us-irs-revenue-rulings-irb-2001-41-pdf•Internal Revenue Bulletin 2001-41 (PDF rendition): IRS Revenue Rulings
Internal Revenue Bulletin 2001-41 (PDF rendition): IRS Revenue Rulings
us-irs-revenue-rulings-irb-2001-41-pdfInternal Revenue Bulletin 2001-41 (PDF rendition): IRS Revenue RulingsGuidance
Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.
INCOME TAX Rev. Rul. 2001–49, page 312. Federal rates; adjusted federal rates; adjusted feder- al long-term rate and the long-term exempt rate.For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for October 2001. Notice 2001–59, page 315. Interest allocation.The IRS and the Treasury Department are soliciting comments on the appropriate method for allo- cating interest to certain types of financial positions that may constitute integrated financial transactions. Notice 2001–64, page 316. This notice solicits comments concerning the scope and substance of proposed regulations under section 707(a)(2)(B) of the Code. Comments must be received by March 31, 2002. EMPLOYEE PLANS Announcement 2001–96, page 317. The Service has issued a new form to be used by sponsors of prototype simplified employee pensions (SEPs) and pro- totype SIMPLE IRA plans to apply for opinion letters on these documents. The new Form 5306-A, Application for Approval of Prototype Simplified Employee Pension (SEP) or Savings Incentive Match Plan for Employees of Small Employers (SIM- PLE IRA Plan) , will replace Form 5306-SEP. EXEMPT ORGANIZATIONS Announcement 2001–100, page 317. A list is provided of organizations now classified as private foundations. EMPLOYMENT TAX Page 314. Railroad retirement; rate determination; quarterly.The Railroad Retirement Board has determined that the rate of tax imposed by section 3221 of the Code shall be 26 cents for the quarter beginning October 1, 2001. EXCISE TAX Announcement 2001–98, page 317. This announcement advises taxpayers who file Form 720, Quarterly Federal Excise Tax Return, of the revised filing and deposit requirements effective for calendar quarters begin- ning after September 30, 2001. Internal Revenue bbuulllleettiinn Bulletin No. 2001–41 October 9, 2001 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. October 9, 20012001–41 I.R.B. The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing offi- cial rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It is published weekly and may be obtained from the Superintendent of Documents on a subscription basis. Bulletin contents are consolidated semiannually into Cumulative Bulletins, which are sold on a single-copy basis. It is the policy of the Service to publish in the Bulletin all sub- stantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless other- wise indicated. Procedures relating solely to matters of in- ternal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published. Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements. Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying pub- lished rulings and procedures, the effect of subsequent leg- islation, regulations, court decisions, rulings, and proce- dures must be considered, and Service personnel and oth- ers concerned are cautioned against reaching the same con- clusions in other cases unless the facts and circumstances are substantially the same. The Bulletin is divided into four parts as follows: Part I.—1986 Code. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1986. Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions and Other Related Items, and Subpart B, Legislation and Related Committee Reports. Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Sub- parts. Also included in this part are Bank Secrecy Act Admin- istrative Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement). Part IV.—Items of General Interest. This part includes notices of proposed rulemakings, disbar- ment and suspension lists, and announcements. The first Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the first Bulletin of the succeeding semi- annual period, respectively. The IRS Mission Provide America’s taxpayers top quality service by help- ing them understand and meet their tax responsibilities and by applying the tax law with integrity and fairness to all. Introduction The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate. For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402. Section 42.—Low-Income Housing Credit The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of October 2001. See Rev. Rul. 2001–49, on this page. Section 280G.—Golden Parachute Payments Federal short-term, mid-term, and long-term rates are set forth for the month of October 2001. See Rev. Rul. 2001–49, on this page. Section 382.—Limitation on Net Operating Loss Carryforwards and Certain Built-In Losses Following Ownership Change The adjusted applicable federal long-term rate is set forth for the month of October 2001. See Rev. Rul. 2001–49, on this page. Section 412.—Minimum Funding Standards The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of October 2001. See Rev. Rul. 2001–49, on this page. Section 467.—Certain Payments for the Use of Property or Services The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of October 2001. See Rev. Rul. 2001–49, on this page. Section 468.—Special Rules for Mining and Solid Waste Reclamation and Closing Costs The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of October 2001. See Rev. Rul. 2001–49, on this page. Section 482.—Allocation of Income and Deductions Among Taxpayers Federal short-term, mid-term, and long-term rates are set forth for the month of October 2001. See Rev. Rul. 2001–49, on this page. Section 483.—Interest on Certain Deferred Payments The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of October 2001. See Rev. Rul. 2001–49, on this page. Section 642.—Special Rules for Credits and Deductions Federal short-term, mid-term, and long-term rates are set forth for the month of October 2001. See Rev. Rul. 2001–49, on this page. Section 807.—Rules for Certain Reserves The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of October 2001. See Rev. Rul. 2001–49, on this page. Section 846.—Discounted Unpaid Losses Defined The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of October 2001. See Rev. Rul. 2001–49, on this page. Section 882(c).—Allowance of Deductions and Credits The IRS and the Treasury Department are solicit- ing comments on the appropriate method for allocat- ing interest to certain types of financial positions that may constitute integrated financial transactions. See Notice 2001–59, page 315. 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 pur- poses of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for October 2001. Rev. Rul. 2001–49 This revenue ruling provides various prescribed rates for federal income tax purposes for October 2001 (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. October 9, 20013122001–41 I.R.B. Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 REV. RUL. 2001–49 TABLE 1 Applicable Federal Rates (AFR) for October 2001 Period for Compounding AnnualSemiannualQuarterlyMonthly Short-Term AFR3.58%3.55%3.53% 3.52% 110% AFR3.95%3.91%3.89%3.88% 120% AFR4.31%4.26%4.24%4.22% 130% AFR4.67%4.62%4.59%4.58% Mid-Term AFR4.59%4.54%4.51%4.50% 110% AFR5.05%4.99%4.96%4.94% 120% AFR5.52%5.45%5.41%5.39% 130% AFR5.99%5.90%5.86%5.83% 150% AFR6.93%6.81%6.75%6.72% 175% AFR8.11%7.95% 7.87%7.82% Long-Term AFR5.39% 5.32% 5.29%5.26% 110% AFR5.94%5.85%5.81%5.78% 120% AFR6.48%6.38%6.33%6.30% 130% AFR7.04%6.92%6.86%6.82% 2001–41 I.R.B.313October 9, 2001 REV. RUL. 2001–49 TABLE 2 Adjusted AFR for October 2001 Period for Compounding AnnualSemiannualQuarterlyMonthly Short-Term adjusted AFR2.72%2.70%2.69%2.68% Mid-term adjusted AFR3.57%3.54%3.52%3.51% Long-term adjusted AFR4.71%4.66%4.63%4.62% REV. RUL. 2001–49 TABLE 3 Rates Under Section 382 for October 2001 Adjusted federal long-term rate for the current month4.71% 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.)4.94% REV. RUL. 2001–49 TABLE 4 Appropriate Percentages Under Section 42(b)(2) for October 2001 Appropriate percentage for the 70% present value low-income housing credit8.16% Appropriate percentage for the 30% present value low-income housing credit3.50% REV. RUL. 2001–49 TABLE 5 Rate Under Section 7520 for October 2001 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 interest5.60% October 9, 20013142001–41 I.R.B. 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 October 2001. See Rev. Rul. 2001–49, page 312. Section 3221.—Rate of Tax Determination of Quarterly Rate of Excise Tax for Railroad Retirement Supplemental Annuity Program In accordance with directions in section 3221(c) of the Railroad Retirement Tax Act (26 U.S.C., section 3221(c)), the Railroad Retirement Board has deter- mined that the excise tax imposed by such section 3221(c) on every employer, with respect to having individuals in his em- ploy, for each work-hour for which com- pensation is paid by such employer for services rendered to him during the quar- ter beginning October 1, 2001, shall be at the rate of 26 cents. In accordance with directions in section 15(a) of the Railroad Retirement Act of 1974, the Railroad Retirement Board has determined that for the quarter beginning October 1, 2001, 38.7 percent of the taxes collected under sections 3211(b) and 3221(c) of the Railroad Retirement Tax Act shall be credited to the Railroad Re- tirement Account and 61.3 percent of the taxes collected under such sections 3211(b) and 3221(c) plus 100 percent of the taxes collected under section 3221(d) of the Railroad Retirement Tax Act shall be credited to the Railroad Retirement Supplemental Account. Dated September 14, 2001. By Authority of the Board. Beatrice Ezerski, Secretary to the Board. (Filed by the Office of the Federal Register on Sep- tember 20, 2001, 8:45 a.m., and published in the issue of the Federal Register for September 21, 2001, 66 F.R. 48721) Section 7520.—Valuation Tables The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of October 2001. See Rev. Rul. 2001–49, page 312. 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 October 2001. See Rev. Rul. 2001–49, page 312. 2001–41 I.R.B.315October 9, 2001 Request for Comments on Regulations That May Be Adopted on Interest Allocation. Notice 2001–59 SECTION 1. PURPOSE This notice requests comments on whether the interest expense allocation and apportionment rules of §§1.861–9T, 1.861–10T, and 1.882–5 of the Income Tax Regulations should be modified to provide integrated treatment (such as net- ting of interest expense and income and/or assets and liabilities) of certain fi- nancial transactions. SECTION 2. THE INTEREST EXPENSE ALLOCATION RULES OF SECTIONS 864(e) AND 882(c)(1)(A) Section 864(e) requires taxpayers that are members of an affiliated group to allocate and apportion interest expense as if all members of such group are a single corpo- ration, and based on assets rather than gross income. The basic approach of the interest allocation rules is that because money is fungible, most borrowing contributes to the financing of all of an affiliated group’s ac- tivities and property. Thus, gross interest expense generally is allocated based on all the assets of an affiliated group, regardless of the specific purpose for any particular borrowing. See§1.861–9T(a). Section 882(c)(1)(A) provides that a foreign corporation engaged in a trade or business within the United States is allowed deductions in computing its tax liability under §11 only to the extent that the deductions are connected with the conduct of such trade or business. Sec- tion 882(c)(1)(A) further provides that the proper allocation and apportionment of deductions for this purpose shall be determined as provided in regulations prescribed by the Secretary. Pursuant to §1.882–5(a)(1)(i), foreign corporations must apply the interest expense alloca- tion rules of §1.882–5, rather than those of §1.861–9T, to determine the amount of interest expense that is deductible under §882(c)(1)(A). The interest allo- cation rules of §1.882–5, like the rules of §1.861–9T, allocate interest expense based on the value of assets. Although interest expense generally is allocated and apportioned based on all as- sets, §864(e)(7)(B) provides that the Sec- retary shall prescribe regulations as may be necessary and appropriate to carry out the purposes of such section, including regulations providing for the direct allo- cation of interest expense incurred to carry out an “integrated financial transac- tion” to any interest (or interest-type in- come) derived from such transaction. See alsoJoint Committee on Taxation, Gen- eral Explanation of the Tax Reform Act of 1986, 99th Cong., 2nd Sess. 948 (1987) (“In the case of an integrated financial transaction such as a debt-financed acqui- sition of foreign currency debt obligations or similar arbitrage transactions, the Act authorizes the Secretary to provide for the direct allocation of interest expense in- curred on funds borrowed to acquire these assets against income from the assets in- volved in the integrated transaction, if ap- propriate.”) Sections 1.861–10T(c) and 1.882–5(a)(1)(ii) provide for direct allo- cation of interest expense on a borrowing to income generated by an asset if certain conditions are met. The value of any asset to which interest expense is directly allocated under these rules then is reduced to take into account the principal amount of the indebtedness to which the directly allocated interest relates (for purposes of applying the general rules for the alloca- tion and apportionment of interest ex- pense not subject to the direct allocation rules). See§§1.861–10T(d)(2), 1.861 –9T(g)(2)(iii), and 1.882–5(a)(1) (ii)(A). These rules for integrated finan- cial transactions do not apply, however, to interest expense and indebtedness of a “fi- nancial services entity” as that term is de- fined in §1.904–4(e)(3). See§1.861 –10T(c)(2)(vi). SECTION 3. RELATED FINANCIAL INSTRUMENTS Treasury and the Service are consider- ing whether to provide, in certain cir- cumstances, for the direct allocation of interest expense to income and for ad- justments to the value of assets to reflect directly allocated liabilities. Such cir- cumstances may include situations in which a taxpayer holds financial instru- ments that, although formally separate, are economically closely related. One possible example is the case of a finan- cial institution that maintains a matched book of securities repurchase (repo) and reverse repurchase (reverse repo) trans- actions, which are treated as secured loans that give rise to interest expense (in a repo) and interest income (in a re- verse repo) for federal tax purposes. See, e.g., Rev. Rul. 74–27 (1974–1 C.B. 24). Similar issues may arise in the case of other financial instruments, including instruments that do not produce interest expense or interest-type income, but for which netting of the assets and the liabil- ities may be appropriate (e.g.notional principal contracts). SECTION 4. REQUEST FOR COMMENTS Comments are requested on whether §§1.861–9T, 1.861–10T, and 1.882–5 should be modified to apply integrated treatment (such as netting of interest ex- pense and income and/or assets and liabil- ities) to other financial transactions and, if so, the circumstances in which such inte- grated treatment should apply. In particu- lar, comments are requested on: (1) whether the rules for integrated financial transactions in §1.861–10T(c) should be made applicable to financial services enti- ties; (2) whether the definition of an inte- grated financial transaction should be ex- panded; (3) the criteria that should apply in determining whether financial transac- tions are sufficiently related to make inte- grated treatment appropriate; and (4) the administrative and record keeping re- quirements that may be appropriate. Comments also are requested regarding whether an integrated or similar approach for related financial transactions is appro- priate under other provisions of the Code. See, e.g., §1.1296–6(i) of the Proposed Income Tax Regulations. SECTION 5. SUBMISSION OF COMMENTS Taxpayers may submit comments to: CC:ITA:RU (OGI-130836-01), Room 5226, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be hand de- Part III. Administrative, Procedural, and Miscellaneous livered between the hours of 8 a.m. and 5 p.m. to CC:ITA:RU (OGI-130836-01), Courier’s Desk, Internal Revenue Ser- vice, 1111 Constitution Avenue NW, Washington, DC. Alternatively, taxpayers may submit comments electronically via the Internet by submitting comments di- rectly to the IRS Internet site at http://www.irs.gov/tax_regs/regslist.html. DRAFTING INFORMATION The principal author of this notice is Kenneth Christman of the Office of Asso- ciate Chief Counsel (International). However, other personnel from the IRS and Treasury Department participated in its development. For further information regarding this notice, contact Kenneth Christman at (202) 622-3870 (not a toll- free call). Disguised Sales of Partnership Interests—Request for Comments Notice 2001–64 The Internal Revenue Service and the Treasury Department are considering is- suing proposed regulations under § 707(a)(2)(B) of the Internal Revenue Code relating to disguised sales of part- nership interests. As part of this consider- ation, comments are being solicited con- cerning the scope and substance of this guidance. Effective April 24, 1991, the Service and Treasury issued final regulations adding new regulations § 1.707–0 and § 1.707–2 through § 1.707–9 to the In- come Tax Regulations (26 CFR part 1) under section 707(a)(2). These regula- tions apply to transfers described in § 707(a)(2)(A) and (B). Section 1.707–7 was reserved for rules on disguised sales of partnership interests. The legislative history of § 707(a)(2) indicates that the provision was adopted as a result of Congress’ concern that taxpay- ers were deferring or avoiding tax on sales of partnership property, including sales of partnership interests, by characterizing sales as contributions of property, includ- ing money, followed or preceded by a re- lated partnership distribution. See H.R. Rep. No. 861, 98th Cong., 2nd Sess. 861 (1984), 1984–3 (Vol. 2) C.B. 115. Specif- ically, Congress was concerned about court decisions that allowed tax-free treat- ment in cases that were economically in- distinguishable from sales of property to a partnership or another partner and be- lieved that these transactions should be treated for tax purposes in a manner con- sistent with their underlying economic substance. See H.R. Rep. No. 432, 98th Cong., 2nd Sess. 1218 (1984), and S. Prt. No. 169 (Vol. I), 98th Cong., 2nd Sess. 225 (1984) (discussing Communications Satellite Corp. v. United States, 625 F.2d 997 (Ct. Cl. 1980), and Jupiter Corp. v. United States, 2 Cl. Ct. 58 (1983), both of which involved the disguised sale of a partnership interest). Comments are requested on the scope and substance of guidance concerning disguised sales of partnership interests, including any applicable safe harbors or exceptions. Prior to the issuance of regu- lations, the determination of whether a transaction is a disguised sale of a part- nership interest under § 707(a)(2)(B) is to be made on the basis of the statute and its legislative history. Direct all written comments to Internal Revenue Service, Attn: CC:MSP:R (NT 2001–64), Room 5228, CC:PSI:01, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. In the alterna- tive, comments may be hand delivered between the hours of 8:00 a.m. and 5:00 p.m. to the courier’s desk at 1111 Consti- tution Avenue, NW, Washington, DC, or submitted electronically to: Notice.Com- ments@m1.irs.cousel.treas.gov.Please submit comments by March 31, 2002. All submissions will be open to public in- spection. The principal author of this notice is Carolyn Gray of the Office of the Associ- ate Chief Counsel (Passthroughs & Spe- cial Industries). For further information regarding this notice, contact Carolyn Gray at (202) 622-3050 (not a toll-free call). October 9, 20013162001–41 I.R.B. New Form 5306-A, Application for Approval of Prototype Simplified Employee Pension (SEP) or Savings Incentive Match Plan for Employees of Small Employers (SIMPLE IRA Plan) Announcement 2001–96 New Form 5306-A is now available for immediate use. The new form is to be used by sponsors of prototype simplified employee pensions (SEPs) and prototype SIMPLE IRA plans to apply for opinion letters on these documents. Form 5306-A replaces Form 5306-SEP, Application for Approval of Prototype Simplified Em- ployee Pension - SEP. The Service will continue to accept applications submitted using Form 5306-SEP until December 31, 2001. The Service will not issue opinion let- ters covering EGTRRA changes to SEPs and SIMPLE IRA plans until further no- tice. You can obtain Form 5306-A by tele- phone or by using IRS electronic informa- tion services. Request byNumber or address Telephone 1-800-TAX-FORM (1-800-829-3676) Personal computer: IRS Web Sitewww.irs.gov File transfer protocolftp.irs.gov Changes to the Requirements for Excise Tax Returns, Payments, and Deposits, Effective for Calendar Quarters Beginning After September 30, 2001 Announcement 2001–98 Purpose The IRS has issued final regulations on the requirements for excise tax returns, payments, and deposits, effective for cal- endar quarters beginning after September 30, 2001. This announcement is to advise taxpayers who file Form 720, Quarterly Federal Excise Tax Return, of the revised filing and deposit requirements. These changes will be reflected on the 4th quar- ter Form 720 and its instructions. Filing Dates All Forms 720 must be filed by the last day of the month following the quarter for which the return is made. The returns are due by April 30, July 31, October 31, and January 31. The one-month filing exten- sion that was allowed for returns relating to communications, air transportation, and ozone-depleting chemicals has been eliminated. Deposit Threshold No deposit is required for taxes listed in Part I of Form 720 if the net tax liabil- ity does not exceed $2,500 for the quarter. The threshold previously was $2,000. Deposit Dates One deposit rule applies for all taxes other than those deposited under the alter- native method. There are two methods under which deposits can be made: The regular method and the alternative method. The classes of tax, which were referred to as the 9-day rule, 14-day rule, and 30-day rule, have been eliminated. Under the regular method, deposits for a semimonthly period are due by the 14th day of the following semimonthly period. Generally, this is the 29th day of the month for the first semimonthly pe- riod and the 14th day of the following month for the second semimonthly pe- riod. If the 14th day is a Saturday, Sun- day, or legal holiday, the deposit is due the immediately precedingday that is not a Saturday, Sunday, or legal holiday. There is no change to deposit dates for taxes deposited under the alternative method. Amount To Deposit and Safe Harbor Rules In general, the deposit of tax for each semimonthly period must be at least 95% of the amount of net tax liability incurred during the semimonthly period. This re- places the requirement to deposit 100% of the net tax liability and the current liabil- ity safe harbor rule. The look-back quarter liability safe harbor rule still applies. Foundations Status of Certain Organizations Announcement 2001–100 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 follow- ing organizations (which have been treated as organizations that are not pri- vate foundations described in section 509(a) of the Code) are now classified as private foundations: 20th Century Unlimited, Santa Fe, NM ABM Sports, Inc., Austin, TX Academy of Restaurant Training, Inc., Bala Cynwyd, PA Acadian Centre Acadien, Inc., Abbeville, LA Acadiana Soccer Association, Inc., Opelousas, LA Access Information Fund, Inc., White Plains, NY Activecare, Inc., Moriarty, NM Adoption Information Foundation, Tulsa, OK African American Scholarship Foundation, New Orleans, LA African and African American Business Foundation, Gary, IN African and American Organization Corporation, Bronx, NY African Queens Community Foundation, Inc., Austin, TX Agape Community Health Services, Inc., Monroe, LA Albert H. and Constance Saunders Foundation, Silver Spring, MD Alliance for Medical Care, Great Falls, VA 2001–41 I.R.B.317October 9, 2001 Part IV. Items of General Interest American Boxer Rescue Association, Tulsa, OK American Computer Education, Inc., Lucas, OH Americas Theatre Group Corp., Coral Gables, FL Art & Understanding, Inc., Albany, NY Arts India Council, Baton Rouge, LA Augustus Straker Bar Foundation, Troy, MI Austin Great Wall Chinese School AGCS, Austin, TX Barron Foundation, Los Angeles, CA Bay Area Female Executives Association, Corpus Christi, TX Bella Vista Public Library Foundation, Bella Vista, AR BFL Foundation, Oceanside, CA Bienville Foundation, New Orleans, LA BioSafe Donor Registry, Inc., Lake Forest, IL Biscayne Bay Foundation, Inc., Coconut Grove, FL Boys & Girls Club of the Choctaw Nation, Inc., Talihina, OK Brother to Brother, Beaumont, TX Caribbean-American Educational Foundation, Del City, OK Caring Hands of Central Louisiana, Inc., Alexandria, LA Caring Strokes, Inc., Los Angeles, CA Carl Albert Foundation, Oklahoma City, OK Catholic Scholarship Fund, Inc., Kenner, LA CCCarts, Inc., Oklahoma City, OK Centex Club 12, Inc., Waco, TX Central Oklahoma Clinical Forensic Consultants, Inc., Oklahoma City, OK Centro Chicano, Inc., El Paso, TX Choctaws for Democracy, Inc., Antlers, OK Christ is Lord Child Care Food Program, Baton Rouge, LA Christian Family Development Association, Clinton, OK Citizens Programs Corporation, Boston, MA Claras Little Lambs Preschool Academy, Inc., New Orleans, LA Clark Trails Associations, Inc., Otisco, IN Claud Gill Arena Association, Duncan, OK Colorado Preservation Housing Corporation, Greeley, CO Comanche Cultural Compact, Inc., Apache, OK Community in Schools of Oklahoma, Inc., Shawnee, OK Community Visions Unlimited, New Orleans, LA Conservation Foundation for Polk County, Inc., West Des Moines, IA Crosslink, Inc., Bryan, TX Cuero New Generation Community Theatre, Cuero, TX Cypress Black Bayou Zoological Association Garden, Inc., Benton, LA Dawn, Inc., Baton Rouge, LA Deaf Culture Project, Cleveland, OH Decision Healthcare, Baton Rouge, LA Dolby Providers, Inc., New Orleans, LA Double Eagle Resources Development Corporation, El Paso, TX Downtown Jacksonville, Inc., Jacksonville, AR Drug-Free Wimberley, Inc., Wimberley, TX East Harlem Renewal Homes-Housing Development Fund Company, Inc., Hellgate Station, NY Eastwood Area Community Development Corporation, Houston, TX EcoTelesis International, Inc., Agoura Hills, CA El Paso Hispanic Chamber of Commerce Educational Development, El Paso, TX El Shaddai Enterprises, Los Angeles, CA End-Time Christian Evangelical Ministry, Bensalem, PA End Time Messengers, Inc., Adair, OK Endwar, Olympia, WA Environmental Education Institute, Inc., Tampa, FL Ernest Kelly Outreach, Inc., Midway, GA E.T.W. Ministries, Inc., Tulsa, OK Exodus 20, Pueblo, CO Expect a Miracle Foundation, Dana Point, CA Eye Light Publishing, Inc., Minneapolis, MN Faith Hope & Love Ministries, Inc., Norman, OK Faith Ministries, Inc., Baton Rouge, LA Family Life Community, Inc., Abbeville, LA Family Making, Pleasanton, CA Feather Awards, Inc., Mission Viejo, CA Feed-A-Child, Inc., New Orleans, LA Foresight Affordable Housing-Vineland, Inc., Rockville, MD Four Pines Care and Transitional Center, Inc., Houston, TX Free Spirit Community Development Corporation, New Orleans, LA Friends for Waialua Town, Waialua, HI Friends in Unity Social, Tulsa, OK Friends of the Shin Enkan, Inc., Bartlesville, OK Friends of Yerevan State University, Farmington Hills, MI Friendship Relief, Inc., San Antonio, TX Gabriel Assistance Ministries, Inc., Victoria, TX Gamma Rho International Educational Foundation, Inc., Tallahassee, FL Gateway Vocational and Restoration Center, Carson, CA Geary Avenue Homeless Mission, Inc., Oklahoma City, OK Geronimo Monument, Incorporated, Portal, AZ Global One, Casa Grande, AZ Gods Monument Bible Excursion World USA, Phillipsburg, NJ Gods News Publications, Channelview, TX Goldbeck Towers Good Samaritan Housing, Inc., Sioux Falls, SD Golden Rule Clothes Closet & More, Ft. Smith, AR Gonzales Independence Homes, Inc., San Antonio, TX Grass Roots Investments, Inc., New Orleans, LA Greater New Orleans Health Center, New Orleans, LA Greater Trinity Christian Learning Academy, Everett, WA Green Country Assistance Program, Inc., Porter, OK Gujarati Samaj of Oklahoma, Inc., Oklahoma City, OK Healthy Lifestyles, Inc., Shreveport, LA Heartland of America Fund, Inc., Oklahoma City, OK Heartland Sailing Foundation, Oklahoma City, OK Heartland Volunteers Recognition Association, Oklahoma City, OK Helping Hands in Hardin, Inc., Hardin, MT Helpline Soul Rescue Ministry, Inc., Baldwin, NY Highway Dog Animal Help, Inc., Riesel, TX Hunter’s Brotherhood Alumni Alumnae, Inc., New Orleans, LA In the Mighty Name of Jesus Christ Ministry, Cleveland, OH Incarcerated Hearts, Corpus Christi, TX Indo American Charities, Inc., Vidalia, GA October 9, 20013182001–41 I.R.B. Institute for Community Development, Inc., Silver Spring, MD Institute for Inner Peace, Maryville, IL Institute for Substainable Power, Inc., Highlands Ranch, CO Interagency Commission for Youth, Inc., Pine Bluff, AR Interfaith Volunteer Caregivers of Southwest Louisiana, Inc., Lake Charles, LA International Aviation Ministry, Inc., Tulsa, OK International Film Fund, Broken Arrow, OK Iranian Cultural Community of Austin, Inc., Austin, TX Jacksonville Chamber Foundation, Inc., Little Rock, AR James H. Young Foundation for the Support of Experimental Therapies, Harahan, LA Kansas Little League, Incorporated, Kansas, OK Kenner Club, Inc., Kenner, LA Kent House, Inc., New Orleans, LA Lafayette Youth Organization, Lafayette, LA LHM, Inc., Shreveport, LA McCurtain County Bar Association Scholarship Fund, Inc., Idabel, OK Mother Goose Day Care, Inc., Natchez, MS Muscle Music, Inc., Austin, TX Nana Kwadwo Adu II Foundation for Ghana, New Orleans, LA National Guard Association of OK Scholarship Foundation, Inc., Oklahoma City, OK New Life Mens Ministries, Inc., Broken Arrow, OK New Mummers Repertory, Inc., Oklahoma City, OK New Orleans Area Literacy Coalition, Inc., New Orleans, LA New Orleans Center for Living, Inc., New Orleans, LA New Orleans Sister Cities, Inc., Mandeville, LA New Year Coalition, New Orleans, LA Nigerian Union Tulsa, Incorporated, Tulsa, OK Oklahoma Center for Grief and Loss and Life Transition, Inc., Oklahoma City, OK Oklahoma Code Enforcement Association, Del City, OK Oklahoma Emergency Medical Technicians Association Foundation, Tulsa, OK Oklahoma Oil & Gas Museum, Inc., Yukon, OK Oklahoma Railway Heritage Association, Inc., Oklahoma City, OK Old Sallisaw High School Association, Sallisaw, OK Ouachita Valley Heritage Museum and Society, W. Monroe, LA Pioneer Technology Center Foundation, Inc., Ponca City, OK Project Mobilization International, Inc., Bixby, OK Rae Valley School, Burton, TX Randolph Drug Abuse Resistance Education, Randolph AFB, TX Rauch, Inc., New Orleans, LA Real Life Ministries, San Antonio, TX Recycled Computers for Kids, Inc., Baton Rouge, LA Riviera Volunteer Fire Dept., Inc., Riviera, TX Roots and Wings Foundation, Oklahoma City, OK Saving Kids Unlimited, Inc., New Orleans, LA Seekers of Wisdom, Inc., Oklahoma City, OK Slidell Liver Support Group, Inc., Slidell, LA South Side Community Improvement Association, Inc., Monroe, LA Southern Providers, Inc., Harvey, LA Southside Restoration, Inc., Jennings, LA Southwestern Louisiana Homeless Coalition, Inc., Lake Charles, LA Sports Club of Jennings, Jennings, LA SSAFE Foundation, Shawnee, OK St. Bernard Community Outreach, Violet, LA St. Martin Deporres Ministry for the Poor, New Orleans, LA Star Medical Transportation, Inc., Athens, LA Sue Eakin Institute for the Study of Plantation Life, Inc., Palmetto, LA Suno School of Social Work Graduate Alumni, Inc., New Orleans, LA Taking Action, Incorporated, Austin, TX Teen Town Council, Inc., Vinita, OK Temple of Truth of the Gospel of Jesus Christ of the Apostolic Faith, Inc., Broken Arrow, OK Thrift Town, Llano, TX Tots Day Care and Preschool, Inc., New Orleans, LA Treme Historical Development Corporation, New Orleans, LA Tulsa Area Aquatic Alliance, Inc., Tulsa, OK Tulsa Senior Citizens Center for the Deaf, Inc., Tulsa, OK Vacherie Youth Organization, Vacherie, LA Virginia Miniex Memorial Scholarship Fund, Lafayette, LA Vision Evangelism, Inc., Tulsa, OK Wagoner Band Booster Club, Wagoner, OK Webb Alliance, Inc., San Antonio, TX Webbers Falls Historical Society Museum, Webbers Falls, OK WINGS Youth Outreach, Mission, TX Working Womens Money University, Oklahoma City, OK Youth Haven, Inc., Laredo, TX Zion Hill Development Education Center, Grambling, LA Zion Human Resources and Development Corporation, New Orleans, LA Zion Travelers Baptist Church Outreach Ministries, Inc., Reserve, LA If an organization listed above sub- mits information that warrants the re- newal of its classification as a public charity or as a private operating founda- tion, the Internal Revenue Service will issue a ruling or determination letter with the revised classification as to foundation status. Grantors and contrib- utors may thereafter rely upon such rul- ing or determination letter as provided in section 1.509(a)–7 of the Income Tax Regulations. It is not the practice of the Service to announce such revised classi- fication of foundation status in the Inter- nal Revenue Bulletin. 2001–41 I.R.B.319October 9, 2001 October 9, 2001i2001–41 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 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 Contributions Act. FISC—Foreign International Sales Company. FPH—Foreign Personal Holding Company. F.R.—Federal Register. FUTA—Federal Unemployment Tax Act. FX—Foreign Corporation. G.C.M.—Chief Counsel’s Memorandum. GE—Grantee. GP—General Partner. GR—Grantor. IC—Insurance Company. I.R.B.—Internal Revenue Bulletin. LE—Lessee. LP—Limited Partner. LR—Lessor. M—Minor. Nonacq.—Nonacquiescence. O—Organization. P—Parent Corporation. PHC—Personal Holding Company. PO—Possession of the U.S. PR—Partner. PRS—Partnership. PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Real Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul.—Revenue Ruling. S—Subsidiary. S.P.R.—Statements of Procedural Rules. Stat.—Statutes at Large. T—Target Corporation. T.C.—Tax Court. T.D.—Treasury Decision. TFE—Transferee. TFR—Transferor. T.I.R.—Technical Information Release. TP—Taxpayer. TR—Trust. TT—Trustee. U.S.C.—United States Code. X—Corporation. Y—Corporation. Z—Corporation. Definition of Terms 2001–41 I.R.B.iiOctober 9, 2001 Numerical Finding List 1 Bulletins 2001–27 through 2001–40 Announcements: 2001–69, 2001–27 I.R.B. 23 2001–70, 2001–27 I.R.B. 23 2001–71, 2001–27 I.R.B. 26 2001–72, 2001–28 I.R.B. 39 2001–73, 2001–28 I.R.B. 40 2001–74, 2001–28 I.R.B. 40 2001–75, 2001–28 I.R.B. 42 2001–76, 2001–29 I.R.B. 67 2001–77, 2001–30 I.R.B. 83 2001–78, 2001–30 I.R.B. 87 2001–79, 2001–31 I.R.B. 97 2001–80, 2001–31 I.R.B. 98 2001–81, 2001–33 I.R.B. 175 2001–82, 2001–32 I.R.B. 123 2001–83, 2001–35 I.R.B. 205 2001–84, 2001–35 I.R.B. 206 2001–85, 2001–36 I.R.B. 219 2001–86, 2001–35 I.R.B. 207 2001–87, 2001–35 I.R.B. 208 2001–88, 2001–36 I.R.B. 220 2001–89, 2001–38 I.R.B. 291 2001–90, 2001–35 I.R.B. 208 2001–91, 2001–36 I.R.B. 221 2001–92, 2001–39 I.R.B. 301 2001–94, 2001–39 I.R.B. 303 2001–95, 2001–39 I.R.B. 303 2001–97, 2001–40 I.R.B. 310 Court Decisions: 2070, 2001–31 I.R.B. 90 Notices: 2001–39, 2001–27 I.R.B. 3 2001–41, 2001–27 I.R.B. 2 2001–42, 2001–30 I.R.B. 70 2001–43, 2001–30 I.R.B. 72 2001–44, 2001–30 I.R.B. 77 2001–45, 2001–33 I.R.B. 129 2001–46, 2001–32 I.R.B. 122 2001–47, 2001–36 I.R.B. 212 2001–48, 2001–33 I.R.B. 130 2001–49, 2001–34 I.R.B. 188 2001–50, 2001–34 I.R.B. 189 2001–51, 2001–34 I.R.B. 190 2001–52, 2001–35 I.R.B. 203 2001–53, 2001–37 I.R.B. 225 2001–54, 2001–37 I.R.B. 225 2001–55, 2001–39 I.R.B. 299 2001–56, 2001–38 I.R.B. 277 2001–57, 2001–38 I.R.B. 279 2001–58, 2001–39 I.R.B. 299 2001–60, 2001–40 I.R.B. 304 2001–61, 2001–40 I.R.B. 305 2001–62, 2001–40 I.R.B. 307 2001–63, 2001–40 I.R.B. 308 Proposed Regulations: REG–110311–98, 2001–35 I.R.B. 204 REG–106917–99, 2001–27 I.R.B. 4 REG–103735–00, 2001–35 I.R.B. 204 REG–103736–00, 2001–35 I.R.B. 204 REG–100548–01, 2001–29 I.R.B. 67 REG–106431–01, 2001–37 I.R.B. 272 Railroad Retirement Quarterly Rates: 2001–27, I.R.B. 1 Revenue Procedures: 2001–39, 2001–28 I.R.B. 38 2001–40, 2001–33 I.R.B. 130 2001–41, 2001–33 I.R.B. 173 2001–42, 2001–36 I.R.B. 212 2001–43, 2001–34 I.R.B. 191 2001–44, 2001–35 I.R.B. 203 2001–45, 2001–37 I.R.B. 227 2001–46, 2001–37 I.R.B. 263 2001–48, 2001–40 I.R.B. 308 2001–49, 2001–39 I.R.B. 300 Revenue Rulings: 2001–30, 2001–29 I.R.B. 46 2001–33, 2001–32 I.R.B. 118 2001–34, 2001–28 I.R.B. 31 2001–35, 2001–29 I.R.B. 59 2001–36, 2001–32 I.R.B. 119 2001–37, 2001–32 I.R.B. 100 2001–38, 2001–33 I.R.B. 124 2001–39, 2001–33 I.R.B. 125 2001–40, 2001–38 I.R.B. 276 2001–41, 2001–35 I.R.B. 193 2001–42, 2001–37 I.R.B. 223 2001–43, 2001–36 I.R.B. 209 2001–44, 2001–37 I.R.B. 223 2001–47, 2001–39 I.R.B. 293 Treasury Decisions: 8947, 2001–28 I.R.B. 36 8948, 2001–28 I.R.B. 27 8949, 2001–28 I.R.B. 33 8950, 2001–28 I.R.B. 34 8951, 2001–29 I.R.B. 63 8952, 2001–29 I.R.B. 60 8953, 2001–29 I.R.B. 44 8954, 2001–29 I.R.B. 47 8955, 2001–32 I.R.B. 101 8956, 2001–32 I.R.B. 112 8957, 2001–33 I.R.B. 125 8958, 2001–34 I.R.B. 183 8959, 2001–34 I.R.B. 185 8960, 2001–34 I.R.B. 176 8961, 2001–35 I.R.B. 194 8962, 2001–35 I.R.B. 201 8963, 2001–35 I.R.B. 197 1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2001–1 through 2001–26 is in Internal Revenue Bulletin 2001–27, dated July 2, 2001. October 9, 2001iii2001–41 I.R.B. Finding List of Current Actions on Previously Published Items 1 Bulletins 2001–27 through 2001–40 Announcements: 2000–48 Modified by Notice 2001–43, 2001–30 I.R.B. 72 Notices: 98–52 Modified by Notice 2001–56, 2001–38 I.R.B. 277 99–41 Modified and superseded by Notice 2001–62, 2001–40 I.R.B. 307 2001–4 Modified by Notice 2001–43, 2001–30 I.R.B. 72 2001–9 Modified by Notice 2001–46, 2001–32 I.R.B. 122 2001–15 Supplemented by Notice 2001–51, 2001–34 I.R.B. 190 2001–42 Modified by Notice 2001–57, 2001–38 I.R.B. 279 Proposed Regulations: LR–97–79 Withdrawn by REG–100548–01, 2001–29 I.R.B. 67 LR–107–84 Withdrawn by REG–100548–01, 2001–29 I.R.B. 67 REG–110311–98 Supplemented by T.D. 8961, 2001–35 I.R.B. 194 REG–106917–99 Corrected by Ann. 2001–86, 2001–35 I.R.B. 207 REG–103735–00 Supplemented by T.D. 8961, 2001–35 I.R.B. 194 REG–103736–00 Supplemented by T.D. 8961, 2001–35 I.R.B. 194 REG–107186–00 Corrected by Ann. 2001–71, 2001–27 I.R.B. 26 REG–130477–00 Supplemented by Ann. 2001–82, 2001–32 I.R.B. 123 REG–130481–00 Supplemented by Ann. 2001–82, 2001–32 I.R.B. 123 Revenue Procedures: 83–74 Revoked by Rev. Proc. 2001–49, 2001–39 I.R.B. 300 Revenue Procedures—Continued: 84–84 Revoked by Rev. Proc. 2001–49, 2001–39 I.R.B. 300 93–27 Clarified by Rev. Proc. 2001–43, 2001–34 I.R.B. 191 97–13 Modified by Rev. Proc. 2001–39, 2001–28 I.R.B. 38 97–19 Modified by Notice 2001–62, 2001–40 I.R.B. 307 98–44 Superseded by Rev. Proc. 2001–40, 2001–33 I.R.B. 130 99–27 Superseded by Rev. Proc. 2001–42, 2001–36 I.R.B. 212 99–49 Modified and amplified by Rev. Proc. 2001–46, 2001–37 I.R.B. 263 2000–20 Modified by Notice 2001–42, 2001–30 I.R.B. 70 2000–39 Corrected by Ann. 2001–73, 2001–28 I.R.B. 40 2001–2 Modified by Rev. Proc. 2001–41, 2001–33 I.R.B. 173 2001–6 Modified by Notice 2001–42, 2001–30 I.R.B. 70 Revenue Rulings: 57–589 Obsoleted by REG–106917–99, 2001–27 I.R.B. 4 65–316 Obsoleted by REG–106917–99, 2001–27 I.R.B. 4 68–125 Obsoleted by REG–106917–99, 2001–27 I.R.B. 4 69–563 Obsoleted by REG–106917–99, 2001–27 I.R.B. 4 70–379 Obsoleted by Rev. Rul. 2001–39, 2001–33 I.R.B. 125 74–326 Obsoleted by REG–106917–99, 2001–27 I.R.B. 4 78–127 Modified by Rev. Rul. 2001–40, 2001–38 I.R.B. 276 78–179 Obsoleted by REG–106917–99, 2001–27 I.R.B. 4 Revenue Rulings—Continued: 92–19 Supplemented by Rev. Rul. 2001–38, 2001–33 I.R.B. 124 Treasury Decisions: 8948 Corrected by Ann. 2001–90, 2001–35 I.R.B. 208 1 A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2001–1 through 2001–26 is in Internal Revenue Bulletin 2001–27, dated July 2, 2001. INTERNAL REVENUE BULLETIN The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue Bulletin is sold on a yearly subscription basis by the Superintendent of Documents. Current subscribers are notified by the Superintendent of Documents when their subscriptions must be renewed. CUMULATIVE BULLETINS The contents of this weekly Bulletin are consolidated semiannually into a permanent, indexed, Cumulative Bulletin. These are sold on a single copy basis and are not included as part of the subscription to the Internal Revenue Bulletin. Subscribers to the weekly Bulletin are notified when copies of the Cumulative Bulletin are available. Certain issues of Cumulative Bulletins are out of print and are not available. Persons desiring available Cumulative Bulletins, which are listed on the reverse, may purchase them from the Superintendent of Documents. ACCESS THE INTERNAL REVENUE BULLETIN ON THE INTERNET You may view the Internal Revenue Bulletin on the Internet at www.irs.gov. Select Tax Info for Business at the bottom of the page. Then select Internal Revenue Bulletins. INTERNAL REVENUE BULLETINS ON CD–ROM Internal Revenue Bulletins are available annually as part of Publication 1796 (Tax Products CD–ROM). The CD–ROM can be purchased from National Technical Information Service (NTIS) on the Internet at www.irs.gov/cdorders(discount for online orders) or by calling 1-877-233-6767. The first release is available in mid-December and the final release is available in late January. HOW TO ORDER Check the publications and/or subscription(s) desired on the reverse, complete the order blank, enclose the proper remittance, detach entire page, and mail to the Superintendent of Documents, P.O. Box 371954, Pittsburgh, PA 15250–7954. Please allow two to six weeks, plus mailing time, for delivery. WE WELCOME COMMENTS ABOUT THE INTERNAL REVENUE BULLETIN If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we would be pleased to hear from you. You can e-mail us your suggestions or comments through the IRS Internet Home Page (www.irs.gov) or write to the IRS Bulletin Unit, W:CAR:MP:FP, Washington, DC 20224. Internal Revenue Service Washington, DC 20224 Official Business Penalty for Private Use, $300
Poursuivez vos recherches dans ChatGPT ou Claude
Connectez Omnilex pour rechercher dans le corpus juridique depuis votre assistant IA.