Part IV of Form 990–EZ, Short Form

Return of Organization Exempt From In- come Tax, and Part V of Form 990, Return of Organization Exempt From Income Tax, require reporting organizations to list the names and addresses for contact of officers, directors, trustees and key employees. Line 1 of Part VIII of Form 990–PF, Return of Private Foundation or Section 4947(a)(1) Nonexempt Charitable Trust Treated as a Private Foundation, requires foundations to list the same information for officers, directors, trustees, or foundation managers. Organizations are also required to report the title of each listed individual and the hours the individual spends per week performing the duties of the position.

The forms also require information on compensation packages for individuals listed as officers, directors, trustees or key employees/foundation managers. The forms ask for amounts paid to each individual as compensation, contributions made to employee benefit plans and other deferred compensation, and payments made to expense accounts and for other allowances.

Since 1999, the instructions to the forms have stated, “If you pay any other person, such as a management services company, for the services provided by any of your officers, directors, trustees, or key employees

[or foundation managers for private foundations], report the compensation and other items as if you had paid them directly.”

The Internal Revenue Service has received a number of comments on these instructions. These comments have either criticized the instructions or expressed concern that the Service might reduce their effectiveness.

Some comments have expressed concern that the reporting requirements are too burdensome on tax-exempt organizations, requiring the organization to obtain detailed information from third-party contractors to accurately complete the form.

Other comments expressed concern that the requirements invade the privacy of individuals who are not employees of the reporting organization. These comments concede, however, that the Service must protect against individuals who incorporate to avoid reporting.

Comments in support of the current reporting requirements expressed concern that allowing tax-exempt organizations to report only the gross amounts they pay for management would deprive the public sources of critical information about the reporting organization.

PUBLIC COMMENTS

This Announcement seeks further public comments on these instructions. Comments should address such issues as:

1. Whether contracting with third parties who provide the reporting organization with allocations for completing the form is consistent with current practices?

2. How can the instructions be revised to simplify reporting, yet protect against abuse by an individual officer, director, trustee, key employee, or private foundation manager who incorporates to avoid reporting? The period for comments will be 90 days from the date this Announcement is published in the Internal Revenue Bulletin.

Comments should be sent to the following address:

Internal Revenue Service 1111 Constitution Ave., N.W. Washington, DC 20224

Attn: David W. Jones, 1750 Penn. Ave., NW T:EO:RA, Room 3T3 Comments may also be sent electronically via the Internet to *TE/GE-EO-1@irs.gov.

REASONABLE CAUSE UNDER SECTION 6652

Until the Service notifies organizations otherwise, by an Announcement published in the Bulletin, organizations that pay other persons, such as management services companies, for the services of officers, directors, trustees, or key employees/foundation managers, will be deemed to have reasonable cause for purposes of the penalty under Section 6652(a)(1)(a)(ii) of the Internal Revenue Code for the failure to provide the information required by the relevant portions of Parts IV, V or VIII of the forms, if:

1. Where the form asks for the name of officers, directors, trustees, or key employees/foundation managers, the reporting organization enters the name of the person (e.g., management services company) that performs those services under contracts and services that it performs:
2. Where the form asks for the address of officers, directors, trustees or key employees/foundation managers, the reporting organization enters the address where the IRS can contact such person (management services company);
3. Where the form asks for compensation paid to officers, directors, trustees or key employees/foundation managers, the reporting organization enters the amount paid to the person (management services company) for the services listed in response to inquiry 1, above.

DRAFTING INFORMATION

The principal author of this announcement is David W. Jones of the Exempt Organizations Technical Division. For further information regarding this announcement contact David W. Jones at (202) 283-8907 (not a toll-free call).

2001–17 I.R.B. 1137 April 23, 2001

IRS, and invited large business taxpayers to participate. Notice 2000–12 requested interested taxpayers to submit applications for the PFA pilot program by March 15, 2000, through the on site LMSB team manager.

PFA Process

The PFA process was managed and conducted by LMSB Industry Directors and field staff, with support from the Office of Pre-Filing and Technical Guidance in LMSB Headquarters. LMSB team managers reviewed all applications and made their recommendations to their respective Industry Directors. The Office of Chief Counsel reviewed all applications to ensure the issues presented were appropriate for inclusion in the PFA pilot program.

The Industry Director with jurisdiction over the taxpayer made the final decision whether to accept a taxpayer’s request for participation in the PFA pilot program. The criteria for selecting a request included:

Announcement and Report Concerning Pre-Filing Agreements

Announcement 2001–38

Introduction

This Announcement is issued pursuant to the Conference Report to H.R. 4577 (Pub. L. 106–554), The Community Re- newal Tax Relief Act of 2000, which requires that the Secretary of the Treasury make publicly available an annual report relating to the Pre-Filing Agreement (“PFA”) program operations for the preceding calendar year. The Conference Report states that the report is to include: (1) the number of pre-filing agreements completed, (2) the number of applications received, (3) the number of applications withdrawn, (4) the types of issues which are resolved by completed agreements, (5) whether the program is being utilized by taxpayers who were previously subject to audit, (6) the average length of time required to complete an agreement, (7) the number, if any, and subject of technical advice and Chief Counsel advice memoranda issued to address issues arising in connection with any pre-filing agreement, (8) any model agreements, and (9) any other information the Secretary deems appropriate. The PFA pilot program was announced in Notice 2000–12, 2000–9 I.R.B. 727. This is the first report issued and sets forth information on the PFA pilot program, including information on (i) the applications received for the PFA pilot program, and (ii) the closing agreements entered into pursuant to the pilot program.

Background

The Large and Mid-Size Business Division (“LMSB”) within the Internal Revenue Service serves corporations and partnerships with assets greater than $5 million. In 2000, approximately 248,000 corporations and partnerships filed returns reporting assets in this range. The returns filed by these taxpayers present a wide variety of complex issues. Taxpayers served by LMSB paid more than $700 billion in taxes to the federal government during 2000. The largest of the taxpayers deal with the IRS on a continuous basis.

One of LMSB’s strategic initiatives is issue management. Through effective

issue management, LMSB seeks to reduce the time necessary to complete an examination, to conduct examinations on a more current basis, and to ensure consistency of issue resolution for all taxpayers. The Pre-Filing Agreement program was designed to support LMSB’s issue management strategy. LMSB believes the Pre-Filing Agreement program will reduce taxpayer burden and make more effective use of IRS resources by resolving or eliminating tax controversy earlier in the examination process.

Pre-Filing Agreement Program

The PFA program is designed to permit a taxpayer to resolve, before the filing of a return, the treatment of an issue that otherwise would likely be disputed in a postfiling examination. The PFA program is intended to reach agreement on factual issues and apply settled legal principles to those facts. Execution of a PFA that resolves issues prior to filing will permit taxpayers to avoid a portion of the costs, burdens and delays that are frequently incident to post-filing examination disputes between taxpayers and the IRS.

In calendar year 2000, a pilot program was implemented which resulted in the execution of seven PFAs. A PFA is a specific matter closing agreement under § 7121. These PFAs permanently and conclusively resolve the subject of the PFA for a taxable period. Based upon input from internal and external participants in the pilot program, the IRS has implemented the PFA program on a continuing and expanded basis. Rev. Proc. 2001–22, 2001–9 I.R.B. 745.

PFA Pilot Program (Notice 2000–12)

Notice 2000–12, 2000–9 I.R.B. 727, dated February 11, 2000, announced the PFA pilot program, which was administered by LMSB. The PFA pilot program was open to Coordinated Examination Program 1 (“CEP”) taxpayers that had a CEP examination team currently on site. The notice provided a description of a PFA, the procedures for requesting a PFA, and the procedures for LMSB to select taxpayers for the PFA pilot program. The IRS believed that this PFA pilot program offered significant benefits for taxpayers, as well as for the

1 This program has recently been renamed. Such cases are now classified as Coordinated Industry Cases.

a. The suitability of the issue presented

by the taxpayer; b. The direct or indirect impact of a

PFA upon other years, issues, taxpayers, or related cases; c. The selection of a cross–section of

issues and industries for the pilot program; and d. The probability of completing the

examination of the issue and entering into a PFA by the target date.

For the cases selected, a mandatory orientation session for the CEP examination team and the taxpayer was conducted. Subsequently, the taxpayer and CEP examination team held a joint planning meeting to seek agreement on a proposed timeframe, to identify and arrange for IRS access to relevant records and testimony, and to define the potential scope and nature of the PFA.

The CEP examination team conducted the factual and issue development consistent with IRS auditing standards. Based upon an examination of the issue, the Team Manager prepared a PFA recommendation for the Industry Director. The Industry Director’s decision to enter into a PFA was based on the Team Manager’s recommendation and discussions with the PFA Program Manager, Chief Counsel attorneys, and the taxpayer. Following Chief Counsel review to ensure that the proposed PFA conformed with guidance provided in Rev. Proc. 68–16, 1968–1

April 23, 2001 1138 2001–17 I.R.B.

C.B. 770 (regarding closing agreements), the Industry Director could execute a PFA if he or she determined that:

a. Entering into the PFA was consistent

with the goals of the PFA pilot program as stated in the Notice; b. The tax results in the PFA reflected

settled legal principles and correctly applied those principles (or positions authorized under Delegation Order Nos. 236 or 247) to facts found by the Examination Team; and c. There appeared to be an advantage in

having the issue(s) permanently and conclusively closed for the taxable

period covered by the PFA, or that the taxpayer showed good and sufficient reasons for desiring a closing agreement and that the United States would sustain no disadvantage through consummation of such an agreement (see section 301.7121–1(a) of the Regulations on Procedure and Administration).

Program Oversight

A designated PFA Program Manager and analyst assigned to the Office of PreFiling and Technical Guidance in LMSB Headquarters provided oversight for the

PFA pilot program. The PFA Program Manager provided assistance to taxpayers, Industry Directors and Team Managers throughout the process and personally conducted the orientation session at each taxpayer location.

Pre-Filing Agreement Pilot Program

Accomplishments

Applications Received

Nineteen applications were received for the PFA pilot program. Applications were received from each LMSB industry segment and involved a variety of issues.

mine whether the objective of the PFA pilot program could be achieved. Several reasons contributed to the taxpayer’s withdrawal, including the complexity of the issue, the time required to complete

Taxpayer Withdrawal (1)

One taxpayer, in accordance with the procedures set forth in Section 7 of Notice 2000–12, withdrew from the PFA pilot

program after its request had been accepted into the PFA pilot program. This withdrawal occurred after the Director, Field Operations, met with the taxpayer and the CEP examination team to deter

2001–17 I.R.B. 1139 April 23, 2001

the analysis and a misunderstanding by the taxpayer of the purpose of the PFA process.

PFAs In Process (4)

The taxpayers and the respective Industry Directors, in accordance with the provisions of Notice 2000–12 ², have agreed

to continue discussions relating to four PFA applications in an effort to reach agreement.

PFAs Executed (7)

Seven PFAs were completed in calendar year 2000.

Notice 2000–12, Section 1, Introduc- tion of Pilot Program states in part, “In

ordinated Examination Team on site.” Each of the taxpayers accepted into the PFA pilot program met this requirement.

The Office of Chief Counsel provided advice to the CEP examination teams and assisted in the drafting and review of the PFAs. No Technical Advice or Chief Counsel Advice Memoranda were issued for issues addressed in the PFA process.

Valuation of Assets (2)

One application concerned the valuation of a “covenant not to compete.” The other application concerned the valuation of patents contributed to a charity. Each of the taxpayers supported its proposed valuation with a study conducted by an independent appraiser. IRS Engineers and Valuation Specialists assisted the CEP examination team in the review of the issues. In the first application, the CEP examination team and the taxpayer agreed that, in a particular purchase transaction, no amount was allocable to a “covenant not to compete.” In the second application, the CEP examination team and the taxpayer reached a determination on the valuation of the patents based on market values.

Expense vs. Capitalization (1)

The taxpayer sought to determine the amount to be capitalized in a large repair expense account. The taxpayer proposed a statistical model for purposes of determining the amount subject to capitalization. An IRS Computer Audit Specialist assisted the CEP examination team in a review of the issue. The issue was resolved on the basis of a methodology that had been utilized in earlier examinations. The CEP examination team and the taxpayer agreed on the portion of the account that would be subject to capitalization.

Method of Accounting (2)

One application concerned whether a contract newly entered into by the tax

payer was required to be accounted for as a long-term contract under § 460. The issue was whether to account for the contract using an accrual method and not a long-term contract method. A technical advisor assisted the CEP examination team. The CEP examination team concluded that an accrual method of accounting was the appropriate method. A change in method of accounting pursuant to § 446 was not required because the change in treatment resulted from a change in the underlying facts.

The other application concerned the determination of the appropriate asset classes for depreciable property placed in service in prior years. The taxpayer proposed to change its method of accounting for certain depreciable property that the taxpayer believed had been misclassified. An IRS Engineer and a Computer Audit Specialist assisted the CEP examination team. The CEP examination team agreed with the taxpayer’s revised classifications and with the taxpayer’s proposal automatically to change its method of accounting for depreciation pursuant to Rev. Proc. 99–49, 1999–2 C.B. 725. The CEP examination team and the taxpayer reached an agreement as to the appropriate § 481 adjustment.

Stock Basis Computation (1)

This application concerned the tax basis of stock acquired in a transaction that qualified under § 368(a)(1)(B). An IRS Economist and a Computer Audit Specialist assisted the CEP examination

team. The CEP examination team agreed with the taxpayer’s computation of the amount of the stock basis under § 362(b).

Investigatory Costs (1)

This application concerned costs incurred to acquire a business. The taxpayer proposed that certain of the costs were investigatory in nature and therefore deductible under §162. Based on the principles contained in Rev. Rul. 99–23, 1999–1 C.B. 998, the CEP examination team and the taxpayer agreed as to which items were §162 costs and which were § 263 costs.

Closing Agreements

Seven PFAs were concluded as of December 31, 2000. A pro forma or model agreement does not exist for a PFA. A PFA represents a specific matter closing agreement under §7121. The closing agreements entered into under this pilot program were prepared with assistance from the Office of Chief Counsel and conform to the guidance provided in Rev. Proc. 68–16, supra .

Processing Statistics

The total average time to complete the seven PFAs executed in calendar 2000 was 166.1 days.

April 23, 2001 1140 2001–17 I.R.B.

Program Evaluation

The PFA Program Manager conducted process evaluations of all of the PFA pilot program cases based on feedback from LMSB employees and taxpayer participants. As a part of this program evaluation, participants were asked to provide an estimate of the direct examination time expended to complete the PFA and an estimate of the direct examination time it would have taken to resolve the issue in a post-filing context.

Phase I – Application Screening Process

Nineteen applications were received for the PFA pilot program. The initial phase was the screening process to determine if an application was appropriate for inclusion in the PFA pilot program. This screening process included obtaining comments from various LMSB functions and Chief Counsel, the review of these comments, and the decision making process on the acceptance/rejection of an application by the Industry Director. The

average time from the date an application was received by the IRS until the Industry Director rendered a decision to accept or reject an application was 37.2 days.

Phase II - PFA Evaluation Process

The second (and final) phase in the PFA pilot program process was the evaluation phase. This phase began when the Industry Director accepted an application into the PFA pilot program and ended when a PFA was executed.

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to final regulations.

SUMMARY: This document contains a correction to final regulations (T.D. 8912, 2001–5 I.R.B. 452) that were published in the Federal Register on Wednesday, December 20, 2000 (65 FR 79735) relating to the generation-skipping transfer (GST) tax imposed under chapter 13 of the Internal Revenue Code.

DATES: This correction is effective December 20, 2000.

FOR FURTHER INFORMATION CONTACT: James F. Hogan (202) 622-3090 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final regulations that are the subject of this correction are under section 2601 of the Internal Revenue Code.

Need for Correction

As published, the final regulations contain an error that may prove to be misleading and is in need of clarification.

Pre-Filing Agreement Pilot Program Summary

After evaluating the PFA pilot program and receiving input from internal and external participants, the IRS has concluded that the PFA program does further LMSB’s issue management strategy by assisting taxpayers to resolve issues in a cost efficient and cooperative environment. Accordingly, the IRS issued Rev. Proc. 2001–22, supra, dated February 26, 2001, which implemented the PFA program on a continuing and expanded basis.

The PFA program is now available to all LMSB taxpayers, including taxpayers that are not currently under examination. While the PFA program will continue to be limited to issues that involve settled legal principles, the list of recommended issues has been expanded, and will now include certain international issues. Generally, the operational procedures used during the PFA pilot program were adopted and enhanced in the current PFA program.

The principal author of this announcement is Robert Kastl, in the Office of LMSB Division Counsel. For further information regarding this announcement

contact Mr. Kastl at (202) 283-8620 (not a toll-free call).

New Publication 584–B, Business Casualty, Disaster, and Theft Loss Workbook

Announcement 2001–39

New Publication 584–B, Business Casu- alty, Disaster, and Theft Loss Workbook, is available from the Internal Revenue Service.

This publication is a workbook that is designed to help you figure your loss on business and income-producing property in the event of a disaster, casualty, or theft.

You can get a copy of this publication by calling 1-800-TAX-FORM (1-800-8293676). You can also write to the IRS Forms Distribution Center nearest you. Check your income tax package for the address. This publication is also available on the IRS Internet web site at www.irs.gov.

Generation-Skipping Transfer Issues; Correction

Announcement 2001–40

2001–17 I.R.B. 1141 April 23, 2001

Correction of Publication

Accordingly, the publication of the final regulations (T.D. 8912), that were the subject of FR Doc. 00–31757, is corrected as follows:

§26.2601–1 [Corrected]

On page 79740, column 2, §26.2601–1, paragraph (b)(4)(i)(E), Example 9., line 6, the language “is to pass to the A’s issue, per stirpes. Under” is corrected to read

“is to pass to A’s issue, per stirpes. Under”.

LaNita Van Dyke, Acting Chief, Regulations Unit,

Office of Special Counsel (Modernization and Strategic Planning).

(Filed by the Office of the Federal Register on February 21, 2001, 8:45 a.m., and published in the issue of the Federal Register for February 22, 2001, 66 F.R. 11108)

April 23, 2001 1142 2001–17 I.R.B.

Revenue rulings and revenue procedures (hereinafter referred to as “rulings”) that have an effect on previous rulings use the following defined terms to de- scribe 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### 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.

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.

2001–17 I.R.B. i April 23, 2001

Revenue Procedures—Continued: 2001–18, 2001–8 I.R.B. 708 2001–19, 2001–9 I.R.B. 732 2001–20, 2001–9 I.R.B. 738 2001–21, 2001–9 I.R.B. 742 2001–22, 2001–9 I.R.B. 745 2001–23, 2001–10 I.R.B. 784 2001–24, 2001–10 I.R.B. 788 2001–25, 2001–12 I.R.B. 913

Revenue Rulings: 2001–1, 2001–9 I.R.B. 726 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 2001–6, 2001–6 I.R.B. 491 2001–7, 2001–7 I.R.B. 541 2001–8, 2001–9 I.R.B. 726 2001–9, 2001–8 I.R.B. 652 2001–10, 2001–10 I.R.B. 755 2001–11, 2001–10 I.R.B. 780 2001–12, 2001–11 I.R.B. 811 2001–13, 2001–12 I.R.B. 898 2001–14, 2001–12 I.R.B. 898 2001–15, 2001–13 I.R.B. 922 2001–16, 2001–13 I.R.B. 936 2001–17, 2001–15 I.R.B. 1052

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 8914, 2001–8 I.R.B. 653 8915, 2001–4 I.R.B. 359 8916, 2001–4 I.R.B. 360 8917, 2001–7 I.R.B. 538 8918, 2001–4 I.R.B. 372 8919, 2001–6 I.R.B. 505 8920, 2001–8 I.R.B. 654 8921, 2001–7 I.R.B. 532 8922, 2001–6 I.R.B. 508 8923, 2001–6 I.R.B. 485 8924, 2001–6 I.R.B. 489 8925, 2001–6 I.R.B. 496 8926, 2001–6 I.R.B. 492 8927, 2001–11 I.R.B. 807 8928, 2001–8 I.R.B. 685 8929, 2001–10 I.R.B. 756 8930, 2001–5 I.R.B. 433 8931, 2001–7 I.R.B. 542 8932, 2001–11 I.R.B. 813 8933, 2001–11 I.R.B. 794 8934, 2001–12 I.R.B. 904 8935, 2001–8 I.R.B. 702 8937, 2001–11 I.R.B. 806 8938, 2001–13 I.R.B. 929 8939, 2001–12 I.R.B. 899 8940, 2001–15 I.R.B. 1016 8941, 2001–14 I.R.B. 977 8942, 2001–13 I.R.B. 929 8943, 2001–15 I.R.B. 1054 8944, 2001–16 I.R.B. 1067

Numerical Finding List ¹

Bulletins 2001–1 through 2001–16

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 2001–12, 2001–6 I.R.B. 526 2001–13, 2001–96 I.R.B. 752 2001–14, 2001–7 I.R.B. 648 2001–15, 2001–8 I.R.B. 715 2001–16, 2001–8 I.R.B. 715 2001–17, 2001–8 I.R.B. 716 2001–18, 2001–10 I.R.B. 791 2001–19, 2001–10 I.R.B. 791 2001–20, 2001–8 I.R.B. 716 2001–21, 2001–9 I.R.B. 752 2001–22, 2001–11 I.R.B. 895 2001–23, 2001–10 I.R.B. 791 2001–24, 2001–10 I.R.B. 793 2001–25, 2001–11 I.R.B. 895 2001–26, 2001–11 I.R.B. 896 2001–27, 2001–11 I.R.B. 897 2001–28, 2001–13 I.R.B. 975 2001–29, 2001–14 I.R.B. 1014 2001–30, 2001–15 I.R.B. 1065 2001–34, 2001–16 I.R.B. 1087 2001–35, 2001–16 I.R.B. 1087 2001–36, 2001–16 I.R.B. 1089 2001–37, 2001–16 I.R.B. 1090

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 2001–13, 2001–6 I.R.B. 514 2001–14, 2001–6 I.R.B. 516 2001–15, 2001–7 I.R.B. 589 2001–16, 2001–9 I.R.B. 730 2001–17, 2001–9 I.R.B. 730 2001–18, 2001–9 I.R.B. 731 2001–19, 2001–10 I.R.B. 784 2001–20, 2001–11 I.R.B. 818 2001–21, 2001–11 I.R.B. 818 2001–22, 2001–12 I.R.B. 911 2001–23, 2001–12 I.R.B. 911 2001–24, 2001–12 I.R.B. 912 2001–25, 2001–13 I.R.B. 941 2001–26, 2001–13 I.R.B. 942 2001–27, 2001–13 I.R.B. 942 2001–28, 2001–13 I.R.B. 944

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.

Notices:—Continued 2001–29, 2001–14 I.R.B. 989 2001–30, 2001–14 I.R.B. 989

Proposed Regulations: LR–230–76, 2001–13 I.R.B. 945 REG–209461–79, 2001–8 I.R.B. 712 REG–246256–96, 2001–8 I.R.B. 713 REG–251701–96, 2001–4 I.R.B. 396 REG–101520–97, 2001–15 I.R.B. 1057 REG–106030–98, 2001–11 I.R.B. 820 REG–106446–98, 2001–13 I.R.B. 945 REG–106542–98, 2001–5 I.R.B. 473 REG–121928–98, 2001–6 I.R.B. 520 REG–109481–99, 2001–13 I.R.B. 961 REG–111835–99, 2001–11 I.R.B. 834 REG–114998–99, 2001–14 I.R.B. 992 REG–115560–99, 2001–14 I.R.B. 993 REG–101739–00, 2001–14 I.R.B. 996 REG–103320–00, 2001–8 I.R.B. 714 REG–104683–00, 2001–4 I.R.B. 407 REG–104876–00, 2001–14 I.R.B. 998 REG–105801–00, 2001–13 I.R.B. 965 REG–105946–00, 2001–16 I.R.B. 1069 REG–106513–00, 2001–16 I.R.B. 1076 REG–106702–00, 2001–4 I.R.B. 424 REG–106791–00, 2001–6 I.R.B. 521 REG–106892–00, 2001–15 I.R.B. 1060 REG–107047–00, 2001–14 I.R.B. 1002 REG–107101–00, 2001–16 I.R.B. 1083 REG–107175–00, 2001–13 I.R.B. 971 REG–107176–00, 2001–4 I.R.B. 428 REG–107186–00, 2001–13 I.R.B. 973 REG–107566–00, 2001–3 I.R.B. 346 REG–110374–00, 2001–12 I.R.B. 915 REG–110659–00, 2001–12 I.R.B. 917 REG–114082–00, 2001–7 I.R.B. 629 REG–114083–00, 2001–7 I.R.B. 630 REG–114084–00, 2001–7 I.R.B. 633 REG–116468–00, 2001–6 I.R.B. 522 REG–119352–00, 2001–6 I.R.B. 525 REG–121109–00, 2001–15 I.R.B. 1064 REG–125237–00, 2001–12 I.R.B. 919 REG–126100–00, 2001–11 I.R.B. 862 REG–129608–00, 2001–14 I.R.B. 1011 REG–130477–00, 2001–11 I.R.B. 865 REG–130481–00, 2001–11 I.R.B. 865

Railroad Retirement Quarterly Rates: 2001–2, I.R.B. 258 2001–15, I.R.B. 1054

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 2001–17, 2001–7 I.R.B. 589

April 23, 2001 ii 2001–17 I.R.B.

Revenue Procedures—Continued:

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

2000–16 Modified and superseded by Rev. Proc. 2001–17, 2001–7 I.R.B. 589

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

2001–3 Corrected by Ann. 2001–25, 2001–11 I.R.B. 895

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

85–30 Clarified by Rev. Rul. 2001–8, 2001–9 I.R.B. 762

88–95 Clarified by Rev. Rul. 2001–8, 2001–9 I.R.B. 762

92–19 Supplemented in part by Rev. Rul. 2001–11, 2001–10 I.R.B. 780

2000–56 Corrected by Ann. 2001–19, 2001–10 I.R.B. 791

2001–4 Modified by Notice 2001–23, 2001–12 I.R.B. 911

Treasury Decisions:

7530 Removed by T.D. 8938, 2001–13 I.R.B. 929

8757 Revised by T.D. 8941, 2001–14 I.R.B. 977

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

8913 Corrected by Ann. 2001–26, 2001–11 I.R.B. 896

8931 Technically amended by Ann. 2001–37, 2001–16 I.R.B. 1090

Finding List of Current Actions on Previously Published Items ¹

Bulletins 2001–1 through 2001–16

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

2000–78 Obsoleted by T.D. 8933, 2001–11 I.R.B. 794

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:

94–3 Modified by T.D. 8933, 2001–11 I.R.B. 794

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

2000–26 Modified by Notice 2001–22, 2001–12 I.R.B. 911

2000–43 Extended by Notice 2001–13, 2001–6 I.R.B. 514

Proposed Regulations:

EE–130–86 Partially withdrawn by REG–209461–79, 2001–8 I.R.B. 712

REG–106030–98 Corrected by Ann. 2001–30, 2001–15 I.R.B. 1065

REG–106542–98 Corrected by Ann. 2001–24, 2001–13 I.R.B. 793

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.

Proposed Regulations—Continued:

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

REG–116048–99 Withdrawn by Ann. 2001–27, 2001–11 I.R.B. 897

REG–106702–00 Corrected by Ann. 2001–28, 2001–13 I.R.B. 975

Revenue Procedures:

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

90–18 Amplified and superseded by Rev. Proc. 2001–18, 2001–8 I.R.B. 708

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

96–15 Modified by Ann. 2001–22, 2001–11 I.R.B. 895

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

99–18 Modified and superseded by Rev. Proc. 2001–21, 2001–9 I.R.B. 742

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

99–49 Modified and amplified by Notice 2001–23, 2001–12 I.R.B. 911 Rev. Proc. 2001–10, 2001–2 I.R.B. 272 Rev. Proc. 2001–23, 2001–10 I.R.B. 784 Rev. Proc. 2001–24, 2001–10 I.R.B. 788 Rev. Proc. 2001–25, 2001–12 I.R.B. 913 Rev. Rul. 2001–8, 2001–9 I.R.B. 762

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

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

2001–17 I.R.B. iii April 23, 2001

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