estimated number of responses for 1998
for Form 1098-E: 8,753,819.
Part IV. Items of General Interest

2000–27 I.R.B.99July 3, 2000
Estimated annual frequency of responses:
Once.
An agency may not conduct or sponsor,
and a person is not required to respond to,
a collection of information unless it dis-
plays a valid control number assigned by
the Office of Management and Budget.
Books or records relating to a collec-
tion of information must be retained as
long as their contents may become mater-
ial in the administration of any internal
revenue law. Generally, tax returns and
tax return information are confidential, as
required by 26 U.S.C. 6103.
Background
1. Information Reporting Requirements
This document contains proposed
amendments to the Income Tax Regula-
tions (26 CFR part 1) relating to informa-
tion reporting requirements under section
6050S. The Taxpayer Relief Act of 1997
(Public Law 105-34 (111 Stat. 788) (TRA
‘97)) added section 25A of the Internal
Revenue Code to provide the Hope Schol-
arship Credit and the Lifetime Learning
Credit (education tax credits). In general,
the Hope Scholarship Credit and the Life-
time Learning Credit allow certain tax-
payers who pay qualified tuition and re-
lated expenses to an eligible educational
institution to claim a nonrefundable credit
against their Federal income tax liability.
On January 6, 1999, the IRS issued pro-
posed regulations under section 25A. See
64 F.R. 794 (1999).
TRA ‘97 also added section 221 of the
Internal Revenue Code to allow certain
taxpayers who pay interest on qualified
education loans to claim a Federal income
tax deduction for their interest payments.
In general, a deduction is allowed for in-
terest payments made during the first 60
months in which interest payments are re-
quired on a qualified education loan.
However, no interest deduction is allowed
for any interest paid before January 1,
1998. On January 21, 1999, the IRS is-
sued proposed regulations under section
221. See 64 F.R. 3257 (1999).
In addition, TRA ‘97 added section
6050S of the Internal Revenue Code,
which requires eligible educational insti-
tutions to file information returns and to
furnish written information statements to
assist taxpayers and the IRS in determin-
ing any education tax credit allowable
under section 25A. Similarly, section
6050S requires any person engaged in a
trade or business of making payments to
any individual under an insurance agree-
ment as reimbursements or refunds of
qualified tuition and related expenses to
file information returns and to furnish
written information statements. Lastly,
section 6050S requires certain payees
who receive payments of interest on one
or more qualified education loans to file
information returns and to furnish written
information statements to assist taxpayers
and the IRS in determining any interest
deduction allowable under section 221.
The IRS has published several notices
prescribing limited information reporting
for eligible educational institutions for the
years 1998, 1999, and 2000. On Decem-
ber 22, 1997, the IRS published Notice
97–73 (1997–2 C.B. 335), which de-
scribes the information that an eligible ed-
ucational institution must report for 1998.
On September 8, 1998, the IRS published
Notice 98–46 (1998–36 I.R.B. 21), which
extends the application of Notice 97–73
to information returns required under sec-
tion 6050S for 1999. On December 7,
1998, the IRS published Notice 98–59
(1998–49 I.R.B. 16), which modifies the
prior Notices by providing that an institu-
tion is not required to file information re-
turns for students who are: (1) enrolled
during the year only in courses for which
the student receives no academic credit;
or (2) nonresident alien students, unless
the student requests the institution to re-
port. On July 26, 1999, the IRS published
Notice 99–37 (1999–30 I.R.B. 124),
which extends the application of Notice
97–73 (as modified) to information re-
turns required under section 6050S for
2000.
In addition, the IRS has published sev-
eral notices describing the information re-
porting for certain payees who receive in-
terest on qualified education loans during
the years 1998, 1999, and 2000. On Janu-
ary 20, 1998, the IRS published Notice
98–7 (1998–1 C.B. 339), which describes
the information reporting required under
section 6050S for 1998. On November
16, 1998, the IRS published Notice 98–54
(1998–2 C.B. 641), which modifies No-
tice 98–7 to reflect a technical change to
section 221 made by the Internal Revenue
Service Restructuring and Reform Act of
1998 (Public Law 105-206 (112 Stat.
685)), and extends the application of No-
tice 98–7 (as modified) to information re-
porting required under section 6050S for
1999. On July 26, 1999, the IRS pub-
lished Notice 99–37, which extends the
application of Notice 98–7 (as modified)
to information returns required under sec-
tion 6050S for 2000.
2. Magnetic Media Requirements
This document also contains proposed
amendments to the Regulations on Proce-
dure and Administration (26 part 301) re-
lating to the filing of information returns
on magnetic media under section 6011(e).
Section 6011(e) authorizes the Secretary
to prescribe regulations providing the
standards for determining which returns
must be filed on magnetic media. Section
6011(e)(2)(A) provides that the Secretary
shall not require any person to file returns
on magnetic media unless the person is
required to file at least 250 returns during
the calendar year. Section 6011(e)(2)(B)
provides that, in prescribing regulations,
the Secretary shall consider the ability of
the taxpayer to comply at reasonable cost
with the requirements of the regulations.
Explanation of Provisions
1. Information Reporting for Payments
and Reimbursements or Refunds of Quali-
fied Tuition and Related Expenses
The proposed regulations require an el-
igible educational institution (as defined
in section 25A(f)(2) and the regulations
thereunder) (an institution) that receives
payments of qualified tuition and related
expenses (as defined in section 25A(f)(1)
and the regulations thereunder) with re-
spect to any individual, or makes reim-
bursements or refunds of such amounts,
to file a Form 1098-T with the IRS. In
addition, the proposed regulations require
any person engaged in a trade or business
of making payments under an insurance
arrangement as reimbursements or re-
funds (or other similar amounts) of quali-
fied tuition and related expenses (an in-
surer) to file a Form 1098-T with the IRS.
Under the proposed regulations, the
following information must be reported
on Form 1098-T: (a) the name, address,
and taxpayer identification number
(TIN)(as defined in section 7701(a)(41))
of the institution or the insurer; (b) the
name, address, and TIN of the individual

July 3, 20001002000–27 I.R.B.
with respect to whom payments of quali-
fied tuition and related expenses were re-
ceived, or reimbursements or refunds
were made; (c) the aggregate amount of
payments of qualified tuition and related
expenses from any source that the institu-
tion received with respect to the individ-
ual during the calendar year; (d) the ag-
gregate amount of reimbursements or
refunds of qualified tuition and related ex-
penses that the institution or insurer made
with respect to the individual during the
calendar year; (e) the aggregate amount of
any scholarships or grants that the institu-
tion processed during the calendar year
for the payment of the individual’s costs
of attendance; (f) an indication by the in-
stitution whether the individual was en-
rolled for at least half of the normal full-
time work load for the course of study the
individual is pursuing for at least one aca-
demic period that begins during the calen-
dar year; (g) an indication by the institu-
tion whether the individual was enrolled
in a program leading to a graduate-level
degree, graduate-level certificate, or other
recognized graduate-level educational
credential; and (h) any other information
required by Form 1098-T and its instruc-
tions.
The proposed regulations reserve the
requirement in section 6050S(b)(2)(B)
that an institution or insurer obtain and re-
port the name, address, and TIN of any
taxpayer who will claim the individual
with respect to whom payments are re-
ceived, or reimbursements or refunds are
made, as a dependent for purposes of the
deduction allowable under section 151 for
the taxable year. Thus, under the pro-
posed regulations, there is no requirement
to obtain and report the name, address,
and TIN of any taxpayer who will claim
the individual as a dependent on the tax-
payer’s Federal income tax return.
Consistent with the exceptions to re-
quired reporting in Notice 98–59, the pro-
posed regulations provide that an institu-
tion or insurer is not required to file a
Form 1098-T for an individual who is a
nonresident alien, unless the individual
requests that the institution or insurer re-
port. In addition, an institution is not re-
quired to file a Form 1098-T for an indi-
vidual who is enrolled during the calendar
year only in courses for which the indi-
vidual receives no academic credit.
Under the proposed regulations, the term
academic creditmeans credit awarded by
an institution for the completion of
coursework leading toward a post-sec-
ondary degree, certificate, or other recog-
nized post-secondary educational creden-
tial.
The proposed regulations provide that,
in determining the payments for qualified
tuition and related expenses that an insti-
tution must report, payments received
with respect to an individual from any
source (except for any scholarship or
grant that, by its terms, must be applied to
expenses other than qualified tuition and
related expenses, such as room and board)
are treated as payments of qualified tu-
ition and related expenses up to the total
amount billed for such expenses.
The proposed regulations provide that
an institution or insurer must furnish an
information statement to each individual
for whom it is required to file a Form
1098-T. The proposed regulations pro-
vide that the statement must include the
information included on the Form 1098-T
filed with the IRS and a legend that iden-
tifies the statement as important tax infor-
mation being furnished to the IRS. The
statement must include instructions that
state that the taxpayer may not be able to
claim an education tax credit under sec-
tion 25A and the regulations thereunder
with respect to the total payments of qual-
ified tuition and related expenses reported
for the calendar year. The instructions
must state that the amount of the scholar-
ships, grants, reimbursements, or refunds
reported for the calendar year and other
similar amounts not reported (because
they are not processed by the institution)
may reduce the amount of any allowable
education tax credit for the taxable year or
a prior taxable year. The instructions
must state that the taxpayer should refer
to relevant IRS forms and publications
(such as Form 8863, “Education Credits,”
and Publication 970, “Tax Benefits for
Higher Education”) for explanations re-
lating to the eligibility requirements for,
and the calculation of, any allowable edu-
cation tax credit.
The proposed regulations reserve the
requirement in section 6050S(d) that an
institution or insurer furnish a statement
to any taxpayer who will claim the indi-
vidual with respect to whom payments are
received, or reimbursements or refunds
are made, as a dependent for purposes of
the deduction allowable under section 151
for the taxable year. Thus, under the pro-
posed regulations, there is no requirement
to furnish a statement to any taxpayer
who will claim the individual as a depen-
dent on the taxpayer’s Federal income tax
return.
The proposed regulations describe the
rules for the time and manner of filing in-
formation returns with the IRS and fur-
nishing information statements. Forms
1098-T must generally be filed with the
IRS on or before February 28 (March 31
if filed electronically) of the year follow-
ing the calendar year in which the pay-
ments were received, or reimbursements
or refunds were made. In general, an in-
stitution or insurer must furnish an infor-
mation statement to each individual with
respect to whom payments of qualified tu-
ition and related expenses were received,
or reimbursements or refunds were made,
on or before January 31 of the year fol-
lowing the calendar year in which pay-
ments were received, or reimbursements
or refunds were made. Although the reg-
ulations do not specifically address the
issue of electronic transmission of infor-
mation statements, the IRS is currently
studying the issue. Accordingly, the IRS
may address that issue in future guidance.
Under the proposed regulations, an in-
stitution or insurer may be subject to a
penalty under section 6721 for failure to
file correct Forms 1098-T and a penalty
under section 6722 for failure to furnish
correct information statements. The pro-
posed regulations generally follow the
rules under section 6724 for waivers of
penalties for certain failures due to rea-
sonable cause. The regulations also pro-
vide special rules for soliciting an individ-
ual’s TIN. An institution or insurer that
complies with those rules will not be pe-
nalized for any failure to obtain or include
a correct TIN on a Form 1098-T or the re-
lated information statement.
2. Information Reporting for Payments of
Interest on Qualified Education Loans
The proposed regulations require any
person engaged in a trade or business that
receives from any payor interest of $600
or more for any calendar year on one or
more qualified education loans (as de-
fined in section 221(e)(1) and the regula-
tions thereunder) (a payee) to file a Form
1098-E with the IRS. Under the proposed

2000–27 I.R.B.101July 3, 2000
regulations, a payee must report the name,
address, and taxpayer identification num-
ber (TIN) of the payee; the name, address,
and TIN of the payor; and the aggregate
amount of interest received during the
calendar year from the payor. The payee
may be the lender, the holder of the loan,
or the loan servicer. The regulations de-
fine the payoras the individual carried on
the books and records of the payee as the
borrower on a qualified education loan. If
there are multiple borrowers, the principal
borrower indicated on the payee’s books
and records is treated as the payor for pur-
poses of section 6050S.
Under the proposed regulations, a
payee is required to report only interest
payments received on a qualified educa-
tion loan during the first 60 months in
which interest payments are required on
the loan. The proposed regulations, in
general, incorporate the rules of section
221 and the regulations thereunder to de-
termine the 60-month period for which in-
terest payments must be reported. Under
the proposed regulations, the 60-month
period generally begins on the date the
qualified education loan first enters re-
payment status. However, for qualified
education loans made before January 1,
1998, if the payee does not know, and
does not have reason to know, the date on
which the loan entered repayment status,
then, for information reporting purposes,
the 60-month period begins on January 1,
1998. For defaulted loans made before
January 1, 1998, if the payee does not
know, and does not have reason to know,
the date on which the loan entered repay-
ment status, then, for information report-
ing purposes, the 60-month period begins
on the earlier of the date the loan went
into default or January 1, 1998. If the
payee does not know, and does not have
reason to know, either the date the loan
entered repayment status or the default
date, then, for information reporting pur-
poses, the 60-month period begins on Jan-
uary 1, 1998.
The proposed regulations provide that,
in determining the aggregate amount of
interest payments to be reported by a
payee, the term interestincludes stated in-
terest, loan origination fees (other than
any fees for services), and capitalized in-
terest as described in proposed regula-
tions §1.221–1(h)(2). However, in order
to provide payees sufficient time to de-
velop systems to report amounts other
than stated interest, the proposed regula-
tions do not require payees to report loan
origination fees and capitalized interest
for loans made before January 1, 2002.
The proposed regulations provide rules
to determine which loans are qualified ed-
ucation loans subject to information re-
porting under section 6050S. The regula-
tions provide that, unless the loan is
subsidized, guaranteed, financed, or oth-
erwise treated as a student loan under a
program of the Federal, state, or local
government or an eligible educational in-
stitution, the payee must request and ob-
tain a certification from the payor that the
loan will be used solely to pay qualified
higher education expenses. The regula-
tions provide that the payee may use
Form W-9S, “Request for Student’s So-
cial Security Number and Borrower Certi-
fication,” to request and obtain the certifi-
cation. If a payee fails to obtain a
required certification, the loan is not
treated as a qualified education loan for
purposes of section 6050S.
The proposed regulations provide that a
payee must furnish an information state-
ment to each payor for whom it is re-
quired to file a Form 1098-E. The pro-
posed regulations provide that the
statement must include the information
included on the Form 1098-E filed with
the IRS and a legend that identifies the
statement as important tax information
being furnished to the IRS. The statement
must include instructions that state that,
under section 221 and the regulations
thereunder, the payor may not be able to
deduct the full amount of interest reported
on the statement. The instructions must
state that interest payments are deductible
only during the first 60-months that inter-
est payments are required. If the payee
reports only stated interest, the instruc-
tions must state that the payor may be
able to deduct additional amounts (e.g.,
certain loan origination fees and capital-
ized interest) not reported on the state-
ment. The instructions must also state
that the payor should refer to relevant IRS
forms and publications (such as Publica-
tion 970) for explanations relating to the
eligibility requirements for, and the calcu-
lation of, any allowable interest deduction
on qualified education loans.
The proposed regulations describe the
rules for the time and manner of filing in-
formation returns with the IRS and fur-
nishing information statements to payors.
Forms 1098-E must generally be filed
with the IRS on or before February 28
(March 31 if filed electronically) of the
year following the calendar year in which
the interest payments were received. In
general, a payee must furnish an informa-
tion statement to the payor on or before
January 31 of the year following the cal-
endar year in which interest payments
were received. Although the regulations
do not specifically address the issue of
electronic transmission of information
statements, the IRS is currently studying
the issue. Accordingly, the IRS may ad-
dress that issue in future guidance.
Under the proposed regulations, a
payee may be subject to a penalty under
section 6721 for failure to file correct
Forms 1098-E and a penalty under section
6722 for a failure to furnish correct infor-
mation statements. The proposed regula-
tions generally follow the rules under sec-
tion 6724 for waivers of penalties for
certain failures due to reasonable cause.
The regulations also provide special rules
for soliciting the payor’s TIN. A payee
that complies with those rules will not be
penalized for any failure to obtain or in-
clude a correct TIN on a Form 1098-E or
the related information statement.
3. Requirement to File Information
Returns on Magnetic Media
The proposed regulations amend the
regulations under section 6011(e) to re-
quire eligible educational institutions, in-
surers, and payees who are required to file
250 or more Forms 1098-T or 1098-E to
file on magnetic media. Under
§301.6011–2(a)(1), the term magnetic
mediameans any media permitted under
applicable regulations, revenue proce-
dures, or publications, including magnetic
tape, tape cartridge, and diskette, as well
as other media (such as electronic filing).
Proposed Effective Date
These regulations are proposed to
apply to information returns required to
be filed, and information statements re-
quired to be furnished, after December
31, 2001. Taxpayers may rely on these
proposed regulations for guidance pend-
ing the issuance of final regulations. If,
and to the extent, future guidance is more
restrictive than the guidance in the pro-

July 3, 20001022000–27 I.R.B.
posed regulations, the future guidance
will be applied without retroactive effect.
Special Analyses
It has been determined that these pro-
posed regulations are not a significant
regulatory action as defined in Executive
Order 12866. Therefore, a regulatory as-
sessment is not required. It has also been
determined that section 553(b) of the Ad-
ministrative Procedure Act (5 U.S.C.
chapter 5) does not apply to these regula-
tions. An initial regulatory flexibility
analysis has been prepared for this notice
of proposed rulemaking under 5 U.S.C.
603 and is set forth under the heading
“Initial Regulatory Flexibility Analysis”
in this preamble. Pursuant to section
7805(f), this notice of proposed rulemak-
ing will be submitted to the Chief Counsel
for Advocacy of the Small Business Ad-
ministration for comment on its impact on
small business.
Initial Regulatory Flexibility Analysis
The collection of information con-
tained in §§1.6050S–1(a) and (b) and
1.6050S–2(a) and (c) is needed to assist
the IRS and taxpayers in determining the
amount of any education credit allowable
under section 25A and the amount of any
interest deduction allowable under section
221. The objectives of the proposed regu-
lations are to provide uniform, practica-
ble, and administrable rules under section
6050S. The types of small entities to
which the proposed regulations may
apply are small eligible educational insti-
tutions (such as colleges and universities),
certain insurers who reimburse educa-
tional expenses, and certain payees who
receive payments of interest on qualified
education loans. As of the end of Decem-
ber 1999, a total of 20,738,039 Forms
1098-T were filed with the IRS for 1998
and a total of 8,753,819 Forms 1098-E
were filed with the IRS for 1998. The
current estimated reporting burden is 7
minutes per Form 1098-T and 3 minutes
per Form 1098-E. No special profes-
sional skills are necessary for preparation
of the reports or records. There are no
known Federal rules that duplicate, over-
lap, or conflict with these proposed regu-
lations. The regulations proposed are
considered to have the least economic im-
pact on small entities of all alternatives
considered.
Moreover, the proposed regulations re-
quiring filing Forms 1098-T and 1098-E
on magnetic media impose no additional
reporting or recordkeeping and only pre-
scribe the method of filing information re-
turns that are already required to be filed.
Further, these regulations are consistent
with the statutory requirement that an eli-
gible educational institution, insurer, or
payee is not required to file Forms 1098-T
or 1098-E on magnetic media unless re-
quired to file at least 250 or more returns
during the year. Finally, the economic im-
pact caused by requiring Forms 1098-T
and 1098-E on magnetic media should be
minimal because most institution’s, in-
surer’s, and payee’s operations are com-
puterized. Even if their operations are not
computerized, the incremental cost of
magnetic media reporting should be mini-
mal in most cases because of the availabil-
ity of computer service bureaus. In addi-
tion, the existing regulations under section
6011(e) provide that the IRS may waive
the magnetic media filing requirements on
a showing of hardship. The waiver au-
thority will be exercised so as not to un-
duly burden institutions, insurers, and pay-
ees lacking both the necessary data
processing facilities and access at a rea-
sonable cost to computer service bureaus.
Comments and Public Hearing
Before these proposed regulations are
adopted as final regulations, considera-
tion will be given to any written and elec-
tronic comments that are submitted timely
to the IRS. The IRS and Treasury specifi-
cally request comments on the clarity of
the proposed regulations and how they
can be made easier to understand. All
comments will be available for public in-
spection and copying.
A public hearing will be scheduled in
the Internal Revenue Building, 1111 Con-
stitution Avenue, NW., Washington, DC.
The IRS recognizes that persons outside
the Washington, DC, area may also wish
to testify at the public hearing through
videoconferencing. Requests to include
videoconferencing sites must be received
by August 15, 2000. If the IRS receives
sufficient indications of interest to war-
rant videoconferencing to a particular
city, and if the IRS has videoconferencing
facilities available in that city on the date
the public hearing is to be scheduled, the
IRS will try to accommodate the requests.
The IRS will publish the time and date
of the public hearing and the locations of
any videoconferencing sites in a docu-
ment in the Federal Register.
Drafting Information
The principal author of the regulations
is Donna Welch, Office of Assistant Chief
Counsel (Income Tax and Accounting).
However, other personnel from the IRS
and the Treasury Department participated
in the development of the regulations.
* * * * *
Proposed Amendments to the
Regulations
Accordingly, 26 CFR parts 1 and 301
are proposed to be amended as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 is amended by adding entries in nu-
merical order to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Section 1.6050S–1 also issued under sec-
tion 26 U.S.C. 6050S(g).
Section 1.6050S–2 also issued under sec-
tion 26 U.S.C.
6050S(g). * * *
Par. 2. Sections 1.6050S–0 through
1.6050S–2 are added to read as follows:
§1.6050S–0 Table of contents
This section lists captions contained in
§§1.6050S–1 and 1.6050S–2.
§1.6050S–1 Information reporting for
payments and reimbursements or refunds
of qualified tuition and related expenses.
(a) Information reporting requirement.
(1) In general.
(2) Exceptions.
(i) No reporting for nonresident alien in-
dividuals.
(ii) No reporting for individuals enrolled
in noncredit courses.
(A) In general.
(B) Academic credit defined.
(C) Example.
(b) Requirement to file return.
(1) Form of return.
(2) Information included on return.
(i) In general.
(ii) Requirement to include name, ad-
dress, and TIN of any taxpayer who will
claim the individual as a dependent on the
taxpayer’s Federal income tax return.
[Reserved]
(3) Time and place for filing return.

2000–27 I.R.B.103July 3, 2000
(i) In general.
(ii) Return for nonresident alien individ-
ual.
(iii) Extensions of time.
(4) Use of magnetic media.
(c) Requirement to furnish statement.
(1) In general.
(2) Statement furnished to any taxpayer
who will claim the individual as a depen-
dent on the taxpayer’s Federal income tax
return. [Reserved]
(3) Time and manner for furnishing state-
ment.
(i) In general.
(ii) Statement to nonresident alien indi-
vidual.
(iii) Extensions of time.
(4) Time and manner for furnishing state-
ment to any taxpayer who will claim the
individual as a dependent on the tax-
payer’s Federal income tax return. [Re-
served]
(5) Copy of Form 1098-T.
(d) Special rules.
(1) Payments received for qualified tu-
ition and related expenses determined.
(i) In general.
(ii) Example.
(2) Payments of qualified tuition and re-
lated expenses received or collected on
behalf of an institution.
(i) In general.
(ii) Exception.
(3) Governmental units.
(e) Penalty provisions.
(1) Failure to file correct returns.
(2) Failure to furnish correct information
statements.
(3) Waiver of penalties for failures to in-
clude a correct TIN.
(i) In general.
(ii) Acting in a responsible manner.
(iii) Manner of soliciting TIN.
(4) Requirement to request and obtain
TIN of any taxpayer who will claim the
individual as a dependent on the tax-
payer’s Federal income tax return. [Re-
served]
(5) Failure to furnish TIN.
(f) Effective date.
§1.6050S–2 Information reporting for
payments of interest on qualified educa-
tion loans.
(a) Information reporting requirement.
(1) In general.
(2) Reporting period.
(i) In general.
(ii) Calculation of 60-month period.
(iii) Transitional rules for reporting on
loans made before January 1, 1998.
(b) Definitions.
(c) Requirement to file return.
(1) Form of return.
(2) Information included on return.
(3) Time and place for filing return.
(i) In general.
(ii) Extensions of time.
(4) Use of magnetic media.
(d) Requirement to furnish statement.
(1) In general.
(2) Time and manner for furnishing state-
ment.
(i) In general.
(ii) Extensions of time.
(3) Copy of Form 1098-E.
(e) Special rules.
(1) Transitional rule for reporting of loan
origination fees and capitalized interest.
(2) Qualified education loan certification.
(3) Payments of interest received or col-
lected by one or more persons.
(i) In general.
(ii) Exception.
(4) Reporting by foreign persons.
(5) Governmental units.
(f) Penalty provisions.
(1) Failure to file correct returns.
(2) Failure to furnish correct information
statements.
(3) Waiver of penalties for failures to in-
clude a correct TIN.
(i) In general.
(ii) Acting in a responsible manner.
(iii) Manner of soliciting TIN.
(4) Failure to furnish TIN.
(g) Effective date.
§1.6050S–1 Information reporting for
payments and reimbursements or refunds
of qualified tuition and related expenses.
(a) Information reporting requirement—
(1) In general. Except as provided in
paragraph (a)(2) of this section, any eligi-
ble educational institution (as defined in
section 25A(f)(2) and §1.25A–2(b))(an in-
stitution) that receives payments of quali-
fied tuition and related expenses (as de-
fined in section 25A(f)(1) and
§1.25A–2(d)) from any source for any cal-
endar year, or that makes reimbursements
or refunds (or similar payments) of such
amounts, and any person engaged in a
trade or business of making payments
under an insurance arrangement as reim-
bursements or refunds (or other similar
amounts) of qualified tuition and related
expenses (an insurer) must—
(i) File an information return, as de-
scribed in paragraph (b) of this section,
with the Internal Revenue Service (IRS)
with respect to each individual for whom
such payments are received, or reim-
bursements or refunds are made; and
(ii) Furnish a statement, as described in
paragraph (c) of this section,to each indi-
vidual described in paragraph (c) of this
section.
(2) Exceptions—(i) No reporting for non-
resident alien individuals. The information
reporting requirements of this section do not
apply with respect to any individual who is
a nonresident alien (as defined in section
7701(b) and §301.7701(b)–3 of this chap-
ter) during the calendar year, unless the in-
dividual requests the institution or insurer to
report. If a nonresident alien individual re-
quests an institution or insurer to report, the
institution or insurer must comply with the
requirements of this section for the year
with respect to which the request is made
and all years after such request in which it
receives payments of qualified tuition and
related expenses or makes reimbursements
or refunds of such amounts with respect to
such individual.
(ii) No reporting for individuals en-
rolled in noncredit courses—(A) In gen-
eral. The information reporting require-
ments of this section do not apply with
respect to any individual who is enrolled
during the calendar year only in courses
for which the individual receives no acad-
emic credit.
(B) Academic credit defined. Acade-
mic creditmeans credit awarded by an in-
stitution for the completion of coursework
leading toward a post-secondary degree,
certificate, or other recognized post-sec-
ondary educational credential.
(C) Example. The following example
illustrates the rules of this paragraph
(a)(2)(ii):
Example. Student A, a medical doctor, takes a
course at University X’s medical school. Student A
takes the course to fulfill State Y’s licensing require-
ment that medical doctors attend continuing medical
education courses each year. Student A is not en-
rolled in a degree program at University X and takes
the medical course through University X’s continu-
ing professional education division. University X
does not award Student A credit toward a post-sec-
ondary degree on an academic transcript for the
completion of the course but gives Student A a cer-
tificate of attendance upon completion. Under this
paragraph (a)(2)(ii), University X is not subject to
the information reporting requirements of section
6050S and this section for the medical education
course taken by Student A.

July 3, 20001042000–27 I.R.B.
(b) Requirement to file return—(1)
Form of return. Except as otherwise pro-
vided in this section, an institution or in-
surer must file an information return for
each individual with respect to whom
payments of qualified tuition and related
expenses are received, or reimbursements
or refunds of such amounts are made, dur-
ing the calendar year on Form 1098-T,
“Tuition Payments Statement.” An insti-
tution or insurer may use a substitute for
Form 1098-T if the substitute form com-
plies with applicable revenue procedures
relating to substitute forms.
(2) Information included on return—(i)
In general. An institution or insurer must
include on Form 1098-T—
(A) The name, address, and taxpayer
identification number (TIN)(as defined in
section 7701(a)(41)) of the institution or
the insurer;
(B) The name, address, and TIN of the
individual with respect to whom pay-
ments of qualified tuition and related ex-
penses were received, or reimbursements
or refunds of such amounts were made;
(C) The aggregate amount of payments
of qualified tuition and related expenses
from any source that the institution re-
ceived with respect to the individual dur-
ing the calendar year;
(D) The aggregate amount of reim-
bursements or refunds of qualified tuition
and related expenses that the institution or
insurer made with respect to the individ-
ual during the calendar year;
(E) The aggregate amount of any schol-
arships or grants that the institution
processed during the calendar year for the
payment of the individual’s costs of atten-
dance;
(F) An indication by the institution
whether the individual was enrolled for at
least half of the normal full-time work
load for the course of study the individual
is pursuing for at least one academic pe-
riod that begins during the calendar year
(see §1.25A–3(d)(1)(ii));
(G) An indication by the institution
whether the individual was enrolled in a
program leading to a graduate-level de-
gree, graduate-level certificate, or other
recognized graduate-level educational
credential; and
(H) Any other information required by
Form 1098-T and its instructions.
(ii) Requirement to include name, ad-
dress, and TIN of any taxpayer who will
claim the individual as a dependent on the
taxpayer’s Federal income tax return.
[Reserved]
(3) Time and place for filing return—
(i) In general. Except as provided in
paragraphs (b)(3)(ii) and (iii) of this sec-
tion, Form 1098-T must be filed on or be-
fore February 28 (March 31 if filed elec-
tronically) of the year following the
calendar year in which payments of quali-
fied tuition or related expenses were re-
ceived, or reimbursements or refunds of
such amounts were made. An institution
or insurer must file Form 1098-T with the
IRS according to the instructions to Form
1098-T.
(ii) Return for nonresident alien indi-
vidual. In general, an institution or in-
surer is not required to file a return on be-
half of a nonresident alien individual.
However, if a nonresident alien individual
requests an institution or insurer to report,
the institution or insurer must file a return
described in paragraph (b)(2) of this sec-
tion with the IRS on or before the date
prescribed in paragraph (b)(3)(i) of this
section, or on or before the thirtieth day
after the request, whichever is later.
(iii) Extensions of time. The IRS may
grant an institution or insurer an extension
of time to file returns required in this sec-
tion upon a showing of good cause. See
the instructions to Form 1098-T and ap-
plicable revenue procedures for rules re-
lating to extensions of time to file.
(4) Use of magnetic media. See section
6011(e) and §301.6011–2 of this chapter
for rules relating to the requirement to file
Forms 1098-T on magnetic media.
(c) Requirement to furnish statement—
(1) In general. An institution or insurer
must furnish a statement to each individ-
ual for whom it is required to file a Form
1098-T. The statement must include—
(i) The information required under
paragraph (b)(2) of this section;
(ii) A legend that identifies the state-
ment as important tax information that is
being furnished to the IRS;
(iii) Instructions that—
(A) State that the taxpayer may not be
able to claim an education tax credit
under section 25A and the regulations
thereunder with respect to the total pay-
ments of qualified tuition and related ex-
penses reported for the calendar year;
(B) State that the amount of any schol-
arships, grants, refunds, or reimburse-
ments reported for the calendar year and
other similar amounts not reported (be-
cause they are not processed by the insti-
tution) may reduce the amount of any al-
lowable education tax credit for the
taxable year or a prior taxable year;
(C) State that the taxpayer should refer
to relevant IRS forms and publications for
explanations relating to the eligibility re-
quirements for, and calculation of, any al-
lowable education tax credit; and
(D) Include the name, address, and
phone number of the individual who is the
information contact for the institution or
insurer that filed the Form 1098-T.
(2) Statement furnished to any taxpayer
who will claim the individual as a depen-
dent on the taxpayer’s Federal income tax
return. [Reserved]
(3) Time and manner for furnishing
statement—(i) In general. Except as pro-
vided in paragraphs (c)(3)(ii) and (iii) of
this section, an institution or insurer must
furnish the statement described in para-
graph (c)(1) of this section to each indi-
vidual with respect to whom payments of
qualified tuition and related expenses
were received, or reimbursements or re-
funds were made, on or before January 31
of the year following the calendar year in
which payments were received or reim-
bursements or refunds were made. If
mailed, the statement must be sent to the
individual’s permanent address, or the in-
dividual’s temporary address if the insti-
tution or insurer does not know the indi-
vidual’s permanent address.
(ii) Statement to nonresident alien indi-
vidual. If an information return is filed
for a nonresident alien individual, the in-
stitution or insurer must furnish a state-
ment described in paragraph (c)(1) of this
section to the individual in the manner
and on or before the date prescribed in
paragraph (c)(3)(i) of this section, or on
or before the thirtieth day after the non-
resident alien’s request to report,
whichever is later.
(iii) Extensions of time. The IRS may
grant an institution or insurer an extension
of time to furnish the statements required
in this section upon a showing of good
cause. See the instructions to Form 1098-
T and applicable revenue procedures for
rules relating to extensions of time to fur-
nish statements.
(4) Time and manner for furnishing
statement to any taxpayer who will claim

2000–27 I.R.B.105July 3, 2000
the individual as a dependent on the tax-
payer’s Federal income tax return. [Re-
served]
(5) Copy of Form 1098-T. An institu-
tion or insurer may satisfy the require-
ment of this paragraph (c) by furnishing
either a copy of Form 1098-T and its in-
structions or another document that con-
tains all of the information filed with the
IRS and the information required by para-
graph (c)(1) of this section if the docu-
ment complies with applicable revenue
procedures relating to substitute state-
ments.
(d) Special rules—(1) Payments re-
ceived for qualified tuition and related ex-
penses determined—(i) In general. In de-
termining the aggregate amount of
payments of qualified tuition and related
expenses that an institution must report,
payments received with respect to an indi-
vidual during the calendar year from any
source (except for any scholarship or
grant that, by its terms, must be applied to
expenses other than qualified tuition and
related expenses, such as room and board)
will be treated as payments of qualified
tuition and related expenses up to the total
amount billed by the institution for such
expenses.
(ii) Example. The following example
illustrates the rules of this paragraph
(d)(1):
Example. (i) During the 2002 Spring semester,
Student C attends College X and enrolls in a pro-
gram leading toward an associate’s degree. Student
C lives on-campus. In December 2001, College X
charges Student C $2,000 for room and board for the
2002 Spring semester. In addition, in December
2001, College X charges Student C $4,000 for quali-
fied tuition and related expenses for the 2002 Spring
semester. In December 2001, Student C pays Col-
lege X $1,500. In early January 2002, College X re-
ceives and processes a $4,500 scholarship that may
be applied to any of Student C’s costs of attendance.
Assume that there are no other payments during the
calendar years 2001 and 2002.
(ii) Under this paragraph (d)(1), for the calendar
year 2001, College X must report $1,500 for pay-
ments of qualified tuition and related expenses re-
ceived during the calendar year 2001. In addition,
for the calendar year 2002, College X must report:
(A) $2,500 for payments of qualified tuition and
related expenses received during the calendar year
2002 ($4,000 total charges for qualified tuition and
related expenses less the $1,500 payments received
during 2001); and
(B) $4,500 of scholarships processed during the
calendar year 2002.
(2) Payments of qualified tuition and
related expenses received or collected on
behalf of an institution—(i) In general. If
an institution contracts with another per-
son to receive or collect payments of
qualified tuition and related expenses on
its behalf, the other person must satisfy
the information reporting requirements of
this section.
(ii) Exception. If the institution does
not provide the other person with the in-
formation necessary to comply with the
reporting requirements of this section, the
other person must request the information
necessary to comply with the information
reporting requirements from the institu-
tion. If the institution does not provide
the other person with the necessary infor-
mation upon request, the institution must
satisfy the information reporting require-
ments of this section.
(3) Governmental units. An institution
or insurer that is a governmental unit, or
an agency or instrumentality of a govern-
mental unit, is subject to the information
reporting requirements of this section and
an appropriately designated officer or em-
ployee of the governmental entity must
satisfy the information reporting require-
ments of this section.
(e) Penalty provisions—(1) Failure to
file correct returns. The section 6721
penalty may apply to an institution or in-
surer that fails to file information returns
required by section 6050S and this section
on or before the required filing date; that
fails to include all of the required infor-
mation on the return; or that includes in-
correct information on the return. See
section 6721, and the regulations thereun-
der, for rules relating to penalties for fail-
ure to file correct returns. See section
6724, and the regulations thereunder, for
rules relating to waivers of penalties for
certain failures due to reasonable cause.
(2) Failure to furnish correct informa-
tion statements. The section 6722 penalty
may apply to an institution or insurer that
fails to furnish statements required by
section 6050S and this section on or be-
fore the prescribed date; that fails to in-
clude all the required information on the
statement; or that includes incorrect infor-
mation on the statement. See section
6722, and the regulations thereunder, for
rules relating to penalties for failure to
furnish correct statements. See section
6724, and the regulations thereunder, for
rules relating to waivers of penalties for
certain failures due to reasonable cause.
(3) Waiver of penalties for failures to
include a correct TIN—(i) In general. In
the case of a failure to include a correct
TIN on Form 1098-T or a related infor-
mation statement, penalties may be
waived if the failure is due to reasonable
cause. Reasonable cause may be estab-
lished if the failure arose from events be-
yond the institution’s or insurer’s control,
such as a failure of the individual to fur-
nish a correct TIN. However, the institu-
tion or insurer must establish that it acted
in a responsible manner both before and
after the failure.
(ii) Acting in a responsible manner. An
institution or insurer must request the TIN
of each individual with respect to whom
payments of qualified tuition were re-
ceived, or reimbursements or refunds
were made, if it does not already have a
record of the individual’s correct TIN. If
the institution or insurer does not have a
record of the individual’s correct TIN,
then it must solicit the TIN in the manner
described in paragraph (e)(3)(iii) of this
section on or before December 31 of each
year during which it receives payments
of, or makes reimbursements of, qualified
tuition and related expenses with respect
to the individual. If an individual refuses
to provide his or her TIN upon request,
the institution or insurer must file the re-
turn and furnish the statement required by
this section without the individual’s TIN,
but with all other required information.
The specific solicitation requirements of
paragraph (e)(3)(iii) of this section apply
in lieu of the solicitation requirements of
§301.6724–1(e) and (f) of this chapter for
the purpose of determining whether an in-
stitution or insurer acted in a responsible
manner in attempting to obtain a correct
TIN. An institution or insurer that com-
plies with the requirements of this para-
graph (e)(3) will be considered to have
acted in a responsible manner within the
meaning of §301.6724–1(d) of this chap-
ter with respect to any failure to include
the correct TIN of an individual on a re-
turn or statement required by section
6050S and this section.
(iii) Manner of soliciting TIN. An insti-
tution or insurer must request the individ-
ual’s TIN in writing and must clearly no-
tify the individual that the law requires
the individual to furnish a TIN so that it
may be included on an information return
filed by the institution or insurer. An in-
stitution or insurer must notify the indi-
vidual that the individual’s failure to fur-

July 3, 20001062000–27 I.R.B.
nish his or her TIN to the institution or in-
surer may result in a $50 penalty being
imposed against the individual as autho-
rized by law. A request for a TIN made on
Form W-9S, “Request for Student’s or
Borrower’s Social Security Number and
Certification,” satisfies the requirements
of this paragraph (e)(3)(iii). An institu-
tion or insurer may establish a system for
individuals to submit Forms W-9S elec-
tronically as described in applicable
forms and instructions. An institution or
insurer may also develop a separate form
to request the individual’s TIN or incor-
porate the request into other forms cus-
tomarily used by the institution or insurer,
such as financial aid applications.
(4) Requirement to request and obtain
TIN of any taxpayer who will claim the in-
dividual as a dependent on the taxpayer’s
Federal income tax return. [Reserved]
(5) Failure to furnish TIN. The section
6723 penalty may apply to any individual
who is required (but fails) to furnish his or
her TIN to an institution or insurer. See
section 6723, and the regulations thereun-
der, for rules relating to the penalty for
failure to furnish a TIN.
(f) Effective date. The rules in this sec-
tion apply to information returns required
to be filed, and information statements re-
quired to be furnished, after December
31, 2001.
§1.6050S–2 Information reporting for
payments of interest on qualified educa-
tion loans.
(a) Information reporting requirement—
(1) In general. Except as otherwise pro-
vided in this section, any person engaged in
a trade or business that, in the course of that
trade or business, receives from any payor
(as defined in paragraph (b)(2) of this sec-
tion) interest payments that aggregate $600
or more for any calendar year on one or
more qualified education loans (as defined
in section 221(e)(1) and §1.221–1(f)(3))(a
payee) must—
(i) File an information return, as de-
scribed in paragraph (c) of this section,
with the IRS with respect to the payor;
and
(ii) Furnish a statement, as described in
paragraph (d) of this section, to the payor.
(2) Reporting period—(i) In general.
The information reporting requirements
of this section apply only to interest pay-
ments received on a qualified education
loan during the first 60 months in which
interest payments are required on the
loan.
(ii) Calculation of 60-month period. In
general, the 60-month period described in
paragraph (a)(2)(i) of this section begins
on the date the qualified education loan
first enters repayment status and ends 60
months later. However, if the payee
knows, or has reason to know, of any peri-
ods of deferment or forbearance during
which the 60-month period is suspended
under the rules described in
§1.221–1(e)(3), the 60-month period de-
scribed in paragraph (a)(2)(i) of this sec-
tion is extended by the period of such de-
ferment or forbearance. The date on
which the qualified education loan first
enters repayment status is determined
under the terms of the loan agreement or,
in the case of a loan issued or guaranteed
under a federal post-secondary education
loan program, under applicable federal
regulations. For purposes of reporting
under section 6050S and this section for
refinanced loans and consolidated and
collapsed loans, the rules of
§1.221–1(h)(1), relating to the date on
which the 60-month period begins, apply.
(iii) Transitional rules for reporting on
loans made before January 1, 1998. For
qualified education loans made before
January 1, 1998, the 60-month period de-
scribed in paragraph (a)(2)(i) of this sec-
tion is determined in accordance with the
rules of paragraph (a)(2)(ii) of this sec-
tion, except that if the payee does not
know, and does not have reason to know,
the date on which the loan entered repay-
ment status, then, for reporting purposes
only, the 60-month period begins on Janu-
ary 1, 1998. For defaulted loans made be-
fore January 1, 1998, if the payee does not
know, and does not have reason to know,
the date on which the loan entered repay-
ment status, then, for reporting purposes
only, the 60-month period begins on the
earlier of the date the loan went into de-
fault or January 1, 1998. If the payee
does not know, and does not have reason
to know, either the date the loan entered
repayment status or the default date, then,
for reporting purposes only, the 60-month
period begins on January 1, 1998. For
purposes of this paragraph (a)(2)(iii), a
defaulted loan is a loan with respect to
which required payments of interest and
principal have not been made when due
over a period of time such that the holder
has declared the loan in default based on
its terms and conditions, and, if applica-
ble, has sought recourse against the ulti-
mate guarantor of the loan.
(b) Definitions. The following defini-
tions apply for purposes of this section:
(1) Interestincludes stated interest,
loan origination fees (other than fees for
services), and capitalized interest as de-
scribed in §1.221–1(h)(2). See paragraph
(e)(1) of this section for a special transi-
tional rule relating to reporting of loan
origination fees and capitalized interest.
(2) Payormeans the individual who is
carried on the books and records of the
payee as the borrower on a qualified edu-
cation loan. If there are multiple borrow-
ers, the principal borrower on the payee’s
books and records is treated as the payor
for purposes of section 6050S and this
section.
(c) Requirement to file return—(1)
Form of return. A payee must file an in-
formation return for the payor on Form
1098-E, “Student Loan Interest State-
ment.” A payee may use a substitute for
Form 1098-E if the substitute form com-
plies with the applicable revenue proce-
dures relating to substitute forms.
(2) Information included on return. A
payee must include on Form 1098-E—
(i) The name, address, and taxpayer
identification number (TIN)(as defined in
section 7701(a)(41)) of the payee;
(ii) The name, address, and TIN of the
payor;
(iii) The aggregate amount of interest
payments received during the calendar
year from the payor; and
(iv) Any other information required by
Form 1098-E and its instructions.
(3) Time and place for filing return—
(i) In general. Except as provided in
paragraph (c)(3)(ii) of this section, the
Form 1098-E must be filed on or before
February 28 (March 31 if filed electroni-
cally) of the year following the calendar
year in which interest payments were re-
ceived. A payee must file Form 1098-E
with the IRS according to the instructions
to Form 1098-E.
(ii) Extensions of time. The IRS may
grant a payee an extension of time to file
returns required in this section upon a
showing of good cause. See the instruc-
tions to Form 1098-E and applicable rev-
enue procedures for rules relating to ex-
tensions of time to file.

2000–27 I.R.B.107July 3, 2000
(4) Use of magnetic media. See section
6011(e) and §301.6011–2 of this chapter
for rules relating to the requirement to file
Forms 1098-E on magnetic media.
(d) Requirement to furnish statement—
(1) In general. A payee must furnish a
statement to each payor for whom it is re-
quired to file a Form 1098-E. The state-
ment must include—
(i) The information required under
paragraph (c)(2) of this section;
(ii) A legend that identifies the state-
ment as important tax information that is
being furnished to the IRS;
(iii) Instructions that—
(A) State that, under section 221 and
the regulations thereunder, the payor may
not be able to deduct the full amount of
interest reported on the statement;
(B) State that interest payments are de-
ductible only during the first 60 months
that interest payments are required;
(C) In the case of qualified education
loans made before January 1, 2002, for
which the payee does not report payments
of interest other than stated interest, state
that the payor may be able to deduct addi-
tional amounts (such as certain loan origi-
nation fees and capitalized interest) not
reported on the statement;
(D) State that the payor should refer to
relevant IRS forms and publications for
explanations relating to the eligibility re-
quirements for, and calculation of, any al-
lowable deduction for interest paid on a
qualified education loan; and
(E) Include the name, address, and
phone number of the individual who is the
information contact for the payee that
filed the Form 1098-E.
(2) Time and manner for furnishing
statement—(i) In general. Except as pro-
vided in paragraph (d)(2)(ii) of this sec-
tion, a payee must furnish the statement
described in paragraph (d)(1) of this sec-
tion to the payor on or before January 31
of the year following the calendar year in
which payments of interest on a qualified
education loan were received. If mailed,
the statement must be sent to the payor’s
last known address.
(ii) Extensions of time. The IRS may
grant a payee an extension of time to fur-
nish statements required in this section
upon a showing of good cause. See the in-
structions to Form 1098-E and applicable
revenue procedures for rules relating to
extensions of time to furnish statements.
(3) Copy of Form 1098-E. A payee
may satisfy the requirement of this para-
graph (d) by furnishing either a copy of
Form 1098-E and its instructions or an-
other document that contains all the infor-
mation filed with the IRS and the infor-
mation required by paragraph (d)(1) of
this section if the document complies with
applicable revenue procedures relating to
substitute statements.
(e) Special rules—(1) Transitional rule
for reporting of loan origination fees and
capitalized interest. For qualified educa-
tion loans made before January 1, 2002, a
payee is not required to report payments
of loan origination fees and capitalized in-
terest as interest under section 6050S and
this section.
(2) Qualified education loan certifica-
tion. If a loan is not subsidized, guaran-
teed, financed, or is not otherwise treated
as a student loan under a program of the
Federal, state, or local government or an
eligible educational institution, a payee
must request a certification from the
payor that the loan will be used solely to
pay for qualified higher education ex-
penses. A payee may use Form W-9S,
“Request for Student’s or Borrower’s So-
cial Security Number and Certification,”
to obtain the certification. A payee may
establish an electronic system for payors
to submit Forms W-9S electronically as
described in applicable forms and instruc-
tions. A payee may also develop a sepa-
rate form to obtain the payor certification
or may incorporate certification into other
forms customarily used by the payee,
such as loan applications, provided the
certification is clearly set forth. If the cer-
tification is not received, the loan is not a
qualified education loan for purposes of
section 6050S and this section.
(3) Payments of interest received or
collected by one or more persons—(i) In
general. If a payee contracts with another
person to receive or collect payments on a
qualified education loan on its behalf, the
other person must satisfy the information
reporting requirements of this section.
(ii) Exception. If the payee does not
provide the other person with information
necessary to comply with the information
reporting requirements of this section, the
other person must request the information
necessary to comply with the information
reporting requirements from the payee. If
the payee does not provide the other per-
son with the necessary information upon
request, the payee must satisfy the infor-
mation reporting requirements of this sec-
tion.
(4) Reporting by foreign persons. A
payee that is not a United States person
(as defined in section 7701(a)(30)) must
report payments of interest it receives on
a qualified education loan only if it re-
ceives the payment—
(i) At a location in the United States; or
(ii) At a location outside the United
States if the payee is–
(A) A controlled foreign corporation
(within the meaning of section 957(a)); or
(B) A person 50 percent or more of the
gross income of which, from all sources
for the three-year period ending with the
close of the taxable year preceding the
taxable year in which interest payments
were received (or for such part of the pe-
riod as the person was in existence), was
effectively connected with the conduct of
a trade or business within the United
States.
(5) Governmental units. A governmen-
tal unit, or an agency or instrumentality of
a governmental unit, that receives from
any payor interest payments that aggre-
gate $600 or more for any calendar year
on one or more qualified education loans
is a payee, without regard to the require-
ment of paragraph (a)(1) of this section
that the interest be received in the course
of a trade or business.
(f) Penalty provisions—(1) Failure to
file correct returns. The section 6721
penalty may apply to a payee that fails to
file information returns required by sec-
tion 6050S and this section on or before
the required filing date; that fails to in-
clude all of the required information on
the return; or that includes incorrect infor-
mation on the return. See section 6721,
and the regulations thereunder, for rules
relating to penalties for failure to file cor-
rect returns. See section 6724, and the
regulations thereunder, for rules relating
to waivers of penalties for certain failures
due to reasonable cause.
(2) Failure to furnish correct informa-
tion statements. The section 6722 penalty
may apply to a payee that fails to furnish
statements required by section 6050S and
this section on or before the prescribed
date; that fails to include all the required
information on the statement; or that in-
cludes incorrect information on the state-

July 3, 20001082000–27 I.R.B.
ment. See section 6722, and the regula-
tions thereunder, for rules relating to
penalties for failure to furnish correct
statements. See section 6724, and the
regulations thereunder, for rules relating
to waivers of penalties for certain failures
due to reasonable cause.
(3) Waiver of penalties for failures to
include a correct TIN—(i) In general. In
the case of a failure to include a correct
TIN on Form 1098-E or a related infor-
mation statement, penalties may be
waived if the failure is due to reasonable
cause. Reasonable cause may be estab-
lished if the failure arose from events be-
yond the payee’s control, such as a failure
of the payor to furnish a correct TIN.
However, the payee must establish that it
acted in a responsible manner both before
and after the failure.
(ii) Acting in a responsible manner. A
payee must request the TIN of each payor
if it does not already have a record of the
payor’s correct TIN. If the payee does not
have a record of the payor’s correct TIN,
then it must solicit the TIN in the manner
described in paragraph (f)(3)(iii) of this
section on or before December 31 of each
year during which it receives payments of
interest. If a payor refuses to provide his
or her TIN upon request, the payee must
file the return and furnish the statement
required by this section without the
payor’s TIN, but with all other required
information. The specific solicitation re-
quirements of paragraph (f)(3)(iii) of this
section apply in lieu of the solicitation re-
quirements of §301.6724–1(e) and (f) of
this chapter for the purpose of determin-
ing whether a payee acted in a responsible
manner in attempting to obtain a correct
TIN. A payee that complies with the re-
quirements of this paragraph (f)(3) will be
considered to have acted in a responsible
manner within the meaning of
§301.6724–1(d) of this chapter with re-
spect to any failure to include the correct
TIN of a payor on a return or statement
required by section 6050S and this sec-
tion.
(iii) Manner of soliciting TIN. A payee
must request the payor’s TIN in writing
and must clearly notify the payor that the
law requires the payor to furnish a TIN so
that it may be included on an information
return filed by the payee. A payee must
notify the payor that the payor’s failure to
furnish his or her TIN to the payee may
result in a $50 penalty being imposed
against the individual as authorized by
law. A request for a TIN made on Form
W-9S, “Request for Student’s or Bor-
rower’s Social Security Number and Cer-
tification,” satisfies the requirements of
this paragraph (f)(3)(iii). A payee may es-
tablish a system for payors to submit
Forms W-9S electronically as described
in applicable forms and instructions. A
payee may also develop a separate form
to request the payor’s TIN or incorporate
the request into other forms customarily
used by the payee, such as loan applica-
tions.
(4) Failure to furnish TIN. The section
6723 penalty may apply to any payor who
is required (but fails) to furnish his or her
TIN to a payee. See section 6723, and the
regulations thereunder, for rules relating
to the penalty for failure to furnish a TIN.
(g) Effective date. The rules in this sec-
tion apply to information returns required
to be filed, and information statements re-
quired to be furnished, after December
31, 2001.
PART 301—PROCEDURE AND
ADMINISTRATION
Par. 3. The authority citation for part
301 continues to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 4. Section 301.6011–2 is amended
by:
1. Revising the first sentence of para-
graph (b)(1).
2. Revising paragraph (g)(1).
3. Adding paragraph (g)(3).
The revisions and additions read as fol-
lows:
§301.6011–2 Required use of magnetic
media.
* * * * *
(b) Returns required on magnetic
media. (1) If the use of Form 1042-S,
1098 series, 1099 series, 5498, 8027,
W-2G, or other form treated as a form
specified in this paragraph (b)(1) is re-
quired by the applicable regulations or
revenue procedures for the purpose of
making an information return, the infor-
mation required by the form must be sub-
mitted on magnetic media, except as oth-
erwise provided in paragraph (c) of this
section. * * *
* * * * *
(g) Effective dates. (1) Except as other-
wise provided in paragraph (g)(2) or
(g)(3) of this section, this section applies
to returns required to be filed after De-
cember 31, 1986.
* * * * *
(3) This section applies to returns on
Forms 1098-T and 1098-E required to be
filed after December 31, 2001.
Robert E. Wenzel,
Deputy Commissioner
of Internal Revenue.
(Filed by the office of the Federal Register on June
15, 2000, 8:45 a.m., and published in the issue of the
Federal Register for June 16, 2000, 65 F.R. 37728)

2000–27 I.R.B.iJuly 3, 2000
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 A but not
to B, and the new ruling holds that it ap-
plies to both A and 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. A ruling
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 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.
Definition of Terms

July 3, 2000ii2000–27 I.R.B.
Numerical Finding List
1
Bulletins 2000–1 through 2000–26
Announcements:
2000–1, 2000–2 I.R.B. 294
2000–2, 2000–2 I.R.B. 295
2000–3, 2000–2 I.R.B. 296
2000–4, 2000–3 I.R.B. 317
2000–5, 2000–4 I.R.B. 427
2000–6, 2000–4 I.R.B. 428
2000–7, 2000–6 I.R.B. 586
2000–8, 2000–6 I.R.B. 586
2000–9, 2000–9 I.R.B. 733
2000–10, 2000–9 I.R.B. 733
2000–11, 2000–10 I.R.B. 739
2000–12, 2000–12 I.R.B. 835
2000–13, 2000–11 I.R.B. 771
2000–14, 2000–11 I.R.B. 772
2000–15, 2000–12 I.R.B. 837
2000–16, 2000–12 I.R.B. 837
2000–17, 2000–13 I.R.B. 846
2000–18, 2000–13 I.R.B. 846
2000–19, 2000–19 I.R.B. 973
2000–20, 2000–19 I.R.B. 977
2000–21, 2000–19 I.R.B. 983
2000–22, 2000–19 I.R.B. 987
2000–23, 2000–19 I.R.B. 992
2000–24, 2000–14 I.R.B. 855
2000–25, 2000–14 I.R.B. 855
2000–26, 2000–15 I.R.B. 876
2000–27, 2000–15 I.R.B. 876
2000–28, 2000–15 I.R.B. 876
2000–29, 2000–15 I.R.B. 877
2000–30, 2000–15 I.R.B. 877
2000–31, 2000–15 I.R.B. 877
2000–32, 2000–15 I.R.B. 878
2000–33, 2000–15 I.R.B. 878
2000–34, 2000–15 I.R.B. 879
2000–35, 2000–16 I.R.B. 922
2000–36, 2000–16 I.R.B. 947
2000–37, 2000–16 I.R.B. 947
2000–38, 2000–16 I.R.B. 948
2000–39, 2000–16 I.R.B. 948
2000–40, 2000–16 I.R.B. 948
2000–41, 2000–16 I.R.B. 949
2000–42, 2000–16 I.R.B. 949
2000–43, 2000–17 I.R.B. 957
2000–44, 2000–17 I.R.B. 958
2000–45, 2000–18 I.R.B. 962
2000–46, 2000–19 I.R.B. 997
2000–47, 2000–21 I.R.B. 1118
2000–48, 2000–23 I.R.B. 1243
2000–49, 2000–19 I.R.B. 998
2000–50, 2000–19 I.R.B. 998
2000–51, 2000–22 I.R.B. 1141
2000–52, 2000–22 I.R.B. 1142
2000–53, 2000–22 I.R.B. 1144
2000–54, 2000–26 I.R.B. 1276
2000–55, 2000–25 I.R.B. 1268
2000–56, 2000–26 I.R.B. 1281
Court Decisions:
2066, 2000–15 I.R.B. 867
2067, 2000–15 I.R.B. 863
Notices:
2000–1, 2000–2 I.R.B. 288
2000–2, 2000–9 I.R.B. 727
Notices—continued:
2000–3, 2000–4 I.R.B. 413
2000–4, 2000–3 I.R.B. 313
2000–5, 2000–3 I.R.B. 314
2000–6, 2000–3 I.R.B. 315
2000–7, 2000–4 I.R.B. 419
2000–8, 2000–4 I.R.B. 420
2000–9, 2000–5 I.R.B. 449
2000–10, 2000–5 I.R.B. 451
2000–11, 2000–6 I.R.B. 572
2000–12, 2000–9 I.R.B. 727
2000–13, 2000–9 I.R.B. 732
2000–14, 2000–10 I.R.B. 737
2000–15, 2000–12 I.R.B. 826
2000–16, 2000–12 I.R.B. 826
2000–17, 2000–12 I.R.B. 827
2000–18, 2000–13 I.R.B. 845
2000–19, 2000–13 I.R.B. 845
2000–20, 2000–14 I.R.B. 851
2000–21, 2000–19 I.R.B. 967
2000–22, 2000–16 I.R.B. 902
2000–23, 2000–17 I.R.B. 952
2000–24, 2000–17 I.R.B. 952
2000–25, 2000–17 I.R.B. 954
2000–26, 2000–17 I.R.B. 954
2000–27, 2000–21 I.R.B. 1116
2000–28, 2000–21 I.R.B. 1116
2000–29, 2000–23 I.R.B. 1241
2000–30, 2000–25 I.R.B. 1266
2000–31, 2000–26 I.R.B. 1274
2000–32, 2000–26 I.R.B. 1274
Proposed Regulations:
REG–208280–86, 2000–8 I.R.B. 654
REG–209135–88, 2000–8 I.R.B. 681
REG–208254–90, 2000–6 I.R.B. 577
REG–209601–92, 2000–12 I.R.B. 829
REG–100276–97, 2000–8 I.R.B. 682
REG–101492–98, 2000–3 I.R.B. 326
REG–106012–98, 2000–2 I.R.B. 290
REG–106186–98, 2000–23 I.R.B. 1226
REG–107644–98, 2000–23 I.R.B. 1229
REG–109101–98, 2000–16 I.R.B. 903
REG–110311–98, 2000–11 I.R.B. 767
REG–122450–98, 2000–8 I.R.B. 682
REG–103831–99, 2000–5 I.R.B. 452
REG–103882–99, 2000–8 I.R.B. 706
REG–105089–99, 2000–6 I.R.B. 580
REG–105279–99, 2000–8 I.R.B. 707
REG–105606–99, 2000–4 I.R.B. 421
REG–107872–99, 2000–16 I.R.B. 911
REG–111119–99, 2000–5 I.R.B. 455
REG–113572–99, 2000–7 I.R.B. 624
REG–116048–99, 2000–6 I.R.B. 584
REG–116567–99, 2000–5 I.R.B. 463
REG–116704–99, 2000–3 I.R.B. 325
REG–117162–99, 2000–15 I.R.B. 871
REG–100163–00, 2000–7 I.R.B. 633
REG–100291–00, 2000–16 I.R.B. 917
REG–103735–00, 2000–11 I.R.B. 770
REG–103736–00, 2000–11 I.R.B. 768
Railroad Retirement Quarterly Rate:
2000–9 I.R.B. 721
Revenue Procedures:
2000–1, 2000–1 I.R.B. 4
2000–2, 2000–1 I.R.B. 73
2000–3, 2000–1 I.R.B. 103
Revenue Procedures—continued:
2000–4, 2000–1 I.R.B. 115
2000–5, 2000–1 I.R.B. 158
2000–6, 2000–1 I.R.B. 187
2000–7, 2000–1 I.R.B. 227
2000–8, 2000–1 I.R.B. 230
2000–9, 2000–2 I.R.B. 280
2000–10, 2000–2 I.R.B. 287
2000–11, 2000–3 I.R.B. 309
2000–12, 2000–4 I.R.B. 387
2000–13, 2000–6 I.R.B. 515
2000–14, 2000–18 I.R.B. 960
2000–15, 2000–5 I.R.B. 447
2000–16, 2000–6 I.R.B. 518
2000–17, 2000–11 I.R.B. 766
2000–18, 2000–9 I.R.B. 722
2000–19, 2000–12 I.R.B. 785
2000–20, 2000–6 I.R.B. 553
2000–21, 2000–19 I.R.B. 971
2000–22, 2000–20 I.R.B. 1008
2000–23, 2000–21 I.R.B. 1018
2000–24, 2000–22 I.R.B. 1133
2000–25, 2000–21 I.R.B. 1033
2000–26, 2000–24 I.R.B. 1257
2000–27, 2000–26 I.R.B. 1272
Revenue Rulings:
2000–1, 2000–2 I.R.B. 250
2000–2, 2000–3 I.R.B. 305
2000–3, 2000–3 I.R.B. 297
2000–4, 2000–4 I.R.B. 331
2000–5, 2000–5 I.R.B. 436
2000–6, 2000–6 I.R.B. 512
2000–7, 2000–9 I.R.B. 712
2000–8, 2000–7 I.R.B. 617
2000–9, 2000–6 I.R.B. 497
2000–10, 2000–8 I.R.B. 643
2000–11, 2000–10 I.R.B. 734
2000–12, 2000–11 I.R.B. 744
2000–13, 2000–12 I.R.B. 774
2000–14, 2000–12 I.R.B. 779
2000–15, 2000–12 I.R.B. 774
2000–16, 2000–12 I.R.B. 780
2000–17, 2000–13 I.R.B. 842
2000–18, 2000–14 I.R.B. 847
2000–19, 2000–14 I.R.B. 849
2000–20, 2000–16 I.R.B. 880
2000–21, 2000–16 I.R.B. 881
2000–22, 2000–16 I.R.B. 880
2000–23, 2000–19 I.R.B. 964
2000–24, 2000–19 I.R.B. 963
2000–25, 2000–20 I.R.B. 1006
2000–26, 2000–22 I.R.B. 1124
2000–27, 2000–21 I.R.B. 1016
2000–28, 2000–23 I.R.B. 1157
2000–29, 2000–24 I.R.B. 1249
2000–30, 2000–25 I.R.B. 1262
2000–31, 2000–26 I.R.B. 1269
Tax Conventions:
2000–22 I.R.B. 1126
Treasury Decisions:
8849, 2000–2 I.R.B. 245
8850, 2000–2 I.R.B. 265
8851, 2000–2 I.R.B. 275
8852, 2000–2 I.R.B.253
8853, 2000–4 I.R.B.377
8854, 2000–3 I.R.B.306
1
A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 1999–27 through
1999–52 is in Internal Revenue Bulletin 2000–1,
dated January 3, 2000.

2000–27 I.R.B.iiiJuly 3, 2000
Treasury Decisions—continued:
8855, 2000–4 I.R.B.374
8856, 2000–3 I.R.B.298
8857, 2000–4 I.R.B.365
8858, 2000–4 I.R.B.332
8859, 2000–5 I.R.B.429
8860, 2000–5 I.R.B.437
8861, 2000–5 I.R.B.441
8862, 2000–6 I.R.B.466
8863, 2000–6 I.R.B.488
8864, 2000–7 I.R.B.614
8865, 2000–7 I.R.B.589
8866, 2000–6 I.R.B.495
8867, 2000–7 I.R.B.620
8868, 2000–6 I.R.B.491
8869, 2000–6 I.R.B.498
8870, 2000–8 I.R.B.647
8871, 2000–8 I.R.B.641
8872, 2000–8 I.R.B.639
8873, 2000–9 I.R.B.713
8874, 2000–8 I.R.B.644
8875, 2000–11 I.R.B.761
8876, 2000–11 I.R.B.753
8877, 2000–11 I.R.B.747
8878, 2000–15 I.R.B.857
8879, 2000–16 I.R.B.882
8880, 2000–20 I.R.B.1003
8881, 2000–23 I.R.B.1158
8882, 2000–23 I.R.B.1150
8883, 2000–23 I.R.B.1151
8884, 2000–24 I.R.B.1250
8885, 2000–25 I.R.B.1260
8887, 2000–26 I.R.B.1269

July 3, 2000iv2000–27 I.R.B.
Finding List of Current Actions on
Previously Published Items
1
Bulletins 2000–1 through 2000–26
Announcements:
99–40
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
99–50
Modified by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
99–59
Superseded by
Announcement 2000–47, 2000–21 I.R.B. 1118
2000–18
Corrected by
Announcement 2000–32, 2000–15 I.R.B. 878
Notices:
88–125
Obsoleted by
T.D. 8870, 2000–8 I.R.B. 647
92–48
Obsoleted by
Notice 2000–11, 2000–6 I.R.B. 572
97–15
Obsoleted by
T.D.8887, 2000–26 I.R.B. 1269
97–19
Modified by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
98–22
Obsoleted by
T.D. 8870, 2000–8 I.R.B. 647
98–49
Modified by
Notice 2000–30, 2000–25 I.R.B. 1266
98–52
Modified by
Notice 2000–3, 2000–4 I.R.B. 413
98–61
Modified and superseded by
Rev. Proc. 2000–15, 2000–5 I.R.B. 447
99–5
Modified by
Notice 2000–32, 2000–26 I.R.B. 1274
99–8
Obsoleted by
Rev. Proc. 2000–12, 2000–4 I.R.B. 387
2000–4
Corrected by
Announcement 2000–9, 2000–9 I.R.B. 733
Proposed Regulations:
REG–209601–92
Corrected by
Announcement 2000–40, 2000–16 I.R.B. 948
REG–100276–97
Corrected by
Announcement 2000–38, 2000–16 I.R.B. 948
Proposed Regulations—Continued:
REG–101492–98
Corrected by
Announcement 2000–16, 2000–12 I.R.B. 837
REG–122450–98
Corrected by
Announcement 2000–38, 2000–16 I.R.B. 948
REG–113572–99
Corrected by
Announcement 2000–41, 2000–16 I.R.B. 949
REG–103736–00
Corrected by
Announcement 2000–44, 2000–17 I.R.B. 958
Revenue Procedures:
80–18
Modified by
Rev. Proc. 2000–13, 2000–6 I.R.B. 515
89–9
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
89–13
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
90–21
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
91–66
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
92–13
Modified, amplified, and superseded by
Rev. Proc. 2000–11, 2000–3 I.R.B. 309
92–13A
Modified, amplified, and superseded by
Rev. Proc. 2000–11, 2000–3 I.R.B. 309
92–41
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
93–9
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
93–10
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
94–12
Modified, amplified, and superseded by
Rev. Proc. 2000–11, 2000–3 I.R.B. 309
95–42
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
96–13
Modified by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
98–14
Modified by
Rev. Proc. 2000–27, 2000–26 I.R.B. 1272
98–22
Modified and superseded by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
Revenue Procedures—Continued:
98–27
Superseded by
Rev. Proc. 2000–12, 2000–4 I.R.B. 387
98–64
Superseded by
Rev. Proc. 2000–9, 2000–2 I.R.B. 280
98–65
Superseded by
Rev. Proc. 2000–19, 2000–12 I.R.B. 785
99–1
Superseded by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
99–2
Superseded by
Rev. Proc. 2000–2, 2000–1 I.R.B. 73
99–3
Superseded by
Rev. Proc. 2000–3, 2000–1 I.R.B. 103
99–4
Superseded by
Rev. Proc. 2000–4, 2000–1 I.R.B. 115
99–5
Superseded by
Rev. Proc. 2000–5, 2000–1 I.R.B. 158
99–6
Superseded by
Rev. Proc. 2000–6, 2000–1 I.R.B. 187
99–7
Superseded by
Rev. Proc. 2000–7, 2000–1 I.R.B. 227
99–8
Superseded by
Rev. Proc. 2000–8, 2000–1 I.R.B. 230
99–13
Modified and superseded by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
99–20
Supplemented by
Rev. Proc. 2000–14, 2000–18 I.R.B. 960
99–22
Obsoleted by
(except as provided in section 5.02 of)
Rev. Proc. 2000–21, 2000–19 I.R.B. 971
99–23
Modified by
Rev. Proc. 2000–27, 2000–26 I.R.B. 1272
99–24
Superseded by
Rev. Proc. 2000–23, 2000–21 I.R.B. 1018
99–25
Superseded by
Rev. Proc. 2000–24, 2000–22 I.R.B. 1133
99–29
Superseded by
Rev. Proc. 2000–25, 2000–21 I.R.B. 1033
99–31
Modified and superseded by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
1
A cumulative list of current actions on previously
published items in Internal Revenue Bulletins
1999–27 through 1999–52 is in Internal Revenue
Bulletin 2000–1, dated January 3, 2000.

2000–27 I.R.B.vJuly 3, 2000
Revenue Procedures—Continued:
99–49
Modified and amplified by
Rev. Rul. 2000–4, 2000–4 I.R.B. 331
Rev. Rul. 2000–7, 2000–9 I.R.B. 712
Notice 2000–4, 2000–3 I.R.B. 313
99–51
Superseded by
Rev. Proc. 2000–3, 2000–1 I.R.B. 103
2000–6
Modified by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
2000–8
Modified by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
2000–12
Corrected by
Announcement 2000–50, 2000–19 I.R.B. 998
2000–16
Corrected by
Announcement 2000–17, 2000–13 I.R.B. 846
2000–20
Modified by
Rev. Proc. 2000–27, 2000–26 I.R.B. 1272
Revenue Rulings:
54–396
Obsoleted by
T.D. 8885, 2000–25 I.R.B. 1260
57–259
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
57–499
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
73–292
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
76–79
Distinguised by
Rev. Rul. 2000–24, 2000–19 I.R.B. 963
78–218
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
80–76
Obsoleted by
T.D. 8883, 2000–23 I.R.B. 1151
86–62
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
88–36
Modified by
Rev. Rul. 2000–6, 2000–6 I.R.B. 512
89–89
Obsoleted by
Rev. Rul. 2000–2, 2000–3 I.R.B. 305
92–19
Supplemented by
Rev. Rul. 2000–17, 2000–13 I.R.B. 842
98–30
Amplified and superseded by
Rev. Rul. 2000–8, 2000–7 I.R.B. 617
Treasury Decisions:
8734
Modified by
T.D. 8856, 2000–3 I.R.B. 298
Treasury Decisions—continued:
8804
Modified by
T.D. 8856, 2000–3 I.R.B. 298
8845
Corrected by
Announcement 2000–6, 2000–4 I.R.B. 428
8846
Corrected by
Announcement 2000–3, 2000–2 I.R.B. 296
8847
Corrected by
Announcement 2000–13, 2000–11 I.R.B. 771
8849
Corrected by
Announcement 2000–28, 2000–15 I.R.B. 876
8852
Corrected by
Announcement 2000–18, 2000–13 I.R.B. 846
8853
Corrected by
Announcement 2000–33, 2000–15 I.R.B. 878
8856
Corrected by
Announcement 2000–31, 2000–15 I.R.B. 877
8859
Corrected by
Announcement 2000–27, 2000–15 I.R.B. 876
8864
Corrected by
Announcement 2000–26, 2000–15 I.R.B. 876
8865
Corrected by
Announcement 2000–37, 2000–16 I.R.B. 947
8867
Corrected by
Announcement 2000–30, 2000–15 I.R.B. 877
8869
Corrected by
Announcement 2000–36, 2000–16 I.R.B. 947
8870
Corrected by
Announcement 2000–34, 2000–15 I.R.B. 879
8874
Corrected by
Announcement 2000–29, 2000–15 I.R.B. 877
8879
Corrected by
Announcement 2000–53, 2000–22 I.R.B. 1144

July 3, 2000vi2000–27 I.R.B.
Index
Internal Revenue Bulletins
2000–1 Through 2000–26
The abbreviation and number in paren-
thesis following the index entry refer to
the specific item; numbers in roman and
italic type following the parenthesis refer
to the Internal Revenue Bulletin in which
the item may be found and the page
number on which it appears.
Key to Abbreviations:
AnnAnnouncement
CDCourt Decision
DODelegation Order
EOExecutive Order
PLPublic Law
PTEProhibited Transaction
Exemption
RPRevenue Procedure
RRRevenue Ruling
SPRStatement of Procedural
Rules
TCTax Convention
TDTreasury Decision
TDOTreasury Department Order
EMPLOYEE PLANS
Advance letter rulings and determination
letters, areas which will not be issued
from:
Associate Chief Counsel, Domestic
(RP 3) 1, 103
Associate Chief Counsel,
International (RP 7) 1, 227
Cafeteria plans, treatment of (TD 8878)
15, 857; (REG–117162–99) 15, 871
Cash or deferred arrangements:
Nondiscrimination (Notice 3) 4, 413
Nonqualified deferred compensation
(RR 8) 7, 617
Separation from service, transferred
employees (RR 27) 21,1016
Determination letters:
Issuing procedures (RP 6) 1, 187
Remedial amendment GUST (RP 27)
26,1272
Eligible rollover distributions:
Hardship distributions, recordkeeping
requirements (Notice 32) 26,
1274
Safe harbor explanations (Notice 11)
6, 572
EPCRS, closing agreements (RP 16) 6,518;
correction (Ann 17) 13,846
Full funding limitations, weighted aver-
age interest rate for:
January (Notice 8) 4, 420
February (Notice 2) 9,727
March (Notice 18) 13, 845
April (Notice 25) 17, 954
May (Notice 27) 21,1116
June (Notice 31) 26,1274
Letter rulings, determination letters and
information letters issued by Associate
Chief Counsel (RP 1) 1, 4
Letter rulings, information letters, etc.
(RP 4) 1, 115
Master and prototype plans, unified pro-
cedures (RP 20) 6, 553
Minimum funding standards:
Amortization bases (RR 20) 16, 880
Waiver of the 100 percent tax (RP 17)
11, 766
Mortality tables (Ann 7) 6, 586
New comparability plans, nondiscrimina-
tion (Notice 14) 10, 737
New technologies in retirement plans,
distribution notices and consents (TD
8873) 9, 713
Proposed Regulations:
26 CFR 1.125–1, amended; 1.125–2,
amended; 1.125–4, amended; tax
treatment of cafeteria plans
(REG–117162–99) 15, 871
26 CFR 1.411(d)–4, amended; special
rules regarding optional forms of
benefit under qualified retirement
plans (REG–109101–98) 16, 903
Qualified retirement plans:
Eligible rollover distributions, relief
from disqualification of (TD 8880)
20, 1003
Optional forms of benefit
(REG–109101–98) 16, 903
Remedial amendment period (TD
8871) 8, 641
Regulations:
26 CFR 1.125–4, added; 1.125–4T,
amended; tax treatment of cafeteria
plans (TD 8878) 15, 857
26 CFR 1.401(a)(31)–1, amended;
1.402(c)–2, amended; 1.403(b)–2,
amended; relief from disqualifica-
tion for plans accepting rollovers
(TD 8880) 20, 1003
26 CFR 1.401(b)–1T, removed; reme-
dial amendment period (TD 8871)
8, 641
26 CFR 1.402(f)–1, amended;
1.411(a)–11, amended; new tech-
nologies in retirement plans (TD
8873) 9,713
Reporting requirements, section 457
plans (Ann 1) 2, 294
Technical advice to district directors and
chiefs, appeals offices, from Associate
Chief Counsel (RP 2) 1, 73
Technical advice to IRS employees (RP
5) 1, 158
User fees, request for letter rulings (RP
8) 1, 230
EMPLOYMENT TAX
Electronic filing; magnetic media:
Form 1040NR (RP 24) 22, 1133
Information reporting seminars for
2000 (Ann 47) 21, 1118
Publication 1220, Specifications for
Filing Forms 1098, 1099, 5498, and
W-2G, Magnetically or
Electronically (RP 25) 21, 1033
Electronically filed information returns,
due dates (REG–105279–99) 8, 707
EmTrac program requirements, food and
beverage industry (Notice 21) 19, 967
EPCRS, closing agreements (RP 16) 6,
518; correction (Ann 17) 13, 846
Forms:
Electronic filing; magnetic media:
1040 NR (RP 24) 22, 1133
1098, 1099, 5498, and W-2G, speci-
fications for filing forms electroni-
cally or magnetically (RP 25) 21,
1033
W-2 and W-3, specifications for private
printing of paper substitutes (RP 23)
21, 1018
Information reporting, election workers
(RR 6) 6,512
New technologies in retirement plans,
distribution notices and consents (TD
8873) 9, 713
Proposed Regulations:
26 CFR 31.3402(q)–1, revised;
31.6053–3, revised; 31.6071(a)–1,
revised; extension of due date for
electronically filed information
returns (REG–105279–99) 8, 707
Publication 1220, Specifications for
Filing Forms 1098, 1099, 5498, and
W-2G, Magnetically or Electronically
(RP 25) 21, 1033
EMPLOYEE PLANS—
cont.
EMPLOYEE PLANS—
cont.

2000–27 I.R.B.viiJuly 3, 2000
Qualified retirements plans, eligible
rollover distributions, relief from dis-
qualification of (TD 8880) 20, 1003
Railroad retirement:
Rate determination (January 2000) 9,
721
Regulations:
26 CFR 31.3405(c)–1, amended; relief
from disqualification for plans
accepting rollovers (TD 8880) 20,
1003
26 CFR 35.3405–1, redesignated as
35.3405–1T, revised; 35.3405–1,
added; new technologies in retire-
ment plans (TD 8873) 9, 713
Substitute for Forms W-2 and W-3, for
private printing and general rules and
specifications (RP 23) 21, 1018
Tips:
Tip rate determination agreement
(TRDA):
Food and beverage industry (Ann
23) 19,992
Generic agreement (Ann 20) 19, 977
Tip reporting alternative commitment
(TRAC) agreement:
Cosmetology and barber industry
(Ann 21) 19,983
Food and beverage industry (Ann
22) 19,987
Generic agreement (Ann 19) 19,
973
ESTATE TAX
Guaranteed annuity interests and unitrust
interests (REG–100291–00) 16, 917
Interest rates; special use value of farm
real property (RR 26) 22, 1124
Marital / charitable deduction, valuation
of property; administration expenses
(Ann 3) 2, 296
Proposed Regulations:
26 CFR 1.170A–6, amended;
20.2055–2, amended; 25.2522(c)–3,
amended; guaranteed annuity inter-
ests and unitrust interests
(REG–100291–00) 16, 917
QTIP elections, individual retirement
accounts and testamentary trusts (RR
2) 3, 305
Valuation tables (Ann 25) 14, 855
EXCISE TAX
Coal exports, nontaxable sale (Notice 28)
21, 1116
Gasoline and diesel fuel dye injection
systems, partial withdrawal of
REG–209735–95 (Ann 42) 16, 949
Imported substances, tax on (Ann 43) 17,
957
Kerosene tax; aviation fuel tax; taxable
fuel measurement and reporting; tax
on heavy trucks and trailers; highway
use tax (TD 8879) 16,882; correction
(Ann 53) 22,1144
Minimum funding standards, waiver of
(RP 17) 11, 766
Prepaid telephone cards (TD 8855) 4, 374
Regulations:
26 CFR 40.0–1, amended; 40.0–1T,
removed; 40.6011(a)–1, added;
40.6011(a)–1T, removed;
40.6302(c)–1, amended;
40.6302(c)–1T, –2T, removed;
40.6302(c)–2, added; safe harbor
deposit rule (TD 8887) 26, 1269
26 CFR 40.6011(a)–1, amended;
41.0–1, revised; 41.02–2, –3,
removed; 41.4481–1T, 41.4481–1,
–2, amended; 41.4481–1T, removed;
41.4482(a)–1, amended;
41.4482(b)–1, amended;
41.4482(b)–1T, removed;
41.4482(c)–1, amended; 41.4483–1,
revised; 41.4483–2, –3, amended;
41.4483–5, removed; 41.4484–1,
removed; 41.6001–1, –2, amended;
41–6011(a)–1, revised;
41.6071(a)–1, amended;
41.6081(a)–1, removed; 41.6091–1,
revised; 41–6101–1, revised;
41.6109–1, revised; 41.6151(a)–1,
revised; 41.6161(a)(1)–1, removed;
41.6302(b)–1, removed; 41.7805–1,
removed; Part 47, removed; 48.0–2,
amended; 48.4041–21, amended;
48.4052–1, added; 48.4081–1,
amended; 48.4081–1T, removed;
48.4081–2, –3, –6, –7, –8, amended;
48.4081–9, removed; 48.4082–1,
amended; 48.4082–2, –3, revised;
48.4082–4, –5, amended;
48.4082–6, –7, added; 48.4082–6T,
–7T, –8T, –9T, –10T, removed;
48.4083–1, amended; 48.4091–3T,
redesignated as 48.4091–3, amend-
ed; 48.4101–3T, removed;
48.4101–1, –2, amended;
48.4102–2T, removed; 48.4221–1,
amended; 48.4222(b)–1, amended;
48.6416(b)(2)–1, –2, amended;
48.6420–7, removed; 48.6420(c)–2,
removed; 48.6421–2, amended;
48.6427–8, –9, amended;
48.6427–10, –11, added;
48.6427–10T, –11T, removed;
48.6715–1, amended; 145.4051–1,
amended; 145.4052–1, amended;
kerosene tax; aviation fuel tax; tax-
able fuel measurement and report-
ing; tax on heavy trucks and trailers;
highway use tax (TD 8879) 16, 882;
correction (Ann 53) 22,1144
26 CFR 49.4251–4, added; 602.101,
amended; prepaid telephone cards
(TD 8855) 4, 374
Return filing and deposits (Ann 5) 4,
427
Safe harbor deposit rule and floor stocks
taxes (TD 8887) 26,1269
EXEMPT
ORGANIZATIONS
Advance letter rulings and determination
letters, areas which will not be issued
from Associate Chief Counsel,
Domestic (RP 3) 1, 103
Charitable split dollar insurance, report-
ing requirements (Notice 24) 17, 952
Information letters available for public
inspection (Ann 2) 2, 295
Letter rulings, information letters, etc.
(RP 4) 1, 115
List of organizations classified as private
foundations (Ann 8) 6, 586; (Ann 52)
22,1142
Private foundation disclosure rules (TD
8861) 5, 441
Proposed Regulations:
26 CFR 1.170A–9(e)(6)(i), amended;
1.509(a)–3(f)(1), amended;
1.512(a)–1(e), amended; 1.513–4,
withdrawn; 1.513–4, added; taxation
of tax-exempt organizations’ income
from corporate sponsorship
(REG–209601–92) 12, 829; correc-
tion (Ann 40) 16, 948
Regulations:
26 CFR 1.513–7, added; travel and
EMPLOYMENT TAX—
cont.
EXCISE TAX—
cont.

July 3, 2000viii2000–27 I.R.B.
tour activities of tax-exempt organi-
zations (TD 8874) 8, 644; correction
(Ann 29) 15, 877
26 CFR 301.6104(d)–1, removed;
301.6104(d)–2, redesignated as
301.6104(d)–0, revised;
301.6104(d)–3, redesignated as
301.6104(d)–1, amended;
301.6104(d)–4, redesignated as
301.6104(d)–2, amended;
301.6104(d)–5, redesignated as
301.6104(d)–3, amended; private
foundation disclosure rules (TD
8861) 5, 441
Revocations:
(Ann 15) 12, 837
(Ann 39) 16, 948
(Ann 56) 26,1281
Sponsorship payments, taxation of
(REG–209601–92) 12, 829; correction
(Ann 40) 16, 948
Technical advice to district directors and
chiefs, appeals offices, from Associate
Chief Counsel (RP 2) 1, 73
Technical advice to IRS employees (RP
5) 1, 158
Travel tours, taxation of (TD 8874) 8,
644; correction (Ann 29) 15, 877
User fees, request for letter rulings (RP
8) 1, 230
GIFT TAX
Guaranteed annuity interests and unitrust
interests (REG–100291–00) 16, 917
Proposed Regulations:
26 CFR 1.170A–6, amended;
20.2055–2, amended; 25.2522(c)–3,
amended; guaranteed annuity inter-
ests and unitrust interests
(REG–100291–00) 16, 917
INCOME TAX
Accounting period change, automatic
consent (RP 11) 3, 309
Acquisitions, recognition of gain on dis-
tributions (Ann 10) 9, 733
Adequate disclosure of gifts (Ann 6) 4,
428
Advance letter rulings and determination
letters, areas which will not be issued
from:
Associate Chief Counsel, Domestic
(RP 3) 1, 103
Associate Chief Counsel, International
(RP 7) 1,227
Advance pricing agreements (Ann 35)
16, 922
Allocation of partnership debt, nonre-
course liabilities (REG–103831–99) 5,
452
Amortization of intangible property (TD
8865) 7, 589; correction (Ann 37) 16,947
Appeals, test of arbitration procedure
(Ann 4) 3, 317
Asset acquisitions, allocation of purchase
price (TD 8858) 4, 332
Automobile owners and lessees (RP 18)
9, 722
Barter exchanges, information reporting
(Notice 6) 3, 315
Business expenses:
ISO 9000 costs (RR 4) 4, 331
Substantiation (TD 8864) 7,614; cor-
rection (Ann 26) 15,876
Traveling expenses, per diem
allowances (RP 9) 2, 280
Canadian banking legislation, repeal,
deferral of termination (Notice 7) 4,
419
Closely-held real estate investment trust,
estimated tax payments, penalty relief
(Notice 5) 3, 314
Consolidated returns, limitations on the
use of certain credits (TD 8884) 24,
1250
Contribution in aid of construction, defi-
nition (REG–106012–98) 2, 290
Corporations, disposition of stock in a
taxable transactions (TD 8883) 23,
1151
Credits:
Low-income housing credit:
Compliance monitoring (TD 8859)
5, 429; correction (Ann 27) 15,
876
Resident population estimates
(Notice 13) 9, 732
Satisfactory bond; “bond factor”
amounts for the period:
January through March 2000
(RR 22) 16, 880
April through June 2000 (RR
31) 26, 1269
Puerto Rico and possession tax credit,
termination of (TD 8868) 6, 491
Research credit, controlled group
(REG–105606–99) 4, 421
Debt instrument (RR 12) 11, 744
Depletion, treatment of delay rental
(REG–103882–99) 8, 706
Depreciation:
MACRS property, involuntary conver-
sion or like-kind exchange (Notice
4) 3, 313; correction (Ann 9) 9, 733
Determination of underwriting income,
non-life insurance companies (TD
8857) 4, 365
Disclosure of return information, Census
of Agriculture (TD 8854) 3,306;
(REG–116704–99) 3, 325
Electronic filing; magnetic media:
Form 1040NR (RP 24) 22, 1133
Information reporting seminars for
2000 (Ann 47) 21, 1118
Publication 1220, Specifications for
Filing Forms 1098, 1099, 5498, and
W-2G, Magnetically or
Electronically (RP 25) 21, 1033
Electronically filed information returns,
due dates of (REG–105279–99) 8, 707
Equity options with flexible terms, special
rules and definitions (TD 8866) 6, 495
Estimated taxes:
Closely-held real estate investment
trust, penalty relief (Notice 5) 3,
314
Date deemed paid (CD 2066) 15, 867
Filing requirements:
Northeastern taxpayers, due dates
(Notice 17) 12, 827
Financial asset securitization investment
trusts, general (REG–100276–97;
REG–122450–98) 8, 682; correction
(Ann 38) 16, 948
Foreign corporations:
Exclusion of shipping income
(REG–208280–86) 8, 654; correc-
tion (Ann 45) 18,962
Information reporting (TD 8850) 2,265
Stock transfer rules:
General provisions (TD 8862) 6, 466
Nonrecognition (TD 8863) 6, 488;
(REG–116048–99) 6, 584
Foreign currency:
Gains and losses, qualified business
units (Notice 20) 14, 851
Hyperinflation; definition
(REG–116567–99) 5, 463; (TD
8860) 5, 437
EXEMPT ORGANIZA-
TIONS—cont.
INCOME TAX—
cont.
INCOME TAX—
cont.

2000–27 I.R.B.ixJuly 3, 2000
Foreign partnerships:
Information reporting (TD 8850) 2,
265
U.S. persons with reportable event,
reporting requirement (TD 8851) 2,
275
Foreign persons, distributions to (Ann
24) 14, 855
Forms:
1040NR, electronic filing, magnetic
media (RP 24) 22, 1133
1042-S, proposed revisions
(Ann 54) 26, 1276
1098, 1099, 5498, and W-2G, specifi-
cations for filing forms magnetically
or electronically (RP 25) 21, 1033
1099-R and 5498, procedures for
reporting recharacterizations and
reconversions (Notice 30) 25, 1266
SS-4, interim waiver of signature
(Notice 19) 13,845
Fringe benefits:
Aircraft valuation (RR 13) 12, 774
Qualified transportation
(REG–113572–99) 7,624; correc-
tion (Ann 41) 16,949
Guaranteed annuity interests and unitrust
interests, definition of (REG–100291–
00) 16, 917
Guidance priority list (Notice 10) 5, 451
Individual retirement arrangements,
reporting recharacterizations and
reconversions (Notice 30) 25, 1266
Information letters available for public
inspection (Ann 2) 2, 295
Information reporting:
Barter exchange (Notice 6) 3, 315
Discharges of indebtedness, penalties
for (Notice 22) 16, 902
Foreign partnerships and foreign cor-
porations (TD 8850) 2, 265
Innocent spouse, equitable relief (RP 15)
5, 447
Installment agreements, limitation of fail-
ure to pay penalty (REG–105279–99)
8, 707
Installment sales (Notice 26) 17, 954
Insurance companies:
Differential earnings rate, tentative
(Notice 16) 12, 826
Prevailing state assumed interest
rates (RR 17) 13, 842
Interest:
Investment:
Federal short-term, mid-term, and
long-term rates for:
January 2000 (RR 1) 2, 250
February 2000 (RR 9) 6,497
March 2000 (RR 11) 10, 734
April 2000 (RR 19) 14, 849
May 2000 (RR 23) 19, 964
June 2000(RR 28) 23,1157
Rates:
Underpayments and overpayments,
quarter beginning:
April 1, 2000 (RR 16) 12, 780
July 1, 2000 (RR 30) 25,1262
Interest netting on tax payments (RP 26)
24, 1257
International operation of ships and/or
aircraft, Kingdom of Saudi
Arabia, 22, 1126
Inventory:
Dollar-value LIFO and inventory price
index computation (IPIC) methods
(REG–107644–98) 23, 1229
LIFO:
Price indexes, department stores:
November 1999 (RR 3) 3, 297
December 1999 (RR 10) 8,643
January 2000 (RR 14) 12,779
February 2000 (RR 21) 16, 881
March 2000 (RR 25) 20,1006
April 2000 (RR 29) 24, 1249
Last known address, definition of (Ann
49) 19, 998
Letter rulings, determination letters and
information letters issued by Associate
Chief Counsel (RP 1) 1, 4
Major disaster and emergency areas,
losses (RR 15 ) 12, 774
Medical conference expenses, deductibil-
ity of (RR 24) 19, 963
Methods of accounting; inventories,
small taxpayers (RP 22) 20, 1008
Mortgage credit certificates, median
income figures (RP 21) 19, 971
Nonconventional source fuel credit,
inflation adjustment factor and refer-
ence price (Notice 23) 17, 952
Nonqualified preferred stock, exchanges
and distributions (REG–105089–99) 6,
580
Office of Tax Shelter Analysis:
Address and phone number (Ann 55)
25, 1268
Newly established office (Ann 12) 12,
835
Partnerships:
Adjustments following sales (Ann 13)
11, 771
Allocation of basis adjustments among
partnership assets
(REG–107872–99) 16, 911
Allocation of nonrecourse liabilities
(REG–103831–99) 5,452
Amortization of intangible property
(REG–100163–00) 7, 633
Basis adjustments, residual method,
valuation of partnership assets
including goodwill
(REG–107872–99) 16, 911
Disposition of stock in a taxable trans-
action (TD 8883) 23, 1151
Mergers and divisions
(REG–111119–99) 5, 455
Options and convertible instruments
(Notice 29) 23, 1241
Qualified replacement property, trans-
fer to (RR 18) 14, 847
Passive foreign investment companies:
Marketable stock (TD 8867) 7, 620;
correction (Ann 30) 15,877
Qualified electing fund (TD 8870) 8,
647; correction (Ann 34) 15, 879
Practice before the Internal Revenue
Service, governing regulations (Ann
51) 22, 1141
Pre-filing agreement pilot program
(Notice 12) 9, 727
Presidentially declared disaster and com-
bat zone, relief (REG–101492–98) 3,
326; correction (Ann 16) 12, 837
Private foundations:
Disclosure rules (TD 8861) 5, 441
Organizations now classified as (Ann
8) 6, 586; (Ann 52) 22, 1142
Proposed Regulations:
26 CFR 1.41–0, amended; 1.41–8,
revised; credit for increasing
research activities
(REG–105606–99) 4, 421
26 CFR 1.118–2, added; contribution
in aid of construction, definition
(REG–106012–98) 2, 290
26 CFR 1.132–0, amended; 1.132–9,
added; qualified transportation
fringe benefits (REG–113572–99) 7,
624; correction (Ann 41) 16, 949
26 CFR 1.170A–6, amended;
20.2055–2, amended; 25.2522(c)–3,
amended; lifetime charitable lead
INCOME TAX—
cont.
INCOME TAX—
cont.
INCOME TAX—
cont.

July 3, 2000x2000–27 I.R.B.
trusts (REG–100291–00) 16, 917
26 CFR 1.197–2, amended; amortiza-
tion of intangible property
(REG–100163–00) 7, 633
26 CFR 1.337(d)–5T, added,
1.852–12, added; 1.857–11, added;
certain asset transfers to regulated
investment companies and real
estate investment trusts
(REG–209135–88) 8, 681
26 CFR 1.354–1, amended; 1.355–1,
amended; 1.356–7, added;
1.1036–1, amended; treatment of
nonqualified perferred stock and
other preferred stock in certain
exchanges and distributions
(REG–105089–99) 6, 580
26 CFR 1.367(b)–3, amended; stock
transfer rules (REG–116048–99) 6, 584
26 CFR 1.368–2, amended; certain
corporate reorganizations involving
disregarded entities
(REG–106186–98) 23, 1226
26 CFR 1.472–8, amended; dollar-
value LIFO regulations, inventory
price index computation method
(REG–107644–98) 23, 1229
26 CFR 1.612–3, amended; depletion,
treatment of delay rental
(REG–103882–99) 8, 706
26 CFR 1.708–1, amended; 1.743–1,
amended; treatment of partnership
mergers and divisions
(REG–111119–99) 5, 455
26 CFR 1.752–3, amended; 1.752–5,
revised; allocation of nonrecourse
liabilities by a partnership
(REG–103831–99) 5, 452
26 CFR 1.755–2, added; 1.755–2T,
removed; allocation of basis adjust-
ments among partnership assets
(REG–107872–99) 16, 911
26 CFR 1.860E–1, amended;
1.860H–0, –1, –2, –3, –4, –5, –6,
added; 1.860I–1, –2, added;
1.860J–1, added; 1.860L–1, –2, –3,
–4, added; 1.861–9T, amended;
1.861–10T, amended; financial asset
securitization investment trusts; real
estate mortgage investment conduits
(REG–100276–97;
REG–122450–98) 8, 682; correction
(Ann 38) 16,948
26 CFR 1.861–4, amended; source of
compensation for labor or personal
services (REG–208254–90) 6, 577
26 CFR 1.883–0, added; 1.883–1,
revised; 1.883–2, –3, –4, –5, added;
exclusions from gross income of
foreign corporations
(REG–208280–86) 8, 654
26 CFR 1.988–1, revised; hyperinfla-
tionary currencies, definition
(REG–116567–99) 5, 463
26 CFR 1.6011–4, added; tax shelter
disclosure statements
(REG–103735–00) 11, 770
26 CFR 1.6041–2, revised; 1.6041–6,
revised; 1.6042–2, revised;
1.6043–2, revised; 1.6044–2,
revised; 1.6045–1, added; 1.6045–2,
revised; 1.6045–4, revised;
1.6047–1, revised; 1.6049–4,
revised; 1.6049–7, revised;
1.6050A–1, revised; 1.6050D–1,
revised; 1.6050E–1, revised;
1.6050H–2, revised; 1.6050J–1T,
revised; 1.6050P–1, revised;
1.6052–1, revised; 301.6651–1,
amended; extension of due date for
electronically filed information
returns; limitation of failure to pay
penalty for individuals during peri-
od of installment agreement
(REG–105279–99) 8, 707
26 CFR 301.6103(j)(5)–1, added; dis-
closure of return information;
Census of Agriculture
(REG–116704–99) 3, 325
26 CFR 301.6111–2, added; corporate
tax shelter registration
(REG–110311–98) 11, 767
26 CFR 301.6112–1, amended;
requirements to maintain list of
investors in potentially abusive tax
shelters (REG–103736–00) 11, 768;
correction (Ann 44) 17, 958
26 CFR 301.7508–1, added;
301.7508A–1, added; relief for ser-
vice in combat zone and for
Presidentially declared disaster
(REG–101492–98) 3, 326; correc-
tion (Ann 16) 12, 837
Publications:
515, changes to Tables 1 and 2 (Ann
11) 10, 739
1167, substitute forms, general
requirements (RP 19) 12, 785
1212, supplemental information (Ann
14) 11, 772
1220, Specifications for Filing Forms
1098, 1099, 5498, and W-2G,
Magnetically or Electronically (RP
25) 21, 1033
Circular 230 (Ann 51) 22,1141
Qualified intermediary withholding
agreements (RP 12) 4, 387; correction
(Ann 50) 19, 998
Qualified mortgage bond, median income
figures (RP 21) 19, 971
Qualified Zone Academy Bonds (RP 10)
2, 287
Real estate investment trusts, asset trans-
fers to (TD 8872) 8, 639;
(REG–209135–88) 8, 681
Real estate mortgage investment con-
duits, safe harbor (REG–100276–97;
REG–122450–98) 8, 682; correction
(Ann 38) 16,948
Recharacterizing financing arrangements,
fast-pay stock (TD 8853) 4, 377; cor-
rection (Ann 33) 15, 878
Regulated investment companies, asset
transfers to (TD 8872) 8, 639;
(REG–209135–88) 8, 681
Regulations:
26 CFR 1.42–5, –6, amended; 1.42
–11, –12, –13, amended; 1.42–17,
added; compliance monitoring and
miscellaneous issues relating to the
low-income housing credit (TD
8859) 5, 429
26 CFR 1.62–2, amended; 1.62–2T,
removed; 1.274–5, added;
1.274–5T, amended; substantiation
of business expenses (TD 8864) 7,
614; correction (Ann 26) 15, 876
26 CFR 1.83–6, amended; 1.1032–2,
amended; 1.1032–3, added;
1.1502–13, amended; disposition of
stock in taxable transaction (TD
8883) 23, 1151
26 CFR 1.162–11, amended;
1.167(a)–3, amended; 1.167(a)–6,
amended; 1.167(a)–14, added;
1.197–0, added; 1.197–2, added;
amortization of goodwill and certain
other intangibles (TD 8865) 7, 589;
correction (Ann 37) 16, 947
26 CFR 1.337(d)–5, added, certain
asset transfers to regulated invest-
ment companies and real estate
INCOME TAX—
cont.
INCOME TAX—
cont.
INCOME TAX—
cont.

2000–27 I.R.B.xiJuly 3, 2000
investment trusts (TD 8872) 8,
639
26 CFR 1.338–0, –1, –2, –3, removed;
1.338–4, redesignated as 1.338–8;
1.338–5, redesignated as 1.338–9;
1.338–4T, –5T, –6T, –7T, –10T,
added; 1.338(b)–1, added;
1.338(b)–2T, –3T, removed;
1.338(h)(10)–1, removed;
1.338(i)–1, removed; 1.338(i)–1T,
added; 1.1060–1T, revised; purchase
price allocations in deemed and
actual asset acquisitions (TD 8858)
4, 332
26 CFR 1.354–1, amended; 1.355–1,
amended; 1.356–3, amended;
1.356–6T, redesignated as 1.356–6;
reorganizations, nonqualified pre-
ferred stock (TD 8882) 23, 1150
26 CFR 1.367(a)–3, amended;
1.367(b)–0, added; 1.367(b)–1, –2,
revised; 1.367(b)–3, added;
1.367(b)–4, revised; 1.367(b)–5, –6,
added; 1.367(b)–7, –8, –9, removed;
1.381(b)–1, amended; 7.367(b)–1,
–2, –3, –4, –5, –6, –7, –8, –9, –10,
–11, removed; 7.367(b)–12, amend-
ed; 7.367(b)–13, removed; stock
transfers rules (TD 8862) 6, 466
26 CFR 1.367(b)–3T, added; stock
transfer rules, (TD 8863) 6, 488
26 CFR 1.367(e)–1, –2, corrected;
treatment of distributions to foreign
persons (Ann 24) 14, 855
26 CFR 1.368–2, amended; solely for
voting stock requirement in certain
corporate reorganizations (TD 8885)
25, 1260
26 CFR 1.401(b)–1, amended;
1.401(b)–1T, removed; remedial
amendment period (TD 8871) 8, 641
26 CFR 1.663(a)–1, amended;
1.663(c)–1, amended; 1.663(c)–2,
revised; 1.663(c)–3, amended;
1.663(c)–4, redesignated as
1.663(c)–5, amended; 1.663(c)–4,
added; 1.663(c)–6, added; separate
shares rule applicable to estates (TD
8849) 2, 245; correction (Ann 28)
15,876
26 CFR 1.664–2, corrected; use of
actuarial tables in valuing annuities,
interests for life or term of years,
and remainder or reversionary inter-
ests (Ann 25) 14, 855
26 CFR 1.743–1, 1.754–1, 1.755–1,
corrected; adjustments following
sales of partnership interests (Ann
13) 11, 771
26 CFR 1.871–14, revised; 1.1441–1,
–4, –5, –6, –8, –9, revised;
1.1443–1, revised; 1.6042–3,
revised; 1.6045–1, revised;
1.6049–5, revised; withholding of
tax on certain U.S. source income
paid to foreign persons; delay of
effective date (TD 8856) 3, 298;
correction (Ann 31) 15, 877
26 CFR 1.883–0, added; 1.883–1,
revised; 1.883–2, –3, –4, –5, added;
exclusions from gross income of
foreign corporations
(REG–208280–86) 8, 654; change
of date for public hearing (Ann 45)
18, 962
26 CFR 1.936–11T, removed;
1.936–11, added; termination of
Puerto Rico and possession tax
credit (TD 8868) 6, 491
26 CFR 1.988–0, amended; 1.988–2,
amended; treatment of income and
expenses from certain hyperinfla-
tionary currencies; nonperiodic pay-
ments (TD 8860) 5, 437
26 CFR 1.1092(c)–1, added; equity
options with flexible terms (TD
8866) 6, 495
26 CFR 1.1291–1T, redesignated as
1.1291–1, revised; 1.1293–1T,
redesignated as 1.1293–1, revised;
1.1295–0, amended; 1.1295–1T,
redesignated as 1.1295–1, amended;
1.1295–3T, redesignated as
1.1295–3, amended; general rules
for making and maintaining quali-
fied electing fund elections (TD
8870) 8, 647; correction (Ann 34)
15,879
26 CFR 1.1296(e)–1, added; passive
foreign investment companies, mar-
ketable stock (TD 8867) 7, 620; cor-
rection (Ann 30) 15,877
26 CFR 1.1361–0, –1; amended;
1.1361–2, –3, –4, –5, –6, added;
1.1362–0, amended; 1.1362–2,
amended; 1.1362–8, added;
1.1368–0, amended; 1.1368–2,
amended; 1.1374–8, amended;
301.6109–1, amended; subchapter S
subsidiaries (TD 8869) 6, 498; cor-
rection (Ann 36) 16,947
26 CFR 1.1366–0, –1, added;
1.1366–2, revised; 1.1366–3, –4, –5,
added; 1.1367–0, –1, amended;
1.1367–3, revised; 1.1368–0, –1, –2,
–3, amended; 1.1368–4, revised;
passthrough of items of an S corpo-
ration to its shareholders (TD 8852)
2, 253; correction (Ann 18) 13,846;
correction (Ann 32) 15,878
26 CFR 1.1441–0, –1, –2, –3, –4, –6,
–7, –9, amended; 1.1441–5, revised;
1.1461–1, amended; 1.6041–1, –4,
amended; 1.6041A–1, amended;
1.6042–3, amended; 1.6045–1,
amended; 1.6049–4, –5, amended;
U.S. source income paid to foreign
persons; reporting and recordkeeping
requirements (TD 8881) 23, 1158
26 CFR 1.1441–10, added; 1.7701(1)–0,
added; 1.7701(1)–3, added;
602.101(b), amended; recharacteriz-
ing financing arrangements involving
fast–pay stock (TD 8853) 4, 377; cor-
rection (Ann 33) 15,878
26 CFR 1.1502–3, –4, –9A, –21, –98,
amended; 1.1502–3T, -4T, -55T,
removed; 1.1502–55, added; consol-
idated returns, limitations on use of
certain credits (TD 8884) 24, 1250
26 CFR 1.6011–4T, added; tax shelter
disclosure statements (TD 8877) 11,
747
26 CFR 1.6038–3, added; 1.6038–2,
amended; 1.6038B–1, amended;
1.6038B–2, amended; information
reporting with respect to certain for-
eign partnerships and certain foreign
corporations (TD 8850) 2, 265
26 CFR 1.6046A–1, added; return
requirement for U.S. persons acquir-
ing or disposing of an interest in a
foreign partnership (TD 8851) 2,
275
26 CFR 301.6103(j)(5)–1T, added;
disclosure of return information;
Census of Agriculture (TD 8854) 3,
306
26 CFR 301.6104(d)–1, removed;
301.6104(d)–2, redesignated as
301.6104(d)–0, revised;
301.6104(d)–3, redesignated as
INCOME TAX—
cont.
INCOME TAX—
cont.
INCOME TAX—
cont.

July 3, 2000xii2000–27 I.R.B.
301.6104(d)–1, amended;
301.6104(d)–4, redesignated as
301.6104(d)–2, amended;
301.6104(d)–5, redesignated as
301.6104(d)–3, amended;
602.101(b), amended; private foun-
dation disclosure rules (TD 8861) 5,
441
26 CFR 301.6111–2T, added; corpo-
rate tax shelter registration (TD
8876) 11, 753
26 CFR 301.6112–1T, amended;
requirements to maintain list of
investors in potentially abusive tax
shelters (TD 8875) 11, 761
Removal costs, capital expenditures (RR
7) 9, 712
Reorganizations:
Divisive mergers, definition (RR 5) 5,
436
Mergers and disregarded entities
(REG–106186–98) 23, 1226
Nonqualified preferred stock (TD
8882) 23, 1150
Revocations, exempt organizations (Ann
15) 12, 837; (Ann 39) 16, 948; (Ann
56) 26, 1281
S corporations:
Passthrough items (TD 8852) 2, 253;
correction (Ann 18) 13,846; correc-
tion (Ann 32) 15,878
Subsidiaries (TD 8869) 6, 498; correc-
tion (Ann 36) 16,947
Section 911(d)(4) waiver; 1999 update
(RP 14) 18, 960
Separate shares rules (TD 8849) 2, 245;
correction (Ann 28) 15,876
Short-term Treasury bills (Ann 14) 11,
772
Solely for voting stock requirement:
Advance notice of final regulations
(Notice 1) 2, 288
Final regulations (TD 8885) 25,1260
Sources of income, compensation for
labor or services (REG–208254–90) 6,
577
Tax conventions:
New treaties with Estonia, Latvia,
Lithuania, Venezuela;
Publication 515 changes (Ann 11)
10, 739
Shipping and aircraft agreement,
Kingdom of Saudi Arabia, 22, 1126
Treaties with Austria, Ireland, South
Africa; Publication 515 changes (Ann
11) 10,739
United Kingdom; repeal of advance
corporation tax (RP 13) 6, 515
Tax liens, determination of property or
rights to property (CD 2067) 15, 863
Tax shelters:
Circular 230 (Ann 51) 22, 1141
Confidential corporate, registration
(TD 8876) 11, 753;
(REG–110311–98) 11,767
Disclosure statements (TD 8877) 11,
747; (REG–103735–00) 11, 770
Listed transactions (Notice 15) 12, 826
Office of Tax Shelter Analysis (Ann
12) 12,835
Potentially abusive, list of investors
(TD 8875) 11, 761;
(REG–103736–00) 11, 768; correc-
tion (Ann 44) 17,958
Technical advice to district directors and
chiefs, appeals office, from Associate
Chief Counsel (RP 2) 1, 73
Treasury bonds, call for redemption of
(Ann 46) 19, 997
Valuation tables (Ann 25) 14, 855
Variable annuity contracts, closing agree-
ments (Notice 9) 5, 449
Withholdings:
Date deemed paid (CD 2066) 15, 867
Qualified intermediary withholding
agreements:
Application procedures (RP 12) 4,
387
Guidance for financial institutions
(Ann 48) 23,1243
U.S. source income paid to foreign
persons:
Delay of effective date (TD 8856) 3,
298; correction (Ann 31) 15, 877
Reporting and recordkeeping
requirements (TD 8881) 23, 1158
INCOME TAX—
cont.
INCOME TAX—
cont.

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