Internal Revenue Bulletin 1996-35

Official source: Internal Revenue Bulletin (https://www.irs.gov/pub/irs-irbs/irb96-35.pdf), retrieved 2026-10-03. U.S. Government work (17 U.S.C. § 105).

HIGHLIGHTS OF THIS ISSUE¶

These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

Rev. Rul. 96–42, page 4. Mutual life insurance companies; differential earn- ings rate. The differential earnings rate for 1995 and the recomputed differential earnings rate for 1994 are set forth for use by mutual life insurance companies to compute their income tax liabilities for 1995.

Notice 96–41, page 6. 1996 section 43 inflation adjustment factor. This notice announces the inflation adjustment factor to be used in determining the enhanced oil recovery credit for tax years beginning in the 1996 calendar year.

Notice 96–42, page 6. 1996 marginal production rates. This notice announces the applicable percentage to be used in determining percentage depletion for marginal properties for the 1996 calendar year.

EXEMPT ORGANIZATIONS

Announcement 96–80, page 16. A list is given of organizations now classified as private foundations.

ADMINISTRATIVE

Rev. Proc. 96–43, page 6. Section 355 ‘‘No Rule.’’ This procedure amplifies the ‘‘No Rule’’ Rev. Proc. 96–3, 1996–1 I.R.B. 82, to

Finding Lists begin on page 17.

Exceptions & meaning →

Bulletin No. 1996–35 August 26, 1996¶

include certain transactions under section 355 of the Code.

Rev. Proc. 96–44, page 7. Insurance companies; loss reserves; discounting un- paid losses. The loss payment patterns and discount factors are set forth for the 1996 accident year. These factors will be used for computing discounted unpaid losses under section 846 of the Code.

Rev. Proc. 96–45, page 12. Insurance companies; discounting estimated salvage recoverable. The salvage discount factors are set forth for the 1996 accident year. These factors will be used for computing estimated salvage recoverable under section 832 of the Code.

Announcement 96–77, page 15. Backup withholding; substitute Form W–9. The effective date of Rev. Proc. 96–26, 1996–8 I.R.B. 22, is extended for certain payors who must secure regulatory approval of changes to their substitute Forms W–9.

Announcement 96–78, page 15. T.D. 8670, 1996–24 I.R.B. 6, relating to qualified cost sharing arrangements, is corrected.

Announcement 96–79, page 15. T.D. 8671, 1996–26 I.R.B. 8, relating to requirements for furnishing a taxpayer identifying number on returns, statements, and other documents, is corrected.

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Mission of the Service¶

The purpose of the Internal Revenue Service is to collect the proper amount of tax revenue at the least cost; serve the public by continually improving the

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Statement of Principles of Internal Revenue Tax Administration¶

The function of the Internal Revenue Service is to administer the Internal Revenue Code. Tax policy for raising revenue is determined by Congress.

With this in mind, it is the duty of the Service to carry out that policy by correctly applying the laws enacted by Congress; to determine the reasonable meaning of various Code provisions in light of the Congressional purpose in enacting them; and to perform this work in a fair and impartial manner, with neither a government nor a taxpayer point of view.

At the heart of administration is interpretation of the Code. It is the responsibility of each person in the Service, charged with the duty of interpreting the law, to try to find the true meaning of the statutory provision and not to adopt a strained construction in the belief that he or she is ‘‘protecting the revenue.’’ The revenue is properly protected only when we ascertain and apply the true meaning of the statute.

quality of our products and services; and perform in a manner warranting the highest degree of public confidence in our integrity, efficiency and fairness.

The Service also has the responsibility of applying and administering the law in a reasonable, practical manner. Issues should only be raised by examining officers when they have merit, never arbitrarily or for trading purposes. At the same time, the examining officer should never hesitate to raise a meritorious issue. It is also important that care be exercised not to raise an issue or to ask a court to adopt a position inconsistent with an established Service position.

Administration should be both reasonable and vigorous. It should be conducted with as little delay as possible and with great courtesy and considerateness. It should never try to overreach, and should be reasonable within the bounds of law and sound administration. It should, however, be vigorous in requiring compliance with law and it should be relentless in its attack on unreal tax devices and fraud.

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Introduction¶

The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It is published weekly and may be obtained from the Superintendent of Documents on a subscription basis. Bulletin contents of a permanent nature are consolidated semiannually into Cumulative Bulletins, which are sold on a single-copy basis.

It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published.

Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements.

Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying published rulings and procedures, the effect of subsequent legislation, regulations,

court decisions, rulings, and procedures must be considered, and Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same.

The Bulletin is divided into four parts as follows:

Part I.—1986 Code. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1986.

Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions, and Subpart B, Legislation and Related Committee Reports.

Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Subparts. Also included in this part are Bank Secrecy Act Administrative Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement).

Part IV.—Items of General Interest. With the exception of the Notice of Proposed Rulemaking and the disbarment and suspension list included in this part, none of these announcements are consolidated in the Cumulative Bulletins.

The first Bulletin for each month includes an index for the matters published during the preceding month. These monthly indexes are cumulated on a quarterly and semiannual basis, and are published in the first Bulletin of the succeeding quarterly and semi-annual period, respectively.

The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.

For sale by the Superintendent of Documents U.S. Government Printing Office, Washington, D.C. 20402.

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Part I. Rulings and Decisions Under the Internal Revenue Code of 1986¶

Section 1.809–9(a) of the regulations provides that neither the differential earnings rate under § 809(c) nor the recomputed differential earnings rate that is used in computing the recomputed differential earnings amount under § 809(f)(3) may be less than zero.

For purposes of § 809, the differential earnings rate for 1995 and the rate used to calculate the recomputed differential earnings amount for 1994 (the recomputed differential earnings rate for 1994), and the figures on which these two rates are based are set forth in Table 1.

Rev. Rul. 96–42 TABLE 1

Determination of Rates To Be Used For Taxable Years Beginning in 1995

Section 355.—Distribution of Stock and Securities of a Controlled Corporation

26 CFR 1.355–3: Active conduct of a trade or business.

The revenue procedure amplifies the ‘‘No Rule’’ revenue procedure, Rev. Proc. 96–3, 1996–1 I.R.B. 82, to include certain transactions under § 355 of the Code. See Rev. Proc. 96–43, page 6.

Section 809.—Reduction in Certain Deductions of Mutual Life Insurance Companies

26 CFR 1.809–9: Computation of the differential earnings rate and the recomputed differential earnings rate.

Mutual life insurance companies; differential earnings rate. The differential earnings rate for 1995 and the recomputed differential earnings rate for 1994 are set forth for use by mutual life insurance companies to compute their income tax liabilities for 1995.

Rev. Rul. 96–42

This revenue ruling contains the differential earnings rate for 1995 and the recomputed differential earnings rate for 1994. Under § 809 of the Internal Revenue Code, mutual life insurance companies use these rates in computing their Federal income tax liability for taxable years beginning in 1995. This revenue ruling also contains the figures on which the determinations of these rates are based. Notice 96–15, 1996–13 I.R.B. 19, contained tentative determinations of these rates.

Section 809(a) provides that, in the case of any mutual life insurance company, the amount of the deduction allowable under § 808 for policyholder dividends is reduced (but not below zero) by the ‘‘differential earnings amount.’’ Any excess of the differential earnings amount over the amount of the deduction allowable under § 808 is taken into account as a reduction in the closing balance of reserves under subsections (a) and (b) of § 807. The ‘‘differential earnings amount’’ for any taxable year is the amount equal to the product of (a) the life insurance company’s average equity base for the taxable year multiplied by (b) the ‘‘differential earnings rate’’ for that taxable year. The ‘‘differential earnings rate’’ for the taxable year is the excess of (a) the ‘‘imputed earnings rate’’ for the taxable year over (b) the ‘‘average mutual earn

ings rate’’ for the second calendar year preceding the calendar year in which the taxable year begins. The ‘‘imputed earnings rate’’ for any taxable year is the amount that bears the same ratio to 16.5 percent as the ‘‘current stock earnings rate’’ for the taxable year bears to the ‘‘base period stock earnings rate.’’

Section 809(f) provides that, in the case of any mutual life insurance company, if the ‘‘recomputed differential earnings amount’’ for any taxable year exceeds the differential earnings amount for that taxable year, the excess is included in life insurance gross income for the succeeding taxable year. If the differential earnings amount for any taxable year exceeds the recomputed differential earnings amount for that taxable year, the excess is allowed as a life insurance deduction for the succeeding taxable year. The ‘‘recomputed differential earnings amount’’ for any taxable year is an amount calculated in the same manner as the differential earnings amount for that taxable year, except that the average mutual earnings rate for the calendar year in which the taxable year begins is substituted for the average mutual earnings rate for the second calendar year preceding the calendar year in which the taxable year begins.

The stock earnings rates and mutual earnings rates taken into account under § 809 generally are determined by dividing statement gain from operations by the average equity base. For this purpose, the term ‘‘statement gain from operations’’ means ‘‘the net gain or loss from operations required to be set forth in the annual statement, determined without regard to Federal income taxes, and . . . properly adjusted for realized capital gains and losses. . . .’’ See § 809(g)(1). The term ‘‘equity base’’ is defined as an amount determined in the manner prescribed by regulations equal to surplus and capital increased by the amount of nonadmitted financial assets, the excess of statutory reserves over the amount of tax reserves, the sum of certain other reserves, and 50 percent of any policyholder dividends (or other similar liability) payable in the following taxable year. See § 809(b)(2), (3), (4), (5) and (6). Section 1.809–10 of the Income Tax Regulations provides that the equity base includes both the asset valuation reserve and the interest maintenance reserve for taxable years ending after December 31, 1991.

Differential earnings rate for

. . . . . . . . . . . . . . . . . . 0 Recomputed differential earn

ings rate for 1994 . . . . . . . . 5.887 Imputed earnings rate for

. . . . . . . . . . . . . . . . . . 15.109 Imputed earnings rate for
. . . . . . . . . . . . . . . . . . 12.625 Base period stock earnings

rate. . . . . . . . . . . . . . . . . . . . 18.221 Current stock earnings rate

for 1995. . . . . . . . . . . . . . . . 13.942 Stock earnings rate for 1992 . 7.004 Stock earnings rate for 1993 . 23.385 Stock earnings rate for 1994 . 11.437 Average mutual earnings rate

for 1993. . . . . . . . . . . . . . . . 18.406 Average mutual earnings rate

for 1994. . . . . . . . . . . . . . . . 9.222

DRAFTING INFORMATION

The principal author of this revenue ruling is Katherine A. Hossofsky of the Assistant Chief Counsel (Financial Institutions and Products). For further information regarding this revenue ruling contact Ms. Hossofsky on (202) 6223477 (not a toll-free number).

Section 832.—Insurance Company Taxable Income

26 CFR 1.832–4: Gross Income.

The salvage discount factors are set forth for the 1996 accident year. These factors will be used for computing estimated salvage recoverable for purposes of section 832 of the Code. See Rev. Proc. 96–45, page 12.

computing estimated salvage recoverable for purposes of section 832 of the Code. See Rev. Proc. 96–45, page 12.

Section 846.—Discounted Unpaid Losses Defined

26 CFR 1.846–1: Application of discount factors.

The loss payment patterns and discount factors are set forth for the 1996 accident year. These

factors will be used for computing discounted unpaid losses under section 846 of the Code. See Rev. Proc. 96–44, page 7.

The salvage discount factors are set forth for the 1996 accident year. These factors will be used for

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Part III. Administrative, Procedural, and Miscellaneous¶

1996 Section 43 Inflation Adjustment

Notice 96–41

Section 43(b)(3)(B) of the Internal Revenue Code requires the Secretary to publish an inflation adjustment factor. The enhanced oil recovery credit under § 43 for any taxable year is reduced if the ‘‘reference price,’’ determined under § 29(d)(2)(C), for the calendar year preceding the calendar year in which the taxable year begins is greater than $28 multiplied by the inflation adjustment factor for that year.

The term ‘‘inflation adjustment factor’’ means, with respect to any calendar year, a fraction the numerator of which is the GNP implicit price deflator for the preceding calendar year and the denominator of which is the GNP implicit price deflator for 1990.

Because the reference price for the 1995 calendar year ($14.26) does not exceed $28 multiplied by the inflation adjustment factor for the 1996 calendar year, the enhanced oil recovery credit for qualified costs paid or incurred in 1996 is determined without regard to the phase-out for crude oil price increases.

Table 1 contains the GNP implicit price deflator used for the 1996 calendar year, as well the previously published GNP implicit price deflators used for the 1991 through 1995 calendar years.

Notice 96–41 TABLE 1

GNP IMPLICIT PRICE DEFLATORS

Notice 96–41 TABLE 2 INFLATION ADJUSTMENT

FACTORS AND PHASE-OUT AMOUNTS

Phase-out

Calendar

Inflation Adjustment

Factor

Year Factor Amount

1991 1.0000 0 1992 1.0363 0 1993 1.0708 0 1994 1.0992 0 1995 1.1160 0 1996 1.1485 0

Year

DRAFTING INFORMATION

The principal author of this notice is Brenda M. Stewart of the Office of Assistant Chief Counsel (Passthroughs and Special Industries). For further information regarding this notice contact Ms. Stewart on (202) 622–3120 (not a toll-free call).

26 CFR 601.201: Rulings and determination let- ters. (Also §§ 355; 1.355–3.)

Rev. Proc. 96–43

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SECTION 1. PURPOSE¶

This revenue procedure amplifies Rev. Proc. 96–3, 1996–1 I.R.B. 82, which sets forth the areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (Domestic) and the Associate Chief Counsel (Employee Benefits and Exempt Organizations) relating to issues on which the Internal Revenue Service will not issue advance rulings or determination letters.

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SECTION 2. BACKGROUND¶

Section 4 of Rev. Proc. 96–3 sets forth those areas in which rulings or determination letters will not ordinarily be issued. Section 355(a) of the Internal Revenue Code applies to distributions of stock or securities of a corporation controlled by the distributing corporation if each of the corporations is engaged in the active conduct of a trade or business. Section 355(b) provides that a corporation is engaged in such conduct if, among other things, it is directly engaged in the active conduct of a trade or business, or substantially all of its assets consist of stock and securities of a corporation controlled by it (immediately after the transaction) which is so engaged.

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SECTION 3. PROCEDURE¶

Rev. Proc. 96–3 is amplified by adding to section 4 the following:

Section 355.—Distribution of Stock and Securities of a Controlled Corporation.—Whether a distribution of stock or securities is described in § 355(a)(1) when the gross assets of the trades or businesses relied on to satisfy the active trade or business requirement of § 355(b) will have a fair market value that is less than 5 percent of the total fair market value of the gross assets of the corporation directly conducting the

Calendar

Year

GNP Implicit Price Deflator

1990 112.9 (used for 1991) 1991 117.0 (used for 1992) 1992 120.9 (used for 1993) 1993 124.1 (used for 1994) 1994 126.0 (used for 1995) 1995 107.5 (used for 1996)* *Beginning in 1995, the GNP implict price deflator was rebased relative to 1992. The 1990 GNP implicit price deflator used to compute the 1996 § 43 inflation adjustment factor is 93.6

Table 2 contains the inflation adjustment factor and the phase-out amount for taxable years beginning in the 1996 calendar year as well as the previously published inflation adjustment factors and phase-out amounts for the 1991 through 1995 calendar years.

DRAFTING INFORMATION

1996 Marginal Production Rates

Notice 96–42

Section 613A(c)(6)(C) of the Internal Revenue Code defines the term ‘‘applicable percentage’’ for purposes of determining percentage depletion for oil and gas produced from marginal properties. The applicable percentage is the percentage (not greater than 25 percent) equal to the sum of 15 percent, plus one percentage point for each whole dollar by which $20 exceeds the reference price (determined under § 29(d)(2)(C)) for crude oil for the calendar year preceding the calendar year in which the taxable year begins. The reference price determined under § 29(d)(2)(C) for the 1995 calendar year is $14.26. Table 1 contains the applicable percentages for marginal production for taxable years beginning in calendar years 1991 through 1996.

Notice 96–42 TABLE 1 APPLICABLE PERCENTAGE FOR

MARGINAL PRODUCTION

Applicable

Calendar Year Percentage

1991 15 percent 1992 18 percent 1993 19 percent 1994 20 percent 1995 21 percent 1996 20 percent

trades or businesses. The Service may rule that the trades or businesses satisfy the active trade or business requirement of § 355(b) if it can be established that, based upon all relevant facts and circumstances, the trades or businesses are not de minimis compared with the other assets or activities of the corporation and its subsidiaries.

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SECTION 4. EFFECTIVE DATE¶

This revenue procedure will apply to all ruling requests postmarked or, if not mailed, received on or after August 8, 1996.

FURTHER INFORMATION

For further information regarding this revenue procedure contact Robert Hawkes of the Office of Assistant Chief Counsel (Corporate) at (202) 622–7530 (not a toll-free call).

.03 Tables

Homeowners/Farmowners

26 CFR 601.201: Rulings and determination let- ters (Also Part I, Sections 846; 1.846–1.)

Rev. Proc. 96–44

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SECTION 1. PURPOSE¶

This revenue procedure prescribes the loss payment patterns and discount factors for the 1996 accident year. These factors will be used for computing discounted unpaid losses under § 846 of the Internal Revenue Code. See Rev. Proc. 92–47, 1992–1 C.B. 980, for background concerning the loss payment patterns and application of the discount factors.

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SEC. 2. SCOPE¶

This revenue procedure applies to any taxpayer that is required to discount its unpaid losses under § 846 for a line of business using discount factors published by the Secretary.

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SEC. 3. TABLES OF DISCOUNT¶

FACTORS

.01 The following tables present separately for each line of business the discount factors under § 846 for accident year 1996. All the discount factors presented in this section were determined using the applicable interest rate under § 846(c) for 1996, which is 6.63 percent, and by assuming all loss payments occur in the middle of the calendar year.

.02 If the groupings of individual lines of business on the annual statement changes, taxpayers must discount the unpaid losses on the resulting lines of business in accordance with the discounting patterns that would have applied to those unpaid losses based on their classification on the 1990 annual statement.

Tables of Discount Factors

Section 846

- 1996 Interest rate: 6.63 percent

Unpaid Losses

at Year End

Estimated Losses

(%)

Discounted Unpaid Losses at

Year End

Discount

Factor

(%)

Tax Year

Cumulative Losses Paid

(%)

Paid Each Year

AY+ 0 66.8753 66.8753 30.6325 33.1247 92.4763 AY+ 1 90.4633 23.5880 8.3060 9.5367 87.0955 AY+ 2 93.3914 2.9281 5.8331 6.6086 88.2656 AY+ 3 95.7081 2.3167 3.8276 4.2919 89.1817 AY+ 4 97.4081 1.7000 2.3259 2.5919 89.7376 AY+ 5 98.6271 1.2190 1.2214 1.3729 88.9620 AY+ 6 99.1528 0.5257 0.7595 0.8472 89.6468 AY+ 7 99.5425 0.3897 0.4074 0.4575 89.0559 AY+ 8 99.7318 0.1893 0.2390 0.2682 89.1020 AY+ 9 99.8063 0.0745 0.1779 0.1937 91.8346 AY+10 N/A 0.0745 0.1127 0.1192 94.5850 AY+11 N/A 0.0745 0.0432 0.0447 96.8412 AY+12 N/A 0.0447 0.0000 0.0000 N/A

Private Passenger Auto Liability/Medical

Unpaid Losses

at Year End

Estimated Losses

(%)

Discounted Unpaid Losses at

Year End

Discount

Factor

(%)

Tax Year

Cumulative Losses Paid

(%)

Paid Each Year

AY+ 0 34.7617 34.7617 58.9016 65.2383 90.2868 AY+ 1 66.2963 31.5346 30.2435 33.7037 89.7336 AY+ 2 81.2140 14.9177 16.8444 18.7860 89.6646 AY+ 3 89.8272 8.6132 9.0671 10.1728 89.1303 AY+ 4 94.4549 4.6277 4.8895 5.5451 88.1776 AY+ 5 96.8788 2.4239 2.7107 3.1212 86.8495 Continued on next page

Unpaid Losses

at Year End

Estimated Losses

(%)

Discounted Unpaid Losses at

Year End

Discount

Factor

(%)

Tax Year

Cumulative Losses Paid

(%)

Paid Each Year

AY+ 6 98.1526 1.2738 1.5751 1.8474 85.2614 AY+ 7 98.6962 0.5436 1.1182 1.3038 85.7661 AY+ 8 99.0485 0.3523 0.8286 0.9515 87.0805 AY+ 9 99.2667 0.2182 0.6582 0.7333 89.7569 AY+10 N/A 0.2182 0.4765 0.5151 92.5079 AY+11 N/A 0.2182 0.2828 0.2969 95.2452 AY+12 N/A 0.2182 0.0762 0.0787 96.8412 AY+13 N/A 0.0787 0.0000 0.0000 N/A

Commercial Auto/Truck Liability/Medical

Unpaid Losses

at Year End

(%)

Estimated Losses

Discounted Unpaid Losses at

Year End

Discount

Factor

(%)

Tax Year

Cumulative Losses Paid

(%)

Paid Each Year

AY+ 0 20.8439 20.8439 69.0004 79.1561 87.1701 AY+ 1 47.3136 26.4697 46.2421 52.6864 87.7685 AY+ 2 65.6475 18.3340 30.3760 34.3525 88.4244 AY+ 3 79.0481 13.4005 18.5522 20.9519 88.5467 AY+ 4 86.8945 7.8465 11.6798 13.1055 89.1220 AY+ 5 92.4503 5.5558 6.7172 7.5497 88.9736 AY+ 6 95.5751 3.1247 3.9359 4.4249 88.9483 AY+ 7 97.3052 1.7302 2.4103 2.6948 89.4420 AY+ 8 98.1469 0.8417 1.7009 1.8531 91.7885 AY+ 9 98.8549 0.7080 1.0826 1.1451 94.5428 AY+10 N/A 0.7080 0.4233 0.4371 96.8412 AY+11 N/A 0.4371 0.0000 0.0000 N/A

Workers’ Compensation

Unpaid Losses

at Year End

Estimated Losses

(%)

Discounted Unpaid Losses at

Year End

Discount

Factor

(%)

Tax Year

Cumulative Losses Paid

(%)

Paid Each Year

AY+ 0 22.3366 22.3366 64.2484 77.6634 82.7268 AY+ 1 50.6941 28.3575 39.2256 49.3059 79.5557 AY+ 2 66.1886 15.4945 25.8264 33.8114 76.3837 AY+ 3 74.4228 8.2342 19.0359 25.5772 74.4253 AY+ 4 79.5663 5.1434 14.9867 20.4337 73.3432 AY+ 5 83.7227 4.1564 11.6883 16.2773 71.8077 AY+ 6 86.1316 2.4089 9.9758 13.8684 71.9321 AY+ 7 88.4452 2.3136 8.2482 11.5548 71.3830 AY+ 8 88.9625 0.5173 8.2608 11.0375 74.8434 AY+ 9 89.9266 0.9641 7.8130 10.0734 77.5606 AY+10 N/A 0.9641 7.3355 9.1093 80.5270 AY+11 N/A 0.9641 6.8263 8.1453 83.8070 AY+12 N/A 0.9641 6.2833 7.1812 87.4975 AY+13 N/A 0.9641 5.7044 6.2171 91.7536 AY+14 N/A 0.9641 5.0871 5.2530 96.8412 AY+15 N/A 5.2530 0.0000 0.0000 N/A

Commercial Multiple Peril

Unpaid Losses

at Year End

Estimated Losses

(%)

Discounted Unpaid Losses at

Year End

Discount

Factor

(%)

Tax Year

Cumulative Losses Paid

(%)

Paid Each Year

AY+ 0 33.4193 33.4193 56.7613 66.5807 85.2519 AY+ 1 59.1296 25.7103 33.9757 40.8704 83.1303 AY+ 2 67.4080 8.2784 27.6799 32.5920 84.9284 Continued on next page

Unpaid Losses

at Year End

Estimated Losses

(%)

Discounted Unpaid Losses at

Year End

Discount

Factor

(%)

Tax Year

Cumulative Losses Paid

(%)

Paid Each Year

AY+ 3 75.7571 8.3491 20.8936 24.2429 86.1844 AY+ 4 83.8673 8.1102 13.9041 16.1327 86.1858 AY+ 5 89.5799 5.7126 8.9270 10.4201 85.6710 AY+ 6 93.4124 3.8325 5.5614 6.5876 84.4217 AY+ 7 95.6455 2.2331 3.6242 4.3545 83.2276 AY+ 8 96.9571 1.3116 2.5101 3.0429 82.4887 AY+ 9 97.4497 0.4926 2.1678 2.5503 85.0017 AY+10 N/A 0.4926 1.8029 2.0577 87.6150 AY+11 N/A 0.4926 1.4137 1.5651 90.3275 AY+12 N/A 0.4926 0.9988 1.0725 93.1260 AY+13 N/A 0.4926 0.5563 0.5799 95.9349 AY+14 N/A 0.4926 0.0845 0.0873 96.8412 AY+15 N/A 0.0873 0.0000 0.0000 N/A

Medical Malpractice

Unpaid Losses

at Year End

Discount

Factor

Estimated Losses

(%)

Discounted Unpaid Losses at

Year End

(%)

Tax Year

Cumulative Losses Paid

(%)

Paid Each Year

AY+ 0 3.7026 3.7026 69.6231 96.2974 72.3001 AY+ 1 11.5535 7.8510 66.1321 88.4465 74.7708 AY+ 2 21.9296 10.3761 59.8022 78.0704 76.6003 AY+ 3 32.8555 10.9259 52.4848 67.1445 78.1669 AY+ 4 46.6164 13.7609 41.7548 53.3836 78.2165 AY+ 5 60.9092 14.2928 29.7641 39.0908 76.1409 AY+ 6 69.2349 8.3257 23.1402 30.7651 75.2157 AY+ 7 71.6574 2.4225 22.1728 28.3426 78.2316 AY+ 8 73.7610 2.1036 21.4707 26.2390 81.8275 AY+ 9 77.8395 4.0786 18.6826 22.1605 84.3062 AY+10 N/A 4.0786 15.7097 18.0819 86.8808 AY+11 N/A 4.0786 12.5396 14.0033 89.5476 AY+12 N/A 4.0786 9.1594 9.9248 92.2886 AY+13 N/A 4.0786 5.5551 5.8462 95.0206 AY+14 N/A 4.0786 1.7118 1.7676 96.8412 AY+15 N/A 1.7676 0.0000 0.0000 N/A

Special Liability (Ocean Marine, Aircraft (all Perils), Boiler and Machinery)

Unpaid Losses

at Year End

Estimated Losses

(%)

Discounted Unpaid Losses at

Year End

Discount

Factor

(%)

Tax Year

Cumulative Losses Paid

(%)

Paid Each Year

AY+ 0 31.2231 31.2231 61.1626 68.7769 88.9290 AY+ 1 68.2247 37.0016 27.0091 31.7753 85.0004 AY+ 2 80.2858 12.0611 16.3453 19.7142 82.9115 AY+ 3 85.4166 5.1308 12.1308 14.5834 83.1827 AY+ 4 89.4028 3.9862 8.8189 10.5972 83.2194 AY+ 5 93.2493 3.8465 5.4316 6.7507 80.4607 AY+ 6 94.0515 0.8022 4.9634 5.9485 83.4397 AY+ 7 95.8901 1.8386 3.3939 4.1099 82.5788 AY+ 8 97.7995 1.9093 1.6473 2.2005 74.8580 AY+ 9 97.9920 0.1925 1.5577 2.0080 77.5737 AY+10 N/A 0.1925 1.4621 1.8155 80.5381 AY+11 N/A 0.1925 1.3603 1.6230 83.8157 AY+12 N/A 0.1925 1.2517 1.4304 87.5033 AY+13 N/A 0.1925 1.1359 1.2379 91.7563 AY+14 N/A 0.1925 1.0124 1.0454 96.8412 AY+15 N/A 1.0454 0.0000 0.0000 N/A

Other Liability

Tax Year

Cumulative Losses Paid

(%)

Unpaid Losses

at Year End

Estimated Losses

(%)

Discounted Unpaid Losses at

Year End

Discount

Factor

Paid Each Year

(%)

AY+ 0 9.9737 9.9737 68.4086 90.0263 75.9874 AY+ 1 21.8819 11.9082 60.6475 78.1181 77.6356 AY+ 2 32.5583 10.6764 53.6438 67.4417 79.5409 AY+ 3 41.4543 8.8960 48.0142 58.5457 82.0115 AY+ 4 56.3583 14.9040 35.8074 43.6417 82.0485 AY+ 5 71.6763 15.3180 22.3638 28.3237 78.9578 AY+ 6 78.0397 6.3635 17.2755 21.9603 78.6670 AY+ 7 82.2566 4.2168 14.0665 17.7434 79.2771 AY+ 8 85.2754 3.0188 11.8818 14.7246 80.6934 AY+ 9 87.4014 2.1260 10.4742 12.5986 83.1378 AY+10 N/A 2.1260 8.9734 10.4727 85.6836 AY+11 N/A 2.1260 7.3730 8.3467 88.3341 AY+12 N/A 2.1260 5.6665 6.2207 91.0905 AY+13 N/A 2.1260 3.8469 4.0948 93.9461 AY+14 N/A 2.1260 1.9066 1.9688 96.8412 AY+15 N/A 1.9688 0.0000 0.0000 N/A

Special Property (Fire, Allied Lines, Inland Marine, Earthquake, Glass, Burglary, and Theft)

Unpaid Losses

at Year End

Estimated Losses

(%)

Discounted Unpaid Losses at

Year End

Discount

Factor

(%)

Tax Year

Cumulative Losses Paid

(%)

Paid Each Year

AY+ 0 57.7817 57.7817 39.8533 42.2183 94.3982 AY+ 1 88.3390 30.5573 10.9415 11.6610 93.8306 AY+ 2 N/A 5.8305 5.6463 5.8305 96.8412 AY+ 3 N/A 5.8305 0.0000 0.0000 N/A

Auto Physical Damage

Unpaid Losses

at Year End

Estimated Losses

(%)

Discounted Unpaid Losses at

Year End

Discount

Factor

(%)

Tax Year

Cumulative Losses Paid

(%)

Paid Each Year

AY+ 0 84.1827 84.1827 15.2177 15.8173 96.2092 AY+ 1 98.8697 14.6870 1.0606 1.1303 93.8306 AY+ 2 N/A 0.5651 0.5473 0.5651 96.8412 AY+ 3 N/A 0.5651 0.0000 0.0000 N/A

Fidelity, Surety, Financial Guaranty, Mortgage Guaranty

Unpaid Losses

at Year End

Estimated Losses

(%)

Discounted Unpaid Losses at

Year End

Discount

Factor

(%)

Tax Year

Cumulative Losses Paid

(%)

Paid Each Year

AY+ 0 25.1728 25.1728 68.7158 74.8272 91.8327 AY+ 1 57.6281 32.4553 39.7578 42.3719 93.8306 AY+ 2 N/A 21.1859 20.5167 21.1859 96.8412 AY+ 3 N/A 21.1859 0.0000 0.0000 N/A

Other (including Credit, Accident and Health)

Unpaid Losses

at Year End

Estimated Losses

(%)

Discounted Unpaid Losses at

Year End

Discount

Factor

(%)

Tax Year

Cumulative Losses Paid

(%)

Paid Each Year

AY+ 0 63.6725 63.6725 34.1976 36.3275 94.1369 AY+ 1 88.8927 25.2202 10.4220 11.1073 93.8306 AY+ 2 N/A 5.5536 5.3782 5.5536 96.8412 AY+ 3 N/A 5.5536 0.0000 0.0000 N/A

International (Composite)

Unpaid Losses

at Year End

Estimated Losses

(%)

Discounted Unpaid Losses at

Year End

Discount

Factor

(%)

Tax Year

Cumulative Losses Paid

(%)

Paid Each Year

AY+ 0 30.8006 30.8006 58.6213 69.1994 84.7137 AY+ 1 56.9235 26.1229 35.5330 43.0765 82.4881 AY+ 2 68.6906 11.7671 25.7379 31.3094 82.2050 AY+ 3 76.7697 8.0791 19.1017 23.2303 82.2275 AY+ 4 83.5336 6.7639 13.3837 16.4664 81.2783 AY+ 5 88.9725 5.4390 8.6546 11.0275 78.4822 AY+ 6 91.6218 2.6493 6.4927 8.3782 77.4953 AY+ 7 93.4305 1.8087 5.0554 6.5695 76.9538 AY+ 8 94.3638 0.9333 4.4269 5.6362 78.5443 AY+ 9 95.0595 0.6957 4.0020 4.9405 81.0046 AY+10 N/A 0.6957 3.5490 4.2448 83.6078 AY+11 N/A 0.6957 3.0659 3.5492 86.3851 AY+12 N/A 0.6957 2.5509 2.8535 89.3943 AY+13 N/A 0.6957 2.0016 2.1578 92.7611 AY+14 N/A 0.6957 1.4160 1.4622 96.8412 AY+15 N/A 1.4622 0.0000 0.0000 N/A

Reinsurance A

Tax Year

Cumulative Losses Paid

(%)

Unpaid Losses

at Year End

Estimated Losses

(%)

Discounted Unpaid Losses at

Year End

Discount

Factor

Paid Each Year

(%)

AY+ 0 35.8044 35.8044 58.7668 64.1956 91.5432 AY+ 1 72.2671 36.4628 25.0109 27.7329 90.1850 AY+ 2 79.1294 6.8622 19.5830 20.8706 93.8306 AY+ 3 N/A 10.4353 10.1057 10.4353 96.8412 AY+ 4 N/A 10.4353 0.0000 0.0000 N/A

Reinsurance B (Composite)

Unpaid Losses

at Year End

Estimated Losses

(%)

Discounted Unpaid Losses at

Year End

Discount

Factor

(%)

Tax Year

Cumulative Losses Paid

(%)

Paid Each Year

Reinsurance C

Tax Year

Cumulative Losses Paid

(%)

Unpaid Losses

at Year End

Estimated Losses

(%)

Discounted Unpaid Losses at

Year End

Discount

Factor

Paid Each Year

(%)

AY+ 0 23.0513 23.0513 69.1110 76.9487 89.8144 AY+ 1 47.1565 24.1051 48.8016 52.8435 92.3512

Continued on next page

Unpaid Losses

at Year End

Estimated Losses

(%)

Discounted Unpaid Losses at

Year End

Discount

Factor

(%)

Tax Year

Cumulative Losses Paid

(%)

Paid Each Year

AY+ 2 73.1742 26.0177 25.1708 26.8258 93.8306 AY+ 3 N/A 13.4129 12.9892 13.4129 96.8412 AY+ 4 N/A 13.4129 0.0000 0.0000 N/A

Miscellaneous Casualty (Composite)

Unpaid Losses

at Year End

(%)

Estimated Losses

Discounted Unpaid Losses at

Year End

Discount

Factor

(%)

Tax Year

Cumulative Losses Paid

(%)

Paid Each Year

AY+ 0 73.9503 73.9503 24.6750 26.0497 94.7226 AY+ 1 93.7601 19.8099 5.8549 6.2399 93.8306 AY+ 2 N/A 3.1199 3.0214 3.1199 96.8412 AY+ 3 N/A 3.1199 0.0000 0.0000 N/A

Long Lines (Composite)

Unpaid Losses

at Year End

Discount

Factor

Estimated Losses

(%)

Discounted Unpaid Losses at

Year End

(%)

Tax Year

Cumulative Losses Paid

(%)

Paid Each Year

Pursuant to § 832(b), the amount of estimated salvage is determined on a discounted basis in accordance with procedures established by the Secretary.

Exceptions & meaning →

SEC. 3. SCOPE¶

This revenue procedure applies to any taxpayer that is required to discount estimated salvage recoverable under § 832.

Exceptions & meaning →

SEC. 4. APPLICATION¶

.01 The following tables present separately for each line of business the discount factors under § 832 for the 1995 accident year. All the discount factors presented in this section were determined using the applicable interest rate under § 846(c) for 1996, which is 6.63 percent, and by assuming all estimated salvage is recovered in the

DRAFTING INFORMATION

The principal author of this revenue procedure is Katherine A. Hossofsky of the Office of the Assistant Chief Counsel (Financial Institutions and Products). For further information regarding this revenue procedure, contact Ms. Hossofsky on (202) 622–3477 (not a tollfree number).

26 CFR 601.201: Rulings and determination let- ters (Also Part I, Sections 832, 846; 1.832–4, 1.846– 1.)

Rev. Proc. 96–45

Exceptions & meaning →

SECTION 1. PURPOSE¶

This revenue procedure prescribes the salvage discount factors for the 1996 accident year. These factors will be used

for computing discounted estimated salvage recoverable under § 832 of the Internal Revenue Code.

Exceptions & meaning →

SEC. 2. BACKGROUND¶

Section 832(b)(5)(A) requires that all estimated salvage recoverable (including that which cannot be treated as an asset for state accounting purposes) be taken into account in computing the deduction for losses incurred. Under § 832(b)(5)(A), paid losses are to be reduced by salvage and reinsurance recovered during the taxable year. This amount is adjusted to reflect changes in discounted unpaid losses on nonlife insurance contracts and in unpaid losses on life insurance contracts. An adjustment is then made to reflect any changes in discounted estimated salvage recoverable and in reinsurance recoverable.

middle of each calendar year. See Rev. Proc. 91–48, 1991–2 C.B. 760, for background regarding the tables.

.02 These tables must be used by taxpayers irrespective of whether they elected to discount unpaid losses using their own historical experience under § 846.

.03 Tables.

AY+ 7 89.4420 AY+ 8 91.7885 AY+ 9 94.5428 AY+10 96.8412

Workers’ Compensation

Discount

Tax Year

Factor

(%)

Factor

(%)

AY+ 9 84.3062 AY+10 86.8808 AY+11 89.5476 AY+12 92.2886 AY+13 95.0206 AY+14 96.8412

Special Liability (Ocean Marine, Aircraft (all Perils), Boiler and Machinery)

Tables of Discount Factors

Discount

Salvage Recoverable

Factor

(%)

- 1996 Interest rate: 6.63 percent

Tax Year

Discount

Homeowners/Farmowners

Tax Year

(%)

Factor

(%)

Discount

Tax Year

Factor

AY+ 0 92.4763 AY+ 1 87.0955 AY+ 2 88.2656 AY+ 3 89.1817 AY+ 4 89.7376 AY+ 5 88.9620 AY+ 6 89.6468 AY+ 7 89.0559 AY+ 8 89.1020 AY+ 9 91.8346 AY+10 94.5850 AY+11 96.8412

Private Passenger Auto Liability/Medical

AY+ 0 82.7268 AY+ 1 79.5557 AY+ 2 76.3837 AY+ 3 74.4253 AY+ 4 73.3432 AY+ 5 71.8077 AY+ 6 71.9321 AY+ 7 71.3830 AY+ 8 74.8434 AY+ 9 77.5606 AY+10 80.5270 AY+11 83.8070 AY+12 87.4975 AY+13 91.7536 AY+14 96.8412

Commercial Multiple Peril

Tax Year

Discount

AY+ 0 88.9290 AY+ 1 85.0004 AY+ 2 82.9115 AY+ 3 83.1827 AY+ 4 83.2194 AY+ 5 80.4607 AY+ 6 83.4397 AY+ 7 82.5788 AY+ 8 74.8580 AY+ 9 77.5737 AY+10 80.5381 AY+11 83.8157 AY+12 87.5033 AY+13 91.7563 AY+14 96.8412

Other Liability

Factor

(%)

Discount

AY+ 0 85.2519 AY+ 1 83.1303 AY+ 2 84.9284 AY+ 3 86.1844 AY+ 4 86.1858 AY+ 5 85.6710 AY+ 6 84.4217 AY+ 7 83.2276 AY+ 8 82.4887 AY+ 9 85.0017 AY+10 87.6150 AY+11 90.3275 AY+12 93.1260 AY+13 95.9349 AY+14 96.8412

Medical Malpractice

Discount

Tax Year

Factor

(%)

Tax Year

Factor

(%)

AY+ 0 90.2868 AY+ 1 89.7336 AY+ 2 89.6646 AY+ 3 89.1303 AY+ 4 88.1776 AY+ 5 86.8495 AY+ 6 85.2614 AY+ 7 85.7661 AY+ 8 87.0805 AY+ 9 89.7569 AY+10 92.5079 AY+11 95.2452 AY+12 96.8412

Commercial Auto/Truck Liability/ Medical

Discount

AY+ 0 75.9874 AY+ 1 77.6356 AY+ 2 79.5409 AY+ 3 82.0115 AY+ 4 82.0485 AY+ 5 78.9578 AY+ 6 78.6670 AY+ 7 79.2771 AY+ 8 80.6934 AY+ 9 83.1378 AY+10 85.6836 AY+11 88.3341 AY+12 91.0905 AY+13 93.9461 AY+14 96.8412

Special Property (Fire, Allied Lines, Inland Marine, Earthquake, Glass, Burglary, and Theft)

Discount

Tax Year

Factor

(%)

Tax Year

Factor

(%)

AY+ 0 87.1701 AY+ 1 87.7685 AY+ 2 88.4244 AY+ 3 88.5467 AY+ 4 89.1220 AY+ 5 88.9736 AY+ 6 88.9483

AY+ 0 72.3001 AY+ 1 74.7708 AY+ 2 76.6003 AY+ 3 78.1669 AY+ 4 78.2165 AY+ 5 76.1409 AY+ 6 75.2157 AY+ 7 78.2316 AY+ 8 81.8275

AY+ 0 89.4016 AY+ 1 91.1418 AY+ 2 92.1391 Continued on next page

Discount

Tax Year

Factor

(%)

Discount

Tax Year

Factor

(%)

Factor

(%)

Factor

(%)

AY+ 3 93.5634 AY+ 4 94.5558 AY+ 5 96.2074 AY+ 6 96.8412

Auto Physical Damage

Discount

AY+ 7 76.9538 AY+ 8 78.5443 AY+ 9 81.0046 AY+10 83.6078 AY+11 86.3851 AY+12 89.3943 AY+13 92.7611 AY+14 96.8412

Reinsurance A

AY+ 4 86.0620 AY+ 5 88.4270 AY+ 6 91.0715 AY+ 7 93.8805 AY+ 8 96.8412

Miscellaneous Casualty (Composite)

Discount

Tax Year

Factor

(%)

Factor

(%)

AY+ 0 95.1966 AY+ 1 95.6676 AY+ 2 96.8412

Fidelity, Surety, Financial Guaranty, Mortgage Guaranty

Discount

AY+ 0 85.0124 AY+ 1 86.9026 AY+ 2 87.8050 AY+ 3 89.0382 AY+ 4 90.2502 AY+ 5 91.6718 AY+ 6 92.9603 AY+ 7 94.5573 AY+ 8 96.8412

Long Lines (Composite)

Tax Year

Factor

(%)

Discount

Tax Year

Factor

(%)

AY+ 0 84.0469 AY+ 1 86.4207 AY+ 2 87.7821 AY+ 3 89.4142 AY+ 4 91.0835 AY+ 5 92.7170 AY+ 6 93.9699 AY+ 7 95.0086 AY+ 8 96.8412

Other (including Credit, Accident and Health)

AY+ 0 77.0244 AY+ 1 80.3308 AY+ 2 82.0405 AY+ 3 83.8941 AY+ 4 86.0620 AY+ 5 88.4270 AY+ 6 91.0715 AY+ 7 93.8805 AY+ 8 96.8412

Reinsurance B (Composite)

AY+ 0 84.7137 AY+ 1 82.4881 AY+ 2 82.2050 AY+ 3 82.2275 AY+ 4 81.2783 AY+ 5 78.4822 AY+ 6 77.4953 AY+ 7 76.9538 AY+ 8 78.5443 AY+ 9 81.0046 AY+10 83.6078 AY+11 86.3851 AY+12 89.3943 AY+13 92.7611 AY+14 96.8412

Reinsurance C

Discount

Factor

(%)

Discount

Tax Year

Factor

(%)

Discount

Tax Year

Factor

(%)

AY+ 0 89.9648 AY+ 1 91.7311 AY+ 2 92.9067 AY+ 3 94.5018 AY+ 4 95.8377 AY+ 5 96.8412

International (Composite)

Discount

Tax Year

Factor

(%)

DRAFTING INFORMATION

AY+ 0 84.7137 AY+ 1 82.4881 AY+ 2 82.2050 AY+ 3 82.2275 AY+ 4 81.2783 AY+ 5 78.4822 AY+ 6 77.4953

AY+ 0 77.0244 AY+ 1 80.3308 AY+ 2 82.0405 AY+ 3 83.8941

Discount

Tax Year

Factor

(%)

Exceptions & meaning →

Part IV. Items of General Interest¶

published in the Federal Register on Wednesday, May 29, 1996 (61 FR 26788). The final regulations relate to requirements for furnishing a taxpayer identifying number on returns, statements or other documents.

EFFECTIVE DATE: May 29, 1996.

FOR FURTHER INFORMATION CONTACT: Lilo A. Hester, (202) 874–1490 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final regulations that are the subject of these corrections are under section 6109 of the Internal Revenue Code.

Need for Correction

As published, TD 8671 contains errors that are in need of correction.

Correction of Publication

Accordingly, the publication of final regulations which are the subject of FR Doc. 96–13397 is corrected as follows:

On page 26790, column 1, in amendatory instruction ‘‘ Par 2. ’’, line 1, the language ‘‘Section § 301.6109–1 is’’ is corrected to read ‘‘Section 301.6109–1 is’’.

§ 301.6109–1 [Corrected]

On page 26791, columns 1 and 2, § 301.6109–1(d)(3)(iv)(A)(1) is corrected to read as follows:

§ 301.6109–1 Identifying numbers.

- - - -

(d) - - (3) - - (iv) - - (A) - - ( 1 ) Procedures for providing Form SS–4 and Form W–7, or such other necessary form to applicants for obtaining a taxpayer identifying number;

- - - -

On page 26792, column 2, § 301.6109–1(h)(1), line 8, the language ‘‘identification numbers apply after

Effective Date Extension for Certain Payors Revising Their Substitute Forms W–9

Announcement 96–77

This announcement extends the January 1, 1997, effective date of certain provisions of Rev. Proc. 96–26, 1996–8 I.R.B. 22, for certain payors. That revenue procedure provides requirements for payors of interest, dividends, and patronage dividends, and brokers that want to design and provide their own substitute Form W–9, Request for Taxpayer Identification Number and Certification, to obtain the required taxpayer identification number and ‘‘no backup withholding’’ certifications from their payees.

The effective date of Rev. Proc. 96–26 (other than for section 5 relating to certain impermissible uses of the required certifications) is extended to July 1, 1997, if a payor (1) is required to obtain the approval of a governmental authority for changes to the format of its substitute Form W–9 required by Rev. Proc. 96–26, (2) applies, on or before September 30, 1996, for that approval, and (3) thereafter actively pursues that approval.

The principal author of this announcement is John Coulter of the Office of Assistant Chief Counsel (Income Tax and Accounting). For further information regarding this announcement contact Mr. Coulter at (202) 622–4910 (not a tollfree call).

Revision of Section 482 Cost Sharing Regulations; Correction

Announcement 96–78

AGENCY: Internal Revenue Service, Treasury.

ACTION: Correction to final regulations.

SUMMARY: This document contains corrections to final regulations (TD 8670 [1996–24 I.R.B. 6]), which were published in the Federal Register on Monday, May 13, 1996 (61 FR 21955) relating to qualified cost sharing arrangements.

EFFECTIVE DATE: May 13, 1996.

FOR FURTHER INFORMATION CONTACT: Lisa Sams (202) 622–3840, (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final regulations that are the subject of these corrections are under section 482 of the Internal Revenue Code.

Need for Correction

As published, the final regulations contain errors which may prove to be misleading and are in need of clarification.

Correction of Publication

Accordingly, the publication of the final regulations (TD 8670), which are the subject of FR Doc. 96–11781, is corrected as follows:

§ 1.482–7 [Corrected]

On page 21956, column 2, instructional ‘‘ Par. 3. ’’, is corrected by revising item g. to read as follows: g. By redesignating the introductory text of paragraph (j)(2) following the heading and paragraphs (j)(2)(i) through (j)(2)(v) as the introductory text of paragraph (j)(2)(i) and paragraphs (j)(2)(i)(A) through (j)(2)(i)(E), respectively; and, by adding a heading to newly designated paragraph (j)(2)(i).

Cynthia E. Grigsby, Chief, Regulations Unit, Assistant Chief Counsel (Corporate).

(Filed by the Office of the Federal Register on June 27, 1996, 8:45 a.m., and published in the issue of the Federal Register for June 28, 1996, 61 F.R. 33656)

Taxpayer Identifying Numbers (TINs); Correction

Announcement 96–79

AGENCY: Internal Revenue Service, Treasury.

ACTION: Correction to final regulations.

SUMMARY: This document contains corrections to final regulations (TD 8671 [1996–26 I.R.B. 8]) which were

15 1996–35 I.R.B.

May’’ is corrected to read ‘‘identification numbers apply on and after May’’.

Cynthia E. Grigsby, Chief, Regulations Unit, Assistant Chief Counsel (Corporate).

(Filed by the Office of the Federal Register on June 27, 1996, 8:45 a.m., and published in the issue of the Federal Register for June 28, 1996, 61 F.R. 33657)

Foundations Status of Certain Organizations

Announcement 96–80

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 designations in the Cumulative List of Organizations (Publication 78), or on the presumption arising from the filing of notices under section 508(b) of the Code. This listing does not indicate that the organizations have lost their status as organizations described in section 501(c)(3), eligible to receive deductible contributions.

Former Public Charities. The following organizations (which have been treated as organizations that are not private foundations described in section 509(a) of the Code) are now classified as private foundations: AFTL Ambassadors for the Lord

Center for Family Resources Inc.,

OH Creative Playgrounds of Nutley a New

Jersey Non-Profit Corporation, Nutley, NJ Cumberland-Goodwill Fire & Rescue,

Metuchen, NJ Center for Industrial Preservation Inc.,

Desert Shield-Storm Family Foundation

Petersburg, VA Center for Justice and International Law,

Inc., Wall, NJ De Unique Incorporated, Cheverly, MD Elizabeth Williams Group Home, Akron,

OH Environmental Awareness Group, Inc.,

Washington, DC Center for Language Development Inc.,

Boston, MA Holiday House II, Philadelphia, PA Indian Head Literacy Coalition, New

East Orange, NJ Center for Public Information on

Richmond, WI International Human Rights Consulting

Electromagnetic Radiation Inc., Milltown, NJ Central Roxborough Civic Assoc.,

Philadelphia, PA Centre County Columbus Celebration,

Group, Washington, DC Lommen Nelson Cole & Stageberg

Foundation, Minneapolis, MN Manchester Supportive Housing Inc.,

State College, PA Charitable Foundation of the Rotary

Oakmont, PA Mathieu Mategot Foundation for

Club of Roanoke Valley Inc., Roanoke, VA Charles County Dive Rescue Inc.,

Waldorf, MD Chinese Academic Link USA Inc.,

Contemporary Tapestry Inc., Bethesda, MD Medical Foundation of Cincinnati,

Hyattsville, MD Christe Inc., Cincinnati, OH Citizens Information Inc., Chester, NJ College Bound Inc., Washington, DC College of Exploration, Vienna, VA Committee of 100 Dorchester Inc.,

Cambridge, MD Common Concerns Broadcasting Inc.,

Cincinnati, OH Paul Morgan Academy, Fort Worth, TX Networking for Jesus, Houston, TX Northeast Scattered Site Resident

Management Corp., Chicago, IL Northwest Perry Township

Trenton, NJ Community Council for the Homeless,

Washington, DC Concerned African American Parents of

Revitalization Group, Lima, OH Out of Bondage Ministries, Inc., La

Salle, CO Prime Life Foundation, Reston, VA Recreational Boating Industries

Educational Foundation, Romeo, MI Remote Sensing Research Incorporated,

Westfield, Westfield, NJ Conservative Christian Action Group

Inc., Elkhart, WI Corrigan Ministries, Inc., Cincinnati,

Fort Collins, CO Reverend Charles Brink Scholarship

Trust, Inc., Kansas City, KS Shelter Company, Lebanon, VA Tri-County Recreational Center Inc.,

Inc., Virginia Beach, VA Wings to Needs Incorporated, LaGrange,

KY 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 determination letter with the revised classification as to foundation status. Grantors and contributors may thereafter rely upon such ruling or determination letter as provided in section 1.509(a)–7 of the Income Tax Regulations. It is not the practice of the Service to announce such revised classification of foundation status in the Internal Revenue Bulletin.

Ministries, Garland, TX American Laryngeal Papilloma

Foundation, Lake Hiawatha, NJ American Values, Washington, DC Apostolic Christian Village Inc.,

Chestertown, NY Virginia Beach Lifeguard Association

Francesville, IN Applewick Sports Fitness Club, East

Carlisle, PA Cure (Citizens Urge Rescue of the

Environment), Hanover, PA Curwensville Development Corp.,

Chicago, IN Aspens Celebration of Indigenous

Cultures, Aspen, CO Balloon Project, Inc., Port Chester, NY Beatrice K. Compten Memorial Trust,

Beaver Falls, PA Bicycle Service Racing Team, Wichita,

Curwensville, PA Daffodil West Hermitage, Cimarron,

Dallas, TX Damocles Inc., Arlington, VA Dancers Unlimited Performing

NM Dallas Contemporary Art Museum,

KS Bogota Resque Squad, Bogota, NJ Books for Democracy Incorporated,

Alexandria, VA Breakthrough Breast Cancer, Bloomfield

Hills, MI Breast Cancer Resource Committee Inc.,

Ensemble, Wilmington, DE Dawson Bucs Little League Teams,

Rawlings, MD Debate America, Washington, DC Delaware Valley Alliance for RIF,

Norristown, PA

Washington, DC

1996–35 I.R.B. 16

Numerical Finding List ¹

Bulletins 1996–27 through 1996–34

Announcements: 96–61, 1996–27 I.R.B. 72 96–62, 1996–28 I.R.B. 55 96–63, 1996–29 I.R.B. 18 96–64, 1996–29 I.R.B. 18 96–65, 1996–29 I.R.B. 18 96–66, 1996–29 I.R.B. 19 96–67, 1996–30 I.R.B. 27 96–68, 1996–31 I.R.B. 45 96–69, 1996–32 I.R.B. 38 96–70, 1996–32 I.R.B. 40 96–71, 1996–33 I.R.B. 16 96–72, 1996–33 I.R.B. 16 96–73, 1996–33 I.R.B. 18 96–74, 1996–33 I.R.B. 19 96–75, 1996–34 I.R.B. 29 96–76, 1996–34 I.R.B. 29

Court Decisions: 2058, 1996–34 I.R.B. 13 2059, 1996–34 I.R.B. 10 2060, 1996–34 I.R.B. 5

Notices:

96–36, 1996–27 I.R.B. 11 96–37, 1996–31 I.R.B. 29 96–38, 1996–31 I.R.B. 29 96–39, 1996–32 I.R.B. 8 96–40, 1996–33 I.R.B. 11

Proposed Regulations:

CO–9–96, 1996–34 I.R.B. 20 CO–24–96, 1996–30 I.R.B. 22 CO–25–96, 1996–31 I.R.B. 30 CO–26–96, 1996–31 I.R.B. 31 FI–28–96, 1996–31, I.R.B. 33 FI–32–95, 1996–34 I.R.B. 21 FI–48–95, 1996–31 I.R.B. 36 FI–59–94, 1996–30 I.R.B. 23 GL–7–96, 1996–33 I.R.B. 13 IA–26–94, 1996–30 I.R.B. 24 IA–29–96, 1996–33 I.R.B. 14 IA-292-84, 1996–28 I.R.B. 38 PS–22–96, 1996–33 I.R.B. 15 PS–39–93, 1996–34 I.R.B. 27

Public Laws:

104–117, 1996–34 I.R.B. 19

Railroad Retirement Quarterly Rate 1996–29 I.R.B. 14

Revenue Procedures:

96–36, 1996–27 I.R.B. 11 96–37, 1996–29 I.R.B. 16 96–39, 1996–33 I.R.B. 11 96–40, 1996–32 I.R.B. 8 96–41, 1996–32 I.R.B. 9 96–42, 1996–32 I.R.B. 14

Revenue Rulings:

96–33, 1996–27 I.R.B. 4 96–34, 1996–28 I.R.B. 4 96–35, 1996–31 I.R.B. 4 96–36, 1996–30 I.R.B. 6 96–37, 1996–32 I.R.B. 4 96–38, 1996–33 I.R.B. 4 96–39, 1996–34 I.R.B. 4

1A cumulative list of all Revenue Rulings, Revenue Procedures, Treasury Decisions, etc., published in Internal Revenue Bulletins 1996–1 through 1996–26 will be found in Internal Revenue Bulletin 1996–27, dated July 1, 1996.

Tax Conventions: 1996–28 I.R.B. 36

Treasury Decisions: 8673, 1996–27 I.R.B. 4 8674, 1996–28 I.R.B. 7 8675, 1996–29 I.R.B. 5 8676, 1996–30 I.R.B. 4 8677, 1996–30 I.R.B. 7 8678, 1996–31 I.R.B. 11 8679, 1996–31 I.R.B. 4 8680, 1996–33 I.R.B. 5

Finding List of Current Action on Previously Published Items ¹

Bulletins 1996–27 through 1996–34

*Denotes entry since last publication

Revenue Procedures:

80–27 Modified by 96–40, 1996–32 I.R.B. 8

87–32 Modified by TD 8680, 1996–33 I.R.B. 5

92–20 Modified by TD 8680, 1996–33 I.R.B. 5

95–29 Superseded by 96–36, 1996–27 I.R.B. 11

95–29A Superseded by 96–36, 1996–27 I.R.B. 11

95–30 Superseded by 96–42, 1996–32 I.R.B. 14

1A cumulative finding list for previously published items mentioned in Internal Revenue Bulletins 1996–1 through 1996–26 will be found in Internal Revenue Bulletin 1996–27, dated July 1, 1996.

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