SPECIAL ANNOUNCEMENTS

Announcement 2002–96, page 756. The Service announces that the Appeals settlement initiative with respect to broad-based leveraged corporate owned life insurance (COLI) plans purchased after June 20, 1986, will be terminated. The Service will vigorously defend or prosecute all future COLI litigation. There will be a 45-day window within which taxpayers will be permitted to enter into the current settlement arrangement by submitting to the Internal Revenue Service a formal written offer to settle.

Announcement 2002–97, page 757. Under the terms of this announcement, taxpayers who have engaged in basis-shifting transactions will be given the opportunity to resolve this issue with minimal further examination or other administrative proceedings. Participating taxpayers will enter into a settlement with fixed terms that are specified in the announcement.