W, and Y each use an accrual method of accounting and a calendar taxable year. Each of the acquisition agreements entered into by U, W, and Y were subject to customary conditions of closing. Finally, U, W, and Y each completed the acquisitions in 1998 and timely elected on their 1998 federal income tax returns to amortize start-up expenditures over a period of not less than 60 months under § 195(b).

LAW AND ANALYSIS

Section 195(a) provides that, except as otherwise provided in § 195, no deduction is allowed for start-up expenditures.

Section 195(b) provides that start-up expenditures may, at the election of the taxpayer, be treated as deferred expenses that are allowed as a deduction prorated equally over a period of not less than 60 months (beginning with the month in which the active trade or business begins).

Section 195(c)(1) defines “start-up expenditure,” in part, as any amount (A) paid or incurred in connection with investigating the creation or acquisition of an active trade or business, and (B) which, if paid or incurred in connection with the operation of an existing active trade or business (in the same field as the trade or business referred to in subparagraph (A)), would be allowable as a deduction for the taxable year in which paid or incurred. Thus, in order to qualify as start-up expenditures under § 195(c)(1), a taxpayer’s “investigatory costs” must satisfy the requirements in both §§ 195(c)(1)(A) and (B). In addition, the term “start-up expenditure” does not include any amount with respect to which a deduction is allowable under §163(a), 164, or 174.

Sections 162 and 1.162–1(a) of the Income Tax Regulations allow a deduction for all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business. Courts generally have construed § 162 as containing five conditions that an expenditure must meet to qualify for deduction. The expenditure must be (1) an expense, (2) ordinary, (3) necessary, (4) paid or incurred during the taxable year, and (5) made to carry on a trade or business. See Commissioner v. Lincoln Savings and Loan Ass’n., 403 U.S. 345 (1971).

Section 162.—Trade or Business Expenses

26 CFR 1.162–1: Business expenses.

What types of expenditures will qualify as investigatory costs that are eligible for amortization as start-up expenditures under section 195 of the Code when a taxpayer acquires the assets of an active trade or business? See Rev. Rul. 99–23, on this page.

Section 195.—Start-up Expenditures

(Also sections 162, 263; 26 CFR 1.162–1, 1.263(a)–1)

Start-up expenditures, business ex- penses, capital expenditures. Guidance is provided on the types of expenditures that will qualify as investigatory costs that are eligible for amortization as start-up expenditures under section 195 of the Code when a taxpayer acquires the assets of an active trade or business.

Rev. Rul. 99–23

ISSUE

When a taxpayer acquires the assets of an active trade or business, which expenditures will qualify as investigatory costs that are eligible for amortization as startup expenditures under § 195 of the Internal Revenue Code?

FACTS

Situation 1

In April 1998, corporation U hired an investment banker to evaluate the possibility of acquiring a trade or business unrelated to U ’s existing business. The investment banker conducted research on several industries and evaluated publicly available financial information relating to several businesses. Eventually, U narrowed its focus to one industry. The investment banker evaluated several businesses within the industry, including corporation V and several of V ’s competitors. The investment

banker then commissioned appraisals of V ’s assets and an in-depth review of V ’s books and records in order to determine a fair acquisition price. On November

1,1998, U entered into an acquisition agreement with V to purchase all the assets of V . U did not prepare and submit a letter of intent, or any other preliminary agreement or written document evidencing an intent to acquire V prior to executing the acquisition agreement.

Situation 2

In May 1998, corporation W began searching for a trade or business to acquire. In anticipation of finding a suitable target to acquire, W hired an investment banker to evaluate three potential businesses and a law firm to begin drafting regulatory approval documents for a target. Eventually, W decided to purchase all the assets of corporation X . W and X entered into an acquisition agreement on December 1, 1998.

Situation 3

In June 1998, corporation Y hired a law firm and an accounting firm to assist in the potential acquisition of corporation Z by performing certain services that the parties labeled as “preliminary due diligence.” These “due diligence” services included conducting research on Z ’s industry (including information relating to competitors of Z ), and analyzing financial projections for Z for 1998 and 1999. In September 1998, at Y ’s request, the law firm prepared and submitted a letter of intent to Z . The offer contained in the letter of intent resulted from prior discussions between Y and Z, and specifically stated that a binding commitment with respect to the proposed transaction would result only upon execution of an acquisition agreement. Thereafter, the law firm and accounting firm continued to provide services labeled as “due diligence,” including a review of Z ’s internal documents relating to insurance policies, employee agreements, and lease agreements, an indepth review of Z ’s books and records, and preparation of an acquisition agreement. On October 10, 1998, Y entered into an acquisition agreement with Z to purchase all the assets of Z .

In each of the three situations, the trades or businesses of the targets are active trades or businesses unrelated to the trades or businesses of U, W, and Y . U,

1999–20 I.R.B. 3 May 17, 1999

sale or property which may be depreciated or amortized based on its useful life. . . Whether an amount is consideration paid to acquire a business depends upon the facts and circumstances of the situation.

House Report at pages 10–11; Senate Report at pages 11–12.

Rev. Rul. 77–254, 1977–2 C.B. 63, which is specifically referenced by the legislative history of § 195 (House Report at 9, Senate Report at 10), considers which costs incurred in the potential acquisition of a new business are capital acquisition costs for purposes of §§ 165 and 263. That ruling provides that expenses incurred in the course of a general search for, or an investigation of, a business that relate to the decisions whether to purchase a business and which business to purchase are investigatory costs. However, once a taxpayer has focused on the acquisition of a specific business, expenses that are related to an attempt to acquire that business are capital in nature. Thus, the “final decision” referred to in the legislative history of § 195 is the point at which a taxpayer makes its decision whether to acquire a business, and which business to acquire, rather than the point at which a taxpayer and seller are legally obligated to complete the transaction.

Courts have long held that legal, brokerage, accounting, appraisal, and similar costs incurred to acquire a capital asset are capital expenditures under § 263. Woodward v. Commissioner, 397 U.S. 572 (1970) (when property is acquired by purchase, nothing is more clearly a part of the process of acquisition than the establishment of a purchase price); United States v. Hilton Hotels Corp., 397 U.S. 580 (1970); Beneficial Industrial Loan Corp. v. Handy, 16 F. Supp. 110, 112 (D. Del. 1936), aff’d, 92 F.2d 74 (3d Cir. 1937); Rev. Rul. 73–580, 1973–2 C.B. 86. For example, in Ellis Banking Corp. v. Commissioner, T.C. Memo. 1981–123, aff’d in part & rem’d in part, 688 F.2d 1376 (11th Cir. 1982), the taxpayer incurred expenses for office supplies, filing fees, travel, and accounting services in connection with its examination of target’s books and records. The examination was performed pursuant to an acquisition agreement for the purchase of target’s stock that was contingent on several terms and conditions, such as regulatory approval. The Tax Court concluded that the

Sections 263 and 1.263(a)–1(a) provide that no deduction is allowed for any amounts paid out for new buildings or for permanent improvements or betterments made to increase the value of any property or estate. Section 1.263(a)–2(a) provides that capital expenditures include the cost of acquisition, construction, or erection of buildings, machinery and equipment, furniture and fixtures, and similar property having a useful life substantially beyond the taxable year.

Through provisions such as §§ 162(a) and 263(a), the Code generally endeavors to match expenses with the revenues of the taxable period to which the expenses are properly attributable, thereby resulting in a more accurate calculation of net income for tax purposes. See, e.g., INDOPCO, Inc. v. Commissioner, 503 U.S. 79 (1992).

In describing the law prior to § 195, Congress explained that “investigatory expenses,” which were “costs incurred in seeking and reviewing prospective businesses prior to reaching a decision to acquire or enter any business,” normally were not deductible because they were not incurred in carrying on a trade or business within the meaning of § 162. See H.R. Rep. No. 1278, 96th Cong., 2d Sess. 9 (1980) (House Report); S. Rep. No. 1036, 96th Cong., 2d Sess 10 (1980) (Senate Report). The “carrying on a trade or business” requirement was not met where investigatory expenses were incurred by a taxpayer who was not yet carrying on any trade or business, or where a taxpayer was carrying on a trade or business but incurred costs to investigate the creation or acquisition of another, unrelated trade or business. Id. However, a taxpayer incurring costs to investigate the expansion of an existing business generally could deduct those costs under § 162, assuming the other requirements of that section were met. This disparity in the tax treatment of investigatory expenses resulting from the “carrying on a trade or business” requirement discouraged taxpayers from investigating the creation or acquisition of new trades or businesses. Section 195 was enacted, in part, to minimize this disparity and thereby encourage formation of new businesses by providing an amortization deduction for eligible investigatory expenses.

Accordingly, under § 195(c)(1)(B), expenditures described in § 195(c)(1)(A) that are incurred before the establishment of an active business are deemed to be paid or incurred in the operation of an existing active trade or business (in the same field as the business that the taxpayer is investigating whether to create or acquire), i.e., they are deemed to satisfy the carrying on a trade or business requirement. However, because § 195(c)(1)(B) also requires that an expenditure described in § 195(c)(1)(A) be allowable as a deduction for the taxable year in which paid or incurred, the expenditure still must meet all the other requirements of §162. Thus, the expenditure must be an ordinary expense under § 162, and not a capital expenditure, to be a start-up expenditure under § 195. “Section 195 did not create a new class of deductible expenditures for existing businesses. . . .

[I]n order to qualify under section 195(c)(1)(B), an expenditure must be one that would have been allowable as a deduction by an existing trade or business when it was paid or incurred.” FMR Corp. v. Commissioner, 110 T.C. No. 30 (June 18, 1998). See also §§ 161 and 261 (deductions are allowed, subject to capitalization provisions). Whether an expenditure is an ordinary expense or is capital in nature is a question of fact that depends on the context in which the expenditure is incurred. See Commissioner v. Idaho Power Co., 418 U.S. 1 (1974); Deputy v. duPont, 308 U.S. 488 (1940); Welch v. Helvering, 290 U.S. 111 (1933).

The legislative history of § 195 provides the following guidance regarding whether an expenditure is an ordinary investigatory cost that is an eligible start-up expenditure, or a capital acquisition cost:

Eligible expenses consist of investigatory costs incurred prior to reaching a final decision to acquire or enter that business. These costs include expenses incurred for the analysis or survey of potential markets, products, labor supply, transportation facilities, etc.

Start-up expenditures eligible for amortization do not include any amount with respect to which a deduction would not be allowed to an existing trade or business for the taxable year in which the expenditure was paid or incurred. . . . In addition, the amortization election for start-up expenditures does not apply to amounts paid or incurred as part of the acquisition cost of a trade or business. Also, start-up expenditures do not include amounts paid or incurred for the acquisition of property to be held for

May 17, 1999 4 1999–20 I.R.B.

expenses were nondeductible capital expenditures incurred in the acquisition of a capital asset. The Court of Appeals for the Eleventh Circuit substantially affirmed, noting that the requirement that costs be capitalized extends beyond the price payable to include any costs incurred by the buyer in connection with the purchase, such as appraisals of the property or the costs of meeting any conditions of sale.

Accordingly, expenditures incurred in the course of a general search for, or an investigation of, an active trade or business, i.e., expenditures paid or incurred in order to determine whether to enter a new business and which new business to enter (other than costs incurred to acquire capital assets that are used in the search or investigation), are investigatory costs that are start-up expenditures under § 195. Alternatively, costs incurred in the attempt to acquire a specific business are capital in nature and thus, are not start-up expenditures under § 195. The nature of the cost must be analyzed based on all the facts and circumstances of the transaction to determine whether it is an investigatory cost incurred to facilitate the whether and which decisions, or an acquisition cost incurred to facilitate consummation of the acquisition. The label that the parties use to describe the cost and the point in time at which the cost is incurred do not necessarily determine the nature of the cost.

In Situation 1, an examination of the nature of the costs incurred indicates that U made its decision to acquire V after the investment banker conducted research on several industries and evaluated publicly available financial information. The costs incurred to conduct industry research and review public financial information are typical of the costs related to a general investigation. Accordingly, the costs incurred to conduct industry research and to evaluate publicly available financial information are investigatory costs eligible for amortization as start-up expenditures under § 195. However, the costs relating to the appraisals of V ’s assets and an indepth review of V ’s books and records to establish the purchase price facilitate consummation of the acquisition, and thus, are capital acquisition costs. The costs incurred to evaluate V and V ’s competitors also may be investigatory costs, but only

to the extent they were incurred to assist U in determining whether to acquire a business and which business to acquire. If the evaluation of V and V ’s competitors occurred after U had made its decision to acquire V (for example, in an effort to establish the purchase price for V ), such evaluation costs are capital acquisition costs.

In Situation 2, the costs incurred to evaluate potential businesses are investigatory costs eligible for amortization as start-up expenditures under § 195 to the extent they relate to the whether and which decisions. However, the costs incurred to draft regulatory approval documents prior to the time W decided to acquire X are not start-up expenditures under § 195. The costs related to such activities, even if the activities occurred during the period W is engaged in a general search for a business, were not incurred in order to investigate whether to acquire a business and which business to acquire, but rather to facilitate an acquisition.

In Situation 3, an examination of the nature of the costs incurred by Y indicates that Y made its decision to acquire Z in September 1998, around the time that Y instructed the law firm to prepare and submit the letter of intent. The costs related to the “preliminary due diligence” services provided prior to that time (including the costs of conducting research on Z ’s industry and in reviewing financial projections of Z ) are typical of the costs incurred during an investigation to determine whether to acquire a new business and which new business to acquire. Thus, these costs are investigatory costs that are eligible for amortization as start-up expenditures under § 195. The costs related to “due diligence” services provided after that time, however, relate to the attempt to acquire the business and must be capitalized under § 263 as acquisition costs. Thus, the “due diligence” costs incurred to review T ’s internal documents, books and records, and to draft the acquisition agreements are not eligible for amortization under § 195.

HOLDING

Expenditures incurred in the course of a general search for, or investigation of, an active trade or business in order to determine whether to enter a new business

and which new business to enter (other than costs incurred to acquire capital assets that are used in the search or investigation) qualify as investigatory costs that are eligible for amortization as start-up expenditures under § 195. However, expenditures incurred in the attempt to acquire a specific business do not qualify as start-up expenditures because they are acquisition costs under § 263. The nature of the cost must be analyzed based on all the facts and circumstances of the transaction to determine whether it is an investigatory cost incurred to facilitate the whether and which decisions, or an acquisition cost incurred to facilitate consummation of an acquisition.

DRAFTING INFORMATION

The principal author of this revenue ruling is Susie K. Bird of the Office of Assistant Chief Counsel (Income Tax and Accounting). For further information regarding this revenue ruling contact Ms. Bird on (202) 622-4950 (not a toll-free call).

Section 7520.—Valuation Tables

26 CFR 20.7520–1: Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests.

T.D. 8819

DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Parts 1, 20, and 25

Use of Actuarial Tables in Valuing Annuities, Interests for Life or Terms of Years, and Remainder or Reversionary Interests

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final and temporary regulations.

SUMMARY: This document contains regulations relating to the use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests. These regulations are necessary because section 7520(c)(3) directs the Secretary to update the actuar

1999–20 I.R.B. 5 May 17, 1999

ial tables to reflect the most recent mortality experience available. These regulations will effect the valuation of inter vivos and testamentary transfers of interests dependent on one or more measuring lives. The text of the temporary regulations also serves as the text of the proposed regulations REG–103851–99, page 93 in this Bulletin.

DATES: These regulations are effective May 1, 1999.

FOR FURTHER INFORMATION CONTACT: Concerning the regulations, William L. Blodgett, (202) 622-3090 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

This document contains amendments to the regulations revising certain tables used for the valuation of partial interests in property under section 7520 of the Internal Revenue Code of 1986 (Code) to reflect the most recent mortality experience available.

In General

Section 7520, effective for transfers for which the valuation date is after April 30, 1989, provides that the value of an annuity, an interest for life or a term of years, and a remainder or reversionary interest is to be determined under tables published by the Internal Revenue Service based on a discount rate (rounded to the nearest two-tenths of one percent) equal to 120 percent of the applicable Federal mid-term rate in effect under section 1274(d)(1) for the month in which the valuation date falls. Section 7520(c)(3) directed the Secretary to issue tables not later than December 31, 1989, utilizing the then most recent mortality experience. Thereafter, the Secretary is directed to revise the tables used in valuing interests dependent on mortality experience not less frequently than once each 10 years to take into account the most recent mortality experience available as of the time of the revision.

These regulations incorporate revised Table S (Single Life Remainder Factors) and Table U(1) (Unitrust Single Life Remainder Factors) based on data compiled from the 1990 census as set forth in Life

Cross Reference to Regulation Sections

Table 90CM, and make conforming amendments to various sections to reflect the revised tables. The current tables are moved to sections containing actuarial material for historical reference. Table B, Table D, Tables F(4.2) through F(14.0), Table J, and Table K, which are not based on mortality experience, are not changed. Internal Revenue Service Publications 1457 “Actuarial Values, Book Aleph” (forthcoming 1999), 1458 “Actuarial Values, Book Beth” (forthcoming 1999), and 1459 “Actuarial Values, Book Gimel” (forthcoming 1999) will contain a complete set of actuarial tables that include factors not contained in the regulations (for example, annuity and life interest factors). Although not available on May 1, 1999, IRS anticipates these publications will be available by July 1, 1999. These publications will be available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402.

The following chart summarizes the applicable interest rates and the citations to textual materials and tables for the various periods covered under the regulations:

Valuation Interest Regulation Period Rate Section Table

Section 642:

Valuation, in general - 1.642(c)–6 before 01/01/52 4% 1.642(c)–6A(a) 01/01/52 – 12/31/70 3.5% 1.642(c)–6A(b) 01/01/71 – 11/30/83 6% 1.642(c)–6A(c) 12/01/83 – 04/30/89 10% 1.642(c)–6A(d) Table G 05/01/89 – 04/30/99 §7520 1.642(c)–6A(e) Table S (5/1/89 – 4/30/99) after 04/30/99 §7520 1.642(c)–6T(e) Table S (after 04/30/99)

Section 664:

Valuation, in general - 1.664–4 before 01/01/52 4% 1.664–4A(a) 01/01/52 – 12/31/70 3.5% 1.664–4A(b) 01/01/71 – 11/30/83 6% 1.664–4A(c) 12/01/83 – 04/30/89 10% 1.664–4A(d) Table E, Table F(1) 05/01/89 – 04/30/99 §7520 1.664–4A(e) Table U(1) (5/1/89 – 4/30/99) after 04/30/99 §7520 1.664–4T(e) Table U(1) (after 04/30/99) 1.664–4(e) Table D and Tables F(4.2) – F(14.0)

Section 2031:

Valuation, in general - 20.2031–7 before 01/01/52 4% 20.2031–7A(a) 01/01/52 – 12/31/70 3.5% 20.2031–7A(b) 01/01/71 – 11/30/83 6% 20.2031–7A(c)

May 17, 1999 6 1999–20 I.R.B.

Cross Reference to Regulation Sections (Continued)

Valuation Interest Regulation Period Rate Section Table

12/01/83 – 04/30/89 10% 20.2031–7A(d) Table A, Table B, Table LN 05/01/89 – 04/30/99 §7520 20.2031–7A(e) Table S (5/1/89 – 4/30/99) Life Table 80CNSMT after 04/30/99 §7520 20.2031–7T(d) Table S (after 04/30/99) and Life Table 90CM 20.2031–7(d) Table B, Table J, Table K, Section 2512:

Valuation, in general 25.2512–5 before 01/01/52 4% 25.2512–5A(a) 01/01/52 – 12/31/70 3.5% 25.2512–5A(b) 01/01/71 – 11/30/83 6% 25.2512–5A(c) 12/01/83 – 04/30/89 10% 25.2512–5A(d) 05/01/89 – 04/30/99 §7520 25.2512–5A(e) after 04/30/99 §7520 25.2512–5T(d)

entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not apply. Therefore, a Regulatory Flexibility Analysis is not required. Pursuant to section 7805(f) of the Internal Revenue Code, these regulations will be submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small business.

Drafting Information

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

- - - -

Adoption of Amendments to the Regulations

Accordingly, 26 CFR parts 1, 20, and 25 are amended as follows:

PART 1—INCOME TAXES

Paragraph 1. The authority citation for part 1 is amended by adding entries in numerical order to read in part as follows:

Authority: 26 U.S.C. 7805 * * * Section 1.170A–12 also issued under 26 U.S.C. 170(f)(4). * * * Section 1.642(c)–6 also issued under 26 U.S.C. 642(c)(5). Section 1.642(c)–6T also issued under 26 U.S.C. 642(c)(5). Section 1.642(c)–6A also issued under 26 U.S.C. 642(c)(5).

Effective Dates

These regulations are applicable in the case of annuities, interests for life or terms of years, and remainder or reversionary interests created after April 30, 1999.

Transitional Rules

The regulations provide certain transitional rules intended to alleviate any adverse consequences resulting from the proposed regulatory change. For gift tax purposes, if the valuation date of a transfer is after April 30, 1999, but before July 1, 1999, the donor may determine the value of the gift (and/or any applicable charitable deduction) under tables based on either Life Table 80CNSMT or Table 90CM (at the donor’s option). Similarly, for estate tax purposes, if the decedent dies after April 30, 1999, but before July 1, 1999, the value of any interest (and/or any applicable charitable deduction) may be determined under tables based on either Table 80CNSMT or Table 90CM, at the option of the decedent’s executor. However, the section 7520 interest rate utilized is the appropriate rate for the month in which the valuation date occurs. In accordance with this transitional rule and those contained in §§1.7520–2(a)(2), 20.7520–2(a)(2) and 25.7520–2(a)(2), in cases involving a charitable deduction, if the valuation date occurs after April 30, 1999, and before July 1, 1999, and the executor or donor elects under section 7520(a) to use the section 7520 interest rate for March 1999 or April 1999, then

the mortality experience contained in 80CNSMT must be used. If the executor or donor uses the section 7520 interest rate for May 1999 or for June 1999, then the tables based on either Table 80CNSMT or Table 90CM may be used. However, if the valuation date occurs after June 30, 1999, the executor or donor must use the new mortality experience contained in Table 90CM even if a prior month interest rate election under section 7520(a) is made. In addition, for estate tax purposes, the estate of a mentally incompetent decedent may elect to value the property interest included in the gross estate under the mortality table and interest rate in effect at the time the decedent became mentally incompetent or the mortality table and interest rate in effect on the decedent’s date of death if the decedent was under a mental incapacity that existed on May 1, 1999, and continued uninterrupted until the decedent’s death, or the decedent died within 90 days of regaining competency after April 30, 1999.

Special Analysis

It has been determined that this Treasury decision 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 these regulations do not impose a collection of information requirement on small

1999–20 I.R.B. 7 May 17, 1999

Section 1.664–1 also issued under 26 U.S.C. 664(a). Section 1.664–2 also issued under 26 U.S.C. 664(a). Section 1.664–3 also issued under 26 U.S.C. 664(a). Section 1.664–4 also issued under 26 U.S.C. 664(a). Section 1.664–4T also issued under 26 U.S.C. 664(a). Section 1.664–4A also issued under 26 U.S.C. 664(a). * * * Section 1.7520–1T also issued under 26 U.S.C. 7520(c)(2). * * *

Par. 2. Section 1.170A–6 is amended by revising paragraph (c)(5), Example ( 2 )(b) introductory text to read as follows:

§1.170A–6 Charitable contributions in trust.

• ---

(c) * * * (5) * * * Example 2. - * *

Where: n = the estimated number of years of useful life, i = the applicable interest rate under section 7520

of the Internal Revenue Code, v = 1 divided by the sum of 1 plus the applicable

interest rate under section 7520 of the Internal Revenue Code, x = the age of the life tenant, and lx = number of persons living at age x as set forth

in Table 90CM of §20.2031–7T (or, for prior periods, the tables set forth under §20.2031– 7A) of this chapter.

(3) The following example illustrates the provisions of this paragraph (b):

Example. A, who is 62, donates to Y University a remainder interest in a personal residence, consisting of a house and land, subject to a reserved life estate in A. At the time of the gift, the land has a value of $30,000 and the house has a value of $100,000 with an estimated useful life of 45 years, at the end of which the value of the house is expected to be $20,000. The portion of the property considered to be depreciable is $80,000 (the value of the house ($100,000) less its expected value at the end of 45 years ($20,000)). The portion of the property considered to be nondepreciable is $50,000 (the value of the land at the time of the gift ($30,000) plus the expected value of the house at the end of 45 years ($20,000)). At the time of the gift, the interest rate prescribed under section 7520 is 8.4 percent. Based on an interest rate of 8.4 percent, the remainder fac

the transfer was 6.0 percent. By reference to Table F(6.0) in §1.664–4(e)(6), the adjusted payout rate is 4.717% (5% 0.943396). The present value of the reversion is $6,473.75, computed by reference to Table D in §1.664–4(e)(6), as follows:

• ---

Par. 3. Section 1.170A–12T is added to read as follows:

§1.170A–12T Valuation of a remainder interest in real property for contributions made after July 31, 1969 (temporary).

(a) through (b)(1) [Reserved] For further guidance see §1.170A–12(a) through (b)(1).

(b)(2) Computation of depreciation factor after April 30, 1999. If the valuation of the remainder interest in depreciable property is dependent upon the continuation of one life, a special factor must be used. The factor determined under this paragraph (b)(2) is carried to the fifth dec

chapter for a person age 62 is 0.27925. The value of the nondepreciable remainder interest is $13,962.50 (0.27925 times $50,000). The value of the depreciable remainder interest is $16,148.80 (0.20186, computed under the formula described in paragraph (b)(2) of this section, times $80,000). Therefore, the value of the remainder interest is $30,111.30.

(c) through (e) [Reserved]. For further guidance see §1.170A–12(c) through (e).

Par. 4. Section 1.642(c)–6 is amended as follows:

1. Revise the section heading.

2. Paragraph (d) is removed.

3. Paragraph (e) is redesignated as paragraph (e) of §1.642(c)–6A.

4. New paragraphs (d) and (e) are added.

5. Paragraph (f) is revised. The revisions and addition read as follows:

§1.642(c)–6 Valuation of a remainder interest in property transferred to a pooled income fund.

• ---

computed on the basis of the interest rate and life contingencies prescribed in §20.2031–7T (or for certain prior periods, §20.2031–7A) of this chapter (Estate Tax Regulations) and on the assumption that the property depreciates on a straight-line basis over its estimated useful life. For transfers for which the valuation date is after April 30, 1999, special factors for determining the present value of a remainder interest following one life and an example describing the computation is contained in Internal Revenue Service Publication 1459, “Actuarial Values, Book Gimel,” (1999). A copy of this publication is available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402. See, however, §1.7520–3(b) (relating to exceptions to the use of prescribed tables under certain circumstances). Otherwise, in the case of the valuation of a remainder interest following one life, the special factor may be obtained through use of the following

guidance, see §1.642(c)–6T(d) and (e).

(f) Effective dates. This section applies after April 30, 1989, and before May 1, 1999. Par. 5. Section 1.642(c)–6T is added to read as follows:

§1.642(c)–6T Valuation of a remainder interest in property transferred to a pooled income fund (temporary).

(a) through (c) [Reserved]. For further guidance, see §1.642(c)–6(a) through (c).

(d) Valuation. The present value of the remainder interest in property transferred to a pooled income fund after April 30, 1999, is determined under paragraph (e) of this section. The present value of the remainder interest in property transferred to a pooled income fund for which the valuation date is before May 1, 1999, is determined under the following sections:

May 17, 1999 8 1999–20 I.R.B.

Valuation Dates Applicable After Before Regulations

• 01-01-52 1.642(c)–6A(a) 12-31-51 01-01-71 1.642(c)-6A(b) 2-31-70 2-01-83 1.642(c)–6A(c) 11-30-83 05-01-89 1.642(c)–6A(d) 04-30-89 05-01-99 1.642(c)–6A(e)

(e) Present value of the remainder in- terest in the case of transfers to pooled in- come funds for which the valuation date is after April 30, 1999 —(1) In general. In the case of transfers to pooled income funds for which the valuation date is after April 30, 1999, the present value of a remainder interest is determined under this section. See, however, §1.7520–3(b) (relating to exceptions to the use of prescribed tables under certain circumstances). The present value of a remainder interest that is dependent on the termination of the life of one individual is computed by the use of Table S in paragraph (e)(6) of this section. For purposes of the computations under this section, the age of an individual is the age at the individual’s nearest birthday.

(2) Transitional rules for valuation of transfers to pooled income funds. (i) For purposes of sections 2055, 2106, or 2624, if on May 1, 1999, the decedent was mentally incompetent so that the disposition of the property could not be changed, and the decedent died after April 30, 1999, without having regained competency to dispose of the decedent’s property, or the decedent died within 90 days of the date that the decedent first regained competency after April 30, 1999, the present value of a remainder interest is determined as if the valuation date with respect to the decedent’s gross estate is either before May 1, 1999, or after April 30, 1999, at the option of the decedent’s executor.

(ii) For purposes of sections 170, 2055, 2106, 2522, or 2624, in the case of transfers to a pooled income fund for which the valuation date is after April 30, 1999, and before July 1, 1999, the present value of the remainder interest under this section is determined by use of the section 7520 interest rate for the month in which the valuation date occurs (See §§1.75201(b) and 1.7520–2(a)(2)) and the appropriate actuarial tables under either paragraph (e)(6) of this section or §1.642(c)–6A(e)(5), at the option of the

donor or the decedent’s executor, as the case may be.

(iii) For purposes of paragraphs (e)(2)(i) and (ii) of this section, where the donor or decedent’s executor is given the option to use the appropriate actuarial tables under either paragraph (e)(6) of this section or §1.642(c)–6A(e)(5), the donor or decedent’s executor must use the same actuarial table with respect to each individual transaction and with respect to all transfers occurring on the valuation date (e.g., gift and income tax charitable deductions with respect to the same transfer must be determined based on the same tables, and all assets includible in the gross estate and/or estate tax deductions claimed must be valued based on the same tables).

(3) Present value of a remainder inter- est. The present value of a remainder interest in property transferred to a pooled income fund is computed on the basis of—

(i) Life contingencies determined from the values of lx that are set forth in Table 90CM in §20.2031–7T(d)(7) of this chapter (Estate Tax Regulations) (See § 20.2031–7A of this chapter for certain prior periods); and

taining an excessive charitable deduction, that rate of return may not be used. In that case, the highest yearly rate of return of the fund is determined by treating the fund as a pooled income fund that has been in existence for less than 3 preceding taxable years.

(4) Pooled income funds in existence less than 3 taxable years. If a pooled income fund has been in existence less than 3 taxable years immediately preceding the taxable year in which the transfer is made to the fund and the transfer to the fund is made after April 30, 1989, the highest rate of return is deemed to be the interest rate (rounded to the nearest two-tenths of one percent) that is 1 percent less than the highest annual average of the monthly section 7520 rates for the 3 calendar years immediately preceding the calendar year in which the transfer to the pooled income fund is made. The deemed rate of return for transfers to new pooled income funds is recomputed each calendar year using the monthly section 7520 rates for the 3year period immediately preceding the calendar year in which each transfer to the fund is made until the fund has been in existence for 3 taxable years and can compute its highest rate of return for the 3 taxable years immediately preceding the taxable year in which the transfer of property to the fund is made in accordance with the rules set forth in the first sentence of paragraph (e)(3)(ii) of this section.

(5) Computation of value of remainder interest. The factor that is used in determining the present value of a remainder interest that is dependent on the termination of the life of one individual is the factor from Table S in paragraph (e)(6) of this section under the appropriate yearly rate of return opposite the number that corresponds to the age of the individual upon whose life the value of the remainder interest is based (See §1.642(c)–6A for certain prior periods). The tables in paragraph (e)(6) of this section include factors for yearly rates of return from 4.2 to 14 percent. Many actuarial factors not contained in the tables in paragraph (e)(6) of this section is contained in Table S in Internal Revenue Service Publication 1457, “Actuarial Values, Book Aleph,” (1999). A copy of this publication is available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington,

(ii) Discount at a rate of interest, compounded annually, equal to the highest yearly rate of return of the pooled income fund for the 3 taxable years immediately preceding its taxable year in which the transfer of property to the fund is made. For purposes of this paragraph (e), the yearly rate of return of a pooled income fund is determined as provided in §1.642(c)–6(c) unless the highest rate of return is deemed to be the rate described in paragraph (e)(4) of this section for funds in existence less than 3 taxable years. For purposes of this paragraph (e)(3)(ii), the first taxable year of a pooled income fund is considered a taxable year even though the taxable year consists of less than 12 months. However, appropriate adjustments must be made to annualize the rate of return earned by the fund for that period. Where it appears from the facts and circumstances that the highest yearly rate of return of the fund for the 3 taxable years immediately preceding the taxable year in which the transfer of property is made has been purposely manipulated to be substantially less than the rate of return that would otherwise be reasonably anticipated with the purpose of ob

1999–20 I.R.B. 9 May 17, 1999

DC 20402. For other situations, see §1.642(c)-6(b). If the yearly rate of return is a percentage that is between the yearly rates of return for which factors are provided, a linear interpolation must be made. The present value of the remainder interest is determined by multiplying the fair market value of the property on the valuation date by the appropriate remainder factor. This paragraph (e)(5) may be illustrated by the following example:

Example. A, who is 54 years and 8 months, transfers $100,000 to a pooled income fund, and re

tains a life income interest in the property. The highest yearly rate of return earned by the fund for its 3 preceding taxable years is 9.47 percent. In Table S, the remainder factor opposite 55 years under 9.4 percent is .17449 and under 9.6 percent is .17001. The present value of the remainder interest is $17,292.00, computed as follows:

Factor at 9.4 percent for age 55 . . . . . . . .17449 Factor at 9.6 percent for age 55 . . . . . . . .17001 Difference . . . . . . . . . . . . . . . . . . . . . . . .00448

Interpolation adjustment:

9.47% – 9.4% x

0.2% .00448 x = .00157

Factor at 9.4 percent for age 55 . . . . . . . .17449 Less: Interpolation adjustment . . . . . . . .00157 Interpolated factor . . . . . . . . . . . . . . . . . .17292

Present value of remainder interest: ($100,000 3 .17292) . . . . . . . . . . . . $17,292.00

(6) Actuarial tables. In the case of transfers for which the valuation date is after April 30, 1999, the present value of a remainder interest dependent on the termination of one life in the case of a transfer to a pooled income fund is determined by use of the following Table S:

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

0 .06752 .06130 .05586 .05109 .04691 .04322 .03998 .03711 .03458 .03233 1 .06137 .05495 .04932 .04438 .04003 .03620 .03283 .02985 .02721 .02487 2 .06325 .05667 .05088 .04580 .04132 .03737 .03388 .03079 .02806 .02563 3 .06545 .05869 .05275 .04752 .04291 .03883 .03523 .03203 .02920 .02668 4 .06784 .06092 .05482 .04944 .04469 .04048 .03676 .03346 .03052 .02791

5 .07040 .06331 .05705 .05152 .04662 .04229 .03845 .03503 .03199 .02928 6 .07310 .06583 .05941 .05372 .04869 .04422 .04025 .03672 .03357 .03076 7 .07594 .06849 .06191 .05607 .05089 .04628 .04219 .03854 .03528 .03236 8 .07891 .07129 .06453 .05853 .05321 .04846 .04424 .04046 .03709 .03407 9 .08203 .07423 .06731 .06115 .05567 .05079 .04643 .04253 .03904 .03592

10 .08532 .07734 .07024 .06392 .05829 .05326 .04877 .04474 .04114 .03790 11 .08875 .08059 .07331 .06683 .06104 .05587 .05124 .04709 .04336 .04002 12 .09233 .08398 .07653 .06989 .06394 .05862 .05385 .04957 .04572 .04226 13 .09601 .08748 .07985 .07304 .06693 .06146 .05655 .05214 .04816 .04458 14 .09974 .09102 .08322 .07624 .06997 .06435 .05929 .05474 .05064 .04694

15 .10350 .09460 .08661 .07946 .07303 .06725 .06204 .05735 .05312 .04930 16 .10728 .09818 .09001 .08268 .07608 .07014 .06479 .05996 .05559 .05164 17 .11108 .10179 .09344 .08592 .07916 .07306 .06755 .06257 .05807 .05399 18 .11494 .10545 .09691 .08921 .08227 .07601 .07034 .06521 .06057 .05636 19 .11889 .10921 .10047 .09259 .08548 .07904 .07322 .06794 .06315 .05880

20 .12298 .11310 .10417 .09610 .08881 .08220 .07622 .07078 .06584 .06135 21 .12722 .11713 .10801 .09976 .09228 .08550 .07935 .07375 .06866 .06403 22 .13159 .12130 .11199 .10354 .09588 .08893 .08260 .07685 .07160 .06682 23 .13613 .12563 .11612 .10748 .09964 .09250 .08601 .08009 .07468 .06975 24 .14084 .13014 .12043 .11160 .10357 .09625 .08958 .08349 .07793 .07284

25 .14574 .13484 .12493 .11591 .10768 .10018 .09334 .08708 .08135 .07611 26 .15084 .13974 .12963 .12041 .11199 .10431 .09728 .09085 .08496 .07956 27 .15615 .14485 .13454 .12513 .11652 .10865 .10144 .09484 .08878 .08322 28 .16166 .15016 .13965 .13004 .12124 .11319 .10580 .09901 .09279 .08706 29 .16737 .15567 .14497 .13516 .12617 .11792 .11035 .10339 .09699 .09109

May 17, 1999 10 1999–20 I.R.B.

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

30 .17328 .16138 .15048 .14047 .13129 .12286 .11510 .10796 .10138 .09532 31 .17938 .16728 .15618 .14599 .13661 .12799 .12004 .11272 .10597 .09974 32 .18568 .17339 .16210 .15171 .14214 .13333 .12520 .11769 .11076 .10435 33 .19220 .17972 .16824 .15766 .14790 .13889 .13058 .12289 .11578 .10920 34 .19894 .18627 .17460 .16383 .15388 .14468 .13618 .12831 .12102 .11426

35 .20592 .19307 .18121 .17025 .16011 .15073 .14204 .13399 .12652 .11958 36 .21312 .20010 .18805 .17691 .16658 .15701 .14814 .13990 .13225 .12514 37 .22057 .20737 .19514 .18382 .17331 .16356 .15450 .14608 .13825 .13096 38 .22827 .21490 .20251 .19100 .18031 .17038 .16113 .15253 .14452 .13705 39 .23623 .22270 .21013 .19845 .18759 .17747 .16805 .15927 .15108 .14344

40 .24446 .23078 .21805 .20620 .19516 .18487 .17527 .16631 .15795 .15013 41 .25298 .23915 .22626 .21425 .20305 .19259 .18282 .17368 .16514 .15715 42 .26178 .24782 .23478 .22262 .21125 .20062 .19069 .18138 .17267 .16450 43 .27087 .25678 .24360 .23129 .21977 .20898 .19888 .18941 .18053 .17220 44 .28025 .26603 .25273 .24027 .22860 .21766 .20740 .19777 .18873 .18023

45 .28987 .27555 .26212 .24953 .23772 .22664 .21622 .20644 .19724 .18858 46 .29976 .28533 .27179 .25908 .24714 .23591 .22536 .21542 .20606 .19725 47 .30987 .29535 .28171 .26889 .25682 .24546 .23476 .22468 .21518 .20621 48 .32023 .30563 .29190 .27897 .26678 .25530 .24447 .23425 .22460 .21549 49 .33082 .31615 .30234 .28931 .27702 .26543 .25447 .24412 .23434 .22509

50 .34166 .32694 .31306 .29995 .28756 .27586 .26479 .25432 .24441 .23502 51 .35274 .33798 .32404 .31085 .29838 .28658 .27541 .26482 .25479 .24528 52 .36402 .34924 .33525 .32200 .30946 .29757 .28630 .27561 .26547 .25584 53 .37550 .36070 .34668 .33339 .32078 .30882 .29746 .28667 .27643 .26669 54 .38717 .37237 .35833 .34500 .33234 .32031 .30888 .29801 .28766 .27782

55 .39903 .38424 .37019 .35683 .34413 .33205 .32056 .30961 .29918 .28925 56 .41108 .39631 .38227 .36890 .35617 .34405 .33250 .32149 .31099 .30097 57 .42330 .40857 .39455 .38118 .36844 .35629 .34469 .33363 .32306 .31297 58 .43566 .42098 .40699 .39364 .38089 .36873 .35710 .34600 .33538 .32522 59 .44811 .43351 .41956 .40623 .39350 .38133 .36968 .35855 .34789 .33768

60 .46066 .44613 .43224 .41896 .40624 .39408 .38243 .37127 .36058 .35033 61 .47330 .45887 .44505 .43182 .41914 .40699 .39535 .38418 .37347 .36318 62 .48608 .47175 .45802 .44485 .43223 .42011 .40848 .39732 .38660 .37629 63 .49898 .48478 .47115 .45807 .44550 .43343 .42184 .41069 .39997 .38966 64 .51200 .49793 .48442 .47143 .45895 .44694 .43539 .42427 .41357 .40326

65 .52512 .51121 .49782 .48495 .47255 .46062 .44912 .43805 .42738 .41709 66 .53835 .52461 .51137 .49862 .48634 .47449 .46307 .45206 .44143 .43118 67 .55174 .53818 .52511 .51250 .50034 .48860 .47727 .46633 .45576 .44556 68 .56524 .55188 .53899 .52654 .51452 .50291 .49168 .48083 .47034 .46020 69 .57882 .56568 .55299 .54071 .52885 .51737 .50627 .49552 .48513 .47506 70 .59242 .57951 .56703 .55495 .54325 .53193 .52096 .51034 .50004 .49007

1999–20 I.R.B. 11 May 17, 1999

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

71 .60598 .59332 .58106 .56918 .55767 .54651 .53569 .52520 .51503 .50516 72 .61948 .60707 .59504 .58338 .57206 .56108 .55043 .54009 .53004 .52029 73 .63287 .62073 .60895 .59751 .58640 .57561 .56513 .55495 .54505 .53543 74 .64621 .63435 .62282 .61162 .60073 .59015 .57985 .56984 .56009 .55061

75 .65953 .64796 .63671 .62575 .61510 .60473 .59463 .58480 .57523 .56591 76 .67287 .66160 .65063 .63995 .62954 .61940 .60952 .59989 .59050 .58135 77 .68622 .67526 .66459 .65419 .64404 .63415 .62450 .61509 .60590 .59694 78 .69954 .68892 .67856 .66845 .65858 .64895 .63955 .63036 .62140 .61264 79 .71278 .70250 .69246 .68265 .67308 .66372 .65457 .64563 .63690 .62836

80 .72581 .71588 .70618 .69668 .68740 .67833 .66945 .66077 .65227 .64396 81 .73857 .72899 .71962 .71045 .70147 .69268 .68408 .67566 .66741 .65933 82 .75101 .74178 .73274 .72389 .71522 .70672 .69840 .69024 .68225 .67441 83 .76311 .75423 .74553 .73700 .72864 .72044 .71240 .70451 .69678 .68919 84 .77497 .76645 .75809 .74988 .74183 .73393 .72618 .71857 .71110 .70377

85 .78665 .77848 .77047 .76260 .75487 .74728 .73982 .73250 .72530 .71823 86 .79805 .79025 .78258 .77504 .76764 .76036 .75320 .74617 .73925 .73245 87 .80904 .80159 .79427 .78706 .77998 .77301 .76615 .75940 .75277 .74624 88 .81962 .81251 .80552 .79865 .79188 .78521 .77865 .77220 .76584 .75958 89 .82978 .82302 .81636 .80980 .80335 .79699 .79072 .78455 .77847 .77248

90 .83952 .83309 .82676 .82052 .81437 .80831 .80234 .79645 .79064 .78492 91 .84870 .84260 .83658 .83064 .82479 .81902 .81332 .80771 .80217 .79671 92 .85716 .85136 .84563 .83998 .83441 .82891 .82348 .81812 .81283 .80761 93 .86494 .85942 .85396 .84858 .84326 .83801 .83283 .82771 .82266 .81767 94 .87216 .86690 .86170 .85657 .85149 .84648 .84153 .83664 .83181 .82704

95 .87898 .87397 .86902 .86412 .85928 .85450 .84977 .84510 .84049 .83592 96 .88537 .88060 .87587 .87121 .86659 .86203 .85751 .85305 .84864 .84427 97 .89127 .88672 .88221 .87775 .87335 .86898 .86467 .86040 .85618 .85200 98 .89680 .89245 .88815 .88389 .87968 .87551 .87138 .86730 .86326 .85926 99 .90217 .89803 .89393 .88987 .88585 .88187 .87793 .87402 .87016 .86633

100 .90738 .90344 .89953 .89567 .89183 .88804 .88428 .88056 .87687 .87322 101 .91250 .90876 .90504 .90137 .89772 .89412 .89054 .88699 .88348 .88000 102 .91751 .91396 .91045 .90696 .90350 .90007 .89668 .89331 .88997 .88666 103 .92247 .91912 .91579 .91249 .90922 .90598 .90276 .89957 .89640 .89326 104 .92775 .92460 .92148 .91839 .91532 .91227 .90924 .90624 .90326 .90031

105 .93290 .92996 .92704 .92415 .92127 .91841 .91558 .91276 .90997 .90719 106 .93948 .93680 .93415 .93151 .92889 .92628 .92370 .92113 .91857 .91604 107 .94739 .94504 .94271 .94039 .93808 .93579 .93351 .93124 .92899 .92675 108 .95950 .95767 .95585 .95404 .95224 .95045 .94867 .94689 .94512 .94336 109 .97985 .97893 .97801 .97710 .97619 .97529 .97438 .97348 .97259 .97170

May 17, 1999 12 1999–20 I.R.B.

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0%

0 .03034 .02857 .02700 .02559 .02433 .02321 .02220 .02129 .02047 .01973 1 .02279 .02094 .01929 .01782 .01650 .01533 .01427 .01331 .01246 .01168 2 .02347 .02155 .01983 .01829 .01692 .01569 .01458 .01358 .01268 .01187 3 .02444 .02243 .02065 .01905 .01761 .01632 .01516 .01412 .01317 .01232 4 .02558 .02349 .02163 .01996 .01846 .01712 .01590 .01481 .01382 .01292

5 .02686 .02469 .02275 .02101 .01945 .01804 .01677 .01562 .01458 .01364 6 .02825 .02600 .02398 .02217 .02053 .01906 .01773 .01653 .01544 .01445 7 .02976 .02742 .02532 .02343 .02172 .02019 .01880 .01754 .01640 .01536 8 .03137 .02894 .02675 .02479 .02301 .02140 .01995 .01864 .01744 .01635 9 .03311 .03059 .02832 .02627 .02442 .02274 .02122 .01985 .01859 .01745

10 .03499 .03237 .03001 .02788 .02595 .02420 .02262 .02118 .01987 .01867 11 .03700 .03428 .03183 .02961 .02760 .02578 .02413 .02262 .02125 .02000 12 .03913 .03632 .03377 .03146 .02937 .02748 .02575 .02418 .02275 .02144 13 .04135 .03843 .03579 .03339 .03122 .02924 .02744 .02580 .02431 .02294 14 .04359 .04057 .03783 .03534 .03308 .03102 .02915 .02744 .02587 .02444

15 .04584 .04270 .03986 .03728 .03493 .03279 .03083 .02905 .02742 .02593 16 .04806 .04482 .04187 .03919 .03674 .03452 .03248 .03063 .02892 .02736 17 .05029 .04692 .04387 .04108 .03855 .03623 .03411 .03218 .03040 .02877 18 .05253 .04905 .04588 .04299 .04036 .03795 .03574 .03373 .03187 .03017 19 .05484 .05124 .04796 .04496 .04222 .03972 .03742 .03532 .03339 .03161

20 .05726 .05354 .05013 .04702 .04418 .04158 .03919 .03700 .03498 .03313 21 .05980 .05595 .05242 .04920 .04625 .04354 .04105 .03877 .03667 .03473 22 .06246 .05847 .05482 .05147 .04841 .04559 .04301 .04063 .03844 .03642 23 .06524 .06112 .05734 .05387 .05069 .04777 .04508 .04260 .04032 .03821 24 .06819 .06392 .06001 .05642 .05312 .05008 .04728 .04470 .04232 .04012

25 .07131 .06690 .06285 .05913 .05570 .05255 .04964 .04695 .04447 .04218 26 .07460 .07005 .06586 .06200 .05845 .05518 .05215 .04936 .04677 .04438 27 .07810 .07340 .06907 .06508 .06140 .05800 .05485 .05195 .04925 .04676 28 .08179 .07693 .07246 .06833 .06451 .06098 .05772 .05469 .05189 .04929 29 .08566 .08065 .07603 .07176 .06780 .06414 .06075 .05761 .05469 .05198

30 .08973 .08456 .07978 .07536 .07127 .06748 .06396 .06069 .05766 .05483 31 .09398 .08865 .08372 .07915 .07491 .07098 .06733 .06394 .06078 .05785 32 .09843 .09294 .08785 .08313 .07875 .07468 .07089 .06737 .06409 .06103 33 .10310 .09745 .09220 .08732 .08279 .07858 .07466 .07100 .06759 .06441 34 .10799 .10217 .09676 .09173 .08705 .08269 .07862 .07483 .07129 .06798

35 .11314 .10715 .10157 .09638 .09155 .08704 .08283 .07890 .07522 .07179 36 .11852 .11236 .10662 .10127 .09628 .09162 .08726 .08319 .07938 .07581 37 .12416 .11783 .11193 .10641 .10126 .09645 .09194 .08772 .08377 .08006 38 .13009 .12359 .11751 .11183 .10652 .10155 .09689 .09253 .08843 .08459 39 .13629 .12962 .12338 .11753 .11206 .10693 .10212 .09761 .09337 .08938

1999–20 I.R.B. 13 May 17, 1999

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0%

40 .14281 .13597 .12955 .12355 .11791 .11262 .10766 .10299 .09860 .09447 41 .14966 .14264 .13606 .12989 .12409 .11864 .11352 .10870 .10417 .09989 42 .15685 .14966 .14291 .13657 .13061 .12500 .11972 .11475 .11006 .10564 43 .16437 .15702 .15010 .14360 .13747 .13171 .12627 .12115 .11631 .11174 44 .17224 .16472 .15764 .15098 .14469 .13876 .13317 .12789 .12290 .11819

45 .18042 .17274 .16550 .15867 .15223 .14615 .14040 .13496 .12982 .12496 46 .18893 .18110 .17370 .16671 .16011 .15387 .14796 .14238 .13708 .13207 47 .19775 .18975 .18220 .17505 .16830 .16190 .15584 .15010 .14466 .13950 48 .20688 .19873 .19102 .18373 .17682 .17027 .16406 .15817 .15258 .14727 49 .21633 .20804 .20018 .19274 .18568 .17898 .17262 .16658 .16084 .15539

50 .22612 .21769 .20969 .20210 .19490 .18805 .18155 .17536 .16948 .16388 51 .23625 .22769 .21955 .21182 .20448 .19749 .19084 .18452 .17849 .17275 52 .24669 .23799 .22973 .22186 .21438 .20726 .20047 .19400 .18784 .18196 53 .25742 .24861 .24022 .23222 .22461 .21735 .21043 .20383 .19753 .19151 54 .26845 .25952 .25101 .24290 .23516 .22777 .22072 .21399 .20756 .20140

55 .27978 .27074 .26212 .25389 .24604 .23853 .23136 .22450 .21793 .21166 56 .29140 .28227 .27355 .26522 .25725 .24963 .24233 .23535 .22867 .22227 57 .30333 .29411 .28529 .27686 .26879 .26106 .25365 .24656 .23976 .23324 58 .31551 .30621 .29731 .28878 .28061 .27278 .26528 .25807 .25116 .24453 59 .32790 .31854 .30956 .30095 .29269 .28477 .27716 .26986 .26284 .25610

60 .34050 .33107 .32202 .31334 .30500 .29699 .28929 .28190 .27478 .26794 61 .35331 .34384 .33473 .32598 .31757 .30948 .30170 .29422 .28701 .28007 62 .36639 .35688 .34772 .33892 .33044 .32229 .31443 .30687 .29958 .29255 63 .37974 .37020 .36101 .35216 .34363 .33542 .32750 .31986 .31250 .30539 64 .39334 .38378 .37456 .36568 .35711 .34884 .34087 .33317 .32574 .31857

65 .40718 .39761 .38838 .37947 .37087 .36257 .35455 .34681 .33932 .33208 66 .42128 .41172 .40249 .39357 .38496 .37663 .36858 .36079 .35326 .34597 67 .43569 .42616 .41694 .40803 .39941 .39107 .38299 .37518 .36761 .36028 68 .45038 .44089 .43170 .42281 .41419 .40585 .39777 .38994 .38235 .37499 69 .46531 .45587 .44672 .43786 .42927 .42094 .41286 .40503 .39743 .39006 70 .48040 .47103 .46194 .45312 .44456 .43626 .42820 .42038 .41278 .40540

71 .49558 .48629 .47727 .46851 .46000 .45174 .44371 .43591 .42832 .42095 72 .51082 .50162 .49268 .48399 .47554 .46733 .45934 .45157 .44401 .43666 73 .52607 .51697 .50813 .49952 .49114 .48299 .47506 .46733 .45981 .45249 74 .54139 .53241 .52367 .51515 .50686 .49879 .49092 .48325 .47578 .46849

75 .55683 .54798 .53936 .53095 .52276 .51477 .50698 .49938 .49197 .48474 76 .57243 .56373 .55524 .54696 .53888 .53100 .52330 .51579 .50846 .50130 77 .58819 .57965 .57132 .56318 .55523 .54747 .53988 .53247 .52523 .51815 78 .60408 .59572 .58755 .57957 .57177 .56414 .55668 .54939 .54225 .53527 79 .62001 .61184 .60385 .59604 .58840 .58092 .57360 .56644 .55943 .55256

May 17, 1999 14 1999–20 I.R.B.

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0%

80 .63582 .62786 .62007 .61244 .60497 .59765 .59048 .58347 .57659 .56985 81 .65142 .64367 .63608 .62864 .62135 .61421 .60721 .60034 .59361 .58701 82 .66673 .65920 .65182 .64458 .63748 .63052 .62368 .61698 .61041 .60395 83 .68175 .67444 .66728 .66024 .65334 .64656 .63991 .63338 .62696 .62066 84 .69657 .68950 .68256 .67574 .66904 .66246 .65599 .64964 .64340 .63727

85 .71128 .70446 .69775 .69116 .68467 .67830 .67204 .66587 .65982 .65386 86 .72576 .71919 .71272 .70636 .70010 .69394 .68789 .68193 .67606 .67029 87 .73981 .73349 .72726 .72114 .71511 .70917 .70333 .69757 .69190 .68632 88 .75342 .74735 .74137 .73548 .72968 .72396 .71833 .71279 .70732 .70194 89 .76658 .76076 .75503 .74938 .74381 .73832 .73290 .72757 .72231 .71712

90 .77928 .77371 .76823 .76281 .75748 .75221 .74702 .74190 .73684 .73186 91 .79131 .78600 .78075 .77557 .77046 .76542 .76044 .75553 .75068 .74589 92 .80246 .79737 .79235 .78740 .78250 .77767 .77290 .76818 .76353 .75893 93 .81274 .80788 .80307 .79832 .79363 .78899 .78441 .77989 .77542 .77100 94 .82232 .81766 .81306 .80850 .80401 .79956 .79517 .79082 .78653 .78228

95 .83141 .82695 .82254 .81818 .81387 .80961 .80539 .80122 .79710 .79302 96 .83996 .83569 .83147 .82729 .82316 .81907 .81503 .81103 .80707 .80315 97 .84787 .84378 .83973 .83573 .83176 .82784 .82396 .82012 .81632 .81255 98 .85530 .85138 .84750 .84366 .83985 .83609 .83236 .82867 .82502 .82140 99 .86255 .85880 .85508 .85140 .84776 .84415 .84057 .83703 .83353 .83005

100 .86960 .86601 .86246 .85894 .85546 .85200 .84858 .84519 .84183 .83849 101 .87655 .87313 .86974 .86638 .86305 .85975 .85648 .85324 .85003 .84684 102 .88338 .88012 .87689 .87369 .87052 .86738 .86426 .86116 .85809 .85505 103 .89015 .88706 .88399 .88095 .87793 .87494 .87197 .86903 .86611 .86321 104 .89737 .89446 .89157 .88871 .88586 .88304 .88024 .87745 .87469 .87195

105 .90443 .90170 .89898 .89628 .89360 .89094 .88830 .88568 .88307 .88049 106 .91351 .91101 .90852 .90605 .90359 .90115 .89873 .89632 .89392 .89154 107 .92452 .92230 .92010 .91791 .91573 .91356 .91141 .90927 .90714 .90502 108 .94161 .93987 .93814 .93641 .93469 .93298 .93128 .92958 .92790 .92622 109 .97081 .96992 .96904 .96816 .96729 .96642 .96555 .96468 .96382 .96296

1999–20 I.R.B. 15 May 17, 1999

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0%

0 .01906 .01845 .01790 .01740 .01694 .01652 .01613 .01578 .01546 .01516 1 .01098 .01034 .00977 .00924 .00876 .00833 .00793 .00756 .00722 .00691 2 .01113 .01046 .00986 .00930 .00880 .00834 .00791 .00753 .00717 .00684 3 .01155 .01084 .01020 .00962 .00909 .00860 .00816 .00775 .00737 .00702 4 .01211 .01137 .01069 .01008 .00952 .00900 .00853 .00810 .00770 .00733

5 .01279 .01201 .01130 .01065 .01006 .00952 .00902 .00856 .00814 .00775 6 .01356 .01274 .01199 .01131 .01068 .01011 .00959 .00910 .00865 .00824 7 .01442 .01356 .01277 .01205 .01140 .01079 .01023 .00972 .00925 .00881 8 .01536 .01446 .01363 .01287 .01218 .01154 .01096 .01041 .00991 .00945 9 .01641 .01546 .01460 .01380 .01307 .01240 .01178 .01120 .01068 .01019

10 .01758 .01659 .01567 .01484 .01407 .01336 .01270 .01210 .01154 .01103 11 .01886 .01781 .01686 .01598 .01517 .01442 .01373 .01310 .01251 .01196 12 .02024 .01915 .01814 .01721 .01636 .01558 .01485 .01419 .01357 .01299 13 .02168 .02054 .01948 .01851 .01762 .01679 .01603 .01533 .01467 .01407 14 .02313 .02193 .02083 .01981 .01887 .01801 .01721 .01646 .01578 .01514

15 .02456 .02330 .02214 .02107 .02009 .01918 .01834 .01756 .01684 .01617 16 .02593 .02462 .02340 .02229 .02126 .02030 .01942 .01860 .01785 .01714 17 .02728 .02590 .02463 .02346 .02238 .02138 .02046 .01960 .01880 .01806 18 .02861 .02717 .02584 .02462 .02348 .02243 .02146 .02056 .01972 .01894 19 .02998 .02847 .02708 .02580 .02461 .02351 .02249 .02154 .02066 .01984

20 .03142 .02984 .02839 .02704 .02580 .02465 .02357 .02258 .02165 .02079 21 .03295 .03130 .02978 .02837 .02706 .02585 .02473 .02368 .02271 .02180 22 .03455 .03283 .03124 .02976 .02839 .02712 .02594 .02484 .02382 .02286 23 .03626 .03446 .03279 .03124 .02981 .02847 .02723 .02608 .02500 .02400 24 .03809 .03620 .03446 .03283 .03133 .02993 .02863 .02741 .02628 .02522

25 .04005 .03808 .03625 .03456 .03298 .03151 .03014 .02887 .02768 .02656 26 .04216 .04010 .03819 .03641 .03476 .03322 .03178 .03044 .02919 .02802 27 .04444 .04229 .04029 .03843 .03670 .03508 .03357 .03217 .03085 .02962 28 .04687 .04463 .04254 .04059 .03877 .03708 .03550 .03402 .03263 .03133 29 .04946 .04712 .04493 .04289 .04099 .03922 .03756 .03600 .03455 .03318

30 .05221 .04976 .04748 .04534 .04335 .04149 .03975 .03812 .03659 .03515 31 .05511 .05255 .05017 .04794 .04585 .04390 .04208 .04037 .03876 .03725 32 .05818 .05551 .05302 .05069 .04851 .04647 .04455 .04276 .04107 .03948 33 .06144 .05866 .05606 .05363 .05135 .04921 .04720 .04532 .04355 .04188 34 .06489 .06200 .05928 .05674 .05436 .05212 .05002 .04805 .04619 .04444

35 .06857 .06555 .06273 .06007 .05758 .05524 .05304 .05097 .04902 .04718 36 .07246 .06932 .06638 .06361 .06101 .05856 .05626 .05409 .05205 .05012 37 .07659 .07332 .07025 .06737 .06466 .06210 .05969 .05742 .05528 .05325 38 .08098 .07758 .07439 .07138 .06855 .06588 .06336 .06099 .05874 .05662 39 .08563 .08210 .07878 .07565 .07270 .06992 .06729 .06480 .06245 .06023

May 17, 1999 16 1999–20 I.R.B.

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0%

40 .09059 .08692 .08347 .08021 .07714 .07423 .07149 .06889 .06643 .06411 41 .09586 .09206 .08848 .08509 .08189 .07886 .07600 .07329 .07072 .06828 42 .10147 .09753 .09381 .09029 .08696 .08381 .08083 .07800 .07531 .07277 43 .10742 .10334 .09948 .09583 .09237 .08909 .08598 .08304 .08024 .07758 44 .11373 .10950 .10551 .10172 .09813 .09472 .09148 .08841 .08549 .08272

45 .12035 .11599 .11185 .10792 .10420 .10066 .09730 .09410 .09106 .08817 46 .12732 .12281 .11853 .11447 .11061 .10694 .10345 .10013 .09696 .09395 47 .13460 .12995 .12553 .12133 .11733 .11353 .10991 .10646 .10317 .10004 48 .14223 .13743 .13287 .12853 .12439 .12046 .11671 .11313 .10972 .10646 49 .15020 .14526 .14056 .13608 .13181 .12774 .12385 .12015 .11661 .11322

50 .15855 .15347 .14862 .14401 .13960 .13540 .13138 .12754 .12388 .12037 51 .16727 .16205 .15707 .15232 .14777 .14344 .13929 .13532 .13153 .12789 52 .17634 .17098 .16587 .16097 .15630 .15183 .14755 .14345 .13953 .13577 53 .18576 .18027 .17501 .16999 .16518 .16057 .15616 .15194 .14789 .14400 54 .19552 .18990 .18451 .17935 .17441 .16968 .16514 .16078 .15661 .15260

55 .20564 .19989 .19437 .18908 .18402 .17915 .17449 .17001 .16571 .16157 56 .21613 .21025 .20461 .19919 .19400 .18901 .18422 .17962 .17519 .17093 57 .22698 .22098 .21522 .20968 .20436 .19925 .19434 .18961 .18507 .18069 58 .23816 .23204 .22616 .22051 .21507 .20984 .20481 .19996 .19530 .19080 59 .24962 .24339 .23740 .23163 .22608 .22073 .21558 .21062 .20584 .20123

60 .26136 .25502 .24892 .24304 .23738 .23192 .22666 .22158 .21669 .21196 61 .27339 .26695 .26075 .25477 .24900 .24343 .23806 .23288 .22787 .22304 62 .28578 .27925 .27295 .26687 .26100 .25533 .24985 .24456 .23945 .23451 63 .29854 .29192 .28553 .27935 .27339 .26762 .26205 .25666 .25145 .24641 64 .31164 .30494 .29846 .29221 .28615 .28030 .27463 .26915 .26384 .25870

65 .32508 .31831 .31177 .30543 .29930 .29336 .28761 .28203 .27663 .27140 66 .33891 .33208 .32547 .31906 .31285 .30684 .30101 .29536 .28987 .28456 67 .35318 .34630 .33963 .33316 .32689 .32081 .31491 .30918 .30363 .29823 68 .36785 .36093 .35422 .34770 .34138 .33524 .32928 .32349 .31787 .31240 69 .38290 .37595 .36920 .36265 .35628 .35009 .34408 .33824 .33256 .32703 70 .39823 .39127 .38450 .37791 .37151 .36529 .35924 .35335 .34762 .34204

71 .41378 .40681 .40003 .39343 .38701 .38076 .37467 .36875 .36298 .35736 72 .42950 .42253 .41575 .40914 .40271 .39644 .39034 .38438 .37858 .37293 73 .44535 .43840 .43162 .42502 .41858 .41231 .40619 .40022 .39440 .38872 74 .46139 .45446 .44771 .44112 .43469 .42842 .42230 .41632 .41049 .40479

75 .47769 .47080 .46408 .45752 .45111 .44485 .43874 .43277 .42693 .42123 76 .49430 .48747 .48079 .47427 .46790 .46167 .45558 .44963 .44380 .43811 77 .51123 .50447 .49786 .49139 .48506 .47888 .47282 .46690 .46111 .45543 78 .52845 .52177 .51523 .50884 .50257 .49645 .49044 .48457 .47881 .47317 79 .54584 .53926 .53282 .52650 .52032 .51426 .50833 .50251 .49681 .49122

1999–20 I.R.B. 17 May 17, 1999

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0%

80 .56325 .55678 .55044 .54423 .53813 .53216 .52630 .52056 .51492 .50939 81 .58054 .57419 .56797 .56186 .55587 .54999 .54422 .53856 .53300 .52754 82 .59762 .59140 .58530 .57931 .57343 .56766 .56198 .55641 .55094 .54557 83 .61448 .60840 .60243 .59657 .59081 .58515 .57958 .57411 .56874 .56346 84 .63124 .62531 .61949 .61376 .60813 .60259 .59715 .59179 .58652 .58134

85 .64800 .64224 .63657 .63099 .62550 .62010 .61478 .60955 .60441 .59934 86 .66461 .65902 .65351 .64810 .64276 .63751 .63233 .62724 .62222 .61728 87 .68083 .67541 .67008 .66483 .65965 .65455 .64953 .64458 .63970 .63489 88 .69663 .69140 .68624 .68116 .67615 .67121 .66634 .66154 .65680 .65213 89 .71201 .70696 .70199 .69708 .69224 .68747 .68276 .67811 .67353 .66900

90 .72694 .72209 .71730 .71257 .70791 .70330 .69876 .69427 .68984 .68547 91 .74117 .73650 .73190 .72735 .72286 .71842 .71404 .70972 .70545 .70123 92 .75439 .74991 .74548 .74110 .73678 .73251 .72829 .72412 .72000 .71593 93 .76664 .76233 .75806 .75385 .74969 .74557 .74150 .73748 .73350 .72957 94 .77809 .77394 .76983 .76578 .76177 .75780 .75388 .75000 .74616 .74237

95 .78899 .78500 .78106 .77715 .77329 .76947 .76569 .76195 .75826 .75460 96 .79928 .79544 .79165 .78790 .78418 .78050 .77686 .77326 .76970 .76617 97 .80883 .80514 .80149 .79787 .79430 .79075 .78725 .78377 .78033 .77693 98 .81781 .81427 .81075 .80727 .80382 .80041 .79703 .79368 .79036 .78708 99 .82661 .82320 .81982 .81648 .81316 .80988 .80662 .80340 .80020 .79704

100 .83519 .83192 .82868 .82547 .82228 .81913 .81600 .81290 .80982 .80678 101 .84368 .84055 .83744 .83437 .83131 .82829 .82529 .82231 .81936 .81643 102 .85203 .84904 .84607 .84313 .84021 .83731 .83444 .83159 .82876 .82596 103 .86034 .85748 .85465 .85184 .84906 .84629 .84355 .84082 .83812 .83544 104 .86923 .86653 .86385 .86119 .85855 .85593 .85333 .85074 .84818 .84563

105 .87792 .87537 .87283 .87032 .86782 .86534 .86287 .86042 .85799 .85557 106 .88918 .88683 .88450 .88218 .87987 .87758 .87530 .87304 .87079 .86855 107 .90291 .90082 .89873 .89666 .89460 .89255 .89051 .88849 .88647 .88447 108 .92455 .92288 .92123 .91958 .91794 .91630 .91468 .91306 .91145 .90984 109 .96211 .96125 .96041 .95956 .95872 .95788 .95704 .95620 .95537 .95455

May 17, 1999 18 1999–20 I.R.B.

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0%

0 .01488 .01463 .01439 .01417 .01396 .01377 .01359 .01343 .01327 .01312 1 .00662 .00636 .00612 .00589 .00568 .00548 .00530 .00513 .00497 .00482 2 .00654 .00626 .00600 .00576 .00554 .00533 .00514 .00496 .00479 .00463 3 .00670 .00641 .00613 .00588 .00564 .00542 .00522 .00502 .00484 .00468 4 .00699 .00668 .00639 .00612 .00587 .00563 .00542 .00521 .00502 .00484

5 .00739 .00706 .00675 .00646 .00620 .00595 .00571 .00550 .00529 .00510 6 .00786 .00751 .00718 .00687 .00659 .00633 .00608 .00585 .00563 .00543 7 .00841 .00803 .00769 .00736 .00706 .00678 .00652 .00627 .00604 .00582 8 .00902 .00863 .00826 .00791 .00759 .00730 .00702 .00675 .00651 .00628 9 .00973 .00931 .00892 .00856 .00822 .00790 .00760 .00733 .00706 .00682

10 .01055 .01010 .00969 .00930 .00894 .00861 .00829 .00799 .00772 .00746 11 .01146 .01099 .01055 .01014 .00976 .00940 .00907 .00875 .00846 .00818 12 .01246 .01196 .01150 .01106 .01066 .01028 .00993 .00960 .00928 .00899 13 .01351 .01298 .01249 .01204 .01161 .01121 .01084 .01049 .01016 .00985 14 .01455 .01400 .01348 .01300 .01255 .01213 .01173 .01136 .01102 .01069

15 .01555 .01497 .01443 .01392 .01345 .01300 .01259 .01220 .01183 .01148 16 .01648 .01587 .01530 .01477 .01427 .01380 .01336 .01295 .01257 .01220 17 .01737 .01673 .01612 .01556 .01504 .01455 .01408 .01365 .01324 .01286 18 .01822 .01754 .01691 .01632 .01576 .01525 .01476 .01430 .01387 .01347 19 .01908 .01837 .01770 .01708 .01650 .01595 .01544 .01495 .01450 .01407

20 .01999 .01924 .01854 .01788 .01726 .01669 .01615 .01564 .01516 .01471 21 .02096 .02017 .01943 .01874 .01809 .01748 .01691 .01637 .01586 .01539 22 .02197 .02114 .02036 .01963 .01895 .01830 .01770 .01713 .01660 .01610 23 .02306 .02218 .02136 .02059 .01987 .01919 .01855 .01795 .01739 .01686 24 .02424 .02331 .02245 .02163 .02087 .02016 .01948 .01885 .01825 .01769

25 .02552 .02455 .02364 .02278 .02197 .02122 .02051 .01984 .01920 .01861 26 .02692 .02589 .02493 .02403 .02318 .02238 .02162 .02091 .02025 .01961 27 .02846 .02738 .02636 .02541 .02451 .02367 .02287 .02212 .02141 .02074 28 .03012 .02898 .02791 .02690 .02595 .02506 .02422 .02342 .02267 .02196 29 .03190 .03070 .02957 .02851 .02751 .02656 .02567 .02483 .02404 .02329

30 .03381 .03254 .03135 .03023 .02917 .02817 .02723 .02634 .02551 .02471 31 .03583 .03450 .03324 .03206 .03094 .02989 .02890 .02796 .02707 .02623 32 .03799 .03659 .03527 .03402 .03284 .03173 .03068 .02968 .02874 .02785 33 .04031 .03883 .03744 .03612 .03488 .03371 .03260 .03155 .03055 .02961 34 .04279 .04123 .03976 .03838 .03707 .03583 .03465 .03354 .03249 .03149

35 .04545 .04382 .04227 .04081 .03943 .03812 .03688 .03571 .03459 .03354 36 .04830 .04658 .04495 .04341 .04196 .04058 .03927 .03803 .03685 .03573 37 .05134 .04953 .04782 .04620 .04467 .04321 .04183 .04052 .03928 .03809 38 .05462 .05272 .05092 .04921 .04760 .04606 .04461 .04322 .04191 .04066 39 .05812 .05613 .05424 .05245 .05075 .04913 .04760 .04614 .04475 .04343

1999–20 I.R.B. 19 May 17, 1999

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0%

40 .06190 .05981 .05782 .05594 .05415 .05245 .05083 .04929 .04783 .04643 41 .06597 .06378 .06170 .05972 .05784 .05605 .05435 .05272 .05118 .04970 42 .07035 .06806 .06587 .06380 .06182 .05994 .05815 .05644 .05481 .05326 43 .07505 .07265 .07036 .06818 .06611 .06414 .06225 .06045 .05874 .05710 44 .08008 .07757 .07518 .07290 .07072 .06865 .06667 .06478 .06298 .06125

45 .08542 .08279 .08029 .07791 .07563 .07346 .07138 .06940 .06750 .06569 46 .09108 .08834 .08573 .08324 .08085 .07858 .07640 .07432 .07233 .07043 47 .09705 .09419 .09147 .08886 .08637 .08399 .08172 .07954 .07745 .07545 48 .10335 .10038 .09754 .09482 .09222 .08973 .08735 .08507 .08288 .08078 49 .10999 .10690 .10394 .10111 .09840 .09581 .09332 .09093 .08864 .08644

50 .11701 .11380 .11073 .10778 .10496 .10225 .09965 .09716 .09477 .09247 51 .12441 .12108 .11789 .11482 .11189 .10907 .10636 .10376 .10126 .09886 52 .13217 .12871 .12540 .12222 .11916 .11623 .11341 .11071 .10810 .10560 53 .14028 .13670 .13327 .12997 .12680 .12375 .12082 .11801 .11529 .11268 54 .14875 .14505 .14150 .13808 .13480 .13163 .12859 .12566 .12284 .12012

55 .15760 .15378 .15011 .14657 .14317 .13989 .13674 .13370 .13077 .12794 56 .16684 .16290 .15911 .15546 .15194 .14855 .14528 .14213 .13909 .13615 57 .17648 .17242 .16851 .16474 .16111 .15760 .15422 .15096 .14781 .14477 58 .18647 .18229 .17827 .17438 .17064 .16702 .16353 .16015 .15689 .15374 59 .19678 .19249 .18835 .18435 .18049 .17676 .17316 .16968 .16631 .16305

60 .20740 .20300 .19875 .19464 .19066 .18682 .18311 .17952 .17604 .17268 61 .21837 .21385 .20949 .20527 .20119 .19724 .19341 .18971 .18613 .18266 62 .22973 .22511 .22064 .21631 .21212 .20807 .20414 .20033 .19664 .19306 63 .24152 .23680 .23222 .22779 .22350 .21934 .21530 .21139 .20760 .20392 64 .25372 .24890 .24422 .23969 .23529 .23103 .22690 .22289 .21899 .21521

65 .26633 .26141 .25664 .25201 .24752 .24316 .23893 .23482 .23083 .22695 66 .27940 .27439 .26953 .26481 .26023 .25577 .25145 .24724 .24316 .23918 67 .29299 .28790 .28296 .27815 .27348 .26894 .26453 .26024 .25606 .25200 68 .30709 .30193 .29691 .29202 .28728 .28265 .27816 .27378 .26952 .26537 69 .32166 .31643 .31134 .30639 .30157 .29687 .29230 .28785 .28351 .27928 70 .33661 .33133 .32618 .32116 .31628 .31152 .30688 .30235 .29794 .29364

71 .35188 .34654 .34134 .33627 .33133 .32651 .32181 .31722 .31275 .30838 72 .36742 .36204 .35679 .35168 .34668 .34181 .33706 .33241 .32788 .32345 73 .38317 .37776 .37248 .36733 .36229 .35738 .35257 .34788 .34330 .33882 74 .39923 .39380 .38849 .38330 .37823 .37328 .36844 .36370 .35908 .35455

75 .41566 .41021 .40489 .39968 .39459 .38961 .38474 .37997 .37531 .37074 76 .43254 .42709 .42176 .41655 .41144 .40645 .40156 .39677 .39208 .38749 77 .44988 .44444 .43912 .43391 .42880 .42380 .41891 .41411 .40940 .40479 78 .46765 .46224 .45694 .45174 .44665 .44166 .43677 .43197 .42726 .42265 79 .48574 .48037 .47510 .46993 .46487 .45990 .45502 .45024 .44554 .44094

May 17, 1999 20 1999–20 I.R.B.

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0%

80 .50397 .49865 .49343 .48830 .48327 .47834 .47349 .46873 .46406 .45947 81 .52219 .51693 .51176 .50669 .50171 .49682 .49201 .48729 .48265 .47809 82 .54029 .53510 .53000 .52499 .52007 .51523 .51047 .50580 .50120 .49667 83 .55826 .55315 .54813 .54319 .53834 .53356 .52886 .52424 .51969 .51522 84 .57624 .57123 .56629 .56144 .55666 .55195 .54732 .54277 .53828 .53386

85 .59435 .58944 .58460 .57984 .57516 .57054 .56599 .56151 .55710 .55275 86 .61241 .60762 .60289 .59824 .59365 .58913 .58468 .58029 .57596 .57170 87 .63015 .62548 .62087 .61633 .61185 .60744 .60309 .59880 .59456 .59039 88 .64753 .64299 .63851 .63409 .62973 .62543 .62118 .61700 .61287 .60879 89 .66454 .66013 .65579 .65150 .64726 .64308 .63895 .63488 .63086 .62689

90 .68115 .67689 .67268 .66853 .66442 .66037 .65637 .65241 .64851 .64465 91 .69706 .69294 .68887 .68486 .68089 .67696 .67309 .66925 .66547 .66173 92 .71190 .70792 .70399 .70011 .69627 .69247 .68872 .68501 .68134 .67771 93 .72569 .72184 .71804 .71429 .71057 .70689 .70326 .69967 .69611 .69259 94 .73861 .73490 .73123 .72759 .72400 .72044 .71692 .71344 .71000 .70659

95 .75097 .74739 .74384 .74033 .73686 .73342 .73002 .72665 .72331 .72001 96 .76267 .75922 .75579 .75240 .74905 .74572 .74243 .73917 .73595 .73275 97 .77356 .77022 .76691 .76363 .76039 .75718 .75399 .75084 .74772 .74463 98 .78382 .78059 .77740 .77423 .77110 .76799 .76491 .76186 .75884 .75584 99 .79390 .79079 .78771 .78465 .78162 .77862 .77565 .77270 .76978 .76688

100 .80376 .80076 .79779 .79485 .79193 .78904 .78617 .78333 .78051 .77771 101 .81353 .81066 .80780 .80497 .80217 .79938 .79662 .79388 .79117 .78847 102 .82318 .82042 .81768 .81496 .81227 .80960 .80694 .80431 .80170 .79911 103 .83278 .83014 .82752 .82491 .82233 .81977 .81723 .81470 .81220 .80971 104 .84310 .84059 .83810 .83563 .83317 .83073 .82831 .82591 .82352 .82115

105 .85318 .85079 .84843 .84607 .84374 .84142 .83911 .83682 .83455 .83229 106 .86633 .86413 .86193 .85975 .85758 .85543 .85329 .85116 .84904 .84694 107 .88247 .88049 .87852 .87656 .87460 .87266 .87073 .86881 .86690 .86500 108 .90825 .90666 .90507 .90350 .90193 .90037 .89881 .89727 .89572 .89419 109 .95372 .95290 .95208 .95126 .95045 .94964 .94883 .94803 .94723 .94643

1999–20 I.R.B. 21 May 17, 1999

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0%

0 .01298 .01285 .01273 .01261 .01250 .01240 .01230 .01221 .01212 .01203 1 .00468 .00455 .00443 .00431 .00420 .00410 .00400 .00391 .00382 .00374 2 .00448 .00435 .00421 .00409 .00398 .00387 .00376 .00366 .00357 .00348 3 .00452 .00437 .00423 .00410 .00398 .00386 .00375 .00365 .00355 .00345 4 .00468 .00452 .00437 .00423 .00410 .00397 .00386 .00375 .00364 .00354

5 .00493 .00476 .00460 .00445 .00431 .00418 .00405 .00393 .00382 .00371 6 .00524 .00506 .00489 .00473 .00458 .00444 .00430 .00418 .00406 .00394 7 .00562 .00543 .00525 .00508 .00492 .00477 .00462 .00449 .00436 .00423 8 .00606 .00586 .00566 .00548 .00531 .00515 .00499 .00485 .00471 .00458 9 .00659 .00637 .00616 .00597 .00579 .00561 .00545 .00529 .00514 .00500

10 .00721 .00698 .00676 .00655 .00636 .00617 .00600 .00583 .00567 .00552 11 .00792 .00767 .00744 .00722 .00701 .00682 .00663 .00645 .00628 .00612 12 .00871 .00845 .00821 .00797 .00775 .00754 .00735 .00716 .00698 .00681 13 .00955 .00928 .00902 .00877 .00854 .00831 .00810 .00790 .00771 .00753 14 .01038 .01009 .00981 .00955 .00930 .00907 .00885 .00864 .00843 .00824

15 .01116 .01085 .01056 .01028 .01002 .00977 .00954 .00932 .00910 .00890 16 .01186 .01153 .01123 .01094 .01066 .01040 .01015 .00992 .00969 .00948 17 .01250 .01215 .01183 .01152 .01124 .01096 .01070 .01045 .01022 .00999 18 .01308 .01272 .01238 .01206 .01175 .01147 .01119 .01093 .01068 .01044 19 .01367 .01329 .01293 .01259 .01227 .01196 .01167 .01140 .01113 .01088

20 .01428 .01388 .01350 .01314 .01280 .01248 .01217 .01188 .01161 .01134 21 .01494 .01451 .01411 .01373 .01337 .01303 .01271 .01240 .01211 .01183 22 .01562 .01517 .01475 .01435 .01397 .01361 .01326 .01294 .01263 .01233 23 .01635 .01588 .01543 .01501 .01460 .01422 .01386 .01351 .01319 .01287 24 .01716 .01665 .01618 .01573 .01530 .01489 .01451 .01415 .01380 .01347

25 .01804 .01751 .01701 .01653 .01608 .01565 .01524 .01485 .01448 .01413 26 .01902 .01845 .01792 .01741 .01693 .01648 .01604 .01563 .01524 .01487 27 .02011 .01951 .01895 .01841 .01790 .01742 .01696 .01652 .01610 .01571 28 .02129 .02066 .02006 .01949 .01895 .01844 .01795 .01748 .01704 .01662 29 .02258 .02191 .02127 .02067 .02009 .01955 .01903 .01853 .01806 .01762

30 .02396 .02325 .02257 .02193 .02132 .02074 .02019 .01966 .01916 .01869 31 .02543 .02467 .02396 .02328 .02263 .02201 .02143 .02087 .02034 .01983 32 .02701 .02621 .02545 .02472 .02404 .02338 .02276 .02217 .02160 .02106 33 .02871 .02786 .02706 .02629 .02556 .02487 .02420 .02357 .02297 .02240 34 .03054 .02964 .02879 .02797 .02720 .02646 .02576 .02509 .02445 .02383

35 .03253 .03158 .03067 .02981 .02898 .02820 .02745 .02674 .02606 .02541 36 .03467 .03366 .03269 .03178 .03090 .03007 .02928 .02852 .02779 .02710 37 .03697 .03590 .03488 .03391 .03298 .03209 .03125 .03044 .02967 .02893 38 .03947 .03833 .03725 .03622 .03524 .03430 .03340 .03254 .03172 .03094 39 .04217 .04096 .03982 .03873 .03768 .03669 .03573 .03482 .03395 .03312

May 17, 1999 22 1999–20 I.R.B.

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0%

40 .04510 .04383 .04262 .04146 .04035 .03930 .03828 .03732 .03639 .03550 41 .04830 .04695 .04567 .04445 .04327 .04215 .04108 .04005 .03907 .03812 42 .05177 .05035 .04900 .04770 .04646 .04527 .04413 .04304 .04200 .04100 43 .05553 .05404 .05261 .05123 .04992 .04866 .04746 .04630 .04520 .04413 44 .05960 .05802 .05651 .05506 .05368 .05235 .05107 .04985 .04867 .04754

45 .06395 .06229 .06069 .05917 .05770 .05630 .05495 .05365 .05241 .05121 46 .06860 .06685 .06517 .06356 .06202 .06053 .05911 .05774 .05643 .05516 47 .07353 .07169 .06992 .06823 .06660 .06504 .06353 .06209 .06070 .05936 48 .07877 .07684 .07498 .07320 .07149 .06984 .06826 .06673 .06527 .06385 49 .08433 .08231 .08036 .07849 .07669 .07495 .07329 .07168 .07013 .06864

50 .09026 .08814 .08609 .08413 .08224 .08042 .07867 .07698 .07535 .07378 51 .09655 .09433 .09219 .09013 .08815 .08624 .08440 .08262 .08091 .07926 52 .10318 .10086 .09863 .09647 .09439 .09239 .09046 .08860 .08680 .08506 53 .11017 .10774 .10541 .10315 .10098 .09888 .09686 .09491 .09302 .09120 54 .11750 .11498 .11254 .11019 .10792 .10572 .10361 .10156 .09958 .09767

55 .12522 .12258 .12005 .11759 .11522 .11294 .11072 .10859 .10652 .10451 56 .13332 .13059 .12794 .12539 .12292 .12054 .11823 .11599 .11383 .11174 57 .14183 .13899 .13624 .13359 .13102 .12853 .12613 .12380 .12154 .11936 58 .15070 .14775 .14490 .14215 .13948 .13689 .13439 .13197 .12962 .12734 59 .15990 .15685 .15389 .15103 .14826 .14558 .14298 .14046 .13801 .13564

60 .16942 .16626 .16321 .16024 .15737 .15459 .15189 .14927 .14673 .14426 61 .17929 .17603 .17287 .16981 .16684 .16395 .16115 .15844 .15580 .15324 62 .18960 .18623 .18297 .17980 .17673 .17375 .17085 .16803 .16530 .16264 63 .20035 .19688 .19352 .19025 .18708 .18400 .18100 .17809 .17525 .17250 64 .21154 .20797 .20451 .20114 .19787 .19469 .19159 .18859 .18566 .18281

65 .22318 .21951 .21595 .21249 .20912 .20584 .20265 .19955 .19652 .19358 66 .23532 .23156 .22790 .22434 .22088 .21751 .21422 .21102 .20791 .20487 67 .24804 .24419 .24044 .23679 .23324 .22977 .22640 .22311 .21990 .21678 68 .26133 .25740 .25356 .24983 .24618 .24263 .23917 .23579 .23250 .22929 69 .27516 .27114 .26723 .26341 .25969 .25605 .25251 .24905 .24567 .24237 70 .28945 .28536 .28137 .27747 .27367 .26996 .26633 .26279 .25934 .25596

71 .30412 .29996 .29590 .29193 .28806 .28427 .28057 .27696 .27343 .26998 72 .31913 .31491 .31078 .30675 .30281 .29895 .29519 .29150 .28790 .28438 73 .33444 .33016 .32597 .32188 .31788 .31396 .31013 .30638 .30271 .29913 74 .35012 .34579 .34155 .33741 .33335 .32938 .32549 .32168 .31795 .31430

75 .36628 .36190 .35762 .35343 .34932 .34530 .34136 .33750 .33372 .33001 76 .38299 .37858 .37427 .37004 .36589 .36183 .35784 .35394 .35011 .34636 77 .40028 .39585 .39151 .38725 .38307 .37898 .37496 .37103 .36716 .36337 78 .41812 .41368 .40933 .40506 .40086 .39675 .39271 .38874 .38485 .38103 79 .43641 .43198 .42762 .42334 .41914 .41502 .41096 .40698 .40308 .39924

1999–20 I.R.B. 23 May 17, 1999

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0%

80 .45496 .45054 .44619 .44192 .43772 .43360 .42954 .42556 .42164 .41779 81 .47360 .46920 .46487 .46061 .45643 .45231 .44827 .44429 .44038 .43653 82 .49223 .48785 .48355 .47932 .47516 .47106 .46703 .46307 .45916 .45532 83 .51081 .50648 .50221 .49802 .49388 .48982 .48581 .48187 .47799 .47416 84 .52951 .52523 .52101 .51686 .51277 .50874 .50477 .50086 .49701 .49321

85 .54847 .54425 .54009 .53600 .53196 .52798 .52406 .52019 .51638 .51262 86 .56749 .56335 .55926 .55523 .55126 .54734 .54348 .53966 .53591 .53220 87 .58627 .58221 .57820 .57425 .57035 .56650 .56270 .55895 .55526 .55161 88 .60477 .60079 .59688 .59301 .58919 .58542 .58170 .57802 .57439 .57081 89 .62297 .61909 .61527 .61149 .60776 .60408 .60044 .59685 .59330 .58979

90 .64084 .63707 .63335 .62968 .62604 .62246 .61891 .61540 .61194 .60851 91 .65803 .65437 .65076 .64719 .64366 .64017 .63672 .63330 .62993 .62659 92 .67412 .67058 .66707 .66360 .66017 .65678 .65342 .65010 .64682 .64357 93 .68911 .68567 .68227 .67890 .67557 .67227 .66901 .66578 .66258 .65942 94 .70321 .69988 .69657 .69330 .69006 .68686 .68369 .68055 .67744 .67437

95 .71674 .71351 .71031 .70713 .70399 .70088 .69781 .69476 .69174 .68875 96 .72959 .72646 .72335 .72028 .71724 .71422 .71123 .70828 .70534 .70244 97 .74156 .73853 .73552 .73254 .72959 .72666 .72376 .72089 .71804 .71522 98 .75287 .74993 .74702 .74413 .74126 .73842 .73561 .73282 .73006 .72732 99 .76401 .76117 .75834 .75555 .75277 .75002 .74730 .74459 .74191 .73926

100 .77494 .77219 .76946 .76676 .76408 .76142 .75878 .75616 .75357 .75099 101 .78580 .78315 .78052 .77791 .77532 .77275 .77021 .76768 .76517 .76268 102 .79654 .79399 .79146 .78894 .78645 .78397 .78152 .77908 .77666 .77426 103 .80724 .80479 .80236 .79994 .79755 .79517 .79280 .79046 .78813 .78582 104 .81879 .81646 .81413 .81183 .80954 .80726 .80501 .80276 .80054 .79832

105 .83005 .82782 .82560 .82340 .82121 .81904 .81688 .81474 .81260 .81049 106 .84485 .84277 .84071 .83866 .83662 .83459 .83257 .83057 .82857 .82659 107 .86311 .86124 .85937 .85751 .85566 .85382 .85199 .85017 .84835 .84655 108 .89266 .89114 .88963 .88812 .88662 .88513 .88364 .88216 .88068 .87922 109 .94563 .94484 .94405 .94326 .94248 .94170 .94092 .94014 .93937 .93860

(f) Effective dates. This section applies after April 30, 1999.

Par. 6. Immediately following §1.643(d)–2, the undesignated centerheading is revised to read as follows:

Pooled Income Fund Actuarial Tables

Applicable Before May 1, 1999

• ---

(e) Present value of the remainder in- terest in the case of transfers to pooled in- come funds for which the valuation date is after April 30, 1989, and before May 1, 1999 —(1) In general. In the case of transfers to pooled income funds for which the valuation date is after April 30, 1989, and before May 1, 1999, the present value of a remainder interest is determined under this section. * * *

(2) * * * (ii) Discount at a rate of interest, compounded annually, equal to the highest

Par. 7. Section 1.642(c)–6A is amended by:

1. Revising the section heading.
2. Amending newly designated paragraph (e) as follows:

a. Paragraph (e) heading is revised.

b. Paragraph (e)(1), first sentence is revised.

c. Paragraph (e)(2)(ii) is revised. d. Paragraph (e)(3) is revised. e. Paragraph (e)(4) is revised. f. Paragraph (e)(5) introductory text is revised.

g. Paragraph (e)(5), the heading for Table S is revised.

The revisions read as follows:

§1.642(c)–6A Valuation of charitable remainder interests for which the valuation date is before May 1, 1999.

May 17, 1999 24 1999–20 I.R.B.

value of a charitable remainder unitrust interest is dependent on the termination of a life interest, see §1.664–4T(e)(7). See, however, §1.7520–3(b) (relating to exceptions to the use of prescribed tables under certain circumstances). Many actuarial factors not contained in the following tables are contained in Internal Revenue Service Publication 1458, “Actuarial Values, Book Beth,” (1999). A copy of this publication is available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402.

• ---

(f) Effective dates. This section applies after April 30, 1989, and before May 1, 1999. Par. 9 Section 1.664–4T is added to read as follows:

§1.664–4T Calculation of the fair market value of the remainder interest in a charitable remainder unitrust (temporary).

(a) [Reserved] For further guidance, see §1.664–4(a).

(1) Life contingencies determined as to each life involved, from the values of lx set forth in Table 90CM contained in §20.2031–7T(d)(7) of this chapter (Estate Tax Regulations) in the case of transfers for which the valuation date is after April 30, 1999; or from Table 80CNSMT contained §20.2031–7A(e)(4) of this chapter in the case of transfer for which the valuation date is after April 30, 1989, and before May 1, 1999. See §20.2031–7A(a) through (d) of this chapter, whichever is applicable, for transfers for which the valuation date is before May 1, 1989;

(a)(2) through (c) [Reserved] For further guidance, see §1,664–4(a)(2) through (c).

(d) Valuation. The fair market value of a remainder interest in a charitable remainder unitrust (as described in §1.664– 3) for transfers for which the valuation date is after April 30, 1999, is its present value determined under paragraph (e) of this section. The fair market value of a remainder interest in a charitable remainder unitrust (as described in §1.664–3) for transfers for which the valuation date is before May 1, 1999, is its present value determined under the following sections:

yearly rate of return of the pooled income fund for the 3 taxable years immediately preceding its taxable year in which the transfer of property to the fund is made. The provisions of §1.642(c)–6(c) apply for determining the yearly rate of return. However, where the taxable year is less than 12 months, the provisions of §1.642(c)–6T(e)(3)(ii) apply for the determining the yearly rate of return.

(3) Pooled income funds in existence less than 3 taxable years. The provisions of §1.642(c)–6T(e)(4) apply for determining the highest yearly rate of return when the pooled income fund has been in existence less than three taxable years.

(4) Computation of value of remainder interest. The factor that is used in determining the present value of a remainder interest that is dependent on the termination of the life of one individual is the factor from Table S in paragraph (e)(5) of this section under the appropriate yearly rate of return opposite the number that corresponds to the age of the individual upon whose life the value of the remainder interest is based. Table S in paragraph (e)(5) of this section includes factors for yearly rates of return from 4.2 to 14 percent. Many actuarial factors not contained in Table S in paragraph (e)(5) of this section are contained in Table S in Internal Revenue Service Publication 1457, “Actuarial Values, Alpha Volume,” (8–89). Publication 1457 is no longer available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402. However, pertinent factors in this publication may be obtained by a written request to: CC:DOM:CORP:R (IRS Publication 1457), room 5226,Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044. For other situations, see §1.642(c)–6(b). If the yearly rate of return is a percentage that is between the yearly rates of return for which factors are provided, a linear interpolation must be made. The present value of the remainder interest is determined by multiplying the fair market value of the property on the valuation date by the appropriate remainder factor. For an example of a computation of the present value of a remainder interest requiring a linear interpolation adjustment, see §1.642(c)–6T(e)(5).

(5) Actuarial tables. In the case of transfers for which the valuation date is after April 30, 1989, and before May 1, 1999, the present value of a remainder interest dependent on the termination of one life in the case of a transfer to a pooled income fund is determined by use of the following tables:

TABLE S.—BASED ON LIFE TABLE 80CNSMT SINGLE LIFE REMAINDER FACTORS

[Applicable After April 30, 1989, and Be fore May 1, 1999]

• ---

Par. 8. Section 1.664–4 is amended as follows:

1. Paragraph (a)(1) is revised.

2. Paragraph (d) is removed.

3. Paragraphs (e) heading, (e)(1) through (e)(5), and (e)(6) heading, introductory text, and Table U(1) are redesignated as §1.664–4A(e) heading, (e)(1) through (e)(5) and (e)(6) heading, introductory text, and Table U(1), respectively.

4. New paragraphs (d) through (e)(5) are added.

5. New paragraph heading and introductory text are added to remaining paragraph (e)(6) preceding Table D.

6. Paragraph (f) is revised. The additions and revision read as follows:

§1.664–4 Calculation of the fair market value of the remainder interest in a charitable remainder unitrust.

(a) * * * (1) [Reserved]. For further guidance, see §1.664–4T(a)(1).

• ---

(d) through (e)(5) [Reserved]. For further guidance, see §1.664–4T(d) through (e)(5).

(6) A ctuarial Table D and F (4.2 through 14.0) for transfers for which the valuation date is after April 30, 1989. For transfers for which the valuation date is after April 30, 1989, the present value of a charitable remainder unitrust interest that is dependent upon a term of years is determined by using the section 7520 rate and the tables in this paragraph (e)(6). For transfers for which the valuation date is after April 30, 1999, where the present

1999–20 I.R.B. 25 May 17, 1999

the term. If the adjusted payout rate is an amount that is between adjusted payout rates for which factors are provided in Table D, a linear interpolation must be made. The present value of the remainder interest is determined by multiplying the net fair market value (as of the appropriate valuation date) of the property placed in trust by the factor determined under this paragraph. For purposes of this section, the valuation date is, in the case of an inter vivos transfer, the date on which the property is transferred to the trust by the donor. However, if an election is made under section 7520 and §1.7520– 2(b) to compute the present value of the charitable interest by use of the interest rate component for either of the 2 months preceding the month in which the date of transfer falls, the month so elected is the valuation date for purposes of determining the interest rate and mortality tables. In the case of a testamentary transfer under section 2055, 2106, or 2624, the valuation date is the date of death, unless the alternate valuation date is elected under section 2032, in which event, and within the limitations set forth in section 2032 and the regulations thereunder, the valuation date is the alternate valuation date. If the decedent’s estate elects the alternate valuation date under section 2032 and also elects, under section 7520 and §1.7520–2(b), to use the interest rate component for one of the 2 months preceding the alternate valuation date, the month so elected is the valuation date for purposes of determining the interest rate and mortality tables. The application of this paragraph (e)(4) may be illustrated by the following example:

Example. D transfers $100,000 to a charitable remainder unitrust on January 1. The trust instrument requires that the trust pay 8 percent of the fair market value of the trust assets as of January 1st for a term of 12 years to D in quarterly payments (March 31, June 30, September 30, and December 31). The section 7520 rate for January (the month that the transfer occurred) is 9.6 percent. Under Table F(9.6) in §1.664–4(e)(6), the appropriate adjustment factor is .944628 for quarterly payments payable at the end of each quarter. The adjusted payout rate is 7.557 (8% � .944628). Based on the remainder factors in Table D in §1.664–4(e)(6), the present value of the remainder interest is $38,950.30, computed as follows:

Factor at 7.4 percent for 12 years ......... .397495 Factor at 7.6 percent for 12 years ......... .387314 Difference ............................................. .010181

Valuation Dates Applicable After Before Regulations

• 01-01-52 1.664-4A(a) 12-31-51 01-01-71 1.664–4A(b) 12-31-70 12-01-83 1.664–4A(c) 11-30-83 05-01-89 1.664–4A(d) 04-30-89 05-01-99 1.664–4A(e)

(e) Valuation of charitable remainder unitrusts having certain payout sequences for transfers for which the valuation date is after April 30, 1999 —(1) In general. Except as otherwise provided in paragraph (e)(2) of this section, in the case of transfers for which the valuation date is after April 30, 1999, the present value of a remainder interest is determined under paragraphs (e)(3) through (e)(6) of this section, provided that the amount of the payout as of any payout date during any taxable year of the trust is not larger than the amount that the trust could distribute on such date under §1.664–3(a)(1)(v) if the taxable year of the trust were to end on such date. See, however, §1.7520– 3(b) (relating to exceptions to the use of the prescribed tables under certain circumstances).

(2) Transitional rules for valuation of charitable remainder unitrusts. (i) For purposes of sections 2055, 2106, or 2624, if on May 1, 1999, the decedent was mentally incompetent so that the disposition of the property could not be changed, and the decedent died after April 30, 1999, without having regained competency to dispose of the decedent’s property, or the decedent died within 90 days of the date that the decedent first regained competency after April 30, 1999, the present value of a remainder interest under this section is determined as if the valuation date with respect to the decedent’s gross estate is either before May 1, 1999, or after April 30, 1999, at the option of the decedent’s executor.

(ii) For purposes of sections 170, 2055, 2106, 2522, or 2624, in the case of transfers to a charitable remainder unitrust for which the valuation date is after April 30, 1999, and before July 1, 1999, the present value of a remainder interest based on one or more measuring lives is determined under this section by use of the section 7520 interest rate for the month in which the valuation date occurs (See §§1.7520– 1(b) and 1.7520–2(a)(2)) and the appropriate actuarial tables under either para

graph (e)(7) of this section or §1.664– 4A(e)(6), at the option of the donor or the decedent’s executor, as the case may be.

(iii) For purposes of paragraphs (e)(2)(i) and (ii) of this section, where the donor or decedent’s executor is given the option to use the appropriate actuarial tables under either paragraph (e)(7) of this section or §1.664–4A(e)(6), the donor or decedent’s executor must use the same actuarial table with respect to each individual transaction and with respect to all transfers occurring on the valuation date (e.g., gift and income tax charitable deductions with respect to the same transfer must be determined based on the same tables, and all assets includible in the gross estate and/or estate tax deductions claimed must be valued based on the same tables).

(3) Adjusted payout rate. For transfers for which the valuation date is after April 30, 1989, the adjusted payout rate is determined by using the appropriate Table F in §1.664–4(e)(6), for the section 7520 interest rate applicable to the transfer. If the interest rate is between 4.2 and 14 percent, see §1.664–4(e)(6). If the interest rate is below 4.2 percent or greater than 14 percent, see §1.664–4(b). The adjusted payout rate is determined by multiplying the fixed percentage described in §1.664–3(a)(1)(i)(a) by the factor describing the payout sequence of the trust and the number of months by which the valuation date for the first full taxable year of the trust precedes the first payout date for such taxable year. If the governing instrument does not prescribe when the distribution or distributions shall be made during the taxable year of the trust, see §1.664–4(a). In the case of a trust having a payout sequence for which no figures have been provided by the appropriate table, and in the case of a trust that determines the fair market value of the trust assets by taking the average of valuations on more than one date during the taxable year, see §1.664–4(b).

(4) Period is a term of years. If the period described in §1.664–3(a)(5) is a term of years, the factor that is used in determining the present value of the remainder interest for transfers for which the valuation date is after November 30, 1983, is the factor under the appropriate adjusted payout rate in Table D of §1.664–4(e)(6) corresponding to the number of years in

May 17, 1999 26 1999–20 I.R.B.

Factor at 8.4 percent at age 45 . . . . . . . . .10117 Less: Interpolation adjustment . . . . . . . . .00008 Interpolated Factor . . . . . . . . . . . . . . . . .10109

Present value of remainder interest:

($100,000 � .10109) . . . . . . . . $10,109.00

(6) [Reserved]. (7) Actuarial Table U(1) for transfers for which the valuation date is after April 30, 1999. For transfers for which the valuation date is after April 30, 1999, the present value of a charitable remainder unitrust interest that is dependent on a term of years or the termination of a life interest is determined by using the section 7520 rate, Table U(1) in this paragraph (e)(7), and Table D and Table F(4.2) through (14.0) in §1.664–4(e)(6). See, however, §1.7520–3(b) (relating to exceptions to the use of prescribed tables under certain circumstances). Many actuarial factors not contained in the following tables are contained in Internal Revenue Service Publication 1458, “Actuarial Values, Book Beth,” (1999). A copy of this publication is available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402.

Interpolation adjustment:

7.557% – 7.4% = x 0.2% .010181 x = .007992

Factor at 7.4 percent for 12 years ......... .397495 Less: Interpolation adjustment ............... .007992 Interpolated factor .................................. .389503

Present value of remainder interest:

($100,000 � .389503) . . . . . . . . . . . $38,950.30

(5) Period is the life of one individual. If the period described in §1.664–3(a)(5) is the life of one individual, the factor that is used in determining the present value of the remainder interest for transfers for which the valuation date is after April 30, 1999, is the factor in Table U(1) in paragraph (e)(7) of this section under the appropriate adjusted payout. For purposes of the computations described in this paragraph, the age of an individual is the age of that individual at the individual’s nearest birthday. If the adjusted payout rate is an amount that is between adjusted payout rates for which factors are provided in the appropriate table, a linear interpolation must be made. The present value of the remainder interest is determined by multiplying the net fair market value (as of the valuation date as deter

mined in paragraph (e)(4) of this section) of the property placed in trust by the factor determined under this paragraph (e)(5). If the adjusted payout rate is between 4.2 and 14 percent, see paragraph (e)(7) of this section. If the adjusted payout rate is below 4.2 percent or greater than 14 percent, see §1.664–4(b). The application of this paragraph (e)(5) may be illustrated by the following example:

Example. A, who is 44 years and 11 months old, transfers $100,000 to a charitable remainder unitrust on January 1st. The trust instrument requires that the trust pay to A semiannually (on June 30 and December 31) 9 percent of the fair market value of the trust assets as of January 1st during A’s life. The section 7520 rate for January is 9.6 percent. Under Table F(9.6) in §1.664–4(e)(6), the appropriate adjustment factor is .933805 for semiannual payments payable at the end of the semiannual period. The adjusted payout rate is 8.404 (9% � .933805). Based on the remainder factors in Table U(1) in this section, the present value of the remainder interest is $10,109.00, computed as follows:

Factor at 8.4 percent at age 45 . . . . . . . . .10117 Factor at 8.6 percent at age 45 . . . . . . . . .09715 Difference. . . . . . . . . . . . . . . . . . . . . . . . .00402

Interpolation adjustment:

8.404% – 8.4% = x 0.2% .00402 x = .00008

TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

0 .06177 .05580 .05061 .04609 .04215 .03871 .03570 .03307 .03075 .02872 1 .05543 .04925 .04388 .03919 .03509 .03151 .02838 .02563 .02321 .02109 2 .05716 .05081 .04528 .04045 .03622 .03252 .02927 .02642 .02391 .02170 3 .05920 .05268 .04699 .04201 .03765 .03382 .03046 .02750 .02490 .02260 4 .06143 .05475 .04889 .04376 .03926 .03530 .03182 .02876 .02605 .02366

5 .06384 .05697 .05095 .04567 .04103 .03694 .03334 .03016 .02735 .02487 6 .06637 .05933 .05315 .04771 .04292 .03870 .03497 .03168 .02876 .02618 7 .06905 .06183 .05547 .04987 .04494 .04058 .03673 .03332 .03029 .02761 8 .07186 .06445 .05792 .05216 .04708 .04258 .03859 .03506 .03192 .02914 9 .07482 .06722 .06052 .05460 .04936 .04471 .04060 .03694 .03369 .03079

10 .07793 .07015 .06327 .05718 .05179 .04700 .04274 .03896 .03559 .03259 11 .08120 .07323 .06617 .05991 .05435 .04942 .04502 .04111 .03762 .03450 12 .08461 .07645 .06920 .06277 .05706 .05197 .04744 .04339 .03978 .03655 13 .08812 .07976 .07234 .06574 .05985 .05461 .04993 .04576 .04202 .03867 14 .09168 .08313 .07552 .06874 .06269 .05729 .05247 .04815 .04428 .04081

1999–20 I.R.B. 27 May 17, 1999

BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

15 .09527 .08652 .07872 .07176 .06554 .05999 .05501 .05055 .04655 .04296 16 .09886 .08991 .08192 .07478 .06839 .06267 .05754 .05294 .04880 .04508 17 .10249 .09334 .08515 .07782 .07126 .06537 .06008 .05533 .05105 .04720 18 .10616 .09680 .08842 .08090 .07415 .06809 .06264 .05774 .05332 .04933 19 .10994 .10037 .09178 .08407 .07714 .07091 .06529 .06023 .05566 .05153

20 .11384 .10406 .09527 .08737 .08025 .07383 .06805 .06283 .05811 .05384 21 .11790 .10790 .09891 .09080 .08349 .07690 .07094 .06555 .06068 .05626 22 .12208 .11188 .10267 .09436 .08686 .08008 .07395 .06839 .06336 .05879 23 .12643 .11601 .10659 .09808 .09038 .08342 .07710 .07138 .06618 .06146 24 .13095 .12031 .11069 .10197 .09408 .08692 .08042 .07452 .06915 .06427

25 .13567 .12481 .11497 .10605 .09795 .09060 .08392 .07784 .07230 .06726 26 .14058 .12950 .11945 .11032 .10202 .09447 .08760 .08134 .07563 .07042 27 .14571 .13442 .12415 .11481 .10631 .09856 .09149 .08505 .07916 .07379 28 .15104 .13953 .12904 .11949 .11078 .10284 .09558 .08895 .08288 .07733 29 .15656 .14484 .13414 .12438 .11546 .10731 .09986 .09304 .08679 .08106

30 .16229 .15034 .13943 .12946 .12034 .11198 .10433 .09732 .09089 .08498 31 .16821 .15605 .14493 .13474 .12541 .11685 .10900 .10179 .09517 .08909 32 .17433 .16196 .15063 .14023 .13069 .12193 .11387 .10647 .09966 .09339 33 .18068 .16810 .15655 .14595 .13620 .12723 .11897 .11137 .10437 .09791 34 .18724 .17446 .16270 .15189 .14193 .13275 .12430 .11650 .10930 .10265

35 .19405 .18107 .16910 .15808 .14791 .13853 .12987 .12187 .11448 .10764 36 .20109 .18791 .17574 .16451 .15414 .14456 .13569 .12749 .11990 .11287 37 .20838 .19500 .18263 .17120 .16062 .15083 .14177 .13337 .12558 .11835 38 .21593 .20236 .18979 .17816 .16739 .15739 .14813 .13953 .13154 .12412 39 .22374 .20998 .19723 .18540 .17443 .16423 .15477 .14597 .13779 .13017

40 .23183 .21789 .20496 .19294 .18177 .17138 .16172 .15272 .14434 .13653 41 .24021 .22611 .21299 .20079 .18943 .17885 .16899 .15980 .15123 .14322 42 .24889 .23463 .22134 .20896 .19741 .18665 .17660 .16721 .15845 .15025 43 .25786 .24344 .23000 .21744 .20572 .19477 .18453 .17496 .16601 .15762 44 .26712 .25257 .23896 .22625 .21435 .20322 .19281 .18305 .17391 .16534

45 .27665 .26196 .24821 .23534 .22328 .21198 .20139 .19145 .18213 .17338 46 .28644 .27163 .25774 .24472 .23251 .22105 .21028 .20018 .19068 .18174 47 .29647 .28155 .26754 .25438 .24201 .23040 .21947 .20919 .19952 .19041 48 .30676 .29173 .27760 .26431 .25181 .24004 .22896 .21852 .20868 .19941 49 .31729 .30217 .28794 .27453 .26190 .24999 .23876 .22817 .21817 .20873

50 .32808 .31289 .29856 .28505 .27229 .26026 .24889 .23814 .22799 .21839 51 .33912 .32387 .30946 .29585 .28299 .27083 .25933 .24845 .23815 .22840 52 .35038 .33507 .32060 .30691 .29395 .28168 .27005 .25904 .24861 .23872 53 .36185 .34651 .33198 .31821 .30517 .29280 .28106 .26993 .25937 .24934 54 .37352 .35815 .34358 .32976 .31664 .30418 .29234 .28110 .27042 .26026

May 17, 1999 28 1999–20 I.R.B.

BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

55 .38539 .37002 .35542 .34155 .32836 .31583 .30390 .29256 .28177 .27149 56 .39746 .38209 .36748 .35358 .34034 .32774 .31574 .30431 .29342 .28303 57 .40971 .39437 .37976 .36584 .35257 .33992 .32785 .31634 .30536 .29488 58 .42212 .40682 .39222 .37829 .36500 .35231 .34019 .32862 .31756 .30699 59 .43464 .41939 .40482 .39090 .37759 .36488 .35272 .34109 .32996 .31932

60 .44726 .43207 .41754 .40364 .39034 .37761 .36542 .35375 .34257 .33186 61 .45999 .44488 .43041 .41655 .40326 .39053 .37833 .36662 .35540 .34463 62 .47286 .45785 .44345 .42964 .41639 .40367 .39146 .37974 .36848 .35767 63 .48589 .47098 .45667 .44293 .42972 .41703 .40484 .39311 .38184 .37100 64 .49903 .48426 .47005 .45638 .44324 .43060 .41843 .40671 .39544 .38458

65 .51229 .49766 .48357 .47001 .45694 .44435 .43223 .42054 .40927 .39841 66 .52568 .51121 .49726 .48381 .47084 .45833 .44626 .43461 .42337 .41252 67 .53924 .52495 .51115 .49784 .48498 .47256 .46056 .44898 .43778 .42696 68 .55293 .53883 .52521 .51205 .49932 .48701 .47511 .46360 .45246 .44169 69 .56671 .55283 .53940 .52640 .51382 .50165 .48985 .47844 .46738 .45666 70 .58052 .56687 .55365 .54084 .52843 .51639 .50473 .49342 .48245 .47181

71 .59431 .58091 .56791 .55529 .54306 .53118 .51966 .50847 .49761 .48707 72 .60804 .59490 .58213 .56973 .55768 .54598 .53461 .52357 .51283 .50239 73 .62168 .60881 .59629 .58411 .57227 .56076 .54955 .53866 .52806 .51774 74 .63528 .62268 .61042 .59848 .58686 .57555 .56453 .55380 .54335 .53316

75 .64887 .63657 .62458 .61290 .60151 .59041 .57959 .56904 .55875 .54872 76 .66249 .65049 .63880 .62739 .61625 .60538 .59478 .58443 .57432 .56446 77 .67612 .66446 .65307 .64194 .63108 .62046 .61009 .59995 .59005 .58037 78 .68975 .67843 .66736 .65654 .64596 .63561 .62548 .61558 .60590 .59643 79 .70330 .69233 .68160 .67109 .66081 .65074 .64088 .63123 .62178 .61253

80 .71666 .70605 .69566 .68548 .67550 .66573 .65615 .64676 .63755 .62853 81 .72975 .71950 .70946 .69961 .68995 .68047 .67117 .66205 .65310 .64433 82 .74250 .73263 .72293 .71342 .70407 .69490 .68589 .67705 .66837 .65984 83 .75493 .74542 .73608 .72690 .71788 .70902 .70031 .69175 .68333 .67506 84 .76712 .75798 .74900 .74016 .73147 .72292 .71451 .70624 .69810 .69010

85 .77913 .77037 .76175 .75326 .74491 .73668 .72859 .72061 .71276 .70503 86 .79086 .78248 .77423 .76610 .75808 .75019 .74241 .73474 .72719 .71974 87 .80218 .79418 .78628 .77850 .77083 .76326 .75580 .74844 .74118 .73402 88 .81307 .80544 .79790 .79047 .78313 .77589 .76874 .76169 .75473 .74786 89 .82355 .81628 .80909 .80200 .79500 .78808 .78125 .77450 .76783 .76125

90 .83360 .82668 .81985 .81309 .80642 .79982 .79330 .78685 .78048 .77418 91 .84308 .83650 .83000 .82357 .81721 .81092 .80470 .79855 .79246 .78645 92 .85182 .84556 .83937 .83325 .82718 .82119 .81525 .80937 .80356 .79780 93 .85985 .85390 .84800 .84215 .83637 .83064 .82497 .81936 .81379 .80829 94 .86732 .86164 .85601 .85044 .84491 .83944 .83402 .82865 .82333 .81806

1999–20 I.R.B. 29 May 17, 1999

BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

95 .87437 .86895 .86359 .85827 .85300 .84778 .84260 .83746 .83237 .82733 96 .88097 .87582 .87070 .86563 .86060 .85561 .85066 .84575 .84088 .83605 97 .88708 .88216 .87727 .87243 .86762 .86285 .85811 .85341 .84875 .84413 98 .89280 .88810 .88343 .87880 .87420 .86964 .86511 .86061 .85614 .85171 99 .89836 .89388 .88943 .88501 .88062 .87626 .87193 .86763 .86336 .85911

100 .90375 .89948 .89525 .89103 .88685 .88269 .87856 .87445 .87037 .86632 101 .90905 .90500 .90097 .89696 .89298 .88902 .88509 .88118 .87729 .87342 102 .91424 .91040 .90658 .90278 .89900 .89524 .89150 .88778 .88408 .88040 103 .91939 .91575 .91214 .90854 .90496 .90139 .89785 .89432 .89081 .88732 104 .92485 .92144 .91805 .91467 .91131 .90796 .90463 .90131 .89800 .89471

105 .93020 .92701 .92383 .92067 .91751 .91437 .91125 .90813 .90502 .90193 106 .93701 .93411 .93122 .92834 .92546 .92260 .91974 .91689 .91405 .91122 107 .94522 .94268 .94013 .93760 .93507 .93254 .93002 .92750 .92499 .92249 108 .95782 .95583 .95385 .95187 .94989 .94791 .94593 .94396 .94199 .94002 109 .97900 .97800 .97700 .97600 .97500 .97400 .97300 .97200 .97100 .97000

May 17, 1999 30 1999–20 I.R.B.

TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0%

0 .02693 .02534 .02395 .02271 .02161 .02063 .01976 .01898 .01828 .01765 1 .01922 .01756 .01610 .01480 .01365 .01263 .01171 .01090 .01017 .00951 2 .01975 .01802 .01650 .01514 .01393 .01286 .01190 .01104 .01028 .00959 3 .02056 .01876 .01717 .01575 .01449 .01336 .01235 .01145 .01064 .00992 4 .02155 .01967 .01800 .01652 .01520 .01401 .01296 .01201 .01116 .01039

5 .02266 .02071 .01896 .01741 .01603 .01479 .01368 .01269 .01179 .01098 6 .02389 .02184 .02003 .01841 .01696 .01566 .01450 .01345 .01251 .01166 7 .02522 .02309 .02120 .01950 .01799 .01663 .01540 .01431 .01332 .01242 8 .02665 .02444 .02246 .02069 .01910 .01768 .01640 .01524 .01420 .01326 9 .02821 .02590 .02384 .02199 .02033 .01884 .01750 .01629 .01520 .01421

10 .02990 .02750 .02535 .02342 .02169 .02013 .01872 .01745 .01631 .01526 11 .03172 .02922 .02698 .02497 .02316 .02153 .02006 .01872 .01752 .01643 12 .03365 .03106 .02872 .02663 .02474 .02303 .02149 .02010 .01884 .01769 13 .03566 .03297 .03054 .02835 .02638 .02460 .02299 .02154 .02021 .01901 14 .03770 .03490 .03237 .03010 .02804 .02619 .02450 .02298 .02159 .02033

15 .03973 .03682 .03419 .03182 .02968 .02775 .02599 .02439 .02294 .02162 16 .04173 .03871 .03598 .03352 .03129 .02926 .02743 .02576 .02424 .02286 17 .04372 .04059 .03775 .03519 .03287 .03076 .02884 .02710 .02551 .02406 18 .04573 .04248 .03953 .03686 .03444 .03224 .03024 .02842 .02676 .02524 19 .04780 .04443 .04137 .03859 .03607 .03378 .03169 .02978 .02804 .02646

20 .04997 .04647 .04329 .04040 .03778 .03539 .03321 .03122 .02940 .02773 21 .05226 .04862 .04532 .04232 .03958 .03709 .03481 .03274 .03083 .02909 22 .05465 .05088 .04745 .04432 .04148 .03888 .03650 .03433 .03234 .03052 23 .05716 .05325 .04969 .04645 .04348 .04077 .03830 .03603 .03394 .03203 24 .05983 .05578 .05208 .04871 .04562 .04280 .04021 .03784 .03566 .03367

25 .06266 .05846 .05463 .05112 .04791 .04497 .04227 .03980 .03752 .03543 26 .06566 .06131 .05734 .05369 .05035 .04729 .04448 .04189 .03951 .03732 27 .06887 .06436 .06024 .05646 .05298 .04979 .04686 .04416 .04168 .03939 28 .07225 .06758 .06331 .05938 .05577 .05245 .04940 .04658 .04398 .04159 29 .07581 .07099 .06656 .06248 .05873 .05528 .05210 .04916 .04645 .04394

30 .07956 .07457 .06998 .06575 .06186 .05827 .05495 .05189 .04906 .04644 31 .08348 .07833 .07358 .06920 .06515 .06142 .05797 .05478 .05182 .04908 32 .08761 .08228 .07736 .07282 .06863 .06475 .06116 .05783 .05475 .05189 33 .09195 .08645 .08136 .07666 .07231 .06828 .06454 .06108 .05786 .05488 34 .09651 .09082 .08557 .08070 .07619 .07200 .06812 .06452 .06117 .05805

35 .10131 .09545 .09002 .08498 .08030 .07596 .07193 .06818 .06469 .06144 36 .10635 .10031 .09470 .08949 .08465 .08015 .07596 .07206 .06842 .06503 37 .11165 .10542 .09963 .09424 .08923 .08457 .08022 .07617 .07238 .06885 38 .11722 .11081 .10484 .09927 .09409 .08926 .08475 .08054 .07661 .07293 39 .12308 .11648 .11032 .10458 .09922 .09422 .08955 .08518 .08109 .07726

1999–20 I.R.B. 31 May 17, 1999

TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0%

40 .12925 .12246 .11612 .11020 .10466 .09949 .09465 .09011 .08587 .08189 41 .13575 .12877 .12225 .11614 .11043 .10508 .10007 .09537 .09097 .08683 42 .14259 .13542 .12871 .12243 .11654 .11101 .10583 .10097 .09640 .09210 43 .14977 .14242 .13552 .12905 .12298 .11729 .11193 .10690 .10217 .09771 44 .15731 .14976 .14269 .13604 .12979 .12391 .11838 .11318 .10828 .10367

45 .16516 .15743 .15017 .14334 .13691 .13086 .12516 .11979 .11472 .10994 46 .17334 .16544 .15800 .15099 .14438 .13816 .13228 .12674 .12150 .11656 47 .18184 .17375 .16613 .15895 .15217 .14576 .13972 .13400 .12860 .12349 48 .19066 .18240 .17461 .16724 .16029 .15371 .14749 .14161 .13604 .13077 49 .19981 .19138 .18342 .17588 .16875 .16201 .15562 .14956 .14383 .13839

50 .20931 .20072 .19259 .18489 .17759 .17067 .16412 .15790 .15199 .14639 51 .21917 .21042 .20212 .19426 .18679 .17971 .17299 .16660 .16054 .15477 52 .22933 .22043 .21198 .20395 .19633 .18909 .18220 .17566 .16943 .16350 53 .23981 .23076 .22216 .21399 .20621 .19881 .19176 .18506 .17867 .17258 54 .25060 .24141 .23267 .22434 .21642 .20886 .20166 .19480 .18826 .18201

55 .26171 .25239 .24351 .23504 .22697 .21927 .21192 .20491 .19821 .19182 56 .27313 .26369 .25468 .24608 .23787 .23003 .22254 .21538 .20854 .20199 57 .28487 .27531 .26618 .25746 .24912 .24114 .23351 .22621 .21923 .21254 58 .29688 .28722 .27798 .26914 .26067 .25257 .24481 .23738 .23025 .22343 59 .30913 .29937 .29002 .28107 .27249 .26427 .25639 .24882 .24157 .23461

60 .32159 .31175 .30231 .29325 .28457 .27623 .26823 .26055 .25317 .24608 61 .33429 .32437 .31485 .30571 .29692 .28848 .28037 .27257 .26507 .25786 62 .34728 .33730 .32770 .31847 .30960 .30106 .29285 .28495 .27734 .27001 63 .36057 .35053 .34087 .33157 .32262 .31400 .30569 .29769 .28998 .28255 64 .37412 .36404 .35433 .34498 .33596 .32726 .31887 .31078 .30298 .29545

65 .38794 .37783 .36809 .35868 .34961 .34085 .33239 .32422 .31633 .30871 66 .40205 .39193 .38216 .37272 .36361 .35479 .34628 .33804 .33008 .32238 67 .41650 .40639 .39661 .38715 .37800 .36915 .36059 .35230 .34428 .33651 68 .43126 .42117 .41139 .40193 .39277 .38390 .37530 .36697 .35890 .35108 69 .44628 .43622 .42648 .41703 .40787 .39898 .39037 .38201 .37391 .36604 70 .46150 .45149 .44178 .43236 .42321 .41433 .40571 .39735 .38922 .38132

71 .47683 .46689 .45723 .44785 .43873 .42987 .42126 .41290 .40476 .39685 72 .49225 .48238 .47279 .46346 .45439 .44556 .43697 .42862 .42048 .41257 73 .50770 .49793 .48841 .47915 .47013 .46135 .45280 .44447 .43635 .42844 74 .52324 .51358 .50416 .49498 .48603 .47731 .46880 .46051 .45242 .44454

75 .53894 .52939 .52008 .51100 .50214 .49349 .48505 .47681 .46877 .46092 76 .55483 .54543 .53624 .52728 .51852 .50996 .50160 .49344 .48546 .47766 77 .57091 .56167 .55263 .54380 .53516 .52671 .51845 .51038 .50247 .49475 78 .58716 .57809 .56922 .56053 .55203 .54372 .53557 .52760 .51980 .51216 79 .60346 .59459 .58590 .57738 .56904 .56086 .55286 .54501 .53732 .52978

May 17, 1999 32 1999–20 I.R.B.

TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0%

80 .61969 .61102 .60252 .59419 .58601 .57800 .57014 .56243 .55487 .54745 81 .63571 .62726 .61897 .61082 .60283 .59499 .58729 .57974 .57232 .56503 82 .65146 .64324 .63515 .62722 .61942 .61176 .60423 .59683 .58957 .58242 83 .66693 .65893 .65108 .64335 .63575 .62828 .62093 .61371 .60660 .59962 84 .68222 .67447 .66684 .65934 .65195 .64468 .63753 .63049 .62356 .61674

85 .69742 .68993 .68255 .67528 .66812 .66106 .65411 .64727 .64053 .63389 86 .71241 .70517 .69805 .69102 .68410 .67727 .67054 .66390 .65736 .65091 87 .72696 .72000 .71313 .70635 .69967 .69307 .68656 .68014 .67381 .66756 88 .74108 .73438 .72777 .72125 .71480 .70845 .70217 .69597 .68985 .68380 89 .75475 .74832 .74198 .73571 .72951 .72339 .71734 .71137 .70547 .69963

90 .76796 .76180 .75572 .74971 .74376 .73788 .73207 .72633 .72065 .71503 91 .78049 .77460 .76878 .76302 .75732 .75168 .74610 .74058 .73512 .72972 92 .79211 .78647 .78089 .77537 .76990 .76449 .75913 .75383 .74858 .74338 93 .80283 .79743 .79208 .78679 .78154 .77634 .77119 .76610 .76105 .75604 94 .81283 .80765 .80253 .79744 .79240 .78741 .78247 .77756 .77270 .76789

95 .82233 .81737 .81245 .80757 .80274 .79795 .79320 .78849 .78382 .77918 96 .83126 .82651 .82180 .81712 .81248 .80788 .80332 .79880 .79431 .78985 97 .83953 .83498 .83046 .82597 .82152 .81710 .81271 .80836 .80404 .79976 98 .84731 .84294 .83860 .83429 .83002 .82577 .82155 .81737 .81321 .80908 99 .85490 .85071 .84656 .84243 .83832 .83425 .83020 .82618 .82219 .81822

100 .86229 .85828 .85431 .85035 .84642 .84252 .83864 .83478 .83095 .82714 101 .86958 .86575 .86195 .85818 .85442 .85069 .84698 .84329 .83962 .83597 102 .87674 .87310 .86947 .86587 .86229 .85873 .85518 .85166 .84815 .84466 103 .88384 .88038 .87694 .87351 .87010 .86671 .86334 .85998 .85663 .85331 104 .89143 .88817 .88492 .88169 .87847 .87526 .87207 .86889 .86573 .86258

105 .89885 .89578 .89272 .88967 .88664 .88361 .88060 .87760 .87461 .87163 106 .90840 .90559 .90278 .89999 .89720 .89442 .89165 .88888 .88613 .88338 107 .91999 .91750 .91501 .91253 .91005 .90758 .90511 .90265 .90019 .89774 108 .93805 .93609 .93412 .93216 .93020 .92824 .92629 .92434 .92239 .92044 109 .96900 .96800 .96700 .96600 .96500 .96400 .96300 .96200 .96100 .96000

1999–20 I.R.B. 33 May 17, 1999

TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0%

0 .01709 .01658 .01612 .01570 .01532 .01497 .01466 .01437 .01410 .01386 1 .00892 .00839 .00791 .00747 .00708 .00672 .00639 .00609 .00582 .00557 2 .00896 .00840 .00790 .00744 .00702 .00664 .00629 .00598 .00569 .00542 3 .00926 .00867 .00814 .00765 .00721 .00681 .00644 .00611 .00580 .00552 4 .00970 .00908 .00851 .00800 .00753 .00711 .00672 .00636 .00604 .00574

5 .01026 .00960 .00900 .00846 .00796 .00751 .00710 .00672 .00637 .00606 6 .01089 .01019 .00956 .00899 .00846 .00799 .00755 .00715 .00678 .00644 7 .01161 .01088 .01021 .00960 .00905 .00854 .00808 .00765 .00726 .00690 8 .01241 .01163 .01093 .01029 .00970 .00917 .00867 .00822 .00781 .00743 9 .01331 .01249 .01175 .01107 .01045 .00988 .00936 .00889 .00845 .00804

10 .01432 .01346 .01268 .01196 .01131 .01071 .01016 .00965 .00918 .00875 11 .01543 .01453 .01370 .01295 .01226 .01162 .01104 .01051 .01001 .00956 12 .01664 .01569 .01482 .01403 .01330 .01263 .01202 .01145 .01093 .01045 13 .01791 .01691 .01600 .01516 .01440 .01369 .01304 .01245 .01190 .01139 14 .01918 .01813 .01717 .01629 .01548 .01474 .01406 .01343 .01285 .01231

15 .02041 .01931 .01831 .01738 .01653 .01576 .01504 .01437 .01376 .01320 16 .02160 .02044 .01938 .01841 .01752 .01670 .01595 .01525 .01460 .01401 17 .02274 .02152 .02041 .01940 .01846 .01760 .01680 .01607 .01539 .01476 18 .02386 .02258 .02142 .02035 .01936 .01846 .01762 .01685 .01613 .01547 19 .02500 .02367 .02245 .02132 .02029 .01933 .01845 .01764 .01689 .01619

20 .02621 .02481 .02353 .02235 .02126 .02025 .01933 .01847 .01768 .01694 21 .02749 .02603 .02468 .02344 .02229 .02124 .02026 .01936 .01852 .01774 22 .02884 .02730 .02589 .02458 .02338 .02227 .02124 .02029 .01940 .01859 23 .03028 .02867 .02718 .02581 .02454 .02337 .02229 .02128 .02035 .01949 24 .03183 .03013 .02857 .02713 .02580 .02456 .02342 .02236 .02138 .02047

25 .03350 .03172 .03008 .02857 .02717 .02587 .02467 .02355 .02251 .02155 26 .03530 .03344 .03172 .03013 .02865 .02729 .02602 .02484 .02375 .02273 27 .03727 .03532 .03351 .03183 .03028 .02885 .02751 .02627 .02511 .02404 28 .03937 .03732 .03543 .03367 .03204 .03052 .02911 .02780 .02658 .02545 29 .04162 .03947 .03748 .03564 .03392 .03233 .03084 .02946 .02818 .02698

30 .04401 .04176 .03967 .03773 .03593 .03425 .03269 .03124 .02988 .02861 31 .04654 .04419 .04200 .03996 .03807 .03630 .03466 .03312 .03169 .03035 32 .04923 .04676 .04447 .04233 .04034 .03849 .03676 .03514 .03363 .03221 33 .05210 .04952 .04711 .04487 .04278 .04083 .03901 .03731 .03571 .03422 34 .05515 .05245 .04993 .04758 .04538 .04333 .04142 .03962 .03794 .03637

35 .05841 .05558 .05295 .05048 .04818 .04603 .04401 .04212 .04035 .03869 36 .06187 .05892 .05616 .05358 .05116 .04890 .04678 .04480 .04293 .04118 37 .06555 .06247 .05958 .05688 .05435 .05198 .04975 .04766 .04570 .04385 38 .06949 .06627 .06325 .06043 .05777 .05528 .05295 .05075 .04868 .04674 39 .07368 .07032 .06717 .06421 .06143 .05882 .05637 .05406 .05189 .04984

May 17, 1999 34 1999–20 I.R.B.

TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0%

40 .07816 .07465 .07137 .06827 .06537 .06263 .06006 .05764 .05535 .05320 41 .08295 .07930 .07587 .07264 .06960 .06674 .06405 .06150 .05910 .05683 42 .08807 .08427 .08069 .07733 .07415 .07116 .06833 .06567 .06315 .06077 43 .09352 .08957 .08585 .08233 .07902 .07589 .07294 .07014 .06750 .06500 44 .09932 .09521 .09134 .08768 .08423 .08096 .07787 .07495 .07218 .06956

45 .10543 .10117 .09715 .09334 .08974 .08634 .08311 .08005 .07716 .07441 46 .11189 .10747 .10329 .09933 .09559 .09204 .08867 .08548 .08245 .07958 47 .11866 .11408 .10974 .10564 .10174 .09805 .09454 .09121 .08805 .08504 48 .12577 .12103 .11654 .11228 .10823 .10439 .10074 .09727 .09397 .09083 49 .13323 .12833 .12368 .11926 .11506 .11107 .10728 .10366 .10022 .09695

50 .14107 .13601 .13120 .12663 .12228 .11813 .11419 .11043 .10685 .10344 51 .14928 .14407 .13910 .13437 .12987 .12558 .12149 .11758 .11386 .11031 52 .15785 .15248 .14735 .14247 .13781 .13337 .12913 .12508 .12122 .11752 53 .16678 .16124 .15597 .15093 .14612 .14153 .13714 .13294 .12893 .12509 54 .17606 .17037 .16493 .15974 .15478 .15004 .14550 .14116 .13700 .13302

55 .18570 .17986 .17428 .16893 .16382 .15893 .15424 .14976 .14546 .14134 56 .19573 .18974 .18400 .17851 .17325 .16821 .16338 .15875 .15430 .15004 57 .20613 .20000 .19412 .18848 .18307 .17789 .17291 .16814 .16355 .15914 58 .21688 .21060 .20458 .19880 .19325 .18792 .18280 .17788 .17316 .16861 59 .22793 .22151 .21535 .20943 .20374 .19827 .19301 .18795 .18309 .17840

60 .23927 .23272 .22642 .22036 .21454 .20893 .20354 .19834 .19334 .18851 61 .25092 .24425 .23782 .23163 .22567 .21993 .21440 .20907 .20393 .19898 62 .26295 .25616 .24961 .24329 .23721 .23134 .22568 .22021 .21494 .20985 63 .27538 .26847 .26180 .25537 .24916 .24316 .23738 .23179 .22639 .22117 64 .28817 .28116 .27438 .26783 .26150 .25539 .24949 .24377 .23825 .23291

65 .30134 .29423 .28735 .28069 .27426 .26803 .26201 .25618 .25054 .24508 66 .31493 .30772 .30075 .29399 .28746 .28113 .27500 .26906 .26331 .25774 67 .32899 .32170 .31464 .30780 .30118 .29475 .28852 .28248 .27663 .27095 68 .34349 .33614 .32901 .32209 .31538 .30887 .30256 .29643 .29047 .28469 69 .35841 .35100 .34381 .33683 .33005 .32346 .31707 .31085 .30481 .29894 70 .37366 .36620 .35896 .35193 .34509 .33844 .33197 .32568 .31957 .31362

71 .38916 .38167 .37440 .36732 .36043 .35372 .34720 .34084 .33466 .32864 72 .40486 .39736 .39006 .38295 .37602 .36927 .36270 .35629 .35005 .34396 73 .42074 .41323 .40591 .39878 .39182 .38504 .37843 .37198 .36568 .35955 74 .43685 .42934 .42202 .41488 .40791 .40110 .39446 .38798 .38165 .37547

75 .45326 .44577 .43846 .43132 .42435 .41754 .41088 .40438 .39802 .39181 76 .47004 .46259 .45530 .44818 .44122 .43442 .42776 .42125 .41488 .40865 77 .48718 .47979 .47255 .46547 .45853 .45175 .44511 .43861 .43225 .42601 78 .50467 .49735 .49017 .48314 .47626 .46951 .46290 .45643 .45008 .44386 79 .52239 .51515 .50806 .50110 .49427 .48758 .48102 .47459 .46828 .46209

1999–20 I.R.B. 35 May 17, 1999

TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0%

80 .54018 .53304 .52603 .51916 .51242 .50580 .49930 .49292 .48666 .48052 81 .55788 .55085 .54396 .53718 .53053 .52399 .51757 .51126 .50507 .49898 82 .57540 .56851 .56173 .55506 .54851 .54207 .53574 .52951 .52339 .51737 83 .59274 .58598 .57933 .57279 .56635 .56001 .55378 .54765 .54161 .53567 84 .61002 .60341 .59690 .59049 .58418 .57796 .57184 .56582 .55988 .55403

85 .62734 .62090 .61454 .60828 .60211 .59603 .59004 .58414 .57832 .57258 86 .64455 .63828 .63210 .62600 .61999 .61406 .60821 .60244 .59675 .59113 87 .66139 .65531 .64930 .64337 .63752 .63175 .62605 .62043 .61488 .60939 88 .67783 .67194 .66612 .66037 .65469 .64908 .64354 .63807 .63267 .62733 89 .69387 .68817 .68254 .67698 .67148 .66605 .66068 .65537 .65012 .64493

90 .70947 .70398 .69855 .69318 .68786 .68261 .67742 .67228 .66719 .66217 91 .72437 .71908 .71385 .70867 .70354 .69847 .69345 .68848 .68357 .67870 92 .73823 .73314 .72810 .72310 .71816 .71326 .70841 .70361 .69886 .69415 93 .75109 .74618 .74132 .73650 .73173 .72700 .72232 .71768 .71308 .70852 94 .76312 .75839 .75370 .74905 .74445 .73988 .73536 .73087 .72643 .72202

95 .77459 .77004 .76552 .76104 .75660 .75220 .74783 .74350 .73920 .73494 96 .78543 .78105 .77670 .77238 .76810 .76386 .75964 .75546 .75131 .74720 97 .79550 .79128 .78709 .78293 .77880 .77470 .77063 .76659 .76258 .75860 98 .80498 .80091 .79687 .79286 .78888 .78492 .78099 .77709 .77322 .76937 99 .81428 .81036 .80647 .80261 .79877 .79496 .79117 .78741 .78367 .77995

100 .82336 .81959 .81586 .81214 .80845 .80478 .80113 .79751 .79390 .79032 101 .83234 .82873 .82515 .82158 .81804 .81451 .81101 .80753 .80406 .80062 102 .84119 .83774 .83431 .83089 .82750 .82412 .82076 .81742 .81409 .81078 103 .84999 .84670 .84342 .84016 .83691 .83368 .83046 .82726 .82408 .82091 104 .85944 .85632 .85321 .85011 .84703 .84396 .84090 .83786 .83483 .83182

105 .86866 .86570 .86276 .85982 .85690 .85399 .85109 .84820 .84532 .84245 106 .88065 .87792 .87520 .87248 .86978 .86708 .86440 .86172 .85905 .85638 107 .89530 .89286 .89042 .88799 .88557 .88315 .88073 .87833 .87592 .87352 108 .91849 .91654 .91460 .91266 .91072 .90879 .90685 .90492 .90299 .90106 109 .95900 .95800 .95700 .95600 .95500 .95400 .95300 .95200 .95100 .95000

May 17, 1999 36 1999–20 I.R.B.

TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0%

0 .01363 .01342 .01323 .01305 .01288 .01272 .01258 .01244 .01231 .01219 1 .00534 .00512 .00493 .00474 .00458 .00442 .00427 .00414 .00401 .00389 2 .00518 .00495 .00474 .00455 .00437 .00421 .00405 .00391 .00377 .00365 3 .00526 .00502 .00480 .00459 .00440 .00422 .00406 .00391 .00376 .00363 4 .00546 .00521 .00497 .00475 .00455 .00436 .00419 .00402 .00387 .00373

5 .00576 .00549 .00524 .00501 .00479 .00459 .00440 .00423 .00406 .00391 6 .00613 .00584 .00557 .00532 .00509 .00488 .00468 .00449 .00432 .00415 7 .00657 .00626 .00598 .00571 .00547 .00524 .00502 .00482 .00464 .00446 8 .00707 .00675 .00644 .00616 .00590 .00565 .00542 .00521 .00501 .00482 9 .00766 .00732 .00699 .00669 .00641 .00615 .00591 .00568 .00547 .00527

10 .00835 .00798 .00764 .00732 .00702 .00675 .00649 .00624 .00602 .00580 11 .00913 .00874 .00838 .00804 .00772 .00743 .00715 .00689 .00665 .00642 12 .01000 .00959 .00920 .00884 .00851 .00819 .00790 .00762 .00737 .00712 13 .01091 .01048 .01007 .00969 .00933 .00900 .00869 .00840 .00813 .00787 14 .01181 .01135 .01092 .01052 .01014 .00979 .00947 .00916 .00887 .00860

15 .01267 .01218 .01173 .01130 .01091 .01054 .01019 .00987 .00956 .00928 16 .01345 .01294 .01246 .01201 .01160 .01121 .01084 .01050 .01018 .00988 17 .01418 .01364 .01313 .01266 .01222 .01181 .01143 .01107 .01073 .01041 18 .01486 .01429 .01375 .01326 .01279 .01236 .01196 .01158 .01122 .01088 19 .01554 .01494 .01438 .01385 .01336 .01291 .01248 .01208 .01170 .01135

20 .01626 .01562 .01503 .01448 .01396 .01348 .01303 .01260 .01220 .01183 21 .01702 .01635 .01573 .01514 .01460 .01409 .01361 .01316 .01274 .01235 22 .01782 .01711 .01645 .01584 .01526 .01472 .01422 .01374 .01330 .01288 23 .01868 .01793 .01724 .01658 .01597 .01540 .01487 .01437 .01390 .01345 24 .01962 .01883 .01809 .01740 .01675 .01615 .01558 .01505 .01455 .01408

25 .02065 .01981 .01903 .01830 .01762 .01698 .01638 .01581 .01528 .01478 26 .02178 .02089 .02006 .01929 .01856 .01789 .01725 .01665 .01609 .01556 27 .02303 .02209 .02122 .02040 .01963 .01891 .01824 .01760 .01700 .01644 28 .02439 .02339 .02247 .02160 .02079 .02002 .01931 .01863 .01800 .01740 29 .02585 .02480 .02382 .02290 .02204 .02123 .02047 .01976 .01908 .01845

30 .02742 .02631 .02527 .02430 .02339 .02253 .02172 .02096 .02025 .01957 31 .02910 .02793 .02683 .02579 .02482 .02391 .02306 .02225 .02149 .02077 32 .03089 .02965 .02849 .02739 .02636 .02540 .02449 .02363 .02282 .02206 33 .03282 .03151 .03028 .02912 .02803 .02701 .02604 .02513 .02427 .02346 34 .03489 .03350 .03220 .03097 .02982 .02873 .02771 .02674 .02583 .02497

35 .03713 .03567 .03429 .03299 .03177 .03061 .02953 .02850 .02753 .02661 36 .03953 .03798 .03653 .03515 .03386 .03263 .03148 .03039 .02936 .02838 37 .04211 .04048 .03894 .03748 .03611 .03481 .03359 .03243 .03134 .03030 38 .04490 .04318 .04155 .04001 .03856 .03719 .03589 .03466 .03350 .03239 39 .04791 .04609 .04437 .04274 .04120 .03975 .03837 .03707 .03583 .03466

1999–20 I.R.B. 37 May 17, 1999

TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0%

40 .05116 .04924 .04742 .04571 .04408 .04254 .04108 .03970 .03839 .03714 41 .05469 .05267 .05075 .04894 .04722 .04559 .04405 .04258 .04119 .03987 42 .05851 .05638 .05436 .05245 .05063 .04891 .04728 .04573 .04425 .04285 43 .06263 .06039 .05827 .05625 .05433 .05252 .05079 .04915 .04759 .04610 44 .06707 .06472 .06248 .06035 .05834 .05642 .05459 .05286 .05121 .04963

45 .07180 .06933 .06698 .06474 .06262 .06059 .05867 .05684 .05509 .05342 46 .07685 .07425 .07178 .06943 .06720 .06507 .06304 .06110 .05926 .05750 47 .08218 .07946 .07687 .07440 .07205 .06981 .06768 .06564 .06369 .06183 48 .08784 .08499 .08228 .07969 .07722 .07487 .07262 .07047 .06842 .06646 49 .09382 .09085 .08801 .08530 .08271 .08024 .07788 .07562 .07346 .07140

50 .10018 .09707 .09410 .09127 .08856 .08597 .08349 .08112 .07885 .07667 51 .10691 .10367 .10057 .09761 .09477 .09206 .08946 .08697 .08459 .08231 52 .11399 .11061 .10738 .10429 .10132 .09849 .09577 .09316 .09066 .08826 53 .12142 .11791 .11454 .11132 .10823 .10526 .10242 .09969 .09707 .09456 54 .12921 .12556 .12206 .11870 .11548 .11239 .10942 .10657 .10383 .10120

55 .13738 .13359 .12995 .12646 .12311 .11989 .11679 .11382 .11096 .10820 56 .14595 .14202 .13824 .13462 .13113 .12778 .12456 .12146 .11847 .11560 57 .15491 .15084 .14693 .14317 .13955 .13607 .13272 .12949 .12638 .12338 58 .16424 .16004 .15599 .15209 .14834 .14473 .14125 .13789 .13465 .13153 59 .17390 .16955 .16537 .16134 .15746 .15371 .15010 .14662 .14325 .14001

60 .18387 .17939 .17507 .17091 .16689 .16302 .15927 .15566 .15217 .14880 61 .19420 .18958 .18513 .18084 .17669 .17268 .16881 .16506 .16145 .15795 62 .20494 .20020 .19561 .19119 .18691 .18277 .17877 .17490 .17115 .16753 63 .21613 .21126 .20654 .20199 .19758 .19331 .18918 .18518 .18131 .17757 64 .22774 .22274 .21791 .21322 .20869 .20429 .20004 .19592 .19192 .18805

65 .23979 .23467 .22971 .22490 .22025 .21573 .21135 .20710 .20299 .19899 66 .25233 .24709 .24202 .23709 .23231 .22767 .22318 .21881 .21457 .21045 67 .26543 .26009 .25489 .24985 .24496 .24021 .23560 .23111 .22676 .22252 68 .27908 .27363 .26833 .26319 .25819 .25332 .24860 .24400 .23954 .23519 69 .29324 .28769 .28230 .27705 .27195 .26699 .26216 .25746 .25288 .24843 70 .30783 .30219 .29671 .29137 .28618 .28112 .27619 .27139 .26672 .26216

71 .32277 .31706 .31150 .30608 .30079 .29564 .29063 .28573 .28096 .27631 72 .33803 .33225 .32661 .32112 .31575 .31052 .30542 .30044 .29559 .29084 73 .35356 .34772 .34201 .33645 .33101 .32571 .32053 .31547 .31053 .30571 74 .36943 .36354 .35778 .35215 .34666 .34129 .33604 .33091 .32590 .32100

75 .38574 .37980 .37400 .36833 .36278 .35735 .35205 .34686 .34178 .33681 76 .40256 .39660 .39076 .38505 .37947 .37400 .36864 .36340 .35827 .35324 77 .41991 .41394 .40808 .40235 .39674 .39124 .38585 .38056 .37539 .37032 78 .43777 .43180 .42594 .42020 .41457 .40906 .40365 .39834 .39314 .38803 79 .45602 .45007 .44422 .43849 .43287 .42735 .42193 .41661 .41139 .40627

May 17, 1999 38 1999–20 I.R.B.

TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0%

80 .47449 .46856 .46275 .45704 .45143 .44592 .44051 .43519 .42997 .42484 81 .49300 .48712 .48134 .47566 .47008 .46460 .45921 .45391 .44870 .44357 82 .51145 .50563 .49990 .49427 .48873 .48328 .47792 .47265 .46746 .46235 83 .52983 .52407 .51841 .51284 .50735 .50195 .49663 .49139 .48624 .48116

84 .54828 .54261 .53702 .53151 .52609 .52075 .51549 .51030 .50519 .50015 85 .56693 .56135 .55586 .55044 .54510 .53983 .53464 .52952 .52447 .51949 86 .58560 .58013 .57474 .56943 .56418 .55901 .55390 .54886 .54389 .53898 87 .60398 .59864 .59337 .58817 .58303 .57795 .57294 .56799 .56310 .55828 88 .62206 .61685 .61170 .60662 .60159 .59663 .59173 .58688 .58209 .57736 89 .63980 .63474 .62972 .62477 .61987 .61503 .61024 .60551 .60083 .59620

90 .65719 .65227 .64741 .64259 .63783 .63312 .62846 .62385 .61928 .61477 91 .67388 .66912 .66440 .65973 .65511 .65053 .64600 .64152 .63708 .63269 92 .68949 .68487 .68030 .67577 .67129 .66685 .66245 .65809 .65378 .64950 93 .70401 .69954 .69511 .69072 .68637 .68205 .67778 .67355 .66935 .66519 94 .71765 .71332 .70902 .70477 .70055 .69636 .69222 .68810 .68403 .67998

95 .73072 .72653 .72237 .71825 .71416 .71010 .70608 .70209 .69813 .69421 96 .74311 .73906 .73504 .73105 .72709 .72316 .71926 .71539 .71155 .70774 97 .75465 .75073 .74684 .74297 .73914 .73533 .73155 .72780 .72407 .72037 98 .76555 .76175 .75798 .75424 .75052 .74683 .74317 .73953 .73591 .73232 99 .77626 .77260 .76895 .76534 .76174 .75817 .75462 .75109 .74759 .74411

100 .78676 .78323 .77971 .77622 .77274 .76929 .76586 .76245 .75906 .75569 101 .79719 .79379 .79040 .78703 .78368 .78035 .77704 .77375 .77048 .76722 102 .80749 .80422 .80096 .79772 .79450 .79130 .78811 .78494 .78178 .77864 103 .81775 .81461 .81149 .80838 .80529 .80221 .79914 .79609 .79306 .79003 104 .82881 .82582 .82284 .81988 .81693 .81399 .81106 .80815 .80525 .80236

105 .83959 .83674 .83391 .83108 .82826 .82546 .82267 .81988 .81711 .81435 106 .85373 .85108 .84844 .84581 .84319 .84058 .83797 .83537 .83278 .83020 107 .87113 .86875 .86636 .86399 .86161 .85925 .85689 .85453 .85218 .84984 108 .89913 .89721 .89529 .89337 .89145 .88953 .88762 .88571 .88380 .88189 109 .94900 .94800 .94700 .94600 .94500 .94400 .94300 .94200 .94100 .94000

1999–20 I.R.B. 39 May 17, 1999

TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0%

0 .01208 .01197 .01187 .01177 .01168 .01159 .01151 .01143 .01135 .01128 1 .00378 .00367 .00358 .00348 .00340 .00331 .00323 .00316 .00309 .00302 2 .00353 .00342 .00331 .00322 .00312 .00304 .00295 .00288 .00280 .00273 3 .00350 .00339 .00327 .00317 .00307 .00298 .00289 .00281 .00273 .00265 4 .00359 .00347 .00335 .00324 .00313 .00303 .00294 .00285 .00276 .00268

5 .00377 .00363 .00351 .00339 .00327 .00317 .00306 .00297 .00288 .00279 6 .00400 .00386 .00372 .00359 .00347 .00335 .00325 .00314 .00305 .00295 7 .00430 .00414 .00400 .00386 .00373 .00360 .00349 .00338 .00327 .00317 8 .00465 .00448 .00432 .00417 .00403 .00390 .00378 .00366 .00354 .00344 9 .00508 .00490 .00473 .00457 .00442 .00428 .00414 .00402 .00389 .00378

10 .00560 .00541 .00523 .00506 .00490 .00475 .00460 .00446 .00433 .00421 11 .00620 .00600 .00581 .00563 .00546 .00529 .00514 .00499 .00485 .00472 12 .00689 .00668 .00647 .00628 .00610 .00593 .00576 .00560 .00545 .00531 13 .00763 .00740 .00718 .00698 .00678 .00660 .00642 .00626 .00610 .00595 14 .00834 .00810 .00787 .00766 .00745 .00726 .00707 .00689 .00673 .00657

15 .00901 .00875 .00851 .00828 .00807 .00786 .00767 .00748 .00730 .00714 16 .00959 .00932 .00907 .00883 .00860 .00839 .00818 .00799 .00780 .00762 17 .01011 .00983 .00956 .00930 .00907 .00884 .00862 .00842 .00822 .00804 18 .01057 .01027 .00999 .00972 .00947 .00923 .00900 .00879 .00858 .00839 19 .01101 .01070 .01040 .01012 .00985 .00960 .00936 .00914 .00892 .00871

20 .01148 .01115 .01083 .01054 .01026 .00999 .00974 .00950 .00927 .00905 21 .01197 .01162 .01129 .01098 .01068 .01040 .01014 .00988 .00964 .00941 22 .01249 .01211 .01176 .01143 .01112 .01082 .01054 .01027 .01002 .00978 23 .01304 .01264 .01227 .01192 .01159 .01127 .01098 .01069 .01042 .01017 24 .01364 .01322 .01283 .01246 .01210 .01177 .01145 .01115 .01087 .01060

25 .01431 .01387 .01345 .01306 .01268 .01233 .01199 .01168 .01137 .01109 26 .01506 .01459 .01415 .01373 .01333 .01295 .01260 .01226 .01194 .01163 27 .01591 .01541 .01494 .01449 .01407 .01367 .01329 .01293 .01259 .01226 28 .01684 .01631 .01580 .01533 .01488 .01445 .01405 .01367 .01330 .01296 29 .01785 .01728 .01675 .01624 .01577 .01531 .01488 .01447 .01408 .01372

30 .01893 .01833 .01776 .01723 .01672 .01623 .01578 .01534 .01493 .01453 31 .02010 .01946 .01885 .01828 .01773 .01722 .01673 .01627 .01582 .01540 32 .02134 .02066 .02002 .01940 .01883 .01828 .01776 .01726 .01679 .01634 33 .02270 .02197 .02128 .02063 .02002 .01943 .01887 .01835 .01784 .01736 34 .02415 .02338 .02265 .02195 .02130 .02067 .02008 .01951 .01897 .01846

35 .02574 .02492 .02414 .02340 .02270 .02203 .02140 .02080 .02022 .01967 36 .02746 .02658 .02575 .02496 .02422 .02350 .02283 .02218 .02157 .02098 37 .02932 .02838 .02750 .02666 .02586 .02510 .02438 .02369 .02303 .02241 38 .03135 .03035 .02941 .02851 .02766 .02685 .02608 .02534 .02464 .02397 39 .03355 .03249 .03149 .03053 .02962 .02876 .02793 .02715 .02640 .02568

May 17, 1999 40 1999–20 I.R.B.

TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0%

40 .03596 .03484 .03377 .03275 .03178 .03086 .02998 .02914 .02833 .02757 41 .03861 .03742 .03628 .03520 .03416 .03318 .03224 .03134 .03048 .02966 42 .04152 .04025 .03903 .03788 .03678 .03573 .03473 .03377 .03285 .03198 43 .04468 .04333 .04205 .04082 .03965 .03853 .03746 .03644 .03546 .03453 44 .04813 .04670 .04533 .04403 .04278 .04159 .04045 .03936 .03832 .03732

45 .05183 .05032 .04887 .04748 .04616 .04489 .04368 .04252 .04141 .04034 46 .05582 .05421 .05267 .05121 .04980 .04846 .04717 .04593 .04475 .04362 47 .06006 .05836 .05673 .05518 .05369 .05226 .05089 .04958 .04832 .04711 48 .06459 .06279 .06107 .05943 .05785 .05634 .05488 .05349 .05216 .05087 49 .06942 .06752 .06571 .06397 .06230 .06070 .05916 .05768 .05626 .05490

50 .07459 .07259 .07068 .06884 .06708 .06538 .06376 .06219 .06069 .05924 51 .08012 .07801 .07599 .07406 .07220 .07041 .06869 .06703 .06544 .06391 52 .08596 .08375 .08163 .07959 .07763 .07574 .07392 .07218 .07049 .06887 53 .09214 .08982 .08759 .08544 .08338 .08139 .07948 .07763 .07586 .07415 54 .09867 .09623 .09389 .09164 .08946 .08737 .08536 .08342 .08154 .07974

55 .10556 .10301 .10055 .09819 .09591 .09371 .09159 .08955 .08757 .08567 56 .11283 .11016 .10759 .10511 .10272 .10042 .09819 .09605 .09397 .09197 57 .12050 .11771 .11502 .11243 .10993 .10751 .10518 .10293 .10075 .09864 58 .12852 .12562 .12281 .12011 .11749 .11496 .11252 .11016 .10787 .10567 59 .13687 .13385 .13092 .12810 .12537 .12273 .12017 .11770 .11531 .11299

60 .14554 .14240 .13935 .13641 .13356 .13080 .12813 .12555 .12305 .12063 61 .15457 .15130 .14813 .14507 .14210 .13923 .13644 .13375 .13113 .12860 62 .16402 .16063 .15734 .15415 .15107 .14808 .14518 .14237 .13964 .13699 63 .17393 .17042 .16700 .16370 .16049 .15738 .15437 .15144 .14860 .14584 64 .18429 .18065 .17712 .17369 .17036 .16714 .16400 .16096 .15800 .15513

65 .19511 .19135 .18769 .18415 .18070 .17735 .17410 .17094 .16787 .16488 66 .20645 .20257 .19880 .19513 .19157 .18810 .18473 .18146 .17827 .17517 67 .21841 .21441 .21052 .20673 .20305 .19947 .19599 .19259 .18929 .18608 68 .23096 .22685 .22284 .21895 .21515 .21146 .20786 .20436 .20094 .19762 69 .24409 .23987 .23575 .23175 .22784 .22404 .22033 .21672 .21320 .20976 70 .25772 .25339 .24918 .24507 .24106 .23715 .23333 .22961 .22598 .22244

71 .27178 .26735 .26304 .25882 .25471 .25070 .24679 .24296 .23923 .23559 72 .28622 .28170 .27729 .27298 .26877 .26467 .26065 .25673 .25290 .24915 73 .30100 .29639 .29189 .28749 .28320 .27899 .27489 .27087 .26694 .26310 74 .31621 .31152 .30694 .30246 .29807 .29378 .28959 .28548 .28146 .27753

75 .33195 .32719 .32253 .31797 .31351 .30914 .30486 .30067 .29657 .29255 76 .34832 .34350 .33877 .33415 .32961 .32517 .32082 .31656 .31238 .30828 77 .36535 .36047 .35570 .35101 .34642 .34192 .33750 .33317 .32892 .32475 78 .38302 .37811 .37329 .36856 .36392 .35937 .35490 .35051 .34621 .34198 79 .40124 .39630 .39145 .38669 .38201 .37742 .37291 .36848 .36413 .35985

1999–20 I.R.B. 41 May 17, 1999

TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0%

80 .41980 .41485 .40998 .40520 .40050 .39588 .39134 .38688 .38249 .37818 81 .43854 .43358 .42871 .42392 .41921 .41457 .41001 .40553 .40112 .39678 82 .45733 .45238 .44752 .44273 .43802 .43338 .42881 .42431 .41989 .41553 83 .47616 .47123 .46638 .46161 .45690 .45227 .44770 .44320 .43877 .43441 84 .49519 .49030 .48548 .48073 .47604 .47143 .46688 .46239 .45797 .45361

85 .51458 .50974 .50496 .50025 .49560 .49102 .48650 .48204 .47763 .47329 86 .53413 .52935 .52463 .51998 .51538 .51084 .50636 .50194 .49758 .49327 87 .55351 .54881 .54416 .53957 .53503 .53055 .52613 .52176 .51744 .51317 88 .57268 .56806 .56349 .55898 .55451 .55010 .54574 .54144 .53718 .53296 89 .59162 .58710 .58262 .57819 .57382 .56949 .56520 .56097 .55678 .55263

90 .61030 .60588 .60151 .59718 .59290 .58866 .58447 .58032 .57621 .57214 91 .62834 .62403 .61977 .61554 .61136 .60722 .60312 .59907 .59505 .59107 92 .64527 .64107 .63692 .63280 .62872 .62468 .62068 .61672 .61279 .60890 93 .66107 .65699 .65294 .64893 .64495 .64101 .63711 .63323 .62940 .62559 94 .67597 .67200 .66806 .66415 .66027 .65643 .65262 .64884 .64509 .64138

95 .69031 .68645 .68262 .67881 .67504 .67130 .66759 .66390 .66025 .65662 96 .70396 .70021 .69648 .69279 .68912 .68548 .68186 .67828 .67471 .67118 97 .71670 .71305 .70943 .70584 .70227 .69872 .69520 .69171 .68824 .68480 98 .72875 .72521 .72169 .71819 .71472 .71127 .70784 .70444 .70106 .69770 99 .74065 .73721 .73379 .73040 .72703 .72368 .72035 .71704 .71375 .71048

100 .75234 .74901 .74570 .74241 .73914 .73589 .73265 .72944 .72625 .72307 101 .76399 .76077 .75757 .75438 .75122 .74807 .74494 .74183 .73873 .73565 102 .77552 .77241 .76932 .76625 .76319 .76015 .75712 .75411 .75111 .74813 103 .78703 .78404 .78106 .77809 .77514 .77221 .76929 .76638 .76348 .76060 104 .79948 .79662 .79377 .79093 .78810 .78528 .78248 .77969 .77691 .77414

105 .81159 .80885 .80612 .80340 .80069 .79799 .79530 .79262 .78995 .78729 106 .82763 .82506 .82250 .81995 .81741 .81488 .81235 .80983 .80732 .80482 107 .84749 .84516 .84283 .84051 .83819 .83587 .83356 .83126 .82896 .82666 108 .87999 .87808 .87618 .87428 .87238 .87049 .86859 .86670 .86481 .86293 109 .93900 .93800 .93700 .93600 .93500 .93400 .93300 .93200 .93100 .93000

(f) Effective dates. This section applies after April 30, 1999.

Par. 10. The undesignated center heading immediately preceding §1.664-4A is revised to read as follows:

The addition and revisions read as follows:

§1.664–4A Valuation of charitable remainder interests for which the valuation date is before May 1, 1999.

• ---

(d) * * * (4) Period is a term of years. If the period described in §1.664-3(a)(5) is a term of years, the factor which is used in determining the present value of the remainder interest is the factor under the appropriate

Unitrust Actuarial Tables Applicable

Before May 1, 1999 Par. 11. Section 1.664-4A is amended as follows:

1. The section heading is revised.

2. In paragraph (d)(4), the first sentence is revised.

3. In paragraph (d)(6), the introductory text is revised and Table D is removed.

4. The heading of newly designated paragraph (e) is revised.

5. In newly designated paragraph (e)(1), the first sentence is revised.

6. Newly designated paragraphs (e)(3) through (e)(5) are revised.

7. In newly designated paragraph (e)(6), the heading and the first sentence of the introductory text are revised and the last sentence of introductory text is removed and two new sentences are added in its place.

8. The heading of Table U(1) is revised.

May 17, 1999 42 1999–20 I.R.B.

written request to: CC:DOM:CORP:R (IRS Publication 1458), room 5226, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044.

Table U(1).—Unitrust Single Life Remainder Factors - Based on Life Table

80CNSMT

[Applicable for Transfers After April 30,

1989, and Before May 1, 1999]

• ---

Par. 12. Section 1.7520–1 is amended by:

1. Revising the last two sentences of paragraph (b)(2).

2. Revising the headings for paragraphs (c)(1) and (c)(2).

3. Revising the introductory text of paragraph (c)(2).

4. Removing the first two sentences of paragraph (c)(2)(iii) and adding one sentence in their place.

5. Revising paragraph (d). The revisions and addition read as follows:

§1.7520–1 Valuation of annuities, unitrust interests, interests for life or terms of years, and remainder or reversionary interests.

• ---

(b) * * * (2) * * * For transactions with valuation dates after April 30, 1989, and before May 1, 1999, the mortality component table (80CNSMT) is contained in §20.2031–7A(e)(4) of this chapter. See §20.2031–7A(a) through (d) of this chapter for mortality component tables applicable to transactions for which the valuation date falls before May 1, 1989.

(c) * * * (1) Regulations sections containing ta- bles with interest rates between 4.2 and 14 percent for valuation dates after April 30, 1989, and before May 1, 1999. - * * (2) Internal Revenue Service publica- tions containing tables with interest rates between 2.2 and 26 percent for valuation dates after April 30, 1989, and before May 1, 1999. The following publications are no longer available for purchase from the Superintendent of Documents, however, they may be obtained from CC:DOM:CORP:R, room 5226, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044:

• ---

adjusted payout rate in Table D in §1.664–4(e)(6) that corresponds to the number of years in the term. * * *

• ---

(6) Actuarial tables for transfers for which the valuation date is after Novem- ber 30, 1983, and before May 1, 1989. Table D in §1.664–4(e)(6) and the following tables shall be used in the application of the provisions of this section:

• ---

(e) Valuation of charitable remainder unitrusts having certain payout sequences for transfers for which the valuation date is after April 30, 1989, and before May 1, 1999 —(1) In general. Except as otherwise provided in paragraph (e)(2) of this section, in the case of transfers for which the valuation date is after April 30, 1989, and before May 1, 1999, the present value of a remainder interest is determined under paragraphs (e)(3) through (e)(6) of this section, provided that the amount of the payout as of any payout date during any taxable year of the trust is not larger than the amount that the trust could distribute on such date under §1.6643(a)(1)(v) if the taxable year of the trust were to end on such date. * * *

• ---

(3) Adjusted payout rate. For transfers for which the valuation date is after April 30, 1989, and before May 1, 1999, the adjusted payout rate is determined by using the appropriate Table F, contained in § 1.664–4(e)(6), for the section 7520 interest rate applicable to the transfer. If the interest rate is between 4.2 and 14 percent, see §1.664–4(e)(6). If the interest rate is below 4.2 percent or greater than 14 percent, see §1.664–4(b). See §1.664– 4(e) for rules applicable in determining the adjusted payout rate.

(4) Period is a term of years. If the period described in §1.664–3(a)(5) is a term of years, the factor that is used in determining the present value of the remainder interest for transfers for which the valuation date is after April 30, 1989, and before May 1, 1999, is the factor under the appropriate adjusted payout rate in Table D in §1.664–4(e)(6) corresponding to the number of years in the term. If the adjusted payout rate is an amount that is between adjusted payout rates for which factors are provided in Table D, a linear

interpolation must be made. The present value of the remainder interest is determined by multiplying the net fair market value (as of the appropriate valuation date) of the property placed in trust by the factor determined under this paragraph. Generally, for purposes of this section, the valuation date is, in the case of an inter vivos transfer, the date on which the property is transferred to the trust by the donor, and, in the case of a testamentary transfer under sections 2055, 2106, or 2624, the valuation date is the date of death. See §1.664– 4T(e)(4) for additional rules regarding the valuation date. See §1.664–4T(e)(4) for an example that illustrates the application of this paragraph (e)(4).

(5) Period is the life of one individual. If the period described in §1.664–3(a)(5) is the life of one individual, the factor that is used in determining the present value of the remainder interest for transfers for which the valuation date is after April 30, 1989, and before May 1, 1999, is the factor in Table U(1) in paragraph (e)(6) of this section under the appropriate adjusted payout. For purposes of the computations described in this paragraph (e)(5), the age of an individual is the age of that individual at the individual’s nearest birthday. If the adjusted payout rate is an amount that is between adjusted payout rates for which factors are provided in the appropriate table, a linear interpolation must be made. The rules provided in §1.664– 4T(e)(5) apply for determining the present value of the remainder interest. See §1.664–4T(e)(5) for an example illustrating the application of this paragraph (e)(5)(using current actuarial tables).

(6) Actuarial tables for transfers for which the valuation date is after April 30, 1989, and before May 1, 1999. For transfers for which the valuation date is after April 30, 1989, and before May 1, 1999, the present value of a charitable remainder unitrust interest that is dependent on a term of years or the termination of a life interest is determined by using the section 7520 rate and Table D, Tables F(4.2) through F(14.0) in §1.664–4(e)(6) and Table U(1) of this paragraph (e)(6), as applicable. * * * Publication 1458 is no longer available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402. However, pertinent factors in this publication may be obtained by a

1999–20 I.R.B. 43 May 17, 1999

(iii) Internal Revenue Service Publication 1459, “Actuarial Values, Gamma Volume,” (8-89). * * *

(d) Effective date. This section applies after April 30, 1989, and before May 1, 1999. Par. 13. Section 1.7520–1T is added to read as follows:

§1.7520–1T Valuation of annuities, unitrust interests, interests for life or terms of years, and remainder or reversionary interests (temporary).

(a) through (b)(1) [Reserved] For further guidance, see §1.7520–1(a) through (b)(1).

(2) Mortality component. The mortality component reflects the mortality data most recently available from the United States census. As new mortality data becomes available after each decennial census, the mortality component described in this section will be revised periodically and the revised mortality component tables will be published in the regulations at that time. For transactions with valuation dates after April 30, 1999, the mortality component table (Table 90CM) is contained in §20.2031–7T(d)(7) of this chapter. See §20.2031–7A of this chapter for mortality component tables applicable to transactions for which the valuation date falls before May 1, 1999.

(c) [Reserved]. For further guidance, see §1.7520–1(c).

(1) Regulation sections containing ta- bles with interest rates between 4.2 and 14 percent for valuation dates after April 30, 1999. Section 1.642(c)–6T(e)(6) contains Table S used for determining the present value of a single life remainder interest in a pooled income fund as defined in §1.642(c)–5. See §1.642(c)–6A for actuarial factors for one life applicable to valuation dates before May 1, 1999. Section 1.664–4(e)(6) contains Table F (payout factors) and Table D (actuarial factors used in determining the present value of a remainder interest postponed for a term of years). Section1.664–4T(e)(7) contains Table U(1) (actuarial factors for one life). These tables are used in determining the present value of a remainder interest in a charitable remainder unitrust as defined in §1.664–3. See §1.664–4A for actuarial factors for one life applicable to valuation dates before May 1, 1999. Section 20.2031–7(d)(6) of this chapter contains

Table B (actuarial factors used in determining the present value of an interest for a term of years), Table K (annuity end-ofinterval adjustment factors), and Table J (term certain annuity beginning-of-interval adjustment factors). Section 20.2031– 7T(d)(7) of this chapter contains Table S (actuarial factors for one life), and Table 90CM (mortality components). These tables are used in determining the present value of annuities, life estates, remainders, and reversions. See §20.2031–7A of this chapter for actuarial factors for one life and mortality components applicable to valuation dates before May 1, 1999.

(2) Internal Revenue Service publica- tions containing tables with interest rates between 2.2 and 26 percent for valuation dates after April 30, 1999. The following documents are available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402:

(i) Internal Revenue Service Publication 1457, “Actuarial Values, Book Aleph,” (1999). This publication includes tables of valuation factors, as well as examples that show how to compute other valuation factors, for determining the present value of annuities, life estates, terms of years, remainders, and reversions, measured by one or two lives. These factors may also be used in the valuation of interests in a charitable remainder annuity trust as defined in §1.664–2 and a pooled income fund as defined in §1.642(c)–5.

(ii) Internal Revenue Service Publication 1458, “Actuarial Values, Book Beth,” (1999). This publication includes term certain tables and tables of one and two life valuation factors for determining the present value of remainder interests in a charitable remainder unitrust as defined in §1.664–3.

(iii) Internal Revenue Service Publication 1459, “Actuarial Values, Book Gimel,” (1999). This publication includes tables for computing deprecation adjustment factors. See §1.170A–12T.

(d) Effective date. This section applies after April 30, 1999.

PART 20—ESTATE TAX; ESTATES OF DECEDENTS DYING AFTER AUGUST 16, 1954

Par. 14. The authority citation for part 20 is amended by adding entries in numerical order to read in part as follows:

Authority: 26 U.S.C. 7805 * * * Section 20.2031–7T also issued under 26 U.S.C. 7520(c)(2). * * * Section 20.7520–1T also issued under 26 U.S.C. 7520(c)(2). * * *

Par. 15. Section 20.2031–0 is revised to read as follows:

§20.2031–0 Table of contents.

This section lists the section headings and undesignated center headings that appear in the regulations under section 2031. §20.2031–1 Definition of gross estate; valuation of property. §20.2031–2 Valuation of stocks and bonds. §20.2031–3 Valuation of interests in businesses. §20.2031–4 Valuation of notes. §20.2031–5 Valuation of cash on hand or on deposit. §20.2031–6 Valuation of household and personal effects. §20.2031–7 Valuation of annuities, interests for life or term of years, and remainder or reversionary interests. §20.2031–7T Valuation of annuities, interests for life or term of years, and remainder or reversionary interests (temporary). §20.2031–8 Valuation of certain life insurance and annuity contracts; valuation of shares in an open-end investment company. §20.2031–9 Valuation of other property.

Actuarial Tables Applicable Before

May 1, 1999

§20.2031–7A Valuation of annuities, interests for life or term of years, and remainder or reversionary interests for estates of decedents for which the valuation date of the gross estate is before May 1, 1999. Par. 16. The undesignated centerheading immediately following §20.2046-1is revised to read as follows:

Actuarial Tables Applicable Before

May 1, 1999

Par. 17. Section 20.2031–7A is amended by:

1. Revising the section heading.
2. Adding paragraph (e). The revision and addition read as follows:

May 17, 1999 44 1999–20 I.R.B.

• ---

Table 80CNSMT.–Applicable After April

30, 1989, and Before May 1, 1999

• ---

Par. 18. Section 20.2031-7 is amended by:

1. Revising the section heading.

2. Revising paragraphs (c) through (d)(5).

3. Revising paragraph (d)(6) heading and introductory text.

4. Revising paragraph (e). The revisions read as follows:

§20.2031–7 Valuation of annuities, interests for life or term of years, and remainder or reversionary interests.

• ---

(c) through (d)(5) [Reserved]. For further guidance, see §20.2031–7T(c) through (d)(5).

(d)(6) Actuarial Table B, Table J, and Table K where the valuation date is after April 30, 1989. Except as provided in §20.7520–3(b) (pertaining to certain limitations on prescribed tables), the tables in this paragraph (d)(6) and either Table S and Table 80CNSMT in §20.2031– 7A(e)(4) (for valuation dates after April 30, 1989, and before May 1, 1999), or Table S and Table 90CM in §20.2031– 7T(d)(7) (for valuation dates after May 1, 1999) must be used in the application of the provisions of this section when the section 7520 interest rate component is between 4.2 and 14 percent.

• ---

(e) Effective date. This section applies after April 30, 1989, and before May 1, 1999. Par. 19. Section 20.2031–7T is added to read as follows:

§20.2031–7A Valuation of annuities, interests for life or term of years, and remainder or reversionary interests for estates of decedents for which the valuation date of the gross estate is before May 1, 1999.

• ---

(e) Valuation of annuities, interests for life or term of years, and remainder or re- versionary interests for estates of dece- dents for which the valuation date of the gross estate is after April 30,1989, and before May 1, 1999 —(1) In general. Except as otherwise provided in §20.2031– 7(b) and §20.7520–3(b) (pertaining to certain limitations on the use of prescribed tables), if the valuation date for the gross estate of the decedent is after April 30, 1989, and before May 1, 1999, the fair market value of annuities, life estates, terms of years, remainders, and reversionary interests is the present value of the interests determined by use of standard or special section 7520 actuarial factors and the valuation methodology described in §20.2031–7T(d). These factors are derived by using the appropriate section 7520 interest rate and, if applicable, the mortality component for the valuation date of the interest that is being valued. See §§20.7520–1 through 20.7520–4. See paragraph (e)(4) of this section for determination of the appropriate table for use in valuing these interests.

(2) Transitional rule. (i) If the valuation date is after April 30, 1989, and before June 10, 1994, a taxpayer can rely on Notice 89–24 (1989–1 C.B. 660), or Notice 89–60 (1989–1 C.B. 700 ). See §601.601(d)(2)(ii)( b ) of this chapter.

(ii) If a decedent dies after April 30, 1989, and if on May 1, 1989, the decedent was mentally incompetent so that the disposition of the decedent’s property could not be changed, and the decedent dies without having regained competency to dispose of the decedent’s property or dies within 90 days of the date on which the decedent first regains competency, the fair market value of annuities, life estates, terms for years, remainders, and reversions included in the gross estate of the decedent is their present value determined either under this section or under the corresponding section applicable at the time the decedent became mentally incompe

tent, at the option of the decedent’s executor. For example, see paragraph (d) of this section.

(3) Publications and actuarial compu- tations by the Internal Revenue Service. Many standard actuarial factors not included in paragraph (e)(4) of this section or in §20.2031–7(d)(6) are included in Internal Revenue Service Publication 1457, “Actuarial Values, Alpha Volume,” (889). Publication 1457 also includes examples that illustrate how to compute many special factors for more unusual situations. Publication 1457 is no longer available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402. However, pertinent factors in this publication may be obtained from: CC:DOM:CORP:R (IRS Publication 1457), room 5226, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044. If a special factor is required in the case of an actual decedent, the Internal Revenue Service may furnish the factor to the executor upon a request for a ruling. The request for a ruling must be accompanied by a recitation of the facts including a statement of the date of birth for each measuring life, the date of the decedent’s death, any other applicable dates, and a copy of the will, trust, or other relevant documents. A request for a ruling must comply with the instructions for requesting a ruling published periodically in the Internal Revenue Bulletin (see §§601.201 and 601.601(d)(2)(ii)(b) of this chapter) and include payment of the required user fee.

(4) Actuarial tables. Except as provided in §20.7520–3(b) (pertaining to certain limitations on the use of prescribed tables), Life Table 80CNSMT and Table S (Single life remainder factors applicable where the valuation date is after April 30, 1989, and before May 1, 1999), contained in this paragraph (b)(4), and Table B, Table J, and Table K set forth in §20.2031–7(d)(6) must be used in the application of the provisions of this section when the section 7520 interest rate component is between 4.2 and 14 percent. Table S and Table 80CNSMT are as follows:

Par. 17a. Section 20.2031–7A is further amended by redesignating Table S and Table 80CNSMT in §20.2031–

7(d)(6) as Table S and Table 80CNSMT in §20.2031–7A(e)(4) and revising the table headings to read as follows:

• ---

(e) * * * (4) * * *

Table S.–Based on Life on Life Table

80CNSMT Single Life Remainder Factors

[Applicable After April 30, 1989, and

Before May 1, 1999]

1999–20 I.R.B. 45 May 17, 1999

cally. This actuarial factor may be derived by subtracting the correlative remainder factor (that corresponds to the applicable section 7520 interest rate and the term of years or the life) in Table B (for a term of years) in §20.2031–7(d)(6) or in Table S (for the life of one individual) in paragraph (d)(7) of this section, as the case may be, from 1.000000. For information about obtaining actuarial factors for other types of term-of-years and life interests, see paragraph (d)(4) of this section.

(iv) Annuities. (A) If the interest to be valued is the right of a person to receive an annuity that is payable at the end of each year for a term of years or for the life of one individual, the present value of the interest is computed by multiplying the aggregate amount payable annually by the appropriate annuity actuarial factor (that corresponds to the applicable section 7520 interest rate and annuity period). Internal Revenue Publication 1457 includes actuarial factors in Table B (for an annuity payable for a term of years) and in Table S (for an annuity payable for the life of one individual when the valuation date is after April 30, 1999). However, annuity actuarial factors are not included in Table B in §20.2031–7(d)(6) or Table S in paragraph (d)(7) of this section. If Internal Revenue Service Publication 1457 (or any other reliable source of annuity actuarial factors) is not conveniently available, a required annuity factor for a term of years or for one life may be mathematically derived. This annuity factor may be derived by subtracting the applicable remainder factor (that corresponds to the applicable section 7520 interest rate and annuity period) in Table B (in the case of a term-of-years annuity) in §20.2031–7(d)(6) or in Table S (in the case of a one-life annuity when the valuation date is after April 30, 1999) in paragraph (d)(7) of this section, as the case may be, from 1.000000 and then dividing the result by the applicable section 7520 interest rate expressed as a decimal number.

(B) If the annuity is payable at the end of semiannual, quarterly, monthly, or weekly periods, the product obtained by multiplying the annuity factor by the aggregate amount payable annually is then multiplied by the applicable adjustment factor as contained in Table K in §20.2031–7(d)(6) for payments made at

§20.2031–7T Valuation of annuities, interests for life or term of years, and remainder or reversionary interests (temporary).

(a) through (b) [Reserved]. For further information see §20.2031–7(a) through (b).

(c) Actuarial valuations. The present value of annuities, life estates, terms of years, remainders, and reversions for estates of decedents for which the valuation date of the gross estate is after April 30, 1999, is determined under paragraph (d) of this section. The present value of annuities, life estates, terms of years, remainders, and reversions for estates of decedents for which the valuation date of the gross estate is before May 1, 1999, is determined under the following sections:

Valuation Date Applicable After Before Section

• 01-01-52 20.2031–7A(a) 12-31-51 01-01-71 20.2031–7A(b) 12-31-70 12-01-83 20.2031–7A(c) 11-30-83 05-01-89 20.2031–7A(d) 04-30-89 05-01-99 20.2031–7A(e)

(d) Actuarial valuations after April 30, 1999 —(1) In general. Except as otherwise provided in paragraph (b) of this section and §20.7520-3(b) (pertaining to certain limitations on the use of prescribed tables), if the valuation date for the gross estate of the decedent is after April 30, 1999, the fair market value of annuities, life estates, terms of years, remainders, and reversionary interests is the present value determined by use of standard or special section 7520 actuarial factors. These factors are derived by using the appropriate section 7520 interest rate and, if applicable, the mortality component for the valuation date of the interest that is being valued. See §§20.7520–1 through 20.7520–4. (2) Specific interests —(i) Charitable remainder trusts. The fair market value of a remainder interest in a pooled income fund, as defined in §1.642(c)–5 of this chapter, is its value determined under §1.642(c)–6T(e) of this chapter. The fair market value of a remainder interest in a charitable remainder annuity trust, as defined in §1.664–2(a) of this chapter, is the present value determined under §1.664– 2(c) of this chapter. The fair market value of a remainder interest in a charitable re

mainder unitrust, as defined in §1.664–3 of this chapter, is its present value determined under §1.664–4T(e) of this chapter. The fair market value of a life interest or term of years in a charitable remainder unitrust is the fair market value of the property as of the date of valuation less the fair market value of the remainder interest on that date determined under §1.664–4T(e)(4) and (5) of this chapter.

(ii) Ordinary remainder and reversion- ary interests. If the interest to be valued is to take effect after a definite number of years or after the death of one individual, the present value of the interest is computed by multiplying the value of the property by the appropriate remainder interest actuarial factor (that corresponds to the applicable section 7520 interest rate and remainder interest period) in Table B (for a term certain) or the appropriate Table S (for one measuring life), as the case may be. Table B is contained in §20.2031–7(d)(6) and Table S (for one measuring life when the valuation date is after April 30, 1999) is contained in paragraph (d)(7) of this section and in Internal Revenue Service Publication 1457. For information about obtaining actuarial factors for other types of remainder interests, see paragraph (d)(4) of this section.

(iii) Ordinary term-of-years and life in- terests. If the interest to be valued is the right of a person to receive the income of certain property, or to use certain nonincome-producing property, for a term of years or for the life of one individual, the present value of the interest is computed by multiplying the value of the property by the appropriate term-of-years or life interest actuarial factor (that corresponds to the applicable section 7520 interest rate and term-of-years or life interest period). Internal Revenue Service Publication 1457 includes actuarial factors for an interest for a term of years in Table B and for the life of one individual in Table S (for one measuring life when the valuation date is after April 30, 1999). However, term-of-years and life interest actuarial factors are not included in Table B in §20.2031–7(d)(6) or Table S in paragraph (d)(7) of this section. If Internal Revenue Service Publication 1457 (or any other reliable source of term-of-years and life interest actuarial factors) is not conveniently available, an actuarial factor for the interest may be derived mathemati

May 17, 1999 46 1999–20 I.R.B.

in the case of an actual decedent, the Internal Revenue Service may furnish the factor to the executor upon a request for a ruling. The request for a ruling must be accompanied by a recitation of the facts including a statement of the date of birth for each measuring life, the date of the decedent’s death, any other applicable dates, and a copy of the will, trust, or other relevant documents. A request for a ruling must comply with the instructions for requesting a ruling published periodically in the Internal Revenue Bulletin (see §§601.201 and 601.601(d)(2)(ii)( b ) of this chapter) and include payment of the required user fee.

(5) Examples. The provisions of this section are illustrated by the following examples:

Example 1. Remainder payable at an individ- ual’s death. The decedent, or the decedent’s estate, was entitled to receive certain property worth $50,000 upon the death of A, to whom the income was bequeathed for life. At the time of the decedent’s death, A was 47 years 5 months old. In the month in which the decedent died, the section 7520 rate was 9.8 percent. Under Table S in paragraph (d)(7) of this section, the remainder factor at 9.8 percent for determining the present value of the remainder interest due at the death of a person aged 47, the number of years nearest A’s actual age at the decedent’s death, is .10317. The present value of the remainder interest at the date of the decedent’s death is, therefore, $5,158.50 ($50,000 � .10317).

Example 2. Income payable for an individual’s life. A’s parent bequeathed an income interest in property to A for life, with the remainder interest passing to B at A’s death. At the time of the parent’s death, the value of the property was $50,000 and A was 30 years 10 months old. The section 7520 rate at the time of the parent’s death was 10.2 percent. Under Table S in paragraph (d)(7) of this section, the remainder factor at 10.2 percent for determining the present value of the remainder interest due at the death of a person aged 31, the number of years closest to A’s age at the decedent’s death, is .03583. Converting this remainder factor to an income factor, as described in paragraph (d)(2)(iii) of this section, the factor for determining the present value of an income interest for the life of a person aged 31 is .96417. The present value of A’s interest at the time of the parent’s death is, therefore, $48,208.50 ($50,000 � .96417).

Example 3. Annuity payable for an individual’s life. A purchased an annuity for the benefit of both A and B. Under the terms of the annuity contract, at A’s death, a survivor annuity of $10,000 a year payable in equal semiannual installments made at the end of each interval is payable to B for life. At A’s death, B was 45 years 7 months old. Also, at A’s death, the section 7520 rate was 9.6 percent. Under Table S in paragraph (d)(7) of this section, the factor at 9.6 percent for determining the present value of the remainder interest at the death of a person age 46 (the number of years nearest B’s actual age) is

the end of the specified periods. The provisions of this paragraph (d)(2)(iv)(B) are illustrated by the following example:

Example. At the time of the decedent’s death, the survivor/annuitant, age 72, is entitled to receive an annuity of $15,000 a year for life payable in equal monthly installments at the end of each period. The section 7520 rate for the month in which the decedent died is 9.6 percent. Under Table S in paragraph (d)(7) of this section, the remainder factor at 9.6 percent for an individual aged 72 is .38438. By converting the remainder factor to an annuity factor, as described above, the annuity factor at 9.6 percent for an individual aged 72 is 6.4127 (1.00000 minus .38438, divided by .096). Under Table K in §20.2031–7(d)(6), the adjustment factor under the column for payments made at the end of each monthly period at the rate of 9.6 percent is 1.0433. The aggregate annual amount, $15,000, is multiplied by the factor 6.4127 and the product multiplied by 1.0433. The present value of the annuity at the date of the decedent’s death is, therefore, $100,355.55 ($15,000 � 6.4127 � 1.0433).

(C) If an annuity is payable at the beginning of annual, semiannual, quarterly, monthly, or weekly periods for a term of years, the value of the annuity is computed by multiplying the aggregate amount payable annually by the annuity factor described in paragraph (d)(2)(iv)(A) of this section; and the product so obtained is then multiplied by the adjustment factor in Table J in §20.2031– 7(d)(6) at the appropriate interest rate component for payments made at the beginning of specified periods. If an annuity is payable at the beginning of annual, semiannual, quarterly, monthly, or weekly periods for one or more lives, the value of the annuity is the sum of the first payment plus the present value of a similar annuity, the first payment of which is not to be made until the end of the payment period, determined as provided in this paragraph (d)(2)(iv).

(v) Annuity and unitrust interests for a term of years or until the prior death of an individual. See §25.2512–5T(d)(2)(v) of this chapter for examples explaining how to compute the present value of an annuity or unitrust interest that is payable until the earlier of the lapse of a specific number of years or the death of an individual.

(3) Transitional rule. (i) If a decedent dies after April 30, 1999, and if on May 1, 1999, the decedent was mentally incompetent so that the disposition of the decedent’s property could not be changed, and the decedent dies without having regained

competency to dispose of the decedent’s property or dies within 90 days of the date on which the decedent first regains competency, the fair market value of annuities, life estates, terms for years, remainders, and reversions included in the gross estate of the decedent is their present value determined either under this section or under the corresponding section applicable at the time the decedent became mentally incompetent, at the option of the decedent’s executor. For example, see §20.2031–7A(e)(2).

(ii) If a decedent dies after April 30, 1999, and before July 1, 1999, the fair market value of annuities, life estates, remainders, and reversions based on one or more measuring lives included in the gross estate of the decedent is their present value determined under this section by use of the section 7520 interest rate for the month in which the valuation date occurs (See §§20.7520–1(b) and 20.7520– 2(a)(2)) and the appropriate actuarial tables under either paragraph (d)(7) of this section or §20.2031–7A(e)(4), at the option of the decedent’s executor.

(iii) For purposes of paragraphs (d)(3)(i) and (ii) of this section, where the decedent’s executor is given the option to use the appropriate actuarial tables under either paragraph (d)(7) of this section or §20.2031–7A(e)(4), the decedent’s executor must use the same actuarial table with respect to each individual transaction and with respect to all transfers occurring on the valuation date (e.g., gift and income tax charitable deductions with respect to the same transfer must be determined based on the same tables, and all assets includible in the gross estate and/or estate tax deductions claimed must be valued based on the same tables).

(4) Publications and actuarial compu- tations by the Internal Revenue Service. Many standard actuarial factors not included in §20.2031–7(d)(6) or in paragraph (d)(7) of this section are included in Internal Revenue Service Publication 1457, “Actuarial Values, Book Aleph,” (1999). Publication 1457 also includes examples that illustrate how to compute many special factors for more unusual situations. A copy of this publication is available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402. If a special factor is required

1999–20 I.R.B. 47 May 17, 1999

(7) Actuarial Table S and Table 90CM where the valuation date is after April 30, 1999. Except as provided in §20.7520– 2(b) (pertaining to certain limitations on the use of prescribed tables), the following Table 90CM and Table S (single life remainder factors applicable where the valuation date is after April 30, 1999) and Table B, Table J, and Table K contained in §20.2031–7(d)(6), must be used in the application of the provisions of this section when the section 7520 interest rate component is between 4.2 and 14 percent.

.10013. By converting the factor to an annuity factor, as described in paragraph (d)(2)(iv)(A) of this section, the factor for the present value of an annuity payable until the death of a person age 46 is 9.3736 (1.00000 minus .10013, divided by .096). The adjustment factor from Table K in §20.2031–7(d)(6) at an interest rate of 9.6 percent for semiannual annuity payments made at the end of the period is 1.0235. The present value of the annuity at the date of A’s death is, therefore, $95,938.80 ($10,000 - 9.3736

• 1.0235). Example 4. Annuity payable for a term of years. The decedent, or the decedent’s estate, was entitled to receive an annuity of $10,000 a year payable in equal quarterly installments at the end of each quarter throughout a term certain. At the time of the decedent’s death, the section 7520 rate was 9.8 per

cent. A quarterly payment had just been made prior to the decedent’s death and payments were to continue for 5 more years. Under Table B in §20.2031– 7(d)(6) for the interest rate of 9.8 percent, the factor for the present value of a remainder interest due after a term of 5 years is .626597. Converting the factor to an annuity factor, as described in paragraph (d)(2)(iv)(A) of this section, the factor for the present value of an annuity for a term of 5 years is 3.8102. The adjustment factor from Table K in §20.2031– 7(d)(6) at an interest rate of 9.8 percent for quarterly annuity payments made at the end of the period is 1.0360. The present value of the annuity is, therefore, $39,473.67 ($10,000 � 3.8102 � 1.0360).

(6) [Reserved]. For further guidance, see §20.2031–7(d)(6).

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

0 .06752 .06130 .05586 .05109 .04691 .04322 .03998 .03711 .03458 .03233 1 .06137 .05495 .04932 .04438 .04003 .03620 .03283 .02985 .02721 .02487 2 .06325 .05667 .05088 .04580 .04132 .03737 .03388 .03079 .02806 .02563 3 .06545 .05869 .05275 .04752 .04291 .03883 .03523 .03203 .02920 .02668 4 .06784 .06092 .05482 .04944 .04469 .04048 .03676 .03346 .03052 .02791

5 .07040 .06331 .05705 .05152 .04662 .04229 .03845 .03503 .03199 .02928 6 .07310 .06583 .05941 .05372 .04869 .04422 .04025 .03672 .03357 .03076 7 .07594 .06849 .06191 .05607 .05089 .04628 .04219 .03854 .03528 .03236 8 .07891 .07129 .06453 .05853 .05321 .04846 .04424 .04046 .03709 .03407 9 .08203 .07423 .06731 .06115 .05567 .05079 .04643 .04253 .03904 .03592

10 .08532 .07734 .07024 .06392 .05829 .05326 .04877 .04474 .04114 .03790 11 .08875 .08059 .07331 .06683 .06104 .05587 .05124 .04709 .04336 .04002 12 .09233 .08398 .07653 .06989 .06394 .05862 .05385 .04957 .04572 .04226 13 .09601 .08748 .07985 .07304 .06693 .06146 .05655 .05214 .04816 .04458 14 .09974 .09102 .08322 .07624 .06997 .06435 .05929 .05474 .05064 .04694

15 .10350 .09460 .08661 .07946 .07303 .06725 .06204 .05735 .05312 .04930 16 .10728 .09818 .09001 .08268 .07608 .07014 .06479 .05996 .05559 .05164 17 .11108 .10179 .09344 .08592 .07916 .07306 .06755 .06257 .05807 .05399 18 .11494 .10545 .09691 .08921 .08227 .07601 .07034 .06521 .06057 .05636 19 .11889 .10921 .10047 .09259 .08548 .07904 .07322 .06794 .06315 .05880

20 .12298 .11310 .10417 .09610 .08881 .08220 .07622 .07078 .06584 .06135 21 .12722 .11713 .10801 .09976 .09228 .08550 .07935 .07375 .06866 .06403 22 .13159 .12130 .11199 .10354 .09588 .08893 .08260 .07685 .07160 .06682 23 .13613 .12563 .11612 .10748 .09964 .09250 .08601 .08009 .07468 .06975 24 .14084 .13014 .12043 .11160 .10357 .09625 .08958 .08349 .07793 .07284

25 .14574 .13484 .12493 .11591 .10768 .10018 .09334 .08708 .08135 .07611 26 .15084 .13974 .12963 .12041 .11199 .10431 .09728 .09085 .08496 .07956 27 .15615 .14485 .13454 .12513 .11652 .10865 .10144 .09484 .08878 .08322 28 .16166 .15016 .13965 .13004 .12124 .11319 .10580 .09901 .09279 .08706 29 .16737 .15567 .14497 .13516 .12617 .11792 .11035 .10339 .09699 .09109

May 17, 1999 48 1999–20 I.R.B.

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

30 .17328 .16138 .15048 .14047 .13129 .12286 .11510 .10796 .10138 .09532 31 .17938 .16728 .15618 .14599 .13661 .12799 .12004 .11272 .10597 .09974 32 .18568 .17339 .16210 .15171 .14214 .13333 .12520 .11769 .11076 .10435 33 .19220 .17972 .16824 .15766 .14790 .13889 .13058 .12289 .11578 .10920 34 .19894 .18627 .17460 .16383 .15388 .14468 .13618 .12831 .12102 .11426

35 .20592 .19307 .18121 .17025 .16011 .15073 .14204 .13399 .12652 .11958 36 .21312 .20010 .18805 .17691 .16658 .15701 .14814 .13990 .13225 .12514 37 .22057 .20737 .19514 .18382 .17331 .16356 .15450 .14608 .13825 .13096 38 .22827 .21490 .20251 .19100 .18031 .17038 .16113 .15253 .14452 .13705 39 .23623 .22270 .21013 .19845 .18759 .17747 .16805 .15927 .15108 .14344

40 .24446 .23078 .21805 .20620 .19516 .18487 .17527 .16631 .15795 .15013 41 .25298 .23915 .22626 .21425 .20305 .19259 .18282 .17368 .16514 .15715 42 .26178 .24782 .23478 .22262 .21125 .20062 .19069 .18138 .17267 .16450 43 .27087 .25678 .24360 .23129 .21977 .20898 .19888 .18941 .18053 .17220 44 .28025 .26603 .25273 .24027 .22860 .21766 .20740 .19777 .18873 .18023

45 .28987 .27555 .26212 .24953 .23772 .22664 .21622 .20644 .19724 .18858 46 .29976 .28533 .27179 .25908 .24714 .23591 .22536 .21542 .20606 .19725 47 .30987 .29535 .28171 .26889 .25682 .24546 .23476 .22468 .21518 .20621 48 .32023 .30563 .29190 .27897 .26678 .25530 .24447 .23425 .22460 .21549 49 .33082 .31615 .30234 .28931 .27702 .26543 .25447 .24412 .23434 .22509

50 .34166 .32694 .31306 .29995 .28756 .27586 .26479 .25432 .24441 .23502 51 .35274 .33798 .32404 .31085 .29838 .28658 .27541 .26482 .25479 .24528 52 .36402 .34924 .33525 .32200 .30946 .29757 .28630 .27561 .26547 .25584 53 .37550 .36070 .34668 .33339 .32078 .30882 .29746 .28667 .27643 .26669 54 .38717 .37237 .35833 .34500 .33234 .32031 .30888 .29801 .28766 .27782

55 .39903 .38424 .37019 .35683 .34413 .33205 .32056 .30961 .29918 .28925 56 .41108 .39631 .38227 .36890 .35617 .34405 .33250 .32149 .31099 .30097 57 .42330 .40857 .39455 .38118 .36844 .35629 .34469 .33363 .32306 .31297 58 .43566 .42098 .40699 .39364 .38089 .36873 .35710 .34600 .33538 .32522 59 .44811 .43351 .41956 .40623 .39350 .38133 .36968 .35855 .34789 .33768

60 .46066 .44613 .43224 .41896 .40624 .39408 .38243 .37127 .36058 .35033 61 .47330 .45887 .44505 .43182 .41914 .40699 .39535 .38418 .37347 .36318 62 .48608 .47175 .45802 .44485 .43223 .42011 .40848 .39732 .38660 .37629 63 .49898 .48478 .47115 .45807 .44550 .43343 .42184 .41069 .39997 .38966 64 .51200 .49793 .48442 .47143 .45895 .44694 .43539 .42427 .41357 .40326

65 .52512 .51121 .49782 .48495 .47255 .46062 .44912 .43805 .42738 .41709 66 .53835 .52461 .51137 .49862 .48634 .47449 .46307 .45206 .44143 .43118 67 .55174 .53818 .52511 .51250 .50034 .48860 .47727 .46633 .45576 .44556 68 .56524 .55188 .53899 .52654 .51452 .50291 .49168 .48083 .47034 .46020 69 .57882 .56568 .55299 .54071 .52885 .51737 .50627 .49552 .48513 .47506 70 .59242 .57951 .56703 .55495 .54325 .53193 .52096 .51034 .50004 .49007

1999–20 I.R.B. 49 May 17, 1999

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

71 .60598 .59332 .58106 .56918 .55767 .54651 .53569 .52520 .51503 .50516 72 .61948 .60707 .59504 .58338 .57206 .56108 .55043 .54009 .53004 .52029 73 .63287 .62073 .60895 .59751 .58640 .57561 .56513 .55495 .54505 .53543 74 .64621 .63435 .62282 .61162 .60073 .59015 .57985 .56984 .56009 .55061

75 .65953 .64796 .63671 .62575 .61510 .60473 .59463 .58480 .57523 .56591 76 .67287 .66160 .65063 .63995 .62954 .61940 .60952 .59989 .59050 .58135 77 .68622 .67526 .66459 .65419 .64404 .63415 .62450 .61509 .60590 .59694 78 .69954 .68892 .67856 .66845 .65858 .64895 .63955 .63036 .62140 .61264 79 .71278 .70250 .69246 .68265 .67308 .66372 .65457 .64563 .63690 .62836

80 .72581 .71588 .70618 .69668 .68740 .67833 .66945 .66077 .65227 .64396 81 .73857 .72899 .71962 .71045 .70147 .69268 .68408 .67566 .66741 .65933 82 .75101 .74178 .73274 .72389 .71522 .70672 .69840 .69024 .68225 .67441 83 .76311 .75423 .74553 .73700 .72864 .72044 .71240 .70451 .69678 .68919 84 .77497 .76645 .75809 .74988 .74183 .73393 .72618 .71857 .71110 .70377

85 .78665 .77848 .77047 .76260 .75487 .74728 .73982 .73250 .72530 .71823 86 .79805 .79025 .78258 .77504 .76764 .76036 .75320 .74617 .73925 .73245 87 .80904 .80159 .79427 .78706 .77998 .77301 .76615 .75940 .75277 .74624 88 .81962 .81251 .80552 .79865 .79188 .78521 .77865 .77220 .76584 .75958 89 .82978 .82302 .81636 .80980 .80335 .79699 .79072 .78455 .77847 .77248

90 .83952 .83309 .82676 .82052 .81437 .80831 .80234 .79645 .79064 .78492 91 .84870 .84260 .83658 .83064 .82479 .81902 .81332 .80771 .80217 .79671 92 .85716 .85136 .84563 .83998 .83441 .82891 .82348 .81812 .81283 .80761 93 .86494 .85942 .85396 .84858 .84326 .83801 .83283 .82771 .82266 .81767 94 .87216 .86690 .86170 .85657 .85149 .84648 .84153 .83664 .83181 .82704

95 .87898 .87397 .86902 .86412 .85928 .85450 .84977 .84510 .84049 .83592 96 .88537 .88060 .87587 .87121 .86659 .86203 .85751 .85305 .84864 .84427 97 .89127 .88672 .88221 .87775 .87335 .86898 .86467 .86040 .85618 .85200 98 .89680 .89245 .88815 .88389 .87968 .87551 .87138 .86730 .86326 .85926 99 .90217 .89803 .89393 .88987 .88585 .88187 .87793 .87402 .87016 .86633

100 .90738 .90344 .89953 .89567 .89183 .88804 .88428 .88056 .87687 .87322 101 .91250 .90876 .90504 .90137 .89772 .89412 .89054 .88699 .88348 .88000 102 .91751 .91396 .91045 .90696 .90350 .90007 .89668 .89331 .88997 .88666 103 .92247 .91912 .91579 .91249 .90922 .90598 .90276 .89957 .89640 .89326 104 .92775 .92460 .92148 .91839 .91532 .91227 .90924 .90624 .90326 .90031

105 .93290 .92996 .92704 .92415 .92127 .91841 .91558 .91276 .90997 .90719 106 .93948 .93680 .93415 .93151 .92889 .92628 .92370 .92113 .91857 .91604 107 .94739 .94504 .94271 .94039 .93808 .93579 .93351 .93124 .92899 .92675 108 .95950 .95767 .95585 .95404 .95224 .95045 .94867 .94689 .94512 .94336 109 .97985 .97893 .97801 .97710 .97619 .97529 .97438 .97348 .97259 .97170

May 17, 1999 50 1999–20 I.R.B.

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0%

0 .03034 .02857 .02700 .02559 .02433 .02321 .02220 .02129 .02047 .01973 1 .02279 .02094 .01929 .01782 .01650 .01533 .01427 .01331 .01246 .01168 2 .02347 .02155 .01983 .01829 .01692 .01569 .01458 .01358 .01268 .01187 3 .02444 .02243 .02065 .01905 .01761 .01632 .01516 .01412 .01317 .01232 4 .02558 .02349 .02163 .01996 .01846 .01712 .01590 .01481 .01382 .01292

5 .02686 .02469 .02275 .02101 .01945 .01804 .01677 .01562 .01458 .01364 6 .02825 .02600 .02398 .02217 .02053 .01906 .01773 .01653 .01544 .01445 7 .02976 .02742 .02532 .02343 .02172 .02019 .01880 .01754 .01640 .01536 8 .03137 .02894 .02675 .02479 .02301 .02140 .01995 .01864 .01744 .01635 9 .03311 .03059 .02832 .02627 .02442 .02274 .02122 .01985 .01859 .01745

10 .03499 .03237 .03001 .02788 .02595 .02420 .02262 .02118 .01987 .01867 11 .03700 .03428 .03183 .02961 .02760 .02578 .02413 .02262 .02125 .02000 12 .03913 .03632 .03377 .03146 .02937 .02748 .02575 .02418 .02275 .02144 13 .04135 .03843 .03579 .03339 .03122 .02924 .02744 .02580 .02431 .02294 14 .04359 .04057 .03783 .03534 .03308 .03102 .02915 .02744 .02587 .02444

15 .04584 .04270 .03986 .03728 .03493 .03279 .03083 .02905 .02742 .02593 16 .04806 .04482 .04187 .03919 .03674 .03452 .03248 .03063 .02892 .02736 17 .05029 .04692 .04387 .04108 .03855 .03623 .03411 .03218 .03040 .02877 18 .05253 .04905 .04588 .04299 .04036 .03795 .03574 .03373 .03187 .03017 19 .05484 .05124 .04796 .04496 .04222 .03972 .03742 .03532 .03339 .03161

20 .05726 .05354 .05013 .04702 .04418 .04158 .03919 .03700 .03498 .03313 21 .05980 .05595 .05242 .04920 .04625 .04354 .04105 .03877 .03667 .03473 22 .06246 .05847 .05482 .05147 .04841 .04559 .04301 .04063 .03844 .03642 23 .06524 .06112 .05734 .05387 .05069 .04777 .04508 .04260 .04032 .03821 24 .06819 .06392 .06001 .05642 .05312 .05008 .04728 .04470 .04232 .04012

25 .07131 .06690 .06285 .05913 .05570 .05255 .04964 .04695 .04447 .04218 26 .07460 .07005 .06586 .06200 .05845 .05518 .05215 .04936 .04677 .04438 27 .07810 .07340 .06907 .06508 .06140 .05800 .05485 .05195 .04925 .04676 28 .08179 .07693 .07246 .06833 .06451 .06098 .05772 .05469 .05189 .04929 29 .08566 .08065 .07603 .07176 .06780 .06414 .06075 .05761 .05469 .05198

30 .08973 .08456 .07978 .07536 .07127 .06748 .06396 .06069 .05766 .05483 31 .09398 .08865 .08372 .07915 .07491 .07098 .06733 .06394 .06078 .05785 32 .09843 .09294 .08785 .08313 .07875 .07468 .07089 .06737 .06409 .06103 33 .10310 .09745 .09220 .08732 .08279 .07858 .07466 .07100 .06759 .06441 34 .10799 .10217 .09676 .09173 .08705 .08269 .07862 .07483 .07129 .06798

35 .11314 .10715 .10157 .09638 .09155 .08704 .08283 .07890 .07522 .07179 36 .11852 .11236 .10662 .10127 .09628 .09162 .08726 .08319 .07938 .07581 37 .12416 .11783 .11193 .10641 .10126 .09645 .09194 .08772 .08377 .08006 38 .13009 .12359 .11751 .11183 .10652 .10155 .09689 .09253 .08843 .08459 39 .13629 .12962 .12338 .11753 .11206 .10693 .10212 .09761 .09337 .08938

1999–20 I.R.B. 51 May 17, 1999

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0%

40 .14281 .13597 .12955 .12355 .11791 .11262 .10766 .10299 .09860 .09447 41 .14966 .14264 .13606 .12989 .12409 .11864 .11352 .10870 .10417 .09989 42 .15685 .14966 .14291 .13657 .13061 .12500 .11972 .11475 .11006 .10564 43 .16437 .15702 .15010 .14360 .13747 .13171 .12627 .12115 .11631 .11174 44 .17224 .16472 .15764 .15098 .14469 .13876 .13317 .12789 .12290 .11819

45 .18042 .17274 .16550 .15867 .15223 .14615 .14040 .13496 .12982 .12496 46 .18893 .18110 .17370 .16671 .16011 .15387 .14796 .14238 .13708 .13207 47 .19775 .18975 .18220 .17505 .16830 .16190 .15584 .15010 .14466 .13950 48 .20688 .19873 .19102 .18373 .17682 .17027 .16406 .15817 .15258 .14727 49 .21633 .20804 .20018 .19274 .18568 .17898 .17262 .16658 .16084 .15539

50 .22612 .21769 .20969 .20210 .19490 .18805 .18155 .17536 .16948 .16388 51 .23625 .22769 .21955 .21182 .20448 .19749 .19084 .18452 .17849 .17275 52 .24669 .23799 .22973 .22186 .21438 .20726 .20047 .19400 .18784 .18196 53 .25742 .24861 .24022 .23222 .22461 .21735 .21043 .20383 .19753 .19151 54 .26845 .25952 .25101 .24290 .23516 .22777 .22072 .21399 .20756 .20140

55 .27978 .27074 .26212 .25389 .24604 .23853 .23136 .22450 .21793 .21166 56 .29140 .28227 .27355 .26522 .25725 .24963 .24233 .23535 .22867 .22227 57 .30333 .29411 .28529 .27686 .26879 .26106 .25365 .24656 .23976 .23324 58 .31551 .30621 .29731 .28878 .28061 .27278 .26528 .25807 .25116 .24453 59 .32790 .31854 .30956 .30095 .29269 .28477 .27716 .26986 .26284 .25610

60 .34050 .33107 .32202 .31334 .30500 .29699 .28929 .28190 .27478 .26794 61 .35331 .34384 .33473 .32598 .31757 .30948 .30170 .29422 .28701 .28007 62 .36639 .35688 .34772 .33892 .33044 .32229 .31443 .30687 .29958 .29255 63 .37974 .37020 .36101 .35216 .34363 .33542 .32750 .31986 .31250 .30539 64 .39334 .38378 .37456 .36568 .35711 .34884 .34087 .33317 .32574 .31857

65 .40718 .39761 .38838 .37947 .37087 .36257 .35455 .34681 .33932 .33208 66 .42128 .41172 .40249 .39357 .38496 .37663 .36858 .36079 .35326 .34597 67 .43569 .42616 .41694 .40803 .39941 .39107 .38299 .37518 .36761 .36028 68 .45038 .44089 .43170 .42281 .41419 .40585 .39777 .38994 .38235 .37499 69 .46531 .45587 .44672 .43786 .42927 .42094 .41286 .40503 .39743 .39006 70 .48040 .47103 .46194 .45312 .44456 .43626 .42820 .42038 .41278 .40540

71 .49558 .48629 .47727 .46851 .46000 .45174 .44371 .43591 .42832 .42095 72 .51082 .50162 .49268 .48399 .47554 .46733 .45934 .45157 .44401 .43666 73 .52607 .51697 .50813 .49952 .49114 .48299 .47506 .46733 .45981 .45249 74 .54139 .53241 .52367 .51515 .50686 .49879 .49092 .48325 .47578 .46849

75 .55683 .54798 .53936 .53095 .52276 .51477 .50698 .49938 .49197 .48474 76 .57243 .56373 .55524 .54696 .53888 .53100 .52330 .51579 .50846 .50130 77 .58819 .57965 .57132 .56318 .55523 .54747 .53988 .53247 .52523 .51815 78 .60408 .59572 .58755 .57957 .57177 .56414 .55668 .54939 .54225 .53527 79 .62001 .61184 .60385 .59604 .58840 .58092 .57360 .56644 .55943 .55256

May 17, 1999 52 1999–20 I.R.B.

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0%

80 .63582 .62786 .62007 .61244 .60497 .59765 .59048 .58347 .57659 .56985 81 .65142 .64367 .63608 .62864 .62135 .61421 .60721 .60034 .59361 .58701 82 .66673 .65920 .65182 .64458 .63748 .63052 .62368 .61698 .61041 .60395 83 .68175 .67444 .66728 .66024 .65334 .64656 .63991 .63338 .62696 .62066 84 .69657 .68950 .68256 .67574 .66904 .66246 .65599 .64964 .64340 .63727

85 .71128 .70446 .69775 .69116 .68467 .67830 .67204 .66587 .65982 .65386 86 .72576 .71919 .71272 .70636 .70010 .69394 .68789 .68193 .67606 .67029 87 .73981 .73349 .72726 .72114 .71511 .70917 .70333 .69757 .69190 .68632 88 .75342 .74735 .74137 .73548 .72968 .72396 .71833 .71279 .70732 .70194 89 .76658 .76076 .75503 .74938 .74381 .73832 .73290 .72757 .72231 .71712

90 .77928 .77371 .76823 .76281 .75748 .75221 .74702 .74190 .73684 .73186 91 .79131 .78600 .78075 .77557 .77046 .76542 .76044 .75553 .75068 .74589 92 .80246 .79737 .79235 .78740 .78250 .77767 .77290 .76818 .76353 .75893 93 .81274 .80788 .80307 .79832 .79363 .78899 .78441 .77989 .77542 .77100 94 .82232 .81766 .81306 .80850 .80401 .79956 .79517 .79082 .78653 .78228

95 .83141 .82695 .82254 .81818 .81387 .80961 .80539 .80122 .79710 .79302 96 .83996 .83569 .83147 .82729 .82316 .81907 .81503 .81103 .80707 .80315 97 .84787 .84378 .83973 .83573 .83176 .82784 .82396 .82012 .81632 .81255 98 .85530 .85138 .84750 .84366 .83985 .83609 .83236 .82867 .82502 .82140 99 .86255 .85880 .85508 .85140 .84776 .84415 .84057 .83703 .83353 .83005

100 .86960 .86601 .86246 .85894 .85546 .85200 .84858 .84519 .84183 .83849 101 .87655 .87313 .86974 .86638 .86305 .85975 .85648 .85324 .85003 .84684 102 .88338 .88012 .87689 .87369 .87052 .86738 .86426 .86116 .85809 .85505 103 .89015 .88706 .88399 .88095 .87793 .87494 .87197 .86903 .86611 .86321 104 .89737 .89446 .89157 .88871 .88586 .88304 .88024 .87745 .87469 .87195

105 .90443 .90170 .89898 .89628 .89360 .89094 .88830 .88568 .88307 .88049 106 .91351 .91101 .90852 .90605 .90359 .90115 .89873 .89632 .89392 .89154 107 .92452 .92230 .92010 .91791 .91573 .91356 .91141 .90927 .90714 .90502 108 .94161 .93987 .93814 .93641 .93469 .93298 .93128 .92958 .92790 .92622 109 .97081 .96992 .96904 .96816 .96729 .96642 .96555 .96468 .96382 .96296

1999–20 I.R.B. 53 May 17, 1999

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0%

0 .01906 .01845 .01790 .01740 .01694 .01652 .01613 .01578 .01546 .01516 1 .01098 .01034 .00977 .00924 .00876 .00833 .00793 .00756 .00722 .00691 2 .01113 .01046 .00986 .00930 .00880 .00834 .00791 .00753 .00717 .00684 3 .01155 .01084 .01020 .00962 .00909 .00860 .00816 .00775 .00737 .00702 4 .01211 .01137 .01069 .01008 .00952 .00900 .00853 .00810 .00770 .00733

5 .01279 .01201 .01130 .01065 .01006 .00952 .00902 .00856 .00814 .00775 6 .01356 .01274 .01199 .01131 .01068 .01011 .00959 .00910 .00865 .00824 7 .01442 .01356 .01277 .01205 .01140 .01079 .01023 .00972 .00925 .00881 8 .01536 .01446 .01363 .01287 .01218 .01154 .01096 .01041 .00991 .00945 9 .01641 .01546 .01460 .01380 .01307 .01240 .01178 .01120 .01068 .01019

10 .01758 .01659 .01567 .01484 .01407 .01336 .01270 .01210 .01154 .01103 11 .01886 .01781 .01686 .01598 .01517 .01442 .01373 .01310 .01251 .01196 12 .02024 .01915 .01814 .01721 .01636 .01558 .01485 .01419 .01357 .01299 13 .02168 .02054 .01948 .01851 .01762 .01679 .01603 .01533 .01467 .01407 14 .02313 .02193 .02083 .01981 .01887 .01801 .01721 .01646 .01578 .01514

15 .02456 .02330 .02214 .02107 .02009 .01918 .01834 .01756 .01684 .01617 16 .02593 .02462 .02340 .02229 .02126 .02030 .01942 .01860 .01785 .01714 17 .02728 .02590 .02463 .02346 .02238 .02138 .02046 .01960 .01880 .01806 18 .02861 .02717 .02584 .02462 .02348 .02243 .02146 .02056 .01972 .01894 19 .02998 .02847 .02708 .02580 .02461 .02351 .02249 .02154 .02066 .01984

20 .03142 .02984 .02839 .02704 .02580 .02465 .02357 .02258 .02165 .02079 21 .03295 .03130 .02978 .02837 .02706 .02585 .02473 .02368 .02271 .02180 22 .03455 .03283 .03124 .02976 .02839 .02712 .02594 .02484 .02382 .02286 23 .03626 .03446 .03279 .03124 .02981 .02847 .02723 .02608 .02500 .02400 24 .03809 .03620 .03446 .03283 .03133 .02993 .02863 .02741 .02628 .02522

25 .04005 .03808 .03625 .03456 .03298 .03151 .03014 .02887 .02768 .02656 26 .04216 .04010 .03819 .03641 .03476 .03322 .03178 .03044 .02919 .02802 27 .04444 .04229 .04029 .03843 .03670 .03508 .03357 .03217 .03085 .02962 28 .04687 .04463 .04254 .04059 .03877 .03708 .03550 .03402 .03263 .03133 29 .04946 .04712 .04493 .04289 .04099 .03922 .03756 .03600 .03455 .03318

30 .05221 .04976 .04748 .04534 .04335 .04149 .03975 .03812 .03659 .03515 31 .05511 .05255 .05017 .04794 .04585 .04390 .04208 .04037 .03876 .03725 32 .05818 .05551 .05302 .05069 .04851 .04647 .04455 .04276 .04107 .03948 33 .06144 .05866 .05606 .05363 .05135 .04921 .04720 .04532 .04355 .04188 34 .06489 .06200 .05928 .05674 .05436 .05212 .05002 .04805 .04619 .04444

35 .06857 .06555 .06273 .06007 .05758 .05524 .05304 .05097 .04902 .04718 36 .07246 .06932 .06638 .06361 .06101 .05856 .05626 .05409 .05205 .05012 37 .07659 .07332 .07025 .06737 .06466 .06210 .05969 .05742 .05528 .05325 38 .08098 .07758 .07439 .07138 .06855 .06588 .06336 .06099 .05874 .05662 39 .08563 .08210 .07878 .07565 .07270 .06992 .06729 .06480 .06245 .06023

May 17, 1999 54 1999–20 I.R.B.

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0%

40 .09059 .08692 .08347 .08021 .07714 .07423 .07149 .06889 .06643 .06411 41 .09586 .09206 .08848 .08509 .08189 .07886 .07600 .07329 .07072 .06828 42 .10147 .09753 .09381 .09029 .08696 .08381 .08083 .07800 .07531 .07277 43 .10742 .10334 .09948 .09583 .09237 .08909 .08598 .08304 .08024 .07758 44 .11373 .10950 .10551 .10172 .09813 .09472 .09148 .08841 .08549 .08272

45 .12035 .11599 .11185 .10792 .10420 .10066 .09730 .09410 .09106 .08817 46 .12732 .12281 .11853 .11447 .11061 .10694 .10345 .10013 .09696 .09395 47 .13460 .12995 .12553 .12133 .11733 .11353 .10991 .10646 .10317 .10004 48 .14223 .13743 .13287 .12853 .12439 .12046 .11671 .11313 .10972 .10646 49 .15020 .14526 .14056 .13608 .13181 .12774 .12385 .12015 .11661 .11322

50 .15855 .15347 .14862 .14401 .13960 .13540 .13138 .12754 .12388 .12037 51 .16727 .16205 .15707 .15232 .14777 .14344 .13929 .13532 .13153 .12789 52 .17634 .17098 .16587 .16097 .15630 .15183 .14755 .14345 .13953 .13577 53 .18576 .18027 .17501 .16999 .16518 .16057 .15616 .15194 .14789 .14400 54 .19552 .18990 .18451 .17935 .17441 .16968 .16514 .16078 .15661 .15260

55 .20564 .19989 .19437 .18908 .18402 .17915 .17449 .17001 .16571 .16157 56 .21613 .21025 .20461 .19919 .19400 .18901 .18422 .17962 .17519 .17093 57 .22698 .22098 .21522 .20968 .20436 .19925 .19434 .18961 .18507 .18069 58 .23816 .23204 .22616 .22051 .21507 .20984 .20481 .19996 .19530 .19080 59 .24962 .24339 .23740 .23163 .22608 .22073 .21558 .21062 .20584 .20123

60 .26136 .25502 .24892 .24304 .23738 .23192 .22666 .22158 .21669 .21196 61 .27339 .26695 .26075 .25477 .24900 .24343 .23806 .23288 .22787 .22304 62 .28578 .27925 .27295 .26687 .26100 .25533 .24985 .24456 .23945 .23451 63 .29854 .29192 .28553 .27935 .27339 .26762 .26205 .25666 .25145 .24641 64 .31164 .30494 .29846 .29221 .28615 .28030 .27463 .26915 .26384 .25870

65 .32508 .31831 .31177 .30543 .29930 .29336 .28761 .28203 .27663 .27140 66 .33891 .33208 .32547 .31906 .31285 .30684 .30101 .29536 .28987 .28456 67 .35318 .34630 .33963 .33316 .32689 .32081 .31491 .30918 .30363 .29823 68 .36785 .36093 .35422 .34770 .34138 .33524 .32928 .32349 .31787 .31240 69 .38290 .37595 .36920 .36265 .35628 .35009 .34408 .33824 .33256 .32703 70 .39823 .39127 .38450 .37791 .37151 .36529 .35924 .35335 .34762 .34204

71 .41378 .40681 .40003 .39343 .38701 .38076 .37467 .36875 .36298 .35736 72 .42950 .42253 .41575 .40914 .40271 .39644 .39034 .38438 .37858 .37293 73 .44535 .43840 .43162 .42502 .41858 .41231 .40619 .40022 .39440 .38872 74 .46139 .45446 .44771 .44112 .43469 .42842 .42230 .41632 .41049 .40479

75 .47769 .47080 .46408 .45752 .45111 .44485 .43874 .43277 .42693 .42123 76 .49430 .48747 .48079 .47427 .46790 .46167 .45558 .44963 .44380 .43811 77 .51123 .50447 .49786 .49139 .48506 .47888 .47282 .46690 .46111 .45543 78 .52845 .52177 .51523 .50884 .50257 .49645 .49044 .48457 .47881 .47317 79 .54584 .53926 .53282 .52650 .52032 .51426 .50833 .50251 .49681 .49122

1999–20 I.R.B. 55 May 17, 1999

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0%

80 .56325 .55678 .55044 .54423 .53813 .53216 .52630 .52056 .51492 .50939 81 .58054 .57419 .56797 .56186 .55587 .54999 .54422 .53856 .53300 .52754 82 .59762 .59140 .58530 .57931 .57343 .56766 .56198 .55641 .55094 .54557 83 .61448 .60840 .60243 .59657 .59081 .58515 .57958 .57411 .56874 .56346 84 .63124 .62531 .61949 .61376 .60813 .60259 .59715 .59179 .58652 .58134

85 .64800 .64224 .63657 .63099 .62550 .62010 .61478 .60955 .60441 .59934 86 .66461 .65902 .65351 .64810 .64276 .63751 .63233 .62724 .62222 .61728 87 .68083 .67541 .67008 .66483 .65965 .65455 .64953 .64458 .63970 .63489 88 .69663 .69140 .68624 .68116 .67615 .67121 .66634 .66154 .65680 .65213 89 .71201 .70696 .70199 .69708 .69224 .68747 .68276 .67811 .67353 .66900

90 .72694 .72209 .71730 .71257 .70791 .70330 .69876 .69427 .68984 .68547 91 .74117 .73650 .73190 .72735 .72286 .71842 .71404 .70972 .70545 .70123 92 .75439 .74991 .74548 .74110 .73678 .73251 .72829 .72412 .72000 .71593 93 .76664 .76233 .75806 .75385 .74969 .74557 .74150 .73748 .73350 .72957 94 .77809 .77394 .76983 .76578 .76177 .75780 .75388 .75000 .74616 .74237

95 .78899 .78500 .78106 .77715 .77329 .76947 .76569 .76195 .75826 .75460 96 .79928 .79544 .79165 .78790 .78418 .78050 .77686 .77326 .76970 .76617 97 .80883 .80514 .80149 .79787 .79430 .79075 .78725 .78377 .78033 .77693 98 .81781 .81427 .81075 .80727 .80382 .80041 .79703 .79368 .79036 .78708 99 .82661 .82320 .81982 .81648 .81316 .80988 .80662 .80340 .80020 .79704

100 .83519 .83192 .82868 .82547 .82228 .81913 .81600 .81290 .80982 .80678 101 .84368 .84055 .83744 .83437 .83131 .82829 .82529 .82231 .81936 .81643 102 .85203 .84904 .84607 .84313 .84021 .83731 .83444 .83159 .82876 .82596 103 .86034 .85748 .85465 .85184 .84906 .84629 .84355 .84082 .83812 .83544 104 .86923 .86653 .86385 .86119 .85855 .85593 .85333 .85074 .84818 .84563

105 .87792 .87537 .87283 .87032 .86782 .86534 .86287 .86042 .85799 .85557 106 .88918 .88683 .88450 .88218 .87987 .87758 .87530 .87304 .87079 .86855 107 .90291 .90082 .89873 .89666 .89460 .89255 .89051 .88849 .88647 .88447 108 .92455 .92288 .92123 .91958 .91794 .91630 .91468 .91306 .91145 .90984 109 .96211 .96125 .96041 .95956 .95872 .95788 .95704 .95620 .95537 .95455

May 17, 1999 56 1999–20 I.R.B.

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0%

0 .01488 .01463 .01439 .01417 .01396 .01377 .01359 .01343 .01327 .01312 1 .00662 .00636 .00612 .00589 .00568 .00548 .00530 .00513 .00497 .00482 2 .00654 .00626 .00600 .00576 .00554 .00533 .00514 .00496 .00479 .00463 3 .00670 .00641 .00613 .00588 .00564 .00542 .00522 .00502 .00484 .00468 4 .00699 .00668 .00639 .00612 .00587 .00563 .00542 .00521 .00502 .00484

5 .00739 .00706 .00675 .00646 .00620 .00595 .00571 .00550 .00529 .00510 6 .00786 .00751 .00718 .00687 .00659 .00633 .00608 .00585 .00563 .00543 7 .00841 .00803 .00769 .00736 .00706 .00678 .00652 .00627 .00604 .00582 8 .00902 .00863 .00826 .00791 .00759 .00730 .00702 .00675 .00651 .00628 9 .00973 .00931 .00892 .00856 .00822 .00790 .00760 .00733 .00706 .00682

10 .01055 .01010 .00969 .00930 .00894 .00861 .00829 .00799 .00772 .00746 11 .01146 .01099 .01055 .01014 .00976 .00940 .00907 .00875 .00846 .00818 12 .01246 .01196 .01150 .01106 .01066 .01028 .00993 .00960 .00928 .00899 13 .01351 .01298 .01249 .01204 .01161 .01121 .01084 .01049 .01016 .00985 14 .01455 .01400 .01348 .01300 .01255 .01213 .01173 .01136 .01102 .01069

15 .01555 .01497 .01443 .01392 .01345 .01300 .01259 .01220 .01183 .01148 16 .01648 .01587 .01530 .01477 .01427 .01380 .01336 .01295 .01257 .01220 17 .01737 .01673 .01612 .01556 .01504 .01455 .01408 .01365 .01324 .01286 18 .01822 .01754 .01691 .01632 .01576 .01525 .01476 .01430 .01387 .01347 19 .01908 .01837 .01770 .01708 .01650 .01595 .01544 .01495 .01450 .01407

20 .01999 .01924 .01854 .01788 .01726 .01669 .01615 .01564 .01516 .01471 21 .02096 .02017 .01943 .01874 .01809 .01748 .01691 .01637 .01586 .01539 22 .02197 .02114 .02036 .01963 .01895 .01830 .01770 .01713 .01660 .01610 23 .02306 .02218 .02136 .02059 .01987 .01919 .01855 .01795 .01739 .01686 24 .02424 .02331 .02245 .02163 .02087 .02016 .01948 .01885 .01825 .01769

25 .02552 .02455 .02364 .02278 .02197 .02122 .02051 .01984 .01920 .01861 26 .02692 .02589 .02493 .02403 .02318 .02238 .02162 .02091 .02025 .01961 27 .02846 .02738 .02636 .02541 .02451 .02367 .02287 .02212 .02141 .02074 28 .03012 .02898 .02791 .02690 .02595 .02506 .02422 .02342 .02267 .02196 29 .03190 .03070 .02957 .02851 .02751 .02656 .02567 .02483 .02404 .02329

30 .03381 .03254 .03135 .03023 .02917 .02817 .02723 .02634 .02551 .02471 31 .03583 .03450 .03324 .03206 .03094 .02989 .02890 .02796 .02707 .02623 32 .03799 .03659 .03527 .03402 .03284 .03173 .03068 .02968 .02874 .02785 33 .04031 .03883 .03744 .03612 .03488 .03371 .03260 .03155 .03055 .02961 34 .04279 .04123 .03976 .03838 .03707 .03583 .03465 .03354 .03249 .03149

35 .04545 .04382 .04227 .04081 .03943 .03812 .03688 .03571 .03459 .03354 36 .04830 .04658 .04495 .04341 .04196 .04058 .03927 .03803 .03685 .03573 37 .05134 .04953 .04782 .04620 .04467 .04321 .04183 .04052 .03928 .03809 38 .05462 .05272 .05092 .04921 .04760 .04606 .04461 .04322 .04191 .04066 39 .05812 .05613 .05424 .05245 .05075 .04913 .04760 .04614 .04475 .04343

1999–20 I.R.B. 57 May 17, 1999

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0%

40 .06190 .05981 .05782 .05594 .05415 .05245 .05083 .04929 .04783 .04643 41 .06597 .06378 .06170 .05972 .05784 .05605 .05435 .05272 .05118 .04970 42 .07035 .06806 .06587 .06380 .06182 .05994 .05815 .05644 .05481 .05326 43 .07505 .07265 .07036 .06818 .06611 .06414 .06225 .06045 .05874 .05710 44 .08008 .07757 .07518 .07290 .07072 .06865 .06667 .06478 .06298 .06125

45 .08542 .08279 .08029 .07791 .07563 .07346 .07138 .06940 .06750 .06569 46 .09108 .08834 .08573 .08324 .08085 .07858 .07640 .07432 .07233 .07043 47 .09705 .09419 .09147 .08886 .08637 .08399 .08172 .07954 .07745 .07545 48 .10335 .10038 .09754 .09482 .09222 .08973 .08735 .08507 .08288 .08078 49 .10999 .10690 .10394 .10111 .09840 .09581 .09332 .09093 .08864 .08644

50 .11701 .11380 .11073 .10778 .10496 .10225 .09965 .09716 .09477 .09247 51 .12441 .12108 .11789 .11482 .11189 .10907 .10636 .10376 .10126 .09886 52 .13217 .12871 .12540 .12222 .11916 .11623 .11341 .11071 .10810 .10560 53 .14028 .13670 .13327 .12997 .12680 .12375 .12082 .11801 .11529 .11268 54 .14875 .14505 .14150 .13808 .13480 .13163 .12859 .12566 .12284 .12012

55 .15760 .15378 .15011 .14657 .14317 .13989 .13674 .13370 .13077 .12794 56 .16684 .16290 .15911 .15546 .15194 .14855 .14528 .14213 .13909 .13615 57 .17648 .17242 .16851 .16474 .16111 .15760 .15422 .15096 .14781 .14477 58 .18647 .18229 .17827 .17438 .17064 .16702 .16353 .16015 .15689 .15374 59 .19678 .19249 .18835 .18435 .18049 .17676 .17316 .16968 .16631 .16305

60 .20740 .20300 .19875 .19464 .19066 .18682 .18311 .17952 .17604 .17268 61 .21837 .21385 .20949 .20527 .20119 .19724 .19341 .18971 .18613 .18266 62 .22973 .22511 .22064 .21631 .21212 .20807 .20414 .20033 .19664 .19306 63 .24152 .23680 .23222 .22779 .22350 .21934 .21530 .21139 .20760 .20392 64 .25372 .24890 .24422 .23969 .23529 .23103 .22690 .22289 .21899 .21521

65 .26633 .26141 .25664 .25201 .24752 .24316 .23893 .23482 .23083 .22695 66 .27940 .27439 .26953 .26481 .26023 .25577 .25145 .24724 .24316 .23918 67 .29299 .28790 .28296 .27815 .27348 .26894 .26453 .26024 .25606 .25200 68 .30709 .30193 .29691 .29202 .28728 .28265 .27816 .27378 .26952 .26537 69 .32166 .31643 .31134 .30639 .30157 .29687 .29230 .28785 .28351 .27928 70 .33661 .33133 .32618 .32116 .31628 .31152 .30688 .30235 .29794 .29364

71 .35188 .34654 .34134 .33627 .33133 .32651 .32181 .31722 .31275 .30838 72 .36742 .36204 .35679 .35168 .34668 .34181 .33706 .33241 .32788 .32345 73 .38317 .37776 .37248 .36733 .36229 .35738 .35257 .34788 .34330 .33882 74 .39923 .39380 .38849 .38330 .37823 .37328 .36844 .36370 .35908 .35455

75 .41566 .41021 .40489 .39968 .39459 .38961 .38474 .37997 .37531 .37074 76 .43254 .42709 .42176 .41655 .41144 .40645 .40156 .39677 .39208 .38749 77 .44988 .44444 .43912 .43391 .42880 .42380 .41891 .41411 .40940 .40479 78 .46765 .46224 .45694 .45174 .44665 .44166 .43677 .43197 .42726 .42265 79 .48574 .48037 .47510 .46993 .46487 .45990 .45502 .45024 .44554 .44094

May 17, 1999 58 1999–20 I.R.B.

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0%

80 .50397 .49865 .49343 .48830 .48327 .47834 .47349 .46873 .46406 .45947 81 .52219 .51693 .51176 .50669 .50171 .49682 .49201 .48729 .48265 .47809 82 .54029 .53510 .53000 .52499 .52007 .51523 .51047 .50580 .50120 .49667 83 .55826 .55315 .54813 .54319 .53834 .53356 .52886 .52424 .51969 .51522 84 .57624 .57123 .56629 .56144 .55666 .55195 .54732 .54277 .53828 .53386

85 .59435 .58944 .58460 .57984 .57516 .57054 .56599 .56151 .55710 .55275 86 .61241 .60762 .60289 .59824 .59365 .58913 .58468 .58029 .57596 .57170 87 .63015 .62548 .62087 .61633 .61185 .60744 .60309 .59880 .59456 .59039 88 .64753 .64299 .63851 .63409 .62973 .62543 .62118 .61700 .61287 .60879 89 .66454 .66013 .65579 .65150 .64726 .64308 .63895 .63488 .63086 .62689

90 .68115 .67689 .67268 .66853 .66442 .66037 .65637 .65241 .64851 .64465 91 .69706 .69294 .68887 .68486 .68089 .67696 .67309 .66925 .66547 .66173 92 .71190 .70792 .70399 .70011 .69627 .69247 .68872 .68501 .68134 .67771 93 .72569 .72184 .71804 .71429 .71057 .70689 .70326 .69967 .69611 .69259 94 .73861 .73490 .73123 .72759 .72400 .72044 .71692 .71344 .71000 .70659

95 .75097 .74739 .74384 .74033 .73686 .73342 .73002 .72665 .72331 .72001 96 .76267 .75922 .75579 .75240 .74905 .74572 .74243 .73917 .73595 .73275 97 .77356 .77022 .76691 .76363 .76039 .75718 .75399 .75084 .74772 .74463 98 .78382 .78059 .77740 .77423 .77110 .76799 .76491 .76186 .75884 .75584 99 .79390 .79079 .78771 .78465 .78162 .77862 .77565 .77270 .76978 .76688

100 .80376 .80076 .79779 .79485 .79193 .78904 .78617 .78333 .78051 .77771 101 .81353 .81066 .80780 .80497 .80217 .79938 .79662 .79388 .79117 .78847 102 .82318 .82042 .81768 .81496 .81227 .80960 .80694 .80431 .80170 .79911 103 .83278 .83014 .82752 .82491 .82233 .81977 .81723 .81470 .81220 .80971 104 .84310 .84059 .83810 .83563 .83317 .83073 .82831 .82591 .82352 .82115

105 .85318 .85079 .84843 .84607 .84374 .84142 .83911 .83682 .83455 .83229 106 .86633 .86413 .86193 .85975 .85758 .85543 .85329 .85116 .84904 .84694 107 .88247 .88049 .87852 .87656 .87460 .87266 .87073 .86881 .86690 .86500 108 .90825 .90666 .90507 .90350 .90193 .90037 .89881 .89727 .89572 .89419 109 .95372 .95290 .95208 .95126 .95045 .94964 .94883 .94803 .94723 .94643

1999–20 I.R.B. 59 May 17, 1999

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0%

0 .01298 .01285 .01273 .01261 .01250 .01240 .01230 .01221 .01212 .01203 1 .00468 .00455 .00443 .00431 .00420 .00410 .00400 .00391 .00382 .00374 2 .00448 .00435 .00421 .00409 .00398 .00387 .00376 .00366 .00357 .00348 3 .00452 .00437 .00423 .00410 .00398 .00386 .00375 .00365 .00355 .00345 4 .00468 .00452 .00437 .00423 .00410 .00397 .00386 .00375 .00364 .00354

5 .00493 .00476 .00460 .00445 .00431 .00418 .00405 .00393 .00382 .00371 6 .00524 .00506 .00489 .00473 .00458 .00444 .00430 .00418 .00406 .00394 7 .00562 .00543 .00525 .00508 .00492 .00477 .00462 .00449 .00436 .00423 8 .00606 .00586 .00566 .00548 .00531 .00515 .00499 .00485 .00471 .00458 9 .00659 .00637 .00616 .00597 .00579 .00561 .00545 .00529 .00514 .00500

10 .00721 .00698 .00676 .00655 .00636 .00617 .00600 .00583 .00567 .00552 11 .00792 .00767 .00744 .00722 .00701 .00682 .00663 .00645 .00628 .00612 12 .00871 .00845 .00821 .00797 .00775 .00754 .00735 .00716 .00698 .00681 13 .00955 .00928 .00902 .00877 .00854 .00831 .00810 .00790 .00771 .00753 14 .01038 .01009 .00981 .00955 .00930 .00907 .00885 .00864 .00843 .00824

15 .01116 .01085 .01056 .01028 .01002 .00977 .00954 .00932 .00910 .00890 16 .01186 .01153 .01123 .01094 .01066 .01040 .01015 .00992 .00969 .00948 17 .01250 .01215 .01183 .01152 .01124 .01096 .01070 .01045 .01022 .00999 18 .01308 .01272 .01238 .01206 .01175 .01147 .01119 .01093 .01068 .01044 19 .01367 .01329 .01293 .01259 .01227 .01196 .01167 .01140 .01113 .01088

20 .01428 .01388 .01350 .01314 .01280 .01248 .01217 .01188 .01161 .01134 21 .01494 .01451 .01411 .01373 .01337 .01303 .01271 .01240 .01211 .01183 22 .01562 .01517 .01475 .01435 .01397 .01361 .01326 .01294 .01263 .01233 23 .01635 .01588 .01543 .01501 .01460 .01422 .01386 .01351 .01319 .01287 24 .01716 .01665 .01618 .01573 .01530 .01489 .01451 .01415 .01380 .01347

25 .01804 .01751 .01701 .01653 .01608 .01565 .01524 .01485 .01448 .01413 26 .01902 .01845 .01792 .01741 .01693 .01648 .01604 .01563 .01524 .01487 27 .02011 .01951 .01895 .01841 .01790 .01742 .01696 .01652 .01610 .01571 28 .02129 .02066 .02006 .01949 .01895 .01844 .01795 .01748 .01704 .01662 29 .02258 .02191 .02127 .02067 .02009 .01955 .01903 .01853 .01806 .01762

30 .02396 .02325 .02257 .02193 .02132 .02074 .02019 .01966 .01916 .01869 31 .02543 .02467 .02396 .02328 .02263 .02201 .02143 .02087 .02034 .01983 32 .02701 .02621 .02545 .02472 .02404 .02338 .02276 .02217 .02160 .02106 33 .02871 .02786 .02706 .02629 .02556 .02487 .02420 .02357 .02297 .02240 34 .03054 .02964 .02879 .02797 .02720 .02646 .02576 .02509 .02445 .02383

35 .03253 .03158 .03067 .02981 .02898 .02820 .02745 .02674 .02606 .02541 36 .03467 .03366 .03269 .03178 .03090 .03007 .02928 .02852 .02779 .02710 37 .03697 .03590 .03488 .03391 .03298 .03209 .03125 .03044 .02967 .02893 38 .03947 .03833 .03725 .03622 .03524 .03430 .03340 .03254 .03172 .03094 39 .04217 .04096 .03982 .03873 .03768 .03669 .03573 .03482 .03395 .03312

May 17, 1999 60 1999–20 I.R.B.

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0%

40 .04510 .04383 .04262 .04146 .04035 .03930 .03828 .03732 .03639 .03550 41 .04830 .04695 .04567 .04445 .04327 .04215 .04108 .04005 .03907 .03812 42 .05177 .05035 .04900 .04770 .04646 .04527 .04413 .04304 .04200 .04100 43 .05553 .05404 .05261 .05123 .04992 .04866 .04746 .04630 .04520 .04413 44 .05960 .05802 .05651 .05506 .05368 .05235 .05107 .04985 .04867 .04754

45 .06395 .06229 .06069 .05917 .05770 .05630 .05495 .05365 .05241 .05121 46 .06860 .06685 .06517 .06356 .06202 .06053 .05911 .05774 .05643 .05516 47 .07353 .07169 .06992 .06823 .06660 .06504 .06353 .06209 .06070 .05936 48 .07877 .07684 .07498 .07320 .07149 .06984 .06826 .06673 .06527 .06385 49 .08433 .08231 .08036 .07849 .07669 .07495 .07329 .07168 .07013 .06864

50 .09026 .08814 .08609 .08413 .08224 .08042 .07867 .07698 .07535 .07378 51 .09655 .09433 .09219 .09013 .08815 .08624 .08440 .08262 .08091 .07926 52 .10318 .10086 .09863 .09647 .09439 .09239 .09046 .08860 .08680 .08506 53 .11017 .10774 .10541 .10315 .10098 .09888 .09686 .09491 .09302 .09120 54 .11750 .11498 .11254 .11019 .10792 .10572 .10361 .10156 .09958 .09767

55 .12522 .12258 .12005 .11759 .11522 .11294 .11072 .10859 .10652 .10451 56 .13332 .13059 .12794 .12539 .12292 .12054 .11823 .11599 .11383 .11174 57 .14183 .13899 .13624 .13359 .13102 .12853 .12613 .12380 .12154 .11936 58 .15070 .14775 .14490 .14215 .13948 .13689 .13439 .13197 .12962 .12734 59 .15990 .15685 .15389 .15103 .14826 .14558 .14298 .14046 .13801 .13564

60 .16942 .16626 .16321 .16024 .15737 .15459 .15189 .14927 .14673 .14426 61 .17929 .17603 .17287 .16981 .16684 .16395 .16115 .15844 .15580 .15324 62 .18960 .18623 .18297 .17980 .17673 .17375 .17085 .16803 .16530 .16264 63 .20035 .19688 .19352 .19025 .18708 .18400 .18100 .17809 .17525 .17250 64 .21154 .20797 .20451 .20114 .19787 .19469 .19159 .18859 .18566 .18281

65 .22318 .21951 .21595 .21249 .20912 .20584 .20265 .19955 .19652 .19358 66 .23532 .23156 .22790 .22434 .22088 .21751 .21422 .21102 .20791 .20487 67 .24804 .24419 .24044 .23679 .23324 .22977 .22640 .22311 .21990 .21678 68 .26133 .25740 .25356 .24983 .24618 .24263 .23917 .23579 .23250 .22929 69 .27516 .27114 .26723 .26341 .25969 .25605 .25251 .24905 .24567 .24237 70 .28945 .28536 .28137 .27747 .27367 .26996 .26633 .26279 .25934 .25596

71 .30412 .29996 .29590 .29193 .28806 .28427 .28057 .27696 .27343 .26998 72 .31913 .31491 .31078 .30675 .30281 .29895 .29519 .29150 .28790 .28438 73 .33444 .33016 .32597 .32188 .31788 .31396 .31013 .30638 .30271 .29913 74 .35012 .34579 .34155 .33741 .33335 .32938 .32549 .32168 .31795 .31430

75 .36628 .36190 .35762 .35343 .34932 .34530 .34136 .33750 .33372 .33001 76 .38299 .37858 .37427 .37004 .36589 .36183 .35784 .35394 .35011 .34636 77 .40028 .39585 .39151 .38725 .38307 .37898 .37496 .37103 .36716 .36337 78 .41812 .41368 .40933 .40506 .40086 .39675 .39271 .38874 .38485 .38103 79 .43641 .43198 .42762 .42334 .41914 .41502 .41096 .40698 .40308 .39924

1999–20 I.R.B. 61 May 17, 1999

TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0%

80 .45496 .45054 .44619 .44192 .43772 .43360 .42954 .42556 .42164 .41779 81 .47360 .46920 .46487 .46061 .45643 .45231 .44827 .44429 .44038 .43653 82 .49223 .48785 .48355 .47932 .47516 .47106 .46703 .46307 .45916 .45532 83 .51081 .50648 .50221 .49802 .49388 .48982 .48581 .48187 .47799 .47416 84 .52951 .52523 .52101 .51686 .51277 .50874 .50477 .50086 .49701 .49321

85 .54847 .54425 .54009 .53600 .53196 .52798 .52406 .52019 .51638 .51262 86 .56749 .56335 .55926 .55523 .55126 .54734 .54348 .53966 .53591 .53220 87 .58627 .58221 .57820 .57425 .57035 .56650 .56270 .55895 .55526 .55161 88 .60477 .60079 .59688 .59301 .58919 .58542 .58170 .57802 .57439 .57081 89 .62297 .61909 .61527 .61149 .60776 .60408 .60044 .59685 .59330 .58979

90 .64084 .63707 .63335 .62968 .62604 .62246 .61891 .61540 .61194 .60851 91 .65803 .65437 .65076 .64719 .64366 .64017 .63672 .63330 .62993 .62659 92 .67412 .67058 .66707 .66360 .66017 .65678 .65342 .65010 .64682 .64357 93 .68911 .68567 .68227 .67890 .67557 .67227 .66901 .66578 .66258 .65942 94 .70321 .69988 .69657 .69330 .69006 .68686 .68369 .68055 .67744 .67437

95 .71674 .71351 .71031 .70713 .70399 .70088 .69781 .69476 .69174 .68875 96 .72959 .72646 .72335 .72028 .71724 .71422 .71123 .70828 .70534 .70244 97 .74156 .73853 .73552 .73254 .72959 .72666 .72376 .72089 .71804 .71522 98 .75287 .74993 .74702 .74413 .74126 .73842 .73561 .73282 .73006 .72732 99 .76401 .76117 .75834 .75555 .75277 .75002 .74730 .74459 .74191 .73926

100 .77494 .77219 .76946 .76676 .76408 .76142 .75878 .75616 .75357 .75099 101 .78580 .78315 .78052 .77791 .77532 .77275 .77021 .76768 .76517 .76268 102 .79654 .79399 .79146 .78894 .78645 .78397 .78152 .77908 .77666 .77426 103 .80724 .80479 .80236 .79994 .79755 .79517 .79280 .79046 .78813 .78582 104 .81879 .81646 .81413 .81183 .80954 .80726 .80501 .80276 .80054 .79832

105 .83005 .82782 .82560 .82340 .82121 .81904 .81688 .81474 .81260 .81049 106 .84485 .84277 .84071 .83866 .83662 .83459 .83257 .83057 .82857 .82659 107 .86311 .86124 .85937 .85751 .85566 .85382 .85199 .85017 .84835 .84655 108 .89266 .89114 .88963 .88812 .88662 .88513 .88364 .88216 .88068 .87922 109 .94563 .94484 .94405 .94326 .94248 .94170 .94092 .94014 .93937 .93860

May 17, 1999 62 1999–20 I.R.B.

LIFE TABLE TABLE 90CM APPLICABLE AFTER APRIL 30, 1999

Age x l(x) Age x l(x) Age x l(x)

(1) (2) (1) (2) (1) (2)

0 100000 37 95969 74 62852 1 99064 38 95780 75 60449 2 98992 39 95581 76 57955 3 98944 40 95373 77 55373 4 98907 41 95156 78 52704

5 98877 42 94928 79 49943 6 98850 43 94687 80 47084 7 98826 44 94431 81 44129 8 98803 45 94154 82 41091 9 98783 46 93855 83 37994

10 98766 47 93528 84 34876 11 98750 48 93173 85 31770 12 98734 49 92787 86 28687 13 98713 50 92370 87 25638 14 98681 51 91918 88 22658

15 98635 52 91424 89 19783 16 98573 53 90885 90 17046 17 98497 54 90297 91 14466 18 98409 55 89658 92 12066 19 98314 56 88965 93 9884

20 98215 57 88214 94 7951 21 98113 58 87397 95 6282 22 98006 59 86506 96 4868 23 97896 60 85537 97 3694 24 97784 61 84490 98 2745

25 97671 62 83368 99 1999 26 97556 63 82169 100 1424 27 97441 64 80887 101 991 28 97322 65 79519 102 672 29 97199 66 78066 103 443

30 97070 67 76531 104 284 31 96934 68 74907 105 175 32 96791 69 73186 106 105 33 96642 70 71357 107 60 34 96485 71 69411 108 33

35 96322 72 67344 109 17 36 96150 73 65154 110 0

(e) Effective dates. This section applies after April 30, 1999.

Par. 20 Section 20.2055–2 is amended by revising paragraph (f)(4) to read as follows:

§20.2055–2 Transfers not exclusively for charitable purposes.

• ---

(f) * * *

(4) Other decedents. The present value of an interest not described in paragraph (f)(2) of this section is to be determined under §20.2031–7T(d) in the case of decedents where the valuation date of the

1999–20 I.R.B. 63 May 17, 1999

gross estate is after April 30, 1999, or under §20.2031–7A in the case of decedents where the valuation date of the gross estate is before May 1, 1999.

• ---

Par. 21. Section 20.7520–1 is amended as follows:

1. Paragraph (b)(2), last two sentences are revised.

2. Headings for paragraphs (c)(1) and (c)(2) are revised.

3. Paragraph (c)(2) introductory text is revised.

4. Paragraph (c)(2)(iii) is amended by removing the first two sentences and adding one sentence in their place.

5. Paragraph (d) is revised. The revised and added provisions read as follows:

§20.7520–1 Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests.

• ---

(b) * * * (2) * * * For decedents’ estates with valuation dates after April 30, 1989, and before May 1, 1999, the mortality component table (Table 80CNSMT) is included in §20.2031–7A(e)(4). See §20.2031– 7A(a) through (d) for mortality component tables applicable to decedents’ estates with valuation dates before May 1, 1989. (c) * * * (1) Regulations sections containing ta- bles with interest rates between 4.2 and 14 percent for valuation dates after April 30, 1989, and before May 1, 1999. - * * (2) Internal Revenue Service publica- tions containing tables with interest rates between 2.2. and 26 percent for valuation dates after April 30, 1989, and before May 1, 1999. The following publications are no longer available from the Superintendent of Documents, however, they may be obtained from: CC:DOM:CORP: R, room 5226, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044:

• ---

(iii) Internal Revenue Service Publication 1459, “Actuarial Values, Gamma Volume,” (8-89). * * *

(d) Effective date. This section applies after April 30, 1989, and before May 1, 1999. Par. 22. Section 20.7520–1T is added to read as follows:

§20.7520–1T Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests (temporary).

(a) (1) [Reserved]. For further guidance, see §20.7520–1(a)1).

(2) In the case of a transfer to a pooled income fund with a valuation date after April 30, 1999, see §1.642(c)–6T(e) (or, for certain prior periods, §1.642(c)–6A) of this chapter (Income Tax Regulations) with respect to the valuation of the remainder interest.

(a)(3) through (b)(1) [Reserved]. For further guidance, see §20.7520–1(a)(3) through (b)(1).

(b)(2) Mortality component. The mortality component reflects the mortality data most recently available from the United States Census. As new mortality data becomes available after each decennial census, the mortality component described in this section will be revised periodically and the mortality component tables will be published in the regulations at that time. For decedents’ estates with valuation dates after April 30, 1999, the mortality component table (Table 90CM) is included in §20.2031–7T(d)(7). See §20.2031–A for mortality component tables applicable to decedent’s estates with valuation dates before May 1, 1999.

(c) [Reserved]. For further guidance, see §20.7520–1(c).

(1) Regulation sections containing ta- bles with interest rates between 4.2 and 14 percent for valuation dates after April 30, 1999. Section 1.642(c)–6T(e)(6) of this chapter contains Table S used for determining the present value of a single life remainder interest in a pooled income fund as defined in §1.642(c)–5 of this chapter. See §1.642(c)–6A of this chapter for actuarial factors for one life applicable to valuation dates before May 1, 1999. Section 1.664–4(e)(6) of this chapter contains Table F (payout factors) and Table D (actuarial factors used in determining the present value of a remainder interest postponed for a term of years). Section 1.664–4T(e)(7) of this chapter contains

Table U(1) (actuarial factors for one life). These tables are used in determining the present value of a remainder interest in a charitable remainder unitrust as defined in §1.664–3 of this chapter. See §1.664–4A of this chapter for actuarial factors for one life applicable to valuation dates before May 1, 1999. Section 20.2031–7(d)(6) contains Table B (actuarial factors used in determining the present value of an interest for a term of years), Table K (annuity end-of-interval adjustment factors), and Table J (term certain annuity beginning-of-interval adjustment factors). Section 20.2031–7T(d)(7) contains Table S (actuarial factors for one life) and Table 90CM (mortality components). These tables are used in determining the present value of annuities, life estates, remainders, and reversions. See §20.2031–7A for actuarial factors for one life and mortality components applicable to valuation dates before May 1, 1999.

(2) Internal Revenue Service publica- tions containing tables with interest rates between 2.2 and 26 percent for valuation dates after April 30, 1999. The following documents are available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402:

(i) Internal Revenue Service Publication 1457, “Actuarial Values, Book Aleph,” (1999). This publication includes tables of valuation factors, as well as examples that show how to compute other valuation factors, for determining the present value of annuities, life estates, terms of years, remainders, and reversions, measured by one or two lives. These factors may also be used in the valuation of interests in a charitable remainder annuity trust as defined in §1.664–2 of this chapter (Income Tax Regulations) and a pooled income fund as defined in §1.642(c)–5 of this chapter.

(ii) Internal Revenue Service Publication 1458, “Actuarial Values, Book Beth,” (1999). This publication includes term certain tables and tables of one and two life valuation factors for determining the present value of remainder interests in a charitable remainder unitrust as defined in §1.664–3 of this chapter.

(iii) Internal Revenue Service Publication 1459, “Actuarial Values, Book Gimel,” (1999). This publication in

May 17, 1999 64 1999–20 I.R.B.

cludes tables for computing depreciation adjustment factors. See §1.170A–12T of this chapter.

(d) Effective date. This section applies after April 30, 1999.

PART 25—GIFT TAX; GIFTS MADE AFTER DECEMBER 31, 1954

Par. 23. The authority citation for part 25 is amended by adding entries in numerical order to read in part as follows:

Authority: 26 U.S.C. 7805 * * * Section 25.2512–5T also issued under 26 U.S.C. 7520(c)(2). * * * Section 25.7520–1T also issued under 26 U.S.C. 7520(c)(2). * * *

Par. 24. Section 25.2512–0 is revised to read as follows:

§25.2512–0 Table of contents.

This section lists the section headings that appear in the regulations under section 2512. §25.2512–1 Valuation of property; in general. §25.2512–2 Stocks and bonds. §25.2512–3 Valuation of interest in businesses. §25.2512–4 Valuation of notes. §25.2512–5 Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests. §25.2512–5T Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests (temporary). §25.2512–6 Valuation of certain life insurance and annuity contracts; valuation of shares in an open-end investment company. §25.2512–7 Effect of excise tax. §25.2512–8 Transfers for insufficient consideration.

Actuarial Tables Applicable Before

May 1, 1999

4. The fair market value of a qualified annuity interest described in section 2702(b)(1) and a qualified unitrust interest described in section 2702(b)(2) is the present value of such interests determined under §25.7520–1(c).

(2) Specific interests. When the donor transfers property in trust or otherwise and retains an interest therein, generally, the value of the gift is the value of the property transferred less the value of the donor’s retained interest. However, if the donor transfers property after October 8, 1990, to or for the benefit of a member of the donor’s family, the value of the gift is the value of the property transferred less the value of the donor’s retained interest as determined under section 2702. If the donor assigns or relinquishes an annuity, life estate, remainder, or reversion that the donor holds by virtue of a transfer previously made by the donor or another, the value of the gift is the value of the interest transferred. However, see section 2519 for a special rule in the case of the assignment of an income interest by a person who received the interest from a spouse.

(i) Charitable remainder trusts. The fair market value of a remainder interest in a pooled income fund, as defined in §1.642(c)–5 of this chapter, is its value determined under §1.642(c)–6T(e) of this chapter (see §1.642(c)–6A for certain prior periods). The fair market value of a remainder interest in a charitable remainder annuity trust, as described in §1.664– 2(a) of this chapter, is its present value determined under §1.664–2(c) of this chapter. The fair market value of a remainder interest in a charitable remainder unitrust, as defined in §1.664–3 of this chapter, is its present value determined under §1.664–4T(e) of this chapter. The fair market value of a life interest or term for years in a charitable remainder unitrust is the fair market value of the property as of the date of transfer less the fair market value of the remainder interest, determined under §1.664–4T(e)(4) and (5) of this chapter.

(ii) Ordinary remainder and reversion- ary interests. If the interest to be valued is to take effect after a definite number of years or after the death of one individual, the present value of the interest is computed by multiplying the value of the property by the appropriate remainder interest actuarial factor (that corresponds to

§25.2512–5A Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests transferred before May 1, 1999.

Par. 25. Section 25.2512–5 is amended as follows:

1. The section heading is revised.
2. Paragraphs (c) and (d) are revised.
3. Paragraph (e) is revised. The revised provisions read as follows:

§25.2512–5 Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests.

• ---

(c) and (d) [Reserved]. For further guidance, see §25.2512–5T(c) and (d).

(e) Effective date. This section applies after April 30, 1989, and before May 1, 1999. Par. 26. Section 25.2512–5T is added to read as follows:

§25.2512–5T Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests (temporary).

(a) and (b) [Reserved]. For further guidance, see §25.2512–5(a) and (b).

(c) Actuarial valuations. The present value of annuities, unitrust interests, life estates, terms of years, remainders, and reversions transferred by gift after April 30, 1999, is determined under paragraph (d) of this section. The present value of annuities, unitrust interests, life estates, terms of years, remainders, and reversions transferred by gift before May 1, 1999, is determined under the following sections:

Transfers Applicable After Before Regulations

• 01-01-52 25.2512–5A(a) 12-31-51 01-01-71 25.2512–5A(b) 12-31-70 12-01-83 25.2512–5A(c) 11-30-83 05-01-89 25.2512–5A(d) 04-30-89 05-01-99 25.2512–5A(e)

(d) Actuarial valuations after April 30, 1999 —(1) In general. Except as otherwise provided in paragraph (b) of this section and §25.7520–3(b) (relating to exceptions to the use of prescribed tables under certain circumstances), if the valuation date for the gift is after April 30, 1999, the fair market value of annuities, life estates, terms of years, remainders, and reversions transferred after April 30, 1999, is the present value of such interests determined under paragraph (d)(2) of this section and by use of standard or special section 7520 actuarial factors. These factors are derived by using the appropriate section 7520 interest rate and, if applicable, the mortality component for the valuation date of the interest that is being valued. See §§25.7520–1 through 25.7520–

1999–20 I.R.B. 65 May 17, 1999

the applicable section 7520 interest rate and remainder interest period) in Table B (for a term certain) or the appropriate Table S (for one measuring life), as the case may be. Table B is contained in §20.2031–7(d) of this chapter and Table S (for one measuring life when the valuation date is after April 30, 1999) is included in §20.2031–7T(d)(7) of this chapter and Internal Revenue Service Publication 1457. See §20.2031– 7A(e)(4) of this chapter containing Table S and Life Table 80CNSMT for valuation of interests after April 30, 1989, and before May 1, 1999. For information about obtaining actuarial factors for other types of remainder interests, see paragraph (d)(4) of this section.

(iii) Ordinary term-of-years and life in- terests. If the interest to be valued is the right of a person to receive the income of certain property, or to use certain nonincome-producing property, for a term of years or for the life of one individual, the present value of the interest is computed by multiplying the value of the property by the appropriate term-of-years or life interest actuarial factor (that corresponds to the applicable section 7520 interest rate and term-of-years or life interest period). Internal Revenue Service Publication 1457 includes actuarial factors for an interest for a term of years in Table B and for the life of one individual in Table S (for one measuring life when the valuation date is after April 30, 1999). However, term-of-years and life interest actuarial factors are not included in Table B in §20.2031–7(d)(6) or Table S in §20.20317T(d)(7) (or in §20.2031–7A(e)(4)) of this chapter. If Internal Revenue Service Publication 1457 (or any other reliable source of term-of-years and life interest actuarial factors) is not conveniently available, an actuarial factor for the interest may be derived mathematically. This actuarial factor may be derived by subtracting the correlative remainder factor (that corresponds to the applicable section 7520 interest rate and the term of years or the life) in Table B (for a term of years) in §20.2031– 7(d)(6) of this chapter or in Table S (for the life of one individual) in §20.2031– 7T(d)(7) of this chapter, as the case may be, from 1.000000. For information about obtaining actuarial factors for other types of term-of-years and life interests, see paragraph (d)(4) of this section.

(iv) Annuities. (A) If the interest to be valued is the right of a person to receive an annuity that is payable at the end of each year for a term of years or for the life of one individual, the present value of the interest is computed by multiplying the aggregate amount payable annually by the appropriate annuity actuarial factor (that corresponds to the applicable section 7520 interest rate and annuity period). Internal Revenue Service Publication 1457 includes actuarial factors in Table B (for an annuity payable for a term of years) and in Table S (for an annuity payable for the life of one individual when the valuation date is after April 30, 1999). However, annuity actuarial factors are not included in Table B in §20.2031–7(d)(6) of this chapter or Table S in §20.2031– 7T(d)(7) (or in §20.2031–7A(e)(4)) of this chapter. If Internal Revenue Service Publication 1457 (or any other reliable source of annuity actuarial factors) is not conveniently available, an annuity factor for a term of years or for one life may be

derived mathematically. This annuity factor may be derived by subtracting the applicable remainder factor (that corresponds to the applicable section 7520 interest rate and annuity period) in Table B (in the case of a term-of-years annuity) in §20.2031–7(d)(6) of this chapter or in Table S (in the case of a one-life annuity) in §20.2031–7T(d)(7) of this chapter, as the case may be, from 1.000000 and then dividing the result by the applicable section 7520 interest rate expressed as a decimal number. See §20.2031–7T(d)(2)(iv) of this chapter for an example that illustrates the computation of the present value of an annuity.

(B) If the annuity is payable at the end of semiannual, quarterly, monthly, or weekly periods, the product obtained by multiplying the annuity factor by the aggregate amount payable annually is then multiplied by the applicable adjustment factor set forth in Table K in §20.2031– 7(d)(6) of this chapter at the appropriate interest rate component for payments made at the end of the specified periods. The provisions of this paragraph (d)(2)(iv)(B) are illustrated by the following example:

Example. In July, the donor agreed to pay the annuitant the sum of $10,000 per year, payable in equal semiannual installments at the end of each period. The semiannual installments are to be made on

each December 31st and June 30th. The annuity is payable until the annuitant’s death. On the date of the agreement, the annuitant is 68 years and 5 months old. The donee annuitant’s age is treated as 68 for purposes of computing the present value of the annuity. The section 7520 rate on the date of the agreement is 10.6 percent. Under Table S in §20.2031–7T(d)(7) of this chapter, the factor at 10.6 percent for determining the present value of a remainder interest payable at the death of an individual aged 68 is .29691. Converting the remainder factor to an annuity factor, as described above, the annuity factor for determining the present value of an annuity transferred to an individual age 68 is 6.6329 (1.00000 minus .29691 divided by .106). The adjustment factor from Table K in §20.2031– 7(d)(6) of this chapter in the column for payments made at the end of each semiannual period at the rate of 10.6 percent is 1.0258. The aggregate annual amount of the annuity, $10,000, is multiplied by the factor 6.6329 and the product multiplied by 1.0258. The present value of the donee’s annuity is, therefore, $68,040.29 ($10,000 � 6.6329 � 1.0258).

(C) If an annuity is payable at the beginning of annual, semiannual, quarterly, monthly, or weekly periods for a term of years, the value of the annuity is computed by multiplying the aggregate amount payable annually by the annuity factor described in paragraph (d)(2)(iv)(A) of this section; and the product so obtained is then multiplied by the adjustment factor in Table J in §20.2031– 7(d)(6) of this chapter at the appropriate interest rate component for payments made at the beginning of specified periods. If an annuity is payable at the beginning of annual, semiannual, quarterly, monthly, or weekly periods for one or more lives, the value of the annuity is the sum of the first payment plus the present value of a similar annuity, the first payment of which is not to be made until the end of the payment period, determined as provided in paragraph (d)(2)(iv)(B) of this section.

(v) Annuity and unitrust interests for a term of years or until the prior death of an individual —(A) Annuity interests. The present value of an annuity interest that is payable until the earlier to occur of the lapse of a specific number of years or the death of an individual may be computed with values from the tables in §§20.2031– 7(d)(6) and 20.2031–7T(d)(7) of this chapter as described in the following example:

Example. The donor transfers $100,000 into a trust and retains the right to receive an annuity from the trust in the amount of $6,000 per year, payable in equal semiannual installments at the end of each pe

May 17, 1999 66 1999–20 I.R.B.

riod. The semiannual installments are to be made on each June 30th and December 31st. The annuity is payable for 10 years or until the donor’s prior death. At the time of the transfer, the donor is 59 years and 6 months old. The donor’s age is taken as 60 for purposes of computing the present value of the re

tained annuity. The section 7520 rate for the month in which the transfer occurred is 9.8 percent. The present value of the donor’s retained interest is $35,709.13, determined as follows:

TABLE S value at 9.8 percent, age 60 . . . . .21669

TABLE S value at 9.8 percent, age 70 . . . . .34762 TABLE 90CM value at age 70 . . . . . . . . . . . 71357 TABLE 90CM value at age 60 . . . . . . . . . . .85537 TABLE B value at 9.8 percent, 10 years . . .392624 TABLE K value at 9.8 percent . . . . . . . . . . 1.0239

Factor for donor’s retained interest at 9.8 percent:

(1.00000 – .21669) – (.392624 � (71357/85537) � (1.00000 – .34762)) = 5.8126

.098

of the semiannual period. The adjusted payout rate is 5.595 percent (6% � .932539). The present value of the donor’s retained interest is $40,848.00 determined as follows:

TABLE U(1) value at 5.6 percent, age 60 . . .35375 TABLE U(1) value at 5.6 percent, age 70 . . .49342 TABLE 90CM value at age 70 . . . . . . . . . . . 71357 TABLE 90CM value at age 60 . . . . . . . . . . . 85537 TABLE D value at 5.6 percent,

10 years . . . . . . . . . . . . . . . . . . . . . . . . . . .561979

Factor for donor’s retained interest at 5.6 percent:

Present value of donor’s retained interest:

($6,000 � 5.8126 � 1.0239) . . . . . . . . $35,709.13

(B) Unitrust interests. The present value of a unitrust interest that is payable until the earlier to occur of the lapse of a specific number of years or the death of an individual may be computed with values from the tables in §§1.664–4(e)(6) and 1.664–4T(e)(7) of this chapter as described in the following example:

Example. The donor who, as of the nearest birthday, is 60 years old, transfers $100,000 to a unitrust on January 1st. The trust instrument requires that each year the trust pay to the donor, in equal semiannual installments on June 30th and December 31st, 6 percent of the fair market value of the trust assets, valued as of January 1st each year, for 10 years or until the prior death of the donor. The section 7520 rate for the January in which the transfer occurred is 9.8 percent. Under Table F(9.8) in §1.664-4(e)(6) of this chapter, the appropriate adjustment factor is .932539 for semiannual payments payable at the end

(1.000000 – .35375) – (.561979 � (71357/85537) � (1.000000 – .49342)) = .40876

TABLE U(1) value at 5.4 percent, age 60 . . .36542 TABLE U(1) value at 5.4 percent, age 70 . . .50473

TABLE 90CM value at age 70 . . . . . . . . . . . 71357 TABLE 90CM value at age 60 . . . . . . . . . . . 85537

TABLE D value at 5.4 percent, 10 years . .573999 Factor for donor’s retained interest at 5.4 percent:

(1.000000 – .36542) – (.573999 � (71357/85537) � (1.000000 – .50473)) = .39742

Difference .01134

Par. 28. Section 25.2512–5A is amended by:

1. Revising the section heading.
2. Adding paragraph (e). The revision and addition read as follows:

§25.2512–5A Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests transferred before May 1, 1999.

• ---

(e) Valuation of annuities, unitrust in- terests, interests for life or term of years, and remainder or reversionary interests transferred after April 30, 1989, and be- fore May 1, 1999 —(1) In general. Except as otherwise provided in §§25.2512–5(b) and 25.7520–3(b) (pertaining to certain limitations on the use of prescribed tables), if the valuation date of the transferred interest is after April 30, 1989, and

Interpolation adjustment:

5.595% – 5.4% = x 0.2% .01134

x = .01106

Factor at 5.4 percent, age 60 . . . . . . . . . . .39742 Plus: Interpolation adjustment . . . . . . . . .01106 Interpolated Factor . . . . . . . . . . . . . . . . . .40848

Present value of donor’s retained interest:

($100,000 � .40848) . . . . . . . . . . . $40,848.00

(3) Transitional rule. If the valuation date of a transfer of property by gift is after April 30, 1999, and before July 1, 1999, the fair market value of the interest transferred is determined by use of the section 7520 interest rate for the month in which the valuation date occurs (See §§25.7520–1(b) and 25.7520–2(a)(2)) and the appropriate actuarial tables under either paragraph (d)(2) of this section or §25.2512–5A(e), at the option of the donor. However, with respect to each individual transaction and with respect to all transfers occurring on the valuation date, the donor must use the same actuarial tables (e.g., gift and income tax charitable deductions with respect to the same transfer must be determined based on the same tables, and all transfers made on the same date must be valued based on the same tables).

(4) Publications and actuarial compu- tations by the Internal Revenue Service. Many standard actuarial factors not included in §20.2031–7(d)(6) or §20.2031– 7T(d)(7) of this chapter are included in Internal Revenue Service Publication 1457, “Actuarial Values, Book Aleph,” (1999). Internal Revenue Service Publication 1457 also includes examples that illustrate how to compute many special factors for more unusual situations. A copy of this publication is available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402. If a special factor is required in the case of a completed gift, the Service may furnish the factor to the donor upon a request for a ruling. The request for a ruling must be accompanied by a recitation of the facts including a statement of the date of birth for each measuring life, the date of the gift, any other applicable dates, and a copy of the will, trust, or other relevant documents. A request for a ruling must comply with the instructions for requesting a ruling published periodically in the Internal Revenue Bulletin (see §§601.201 and 601.601(d)(2)(ii)(b) of this chapter) and include payment of the required user fee.

(e) Effective dates. This section applies after April 30, 1999.

Par. 27. The undesignated centerheading immediately following §25.2518–3 is revised to read as follows:

Actuarial Tables Applicable Before

May 1, 1999

1999–20 I.R.B. 67 May 17, 1999

dates after April 30, 1989, and before May 1, 1999. The following publications are no longer available from the Superintendent of Documents, however, they may be obtained from: CC:DOM:CORP: R, room 5226, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044:

• ---

(iii) Internal Revenue Service Publication 1459, “Actuarial Values, Gamma Volume,” (8-89). * * *

(d) Effective date. This section applies after April 30, 1989, and before May 1, 1999. Par. 30. Section 25.7520-1T is added to read as follows:

§25.7520–1T Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests (temporary).

(a) through (b) (1) [Reserved]. For further guidance, see §25.7520–1(a) through (b)(1).

(b)(2) Mortality component. The mortality component reflects the mortality data most recently available from the United States Census. As new mortality data becomes available after each decennial census, the mortality component described in this section will be revised periodically and the mortality component tables will be published in the regulations at that time. For gifts with valuation dates after April 30, 1999, the mortality component table (Table 90CM) is included in §20.2031–7T(d)(7) of this chapter. See §20.2031–7A of this chapter for mortality component tables applicable to decedent’s estates with valuation dates before May 1, 1999.

(c) [Reserved]. For further guidance, see §25.7520–1(c).

(1) Regulation sections containing ta- bles with interest rates between 4.2 and 14 percent for valuation dates after April 30, 1999. Section 1.642(c)–6T(e)(6) of this chapter contains Table S used for determining the present value of a single life remainder interest in a pooled income fund as defined in §1.642(c)–5 of this chapter. See §1.642(c)–6A for actuarial factors for one life applicable to valuation dates before May 1, 1999. Section 1.664– 4(e)(6) of this chapter contains Table F (payout factors) and Table D (actuarial

before May 1, 1999, the fair market value of annuities, unitrust interests, life estates, terms of years, remainders, and reversions transferred by gift is the present value of the interests determined by use of standard or special section 7520 actuarial factors and the valuation methodology described in §25.2512–5T(d). Sections 20.2031–7(d)(6) and 20.2031–7A(e)(4) of this chapter and related sections provide tables with standard actuarial factors and examples that illustrate how to use the tables to compute the present value of ordinary annuity, life, and remainder interests in property. These sections also refer to standard and special actuarial factors that may be necessary to compute the present value of similar interests in more unusual fact situations. These factors and examples are also generally applicable for gift tax purposes in computing the values of taxable gifts.

(2) Transitional rule. (i) If the valuation date of a transfer of an interest in property by gift is after April 30, 1989, and before June 10, 1994, a donor can rely on Notice 89–24 (1989–1 C.B. 660), or Notice 89–60 (1989–1 C.B. 700), in valuing the transferred interest. (See §601.601(d)(2)(ii)(b) of this chapter.)

(ii) If a donor transferred an interest in property by gift after December 31, 1988, and before May 1, 1989, retaining an interest in the same property, and after April 30, 1989, and before January 1, 1990, transferred the retained interest in property, the donor may, at the option of the donor, value the transfer of the retained interest under this paragraph (e) or paragraph (d) of this section.

(3) Publications and actuarial compu- tations by the Internal Revenue Service. Many standard actuarial factors not included in §§20.2031–7(d)(6) and 20.2031–7A(e)(4) of this chapter are included in Internal Revenue Service Publication 1457, “Actuarial Values, Alpha Volume,” (8-89). Internal Revenue Service Publication 1457 also includes examples that illustrate how to compute many special factors for more unusual situations. Publication 1457 is no longer available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402. However, pertinent factors in this publication may be obtained from: CC:DOM:CORP:R (IRS Publication

1457), room 5226, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044. If a special factor is required in the case of a completed gift, the Internal Revenue Service may furnish the factor to the donor upon a request for a ruling. The request for a ruling must be accompanied by a recitation of the facts including a statement of the date of birth for each measuring life, the date of the gift, any other applicable dates, and a copy of the will, trust, or other relevant documents. A request for a ruling must comply with the instructions for requesting a ruling published periodically in the Internal Revenue Bulletin (see §§601.201 and 601.601(d)(2)(ii)(b) of this chapter) and include payment of the required user fee.

Par. 29. Section 25.7520–1 is amended as follows:

1. Paragraph (b)(2), the last two sentences are revised.

2. The headings for paragraphs (c)(1) and (c)(2) are revised.

3. Paragraph (c)(2) introductory text is revised.

4. Paragraph (c)(2)(iii) is amended by removing the first two sentences and adding one sentence in their place.

5. Paragraph (d) is revised. The revised and added provisions read as follows:

§25.7520–1 Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests.

• ---

(b) * * * (2) * * * For gifts with valuation dates after April 30, 1989, and before May 1, 1999, the mortality component table (Table 80CNSMT) is included in §20.2031–7A(e)(4) of this chapter. See §20.2031–7A(a) through (d) of this chapter for mortality component tables applicable to decedents’ estates with valuation dates before May 1, 1989.

(c) * * * (1) Regulations sections containing ta- bles with interest rates between 4.2 and 14 percent for valuation dates after April 30, 1989, and before May 1, 1999. - * * (2) Internal Revenue Service publica- tions containing tables with interest rates between 2.2. and 26 percent for valuation

May 17, 1999 68 1999–20 I.R.B.

factors used in determining the present value of a remainder interest postponed for a term of years). Section 1.664– 4T(e)(7) of this chapter contains, Table U(1) (actuarial factors for one life). These tables are used in determining the present value of a remainder interest in a charitable remainder unitrust as defined in §1.664-3 of this chapter. See §1.664–4A for actuarial factors for one life applicable to valuation dates before May 1, 1999. Section 20.2031–7(d)(6) of this chapter contains Table B (actuarial factors used in determining the present value of an interest for a term of years), Table K (annuity end-of-interval adjustment factors), Table J (term certain annuity beginning-of-interval adjustment factors). Section 20.2031– 7T(d)(7) of this chapter contains Table S (actuarial factors for one life) and Table 90CM (mortality components). These tables are used in determining the present value of annuities, life estates, remainders, and reversions. See §20.2031– 7A of this chapter for actuarial factors for one life and mortality components applicable to valuation dates before May 1, 1999.

(2) Internal Revenue Service publica- tions containing tables with interest rates between 2.2 and 26 percent for valuation dates after April 30, 1999. The following documents are available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402:

(i) Internal Revenue Service Publication 1457, “Actuarial Values, Book Aleph,” (1999). This publication includes tables of valuation factors, as well as examples that show how to compute other valuation factors, for determining the present value of annuities, life estates, terms of years, remainders, and reversions, measured by one or two lives. These factors may also be used in the valuation of interests in a charitable remainder annuity trust as defined in §1.664–2 of this chapter (Income Tax Regulations) and a pooled income fund as defined in §1.642(c)–5 of this chapter.

(ii) Internal Revenue Service Publication 1458, “Actuarial Values, Book Beth,”

(1999). This publication includes term certain tables and tables of one and two life valuation factors for determining the present value of remainder interests in a charitable remainder unitrust as defined in §1.664-3 of this chapter.

(iii) Internal Revenue Service Publication 1459, “Actuarial Values, Book Gimel,” (1999). This publication includes tables for computing depreciation adjustment factors. See §1.170A–12T of this chapter.

(d) Effective date. This section applies after April 30, 1999.

Par. 31. Section 25.7520–3 is amended as follows:

1. In paragraph (b)(2)(v), Example 5 is revised.

2. In paragraph (b)(4), the Example is revised.

The revised examples read as follows:

§25.7520–3 Limitation on the application of section 7520.

• ---

(b) * * * (2) * * * (v) * **

Example 5. Eroding corpus in an annuity trust. (i) The donor, who is age 60 and in normal health, transfers property worth $1,000,000 to a trust. The trust will pay a 10 percent ($100,000 per year) annuity to a charitable organization for the life of the donor, payable annually at the end of each period, and the remainder will be distributed to the donor’s child. The section 7520 rate for the month of the transfer is 6.8 percent. First, it is necessary to determine whether the annuity may exhaust the corpus before all annuity payments are made. Because it is assumed that any measuring life may survive until age 110, any life annuity could require payments until the measuring life reaches age 110. Based on a section 7520 interest rate of 6.8 percent, the determination of whether the annuity may exhaust the corpus before the annuity payments are made is computed as follows:

Age to which life annuity may continue . . . .110 less: Age of measuring life at date of

transfer . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 Number of years annuity may continue . . . . . .50

Annual annuity payment . . . . . . . . $100,000.00 times: Annuity factor for 50 years

derived from Table B . . . . . . . . . . 14.1577 Present value of term certain

annuity . . . . . . . . . . . . . . . . . . . .$1,415,770.00

(ii) Since the present value of an annuity for a term of 50 years exceeds the corpus, the annuity may exhaust the trust before all payments are made. Consequently, the annuity must be valued as an annuity payable for a term of years or until the prior death of the annuitant, with the term of years determined by when the fund will be exhausted by the annuity payments.

(iii) Using factors based on Table 90CM at 6.8 percent (see §20.2031–7T(d)(7) of this chapter), it is determined that the fund will be sufficient to make 17 annual payments, but not to make the entire 18th payment. Specifically, the initial corpus will be able to make payments of $67,287.26 per year for 17 years plus payments of $32,712.74 per year for 18 years. The annuity is valued by adding the value of the two separate temporary annuities.

(iv) Based on Table H of Publication 1457 (a copy of this publication may be purchased from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402), the present value of an annuity of $67,287.26 per year payable for 17 years or until the prior death of a person aged 60 is $588,016.64 ($67,287.26 8.7389). The present value of an annuity of $32,712.74 per year payable for 18 years or until the prior death of a person aged 60 is $292,196.74 ($32,712.74 � 8.9322). Thus, the present value of the charitable annuity interest is $880,213.38 ($588,016.64 + $292,196.74).

• ---

(4) * * * Example. Terminal illness. The donor transfers property worth $1,000,000 to a child in exchange for the child’s promise to pay the donor $103,000 per year for the donor’s life, payable annually at the end of each period. The donor is age 60 but has been diagnosed with an incurable illness and has at least a 50 percent probability of dying within 1 year. The section 7520 interest rate for the month of the transfer is 10.6 percent, and the standard annuity factor at that interest rate for a person age 60 in normal health is 7.5590. Thus, if the donor were not terminally ill, the present value of the annuity would be $778,577 ($103,000 - 7.5590). Assuming the presumption provided in paragraph (b)(3) of this section does not apply, because there is at least a 50 percent probability that the donor will die within 1 year, the standard section 7520 annuity factor may not be used to determine the present value of the donor’s annuity interest. Instead, a special section 7520 annuity factor must be computed that takes into account the projection of the donor’s actual life expectancy.

• ---

Par. 32. In the list below, for each section indicated in the left column, remove the language in the middle column and add the language in the right column:

1999–20 I.R.B. 69 May 17, 1999

Section Remove Add

1.170A–6(c)(5) 1970 1971 Example (1) first and last sentence

1.170A–6(c)(5) 1970 Example (2) (a) first sentence

1.170A–6(c)(5) 1970 1971 Example (3) (a) first, sixth, seventh and eighth sentences

1.170A–6(c)(5) 1971 1972 Example (3) (a) seventh and eighth sentences

1.170A–6(c)(5) 1972 1973 Example (3) (a) seventh and eighth sentences

1.170A–6(c)(5) 1970 1971 Example (3) (b) introductory text

1.170A–6(c)(5) Jan. 1,1970 Jan. 1,1971 Example (3) (b) Table headings

1.170A–6(c)(5) Dec. 31, 1970 Dec. 31, 1971 Example (3) (b) column 1 of table

1.170A–6(c)(5) Dec. 31, 1971 Dec. 31, 1972 Example (3) (b) column 1 of table

1.170A–6(c)(5) Dec. 31, 1972 Dec. 31, 1973 Example (3) (b) column 1 of table

1.170A–6(c)(5) 1972 1973 Example (3) (c)

1.170A–6(c)(5) 1972 1973 Example (3) (d)

1.170A–12(b)(2) factor factor before May 1, 1999 paragraph heading

1.170A–12(b)(2) April 30, 1989, April 30, 1989, and before May 1, fourth sentence 1999,

1.170A–12(b)(2) CC:DOM:CORP:T:R CC:DOM:CORP:R sixth sentence

1.170A–12(b)(2) room 5228 room 5226 sixth sentence

May 17, 1999 70 1999–20 I.R.B.

Section Remove Add

1.170A–12(c) paragraph (f) of such sections §20.2031-7(d)(6) of this chapter first sentence

1.170A–12(e)(2) Table 80CNSMT in §20.2031–7 Table 90CM in §20.2031–7T following the formula

1.170A–12(e)(3) E:A:G OP:E:EP:A:1 last sentence

1.170A–14(h)(4), December 1, 1983 May 1, 1999 Example 2, fourth sentence

1.642(c)–6A(e)(2)(i) §20.2031–7(d)(6) §20.2031–7A(e)(4)

1.664–1(a)(5)(ii)(b)(1) column 2 of Table D Table D in §1.664–4(e)(6) In §1.664–4A(d)(6)

1.664–1(a)(5)(iv) (iii) of this section: (ii) of this section: introductory text

1.664–1(a)(6) §1.664–4(e), §1.664–4(A) §§1.664–4T(e), 1.664–4T(e) and introductory text (d), and former §1.664–4 1.664–4A(d) and (e) (d) (as contained in the 26 CFR part 1 edition revised as of April 1, 1994)

1.664–2(c) April 30, 1989 April 30, 1999

1.664–2(c) §20.2031–7A(a) through (d) §20.2031–7A (a) through (e) sixth sentence

1.664–2(c) May 1, 1989 May 1, 1999 sixth sentence

1.664–2(c) last sentence

1.7520–1(a)(2) 1989, see §1.642(c)–6(e) 1999, see §1.642(c)–6T(e)

1.7520–1(a)(3) (or, for certain prior periods, last sentence §1.664–4A)

1.7520–1(c)(1) Section 1.642(c)–6(e)(4) Section 1.642(c)–6A(e)(5) first sentence

1.7520–1(c)(1) Section 1.664–4(e)(6) contains Sections 1.664–4(e)(6) and second sentence 1.664–4A(e)(6) contain

1.7520–1(c)(1) Section 20.2031–7(d)(6) Sections 20.2031–7(d)(6) and third sentence of this chapter (Estate Tax 20.2031–7A(e)(4) of this chapter Regulations) contains contain

20.2032–1(f)(1) paragraph (d) of §20.2031–7A(d)(4) fourth sentence §20.2031–7(A)(d)

20.2055–2(f)(2)(iv) §20.2031–10(f) §20.2031–7A(d) Example (1) second sentence

20.2055–2(f)(2)(iv) §20.2031–10(f) §20.2031–7A(d) Example (2) second sentence

1999–20 I.R.B. 71 May 17, 1999

Section Remove Add

20.2055–2(f)(2)(iv) §20.2031–10(e) §20.2031–7A(c) Example (3) second sentence

20.2055–2(f)(2)(iv) §20.2031–10(f) §20.2031–7A(d) Example (3) third sentence

20.2056A–4(c)(4)(ii)(B) Alpha Volume Book Aleph penultimate sentence

20.2056A–4(d), Alpha Volume Book Aleph Example 4(iii) second sentence

20.7520–(a)(2) 1989, see §1.642(c)–6(e) 1999, see §1.642(c)–6T(e)

20.7520–1(a)(3) (or, for certain prior periods, second sentence §1.664–4A)

20.7520–1(c)(1) Section 1.642(c)–6(e)(4) Section 1.642(c)–6A(e)(5) first sentence

20.7520–1(c)(1) Section 1.664–4(e)(6) Sections 1.664–4(e)(6) and second sentence of this chapter contains 1.664-4A(e)(6) of this chapter contain

20.7520–1(c)(1) Section 20.2031–7(d)(6) contains Sections 20.2031–7(d)(6) and third sentence 20.2031–7A(e)(4) contain

25.7520–1(a)(2) 1989, see §1.642(c)–6(e) 1999, see §1.642(c)–6T(e)

25.7520–1(a)(3) (or, for certain prior periods, last sentence §1.664–4A)

25.7520-1(c)(1) Section 1.642(c)–6(e)(4) Section 1.642(c)–6A(e)(5) first sentence

25.7520–1(c)(1) Section 1.664–4(e)(6) of this chapter Sections 1.664–4(e)(6) and second sentence contains 1.664–4A(e)(6) of this chapter contain

25.7520–1(c)(1) Section 20.2031–7(d)(6) Sections 20.2031–7(d)(6) and third sentence (Estate Tax Regulations) contains 20.2031–7A(e)(4) contain

Robert E. Wenzel, Deputy Commissioner of

Internal Revenue.

Approved April 21, 1999.

Donald C. Lubick, Assistant Secretary of

the Treasury.

(Filed by the Office of the Federal Register on April 29, 1999, 8:45 a.m., and published in the issue of the Federal Register for April 30, 1999, 64 F.R. 23187)

May 17, 1999 72 1999–20 I.R.B.