Internal Revenue Bulletin 2000-17 (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
Notice 2000–23, page 952.
Credit for producing fuel from a nonconventional
source, inflation adjustment factor, and reference price.
This notice publishes the nonconventional source fuel credit,
the inflation adjustment factor, and the reference price under
section 29 of the Code for calendar year 1999. This data is
used to determine the credit allowable on fuel produced from a
nonconventional source.
Notice 2000–26, page 954.
Methods of accounting; installment sales.This notice
provides guidance in a question and answer format on the
application of section 453(a)(2) of the Code to certain install-
ment sale transactions. The installment method does not
apply to income from an installment sale if the income would
be reported under an accrual method of accounting without
regard to section 453.
EMPLOYEE PLANS
Notice 2000–25, page 954.
Weighted average interest rate update.The weighted
average interest rate for April 2000 and the resulting per-
missible range of interest rates used to calculate current lia-
bility for purposes of the full funding limitation of section
412(c)(7) of the Code are set forth.
EXEMPT ORGANIZATIONS
Notice 2000–24, page 952.
Charitable split-dollar insurance.This notice provides
guidance to help charitable organizations comply with the in-
formation reporting requirements imposed by the Ticket to
Work and Work Incentives Improvement Act of 1999. The re-
quirements apply to charitable organizations that pay premi-
ums after February 8, 1999, in connection with certain life
insurance, annuity, and endowment contracts.
EXCISE TAX
Announcement 2000–43, page 957.
This document announces the acceptance of petitions re-
questing that nine polyether polyol substances be added to
the list of taxable substances in section 4672(a)(3) of the
Code.
ADMINISTRATIVE
Announcement 2000–44, page 958.
This document contains a correction to proposed regula-
tions (REG–103736–00, 2000–11 I.R.B. 768) relating to the
maintenance of lists of potentially abusive tax shelters de-
scribed in section 6112 of the Code.
Internal Revenue
bbuulllleettiinn
Bulletin No. 2000–17
April 24, 2000
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 ii.

April 24, 20002000–17 I.R.B.
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
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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.
The IRS Mission
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.
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 338.—Certain Stock
Purchases Treated as Asset
Acquisitions
26 CFR 1.338(h)(10)–1T: Deemed asset sale and
liquidation.
How does section 453(a)(2) of the Code, enacted
in 1999, apply to certain installment sale transac-
tions. See Notice 2000–26, page 954.
Section 1001.—Determination
of Amount of and Recognition of
Gain or Loss
26 CFR 1.1001–1: Computation of gain or loss.
How does section 453(a)(2) of the Code, enacted
in 1999, apply to certain installment sale transac-
tions. See Notice 2000–26, page 954.
2000–17 I.R.B.951April 24, 2000
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

Nonconventional Source Fuel
Credit, Section 29 Inflation
Adjustment Factor, and Section
29 Reference Price
Notice 2000–23
This notice publishes the nonconven-
tional source fuel credit, inflation adjust-
ment factor, and reference price under § 29
of the Internal Revenue Code for calendar
year 1999. These are used to determine the
credit allowable on fuel produced from a
nonconventional source under § 29 of the
Internal Revenue Code. The calendar year
1999 inflation-adjusted credit applies to the
sales of barrel-of-oil equivalent of qualified
fuels sold by a taxpayer to an unrelated per-
son during the 1999 calendar year, the do-
mestic production of which is attributable
to the taxpayer.
BACKGROUND
Section 29(a) provides for a credit for
producing fuel from a nonconventional
source, measured in barrel-of-oil equiva-
lent of qualified fuels, the production of
which is attributable to the taxpayer and
sold by the taxpayer to an unrelated per-
son during the tax year. The credit is
equal to the product of $3.00 and the ap-
propriate inflation adjustment factor.
Section 29(b)(1) and (2) provides for
a phaseout of the credit. The credit al-
lowable under § 29(a) must be reduced
by an amount which bears the same ratio
to the amount of the credit (determined
without regard to § 29(b)(1)) as the
amount by which the reference price for
the calendar year in which the sale oc-
curs exceeds $23.50 bears to $6.00. The
$3.00 in § 29(a) and the $23.50 and
$6.00 must each be adjusted by multi-
plying these amounts by the 1999 infla-
tion adjustment factor. In the case of
gas from a tight formation, the $3.00
amount in § 29(a) must not be adjusted.
Section 29(c)(1) defines the term
“qualified fuels” to include oil produced
from shale and tar sands; gas produced
from geopressurized brine, Devonian
shale, coal seams, or a tight formation, or
biomass; and liquid, gaseous, or solid
synthetic fuels produced from coal (in-
cluding lignite), including such fuels
when used as feedstocks.
Section 29(d)(1) provides that the
credit is to be applied only for sale of
qualified fuels the production of which is
within the United States (within the
meaning of § 638(1)) or a possession of
the United States (within the meaning of §
638(2)).
Section 29(d)(2)(A) requires that the
Secretary, not later than April 1 of each
calendar year, determine and publish in
the Federal Register the inflation adjust-
ment factor and the reference price for the
preceding calendar year.
Section 29(d)(2)(B) defines “inflation
adjustment factor” for a calendar year as
the fraction the numerator of which is the
GNP implicit price deflator for the calen-
dar year and the denominator of which is
the GNP implicit price deflator for calen-
dar year 1979. The term “GNP implicit
price deflator” means the first revision of
the implicit price deflator for the gross na-
tional product as computed and published
by the Department of Commerce.
Section 29(d)(2)(C) defines “reference
price” to mean with respect to a calendar
year the Secretary’s estimate of the annual
average wellhead price per barrel of all do-
mestic crude oil the price of which is not
subject to regulation by the United States.
Section 29(d)(3) provides that in the
case of a property or facility in which
more than one person has an interest, ex-
cept to the extent provided by regulations
prepared by the Secretary, production
from the property or facility (as the case
may be) must be allocated among the per-
sons in proportion to their respective in-
terests in the gross sales from the property
or facility.
Section 29(d)(5) and (6) provides that
the term “barrel-of-oil equivalent” with
respect to any fuel generally means that
amount of the fuel which has a Btu con-
tent of 5.8 million.
INFLATION ADJUSTMENT FACTOR
AND REFERENCE PRICE
The inflation factor is calculated using
GNP Implicit Price Deflators as com-
puted and published by the Department of
Commerce. The inflation factor for 1999,
which is smaller than the factor published
for 1998, reflects a comprehensive revi-
sion in 1999 of the national income and
product accounts by the Department of
Commerce. The inflation adjustment fac-
tor for calendar year 1999 is 2.0013. The
reference price for calendar year 1999 is
$15.56. As required by § 29(d)(2)(A), the
inflation adjustment factor and reference
price for calendar year 1999 were pub-
lished in the Federal Register on April 7,
2000 (65 Fed. Reg. 18429).
PHASE-OUT CALCULATION
Because the calendar year 1999 refer-
ence price does not exceed $23.50 multi-
plied by the inflation adjustment factor,
the phaseout of the credit provided for in
§ 29(b)(1) does not occur for any quali-
fied fuel sold in calendar year 1999.
CREDIT AMOUNT
The nonconventional source fuel credit
under § 29(a) is $6.00 per barrel-of-oil
equivalent of qualified fuels ($3.00 x
2.0013). This amount was published in
the Federal Register on April 7, 2000 (65
Fed. Reg. 18429).
DRAFTING INFORMATION
CONTACT
The principal author of this notice is
David McMunn of the Office of Assistant
Chief Counsel (Passthroughs and Special
Industries). For further information re-
garding this notice contact David Mc-
Munn or Alan H. Cooper at (202) 622-
3110 (not a toll-free call).
Charitable Split-Dollar Insurance
Reporting Requirements
Notice 2000–24
I. PURPOSE
This notice provides guidance to help
charitable organizations comply with the
information reporting requirements im-
posed by the Ticket to Work and Work In-
centives Improvement Act of 1999, Pub.
L. No. 106-170 (Dec. 17, 1999) (“Act”).
The reporting requirements apply to char-
itable organizations that pay premiums
after February 8, 1999, in connection with
certain life insurance, annuity, and en-
dowment contracts.
April 24, 20009522000–17 I.R.B.
Part III. Administrative, Procedural, and Miscellaneous

II. BACKGROUND
a. Overview.
Section 537 of the Act added §
170(f)(10) to the Internal Revenue Code.
Section 170(f)(10)(A) provides that, in
two circumstances, no charitable contri-
bution deduction is allowed under § 170,
545(b)(2), 556(b)(2), 642(c), 2055,
2106(a)(2), or 2522 for any transfer to, or
for the use of, an organization described
in § 170(c) or a charitable remainder trust
described in § 664(d) (such an organiza-
tion or trust is referred to herein as a
“charitable organization”). No charitable
contribution deduction is allowed if, in
connection with the transfer, (1) the chari-
table organization directly or indirectly
pays, or has previously paid, any pre-
mium on a personal benefit contract with
respect to the transferor, or (2) there is an
understanding or expectation that any per-
son will directly or indirectly pay any pre-
mium on a personal benefit contract with
respect to the transferor.
b. Personal Benefit Contract.
In general, § 170(f)(10)(B) defines a
“personal benefit contract” as any life in-
surance, annuity, or endowment contract
that benefits, directly or indirectly, the
transferor, a member of the transferor’s
family, or any other person designated by
the transferor (other than an organization
described in § 170(c)). Under §
170(f)(10)(D), a person receiving pay-
ments under a charitable gift annuity (as
defined in § 501(m)) funded by an annuity
contract purchased by a charitable organi-
zation is not treated as an indirect benefi-
ciary of a personal benefit contract if the
timing and amount of the payments under
the annuity contract are substantially the
same as the charitable organization’s
obligations under the charitable gift annu-
ity. For this exception to apply, the chari-
table organization must possess all the in-
cidents of ownership and be entitled to all
the payments under the annuity contract.
III. REPORTING AND EXCISE TAX
REQUIREMENTS
Section 170(f)(10)(F) requires any
charitable organization that pays premi-
ums on a personal benefit contract in con-
nection with a transfer for which a deduc-
tion is not allowed under § 170(f)(10)(A)
to pay an excise tax and to report certain
information related to the premium pay-
ments.
a. Form 4720 — Excise Tax Return
Section 170(f)(10)(F)(i) imposes on a
charitable organization an excise tax
equal to the premiums paid by the organi-
zation after December 17, 1999, on any
personal benefit contract, if the payment
of premiums is in connection with a trans-
fer for which a deduction is not allowed
under § 170(f)(10)(A). For purposes of
this excise tax, § 170(f)(10)(F)(ii) pro-
vides that premium payments made by
any other person pursuant to an under-
standing or expectation described in §
170(f)(10)(A) are treated as made by the
charitable organization.
A charitable organization liable for ex-
cise taxes under § 170(f)(10)(F)(i), must
file a return on Form 4720, Return of Cer-
tain Excise Tax on Charities and Other
Persons Under Chapters 41 and 42 of the
Internal Revenue Code, to report and pay
the taxes due. The charitable organization
must include the amount of the §
170(f)(10)(F) tax on line 8 of Part I and
should write in the amount of the §
170(f)(10)(F) tax, preceded by “Sec
170(f)(10)(F)” on the dotted line to the
left of the entry space for line 8 of the
1999 Form 4720. The Service will revise
Form 4720 for taxable years beginning
after December 31, 1999.
Some charitable organizations may not
yet be aware of this new excise tax re-
quirement. Therefore, this Notice extends
the due dates for the 1999 Form 4720
only with respect to the § 170(f)(10)(F)
tax as follows. For a taxable year begin-
ning prior to January 1, 2000, a charitable
organization liable for the § 170(f)(10)(F)
tax must report and pay that tax on a Form
4720 filed by the later of July 24, 2000 or
the regular due date specified in §
53.6071–1 of the Procedure and Adminis-
tration Regulations. For a charitable or-
ganization, other than a charitable re-
mainder trust described in § 664(d), the
regular due date for filing Form 4720 oc-
curs on the fifteenth day of the fifth
month following the close of the organi-
zation’s taxable year. For a charitable re-
mainder trust, the regular due date for fil-
ing Form 4720 occurs on the fifteenth day
of the fourth month following the close of
the trust’s tax year. Charitable organiza-
tions that are required to report items
other than the § 170(f)(10)(F) tax must re-
port those items on a 1999 Form 4720
filed by the regular due date. A charitable
organization may request an extension of
time to file Form 4720 by filing Form
2758, Application for Extension of Time
to File Certain Excise, Income, Informa-
tion, and Other Returns, on or before the
due date of the return.
If a 1999 Form 4720 reporting the §
170(f)(10)(F) tax is filed and the tax is
paid by the later of July 24, 2000 or the
regular due date specified in § 53.6071–1,
the Service will not assess penalties under
§ 6651 for failure to file a tax return or to
pay the tax required under §
170(f)(10)(F). The law does not, how-
ever, permit the Service to waive the in-
terest due under § 6601. Section 6601 re-
quires that taxpayers pay interest from the
last date prescribed for payment of the tax
(determined without regard to any exten-
sion of time for payment) to the date the
taxes are paid.
b. Form 8870 — Information Return
Required By § 170(f)(10)(F)(iii)
Section 170(f)(10)(F)(iii) requires
charitable organizations to report annu-
ally (1) the amount of premiums paid dur-
ing the year which are subject to the tax
under § 170(f)(10)(F) (to be determined
in the case of premiums paid after Febru-
ary 8, 1999 and before December 18,
1999 as if the excise tax applied to premi-
ums paid during that period); (2) the name
and taxpayer identification number
(“TIN”) of each beneficiary under each
contract to which the premiums relate;
and (3) any other information the Secre-
tary may require. Section
170(f)(10)(F)(iii) makes returns required
by § 170(f)(10)(F)(iii) subject to the
penalties applicable to returns filed under
§ 6033.
The Internal Revenue Service expects to
issue a new form, Form 8870, Information
Return for Transfers Associated with Per-
sonal Benefit Contracts (Under section
170(f)(10)), for reporting the information
required by § 170(f)(10)(F)(iii). For a tax-
able year beginning prior to January 1,
2000, a charitable organization that paid
any such premiums during the taxable year
must file Form 8870 by the later of 90 days
after the date of the Service’s announce-
ment in the Internal Revenue Bulletin of
2000–17 I.R.B.953April 24, 2000

April 24, 20009542000–17 I.R.B.
the availability of Form 8870, or the date
the charitable organization is required to
file its annual information return under §
1.6033–2(e) or § 53.6071–1(c), as applica-
ble. The Service expects to publish the an-
nouncement by May 15, 2000. Section
1.6033–2(e) requires a charitable organiza-
tion, other than a charitable remainder trust
described in § 664(d), to file its annual in-
formation return by the fifteenth day of the
fifth month following the close of the chari-
table organization’s taxable year. Section
53.6071–1(c) requires a charitable remain-
der trust to file its annual information return
by the fifteenth day of the fourth month fol-
lowing the close of the trust’s taxable year.
A charitable organization, including a char-
itable remainder trust, may obtain an exten-
sion of time to file Form 8870 by filing
Form 2758 on or before the due date of the
return, stating on line 4 of Form 2758 that it
is requesting an extension to file Form
8870 pursuant to this notice. For any tax-
able year beginning after December 31,
1999, Form 8870 will be due on the date
the charitable organization is required to
file its annual information return.
c. Forms 990, 990-PF, and 5227 — In-
formation Returns By Charitable Organi-
zations
Section 6033 requires most charitable or-
ganizations to file annual information re-
turns with the Service. Generally, an orga-
nization described in § 170(c) files either
Form 990, Return of Organization Exempt
From Income Tax, or Form 990-PF, Return
of Private Foundation or Section
4947(a)(1) Nonexempt Charitable Trust
Treated as a Private Foundation. The regu-
lations under § 6011 require a split-interest
trust described in § 4947(a)(2), including a
charitable remainder trust described in §
664(d), to file Form 5227, Split-Interest
Trust Information Return. Form 5227 is
used by a split-interest trust to report its fi-
nancial activities and whether it is subject
to excise taxes under Chapter 42 of the
Code. The Service will revise Forms 990,
990-PF, and 5227 for taxable years begin-
ning after December 31, 1999, to add ques-
tions relating to charitable split-dollar in-
surance arrangements described in §
170(f)(10)(F).
DRAFTING INFORMATION
The principal author of this notice is
Michael B. Blumenfeld of the Office of
Associate Chief Counsel (Employee Ben-
efits & Exempt Organizations). For fur-
ther information regarding this notice
contact Mr. Blumenfeld at (202) 622-
6070 (not a toll-free call).
Weighted Average Interest Rate
Update
Notice 2000–25
Notice 88–73 provides guidelines for de-
termining the weighted average interest
rate and the resulting permissible range of
interest rates used to calculate current lia-
bility for the purpose of the full funding
limitation of § 412(c)(7) of the Internal
Revenue Code as amended by the Omnibus
Budget Reconciliation Act of 1987 and as
further amended by the Uruguay Round
Agreements Act, Pub. L. 103-465 (GATT).
The average yield on the 30-year Trea-
sury Constant Maturities for March 2000
is 6.05 percent.
The following rates were determined
for the plan years beginning in the month
shown below.
90% to 105%90% to 110%
WeightedPermissiblePermissible
MonthYearAverageRangeRange
April20006.035.43 to 6.335.43 to 6.64
Drafting Information
The principal author of this notice is
Todd Newman of the Employee Plans,
Tax Exempt and Government Entities Di-
vision. For further information regarding
this notice, call the Employee Plans Actu-
arial hotline, (202) 622-6076 between
2:30 and 3:30 p.m. Eastern time (not a
toll-free number). Mr. Newman’s number
is (202) 622-8458 (also not a toll-free
number).
Installment Sales by Accrual
Method Taxpayers
Notice 2000–26
PURPOSE
This notice provides guidance in a
question and answer format on the appli-
cation of § 453(a)(2) of the Internal Rev-
enue Code to certain installment sale
transactions.
BACKGROUND
An installment sale is defined in § 453(b)
to mean generally a disposition of property
where at least one payment is to be re-
ceived after the close of the taxable year in
which the disposition occurs. Section
453(a)(1) provides the general rule that in-
come from an installment sale must be
taken into account under the installment
method. An exception to this rule is set
forth in § 453(a)(2), which provides gener-
ally that the installment method does not
apply to income from an installment sale if
the income would be reported under an ac-
crual method of accounting without regard
to § 453. Section 453(a)(2) was added by §
536 of the Ticket to Work and Work Incen-
tives Improvement Act of 1999, Pub. L.
No. 106-170, 113 Stat. 1860 (1999), and is
effective for sales or other dispositions oc-
curring on or after December 17, 1999, the
date of enactment. Section 453(a)(2) does
not affect the ability of a taxpayer using the
cash receipts and disbursements method of
accounting to use the installment method.
QUESTIONS AND ANSWERS
The following questions and answers
provide guidance on the application of §
453(a)(2) to certain installment sale trans-

2000–17 I.R.B.955April 24, 2000
actions. Depending on the facts and cir-
cumstances of a particular transaction,
taxpayers also should consider the applic-
ability of § 453A, which in certain cir-
cumstances imposes an interest charge on
the tax liability that is deferred through
use of the installment method.
Corporations
For each question and answer assume
the shareholder uses the cash receipts and
disbursements method of accounting and
the corporation uses an accrual method of
accounting. Also assume the stock of the
corporation is not traded on an established
securities market. Except as otherwise in-
dicated, the term “corporation” refers to
either an S corporation or a C corporation.
Q-1: Can the shareholder report on the
installment method the gain arising from
a sale of the shareholder’s stock in the
corporation in exchange for cash and an
installment obligation?
A-1: The shareholder can report the
gain from the sale of the stock on the in-
stallment method.
Q-2: Can the corporation report on the
installment method the gain arising from a
sale of the corporation’s assets in exchange
for cash and an installment obligation?
A-2: The corporation cannot report the
gain from the sale of its assets on the in-
stallment method. See§ 453(a)(2).
Q-3: What is the effect on the transac-
tion described in Q&A:1 above if the
buyer makes an election under § 338(g) (a
“§ 338 election”) for the corporation?
A-3: The shareholder is not affected
and can report the gain from the sale of
the stock on the installment method. The
corporation cannot report the gain from
the deemed sale of assets on the install-
ment method. See§ 453(a)(2).
Q-4: What is the effect on the transac-
tion described in Q&A:1 above if the
shareholder is a corporation and the buyer
and the corporate shareholder join in
making a § 338(h)(10) election for the tar-
get corporation, a C corporation, which is
either the corporate shareholder’s affiliate
or a member of its consolidated group?
A-4: The corporate shareholder recog-
nizes no gain or loss on the sale of the tar-
get corporation’s stock. See§
1.338(h)(10)–1T(d)(5)(iii) of the tempo-
rary Income Tax Regulations. The target
corporation cannot report the gain from
the deemed sale of assets on the install-
ment method. See§ 453(a)(2). The cor-
porate shareholder generally recognizes
no gain or loss on the deemed transfer of
the target corporation’s assets (including
the installment obligation) to the corpo-
rate shareholder because, in most circum-
stances, the transfer would qualify as a
distribution in complete liquidation to
which § 332 applies. See§
1.338(h)(10)–1T(d)(5)(i).
Q-5: What is the effect on the transac-
tion described in Q&A:1 above if the
buyer and the shareholder join in making
a § 338(h)(10) election for the corpora-
tion, an S corporation?
A-5: The shareholder recognizes no gain
or loss on the sale of the S corporation’s
stock. See§ 1.338(h)(10)–1T(d)(5)(iii).
The S corporation cannot report the gain
from the deemed sale of assets on the in-
stallment method. See§ 453(a)(2). The
shareholder may realize gain or loss on the
deemed transfer of the S corporation’s as-
sets (including the installment obligation)
to the shareholder, after taking into account
the effect of the deemed sale of the assets.
See§ 1.338(h)(10)–1T(d)(5)(i). The share-
holder can report on the installment method
the gain, if any, arising from this deemed
transfer. See§ 453(h); §§ 1.453–11(a)(2)
and 1.338(h)(10)–1T(d)(8).
Q-6: What is the effect on the transac-
tion described in Q&A:2 above if the cor-
poration, a C corporation, distributes the
note to a shareholder in a liquidation that
meets the requirements of § 453(h)?
A-6: The C corporation must recog-
nize any gain or loss upon the distribution
of the note. See§ 453B(a). The share-
holder can report on the installment
method the gain arising from the ex-
change of the shareholder’s stock for the
note. See§ 1.453–11(a)(2).
Q-7: What is the effect on the transac-
tion described in Q&A:2 above if the cor-
poration, an S corporation, distributes the
note to a shareholder in a liquidation that
meets the requirements of § 453(h)?
A-7: Except for taxes imposed by sub-
chapter S (e.g., §§ 1374 and 1375), the S
corporation does not recognize gain or
loss upon the distribution of the note. See
§ 453B(h). The shareholder can report on
the installment method the gain, if any,
arising from the exchange of the share-
holder’s stock for the note. See§
1.453–11(a)(2).
Partnerships
For each question and answer assume
the partner uses the cash receipts and dis-
bursements method of accounting and the
partnership uses an accrual method of ac-
counting.
Q-8: Can the partner report on the in-
stallment method the gain arising from a
sale of an interest in the partnership in ex-
change for cash and an installment obliga-
tion?
A-8: If the sale otherwise qualifies for
installment method reporting, the partner
is not precluded by § 453(a)(2) from re-
porting on the installment method the
gain arising from the sale of the partner-
ship interest. But see, e.g., § 453(i)(2)
and Rev. Rul. 89–108, 1989–2 C.B. 100.
Q-9: Can the partnership report on the
installment method the gain arising from
a sale of the partnership’s assets in ex-
change for cash and an installment obliga-
tion?
A-9: The partnership cannot report the
gain from the sale of its assets on the in-
stallment method. See§ 453(a)(2).
Treatment of Sales Not Eligible for the
Installment Method
Q-10: How does a taxpayer take into ac-
count an installment obligation received in
an installment sale transaction that is not el-
igible for the installment method for any
reason, including § 453(a)(2)?
A-10: The taxpayer generally must
recognize the entire amount of the gain
from the installment sale in the year of the
sale. See§ 1001(c). Section 1.1001–1(a)
or § 1.1001–1(g), whichever is applica-
ble, will determine the amount of gain
that is realized by the taxpayer attribut-
able to an installment obligation issued in
exchange for property when the income
from the exchange is not eligible to be re-
ported on the installment method. See
also§§ 483 and 1271 through 1275, and
the underlying regulations, to determine if
the installment obligation has either un-
stated interest or original issue discount.
Q-11: If an installment obligation pro-
viding for one or more contingent pay-
ments is issued in the installment sale
transaction described in Q&A:10 above,
can the taxpayer use the “open transac-
tion” method to report the gain from the
transaction? See, e.g., Burnet v. Logan,
283 U.S. 404 (1931).

April 24, 20009562000–17 I.R.B.
A-11: In general, the taxpayer cannot
use the “open transaction” method to report
the gain from the installment sale transac-
tion. Only in those rare and extraordinary
cases in which the fair market value of the
obligation cannot reasonably be ascertained
can a taxpayer use the “open transaction”
method to report the gain from the transac-
tion. See§ 1.1001–1(a) or § 1.1001–1(g).
See also § 1.483–4 or § 1.1275–4,
whichever is applicable, for rules concern-
ing the taxpayer’s treatment of the install-
ment obligation.
DRAFTING INFORMATION
The principal author of this notice is
Kimberly L. Koch of the Office of Assis-
tant Chief Counsel (Income Tax and Ac-
counting). For further information re-
garding a § 338 election or a § 338(h)(10)
election made in connection with an in-
stallment sale transaction, contact Victor
Penico on (202) 622-7790 (not a toll-free
call). For further information regarding
the rest of this notice, contact Ms. Koch
on (202) 622-4950 (not a toll-free call).

Tax on Certain Imported
Substances; Filing of Petitions
Announcement 2000–43
This announces the acceptance, under
Notice 89–61 (1989–1 C.B. 717), of peti-
tions requesting that nine polyether polyol
substances be added to the list of taxable
substances in § 4672(a)(3). Publication
of this notice is in compliance with Notice
89–61. This is not a determination that
the list of taxable substances should be
modified. Any modification of the list of
taxable substances based upon these peti-
tions would be effective October 1, 1992.
Before a determination is made, con-
sideration will be given to any written and
electronic comments that are submitted
timely to the IRS. Comments and re-
quests for a public hearing relating to
these petitions must be received by May
15, 2000. Send submissions to:
CC:DOM:CORP:R (Petition), room
5226, Internal Revenue Service, POB
7604, Ben Franklin Station, Washington,
DC 20044. Submissions may be hand de-
livered Monday through Friday between
the hours of 8 a.m. and 5 p.m. to:
CC:DOM:CORP:R (Petition), Courier’s
Desk, Internal Revenue Service, 1111
Constitution Avenue NW., Washington,
DC. Alternatively, taxpayers may send
submissions electronically to the IRS at
Sharon.Y.Horn@m1.irscounsel.treas.gov.
All comments will be available for public
inspection and copying. A public hearing
may be scheduled if requested in writing
by a person that timely submits written or
electronic comments. If a public hearing
is scheduled, notice of the date, time, and
place for the hearing will be published in
the Federal Register.
The petitions were received on Novem-
ber 21, 1991. The petitioner is Dow
Chemical Company, a manufacturer and
exporter of these substances. The follow-
ing is a summary of the information con-
tained in the petitions. The complete peti-
tions are available in the Internal Revenue
Service Freedom of Information Reading
Room.
The nine polyether polyol substances
are liquids. They are produced predomi-
nantly by the base-catalyzed reaction of
cyclic ethers, usually ethylene oxide and
propylene oxide, with active hydrogen-
containing compounds (initiators) such as
water, glycols, polyols, and amines. The
reaction is carried out by a discontinuous
batch process at elevated temperatures
and pressures and under an inert atmos-
phere. The particular substance produced
depends upon the oxides, initiators, reac-
tion conditions, and catalysts used. The
stoichiometric amounts of oxide reacted
on the initiator determine the chain
lengths and thus the molecular weights.
HTS number: 3907.20.00
Poly(propylene)glycol
CAS number: 025322–69–4
Poly(propylene)glycol is derived from
the taxable chemicals propylene, chlorine,
and sodium hydroxide.
The stoichiometric material consump-
tion formula for this substance is:
n+1(C
3
H
6
(propylene) + Cl
2
(chlorine) + 2
NaOH (sodium hydroxide)) + H
2
O (water)
ÕC
3
H
8
O
2
(C
3
H
6
O)
n
(poly(propylene)gly-
col) + n+1(2 NaCl (sodium chloride) +
H
2
O (water))
According to the petition, taxable
chemicals constitute at least 90 percent by
weight of the materials used to produce
this substance. The rate of tax for this
substance would be $7.74 per ton. This is
based upon a conversion factor for propy-
lene of 0.781, a conversion factor for
chlorine of 1.31, and a conversion factor
for sodium hydroxide of 1.43.
Poly(propylene/ethylene)glycol
CAS number: 053637–25–5
Poly(propylene/ethylene)glycol is de-
rived from the taxable chemicals propy-
lene, chlorine, sodium hydroxide, and
ethylene.
The stoichiometric material consump-
tion formula for this substance is:
n+1(C
3
H
6
(propylene) + Cl
2
(chlorine) +
2 NaOH (sodium hydroxide)) + H
2
O
(water) + m/2(2 C
2
H
4
(ethylene) + O
2
(oxygen)) ÕC
3
H
8
O
2
(C
3
H
6
O)
n
(C
2
H
4
O)
m
(poly(propylene/ethylene)glycol) + n+1(2
NaCl (sodium chloride) + H
2
O (water))
According to the petition, taxable
chemicals constitute at least 90 percent by
weight of the materials used to produce
this substance. The rate of tax for this
substance would be $7.16 per ton. This is
based upon a conversion factor for propy-
lene of 0.663, a conversion factor for
chlorine of 1.11, a conversion factor for
sodium hydroxide of 1.21, and a conver-
sion factor for ethylene of 0.123.
Poly(propyleneoxy)glycerol
CAS number: 025791–96–2
Poly(propyleneoxy)glycerol is derived
from the taxable chemicals propylene,
chlorine, and sodium hydroxide.
The stoichiometric material consump-
tion formula for this substance is: C
3
H
8
O
3
(glycerine) + n(C
3
H
6
(propylene) + Cl
2
(chlorine) + 2 NaOH (sodium hydroxide))
ÕC
3
H
8
O
3
(C
3
H
6
O)
n
(poly(propyle-
neoxy)glycerol) + n(2 NaCl (sodium
chloride) + H
2
O (water))
According to the petition, taxable
chemicals constitute at least 85 percent by
weight of the materials used to produce
this substance. The rate of tax for this
substance would be $6.38 per ton. This is
based upon a conversion factor for propy-
lene of 0.645, a conversion factor for
chlorine of 1.08, and a conversion factor
for sodium hydroxide of 1.18.
Poly(ethyleneoxy)glycerol
CAS number: 031694–55–0
Poly(ethyleneoxy)glycerol is derived
from the taxable chemical ethylene.
The stoichiometric material consump-
tion formula for this substance is: C
3
H
8
O
3
(glycerine) + m/2(2 C
2
H
4
(ethylene) + O
2
(oxygen)) ÕC
3
H
8
O
3
(C
2
H
4
O)
m
(poly(eth-
yleneoxy)glycerol)
According to the petition, taxable
chemicals constitute more than 50 percent
by weight of the materials used to pro-
duce this substance. The rate of tax for
this substance would be $3.31 per ton.
This is based upon a conversion factor for
ethylene of 0.681.
Poly(propyleneoxy/ethyleneoxy)glycerol
CAS number: 009082–00–2
Poly(propyleneoxy/ethyleneoxy)glyc-
erol is derived from the taxable chemicals
propylene, chlorine, sodium hydroxide,
and ethylene.
The stoichiometric material consump-
tion formula for this substance is: C
3
H
8
O
3
(glycerine) + n(C
3
H
6
(propylene) + Cl
2
(chlorine) + 2 NaOH (sodium hydroxide))
2000–17 I.R.B.957April 24, 2000
Part IV. Items of General Interest

+ m/2(2 C
2
H
4
(ethylene) + O
2
(oxygen)) Õ
C
3
H
8
O
3
(C
3
H
6
O)
n
(C
2
H
4
O)
m
(poly(propyle-
neoxy/ethyleneoxy)glycerol) + n(2 NaCl
(sodium chloride) + H
2
O (water))
According to the petition, taxable
chemicals constitute at least 85 percent by
weight of the materials used to produce
this substance. The rate of tax for this
substance would be $7.20 per ton. This is
based upon a conversion factor for propy-
lene of 0.71, a conversion factor for chlo-
rine of 1.05, a conversion factor for
sodium hydroxide of 1.05, and a conver-
sion factor for ethylene of 0.126.
Poly(propyleneoxy)sucrose
CAS number: 009049–71–2
Poly(propyleneoxy)sucrose is derived
from the taxable chemicals propylene,
chlorine, and sodium hydroxide.
The stoichiometric material consump-
tion formula for this substance is:
C
12
H
22
O
11
(sucrose) + n(C
3
H
6
(propy-
lene) + Cl
2
(chlorine) + 2 NaOH (sodium
hydroxide)) ÕC
12
H
22
O
11
(C
3
H
6
O)
n
(poly(propyleneoxy)sucrose) + n(2 NaCl
(sodium chloride) + H
2
O (water))
According to the petition, taxable
chemicals constitute at least 65 percent by
weight of the materials used to produce
this substance. The rate of tax for this
substance would be $4.18 per ton. This is
based upon a conversion factor for propy-
lene of 0.423, a conversion factor for
chlorine of 0.707, and a conversion factor
for sodium hydroxide of 0.773.
Poly(propyleneoxy/ethyleneoxy)sucrose
CAS number: 026301–10–0
Poly(propyleneoxy/ethyleneoxy)su-
crose is derived from the taxable chemi-
cals propylene, chlorine, sodium hydrox-
ide, and ethylene.
The stoichiometric material consumption
formula for this substance is: C
12
H
22
O
11
(su-
crose) + n(C
3
H
6
(propylene) + Cl
2
(chlorine)
+ 2 NaOH (sodium hydroxide)) + m/2(2
C
2
H
4
(ethylene) + O
2
(oxygen)) Õ
C
12
H
22
O
11
(C
3
H
6
O)
n
(C
2
H
4
O)
m
(poly(propy-
leneoxy/ethyleneoxy)sucrose) + n(2 NaCl
(sodium chloride) + H
2
O (water))
According to the petition, taxable
chemicals constitute at least 75 percent by
weight of the materials used to produce
this substance. The rate of tax for this
substance would be $6.11 per ton. This is
based upon a conversion factor for propy-
lene of 0.549, a conversion factor for
chlorine of 0.918, a conversion factor for
sodium hydroxide of 1.0, and a conver-
sion factor for ethylene of 0.14.
Poly(propyleneoxy/ethyleneoxy)diamine
CAS number: 031568–06–6
Poly(propyleneoxy/ethyleneoxy)diamine
is derived from the taxable chemicals propy-
lene, chlorine, and sodium hydroxide.
The stoichiometric material consump-
tion formula for this substance is:
C
4
H
12
N
2
O (aminoethylethanolamine) +
n(C
3
H
6
(propylene) + Cl
2
(chlorine) + 2
NaOH (sodium hydroxide)) Õ
C
4
H
12
N
2
O(C
3
H
6
O)
n
(poly(propyleneoxy/
ethyleneoxy)diamine) + n(2 NaCl (sodium
chloride) + H
2
O (water))
According to the petition, taxable
chemicals constitute at least 60 percent by
weight of the materials used to produce
this substance. The rate of tax for this
substance would be $4.92 per ton. This is
based upon a conversion factor for propy-
lene of 0.498, a conversion factor for
chlorine of 0.833, and a conversion factor
for sodium hydroxide of 0.91.
Poly(propyleneoxy/ethyleneoxy)benzen
ediamine
CAS number: 067800–94–6
Poly(propyleneoxy/ethyleneoxy)ben-
zenediamine is derived from the taxable
chemicals propylene, chlorine, sodium
hydroxide, and ethylene.
The stoichiometric material consump-
tion formula for this substance is: C
7
H
10
N
2
(ortho-toluenediamine) + n(C
3
H
6
(propy-
lene) + Cl
2
(chlorine) + 2 NaOH (sodium
hydroxide)) + m/2(2 C
2
H
4
(ethylene) + O
2
(oxygen)) ÕC
7
H
10
N
2
(C
3
H
6
O)
n
(C
2
H
4
O)
m
(poly(propyleneoxy/ethyleneoxy)benzene-
diamine) + n(2 NaCl (sodium chloride) +
H
2
O (water))
According to the petition, taxable
chemicals constitute at least 60 percent by
weight of the materials used to produce
this substance. The rate of tax for this
substance would be $5.25 per ton. This is
based upon a conversion factor for propy-
lene of 0.491, a conversion factor for
chlorine of 0.821, a conversion factor for
sodium hydroxide of 0.897, and a conver-
sion factor for ethylene of 0.081.
The principal author of this announce-
ment is Ruth Hoffman, Office of Assistant
Chief Counsel (Passthroughs and Special
Industries). For further information re-
garding this announcement contact Ruth
Hoffman on (202) 622-3130 (not a toll-
free number).
Requirement to Maintain List of
Investors in Potentially Abusive
Tax Shelters; Correction
Announcement 2000–44
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Correction to cross-reference
notice of proposed rulemaking and notice
of public hearing.
SUMMARY: This document contains a
correction to a notice of proposed rule-
making and notice of public hearing
(REG–103736–00, 2000–11 I.R.B. 768),
which were published in the Federal
Registeron Thursday, March 2, 2000 (65
FR 11271), relating to the maintenance of
lists of potentially abusive tax shelters de-
scribed in section 6112.
FOR FURTHER INFORMATION CON-
TACT: Guy Traynor at (202) 622-7180.
SUPPLEMENTARY INFORMATION:
Background
The regulations that are subject to this
correction are under section 6112 of the
Internal Revenue Code.
Need for Correction
As published, the regulations
[REG–103736–00] contain an error in the
preamble that may prove to be misleading
and is in need of clarification.
Correction of Publication
Accordingly, the publication of the notice
of proposed rulemaking [REG–103736–00],
which was the subject of FR Doc. 00–4847,
is corrected as follows:
1. On page 1272, column 2, fifth line
from the top of the column, the language
“June 22, 2000,” is corrected to read
“June 20, 2000,”.
Dale D. Goode,
Federal Register Liaison,
Assistant Chief Counsel (Corporate).
(Filed by the Office of the Federal Register on April
3, 2000, 8:45 a.m., and published in the issue of the
Federal Register on April 4, 2000, 65 F.R. 17617)
April 24, 20009582000–17 I.R.B.

2000–17 I.R.B.iApril 24, 2000
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe 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

April 24, 2000ii2000–17 I.R.B.
Numerical Finding List
1
Bulletins 2000–1 through 2000–16
Announcements:
2000–1, 2000–2 I.R.B. 294
2000–2, 2000–2 I.R.B. 295
2000–3, 2000–2 I.R.B. 296
2000–4, 2000–3 I.R.B. 317
2000–5, 2000–4 I.R.B. 427
2000–6, 2000–4 I.R.B. 428
2000–7, 2000–6 I.R.B. 586
2000–8, 2000–6 I.R.B. 586
2000–9, 2000–9 I.R.B. 733
2000–10, 2000–9 I.R.B. 733
2000–11, 2000–10 I.R.B. 739
2000–12, 2000–12 I.R.B. 835
2000–13, 2000–11 I.R.B. 771
2000–14, 2000–11 I.R.B. 772
2000–15, 2000–12 I.R.B. 837
2000–16, 2000–12 I.R.B. 837
2000–17, 2000–13 I.R.B. 846
2000–18, 2000–13 I.R.B. 846
2000–24, 2000–14 I.R.B. 855
2000–25, 2000–14 I.R.B. 855
2000–26, 2000–15 I.R.B. 876
2000–27, 2000–15 I.R.B. 876
2000–28, 2000–15 I.R.B. 876
2000–29, 2000–15 I.R.B. 877
2000–30, 2000–15 I.R.B. 877
2000–31, 2000–15 I.R.B. 877
2000–32, 2000–15 I.R.B. 879
2000–33, 2000–15 I.R.B. 878
2000–34, 2000–15 I.R.B. 879
2000–35, 2000–16 I.R.B. 922
2000–36, 2000–16 I.R.B. 947
2000–37, 2000–16 I.R.B. 947
2000–38, 2000–16 I.R.B. 948
2000–39, 2000–16 I.R.B. 948
2000–40, 2000–16 I.R.B. 948
2000–41, 2000–16 I.R.B. 949
2000–42, 2000–16 I.R.B. 949
Court Decisions:
2066, 2000–15 I.R.B. 867
2067, 2000–15 I.R.B. 863
Notices:
2000–1, 2000–2 I.R.B. 288
2000–2, 2000–9 I.R.B. 727
2000–3, 2000–4 I.R.B. 413
2000–4, 2000–3 I.R.B. 313
2000–5, 2000–3 I.R.B. 314
2000–6, 2000–3 I.R.B. 315
2000–7, 2000–4 I.R.B. 419
2000–8, 2000–4 I.R.B. 420
2000–9, 2000–5 I.R.B. 449
2000–10, 2000–5 I.R.B. 451
2000–11, 2000–6 I.R.B. 572
2000–12, 2000–9 I.R.B. 727
2000–13, 2000–9 I.R.B. 732
2000–14, 2000–10 I.R.B. 737
2000–15, 2000–12 I.R.B. 826
2000–16, 2000–12 I.R.B. 826
2000–17, 2000–12 I.R.B. 827
2000–18, 2000–13 I.R.B. 845
Notices—continued:
2000–19, 2000–13 I.R.B. 845
2000–20, 2000–14 I.R.B. 851
2000–22, 2000–16 I.R.B. 902
Proposed Regulations:
REG–208280–86, 2000–8 I.R.B. 654
REG–209135–88, 2000–8 I.R.B. 681
REG–208254–90, 2000–6 I.R.B. 577
REG–209601–92, 2000–12 I.R.B. 829
REG–100276–97, 2000–8 I.R.B. 682
REG–101492–98, 2000–3 I.R.B. 326
REG–106012–98, 2000–2 I.R.B. 290
REG–109101–98, 2000–16 I.R.B. 903
REG–110311–98, 2000–11 I.R.B. 767
REG–103831–99, 2000–5 I.R.B. 452
REG–103882–99, 2000–8 I.R.B. 706
REG–105089–99, 2000–6 I.R.B. 580
REG–105279–99, 2000–8 I.R.B. 707
REG–105606–99, 2000–4 I.R.B. 421
REG–107872–99, 2000–16 I.R.B. 911
REG–111119–99, 2000–5 I.R.B. 455
REG–113572–99, 2000–7 I.R.B. 624
REG–116048–99, 2000–6 I.R.B. 584
REG–116567–99, 2000–5 I.R.B. 463
REG–116704–99, 2000–3 I.R.B. 325
REG–117162–99, 2000–15 I.R.B. 871
REG–100163–00, 2000–7 I.R.B. 633
REG–100291–00, 2000–16 I.R.B. 917
REG–103735–00, 2000–11 I.R.B. 770
REG–103736–00, 2000–11 I.R.B. 768
Railroad Retirement Quarterly Rate:
2000–9 I.R.B. 721
Revenue Procedures:
2000–1, 2000–1 I.R.B. 4
2000–2, 2000–1 I.R.B. 73
2000–3, 2000–1 I.R.B. 103
2000–4, 2000–1 I.R.B. 115
2000–5, 2000–1 I.R.B. 158
2000–6, 2000–1 I.R.B. 187
2000–7, 2000–1 I.R.B. 227
2000–8, 2000–1 I.R.B. 230
2000–9, 2000–2 I.R.B. 280
2000–10, 2000–2 I.R.B. 287
2000–11, 2000–3 I.R.B. 309
2000–12, 2000–4 I.R.B. 387
2000–13, 2000–6 I.R.B. 515
2000–15, 2000–5 I.R.B. 447
2000–16, 2000–6 I.R.B. 518
2000–17, 2000–11 I.R.B. 766
2000–18, 2000–9 I.R.B. 722
2000–19, 2000–12 I.R.B. 785
2000–20, 2000–6 I.R.B. 553
Revenue Rulings:
2000–1, 2000–2 I.R.B. 250
2000–2, 2000–3 I.R.B. 305
2000–3, 2000–3 I.R.B. 297
2000–4, 2000–4 I.R.B. 331
2000–5, 2000–5 I.R.B. 436
2000–6, 2000–6 I.R.B. 512
2000–7, 2000–9 I.R.B. 712
2000–8, 2000–7 I.R.B. 617
2000–9, 2000–6 I.R.B. 497
Revenue Rulings—continued:
2000–10, 2000–8 I.R.B. 643
2000–11, 2000–10 I.R.B. 734
2000–12, 2000–11 I.R.B. 744
2000–13, 2000–12 I.R.B. 774
2000–14, 2000–12 I.R.B. 779
2000–15, 2000–12 I.R.B. 774
2000–16, 2000–12 I.R.B. 780
2000–17, 2000–13 I.R.B. 842
2000–18, 2000–14 I.R.B. 847
2000–19, 2000–14 I.R.B. 849
2000–20, 2000–16 I.R.B. 880
2000–21, 2000–16 I.R.B. 881
2000–22, 2000–16 I.R.B. 880
Treasury Decisions:
8849, 2000–2 I.R.B. 245
8850, 2000–2 I.R.B. 265
8851, 2000–2 I.R.B. 275
8852, 2000–2 I.R.B.253
8853, 2000–4 I.R.B.377
8854, 2000–3 I.R.B.306
8855, 2000–4 I.R.B.374
8856, 2000–3 I.R.B.298
8857, 2000–4 I.R.B.365
8858, 2000–4 I.R.B.332
8859, 2000–5 I.R.B.429
8860, 2000–5 I.R.B.437
8861, 2000–5 I.R.B.441
8862, 2000–6 I.R.B.466
8863, 2000–6 I.R.B.488
8864, 2000–7 I.R.B.614
8865, 2000–7 I.R.B.589
8866, 2000–6 I.R.B.495
8867, 2000–7 I.R.B.620
8868, 2000–6 I.R.B.491
8869, 2000–6 I.R.B.498
8870, 2000–8 I.R.B.647
8871, 2000–8 I.R.B.641
8872, 2000–8 I.R.B.639
8873, 2000–9 I.R.B.713
8874, 2000–8 I.R.B.644
8875, 2000–11 I.R.B.761
8876, 2000–11 I.R.B.753
8877, 2000–11 I.R.B.747
8878, 2000–15 I.R.B.857
8879, 2000–16 I.R.B.882
1
A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 1999–27 through
1999–52 is in Internal Revenue Bulletin 2000–1,
dated January 3, 2000.

2000–17 I.R.B.iiiApril 24, 2000
Finding List of Current Actions on
Previously Published Items
1
Bulletins 2000–1 through 2000–16
Announcements:
99–40
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
99–50
Modified by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
2000–18
Corrected by
Announcement 2000–32, 2000–15 I.R.B. 878
Notices:
88–125
Obsoleted by
T.D. 8870, 2000–8 I.R.B. 647
92–48
Obsoleted by
Notice 2000–11, 2000–6 I.R.B. 572
97–19
Modified by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
98–22
Obsoleted by
T.D. 8870, 2000–8 I.R.B. 647
98–52
Modified by
Notice 2000–3, 2000–4 I.R.B. 413
98–61
Modified and superseded by
Rev. Proc. 2000–15, 2000–5 I.R.B. 447
99–8
Obsoleted by
Rev. Proc. 2000–12, 2000–4 I.R.B. 387
2000–4
Corrected by
Announcement 2000–9, 2000–9 I.R.B. 733
Proposed Regulations:
REG–209601–92
Corrected by
Announcement 2000–40, 2000–16 I.R.B. 948
REG–100276–97
Corrected by
Announcement 2000–38, 2000–16 I.R.B. 948
REG–101492–98
Corrected by
Announcement 2000–16, 2000–12 I.R.B. 837
REG–113572–99
Corrected by
Announcement 2000–41, 2000–16 I.R.B. 949
Revenue Procedures:
80–18
Modified by
Rev. Proc. 2000–13, 2000–6 I.R.B. 515
89–9
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
Revenue Procedures—Continued:
89–13
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
90–21
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
91–66
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
92–13
Modified, amplified, and superseded by
Rev. Proc. 2000–11, 2000–3 I.R.B. 309
92–13A
Modified, amplified, and superseded by
Rev. Proc. 2000–11, 2000–3 I.R.B. 309
92–41
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
93–9
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
93–10
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
94–12
Modified, amplified, and superseded by
Rev. Proc. 2000–11, 2000–3 I.R.B. 309
95–42
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
96–13
Modified by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
98–22
Modified and superseded by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
98–27
Superseded by
Rev. Proc. 2000–12, 2000–4 I.R.B. 387
98–64
Superseded by
Rev. Proc. 2000–9, 2000–2 I.R.B. 280
98–65
Superseded by
Rev. Proc. 2000–19, 2000–12 I.R.B. 785
99–1
Superseded by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
99–2
Superseded by
Rev. Proc. 2000–2, 2000–1 I.R.B. 73
99–3
Superseded by
Rev. Proc. 2000–3, 2000–1 I.R.B. 103
99–4
Superseded by
Rev. Proc. 2000–4, 2000–1 I.R.B. 115
99–5
Superseded by
Rev. Proc. 2000–5, 2000–1 I.R.B. 158
Revenue Procedures—Continued:
99–6
Superseded by
Rev. Proc. 2000–6, 2000–1 I.R.B. 187
99–7
Superseded by
Rev. Proc. 2000–7, 2000–1 I.R.B. 227
99–8
Superseded by
Rev. Proc. 2000–8, 2000–1 I.R.B. 230
99–13
Modified and superseded by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
99–31
Modified and superseded by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
99–49
Modified and amplified by
Rev. Rul. 2000–4, 2000–4 I.R.B. 331
Rev. Rul. 2000–7, 2000–9 I.R.B. 712
Notice 2000–4, 2000–3 I.R.B. 313
99–51
Superseded by
Rev. Proc. 2000–3, 2000–1 I.R.B. 103
2000–6
Modified by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
2000–8
Modified by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
2000–16
Corrected by
Announcement 2000–17, 2000–13 I.R.B. 846
Revenue Rulings:
57–259
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
57–499
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
73–292
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
78–218
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
86–62
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
88–36
Modified by
Rev. Rul. 2000–6, 2000–6 I.R.B. 512
89–89
Obsoleted by
Rev. Rul. 2000–2, 2000–3 I.R.B. 305
92–19
Supplemented by
Rev. Rul. 2000–17, 2000–13 I.R.B. 842
98–30
Amplified and superseded by
Rev. Rul. 2000–8, 2000–7 I.R.B. 617
1
A cumulative list of current actions on previously
published items in Internal Revenue Bulletins
1999–27 through 1999–52 is in Internal Revenue
Bulletin 2000–1, dated January 3, 2000.

April 24, 2000iv2000–17 I.R.B.
Treasury Decisions:
8734
Modified by
T.D. 8856, 2000–3 I.R.B. 298
8804
Modified by
T.D. 8856, 2000–3 I.R.B. 298
8845
Corrected by
Announcement 2000–6, 2000–4 I.R.B. 428
8846
Corrected by
Announcement 2000–3, 2000–2 I.R.B. 296
8847
Corrected by
Announcement 2000–13, 2000–11 I.R.B. 771
8849
Corrected by
Announcement 2000–28, 2000–15 I.R.B. 876
8852
Corrected by
Announcement 2000–18, 2000–13 I.R.B. 846
8853
Corrected by
Announcement 2000–33, 2000–15 I.R.B. 878
8856
Corrected by
Announcement 2000–31, 2000–15 I.R.B. 877
8859
Corrected by
Announcement 2000–27, 2000–15 I.R.B. 876
8864
Corrected by
Announcement 2000–26, 2000–15 I.R.B. 876
8865
Corrected by
Announcement 2000–37, 2000–16 I.R.B. 947
8867
Corrected by
Announcement 2000–30, 2000–15 I.R.B. 877
8869
Corrected by
Announcement 2000–36, 2000–16 I.R.B. 947
8870
Corrected by
Announcement 2000–34, 2000–15 I.R.B. 879
8874
Corrected by
Announcement 2000–29, 2000–15 I.R.B. 877

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