Abbreviations

The following abbreviations in current use and formerly 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.

applies 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Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings).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. —Intemal 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 For example, modified and superseded describes a situation where the substance of a previously published ruling is being changed in part and is continued without change in part and it is desired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.

December 3, 2001 i 2001–49 I.R.B.

Numerical Finding List ¹

Bulletins 2001–27 through 2001–48

Announcements:

2001–69, 2001–27 I.R.B. 23 2001–70, 2001–27 I.R.B. 23 2001–71, 2001–27 I.R.B. 26 2001–72, 2001–28 I.R.B. 39 2001–73, 2001–28 I.R.B. 40 2001–74, 2001–28 I.R.B. 40 2001–75, 2001–28 I.R.B. 42 2001–76, 2001–29 I.R.B. 67 2001–77, 2001–30 I.R.B. 83 2001–78, 2001–30 I.R.B. 87 2001–79, 2001–31 I.R.B. 97 2001–80, 2001–31 I.R.B. 98 2001–81, 2001–33 I.R.B. 175 2001–82, 2001–32 I.R.B. 123 2001–83, 2001–35 I.R.B. 205 2001–84, 2001–35 I.R.B. 206 2001–85, 2001–36 I.R.B. 219 2001–86, 2001–35 I.R.B. 207 2001–87, 2001–35 I.R.B. 208 2001–88, 2001–36 I.R.B. 220 2001–89, 2001–38 I.R.B. 291 2001–90, 2001–35 I.R.B. 208 2001–91, 2001–36 I.R.B. 221 2001–92, 2001–39 I.R.B. 301 2001–93, 2001–44 I.R.B. 416 2001–94, 2001–39 I.R.B. 303 2001–95, 2001–39 I.R.B. 303 2001–96, 2001–41 I.R.B. 317 2001–97, 2001–40 I.R.B. 310 2001–98 2001–41 I.R.B. 317 2001–99 2001–42 I.R.B. 340 2001–100, 2001–41 I.R.B. 317 2001–101, 2001–43 I.R.B. 374 2001–102, 2001–42 I.R.B. 340 2001–103, 2001–43 I.R.B. 375 2001–104, 2001–43 I.R.B. 376 2001–105, 2001–43 I.R.B. 376 2001–106, 2001–44 I.R.B. 416 2001–107, 2001–44 I.R.B. 419 2001–108, 2001–44 I.R.B. 419 2001–109, 2001–45 I.R.B. 485 2001–110, 2001–45 I.R.B. 486 2001–111, 2001–45 I.R.B. 486 2001–112, 2001–46 I.R.B. 494 2001–113, 2001–46 I.R.B. 494 2001–114, 2001–47 I.R.B. 528 2001–115, 2001–48 I.R.B. 539 2001–116, 2001–48 I.R.B. 540 2001–118, 2001–48 I.R.B. 541

Court Decisions:

2070, 2001–31 I.R.B. 90 2071, 2001–44 I.R.B. 385 2072, 2001–44 I.R.B. 379

1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2001–1 through 2001–26 is in Internal Revenue Bulletin 2001–27, dated July 2, 2001.

Notices:

2001–39, 2001–27 I.R.B. 3 2001–41, 2001–27 I.R.B. 2 2001–42, 2001–30 I.R.B. 70 2001–43, 2001–30 I.R.B. 72 2001–44, 2001–30 I.R.B. 77 2001–45, 2001–33 I.R.B. 129 2001–46, 2001–32 I.R.B. 122 2001–47, 2001–36 I.R.B. 212 2001–48, 2001–33 I.R.B. 130 2001–49, 2001–34 I.R.B. 188 2001–50, 2001–34 I.R.B. 189 2001–51, 2001–34 I.R.B. 190 2001–52, 2001–35 I.R.B. 203 2001–53, 2001–37 I.R.B. 225 2001–54, 2001–37 I.R.B. 225 2001–55, 2001–39 I.R.B. 299 2001–56, 2001–38 I.R.B. 277 2001–57, 2001–38 I.R.B. 279 2001–58, 2001–39 I.R.B. 299 2001–59, 2001–41 I.R.B. 315 2001–60, 2001–40 I.R.B. 304 2001–61, 2001–40 I.R.B. 305 2001–62, 2001–40 I.R.B. 307 2001–63, 2001–40 I.R.B. 308 2001–64, 2001–41 I.R.B. 316 2001–65, 2001–43 I.R.B. 369 2001–66, 2001–44 I.R.B. 396 2001–68, 2001–47 I.R.B. 504 2001–69, 2001–46 I.R.B. 491 2001–70, 2001–45 I.R.B. 437 2001–71, 2001–48 I.R.B. 530

Proposed Regulations:

REG–110311–98, 2001–35 I.R.B. 204 REG–106917–99, 2001–27 I.R.B. 4 REG–103735–00, 2001–35 I.R.B. 204 REG–103736–00, 2001–35 I.R.B. 204 REG–107151–00, 2001–43 I.R.B. 370 REG–100548–01, 2001–29 I.R.B. 67 REG–106431–01, 2001–37 I.R.B. 272 REG–125161–01, 2001–48 I.R.B. 537 REG–142499–01, 2001–45 I.R.B. 476

Railroad Retirement Quarterly Rates:

2001–27, I.R.B. 1 2001–41, I.R.B. 314

Revenue Procedures:

2001–39, 2001–28 I.R.B. 38 2001–40, 2001–33 I.R.B. 130 2001–41, 2001–33 I.R.B. 173 2001–42, 2001–36 I.R.B. 212 2001–43, 2001–34 I.R.B. 191 2001–44, 2001–35 I.R.B. 203 2001–45, 2001–37 I.R.B. 227 2001–46, 2001–37 I.R.B. 263 2001–47, 2001–42 I.R.B. 332

Revenue Procedures—Continued

2001–48, 2001–40 I.R.B. 308 2001–49, 2001–39 I.R.B. 300 2001–50, 2001–43 I.R.B. 437 2001–51, 2001–43 I.R.B. 369 2001–52, 2001–46 I.R.B. 491 2001–53, 2001–47 I.R.B. 506 2001–54, 2001–48 I.R.B. 530

Revenue Rulings:

2001–30, 2001–29 I.R.B. 46 2001–33, 2001–32 I.R.B. 118 2001–34, 2001–28 I.R.B. 31 2001–35, 2001–29 I.R.B. 59 2001–36, 2001–32 I.R.B. 119 2001–37, 2001–32 I.R.B. 100 2001–38, 2001–33 I.R.B. 124 2001–39, 2001–33 I.R.B. 125 2001–40, 2001–38 I.R.B. 276 2001–41, 2001–35 I.R.B. 193 2001–42, 2001–37 I.R.B. 223 2001–43, 2001–36 I.R.B. 209 2001–44, 2001–37 I.R.B. 223 2001–45, 2001–42 I.R.B. 323 2001–46, 2001–42 I.R.B. 321 2001–47, 2001–39 I.R.B. 293 2001–48, 2001–42 I.R.B. 324 2001–49, 2001–41 I.R.B. 312 2001–50, 2001–43 I.R.B. 343 2001–51, 2001–45 I.R.B. 427 2001–52, 2001–45 I.R.B. 434 2001–53, 2001–46 I.R.B. 489 2001–54, 2001–46 I.R.B. 490 2001–55, 2001–47 I.R.B. 497 2001–56, 2001–47 I.R.B. 500 2001–57, 2001–46 I.R.B. 488

Treasury Decisions:

8947, 2001–28 I.R.B. 36 8948, 2001–28 I.R.B. 27 8949, 2001–28 I.R.B. 33 8950, 2001–28 I.R.B. 34 8951, 2001–29 I.R.B. 63 8952, 2001–29 I.R.B. 60 8953, 2001–29 I.R.B. 44 8954, 2001–29 I.R.B. 47 8955, 2001–32 I.R.B. 101 8956, 2001–32 I.R.B. 112 8957, 2001–33 I.R.B. 125 8958, 2001–34 I.R.B. 183 8959, 2001–34 I.R.B. 185 8960, 2001–34 I.R.B. 176 8961, 2001–35 I.R.B. 194 8962, 2001–35 I.R.B. 201 8963, 2001–35 I.R.B. 197 8964, 2001–42 I.R.B. 320 8965, 2001–43 I.R.B. 344 8966, 2001–45 I.R.B. 422

2001–49 I.R.B ii December 3, 2001

Finding List of Current Actions on Previously Published Items ¹

Bulletins 2001–27 through 2001–48

Announcements:

2000–48 Modified by Notice 2001–43, 2001–30 I.R.B. 72

Notices:

98–52 Modified by Notice 2001–56, 2001–38 I.R.B. 277

99–41 Modified and superseded by Notice 2001–62, 2001–38 I.R.B. 307

2001–4 Modified by Notice 2001–43, 2001–30 I.R.B. 72

2001–9 Modified by Notice 2001–46, 2001–32 I.R.B. 122

2001–15 Supplemented by Notice 2001–51, 2001–34 I.R.B. 190

2001–42 Modified by Notice 2001–57, 2001–38 I.R.B. 279

Proposed Regulations:

LR–97–79 Withdrawn by REG–100548–01, 2001–29 I.R.B. 67

LR–107–84 Withdrawn by REG–100548–01, 2001–29 I.R.B. 67

REG–110311–98 Supplemented by T.D. 8961, 2001–35 I.R.B. 194

REG–106917–99 Corrected by Ann. 2001–86, 2001–35 I.R.B. 207

REG–103735–00 Supplemented by T.D. 8961, 2001–35 I.R.B. 194

REG–103736–00 Supplemented by T.D. 8961, 2001–35 I.R.B. 194

Proposed Regulations—Continued

REG–107186–00 Corrected by Ann. 2001–71, 2001–27 I.R.B. 26

REG–130477–00 Supplemented by Ann. 2001–82, 2001–32 I.R.B. 123

REG–130481–00 Supplemented by Ann. 2001–82, 2001–32 I.R.B. 123

Revenue Procedures:

83–74 Revoked by Rev. Proc. 2001–49, 2001–39 I.R.B. 300

84–84 Revoked by Rev. Proc. 2001–49, 2001–39 I.R.B. 300

93–27 Clarified by Rev. Proc. 2001–43, 2001–34 I.R.B. 191

97–13 Modified by Rev. Proc. 2001–39, 2001–28 I.R.B. 38

97–19 Modified by Notice 2001–62, 2001–40 I.R.B. 307

98–44 Superseded by Rev. Proc. 2001–40, 2001–33 I.R.B. 130

99–27 Superseded by Rev. Proc. 2001–42, 2001–36 I.R.B. 212

99–49 Modified and amplified by Rev. Proc. 2001–46, 2001–37 I.R.B. 263

2000–20 Modified by Notice 2001–42, 2001–30 I.R.B. 70

2000–28 Superseded by Rev. Proc. 2001–50, 2001–45 I.R.B. 437

2000–39 Corrected by Ann. 2001–73, 2001–28 I.R.B. 40 Superseded by Rev. Proc. 2001–47, 2001–42 I.R.B. 332

2000–48 Superseded by Rev. Proc. 2001–54, 2001-48 I.R.B. 530

2001–2 Modified by Rev. Proc. 2001–41, 2001–33 I.R.B. 173

Revenue Procedures–Continued

2001–3 Modified by Rev. Proc. 2001–51, 2001–43 I.R.B. 369

2001–6 Modified by Notice 2001–42, 2001–30 I.R.B. 70

Revenue Rulings:

57–589 Obsoleted by REG–106917–99, 2001–27 I.R.B. 4

65–316 Obsoleted by REG–106917–99, 2001–27 I.R.B. 4

67–274 Amplified by Rev. Rul. 2001–46, 2001–42 I.R.B. 321

68–125 Obsoleted by REG–106917–99, 2001–27 I.R.B. 4

69–563 Obsoleted by REG–106917–99, 2001–27 I.R.B. 4

70–379 Obsoleted by Rev. Rul. 2001–39, 2001–33 I.R.B. 125

74–326 Obsoleted by REG–106917–99, 2001–27 I.R.B. 4

78–127 Modified by Rev. Rul. 2001–40, 2001–38 I.R.B. 276

78–179 Obsoleted by REG–106917–99, 2001–27 I.R.B. 4

89–42 Modified and superseded by Rev. Rul. 2001–48, 2001–42 I.R.B. 324

90–95 Distinguished by Rev. Rul. 2001–42, 2001–42 I.R.B. 321

92–19 Supplemented by Rev. Rul. 2001–38, 2001–33 I.R.B. 124

97–31 Modified and superseded by Rev. Rul. 2001–48, 2001–42 I.R.B. 324

Treasury Decisions:

8948 Corrected by Ann. 2001–90, 2001–35 I.R.B. 208

1 A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2001–1 through 2001–26 is in Internal Revenue Bulletin 2001–27, dated July 2, 2001.

December 3, 2001 iii 2001–49 I.R.B.