SEC. 4. EFFECT ON OTHER

REVENUE PROCEDURES

Revenue Procedure 96–42, 1996–32 I.R.B. 14, covering paper returns and statements for payments made during the 1996 calendar year is hereby superseded.

July 7, 1997 18 1997-27 I.R.B.

1997-27 I.R.B. 19 July 7, 1997

July 7, 1997 20 1997-27 I.R.B.

1997-27 I.R.B. 21 July 7, 1997

July 7, 1997 22 1997-27 I.R.B.

1997-27 I.R.B. 23 July 7, 1997

July 7, 1997 24 1997-27 I.R.B.

1997-27 I.R.B. 25 July 7, 1997

July 7, 1997 26 1997-27 I.R.B.

1997-27 I.R.B. 27 July 7, 1997

July 7, 1997 28 1997-27 I.R.B.

1997-27 I.R.B. 29 July 7, 1997

July 7, 1997 30 1997-27 I.R.B.

1997-27 I.R.B. 31 July 7, 1997

July 7, 1997 32 1997-27 I.R.B.

1997-27 I.R.B. 33 July 7, 1997

July 7, 1997 34 1997-27 I.R.B.

1997-27 I.R.B. 35 July 7, 1997

July 7, 1997 36 1997-27 I.R.B.

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

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

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

July 7, 1997 38 1997–27 I.R.B.

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

Padgett, John Orleans, MA Attorney May 22, 1997 to October 21, 1998

Crisp, Jerry W. Dallas, TX CPA June 1, 1997 to May 31, 2000

Kessel, Donald K. Export, PA CPA June 1, 1997 to November 30, 1998

Klimchak, Joseph Aliquippa, PA CPA June 1, 1997 to February 28, 1998

Steele, Lewis M. Pittsburgh, PA CPA June 1, 1997 to May 31, 1998

Castleberry, Gene A. Oklahoma City, OK Attorney June 4, 1997 to August 3, 1997

O’Connor, Paul J. Hanover, MA CPA June 6, 1997 to June 5, 2000

Olshan, Robert M. Washington, DC CPA June 10, 1997 to December 9, 1998

Johnson, Kirk L. Ann Arbor, MI CPA July 1, 1997 to June 30, 1999

Mattutat, Stephen Ellicott City, MD CPA July 1, 1997 to March 31, 1998

Trenary, Lloyd R. Oklahoma City, OK CPA August 1, 1997 to March 31, 1998

Ritchey Jr., Ferris Birmingham, AL Attorney August 1, 1997 to July 31, 2000

Gold, Howard G. Hamden, CT CPA August 1, 1997 to July 31, 1999

Womack, Kathleen Hammond, LA CPA August 1, 1997 to July 31, 1999

1997–27 I.R.B. 39 July 7, 1997

Public Law:

105–2, 1997–18 I.R.B. 14

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 97–31, 1997–26 I.R.B. 6

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 ¹

Bulletins 1997–1 through 1997–26

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 97–63, 1997–26 I.R.B. 8 97–64, 1997–26 I.R.B. 9 97–65, 1997–26 I.R.B. 9 97–66, 1997–26 I.R.B. 9

Delegation Orders:

232 (Rev. 3), 21

1See footnote at end of list.

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 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 97–36, 1997–26 I.R.B. 6

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

July 7, 1997 40 1997–27 I.R.B.

Numerical Finding List—Continued Bulletins 1997–1 through 1997–26

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 8721, 1997–26 I.R.B. 4

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.

1997–27 I.R.B. 41 July 7, 1997

Finding List of Current Action on Previously Published Items ¹

Bulletins 1997–1 through 1997–26

*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

July 7, 1997 42 1997–27 I.R.B.

Internal Revenue Bulletins 1997–1 Through 1997–26

For index of items published during the last six months of 1996, see I.R.B. 1997–1, dated January 6, 1997.

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

Regulations:

26 CFR 26.2652–1, amended; generation-skipping transfer tax (TD 8720) 23, 4

Cash or deferred arrangements (No

tice 2) 2, 22 Funding:

Deposits (Notice 15) 8, 23 Epoxy (DGEBA) determination (Notice

22. 13, 9 Proposed regulations:

26 CFR 48.4081–1, amended; 48.4082–5, 48.6715–2, added; gasoline and diesel fuel excise tax, special rules for Alaska, definition of aviation gasoline and kerosene (REG–247678–96) 6, 17 26 CFR 54.9801–1 through –6, 54.9802–1, 54.9804–1, 54.9806–1, added; group health plan, health insurance portability (REG– 253578–96) 19, 93 Regulations:

Credit for producing fuel from a nonconventional source, section 29 inflation adjustment factor, and reference price (Notice 28) 18, 45 Credits against tax:

Low-income housing credit:

Building’s credit period beginning

after 1995 (RR 4) 3, 6 Satisfactory bond, bond factor amounts for January, February, and March 1997 (RR 16) 13, 4 ; for April, May, and June 1997 (RR 25) 23, 4 Depreciation:

Retail motor fuels outlets (RP 10) 2, added; diesel fuel excise tax, special rules for Alaska (TD 8693) 6, 9 26 CFR 54.9801–1T through –6T, 54.9802–1T, 54.9804–1T, 54.9806– 1T, added; group health plans, access, portability, and renewability requirements (TD 8716) 19, 5

59 Differential earnings rate (Notice 17) 10,

34 Domestic asset/liability and investment

yield percentages (RP 16) 5, 25 Electing Small Business Trust (ESBT)

election (Notice 12) 3, 11 Electricity from certain renewable re

sources: Inflation adjustment factor and refer

ence prices, calendar year 1997 (Notice 30) 20, 6 Employee plans:

Full funding limitations, weighted

Railroad retirement:

Rate determination, quarterly (April 1,

Proposed regulations:

26 CFR 25.2702–1(c)(3), revised; charitable remainder trusts (REG– 209823–96) 18, 47

1997. 21, 4 Regulations:

26 CFR 31.3406(j)–1, added; 35a.3406–3, removed; taxpayer identification number (TIN) matching program (TD 8721) 26, 4 Social Security domestic employee cov

average interest rate, January 1997 (Notice 8) 4, 7 ; February 1997 (Notice 16) 9, 15 ; March 1997 (Notice 23) 14, 8 ; April 1997 (Notice 27) 17, 7 ; May 1997 (Notice 33) 22, 22 ; June 1997 (Notice 35) 25, 32 Qualification:

erage threshold amount for 1997, 9, 17

Qualified domestic relations orders

(Notice 11) 2, 49 Qualified joint and survivor annu

Proposed regulations:

ities (Notice 10) 2, 49 SIMPLES (RP 9) 2, 55 SIMPLE–IRAs (Notice 6) 2, 26 ; (RP

26 CFR 20.2044–1, added; 20.2056(b)–7, amended; estate and gift tax marital deduction (REG– 209830–96) 15, 7 Regulations:

29. 24, 9 User fees (RP 8) 1, 187 Exempt organizations:

Tax consequences of physician recruit

26 CFR 20.2044–1T, 20.2056(b)–7T, –10T, added; estate tax marital deduction (TD 8714) 15, 5

Abusive trusts (Notice 24) 16, 6 Accounting periods; small business cor porations (Notice 20) 10, 52 Adoption assistance (Notice 9) 2, 35 Advance guidance under Section 877

(Notice 19) 10, 40 Alternative minimum tax, change in ac counting method (Notice 13) 6, 13 Automobile inflation adjustment (RP 20)

11, 10 Books and records; electronic storage;

imaging (RP 22) 13, 9 Changes in accounting periods and methods of accounting (RP 27) 21, 10 Charitable remainder unitrusts; no rule

on CRT abuses (RP 23) 17, 7 Consolidated returns, TD 7637; correc tion (Notice 29) 20, 6

ment incentives provided by hospitals described in section 501(c)(3) of the Code (RR 21) 18, 8 Unrelated business taxable income (RP 12) 4, 7 User fees (RP 8) 1, 187 Foreign trust and foreign gift reporting

Airport and airway trust fund excise

taxes (PL 105–2) 18, 14

provisions (Notice 34) 25, 22

1997–27 I.R.B. 43 July 7, 1997

Forms W–2 and W–3; general rules and

specifications for private printing (RP 24) 16, 10 ; correction (RP 24A) 20, 7 Form 8851; electronic and magnetic media filing specifications (RP 25) 17, 8 Fringe benefits aircraft valuation for mula (RR 14) 11, 5 General asset accounts; election (RP 30)

Proposed regulations—Continued

26 CFR 1.905–2, amended; foreign tax credit filing requirements (REG–208288–90) 11, 14 26 CFR 1.1275–7, 1.1286–2, added; inflation-indexed debt instruments (REG–242996–96) 9, 18 26 CFR 1.1293–2, 1.1295–2, added; qualified electing fund elections, preferred shares, hearing (REG– 209040–88) 7, 34 26 CFR 1.1396–1, added; empowerment zone employment credit; qualified zone employees (REG– 209834–96) 4, 9 26 CFR 1.1402(a)–18, withdrawn; (REG–209729–94) 11, 19 26 CFR 1.6013–2, 301.6334–1, 301.6601–1, 301.6651–1, 301.7430– 0, –1, –2, –4, –5, amended; 301.6656–3, added; 301.7122–1(e), 301.7430–6, revised; Taxpayer Bill of Rights 2 and Personal Responsibility and Work Opportunity Reconciliation Act of 1996, miscellaneous sections affected (REG– 248770–96) 8, 33 26 CFR 1.7701(1)–1, amended; 1.7701(1)–2; obligation-shifting transactions, multiple-party, realized income and deductions (REG– 209817–96) 7, 41 26 CFR 53.6011–1, amended; 53.6017– 1T; return and time for filing requirements (REG–247862–96) 8, 32 26 CFR 301.7701–5, amended; 301.7701–7, added; residence of trusts and estates (REG–251703– 96) 25, 5 Qualified long-term care, definitions (Notice 31) 21, 5 Qualified mortgage bonds; mortgage credit certificates; national median gross income (RP 26) 17, 17 Regulations:

26 CFR 1.25–3, added; 1.25–3T, amended; mortgage credit certificate reissuance (TD 8692) 3, 4 26 CFR 1.42–16T, added; low-income housing tax credits, Federal grants (TD 8713) 14, 4 26 CFR 1.45B–1; withdrawal of credit for employer social security taxes paid on employee tips (REG– 209672–93) 6, 15 26 CFR 1.45B–1T, removed; credit for employer social security taxes paid on employee tips (TD 8699) 6, 4

25, 20 Insurance companies:

Interest rate tables (RR 2) 2, 8 Premium stabilization reserves (RR 5)

4, 5 Interest:

Investment:

Federal short-term, mid-term, and

Proposed regulations—Continued

26 CFR 1.167(a)–3, amended; 1.167(a)–14, 1.197–0, 1.197–2, added; amortization of intangible property (REG–209709–94) 13, 12 26 CFR 1.274–5, added; substantiation of business expenses for travel, entertainment, gifts, and listed property (REG–209785–95) 18, 46 26 CFR 1.337(d)–4, added; certain asset transfers to tax-exempt entity (REG–209121–89) 11, 15 26 CFR 1.338(b)–2, –3, added; intangibles under sections 1060 and 338 (REG–252665–96) 12, 46 26 CFR 1.354–1, 1.355–1, 1.356–3, amended; reorganizations, receipt of securities (REG–249819–96) 7, 50 26 CFR 1.368–1, amended; shareholder interest continuity requirement for corporate reorganizations (REG–252231–96) 7, 52 26 CFR 1.368–1, –2, amended; continuity of interest and business requirements (REG–252233–96) 9, 19 26 CFR 1.446–1, amended; 301.9100–1(h), added; 301.9100–3, revised; adoption or change of accounting method, extensions of time to make elections (REG– 209837–96; REG–105299–97) 23, 8 26 CFR 1.453–11, added; installment obligations received from liquidating corporations; partial withdrawal (REG–209332–80) 14, 9 26 CFR 1.468A–2, –3, amended; nuclear decommissioning reserve funds; revised schedules of ruling amounts (REG–209828–96) 6, 15 26 CFR 1.643(h)–1, 1.672(f)–1, –2, –3, –4, –5, added; 1.671–2(e), revised; inbound grantor trusts with foreign grantors (REG–252487–96) 25, 9 26 CFR 1.664–1(a)(7), (d)(1)(iii), (f)(4), added; 1.664–2, revised; 1.664–3, amended; charitable remainder trusts (REG–209823–96) 18, 47 26 CFR 1.704–3, 1.1245–1, amended; depreciation allocations, recapture among partners in a partnership (REG–209762–95) 3, 12 26 CFR 1.801–4, amended; life insurance reserves, recomputation hearing (REG–246018–96) 8, 30 26 CFR 1.832–4, amended; insurance companies, determination of earned premiums (REG–209839–96) 8, 26

long-term rates for January 1997 (RR 1) 2, 10 ; February 1997 (RR 7) 5, 14 ; March 1997 (RR 10) 10, 31 ; April 1997 (RR 17) 14, 5 ; May 1997 (RR 19) 18, 11 ; June 1997 (RR 24) 22, 17 Penalties:

Underpayment and overpayment rates for April 1997 (RR 12) 11, 5 ; July 1997 (RR 23) 22, 18 Inventories:

LIFO, price indexes, department stores, November 1996 (RR 6) 4, 4 ; December 1996 (RR 8) 7, 4 ; January 1997 (RR 15) 12, 42 ; February 1997 (RR 18) 15, 4 ; March 1997 (RR 22) 20, 5 ; April 1997 (RR 26) 24, 4 Losses:

Net operating; specified liability losses (Notice 36) 26, 6 Low-income housing tax credit (Notice

14. 8, 23 Major disaster areas (RR 11) 10, 5 Medical and dental expenses (RR 9) 9,

4 Medical savings accounts:

High-deductible plan (RR 20) 19, 4 Modified guaranteed contracts (Notice

32. 21, 8 Obsolete revenue rulings and revenue

procedures under TD 8697 (Notice 1) 2, 22 Photocopy fee increase (RP 11) 6, 13 Pilot pre-submission conference proce

dure (RP 21) 12, 44 Proposed regulations:

26 CFR 1.41–0, amended; 1.41–4, revised; research activities increase, credit, hearing (REG–209494–90) 8, 24 26 CFR 1.42–16, added; low-income housing tax credits, Federal grants (REG–254394–96) 14, 14

July 7, 1997 44 1997–27 I.R.B.

Regulations—Continued

26 CFR 1.103–8(a)(5), revised; 1.103–8T, removed; 1.142–4, added; 1.148–0(c), amended; 1.148–1T through –6T and intermediary sections, –9T, –10T, –11T, redesignated; 1.148–1A through –6A and intermediary sections, amended; 1.148–2(b)(2)(ii), 1.148– 3, revised; 1.148–4, amended; 1.148–5(b)(2)(iii), (c)(2)(i), (c)(3)(ii), (d)(3)(ii), (e)(2)(ii)(B), (e)(2)(iii), 1.148–6(d)(3)(iii)(C), 1.148– 9(c)(2)(ii)(B) and (h)(4)(vi), revised; 1.148–10, –11, amended; 1.148–11A(i), revised; 1.149(d)–1, amended; 1.149(d)–1T, redesignated; 1.150–1, amended; 1.150– 1T, redesignated; tax-exempt bonds, arbitrage restrictions (TD 8718) 22, 4 26 CFR 1.108(a)–1, –2, 108(b)–1, 1.1016–7, –8, 1.1017–2, removed; 1.108–4, –5, added; 1.1017–1, revised; 1.301.9100–13T, removed; basis reduction due to discharge of indebtedness (REG–208172–91) 10, 59 26 CFR 1.108(c)–1T, 1.163(d)–1T, 1.1044(a)–1T, 1.6655(e)–1T, removed; 1.108(c)–1, 1.163(d)–1, 1.1044(a)–1, 1.6655(e)–1, added; Omnibus Budget Reconciliation Act, elections (TD 8688) 3, 7 26 CFR 1.141–1, revised; 1.143–1, redesignated; 1.144–3, removed; 1.141–0, –2 through –16, 1.142–0, –3, 1.144–0, 1.145–0, –1, –2, 1.147–0, –1, –2, 1.150–4, added; 1.142–1, –2, 1.144–1, –2, revised; 1.148–6, 1.150–1, amended; private activity bonds definition (TD 8712) 12, 4 26 CFR 1.170A–1, –13, amended; charitable contributions, deductibility, substantiation, and disclosure (TD 8690) 5, 5 26 CFR 1.267(f)–1, 1.1502–11, –13, –19, –20, –32, –43, –76, –80, corrected; consolidated returns, consolidated and controlled groups (Notice 25) 16, 8 26 CFR 1.280H–1T, amended; 1.274–5, redesignated; 1.274–5T, amended; substantiation of business expenses for travel, entertainment, gifts, and listed property (TD 8715) 18, 5

Regulations—Continued

26 CFR 1.338(b)–2T(b)(2)(v), –2T(c)(4), added; 1.338–3, 1.338(b)–2T, –3T, 1.1060–1T, amended; intangibles under sections 1060 and 338 (TD 8711) 12, 35 26 CFR Part 1, 1.338–0, –4, amended; 1.338–4T, removed; 1.338(i)–1(a) and (b), revised; target affiliates that are controlled foreign corporations (TD 8710) 13, 4 26 CFR 1.367(a)–3, added; foreign corporations, transfer of domestic stock or securities by U.S. person (TD 8702) 8, 4 26 CFR 1.446–1(e)(3)(i), amended; 1.446–1T, added; 301.9100–1T(h), amended; adoption or change of accounting method, extensions of time to make elections (TD 8719) 23, 4 26 CFR 1.475(b)–1T, –2T, 1.475(c)– 1T, –2T, 1.475(d)–1T, 1.475(e)–1T, removed; 1.475–0, 1.475(a)–3, 1.475(b)–1, –2, –4, 1.475(c)–1, –2, 1.475(d)–1, 1.475(e)–1, added; securities dealers; mark-to-market accounting; equity interests in related parties and dealer-customer relationship (TD 8700) 7, 5 26 CFR 1.581–1, revised; 1.581–2, 1.761–1(a), revised; 301.6109–1, amended; 301.7701–1, –2, –3, revised; 301.7701–4, amended; domestic unincorporated business organizations classified as partnerships or associations (TD 8697) 2, 11 26 CFR 1.704–1, –3, –4, 1.708–1, 1.732–2, amended; 1.743–1(d), 1.761–1(e), added; 301.6109–1, amended; termination of a partnership (TD 8717) 24, 5 26 CFR 1.731–2, added; partnerships, distribution of marketable securities (TD 8707) 7, 17 26 CFR 1.902–0, –1, –2, added; foreign taxes deemed paid by domestic corporate shareholder; computation (TD 8708) 10, 14 26 CFR 1.952–1(e), (f), added; 1.952– 2(c)(1), 1.954–1(d)(4)(iii), 1.954– 2(b)(3), 1.954–2(g)(2)(ii)(B)(1)(i), –(2), revised; 1.957–1, amended; 1.960–1(i), added; controlled foreign corporations, foreign bas company and foreign personal holding company income, definitions (TD 8704) 8, 12

Regulations—Continued

tic), Associate Chief Counsel (Employee Benefits and Exempt Organizations (RP 3) 1, 85 ; Associate Chief Counsel (International) (RP 7) 1, 185

26 CFR 1.1271–0, 1.1275–4, amended; 1.1275–7T, 1.1286–2T, added; inflation-indexed debt instrument (TD 8709) 9, 5 26 CFR 1.1291–0, –9, –10, added; 1.1291–0T, amended; 1.1291–9T, –10T, removed; treatment of shareholders of certain passive foreign investment companies (TD 8701) 7, 23 26 CFR 1.1368–1 amended; 1.1377– 0, –1, –2, –3, added; 18.1377–1, removed; S corporations and their shareholders, definitions under subchapter S (TD 8696) 6, 4 26 CFR 1.1402(a)–2, amended; definition of limited partner for selfemployment tax purposes (REG– 209824–96) 11, 19 26 CFR 1.6081–2, –6, added; 1.6081– 2T, –3T, –4T, removed; 1.6081–4, amended; 301.6651, amended; 301.6651–1T, removed; individual, partnership, trust, and U.S. real estate mortgage investment conduit income tax returns, automatic extension of filing time (TD 8703) 8, 18 26 CFR 1.6695–1(b), amended; 1.6695– 1T, removed; 301.6061–1, revised; 301.6061–1T, removed; returns, statements, or other documents, signing methods (TD 8689) 3, 9 26 CFR 31.3402(f)(5)–1, amended; 31.3402(f)(5)–2T, removed; employment taxes and collection of income taxes at source, Form W–4, electronic filing (TD 8706) 9, 11 26 CFR 53.6011–1, amended; 53.6071–1T; return and time for filing requirements (TD 8705) 8, 16 26 CFR 301.6103(n)–1, amended; return information disclosure; property or services for tax administration purposes, Justice Department (TD 8695) 4, 5 26 CFR 301.6231(a)(7)–1T, removed; 301.6231(a)(7)–1, added; limited liability companies; tax matters partner selection (TD 8698) 7, 29 26 CFR 301.6335–1, amended; sale of seized property (TD 8691) 5, 16 REIT preferred stock (Notice 21) 11, 9 Rulings:

Areas in which advance rulings will

not be issued: Associate Chief Counsel (Domes

1997–27 I.R.B. 45 July 7, 1997

Special use value; farms; interest rates

(RR 13) 16, 4 Tax conventions:

Determination letters, employee plans

(RP 6) 1, 153 Environmental cleanup costs; letter rulings (Notice 7) 1, 8 Letter rulings, determination letter, in formation letter, Associate Chief Counsel (Domestic), Associate Chief Counsel (Employee Benefits and Exempt Organizations), Associate Chief Counsel (Enforcement Litigation), Associate Chief Counsel (International) (RP 1) 1, 11 Rulings and determination letters, is suance procedures (RP 4) 1, 97 Technical advice; employee plans, ex empt organizations (RP 5) 1, 132

Technical advice to district directors

Accounting periods (Notice 3) 1, 8 Electing small business corporations

and chiefs, appeals offices, Associate Chief Counsel (Domestic), Associate Chief Counsel (Employee Benefits and Exempt Organizations), Associate Chief Counsel (Enforcement Litigation), Associate Chief Counsel (International) (RP 2) 1, 64 SBA guaranteed payment rights; partici pating securities (RR 3) 2, 5 Scenarios of disciplinary actions, 13, 32 S corporation bank accounting method

change (RP 18) 10, 53 S corporation subsidiaries (Notice 4) 2,

Shipping and aircraft agreements

Malta, 17, 5 Tax-exempt bonds:

Private activity bonds (RP 13) 5, 18 ;

(RP 14) 5, 20 ; (RP 15) 5, 21 Tax forms and instructions:

Magnetic media/electronic filing pro

24 Small Business Corporations:

gram for Form 1040NR filers (RP 28) 23, 9 Taxpayer assistance orders (DO[Rev. 3])

25, 21 Timely filing or payment; private deliv ery services (RP 19) 10, 55 ; (Notice 26) 17, 6 TIN matching; backup withholding (RP

31. 26, 6 Transfers to foreign entities (Notice 18)

10, 35

and banks (Notice 5) 2, 25

July 7, 1997 46 1997–27 I.R.B.