Part IV. Items of General Interest

Notice of Proposed Rulemaking and Notice of Public Hearing

Continuity of Interest

REG–120882–97

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking by cross-reference to temporary regulations and notice of public hearing.

SUMMARY: In T.D. 8761, page 13 of this Bulletin, the IRS is issuing temporary regulations providing guidance regarding satisfaction of the continuity of interest requirement for corporate reorganizations. The temporary regulations affect corporations and their shareholders. The text of those temporary regulations also serves as the text of these proposed regulations. In addition, this document provides notice of a public hearing on these proposed regulations.

DATES: Written comments and outlines of topics to be discussed at the hearing scheduled for Tuesday, May 26, 1998, must be received by Tuesday, May 5, 1998.

ADDRESSES: Send submissions to: CC:DOM:CORP:R (REG–120882–97), room 5226, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be hand delivered between the hours of 8 a.m. and 5 p.m. to CC:DOM:CORP:R (REG–120882–97), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue NW, Washington, DC. Alternatively, taxpayers may submit comments electronically via the Internet by selecting the “Tax Regs” option on the IRS Home Page, or by submitting comments directly to the IRS Internet site at http://www.irs. ustreas.gov/prod/tax_regs/comments.html. The public hearing will be held in room 2615, Internal Revenue Building, 1111 Constitution Avenue NW, Washington, DC.

FOR FURTHER INFORMATION CONTACT: Concerning the regulations, Phoebe Bennett, (202) 622-7750; concerning submissions and the hearing,

LaNita Van Dyke, (202) 622-7190 (not toll-free numbers).

SUPPLEMENTARY INFORMATION:

Background

In T.D. 8761, temporary regulations amend the Income Tax Regulations (26 CFR part 1) under section 368. The temporary regulations provide that in determining whether the continuity of interest requirement for corporate reorganizations is satisfied with respect to a potential reorganization, a proprietary interest in the target corporation is not preserved if, in connection with a potential reorganization, it is redeemed or acquired by a person related to the target corporation, or to the extent that, prior to and in connection with a potential reorganization, an extraordinary distribution is made with respect to it.

The text of the temporary regulations also serves as the text of these proposed regulations. The preamble to the temporary regulations describes the temporary regulations.

The temporary regulations do not provide guidance on the determination of whether a distribution will be treated as an extraordinary distribution, except that the rules of section 1059 do not apply for this purpose. The IRS and Treasury Department invite comments on whether the regulations should provide more specific guidance in this area.

Special Analyses

It has been determined that this notice of proposed rulemaking is not a significant regulatory action as defined in EO 12866. Therefore, a regulatory assessment is not required. It also has been determined that section 553(b) of the Administrative Procedure Act (5 U.S.C. chapter 5) does not apply to these regulations, and because the regulation does not impose a collection of information on small entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not apply. Pursuant to section 7805(f) of the Internal Revenue Code, this notice of proposed rulemaking will be submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small business.

Comments and Public Hearing

Before these proposed regulations are adopted as final regulations, consideration will be given to any comments that are submitted timely to the IRS. All comments will be available for public inspection and copying.

A public hearing has been scheduled at 10 a.m. on Tuesday, May 26, 1998, in room 2615, Internal Revenue Service, 1111 Constitution Avenue NW, Washington, DC. Because of access restrictions, visitors will not be admitted beyond the Internal Revenue Building lobby more than 15 minutes before the hearing starts.

The rules of 26 CFR 601.601(a)(3) apply to the hearing.

Persons that wish to present oral comments at the hearing must submit written comments by Tuesday, May 5, 1998 and submit an outline of the topics to be discussed and the time to be devoted to each topic (a signed original and eight (8) copies) by Tuesday, May 5, 1998.

A period of 10 minutes will be allotted to each person for making comments.

An agenda showing the scheduling of the speakers will be prepared after the deadline for receiving outlines has passed. Copies of the agenda will be available free of charge at the hearing.

Proposed Effective Date

These regulations are proposed to apply to transactions occurring after January 28, 1998, except that they do not apply to any transaction occurring pursuant to a written agreement which is (subject to customary conditions) binding on January 28, 1998, and at all times thereafter.

- - - -

Proposed Amendments to the Regulations

Accordingly, 26 CFR part 1 is proposed to be amended as follows:

PART 1—INCOME TAXES

Paragraph 1. The authority citation for part 1 continues to read in part as follows:

Authority: 26 U.S.C. 7805. * * * Par. 2. Section 1.368–1 is amended as follows:

1998–14 I.R.B. 25 April 6, 1998

1. Revising paragraphs (e)(1)(ii)(A), (e)(1)(ii)(B), (e)(2)(ii), and (f).

2. Adding paragraph (e)(6) Example 10 and Example 11. The addition and revisions read as follows:

§1.368-– Purpose and scope of exception of reorganization exchanges.

[The text of proposed paragraphs (e)(1)(ii)(A) and (B), (e)(2)(ii), (e)(6) Ex- ample 10 and Example 11, and (f) is the same as the text of §1.368–1T published in T.D. 8761.]

Michael P. Dolan, Deputy Commissioner of

Internal Revenue.

(Filed by the Office of the Federal Register on January 23, 1998, 12:15 p.m., and published in the issue of the Federal Register for January 28, 1998, 63 F.R. 4204)

Notice of Proposed Rulemaking and Notice of Public Hearing

Election to Amortize Start-Up Expenditures

REG–209373–81

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking and notice of public hearing.

SUMMARY: This document contains proposed regulations concerning start-up expenditures under section 195. The proposed regulations provide rules and procedures for electing to amortize start-up expenditures under section 195. The regulations affect all taxpayers wishing to amortize start-up expenditures under section 195. This document also provides notice of a public hearing on these proposed regulations.

DATES: Comments and outlines of topics to be discussed at the public hearing scheduled for June 2, 1998, at 10 a.m., must be received by April 13, 1998.

ADDRESSES: Send submissions to: CC:DOM:CORP:R (PS–36–81), room 5228, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044. In the alternative, submis

sions may be hand-delivered between the hours of 8:15 a.m. and 5 p.m. to: CC:DOM:CORP:R (REG–209373–81), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue NW, Washington, DC, or electronically, via the IRS Internet site at: http://www.irs.ustreas.gov/prod/tax_regs/comments.html. The public hearing will be held in the NYU Classroom, Room 2615, Internal Revenue Building, 1111 Constitution Avenue, NW, Washington, DC.

FOR FURTHER INFORMATION CONTACT: Concerning the regulations, David Selig, (202) 622-3040; concerning submissions and the hearing, LaNita VanDyke, (202) 622-7180 (not toll-free numbers).

SUPPLEMENTARY INFORMATION:

Paperwork Reduction Act

The collection of information contained in this notice of proposed rulemaking has been submitted to the Office of Management and Budget for review in accordance with the Paperwork Reduction Act of 1995 (44 U.S.C. 3507(d)).

Comments on the collection of information should be sent to the Office of Management and Budget, Attn: Desk Officer for the Department of the Treasury, Office of Information and Regulatory Affairs, Washington, DC 20503, with copies to the Internal Revenue Service, Attn: IRS Reports Clearance Officer, T:FP, Washington, DC 20224. Comments on the collection of information should be received by March 16, 1998. Comments are specifically requested concerning: Whether the proposed collection of information is necessary for the proper performance of the functions of the Internal Revenue Service, including whether the information will have practical utility; The accuracy of the estimated burden associated with the proposed collection of information (see below); How the quality, utility, and clarity of the information to be collected may be enhanced; How the burden of complying with the proposed collection of information may be minimized, including through the application of automated collection techniques or other forms of information tech

nology; and Estimates of capital or start-up costs of operation, maintenance, and purchase of services to provide information.

The requirement for the collection of information in this notice of proposed rulemaking is in §1.195-1(c). This information is required by the IRS to establish that a taxpayer properly has made an election to amortize start-up expenditures under section 195. This information will be used to determine whether the amount amortized under section 195 has been computed properly. The likely respondents are businesses and other for-profit organizations. Responses to this collection of information are required to make an election to amortize start-up expenditures under section 195. Estimated total annual reporting burden: 37,500 hours. The estimated annual burden per respondent varies from .10 hours to .50 hour, depending on individual circumstances, with an estimated average of .25 hours. Estimated number of respondents : 150,000. Estimated annual frequency of responses: one-time election.

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection of information displays a valid OMB control number.

Books or records relating to a collection of information must be retained as long as their contents may become material in the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by 26 U.S.C. 6103.

Background

This document contains proposed amendments to the Income Tax Regulations (26 CFR part 1) to provide regulations under section 195 of the Internal Revenue Code. Section 195 was added to the Internal Revenue Code of 1954 by section 102 of the Miscellaneous Revenue Act of 1980, and amended by section 94 of the Tax Reform Act of 1984.

Section 195 generally provides that no deduction is allowed for start-up expenditures unless the taxpayer elects to amortize the expenditures. If the taxpayer elects to amortize start-up expenditures under section 195(b)(1), the expenditures

April 6, 1998 26 1998–14 I.R.B.

are amortizable over a period of not less than 60 months beginning with the month when the active trade or business begins. Under section 195(d), an election to amortize start-up expenditures must be made not later than the time prescribed by law for filing the return for the taxable year in which the active trade or business begins (including extensions thereof). Announcement 81–43 (1981–1 I.R.B. 52) described the time and manner for making this election.

An expense is a start-up expenditure if it satisfies two conditions. First, the expense must be paid or incurred in connection with any one of the following: (1) creating an active trade or business, (2) investigating the creation or acquisition of an active trade or business, or (3) any activity entered into for profit and for the production of income before the day on which the active trade or business begins, in anticipation of the activity becoming an active trade or business (expenditures in this last category are start-up expenditures only if they are attributable to periods after June 30, 1984).

Second, the expenditure must be of the type that, if paid or incurred in connection with the operation of an existing active trade or business in the same field as that being entered into by the taxpayer, would be allowable as a deduction for the taxable year when paid or incurred.

Explanation of Provisions

The proposed regulations provide that an election to amortize start-up expenditures is made by attaching a statement to the taxpayer’s income tax return. The income tax return and statement must be filed not later than the date prescribed by law for filing the income tax return (including any extensions of time) for the taxable year when the active trade or business begins.

The IRS is interested in ways to simplify the filing of elections. The proposed regulations are intended to simplify the filing of section 195 elections in two ways. First, the proposed regulations clarify that a taxpayer who is uncertain as to the year in which the active trade or business begins need not file an election for each possible taxable year. Rather, a section 195 election for a particular trade or business will be effective if the trade or business becomes active in the year for

which the election is filed or in any subsequent year. In developing this notice of proposed rulemaking, more burdensome methods of making the election were considered and rejected. For example, an approach that would have required taxpayers to file an election statement each year was rejected. Second, the proposed regulations also allow taxpayers who have made timely elections under section 195 to file a revised statement with a subsequent return to include any start-up expenditures not included in the original statement.

Special Analyses

It has been determined that this notice of proposed rulemaking is not a significant regulatory action as defined in EO 12866. Therefore, a regulatory assessment is not required. It is hereby certified that these regulations do not have a significant impact on a substantial number of small entities. This certification is based upon the fact that the time required to prepare and file the election statement is minimal and will not have a significant impact on those small entities that choose to make the election. Therefore, a Regulatory Flexibility Analysis under the Regulatory Flexibility Act (5 U.S.C. chapter 6) is not required. Pursuant to section 7805(f) of the Internal Revenue Code, this notice of proposed rulemaking will be submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small business.

Comments and Public Hearing

Before these proposed regulations are adopted as final regulations, consideration will be given to any comments that are submitted (in the manner described in the ADDRESSES caption) timely to the IRS. All comments will be available for public inspection and copying.

A public hearing has been scheduled for Tuesday, June 2, 1998, at 10 a.m. in the NYU Classroom, Room 2615, Internal Revenue Building, 1111 Constitution Avenue, NW, Washington DC. Because of access restrictions, visitors will not be admitted beyond the Internal Revenue Building lobby more than 15 minutes before the hearing starts.

The rules of 26 CFR 601.601(a)(3) apply to the hearing.

Persons that wish to present oral comments at the hearing must submit comments by April 13, 1998 and submit an outline of the topics to be discussed and the time to be devoted to each topic by April 13, 1998.

A period of 10 minutes will be allotted to each person for making comments.

An agenda showing the scheduling of the speakers will be prepared after the deadline for receiving outlines has passed. Copies of the agenda will be available free of charge at the hearing.

Drafting Information

The principal author of these regulations is David Selig, Office of the Assistant Chief Counsel (Passthroughs and Special Industries), IRS. However, other personnel from the IRS and Treasury Department participated in their development.

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Proposed Amendments to the Regulations

Accordingly, 26 CFR part 1 is proposed to be amended as follows:

PART 1—INCOME TAXES

Paragraph 1. The authority citation for part 1 continues to read in part as follows:

Authority: 26 U.S.C. 7805 * * * Par. 2. Section 1.195–1 is added to read as follows:

§1.195–1 Election to amortize start-up expenditures.

(a) In general. Under section 195(b), a taxpayer may elect to amortize start-up expenditures (as defined in section 195(c)(1)). A taxpayer who elects to amortize start-up expenditures must, at the time of the election, select an amortization period of not less than 60 months, beginning with the month the active trade or business begins. The election applies to all of the taxpayer’s start-up expenditures. The election is irrevocable and the amortization period selected by the taxpayer in making the election may not subsequently be changed.

(b) Time and manner of making elec- tion. The election to amortize start-up expenditures under section 195 shall be made by attaching a statement containing the information described in paragraph (c)

1998–14 I.R.B. 27 April 6, 1998

Dayton Academy Boosters Club,

of this section to the taxpayer’s return. The statement must be filed no later than the date prescribed by law for filing the return (including any extensions of time) for the taxable year when the active trade or business begins. The statement may be filed with a return for any taxable year prior to the year in which the taxpayer’s active trade or business begins, but no later than the date prescribed in the preceding sentence. Accordingly, an election under section 195 filed in a taxable year prior to the year in which the taxpayer’s active trade or business begins will become effective in the month for the later year in which the taxpayer’s active trade or business begins.

(c) Information required. The statement shall set forth a description of the trade or business to which it relates with sufficient detail so that expenses relating to the trade or business can be identified properly for the taxable year in which the statement is filed and for all future taxable years to which it relates. To the extent known at the time the statement is filed, the statement also shall include a description of each start-up expenditure incurred (whether or not paid); the month when the active trade or business began (or was acquired); and the number of months (not less than 60) over which the expenditures are to be amortized. A revised statement to include any start-up expenditures not included in the taxpayer’s original election statement may be filed with a return filed after the return that contained the election.

(d) Effective date. This section applies to elections filed on or after the date final regulations are published in the Federal Register.

as operating foundations. Accordingly, grantors and contributors may not, after this date, rely on previous rulings or designations in the Cumulative List of Organizations (Publication 78), or on the presumption arising from the filing of notices under section 508(b) of the Code. This listing does not indicate that the organizations have lost their status as organizations described in section 501(c)(3), eligible to receive deductible contributions.

Former Public Charities. The following organizations (which have been treated as organizations that are not private foundations described in section 509(a) of the Code) are now classified as private foundations: Centro De Intercambio Cultural Mexico

Minneapolis, MN Cityvision Services Inc., Fort Worth, TX Civitas Associates Inc., St. Louis, MO Clarendon School District Two Education

Fairborn, OH Deaf and Hard of Hearing Outreach

Services Inc., Anderson, IN Dearborn Fire Fighters Burn Drive,

Dearborn, MI Decatur Cadet Core Inc., Decatur, AL Deep East Texas Fine Arts Series Inc.,

Jasper, TX Deer Park Christian Child Development

Center Inc., Cincinnati, OH Defense Readiness Foundation,

Americano, Brownsville, TX Century Plaza Housing Corporation of

Topeka, Topeka, KS CFIDS Central Support Network, West

Washington, DC Dekalb Co-Ops Inc., Atlanta, GA Del City Youth Park Inc., Del City, OK Delaware Action for Families and

Children Inc., Wilmington, DE Delaware Foundation for Literacy Inc.,

Chester, PA Chaldean Assyrian Foundation, Ferndale,

Wilmington, DE Deloach Ministries Inc., Houston, TX De Novo Systems Inc., Tempe, AZ Earthdance Institute Inc., Asheville, NC Earth Education Council Inc., Miami, FL Earth Shakers Inc., Blytheville, AR Earth Shuttle Foundation Inc., Reston,

MI Challengers Baseball Booster Club Inc.,

VA Earth Village Foundation, Houston, TX East Bay Senior Housing Inc., Denver,

Miami, FL Chamber Foundation Inc., Kissimmee,

FL Chamber Music Outreach Foundation,

Cambridge, MN East Denver Eruv Committee, Denver,

Chicago, IL Chamber Orchestra Arizona Limited,

Phoenix, AZ Chambers & Valentine Daycare Inc.,

CO East Central Community Arts,

Baton Rouge, LA Champaign Free Press Inc., Champaign,

CO East End Ball Association Emma St.,

Bigelow, AR East Green Bay Lightning Soccer Club,

IL City of Lakes Girls Basketball,

Green Bay, WI East Green Enrichment Center Inc.,

Wilson, NC East Liverpool Area Youth, E. Liverpool,

OH East Post Oak Volunteer Fire

Michael P. Dolan, Deputy Commissioner of

Internal Revenue.

Foundation, Manning, SC Clarksdale Law Enforcement

Association, Inc., Clarksdale, MS Clarksville-Montgomery County Council

of Commuity Services, Clarksville, TN Class of 1937, Lexington, MI Clay Center Day Care Inc., Clay Center,

Department, Detroit, TX East St. Louis Community Athletic Club

Inc., E. St. Louis, IL East West Oneness Foundation, Houston,

TX Eastern Chester County EMS Committee,

Richburg, SC Eastern Europe Outreach, Pueblo West,

(Filed by the Office of the Federal Register on January 12, 1998, 8:45 a.m., and published in the issue of the Federal Register for January 13, 1998, 63 F.R. 1933)

Foundations Status of Certain Organizations

Announcement 98–26

The following organizations have failed to establish or have been unable to maintain their status as public charities or

NE Clean Air Vehicle Association Inc.,

Atlanta, GA Clear Creek Education Foundation,

CO Eastern Shore Womens Fast Pitch,

League City, TX Daybreak Inc., Jackson, MS Dayspring Ministries Inc., Greenville,

Salisbury, MD Eastern Wildlife Center Inc., Greensville,

NC Echos of Life Inc., Irving, TX Family Ancestral Research Association,

MS Daystar Foundation Inc., Toledo, OH

Sandy, UT

April 6, 1998 28 1998–14 I.R.B.

Central Iowa Mens Chorus Inc., Des

Family Church of God Inc., Columbus,

IN Family Complex East Inc., Pittsburgh, PA Family Counseling and Resource of

Giles County Humane Association Inc.,

Pulaski, TN Gill Creek Baptist Church Inc.,

Columbia, SC Gillespie County Law Enforcement Youth

Activities League, Fredericksburg, TX Gillis Foundation, Biloxi, MS Gils Professional Youth Services,

Moines, IA Central Surgical Association Foundation,

Ann Arbor, MI Central Texas Hot Spurs Soccer Club,

Georgetown, TX Central Texas Quality Quorum Inc.,

Temple, TX Central Texas Volunteer Firefighters

Mississippi Inc., Brandon, MS Family Health Services of Lumberton

Inc., Lumberton, MS Family Leadership Project Inc., Little

Albuquerque, NM Ginosko Ministries Inc., Charlotte, NC Girls Incorporated of Orange County,

Rock, AR Family-Owned Business Institute,

Denver, CO Family Rescue Coalition of Citrus

Association, Blanket, TX Centro Cultural Mexicano, Denver, CO Dallas County Education Fund Inc.,

Selma, AL Dallas County Save Our Communities

Inc., Rockwall, TX Dallas CV Inc., Dallas, TX Dallas Life Ministries Inc., Dallas, TX Dallas Neighbors a Non-Profit

County Inc., Homosassa Springs, FL Family Strategies Inc., Clancy, MT Family Tree Ministries Inc., Wichita, KS Family YMCA of McNairy & Hardin

Orlando, FL Glad Tiding Ministries Inc., Lebanon, MO Gladiators Inc., Stone Mtn, GA Glasgow Independent Schools Education

Foundation Inc., Glasgow, KY Gleaning for Jesus Recycling Year 2000,

Counties, Adamsville, TN Famli First Inc., Richmond, VA Fannin County Youth Softball

Association Inc., Blue Ridge, GA Far Northeast Neighbors Inc., Denver,

Saginaw, MI Akademeia Inc., Cleveland, OH Ambassadors in Mashiyach, Azle, TX Avicultural Society of Tucson, Tucson,

Corporation, Dallas, TX Dalton Stewart Evangelistic Music,

Abilene, TX Dalton Village Outreach Center,

Coconut Grove, FL Daniel Catarisano Ministries, Houston, TX Danny Hood Evangelistic Association,

CO Far South Side Community Health

Center, Chicago Heights, IL Gem City Senior Olympics Inc., Quincy,

AZ Canaday Ministries, Inc., Fort Smith, AR Catholic Evidence Guild, Ann Arbor, MI Catholic Radio Broadcasting, Saint

Johns, MI Catoosa Senior Citizens Association Inc.,

Charlotte, NC Dance Expressions Inc., Florissant, MO Dance Project Inc., Tampa, FL Dancer Scholarship Foundation Inc.,

IL Gemini Nutriential Services Inc.,

Bellaire, TX General Baptist Home Mission Center,

Detroit, MI Generations United of Michigan,

Southfield, MI Genesis House, Richmond, VA Genesius Guild West Theatre Inc., Salt

Catoosa, OK Cedar Social, St. Paul, MN Celebrate Kids Inc., Fort Worth, TX Celebrate Two in 92, Ashdown, AR Celebration of Pianos, Denver, CO Celtic-American Heritage Society,

Jackson, MS Celuni Inc., Miami, FL Center for Disfigured Children, Ann

Kingsford, MI Danville Literacy Council, Danville, VA Darla Johnson Andrew Long and

Company, Austin, TX Darrons Oak Inc., Oklahoma City, OK Dartmouth Club of Houston Inc.,

Lake City, UT Georgetown Sportfishing Association

Houston, TX David L. Stone Wildlife Rehab Clinc

Inc., Lordsburg, NM Davids Mighty Men, Beaumont, TX Davidson Transit Organization,

Inc., Georgetown, SC Georgia Foundation for Athletic

Excellence Inc., Atlanta, GA Georgia Hooved Animal Humane Society

Arbor, MI Center for Health Care Access & Reform,

St. Paul, MN Center for Jewish Medical Heritage,

Nashville, TN Dawson Foundation Inc., Lynwood, IL Developmental Planning Associates of

Inc., Canton, GA Georgia Legal Foundation Inc., Atlanta,

GA Georgia Metros Athletic Foundation Inc.,

Cleveland, OH Center for Media in the Public Interest at

the Grosvener Institute, Carlisle, PA Center for Research in Human Ecology,

Houston, TX Center for Sustainable Living Inc.,

Decatur, GA Georgia Providers for Non Profits Inc.,

Greater New York Inc., Staten Island, NY E.J. Charities Inc., Little Rock, AR Each One Teach One Learning Center

Inc., Nashville, TN Eagle Star Inc., Scottsbluff, NE Eagle-Union Youth Soccer Association

Inc., Zionsville, IN Eagle Wing Estates Inc., Jackson, MS Earl Carl Institute for Legal and Social

Sandy Springs, GA Georgia Veterinary Medical Association

Foundation Inc., Norcross, GA Georgia Youth Leadership Council Inc.,

Shenandoah Junction, WV Center for the Development of Pluralistic

Education, Inc., Cincinnati, OH Center of Perpetual Help Inc., Stow, OH Center-Peace Ministries Inc., Palm City,

Policy Inc., Houston, TX Early Bird Child Care Food Program

Inc., Baton Rouge, LA Early Childhood Autism Project Inc.,

Fairfax Station, VA Germantown Touchdown Club,

Leadership, Inc., Eden Prairie, MN Center for Trauma Information and

Germantown, TN Get a Life Inc., Fort Worth, TX Ghana Neurological Foundation Inc.,

Orlando, FL Central Florida Police Stress Unit Inc.,

Overland Park, KS

Tampa, FL Gilbert and Sullivan Society of

FL Central Florida Earth Alliance Inc.,

Winter Park, FL

Rochester, Rochester, MN

1998–14 I.R.B. 29 April 6, 1998

Earning by Learing of Mississippi Bucks

Garden County Community Foundation

Inc., Oshkosk, NE Garfield Development Corporation,

Mills Station Foundation, Sacramento,

CA Nicaraguan Atlantic Development

for Books, Jackson, MS Earth Day Arizona Earth Day Phoenix,

Grand Rapids, MI Gary Accord Inc., Gary, IN Gary Freedom House Inc., Gary, IN Gary Oliver Ministries Inc., Nashville,

Phoenix, AZ Facility Committee, Jackson, AL Fair Havens Missionary Mission Inc.,

Association Inc., Miami, FL Sexton Mountain Parent Teacher Club,

Pompano Beach, FL Fairfield Ambulance Service Inc.,

Fairfield, TX Fairhope Historical Museum Inc.,

TN Gathering Place of Wilmington NC Inc.,

Beaverton, OR Vaad Hakashruth of San Antonio, San

Antonio, TX Vitamin E Research and Information

Service, Inc., LaGrange, IL Wekaf USA World Eskrima Kali Arnis,

Fairhope, AL Fairview Dixie Youth Inc., Grant, LA Faith Out Reach Center Inc., Kenova,

Wilmington, NC Gay and Lesbian Organization of

WV Falls City Community Art Gallery Inc.,

Professional Inc., Huntsville, AL Gays and Lesbians United for Equality

Inc., Louisville, KY G I F T Non Profit, Jackson, MS G P H S Alumni Association Inc., Grand

Torrance, CA World Cultural Exchange Foundation,

Louisville, KY Families Access Inc., Atlanta, GA Families Against Drugs Inc., Osceola,

Praire, TX Greater Atlanta Billy Graham Crusade

Inc., Atlanta, GA Guntersville VOA Elderly Housing, Inc.,

MO Families of Truckers Support Group,

Metairie, LA High Aspirations Home for Teens, Los

Joplin, MO Gabriel Foundation Inc., Wall, NJ Gainsville Volleyball Officials

Burbank, CA If an organization listed above submits information that warrants the renewal of its classification as a public charity or as a private operating foundation, the Internal Revenue Service will issue a ruling or determination letter with the revised classification as to foundation status. Grantors and contributors may thereafter rely upon such ruling or determination letter as provided in section 1.509(a)–7 of the Income Tax Regulations. It is not the practice of the Service to announce such revised classification of foundation status in the Internal Revenue Bulletin.

Association Inc., Gainesville, FL Galveston Club Inc., Galveston, TX Galveston County Medical Society Inc.,

Angeles, CA Infinite Sun Recycling, Kansas City, MO Interamerica Institute for Border Health

& Environment, El Paso, TX Manitowoc County Crimestoppers Inc.,

Galveston, TX Gangbusters, Inc., Tucson, AZ

Manitowoc, WI

April 6, 1998 30 1998–14 I.R.B.