Part IV. Items of General Interest

Foundations Status of Certain Organizations

Announcement 2002–69

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

Acts of Praise, Inc., Norcross, GA Adullam Services, Olympic, WA Agency Niagara, Inc., Tonawanda, NY Akan Studies Institute, Washington, DC All Nations Fund, Woodland Hills, CA Allegiance Ministries, Inc.,

Pickerington, OH Alpha Watch Family Counceling, Inc.,

Staten Island, NY Alternatives for Youth, Cleveland, OH Alumnae Association St. Elizabeth

Hospital School of Nursing, Lafayette, IN American Alliance for Charity, Inc.,

Bronx, NY American Association of Artists, Inc.,

Venice, CA American Friends of Aphrodisias,

New York, NY American Gospel Music Heritage

Foundation, Inc., Baltimore, MD American Housing Foundation,

Schaumberg, IL Americans for a Better America, Inc.,

White Plains, NY AnCam Antique Airfield Museum,

West Burlington, IA Angels Touch Foundation, Clovis, CA Anthony Kincade Scholarship Foundation,

Inc., Crown Point, IN

Archipelagos Regeneration & Restoration

Group, Honolulu, HI Art of Living, Inc., Ft. Lauderdale, FL Art Rod Foundation, Inc., Metamora, FL Asamang Relief Donation,

Delray Beach, FL Aurora Puerto Rican Cultural Council,

Inc., Aurora, IN Autumn Hills Health Foundation,

Kansas City, MO Azusa Pacific University Foundation,

Azusa, CA B C Inspiration, Inc., West Hollywood, FL Basin Educational Excelence Foundation,

Burton, TX Belding Housing Development and

Services Corporation, Belding, MI Ben Benavidez Advocacy Center,

Fontana, CA Bethlehem Babe Ruth, Inc., Delmar, NY Birthright of Aurora, Aurora, MN Big Island Residential, Inc., Honolulu, HI Blessed Brotherhood of the Ancient

Church — Minnesota, St. Paul, MN Booker T. Washington Education Training

& Community Development, Inc., Fresno, CA Books to Read, Murrieta, CA Brave New World, Inc., Washington, DC Bread of Life Community Development

Corporation, Detroit, MI Breaking Chains, Inc., Philadelphia, PA Business and Economic Access,

Incorporated, Whittier, CA California Womens Basketball Academy,

Newport Beach, CA Capistrano Charitable Foundation,

San Juan Capo, CA Caritas Traditionalis — The Institute of

Biomedicine and Sciences, Tucson, AZ Cars for Charities, Inc., Texarkana, TX Celestial Flight Nonprofit Housing

Corporation, Detroit, MI Center for National Software Studies,

Reston, VA Center for Strategic Economic Studies and

Institutional Dvlp., Inc., Baltimore, MD Center for Teacher Professionalism,

Grass Valley, CA Center for Teaching Learning and Culture,

Inc., Landover Hills, MD Chaplain Services, Inc., Sandy, OR Charitable Religious Organization,

Boston, MA Charles E. Beard Memorial School

Corporation, Knightstown, IN

Cherish the Children Foundation-Luwann

Youth Center, Inglewood, CA Chicago Health Initiative CHI,

Chicago, IL Chicago Juvenile Advisory Council,

Chicago, IL Chicago Printing Ink Production Club,

Inc., Hickory Hills, IL Chice, Inc., Omaha, NE Childhood Incontinence Institute,

Austin, TX Children 2000, Inc., New York, NY Children Oncology Cycling of America,

Clifton Park, NY Children’s 2000 Foundation, Justin, TX Children’s Depot, Calumet Park, IL Childrens Empowerment Fund,

Huntsville, TX Christ Is First Productions, Chicago, IL Christian Children Complete Camping,

Philadelphia, PA Christian Faith Outreach Community

Development Corporation, Inc., Ft. Lauderdale, FL Christian Mission Learning Foundation,

Jackson, MS Christian Voices in Unity, Inc.,

Baltimore, MD City of Ardmore Cemetery Trust Fund,

Inc., Ardmore, OK Coalition for Alcohol-Free Kids, Inc.,

Natick, MA Coalition for Corrections Reform,

Jackson, MI Coitsville Historical Society, Inc.,

Lowellville, OH Columbia Research Institute,

Olympia, WA Community Caring Centers of New

Orleans, Inc., New Orleans, LA Community Church of Christ of Colorado

Springs, Colorado Springs, CO Community Connections, Inc.,

Buchanan, MI Community Empowerment Organization,

Inc., Yorktown, VA Community Hope Foundation,

Long Beach, CA Community Media Services, Fairfax, VA Compassionate Hearts & Hands

International, Columbia, SC Co-Operative Opportunity for Online

Learning, Tiburon, CA Copper Basin Lady Cougar Tip-Off Club,

Inc., Copperhill, TN Creatures Great & Small, Davis, OK

November 17, 2003 1086 2003-46 I.R.B.

Home for Every Child Foundation,

Sharpsville, IN Homes for Families, Inc., New York, NY Homesteade Assist Living, Inc.,

West Friendship, MD Hoop City Foundation, Wichita, KS Hope of North Carolina, Zebulon, NC H.O.P.E. Vocational Services, Ltd.,

Walnut Creek, CA House of Prayer Economic Development,

Inc., Lakeland, FL House of Reuben, Andover, MA Idaho Celebrity Classics, Inc., Boise, ID India for Jesus, Colleyville, TX Indiana Consortium on Professional Dev.

for Educ. of Young Children, Inc., Indianapolis, IN Indy Jazz Fest, Inc., Indianapolis, IN Inner City Development Foundation,

Los Angeles, CA International Center for Education About

Aging, Inc., Auburndale, MA International College of Psychology

Foundation, Carlsbad, NM International Health Resources, Pryor, OK International Sailing Hall of Fame,

Jensen Beach, FL Irene E. Boothe Book Review Club,

Fort Worth, TX Island Business Connection, Inc.,

Pawtucket, RI Ivie Carter Home, Inc., Lithonia, GA Jade Art Foundation, New York, NY Jefferson 21st Century Institute,

Centerville, UT Jefferson Park Housing Development

Fund Company, Inc., Rochester, NY Jermiah Restoration Ministry, Inc.,

Elgin, IL Jesus Loves You, Inc., Colleyville, TX Joes Good Samaritan Soup Kitchen,

Prichard, AL John and Mildred Medic Wuchenich

Foundation, Redlands, CA John Campbell Ministries,

Youngstown, OH Jones Community Support Center,

Clarksdale, MS Journey With Jesus, Dyersburg, TN K A S T, Inc., Springfield, MO Kevin Ghelli Celebration Fund, Inc.,

Holliston, MA Khan Universal Foundation, Inc.,

Armonk, NY Kids Land Daycare and Teenage

Mentoring Service, Inc., Kansas City, KS Kinship of Monticello, Monticello, MN

David Yaghoubi Foundation, Inc.,

Secaucus, NJ Developmental Resource Corporation,

Shreveport, LA Doggone Dogs of South Florida, Inc.,

Hollywood, FL Dogwood Springs Outreach, Inc.,

Richmond Hill, GA Don Smith Ministries, Aurora, CO Dream Camps of Cary, Inc., Cary, NC Dzilth Na Odilth Ne Resident

Organization, Bloomfield, NM Eagles Nest Ranch of North Carolina,

Randleman, NC East African Refugees in North America,

Minneapolis, MN Eco Balance, La Mesa, CA Eco Impact, La Mesa, CA Eco-Watch, Inc., Bettendorf, IA Edge Jumper Children’s Foundation,

Sonoma, CA Education Project Foundation, Detroit, MI Educational and Group Support Found.

for Epilepsy and Asthma, Ventura, CA El Paso Association of Adult Educators,

El Paso, TX Emerald Therapeutic Riding Academy,

Westlake, OH Emergency Transportation Team or Iron

Posse, Michigan City, IN Employment Action Resource Network,

Inc., New York, NY Empowerment Through Perserverance,

Inc., Saint Albans, NY Enabling Sport Foundation, Franklin, NH Endangered Species Arts Alliance,

Denver, CO Environmentally Correct, Inc., Reno, NV Equal Employment Opportunity Network,

Bel Air, MD Equal Partners, Inc., Southhampton, NJ Esti Topfer Foundation, Miami, FL Every-Day Angels Foundation,

Beverly Hills, CA Excell Clinical Laboratories, Inc.,

Brighton, MA Faith Tabernacle Community

Development Corporation, Inc., Chicago, IL Fellowship Deliverance Ministries, Inc.,

Lagrange, GA First Congregational Christian United

Church of Christ, Irvington, NJ First Night Gloucester, Inc.,

Gloucester, MA First Page New Chapter & Peer Adviser

Learning Skills FPNC & PAL, Castro Valley, CA

First Tee of Howard County, Inc.,

Columbia, MD Florida Institute of Research Science &

Technology, Inc., Jacksonville, FL Forensis, Inc., San Diego, CA Foundation for Entrepreneurship, Inc.,

New York, NY Freedom Farm, Cary, IL Freeport Community Services Center,

Inc., Freeport, NY Friends of Arborough Games, Inc.,

Ann Arbor, MI Friends of Callithea Farm, Inc.,

Potomac, MD Friends of Santa, Inc., Sicklerville, NJ Friends of the Elderly, Inc.,

Lincolndale, NY Friends of West Portland, Inc.,

Springfield Gardens, NY Gabryelski Film Art Foundation,

New York, NY Georgia Sulprizio Scholarship Fund,

Danville, CA Gesher L. Kehillatenu Foundation,

Cambridge, MA Girls Unlimited, Inc., Decatur, GA Giving Tree Foundation, Inc.,

Agoura Hills, CA Global Education Development, Inc.,

Albuquerque, NM Global Foundation, Woburn, MA Global Imperative, La Mesa, CA God’s People, Incorporated, Atlanta, GA Goddard Foundation, Cordova, TN Gold Coast Shakespeare Festival, Inc.,

New York, NY Grayson’s Awareness Outreach,

Los Angeles, CA Greater Flint RC IMAA Chapter 365,

Flint, MI Greater New Jericho Bible College,

Rosewood, CA Guardian Angel Foundation for Homeless

Children, Lumberton, NC Haitian American Community

Broadcasting Association, Inc., Miami, FL Hammond Babe Ruth League,

Hammond, IN Hawkins Village Resident Council,

Pittsburgh, PA Heartland Railroad Historical Society,

Council Bluff, IA Hearts Hands Center for Mental Health,

Inc., Platteville, WI Helping Home of America,

Los Angeles, CA

2003-46 I.R.B. 1087 November 17, 2003

Northwest Colorectal Foundation,

Seattle, WA Ogden Business Development Committee,

Ogden, IL Olive Branch Early Learning &

Enrichment Center, Inc., Atlanta, GA Omonoia Cretan Charitable Foundation,

Inc., Hauppauge, NY Open Arms Outreach, Inc., Valdosta, GA Open Mind Foundation,

Salt Lake City, UT Order of Ahepa District 17 Scholarship,

Belen, NM Ordinary Theater, New York, NY Orlando Branches Steel Orchestra, Inc.,

Orlando, FL Outreach Needs Effort, Seattle, WA Overton Park SDA Church Community

Center, Memphis, TN Owensboro Family YMCA Endowment

Fund, Inc., Owensboro, KY Palm Reef, Inc., Thayne, WY Pan American Institute for Medical

Education and Research, Inc., Houston, TX Parama Retreat Center, Inc., Elmore, VT Parental Guidance Associates,

Wallingford, PA Park Flava Foundation,

Stone Mountain, GA Partners in Art, Inc., Sheldonville, MA Partnership for Sri Lanku-USA,

West Springfield, MA Paw Patch, Ltd., Pawling, NY Pawnee Pioneer Trails Scenic and

Historical Byway Council, Inc., Sterling, CO Penn North Revitalize Corporation,

Baltimore, MD Pens Across the Metroplex,

Kansas City, MO People Aiding Feral Cats, Ventura, CA Perry County Community Association,

Newbern, AL Personal Touch Incentive Center, Inc.,

Los Angeles, CA PHA Development Corporation,

Miami, OK Philadelphia Scholastic Rowing

Association, Philadelphia, PA Phoenix Project, Inc., Baltimore, MD Podiatry Research & Educational

Foundation, Inc., Belleville, NJ Possibilities for Youth, Divide, CO Power of Tehillum, Brooklyn, NY Prairie Health Services, Inc., Hopedale, IL Praxis Youth Development Corp.,

Layton, UT

Kiwanis Club of Concord NH Charitable

Foundation, Concord, NH Kiwanis Club of Covington Foundation,

Covington, WA Koda Foundation, Peever, SD Ladies Health Foundation, Cerritos, CA Lancaster Community Housing

Corporation, Lancaster, OH Landhealers Ministries, Kalamazoo, MI Learning Disabilities Association

for Nassau Suffolk Counties, Inc., Massapequa Park, NY Leon and Ollie Craig Foundation, Inc.,

Visalia, CA Let’s Grow, Inc., Silver Spring, MD Lighted Candle Society, Bountiful, UT Living With Lupus Foundation, Inc.,

Jacksonville, AR Londonderry Basketball Club,

Londonderry, NH Long Beach Air Museum, Lawndale, CA Long View Learning, Inc., Raleigh, NC Loveforce Ministries, Inc., Atlanta, GA Lynnhaven Kiwanis Charity Foundation,

Norfolk, VA M. B. Peterson Ministries, Inc., Miami, FL Majestic Wildlife Rehabilitation &

Education Center, Inc., Bethlehem, PA Maloney Group, Florissant, MO Maloney Group II, Florissant, MO Maloney Group III, Florissant, MO Maloney Group IV, Hazelwood, MO Marriage & Family Success Center, Inc.,

Mission Viejo, CA Martina Starke Foundation, Incorporated,

Whitakers, NC McCloud Memorial Foundation,

Elmendorf AFB, AK Medical Center Resident Advisory Group,

San Bernardino, CA Memphis Community Development

Partnership, Inc., Memphis, TN Men-N-Effect Civic Sports,

Chesapeake, VA Meriden Community Action Agency, Inc.,

Meriden, CT Metro Ferals, Inc., Arlington, VA Midwest Care Centers, Inc.,

Kansas City, MO Midwest Care Center II, Inc.,

Kansas City, MO Midwest Care Center III, Inc.,

Kansas City, MO Midwest Care Center IV, Inc.,

Kansas City, MO Midwest Care Center V, Inc.,

Kansas City, MO

Midwest Care Center VI, Inc.,

Kansas City, MO Midwest Care Center VII, Inc.,

Kansas City, MO Midwest Care Center VIII, Inc.,

Kansas City, MO Midwest Care Center IX, Inc.,

Kansas City, MO Ministry Resources, Inc., Charlotte, NC Minnesota Attainable Housing

Corporation I, Minneapolis, MN Mission of Light, Inc., Sherwood, MI Mixed Pickles Vintage Dance Company,

Philadelphia, PA Moon School Parents Club, Waterford, CA Mothers Dream, Lexington, SC Mountain Empire Athletic League,

Campo, CA Mt. Olive Community Development

Ministries, Inc., Jacksonville, FL Multi-Cultural Center of Southeast Texas,

Beaumont, TX My Brothers Helper, Inc., Oakland, CA Nashua Downtown Development

Corporation, Nashua, NH National Alliance for the Protection of

Our Children, Salt Lake City, UT National Association of Federal Law

Enforcement Assistance Group, Ltd., New York, NY National Baptist Convention Housing

Board, Inc., Newark, OH Natural High Adventures,

Los Angeles, CA Natures Neighbors, Jemul, CA Neighborhood Educational Empowerment

Development Services, Joliet, IL Never Again Treatment Facility,

Chicago, IL New Dawn Foundation, Palmdale, CA New Dawn Residential Facility,

Youngstown, OH New Jersey Community Development

Enterprises, Inc., Orange, NJ New Light Consultants, Millington, MI New Priorities Child Refuge, Bend, OR New Ventures Community Development

Corporation, Inc., Bridgeport, CT New World Youth Center, Gardena, CA New York Metro American Studies

Association, Inc., Brooklyn, NY Niche Ministries, Inc., Sonora, CA Nigerian Peoples Forum NPF,

Rockville, MD Nineteenth Street Baptist Church

Community Development Corporation, Washington, DC NISAA, Inc., Syracuse, NY

November 17, 2003 1088 2003-46 I.R.B.

Virginia Skeet Shooting Association, Inc.,

Annandale, VA Virtual Diagnostic and Rehabilitation

Scenarios, Inc., Newton, MA Volleyball Development Corp.,

Saint Louis, MO Wang Yun-Wu Foundation, Inc.,

Redwood City, CA Warwick Revitalization, Inc.,

Warwick, GA Wasco County Historical Museum,

The Dalles, OR Watchkeepers, Inc., Middleboro, MA Wayne Morse Youth Program,

Eugene, OR Waynoka Ministries, Inc.,

Oklahoma City, OK We Share, Inc., Atlanta, GA Western Health Foundation, Arcadia, CA Williamsburg Basketball League, Inc.,

Brooklyn, NY Willits Senior Housing Corporation,

Ukiah, CA Willing Hearts, Inc., San Antonio, TX Wind Symphony of Corpus Christi,

Alice, TX Windsor Repertory Theater Co., Inc.,

Mineola, NY Women’s Day USA, Santa Monica, CA Women’s Institute for Personal and

Political Justice, Santa Barbara, CA Worcester Area Dual Diagnosis Task

Force, Inc., Worcester, MA Word & Praise Ministries International,

Inc., Tulsa, OK World Center for Clinical Research,

Reno, NV World Foundation for Smart

Communities, La Jolla, CA World Species List-Natural Features

Registry Institute, Savannah, GA Wounded Healers, Miami, FL Wyoming Press Association Foundation,

Cheyenne, WY Yankton Swim Team, Yankton, SD Yesterday, Today, Tomorrow, Inc.,

Lake Charles, LA You Belong, Inc., Fontana, CA Young Eagles, Inc., Los Angeles, CA Yuba Volunteer Fire Dept., Hendrix, OK Zanadu Performing Arts Centre,

Newport News, VA

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

Presbyterian Homes Mill Pond Care

Center, Inc., Roseville, MN Professional Education and Training

Association of Alaska, Inc., Juneau, AK Progressive Housing Solutions of Florida,

Inc., St. Petersburg, FL Promise, Incorporated, Toledo, OH Quality Childcare Center, Kenner, LA Quantize Records, Inc., McCormick, SC Rainbow Club, Inc., Old Greenwich, CT Rammoth Deliverance Ministries,

Raymond, MS Ranch, Inc., Menomonee Falls, WI Reading Education for Adults, Inc.,

Lake Jackson, TX Recap Development, Inc., Houston, TX Red River Place Housing, Inc.,

Houston, TX Religious Times, Philadelphia, PA Remembrance Society, Alameda, CA Resident’s Council of Brevard Housing

Authority, Inc., Brevard, NC Rock, Tampa, FL Rodney McBride Arts Society,

Palo Alto, CA S A C, Inc., Washington, DC San Angelo Chamber of Commerce

Development Organization, San Angelo, TX Santa Barbara Jazz Hall, Inc.,

Santa Barbara, CA Save a Life 2000 Coalition, Bronx, NY School Bus Drug Prevention, Inc.,

Aventura, FL Scope USA, Inc., Wauseon, OH Seafood Producers Cooperative

Foundation, Bellingham, WA Share a Suit Foundation, Chicago, IL Sharetech, Inc., Chubbuck, ID Shelton Youth Programs, Shelton, WA Shepherd Ministries, Columbia, SC Sirenia Center, Inc., Sunrise, FL Simon Peter Ministries, Yamika, WA Sister Cities Foundation, Tempe, AZ Sister Niguma Productions, Inc.,

Boulder, CO Sisters Striving for Entrepreneurship, Inc.,

Decatur, GA Society for the Prevention of Domestic

Violence, Inc., New York, NY Southeast Corner Alliance of

Neighborhoods, Austin, TX Southeast Texas Girls Softball

Association, Inc., Beaumont, TX Spine & Scoliosis Research Associates,

Inc., Summit, NJ Spirit Word Teaching Ministries and Bible

Training Center Intl., Inc., Barstow, CA

Spur on Ministries, Inc., Okeechobee, FL St. Ephrem Foundation, Inc.,

Kiennelon, NJ S.T.E.P., Compton, CA Step Up Community Partnership for Good

Parenting, Cleveland, MS Stepfamily Network, Palo Alto, CA Still Water Area Baseball Boosters,

Still Water, MN Students at Risk, Inc., Prospect, KY Summit of Fairfield County, Incorporated,

Fairfield, CT Sure Foundation, Inc., Baltimore, MD Surrogate Father Program, Inc.,

Martinsburg, WV Survivor Fund, New York, NY S V U Outreach Programs, Inc.,

Detroit, MI Task of Rome GA, Inc., Rome, GA Tejano Policy Institute, Houston, TX Texas Volunteer, Mission, TX Thapar Institute of Engineering and

Technology Patiala Ed Tr Ltd., Iowa City, IA Third Millenium Catholic Artists,

Miami, FL Third Wave Institute, Inc.,

Bloomington, IN Thomas Alva Edison Foundation,

Washington, DC Thunder Fastpitch, Inc., Eagle, ID Tiger Baseball Association, Inc.,

Lees Summit, MO Tobey Homestead Restoration Trust, Inc.,

Wareham, MA Todd Theatre Troupe, New York, NY Torat Hayim, Los Angeles, CA Trainease International, Inc.,

Middletown, NY Transform and Transcend, Inc., Salem, OR Transformation Retreats, Incorporated,

Richmond, VA Tri State Animal Rescue Services, Inc.,

Mineola, NY Tri State Urban Renewal, East Orange, NJ Trigg Hospital Foundation,

Tucumcari, NM Trinity Alliance, Inc., N. Miami Beach, FL Troy Local Development Corporation,

Troy, NY Tyn, Inc., Santa Barbara, CA Ultimate Vision Ministries, Inc.,

Arnold, MO Universal Divine Saviors, Chicago, IL Utah Woodcarvers Guild, Sandy, UT Veterans Memorial of Alto Pass Area,

Alto Pass, IL

2003-46 I.R.B. 1089 November 17, 2003

Although the Service will resume its ruling practice, the Service has continuing concerns regarding the sampling and data/record retention practices prevalent in the synthetic fuels industry. Accordingly, in order to receive future rulings, taxpayers will be required to (i) maintain sampling and quality control procedures that conform to ASTM or other appropriate industry guidelines at their synthetic fuel production facilities, (ii) obtain regular reports from independent laboratories that have analyzed the synthetic fuel produced in such facilities to verify that the coal used to produce the fuel undergoes a significant chemical change, consistent with prior ruling practice, and (iii) maintain records and data underlying the reports that taxpayers obtain from independent laboratories including raw FTIR data, and processed FTIR data sufficient to document the selection of absorption peaks and integration points. The Service also plans to issue guidance extending these requirements to taxpayers already holding rulings on the issue of significant chemical change. In addition to these requirements, the Service is considering whether to impose certain requirements on laboratories used by taxpayers to demonstrate significant chemical change, consistent with prior ruling practice, such as requiring that the laboratories be accredited by the NIST National Voluntary Laboratory Accreditation Program.

DRAFTING INFORMATION

The principal author of this announcement is Joseph H. Makurath of the Office of Associate Chief Counsel (Passthroughs & Special Industries). For further information regarding this announcement, contact Jaime C. Park at (202) 622–3120 (not a toll-free call).

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.

Section 29—Test Procedures and Significant Chemical Change

Announcement 2003–70

Section 29 of the Internal Revenue Code provides a tax credit for the production and sale of solid synthetic fuels produced from coal. Rev. Rul. 86–100, 1986–2 C.B. 3, adopts for purposes of § 29(c)(1)(C) the definition of synthetic fuel in § 1.48–9(c)(5) of the Income Tax Regulations. Section 1.48–9(c)(5)(ii) provides that, to be “synthetic,” a fuel must differ significantly in chemical composition, as opposed to physical composition, from the substance used to produce it. Rev. Rul. 86–100 describes favorably processes such as gasification, liquefaction, and production of solvent refined coal that result in substantial chemical changes to the entire coal feedstock rather than changes that affect only the surface of the coal.

Consistent with its ruling practice that began in the mid 1990’s, the Internal Revenue Service, in Rev. Proc. 2001–30, 2001–1 C.B.1163, provided that taxpayers must satisfy certain conditions in order to obtain a letter ruling that a solid fuel (other than coke) produced from coal is a qualified fuel under § 29(c)(1)(C). Rev. Proc. 2001–30, as modified by Rev. Proc. 2001–34, 2001–1 C.B. 1293. The revenue procedure requires taxpayers to present evidence that all, or substantially all, of the

coal used as feedstock undergoes a significant chemical change. To meet this requirement and obtain favorable private letter rulings, taxpayers have provided expert reports asserting that their processes resulted in a significant chemical change.

In Announcement 2003–46, 2003–30 I.R.B. 222, the Service stated that it would review the scientific validity of test procedures and results presented as evidence of significant chemical change. The Service also stated that no additional rulings on the question of significant chemical change would be issued until the completion of the review.

The principal tests used to determine that chemical changes to coal have occurred involve sophisticated technology and a large number of complex steps to prepare samples for testing as well as to analyze and interpret results. In reviewing these tests, the Service has consulted with experts and has considered the views of taxpayers in the synthetic fuels industry and their experts and advisers.

The Service has finished the review started with Announcement 2003–46. As a result of this review, the Service has determined that the test procedures and results used by taxpayers are scientifically valid if the procedures are applied in a consistent and unbiased manner. The Service believes, however, that the processes approved under its long standing ruling practice and as set forth in Rev. Proc. 2001–30 do not produce the level of chemical change required by § 29 (c)(1)(C) and Rev. Rul. 86–100. Nevertheless, the Service continues to recognize that many taxpayers and their investors have relied on its long standing ruling practice to make investments. Therefore, the Service will continue to issue rulings on significant chemical change but only under the guidelines set forth in Rev. Proc. 2001–30, as modified by Rev. Proc. 2001–34.