Abbreviations

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

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

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

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

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

Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings).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

E.O. —Executive Order. ER —Employer. ERISA —Employee Retirement Income Security Act. EX —Executor. F —Fiduciary.

FC —Foreign Country. FICA —Federal Insurance 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.

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 For example, modified and superseded describes a situation where the substance of a previously published ruling is being changed in part and is continued without change in part and it is desired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.

P —Parent Corporation. 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.

February 5, 2001 i 2001–6 I.R.B.

Numerical Finding List ¹

Bulletins 2001–1 through 2001–5

Announcements: 2001–1, 2001–2 I.R.B. 277 2001–2, 2001–2 I.R.B. 277 2001–3, 2001–2 I.R.B. 278 2001–4, 2001–2 I.R.B. 286 2001–5, 2001–2 I.R.B. 286 2001–6, 2001–3 I.R.B. 357 2001–7, 2001–3 I.R.B. 357 2001–8, 2001–3 I.R.B. 357 2001–9, 2001–3 I.R.B. 357 2001–10, 2001–4 I.R.B. 431 2001–11, 2001–4 I.R.B. 432

Notices: 2001–1, 2001–2 I.R.B. 261 2001–2, 2001–2 I.R.B. 265 2001–3, 2001–2 I.R.B. 267 2001–4, 2001–2 I.R.B. 267 2001–5, 2001–3 I.R.B. 327 2001–6, 2001–3 I.R.B. 327 2001–7, 2001–4 I.R.B. 374 2001–8, 2001–4 I.R.B. 374 2001–9, 2001–4 I.R.B. 375 2001–10, 2001–5 I.R.B. 459 2001–11, 2001–5 I.R.B. 464 2001–12, 2001–3 I.R.B. 328

Proposed Regulations: REG–251701–96, 2001–4, I.R.B. 396 REG–106542–98, 2001–5, I.R.B. 473 REG–104683–00, 2001–4, I.R.B. 407 REG–106702–00, 2001–4, I.R.B. 424 REG–107176–00, 2001–4, I.R.B. 428 REG–107566–00, 2001–3, I.R.B. 346

Railroad Retirement Quarterly Rates: 2001–2, I.R.B. 258

Revenue Procedures: 2001–1, 2001–1 I.R.B. 1 2001–2, 2001–1 I.R.B. 79 2001–3, 2001–1 I.R.B. 111 2001–4, 2001–1 I.R.B. 121 2001–5, 2001–1 I.R.B. 164 2001–6, 2001–1 I.R.B. 194 2001–7, 2001–1 I.R.B. 236 2001–8, 2001–1 I.R.B. 239 2001–9, 2001–3 I.R.B. 328 2001–10, 2001–2 I.R.B. 272 2001–11, 2001–2 I.R.B. 275 2001–12, 2001–3 I.R.B. 335 2001–13, 2001–3 I.R.B. 337 2001–14, 2001–3 I.R.B. 343 2001–15, 2001–5 I.R.B. 465 2001–16, 2001–4 I.R.B. 376

1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2000–27 through 2000–52 is in Internal Revenue Bulletin 2001–1, dated January 2, 2001.

Revenue Rulings: 2001–2, 2001–2 I.R.B. 255 2001–3, 2001–3 I.R.B. 319 2001–4, 2001–3 I.R.B. 295 2001–5, 2001–5 I.R.B. 451

Treasury Decisions: 8910, 2001–2 I.R.B. 258 8911, 2001–3 I.R.B. 321 8912, 2001–5 I.R.B. 452 8913, 2001–3 I.R.B. 300 8915, 2001–4 I.R.B. 359 8916, 2001–4 I.R.B. 360 8918, 2001–4 I.R.B. 372 8930, 2001–5 I.R.B. 433

2001–6 I.R.B. ii February 5, 2001

Finding List of Current Actions on Previously Published Items ¹

Bulletins 2001–1 through 2001–5

Announcement:

98–99 Modified by Ann. 2001–9, 2001–3 I.R.B. 357

99–79 Superseded by Ann. 2001–3, 2001–2 I.R.B. 278

2000–97 Corrected by Ann. 2001–7, 2001–3 I.R.B. 357

Cumulative Bulletin:

1998–2 Corrected by Ann. 2001–5, 2001–2 I.R.B. 286

Notices:

98–39 Modified by Notice 2001–9, 2001–4 I.R.B. 375

98–40 Modified by Notice 2001–9, 2001–4 I.R.B. 375

99–53 Modified and superseded by Notice 2001–7, 2001–4 I.R.B. 374

2000–21 Superseded by Notice 2001–1, 2001–2 I.R.B. 261

2000–22 Modified and superseded by Notice 2001–8, 2001–4 I.R.B. 374

Proposed Regulations:

REG–116733–98 Withdrawn by Ann. 2001–11, 2001–4 I.R.B. 432

Revenue Procedures:

83–87 Superseded by Rev. Proc. 2001–15, 2001–5 I.R.B. 465

92–19 Superseded by Rev. Proc. 2001–15, 2001–5 I.R.B. 465

96–17 Modified by Rev. Proc. 2001–9, 2001–3 I.R.B. 328

99–47 Superseded by Rev. Proc. 2001–16, 2001–4 I.R.B. 376

99–49 Modified and amplified by Rev. Proc. 2001–10, 2001–2 I.R.B. 272

2000–1 Superseded by Rev. Proc. 2001–1, 2001–1 I.R.B. 1

1 A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2000–27 through 2000–52 is in Internal Revenue Bulletin 2001–1, dated January 2, 2001.

Revenue Procedures–continued:

2000–2 Superseded by Rev. Proc. 2001–2, 2001–1 I.R.B. 79

2000–3 Superseded by Rev. Proc. 2001–3, 2001–1 I.R.B. 111

2000–4 Superseded by Rev. Proc. 2001–4, 2001–1 I.R.B. 121

2000–5 Superseded by Rev. Proc. 2001–5, 2001–1 I.R.B. 164

2000–6 Superseded by Rev. Proc. 2001–6, 2001–1 I.R.B. 194

2000–7 Superseded by Rev. Proc. 2001–7, 2001–1 I.R.B. 236

2000–8 Superseded by Rev. Proc. 2001–8, 2001–1 I.R.B. 239

2000–22 Modified and superseded by Rev. Proc. 2001–10, 2001–2 I.R.B. 272

2001–13 Clarified by Notice 2001–12, 2001–3 I.R.B. 328

Revenue Rulings:

64–328 Modified by Notice 2001–10, 2001–5 I.R.B. 459

66–110 Modified by Notice 2001–10, 2001–5 I.R.B. 459

Treasury Decisions:

8889 Corrected by Ann. 2001–14, 2001–2 I.R.B. 286

February 5, 2001 iii 2001–6 I.R.B.