Internal Revenue Bulletin 1999-14 (PDF rendition): IRS Revenue Rulings

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INCOME TAX
Rev. Rul. 99–17, page 4.
Federal rates; adjusted federal rates; adjusted federal
long-term rate, and the long-term exempt rate.For
purposes of sections 1274, 1288, 382, and other sections
of the Code, tables set forth the rates for April 1999.
Rev. Rul. 99–18, page 3.
Low-income housing credits; satisfactory bond; “bond
factor” amounts for the period January through March
1999.This ruling announces the monthly bond factor
amounts to be used by taxpayers who dispose of qualified
low-income buildings or interests therein during the period
January through March 1999.
Notice 99–17, page 6.
This notice modifies Notice 98–20, 1998–13 I.R.B. 25, to
reflect changes made to section 1(h) of the Internal Revenue
Code by sections 4002(i)(3) and 4003(b) of the Tax and
Trade Relief Extension Act of 1998. The changes affect the
treatment of post-1997 distributions of capital gains from a
charitable remainder trust.
Rev. Proc. 99–20, page 7.
Section 911(d)(4) waiver.Guidance is provided to individ-
uals who fail to meet the eligibility requirements of section
911(d)(1) of the Internal Revenue Code because adverse
conditions in a foreign country preclude the individual from
meeting those requirements. A current list of countries and
the dates those countries are subject to the section
911(d)(4) waiver is provided.
EXEMPT ORGANIZATIONS
Announcement 99–32, page 20.
A list is given of organizations now classified as private foun-
dations.
ADMINISTRATIVE
REG–100729–98, page 9.
Proposed regulations under section 6302 of the Code relate
to the deposit of Federal taxes by electronic funds transfer
(EFT). A public hearing is scheduled for May 11, 1999.
Announcement 99–24, page 12.
The Service is requesting comments from the public on pro-
posed revisions to Form 1042–S, Foreign Person’s U.S.
Source Income Subject to Withholding.
Announcement 99–26, page 20.
An updated edition of Publication 954, Tax Incentives for Em-
powerment Zones and Other Distressed Communities (re-
vised February 1999), is now available.
Announcement 99–33, page 21.
Updated editions of Publication 547, Casualties, Disasters,
and Thefts (Business and Nonbusiness) (revised February
1999), and Publication 584, Casualty, Disaster, and Theft
Loss Workbook (Personal-Use Property) (revised February
1999) are now available.
Announcement 99–35, page 22.
Proposed regulation REG–113744–98, 1999–10 I.R.B. 59,
under section 1296 of the Code relating to the new mark-to-
market election for stock of a passive foreign investment
company (PFIC), is corrected.
Internal Revenue
bbuulllleettiinn
Bulletin No. 1999–14
April 5, 1999
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
Department of the Treasury
Internal Revenue Service
Finding Lists begin on page 28.
Announcement of Disbarments and Suspensions begins on page 25.
Announcement of Declaratory Judgment Proceedings Under Section 7428 is on page 22.
Index for January through March begins on page 30.

The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing offi-
cial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
general interest. It is published weekly and may be obtained
from the Superintendent of Documents on a subscription
basis. Bulletin contents are consolidated semiannually into
Cumulative Bulletins, which are sold on a single-copy basis.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of in-
ternal management are not published; however, statements
of internal practices and procedures that affect the rights
and duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the
revenue ruling. In those based on positions taken in rulings
to taxpayers or technical advice to Service field offices,
identifying details and information of a confidential nature
are deleted to prevent unwarranted invasions of privacy and
to comply with statutory requirements.
Rulings and procedures reported in the Bulletin do not have
the force and effect of Treasury Department Regulations,
but they may be used as precedents. Unpublished rulings
will not be relied on, used, or cited as precedents by Service
personnel in the disposition of other cases. In applying pub-
lished rulings and procedures, the effect of subsequent leg-
islation, regulations, court decisions, rulings, and proce-
dures must be considered, and Service personnel and oth-
ers concerned are cautioned against reaching the same con-
clusions in other cases unless the facts and circumstances
are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions, and Subpart B, Legislation and Related
Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to
these subjects are contained in the other Parts and Sub-
parts. Also included in this part are Bank Secrecy Act Admin-
istrative Rulings. Bank Secrecy Act Administrative Rulings
are issued by the Department of the Treasury’s Office of the
Assistant Secretary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The first Bulletin for each month includes a cumulative index
for the matters published during the preceding months.
These monthly indexes are cumulated on a semiannual basis,
and are published in the first Bulletin of the succeeding semi-
annual period, respectively.
Mission of the Service
Provide America’s taxpayers top quality service by help-
ing them understand and meet their tax responsibilities
and by applying the tax law with integrity and fairness to
all.
2
Introduction
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402.

Section 42.–Low-Income
Housing Credit
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of April 1999. See Rev. Rul. 99–17, page 4.
Low-income housing credits; satis-
factory bond; “bond factor” amounts
for the period January through March
1999.This ruling announces the monthly
bond factor amounts to be used by tax-
payers who dispose of qualified low-in-
come buildings or interests therein during
the period January through March 1999.
Rev. Rul. 99–18
In Rev. Rul. 90–60, 1990–2 C.B. 3, the
Internal Revenue Service provided guid-
ance to taxpayers concerning the general
methodology used by the Treasury De-
partment in computing the bond factor
amounts used in calculating the amount of
bond considered satisfactory by the Sec-
retary under § 42(j)(6) of the Internal
Revenue Code. It further announced that
the Secretary would publish in the Inter-
nal Revenue Bulletin a table of “bond fac-
tor” amounts for dispositions occurring
during each calendar month.
This revenue ruling provides in Table 1
the bond factor amounts for calculating
the amount of bond considered satisfac-
tory under § 42(j)(6) for dispositions of
qualified low-income buildings or inter-
ests therein during the period January
through March 1999.
1999–14 I.R.B.3April 5, 1999
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
Table 1
Rev. Rul. 99–18
Monthly Bond Factor Amounts for Dispositions Expressed
As a Percentage of Total Credits
Calendar Year Building Placed in Service
or, if Section 42(f)(1) Election Was Made,
the Succeeding Calendar Year
Month of
Disposition 1987198819891990199119921993199419951996199719981999
Jan ’9944.1057.4870.9872.5674.6777.0979.5481.8784.1886.7089.3392.3392.81
Feb ’9944.1057.4870.9872.3574.4576.8579.2981.6083.9086.4089.0091.9292.81
Mar ’9944.1057.4870.9872.1474.2476.6279.0581.3583.63 86.1188.6991.5692.81
For a list of bond factor amounts ap-
plicable to dispositions occurring during
other calendar years, see the following
revenue rulings: Rev. Rul. 98–3, 1998–2
I.R.B. 4, for dispositions occurring during
the calendar years 1996 and 1997; Rev.
Rul. 98–13, 1998–11 I.R.B. 4, for disposi-
tions occurring during the period January
through March 1998; Rev. Rul. 98–31,
1998–25 I.R.B. 4, for dispositions occur-
ring during the period April through June
1998; Rev. Rul. 98–45, 1998–38 I.R.B. 4,
for dispositions occurring during the pe-
riod July through September 1998; and
Rev. Rul. 99–1, 1999–2 I.R.B. 4, for dis-
positions occurring during the period Oc-
tober through December 1998.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Gregory Doran of the Office of
Assistant Chief Counsel (Passthroughs
and Special Industries). For further infor-
mation regarding this revenue ruling, con-
tact Mr. Doran on (202) 622-3040 (not a
toll-free call).
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term
rates are set forth for the month of April 1999. See
Rev. Rul. 99–17, page 4.
Section 382.—Limitation on
Net Operating Loss
Carryforwards and Certain
Built-In Losses Following
Ownership Change
The adjusted applicable federal long-term rate is
set forth for the month of April 1999. See Rev. Rul.
99–17, page 4.
Section 412.—Minimum
Funding Standards
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of April 1999. See Rev. Rul. 99–17, page 4.
Section 467.—Certain
Payments for the Use of
Property or Services
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of April 1999. See Rev. Rul. 99–17, page 4
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 April 1999. See Rev. Rul. 99–17, page 4.
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 April 1999. See
Rev. Rul. 99–17, page 4.

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 April 1999. See Rev. Rul. 99–17, page 4.
Section 642.—Special Rules for
Credits and Deductions
Federal short-term, mid-term, and long-term
rates are set forth for the month of April 1999. See
Rev. Rul. 99–17, page 4.
Section 807.—Rules for Certain
Reserves
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of April 1999. See Rev. Rul. 99–17, page 4.
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 April 1999. See Rev. Rul. 99–17, page 4.
Section 911.—Citizens or
Residents of the United States
Living Abroad
26 CFR 1.911–1: Partial exclusion for earned
income sources within a foreign country and foreign
housing costs.
Guidance is provided to individuals who fail to
meet the eligibility requirements of section
911(d)(1) of the Internal Revenue Code because ad-
verse conditions in a foreign country preclude the
individual from meeting those requirements. A cur-
rent list of countries and the dates of those countries
are subject to the section 911(d)(4) waiver is pro-
vided. See Rev. Proc. 99–20, page 7.
Section 1274.—Determination
of Issue Price in the Case of
Certain Debt Instruments Issued
for Property
(Also Sections 42, 280G, 382, 412, 467, 468, 482,
483, 642, 807, 846, 1288, 7520, 7872.)
Federal rates; adjusted federal rates;
adjusted federal long-term rate, and
the long-term exempt rate.For purposes
of sections 1274, 1288, 382, and other
sections of the Code, tables set forth the
rates for April 1999.
Rev. Rul. 99-17
This revenue ruling provides various
prescribed rates for federal income tax
purposes for April 1999 (the current
month.) Table 1 contains the short-term,
mid-term, and long-term applicable fed-
eral rates (AFR) for the current month for
purposes of section 1274(d) of the Inter-
nal Revenue Code. Table 2 contains the
short-term, mid-term, and long-term ad-
justed applicable federal rates (adjusted
AFR) for the current month for purposes
of section 1288(b). Table 3 sets forth the
adjusted federal long-term rate and the
long-term tax-exempt rate described in
section 382(f). Table 4 contains the ap-
propriate percentages for determining the
low-income housing credit described in
section 42(b)(2) for buildings placed in
service during the current month. Finally,
Table 5 contains the federal rate for deter-
mining the present value of an annuity, an
interest for life or for a term of years, or a
remainder or a reversionary interest for
purposes of section 7520.
April 5, 199941999–14 I.R.B.
REV. RUL. 99–17 TABLE 1
Applicable Federal Rates (AFR) for April 1999
Period for Compounding
AnnualSemiannual Quarterly Monthly
Short-Term
AFR4.99%4.93%4.90%4.88%
110% AFR5.49%5.42%5.38%5.36%
120% AFR6.01%5.92%5.88%5.85%
130% AFR6.51%6.41%6.36%6.33%
Mid-Term
AFR5.28%5.21%5.18%5.15%
110% AFR5.81%5.73%5.69%5.66%
120% AFR6.35%6.25%6.20%6.17%
130% AFR6.88%6.77%6.71%6.68%
150% AFR7.97%7.82%7.75%7.70%
175% AFR9.33%9.12%9.02%8.95%
Long-Term
AFR5.67%5.59%5.55%5.53%
110% AFR6.24%6.15%6.10%6.07%
120% AFR6.82%6.71%6.65%6.62%
130% AFR7.40%7.27%7.21%7.16%

REV. RUL. 99–17 TABLE 2
Adjusted AFR for April 1999
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
adjusted AFR3.18%3.16%3.15%3.14%
Mid-term
adjusted AFR3.82%3.78%3.76%3.75%
Long-term
adjusted AFR4.78%4.72%4.69%4.67%
1999–14 I.R.B.5April 5, 1999
REV. RUL. 99–17 TABLE 3
Rates Under Section 382 for April 1999
Adjusted federal long-term rate for the current month4.78%
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.)4.78%
REV. RUL. 99–17 TABLE 4
Appropriate Percentages Under Section 42(b)(2) for April 1999
Appropriate percentage for the 70% present value low-income housing credit8.28%
Appropriate percentage for the 30% present value low-income housing credit 3.55%
REV. RUL. 99–17 TABLE 5
Rate Under Section 7520 for April 1999
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 interest6.4%
Section 1288.—Treatment of
Original Issue Discount on
Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of April 1999. See Rev. Rul. 99–17, page 4.
Section 7520.—Valuation Tables
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of April 1999. See Rev. Rul. 99–17, page 4.
Section 7872.—Treatment of
Loans With Below-Market
Interest Rates
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of April 1999. See Rev. Rul. 99–17, page 4.

Table 1
Rules Applicable to LTCGs Distributed in Tax Year 1997
Pre-1997 LTCGs realized LTCGs realized LTCGs realized
LTCGsfrom 1/1/97-5/6/97from 5/7/97-7/28/97from 7/29/97-12/31/97
20%28% if property 28% for collectibles gain28% if property held > 12 months
held > 12 monthsand < 18 months or for collectibles
gain
25% if property held > 12 months and25% if property held > 18 months
LTCG is unrecaptured § 1250 gainand LTCG is unrecaptured § 1250
gain
20% for all other property 20% for all other property held >
held > 12 months18 months
April 5, 199961999–14 I.R.B.
Post-1997 Distributions of
Capital Gains from Charitable
Remainder Trusts
Notice 99–17
This notice modifies Notice 98–20,
1998–13 I.R.B. 25, to reflect changes
made to § 1(h) of the Internal Revenue
Code by §§ 4002(i)(3) and 4003(b) of the
Tax and Trade Relief Extension Act of
1998 (Division J of H.R. 4328, Omnibus
Consolidated and Emergency Supplemen-
tal Appropriations Act, 1999), Pub. L. No.
105–277, 112 Stat. 2681 (1998) (TTREA
of 1998). The changes affect the treat-
ment of post-1997 distributions of certain
capital gains properly taken into account
in 1997 by a charitable remainder trust
(CRT) described in § 664.
BACKGROUND
Notice 98–20 provides guidance on the
ordering and taxation of distributions
under § 664(b)(2) from a CRT to reflect
changes made to § 1(h) by the Taxpayer
Relief Act of 1997 (TRA 1997), Pub. L.
No. 105–34, § 311, 111 Stat. 788, 831.
TRA 1997 amended § 1(h) to provide for
new capital gain tax rates for noncorpo-
rate taxpayers. Under Notice 98–20, a
CRT’s long-term capital gains (LTCGs)
and losses fall into three separate tax rate
groups: (1) the 28-percent group, (2) the
25-percent group, and (3) the 20-percent
group. Grouping of LTCGs properly
taken into account by a CRT is necessary
in order to determine the treatment of dis-
tributions by the CRT. Notice 98–20 pro-
vides that LTCGs properly taken into ac-
count by a CRT from January 1, 1997,
through May 6, 1997, are treated as
LTCGs in the 28-percent group.
Section 4002(i)(3) of the TTREA of
1998 added § 1(h)(13)(D). New § 1(h)-
(13)(D) provides that § 1(h)(13)(A) and
§ 1(h)(13)(B)(ii) (providing 28-percent
rate treatment for certain LTCGs properly
taken into account in 1997) do not apply
to any capital gain distribution made by a
CRT, effective for taxable years ending
after December 31, 1997. Because
§ 1(h)(13)(A) and § 1(h)(13)(B)(ii) do not
apply to a CRT distribution for taxable
years ending after December 31, 1997,
LTCGs (other than collectibles gain)
properly taken into account by a CRT dur-
ing 1997 and distributed in taxable years
ending after December 31, 1997, that
would have been in the 28-percent group
now fall within either the 25-percent
group or the 20-percent group.
To reflect the changes made to § 1(h)
by § 4002(i)(3) of the TTREA of 1998,
this present notice modifies two sections
of Notice 98–20: (1) 1997 PRE-EFFEC-
TIVE DATE LONG-TERM CAPITAL
GAINS and (2) EXAMPLE ILLUS-
TRATING ORDERING AND CHARAC-
TER RULES. The 1997 PRE-EFFEC-
TIVE DATE LONG-TERM CAPITAL
GAINS section of Notice 98–20 should
be disregarded for taxable years ending
after December 31, 1997. In the EXAM-
PLE ILLUSTRATING ORDERING
AND CHARACTER RULES section of
Notice 98–20, the 28-percent group gain
is changed to collectibles gain.
DISCUSSION
The character of a CRT’s income is de-
termined at the time the income is real-
ized by the trust. Under § 1(h)(13)(D), a
CRT’s LTCG in the 28-percent group
(other than collectibles gain) that was
properly taken into account during 1997
and distributed in taxable years ending
after December 31, 1997, falls within ei-
ther the 25-percent group or the 20-per-
cent group. Thus, a CRT’s LTCG de-
scribed in the previous sentence now falls
within the 25-percent group if the gain (1)
was from property held more than 12
months but not more than 18 months, (2)
was properly taken into account for the
portion of the taxable year after July 28,
1997, and before January 1, 1998, and (3)
otherwise satisfies the requirements for
unrecaptured § 1250 gain under § 1(h)(7);
any remaining LTCG falls within the 20-
percent group.
To reflect this change in law, some
CRTs will need to remove from the 28-
percent group any LTCGs (other than col-
lectibles gain) properly taken into account
during 1997 that were not distributed in
taxable year 1997 and place those LTCGs
in either the 25-percent group or the 20-
percent group, as appropriate.
Tables 1 and 2 illustrate the recent
changes made to § 1(h) and their effect on
CRTs.
Part III. Administrative, Procedural, and Miscellaneous

Table 2
Rules Applicable to LTCGs Distributed in Post-1997 Tax Years
Pre-1997 LTCGs realized LTCGs realized LTCGs realized
LTCGsfrom 1/1/97-5/6/97from 5/7/97-7/28/97from 7/29/97-12/31/97
No change–Change–20%if property No change–28% for collectibles Change–28% onlyfor collectibles gain
20%held > 12 monthsgain
No change–25% if property Change–25% if property held > 12
held > 12 months and LTCGmonths and LTCG is unrecaptured
is unrecaptured § 1250 gain§ 1250 gain
No change–20% for all other Change–20% for all other property held
property held > 12 months> 12 months
1999–14 I.R.B.7April 5, 1999
EFFECTIVE DATE
The statutory changes described in this
notice apply to CRT distributions made in
taxable years ending after December 31,
1997.
EFFECT ON OTHER DOCUMENTS
Notice 98–20 is modified.
DRAFTING INFORMATION
The principal author of this notice is
Mary Beth Collins of the Office of Assis-
tant Chief Counsel (Passthroughs and
Special Industries). For further informa-
tion regarding this notice, contact Ms.
Collins on (202) 622-3080 (not a toll-free
call).
26 CFR 601.105: Examination of returns and
claims for refund, credit, or abatement;
determination of correct tax liability.
(Also Part I, section 911, 1.911–1)
Rev. Proc. 99–20
SECTION 1. PURPOSE
01. This revenue procedure provides
information to any individual who failed
to meet the eligibility requirements of
§ 911(d)(1) of the Internal Revenue Code
because adverse conditions in a foreign
country precluded the individual from
meeting those requirements for taxable
year 1998.
02. The Internal Revenue Service has
previously listed countries for which the
eligibility requirements of § 911(d)(1) of
the Code are waived under § 911(d)(4)
because of adverse conditions in those
countries on and after the date stated. See
Rev. Proc. 98–38, 1998–27 I.R.B. 29,
Rev. Proc. 97–51, 1997–2 C.B. 526, and
Rev. Proc. 96–33, 1996–1 C.B. 720. This
revenue procedure lists countries added to
the list in 1998, for which the eligibility
requirements of § 911(d)(1) are waived.
Rev. Proc. 98–38, Rev. Proc. 97–51, and
Rev. Proc. 96–33 remain in full force and
effect.
SEC. 2. BACKGROUND
01. Section 911(a) of the Code allows
a “qualified individual,” as defined in
§ 911(d)(1), to exclude foreign earned in-
come and housing cost amounts from
gross income. Section 911(c)(3) of the
Code allows a qualified individual to
deduct housing cost amounts from gross
income.
02. Section 911(d)(1) of the Code de-
fines the term “qualified individual” as an
individual whose tax home is in a foreign
country and who is (A) a citizen of the
United States and establishes to the satis-
faction of the Secretary of the Treasury
that the individual has been a bona fide
resident of a foreign country or countries
for an uninterrupted period that includes
an entire taxable year, or (B) a citizen or
resident of the United States who, during
any period of 12 consecutive months, is
present in a foreign country or countries
during at least 330 full days.
03. Section 911(d)(4) of the Code pro-
vides an exception to the eligibility re-
quirements of § 911(d)(1). An individual
will be treated as a qualified individual
with respect to a period in which the indi-
vidual was a bona fide resident of, or was
present in, a foreign country if the indi-
vidual left the country during a period for
which the Secretary of the Treasury, after
consultation with the Secretary of State,
determines that individuals were required
to leave because of war, civil unrest, or
similar adverse conditions that precluded
the normal conduct of business. An indi-
vidual must establish that but for those
conditions the individual could reason-
ably have been expected to meet the eligi-
bility requirements.
04. For 1998, the Secretary of the Trea-
sury in consultation with the Secretary of
State, has determined that war, civil un-
rest, or similar adverse conditions that pre-
cluded the normal conduct of business ex-
isted in the following countries beginning
on or after the specified dates:
Date of Departure
CountryOn or After
AlbaniaAugust 14, 1998
Democratic
Republic of
the CongoAugust 5, 1998
EritreaJune 5, 1998
Guinea-BissauJune 10, 1998
IndonesiaMay 15, 1998
PakistanAugust 16, 1998
Sierra LeoneDecember 23, 1998
Serbia-MontenegroOctober 11, 1998
05. Accordingly, for purposes of § 911
of the Code, an individual who left one of
the foregoing countries on or after the
specified departure date shall be treated as
a qualified individual with respect to the
period during which that individual was
present in, or was a bona fide resident of,

such foreign country if the individual es-
tablishes a reasonable expectation of
meeting the requirements of § 911(d) but
for those conditions.
06. To qualify for relief under
§ 911(d)(4) of the Code, an individual
must have established residency or have
been physically present in the foreign
country on or prior to the date that the
Secretary of the Treasury determines that
individuals were required to leave the for-
eign country. Individuals who establish
residency or are first physically present in
the foreign country after the date that the
Secretary prescribes, shall not be treated
as qualified individuals under § 911(d)(4)
of the Code pursuant to § 911(d)(4)(C).
For example, individuals who are first
physically present in Albania after August
14, 1998, are not eligible to qualify for the
exemption prescribed in § 911(d)(4) of
the Code for taxable year 1998.
07. In order to assist those individuals
who are filing prior year or amended tax
returns, the Internal Revenue Service is
republishing the countries added to the
list for tax years 1995, 1996 and 1997, for
which the eligibility requirements of
§ 911(d)(1) of the Code are waived under
§ 911(d)(4):
Tax Year 1995 - No new departure
dates were added to the list.
April 5, 199981999–14 I.R.B.
Tax Year 1996–
Date of Departure
CountryOn or AfterOn or Before
Central African RepublicMay 21, 1996September 12, 1996
Tax Year 1997–
Date of Departure
CountryOn or After
AlbaniaMarch 12,1997
CambodiaJuly 9, 1997
Central African RepublicMarch 28, 1997
Democratic Republic of the CongoMay 3, 1997
Republic of the CongoJune 7, 1997
Sierra LeoneMay 28, 1997
TajikistanNovember 26, 1997
SEC. 3. INQUIRES
A taxpayer who needs assistance on
how to claim this exclusion, or on how to
file an amended return, should contact a
local IRS Office or, for a taxpayer resid-
ing or traveling outside the United States,
the nearest overseas IRS office.
SEC. 4. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 98–38, 1998–27 I.R.B. 29 is
supplemented.
DRAFTING INFORMATION
The principal author of this revenue
procedure is Kate Y. Hwa of the Office of
Associate Chief Counsel (International).
For further information regarding this
revenue procedure contact Ms. Hwa at
(202) 622-3840 (not a toll-free call).

1999–14 I.R.B.9April 5, 1999
Part IV. Items of General Interest
Notice of Proposed Rulemaking
and Notice of Public Hearing
Electronic Funds Transfers of
Federal Deposits
REG–100729–98
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of proposed rulemak-
ing and notice of public hearing.
SUMMARY: This document contains
proposed regulations relating to the de-
posit of Federal taxes by electronic funds
transfer (EFT). The proposed regulations
affect certain taxpayers required to make
deposits of Federal taxes. For calendar
years beginning after 1999, the proposed
regulations provide rules under which
certain taxpayers must make deposits by
EFT.
DATES: Written and electronic com-
ments must be received by May 24, 1999.
Outlines and topics to be discussed at the
public hearing scheduled for May 11,
1999, at 10 a.m. must be received by
April 20, 1999.
ADDRESSES: Send submissions to:
CC:DOM:CORP:R (REG–100729–98),
room 5226, Internal Revenue Service,
POB 7604, Ben Franklin Station, Wash-
ington, DC 20044. Submissions may be
hand delivered Monday through Friday
between the hours of 8 a.m. and 5 p.m. to:
CC:DOM:CORP:R (REG–100729–98),
Courier’s Desk, Internal Revenue Ser-
vice, 1111 Constitution Avenue NW,
Washington, DC. Alternatively, taxpayers
may submit comments electronically via
the Internet by selecting the “Tax Regs”
option on the IRS Home Page, or by sub-
mitting comments directly to http://www.
irs.ustreas.gov/prod/tax_regs/comments.
html (the IRS Internet address). The pub-
lic hearing will be held in room 2615, In-
ternal Revenue Building, 1111 Constitu-
tion Ave. NW, Washington, DC.
FOR FURTHER INFORMATION CON-
TACT: Concerning the proposed regula-
tions, Vincent Surabian, (202) 622-4940;
concerning submission of comments, the
hearing, and/or to be placed on the build-
ing access list to attend the hearing,
Michael Slaughter, (202) 622-7190 (not
toll-free numbers).
SUPPLEMENTARY INFORMATION:
Background
This document contains proposed
amendments to the Income Tax Regula-
tions (26 CFR part 1), the Estate Tax Reg-
ulations (26 CFR part 20), the Gift Tax
Regulations (26 CFR part 25), the Em-
ployment Taxes and Collection of Income
Tax at Source Regulations (26 CFR part
31), and the Excise Tax Procedural Regu-
lations (26 CFR part 40).
On July 14, 1997, the IRS issued final
regulations under section 6302(h) of the
Internal Revenue Code relating to the de-
posit of Federal taxes by EFT (T.D. 8723,
62 F.R. 37490).
Those final regulations gradually phase
taxpayers into the EFT system through
1999. In the final stages of the phase-in
under those regulations, taxpayers with
more than $50,000 in employment tax de-
posits during calendar year 1995, 1996, or
1997, and taxpayers that, in any of those
years, had no employment tax deposits
but made deposits of other depository
taxes exceeding $50,000, were required to
begin to deposit by EFT.
At present, the regulations do not re-
quire EFT use by a new or growing tax-
payer with annual deposits that did not
exceed the prescribed threshold for the
first time before 1998.
Explanation of Provisions
1. Increase in Current $50,000 Threshold
Section 6302(h) requires that in fiscal
year 1999 and subsequent years 94 per-
cent of employment taxes and 94 percent
of other depository taxes be collected by
EFT. The IRS and Treasury Department
previously concluded that the deposit
threshold had to be set at $50,000 to sat-
isfy this statutory requirement. More re-
cent experience suggests, however, that
the statutory requirement can be satisfied
even if the threshold is set at a substan-
tially higher level. Moreover, an increase
in the threshold would allow small busi-
nesses to make the transition to the EFT
system at their own pace as they adopt
electronic funds transfer in their other
business operations. Accordingly, the
proposed regulations increase the deposit
threshold to $200,000 in aggregate Fed-
eral tax deposits during a calendar year.
The new threshold will be applied ini-
tially to 1998 deposits, and taxpayers that
exceed the threshold in 1998 will be re-
quired to deposit by EFT in 2000 and sub-
sequent years. Taxpayers that first exceed
the threshold in 1999 or a subsequent year
will similarly be required to deposit by
EFT after a one-year grace period. A tax-
payer that exceeds the threshold will not be
permitted to resume making paper coupon
deposits if its deposits fall below $200,000
in a subsequent year. Although a similar
rule applies under the current regulations,
taxpayers that are currently required to de-
posit by EFT will be given a fresh start and
will not be required to use EFT unless they
exceed the $200,000 threshold in 1998 or a
subsequent calendar year.
Under the new rules, only 9 percent of
all business taxpayers that make Federal
tax deposits will be required to deposit by
EFT. The fresh start will allow 65 percent
of the taxpayers subject to the EFT re-
quirement under the current regulations to
resume making paper coupon deposits be-
ginning in 2000. The IRS and Treasury
Department are confident, however, that
most of these taxpayers have come to ap-
preciate the simplicity and convenience of
the EFT system and will continue to de-
posit by EFT on a voluntary basis. The
continued participation of these taxpayers,
coupled with ongoing efforts to encourage
voluntary enrollment, should assure 94
percent collections by EFT notwithstand-
ing the increase in the threshold.
2. Taxes Taken into Account in Applying
Threshold
The current regulations prescribe one
threshold ($50,000 in employment taxes)
for depositors liable for employment
taxes and a separate threshold ($50,000 in
other taxes) for taxpayers with no em-
ployment tax liability. Thus, taxpayers
that deposit employment taxes but do not
exceed the applicable $50,000 threshold
are not subject to the EFT requirement
even if they deposit large amounts of

April 5, 1999101999–14 I.R.B.
other depository taxes. In Notice 97–43
(1997–2 C.B. 294), the IRS and Treasury
Department invited public comment on
two alternatives to these rules and also
welcomed any suggestions for a different
rule. The first alternative presented in
Notice 97–43 is a two-pronged test under
which a taxpayer that deposits more than
the threshold amount of the employment
taxes imposed by chapters 21, 22, and 24
or more than the threshold amount of
other depository taxes would be required
to deposit by EFT. The second alternative
is an aggregate deposits test under which
a taxpayer that deposits more than the
threshold amount of employment and
other taxes combined would be required
to deposit by EFT.
The IRS received six comments in re-
sponse to Notice 97–43. Two commenta-
tors stated that the aggregate deposits test
would be the most satisfactory. One of
these commentators stated that an aggre-
gate test (1) is simple for taxpayers to cal-
culate; (2) is easy for financial institutions
to calculate; and (3) is easy for the IRS to
monitor and maintain. The second com-
mentator favored an aggregate deposits
test because it would introduce a larger
number of taxpayers to the advantages
and efficiencies of the EFT system.
Two commentators stated that the pre-
sent system should be retained because of
its simplicity. One of these commentators
stated that a taxpayer need consider only
one set of figures, its employment taxes,
to determine if it is subject to EFT. If the
taxpayer has no employment taxes, then
the taxpayer would simply look at its
other depository taxes. The second com-
mentator favored the present rule because
of its belief that the adoption of either of
the two proposals described in Notice 97-
43 would bring additional smaller em-
ployers into the EFT system. The com-
mentator stated that it is unnecessary to
bring additional employers into the EFT
system because, under the current rule,
the IRS is satisfying the requirement of
section 6302(h) that more than 94 percent
of all depository taxes be deposited by
EFT for fiscal year 1999 and thereafter.
The proposed regulations adopt an ag-
gregate deposits test. As the comments il-
lustrate, there is disagreement concerning
the relative simplicity of the various op-
tions. The view of the IRS and Treasury
Department, based on experience with the
current system, is that an aggregate de-
posits test would be, on balance, simpler,
less confusing to taxpayers, and more eas-
ily administered than a two-threshold
rule. The aggregate deposits test also has
the advantage of eliminating the anom-
alous current treatment of taxpayers that
deposit small amounts of employment
taxes and large amounts of other taxes as
if they were smaller than taxpayers that
deposit no employment taxes but are oth-
erwise similarly situated. The IRS and
Treasury Department believe that the
other concern expressed in the comments,
that the aggregate deposits test would un-
necessarily extend the EFT system to ad-
ditional small employers, has been ade-
quately addressed by the proposed
increase in the threshold.
A fifth commentator suggested that a
rule be considered under which a taxpayer
could be relieved of the EFT deposit re-
quirement if the taxpayer, after being
mandated into the system, fails to deposit
the threshold amount during succeeding
calendar years. This suggestion has not
been adopted because of concerns that it
would be more complex and more diffi-
cult to administer than the proposed rule.
A final commentator stated that the cur-
rent regulations make no provision for the
consciences of persons whose religious
beliefs restrict the use of computer equip-
ment in their businesses. The IRS and
Treasury Department are continually sen-
sitive to the limited nature of the technol-
ogy available to many taxpayers and, for
that reason, have developed a system
under which, using the ACH debit option,
equipment no more complex than a rotary
or touch-tone telephone is all that is nec-
essary to make an EFT deposit. A com-
puter is not required.
3. Expansion of Voluntary Payments by
EFT
Finally, the current regulations allow
the voluntary payment by EFT of certain
nondepository taxes, specifically individ-
ual income taxes (including estimated
taxes). These proposed regulations ex-
pand the types of nondepository tax pay-
ments for which voluntary payment by
EFT is allowed to include nondepository
payments of Federal income, estate and
gift, employment, and various specified
excise taxes.
Special Analyses
It has been determined that this notice
of proposed rulemaking is not a signifi-
cant regulatory action as defined in EO
12866. Therefore, a regulatory assess-
ment is not required. It also has been de-
termined that section 553(b) of the Ad-
ministrative Procedure Act (5 U.S.C.
chapter 5) does not apply to these regula-
tions and, because these regulations do
not impose a collection of information re-
quirement on small entities, the Regula-
tory Flexibility Act (5 U.S.C. chapter 6)
does not apply. Pursuant to section
7805(f) of the Internal Revenue Code,
this notice of proposed rulemaking will be
submitted to the Chief Counsel for Advo-
cacy of the Small Business Administra-
tion for comment on its impact on small
business.
Proposed Effective Date
The regulations are proposed to be-
come effective on the date final regula-
tions are published in the Federal Regis-
ter.
Comments and Public Hearing
Before these proposed regulations are
adopted as final regulations, considera-
tion will be given to any electronic and
written comments (a signed original and
eight (8) copies) that are submitted timely
to the IRS. The IRS and Treasury Depart-
ment specifically request comments on
the clarity of the proposed regulations and
how they can be made easier to under-
stand. All comments will be available for
public inspection and copying.
A public hearing has been scheduled
for May 11, 1999, beginning at 10 a.m.
The hearing will be held in room 2615,
Internal Revenue Building, 1111 Consti-
tution Avenue, NW, Washington, DC.
Due to building security procedures, visi-
tors must enter at the 10th Street entrance,
located between Constitution and Penn-
sylvania Avenues, NW. In addition, all
visitors must present photo identification
to enter the building. Because of access
restrictions, visitors will not be admitted
beyond the immediate entrance area more
than 15 minutes before the hearing starts.
For information about having your name
placed on the building access list to attend
the hearing, see the FOR FURTHER IN-

1999–14 I.R.B.11April 5, 1999
FORMATION CONTACT section of this
preamble.
The rules of 26 CFR 601.601(a)(3)
apply to the hearing. Persons who wish to
present oral comments at the hearing must
submit written or electronic comments by
May 24, 1999, and submit an outline of
topics to be discussed and the time to be
devoted to each topic (a signed original
and eight (8) copies) by April 20, 1999.
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 receiving 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 Vincent Surabian, Office of Assis-
tant Chief Counsel (Income Tax & Ac-
counting). However, other personnel
from the IRS and Treasury Department
participated in their development.
*****
Proposed Amendments to the Regulations
Accordingly, 26 CFR parts 1, 20, 25,
31, and 40 are proposed to be amended as
follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 is amended by revising the entry for
§1.6302–4 to read as follows:
Authority: 26 U.S.C. 7805 * * *
Section 1.6302–4 also issued under
sections 6302(a), (c), and (h). * * *
Par. 2. Section 1.6302-4 is revised to
read as follows:
§1.6302–4 Use of financial institutions
in connection with income taxes;
voluntary payments by electronic funds
transfer.
Any person may voluntarily remit by
electronic funds transfer any payment of
tax imposed by subtitle A of the Internal
Revenue Code, including any payment of
estimated tax. Such payment must be
made in accordance with procedures pre-
scribed by the Commissioner.
PART 20—ESTATE TAX; ESTATES OF
DECEDENTS DYING AFTER
AUGUST 16, 1954
Par. 3. The authority citation for part
20 is amended by adding an entry in nu-
merical order to read as follows:
Authority: 26 U.S.C. 7805 * * *
Section 20.6302–1 also issued under
sections 6302(a) and (h). * * *
Par. 4. Section 20.6302–1 is added to
read as follows:
§20.6302–1 Voluntary payments of estate
taxes by electronic funds transfer.
Any person may voluntarily remit by
electronic funds transfer any payment of
tax to which this part 20 applies. Such
payment must be made in accordance
with procedures prescribed by the Com-
missioner.
PART 25—GIFT TAX; GIFTS MADE
AFTER DECEMBER 31, 1954
Par. 5. The authority citation for part
25 is amended by adding an entry in nu-
merical order to read as follows:
Authority: 26 U.S.C. 7805 * * *
Section 25.6302–1 also issued under
sections 6302(a) and (h). * * *
Par. 6. Section 25.6302–1 is added to
read as follows:
§25.6302–1 Voluntary payments of gift
taxes by electronic funds transfer.
Any person may voluntarily remit by
electronic funds transfer any payment of
tax to which this part 25 applies. Such
payment must be made in accordance
with procedures prescribed by the Com-
missioner.
PART 31—EMPLOYMENT TAXES
AND COLLECTION OF INCOME TAX
AT SOURCE
Par. 7. The authority citation for part
31 continues to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 8. Section 31.6302-1 is amended
as follows:
1. The heading for paragraph (h)(2) is
revised.
2. A heading is added for paragraph
(h)(2)(i).
3. New paragraph (h)(2)(i)(C) is
added.
4. Paragraph (h)(2)(ii) is revised
5. Paragraph (h)(2)(iii) is added.
6. Paragraph (m) is redesignated as
paragraph (n).
7. Paragraph (k) is redesignated as
paragraph (m).
8. Paragraph (j) is redesignated as
paragraph (k).
9. New paragraph (j) is added.
The additions and revisions read as fol-
lows:
§31.6302–1 Federal tax deposit rules for
withheld income taxes and taxes under
the Federal Insurance Contributions Act
(FICA) attributable to payments made
after December 31, 1992.
* * * * *
(h) * * *
(2) Applicability of requirement—(i)
Deposits for return periods beginning be-
fore January 1, 2000.* * *
(C) This paragraph (h)(2)(i) applies
only to deposits required to be made for
return periods beginning before January
1, 2000. Thus, a taxpayer, including a
taxpayer that is required under this para-
graph (h)(2)(i) to make deposits by elec-
tronic funds transfer beginning in 1999 or
an earlier year, is not required to use elec-
tronic funds transfer to make deposits for
return periods beginning after December
31, 1999, unless deposits by electronic
funds transfer are required under para-
graph (h)(2)(ii) of this section.
(ii) Deposits for return periods begin-
ning after December 31, 1999.Unless
exempted under paragraph (h)(5) of this
section, a taxpayer that deposits more
than $200,000 of taxes described in para-
graph (h)(3) of this section during a calen-
dar year beginning after December 31,
1997, must use electronic funds transfer
(as defined in paragraph (h)(4) of this sec-
tion) to make all deposits of those taxes
that are required to be made for return pe-
riods beginning after December 31 of the
following year and must continue to de-
posit by electronic funds transfer in all
succeeding years. Thus, a taxpayer that
exceeds the $200,000 deposit threshold
during calendar year 1998 is required to

April 5, 1999121999–14 I.R.B.
make deposits for return periods begin-
ning in calendar year 2000 by electronic
funds transfer.
(iii) Voluntary deposits.A taxpayer
that is not required by this section to use
electronic funds transfer to make a de-
posit of taxes described in paragraph
(h)(3) of this section may voluntarily
make the deposit by electronic funds
transfer, but remains subject to the rules
of paragraph (i) of this section, pertaining
to deposits by Federal tax deposit (FTD)
coupon, in making deposits other than by
electronic funds transfer.
* * * * *
(j) Voluntary payments by electronic
funds transfer. Any person may voluntar-
ily remit by electronic funds transfer any
payment of tax imposed by subtitle C of
the Internal Revenue Code. Such pay-
ment must be made in accordance with
procedures prescribed by the Commis-
sioner.
* * * * *
PART 40—EXCISE TAX
PROCEDURAL REGULATIONS
Par. 9. The authority citation for part
40 is amended by adding an entry in nu-
merical order to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Section 40.6302(a)-1 also issued under
26 U.S.C. 6302(a) and (h). * * *
Par. 10. Section 40.6302(a)-1 is added
to read as follows:
§40.6302(a)–1 Voluntary payments of
excise taxes by electronic funds transfer.
Any person may voluntarily remit by
electronic funds transfer any payment of
tax to which this part 40 applies. Such
payment must be made in accordance
with procedures prescribed by the Com-
missioner.
Robert E. Wenzel,
Deputy Commissioner of
Internal Revenue.
(Filed by the Office of the Federal Register on
March 22, 1999, 8:45 a.m., and published in the
issue of the Federal Register for March 23, 1999, 64
F.R. 13940)
Proposed Form 1042-S, Foreign
Person’s U.S. Source Income
Subject to Withholding
Announcement 99–24
The Internal Revenue Service an-
nounces that it is requesting comments
from the public on proposed revisions to
Form 1042-S. The form is being revised
as a result of final regulations (T.D. 8734,
62 F.R. 53387; 1997–2 C.B. 109) pub-
lished on October 14, 1997, relating to the
withholding of income tax under sections
1441, 1442, and 1443 on certain U.S.
source income paid to foreign persons.
Form 1042-S is used by U.S. withhold-
ing agents to report the withholding of
U.S. income tax on certain U.S. source in-
come paid to foreign persons.
This announcement provides a draft
copy of proposed revisions to Form 1042-
S. The form is being issued so that with-
holding agents can adapt their systems to
comply with the regulations. Filers and
recipients of the form are advised that the
form may be revised based on further de-
velopments and comments. The form, to-
gether with instructions, will be re-issued
for further comment as part of the OMB
approval process.
The IRS would like to receive com-
ments on this proposed draft form from
all interested persons by May 5, 1999.
Please send comments to Chairman, Tax
Forms Coordinating Committee, Internal
Revenue Service, OP:FS:FP, Room 5577,
1111 Constitution Avenue, NW, Washing-
ton, DC 20224. Alternatively, you may e-
mail your comments to tfpmail@pub-
lish.no.irs.gov.

1999–14 I.R.B.13April 5, 1999

April 5, 1999141999–14 I.R.B.

1999–14 I.R.B.15April 5, 1999

April 5, 1999161999–14 I.R.B.

1999–14 I.R.B.17April 5, 1999

April 5, 1999181999–14 I.R.B.

1999–14 I.R.B.19April 5, 1999

April 5, 1999201999–14 I.R.B.
New Revision of Publication
954, Tax Incentives for
Empowerment Zones and Other
Distressed Communities
Announcement 99–26
Publication 954, revised February
1999, is now available from the Internal
Revenue Service. It replaces the March
1998 revision.
This publication is primarily for busi-
ness owners who want to find out whether
they qualify for certain tax incentives cre-
ated to increase business activity in dis-
tressed communities.
You can get a copy of this publication
by calling 1-800-TAX-FORM (1-800-
829-3676). You can also write to the IRS
Forms Distribution Center nearest you.
Check your income tax package for the
address. The publication is also available
on the IRS Internet Web site at www.irs.
ustreas.gov.
Foundations Status of Certain
Organizations
Announcement 99–32
The following organizations have
failed to establish or have been unable to
maintain their status as public charities or
as operating foundations. Accordingly,
grantors and contributors may not, after
this date, rely on previous rulings or des-
ignations in the Cumulative List of Orga-
nizations (Publication 78), or on the pre-
sumption arising from the filing of notices
under section 508(b) of the Code. This
listing does notindicate that the organiza-
tions have lost their status as organiza-
tions described in section 501(c)(3), eligi-
ble to receive deductible contributions.
Former Public Charities.The following
organizations (which have been treated as
organizations that are not private founda-
tions described in section 509(a) of the
Code) are now classified as private foun-
dations:
Argonne Publishing Inc., Durham, NC
Birmingham Area Council of
Beautification Boards, Birmingham, AL
Careplus Endowment Program,
Washington Grove, MD
Class Inc., Santa Fe, NM
Community Evangelism & Discipleship,
Ooleteway, TN
Community Network, Inc., Chester, PA
D & R Inc. of Myrtle Beach, Myrtle,
Beach, SC
D & T Kare, New Orleans, LA
David H. Patterson Ministries, Inc.,
Kernersville, NC
DELVAHouse Inc., Marinette, WI
D FY IT, Inc., Tucson, AZ
Daedalus Foundation, Philadelphia, PA
Dallas A&M Club, Dallas, TX
Dallas Family Resources Inc., Dallas, TX
Dalton Benefit Association, Dalton, MA
Damas Unidas Latino-Americanas Inc.,
Bellerose, NY
Damascus Road Ministries Inc.,
Arkansas, City, KS
Dance Experience, Columbia, SC
Dance Kids Inc., Carmel, CA
Dance Theatre of Corpus Christi, Corpus
Christi, TX
Danceart Isadora Inc., New York, NY
Dancers Edge, Austin, TX
Dane County Democratic Party
Education Scholarship Fund Inc.,
Madison, WI
Danvers American Legion Baseball Fund
Post 180, Danvers, MA
Das Yosef Charity TR, Brooklyn, NY
Daughters in Progress Clubs, Bay City,
TX
Daves Arid Club Inc., Nocona, TX
David Layne Ministries Inc., Farmville,
VA
David Smiles, Grand Junction, CO
David Young Ministries Inc., Broken
Arrow, OK
De Best Shared Housing Inc., Baltimore,
MD
Deaf AIDS Coalition, Chicago, IL
Deaf Childrens Athletic Association,
Fountain Valley, CA
Deb Scholarship Fund, W Wareham,
MA
Debra Lynn Woods Theatre, Dallas, TX
Deep Creek Raptor and Wildlife
Rehabilitation Center, Missoula, MT
Deerfield Neighborhood Association,
Colorado Springs, CO
Delaware Teachers Academy for Service
Learning Association, Seaford, DE
Delaware Valley Concerned Citizens
Preservation Inc., Paulsboro, NJ
Delaware Valley Ethics Committee
Network, Laverock, PA
Delegation Established to End
Recividism Inc., New York, NY
Deliverance Centers of Hope Inc.,
Philadelphia, PA
Deliverance Grocery & Deli Institute
Inc., Houston, TX
Denny Plattner Memorial scholarship
Fund Inc., Cold Spring, KY
Deporres Eagles Club, Southfield, MI
Derek Scott Ministries, Dallas, TX
Des Moines Housing Authority
Foundation Inc., Des Moines, IA
Desiree Dottoli Scholarship Fund Inc.,
Waterford, NJ
Desoto County Soccer Association,
Memphis, TN
Developing Economical and Better
Living Inc., Chicago, IL
Developing Education Leadership and
Occupations for Neighborhood,
Paterson, NJ
Developing Industrial Skills &
Knowledge Inc., New York, NY
Dew of Hermon China Mission, Garden
Grove, CA
Diamond in the Rough, Riverside, CA
Diamond Management Youth Corp.,
Jersey City, NJ
Dick Tate Productions Inc., Milwaukee,
WI
Dillon Alano Club, Dillon, MT
Dine Foundation Inc., Amherst, NY
Disabled Travelers Friendship Network
Inc., Orlando, FL
Disaster Survival Foundation Inc.,
Ardsley, NY
Distinguished Men and Women Youth
Development Agency Inc., Dallas,
TX
District 200 CO Curricular Boosters,
Woodstock, IL
Diversity Inc., Indianapolis, IN
Divine Light Service Inc., Bayside, WI
Divorce Prevention International
Foundation, Rancho Cordova, CA
DLM Health Services, Guilford, ME
Dodi Yavoh, Collinsville, IL
DOE Valley Volunteer Fire Department,
Mountain City, TN
Doingsomething Inc., Minneapolis, MN
Dollie Lowther Robinson Foundation
Inc., New York, NY
Dolphinback Theatre Company, Chicago,
IL
Domestic Violence Training and
Resource Institute, Acton, MA
Don Bosco Club DBC Inc., Brooklyn,
NY
Don Jackson Ministries Inc.,
Thermopolis, WY
Door to Hope Inc., Jacksonville, FL
Dorothys Kitchen, Chadron, NE

1999–14 I.R.B.21April 5, 1999
Dothan Independent Living Center Inc.,
Dothan, AL
Douglass Policy Institute, Washington,
DC
Downstate Sickle Cell Anemia
Association, Peoria, IL
Downtown Middletown Partnership Inc.,
Middletown, OH
Dr Huey P Newton Foundation, Berkeley,
CA
Dr Jorge Prieto Community Clinic,
Chicago, IL
Dream, Nashville, TN
Dredf Development Partnership Inc.,
Berkeley, CA
Dress for Success Inc., North Potomac,
MD
Dress Smart Inc., Milwaukee, WI
Drug and Life Style and Addiction
Project Inc., Atlanta, GA
Dufour Baldwin House Museum &
Gardens Inc., New Orleans, LA
Dumas Community Rescue Mission,
Dumas, AR
Dunamis, Detroit, MI
Dupage County Crime Stoppers,
Wheaton, IL
Durham County Friends of Black
Children Council, Durham, NC
Educational Software Fdn., Rochester
Hills, MI
FACTNet Inc. – Fight Against
Coercive Tactics Network, Golden, CO
F and M Community Corporation Inc.,
Youngstown, OH
F L A M E Inc., Framingham, MA
FRIENDS 7, Jacksonville, NC
Fair Play for Women Athletes an Oregon
Non-profit Organization, Hood River,
OR
Fairfield Jets Track Club Association,
Fairfield, CA
Fairfield Residential Program Inc.,
Fairfield, CA
Fairgrounds Racing Museum Inc.,
New Orleans. LA
Faith Bible Christian Center, Dallas, TX
Faith Community Singers Inc., Houston,
TX
Faith Forum Inc., Atlanta, GA
Faith in Action International Inc., Burr
Ridge, IL
Faith in Serving Humanity Inc., Monroe,
GA
Fall River Five Cents Savings Bank, Fall
River, MA
Falstaff Presents, New York, NY
Families Against Drugs and Abuse Inc.,
Margate, FL
Families and Mentors Instituting
Leadership for Youth, Hollandale, MS
Families are Important to Him, Green
Camp, OH
Families are Special Inc., N Little Rock,
AR
Family & Friends in Support of Children
of Divorce Inc., Phoenix, AZ
Family Advisory Council on Education,
Greensboro, NC
Family Awareness Project, Sioux Falls,
SD
Family Day Care Association of Nassau
County Inc., W Hempstead, NY
Family Focus Inc., Reedsburg, WI
Family Health Organization Inc.,
Bayside, WI
Family Life and Christian Womens
Foundation, Englewood, CO
Family Memories Foundation Inc.,
Stanhope, NJ
Family Nurturing Center of Indiana Inc.,
Indianapolis, IN
Family Outreach of Magnolia Columbia
County Inc., Magnolia, AR
Family Psychological Center of Elk
Grove, Elk Grove, CA
Family Reflections Nonprofit Housing
Corporation, East Lansing, MI
Family Resource Center Advisory Board
Inc., Eagle Pass, TX
Family Support Systems Unlimited
Housing Developments Fund Corp.,
Bronx, NY
Family Worship Center Church Inc.,
Penns Grove, NJ
Farleys Aquatic Research Laboratory
Inc., Tallahassee, FL
Farm Financial Standards Task Force,
Omaha, NE
Farm Workers Housing Inc., Manning,
SC
Farragut High School Football Boosters
Club Inc., Knoxville, TN
Fashion Outreach Inc., New York, NY
Fathers Against Violence Inc., Carlisle,
MA
Fathers Education Network Inc., Detroit,
MI
Fathers Network of Orange County,
Irvine, CA
Fathers Raising Children Alone Inc.,
Pasadena, TX
Fathers Working with Fathers, Dayton,
OH
Fayetteville Baseball Boosters Assn.,
Fayetteville, AR
Feagin Day Care Center, North Long
Beach, CA
Fearless, Grinnell, IA
Federal Gay Lesbian Bi-Sexual
Employees of Texas Inc., Dallas, TX
Federal Way Veterans Center &
Homestart Transition Program, Federal
Wa y, WA
Federation of Gujarati Associations in
North America, Spring Valley, OH
Fedohny Inc., New York, NY
Feed my Sheep by the Word of God
Outreach Inc., Houston, TX
Feed the People, Beaumont, TX
Feline Friends Inc., Hudson, NY
Fellowship Development Group Inc.,
Milwaukee, WI
Fertile Ground Inc., New York, NY
Fflair Productions Inc., Miami, FL
Fieldhome Community Inc., Peekskill,
NY
Fifth Step House Society Inc., Seattle,
WA
Filarmonica Santo Antonio Inc.,
Cambridge, MA
Filipino American Scholarship
Foundation Inc., American Fork, UT
Financial and Estate Planning
Educational Foundation for Women,
Weston, MA
If an organization listed above submits
information that warrants the renewal of
its classification as a public charity or as a
private operating foundation, the Internal
Revenue Service will issue a ruling or de-
termination letter with the revised classi-
fication as to foundation status. Grantors
and contributors may thereafter rely upon
such ruling or determination letter as pro-
vided in section 1.509(a)–7 of the Income
Tax Regulations. It is not the practice of
the Service to announce such revised clas-
sification of foundation status in the Inter-
nal Revenue Bulletin.
New Revisions of Publication
547, Casualties, Disasters, and
Thefts (Business and Nonbusiness),
and Publication 584, Casualty,
Disaster, and Theft Loss Workbook
(Personal-Use Property)
Announcement 99–33

April 5, 1999221999–14 I.R.B.
The February 1999 revisions of Publi-
cation 547 and Publication 584 are now
available from the Internal Revenue Ser-
vice. These revisions replace the Febru-
ary 1998 revision of Publication 547 and
the November 1991 revision of Publica-
tion 584.
Publication 547 is primarily for indi-
viduals who want to find out about the tax
treatment of casualties, disasters, and
thefts. Publication 584 contains schedules
individuals can use to figure the loss on
their main home, its contents, and their
motor vehicles.
You can get copies of these publica-
tions by calling 1-800-TAX-FORM (1-
800-829-3676). You can also write to the
IRS Forms Distribution Center nearest
you. Check your income tax package for
the address. These publications are also
available on the IRS Internet Web site at
www.irs.ustreas.gov.
Passive Foreign Investment
Companies; Definition of
Marketable Stock; Correction
Announcement 99–35
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Correction to notice of pro-
posed rulemaking.
SUMMARY: This document contains a
correction to the notice of proposed rule-
making (REG–113744–98, 1999–10
I.R.B. 59), which was published in the
Federal RegisterTuesday, February 2,
1999 (64 F.R. 5012), relating to the new
mark to market election for stock of a pas-
sive foreign investment company.
FOR FURTHER INFORMATION CON-
TACT: Robert Laudeman (202) 622-
3840 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The notice of proposed rulemaking that
is the subject of this correction is under
section 1296 of the Internal Revenue
Code.
Need for Correction
As published, REG–113744–98 con-
tains an error which may prove to be mis-
leading and is in need of clarification.
Correction of Publication
Accordingly, the publication of the no-
tice of proposed rulemaking (REG–
113744–98), which was the subject of FR
Doc. 99-1666, is corrected as follows:
On page 5012, column 1, in the pream-
ble under the caption “ADDRESSES”,
line 9, the language “to: CC:DOM:
CORP:R (REG–110524–98),” is cor-
rected to read “to: CC:DOM:CORP:R
(REG–113744–98),”.
Cynthia E. Grigsby,
Chief, Regulations Unit,
Assistant Chief Counsel (Corporate).
(Filed by the Office of the Federal Register on
March 22, 1999, 8:45 a.m., and published in the
issue of the Federal Register for March 23, 1999, 64
F.R. 13939)
Section 7428(c) Validation of
Certain Contributions Made
During Pendency of Declaratory
Judgment Proceedings
This announcement serves notice to po-
tential donors that the organizations listed
below have recently filed timely declara-
tory judgment suits under section 7428 of
the Code, challenging revocation of their
status as eligible donees under section
170(c)(2).
Protection under section 7428(c) of the
Code begins on the date that the notice of
revocation is published in the Internal
Revenue Bulletin and ends on the date on
which a court first determines that an or-
ganization is not described in section
170(c)(2), as more particularly set forth in
section 7428(c)(1). In the case of individ-
ual contributors, the maximum amount of
contributions protected during this period
is limited to $1,000.00, with a husband
and wife being treated as one contributor.
This protection is not extended to any in-
dividual who was responsible, in whole or
in part, for the acts or omissions of the or-
ganization that were the basis for the re-
vocation. This protection also applies
(but without limitation as to amount) to
organizations described in section
170(c)(2) which are exempt from tax
under section 501(a). If the organization
ultimately prevails in its declaratory judg-
ment suit, deductibility of contributions
would be subject to the normal limitations
set forth under section 170.
Abraham Lincoln Opportunity
Foundation, Denver, CO
The Freedom Alliance
Dulles, VA

1999–14 I.R.B.23April 5, 1999
NameAddressDate of Resignation
Ellis, Ronald C.Billings, MTOctober 6, 1998
Announcement of the Consent Voluntary Suspension of Attorneys,
Certified Public Accountants, Enrolled Agents, and Enrolled Actuaries
From Practice Before the Internal Revenue Service
Under 31 Code of Federal Regulations,
Part 10, an enrolled agent, in order to
avoid the institution or conclusion of a
proceeding for his disbarment or suspen-
sion from practice before the Internal
Revenue Service, may offer his resigna-
tion from such practice. The Director of
Practice, in his discretion, may suspend
an enrolled agent in accordance with the
consent offered.
Attorneys, certified public accountants,
enrolled agents, and enrolled actuaries are
prohibited in any Internal Revenue Ser-
vice matter from directly or indirectly em-
ploying, accepting assistance from, being
employed by or sharing fees with, any en-
rolled agent who has resigned from prac-
tice before the Internal Revenue Service.
To enable attorneys, certified public ac-
countants, enrolled agents, and enrolled
actuaries to identify former enrolled
agents who have resigned from practice
before the Internal Revenue Service, the
Director of Practice will announce in the
Internal Revenue Bulletin the names and
addresses of former enrolled agents who
have resigned from such practice, and
date of resignation. This announcement
will appear in the weekly Bulletin at the
earliest practicable date after such action
and will continue to appear in the weekly
Bulletins for five successive weeks or for
as many weeks as is practicable for each
enrolled agent, who has resigned, and will
be consolidated and published in the Cu-
mulative Bulletin.
The following individual has offered
his resignation as an enrolled agent:

April 5, 1999241999–14 I.R.B.
Announcement of the Expedited Suspension of Attorneys, Certified Public
Accountants, Enrolled Agents, and Enrolled Actuaries From Practice
Before the Internal Revenue Service
Under Title 31 of the Code of Federal
Regulations, section 10.76, the Director
of Practice is authorized to immediately
suspend from practice before the Internal
Revenue Service any practitioner who,
within five years, from the date the expe-
dited proceeding is instituted, (1) has had
a license to practice as an attorney, certi-
fied public accountant, or actuary sus-
pended or revoked for cause; or (2) has
been convicted of any crime under title 26
of the United States Code or, of a felony
under title 18 of the United States Code
involving dishonesty or breach of trust.
Attorneys, certified public accountants,
enrolled agents, and enrolled actuaries are
prohibited in any Internal Revenue Service
matter from directly or indirectly employ-
ing, accepting assistance from, being em-
ployed by, or sharing fees with, any practi-
tioner disbarred or suspended from practice
before the Internal Revenue Service.
To enable attorneys, certified public ac-
countants, enrolled agents, and enrolled ac-
tuaries to identify practitioners under expe-
dited suspension from practice before the
Internal Revenue Service, the Director of
Practice will announce in the Internal Rev-
enue Bulletin the names and addresses of
practitioners who have been suspended
from such practice, their designation as at-
torney, certified public accountant, en-
rolled agent, or enrolled actuary, and date
or period of suspension. This announce-
ment will appear in the weekly Bulletin at
the earliest practicable date after such ac-
tion and will continue to appear in the
weekly Bulletins for five successive weeks
or for as many weeks as is practicable for
each attorney, certified public accountant,
enrolled agent, or enrolled actuary so sus-
pended and will be consolidated and pub-
lished in the Cumulative Bulletin.
The following individual have been
placed under suspension from practice be-
fore the Internal Revenue Service by virtue
of the expedited proceeding provisions of
the applicable regulations:
NameAddressDesignationDate of Suspension
Pierce, Steven J.Aventura, FLAttorneyIndefinite from October 15, 1998
Baker, Charles C.Monteagle, TNAttorneyIndefinite from October 15, 1998
Kantor, Stanley L.New York, NYAttorneyIndefinite from October 15, 1998
Wagner, Richard E.Spencerport, NYEnrolled AgentIndefinite from October 15, 1998
Tuohey, SeamusMontclair, NJAttorneyIndefinite from October 15, 1998
Burke, Beau E.Santa Rosa, CACPAIndefinite from October 15, 1998
Marn, Eric Y.Honolulu, HIAttorneyIndefinite from October 15, 1998
Todd, KennethTulsa, OKAttorneyIndefinite from November 4, 1998

1999–14 I.R.B.25April 5, 1999
NameAddressDesignationEffective Date
Shaw-Boatner, DeborahAustin, TXCPASeptember 24, 1998
Hannum, DavidPhiladelphia, PAEnrolled AgentSeptember 30, 1998
Miller, TheodoreNeshaminy Valley, PACPAFebruary 27, 1999
Announcement of the Disbarment and Suspension of Attorneys, Certified
Public Accountants, Enrolled Agents, and Enrolled Actuaries From
Practice Before the Internal Revenue Service
Under 330, Title 31 of the United
States Code, the Secretary of the Trea-
sury, after due notice and opportunity for
hearing, is authorized to suspend or dis-
bar from practice before the Internal Rev-
enue Service any person who has vio-
lated the rules and regulations governing
the recognition of attorneys, certified
public accountants, enrolled agents, or
enrolled actuaries to practice before the
Internal Revenue Service.
Attorneys, certified public accountants,
enrolled agents, and enrolled actuaries are
prohibited in any Internal Revenue Service
matter from directly or indirectly employ-
ing, accepting assistance from, being em-
ployed by, or sharing fees with, any practi-
tioner disbarred or under suspension from
practice before the Internal Revenue Ser-
vice.
To enable attorneys, certified public ac-
countants, enrolled agents, and enrolled
actuaries to identify such disbarred or sus-
pended practitioners, the Director
of Practice will announce in the Internal
Revenue Bulletin the names and ad-
dresses of practitioners who have been
suspended from such practice, their desig-
nation as attorney, certified public ac-
countant, enrolled agent, or enrolled actu-
ary, and date of disbarment or period of
suspension. This announcement will ap-
pear in the weekly Bulletin for five suc-
cessive weeks or as long as it is practica-
ble for each attorney, certified public
accountant, enrolled agent, or enrolled ac-
tuary so suspended or disbarred and will
be consolidated and published in the Cu-
mulative Bulletin.
After due notice and opportunity for
hearing before an administrative law
judge, the following individuals have
been disbarred from further practice be-
fore the Internal Revenue Service:

April 5, 1999261999–14 I.R.B.
NameAddressDesignationDate of Suspension
Cohn, IrvingBaltimore, MDAttorneySeptember 4, 1998 to September 3, 2000
Hwang, Catherine T.Livingston, NJCPAOctober 1, 1998 to September 30, 1999
Bratek, RonaldN. Brunswick, NJCPAOctober 5, 1998 to July 4, 2000
Walker, Frank O.Bay City, TXCPAOctober 5, 1998 to April 4, 2001
Ng, Peter J.Monticello, NYAttorneyOctober 5, 1998 to May 4, 2002
Sopkovich, CarolGirard, OHAttorneyOctober 5, 1998 to October 4, 2001
Kappler, John E.Evansville, INCPAOctober 8, 1998 to October 7, 1999
Sarcia, Jerry J.Libertyville, ILCPAOctober 30, 1998 to August 29, 2002
Spey, Gregory E.Youngstown, OHCPANovember 1, 1998 to April 30, 2001
Jacobson, KennethJacksonville, FLCPANovember 9, 1998 to November 8, 2000
Lopshire, LarryWhiteland, INCPADecember 2, 1998 to December 1, 1999
Lederer, Christine L.Somers, CTAttorneyDecember 7, 1998 to December 6, 2001
Kieffer, Richard D.Olney, ILCPADecember 15, 1998 to December 14, 1999
Cleaver Jr., Thomas E.Severna Park, MDEnrolled AgentDecember 23, 1998 to June 22, 2002
Trent, Douglas I.Allen, TXCPAJanuary 1, 1999 to December 31, 1999
Winters, John E. Bayonne, NJCPAJanuary 1, 1999 to September 30, 1999
Todd Jr., Emory S.Chester SpringsCPAJanuary 15, 1999 to July 14, 1999
Hawkins, William M.Indianapolis, INAttorneyFebruary 1, 1999 to January 31, 2002
Gimbal, PeterUnion City, NJCPAApril 1, 1999 to September 30, 2000
Ryan, Thomas J.Danbury, CTAttorneyMay 1, 1999 to October 30, 2000
Announcement of the Consent Voluntary Suspension of Attorneys,
Certified Public Accountants, Enrolled Agents, and Enrolled Actuaries
From Practice Before the Internal Revenue Service
Under 31 Code of Federal Regulations,
Part 10, an attorney, certified public ac-
countant, enrolled agent, or enrolled ac-
tuary, in order to avoid the institution or
conclusion of a proceeding for his disbar-
ment or suspension from practice before
the Internal Revenue Service, may offer
his consent to suspension from such prac-
tice. The Director of Practice, in his dis-
cretion, may suspend an attorney, certi-
fied public accountant, enrolled agent, or
enrolled actuary in accordance with the
consent offered.
Attorneys, certified public accountants,
enrolled agents, and enrolled actuaries are
prohibited in any Internal Revenue Ser-
vice matter from directly or indirectly em-
ploying, accepting assistance from, being
employed by, or sharing fees with any
practitioner disbarred or suspended from
practice before the Internal Revenue Ser-
vice.
To enable attorneys, certified public ac-
countants, enrolled agents, and enrolled
actuaries to identify practitioners under
consent suspension from practice before the
Internal Revenue Service, the Director
of Practice will announce in the Internal
Revenue Bulletin the names and ad-
dresses of practitioners who have been
suspended from such practice, their desig-
nation as attorney, certified public ac-
countant, enrolled agent, or enrolled actu-
ary, and date or period of suspension. This
announcement will appear in the weekly
Bulletin at the earliest practicable date
after such action and will continue to ap-
pear in the weekly Bulletins for five suc-
cessive weeks or for as many weeks as is
practicable for each attorney, certified
public accountant, enrolled agent, or en-
rolled actuary so suspended and will be
consolidated and published in the Cumu-
lative Bulletin.
The following individuals have been
placed under consent suspension from
practice before the Internal Revenue Ser-
vice:

1999–14 I.R.B.27April 5, 1999
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”)
that have an effect on previous rulings
use the following defined terms to de-
scribe the effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus,
if an earlier ruling held that a principle
applied to A, and the new ruling holds
that the same principle also applies to B,
the earlier ruling is amplified. (Compare
with modified, below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously
published ruling and points out an essen-
tial difference between them.
Modified is used where the substance
of a previously published position is
being changed. Thus, if a prior ruling
held that a principle applied to A but not
to B, and the new ruling holds that it ap-
plies to both A and B, the prior ruling is
modified because it corrects a published
position. (Compare with amplified and
clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used
in a ruling that lists previously published
rulings that are obsoleted because of
changes in law or regulations. A ruling
may also be obsoleted because the sub-
stance has been included in regulations
subsequently adopted.
Revoked describes situations where the
position in the previously published rul-
ing is not correct and the correct position
is being stated in the new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a pe-
riod of time in separate rulings. If the
new ruling does more than restate the
substance of a prior ruling, a combination
of terms is used. For example, modified
and superseded describes a situation
where the substance of a previously pub-
lished ruling is being changed in part and
is continued without change in part and it
is desired to restate the valid portion of
the previously published ruling in a new
ruling that is self contained. In this case
the previously published ruling is first
modified and then, as modified, is super-
seded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and
that list is expanded by adding further
names in subsequent rulings. After the
original ruling has been supplemented
several times, a new ruling may be pub-
lished that includes the list in the original
ruling and the additions, and supersedes
all prior rulings in the series.
Suspended is used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current use and for-
merly used will appear in material published in the
Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C.—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contribution Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign Corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statements of Procedral Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Definition of Terms

April 5, 1999281999–14 I.R.B.
1
A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 1998–1 through 1998–52
will be found in Internal Revenue Bulletin 1999–1,
dated January 4, 1999.
Numerical Finding List
1
Bulletins 1999–1 through 1999–13
Announcements:
99–1, 1999–2 I.R.B. 41
99–2, 1999–2 I.R.B. 44
99–3, 1999–3 I.R.B. 15
99–4, 1999–3 I.R.B. 15
99–5, 1999–3 I.R.B. 16
99–6, 1999–4 I.R.B.24
99–7, 1999–2 I.R.B. 45
99–8, 1999–4 I.R.B.24
99–9, 1999–4 I.R.B. 24
99–10, 1999–5 I.R.B. 63
99–11, 1999–5 I.R.B. 64
99–12, 1999–5 I.R.B. 65
99–13, 1999–6 I.R.B. 18
99–14, 1999–7 I.R.B.60
99–15, 1999–8 I.R.B.78
99–16, 1999–8 I.R.B. 80
99–17, 1999–9 I.R.B. 59
99–18, 1999–13 I.R.B. 22
99–19, 1999–10 I.R.B. 63
99–20, 1999–11 I.R.B.53
99–21, 1999–11 I.R.B.55
99–22, 1999–12 I.R.B. 32
99–25, 1999–12 I.R.B. 35
99–27, 1999–13 I.R.B. 23
99–28, 1999–13 I.R.B. 26
99–29, 1999–13 I.R.B. 26
99–30, 1999–13 I.R.B. 27
99–31, 1999–13 I.R.B. 27
Notices:
99–1, 1999–2 I.R.B. 8
99–2, 1999–2 I.R.B. 8
99–3, 1999–2 I.R.B. 10
99–4, 1999–3 I.R.B. 9
99–5, 1999–3 I.R.B. 10
99–6, 1999–3 I.R.B. 12
99–7, 1999–4 I.R.B.23
99–8, 1999–5 I.R.B. 26
99–9, 1999–4 I.R.B. 23
99–10, 1999–6 I.R.B. 14
99–11, 1999–8 I.R.B.56
99–12, 1999–9 I.R.B. 44
99–13, 1999–10 I.R.B. 26
99–14, 1999–11 I.R.B.7
99–15, 1999–12 I.R.B.20
99–16, 1999–13 I.R.B.10
Proposed Regulations:
REG–209103–89, 1999–11 I.R.B. 10
REG–209619–93, 1999–10 I.R.B. 28
REG–245562–96, 1999–9 I.R.B. 45
REG–104072–97, 1999–11 I.R.B. 12
REG–114663–97, 1999–6 I.R.B. 15
REG–114664–97, 1999–11 I.R.B. 21
REG–116826–97, 1999–10 I.R.B. 40
REG–118620–97, 1999–9 I.R.B. 46
REG–120168–97, 1999–12 I.R.B. 21
REG–121806–97, 1999–10 I.R.B. 46
REG–104924–98, 1999–10 I.R.B.47
REG–105964–98, 1999–12 I.R.B. 22
REG–106177–98, 1999–12 I.R.B. 25
REG–106219–98, 1999–9 I.R.B. 51
REG–106386–98, 1999–12 I.R.B. 31
REG–106388–98, 1999–11 I.R.B. 27
REG–106564–98, 1999–10 I.R.B.53
Proposed Regulations—Continued
REG–106902–98, 1999–8 I.R.B. 57
REG–106905–98, 1999–11 I.R.B. 39
REG–110524–98, 1999–10 I.R.B. 55
REG–111435–98, 1999–7 I.R.B. 55
REG–113694–98, 1999–7 I.R.B. 56
REG–111435–98, 1999–7 I.R.B. 55
REG–113744–98, 1999–10 I.R.B. 59
REG–114841–98, 1999–11 I.R.B. 41
REG–115433–98, 1999–9 I.R.B. 54
REG–116099–98, 1999–12 I.R.B. 34
REG–116824–98, 1999–7 I.R.B.57
REG–117620–98, 1999–7 I.R.B. 59
REG–118662–98, 1999–13 I.R.B. 14
REG–119192–98, 1999–11 I.R.B. 45
REG–121865–98, 1999–8 I.R.B.63
Revenue Procedures:
99–1, 1999–1 I.R.B. 6
99–2, 1999–1 I.R.B. 73
99–3, 1999–1 I.R.B. 103
99–4, 1999–1 I.R.B. 115
99–5, 1999–1 I.R.B. 158
99–6, 1999–1 I.R.B. 187
99–7, 1999–1 I.R.B. 226
99–8, 1999–1 I.R.B. 229
99–9, 1999–2 I.R.B. 17
99–10, 1999–2 I.R.B. 11
99–11, 1999–2 I.R.B. 14
99–12, 1999–3 I.R.B. 13
99–13, 1999–5 I.R.B. 52
99–14, 1999–5 I.R.B. 56
99–15, 1999–7 I.R.B. 42
99–16, 1999–7 I.R.B. 50
99–17, 1999–7 I.R.B. 52
99–18, 1999–11 I.R.B.7
99–19, 1999–13 I.R.B.10
Revenue Rulings:
99–1, 1999–2 I.R.B. 4
99–2, 1999–2 I.R.B. 5
99–3, 1999–3 I.R.B. 4
99–4, 1999–4 I.R.B.19
99–5, 1999–6 I.R.B.8
99–6, 1999–6 I.R.B. 6
99–7, 1999–5 I.R.B. 4
99–8, 1999–6 I.R.B.8
99–9, 1999–7 I.R.B.14
99–10, 1999–10 I.R.B. 10
99–11, 1999–10 I.R.B. 18
99–12, 1999–11 I.R.B. 6
99–13, 1999–10 I.R.B. 4
99–14, 1999–13 I.R.B. 3
99–15, 1999–12 I.R.B.4
99–16, 1999–13 I.R.B.5
Treasury Decisions:
8789, 1999–3 I.R.B. 5
8791, 1999–5 I.R.B. 7
8792, 1999–7 I.R.B.36
8793, 1999–7 I.R.B.15
8794, 1999–7 I.R.B.4
8795, 1999–7 I.R.B.8
8796, 1999–4 I.R.B. 16
8797, 1999–5 I.R.B. 5
8798, 1999–12 I.R.B. 16
8799, 1999–6 I.R.B. 10
8800, 1999–4 I.R.B. 20
8801, 1999–4 I.R.B. 5
8802, 1999–4 I.R.B. 10
Treasury Decisions—Continued
8803, 1999–12 I.R.B. 15
8804, 1999–12 I.R.B. 5
8805, 1999–5 I.R.B. 14
8806, 1999–6 I.R.B.4
8807, 1999–9 I.R.B. 33
8808, 1999–10 I.R.B. 21
8809, 1999–7 I.R.B.27
8810, 1999–7 I.R.B.19
8811, 1999–10 I.R.B. 19
8812, 1999–8 I.R.B. 19
8813, 1999–9 I.R.B. 34
8814, 1999–9 I.R.B. 4
8815, 1999–9 I.R.B. 31
8816, 1999–8 I.R.B. 4
8817, 1999–8 I.R.B. 51

1999–14 I.R.B.29April 5, 1999
Finding List of Current Action on
Previously Published Items
1
Bulletins 1999–1 through 1999–13
Revenue Procedures:
78–10
Obsoleted by
99–12, 1999–3 I.R.B. 13
94–56
Superseded by
99–9, 1999–2 I.R.B. 17
97–23
Superseded by
99–3, 1999–1 I.R.B. 103
98–1
Superseded by
99–1, 1999–1 I.R.B. 6
98–2
Superseded by
99–2, 1999–1 I.R.B. 73
98–3
Superseded by
99–3, 1999–1 I.R.B. 103
98–4
Superseded by
99–4, 1999–1 I.R.B. 115
98–5
Superseded by
99–5, 1999–1 I.R.B. 158
98–6
Superseded by
99–6, 1999–1 I.R.B. 187
98–7
Superseded by
99–7, 1999–1 I.R.B. 226
98–8
Superseded by
99–8, 1999–1 I.R.B. 229
98–22
Modified and amplified by
99–13, 1999–5 I.R.B. 52
98–56
Superseded by
99–3, 1999–1 I.R.B. 103
98–63
Modified by announcement
99–7, 1999–2 I.R.B. 45
Revenue Rulings:
92–19
Supplemented in part by
99–10, 1999–10 I.R.B. 10
1
A cumulative finding list for previously published
items mentioned in Internal Revenue Bulletins
1998–1 through 1998–52 will be found in Internal
Revenue Bulletin 1999–1, dated January 4, 1999.

Index
Internal Revenue Bulletins
1999–1 Through 1999–13
For the index of items published during
1998, see I.R.B. 1999–1, dated Janu-
ary 4, 1999.
The abbreviation and number in paren-
thesis following the index entry refer to
the specific item; numbers in roman and
italic type following the parenthesis refer
to the Internal Revenue Bulletin in which
the item may be found and the page
number on which it appears.
Key to Abbreviations:
RRRevenue Ruling
RPRevenue Procedure
TDTreasury Decision
CDCourt Decision
PLPublic Law
EOExecutive Order
DODelegation Order
TDOTreasury Department Order
TCTax Convention
SPRStatement of Procedural
Rules
PTEProhibited Transaction
Exemption
EMPLOYEE PLANS
Proposed Regulations:
26 CFR 1.402(f)–1, amended; required
explanation of eligible rollover dis-
tributions; questions and answers
(REG–118662–98) 13, 13
26 CFR 1.411(a)–11, amended; restric-
tion and valuation of distributions
(REG–118662–98) 13, 13
26 CFR 35.3405–1, amended; ques-
tions and answers relating to with-
holding on pensions, annuities, and
certain other deferred income
(REG–118662–98) 13, 13
EMPLOYMENT TAX
Deferred compensation:
Change in method of accounting
(Notice 16) 13, 10
Disregarded entities (Notice 6) 3, 12
Penalty:
Failure to deposit penalty using elec-
tronic funds transfer on or after July
1, 1997 (Notice 12) 9, 44
ESTATE TAX
Adequate disclosure of gifts (Ann. 28) 13,
25
EXCISE TAX
Regulations:
26 CFR 49.4251–4, added; communi-
cations excise tax; prepaid telephone
cards (REG–118620–97) 9, 46
INCOME TAX
Abatement of interest (TD 8789) 3, 5
Automobile owners and lessees (RP 14)
5, 56
Business expenses:
Lease-in / lease-out transactions (RR
14) 13, 3
Chief Counsel advice available for public
inspection (Ann. 4) 3,15
Court decisions in 1999–4 I.R.B. 4; cor-
rection (Ann. 17) 9, 59
Child support enforcement program (RP
12) 3, 13
Commodities dealers; securities or com-
modities traders; procedures for mak-
ing elections (RP 17) 7, 52
Correction of Rev. Proc. 98–44 (Ann 12)
5, 65
Daily transportation expenses; commut-
ing expenses; business expenses; per-
sonal expenses (RR 7) 5, 4
Debt roll-ups; election to treat certain debt
substitutions as realization events (RP
18) 11, 7
Deficiencies:
Interest abatement, Presidentially de-
clared disasters (Notice 2) 2,8
Disregarded entity to partnership (RR 5)
6, 8
Election in respect of losses attributable to
a disaster (RR 13) 10, 4
Electronic:
Filing; magnetic media; 1998 Form
8596 (RP 9) 2, 17
Submission of Form W-5 (Ann. 3) 3,
15; Forms W-4P, W-4S and W-4V
(Ann. 6) 4,24
Employee plans:
Determination letters (RP 6) 1, 187
Eligible rollover distributions; transi-
tional relief (Notice 5) 3, 10
Funding:
Full funding limitations, weighted av-
erage interest rate for January 1999
(Notice 7) 4, 23; February 1999
(Notice 11) 8, 56; March 1999
(Notice 15) 12, 21
Individual retirement arrangements:
Payroll deductions (Ann. 2) 2, 44
Recharacterizations and reconver-
sions (Ann. 5) 3,16
Letter rulings, etc. (RP 4) 1, 115
Plan administration (Notice 1) 2, 8
Regulations:
26 CFR 1.411(a)–11(c)(2)(ii), re-
vised; 1.411(a)–11(c)(2)(iii), (iv),
(v), and (c)(8), added; 1.411(a)–
11T, removed; 1.417(e)– 1(b)(3),
revised; (b)(4), added; 1.417(e)–
1T, amended; qualified retirement
plans (TD 8796) 4, 16
Tax-sheltered annuities (RP 13) 5, 52
Technical advice (5) 1, 158
User fees (RP 8) 1, 229
Exclusions-inclusions:
Payments for Temporary Assistance for
Needy Families (Notice 3) 2, 10
Exempt Organizations:
Letter rulings, etc. (RP 4) 1, 115
List of organizations classified as pri-
vate foundations (Ann 10) 5, 63; (Ann 13)
6, 20; (Ann 15) 8, 78; (Ann. 19) 10, 63;
(Ann. 20) 11, 53; (Ann. 22) 12, 32; (Ann.
27) 13, 22
Private foundations (Ann. 9) 4, 24
Technical advice (RP 5) 1, 158
User fees (RP 8) 1, 229
Failure by certain charitable organizations
to meet certain qualified requirements;
taxes on excess benefit transactions
(Ann. 21) 11, 55
Failure to deposit federal tax; penalties
(RP 10) 2, 11
Federal rates; adjusted federal rates; ad-
justed federal long-term rate, long-term
exempt rate for February 1999 (RR 8)
6, 10
Form:
1040NR instructions for 1998, cor-
rected (Ann. 8) 4, 24
8866 (Ann 16) 8, 80
Insurance companies:
Tentative differential earnings rate for
1998 (Notice 13) 10, 26
Prevailing state assumed interest rates
(RR 10) 10, 10
Discounting estimated salvage recover-
able (RP 16) 7, 50
Loss reserves; discounting unpaid
losses (RP 15) 7, 42
April 5, 1999301999–14 I.R.B.
INCOME TAX—Continued

INCOME TAX—Continued
Interest:
Investment:
Federal short-term, mid-term, and
long-term rates for January 1999
(RR 2) 2, 5; February (RR 8) 6,
10;March 1999 (RR 11) 10, 18
Rates:
Underpayments and overpayments
for calender quarter beginning
April 1, 1999 (RR 16) 13, 5
Interest netting for interest accruing be-
fore October 1, 1998 (RP 19) 13, 10
Inventory:
LIFO:
Price indexes; department stores for
November 1998 (RR 4) 4, 19;
December 1998 (RR 9) 7, 14;
January 1999 (RR15) 12,4
Joint Board for the Enrollment of
Actuaries (Ann. 25) 12, 35
Letter rulings, determination letters, and
information letters issued by Associate
Chief Counsel (Domestic), Associate
Chief Counsel (EBEO), Associate
Chief Counsel (Enforcement Litiga-
tion), and Associate Chief Counsel
(International) (RP 1) 1, 6
Long-term capital gain treatment for fis-
cal year individuals, estates, partner-
ships, and S corporations (Ann 11) 5,
64
Low-income housing credit:
Alternative collateral program (RP 11)
2, 14
Low-income housing tax credit:
1999 calendar year resident population
estimates (Notice 10) 6, 16
Satisfactory bond; “bond factor”
amounts for the period October
through December 1998 (RR 1) 2, 4
Low-income taxpayer clinics grant pro-
gram (Notice 9) 4, 23
Mark-to-market election for regulated
investment companies that are share-
holders of PFICs (Notice 14) 11, 7
Model qualified intermediary withholding
agreement (Notice 8) 5, 26
Mutual holding company conversions
(RR 3) 3, 4
Notice of significant reduction in the rate
of future benefit accrual, T.D. 8795;
correction (Ann. 31) 13, 26
Optional standard mileage rates; effective
date (Ann. 7) 2, 45
Partnership to disregarded entity (RR 6) 6,
6
INCOME TAX—Continued
Penalties:
Designation of Federal Tax Deposits
(RP 10) 2, 11
Penalty and interest study (Notice 4) 3, 9
Proposed regulations:
26 CFR 1.25A–0 thru 1.25A–5, added;
calculation of education credit and
general eligibility requirements
(REG– 106388–98) 11, 27
26 CFR 1.42–5, –6, –11, –12, –13,
amended; 1.42–17, added; low-in-
come housing credit; compliance
monitoring, etc. (REG–114664–97)
11, 21
26 CFR 1.79–3, amended; group-term
insurance: uniform programs
(REG–209103–89) 11, 10
26 CFR 1.221–1, added; deduction for
interest on qualified education loans
(REG–116826–97), 10, 40
26 CFR 1.401(a)(31)–1, amended; Re-
lief from disqualification for plans
accepting rollovers (REG–245562–
96) 9, 45
26 CFR 1.411(a)–7, –11, 1.417(e)–1,
amended; increase in cash-out limit
under sections 411(a)(7), 411(a)(11)
and 417(e)(1) for qualified retire-
ment plans (REG–113694–98) 7, 56
26 CFR 1.446–1, added; 1.471–12,
added; 1.475(c)–1, revised; 1.475(c)–
2, added; 1.475(e)–1, redesignated as
1.475(g)–1; 1.475(e)–1, added;
1.475(f)–1, –2, added; 1.475(g)–1,
amended; mark-to-market account-
ing for dealers in commodities and
traders in securities or commodities
(REG– 104924–98) 10, 47
26 CFR 1.453–12, added; capital gains,
installment sales, unrecaptured sec-
tion 1250 gain (REG–110524–98)
10, 55
26 CFR 1.468B–0, amended;
1.468B–1, amended; 1.468B–5,
amended; 1.468B–6 thru 1.468B–9,
and intermediary sections, added;
1.1031(k)–1, amended; escrow funds
and other similar funds
(REG–209619–93) 10, 28
26 CFR 1.1502–3, amended; 1.1502–
9A, added; new 1.1502–9, added;
consolidated overall foreign losses
and separate limitation losses (REG–
106902–98) 8, 57
26 CFR 1.663(c)–1, amended;
1.663(c)–2, revised; 1.663(c)–3,
amended; 1.663(c)–4, redesignated;
1.663(c)–4, added; 1.663(c)–5,
amended; 1.663(c)–6, added; sepa-
rate share rules applicable to estates
(REG–114841–98) 11, 41
26 CFR 1.861–8, amended; 1.865–1,
added; 1.865–2, amended; allocation
of loss with respect to stock and other
personal property (REG–106905–98)
11, 39
26 CFR 1.1296(e)–1, added; passive
foreign investment companies; defin-
itions of marketable stocks (REG–
113744–98), 10, 59
26 CFR 1.1362–3, amended; 1.1502–
76, amended; acquisition of an S cor-
poration by a member of a consoli-
dated group (REG–106219–98) 9, 51
26 CFR 1.1502–13, amended; inter-
company transactions (REG–
105964–98) 12, 22
26 CFR 1.6695–1, amended; retention
of income tax return preparer’s sig-
nature (REG–106386–98) 12, 15
26 CFR 1.6695–2, added; preparer due
diligence requirements for determin-
ing earned income credit eligibility
(REG–120168–97) 12, 16
26 CFR 1.7701(1)–3, added; 1.1441–7,
amended; recharacterizing financing
arrangements involving fast–pay
stock (REG– 104072–97) 11, 12
26 CFR 20.2001–1, revised; valuation
of adjusted taxable gifts and section
2701(d) taxable events (REG–
106177–98) 12, 25
26 CFR 25.2504–2, revised; valuation
of certain gifts for preceding calender
periods (REG– 106177–98) 12, 25
26 CFR 20.2055–1(d)(6), added;
20.2056(b)–4, amended; marital de-
duction; valuation of interest passing
to surviving spouse (REG–114663–
97) 6, 17
26 CFR 54.4980B, amended; continua-
tion coverage requirements of group
health plans (REG–121865–98) 8, 63
26 CFR 301.6103(j)(1)–1, amended;
disclosure of return information to
the Bureau of Census (REG–
121806–97) 10, 46
26 CFR 301.6103(k)(9)–1, added;
301.6311–1(a)(1)(i), amended; pay-
ment of tax by credit card or debit
card (REG–111435–98) 7, 55
26 CFR 301.6221–1, amended;
301.6223(c)–1, amended;
301.6224(c)–3, amended;
1999–14 I.R.B.31April 5, 1999
INCOME TAX—Continued

301.6229(b)– 2, added; 301.6229(f)–
1, added; 301.6231(a)(1)–1,
amended; 301.6231(a)(6)–1,
amended; 301.6231(a)(7)–1,
amended; modifications and addi-
tions to the unified partnership audit
procedures (REG–106564–98) 10, 53
26 CFR 301.6320–1, added; notice and
opportunity for hearing upon filing of
notice of lien (REG–116824–98) 7,
57
26 CFR 301.6330–1, added; notice and
opportunity for hearing prior to levy
(REG–117620–98) 7, 59
26 CFR 301.6501(c)–1, amended; ade-
quate disclosure of gifts (REG–
106177–98) 12, 25
26 CFR 301.7502–1, revised;
301.7502–2, added; Timely mailing
treated as timely filing / electronic
postmark (REG– 115433–98) 9, 54
26 CFR 801.0–1 thru 801.0–5, and in-
termediary sections, added; estab-
lishment of a balanced measurement
system (REG–119192–98) 11, 45
Proposed update of Rev. Proc. 65–17
(Ann. 1) 2, 41
Recharacterizing financing arrangements
involving fast-pay stock, REG–
104072–97; correction (Ann. 30) 11, 26
Regulations:
26 CFR 1.148–5(d)(6)(iii), revised;
1.148–5(e)(2)(iv), added; arbitrage
restrictions on tax-exempt bond
(T.D. 8801) 4, 5
26 CFR 1.195–1, added; election to
amortize start-up expenditures for
active trades or businesses (T.D.
8797)5, 5
26 CFR 1.337(d)–4, added; certain
asset transfers to a tax-exempt entity
(T.D. 8802) 4, 10
26 CFR 1.408A–0 through –9 and in-
termediary sections, added; Roth
IRAs (T.D. 8816) 8,4
26 CFR 1.411(a)–7, –11, amended;
1.411(a)–7T, –11T, added; increase
in cash-out limit under sections
411(a)(7), 411(a)(11) and 417(e)(1)
for qualified retirement plans (T.D.
8794) 7, 4
26 CFR 1.411(d)(4), amended;
1.411(d)–4T, removed; employee
stock ownership plans qualified re-
tirement plan benefits (T.D. 8806)
6, 4
26 CFR 1.411(d)–6T, removed;
1.411(d)–6, added; notice of signifi-
cant reduction in the rate of future
benefit accrual (T.D. 8795) 7, 8
26 CFR 1.469–10, revised; 1.7704–3,
added; certain investment income
under the qualifying income provi-
sions and the application of the pas-
sive activity loss rules to publicly
traded partnerships (T.D. 8799) 6, 12
26 CFR 1.664–1(a)(7), (d)(1)(iii),
(f)(4), added; 1.664–2(a)(1)(i), re-
vised; 1.664–3, amended; 25.2702–
1(c)(3), revised; charitable remain-
der trusts and special valuation rules
for transfers of interests in trusts
(T.D. 8791) 5, 7
26 CFR 1.861–8, amended; 1.861–8T,
amended; 1.865–1T, added; 1.865–2,
added; 1.865–2T, added; 1.904–0,
amended; 1904–4, amended; alloca-
tion of loss with respect to stocks
and other personal property (T.D.
8805) 5, 14
26 CFR 1.871–14, revised; rules relat-
ing to repeal of tax on interest of
nonresident alien individuals and
foreign corporations received from
certain portfolio debt investments
(T.D. 8804) 12, 5
26 CFR 1.881–3, corrected conduit
arrangement regulations (Ann 14) 7,
60
26 CFR 1.1441–1, –5, –6, –9, revised;
1.1441–4, amended; 1.1441–8, re-
designated and amended; 1.1443–1,
revised; requirements for the deduc-
tion and withholding of tax on pay-
ments to foreign persons (T.D. 8804)
12, 5
26 CFR 1.6038B–1, amended;
1.6038B–2, added; notice of certain
transfers to foreign partnerships and
foreign corporations (T.D. 8817) 8,
51
26 CFR 1.6042–3, amended; dividends
subject to reporting; 1.6045–1,
amended; returns of information of
brokers and barter exchanges;
1.6049–5, amended; interest and
original issue discount subject to re-
porting after December 31, 1982
(T.D. 8804) 12, 5
26 CFR 1.6695–1, amended;
1.6695–1T, added; retention of in-
come tax return preparer’s signature
(temporary) (T.D. 8803) 12, 15
INCOME TAX—Continued
26 CFR 1.6695–2T, added; preparer
due diligence requirements for deter-
mining earned income credit eligibil-
ity (temporary) (T.D. 8798) 12, 16
26 CFR 1.7702B–1, –2, added; quali-
fied long-term care insurance con-
tracts (T.D. 8792) 7, 36
26 CFR 31.3306(r)(2)–1, added; FUTA
tax amounts under employee benefit
plans (T.D. 8815) 9, 31
26 CFR 31.3121(v)(2)–1, –2, added;
FICA tax amounts under employee
benefit plans (T.D. 8814) 9, 4
26 CFR 54.4980B–0 through –8 and
intermediary sections, added; contin-
uation coverage requirements of
group health plans (T.D. 8812) 8, 19
26 CFR 301.6103(j)(1)–1, amended;
301.6103(j)(1)–1T, added; disclo-
sure of return information to the Bu-
reau of Census (T.D. 8811) 10, 19
26 CFR 301.6103(k)(9)–1T, –2T,
added; payment of tax by credit card
or debit card (T.D. 8793) 7, 15
26 CFR 301.6221–1T, amended;
301.6223(c)–1T, amended;
301.6224(c)–3T, amended;
301.6229(b)–2T, added;
301–6229(f)–1T, added;
301.6231(a)(1)–1T, amended;
301.6231(a)(6)–1T, amended;
301.6231(a)(7)–1, amended;
301.6231(a)(7)–1, added; modifica-
tions and additions to the unified
partnership audit procedures (T.D.
8808) 10, 21
26 CFR 301.6320–1T, added; notice
and opportunity for hearing upon fil-
ing of notice of lien (T.D. 8810) 7, 19
26 CFR 301.6330–1T, added; notice
and opportunity for hearing prior to
levy (T.D. 8809) 7, 27
26 CFR 301.7502–1, amended;
301.7502–1T, added; Timely mailing
treated as timely filing / electronic
postmark (T.D. 8807) 9, 33
26 CFR 301.7701–5, amended;
301.7701–7, added; residence of
trusts and estates (T.D. 8813) 9, 34
26 CFR 1.1502–3T, –9(a), –9T(b)(1)(v)
and (vi), amended; consolidated re-
turns, limitation on recapture of
overall foreign loss accounts (T.D.
8800) 4, 20
Requirements for the deduction and with-
holding of tax on certain U.S. source
April 5, 1999321999–14 I.R.B.
INCOME TAX—ContinuedINCOME TAX—Continued

income paid to foreign persons, T.D.
8804; correction (Ann. 29) 13, 25
Roth IRAs:
Conversions on Form 8606, Nonde-
ductible IRAs (Ann. 18) 13, 21
Rulings:
Areas in which advance rulings will not
be issued:
Associate Chief Counsel (Domes-
tic), Associate Chief Counsel
(EBEO) (RP 3) 1, 103
Associate Chief Counsel (Interna-
tional) (RP 7) 1, 226
Standard Industry Fare Level (SIFL) rates
for the first half of 1999 (RR 12) 11,6
Technical advice to district directors and
chiefs, appeals offices, Associate Chief
Counsel (Domestic), Associate Chief
Counsel (EBEO), Associate Chief
Counsel (Enforcement Litigation), and
Associate Chief Counsel (International)
(RP 2) 1, 73
Valuation of adjusted taxable gifts and
section 2701(d) taxable events, REG–
106177–98; correction (Ann. 28) 13, 25
1999–14 I.R.B.33April 5, 1999
INCOME TAX—ContinuedINCOME TAX—ContinuedINCOME TAX—Continued

Notes
April 5, 1999341999–14 I.R.B.

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