Internal Revenue Bulletin 2000-39

Official source: Internal Revenue Bulletin (https://www.irs.gov/pub/irs-irbs/irb00-39.pdf), retrieved 2026-10-03. U.S. Government work (17 U.S.C. § 105).

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These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

Rev. Rul. 2000–42, page 297. Interest rates; underpayments and overpayments. The rate of interest determined under section 6621 of the Code for the calendar quarter beginning October 1, 2000, will be 9 percent for overpayments (8 percent in the case of a corporation), 9 percent for underpayments, and 11 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 is 6.5 percent.

Notice 2000–42, page 302. Weighted average interest rate update. The weighted average interest rate for September 2000 and the resulting permissible range of interest rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code are set forth.

Finding Lists begin on page ii.

Department of the Treasury Internal Revenue Service

Announcement 2000–79, page 303. A list is given of organizations now classified as private foundations.

Provide America’s taxpayers top quality service by helping them understand and meet their tax responsibilities

The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It is published weekly and may be obtained from the Superintendent of Documents on a subscription basis. Bulletin contents are consolidated semiannually into Cumulative Bulletins, which are sold on a single-copy basis.

It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published.

Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements.

Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and proce

and by applying the tax law with integrity and fairness to all.

dures must be considered, and Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same.

The Bulletin is divided into four parts as follows:

Part I.—1986 Code. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1986.

Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions, and Subpart B, Legislation and Related Committee Reports.

Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Subparts. Also included in this part are Bank Secrecy Act Administrative Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement).

Part IV.—Items of General Interest. This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.

The first Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the first Bulletin of the succeeding semiannual period, respectively.

The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.

For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402.

September 25, 2000 2000–39 I.R.B.

Rounded to the nearest full percent, the federal short- term rate based on daily compounding determined during the month of July 2000 is 6 percent. Accordingly, an overpayment rate of 9 percent (8 percent in the case of a corporation) and an underpayment rate of 9 percent are established for the calendar quarter beginning October 1, 2000. The overpayment rate for the portion of a corporate overpayment exceeding $10,000 for the calendar quarter beginning October 1, 2000, is 6.5 percent. The underpayment rate for large corporate underpayments for the calendar quarter beginning October 1, 2000, is 11 percent. These rates apply to amounts bearing interest during that calendar quarter.

Interest factors for daily compound interest for annual rates of 6.5 percent, 8 percent, 9 percent, and 11 percent are published in Tables 66, 69, 71, and 75 of Rev. Proc. 95–17, 1995–1 C.B. 556, 620, 623, 625, and 629. 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 (Administrative Provisions and Judicial Practice). For further information regarding this revenue ruling, contact Mr. Bailey at (202) 6226226 (not a toll-free call).

Section 6621.—Determination of Interest Rate

26 CFR 301.6621–1: Interest rate.

Interest rates; underpayments and overpayments. The rate of interest determined under section 6621 of the Code for the calendar quarter beginning October 1, 2000, will be 9 percent for overpayments (8 percent in the case of a corporation), 9 percent for underpayments, and 11 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 is 6.5 percent.

Rev. Rul. 2000–42

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 October 1, 2000, 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 un

derpayment 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.

2000–39 I.R.B. 297 September 25, 2000

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

TABLE OF INTEREST RATES

FROM JAN. 1, 1987 - Dec. 31, 1998

OVERPAYMENTS UNDERPAYMENTS

1995–1 C.B. 1995–1 C.B. RATE TABLE PG RATE TABLE PG

Jan. 1, 1987—Mar. 31, 1987 8% 21 575 9% 23 577 Apr. 1, 1987—Jun. 30, 1987 8% 21 575 9% 23 577 Jul. 1, 1987—Sep. 30, 1987 8% 21 575 9% 23 577 Oct. 1, 1987—Dec. 31, 1987 9% 23 577 10% 25 579 Jan. 1, 1988—Mar. 31, 1988 10% 73 627 11% 75 629 Apr. 1, 1988—Jun. 30, 1988 9% 71 625 10% 73 627 Jul. 1, 1988—Sep. 30, 1988 9% 71 625 10% 73 627 Oct. 1, 1988—Dec. 31, 1988 10% 73 627 11% 75 629 Jan. 1, 1989—Mar. 31, 1989 10% 25 579 11% 27 581 Apr. 1, 1989—Jun. 30, 1989 11% 27 581 12% 29 583 Jul. 1, 1989—Sep. 30, 1989 11% 27 581 12% 29 583 Oct. 1, 1989—Dec. 31, 1989 10% 25 579 11% 27 581 Jan. 1, 1990—Mar. 31, 1990 10% 25 579 11% 27 581 Apr. 1, 1990—Jun. 30, 1990 10% 25 579 11% 27 581 Jul. 1, 1990—Sep. 30, 1990 10% 25 579 11% 27 581 Oct. 1, 1990—Dec. 31, 1990 10% 25 579 11% 27 581 Jan. 1, 1991—Mar. 31, 1991 10% 25 579 11% 27 581 Apr. 1, 1991—Jun. 30, 1991 9% 23 577 10% 25 579 Jul. 1, 1991—Sep. 30, 1991 9% 23 577 10% 25 579 Oct. 1, 1991—Dec. 31, 1991 9% 23 577 10% 25 579 Jan. 1, 1992—Mar. 31, 1992 8% 69 623 9% 71 625 Apr. 1, 1992—Jun. 30, 1992 7% 67 621 8% 69 623 Jul. 1, 1992—Sep. 30, 1992 7% 67 621 8% 69 623 Oct. 1, 1992—Dec. 31, 1992 6% 65 619 7% 67 621 Jan. 1, 1993—Mar. 31, 1993 6% 17 571 7% 19 573 Apr. 1, 1993—Jun. 30, 1993 6% 17 571 7% 19 573 Jul. 1, 1993—Sep. 30, 1993 6% 17 571 7% 19 573 Oct. 1, 1993—Dec. 31, 1993 6% 17 571 7% 19 573 Jan. 1, 1994—Mar. 31, 1994 6% 17 571 7% 19 573 Apr. 1, 1994—Jun. 30, 1994 6% 17 571 7% 19 573

September 25, 2000 298 2000–39 I.R.B.

TABLE OF INTEREST RATES—Continued

FROM JAN. 1, 1987 - Dec. 31, 1998

OVERPAYMENTS UNDERPAYMENTS

1995–1 C.B. 1995–1 C.B. RATE TABLE PG RATE TABLE PG

Jul. 1, 1994—Sep. 30, 1994 7% 19 573 8% 21 575 Oct. 1, 1994—Dec. 31, 1994 8% 21 575 9% 23 577 Jan. 1, 1995—Mar. 31, 1995 8% 21 575 9% 23 577 Apr. 1, 1995—Jun. 30, 1995 9% 23 577 10% 25 579 Jul. 1, 1995—Sep. 30, 1995 8% 21 575 9% 23 577 Oct. 1, 1995—Dec. 31, 1995 8% 21 575 9% 23 577 Jan. 1, 1996—Mar. 31, 1996 8% 69 623 9% 71 625 Apr. 1, 1996—Jun. 30, 1996 7% 67 621 8% 69 623 Jul. 1, 1996—Sep. 30, 1996 8% 69 623 9% 71 625 Oct. 1, 1996—Dec. 31, 1996 8% 69 623 9% 71 625 Jan. 1, 1997—Mar. 31, 1997 8% 21 575 9% 23 577 Apr. 1, 1997—Jun. 30, 1997 8% 21 575 9% 23 577 Jul. 1, 1997—Sep. 30, 1997 8% 21 575 9% 23 577 Oct. 1, 1997—Dec. 31, 1997 8% 21 575 9% 23 577 Jan. 1, 1998—Mar. 31, 1998 8% 21 575 9% 23 577 Apr. 1, 1998—Jun. 30, 1998 7% 19 573 8% 21 575 Jul. 1, 1998—Sep. 30, 1998 7% 19 573 8% 21 575 Oct. 1, 1998—Dec. 31, 1998 7% 19 573 8% 21 575

TABLE OF INTEREST RATES

FROM JANUARY 1, 1999 - PRESENT

NONCORPORATE OVERPAYMENTS AND UNDERPAYMENTS

1995–1 C.B. RATE TABLE PAGE

Jan. 1, 1999—Mar. 31, 1999 7% 19 573 Apr. 1, 1999—Jun. 30, 1999 8% 21 575 Jul. 1, 1999—Sep. 30, 1999 8% 21 575 Oct. 1, 1999—Dec. 31, 1999 8% 21 575 Jan. 1, 2000—Mar. 31, 2000 8% 69 623 Apr. 1, 2000—Jun. 30, 2000 9% 71 625 Jul. 1, 2000—Sep. 30, 2000 9% 71 625 Oct. 1, 2000—Dec 31, 2000 9% 71 625

TABLE OF INTEREST RATES

FROM JANUARY 1, 1999 - PRESENT

CORPORATE OVERPAYMENTS AND UNDERPAYMENTS

OVERPAYMENTS UNDERPAYMENTS

1995–1 C.B. 1995–1 C.B. RATE TABLE PG RATE TABLE PG

Jan. 1, 1999—Mar. 31, 1999 6% 17 571 7% 19 573 Apr. 1, 1999—Jun. 30, 1999 7% 19 573 8% 21 575 Jul. 1, 1999—Sep. 30, 1999 7% 19 573 8% 21 575 Oct. 1, 1999—Dec. 31, 1999 7% 19 573 8% 21 575 Jan. 1, 2000—Mar. 31, 2000 7% 67 621 8% 69 623 Apr. 1, 2000—Jun. 30, 2000 8% 69 623 9% 71 625 Jul. 1, 2000—Sep. 30, 2000 8% 69 623 9% 71 625 Oct. 1, 2000—Dec. 31, 2000 8% 69 623 9% 71 625

2000–39 I.R.B. 299 September 25, 2000

TABLE OF INTEREST RATES FOR LARGE CORPORATE UNDERPAYMENTS

FROM JANUARY 1, 1991 - PRESENT

1995–1 C.B. RATE TABLE PG

Jan. 1, 1991—Mar. 31, 1991 13% 31 585 Apr. 1, 1991—Jun. 30, 1991 12% 29 583 Jul. 1, 1991—Sep. 30, 1991 12% 29 583 Oct. 1, 1991—Dec. 31, 1991 12% 29 583 Jan. 1, 1992—Mar. 31, 1992 11% 75 629 Apr. 1, 1992—Jun. 30, 1992 10% 73 627 Jul. 1, 1992—Sep. 30, 1992 10% 73 627 Oct. 1, 1992—Dec. 31, 1992 9% 71 625 Jan. 1, 1993—Mar. 31, 1993 9% 23 577 Apr. 1, 1993—Jun. 30, 1993 9% 23 577 Jul. 1, 1993—Sep. 30, 1993 9% 23 577 Oct. 1, 1993—Dec. 31, 1993 9% 23 577 Jan. 1, 1994—Mar. 31, 1994 9% 23 577 Apr. 1, 1994—Jun. 30, 1994 9% 23 577 Jul. 1, 1994—Sep. 30, 1994 10% 25 579 Oct. 1, 1994—Dec. 31, 1994 11% 27 581 Jan. 1, 1995—Mar. 31, 1995 11% 27 581 Apr. 1, 1995—Jun. 30, 1995 12% 29 583 Jul. 1, 1995—Sep. 30, 1995 11% 27 581 Oct. 1, 1995—Dec. 31, 1995 11% 27 581 Jan. 1, 1996—Mar. 31, 1996 11% 75 629 Apr. 1, 1996—Jun. 30, 1996 10% 73 627 Jul. 1, 1996—Sep. 30, 1996 11% 75 629 Oct. 1, 1996—Dec. 31, 1996 11% 75 629 Jan. 1, 1997—Mar. 31, 1997 11% 27 581 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 Oct. 1, 1999—Dec. 31, 1999 10% 25 579 Jan. 1, 2000—Mar. 31, 2000 10% 73 627 Apr. 1, 2000—Jun. 30, 2000 11% 75 629 Jul. 1, 2000—Sep. 30, 2000 11% 75 629 Oct. 1, 2000—Dec. 1, 2000 11% 75 629

September 25, 2000 300 2000–39 I.R.B.

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 Oct. 1, 1999—Dec. 31, 1999 5.5% 16 570 Jan. 1, 2000—Mar. 31, 2000 5.5% 64 618 Apr. 1, 2000—Jun. 30, 2000 6.5% 66 620 Jul. 1, 2000—Sep. 30, 2000 6.5% 66 620 Oct. 1, 2000—Dec. 31, 2000 6.5% 66 620

2000–39 I.R.B. 301 September 25, 2000

The average yield on the 30-year Treasury Constant Maturities for August 2000 is 5.72 percent.

The following rates were determined for the plan years beginning in the month shown below.

Weighted Average Interest Rate Update

Notice 2000–42

Notice 88–73 provides guidelines for determining the weighted average interest rate and the resulting permissible range of

interest rates used to calculate current liability for the purpose of the full funding limitation of § 412(c)(7) of the Internal Revenue Code as amended by the Omnibus Budget Reconciliation Act of 1987 and as further amended by the Uruguay Round Agreements Act, Pub. L. 103-465 (GATT).

90% to 105% 90% to 110% Weighted Permissible Permissible Month Year Average Range Range

September 2000 5.96 5.36 to 6.26 5.36 to 6.56

Drafting Information

The principal author of this notice is Todd Newman of the Employee Plans, Tax Exempt and Government Entities Division. For further information regarding this notice, call the Employee Plans Actuarial hotline, (202) 622-6076 between 2:30 and 3:30 p.m. Eastern time (not a toll-free number). Mr. Newman’s number is (202) 622-8458 (also not a toll-free number).

September 25, 2000 302 2000–39 I.R.B.

SHARE Supportive Housing and

Foundations Status of Certain Organizations

Announcement 2000–79

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:

Dansville Ambulance Company, Inc.,

Education, Rupert, ID IDEC or` Intake-Discharge Evaluation

Center, Houston, TX Institute for Better Education Through

Dansville, NY East Little Rock Community

Development Corporation, Little Rock, AR Eastern Maine Conservation Initiative,

Resources for the Elderly, Las Vegas, NV Soccer Association of Warren County,

Portland, ME Edward I. Rich Family Organization,

Inc., Salt Lake City, UT ESB Foundation, Tacoma, WA FRP Community Housing Corporation,

Warren, PA South Plainfield Vision 2001 Education

Foundation, Inc., South Plainfield, NJ Springfield Parents Recreation

Association, Inc., Springfield, NJ St. Joseph County Courthouse

Philadelphia, PA Good Samaritan Ministries International,

Restoration Corporation, South Bend, IN Sustainable Communities, Inc.,

Santa Fe, NM Terreverte Foundation, Cliffside Park, NJ Theodora B. Brown Scholarship Fund,

Inc., Hillside, IL Hamilton Amateur Figure Skating

Association, Inc., Trenton, NJ Health Development International,

Santee, CA Hispanic American Medical Scholarship

Inc., Red Bank, NJ Topeka Shawnee County Child &

Fund, Houston, TX Idaho Association For Bilingual

Against All Odds, Inc., Livingston, NJ Agape Multi-Purpose Ministry, Inc.,

Adolescent Assessment Center, Inc., Topeka, KS Total Truth Ministries, Inc., Ottawa, IL Trinity Housing Services, Inc., Paoli, PA United States of America Foundation,

San Diego, CA United States Water Fitness Association,

Inc., Boynton Beach, FL Villa Encantada, Inc., Albuquerque, NM Warthog Productions, Inc., Boston, MA Wasco County Historical Museum,

Compton, CA American Advocate, Inc., Baltimore, MD American Family Thrift Stores,

Resource Technology, Northridge, CA Institute of American Studies, Inc.,

Rowland Heights, CA Madison Youth Theatre, Madison, CT MBARI Institute for Contemporary

Sarasota, FL International Cultural League,

The Dalles, OR Welcome Grove Development Center,

Brighton, MA Arkansas Housing Partnership, Inc.,

Little Rock, AR Ayehu Brehan Foundation, Inc.,

Inc., Atlanta, GA Winokur Family Foundation

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.

Ft. Washington, MD Caretuck Farms Foundation, Inc.,

Lake Toxaway, NC Children’s Pennsylvania Adoption

Wynnewood, PA Young People Working for Christ,

Wichita, KS

Network, Erie, PA Christian Sports Camp, Inc., Doyle, TN Christmas in April Carroll County, Inc.,

African Art, Inc., Washington, DC New Vision Services, Inc., Neenah, WI North Louisiana Child Development

Agency, Inc., Jonesboro, LA Oakland Technical High School Library

Fund, Inc., Oakland, CA Odyssey for Peace, Bexley, OH Palm Beach Seaport Aquarium,

Westminster, MD Cirik Foundation, Bonifacius, MN Committee Hermandad Pro-Aguilares,

Murietta, CA Community Brainstorming Foundation of

Tequest, FL Pinnacle Foundation, Inc., Milburn, NJ PSI Chapter Diamond Association

Charitable Foundation, Inc., Wheeling, WV Ruby Diamond Breast Cancer

Milwaukee, Inc., Milwaukee, WI Community Communications Center,

Inc., New Haven, CT Cyberlife Eternal, Inc., Fremont, CA

Foundation, University Heights, OH San Antonio Business Development

Corporation, San Antonio, TX

2000–39 I.R.B. 303 September 25, 2000

Revenue rulings and revenue procedures (hereinafter referred to as “rulings”) that have an effect on previous rulings use the following defined terms to describe the effect:

Amplified describes a situation where no change is being made in a prior published position, but the prior position is being extended to apply to a variation of the fact situation set forth therein. Thus, if an earlier ruling held that a principle applied to A, and the new ruling holds that the same principle also applies to B, the earlier ruling is amplified. (Compare with modified, below).

Clarified is used in those instances where the language in a prior ruling is being made clear because the language has caused, or may cause, some confusion. It is not used where a position in a prior ruling is being changed.

Distinguished describes a situation where a ruling mentions a previously published ruling and points out an essential difference between them.

Modified is used where the substance of a previously published position is being changed. Thus, if a prior ruling held that a principle applied to A but not to B, and the new ruling holds that it ap

The following abbreviations in current use and for- merly used will appear in material published in the Bulletin.

A —Individual. Acq. —Acquiescence. B —Individual. BE —Beneficiary. BK —Bank. B.T.A. —Board of Tax Appeals. C —Individual. C.B. —Cumulative Bulletin. CFR —Code of Federal Regulations. CI —City. COOP —Cooperative. Ct.D. —Court Decision. CY —County. D —Decedent. DC —Dummy Corporation. DE —Donee. Del. Order —Delegation Order. DISC —Domestic International Sales Corporation. DR —Donor. E —Estate. EE —Employee.

plies to both A and B, the prior ruling is modified because it corrects a published position. (Compare with amplified and clarified, above).

Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions. This term is most commonly used in a ruling that lists previously published rulings that are obsoleted because of changes in law or regulations. A ruling may also be obsoleted because the substance has been included in regulations subsequently adopted.

Revoked describes situations where the position in the previously published ruling is not correct and the correct position is being stated in the new ruling.

Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings). Thus, the term is used to republish under the 1986 Code and regulations the same position published under the 1939 Code and regulations. The term is also used when it is desired to republish in a single ruling a series of situations, names, etc., that were previously published over a period of time in separate rulings. If the

E.O. —Executive Order. ER —Employer. ERISA —Employee Retirement Income Security Act. EX —Executor. F —Fiduciary. FC —Foreign Country. FICA —Federal Insurance Contributions Act. FISC —Foreign International Sales Company. FPH —Foreign Personal Holding Company. F.R. —Federal Register. FUTA —Federal Unemployment Tax Act. FX —Foreign Corporation. G.C.M. —Chief Counsel’s Memorandum. GE —Grantee. GP —General Partner. GR —Grantor. IC —Insurance Company. I.R.B. —Internal Revenue Bulletin. LE —Lessee. LP —Limited Partner. LR —Lessor. M —Minor. Nonacq. —Nonacquiescence. O —Organization. P —Parent Corporation.

new ruling does more than restate the substance of a prior ruling, a combination of terms is used. For example, modified and superseded describes a situation where the substance of a previously published ruling is being changed in part and is continued without change in part and it is desired to restate the valid portion of the previously published ruling in a new ruling that is self contained. In this case the previously published ruling is first modified and then, as modified, is superseded.

Supplemented is used in situations in which a list, such as a list of the names of countries, is published in a ruling and that list is expanded by adding further names in subsequent rulings. After the original ruling has been supplemented several times, a new ruling may be published that includes the list in the original ruling and the additions, and supersedes all prior rulings in the series.

Suspended is used in rare situations to show that the previous published rulings will not be applied pending some future action such as the issuance of new or amended regulations, the outcome of cases in litigation, or the outcome of a Service study.

PHC —Personal Holding Company. PO —Possession of the U.S. PR —Partner. PRS —Partnership. PTE —Prohibited Transaction Exemption. Pub. L. —Public Law. REIT —Real Estate Investment Trust. Rev. Proc. —Revenue Procedure. Rev. Rul. —Revenue Ruling. S —Subsidiary. S.P.R. —Statements of Procedural Rules. Stat. —Statutes at Large. T —Target Corporation. T.C. —Tax Court. T.D. —Treasury Decision. TFE —Transferee. TFR —Transferor. T.I.R. —Technical Information Release. TP —Taxpayer. TR —Trust. TT —Trustee. U.S.C. —United States Code. X —Corporation. Y —Corporation. Z —Corporation.

September 25, 2000 i 2000–39 I.R.B.

Numerical Finding List ¹

Bulletins 2000–27 through 2000–38

Announcements: 2000–57, 2000–28 I.R.B. 115 2000–58, 2000–30 I.R.B. 135 2000–59, 2000–29 I.R.B. 120 2000–60, 2000–31 I.R.B. 149 2000–61, 2000–30 I.R.B. 136 2000–62, 2000–30 I.R.B. 137 2000–63, 2000–31 I.R.B. 149 2000–64, 2000–31 I.R.B. 149 2000–65, 2000–31 I.R.B. 150 2000–66, 2000–32 I.R.B. 160 2000–67, 2000–32 I.R.B. 160 2000–68, 2000–32 I.R.B. 161 2000–69, 2000–33 I.R.B. 183 2000–70, 2000–34 I.R.B. 204 2000–72, 2000–35 I.R.B. 226 2000–73, 2000–35 I.R.B. 230 2000–74, 2000–35 I.R.B. 230 2000–75, 2000–37 I.R.B. 268 2000–76, 2000–36 I.R.B. 260 2000–77, 2000–36 I.R.B. 260

Court Decisions: 2068, 2000–28 I.R.B. 109

Notices: 2000–33, 2000–27 I.R.B. 97 2000–34, 2000–33 I.R.B. 172 2000–35, 2000–29 I.R.B. 118 2000–36, 2000–33 I.R.B. 173 2000–37, 2000–29 I.R.B. 118 2000–38, 2000–33 I.R.B. 174 2000–39, 2000–30 I.R.B. 132 2000–40, 2000–30 I.R.B. 134 2000–41, 2000–33 I.R.B. 177 2000–43, 2000–35 I.R.B. 209 2000–44, 2000–36 I.R.B. 255 2000–45, 2000–36 I.R.B. 256 2000–46, 2000–37 I.R.B. 265 2000–48, 2000–37 I.R.B. 265 2000–49, 2000–37 I.R.B. 266 2000–50, 2000–38 I.R.B. 291 2000–51, 2000–38 I.R.B. 291 2000–52, 2000–38 I.R.B. 292 2000–53, 2000–38 I.R.B. 293

Proposed Regulations: REG–209038–89, 2000–34 I.R.B. 191 REG–105316–98, 2000–27 I.R.B. 98 REG–110311–98, 2000–36 I.R.B. 258 REG–116495–99, 2000–33 I.R.B. 179 REG–103735–00, 2000–36 I.R.B. 258 REG–103736–00, 2000–36 I.R.B. 258 REG–108522–00, 2000–34 I.R.B. 187

Railroad Retirement Quarterly Rate: 2000–28, I.R.B. 112 2000–29, I.R.B. 117

Revenue Procedures: 2000–28, 2000–27 I.R.B. 60 2000–29, 2000–28 I.R.B. 113 2000–30, 2000–28 I.R.B. 113 2000–31, 2000–31 I.R.B. 146 2000–32, 2000–33 I.R.B. 172 2000–33, 2000–36 I.R.B. 257

1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2000–1 through 2000–26 is in Internal Revenue Bulletin 2000–27, dated July 3, 2000.

Revenue Procedures—continued: 2000–34, 2000–34 I.R.B. 186 2000–35, 2000–35 I.R.B. 211 2000–36, 2000–37 I.R.B. 267

Revenue Rulings: 2000–32, 2000–27 I.R.B. 1 2000–33, 2000–31 I.R.B. 142 2000–34, 2000–29 I.R.B. 116 2000–35, 2000–31 I.R.B. 138 2000–36, 2000–31 I.R.B. 140 2000–37, 2000–32 I.R.B. 156 2000–38, 2000–32 I.R.B. 157 2000–39, 2000–34 I.R.B. 184 2000–40, 2000–35 I.R.B. 208 2000–41, 2000–36 I.R.B. 248 2000–47, 2000–37 I.R.B. 264

Treasury Decisions: 8886, 2000–27 I.R.B. 3 8888, 2000–27 I.R.B. 3 8889, 2000–30 I.R.B. 124 8890, 2000–30 I.R.B. 122 8891, 2000–32 I.R.B. 152 8892, 2000–32 I.R.B. 158 8893, 2000–31 I.R.B. 143 8894, 2000–33 I.R.B. 162 8896, 2000–36 I.R.B. 249 8897, 2000–36 I.R.B. 234 8898, 2000–38 I.R.B. 276 8899, 2000–38 I.R.B. 288 8900, 2000–38 I.R.B. 279 8901, 2000–38 I.R.B. 272

2000–39 I.R.B. ii September 25, 2000

Finding List of Current Actions on Previously Published Items ¹

Bulletins 2000–27 through 2000–38

Notices:

87–76 Obsoleted by T.D. 8897, 2000–36 I.R.B. 234

88–24 Obsoleted by T.D. 8897, 2000–36 I.R.B. 234

88–86 Obsoleted by T.D. 8897 (section V), 2000–36 I.R.B. 234

Proposed Regulations:

FI–42–90 Withdrawn by Announcement 2000–63, 2000–31 I.R.B. 149

IA–38–93 Withdrawn by Announcement 2000–68, 2000–32 I.R.B. 161

REG–107644–98 Corrected by Announcement 2000–66, 2000–32 I.R.B. 160

Revenue Procedures:

88–23 Superseded by Rev. Proc. 2000–35, 2000–35 I.R.B. 211

98–50 Modified and superseded by Rev. Proc. 2000–31, 2000–31 I.R.B. 146

98–51 Modified and superseded by Rev. Proc. 2000–31, 2000–31 I.R.B. 146

99–18 Modified by Rev. Proc. 2000–29, 2000–28 I.R.B. 113

99–34 Superseded by Rev. Proc. 2000–28, 2000–27 I.R.B. 60

Treasury Decisions:

8873 Corrected by Announcement 2000–74, 2000–35 I.R.B. 230

8883 Corrected by Announcement 2000–57, 2000–28 I.R.B. 115

8884 Corrected by Announcement 2000–73, 2000–35 I.R.B. 230

1 A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2000–1 through 2000–26 is in Internal Revenue Bulletin 2000–27, dated July 3, 2000.

September 25, 2000 iii 2000–39 I.R.B.

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