Internal Revenue Bulletin 2000-24 (PDF rendition): IRS Revenue Rulings

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INCOME TAX
Rev. Rul. 2000–29, page 1249.
LIFO; price indexes; department stores.The April 2000
Bureau of Labor Statistics price indexes are accepted for
use by department stores employing the retail inventory and
last-in, first-out inventory methods for valuing inventories for
tax years ended on, or with reference to, April 30, 2000.
T.D. 8884, page 1250.
Final regulations under section 1502 of the Code relate to
certain credits of corporations that become members of a
consolidated group.
ADMINISTRATIVE
Rev. Proc. 2000–26, page 1257.
Interest netting for interest accruing on or after Oc-
tober 1, 1998. This procedure provides guidance regard-
ing the application of section 6621(d) of the Code to inter-
est accruing on or after October 1, 1998. Section
6621(d) provides for a net interest rate of zero to the ex-
tent of overlapping tax underpayments and tax overpay-
ments, and generally applies to interest for periods begin-
ning after July 22, 1998 (interest accruing on or after
October 1, 1998).
Internal Revenue
bbuulllleettiinn
Bulletin No. 2000–24
June 12, 2000
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
Department of the Treasury
Internal Revenue Service
Finding Lists begin on page ii.

June 12, 20002000–24 I.R.B.
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing offi-
cial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
general interest. It is published weekly and may be obtained
from the Superintendent of Documents on a subscription
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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.
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ing them understand and meet their tax responsibilities
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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 472.—Last-in, First-out
Inventories
26 CFR 1.472–1: Last-in, first-out inventories.
LIFO; price indexes; department
stores.The April 2000 Bureau of Labor
Statistics price indexes are accepted for
use by department stores employing the
retail inventory and last-in, first-out in-
ventory methods for valuing inventories
for tax years ended on, or with reference
to, April 30, 2000.
Rev. Rul. 2000–29
The following Department Store In-
ventory Price Indexes for April 2000
were issued by the Bureau of Labor Sta-
tistics. The indexes are accepted by the
Internal Revenue Service, under
§ 1.472–1(k) of the Income Tax Regula-
tions and Rev. Proc. 86–46, 1986–2 C.B.
739, for appropriate application to in-
ventories of department stores employ-
ing the retail inventory and last-in, first-
out inventory methods for tax years
ended on, or with reference to, April 30,
2000.
The Department Store Inventory Price
Indexes are prepared on a national basis
and include (a) 23 major groups of depart-
ments, (b) three special combinations of
the major groups - soft goods, durable
goods, and miscellaneous goods, and (c) a
store total, which covers all departments,
including some not listed separately, ex-
cept for the following: candy, food,
liquor, tobacco, and contract departments.
2000–24 I.R.B.1249June 12, 2000
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
BUREAU OF LABOR STATISTICS, DEPARTMENT STORE
INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS
(January 1941 = 100, unless otherwise noted)
Percent Change
GroupsApr.Apr.from Apr. 1999
19992000to Apr. 2000
1
1.Piece Goods - - - - - - - - - - - - - - - - - - - - - - - - - -553.1516.8-6.6
2.Domestics and Draperies - - - - - - - - - - - - - - - - -633.8631.1-0.4
3.Women’s and Children’s Shoes - - - - - - - - - - - - -669.4646.0-3.5
4.Men’s Shoes - - - - - - - - - - - - - - - - - - - - - - - - -894.6919.22.7
5.Infants’ Wear - - - - - - - - - - - - - - - - - - - - - - - - -617.2642.54.1
6.Women’s Underwear - - - - - - - - - - - - - - - - - - - -576.0576.20.0
7.Women’s Hosiery - - - - - - - - - - - - - - - - - - - - - -321.9334.2 3.8
8.Women’s and Girls’ Accessories - - - - - - - - - - - -568.9553.3-2.7
9.Women’s Outerwear and Girls’ Wear - - - - - - - - -415.5413.3-0.5
10.Men’s Clothing - - - - - - - - - - - - - - - - - - - - - - - -629.3615.3-2.2
11.Men’s Furnishings - - - - - - - - - - - - - - - - - - - - -629.2631.70.4
12.Boys’ Clothing and Furnishings - - - - - - - - - - - -495.7497.5 0.4
13.Jewelry - - - - - - - - - - - - - - - - - - - - - - - - - - - - -984.0971.9-1.2
14.Notions - - - - - - - - - - - - - - - - - - - - - - - - - - - - -778.7757.6-2.7
15.Toilet Articles and Drugs - - - - - - - - - - - - - - - - -956.1971.51.6
16.Furniture and Bedding - - - - - - - - - - - - - - - - - - -699.4680.8-2.7
17.Floor Coverings - - - - - - - - - - - - - - - - - - - - - - -602.8607.40.8
18.Housewares - - - - - - - - - - - - - - - - - - - - - - - - - -802.1782.1-2.5
19.Major Appliances - - - - - - - - - - - - - - - - - - - - - -232.8234.80.9
20.Radio and Television - - - - - - - - - - - - - - - - - - - -67.560.0-11.1
21.Recreation and Education
2
- - - - - - - - - - - - - - - -99.494.9-4.5
22.Home Improvements
2
- - - - - - - - - - - - - - - - - - -128.1128.0-0.1
23.Auto Accessories
2
- - - - - - - - - - - - - - - - - - - - - -106.8106.5-0.3
Groups 1 - 15: Soft Goods - - - - - - - - - - - - - - - - - - - -612.3610.5-0.3
Groups 16 - 20: Durable Goods - - - - - - - - - - - - - - - - -454.4440.3-3.1
Groups 21 - 23: Misc. Goods
2
- - - - - - - - - - - - - - - - - -104.7101.5-3.1
Store Total
3
- - - - - - - - - - - - - - - - - - - - - - - - - - - -553.5547.0-1.2
1 Absence of a minus sign before the percentage change in this column signifies a price increase.
2 Indexes on a January 1986=100 base.
3 The store total index covers all departments, including some not listed separately, except for the following: candy, food, liquor, tobacco, and contract departments.

DRAFTING INFORMATION
The principal author of this revenue ruling
is Alan J. Tomsic of the Office of Assistant
Chief Counsel (Income Tax and Account-
ing). For further information regarding this
revenue ruling, contact Mr. Tomsic on (202)
622-4970 (not a toll-free call).
Section 1502.—Regulations
26 CFR 1.1502–3: Consolidated tax credits.
T.D. 8884
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
Consolidated Returns—
Limitations on the Use of
Certain Credits
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations.
SUMMARY: This document contains
final regulations regarding certain credits
of corporations that become members of a
consolidated group. The regulations pro-
vide rules for computing the limitation
with respect to certain credits earned in a
separate return limitation year (SRLY)
and the carryover and carryback of those
credits to consolidated and separate return
years. The regulations also eliminate the
application of the SRLY rules in certain
circumstances in which the rules of sec-
tion 383 also apply.
DATES: Effective Date: These regula-
tions are effective May 25, 2000.
Applicability Dates: For dates of ap-
plicability, see the “Dates of Applicabil-
ity” portion of this preamble.
FOR FURTHER INFORMATION CON-
TACT: Marie C. Milnes-Vasquez, (202)
622-7770 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background and Explanation of
Provisions
A. In General
On January 12, 1998, the IRS and Trea-
sury published in the Federal Registera
Treasury decision (T.D. 8751, 1998–1
C.B. 655 [63 F.R. 1740]) containing tem-
porary regulations concerning the use of
certain tax attributes by a consolidated
group. In part, these regulations provided
rules governing the absorption of general
business credits and minimum tax credits
carried from separate return limitation
years (SRLYs), and eliminated SRLY re-
strictions with respect to recapture of
overall foreign losses (OFLs) and on the
use of foreign tax credits of corporations
joining a group. Further, this Treasury
decision contained a final regulation elim-
inating the limitation on credit carryovers
following a consolidated return change of
ownership (CRCO).
A notice of proposed rulemaking cross-
referencing the temporary regulations was
published in the Federal Registeron the
same day (63 F.R. 1803). On March 16,
1998, the IRS and Treasury published
temporary amendments to those consoli-
dated return regulations (T.D. 8766,
1998–1 C.B. 888 [63 F.R. 12641]) and the
corresponding notice of proposed rule-
making (63 F.R. 12717) modifying the
general date of applicability contained in
the January 12, 1998, temporary regula-
tions. Per the amendment, the January
12, 1998, temporary regulations, as
amended, are generally applicable for
consolidated return years for which the
due date of the return is after March 13,
1998. The amendments provided further
guidance with respect to consolidated re-
turn years beginning on or after January
1, 1997, for which the income tax return
is due on or before March 13, 1998.
On August 11, 1999, the IRS and Trea-
sury issued final regulations relating to
the recapture of OFLs (including elimina-
tion of any SRLY limitation on such re-
capture). (T.D. 8833, 1999–36 I.R.B. 338
[64 F.R. 43613]).
This Treasury decision adopts without
substantive change the portions of the
temporary regulations that were issued in
1998, relating to general business credits
and minimum tax credits, with the addi-
tion of the “overlap rule”, discussed in
Extension of 1999 Principlesof this pre-
amble. This Treasury decision also
makes final the rules eliminating SRLY
restrictions on the use of foreign tax cred-
its, and the rules repealing the consoli-
dated return change of ownership provi-
sions pertaining to those credits.
B. Extension of 1999 Principles
On July 2, 1999, the IRS and Treasury
published in the Federal Registera Trea-
sury decision (T.D. 8823, 1999–29 I.R.B.
34 [64 F.R. 36092]) containing final regu-
lations providing rules governing the ab-
sorption of certain tax attribute carryovers
and carrybacks from separate return limi-
tation years (SRLYs). These tax attrib-
utes included net operating losses and net
capital losses. The rules also governed
the absorption of recognized built-in
losses. These regulations, in part, elimi-
nated the application of the SRLY rules in
certain circumstances in which the rules
of section 382 also apply (overlap rule).
The IRS and Treasury believe that it is
appropriate to apply a single set of SRLY
principles to all attributes that are subject
to SRLY limitations. Unnecessary com-
plexity would result from applying differ-
ent principles to different attributes. Ac-
cordingly, this document extends the
principles of the overlap rule of the 1999
final regulations to the general business
credit and the minimum tax credit. These
final regulations adopt the mechanism of
subgrouping and the overlap rule set forth
in §1.1502–21 (including the require-
ments of coextensive subgroups and con-
temporaneity).
C.Dates of Applicability
The final regulations generally are ap-
plicable to consolidated return years for
which the due date of the income tax re-
turn (without extensions) is after March
13, 1998. However, there are some spe-
cial effective dates. The rules contained
in these final regulations (except the over-
lap rule) may be applied optionally to
years beginning on or after January 1,
1997. Application of the overlap princi-
ples of §1.1502–21(g) is generally effec-
tive for consolidated return years for
which the return (without extensions) is
due after May 25, 2000.
Special Analyses
It has been determined that this Trea-
sury decision is not a significant regula-
tory action as defined in Executive Order
12866. Therefore, a regulatory assess-
ment is not required. It is hereby certi-
fied that these regulations do not have a
significant economic impact on a sub-
stantial number of small entities. This
June 12, 200012502000–24 I.R.B.

certification is based on the fact that
these regulations principally affect per-
sons filing consolidated federal income
tax returns that have carryover or carry-
back of credits from separate return limi-
tation years. Available data indicates that
many consolidated return filers are large
companies (not small businesses). In ad-
dition, the data indicates that an insub-
stantial number of consolidated return fil-
ers that are smaller companies have
credit carryovers or carrybacks, and thus
even fewer of these filers have credit car-
ryovers or carrybacks that are subject to
the separate return limitation year rules.
Therefore, a Regulatory Flexibility
Analysis under the Regulatory Flexibility
Act (5 U.S.C. chapter 6) is not required.
Pursuant to section 7805(f) of the Inter-
nal Revenue Code, the notice of proposed
rulemaking accompanying these regula-
tions was sent to the Small Business Ad-
ministration for comment on their impact
on small businesses.
Drafting Information
The principal author of these regulations
is Marie C. Milnes-Vasquez of the Office
of Assistant Chief Counsel (Corporate).
Other personnel from the IRS and Treasury
participated in their development.
* * * * *
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR part 1 is amended
as follows:
PART 1—INCOME TAXES
Paragraph . The authority citation for
part 1 is amended by removing the en-
tries for sections 1.1502–3T and
1.1502–55T and adding entries in numeri-
cal order to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Section 1.1502–3 also issued under 26
U.S.C. 1502.
Section 1.1502–4 also issued under 26
U.S.C. 1502. * * *
Section 1.1502–55 also issued under 26
U.S.C. 1502. * * *
Par. 2. Section 1.1502–3 is amended as
follows:
1. The section heading is revised.
2. Paragraph (b)(3) is added.
3. Paragraphs (c), (d), and (e)(3) are
revised.
The addition and revisions read as fol-
lows:
§1.1502–3 Consolidated tax credits.
* * * * *
(b) * * *
(3) Example. The provisions of para-
graphs (a) and (b) of this section may be
illustrated by the following example:
Example. (i) Corporation P is incorporated on
January 1, 1966. On that same day P incorporates
corporation S, a wholly owned subsidiary. P and S
file consolidated returns for calendar years 1966 and
1967. P’s and S’s credit earned, the consolidated
credit earned, and the consolidated limitation based
on amount of tax for 1966 and 1967 are as follows:
2000–24 I.R.B.1251June 12, 2000
CreditConsolidatedConsolidated
earnedcredit earnedlimitation based
on amount of tax
1966:
P$ 60,000
S$ 30,000$ 90,000$ 100,000
1967:
P$ 40,000
S$ 25,000$ 65,000$ 50,000
(ii) P’s and S’s credit earned for 1966 are aggre-
gated, and the group’s consolidated credit earned,
$90,000, is allowable in full to the group as a credit
under section 38 for 1966 since such amount is less
than the consolidated limitation based on amount of
tax for 1966, $100,000.
(iii) Since the consolidated limitation based on
amount of tax for 1967 is $50,000, only $50,000 of
the $65,000 consolidated credit earned for such year
is allowable to the group under section 38 as a credit
for 1967. The consolidated unused credit for 1967
of $15,000 ($65,000 less $50,000) is a consolidated
investment credit carryback and carryover to the
years prescribed in section 46(b). In this case the
consolidated unused credit is a consolidated invest-
ment credit carryback to 1966 (since P and S were
not in existence in 1964 and 1965) and a consoli-
dated investment credit carryover to 1968 and sub-
sequent years. The portion of the consolidated un-
used credit for 1967 which is allowable as a credit
for 1966 is $10,000. This amount shall be added to
the amount allowable as a credit to the group for
1966. The balance of the consolidated unused credit
for 1967 to be carried to 1968 is $5,000. These
amounts are computed as follows:
Consolidated carryback to 1966$ 15,000
1966 consolidated limitation based on tax$ 100,000
Less: Consolidated credit earned for 1966$ 90,000
Consolidated unused credits attributable to years preceding 19670 $ 90,000
Limit on amount of 1967 consolidated unused credit which may be added as a credit for 1966$ 10,000
Balance of 1967 consolidated unused credit to be carried to 1968$ 5,000

(c) Limitation on investment credit car-
ryovers and carrybacks from separate re-
turn limitation years applicable for con-
solidated return years for which the due
date of the return is on or before March
13, 1998—(1) General rule. In the case
of an unused credit of a member of the
group arising in a separate return limita-
tion year (as defined in §1.1502–1(f)) of
such member (and in a separate return
limitation year of any predecessor of such
member), the amount which may be in-
cluded under paragraph (b) of this section
(computed without regard to the limita-
tion contained in paragraph (e) of this sec-
tion) shall not exceed the amount deter-
mined under paragraph (c)(2) of this
section.
(2) Computation of limitation. The
amount referred to in paragraph (c)(1) of
this section with respect to a member of
the group is the excess, if any, of–
(i) The limitation based on amount of
tax of the group, minus such limitation re-
computed by excluding the items of in-
come, deduction, and foreign tax credit of
such member; over
(ii) The sum of the investment credit
earned by such member for such consoli-
dated return year, and the unused credits
attributable to such member which may
be carried to such consolidated return
year arising in unused credit years ending
prior to the particular separate return limi-
tation year.
(3) Special effective date. This para-
graph (c) applies to consolidated return
years for which the due date of the in-
come tax return (without extensions) is on
or before March 13, 1998. See paragraph
(d) of this section for the rule that limits
the group’s use of a section 38 credit car-
ryover or carryback from a SRLY for a
consolidated return year for which the due
date of the income tax return (without ex-
tensions) is after March 13, 1998. See
also paragraph (d)(4) of this section for an
optional effective date rule (generally
making the rules of this paragraph (c) in-
applicable to a consolidated return year
beginning after December 31, 1996, if the
due date of the income tax return (without
extensions) for such year is on or before
March 13, 1998).
(4) Examples. The provisions of this
paragraph (c) may be illustrated by the
following examples:
Example 1. (i) Assume the same facts as in the
example contained in paragraph (b)(3) of this sec-
tion, except that all the stock of corporation T, also a
calendar year taxpayer, is acquired by P on January
1, 1968, and that P, S, and T file a consolidated re-
turn for 1968. In 1966, T had an unused credit of
$10,000 which has not been absorbed and is avail-
able as an investment credit carryover to 1968. Such
carryover is from a separate return limitation year.
P’s and S’s credit earned for 1968 is $10,000 each,
and T’s credit earned is $8,000; the consolidated
credit earned is therefore $28,000. The group’s con-
solidated limitation based on amount of tax for 1968
is $50,000. Such limitation recomputed by exclud-
ing the items of income, deduction, and foreign tax
credit of T is $30,000. Thus, the amount determined
under paragraph (c)(2)(i) of this section is $20,000
($50,000 minus $30,000). Accordingly, the limita-
tion on the carryover of T’s unused credit is
$12,000, the excess of $20,000 over $8,000 (the sum
of T’s credit earned for the taxable year and any car-
ryovers from prior unused credit years (none in this
case)). Therefore T’s $10,000 unused credit from
1966 may be carried over to the consolidated return
year without limitation.
(ii) The group’s consolidated credit earned for
1968, $28,000, is allowable in full as a credit under
section 38 since such amount is less than the consol-
idated limitation based on amount of tax, $50,000.
(iii) The group’s consolidated investment credit
carryover to 1968 is $15,000, consisting of the consol-
idated unused credits of the group ($5,000) plus T’s
separate return year unused credit ($10,000). The en-
tire $15,000 consolidated carryover shall be added to
the amount allowable to the group as a credit under
section 38 for 1968, since such amount is less than
$22,000 (the excess of the consolidated limitation
based on tax, $50,000, over the sum of the consoli-
dated credit earned for 1968, $28,000, and unused
credits arising in prior unused credit years, zero).
Example 2. Assume the same facts as in Example
1, except that the amount determined under para-
graph (c)(2)(i) of this section is $12,000. Therefore,
the limitation on the carryover of T’s unused credit
is $4,000. Accordingly, the consolidated investment
credit carryover is only $9,000 since the amount of
T’s separate return year unused credit which may be
added to the group’s $ 5,000 consolidated unused
credit is $4,000. These amounts are computed as
follows:
June 12, 200012522000–24 I.R.B.
T’s carryover to 1968$ 10,000
Consolidated limitation based on amount of tax minus recomputed limitation$12,000
Less: T’s credit earned for 1968$ 8,000
Unused credits attributable to T arising in unused credit years preceding 19660 $ 8,000
Limit on amount of 1966 unused credit of T which may be added to consolidated
investment credit carryover$ 4,000
Balance of 1966 unused credit of T to be carried to 1969 (subject to the limitation
contained in paragraph (c) of this section)$ 6,000
(d) Limitation on tax credit carryovers
and carrybacks from separate return limi-
tation years applicable for consolidated re-
turn years for which the due date of the re-
turn is after March 13, 1998—(1) General
rule. The aggregate of a member’s unused
section 38 credits arising in SRLYs that are
included in the consolidated section 38
credits for all consolidated return years of
the group may not exceed—
(i) The aggregate for all consolidated
return years of the member’s contribu-
tions to the consolidated section 38(c)
limitation for each consolidated return
year; reduced by
(ii) The aggregate of the member’s sec-
tion 38 credits arising and absorbed in all
consolidated return years (whether or not
absorbed by the member).
(2) Computational rules—(i) Mem-
ber’s contribution to the consolidated sec-
tion 38(c) limitation. If the consolidated
section 38(c) limitation for a consolidated
return year is determined by reference to
the consolidated tentative minimum tax
(see section 38(c)(1)(A)), then a mem-
ber’s contribution to the consolidated sec-
tion 38(c) limitation for such year equals
the member’s share of the consolidated
net income tax minus the member’s share
of the consolidated tentative minimum
tax. If the consolidated section 38(c) lim-
itation for a consolidated return year is
determined by reference to the consoli-
dated net regular tax liability (see section
38(c)(1)(B)), then a member’s contribu-
tion to the consolidated section 38(c) lim-
itation for such year equals the member’s
share of the consolidated net income tax
minus 25 percent of the quantity which is
equal to so much of the member’s share
of the consolidated net regular tax liabil-
ity less its portion of the $25,000 amount
specified in section 38(c)(1)(B). The
group computes the member’s shares by

applying to the respective consolidated
amounts the principles of section 1552
and the percentage method under
§1.1502–33(d)(3), assuming a 100% allo-
cation of any decreased tax liability. The
group must make proper adjustments so
that taxes and credits not taken into ac-
count in computing the limitation under
section 38(c) are not taken into account in
computing the member’s share of the con-
solidated net income tax, etc. (See, for
example, the taxes described in section
26(b) that are disregarded in computing
regular tax liability.) Also, the group may
apportion all or a part of the $25,000
amount (or lesser amount if reduced by
section 38(c)(3)) for any year to one or
more members.
(ii) Years included in computation. For
purposes of computing the limitation
under this paragraph (d), the consolidated
return years of the group include only
those years, including the year to which a
credit is carried, that the member has been
continuously included in the group’s con-
solidated return, but exclude—
(A) For carryovers, any years ending
after the year to which the credit is car-
ried; and
(B) For carrybacks, any years ending
after the year in which the credit arose.
(iii) Subgroups and successors. The
SRLY subgroup principles under
§1.1502–21(c)(2) apply for purposes of this
paragraph (d). The predecessor and succes-
sor principles under §1.1502–21(f) also
apply for purposes of this paragraph (d).
(iv) Overlap with section 383. The prin-
ciples under §1.1502–21(g) apply for pur-
poses of this paragraph (d). For example,
an overlap of paragraph (d) of this section
and the application of section 383 with re-
spect to a credit carryover occurs if a cor-
poration becomes a member of a consoli-
dated group (the SRLY event) within six
months of the change date of an ownership
change giving rise to a section 383 credit
limitation with respect to that carryover
(the section 383 event), with the result that
the limitation of this paragraph (d) does
not apply. See §§1.1502–21(g)(2)(ii)(A)
and 1.383–1; see also §1.1502–21(g)(4)
(subgroup rules).
(3) Effective date—(i) In general. This
paragraph (d) generally applies to consol-
idated return years for which the due date
of the income tax return (without exten-
sions) is after March 13, 1998.
(A) Contribution years. Except as pro-
vided in paragraph (d)(4)(ii) of this sec-
tion, a group does not take into account a
consolidated taxable year for which the
due date of the income tax return (without
extensions) is on or before March 13,
1998, in determining a member’s (or sub-
group’s) contributions to the consolidated
section 38(c) limitation under this para-
graph (d).
(B) Special subgroup rule. In the event
that the principles of §1.1502–21(g)(1) do
not apply to a particular credit carryover
in the current group, then solely for pur-
poses of applying paragraph (d) of this
section to determine the limitation with
respect to that carryover and with respect
to which the SRLY register (the aggregate
of the member’s or subgroup’s contribu-
tion to consolidated section 38(c) limita-
tion reduced by the aggregate of the mem-
ber’s or subgroup’s section 38 credits
arising and absorbed in all consolidated
return years) began in a taxable year for
which the due date of the return is on or
before May 25, 2000, the principles of
§1.1502–21(c)(2) shall be applied without
regard to the phrase “or for a carryover
that was subject to the overlap rule de-
scribed in paragraph (g) of this section or
§1.1502–15(g) with respect to another
group (the former group).”
(ii) Overlap rule. Paragraph (d)(2)(iv)
of this section (relating to overlap with
section 383) applies to taxable years for
which the due date (without extensions)
of the consolidated return is after May 25,
2000. For purposes of paragraph
(d)(2)(iv) of this section, only an owner-
ship change to which section 383, as
amended by the Tax Reform Act of 1986
(100 Stat. 2085), applies and which re-
sults in a section 383 credit limitation
shall constitute a section 383 event.
(4) Optional effective date of January 1,
1997. (i) For consolidated taxable years
beginning on or after January 1, 1997, for
which the due date of the income tax re-
turn (without extensions) is on or before
March 13, 1998, in lieu of paragraphs (c)
and (e)(3) of this section (relating to the
general business credit), §1.1502–4(f)(3)
and (g)(3) (relating to the foreign tax
credit), the next to last sentence of
§1.1502–9A(a)(2), §1.1502–9A(b)(1)(v)
(relating to overall foreign losses), and
§1.1502–55(h)(4)(iii) (relating to the alter-
native minimum tax credit), a consoli-
dated group may apply the corresponding
provisions as they appear in 1998–1 C.B.
655 through 661 (see §601.601(d)(2) of
this chapter) (treating references in such
corresponding provisions to
§§1.1502–9(b)(1)(ii), (iii), and (iv) as ref-
erences to §§1.1502–9A(b)(1)(ii), (iii),
and (iv)). Also, in the case of a consoli-
dated return change of ownership that oc-
curs on or after January 1, 1997, in a tax-
able year for which the due date of the
income tax return (without extensions) is
on or before March 13, 1998, a consoli-
dated group may choose not to apply para-
graph (e) of this section and §1.1502–4(g)
to taxable years ending after December
31, 1996. A consolidated group making
the choices described in the two preceding
sentences generally must apply all such
corresponding provisions (including not
applying paragraph (e) of this section and
§1.1502–4(g)) for all relevant years.
However, a consolidated group making
the election provided in
§1.1502–9A(b)(1)(vi) (electing not to
apply §1.1502–9A(b)(1)(v) to years be-
ginning before January 1, 1998) may nev-
ertheless choose to apply all such corre-
sponding provisions referred to in this
paragraph (d)(4)(i) other than the provi-
sion corresponding to
§1.1502–9A(b)(1)(v) for all relevant
years.
(ii) If a consolidated group chooses to
apply the corresponding provisions re-
ferred to in paragraph (d)(4)(i) of this sec-
tion, the consolidated group shall not take
into account a consolidated taxable year
beginning before January 1, 1997, in de-
termining a member’s (or subgroup’s)
contributions to the consolidated section
38(c) limitation under this paragraph (d).
(5) Example. The following example
illustrates the provisions of this paragraph
(d):
Example. (i) Individual A owns all of the stock
of P and T. P is the common parent of the P group.
P acquires all the stock of T at the beginning of Year
2. T carries over an unused section 38 general busi-
ness credit from Year 1 of $100,000. The table in
paragraph (i) of this Example shows the group’s net
consolidated income tax, consolidated tentative min-
imum tax, and consolidated net regular tax liabili-
ties, and T’s share of such taxes computed under the
principles of section 1552 and the percentage
method under §1.1502–33(d)(3), assuming a 100%
allocation of any decreased tax liability, for Year 2.
(The effects of the lower section 11 brackets are ig-
nored, there are no other tax credits affecting a
group amount or member’s share, and $1,000s are
omitted.)
2000–24 I.R.B.1253June 12, 2000

P’s T’s
share share
of col. 1of col. 1
$1,500$(300)
$525$(105)
$1,700$(200)
$340$(40)
$525$(105)
Year 2Group
1. consolidated taxable income $2,000
2. consolidated net regular tax$700
3. consolidated alternative minimum taxable income$4,000
4. consolidated tentative minimum tax$800
5. consolidated net income tax$800
6. greater of line 4 or 25% of (line 2 minus $25,000)$800
for the group
7. consolidated §38(c) limitation (line 5 minus line 6)$0
June 12, 200012542000–24 I.R.B.
P’s T’s
share share
of col. 1of col. 1
$1,200$800
$420$280
$3,200$800
$640$160
$520$280
(ii) T’s Year 1 is a SRLY with respect to the P
group. See §1.1502–1(f)(2)(ii). T did not undergo
an ownership change giving rise to a section 383
credit limitation within 6 months of joining the P
group. Thus, T’s $100,000 general business credit
arising in Year 1 is subject to a SRLY limitation in
the P group. The amount of T’s unused section 38
credits from Year 1 that are included in the consoli-
dated section 38 credits for Year 2 may not exceed
T’s contribution to the consolidated section 38(c)
limitation. For Year 2, the group determines the
consolidated section 38(c) limitation by reference to
consolidated tentative minimum tax for Year 2.
Therefore, T’s contribution to the consolidated sec-
tion 38(c) limitation for Year 2 equals its share of
consolidated net income tax minus its share of con-
solidated tentative minimum tax. T’s contribution is
$280,000 minus $160,000, or $120,000. However,
because the group has a consolidated section 38 lim-
itation of zero, it may not include any of T’s unused
section 38 credits in the consolidated section 38
credits for Year 2.
(iii) The following table shows similar informa-
tion for the group for Year 3:
Year 3Group
1. consolidated taxable income $1,200
2. consolidated net regular tax$420
3. consolidated alternative minimum taxable income$1,500
4. consolidated tentative minimum tax$300
5. consolidated net income tax$420
6. greater of line 4 or 25% of (line 2 minus $25,000)$300
for the group
7. consolidated §38(c) limitation (line 5 minus line 6)$120
(iv) The amount of T’s unused section 38 credits
from Year 1 that are included in the consolidated
section 38 credits for Year 3 may not exceed T’s ag-
gregate contribution to the consolidated section
38(c) limitation for Years 2 and 3. For Year 3, the
group determines the consolidated section 38(c) lim-
itation by reference to the consolidated tentative
minimum tax for Year 3. Therefore, T’s contribution
to the consolidated section 38(c) limitation for Year
3 equals its share of consolidated net income tax
minus its share of consolidated tentative minimum
tax. Applying the principles of section 1552 and
§1.1502–33(d) (taking into account, for example,
that T’s positive earnings and profits adjustment
under §1.1502–33(d) reflects its losses actually ab-
sorbed by the group), T’s contribution is $(105,000)
minus $(40,000), or $(65,000). T’s aggregate contri-
butions to the consolidated section 38(c) limitation
for Years 2 and 3 is $120,000 + $(65,000), or
$55,000. The group may include $55,000 of T’s
Year 1 unused section 38 credits in its consolidated
section 38 tax credit in Year 3.
(e) * * *
(3) Special effective date. This para-
graph (e) applies only to a consolidated
return change of ownership that occurred
during a consolidated return year for
which the due date of the income tax re-
turn (without extensions) is on or before
March 13, 1998. See paragraph (d)(4) of
this section for an optional effective date

rule (generally making the rules of this
paragraph (e) also inapplicable if the con-
solidated return change of ownership oc-
curred on or after January 1, 1997, and
during a consolidated return year for
which the due date of the income tax re-
turn (without extensions) is on or before
March 13, 1998).
* * * * *
§1.1502–3T [Removed]
Par. 3. Section 1.1502–3T is removed.
Par. 4. Section 1.1502–4 is amended
by revising paragraphs (f)(3) and (g)(3) to
read as follows:
§1.1502–4 Consolidated foreign tax
credit.
* * * * *
(f)* * *
(3) Limitation on unused foreign tax
credit carryover or carryback from sepa-
rate return limitation years. Paragraphs
(f)(1) and (2) of this section do not apply
for consolidated return years for which
the due date of the income tax return
(without extensions) is after March 13,
1998. For consolidated return years for
which the due date of the income tax re-
turn (without extensions) is after March
13, 1998, a group shall include an unused
foreign tax of a member arising in a
SRLY without regard to the contribution
of the member to consolidated tax liabil-
ity for the consolidated return year. See
also §1.1502–3(d)(4) for an optional ef-
fective date rule (generally making the
rules of paragraphs (f)(1) and (2) of this
section also inapplicable to a consolidated
return year beginning on or after January
1, 1997, if the due date of the income tax
return (without extensions) for such year
is on or before March 13, 1998).
(g)* * *
(3) Special effective date for CRCO
limitation. Paragraphs (g)(1) and (2) of
this section apply only to a consolidated
return change of ownership that occurred
during a consolidated return year for
which the due date of the income tax re-
turn (without extensions) is on or before
March 13, 1998. See also
§1.1502–3(d)(4) for an optional effective
date rule (generally making the rules of
paragraph (g)(1) and (2) of this section
also inapplicable if the consolidated re-
turn change of ownership occurred on or
after January 1, 1997, and during a con-
solidated return year for which the due
date of the income tax return (without ex-
tensions) is on or before March 13, 1998).
* * * * *
§1.1502–4T [Removed]
Par. 5. Section 1.1502–4T is removed.
Par. 6. Section 1.1502–21 is amended
by revising paragraph (c)(2)(ix) to read as
follows:
§1.1502–21 Net operating losses.
* * * * *
(c) * * *
(2) * * *
(ix) Application to other than loss car-
ryovers. Paragraph (g) of this section and
the phrase “or for a carryover that was
subject to the overlap rule described in
paragraph (g) of this section or
§1.1502–15(g) with respect to another
group (the former group)” in this para-
graph (c)(2) apply only to carryovers of
net operating losses, net capital losses,
and for taxable years for which the due
date (without extensions) of the consoli-
dated return is after May 25, 2000, to car-
ryovers of credits described in section
383(a)(2). Accordingly, as the context
may require, if another regulation refer-
ences this section and such other regula-
tion does not concern a carryover of net
operating losses, net capital losses, or for
taxable years for which the due date
(without extensions) of the consolidated
return is after May 25, 2000, carryovers
of credits described in section 383(a)(2),
then such reference does not include a ref-
erence to such paragraph or phrase.
* * * * *
Par. 7. Section 1.1502–55 is added to
read as follows:
§1.1502–55 Computation of alternative
minimum tax of consolidated groups.
(a) through (h)(3) [Reserved].
(h)(4) Separate return year minimum
tax credit.
(i) and (ii) [Reserved].
(iii)(A) Limitation on portion of sepa-
rate return year minimum tax credit aris-
ing in separate return limitation years.
The aggregate of a member’s minimum
tax credits arising in SRLYs that are in-
cluded in the consolidated minimum tax
credits for all consolidated return years of
the group may not exceed—
(1) The aggregate for all consolidated
return years of the member’s contribu-
tions to the consolidated section 53(c)
limitation for each consolidated return
year; reduced by
(2) The aggregate of the member’s
minimum tax credits arising and absorbed
in all consolidated return years (whether
or not absorbed by the member).
(B) Computational rules—(1) Mem-
ber’s contribution to the consolidated sec-
tion 53(c) limitation. Except as provided
in the special rule of paragraph
(h)(4)(iii)(B)(2) of this section, a mem-
ber’s contribution to the consolidated sec-
tion 53(c) limitation for a consolidated re-
turn year equals the member’s share of
the consolidated net regular tax liability
minus its share of consolidated tentative
minimum tax. The group computes the
member’s shares by applying to the re-
spective consolidated amounts the princi-
ples of section 1552 and the percentage
method under §1.1502–33(d)(3), assum-
ing a 100% allocation of any decreased
tax liability. The group makes proper ad-
justments so that taxes and credits not
taken into account in computing the limi-
tation under section 53(c) are not taken
into account in computing the member’s
share of the consolidated net regular tax,
etc. (See, for example, the taxes de-
scribed in section 26(b) that are disre-
garded in computing regular tax liability.)
(2) Adjustment for year in which alter-
native minimum tax is paid. For a consol-
idated return year for which consolidated
tentative minimum tax is greater than
consolidated regular tax liability, the
group reduces the member’s share of the
consolidated tentative minimum tax by
the member’s share of the consolidated
alternative minimum tax for the year. The
group determines the member’s share of
consolidated alternative minimum tax for
a year using the same method it uses to
determine the member’s share of the con-
solidated minimum tax credits for the
year.
(3) Years included in computation. For
purposes of computing the limitation
under this paragraph (h)(4)(iii), the con-
solidated return years of the group include
only those years, including the year to
which a credit is carried, that the member
has been continuously included in the
group’s consolidated return, but exclude
any years after the year to which the
credit is carried.
(4) Subgroup principles. The SRLY
subgroup principles under
§1.1502–21(c)(2) apply for purposes of
2000–24 I.R.B.1255June 12, 2000

this paragraph (h)(4)(iii). The predeces-
sor and successor principles under
§1.1502–21(f) also apply for purposes of
this paragraph (h)(4)(iii).
(5) Overlap with section 383. The
principles under §1.1502–21(g) apply for
purposes of this paragraph (h)(4)(iii). For
example, an overlap of this paragraph
(h)(4)(iii) and the application of section
383 with respect to a credit carryover oc-
curs if a corporation becomes a member
of a consolidated group (the SRLY event)
within six months of the change date of an
ownership change giving rise to a section
383 credit limitation with respect to that
carryover (the section 383 event), with
the result that the limitation of this para-
graph (h)(4)(iii) does not apply. See
§§1.1502–21(g)(2)(ii)(A) and 1.383–1;
see also §1.1502–21(g)(4) (subgroup
rules).
(C) Effective date—(1) In general.
This paragraph (h)(4)(iii) generally ap-
plies to consolidated return years for
which the due date of the income tax re-
turn (without extensions) is after March
13, 1998. See §1.1502–3(d)(4) for an op-
tional effective date rule (generally mak-
ing this paragraph (h)(4)(iii) also applica-
ble to a consolidated return year
beginning on or after January 1, 1997, if
the due date of the income tax return
(without extensions) was on or before
March 13, 1998).
(i) Contribution years. In general, a
group does not take into account a consol-
idated taxable year for which the due date
of the income tax return (without exten-
sions) is on or before March 13, 1998, in
determining a member’s (or subgroup’s)
contributions to the consolidated section
53(c) limitation under this paragraph
(h)(4)(iii). However, if a consolidated
group chooses to apply the optional effec-
tive date rule, the consolidated group
shall not take into account a consolidated
taxable year beginning before January 1,
1997 in determining a member’s (or sub-
group’s) contributions to the consolidated
section 53(c) limitation under this para-
graph (h)(4)(iii).
(ii) Special subgroup rule. In the event
that the principles of §1.1502–21(g)(1) do
not apply to a particular credit carryover
in the current group, then solely for pur-
poses of applying this paragraph
(h)(4)(iii) to determine the limitation with
respect to that carryover and with respect
to which the SRLY register (the aggregate
of the member’s or subgroup’s contribu-
tion to consolidated section 53(c) limita-
tion reduced by the aggregate of the mem-
ber’s or subgroup’s minimum tax credits
arising and absorbed in all consolidated
return years) began in a taxable year for
which the due date of the return is on or
before May 25, 2000, the principles of
§1.1502–21(c)(2) shall be applied without
regard to the phrase “or for a carryover
that was subject to the overlap rule de-
scribed in paragraph (g) of this section or
§1.1502–15(g) with respect to another
group (the former group).”
(2) Overlap rule. Paragraph
(h)(4)(iii)(B)(5) of this section (relating to
overlap with section 383) applies to tax-
able years for which the due date (without
extensions) of the consolidated return is
after May 25, 2000. For purposes of para-
graph (h)(4)(iii)(B)(5
) of this section,
only an ownership change to which sec-
tion 383, as amended by the Tax Reform
Act of 1986 (100 Stat. 2095), applies and
which results in a section 383 credit limi-
tation shall constitute a section 383 event.
The optional effective date rule of
§1.1502–3(d)(4) (generally making this
paragraph (h)(4)(iii) also applicable to a
consolidated return year beginning on or
after January 1, 1997, if the due date of
the income tax return (without exten-
sions) was on or before March 13, 1998)
does not apply with respect to paragraph
(h)(4)(iii)(B)(5) of this section (relating to
the overlap rule).
§1.1502–55T [Removed]
Par. 8. Section 1.1502–55T is re-
moved.
Par. 9. Section 1.1502–98 is amended
by adding a sentence immediately follow-
ing the first sentence to read as follows:
§1.1502–98 Coordination with section
383.
* * * For example, subgroups with re-
spect to the carryover of general business
credits, minimum tax credits, unused for-
eign tax, and net capital loss are deter-
mined by applying the principles of
§1.1502–91(d)(1). * * *
§1.1502–9A [Amended]
Par. 10. Section 1.1502–9A is
amended as follows:
1. In paragraph (a)(2), the last sentence
is amended by removing the language
“1.1502–3T(c)(4)” and adding
“1.1502–3(d)(4)” in its place.
2. In paragraph (b)(1)(v), the last sen-
tence is amended by removing the lan-
guage “1.1502–3T(c)(4)” and adding
“1.1502–3(d)(4)” in its place.
Robert E. Wenzel,
Deputy Commissioner
of Internal Revenue.
Approved May 8, 2000.
Jonathan Talisman,
Deputy Assistant Secretary
of the Treasury.
(Filed by the Office of the Federal Register on May
24, 2000, 8:45 a.m., and published in the issue of the
Federal Register for May 25, 2000, 65 F.R. 12717)
Section 6601.—Interest on
Underpayment, Nonpayment, or
Extensions of Time for Payment,
of Tax
26 CFR 301.6601–1: Interest on underpayments.
What are the rules for applying the net interest
rate of zero under § 6621(d) of the Code to interest
accruing on or after October 1, 1998. See Rev. Proc.
2000–26, page 1257.
Section 6611.—Interest on
Overpayments
26 CFR 301.6611–1: Interest on overpayments.
What are the rules for applying the net interest
rate of zero under § 6621(d) of the Code to interest
accruing on or after October 1, 1998. See Rev. Proc.
2000–26, page 1257.
Section 6621.—Determination
of Rate of Interest
26 CFR 301.6621–1: Interest rate.
What are the rules for applying the net interest
rate of zero under § 6621(d) of the Code to interest
accruing on or after October 1, 1998. See Rev. Proc.
2000–26, page 1257.
June 12, 200012562000–24 I.R.B.

26 CFR 601.105: Examination of returns and
claims for refund, credit, or abatement;
determination of correct tax liability. (Also Part I,
sections 6601, 6611, 6621; 301.6601–1,
301.6611–1, 301.6621–1.)
Rev. Proc. 2000–26
SECTION 1. PURPOSE
This revenue procedure provides guid-
ance regarding the application of
§ 6621(d) of the Internal Revenue Code to
interest accruing on or after October 1,
1998. Section 6621(d) was enacted by
§ 3301 of the Internal Revenue Service
Restructuring and Reform Act of 1998
(RRA), Pub. L. No. 105–206, 112 Stat.
741, and was amended by § 4002(d) of
the Tax and Trade Relief Extension Act of
1998, Pub. L. No. 105–277, 112 Stat.
2681. Section 6621(d) provides for a net
interest rate of zero to the extent of over-
lapping tax underpayments and tax over-
payments, and generally applies to inter-
est for periods beginning after July 22,
1998 (i.e., interest accruing on or after
October 1, 1998). The net interest rate of
zero in § 6621(d) also applies to interest
for periods beginning before July 22,
1998 (i.e., interest accruing before Octo-
ber 1, 1998), provided certain conditions
are met. Rev. Proc. 99–43, 1999–47
I.R.B. 579, which modifies and super-
sedes Rev. Proc. 99–19, 1999–13 I.R.B.
10, provides guidance on the conditions
applicable to requests for the application
of a net interest rate of zero to interest ac-
cruing before October 1, 1998. Section
3.02(1) of Rev. Proc. 99–43 states that
the Service intends to provide further
guidance for interest accruing for periods
on or after October 1, 1998. This revenue
procedure provides guidance on the appli-
cation of § 6621(d) for interest accruing
on or after October 1, 1998.
SECTION 2. BACKGROUND
.01 Interest computations in general.
(1) Section 6601(a) provides, in gen-
eral, that if any amount of tax imposed by
the Code is not paid on or before the last
date prescribed for payment, interest on
such amount must be paid for the period
from such last date to the date paid at the
underpayment rate established under §
6621.
(2) Section 6611(a) provides that in-
terest must be allowed and paid on any
overpayment in respect of any internal
revenue tax at the overpayment rate estab-
lished under § 6621. Section 6611(b)(1)
provides that, in the case of a credit, inter-
est must be allowed and paid from the
date of the overpayment to the due date of
the amount against which the credit is
taken. Section 6611(b)(2) provides that,
in the case of a refund, interest must be al-
lowed and paid from the date of the over-
payment to a date preceding the date of
the refund check by not more than 30
days.
.02 Interest rates in general.
(1) For interest accruing before Janu-
ary 1, 1999, § 6621(a)(1) provides that the
overpayment rate is the federal short-term
rate (determined under § 6621(b)) plus 2
percentage points. For interest accruing
on or after January 1, 1999, § 6621(a)(1)
provides that the overpayment rate is the
federal short term rate (determined under
§ 6621(b)) plus 3 percentage points (2
percentage points in the case of a corpora-
tion). To the extent that an overpayment
of tax by a corporation exceeds $10,000,
the overpayment rate is the federal short-
term rate plus 0.5 percent.
(2) Section 6621(a)(2) provides that
the underpayment rate is the federal short-
term rate (determined under § 6621(b))
plus 3 percentage points. Special rules in
§ 6621(c) increase the underpayment rate
on large corporate underpayments by an
additional 2 percentage points.
.03 Interest for overlapping periods.
(1) Section 6621(d), as enacted by
the RRA on July 22, 1998, provides that,
to the extent that for any period interest is
payable under subchapter A (§§ 6601 and
6602) and allowable under subchapter B
(§ 6611) on equivalent underpayments
and overpayments by the same taxpayer
of tax imposed by the Code, the net rate
of interest under § 6621 on such amounts
is zero for such period.
(2) The Conference Report, H. R.
Conf. Rep. No. 599, 105th Cong., 2d Sess.
257 (1998), accompanying the RRA pro-
vides that the net interest rate of zero is ap-
plied without regard to whether the over-
payment or underpayment is currently
outstanding. Further, each overpayment or
underpayment is considered only once in
determining whether equivalent amounts
of overpayment and underpayment overlap
for a particular period. That report also
provides that the net interest rate of zero
applies even when special rules increase
the rate of interest for large corporate un-
derpayments under § 6621(c), or decrease
the rate of interest for large corporate over-
payments under § 6621(a).
.04 Interest accruing on or after Octo-
ber 1, 1998.
(1) Section 3301(c)(1) of the RRA
states that § 6621(d) generally applies to
interest for periods beginning after July
22, 1998 (i.e., interest accruing on or after
October 1, 1998).
(2) In enacting § 6621(d), Congress
anticipated that in situations in which in-
terest is both payable and allowable by
the same taxpayer for the same period, the
Secretary will make all reasonable efforts
to offset the liabilities, rather than process
them separately using the net interest rate
of zero. See H. R. Conf. Rep. No. 599,
105th Cong., 2d Sess. 257 (1998).
(3) Section 3301(c)(1) of the RRA
does not impose preconditions to apply-
ing the net interest rate of zero in §
6621(d) to interest accruing on or after
October 1, 1998. Thus, for interest accru-
ing on or after October 1, 1998, there is
no statutory requirement that the taxpayer
request that the Service apply § 6621(d).
(4) The Service does not currently
have the ability to automatically apply the
net rate of zero in § 6621(d). Congress
recognized this current limitation and in-
tended that until such time as procedures
are implemented that allow for the auto-
matic application of § 6621(d) by the Ser-
vice, the Service will promptly and care-
fully consider any taxpayer’s request to
have interest charges recalculated in ac-
cordance with § 6621(d). See H. R. Rep.
No. 364 (Part 1), 105th Cong., 1st Sess.
64 (1998); S. Rep. No. 174, 105th Cong.,
2d Sess. 62 (1998).
SECTION 3. SCOPE
.01Applicability. This revenue proce-
dure applies to the application of the net
interest rate of zero in § 6621(d) to inter-
est for periods beginning after July 22,
1998 (i.e., interest accruing on or after
October 1, 1998).
2000–24 I.R.B.1257June 12, 2000
Part III. Administrative, Procedural, and Miscellaneous

.02 Inapplicability.This revenue pro-
cedure does not apply to:
(1) the application of the net interest
rate of zero in § 6621(d) to interest for pe-
riods beginning before July 22, 1998 (i.e.,
interest accruing before October 1, 1998)
(see Rev. Proc. 99–43 for guidance re-
garding interest accruing before October
1, 1998);
(2) interest accruing on or after Janu-
ary 1, 1999, for taxpayers other than cor-
porations (the interest rate on underpay-
ments and overpayments is equal for such
taxpayers on or after January 1, 1999);
(3) an overpayment or underpayment
for any period during which interest on
the overpayment or underpayment is not
allowable or payable by law (e.g., the 45-
day interest disallowance rule under
§ 6611(e)); or
(4) the extent of an offset made pur-
suant to §§ 6402(a) and 6601(f), regard-
ing the crediting of an outstanding over-
payment against an outstanding
underpayment.
SECTION 4. IDENTIFYING PERIODS
FOR WHICH THE NET RATE OF
ZERO APPLIES
.01 In general. The Service will take
reasonable steps to identify overlapping
periods of tax overpayments and under-
payments and apply the net interest rate of
zero in § 6621(d) to interest accruing on or
after October 1,1998. In such instances,
the Service will provide a copy of the in-
terest computation to the taxpayer. How-
ever, because the Service is currently un-
able to automatically apply the net interest
rate of zero in § 6621(d), there may be in-
stances when the Service fails to identify
periods of overlap and apply the net inter-
est rate of zero. To ensure that taxpayers
receive the benefit of the net interest rate
of zero in all applicable situations, taxpay-
ers should request the net interest rate of
zero (or request the Service to recompute
the net interest rate of zero if the taxpayer
disagrees with a Service computation of
the net interest rate of zero) on or before
the date on which the last applicable pe-
riod of limitation (as described in section
4.02 of this revenue procedure) closes and
according to the procedures in section 5 of
this revenue procedure. Requests will be
required until such time as the Service can
automatically apply the net interest rate of
zero.
.02 Applicable periods of limitation.
The applicable periods of limitation are as
follows:
(1) Underpayment interest. A claim
for credit or refund of interest paid on an
underpayment pursuant to § 6601 or 6602
generally must be filed within 3 years
from the time the tax return was filed or 2
years from the time the interest was paid,
whichever period expires later, pursuant
to § 6511.
(2) Overpayment interest. A claim
for payment of additional interest allow-
able on an overpayment pursuant to
§ 6611 must be filed within the 6-year pe-
riod in which a suit must be filed pursuant
to 28 U.S.C. §§ 2401 and 2501. SeeRev.
Rul. 56–506, 1956–2 C.B. 959. A tax-
payer’s request for application of the net
interest rate of zero under the procedures
described in section 5 of this revenue pro-
cedure does not protect the taxpayer’s
rights with respect to suits against the
government pursuant to 28 U.S.C.
§§ 2401 and 2501. The only manner in
which a taxpayer can fully protect its
rights to additional overpayment interest
is by filing a civil suit against the United
States prior to the termination of the
6–year statutory period set forth in 28
U.S.C. §§ 2401 and 2501. SeeRev. Rul.
57–242, 1957–1 C.B. 452.
.03 Net Rate of Zero. In general, the
Service will apply the net rate of zero as
follows:
(1) If the period of limitation for re-
funding underpayment interest (as de-
scribed in section 4.02(1) of this revenue
procedure) is open at the time a claim (as
described in sections 5.01 through 5.04 of
this revenue procedure) is filed or a writ-
ten request (as described in section 5.06
of this revenue procedure) is made, the
Service will apply the net rate of zero by
decreasing underpayment interest owed
by the taxpayer.
(2) If the period of limitation for re-
funding underpayment interest (as de-
scribed in section 4.02(1) of this revenue
procedure) is closed at the time a claim
(as described in sections 5.01 through
5.04 of this revenue procedure) is filed or
a written request (as described in section
5.06 of this revenue procedure) is made,
but the period for paying additional over-
payment interest (as described in section
4.02(2) of this revenue procedure) is
open, the Service will apply the net rate of
zero by increasing overpayment interest
owed to the taxpayer.
SECTION 5. PROCEDURES FOR
REQUESTING THE NET RATE OF
ZERO
.01 Form to file. Except as provided in
section 5.06 of this revenue procedure, re-
quests for the application of the net inter-
est rate of zero in § 6621(d) with respect
to interest accruing on or after October 1,
1998, should be made on Form 843,
Claim for Refund and Request for Abate-
ment.
.02 Where to file. A Form 843 request-
ing the net rate of zero solely with respect
to interest accruing on or after October 1,
1998, should be sent to the Internal Rev-
enue Service Center where the taxpayer
filed its most recent federal income tax re-
turn.
.03 Label. The taxpayer should label
the top of the Form 843: “Request for Net
Interest Rate of Zero Under Rev. Proc.
2000–26.”
.04 Filing requirements for Form 843.
(1) Line 1 should be left blank.
(2) The taxpayer may, but is not re-
quired to, place a dollar amount on Line
2.
(3) Line 3 should indicate the type of
tax and type of return covered by the re-
quest. More than one box may be
checked if more than one type of tax or
return is covered by the request. In addi-
tion, any taxes imposed by the Code (or
returns for those taxes) for which there is
no box on Line 3 should be written in on
that line.
(4) Line 4 should be left blank.
(5) Line 5 should:
(a) identify the taxable periods for
which the taxpayer overpaid and under-
paid its tax liability. A separate Form 843
is not required for each separate taxable
period involved in the request;
(b) state when the taxpayer paid
the tax if the underpayment is no longer
outstanding;
(c) state when the taxpayer re-
ceived a refund of tax if the overpayment
is no longer outstanding;
(d) identify and establish the pe-
riod(s) for which the taxpayer’s overpay-
ment and underpayment overlapped and
the overlapping amount. For this pur-
pose, the taxpayer should provide any
background material (such as copies of
June 12, 200012582000–24 I.R.B.

examination reports, notices, or prior in-
terest computations provided by the Ser-
vice) relating to the overpayments and un-
derpayments. The background material is
needed to assist the Service in determin-
ing the period(s) for which the overpay-
ment and underpayment overlap, and the
amount of such overlap;
(e) state that, to the extent of
equivalent amounts of underpayment and
overpayment for the period(s) identified
and established under section 5.04(5)(d)
of this revenue procedure, the period(s)
has (have) been used only once in a re-
quest to obtain the net interest rate of zero
under § 6621(d); however, if the full
amount of the overpayment or underpay-
ment is not used in a netting calculation,
the remaining portion may be used in an-
other netting calculation; and
(f) provide a computation, to the
extent possible, of the amount of interest
to be credited, refunded, or abated to pro-
vide a net interest rate of zero for the pe-
riod(s) of overlap. This computation gen-
erally should be made by applying
§ 6621(d) to reduce the taxpayer’s under-
payment interest payable to the Service.
However, if the Form 843 is filed after
December 31, 1999, and only the period
of limitation for claiming additional over-
payment interest is open on that filing
date, the computation should be made by
applying § 6621(d) to increase the tax-
payer’s overpayment interest payable by
the Service.
.05 Verification. The amounts used in a
computation provided under section
5.04(5)(f) of this revenue procedure are
subject to verification by the Service and
may be subject to adjustment for purposes
of computing the net interest rate of zero
pursuant to § 6621(d).
.06 Special procedure. No Form 843 is
required when a computation of interest
using the net interest rate of zero under §
6621(d) for interest accruing on or after
October 1, 1998, is requested by a tax-
payer in connection with a return (or re-
turns) of the taxpayer under consideration
by any function of the Service (including
Examination, Appeals, or a case before a
federal court that requires a computation
of interest by any function of the Service).
Rather than filing a Form 843, the tax-
payer should provide the contact repre-
sentative of such function a letter or writ-
ten statement that:
(1) states that the taxpayer is request-
ing the net interest rate of zero under
§ 6621(d);
(2) indicates the type of tax and type
of return that affects the interest computa-
tion for the taxable period under considera-
tion;
(3) states when and for what period(s)
the refund or payment (that affects the in-
terest computation for the taxable period
under consideration) was made; and
(4) states that, to the extent of equiva-
lent amounts of overpayment or underpay-
ment, the period(s) set forth under section
5.06(3) of this revenue procedure has
(have) not previously been applied to ob-
tain a net interest rate of zero under §
6621(d).
.07 Special procedure verification. The
refund or payment provided under section
5.06(3) of this revenue procedure is sub-
ject to verification by the Service and may
be subject to adjustment for purposes of
computing the net interest rate of zero
pursuant to § 6621(d).
.08 Coordination of requests. If a tax-
payer has made a request for the applica-
tion of the net interest rate of zero for in-
terest accruing before October 1, 1998,
pursuant to either Rev. Proc. 99–19 or
Rev. Proc. 99–43, then that taxpayer
does not have to make a separate request
pursuant to this revenue procedure for the
portion of the overlapping period identi-
fied in that request that affects interest ac-
cruing on or after October 1, 1998. The
Service will apply the net interest rate of
zero to interest accruing for the entire
overlapping period identified in the previ-
ously filed request at the time such re-
quest is processed. Similarly, if a tax-
payer anticipates that a request will be
filed pursuant to Rev. Proc. 99–43, then
the taxpayer may request the net interest
rate of zero for the entire overlapping pe-
riod and will not be required to make a
separate request under this revenue proce-
dure for the portion of the overlapping pe-
riod that affects interest accruing on or
after October 1, 1998. The Service will
apply the net interest rate of zero to inter-
est accruing for the entire overlapping pe-
riod identified in the request at the time
such request is processed.
SECTION 6. EFFECTIVE DATE
This revenue procedure is effective for
the application of the net interest rate of
zero in § 6621(d) to interest accruing on
or after October 1, 1998.
DRAFTING INFORMATION
The principal author of this revenue
procedure is John J. McGreevy of the Of-
fice of Assistant Chief Counsel (Income
Tax and Accounting). For further infor-
mation regarding this revenue procedure,
contact Mr. McGreevy on (202) 622-4910
(not a toll- free call).
2000–24 I.R.B.1259June 12, 2000

June 12, 2000i2000–24 I.R.B.
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus,
if an earlier ruling held that a principle
applied to A, and the new ruling holds
that the same principle also applies to B,
the earlier ruling is amplified. (Compare
with modified, below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously
published ruling and points out an essen-
tial difference between them.
Modified is used where the substance
of a previously published position is
being changed. Thus, if a prior ruling
held that a principle applied to 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

Numerical Finding List
1
Bulletins 2000–1 through 2000–23
Announcements:
2000–1, 2000–2 I.R.B. 294
2000–2, 2000–2 I.R.B. 295
2000–3, 2000–2 I.R.B. 296
2000–4, 2000–3 I.R.B. 317
2000–5, 2000–4 I.R.B. 427
2000–6, 2000–4 I.R.B. 428
2000–7, 2000–6 I.R.B. 586
2000–8, 2000–6 I.R.B. 586
2000–9, 2000–9 I.R.B. 733
2000–10, 2000–9 I.R.B. 733
2000–11, 2000–10 I.R.B. 739
2000–12, 2000–12 I.R.B. 835
2000–13, 2000–11 I.R.B. 771
2000–14, 2000–11 I.R.B. 772
2000–15, 2000–12 I.R.B. 837
2000–16, 2000–12 I.R.B. 837
2000–17, 2000–13 I.R.B. 846
2000–18, 2000–13 I.R.B. 846
2000–19, 2000–19 I.R.B. 973
2000–20, 2000–19 I.R.B. 977
2000–21, 2000–19 I.R.B. 983
2000–22, 2000–19 I.R.B. 987
2000–23, 2000–19 I.R.B. 992
2000–24, 2000–14 I.R.B. 855
2000–25, 2000–14 I.R.B. 855
2000–26, 2000–15 I.R.B. 876
2000–27, 2000–15 I.R.B. 876
2000–28, 2000–15 I.R.B. 876
2000–29, 2000–15 I.R.B. 877
2000–30, 2000–15 I.R.B. 877
2000–31, 2000–15 I.R.B. 877
2000–32, 2000–15 I.R.B. 879
2000–33, 2000–15 I.R.B. 878
2000–34, 2000–15 I.R.B. 879
2000–35, 2000–16 I.R.B. 922
2000–36, 2000–16 I.R.B. 947
2000–37, 2000–16 I.R.B. 947
2000–38, 2000–16 I.R.B. 948
2000–39, 2000–16 I.R.B. 948
2000–40, 2000–16 I.R.B. 948
2000–41, 2000–16 I.R.B. 949
2000–42, 2000–16 I.R.B. 949
2000–43, 2000–17 I.R.B. 957
2000–44, 2000–17 I.R.B. 958
2000–45, 2000–18 I.R.B. 962
2000–46, 2000–19 I.R.B. 997
2000–47, 2000–21 I.R.B. 1118
2000–48, 2000–23 I.R.B. 1243
2000–49, 2000–19 I.R.B. 998
2000–50, 2000–19 I.R.B. 998
2000–51, 2000–22 I.R.B. 1141
2000–52, 2000–22 I.R.B. 1142
2000–53, 2000–22 I.R.B. 1144
Court Decisions:
2066, 2000–15 I.R.B. 867
2067, 2000–15 I.R.B. 863
Notices:
2000–1, 2000–2 I.R.B. 288
2000–2, 2000–9 I.R.B. 727
2000–3, 2000–4 I.R.B. 413
2000–4, 2000–3 I.R.B. 313
2000–5, 2000–3 I.R.B. 314
Notices—continued:
2000–6, 2000–3 I.R.B. 315
2000–7, 2000–4 I.R.B. 419
2000–8, 2000–4 I.R.B. 420
2000–9, 2000–5 I.R.B. 449
2000–10, 2000–5 I.R.B. 451
2000–11, 2000–6 I.R.B. 572
2000–12, 2000–9 I.R.B. 727
2000–13, 2000–9 I.R.B. 732
2000–14, 2000–10 I.R.B. 737
2000–15, 2000–12 I.R.B. 826
2000–16, 2000–12 I.R.B. 826
2000–17, 2000–12 I.R.B. 827
2000–18, 2000–13 I.R.B. 845
2000–19, 2000–13 I.R.B. 845
2000–20, 2000–14 I.R.B. 851
2000–21, 2000–19 I.R.B. 967
2000–22, 2000–16 I.R.B. 902
2000–23, 2000–17 I.R.B. 952
2000–24, 2000–17 I.R.B. 952
2000–25, 2000–17 I.R.B. 954
2000–26, 2000–17 I.R.B. 954
2000–27, 2000–21 I.R.B. 1116
2000–28, 2000–21 I.R.B. 1116
2000–29, 2000–23 I.R.B. 1241
Proposed Regulations:
REG–208280–86, 2000–8 I.R.B. 654
REG–209135–88, 2000–8 I.R.B. 681
REG–208254–90, 2000–6 I.R.B. 577
REG–209601–92, 2000–12 I.R.B. 829
REG–100276–97, 2000–8 I.R.B. 682
REG–101492–98, 2000–3 I.R.B. 326
REG–106012–98, 2000–2 I.R.B. 290
REG–106186–98, 2000–23 I.R.B. 1226
REG–107644–98, 2000–23 I.R.B. 1229
REG–109101–98, 2000–16 I.R.B. 903
REG–110311–98, 2000–11 I.R.B. 767
REG–122450–98, 2000–8 I.R.B. 682
REG–103831–99, 2000–5 I.R.B. 452
REG–103882–99, 2000–8 I.R.B. 706
REG–105089–99, 2000–6 I.R.B. 580
REG–105279–99, 2000–8 I.R.B. 707
REG–105606–99, 2000–4 I.R.B. 421
REG–107872–99, 2000–16 I.R.B. 911
REG–111119–99, 2000–5 I.R.B. 455
REG–113572–99, 2000–7 I.R.B. 624
REG–116048–99, 2000–6 I.R.B. 584
REG–116567–99, 2000–5 I.R.B. 463
REG–116704–99, 2000–3 I.R.B. 325
REG–117162–99, 2000–15 I.R.B. 871
REG–100163–00, 2000–7 I.R.B. 633
REG–100291–00, 2000–16 I.R.B. 917
REG–103735–00, 2000–11 I.R.B. 770
REG–103736–00, 2000–11 I.R.B. 768
Railroad Retirement Quarterly Rate:
2000–9 I.R.B. 721
Revenue Procedures:
2000–1, 2000–1 I.R.B. 4
2000–2, 2000–1 I.R.B. 73
2000–3, 2000–1 I.R.B. 103
2000–4, 2000–1 I.R.B. 115
2000–5, 2000–1 I.R.B. 158
2000–6, 2000–1 I.R.B. 187
2000–7, 2000–1 I.R.B. 227
2000–8, 2000–1 I.R.B. 230
2000–9, 2000–2 I.R.B. 280
Revenue Procedures—continued:
2000–10, 2000–2 I.R.B. 287
2000–11, 2000–3 I.R.B. 309
2000–12, 2000–4 I.R.B. 387
2000–13, 2000–6 I.R.B. 515
2000–14, 2000–18 I.R.B. 960
2000–15, 2000–5 I.R.B. 447
2000–16, 2000–6 I.R.B. 518
2000–17, 2000–11 I.R.B. 766
2000–18, 2000–9 I.R.B. 722
2000–19, 2000–12 I.R.B. 785
2000–20, 2000–6 I.R.B. 553
2000–21, 2000–19 I.R.B. 971
2000–22, 2000–20 I.R.B. 1008
2000–23, 2000–21 I.R.B. 1018
2000–24, 2000–22 I.R.B. 1133
2000–25, 2000–21 I.R.B. 1033
Revenue Rulings:
2000–1, 2000–2 I.R.B. 250
2000–2, 2000–3 I.R.B. 305
2000–3, 2000–3 I.R.B. 297
2000–4, 2000–4 I.R.B. 331
2000–5, 2000–5 I.R.B. 436
2000–6, 2000–6 I.R.B. 512
2000–7, 2000–9 I.R.B. 712
2000–8, 2000–7 I.R.B. 617
2000–9, 2000–6 I.R.B. 497
2000–10, 2000–8 I.R.B. 643
2000–11, 2000–10 I.R.B. 734
2000–12, 2000–11 I.R.B. 744
2000–13, 2000–12 I.R.B. 774
2000–14, 2000–12 I.R.B. 779
2000–15, 2000–12 I.R.B. 774
2000–16, 2000–12 I.R.B. 780
2000–17, 2000–13 I.R.B. 842
2000–18, 2000–14 I.R.B. 847
2000–19, 2000–14 I.R.B. 849
2000–20, 2000–16 I.R.B. 880
2000–21, 2000–16 I.R.B. 881
2000–22, 2000–16 I.R.B. 880
2000–23, 2000–19 I.R.B. 964
2000–24, 2000–19 I.R.B. 963
2000–25, 2000–20 I.R.B. 1006
2000–26, 2000–22 I.R.B. 1124
2000–27, 2000–21 I.R.B. 1016
2000–28, 2000–23 I.R.B. 1157
Tax Conventions:
2000–22 I.R.B. 1126
Treasury Decisions:
8849, 2000–2 I.R.B. 245
8850, 2000–2 I.R.B. 265
8851, 2000–2 I.R.B. 275
8852, 2000–2 I.R.B.253
8853, 2000–4 I.R.B.377
8854, 2000–3 I.R.B.306
8855, 2000–4 I.R.B.374
8856, 2000–3 I.R.B.298
8857, 2000–4 I.R.B.365
8858, 2000–4 I.R.B.332
8859, 2000–5 I.R.B.429
8860, 2000–5 I.R.B.437
8861, 2000–5 I.R.B.441
8862, 2000–6 I.R.B.466
8863, 2000–6 I.R.B.488
8864, 2000–7 I.R.B.614
8865, 2000–7 I.R.B.589
2000–24 I.R.B.iiJune 12, 2000
1
A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 1999–27 through
1999–52 is in Internal Revenue Bulletin 2000–1,
dated January 3, 2000.

Treasury Decisions—continued:
8866, 2000–6 I.R.B.495
8867, 2000–7 I.R.B.620
8868, 2000–6 I.R.B.491
8869, 2000–6 I.R.B.498
8870, 2000–8 I.R.B.647
8871, 2000–8 I.R.B.641
8872, 2000–8 I.R.B.639
8873, 2000–9 I.R.B.713
8874, 2000–8 I.R.B.644
8875, 2000–11 I.R.B.761
8876, 2000–11 I.R.B.753
8877, 2000–11 I.R.B.747
8878, 2000–15 I.R.B.857
8879, 2000–16 I.R.B.882
8880, 2000–20 I.R.B.1003
8881, 2000–23 I.R.B.1158
8882, 2000–23 I.R.B.1150
8883, 2000–23 I.R.B.1151
June 12, 2000iii2000–24 I.R.B.

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2000–1 through 2000–23
Announcements:
99–40
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
99–50
Modified by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
99–59
Superseded by
Announcement 2000–47, 2000–21 I.R.B. 1118
2000–18
Corrected by
Announcement 2000–32, 2000–15 I.R.B. 878
Notices:
88–125
Obsoleted by
T.D. 8870, 2000–8 I.R.B. 647
92–48
Obsoleted by
Notice 2000–11, 2000–6 I.R.B. 572
97–19
Modified by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
98–22
Obsoleted by
T.D. 8870, 2000–8 I.R.B. 647
98–52
Modified by
Notice 2000–3, 2000–4 I.R.B. 413
98–61
Modified and superseded by
Rev. Proc. 2000–15, 2000–5 I.R.B. 447
99–8
Obsoleted by
Rev. Proc. 2000–12, 2000–4 I.R.B. 387
2000–4
Corrected by
Announcement 2000–9, 2000–9 I.R.B. 733
Proposed Regulations:
REG–209601–92
Corrected by
Announcement 2000–40, 2000–16 I.R.B. 948
REG–100276–97
Corrected by
Announcement 2000–38, 2000–16 I.R.B. 948
REG–101492–98
Corrected by
Announcement 2000–16, 2000–12 I.R.B. 837
REG–122450–98
Corrected by
Announcement 2000–38, 2000–16 I.R.B. 948
REG–113572–99
Corrected by
Announcement 2000–41, 2000–16 I.R.B. 949
Proposed Regulations:—Continued
REG–103736–00
Corrected by
Announcement 2000–44, 2000–17 I.R.B. 958
Revenue Procedures:
80–18
Modified by
Rev. Proc. 2000–13, 2000–6 I.R.B. 515
89–9
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
89–13
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
90–21
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
91–66
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
92–13
Modified, amplified, and superseded by
Rev. Proc. 2000–11, 2000–3 I.R.B. 309
92–13A
Modified, amplified, and superseded by
Rev. Proc. 2000–11, 2000–3 I.R.B. 309
92–41
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
93–9
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
93–10
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
94–12
Modified, amplified, and superseded by
Rev. Proc. 2000–11, 2000–3 I.R.B. 309
95–42
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
96–13
Modified by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
98–22
Modified and superseded by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
98–27
Superseded by
Rev. Proc. 2000–12, 2000–4 I.R.B. 387
98–64
Superseded by
Rev. Proc. 2000–9, 2000–2 I.R.B. 280
98–65
Superseded by
Rev. Proc. 2000–19, 2000–12 I.R.B. 785
99–1
Superseded by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
Revenue Procedures—Continued:
99–2
Superseded by
Rev. Proc. 2000–2, 2000–1 I.R.B. 73
99–3
Superseded by
Rev. Proc. 2000–3, 2000–1 I.R.B. 103
99–4
Superseded by
Rev. Proc. 2000–4, 2000–1 I.R.B. 115
99–5
Superseded by
Rev. Proc. 2000–5, 2000–1 I.R.B. 158
99–6
Superseded by
Rev. Proc. 2000–6, 2000–1 I.R.B. 187
99–7
Superseded by
Rev. Proc. 2000–7, 2000–1 I.R.B. 227
99–8
Superseded by
Rev. Proc. 2000–8, 2000–1 I.R.B. 230
99–13
Modified and superseded by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
99–20
Supplemented by
Rev. Proc. 2000–14, 2000–18 I.R.B. 960
99–22
Obsoleted by
(except as provided in section 5.02 of)
Rev. Proc. 2000–21, 2000–19 I.R.B. 971
99–24
Superseded by
Rev. Proc. 2000–23, 2000–21 I.R.B. 1018
99–25
Superseded by
Rev. Proc. 2000–24, 2000–22 I.R.B. 1133
99–29
Superseded by
Rev. Proc. 2000–25, 2000–21 I.R.B. 1033
99–31
Modified and superseded by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
99–49
Modified and amplified by
Rev. Rul. 2000–4, 2000–4 I.R.B. 331
Rev. Rul. 2000–7, 2000–9 I.R.B. 712
Notice 2000–4, 2000–3 I.R.B. 313
99–51
Superseded by
Rev. Proc. 2000–3, 2000–1 I.R.B. 103
2000–6
Modified by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
2000–8
Modified by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
2000–24 I.R.B.ivJune 12, 2000
1
A cumulative list of current actions on previously
published items in Internal Revenue Bulletins
1999–27 through 1999–52 is in Internal Revenue
Bulletin 2000–1, dated January 3, 2000.

Revenue Procedures—Continued:
2000–12
Corrected by
Announcement 2000–50, 2000–19 I.R.B. 998
2000–16
Corrected by
Announcement 2000–17, 2000–13 I.R.B. 846
Revenue Rulings:
57–259
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
57–499
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
73–292
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
76–79
Distinguised by
Rev. Rul. 2000–24, 2000–19 I.R.B. 963
78–218
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
80–76
Obsoleted by
T.D. 8883, 2000–23 I.R.B. 1151
86–62
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
88–36
Modified by
Rev. Rul. 2000–6, 2000–6 I.R.B. 512
89–89
Obsoleted by
Rev. Rul. 2000–2, 2000–3 I.R.B. 305
92–19
Supplemented by
Rev. Rul. 2000–17, 2000–13 I.R.B. 842
98–30
Amplified and superseded by
Rev. Rul. 2000–8, 2000–7 I.R.B. 617
Treasury Decisions:
8734
Modified by
T.D. 8856, 2000–3 I.R.B. 298
8804
Modified by
T.D. 8856, 2000–3 I.R.B. 298
8845
Corrected by
Announcement 2000–6, 2000–4 I.R.B. 428
8846
Corrected by
Announcement 2000–3, 2000–2 I.R.B. 296
8847
Corrected by
Announcement 2000–13, 2000–11 I.R.B. 771
8849
Corrected by
Announcement 2000–28, 2000–15 I.R.B. 876
8852
Corrected by
Announcement 2000–18, 2000–13 I.R.B. 846
Treasury Decisions—continued:
8853
Corrected by
Announcement 2000–33, 2000–15 I.R.B. 878
8856
Corrected by
Announcement 2000–31, 2000–15 I.R.B. 877
8859
Corrected by
Announcement 2000–27, 2000–15 I.R.B. 876
8864
Corrected by
Announcement 2000–26, 2000–15 I.R.B. 876
8865
Corrected by
Announcement 2000–37, 2000–16 I.R.B. 947
8867
Corrected by
Announcement 2000–30, 2000–15 I.R.B. 877
8869
Corrected by
Announcement 2000–36, 2000–16 I.R.B. 947
8870
Corrected by
Announcement 2000–34, 2000–15 I.R.B. 879
8874
Corrected by
Announcement 2000–29, 2000–15 I.R.B. 877
8879
Corrected by
Announcement 2000–53, 2000–22 I.R.B. 1144
June 12, 2000v2000–24 I.R.B.

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