Internal Revenue Bulletin 1996-45 (PDF rendition): IRS Announcements

Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.

INCOME TAX
Rev. Rul. 96–41, page 4.
Educational assistance after termination of employ-
ment.Educational assistance plans that provide ben-
efits to participants by reason of their employment with
the employer will not fail to qualify as educational
assistance programs described in section 127(b) of the
Code merely because eligible participants include former
employees.
Rev. Rul. 96–52, page 5.
Federal rates; adjusted federal rates; adjusted fed-
eral long-term rate, and the long-term exempt rate.
For purposes of sections 1274, 1288, 382, and other
sections of the Code, tables set forth the rates for
November 1996.
EMPLOYEE PLANS
Announcement 96–112, page 7.
The initial notice and election period for a savings
incentive match plan for employees of small employers
described in section 408(p) of the Code as added by the
Small Business Job Protection Act of 1996, P.L. 104–
188, is being extended.
EXEMPT ORGANIZATIONS
Announcement 96–114, page 7.
A list is given of organizations now classified as private
foundations.
ADMINISTRATIVE
Announcement 96–115, page 9.
Proposed regulations FI–59–94, 1996–30 I.R.B. 23,
relating to the allowance of a deduction for a partially
worthless debt when the terms of a debt instrument
have been modified, is corrected.
Finding Lists begin on page 13.
Announcements of Disbarments and Suspensions begin on page 10.
Monthly Index for October is on page 15.
Bulletin No. 1996–45
November 4, 1996
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be relied
upon as authoritative interpretations.

Mission of the Service
The purpose of the Internal Revenue Service is to
collect the proper amount of tax revenue at the least
cost; serve the public by continually improving the
quality of our products and services; and perform in a
manner warranting the highest degree of public
confidence in our integrity, efficiency and fairness.
Statement of Principles
of Internal Revenue
Tax Administration
The function of the Internal Revenue Service is to
administer the Internal Revenue Code. Tax policy
for raising revenue is determined by Congress.
With this in mind, it is the duty of the Service to
carry out that policy by correctly applying the laws
enacted by Congress; to determine the reasonable
meaning of various Code provisions in light of the
Congressional purpose in enacting them; and to
perform this work in a fair and impartial manner,
with neither a government nor a taxpayer point of view.
At the heart of administration is interpretation of the
Code. It is the responsibility of each person in the
Service, charged with the duty of interpreting the
law, to try to find the true meaning of the statutory
provision and not to adopt a strained construction in
the belief that he or she is ‘‘protecting the revenue.’’
The revenue is properly protected only when we as-
certain and apply the true meaning of the statute.
The Service also has the responsibility of applying
and administering the law in a reasonable,
practical manner. Issues should only be raised by
examining officers when they have merit, never
arbitrarily or for trading purposes. At the same
time, the examining officer should never hesitate
to raise a meritorious issue. It is also important
that care be exercised not to raise an issue or to
ask a court to adopt a position inconsistent with
an established Service position.
Administration should be both reasonable and
vigorous. It should be conducted with as little
delay as possible and with great courtesy and
considerateness. It should never try to overreach,
and should be reasonable within the bounds of law
and sound administration. It should, however, be
vigorous in requiring compliance with law and it
should be relentless in its attack on unreal tax
devices and fraud.
2

Introduction
The Internal Revenue Bulletin is the authoritative instru-
ment of the Commissioner of Internal Revenue for
announcing official rulings and procedures of the Inter-
nal Revenue Service and for publishing Treasury Deci-
sions, Executive Orders, Tax Conventions, legislation,
court decisions, and other items of general interest. It is
published weekly and may be obtained from the Superin-
tendent of Documents on a subscription basis. Bulletin
contents of a permanent nature are consolidated semi-
annually into Cumulative Bulletins, which are sold on a
single-copy basis.
It is the policy of the Service to publish in the Bulletin all
substantive rulings necessary to promote a uniform
application of the tax laws, including all rulings that
supersede, revoke, modify, or amend any of those
previously published in the Bulletin. All published rulings
apply retroactively unless otherwise indicated. Proce-
dures relating solely to matters of internal management
are not published; however, statements of internal
practices and procedures that affect the rights and
duties of taxpayers are published.
Revenue rulings represent the conclusions of the Ser-
vice on the application of the law to the pivotal facts
stated in the revenue ruling. In those based on positions
taken in rulings to taxpayers or technical advice to
Service field offices, identifying details and information
of a confidential nature are deleted to prevent unwar-
ranted invasions of privacy and to comply with statutory
requirements.
Rulings and procedures reported in the Bulletin do not
have the force and effect of Treasury Department
Regulations, but they may be used as precedents.
Unpublished rulings will not be relied on, used, or cited
as precedents by Service personnel in the disposition of
other cases. In applying published rulings and proce-
dures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be consid-
ered, and Service personnel and others concerned are
cautioned against reaching the same conclusions in
other cases unless the facts and circumstances are
substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on
provisions of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows:
Subpart A, Tax Conventions, and Subpart B, Legislation
and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to
these subjects are contained in the other Parts and
Subparts. Also included in this part are Bank Secrecy
Act Administrative Rulings. Bank Secrecy Act Administra-
tive Rulings are issued by the Department of the
Treasury’s Office of the Assistant Secretary (Enforce-
ment).
Part IV.—Items of General Interest.
With the exception of the Notice of Proposed Rulemak-
ing and the disbarment and suspension list included in
this part, none of these announcements are consoli-
dated in the Cumulative Bulletins.
The first Bulletin for each month includes an index for
the matters published during the preceding month.
These monthly indexes are cumulated on a quarterly and
semiannual basis, and are published in the first Bulletin
of the succeeding quarterly and semi-annual period,
respectively.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
For sale by the Superintendent of Documents U.S. Government Printing Office, Washington, D.C. 20402.
3

Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
Section 42.—Low-Income Housing
Credit
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the
month of November 1996. See Rev. Rul. 96–52,
page 5.
Section 127.— Educational
Assistance Programs
26 CFR 1.127–2: Educational Assistance Pro-
grams.
Educational assistance after termi-
nation of employment.Educational as-
sistance plans that provide benefits to
participants by reason of their employ-
ment with the employer will not fail to
qualify as educational assistance pro-
grams described in section 127(b) of the
Code merely because eligible partici-
pants include former employees.
Rev. Rul. 96–41
ISSUE
Does a plan fail to qualify as an
educational assistance program de-
scribed in section 127(b) of the Internal
Revenue Code if the plan provides ben-
efits to individuals after their employ-
ment has terminated, regardless of the
reason for termination?
FACTS
Situation (1).Employer X maintains a
plan that is intended to be a qualified
educational assistance program. The
plan provides educational assistance to
participants to help them obtain educa-
tion and training. Under the plan, X
pays expenses incurred by or on behalf
of plan participants for instruction and
training (including instruction that is
part of a degree program as well as
vocational and technical training) that
constitutes ‘‘education’’ as that term is
used in section 127 and the regulations
thereunder. Employees who qualify as
participants earn educational benefits for
hours of service according to a schedule
of benefits. The participants are current
and former employees of X, and a
participant may take courses of instruc-
tion either during employment or after
termination of employment with X. The
former employees who are participants
include individuals who terminated their
employment voluntarily (including by
retirement), were laid off, were termi-
nated involuntarily, or terminated be-
cause of disability.
Situation (2).In connection with its
corporate ‘‘downsizing’’ efforts, em-
ployer Y adopts a plan that is intended
to be a qualified educational assistance
program. The plan provides educational
assistance to participants to help them
obtain education and training. The par-
ticipants are former employees of Y
whose employment with Y has termi-
nated in connection with a cutback in
operations affecting a broad range of
personnel. Under the plan, Y pays ex-
penses incurred by or on behalf of plan
participants after termination of employ-
ment for instruction and training (in-
cluding instruction that is part of a
degree program as well as vocational
and technical training) that constitutes
‘‘education’’ as that term is used in
section 127 and the regulations thereun-
der.
LAW AND ANALYSIS
Section 127(a) provides that gross
income of an employee does not include
amounts paid or expenses incurred by
the employer for educational assistance
to the employee if the assistance is
furnished pursuant to a program de-
scribed in § 127(b). Section 127(b)(1)
provides that, for purposes of § 127, an
educational assistance program is a
separate written plan of an employer for
the exclusive benefit of his employees
to provide such employees with educa-
tional assistance, and that the program
must meet the other requirements set
forth in § 127(b).
A qualified educational assistance
program is permitted to provide benefits
only to employees, and not to spouses
or dependents of employees. Section
1.127–2(d) of the Income Tax Regula-
tions provides that a qualified educa-
tional assistance program is only permit-
ted to benefit employees of the
employer, including, at the employer’s
option, individuals who are employees
within the meaning of section 1.127–
2(h)(1) of the regulations. Under section
1.127–2(h)(1)(i) of the regulations, the
term ‘‘employee’’ includes a retired, dis-
abled or laid-off employee.
HOLDING
In bothSituations (1)and(2), the
plans provide benefits to participants by
reason of their employment with the
employer and, accordingly, will not fail
to qualify as educational assistance pro-
grams described in section 127(b) merely
because eligible participants include
former employees, regardless of the rea-
son for termination of employment.
FURTHER INFORMATION
For further information regarding this
Revenue Ruling contact Monice
Rosenbaum of the Office of the Associ-
ate Chief Counsel (Employee Benefits
and Exempt Organizations) at (202)
622–6070 (not a toll-free call).
Section 280G.—Golden Parachute
Payments
Federal short-term, mid-term, and long-term
rates are set forth for the month of November
1996. See Rev. Rul. 96–52, page 5.
Section 382.—Limitation on Net
Operating Loss Carryforwards and
Certain Built-In Losses Following
Ownership Change
The adjusted federal long-term rate is set forth
for the month of November 1996. See Rev. Rul.
96–52, page 5.
Section 412.—Minimum Funding
Standards
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the
month of November 1996. See Rev. Rul. 96–52,
page 5.
Section 467.—Certain Payments
for the Use of Property or Services
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the
month of November 1996. See Rev. Rul. 96–52,
page 5.
Section 468.—Special Rules for
Mining and Solid Waste
Reclamation and Closing Costs
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the
month of November 1996. See Rev. Rul. 96–52,
page 5.
Section 483.—Interest on Certain
Deferred Payments
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the
month of November 1996. See Rev. Rul. 96–52,
page 5.
Section 807.—Rules for Certain
Reserves
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the
month of November 1996. See Rev. Rul. 96–52,
page 5.
4

Section 846.—Discounted Unpaid
Losses Defined
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the
month of November 1996. See Rev. Rul. 96–52,
this page.
Section 1274.—Determination of
Issue Price in the Case of Certain
Debt Instruments Issued for
Property
(Also sections 42, 280G, 382, 412, 467, 468, 482,
483, 807, 846, 1288, 7520, 7872.)
Federal rates; adjusted federal
rates; adjusted federal long-term rate,
and the long-term exempt rate.For
purposes of sections 1274, 1288, 382,
and other sections of the Code, tables
set forth the rates for November 1996.
Rev. Rul. 96–52
This revenue ruling provides various
prescribed rates for federal income tax
purposes for November 1996 (the cur-
rent month.) Table 1 contains the short-
term, mid-term, and long-term appli-
cable federal rates (AFR) for the current
month for purposes of section 1274(d)
of the Internal Revenue Code. Table 2
contains the short-term, mid-term, and
long-term adjusted applicable federal
rates (adjusted AFR) for the current
month for purposes of section 1288(b).
Table 3 sets forth the adjusted federal
long-term rate and the long-term tax-
exempt rate described in section 382(f).
Table 4 contains the appropriate percent-
ages for determining the low-income
housing credit described in section
42(b)(2) for buildings placed in service
during the current month. Finally, Table
5 contains the federal rate for determin-
ing the present value of an annuity, an
interest for life or for a term of years, or
a remainder or a reversionary interest
for purposes of section 7520.
REV. RUL. 96–52 TABLE 1
Applicable Federal Rates (AFR) for November 1996
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-Term
AFR5.96%5.87%5.83%5.80%
110% AFR6.56%6.46%6.41%6.37%
120% AFR7.16%7.04%6.98%6.94%
130% AFR7.78%7.63%7.56%7.51%
Mid-Term
AFR6.60%6.49%6.44%6.40%
110% AFR7.27%7.14%7.08%7.04%
120% AFR7.94%7.79%7.72%7.67%
130% AFR8.62%8.44%8.35%8.30%
150% AFR9.98%9.74%9.62%9.55%
175% AFR11.68%11.36%11.20%11.10%
Long-Term
AFR7.02%6.90%6.84%6.80%
110% AFR7.73%7.59%7.52%7.47%
120% AFR8.45%8.28%8.20%8.14%
130% AFR9.17%8.97%8.87%8.81%
REV. RUL. 96–52 TABLE 2
Adjusted AFR for November 1996
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
adjusted AFR3.95%3.91%3.89%3.88%
Mid-term
adjusted AFR4.73%4.68%4.65%4.64%
Long-term
adjusted AFR5.60%5.52%5.48%5.46%
5

REV. RUL. 96–52 TABLE 3
Rates Under Section 382 for November 1996
Adjusted federal long-term rate for the current month5.60%
Long-term tax-exempt rate for ownership changes during the current month (the highest of
the adjusted federal long-term rates for the current month and the prior two months.)5.64%
REV. RUL. 96–52 TABLE 4
Appropriate Percentages Under Section 42(b)(2) for November 1996
Appropriate percentage for the 70% present value low-income housing credit8.60%
Appropriate percentage for the 30% present value low-income housing credit3.69%
REV. RUL. 96–52 TABLE 5
Rate Under Section 7520 for November 1996
Applicable federal rate for determining the present value of an annuity, an interest for life or
a term of years, or a remainder or reversionary interest8.0%
Section 1288.—Treatment of
Original Issue Discount on
Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the
month of November 1996. See Rev. Rul. 96–52,
page 5.
Section 7520.—Valuation Tables
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the
month of November 1996. See Rev. Rul. 96–52,
page 5.
Section 7872.—Treatment of Loans
With Below-Market Interest Rates
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the
month of November 1996. See Rev. Rul. 96–52,
page 5.
6

Part IV. Items of General Interest
Transition Relief for SIMPLES
Announcement 96–112
PURPOSE
Section 1421 of the Small Business
Job Protection Act of 1996 (P.L. 104–
188), signed into law on August 20,
1996, established a simplified tax-
favored retirement plan for small em-
ployers (the ‘‘SIMPLE plan’’) under
section 408(p) of the Internal Revenue
Code. The purpose of this announce-
ment is to provide transition relief from
the 60-day election period and related
notice requirements in the case of
SIMPLE plans that begin January 1,
1997.
Under this transition relief, for a
SIMPLE plan that allows employees to
begin salary reduction contributions on
January 1, 1997, the employees’ salary
reduction election period may begin as
late as January 1, 1997. During this 60-
day election period, employees must be
permitted to prospectively make or
modify any salary reduction election.
BACKGROUND
SIMPLE plans can be established for
calendar years beginning after 1996.
Generally, SIMPLE plans can be estab-
lished by any employer that, for the
prior year, had no more than 100 em-
ployees who received at least $5,000 in
compensation from the employer.
Under section 408(p), contributions to
a SIMPLE plan are made to individual
retirement accounts or annuities
(SIMPLE IRAs) that are established
under the SIMPLE plan adopted by the
employer. The Code provides that, if an
employer adopts a SIMPLE plan, all of
the employer’s eligible employees must
be given the opportunity to make salary
reduction contributions to their SIMPLE
IRAs (up to a maximum of $6,000 for
1997). The adopting employer is re-
quired to match 100 percent of employ-
ees’ salary reduction contributions up to
three percent of compensation. Alterna-
tively, an employer may contribute two
percent of compensation for all eligible
employees or, for up to two out of five
years, match a lower percentage (but not
less than one percent of compensation.)
Section 408(p)(5)(C) provides that,
for each calendar year, each eligible
employee may elect, during the 60-day
period before the beginning of the cal-
endar year (and the 60-day period be-
fore the first day the employee is eli-
gible to participate), to participate in the
qualified salary reduction arrangement
under the SIMPLE plan maintained by
the employer, or to modify the amounts
subject to the arrangement. The statute
requires that the employer notify each
eligible employee immediately before
the election period of the employee’s
opportunity to make salary reduction
contributions and provide certain other
information.
TRANSITION RELIEF FOR PLANS
THAT BEGIN JANUARY 1, 1997
The 60-day period during which eli-
gible employees may elect to make
salary reduction contributions under a
SIMPLE plan, or to modify prior elec-
tions, will not be required (but will be
permitted) to begin before January 1,
1997. For plans that begin January 1,
1997, the 60-day election period require-
ment can be satisfied by providing an
election period, of at least 60 days, that
includes either the date the employee
becomes eligible to make salary reduc-
tion contributions or the day immedi-
ately before that date. Thus, in the case
of a SIMPLE plan under which eligible
employees may begin making salary
reduction contributions on January 1,
1997, employees who are eligible em-
ployees as of that date must have an
election period of at least 60 continuous
days that begins between November 2,
1996, and January 1, 1997. This min-
imum 60-day election period could
be November 2 through December 31,
1996; January 1 through March 2, 1997;
or any continuous period of at least 60
days beginning between November 2,
1996, and January 1, 1997.
The election period cannot begin until
notice is provided to all eligible employ-
ees of their opportunity to make salary
reduction contributions, including the
summary description required by the
statute. An employer may permit an
eligible employee to begin making sal-
ary reduction contributions less than 60
days after receiving notice of the oppor-
tunity to make these contributions, but
in no event before January 1, 1997. The
employee must be given the opportunity
to prospectively modify the election dur-
ing the remainder of the 60-day election
period.
PLANS THAT BEGIN AFTER
JANUARY 1, 1997
This announcement does not address
the treatment of SIMPLE plans estab-
lished for 1997 that are first effective
after January 1, 1997. Further guidance
will be provided regarding those plans.
Foundations Status of Certain
Organizations
Announcement 96–114
The following organizations have
failed to establish or have been unable
to maintain their status as public chari-
ties or as operating foundations. Accord-
ingly, 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 doesnotindicate that
the organizations have lost their status
as organizations described in section
501(c)(3), eligible to receive deductible
contributions.
Former Public Charities. The follow-
ing 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:
Action Foundation Inc., Washington, DC
Adopt Hunger of Utah, Inc., Salt Lake
City, UT
Affirmations III, Inc., Houston, TX
AJO Ambulance, Inc., Ajo, AZ
Altus Public School Foundation, Inc.,
Altus, OK
American Men’s Studies Association
Inc., Northampton, MA
Arizona Council for Sustainable
Development, Tempe, AZ
Association for Community Theatre
Excellence, Inc., Bourne, MA
Astronomical Institute for Research and
Education, Madill, OK
ASU Cycling Devils, Tempe, AZ
Austin Area Youth, Austin, TX
Austin Sickle Cell Anemia Association,
Inc., Austin, TX
Bay Area Veterans and Associates,
LaPorte, TX
Big Bend, Inc., Riverton, WY
Boulder Chorale, Boulder, CO
British American Youth Festival Theatre,
New York, NY
Brother Phi Brother, Inc., Fort Worth,
TX
71996–45 I.R.B.

Buckingham Square Optimist Fund,
Inc., Aurora, CO
Business and Professional Womens
Heritage Association, Merrimack, NH
Cancer Treatment Research Foundation,
Inc., Arlington Heights, IL
Career Development Incorporated,
Holbrook, AZ
Casa Grande Regional Retirement
Community, Casa Grande, AZ
Celebration of Freedom, Inc., Boston,
MA
Center for Indigenous Studies in the
Americas, Phoenix, AZ
Central Arizona Chapter of the A. Philip
Randolph Institute, Phoenix, AZ
Childrens Connection, Inc., Chester, NH
Christfest Productions, Inc., Austin, TX
Cibola County Community Systems,
Grants, NM
Cigarroa High-Crime Stoppers, Laredo,
TX
City Art, Salt Lake City, UT
Clear Creek Project Graduation, Inc.,
League City, TX
Clinton County Council on Alcoholism
Inc., Plattsburgh, NY
Colorado Animal Refuge, Inc., Simla,
CO
Colorado Drug Education Services,
Aurora, CO
Colorado Springs Volleyball Club,
Colorado Springs, CO
Cross Timbers Crisis Center,
Stephenville, TX
Daily Planet Option Store, Inc.,
Colorado Springs, CO
Dallas Womens Coalition, Dallas, TX
Dear Valley High School Band and Flag
Boosters, Inc., Glendale, AZ
Designated Driver Program, Inc., Austin,
TX
Eagle Aquatic Team, Salt Lake City, UT
Edisto Wildlife Sanctuary Fund Edisto
Natural History Museum Inc., Tyrone,
GA
Family Outreach Central, Inc., Houston,
TX
Forth Worth Foreign Film Festival,
Forth Worth, TX
Foundation of Hope, Corpus Christi, TX
Friends of Horn Foundation, Bellaire,
TX
Friends of Martha’s Vineyard Scouting,
Inc., Oak Bluffs, MA
Friends of the Utah Avalanche Forecast
Center, Inc., Holladay, UT
Glendale Kachina Rotary Foundation,
Inc., Glendale, AZ
Global Survival Inc., Riverdale, NY
Greater Houston Nutritional & Support
Service, Houston, TX
Hamshire-Fannett Education Foundation,
Hamshire, TX
Harrington Elementary School PTO,
Plano, TX
Hood-Erath County Foster Parents
Association, Stephenville, TX
Houston Steel Light Orchestra, Houston,
TX
Human Enrichment and Learning
Project, Houston, TX
Hutchinson High School Booster Club,
Inc., Hutchinson, KS
Indian Health Care Clinic, Inc., Salt
Lake City, UT
International Leadership Group, Inc.,
Salt Lake City, UT
Join the Move, Austin, TX
Jones Township Historical Society Inc.,
Wilcox, PA
K.A.C.U., Inc. K.A.C.U.-FM, Abilene,
TX
Kerrville South Volunteer Fire Dept,
Inc., Kerrville, TX
Kids Place, Salt Lake City, UT
Leadership Fort Worth, Forth Worth, TX
Leadership Forum of North Carolina,
Wilmington, NC
Learning Disabilities Association of
Norman, Norman, OK
Manassa Maulers, Inc., Manassa, CO
Mariposa Arts Foundation, Inc., Corpus
Christi, TX
Millennium 2000 Foundation LTD,
Littleton, CO
Millner Elderly Housing, Inc., Atlanta,
GA
Millner Ridge Inc., Atlanta, GA
New Beginning Nutrition Food
Program, Humble, TX
New Mountain Volunteer Fire Dept.
Inc., Ore City, TX
New Southwest Orchestra, Albuquerque,
NM
Northern New Mexico Volleyball
Association, Los Alamos, NM
Northwood Booster Club, Cedar Hill,
TX
Oklahoma Homeless Network, Inc.,
Oklahoma City, OK
Orange Pathways Incorporated, Goshen,
NY
Parents and Educators Achieving
Community Excellence, Mission, TX
Petroglyphs Por Los Ninos Coalition,
Santa Fe, NM
Pharr Chamber of Commerce, Pharr, TX
Piper Denver Outreach, Inc., Denver,
CO
Point of Light, Sinton, TX
RHS, Inc., Albuquerque, NM
Rock Springs Youth Boys Basketball,
Rock Springs, WY
Sail Connecticut Access Program Inc.,
Branford, CT
Sal De Ahi, Santa Fe, NM
Salt Lake Mens Choir A Non-Profit
Utah Corporation DTD, Salt Lake
City, UT
Say Yes San Antonio With Luis Palau,
Inc., San Antonio, TX
Scotcrest, Inc., Houston, TX
S.D.N.C., Cheyenne, WY
Secaucus Lions Charities Inc., Cedar
Grove, NJ
Sedona Repertory Theater An Arizona
Non-Profit Corporation, Sedona, AZ
Serenty Center for Girls, Inc., Marlin,
TX
Shawnee Mission North Band Parents
Club, Shawnee Mission, KS
Southeast Nutritious Food Program,
Houston, TX
South Texas Counsel on Alcohol and
Drug Abuse, Inc., Laredo, TX
South Valley Fire & Rescue Auxiliary,
Albuquerque, NM
Swedish-American Research Foundation
for Diet & Disease Inc., Morris
Plains, NJ
Take Pride in Arizona, Inc., Phoenix,
AZ
Task Force for Housing, Lock Haven,
PA
Temple Bar Foundation, Washington,
DC
Texas Bankers Foundation, Austin, TX
T.F.O.C. Incorporated, Conroe, TX
Third Eternal Baptist Community
Outreach, Philadelphia, PA
Thomas McNaughton Foundation for
Liver Transplants Inc., Baltimore, MD
Tri-State Conference Education Fund,
Pittsburgh, PA
Troika Productions, Washington, DC
Ulster Choral Society, Kingston, NY
United Fire Fighters Task of Prince
Georges County Maryland Inc.,
Capitol Heights, MD
Urban Center for Change Housing
Development Fund Corporation,
Brooklyn, NY
Utah Coalition of La Raza, Salt Lake
City, UT
VDT Housing Development Fund
Company, Inc., New York, NY
Veterans Support Services, Inc.,
Portland, ME
Wheat Ridge Coalition, Wheat Ridge,
CO
Whole Brain Connection, Dallas, TX
Will Rogers PTO, Houston, TX
Williams Technology Initiative
Committee, Inc., Austin, TX
Winters A.C.E.S. Inc., Winters, TX
Word of Faith Outreach Food Program,
Channelview, TX
Work Work Opportunities of a
Rehabilitative Kind, Austin, TX
81996–45 I.R.B.

Young Israel Soup Kitchen Incorporated,
New Haven, CT
Youth Sports Systems, Inc.,
Albuquerque, NM
If an organization listed above sub-
mits information that warrants the re-
newal of its classification as a public
charity or as a private operating founda-
tion, the Internal Revenue Service will
issue a ruling or determination letter
with the revised classification as to
foundation status. Grantors and contribu-
tors may thereafter rely upon such rul-
ing 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 classi-
fication of foundation status in the Inter-
nal Revenue Bulletin.
Modifications of Bad Debts and
Dealer Assignments of Notional
Principal Contracts; Correction
Announcement 96–115
AGENCY: Internal Revenue Service,
Treasury.
ACTION: Correction to the notice of
proposed rulemaking by cross-reference
to temporary regulations.
SUMMARY: This document contains a
correction to the notice of proposed
rulemaking by cross-reference to tempo-
rary regulations (FI–59–94 [1996–30
I.R.B. 23]) which was published in the
Federal Registeron Tuesday, June 25,
1996 (61 FR 32728). The notice of
proposed rulemaking by cross-reference
to temporary regulations relates to the
allowance of a deduction for a partially
worthless debt when the terms of a debt
instrument have been modified.
FOR FURTHER INFORMATION
CONTACT: Craig R. Wojay, (202) 622–
3920 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The notice of proposed rulemaking by
cross-reference to temporary regulations
that is subject to this correction is under
sections 166 and 1001 of the Internal
Revenue Code.
Need for Correction
As published, the notice of proposed
rulemaking by cross-reference to tempo-
rary regulations (FI–59–94) contains an
error which may prove to be misleading
and is in need of clarification.
Correction of Publication
Accordingly, the publication of the
notice of proposed rulemaking by cross-
reference to temporary regulations (FI–
59–94) which is the subject of FR Doc.
96–15831 is corrected as follows:
On page 32728, column 2, in the
heading, the RIN‘‘RIN 1545–AT08’’is
corrected to read‘‘RIN 1545–AU06’’.
Cynthia E. Grigsby,
Chief, Regulations Unit,
Assistant Chief Counsel (Corporate).
(Filed by the Office of the Federal Register on
October 11, 1996, 8:45 a.m., and published in the
issue of the Federal Register for October 15, 1996,
61 F.R. 53688)
91996–45 I.R.B.

Announcement of the Disbarment, Suspension, or Consent to Voluntary
Suspension of Attorneys, Certified Public Accountants, Enrolled Agents, and
Enrolled Actuaries From Practice Before the Internal Revenue Service
Under 31 Code of Federal Regula-
tions, Part 10, an attorney, certified pub-
lic accountant, enrolled agent, or en-
rolled actuary, in order to avoid the
institution or conclusion of a proceeding
for his disbarment or suspension from
practice before the Internal Revenue Ser-
vice, may offer his consent to suspension
from such practice. The Director of
Practice, in his discretion, may suspend
an attorney, certified public accountant,
enrolled agent, or enrolled actuary in
accordance with the consent offered.
Attorneys, certified public accoun-
tants, enrolled agents, and enrolled actu-
aries are prohibited in any Internal Rev-
enue Service matter from directly or
indirectly employing, accepting assis-
tance from, being employed by or shar-
ing fees with, any practitioner disbarred
or suspended from practice before the
Internal Revenue Service.
To enable attorneys, certified public
accountants, enrolled agents, and en-
rolled actuaries to identify practitioners
under consent suspension from practice
before the Internal Revenue Service, the
Director of Practice will announce in the
Internal Revenue Bulletin the names and
addresses of practitioners who have
been suspended from such practice, their
designation as attorney, certified public
accountant, enrolled agent, or enrolled
actuary, and date or period of suspen-
sion. This announcement will appear in
the weekly Bulletin at the earliest practi-
cable date after such action and will
continue to appear in the weekly Bulle-
tins for five successive weeks or for as
many weeks as is practicable for each
attorney, certified public accountant, en-
rolled agent, or enrolled actuary so
suspended and will be consolidated and
published in the Cumulative Bulletin.
The following individuals have been
placed under consent suspension from
practice before the Internal Revenue
Service:
NameAddressDesignationDate of Suspension
Lamb, Gordon W.Pullman, WACPASeptember 1, 1996 to January 31, 1997
Anderson, Randall S.Arlington Hgts, ILCPASeptember 1, 1996 to February 28, 1998
Broderick, William J.Farmington Hills, MICPASeptember 1, 1996 to November 30, 1996
Ruggiero, John M.Rutland, VTAttorneySeptember 1, 1996 to October 31, 1996
Eklund, MarkPortland, ORCPASeptember 1, 1996 to February 28, 1997
Stayner, G. CraigSalt Lake City, UTCPASeptember 15, 1996 to June 14, 1997
Allen, Lehman D.Lubbock, TXCPASeptember 20, 1996 to September 19, 1998
Hardgrove, David L.Amarillo, TXCPASeptember 21, 1996 to June 20, 1997
Trader, John H.Kansas City, MOAttorneySeptember 30, 1996 to March 29, 1997
Schmertz, Carl D.Wilmette, ILCPAOctober 1, 1996 to March 31, 1999
Bengston, WesselChicago, ILCPAOctober 15, 1996 to April 14, 1997
10

Announcement of the Expedited Suspension of Attorneys, Certified Public
Accountants, Enrolled Agents, and Enrolled Actuaries From Practice Before The
Internal Revenue Service
Under title 31 of the Code of Federal
Regulations, section 10.76, the Director
of Practice is authorized to immediately
suspend from practice before the Internal
Revenue Service any practitioner who,
within five years, from the date the
expedited proceeding is instituted, (1)
has had a license to practice as an
attorney, certified public accountant, or
actuary suspended or revoked for cause;
or (2) has been convicted of any crime
under title 26 of the United States Code
or, of a felony under title 18 of the
United States Code involving dishonesty
or breach of trust.
Attorneys, certified public accoun-
tants, enrolled agents, and enrolled actu-
aries are prohibited in any Internal Rev-
enue Service matter from directly or
indirectly employing, accepting assis-
tance from, being employed by, or shar-
ing fees with, any practitioner disbarred
or suspended from practice before the
Internal Revenue Service.
To enable attorneys, certified public
accountants, enrolled agents, and en-
rolled actuaries to identify practitioners
under expedited suspension from prac-
tice before the Internal Revenue Service,
the Director of Practice will announce in
the Internal Revenue Bulletin the names
and addresses of practitioners who have
been suspended from such practice, their
designation as attorney, certified public
accountant, enrolled agent, or enrolled
actuary, and date or period of suspen-
sion. This announcement will appear in
the weekly Bulletin at the earliest practi-
cable date after such action and will
continue to appear in the weekly Bulle-
tins for five successive weeks or for as
many weeks as is practicable for each
attorney, certified public accountant, en-
rolled agent, or enrolled actuary so
suspended and will be consolidated and
published in the Cumulative Bulletin.
The following individuals have been
placed under suspension from practice
before the Internal Revenue Service by
virtue of the expedited proceeding pro-
visions of the applicable regulations:
NameAddressDesignationDate of Suspension
Alleva, DonaldMount Vernon, NYEnrolled AgentIndefinite from September 5, 1996
Rose, Robert M.Dallas, TXAttorneyIndefinite from September 5, 1996
McGrath, GregoryNew Smyrna Bch, FLCPAIndefinite from September 8, 1996
Finch, Kenneth L. Jr.Pelham, ALCPAIndefinite from September 8, 1996
11

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as ‘‘rulings’’)
that have an effect on previous rulings
use the following defined terms to de-
scribe the effect:
Amplifieddescribes a situation where
no change is being made in a prior
published position, but the prior position
is being extended to apply to a variation
of the fact situation set forth therein.
Thus, if an earlier ruling held that a
principle applied to A, and the new
ruling holds that the same principle also
applies to B, the earlier ruling is ampli-
fied. (Compare withmodified, below).
Clarifiedis used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously
published ruling and points out an es-
sential difference between them.
Modifiedis used where the substance
of a previously published position is
being changed. Thus, if a prior ruling
held that a principle applied to A but not
to B, and the new ruling holds that it
applies to both A and B, the prior ruling
is modified because it corrects a pub-
lished position. (Compare withamplified
andclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered de-
terminative with respect to future trans-
actions. This term is most commonly
used in a ruling that lists previously
published rulings that are obsoleted be-
cause of changes in law or regulations.
A ruling may also be obsoleted because
the substance has been included in regu-
lations subsequently adopted.
Revokeddescribes situations where
the position in the previously published
ruling is not correct and the correct
position is being stated in the new
ruling.
Supersededdescribes a situation
where the new ruling does nothing more
than restate the substance and situation
of a previously published ruling (or
rulings). Thus, the term is used to
republish under the 1986 Code and
regulations the same position published
under the 1939 Code and regulations.
The term is also used when it is desired
to republish in a single ruling a series of
situations, names, etc., that were previ-
ously published over a period of time in
separate rulings. If the new ruling does
more than restate the substance of a
prior ruling, a combination of terms is
used. For example,modifiedandsuper-
sededdescribes a situation where the
substance of a previously published rul-
ing is being changed in part and is
continued without change in part and it
is desired to restate the valid portion of
the previously published ruling in a new
ruling that is self contained. In this case
the previously published ruling is first
modified and then, as modified, is su-
perseded.
Supplementedis used in situations in
which a list, such as a list of the names
of countries, is published in a ruling and
that list is expanded by adding further
names in subsequent rulings. After the
original ruling has been supplemented
several times, a new ruling may be
published that includes the list in the
original ruling and the additions, and
supersedes all prior rulings in the series.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current use and
formerly used will appear in material published in
the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C.—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contribution Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign Corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statements of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
12

Numerical Finding List
1
Bulletins 1996–27 through 1996–44
Announcements:
96–61, 1996–27 I.R.B.72
96–62, 1996–28 I.R.B.55
96–63, 1996–29 I.R.B.18
96–64, 1996–29 I.R.B.18
96–65, 1996–29 I.R.B.18
96–66, 1996–29 I.R.B.19
96–67, 1996–30 I.R.B.27
96–68, 1996–31 I.R.B.45
96–69, 1996–32 I.R.B.38
96–70, 1996–32 I.R.B.40
96–71, 1996–33 I.R.B.16
96–72, 1996–33 I.R.B.16
96–73, 1996–33 I.R.B.18
96–74, 1996–33 I.R.B.19
96–75, 1996–34 I.R.B.29
96–76, 1996–34 I.R.B.29
96–77, 1996–35 I.R.B.15
96–78, 1996–35 I.R.B.15
96–79, 1996–35 I.R.B.15
96–80, 1996–35 I.R.B.16
96–81, 1996–36 I.R.B.13
96–82, 1996–36 I.R.B.14
96–83, 1996–36 I.R.B.14
96–84, 1996–36 I.R.B.14
96–85, 1996–37 I.R.B.20
96–86, 1996–37 I.R.B.21
96–87, 1996–37 I.R.B.21
96–88, 1996–38 I.R.B.150
96–89, 1996–37 I.R.B.22
96–90, 1996–37 I.R.B.22
96–91, 1996–37 I.R.B.23
96–92, 1996–38 I.R.B.151
96–93, 1996–38 I.R.B.151
96–94, 1996–38 I.R.B.153
96–96, 1996–39 I.R.B.41
96–97, 1996–39 I.R.B.41
96–98, 1996–39 I.R.B.42
96–99, 1996–39 I.R.B.42
96–100, 1996–40 I.R.B.10
96–101, 1996–40 I.R.B.10
96–102, 1996–40 I.R.B.11
96–103, 1996–40 I.R.B.12
96–104, 1996–41 I.R.B.10
96–105, 1996–42 I.R.B.19
96–106, 1996–42 I.R.B.23
96–107, 1996–42 I.R.B.27
96–108, 1996–44 I.R.B.15
96–109, 1996–43 I.R.B.76
96–110, 1996–43 I.R.B.77
96–111, 1996–44 I.R.B.16
96–113, 1996–44 I.R.B.18
Court Decisions:
2058, 1996–34 I.R.B.13
2059, 1996–34 I.R.B.10
2060, 1996–34 I.R.B.5
Delegation Orders:
155 (Rev. 4), 1996–40 I.R.B.9
Notices:
96–36, 1996–27 I.R.B.11
96–37, 1996–31 I.R.B.29
Notices—Continued
96–38, 1996–31 I.R.B.29
96–39, 1996–32 I.R.B.8
96–40, 1996–33 I.R.B.11
96–41, 1996–35 I.R.B.6
96–42, 1996–35 I.R.B.6
96–43, 1996–36 I.R.B.7
96–44, 1996–36 I.R.B.7
96–45, 1996–39 I.R.B.7
96–46, 1996–39 I.R.B.7
96–47, 1996–39 I.R.B.8
96–48, 1996–39 I.R.B.8
96–49, 1996–41 I.R.B.6
96–50, 1996–41 I.R.B.6
96–51, 1996–42 I.R.B.6
96–52, 1996–42 I.R.B. 8
96–54, 1996–44 I.R.B.13
Proposed Regulations:
CO–9–96, 1996–34 I.R.B.20
CO–24–96, 1996–30 I.R.B.22
CO–25–96, 1996–31 I.R.B.30
CO–26–96, 1996–31 I.R.B.31
FI–59–94, 1996–30 I.R.B.23
FI–32–95, 1996–34 I.R.B.21
FI–48–95, 1996–31 I.R.B.36
FI–28–96, 1996–31, I.R.B.33
GL–7–96, 1996–33 I.R.B.13
IA–292–84, 1996–28 I.R.B.38
IA–26–94, 1996–30 I.R.B.24
IA–29–96, 1996–33 I.R.B.14
INTL–4–95, 1996–36 I.R.B.8
PS–39–93, 1996–34 I.R.B.27
PS–22–96, 1996–33 I.R.B.15
REG–208215–91, 1996–38 I.R.B.145
REG–209803–95, 1996–44 I.R.B.14
REG–209826–96, 1996–42 I.R.B.10
REG–209827–96, 1996–37 I.R.B.19
REG–245562–96, 1996–41 I.R.B.8
Public Laws:
104–117, 1996–34 I.R.B.19
104–134, 1996–38 I.R.B.7
104–168, 1996–38 I.R.B.8
104–191, 1996–43 I.R.B.7
Railroad Retirement Quarterly Rate
1996–29 I.R.B.14
Revenue Procedures:
96–36, 1996–27 I.R.B.11
96–37, 1996–29 I.R.B.16
96–39, 1996–33 I.R.B.11
96–40, 1996–32 I.R.B.8
96–41, 1996–32 I.R.B.9
96–42, 1996–32 I.R.B.14
96–43, 1996–35 I.R.B.6
96–44, 1996–35 I.R.B.7
96–45, 1996–35 I.R.B.12
96–46, 1996–38 I.R.B.144
96–47, 1996–39 I.R.B.10
96–48, 1996–39 I.R.B.10
96–49, 1996–43 I.R.B.74
Revenue Rulings:
96–33, 1996–27 I.R.B.4
96–34, 1996–28 I.R.B.4
Revenue Rulings—Continued
96–35, 1996–31 I.R.B.4
96–36, 1996–30 I.R.B.6
96–37, 1996–32 I.R.B.4
96–38, 1996–33 I.R.B.4
96–39, 1996–34 I.R.B.4
96–42, 1996–35 I.R.B.4
96–43, 1996–36 I.R.B.4
96–44, 1996–38 I.R.B.4
96–45, 1996–39 I.R.B.5
96–46, 1996–39 I.R.B.5
96–47, 1996–40 I.R.B.7
96–48, 1996–40 I.R.B.4
96–49, 1996–41 I.R.B.4
96–50, 1996–42 I.R.B.4
96–51, 1996–43 I.R.B.5
Tax Conventions:
1996–28 I.R.B. 36
1996–36 I.R.B.6
1996–40 I.R.B.8
Treasury Decisions:
8673, 1996–27 I.R.B.4
8674, 1996–28 I.R.B.7
8675, 1996–29 I.R.B.5
8676, 1996–30 I.R.B.4
8677, 1996–30 I.R.B.7
8678, 1996–31 I.R.B.11
8679, 1996–31 I.R.B.4
8680, 1996–33 I.R.B.5
8681, 1996–37 I.R.B.17
8682, 1996–37 I.R.B.4
8683, 1996–44 I.R.B.9
8684, 1996–44 I.R.B.4
1
A cumulative list of all Revenue Rulings, Rev-
enue Procedures, Treasury Decisions, etc., pub-
lished in Internal Revenue Bulletins 1996–1
through 1996–26 will be found in Internal Rev-
enue Bulletin 1996–27, dated July 1, 1996.
13

Finding List of Current Action on
Previously Published Items
1
Bulletins 1996–27 through 1996–44
*Denotes entry since last publication
Revenue Procedures:
80–27
Modified by
96–40, 1996–32 I.R.B.8
87–32
Modified by
TD 8680, 1996–33 I.R.B.5
92–20
Modified by
TD 8680, 1996–33 I.R.B.5
95–16
Superseded by
96–48, 1996–39 I.R.B.10
95–29
Superseded by
96–36, 1996–27 I.R.B.11
95–29A
Superseded by
96–36, 1996–27 I.R.B.11
95–30
Superseded by
96–42, 1996–32 I.R.B.14
95–46
Superseded by
96–48, 1996–39 I.R.B.10
96–41
Modified by
Notice 96–49, 1996–41 I.R.B.6
1
A cumulative finding list for previously published
items mentioned in Internal Revenue Bulletins
1996–1 through 1996–26 will be found in Internal
Revenue Bulletin 1996–27, dated July 1, 1996.
14

Index
Internal Revenue Bulletins 1996–27
Through 1996–44
For index of items published during
the first six months of 1996, see
I.R.B. 1996–27, dated July 1, 1996.
The abbreviation and number in pa-
renthesis following the index entry
refer to the specific item; numbers in
roman and italic type following the
parenthesis refer to the Internal Rev-
enue Bulletin in which the item may
be found and the page number on
which it appears.
Key to Abbreviations:
RRRevenue Ruling
RPRevenue Procedure
TDTreasury Decision
CDCourt Decision
PLPublic Law
EOExecutive Order
DODelegation Order
TDO Treasury Department Order
TCTax Convention
SPR Statement of Procedural
Rules
PTEProhibited Transaction
Exemption
EMPLOYMENT TAXES
Proposed regulations:
26 CFR 301.9100–1T—301.9100–3T
and intermediary sections, added;
extensions of time to make elec-
tions (IA–29–96) 33,14
Railroad retirement:
Rate determination, quarterly (July 1,
1996) 29,14
Regulations:
26 CFR 301.9100–1T—301.9100–3T
and intermediary sections, added;
extensions of time to make elec-
tions (TD 8680) 33,5
ESTATE AND GIFT TAX
ADMINISTRATIVE
Proposed regulations:
26 CFR 20.2041–3, 20.2056(d)–2,
25.2511–1, 25.2514–3, 25.2518–1,
–2, amended; 20.2041–3, added;
disclaimer of interests and powers
(REG–208215–91) 38,145
ESTATE AND GIFT TAXES
ADMINISTRATIVE—
Continued
Proposed regulations—Continued
26 CFR 301.9100–1T—301.9100–3T
and intermediary sections, added;
extensions of time to make elec-
tions (IA–29–96) 33,14
ESTATE TAX
Proposed regulations:
26 CFR 20.2041–3(d)(6)(i), amend-
ed; 20.2041–3(d)(6)(iii), added;
20.2056(d)–2, amended; disclaimer
of interests and powers (REG–
208215–91) 38,145
Regulations:
26 CFR 301.9100–1T—301.9100–3T
and intermediary sections, added;
extensions of time to make elec-
tions (TD 8680) 33,5
EXCISE TAXES
Exempt organizations:
Excess benefit transactions engaged in
(Notice 46) 39,7
Foreign insurance taxes (Ct.D 2060) 34,
5
Proposed regulations:
26 CFR 2652–1, amended; genera-
tion-skipping transfer tax (PS–22–
96) 33,15
GIFT TAX
Proposed regulations:
26 CFR 25.2511–1, 25.2514–3,
25.2518–1, –2, amended; dis-
claimer of interests and powers
(REG–208215–91) 38,145
INCOME TAX
Accounting methods (Notice 40) 33,11
Bankruptcy; validity of liens (Ct.D
2059) 34,10
Bonds:
Qualified mortgage bonds:
Mortgage credit certificates:
National median gross income
(RP 37) 29,16
Claiming a refund, U.S. v. IBM (Notice
37) 31,29
Credits against tax:
Low-income housing (RP 46) 38,144
Satisfactory bond, ‘‘bond factor’’
amounts for the period July through
September 1996 (RR 45) 39,5
INCOME TAX—Continued
Employee plans:
Funding:
Full funding limitations, weighted
average interest rate, June 1996
(Notice 36) 27,11; July 1996
(Notice 38) 31,29
Full funding limitation:
Weighted average interest rate for
August 1996, (Notice 43) 36,7;
September 1996 (Notice 45) 39,
7; October 1996 (Notice 54) 44,
13
Nondiscrimination and coverage,
rollover (RR 48) 40,4
Participant consent, significant det-
riment (RR 47) 40,7
Section 414(u); retirement plans;
model amendments (RP 49) 43,
74
Exempt organizations:
Group letter exemption (RP 40) 32,8
Private inurement expressly prohibited
(Notice 47) 39,8
Information returns, copies to the
public and increases to certain pen-
alties (Notice 48) 39,8
Forms:
Paper substitutes, Forms 1096, 1098,
1099 series, 5498, and W–2G (RP
42) 32,14
Substitute printed, computer-prepared,
and computer-generated tax forms
and schedules (RP 48) 39,8
Health Insurance Portability and Ac-
countability Act of 1996 (P.L. 104–
191) 43,7
Income:
Controlled foreign corporation, part-
nership, subpart F income (Notice
39) 32,8
Inflation adjustment factor for 1996
(Notice 41) 35,6
Inflation-indexed debt instruments (No-
tice 51) 42,6
Insurance companies:
Differential earnings rate (RR 42) 35,
4
Loss reserves, discounting unpaid
losses (RP 44) 35,7
Discounting estimated salvage recov-
erable (RP 45) 35,12
Interest:
Investment:
Federal short-term, mid-term, and
long-term rates, July 1996 (RR
34) 28,4; August 1996 (RR 37)
32,4; September 1996 (RR 43)
36,4; October 1996 (RR 49) 41,
4
15

INCOME TAX—Continued
Interest—Continued
Rates, underpayments and overpay-
ments beginning October 1, 1996
(RR 44) 38,4
Inventories:
LIFO:
Price indexes, department stores,
May 1996 (RR 36) 30,6; June
1996 (RR 39) 34,4
Price indexes, department stores,
July 1996 (RR 46) 39,5
Price indexes, department stores,
August 1996 (RR 50) 42,4
Low income housing credit:
Bond factor amounts, April–June
1996 (RR 33) 27,4
FEMA (RR 35) 31,4
Marginal production rates for 1996 (No-
tice 42) 35,6
Omnibus Consolidated Recissions and
Appropriations Act of 1996 (PL 104–
134) 38,7
Pooled income fund; community trust;
maintenance requirement (RR 38) 33,
4
Proposed regulations:
26 CFR 1.61–8(b), revised; 1.451–
1(g), added; 1.467–1, amended;
1.467–4, amended; 1.467–0 through
–8, added; rental agreements (IA–
292–84) 28,38
26 CFR 1.61–12(c), 1.163–7(c),
1.171–1—1.171–4, 1.1016–5(b), re-
vised; 1.163–13, 1.171–5, added;
1.1016–9, removed; amortizable
bond premium (FI–48–95) 31,36
26 CFR 1.148–5(d)(6)(iv)—(viii) and
intermediary sections; 1.148–
5(e)(2)(iv), added; arbitrage restric-
tions on tax-exempt bonds (FI–28–
96) 31,33
26 CFR 1.166–3(a)(3), added; bad
debts modifications and dealer as-
signments of notional principal
contracts (FI–59–94) 30,23
26 CFR 1.280B–1, added; structure,
definition (PS–39–93) 34,27
26 CFR 1.367(e)–1, 1.6038B–
1(b)(2)(i); section 355 distributions
of stock and securities by domestic
corporations to foreign persons
(REG–209827–96) 37,19
26 CFR 1.382–5, –8, added; 1.382–
2(a)(1)(iv), revised; consolidated re-
turns, short taxable years for con-
trolled groups (CO–26–96) 31,31
26 CFR 1.401(a)(31)–1; 1.402(c)–2,
amended; relief from disqualifica-
tion of plans accepting rollovers
(REG–245562–96) 41,8
INCOME TAX—Continued
Proposed regulations—Continued
26 CFR 1.475(b)–1, –2, –4, 1.475-
(c)–1, –2, 1.475(e)–1, revised;
mark-to-market equity interests in
related parties and dealer-customer
relationship (FI–32–95) 34,21
26 CFR 1.671–1(g), (h), 1.671–2(f),
1.1297–4, added; application of the
grantor trust rules to nonexempt
employees’ trusts (REG–209826–
96) 42,10
26 CFR 1.861–8(e)(7)(iii), 1.865–1,
–2, 1.904–4(c)(2)(ii)(A) and (B),
added; 1.904–0, amended; stock
disposition loss allocation (INTL–
4–95) 36,8
26 CFR 1.1059(e)–1, added; extraor-
dinary dividends; distributions to
corporate shareholders (CO–9–96)
34,20
26 CFR 1.1202–0, –2, added; quali-
fied small business stock (IA–26–
94) 30,24
26 CFR 1.1502–15, –21, –22, –23,
added; consolidated returns, limita-
tions on the use of certain losses
and deductions (CO–24–96) 30,22
26 CFR 1.1502–90T—1.1502–99T
and intermediary sections, added;
consolidated group, net operating
loss carryforwards and built-in
losses and credits following owner-
ship change, limitation (CO–25–96)
31,30
26 CFR 1.6045–1, –2, 301.6011–2,
revised; magnetic media filing re-
quirements for information returns
(REG–209803–95) 44,14
26 CFR 301.9100–1T—301.9100–3T
and intermediary sections, added;
extensions of time to make elec-
tions (IA–29–96) 33,14
Recommendation letters for nonsuit
settlements (Del. Order 155, Rev. 4)
40,9
Refund claims; Tax Court; return not
filed (Ct.D. 2058) 34,13
Regulated investment companies, prefer-
ential dividends (RP 47) 39,10
Regulations:
26 CFR 1.110–3, added; debt instru-
ments modifications (TD 8675) 29,
5
26 CFR 1.163–7(a), added; 1.446–4,
amended; 1.483–2T, removed;
1.483–4, added; 1.1001–1, revised;
1.1012–1(g), revised; 1.1271–0(b),
amended; 1.1272–1(c)(7), added;
1.1274–2(g), revised; 1.1274–2(i)
and (j), added; 1.1275–2(g), (h), (i),
(j), added; 1.1275–2T, removed;
1.1275–4, added; 1.1275–5(a)(5),
INCOME TAX—Continued
Regulations—Continued
(6), added; 1.1275–5(c)(1), (5), re-
vised; 1.1275–6, added; debt instru-
ments with original issue discount,
contingent payments, anti-abuse
rule (TD 8674) 28,7
26 CFR 1.166–3T, 1.1001–4T, added;
bad debts modifications and dealer
assignments of notional principal
contracts (TD 8676) 30,4
26 CFR 1.367(e)–0; 1.367(e)–1, re-
moved; 1.367(e)–0T, –1T, added;
section 355 distributions of stock
and securities by domestic corpora-
tions to foreign persons (TD 8682)
37,4
26 CFR 1.382–5T, –8T, –2T(f)(1)(i)—
(iii) and intermediary sections,
added; 1.382–2, –2T, removed;
consolidated groups, short taxable
years for controlled groups (TD
8679) 31,4
26 CFR 1.1254–2(d)(1)(ii), –3(b)(1)(i)
and (ii), –3(d)(1)(i) and (ii), re-
vised; 1.1254–4, –6, amended;
treatment of gain from disposition
of interest in certain natural re-
source recapture property by S
corps and their shareholders (TD
8684) 44,4
26 CFR 1.1394–0, –1, added;
enterprize zone facility bonds (TD
8673) 27,4
26 CFR 1.1502–0, –1, –2, –11, –21A,
–22A, –23A, –41A, revised;
1.1502–15, –21, redesignated,
1.1502–21T, –23T, –79A, added;
1.1502–79, amended; consolidated
returns, limitations on the use of
certain losses and deductions (TD
8677) 30,7
26 CFR 1.1502–90T through –99T
and intermediary sections, added;
consolidated groups, net operating
loss carryforwards and built-in
losses and credits following owner-
ship change, limitations (TD 8678)
31,11
26 CFR 1.6045–1(q), –2, amended;
1.6045–1T, –2T, 301.6011–2T,
added; magnetic media filing re-
quirements for information returns
(TD 8683) 44,9
26 CFR 301.6355–1, amended; sale
of seized property (GL–7–96) 33,
13
26 CFR 301.7503–1, amended; time
for performance of acts where last
day falls on Saturday, Sunday, or
legal holiday (TD 8681) 37,17
16

INCOME TAX—Continued
Regulations—Continued
26 CFR 301.9100–1T—301.9100–3T
and intermediary sections, added;
extensions of time to make elec-
tions (TD 8680) 33,5
Returns:
Magnetic media reporting, Forms
1098, 1099, 5498, and W–2G (RP
36) 27,11
Section 355 de minimis limitation (RP
43) 35,6
INCOME TAX—Continued
Section 355 No Rule (RP 39) 33,11
Statements required by brokers; correc-
tion (Notice 50) 41,6
Tax benefits for individuals performing
services in certain hazardous duty
areas (PL 104–117) 34,19
Tax conventions:
Fiji 40,8
Russia 36,6
Taxes, accrual of deduction (RR 51)
43,5
INCOME TAX—Continued
Tax-exempt bonds; arbitrage (RR 41)
32,9; (Notice 49) 41,6
Tax treatment of partnership items cor-
rection (Notice 44) 36,7
Taxpayer Bill of Rights 2 (PL 104–168)
38,8
Work opportunity tax credit (Notice 52)
42,8
17