PART VII. CHRONOLOGY, EFFECT

Revenue rulings and revenue procedures (hereinafter referred to as “rulings”) that have an effect on previous rulings use the following defined terms to describe 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 ap

The following abbreviations in current use and for- merly 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.

plies to both A and B, the prior ruling 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Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings).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

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.

new ruling does more than restate the substance of a prior ruling, a combination of terms is used. For example, modified and superseded 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. Proc.. —Revenue Ruling. S —Subsidiary. S.P.R. —Statements of Procedral 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.

1998–12 I.R.B. 37 March 23, 1998

Numerical Finding List ¹

Bulletins 1998–1 through 1998–11

Announcements:

98–1, 1998–2 I.R.B. 38 98–2, 1998–2 I.R.B. 38 98–3, 1998–2 I.R.B. 38 98–4, 1998–4 I.R.B. 31 98–5, 1998–5 I.R.B. 25 98–6, 1998–5 I.R.B. 25 98–7, 1998–5 I.R.B. 26 98–8, 1998–6 I.R.B. 96 98–9, 1998–7 I.R.B. 35 98–10, 1998–7 I.R.B. 35 98–11, 1998–8 I.R.B. 42 98–12, 1998–8 I.R.B. 43 98–13, 1998–8 I.R.B. 43 98–14, 1998–8 I.R.B. 44 98–15, 1998–10 I.R.B. 36 98–16, 1998–9 I.R.B. 17 98–17, 1998–9 I.R.B. 16 98–18, 1998–10 I.R.B. 44 98–19, 1998–10 I.R.B. 44 98–20, 1998–11 I.R.B. 25 98–21, 1998–11 I.R.B. 26

Notices:

98–1, 1998–3 I.R.B. 42 98–2, 1998–2 I.R.B. 22 98–3, 1998–3 I.R.B. 48 98–4, 1998–2 I.R.B. 25 98–5, 1998–3 I.B.R. 49 98–6, 1998–3 I.R.B. 52 98–7, 1998–3 I.R.B. 54 98–8, 1998–4 I.R.B. 6 98–9, 1998–4 I.R.B. 8 98–10, 1998–6 I.R.B. 9 98–11, 1998–6 I.R.B. 18 98–12, 1998–5 I.R.B. 12 98–13, 1998–6 I.R.B. 19 98–14, 1998–8 I.R.B. 27 98–15, 1998–9 I.R.B. 8 98–17, 1998–11 I.R.B. 6

Proposed Regulations:

PS–158–86, 1998–11 I.R.B. 13 REG–100841–97, 1998–8 I.R.B. 30 REG–102894–97, 1998–3 I.R.B. 59 REG–104062–97, 1998–10 I.R.B. 34 REG–104691–97, 1998–11 I.R.B. 13 REG–105163–97, 1998–8 I.R.B. 31 REG–109333–97, 1998–9 I.R.B. 9 REG–109704–97, 1998–3 I.R.B. 60 REG–115795–97, 1998–8 I.R.B. 33 REG–119449–97, 1998–10 I.R.B. 35 REG–121755–97, 1998–9 I.R.B. 13 REG–209276–87, 1998–11 I.R.B. 18 REG–209463–82, 1998–4 I.R.B. 27 REG–209476–82, 1998–8 I.R.B. 36 REG–209484–87, 1998–8 I.R.B. 40 REG–209485–86, 1998–11 I.R.B. 21 REG–209807–95, 1998–8 I.R.B. 40 REG–251502–96, 1998–9 I.R.B. 14

Revenue Procedures:

98–1, 1998–1 I.R.B. 7 98–2, 1998–1 I.R.B. 74 98–3, 1998–1 I.R.B. 100

1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 1997–27 through 1997–52 will be found in Internal Revenue Bulletin 1998–1, dated January 5, 1998.

Revenue Procedures—Continued

98–4, 1998–1 I.R.B. 113 98–5, 1998–1 I.R.B. 155 98–6, 1998–1 I.R.B. 183 98–7, 1998–1 I.R.B. 222 98–8, 1998–1 I.R.B. 225 98–9, 1998–3 I.R.B. 56 98–10, 1998–2 I.R.B. 35 98–11, 1998–4 I.R.B. 9 98–12, 1998–4 I.R.B. 18 98–13, 1998–4 I.R.B. 21 98–14, 1998–4 I.R.B. 22 98–15, 1998–4 I.R.B. 25 98–16, 1998–5 I.R.B. 19 98–17, 1998–5 I.R.B. 21 98–18, 1998–6 I.R.B. 20 98–19, 1998–7 I.R.B. 30 98–20, 1998–7 I.R.B. 32 98–21, 1998–8 I.R.B. 27 98–23, 1998–10 I.R.B. 30 98–24, 1998–10 I.R.B. 31 98–25, 1998–11 I.R.B. 7

Revenue Rulings:

98–1, 1998–2 I.R.B. 5 98–2, 1998–2 I.R.B. 15 98–3, 1998–2 I.R.B. 4 98–4, 1998–2 I.R.B. 18 98–5, 1998–2 I.R.B. 20 98–6, 1998–4 I.R.B. 4 98–7, 1998–6 I.R.B. 6 98–8, 1998–7 I.R.B. 24 98–9, 1998–6 I.R.B. 5 98–10, 1998–10 I.R.B. 11 98–11, 1998–10 I.R.B. 13 98–12, 1998–10 I.R.B. 5 98–13, 1998–11 I.R.B. 4 98–14, 1998–11 I.R.B. 4

Treasury Decisions:

8740, 1998–3 I.R.B. 4 8741, 1998–3 I.R.B. 6 8742, 1998–5 I.R.B. 4 8743, 1998–7 I.R.B. 26 8744, 1998–7 I.R.B. 20 8745, 1998–7 I.R.B. 15 8746, 1998–7 I.R.B. 4 8747, 1998–7 I.R.B. 18 8748, 1998–8 I.R.B. 24 8749, 1998–7 I.R.B. 16 8750, 1998–8 I.R.B. 4 8751, 1998–10 I.R.B. 23 8752, 1998–9 I.R.B. 4 8753, 1998–9 I.R.B. 6 8754, 1998–10 I.R.B. 15 8755, 1998–10 I.R.B. 21

March 23, 1998 38 1998–12 I.R.B.

Finding List of Current Action on Previously Published Items ¹

Bulletins 1998–1 through 1998–11

Revenue Procedures:

91–59 Updated and superseded by 98–25, 1998–11 I.R.B. 7

95–35 95–35A Superseded by 98–19, 1998–7 I.R.B. 30

97–1 Superseded by 98–1, 1998–1 I.R.B. 7

97–2 Superseded by 98–2, 1998–1 I.R.B. 74

97–3 Superseded by 98–3, 1998–1 I.R.B. 100

97–4 Superseded by 98–4, 1998–1 I.R.B. 113

97–5 Superseded by 98–5, 1998–1 I.R.B. 155

97–6 Superseded by 98–6, 1998–1 I.R.B. 183

97–7 Superseded by 98–7, 1998–1 I.R.B. 222

97–8 Superseded by 98–8, 1998–1 I.R.B. 225

97–21 Superseded by 98–2, 1998–1 I.R.B. 74

97–53 Superseded by 98–3, 1998–1 I.R.B. 100

Revenue Rulings:

75–17 Supplemented and superseded by 98–5, 1998–2 I.R.B. 20

92–19 Supplemented in part by 98–2, 1998–2 I.R.B. 15

1 A cumulative finding list for previously published items mentioned in Internal Revenue Bulletins 1997–27 through 1997–52 will be found in Internal Revenue Bulletin 1998–1, dated January 5, 1998.

1998–12 I.R.B. 39 March 23, 1998

March 23, 1998 40 1998–12 I.R.B.

1998–12 I.R.B. 41 March 23, 1998

March 23, 1998 42 1998–12 I.R.B.

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