Internal Revenue Bulletin 2001-25 (PDF rendition): IRS Revenue Rulings

Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.

SPECIAL ANNOUNCEMENT
Announcement 2001–64, page 1344.
This document provides the schedule for the 2001 IRS
Nationwide Tax Forums and the 2001 IRS/SSA Information
Reporting Program Seminars.
INCOME TAX
Rev. Rul. 2001–28, page 1338.
LIFO; price indexes; department stores. The April 2001
Bureau of Labor Statistics price indexes are accepted for
use by department stores employing the retail inventory and
last-in, first-out inventory methods for valuing inventories for
tax years ended on, or with reference to, April 30, 2001.
EMPLOYEE PLANS
Notice 2001–37, page 1340.
Definition of compensation; qualified transportation
fringe benefits.This notice provides guidance to sponsors
of qualified plans and tax-sheltered annuity plans concerning
changes made to the definition of compensation by the
Community Renewal Tax Relief Act of 2000. These changes
generally expand the definition of compensation to reflect
elective salary reductions for qualified transportation fringe
benefits.
Announcement 2001–63, page 1344.
The Service has revised the Defined Benefit Listing of
Required Modifications and Information Package to allow
additional options for master and prototype and volume sub-
mitter plans with respect to sections 415 and 417 of the
Code.
EXEMPT ORGANIZATIONS
Announcement 2001–66, page 1345.
A list is provided of organizations now classified as private
foundations.
Internal Revenue
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Bulletin No. 2001–25
June 18, 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.

June 18, 20012001–25 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
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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 1100.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions, and Subpart B, Legislation and Related
Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to
these subjects are contained in the other Parts and Sub-
parts. Also included in this part are Bank Secrecy Act Admin-
istrative Rulings. Bank Secrecy Act Administrative Rulings
are issued by the Department of the Treasury’s Office of the
Assistant Secretary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The first Bulletin for each month includes a cumulative index
for the matters published during the preceding months.
These monthly indexes are cumulated on a semiannual basis,
and are published in the first Bulletin of the succeeding semi-
annual period, respectively.
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.

June 18, 200113382001–25 I.R.B.
Section 472.—Last-in, First-out
Inventories
26 CFR 1.472–1: Last-in, first-out inventories.
LIFO; price indexes; department
stores. The April 2001 Bureau of Labor
Statistics price indexes are accepted for
use by department stores employing the
retail inventory and last-in, first-out
inventory methods for valuing inventories
for tax years ended on, or with reference
to, April 30, 2001.
Rev. Rul. 2001–28
The following Department Store In-
ventory Price Indexes for April 2001
were issued by the Bureau of Labor Sta-
tistics. The indexes are accepted by the
Internal Revenue Service, under
§ 1.472–1(k) of the Income Tax Regula-
tions and Rev. Proc. 86–46, 1986–2 C.B.
739, for appropriate application to in-
ventories of department stores employ-
ing the retail inventory and last-in, first-
out inventory methods for tax years
ended on, or with reference to, April 30,
2001.
The Department Store Inventory Price
Indexes are prepared on a national basis
and include (a) 23 major groups of depart-
ments, (b) three special combinations of
the major groups - soft goods, durable
goods, and miscellaneous goods, and (c) a
store total, which covers all departments,
including some not listed separately, ex-
cept for the following: candy, food,
liquor, tobacco, and contract departments.
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
BUREAU OF LABOR STATISTICS, DEPARTMENT STORE
INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS
(January 1941 = 100, unless otherwise noted)
Percent Change
GroupsApr.Apr.from Apr. 2000
20002001to Apr. 2001
1
1. Piece Goods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .516.8497.9-3.7
2. Domestics and Draperies . . . . . . . . . . . . . . . . . . . . . . . . .631.1606.5-3.9
3. Women’s and Children’s Shoes . . . . . . . . . . . . . . . . . . . .646.0657.41.8
4. Men’s Shoes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .919.2895.3-2.6
5. Infants’ Wear . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .642.5626.8-2.4
6. Women’s Underwear . . . . . . . . . . . . . . . . . . . . . . . . . . . .576.2565.5-1.9
7. Women’s Hosiery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .334.2344.8 3.2
8. Women’s and Girls’ Accessories . . . . . . . . . . . . . . . . . . .553.3557.30.7
9. Women’s Outerwear and Girls’ Wear . . . . . . . . . . . . . . . .413.3414.50.3
10. Men’s Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .615.3591.8-3.8
11. Men’s Furnishings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .631.7618.7-2.1
12. Boys’ Clothing and Furnishings . . . . . . . . . . . . . . . . . . . .497.5485.0 -2.5
13. Jewelry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .971.9938.6-3.4
14. Notions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .757.6793.44.7
15. Toilet Articles and Drugs . . . . . . . . . . . . . . . . . . . . . . . . .971.5991.02.0
16. Furniture and Bedding . . . . . . . . . . . . . . . . . . . . . . . . . . .680.8650.3-4.5
17. Floor Coverings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .607.4626.83.2
18. Housewares . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .782.1773.8-1.1
19. Major Appliances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .234.8224.8-4.3
20. Radio and Television . . . . . . . . . . . . . . . . . . . . . . . . . . . .60.055.2-8.0
21. Recreation and Education
2
. . . . . . . . . . . . . . . . . . . . . . . .94.990.3-4.8
22. Home Improvements
2
. . . . . . . . . . . . . . . . . . . . . . . . . . .128.0127.0-0.8
23. Auto Accessories
2
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .106.5109.02.3
Groups 1 - 15: Soft Goods . . . . . . . . . . . . . . . . . . . . . . . . . .610.5603.2-1.2
Groups 16 - 20: Durable Goods . . . . . . . . . . . . . . . . . . . . . . .440.3426.5-3.1
Groups 21 - 23: Misc. Goods
2
. . . . . . . . . . . . . . . . . . . . . . . .101.598.9-2.6
Store Total
3
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .547.0537.5-1.7
1
Absence of a minus sign before the percentage change in this column signifies a price increase.
2
Indexes on a January 1986=100 base.
3
The store total index covers all departments, including some not listed separately, except for the following: candy, food, liquor,
tobacco, and contract departments.

2001–25 I.R.B.1339June 18, 2001
DRAFTING INFORMATION
The principal author of this revenue
ruling is Alan J. Tomsic of the Office of
Associate Chief Counsel (Income Tax and
Accounting). For further information re-
garding this revenue ruling, contact Mr.
Tomsic at (202) 622-4970 (not a toll-free
call).

June 18, 200113402001–25 I.R.B.
Inclusion of Elective Reductions
for Qualified Transportation
Fringes in Compensation Under
Qualified Plans and 403(b)
Plans
Notice 2001–37
I. PURPOSE
The purpose of this notice is to provide
guidance relating to the amendments
made by § 314(e) of the Community Re-
newal Tax Relief Act of 2000 (“CRA”) to
§§ 403(b)(3), 414(s)(2), and 415(c)(3) of
the Internal Revenue Code. These Code
sections provide definitions of compensa-
tion that apply to plans described in
§§ 401(a) and 403(a) (“qualified plans”)
and § 403(b) (“403(b) plans”). The CRA
amendments change these compensation
definitions to reflect the amount of the
compensation reduction elected for quali-
fied transportation fringes that is not in-
cludible in the employee’s gross income
by reason of § 132(f)(4) of the Code
(“§ 132(f) elective reductions”). The
CRA amendments to §§ 403(b)(3),
414(s), and 415(c)(3) are retroactively ef-
fective for years beginning after Decem-
ber 31, 1997.
Specifically, this notice provides that –
• Qualified plans must be operated in
accordance with the CRA amendments
for plan and limitation years beginning
on or after January 1, 2001. Plan
amendments that are needed as a result
of the CRA amendments must be
adopted within the GUST remedial
amendment period. The plan amend-
ments must be effective no later than
the first day of the first plan and limita-
tion years beginning on or after January
1, 2001.
• Sponsors of qualified plans may satisfy
the preceding requirements by adopting
the model amendments included in the
appendix to this notice.
• Qualified plans will not be disqualified
solely on account of a failure to reflect
in form or operation the CRA amend-
ments to §§ 414(s) and 415(c)(3) for
plan and limitation years beginning
before January 1, 2001. Retroactive
plan amendments that take the CRA
amendments into account for those
years are required only for plans that
operated in those years in accordance
with §§ 414(s) and 415(c)(3) as amend-
ed.
• Exclusion allowances for employees
who participate in 403(b) plans need
not be recalculated under § 403(b)(2)
on account of the CRA amendments for
years before January 1, 2001.
II. BACKGROUND
Section 132(a)(5) of the Code provides
that a qualified transportation fringe is ex-
cluded from an employee’s gross income.
Section 132(f)(1) defines a qualified
transportation fringe to include employer-
provided transportation in a commuter
highway vehicle between the employee’s
home and office, transit passes, and quali-
fied parking. Section 132(f)(4) provides
that no amount is included in an em-
ployee’s gross income solely because the
employer offers the employee a choice
between any qualified transportation
fringe and compensation that would oth-
erwise be included in gross income.
The definition of compensation under
§ 415(c)(3) is used to determine whether
annual additions to a participant’s ac-
count exceed the percentage limitation
described in § 415(c)(1)(B). The defini-
tion is also used for other purposes under
the Code relating to qualified plans, in-
cluding the percentage limitation de-
scribed in § 415(b)(1)(B), the determina-
tion of who is a highly compensated
employee under § 414(q), and the deter-
mination of who is a key employee and
the amount of required minimum contri-
butions or benefits for top-heavy plans
under § 416. Further, this definition is
frequently used by qualified plans to de-
termine employees’ benefits. Section
415(c)(3)(D) was added by the Small
Business Job Protection Act of 1996
(“SBJPA”), effective for years beginning
after December 31, 1997. Prior to
amendment by CRA, § 415(c)(3)(D) pro-
vided that a participant’s compensation
includes elective deferrals as defined in
§ 402(g)(3) and amounts contributed or
deferred by the employer at the election
of the employee that are not includible in
gross income by reason of § 125 or 457.
CRA amended § 415(c)(3)(D)(ii), effec-
tive for years beginning after December
31, 1997, to provide that a participant’s
compensation for any year after 1997
also includes § 132(f) elective reductions.
It should be noted that, for some of the
purposes for which the definition of
§ 415(c)(3) is used, e.g., the definition of
highly compensated employee (which is
required to be based on prior year com-
pensation data), the change to the
§ 415(c)(3) compensation would not af-
fect the plan until the year after the first
year for which it is effective.
Section 414(s) provides a definition of
compensation that applies for any Code
provision that specifically refers to
§ 414(s). The definition of compensation
under § 414(s) is used for nondiscrimina-
tion testing under qualified plans and
403(b) plans, including the actual deferral
percentage (“ADP”) test under
§ 401(k)(3) and the actual contribution
percentage (“ACP”) test under
§ 401(m)(2). Section 414(s)(1) provides
that compensation has the meaning given
in § 415(c)(3). Prior to amendment by
CRA, § 414(s)(2) provided that an em-
ployer may elect not to include as com-
pensation amounts contributed by the em-
ployer pursuant to a salary reduction
agreement that are not includible in the
employee’s gross income under § 125,
402(e)(3), 402(h), or 403(b). CRA
amended § 414(s)(2), effective for years
beginning after December 31, 1997, to
add § 132(f) elective reductions to this
list. Section 414(s)(3) requires the Secre-
tary of the Treasury to provide for alterna-
tive definitions of compensation that sat-
isfy § 414(s) and that do not discriminate
in favor of highly compensated employ-
ees.
Section 1.414(s)–1(c)(1) prescribes
general rules regarding the definition of
compensation under § 414(s). Section
1.414(s)–1(c)(2) provides that a definition
of compensation that includes all com-
pensation under § 415(c)(3), as described
in § 1.415–2(d), and excludes all other
compensation, is a safe harbor definition
of compensation for purposes of § 414(s).
Prior to the amendment of § 415(c)(3) by
SBJPA, total compensation under
§ 415(c)(3) did not include elective
Part III. Administrative, Procedural, and Miscellanous

amounts. Section 1.414(s)–1(c)(4) pro-
vides that a definition of compensation
that includes all compensation under
§ 415(c)(3) and also includes elective
amounts that are not includible in gross
income under §§ 125, 402(e)(3), 401(h),
and 403(b), compensation deferred under
an eligible deferred compensation plan
described in § 457(b), and employee con-
tributions described in § 414(h)(2) that
are picked up by the employer, is a safe
harbor definition of compensation for
purposes of § 414(s). Section
1.414(s)–1(c)(1) and (4) does not reflect
the amendments to § 415(c)(3) by SBJPA
and CRA. A definition of compensation
that does not satisfy one of the safe har-
bors can nonetheless satisfy § 414(s) if it
satisfies the nondiscrimination require-
ment of § 1.414(s)–1(d).
Section 403(b)(3) provides a definition
of “includible compensation” that is used
for purposes of determining an em-
ployee’s exclusion allowance under
§ 403(b)(2). The Taxpayer Relief Act of
1997 (“TRA ’97”) amended the definition
of includible compensation under
§ 403(b)(3) to include elective deferrals
as defined in § 402(g)(3) and amounts
contributed or deferred by the employer at
the election of the employee that are not
currently includible in gross income by
reason of § 125 or 457, effective for years
beginning after December 31, 1997.
CRA amended § 403(b)(3)(B), effective
for years beginning after December 31,
1997, to provide that includible compen-
sation for any year after 1997 also in-
cludes § 132(f) elective reductions. For
employees who make the election under
§ 415(c)(4)(D) to have the provisions of
§ 415(c)(4)(C) apply, the exclusion al-
lowance under § 403(b)(2) is determined
with reference to the limitations under
§ 415. In this case, the definition of com-
pensation under § 415(c)(3) applies.
Section 1.401(b)–1(b)(3) authorizes the
Commissioner to designate a plan provi-
sion as a disqualifying provision if the
provision either (1) results in the failure
of the plan to satisfy the qualification re-
quirements of the Code by reason of a
change in those requirements or (2) is in-
tegral to a qualification requirement that
has been changed. The remedial amend-
ment period for a disqualifying provision
that is integral to a qualification require-
ment that has been changed begins on the
first day on which the plan was operated
in accordance with such provision, as
amended (unless another time is specified
by the Commissioner). Section
1.401(b)–1(c)(3) authorizes the Commis-
sioner, in the case of disqualifying provi-
sions designated as described in the pre-
ceding sentence, to impose limits and
provide additional rules regarding the
amendments that may be made with re-
spect to that disqualifying provision.
Revenue Procedure 2000–27, 2000–26
I.R.B. 1272, provides that the GUST re-
medial amendment period for nongovern-
mental plans ends on the last day of the
first plan year beginning on or after Janu-
ary 1, 2001. The remedial amendment
period for governmental plans, as defined
in § 414(d), ends on the later of (i) the last
day of the first plan year beginning on or
after January 1, 2001, or (ii) the last day
of the first plan year beginning on or after
the “2000 legislative date” (that is, the
90
th
day after the opening of the first leg-
islative session beginning after December
31, 1999, of the governing body with au-
thority to amend the plan, if that body
does not meet continuously). An ex-
tended GUST remedial amendment pe-
riod may be available under the provi-
sions of Rev. Proc. 2000–20, 2000–6
I.R.B. 553. The GUST remedial amend-
ment period is available for certain plan
amendments, including amendments to
comply with the Uruguay Round Agree-
ments Act, the Uniformed Services Em-
ployment and Reemployment Rights Act
of 1994, the Small Business Job Protec-
tion Act of 1996, the Taxpayer Relief Act
of 1997, and the Internal Revenue Service
Restructuring and Reform Act of 1998.
III. APPLICATION OF THE CRA
AMENDMENTS TO §§ 414(s) AND
415(c)(3) TO QUALIFIED PLANS
The CRA amendments not only change
the definitions of compensation under
§§ 414(s) and 415(c) but also, as de-
scribed above, affect other qualification
requirements that depend in part on those
Code sections. Pursuant to
§ 1.401(b)–1(b)(3), plan provisions that
must be amended as a result of the CRA
amendments and plan provisions that are
integrally related to qualification require-
ments changed by the CRA amendments
are hereby designated disqualifying pro-
visions, as further described below. Pur-
suant to the authority under § 1.401
(b)–1(c)(3), the remedial amendment pe-
riod with respect to such disqualifying
provisions ends on the last day of a plan’s
GUST remedial amendment period.
A.Prospective application
For plan and limitation years beginning
on or after January 1, 2001, a plan provi-
sion is a disqualifying provision if it
causes the plan to fail to satisfy the quali-
fication requirements as a result of the
CRA amendments for such years. Ac-
cordingly, a plan must be amended within
the plan’s GUST remedial amendment pe-
riod to the extent necessary to comply in
form with the CRA amendments for plan
and limitation years beginning on or after
January 1, 2001. The plan must also be
operated in accordance with the CRA
amendments for those years.
B. Retroactive application
Pursuant to § 7805(b), the Service will
not treat a qualified plan as having failed
to satisfy the requirements of § 401(a)
merely because the plan did not take the
CRA amendments into account for plan or
limitation years beginning before January
1, 2001.
For plan and limitation years beginning
on or after January 1, 1998, a plan provi-
sion is a disqualifying provision if the plan
provision is integral to a qualification re-
quirement changed by the CRA amend-
ments. Thus, plans that took the CRA
amendments into account in operation for
plan or limitation years beginning before
January 1, 2001, must be retroactively
amended within the GUST remedial
amendment period to the extent necessary
to comply in form with the CRA amend-
ments. The plan amendments must be ef-
fective retroactively to the first day of the
plan and limitation years for which the
plan was first operated in accordance with
the CRA amendments. Under this notice,
retroactive plan amendments that take into
account the CRA amendments for plan
and limitation years beginning before Jan-
uary 1, 2001, are required only for those
plans that took the CRA amendments into
account in operation for those years. A
plan that has not been operated in accor-
dance with the CRA amendments for plan
or limitation years beginning before Janu-
ary 1, 2001, may not be amended retroac-
tively for CRA, but must be amended for
2001–25 I.R.B.1341June 18, 2001

years beginning on or after January 1,
2001, as described in § IIIA above.
C. Examples
The following examples illustrate the
application of the CRA amendment to
§ 415(c)(3) to qualified plans. The exam-
ples assume, in each case, that the em-
ployers provide for § 132(f) elective re-
ductions.
Example 1. Employer A sponsors a calendar
year defined benefit plan that specifically in-
cludes amounts deferred under §§ 125,
402(g)(3), and 457, but not § 132(f) elective re-
ductions, in the definition of compensation for
purposes of applying the § 415(b) limitations,
the definition of key employee under § 416, and
calculating the § 416 top-heavy minimums. Be-
cause the plan’s definition of compensation is
used for purposes of the plan’s provisions relat-
ing to §§ 415 and 416, the plan must be operated
and amended, effective January 1, 2001, by the
end of its GUST remedial amendment period, to
reflect § 415(c)(3) as amended by CRA.
Example 2.Employer B sponsors a money pur-
chase pension plan that includes a definition of
compensation for making contributions that
specifically includes amounts deferred under
§§ 125, 402(g)(3), and 457, but not
§ 132(f) elective reductions, in the definition of
compensation for purposes of applying the
§ 415(c) limitations, the definition of key em-
ployee under § 416, and calculating the § 416
top-heavy minimums. The plan year and limita-
tion year both begin on October 1. However, for
plan and limitation years beginning on October
1, 1999, the plan adminstrator operated the plan
to include § 132(f) elective reductions. Em-
ployer B must amend the plan’s definition of
compensation to include § 132(f) elective reduc-
tions. The amendment must be made effective
retroactively for plan and limitation years begin-
ning on October 1, 1999, and must be adopted
by the end of the plan’s GUST remedial amend-
ment period.
IV. 403(b) PLANS
CRA amended § 403(b)(3) to provide
that, for purposes of determining the ex-
clusion allowance under § 403(b)(2),
§ 132(f) elective reductions are to be in-
cluded in an employee’s compensation for
years beginning after December 31, 1997.
For the 2001 and later taxable years, em-
ployees’ exclusion allowances are calcu-
lated taking into account the CRA amend-
ment of § 403(b)(3). For purposes of
determining the exclusion allowance for
employees for 1998 and years thereafter
to the extent the determination uses com-
pensation with respect to 1998, 1999, and
2000, compensation may be calculated in
accordance with § 403(b) as it read after
amendment by TRA ’97 but before
amendment by CRA, i.e., by not includ-
ing § 132(f) elective reductions in the def-
inition of compensation.
A 403(b) plan that is required to satisfy
the nondiscrimination requirements of
§ 403(b)(12) must be operated in accor-
dance with the CRA amendments to
§§ 403(b), 414(s), and 415(c) in years be-
ginning on or after January 1, 2001.
V. PROCEDURES RELATING TO
ADOPTION OF MODEL
AMENDMENTS
The model amendments that appear in
the Appendix to this revenue procedure
may be adopted by sponsors of individu-
ally designed plans (including adopters of
volume submitter plans) and by practi-
tioners that sponsor volume submitter
specimen plans. The model amendments
may also be used by sponsors and
adopters of master and prototype (M&P)
plans.
The model amendments in the appen-
dix to this revenue procedure, if adopted
on a word-for-word identical basis
within a plan’s GUST remedial amend-
ment period, will be deemed to satisfy
the requirements of §§ 415(c)(3) and
414(s)(2) as amended by CRA, respec-
tively. Practitioners that sponsor volume
submitter specimen plans may include
the model amendments in a specimen
plan without adversely affecting the
plan’s advisory letter. An employer that
has adopted a volume submitter speci-
men plan prior to this amendment of the
specimen plan may individually adopt
the model amendments without ad-
versely affecting the plan’s determina-
tion letter. Sponsors of M&P plans that
have not yet been approved for GUST
may incorporate the model provisions in
adoption agreements. Sponsors of M&P
plans that have been approved for GUST
may provide the model amendments to
adopting employers as supplements to
the approved adoption agreement. The
Service will not issue new opinion, advi-
sory, or determination letters for plans
that are amended solely to add the model
amendments.
M&P and volume submitter plan spon-
sors that use the model language must file
Form 8837, Notice of Adoption of Rev-
enue Procedure Model Amendments.At
line 2 of Form 8837, enter “Notice
2001–37” instead of “Revenue Proce-
dure.”
DRAFTING INFORMATION
The principal drafter of this revenue
procedure is Diane S. Bloom of the Em-
ployee Plans Division. For further infor-
mation regarding this revenue procedure,
please contact the Employee Plans Divi-
sion’s taxpayer assistance telephone ser-
vice at (202) 283-9516 or (202) 283-
9517, between the hours of 1:30 p.m. and
3:30 p.m. Eastern Time, Monday through
Thursday. Ms. Bloom may be reached at
(202) 283-9888. These telephone num-
bers are not toll-free.
APPENDIX — MODEL
AMENDMENTS
The following are model amendments
that sponsors of qualified plans may adopt
to comply with §§ 415(c) and 414(s), as
amended by CRA. Plan sponsors should
first review their plan documents and op-
eration to determine whether the plan al-
ready complies with §§ 415(c) and
414(s), as amended.
A. Model language for § 415(c)(3)
compensation definition
For limitation years beginning on and
after [enter the earlier of January 1,
2001, or the first day of the first limita-
tion year for which the plan was oper-
ated in accordance with the CRA
amendment of § 415(c)(3), but in no
case earlier than the first day of the
first limitation year beginning on or
after January 1, 1998], for purposes of
applying the limitations described in
section ____ of the plan, compensation
paid or made available during such
limitation years shall include elective
amounts that are not includible in the
gross income of the employee by rea-
son of § 132(f)(4).
(Note: The following language may
be adopted for plans that also use
§ 415(c)(3) compensation for other
purposes under the plan.)
This amendment shall also apply to the
definition of compensation for pur-
poses of section(s) ____ of the plan for
plan years beginning on and after
June 18, 200113422001–25 I.R.B.

[enter the earlier of January 1, 2001, or
the first day of the first plan year for
which these sections of the plan were
operated in accordance with the CRA
amendment of § 415(c)(3), but in no
case earlier than the first day of the
first plan year beginning on or after
January 1, 1998].
B. Model language for § 414(s) com-
pensation definition that excludes
amounts of compensation reduction
elected for qualified transportation
fringes
(Note: The following language should
be adopted only for a plan that either 1)
has been operated since the first day of
the first plan year beginning on or after
January 1, 1998 (or any subsequent
plan year beginning before January 1,
2001), or 2) has been operated since the
first day of the first plan year begin-
ning on or after January 1, 2001, by ex-
cluding from its definition of compen-
sation under § 414(s) any amount that
is contributed by the employer pur-
suant to a salary reduction agreement
and that is not includible in the em-
ployee’s gross income under § 125,
132(f), 402(e)(3), 402(h), or 403(b).
For plan years beginning on and after
[enter the earlier of January 1, 2001, or
the first day of the first plan year for
which the plan was operated in accor-
dance with the CRA amendment of
§ 414(s), but in no case earlier than the
first day of the first plan year begin-
ning on or after January 1, 1998], com-
pensation shall not include elective
amounts that are not includible in the
gross income of the employee under
§ 125, 132(f)(4), 402(e)(3), 402(h), or
403(b). This amendment shall apply
for purposes of section(s) _____ of the
plan.
2001–25 I.R.B.1343June 18, 2001

June 18, 200113442001–25 I.R.B.
New Alternatives for Defined
Benefit Master and Prototype
and Volume Submitter Plans
Announcement 2001–63
Rev. Rul. 98–1, 1998–1 C.B. 249, pro-
vides guidance concerning changes to
§ 415 of the Internal Revenue Code that
were made by the Uruguay Round Agree-
ments Act, which included the Retirement
Protection Act of 1994, and by the Small
Business Job Protection Act of 1996.
Section 415 limits the contributions and
benefits under qualified pension, profit-
sharing, etc., plans. Q&A-12 of Rev. Rul.
98–1 provides that a defined benefit plan
may provide that changes to
§ 415(b)(2)(E) do not apply to benefits
accrued before a certain date, which is re-
ferred to here as the “RPA ’94 Freeze
Date.” In addition, the pre-RPA ’94
Freeze Date accrued benefits are referred
to as “old-law benefits.” Q&A–14 of
Rev. Rul. 98–1 contains three methods for
applying the limitations in § 415(b) in a
defined benefit plan that does not apply
the changes to § 415(b)(2)(E) to old-law
benefits. (How and when the RPA ’94
Freeze Date and a participant’s old-law
benefit are determined are described in
Q&A–13 of Rev. Rul. 98–1.)
Previously, the Master and Prototype
program and the volume submitter pro-
gram have permitted only one of the three
methods (Method 2) described in
Q&A–14 of Rev. Rul. 98–1. These pro-
grams also have required the RPA ’94
Freeze Date to be the same date as the
plan’s § 417(e) effective date (i.e., the
plan’s date as of which the RPA ’94
changes to § 417(e)(3) apply). However,
commentators have requested the use of
all three methods in these programs.
They have also requested the use of dif-
ferent dates for the plan’s RPA ’94 Freeze
Date and the plan’s § 417(e) effective
date.
The Service is now allowing the use of
all three methods and the use of different
dates for the plan’s RPA ’94 Freeze Date
and the plan’s § 417(e) effective date.
The Service has revised Item #40 (Section
415 Limitation on Benefits) of the Febru-
ary 2000, version of the Defined Benefit
Listing of Required Modifications and In-
formation Package (the “DB LRM”) to
include all three methods described in
Q&A–14 of Rev. Rul. 98–1 and the use of
different dates for the plan’s RPA ’94
Freeze Date and the plan’s § 417(e) effec-
tive date. The Service is accepting these
revisions in requests for opinion letters
for master and prototype plans and advi-
sory letters for volume submitter speci-
men plans.
The revisions to DB LRM Item #40 are
posted to the Employee Plans Internet ad-
dress at www.irs.gov/ep.In addition, a
paper copy of those revisions to the DB
LRM may be obtained by writing to the In-
ternal Revenue Service at EP Rulings and
Agreements, Att’n: T:EP:RA:ICU, 1111
Constitution Ave., N.W., Washington, D.C.
20024 or by sending a fax to EP Rulings
and Agreements, Taxpayer Request, Att’n:
Ms. Nancy Arrington, 202-283-9554.
IRS/SSA Information Reporting
Program (IRP) Seminars
Announcement 2001–64
IRS and SSA Announce Year-End
Training for Employers/Payers
To help employers and payers who file
Information returns with year-end
wage/tax reporting, the Internal Revenue
Service/Martinsburg Computing Center
(MCC) and the Social Security Adminis-
tration (SSA) have arranged the following
training sessions on filing Forms 1042–S,
1098, 1099, 5498, W-2G, W-2, and re-
lated issues.
IRS Nationwide Tax Forums
Six three-day Nationwide Tax Forums
offer employers/payers detailed sessions
on a wide variety of year-end wage and
tax filing topics such as:
Electronic filing
Backup withholding and IRP penalties
Form 1042-S filing
Form W-2 filing
There is a nominal fee to attend a forum.
For more information, contact the
IRS/MCC IRP Call Site at 304-263-8700
between 8:30 a.m. and 4:30 p.m., EST,
Monday through Friday or E-Mail:
mccirp@irs.gov. The dates and locations
are as follows:
LocationDate
Philadelphia, PAJuly 10-12
Ft. Lauderdale, FLJuly 24-26
Dallas, TXAugust 14-16
Atlanta, GAAugust 21-23
Cleveland, OHSeptember 4-6
Las Vegas, NVSeptember 18-20
IRS/SSA Information Reporting Program
Seminars
Six IRP seminars for employers/payers
will be offered in one-day sessions, free
of charge. The morning session is similar
in content to the Nationwide Tax Forums,
but is condensed into a one-half day for-
mat. The afternoon session will be di-
rected toward software vendors that
would like more information about elec-
tronic filing with IRS and SSA.
Following is a schedule of seminar
sites and dates, as well as telephone num-
bers of the IRS office closest to the sites.
Please call the appropriate office for the
exact location and time or E-Mail:
mccirp@irs.gov.
Part IV. Items of General Interest
LocationDatePhoneFAX
Frederick, MDJuly 17304-263-8700304-264-5602
New York CityAugust 21212-436-1039212-436-1046
Denver, COSeptember 5303-446-1412303-446-1387
Raleigh/DurhamSeptember 6304-263-8700304-264-5602
Oakland, CASeptember 11510-637-2193510-637-2413
Seattle, WASeptember 13206-220-5300206-220-4391

Foundations Status of Certain
Organizations
Announcement 2001–66
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:
Abundant Changes Community
Outreach, Detroit, MI
Adventists Affirm, Inc.,
Berrien Springs, MI
After Hours Resource Services, Inc.,
Detroit, MI
All Because of Christ, Inc., Flora, IL
Always in Season, Inc., Myakka City, FL
Amazing Grace Community
Development Ctr., Detroit, MI
American Crusaders for the Education of
Youth, Lansing, MI
American Mission Training Foundation,
Inc., Waterford, MI
Animal Crafters, W. Bloomfield, MI
Animal Rescue & Relief Foundation of
Southwest Illinois, Inc.,
Belleville, IL
Athens Rodeo, Athens, IL
Austin Foundation, East Lansing, MI
Avant-Garde Ministries, Marenisco, MI
Baker Youth Foundation, Inc., Flint, MI
Beath Foundation, Richmond, VA
Bedford Flyers Softball League,
Temperance, MI
Belleville Fussball Club, Inc.,
Belleville, IL
Benton Harbor Athletic Association, Inc.,
Benton Harbor, MI
Beverly A. Mann Performing Arts Studio
& Craft Designs, Inc., Detroit, MI
Branch County Equine Enthusiasts,
Coldwater, MI
Brigham Young Family Association,
Salt Lake City, UT
Business United with Officers and Youth,
5 - Bouy 5, Detroit, MI
C & J Needham Career and Development
Training Institute, Detroit, MI
Cahokia Association for the
Tricentennial, Cahokia, IL
Campaign Reform Project,
Mount Kisco, NY
Capital City Preservation Trust,
Sacramento, CA
Caribbean American Cultural Center,
Oak Park, MI
Castle Acres Adult Foster Care, Inc.,
Iron River, MI
Central Mine M. E. Church Corp.,
Laurium, MI
Chelsea Film Society, Chelsea, MI
Chip Alumni Association of
Southwestern Michigan,
Kalamazoo, MI
Chippewa Valley Action Coalition,
Clinton Twp., MI
Christian Homecare Services, Inc.,
Lebanon, IL
Church Helping Urban Restoration of
Community & Home, Inc., Detroit, MI
Cincinnati Theological Society,
Cincinnati, OH
City Cab Company Youth and Scholarship
Fund Corporation, Detroit, MI
Community Concerns Alliance, Inc.,
Detroit, MI
Compassionate Heart Film Production
Company, Inc., Fullerton, CA
Consort of Voices, Inc., Holland, MI
Crawford County Crisis Pregnancy
Center, Inc., Robinson, IL
Creative Wellness Institute Corporation,
Scottsdale, AZ
Crittenton-DMC Health Services,
Rochester, MI
Delta Life Development Foundation of
Albany, Inc., Albany, GA
Detroit Betterment Division-Unit A,
Detroit, MI
Detroit Youth Endowment, Inc.,
Detroit, MI
Domestic Violence Intervention Program,
E. Lansing, MI
Double-O-Rhythm Double Dutch &
Dance Troupe, Muskegon, MI
Downriver Raiders Football Association,
Lincoln Park, MI
Easna Foundation, Berkley, MI
East St. Louis Community Awareness
Project, Belleville, IL
Eastside Community Development
Corporation, Monroe, MI
Emanuel First Housing Corp.,
Lansing, MI
Emerging Communities, Inc.,
Littleton, CO
Empowerment Health Care Systems, Inc.,
Detroit, MI
End the Homeless Network, Detroit, MI
Environmental Engineering Student
Society, East Lansing, MI
EREB Foundation, Inc., Atlanta, GA
Essex House Neighborhood Corporation,
Annapolis, MD
Everyday Art, Detroit, MI
Extended Hands Ministries, Inc.,
Detroit, MI
Fatherhood Foundation, Inc.,
Tempe, AZ
Ferndale Arts Council, Ferndale, MI
Financial Assistance in Transacting
Home Ownership, Inc., Oviedo, FL
Financial Enrichment Education
Foundation, Lauderhill, FL
Forrest Organization, Atow, OH
Foundation for Ecumenical Ministries in
Higher Education, Rochester Hills, MI
Friends of Artistry in Motion, Inc.,
Ferndale, MI
Friends of the Ott Preserve, Marshall, MI
From the Heart, Ann Arbor, MI
Gaelic League-Irish-American Club of
West Michigan, Grand Rapids, MI
Gallery O, Ltd., Evanston, IL
Genesee-Lapeer-Shiawassee Critical
Incident Stress Management Team,
Flint, MI
German-American Heritage Foundation
International, Harper Woods, MI
Gillis Foundation, Biloxi, MS
Godfrey Lee Organized Recreation for
Youth, Wyoming, MI
Government Intern Training Program,
Clinton Twp., MI
Great Lakes Institute for Economic
Initiative, Muskegon, MI
Greater New York Association of
Holocaust Survivors, Inc.,
Woodburgh, NY
Gross Pointe Baseball Organization, Inc.,
Grosse Pointe Park, MI
Hand Surgery Endowment Charitable
Foundation, Chicago, IL
Haven Ministries, Grand Rapids, MI
Healingworks Institute, Inc.,
Scottsdale, AZ
Helping Touch Foundation,
Barberton, OH
2001–25 I.R.B.1345June 18, 2001

Heritage Park I Neighborhood
Corporation, Annapolis, MD
Heritage Park II Neighborhood
Corporation, Annapolis, MD
Hispanics Against Aids, Inc.,
Grand Rapids, MI
Homeless Empowerment Relationship
Organization of Greater Flint, Inc.,
Flint, MI
Hope for Prisoners Ministries,
Springfield, IL
Howell Area Junior Football League,
Howell, MI
Human Resources and Services of
Michigan, Inc., Saginaw, MI
Huron Valley Christian Academy
Foundation, Inc., Ann Arbor, MI
In His Hands Ministries, Harrisburg, IL
Institute for Cooperation of Art and
Research, Inc., New York, NY
Institute of World Traditional Medicine,
Santa Monica, CA
Inter-Networks Multi Service Center,
Inc., Detroit, MI
Inward Bound, Inc., Rapid River, MI
Islamic Library of Dearborn,
Dearborn, MI
Jackson Avenue Community
Organization, Bronx, NY
Jerry Keiper Memorial Center for
Teacher Development, Champaign, IL
Joseph W. Samuels M.D. & Clarence E.
Thompson Scholarship Fund, Inc.,
Detroit, MI
Justice for Children-Michigan Chapter,
Southfield, MI
Kalamazoo Community Enrichment,
Kalamazoo, MI
Keep Coming Back, Lake Orion, MI
Kirk Family Gospel Singers,
Elizabethtown, KY
Land Trust of the Palm Beaches, Inc.,
West Palm Beach, FL
Life Choice, Inc., Detroit, MI
Link, Sturgis, MI
Livingston Citizens for Better Housing,
Howell, MI
L. J. H. J. Community Development
Corporation, Flint, MI
Love Joy and Peace Ministries,
Houston, TX
Lynn Dennis Memorial Bass Tournament,
Lansing, MI
Magalit, Ft. Worth, TX
Maiden House Ministry,
Highland Park, MI
Met-Rx Foundation for Health
Enhancement, Irvine, CA
Michigan Aviation Education
Foundation, Inc., Grand Haven, MI
Michigan Cancer Pain Initiative,
St. Clair Shores, MI
Michigan Indian Law Center,
Lansing, MI
Michigan Society for Cardiovascular and
Pulmonary Rehabilitation, Inc.,
Farmington Hills, MI
Michigan State University Black
Engineering Alumni Association,
Southfield, MI
Missing Childrens Network of Michigan,
Inc., Traverse City, MI
Mt. Superior Wilderness Institute, Inc.,
Marquette, MI
National Relief Network, Inc.,
Grand Rapids, MI
New J Senior Citizen Center, Inc.,
Lansing, MI
New Rise Non-Profit Housing
Corporation, Detroit, MI
Noah Productions, Urbana, IL
Northstar Housing Corporation,
Lansing, MI
Oakland Housing Advantage Non-Profit
Housing Corporation,
Grand Rapids, MI
Oakland Leadership Council, Inc., Troy, MI
Ogr Award of Excellence, Inc.,
Springfield, IL
One of Us, Inc., Detroit, MI
Operation Educate, Detroit, MI
Pankin Foundation Inc.,
Farmington Hills, MI
Parents Against Lead, Kalamazoo, MI
Partners in Service, Inc., Detroit, MI
Paul B. Henry Scholarship Committee,
Grand Rapids, MI
Pediatric Oncology Resource Team,
Grand Rapids, MI
People Centers U S A, Warren, MI
Ping Athletic Scholarship Fund,
Saline, MI
Pittman Memorial Non-Profit Housing
Corporation, Detroit, MI
Place for Learning, Inc., Riverhead, NY
Praisefest, Grand Rapids, MI
Project Founding Fathers, Highland, MI
Pyramid Program, Inc., Southfield, MI
Quincy Preserves, Inc., Quincy, IL
Ralph Bell Crusade, Inc., Port Huron, MI
Rapid River Band Boosters
Rapid River, MI
Ready About, Inc., W. Olive, MI
Reconciliation & Restoration Prison
Ministries, Southfield, MI
Recovery Zone, Pontiac, MI
Roy Bill Frakes Scholarship Fund,
Avon, IL
Run Around the World, Inc.,
Grand Rapids, MI
Ruth Resources United to Help
Fellowship Corporation, Flint, MI
Safety, Inc., Gladwin, MI
Serve Across America, Dallas, TX
Shiawassee Boxing Club, Inc.,
Owosso, MI
Shining Light Youth Bureau,
East St. Louis, IL
Side by Side Foundation,
Dearborn Hts., MI
Silent Cry, Inc., Los Angeles, CA
Smiles Foundation, Carrolton, IL
Solid Ice, Big Rapids, MI
Soundbyte Incorporated, Washington, DC
Speaking of Wildlife, Mason, MI
Specialty Foundation, Auburn Hills, MI
Spectrum Ringwood Apartments, Inc.,
River Vale, NJ
Spiritual Israel Ministries, Detroit, MI
St. James Community Development
Organization, Inc., Detroit, MI
Stop Pet Overpopulation, Inc.,
Port Huron, MI
Swifa Childrens Fire Safety House,
Mascoutah, IL
Taguchi Academy, Inc., Allen Park, MI
T C 3 - Tower Community Concerns
Committee, East Lansing, MI
Third Eye, Inc., Detroit, MI
Thorn Hospital Foundation, Hudson, MI
Tietjens Memorial Foundation,
Abilene, KS
Together Strong, Inc., Venice, CA
Tri-City Wood Carvers, Saginaw, MI
Tri-Valley Education Foundation, Inc.,
Downs, IL
Unlimited Resources, Inc.,
Southfield, MI
Urban Renewal Coalition, Detroit, MI
Urban Revival Foundation, Inc.,
Peoria, IL
Urban Scape Development Incorporated,
Grand Rapids, MI
Urban Solutions, Inc., Detroit, MI
Vandenberghe Foundation, Inc.,
Danville, CA
Veteran Association of Vietnam Republic,
Grand Rapids, MI
Victims for Victims, Mt. Clemons, MI
Village Potters Guild, Inc., Plymouth, MI
Warrendale Community Organization,
Detroit, MI
Washington 2000 Foundation,
Washington, IL
June 18, 200113462001–25 I.R.B.

Waterford Police Benevolent Fund,
Waterford, MI
West Michigan Gay Community Chorus,
Zeeland, MI
Western Michigan Health Services, Inc.,
Muskegon, MI
Wildside Rehabilitation and Education
Center, Eaton Rapids, MI
Women Involved in Giving Support,
Lake Orion, MI
Womens Auxiliary of the Womens
Opportunity House, Lansing, MI
Word Alive Outreach Ministries,
Detroit, MI
World Wide Apostolic Missions,
Mount Carmel, IL
If an organization listed above submits
information that warrants the renewal of
its classification as a public charity or as a
private operating foundation, the Internal
Revenue Service will issue a ruling or de-
termination letter with the revised classi-
fication as to foundation status. Grantors
and contributors may thereafter rely upon
such ruling or determination letter as pro-
vided in section 1.509(a)–7 of the Income
Tax Regulations. It is not the practice of
the Service to announce such revised clas-
sification of foundation status in the Inter-
nal Revenue Bulletin.
2001–25 I.R.B.1347June 18, 2001

June 18, 2001i2001–25 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

2001–25 I.R.B.iiJune 18, 2001
Numerical Finding List
1
Bulletins 2001–1 through 2001–24
Announcements:
2001–1, 2001–2 I.R.B. 277
2001–2, 2001–2 I.R.B. 277
2001–3, 2001–2 I.R.B. 278
2001–4, 2001–2 I.R.B. 286
2001–5, 2001–2 I.R.B. 286
2001–6, 2001–3 I.R.B. 357
2001–7, 2001–3 I.R.B. 357
2001–8, 2001–3 I.R.B. 357
2001–9, 2001–3 I.R.B. 357
2001–10, 2001–4 I.R.B. 431
2001–11, 2001–4 I.R.B. 432
2001–12, 2001–6 I.R.B. 526
2001–13, 2001–9 I.R.B. 752
2001–14, 2001–7 I.R.B. 648
2001–15, 2001–8 I.R.B. 715
2001–16, 2001–8 I.R.B. 715
2001–17, 2001–8 I.R.B. 716
2001–18, 2001–10 I.R.B. 791
2001–19, 2001–10 I.R.B. 791
2001–20, 2001–8 I.R.B. 716
2001–21, 2001–9 I.R.B. 752
2001–22, 2001–11 I.R.B. 895
2001–23, 2001–10 I.R.B. 791
2001–24, 2001–10 I.R.B. 793
2001–25, 2001–11 I.R.B. 895
2001–26, 2001–11 I.R.B. 896
2001–27, 2001–11 I.R.B. 897
2001–28, 2001–13 I.R.B. 975
2001–29, 2001–14 I.R.B. 1014
2001–30, 2001–15 I.R.B. 1065
2001–31, 2001–17 I.R.B. 1113
2001–32, 2001–17 I.R.B. 1113
2001–33, 2001–17 I.R.B. 1137
2001–34, 2001–16 I.R.B. 1087
2001–35, 2001–16 I.R.B. 1087
2001–36, 2001–16 I.R.B. 1089
2001–37, 2001–16 I.R.B. 1090
2001–38, 2001–17 I.R.B. 1138
2001–39, 2001–17 I.R.B. 1141
2001–40, 2001–17 I.R.B. 1141
2001–41, 2001–18 I.R.B. 1147
2001–42, 2001–18 I.R.B. 1147
2001–43, 2001–18 I.R.B. 1147
2001–44, 2001–18 I.R.B. 1148
2001–45, 2001–18 I.R.B. 1148
2001–46, 2001–19 I.R.B. 1165
2001–47, 2001–19 I.R.B. 1165
2001–48, 2001–19 I.R.B. 1168
2001–49, 2001–20 I.R.B. 1183
2001–50, 2001–20 I.R.B. 1184
2001–51, 2001–20 I.R.B. 1185
2001–52, 2001–20 I.R.B. 1186
2001–53, 2001–20 I.R.B. 1186
2001–54, 2001–21 I.R.B. 1284
2001–55, 2001–21 I.R.B. 1284
2001–56, 2001–21 I.R.B. 1286
2001–57, 2001–20 I.R.B. 1187
2001–58, 2001–22 I.R.B. 1295
2001–59, 2001–23 I.R.B. 1331
2001–60, 2001–21 I.R.B. 1287
2001–61, 2001–22 I.R.B. 1296
2001–62, 2001–24 I.R.B. 1337
Court Decisions:
2069, 2001–21 I.R.B. 1191
Notices:
2001–1, 2001–2 I.R.B. 261
2001–2, 2001–2 I.R.B. 265
2001–3, 2001–2 I.R.B. 267
2001–4, 2001–2 I.R.B. 267
2001–5, 2001–3 I.R.B. 327
2001–6, 2001–3 I.R.B. 327
2001–7, 2001–4 I.R.B. 374
2001–8, 2001–4 I.R.B. 374
2001–9, 2001–4 I.R.B. 375
2001–10, 2001–5 I.R.B. 459
2001–11, 2001–5 I.R.B. 464
2001–12, 2001–3 I.R.B. 328
2001–13, 2001–6 I.R.B. 514
2001–14, 2001–6 I.R.B. 516
2001–15, 2001–7 I.R.B. 589
2001–16, 2001–9 I.R.B. 730
2001–17, 2001–9 I.R.B. 730
2001–18, 2001–9 I.R.B. 731
2001–19, 2001–10 I.R.B. 784
2001–20, 2001–11 I.R.B. 818
2001–21, 2001–11 I.R.B. 818
2001–22, 2001–12 I.R.B. 911
2001–23, 2001–12 I.R.B. 911
2001–24, 2001–12 I.R.B. 912
2001–25, 2001–13 I.R.B. 941
2001–26, 2001–13 I.R.B. 942
2001–27, 2001–13 I.R.B. 942
2001–28, 2001–13 I.R.B. 944
2001–29, 2001–14 I.R.B. 989
2001–30, 2001–14 I.R.B. 989
2001–31, 2001–17 I.R.B. 1093
2001–32, 2001–18 I.R.B. 1146
2001–33, 2001–19 I.R.B. 1155
2001–34, 2001–23 I.R.B. 1302
2001–35, 2001–23 I.R.B. 1314
2001–36, 2001–24 I.R.B. 1334
2001–38, 2001–24 I.R.B. 1334
Proposed Regulations:
LR–230–76, 2001–13 I.R.B. 945
REG–209461–79, 2001–8 I.R.B. 712
REG–246256–96, 2001–8 I.R.B. 713
REG–251701–96, 2001–4 I.R.B. 396
REG–101520–97, 2001–15 I.R.B. 1057
REG–106030–98, 2001–11 I.R.B. 820
REG–106446–98, 2001–13 I.R.B. 945
REG–106542–98, 2001–5 I.R.B. 473
REG–121928–98, 2001–6 I.R.B. 520
REG–109481–99, 2001–13 I.R.B. 961
REG–111835–99, 2001–11 I.R.B. 834
REG–114998–99, 2001–14 I.R.B. 992
REG–115560–99, 2001–14 I.R.B. 993
REG–101739–00, 2001–14 I.R.B. 996
REG–103320–00, 2001–8 I.R.B. 714
REG–104683–00, 2001–4 I.R.B. 407
REG–104876–00, 2001–14 I.R.B. 998
REG–105801–00, 2001–13 I.R.B. 965
REG–105946–00, 2001–16 I.R.B. 1069
REG–106513–00, 2001–16 I.R.B. 1076
REG–106702–00, 2001–4 I.R.B. 424
REG–106791–00, 2001–6 I.R.B. 521
REG–106892–00, 2001–15 I.R.B. 1060
REG–107047–00, 2001–14 I.R.B. 1002
REG–107101–00, 2001–16 I.R.B. 1083
REG–107175–00, 2001–13 I.R.B. 971
REG–107176–00, 2001–4 I.R.B. 428
REG–107186–00, 2001–13 I.R.B. 973
REG–107566–00, 2001–3 I.R.B. 346
REG–110374–00, 2001–12 I.R.B. 915
Proposed Regulations—Continued:
REG–110659–00, 2001–12 I.R.B. 917
REG–114082–00, 2001–7 I.R.B. 629
REG–114083–00, 2001–7 I.R.B. 630
REG–114084–00, 2001–7 I.R.B. 633
REG–116468–00, 2001–6 I.R.B. 522
REG–119352–00, 2001–6 I.R.B. 525
REG–121109–00, 2001–15 I.R.B. 1064
REG–125237–00, 2001–12 I.R.B. 919
REG–126100–00, 2001–11 I.R.B. 862
REG–129608–00, 2001–14 I.R.B. 1011
REG–130477–00, 2001–11 I.R.B. 865
REG–130481–00, 2001–11 I.R.B. 865
REG–119436–01, 2001–20 I.R.B. 1183
Railroad Retirement Quarterly Rates:
2001–2, I.R.B. 258
2001–15, I.R.B. 1054
Revenue Procedures:
2001–1, 2001–1 I.R.B. 1
2001–2, 2001–1 I.R.B. 79
2001–3, 2001–1 I.R.B. 111
2001–4, 2001–1 I.R.B. 121
2001–5, 2001–1 I.R.B. 164
2001–6, 2001–1 I.R.B. 194
2001–7, 2001–1 I.R.B. 236
2001–8, 2001–1 I.R.B. 239
2001–9, 2001–3 I.R.B. 328
2001–10, 2001–2 I.R.B. 272
2001–11, 2001–2 I.R.B. 275
2001–12, 2001–3 I.R.B. 335
2001–13, 2001–3 I.R.B. 337
2001–14, 2001–3 I.R.B. 343
2001–15, 2001–5 I.R.B. 465
2001–16, 2001–4 I.R.B. 376
2001–17, 2001–7 I.R.B. 589
2001–18, 2001–8 I.R.B. 708
2001–19, 2001–9 I.R.B. 732
2001–20, 2001–9 I.R.B. 738
2001–21, 2001–9 I.R.B. 742
2001–22, 2001–9 I.R.B. 745
2001–23, 2001–10 I.R.B. 784
2001–24, 2001–10 I.R.B. 788
2001–25, 2001–12 I.R.B. 913
2001–26, 2001–17 I.R.B. 1093
2001–27, 2001–19 I.R.B. 1155
2001–28, 2001–19 I.R.B. 1156
2001–29, 2001–19 I.R.B. 1160
2001–30, 2001–19 I.R.B. 1163
2001–31, 2001–20 I.R.B. 1170
2001–32, 2001–21 I.R.B. 1197
2001–33, 2001–23 I.R.B. 1322
2001–34, 2001–22 I.R.B. 1293
2001–35, 2001–22 I.R.B. 1293
2001–36, 2001–23 I.R.B. 1326
2001–37, 2001–23 I.R.B. 1327
2001–38, 2001–24 I.R.B. 1335
Revenue Rulings:
2001–1, 2001–9 I.R.B. 726
2001–2, 2001–2 I.R.B. 255
2001–3, 2001–3 I.R.B. 319
2001–4, 2001–3 I.R.B. 295
2001–5, 2001–5 I.R.B. 451
2001–6, 2001–6 I.R.B. 491
2001–7, 2001–7 I.R.B. 541
2001–8, 2001–9 I.R.B. 726
2001–9, 2001–8 I.R.B. 652
2001–10, 2001–10 I.R.B. 755
1
A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 2000–27 through
2000–52 is in Internal Revenue Bulletin 2001–1,
dated January 2, 2001.

June 18, 2001iii2001–25 I.R.B.
Revenue Rulings—Continued:
2001–11, 2001–10 I.R.B. 780
2001–12, 2001–11 I.R.B. 811
2001–13, 2001–12 I.R.B. 898
2001–14, 2001–12 I.R.B. 898
2001–15, 2001–13 I.R.B. 922
2001–16, 2001–13 I.R.B. 936
2001–17, 2001–15 I.R.B. 1052
2001–18, 2001–17 I.R.B. 1092
2001–19, 2001–18 I.R.B. 1143
2001–20, 2001–18 I.R.B. 1143
2001–21, 2001–18 I.R.B. 1144
2001–22, 2001–19 I.R.B. 1152
2001–23, 2001–20 I.R.B. 1169
2001–24, 2001–22 I.R.B. 1290
2001–25, 2001–22 I.R.B. 1291
2001–26, 2001–23 I.R.B. 1297
2001–27, 2001–23 I.R.B. 1298
Treasury Decisions:
8910, 2001–2 I.R.B. 258
8911, 2001–3 I.R.B. 321
8912, 2001–5 I.R.B. 452
8913, 2001–3 I.R.B. 300
8914, 2001–8 I.R.B. 653
8915, 2001–4 I.R.B. 359
8916, 2001–4 I.R.B. 360
8917, 2001–7 I.R.B. 538
8918, 2001–4 I.R.B. 372
8919, 2001–6 I.R.B. 505
8920, 2001–8 I.R.B. 654
8921, 2001–7 I.R.B. 532
8922, 2001–6 I.R.B. 508
8923, 2001–6 I.R.B. 485
8924, 2001–6 I.R.B. 489
8925, 2001–6 I.R.B. 496
8926, 2001–6 I.R.B. 492
8927, 2001–11 I.R.B. 807
8928, 2001–8 I.R.B. 685
8929, 2001–10 I.R.B. 756
8930, 2001–5 I.R.B. 433
8931, 2001–7 I.R.B. 542
8932, 2001–11 I.R.B. 813
8933, 2001–11 I.R.B. 794
8934, 2001–12 I.R.B. 904
8935, 2001–8 I.R.B. 702
8936, 2001–9 I.R.B. 720
8937, 2001–11 I.R.B. 806
8938, 2001–13 I.R.B. 929
8939, 2001–12 I.R.B. 899
8940, 2001–15 I.R.B. 1016
8941, 2001–14 I.R.B. 977
8942, 2001–13 I.R.B. 929
8943, 2001–15 I.R.B. 1054
8944, 2001–16 I.R.B. 1067
8945, 2001–23 I.R.B. 1300
8946, 2001–24 I.R.B. 1332

2001–25 I.R.B.ivJune 18, 2001
Finding List of Current Actions on
Previously Published Items
1
Bulletins 2001–1 through 2001–24
Announcements:
98–99
Modified by
Ann. 2001–9, 2001–3 I.R.B. 357
99–79
Superseded by
Ann. 2001–3, 2001–2 I.R.B. 278
2000–78
Obsoleted by
T.D. 8933, 2001–11 I.R.B. 794
2000–97
Corrected by
Ann. 2001–7, 2001–3 I.R.B. 357
Cumulative Bulletin:
1998–2
Corrected by
Ann. 2001–5, 2001–2 I.R.B. 286
Notices:
84–37
Modified by
Rev. Proc. 2001–1, 2001–1 I.R.B. 1
87–49
Modified by
Notice 2001–14, 2001–6 I.R.B. 516
94–3
Modified by
T.D. 8933, 2001–11 I.R.B. 794
96–13
Modified by
Rev. Proc. 2001–1, 2001–1 I.R.B. 1
97–19
Modified by
Rev. Proc. 2001–1, 2001–1 I.R.B. 1
98–39
Modified by
Notice 2001–9, 2001–4 I.R.B. 375
99–40
Modified by
Notice 2001–9, 2001–4 I.R.B. 375
99–53
Modified and superseded by
Notice 2001–7, 2001–4 I.R.B. 374
2000–21
Superseded by
Notice 2001–1, 2001–2 I.R.B. 261
2000–22
Modified and superseded by
Notice 2001–8, 2001–4 I.R.B. 374
2000–26
Modified by
Notice 2001–22, 2001–12 I.R.B. 911
2000–33
Obsoleted by
T.D. 8945, 2001–23 I.R.B. 1300
2000–43
Extended by
Notice 2001–13, 2001–6 I.R.B. 514
Proposed Regulations:
EE–130–86
Partially withdrawn by
REG–209461–79, 2001–8 I.R.B. 712
REG–106030–98
Corrected by
Ann. 2001–30, 2001–15 I.R.B. 1065
REG–106542–98
Corrected by
Ann. 2001–24, 2001–10 I.R.B. 793
REG–116733–98
Withdrawn by
Ann. 2001–11, 2001–4 I.R.B. 432
REG–105235–99
Corrected by
Ann. 2001–52, 2001–20 I.R.B. 1186
REG–116048–99
Withdrawn by
Ann. 2001–27, 2001–11 I.R.B. 897
REG–116050–99
Corrected by
Ann. 2001–51, 2001–20 I.R.B. 1185
REG–104683–00
Corrected by
Ann. 2001–42, 2001–18 I.R.B. 1147
REG–106702–00
Corrected by
Ann. 2001–28, 2001–13 I.R.B. 975
REG–110374–00
Corrected by
Ann. 2001–44, 2001–18 I.R.B. 1148
REG–126100–00
Corrected by
Ann. 2001–50, 2001–20 I.R.B. 1184
Revenue Procedures:
75–21
Modified and superseded by
Rev. Proc. 2001–28, 2001–19 I.R.B. 1156
75–28
Modified and superseded by
Rev. Proc. 2001–29, 2001–19 I.R.B. 1160
76–30
Modified and superseded by
Rev. Proc. 2001–28, 2001–19 I.R.B. 1156
79–48
Modified and superseded by
Rev. Proc. 2001–28, 2001–19 I.R.B. 1156
Rev. Proc. 2001–29, 2001–19 I.R.B. 1160
83–87
Superseded by
Rev. Proc. 2001–15, 2001–5 I.R.B. 465
90–18
Amplified and superseded by
Rev. Proc. 2001–18, 2001–8 I.R.B. 708
92–19
Superseded by
Rev. Proc. 2001–15, 2001–5 I.R.B. 465
96–15
Modified by
Ann. 2001–22, 2001–11 I.R.B. 895
96–17
Modified by
Rev. Proc. 2001–9, 2001–3 I.R.B. 328
Revenue Procedures—Continued:
97–25
Superseded by
Rev. Proc. 2001–31, 2001–20 I.R.B. 1170
99–18
Modified and superseded by
Rev. Proc. 2001–21, 2001–9 I.R.B. 742
99–47
Superseded by
Rev. Proc. 2001–16, 2001–4 I.R.B. 376
99–49
Modified and amplified by
Notice 2001–23, 2001–12 I.R.B. 911
Rev. Proc. 2001–10, 2001–2 I.R.B. 272
Rev. Proc. 2001–23, 2001–10 I.R.B. 784
Rev. Proc. 2001–24, 2001–10 I.R.B. 788
Rev. Proc. 2001–25, 2001–12 I.R.B. 913
Rev. Rul. 2001–4, 2001–3 I.R.B.295
Rev. Rul. 2001–8, 2001–9 I.R.B. 726
2000–1
Superseded by
Rev. Proc. 2001–1, 2001–1 I.R.B. 1
2000–2
Superseded by
Rev. Proc. 2001–2, 2001–1 I.R.B. 79
2000–3
Superseded by
Rev. Proc. 2001–3, 2001–1 I.R.B. 111
2000–4
Superseded by
Rev. Proc. 2001–4, 2001–1 I.R.B. 121
2000–5
Superseded by
Rev. Proc. 2001–5, 2001–1 I.R.B. 164
2000–6
Superseded by
Rev. Proc. 2001–6, 2001–1 I.R.B. 194
2000–7
Superseded by
Rev. Proc. 2001–7, 2001–1 I.R.B. 236
2000–8
Superseded by
Rev. Proc. 2001–8, 2001–1 I.R.B. 239
2000–14
Supplemented by
Rev. Proc. 2001–27, 2001–19 I.R.B. 1155
2000–16
Modified and superseded by
Rev. Proc. 2001–17, 2001–7 I.R.B. 589
2000–21
Obsoleted by
Rev. Proc. 2001–35, 2001–22 I.R.B. 1293
2000–22
Modified and superseded by
Rev. Proc. 2001–10, 2001–2 I.R.B. 272
2000–23
Superseded by
Rev. Proc. 2001–26, 2001–17 I.R.B. 1093
2000–25
Superseded by
Rev. Proc. 2001–32, 2001–21 I.R.B. 1197
2000–27
Modified by
Rev. Proc. 2001–6, 2001–1 I.R.B. 194
1
A cumulative list of current actions on previously
published items in Internal Revenue Bulletins
2000–27 through 2000–52 is in Internal Revenue
Bulletin 2001–1, dated January 2, 2001.

June 18, 2001v2001–25 I.R.B.
Revenue Procedures—Continued:
2000–46
Superseded by
Rev. Proc. 2001–3, 2001–1 I.R.B. 111
2000–47
Superseded by
Rev. Proc. 2001–3, 2001–1 I.R.B. 111
2001–3
Corrected by
Ann. 2001–25, 2001–11 I.R.B. 895
Section 5.01 revoked by
Rev. Proc. 2001–30, 2001–19 I.R.B. 1163
2001–8
Modified by
Rev. Proc. 2001–17, 2001–7 I.R.B. 589
2001–13
Clarified by
Notice 2001–12, 2001–3 I.R.B. 328
2001–26
Corrected by
Ann. 2001–59, 2001–23 I.R.B. 1331
2001–30
Modified by
Rev. Proc. 2001–34, 2001–22 I.R.B. 1293
Revenue Rulings:
55–747
Revoked by
Notice 2001–10, 2001–5 I.R.B. 459
64–328
Modified by
Notice 2001–10, 2001–5 I.R.B. 459
66–110
Modified by
Notice 2001–10, 2001–5 I.R.B. 459
71–52
Obsoleted by
Notice 2001–14, 2001–6 I.R.B. 516
85–30
Clarified by
Rev. Rul. 2001–8, 2001–9 I.R.B. 726
88–95
Clarified by
Rev. Rul. 2001–8, 2001–9 I.R.B. 726
92–19
Supplemented in part by
Rev. Rul. 2001–11, 2001–10 I.R.B. 780
2000–56
Corrected by
Ann. 2001–19, 2001–10 I.R.B. 791
2001–4
Modified by
Notice 2001–23, 2001–12 I.R.B. 911
Treasury Decisions:
7530
Removed by
T.D. 8938, 2001–13 I.R.B. 929
8757
Revised by
T.D. 8941, 2001–14 I.R.B. 977
8881
Corrected by
Ann. 2001–55, 2001–21 I.R.B. 1284
8889
Corrected by
Ann. 2001–4, 2001–2 I.R.B. 286
Treasury Decisions—Continued:
8912
Corrected by
Ann. 2001–40, 2001–17 I.R.B. 1141
8913
Corrected by
Ann. 2001–26, 2001–11 I.R.B. 896
8916
Corrected by
Ann. 2001–41, 2001–18 I.R.B. 1147
8921
Corrected by
Ann. 2001–43, 2001–18 I.R.B. 1147
8929
Corrected by
Ann. 2001–56, 2001–21 I.R.B. 1286
8931
Technically amended by
Ann. 2001–37, 2001–16 I.R.B. 1090
8933
Corrected by
Ann. 2001–31, 2001–17 I.R.B. 1113
8940
Corrected by
Ann. 2001–53, 2001–20 I.R.B. 1186

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