SECTION 15. EFFECTIVE DATE

This revenue procedure applies to a request for a Statement of Value for an item of art if the request is submitted after January 15, 1996.

DRAFTING INFORMATION

The principal authors of this revenue procedure are Jefferson K. Fox of the

ruling must address a specific, prospective issuance of obligations. A resolution must have been adopted before the request is submitted, in accordance with state or local law authorizing the issuance of a specific issue of obligations. The resolution may state that the issuance of obligations is contingent upon a favorable ruling by the Service or a favorable decision by the Tax Court.

.03 Statement of Facts . The statement of facts in a request for a reviewable ruling must be complete, accurate, and detailed. Each request must contain all relevant facts. These facts include but are not limited to the following:

(1) the name, address, and taxpayer identification number of the issuer, each underwriter, and each conduit borrower (except conduit borrowers of the proceeds of bonds such as qualified mortgage bonds, qualified veterans’ mortgage bonds, and qualified student loan bonds);

(2) a description of all uses and users of proceeds of the obligations;

(3) a description of the accounting method or methods that will be used to account for investments and expenditures of gross proceeds of the obligations;

(4) an estimate of all fees that will be paid in connection with the issuance of the obligations;

(5) a description of any elections made pursuant to the regulations under § 148 including elections on the application of the various versions of the those regulations;

(6) the expected principal amount, expected yield, expected issue price, and expected issue date of the prospective obligations and of the expected investments to be acquired with bond proceeds;

(7) a statement whether proceeds are expected to be invested at a yield that exceeds the yield on the issue of obligations by more than the amount permitted in § 1.148–2(d)(2) of the Income Tax Regulations (definition of materially higher yield) and a statement indicating which definition the issuer expects will apply;

(8) descriptions of any obligations that are to be refunded by the prospective obligations and representations whether the interest on each obligation that is to be refunded has been treated by the issuer as excludable from gross income under § 103; and

Office of Chief Counsel (Income Tax and Accounting) and Deborah Ryan of the Office of Chief Counsel (Passthroughs and Special Industries). For further information regarding this revenue procedure, contact Karen Carolan of the Office of Art Appraisal Services at (202) 401-4128 (not a toll-free call).

26 CFR 601.105: Rulings and determination letters. (Also Part I, §§ 103, 7478.)

Rev. Proc. 96–16