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Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings).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.—Internal Revenue Bulletin. LE—Lessee. LP—Limited Partner. LR—Lessor. M—Minor. Nonacq.—Nonacquiescence. O—Organization. P—Parent Corporation. PHC—Personal Holding Company.

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 For example, modified and superseded describes a situation where the substance of a previously published ruling is being changed in part and is continued without change in part and it is desired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.

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.

2003–8 I.R.B. i February 24, 2003

Numerical Finding List ¹

Bulletins 2003–1 through 2003–7

Announcements:

2003–1, 2003–2 I.R.B. 281 2003–2, 2003–3 I.R.B. 301 2003–3, 2003–4 I.R.B. 361 2003–4, 2003–5 I.R.B. 396 2003–5, 2003–5 I.R.B. 397 2003–6, 2003–6 I.R.B. 450 2003–7, 2003–6 I.R.B. 450 2003–8, 2003–6 I.R.B. 451 2003–9, 2003–7 I.R.B. 490 2003–10, 2003–7 I.R.B. 490

Notices:

2003–1, 2003–2 I.R.B. 257 2003–2, 2003–2 I.R.B. 257 2003–3, 2003–2 I.R.B. 258 2003–4, 2003–3 I.R.B. 294 2003–5, 2003–3 I.R.B. 294 2003–6, 2003–3 I.R.B. 298 2003–7, 2003–4 I.R.B. 310 2003–8, 2003–4 I.R.B. 310 2003–9, 2003–5 I.R.B. 369 2003–10, 2003–5 I.R.B. 369 2003–11, 2003–6 I.R.B. 422 2003–12, 2003–6 I.R.B. 422

Proposed Regulations:

REG–209500–86, 2003–2 I.R.B. 262 REG–125638–01, 2003–5 I.R.B. 373 REG–126016–01, 2003–7 I.R.B. 486 REG–124069–02, 2003–7 I.R.B. 488 REG–151043–02, 2003–3 I.R.B. 300 REG–164464–02, 2003–2 I.R.B. 262

Revenue Procedures:

2003–1, 2003–1, I.R.B. 1 2003–2, 2003–1, I.R.B. 76 2003–3, 2003–1, I.R.B. 113 2003–4, 2003–1, I.R.B. 123 2003–5, 2003–1, I.R.B. 163 2003–6, 2003–1, I.R.B. 191 2003–7, 2003–1, I.R.B. 233 2003–8, 2003–1, I.R.B. 236 2003–10, 2003–2 I.R.B. 259 2003–11, 2003–4 I.R.B. 311 2003–12, 2003–4 I.R.B. 316 2003–13, 2003–4 I.R.B. 317 2003–14, 2003–4 I.R.B. 319 2003–15, 2003–4 I.R.B. 321 2003–16, 2003–4 I.R.B. 359 2003–17, 2003–6 I.R.B. 427 2003–18, 2003–6 I.R.B. 439 2003–19, 2003–5 I.R.B. 371 2003–20, 2003–6 I.R.B. 445 2003–21, 2003–6 I.R.B. 448

Revenue Rulings:

2003–1, 2003–3 I.R.B. 291 2003–2, 2003–2 I.R.B. 251 2003–3, 2003–3 I.R.B. 252

1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2002–26 through 2002–52 is in Internal Revenue Bulletin 2003–1, dated January 6, 2003.

Revenue Rulings—Continued:

2003–4, 2003–4 I.R.B. 253 2003–5, 2003–5 I.R.B. 254 2003–6, 2003–3 I.R.B. 286 2003–7, 2003–5 I.R.B. 363 2003–8, 2003–3 I.R.B. 290 2003–9, 2003–4 I.R.B. 303 2003–10, 2003–3 I.R.B. 288 2003–11, 2003–3 I.R.B. 285 2003–12, 2003–3 I.R.B. 283 2003–13, 2003–4 I.R.B. 305 2003–14, 2003–4 I.R.B. 302 2003–15, 2003–4 I.R.B. 302 2003–16, 2003–6 I.R.B. 401 2003–17, 2003–6 I.R.B. 400 2003–18, 2003–7 I.R.B. 467 2003–19, 2003–7 I.R.B. 468 2003–20, 2003–7 I.R.B. 465

Treasury Decisions:

9024, 2003–5 I.R.B. 365 9025, 2003–5 I.R.B. 362 9026, 2003–5 I.R.B. 366 9027, 2003–6 I.R.B. 413 9028, 2003–6 I.R.B. 415 9029, 2003–6 I.R.B. 403 9032, 2003–7 I.R.B. 471 9033, 2003–7 I.R.B. 483 9034, 2003–7 I.R.B. 453

February 24, 2003 ii 2003–8 I.R.B.

Finding List of Current Actions on Previously Published Items ²

Bulletins 2003–1 through 2003–7

Notices:

97–19 Modified by Rev. Proc. 2003–1, 2003–1 I.R.B. 1

2001–26 Obsoleted by T.D. 9032, 2003–7 I.R.B. 471

2001–46 Modified by Notice 2003–6, 2003–3 I.R.B. 298

2001–69 Modified and superseded by Notice 2003–1, 2003–2 I.R.B. 257

2002–27 Clarified by Notice 2003–3, 2003–2 I.R.B. 258

2002–46 Modified by Notice 2003–10, 2003–5 I.R.B. 369

Proposed Regulations:

REG–209500–86 Corrected by Ann. 2003–6, 2003–6 I.R.B. 450

REG–164464–02 Corrected by Ann. 2003–6, 2003–6 I.R.B. 450

Revenue Procedures:

83–23 Supplemented by Rev. Proc. 2003–21, 2003–6 I.R.B. 448

84–37 Modified by Rev. Proc. 2003–1, 2003–1 I.R.B. 1

93–38 Obsoleted by Rev. Proc. 2003–15, 2003–4 I.R.B. 321

98–13 Obsoleted by T.D. 9032, 2003–7 I.R.B. 471

2002–1 Superseded by Rev. Proc. 2003–1, 2003–1 I.R.B. 1

2002–2 Superseded by Rev. Proc. 2003–2, 2003–1 I.R.B. 76

2002–3 Superseded by Rev. Proc. 2003–3, 2003–1 I.R.B. 113

2 A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2002–26 through 2002–52 is in Internal Revenue Bulletin 2003–1, dated January 6, 2003.

Revenue Procedures—Continued:

2002–4 Superseded by Rev. Proc. 2003–4, 2003–1 I.R.B. 123

2002–5 Superseded by Rev. Proc. 2003–5, 2003–1 I.R.B. 163

2002–6 Superseded by Rev. Proc. 2003–6, 2003–1 I.R.B. 191

2002–7 Superseded by Rev. Proc. 2003–7, 2003–1 I.R.B. 233

2002–8 Superseded by Rev. Proc. 2003–8, 2003–1 I.R.B. 236

2002–9 Modified and amplified by Rev. Proc. 2003–20, 2003–6 I.R.B. 445 Rev. Rul. 2003–3, 2003–2 I.R.B. 252

2002–22 Modified by Rev. Proc. 2003–3, 2003–1 I.R.B. 113

2002–29 Modified by Rev. Proc. 2003–10, 2003–2 I.R.B. 259

2002–52 Modified by Rev. Proc. 2003–1, 2003–1 I.R.B. 1

2002–67 Supplemented by Ann. 2003–3, 2003–4 I.R.B. 361

2002–75 Superseded by Rev. Proc. 2003–3, 2003–1 I.R.B. 113

2003–3 Amplified by Rev. Proc. 2003–14, 2003–4 I.R.B. 319

2003–7 Corrected by Ann. 2003–4, 2003–5 I.R.B 396

Revenue Rulings:

53–131 Modified by Rev. Rul. 2003–12, 2003–3 I.R.B. 283

57–190 Obsoleted by Rev. Rul. 2003–18, 2003–7 I.R.B. 467

65–190 Revoked by Rev. Rul. 2003–3, 2003–2 I.R.B. 252

69–372 Revoked by Rev. Rul. 2003–3, 2003–2 I.R.B. 252

Treasury Decisions:

9002 Corrected by Ann. 2003–8, 2003–6 I.R.B. 451

9022 Supplemented by Ann. 2003–7, 2003–6 I.R.B. 450

2003–8 I.R.B. iii *U.S. Government Printing Office: 2003—496-919/60071 February 24, 2003