Disbarments — Internal Revenue Bulletin 2007-47

Under Title 31, Code of Federal Regulations, Part 10, after notice and an oppor

tunity for a proceeding before an administrative law judge, the following individu

als have been disbarred from practice before the Internal Revenue Service:

Name Address Designation Effective Date

Ruocchio, Robert Havertown, PA CPA June 11, 2007

Turner, John S. Paradise, CA Enrolled Agent June 15, 2007

Johnson, Ted R. Frankfort, IN Attorney July 30, 2007

Ayers, Dani D. Kelseyville, CA Enrolled Agent August 6, 2007

Historic Herbert House Events Facility,

Vallejo, CA Hollywood Community Corporation, Inc.,

Fayette, MS Homeplanner Institute, Houston, TX Hope for the Hurting Ministries, Inc.,

Mesa, AZ Indiana Public Health Institute, Inc.,

Indianapolis, IN Individuals With Disabilities

Enabling Advocacy Link-IDEAL, Bedminister, NJ International Brotherhood in Recovery,

Sunrise, FL International Center for Ethics

and Workforce Readiness, Panama City Beach, FL James Thompson Community

Development, Inc., Pensacola, FL Just Alternatives, Brooklin, MA Juventud Encantador, Hillsborough, CA Kendrick Foundation, Inc.,

Mooresville, IN Kims Extended Learning Center, Inc.,

Memphis, TN Kosas, New Orleans, LA KWJWD Ministries, Moreno Valley, CA Life Care Ministries, Inc., Fort Pierce, FL Lupus Clinical Trials Consortium,

Princeton, NJ Malcolm X— Ella L. Little Collins

Family Foundation, Inc., Boston, MA Markee Pet Refuge, Salem, OR MB Comprehensive Social Services,

Compton, CA Me Too Youth Foundation, Oakland, CA Michael Jefferson Outreach Ministries,

Starkville, MS Militis Christi, Inc., Austin, TX Ministries of the Well, Albuquerque, NM

Foundations Status of Certain Organizations

Announcement 2007–108

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.

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:

A Plus Care Development, Inc.,

San Bernardino, CA ABC Ministry & Counseling Center, Inc.,

Brooklyn, NY Advantage Rutherford Foundation,

Rutherfordton, NC AFRI — Assistance for Refugees, Inc.,

Brooklyn, NY Angels of Mercy Aviation Corp., Inc.,

Warrensburg, MO Babblingbrook Family Learning Center,

Inc., East Boston, MA Bayside Lions Service, Inc., Bacliff, TX

Big Picture Social Marketing,

Overbrook, KS Big P.L.A.Y. (Planning, Life, Athletic,

Youth) League, Alta Loma, CA Brothers of One Kind Child

Development and Learning Center, Moreno Valley, CA CAFMA, Inc., St. Albans, NY Caring and Sharing for the Homeless,

Inc., Ellicott City, MD Case Management Resources, Inc.,

Ridgway, PA Center for Adaptive Policy in Ecosystems,

Mukilteo, WA Concerts by the Sea, Swampscott, MA Crosswoods Entertainment Incorporated,

Santa Monica, CA Daybreakers Foundation, Branson, MO Dimension Family Development,

Stafford, VA Discover America Foundation,

Richmond, CA Dormay Learning Institute, Incorporated,

Miami, FL Dunleith Railroad Historical Society,

East Dubuque, IL Eastside Extreme, Bothell, WA Family Institute, Inc., Lexington, KY Foundation for Learning Development,

Manhattan Beach, CA Free Energy, South Lake Tahoe, CA Friends of City University, Inc.,

Washington, DC Global Foundation for Education

Development, Inc., Arlington, VA Good Samaritan Corporation,

Burlington, NJ Great Commission International

Ministries, Cullman, AL Greenlife Enrichment, Inc., Pasadena, CA Hearts Senior Citizens, Denver, CO

2007–47 I.R.B. 1044 November 19, 2007

regarding the treatment of transactions involving obligations between members of a consolidated group and the treatment of transactions involving the provision of insurance between members of a consolidated group. The regulations will affect corporations filing consolidated returns.

FOR FURTHER INFORMATION CONTACT: Frances L. Kelly, (202) 622–7770 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The correction notice that is the subject of this document is under section 1502 of the Internal Revenue Code.

Need for Correction

As published, the notice of proposed rulemaking (REG–107592–00) and withdrawal of proposed regulations (REG–105964–98) contain errors that may prove to be misleading and are in need of clarification.

Correction of Publication

Accordingly, the publication of proposed rulemaking (REG–107592–00) and withdrawal of proposed regulations (REG–105964–98), which were the subjects of FR Doc. E7–19134, is corrected as follows:

On page 55142, column 3, in the preamble, under the paragraph heading “E. Material Tax Benefit Rule”, eleventh line of the third paragraph, the language “a material tax benefit that would not” is corrected to read “a material Federal tax benefit that would not”.
On page 55143, column 1, in the preamble, under the paragraph heading “F. Off-Market Issuance Rule”, eleventh line of the second paragraph of the column, the language “tax benefit. In such cases, the” is corrected to read “Federal tax benefit. In such cases, the”.
On page 55143, column 1, in the preamble, under the paragraph heading “G. Outbound Transactions”, eighth line of the first paragraph, the language “obligation that became intercompany” is corrected to read “obligation that became an intercompany”.
On page 55144, column 1, in the preamble, under the paragraph heading “I.

Mount Olive Community Development

Corporation, Riverside, CA Multgenerational Outreach Center, Inc.,

Missouri City, TX MVP Outreach, Inc., Greenville, SC National Council on Paint Disposition,

Inc., East Brunswick, NJ National Organization of Pacific Islanders

in America, Waldorf, MD No-Charge Cards, Nassau, NY North American Foundation for Keele

University, Inc., New York, NY North Carolina Cotton Foundation, Inc.,

Nashville, NC Olive Branch Animal Rescue & Refuge,

Inc., Sistersville, WV Omni Educational & Cultural Foundation,

St. Charles, MO One Village, Inc., Lilburn, GA Paragon Payee Services, Inc.,

Vancouver, WA Pardada Pardadi Educational Society,

Inc., Fairfax, VA Payton Memorial Education Foundation,

Inc., Hialeah, FL PEAK Institute, Inc., Adrian, MI Pentacle Educational, Inc., Hazel Crest, IL Premier Youth Opportunity Center,

West Covina, CA Progressive Development Corporation,

Gloucester, MA Project Outreach - Early Breast Care

Education Screening & Advocacy, Inc., Oklahoma City, OK Rainbow Wellness Center, Galloway, NJ Red Hill Community Unit 10 Academic

Foundation, Bridgeport, IL Restoring Hope, Inc., New Orleans, LA Richard A. Coz SJ Foundation, Ltd.,

Redwood City, CA Rohnert Park Boards and Blades

Corporation, Rohnert Park, CA Rosa Parks School Collaborative,

Berkley, CA Scott Anderson Ministries, Inc.,

Kalamazoo, MI Shalom Oasis Ministries, Inc.,

Raleigh, NC Societa Dante Alighier, Inc.,

Isle of Palms, SC Spelling Bee Competition, Inc.,

Chicago, IL Ssanyu Youth Aid International,

Farmington Hills, MI Tedrow Home Educators Network,

Wauseon, OH They Are Helping People, New Caney, TX

Towpath Lodge Association, Inc.,

Brockport, NY Universal Haitian Development & Relief

Fund, Inc., Bridgeport, GA Vision and Leadership Community

Foundation, Frisco, TX Vision Communities, Inc.,

Indianapolis, IN Water Walker Ministries Incorporated,

Fayetteville, GA Wes Becker Public School Survival Fund,

Inc., Eugene, OR We Will Stand, Burbonnais, IL Work-Scholarship Connection, Inc.,

Oxford, NC Zoe Music Ministries, Inc.,

Coral Springs, FL

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.

Consolidated Returns; Intercompany Obligations; Correction

Announcement 2007–109

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to notice of proposed rulemaking and withdrawal of proposed regulations.

SUMMARY: This document contains corrections to a notice of proposed rulemaking (REG–107592–00, 2007–44 I.R.B. 908) and withdrawal of proposed regulations (REG–105964–98, 2007–44 I.R.B. 908) that were published in the Fed- eral Register on Friday, September 28, 2007 (72 FR 55139) providing guidance

November 19, 2007 1045 2007–47 I.R.B.

On page 55151, column 2, § 1.1502–13(g)(7)(ii) Example 9 .(i), third through fourth lines of the paragraph, the language “material loss from a separate return limitation year (SRLY). T’s sole shareholder,” is corrected to read “material SRLY loss. T’s sole shareholder,”.
On page 55151, column 3, § 1.1502–13(g)(7)(ii) Example 10 .(iii), ninth line of the paragraph, the language “principal amount, and a fair market value of” is corrected to read “principal amount, and fair market value of”.

LaNita Van Dyke, Chief, Publications and

Regulations Branch, Legal Processing Division,

Associate Chief Counsel (Procedure and Administration).

(Filed by the Office of the Federal Register on October 30, 2007, 8:45 a.m., and published in the issue of the Federal Register for October 31, 2007, 72 F.R. 61582)

Other Request for Comments”, eleventh line of the first full paragraph of the column, the language “and basis (such as the issuance of note” is corrected to read “and basis (such as the issuance of a note”.

§ 1.1502–13 [Corrected]

On page 55146, column 2, § 1.1502–13(g)(2)(v), second line of the paragraph, the language “of a material net reduction in income or” is corrected to read “of, for Federal tax purposes, a material net reduction in income or”.
On page 55146, column 3, § 1.1502–13(g)(3)(i)(B), last line of the paragraph, the language “or ( 6 ) of this section apply.” is corrected to read “or ( 6 ) of this section apply. The exceptions are as follows.”.
On page 55147, column 3, § 1.1502–13(g)(4)(iii), last line of the paragraph, the language “market interest rates.” is corrected to read “market interest rates).”.
On page 55149, column 2, § 1.1502–13(g)(7)(ii) Example 2 .(vi), sixth line of the paragraph, the language “as selling all of its assets to X, including the” is corrected to read “as selling all of its assets to new S, including the”.
On page 55149, column 2, § 1.1502–13(g)(7)(ii) Example 2 .(vi), seventeenth line of the paragraph, the language “to X for $70, the amount realized with” is corrected to read “to new S for $70, the amount realized with”.
On page 55150, column 3, § 1.1502–13(g)(7)(ii) Example 6 .(i), sixth line of the paragraph, the language “repayment of $100 at the end of year 5. The” is corrected to read “repayment of $100 at the end of year 20. The”.
On page 55151, column 1, § 1.1502–13(g)(7)(ii) Example 8 .(i), third line of the paragraph, the language “from a separate return limitation year (SRLY).” is corrected to read “from a separate return limitation year that is subject to limitation under § 1.1502–21(c) (a SRLY loss).”.

2007–47 I.R.B. 1046 November 19, 2007