Resignations of Enrolled Agents

The Director, Office of Professional Responsibility, has accepted offers of resignation as an enrolled agent from the following individuals:

Under Title 31, Code of Federal Regulations, Part 10, an enrolled agent, in order to avoid the institution or conclusion of a proceeding for his or her disbarment or suspension from practice before the In

ternal Revenue Service, may offer his or her resignation as an enrolled agent. The Director, Office of Professional Responsibility, in his discretion, may accept the offered resignation.

Name Address Date of Resignation

Schwartz, Judy Las Vegas, NV October 13, 2006

the tax treatment or tax structure of the transaction is limited in”.

LaNita Van Dyke,

Branch Chief, Publications and Regulations Branch,

Legal Processing Division,

Associate Chief Counsel (Procedure and Administration).

(Filed by the Office of the Federal Register on December 1, 2006, 8:45 a.m., and published in the issue of the Federal Register for December 4, 2006, 71 F.R. 70335)

Foundations Status of Certain Organizations

Announcement 2006–99

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.

AJCA Modifications to the Section 6111 Regulations; Correction

Announcement 2006–98

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to notice of proposed rulemaking by cross-reference to temporary regulations.

SUMMARY: This document contains a correction to notice of proposed rulemaking by cross-reference to temporary regulations (REG–103039–05, 2006–49 I.R.B. 1057) that were published in the Federal Register on Thursday, November 2, 2006 (71 FR 64496) relating to the disclosure of reportable transactions by material advisors.

FOR FURTHER INFORMATION CONTACT: Tara P. Volungis or Charles Wien, 202–622–3070 (not a toll-free number).

SUPPLEMENTAL INFORMATION:

Background

The notice of proposed rulemaking by cross-reference to temporary regulations (REG–103039–05) that is the subject of this correction is under sections 6111 and 6112 of the Internal Revenue Code.

Need for Correction

As published, the notice of proposed rulemaking by cross-reference to temporary regulations (REG–103039–05) contains an error that may prove to be misleading and is in need of clarification.

Correction of Publication

Accordingly, the notice of proposed rulemaking by cross-reference to temporary regulations (REG–103039–05) that was the subject of FR Doc. E6–18321 is corrected as follows:

§301.6111–3 [Corrected]

On page 64499, column 1, §301.6111–3(b)(2)(ii)(B), first paragraph of the column, lines 4 and 5, the language “disclosure of the tax structure or tax aspects of the transaction is limited in” is corrected to read “disclosure of

2006–51 I.R.B. 1139 December 18, 2006

LFC Recreation Center for the Aged and

Disabled Adults, Houston, TX Living Word Affordable Housing

Communities, Incorporated, Nashville, TN Local Organizing Committee, Fresno, CA Lubbock Area Children Empowerment,

Lubbock, TX Malcolm Foundation, Inc., Madison, MS Manjui Foundation, Inc., Baltimore, MD Metro Mustangs Basketball Foundation,

Dallas, TX New Foundation Church,

Philadelphia, MS Newport Housing Authority Development

Corporation, Newport, TN Northey Foundation, Morrison, CO Olen C. and Carmen Hendrix Foundation,

Prescott, AR Open Heart of Love Non Profit

Organization, Matteson, IL Order of the Dragon, Bakersfield, CA Out of Pain, Inc.,

Montgomery Village, MD Outdoors for All, Lansing, MI Patrajsha Connection, Los Angeles, CA Peniel Family Resource Center, Inc.,

Lithonia, GA People Caring for People Through

Technology PCP Group Community, Odenton, MD Percussion for Kids Association,

Seattle, WA Philant, San Diego, CA Piller Family Foundation in Memory

of Raizy Rivky and Eli Piller, Brooklyn, NY P L I E, Greensboro, NC Potter’s Center for the Homeless, Inc.,

Norwalk, CT Power Training Academy, Inc.,

Columbus, OH Presidio Films Foundation, Inc.,

Newport Beach, CA Prima Sounds Foundation, Inc.,

Winter Park, FL Providence Baptist Church Foundation,

Inc., Opelika, AL Quiet Environment Society, Inc.,

Tewksbury, MA Reaching You Resource Center, Inc.,

Thomasville, GA Restoration Dream Center, Inc.,

Mabelvale, AR Revelation Enterprise, Los Angeles, CA Rhema Sports Park and Learning Center,

Virginia Beach, VA

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:

Act of Change, Dallas, TX African Federation, Inc., Ossining, NY Alliance for Consumer Housing

and Educational Services, Inc., Stone Mountain, GA American Flyers Special Development

Sport Team, Springfield, OH American Foundation for Abused

Childrens Therapy, Raleigh, NC American Society for Education &

Training in Aviation, Las Vegas, NV Aseonyn Opportunity Center, Inc.,

Fort Lauderdale, FL Asian Community of California, Inc.,

Richmond, CA Aspirations Center Community

Development Corporation, East St. Louis, IL Bicycle for Everyones Earth USA,

Phoenix, AZ Big Horn Lenape Fed, Martinsville, OH Bless the Children, Dallas, TX Blessed to Bless Phase II, Berkley, MO Boston Institute for the Advancement of

Science, Inc., Hyde Park, MA Calligraphy Education Group,

Silver Spring, MD CCD of Texas, Inc., Richardson, TX Center for Universal Understanding, Inc.,

Charlotte, SC Charles Livingston Family Research

Association, Salt Lake City, UT Clover Housing and Redevelopment

Services, Clover, SC Collaboration of Creation, Inc.,

Sacramento, CA Colorado Business Roundtable,

Denver, CO Community Care Service,

Warner Robins, GA Community for Humanity Agency,

La Habra, CA Community Outreach Ministries, Inc.,

Safford, AZ Consciousness, Inc., Milwaukee, WI Corenet Global Community Reinvestment

Challenge, Atlanta, GA Cornerstone Counseling and Learning

Center, Inc., Bronx, NY Cultural Community Care, Inc.,

Sherman, TX

Cutting Edge of Medical Invention

Foundation, Malibu, CA David B. and Eileen M. Kinney

Memorial Childhood Foundation, Los Angeles, CA Delphi Foundation, Middleburg, VA Derrick E. Houston Ministries, Inc.,

Birmingham, AL Despite the Odds, Inc., Miami, FL Dicarlo Corporation, Newton, MA Disciples of Christ Community

Development Center, Tuscaloosa, AL D-One Education and Sports Foundation,

Inc., Greensboro, NC Edna Travis Helping Hands Foundation,

Inc., Baton Rouge, LA Foundation of Family Happiness,

Arlington, VA Friends of Fun Shop Foundation,

Springfield, IL Frontline Bible Ministries, Inc.,

Ypsilanti, MI Gathering Point, Chicago, IL Golden Years, Hattiesburg, MS Good Shephard Holy Cross Apostolate,

Inc., Elyria, OH Goodbyebills, Inc., El Paso, TX Harvest for Haiti, Oakland, CA Hep C Advocated Network, Inc.,

Longview, TX Illuminated Life Foundation, Honolulu, HI Immunogenic Research Foundation, Inc.,

Pompano Beach, FL Indiana Assisted Living Foundation, Inc.,

Indianapolis, IN International Tcm Center, Pittsburgh, PA International Word Outreach Ministries,

Inc., Chicago, IL Jeffrey Sealey, Tuscaloosa, AL Joshua & Caleb Community Development

Corporation, Baton Rouge, LA Jus Tus, Inc., Rancho Cucamonga, CA Kicking Kids, Inc., Douglasville, GA Kingdom House Therapeutic Treatment

Center, Haslet, TX Kiwanis Club of North Mason Foundation

Trust Fund, Belfair, WA Lakemor Foundation for Breast Cancer

Research, Inc., Reno, NV Lampkin-Asam Cancer Institute, Inc.,

Deltona, FL Last Day Plea Publications,

Baltimore, MD Law Street Economic Development

Corporation, New Orleans, LA Lear Charitable Foundation,

Garden Grove, CA Legacy Foundation, Shorewood, MN

December 18, 2006 1140 2006–51 I.R.B.

Rivers of Living Water Ministries, Inc.,

Monroe, NC San Juan Island Farm and Retreat Center,

Seattle, WA Second Chance a Sober Living Facility,

Tucson, AZ Sewickley Township Community

Ambulance Service, Herminie, PA Shantivanam Northern Knights Camp and

Conference Center, Inc., Glover, VT Social Venture Network,

San Francisco, CA Solid Oak Accessible Resources, Inc.,

Nacogdoches, TX Solid Rock Productions, Inc.,

Scottsdale, AZ South Florida Community Development

Corporation, Miami, FL St. Francois Society, St. Louis, MO Steps Vocational Services,

Marysville, WA Student Image & Career Consulting, Inc.,

Mableton, GA Tennessee Ministries, Madisonville, TN This-Story, Inc., Portland, OR Triumph Empowerment Center, Inc.,

Erwin, NC United States Colored Troops Institute of

Suffolk County, Amityville, NY Victory Enterprises and Ministries,

Reseda, CA Volunteer Refugee Aid International, Inc.,

Temple City, CA Well – Spring Prevention, Inc., Miami, FL Whitemarsh Continuing Care Retirement

Community, Plymouth Meeting, PA William H. McDonald Community

Outreach Center, Inc., Kansas City, KS With One Accord, Durham, NC Women Ministering Women, Inc.,

Kechi, KS

Yellow Cross AELS, Beaverton, OR Youngblood Enterprises, Inc.,

Montgomery, AL

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 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.

Appeals Closing Cases Involving Unsettled Listed Transactions

Announcement 2006–100

The Internal Revenue Service announced today that it is updating its procedures relating to cases involving a listed transaction with respect to which the Office of Appeals and the taxpayer are unable to reach a satisfactory settlement. The new procedures take effect today and are part of a continuing effort by the IRS to ensure the efficiency and integrity of tax administration, while at the same time successfully combating abusive tax avoidance transactions.

When a settlement cannot be reached by the Office of Appeals in a case that is not docketed in the Tax Court, it is ex

pected that the case will proceed to litigation. The Service wants to ensure that it has fully developed the limited number of unagreed cases that involve listed transactions (within the meaning of Treas. Reg. § 1.6011–4) before it sends a statutory notice of deficiency (or other determination notice triggering litigation rights) to the taxpayer. Consequently, the Service is revising its procedures to provide that when the Office of Appeals and the taxpayer are unable to reach a satisfactory settlement in a nondocketed case involving a listed transaction, the Office of Appeals will close out its consideration, notify the taxpayer, and send the case to the appropriate Operating Division for further handling. The process by which a taxpayer seeks consideration of the case by the Office of Appeals, and the manner in which Appeals and the taxpayer attempt to settle the case remain unchanged.

After the case is closed by the Office of Appeals, the Operating Division will determine whether the unsettled adjustments relating to the listed transaction merit further development. If not, a statutory notice of deficiency (or other appropriate notice) will be issued to the taxpayer by the Operating Division. If further case development is deemed necessary, additional development of the case will proceed and the statutory notice of deficiency (or other appropriate notice) will be issued to the taxpayer by the Operating Division after the development is completed. The decision to further develop a case is expected to rarely occur and will be made by the Commissioner of the Operating Division after consultation with the Office of Chief Counsel to ensure national consistency.

2006–51 I.R.B. 1141 December 18, 2006