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. 97–12, page 5. Interest rates; underpayments and overpayments. The rate of interest determined under section 6621 of the Code for the calendar quarter beginning April 1, 1997, will be 8 percent for overpayments, 9 percent for underpayments, and 11 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 is 6.5 percent.

Rev. Rul. 97–14, page 5. Fringe benefits aircraft valuation formula. For purposes of section 1.61–21(g) of the regulations, relating to the rule for valuing noncommercial flights on employer-provided aircraft, the Standard Industry Fare Level (SIFL), cents-per-mile rates, and terminal charges in effect for the first half of 1997 are set forth.

REG–208288–90, page 14. Proposed regulations under section 905 of the Code relate to the substantiation requirements for taxpayers claiming foreign tax credits.

REG–209121–89, page 15. Proposed regulations under section 337 of the Code generally affect a taxable corporation that transfers all or substantially all of its assets to a tax-exempt entity or converts from a taxable corporation to a tax-exempt entity, and generally requires the taxable corporation to recognize gain or loss in such a transaction. A public hearing will be held on May 6, 1997.

REG–209824–96, page 19. Proposed regulations under section 1402 of the Code relate to the definition of limited partner for selfemployment tax purposes. A public hearing will be held on May 21, 1997.