Internal Revenue Bulletin 2003-10 (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.

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.
INCOME TAX
Rev. Rul. 2003–24, page 557.
Insurance companies; interest rate tables.Prevailing state
assumed interest rates are provided for the determination of re-
serves under section 807 of the Code for contracts issued in
2002 and 2003. Rev. Rul. 92–19 supplemented in part.
Rev. Rul. 2003–26, page 563.
Federal rates; adjusted federal rates; adjusted federal long-
term rate and the long-term exempt rate.For purposes of
sections 382, 1274, 1288, and other sections of the Code,
tables set forth the rates for March 2003.
T.D. 9039, page 561.
Final regulations under section 954 of the Code provide that gain
or loss arising from certain commodities hedging transactions
and currency gain or loss arising from certain interest-bearing
liabilities do not constitute (or are not netted against) foreign per-
sonal holding company income. This treatment is implemented
because the applicable commodities hedging transactions and
interest-bearing liabilities typically offset transactions that do not
generate foreign personal holding company income.
T.D. 9040, page 568.
Final regulations under sections 48, 152, 611, 852, 6011, and
6903 of the Code provide rules designed to eliminate regula-
tory impediments to the electronic filing of Form 1040,U.S. In-
dividual Income Tax Return.
Notice 2003–16, page 575.
Low-income housing tax credit; private activity bonds.Resi-
dent population figures of the various states are provided for pur-
poses of determining the 2003 calendar year (1) state housing
credit ceiling under section 42(h) of the Code, (2) private activ-
ity bond volume cap under section 146, and (3) private activity
bond volume limit under section 142(k)(5).
Rev. Proc. 2003–22, page 577.
Standard meal rates for family day care providers.This pro-
cedure provides optional standard meal and snack rates that fam-
ily day care providers may use in computing the deductible cost
of food provided to eligible children in the day care.
Announcement 2003–12, page 585.
This document changes the location of two public hearings on
proposed regulations (REG–103829–99 and REG–143321–
02) that relate to the definition of a highway vehicle for pur-
poses of various excise taxes and information reporting of taxable
stock transactions, respectively.
(Continued on the next page)
Bulletin No. 2003–10
March 10, 2003
Finding Lists begin on page ii.

EXCISE TAX
T.D. 9042, page 564.
REG–139768–02, page 583.
Temporary and proposed regulations, primarily under section
5891 of the Code, provide the manner and method of paying and
reporting the nondeductible 40-percent excise tax imposed on
any person who acquires structured settlement payment rights
in a structured settlement factoring transaction. A public hear-
ing on the proposed regulations is scheduled for June 12, 2003.
Announcement 2003–12, page 585.
This document changes the location of two public hearings on
proposed regulations (REG–103829–99 and REG–143321–
02) that relate to the definition of a highway vehicle for pur-
poses of various excise taxes and information reporting of taxable
stock transactions, respectively.
ADMINISTRATIVE
Announcement 2003–11, page 585.
This document contains corrections to temporary regulations (T.D.
9022, 2002–48 I.R.B. 909) under section 6043(c) that require
information reporting by a corporation if control of the corpora-
tion is acquired or if the corporation has a recapitalization or other
substantial change in capital structure.
March 10, 20032003–10 I.R.B.

The IRS Mission
Provide America’s taxpayers top quality service by helping them
understand and meet their tax responsibilities and by applying
the tax law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of the
Commissioner of Internal Revenue for announcing official rul-
ings and procedures of the Internal Revenue Service and for pub-
lishing Treasury Decisions, Executive Orders, Tax Conventions,
legislation, court decisions, and other items of general inter-
est. It is published weekly and may be obtained from the Super-
intendent 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 pub-
lished rulings apply retroactively unless otherwise indicated. Pro-
cedures relating solely to matters of internal management are
not published; however, statements of internal practices and pro-
cedures that affect the rights and duties of taxpayers are pub-
lished.
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 taxpay-
ers or technical advice to Service field offices, identifying de-
tails 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 re-
lied on, used, or cited as precedents by Service personnel in the
disposition of other cases. In applying published rulings and pro-
cedures, the effect of subsequent legislation, regulations, court
decisions, rulings, and procedures must be considered, and Ser-
vice personnel and others concerned are cautioned against reach-
ing the same conclusions in other cases unless the facts and
circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions of
the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A, Tax
Conventions and Other Related Items, and Subpart B, Legisla-
tion and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these sub-
jects are contained in the other Parts and Subparts. Also in-
cluded in this part are Bank Secrecy Act Administrative Rulings.
Bank Secrecy Act Administrative Rulings are issued by the De-
partment of the Treasury’s Office of the Assistant Secretary (En-
forcement).
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 semiannual pe-
riod, respectively.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402.
2003–10 I.R.B.March 10, 2003

Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
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 March 2003. See Rev. Rul. 2003–26, page 563.
Section 162.—Trade or Busi-
ness Expenses
Optional standard meal and snack rates are pro-
vided for use by taxpayers engaged in the trade or
business of providing family day care in computing
the deductible cost of food provided to eligible chil-
dren in the day care. See Rev. Proc. 2003–22, page
577.
Section 280G.—Golden Para-
chute Payments
Federal short-term, mid-term, and long-term rates
are set forth for the month of March 2003. See Rev.
Rul. 2003–26, page 563.
Section 382.—Limitation on
Net Operating Loss Carryfor-
wards and Certain Built-In
Losses Following Ownership
Change
The adjusted applicable federal long-term rate is
set forth for the month of March 2003. See Rev. Rul.
2003–26, page 563.
Section 412.—Minimum
Funding Standards
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of March 2003. See Rev. Rul. 2003–26, page 563.
Section 467.—Certain Pay-
ments 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 March 2003. See Rev. Rul. 2003–26, page 563.
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 March 2003. See Rev. Rul. 2003–26, page 563.
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 March 2003. See Rev.
Rul. 2003–26, page 563.
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 March 2003. See Rev. Rul. 2003–26, page 563.
Section 642.—Special Rules
for Credits and Deductions
Federal short-term, mid-term, and long-term rates
are set forth for the month of March 2003. See Rev.
Rul. 2003–26, page 563.
Section 807.—Rules for Cer-
tain Reserves
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of March 2003. See Rev. Rul. 2003–26, page 563.
Insurance companies; interest rate
tables.Prevailing state assumed interest
rates are provided for the determination of
reserves under section 807 of the Code for
contracts issued in 2002 and 2003. Rev. Rul.
92–19 supplemented in part.
Rev. Rul. 2003–24
For purposes of § 807(d)(4) of the In-
ternal Revenue Code, for taxable years be-
ginning after December 31, 2001, this ruling
supplements the schedules of prevailing
state assumed interest rates set forth in Rev.
Rul. 92–19, 1992–1 C.B. 227. This infor-
mation is to be used by insurance compa-
nies in computing their reserves for (1) life
insurance and supplementary total and per-
manent disability benefits, (2) individual an-
nuities and pure endowments, and (3) group
annuities and pure endowments. As
§ 807(d)(2)(B) requires that the interest rate
used to compute these reserves be the
greater of (1) the applicable federal inter-
est rate, or (2) the prevailing state assumed
interest rate, the table of applicable fed-
eral interest rates in Rev. Rul. 92–19 is also
supplemented.
Following are supplements to sched-
ules A, B, C, and D to Part III of Rev. Rul.
92–19, providing prevailing state assumed
interest rates for insurance products with dif-
ferent features issued in 2002 and 2003, and
a supplement to the table in Part IV of Rev.
Rul. 92–19, providing the applicable fed-
eral interest rates under § 807(d) for 2002
and 2003. This ruling does not supple-
ment Parts I and II of Rev. Rul. 92–19.
This is the eleventh supplement to the
interest rates provided in Rev. Rul. 92–
19. Earlier supplements were published in
Rev. Rul. 93–58, 1993–2 C.B. 241 (inter-
est rates for insurance products issued in
1992 and 1993); Rev. Rul. 94–11, 1994–1
C.B. 196 (1993 and 1994); Rev. Rul. 95–4,
1995–1 C.B. 141 (1994 and 1995); Rev.
Rul. 96–2, 1996–1 C.B. 141 (1995 and
1996); Rev. Rul. 97–2, 1997–1 C.B. 134
(1996 and 1997); Rev. Rul. 98–2, 1998–1
C.B. 259 (1997 and 1998); Rev. Rul. 99–
10, 1999–1 C.B. 671 (1998 and 1999); Rev.
Rul. 2000–17, 2000–1 C.B. 842 (1999 and
2000); Rev. Rul. 2001–11, 2001–1 C.B. 780
(2000 and 2001); and Rev. Rul. 2002–12,
2002–11 I.R.B. 624 (2001 and 2002).
2003–10 I.R.B.557March 10, 2003

Part III. Prevailing State Assumed Interest Rates — Products Issued in Years After 1982.*
Schedule A
STATUTORY VALUATION INTEREST RATES
BASED ON THE 1980 AMENDMENTS TO THE
NAIC STANDARD VALUATION LAW
A. Life insurance valuation:
Guarantee Duration
(years)
Calendar Year of Issue
2003
10 or fewer5.00**
More than 10 but not more than 204.75**
More than 204.50**
Source: Rates calculated from the monthly averages, ending June 30, 2002, of Moody’s Corporate Bond Yield Average—Monthly
Average Corporates.
** As the applicable federal interest rate for 2003 of 5.27 percent exceeds this prevailing state assumed interest rate, the interest
rate to be used for this product under§807 is 5.27 percent.
* The terms used in the schedules in this ruling and in Part III of Rev. Rul. 92–19 are those used in the Standard Valuation Law;
the terms are defined in Rev. Rul. 92–19.
Part III, Schedule B
STATUTORY VALUATION INTEREST RATES
BASED ON THE 1980 AMENDMENTS TO THE
NAIC STANDARD VALUATION LAW
B. Single premium immediate annuities and annuity benefits involving life contingencies arising from other annuities with cash
settlement options and from guaranteed interest contracts with cash settlement options:
Calendar Year of Issue
Valuation Interest Rate
20026.50*
Source: Rates calculated from the monthly averages, ending June 30, 2002, of Moody’s Corporate Bond Yield Average—Monthly
Average Corporates. The terms used in this schedule are those used in the Standard Valuation Law as defined in Rev. Rul. 92–
19.
*As this prevailing state assumed interest exceeds the applicable federal interest rate for 2002 of 5.71 percent, the valuation in-
terest rate of 6.50 percent is to be used for this product under§807.
March 10, 20035582003–10 I.R.B.

Part III, Schedule C20–2002
STATUTORY VALUATION INTEREST RATES
BASED ON NAIC STANDARD VALUATION LAW
FOR2002CALENDAR YEAR BUSINESS
GOVERNED BY THE 1980 AMENDMENTS
C. Valuation interest rates for other annuities and guaranteed interest contracts that are valued on an issue year basis:
Cash
Settlement
Options?
Future
Interest
Guarantee?
Guarantee Duration
(years)
Valuation Interest Rate
For Plan Type
ABC
YesYes5 or fewer6.505.755.25*
More than 5, but not more than 106.255.755.25*
More than 10, but not more than 206.005.25*5.00*
More than 205.00*4.50*4.50*
YesNo5 or fewer6.756.005.50*
More than 5, but not more than 106.506.005.50*
More than 10, but not more than 206.005.50*5.25*
More than 205.25*4.75*4.75*
NoYes or No5 or fewer6.50
More than 5, but not more than 106.25NOT
APPLICABLE
More than 10, but not more than 206.00
More than 205.00*
Source: Rates calculated from the monthly averages, ending June 30, 2002, of Moody’s Corporate Bond Yield Average—Monthly
Average Corporates.
*As the applicable federal interest rate for 2002 of 5.71 percent exceeds this prevailing state assumed interest rate, the interest
rate to be used for this product under§807 is 5.71 percent.
Part III, Schedule D20–2002
STATUTORY VALUATION INTEREST RATES
BASED ON NAIC STANDARD VALUATION LAW
FOR2002CALENDAR YEAR BUSINESS
GOVERNED BY THE 1980 AMENDMENTS
D. Valuation interest rates for other annuities and guaranteed interest contracts that are contracts with cash settlement options and
that are valued on a change in fund basis:
2003–10 I.R.B.559March 10, 2003

Cash
Settlement
Options?
Future
Interest
Guarantee?
Guarantee Duration
(years)
Valuation Interest Rate
For Plan Type
ABC
YesYes5 or fewer7.256.755.50*
More than 5, but not
more than 10
7.006.755.50*
More than 10, but not
more than 20
6.506.255.25*
More than 205.755.754.75*
YesNo5 or fewer7.507.005.75
More than 5, but not
more than 10
7.257.005.75
More than 10, but not
more than 20
6.756.505.50*
More than 206.006.005.00*
Source: Rates calculated from the monthly averages, ending June 30, 2002, of Moody’s Corporate Bond Yield Average—Monthly
Average Corporates.
*As the applicable federal interest rate for 2002 of 5.71 percent is equal to or exceeds this prevailing state assumed interest rate,
the interest rate to be used for this product under§807 is 5.71 percent.
Part IV. Applicable Federal Interest Rates.
TABLE OF
APPLICABLE FEDERAL INTEREST RATES
FOR PURPOSES OF§807
YearInterest Rate
20025.71
20035.27
Sources: Rev. Rul. 2001–58, 2001–2 C.B. 570 for the 2002 rate and Rev. Rul. 2002–81, 2002–49 I.R.B. 928 for the 2003 rate.
EFFECT ON OTHER REVENUE
RULINGS
Rev. Rul. 92–19 is supplemented by the
addition to Part III of that ruling of pre-
vailing state assumed interest rates under
§807 for certain insurance products is-
sued in 2002 and 2003 and is further
supplemented by an addition to the table in
PartIVofRev.Rul.92–19 listing appli-
cable federal interest rates. Parts I and II
of Rev. Rul. 92–19 are not affected by this
ruling.
DRAFTING INFORMATION
The principal author of this revenue rul-
ing is Ann H. Logan of the Office of As-
sociate Chief Counsel (Financial Institutions
and Products). For further information re-
garding this revenue ruling, contact her at
(202) 622–3970 (not a toll-free call).
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 March 2003. See Rev. Rul. 2003–26, page 563.
March 10, 20035602003–10 I.R.B.

Section 954.—Foreign Base
Company Income
26 CFR 1.954–2: Foreign personal holding
company income.
T.D. 9039
DEPARTMENT OF THE
TREASURY
Internal Revenue Service
26 CFR Part 1
Guidance Regarding the
Definition of Foreign Personal
Holding Company Income
AGENCY: Internal Revenue Service (IRS),
Treasury.
ACTION: Final regulations.
SUMMARY: This document contains fi-
nal regulations that provide that gain or loss
arising from certain commodities hedg-
ing transactions and currency gain or loss
arising from certain interest-bearing liabili-
ties do not constitute (or are not netted
against) foreign personal holding com-
pany income. This treatment is implemented
because the applicable commodities hedg-
ing transactions and interest-bearing liabili-
ties typically offset transactions that do not
generate foreign personal holding com-
pany income.
DATES:Effective Date:These regulations
are effective on January 31, 2003.
Applicability Date:For dates of appli-
cability, see§1.954–2(f)(2)(iv)(C), (v)(D),
and (g)(2)(ii)(C)(2)(iii).
FOR FURTHER INFORMATION CON-
TACT: Kenneth Christman or Gregory
Spring at (202) 622–3870 (not toll-free
numbers).
SUPPLEMENTARY INFORMATION:
Background
On May 13, 2002, proposed regula-
tions (REG–154920–01, 2002–22 I.R.B.
1060 [67 FR 31995]) were published in the
Federal Registerunder section 954 gov-
erning the definition offoreign base com-
pany incomeandforeign personal holding
company incomeof acontrolled foreign cor-
poration(a CFC). These regulations ad
dressed, among other matters, the circum-
stances in which income from transac-
tions in commodities will be treated as
foreign personal holding company income.
Following the publication of the pro-
posed regulations, the IRS scheduled a pub-
lic hearing and requested written comments
on the regulations. The public hearing was
canceled because no one requested to speak
at the hearing. The IRS received one writ-
ten comment, which recommended the pro-
posed regulations be finalized as written.
Explanation of Revisions
The language of the proposed regula-
tions is unchanged except for nonsubstan-
tive changes to§§1.954–2(g)(2)(ii)(C)(2)(i)
and (ii) that more explicitly set out the re-
lationship between those paragraphs and
§1.954–2(g)(2)(ii)(C)(1).
Special Analyses
It has been determined that this Trea-
sury decision is not a significant regula-
tory action 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
Procedure Act (5 U.S.C. chapter 5) does not
apply to these regulations, and because these
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. Therefore, a Regulatory
Flexibility Analysis is not required. Pur-
suant to section 7805(f) of the Internal Rev-
enue Code, the notice of proposed
rulemaking preceding these regulations was
submitted to the Chief Counsel for Advo-
cacy of the Small Business Administra-
tion for comment on its impact on small
business.
Drafting Information
The principal authors of these regula-
tions are Kenneth Christman and Ted
Setzer of the Office of the Associate Chief
Counsel (International). However, other
presonnel 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:
PA RT 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 continues to read in part as follows:
Authority: 26 U.S.C. 7805***
Par.2.In§1.954–0, paragraph (b) is
amended by:
1. Removing the entry for§1.954–
2(f)(2)(iii)(E).
2. Revising the entry for§1.954–
2(f)(2)(iv).
3.Addingentriesfor§1.954–
2(f)(2)(iv)(C), and (f)(2)(v) through
(f)(2)(vi).
4.Addingentriesfor§1.954–
2(g)(2)(ii)(C)(1) through (g)(2)(ii)(C)(2)(iii).
The additions and revisions read as
follows:
§1.954–0 Introduction.
*****
(b)***
§1.954–2 Foreign personal holding
company income.
*****
(f)***
(2)***
(iv) Qualified hedging transaction en-
tered into prior to January 31, 2003.
*****
(C) Effective date.
(v) Qualified hedging transaction en-
tered into on or after January 31, 2003.
(A) In general.
(B) Exception.
(C) Examples.
(D) Effective date.
(vi) Financial institutions not a pro-
ducer, etc.
(g)***
(2)***
(ii)***
(C) Regular dealers.
(1) General rule.
(2) Certain interest-bearing liabilities
treated as dealer property.
(i) In general.
(ii) Failure to identify certain liabili-
ties.
(iii) Effective date.
*****
Par. 3. Section 1.954–2 is amended by:
1. Removing paragraph (f)(2)(iii)(E).
2. Revising the heading of paragraph
(f)(2)(iv).
2003–10 I.R.B.561March 10, 2003

3. Adding paragraphs (f)(2)(iv)(C) and
(f)(2)(v) through (f)(2)(vi).
4. Adding paragraphs (g)(2)(ii)(C)(1)
through (g)(2)(ii)(C)(2)(iii).
5. Revising paragraph (g)(2)(iii).
The revisions and additions read as
follows:
§1.954–2 Foreign personal holding
company income.
*****
(f)***
(2)***
(iv)Qualified hedging transaction en-
tered into prior to January 31, 2003.
*****
(C)Effective date.This paragraph
(f)(2)(iv) applies to gain or loss realized by
a controlled foreign corporation with re-
spect to a qualified hedging transaction en-
tered into prior to January 31, 2003.
(v)Qualified hedging transaction en-
tered into on or after January 31, 2003—
(A)In general.The termqualified hedging
transactionmeans abona fidehedging
transaction, as defined in paragraph (a)(4)(ii)
of this section, with respect to one or more
commodities transactions reasonably nec-
essary to the conduct of any business by a
producer, processor, merchant or handler of
commodities in a manner in which such
business is customarily and usually con-
ducted by others. For purposes of this para-
graph (f)(2)(v), a producer, processor,
merchant or handler of commodities in-
cludes a controlled foreign corporation that
regularly uses commodities in a manufac-
turing, construction, utilities, or transpor-
tation business.
(B)Exception.The termqualified hedg-
ing transactiondoes not include a trans-
action described in section 988(c)(1)
(without regard to section 988(c)(1)(D)(i)).
(C)Examples.The following examples
illustrate the provisions of this paragraph
(f)(2)(v):
Example 1.CFC1 is a controlled foreign corpora-
tion located in country A. CFC1 manufactures and sells
machinery in country B using aluminum and com-
ponent parts purchased from third parties that con-
tain significant amounts of aluminum. CFC1 conducts
its manufacturing business in a manner in which such
business is customarily and usually conducted by oth-
ers. To protect itself against increases in the price of
aluminum used in the machinery it manufactures,
CFC1 enters into futures purchase contracts for the
delivery of aluminum. These futures purchase con-
tracts arebona fidehedging transactions. As CFC1 pur-
chases aluminum and component parts containing
significant amounts of aluminum in the spot market
for use in its business, it closes out an equivalent
amount of aluminum futures purchase contracts by en-
tering into offsetting aluminum futures sales con-
tracts. The aluminum futures purchase contracts are
qualified hedging transactions as defined in para-
graph (f)(2)(v)(A) of this section. Accordingly, any gain
or loss on such aluminum futures purchase contracts
is excluded from the computation of foreign per-
sonal holding company income.
Example 2.CFC2 is a controlled foreign corpora-
tion located in country B. CFC2 operates an airline
business within country B in a manner in which such
business is customarily and usually conducted by oth-
ers. To protect itself against increases in the price of
aviation fuel, CFC2 enters into forward contracts for
the purchase of aviation fuel. These forward pur-
chase contracts arebona fidehedging transactions. As
CFC2 purchases aviation fuel in the spot market for
use in its business, it closes out an equivalent amount
of its forward purchase contracts for cash pursuant to
a contractual provision that permits CFC2 to termi-
nate the contract and make or receive a one-time pay-
ment representing the contract’s fair market value. The
aviation fuel forward purchase contracts are quali-
fied hedging transactions as defined in paragraph
(f)(2)(v)(A) of this section. Accordingly, any gain or
loss on such aviation fuel forward purchase con-
tracts is excluded from the computation of foreign per-
sonal holding company income.
(D)Effective date.This paragraph
(f)(2)(v) applies to gain or loss realized by
a controlled foreign corporation with re-
spect to a qualified hedging transaction en-
tered into on or after January 31, 2003.
(vi)Financial institutions not a pro-
ducer, etc.For purposes of this paragraph
(f), a corporation is not a producer, pro-
cessor, merchant, or handler of commodi-
ties if its business is primarily financial. For
example, the business of a controlled for-
eign corporation is primarily financial if its
principal business is making a market in no-
tional principal contracts based on a com-
modities index.
*****
(g)***
(2)***
(ii)***
(C)Regular dealers—(1)General rule.
Transactions in dealer property (as de-
fined in paragraph (a)(4)(v) of this sec-
tion) described in section 988(c)(1)(B) or
(C) that are entered into by a controlled for-
eign corporation that is a regular dealer (as
defined in paragraph (a)(4)(iv) of this sec-
tion) in such property in its capacity as a
dealer will be treated as directly related to
the business needs of the controlled for-
eigncorporationunderparagraph
(g)(2)(ii)(A) of this section.
(2)Certain interest-bearing liabilities
treated as dealer property—(i)In gen-
eral.For purposes of this paragraph
(g)(2)(ii)(C), an interest-bearing liability in-
curred by a controlled foreign corpora-
tion that is denominated in (or determined
by reference to) a non-functional currency
shall be treated as dealer property of the
type described in paragraph (g)(2)(ii)(C)(1)
of this section if the liability, by being de-
nominated in such currency, reduces the
controlled foreign corporation’s currency
risk with respect to dealer property, and the
liability is identified on the controlled for-
eign corporation’s records as a liability
treated as dealer property before the close
of the day on which the liability is in-
curred.
(ii)Failure to identify certain liabili-
ties.If a controlled foreign corporation iden-
tifies certain interest-bearing liabilities as
liabilities treated as dealer property under
paragraph (g)(2)(ii)(C)(2)(i) of this sec-
tion but fails to so identify other interest-
bearing liabilities that manage its currency
risk with respect to assets held that con-
stitute dealer property, the Commissioner
may treat such other liabilities as prop-
erly identified as dealer property under para-
graph (g)(2)(ii)(C)(2)(i) of this section if the
Commissioner determines that the failure
to identify such other liabilities had as one
of its principal purposes the avoidance of
federal income tax.
(iii)Effective date.This paragraph
(g)(2)(ii)(C)(2) applies only to gain or loss
from an interest-bearing liability entered into
by a controlled foreign corporation on or
after January 31, 2003.
*****
(iii)Special rule for foreign currency
gain or loss from an interest-bearing li-
ability.Except as provided in paragraph
(g)(2)(ii)(C)(2) or (g)(5)(iv) of this sec-
tion, foreign currency gain or loss arising
from an interest-bearing liability is char-
acterized as subpart F income and non-
subpart F income in the same manner that
interest expense associated with the liabil-
ity would be allocated and apportioned be-
tween subpart F income and non-subpart F
income under§§1.861–9T and 1.861–12T.
*****
David A. Mader,
Assistant Deputy Commissioner
of Internal Revenue.
Approved January 17, 2003.
March 10, 20035622003–10 I.R.B.

Pamela F. Olson,
Assistant Secretary of the Treasury.
(Filed by the Office of the Federal Register January 30, 2003,
8:45 a.m., and published in the issue of the Federal Regis-
ter for January 31, 2003, 68 F.R. 4916)
Section 1274.—Determina-
tion 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 382, 1274, 1288, and other sec-
tions of the Code, tables set forth the rates
for March 2003.
Rev. Rul. 2003–26
This revenue ruling provides various pre-
scribed rates for federal income tax pur-
poses for March 2003 (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 Rev-
enue 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 fed-
eral long-term rate and the long-term tax-
exempt rate described in section 382(f).
Table 4 contains the appropriate percent-
ages for determining the low-income hous-
ing credit described in section 42(b)(2) for
buildings placed in service during the cur-
rent month. Finally, Table 5 contains the
federal rate for determining the present
value of annuity, an interest for life or for
a term of years, or a remainder or a rever-
sionary interest for purposes of section
7520.
REV. RUL. 2003–26 TABLE 1
Applicable Federal Rates (AFR) for March 2003
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-Term
AFR1.58%1.57%1.57%1.56%
110% AFR1.74%1.73%1.73%1.72%
120% AFR1.89%1.88%1.88%1.87%
130% AFR2.05%2.04%2.03%2.03%
Mid-Term
AFR3.24%3.21%3.20%3.19%
110% AFR3.56%3.53%3.51%3.50%
120% AFR3.89%3.85%3.83%3.82%
130% AFR4.21%4.17%4.15%4.13%
150% AFR4.88%4.82%4.79%4.77%
175% AFR5.70%5.62%5.58%5.56%
Long-Term
AFR4.80%4.74%4.71%4.69%
110% AFR5.28%5.21%5.18%5.15%
120% AFR5.77%5.69%5.65%5.62%
130% AFR6.25%6.16%6.11%6.08%
REV. RUL. 2003–26 TABLE 2
Adjusted AFR for March 2003
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
adjusted AFR1.34%1.34%1.34%1.34%
Mid-term
adjusted AFR2.76%2.74%2.73%2.72%
Long-term
adjusted AFR4.58%4.53%4.50%4.49%
2003–10 I.R.B.563March 10, 2003

REV. RUL. 2003–26 TABLE 3
Rates Under Section 382 for March 2003
Adjusted federal long-term rate for the current month4.58%
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.)4.61%
REV. RUL. 2003–26 TABLE 4
Appropriate Percentages Under Section 42(b)(2) for March 2003
Appropriate percentage for the 70% present value low-income housing credit7.93%
Appropriate percentage for the 30% present value low-income housing credit3.40%
REV. RUL. 2003–26 TABLE 5
Rate Under Section 7520 for March 2003
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 interest3.8%
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 March 2003. See Rev. Rul. 2003–26, page 563.
Section 5891.—Structured
Settlement Factoring
Transactions
26 CFR 157.5891–1T: Imposition of excise tax on
structured settlement factoring transactions.
T.D. 9042
DEPARTMENT OF THE
TREASURY
Internal Revenue Service
26 CFR Parts 157 and 602
Excise Tax Relating to
Structured Settlement
Factoring Transactions
AGENCY: Internal Revenue Service (IRS),
Treasury.
ACTION: Temporary regulations.
SUMMARY: This document contains tem-
porary regulations relating to the manner
and method of reporting and paying the
nondeductible 40-percent excise tax im-
posed on any person who acquires struc-
tured settlement payment rights in a
structured settlement factoring transac-
tion. The Victims of Terrorism Tax Relief
Act of 2001 added this excise tax to the In-
ternal Revenue Code of 1986. The text of
the temporary regulations also serves as the
text of the proposed regulations set forth in
the notice of proposed rulemaking (REG–
139768–02) on this subject in this issue of
the Bulletin.
DATES:Effective Date:These regulations
are effective on February 19, 2003.
Applicability Date:For dates of appli-
cability, see§157.5891–1T(e).
FOR FURTHER INFORMATION CON-
TACT: Shareen S. Pflanz at 202–622–8488
(not a toll-free call).
SUPPLEMENTARY INFORMATION:
Paperwork Reduction Act
These regulations are being issued with-
out prior notice and public procedure pur-
suant to the Administrative Procedure Act
(5 U.S.C. 553). For this reason, the col-
lection of information contained in these
regulations has been reviewed and, pend-
ing receipt and evaluation of public com-
ments, approved by the Office of
Management and Budget under control
number 1545–1824. Responses to this col-
lection of information are mandatory.
March 10, 20035642003–10 I.R.B.

An agency may not conduct or spon-
sor, and a person is not required to re-
spond to, a collection of information unless
it displays a valid control number assigned
by the Office of Management and Bud-
get.
For further information concerning this
collection of information, and where to sub-
mit comments on the collection of infor-
mation and the accuracy of the estimated
burden, and suggestions for reducing this
burden, please refer to the preamble to the
cross-referencing notice of proposed rule-
making (REG–139768–02) on page 583 of
this Bulletin.
Books or records relating to a collec-
tion of information must be retained as long
as their contents may become material in
the administration of any internal revenue
law. Generally, tax returns and tax return
information are confidential, as required by
26 U.S.C. 6103.
Background
This document adds a new part 157, Ex-
cise Tax on Structured Settlement Factor-
ing Transactions, to title 26 of the Code of
Federal Regulations. The temporary regu-
lations under part 157 provide guidance on
the proper manner and method of report-
ing and paying the 40-percent excise tax im-
posed on any person who acquires, directly
or indirectly, structured settlement pay-
ment rights in a structured settlement fac-
toring transaction. The temporary regulations
reflect the addition to the Internal Rev-
enue Code (Code) of chapter 55 and sec-
tion 5891 by section 115 of the Victims of
Terrorism Tax Relief Act of 2001, Public
Law 107–134 (115 Stat. 2427, 2436–2439).
Explanation of Provisions
Section 5891of the Internal Revenue
Code imposes an excise tax on any per-
son who acquires, directly or indirectly,
structured settlement payment rights in a
structured settlement factoring transac-
tion. The tax is equal to 40 percent of the
factoring discount with respect to the fac-
toring transaction.
The temporary regulations set forth the
manner and method of paying the excise tax
imposed under section 5891 of the Code.
Generally, the termstructured settlement
factoring transactionis defined as a trans-
fer of structured settlement payment rights
made for consideration by means of sale,
assignment, pledge, or other form of en-
cumbrance or alienation for consideration.
If a taxpayer is liable for the tax imposed
by section 5891, the excise tax must be re-
ported on Form 8876,Excise Tax on Struc-
tured Settlement Factoring Transactions.
Generally, the temporary regulations re-
quire that the excise tax return be filed and
the tax paid on or before the later of the
ninetieth day following the day the tax-
payer receives any structured settlement
payment rights (including portions of struc-
tured settlement payments) or May 20,
2003. The temporary regulations provide
rules relating to the Service’s authority to
extend the time for payment of any amount
shown or required to be shown on the re-
turn.
The temporary regulations do not ad-
dress the method of determining the proper
amount of the excise tax imposed by sec-
tion 5891 of the Code. Issues related to the
determination of the amount of the excise
tax may be addressed by future regula-
tions.
The temporary regulations will be ef-
fective generally for structured settlement
factoring transactions entered into on or af-
ter February 22, 2002.
Special Analyses
It has been determined that this Trea-
sury decision is not a significant regula-
tory action 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
Procedure Act (5 U.S.C. chapter 5) does not
apply to these regulations. For the appli-
cability of the Regulatory Flexibility Act (5
U.S.C. chapter 6), refer to the Special
Analyses section of the preamble to the
cross-reference notice of proposed rule-
making (REG–139768–02) on page 583 of
this issue of the Bulletin. Pursuant to sec-
tion 7805(f) of the Internal Revenue Code,
these temporary regulations will be sub-
mitted to the Chief Counsel for Advocacy
of the Small Business Administration for
comment on their impact.
Drafting Information
The principal author of these regula-
tions is Shareen Soltanzadeh Pflanz, At-
torney, Office of Associate Chief Counsel
(Income Tax and Accounting). However,
other personnel from the IRS and Trea-
sury Department participated in their de-
velopment.
*****
Amendments to the Regulations
Accordingly, title 26 of the Code of Fed-
eral Regulations is amended as follows:
SUBCHAPTER D—MISCELLAN-
EOUS EXCISE TAXES
Paragraph 1. Part 157 is added to read
as follows:
PART 157—EXCISE TAX ON
STRUCTURED SETTLEMENT
FACTORING TRANSACTIONS
Subpart A—Tax on Structured
Settlement Factoring Transactions
Sec.
157.5891–1T Imposition of excise tax on
structured settlement factoring transac-
tions.
Subpart B—Procedure and
Administration
Sec.
157.6001–1T Records, statements, and
special returns.
157.6011–1T General requirement of re-
turn, statement, or list.
157.6061–1T Signing of returns and
other documents.
157.6065–1T Verification of returns.
157.6071–1T Time for filing returns.
157.6081–1T Extension of time for fil-
ing the return.
157.6091–1T Place for filing returns.
157.6151–1T Time and place for pay-
ing of tax shown on returns.
157.6161–1T Extension of time for pay-
ing tax.
157.6165–1T Bonds where time to pay
tax has been extended.
Authority: 26 U.S.C. 7805
Section 157.6001–1T also issued un-
der 26 U.S.C. 6001.
Section 157.6011–1T also issued un-
der 26 U.S.C. 6011.
Section 157.6061–1T also issued un-
der 26 U.S.C. 6061
Section 157.6091–1T also issued un-
der 26 U.S.C. 6091.
Section 157.6161–1T also issued un-
der 26 U.S.C. 6161.
Subpart A—Tax on Structured
Settlement Factoring Transactions
2003–10 I.R.B.565March 10, 2003

§157.5891–1T Imposition of excise tax
on structured settlement factoring
transactions.
(a)In general.Section 5891 imposes on
any person who acquires, directly or indi-
rectly, structured settlement payment rights
in a structured settlement factoring trans-
action a tax equal to 40 percent of the fac-
toring discount with respect to such
factoring transactions.
(b)Exceptions for certain approved
transactions—(1)In general.The ex-
cise tax shall not apply to a structured settle-
ment factoring transaction if the transfer of
structured settlement payment rights is ap-
proved in advance in a qualified order.
(2)Qualified order dispositive.A quali-
fied order shall be treated as dispositive for
purposes of this exception.
(c)Definitions—(1)Applicable state
statutemeans—
(i) A statute that is enacted by the state
in which the payee of the structured settle-
ment is domiciled and that provides for the
entry of an order, judgment, or decree de-
scribed in paragraph (c)(4)(i) of this sec-
tion; or
(ii) If there is no such statute, a statute
that is enacted by the state in which ei-
ther the party to the structured settlement
(including an assignee under a qualified as-
signment under section 130) or the per-
son issuing the funding asset for the
structured settlement is domiciled or has its
principal place of business and that pro-
vides for the entry of such an order, judg-
ment, or decree.
(2)Applicable state courtmeans, with
respect to any applicable state statute, a
court of the state that enacted such stat-
ute. If the payee of the structured settle-
ment is not domiciled in the state that
enacted the statute, the term also includes
a court of the state in which the payee is
domiciled.
(3)Factoring discountmeans an amount
equal to the excess of—
(i) The aggregate undiscounted amount
of structured settlement payments being ac-
quired in the structured settlement factor-
ing transaction; over
(ii) The total amount actually paid by the
acquirer to the person from whom such
structured settlement payments are acquired.
(4)Qualified ordermeans a final or-
der, judgment, or decree that—
(i) Finds that the transfer of structured
settlement payment rights does not contra-
vene any federal or state statute, or the or-
der of any court or responsible admin-
istrative authority, and is in the best inter-
est of the payee, taking into account the
welfare and support of the payee’s depen-
dents; and
(ii) Is issued under the authority of an
applicable state statute by an applicable state
court, or is issued by the responsible ad-
ministrative authority (if any) which has ex-
clusive jurisdiction over the underlying
action or proceeding which was resolved by
means of the structured settlement.
(5)Responsible administrative author-
itymeans the administrative authority that
had jurisdiction over the underlying ac-
tion or proceeding that was resolved by
means of the structured settlement.
(6)Stateincludes the Commonwealth of
Puerto Rico and any possession of the
United States.
(7)Structured settlementmeans an ar-
rangement—
(i) That is established by—
(A) Suit or agreement for the periodic
payment of damages excludable from the
gross income of the recipient under sec-
tion 104(a)(2); or
(B) Agreement for the periodic pay-
ment of compensation under any work-
ers’compensation law excludable from the
gross income of the recipient under sec-
tion 104(a)(1); and
(ii) Under which the periodic payments
are—
(A) Of the character described in sec-
tion 130(c)(2)(A) and (B); and
(B) Payable by a person who is a party
to the suit or agreement or to the work-
ers’compensation claim or by a person who
has assumed the liability for such peri-
odic payments under a qualified assign-
ment in accordance with section 130.
(8)Structured settlement factoring trans-
actionmeans a transfer of structured settle-
ment payment rights (including portions of
structured settlement payments) made for
consideration by means of sale, assign-
ment, pledge, or other form of encum-
brance or alienation for consideration other
than—
(i) The creation or perfection of a se-
curity interest in structured settlement pay-
ment rights under a blanket security
agreement entered into with an insured de-
pository institution in the absence of any
action to redirect the structured settlement
payments to such institution (or agent or
successor thereof) or otherwise to enforce
such blanket security interest as against the
structured settlement payment rights; or
(ii) A subsequent transfer of structured
settlement payment rights acquired in a
structured settlement factoring transac-
tion.
(9)Structured settlement payment rights
means rights to receive payments under a
structured settlement.
(d)Coordination with other provisions
of the Internal Revenue Code—(1)In gen-
eral.If the applicable requirements of sec-
tions 72, 104(a)(1), 104(a)(2), 130, and
461(h) were satisfied at the time the struc-
tured settlement involving structured settle-
ment payment rights was entered into, the
subsequent occurrence of a structured settle-
ment factoring transaction shall not affect
the application of the provisions of such
sections to the parties to the structured
settlement (including an assignee under a
qualified assignment under section 130) in
any taxable year.
(2)No withholding of tax.The provi-
sions of section 3405 regarding withhold-
ing of tax shall not apply to the person
making the payments in the event of a
structured settlement factoring transac-
tion.
(e)Effective dates—(1)In general.Sec-
tion 5891 applies to structured settlement
factoring transactions entered into on or af-
ter February 22, 2002. Section 5891(d) also
applies to structured settlement factoring
transactions entered into before February 22,
2002.
(2)Transition rule.In the case of a struc-
tured settlement factoring transaction en-
tered into during the period beginning on
February 22, 2002, and ending on July 1,
2002, no tax shall be imposed under sec-
tion 5891(a) if—
(i) The structured settlement payee is do-
miciled in a state (or possession of the
United States) that has not enacted an ap-
plicable state statute (as defined in sec-
tion 5891(b)(3)); and
(ii) The person acquiring the structured
settlement payment rights discloses to the
structured settlement payee in advance of
the structured settlement factoring trans-
action—
March 10, 20035662003–10 I.R.B.

(A) The amounts and due dates of the
payments to be transferred;
(B) The aggregate amount to be trans-
ferred;
(C) The consideration to be received by
the structured settlement payee for the trans-
ferred payments;
(D) The discounted present value of the
transferred payments (including the present
value as determined in the manner de-
scribed in section 7520); and
(E) The expenses required under the
terms of the structured settlement factor-
ing transaction to be paid by the struc-
tured settlement payee or deducted from the
proceeds of such transaction.
Subpart B—Procedure and
Administration
§157.6001–1T Records, statements, and
special returns.
(a)In general.Any person subject to tax
under chapter 55 (Structured Settlement
Factoring Transactions) of the Internal Rev-
enue Code (chapter 55) must keep such
complete and detailed records as are suf-
ficient to enable the Internal Revenue Ser-
vice (IRS) to determine accurately the
amount of liability under chapter 55.
(b)Notice by the IRS requiring returns,
statements, or the keeping of records.The
IRS may require any person, by notice
served upon him, to make such returns, ren-
der such statements, or keep such spe-
cific records as will enable the IRS to
determine whether or not the person is li-
able for tax under chapter 55.
(c)Retention of records.The records re-
quired by this section must be kept at all
times available for inspection by the IRS,
and shall be retained so long as the con-
tents thereof may become material in the
administration of any internal revenue law.
§157.6011–1T General requirement of
return, statement, or list.
Every person liable for tax under sec-
tion 5891 must file a return with respect to
the tax in accordance with the forms and
instructions provided by the Internal Rev-
enue Service.
§157.6061–1T Signing of returns and
other documents.
Any return, statement, or other docu-
ment required to be made with respect to
a tax imposed by chapter 55 (Structured
Settlement Factoring Transactions) of the
Internal Revenue Code or the regulations
thereunder must be signed by the person re-
quired to file the return, statement, or other
document, or by the persons required or
duly authorized to sign in accordance with
the regulations, forms, or instructions pre-
scribed with respect to such return, state-
ment, or document. An individual’s
signature on such return, statement, or other
document shall beprima facieevidence that
the individual is authorized to sign the re-
turn, statement, or other document.
§157.6065–1T Verification of returns.
If a return, statement, or other docu-
ment made under the provisions of chap-
ter 55 of the Internal Revenue Code
(chapter 55) or of subtitle F of the Code
(subtitle F), or the regulations thereunder
with respect to any tax imposed by chap-
ter 55, or the form and instructions is-
sued with respect to such return, statement,
or other document, requires that it shall con-
tain or be verified by a written declara-
tion that it is made under the penalties of
perjury, it must be so verified by the per-
son or persons required to sign such re-
turn, statement, or other document. In
addition, any other statement or document
submitted under any provision of chapter
55 or subtitle F, or the regulations there-
under, with respect to any tax imposed by
chapter 55 may be required to contain or
be verified by written declaration that is
made under the penalties of perjury.
§157.6071–1T Time for filing returns.
(a)In general.Except as provided in
paragraph (b) of this section, returns re-
quired by§157.6011–1T (relating to re-
turns of tax with respect to structured
settlement factoring transactions) must be
filed on or before the ninetieth day follow-
ing the receipt of structured settlement pay-
ment rights in a structured settlement
factoring transaction.
(b)Returns relating to structured settle-
ment payment rights received before Feb-
ruary 19, 2003.Returns required by
§157.6011–1T that relate to structured settle-
ment payment rights received on or be-
fore February 19, 2003, must be filed on
or before May 20, 2003.
§157.6081–1T Extension of time for
filing the return.
(a)Application for extension.An appli-
cation for an extension of time for filing the
return required by§157.6011–1T (relat-
ing to returns of tax with respect to struc-
tured settlement factoring transactions) must
be completed in accordance with the forms
and instructions provided by the Internal
Revenue Service. It should be made be-
fore the expiration of the time within which
the return otherwise must be filed, and fail-
ure to do so may indicate negligence and
constitute sufficient cause for denial. It
should, where possible, be made suffi-
ciently early to permit consideration of the
matter and reply before what otherwise
would be the due date of the return. An ex-
tension of time for filing a return shall not
extend the time for the payment of the tax
or any part thereof unless specified to the
contrary in the grant of the extension.
(b)Filing of return.If an extension of
time for filing the return is granted, a re-
turn must be filed before the period of ex-
tension expires.
§157.6091–1T Place for filing returns.
The return required by§157.6011–1T
(relating to returns of tax with respect to
structured settlement factoring transac-
tions) must be filed at the place specified
in the forms and instructions provided by
the Internal Revenue Service.
§157.6151–1T Time and place for paying
of tax shown on returns.
The tax under chapter 55 (Structured
Settlement Factoring Transactions) of the
Internal Revenue Code shown on any re-
turn must, without assessment or notice and
demand, be paid at the time and place
specified in the forms and instructions pro-
vided by the IRS. For provisions relating
to the time and place for filing such re-
turn, see§157.6071–1T and§157.6091–
1T. For provisions relating to the extension
of time for paying the tax, see§157.6161–
1T.
§157.6161–1T Extension of time for
paying tax.
(a)In general—(1)Tax shown or re-
quired to be shown on return.The Inter-
nal Revenue Service may, at the request of
the taxpayer, grant a reasonable exten-
sion of time for payment of the amount of
any tax imposed by chapter 55 (Struc-
tured Settlement Factoring Transactions) of
the Internal Revenue Code (chapter 55) and
shown or required to be shown on any re-
turn. The period of such extension shall not
2003–10 I.R.B.567March 10, 2003

exceed 6 months from the date fixed for
payment of such tax, except that in the case
of a taxpayer that is abroad, such exten-
sion may exceed 6 months.
(2)Extension of time for filing distin-
guished.The granting of an extension of
time for filing a return does not extend the
time for the payment of the tax or any part
thereof unless so specified in the exten-
sion.
(b)Certain rules relating to extension of
time for paying income tax to apply.The
provisions of§1.6161–1(b), (c), and (d) of
this chapter (relating to a requirement for
undue hardship, to the application for ex-
tension, and to payment pursuant to an ex-
tension) shall apply to extensions of time
for payment of the tax imposed by chap-
ter 55 of the Internal Revenue Code.
§157.6165–1T Bonds where time to pay
tax has been extended.
If an extension of time for payment is
granted under section 6161, the Internal
Revenue Service may, if it deems neces-
sary, require a bond for the payment, in ac-
cordance with the terms of the extension,
of the amount with respect to which the ex-
tension is granted. However, the bond shall
not exceed double the amount with re-
spect to which the extension is granted. For
provisions relating to the form of bonds, see
the regulations under section 7101 con-
tained in part 301 (Regulations on Proce-
dure and Administration) of this chapter.
PART 602—OMB CONTROL
NUMBERS UNDER THE
PAPERWORK REDUCTION ACT
Par. 2. The authority citation for part 602
continues to read as follows:
Authority: 26 U.S.C. 7805.
Par.3.In§602.101, paragraph (b) is
amended by adding entries in numerical or-
der to the table as follows:
§602.101 OMB control numbers.
*****
(b)***
CFR part or section where
identified and described
Current OMB
control No.
*****
157.6001–1T ...............................................................................................................................................................1545–1824
157.6011–1T ...............................................................................................................................................................1545–1824
157.6081–1T ...............................................................................................................................................................1545–1824
157.6161–1T ...............................................................................................................................................................1545–1824
*****
David A. Mader,
Assistant Deputy Commissioner
of Internal Revenue.
Approved December 17, 2002.
Pamela F. Olson,
Assistant Secretary of the Treasury.
(Filed by the Office of the Federal Register on February 18,
2003, 8:45 a.m., and published in the issue of the Federal Reg-
ister for February 19, 2003, 68 F.R. 7922)
Section 6001.—Notice or
Regulations Requiring
Records, Statements, and
Special Returns
26 CFR 157.6001–1T: Records, statements, and
special returns.
Rules are provided regarding the recordkeeping re-
quirements imposed on any person subject to tax un-
der chapter 55 (regarding structured settlement
factoring transactions) of the Code. See T.D. 9042,
page 564.
26 CFR 1.6001: Records.
Family day care providers may use optional stan-
dard meal and snack rates to compute the deduct-
ible cost of food provided to eligible children in the
day care in lieu of maintaining records to substanti-
ate actual cost. Family day care providers who use the
standard meal and snack rates should maintain records
that include the name of each eligible child, dates and
hours of attendance in the family day care, and the
type and quantity of meals and snacks served, and may
use the meal and snack log provided. See Rev. Proc.
2003–22, page 577.
Section 6011.—General Re-
quirement of Return, State-
ment, or List
26 CFR 157.6011–1T: General requirement of re-
turn, statement, or list.
Rules are provided under which every person li-
able for the 40-percent excise tax under section 5891
of the Code (regarding structured settlement factor-
ing transactions) must file a return with respect to such
tax. See T.D. 9042, page 564.
26 CFR 301.6011–1: General requirement of re-
turn, statement or list.
T.D. 9040
DEPARTMENT OF THE
TREASURY
Internal Revenue Service
26 CFR Parts 1, 301 and 602
Guidance Necessary to
Facilitate Electronic Tax
Administration
AGENCY: Internal Revenue Service (IRS),
Treasury.
ACTION: Final and removal of tempo-
rary regulations.
SUMMARY: This document contains fi-
nal regulations that eliminate regulatory im-
pediments to the electronic filing of Form
1040,U.S. Individual Income Tax Return.
These regulations affect taxpayers who file
Form 1040 and who are required to file any
of the following forms: Form 56,Notice
Concerning Fiduciary Relationship; Form
March 10, 20035682003–10 I.R.B.

2120,Multiple Support Declaration; Form
2439,Notice to Shareholder of Undistrib-
uted Long-Term Capital Gains; Form 3468,
Investment Credit; and Form T (Timber),
Forest Activities Schedules.
DATES: EFFECTIVE DATE: These regu-
lations are effective January 31, 2003.
FOR FURTHER INFORMATION CON-
TACT: Joseph P. Dewald, (202) 622–4910
(not a toll-free number).
SUPPLEMENTARY INFORMATION:
Paperwork Reduction Act
The collection of information contained
in these final regulations has been reviewed
and approved by theOffice of Manage-
ment and Budgetin accordance with the
Paperwork Reduction Act of 1995 (44
U.S.C. 3507(d)) under control number
1545–1783. The collection of informa-
tion in these final regulations is in§§1.48–
12(d)(7)(iv), 1.152–3(c), 1.611–3(h), 1.852–
9(c)(1), and 301.6903–1(b). Responses to
this collection of information are manda-
tory.
An agency may not conduct or spon-
sor, and a person is not required to re-
spond to, a collection of information unless
the collection of information displays a valid
control number assigned by theOffice of
Management and Budget.
The estimated additional burden in fi-
nal regulations§§1.611–3(h), 1.852–9(c)(1),
and 301.6903–1(b) is 0 hours because the
records that are required to be maintained
were previously required to be maintained
to document the reporting requirements.
This reporting burden will be reflected in
the burden estimate for Form T (Timber),
Form 2439, and Form 56, respectively.
Estimated additional total annual report-
ing burden for 2002 for Form 3468: 376
hours.
Estimated number of responses for 2002
for Form 3468: 22,575.
Estimated additional average annual bur-
den hours per response for 2002 for Form
3468: 1 minute.
Estimated additional total annual report-
ing burden for 2002 for Form 2120: 550
hours.
Estimated number of responses for 2002
for Form 2120: 11,000.
Estimated additional average annual bur-
den hours per response for 2002 for Form
2120: 3 minutes.
The estimated additional reporting bur-
den for the reporting in final regulations
§§1.48–12(d)(7)(iv) and 1.152–3(c) will be
reflected in the burden estimate for Form
3468 and Form 2120, respectively.
Comments concerning the accuracy of
this burden estimate and suggestions for re-
ducing this burden should be sent to the In-
ternal Revenue Service, Attn: IRS Reports
Clearance Officer, W:CAR:MP:FP:S, Wash-
ington, DC 20224, and to theOffice of
Management and Budget, Attn: Desk Of-
ficer for the Department of the Treasury, Of-
fice of Information and Regulatory Affairs,
Washington, DC 20503.
Books or records relating to a collec-
tion of information must be retained as long
as their contents may become material in
the administration of any internal revenue
law. Generally, tax returns and tax return
information are confidential, as required by
26 U.S.C. 6103.
Background
This document contains amendments to
the Income Tax Regulations (26 CFR part
1) and the Procedure and Administration
Regulations (26 CFR part 301) designed to
eliminate regulatory impediments to the
electronic filing of Form 1040.
In 1998, Congress enacted the Internal
Revenue Service Restructuring and Re-
form Act of 1998 (RRA 1998), Public Law
105–206 (112 Stat. 685) (1998). Section
2001(a) of RRA 1998 states that the policy
of Congress is that paperless filing should
be the preferred and most convenient means
of filing Federal tax returns. Section 2001(a)
of RRA 1998 also sets a long-range goal
for the IRS to have at least 80 percent of
all federal tax returns filed electronically by
2007. Section 2001(b) of RRA 1998 re-
quires the IRS to establish a 10-year stra-
tegic plan to eliminate barriers to electronic
filing. On April 24, 2002, the IRS pub-
lished temporary regulations (T.D. 8989,
2002–20 I.R.B. 920 [67 FR 20028]) and a
cross-reference notice of proposed rule-
making (REG–107184–00, 2002–20 I.R.B.
967 [67 FR 20072]) to facilitate the imple-
mentation of this plan by eliminating regu-
latory impediments to the electronic filing
of Form 1040.
The temporary regulations amended the
Procedure and Administration Regulations
to provide a regulatory statement of IRS au-
thority to prescribe what return informa-
tion or documentation must be filed with
a return, statement, or other document re-
quired to be made under any provision of
the internal revenue laws or regulations. The
regulations give the IRS maximum flex-
ibility in prescribing (1) what needs to be
filed in support of a return or claim, and (2)
the form of the filing,e.g., electronic ver-
sus paper. The regulations permit the IRS
to prescribe required return information in
forms, instructions, or other appropriate
guidance.
In addition, the IRS identified five regu-
latory provisions that impede electronic fil-
ing by requiring the taxpayer to either
include a third-party signature, or attach a
document generated by a third party. The
temporary regulations amended those pro-
visions to eliminate the impediments.
No written comments were received in
response to the cross-reference notice of
proposed rulemaking and no public hear-
ing was requested or held.
Explanation of Provisions
This Treasury decision removes the tem-
porary regulations and adopts the proposed
regulations with minor clarifications ex-
plained below.
These final regulations clarify how to
“file”a written declaration waiving the de-
pendency deduction under section 152(c)(4).
Section 1.152–3(a)(4) of the existing regu-
lations provides that each person waiving
the deduction should“file”a written dec-
laration stating that the person waiving the
deduction will not claim the individual as
a dependent. However, the term“file”is
confusing because it usually refers to a sub-
mission to the IRS. These final regula-
tions amend section 1.152–3(a)(4) to
provide that each person waiving the de-
duction should“furnish”a written waiver
declaration to the taxpayer claiming the de-
duction.
Section 1.152–3(b) of the existing regu-
lations provides two examples explaining
the requirements in section 1.152–3(a). The
examples require that the written declara-
tions furnished by each person waiving the
deduction be attached to the income tax re-
turn of the taxpayer. These final regula-
tions update the examples by removing the
requirement that the waivers be attached to
the taxpayer’s return. The amended regu-
lations require the taxpayer to retain the
waivers consistent with section 1.152–
3(c).
2003–10 I.R.B.569March 10, 2003

Under section 1.152–3(c)(3) of the pro-
posed regulations, the taxpayer claiming the
individual as a dependent must retain the
declarations furnished by the persons waiv-
ing the deduction. Section 1.152–3(c)(3) of
the proposed regulations also provides that
the IRS may request other information from
the taxpayer to substantiate the depen-
dency claim. The proposed regulation then
states that the other information that will
substantiate the claim may include a state-
ment showing the names of all contribu-
tors and the amount contributed by each.
These final regulations clarify that the state-
ment is just one of many pieces of infor-
mation that the IRS may request to
substantiate the dependency claim. No one
statement or piece of information is nec-
essarily determinative.
Special Analyses
It has been determined that this Trea-
sury decision is not a significant regula-
tory action 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
Procedure Act (5 U.S.C. chapter 5) does not
apply to these regulations. It is hereby cer-
tified that the collection of information in
these regulations will not have a signifi-
cant economic impact on a substantial num-
ber of small entities. This certification is
based upon the fact that the persons re-
sponsible for recordkeeping are princi-
pally individuals, and the burden is not
significant as described earlier in the pre-
amble. Therefore, a Regulatory Flexibil-
ity Analysis under the Regulatory Flexibility
Act (5 U.S.C. chapter 6) is not required.
Pursuant to section 7805(f) of the Inter-
nal Revenue Code, the notice of proposed
rulemaking preceding these regulations was
submitted to the Chief Counsel for Advo-
cacy of the Small Business Administra-
tion for comment on their impact on small
business.
Drafting Information
The principal author of these regula-
tions is Joseph P. Dewald, Office of Asso-
ciate Chief Counsel (Procedure and
Administration), Administrative Provi-
sions and Judicial Practice Division. How-
ever, other personnel from the IRS and the
Treasury Department participated in the de-
velopment of the regulations.
*****
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR parts 1, 301, and
602 are amended as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 is amended as follows:
Authority: 26 U.S.C. 7805***
Par. 2. Section 1.48–12 is amended as
follows:
1. Revising paragraph (d)(7)(iii).
2. Adding a new paragraph (d)(7)(iv).
§1.48–12 Qualified rehabilitated
building; expenditures incurred after
December 31, 1981.
*****
(d)***
(7)***
(iii)Effective dates.Paragraph (d)(7)(i)
of this section applies to returns for tax-
able years beginning before January 1,
2002. The requirement in the fourth sen-
tence of paragraph (d)(7)(ii) of this sec-
tion applies only if the first income tax
return filed after receipt by the taxpayer of
the certification is for a taxable year be-
ginning before January 1, 2002. For rules
applicable to returns for taxable years be-
ginning after December 31, 2001, see para-
graph (d)(7)(iv) of this section.
(iv)Returns for taxable years begin-
ning after December 31, 2001—(A)In gen-
eral.Except as otherwise provided in
paragraph (d)(7)(ii) of this section and this
paragraph (d)(7)(iv), a taxpayer claiming the
credit for rehabilitation of a certified his-
toric structure (within the meaning of sec-
tion 47(c)(3) and paragraph (d)(1) of this
section) for a taxable year beginning af-
ter December 31, 2001, must provide with
the return for the taxable year in which the
credit is claimed, the NPS project num-
ber assigned by, and the date of the final
certification of completed work received
from, the Secretary of the Interior. If a credit
(including a credit for a taxable year be-
ginning before January 1, 2002) is claimed
under the late certification procedures of
paragraph (d)(7)(ii) of this section and the
first income tax return filed by the tax-
payer after receipt of the certification is for
a taxable year beginning after December 31,
2001, the taxpayer must provide the NPS
project number assigned by, and the date
of the final certification of completed work
received from, the Secretary of the Inte-
rior with that return.
(B)Reporting and recordkeeping re-
quirements.The information required un-
der paragraph (d)(7)(iv)(A) of this section
must be provided on Form 3468 (or its suc-
cessor) filed with the taxpayer’s return. In
addition, the taxpayer must retain a copy
of the final certification of completed work
for as long as its contents may become ma-
terial in the administration of any internal
revenue law.
(C)Passthrough entities.In the case of
a credit for qualified rehabilitation expen-
ditures of a partnership, S corporation, es-
tate, or trust, the requirements of this
paragraph (d)(7)(iv) apply only to the en-
tity. Each partner, shareholder or benefi-
ciary claiming a credit for such qualified
rehabilitationexpendituresfroma
passthrough entity must, however, pro-
vide the employer identification number of
the entity on Form 3468 (or its succes-
sor).
§1.48–12T [Removed]
Par. 3. Section 1.48–12T is removed.
Par.4.In§1.152–3, paragraphs (a)(4)
and (b) are revised and paragraph (c) is
added to read as follows:
§1.152–3 Multiple support agreements.
(a)***
(4) Each other person in the group who
contributed more than 10 percent of such
support furnishes to the taxpayer claim-
ing the dependent a written declaration that
such other person will not claim the indi-
vidual as a dependent for any taxable year
beginning in such calendar year.
(b)Examples.Application of the rule
contained in paragraph (a) of this section
may be illustrated by the following
examples:
March 10, 20035702003–10 I.R.B.

Example (1).During the taxable year, brothers A,
B, C, and D contributed the entire support of their
mother in the following percentages: A, 30 percent;
B, 20 percent; C, 29 percent; and D, 21 percent. Any
one of the brothers, except for the fact that he did not
contribute more than half of her support, would have
been entitled to claim his mother as a dependent. Con-
sequently, any one of the brothers could claim a de-
duction for the exemption of the mother if he obtained
a written declaration (as provided in paragraph (a)(4)
of this section) from each of the other brothers. Even
though A and D together contributed more than one-
half the support of the mother, A, if he wished to claim
his mother as a dependent, would be required to ob-
tain written declarations from B, C, and D, since each
of those three contributed more than 10 percent of the
support and, but for the failure to contribute more than
half of the mother’s support, would have been en-
titled to claim his mother as a dependent.
Example (2).During the taxable year, E, an indi-
vidual who resides with his son, S, received his en-
tire support for that year as follows:
SourcePercentage of
Total
Social Security ......................................................................................................................................................25
N, an unrelated neighbor......................................................................................................................................11
B, a brother ...........................................................................................................................................................14
D, a daughter ........................................................................................................................................................10
S, a son .................................................................................................................................................................40
Total received by E ..........................................................................................................................100
B, D, and S are persons each of whom, but for the
fact that none contributed more than half of E’s sup-
port, could claim E as a dependent for the taxable year.
The three together contributed 64 percent of E’s sup-
port, and, thus, each is a member of the group to be
considered for the purpose of section 152(c). B and
S are the only members of such group who can meet
all the requirements of section 152(c), and either one
could claim E as a dependent for his taxable year if
he obtained a written declaration (as provided in para-
graph (a)(4) of this section) signed by the other, and
furnished the other information required by the re-
turn with respect to all the contributions to E. Inas-
much as D did not contribute more than 10 percent
of E’s support, she is not entitled to claim E as a de-
pendent for the taxable year nor is she required to fur-
nish a written declaration with respect to her
contributions to E. N contributed over 10 percent of
the support of E, but, since he is an unrelated neigh-
bor, he does not qualify as a member of the group for
the purpose of the multiple support agreement un-
der section 152(c).
(c)(1) The member of a group of con-
tributors who claims an individual as a de-
pendent for a taxable year beginning before
January 1, 2002, under the multiple sup-
port agreement provisions of section 152(c)
must attach to the member’s income tax re-
turn for the year of the deduction a writ-
ten declaration from each of the other
persons who contributed more than 10 per-
cent of the support of such individual and
who, but for the failure to contribute more
than half of the support of the individual,
would have been entitled to claim the in-
dividual as a dependent.
(2) The taxpayer claiming an individual
as a dependent for a taxable year begin-
ning after December 31, 2001, under the
multiple support agreement provisions of
section 152(c) must provide with the in-
come tax return for the year of the
deduction—
(i) A statement identifying each of the
other persons who contributed more than
10 percent of the support of the individual
and who, but for the failure to contribute
more than half of the support of the indi-
vidual, would have been entitled to claim
the individual as a dependent; and
(ii) A statement indicating that the tax-
payer obtained a written declaration from
each of the persons described in section
152(c)(2) waiving the right to claim the in-
dividual as a dependent.
(3) The taxpayer claiming the individual
as a dependent for a taxable year begin-
ning after December 31, 2001, must re-
tain the waiver declarations and should be
prepared to furnish the waiver declara-
tions and any other information neces-
sary to substantiate the claim, which may
include a statement showing the names of
all contributors (whether or not members
of the group described in section 152(c)(2))
and the amount contributed by each to the
support of the claimed dependent.
§1.152–3T [Removed]
Par. 5. Section 1.152–3T is removed.
Par.6.In§1.611–3, paragraph (h) is
added to read as follows:
§1.611–3 Rules applicable to timber.
*****
(h)Reporting and recordkeeping
requirements—(1)Taxable years begin-
ning before January 1, 2002.A taxpayer
claiming a deduction for depletion of tim-
ber for a taxable year beginning before
January 1, 2002, shall attach to the in-
come tax return of the taxpayer a filled-
out Form T (Timber) for the taxable year
covered by the income tax return, includ-
ing the following information—
(i) A map where necessary to show
clearly timber and land acquired, timber cut,
and timber and land sold;
(ii) Description of, cost of, and terms of
purchase of timberland or timber, or cut-
ting rights, including timber or timber rights
acquired under any type of contract;
(iii) Profit or loss from sale of land, or
timber, or both;
(iv) Description of timber with respect
to which claim for loss, if any, is made;
(v) Record of timber cut;
(vi) Changes in each timber account as
a result of purchase, sale, cutting, reesti-
mate, or loss;
(vii) Changes in improvements accounts
as the result of additions to or deductions
from capital and depreciation, and compu-
tation of profit or loss on sale or other dis-
position of such improvements;
(viii) Operation data with respect to raw
and finished material handled and inven-
toried;
(ix) Statement as to application of the
election under section 631(a) and perti-
nent information in support of the fair mar-
ket value claimed thereunder;
(x) Information with respect to land
ownership and capital investment in tim-
berland; and
(xi) Any other data which will be help-
ful in determining the reasonableness of the
depletion or depreciation deductions claimed
in the return.
(2)Taxable years beginning after De-
cember 31, 2001.A taxpayer claiming a de-
2003–10 I.R.B.571March 10, 2003

duction for depletion of timber on a return
filed for a taxable year beginning after De-
cember 31, 2001, shall attach to the in-
come tax return of the taxpayer a filled-
out Form T (Timber) for the taxable year
covered by the income tax return. In ad-
dition, the taxpayer must retain records suf-
ficient to substantiate the right of the
taxpayer to claim the deduction, includ-
ing a map, where necessary, to show clearly
timber and land acquired, timber cut, and
timber and land sold for as long as their
contents may become material in the ad-
ministration of any internal revenue law.
§1.611–3T [Removed]
Par. 7. Section 1.611–3T is removed.
Par.8.In§1.852–9, paragraph (c)(1) is
added to read as follows:
§1.852–9 Special procedural
requirements applicable to designation
under section 852(b)(3)(D).
*****
(c)Shareholders—(1)Return and
Recordkeeping Requirements—(i)Return re-
quirements for taxable years beginning be-
fore January 1, 2002.For taxable years
beginning before January 1, 2002, the copy
B of Form 2439 furnished to a shareholder
by the regulated investment company or by
a nominee, as provided in§1.852–9(a) or
(b) shall be attached to the income tax re-
turn of the shareholder for the taxable year
in which the amount of undistributed capi-
tal gains is includible in gross income as
provided in§1.852–4(b)(2).
(ii)Recordkeeping requirements for tax-
able years beginning after December 31,
2001.For taxable years beginning after De-
cember 31, 2001, the shareholder shall re-
tain a copy of Form 2439 for as long as its
contents may become material in the ad-
ministration of any internal revenue law.
*****
§1.852–9T [Removed]
Par. 9. Section 1.852–9T is removed.
PART 301—PROCEDURE AND
ADMINISTRATION
Par. 10. The authority citation for part
301 continues to read as follows:
Authority: 26 U.S.C. 7805***
Par. 11. Section 301.6011–1 is added to
read as follows:
§301.6011–1 General requirement of
return, statement or list.
(a) For provisions requiring returns, state-
ments, or lists, see the regulations relat-
ing to the particular tax.
(b) The Internal Revenue Service may
prescribe in forms, instructions, or other ap-
propriate guidance the information or docu-
mentation required to be included with any
return or any statement required to be made
or other document required to be furnished
under any provision of the internal rev-
enue laws or regulations.
§301.6011–1T [Removed]
Par. 12. Section 301.6011–1T is re-
moved.
Par. 13. In§301.6903–1, paragraph (b)
is added to read as follows:
§301.6903–1 Notice of fiduciary
relationship.
*****
(b)Manner of notice—(1)Notices filed
before April 24, 2002.This paragraph (b)(1)
applies to notices filed before April 24,
2002. The notice shall be signed by the fi-
duciary, and shall be filed with the Inter-
nal Revenue Service office where the return
of the person for whom the fiduciary is act-
ing is required to be filed. The notice must
state the name and address of the person for
whom the fiduciary is acting, and the na-
ture of the liability of such person; that is,
whether it is a liability for tax, and, if so,
the type of tax, the year or years involved,
or a liability at law or in equity of a trans-
feree of property of a taxpayer, or a liabil-
ity of a fiduciary under section 3467 of the
Revised Statutes, as amended (31 U.S.C.
192) in respect of the payment of any tax
from the estate of the taxpayer. Satisfac-
tory evidence of the authority of the fidu-
ciary to act for any other person in a
fiduciary capacity must be filed with and
made a part of the notice. If the fiduciary
capacity exists by order of court, a certi-
fied copy of the order may be regarded as
satisfactory evidence. When the fiduciary
capacity has terminated, the fiduciary, in or-
der to be relieved of any further duty or li-
ability as such, must file with the Internal
Revenue Service office with whom the no-
tice of fiduciary relationship was filed writ-
ten notice that the fiduciary capacity has
terminated as to him, accompanied by sat-
isfactory evidence of the termination of the
fiduciary capacity. The notice of termina-
tion should state the name and address of
the person, if any, who has been substi-
tuted as fiduciary. Any written notice dis-
closing a fiduciary relationship which has
been filed with the Commissioner under the
Internal Revenue Code of 1939 or any prior
revenue law shall be considered as suffi-
cient notice within the meaning of sec-
tion 6903. Any satisfactory evidence of the
authority of the fiduciary to act for an-
other person already filed with the Com-
missioner or district director need not be
resubmitted.
(2)Notices filed on or after April 24,
2002.This paragraph (b)(2) applies to no-
tices filed on or after April 24, 2002. The
notice shall be signed by the fiduciary, and
shall be filed with the Internal Revenue Ser-
vice Center where the return of the per-
son for whom the fiduciary is acting is
required to be filed. The notice must state
the name and address of the person for
whom the fiduciary is acting, and the na-
ture of the liability of such person; that is,
whether it is a liability for tax, and if so,
the type of tax, the year or years involved,
or a liability at law or in equity of a trans-
feree of property of a taxpayer, or a liabil-
ity of a fiduciary under 31 U.S.C. 3713(b),
in respect of the payment of any tax from
the estate of the taxpayer. The fiduciary
must retain satisfactory evidence of his or
her authority to act for any other person in
a fiduciary capacity as long as the evi-
dence may become material in the admin-
istration of any internal revenue law.
*****
§301.6903–1T [Removed]
Par. 14. Section 301.6903–1T is re-
moved.
PART 602—OMB CONTROL
NUMBERS UNDER THE
PAPERWORK REDUCTION ACT
Par. 15. The authority citation for part
602 continues to read as follows:
Authority: 26 U.S.C. 7805.
Par. 16. In§602.101, paragraph (b), the
table is amended as follows:
1. The following entries are removed:
§602.101 OMB Control numbers.
*****
(b)***
March 10, 20035722003–10 I.R.B.

CFR part or section where
identified and described
Current OMB
control No.
*****
1.48–12T .....................................................................................................................................................................1545–0155
1545–1783
*****
1.152–3T .....................................................................................................................................................................1545–0071
1545–1783
*****
1.611–3T .....................................................................................................................................................................1545–0007
1545–0099
1545–1784
*****
1.852–9T .....................................................................................................................................................................1545–0074
1545–0123
1545–0144
1545–0145
1545–1783
*****
301.6903–1T ...............................................................................................................................................................1545–0013
1545–1783
*****
2. The following entries are revised:§602.101 OMB Control numbers.
*****
(b)***
CFR part or section where
identified and described
Current OMB
control No.
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1.48–12........................................................................................................................................................................1545–0155
1545–1783
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1.152–3........................................................................................................................................................................1545–0071
1545–1783
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1.611–3 ........................................................................................................................................................................1545–0007
1545–0099
1545–1784
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1.852–9........................................................................................................................................................................1545–0074
1545–0123
1545–0144
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301.6903–1..................................................................................................................................................................1545–0013
1545–1783
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2003–10 I.R.B.573March 10, 2003

David A. Mader,
Assistant Deputy Commissioner
of Internal Revenue.
Approved January 14, 2003.
Pamela F. Olson,
Assistant Secretary of the Treasury.
(Filed by the Office of the Federal Register on January 30,
2003, 8:45 a.m., and published in the issue of the Federal Reg-
ister for January 31, 2003, 68 F.R. 4918)
Section 6061.—Signing of
Returns and Other Documents
26 CFR 157.6061–1T: Signing of returns and other
documents.
Rules are provided for the manner and method of
paying and reporting the non-deductible 40-percent ex-
cise tax imposed on any person who acquires struc-
tured settlement payment rights in a structured
settlement factoring transaction. See T.D. 9042, page
564.
Section 6065.—Verification
of Returns
26 CFR 157.6065–1T: Verification of returns.
Rules are provided for the manner and method of
paying and reporting the non-deductible 40-percent ex-
cise tax imposed on any person who acquires struc-
tured settlement payment rights in a structured
settlement factoring transaction. See T.D. 9042, page
564.
Section 6071.—Time for Fil-
ing Returns and Other Docu-
ments
26 CFR 157.6071–1T: Time for filing returns relat-
ing to structured settlement factoring transactions.
Rules are provided regarding the time for filing
returns relating to the 40-percent excise tax under sec-
tion 5891 of the Code (regarding structured settle-
ment factoring transactions). See T.D. 9042, page 564.
Section 6081.—Extension of
Time for Filing Returns
26 CFR 157.6081–1T: Extension of time for filing
the return.
Rules are provided regarding extensions of time
for filing returns relating to the 40-percent excise tax
under section 5891 of the Code (regarding struc-
tured settlement factoring transactions). See T.D. 9042,
page 564.
Section 6091.—Place for Fil-
ing Returns or Other Docu-
ments
26 CFR 157.6091–1T: Place for filing returns.
Rules are provided regarding the place for filing
returns relating to the 40-percent excise tax under sec-
tion 5891 of the Code (regarding structured settle-
ment factoring transactions). See T.D. 9042, page 564.
Section 6151.—Time and
Place for Paying Tax Shown
on Returns
26 CFR 157.6151–1T: Time and place for paying
tax shown on returns.
Rules are provided regarding the time and man-
ner for paying the 40-percent excise tax imposed un-
der section 5891 of the Code (regarding structured
settlement factoring transactions). See T.D. 9042, page
564.
Section 6161.—Extension of
Time for Paying Tax
26 CFR 157.6161–1T: Extension of time for paying
tax.
Rules are provided regarding extensions of time
for paying the 40-percent excise tax under section 5891
of the Code (regarding structured settlement factor-
ing transactions). See T.D. 9042, page 564.
Section 6165.—Bonds Where
Time to Pay Tax or Deficiency
Has Been Extended
26 CFR 157.6165–1T: Bonds where time to pay tax
has been extended.
Rules are provided for the manner and method of
paying and reporting the non-deductible 40-percent ex-
cise tax imposed on any person who acquires struc-
tured settlement payment rights in a structured
settlement factoring transaction. See T.D. 9042, page
564.
Section 7520.—Valuation
Tables
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of March 2003. See Rev. Rul. 2003–26, page 563.
Section 7872.—Treatment of
Loans With Below-Market In-
terest Rates
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of March 2003. See Rev. Rul. 2003–26, page 563.
March 10, 20035742003–10 I.R.B.

Part III. Administrative, Procedural, and Miscellaneous
2003 Calendar Year Resident
Population Estimates
Notice 2003–16
This notice informs (1) state and local
housing credit agencies that allocate low-
income housing tax credits under§42 of
the Internal Revenue Code and (2) states
and other issuers of tax-exempt private ac-
tivity bonds under§141, of the proper
population figures to be used for calculat-
ing the 2003 calendar year population-
based component of the state housing credit
ceiling(CreditCeiling)under
§42(h)(3)(C)(ii), the 2003 calendar year
volume cap (Volume Cap) under§146, and
the 2003 volume limit (Volume Limit) un-
der§142(k)(5).
The population figures both for the
population-based component of the Credit
Ceiling and for the Volume Cap are deter-
mined by reference to§146(j). That sec-
tion provides generally that determinations
of population for any calendar year are
made on the basis of the most recent cen-
sus estimate of the resident population of
a state (or issuing authority) released by the
Bureau of the Census before the begin-
ning of such calendar year. Section
142(k)(5) provides that the Volume Limit
is based on the State population.
The population-based component of the
Credit Ceiling and the Volume Cap are ad-
justedforinflationpursuantto
§§42(h)(3)(H) and 146(d)(2), respectively.
The adjustments for the 2003 calendar year
were published in Rev. Proc. 2002–70,
2002–46 I.R.B. 845. Section 3.07 of Rev.
Proc. 2002–70 provides that, for calendar
years beginning in 2003, the amounts used
under§42(h)(3)(C)(ii) to calculate the
Credit Ceiling is the greater of $1.75 mul-
tiplied by the State population (see the resi-
dent population figures provided below) or
$2,030,000. Further, section 3.14 of Rev.
Proc. 2002–70 provides that the amounts
used under§146(d)(1) to calculate the Vol-
ume Cap for calendar year 2003 is the
greater of $75 multiplied by the State popu-
lation (see the resident population figures
provided below) or $228,580,000.
The proper population figures for cal-
culating the Credit Ceiling, the Volume Cap,
and the Volume Limit for the 2003 calen-
dar year are the estimates of the resident
population of the 50 states, the District of
Columbia, and Puerto Rico released by the
Bureau of the Census on December 20,
2002, in Press Release CB02–168. The
proper population figures for calculating the
Credit Ceiling, the Volume Cap, and the
Volume Limit for the 2003 calendar year
for the insular areas (American Samoa,
Guam, Northern Mariana Islands, and U.S.
Virgin Islands) are the figures released by
the Bureau of the Census on July 3, 2001,
in press release CB01–CN.1. For conve-
nience, these estimates are reprinted be-
low.
Resident Population Figures
Alabama4,486,508
Alaska643,786
American Samoa57,291
Arizona5,456,453
Arkansas2,710,079
California35,116,033
Colorado4,506,542
Connecticut3,460,503
Delaware807,385
D.C.570,898
Florida16,713,149
Georgia8,560,310
Guam154,805
Hawaii1,244,898
Idaho1,341,131
Illinois12,600,620
Indiana6,159,068
Iowa2,936,760
2003–10 I.R.B.575March 10, 2003

Resident Population Figures
Kansas2,715,884
Kentucky4,092,891
Louisiana4,482,646
Maine1,294,464
Maryland5,458,137
Massachusetts6,427,801
Michigan10,050,446
Minnesota5,019,720
Mississippi2,871,782
Missouri5,672,579
Montana909,453
Nebraska1,729,180
Nevada2,173,491
New Hampshire1,275,056
New Jersey8,590,300
New Mexico1,855,059
New York19,157,532
North Carolina8,320,146
North Dakota634,110
Northern Mariana Islands69,221
Ohio11,421,267
Oklahoma3,493,714
Oregon3,521,515
Pennsylvania12,335,091
Puerto Rico3,858,806
Rhode Island1,069,725
South Carolina4,107,183
South Dakota761,063
Tennessee5,797,289
Texas21,779,893
U.S. Virgin Islands108,612
Utah2,316,256
Vermont616,592
Virginia7,293,542
Washington6,068,996
West Virginia1,801,873
Wisconsin5,441,196
Wyoming498,703
March 10, 20035762003–10 I.R.B.

The principal authors of this notice are
Christopher J. Wilson, Office of the Asso-
ciate Chief Counsel (Passthroughs and Spe-
cial Industries) and Timothy L. Jones, Office
of the Division Counsel/Associate Chief
Counsel (Tax-Exempt and Government En-
tities). For further information regarding this
notice, contact Mr. Wilson at (808) 539–
2874 or Susan Reaman at (202) 622–3040
(not toll-free calls).
26 CFR 601.105: Examination of returns and
claims for refund, credit, or abatement; determina-
tion of correct tax liability.
(Also Part I,§§162, 6001, 1.6001–1.)
Rev. Proc. 2003–22
SECTION 1. PURPOSE
This revenue procedure provides tax-
payers engaged in the trade or business of
providing family day care with optional
standard meal and snack rates to use in
computing the deductible cost of food pro-
vided to eligible children receiving care
from family day care providers.
SECTION 2. BACKGROUND
.01 Section 162(a) of the Internal Rev-
enue Code allows a deduction for ordi-
nary and necessary expenses paid or
incurred during the taxable year in carry-
ing on a trade or business. Under this sec-
tion, family day care providers may deduct
the cost of food provided to eligible chil-
dren in the family day care. For family day
care providers who receive reimbursements
from a sponsor under the Child and Adult
Care Food Program (CACFP) of the De-
partment of Agriculture, only the portion of
the cost of food, if any, that exceeds the re-
imbursements is deductible. Under§262,
however, no portion of the cost of food pro-
vided to the family day care provider’s fam-
ily, including food consumed by the
provider or the provider’s own children, is
deductible.
.02 Section 6001 provides that every per-
son liable for federal income tax shall keep
such records and comply with such rules
as the Commissioner of Internal Revenue
prescribes. Section 1.6001–1(a) of the In-
come Tax Regulations provides that ev-
ery person must keep records to substantiate
the amount of any deduction.
.03 Section 7602(a) provides that the
Commissioner may examine any books, pa-
pers, records, or other data that may be rel-
evant to ascertaining the correctness of any
return, making a return where none has
been made, or determining the liability of
any person for any internal revenue tax.
.04 Under§§162 and 6001, family day
care providers must keep records that sub-
stantiate deductions for food provided to eli-
gible children in the family day care.
Because family day care providers often
purchase food that is used for their own
families as well as in carrying on their fam-
ily day care business, they may have dif-
ficulty substantiating the portion of the cost
of food that is attributable to their family
day care business. Additionally, it is bur-
densome for family day care providers to
keep receipts for all food purchased dur-
ing the taxable year for both the family day
care and their own family’s personal use.
To minimize disputes concerning the records
family day care providers must keep to sub-
stantiate their deductible food cost, and to
reduce burden by eliminating the need to
keep all receipts for food purchased dur-
ing the taxable year, the Internal Revenue
Service will permit family day care pro-
viders to use the standard meal and snack
rates provided in this revenue procedure to
compute the deductible cost of food in lieu
of using actual costs. A family day care pro-
vider who complies with all the provi-
sions of this revenue procedure will be
deemed to meet the substantiation require-
ments of§6001 and the regulations there-
under for the purpose of computing the
deductible cost of food provided to eli-
gible children in the family day care.
SECTION 3. SCOPE
This revenue procedure applies to any
family day care provider, whether or not li-
censed, registered, or otherwise regulated
by the state or locality in which the fam-
ily day care operates, who chooses to use
the standard meal and snack rates pro-
vided in this revenue procedure to substan-
tiate the deductible cost of meals and snacks
provided to eligible children in the fam-
ily day care.
SECTION 4. DEFINITIONS
.01Family Day Care Provider.A fam-
ily day care provider is a taxpayer en-
gaged in the trade or business of providing
family day care.
.02Family Day Care.Family day care
is child care provided to eligible children
in the home of the family day care pro-
vider that is (1) non-medical, (2) does not
involve a transfer of legal custody, and (3)
generally lasts for less than 24 hours each
day.
.03Eligible Children.Except as other-
wise provided in this section, eligible chil-
dren are unemancipated minors receiving
family day care in the home of the fam-
ily day care provider. Eligible children do
not include children who are full-time or
part-time residents in the home in which the
child care is provided or children whose
parent(s) or guardian(s) are residents of the
same home. For example, a family day care
provider’s own children, and any chil-
dren who live in the family day care pro-
vider’s home on a full or part-time basis,
are not eligible children even if they re-
ceive day care services from the family day
care provider. Eligible children do not in-
clude children who receive day care ser-
vices for personal reasons of the family day
care provider. For example, if a family day
care provider provides day care services for
the provider’s sister’s child as a favor to the
sister, that child is not an eligible child
within the meaning of this revenue proce-
dure.
SECTION 5. APPLICATION
.01In General.Family day care pro-
viders may compute the deductible cost of
each meal and snack actually purchased and
served to an eligible child during the time
period when family day care is provided by
using the standard meal and snack rates pro-
vided in section 5.04 of this revenue pro-
cedure. A family day care provider may use
the standard meal and snack rates for a
maximum of one breakfast, one lunch, one
dinner, and three snacks per eligible child
per day. The rates apply regardless of
whether a family day care provider is re-
imbursed for food costs, in whole or in part,
under the CACFP, or under any other pro-
gram, for a particular meal or snack. A fam-
ily day care provider who receives a
reimbursement for a particular meal or
snack, however, may deduct only the por-
tion of the applicable standard meal or
snack rate that exceeds the amount of the
reimbursement.
.02Rates Must Be Used Consistently.
Family day care providers may use either
the standard meal and snack rates or ac-
tual costs to calculate the deductible cost
of food provided to eligible children in the
2003–10 I.R.B.577March 10, 2003

family day care in any particular taxable
year. Family day care providers who choose
to use the standard meal and snack rates
provided in this revenue procedure for a
particular taxable year must use the rates
for all their deductible food costs during that
taxable year. However, a family day care
provider who uses the standard meal and
snack rates in any taxable year may use ac-
tual costs to compute the deductible cost of
food in any other taxable year.
.03Record Keeping.To satisfy the record
keeping requirements of§6001 and the
regulations thereunder, family day care pro-
viders who use the standard meal and snack
rates provided in this revenue procedure
must maintain records to substantiate their
computation of the total amount deduct-
ible under this revenue procedure for each
taxable year. The records should include the
name of each eligible child, dates and hours
of attendance in the family day care, and
the type and quantity of meals and snacks
served. This information may be recorded
in the meal and snack log contained in the
APPENDIX to this revenue procedure. A
family day care provider who uses the log
in the APPENDIX to maintain accurate and
required information will be deemed to
comply with the record keeping require-
ments of§6001 and the regulations there-
under.
.04Standard Meal and Snack Rates.
The standard meal and snack rates are
equal to the Tier I reimbursement rates of
the CACFP for meals served in day care
homes. For purposes of this revenue pro-
cedure, the standard meal and snack rates
for a taxable year are the Tier I rates in ef-
fect on December 31 preceding the begin-
ning of the family day care provider’s
taxable year. For example, for the 2003 tax-
able year, calendar year family day care pro-
viders will use the Tier I rates in effect on
December 31, 2002, as the standard meal
and snack rates to calculate their deduct-
ible food costs for the entire 2003 tax-
able year. The rates will be adjusted
annually (see section 5.06 of this revenue
procedure).
The standard meal and snack rates in ef-
fect on December 31, 2002, are:
(1) For all family day care providers other than those located in Alaska or Hawaii:
Breakfast$0.98
Lunch/Dinner$1.80
Snack$0.53
(2) For family day care providers located in Alaska:
Breakfast$1.55
Lunch/Dinner$2.93
Snack$0.87
(3) For family day care providers located in Hawaii:
Breakfast$1.13
Lunch/Dinner$2.11
Snack$0.63
.05What is Included in the Standard
Meal and Snack Rates.The standard meal
rates apply to breakfast, lunch, and din-
ner. The standard meal and snack rates in-
clude beverages, but do not include non-
food supplies used for food preparation,
service, or storage, such as containers, pa-
per products or utensils. The standard meal
and snack rates do not include other non-
food items such as medication, adminis-
trative supplies, or toys. A family day care
provider who uses the standard meal and
snack rates may separately deduct the cost
of these non-food items if the cost is de-
ductible under§162.
.06Annual Adjustment of the Standard
Meal and Snack Rates.The standard meal
and snack rates will be adjusted annually.
The Department of Agriculture adjusts the
Tier I reimbursement rates each July based
on changes to the consumer price index for
the cost of food at home. Although the Tier
I reimbursement rates apply for the pe-
riod of July 1 to June 30 of each year, for
purposes of this revenue procedure the stan-
dard meal and snack rates applicable for a
particular taxable year are the Tier I rates
in effect on December 31 preceding the be-
ginning of the family day care provider’s
taxable year.
Generally, the CACFP reimbursement
rates may be found on the Internet at
www.usda.govunder“Child and Adult Care
Food Program.”The Service will post the
standard meal and snack rates currently in
effect under this revenue procedure on the
Internet atwww.irs.gov/businesses/small/
industries/index.html, then click on“Child
Care.”The Service will also include the
standard meal and snack rates that are cur-
rent at the time of publication in Publica-
tion 587,Business Use of Your Home.
SECTION 6. EFFECTIVE DATE
This revenue procedure is effective for
taxable years beginning after December 31,
2002.
SECTION 7. AUDIT PROTECTION
If a family day care provider uses the
Tier I rates to compute the deductible cost
of food provided to eligible children in a
taxable year that ends before January 1,
2003, the Service will not raise the issue
of the amount of the family day care pro-
vider’s deductible food costs. If a family
day care provider uses the Tier I rates to
compute the deductible cost of food pro-
vided to eligible children in a taxable year
that ends before January 1, 2003, and the
amount of the family day care provider’s
deductible food costs is an issue under con-
sideration (within the meaning of section
3.09 of Rev. Proc. 2002–9, 2002–3 I.R.B.
March 10, 20035782003–10 I.R.B.

327) in examination, in appeals, or be-
fore the U.S. Tax Court in a taxable year
that ends before January 1, 2003, that is-
sue will not be further pursued by the Ser-
vice.
DRAFTING INFORMATION
The principal author of this revenue pro-
cedure is Angella Warren of the Office of
Associate Chief Counsel (Income Tax and
Accounting). For further information re-
garding this revenue procedure, contact
Ms. Warren at (202) 622–4950 (not a toll-
free call).
2003–10 I.R.B.579March 10, 2003

March 10, 20035802003–10 I.R.B.

2003–10 I.R.B.581March 10, 2003

March 10, 20035822003–10 I.R.B.

Part IV. Items of General Interest
Notice of Proposed Rulemak-
ing by Cross-Reference to
Temporary Regulations and
Notice of Public Hearing
Excise Tax Relating to
Structured Settlement
Factoring Transactions
REG–139768–02
AGENCY: Internal Revenue Service (IRS),
Treasury.
ACTION: Notice of proposed rulemak-
ing by cross-reference to temporary regu-
lations and notice of public hearing.
SUMMARY: In T.D. 9042 on page 564 of
this issue of the Bulletin, the IRS is issu-
ing temporary regulations relating to the
manner and method of reporting and pay-
ing the 40-percent excise tax imposed on
any person who acquires structured settle-
ment payment rights in a structured settle-
ment factoring transaction. The text of those
regulations also serves as the text of these
proposed regulations. This document also
provides notice of a public hearing on these
proposed regulations.
DATES: Written or electronic comments
must be received by May 20, 2003. Out-
lines of topics to be discussed at the pub-
lic hearing scheduled for June 12, 2003, at
10:00 a.m. must be received by May 22,
2003.
ADDRESSES: Send submissions to:
CC:PA:RU (REG–139768–02), room 5226,
Internal Revenue Service, P.O. Box 7604,
Ben Franklin Station, Washington, DC
20044. Submissions may be hand deliv-
ered Monday through Friday between the
hours of 8 a.m. and 4 p.m. to: CC:PA:RU
(REG–139768–02), Courier’s Desk, Inter-
nal Revenue Service,1111Constitution Av-
enue NW, Washington, DC. Alternatively,
taxpayers may submit electronic comments
directly to the IRS internet site at
www.irs.gov/regs.The public hearing will
be held in room 6718 of the Internal Rev-
enue Building,1111Constitution Avenue
NW, Washington, DC.
FOR FURTHER INFORMATION CON-
TACT: Concerning the proposed regula-
tions, Shareen S. Pflanz, 202–622–8488;
concerning submissions of comments,
Sonya Cruse, 202–622–7180 (not toll-free
numbers).
SUPPLEMENTARY INFORMATION:
Paperwork Reduction Act
The collection of information contained
in this notice of proposed rulemaking has
been submitted to the Office of Manage-
ment and Budget for review in accordance
with the Paperwork Reduction Act of 1995
(44 U.S.C. 3507(d)). Comments on the col-
lection of information should be sent to the
Office of Management and Budget, Attn:
Desk Officer for the Department of the
Treasury, Office of Information and Regu-
latory Affairs, Washington, DC 20503, with
copies to theInternal Revenue Service,
Attn: IRS Reports Clearance Officer,
W:CAR:MP:FP:S, Washington, DC 20224.
Comments on the collection of informa-
tion should be received by April 21, 2003.
Comments are specifically requested
concerning:
Whether the proposed collection of in-
formation is necessary for the proper per-
formance of the functions of theInternal
Revenue Service, including whether the in-
formation will have practical utility;
The accuracy of the estimated burden as-
sociated with the proposed collection of in-
formation (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 applica-
tion of automated collection techniques or
other forms of information technology; and
Estimates of capital or start-up costs and
costs of operation, maintenance, and pur-
chase of service to provide information.
The collection of information in this pro-
posed regulation is in§§157.6001–1T,
157.6011–1T, 157.6081–1T, and 157.6161–
1T. This information is required by the IRS
to verify that the excise tax imposed un-
der section 5891 of the Internal Revenue
Code is properly reported on Form 8876
and timely paid. This information will be
used for that purpose. The collection of in-
formation is mandatory. The likely respon-
dents and/or recordkeepers are individuals,
business or other for-profit institutions, and
small businesses and organizations. The re-
porting burden is also reflected on Form
8876.
Estimated total annual reporting and/or
recordkeeping burden: 2 hours.
Estimated average annual burden hours
per respondent and/or recordkeeper: 30 min-
utes.
Estimated number of respondents and/or
recordkeepers: 4.
Estimated annual frequency of responses
(for reporting requirements only): On oc-
casion.
An agency may not conduct or spon-
sor, and a person is not required to re-
spond to, a collection of information unless
it displays a valid control number assigned
by the Office of Management and Bud-
get.
Books or records relating to a collec-
tion of information must be retained as long
as their contents may become material in
the administration of any internal revenue
law. Generally, tax returns and tax return
information are confidential, as required by
26 U.S.C. 6103.
Background and Explanation of
Provisions
Temporary regulations in T.D. 9042 in
this issue of the Bulletin add a new part 157
to title 26 of the Code of Federal Regula-
tions. The temporary regulations set forth
the manner and method of paying the ex-
cise tax imposed under section 5891. The
text of those regulations also serves as the
text of these proposed regulations. The pre-
amble to the temporary regulations ex-
plains the amendments.
Special Analyses
It has been determined that this notice
of proposed rulemaking is not a signifi-
cant regulatory action as defined in Ex-
ecutive Order 12866. Therefore, a regulatory
assessment is not required. It also has been
determined that section 553(b) of the Ad-
ministrative Procedure Act (5 U.S.C. chap-
ter 5) does not apply to these regulations.
Further, it is hereby certified, pursuant to
sections 603(a) and 605(b) of the Regula-
tory Flexibility Act, that the collection of
information in these regulations will not
have a significant economic impact on a
substantial number of small entities. This
2003–10 I.R.B.583March 10, 2003

certification is based upon the expecta-
tion that the excise tax imposed by sec-
tion 5891 of the Code will apply to few
structured settlement factoring transac-
tions. Therefore, a Regulatory Flexibility
Analysis under the Regulatory Flexibility
Act (5 U.S.C. chapter 6) is not required.
Pursuant to section 7805(f) of the Inter-
nal Revenue Code, this notice of proposed
rulemaking will be submitted to the Chief
Counsel for Advocacy of the Small Busi-
ness Administration for comment on its im-
pact.
Comments and Requests for Public
Hearing
Before these proposed regulations are
adopted as final regulations, consideration
will be given to any written comments (a
signed original and eight (8) copies) or elec-
tronic comments that are submitted timely
to the IRS. All comments will be avail-
able for public inspection and copying.
A public hearing has been scheduled for
June 12, 2003 beginning at 10:00 a.m. in
room 6718 of the Internal Revenue Build-
ing,1111Constitution Avenue, NW, Wash-
ington, DC. Due to building security
procedures, visitors will not be admitted be-
yond the immediate entrance area more than
15 minutes before the hearing starts. For in-
formation about having your name placed
on the building access list to attend the hear-
ing, see the“FOR FURTHER INFORMA-
TION CONTACT”section of this preamble.
The rules of 26 CFR 601.601(a)(3) ap-
ply to the hearing. Persons who wish to
present oral comments at the hearing must
submit written comments and an outline of
the topics to be discussed and the time to
be devoted to each topic (signed original
and eight (8) copies) by May 22, 2003. A
period of 10 minutes will be allotted to each
person for making comments. An agenda
showing the scheduling of the speakers will
be prepared after the deadline for receiv-
ing outlines has passed. Copies of the
agenda will be available free of charge at
the hearing.
Drafting Information
The principal author of these regula-
tions is Shareen Soltanzadeh Pflanz, Of-
fice of Associate Chief Counsel (Income
Tax and Accounting). However, other per-
sonnel from the IRS and Treasury Depart-
ment participated in their development.
*****
Proposed Amendments to the
Regulations
Accordingly, title 26 of the Code of Fed-
eral Regulations is proposed to be amended
as follows:
SUBCHAPTER D—
MISCELLANEOUS EXCISE TAXES
Paragraph 1. A new part 157 is added to
read as follows:
PART 157—EXCISE TAX ON
STRUCTURED SETTLEMENT
FACTORING TRANSACTIONS
Subpart A—Tax on Structured
Settlement Factoring Transactions
Sec.
157.5891–1 Imposition of excise tax on
structured settlement factoring transac-
tions.
Subpart B—Procedure and
Administration
Sec.
157.6001–1 Records, statements, and
special returns.
157.6011–1 General requirement of re-
turn, statement, or list.
157.6061–1 Signing of returns and other
documents.
157.6065–1 Verification of returns.
157.6071–1 Time for filing returns.
157.6081–1 Extension of time for fil-
ing the return.
157.6091–1 Place for filing returns.
157.6151–1 Time and place for paying
of tax shown on returns.
157.6161–1 Extension of time for pay-
ing tax.
157.6165–1 Bonds where time to pay tax
has been extended.
Authority: 26 U.S.C. 7805
Section 157.6001–1 also issued under 26
U.S.C. 6001.
Section 157.6011–1 also issued under 26
U.S.C. 6011.
Section 157.6061–1 also issued under 26
U.S.C. 6061.
Section 157.6091–1 also issued under 26
U.S.C. 6091.
Section 157.6161–1 also issued under 26
U.S.C. 6161.
Subpart A—Tax on Structured
Settlement Factoring Transactions
§157.5891–1 Imposition of excise tax on
structured settlement factoring
transactions.
[The text of proposed§157.5891–1isthe
same as the text of§157.5891–1T pub-
lished elsewhere in this issue of theFed-
eral Register].
Subpart B—Procedure and
Administration
§157.6001–1 Records, statements, and
special returns.
[The text of proposed§157.6001–1isthe
same as the text of§157.6001–1T pub-
lished elsewhere in this issue of theFed-
eral Register].
§157.6011–1 General requirement of
return, statement, or list.
[The text of proposed§157.6011–1isthe
same as the text of§157.6011–1T pub-
lished elsewhere in this issue of theFed-
eral Register].
§157.6061–1 Signing of returns and
other documents.
[The text of proposed§157.6061–1isthe
same as the text of§157.6061–1T pub-
lished elsewhere in this issue of theFed-
eral Register].
§157.6065–1 Verification of returns.
[The text of proposed§157.6065–1isthe
same as the text of§157.6065–1T pub-
lished elsewhere in this issue of theFed-
eral Register].
§157.6071–1 Time for filing returns.
[The text of proposed§157.6071–1isthe
same as the text of§157.6071–1T pub-
lished elsewhere in this issue of theFed-
eral Register].
§157.6081–1 Extension of time for filing
the return.
[The text of proposed§157.6081–1isthe
same as the text of§157.6081–1T pub-
lished elsewhere in this issue of theFed-
eral Register].
March 10, 20035842003–10 I.R.B.

§157.6091–1 Place for filing returns.
[The text of proposed§157.6091–1isthe
same as the text of§157.6091–1T pub-
lished elsewhere in this issue of theFed-
eral Register].
§157.6151–1 Time and place for paying
of tax shown on returns.
[The text of proposed§157.6151–1isthe
same as the text of§157.6151–1T pub-
lished elsewhere in this issue of theFed-
eral Register].
§157.6161–1 Extension of time for
paying tax.
[The text of proposed§157.6156–1isthe
same as the text of§157.6161–1T pub-
lished elsewhere in this issue of theFed-
eral Register].
§157.6165–1 Bonds where time to pay
tax has been extended.
[The text of proposed§157.6165–1isthe
same as the text of§157.6165–1T pub-
lished elsewhere in this issue of theFed-
eral Register].
David A. Mader,
Assistant Deputy Commissioner
of Internal Revenue.
(Filed by the Office of the Federal Register on February 18,
2003, 8:45 a.m., and published in the issue of the Federal Reg-
ister for February 19, 2003, 68 F.R. 7956)
Information Reporting
Relating to Taxable Stock
Transactions; Correction
Announcement 2003–11
AGENCY: Internal Revenue Service (IRS),
Treasury
ACTION: Correction to temporary regu-
lations.
SUMMARY: This document contains cor-
rections to temporary regulations that were
published in theFederal Registeron No-
vember 18, 2002 (T.D. 9022, 2002–48
I.R.B. 909 [67 FR 69468]). This docu-
ment contains temporary regulations un-
der section 6043(c) requiring information
reporting by a corporation if control of the
corporation is acquired or if the corpora-
tion has a recapitalization or other substan-
tial change in capital structure.
DATES: This correction is effective No-
vember 18, 2002.
FOR FURTHER INFORMATION CON-
TACT: Nancy Rose at (202) 622–4910 (not
a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The temporary regulations that are the
subject of this correction are under sec-
tion 6043(c) of the Internal Revenue Code.
Need for Correction
As published, the temporary regula-
tions (T.D. 9022) contain errors that may
prove to be misleading and are in need of
clarification.
Correction of Publication
Accordingly, the publication of the tem-
porary regulations (T.D. 9022), which is the
subject of FR Doc. 02–29199, is corrected
as follows:
1. On page 69469, column 2, in the pre-
amble, under the paragraph heading“Back-
ground and Explanation of Provisions”, line
5, the language“regulations published in
proposed rules”is corrected to read“regu-
lations published in the proposed rules”.
§1.6043–4T [Corrected]
2. On page 69470, column 1,§1.6043–
4T, paragraph (a)(5), the last line in col-
umn one, the language“shareholders who
receive cash, stock or”is corrected to read
“shareholders who receive cash, stock, or”.
3. On page 69472, column 1,§1.6043–
4T, paragraph (h), ofExample 2,line1,the
language“Example 2. C, a domestic cor-
poration, and”is corrected to read“Ex-
ample 2. C, a domestic corporation and”.
§1.6045–3T [Corrected]
4. On page 69473, column 1,§1.6045–
3T, paragraph (d), line 2, the language“re-
ceives stock, cash or other property”is
corrected to read“receives stock, cash, or
other property”.
Cynthia E. Grigsby,
Chief, Regulations Unit,
Associate Chief Counsel
(Procedure and Administration).
(Filed by the Office of the Federal Register on February 5,
2003, 8:45 a.m., and published in the issue of the Federal Reg-
ister for February 6, 2003, 68 F.R. 6081)
Excise Taxes; Definition of
Highway Vehicle; Hearing,
and Information Reporting
Relating to Taxable Stock
Transactions; Hearing
Announcement 2003–12
AGENCY: Internal Revenue Service (IRS),
Treasury.
ACTION: Change of location of public
hearings.
SUMMARY: This document changes the
location of two public hearings on pro-
posed regulations relating to the defini-
tion of a highway vehicle for purposes of
various excise taxes and information re-
porting relating to taxable stock transac-
tions.
DATES: The public hearings scheduled in
room 4718 on Thursday, February 27, 2003,
and Tuesday, March 25, 2003, respectively,
are rescheduled to be held in the IRS Au-
ditorium at 10 a.m.
FOR FURTHER INFORMATION CON-
TACT: Concerning submissions of com-
ments, the hearing, and/or to be placed on
the building access list to attend the hear-
ing, Treena Garrett at (202) 622–7180 (not
a toll-free number).
SUPPLEMENTARY INFORMATION:
A notice of public hearing (REG–
103829–99, published in the I.R.B. as An-
nouncement 2002–95, 2002–42 I.R.B. 727
[67 FR 58346]), that was published in the
Federal Registeron Monday, September
16, 2002, announced that a public hear-
ing on proposed regulations relating to the
definition of a highway vehicle for pur-
poses of various excise taxes under sec-
tions 4041 (fuel taxes), 4051 (retail tax on
heavy vehicles), 4071 (tire tax) and sec-
tions 6421 and 6427 (fuel tax credits and
refunds) of the Internal Revenue Code
would be held on Thursday, February 27,
2003, beginning at 10 a.m. in room 4718
of the Internal Revenue Building,1111Con-
stitution Avenue, NW, Washington, DC.
A notice of proposed rulemaking by
cross-reference to temporary regulations and
notice of public hearing (REG–143321–
02, 2002–48 I.R.B. 922 [67 FR 69496]),
that was published in theFederal Regis-
teron Monday, November 18, 2002, and
2003–10 I.R.B.585March 10, 2003

Wednesday, November 27, 2002 (published
in the I.R.B. as Announcement 2002–111,
2002–50 I.R.B. 971 [70891]), announced
that a public hearing on proposed regula-
tions relating to information reporting re-
lating to taxable stock transactions under
sections 6043(c) and 6045 of the Internal
Revenue Code would be held on Tues-
day, March 25, 2003, beginning at 10 a.m.
in room 4718 of the Internal Revenue
Building,1111Constitution Avenue, NW,
Washington, DC.
The location of both public hearings has
changed. The public hearing for REG–
103829–99 and REG–143321–02 are be-
ing held in the Auditorium, beginning at 10
a.m., Internal Revenue Service Building,
1111Constitution Avenue, NW, Washing-
ton, DC. Because of the controlled access
restrictions, attendees are not admitted be-
yond the lobby of the Internal Revenue Ser-
vice Building until 9:30 a.m. The IRS will
prepare an agenda showing the schedul-
ing of the speakers after the outlines are re-
ceived from the persons testifying and make
copies available free of charge at the hear-
ing.
Cynthia E. Grigsby,
Chief, Regulations Unit,
Associate Chief Counsel
(Procedure and Administration).
(Filed by the Office of the Federal Register on February 13,
2003, 8:45 a.m., and published in the issue of the Federal Reg-
ister for February 14, 2003, 68 F.R. 7454)
March 10, 20035862003–10 I.R.B.

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as“rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplifieddescribes 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
withmodified, below).
Clarifiedis used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously
published ruling and points out an essen-
tial difference between them.
Modifiedis used where the substance
of a previously published position is
being changed. Thus, if a prior ruling
held that a principle applied to A but not
to B, and the new ruling holds that it
applies to both A and B, the prior ruling
is modified because it corrects a pub-
lished position. (Compare withamplified
andclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered 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.
Revokeddescribes situations where the
position in the previously published rul-
ing is not correct and the correct position
is being stated in the new ruling.
Supersededdescribes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a
period of time in separate rulings. If the
new ruling does more than restate the
substance of a prior ruling, a combination
of terms is used. For example,modified
andsupersededdescribes 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.
Supplementedis used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in
material published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions 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.
2003–10 I.R.B.iMarch 10, 2003

Numerical Finding List
1
Bulletins 2003–1 through 2003–9
Announcements:
2003–1, 2003–2 I.R.B.281
2003–2, 2003–3 I.R.B.301
2003–3, 2003–4 I.R.B.361
2003–4, 2003–5 I.R.B.396
2003–5, 2003–5 I.R.B.397
2003–6, 2003–6 I.R.B.450
2003–7, 2003–6 I.R.B.450
2003–8, 2003–6 I.R.B.451
2003–9, 2003–7 I.R.B.490
2003–10, 2003–7 I.R.B.490
Notices:
2003–1, 2003–2 I.R.B.257
2003–2, 2003–2 I.R.B.257
2003–3, 2003–2 I.R.B.258
2003–4, 2003–3 I.R.B.294
2003–5, 2003–3 I.R.B.294
2003–6, 2003–3 I.R.B.298
2003–7, 2003–4 I.R.B.310
2003–8, 2003–4 I.R.B.310
2003–9, 2003–5 I.R.B.369
2003–10, 2003–5 I.R.B.369
2003–11, 2003–6 I.R.B.422
2003–12, 2003–6 I.R.B.422
2003–13, 2003–8 I.R.B.513
2003–14, 2003–8 I.R.B.515
2003–15, 2003–9 I.R.B.540
Proposed Regulations:
REG–209500–86, 2003–2 I.R.B.262
REG–116641–01, 2003–8 I.R.B.518
REG–125638–01, 2003–5 I.R.B.373
REG–126016–01, 2003–7 I.R.B.486
REG–126485–01, 2003–9 I.R.B.542
REG–103580–02, 2003–9 I.R.B.543
REG–124069–02, 2003–7 I.R.B.488
REG–138882–02, 2003–8 I.R.B.522
REG–151043–02, 2003–3 I.R.B.300
REG–164464–02, 2003–2 I.R.B.262
Revenue Procedures:
2003–1, 2003–1 I.R.B.1
2003–2, 2003–1 I.R.B.76
2003–3, 2003–1 I.R.B.113
2003–4, 2003–1 I.R.B.123
2003–5, 2003–1 I.R.B.163
2003–6, 2003–1 I.R.B.191
2003–7, 2003–1 I.R.B.233
2003–8, 2003–1 I.R.B.236
2003–9, 2003–8 I.R.B.516
2003–10, 2003–2 I.R.B.259
2003–11, 2003–4 I.R.B.311
2003–12, 2003–4 I.R.B.316
2003–13, 2003–4 I.R.B.317
2003–14, 2003–4 I.R.B.319
2003–15, 2003–4 I.R.B.321
2003–16, 2003–4 I.R.B.359
2003–17, 2003–6 I.R.B.427
2003–18, 2003–6 I.R.B.439
Revenue Procedures—Continued:
2003–19, 2003–5 I.R.B.371
2003–20, 2003–6 I.R.B.445
2003–21, 2003–6 I.R.B.448
Revenue Rulings:
2003–1, 2003–3 I.R.B.291
2003–2, 2003–2 I.R.B.251
2003–3, 2003–3 I.R.B.252
2003–4, 2003–4 I.R.B.253
2003–5, 2003–5 I.R.B.254
2003–6, 2003–3 I.R.B.286
2003–7, 2003–5 I.R.B.363
2003–8, 2003–3 I.R.B.290
2003–9, 2003–4 I.R.B.303
2003–10, 2003–3 I.R.B.288
2003–11, 2003–3 I.R.B.285
2003–12, 2003–3 I.R.B.283
2003–13, 2003–4 I.R.B.305
2003–14, 2003–4 I.R.B.302
2003–15, 2003–4 I.R.B.302
2003–16, 2003–6 I.R.B.401
2003–17, 2003–6 I.R.B.400
2003–18, 2003–7 I.R.B.467
2003–19, 2003–7 I.R.B.468
2003–20, 2003–7 I.R.B.465
2003–21, 2003–8 I.R.B.509
2003–22, 2003–8 I.R.B.494
2003–23, 2003–8 I.R.B.511
Treasury Decisions:
9024, 2003–5 I.R.B.365
9025, 2003–5 I.R.B.362
9026, 2003–5 I.R.B.366
9027, 2003–6 I.R.B.413
9028, 2003–6 I.R.B.415
9029, 2003–6 I.R.B.403
9030, 2003–8 I.R.B.495
9031, 2003–8 I.R.B.504
9032, 2003–7 I.R.B.471
9033, 2003–7 I.R.B.483
9034, 2003–7 I.R.B.453
9035, 2003–9 I.R.B.528
9036, 2003–9 I.R.B.533
9037, 2003–9 I.R.B.535
9038, 2003–9 I.R.B.524
9041, 2003–8 I.R.B.510
1
A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 2002–26 through 2002–52 is
in Internal Revenue Bulletin 2003–1, dated January 6, 2003.
March 10, 2003ii2003–10 I.R.B.

Finding List of Current Actions
on Previously Published Items
2
Bulletins 2003–1 through 2003–9
Notices:
97–19
Modified by
Rev. Proc. 2003–1, 2003–1 I.R.B.1
2001–26
Obsoleted by
T.D. 9032, 2003–7 I.R.B.471
2001–46
Modified by
Notice 2003–6, 2003–3 I.R.B.298
2001–69
Modified and superseded by
Notice 2003–1, 2003–2 I.R.B.257
2002–27
Clarified by
Notice 2003–3, 2003–2 I.R.B.258
2002–46
Modified by
Notice 2003–10, 2003–5 I.R.B.369
Proposed Regulations:
REG–209500–86
Corrected by
Ann. 2003–6, 2003–6 I.R.B.450
REG–126485–01
Withdrawn by
REG–126485–01, 2003–9 I.R.B.542
REG–164464–02
Corrected by
Ann. 2003–6, 2003–6 I.R.B.450
Revenue Procedures:
83–23
Supplemented by
Rev. Proc. 2003–21, 2003–6 I.R.B.448
84–37
Modified by
Rev. Proc. 2003–1, 2003–1 I.R.B.1
93–38
Obsoleted by
Rev. Proc. 2003–15, 2003–4 I.R.B.321
97–31
Modified by
Rev. Proc. 2003–9, 2003–8 I.R.B.516
98–13
Obsoleted by
T.D. 9032, 2003–7 I.R.B.471
2002–1
Superseded by
Rev. Proc. 2003–1, 2003–1 I.R.B.1
Revenue Procedures—Continued:
2002–2
Superseded by
Rev. Proc. 2003–2, 2003–1 I.R.B.76
2002–3
Superseded by
Rev. Proc. 2003–3, 2003–1 I.R.B.113
2002–4
Superseded by
Rev. Proc. 2003–4, 2003–1 I.R.B.123
2002–5
Superseded by
Rev. Proc. 2003–5, 2003–1 I.R.B.163
2002–6
Superseded by
Rev. Proc. 2003–6, 2003–1 I.R.B.191
2002–7
Superseded by
Rev. Proc. 2003–7, 2003–1 I.R.B.233
2002–8
Superseded by
Rev. Proc. 2003–8, 2003–1 I.R.B.236
2002–9
Modified and amplified by
Rev. Proc. 2003–20, 2003–6 I.R.B.445
Rev. Rul. 2003–3, 2003–2 I.R.B.252
2002–22
Modified by
Rev. Proc. 2003–3, 2003–1 I.R.B.113
2002–29
Modified by
Rev. Proc. 2003–10, 2003–2 I.R.B.259
2002–52
Modified by
Rev. Proc. 2003–1, 2003–1 I.R.B.1
2002–67
Supplemented by
Ann. 2003–3, 2003–4 I.R.B.361
2002–75
Superseded by
Rev. Proc. 2003–3, 2003–1 I.R.B.113
2003–3
Amplified by
Rev. Proc. 2003–14, 2003–4 I.R.B.319
2003–7
Corrected by
Ann. 2003–4, 2003–5 I.R.B396
Revenue Rulings:
53–131
Modified by
Rev. Rul. 2003–12, 2003–3 I.R.B.283
57–190
Obsoleted by
Rev. Rul. 2003–18, 2003–7 I.R.B.467
Revenue Rulings—Continued:
65–190
Revoked by
Rev. Rul. 2003–3, 2003–2 I.R.B.252
69–372
Revoked by
Rev. Rul. 2003–3, 2003–2 I.R.B.252
2003–2
Revoked by
Rev. Rul. 2003–22, 2003–8 I.R.B.494
Treasury Decisions:
9002
Corrected by
Ann. 2003–8, 2003–6 I.R.B.451
9022
Supplemented by
Ann. 2003–7, 2003–6 I.R.B.450
2
A cumulative list of current actions on previously
published items in Internal Revenue Bulletins
2002–26 through 2002–52 is in Internal Revenue
Bulletin 2003–1, dated January 6, 2003.
2003–10 I.R.B.iii*U.S. Government Printing Office: 2003—496-919/60073March 10, 2003