INCOME TAX—Cont.

For one measuring life (RP 57) 31,

257 With concurrent and consecutive in terests for two measuring lives (RP 60) 31, 274 With consecutive interests for two

measuring lives (RP 59) 31, 268 Child’s attainment of an age (RR 72) 33,

346 Common trust fund, listed transaction,

straddle, tax shelter (Notice 54) 33, 363 Compliance initiative, nonresident aliens

and foreign corporations (Notice 38) 27, 9 Consumer Price Index (CPI) adjustments:

Below-market loans under section 7872(g) for 2004 (RR 118) 47, 1095 Certain loans under section 1274A for

2004 (RR 119) 47, 1094 Controlled foreign corporations, insur ance business treated as a domestic corporation (RP 47) 28, 55 Corporations:

Distributions of interests in a loss cor poration from qualified trusts (TD 9063) 36, 510 ; (REG–108676–03) 36, 523 Effect of section 338(h)(10) elec tions in certain multi-step transactions (TD 9071) 38, 560 ; (REG–143679–02) 38, 592 Outbound liquidations to foreign cor porations (TD 9066) 36, 509 Spin-offs, stock distributions:

Acquisition by an unrelated corpo ration (RR 79) 29, 80 Requests for letter ruling or deter mination letter (RP 48) 29, 86 Separation of two different busi nesses within the same corporate group:

To concentrate on one business

(RR 74) 29, 77 To resolve capital allocation problem (RR 75) 29, 79 Treatment of foreign stapled entity un der section 269B as domestic (Notice 50) 32, 295 Worthless security deduction, deemed

liquidation, election to change entity classification (RR 125) 52, 1243 Cost of living adjustments for inflation for

2004 (RP 85) 49, 1184 Costs attributable to stock options in

qualified cost sharing arrangements (TD 9088) 42, 841