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SECTION 7. EFFECTIVE DATE

Internal Revenue Bulletin 1997-26 · 2026-10-03 edition · updated 2026-10-04 · United States

The Service intends that the Program will be operational beginning on the later of July 1, 1997, or the date the necessary updates to the relevant systems of records are effective. However, the Service will accept an MOU from an agency wishing to participate in the Program and name/TIN data transmitted by a participant beginning on June 18, 1997.

DRAFTING INFORMATION

The principal authors of this revenue procedure are Luetta Donalds of the Office of Payer Compliance and Nancy Rose of the Office of Assistant Chief Counsel (Income Tax and Accounting). For further information regarding this revenue procedure, contact Ms. Donalds at (202) 622–8753, or Ms. Rose at (202) 622-4910 (not toll-free calls).

1997–26 I.R.B. 7 June 30, 1997

Announcement of the Expedited Suspension of Attorneys, Certified Public Accountants,…

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

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:

Name Address Designation Date of Suspension

Dally, Candace L. Winston-Salem, NC CPA Indefinite from April 16, 1997

Mellor, Gary D. Norton, KS Attorney Indefinite from April 16, 1997

Gottesman, Milton New York, NY CPA Indefinite from April 16, 1997

Wiener, James Germantown, NY Attorney Indefinite from April 16, 1997

Lunblad, Gerald Sacramento, CA CPA Indefinite from April 16, 1997

Driscoll, Robert J. Denver, CO Attorney Indefinite from April 16, 1997

Alico, Kenneth N. Orchard Park, NY CPA Indefinite from April 16, 1997

Mack, Roland G. Hyattsville, MD CPA Indefinite from May 1, 1997

Newman, Harry J. Covington, VA CPA Indefinite from May 16, 1997

Sehnert, Fred Dallas, TX CPA Indefinite from May 16, 1997

Gaskins, John D. Valdosta, GA CPA Indefinite from May 16, 1997

Turner, Charles L. Goshen, KY Attorney Indefinite from May 16, 1997

Thornton Jr., Kenneth W. Murrells Inlet, SC Attorney Indefinite from May 16, 1997

Kellogg, Richard White Hall, AR CPA Indefinite from May 16, 1997 Stec, Albert J. Schereville, IN CPA Indefinite from May 16, 1997

Huff Jr., James G. Raleigh, NC CPA Indefinite from May 16, 1997 Seall, William Dayton, OH Attorney Indefinite from May 16, 1997 Brunner, L. Keith Centerville, OH Attorney Indefinite from May 16, 1997 Bart, David R. Oakwood, OH Attorney Indefinite from May 16, 1997 Shafer, David A. Franklin, OH CPA Indefinite from May 16, 1997

Schouman, James Milford, MI Attorney Indefinite from May 16, 1997 Jones, Milo A. Greensboro, NC CPA Indefinite from May 16, 1997 Dolan, Gary L. Lincoln, NE Attorney Indedinite from May 16, 1997

Coorey, Edward T. Hampton, NH Enrolled Agent Indefinite from May 16, 1997 Sheehan, Thomas J. Maggie Valley, NC CPA Indefinite from May 16, 1997 Millonig, Arthur F. Dayton, OH Attorney Indefinite from May 16, 1997 McHaffie, Richard T. St. Paul, MN Attorney Indefinite from June 4, 1997

Rigler, Michael Gainesville, TX CPA Indefinite from June 4, 1997

1997–26 I.R.B. 11 June 30, 1997

Name Address Designation Date of Suspension

Hopkins, Diane E. St. Paul, MN Attorney Indefinite from June 4, 1997 Adae, F. Brian Barrington, RI Attorney Indefinite from June 4, 1997

Definition of Terms

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

Exceptions & meaning →

Abbreviations

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.

13

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.

Numerical Finding List 1

Bulletins 1997–1 through 1997–25

Announcements:

97–1, 1997–2 I.R.B. 63 97–2, 1997–2 I.R.B. 63 97–3, 1997–2 I.R.B. 63 97–4, 1997–3 I.R.B. 14 97–5, 1997–3 I.R.B. 15 97–6, 1997–4 I.R.B. 11 97–7, 1997–4 I.R.B. 12 97–8, 1997–4 I.R.B. 12 97–9, 1997–5 I.R.B. 27 97–10, 1997–10 I.R.B. 64 97–11, 1997–6 I.R.B. 19 97–12, 1997–7 I.R.B. 55 97–13, 1997–8 I.R.B. 38 97–14, 1997–8 I.R.B. 38 97–15, 1997–9 I.R.B. 23 97–16, 1997–9 I.R.B. 23 97–17, 1997–9 I.R.B. 23 97–18, 1997–10 I.R.B. 67 97–19, 1997–10 I.R.B. 68 97–20, 1997–11 I.R.B. 22 97–21, 1997–11 I.R.B. 23 97–22, 1997–12 I.R.B. 47 97–23, 1997–11 I.R.B. 23 97–24, 1997–11 I.R.B. 24 97–25, 1997–12 I.R.B. 47 97–26, 1997–12 I.R.B. 48 97–27, 1997–13 I.R.B. 30 97–28, 1997–14 I.R.B. 15 97–29, 1997–14 I.R.B. 16 97–30, 1997–14 I.R.B. 16 97–31, 1997–14 I.R.B. 16 97–32, 1997–14 I.R.B. 17 97–33, 1997–15 I.R.B. 8 97–34, 1997–15 I.R.B. 8 97–35, 1997–15 I.R.B. 9 97–36, 1997–15 I.R.B. 10 97–37, 1997–15 I.R.B. 10 97–38, 1997–15 I.R.B. 10 97–39, 1997–16 I.R.B. 27 97–40, 1997–16 I.R.B. 28 97–41, 1997–16 I.R.B. 28 97–42, 1997–17 I.R.B. 19 97–43, 1997–17 I.R.B. 19 97–44, 1997–17 I.R.B. 19 97–45, 1997–17 I.R.B. 20 97–46, 1997–18 I.R.B. 53 97–47, 1997–19 I.R.B. 94 97–48, 1997–20 I.R.B. 8 97–49, 1997–20 I.R.B. 8 97–50, 1997–20 I.R.B. 8 97–51, 1997–20 I.R.B. 9 97–52, 1997–21 I.R.B. 22 97–53, 1997–21 I.R.B. 22 97–54, 1997–22 I.R.B. 23 97–55, 1997–22 I.R.B. 23 97–56, 1997–23 I.R.B. 17 97–57, 1997–23 I.R.B. 18 97–58, 1997–24 I.R.B. 13 97–59, 1997–24 I.R.B. 13 97–60, 1997-24 I.R.B. 14 97–62, 1997–25, I.R.B. 34

Delegation Orders:

232 (Rev. 3), 21

Notices:

97–1, 1997–2 I.R.B. 22 97–2, 1997–2 I.R.B. 22 97–3, 1997–1 I.R.B. 8

1See footnote at end of list.

Notices—Continued

97–4, 1997–2 I.R.B. 24 97–5, 1997–2 I.R.B. 25 97–6, 1997–2 I.R.B. 26 97–7, 1997–1 I.R.B. 8 97–8, 1997–4 I.R.B. 7 97–9, 1997–2 I.R.B. 35 97–10, 1997–2 I.R.B. 41 97–11, 1997–2 I.R.B. 50 97–12, 1997–3 I.R.B. 11 97–13, 1997–6 I.R.B. 13 97–14, 1997–8 I.R.B. 23 97–15, 1997–8 I.R.B. 23 97–16, 1997–9 I.R.B. 15 97–17, 1997–10 I.R.B. 34 97–18, 1997–10 I.R.B. 35 97–19, 1997–10 I.R.B. 40 97–20, 1997–10 I.R.B. 52 97–21, 1997–11 I.R.B. 9 97–22, 1997–13 I.R.B. 9 97–23, 1997–14 I.R.B. 8 97–24, 1997–16 I.R.B. 6 97–25, 1997–16 I.R.B. 8 97–26, 1997–17 I.R.B. 6 97–27, 1997–17 I.R.B. 7 97–28, 1997–18 I.R.B. 45 97–29, 1997–20 I.R.B. 6 97–30, 1997–20 I.R.B. 6 97–31, 1997–21 I.R.B. 5 97–32, 1997–21 I.R.B. 8 97–33, 1997–22 I.R.B. 22 97–34, 1997–25 I.R.B. 22 97–35, 1997–25 I.R.B. 32

Proposed Regulations:

REG–209332–80, 1997–14 I.R.B. 9 REG–209040–88, 1997–7 I.R.B. 34 REG–209121–89, 1997–11 I.R.B. 15 REG–208288–90, 1997–11 I.R.B. 14 REG–209494–90, 1997–8 I.R.B. 24 REG–208172–91, 1997–10 I.R.B. 59 REG–209672–93, 1997–6 I.R.B. 15 REG–209709–94 1997–13 I.R.B. 12 REG–209729–94, 1997–11 I.R.B. 19 REG–209762–95, 1997–3 I.R.B. 12 REG–209785–95, 1997–18 I.R.B. 46 REG–209817–96, 1997–7 I.R.B. 41 REG–209824–96, 1997–11 I.R.B. 19 REG–254394–96, 1997–14 I.R.B. 14 REG–209823–96, 1997–18 I.R.B. 47 REG–209828–96, 1997–6 I.R.B. 15 REG–209830–96, 1997–15 I.R.B. 7 REG–209834–96, 1997–4 I.R.B. 9 REG–209837–96, 1997–23 I.R.B. 8 REG–209839–96, 1997–8 I.R.B. 26 REG–242996–96, 1997–9 I.R.B. 18 REG–246018–96, 1997–8 I.R.B. 30 REG–247678–96, 1997–6 I.R.B. 17 REG–247862–96, 1997–8 I.R.B. 32 REG–248770–96, 1997–8 I.R.B. 33 REG–249819–96, 1997–7 I.R.B. 50 REG–251703–96, 1997–25 I.R.B. 5 REG–252231–96, 1997–7 I.R.B. 52 REG–252233–96, 1997–9 I.R.B. 19 REG–252487–96, 1997–25 I.R.B. 9 REG–252665–96, 1997–12 I.R.B. 46 REG–253578–96, 1997–19 I.R.B. 93 REG–105299–97, 1997–23 I.R.B. 8

Public Law:

105–2, 1997–18 I.R.B. 14

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Railroad Retirement Quarterly Rate:

1997–21 I.R.B. 4

Revenue Procedures:

97–1, 1997–1 I.R.B. 11 97–2, 1997–1 I.R.B. 64 97–3, 1997–1 I.R.B. 84 97–4, 1997–1 I.R.B. 96 97–5, 1997–1 I.R.B. 132 97–6, 1997–1 I.R.B. 153 97–7, 1997–1 I.R.B. 185 97–8, 1997–1 I.R.B. 187 97–9, 1997–2 I.R.B. 56 97–10, 1997–2 I.R.B. 59 97–11, 1997–6 I.R.B. 13 97–12, 1997–4 I.R.B. 7 97–13, 1997–5 I.R.B. 18 97–14, 1997–5 I.R.B. 20 97–15, 1997–5 I.R.B. 21 97–16, 1997–5 I.R.B. 25 97–17, 1997–9 I.R.B. 15 97–18, 1997–10 I.R.B. 53 97–19, 1997–10 I.R.B. 55 97–20, 1997–11 I.R.B. 10 97–21, 1997–12 I.R.B. 44 97–22, 1997–13 I.R.B. 9 97–23, 1997–17 I.R.B. 7 97–24, 1997–16 I.R.B. 10 97–24A, 1997–20 I.R.B. 7 97–25, 1997–17 I.R.B. 8 97–26, 1997–17 I.R.B. 17 97–27, 1997–21 I.R.B. 10 97–28, 1997–23 I.R.B. 9 97–29, 1997–24 I.R.B. 9 97–30, 1997–25 I.R.B. 20

Revenue Rulings:

97–1, 1997–2 I.R.B. 10 97–2, 1997–2 I.R.B. 7 97–3, 1997–2 I.R.B. 5 97–4, 1997–3 I.R.B. 6 97–5, 1997–4 I.R.B. 5 97–6, 1997–4 I.R.B. 4 97–7, 1997–5 I.R.B. 14 97–8, 1997–7 I.R.B. 4 97–9, 1997–9 I.R.B. 4 97–10, 1997–10 I.R.B. 31 97–11, 1997–10 I.R.B. 5 97–12, 1997–11 I.R.B. 5 97–13, 1997–16 I.R.B. 4 97–14, 1997–11 I.R.B. 5 97–15, 1997–12 I.R.B. 42 97–16, 1997–13 I.R.B. 4 97–17, 1997–14 I.R.B. 5 97–18, 1997–15 I.R.B. 4 97–19, 1997–18 I.R.B. 11 97–20, 1997–19 I.R.B. 4 97–21, 1997–18 I.R.B. 8 97–22, 1997–20 I.R.B. 5 97–23, 1997–22 I.R.B. 18 97–24, 1997–22 I.R.B. 17 97–25, 1997–23 I.R.B. 4 97–26, 1997–24 I.R.B. 4

Social Security Domestic Coverage Threshold:

1997–9, I.R.B. 17

Tax Conventions:

1997–17 I.R.B. 5

Numerical Finding List—Continued Bulletins 1997–1 through 1997–25

Treasury Decisions:

8688, 1997–3 I.R.B. 7 8689, 1997–3 I.R.B. 9 8690, 1997–5 I.R.B. 5 8691, 1997–5 I.R.B. 16 8692, 1997–3 I.R.B. 4 8693, 1997–6 I.R.B. 9 8694, 1997–6 I.R.B. 11 8695, 1997–4 I.R.B. 5 8696, 1997–6 I.R.B. 4 8697, 1997–2 I.R.B. 11 8698, 1997–7 I.R.B. 29 8699, 1997–6 I.R.B. 4 8700, 1997–7 I.R.B. 5 8701, 1997–7 I.R.B. 23 8702, 1997–8 I.R.B. 4 8703, 1997–8 I.R.B. 18 8704, 1997–8 I.R.B. 12 8705, 1997–8 I.R.B. 16 8706, 1997–9 I.R.B. 11 8707, 1997–7 I.R.B. 17 8708, 1997–10 I.R.B. 14 8709, 1997–9 I.R.B. 5 8710, 1997–13 I.R.B. 4 8711, 1997–12 I.R.B. 35 8712, 1997–12 I.R.B. 4 8713, 1997–14 I.R.B. 4 8714, 1997–15 I.R.B. 5 8715, 1997–18 I.R.B. 5 8716, 1997–19 I.R.B. 5 8717, 1997–24 I.R.B. 5 8718, 1997–22 I.R.B. 4 8719, 1997–23 I.R.B. 4 8720, 1997–23 I.R.B. 6

1A cumulative list of all Revenue Rulings, Revenue Procedures, Treasury Decisions, etc., published in Internal Revenue Bulletins 1996–27 through 1996–53 will be found in Internal Revenue Bulletin 1997–1, dated January 6, 1997.

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Finding List of Current Action on Previously Published Items 1

Bulletins 1997–1 through 1997–25

*Denotes entry since last publication

Delegation Orders:

232 (Rev. 2) Modified by 232 (Rev. 3), 1997–25 I.R.B. 21

Revenue Procedures:

66–3 Modified by 97–11, 1997–6 I.R.B. 13

87–21 Modified by 97–11, 1997–6 I.R.B. 13

92–20 Modified by 97–1, 1997–1 I.R.B. 11

92–20 Modified by 97–10, 1997–2 I.R.B. 59

92–90 Superseded by 97–1, 1997–1 I.R.B. 11

94–52 Revoked by 97–11, 1997–6 I.R.B. 13

96–1 Superseded by 97–1, 1997–1 I.R.B. 11

96–2 Superseded by 97–2, 1997–1 I.R.B. 64

96–3 Superseded by 97–3, 1997–1 I.R.B. 84

96–4 Superseded by 97–4, 1997–1 I.R.B. 96

96–5 Superseded by 97–5, 1997–1 I.R.B. 132

96–6 Superseded by 97–6, 1997–1 I.R.B. 153

96–7 Superseded by 97–7, 1997–1 I.R.B. 185

96–8 Superseded by 97–8, 1997–1 I.R.B. 187

96–24 96–24A Superseded by 97–24, 1997–16 I.R.B. 10

96–37 Obsoleted by 97–26, 1997–17 I.R.B. 17

1A cumulative finding list for previously published items mentioned in Internal Revenue Bulletins 1996–27 through 1996–53 will be found in Internal Revenue Bulletin 1997–1, dated January 6, 1997.

Revenue Procedures—Continued

97–2 Amplified by 97–21, 1997–12 I.R.B. 44

97–3 Amplified by 97–23, 1997–17 I.R.B. 7

97–27 Superseded by 97–30, 1997–25 I.R.B. 20

Revenue Rulings:

70–480 Revoked by 97–6, 1997–4 I.R.B. 4

72–527 Obsoleted by 8704, 1997–8 I.R.B. 12

74–59 Revoked by 8708, 1997–10 I.R.B. 14

86–73 Obsoleted by TD 8717, 1997–24 I.R.B. 5

87–50 Obsoleted by TD 8717, 1997–24 I.R.B. 5

87–51 Obsoleted by TD 8717, 1997–24 I.R.B. 5

88–42 Obsoleted by TD 8717, 1997–24 I.R.B. 5

92–19 Supplemented in part by 97–2, 1997–2 I.R.B. 7

93–90 Obsoleted by TD 8717, 1997–24 I.R.B. 5

96–12 Superseded by 97–3, 1997–1 I.R.B. 84

96–13 Modified by 97–1, 1997–1 I.R.B. 11

96–22 Superseded by 97–3, 1997–1 I.R.B. 84

96–34 Superseded by 97–3, 1997–1 I.R.B. 84

96–39 Superseded by 97–3, 1997–1 I.R.B. 84

96–43 Superseded by 97–3, 1997–1 I.R.B. 84

96–56 Superseded by 97–3, 1997–1 I.R.B. 84

16

NOTES

17

NOTES

18

Exceptions & meaning →

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