INCOME TAX—Cont.

Reporting requirements for widely held fixed investment trusts

(TD 9241) 7, 427 Revocations, exempt organizations (Ann 3) 3, 327 ; (Ann 9) 5,

392 ; (Ann 13) 7, 462 Section 1503(d) filings, adoption of reasonable cause standard

(Notice 13) 8, 496 Stocks:

Application of section 409A to outstanding stock rights (No tice 4) 3, 307 Determination of basis of stock and securities received in cer tain transactions (TD 9244) 8, 463 Treatment of excess loss accounts (TD 9244) 8, 463 ;

(REG–138879–05) 8, 503 Substitute for return, Internal Revenue officer or employee, hear ing on REG–131739–03 (Ann 10) 5, 393 Tax conventions:

Japan Investment Bank memorandum of understanding

(MOU) (Ann 6) 4, 340 Superseding U.S.-Mexico LLC mutual agreement procedure

(MAP) (Ann 8) 4, 344 U.S.-Canada Appeals memorandum of understanding (MOU)

(Ann 7) 4, 342 Technical Advice Memoranda (TAMs) and Technical Expedited

Advice Memoranda (TEAMs) (RP 2) 1, 89 Waiver of penalties for failure to report loan origination fees and

capitalized interest (Notice 5) 4, 348