Internal Revenue Bulletin 1999-19 (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. 99–22, page 3.
LIFO; price indexes; department stores.The March
1999 Bureau of Labor Statistics price indexes are accepted
for use by department stores employing the retail inventory
and last-in, first-out inventory methods for valuing inventories
for tax years ended on, or with reference to, March 31,
1999.
EMPLOYEE PLANS
Announcement 99–50, page 6.
Effective May 10, 1999, the Service will temporarily discon-
tinue accepting applications for approval of master and pro-
totype plans (M & P) and regional prototype plans pending
the issuance of revised revenue procedures.
EXEMPT ORGANIZATIONS
Announcement 99–51, page 6.
A list is given of organizations now classified as private foun-
dations.
ADMINISTRATIVE
Notice 99–22, page 5.
Low-income housing tax credit.Resident population fig-
ures are reproduced for American Samoa, Guam, the North-
ern Mariana Islands, Puerto Rico, and the U.S. Virgin Islands
for the purpose of determining their 1999 calendar year
state housing credit ceiling under section 42(h) of the Code
and private activity bond volume cap under section 146 of
the Code. Notice 94–16 obsoleted.
Announcement 99–52, page 9.
This document contains a correction to Announcement
99–36, 1999–16 I.R.B. 10, relating to the decision by the
Service to continue to publish the cumulative bulletin but in a
new format.
Internal Revenue
bbuulllleettiinn
Bulletin No. 1999–19
May 10, 1999
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.
Department of the Treasury
Internal Revenue Service
Finding Lists begin on page 11.

The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing offi-
cial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
general interest. It is published weekly and may be obtained
from the Superintendent of Documents on a subscription
basis. Bulletin contents are consolidated semiannually into
Cumulative Bulletins, which are sold on a single-copy basis.
It is the policy of the Service to publish in the Bulletin all sub-
stantive 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 other-
wise indicated. Procedures relating solely to matters of in-
ternal 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 Service 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 unwarranted 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 pub-
lished rulings and procedures, the effect of subsequent leg-
islation, regulations, court decisions, rulings, and proce-
dures must be considered, and Service personnel and oth-
ers concerned are cautioned against reaching the same con-
clusions 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 Sub-
parts. Also included in this part are Bank Secrecy Act Admin-
istrative Rulings. Bank Secrecy Act Administrative Rulings
are issued by the Department of the Treasury’s Office of the
Assistant Secretary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The first Bulletin for each month includes a cumulative index
for the matters published during the preceding months.
These monthly indexes are cumulated on a semiannual basis,
and are published in the first Bulletin of the succeeding semi-
annual period, respectively.
Mission of the Service
Provide America’s taxpayers top quality service by help-
ing them understand and meet their tax responsibilities
and by applying the tax law with integrity and fairness to
all.
2
Introduction
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, DC 20402.

Section 472.—Last-in, First-out
Inventories
26 CFR 1.472–1: Last-in, first-out inventories.
LIFO; price indexes; department
stores. The March 1999 Bureau of Labor
Statistics price indexes are accepted for
use by department stores employing the
retail inventory and last-in, first-out in-
ventory methods for valuing inventories
for tax years ended on, or with reference
to, March 31, 1999.
Rev. Rul. 99–22
The following Department Store In-
ventory Price Indexes for March 1999
were issued by the Bureau of Labor Sta-
tistics. The indexes are accepted by the
Internal Revenue Service, under
§ 1.472–1(k) of the Income Tax Regula-
tions and Rev. Proc. 86–46, 1986–2 C.B.
739, for appropriate application to inven-
tories of department stores employing
the retail inventory and last-in, first-out
inventory methods for tax years ended
on, or with reference to, March 31, 1999.
The Department Store Inventory Price
Indexes are prepared on a national basis
and include (a) 23 major groups of depart-
ments, (b) three special combinations of
the major groups - soft goods, durable
goods, and miscellaneous goods, and (c) a
store total, which covers all departments,
including some not listed separately, ex-
cept for the following: candy, food,
liquor, tobacco, and contract departments.
1999–19 I.R.B.3May 10, 1999
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
BUREAU OF LABOR STATISTICS, DEPARTMENT STORE
INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS
(January 1941 = 100, unless otherwise noted)
Percent Change
Mar.Mar.from Mar.1998
Groups19981999to Mar. 1999
1
1. Piece Goods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .538.9555.83.1
2. Domestics and Draperies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .636.1619.9–2.5
3. Women’s and Children’s Shoes . . . . . . . . . . . . . . . . . . . . . . . . . . . . .658.7651.0–1.2
4. Men’s Shoes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .898.3887.6–1.2
5. Infants’ Wear . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .620.5617.2–0.5
6. Women’s Underwear . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .576.3577.40.2
7. Women’s Hosiery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .308.1321.4 4.3
8. Women’s and Girls’ Accessories . . . . . . . . . . . . . . . . . . . . . . . . . . . .556.8557.40.1
9. Women’s Outerwear and Girls’ Wear . . . . . . . . . . . . . . . . . . . . . . . .429.5408.4–4.9
10. Men’s Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .636.5623.1–2.1
11. Men’s Furnishings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .608.1611.10.5
12. Boys’ Clothing and Furnishings . . . . . . . . . . . . . . . . . . . . . . . . . . . .501.4488.6–2.6
13. Jewelry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .993.0977.8–1.5
14. Notions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .796.7785.7–1.4
15. Toilet Articles and Drugs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .932.4957.32.7
16. Furniture and Bedding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .673.0690.92.7
17. Floor Coverings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .583.1602.43.3
18. Housewares . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .818.3803.5–1.8
19. Major Appliances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .237.4233.9–1.5
20. Radio and Television . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .73.467.9–7.5
21. Recreation and Education
2
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .106.799.9–6.4
22. Home Improvements
2
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .134.5128.5–4.5
23. Auto Accessories
2
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .107.5107.4–0.1
Groups 1 – 15: Soft Goods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .612.2603.6–1.4
Groups 16 – 20: Durable Goods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .463.0454.6–1.8
Groups 21 – 23: Misc. Goods
2
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .110.4105.1–4.8
Store Total
3
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .558.9548.5–1.9
1
Absence of a minus sign before percentage change in this column signifies price increase.
2
Indexes on a January 1986=100 base.
3
The store total index covers all departments, including some not listed separately, except for the following: candy, food, liquor, tobacco, and contract departments.

May 10, 199941999–19 I.R.B.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Richard C. Farley, Jr. of the Of-
fice of Assistant Chief Counsel (Income
Tax and Accounting). For further infor-
mation regarding this revenue ruling, con-
tact Mr. Farley on (202) 622-4970 (not a
toll-free call).

Low-Income Housing Tax
Credit—1999 Possessions
Population Figures
Notice 99–22
This notice obsoletes Notice 94–16,
1994–1 C.B. 337, and publishes the Bu-
reau of the Census population figures for
American Samoa, Guam, the Northern
Mariana Islands, Puerto Rico, and the
U.S. Virgin Islands (the Possessions) for
use in calculating the 1999 calendar year
population-based component of the state
housing credit ceiling (Credit Ceiling)
under § 42(h)(3)(C)(i) of the Internal
Revenue Code and the 1999 calendar year
volume cap (Volume Cap) under § 146.
Notice 94–16 provides resident popula-
tion figures for the Possessions to use in
calculating their Credit Ceilings and Vol-
ume Caps for the 1994 calendar year and
subsequent calendar years until super-
seded by release of new population fig-
ures by the Bureau of the Census.
The Bureau of the Census has released
in CB98–219 and CB98–241 new esti-
mates of the resident population of the
Possessions. The new resident population
figures of the Possessions, reprinted
below, must be used by the Possessions in
determining their 1999 Credit Ceilings
and Volume Caps.
Resident Population Figures
PossessionPopulation
American Samoa62,093
Guam149,101
Northern Mariana Islands66,611
Puerto Rico3,860,091
U.S. Virgin Islands118,382
For calendar years after 1999, the resi-
dent population figures of the Possessions
will be included in the annual Internal
Revenue Service publication providing
the most recent estimates of the resident
population for the states.
The principal authors of this notice are
Christopher J. Wilson of the Office of As-
sistant Chief Counsel (Passthroughs and
Special Industries) and Timothy L. Jones
of the Office of Assistant Chief Counsel
(Financial Institutions and Products). For
further information regarding this notice
contact Mr. Wilson on (202) 622-3040
(not a toll-free call).
1999–19 I.R.B.5May 10, 1999
Part III. Administrative, Procedural, and Miscellaneous

May 10, 199961999–19 I.R.B.
Part IV. Items of General Interest
Temporary Closing of M&P
and Regional Prototype
Plan Programs
Announcement 99–50
The Service is revising and improving
the master and prototype (M&P) and re-
gional prototype plan programs. Revised
procedures are expected to be published
soon. In the interim, the Service will tem-
porarily discontinue accepting applica-
tions for approval of M&P and regional
prototype plans, effective May 10, 1999.
At the present time, the Service’s re-
view of applications for approval of M&P
and regional prototype plans generally
takes into account recent changes in law,
but does not consider the provisions of the
Small Business Job Protection Act of
1996, Pub. L. 104–88 (SBJPA), that are
effective in 1999 and later (that is, the
nondiscrimination safe harbors under
§ 401(k)(12) and § 401(m)(11) of the In-
ternal Revenue Code and the repeal of the
combined plan limitation under § 415(e)).
See Rev. Proc. 98–14, 1998–4 I.R.B. 22,
as modified by Rev. Proc. 98–53,
1998–40 I.R.B. 9. The Service is cur-
rently developing procedures that will
allow sponsors to request approval letters
for these plans which will take into ac-
count all recent changes in law, including
the provisions of SBJPA that are effective
in 1999 and later. Because the Service
has consolidated its determination letter
program, it is no longer necessary or prac-
tical to maintain two separate programs
for the approval of prototype plans.
Therefore, it is expected that the new pro-
cedures will combine the M&P and re-
gional prototype plan programs into a sin-
gle program that will be administered by
the Service’s headquarters office. This
single program will provide a uniform set
of procedures that will apply to all proto-
type plans, regardless of whether the
plans are sponsored by organizations that
currently may sponsor M&P plans or by
individuals or organizations that currently
may sponsor regional prototype plans.
The Service expects to publish these
new procedures soon. In anticipation of
this, effective May 10, 1999, it will not
accept applications for approval of M&P
and regional prototype plans until further
notice. The Service will continue to
process all M&P and regional prototype
plan applications submitted before May
10, 1999 in accordance with Rev. Proc.
98–14, as modified by Rev. Proc. 98–53.
Any opinion or notification letter issued
in response to a pre-May 10, 1999 appli-
cation will not take into account the pro-
visions of SBJPA that are effective in
1999 and later, even if the letter is issued
after the date that the Service starts ac-
cepting applications under the new proce-
dures. Alternatively, sponsors may with-
draw any pending application relating to
an M&P or regional prototype plan. In
this case, the user fee will not be re-
funded. However, if a new application
pertaining to the same plan is filed under
the new procedures on or before Decem-
ber 31, 1999, the user fee for the new ap-
plication will be waived. The sponsor
should indicate on the face of the applica-
tion form that the user fee is being waived
pursuant to Announcement 99–50.
Foundations Status of Certain
Organizations
Announcement 99–51
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 des-
ignations in the Cumulative List of Orga-
nizations (Publication 78), or on the pre-
sumption arising from the filing of notices
under section 508(b) of the Code. This
listing does notindicate that the organiza-
tions have lost their status as organiza-
tions described in section 501(c)(3), eligi-
ble to receive deductible contributions.
Former Public Charities.The following
organizations (which have been treated as
organizations that are not private founda-
tions described in section 509(a) of the
Code) are now classified as private foun-
dations:
Able House Inc., Los Angeles, CA
Arizona Youthline, Phoenix, AZ
Claypole Publishers Inc., Princeton, NJ
Creative Parents Television, Carmichael,
CA
Crescent City Community Housing
Corporation, New Orleans, LA
DARE for the Kids of Apache Junction
Inc., Apache Junction, AZ
East Grasslands Waterfowl Habitat
Association, Modesto, CA
Extended Academics Inc., Bay Minette,
AL
First Quartet Inc., Atlanta, GA
Foundation for Regional Transit,
Palo Alto, CA
Friends of the Columbia County Library
Chapter of Suwanne Regional,
Lake City, FL
Harmon Glass Foundation for Highway
Safety Inc., Minneapolis, MN
Help Ourselves Project, Philadelphia, PA
Korean Community Talk Line,
Sacramento, CA
Left Coast Crime Conference Inc.,
Phoenix, AZ
Living Traditions Inc., New York, NY
Lonsdale Improvement Organization Inc.,
Knoxville, TN
Mansfield Families, Mansfield, MA
Manufacturing Technology Initiative,
San Jose, CA
Medical Psychophysics Research
Institute Inc., Las Vegas, NV
Metropolitan Innovations Incorporated,
Minneapolis, MN
Mohawk Valley Breastfeeding Network,
Utica, NY
Mount Zion Area Economic
Development Corporation, Mount
Zion, IL
Multi-Cultural Visions, Phoenix, AZ
New Hope Arts Commission Inc.,
New Hope, PA
New Hope of Florence Inc., Florence, SC
New Hope Outreach Ministries, Baton
Rouge, LA
New Horizons Development Corporation,
Brooklyn, NY
New Jersey Coalition Against Sexual
Assault, New Brunswick, NJ
New Jersey Disability and Non-Profit
Micro-Loan Fund Inc., Trenton, NJ
New Joshua Center for Hope, Cleveland,
OH
New Life Cultural Society, Northbrook,
IL
New Life Dimensions Ministries,
Scottsdale, AZ
New Life Intracoastal Community,
New Orleans, LA

1999–19 I.R.B.7May 10, 1999
New Life Newspapers, Seattle, WA
New Life Options for the Vital Elderly
Inc., Antioch, IL
New London Community Center Inc.,
New London, CT
New Lothrop Teen Center Inc.,
New Lothrop, MI
New Mexico Center for Loss and Grief,
Santa Fe, NM
New Mexico Housing Alliance,
Albuquerque, NM
New Mexico Law Enforcement Football
League, Albuquerque, NM
New Mt. Zion Family Life Center Inc.,
West Memphis, AR
New Music Institute of Kansas City Inc.,
Westwood, KS
New Name of the Game Golf Foundation
Inc., Pittsburgh, PA
New Orleans Rhythm & Dance Ensemble
Inc., New Orleans, LA
New Pisgah Haven Homes, Chicago, IL
New Press, Rego Park, NY
New Providence Sports Club Inc., New
Providence, NJ
New Refuge House Inc., Buffalo, NY
New Renaissance of Hope Inc., Detroit,
MI
New Spirit Evangelistic Ministries,
Houston, TX
New Wine Ministries, West Monroe, LA
New Wings Ministries, Vestal. NY
New World Studios Incorporated,
Springfield, OR
New York Alliance of Black School
Educators Incorporated, Brooklyn,
NY
New York Association of Psychiatric
Rehabilitation Services Inc., Syracuse,
NY
New York Drug Enforcement Agents
Scholarship Foundation Inc.,
New York, NY
New York International African Institute,
Buffalo, NY
New York Knights of the Grip Nassau Co
Inc., Woodbury, NY
New York Labor History Association
Incorporated, New York, NY
New York State Council for Education in
Agriculture, Caneadea, NY
New Yorkers for Companion Animals
Inc., New York, NY
Newberry County Project Life Inc.,
Newberry, SC
Newburgh Heritage Trust Inc.,
Newburgh, ME
Newburgh Karate Club, Newburgh, IN
Newport Foundation Incorporated,
Windsor Locks, CT
Newport Preservation Alliance, Newport,
RI
Newport Volunteer Firefighters & Rescue
Association, Newport, NC
Newton Rotary Club Endowment Inc.,
Newton, NJ
Next Progressive Inc., Washington, DC
Next Stage Productions Inc., Port
Washington, NY
NFTE Solutions Inc., Bronx, NY
NIA Hope Inc., Philadelphia, PA
Night and Day Group, Euclid, OH
NIOTA Flood Control Council, Nauvoo,
IL
Nirmala Foundation, Pittsburgh, PA
Nisswi Ishkoden, Grand Rapids, MI
NLF Education Foundation Inc., Dallas
Ft. Worth, TX
Noble County AIDS Task Force Inc.,
Kendallville, IN
Noblesville Cultural Arts Commission
Inc., Noblesville, IN
Nolan Outreach, Baton Rouge, LA
Nomad Cincinnati, OH
Nome Library Foundation Inc., Nome,
AK
Non-Profit Import Exchange Inc.,
St. Charles, MO
Nordenlight Love for Animals Inc.,
Upper Saddle River, NJ
Nordyne Flood Relief Fund, St. Louis,
MO
Norfolk Youth Association Inc., Norfolk,
VA
North Alexander School Association Inc.,
Washington, GA
North American Chinese Christian
Literature Ministry, Chicago, IL
North American Chinese Martial Arts
Federation Inc., Baltimore, MD
North American Chinese Sociologist
Association, Poway, CA
North American Jat Charities Inc.,
Freehold, NJ
North American Snake Institute Inc.,
Jacksonville, FL
North Area Adult Respite Center, North
Syracuse, NY
North Area Athletic Club Inc., Liverpool,
NY
North Attleboro Educational Foundation
Inc., N. Attleboro, MA
North Augusta High School Foundation,
North Augusta, SC
North Bennington Independent Artists
Space, N. Bennington, VT
North Carolina Alliance for
Transportation Reform, Durham, NC
North Carolina Depressive & Manic-
Depressive Association, Raleigh, NC
North Carolina Injured Workers Network,
Granite Falls, NC
North Central Recycling Inc., Concordia,
KS
North Country Fiber Fair Inc., Valley
City, ND
North Dade Community Development
Corporation, Miami, FL
North Dakota Peace Officers Foundation
Inc., West Fargo, ND
North Hill Apartments Inc., Springfield,
OH
North Kansas City Historical Society,
North Kansas City, MO
Northland Village Residents Council,
Dayton, OH
North Mobile Boxing Club, Satsuma,
AL
North Newstead Merchants Association,
St. Louis, MO
North Pole Youth Sports Council Inc.,
N. Pole, AK
North Texas Kids Services Inc., Dallas,
TX
North Texas Tres Dias, Dallas, TX
North Tulsa Neighborhood Development
Corporation, Tulsa, OK
Northampton Childrens Theatre Inc.,
Northampton, MA
Northampton Soccer Club Inc.,
Northampton, MA
Northeast Community Drill Team,
Houston, TX
Northeast Hawkwatch Inc., Southwick,
MA
Northeast Metro Pageant Inc., Ham Lake,
MN
Northeast Minnesota Housing
Partnership, Virginia, MN
Northeast Mobile Search & Rescue Inc.,
Ballston Lake, NY
Northeast Regional Tenant Community
Association Inc., Baltimore, MD
Northeast Sports Center of Amherst,
Nelson, NH
Northeast Tarrant Foundation, Haltom
City, TX
Northern Area Association, Detroit, MI
Northern California Family Life Skills
Learning Ctr & Domestic, Redding,
CA

Northern California Swim League, Galt,
CA
Northern Lights Alternatives-Capital
District, Delmar, NY
Northern Lights Jr. Drum and Bugle
Corps Association, Longview, WA
Northern Nevada Foundation Inc., Reno,
NV
Northern Rockies Heritage Center Inc.,
Missoula, MT
Northern Virginia Tennis Patrons
Association Inc., Fairfax, VA
Northern York County Historical and
Preservation Society Inc., York, PA
Northern Youth Recreation Association,
Inc., Dillsburg, PA
Northland Military Museum, Sebeka,
MN
Northland Vietnam Veterans Memorial
Foundation, Duluth, MN
Northshore Hellenic Womens Guild Inc.,
Danvers, MA
Northside Neighbors Inc., Wadsworth,
OH
Northwest Babe Ruth League,
Bakersfield, CA
Northwest Community Projects Inc.,
Arlington Heights, IL
Northwest Educational Foundation Inc.,
Grand Island, NE
Northwest Health Center, Santa Maria,
CA
Northwest Hope Ministries for Persons
with Disabilities, Troutdale, OR
Northwest Omaha Renegades Youth
Athletic Association Inc., Omaha, NE
Northwest United Soccer Club, Crystal
Lake, IL
Norwegian Emigrant Museum, Fridley,
MN
Novalight Arts Inc., New York, NY
Now Detroit Community Organization,
Detroit, MI
NSSC National Space Science Center
Inc., Scottsdale, AZ
Nuage Life Style Balance Inc., New
York, NY
Nucleus Inc., Franklin, NE
Nuestra Casa, San Jose, CA
Nulife Elder Care Home Inc., Oakwood
Village, OH
Nur-Ain Jahan of the Southern Tier,
Binghamton, NY
Nurses for National Health Care –
Midwest, Naperville, IL
Nursing Research Institute of the
Southwest Inc., Denton, TX
Nutrition and Fitness Research
Associates Inc., Philadelphia, PA
Nysmith Fund Inc., Herndon, VA
Parkville School-Age Child Care Inc.,
Hartford, CT
Rights and Resources, Arlington, VA
Rio Bravo Association, Edinburg, TX
Rio Grande Counseling Center, Los
Fresnos, TX
Ripley Band Boosters, Ripley, OH
Ripley County Child Abuse Prevention
Council, Versailles, IN
Ripley Youth Basketball League Inc.,
Ripley, WV
Rise & Shine Development Center,
Boone, NC
Rising Star Child Care and Development
Center Inc., Raleigh, NC
Rising Stars Early Learning Centers Inc.,
Baltimore, MD
Rising Sun Energy Center, Santa Cruz,
CA
Rita Ethington Deliverance Ministry of
Helps Inc., Detroit, MI
River Heights Apartments Inc.,
Starkville, MS
River Oaks Arts, Oak Park, IL
River of Life Ministries Inc., Macon, GA
River Road Band Booster Association,
Amarillo, TX
River Valley Childrens Home Inc.,
Minneapolis, MN
Riverdale Volunteer Fire Company Inc.,
Riverdale, NJ
Riverside Arts Center, Riverside, IL
Riverside Tournament Association,
Littleton, CO
Riviera Kleberg County Scholarship
Fund Inc., Riviera, TX
Ro Shea Recovery Center, Sandhill, MS
Roaring Twenties of Rockford Inc.,
Rockford, IL
Robert Carter House Inc., Houston, TX
Robert Gamez Foundation, Las Vegas,
NV
Robert Hammond Ministries Inc.,
Wichita, KS
Robert R Mitchell Scholarship Fund,
Akron, OH
Rochelle Can, Oregon, IL
Rochester School of the Arts, Rochester,
MN
Rock-on Camp Inc., Barrington, IL
Rockaway Beach Community
Development Association, Rockaway
Beach, MO
Rockdale Swimming Inc., Conyers, GA
Rocky Mountain Care-Holladay Inc., Salt
Lake City, UT
Rocky Mountain Division of the
International Association for, Denver,
CO
Rocky Mountain Repertory Ensemble,
Broomfield, CO
Roff Educational Enrichment
Foundation, Roff, OK
Roger D Watkins Evangelistic
Association Inc., Crossville, AL
Rolling Hills Ministry Inc., Alvord, TX
Ropes Course in Support of Project Dare,
Cary, NC
Rosedale Historical Society Inc.,
Rosedale, MD
Rosemary Hubbell Wirkus Memory
Disorder Residential Facility Inc.,
Chiegiak, AK
Rosemary Institute for Public
Involvement Inc., Portland, OR
Roseville Public Schools Foundation,
Roseville, IL
Roslyn Nadel Scholarship for Disabled
Persons Inc., Florham Park, NJ
Rowan County Christmas Inc.,
Morehead, KY
Rowlett Animal Adoption Center,
Rowlett, TX
Rowlett Needy Childrens Fund, Dallas,
TX
Royal Court of the Golden Spike Empire,
Salt Lake, UT
Royal Heights Housing Inc., Dunn, NC
Royal Oak Foundation for Public
Education, Royal Oak, MI
RSD Charitable Trust of Michigan, Ann
Arbor, MI
Ruach Ministries Inc., Ramsey, NJ
Rubicon Productions Inc., Lexington, VA
Rugby Volunteer Rescue Squad and Fire
Department Inc., Mount of Wilson, VA
Ruidoso Junior Golf Inc., Ruidoso, NM
Rural America Network, Newport, WA
Rural Minnesota Community Computer
Consortium Inc., Princeton, NM
Rural Partners, Springfield, IL
Russell County Medical Center Auxiliary,
Lebanon, VA
Russian American Development
Corporation, Cheverly, MD
Russian-American Fund for Orthodoxy,
New York, NY
Russian Ballet Institute Inc., Salt Lake
City, UT
Russian Business Foundation Ltd.,
Osterville, MA
May 10, 199981999–19 I.R.B.

Russian Educational Foundation Inc.,
Houston, TX
Ruth Bass Memorial Foundation Inc.,
W. Orange, NJ
Ruth Taylor Williams Foundation,
Las Vegas, NV
Ryan Lynch Memorial Polocrosse
Foundation, Aspen, CO
Rye Education Fund Inc., Rye, NY
Side By Side, E. Williston, NY
Summit Vietnam Veterans Foundation
Corp., Mogadore, OH
Teacher Mommy Day Care Inc., Monsey,
NY
The Japanese Folk Dance Institute of N Y
Inc., New York, NY
The Parks Project, Sacramento, CA
Unlimited Minds Inc., Albany, NY
Vallejo Affordable Housing Inc., Vallejo,
CA
Venezuela en Danzas, Houston, TX
We Care Foundation Inc., Baton Rouge,
LA
Westside Track Club Inc., Louisville, KY
White Oak Mountain Ministries Inc.,
Harrison, TN
63rd Ohio Volunteer Infantry Regiment,
Chillicothe, Oh
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 de-
termination letter with the revised classi-
fication as to foundation status. Grantors
and contributors may thereafter rely upon
such ruling or determination letter as pro-
vided in section 1.509(a)–7 of the Income
Tax Regulations. It is not the practice of
the Service to announce such revised clas-
sification of foundation status in the Inter-
nal Revenue Bulletin.
Cumulative Bulletin Continued
in a New Format; Correction
Announcement 99–52
Announcement 99–36, 1999–16 IRB
10, is missing text in the first column,
item #1, on page 10. The second sentence
in the paragraph reads:
“Volume 1 will contain the first 26 is-
sues of the IRB (1998–27 to 1998–52).”
The text is corrected as follows:
“Volume 1 will contain the first 26 is-
sues of the IRB (1998–1 to 1998–26), and
Volume 2 will contain the second 26 is-
sues of the IRB (1998–27 to 1998–52).”
1999–19 I.R.B.9May 10, 1999

May 10, 1999101999–19 I.R.B.
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:
Amplified describes a situation where
no change is being made in a prior pub-
lished 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 amplified. (Compare
with modified, below).
Clarified is 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 essen-
tial difference between them.
Modified is 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 ap-
plies to both A and B, the prior ruling is
modified because it corrects a published
position. (Compare with amplified and
clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used
in a ruling that lists previously published
rulings that are obsoleted because of
changes in law or regulations. A ruling
may also be obsoleted because the sub-
stance has been included in regulations
subsequently adopted.
Revoked describes situations where the
position in the previously published rul-
ing is not correct and the correct position
is being stated in the new ruling.
Superseded describes 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 previously published over a pe-
riod 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, modified
and superseded describes a situation
where the substance of a previously pub-
lished ruling 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 super-
seded.
Supplemented is 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 pub-
lished that includes the list in the original
ruling and the additions, and supersedes
all prior rulings in the series.
Suspended is 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 for-
merly 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 Procedral 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.
Definition of Terms

1999–19 I.R.B.11May 10, 1999
1
A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 1998–1 through 1998–52
will be found in Internal Revenue Bulletin 1999–1,
dated January 4, 1999.
Numerical Finding List
1
Bulletins 1999–1 through 1999–18
Announcements:
99–1, 1999–2 I.R.B. 41
99–2, 1999–2 I.R.B. 44
99–3, 1999–3 I.R.B. 15
99–4, 1999–3 I.R.B. 15
99–5, 1999–3 I.R.B. 16
99–6, 1999–4 I.R.B.24
99–7, 1999–2 I.R.B. 45
99–8, 1999–4 I.R.B.24
99–9, 1999–4 I.R.B. 24
99–10, 1999–5 I.R.B. 63
99–11, 1999–5 I.R.B. 64
99–12, 1999–5 I.R.B. 65
99–13, 1999–6 I.R.B. 18
99–14, 1999–7 I.R.B.60
99–15, 1999–8 I.R.B.78
99–16, 1999–8 I.R.B. 80
99–17, 1999–9 I.R.B. 59
99–18, 1999–13 I.R.B. 21
99–19, 1999–10 I.R.B. 63
99–20, 1999–11 I.R.B.53
99–21, 1999–11 I.R.B.55
99–22, 1999–12 I.R.B. 32
99–23, 1999–15 I.R.B. 7
99–24, 1999–14 I.R.B. 12
99–25, 1999–12 I.R.B. 35
99–26, 1999–14 I.R.B. 20
99–27, 1999–13 I.R.B. 22
99–28, 1999–13 I.R.B. 25
99–29, 1999–13 I.R.B. 25
99–30, 1999–13 I.R.B. 26
99–31, 1999–13 I.R.B. 26
99–32, 1999–14 I.R.B.20
99–33, 1999–14 I.R.B. 21
99–34, 1999–15 I.R.B. 8
99–35, 1999–14 I.R.B. 22
99–36, 1999–16 I.R.B. 10
99–37, 1999–15 I.R.B. 9
99–38, 1999–15 I.R.B. 9
99–39, 1999–15 I.R.B. 10
99–40, 1999–16 I.R.B. 10
99–41, 1999–16 I.R.B. 10
99–42, 1999–16 I.R.B. 11
99–43, 1999–16 I.R.B. 11
99–44, 1999–16 I.R.B. 12
99–45, 1999–16 I.R.B. 12
99–46, 1999–16 I.R.B. 13
99–48, 1999–17 I.R.B.20
99–49, 1999–18 I.R.B.7
Notices:
99–1, 1999–2 I.R.B. 8
99–2, 1999–2 I.R.B. 8
99–3, 1999–2 I.R.B. 10
99–4, 1999–3 I.R.B. 9
99–5, 1999–3 I.R.B. 10
99–6, 1999–3 I.R.B. 12
99–7, 1999–4 I.R.B.23
99–8, 1999–5 I.R.B. 26
99–9, 1999–4 I.R.B. 23
99–10, 1999–6 I.R.B. 14
99–11, 1999–8 I.R.B.56
99–12, 1999–9 I.R.B. 44
99–13, 1999–10 I.R.B. 26
99–14, 1999–11 I.R.B.7
99–15, 1999–12 I.R.B.20
Notices—Continued
99–16, 1999–13 I.R.B.10
99–17, 1999–14 I.R.B.6
99–18, 1999–16 I.R.B. 4
99–19, 1999–16 I.R.B. 4
99–20, 1999–17 I.R.B.16
99–21, 1999–17 I.R.B. 19
Proposed Regulations:
REG–209103–89, 1999–11 I.R.B. 10
REG–209619–93, 1999–10 I.R.B. 28
REG–245562–96, 1999–9 I.R.B. 45
REG–104072–97, 1999–11 I.R.B. 12
REG–114663–97, 1999–6 I.R.B. 15
REG–114664–97, 1999–11 I.R.B. 21
REG–116826–97, 1999–10 I.R.B. 40
REG–118620–97, 1999–9 I.R.B. 46
REG–120168–97, 1999–12 I.R.B. 21
REG–121806–97, 1999–10 I.R.B. 46
REG–100729–98, 1999–14 I.R.B. 9
REG–104924–98, 1999–10 I.R.B.47
REG–105964–98, 1999–12 I.R.B. 22
REG–106177–98, 1999–12 I.R.B. 25
REG–106219–98, 1999–9 I.R.B. 51
REG–106386–98, 1999–12 I.R.B. 31
REG–106388–98, 1999–11 I.R.B. 27
REG–106564–98, 1999–10 I.R.B.53
REG–106902–98, 1999–8 I.R.B. 57
REG–106905–98, 1999–11 I.R.B. 39
REG–110524–98, 1999–10 I.R.B. 55
REG–111435–98, 1999–7 I.R.B. 55
REG–113694–98, 1999–7 I.R.B. 56
REG–111435–98, 1999–7 I.R.B. 55
REG–113744–98, 1999–10 I.R.B. 59
REG–114841–98, 1999–11 I.R.B. 41
REG–115433–98, 1999–9 I.R.B. 54
REG–116099–98, 1999–12 I.R.B. 34
REG–116824–98, 1999–7 I.R.B.57
REG–117620–98, 1999–7 I.R.B. 59
REG–118662–98, 1999–13 I.R.B. 13
REG–119192–98, 1999–11 I.R.B. 45
REG–121865–98, 1999–8 I.R.B.63
Revenue Procedures:
99–1, 1999–1 I.R.B. 6
99–2, 1999–1 I.R.B. 73
99–3, 1999–1 I.R.B. 103
99–4, 1999–1 I.R.B. 115
99–5, 1999–1 I.R.B. 158
99–6, 1999–1 I.R.B. 187
99–7, 1999–1 I.R.B. 226
99–8, 1999–1 I.R.B. 229
99–9, 1999–2 I.R.B. 17
99–10, 1999–2 I.R.B. 11
99–11, 1999–2 I.R.B. 14
99–12, 1999–3 I.R.B. 13
99–13, 1999–5 I.R.B. 52
99–14, 1999–5 I.R.B. 56
99–15, 1999–7 I.R.B. 42
99–16, 1999–7 I.R.B. 50
99–17, 1999–7 I.R.B. 52
99–18, 1999–11 I.R.B.7
99–19, 1999–13 I.R.B.10
99–20, 1999–14 I.R.B.7
99–21, 1999–17 I.R.B. 18
99–22, 1999–15 I.R.B.5
99–23, 1999–16 I.R.B.5
Revenue Rulings:
99–1, 1999–2 I.R.B. 4
Revenue Rulings—Continued
99–2, 1999–2 I.R.B. 5
99–3, 1999–3 I.R.B. 4
99–4, 1999–4 I.R.B.19
99–5, 1999–6 I.R.B.8
99–6, 1999–6 I.R.B. 6
99–7, 1999–5 I.R.B. 4
99–8, 1999–6 I.R.B.8
99–9, 1999–7 I.R.B.14
99–10, 1999–10 I.R.B. 10
99–11, 1999–10 I.R.B. 18
99–12, 1999–11 I.R.B. 6
99–13, 1999–10 I.R.B. 4
99–14, 1999–13 I.R.B. 3
99–15, 1999–12 I.R.B.4
99–16, 1999–13 I.R.B.5
99–17, 1999–14 I.R.B. 4
99–18, 1999–14 I.R.B. 3
99–19, 1999–15 I.R.B. 3
99–20, 1999–18 I.R.B.5
99–21, 1999–18 I.R.B. 3
Treasury Decisions:
8789, 1999–3 I.R.B. 5
8791, 1999–5 I.R.B. 7
8792, 1999–7 I.R.B.36
8793, 1999–7 I.R.B.15
8794, 1999–7 I.R.B.4
8795, 1999–7 I.R.B.8
8796, 1999–4 I.R.B. 16
8797, 1999–5 I.R.B. 5
8798, 1999–12 I.R.B. 16
8799, 1999–6 I.R.B. 10
8800, 1999–4 I.R.B. 20
8801, 1999–4 I.R.B. 5
8802, 1999–4 I.R.B. 10
8803, 1999–12 I.R.B. 15
8804, 1999–12 I.R.B. 5
8805, 1999–5 I.R.B. 14
8806, 1999–6 I.R.B.4
8807, 1999–9 I.R.B. 33
8808, 1999–10 I.R.B. 21
8809, 1999–7 I.R.B.27
8810, 1999–7 I.R.B.19
8811, 1999–10 I.R.B. 19
8812, 1999–8 I.R.B. 19
8813, 1999–9 I.R.B. 34
8814, 1999–9 I.R.B. 4
8815, 1999–9 I.R.B. 31
8816, 1999–8 I.R.B. 4
8817, 1999–8 I.R.B. 51
8818, 1999–17 I.R.B.3

May 10, 1999121999–19 I.R.B.
Finding List of Current Action on
Previously Published Items
1
Bulletins 1999–1 through 1999–18
Notices:
92–36
Modified by
Rev. Proc. 99–23, 1999–16 I.R.B. 5
96–64
Modified by
Rev. Proc. 99–23, 1999–16 I.R.B. 5
98–39
Modified by
Rev. Proc. 99–23, 1999–16 I.R.B. 5
98–52
Modified by
Rev. Proc. 99–23, 1999–16 I.R.B. 5
99–5
Modified by
Rev. Proc. 99–23, 1999–16 I.R.B. 5
Revenue Procedures:
78–10
Obsoleted by
99–12, 1999–3 I.R.B. 13
89–9
Modified by
99–23, 1999–16 I.R.B. 5
89–13
Modified by
99–23, 1999–16 I.R.B. 5
93–39, section 13
Modified by
99–23, 1999–16 I.R.B. 5
94–56
Superseded by
99–9, 1999–2 I.R.B. 17
95–12
Modified by
99–23, 1999–16 I.R.B. 5
97–23
Superseded by
99–3, 1999–1 I.R.B. 103
97–41
Modified by
99–23, 1999–16 I.R.B. 5
98–1
Superseded by
99–1, 1999–1 I.R.B. 6
98–2
Superseded by
99–2, 1999–1 I.R.B. 73
98–3
Superseded by
99–3, 1999–1 I.R.B. 103
98–4
Superseded by
99–4, 1999–1 I.R.B. 115
98–5
Superseded by
99–5, 1999–1 I.R.B. 158
Revenue Procedures—Continued
98–6
Superseded by
99–6, 1999–1 I.R.B. 187
98–7
Superseded by
99–7, 1999–1 I.R.B. 226
98–8
Superseded by
99–8, 1999–1 I.R.B. 229
98–14
Modified by
99–23, 1999–16 I.R.B. 5
98–22
Modified and amplified by
99–13, 1999–5 I.R.B. 52
98–28
Obsoleted by (except as provided in section 5.02 of)
99–22, 1999–15 I.R.B. 5
98–56
Superseded by
99–3, 1999–1 I.R.B. 103
98–63
Modified by announcement
99–7, 1999–2 I.R.B. 45
Revenue Rulings:
92–19
Supplemented in part by
99–10, 1999–10 I.R.B. 10
1
A cumulative finding list for previously published
items mentioned in Internal Revenue Bulletins
1998–1 through 1998–52 will be found in Internal
Revenue Bulletin 1999–1, dated January 4, 1999.

1999–19 I.R.B.13May 10, 1999
Notes

May 10, 1999141999–19 I.R.B.
Notes

INTERNAL REVENUE BULLETIN
The Introduction on page 3 describes the purpose and content of this publication. The weekly Internal Revenue Bulletin is sold
on a yearly subscription basis by the Superintendent of Documents. Current subscribers are notified by the Superintendent of
Documents when their subscriptions must be renewed.
CUMULATIVE BULLETINS
The contents of this weekly Bulletin are consolidated semiannually into a permanent, indexed, Cumulative Bulletin. These are
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ly Bulletin are notified when copies of the Cumulative Bulletin are available. Certain issues of Cumulative Bulletins are out of print
and are not available. Persons desiring available Cumulative Bulletins, which are listed on the reverse, may purchase them from the
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Check the publications and/or subscription(s) desired on the reverse, complete the order blank, enclose the proper remittance,
detach entire page, and mail to the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402. Please
allow two to six weeks, plus mailing time, for delivery.
WE WELCOME COMMENTS ABOUT THE
INTERNAL REVENUE BULLETIN
If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we
would be pleased to hear from you. You can e-mail us your suggestions or comments through the IRS Internet Home Page
(www.irs.ustreas.gov) or write to the IRS Bulletin Unit, OP:FS:FP:P:1, Room 5617, 1111 Constitution Avenue NW, Washington,
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