Part IV. Items — Internal Revenue Bulletin 2002-8

Notice of Proposed Rulemaking

Definition of Agent for Certain Purposes

REG–120135–01

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking.

SUMMARY: This document contains proposed regulations relating to the definition of agent for certain purposes. The proposed regulations clarify that the term agent in certain provisions of section 6103 of the Internal Revenue Code includes contractors.

DATES: Written and electronic comments and requests for a public hearing must be received by May 1, 2002.

ADDRESSES: Send submissions to CC:ITA:RU (REG–120135–01), room 5226, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be delivered Monday through Friday between the hours of 8 a.m. and 5 p.m. to CC:ITA:RU (REG–120135–01), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue, NW, Washington, DC. Alternatively, taxpayers may submit comments electronically via the Internet by selecting the “Tax Regs” option on the IRS Home Page, or by submitting comments directly to the IRS Internet site: http:// www.irs.ustreas.gov/tax_regs/ regslist.html .

FOR FURTHER INFORMATION CONTACT: Helene R. Newsome, 202–622– 4580 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

Generally, returns and return information are confidential under section 6103 of the Internal Revenue Code (Code) unless a specific statutory exception applies. In cases of non-tax-related disclosures, returns and return information

generally may only be disclosed to officers and employees of federal, state, and local government agencies, and not to contractors or agents of such agencies. In certain limited circumstances, however, Congress has permitted disclosures to agents of these agencies. See sections 6103(l)(6)(B), 6103(l)(12), 6103(m)(2), 6103(m)(4), 6103(m)(5), and 6103(m)(7). This document contains proposed regulations that clarify that the term agent in sections 6103(l) and (m) includes contractors. Clarification that the term agent includes contractors is necessary for the purpose of bringing certain statutory grants of disclosure authority into alignment with the reality of many agencies’ operations. Agencies generally procure the services of third parties under public contracting laws, which do not necessarily correlate with common law concepts of agent. This clarification is also consistent with Congressional intent. For example, the Senate Finance Committee, in amending section 6103(m)(2), stated, “Agents are those who are engaged directly in performing or assisting in collection functions for the federal government, presumably, private collection agencies who have contracted with the government to collect claims...” S. Rep. No. 97–378, at 15 (1982).

This clarification does not provide any new disclosure authority, nor does it authorize the disclosure of return information to contractors that Congress has not previously specifically authorized in the Code. With regard to protection of taxpayer data, agents/contractors are subject to safeguard requirements, redisclosure prohibitions, and civil and criminal penalties for unauthorized disclosures. Accordingly, the proposed regulations do not have an impact on taxpayer privacy.

Special Analyses

It has been determined that this notice of proposed rulemaking is not a significant regulatory action as defined in Executive Order 12866. Therefore, a regulatory assessment is not required. It also has been determined that section 553(b) of the Administrative Procedure Act (5 U.S.C. chapter 5) and the Regulatory Flexibility Act (5 U.S.C. chapter 6) do not apply to these regulations, and, therefore, a Regulatory Flexibility Analy

sis is not required. Pursuant to section 7805(f), this notice of proposed rulemaking will be submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small businesses.

Comments and Request for a Public Hearing

Before these proposed regulations are adopted as final regulations, consideration will be given to any electronic and written comments (a signed original and eight (8) copies) that are submitted timely to the IRS. The IRS and Treasury Department request comments on the clarity of the proposed rule and how it may be made easier to understand. All comments will be available for public inspection and copying. A public hearing may be scheduled if requested in writing by a person that timely submits written comments. If a public hearing is scheduled, notice of the date, time, and place for the hearing will be published in the Federal Register .

Drafting Information

The principal author of these regulations is Helene R. Newsome, Office of the Associate Chief Counsel (Procedure & Administration), Disclosure & Privacy Law Division.

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Proposed Amendments to the Regulations

Accordingly, 26 CFR part 301 is proposed to be amended as follows:

PART 301—PROCEDURE AND ADMINISTRATION

Paragraph 1. The authority citation for part 301 is amended by adding an entry in numerical order to read as follows:

Authority: 26 U.S.C. 7805 ***

Section 301.6103(l)–1 also issued under 26 U.S.C. 6103(q);***

Section 301.6103(m)–1 also issued under 26 U.S.C. 6103(q);***

Par. 2. Section 301.6103(l)–1 is added to read as follows:

February 25, 2002 552 2002–8 I.R.B.

requirements of the regulations, or has administered a fiduciary account in a grossly negligent manner.

The written notice of approval to serve as a nonbank trustee or nonbank custodian is not an endorsement of any investment made with respect to any retirement plan or arrangement handled by the approved nonbank trustee or custodian. The Internal Revenue Service does not review or approve investments.

If the trustee or custodian of an account described above is not a bank or an approved nonbank trustee or nonbank custodian, the amounts held in such account (including earned interest) will be deemed distributed and includible in gross income in the year(s) the account’s trustee or custodian was not a bank or an approved nonbank trustee or nonbank custodian. Contributions made to such account are not deductible from gross income and will be disallowed if claimed on an income tax return.

This list of approved nonbank trustees and nonbank custodians includes their names, addresses, and the date each application was approved.

If an approved nonbank trustee or custodian believes that the information about it is incorrect, incomplete, or that it has been incorrectly omitted from this list, it may, on or before April 26, 2002, which is 60 days from the date of the publication of this list in the Internal Revenue Bulletin, notify the Service in writing of any changes it proposes to the list. This notification should include a copy of the approval letter.

The notification should be addressed to:

Internal Revenue Service T:EP:RA:T1 Announcement 2002–12 1111 Constitution Ave., NW Washington, DC 20224

Drafting Information

The principal author of this announcement is Calvin Thompson of the Employee Plans, Tax Exempt and Government Entities Division. Please contact Mr. Thompson at 1–202–283–9596 (not a toll-free number), if there are any questions regarding the publication of this list. Written inquiries concerning this announcement should be addressed to the Internal Revenue Service at the above address.

§ 301.6103(l)–1 Disclosure of returns and return information for purposes other than tax administration .

(a) Definition . For purposes of applying the provisions of section 6103(l) of the Internal Revenue Code, the term agent includes a contractor.

(b) Effective date . This section is applicable on or after the date of publication of the Treasury decision adopting these regulations as final regulations in the Federal Register .

Par. 3. Section 301.6103(m)–1 is added to read as follows:

§ 301.6103(m)–1 Disclosure of taxpayer identity information.

(a) Definition . For purposes of applying the provisions of section 6103(m) of the Internal Revenue Code, the term agent includes a contractor.

(b) Effective date . This section is applicable on or after the date of publication of the Treasury decision adopting these regulations as final regulations in the Federal Register .

Robert E. Wenzel, Deputy Commissioner of

Internal Revenue.

(Filed by the Office of the Federal Register on January 31, 2002, 8:45 a.m., and published in the issue of the Federal Register for February 1, 2002, 67 F.R. 4938)

List of Nonbank Trustees and Custodians

Announcement 2002–12

The following is a list of entities that have been approved by the Commissioner of the Internal Revenue Service, pursuant to § 1.408–2(e) of the Income Tax Regulations, to serve as a nonbank trustee or custodian.

Archer medical savings accounts (Archer MSAs) established under § 220 of the Internal Revenue Code, custodial accounts of a pension plan qualified under § 401, custodial accounts described in § 403(b)(7), trust or custodial accounts of individual retirement accounts (IRAs) established under §§ 408(a), 408A (Roth IRAs), or 530 (Coverdell Education Sav

ings Accounts), and custodial accounts of eligible deferred compensations plans described in § 457(b) will not be tax exempt if the trustee or custodian of such accounts is not a bank (as defined in § 408(n)) (and in the case of Archer MSAs a bank within the meaning of § 408(n) or an insurance company within the meaning of § 816) or an approved nonbank trustee or custodian.

An entity that is not a bank, as defined in § 408(n), must receive approval from the Service to serve as a nonbank trustee or nonbank custodian. A prospective nonbank trustee or custodian must file a written application with the Commissioner of Internal Revenue demonstrating that the requirements of § 1.408–2(e)(2) through § 1.408–2(e)(7) of the regulations will be met. If the application is approved, a written notice of approval will be issued to the applicant. The notice of approval will state the day on which it becomes effective, and (except as otherwise provided therein) will remain effective until revoked by the Service or withdrawn by the applicant. Entities that have received such approval from the Service may also sponsor certain retirement plans, custodial accounts under § 403(b)(7) of the Code and individual retirement arrangements established under § 408. (See Rev. Proc. 2000–20, 2000–6 I.R.B. 553, and Rev. Proc. 87–50, 1987–2 C.B. 647, as modified.)

A prospective nonbank trustee or custodian may not accept any fiduciary account before such notice of approval becomes effective. In addition, a nonbank trustee or custodian may not accept a fiduciary account until after the plan administrator or the person for whose benefit the account is to be established is furnished with a copy of the written notice of approval issued to the applicant.

The continued reliance on a notice of approval is dependent upon the continued satisfaction of the nonbank trustee requirements set forth in the regulations. The notice of approval issued to an applicant will be revoked if the Commissioner determines that the applicant is unwilling or unable to administer fiduciary accounts in a manner consistent with the requirements of the regulations. Generally, the notice will not be revoked unless the Commissioner determines that the applicant has knowingly, willfully, or repeatedly failed to administer fiduciary accounts in a manner consistent with the

2002–8 I.R.B. 553 February 25, 2002

APPROVED Nonbank Trustees/Custodians as of December 31, 2001

Name Address Approval Date

City Center One Bldg. Youngstown, OH 44501

Banc One Capital Corporation

P.O. Box 18277 90 North High Street Columbus, OH 43218

February 24, 1992

Butler Wick & Co., Inc.

October 8, 1992

February 25, 2002 554 2002–8 I.R.B.

Name Address Approval Date

400 Atrium Drive Somerset, NJ 08873

Deutsche Banc Alex. Brown, Inc.

1 South Street Baltimore, MD 21202

January 12, 2001

Financial Data Services, Inc.

November 14, 1990

2002–8 I.R.B. 555 February 25, 2002

Name Address Approval Date

H.G. Wellington & Co., Inc.

14 Wall Street New York, NY 10005

September 13, 1993

I.M. Simon & Co. 7730 Forsyth Blvd. Clayton, MO 63105

November 3, 1981

February 25, 2002 556 2002–8 I.R.B.

Name Address Approval Date

Two Broadway New York, NY 10004

November 15, 1977

Lehman Brothers, Inc. 200 Vesey Street New York, NY 10285

December 20, 2000

Moore & Schley, Cameron & Co.

2002–8 I.R.B. 557 February 25, 2002

Name Address Approval Date

Newhard, Cook & Co. 300 North Broadway St. Louis, MO 63102

June 4, 1985

R. Rowland & Co., Inc.

St. Louis, MO March 29, 1984

February 25, 2002 558 2002–8 I.R.B.

Name Address Approval Date

101 Prospect Street Bellingham, WA 98227-2838

Saturna Capital Corporation

March 28, 1991

Stephens, Inc. 111 Center Street Little Rock, AR 72201

December 4, 1987

2002–8 I.R.B. 559 February 25, 2002

Name Address Approval Date

United of Omaha Life Insurance

Mutual of Omaha Plaza Omaha, NE 68175

March 16, 1982

February 25, 2002 560 2002–8 I.R.B.

Extension of Time for Employers Required to Furnish Forms W–2 to Household Employees

Announcement 2002–19

This announcement provides for an extension of time for employers required to furnish Forms W-2 ( Wage and Tax Statement ) to household employees. Section 6051 of the Internal Revenue Code and section 31.6051–1(d)(1) of the Employment Tax Regulations require an employer to furnish employees a Form W-2 reflecting wages paid and employment taxes withheld by January 31 ^st of the year subsequent to the one in which the wages were paid. Package H ( Forms and Instructions for Household Employ- ers ), which is sent to employers of household employees, contains blank Forms W-2 and W-3 ( Transmittal of Wage and Tax Statements ). The Package H for the 2001 tax year was mailed late. Consequently, the last date for furnishing household employees their copies of Form W-2 is extended to February 15, 2002. The date for filing Forms W-2 and W-3 with the Social Security Administration remains February 28, 2002.

The principal author of this announcement is Joseph Dewald of the Office of Associate Chief Counsel, Procedure and Administration (Administrative Provisions and Judicial Practice Division). For further information regarding this announcement, you may call 202–622– 4910 (not a toll-free call).

New Markets Tax Credit; Correction

Announcement 2002–20

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Corrections to temporary regulations.

SUMMARY: This document contains corrections to temporary regulations (T.D. 8971, 2002–3 I.R.B. 308) that was published in the Federal Register on December 26, 2001 (66 FR 66307). This document contains temporary regulations that

Section 446 — Methods of Accounting

Announcement 2002–17

PURPOSE

This announcement reflects corrections to Rev. Proc. 2002–9 (2002–3 I.R.B. 327) (Jan. 22, 2002), which provides procedures under which taxpayers may obtain automatic consent of the Commissioner to change certain methods of accounting. Rev. Proc. 2002–9 was released by the Service on January 7, 2002, in advance of its publication in the Internal Revenue Bulletin. Except for items 2, 6, and 8 below, the corrections described in this announcement are already reflected in Rev. Proc. 2002–9 as published in the Internal Revenue Bulletin.

CORRECTIONS

In section 6.02(6)(b) the address to which copies of the application must be sent in the case of exempt organizations is changed to: “ . . . Commissioner, Tax Exempt and Government Entities, Attention: TEGE:EO, P.O. Box 27720, McPherson Station, Washington, D.C. 20038.”
Section 13.01 is changed to read as follows: “Except as provided in sections 13.02 and 13.03 of this revenue procedure, this revenue procedure is effective for taxable years ending on or after December 31, 2001. The Service will return any application that is filed on or after January 7, 2002, if the application is filed with the national office pursuant to the Code, regulations, or administrative guidance other than this revenue procedure and the change in method of accounting is within the scope of this revenue procedure.”
In section 13.02, first sentence, the date is changed from December 31, 2001, to January 7, 2002.
In the DRAFTING INFORMATION paragraph, item (7) is changed to read: “for changes in methods of accounting under section 4B of the APPENDIX of this revenue procedure, Norm Paul of the Office of the Division Counsel/ Associate Chief Counsel (Tax Exempt and Government Entities) at (202) 622– 6060.”
The caption for section 4.01 of the Appendix is changed to read: Certain uni- form capitalization (UNICAP) methods used by resellers and reseller-producers . A conforming change is made to the Table of Contents.
Section 4.01(1)(vi) of the Appendix is changed to read: “a reseller changing from a non-UNICAP method to a UNICAP method specifically described in the regulations (and making any attendant changes in the identification of costs subject to § 263A) in any taxable year, other than the first taxable year, that it does not qualify as a small reseller.”
Section 4.01(1)(c) of the Appendix is changed to read: “This change does not apply to a taxpayer making an historic absorption ratio election under §§ 1.263A–2(b)(4) or 1.263–3(d)(4), or to a taxpayer that wants to revoke an election to use the historic absorption ratio with the simplified resale method (see § 1.263A–3(d)(4)(iii)(B)).
Section 4.02(1) of the Appendix is changed to read: “ Applicability . This change applies to a producer of real or tangible personal property described in § 1.263A–2 that wants to change to a UNICAP method (or methods) specifically described in the regulations, and includes any changes in the identification of costs subject to section 263A made in connection therewith, but does not include a change for purposes of determining “section 471 costs” under the simplified production method.”
In section 5.01(1)(b)(iv)(D) of the Appendix, the first full sentence is changed to read: “ . . . the simplified production method without the historic absorption ratio election (§ 1.263A–2(b)) . . ..”
Section 10.01(1)(b)(i)(A) of the Appendix is changed to read: “ . . . then the taxpayer must use that same inventory method for all of its non-LIFO inventory, including the inventory that is the subject of this accounting method change.”

EFFECT ON OTHER DOCUMENTS

Rev. Proc. 2002–9 is modified and clarified.

2002–8 I.R.B. 561 February 25, 2002

provide guidance for taxpayers claiming the new market tax credit under section 45D.

DATES: This correction is effective December 26, 2002.

FOR FURTHER INFORMATION CONTACT: Paul A. Handleman (202) 622– 3040 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The temporary regulations that are the subject of this correction are under section 45D of Internal Revenue Code.

Need for Correction

As published, the temporary regulations (T.D. 8971) contains errors that may prove to be misleading and are in need of clarification.

Correction of Publication

Accordingly, the publication of the temporary regulations (T.D. 8971), which is the subject of FR. Doc. 01–31528, is corrected as follows:

On page 66310, column 1, under the paragraph heading “Part 1 — Income Taxes”, following paragraph 1, please insert the amendatory instruction “Par. 1a. The undesignated center heading immediately preceding § 1.30–1 is revised to read as follows: Credits Allowable Under Section 30 through 45D”.

LaNita Van Dyke, Acting Chief, Regulations Unit,

Associate Chief Counsel (Income Tax and Accounting).

(Filed by the Office of the Federal Register on February 1, 2002, 8:45 a.m., and published in the issue of the Federal Register for February 4, 2002, 67 F.R. 5061)

Certain Transfers of Property to Regulated Investment Companies [RICs] and Real Estate Investment Trusts

[REITs]; Correction

Announcement 2002–21

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to temporary regulations.

SUMMARY: This document contains corrections to temporary regulations (T.D. 8975, 2002–4 I.R.B. 379) that were published in the Federal Register on Wednesday, January 2, 2002 (67 FR 8) relating to certain transactions or events that result in a Regulated Investment Company [RIC] or a Real Estate Investment Trust [REIT] owning property that has a basis determined by reference to a C corporation’s basis in the property under sections 631 and 633.

DATES: This correction is effective January 2, 2002.

FOR FURTHER INFORMATION CONTACT: Lisa A. Fuller (202) 622–7750 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The temporary regulations that are the subject of these corrections is under sections 631 and 633 of the Internal Revenue Code.

Need for Correction

As published, the T.D. 8975 contain errors that may prove to be misleading and are in need of clarification.

Correction of Publication

Accordingly, the publication of T.D. 8975, that were the subject of FR Doc. 01–31969, is corrected as follows:

On page 10, column 1, in the preamble under the paragraph heading “Sec- tion 1374 Operational Rules”, first paragraph, line 8, the language “The comments pointed out certain” is corrected to read “The commentators pointed out certain”.

LaNita Van Dyke, Acting Chief, Regulations Unit,

Associate Chief Counsel (Income Tax and Accounting) .

(Filed by the Office of the Federal Register on January 28, 2002, 8:45 a.m., and published in the issue of the Federal Register for January 29, 2002, 67 F.R. 4177)

Dollar-Value LIFO Regulations; Inventory Price Index Computation Method; Correction

Announcement 2002–22

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Corrections to final regulations.

SUMMARY: This document contains corrections to final regulations (T.D. 8976, 2002–5 I.R.B. 421) that were published in the Federal Register on Wednesday, January 9, 2002 (67 FR 1075) providing guidance on methods of valuing dollar-value LIFO pools under section 472.

DATES: This correction is effective January 9, 2002.

FOR FURTHER INFORMATION CONTACT: Leo F. Nolan II (202) 622–4970 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final regulations that are the subject of these corrections are under section 472 of the Internal Revenue Code.

Need for Correction

As published, final regulations (T.D. 8976) contain errors which may prove to be misleading and are in need of clarification.

Correction of Publication

Accordingly, the publication of final regulations (T.D. 8976), which are the subject of FR Doc. 02–184, is corrected as follows:

February 25, 2002 562 2002–8 I.R.B.

On page 1075, columns 2 and 3, in the preamble under the paragraph heading “ Paperwork Reduction Act ”, the existing language is removed and the following language is added in its place.

The collections of information in this final rule have been reviewed and, pending receipt and evaluation of public comments, approved by the Office of Management and Budget (OMB) under 44 U.S.C. 3507 and assigned control number 1545–1767. The collections of information in this regulation are in § 1.472–8(e)(3)(iii)(B) ( 3 ) and (e)(3)(iv). To elect the IPIC method, a taxpayer must file Form 970, “ Application to Use LIFO Inventory Method. ” This information is required to inform the Commissioner regarding the taxpayer’s elections under the IPIC method. This information will be used to determine whether the taxpayer is properly accounting for its dollar-value pools under the IPIC method. The collections of information are required if the taxpayer wants to obtain the tax benefits of the LIFO method. The likely respondents are business or other for-profit institutions, and/or small businesses or organizations.

Comments on the collections of information should be sent to the Office of Management and Budget, Attn: Desk Officer for the Department of the Treasury, Office of Information and Regulatory Affairs, Washington, DC 20503, with copies to the Internal Revenue Service, Attn: IRS Reports Clearance Officer, W:CAR:MP:FP:S, Washington, DC 20224. Comments on the collections of information should be received by March 20, 2002. Comments are specifically requested concerning:

Whether the collections of information are necessary for the proper performance of the functions of the Internal Revenue Service, including whether the information will have practical utility;

The accuracy of the estimated burden associated with the collections of information (see below);

How the quality, utility, and clarity of the information to be collected may be enhanced;

How the burden of complying with the collections of information may be minimized, including through the application

of automated collection techniques or other forms of information technology; and,

Estimates of capital or start-up costs and costs of operation, maintenance, and purchase of service to provide information.

The reporting burden contained in § 1.472.–8(e)(3)(iii)(B)( 3 ) and (e)(3)(iv) is reflected in the burden of Form 970.

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid control number assigned by the Office of Management and Budget.

Books or records relating to a collection of information must be retained as long as their contents may become material in the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by 26 U.S.C. 6103.

§ 1.472–8 [Corrected]

On page 1088, column 3, § 1.472– 8(e)(3)(iii)(E)(i), Example 1., line 21, the language “items in R’s inventories fall within the 2-digit” is corrected to read “items in R’s inventory fall within the 2-digit.”
On page 1094, column 2, § 1.472– 8(e)(3)(v)(B), lines 23 and 24, the language “year as required by paragraph (e)(3)(iv)(B)(1) of this section. Because a” is corrected to read “year. See paragraph (e)(3)(iv)(B)(1) of this section for an example of this computation. Because a.”

LaNita VanDyke, Acting Chief, Regulations Unit,

Associate Chief Counsel (Income Tax and Accounting).

(Filed by the Office of the Federal Register on February 1, 2002, 8:45 a.m., and published in the issue of the Federal Register for February 4, 2002, 67 F.R. 5061)

Averaging of Farm Income; Correction

Announcement 2002–23

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to final regulations.

SUMMARY: This document contains a correction to final regulations (T.D. 8972, 2002–5 I.R.B. 443) that were published in the Federal Register on Tuesday, January 8, 2002 (67 FR 817), relating to the election to average farm income in computing tax liability.

DATES: This correction is effective January 8, 2002.

FOR FURTHER INFORMATION CONTACT: John M. Moran (202) 622–4940 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final regulations that are the subject of this correction are under section 1301 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.

Correction of Publication

Accordingly, the publication of the final regulations (T.D. 8972), that were the subject of FR Doc. 02–183, is corrected as follows:

§ 1–1301–1 [Corrected]

On page 821, column 1, § 1.1301–1, paragraph (d)(3)(ii), Example (ii), line 9, the language “years 1990, 2000, and 2001. T’s 2002 tax” is corrected to read “years 1999, 2000, and 2001. T’s 2002 tax”.

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 4, 2002, 8:45 a.m., and published in the issue of the Federal Register for February 5, 2002, 67 F.R. 5203)

2002–8 I.R.B. 563 February 25, 2002