Internal Revenue Bulletin 1996-9 (PDF rendition): IRS Revenue Rulings

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Bulletin No. 1996–9
February 26, 1996
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
INCOME TAX
Rev. Rul. 96–12, page 4.
LIFO; price indexes; department stores. The December
1995 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, December 31, 1995.
T.D. 8647, page 7.
Final regulations under section 1445 of the Code
relating to withholding upon certain distributions or
dispositions of U.S. real property interests.
T.D. 8649, page 5.
Final regulations under section 1258 of the Code
relating to conversion transactions.
EMPLOYEE PLANS
Rev. Proc. 96–8A, page 10.
User fees. Corrections are made to Rev. Proc. 96–8,
1996–1 I.R.B. 187, concerning user fees.
ADMINISTRATIVE
Announcement 96–11, page 11.
Supplemental information on Treasury bills for Publica-
tion 1212, List of Original Issue Discount Instruments
(Rev. Nov. 95), is given.
Finding Lists begin on page 15.
Announcement of Disbarments and Suspensions begin on page 12.

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Mission of the Service
The purpose of the Internal Revenue Service is to
collect the proper amount of tax revenue at the least
cost; serve the public by continually improving the
quality of our products and services; and perform in a
manner warranting the highest degree of public
confidence in our integrity, efficiency and fairness.
Statement of Principles
of Internal Revenue
Tax Administration
The function of the Internal Revenue Service is to
administer the Internal Revenue Code. Tax policy
for raising revenue is determined by Congress.
With this in mind, it is the duty of the Service to
carry out that policy by correctly applying the laws
enacted by Congress; to determine the reasonable
meaning of various Code provisions in light of the
Congressional purpose in enacting them; and to
perform this work in a fair and impartial manner,
with neither a government nor a taxpayer point of
view.
At the heart of administration is interpretation of the
Code. It is the responsibility of each person in the
Service, charged with the duty of interpreting the
law, to try to find the true meaning of the statutory
provision and not to adopt a strained construction in
the belief that he or she is ‘‘protecting the revenue.’’
The revenue is properly protected only when we as-
certain and apply the true meaning of the statute.
The Service also has the responsibility of applying
and administering the law in a reasonable,
practical manner. Issues should only be raised by
examining officers when they have merit, never
arbitrarily or for trading purposes. At the same
time, the examining officer should never hesitate
to raise a meritorious issue. It is also important
that care be exercised not to raise an issue or to
ask a court to adopt a position inconsistent with
an established Service position.
Administration should be both reasonable and
vigorous. It should be conducted with as little
delay as possible and with great courtesy and
considerateness. It should never try to overreach,
and should be reasonable within the bounds of law
and sound administration. It should, however, be
vigorous in requiring compliance with law and it
should be relentless in its attack on unreal tax
devices and fraud.

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Introduction
The Internal Revenue Bulletin is the authoritative
instrument of the Commissioner of Internal Revenue for
announcing official rulings and procedures of the
Internal Revenue Service and for publishing Treasury
Decisions, Executive Orders, Tax Conventions, legisla-
tion, court decisions, and other items of general
interest. It is published weekly and may be obtained
from the Superintendent of Documents on a subscrip-
tion basis. Bulletin contents of a permanent nature 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 substantive 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 otherwise indicated.
Procedures relating solely to matters of internal
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 published rulings and proce-
dures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be
considered, and Service personnel and others con-
cerned are cautioned against reaching the same
conclusions in other cases unless the facts and
circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on
provisions of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows:
Subpart A, Tax Conventions, and Subpart B, Legislation
and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellanous.
To the extent practicable, pertinent cross references to
these subjects are contained in the other Parts and
Subparts. Also included in this part are Bank Secrecy
Act Administrative Rulings. Bank Secrecy Act Admin-
istrative Rulings are issued by the Department of the
Treasury’s Office of the Assistant Secretary
(Enforcement).
Part IV.—Items of General Interest.
With the exception of the Notice of Proposed Rulemak-
ing and the disbarment and suspension list included in
this part, none of these announcements are consoli-
dated in the Cumulative Bulletins.
The first Bulletin for each month includes an index for
the matters published during the preceding month.
These monthly indexes are cumulated on a quarterly
and semiannual basis, and are published in the first
Bulletin of the succeeding quarterly and semi-annual
period, respectively.
The Bulletin Index-Digest System, a research and
reference service supplementing the Bulletin, may be
obtained from the Superintendent of Documents on a
subscription basis. It consists of four Services: Service
No. 1, Income Tax; Service No. 2, Estate and Gift
Taxes; Service No. 3, Employment Taxes; Service No.
4, Excise Taxes. Each Service consists of a basic
volume and a cumulative supplement that provides (1)
finding lists of items published in the Bulletin, (2)
digests of revenue rulings, revenue procedures, and
other published items, and (3) indexes of Public Laws,
Treasury Decisions, and Tax Conventions.
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, D.C. 20402.

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Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
§ 472.—Last-in, First-out Inventories
26 CFR 1.472–1: Last-in, first-out inventories.
LIFO; price indexes; department
stores. The December 1995 Bureau of
Labor Statistics price indexes are ac-
cepted 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, December 31,
1995.
Rev. Rul. 96–12
The following Department Store In-
ventory Price Indexes for December
1995 were issued by the Bureau of
Labor Statistics on February 1, 1996.
The indexes are accepted by the
Internal Revenue Service, under
§ 1.472–1(k) of the Income Tax Reg-
ulations and Rev. Proc. 86–46, 1986–2
C.B. 739, for appropriate application to
inventories of department stores
employing the retail inventory and last-
in, first-out inventory methods for tax
years ended on, or with reference to,
December 31, 1995.
The Department Store Inventory
Price Indexes are prepared on a na-
tional basis and include (a) 23 major
groups of departments, (b) three special
combinations of the major groups—soft
goods, durable goods, and misce-
llaneous goods, and (c) a store total,
which covers all departments, including
some not listed separately, except for
the following: candy, foods, liquor,
tobacco, and contract departments.
BUREAU OF LABOR STATISTICS, DEPARTMENT STORE
INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS
(January 1941 = 100, unless otherwise noted)
GroupsDec. 1994Dec. 1995
Percent Change from
Dec. 1994 to Dec. 1995
1
1. Piece Goods...........................483.5532.610.2
2. Domestics and Draperies................630.5633.50.5
3. Women’s and Children’s Shoes..........630.9625.6–0.8
4. Men’s Shoes..........................907.3891.0–1.8
5. Infants’ Wear..........................620.9635.62.4
6. Women’s Underwear...................521.9521.6–0.1
7. Women’s Hosiery......................280.4290.23.5
8. Women’s and Girls’ Accessories.........560.6559.9–0.1
9. Women’s Outerwear and Girls’ Wear.....413.9407.1–1.6
10. Men’s Clothing........................603.0602.1–0.1
11. Men’s Furnishings......................558.6561.60.5
12. Boys’ Clothing and Furnishings..........472.4481.82.0
13. Jewelry...............................979.4978.1–0.1
14. Notions...............................720.8773.67.3
15. Toilet Articles and Drugs...............854.2870.81.9
16. Furniture and Bedding..................637.3669.05.0
17. Floor Coverings........................564.2564.50.1
18. Housewares...........................776.3782.30.8
19. Major Appliances......................249.4246.1–1.3
20. Radio and Television...................83.979.1–5.7
21. Recreation and Education
2
..............114.5112.8–1.5
22. Home Improvements
2
...................122.0123.71.4
23. Auto Accessories
2
......................106.6107.50.8
Groups 1–15: Soft Goods...................584.4585.10.1
Groups 16–20: Durable Goods..............463.4462.2–0.3
Groups 21–23: Misc. Goods
2
................114.1113.3–0.7
Store Total
3
.........................544.0543.7–0.1
1
Absence of a minus sign before percentage change in this column signifies 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, foods, liquor, tobacco, and contract
departments.

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DRAFTING INFORMATION
The principal author of this revenue
ruling is Stan Michaels of the Office of
Assistant Chief Counsel (Income Tax
and Accounting). For further informa-
tion regarding this revenue ruling,
contact Mr. Michaels on (202)
622-4970 (not a toll-free call).
Section 1258.—Recharacterization of
Gain from Certain Financial
Transactions
26 CFR 1.1258–1: Netting rule for certain
conversion transactions.
T.D. 8649
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Parts 1 and 602
Regulations Under Section 1258 of
the Internal Revenue Code of 1986;
Netting Rule For Certain Conversion
Transactions
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations.
SUMMARY: This document contains
final regulations relating to conversion
transactions. These regulations provide
that certain gains and losses from
positions of the same conversion trans-
action may be netted for purposes of
determining the amount of gain that is
recharacterized as ordinary income.
These regulations reflect changes to the
law made by the Revenue Reconcilia-
tion Act of 1993 and affect persons
who enter into conversion transactions.
DATE: These regulations are effective
December 21, 1995.
For applicability of these regulations,
see EFFECTIVE DATES under the
SUPPLEMENTARY INFORMATION
part of the preamble.
FOR FURTHER INFORMATION
CONTACT: Alan B. Munro, (202)
622-3950 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Paperwork Reduction Act
The collection of information con-
tained in these final regulations has
been reviewed and approved by the
Office of Management and Budget in
accordance with the Paperwork Reduc-
tion Act (44 U.S.C. 3507) under
control number 1545–1452. Responses
to this collection of information are
required to obtain netting relief for
conversion transactions.
An agency may not conduct or
sponsor, and a person is not required to
respond to, a collection of information
unless the collection of information
displays a valid control number.
The estimated annual burden per
recordkeeper varies from .05 to 10
hours, depending on individual circum-
stances, with an estimated average of
.10 hour.
Comments concerning the accuracy
of this burden estimate and suggestions
for reducing this burden should be sent
to the Internal Revenue Service, Attn:
IRS Reports Clearance Officer, T:FP,
Washington, DC 20224, and to the
Office of Management and Budget,
Attn: Desk Officer for the Department
of the Treasury, Office of Information
and Regulatory Affairs, Washington,
DC 20503.
Books or records relating to this
collection of information must be re-
tained as long as their contents may
become material in the administration
of any internal revenue law. Generally,
tax returns and tax return information
are confidential, as required by 26
U.S.C. 6103.
Background
On December 27, 1994, the IRS
published in the Federal Register a
notice of proposed rulemaking and
notice of public hearing at 59 FR
66498 (FI–43–94 [1995–1 C.B. 932])
under section 1258 of the Internal
Revenue Code of 1986.
The IRS received a number of
written comments on the proposed
regulations. No requests to speak at the
public hearing were received, however,
and consequently the hearing was
cancelled.
Explanation of Provisions
A.General
The proposed regulations allow tax-
payers to net gains and losses on the
positions of certain conversion transac-
tions for purposes of section 1258(a).
For a taxpayer to be eligible, the
proposed regulations require the tax-
payer to identify, before the close of
the day on which the positions become
part of the conversion transaction, all
the positions that are part of the
conversion transaction. In addition, the
taxpayer has to dispose of all the
positions within a 14-day period that is
within a single taxable year. The
proposed regulations also define built-
in loss and prohibit the netting of built-
in loss against gain.
The commenters uniformly supported
the netting relief provided by the
proposed regulations. Accordingly, the
final regulations are substantially un-
changed from the proposed regulations.
The proposed regulations provide
that the regulations will be effective for
conversion transactions entered into on
or after the date of filing of final
regulations with the Federal Register.
Several commenters requested that the
regulations also apply to conversion
transactions entered into prior to the
filing date. In response to these com-
ments, the final regulations provide for
application of the regulations to any
conversion transaction that is outstand-
ing on December 21, 1995, provided
that all the positions which are part of
the conversion transaction are identified
under §1.1258–1(b)(2) before the close
of business on February 20, 1996. The
final regulations also provide a transi-
tion rule for the same-day identification
requirement that allows taxpayers to
identify conversion transactions entered
into prior to February 20, 1996, at any
time on or before February 20, 1996.
Several commenters criticized the
examples for failing to adjust the
applicable imputed income amount
(AIIA) under section 1258(b) for inter-
est and dividends received. The scope
of these regulations, however, is lim-
ited to netting relief. The IRS is still
studying various situations to determine
the extent to which it is appropriate to
reduce the AIIA by reason of amounts
capitalized under section 263(g), ordi-
nary income received, or otherwise.
Accordingly, Example 3 has been de-
leted and Examples 1 and 2 have been
clarified to eliminate any implication
on this issue.
One commenter requested that the
identification requirement be eliminated
as impractical, unnecessary, and a trap
for the unwary. This same-day identi-
fication requirement is similar to identi-
fication requirements under sections
475 and 1221. Identification of all the

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positions of a conversion transaction
will aid examiners attempting to deter-
mine whether conversion transactions
are present and will prevent mismatch-
ing of those positions by both tax-
payers and agents. The final regulations
retain the same-day identification re-
quirement but provide a transition rule.
Some commenters asked that netting
relief be expanded to cover unrealized
losses in retained positions by allowing
loss positions to be marked to market
when a gain position is disposed of or
terminated. Allowing retained positions
to be marked to market raises valuation
and other potentially complex issues.
For example, many of the issues ad-
dressed by the regulations under sec-
tion 475 would have to be addressed
here. The complexity of these issues
outweighs the potential benefit of al-
lowing retained positions to be marked
to market. Thus, the final regulations
do not include a mark-to-market
provision.
To preserve the character of gain that
arose before a position became part of
a conversion transaction, one commen-
ter requested built-in gain rules similar
to the built-in loss rules in the pro-
posed regulations. The appropriateness
of a built-in gain rule under section
1258 is beyond the scope of these
regulations. Therefore, the final regula-
tions do not address this issue.
The IRS is aware that section 1258
presents a number of issues not ad-
dressed by these final regulations. The
IRS continues to study the scope of
section 1258, the types of transactions
that should be included under the
r e g u l a t o r y a u t h o r i t y o f s e c t i o n
1258(c)(2)(D), and what reductions, if
any, in the AIIA are appropriate under
section 1258(b). The IRS welcomes
comments on these and other issues
under section 1258.
B.Effective Dates
The regulations are effective for
conversion transactions that are out-
standing on or after December 21,
1995. In the case of a conversion
transaction entered into before February
20, 1996, the same-day identification
requirement is treated as satisfied if the
identification is made on or before
February 20, 1996.
Special Analyses
It has been determined that this
Treasury decision is not a significant
regulatory action as defined in EO
12866. Therefore, a regulatory assess-
ment is not required. It also has been
determined that section 553(b) of the
Administrative Procedure Act (5 U.S.C.
chapter 5) and the Regulatory Flex-
ibility Act (5 U.S.C. chapter 6) do not
apply to these regulations, and, there-
fore, a Regulatory Flexibility Analysis
is not required. Pursuant to section
7805(f) of the Internal Revenue Code,
the notice of proposed rulemaking pre-
ceding these regulations was submitted
to the Small Business Administration
for comment on its impact on small
business.
Drafting Information
The principal author of these regula-
tions is Alan B. Munro, Office of
Assistant Chief Counsel (Financial In-
stitutions and Products). However,
other personnel from the IRS and
Treasury Department participated in
their development.
******
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR parts 1 and
602 are amended as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation
for part 1 continues to read in part as
follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 1.1258–1 is added to
read as follows:
§1.1258–1 Netting rule for certain
conversion transactions.
(a)Purpose. The purpose of this
section is to provide taxpayers with a
method to net certain gains and losses
from positions of the same conversion
transaction before determining the
amount of gain treated as ordinary
income under section 1258(a).
(b)Netting of gain and loss for
identified transactions—(1) In general.
If a taxpayer disposes of or terminates
all the positions of an identified netting
transaction (as defined in paragraph
(b)(2) of this section) within a 14-day
period in a single taxable year, all
gains and losses on those positions
taken into account for federal tax
purposes within that period (other than
built-in losses as defined in paragraph
(c) of this section) are netted solely for
purposes of determining the amount of
gain treated as ordinary income under
section 1258(a). For purposes of the
preceding sentence, a taxpayer is
treated as disposing of any position that
is treated as sold under any provision
of the Code or regulations thereunder
(for example, under section 1256(a)-
(1)).
(2)Identified netting transaction.
For purposes of this section, an identi-
fied netting transaction is a conversion
transaction (as defined in section
1258(c)) that the taxpayer identifies as
an identified netting transaction on its
books and records. Identification of
each position of the conversion transac-
tion must be made before the close of
the day on which the position becomes
part of the conversion transaction. No
particular form of identification is
necessary, but all the positions of a
single conversion transaction must be
identified as part of the same transac-
tion and must be distinguished from all
other positions.
(c)Definition of built-in loss. For
purposes of this section, built-in loss
means—
(1)Built-in loss as defined in sec-
tion 1258(d)(3)(B); and
(2)If a taxpayer realizes gain or loss
on any one position of a conversion
transaction (for example, under section
1256), as of the date that gain or loss is
realized, any unrecognized loss in any
other position of the conversion trans-
action that is not disposed of, termi-
nated, or treated as sold under any
provision of the Code or regulations
thereunder within 14 days of and
within the same taxable year as the
realization event.
(d)Examples. These examples illus-
trate this section:
Example 1. Identified netting transaction with
simultaneous actual dispositions. (i) On Decem-
ber 1, 1995, A purchases 1,000 shares of XYZ
stock for $100,000 and enters into a forward
contract to sell 1,000 shares of XYZ stock on
November 30, 1997, for $110,000. The XYZ
stock is actively traded as defined in §1.1092(d)–
1(a) and is a capital asset in A’s hands. A
maintains books and records on which, on
December 1, 1995, it identifies the two positions
as all the positions of a single conversion
transaction. A owns no other XYZ stock. On
December 1, 1996, when the applicable imputed
income amount for the transaction is $7,000, A
sells the 1,000 shares of XYZ stock for $95,000.
On the same day, A terminates its forward
contract with its counterparty, receiving $10,200.
No dividends were received on the stock during

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the time it was part of the conversion
transaction.
(ii) The XYZ stock and forward contract are
positions of a conversion transaction. Under
section 1258(c)(1), substantially all of A’s
expected return from the overall transaction is
attributable to the time value of the net
investment in the transaction. Under section
1258(c)(2)(B), the transaction is an applicable
straddle as defined in section 1258(d)(1).
(iii)A disposed of or terminated all the
positions of the conversion transaction within 14
days and within the same taxable year as re-
quired by paragraph (b)(1) of this section. The
transaction is an identified netting transaction
because it meets the identification requirement of
paragraph (b)(2) of this section. Solely for
purposes of section 1258(a), the $5,000 loss
realized ($100,000 basis less $95,000 amount
realized) on the disposition of the XYZ stock is
netted against the $10,200 gain recognized on the
disposition of the forward contract. Thus, the net
gain from the conversion transaction for purposes
of section 1258(a) is $5,200 ($10,200 gain less
$5,000 loss). Only the $5,200 net gain is re-
characterized as ordinary income under section
1258(a) even though the applicable imputed
income amount is $7,000. For federal tax
purposes other than section 1258(a), A has
recognized a $10,200 gain on the disposition of
the forward contract ($5,200 of which is treated
as ordinary income) and realized a separate
$5,000 loss on the sale of the XYZ stock.
Example 2. Identified netting transaction with
built-in loss. (i) The facts are the same as in
Example 1, except that A had purchased the XYZ
stock for $104,000 on May 15, 1995. The XYZ
stock had a fair market value of $100,000 on
December 1, 1995, the date it became part of a
conversion transaction.
(ii)The results are the same as in Example 1,
except that A has built-in loss (in addition to the
$5,000 loss that arose economically during the
period of the conversion transaction), as defined
in section 1258(d)(3)(B), of $4,000 on the XYZ
stock. That $4,000 built-in loss is not netted
against the $10,200 gain on the forward contract
for purposes of section 1258(a). Thus, the net
gain from the conversion transaction for purposes
of section 1258(a) is $5,200, the same as in
Example 1. The $4,000 built-in loss is recog-
nized and has a character determined without
regard to section 1258.
(e)Effective date and transition
rule—(1) In general. These regulations
are effective for conversion transactions
that are outstanding on or after Decem-
ber 21, 1995.
(2)Transition rule for identification
requirements. In the case of a conver-
sion transaction entered into before
February 20, 1996, paragraph (b)(2) of
this section is treated as satisfied if the
identification is made before the close
of business on February 20, 1996.
PART 602—OMB CONTROL
NUMBERS UNDER THE
PAPERWORK REDUCTION ACT
Par. 3. The authority citation for part
602 continues to read as follows:
Authority: 26 U.S.C. 7805.
§602.101 [Amended]
Par. 4. In §602.101, paragraph (c) is
amended by adding the entry ‘‘1.1258–
1 . . . .1545–1452’’ in numerical order
to the table.
Margaret Milner Richardson,
Commissioner of
Internal Revenue.
Approved November 28, 1995.
Leslie Samuels,
Assistant Secretary of
the Treasury.
(Filed by the Office of the Federal Register on
December 20, 1995, 8:45 a.m., and published
in the issue of the Federal Register for
December 21, 1995, 60 F.R. 66083)
Section 1445.—Withholding of Tax
on Dispositions of United States Real
Property Interests
26 CFR 1.1445–1: Withholding on dispositions
of U.S. real property interests by foreign
persons; in general.
T.D. 8647
DEPARTMENT OF TREASURY
Internal Revenue Service
26 CFR Part 1
Withholding of Tax on Dispositions of
U.S. Real Property Interests by
Foreign Persons.
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations.
SUMMARY: This document contains
final regulations relating to withholding
upon certain distributions or disposi-
tions of U.S. real property interests.
These regulations reflect changes to the
law made by the Omnibus Budget Re-
conciliation Act of 1993 and affect
withholding agents required to withhold
tax due on certain dispositions and
distributions of U.S. real property
interests.
DATES: These final regulations are
effective January 22, 1996. These
regulations are applicable to transac-
tions occurring after August 9, 1993.
FOR FURTHER INFORMATION
CONTACT: Gwendolyn A. Stanley
(202) 622-3860 (not a toll free-call).
SUPPLEMENTARY INFORMATION:
Background
This document contains final regula-
tions reflecting changes made by the
Omnibus Budget Reconciliation Act of
1993 to the withholding rates on
certain distributions and dispositions of
U.S. real property interests. These
regulations were not preceded by a
Notice of Proposed Rulemaking be-
cause the withholding rates were
changed by the Act. This document
also updates the address of the Assist-
ant Commissioner (International) to
whom various forms must be sent.
Explanation of Provisions
The rate of withholding under sec-
tion 1445(e)(1) and (2) of the Internal
Revenue Code was increased from 34%
to 35% by the Omnibus Budget Recon-
ciliation Act of 1993. The existing
regulations reflect the prior 34% with-
holding rate. These regulations reflect
the increase in withholding to 35% (or
the highest rate specified in section
1445(e)(1) or (2)) for dispositions
occurring on or after August 10, 1993.
Special Analyses
It has been determined that this
Treasury decision is not a significant
regulatory action as defined in EO
12866. Therefore, a regulatory assess-
ment is not required. It has also been
determined that section 553(b) of the
Administrative Procedure Act (5 U.S.C.
chapter 5) and the Regulatory Flexibility
Act (5 U.S.C. chapter 6) do not apply to
these regulations, and, therefore, a Reg-
ulatory Flexibility Analysis is not re-
quired. Pursuant to section 7805(f) of
the Internal Revenue Code, these final
regulations were submitted to the Small
Business Administration for comment
on their impact on small business.
Drafting Information
The principal author of these regula-
tions is Gwendolyn Stanley, Office of
Associate Chief Counsel (Interna-
tional), IRS. However, other personnel
from the IRS and Treasury Department
participated in their development.
******

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Adoption of Amendments to the
Regulations
Accordingly, 26 CFR part 1 is
amended as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation
for part 1 continues to read in part as
follows:
Authority: 26 U.S.C. 7805. * * *
Section 1.1445–5 also issued under
26 U.S.C. 1445(e)(6).
Section 1.1445–8 also issued under
26 U.S.C. 1445(e)(6). * * *
Par. 2. In section 1.1445–1, the
section heading and paragraph (g)(10)
are revised to read as follows:
§1.1445–1 Withholding on
dispositions of U.S. real property
interests by foreign persons: In
general.
******
(g)* * *
(10)Address of the Assistant Com-
missioner International. Any written
communication directed to the Assist-
ant Commissioner (International) is to
be addressed as follows: Director,
Philadelphia Service Center; 11601
Roosevelt Blvd.; Philadelphia, PA
19255; ATTN: Drop Point 543X.
Par. 3. Section 1.1445–5 is amended
as follows:
1.Paragraph (c)(1)(ii) is revised.
2.The third sentence and the last
sentence of paragraph (c)(1)(iii)(A) are
revised.
3 . P a r a g r a p h ( c ) ( 1 ) ( i i i ) ( B ) i s
removed.
4.Paragraph (c)(1)(iii)(C) is redesig-
nated as (c)(1)(iii)(B) and revised.
5.Paragraph (c)(1)(iv) is revised.
6.Paragraph (c)(3)(ii) is revised.
7.The first sentence of paragraph
(d)(1) is revised.
8.The second sentence of paragraph
(d)(1) is removed.
The revisions read as follows:
§1.1445–5 Special rules concerning
distributions and other transactions
by corporations, partnerships, trusts,
and estates.
******
(c)(1) * * *
(ii)Disposition by partnership. A
partnership must withhold a tax equal
to 35 percent (or the highest rate
specified in section 1445(e)(1)) of each
foreign partner’s distributive share of
the gain realized by the partnership
upon the disposition of each U.S. real
property interest. Such distributive
share of the gain must be determined
pursuant to the principles of section
704 and the regulations thereunder. For
the rules applicable to partnerships,
interests in which are regularly traded
on an established securities market, see
§1.1445–8.
(iii)Disposition by trust or estate—
(A) In general. * * * The fiduciary
must withhold 35 percent (or the
highest rate specified in section
1445(e)(1)) of any distribution to a
foreign beneficiary that is attributable
to the balance in the U.S. real property
interest account on the day of the
distribution. * * * For rules applicable
to trusts, interests in which are reg-
ularly traded on an established se-
curities market and real estate invest-
ment trusts, see §1.1445–8.
(B)Example. The following example
illustrates the rules of paragraph
(c)(1)(iii)(A) of this section.
On January 1, 1994, A establishes a domestic
trust (which has as its taxable year, the calendar
year) for the benefit of B, a nonresident alien,
and C, a U.S. citizen. The trust is not a trust
subject to sections 671 through 679. Under the
terms of the trust, the trustee, T, is given
discretion to distribute income and corpus of the
trust to provide for the reasonable needs of B
and C. During the trust’s 1994 tax year, T dis-
poses of three parcels of vacant land located in
the United States. The following chart illustrates
the computation of the amount subject to with-
holding under section 1445 with respect to
distributions made by T to B and C during 1994.
DateParcel sold
Gains or
(loss) realized
Distributions
to C
Distributions
to B (before
withholding)
Section 1445
withholding
35% rate
U.S. real
property
interest
account
1/01/94............................................................................................................-0-
3/01/94..................Parcel 1140,000140,000
3/05/94.....................................................5,00010,0003,500125,000
3/15/94.....................................................10,0005,0001,750110,000
5/01/94..................Parcel 2300,000410,000
5/15/94..................Parcel 3(50,000)360,000
12/01/94.....................................................170,000170,00059,50020,000
1/01/95............................................................................................................-0-
(iv)Disposition by grantor trust. The
trustee or equivalent fiduciary of a trust
that is subject to the provisions of
subpart E of part I of subchapter J
(sections 671 through 679) must with-
hold a tax equal to 35 percent (or the
highest rate specified in section
1445(e)(1)) of the gain realized from
each disposition of a U.S. real property
interest to the extent such gain is al-
locable to a portion of the trust treated
as owned by a foreign person under
subpart E of part I of subchapter J.
******
(3)* * *
(ii)Amount to be withheld. A part-
nership or trust electing to withhold
under this §1.1445–5(c)(3) shall with-
hold from each distribution to a foreign
person an amount equal to 35 percent
(or the highest rate specified in section
1445(e)(1)) of the amount attributable
to section 1445(e)(1) transfers.
******
(d)Distributions of U.S. real prop-
erty interests by foreign corporations—
(1) In general. A foreign corporation
that distributes a U.S. real property
interest must deduct and withhold a tax
equal to 35 percent (or the rate
specified in section 1445(e)(2)) of the

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amount of gain recognized by the
corporation on the distribution. * * *
******
Par. 4. Section 1.1445–8(c)(2)(i) is
revised to read as follows:
§ 1.1445–8 Special rules regarding
publicly traded partnerships, publicly
traded trusts and real estate
investment trusts (REITS).
******
(c)* * *
(2)REITS—(i) In general. The
amount to be withheld with respect to a
distribution by a REIT, under this
section shall be equal to 35 percent (or
the highest rate specified in section
1445(e)(1)) of the amount described in
paragraph (c)(2)(ii) of this section.
******
Margaret Milner Richardson,
Commissioner of
Internal Revenue.
Approved November 28, 1995.
Leslie Samuels,
Assistant Secretary of
the Treasury.
(Filed by the Office of the Federal Register on
December 20, 1995, 8:45 a.m., and published
in the issue of the Federal Register for
December 21, 1995, 60 F.R. 66076)

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10
Part III.Administrative, Procedural, and Miscellaneous
Rev. Proc. 96–8A
26 CFR 601.201: Rulings and determination
letters.
SECTION 1. PURPOSE
The purpose of this revenue proce-
dure is to correct errors in Rev. Proc.
96–8, 1996–1 I.R.B. 187, relating to
user fees. These corrections will be
incorporated into Rev. Proc. 96–8 when
it is published in the first cumulative
bulletin of 1996.
SECTION 2. CORRECTIONS TO
REV. PROC. 96–8
.01Section 6.04(5) is cor-
rected to read:
N o n m a s s s u b m i s s i o n
(new or amended) by M
& P sponsoring organiza-
tion, per adoption agree-
ment$3,000
.02Paragraphs (4), (5), and
(6) of section 6.05, and
paragraphs (6) and (7) of
section 6.06, are cor-
rected to state that the
fee, in each case, is $400.
.03Paragraph 6.08(1)(a) is
corrected to state that the
fee is $500.
SECTION 3. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 96–8 is modified.
SECTION 4. EFFECTIVE DATE
This revenue procedure is effective
January 2, 1996.
DRAFTING INFORMATION
The principal author of this revenue
procedure is John Turner of the
Employee Plans Division. For further
information regarding this revenue pro-
cedure, please contact Mr. Turner on
(202) 622-6214. (This is not a toll-free
number.)

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111996–24 I.R.B.
Part IV. Items of General Interest
Supplemental Information on Treasury
Bills for Publication 1212
Announcement 96–11
Banks, brokers, and other middlemen
who report discount on Treasury bill
redemptions on Form 1099–INT must
use the owner’s purchase price, where
available, to determine the amount of
discount to report. This information can
usually be obtained from the owner’s
or middleman’s records. However, if
the owner’s purchase price is not
available from existing records, the
middleman must report the discount as
if the holder had purchased the Treas-
ury bill at its original issue price. In
this case, the middleman must use as
the original issue price the noncompeti-
tive issue price for the longest-maturity
Treasury bill maturing on that date.
For Treasury bill redemptions when
the owner’s purchase price cannot be
determined, the following list gives the
noncompetitive issue prices and corre-
sponding amounts of discount to be
reported on Form 1099–INT for Treas-
ury bills maturing July through Decem-
ber 1996. This list, which should also
help middlemen determine any amounts
subject to backup withholding, supple-
ments the list that appears in Publica-
tion 1212, List of Original Issue
Discount Instruments (Rev. Nov. 95).
CUSIP
Number
Maturity
Date
Issue
Date
Issue Price (%
of Principal
Amount)
Discount to be
Reported as 1995
Interest (per $1,000
Maturity Value)
912794
W4201/04/9607/06/9597.24027.60
W5901/11/9601/12/9593.06469.36
W6701/18/9607/20/9597.27027.30
W7501/25/9607/27/9597.24027.60
W8302/01/9608/03/9597.27527.25
W9102/08/9602/09/9593.33766.83
X2502/15/9608/17/9597.26027.40
X3302/22/9608/24/9597.25527.45
X4102/29/9608/31/9597.30027.00
X5803/07/9603/09/9593.77262.28
X6603/14/9609/14/9597.30526.95
X7403/21/9609/21/9597.36126.39
X8203/28/9609/28/9597.33626.64
X9004/04/9604/06/9593.91360.87
Y2404/11/9610/12/9597.31026.90
Y3204/18/9610/19/9597.30027.00
Y4004/25/9610/26/9597.30526.95
Y5705/02/9605/04/9594.03459.66
Y6505/09/9611/09/9597.32626.74
Y7305/16/9611/16/9597.30526.95
Y8105/23/9611/24/9597.36026.40
Y9905/30/9606/01/9594.39856.02
Z2306/06/9612/07/9597.37626.24
Z3106/13/9612/14/9597.37126.29
Z4906/20/9612/21/9597.39626.04
Z5606/27/9606/29/9594.72252.78

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Announcement of the Disbarment, Suspension, or Consent to Voluntary
Suspension of Attorneys, Certified Public Accountants, Enrolled Agents and
Enrolled Actuaries From Practice Before the Internal Revenue Service
Under 31 Code of Federal Regula-
tions, Part 10, an attorney, certified
public accountant, enrolled agent or en-
rolled actuary, in order to avoid the in-
stitution or conclusion of a proceeding
for his disbarment or suspension from
practice before the Internal Revenue
Service, may offer his consent to
suspension from such practice. The
Director of Practice, in his discretion,
may suspend an attorney, certified
public accountant, enrolled agent or
enrolled actuary in accordance with the
consent offered.
Attorneys, certified public account-
ants, enrolled agents and enrolled actu-
aries are prohibited in any Internal
Revenue Service matter from directly
or indirectly employing, accepting
assistance from, being employed by,
or sharing fees with, any practi-
tioner disbarred or suspended from
practice before the Internal Revenue
Service.
To enable attorneys, certified public
accountants, enrolled agents and en-
rolled actuaries to identify practitioners
under consent suspension from practice
before the Internal Revenue Service,
the Director of Practice will announce
in the Internal Revenue Bulletin the
names and addresses of practitioners
who have been suspended from such
practice, their designation as attor-
ney, certified public accountant, en-
rolled agent or enrolled actuary and
date or period of suspension. This an-
nouncement will appear in the weekly
Bulletin at the earliest practicable date
after such action and will continue to
appear in the weekly Bulletins for five
successive weeks or for as many weeks
as is practicable for each attorney,
certified public accountant, enrolled
agent or enrolled actuary so suspended
and will be consolidated and published
in the Cumulative Bulletin.
The following individuals have been
placed under consent suspension from
practice before the Internal Revenue
Service:
NameAddressDesignationDate of Suspension
Isdaner, Thomas M.Crofton, MDCPAOctober 31, 1995 to October 30, 1996
Cacciola, MarlenePittsburg, CAEnrolled
Agent
November 9, 1995 to May 8, 1996
Goldman, William D.Hot Springs, ARAttorneyNovember 9, 1995 to November 8, 1996
Armstrong, David L.Norman, OKCPAIndefinite from November 10, 1995
Heckathorn, BenRed Oak, TXCPA
Attorney
Indefinite from November 28, 1995
Tisdel, LindaSeattle, WAEnrolled
Agent
November 28, 1995 to May 27, 1997
Webb, Herbert M.Gainsville, FLAttorneyDecember 21, 1995 to June 20, 1997
Hipp, Robert J.Evanston, ILCPADecember 28, 1995 to April 27, 1996
Ruff, James M.Willmar, MNCPAJanuary 1, 1996 to March 31, 1996
Mulkerin, John J.Wheaton, ILCPAJanuary 5, 1996 to April 4, 1996
Redwitz, RobertIrvine, CACPAFebruary 15, 1996 to May 14, 1996
Lind, Stanley L.Milwaukee, WIAttorneyMarch 1, 1996 to February 28, 1997
Dais, Robert E.Plano, TXCPAMarch 1, 1996 to February 28, 1997
Under Section 330, Title 31 of the
United States Code, the Secretary of
the Treasury, after due notice and
opportunity for hearing, is authorized
to suspend or disbar from practice
before the Internal Revenue Service
any person who has violated the rules
and regulations governing the recogni-
tion of attorneys, certified public ac-
countants, enrolled agents or enrolled
actuaries to practice before the Internal
Revenue Service.
Attorneys, certified public account-
ants, enrolled agents, and enrolled
actuaries are prohibited in any Internal
Revenue Service matter from directly
or indirectly employing, accepting as-
sistance from, being employed by or
sharing fees with, any practitioner
disbarred or under suspension from
practice before the Internal Revenue
Service.
To enable attorneys, certified public
accountants, enrolled agents and
enrolled actuaries to identify such
disbarred or suspended practitioners,
the Director of Practice will announce
in the Internal Revenue Bulletin the
names and addresses of practitioners
who have been suspended from such
practice, their designation as attorney,
certified public accountant, enrolled
agent or enrolled actuary, and the date
of disbarment or period of suspension.
This announcement will appear in the
weekly Bulletin for five successive
weeks or as long as it is practicable for
each attorney, certified public account-
ant, enrolled agent or enrolled actuary
so suspended or disbarred and will be
consolidated and published in the
Cumulative Bulletin.
After due notice and opportunity
for hearing before an administrative
law judge, the following individuals
have been disbarred from further prac-
tice before the Internal Revenue
Service:

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NameAddressDesignationEffective Date
Muraskin, DavidNew York, NYAttorneyNovember 6, 1995
Kelsey, PatrickPoolesville, MDCPANovember 13, 1995
Announcement of the Expedited Suspension of Attorneys, Certified Public
Accountants, Enrolled Agents, and Enrolled Actuaries From Practice Before the
Internal Revenue Service
Under title 31 of the Code of Federal
Regulations, section 10.76, the Director
of Practice is authorized to immediately
suspend from practice before the Inter-
nal Revenue Service any practitioner
who, within five years, from the date
the expedited proceeding is instituted,
(1) has had a license to practice as an
attorney, certified public accountant, or
actuary suspended or revoked for
cause; or (2) has been convicted of any
crime under title 26 of the United
States Code or, of a felony under title
18 of the United States Code involving
dishonesty or breach of trust.
Attorneys, certified public account-
ants, enrolled agents, and enrolled ac-
tuaries are prohibited in any Internal
Revenue Service matter from directly
or indirectly employing, accepting as-
sistance from, being employed by, or
sharing fees with, any practitioner
disbarred or suspended from practice
before the Internal Revenue Service.
To enable attorneys, certified public
accountants, enrolled agents, and en-
rolled actuaries to identify practitioners
under expedited suspension from prac-
tice before the Internal Revenue Serv-
ice, the Director of Practice will an-
nounce in the Internal Revenue Bulletin
the names and addresses of practition-
ers who have been suspended from such
practice, their designation as attorney,
certified public accountant, enrolled
agent, or enrolled actuary, and date or
period of suspension. This announce-
ment will appear in the weekly Bulletin
at the earliest practicable date after
such action and will continue to appear
in the weekly Bulletins for five succes-
sive weeks or for as many weeks as is
practicable for each attorney, certified
public accountant, enrolled agent, or
enrolled actuary so suspended and will
be consolidated and published in the
Cumulative Bulletin.
The following individuals have been
placed under suspension from practice
before the Internal Revenue Service by
virtue of the expedited proceeding
provisions of the applicable regulations:
NameAddressDesignationDate of Suspension
Trebatch, Henry T.Great Neck, NYCPAIndefinite from November 6, 1995
Roomberg, AlanMinersville, PACPAIndefinite from November 10, 1995
Elfenbein, Emanuel B.Miami, FLEnrolled
Agent
Indefinite from November 27, 1995
Cerullo, Louis, J.Boca Raton, FLCPAIndefinite from November 27, 1995
Fogel, HaroldSt. Paul, MNCPAIndefinite from December 13, 1995
Glover, Paul L.Downers Grove, ILAttorneyIndefinite from December 13, 1995
Miller, John R.Akron, OHAttorneyIndefinite from December 13, 1995
Pofahl, CharlesDallas, TXAttorneyIndefinite from December 18, 1995
Walburg, DouglasMahtomedi, MNCPAIndefinite from December 18, 1995
Hibler, Thomas M.Plymouth, MICPA
Attorney
Indefinite from December 18, 1995
Oringer, RonaldFlanders, NJCPAIndefinite from December 29, 1995
Butcher, FrederickStillwater, NJCPAIndefinite from December 29, 1995
Tokars, FredericAtlanta, GAAttorneyIndefinite from December 29, 1995
Atkins, Sanford I.Moreland Hills, OHAttorneyIndefinite from December 29, 1995

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Definition of Terms
Revenue rulings and revenue proce-
dures (hereinafter referred to as ‘‘rul-
ings’’) 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
published position, but the prior posi-
tion 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 princi-
ple 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.
Distinguished describes a situation
where a ruling mentions a previously
published ruling and points out an
essential 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 applies to both A and B, the prior
ruling is modified because it corrects a
published position. (Compare with am-
plified and clarified, above).
Obsoleted describes a previously
published ruling that is not considered
determinative with respect to future
transactions. This term is most com-
monly 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 substance has
been included in regulations subse-
quently adopted.
Revoked describes situations where
the position in the previously published
ruling 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 pub-
lished under the 1939 Code and regula-
tions. The term is also used when it is
desired to republish in a single ruling a
series of situations, names, etc., that
were previously published over a
period of time in separate rulings. If
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 de-
scribes a situation where the substance
of a previously published 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
superseded.
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 published 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
formerly used will appear in material published
in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C.—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contribution Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign Corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statements of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.

SEQ 0055 JOB B23-052-003 PAGE-0015 FINDING LIST
REVISED 28MAY96 AT 11:34 BY LR DEPTH: 65.01 PICAS WIDTH 32.08 PICAS
COMPOSITE COLOR
778/20049/28MAY96/B23-052
15
Numerical Finding List
1
Bulletins 1996–1 through 1996–8
Announcements:
96–1, 1996–2 I.R.B. 57
96–2, 1996–2 I.R.B. 57
96–3, 1996–2 I.R.B. 57
96–4, 1996–3 I.R.B. 50
96–5, 1996–4 I.R.B. 99
96–6, 1996–5 I.R.B. 43
96–7, 1996–5 I.R.B. 44
96–8, 1996–7 I.R.B. 56
96–9, 1996–8 I.R.B. 30
96–10, 1996–8 I.R.B. 30
Delegations Orders:
232 (Rev. 2), 1996–7 I.R.B. 49
239 (Rev. 1), 1996–7 I.R.B. 49
Notices:
96–2, 1996–2 I.R.B. 15
96–1, 1996–3 I.R.B. 30
96–4, 1996–4 I.R.B. 69
96–5, 1996–6 I.R.B. 22
96–6, 1996–5 I.R.B. 27
96–7, 1996–6 I.R.B. 22
96–8, 1996–6 I.R.B. 23
96–9, 1996–6 I.R.B. 26
96–10, 1996–7 I.R.B. 47
96–11, 1996–8 I.R.B. 19
Proposed Regulations:
DL–1–95, 1996–6 I.R.B. 28
EE–20–95, 1996–5 I.R.B. 15
EE–34–95, 1996–3 I.R.B. 49
EE–35–95, 1996–5 I.R.B. 19
EE–53–95, 1996–5 I.R.B. 23
IA–33–95, 1996–4 I.R.B. 99
INTL–3–95, 1996–6 I.R.B. 29
INTL–9–95, 1996–5 I.R.B. 25
PS–2–95, 1996–7 I.R.B. 50
Revenue Procedures:
96–1, 1996–1 I.R.B. 8
96–2, 1996–1 I.R.B. 60
96–3, 1996–1 I.R.B. 82
96–4, 1996–1 I.R.B. 94
96–5, 1996–1 I.R.B. 129
96–6, 1996–1 I.R.B. 151
96–7, 1996–1 I.R.B. 185
96–8, 1996–1 I.R.B. 187
96–9, 1996–2 I.R.B. 15
96–10, 1996–2 I.R.B. 17
96–11, 1996–2 I.R.B. 18
96–12, 1996–3 I.R.B. 30
96–13, 1996–3 I.R.B. 31
1
A cumulative list of all Revenue Rulings,
Revenue Procedures, Treasury Decisions, etc.,
published in Internal Revenue Bulletins 1995–27
through 1995–52 will be found in Internal
Revenue Bulletin 1996–1, dated January 2, 1996.
Revenue Procedures—Continued
96–14, 1996–3 I.R.B. 41
96–15, 1996–3 I.R.B. 41
96–16, 1996–3 I.R.B. 45
96–17, 1996–4 I.R.B. 69
96–18, 1996–4 I.R.B. 73
96–19, 1996–4 I.R.B. 80
96–20, 1996–4 I.R.B. 88
96–21, 1996–4 I.R.B. 96
96–22, 1996–5 I.R.B. 27
96–23, 1996–5 I.R.B. 27
96–24, 1996–5 I.R.B. 28
96–25, 1996–8 I.R.B. 19
96–26, 1996–8 I.R.B. 22
Revenue Rulings:
96–1, 1996–1 I.R.B. 7
96–2, 1996–2 I.R.B. 5
96–3, 1996–2 I.R.B. 14
96–6, 1996–2 I.R.B. 8
96–4, 1996–3 I.R.B. 16
96–5, 1996–3 I.R.B. 29
96–7, 1996–3 I.R.B. 12
96–8, 1996–4 I.R.B. 62
96–9, 1996–4 I.R.B. 5
96–10, 1996–4 I.R.B. 27
96–11, 1996–4 I.R.B. 28
96–14, 1996–6 I.R.B. 20
Treasury Decisions:
8630, 1996–3 I.R.B. 19
8631, 1996–3 I.R.B. 7
8632, 1996–4 I.R.B. 6
8633, 1996–4 I.R.B. 20
8634, 1996–3 I.R.B. 17
8635, 1996–3 I.R.B. 5
8636, 1996–4 I.R.B. 64
8637, 1996–4 I.R.B. 29
8638, 1996–5 I.R.B. 5
8639, 1996–5 I.R.B. 12
8640, 1996–2 I.R.B. 10
8641, 1996–6 I.R.B. 4
8642, 1996–7 I.R.B. 4
8644, 1996–7 I.R.B. 16
8645, 1996–8 I.R.B. 4
8646, 1996–8 I.R.B. 10

SEQ 0056 JOB B23-052-003 PAGE-0016 FINDING LIST
REVISED 28MAY96 AT 11:34 BY LR DEPTH: 65.01 PICAS WIDTH 41.11 PICAS
COMPOSITE COLOR
778/20049/28MAY96/B23-052
16
Finding List of Current Action on
Previously Published Items
1
Bulletins 1996–1 through 1996–8
*Denotes entry since last publication
Delegation Orders:
232 (Rev. 1)
Superseded by
232 (Rev. 2), 1996–7 I.R.B. 49
239
Amended by
239 (Rev. 1), 1996–7 I.R.B. 49
Revenue Procedures:
65–17
Modified by
96–14, 1996–3 I.R.B. 41
66–49
Modified by
96–15, 1996–3 I.R.B. 41
88–32
Obsoleted by
96–15, 1996–3 I.R.B. 41
88–33
Obsoleted by
96–15, 1996–3 I.R.B. 41
89–19
Superseded by
96–17, 1996–4 I.R.B. 69
89–48
Superseded in part by
96–17, 1996–4 I.R.B. 69
91–22
Modified by
96–1, 1996–1 I.R.B. 8
91–22
Amplified by
96–13, 1996–3 I.R.B. 31
91–23
Superseded by
96–13, 1996–3 I.R.B. 31
91–24
Superseded by
96–14, 1996–3 I.R.B. 41
91–26
Superseded by
96–13, 1996–3 I.R.B. 31
92–20
Modified by
96–1, 1996–1 I.R.B. 8
1
A cumulative finding list for previously
published items mentioned in Internal Revenue
Bulletins 1995–27 through 1995–52 will be
found in Internal Revenue Bulletin 1996–1, dated
January 2, 1996.
Revenue Procedures—Continued
92–85
Modified by
96–1, 1996–1 I.R.B. 8
93–16
Superseded by
96–11, 1996–2 I.R.B. 18
93–46
Superseded in part by
96–17, 1996–4 I.R.B. 69
Superseded by
96–18, 1996–4 I.R.B. 73
94–18
Superseded in part by
96–17, 1996–4 I.R.B. 69
Superseded by
96–18, 1996–4 I.R.B. 73
94–59
Superseded in part by
96–17, 1996–4 I.R.B. 69
Superseded by
96–18, 1996–4 I.R.B. 73
95–1
Superseded by
96–1, 1996–1 I.R.B. 8
95–2
Superseded by
96–2, 1996–1 I.R.B. 60
95–3
Superseded by
96–3, 1996–1 I.R.B. 82
95–4
Superseded by
96–4, 1996–1 I.R.B. 94
95–5
Superseded by
96–5, 1996–1 I.R.B. 129
95–6
Superseded by
96–6, 1996–1 I.R.B. 151
95–7
Superseded by
96–7, 1996–1 I.R.B. 185
95–8
Superseded by
96–8, 1996–1 I.R.B. 187
95–13
Superseded by
96–20, 1996–4 I.R.B. 88
Revenue Procedures—Continued
95–20
Superseded by
96–24, 1996–5 I.R.B. 28
95–50
Superseded by
96–3, 1996–1 I.R.B. 82
96–3
Amplified by
96–12, 1996–3 I.R.B. 30
Revenue Rulings:
66–307
Obsoleted by
96–3, 1996–2 I.R.B. 14
72–437
Modified by
96–13, 1996–3 I.R.B. 31
80–80
Obsoleted by
96–3, 1996–2 I.R.B. 14
82–80
Modified by
96–14, 1996–3 I.R.B. 41
92–19
Supplemented in part
96–2, 1996–2 I.R.B. 5
92–75
Clarified by
96–13, 1996–3 I.R.B. 31
95–10
Supplemented and superseded by
96–4, 1996–3 I.R.B. 16
95–11
Supplemented and superseded by
96–5, 1996–3 I.R.B. 29

SEQ 0057 JOB B23-052-003 PAGE-0017 FINDING LIST
REVISED 28MAY96 AT 11:34 BY LR DEPTH: 65.01 PICAS WIDTH 32.10 PICAS
COMPOSITE COLOR
778/20049/28MAY96/B23-052
17
NOTES

SEQ 0058 JOB B23-052-003 PAGE-0018 FINDING LIST
REVISED 28MAY96 AT 11:34 BY LR DEPTH: 65.01 PICAS WIDTH 32.10 PICAS
COMPOSITE COLOR
778/20049/28MAY96/B23-052
18
NOTES

SEQ 0059 JOB B23-052-003 PAGE-0019 FINDING LIST
REVISED 28MAY96 AT 11:34 BY LR DEPTH: 65.01 PICAS WIDTH 32.10 PICAS
COMPOSITE COLOR
778/20049/28MAY96/B23-052
19
NOTES