SECTION 6. DRAFTING

INFORMATION

The principal author of this revenue procedure is Marnette M. Myers of the Office of Associate Chief Counsel (Income Tax & Accounting). For further information regarding sections 2.04 and 4 of this revenue procedure, contact Jeanne Royal Singley at (202) 622–0047 (not a toll-free call). For further information regarding the remainder of this revenue procedure, contact Ms. Myers at (202) 622–4920 (not a toll-free call).

age annual net income tax” of more than $136,000 for the five taxable years ending before the date of the loss of United States citizenship under § 877(a)(2)(A) is subject to tax under § 877(b).

.30 Foreign Earned Income Exclusion . For taxable years beginning in 2007, the foreign earned income exclusion amount under § 911(b)(2)(D)(i) is $85,700.

.31 Valuation of Qualified Real Prop- erty in Decedent’s Gross Estate . For an estate of a decedent dying in calendar year 2007, if the executor elects to use the special use valuation method under § 2032A for qualified real property, the aggregate decrease in the value of qualified real property resulting from electing to use § 2032A for purposes of the estate tax can not exceed $940,000.

.32 Annual Exclusion for Gifts . (1) For calendar year 2007, the first $12,000 of gifts to any person (other than gifts of future interests in property) are not included in the total amount of taxable gifts under § 2503 made during that year.

(2) For calendar year 2007, the first $125,000 of gifts to a spouse who is not a citizen of the United States (other than gifts of future interests in property) are not included in the total amount of taxable gifts under §§ 2503 and 2523(i)(2) made during that year.

.33 Tax on Arrow Shafts . For calendar year 2007, the tax imposed under § 4161(b)(2)(A) on the first sale by the manufacturer, producer, or importer of any shaft of a type used in the manufacture of certain arrows is $0.42 per shaft.

.34 Passenger Air Transportation Ex- cise Tax . For calendar year 2007, the tax under § 4261(b) on the amount paid for each domestic segment of taxable air transportation is $3.40. For calendar year 2007, the tax under § 4261(c) on any amount paid (whether within or without the United States) for any air transportation, if the transportation begins or ends in the United States, generally is $15.10. However, for a domestic segment beginning or ending in Alaska or Hawaii as described in § 4261(c)(3), the tax applies only to departures and the rate is $7.50.

.35 Reporting Exception for Certain Exempt Organizations with Nondeductible Lobbying Expenditures . For taxable years beginning in 2007, the annual per per

son, family, or entity dues limitation to qualify for the reporting exception under § 6033(e)(3) (and section 5.05 of Rev. Proc. 98–19, 1998–1 C.B. 547), regarding certain exempt organizations with nondeductible lobbying expenditures, is $95 or less.

.36 Notice of Large Gifts Received from Foreign Persons . For taxable years beginning in 2007, recipients of gifts from certain foreign persons may be required to report these gifts under § 6039F if the aggregate value of gifts received in a taxable year exceeds $13,258.

.37 Persons Against Whom a Federal Tax Lien Is Not Valid . For calendar year 2007, a federal tax lien is not valid against (1) certain purchasers under § 6323(b)(4) who purchased personal property in a casual sale for less than $1,290, or (2) a mechanic’s lienor under § 6323(b)(7) that repaired or improved certain residential property if the contract price with the owner is not more than $6,450.

.38 Property Exempt from Levy . For calendar year 2007, the value of property exempt from levy under § 6334(a)(2) (fuel, provisions, furniture, and other household personal effects, as well as arms for personal use, livestock, and poultry) can not exceed $7,720. The value of property exempt from levy under § 6334(a)(3) (books and tools necessary for the trade, business, or profession of the taxpayer) can not exceed $3,860.

.39 Interest on a Certain Portion of the Estate Tax Payable in Installments . For an estate of a decedent dying in calendar year 2007, the dollar amount used to determine the “2-percent portion” (for purposes of calculating interest under § 6601(j)) of the estate tax extended as provided in § 6166 is $1,250,000.

.40 Attorney Fee Awards . For fees incurred in calendar year 2007, the attorney fee award limitation under § 7430(c)(1)(B)(iii) is $170 per hour.

.41 Periodic Payments Received un- der Qualified Long-Term Care Insurance Contracts or under Certain Life Insur- ance Contracts . For calendar year 2007, the stated dollar amount of the per diem limitation under § 7702B(d)(4), regarding periodic payments received under a qualified long-term care insurance contract or periodic payments received under a life

November 27, 2006 1003 2006–48 I.R.B.