INCOME TAX — Internal Revenue Bulletin 2005-52

Accounting methods:

Automatic consent to change to a method under which a utility

may treat an up-front payment for network upgrades as not being taxable income when received (RP 35) 28, 76 Changes in method of accounting, time periods for requesting

consent (RP 63) 36, 491 Change in reporting method for eligible educational institu tion (RP 50) 32, 272 Credit card cash advance fees (RP 47) 32, 269 Request for comments, possible changes to procedures, auto matic consent from Commissioner (Notice 97) 52, 1210 Uniform capitalization of costs, environmental remediation

(RR 42) 28, 67 Air transportation services subject to tax, passive losses (RR 64)

39, 600 Amended returns, qualified, John Doe summons (TD 9186); cor rection (Ann 53) 31, 258 ; correction (Ann 61) 36, 495 Arbitrage rebate payments:

Address change (Notice 52) 28, 75 Late payment (RP 40) 28, 83 ATM surcharge, treatment of cardholder surcharge fees by credit

card issuers (RR 47) 32, 261 Balanced system for measuring organizational and employee performance within IRS (TD 9227) 45, 924 ; (REG–114444–05) 45, 934 Base period T-bill rate, 2005 (RR 70) 45, 919 Charitable contributions:

Allocation and apportionment of deductions (TD 9211) 33,

287 Food donations, contribution base (Ann 84) 48, 1064 Charitable remainder unitrusts (CRUTs):

Inter vivos:

For a term of years (RP 53) 34, 339 For one measuring life (RP 52) 34, 326 With concurrent and consecutive interests for two measur ing lives (RP 55) 34, 367 With consecutive interests for two measuring lives (RP 54)

34, 353 Testamentary:

For a term of years (RP 57) 34, 392 For one measuring life (RP 56) 34, 383 With concurrent and consecutive interests for two measur ing lives (RP 59) 34, 412 With consecutive interests for two measuring lives (RP 58)

34, 402 Collection due process hearings, clarification of the way con ducted:

Federal tax lien (REG–150088–02) 43, 774 Levy (REG–150091–02) 43, 780 Compensation for labor or personal services, basis for determin ing source (TD 9212) 35, 429 Consumer Price Index (CPI) adjustments:

Below-market loans under section 7872(g) for 2006 (RR 75)

49, 1073 Certain loans under section 1274A for 2006 (RR 76) 49, 1072