Part IV. Items of General Interest

Therefore, the committee determines that the valuation problems inherent in trusts and term interests in property are best addressed by valuing retained interests at zero unless they take an easily valued form—as an annuity or unitrust interest. By doing so, the bill draws upon present law rules valuing split interests in property for purposes of the charitable deduction. 136 Cong. Rec. S15681 (daily ed. Oct. 18, 1990) (Informal Senate Report on S. 3209). The provisions of section 2702 and the regulations thereunder are intended to ensure that, when a donor transfers property and retains an interest in the property, the value of the retained interest is readily ascertainable. Thus, the value of the gift, that is, the value of the transferred property less the value of the retained interest, can be accurately determined. Section 25.2702–3(b)(1) of the Gift Tax Regulations implements this principle by requiring that for a qualified annuity interest: (1) the annuity must be a fixed amount; (2) the annuity must be payable at least annually; and (3) the yearly amount must be paid by a specified date each year, that is, the annuity payment may be paid after the close of the taxable year, but no later than the due date of the trust’s income tax return. The annuity payment must be payable to (or for the benefit of) the holder of the annuity interest for each taxable year of the trust term. A right of withdrawal, whether or not cumulative, is not a qualified annuity interest. Section 25.2702–3(c) provides comparable rules applicable in the case of a qualified unitrust interest.

To avoid making a cash or an in-kind payment, some GRATs have issued notes to the transferor in satisfaction of the obligation to make the annual payment. In certain cases, the trust instrument specifically authorizes the trustee to satisfy the annual payment obligation with notes. The notes provide for actual payment at a date some time in the future.

Thus far, the transactions that have come to the Service’s attention have involved the use of notes. However, the Service is also concerned about other financial arrangements that have the effect of delaying payment from the trust to the

Notice of Proposed Rulemaking and Notice of Public Hearing

Definition of a Qualified Interest in a Grantor Retained Annuity Trust and a Grantor Retained Unitrust

REG–108287–98

AGENCY: Internal Revenue Service (IRS), Treasury.

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

SUMMARY: This document contains proposed regulations relating to the definition of a qualified interest. The proposed regulations apply to a grantor retained annuity trust (GRAT) and a grantor retained unitrust (GRUT) in determining whether a retained interest is a “qualified interest.” The proposed regulations will affect individuals who have made a transfer in trust to a family member and have retained an interest in the trust. The proposed regulations clarify that a trust that uses a note, other debt instrument, option or similar financial arrangement to satisfy the annual payment obligation will not meet the requirements of section 2702(b) of the Internal Revenue Code. This document also provides notice of a public hearing on these proposed regulations.

DATES: Written comments must be received by September 20, 1999. Outlines of topics to be discussed at the public hearing scheduled for October 20, 1999, at 10:00 a.m., must be received by September 29, 1999.

ADDRESSES: Send submissions to: CC:DOM:CORP:R (REG–108287–98), room 5226, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044. Submissions may also be hand delivered Monday through Friday between the hours of 8 a.m. and 5 p.m. to: CC:DOM:CORP:R (REG–108287–98), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue, NW, Washington, DC. Alternatively, taxpayers may submit comments electronically via the internet by selecting the “Tax Regs” option on the IRS Home Page, or by sub

mitting comments directly to the IRS internet site at http://www.irs.gov/prod/tax regs/regslist.html. The public hearing will be held in the IRS Auditorium, Internal Revenue Building, 1111 Constitution Avenue, NW, Washington, DC.

FOR FURTHER INFORMATION CONTACT: Concerning the regulations, James F. Hogan, (202) 622-3090; concerning submissions of comments, the hearing, and/or to be placed on the building access list to attend the hearing, LaNita Van Dyke, (202) 622-7190 (not toll-free numbers).

SUPPLEMENTARY INFORMATION:

Background

Sections 2701 through 2704 were added to the Internal Revenue Code in the Omnibus Budget and Reconciliation Act of 1990 (1990 Act), 1991–2 C.B. 481, 524. Section 2702 applies to a transfer in trust that benefits a family member where the transferor retains an interest in the property subject to the transfer. If section 2702 applies to a transfer, the transferor’s retained interest will be valued at zero for gift tax purposes (and the transferor will be treated as making a gift of the entire value of the property), unless the interest is a “qualified interest.” The term “qualified interest” is defined in section 2702(b) and includes a right to receive, annually, fixed payments (a qualified annuity interest) and a right to receive, annually, a fixed percentage of the trust corpus determined annually (a qualified unitrust interest).

Congress was particularly concerned about properly valuing gifts in trust with retained interests. The legislative history that accompanied the 1990 Act states:

[T]he committee is concerned about the undervaluation of gifts valued pursuant to Treasury tables. Based on average rates of return and life expectancy, those tables are seldom accurate in a particular case, and therefore, may be the subject of adverse selection. Because the taxpayer decides what property to give, when to give it, and often controls the return on the property, use of Treasury tables undervalues the transferred interests in the aggregate, more often than not.

1999–28 I.R.B. 27 July 12, 1999

grantor and thus may alter the value of the transferor’s retained interest. These techniques include the grant of an option to purchase trust property in the future.

Issuing a note is not payment of a fixed amount not less frequently than annually, nor is it payment of a fixed percentage of the trust assets determined annually, as required by the statute and regulations. A note is merely a promise to pay in the future. Delaying payment by the use of a note to satisfy the annual payment obligation alters the true value of the transferor’s retained interest, contrary to Congressional intent in requiring provisions ensuring an accurate valuation of the interest. This position is consistent with case law and rulings concluding that the use of a note to satisfy an obligation does not constitute payment of the obligation for tax purposes. Don E. Williams Com- pany v. Commissioner, 429 U.S. 569 (1977); Helvering v. Price, 309 U.S. 409 (1940); Eckert v. Burnet; 283 U.S. 140 (1931); Maddrix v. Commissioner, 780 F.2d 946 (11th Cir. 1986); Battelstein v. Internal Revenue Service, 631 F.2d 1182 (5th Cir. 1980); Rev. Rul. 76–135, 1976–1 C.B. 114.

Furthermore, under §§25.2702–(3)(b)(1)(i) and 25.2702–(3)(c)(1)(i), a right of withdrawal is not a qualified annuity or unitrust interest. A right of withdrawal allows the payee to determine, in the payee’s discretion, when the payment will be made, and thus, neither the timing nor the amount of each payment is fixed and determinable under the trust instrument. For similar reasons, the use of notes, other debt instruments, options or other similar financial arrangements that place the amount and timing of each payment at the discretion of the payee should not satisfy the annual payment obligation.

Accordingly, these proposed regulations amend the regulations under section 2702 to provide that issuance of a note, other debt instrument, option or similar financial arrangement does not constitute payment for purposes of section 2702. A retained interest that can be satisfied with such instruments is not a qualified annuity interest or a qualified unitrust interest. In examining all of these transactions, the Service will apply the step transaction doctrine where more than one step is used to achieve similar results. In addition, a retained interest is not a qualified interest

under section 2702, unless the trust instrument expressly prohibits the use of notes, other debt instruments, options or similar financial arrangements that effectively delay receipt by the grantor of the annual payment necessary to satisfy the annuity or unitrust interest amount. Under these provisions, in order to satisfy the annuity or unitrust payment obligation under section 2702(b), the annuity or unitrust payment must be made with either cash or other assets held by the trust.

The proposed regulations provide a transition rule for trusts created before September 20, 1999. If a trust created before September 20, 1999, does not prohibit a trustee from issuing a note, other debt instrument, option or other similar financial arrangement in satisfaction of the annuity or unitrust payment obligation, the interest will be treated as a qualified interest under section 2702(b) if notes, etc. are not used after September 20, 1999, to satisfy the obligation and any note or notes or other debt instruments issued on or prior to September 20, 1999, to satisfy the annual payment obligation are paid in full by December 31, 1999, and any option or similar financial arrangement is terminated by December 31, 1999, such that the grantor actually receives cash or other trust assets in satisfaction of the payment obligation. For purposes of this section, an option will be considered terminated if the grantor is paid the greater of the required annuity or unitrust payment plus interest computed under section 7520 of the Code, or the fair market value of the option.

Special Analyses

It has been determined that this notice of proposed rulemaking is not a significant regulatory action as defined in EO 12866. Therefore, a regulatory assessment is not required. It also has been determined that section 553(b) of the Administrative Procedure Act (5 U.S.C. chapter 5) does not apply to these regulations, and because these regulations do not impose a collection of information on small 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, the regulations will be submitted to the Small

Business Administration for comment on their impact on small business.

Comments and Public Hearing

Before these proposed regulations are adopted as final regulations, consideration will be given to any written (a signed original and eight (8) copies) that are submitted timely to the IRS. The IRS and Treasury Department request comments on the clarity of the proposed rule and how it may be made easier to understand. All comments will be available for public inspection and copying.

A public hearing has been scheduled for October 20, 1999, at 10:00 a.m. in the IRS Auditorium, Internal Revenue Building, 1111 Constitution Avenue, NW, Washington, DC. Due to building security procedures, visitors must enter at the 10th Street entrance, located between Constitution and Pennsylvania Avenues, NW. In addition, all visitors must present photo identification to enter the building. Because of access restrictions, visitors will not be admitted beyond the immediate entrance area more than 15 minutes before the hearing starts. For information about having your name placed on the building access list to attend the hearing, see the “FOR FURTHER INFORMATION CONTACT” section of this preamble.

The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who wish to present oral comments at the hearing must submit comments by September 20, 1999, and submit an outline of the topics to be discussed and the time to be devoted to each topic (signed original and eight (8) copies) by September 29, 1999. A period of 10 minutes will be allotted to each person for making comments. An agenda showing the scheduling of the speakers will be prepared after the deadline for receiving outlines has passed. Copies of the agenda will be available free of charge at the hearing.

Drafting Information

The principal author of these proposed regulations is James F. Hogan, Office of the Chief Counsel, IRS. Other personnel from the IRS and Treasury Department participated in their development.

- - - -

July 12, 1999 28 1999–28 I.R.B.

Proposed Amendments to the Regulations

Accordingly, 26 CFR part 25 is proposed to be amended as follows:

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

Par. 1. The authority citation for part 25 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * * Par. 2. Section 25.2702–3 is amended as follows:

1. Paragraph (b)(1)(i) is amended by adding a new sentence after the third sentence.

2. Paragraph (c)(1)(i) is amended by adding a new sentence after the fourth sentence.

3. A new paragraph (d)(5) is added. The additions read as follows:

§25.2702–3 Qualified interests.

• ---

(b) * * * (1) * * * (i) * * * Issuance of a note, other debt instrument, option or other similar financial arrangement in satisfaction of the annuity amount does not constitute payment of the annuity amount. * * *

• ---

(c) * * * (1) * * * (i) * * * Issuance of a note, other debt instrument, option or other similar financial arrangement in satisfaction of the unitrust amount does not constitute payment of the unitrust amount. * * *

• ---

(d) * * * (5) Use of debt obligations to satisfy the annuity or unitrust payment obliga- tion —(i) In general. The trust instrument must prohibit the trustee from issuing a note, other debt instrument, option or other similar financial arrangement in satisfaction of the annuity or unitrust payment obligation.

(ii) Special rule in the case of a trust created prior to September 20, 1999. In

the case of a trust created prior to September 20, 1999, the interest will be treated as a qualified interest under section 2702(b) if—

(A) Notes, other debt instruments, options or similar financial arrangements are not used after September 20, 1999, to satisfy the annuity or unitrust payment obligation; and

• ---

Robert E. Wenzel, Deputy Commissioner of

Internal Revenue.

(Filed by the Office of the Federal Register on June 21, 1999, 8:45 a.m., and published in the issue of the Federal Register for June 22, 1999, 64 F.R. 33235)

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

Announcement 99–47

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to final regulations.

SUMMARY: This document contains

(B) Any note or notes or any other debt instruments issued to satisfy the annual payment obligation on or prior to September 20, 1999, are paid in full by December 31, 1999, and, any option or similar financial arrangement issued to satisfy the annual payment obligation is terminated by December 31, 1999, such that the grantor receives cash or other trust assets in satisfaction of the payment obligation. For purposes of the preceding sentence, an option will be considered terminated only

corrections to T.D. 8819, 1999–20 I.R.B. 5, final regulations relating to the use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests.

DATES: This correction is effective May 1, 1999.

FOR FURTHER INFORMATION CONTACT: William L. Blodgett (202) 6223090 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final regulations that are the subject of these corrections are under section 7520 and 2031 of the Internal Revenue Code.

Need for correction

As published, the final regulations contain errors that may prove to be misleading and are in need of clarification.

Correction of Publication

Accordingly, the publication of the final regulations (T.D. 8819), that were the subject of F.R. Doc. 99–10533 is corrected as follows:

1. On page 23188, in the table entitled “CROSS REFERENCE TO REGULATION SECTIONS”, in the column entitled “Interest rate”, line 11, the language “§7520.............” is corrected to read “§7520”.

PART 1 — [CORRECTED]

§1.170A–12T [Corrected]

2. On page 23189, column 3, §1.170A– 12T(b)(2), the formula is corrected to read as follows:

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

• ---

(b) (2) * * *

if the grantor receives cash or other trust assets equal in value to the greater of the required annuity or unitrust payment plus interest computed under section 7520 of the Code, or the fair market value of the option.

1999–28 I.R.B. 29 July 12, 1999

• ---

§1.7520–1T [Corrected]

3. On page 23211, column 1, §1.7520– 1T(c)(2) heading, line 3, the language “interest rates between 2.2 and 26” is corrected to read “interest rates between 2.2 and 22” .
4. On page 23211, column 1, §1.75201T(c)(2)(iii), line 5, the language “deprecation adjustment factors. See” is cor

rected to read “depreciation adjustment factors. See”.

PART 20 — [CORRECTED]

§20.2031–7A [Corrected]

5. On page 23212, column 1, §20.2031–7A(e)(4), line 9, the language “paragraph (b)(4), and Table B, Table J,” is corrected to read “paragraph (e)(4), and Table B, Table J,”.

6. On page 23212, column 2, §20.2031–7T(c), the table at the end of the paragraph is corrected to read as follows:

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

• ---

(c) * * *

Valuation Dates

Applicable After Before Regulations

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).

- - - -

7. On page 23222, §20.2031-7T(d)(7), in the table entitled “TABLE 90 CM. LIFE TABLE APPLICABLE AFTER APRIL 30, 1999”, the column headings are corrected to read as follows:

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

- - - -

(d) * * * (7) * * *

TABLE 90 CM. LIFE TABLE APPLICABLE AFTER APRIL 30, 1999

- - - -

§20.7520–1T [Corrected]

8. On page 23223, column 2, §20.7520–1T(c)(2) heading, line 3, the language “interest rates between 2.2 and 26” is corrected to read “interest rates between 2.2 and 22”.

PART 25 — [CORRECTED]

§25.7520–1T [Corrected]

9. On page 23227, column 3, §25.7520

1T(c)(2) heading, line 3, the language “interest rates between 2.2 and 26” is corrected to read “interest rates between 2.2 and 22” .

PARTS 1, 20, 25 — [CORRECTED]

10. On page 23228, in the table in amendatory instruction Par.32, the entry for 1.170A–6(c)(5), Example (2)(c) is added in numerical order; and the entries for 1.170A-6(c)(5), Example (2)(a), first sentence; 1.170A-6(c)(5), Example (3)(a), seventh and eighth sentences (the fifth

entry from top of chart); 1.642(c)– A6(e)(2)(i); 20.2055–2 (f)(2)(iv), Exam- ple (3), second sentence; 20.2055– 2(f)(2)(iv), Example (3), third sentence; 20.2056A–4(c)(4)(ii)(B), penultimate sentence; and 25.7520–1(c)(1), third sentence are corrected to read as follows:

July 12, 1999 30 1999–28 I.R.B.

Michael Slaughter, Acting Chief, Regulations Unit, Assistant Chief Counsel (Corporate).

(Filed by the Office of the Federal Register on June 21, 1999, 8:45 a.m., and published in the issue of the Federal Register for June 22, 1999, 64 F.R. 33194)

Information Reporting Seminar for 1999; Correction

Announcement 99–67

This announcement reflects information to be corrected in Announcement 99–59, 1999–24 I.R.B. 52, dated June 14, 1999.

1. The IRS/SSA seminar scheduled in Louisville, KY, on September 16, 1999, has been canceled.

2. The telephone number for the IRS/SSA seminar scheduled for Salt Lake City, UT, on September 2, 1999, has changed to 801-799-6876.

3. The telephone number for the IRS/SSA seminar scheduled for Tampa, FL, on September 23, 1999, has changed to 904-665-0520 and the fax number has changed to 904-665-1842.

Association, Snohomish, WA

Foundations Status of Certain Organizations

Announcement 99–68

Snowmass-Capitol Creek Caucus,

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

Former Public Charities. The following organizations (which have been treated as organizations that are not private foundations described in section 509(a) of the Code) are now classified as private foundations: Smith-Cotton Alumni Association,

Snowmass, CO Sober House, Port Angeles, WA Sober Lifestyles Inc., Houston, TX Social Work Association of the Veterans

Kansas City, KS Solo Arts Group Inc., New York, NY Solutions & Possibilities Inc., Columbus,

OH Solutions Business Center, Markham, IL

Administration, Woodside, CA Society for Preservation of McGrew

House Inc., Kingwood, WV Society for the Construction of an

Observatory for Public Education, Salt Lake City, UT Society for the Cultural Preservation of

Hist Jonesborough, Jonesborough, TN Society of Arab Americans Inc., Houston,

TX Society of Arab Womens Welfare Aid,

Chicago, IL Society of Connecticut Sculptors,

Windsor Locks, CT Socorro ISD PTO-PTA Inc., El Paso, TX Sojourners Athletic Club, Birmingham,

AL Solano County Visually Impaired Group,

Sedalia, MO Smoketown Neighborhood Development

Fairfield, CA Solid Believers Ministry Incorporated,

Incorporated, Louisville, KY Snohomish Valley Junior Football

1999–28 I.R.B. 31 July 12, 1999

Solutions for the Homeless, Baltimore,

South Hills Terrace Tenants

Organizations Inc., Brownsville, PA South Little Rock Community

MD Solutions Group Inc., Sandpoint, ID Somali Community of San Diego, San

Southeastern Climbers Coalition Inc.,

Chattanooga, TN Southeastern Community Development

Corporation, Rowland, NC Southeastern Institute for Law &

Commerce, Nashville, TN Southeastern Pennsylvania Womens

Diego, CA Somerville Players Inc., Tewksbury,

NJ South Orange Athletic Association Inc.,

MA Somnambulist Project, Chapel Hill, NC Sonny Billie Foundation for Native

Development Corporation, Little Rock, AR South Mountain Manor Inc., Vauxhall,

Ordination Conference, Blue Bell, PA Southern Arizona Hospice Memorial

Foundation, Tucson, AZ Southern California Tradeswomen

Culture Studies Inc., Ft. Lauderdale, FL Sonoma County Trails Council, Windsor,

Orlando, FL South Puget Environmental Education

Clearinghouse, Olympia, WA South Texas Chariot Wheelchair

CA Sons & Daughters of America Inc.,

Network, Fontana, CA Southern Colorado Coal Miners

Plantation, FL SOS Community Foundation, Fairview,

Basketball Association, Mission, TX South Texas Informer Educational

Foundation Inc., Corpus Christi, TX South Village Neighborhood Association

Memorial and Scholarship Fund, Trinidad, CO Southern Equine Educational Foundation

Inc., Hopkins, SC Southern Maryland Association for Deaf

OK Souderton Tourney Incorporated,

Inc., Indianapolis, IN Southeast Durham Development

Tylersport, PA Soul in Motion Players Inc.,

Gaithersburg, MD Souls of Wonder Inc., New York, NY Sound Vision Radio Reading Service for

the Blind Incorporated, Tulsa, OK Soundbyte Incorporated, Baltimore, MD South Asian Society on Atherosclerosis

and Thrombosis Inc., Minneapolis, MN South Bay Junior All American Football,

Corporation, Durham, NC Southeast Kirkwood Housing

Development Association Inc., Homestead, FL Southwest Center for World Missions,

Corporation, Kirkwood, MO Southeast Missouri Ballet Theatre, Cape

Children, Bryans Rd., MD Southern Minnesota Retrouvaille,

Mankato, MN Southern Onondaga Youth Football

Association Inc., Lafayette, NY Southern Regional Model United Nations

Inc., N. Miami Beach, FL Southern Union Gas Company Employee

Directed Charity, Austin, TX Southland Sheltie Rescue Inc., La Habra,

Girardeau, MO Southwest Arts in Action Inc., Sedona,

AZ Southwest Business & Economic

Torrance, CA South Bend Junior Chamber of

CA Southwestern Family Center Inc.,

Baltimore, MD Sovereign God Ministries Inc., College

Commerce Charitable Fund Inc., South Bend, IN South Carolina Association of Prevention

El Paso, TX Southwest Development Partnership Inc.,

Dallas, TX Southwest Firefighting Explorer Post

Cleveland, OH Southwest Fantasy Sports Foundation,

Station, TX Soweta Beat Street Theatre Inc.,

Professional and, Columbia, SC South Central Community Development

790, MacDona, TX Southwest Germantown Performing Arts

Marietta, GA Space Information Laboratories Inc.,

Vandenberg AFB, CA Spanish River Community High School

Committee Inc., Dallas, TX South Central Kentucky Soccer

Association Inc., Somerset, KY South Central Shepherds Center of

Center, Philadelphia, PA Southwest Iowa Humane Society,

Wichita Inc., Wichita, KS South Coast Storytellers Guild, Dana

Clarinda, IA Southwest Louisiana Economic

Foundation Inc., Boca Raton, FL Spearfish Youth Baseball Assoc. Inc.,

Spearfish, SD Special Education Booster Club Inc.,

Austin, TX Special Kids Equipment Association, San

Diego, CA Special People Accessing the Community

Point, CA South County Resource Center Inc.,

Venice, FL South Cumberland Regional Land Trust

Development Inc., Lake Charles, LA Southwest Lynx System Inc., Midland,

TX Southwest Trailriders Association Inc.,

Houston, TX Southwest Virginia Public Education

Inc., Sewanee, TN South Dakota Council on Problem

Equally Inc., Cincinnati, OH Spina Bifida Association of Akron Inc.,

Akron, OH Splendora Football Association,

Splendora, TX Sports Foundation of Texas Inc.,

Gambling, Sioux Falls, SD South East Atlanta Resource Center for

Housing Inc., Atlanta, GA South Florida Dance Theatre Inc., Boca

Foundation Inc., Wise, VA Southwest Wings Inc., Sierra Vista, AZ Southwest Yonkers Planning Association,

Yonkers, NY Southwest Rural Vision Enterprises

Houston, TX Sports Pride of America Foundation Inc.,

Raton, FL South Florida Reef Research Team,

Hallandale, FL South Georgia Baseball & Softball

Raleigh, NC Spotlight Productions, Poquoson, VA Spring Up O Well Inc., Benbrook, TX

Umpires Association Inc., Waycross, GA

Foundation, Kindred, ND Southeast Texas Trauma Regional

Advisory Council, Houston, TX Southeastern Animal Fiber Fair,

Hillsborough, NC

July 12, 1999 32 1999–28 I.R.B.

Sweetwater Crisis Pregnancy Center Inc.,

Springfield Area Soccer Assoc.,

Stephen Girard Memorial Committee

Springfield, IL St. Anthonys Catholic School

Endowment Fund Inc., Lakeland, FL St. Clair County Housing Development

Inc., Philadelphia, PA Stepping High Youth Club Inc.,

Clearwater, FL Stop and Recover, Philadelphia, PA Stow Munroe Falls Library Foundation

Sweetwater, TX Swing Orchestra Institute of Chicago,

Chicago, IL Sylacauga Jaycees Childrens Fund Inc.,

Corporation, Fort Gratiot, MI St. Francis Center at the Knolls Inc.,

Inc., Stow, OH Straight & Narrow Inc., Lake Forest, IL Strategic Arts Alliance Inc., Tinker AFB,

Sylacauga, AL Symphonic Fund Inc., Galesburg, IL Synergy Research Consortium,

Pittsburgh, PA Syosset Baseball Association Inc.,

Warwick, NY St. James USA Inc., Ellington, CT St. John Bosco Educational Society

Desert Solitaire, Dolores, CO St. John Institute of Culture Inc., Cruz

Bay, VI St.Joseph Fire Museum Inc., St. Joseph,

OK Strategies for the Disadvantaged &

Indigent, Mitchellville, MD Straughn Memorial Diabetes Ride,

Mancelona, MI Substance Abuse Management and

MO St. Jude Day Care Center Incorporated,

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

Memphis, TN St. Louis Firefighter Memorial Statue

Inc., St. Louis, MO St. Louis Knights Soccer Club, St. Louis,

Development Corporation, Cincinnati, OH Substance Abuse Recovery Group Inc.,

Great Falls, MT Suda for Ex-Offenders Inc., Adams

Basin, NY Suffolk Essential Needs for Seniors

MO St. Martin De Porres Center, San Diego,

CA St. Mary Crime Stoppers Inc., Morgan

City, LA St. Matthew Housing Corp., Milwaukee,

WI St. Peters Homes Inc., Charlotte, NC St. Rose Center Support Board, Chicago,

Effort Inc., Commack, NY Sugar Land Select Soccer Club,

Incorporated, Lenexa, KS Sunny Hills High School Athletic Fund,

Sugarland, TX Summer Incentive Program Foundation,

Cincinnati, OH Summer Academy Alumni Association

IL St. Stephen Parent Teachers

Organization, St. Stephen, MN Stage Studio Inc., Largo, FL Stagelights, Williamsburg, VA Stan Ham Memorial Bull Ride and Bull

Fullerton, CA Sunshine Emergency Shelter and

Fight, Odessa, TX Stana Foundation for Democracy,

Residential Home, Loma Linda, CA Sunshine Health Foundation Inc.,

Chantilly, VA Stand-Up Incorporated, Kansas City, MO Star Flight Fund Inc., Austin, TX Starfire Council of Greater Cincinnati

Pompano Beach, FL Sunshine House Inc., Fresno, CA Support Our Communities Kids Inc.,

Gainesville, FL Support Services Network Inc., San

Angelo, TX Survivors of Suicide, Aurora, IL Susquehanna River Arts Center Inc.,

Inc., Cincinnati, OH Starke County Child Abuse Prevention

Clearfield, PA Sustainability Project Inc., Santa Fe, NM Swap Inc., West Annapolis, MD

Page Numbers in Internal Revenue Bulletins

Announcement 99–69

Beginning with Internal Revenue Bulletin (IRB) 1999–28, the page numbers will run consecutively from one IRB to the next. Since IRB 1999–27 ended on page 18, this IRB starts with page 19. Previously, each IRB started with page one.

This change is based on Announcement 99–36, 1999–16 IRB 10, which stated that reprints of weekly IRBs will be bound together to form the Cumulative Bulletin (CB). With this new numbering system, the page number for an item will be the same in the CB as it is in the IRB.

Council Inc., Knox, IN Starr Fine Arts Ranch, Wimberly, TX Stat Team, San Antonio, TX

1999–28 I.R.B. 33 July 12, 1999