Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

Section 29.—Credit for Producing Fuel From a Nonconventional Source

Under what circumstances may a taxpayer obtain a private letter ruling under section 29(c)(1)(C) that a solid fuel produced from coal is a qualified fuel? See Rev. Proc. 2001–30, page 1163.

Section 38.—General Business Credit

What guidelines will be used, and what information and representations are required to be furnished by taxpayers, in connection with obtaining an advance ruling from the Service as to whether certain transactions purporting to be leases of property are, in fact, leases for federal income tax purposes. See Rev. Proc. 2001–28, page 1156, and Rev. Proc. 2001–29, page 1160.

Section 42.—Low-Income Housing Credit

The adjusted applicable federal short-term, midterm and long-term rates are set forth for the month of May 2001. See Rev. Rul. 2001–22, beginning on this page.

Section 61.—Gross Income Defined

26 CFR 1.61–1: Gross income.

What guidelines will be used, and what information and representations are required to be furnished by taxpayers, in connection with obtaining an advance ruling from the Service as to whether certain transactions purporting to be leases of property are, in fact, leases for federal income tax purposes. See Rev. Proc. 2001–28, page 1156, and Rev. Proc. 2001–29, page 1160.

Section 162.—Trade or Business Expenses

26 CFR 1.162–1: Business expenses.

What guidelines will be used, and what information and representations are required to be furnished by taxpayers, in connection with obtaining an advance ruling from the Service as to whether certain transactions purporting to be leases of property are, in fact, leases for federal income tax purposes. See Rev. Proc. 2001–28, page 1156, and Rev. Proc. 2001–29, page 1160.

Section 167.—Depreciation

26 CFR 1.167(a)–1: Depreciation in general.

What guidelines will be used, and what information and representations are required to be furnished by taxpayers, in connection with obtaining an advance ruling from the Service as to whether certain transactions purporting to be leases of property are, in fact, leases for federal income tax purposes. See Rev. Proc. 2001–28, page 1156, and Rev. Proc. 2001–29, page 1160.

Section 280G.—Golden Parachute Payments

Federal short-term, mid-term, and long-term rates are set forth for the month of May 2001. See Rev. Rul. 2001–22, beginning on this page.

Section 382.—Limitation on Net Operating Loss Carryforwards and Certain Built-In Losses Following Ownership Change

The adjusted applicable federal long-term rate is set forth for the month of May 2001. See Rev. Rul. 2001–22, beginning on this page.

Section 467.—Certain Payments for the Use of Property or Services

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of May 2001. See Rev. Rul. 2001–22, beginning on this page.

Section 467.—Certain Payments for the Use of Property or Services

26 CFR 1.467–3: Disqualified leasebacks and long- term agreements.

What guidelines will be used, and what information and representations are required to be furnished by taxpayers, in connection with obtaining an advance ruling from the Service as to whether certain transactions purporting to be leases of property are, in fact, leases for federal income tax purposes. See Rev. Proc. 2001–28, page 1156, and Rev. Proc. 2001–29, page 1160.

Section 468.—Special Rules for Mining and Solid Waste Reclamation and Closing Costs

The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of May 2001. See Rev. Rul. 2001–22, beginning on this page.

Section 482.—Allocation of Income and Deductions Among Taxpayers

Federal short-term, mid-term, and long-term rates are set forth for the month of May 2001. See Rev. Rul. 2001–22, beginning on this page.

Section 483.—Interest on Certain Deferred Payments

The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of May 2001. See Rev. Rul. 2001–22, beginning on this page.

Section 642.—Special Rules for Credits and Deductions

Federal short-term, mid-term, and long-term rates are set forth for the month of May 2001. See Rev. Rul. 2001–22, beginning on this page.

Section 807.—Rules for Certain Reserves

The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of May 2001. See Rev. Rul. 2001–22, beginning on this page.

Section 846.—Discounted Unpaid Losses Defined

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of May 2001. See Rev. Rul. 2001–22, beginning on this page.

Section 1274.—Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property

(Also sections 42, 280G, 382, 412, 467, 468, 482, 483, 642, 807, 846, 1288, 7520, 7872.)

May 7, 2001 1152 2001–19 I.R.B.

mining the present value of an annuity, an interest for life or for a term of years, or a remainder or a reversionary interest for purposes of section 7520.

Federal rates; adjusted federal rates; adjusted federal long-term rate, and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for May 2001.

Rev. Rul. 2001–22

This revenue ruling provides various prescribed rates for federal income tax purposes for May 2001 (the current month). Table 1 contains the short-term, mid-term, and long-term applicable federal rates (AFR) for the current month for

purposes of section 1274(d) of the Internal Revenue Code. Table 2 contains the short-term, mid-term, and long-term adjusted applicable federal rates (adjusted AFR) for the current month for purposes of section 1288(b). Table 3 sets forth the adjusted federal long-term rate and the long-term tax-exempt rate described in section 382(f). Table 4 contains the appropriate percentages for determining the low-income housing credit described in section 42(b)(2) for buildings placed in service during the current month. Finally, Table 5 contains the federal rate for deter

REV. RUL. 2001–22 TABLE 1

Applicable Federal Rates (AFR) for May 2001

Period for Compounding

Annual Semiannual Quarterly Monthly

Short-Term

AFR 4.25% 4.21% 4.19% 4.17% 110% AFR 4.68% 4.63% 4.60% 4.59% 120% AFR 5.11% 5.05% 5.02% 5.00% 130% AFR 5.54% 5.47% 5.43% 5.41%

Mid-Term

AFR 4.77% 4.71% 4.68% 4.66% 110% AFR 5.25% 5.18% 5.15% 5.12% 120% AFR 5.73% 5.65% 5.61% 5.58% 130% AFR 6.21% 6.12% 6.07% 6.04% 150% AFR 7.19% 7.07% 7.01% 6.97% 175% AFR 8.41% 8.24% 8.16% 8.10%

Long-Term

AFR 5.43% 5.36% 5.32% 5.30% 110% AFR 5.99% 5.90% 5.86% 5.83% 120% AFR 6.53% 6.43% 6.38% 6.35% 130% AFR 7.09% 6.97% 6.91% 6.87%

REV. RUL. 2001–22 TABLE 2

Adjusted AFR for May 2001

Period for Compounding

Annual Semiannual Quarterly Monthly

Short-term adjusted AFR 3.34% 3.31% 3.30% 3.29%

Mid-term adjusted AFR 3.89% 3.85% 3.83% 3.82%

Long-term adjusted AFR 4.89% 4.83% 4.80% 4.78%

2001–19 I.R.B. 1153 May 7, 2001

REV. RUL. 2001–22 TABLE 3

Rates Under Section 382 for May 2001

Adjusted federal long-term rate for the current month 4.89%

Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal long-term rates for the current month and the prior two months.) 4.89%

REV. RUL. 2001–22 TABLE 4

Appropriate Percentages Under Section 42(b)(2) for May 2001

Appropriate percentage for the 70% present value low-income housing credit 8.19%

Appropriate percentage for the 30% present value low-income housing credit 3.51%

REV. RUL. 2001–22 TABLE 5

Rate Under Section 7520 for May 2001

Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years, or a remainder or reversionary interest 5.8%

Section 1288.—Treatment of Original Issue Discounts on Tax- Exempt Obligations

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of May 2001. See Rev. Rul. 2001–22, page 1152.

Section 7520.—Valuation Tables

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of May 2001. See Rev. Rul. 2001–22, page 1152.

Section 7872.—Treatment of Loans with Below-Market Interest Rates

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of May 2001. See Rev. Rul. 2001–22, page 1152.

May 7, 2001 1154 2001–19 I.R.B.