Part IV. Items — Internal Revenue Bulletin 2002-32

a transfer under section 2519 from the donee spouse to the person receiving the transferred property. The payment of gift tax by the person receiving the property benefits the donee spouse because the donee spouse is liable for the payment of this tax and, absent the right of recovery, would be required to pay the tax from the donee spouse’s own assets.

The proposed regulations will amend the regulations under section 2519 to provide that the amount of the transfer under section 2519 is reduced by the amount of the gift tax that the donee spouse is entitled to recover under section 2207A(b). The amount of gift tax recoverable and the amount of the remainder interest treated as transferred under section 2519 are determined by using the interrelated computation applicable to other transfers in which the transferee agrees to pay the gift tax. See Rev. Rul. 81–223, 1981–2 C.B. 189. In addition, the proposed regulations will amend the regulations under section 2207A(b) to provide that if the donee spouse fails to exercise the right to recover the gift tax, the donee spouse makes a gift in the amount of the unrecovered gift tax to the person from whom the recovery of gift tax could have been obtained.

Proposed Effective Date

The regulations will apply to any transfer under section 2519 where there is a right to recover gift tax under section 2207A(b) that occurs on or after the date final regulations are published in the Fed- eral Register .

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) does not apply to these regulations, and because these regulations do not impose a collection of information on small entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not apply. Therefore, a Regulatory

Notice of Proposed Rulemaking and Notice of Public Hearing

Net Gift Treatment Under Section 2519

REG–123345–01

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking and notice of public hearing.

SUMMARY: This document contains proposed amendments to the regulations relating to the amount treated as a transfer under section 2519 of the Internal Revenue Code when there is a right to recover gift tax under section 2207A(b) and the related gift tax consequences if the right to recover the gift tax is not exercised. The proposed regulations will affect donee spouses who make lifetime dispositions of all or part of a qualifying income interest in qualified terminable interest property. This document also provides notice of a public hearing on these proposed regulations.

DATES: Written comments and outlines of topics to be discussed at the public hearing scheduled for Tuesday, October 15, 2002, at 10 a.m., must be received by Tuesday, September 24, 2002.

ADDRESSES: Send submissions to: CC:ITA:RU (REG–123345–01), room 5226, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044. Submissions may also be hand delivered Monday through Friday between the hours of 8 a.m. and 5 p.m. to: CC:ITA:RU (REG–123345–01), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue NW, Washington, DC. Alternatively, taxpayers may submit comments electronically directly to the IRS internet site at www.irs.gov/ regs . The public hearing will be held in room 4718, Internal Revenue Building, 1111 Constitution Avenue NW, Washington, DC.

FOR FURTHER INFORMATION CONTACT: Concerning the regulations,

DeAnn K. Malone, (202) 622–7830; concerning submissions of comments, the hearing, and/or to be placed on the building access list to attend the hearing, Guy Traynor, (202) 622–7180 (not toll-free numbers).

SUPPLEMENTARY INFORMATION:

Background

A marital deduction for qualified terminable interest property is allowed for estate tax purposes under section 2056(b)(7) and for gift tax purposes under section 2523(f). Qualified terminable interest property is property transferred by the decedent or donor spouse, in which the donee spouse has a qualifying income interest for life, and for which an election has been made. If the donee spouse makes a lifetime disposition of all or a portion of the qualifying income interest, section 2519 provides that the donee spouse is treated for estate and gift tax purposes as transferring all interests in the property other than the qualifying income interest. Under section 2207A(b), the donee spouse is entitled to recover any gift tax paid with respect to a transfer under section 2519 from the person receiving the transferred property.

Proposed regulations under several sections including sections 2519 and 2207A(b) were issued on May 21, 1984 (LR–211–76, 1984–1 C.B. 598 [49 FR 21350]). The proposed regulations provided that the amount of the gift under section 2519 is reduced by the amount of the gift tax that the donee spouse is entitled to recover under section 2207A(b) and that the donee spouse makes an additional gift if the donee spouse fails to exercise the right to recover the gift tax. These two provisions were not included in the regulations when they were finalized (T.D. 8522, 1994–1 C.B. 236). The preamble to the final regulations stated that these issues would be the subject of future proposed regulations. Sections 25.2519–1(c)(4) and 25.2207A– 1(b) were reserved for those provisions.

Explanation of Provisions

Section 2207A(b) statutorily shifts the burden for paying the gift tax imposed on

August 12, 2002 321 2002–32 I.R.B.

Flexibility Analysis is not required. Pursuant to section 7805(f) of the Internal Revenue Code, the regulations will be submitted to the Small Business Administration for comment on their impact on small business.

Comments and Public Hearing

Before these proposed regulations are adopted as final regulations, consideration will be given to any 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 has been scheduled for Tuesday, October 15, 2002, at 10 a.m., in room 4718, Internal Revenue Building, 1111 Constitution Avenue NW, Washington, DC. Due to building security procedures, visitors must use the main building entrance on Constitution Avenue, NW. In addition, all visitors must present photo identification to enter the building. Because of access restrictions, visitors will not be admitted beyond the immediate entrance area more than 30 minutes before the hearing starts. For information about having your name placed on the building access list to attend the hearing, see the “FOR FURTHER INFORMATION CONTACT” section of this preamble.

The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who wish to present oral comments at the hearing must submit comments and an outline of the topics to be discussed and the time to be devoted to each topic (signed original and eight (8) copies) by Tuesday, September 24, 2002. A period of 10 minutes will be allotted to each person for making comments. An agenda showing the scheduling of the speakers will be prepared after the deadline for receiving outlines has passed. Copies of the agenda will be available free of charge at the hearing.

Drafting Information

The principal author of these proposed regulations is DeAnn K. Malone, Office of the Chief Counsel, IRS. Other person

nel from the IRS and Treasury Department participated in their development.

- - - -

Proposed Amendments to the Regulations

Accordingly, 26 CFR part 25 is proposed to be amended as follows:

PART 25—GIFT TAX; GIFTS MADE AFTER DECEMBER 31, 1954

Par. 1. The authority citation for part 25 continues to read in part as follows: Authority: 26 U.S.C. 7805. - - Par. 2. Section 25.2207A–1 is amended by adding the text of paragraph (b) to read as follows:

§ 25.2207A–1 Right of recovery of gift taxes in the case of certain marital deduction property .

- - - (b) Failure of a person to exercise the right of recovery . The failure of a person to exercise a right of recovery provided by section 2207A(b) upon a lifetime transfer subject to section 2519 is treated as a transfer for Federal gift tax purposes of the unrecovered amounts to the person(s) from whom the recovery could have been obtained. See § 25.2511–1. The transfer is considered to be made when the right to recovery is no longer enforceable and is treated as a gift even if recovery is impossible. Any delay in the exercise of the right of recovery shall be treated as an interest-free loan with the appropriate gift tax consequences.
- - - Par. 3. Section 25.2519–1 is amended as follows:

Paragraph (c)(1) is amended by adding a sentence to the end of the paragraph.
The paragraph heading for paragraph (c)(4) is revised and the text of paragraph (c)(4) is added.
Paragraph (g) introductory text is revised.

The additions and revisions read as follows:

§ 25.2519–1 Disposition of certain life estates .

- - - (c) - - *(1) - - - See paragraph (c)(4) of this section for the effect of gift tax that the donee spouse is entitled to recover under section 2207A.
- - - (4) Effect of gift tax entitled to be recovered under section 2207A on the amount of the transfer . The amount treated as a transfer under paragraph (c)(1) of this section is further reduced by the amount the donee spouse is entitled to recover under section 2207A(b) (relating to the right to recover gift tax attributable to the remainder interest). If the spouse is entitled to recover gift tax under section 2207A(b), the amount of gift tax recoverable and the value of the remainder interest treated as transferred under section 2519 are determined by using the same interrelated computation applicable for other transfers in which the transferee assumes the gift tax liability. The gift tax consequences of failing to exercise the right of recovery are determined separately under § 25.2207A–1(b).
- - - (g) Examples . The following examples illustrate the application of paragraphs (a) through (f) of this section. Except as provided otherwise in the examples, assume that the decedent, D, was survived by spouse, S, that in each example the section 2503(b) exclusion has already been fully utilized for each year with respect to the donee in question, that section 2503(e) is not applicable to the amount deemed transferred, and that the gift taxes on the amount treated as transferred under paragraph (c) are offset by S’s unified credit. The examples are as follows:
- - - Robert E. Wenzel, Deputy Commissioner

of Internal Revenue .

(Filed by the Office of the Federal Register on July 19, 2002, 8:45 a.m., and published in the issue of the Federal Register for July 22, 2002, 67 F.R. 47755)

2002–32 I.R.B. 322 August 12, 2002

vate foundations described in section 509(a) of the Code) are now classified as private foundations:

Brooklyn, NY

Treaty Guidance Regarding Payments With Respect to Domestic Reverse Hybrid Entities; Correction

Announcement 2002–71

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to final regulations.

SUMMARY: This document contains corrections to final regulations (T.D. 8999, 2002–28 I.R.B. 78) that were published in the Federal Register on Wednesday, June 12, 2002 (67 FR 40157) relating to the eligibility for treaty benefits of items of income paid by domestic entities.

DATES: This correction is effective June 12, 2002.

FOR FURTHER INFORMATION CONTACT: Elizabeth U. Karzon (202) 622– 3880 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final regulations that are the subject of these corrections is under section 894 of the Internal Revenue Code.

Need for Correction

As published, the final regulations contain errors that may prove to be misleading and are in need of clarification.

Correction of Publication

Accordingly, the publication of final regulations (T.D. 8999), that were the subject of FR Doc. 02–14506, is corrected as follows:

On page 40159, column 1, in the preamble under the paragraph heading “III. Comments and Changes to § 1.894– 1(d)(2)(ii)(B)( 3 ): Definition of Related”, first paragraph, line 1, the language “constructive ownership rules of sections” is corrected to read “constructive ownership rules of section”.
On page 40159, column 1, in the preamble under the paragraph heading “III. Comments and Changes to § 1.894–

1(d)(2)(ii)(B)( 3 ): Definition of Related”, third paragraph, line 3, the language “(d)(2)(ii)(B)( ii ) of the final regulations” is corrected to read “(d)(2)(ii)(B)( 1 )( ii ) of the final regulations”.

On page 40159, column 2, in the preamble the paragraph heading “IV. Comments and Changes to § 1.894– 1(d)(2)(ii)(C): Commissioner’s discretion.” is corrected to read “IV. Comments and Changes to § 1.894–1(d)(2)(ii)(C): Commissioner’s discretion”.
On page 40159, column 2, in the preamble under the paragraph heading “IV. Comments and Changes to § 1.894– 1(d)(2)(ii)(C): Commissioner’s discretion, second paragraph, line 14, the language “following conditions are met: (1) A” is corrected to read “following conditions are met: (1) a”.
On page 40162, column 2, second signature block, the language “Assistant Secretary of the Treasury (Tax Policy).” is corrected to read “Acting Assistant Secretary of the Treasury (Tax Policy).”

Cynthia E. Grigsby, Chief, Regulations Unit, Associate Chief Counsel (Income Tax and Accounting) .

(Filed by the Office of the Federal Register on July 16, 2002, 8:45 a.m., and published in the issue of the Federal Register for July 17, 2002, 67 F.R. 46855)

Foundations Status of Certain Organizations

Announcement 2002–72

The following organizations have failed to establish or have been unable to maintain their status as public charities or as operating foundations. Accordingly, grantors and contributors may not, after this date, rely on previous rulings or designations in the Cumulative List of Organizations (Publication 78), or on the presumption arising from the filing of notices under section 508(b) of the Code. This listing does not indicate that the organizations have lost their status as organizations described in section 501(c)(3), eligible to receive deductible contributions.

Former Public Charities . The following organizations (which have been treated as organizations that are not pri

14 Karat Steppers, Philadelphia, PA Absalom Jones Foundation,

Philadelphia, PA African American Students in Africa,

Los Angeles, CA Ahavah Respite Services, Inc.,

Lake Worth, FL Amarillo Wildlife Refuge, Inc.,

Amarillo, TX American Council for Greater

Understanding, San Francisco, CA American Flyers Volleyball Club,

Long Beach, CA American Folk Art Foundation,

Salt Lake City, UT American Veterans Housing &

Rehabilitation Project, Redwood City, CA Arizona Gymnastics Boosters, Inc.,

Scottsdale, AZ Art Museum of Southeast Texas Fund

Raising Foundation, Inc., Beaumont, TX Art of Dove Healing Through Art &

Sailing, Inc., Volcano, HI Art Resources Trust Fund,

Washington, DC Artskate, Houston, TX Ashe Village, Akron, OH Ask the Angels Foundation, Carmel, CA Assist Foundation, Inc., Atlanta, GA Association of the Variety Clubs of the

United States, Los Angeles, CA Atlantis Healing Center, Inc.,

Jacksonville, FL Autaugaville Volunteer Fire Department,

Inc., Autaugaville, AL Bartlett Youth League, Bartlett, TX Basic Skills Foundation, Chicago, IL Basketball Tournament Escrow Fund,

Sharon, MA Bayview Hunters Point Contractors

Association, San Francisco, CA Benton Conservation District,

Prosser, WA Black Attorney General Employees of

Texas, Inc., Buda, TX Blaze Junior Volleyball Club, Inc.,

Middleburg, FL Blessed Children, Chicago, IL Blocked Flock Repertory Company, Inc.,

Long Island City, NY Bnei Reuven Organization, Inc.,

August 12, 2002 323 2002–32 I.R.B.

Brown County Fair Building

Heart of the City Neighborhood

Association, Brownwood, TX California Indian Museum & Cultural

Desert Institute of the Environment,

Skull Valley, AZ Digs for Dogs, Bethesda, MD Dolphin Aquatics Team, Inc.,

Center, Petaluma, CA Capital Slavik Center,

Citrus Heights, CA Caring Consumer Connection,

Farmington, MN Dress for Success Los Angeles,

Association Beaumont Texas, Beaumont, TX Heartland Ministries, Inc., Loomis, CA Heartright Foundation, Inc.,

Norman, OK Heath Youth Athletic Association, Inc.,

W. Paducah, KY Help for Haiti Mission, Cleveland, OH Help One Help All Missionary Help

Center, Detroit, MI Helping Unite Mothers and Children,

Detroit, MI Hempstead Kiwanis Foundation, Inc.,

Greensboro, NC Caring Place, Broadview, IL Carteret Sports Leadership, Inc.,

Morehead City, NC Center for American Indian Research

Los Angeles, CA Eagle Foundation, Inc., Ashland, MO Eagle Spirit Academy Parent

Organization, Cody, WY Eagles Mickey Mantle Baseball Team,

and Education, Inc., Carson City, NV Century Corner Committee, Pittsfield, IL Changes Behavioral Services,

Oak Park, IL Charitable Merchants, Inc., Sarasota, FL Cheer Foundation, Georgetown, DE Chester Blazers Track and Field Team,

Brookhaven, PA Chester Swarthmore College Community

Brier, WA East Valley Softball League,

Concord, NH Everyone Deserves Enough, Inc.,

San Jose, CA Elmhurst Youth Tennis Center,

Oakland, CA Enable Scholarship Project, Chicago, IL Environmental Center of Dallas, Inc.,

Hempstead, NY Highlands Iron Conservancy, Inc.,

Rockaway, NJ Hillside Education Association

Dallas, TX Epsom Elderly Housing, Inc.,

Philanthropic Fund, Inc., Hillside, NJ Holystar Music Foundation, Inc.,

Coalition, Swarthmore, PA Children of the Earth, Inc.,

Monterey, CA In-Choir-er, Inc., Braintree, MA Infinite Spirit Museum, Inc.,

Marietta, GA Inner-City Childrens Foundation, Inc.,

Coral Gables, FL Christian Community Center of Calumet

Dorchester, MA Executive Nutritional Management, Inc.,

Baton Rouge, LA Fabra Elementary School PTO,

Region, Inc., Hammond, IN Christians Involved With Todays Youth,

Inc., Marrero, LA Circle of the People, Inc., Chandler, IN Civil Defense Corps, Inc., Gilford, NH Clay Connection, Merrifield, VA Communities in Schools of New

Mexico, La Cruces, NM Communities in Schools of Texas, Inc.,

Cleveland, OH Irvington International Parents

Boerne, TX Fayetteville Vocational Center, Inc.,

Miami, FL Institute for the Study of Families in

Fayetteville, NC Florida Main Street Association, Inc.,

Transition, Houston, TX Interfaith Initiative With Persons With

Disabilities, Inc., Boston, MA Inter-National Foundation for the Living

Quincy, FL Folks, Pomona, CA Food for Life-Colorado, Inc.,

Arts, Inc., Miami, FL International Heart to Heart Foundation,

Austin, TX Community Alliance for Responsible

Museum Development, Inc., New York, NY Community Outreach for the Homeless,

Denver, CO Forest & Agricultural Reserve

Management, Waterford, VA Fort Wayne Music Fest, Inc.,

Literacy, Inc., Northfield, VT Fund for Millenium House, Inc.,

Fort Wayne, IN Foundation for Enhancing Education and

Association, Irvington, NJ It’s Time, Inc., Springfield, IL Jamaica Plain Symphony Orchestra, Inc.,

Jamaica Plain, MA James R. Coulter Memorial Educational

Birmingham, AL Concho Valley Disabled Sports

Assistance Fund, Inc., Collingswood, NJ Jessamine County Youth Softball

Kalamazoo, MI Keith Alan Copeland Memorial

Association, Inc., San Angelo, TX Congregation Eizer L’Nitzrochim, Inc.,

Association, Inc., Nicholsville, KY Jewish Community Foundation of the

Spring Valley, NY Consortium on Substance Abuse Free

Environment, El Paso, TX Consumer Coalition of New Mexico,

North Shore, Inc., Marblehead, MA Jimmy Dickens Family Ministries, Inc.,

Albuquerque, NM Crosbyton CISD Foundation for

Academic Excellence, Crosbyton, TX Cycle Messenger World Championship

New York, NY Gabriels Passage, Inc., Memphis, TN Gate City Thunderbirds, Nashua, NH Gathering Ministries-Austin, Austin, TX German-American Memorial Foundation,

Norco, LA Ghetto Productions, Chicago, IL Gift to Generation, San Francisco, CA Global World Development Foundation,

Beverly Hills, CA Greater Dallas Arts Consortium, Inc.,

Dallas TX Groom Volunteer Ambulance Service,

Inc., Groom, TX Groveland Neighborhood Center, Inc.,

Cedar Bluff, VA Kalamazoo City Comics Commission,

Scholarship Fund, Inc., Edmond, OK Kids Helping Kids, Inc., Wellington, FL Kids Voting Northern Illinois, Inc.,

Springfield, IL Kimball Glassco Residential Center, Inc.,

96, San Francisco, CA Dawn House, Inc., Bay Minette, AL Dayton Rodeo Team, Dayton, TX D C Housing Education Foundation,

Inc., Washington, DC Del Norte Amateur, Crescent City, CA

Groveland, FL Harvest Fund, Inc., New York, NY

Greenville, MS

2002–32 I.R.B. 324 August 12, 2002

Lakes Area Penguin Swimmers,

Nations of the World Interfaith

Ministries, Inc., Wewoka, OK New Century Foundation, Ltd.,

Perham, MN Las Casitas De Socorro, Inc.,

Manhattan, NY New Jersey Personal Assistance Services

Prairie Family Chautauqua, Inc.,

Socorro, NM Latria, Inc., Indianapolis, IN Laura Jepson Institute, Inc.,

Casper, WY Prince Georges County Community

Development Corporation, Forestville, MD Project Respect, San Francisco, CA Rafiki AIDS Ministry, Inc.,

Tallahassee, FL Leaves of Learning, Milwaukee, WI Lincoln Magic Softball, Lincoln, NE Little Rock Citizens Police Academy

Cooperative, Inc., Long Branch, NJ New Milford Youth Baseball,

Columbus, OH Ramsey International Fine Arts Center

Foundation, Minneapolis, MN Real Lewin Torah Research Int’l Fund,

Seaside, CA Roanoke Valley Adoptive-Foster Care

Alumni Association, Little Rock, AR Llama Community Development

New Milford, CT New Village Community Public Charter

School of the East Bay, Hayward, CA New York Skyriders, Inc.,

Springfield Gardens, NY Newberry Community Day Care Center,

Inc., Newberry, FL North Texas Criminal Justice Ministries

Network, Garland, TX Northeast Organization Allied for Hope,

Inc., Brooklyn, NY Resources International, Inc.,

Corporation, Salinas, CA Lost Tribe Theatre Company, Inc.,

New York, NY Love M’ Thrift II, Inc., Mineola, NY Marcus Garvey Youth Development

Cambridge, MA Ride & Stride, Honolulu, HI R I S E Educational Services, Inc.,

Institute, Southborough, MA Maritime Youth Ministries, Inc.,

Oklahoma City, OK Matthews Challenge Biking Across

Detroit, MI Northern California Girls Athletics

Foundation, Petaluma, CA Northwest Community Housing, Inc.,

Association, Vinton, VA Robert L. Reed Tap Heritage Inst.,

St. Louis, MO ROCK, St. Peter, MN Rockwood Area Community

America for Alzheimers, Inc., New York, NY Maya Society of Minnesota, Inc.,

Dodge City, KS Northwest Polymer Clay Guild,

Organization, Rockwood, MI Roslyn Booster Basketball Club, Inc.,

Roslyn Heights, NY Sacramento Helping Professionals R

St. Paul, MN McDowell County Board of Parks &

Seattle, WA NSAA, Inc., Detroit, MI Oak Lawn Library Friends, Inc.,

Recreation, Gary, WV McDowell County Commission on

Aging, Inc., Welch, WV Mem Group, Inc., Vallejo, CA Mens Fathers Hotline, Austin, TX Mercedes Affordable Housing Corp.,

Dallas, TX Oakland Jr. Olympic Softball

Entertaining, Sacramento, CA Safety Village, Inc., Daytona Beach, FL Salem Community Skating Rink, Inc.,

Foundation, Salinas, CA San Angelo Housing Support, Inc.,

Mercedes, TX Miami Philharmonic Steel & Percussion

Association, Oakland, CA Occasional Theater, Anniston, AL Ohio Bulldogs, Reynoldsburg, OH Old Town-Buda Association, Inc.,

Buda, TX Orangemen Youth Basketball

Organization, Gurnee, IL Pacific-West Associates, Inc.,

Salem, NH Salinas Valley Aquatics Development

San Angelo, TX Schutz American Schools of Alexandria

Orchestra, Inc., North Miami, FL Mid-South Speakers Association,

Memphis, TN Military Women of New York City &

Friends, Inc., Jamaica, NY Millport Regional Resource Foundation,

Bothell, WA Parents Academic and Athletic

Community Career Counsel, Pomona, CA Park View Development Corporation,

Foundation, Pittsburgh, PA Section 8 Resident Council of New

Orleans, Inc., New Orleans, LA Service Management, Incorporated,

Taylor, MI Shades of Youth Foundation,

Millport, AL Mindanet, Inc., Little Rock, AR Minnesota Professional Athletes Youth

Charity, Minneapolis, MN Minority Economic Development, Inc.,

Washington, DC Pathfinder Historians,

Tollhouse, CA Shaw Neighborhood Improvement

Council, Washington, DC Shelter the World, Inc., San Diego, CA Short North Dallas Community

Chattanooga, TN MMM Comprehensive Learning Center,

W. Bloomfield, MI People Effectively Assisting Kids to

Succeed, Inc., Lititz, PA Persian Schools Network, Inc.,

Inc., Riverdale, IL Mokelumne Manor Thornton Homes

Development Corporation, Dallas, TX Silver Spring Youth Baseball Assoc.,

New Kingston, PA Simon Bolivar Institute, Inc., Miami, FL Sioux Land Teens Encounter Christ,

Newcastle, NE South Valley AIDS Network, Visalia, CA Southeast Center for Ecological

Resident Council, Thornton, CA Mr. Muscle Foundation, Houston, TX National Academy of Alternative

Yonkers, NY Pewaukee Fire Fighters Auxiliary, Inc.,

Waukesha, WI Phenix, Incorporated, Westland, MI Pinetree High School Crime Stoppers,

Education, New York, NY National Brachial Plex-Erbs Palsy

Association, Inc., Larsen, WI National Coalition of 100 Black Women

Longview, TX Pink Ribbon, Inc., Bogart, GA Pinnacle Park Association, Inc.,

Houston, TX Playground Partners, Borger, TX

Awareness, Inc., Chattanooga, TN Southern Cal School Foundation,

Lake City, IA

of Greater Charlotte, Inc., Fort Mill, SC

August 12, 2002 325 2002–32 I.R.B.

Women and Environmental Degradation,

Takoma Park, MD Womens Outdoor Challenges, Inc.,

Southern York County Arena,

Sanford, ME Sports, Inc., Detroit, MI St. Bernard Resident Council,

UPPCP-Unidos Para El Progresso De

Cameron Park, Brownsville, TX US Falun-Buddhism Society,

New Orleans, LA Stone-Hays Center for Independent

Living, Galesburg, IL Stop-Students that Officially Patrol,

Torrance, CA Vacaville Pony Association,

Vacaville, CA Victim Offender Reconciliation Program

Grantham, NH Wood Family International Foundation

for Multiple Sclorosis, Ft. Lauderdale, FL Woodlands Indian Community Center,

Little Rock, AR Strake Jesuit Art Museum, Houston, TX Sunrise Optimist Club of Appleton

of Sacramento County, Inc., Sacramento, CA V M & R Home Services, Inc.,

Washington, MI Wabash County Youth Baseball and

Lansing, MI Woodlawn Park Parents Club,

Foundation, Inc., Neenah, WI SW Florida Fibromyalgia Group, Inc.,

Softball, Inc., Mount Carmel, IL Walkers Elderly Home Care Services,

Indian Mound, TN Wynton M. Blount Cultural Park,

Montgomery, AL Yonkers Sponsoring Committee,

Fort Meyers, FL Take-a-Break Respit Care, Inc.,

Sarasota, FL Talamm, Silver Spring, MD Tallahassee Youth Council Initiative,

Inc., New Orleans, LA Waretown Education Association

Yonkers, NY Youth Into Adulthood Corp.,

Brooklyn, NY

Inc., Tallahassee, FL Tecumseh Area Communities in Schools,

Philanthropic Fund, Inc., Waretown, NJ Washington Area Softball Association,

Inc., Washington, IA West Point Society of the Piedmont,

Tecumseh, MI Tennessee Business Roundtable

Foundation, Nashville, TN Texas Inmate Families Association,

Greensboro, NC West Side Human Services Corporation,

San Antonio, TX Texas Vocabulary Institute, Inc.,

San Antonio, TX Therapeutic and Educational Animal

Inc., Hollywood, FL Westview PAC, Longmont, CO Willamette Youth Chorusee Northwest,

Center of Southwest Louisiana, Inc., Lake Charles, LA TIPAAA Foundation, Inc., Oakland, CA Turkmen Association, Inc.,

Lake Oswego, OR Williamson County Aquatic Team,

Franklin, TN Willis Youth Council, Inc., Willis, TX Wings A Positive Social Opportunities

Network, Commerce TWP, MI WNC Retreat Center, Inc., Asheville, NC Wolfpack Instrumental Music Support

If an organization listed above submits information that warrants the renewal of its classification as a public charity or as a private operating foundation, the Internal Revenue Service will issue a ruling or determination letter with the revised classification as to foundation status. Grantors and contributors may thereafter rely upon such ruling or determination letter as provided in section 1.509(a)–7 of the Income tax Regulations. It is not the practice of the Service to announce such revised classification of foundation status in the Internal Revenue Bulletin.

Franklin Park, NJ Tuscaloosa Volleyball Club,

Group, Van Nuys, CA

Tuscaloosa, AL

2002–32 I.R.B. 326 August 12, 2002