PART III. PROCESSING DETERMINATION LETTER REQUESTS

accountant, enrolled agent, or enrolled actuary, and date or period of suspension. This announcement will appear in the weekly Bulletin at the earliest practicable date after such action and will continue to appear in the weekly Bulletins for five successive weeks or for as many weeks as is practicable for each attorney, certified public accountant, enrolled agent, or enrolled actuary so suspended and will be consolidated and published in the Cumulative Bulletin.

The following individuals have been placed under consent suspension from practice before the Internal Revenue Service:

Under 31 Code of Federal Regulations, Part 10, an attorney, certified public accountant, enrolled agent, or enrolled actuary, in order to avoid the institution or conclusion of a proceeding for his disbarment or suspension from practice before the Internal Revenue Service, may offer his consent to suspension from such practice. The Director of Practice, in his discretion, may suspend an attorney, certified public accountant, enrolled agent, or enrolled actuary in accordance with the consent offered. Attorneys, certified public accountants, enrolled agents, and enrolled actuaries are prohibited in any Internal Rev

enue Service matter from directly or indirectly employing, accepting assistance from, being employed by or sharing fees with, any practitioner disbarred or suspended from practice before the Internal Revenue Service.

To enable attorneys, certified public accountants, enrolled agents, and enrolled actuaries to identify practitioners under consent suspension from practice before the Internal Revenue Service, the Director of Practice will announce in the Internal Revenue Bulletin the names and addresses of practitioners who have been suspended from such practice, their designation as attorney, certified public

Name Address Designation Date of Suspension

Sherman, Richard M. Crystal Lake, IL CPA October 18, 1996 to July 17, 1997 Hunter, Lewis Jacksonville, FL CPA October 25, 1996 to January 24, 1997 Hisken, Donald Red Bluff, CA CPA November 1, 1996 to March 31, 1997 Byrne, Steven P. Arcadia, CA Attorney November 1, 1996 to January 31, 1997 Mulrey, Robert M. Milton, MA CPA November 1, 1996 to October 31, 1997 Edwards, Ronald A. Plymouth, MI CPA November 1, 1996 to April 30, 1998 Hart Jr., Charles E. Wilmington, OH Attorney November 1, 1996 to October 31, 1998 Willner, Peter D. Stowe, VT CPA November 1, 1996 to April 30, 1997 May, Gary Madison, WI Attorney November 1, 1996 to October 31, 1998 Josephson, Elliott Northbrook, IL CPA November 1, 1996 to October 31, 1998 Capwill Jr., James A. Solon, OH CPA November 1, 1996 to February 28, 1997 Hazel, John J. Ridgefield, CT Enrolled Agent November 1, 1996 to January 31, 1997 Jacobs, Patrick St. Paul, MN CPA November 1, 1996 to December 31, 1996 Lau, William Crete, IL CPA November 1, 1996 to June 30, 1997 Franklin, Gene L. Lees Summit, MO Enrolled Agent November 1, 1996 to January 31, 1997 Winterhalter, Charles L. Cincinnati, OH CPA November 1, 1996 to April 30, 1998 Cremer, Patricia L. Roundup, MT CPA November 5, 1996 to May 4, 1997 Gardner, Stephen A. Dallas, TX Attorney November 7, 1996 to May 6, 1999 Masini, David Wheat Ridge, CO CPA November 12, 1996 to November 11, 1997 Cunningham, Michael Lafayette, IN CPA November 12, 1996 to August 11, 1997 Smith, Robert Chicago, IL CPA January 1, 1997 to December 31, 1997

205

accountant, enrolled agent, or enrolled actuary, and date or period of suspension. This announcement will appear in the weekly Bulletin at the earliest practicable date after such action and will continue to appear in the weekly Bulletins for five successive weeks or for as many weeks as is practicable for each attorney, certified public accountant, enrolled agent, or enrolled actuary so suspended and will be consolidated and published in the Cumulative Bulletin.

The following individuals have been placed under suspension from practice before the Internal Revenue Service by virtue of the expedited proceeding provisions of the applicable regulations:

Under title 31 of the Code of Federal Regulations, section 10.76, the Director of Practice is authorized to immediately suspend from practice before the Internal Revenue Service any practitioner who, within five years, from the date the expedited proceeding is instituted, (1) has had a license to practice as an attorney, certified public accountant, or actuary suspended or revoked for cause; or (2) has been convicted of any crime under title 26 of the United States Code or, of a felony under title 18 of the United States Code involving dishonesty or breach of trust.

Attorneys, certified public accountants, enrolled agents, and enrolled actu

aries are prohibited in any Internal Revenue Service matter from directly or indirectly employing, accepting assistance from, being employed by, or sharing fees with, any practitioner disbarred or suspended from practice before the Internal Revenue Service.

To enable attorneys, certified public accountants, enrolled agents, and enrolled actuaries to identify practitioners under expedited suspension from practice before the Internal Revenue Service, the Director of Practice will announce in the Internal Revenue Bulletin the names and addresses of practitioners who have been suspended from such practice, their designation as attorney, certified public

Name Address Designation Date of Suspension

Pacchiana, Paul Chappaqua, NY Attorney Indefinite from October 9, 1996 Rosenberger, David H. Centerville, OH Enrolled Agent Indefinite from October 21, 1996 Gudes, Gerald W. Bloomfield, MI CPA Indefinite from October 22, 1996 Donnelly, Richard S. Asheville, NC CPA Indefinite from October 22, 1996 Burrows, William D. Dallas, TX Attorney Indefinite from November 13, 1996 Klausner, Julius Scarsdale, NY CPA Indefinite from November 13, 1996 Glessner, Randy Omak, WA CPA Indefinite from November 13, 1996 Aspland, Frieda R. Greenville, SC CPA Indefinite from November 13, 1996

206

Revenue rulings and revenue procedures (hereinafter referred to as ‘‘rulings’’) that have an effect on previous rulings use the following defined terms to de- scribe the effect:

Amplified describes a situation where no change is being made in a prior 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 ruling

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.

is modified because it corrects a published position. (Compare with amplified 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 the new ruling does

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.

207

more than restate the substance of a prior ruling, a combination of terms is used. For example, modified and super- seded 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.

Proposed Regulations—Continued

REG–209827–96, 1996–37 I.R.B. 19 REG–245562–96, 1996–41 I.R.B. 8 REG–251520–96, 1996–48 I.R.B. 15

Public Laws:

104–117, 1996–34 I.R.B. 19 104–134, 1996–38 I.R.B. 7 104–168, 1996–38 I.R.B. 8 104–191, 1996–43 I.R.B. 7 104–193, 1996–46 I.R.B. 4

Railroad Retirement Quarterly Rate

1996–29 I.R.B. 14 1996–53 I.R.B. 9

Revenue Procedures:

96–36, 1996–27 I.R.B. 11 96–37, 1996–29 I.R.B. 16 96–38, 1996–53 I.R.B. 13 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 96–46, 1996–38 I.R.B. 144 96–47, 1996–39 I.R.B. 10 96–48, 1996–39 I.R.B. 10 96–49, 1996–43 I.R.B. 74 96–50, 1996–47 I.R.B. 10 96–51, 1996–47 I.R.B. 10 96–52, 1996–48 I.R.B. 10 96–53, 1996–49 I.R.B. 9 96–54, 1996–50 I.R.B. 9 96–55, 1996–50 I.R.B. 10 96–56, 1996–51 I.R.B. 11 96–57, 1996–53 I.R.B. 14 96–58, 1996–53 I.R.B. 16 96–59, 1996–53 I.R.B. 17 96–60, 1996–53 I.R.B. 24 96–61, 1996–53 I.R.B. 27 96–62, 1996–53 I.R.B. 38 96–63, 1996–53 I.R.B. 46 96–64, 1996–53 I.R.B. 52

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 96–41, 1996–45 I.R.B. 4 96–42, 1996–35 I.R.B. 4 96–43, 1996–36 I.R.B. 4 96–44, 1996–38 I.R.B. 4 96–45, 1996–39 I.R.B. 5 96–46, 1996–39 I.R.B. 5 96–47, 1996–40 I.R.B. 7 96–48, 1996–40 I.R.B. 4 96–49, 1996–41 I.R.B. 4 96–50, 1996–42 I.R.B. 4 96–51, 1996–43 I.R.B. 5 96–52, 1996–45 I.R.B. 5 96–53, 1996–47 I.R.B. 4 96–54. 1996–47 I.R.B. 5 96–55, 1996–49 I.R.B. 4 96–56, 1996–50 I.R.B. 7 96–57, 1996–50 I.R.B. 5

Numerical Finding List ¹

Bulletins 1996–27 through 1996–53

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 96–85, 1996–37 I.R.B. 20 96–86, 1996–37 I.R.B. 21 96–87, 1996–37 I.R.B. 21 96–88, 1996–38 I.R.B. 150 96–89, 1996–37 I.R.B. 22 96–90, 1996–37 I.R.B. 22 96–91, 1996–37 I.R.B. 23 96–92, 1996–38 I.R.B. 151 96–93, 1996–38 I.R.B. 151 96–94, 1996–38 I.R.B. 153 96–96, 1996–39 I.R.B. 41 96–97, 1996–39 I.R.B. 41 96–98, 1996–39 I.R.B. 42 96–99, 1996–39 I.R.B. 42 96–100, 1996–40 I.R.B. 10 96–101, 1996–40 I.R.B. 10 96–102, 1996–40 I.R.B. 11 96–103, 1996–40 I.R.B. 12 96–104, 1996–41 I.R.B. 10 96–105, 1996–42 I.R.B. 19 96–106, 1996–42 I.R.B. 23 96–107, 1996–42 I.R.B. 27 96–108, 1996–44 I.R.B. 15 96–109, 1996–43 I.R.B. 76 96–110, 1996–43 I.R.B. 77 96–111, 1996–44 I.R.B. 16 96–112, 1996–45 I.R.B. 7 96–113, 1996–44 I.R.B. 18 96–114, 1996–45 I.R.B. 7 96–115, 1996–45 I.R.B. 9 96–116, 1996–46 I.R.B. 12 96–117, 1996–46 I.R.B. 12 96–118, 1996–46 I.R.B. 12 96–119, 1996–46 I.R.B. 13 96–120, 1996–47 I.R.B. 12 96–121, 1996–47 I.R.B. 12 96–122, 1996–47 I.R.B. 13 96–123, 1996–51 I.R.B. 13 96–124, 1996–49 I.R.B. 22 96–125, 1996–48 I.R.B. 21 96–126, 1996–50 I.R.B. 12 96–127, 1996–50 I.R.B. 12 96–128, 1996–51 I.R.B. 14

See footnote at end of list.

Announcements—Continued:

96–129, 1996–51 I.R.B. 14 96–130, 1996–52 I.R.B. 32 96–131, 1996–52 I.R.B. 32 96–132, 1996–52 I.R.B. 33 96–133, 1996–53 I.R.B. 60 96–134, 1996–53 I.R.B. 60 96–135, 1996–53 I.R.B. 60

Court Decisions:

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

Delegation Orders:

155 (Rev. 4), 1996–40 I.R.B. 9

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 96–45, 1996–39 I.R.B. 7 96–46, 1996–39 I.R.B. 7 96–47, 1996–39 I.R.B. 8 96–48, 1996–39 I.R.B. 8 96–49, 1996–41 I.R.B. 6 96–50, 1996–41 I.R.B. 6 96–51, 1996–42 I.R.B. 6 96–52, 1996–42 I.R.B. 8 96–53, 1996–51 I.R.B. 5 96–54, 1996–44 I.R.B. 13 96–55, 1996–47 I.R.B. 7 96–56, 1996–47 I.R.B. 7 96–57, 1996–47 I.R.B. 9 96–58, 1996–49 I.R.B. 7 96–59, 1996–48 I.R.B. 10 96–60, 1996–49 I.R.B. 7 96–61, 1996–49 I.R.B. 8 96–62, 1996–49 I.R.B. 8 96–63, 1996–51 I.R.B. 8 96–64, 1996–51 I.R.B. 8 96–65, 1996–52 I.R.B. 28 96–66, 1996–53 I.R.B. 12 96–67, 1996–53 I.R.B. 12 96–68, 1996–52 I.R.B. 30

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–59–94, 1996–30 I.R.B. 23 FI–32–95, 1996–34 I.R.B. 21 FI–48–95, 1996–31 I.R.B. 36 FI–28–96, 1996–31, I.R.B. 33 GL–7–96, 1996–33 I.R.B. 13 IA–292–84, 1996–28 I.R.B. 38 IA–26–94, 1996–30 I.R.B. 24 IA–42–95, 1996–49 I.R.B. 21 IA–29–96, 1996–33 I.R.B. 14 INTL–4–95, 1996–36 I.R.B. 8 PS–39–93, 1996–34 I.R.B. 27 PS–22–96, 1996–33 I.R.B. 15 REG–208215–91, 1996–38 I.R.B. 145 REG–209803–95, 1996–44 I.R.B. 14 REG–209826–96, 1996–42 I.R.B. 10

208

Numerical Finding List—Continued

Bulletins 1996–27 through 1996–53

Revenue Rulings—Continued

96–58, 1996–50 I.R.B. 4 96–59, 1996–50 I.R.B. 4 96–60, 1996–51 I.R.B. 4 96–61, 1996–52 I.R.B. 24 96–62, 1996–53 I.R.B. 6 96–63, 1996–53 I.R.B. 8 96–64, 1996–53 I.R.B. 11 96–65, 1996–53 I.R.B. 5

Social Security Contributions & Benefit

1996–53 I.R.B. 59

Tax Conventions:

1996–28 I.R.B. 36 1996–36 I.R.B. 6 1996–40 I.R.B. 8 1996–50 I.R.B. 8

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 8681, 1996–37 I.R.B. 17 8682, 1996–37 I.R.B. 4 8683, 1996–44 I.R.B. 9 8684, 1996–44 I.R.B. 4 8685, 1996–48 I.R.B. 4 8686, 1996–52 I.R.B. 14 8687, 1996–52 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.

209

Finding List of Current Action on Previously Published Items ¹

Bulletins 1996–27 through 1996–53

*Denotes entry since last publication

Notices:

95–45 Superseded by Rev. Rul. 96–65, 1996–53 I.R.B. 5

Revenue Procedures:

67–396 Modified by 96–56, 1996–50 I.R.B. 7

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

84–77 Modified and superseded by 96–60, 1996–53 I.R.B. 24

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

91–22 Superseded by 96–53, 1996–49 I.R.B. 9

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

95–16 Superseded by 96–48, 1996–39 I.R.B. 10

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

95–46 Superseded by 96–48, 1996–39 I.R.B. 10

95–54 Superseded by 96–63, 1996–53 I.R.B. 46

96–3 Amplified by 96–56, 1996–51 I.R.B. 11 Modified by Rev. Rul. 96–65, 1996–53 I.R.B. 5

96–25 Modified by 96–58, 1996–50 I.R.B. 4

96–28 Superseded by 96–64, 1996–53 I.R.B. 52

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.

Revenue Procedures—Continued

96–41 Modified by Notice 96–49, 1996–41 I.R.B. 6

96–46 Supplemented by 96–51, 1996–47 I.R.B. 10

Revenue Rulings:

72–341 Obsoleted by 96–65, 1996–53 I.R.B. 5

93–88 Obsoleted by 96–65, 1996–53 I.R.B. 5

94–92 Obsoleted by 96–65, 1996–53 I.R.B. 5

96–4 Supplemented and superseded by 96–63, 1996–53 I.R.B. 8

96–5 Supplemented and superseded by 96–64, 1996–53 I.R.B. 8

210

Internal Revenue Bulletins 1996–27 Through 1996–53

For index of items published during the first six months of 1996, see I.R.B. 1996–27, dated July 1, 1996.

The abbreviation and number in parenthesis following the index entry refer to the specific item; numbers in roman and italic type following the parenthesis 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

Automatic extensions for Forms W–2

(RP 57) 53, 14 Levy:

Gift of checks (RR 56) 50, 7 Proposed regulations:

26 CFR 25.2511–1, 25.2514–3, 25.2518–1, –2, amended; disclaimer of interests and powers (REG– 208215–91) 38, 145

Accounting methods (Notice 40) 33, 11 Advance pricing agreement (RP 53) 49,

9 Bankruptcy; validity of liens (Ct.D 2059) 34, 10 Base period T-bill rate for 1996 (RR 55)

49, 4 Bonds:

Qualified mortgage bonds:

Mortgage credit certificates:

National median gross income

(RP 37) 29, 16 Claiming a refund, U.S. v. IBM (Notice

37. 31, 29 Cost-of-living adjustments, 1997 (RP

38. 53, 17 Covered compensation tables; 1997 (RR

39. 47, 4 CPI adjustment for below-market loans

for 1997 (RR 64) 53, 11 Credits against tax:

Table, exempt from levy on wages,

Gift of checks (RR 56) 50, 7 Proposed regulations:

26 CFR 20.2041–3, 20.2056(d)–2, 25.2511–1, 25.2514–3, 25.2518–1, –2, amended; 20.2041–3, added; disclaimer of interests and powers (REG–208215–91) 38, 145 Proposed regulations—Continued and intermediary sections, added; extensions of time to make elections (IA–29–96) 33, 14

Proposed regulations:

26 CFR 20.2041–3(d)(6)(i), amended; 20.2041–3(d)(6)(iii), added; 20.2056(d)–2, amended; disclaimer of interests and powers (REG– 208215–91) 38, 145 Qualified domestic trust (RP 54) 50, 9 Regulations:

26 CFR 301.9100–1T—301.9100–3T and intermediary sections, added; extensions of time to make elections (TD 8680) 33, 5 26 CFR 20.2056A–0, revised; 20.2056A–2(d), added; 20.2056A– 2T, removed; qualified domestic trusts; requirements to ensure estate tax collection (TD 8686) 52, 14

Exempt organizations:

Excess benefit transactions engaged in

(Notice 46) 39, 7 Foreign insurance taxes (Ct.D 2060) 34, 5 Proposed regulations:

26 CFR 2652–1, amended; generation-skipping transfer tax (PS–22– 96) 33, 15 Regulations:

26 CFR 40.6011(a)–1, –2(b)(2), 40.6302(c)–1, –2, –3, –4, 40.9999– 1, 48.4082–2(a), 48.4083–1, 48.6715(a); amended; Subpart F of 49.4291–1, added; 40.6302(c)–5T, 48.6427–7, 301.6156–1, 301.6206–1, 301.6415–1—6421–1 and intermediary sections, 301.6423–1, 301.6675– 1, removed; 48.6714–1, redesignated, excise tax deposits (TD 8685) 48, 4

211

Low-income housing (RP 46) 38, 144 ; (RP 51) 47, 10 Satisfactory bond, ‘‘bond factor’’ amounts for the period July through September 1996 (RR 45) 39, 5 ; October—December 1996 (RR 59) 50, 4 Damages for personal injuries or sick ness (65) 53, 5 Educational assistance after termination

of employment (RR 41) 45, 4 Educational assistance program, section

127 (Notice 68) 52, 30 Electronic filing program for Form 1040

series, 1997 (RP 61) 53, 27 Employees attaining age 70 1/2 in 1996

salary, and other income (Notice 56) 47, 7 Modification of RP 84–77 (RP 60) 53,

24 Proposed regulations:

26 CFR 301.9100–1T—301.9100–3T and intermediary sections, added; extensions of time to make elections (IA–29–96) 33, 14 Railroad retirement:

Rate determination, quarterly (July 1,

1996. 29, 14 ; (October 1, 1996 and January 1, 1997) 53, 9 Regulations:

26 CFR 301.9100–1T—301.9100–3T and intermediary sections, added; extensions of time to make elections (TD 8680) 33, 5 Social security contribution and benefit

base (1997) 53, 59

(Notice 67) 53, 12 Employee plans:

Funding:

Full funding limitations, weighted

average interest rate, June 1996 (Notice 36) 27, 11 ; July 1996 (Notice 38) 31, 29 ; August 1996, (Notice 43) 36, 7 ; September 1996 (Notice 45) 39, 7 ; October 1996 (Notice 54) 44, 13 ; November 1996 (Notice 59) 48, 10 ; December 1996 (Notice 66) 53, 12

Employee plans—Continued

Limit on contributions and benefits;

cost-of-living adjustments (Notice 55) 47, 7 Nondiscrimination and coverage, rollover (RR 48) 40, 4 Participant consent, significant detri ment (RR 47) 40, 7 Qualification (RP 55) 50, 10 Requests for comments on proposed

Interest:

Investment:

long-term rates, July 1996 (RR 34) 28, 4 ; August 1996 (RR 37) 32, 4 ; September 1996 (RR 43) 36, 4 ; October 1996 (RR 49) 41, 4 ; November 1996 (RR 52) 45, 5 ; December 1996 (RR 57) 50, 5 Rates, underpayments and overpay

Federal short-term, mid-term, and

guidance for section 457 plans (Notice 63) 51, 8 Section 414(u); retirement plans; model amendments (RP 49) 43, 74 Tax-sheltered annuities; correction program; extension (RP 50) 47, 10 Exempt organizations:

ments beginning October 1, 1996 (RR 44) 38, 4 ; (RP 61) 52, 24 Inventories:

LIFO:

Price indexes, department stores,

Proposed regulations—Continued

26 CFR 1.148–5(d)(6)(iv)—(viii) and intermediary sections; 1.148– 5(e)(2)(iv), added; arbitrage restrictions on tax-exempt bonds (FI–28– 96) 31, 33 26 CFR 1.166–3(a)(3), added; bad debts modifications and dealer assignments of notional principal contracts (FI–59–94) 30, 23 26 CFR 1.280B–1, added; structure, definition (PS–39–93) 34, 27 26 CFR 1.367(e)–1, 1.6038B– 1(b)(2)(i); section 355 distributions of stock and securities by domestic corporations to foreign persons (REG–209827–96) 37, 19 26 CFR 1.382–5, –8, added; 1.382– 2(a)(1)(iv), revised; consolidated returns, short taxable years for controlled groups (CO–26–96) 31, 31 26 CFR 1.401(a)(31)–1; 1.402(c)–2, amended; relief from disqualification of plans accepting rollovers (REG–245562–96) 41, 8 26 CFR 1.475(b)–1, –2, –4, 1.475(c)–1, –2, 1.475(e)–1, revised; mark-to-market equity interests in related parties and dealer-customer relationship (FI–32–95) 34, 21 26 CFR 1.671–1(g), (h), 1.671–2(f), 1.1297–4, added; application of the grantor trust rules to nonexempt employees’ trusts (REG–209826– 96) 42, 10 26 CFR 1.861–8(e)(7)(iii), 1.865–1, –2, 1.904–4(c)(2)(ii)(A) and (B), added; 1.904–0, amended; stock disposition loss allocation (INTL– 4–95) 36, 8 26 CFR 1.861–18, added; classification of certain transactions involving computer programs (REG 251520–96) 48, 15 26 CFR 1.1059(e)–1, added; extraordinary dividends; distributions to corporate shareholders (CO–9–96) 34, 20 26 CFR 1.1202–0, –2, added; qualified small business stock (IA–26– 94) 30, 24 26 CFR 1.1502–15, –21, –22, –23, added; consolidated returns, limitations on the use of certain losses and deductions (CO–24–96) 30, 22 26 CFR 1.1502–90T—1.1502–99T and intermediary sections, added; consolidated group, net operating loss carryforwards and built-in losses and credits following ownership change, limitation (CO–25–96) 31, 30

Group letter exemption (RP 40) 32, 8 Private inurement expressly prohibited

(Notice 47) 39, 8 Information returns, copies to the public and increases to certain penalties (Notice 48) 39, 8 Forms:

Paper substitutes, Forms 1096, 1098,

1099 series, 5498, and W–2G (RP 42) 32, 14 Substitute printed, computer-prepared,

and computer-generated tax forms and schedules (RP 48) 39, 8 Fringe benefits aircraft valuation for mula (RR 58) 50, 4 Governmental plans (Notice 64) 51, 8 Guidance for acceptance agent program

(RP 52) 48, 10 Health Insurance Portability and Ac countability Act of 1996 (P.L. 104– 191) 43, 7 Income:

Controlled foreign corporation, part nership, subpart F income (Notice 39) 32, 8 Indian tribal casinos, information report ing (Notice 57) 47, 9 Inflation-adjusted numbers for 1997 (RR

63. 53, 8 Inflation adjustment factor for 1996 (Notice 41) 35, 6 Inflation-indexed debt instruments (No

Controlled foreign corporation, part

May 1996 (RR 36) 30, 6 ; June 1996 (RR 39) 34, 4 ; July 1996 (RR 46) 39, 5 ; August 1996 (RR 50) 42, 4 ; September 1996 (RR 54) 47, 5 ; October 1996 (RR 60) 51, 4 Low income housing credit:

Bond factor amounts, April–June 1996 (RR 33) 27, 4 FEMA (RR 35) 31, 4 Marginal production rates for 1996 (No tice 42) 35, 6 Medical savings accounts (Notice 53)

51, 5 Offers in compromise; substitute Forms

656 (RP 38) 53, 13 Omnibus Consolidated Recissions and

Appropriations Act of 1996 (PL 104– 134) 38, 7 On-line filing program for Form 1040

series, 1997 (RP 62) 53, 38 Optional standard mileage rates, 1997

(RP 63) 53, 46 Penalty provisions, filing requirements

(Notice 60) 49, 7 Per diem allowances (RP 64) 53, 52 Personal Responsibility and Work Op portunity Reconciliation Act of 1996 (PL 104–193) 46, 4 Pooled income fund; community trust;

maintenance requirement (RR 38) 33, 4 Proposed regulations:

tice 51) 42, 6 Information reporting:

Discharge of

49, 8 Insurance companies:

Discharge of indebtedness (Notice 61)

Differential earnings rate (RR 42) 35,

4 Loss reserves, discounting unpaid losses (RP 44) 35, 7 Discounting estimated salvage recov

26 CFR 1.61–8(b), revised; 1.451– 1(g), added; 1.467–1, amended; 1.467–4, amended; 1.467–0 through –8, added; rental agreements (IA– 292–84) 28, 38 26 CFR 1.61–12(c), 1.163–7(c), 1.171–1—1.171–4, 1.1016–5(b), revised; 1.163–13, 1.171–5, added; 1.1016–9, removed; amortizable bond premium (FI–48–95) 31, 36

erable (RP 45) 35, 12

212

Proposed regulations—Continued revised; magnetic media filing requirements for information returns (REG–209803–95) 44, 14

26 CFR 1.6662–0, –3, amended; 1.6662–4(d)(2), –7(d), revised; 1.6664–0, amended; definition of reasonable basis (IA–42–95) 49, 21

26 CFR 301.9100–1T—301.9100–3T and intermediary sections, added; extensions of time to make elections (IA–29–96) 33, 14

Qualified State Tuition Program (Notice

58. 49, 7

Recommendation letters for nonsuit settlements (Del. Order 155, Rev. 4) 40, 9

Refund claims; Tax Court; return not

filed (Ct.D. 2058) 34, 13

Regulated investment companies, prefer ential dividends (RP 47) 39, 10

Regulations:

26 CFR 1.110–3, added; debt instruments modifications (TD 8675) 29, 5

26 CFR 1.163–7(a), added; 1.446–4, amended; 1.483–2T, removed; 1.483–4, added; 1.1001–1, revised; 1.1012–1(g), revised; 1.1271–0(b), amended; 1.1272–1(c)(7), added; 1.1274–2(g), revised; 1.1274–2(i) and (j), added; 1.1275–2(g), (h), (i), (j), added; 1.1275–2T, removed; 1.1275–4, added; 1.1275–5(a)(5), (6), added; 1.1275–5(c)(1), (5), revised; 1.1275–6, added; debt instruments with original issue discount, contingent payments, anti-abuse rule (TD 8674) 28, 7 26 CFR 1.166–3T, 1.1001–4T, added; bad debts modifications and dealer assignments of notional principal contracts (TD 8676) 30, 4

Proposed regulations—Continued

26 CFR 1.367(e)–0; 1.367(e)–1, removed; 1.367(e)–0T, –1T, added; section 355 distributions of stock and securities by domestic corporations to foreign persons (TD 8682) 37, 4

26 CFR 1.382–5T, –8T, –2T(f)(1)(i)— (iii) and intermediary sections, added; 1.382–2, –2T, removed; consolidated groups, short taxable years for controlled groups (TD 8679) 31, 4

26 CFR 1.863–0, –1(e), –3, added; 1.863–1(a), (b), (c), –2, –4, revised; 1.863–5, removed; source of income from sales of inventory and natural resources produced in one jurisdiction and sold in another jurisdiction (TD 8687) 52, 4

26 CFR 1.1254–2(d)(1)(ii), –3(b)(1)(i) and (ii), –3(d)(1)(i) and (ii), revised; 1.1254–4, –6, amended; treatment of gain from disposition of interest in certain natural resource recapture property by S corps and their shareholders (TD 8684) 44, 4

26 CFR 1.1394–0, –1, added; enterprize zone facility bonds (TD 8673) 27, 4

26 CFR 1.1502–0, –1, –2, –11, –21A, –22A, –23A, –41A, revised; 1.1502– 15, –21, redesignated, 1.1502–21T, –23T, –79A, added; 1.1502–79, amended; consolidated returns, limitations on the use of certain losses and deductions (TD 8677) 30, 7

26 CFR 1.1502–90T through –99T and intermediary sections, added; consolidated groups, net operating loss carryforwards and built-in losses and credits following ownership change, limitations (TD 8678) 31, 11

213

Proposed regulations—Continued

42, 8

26 CFR 1.6045–1(q), –2, amended; 1.6045–1T, –2T, 301.6011–2T, added; magnetic media filing requirements for information returns (TD 8683) 44, 9 26 CFR 301.6355–1, amended; sale of seized property (GL–7–96) 33, 13 26 CFR 301.7503–1, amended; time for performance of acts where last day falls on Saturday, Sunday, or legal holiday (TD 8681) 37, 17 26 CFR 301.9100–1T—301.9100–3T and intermediary sections, added; extensions of time to make elections (TD 8680) 33, 5 Returns:

Magnetic media reporting, Forms 1098, 1099, 5498, and W–2G (RP 36) 27, 11 Section 355 de minimis limitation (RP

43. 35, 6 Section 355 No Rule (RP 39) 33, 11 Section 457 ‘‘no rule’’ rev. proc. (RP

44. 51, 11 Statements required by brokers; correc tion (Notice 50) 41, 6 Substitute Forms 1099; logos (Notice

45. 49, 8 Tax benefits for individuals performing

services in certain hazardous duty areas (PL 104–117) 34, 19 Tax conventions:

Fiji 40, 8 Jordan, 50, 8 Russia 36, 6 Taxes, accrual of deduction (RR 51)

43, 5 Tax-exempt bonds; arbitrage (RR 41)

32, 9 ; (Notice 49) 41, 6 Tax treatment of partnership items cor rection (Notice 44) 36, 7 Taxpayer Bill of Rights 2 (PL 104–168)

38, 8 Training costs; business expenses (RR

62. 53, 6 Trust treatment, domestic or foreign by

PL 104–188 (Notice 65) 52, 28 Work opportunity tax credit (Notice 52)