Part I. Rulings — Internal Revenue Bulletin 1999-25

posed table also added a new age bracket to the table for ages under 25. A special effective date was proposed solely for purposes of determining whether a policy is carried directly or indirectly by the employer.

Explanation of Provisions

Uniform Premium Table

The IRS received 26 written comments concerning the proposed regulations. No commentator suggested changes to the proposed uniform premium table. The final regulations reflect the uniform premium table that was set forth in the proposed regulations.

General Effective Date

Many of the comments received by the IRS discussed the proposed effective date for the uniform premium rates. Some commentators agreed with the proposed effective date of July 1, 1999. Many of the commentators asked that the effective date be made retroactive to January 1, 1999. A few of the commentators requested that it be postponed, generally until January 1, 2000. Some commentators suggested that each employer should be allowed to decide the effective date for its employees, within a limited period of time set by the IRS . Some commentators requested that the effective date of the revised Table I be the first payroll period beginning on or after July 1, 1999.

Those advocating a January 1, 1999 effective date expressed the view that employees should get the benefit of the lower Table I rates for the entire year. In their opinion, additional administrative costs, if any, for implementing revised rates retroactively, rather than July 1,

group-term life insurance during the 1985-1989 period, as reflected in a Society of Actuaries report. The mortality rates have been adjusted for improvements in mortality from 1988 (the weighted midpoint for the data used in the 1985-89 study) through 2000, based on the same rates of mortality improvement that were adopted by the Society of Actuaries Group Annuity Valuation Table Task Force for the period 1988-1994. Separate mortality rates have been derived for males and females, and the uniform premium table reflects a 50/50 blend of the male and female mortality rates. The resulting mortality projections have been adjusted to reflect a 10 percent load factor.

Section 79.—Group-Term Life Insurance Purchased for Employees

26 CFR 1.79–3: Determination of amount equal to cost of group-term life insurance.

T.D. 8821

DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1

Group-Term Insurance; Uniform Premiums

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final regulations.

SUMMARY: This document contains final regulations revising the uniform premium table used to calculate the cost of group-term life insurance coverage provided to an employee by an employer. These regulations provide guidance to employers who provide group-term life insurance coverage to their employees that is includible in the gross income of the employees.

DATES: Effective Date: These regulations are effective July 1, 1999.

Applicability Date: For the applicability of these regulations to group-term life insurance coverage, see §1.79–3(e)

FOR FURTHER INFORMATION CONTACT: Betty J. Clary, (202) 622-6070 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

This document contains amendments to the Income Tax Regulations under section 79 of the Internal Revenue Code. These regulations revise the uniform premiums used to calculate the cost of group-term life insurance provided to employees. The revised uniform premiums are effective generally on July 1, 1999. However, employers have until the last pay period of 1999 to make any needed adjustments of amounts withheld for purposes of the FICA. Further, an employer may con

tinue using only 10 age-brackets for making its calculations until January 1, 2000. A special effective date applies to a policy of life insurance issued under a plan in existence on June 30, 1999, if the policy would not be treated as carried directly or indirectly by an employer under §1.79–0 of the Income Tax Regulations using the section 79 uniform premium table in effect on June 30, 1999. If this is the case, the employer may continue using such table for determining if the policy is carried directly or indirectly by an employer until January 1, 2003.

Section 79 generally permits an employee to exclude from gross income the cost of $50,000 of group-term life insurance carried directly or indirectly by an employer. The remaining cost of the group-term life insurance is included in the employee’s gross income to the extent it exceeds the amount, if any, paid by the employee for the coverage. Income imputed under section 79 is not subject to Federal income tax withholding. However, it is subject to FICA tax and, for active employees, an employer is required to withhold the FICA tax at least once a year. Also, the amount of the income imputed under section 79 is reported on an employee’s Form W-2.

Section 79 provides for the cost of the group-term life insurance to be determined on the basis of five-year age brackets prescribed by regulations. Those costs are set forth in the regulations in Table I entitled “Uniform Premiums for $1,000 of Group-term Life Insurance Protection.” §1.7–3(d)(2). The group-term life insurance costs are calculated on a calendar month basis. §1.79–3 (a) through (c).

Table I was initially published on July 6, 1966 (31 F.R. 9199), and was revised on December 6, 1983 (48 F.R. 54595). In a notice of proposed rulemaking (REG– 209103–89, 1999–11 I.R.B. 10) published in the Federal Register (64 F.R. 2164) on January 13, 1999, the IRS and Treasury proposed revising the Table I rates, effective July 1, 1999. The uniform premiums under the proposed table were lower in all age groups than those under the then-current section 79 regulations. ¹ The pro

1The revised uniform premiums are based on mortality experience for individuals covered by

1999–25 I.R.B. 3 June 21, 1999

1999, would be minimal. Some commentators observed that the use of a January 1 effective date would permit the use of a single set of Table I rates for the entire year, rather than a bifurcated rate for 1999. However, there was no consensus as to whether this factor suggests using an effective date of January 1, 1999 or (as discussed below) January 1, 2000.

Some commentators suggested a January 1, 2000 effective date on account of resource constraints resulting from year 2000 compliance. One of the commentators also observed that many payroll systems are now “hard coded” for making group-term calculations using only 10 age brackets, and that the additional age bracket (for ages under 25) in the revised Table I would make it more difficult to modify those payroll systems by July 1, 1999. In the public hearing that was held on the proposed regulations on May 6, 1999, the sole speaker reiterated its written comment in which it requested that the effective date be postponed, generally until January 1, 2000, and indicated that a change in the proposed regulations to not mandate use of the “Under 25” age bracket would significantly reduce the administrative burden of a July 1, 1999 effective date.

The IRS and Treasury continue to believe that an effective date of July 1, 1999 provides the best way to balance the ability of employees to obtain the tax benefits of the lower Table I rates with the concerns expressed by some commentators about modifying payroll systems. As stated previously, income imputed under section 79 is not subject to Federal income tax withholding. Further, while it must be reported on Form W-2 and it is subject to FICA tax withholding, changes to payroll systems are not required to be effectuated by the July 1, 1999 effective date.

Specifically, Notice 88–82 (1988–2 C.B. 398), “Reporting FICA Taxes on Group-Term Life Insurance,” explains that an employer may treat the imputed income amounts as paid either by the pay period, by the quarter, or on any other basis so long as the payments are treated as paid at least as often as once a year. The employer need not inform the IRS of a formal choice of payment dates or the dates chosen. Furthermore, the same choice need not be made for all employ

ees. The employer may change methods at any time, so long as all imputed income amounts includible in a calendar year are treated as paid by December 31 of the calendar year. Notice 88–82, therefore, permits those employers currently withholding the FICA taxes on a pay period basis to either (1) change methods to treat the Table I amounts includible in income after July 1, 1999 as paid on December 31, 1999, or (2) continue to withhold using the old Table I rates, so long as adjustments for the post-July 1, 1999 FICA withholding amounts are made by the last pay period for 1999.

Accordingly, the regulations provide that the revised Table I rates are effective, generally, on July 1, 1999. However, in order to further minimize the administrative burden of a July 1, 1999 effective date, the regulations allow employers to continue using 10 age brackets until January 1, 2000, thereby eliminating the need for “hard coded” systems to be modified during 1999 to include the “Under 25” age bracket.

Special Effective Date

Several comments were received on the topic of the effective date for purposes of determining whether, for purposes of section 79, a policy is carried directly or indirectly by the employer. A policy is considered carried directly or indirectly by the employer if (a) the employer pays any part of the life insurance, or (b) the employer arranges for payment of the cost of the life insurance by its employees and charges at least one employee less than the cost of his or her insurance (as determined under Table I) and at least one other employee more than his or her insurance (as determined under Table I). §1.79–0.

The IRS and Treasury recognize that the premiums charged to employees under some employee-pay-all plans may involve premiums charged to employees that are all at or below the uniform premium rates prior to the revision of Table I. Because the revised Table I rates are lower than the rates under the prior table, it is likely that the premiums charged under some of those policies will now straddle the new rates. As a result, the life insurance provided under those policies will become subject to section 79. The

notice of proposed rulemaking proposed a special effective date rule to apply to any policy of life insurance issued under a plan in existence before the general July 1, 1999 effective date. Under the special rule, if a policy would not be treated as carried directly or indirectly by an employer using the Table I rates in effect on June 30, 1999, the policy would continue to be treated as not carried directly or indirectly by the employer until the first plan year that begins after the general effective date.

Several comments received about the proposed special rule support the use of a special effective date for the purpose of determining whether a policy is carried directly or indirectly by the employer. However, most of those comments requested that the special rule be extended under certain identified circumstances. One commentator favored extending the special effective date for group-term coverage provided under a collectively bargained agreement. The commentator noted that collectively bargained plans may not be able to adjust rates within the time period of the proposed special rule because rate changes would require a substantive change to benefits in the middle of a contract. Two commentators suggested that the special effective date for a plan with a multi-year guarantee be extended until the end of the last plan year covered by the guarantee. Others suggested that the revised Table I rates not be effective for purposes of determining if the plan is carried directly or indirectly by the employer until there is a change in a plan’s premium rates. Another comment addressed an issue under the definition of carried directly or indirectly by the employer different from the special effective date issue. The comment suggested that a policy not be treated as carried directly or indirectly by the employer if the policy charges employees actuarially determined, age-specific premium rates, rather than the rates in the five-year age brackets in Table I.

The IRS and Treasury agree that some additional time should be given to employee-pay-all plans that would previously not be subject to section 79. Accordingly, the final regulations provide a special rule under which, until January 1, 2003, an employer can use either the

June 21, 1999 4 1999–25 I.R.B.

Table I rates in effect on June 30, 1999 or the new Table I rates in the final regulation for determining if a plan in existence on June 30, 1999 is carried directly or indirectly by the employer.

Special Analyses

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) and the Regulatory Flexibility Act (5 U.S.C. chapter 6) do not apply to these regulations, and, therefore, a Regulatory Flexibility Analysis is not required. Pursuant to section 7805(f) of the Internal Revenue Code, the notice of proposed rulemaking preceding these regulations was submitted to the Small Business Administration for comment on its impact on small business.

Drafting Information

The principal author of these regulations is Betty J. Clary, Office of Associate Chief Counsel (Employee Benefits and Exempt Organizations), IRS. Other personnel from the IRS and the Treasury Department also participated in their development.

- - - -

Adoption of Amendments to the Regulations

Accordingly, 26 CFR part 1 is amended as follows:

PART 1–INCOME TAXES

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

Authority: 26 U.S.C. 7805 * * * Par. 2. In §1.79–1, paragraph (d)(7) is revised to read as follows:

§1.79–1 Group-term life insurance–general rules.

(d) * * * (7) Example. The provisions of this paragraph may be illustrated by the following example:

Example. An employer provides insurance to employee A under a policy that meets the require

ments of this section. Under the policy, A, who is 47 years old, received $70,000 of group-term life insurance and elects to receive a permanent benefit under the policy. A pays $2 for each $1,000 of group-term life insurance through payroll deductions and the employer pays the remainder of the premium for the group-term life insurance. The employer also pays one half of the premium specified in the policy for the permanent benefit. A pays the other half of the premium for the permanent benefit through payroll deductions. The policy specifies that the annual premium paid for the permanent benefit is $300. However, the amount of premium allocated to the permanent benefit by the formula in paragraph (d)(2) of this section is $350. A is a calendar year taxpayer; the policy year begins January 1. In year 2000, $200 is includible in A’s income because of insurance provided by the employer. This amount is computed as follows:

(1) Cost of permanent benefits . . . . . . . . . . . $350 (2) Amounts considered paid by A for

permanent benefits ( ¹ ⁄2 � $300) . . . . . . . 150 (3) Line (1) minus line (2) . . . . . . . . . . . . . . 200 (4) Cost of $70,000 of group-term life

insurance under Table I of §1.79–3 . . . . 126 (5) Cost of $50,000 of group-term life

insurance under Table I of §1.79–3 . . . . 90 (6) Cost of group-term insurance in excess

of $50,000 (line (4) minus line(5)) . . . . . 36 (7) Amount considered paid by A for

group-term life insurance (70 � $2) . . . 140 (8) Line (6) minus line (7) (but not less

than 0) . . . . . . . . . . . . . . . . . . . . . . . . . . . 0 (9) Amount includible in income (line (3)

plus line (8)) . . . . . . . . . . . . . . . . . . . . . . 200

Par. 3. Section 1.79–3 is amended as follows:

Paragraph (d)(2) is revised.
Paragraphs (e) and (f) are redesignated as paragraphs (f) and (g), respectively.
New paragraph (e) is added. The revision and addition read as follows:

§1.79–3 Determination of amount equal to cost of group-term life insurance.

(d) * * * (2) For the cost of group-term life insurance provided after June 30, 1999, the following table sets forth the cost of $1,000 of group-term life insurance provided for one month, computed on the basis of 5-year age brackets. See 26 CFR 1.79–3(d)(2) in effect prior to July 1, 1999, and contained in the 26 CFR part 1 edition revised as of April 1, 1999, for a table setting forth the cost of group-term life insurance provided before July 1, 1999. For purposes of Table I, the age of

the employee is the employee’s attained age on the last day of the employee’s taxable year.

TABLE I. – UNIFORM PREMIUMS FOR $1,000 OF GROUP-TERM LIFE

INSURANCE PROTECTION

Cost per $1,000 5-year age of protection bracket for one month

Under 25 . . . . . . . . . . . . . . $0.05 25 to 29 . . . . . . . . . . . . . . . .06 30 to 34 . . . . . . . . . . . . . . . .08 35 to 39 . . . . . . . . . . . . . . . .09 40 to 44. . . . . . . . . . . . . . . .10 45 to 49 . . . . . . . . . . . . . . . .15 50 to 54 . . . . . . . . . . . . . . . .23 55 to 59 . . . . . . . . . . . . . . . .43 60 to 64 . . . . . . . . . . . . . . . .66 65 to 69 . . . . . . . . . . . . . . . 1.27 70 and above . . . . . . . . . . . 2.06

(e) Effective date - (1) General effec- tive date for table. Except as provided in paragraph (e)(2) of this section, the table in paragraph (d)(2) of this section is applicable July 1, 1999. Until January 1, 2000, an employer may calculate imputed income for all its employees under age 30 using the 5-year age bracket for ages 25 to 29. (2) Effective date for table for pur- poses of §1.79–0. For a policy of life insurance issued under a plan in existence on June 30, 1999, which would not be treated as carried directly or indirectly by an employer under §1.79–0 (taking into account the Table I in effect on that date), until January 1, 2003, an employer may use either the table in paragraph (d)(2) of this section or the table in effect prior to July 1, 1999 (as described in paragraph (d)(2) of this section) for determining if the policy is carried directly or indirectly by the employer.

Robert E. Wenzel, Deputy Commissioner of

Internal Revenue.

Approved May 25, 1999.

Donald C. Lubick, Assistant Secretary of the Treasury (Tax Policy).

1999–25 I.R.B. 5 June 21, 1999

tion to nicotine. Accordingly, A ’s costs for the smoking-cessation program and B ’s costs for prescribed drugs to alleviate the effects of nicotine withdrawal are amounts paid for medical care under § 213(d)(1). However, under § 213(b), A ’s costs for nicotine gum and nicotine patches are not deductible because they contain a drug (other than insulin) and do not require a prescription of a physician.

HOLDING

Uncompensated amounts paid by taxpayers for participation in a smoking-cessation program and for prescribed drugs designed to alleviate nicotine withdrawal are expenses for medical care that are deductible under § 213, subject to the 7.5 percent limitation. However, amounts paid for drugs (other than insulin) not requiring a prescription, such as nicotine gum and certain nicotine patches, are not deductible under § 213.

EFFECT ON OTHER DOCUMENTS

Rev. Rul. 79–162 is revoked.

DRAFTING INFORMATION

The principal authors of this revenue ruling are Donna M. Crisalli and John T. Sapienza, Jr. of the Office of Assistant Chief Counsel (Income Tax and Accounting). For further information regarding this revenue ruling, contact Ms. Crisalli or Mr. Sapienza on (202) 622-4920 (not a toll-free call).

Section 262.—Personal, Living, and Family Expenses

26 CFR 1.262–1: Personal, living, and family expenses.

Are uncompensated amounts paid by taxpayers for participation in a smoking-cessation program, for prescribed drugs designed to alleviate nicotine withdrawal, and for nicotine gum and nicotine patches that do not require a prescription, expenses for medical care that are deductible under § 213 of the Code. See Rev. Rul. 99–28, on this page.

Section 6621.— Determination of Interest Rate

26 CFR 301.6621–1: Interest rate.

Interest rates; underpayments and overpayments. The rate of interest deter

(Filed by the Office of the Federal Register on May 28, 1999, 11:22 a.m., and published in the issue of the Federal Register for June 3, 1999, 64 F.R. 29788)

Section 213.—Medical, Dental, Etc., Expenses

26 CFR 1.213–1: Medical, dental, etc., expenses. (Also section 262; 1.262–1.)

Medical expenses; smoking-cessation programs. Uncompensated amounts paid by taxpayers for participation in a smoking-cessation program and for prescribed drugs designed to alleviate nicotine withdrawal are expenses for medical care that are deductible under section 213 of the Code. The cost of nicotine gum and patches available without a prescription is not deductible as a medical expense. Rev. Rul. 79–162 is revoked.

Rev. Rul. 99–28

ISSUE

Are uncompensated amounts paid by taxpayers for participation in a smokingcessation program, for prescribed drugs designed to alleviate nicotine withdrawal, and for nicotine gum and nicotine patches that do not require a prescription, expenses for medical care that are deductible under § 213 of the Internal Revenue Code?

FACTS

Taxpayers A and B were cigarette smokers. A participated in a smokingcessation program and purchased nicotine gum and nicotine patches that did not require a prescription. A had not been diagnosed as having any specific disease, and participation in the program was not suggested by a physician. B purchased drugs that required a prescription of a physician to alleviate the effects of nicotine withdrawal. A ’s and B ’s costs were not compensated for by insurance or otherwise.

LAW AND ANALYSIS

Section 213(a) allows a deduction for uncompensated expenses for medical care of an individual, the individual’s spouse or a dependent to the extent the expenses exceed 7.5 percent of adjusted gross income. Section 213(d)(1) provides, in

part, that medical care means amounts paid for the diagnosis, cure, mitigation, treatment, or prevention of disease, or for the purpose of affecting any structure or function of the body.

Under § 213(b), a deduction is allowed for amounts paid during the taxable year for medicine or a drug only if the medicine or drug is a prescribed drug or insulin. Section 213(d)(3) defines a “prescribed drug” as a drug or biological that requires a prescription of a physician for its use by an individual.

Section 1.213–1(e)(1)(ii) of the Income Tax Regulations provides, in part, that the deduction for medical care expenses will be confined strictly to expenses incurred primarily for the prevention or alleviation of a physical or mental defect or illness. An expense that is merely beneficial to the general health of an individual is not an expense for medical care.

Section 262 provides that, except as otherwise expressly provided by the Code, no deduction is allowed for personal, living, or family expenses.

Rev. Rul. 79–162, 1979–1 C.B. 116, holds that a taxpayer who has no specific ailment or disease may not deduct as a medical expense under § 213 the cost of participating in a smoking-cessation program. However, the Internal Revenue Service has held that treatment for addiction to certain substances qualifies as medical care under § 213. See Rev. Rul. 73–325, 1973–2 C.B. 75 (alcoholism); Rev. Rul. 72–226, 1972–1 C.B. 96 (drug addiction). A report of the Surgeon General, The Health Consequences of Smoking: Nico- tine Addiction (1988), states that scientists in the field of drug addiction agree that nicotine, a substance common to all forms of tobacco, is a powerfully addictive drug. Other reports of the Surgeon General have concluded, based on numerous studies, that a strong causal link exists between smoking and several diseases. See, e.g., Tobacco Use Among U.S. Racial/ Ethnic Minority Groups (1998); Prevent- ing Tobacco Use Among Young People (1994); The Health Benefits of Smoking Cessation (1990). Scientific evidence has thus established that nicotine is addictive and that smoking is detrimental to the health of the smoker.

Under the facts provided, the smokingcessation program and the prescribed drugs are treatment for A ’s and B ’s addic

June 21, 1999 6 1999–25 I.R.B.

month of April 1999 is 5 percent. Accordingly, an overpayment rate of 8 percent (7 percent in the case of a corporation) and an underpayment rate of 8 percent are established for the calendar quarter beginning July 1, 1999. The overpayment rate for the portion of a corporate overpayment exceeding $10,000 for the calendar quarter beginning July 1, 1999, is 5.5 percent. The underpayment rate for large corporate underpayments for the calendar quarter beginning July 1, 1999, is 10 percent. These rates apply to amounts bearing interest during that calendar quarter.

Interest factors for daily compound interest for annual rates of 5.5 percent, 7 percent, 8 percent, and 10 percent are published in Tables 16, 19, 21, and 25 of Rev. Proc. 95–17, 1995–1 C.B. 556, 570, 573, 575, and 579. Annual interest rates to be compounded daily pursuant to § 6622 that apply for prior periods are set forth in the tables accompanying this revenue ruling.

DRAFTING INFORMATION

The principal author of this revenue ruling is Raymond Bailey of the Office of Assistant Chief Counsel (Income Tax and Accounting). For further information regarding this revenue ruling, contact Mr. Bailey on (202) 622-6226 (not a toll-free call).

mined under section 6621 of the Code for the calendar quarter beginning July 1, 1999, will be 8 percent for overpayments (7 percent in the case of a corporation), 8 percent for underpayments, and 10 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 is 5.5 percent.

Rev. Rul. 99–27

Section 6621 of the Internal Revenue Code establishes the rates for interest on tax overpayments and tax underpayments. Under § 6621(a)(1), the overpayment rate beginning July 1, 1999, is the sum of the federal short-term rate plus 3 percentage points (2 percentage points in the case of a corporation), except the rate for the portion of a corporate overpayment of tax exceeding $10,000 for a taxable period is the sum of the federal short-term rate plus 0.5 of a percentage point for interest computations made after December 31, 1994. Under § 6621(a)(2), the underpayment rate is the sum of the federal short-term rate plus 3 percentage points.

Section 6621(c) provides that for purposes of interest payable under § 6601 on any large corporate underpayment, the underpayment rate under § 6621(a)(2) is determined by substituting “5 percentage points” for “3 percentage points.” See § 6621(c) and § 301.6621–3 of the Regulations on Procedure and Administration

for the definition of a large corporate underpayment and for the rules for determining the applicable date. Section 6621(c) and § 301.6621–3 are generally effective for periods after December 31, 1990. Section 6621(b)(1) provides that the Secretary will determine the federal shortterm rate for the first month in each calendar quarter.

Section 6621(b)(2)(A) provides that the federal short-term rate determined under § 6621(b)(1) for any month applies during the first calendar quarter beginning after such month.

Section 6621(b)(3) provides that the federal short-term rate for any month is the federal short-term rate determined during such month by the Secretary in accordance with § 1274(d), rounded to the nearest full percent (or, if a multiple of ¹ ⁄2 of 1 percent, the rate is increased to the next highest full percent).

Notice 88–59, 1988–1 C.B. 546, announced that, in determining the quarterly interest rates to be used for overpayments and underpayments of tax under § 6621, the Internal Revenue Service will use the federal short-term rate based on daily compounding because that rate is most consistent with § 6621 which, pursuant to § 6622, is subject to daily compounding.

Rounded to the nearest full percent, the federal short-term rate based on daily compounding determined during the

TABLE OF INTEREST RATES

PERIODS BEFORE JUL. 1, 1975 – PERIODS ENDING DEC. 31, 1986

OVERPAYMENTS AND UNDERPAYMENTS

In 1995–1 C.B. PERIOD RATE DAILY RATE TABLE

Before Jul. 1, 1975 6% Table 2, pg. 557 Jul. 1, 1975–Jan. 31, 1976 9% Table 4, pg. 559 Feb. 1, 1976–Jan. 31, 1978 7% Table 3, pg. 558 Feb. 1, 1978–Jan. 31, 1980 6% Table 2, pg. 557 Feb. 1, 1980–Jan. 31, 1982 12% Table 5, pg. 560 Feb. 1, 1982–Dec. 31, 1982 20% Table 6, pg. 560 Jan. 1, 1983–Jun. 30, 1983 16% Table 37, pg. 591 Jul. 1, 1983–Dec. 31, 1983 11% Table 27, pg. 581 Jan. 1, 1984–Jun. 30, 1984 11% Table 75, pg. 629 Jul. 1, 1984–Dec. 31, 1984 11% Table 75, pg. 629 Jan. 1, 1985–Jun. 30, 1985 13% Table 31, pg. 585 Jul. 1, 1985–Dec. 31, 1985 11% Table 27, pg. 581 Jan. 1, 1986–Jun. 30, 1986 10% Table 25, pg. 579 Jul. 1, 1986–Dec. 31, 1986 9% Table 23, pg. 577

1999–25 I.R.B. 7 June 21, 1999

June 21, 1999 8 1999–25 I.R.B.

1999–25 I.R.B. 9 June 21, 1999

TABLE OF INTEREST RATES FOR LARGE CORPORATE UNDERPAYMENTS

FROM JANUARY 1, 1991 PRESENT—Continued

1995–1 C.B. RATE TABLE PG

Apr. 1, 1997–Jun. 30, 1997 11% 27 581 Jul. 1, 1997–Sep. 30, 1997 11% 27 581 Oct. 1, 1997–Dec. 31, 1997 11% 27 581 Jan. 1, 1998–Mar. 31, 1998 11% 27 581 Apr. 1, 1998–Jun. 30, 1998 10% 25 579 Jul. 1, 1998–Sep. 30, 1998 10% 25 579 Oct. 1, 1998–Dec. 31, 1998 10% 25 579 Jan. 1, 1999–Mar. 31, 1999 9% 23 577 Apr. 1, 1999–Jun. 30, 1999 10% 25 579 Jul. 1, 1999–Sep. 30, 1999 10% 25 579

TABLE OF INTEREST RATES FOR CORPORATE

OVERPAYMENTS EXCEEDING $10,000

FROM JANUARY 1, 1995 – PRESENT

1995–1 C.B. RATE TABLE PG

Jan. 1, 1995–Mar. 31, 1995 6.5% 18 572 Apr. 1, 1995–Jun. 30, 1995 7.5% 20 574 Jul. 1, 1995–Sep. 30, 1995 6.5% 18 572 Oct. 1, 1995–Dec. 31, 1995 6.5% 18 572 Jan. 1, 1996–Mar. 31, 1996 6.5% 66 620 Apr. 1, 1996–Jun. 30, 1996 5.5% 64 618 Jul. 1, 1996–Sep. 30, 1996 6.5% 66 620 Oct. 1, 1996–Dec. 31, 1996 6.5% 66 620 Jan. 1, 1997–Mar. 31, 1997 6.5% 18 572 Apr. 1, 1997–Jun. 30, 1997 6.5% 18 572 Jul. 1, 1997–Sep. 30, 1997 6.5% 18 572 Oct. 1, 1997–Dec. 31, 1997 6.5% 18 572 Jan. 1, 1998–Mar. 31, 1998 6.5% 18 572 Apr. 1, 1998–Jun. 30, 1998 5.5% 16 570 Jul. 1. 1998–Sep. 30, 1998 5.5% 16 570 Oct. 1, 1998–Dec. 31, 1998 5.5% 16 570 Jan. 1, 1999–Mar. 31, 1999 4.5% 14 568 Apr. 1, 1999–Jun. 30, 1999 5.5% 16 570 Jul. 1, 1999–Sep. 30, 1999 5.5% 16 570

June 21, 1999 10 1999–25 I.R.B.