PART III. PROCESSING

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 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 confusion. 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

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.

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 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 substance has been included in regulations subsequently 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Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings).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 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 period of time in separate rulings. If

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.

203

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 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.

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.

Revenue Procedures—Continued

95–35A, 1995–40 I.R.B. 38 95–36, 1995–33 I.R.B. 24 95–37, 1995–34 I.R.B. 21 95–38, 1995–34 I.R.B. 25 95–39, 1995–35 I.R.B. 17 95–40, 1995–36 I.R.B. 21 95–41, 1995–36 I.R.B. 28 95–42, 1995–35 I.R.B. 20 95–43, 1995–36 I.R.B. 31 95–44, 1995–42 I.R.B. 9 95–45, 1995–44 I.R.B. 22 95–46, 1995–46 I.R.B. 13 95–47, 1995–47 I.R.B. 12 95–48, 1995–47 I.R.B. 13 95–49, 1995–50 I.R.B. 5 95–50, 1995–50 I.R.B. 16 95–51, 1995–51 I.R.B. 6 95–52, 1995–51 I.R.B. 14 95–53, 1995–52 I.R.B. 22 95–54, 1995–52 I.R.B. 27 95–55, 1995–52 I.R.B. 34

Revenue Rulings:

95–29A, 1995–28 I.R.B. 4 95–48, 1995–27 I.R.B. 5 95–49, 1995–29 I.R.B. 4 95–50, 1995–30 I.R.B. 4 95–51, 1995–32 I.R.B. 4 95–52, 1995–34 I.R.B. 16 95–53, 1995–34 I.R.B. 17 95–54, 1995–35 I.R.B. 5 95–55, 1995–35 I.R.B. 13 95–56, 1995–36 I.R.B. 20 95–57, 1995–35 I.R.B. 5 95–58, 1995–36 I.R.B. 16 95–59, 1995–35 I.R.B. 10 95–60, 1995–35 I.R.B. 7 95–61, 1995–35 I.R.B. 6 95–62, 1995–36 I.R.B. 14 95–63, 1995–37 I.R.B. 4 95–64, 1995–38 I.R.B. 4 95–65, 1995–39 I.R.B. 4 95–66, 1995–40 I.R.B. 4 95–67, 1995–41 I.R.B. 29 95–68, 1995–42 I.R.B. 5 95–69, 1995–42 I.R.B. 4 95–70, 1995–43 I.R.B. 4 95–71, 1995–42 I.R.B. 7 95–72, 1995–42 I.R.B. 4 95–73, 1995–45 I.R.B. 6 95–74, 1995–46 I.R.B. 6 95–75, 1995–46 I.R.B. 8 95–76, 1995–47 I.R.B. 5 95–77, 1995–47 I.R.B. 6 95–78, 1995–49 I.R.B. 6 95–79, 1995–49 I.R.B. 4 95–80, 1995–51 I.R.B. 4 95–81, 1995–52 I.R.B. 6

Numerical Finding List ¹

Bulletins 1995–27 through 1995–52

Announcements:

95–54, 1995–27 I.R.B. 39 95–55, 1995–27 I.R.B. 39 95–56, 1995–27 I.R.B. 39 95–57, 1995–28 I.R.B. 13 95–58, 1995–29 I.R.B. 13 95–59, 1995–31 I.R.B. 29 95–60, 1995–31 I.R.B. 11 95–61, 1995–32 I.R.B. 54 95–62, 1995–32 I.R.B. 76 95–63, 1995–32 I.R.B. 76 95–64, 1995–32 I.R.B. 30 95–65, 1995–33 I.R.B. 25 95–66, 1995–33 I.R.B. 25 95–67, 1995–34 I.R.B. 28 95–68, 1995–34 I.R.B. 28 95–69, 1995–34 I.R.B. 31 95–70, 1995–35 I.R.B. 22 95–71, 1995–35 I.R.B. 22 95–72, 1995–36 I.R.B. 33 95–73, 1995–37 I.R.B. 50 95–74, 1995–37 I.R.B. 50 95–75, 1995–37 I.R.B. 51 95–76, 1995–38 I.R.B. 48 95–77, 1995–38 I.R.B. 49 95–78, 1995–39 I.R.B. 19 95–79, 1995–40 I.R.B. 44 95–80, 1995–40 I.R.B. 44 95–81, 1995–41 I.R.B. 34 95–82, 1995–41 I.R.B. 37 95–83, 1995–42 I.R.B. 11 95–84, 1995–42 I.R.B. 11 95–85, 1995–42 I.R.B. 12 95–86, 1995–44 I.R.B. 27 95–87, 1995–43 I.R.B. 8 95–88, 1995–43 I.R.B. 8 95–89, 1995–43 I.R.B. 8 95–90, 1995–43 I.R.B. 9 95–91, 1995–44 I.R.B. 33 95–92, 1995–45 I.R.B. 14 95–93, 1995–46 I.R.B. 17 95–94, 1995–46 I.R.B. 17 95–95, 1995–47 I.R.B. 18 95–96, 1995–47 I.R.B. 18 95–97, 1995–47 I.R.B. 19 95–98, 1995–47 I.R.B. 19 95–99, 1995–48 I.R.B. 10 95–100, 1995–48 I.R.B. 10 95–101, 1995–49 I.R.B. 10 95–102, 1995–50 I.R.B. 17 95–103, 1995–50 I.R.B. 17 95–104, 1995–51 I.R.B. 21 95–105, 1995–51 I.R.B. 21 95–106, 1995–51 I.R.B. 21 95–107, 1995–52 I.R.B. 37

See footnote at end of list.

Notices:

95–41, 1995–28 I.R.B. 5 95–42, 1995–31 I.R.B. 4 95–43, 1995–33 I.R.B. 22 95–44, 1995–33 I.R.B. 23 95–45, 1995–34 I.R.B. 20 95–46, 1995–34 I.R.B. 20 95–47, 1995–35 I.R.B. 17 95–48, 1995–36 I.R.B. 21 95–49, 1995–39 I.R.B. 18 95–50, 1995–42 I.R.B. 8 95–51, 1995–42 I.R.B. 8 95–52, 1995–43 I.R.B. 7 95–53, 1995–44 I.R.B. 21 95–54, 1995–44 I.R.B. 21 95–55, 1995–45 I.R.B. 11 95–56, 1995–45 I.R.B. 11 95–57, 1995–45 I.R.B. 12 95–58, 1995–46 I.R.B. 12 95–59, 1995–46 I.R.B. 12 95–60, 1995–47 I.R.B. 9 95–61, 1995–47 I.R.B. 10 95–62, 1995–47 I.R.B. 12 95–63, 1995–48 I.R.B. 8 95–64, 1995–50 I.R.B. 5 95–65, 1995–50 I.R.B. 5 95–66, 1995–51 I.R.B. 19 95–67, 1995–52 I.R.B. 35

Proposed Regulations:

CO–19–95, 1995–38 I.R.B. 43 CO–24–95, 1995–32 I.R.B. 53 95–87, 1995–43 I.R.B. 8 IA–10–95, 1995–34 I.R.B. 27 IA–30–95, 1995–45 I.R.B. 13 INTL–75–92, 1995–40 I.R.B. 39 INTL–24–94, 1995–27 I.R.B. 33 PS–268–82, 1995–31 I.R.B. 5 PS–29–92, 1995–36 I.R.B. 32 PS–34–92, 1995–47 I.R.B. 15 PS–25–94, 1995–38 I.R.B. 47 PS–54–94, 1995–37 I.R.B. 48 PS–8–95, 1995–39 I.R.B. 19

Public Laws:

104–7, 1995–29 I.R.B. 5

Railroad Retirement Quarterly Rate:

1995–40 I.R.B. 37

Revenue Procedures:

95–29A, 1995–30 I.R.B. 5 95–30, 1995–27 I.R.B. 9 95–31, 1995–28 I.R.B. 5 95–32, 1995–28 I.R.B. 6 95–33, 1995–28 I.R.B. 7 95–34, 1995–29 I.R.B. 7 95–35, 1995–32 I.R.B. 51

204

Numerical Finding List ¹ —Continued

Bulletins 1995–27 through 1995–52

Revenue Rulings—Continued

95–82, 1995–52 I.R.B. 7 95–83, 1995–52 I.R.B. 5

Social Security Contributions & Benefit Base:

1995–46 I.R.B. 16

Treasury Decisions:

8597, 1995–32 I.R.B. 6 8598, 1995–32 I.R.B. 47 8599, 1995–33 I.R.B. 5 8600, 1995–33 I.R.B. 10 8601, 1995–33 I.R.B. 8 8602, 1995–34 I.R.B. 5 8603, 1995–34 I.R.B. 18 8604, 1995–35 I.R.B. 9 8605, 1995–36 I.R.B. 17 8606, 1995–36 I.R.B. 5 8607, 1995–36 I.R.B. 8 8608, 1995–36 I.R.B. 10 8609, 1995–37 I.R.B. 5 8610, 1995–37 I.R.B. 13 8611, 1995–37 I.R.B. 20 8612, 1995–38 I.R.B. 7 8613, 1995–38 I.R.B. 31 8614, 1995–38 I.R.B. 4 8615, 1995–39 I.R.B. 5 8616, 1995–39 I.R.B. 7 8617, 1995–39 I.R.B. 9 8618, 1995–40 I.R.B. 4 8619, 1995–41 I.R.B. 4 8620, 1995–41 I.R.B. 25 8621, 1995–43 I.R.B. 5 8622, 1995–44 I.R.B. 5 8623, 1995–45 I.R.B. 4 8624, 1994–45 I.R.B. 8 8625, 1995–46 I.R.B. 10 8626, 1995–46 I.R.B. 4 8627, 1995–48 I.R.B. 4 8628, 1995–52 I.R.B. 9 8629, 1995–52 I.R.B. 14

Treasury Department Directives:

15–42, 1995–41 I.R.B. 32 15–43, 1995–36 I.R.B. 31

Treasury Department Orders:

150–01, 1995–44 I.R.B. 23

1A cumulative list of all Revenue Rulings, Revenue Procedures, Treasury Decisions, etc., published in Internal Revenue Bulletins 1995–1 through 1995–26 will be found in Internal Revenue Bulletin 1995–27, dated July 3, 1995.

205

Revenue Rulings—Continued

57–490 Obsoleted by 95–71, 1995–42 I.R.B. 7

58–9 Obsoleted by 95–71, 1995–42 I.R.B. 7

58–241 Obsoleted by 95–71, 1995–42 I.R.B. 7

58–391 Obsoleted by 95–71, 1995–42 I.R.B. 7

63–125 Obsoleted by 95–71, 1995–42 I.R.B. 7

64–100 Obsoleted by 95–71, 1995–42 I.R.B. 7

64–239 Obsoleted by 95–71, 1995–42 I.R.B. 7

64–257 Obsoleted by 95–71, 1995–42 I.R.B. 7

65–30 Obsoleted by 95–71, 1995–42 I.R.B. 7

66–81 Obsoleted by 95–71, 1995–42 I.R.B. 7

66–306 Obsoleted by 95–71, 1995–42 I.R.B. 7

66–327 Obsoleted by 95–71, 1995–42 I.R.B. 7

67–269 Obsoleted by 95–71, 1995–42 I.R.B. 7

68–21 Obsoleted by 95–71, 1995–42 I.R.B. 7

68–294 Obsoleted by 95–71, 1995–42 I.R.B. 7

68–358 Obsoleted by 95–71, 1995–42 I.R.B. 7

68–457 Obsoleted by 95–71, 1995–42 I.R.B. 7

Finding List of Current Action on Previously Published Items ¹

Bulletins 1995–27 through 1995–52

*Denotes entry since last publication

Revenue Procedures:

71–38 Obsoleted by 95–44, 1995–42 I.R.B. 9

72–15 Obsoleted by 95–44, 1995–42 I.R.B. 9

82–20 Obsoleted by 95–43, 1995–36 I.R.B. 31

82–59 Obsoleted by 95–44, 1995–42 I.R.B. 9

83–23 Supplemented by 95–48, 1995–47 I.R.B. 13

89–9 Modified by 95–34, 1995–29 I.R.B. 7

89–13 Modified by 95–34, 1995–29 I.R.B. 7 95–42, 1995–35 I.R.B. 20

90–55 Obsoleted by 95–45, 1995–44 I.R.B. 22

92–10 Clarified by 95–52, 1995–51 I.R.B. 14

92–16 Modified & Superseded by 95–52, 1995–51 I.R.B. 14

93–12 Modified by 95–34, 1995–29 I.R.B. 7

93–38 Supplemented by 95–31, 1995–28 I.R.B. 5

93–39 Modified by 95–34, 1995–29 I.R.B. 7

93–42 Modified by 95–34, 1995–29 I.R.B. 7

93–47 Modified by 95–34, 1995–29 I.R.B. 7

See footnote at end of list.

Revenue Procedure—Continued

94–13 Modified by 95–34, 1995–29 I.R.B. 7

94–19 Superseded by 95–52, 1995–51 I.R.B. 14

94–35 Superseded by 95–30, 1995–27 I.R.B. 9

94–49 Modified by 95–33, 1995–28 I.R.B. 7

94–63 Superseded by 95–49, 1995–50 I.R.B. 5

94–66 Obsoleted in part by 95–32, 1995–28 I.R.B. 6

94–73 Superseded by 95–54, 1995–52 I.R.B. 27 95–3 Amplified by Notice 95–45, 1995–34 I.R.B. 20 95–50, 1995–50 I.R.B. 16

95–8 Modified by 95–34, 1995–29 I.R.B. 7

95–29 Modified and Amplified by 95–29A, 1995–30 I.R.B. 5

95–35 Modified in part by 95–35A, 1995–40 I.R.B. 38

Revenue Rulings:

54–171 Obsoleted by 95–71, 1995–42 I.R.B. 7

54–257 Obsoleted by 95–71, 1995–42 I.R.B. 7

56–171 Obsoleted by 95–71, 1995–42 I.R.B. 7

56–286 Obsoleted by 95–71, 1995–42 I.R.B. 7

57–243 Obsoleted by 95–71, 1995–42 I.R.B. 7

206

Revenue Rulings—Continued

79–353 Revoked by 95–58, 1995–36 I.R.B. 16

79–376 Obsoleted by 95–71, 1995–42 I.R.B. 7

80–221 Obsoleted by 95–71, 1995–42 I.R.B. 7

81–51 Revoked by 95–58, 1995–36 I.R.B. 16

81–204 Obsoleted by 95–71, 1995–42 I.R.B. 7 81–218 Obsoleted by 95–71, 1995–42 I.R.B. 7

82–58 Obsoleted by 95–71, 1995–42 I.R.B. 7

82–72 Obsoleted by 95–71, 1995–42 I.R.B. 7

82–113 Obsoleted by 95–71, 1995–42 I.R.B. 7

83–38 Obsoleted by 95–71, 1995–42 I.R.B. 7

84–152 Obsoleted by 95–56, 1995–36 I.R.B. 20

84–153 Obsoleted by 95–56, 1995–36 I.R.B. 20

85–125 Obsoleted by 95–71, 1995–42 I.R.B. 7

85–161 Obsoleted by 95–71, 1995–42 I.R.B. 7

85–163 Obsoleted by 95–56, 1995–36 I.R.B. 20

87–4 Obsoleted by 95–71, 1995–42 I.R.B. 7

87–89 Obsoleted in part by 95–56, 1995–36 I.R.B. 20

92–63 Modified and Superseded by 95–63, 1995–37 I.R.B. 4

Finding List of Current Action on Previously Published Items ¹ — Continued

Bulletins 1995–27 through 1995–52

*Denotes entry since last publication

Revenue Rulings—Continued

69–95 Obsoleted by 95–71, 1995–42 I.R.B. 7

69–172 Obsoleted by 95–71, 1995–42 I.R.B. 7

69–284 Obsoleted by 95–71, 1995–42 I.R.B. 7

70–467 Obsoleted by 95–71, 1995–42 I.R.B. 7

70–514 Obsoleted by 95–71, 1995–42 I.R.B. 7

71–367 Obsoleted by 95–80, 1995–51 I.R.B. 4 71–522 Obsoleted by 95–71, 1995–42 I.R.B. 7

73–2 Obsoleted by 95–71, 1995–42 I.R.B. 7

73–264 Obsoleted by 95–71, 1995–42 I.R.B. 7

73–515 Obsoleted by 95–71, 1995–42 I.R.B. 7

73–551 Obsoleted by 95–71, 1995–42 I.R.B. 7

73–552 Obsoleted by 95–71, 1995–42 I.R.B. 7

73–611 Obsoleted by 95–71, 1995–42 I.R.B. 7

74–61 Obsoleted by 95–71, 1995–42 I.R.B. 7

74–119 Obsoleted by 95–71, 1995–42 I.R.B. 7

74–295 Obsoleted by 95–71, 1995–42 I.R.B. 7

See footnote at end of list.

Revenue Rulings—Continued

74–430 Obsoleted by 95–71, 1995–42 I.R.B. 7

74–441 Obsoleted by 95–71, 1995–42 I.R.B. 7

74–522 Obsoleted by 95–71, 1995–42 I.R.B. 7

75–40 Obsoleted by 95–71, 1995–42 I.R.B. 7

75–240 Obsoleted by 95–71, 1995–42 I.R.B. 7

75–324 Obsoleted by 95–71, 1995–42 I.R.B. 7

75–460 Obsoleted by 95–71, 1995–42 I.R.B. 7

75–508 Obsoleted by 95–71, 1995–42 I.R.B. 7

76–36 Obsoleted by 95–31, 1995–42 I.R.B. 7

77–190 Obsoleted by 95–71, 1995–42 I.R.B. 7

77–182 Modified by 95–58, 1995–36 I.R.B. 16

78–285 Obsoleted by 95–71, 1995–42 I.R.B. 7

78–350 Obsoleted by 95–71, 1995–42 I.R.B. 7

78–422 Obsoleted by 95–71, 1995–42 I.R.B. 7

79–3 Obsoleted by 95–71, 1995–42 I.R.B. 7

79–41 Clarified & Superseded by 95–53, 1995–34 I.R.B. 17

79–121 Obsoleted by 95–71, 1995–42 I.R.B. 7

79–149 Obsoleted by 95–71, 1995–42 I.R.B. 7

207

Finding List of Current Action on Previously Published Items ¹ — Continued

Bulletins 1995–27 through 1995–52

*Denotes entry since last publication

Revenue Rulings—Continued

92–84 Obsoleted by T.D. 8600, 1995–33 I.R.B. 10

93–88 Suspended by Notice 95–45, 1995–34 I.R.B. 20

95–35 Modified by 95–66, 1995–40 I.R.B. 4

1A cumulative finding list for previously published items mentioned in Internal Revenue Bulletins 1995–1 through 1995–26 will be found in Internal Revenue Bulletin 1995–27, dated July 3, 1995.

208

Internal Revenue Bulletins 1995–27 Through 1995–52

For index of items published during the first six months of 1995, see I.R.B. 1995–27, dated July 3, 1995.

The abbreviation and number in parentheses following the index entry refer to the specific item; numbers in roman and italic type following the parentheses refer to the Internal Revenue Bulletin in which the item may be found and the page number on which it appears.

Key to Abbreviations:

RR Revenue Ruling RP Revenue Procedure TD Treasury Decision CD Court Decision PL Public Law EO Executive Order DO Delegation Order TDO Treasury Department Order TC Tax Convention SPR Statement of Procedural

Rules PTE Prohibited Transaction

Exemption

Proposed regulations—Continued

26 CFR 301.6231(a)(7)–1, amended; 301.6231(a)(7)–2, added; selection of tax matters partner for limited liability companies (PS–34–92) 47, 15 26 CFR 301.7503–1, amended; time for performance of acts where last day falls on Saturday, Sunday, or legal holiday (IA–36–91) 42, 10 26 CFR 301.7701–4(e), added; environmental settlement funds, classification (PS–54–94) 37, 48 Request for comments concerning

Regulations—Continued

26 CFR 301.7701(i)–0—301.7701(i)– 4, added; taxable mortgage pools (TD 8610) 37, 13 Request for comments concerning

removal (Notice 51) 42, 8 Rulings:

Obsolete (RP 43) 36, 31 Self-employment tax:

Social Security contribution and ben

efit base 46, 16

withdrawal (Notice 51) 42, 8 Railroad retirement:

Rate determination, quarterly (begin

ADMINISTRATIVE

ning Oct. 1, 1995) 40, 37 Rates of tax:

Social Security contribution and ben

Deficiencies:

Adjusted interest rates (RR 59) 35,

efit base 40, 16 Regulations:

10 ; (RR 78) 49, 4 Overpayments:

26 CFR 301.6061–1T, added; methods of signing (TD 8603) 34, 18 26 CFR 301.6109–2, amended; authority of Sec. of Agriculture to share EIN collected from retail food stores and wholesale food concerns (TD 8621) 43, 5

Adjusted interest rates (RR 59) 35,

10 ; (RR 78) 49, 4 Proposed regulations:

Administration:

Correction of previously filed Forms

942 (Notice 54) 44, 21 Deficiencies:

Adjusted interest rates (RR 59) 35,

10 ; (RR 78) 49, 4 Overpayments:

Adjusted interest rates (RR 59) 35,

10 ; (RR 78) 49, 4 Penalties, use of electronic funds

transfer (RR 68) 42, 5 Proposed regulations:

26 CFR 31.6011(a)–4, revised; reporting of nonpayroll withheld tax liabilities (IA–30–95) 45, 13 26 CFR 301.6061–1, amended; methods of signing (IA–10–95) 34, 27 26 CFR 301.6109–1, amended; taxpayer identifying numbers (INTL– 24–94) 27, 33 26 CFR 301.6109–3, added; authority of FCIC to require EINs, withdrawal of regs. (Notice 62) 47, 12

26 CFR 31.3402(p)–1, amended; 31.3504(c)–1, added; 31.3405(c)– 1T, removed; direct rollovers and 20-percent withholding upon eligible rollover distributions from qualified plans (TD 8619) 41, 4 26 CFR 31.3505–1, amended; liability of third parties paying or providing for wages, suit period and extension and maximum amount recoverable (TD 8604) 35, 9 26 CFR 31.6011(a)–4, amended; 31.6011(a)–4T, added; reporting of nonpayroll withheld tax liabilities (TD 8624) 45, 8 26 CFR 301.6061–1T, added; methods of signing (TD 8603) 34, 18 26 CFR 301.6109–2, amended; authority of Sec. of Agriculture to share EIN collected from retail food stores and wholesale food concerns (TD 8621) 43, 5 26 CFR 301.6211–1, 301.7611–1, and intermediate sections, amended; 301.6852–1, 301.7409– 1, added; political expenditures by sec. 501(c)(3) organizations (TD 8628) 52, 9 26 CFR 301.6867–1, added; 301.6867–1T, removed; presumptions where owner of large amount of cash is not identified (TD 8605) 36, 17 26 CFR 301.7514–1, amended; seals of office (TD 8625) 46, 10

26 CFR 301.6061–1, amended; methods of signing (IA–10–95) 34, 27 26 CFR 301.6109–1, amended; taxpayer identifying numbers (INTL– 24–94) 27, 33 26 CFR 301.6109–3, added; authority of FCIC to require EINs, withdrawal of regs. (Notice 62) 47, 12 26 CFR 301.6231(a)(7)–1, amended; 301.6231(a)(7)–2, added; selection of tax matters partner for limited liability companies (PS–34–92) 47, 15 26 CFR 301.7503–1, amended; time for performance of acts where last day falls on Saturday, Sunday, or legal holiday (IA–36–91) 42, 10 26 CFR 301.7701–4(e), added; environmental settlement funds, classification (PS–54–94) 37, 48 Request for comments concerning

withdrawal (Notice 51) 42, 8 Regulations:

209

Regulations—Continued

26 CFR 40.6302(c)–5T, added; deposits of excise taxes (TD 8616) 39, 7 26 CFR 52.4681–0, removed; 52.4681–1, 52.4682–1, –2, –4, amended; 52.4682–5, added; exports of chemicals that deplete the ozone layer, special rules for certain medical uses of chemicals that deplete the ozone layer (TD 8622) 44, 5 26 CFR 53.4955–1, 53.6071–1(e), 301.6852–1, 301.7409–1, added; 53.4963–1, 53–6011–1, 301.6211– 1, 301.7611–1, and intermediated sections, amended; 53.6091–1, revised; political expenditures by sec. 501(c)(3) organizations (TD 8628) 52, 9 26 CFR 301.6061–1T, added; methods of signing (TD 8603) 34, 18 26 CFR 301.6109–2, amended; authroity of Sec. of Agriculture to share EIN collected from retail food stores and wholesale food concerns (TD 8621) 43, 5 26 CFR 301.6867–1, added; 301.6867–1T, removed; presumptions where owner of large amount of cash is not identified (TD 8605) 36, 17 26 CFR 301.7514–1, amended; seals of office (TD 8625) 46, 10 26 CFR 301.7701(i)–0—301.7701(i)– 4, added; taxable mortgage pools (TD 8610) 37, 13

Regulations—Continued and intermediate sections, amended; 301.6852–1, 301.7409– 1, added; political expenditures by sec. 501(c)(3) organizations (TD 8628) 52, 9 26 CFR 301.6867–1, added; 301.6867–1T, removed; presumptions where owner of large amount of cash is not identified (TD 8605) 36, 17 26 CFR 301.7514–1, amended; seals of office (TD 8625) 46, 10 26 CFR 301.7701(i)–0—301.7701(i)– 4, added; taxable mortgage pools (TD 8610) 37, 13 Request for comments concerning

10 ; (RR 78) 49, 4 Proposed regulations:

Methyl methacrylate (Notice 58)

46, 12 Monoethanolamine, diethanola mine, triethanolamine, monoisopropanolamine, diisopropanolamine, triisopropanolamine, toluene diisocyanate, and chlorinated polyethylene (Notice 43) 33, 22 Poly 1,4 butyleneterephthalate

(Notice 59) 46, 12 Toluenediamine (Notice 44) 33, 23 Deficiencies:

Adjusted interest rates (RR 59) 35,

10 ; (RR 78) 49, 4 Overpayments:

Adjusted interest rates (RR 59) 35,

removal (Notice 51) 42, 8 Rulings:

Areas in which rulings will not be

issued: Generation skipping transfers (RP

26 CFR 40.6302(c)–5, added; deposits of excise taxes (PS–8–95) 39, 19 26 CFR 301.6061–1, amended; methods of signing (IA–10–95) 34, 27 26 CFR 301.6109–1, amended; taxpayer identifying numbers (INTL– 24–94) 27, 33 26 CFR 301.6109–3, added; authority of FCIC to require EINs, withdrawal of regs. (Notice 62) 47, 12 26 CFR 301.6231(a)(7)–1, amended; 301.6231(a)(7)–2, added; selection of tax matters partner for limited liability companies (PS–34–92) 47, 15 26 CFR 301.7503–1, amended; time for performance of acts where last day falls on Saturday, Sunday, or legal holiday (IA–36–91) 42, 10 26 CFR 301.7701–4(e), added; environmental settlement funds, classification (PS–54–94) 37, 48 Rates of tax:

50. 50, 16

ESTATE TAX

Proposed regulations:

26 CFR 20.2056A–2, amended; requirements to ensure collection of estate tax (PS–25–94) 38, 47 Regulations:

26 CFR 20.2056–0, 20.2102–1, 20.2106–1, amended; 20.2056(d)–1 & –2 redesignated (d) –2 & –3; 20.2056(d)–1, 20.2056A–0— 20.2056A–13, added; 20.2101–1, revised; 20.2106–2(c) removed & reserved; marital deduction provisions (TD 8612) 38, 7 26 CFR 20.2056A–2T, added; requirements to ensure collection of estate tax (TD 8613) 38, 31 Trusts:

Accounting methods:

Change, section 263A costs (RP 33)

28, 7 Rent-to-own contracts (RP 38) 34,

25 Sec. 1281 method changes (Notice

Power to appoint trustee (RR 58) 36,

(RP 53) 52, 22 Regulations:

Luxury automobile, adjustment, 1996

16

57. 45, 12 Administration:

penalty enforcement authority to Commissioner (Treas. Directive 15–43) 36, 31

GIFT TAX

Regulations:

26 CFR 25.2503–2, amended; 25.2523(i)–1, –2, –3, 25.2702– 1(c)(8), added; marital deduction provisions (TD 8612) 38, 7

26 CFR 40.6302(c)–0, 48.4081–0, removed; 40.6302(c)–1(e)(4), 48.4101–3, added; 48.4041–8(f), 48.4081–7, amended; 48.4041–21, 48.4081–3(b)(1), 48.4081–6, revised; gasohol, compressed natural gas (CNG) (TD 8609) 37, 5

Delegation of authority:

Criminal investigatory and civil

210

Administration—Continued

Credit against tax—Continued

Exempt organizations—Continued

Delegation of authority—Continued

Low-income housing—Continued

General—Continued

Hurricane Opal assistance, relief

from certain providions (Notice 66) 51, 19 Lobbying and political expendi

Investigatory, seizure, and forfeit ure authority under Money Laundering Control Act of 1986 to Commissioner (Treas. Directive 15–42) 41, 32 Merchant Marine Capital Con

Adjusted interest rates (RR 59) 35,

Section 42(h)(6) extended commit ment (RR 49) 29, 4 Damages, compensation for inju

ries or sickness (Notice 45) 34, 20 Deficiencies:

tures, reporting requirement exception (RP 35) 32, 51 ; (RP 35A) 40, 38 Qualification:

struction Funds, interest rate (Notice 46) 34, 20 Regional and district offices of the

Leased consumer durable property

10 ; (RR 78) 49, 4 Depreciation:

assistance (Notice 47) 35, 17 Foreign tax credit:

Virginia flood relief, emergency

IRS (TDO 150–01) 44, 23 Allocation of income and deductions,

‘‘stripping transactions’’ (Notice 53) 44, 21 Automobiles:

(RR 52) 34, 16 Domestic international sales corpora

Income source, certain countries (RR

63. 37, 4 International boycotts, countries re

Optional standard mileage rates (RP

tions (DISC): International boycotts, countries re quiring cooperation (Notice 41) 28, 5 ; (Notice 65) 50, 5 Taxation of DISC income to share

54. 52, 27 Bonds:

Qualified mortgage bonds:

Mortgage credit certificates:

National median gross income

(RP 32) 28, 6 Qualified census tracts (RP 31)

holders, T-bill rate ending 9/30/95 (RR 77) 47, 6 Employee plans:

tended indefinitely (RP 52) 51, 14 Contributions and benefits:

Recognition:

Administrative:

Closing agreement program ex

quiring cooperation (Notice 41) 28, 5 ; (Notice 65) 50, 5 Forms:

1040A & related schedules will be input through Document Processing System (RP 46) 46, 13 Gain or loss:

28, 5 Tax-exempt bonds, arbitrage (RP 47)

Cost-of-living adjustments, dollar

Nonrecognition of FCC certified

47, 12 Business expenses:

sales and exchanges, repealed (PL 104–7) 29, 5 Gross income:

Health insurance, self-employed indi vidual (PL 104–7) 29, 5 Substantiation requirements (Notice

limitations, 1996 (Notice 55) 45, 11 Limitations (RR 29A) 28, 4 Employee stock ownership plans:

Exercise of voting rights by trustee

Exclusions-inclusions:

Fringe benefits, SIFL, aircraft

valuation formula (RR 66) 40, 4 Income source:

50. 42, 8 Charitable contributions:

Organizations providing relief to vic

(RR 57) 35, 5 Funding:

U.S. citizen abroad, waiver of resi

dency requirements (RP 45) 44, 22 Insurance companies:

Differential earning rate for 1994

and recomputed rate for 1993 (RR 60) 35, 7 Reserves, health and accident pol

tims of Hurricane Marilyn (Notice 56) 45, 11 Consolidated returns:

Life:

Permission to discontinue filing (RP

Change in method, automatic ap proval for specific methods (RP 51) 51, 6 Full funding limitations, weighted

39. 35, 17 Corporations:

Foreign sales corporations, require

icies (RR 80) 51, 4 Other than life or mutual:

ments suspended, Hurricane Marilyn (Notice 60) 47, 9 Credits against tax:

Carryovers allocated to qualified

states (RP 36) 33, 24 Commingled alcohol mixture (RR

54. 35, 5 Earned income, excessive investment

average interest rate, July 1995 (Notice 42) 31, 4; Aug. 1995 (Notice 48) 36, 21; Sept. 1995 (Notice 49) 39, 18 ; Oct. 1995 (Notice 52) 43, 7 ; Nov. 1995 (Notice 63) 48, 8 Qualification:

Covered compensation tables,

1996 (RR 75) 46, 8 Highly compensated employees,

definition (RP 34) 29, 7 Issuance of notification letters,

Loss payment and discount fac tors, 1995 (RP 40) 36, 21 Salvage discount factors, 1995 (RP

Federal short-term, mid-term, and

41. 36, 28 Interest:

income (PL 104–7) 29, 5 Low-income housing:

Investment:

Satisfactory bond, ‘‘bond factor’’

certain regional prototype plans (RP 42) 35, 20 Exempt organizations:

amounts, Jan. through Sept. 1995 (RR 64) 38, 4 ; Jan. through Dec. 1995 (RR 83) 52, 5

General:

cretionary authority under sec. 6033 (RP 48) 47, 13

Exercise of Commissioner’s dis

long-term rates, July 1995 (RR 48) 27, 5; Aug. 1995 (RR 51) 32, 4; Sept. 1995 (RR 62) 36, 14 ; Oct. 1995 (RR 67) 41, 29 ; Nov. 1995 (RR 73) 45, 6 ; Dec. 1995 (RR 79) 49, 4

211

Interest—Continued

Proposed regulations—Continued

Paid:

Qualified stated interest, definition

(RR 70) 43, 4 Single premium annuity contract,

loan collateral (RR 53) 34, 17 Inventories:

LIFO:

Price indexes, department stores,

26 CFR 1.952–1, amended; 1.952– 2(c)(1), revised; 1.954–2(b)(3), 1.960–1(i), added; definition of foreign base company income and foreign personal holding company income of a controlled foreign corporation (INTL–75–92) 40, 39 26 CFR 1.1377–0, –1, –2, –3, added; definitions under subchapter S for S corporations and their shareholders (PS–268–82) 31, 5 26 CFR 1.1502–1(f)(6), added; consolidated groups—intercompany transactions and related rules (CO– 24–95) 32, 53 26 CFR 1.6695–1, revised; 301.6061–1, amended; methods of signing (IA–10–95) 34, 27 26 CFR 301.6109–1, amended; taxpayer identifying numbers (INTL– 24–94) 27, 33 26 CFR 301.6109–3, added; authority of FCIC to require EINs, withdrawal of regs. (Notice 62) 47, 12 26 CFR 301.6231(a)(7)–1, amended; 301.6231(a)(7)–2, added; selection of tax matters partner for limited liability companies (PS–34–92) 47, 15 26 CFR 301.7503–1, amended; time for performance of acts where last day falls on Saturday, Sunday, or legal holiday (IA–36–91) 42, 10 26 CFR 301.7701–4(e), added; environmental settlement funds, classification (PS–54–94) 37, 48 Request for comments concerning

May 1995 (RR 50) 30, 4; June 1995 (RR 61) 35, 6; July 1995 (RR 65) 39, 4 ; Aug. 1995 (RR 72) 42, 4 ; Sept. 1995 (RR 76) 47, 5 ; Oct. 1995 (RR 82) 52, 7 REMIC residual interests (RR 81)

52, 6 Involuntary conversions:

Treatment of specific section 1033

transactions (PL 104–7) 29, 5 Levy:

Table, exempt from levy on wages,

salary, and other income (Notice 61) 47, 10 Liability for tax:

Contingent liabilities assumed in sec

tion 351 exchanges (RR 74) 46, 6 Overpayments:

Adjusted interest rates (RR 59) 35,

10 ; (RR 78) 49, 4 Partnership:

Limited:

New York (RLLP) (RR 55) 35, 13 Penalties:

Substantial understatement (RP 55)

52, 34 Possessions of the United States:

Post-1993 section 936 elections (RP

37. 34, 21 Proposed regulations:

26 CFR 1.170A–1, 1.170A–13, amended; 1.6115–1, added; deductibility, substantiation, and disclosure of certain charitable contributions (IA–44–94) 37, 41 26 CFR 1.351–1, amended; transfers to investment companies (CO–19– 95) 38, 43 26 CFR 1.351–1(a)(3), 1.721–1(c), added; treatment of underwriters (CO–26–95) 38, 45 26 CFR 1.411(a)–11, 1.417(e)–1, amended; notice, consent, and election requirements (EE–24–93) 41, 33 26 CFR 1.584–2, 1.584–4, amended; diversification of common trust funds (PS–29–92) 36, 32

withdrawal (Notice 51) 42, 8 Rates of tax:

Income tax cost-of-living adjust

ments, 1996 (RP 53) 52, 22 Regulations:

26 CFR 1.30–1, 1.179A–1, added; definition of qualified electric vehicle, recapture rules for qualified electric vehicles, qualified cleanfuel vehicle property, qualified clean-fuel vehicle refueling property (TD 8606) 36, 5 26 CFR 1.61–2, 1.217–2, amended; 1.61–22T, 1.217–2T, removed; allowances received by members of the Armed Forces in connection with moves to new permanent duty stations (TD 8607) 36, 8

Regulations—Continued

26 CFR 1.83–6, amended; deductions for transfers of property (TD 8599) 33, 5 26 CFR 1.108–3, added; 1.167(a)– 11, 1.460–0, –4, 1.469–0, –1, –1T, 1.1502–17, –18, –20, –26, –33, –79, –80, amended; 1.263A–1, 1.267(f)–1, 1.1502–13, revised; 1267(f)–1T, –2T, –3, 1.1502–13T, –14, –14T, removed; consolidated return intercompany transactions system and related rules (TD 8597) 32, 6 26 CFR 1.162–20(c)(5) & (d), 1.162–28, 1.162–29, added; 1.162– 20T, removed; lobbying expense deductions (TD 8602) 34, 5 26 CFR 1.170A–13(e), added & reserved; 1.170A–13(f), added; 1.170A–13T, removed; substantiation requirement for certain charitable contributions (TD 8623) 45, 4 26 CFR 1.274–2, 1.274–5T, amended; definition of club (TD 8601) 33, 8 26 CFR 1.338–0, 1.338–2, amended; continuity of interest in transfer of target assets after qualified stock purchase of target (TD 8626) 46, 4 26 CFR 1.401(a)(31)–1T, 1.402(c)– 2T, 1.402(f)–2T, 1.403(b)–2T, removed; 1.401(a)(31)–1, 1.402(c)– 2, 1.403(b)–2, added; 1.402(f)–1, revised direct rollovers and 20percent withholding upon eligible rollover distributions from qualified plans (TD 8619) 41, 4 26 CFR 1.411(a)–11, 1.417(e)–1, 1.417(e)–1T, amended; 1.411(a)– 11T, added; notice, consent, and election requirements (TD 8620) 41, 25 26 CFR 1.446–1, 1.481–1, –2, –3, amended; 1.481–4, –6, removed; 1.481–5 redesignated 1.481–4 & revised; 1.481–5, added; requirements for changes in method of accounting (TD 8608) 36, 10 26 CFR 1.860A–0, 1.860G–1, amended; 1.860A–1(b)(4), added; 1.860G–1T, removed; real estate mortgage investment conduits (TD 8614) 38, 4

212

Regulations—Continued

26 CFR 1.863–1(d), added; special rules for determining sources of scholarships and fellowship grants (TD 8615) 39, 5 26 CFR 1.871–1 (b) (7), 1.881–0, –3, –4, 1.1441–3(j), 1.1441–7(d), 1.6038A–3(b)(5) & (c)(2)(vii), 1.7701(1)–1, added; conduit financing arrangements (TD 8611) 37, 20 26 CFR 1.904–0, amended; 1.904(i)– 1, added; limitation on use of deconsolidation to avoid foreign tax credit limitations (TD 8627) 48, 4 26 CFR 1.952–3, 1.954A–1, –2, 1.957–1T, removed; 1.954–0, –1, –2, Part 4, added; 1.957–1, 4.954– 0, amended; 1.954–0T, –1T, –2T redesignated 4.954–0, –1, –2; definition of controlled foreign corporation, foreign base company income and foreign personal holding company income of a controlled foreign company (TD 8618) 40, 4 26 CFR 1.1015–5, amended; marital deduction provisions (TD 8612) 38, 7 26 CFR 1.1361–0, revised; 1.1361–1, amended; definition of an S corporation (TD 8600) 33, 10 26 CFR 1.1502–13T, added; consolidated groups—intercompany transactions and related rules (TD 8598) 32, 47

Regulations—Continued

26 CFR 1.6091–2, 301.6852–1, 301.7409–1, added; 301.6211–1, 301.7611–1, and intermediate sections, amended; political expenditures by sec. 501(c)(3) organizations (TD 8628) 52, 9 26 CFR 1.6662–0, –2, –3, –4, 1.6664–0, –1, –4, amended; 1.6662–1, revised; 1.6662–7, added; 1.6662–7T, removed; accuracy-related penalty (TD 8617) 39, 9 26 CFR 1.6695–1T, 301.6061–1T, added; methods of signing (TD 8603) 34, 18 26 CFR 1.7704–1, added; classification of certain publicly traded partnerships as corporations (TD 8629) 52, 14 26 CFR 301.6109–2, amended; authority of Sec. of Agriculture to share EIN collected from retail food stores and wholesale food concerns (TD 8621) 43, 5 26 CFR 301.6867–1, added; 301.6867–1T, removed; presumptions where owner of large amount of cash is not identified (TD 8605) 36, 17 26 CFR 301.7514–1, amended; seals of office (TD 8625) 46 10 26 CFR 301.7701(i)–0—301.7701(i)– 4, added; taxable mortgage pools (TD 8610) 37, 13

213

issued (Notice 67) 52, 35

Regulations—Continued

Request for comments concering re

moval (Notice 51) 42, 8 Reorganizations:

Continuity of proprietary interest,

distribution to partners (RR 69) 42, 4 Returns:

Electronic filing, Form 1040 (RP 49)

50, 5 Information, magnetic media, wage

and tax statements, Puerto Rico, Virgin Islands, Guam and American Samoa (Notice 64) 50, 5 Information, reproduction of Forms

1096, 1098, 1099 Series, 5498, and W–2G (RP 30) 27, 9 Magnetic media reporting, Forms

1098, 1099 series, 5498, and W– 2G (RP 29A) 30, 5 Rulings:

Obsolete, conduit rev. ruls. (RR 56)

36, 20 Obsolete procedures as a result of

Regulatory Reinvention Initiative (RP 44) 42, 9 Obsolete rulings as result of Regula

tory Reinvention Initiative (RR 71) 42, 7 Self-employment tax:

Social Security contribution and ben

efit base 46, 16 Travel expenses:

Per diem allowance procedure to be