Part IV. Items — Internal Revenue Bulletin 1998-32

Indiana Harvest Inc., Indianapolis, IN Kinetic Image Inc., New York, NY Life Stride Ministries, Inc., Boston, MA Living Hope Crisis Pregnancy Center,

Foundations Status of Certain Organizations

Announcement 98–76

Charlotte H. Edwards Christian Institute,

Inc., Powder Springs, GA Christa McAuliffe Staff and Parents

Lansing, MI Needy School Childrens Fund Inc., Perry,

The following organizations have failed to establish or have been unable to maintain their status as public charities or 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: American Indian Cultural Society of

Actively Contributing to Education, Oxnard, CA Chula Vista Connection Neighbors

Helping Neighbors, Chula Vista, CA Church of Grace, Lancaster, PA Clearwater Resource Coalition Inc.,

Nacogdoches, TX Fast Foundation, Inc., Charlotte, NC Fayette Elementary School PTO Inc.,

Chester, CA Missionary of Mercy Mission Inc.,

Detroit, MD Mountain Thunder Productions, Inc.,

Orofino, ID Citizens Concerned for Balanced

Education, San Francisco, CA Citizens for the Preservation of Santa

Rosa Creek, Santa Rosa, CA David Institute, Tustin, CA Easy Does It Inc., Houston, TX Edison Boosters Club Inc., Minneapolis,

FL Offspring, Inc., Baltimore, MD One Heart Music Press LTD, Bethany,

OK Our Community Associations, St. Louis,

MN Ellen M. Leach Memorial Home, Inc.,

MO Pantheon Corporation of Indiana,

Sterling, MA Environmental Fund, Inc., Petersburg,

VA Eureka Symphony Orchestra, Eureka, CA Family Outreach Services, Inc.,

Griffith, IN Pomfret House, Inc., Woodstock, VT Pony League of El Cajon, El Cajon, CA Radio Lollipop USA Inc., Miami, FL Richlee Deserved Foundation, Tacoma,

Sacramento, CA Somber Reptile Art and Music

WA Sacramento Girls Softball League Inc.,

North Florida Inc., Tallahassee, FL An Ark of Love Inc., Oakland, CA Belize International Educational

Fayetteville, GA Florence Housing Development

Foundation Inc., Lakeland, FL Big Orange Soccer Club Inc.,

Sweetwater, TN Booker Street Center, Jackson, MS Bret Harte Educational Assoc., San Jose,

Authority, Florence, AL Foundation for the Future, Las Vegas,

Development Center, Inc., Atlanta, GA Wagon Wheel James Street Residence

Inc., Syracuse, NY 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.

CA Caddo Fencers Booster Club, Shreveport,

NV Friends of Bayfront Park Inc., Miami, FL Greater Bethlehem Housing Corp.,

St. Louis, MO Hebrew Hospital Home of Westchester,

Inc., Bronx, NY His Image Outreach, Bedford, OH Hopkins County Literacy Council Inc.,

Sulphur Springs, TX Illumination Society, Inc., Schenectady,

LA Catskill Theatre Arts Center, Inc.,

Forestburgh, NY Center for School and Community

Relations, Inc., Flagtown, NJ Challenger 2 Expedition, Inc., Windsor,

NY Impact Outreach Inc., Arlington, VA

August 10, 1998 64 1998–32 I.R.B.

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 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

Abbreviations

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. Rul. —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.

1998–32 I.R.B. 65 August 10, 1998

Numerical Finding List ¹

Bulletins 1998–29 through 31

Announcements:

98–62, 1998–29 I.R.B. 13 98–68, 1998–29 I.R.B. 14 98–69, 1998–30 I.R.B. 16 98–70, 1998–30 I.R.B. 17 98–71, 1998–30 I.R.B. 17 98–72, 1998–31 I.R.B. 14 98–73, 1998–31 I.R.B. 14 98–74, 1998–31 I.R.B. 15 98–75, 1998–31 I.R.B. 15

Notices:

98–36, 1998–29 I.R.B. 8 98–37, 1998–30 I.R.B. 13

Railroad Retirement Quarterly Rate:

1998–31 I.R.B. 7

Proposed Regulations:

REG–104641–97, 1998–29 I.R.B. 9 REG–110403–98, 1998–29 I.R.B. 11 REG–116608–97, 1998–29 I.R.B. 12 REG–119227–97, 1998–30 I.R.B. 13

Revenue Procedures:

98–43, 1998–29 I.R.B. 8

Revenue Rulings:

98–34, 1998–31 I.R.B. 12 98–35, 1998–30 I.R.B. 4 98–36, 1998–31 I.R.B. 6

Treasury Decisions:

8771, 1998–29 I.R.B. 6 8772, 1998–31 I.R.B. 8 8773, 1998–29 I.R.B. 4 8774, 1998–30 I.R.B. 5 8775. 1998–31 I.R.B. 4

1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 1998–1 through 1998–28 will be found in Internal Revenue Bulletin 1998–29, dated July 20, 1998.

August 10, 1998 66 1998–32 I.R.B.

Finding List of Current Action on Previously Published Items ¹

Bulletins 1998–29 through 31

*Denotes entry since last publication

1 A cumulative finding list for previously published items mentioned in Internal Revenue Bulletins 1998–1 through 1998–28 will be found in Internal Revenue Bulletin 1998–29, dated July 20, 1998.

1998–32 I.R.B. 67 August 10, 1998

Notes

August 10, 1998 68 1998–32 I.R.B.

Notes

1998–32 I.R.B. 69 August 10, 1998

Notes

August 10, 1998 70 1998–32 I.R.B.

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