Part IV. Items — Internal Revenue Bulletin 1996-37

Notice of Proposed Rulemaking and Notice of Public Hearing

Treatment of Section 355 Distributions by U.S. Corporations to Foreign Persons

REG–209827–96

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking by cross-reference to temporary regulations and notice of public hearing.

SUMMARY: In - * * TD 8682, page 4, this Bulletin, the IRS is issuing temporary regulations revising the final regulations under section 367(e)(1) with respect to section 355 distributions of stock or securities by domestic corporations to foreign persons. The IRS is also modifying the temporary regulations under section 6038B to provide that distributions described under section 367(e)(1) are subject to rules under section 6038B. The text of those temporary regulations also serves as the text of these proposed regulations. This document also provides notice of a public hearing on these proposed regulations.

DATES: Written comments must be received by November 7, 1996. Outlines of topics to be discussed at the public hearing scheduled for November 20, 1996, at 10 a.m. must be received by October 31, 1996.

ADDRESSES: Send submissions to: CC:DOM:CORP:R (INTL 0020–96), room 5228, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044. In the alternative, submissions may be hand delivered between the hours of 8 a.m. and 5 p.m. to: CC:DOM:CORP:R (INTL–0020–96), Courier’s Desk, Internal Revenue Service, 1111 Constitution Ave. NW., Washington, DC. The public hearing will be held in the IRS Auditorium, Internal Revenue Building, 1111 Constitution Avenue NW., Washington, DC.

FOR FURTHER INFORMATION CONTACT: Concerning the regulations, Philip L. Tretiak at (202) 622–3860; concerning submissions and the hearing, Evangelista Lee at (202) 622–7180 (not toll-free numbers).

SUPPLEMENTARY INFORMATION:

Paperwork Reduction Act

The collection of information contained in this notice of proposed rulemaking has been submitted to the Office of Management and Budget for review in accordance with the Paperwork Reduction Act of 1995 (44 U.S.C. 3507). Comments on the collection of information should be sent to the Office of Management and Budget, Attn: Desk Officer for the Department of Treasury, Office of Information and Regulatory Affairs, Washington, DC 20503, with copies to the Internal Revenue Service, Attn: IRS Reports Clearance Officer, T:FP, Washington, DC 20224. Alternatively, taxpayers may submit comments electronically via the Internet by selecting the ‘‘Tax Regs’’ option on the IRS Home Page, or by submitting comments directly to the IRS Internet site at http://www.irs.ustreas.gov/prod/tax regs/ comments.html. Comments on the collection of information should be received by October 15, 1996.

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection of information displays a valid control number.

The collection of information under section 367(e)(1) is in § 1.367(e)– 1T(c)(1)(ii), (2)(i)(C) and (3). The temporary regulations provide that in order for taxpayers to qualify for either the ‘‘U.S. real property holding corporation exception’’ or the ‘‘publicly traded corporation’’ exception, taxpayers must comply with the reporting requirements contained in § 1.367(e)–1T(c)(1)(ii) and § 1.367(e)–1T(c)(2)(i)(C), respectively. The temporary regulations also modify the reporting requirements under the ‘‘gain recognition agreement’’ exception (§ 1.367(e)–1T(c)(3)). Under the temporary regulations, the controlled corporation, in addition to the distributing corporation, must sign the gain recognition agreement (§ 1.367(e)–1T(c)(3)(ii)(F) and (iii)), extend the statute of limitations accordingly (§ 1.367(e)–1T(c)(3)(ii)(F) and (iv)), and annually report its distributees to the distributing corporation but not the Service (§ 1.367(e)– 1T(c)(3)(v)(B)). This information is required by the IRS as a condition for a taxpayer to qualify for an exception to the general rule of taxation under sec

tion 367(e)(1), and to avoid the penalties contained under section 6038B. This information will be used to determine whether a taxpayer properly qualifies for a claimed exception. The respondents generally will be U.S. corporations, probably subsidiaries of foreign multinationals, that are either distributing another corporation or being distributed under section 355, pursuant to a corporate restructuring.

Books or records relating to a collection of information must be retained as long as their contents may become material in the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by 26 U.S.C. 6103.

Estimated total annual reporting burden: 2,124 hours. (This equals the sum of (i) the prior burden of 1,604 hours, and (ii) the additional burden of 520 hours contained in the new regulations.) The estimated annual burden per respondent varies from 1 hour to 8 hours, depending on individual circumstances, with an estimated average of 2 hours.

Estimated number of respondents: 462. Estimated annual frequency of responses: Once (in the case of taxpayers that qualify for the U.S. real property holding company exception and the publicly traded company exception). Annually (in the case of taxpayers that qualify for the gain recognition agreement exception).

Background

The *** T.D. 8682, page 4 in this Bulletin, amends the Income Tax Regulations (26 CFR part 1) under section 367(e)(1). The temporary regulations under section 367(e)(1) contain rules relating to the distribution of stock or securities under section 355 by a domestic corporation to a person that is not a U.S. person.

The text of T.D. 8682 also serves as the text of these proposed regulations. The preamble to T.D. 8682 explains the reasons for the modifications to the final regulations contained in the temporary regulations.

Special Analyses

It has been determined that this notice of proposed rulemaking is not a significant regulatory action as defined in EO

19 1996–37 I.R.B.

Therefore, a regulatory assessment is not required. It is hereby certified that these regulations do not have a significant impact on a substantial number of small entities. This certification is based on the fact that these regulations will primarily affect large multinational corporations with foreign shareholders. The regulations do not significantly alter the reporting or recordkeeping duties of small entities. Therefore, a Regulatory Flexibility Analysis under the Regulatory Flexibility Act (5 U.S.C. chapter 6) is not required. Pursuant to section 7805(f) of the Internal Revenue Code, this notice of proposed rulemaking will be submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on their impact on small business.

Comments and Notice of Public Hearing

Before these proposed regulations are adopted as final regulations, consideration will be given to any written comments (a signed original and eight (8) copies) that are submitted timely to the Internal Revenue Service. All comments will be available for public inspection and copying.

A public hearing has been scheduled for November 20, 1996, at 10 a.m. in the IRS Auditorium. Because of access restrictions, visitors will not be admitted beyond the building lobby more than 15 minutes before the hearing starts.

The rules of 26 CFR 601.601(a)(3) apply to the hearing.

Persons that wish to present oral comments at the hearing must submit written comments by November 7, 1996, and submit an outline of the topics to be discussed and the time to be devoted to each topic (signed original and eight (8) copies) by October 31, 1996. A period of 10 minutes will be allotted to each person for making comments.

An agenda showing the scheduling of the speakers will be prepared after the deadline for receiving outlines has passed. Copies of the agenda will be available free of charge at the hearing.

Drafting Information

The principal author of these proposed regulations is Philip L. Tretiak of the Office of Associate Chief Counsel (International), IRS. However, other personnel from the IRS and Treasury Department participated in their development.

- - - -

Proposed Amendments to the Regula- tions

Accordingly, 26 CFR part 1 is proposed to be amended as follows:

PART 1—INCOME TAXES

Paragraph 1. The authority citation for part 1 continues to read in part as follows:

Authority: 26 U.S.C. 7805. - - Par. 2. Section 1.367(e)–1 is added to read as follows:

§ 1.367(e)–1 Treatment of section 355 distributions by U.S. corporations to foreign persons.

[The text of this proposed section is the same as the text of § 1.367(e)–1T published in T.D. 8682, page 4 of this Bulletin].

Par. 3. Section 1.6038B–1, as proposed on May 16, 1986, at 51 FR 17990, is amended by revising the second sentence of paragraph (b)(2)(i) and adding the text of paragraph (e) to read as follows:

§ 1.6038B–1 Reporting of transfers de- scribed in section 367.

[The text of proposed paragraphs (b)(2)(i) and (e) are the same as the text of § 1.6038B–1T(b)(2)(i) and (e) published in T.D. 8682, page 4 of this Bulletin].

Margaret Milner Richardson, Commissioner of Internal Revenue.

(Filed by the Office of the Federal Register on August 9, 1996, 12:19 p.m., and published in the issue of the Federal Register for August 14, 1996, 61 F.R. 42217)

Excise Tax Changes

Announcement 96–85

The Small Business Job Protection Act of 1996, which was signed into law on August 20, 1996, makes the following changes to Federal excise taxes. These changes will be reflected on Form 720, Quarterly Federal Excise Tax Return; Form 4136, Credit for Federal Tax Paid on Fuels; and Form 8849, Refund of Excise Taxes.

I. TAX ON AVIATION GASOLINE

Tax is imposed on aviation gasoline (IRS No. 14) at a rate of 19.3 cents per gallon beginning on August 27, 1996, and ending December 31, 1996.

Also effective August 27, 1996, the tax on aviation gasoline is imposed in the same manner as on other gasoline, rather than partly at the retail level. The former retail level tax of one cent per gallon is repealed. Thus, a tax of 19.3 cents per gallon will be imposed on the removal of aviation gasoline from a terminal at the terminal rack.

II. TAX ON AVIATION FUEL (OTHER THAN GASOLINE)

Tax is imposed on aviation fuel (other than gasoline) (IRS No. 69) at a rate of 21.8 cents per gallon beginning on August 27, 1996, and ending December 31, 1996.

III. FLOOR STOCKS TAX ON AVIATION FUEL (OTHER THAN GASOLINE)

A floor stocks tax is imposed on any person that holds previously-taxed aviation fuel (other than gasoline) on the first moment of August 27, 1996. The rate of the floor stocks tax is 17.5 cents per gallon. The floor stocks tax payment is due by March 1, 1997.

The floor stocks tax does not apply to aviation fuel held for use in foreign trade or in military aircraft. Also, the floor stocks tax does not apply if the aggregate amount of aviation fuel held by a person or related group of persons on August 27, 1996, is not more than 2,000 gallons. Aviation fuel held for an exempt use is not taken into account for purposes of calculating the 2,000 gallons.

IV. DIESEL FUEL FOR MOTORBOATS

Between August 27, 1996, and December 31, 1997, the use of diesel fuel in a motorboat is exempt from tax and the penalty for misuse of dyed diesel fuel does not apply to use in a motorboat. Thus, you may now use either dyed diesel fuel (which has not been previously taxed) or undyed diesel fuel (on which tax has been paid) in a motorboat. If you use dyed fuel, no penalty will be imposed on that use. If you use undyed diesel fuel, you may claim a credit or refund of the tax paid on that fuel. Only the purchaser may make this claim. The seller of the fuel is not eligible for a credit or refund.

V. GASOHOL BLENDERS

The gasohol blender credit (or refund) under section 6427(f) has been reinstated, retroactive to October 1, 1995.

1996–37 I.R.B. 20

Claims for gasoline used to produce gasohol that was sold or used before April 1, 1996, must be taken as an income tax credit on Form 4136.

For sales or uses after March 31, 1996, you may use Form 8849 (Rev. April 1996). Print the rate and amount in the shaded area of line 10. The rates per gallon of gasoline used in blending are: Percentage of alcohol in the gasohol Rate

At least 10% $.03967 At least 7.7% alcohol but less .02979 than 10%

VIII. OZONE-DEPLETING CHEMICALS (ODCs)

Effective August 27, 1996, no tax is imposed on ODCs (IRS No. 98) used as propellants in metered-dose inhalers.

IX. LUXURY TAX

Effective for sales after August 27, 1996, the luxury tax on passenger automobiles (IRS No. 92) decreases from 10% to 9% and applies to the amount by which the sales price exceeds $34,000. The base amount for 1996 ($34,000) has not changed. For example, for a sale after August 27, 1996, if the sales price of the automobile is $35,000, the tax is $90 (9% of $1,000). This tax will be phased down one percentage point each year through the year 2002.

X. HOW TO GET FORMS

IRS Forms can be obtained by calling 1–800–829–3676 or downloaded from the IRS Internet Home Page at ftp:// irs.ustreas.gov.

Information Reporting and Backup Withholding; Correction

Announcement 96–86

AGENCY: Internal Revenue Service, Treasury.

ACTION: Correction to final regulations.

SUMMARY: This document contains corrections to final regulations (TD 8664 [1996–20 I.R.B. 7]) which were published in the Federal Register on Monday, April 22, 1996 (61 FR 17572). The final regulations provide rules regarding the reporting on Form 1042–S of certain bank deposit interest paid with respect to a United States bank account to an individual who is a nonresident alien of the United States and a resident of Canada.

EFFECTIVE DATE: January 1, 1997.

FOR FURTHER INFORMATION CONTACT: Teresa Burridge Hughes, (202) 622–3880 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final regulations which are the subject of these corrections are under sections 3406 and 6049 of the Internal Revenue Code.

Need for Correction

As published, the final regulations (TD 8664) contain errors which may prove to be misleading and are in need of clarification.

Correction of Publication

Accordingly, the publication of final regulations (TD 8664), which are the subject of FR Doc. 96–9456 is corrected as follows:

On page 17572, column 3, in the preamble following the paragraph heading ‘‘ Paperwork Reduction Act ’’, the first line of the column, the language ‘‘Washington DC 20224, and the Office of’’ is corrected to read ‘‘Washington, DC 20224, and the Office of’’.
On page 17573, column 1, in the preamble following the paragraph heading ‘‘ B. Comments on Canadian Report- ing Provisions ’’, the third paragraph, line 5, the language ‘‘the Form 1042–S to be the transmittal’’ is corrected to read ‘‘the Form 1042 to be the transmittal’’.

Part 1 [Corrected]

On page 17573, column 2, in the authority citation, line 2, the language ‘‘Sections 1.6049–4 also issued under 26’’ is corrected to read ‘‘Section 1.6049–4 also issued under 26’’.

§ 1.6049–6 [Corrected]

On page 17574, column 1, § 1.6049–6(e)(4), the fourth line from the bottom of the paragraph, the language ‘‘information on the Form is being’’ is corrected to read ‘‘information on the form is being’’.

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

(Filed by the Office of the Federal Register on August 6, 1996, 8:45 a.m., and published in the issue of the Federal Register for August 7, 1996, 61 F.R. 40993)

Deletions from Cumulative List of Organizations Contributions to Which Are Deductible Under Section 170 of the Code

Announcement 96–87

The names of organizations that no longer qualify as organizations described in section 170(c)(2) of the Internal Revenue Code of 1986 are listed below.

Generally, the Service will not disallow deductions for contributions made

At least 5.7% alcohol but less than 7.7%

.02979

.02158

Write ‘‘GASOHOL CLAIM’’ at the top of Form 8849 and on the envelope. Mail your claim to the service center using the special addresses under Where to File on page 1 of the Instructions for Form 8849. Note that refund claims for sales or uses between April 1, 1996, and June 30, 1996, must be filed by September 30, 1996.

VI. AIR TRANSPORTATION TAXES

The following taxes apply to amounts paid on or after August 27, 1996, for transportation beginning on or after August 27, 1996, and before January 1, 1997. No tax applies to amounts paid before August 27, 1996, and, unless extended by future legislation, these taxes will not apply to amounts paid for transportation beginning after December 31, 1996.

IRS No. Tax

26 Transportation of persons by air

28 Transportation of property by air

27 Use of international air travel facilities

Tax rate

10%

6.25%

$6.00

The exemption for emergency medical transportation now includes flights by certain fixed-wing aircraft. Also, the exemption relating to affiliated corporations applies on a flight-by-flight basis.

VII. DIESEL-POWERED HIGHWAY VEHICLE CREDIT

Effective for vehicles bought after August 20, 1996, the diesel-powered highway vehicle credit is repealed. For vehicles purchased between January 1, 1996, and August 20, 1996, the credit is claimed on Form 4136, Part I.

21 1996–37 I.R.B.

8644 [1996–7 I.R.B. 16]) which were published in the Federal Register for Wednesday, December 27, 1995 (60 FR 66898), as corrected on June 12, 1996 (61 FR 29653). The final regulations relate to generation-skipping transfer tax.

EFFECTIVE DATE: December 27, 1995.

FOR FURTHER INFORMATION CONTACT: Jim Hogan (202) 622–3090 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final regulations that are subject to these corrections are under chapter 13 of the Internal Revenue Code.

Need for Correction

As published, TD 8644 as corrected, contains errors that may prove to be misleading and are in need of clarification.

- - - - Accordingly, 26 CFR part 26 is corrected by making the following correcting amendments:

PART 26—GENERATION-SKIPPING TRANSFER TAX REGULATIONS UNDER THE TAX REFORM ACT OF 1986

Paragraph 1. The authority citation for part 26 continues to read in part as follows:

Authority: 26 U.S.C. 7805 - * *

§ 26.2601–1 [Corrected]

Par. 2. In § 26.2601–1, paragraph (b)(3)(iii)(B) is amended by revising ‘‘(b)(3)(iii)(A), (B), (C)’’ to read ‘‘(b)(3)(iii)(A)( 1 ), ( 2 ), ( 3 )’’.

§ 26.2642–5 [Corrected]

Par. 3. Section 26.2642–5 is amended by removing the punctuation ‘‘;’’ following the word ‘‘ratio’’ in the first sentence of paragraph (b)(1).

§ 26.2654–1 [Corrected]

Par. 4. Section 26.2654–1 is amended by revising paragraph (a)(1)(ii)(B) to read as follows:

§ 26.2654–1 Certain trusts treated as separate trusts.

(a) - * * (1) - * * (ii) - * *

to a listed organization on or before the date of announcement in the Internal Revenue Bulletin that an organization no longer qualifies. However, the Service is not precluded from disallowing a deduction for any contributions made after an organization ceases to qualify under section 170(c)(2) if the organization has not timely filed a suit for declaratory judgment under section 7428 and if the contributor (1) had knowledge of the revocation of the ruling or determination letter, (2) was aware that such revocation was imminent, or (3) was in part responsible for or was aware of the activities or omissions of the organization that brought about this revocation.

If on the other hand a suit for declaratory judgment has been timely filed, contributions from individuals and organizations described in section 170(c)(2) that are otherwise allowable will continue to be deductible. Protection under section 7428(c) would begin on September 9, 1996, and would end on the date the court first determines that the organization is not described in section 170(c)(2) as more particularly set forth in section 7428(c)(1). For individual contributors, the maximum deduction protected is $1,000, with a husband and wife treated as one contributor. This benefit is not extended to any individual who was responsible, in whole or in part, for the acts or omissions of the organization that were the basis for revocation. Gordon Jensen Health Care Association,

Inc. Atlanta, GA National Assistance Bureau, Inc. Atlanta,

Definition of Structure; Hearing

Announcement 96–89

AGENCY: Internal Revenue Service, Treasury.

ACTION: Change of location of public hearing.

SUMMARY: This document changes the location of the public hearing on proposed regulations relating to deductions available upon demolition of a building.

DATE: The public hearing is being held on Wednesday, October 9, 1996, beginning at 10:00 a.m.

ADDRESSES: The public hearing originally scheduled in the Commissioner’s Conference Room, Internal Revenue Building, 1111 Constitution Avenue NW, Washington, DC is changed to Room

2615, Internal Revenue Building, 1111 Constitution Avenue NW, Washington, DC.

FOR FURTHER INFORMATION CONTACT: Christina Vasquez of the Regulations Unit, Assistant Chief Counsel (Corporate), (202) 622–7180 (not a tollfree number).

SUPPLEMENTARY INFORMATION:

A notice of proposed rulemaking and notice of public hearing appearing in the Federal Register on Thursday, June 20, 1996 (61 FR 31473 [PS–39–93, 1996–34 I.R.B. 27]), announced that a public hearing on proposed regulations relating to deductions available upon demolition of a building will be held on Wednesday, October 9, 1996, beginning at 10:00 a.m. in the Commissionser’s Conference Room, 1111 Constitution Avenue NW, Washington, DC and that request to speak and outlines of oral comments should be received by Wednesday, September 18, 1996.

The location of the pubic hearing has changed. The hearing is scheduled for Wednesday, October 9, 1996, beginning at 10:00 a.m. in room 2615, Internal Revenue Building, 1111 Constitution Avenue NW, Washington, DC. The requests to speak and outlines of oral comments must have been received by Wednesday, September 18, 1996. Because of controlled access restrictions, attenders are not admitted beyond the lobby of the Internal Revenue Building until 9:45 a.m.

The Service will prepare an agenda showing the scheduling of the speakers after the outlines are received from the persons testifying and make copies available free of charge at the hearing.

Michael L. Slaughter, Acting Chief, Regulations Unit, Assistant Chief Counsel (Corporate).

(Filed by the Office of the Federal Register on August 23, 1996, 8:45 a.m., and published in the issue of the Federal Register for August 26, 1996, 61 F.R. 43695)

Generation-Skipping Transfer Tax; Correction

Announcement 96–90

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendment.

SUMMARY: This document contains corrections to final regulations (T.D.

1996–37 I.R.B. 22

(B) If the pecuniary amount is payable in kind on the basis of value other than the date of distribution value of the assets, the trustee is required to allocate assets to the pecuniary payment in a manner that fairly reflects net appreciation or depreciation in the value of the assets in the fund available to pay the pecuniary amount measured from the valuation date to the date of payment.

- - - -

Michael L. Slaughter, Acting Chief, Regulations Unit, Assistant Chief Counsel (Corporate).

(Filed by the Office of the Federal Register on August 23, 1996, 8:45 a.m., and published in the issue of the Federal Register for August 26, 1996, 61 F.R. 43656)

Foundations Status of Certain Organizations

Announcement 96–91

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: Ada Village, Benton Harbor, MI Allen County Foster Parent Association,

Chatham Volunteer Firemen’s

Ephrata, PA Hanna Ministries, Inc., Columbus, OH Hardyston Creative Playground, Inc.,

Association, Spencer, OH Childrens Covenant Foundation, Inc.,

Historic Morristown, Inc., Morristown,

NJ Historic Riverton Nomination

Committee, Inc., Riverton, NJ Hoboken Creative Alliance, Inc.,

Hoboken, NJ Hot Line React Team 4086, Inc.,

San Antonio, TX Cincinnati Womens Health Project,

Cincinnati, OH Circle City Family Child Care

Association, Inc., Indianapolis, IN City of Lagrange Foundation, Inc.,

Lagrange, KY Classic One Fifty, Chattanooga, TN Community Care Center, Inc., Dayton,

Hagerstown, MD Housing and Business Development

Corporation of Philadelphia, Philadelphia, PA Housing and Neighborhood Resources,

OH Cumberland Homestead Tower

Association, Inc., Crossville, TN Development Services International,

Inc., Warrenton, VA Dialogue on Diversity, Inc., Washington,

Washington, DC Human Strategies, Inc., Millersburg, OH Hyattsville Mt. Rainier Brentwood Boys

and Girls Club Incorporated, Mt. Rainier, MD IAC-Enterprises Nehemiah Development

Inc., Columbia, MD I.H.C. Professional Services, Inc., Salt

Lake City, UT Indiana Soviet Trade Consortium Inc.,

Indianapolis, IN Inspirational Media, Inc., Mentor, OH Institute for Cooperation on Sec

DC Don’t Waste the United States, Inc.,

Takoma Park, MD Downtown Petersburg, Inc., Petersburg,

VA Drinker Society for Critical Care in

Phila., Philadelphia, PA Drug Awareness Foundation, Pontiac,

MI DVV Leukemia Fund, Wayne, NJ Eagle Clan Shawnee Tribe of Ohio, Inc.,

Economics and the Environment, Washington, DC Institute for Latin American Unity,

Washington, DC Institute for Social and Educational

Rayland, OH Ekklesia Incorporated, Leonard, MI Enviro-Rite, Inc., Corydon, IN Family Outreach Central, Inc., Houston,

Development of Man, Silver Spring, MD Inter-American Management Education

Research, Inc., Tuscaloosa, AL Institute for the Harmonious

TX Forest Park School Foundation, Crystal

Foundation, Washington, DC Interface Group Homes, Inc., Willow

Falls, MI Foundation for Emergency Medical

Grove, PA International Biotest Foundation, Troy,

Research, Phoenix, AZ Freedom Link, Ann Arbor, MI Free Spirit Enterprise Association,

MI International Community School of

Chicago, IL Greater Latrobe Caring Program,

Abidjan Inc., Princeton, NJ Izetta Cutrell Mae Zimmerman

Latrobe, PA Guiding Star Ministries, Inc.,

Philadelphia, PA Haad Support Groups, Roanoke, VA Hand of the Master Ministries, Inc.,

Council, Inc., Vincennes, IN Marine Corps Coordinating Council

Foundation, Herrin, IL Jane Silva House Inc., Fort Wayne, IN Jesus Unlimited J.U.L., Tulsa, OK Knox County Child Abuse Prevention

Louisville, Inc., Louisville, KY Marshall Recycling Partnership, Inc.,

Lima, OH Benny Brink Evangelistic Association,

Inc., Littleton, CO Blue Ribbon Committee on Education,

Attalla, AL B.M.P.C. & Associates, Rosenberg, TX Bridgforth Foundation, Grosse Pointe

Franklin, NJ Harford Leadership Association, Inc.,

Bel Air, MD Harvest Fellowship, Upper Marlboro,

MD Harvest International, Inc., Big Stone

Association MBAA, Bloomington, IN Mercy Assoc., Little Rock, AR Miami County Child Abuse Prevention

Council Inc., Peru, IN Minority Business Owners of

Marshall, TX Masters of Business Administration

Shores, MI Browns Mount Association, Inc.,

Macon, GA Carrolton Farmers Branch Insurance

Gap, VA Health Start, Inc., Wilkinsburg, PA Hearts for Croatia-SRCE ZA

Washtenaw County, Ypsilanti, MI National Association of Minority

Contractors, Atlanta, GA National Commission on Rape

Prevention, Mesa, AZ

Agents Assoc., Carrolton, TX Center for Economic Development, Inc.,

Hrvatsku-Inc., Cherry Hill, NJ Heros Touch, Washington, DC High Bridge Athletic Association, Inc.,

High Bridge, NJ

Cary, NC

23 1996–37 I.R.B.

North American Plant Preservation

Council, Inc., Renick, WV Northeastern Indiana Allen County

Medical Response Team, Inc., Ft. Wayne, IN Parents Helping Parents of Wyoming,

Skillful Child Care Inc., Lansing, MI Stress Research Foundation, Dallas, TX Summer Enrichment Program for

Inc., Buffalo, WY Preston Plantation, Inc., Bedford, KY PRIDE Community Center, Flint, MI P R I D E Corporation, Ft. Wayne, IN Ray and Rosetta Doerhoff Scholarship

Trust, St. Elizabeth, MO Shelby County Child Abuse Prevention

Council, Inc., Shelbyville, IN Sherman County Crime Stoppers, Inc.,

Handicapped Children of Trumbull County, Warren, OH Teamnester Retiree Housing of

Detroit, MI

Birmingham Inc., Birmingham, AL Tell It To Jesus Ministries Inc., Monroe,

NC Tennessee Association Education

Foundation, Nashville, TN Texas Literacy Foundation, San Antonio,

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.

Stratford, TX

TX Williams Community Living Inc.,

1996–37 I.R.B. 24

Numerical Finding List ¹

Bulletins 1996–27 through 1996–36

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 96–77, 1996–35 I.R.B. 15 96–78, 1996–35 I.R.B. 15 96–79, 1996–35 I.R.B. 15 96–80, 1996–35 I.R.B. 16 96–81, 1996–36 I.R.B. 13 96–82, 1996–36 I.R.B. 14 96–83, 1996–36 I.R.B. 14 96–84, 1996–36 I.R.B. 14

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 96–41, 1996–35 I.R.B. 6 96–42, 1996–35 I.R.B. 6 96–43, 1996–36 I.R.B. 7 96–44, 1996–36 I.R.B. 7

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 INTL–4–95, 1996–36 I.R.B. 8 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

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.

Revenue Procedures—Continued 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 96–43, 1996–35 I.R.B. 6 96–44, 1996–35 I.R.B. 7 96–45, 1996–35 I.R.B. 12

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 96–42, 1996–35 I.R.B. 4 96–43, 1996–36 I.R.B. 4

Tax Conventions: 1996–28 I.R.B. 36 1996–36 I.R.B. 6

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 1996–36

*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.