us-irs-revenue-procedures-irb-2000-27-pdf•Internal Revenue Bulletin 2000-27 (PDF rendition): IRS Revenue Procedures
Internal Revenue Bulletin 2000-27 (PDF rendition): IRS Revenue Procedures
us-irs-revenue-procedures-irb-2000-27-pdfInternal Revenue Bulletin 2000-27 (PDF rendition): IRS Revenue ProceduresGuidance
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. 2000–32, page 1. Federal rates; adjusted federal rates; adjusted federal long-term rate, and the long-term exempt rate.For purposes of sections 1274, 1288, 382, and other sections of the Code, tables set forth the rates for July 2000. T.D. 8888, page 3. Final regulations under section 6049 of the Code rescind the requirement that certain information related to the accrual of original issue discount (OID) be set forth on the face of certifi- cates for a collateralized debt obligation (CDO) or regular inter- est in a real estate mortgage investment conduit (REMIC). REG–105316–98, page 98. Proposed regulations under section 6050S of the Code re- late to information reporting for payments of qualified tu- ition and related expenses and payments of interest on qualified education loans. In addition, proposed regula- tions under section 6011(e) of the Code relate to mag- netic media filing requirements for information returns. ESTATE TAX T.D. 8886, page 3. Final regulations under section 7520 of the Code relate to the use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests. EXCISE TAX Notice 2000–33, page 97. Taxable fuel measurement.This notice provides infor- mation under section 4081 of the Code relating to the measurement of taxable fuel for the period July 1, 2000, through June 30, 2001. ADMINISTRATIVE Rev. Proc. 2000–28, page 60. Rules and specifications for private printing of sub- stitute forms.This procedure provides requirements for reproducing paper substitutes and for furnishing substi- tute recipient statements for Forms 1096, 1098, 1099, 5498, and W-2G. It will be reproduced as the July 2000 re- vision of Publication 1179. Rev. Proc. 99–34 superseded. Internal Revenue bbuulllleettiinn Bulletin No. 2000–27 July 3, 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. Index for January through June begins on page vi. July 3, 20002000–27 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 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. 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 42.—Low-Income Housing Credit The adjusted applicable federal short-term, mid- term and long-term rates are set forth for the month of July 2000. See Rev. Rul. 2000–32, on this page. Section 280G.—Golden Parachute Payments Federal short-term, mid-term, and long-term rates are set forth for the month of July 2000. See Rev. Rul. 2000–32, on this page. Section 382.—Limitation on Net Operating Loss Carryforwards and Certain Built-In Losses Following Ownership Change The adjusted applicable federal long-term rate is set forth for the month of July 2000. See Rev. Rul. 2000–32, on this page. Section 412.—Minimum Funding Standards The adjusted applicable federal short-term, mid- term and long-term rates are set forth for the month of July 2000. See Rev. Rul. 2000–32, on this page. Section 467.—Certain Payments for the Use of Property or Services The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of July 2000. See Rev. Rul. 2000–32, on this page. Section 468.—Special Rules for Mining and Solid Waste Reclamation and Closing Costs The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of July 2000. See Rev. Rul. 2000–32, on this page. Section 482.—Allocation of Income and Deductions Among Taxpayers Federal short-term, mid-term, and long-term rates are set forth for the month of July 2000. See Rev. Rul. 2000–32, on this page. Section 483.—Interest on Certain Deferred Payments The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of July 2000. See Rev. Rul. 2000–32, on this page. Section 642.—Special Rules for Credits and Deductions Federal short-term, mid-term, and long-term rates are set forth for the month of July 2000. See Rev. Rul. 2000–32, on this page. Section 807.—Rules for Certain Reserves The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of July 2000. See Rev. Rul. 2000–32, on this page. Section 846.—Discounted Unpaid Losses Defined The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of July 2000. See Rev. Rul. 2000–32, on this page. Section 1274.—Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also Sections 42, 280G, 382, 412, 467, 468, 482, 483, 642, 807, 846, 1288, 7520, 7872.) Federal rates; adjusted federal rates; adjusted federal long-term rate, and the long-term exempt rate.For purposes of sections 1274, 1288, 382, and other sections of the Code, tables set forth the rates for July 2000. Rev. Rul. 2000–32 This revenue ruling provides various pre- scribed rates for federal income tax purposes for July 2000 (the current month.) Table 1 contains the short-term, mid-term, and long- term applicable federal rates (AFR) for the current month for purposes of section 1274(d) of the Internal Revenue Code. Table 2 contains the short-term, mid-term, and long-term adjusted applicable federal rates (adjusted AFR) for the current month for purposes of section 1288(b). Table 3 sets forth the adjusted federal long-term rate and the long-term tax-exempt rate described in section 382(f). Table 4 contains the appro- priate percentages for determining the low- income housing credit described in section 42(b)(2) for buildings placed in service dur- ing the current month. Table 5 contains the federal rate for determining the present value of an annuity, an interest for life or for a term of years, or a remainder or a reversionary in- terest for purposes of section 7520. Finally, Table 6 contains the blended annual rate for purposes of section 7872. 2000–27 I.R.B.1July 3, 2000 Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 REV. RUL. 2000–32 TABLE 1 Applicable Federal Rates (AFR) for July 2000 Period for Compounding AnnualSemiannualQuarterlyMonthly Short-Term AFR6.60%6.49%6.44%6.40% 110% AFR7.27%7.14%7.08%7.04% 120% AFR7.94%7.79%7.72%7.67% 130% AFR8.62%8.44%8.35% 8.30% Mid-Term AFR6.62% 6.51% 6.46%6.42% 110% AFR7.29%7.16%7.10%7.06% 120% AFR7.96%7.81%7.74%7.69% 130% AFR8.64%8.46%8.37%8.31% 150% AFR10.01%9.77%9.65%9.58% 175% AFR11.71%11.39%11.23%11.13% Long-Term AFR6.40%6.30%6.25%6.22% 110% AFR7.05%6.93%6.87%6.83% 120% AFR7.70%7.56%7.49%7.44% 130% AFR8.36%8.19%8.11%8.05% July 3, 200022000–27 I.R.B. REV. RUL. 2000–32 TABLE 2 Adjusted AFR for July 2000 Period for Compounding AnnualSemiannualQuarterlyMonthly Short-term adjusted AFR4.88%4.82%4.79%4.77% Mid-term adjusted AFR5.12%5.06%5.03%5.01% Long-term adjusted AFR5.79%5.71%5.67%5.64% REV. RUL. 2000–32 TABLE 3 Rates Under Section 382 for July 2000 Adjusted federal long-term rate for the current month5.79% Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal long-term rates for the current month and the prior two months.)5.79% REV. RUL. 2000–32 TABLE 4 Appropriate Percentages Under Section 42(b)(2) for July 2000 Appropriate percentage for the 70% present value low-income housing credit8.53% Appropriate percentage for the 30% present value low-income housing credit3.66% REV. RUL. 2000–32 TABLE 5 Rate Under Section 7520 for July 2000 Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years, or a remainder or reversionary interest8.0% 2000–27 I.R.B.3July 3, 2000 REV. RUL. 2000–32 TABLE 6 Blended Annual Rate for 2000 Section 7872(e)(2) blended annual rate for 20006.24% Section 1288.—Treatment of Original Issue Discounts on Tax- Exempt Obligations The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of July 2000. See Rev. Rul. 2000–32, page 1. Section 6049.—Returns Regarding Payments of Interest 26 CFR 1.6049–7: Returns of information with respect to REMIC regular interests and collateralized debt obligations. T.D. 8888 DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 Real Estate Mortgage Investment Conduits; Reporting Requirements and Other Administrative Matters AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Final regulations. SUMMARY: This document eliminates the regulatory requirement that the issuer of a collateralized debt obligation (CDO) or regular interest in a real estate mort- gage investment conduit (REMIC) set forth certain information on the face of the CDO or regular interest. This action eliminates a reporting burden imposed on issuers of CDOs and regular interests. EFFECTIVE DATE: These regulations are effective June 16, 2000. FOR FURTHER INFORMATION CON- TACT: Kenneth Christman, (202) 622- 3950 (not toll-free numbers). SUPPLEMENTARY INFORMATION: Background On May 19, 1999, the IRS published in the Federal Register a notice of proposed rulemaking (REG–100905–97, 1999–22 I.R.B. 10 [64 F.R. 27221]) intending to eliminate the regulatory requirement that certain information be set forth on the face of a certificate representing a CDO or REMIC regular interest. The public hearing scheduled for Sep- tember 13, 1999, was canceled because no one requested to speak, and the only written comment received supports finalizing the regulations in the form proposed. This Treasury decision, therefore, adopts the proposed regulations with no change. Special Analyses It has been determined that this Treasury decision is not a significant regulatory ac- tion as defined in Executive Order 12866. Therefore, a regulatory assessment is not required. It has also been determined that section 553(b) of the Administrative Proce- dure Act (5 U.S.C. chapter 5) does not apply to these regulations, and, because the regulations do not impose a collection of information on small entities, the Regula- tory Flexibility Act (5 U.S.C. chapter 6) does not apply. Pursuant to section 7805(f) of the Internal Revenue Code, the notice of proposed rulemaking preceding these regu- lations was submitted to the Chief Counsel for Advocacy of the Small Business Ad- ministration for comment on its impact on small business. Drafting Information The principal author of these regula- tions is Kenneth Christman, Office of As- sistant Chief Counsel (Financial Institu- tions and Products). However, other personnel from the IRS and Treasury De- partment participated in their develop- ment. * * * * * Adoption of Amendments to the Regulations Accordingly, 26 CFR part 1 is amended as follows: PART 1—INCOME TAXES Paragraph 1. The authority citation for part 1 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * * §1.6049–7 [Amended] Par. 2. In §1.6049–7, paragraph (g) is removed. John M. Dalrymple, Acting Deputy Commissioner of Internal Revenue. Approved June 1, 2000. Jonathan Talisman, Deputy Assistant Secretary of the Treasury. (Filed by the Office of the Federal Register on June 15, 2000, 8:45 a.m., and published in the issue of the Federal Register for June 16, 2000, 65 F.R. 37701) Section 7520.—Valuation Tables The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of July 2000. See Rev. Rul. 2000–32, page 1. 26 CFR Section 20.7520–1.—Valuation of annuities, unitrust interests, interests for life or terms of years, and remainder or reversionary interests. T.D. 8886 DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Parts 1, 20, and 25 Use of Actuarial Tables in Valuing Annuities, Interests for Life or Terms of Years, and Remainder or Reversionary Interests AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Final regulations. SUMMARY: This document contains final regulations relating to the use of ac- tuarial tables in valuing annuities, inter- ests for life or terms of years, and remain- der or reversionary interests. These regulations will effect the valuation of inter vivos and testamentary transfers of interests dependent on one or more mea- suring lives. Section 7520 of the Internal Revenue Code of 1986 (Code) was en- acted by section 5031 of the Technical and Miscellaneous Revenue Act of 1988 and was effective on May 1, 1989. These regulations are necessary because section 7520(c)(3) directs the Secretary to revise the actuarial tables used in valuing inter- ests dependent on mortality experience not less frequently than once each 10 years to take into account the most recent mortality experience available as of the time of the revision. This document con- tains amendments to the regulations revis- ing certain tables used for the valuation of partial interests in property under section 7520 to reflect the most recent mortality experience available. DATES: These regulations are effective June 12, 2000. FOR FURTHER INFORMATION CON- TACT: William L. Blodgett, (202) 622- 3090 (not a toll-free number). SUPPLEMENTARY INFORMATION: Background On April 30, 1999, the IRS published in the Federal Register(T.D. 8819, 1999–20 I.R.B. 5 [64 F.R. 23187 and 64 F.R. 23245]) temporary regulations and a notice of proposed rulemaking by cross reference to temporary regulations (REG–103851–99, 1999–20, I.R.B. 93) under sections 642, 664, 2031, 2512, and 7520 relating to the use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or rever- sionary interests. No written comments responding to the notice of proposed rule- making by cross reference to temporary regulations were received and, thus, no hearing was held. This document adopts, with no substantive changes, final regula- tions with respect to this notice of pro- posed rulemaking by cross reference to temporary regulations. The following chart summarizes the applicable interest rates and the citations to textual materials and tables for the var- ious periods covered under the regula- tions: July 3, 200042000–27 I.R.B. Cross Reference to Regulation Sections ValuationInterestRegulation PeriodRateSectionTable Section 642: Valuation, in general-1.642(c)–6 before 01/01/524%1.642(c)–6A(a) 01/01/52 - 12/31/703.5%1.642(c)–6A(b) 01/01/71 - 11/30/836%1.642(c)–6A(c) 12/01/83 - 04/30/8910%1.642(c)–6A(d)Table G 05/01/89 - 04/30/99§75201.642(c)–6A(e)Table S (05/01/89 - 4/30/99) after 04/30/99§75201.642(c)–6(e)Table S (after 04/30/99) Section 664: Valuation, in general-1.664–4 before 01/01/524%1.664–4A(a) 01/01/52 - 12/31/703.5%1.664–4A(b) 01/01/71 - 11/30/836%1.664–4A(c) 12/01/83 - 04/30/8910%1.664–4A(d)Table E, Table F(1) 05/01/89 - 04/30/99§75201.664–4A(e)Table U(1) (05/01/89 - 4/30/99) after 04/30/99§75201.664–4(e)(6)Table D and Tables F(4.2) – F(14.0) 1.664–4(e)(7)Table U(1) (after 04/30/99) Section 2031: Valuation, in general-20.2031–7 before 01/01/524%20.2031–7A(a) 01/01/52 - 12/31/703.5%20.2031–7A(b) 01/01/71 - 11/30/836%20.2031–7A(c) 12/01/83 - 04/30/8910%20.2031–7A(d)Table A, Table B, Table LN 05/01/89 - 04/30/99§752020.2031–7A(e)Table S (05/01/89 - 4/30/99) Life Table 80CNSMT after 04/30/99§752020.2031–7(d)(6)Table B, Table J, Table K 20.2031–7(d)(7)Table S (after 04/30/99) and Life Table 90CM Section 2512: Valuation, in general-25.2512–5 before 01/01/524%25.2512–5A(a) 01/01/52 - 12/31/703.5%25.2512–5A(b) 01/01/71 - 11/30/836%25.2512–5A(c) 12/01/83 - 04/30/8910%25.2512–5A(d) 05/01/89 - 04/30/99§752025.2512–5A(e) after 04/30/99§752025.2512–5(d) 2000–27 I.R.B.5July 3, 2000 Effective Dates These regulations are applicable in the case of annuities, interests for life or terms of years, and remainder or reversionary in- terests created after April 30, 1999. Special Analysis It has been determined that this Treasury decision is not a significant regulatory ac- tion as defined in Executive Order 12866. Therefore, a regulatory assessment is not required. It also has been determined that section 553(b) of the Administrative Proce- dure Act (5 U.S.C. chapter 5) does not apply to these regulations, and because these regulations do not impose a collection of information requirement on small enti- ties, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not apply. There- fore, a Regulatory Flexibility Analysis is not required. Pursuant to section 7805(f) of the Internal Revenue Code, the notice of proposed rulemaking by cross reference to temporary regulations was submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small business. Drafting Information The principal author of these regulations is William L. Blodgett, Office of Assistant Chief Counsel (Passthroughs and Special Industries), IRS. However, other personnel from the IRS and Treasury Department par- ticipated in their development. * * * * * Adoption of Amendments to the Regulations Accordingly, 26 CFR parts 1, 20, and 25 are amended as follows: PART 1—INCOME TAXES Paragraph 1. The authority citation for part 1 is amended by removing the entries for 1.642(c)–6T, 1.664–4Tand 1.7520–1T to read in part as follows: Authority: 26 U.S.C. 7805 * * * Par. 2. Section 1.170A–12 is amended by revising paragraphs (b)(2) and (b)(3) to read as follows: §1.170A–12 Valuation of a remainder in- terest in real property for contributions made after July 31, 1969. * * * * * (b) * * * (2) Computation of depreciation factor. If the valuation of the remainder interest in depreciable property is dependent upon the continuation of one life, a special fac- tor must be used. The factor determined under this paragraph (b)(2) is carried to the fifth decimal place. The special factor is to be computed on the basis of the inter- est rate and life contingencies prescribed in §20.2031–7 of this chapter (or for peri- ods before May 1, 1999, §20.2031–7A) and on the assumption that the property depreciates on a straight-line basis over its estimated useful life. For transfers for which the valuation date is after April 30, 1999, special factors for determining the present value of a remainder interest fol- lowing one life and an example describ- ing the computation is contained in Inter- nal Revenue Service Publication 1459, “Actuarial Values, Book Gimel,” (7- 1999). A copy of this publication is avail- able for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402. For transfers for which the valuation date is after April 30, 1989, and before May 1, 1999, special factors for determining the present value of a remainder interest fol- lowing one life and an example describ- ing the computation is contained in Inter- nal Revenue Service Publication 1459, “Actuarial Values, Gamma Volume,” (8- 89). This publication is no longer avail- able for purchase from the Superintendent of Documents. However, it may be ob- tained by requesting a copy from: CC:DOM:CORP:R (IRS Publication 1459), room 5226, Internal Revenue Ser- vice, POB 7604, Ben Franklin Station, Washington, DC 20044. See, however, §1.7520–3(b) (relating to exceptions to the use of prescribed tables under certain circumstances). Otherwise, in the case of the valuation of a remainder interest fol- lowing one life, the special factor may be obtained through use of the following for- mula: Where: n=the estimated number of years of useful life, i=the applicable interest rate under sec- tion 7520 of the Internal Revenue Code, v=1 divided by the sum of 1 plus the ap- plicable interest rate under section 7520 of the Internal Revenue Code, x=the age of the life tenant, and lx=number of persons living at age x as set forth in Table 90CM of §20.2031–7 (or, for periods before May 1, 1999, the tables set forth under §20.2031–7A) of this chapter. (3) Example. The following example illustrates the provisions of this paragraph (b): Example. A, who is 62, donates to Y University a remainder interest in a personal residence, consist- ing of a house and land, subject to a reserved life es- tate in A. At the time of the gift, the land has a value of $30,000 and the house has a value of $100,000 with an estimated useful life of 45 years, at the end of which the value of the house is expected to be $20,000. The portion of the property considered to be depreciable is $80,000 (the value of the house ($100,000) less its expected value at the end of 45 years ($20,000)). The portion of the property con- sidered to be nondepreciable is $50,000 (the value of the land at the time of the gift ($30,000) plus the ex- pected value of the house at the end of 45 years ($20,000)). At the time of the gift, the interest rate prescribed under section 7520 is 8.4 percent. Based on an interest rate of 8.4 percent, the remainder fac- tor for $1.00 prescribed in §20.2031–7(d) of this chapter for a person age 62 is 0.27925. The value of the nondepreciable remainder interest is $13,962.50 (0.27925 times $50,000). The value of the deprecia- ble remainder interest is $16,148.80 (0.20186, com- puted under the formula described in paragraph (b)(2) of this section, times $80,000). Therefore, the value of the remainder interest is $30,111.30. * * * * * §1.170A–12T [Removed] Par. 3. Section 1.170A–12T is re- moved. Par. 4. -5. Section 1.642(c)–6 is amended by revising paragraphs (d), (e) and (f) to read as follows: §1.642(c)–6 Valuation of a remainder in- terest in property transferred to a pooled income fund. * * * * * (d) Valuation. The present value of the remainder interest in property transferred to a pooled income fund after April 30, 1999, is determined under paragraph (e) of this section. The present value of the remainder interest in property transferred to a pooled income fund for which the valuation date is before May 1, 1999, is determined under the following sections: July 3, 200062000–27 I.R.B. Valuation DatesApplicable AfterBeforeRegulations 01-01-521.642(c)–6A(a) 12-31-5101-01-711.642(c)–6A(b) 12-31-7012-01-831.642(c)–6A(c) 11-30-8305-01-891.642(c)–6A(d) 04-30-8905-01-991.642(c)–6A(e) (e) Present value of the remainder in- terest in the case of transfers to pooled in- come funds for which the valuation date is after April 30, 1999—(1)In general. In the case of transfers to pooled income funds for which the valuation date is after April 30, 1999, the present value of a re- mainder interest is determined under this section. See, however, §1.7520–3(b) (re- lating to exceptions to the use of pre- scribed tables under certain circum- stances). The present value of a remainder interest that is dependent on the termination of the life of one individ- ual is computed by the use of Table S in paragraph (e)(6) of this section. For pur- poses of the computations under this sec- tion, the age of an individual is the age at the individual’s nearest birthday. (2) Transitional rules for valuation of transfers to pooled income funds. (i) For purposes of sections 2055, 2106, or 2624, if on May 1, 1999, the decedent was men- tally incompetent so that the disposition of the property could not be changed, and the decedent died after April 30, 1999, without having regained competency to dispose of the decedent’s property, or the decedent died within 90 days of the date that the decedent first regained compe- tency after April 30, 1999, the present value of a remainder interest is deter- mined as if the valuation date with respect to the decedent’s gross estate is either be- fore May 1, 1999, or after April 30, 1999, at the option of the decedent’s executor. (ii) For purposes of sections 170, 2055, 2106, 2522, or 2624, in the case of trans- fers to a pooled income fund for which the valuation date is after April 30, 1999, and before July 1, 1999, the present value of the remainder interest under this sec- tion is determined by use of the section 7520 interest rate for the month in which the valuation date occurs (see §§1.7520–1(b) and 1.7520–2(a)(2)) and the appropriate actuarial tables under ei- ther paragraph (e)(6) of this section or §1.642(c)–6A(e)(5), at the option of the donor or the decedent’s executor, as the case may be. (iii) For purposes of paragraphs (e)(2)(i) and (ii) of this section, where the donor or decedent’s executor is given the option to use the appropriate actuarial ta- bles under either paragraph (e)(6) of this section or §1.642(c)–6A(e)(5), the donor or decedent’s executor must use the same actuarial table with respect to each indi- vidual transaction and with respect to all transfers occurring on the valuation date (for example, gift and income tax charita- ble deductions with respect to the same transfer must be determined based on the same tables, and all assets includible in the gross estate and/or estate tax deduc- tions claimed must be valued based on the same tables). (3) Present value of a remainder inter- est. The present value of a remainder in- terest in property transferred to a pooled income fund is computed on the basis of— (i) Life contingencies determined from the values of lxthat are set forth in Table 90CM in §20.2031–7(d)(7) of this chapter (see § 20.2031–7A of this chapter for cer- tain prior periods); and (ii) Discount at a rate of interest, com- pounded annually, equal to the highest yearly rate of return of the pooled income fund for the 3 taxable years immediately preceding its taxable year in which the transfer of property to the fund is made. For purposes of this paragraph (e), the yearly rate of return of a pooled income fund is determined as provided in para- graph (c) of this section unless the highest rate of return is deemed to be the rate de- scribed in paragraph (e)(4) of this section for funds in existence less than 3 taxable years. For purposes of this paragraph (e)(3)(ii), the first taxable year of a pooled income fund is considered a taxable year even though the taxable year consists of less than 12 months. However, appropri- ate adjustments must be made to annual- ize the rate of return earned by the fund for that period. Where it appears from the facts and circumstances that the highest yearly rate of return of the fund for the 3 taxable years immediately preceding the taxable year in which the transfer of prop- erty is made has been purposely manipu- lated to be substantially less than the rate of return that would otherwise be reason- ably anticipated with the purpose of ob- taining an excessive charitable deduction, that rate of return may not be used. In that case, the highest yearly rate of return of the fund is determined by treating the fund as a pooled income fund that has been in existence for less than 3 preceding taxable years. (4) Pooled income funds in existence less than 3 taxable years. If a pooled in- come fund has been in existence less than 3 taxable years immediately preceding the taxable year in which the transfer is made to the fund and the transfer to the fund is made after April 30, 1989, the highest rate of return is deemed to be the interest rate (rounded to the nearest two-tenths of one percent) that is 1 percent less than the highest annual average of the monthly section 7520 rates for the 3 calendar years immediately preceding the calendar year in which the transfer to the pooled income fund is made. The deemed rate of return for transfers to new pooled income funds is recomputed each calendar year using the monthly section 7520 rates for the 3- year period immediately preceding the calendar year in which each transfer to the fund is made until the fund has been in existence for 3 taxable years and can compute its highest rate of return for the 3 taxable years immediately preceding the taxable year in which the transfer of prop- erty to the fund is made in accordance with the rules set forth in the first sen- tence of paragraph (e)(3)(ii) of this sec- tion. (5) Computation of value of remainder interest. The factor that is used in deter- mining the present value of a remainder interest that is dependent on the termina- tion of the life of one individual is the fac- tor from Table S in paragraph (e)(6) of this section under the appropriate yearly rate of return opposite the number that corresponds to the age of the individual upon whose life the value of the remain- der interest is based (see §1.642(c)–6A for certain prior periods). The tables in paragraph (e)(6) of this section include factors for yearly rates of return from 4.2 to 14 percent. Many actuarial factors not contained in the tables in paragraph (e)(6) of this section are contained in Table S in Internal Revenue Service Publication 1457, “Actuarial Values, Book Aleph,” (7-1999). A copy of this publication is available for purchase from the Superin- tendent of Documents, United States Government Printing Office, Washington, DC 20402. For other situations, see para- graph (b) of this section. If the yearly rate of return is a percentage that is between the yearly rates of return for which factors are provided, a linear interpolation must be made. The present value of the re- mainder interest is determined by multi- plying the fair market value of the prop- erty on the valuation date by the appropri- ate remainder factor. This paragraph (e)(5) may be illustrated by the following example: Example. A, who is 54 years and 8 months, transfers $100,000 to a pooled income fund, and re- tains a life income interest in the property. The highest yearly rate of return earned by the fund for its 3 preceding taxable years is 9.47 percent. In Table S, the remainder factor opposite 55 years under 9.4 percent is .17449 and under 9.6 percent is .17001. The present value of the remainder interest is $17,292.00, computed as follows: Factor at 9.4 percent for age 55 . . . . . .17449 Factor at 9.6 percent for age 55 . . . . . . .17001 Difference . . . . . . . . . . . . . . . . . . . . . . .00448 Interpolation adjustment: 9.47% - 9.4%=x 0.2%.00448 x = .00157 Factor at 9.4 percent for age 55 . . . . . . . .17449 Less: Interpolation adjustment. . . . . . . .00157 Interpolated factor. . . . . . . . . . . . . . . . . .17292 Present value of remainder interest: ($100,000 X .17292) . . . . . . . . . $17,292.00 (6) Actuarial tables. In the case of transfers for which the valuation date is after April 30, 1999, the present value of a remainder interest dependent on the ter- mination of one life in the case of a trans- fer to a pooled income fund is determined by use of the following Table S: 2000–27 I.R.B.7July 3, 2000 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0% 0.06752.06130.05586.05109.04691.04322.03998.03711.03458.03233 1.06137.05495.04932.04438.04003.03620.03283.02985.02721.02487 2.06325.05667.05088.04580.04132.03737.03388.03079.02806.02563 3.06545.05869.05275.04752.04291.03883.03523.03203.02920.02668 4.06784.06092.05482.04944.04469.04048.03676.03346.03052.02791 5.07040.06331.05705.05152.04662.04229.03845.03503.03199.02928 6.07310.06583.05941.05372.04869.04422.04025.03672.03357.03076 7.07594.06849.06191.05607.05089.04628.04219.03854.03528.03236 8.07891.07129.06453.05853.05321.04846.04424.04046.03709.03407 9.08203.07423.06731.06115.05567.05079.04643.04253.03904.03592 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0% 10.08532.07734.07024.06392.05829.05326.04877.04474.04114.03790 11.08875.08059.07331.06683.06104.05587.05124.04709.04336.04002 12.09233.08398.07653.06989.06394.05862.05385.04957.04572.04226 13.09601.08748.07985.07304.06693.06146.05655.05214.04816.04458 14.09974.09102.08322.07624.06997.06435.05929.05474.05064.04694 15.10350.09460.08661.07946.07303.06725.06204.05735.05312.04930 16.10728.09818.09001.08268.07608.07014.06479.05996.05559.05164 17.11108.10179.09344.08592.07916.07306.06755.06257.05807.05399 18.11494.10545.09691.08921.08227.07601.07034.06521.06057.05636 19.11889.10921.10047.09259.08548.07904.07322.06794.06315.05880 20.12298.11310.10417.09610.08881.08220.07622.07078.06584.06135 21.12722.11713.10801.09976.09228.08550.07935.07375.06866.06403 22.13159.12130.11199.10354.09588.08893.08260.07685.07160.06682 23.13613.12563.11612.10748.09964.09250.08601.08009.07468.06975 24.14084.13014.12043.11160.10357.09625.08958.08349.07793.07284 25.14574.13484.12493.11591.10768.10018.09334.08708.08135.07611 26.15084.13974.12963.12041.11199.10431.09728.09085.08496.07956 27.15615.14485.13454.12513.11652.10865.10144.09484.08878.08322 28.16166.15016.13965.13004.12124.11319.10580.09901.09279.08706 29.16737.15567.14497.13516.12617.11792.11035.10339.09699.09109 30.17328.16138.15048.14047.13129.12286.11510.10796.10138.09532 31.17938.16728.15618.14599.13661.12799.12004.11272.10597.09974 32.18568.17339.16210.15171.14214.13333.12520.11769.11076.10435 33.19220.17972.16824.15766.14790.13889.13058.12289.11578.10920 34.19894.18627.17460.16383.15388.14468.13618.12831.12102.11426 35.20592.19307.18121.17025.16011.15073.14204.13399.12652.11958 36.21312.20010.18805.17691.16658.15701.14814.13990.13225.12514 37.22057.20737.19514.18382.17331.16356.15450.14608.13825.13096 38.22827.21490.20251.19100.18031.17038.16113.15253.14452.13705 39.23623.22270.21013.19845.18759.17747.16805.15927.15108.14344 40.24446.23078.21805.20620.19516.18487.17527.16631.15795.15013 41.25298.23915.22626.21425.20305.19259.18282.17368.16514.15715 42.26178.24782.23478.22262.21125.20062.19069.18138.17267.16450 43.27087.25678.24360.23129.21977.20898.19888.18941.18053.17220 44.28025.26603.25273.24027.22860.21766.20740.19777.18873.18023 45.28987.27555.26212.24953.23772.22664.21622.20644.19724.18858 46.29976.28533.27179.25908.24714.23591.22536.21542.20606.19725 47.30987.29535.28171.26889.25682.24546.23476.22468.21518.20621 48.32023.30563.29190.27897.26678.25530.24447.23425.22460.21549 49.33082.31615.30234.28931.27702.26543.25447.24412.23434.22509 50.34166.32694.31306.29995.28756.27586.26479.25432.24441.23502 51.35274.33798.32404.31085.29838.28658.27541.26482.25479.24528 52.36402.34924.33525.32200.30946.29757.28630.27561.26547.25584 53.37550.36070.34668.33339.32078.30882.29746.28667.27643.26669 54.38717.37237.35833.34500.33234.32031.30888.29801.28766.27782 July 3, 200082000–27 I.R.B. TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0% 55.39903.38424.37019.35683.34413.33205.32056.30961.29918.28925 56.41108.39631.38227.36890.35617.34405.33250.32149.31099.30097 57.42330.40857.39455.38118.36844.35629.34469.33363.32306.31297 58.43566.42098.40699.39364.38089.36873.35710.34600.33538.32522 59.44811.43351.41956.40623.39350.38133.36968.35855.34789.33768 60.46066.44613.43224.41896.40624.39408.38243.37127.36058.35033 61.47330.45887.44505.43182.41914.40699.39535.38418.37347.36318 62.48608.47175.45802.44485.43223.42011.40848.39732.38660.37629 63.49898.48478.47115.45807.44550.43343.42184.41069.39997.38966 64.51200.49793.48442.47143.45895.44694.43539.42427.41357.40326 65.52512.51121.49782.48495.47255.46062.44912.43805.42738.41709 66.53835.52461.51137.49862.48634.47449.46307.45206.44143.43118 67.55174.53818.52511.51250.50034.48860.47727.46633.45576.44556 68.56524.55188.53899.52654.51452.50291.49168.48083.47034.46020 69.57882.56568.55299.54071.52885.51737.50627.49552.48513.47506 70.59242.57951.56703.55495.54325.53193.52096.51034.50004.49007 71.60598.59332.58106.56918.55767.54651.53569.52520.51503.50516 72.61948.60707.59504.58338.57206.56108.55043.54009.53004.52029 73.63287.62073.60895.59751.58640.57561.56513.55495.54505.53543 74.64621.63435.62282.61162.60073.59015.57985.56984.56009.55061 75.65953.64796.63671.62575.61510.60473.59463.58480.57523.56591 76.67287.66160.65063.63995.62954.61940.60952.59989.59050.58135 77.68622.67526.66459.65419.64404.63415.62450.61509.60590.59694 78.69954.68892.67856.66845.65858.64895.63955.63036.62140.61264 79.71278.70250.69246.68265.67308.66372.65457.64563.63690.62836 80.72581.71588.70618.69668.68740.67833.66945.66077.65227.64396 81.73857.72899.71962.71045.70147.69268.68408.67566.66741.65933 82.75101.74178.73274.72389.71522.70672.69840.69024.68225.67441 83.76311.75423.74553.73700.72864.72044.71240.70451.69678.68919 84.77497.76645.75809.74988.74183.73393.72618.71857.71110.70377 85.78665.77848.77047.76260.75487.74728.73982.73250.72530.71823 86.79805.79025.78258.77504.76764.76036.75320.74617.73925.73245 87.80904.80159.79427.78706.77998.77301.76615.75940.75277.74624 88.81962.81251.80552.79865.79188.78521.77865.77220.76584.75958 89.82978.82302.81636.80980.80335.79699.79072.78455.77847.77248 90.83952.83309.82676.82052.81437.80831.80234.79645.79064.78492 91.84870.84260.83658.83064.82479.81902.81332.80771.80217.79671 92.85716.85136.84563.83998.83441.82891.82348.81812.81283.80761 93.86494.85942.85396.84858.84326.83801.83283.82771.82266.81767 94.87216.86690.86170.85657.85149.84648.84153.83664.83181.82704 95.87898.87397.86902.86412.85928.85450.84977.84510.84049.83592 96.88537.88060.87587.87121.86659.86203.85751.85305.84864.84427 97.89127.88672.88221.87775.87335.86898.86467.86040.85618.85200 98.89680.89245.88815.88389.87968.87551.87138.86730.86326.85926 99.90217.89803.89393.88987.88585.88187.87793.87402.87016.86633 2000–27 I.R.B.9July 3, 2000 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0% 100.90738.90344.89953.89567.89183.88804.88428.88056.87687.87322 101.91250.90876.90504.90137.89772.89412.89054.88699.88348.88000 102.91751.91396.91045.90696.90350.90007.89668.89331.88997.88666 103.92247.91912.91579.91249.90922.90598.90276.89957.89640.89326 104.92775.92460.92148.91839.91532.91227.90924.90624.90326.90031 105.93290.92996.92704.92415.92127.91841.91558.91276.90997.90719 106.93948.93680.93415.93151.92889.92628.92370.92113.91857.91604 107.94739.94504.94271.94039.93808.93579.93351.93124.92899.92675 108.95950.95767.95585.95404.95224.95045.94867.94689.94512.94336 109.97985.97893.97801.97710.97619.97529.97438.97348.97259.97170 July 3, 2000102000–27 I.R.B. TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0% 0.03034.02857.02700.02559.02433.02321.02220.02129.02047.01973 1.02279.02094.01929.01782.01650.01533.01427.01331.01246.01168 2.02347.02155.01983.01829.01692.01569.01458.01358.01268.01187 3.02444.02243.02065.01905.01761.01632.01516.01412.01317.01232 4.02558.02349.02163.01996.01846.01712.01590.01481.01382.01292 5.02686.02469.02275.02101.01945.01804.01677.01562.01458.01364 6.02825.02600.02398.02217.02053.01906.01773.01653.01544.01445 7.02976.02742.02532.02343.02172.02019.01880.01754.01640.01536 8.03137.02894.02675.02479.02301.02140.01995.01864.01744.01635 9.03311.03059.02832.02627.02442.02274.02122.01985.01859.01745 10.03499.03237.03001.02788.02595.02420.02262.02118.01987.01867 11.03700.03428.03183.02961.02760.02578.02413.02262.02125.02000 12.03913.03632.03377.03146.02937.02748.02575.02418.02275.02144 13.04135.03843.03579.03339.03122.02924.02744.02580.02431.02294 14.04359.04057.03783.03534.03308.03102.02915.02744.02587.02444 15.04584.04270.03986.03728.03493.03279.03083.02905.02742.02593 16.04806.04482.04187.03919.03674.03452.03248.03063.02892.02736 17.05029.04692.04387.04108.03855.03623.03411.03218.03040.02877 18.05253.04905.04588.04299.04036.03795.03574.03373.03187.03017 19.05484.05124.04796.04496.04222.03972.03742.03532.03339.03161 20.05726.05354.05013.04702.04418.04158.03919.03700.03498.03313 21.05980.05595.05242.04920.04625.04354.04105.03877.03667.03473 22.06246.05847.05482.05147.04841.04559.04301.04063.03844.03642 23.06524.06112.05734.05387.05069.04777.04508.04260.04032.03821 24.06819.06392.06001.05642.05312.05008.04728.04470.04232.04012 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0% 25.07131.06690.06285.05913.05570.05255.04964.04695.04447.04218 26.07460.07005.06586.06200.05845.05518.05215.04936.04677.04438 27.07810.07340.06907.06508.06140.05800.05485.05195.04925.04676 28.08179.07693.07246.06833.06451.06098.05772.05469.05189.04929 29.08566.08065.07603.07176.06780.06414.06075.05761.05469.05198 30.08973.08456.07978.07536.07127.06748.06396.06069.05766.05483 31.09398.08865.08372.07915.07491.07098.06733.06394.06078.05785 32.09843.09294.08785.08313.07875.07468.07089.06737.06409.06103 33.10310.09745.09220.08732.08279.07858.07466.07100.06759.06441 34.10799.10217.09676.09173.08705.08269.07862.07483.07129.06798 35.11314.10715.10157.09638.09155.08704.08283.07890.07522.07179 36.11852.11236.10662.10127.09628.09162.08726.08319.07938.07581 37.12416.11783.11193.10641.10126.09645.09194.08772.08377.08006 38.13009.12359.11751.11183.10652.10155.09689.09253.08843.08459 39.13629.12962.12338.11753.11206.10693.10212.09761.09337.08938 40.14281.13597.12955.12355.11791.11262.10766.10299.09860.09447 41.14966.14264.13606.12989.12409.11864.11352.10870.10417.09989 42.15685.14966.14291.13657.13061.12500.11972.11475.11006.10564 43.16437.15702.15010.14360.13747.13171.12627.12115.11631.11174 44.17224.16472.15764.15098.14469.13876.13317.12789.12290.11819 45.18042.17274.16550.15867.15223.14615.14040.13496.12982.12496 46.18893.18110.17370.16671.16011.15387.14796.14238.13708.13207 47.19775.18975.18220.17505.16830.16190.15584.15010.14466.13950 48.20688.19873.19102.18373.17682.17027.16406.15817.15258.14727 49.21633.20804.20018.19274.18568.17898.17262.16658.16084.15539 50.22612.21769.20969.20210.19490.18805.18155.17536.16948.16388 51.23625.22769.21955.21182.20448.19749.19084.18452.17849.17275 52.24669.23799.22973.22186.21438.20726.20047.19400.18784.18196 53.25742.24861.24022.23222.22461.21735.21043.20383.19753.19151 54.26845.25952.25101.24290.23516.22777.22072.21399.20756.20140 55.27978.27074.26212.25389.24604.23853.23136.22450.21793.21166 56.29140.28227.27355.26522.25725.24963.24233.23535.22867.22227 57.30333.29411.28529.27686.26879.26106.25365.24656.23976.23324 58.31551.30621.29731.28878.28061.27278.26528.25807.25116.24453 59.32790.31854.30956.30095.29269.28477.27716.26986.26284.25610 60.34050.33107.32202.31334.30500.29699.28929.28190.27478.26794 61.35331.34384.33473.32598.31757.30948.30170.29422.28701.28007 62.36639.35688.34772.33892.33044.32229.31443.30687.29958.29255 63.37974.37020.36101.35216.34363.33542.32750.31986.31250.30539 64.39334.38378.37456.36568.35711.34884.34087.33317.32574.31857 65.40718.39761.38838.37947.37087.36257.35455.34681.33932.33208 66.42128.41172.40249.39357.38496.37663.36858.36079.35326.34597 67.43569.42616.41694.40803.39941.39107.38299.37518.36761.36028 68.45038.44089.43170.42281.41419.40585.39777.38994.38235.37499 69.46531.45587.44672.43786.42927.42094.41286.40503.39743.39006 2000–27 I.R.B.11July 3, 2000 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0% 70.48040.47103.46194.45312.44456.43626.42820.42038.41278.40540 71.49558.48629.47727.46851.46000.45174.44371.43591.42832.42095 72.51082.50162.49268.48399.47554.46733.45934.45157.44401.43666 73.52607.51697.50813.49952.49114.48299.47506.46733.45981.45249 74.54139.53241.52367.51515.50686.49879.49092.48325.47578.46849 75.55683.54798.53936.53095.52276.51477.50698.49938.49197.48474 76.57243.56373.55524.54696.53888.53100.52330.51579.50846.50130 77.58819.57965.57132.56318.55523.54747.53988.53247.52523.51815 78.60408.59572.58755.57957.57177.56414.55668.54939.54225.53527 79.62001.61184.60385.59604.58840.58092.57360.56644.55943.55256 80.63582.62786.62007.61244.60497.59765.59048.58347.57659.56985 81.65142.64367.63608.62864.62135.61421.60721.60034.59361.58701 82.66673.65920.65182.64458.63748.63052.62368.61698.61041.60395 83.68175.67444.66728.66024.65334.64656.63991.63338.62696.62066 84.69657.68950.68256.67574.66904.66246.65599.64964.64340.63727 85.71128.70446.69775.69116.68467.67830.67204.66587.65982.65386 86.72576.71919.71272.70636.70010.69394.68789.68193.67606.67029 87.73981.73349.72726.72114.71511.70917.70333.69757.69190.68632 88.75342.74735.74137.73548.72968.72396.71833.71279.70732.70194 89.76658.76076.75503.74938.74381.73832.73290.72757.72231.71712 90.77928.77371.76823.76281.75748.75221.74702.74190.73684.73186 91.79131.78600.78075.77557.77046.76542.76044.75553.75068.74589 92.80246.79737.79235.78740.78250.77767.77290.76818.76353.75893 93.81274.80788.80307.79832.79363.78899.78441.77989.77542.77100 94.82232.81766.81306.80850.80401.79956.79517.79082.78653.78228 95.83141.82695.82254.81818.81387.80961.80539.80122.79710.79302 96.83996.83569.83147.82729.82316.81907.81503.81103.80707.80315 97.84787.84378.83973.83573.83176.82784.82396.82012.81632.81255 98.85530.85138.84750.84366.83985.83609.83236.82867.82502.82140 99.86255.85880.85508.85140.84776.84415.84057.83703.83353.83005 100.86960.86601.86246.85894.85546.85200.84858.84519.84183.83849 101.87655.87313.86974.86638.86305.85975.85648.85324.85003.84684 102.88338.88012.87689.87369.87052.86738.86426.86116.85809.85505 103.89015.88706.88399.88095.87793.87494.87197.86903.86611.86321 104.89737.89446.89157.88871.88586.88304.88024.87745.87469.87195 105.90443.90170.89898.89628.89360.89094.88830.88568.88307.88049 106.91351.91101.90852.90605.90359.90115.89873.89632.89392.89154 107.92452.92230.92010.91791.91573.91356.91141.90927.90714.90502 108.94161.93987.93814.93641.93469.93298.93128.92958.92790.92622 109.97081.96992.96904.96816.96729.96642.96555.96468.96382.96296 July 3, 2000122000–27 I.R.B. TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0% 0.01906.01845.01790.01740.01694.01652.01613.01578.01546.01516 1.01098.01034.00977.00924.00876.00833.00793.00756.00722.00691 2.01113.01046.00986.00930.00880.00834.00791.00753.00717.00684 3.01155.01084.01020.00962.00909.00860.00816.00775.00737.00702 4.01211.01137.01069.01008.00952.00900.00853.00810.00770.00733 5.01279.01201.01130.01065.01006.00952.00902.00856.00814.00775 6.01356.01274.01199.01131.01068.01011.00959.00910.00865.00824 7.01442.01356.01277.01205.01140.01079.01023.00972.00925.00881 8.01536.01446.01363.01287.01218.01154.01096.01041.00991.00945 9.01641.01546.01460.01380.01307.01240.01178.01120.01068.01019 10.01758.01659.01567.01484.01407.01336.01270.01210.01154.01103 11.01886.01781.01686.01598.01517.01442.01373.01310.01251.01196 12.02024.01915.01814.01721.01636.01558.01485.01419.01357.01299 13.02168.02054.01948.01851.01762.01679.01603.01533.01467.01407 14.02313.02193.02083.01981.01887.01801.01721.01646.01578.01514 15.02456.02330.02214.02107.02009.01918.01834.01756.01684.01617 16.02593.02462.02340.02229.02126.02030.01942.01860.01785.01714 17.02728.02590.02463.02346.02238.02138.02046.01960.01880.01806 18.02861.02717.02584.02462.02348.02243.02146.02056.01972.01894 19.02998.02847.02708.02580.02461.02351.02249.02154.02066.01984 20.03142.02984.02839.02704.02580.02465.02357.02258.02165.02079 21.03295.03130.02978.02837.02706.02585.02473.02368.02271.02180 22.03455.03283.03124.02976.02839.02712.02594.02484.02382.02286 23.03626.03446.03279.03124.02981.02847.02723.02608.02500.02400 24.03809.03620.03446.03283.03133.02993.02863.02741.02628.02522 25.04005.03808.03625.03456.03298.03151.03014.02887.02768.02656 26.04216.04010.03819.03641.03476.03322.03178.03044.02919.02802 27.04444.04229.04029.03843.03670.03508.03357.03217.03085.02962 28.04687.04463.04254.04059.03877.03708.03550.03402.03263.03133 29.04946.04712.04493.04289.04099.03922.03756.03600.03455.03318 30.05221.04976.04748.04534.04335.04149.03975.03812.03659.03515 31.05511.05255.05017.04794.04585.04390.04208.04037.03876.03725 32.05818.05551.05302.05069.04851.04647.04455.04276.04107.03948 33.06144.05866.05606.05363.05135.04921.04720.04532.04355.04188 34.06489.06200.05928.05674.05436.05212.05002.04805.04619.04444 35.06857.06555.06273.06007.05758.05524.05304.05097.04902.04718 36.07246.06932.06638.06361.06101.05856.05626.05409.05205.05012 37.07659.07332.07025.06737.06466.06210.05969.05742.05528.05325 38.08098.07758.07439.07138.06855.06588.06336.06099.05874.05662 39.08563.08210.07878.07565.07270.06992.06729.06480.06245.06023 40.09059.08692.08347.08021.07714.07423.07149.06889.06643.06411 41.09586.09206.08848.08509.08189.07886.07600.07329.07072.06828 42.10147.09753.09381.09029.08696.08381.08083.07800.07531.07277 43.10742.10334.09948.09583.09237.08909.08598.08304.08024.07758 44.11373.10950.10551.10172.09813.09472.09148.08841.08549.08272 2000–27 I.R.B.13July 3, 2000 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0% 45.12035.11599.11185.10792.10420.10066.09730.09410.09106.08817 46.12732.12281.11853.11447.11061.10694.10345.10013.09696.09395 47.13460.12995.12553.12133.11733.11353.10991.10646.10317.10004 48.14223.13743.13287.12853.12439.12046.11671.11313.10972.10646 49.15020.14526.14056.13608.13181.12774.12385.12015.11661.11322 50.15855.15347.14862.14401.13960.13540.13138.12754.12388.12037 51.16727.16205.15707.15232.14777.14344.13929.13532.13153.12789 52.17634.17098.16587.16097.15630.15183.14755.14345.13953.13577 53.18576 .18027.17501.16999.16518.16057.15616.15194.14789.14400 54.19552.18990.18451.17935.17441.16968.16514.16078.15661.15260 55.20564.19989.19437.18908.18402.17915.17449.17001.16571.16157 56.21613.21025.20461.19919.19400.18901.18422.17962.17519.17093 57.22698.22098.21522.20968.20436.19925.19434.18961.18507.18069 58.23816.23204.22616.22051.21507.20984.20481.19996.19530.19080 59.24962.24339.23740.23163.22608.22073.21558.21062.20584.20123 60.26136.25502.24892.24304.23738.23192.22666.22158.21669.21196 61.27339.26695.26075.25477.24900.24343.23806.23288.22787.22304 62.28578.27925.27295.26687.26100.25533.24985.24456.23945.23451 63.29854.29192.28553.27935.27339.26762.26205.25666.25145.24641 64.31164.30494.29846.29221.28615.28030.27463.26915.26384.25870 65.32508.31831.31177.30543.29930.29336.28761.28203.27663.27140 66.33891.33208.32547.31906.31285.30684.30101.29536.28987.28456 67.35318.34630.33963.33316.32689.32081.31491.30918.30363.29823 68.36785.36093.35422.34770.34138.33524.32928.32349.31787.31240 69.38290.37595.36920.36265.35628.35009.34408.33824.33256.32703 70.39823.39127.38450.37791.37151.36529.35924.35335.34762.34204 71.41378.40681.40003.39343.38701.38076.37467.36875.36298.35736 72.42950.42253.41575.40914.40271.39644.39034.38438.37858.37293 73.44535.43840.43162.42502.41858.41231.40619.40022.39440.38872 74.46139.45446.44771.44112.43469.42842.42230.41632.41049.40479 75.47769.47080.46408.45752.45111.44485.43874.43277.42693.42123 76.49430.48747.48079.47427.46790.46167.45558.44963.44380.43811 77.51123.50447.49786.49139.48506.47888.47282.46690.46111.45543 78.52845 .52177.51523.50884.50257.49645.49044.48457.47881.47317 79.54584.53926.53282.52650.52032.51426.50833.50251.49681.49122 80.56325.55678.55044.54423.53813.53216.52630.52056.51492.50939 81.58054.57419.56797.56186.55587.54999.54422.53856.53300.52754 82.59762.59140.58530.57931.57343.56766.56198.55641.55094.54557 83.61448.60840.60243.59657.59081.58515.57958.57411.56874.56346 84.63124.62531.61949.61376.60813.60259.59715.59179.58652.58134 85.64800.64224.63657.63099.62550.62010.61478.60955.60441.59934 86.66461.65902.65351.64810.64276.63751.63233.62724.62222.61728 87.68083.67541.67008.66483.65965.65455.64953.64458.63970.63489 88.69663.69140.68624.68116.67615.67121.66634.66154.65680.65213 89.71201.70696.70199.69708.69224.68747.68276.67811.67353.66900 July 3, 2000142000–27 I.R.B. TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0% 90.72694.72209.71730.71257.70791.70330.69876.69427.68984.68547 91.74117.73650.73190.72735.72286.71842.71404.70972.70545.70123 92.75439.74991.74548.74110.73678.73251.72829.72412.72000.71593 93.76664.76233.75806.75385.74969.74557.74150.73748.73350.72957 94.77809.77394.76983.76578.76177.75780.75388.75000.74616.74237 95.78899.78500.78106.77715.77329.76947.76569.76195.75826.75460 96.79928.79544.79165.78790.78418.78050.77686.77326.76970.76617 97.80883.80514.80149.79787.79430.79075.78725.78377.78033.77693 98.81781.81427.81075.80727.80382.80041.79703.79368.79036.78708 99.82661.82320.81982.81648.81316.80988.80662.80340.80020.79704 100.83519.83192.82868.82547.82228.81913.81600.81290.80982.80678 101.84368.84055.83744.83437.83131.82829.82529.82231.81936.81643 102.85203.84904.84607.84313.84021.83731.83444.83159.82876.82596 103.86034.85748.85465.85184.84906.84629.84355.84082.83812.83544 104.86923.86653.86385.86119.85855.85593.85333.85074.84818.84563 105.87792.87537.87283.87032.86782.86534.86287.86042.85799.85557 106.88918.88683.88450.88218.87987.87758.87530.87304.87079.86855 107.90291.90082.89873.89666.89460.89255.89051.88849.88647.88447 108.92455.92288.92123.91958.91794.91630.91468.91306.91145.90984 109.96211.96125.96041.95956.95872.95788.95704.95620.95537.95455 2000–27 I.R.B.15July 3, 2000 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0% 0.01488.01463.01439.01417.01396.01377.01359.01343.01327.01312 1.00662.00636.00612.00589.00568.00548.00530.00513.00497.00482 2.00654.00626.00600.00576.00554.00533.00514.00496.00479.00463 3.00670.00641.00613.00588.00564.00542.00522.00502.00484.00468 4.00699.00668.00639.00612.00587.00563.00542.00521.00502.00484 5.00739.00706.00675.00646.00620.00595.00571.00550.00529.00510 6.00786.00751.00718.00687.00659.00633.00608.00585.00563.00543 7.00841.00803.00769.00736.00706.00678.00652.00627.00604.00582 8.00902.00863.00826.00791.00759.00730.00702.00675.00651.00628 9.00973.00931.00892.00856.00822.00790.00760.00733.00706.00682 10.01055.01010.00969.00930.00894.00861.00829.00799.00772.00746 11.01146.01099.01055.01014.00976.00940.00907.00875.00846.00818 12.01246.01196.01150.01106.01066.01028.00993.00960.00928.00899 13.01351.01298.01249.01204.01161.01121.01084.01049.01016.00985 14.01455.01400.01348.01300.01255.01213.01173.01136.01102.01069 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0% 15.01555.01497.01443.01392.01345.01300.01259.01220.01183.01148 16.01648.01587.01530.01477.01427.01380.01336.01295.01257.01220 17.01737.01673.01612.01556.01504.01455.01408.01365.01324.01286 18.01822.01754.01691.01632.01576.01525.01476.01430.01387.01347 19.01908.01837.01770.01708.01650.01595.01544.01495.01450.01407 20.01999.01924.01854.01788.01726.01669.01615.01564.01516.01471 21.02096.02017.01943.01874.01809.01748.01691.01637.01586.01539 22.02197.02114.02036.01963.01895.01830.01770.01713.01660.01610 23.02306.02218.02136.02059.01987.01919.01855.01795.01739.01686 24.02424.02331.02245.02163.02087.02016.01948.01885.01825.01769 25.02552.02455.02364.02278.02197.02122.02051.01984.01920.01861 26.02692.02589.02493.02403.02318.02238.02162.02091.02025.01961 27.02846.02738.02636.02541.02451.02367.02287.02212.02141.02074 28.03012.02898.02791.02690.02595.02506.02422.02342.02267.02196 29.03190.03070.02957.02851.02751.02656.02567.02483.02404.02329 30.03381.03254.03135.03023.02917.02817.02723.02634.02551.02471 31.03583.03450.03324.03206.03094.02989.02890.02796.02707.02623 32.03799.03659.03527.03402.03284.03173.03068.02968.02874.02785 33.04031.03883.03744.03612.03488.03371.03260.03155.03055.02961 34.04279.04123.03976.03838.03707.03583.03465.03354.03249.03149 35.04545.04382.04227.04081.03943.03812.03688.03571.03459.03354 36.04830.04658.04495.04341.04196.04058.03927.03803.03685.03573 37.05134.04953.04782.04620.04467.04321.04183.04052.03928.03809 38.05462.05272.05092.04921.04760.04606.04461.04322.04191.04066 39.05812.05613.05424.05245.05075.04913.04760.04614.04475.04343 40.06190.05981.05782.05594.05415.05245.05083.04929.04783.04643 41.06597.06378.06170.05972.05784.05605.05435.05272.05118.04970 42.07035.06806.06587.06380.06182.05994.05815.05644.05481.05326 43.07505.07265.07036.06818.06611.06414.06225.06045.05874.05710 44.08008.07757.07518.07290.07072.06865.06667.06478.06298.06125 45.08542.08279.08029.07791.07563.07346.07138.06940.06750.06569 46.09108.08834.08573.08324.08085.07858.07640.07432.07233.07043 47.09705.09419.09147.08886.08637.08399.08172.07954.07745.07545 48.10335.10038.09754.09482.09222.08973.08735.08507.08288.08078 49.10999.10690.10394.10111.09840.09581.09332.09093.08864.08644 50.11701.11380.11073.10778.10496.10225.09965.09716.09477.09247 51.12441.12108.11789.11482.11189.10907.10636.10376.10126.09886 52.13217.12871.12540.12222.11916.11623.11341.11071.10810.10560 53.14028.13670.13327.12997.12680.12375.12082.11801.11529.11268 54.14875.14505.14150.13808.13480.13163.12859.12566.12284.12012 55.15760.15378.15011.14657.14317.13989.13674.13370.13077.12794 56.16684.16290.15911.15546.15194.14855.14528.14213.13909.13615 57.17648.17242.16851.16474.16111.15760.15422.15096.14781.14477 58.18647.18229.17827.17438.17064.16702.16353.16015.15689.15374 59.19678.19249.18835.18435.18049.17676.17316.16968.16631.16305 July 3, 2000162000–27 I.R.B. TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0% 60.20740.20300.19875.19464.19066.18682.18311.17952.17604.17268 61.21837.21385.20949.20527.20119.19724.19341.18971.18613.18266 62.22973.22511.22064.21631.21212.20807.20414.20033.19664.19306 63.24152.23680.23222.22779.22350.21934.21530.21139.20760.20392 64.25372.24890.24422.23969.23529.23103.22690.22289.21899.21521 65.26633.26141.25664.25201.24752.24316.23893.23482.23083.22695 66.27940.27439.26953.26481.26023.25577.25145.24724.24316.23918 67.29299.28790.28296.27815.27348.26894.26453.26024.25606.25200 68.30709.30193.29691.29202.28728.28265.27816.27378.26952.26537 69.32166.31643.31134.30639.30157.29687.29230.28785.28351.27928 70.33661.33133.32618.32116.31628.31152.30688.30235.29794.29364 71.35188.34654.34134.33627.33133.32651.32181.31722.31275.30838 72.36742.36204.35679.35168.34668.34181.33706.33241.32788.32345 73.38317.37776.37248.36733.36229.35738.35257.34788.34330.33882 74.39923.39380.38849.38330.37823.37328.36844.36370.35908.35455 75.41566.41021.40489.39968.39459.38961.38474.37997.37531.37074 76.43254.42709.42176.41655.41144.40645.40156.39677.39208.38749 77.44988.44444.43912.43391.42880.42380.41891.41411.40940.40479 78.46765.46224.45694.45174.44665.44166.43677.43197.42726.42265 79.48574.48037.47510.46993.46487.45990.45502.45024.44554.44094 80.50397.49865.49343.48830.48327.47834.47349.46873.46406.45947 81.52219.51693.51176.50669.50171.49682.49201.48729.48265.47809 82.54029.53510.53000.52499.52007.51523.51047.50580.50120.49667 83.55826.55315.54813.54319.53834.53356.52886.52424.51969.51522 84.57624.57123.56629.56144.55666.55195.54732.54277.53828.53386 85.59435.58944.58460.57984.57516.57054.56599.56151.55710.55275 86.61241.60762.60289.59824.59365.58913.58468.58029.57596.57170 87.63015.62548.62087.61633.61185.60744.60309.59880.59456.59039 88.64753.64299.63851.63409.62973.62543.62118.61700.61287.60879 89.66454.66013.65579.65150.64726.64308.63895.63488.63086.62689 90.68115.67689.67268.66853.66442.66037.65637.65241.64851.64465 91.69706.69294.68887.68486.68089.67696.67309.66925.66547.66173 92.71190.70792.70399.70011.69627.69247.68872.68501.68134.67771 93.72569.72184.71804.71429.71057.70689.70326.69967.69611.69259 94.73861.73490.73123.72759.72400.72044.71692.71344.71000.70659 95.75097.74739.74384.74033.73686.73342.73002.72665.72331.72001 96.76267.75922.75579.75240.74905.74572.74243.73917.73595.73275 97.77356.77022.76691.76363.76039.75718.75399.75084.74772.74463 98.78382.78059.77740.77423.77110.76799.76491.76186.75884.75584 99.79390.79079.78771.78465.78162.77862.77565.77270.76978.76688 100.80376.80076.79779.79485.79193.78904.78617.78333.78051.77771 101.81353.81066.80780.80497.80217.79938.79662.79388.79117.78847 102.82318.82042.81768.81496.81227.80960.80694.80431.80170.79911 103.83278.83014.82752.82491.82233.81977.81723.81470.81220.80971 104.84310.84059.83810.83563.83317.83073.82831.82591.82352.82115 2000–27 I.R.B.17July 3, 2000 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0% 105.85318.85079.84843.84607.84374.84142.83911.83682.83455.83229 106.86633.86413.86193.85975.85758.85543.85329.85116.84904.84694 107.88247.88049.87852.87656.87460.87266.87073.86881.86690.86500 108.90825.90666.90507.90350.90193.90037.89881.89727.89572.89419 109.95372.95290.95208.95126.95045.94964.94883.94803.94723.94643 July 3, 2000182000–27 I.R.B. TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE12.2%12.4%12.6%12.8%13.0%13.2%13.4%13.6%13.8%14.0% 0.01298.01285.01273.01261.01250.01240.01230.01221.01212.01203 1.00468.00455.00443.00431.00420.00410.00400.00391.00382.00374 2.00448.00435.00421.00409.00398.00387.00376.00366.00357.00348 3.00452.00437.00423.00410.00398.00386.00375.00365.00355.00345 4.00468.00452.00437.00423.00410.00397.00386.00375.00364.00354 5.00493.00476.00460.00445.00431.00418.00405.00393.00382.00371 6.00524.00506.00489.00473.00458.00444.00430.00418.00406.00394 7.00562.00543.00525.00508.00492.00477.00462.00449.00436.00423 8.00606.00586.00566.00548.00531.00515.00499.00485.00471.00458 9.00659.00637.00616.00597.00579.00561.00545.00529.00514.00500 10.00721.00698.00676.00655.00636.00617.00600.00583.00567.00552 11.00792.00767.00744.00722.00701.00682.00663.00645.00628.00612 12.00871.00845.00821.00797.00775.00754.00735.00716.00698.00681 13.00955.00928.00902.00877.00854.00831.00810.00790.00771.00753 14.01038.01009.00981.00955.00930.00907.00885.00864.00843.00824 15.01116.01085.01056.01028.01002.00977.00954.00932.00910.00890 16.01186.01153.01123.01094.01066.01040.01015.00992.00969.00948 17.01250.01215.01183.01152.01124.01096.01070.01045.01022.00999 18.01308.01272.01238.01206.01175.01147.01119.01093.01068.01044 19.01367.01329.01293.01259.01227.01196.01167.01140.01113.01088 20.01428.01388.01350.01314.01280.01248.01217.01188.01161.01134 21.01494.01451.01411.01373.01337.01303.01271.01240.01211.01183 22.01562.01517.01475.01435.01397.01361.01326.01294.01263.01233 23.01635.01588.01543.01501.01460.01422.01386.01351.01319.01287 24.01716.01665.01618.01573.01530.01489.01451.01415.01380.01347 25.01804.01751.01701.01653.01608.01565.01524.01485.01448.01413 26.01902.01845.01792.01741.01693.01648.01604.01563.01524.01487 27.02011.01951.01895.01841.01790.01742.01696.01652.01610.01571 28.02129.02066.02006.01949.01895.01844.01795.01748.01704.01662 29.02258.02191.02127.02067.02009.01955.01903.01853.01806.01762 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE12.2%12.4%12.6%12.8%13.0%13.2%13.4%13.6%13.8%14.0% 30.02396.02325.02257.02193.02132.02074.02019.01966.01916.01869 31.02543.02467.02396.02328.02263.02201.02143.02087.02034.01983 32.02701.02621.02545.02472.02404.02338.02276.02217.02160.02106 33.02871.02786.02706.02629.02556.02487.02420.02357.02297.02240 34.03054.02964.02879.02797.02720.02646.02576.02509.02445.02383 35.03253.03158.03067.02981.02898.02820.02745.02674.02606.02541 36.03467.03366.03269.03178.03090.03007.02928.02852.02779.02710 37.03697.03590.03488.03391.03298.03209.03125.03044.02967.02893 38.03947.03833.03725.03622.03524.03430.03340.03254.03172.03094 39.04217.04096.03982.03873.03768.03669.03573.03482.03395.03312 40.04510.04383.04262.04146.04035.03930.03828.03732.03639.03550 41.04830.04695.04567.04445.04327.04215.04108.04005.03907.03812 42.05177.05035.04900.04770.04646.04527.04413.04304.04200.04100 43.05553.05404.05261.05123.04992.04866.04746.04630.04520.04413 44.05960.05802.05651.05506.05368.05235.05107.04985.04867.04754 45.06395.06229.06069.05917.05770.05630.05495.05365.05241.05121 46.06860.06685.06517.06356.06202.06053.05911.05774.05643.05516 47.07353.07169.06992.06823.06660.06504.06353.06209.06070.05936 48.07877.07684.07498.07320.07149.06984.06826.06673.06527.06385 49.08433.08231.08036.07849.07669.07495.07329.07168.07013.06864 50.09026.08814.08609.08413.08224.08042.07867.07698.07535.07378 51.09655.09433.09219.09013.08815.08624.08440.08262.08091.07926 52.10318.10086.09863.09647.09439.09239.09046.08860.08680.08506 53.11017.10774.10541.10315.10098.09888.09686.09491.09302.09120 54.11750.11498.11254.11019.10792.10572.10361.10156.09958.09767 55.12522.12258.12005.11759.11522.11294.11072.10859.10652.10451 56.13332.13059.12794.12539.12292.12054.11823.11599.11383.11174 57.14183.13899.13624.13359.13102.12853.12613.12380.12154.11936 58.15070.14775.14490.14215.13948.13689.13439.13197.12962.12734 59.15990.15685.15389.15103.14826.14558.14298.14046.13801.13564 60.16942.16626.16321.16024.15737.15459.15189.14927.14673.14426 61.17929.17603.17287.16981.16684.16395.16115.15844.15580.15324 62.18960.18623.18297.17980.17673.17375.17085.16803.16530.16264 63.20035.19688.19352.19025.18708.18400.18100.17809.17525.17250 64.21154.20797.20451.20114.19787.19469.19159.18859.18566.18281 65.22318.21951.21595.21249.20912.20584.20265.19955.19652.19358 66.23532.23156.22790.22434.22088.21751.21422.21102.20791.20487 67.24804.24419.24044.23679.23324.22977.22640.22311.21990.21678 68.26133.25740.25356.24983.24618.24263.23917.23579.23250.22929 69.27516.27114.26723.26341.25969.25605.25251.24905.24567.24237 70.28945.28536.28137.27747.27367.26996.26633.26279.25934.25596 71.30412.29996.29590.29193.28806.28427.28057.27696.27343.26998 72.31913.31491.31078.30675.30281.29895.29519.29150.28790.28438 73.33444.33016.32597.32188.31788.31396.31013.30638.30271.29913 74.35012.34579.34155.33741.33335.32938.32549.32168.31795.31430 2000–27 I.R.B.19July 3, 2000 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE12.2%12.4%12.6%12.8%13.0%13.2%13.4%13.6%13.8%14.0% 75.36628.36190.35762.35343.34932.34530.34136.33750.33372.33001 76.38299.37858.37427.37004.36589.36183.35784.35394.35011.34636 77.40028.39585.39151.38725.38307.37898.37496.37103.36716.36337 78.41812.41368.40933.40506.40086.39675.39271.38874.38485.38103 79.43641.43198.42762.42334.41914.41502.41096.40698.40308.39924 80.45496.45054.44619.44192.43772.43360.42954.42556.42164.41779 81.47360.46920.46487.46061.45643.45231.44827.44429.44038.43653 82.49223.48785.48355.47932.47516.47106.46703.46307.45916.45532 83.51081.50648.50221.49802.49388.48982.48581.48187.47799.47416 84.52951.52523.52101.51686.51277.50874.50477.50086.49701.49321 85.54847.54425.54009.53600.53196.52798.52406.52019.51638.51262 86.56749.56335.55926.55523.55126.54734.54348.53966.53591.53220 87.58627.58221.57820.57425.57035.56650.56270.55895.55526.55161 88.60477.60079.59688.59301.58919.58542.58170.57802.57439.57081 89.62297.61909.61527.61149.60776.60408.60044.59685.59330.58979 90.64084.63707.63335.62968.62604.62246.61891.61540.61194.60851 91.65803.65437.65076.64719.64366.64017.63672.63330.62993.62659 92.67412.67058.66707.66360.66017.65678.65342.65010.64682.64357 93.68911.68567.68227.67890.67557.67227.66901.66578.66258.65942 94.70321.69988.69657.69330.69006.68686.68369.68055.67744.67437 95.71674.71351.71031.70713.70399.70088.69781.69476.69174.68875 96.72959.72646.72335.72028.71724.71422.71123.70828.70534.70244 97.74156.73853.73552.73254.72959.72666.72376.72089.71804.71522 98.75287.74993.74702.74413.74126.73842.73561.73282.73006.72732 99.76401.76117.75834.75555.75277.75002.74730.74459.74191.73926 100.77494.77219.76946.76676.76408.76142.75878.75616.75357.75099 101.78580.78315.78052.77791.77532.77275.77021.76768.76517.76268 102.79654.79399.79146.78894.78645.78397.78152.77908.77666.77426 103.80724.80479.80236.79994.79755.79517.79280.79046.78813.78582 104.81879.81646.81413.81183.80954.80726.80501.80276.80054.79832 105.83005.82782.82560.82340.82121.81904.81688.81474.81260.81049 106.84485.84277.84071.83866.83662.83459.83257.83057.82857.82659 107.86311.86124.85937.85751.85566.85382.85199.85017.84835.84655 108.89266.89114.88963.88812.88662.88513.88364.88216.88068.87922 109.94563.94484.94405.94326.94248.94170.94092.94014.93937.93860 July 3, 2000202000–27 I.R.B. (f) Effective dates.This section applies after April 30, 1999. §1.642(c)–6T [Removed] Par. 6. Section 1.642(c)–6T is re- moved. Par. 7. Section 1.664–4 is amended by: 1. Revising paragraphs (a)(1). 2. Removing existing paragraphs (d) through (e)(5). 3. Adding paragraphs (d), (e) heading and (e)(1) through (e)(5). 4. Adding paragraph (e)(7). 5. Revising paragraph (f). The revisions and additions read as fol- lows: §1.664–4 Calculation of the fair market value of the remainder interest in a chari- table remainder unitrust. (a) * * * (1) Life contingencies determined as to each life involved, from the values oflxset forth in Table 90CM contained in §20.2031–7(d)(7) of this chapter in the case of transfers for which the valuation date is after April 30, 1999; or from Table 80CNSMT contained §20.2031–7A(e)(4) of this chapter in the case of transfer for which the valuation date is after April 30, 1989, and before May 1, 1999. See §20.2031–7A(a) through (d) of this chapter, whichever is ap- plicable, for transfers for which the valuation date is before May 1, 1989; * * * * * (d) Valuation. The fair market value of a remainder interest in a charitable remainder unitrust (as described in §1.664–3) for transfers for which the valuation date is after April 30, 1999, is its present value de- termined under paragraph (e) of this sec- tion. The fair market value of a remainder interest in a charitable remainder unitrust (as described in §1.664–3) for transfers for which the valuation date is before May 1, 1999, is its present value determined under the following sections: 2000–27 I.R.B.21July 3, 2000 ValuationDatesApplicable AfterBeforeRegulations 01-01-521.664–4A(a) 12-31-5101-01-711.664–4A(b) 12-31-7012-01-831.664–4A(c) 11-30-8305-01-891.664–4A(d) 04-30-8905-01-991.664–4A(e) (e) Valuation of charitable remainder unitrusts having certain payout sequences for transfers for which the valuation date is after April 30, 1999—(1) In general. Except as otherwise provided in para- graph (e)(2) of this section, in the case of transfers for which the valuation date is after April 30, 1999, the present value of a remainder interest is determined under paragraphs (e)(3) through (e)(7) of this section, provided that the amount of the payout as of any payout date during any taxable year of the trust is not larger than the amount that the trust could distribute on such date under §1.664–3(a)(1)(v) if the taxable year of the trust were to end on such date. See, however, §1.7520–3(b) (relating to exceptions to the use of the prescribed tables under cer- tain circumstances). (2) Transitional rules for valuation of charitable remainder unitrusts. (i) For purposes of sections 2055, 2106, or 2624, if on May 1, 1999, the decedent was men- tally incompetent so that the disposition of the property could not be changed, and the decedent died after April 30, 1999, without having regained competency to dispose of the decedent’s property, or the decedent died within 90 days of the date that the decedent first regained compe- tency after April 30, 1999, the present value of a remainder interest under this section is determined as if the valuation date with respect to the decedent’s gross estate is either before May 1, 1999, or after April 30, 1999, at the option of the decedent’s executor. (ii) For purposes of sections 170, 2055, 2106, 2522, or 2624, in the case of trans- fers to a charitable remainder unitrust for which the valuation date is after April 30, 1999, and before July 1, 1999, the present value of a remainder interest based on one or more measuring lives is determined under this section by use of the section 7520 interest rate for the month in which the valuation date occurs (see §§1.7520–1(b) and 1.7520–2(a)(2)) and the appropriate actuarial tables under ei- ther paragraph (e)(7) of this section or §1.664–4A(e)(6), at the option of the donor or the decedent’s executor, as the case may be. (iii) For purposes of paragraphs (e)(2)(i) and (ii) of this section, where the donor or decedent’s executor is given the option to use the appropriate actuarial ta- bles under either paragraph (e)(7) of this section or §1.664–4A(e)(6), the donor or decedent’s executor must use the same ac- tuarial table with respect to each individ- ual transaction and with respect to all transfers occurring on the valuation date (for example, gift and income tax charita- ble deductions with respect to the same transfer must be determined based on the same tables, and all assets includible in the gross estate and/or estate tax deduc- tions claimed must be valued based on the same tables). (3) Adjusted payout rate. For transfers for which the valuation date is after April 30, 1989, the adjusted payout rate is de- termined by using the appropriate Table F in paragraph (e)(6) of this section, for the section 7520 interest rate applicable to the transfer. If the interest rate is between 4.2 and 14 percent, see paragraph (e)(6) of this section. If the interest rate is below 4.2 percent or greater than 14 percent, see paragraph (b) of this section. The ad- justed payout rate is determined by multi- plying the fixed percentage described in §1.664–3(a)(1)(i)(a) by the factor de- scribing the payout sequence of the trust and the number of months by which the valuation date for the first full taxable year of the trust precedes the first payout date for such taxable year. If the govern- ing instrument does not prescribe when the distribution or distributions shall be made during the taxable year of the trust, see paragraph (a) of this section. In the case of a trust having a payout sequence for which no figures have been provided by the appropriate table, and in the case of a trust that determines the fair market value of the trust assets by taking the av- erage of valuations on more than one date during the taxable year, see paragraph (b) of this section. (4) Period is a term of years. If the pe- riod described in §1.664–3(a)(5) is a term of years, the factor that is used in deter- mining the present value of the remainder interest for transfers for which the valua- tion date is after November 30, 1983, is the factor under the appropriate adjusted payout rate in Table D of paragraph (e)(6) of this section corresponding to the num- ber of years in the term. If the adjusted payout rate is an amount that is between adjusted payout rates for which factors are provided in Table D, a linear interpolation must be made. The present value of the remainder interest is determined by multi- plying the net fair market value (as of the appropriate valuation date) of the property placed in trust by the factor determined under this paragraph. For purposes of this section, the valuation date is, in the case of an inter vivos transfer, the date on which the property is transferred to the trust by the donor. However, if an election is made under section 7520 and §1.7520–2(b) to compute the present value of the charita- ble interest by use of the interest rate com- ponent for either of the 2 months preced- ing the month in which the date of transfer falls, the month so elected is the valuation date for purposes of determining the inter- est rate and mortality tables. In the case of a testamentary transfer under section 2055, 2106, or 2624, the valuation date is the date of death, unless the alternate valu- ation date is elected under section 2032, in which event, and within the limitations set forth in section 2032 and the regulations thereunder, the valuation date is the alter- nate valuation date. If the decedent’s es- tate elects the alternate valuation date under section 2032 and also elects, under section 7520 and §1.7520–2(b), to use the interest rate component for one of the 2 months preceding the alternate valuation date, the month so elected is the valuation date for purposes of determining the inter- est rate and mortality tables. The applica- tion of this paragraph (e)(4) may be illus- trated by the following example: Example. D transfers $100,000 to a charitable re- mainder unitrust on January 1. The trust instrument requires that the trust pay 8 percent of the fair mar- ket value of the trust assets as of January 1st for a term of 12 years to D in quarterly payments (March 31, June 30, September 30, and December 31). The section 7520 rate for January (the month that the transfer occurred) is 9.6 percent. Under Table F(9.6) in paragraph(e)(6) of this section, the appropriate adjustment factor is .944628 for quarterly payments payable at the end of each quarter. The adjusted payout rate is 7.557 (8% X .944628). Based on the remainder factors in Table D in paragraph(e)(6) of this section, the present value of the remainder inter- est is $38,950.30, computed as follows: Factor at 7.4 percent for 12 years . . . . .397495 Factor at 7.6 percent for 12 years . . . . .387314 Difference . . . . . . . . . . . . . . . . . . . . . . .010181 Interpolation adjustment: 7.557% - 7.4% = x 0.2%.010181 x = .007992 Factor at 7.4 percent for 12 years . . . . .397495 Less: Interpolation adjustment . . . . . . . .007992 Interpolated factor . . . . . . . . . . . . . . . . .389503 Present value of remainder interest: ($100,000 X .389503) . . . . . . . . . $38,950.30 (5) Period is the life of one individual. If the period described in §1.664–3(a)(5) is the life of one individual, the factor that is used in determining the present value of the remainder interest for transfers for which the valuation date is after April 30, 1999, is the factor in Table U(1) in para- graph (e)(7) of this section under the ap- propriate adjusted payout. For purposes of the computations described in this paragraph, the age of an individual is the age of that individual at the individual’s nearest birthday. If the adjusted payout rate is an amount that is between adjusted payout rates for which factors are pro- vided in the appropriate table, a linear in- terpolation must be made. The present value of the remainder interest is deter- mined by multiplying the net fair market value (as of the valuation date as deter- mined in paragraph (e)(4) of this section) of the property placed in trust by the fac- tor determined under this paragraph (e)(5). If the adjusted payout rate is be- tween 4.2 and 14 percent, see paragraph (e)(7) of this section. If the adjusted pay- out rate is below 4.2 percent or greater than 14 percent, see paragraph (b) of this section. The application of this paragraph (e)(5) may be illustrated by the following example: Example. A, who is 44 years and 11 months old, transfers $100,000 to a charitable remainder unitrust on January 1st. The trust instrument requires that the trust pay to A semiannually (on June 30 and De- cember 31) 9 percent of the fair market value of the trust assets as of January 1st during A’s life. The section 7520 rate for January is 9.6 percent. Under Table F(9.6) in paragraph (e)(6) of this section, the appropriate adjustment factor is .933805 for semian- nual payments payable at the end of the semiannual period. The adjusted payout rate is 8.404 (9% X .933805). Based on the remainder factors in Table U(1) in paragraph (e)(7) of this section, the present value of the remainder interest is $10,109.00, com- puted as follows: Factor at 8.4 percent at age 45 . . . . . . .10117 Factor at 8.6 percent at age 45 . . . . . . .09715 Difference . . . . . . . . . . . . . . . . . . . . . . .00402 Interpolation adjustment: 8.404% - 8.4%=x 0.2%.00402 x = .00008 Factor at 8.4 percent at age 45 . . . . . . .10117 Less: Interpolation adjustment . . . . . . .00008 Interpolated Factor . . . . . . . . . . . . . . . .10109 Present value of remainder interest: ($100,000 X .10109) . . . . . . . . . . $10,109.00 * * * * * (7) Actuarial Table U(1) for transfers for which the valuation date is after April 30, 1999. For transfers for which the val- uation date is after April 30, 1999, the present value of a charitable remainder unitrust interest that is dependent on the termination of a life interest is determined by using the section 7520 rate, Table U(1) in this paragraph (e)(7), and Table F(4.2) through (14.0) in paragraph (e)(6) of this section. See, however, §1.7520–3(b) (re- lating to exceptions to the use of pre- scribed tables under certain circum- stances). Many actuarial factors not contained in the following tables are con- tained in Internal Revenue Service Publi- cation 1458, “Actuarial Values, Book Beth,” (7-1999). A copy of this publica- tion is available for purchase from the Su- perintendent of Documents, United States Government Printing Office, Washington, DC 20402. July 3, 2000222000–27 I.R.B. TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0% 0.06177.05580.05061.04609.04215.03871.03570.03307.03075.02872 1.05543.04925.04388.03919.03509.03151.02838.02563.02321.02109 2.05716.05081.04528.04045.03622.03252.02927.02642.02391.02170 3.05920.05268.04699.04201.03765.03382.03046.02750.02490.02260 4.06143.05475.04889.04376.03926.03530.03182.02876.02605.02366 5.06384.05697.05095.04567.04103.03694.03334.03016.02735.02487 6.06637.05933.05315.04771.04292.03870.03497.03168.02876.02618 7.06905.06183.05547.04987.04494.04058.03673.03332.03029.02761 8.07186.06445.05792.05216.04708.04258.03859.03506.03192.02914 9.07482.06722.06052.05460.04936.04471.04060.03694.03369.03079 10.07793.07015.06327.05718.05179.04700.04274.03896.03559.03259 11.08120.07323.06617.05991.05435.04942.04502.04111.03762.03450 12.08461.07645.06920.06277.05706.05197.04744.04339.03978.03655 13.08812.07976.07234.06574.05985.05461.04993.04576.04202.03867 14.09168.08313.07552.06874.06269.05729.05247.04815.04428.04081 15.09527.08652.07872.07176.06554.05999.05501.05055.04655.04296 16.09886.08991.08192.07478.06839.06267.05754.05294.04880.04508 17.10249.09334.08515.07782.07126.06537.06008.05533.05105.04720 18.10616.09680.08842.08090.07415.06809.06264.05774.05332.04933 19.10994.10037.09178.08407.07714.07091.06529.06023.05566.05153 20.11384.10406.09527.08737.08025.07383.06805.06283.05811.05384 21.11790.10790.09891.09080.08349.07690.07094.06555.06068.05626 22.12208.11188.10267.09436.08686.08008.07395.06839.06336.05879 23.12643.11601.10659.09808.09038.08342.07710.07138.06618.06146 24.13095.12031.11069.10197.09408.08692.08042.07452.06915.06427 25.13567.12481.11497.10605.09795.09060.08392.07784.07230.06726 26.14058.12950.11945.11032.10202.09447.08760.08134.07563.07042 27.14571.13442.12415.11481.10631.09856.09149.08505.07916.07379 28.15104.13953.12904.11949.11078.10284.09558.08895.08288.07733 29.15656.14484.13414.12438.11546.10731.09986.09304.08679.08106 30.16229.15034.13943.12946.12034.11198.10433.09732.09089.08498 31.16821.15605.14493.13474.12541.11685.10900.10179.09517.08909 32.17433.16196.15063.14023.13069.12193.11387.10647.09966.09339 33.18068.16810.15655.14595.13620.12723.11897.11137.10437.09791 34.18724.17446.16270.15189.14193.13275.12430.11650.10930.10265 35.19405.18107.16910.15808.14791.13853.12987.12187.11448.10764 36.20109.18791.17574.16451.15414.14456.13569.12749.11990.11287 37.20838.19500.18263.17120.16062.15083.14177.13337.12558.11835 38.21593.20236.18979.17816.16739.15739.14813.13953.13154.12412 39.22374.20998.19723.18540.17443.16423.15477.14597.13779.13017 40.23183.21789.20496.19294.18177.17138.16172.15272.14434.13653 41.24021.22611.21299.20079.18943.17885.16899.15980.15123.14322 42.24889.23463.22134.20896.19741.18665.17660.16721.15845.15025 43.25786.24344.23000.21744.20572.19477.18453.17496.16601.15762 44.26712.25257.23896.22625.21435.20322.19281.18305.17391.16534 2000–27 I.R.B.23July 3, 2000 TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0% 45.27665.26196.24821.23534.22328.21198.20139.19145.18213.17338 46.28644.27163.25774.24472.23251.22105.21028.20018.19068.18174 47.29647.28155.26754.25438.24201.23040.21947.20919.19952.19041 48.30676.29173.27760.26431.25181.24004.22896.21852.20868.19941 49.31729.30217.28794.27453.26190.24999.23876.22817.21817.20873 50.32808.31289.29856.28505.27229.26026.24889.23814.22799.21839 51.33912.32387.30946.29585.28299.27083.25933.24845.23815.22840 52.35038.33507.32060.30691.29395.28168.27005.25904.24861.23872 53.36185.34651.33198.31821.30517.29280.28106.26993.25937.24934 54.37352.35815.34358.32976.31664.30418.29234.28110.27042.26026 55.38539.37002.35542.34155.32836.31583.30390.29256.28177.27149 56.39746.38209.36748.35358.34034.32774.31574.30431.29342.28303 57.40971.39437.37976.36584.35257.33992.32785.31634.30536.29488 58.42212.40682.39222.37829.36500.35231.34019.32862.31756.30699 59.43464.41939.40482.39090.37759.36488.35272.34109.32996.31932 60.44726.43207.41754.40364.39034.37761.36542.35375.34257.33186 61.45999.44488.43041.41655.40326.39053.37833.36662.35540.34463 62.47286.45785.44345.42964.41639.40367.39146.37974.36848.35767 63.48589.47098.45667.44293.42972.41703.40484.39311.38184.37100 64.49903.48426.47005.45638.44324.43060.41843.40671.39544.38458 65.51229.49766.48357.47001.45694.44435.43223.42054.40927.39841 66.52568.51121.49726.48381.47084.45833.44626.43461.42337.41252 67.53924.52495.51115.49784.48498.47256.46056.44898.43778.42696 68.55293.53883.52521.51205.49932.48701.47511.46360.45246.44169 69.56671.55283.53940.52640.51382.50165.48985.47844.46738.45666 70.58052.56687.55365.54084.52843.51639.50473.49342.48245.47181 71.59431.58091.56791.55529.54306.53118.51966.50847.49761.48707 72.60804.59490.58213.56973.55768.54598.53461.52357.51283.50239 73.62168.60881.59629.58411.57227.56076.54955.53866.52806.51774 74.63528.62268.61042.59848.58686.57555.56453.55380.54335.53316 75.64887.63657.62458.61290.60151.59041.57959.56904.55875.54872 76.66249.65049.63880.62739.61625.60538.59478.58443.57432.56446 77.67612.66446.65307.64194.63108.62046.61009.59995.59005.58037 78.68975.67843.66736.65654.64596.63561.62548.61558.60590.59643 79.70330.69233.68160.67109.66081.65074.64088.63123.62178.61253 80.71666.70605.69566.68548.67550.66573.65615.64676.63755.62853 81.72975.71950.70946.69961.68995.68047.67117.66205.65310.64433 82.74250.73263.72293.71342.70407.69490.68589.67705.66837.65984 83.75493.74542.73608.72690.71788.70902.70031.69175.68333.67506 84.76712.75798.74900.74016.73147.72292.71451.70624.69810.69010 85.77913.77037.76175.75326.74491.73668.72859.72061.71276.70503 86.79086.78248.77423.76610.75808.75019.74241.73474.72719.71974 87.80218.79418.78628.77850.77083.76326.75580.74844.74118.73402 88.81307.80544.79790.79047.78313.77589.76874.76169.75473.74786 89.82355.81628.80909.80200.79500.78808.78125.77450.76783.76125 July 3, 2000242000–27 I.R.B. TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0% 90.83360.82668.81985.81309.80642.79982.79330.78685.78048.77418 91.84308.83650.83000.82357.81721.81092.80470.79855.79246.78645 92.85182.84556.83937.83325.82718.82119.81525.80937.80356.79780 93.85985.85390.84800.84215.83637.83064.82497.81936.81379.80829 94.86732.86164.85601.85044.84491.83944.83402.82865.82333.81806 95.87437.86895.86359.85827.85300.84778.84260.83746.83237.82733 96.88097.87582.87070.86563.86060.85561.85066.84575.84088.83605 97.88708.88216.87727.87243.86762.86285.85811.85341.84875.84413 98.89280.88810.88343.87880.87420.86964.86511.86061.85614.85171 99.89836.89388.88943.88501.88062.87626.87193.86763.86336.85911 100.90375.89948.89525.89103.88685.88269.87856.87445.87037.86632 101.90905.90500.90097.89696.89298.88902.88509.88118.87729.87342 102.91424.91040.90658.90278.89900.89524.89150.88778.88408.88040 103.91939.91575.91214.90854.90496.90139.89785.89432.89081.88732 104.92485.92144.91805.91467.91131.90796.90463.90131.89800.89471 105.93020.92701.92383.92067.91751.91437.91125.90813.90502.90193 106.93701.93411.93122.92834.92546.92260.91974.91689.91405.91122 107.94522.94268.94013.93760.93507.93254.93002.92750.92499.92249 108.95782.95583.95385.95187.94989.94791.94593.94396.94199.94002 109.97900.97800.97700.97600.97500.97400.97300.97200.97100.97000 2000–27 I.R.B.25July 3, 2000 TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0% 0.02693.02534.02395.02271.02161.02063.01976.01898.01828.01765 1.01922.01756.01610.01480.01365.01263.01171.01090.01017.00951 2.01975.01802.01650.01514.01393.01286.01190.01104.01028.00959 3.02056.01876.01717.01575.01449.01336.01235.01145.01064.00992 4.02155.01967.01800.01652.01520.01401.01296.01201.01116.01039 5.02266.02071.01896.01741.01603.01479.01368.01269.01179.01098 6.02389.02184.02003.01841.01696.01566.01450.01345.01251.01166 7.02522.02309.02120.01950.01799.01663.01540.01431.01332.01242 8.02665.02444.02246.02069.01910.01768.01640.01524.01420.01326 9.02821.02590.02384.02199.02033.01884.01750.01629.01520.01421 10.02990.02750.02535.02342.02169.02013.01872.01745.01631.01526 11.03172.02922.02698.02497.02316.02153.02006.01872.01752.01643 12.03365.03106.02872.02663.02474.02303.02149.02010.01884.01769 13.03566.03297.03054.02835.02638.02460.02299.02154.02021.01901 14.03770.03490.03237.03010.02804.02619.02450.02298.02159.02033 TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0% 15.03973.03682.03419.03182.02968.02775.02599.02439.02294.02162 16.04173.03871.03598.03352.03129.02926.02743.02576.02424.02286 17.04372.04059.03775.03519.03287.03076.02884.02710.02551.02406 18.04573.04248.03953.03686.03444.03224.03024.02842.02676.02524 19.04780.04443.04137.03859.03607.03378.03169.02978.02804.02646 20.04997.04647.04329.04040.03778.03539.03321.03122.02940.02773 21.05226.04862.04532.04232.03958.03709.03481.03274.03083.02909 22.05465.05088.04745.04432.04148.03888.03650.03433.03234.03052 23.05716.05325.04969.04645.04348.04077.03830.03603.03394.03203 24.05983.05578.05208.04871.04562.04280.04021.03784.03566.03367 25.06266.05846.05463.05112.04791.04497.04227.03980.03752.03543 26.06566.06131.05734.05369.05035.04729.04448.04189.03951.03732 27.06887.06436.06024.05646.05298.04979.04686.04416.04168.03939 28.07225.06758.06331.05938.05577.05245.04940.04658.04398.04159 29.07581.07099.06656.06248.05873.05528.05210.04916.04645.04394 30.07956.07457.06998.06575.06186.05827.05495.05189.04906.04644 31.08348.07833.07358.06920.06515.06142.05797.05478.05182.04908 32.08761.08228.07736.07282.06863.06475.06116.05783.05475.05189 33.09195.08645.08136.07666.07231.06828.06454.06108.05786.05488 34.09651.09082.08557.08070.07619.07200.06812.06452.06117.05805 35.10131.09545.09002.08498.08030.07596.07193.06818.06469.06144 36.10635.10031.09470.08949.08465.08015.07596.07206.06842.06503 37.11165.10542.09963.09424.08923.08457.08022.07617.07238.06885 38.11722.11081.10484.09927.09409.08926.08475.08054.07661.07293 39.12308.11648.11032.10458.09922.09422.08955.08518.08109.07726 40.12925.12246.11612.11020.10466.09949.09465.09011.08587.08189 41.13575.12877.12225.11614.11043.10508.10007.09537.09097.08683 42.14259.13542.12871.12243.11654.11101.10583.10097.09640.09210 43.14977.14242.13552.12905.12298.11729.11193.10690.10217.09771 44.15731.14976.14269.13604.12979.12391.11838.11318.10828.10367 45.16516.15743.15017.14334.13691.13086.12516.11979.11472.10994 46.17334.16544.15800.15099.14438.13816.13228.12674.12150.11656 47.18184.17375.16613.15895.15217.14576.13972.13400.12860.12349 48.19066.18240.17461.16724.16029.15371.14749.14161.13604.13077 49.19981.19138.18342.17588.16875.16201.15562.14956.14383.13839 50.20931.20072.19259.18489.17759.17067.16412.15790.15199.14639 51.21917.21042.20212.19426.18679.17971.17299.16660.16054.15477 52.22933.22043.21198.20395.19633.18909.18220.17566.16943.16350 53.23981.23076.22216.21399.20621.19881.19176.18506.17867.17258 54.25060.24141.23267.22434.21642.20886.20166.19480.18826.18201 55.26171.25239.24351.23504.22697.21927.21192.20491.19821.19182 56.27313.26369.25468.24608.23787.23003.22254.21538.20854.20199 57.28487.27531.26618.25746.24912.24114.23351.22621.21923.21254 58.29688.28722.27798.26914.26067.25257.24481.23738.23025.22343 59.30913.29937.29002.28107.27249.26427.25639.24882.24157.23461 July 3, 2000262000–27 I.R.B. TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0% 60.32159.31175.30231.29325.28457.27623.26823.26055.25317.24608 61.33429.32437.31485.30571.29692.28848.28037.27257.26507.25786 62.34728.33730.32770.31847.30960.30106.29285.28495.27734.27001 63.36057.35053.34087.33157.32262.31400.30569.29769.28998.28255 64.37412.36404.35433.34498.33596.32726.31887.31078.30298.29545 65.38794.37783.36809.35868.34961.34085.33239.32422.31633.30871 66.40205.39193.38216.37272.36361.35479.34628.33804.33008.32238 67.41650.40639.39661.38715.37800.36915.36059.35230.34428.33651 68.43126.42117.41139.40193.39277.38390.37530.36697.35890.35108 69.44628.43622.42648.41703.40787.39898.39037.38201.37391.36604 70.46150.45149.44178.43236.42321.41433.40571.39735.38922.38132 71.47683.46689.45723.44785.43873.42987.42126.41290.40476.39685 72.49225.48238.47279.46346.45439.44556.43697.42862.42048.41257 73.50770.49793.48841.47915.47013.46135.45280.44447.43635.42844 74.52324.51358.50416.49498.48603.47731.46880.46051.45242.44454 75.53894.52939.52008.51100.50214.49349.48505.47681.46877.46092 76.55483.54543.53624.52728.51852.50996.50160.49344.48546.47766 77.57091.56167.55263.54380.53516.52671.51845.51038.50247.49475 78.58716.57809.56922.56053.55203.54372.53557.52760.51980.51216 79.60346.59459.58590.57738.56904.56086.55286.54501.53732.52978 80.61969.61102.60252.59419.58601.57800.57014.56243.55487.54745 81.63571.62726.61897.61082.60283.59499.58729.57974.57232.56503 82.65146.64324.63515.62722.61942.61176.60423.59683.58957.58242 83.66693.65893.65108.64335.63575.62828.62093.61371.60660.59962 84.68222.67447.66684.65934.65195.64468.63753.63049.62356.61674 85.69742.68993.68255.67528.66812.66106.65411.64727.64053.63389 86.71241.70517.69805.69102.68410.67727.67054.66390.65736.65091 87.72696.72000.71313.70635.69967.69307.68656.68014.67381.66756 88.74108.73438.72777.72125.71480.70845.70217.69597.68985.68380 89.75475.74832.74198.73571.72951.72339.71734.71137.70547.69963 90.76796.76180.75572.74971.74376.73788.73207.72633.72065.71503 91.78049.77460.76878.76302.75732.75168.74610.74058.73512.72972 92.79211.78647.78089.77537.76990.76449.75913.75383.74858.74338 93.80283.79743.79208.78679.78154.77634.77119.76610.76105.75604 94.81283.80765.80253.79744.79240.78741.78247.77756.77270.76789 95.82233.81737.81245.80757.80274.79795.79320.78849.78382.77918 96.83126.82651.82180.81712.81248.80788.80332.79880.79431.78985 97.83953.83498.83046.82597.82152.81710.81271.80836.80404.79976 98.84731.84294.83860.83429.83002.82577.82155.81737.81321.80908 99.85490.85071.84656.84243.83832.83425.83020.82618.82219.81822 100.86229.85828.85431.85035.84642.84252.83864.83478.83095.82714 101.86958.86575.86195.85818.85442.85069.84698.84329.83962.83597 102.87674.87310.86947.86587.86229.85873.85518.85166.84815.84466 103.88384.88038.87694.87351.87010.86671.86334.85998.85663.85331 104.89143.88817.88492.88169.87847.87526.87207.86889.86573.86258 2000–27 I.R.B.27July 3, 2000 TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0% 105.89885.89578.89272.88967.88664.88361.88060.87760.87461.87163 106.90840.90559.90278.89999.89720.89442.89165.88888.88613.88338 107.91999.91750.91501.91253.91005.90758.90511.90265.90019.89774 108.93805.93609.93412.93216.93020.92824.92629.92434.92239.92044 109.96900.96800.96700.96600.96500.96400.96300.96200.96100.96000 July 3, 2000282000–27 I.R.B. TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0% 0.01709.01658.01612.01570.01532.01497.01466.01437.01410.01386 1.00892.00839.00791.00747.00708.00672.00639.00609.00582.00557 2.00896.00840.00790.00744.00702.00664.00629.00598.00569.00542 3.00926.00867.00814.00765.00721.00681.00644.00611.00580.00552 4.00970.00908.00851.00800.00753.00711.00672.00636.00604.00574 5.01026.00960.00900.00846.00796.00751.00710.00672.00637.00606 6.01089.01019.00956.00899.00846.00799.00755.00715.00678.00644 7.01161.01088.01021.00960.00905.00854.00808.00765.00726.00690 8.01241.01163.01093.01029.00970.00917.00867.00822.00781.00743 9.01331.01249.01175.01107.01045.00988.00936.00889.00845.00804 10.01432.01346.01268.01196.01131.01071.01016.00965.00918.00875 11.01543.01453.01370.01295.01226.01162.01104.01051.01001.00956 12.01664.01569.01482.01403.01330.01263.01202.01145.01093.01045 13.01791.01691.01600.01516.01440.01369.01304.01245.01190.01139 14.01918.01813.01717.01629.01548.01474.01406.01343.01285.01231 15.02041.01931.01831.01738.01653.01576.01504.01437.01376.01320 16.02160.02044.01938.01841.01752.01670.01595.01525.01460.01401 17.02274.02152.02041.01940.01846.01760.01680.01607.01539.01476 18.02386.02258.02142.02035.01936.01846.01762.01685.01613.01547 19.02500.02367.02245.02132.02029.01933.01845.01764.01689.01619 20.02621.02481.02353.02235.02126.02025.01933.01847.01768.01694 21.02749.02603.02468.02344.02229.02124.02026.01936.01852.01774 22.02884.02730.02589.02458.02338.02227.02124.02029.01940.01859 23.03028.02867.02718.02581.02454.02337.02229.02128.02035.01949 24.03183.03013.02857.02713.02580.02456.02342.02236.02138.02047 25.03350.03172.03008.02857.02717.02587.02467.02355.02251.02155 26.03530.03344.03172.03013.02865.02729.02602.02484.02375.02273 27.03727.03532.03351.03183.03028.02885.02751.02627.02511.02404 28.03937.03732.03543.03367.03204.03052.02911.02780.02658.02545 29.04162.03947.03748.03564.03392.03233.03084.02946.02818.02698 30.04401.04176.03967.03773.03593.03425.03269.03124.02988.02861 31.04654.04419.04200.03996.03807.03630.03466.03312.03169.03035 32.04923.04676.04447.04233.04034.03849.03676.03514.03363.03221 33.05210.04952.04711.04487.04278.04083.03901.03731.03571.03422 TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0% 34.05515.05245.04993.04758.04538.04333.04142.03962.03794.03637 35.05841.05558.05295.05048.04818.04603.04401.04212.04035.03869 36.06187.05892.05616.05358.05116.04890.04678.04480.04293.04118 37.06555.06247.05958.05688.05435.05198.04975.04766.04570.04385 38.06949.06627.06325.06043.05777.05528.05295.05075.04868.04674 39.07368.07032.06717.06421.06143.05882.05637.05406.05189.04984 40.07816.07465.07137.06827.06537.06263.06006.05764.05535.05320 41.08295.07930.07587.07264.06960.06674.06405.06150.05910.05683 42.08807.08427.08069.07733.07415.07116.06833.06567.06315.06077 43.09352.08957.08585.08233.07902.07589.07294.07014.06750.06500 44.09932.09521.09134.08768.08423.08096.07787.07495.07218.06956 45.10543.10117.09715.09334.08974.08634.08311.08005.07716.07441 46.11189.10747.10329.09933.09559.09204.08867.08548.08245.07958 47.11866.11408.10974.10564.10174.09805.09454.09121.08805.08504 48.12577.12103.11654.11228.10823.10439.10074.09727.09397.09083 49.13323.12833.12368.11926.11506.11107.10728.10366.10022.09695 50.14107.13601.13120.12663.12228.11813.11419.11043.10685.10344 51.14928.14407.13910.13437.12987.12558.12149.11758.11386.11031 52.15785.15248.14735.14247.13781.13337.12913.12508.12122.11752 53.16678.16124.15597.15093.14612.14153.13714.13294.12893.12509 54.17606.17037.16493.15974.15478.15004.14550.14116.13700.13302 55.18570.17986.17428.16893.16382.15893.15424.14976.14546.14134 56.19573.18974.18400.17851.17325.16821.16338.15875.15430.15004 57.20613.20000.19412.18848.18307.17789.17291.16814.16355.15914 58.21688.21060.20458.19880.19325.18792.18280.17788.17316.16861 59.22793.22151.21535.20943.20374.19827.19301.18795.18309.17840 60.23927.23272.22642.22036.21454.20893.20354.19834.19334.18851 61.25092.24425.23782.23163.22567.21993.21440.20907.20393.19898 62.26295.25616.24961.24329.23721.23134.22568.22021.21494.20985 63.27538.26847.26180.25537.24916.24316.23738.23179.22639.22117 64.28817.28116.27438.26783.26150.25539.24949.24377.23825.23291 65.30134.29423.28735.28069.27426.26803.26201.25618.25054.24508 66.31493.30772.30075.29399.28746.28113.27500.26906.26331.25774 67.32899.32170.31464.30780.30118.29475.28852.28248.27663.27095 68.34349.33614.32901.32209.31538.30887.30256.29643.29047.28469 69.35841.35100.34381.33683.33005.32346.31707.31085.30481.29894 70.37366.36620.35896.35193.34509.33844.33197.32568.31957.31362 71.38916.38167.37440.36732.36043.35372.34720.34084.33466.32864 72.40486.39736.39006.38295.37602.36927.36270.35629.35005.34396 73.42074.41323.40591.39878.39182.38504.37843.37198.36568.35955 74.43685.42934.42202.41488.40791.40110.39446.38798.38165.37547 75.45326.44577.43846.43132.42435.41754.41088.40438.39802.39181 76.47004.46259.45530.44818.44122.43442.42776.42125.41488.40865 77.48718.47979.47255.46547.45853.45175.44511.43861.43225.42601 78.50467.49735.49017.48314.47626.46951.46290.45643.45008.44386 79.52239.51515.50806.50110.49427.48758.48102.47459.46828.46209 2000–27 I.R.B.29July 3, 2000 TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0% 80.54018.53304.52603.51916.51242.50580.49930.49292.48666.48052 81.55788.55085.54396.53718.53053.52399.51757.51126.50507.49898 82.57540.56851.56173.55506.54851.54207.53574.52951.52339.51737 83.59274.58598.57933.57279.56635.56001.55378.54765.54161.53567 84.61002.60341.59690.59049.58418.57796.57184.56582.55988.55403 85.62734.62090.61454.60828.60211.59603.59004.58414.57832.57258 86.64455.63828.63210.62600.61999.61406.60821.60244.59675.59113 87.66139.65531.64930.64337.63752.63175.62605.62043.61488.60939 88.67783.67194.66612.66037.65469.64908.64354.63807.63267.62733 89.69387.68817.68254.67698.67148.66605.66068.65537.65012.64493 90.70947.70398.69855.69318.68786.68261.67742.67228.66719.66217 91.72437.71908.71385.70867.70354.69847.69345.68848.68357.67870 92.73823.73314.72810.72310.71816.71326.70841.70361.69886.69415 93.75109.74618.74132.73650.73173.72700.72232.71768.71308.70852 94.76312.75839.75370.74905.74445.73988.73536.73087.72643.72202 95.77459.77004.76552.76104.75660.75220.74783.74350.73920.73494 96.78543.78105.77670.77238.76810.76386.75964.75546.75131.74720 97.79550.79128.78709.78293.77880.77470.77063.76659.76258.75860 98.80498.80091.79687.79286.78888.78492.78099.77709.77322.76937 99.81428.81036.80647.80261.79877.79496.79117.78741.78367.77995 100.82336.81959.81586.81214.80845.80478.80113.79751.79390.79032 101.83234.82873.82515.82158.81804.81451.81101.80753.80406.80062 102.84119.83774.83431.83089.82750.82412.82076.81742.81409.81078 103.84999.84670.84342.84016.83691.83368.83046.82726.82408.82091 104.85944.85632.85321.85011.84703.84396.84090.83786.83483.83182 105.86866.86570.86276.85982.85690.85399.85109.84820.84532.84245 106.88065.87792.87520.87248.86978.86708.86440.86172.85905.85638 107.89530.89286.89042.88799.88557.88315.88073.87833.87592.87352 108.91849.91654.91460.91266.91072.90879.90685.90492.90299.90106 109.95900.95800.95700.95600.95500.95400.95300.95200.95100.95000 July 3, 2000302000–27 I.R.B. TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0% 0.01363.01342.01323.01305.01288.01272.01258.01244.01231.01219 1.00534.00512.00493.00474.00458.00442.00427.00414.00401.00389 2.00518.00495.00474.00455.00437.00421.00405.00391.00377.00365 3.00526.00502.00480.00459.00440.00422.00406.00391.00376.00363 4.00546.00521.00497.00475.00455.00436.00419.00402.00387.00373 TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0% 5.00576.00549.00524.00501.00479.00459.00440.00423.00406.00391 6.00613.00584.00557.00532.00509.00488.00468.00449.00432.00415 7.00657.00626.00598.00571.00547.00524.00502.00482.00464.00446 8.00707.00675.00644.00616.00590.00565.00542.00521.00501.00482 9.00766.00732.00699.00669.00641.00615.00591.00568.00547.00527 10.00835.00798.00764.00732.00702.00675.00649.00624.00602.00580 11.00913.00874.00838.00804.00772.00743.00715.00689.00665.00642 12.01000.00959.00920.00884.00851.00819.00790.00762.00737.00712 13.01091.01048.01007.00969.00933.00900.00869.00840.00813.00787 14.01181.01135.01092.01052.01014.00979.00947.00916.00887.00860 15.01267.01218.01173.01130.01091.01054.01019.00987.00956.00928 16.01345.01294.01246.01201.01160.01121.01084.01050.01018.00988 17.01418.01364.01313.01266.01222.01181.01143.01107.01073.01041 18.01486.01429.01375.01326.01279.01236.01196.01158.01122.01088 19.01554.01494.01438.01385.01336.01291.01248.01208.01170.01135 20.01626.01562.01503.01448.01396.01348.01303.01260.01220.01183 21.01702.01635.01573.01514.01460.01409.01361.01316.01274.01235 22.01782.01711.01645.01584.01526.01472.01422.01374.01330.01288 23.01868.01793.01724.01658.01597.01540.01487.01437.01390.01345 24.01962.01883.01809.01740.01675.01615.01558.01505.01455.01408 25.02065.01981.01903.01830.01762.01698.01638.01581.01528.01478 26.02178.02089.02006.01929.01856.01789.01725.01665.01609.01556 27.02303.02209.02122.02040.01963.01891.01824.01760.01700.01644 28.02439.02339.02247.02160.02079.02002.01931.01863.01800.01740 29.02585.02480.02382.02290.02204.02123.02047.01976.01908.01845 30.02742.02631.02527.02430.02339.02253.02172.02096.02025.01957 31.02910.02793.02683.02579.02482.02391.02306.02225.02149.02077 32.03089.02965.02849.02739.02636.02540.02449.02363.02282.02206 33.03282.03151.03028.02912.02803.02701.02604.02513.02427.02346 34.03489.03350.03220.03097.02982.02873.02771.02674.02583.02497 35.03713.03567.03429.03299.03177.03061.02953.02850.02753.02661 36.03953.03798.03653.03515.03386.03263.03148.03039.02936.02838 37.04211.04048.03894.03748.03611.03481.03359.03243.03134.03030 38.04490.04318.04155.04001.03856.03719.03589.03466.03350.03239 39.04791.04609.04437.04274.04120.03975.03837.03707.03583.03466 40.05116.04924.04742.04571.04408.04254.04108.03970.03839.03714 41.05469.05267.05075.04894.04722.04559.04405.04258.04119.03987 42.05851.05638.05436.05245.05063.04891.04728.04573.04425.04285 43.06263.06039.05827.05625.05433.05252.05079.04915.04759.04610 44.06707.06472.06248.06035.05834.05642.05459.05286.05121.04963 45.07180.06933.06698.06474.06262.06059.05867.05684.05509.05342 46.07685.07425.07178.06943.06720.06507.06304.06110.05926.05750 47.08218.07946.07687.07440.07205.06981.06768.06564.06369.06183 48.08784.08499.08228.07969.07722.07487.07262.07047.06842.06646 49.09382.09085.08801.08530.08271.08024.07788.07562.07346.07140 2000–27 I.R.B.31July 3, 2000 TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0% 50.10018.09707.09410.09127.08856.08597.08349.08112.07885.07667 51.10691.10367.10057.09761.09477.09206.08946.08697.08459.08231 52.11399.11061.10738.10429.10132.09849.09577.09316.09066.08826 53.12142.11791.11454.11132.10823.10526.10242.09969.09707.09456 54.12921.12556.12206.11870.11548.11239.10942.10657.10383.10120 55.13738.13359.12995.12646.12311.11989.11679.11382.11096.10820 56.14595.14202.13824.13462.13113.12778.12456.12146.11847.11560 57.15491.15084.14693.14317.13955.13607.13272.12949.12638.12338 58.16424.16004.15599.15209.14834.14473.14125.13789.13465.13153 59.17390.16955.16537.16134.15746.15371.15010.14662.14325.14001 60.18387.17939.17507.17091.16689.16302.15927.15566.15217.14880 61.19420.18958.18513.18084.17669.17268.16881.16506.16145.15795 62.20494.20020.19561.19119.18691.18277.17877.17490.17115.16753 63.21613.21126.20654.20199.19758.19331.18918.18518.18131.17757 64.22774.22274.21791.21322.20869.20429.20004.19592.19192.18805 65.23979.23467.22971.22490.22025.21573.21135.20710.20299.19899 66.25233.24709.24202.23709.23231.22767.22318.21881.21457.21045 67.26543.26009.25489.24985.24496.24021.23560.23111.22676.22252 68.27908.27363.26833.26319.25819.25332.24860.24400.23954.23519 69.29324.28769.28230.27705.27195.26699.26216.25746.25288.24843 70.30783.30219.29671.29137.28618.28112.27619.27139.26672.26216 71.32277.31706.31150.30608.30079.29564.29063.28573.28096.27631 72.33803.33225.32661.32112.31575.31052.30542.30044.29559.29084 73.35356.34772.34201.33645.33101.32571.32053.31547.31053.30571 74.36943.36354.35778.35215.34666.34129.33604.33091.32590.32100 75.38574.37980.37400.36833.36278.35735.35205.34686.34178.33681 76.40256.39660.39076.38505.37947.37400.36864.36340.35827.35324 77.41991.41394.40808.40235.39674.39124.38585.38056.37539.37032 78.43777.43180.42594.42020.41457.40906.40365.39834.39314.38803 79.45602.45007.44422.43849.43287.42735.42193.41661.41139.40627 80.47449.46856.46275.45704.45143.44592.44051.43519.42997.42484 81.49300.48712.48134.47566.47008.46460.45921.45391.44870.44357 82.51145.50563.49990.49427.48873.48328.47792.47265.46746.46235 83.52983.52407.51841.51284.50735.50195.49663.49139.48624.48116 84.54828.54261.53702.53151.52609.52075.51549.51030.50519.50015 85.56693.56135.55586.55044.54510.53983.53464.52952.52447.51949 86.58560.58013.57474.56943.56418.55901.55390.54886.54389.53898 87.60398.59864.59337.58817.58303.57795.57294.56799.56310.55828 88.62206.61685.61170.60662.60159.59663.59173.58688.58209.57736 89.63980.63474.62972.62477.61987.61503.61024.60551.60083.59620 90.65719.65227.64741.64259.63783.63312.62846.62385.61928.61477 91.67388.66912.66440.65973.65511.65053.64600.64152.63708.63269 92.68949.68487.68030.67577.67129.66685.66245.65809.65378.64950 93.70401.69954.69511.69072.68637.68205.67778.67355.66935.66519 94.71765.71332.70902.70477.70055.69636.69222.68810.68403.67998 July 3, 2000322000–27 I.R.B. TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0% 95.73072.72653.72237.71825.71416.71010.70608.70209.69813.69421 96.74311.73906.73504.73105.72709.72316.71926.71539.71155.70774 97.75465.75073.74684.74297.73914.73533.73155.72780.72407.72037 98.76555.76175.75798.75424.75052.74683.74317.73953.73591.73232 99.77626.77260.76895.76534.76174.75817.75462.75109.74759.74411 100.78676.78323.77971.77622.77274.76929.76586.76245.75906.75569 101.79719.79379.79040.78703.78368.78035.77704.77375.77048.76722 102.80749.80422.80096.79772.79450.79130.78811.78494.78178.77864 103.81775.81461.81149.80838.80529.80221.79914.79609.79306.79003 104.82881.82582.82284.81988.81693.81399.81106.80815.80525.80236 105.83959.83674.83391.83108.82826.82546.82267.81988.81711.81435 106.85373.85108.84844.84581.84319.84058.83797.83537.83278.83020 107.87113.86875.86636.86399.86161.85925.85689.85453.85218.84984 108.89913.89721.89529.89337.89145.88953.88762.88571.88380.88189 109.94900.94800.94700.94600.94500.94400.94300.94200.94100.94000 2000–27 I.R.B.33July 3, 2000 TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE12.2%12.4%12.6%12.8%13.0%13.2%13.4%13.6%13.8%14.0% 0.01208.01197.01187.01177.01168.01159.01151.01143.01135.01128 1.00378.00367.00358.00348.00340.00331.00323.00316.00309.00302 2.00353.00342.00331.00322.00312.00304.00295.00288.00280.00273 3.00350.00339.00327.00317.00307.00298.00289.00281.00273.00265 4.00359.00347.00335.00324.00313.00303.00294.00285.00276.00268 5.00377.00363.00351.00339.00327.00317.00306.00297.00288.00279 6.00400.00386.00372.00359.00347.00335.00325.00314.00305.00295 7.00430.00414.00400.00386.00373.00360.00349.00338.00327.00317 8.00465.00448.00432.00417.00403.00390.00378.00366.00354.00344 9.00508.00490.00473.00457.00442.00428.00414.00402.00389.00378 10.00560.00541.00523.00506.00490.00475.00460.00446.00433.00421 11.00620.00600.00581.00563.00546.00529.00514.00499.00485.00472 12.00689.00668.00647.00628.00610.00593.00576.00560.00545.00531 13.00763.00740.00718.00698.00678.00660.00642.00626.00610.00595 14.00834.00810.00787.00766.00745.00726.00707.00689.00673.00657 15.00901.00875.00851.00828.00807.00786.00767.00748.00730.00714 16.00959.00932.00907.00883.00860.00839.00818.00799.00780.00762 17.01011.00983.00956.00930.00907.00884.00862.00842.00822.00804 18.01057.01027.00999.00972.00947.00923.00900.00879.00858.00839 19.01101.01070.01040.01012.00985.00960.00936.00914.00892.00871 TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE12.2%12.4%12.6%12.8%13.0%13.2%13.4%13.6%13.8%14.0% 20.01148.01115.01083.01054.01026.00999.00974.00950.00927.00905 21.01197.01162.01129.01098.01068.01040.01014.00988.00964.00941 22.01249.01211.01176.01143.01112.01082.01054.01027.01002.00978 23.01304.01264.01227.01192.01159.01127.01098.01069.01042.01017 24.01364.01322.01283.01246.01210.01177.01145.01115.01087.01060 25.01431.01387.01345.01306.01268.01233.01199.01168.01137.01109 26.01506.01459.01415.01373.01333.01295.01260.01226.01194.01163 27.01591.01541.01494.01449.01407.01367.01329.01293.01259.01226 28.01684.01631.01580.01533.01488.01445.01405.01367.01330.01296 29.01785.01728.01675.01624.01577.01531.01488.01447.01408.01372 30.01893.01833.01776.01723.01672.01623.01578.01534.01493.01453 31.02010.01946.01885.01828.01773.01722.01673.01627.01582.01540 32.02134.02066.02002.01940.01883.01828.01776.01726.01679.01634 33.02270.02197.02128.02063.02002.01943.01887.01835.01784.01736 34.02415.02338.02265.02195.02130.02067.02008.01951.01897.01846 35.02574.02492.02414.02340.02270.02203.02140.02080.02022.01967 36.02746.02658.02575.02496.02422.02350.02283.02218.02157.02098 37.02932.02838.02750.02666.02586.02510.02438.02369.02303.02241 38.03135.03035.02941.02851.02766.02685.02608.02534.02464.02397 39.03355.03249.03149.03053.02962.02876.02793.02715.02640.02568 40.03596.03484.03377.03275.03178.03086.02998.02914.02833.02757 41.03861.03742.03628.03520.03416.03318.03224.03134.03048.02966 42.04152.04025.03903.03788.03678.03573.03473.03377.03285.03198 43.04468.04333.04205.04082.03965.03853.03746.03644.03546.03453 44.04813.04670.04533.04403.04278.04159.04045.03936.03832.03732 45.05183.05032.04887.04748.04616.04489.04368.04252.04141.04034 46.05582.05421.05267.05121.04980.04846.04717.04593.04475.04362 47.06006.05836.05673.05518.05369.05226.05089.04958.04832.04711 48.06459.06279.06107.05943.05785.05634.05488.05349.05216.05087 49.06942.06752.06571.06397.06230.06070.05916.05768.05626.05490 50.07459.07259.07068.06884.06708.06538.06376.06219.06069.05924 51.08012.07801.07599.07406.07220.07041.06869.06703.06544.06391 52.08596.08375.08163.07959.07763.07574.07392.07218.07049.06887 53.09214.08982.08759.08544.08338.08139.07948.07763.07586.07415 54.09867.09623.09389.09164.08946.08737.08536.08342.08154.07974 55.10556.10301.10055.09819.09591.09371.09159.08955.08757.08567 56.11283.11016.10759.10511.10272.10042.09819.09605.09397.09197 57.12050.11771.11502.11243.10993.10751.10518.10293.10075.09864 58.12852.12562.12281.12011.11749.11496.11252.11016.10787.10567 59.13687.13385.13092.12810.12537.12273.12017.11770.11531.11299 60.14554.14240.13935.13641.13356.13080.12813.12555.12305.12063 61.15457.15130.14813.14507.14210.13923.13644.13375.13113.12860 62.16402.16063.15734.15415.15107.14808.14518.14237.13964.13699 63.17393.17042.16700.16370.16049.15738.15437.15144.14860.14584 64.18429.18065.17712.17369.17036.16714.16400.16096.15800.15513 July 3, 2000342000–27 I.R.B. TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE12.2%12.4%12.6%12.8%13.0%13.2%13.4%13.6%13.8%14.0% 65.19511.19135.18769.18415.18070.17735.17410.17094.16787.16488 66.20645.20257.19880.19513.19157.18810.18473.18146.17827.17517 67.21841.21441.21052.20673.20305.19947.19599.19259.18929.18608 68.23096.22685.22284.21895.21515.21146.20786.20436.20094.19762 69.24409.23987.23575.23175.22784.22404.22033.21672.21320.20976 70.25772.25339.24918.24507.24106.23715.23333.22961.22598.22244 71.27178.26735.26304.25882.25471.25070.24679.24296.23923.23559 72.28622.28170.27729.27298.26877.26467.26065.25673.25290.24915 73.30100.29639.29189.28749.28320.27899.27489.27087.26694.26310 74.31621.31152.30694.30246.29807.29378.28959.28548.28146.27753 75.33195.32719.32253.31797.31351.30914.30486.30067.29657.29255 76.34832.34350.33877.33415.32961.32517.32082.31656.31238.30828 77.36535.36047.35570.35101.34642.34192.33750.33317.32892.32475 78.38302.37811.37329.36856.36392.35937.35490.35051.34621.34198 79.40124.39630.39145.38669.38201.37742.37291.36848.36413.35985 80.41980.41485.40998.40520.40050.39588.39134.38688.38249.37818 81.43854.43358.42871.42392.41921.41457.41001.40553.40112.39678 82.45733.45238.44752.44273.43802.43338.42881.42431.41989.41553 83.47616.47123.46638.46161.45690.45227.44770.44320.43877.43441 84.49519.49030.48548.48073.47604.47143.46688.46239.45797.45361 85.51458.50974.50496.50025.49560.49102.48650.48204.47763.47329 86.53413.52935.52463.51998.51538.51084.50636.50194.49758.49327 87.55351.54881.54416.53957.53503.53055.52613.52176.51744.51317 88.57268.56806.56349.55898.55451.55010.54574.54144.53718.53296 89.59162.58710.58262.57819.57382.56949.56520.56097.55678.55263 90.61030.60588.60151.59718.59290.58866.58447.58032.57621.57214 91.62834.62403.61977.61554.61136.60722.60312.59907.59505.59107 92.64527.64107.63692.63280.62872.62468.62068.61672.61279.60890 93.66107.65699.65294.64893.64495.64101.63711.63323.62940.62559 94.67597.67200.66806.66415.66027.65643.65262.64884.64509.64138 95.69031.68645.68262.67881.67504.67130.66759.66390.66025.65662 96.70396.70021.69648.69279.68912.68548.68186.67828.67471.67118 97.71670.71305.70943.70584.70227.69872.69520.69171.68824.68480 98.72875.72521.72169.71819.71472.71127.70784.70444.70106.69770 99.74065.73721.73379.73040.72703.72368.72035.71704.71375.71048 100.75234.74901.74570.74241.73914.73589.73265.72944.72625.72307 101.76399.76077.75757.75438.75122.74807.74494.74183.73873.73565 102.77552.77241.76932.76625.76319.76015.75712.75411.75111.74813 103.78703.78404.78106.77809.77514.77221.76929.76638.76348.76060 104.79948.79662.79377.79093.78810.78528.78248.77969.77691.77414 105.81159.80885.80612.80340.80069.79799.79530.79262.78995.78729 106.82763.82506.82250.81995.81741.81488.81235.80983.80732.80482 107.84749.84516.84283.84051.83819.83587.83356.83126.82896.82666 108.87999.87808.87618.87428.87238.87049.86859.86670.86481.86293 109.93900.93800.93700.93600.93500.93400.93300.93200.93100.93000 2000–27 I.R.B.35July 3, 2000 (f) Effective dates. This section applies after April 30, 1999. §1.664–4T [Removed] Par. 8. Section 1.664–4T is removed. Par. 9. Section 1.7520–1 is amended by: 1. Revising paragraph (b)(2). 2. Revising paragraphs (c)(1) and (c)(2). 3. Revising paragraph (d). The revisions read as follows: §1.7520–1 Valuation of annuities, unitrust interests, interests for life or terms of years, and remainder or reversionary in- terests. * * * * * (b) * * * (2) Mortality component. The mortality component reflects the mortality data most recently available from the United States census. As new mortality data be- comes available after each decennial cen- sus, the mortality component described in this section will be revised periodically and the revised mortality component ta- bles will be published in the regulations at that time. For transactions with valuation dates after April 30, 1999, the mortality component table (Table 90CM) is con- tained in §20.2031–7(d)(7) of this chap- ter. See §20.2031–7A of this chapter for mortality component tables applicable to transactions for which the valuation date falls before May 1, 1999. (c) * * * (1) Regulation sections containing ta- bles with interest rates between 4.2 and 14 percent for valuation dates after April 30, 1999. Section 1.642(c)–6(e)(6) con- tains Table S used for determining the present value of a single life remainder in- terest in a pooled income fund as defined in §1.642(c)–5. See §1.642(c)–6A for ac- tuarial factors for one life applicable to valuation dates before May 1, 1999. Sec- tion 1.664–4(e)(6) contains Table F (pay- out factors) and Table D (actuarial factors used in determining the present value of a remainder interest postponed for a term of years). Section 1.664–4(e)(7) contains Table U(1) (unitrust single life remainder factors). These tables are used in deter- mining the present value of a remainder interest in a charitable remainder unitrust as defined in §1.664–3. See §1.664–4A for unitrust single life remainder factors applicable to valuation dates before May 1, 1999. Section 20.2031–7(d)(6) of this chapter contains Table B (actuarial factors used in determining the present value of an interest for a term of years), Table K (annuity end-of-interval adjustment fac- tors), and Table J (term certain annuity beginning-of-interval adjustment factors). Section 20.2031–7(d)(7) of this chapter contains Table S (single life remainder factors), and Table 90CM (mortality com- ponents). These tables are used in deter- mining the present value of annuities, life estates, remainders, and reversions. See §20.2031–7A of this chapter for single life remainder factors and mortality com- ponents applicable to valuation dates be- fore May 1, 1999. (2) Internal Revenue Service publica- tions containing tables with interest rates between 2.2 and 22 percent for valuation dates after April 30, 1999. The following documents are available for purchase from the Superintendent of Documents, United States Government Printing Of- fice, Washington, DC 20402: (i) Internal Revenue Service Publica- tion 1457, “Actuarial Values, Book Aleph,” (7-1999). This publication in- cludes tables of valuation factors, as well as examples that show how to compute other valuation factors, for determining the present value of annuities, life estates, terms of years, remainders, and rever- sions, measured by one or two lives. These factors may also be used in the val- uation of interests in a charitable remain- der annuity trust as defined in §1.664–2 and a pooled income fund as defined in §1.642(c)–5. See §20.2031–7A of this chapter for publications containing tables for valuation dates before May 1, 1999. (ii) Internal Revenue Service Publica- tion 1458, “Actuarial Values, Book Beth,” (7-1999). This publication includes term certain tables and tables of one and two life valuation factors for determining the present value of remainder interests in a charitable remainder unitrust as defined in §1.664–3. See §1.664–4A for publica- tions containing tables for valuation dates before May 1, 1999. (iii) Internal Revenue Service Publica- tion 1459, “Actuarial Values, Book Gimel,” (7-1999). This publication in- cludes tables for computing depreciation adjustment factors. See §1.170A–12. (d) Effective date. This section applies after April 30, 1989. §1.7520–1T [Removed] Par. 10. Section 1.7520–1T is re- moved. PART 20—ESTATE TAX; ESTATES OF DECEDENTS DYING AFTER AUGUST 16, 1954 Par. 11. The authority citation for part 20 is amended by removing entries for sections 20.2031–7T and 20.7520–1T to read in part as follows: Authority: 26 U.S.C. 7805 * * * §20.2031–0 [Amended] Par. 12 Section 20.2031–0 is amended by removing the entry for §20.2031–7T from the contents listing. Par. 13. Section 20.2031–7 is amended by: 1. Removing existing paragraphs (c) through (d)(5). 2. Adding paragraphs (c), (d) heading, and (d)(1) through (d)(5). 3. Revising the introductory text of paragraph (d)(6). 4. Adding paragraph (d)(7). 5. Revising paragraph (e). The revisions and additions read as fol- lows: §20.2031–7 Valuation of annuities, inter- ests for life or term of years, and remain- der or reversionary interests. * * * * * (c) Actuarial valuations. The present value of annuities, life estates, terms of years, remainders, and reversions for es- tates of decedents for which the valuation date of the gross estate is after April 30, 1999, is determined under paragraph (d) of this section. The present value of an- nuities, life estates, terms of years, re- mainders, and reversions for estates of decedents for which the valuation date of the gross estate is before May 1, 1999, is determined under the following sections: July 3, 2000362000–27 I.R.B. (d) Actuarial valuations after April 30, 1999—(1) In general. Except as otherwise provided in paragraph (b) of this section and §20.7520–3(b) (pertaining to certain limitations on the use of prescribed tables), if the valuation date for the gross estate of the decedent is after April 30, 1999, the fair market value of annuities, life estates, terms of years, remainders, and reversionary in- terests is the present value determined by use of standard or special section 7520 ac- tuarial factors. These factors are derived by using the appropriate section 7520 interest rate and, if applicable, the mortality compo- nent for the valuation date of the interest that is being valued. For purposes of the computations described in this section, the age of an individual is the age of that indi- vidual at the individual’s nearest birthday. See §§20.7520–1 through 20.7520–4. (2) Specific interests—(i) Charitable re- mainder trusts. The fair market value of a remainder interest in a pooled income fund, as defined in §1.642(c)–5 of this chapter, is its value determined under §1.642(c)–6(e) of this chapter. The fair market value of a remainder interest in a charitable remainder annuity trust, as defined in §1.664–2(a) of this chapter, is the present value determined under §1.664–2(c) of this chapter. The fair market value of a remainder interest in a charitable remainder unitrust, as defined in §1.664–3 of this chapter, is its present value determined under §1.664–4(e) of this chap- ter. The fair market value of a life interest or term of years in a charitable remainder unitrust is the fair market value of the prop- erty as of the date of valuation less the fair market value of the remainder interest on that date determined under §1.664–4(e)(4) and (5) of this chapter. (ii) Ordinary remainder and reversion- ary interests. If the interest to be valued is to take effect after a definite number of years or after the death of one individual, the present value of the interest is computed by multiplying the value of the property by the appropriate remainder interest actuarial factor (that corresponds to the applicable section 7520 interest rate and remainder in- terest period) in Table B (for a term certain) or the appropriate Table S (for one measur- ing life), as the case may be. Table B is contained in paragraph (d)(6) of this section and Table S (for one measuring life when the valuation date is after April 30, 1999) is contained in paragraph (d)(7) of this section and in Internal Revenue Service Publica- tion 1457. For information about obtaining actuarial factors for other types of remain- der interests, see paragraph (d)(4) of this section. (iii) Ordinary term-of-years and life in- terests. If the interest to be valued is the right of a person to receive the income of certain property, or to use certain nonin- come-producing property, for a term of years or for the life of one individual, the present value of the interest is computed by multiplying the value of the property by the appropriate term-of-years or life interest ac- tuarial factor (that corresponds to the ap- plicable section 7520 interest rate and term- of-years or life interest period). Internal Revenue Service Publication 1457 includes actuarial factors for an interest for a term of years in Table B and for the life of one indi- vidual in Table S (for one measuring life when the valuation date is after April 30, 1999). However, term-of-years and life in- terest actuarial factors are not included in Table B in paragraph (d)(6) of this section or Table S in paragraph (d)(7) of this sec- tion. If Internal Revenue Service Publica- tion 1457 (or any other reliable source of term-of-years and life interest actuarial fac- tors) is not conveniently available, an actu- arial factor for the interest may be derived mathematically. This actuarial factor may be derived by subtracting the correlative re- mainder factor (that corresponds to the ap- plicable section 7520 interest rate and the term of years or the life) in Table B (for a term of years) in paragraph (d)(6) of this section or in Table S (for the life of one in- dividual) in paragraph (d)(7) of this section, as the case may be, from 1.000000. For in- formation about obtaining actuarial factors for other types of term-of-years and life in- terests, see paragraph (d)(4) of this section. (iv) Annuities. (A) If the interest to be valued is the right of a person to receive an annuity that is payable at the end of each year for a term of years or for the life of one individual, the present value of the interest is computed by multiplying the aggregate amount payable annually by the appropri- ate annuity actuarial factor (that corre- sponds to the applicable section 7520 inter- est rate and annuity period). Internal Revenue Publication 1457 includes actuar- ial factors in Table B (for an annuity payable for a term of years) and in Table S (for an annuity payable for the life of one individual when the valuation date is after April 30, 1999). However, annuity actuar- ial factors are not included in Table B in paragraph (d)(6) of this section or Table S in paragraph (d)(7) of this section. If Inter- nal Revenue Service Publication 1457 (or any other reliable source of annuity actuar- ial factors) is not conveniently available, a required annuity factor for a term of years or for one life may be mathematically de- rived. This annuity factor may be derived by subtracting the applicable remainder factor (that corresponds to the applicable section 7520 interest rate and annuity pe- riod) in Table B (in the case of a term-of- years annuity) in paragraph (d)(6) of this section or in Table S (in the case of a one- life annuity when the valuation date is after April 30, 1999) in paragraph (d)(7) of this section, as the case may be, from 1.000000 and then dividing the result by the applica- ble section 7520 interest rate expressed as a decimal number. (B) If the annuity is payable at the end of semiannual, quarterly, monthly, or weekly periods, the product obtained by multiply- ing the annuity factor by the aggregate amount payable annually is then multiplied by the applicable adjustment factor as con- tained in Table K in paragraph (d)(6) of this section for payments made at the end of the specified periods. The provisions of this paragraph (d)(2)(iv)(B) are illustrated by the following example: Example. At the time of the decedent’s death, the survivor/annuitant, age 72, is entitled to receive an an- 2000–27 I.R.B.37July 3, 2000 Valuation DateApplicable AfterBeforeRegulations 01-01-5220.2031–7A(a) 12-31-5101-01-7120.2031–7A(b) 12-31-7012-01-8320.2031–7A(c) 11-30-8305-01-8920.2031–7A(d) 04-30-8905-01-9920.2031–7A(e) nuity of $15,000 a year for life payable in equal monthly installments at the end of each period. The section 7520 rate for the month in which the decedent died is 9.6 percent. Under Table S in paragraph (d)(7) of this section, the remainder factor at 9.6 percent for an individual aged 72 is .38438. By converting the re- mainder factor to an annuity factor, as described above, the annuity factor at 9.6 percent for an individ- ual aged 72 is 6.4127 (1.00000 minus .38438, divided by .096). Under Table K in paragraph (d)(6) of this section, the adjustment factor under the column for payments made at the end of each monthly period at the rate of 9.6 percent is 1.0433. The aggregate annual amount, $15,000, is multiplied by the factor 6.4127 and the product multiplied by 1.0433. The present value of the annuity at the date of the decedent’s death is, therefore, $100,355.55 ($15,000 x 6.4127 x 1.0433). (C) If an annuity is payable at the begin- ning of annual, semiannual, quarterly, monthly, or weekly periods for a term of years, the value of the annuity is computed by multiplying the aggregate amount payable annually by the annuity factor de- scribed in paragraph (d)(2)(iv)(A) of this section; and the product so obtained is then multiplied by the adjustment factor in Table J in paragraph (d)(6) of this section at the appropriate interest rate component for payments made at the beginning of speci- fied periods. If an annuity is payable at the beginning of annual, semiannual, quarterly, monthly, or weekly periods for one or more lives, the value of the annuity is the sum of the first payment plus the present value of a similar annuity, the first payment of which is not to be made until the end of the pay- ment period, determined as provided in this paragraph (d)(2)(iv). (v) Annuity and unitrust interests for a term of years or until the prior death of an individual. See §25.2512–5(d)(2)(v) of this chapter for examples explaining how to compute the present value of an annuity or unitrust interest that is payable until the ear- lier of the lapse of a specific number of years or the death of an individual. (3) Transitional rule. (i) If a decedent dies after April 30, 1999, and if on May 1, 1999, the decedent was mentally incompe- tent so that the disposition of the decedent’s property could not be changed, and the decedent dies without having regained competency to dispose of the decedent’s property or dies within 90 days of the date on which the decedent first regains compe- tency, the fair market value of annuities, life estates, terms for years, remainders, and reversions included in the gross estate of the decedent is their present value deter- mined either under this section or under the corresponding section applicable at the time the decedent became mentally incom- petent, at the option of the decedent’s ex- ecutor. For example, see §20.2031–7A(e)(2). (ii) If a decedent dies after April 30, 1999, and before July 1, 1999, the fair mar- ket value of annuities, life estates, remain- ders, and reversions based on one or more measuring lives included in the gross estate of the decedent is their present value deter- mined under this section by use of the sec- tion 7520 interest rate for the month in which the valuation date occurs (see §§20.7520–1(b) and 20.7520-2(a)(2)) and the appropriate actuarial tables under either paragraph (d)(7) of this section or §20.2031–7A(e)(4), at the option of the decedent’s executor. (iii) For purposes of paragraphs (d)(3)(i) and (ii) of this section, where the dece- dent’s executor is given the option to use the appropriate actuarial tables under either paragraph (d)(7) of this section or §20.2031–7A(e)(4), the decedent’s execu- tor must use the same actuarial table with respect to each individual transaction and with respect to all transfers occurring on the valuation date (for example, gift and in- come tax charitable deductions with respect to the same transfer must be determined based on the same tables, and all assets in- cludible in the gross estate and/or estate tax deductions claimed must be valued based on the same tables). (4) Publications and actuarial computa- tions by the Internal Revenue Service. Many standard actuarial factors not in- cluded in paragraphs (d)(6) or (d)(7) of this section are included in Internal Revenue Service Publication 1457, “Actuarial Val- ues, Book Aleph,” (7-1999). Publication 1457 also includes examples that illustrate how to compute many special factors for more unusual situations. A copy of this publication is available for purchase from the Superintendent of Documents, United States Government Printing Office, Wash- ington, DC 20402. See §20.2031–7A for publications containing actuarial factors for valuing interests for which the valuation date is before May 1, 1999. If a special fac- tor is required in the case of an actual dece- dent, the Internal Revenue Service may fur- nish the factor to the executor upon a request for a ruling. The request for a rul- ing must be accompanied by a recitation of the facts including a statement of the date of birth for each measuring life, the date of the decedent’s death, any other applicable dates, and a copy of the will, trust, or other relevant documents. A request for a ruling must comply with the instructions for re- questing a ruling published periodically in the Internal Revenue Bulletin (see §§601.201 and 601.601(d)(2)(ii)(b ) of this chapter) and include payment of the re- quired user fee. (5) Examples. The provisions of this section are illustrated by the following ex- amples: Example 1. Remainder payable at an individual’s death.The decedent, or the decedent’s estate, was en- titled to receive certain property worth $50,000 upon the death of A, to whom the income was bequeathed for life. At the time of the decedent’s death, A was 47 years 5 months old. In the month in which the dece- dent died, the section 7520 rate was 9.8 percent. Under Table S in paragraph (d)(7) of this section, the remainder factor at 9.8 percent for determining the present value of the remainder interest due at the death of a person aged 47, the number of years nearest A’s actual age at the decedent’s death, is .10317. The pre- sent value of the remainder interest at the date of the decedent’s death is, therefore, $5,158.50 ($50,000 X .10317). Example 2. Income payable for an individual’s life. A’s parent bequeathed an income interest in property to A for life, with the remainder interest passing to B at A’s death. At the time of the parent’s death, the value of the property was $50,000 and A was 30 years 10 months old. The section 7520 rate at the time of the parent’s death was 10.2 percent. Under Table S in paragraph (d)(7) of this section, the remainder factor at 10.2 percent for determining the present value of the remainder interest due at the death of a person aged 31, the number of years closest to A’s age at the dece- dent’s death, is .03583. Converting this remainder fac- tor to an income factor, as described in paragraph (d)(2)(iii) of this section, the factor for determining the present value of an income interest for the life of a per- son aged 31 is .96417. The present value of A’s inter- est at the time of the parent’s death is, therefore, $48,208.50 ($50,000 X .96417). Example 3. Annuity payable for an individual’s life.A purchased an annuity for the benefit of both A and B. Under the terms of the annuity contract, at A’s death, a survivor annuity of $10,000 a year payable in equal semiannual installments made at the end of each interval is payable to B for life. At A’s death, B was 45 years 7 months old. Also, at A’s death, the section 7520 rate was 9.6 percent. Under Table S in paragraph (d)(7) of this section, the factor at 9.6 percent for de- termining the present value of the remainder interest at the death of a person age 46 (the number of years near- est B’s actual age) is .10013. By converting the factor to an annuity factor, as described in paragraph (d)(2)(iv)(A) of this section, the factor for the present value of an annuity payable until the death of a person age 46 is 9.3736 (1.00000 minus .10013, divided by .096). The adjustment factor from Table K in para- graph (d)(6) of this section at an interest rate of 9.6 percent for semiannual annuity payments made at the end of the period is 1.0235. The present value of the annuity at the date of A’s death is, therefore, July 3, 2000382000–27 I.R.B. $95,938.80 ($10,000 X 9.3736 X 1.0235). Example 4. Annuity payable for a term of years. The decedent, or the decedent’s estate, was entitled to receive an annuity of $10,000 a year payable in equal quarterly installments at the end of each quarter throughout a term certain. At the time of the dece- dent’s death, the section 7520 rate was 9.8 percent. A quarterly payment had just been made prior to the decedent’s death and payments were to continue for 5 more years. Under Table B in paragraph (d)(6) of this section for the interest rate of 9.8 percent, the factor for the present value of a remainder interest due after a term of 5 years is .626597. Converting the factor to an annuity factor, as described in paragraph (d)(2)(iv)(A) of this section, the factor for the present value of an annuity for a term of 5 years is 3.8102. The adjust- ment factor from Table K in paragraph (d)(6) of this section at an interest rate of 9.8 percent for quarterly annuity payments made at the end of the period is 1.0360. The present value of the annuity is, therefore, $39,473.67 ($10,000 X 3.8102 X 1.0360). (6) Actuarial Table B, Table J, and Table K where the valuation date is after April 30, 1989. Except as provided in §20.7520–3(b) (pertaining to certain limita- tions on prescribed tables), for determina- tion of the present value of an interest that is dependent on a term of years, the tables in this paragraph (d)(6) must be used in the application of the provisions of this section when the section 7520 interest rate compo- nent is between 4.2 and 14 percent. * * * * * (7) Actuarial Table S and Table 90CM where the valuation date is after April 30, 1999. Except as provided in §20.7520–2(b) (pertaining to certain limita- tions on the use of prescribed tables), for determination of the present value of an in- terest that is dependent on the termination of a life interest, Table 90CM and Table S, single life remainder factors applicable where the valuation date is after April 30, 1999, contained in this paragraph (d)(7) (or Table S and Table 80CNSMT contained in §20.2031–7A(e)(4) for valuation dates after April 30, 1989, and before May 1, 1999) and Table J and Table K contained in para- graph (d)(6) of this section, must be used in the application of the provisions of this sec- tion when the section 7520 interest rate component is between 4.2 and 14 percent. 2000–27 I.R.B.39July 3, 2000 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0% 0.06752.06130.05586.05109.04691.04322.03998.03711.03458.03233 1.06137.05495.04932.04438.04003.03620.03283.02985.02721.02487 2.06325.05667.05088.04580.04132.03737.03388.03079.02806.02563 3.06545.05869.05275.04752.04291.03883.03523.03203.02920.02668 4.06784.06092.05482.04944.04469.04048.03676.03346.03052.02791 5.07040.06331.05705.05152.04662.04229.03845.03503.03199.02928 6.07310.06583.05941.05372.04869.04422.04025.03672.03357.03076 7.07594.06849.06191.05607.05089.04628.04219.03854.03528.03236 8.07891.07129.06453.05853.05321.04846.04424.04046.03709.03407 9.08203.07423.06731.06115.05567.05079.04643.04253.03904.03592 10.08532.07734.07024.06392.05829.05326.04877.04474.04114.03790 11.08875.08059.07331.06683.06104.05587.05124.04709.04336.04002 12.09233.08398.07653.06989.06394.05862.05385.04957.04572.04226 13.09601.08748.07985.07304.06693.06146.05655.05214.04816.04458 14.09974.09102.08322.07624.06997.06435.05929.05474.05064.04694 15.10350.09460.08661.07946.07303.06725.06204.05735.05312.04930 16.10728.09818.09001.08268.07608.07014.06479.05996.05559.05164 17.11108.10179.09344.08592.07916.07306.06755.06257.05807.05399 18.11494.10545.09691.08921.08227.07601.07034.06521.06057.05636 19.11889.10921.10047.09259.08548.07904.07322.06794.06315.05880 20.12298.11310.10417.09610.08881.08220.07622.07078.06584.06135 21.12722.11713.10801.09976.09228.08550.07935.07375.06866.06403 22.13159.12130.11199.10354.09588.08893.08260.07685.07160.06682 23.13613.12563.11612.10748.09964.09250.08601.08009.07468.06975 24.14084.13014.12043.11160.10357.09625.08958.08349.07793.07284 25.14574.13484.12493.11591.10768.10018.09334.08708.08135.07611 26.15084.13974.12963.12041.11199.10431.09728.09085.08496.07956 27.15615.14485.13454.12513.11652.10865.10144.09484.08878.08322 28.16166.15016.13965.13004.12124.11319.10580.09901.09279.08706 29.16737.15567.14497.13516.12617.11792.11035.10339.09699.09109 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0% 30.17328.16138.15048.14047.13129.12286.11510.10796.10138.09532 31.17938.16728.15618.14599.13661.12799.12004.11272.10597.09974 32.18568.17339.16210.15171.14214.13333.12520.11769.11076.10435 33.19220.17972.16824.15766.14790.13889.13058.12289.11578.10920 34.19894.18627.17460.16383.15388.14468.13618.12831.12102.11426 35.20592.19307.18121.17025.16011.15073.14204.13399.12652.11958 36.21312.20010.18805.17691.16658.15701.14814.13990.13225.12514 37.22057.20737.19514.18382.17331.16356.15450.14608.13825.13096 38.22827.21490.20251.19100.18031.17038.16113.15253.14452.13705 39.23623.22270.21013.19845.18759.17747.16805.15927.15108.14344 40.24446.23078.21805.20620.19516.18487.17527.16631.15795.15013 41.25298.23915.22626.21425.20305.19259.18282.17368.16514.15715 42.26178.24782.23478.22262.21125.20062.19069.18138.17267.16450 43.27087.25678.24360.23129.21977.20898.19888.18941.18053.17220 44.28025.26603.25273.24027.22860.21766.20740.19777.18873.18023 45.28987.27555.26212.24953.23772.22664.21622.20644.19724.18858 46.29976.28533.27179.25908.24714.23591.22536.21542.20606.19725 47.30987.29535.28171.26889.25682.24546.23476.22468.21518.20621 48.32023.30563.29190.27897.26678.25530.24447.23425.22460.21549 49.33082.31615.30234.28931.27702.26543.25447.24412.23434.22509 50.34166.32694.31306.29995.28756.27586.26479.25432.24441.23502 51.35274.33798.32404.31085.29838.28658.27541.26482.25479.24528 52.36402.34924.33525.32200.30946.29757.28630.27561.26547.25584 53.37550.36070.34668.33339.32078.30882.29746.28667.27643.26669 54.38717.37237.35833.34500.33234.32031.30888.29801.28766.27782 55.39903.38424.37019.35683.34413.33205.32056.30961.29918.28925 56.41108.39631.38227.36890.35617.34405.33250.32149.31099.30097 57.42330.40857.39455.38118.36844.35629.34469.33363.32306.31297 58.43566.42098.40699.39364.38089.36873.35710.34600.33538.32522 59.44811.43351.41956.40623.39350.38133.36968.35855.34789.33768 60.46066.44613.43224.41896.40624.39408.38243.37127.36058.35033 61.47330.45887.44505.43182.41914.40699.39535.38418.37347.36318 62.48608.47175.45802.44485.43223.42011.40848.39732.38660.37629 63.49898.48478.47115.45807.44550.43343.42184.41069.39997.38966 64.51200.49793.48442.47143.45895.44694.43539.42427.41357.40326 65.52512.51121.49782.48495.47255.46062.44912.43805.42738.41709 66.53835.52461.51137.49862.48634.47449.46307.45206.44143.43118 67.55174.53818.52511.51250.50034.48860.47727.46633.45576.44556 68.56524.55188.53899.52654.51452.50291.49168.48083.47034.46020 69.57882.56568.55299.54071.52885.51737.50627.49552.48513.47506 70.59242.57951.56703.55495.54325.53193.52096.51034.50004.49007 71.60598.59332.58106.56918.55767.54651.53569.52520.51503.50516 72.61948.60707.59504.58338.57206.56108.55043.54009.53004.52029 73.63287.62073.60895.59751.58640.57561.56513.55495.54505.53543 74.64621.63435.62282.61162.60073.59015.57985.56984.56009.55061 July 3, 2000402000–27 I.R.B. TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0% 75.65953.64796.63671.62575.61510.60473.59463.58480.57523.56591 76.67287.66160.65063.63995.62954.61940.60952.59989.59050.58135 77.68622.67526.66459.65419.64404.63415.62450.61509.60590.59694 78.69954.68892.67856.66845.65858.64895.63955.63036.62140.61264 79.71278.70250.69246.68265.67308.66372.65457.64563.63690.62836 80.72581.71588.70618.69668.68740.67833.66945.66077.65227.64396 81.73857.72899.71962.71045.70147.69268.68408.67566.66741.65933 82.75101.74178.73274.72389.71522.70672.69840.69024.68225.67441 83.76311.75423.74553.73700.72864.72044.71240.70451.69678.68919 84.77497.76645.75809.74988.74183.73393.72618.71857.71110.70377 85.78665.77848.77047.76260.75487.74728.73982.73250.72530.71823 86.79805.79025.78258.77504.76764.76036.75320.74617.73925.73245 87.80904.80159.79427.78706.77998.77301.76615.75940.75277.74624 88.81962.81251.80552.79865.79188.78521.77865.77220.76584.75958 89.82978.82302.81636.80980.80335.79699.79072.78455.77847.77248 90.83952.83309.82676.82052.81437.80831.80234.79645.79064.78492 91.84870.84260.83658.83064.82479.81902.81332.80771.80217.79671 92.85716.85136.84563.83998.83441.82891.82348.81812.81283.80761 93.86494.85942.85396.84858.84326.83801.83283.82771.82266.81767 94.87216.86690.86170.85657.85149.84648.84153.83664.83181.82704 95.87898.87397.86902.86412.85928.85450.84977.84510.84049.83592 96.88537.88060.87587.87121.86659.86203.85751.85305.84864.84427 97.89127.88672.88221.87775.87335.86898.86467.86040.85618.85200 98.89680.89245.88815.88389.87968.87551.87138.86730.86326.85926 99.90217.89803.89393.88987.88585.88187.87793.87402.87016.86633 100.90738.90344.89953.89567.89183.88804.88428.88056.87687.87322 101.91250.90876.90504.90137.89772.89412.89054.88699.88348.88000 102.91751.91396.91045.90696.90350.90007.89668.89331.88997.88666 103.92247.91912.91579.91249.90922.90598.90276.89957.89640.89326 104.92775.92460.92148.91839.91532.91227.90924.90624.90326.90031 105.93290.92996.92704.92415.92127.91841.91558.91276.90997.90719 106.93948.93680.93415.93151.92889.92628.92370.92113.91857.91604 107.94739.94504.94271.94039.93808.93579.93351.93124.92899.92675 108.95950.95767.95585.95404.95224.95045.94867.94689.94512.94336 109.97985.97893.97801.97710.97619.97529.97438.97348.97259.97170 2000–27 I.R.B.41July 3, 2000 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0% 0.03034.02857.02700.02559.02433.02321.02220.02129.02047.01973 1.02279.02094.01929.01782.01650.01533.01427.01331.01246.01168 2.02347.02155.01983.01829.01692.01569.01458.01358.01268.01187 3.02444.02243.02065.01905.01761.01632.01516.01412.01317.01232 4.02558.02349.02163.01996.01846.01712.01590.01481.01382.01292 5.02686.02469.02275.02101.01945.01804.01677.01562.01458.01364 6.02825.02600.02398.02217.02053.01906.01773.01653.01544.01445 7.02976.02742.02532.02343.02172.02019.01880.01754.01640.01536 8.03137.02894.02675.02479.02301.02140.01995.01864.01744.01635 9.03311.03059.02832.02627.02442.02274.02122.01985.01859.01745 10.03499.03237.03001.02788.02595.02420.02262.02118.01987.01867 11.03700.03428.03183.02961.02760.02578.02413.02262.02125.02000 12.03913.03632.03377.03146.02937.02748.02575.02418.02275.02144 13.04135.03843.03579.03339.03122.02924.02744.02580.02431.02294 14.04359.04057.03783.03534.03308.03102.02915.02744.02587.02444 15.04584.04270.03986.03728.03493.03279.03083.02905.02742.02593 16.04806.04482.04187.03919.03674.03452.03248.03063.02892.02736 17.05029.04692.04387.04108.03855.03623.03411.03218.03040.02877 18.05253.04905.04588.04299.04036.03795.03574.03373.03187.03017 19.05484.05124.04796.04496.04222.03972.03742.03532.03339.03161 20.05726.05354.05013.04702.04418.04158.03919.03700.03498.03313 21.05980.05595.05242.04920.04625.04354.04105.03877.03667.03473 22.06246.05847.05482.05147.04841.04559.04301.04063.03844.03642 23.06524.06112.05734.05387.05069.04777.04508.04260.04032.03821 24.06819.06392.06001.05642.05312.05008.04728.04470.04232.04012 25.07131.06690.06285.05913.05570.05255.04964.04695.04447.04218 26.07460.07005.06586.06200.05845.05518.05215.04936.04677.04438 27.07810.07340.06907.06508.06140.05800.05485.05195.04925.04676 28.08179.07693.07246.06833.06451.06098.05772.05469.05189.04929 29.08566.08065.07603.07176.06780.06414.06075.05761.05469.05198 30.08973.08456.07978.07536.07127.06748.06396.06069.05766.05483 31.09398.08865.08372.07915.07491.07098.06733.06394.06078.05785 32.09843.09294.08785.08313.07875.07468.07089.06737.06409.06103 33.10310.09745.09220.08732.08279.07858.07466.07100.06759.06441 34.10799.10217.09676.09173.08705.08269.07862.07483.07129.06798 35.11314.10715.10157.09638.09155.08704.08283.07890.07522.07179 36.11852.11236.10662.10127.09628.09162.08726.08319.07938.07581 37.12416.11783.11193.10641.10126.09645.09194.08772.08377.08006 38.13009.12359.11751.11183.10652.10155.09689.09253.08843.08459 39.13629.12962.12338.11753.11206.10693.10212.09761.09337.08938 40.14281.13597.12955.12355.11791.11262.10766.10299.09860.09447 41.14966.14264.13606.12989.12409.11864.11352.10870.10417.09989 42.15685.14966.14291.13657.13061.12500.11972.11475.11006.10564 43.16437.15702.15010.14360.13747.13171.12627.12115.11631.11174 44.17224.16472.15764.15098.14469.13876.13317.12789.12290.11819 July 3, 2000422000–27 I.R.B. TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0% 45.18042.17274.16550.15867.15223.14615.14040.13496.12982.12496 46.18893.18110.17370.16671.16011.15387.14796.14238.13708.13207 47.19775.18975.18220.17505.16830.16190.15584.15010.14466.13950 48.20688 .19873.19102.18373.17682.17027.16406.15817.15258.14727 49.21633.20804.20018.19274.18568.17898.17262.16658.16084.15539 50.22612.21769.20969.20210.19490.18805.18155.17536.16948.16388 51.23625.22769.21955.21182.20448.19749.19084.18452.17849.17275 52.24669.23799.22973.22186.21438.20726.20047.19400.18784.18196 53.25742.24861.24022.23222.22461.21735.21043.20383.19753.19151 54.26845.25952.25101.24290.23516.22777.22072.21399.20756.20140 55.27978.27074.26212.25389.24604.23853.23136.22450.21793.21166 56.29140.28227.27355.26522.25725.24963.24233.23535.22867.22227 57.30333.29411.28529.27686.26879.26106.25365.24656.23976.23324 58.31551.30621.29731.28878.28061.27278.26528.25807.25116.24453 59.32790.31854.30956.30095.29269.28477.27716.26986.26284.25610 60.34050.33107.32202.31334.30500.29699.28929.28190.27478.26794 61.35331.34384.33473.32598.31757.30948.30170.29422.28701.28007 62.36639.35688.34772.33892.33044.32229.31443.30687.29958.29255 63.37974.37020.36101.35216.34363.33542.32750.31986.31250.30539 64.39334.38378.37456.36568.35711.34884.34087.33317.32574.31857 65.40718.39761.38838.37947.37087.36257.35455.34681.33932.33208 66.42128.41172.40249.39357.38496.37663.36858.36079.35326.34597 67.43569.42616.41694.40803.39941.39107.38299.37518.36761.36028 68.45038.44089.43170.42281.41419.40585.39777.38994.38235.37499 69.46531.45587.44672.43786.42927.42094.41286.40503.39743.39006 70.48040.47103.46194.45312.44456.43626.42820.42038.41278.40540 71.49558.48629.47727.46851.46000.45174.44371.43591.42832.42095 72.51082.50162.49268.48399.47554.46733.45934.45157.44401.43666 73.52607.51697.50813.49952.49114.48299.47506.46733.45981.45249 74.54139.53241.52367.51515.50686.49879.49092.48325.47578.46849 75.55683.54798.53936.53095.52276.51477.50698.49938.49197.48474 76.57243.56373.55524.54696.53888.53100.52330.51579.50846.50130 77.58819.57965.57132.56318.55523.54747.53988.53247.52523.51815 78.60408.59572.58755.57957.57177.56414.55668.54939.54225.53527 79.62001.61184.60385.59604.58840.58092.57360.56644.55943.55256 80.63582.62786.62007.61244.60497.59765.59048.58347.57659.56985 81.65142.64367.63608.62864.62135.61421.60721.60034.59361.58701 82.66673.65920.65182.64458.63748.63052.62368.61698.61041.60395 83.68175.67444.66728.66024.65334.64656.63991.63338.62696.62066 84.69657.68950.68256.67574.66904.66246.65599.64964.64340.63727 85.71128.70446.69775.69116.68467.67830.67204.66587.65982.65386 86.72576.71919.71272.70636.70010.69394.68789.68193.67606.67029 87.73981.73349.72726.72114.71511.70917.70333.69757.69190.68632 88.75342.74735.74137.73548.72968.72396.71833.71279.70732.70194 89.76658.76076.75503.74938.74381.73832.73290.72757.72231.71712 2000–27 I.R.B.43July 3, 2000 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0% 90.77928.77371.76823.76281.75748.75221.74702.74190.73684.73186 91.79131.78600.78075.77557.77046.76542.76044.75553.75068.74589 92.80246.79737.79235.78740.78250.77767.77290.76818.76353.75893 93.81274.80788.80307.79832.79363.78899.78441.77989.77542.77100 94.82232.81766.81306.80850.80401.79956.79517.79082.78653.78228 95.83141.82695.82254.81818.81387.80961.80539.80122.79710.79302 96.83996.83569.83147.82729.82316.81907.81503.81103.80707.80315 97.84787.84378.83973.83573.83176.82784.82396.82012.81632.81255 98.85530.85138.84750.84366.83985.83609.83236.82867.82502.82140 99.86255.85880.85508.85140.84776.84415.84057.83703.83353.83005 100.86960.86601.86246.85894.85546.85200.84858.84519.84183.83849 101.87655.87313.86974.86638.86305.85975.85648.85324.85003.84684 102.88338.88012.87689.87369.87052.86738.86426.86116.85809.85505 103.89015.88706.88399.88095.87793.87494.87197.86903.86611.86321 104.89737.89446.89157.88871.88586.88304.88024.87745.87469.87195 105.90443.90170.89898.89628.89360.89094.88830.88568.88307.88049 106.91351.91101.90852.90605.90359.90115.89873.89632.89392.89154 107.92452.92230.92010.91791.91573.91356.91141.90927.90714.90502 108.94161.93987.93814.93641.93469.93298.93128.92958.92790.92622 109.97081.96992.96904.96816.96729.96642.96555.96468.96382.96296 July 3, 2000442000–27 I.R.B. TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0% 0.01906.01845.01790.01740.01694.01652.01613.01578.01546.01516 1.01098.01034.00977.00924.00876.00833.00793.00756.00722.00691 2.01113.01046.00986.00930.00880.00834.00791.00753.00717.00684 3.01155.01084.01020.00962.00909.00860.00816.00775.00737.00702 4.01211.01137.01069.01008.00952.00900.00853.00810.00770.00733 5.01279.01201.01130.01065.01006.00952.00902.00856.00814.00775 6.01356.01274.01199.01131.01068.01011.00959.00910.00865.00824 7.01442.01356.01277.01205.01140.01079.01023.00972.00925.00881 8.01536.01446.01363.01287.01218.01154.01096.01041.00991.00945 9.01641.01546.01460.01380.01307.01240.01178.01120.01068.01019 10.01758.01659.01567.01484.01407.01336.01270.01210.01154.01103 11.01886.01781.01686.01598.01517.01442.01373.01310.01251.01196 12.02024.01915.01814.01721.01636.01558.01485.01419.01357.01299 13.02168.02054.01948.01851.01762.01679.01603.01533.01467.01407 14.02313.02193.02083.01981.01887.01801.01721.01646.01578.01514 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0% 15.02456.02330.02214.02107.02009.01918.01834.01756.01684.01617 16.02593.02462.02340.02229.02126.02030.01942.01860.01785.01714 17.02728.02590.02463.02346.02238.02138.02046.01960.01880.01806 18.02861.02717.02584.02462.02348.02243.02146.02056.01972.01894 19.02998.02847.02708.02580.02461.02351.02249.02154.02066.01984 20.03142.02984.02839.02704.02580.02465.02357.02258.02165.02079 21.03295.03130.02978.02837.02706.02585.02473.02368.02271.02180 22.03455.03283.03124.02976.02839.02712.02594.02484.02382.02286 23.03626.03446.03279.03124.02981.02847.02723.02608.02500.02400 24.03809.03620.03446.03283.03133.02993.02863.02741.02628.02522 25.04005.03808.03625.03456.03298.03151.03014.02887.02768.02656 26.04216.04010.03819.03641.03476.03322.03178.03044.02919.02802 27.04444.04229.04029.03843.03670.03508.03357.03217.03085.02962 28.04687.04463.04254.04059.03877.03708.03550.03402.03263.03133 29.04946.04712.04493.04289.04099.03922.03756.03600.03455.03318 30.05221.04976.04748.04534.04335.04149.03975.03812.03659.03515 31.05511.05255.05017.04794.04585.04390.04208.04037.03876.03725 32.05818.05551.05302.05069.04851.04647.04455.04276.04107.03948 33.06144.05866.05606.05363.05135.04921.04720.04532.04355.04188 34.06489.06200.05928.05674.05436.05212.05002.04805.04619.04444 35.06857.06555.06273.06007.05758.05524.05304.05097.04902.04718 36.07246.06932.06638.06361.06101.05856.05626.05409.05205.05012 37.07659.07332.07025.06737.06466.06210.05969.05742.05528.05325 38.08098.07758.07439.07138.06855.06588.06336.06099.05874.05662 39.08563.08210.07878.07565.07270.06992.06729.06480.06245.06023 40.09059.08692.08347.08021.07714.07423.07149.06889.06643.06411 41.09586.09206.08848.08509.08189.07886.07600.07329.07072.06828 42.10147.09753.09381.09029.08696.08381.08083.07800.07531.07277 43.10742.10334.09948.09583.09237.08909.08598.08304.08024.07758 44.11373.10950.10551.10172.09813.09472.09148.08841.08549.08272 45.12035.11599.11185.10792.10420.10066.09730.09410.09106.08817 46.12732.12281.11853.11447.11061.10694.10345.10013.09696.09395 47.13460.12995.12553.12133.11733.11353.10991.10646.10317.10004 48.14223.13743.13287.12853.12439.12046.11671.11313.10972.10646 49.15020.14526.14056.13608.13181.12774.12385.12015.11661.11322 50.15855.15347.14862.14401.13960.13540.13138.12754.12388.12037 51.16727.16205.15707.15232.14777.14344.13929.13532.13153.12789 52.17634.17098.16587.16097.15630.15183.14755.14345.13953.13577 53.18576.18027.17501.16999.16518.16057.15616.15194.14789.14400 54.19552.18990.18451.17935.17441.16968.16514.16078.15661.15260 55.20564.19989.19437.18908.18402.17915.17449.17001.16571.16157 56.21613.21025.20461.19919.19400.18901.18422.17962.17519.17093 57.22698.22098.21522.20968.20436.19925.19434.18961.18507.18069 58.23816.23204.22616.22051.21507.20984.20481.19996.19530.19080 59.24962.24339.23740.23163.22608.22073.21558.21062.20584.20123 2000–27 I.R.B.45July 3, 2000 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0% 60.26136.25502.24892.24304.23738.23192.22666.22158.21669.21196 61.27339.26695.26075.25477.24900.24343.23806.23288.22787.22304 62.28578.27925.27295.26687.26100.25533.24985.24456.23945.23451 63.29854.29192.28553.27935.27339.26762.26205.25666.25145.24641 64.31164.30494.29846.29221.28615.28030.27463.26915.26384.25870 65.32508.31831.31177.30543.29930.29336.28761.28203.27663.27140 66.33891.33208.32547.31906.31285.30684.30101.29536.28987.28456 67.35318.34630.33963.33316.32689.32081.31491.30918.30363.29823 68.36785.36093.35422.34770.34138.33524.32928.32349.31787.31240 69.38290.37595.36920.36265.35628.35009.34408.33824.33256.32703 70.39823.39127.38450.37791.37151.36529.35924.35335.34762.34204 71.41378.40681.40003.39343.38701.38076.37467.36875.36298.35736 72.42950.42253.41575.40914.40271.39644.39034.38438.37858.37293 73.44535.43840.43162.42502.41858.41231.40619.40022.39440.38872 74.46139.45446.44771.44112.43469.42842.42230.41632.41049.40479 75.47769.47080.46408.45752.45111.44485.43874.43277.42693.42123 76.49430.48747.48079.47427.46790.46167.45558.44963.44380.43811 77.51123.50447.49786.49139.48506.47888.47282.46690.46111.45543 78.52845.52177.51523.50884.50257.49645.49044.48457.47881.47317 79.54584.53926.53282.52650.52032.51426.50833.50251.49681.49122 80.56325.55678.55044.54423.53813.53216.52630.52056.51492.50939 81.58054.57419.56797.56186.55587.54999.54422.53856.53300.52754 82.59762.59140.58530.57931.57343.56766.56198.55641.55094.54557 83.61448.60840.60243.59657.59081.58515.57958.57411.56874.56346 84.63124.62531.61949.61376.60813.60259.59715.59179.58652.58134 85.64800.64224.63657.63099.62550.62010.61478.60955.60441.59934 86.66461.65902.65351.64810.64276.63751.63233.62724.62222.61728 87.68083.67541.67008.66483.65965.65455.64953.64458.63970.63489 88.69663.69140.68624.68116.67615.67121.66634.66154.65680.65213 89.71201.70696.70199.69708.69224.68747.68276.67811.67353.66900 90.72694.72209.71730.71257.70791.70330.69876.69427.68984.68547 91.74117.73650.73190.72735.72286.71842.71404.70972.70545.70123 92.75439.74991.74548.74110.73678.73251.72829.72412.72000.71593 93.76664.76233.75806.75385.74969.74557.74150.73748.73350.72957 94.77809.77394.76983.76578.76177.75780.75388.75000.74616.74237 95.78899.78500.78106.77715.77329.76947.76569.76195.75826.75460 96.79928.79544.79165.78790.78418.78050.77686.77326.76970.76617 97.80883.80514.80149.79787.79430.79075.78725.78377.78033.77693 98.81781.81427.81075.80727.80382.80041.79703.79368.79036.78708 99.82661.82320.81982.81648.81316.80988.80662.80340.80020.79704 July 3, 2000462000–27 I.R.B. TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0% 100.83519.83192.82868.82547.82228.81913.81600.81290.80982.80678 101.84368.84055.83744.83437.83131.82829.82529.82231.81936.81643 102.85203.84904.84607.84313.84021.83731.83444.83159.82876.82596 103.86034.85748.85465.85184.84906.84629.84355.84082.83812.83544 104.86923.86653.86385.86119.85855.85593.85333.85074.84818.84563 105.87792.87537.87283.87032.86782.86534.86287.86042.85799.85557 106.88918.88683.88450.88218.87987.87758.87530.87304.87079.86855 107.90291.90082.89873.89666.89460.89255.89051.88849.88647.88447 108.92455.92288.92123.91958.91794.91630.91468.91306.91145.90984 109.96211.96125.96041.95956.95872.95788.95704.95620.95537.95455 2000–27 I.R.B.47July 3, 2000 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0% 0.01488.01463.01439.01417.01396.01377.01359.01343.01327.01312 1.00662.00636.00612.00589.00568.00548.00530.00513.00497.00482 2.00654.00626.00600.00576.00554.00533.00514.00496.00479.00463 3.00670.00641.00613.00588.00564.00542.00522.00502.00484.00468 4.00699.00668.00639.00612.00587.00563.00542.00521.00502.00484 5.00739.00706.00675.00646.00620.00595.00571.00550.00529.00510 6.00786.00751.00718.00687.00659.00633.00608.00585.00563.00543 7.00841.00803.00769.00736.00706.00678.00652.00627.00604.00582 8.00902.00863.00826.00791.00759.00730.00702.00675.00651.00628 9.00973.00931.00892.00856.00822.00790.00760.00733.00706.00682 10.01055.01010.00969.00930.00894.00861.00829.00799.00772.00746 11.01146.01099.01055.01014.00976.00940.00907.00875.00846.00818 12.01246.01196.01150.01106.01066.01028.00993.00960.00928.00899 13.01351.01298.01249.01204.01161.01121.01084.01049.01016.00985 14.01455.01400.01348.01300.01255.01213.01173.01136.01102.01069 15.01555.01497.01443.01392.01345.01300.01259.01220.01183.01148 16.01648.01587.01530.01477.01427.01380.01336.01295.01257.01220 17.01737.01673.01612.01556.01504.01455.01408.01365.01324.01286 18.01822.01754.01691.01632.01576.01525.01476.01430.01387.01347 19.01908.01837.01770.01708.01650.01595.01544.01495.01450.01407 20.01999.01924.01854.01788.01726.01669.01615.01564.01516.01471 21.02096.02017.01943.01874.01809.01748.01691.01637.01586.01539 22.02197.02114.02036.01963.01895.01830.01770.01713.01660.01610 23.02306.02218.02136.02059.01987.01919.01855.01795.01739.01686 24.02424.02331.02245.02163.02087.02016.01948.01885.01825.01769 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0% 25.02552.02455.02364.02278.02197.02122.02051.01984.01920.01861 26.02692.02589.02493.02403.02318.02238.02162.02091.02025.01961 27.02846.02738.02636.02541.02451.02367.02287.02212.02141.02074 28.03012.02898.02791.02690.02595.02506.02422.02342.02267.02196 29.03190.03070.02957.02851.02751.02656.02567.02483.02404.02329 30.03381.03254.03135.03023.02917.02817.02723.02634.02551.02471 31.03583.03450.03324.03206.03094.02989.02890.02796.02707.02623 32.03799.03659.03527.03402.03284.03173.03068.02968.02874.02785 33.04031.03883.03744.03612.03488.03371.03260.03155.03055.02961 34.04279.04123.03976.03838.03707.03583.03465.03354.03249.03149 35.04545.04382.04227.04081.03943.03812.03688.03571.03459.03354 36.04830.04658.04495.04341.04196.04058.03927.03803.03685.03573 37.05134.04953.04782.04620.04467.04321.04183.04052.03928.03809 38.05462.05272.05092.04921.04760.04606.04461.04322.04191.04066 39.05812.05613.05424.05245.05075.04913.04760.04614.04475.04343 40.06190.05981.05782.05594.05415.05245.05083.04929.04783.04643 41.06597.06378.06170.05972.05784.05605.05435.05272.05118.04970 42.07035.06806.06587.06380.06182.05994.05815.05644.05481.05326 43.07505.07265.07036.06818.06611.06414.06225.06045.05874.05710 44.08008.07757.07518.07290.07072.06865.06667.06478.06298.06125 45.08542.08279.08029.07791.07563.07346.07138.06940.06750.06569 46.09108.08834.08573.08324.08085.07858.07640.07432.07233.07043 47.09705.09419.09147.08886.08637.08399.08172.07954.07745.07545 48.10335.10038.09754.09482.09222.08973.08735.08507.08288.08078 49.10999.10690.10394.10111.09840.09581.09332.09093.08864.08644 50.11701.11380.11073.10778.10496.10225.09965.09716.09477.09247 51.12441.12108.11789.11482.11189.10907.10636.10376.10126.09886 52.13217.12871.12540.12222.11916.11623.11341.11071.10810.10560 53.14028.13670.13327.12997.12680.12375.12082.11801.11529.11268 54.14875.14505.14150.13808.13480.13163.12859.12566.12284.12012 55.15760.15378.15011.14657.14317.13989.13674.13370.13077.12794 56.16684.16290.15911.15546.15194.14855.14528.14213.13909.13615 57.17648.17242.16851.16474.16111.15760.15422.15096.14781.14477 58.18647.18229.17827.17438.17064.16702.16353.16015.15689.15374 59.19678.19249.18835.18435.18049.17676.17316.16968.16631.16305 60.20740.20300.19875.19464.19066.18682.18311.17952.17604.17268 61.21837.21385.20949.20527.20119.19724.19341.18971.18613.18266 62.22973.22511.22064.21631.21212.20807.20414.20033.19664.19306 63.24152.23680.23222.22779.22350.21934.21530.21139.20760.20392 64.25372.24890.24422.23969.23529.23103.22690.22289.21899.21521 65.26633.26141.25664.25201.24752.24316.23893.23482.23083.22695 66.27940.27439.26953.26481.26023.25577.25145.24724.24316.23918 67.29299.28790.28296.27815.27348.26894.26453.26024.25606.25200 68.30709.30193.29691.29202.28728.28265.27816.27378.26952.26537 69.32166.31643.31134.30639.30157.29687.29230.28785.28351.27928 July 3, 2000482000–27 I.R.B. TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0% 70.33661.33133.32618.32116.31628.31152.30688.30235.29794.29364 71.35188.34654.34134.33627.33133.32651.32181.31722.31275.30838 72.36742.36204.35679.35168.34668.34181.33706.33241.32788.32345 73.38317.37776.37248.36733.36229.35738.35257.34788.34330.33882 74.39923.39380.38849.38330.37823.37328.36844.36370.35908.35455 75.41566.41021.40489.39968.39459.38961.38474.37997.37531.37074 76.43254.42709.42176.41655.41144.40645.40156.39677.39208.38749 77.44988.44444.43912.43391.42880.42380.41891.41411.40940.40479 78.46765.46224.45694.45174.44665.44166.43677.43197.42726.42265 79.48574.48037.47510.46993.46487.45990.45502.45024.44554.44094 80.50397.49865.49343.48830.48327.47834.47349.46873.46406.45947 81.52219.51693.51176.50669.50171.49682.49201.48729.48265.47809 82.54029.53510.53000.52499.52007.51523.51047.50580.50120.49667 83.55826.55315.54813.54319.53834.53356.52886.52424.51969.51522 84.57624.57123.56629.56144.55666.55195.54732.54277.53828.53386 85.59435.58944.58460.57984.57516.57054.56599.56151.55710.55275 86.61241.60762.60289.59824.59365.58913.58468.58029.57596.57170 87.63015.62548.62087.61633.61185.60744.60309.59880.59456.59039 88.64753.64299.63851.63409.62973.62543.62118.61700.61287.60879 89.66454.66013.65579.65150.64726.64308.63895.63488.63086.62689 90.68115.67689.67268.66853.66442.66037.65637.65241.64851.64465 91.69706.69294.68887.68486.68089.67696.67309.66925.66547.66173 92.71190.70792.70399.70011.69627.69247.68872.68501.68134.67771 93.72569.72184.71804.71429.71057.70689.70326.69967.69611.69259 94.73861.73490.73123.72759.72400.72044.71692.71344.71000.70659 95.75097.74739.74384.74033.73686.73342.73002.72665.72331.72001 96.76267.75922.75579.75240.74905.74572.74243.73917.73595.73275 97.77356.77022.76691.76363.76039.75718.75399.75084.74772.74463 98.78382.78059.77740.77423.77110.76799.76491.76186.75884.75584 99.79390.79079.78771.78465.78162.77862.77565.77270.76978.76688 100.80376.80076.79779.79485.79193.78904.78617.78333.78051.77771 101.81353.81066.80780.80497.80217.79938.79662.79388.79117.78847 102.82318.82042.81768.81496.81227.80960.80694.80431.80170.79911 103.83278.83014.82752.82491.82233.81977.81723.81470.81220.80971 104.84310.84059.83810.83563.83317.83073.82831.82591.82352.82115 105.85318.85079.84843.84607.84374.84142.83911.83682.83455.83229 106.86633.86413.86193.85975.85758.85543.85329.85116.84904.84694 107.88247.88049.87852.87656.87460.87266.87073.86881.86690.86500 108.90825.90666.90507.90350.90193.90037.89881.89727.89572.89419 109.95372.95290.95208.95126.95045.94964.94883.94803.94723.94643 2000–27 I.R.B.49July 3, 2000 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE12.2%12.4%12.6%12.8%13.0%13.2%13.4%13.6%13.8%14.0% 0.01298.01285.01273.01261.01250.01240.01230.01221.01212.01203 1.00468.00455.00443.00431.00420.00410.00400.00391.00382.00374 2.00448.00435.00421.00409.00398.00387.00376.00366.00357.00348 3.00452.00437.00423.00410.00398.00386.00375.00365.00355.00345 4.00468.00452.00437.00423.00410.00397.00386.00375.00364.00354 5.00493.00476.00460.00445.00431.00418.00405.00393.00382.00371 6.00524.00506.00489.00473.00458.00444.00430.00418.00406.00394 7.00562.00543.00525.00508.00492.00477.00462.00449.00436.00423 8.00606.00586.00566.00548.00531.00515.00499.00485.00471.00458 9.00659.00637.00616.00597.00579.00561.00545.00529.00514.00500 10.00721.00698.00676.00655.00636.00617.00600.00583.00567.00552 11.00792.00767.00744.00722.00701.00682.00663.00645.00628.00612 12.00871.00845.00821.00797.00775.00754.00735.00716.00698.00681 13.00955.00928.00902.00877.00854.00831.00810.00790.00771.00753 14.01038.01009.00981.00955.00930.00907.00885.00864.00843.00824 15.01116.01085.01056.01028.01002.00977.00954.00932.00910.00890 16.01186.01153.01123.01094.01066.01040.01015.00992.00969.00948 17.01250.01215.01183.01152.01124.01096.01070.01045.01022.00999 18.01308.01272.01238.01206.01175.01147.01119.01093.01068.01044 19.01367.01329.01293.01259.01227.01196.01167.01140.01113.01088 20.01428.01388.01350.01314.01280.01248.01217.01188.01161.01134 21.01494.01451.01411.01373.01337.01303.01271.01240.01211.01183 22.01562.01517.01475.01435.01397.01361.01326.01294.01263.01233 23.01635.01588.01543.01501.01460.01422.01386.01351.01319.01287 24.01716.01665.01618.01573.01530.01489.01451.01415.01380.01347 25.01804.01751.01701.01653.01608.01565.01524.01485.01448.01413 26.01902.01845.01792.01741.01693.01648.01604.01563.01524.01487 27.02011.01951.01895.01841.01790.01742.01696.01652.01610.01571 28.02129.02066.02006.01949.01895.01844.01795.01748.01704.01662 29.02258.02191.02127.02067.02009.01955.01903.01853.01806.01762 30.02396.02325.02257.02193.02132.02074.02019.01966.01916.01869 31.02543.02467.02396.02328.02263.02201.02143.02087.02034.01983 32.02701.02621.02545.02472.02404.02338.02276.02217.02160.02106 33.02871.02786.02706.02629.02556.02487.02420.02357.02297.02240 34.03054.02964.02879.02797.02720.02646.02576.02509.02445.02383 35.03253.03158.03067.02981.02898.02820.02745.02674.02606.02541 36.03467.03366.03269.03178.03090.03007.02928.02852.02779.02710 37.03697.03590.03488.03391.03298.03209.03125.03044.02967.02893 38.03947.03833.03725.03622.03524.03430.03340.03254.03172.03094 39.04217.04096.03982.03873.03768.03669.03573.03482.03395.03312 40.04510.04383.04262.04146.04035.03930.03828.03732.03639.03550 41.04830.04695.04567.04445.04327.04215.04108.04005.03907.03812 42.05177.05035.04900.04770.04646.04527.04413.04304.04200.04100 43.05553.05404.05261.05123.04992.04866.04746.04630.04520.04413 44.05960.05802.05651.05506.05368.05235.05107.04985.04867.04754 July 3, 2000502000–27 I.R.B. TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE12.2%12.4%12.6%12.8%13.0%13.2%13.4%13.6%13.8%14.0% 45.06395.06229.06069.05917.05770.05630.05495.05365.05241.05121 46.06860.06685.06517.06356.06202.06053.05911.05774.05643.05516 47.07353.07169.06992.06823.06660.06504.06353.06209.06070.05936 48.07877.07684.07498.07320.07149.06984.06826.06673.06527.06385 49.08433.08231.08036.07849.07669.07495.07329.07168.07013.06864 50.09026.08814.08609.08413.08224.08042.07867.07698.07535.07378 51.09655.09433.09219.09013.08815.08624.08440.08262.08091.07926 52.10318.10086.09863.09647.09439.09239.09046.08860.08680.08506 53.11017.10774.10541.10315.10098.09888.09686.09491.09302.09120 54.11750.11498.11254.11019.10792.10572.10361.10156.09958.09767 55.12522.12258.12005.11759.11522.11294.11072.10859.10652.10451 56.13332.13059.12794.12539.12292.12054.11823.11599.11383.11174 57.14183.13899.13624.13359.13102.12853.12613.12380.12154.11936 58.15070.14775.14490.14215.13948.13689.13439.13197.12962.12734 59.15990.15685.15389.15103.14826.14558.14298.14046.13801.13564 60.16942.16626.16321.16024.15737.15459.15189.14927.14673.14426 61.17929.17603.17287.16981.16684.16395.16115.15844.15580.15324 62.18960.18623.18297.17980.17673.17375.17085.16803.16530.16264 63.20035.19688.19352.19025.18708.18400.18100.17809.17525.17250 64.21154.20797.20451.20114.19787.19469.19159.18859.18566.18281 65.22318.21951.21595.21249.20912.20584.20265.19955.19652.19358 66.23532.23156.22790.22434.22088.21751.21422.21102.20791.20487 67.24804.24419.24044.23679.23324.22977.22640.22311.21990.21678 68.26133.25740.25356.24983.24618.24263.23917.23579.23250.22929 69.27516.27114.26723.26341.25969.25605.25251.24905.24567.24237 70.28945.28536.28137.27747.27367.26996.26633.26279.25934.25596 71.30412.29996.29590.29193.28806.28427.28057.27696.27343.26998 72.31913.31491.31078.30675.30281.29895.29519.29150.28790.28438 73.33444.33016.32597.32188.31788.31396.31013.30638.30271.29913 74.35012.34579.34155.33741.33335.32938.32549.32168.31795.31430 75.36628.36190.35762.35343.34932.34530.34136.33750.33372.33001 76.38299.37858.37427.37004.36589.36183.35784.35394.35011.34636 77.40028.39585.39151.38725.38307.37898.37496.37103.36716.36337 78.41812.41368.40933.40506.40086.39675.39271.38874.38485.38103 79.43641.43198.42762.42334.41914.41502.41096.40698.40308.39924 80.45496.45054.44619.44192.43772.43360.42954.42556.42164.41779 81.47360.46920.46487.46061.45643.45231.44827.44429.44038.43653 82.49223.48785.48355.47932.47516.47106.46703.46307.45916.45532 83.51081.50648.50221.49802.49388.48982.48581.48187.47799.47416 84.52951.52523.52101.51686.51277.50874.50477.50086.49701.49321 85.54847.54425.54009.53600.53196.52798.52406.52019.51638.51262 86.56749.56335.55926.55523.55126.54734.54348.53966.53591.53220 87.58627.58221.57820.57425.57035.56650.56270.55895.55526.55161 88.60477.60079.59688.59301.58919.58542.58170.57802.57439.57081 89.62297.61909.61527.61149.60776.60408.60044.59685.59330.58979 2000–27 I.R.B.51July 3, 2000 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE12.2%12.4%12.6%12.8%13.0%13.2%13.4%13.6%13.8%14.0% 90.64084.63707.63335.62968.62604.62246.61891.61540.61194.60851 91.65803.65437.65076.64719.64366.64017.63672.63330.62993.62659 92.67412.67058.66707.66360.66017.65678.65342.65010.64682.64357 93.68911.68567.68227.67890.67557.67227.66901.66578.66258.65942 94.70321.69988.69657.69330.69006.68686.68369.68055.67744.67437 95.71674.71351.71031.70713.70399.70088.69781.69476.69174.68875 96.72959.72646.72335.72028.71724.71422.71123.70828.70534.70244 97.74156.73853.73552.73254.72959.72666.72376.72089.71804.71522 98.75287.74993.74702.74413.74126.73842.73561.73282.73006.72732 99.76401.76117.75834.75555.75277.75002.74730.74459.74191.73926 100.77494.77219.76946.76676.76408.76142.75878.75616.75357.75099 101.78580.78315.78052.77791.77532.77275.77021.76768.76517.76268 102.79654.79399.79146.78894.78645.78397.78152.77908.77666.77426 103.80724.80479.80236.79994.79755.79517.79280.79046.78813.78582 104.81879.81646.81413.81183.80954.80726.80501.80276.80054.79832 105.83005.82782.82560.82340.82121.81904.81688.81474.81260.81049 106.84485.84277.84071.83866.83662.83459.83257.83057.82857.82659 107.86311.86124.85937.85751.85566.85382.85199.85017.84835.84655 108.89266.89114.88963.88812.88662.88513.88364.88216.88068.87922 109.94563.94484.94405.94326.94248.94170.94092.94014.93937.93860 July 3, 2000522000–27 I.R.B. LIFE TABLE TABLE 90CM APPLICABLE AFTER APRIL 30, 1999 Age xl(x)Age xl(x)Age xl(x) (1)(2)(1)(2)(1)(2) 010000037959697462852 19906438957807560449 29899239955817657955 39894440953737755373 49890741951567852704 59887742949287949943 69885043946878047084 79882644944318144129 89880345941548241091 99878346938558337994 109876647935288434876 119875048931738531770 129873449927878628687 139871350923708725638 149868151919188822658 159863552914248919783 169857353908859017046 179849754902979114466 189840955896589212066 19983145688965939884 20982155788214947951 21981135887397956282 22980065986506964868 23978966085537973694 24977846184490982745 25976716283368991999 269755663821691001424 27974416480887101991 28973226579519102672 29971996678066103443 30970706776531104284 31969346874907105175 32967916973186106105 3396642707135710760 3496485716941110833 3596322726734410917 369615073651541100 2000–27 I.R.B.53July 3, 2000 (e) Effective dates. This section applies after April 30, 1999. §20.2031–7T [Removed] Par. 13a. Section 20.2031–7T is re- moved. Par. 14. Section 20.7520–1 is amended by revising paragraphs (a)(2), (b)(2), (c)(1), (c)(2) and (d) to read as follows: §20.7520–1 Valuation of annuities, uni- trust interests, interests for life or term of years, and remainder or reversionary in- terests. (a) * * * (2) In the case of a transfer to a pooled income fund with a valuation date after April 30, 1999, see §1.642(c)–6(e) (or, for certain prior periods, §1.642(c)–6A of this chapter) of this chapter with respect to the valuation of the remainder interest. * * * * * (b) * * * (2) Mortality component. The mortal- ity component reflects the mortality data most recently available from the United States Census. As new mortality data be- comes available after each decennial cen- sus, the mortality component described in this section will be revised periodically and the mortality component tables will be published in the regulations at that time. For decedents’ estates with valua- tion dates after April 30, 1999, the mortal- ity component table (Table 90CM) is in- cluded in §20.2031–7(d)(7). See §20.2031–7A for mortality component ta- bles applicable to decedent’s estates with valuation dates before May 1, 1999. (c) * * * (1) Regulation sections containing ta- bles with interest rates between 4.2 and 14 percent for valuation dates after April 30, 1999. Section 1.642(c)–6(e)(6) of this chapter contains Table S used for deter- mining the present value of a single life remainder interest in a pooled income fund as defined in §1.642(c)–5 of this chapter. See §1.642(c)–6A of this chapter for single life remainder factors applica- ble to valuation dates before May 1, 1999. Section 1.664–4(e)(6) of this chapter con- tains Table F (payout factors) and Table D (actuarial factors used in determining the present value of a remainder interest post- poned for a term of years). Section 1.664–4(e)(7) of this chapter contains Table U(1) (unitrust single life remainder factors). These tables are used in deter- mining the present value of a remainder interest in a charitable remainder unitrust as defined in §1.664–3 of this chapter. See §1.664–4A of this chapter for unitrust single life remainder factors applicable to valuation dates before May 1, 1999. Sec- tion 20.2031–7(d)(6) contains Table B (actuarial factors used in determining the present value of an interest for a term of years), Table K (annuity end-of-interval adjustment factors), and Table J (term cer- tain annuity beginning-of-interval adjust- ment factors). Section 20.2031–7(d)(7) contains Table S (single life remainder factors) and Table 90CM (mortality com- ponents). These tables are used in deter- mining the present value of annuities, life estates, remainders, and reversions. See §20.2031–7A for single life remainder factors and mortality components applica- ble to valuation dates before May 1, 1999. (2) Internal Revenue Service publica- tions containing tables with interest rates between 2.2 and 22 percent for valuation dates after April 30, 1999. The following documents are available for purchase from the Superintendent of Documents, United States Government Printing Of- fice, Washington, DC 20402: (i) Internal Revenue Service Publica- tion 1457, “Actuarial Values, Book Aleph,” (7-1999). This publication in- cludes tables of valuation factors, as well as examples that show how to compute other valuation factors, for determining the present value of annuities, life estates, terms of years, remainders, and rever- sions, measured by one or two lives. These factors may also be used in the val- uation of interests in a charitable remain- der annuity trust as defined in §1.664–2 of this chapter and a pooled income fund as defined in §1.642(c)–5 of this chapter. See §20.2031–7A for publications con- taining tables for valuation dates before May 1, 1999. (ii) Internal Revenue Service Publica- tion 1458, “Actuarial Values, Book Beth,” (7-1999). This publication includes term certain tables and tables of one and two life valuation factors for determining the present value of remainder interests in a charitable remainder unitrust as defined in §1.664–3 of this chapter. See §1.664–4A of this chapter for publications containing tables for valuation dates before May 1, 1999. (iii) Internal Revenue Service Publica- tion 1459, “Actuarial Values, Book Gimel,” (7-1999). This publication in- cludes tables for computing depreciation adjustment factors. See §1.170A–12 of this chapter. (d) Effective date. This section applies after April 30, 1989. §20.7520–1T [Removed] Par. 15. Section 20.7520–1T is re- moved. PART 25—GIFT TAX; GIFTS MADE AFTER DECEMBER 31, 1954 Par. 16. The authority citation for part 25 is amended by removing the entries for Sections 25–2512–5T and 25.7520–1T to read in part as follows: Authority: 26 U.S.C. 7805 * * * §25.2512–0 [Amended] Par. 17. Section 25.2512–0 is amended by removing the entry for §25.2512–5T from the contents listing. Par. 18. Section 25.2512–5 is amended by revising paragraphs (c), (d) and (e) to read as follows: §25.2512–5 Valuation of annuities, uni- trust interests, interests for life or term of years, and remainder or reversionary in- terests. * * * * * (c) Actuarial valuations. The present value of annuities, unitrust interests, life estates, terms of years, remainders, and reversions transferred by gift after April 30, 1999, is determined under paragraph (d) of this section. The present value of annuities, unitrust interests, life estates, terms of years, remainders, and reversions transferred by gift before May 1, 1999, is determined under the following sections: July 3, 2000542000–27 I.R.B. (d) Actuarial valuations after April 30, 1999—(1) In general. Except as other- wise provided in paragraph (b) of this sec- tion and §25.7520–3(b) (relating to ex- ceptions to the use of prescribed tables under certain circumstances), if the valua- tion date for the gift is after April 30, 1999, the fair market value of annuities, life estates, terms of years, remainders, and reversions transferred after April 30, 1999, is the present value of such interests determined under paragraph (d)(2) of this section and by use of standard or special section 7520 actuarial factors. These fac- tors are derived by using the appropriate section 7520 interest rate and, if applica- ble, the mortality component for the valu- ation date of the interest that is being val- ued. See §§25.7520–1 through 25.7520–4. The fair market value of a qualified annuity interest described in section 2702(b)(1) and a qualified unitrust interest described in section 2702(b)(2) is the present value of such interests deter- mined under §25.7520–1(c). (2) Specific interests. When the donor transfers property in trust or otherwise and retains an interest therein, generally, the value of the gift is the value of the property transferred less the value of the donor’s retained interest. However, if the donor transfers property after October 8, 1990, to or for the benefit of a member of the donor’s family, the value of the gift is the value of the property transferred less the value of the donor’s retained interest as determined under section 2702. If the donor assigns or relinquishes an annuity, life estate, remainder, or reversion that the donor holds by virtue of a transfer previ- ously made by the donor or another, the value of the gift is the value of the interest transferred. However, see section 2519 for a special rule in the case of the assign- ment of an income interest by a person who received the interest from a spouse. (i) Charitable remainder trusts.The fair market value of a remainder interest in a pooled income fund, as defined in §1.642(c)–5 of this chapter, is its value determined under §1.642(c)–6(e) of this chapter (see §1.642(c)–6A for certain prior periods). The fair market value of a remainder interest in a charitable remain- der annuity trust, as described in §1.664–2(a) of this chapter, is its present value determined under §1.664–2(c) of this chapter. The fair market value of a remainder interest in a charitable remain- der unitrust, as defined in §1.664–3 of this chapter, is its present value determined under §1.664–4(e) of this chapter. The fair market value of a life interest or term for years in a charitable remainder uni- trust is the fair market value of the prop- erty as of the date of transfer less the fair market value of the remainder interest, determined under §1.664–4(e)(4) and (5) of this chapter. (ii) Ordinary remainder and reversion- ary interests. If the interest to be valued is to take effect after a definite number of years or after the death of one individual, the present value of the interest is com- puted by multiplying the value of the property by the appropriate remainder in- terest actuarial factor (that corresponds to the applicable section 7520 interest rate and remainder interest period) in Table B (for a term certain) or the appropriate Table S (for one measuring life), as the case may be. Table B is contained in §20.2031–7(d)(6) of this chapter and Table S (for one measuring life when the valuation date is after April 30, 1999) is included in §20.2031–7(d)(7) of this chapter and Internal Revenue Service Publication 1457. See §20.2031–7A(e)(4) of this chapter con- taining Table S and Life Table 80CNSMT for valuation of interests after April 30, 1989, and before May 1, 1999. For infor- mation about obtaining actuarial factors for other types of remainder interests, see paragraph (d)(4) of this section. (iii) Ordinary term-of-years and life in- terests. If the interest to be valued is the right of a person to receive the income of certain property, or to use certain nonin- come-producing property, for a term of years or for the life of one individual, the present value of the interest is computed by multiplying the value of the property by the appropriate term-of-years or life inter- est actuarial factor (that corresponds to the applicable section 7520 interest rate and term-of-years or life interest period). Inter- nal Revenue Service Publication 1457 in- cludes actuarial factors for an interest for a term of years in Table B and for the life of one individual in Table S (for one measur- ing life when the valuation date is after April 30, 1999). However, term-of-years and life interest actuarial factors are not in- cluded in Table B in §20.2031–7(d)(6) or Table S in §20.2031–7(d)(7) (or in §20.2031–7A(e)(4)) of this chapter. If In- ternal Revenue Service Publication 1457 (or any other reliable source of term-of- years and life interest actuarial factors) is not conveniently available, an actuarial factor for the interest may be derived mathematically. This actuarial factor may be derived by subtracting the correlative remainder factor (that corresponds to the applicable section 7520 interest rate) in Table B (for a term of years) in §20.2031–7(d)(6) of this chapter or in Table S (for the life of one individual) in §20.2031–7(d)(7) of this chapter, as the case may be, from 1.000000. For informa- tion about obtaining actuarial factors for other types of term-of-years and life inter- ests, see paragraph (d)(4) of this section. (iv) Annuities. (A) If the interest to be valued is the right of a person to receive an annuity that is payable at the end of each year for a term of years or for the life of one individual, the present value of the interest is computed by multiplying the aggregate amount payable annually by the appropriate annuity actuarial factor (that corresponds to the applicable section 7520 interest rate and annuity period). In- ternal Revenue Service Publication 1457 includes actuarial factors in Table B (for an annuity payable for a term of years) 2000–27 I.R.B.55July 3, 2000 TransfersApplicable AfterBeforeRegulations 01-01-5225.2512–5A(a) 12-31-5101-01-7125.2512–5A(b) 12-31-7012-01-8325.2512–5A(c) 11-30-8305-01-8925.2512–5A(d) 04-30-8905-01-9925.2512–5A(e) and in Table S (for an annuity payable for the life of one individual when the valua- tion date is after April 30, 1999). How- ever, annuity actuarial factors are not in- cluded in Table B in §20.2031–7(d)(6) of this chapter or Table S in §20.2031–7(d)(7) (or in §20.2031–7A(e)(4)) of this chapter. If In- ternal Revenue Service Publication 1457 (or any other reliable source of annuity actuarial factors) is not conveniently available, an annuity factor for a term of years or for one life may be derived math- ematically. This annuity factor may be derived by subtracting the applicable re- mainder factor (that corresponds to the applicable section 7520 interest rate and annuity period) in Table B (in the case of a term-of-years annuity) in §20.2031–7(d)(6) of this chapter or in Table S (in the case of a one-life annuity) in §20.2031–7(d)(7) of this chapter, as the case may be, from 1.000000 and then di- viding the result by the applicable section 7520 interest rate expressed as a decimal number. See §20.2031–7(d)(2)(iv) of this chapter for an example that illustrates the computation of the present value of an an- nuity. (B) If the annuity is payable at the end of semiannual, quarterly, monthly, or weekly periods, the product obtained by multiplying the annuity factor by the ag- gregate amount payable annually is then multiplied by the applicable adjustment factor set forth in Table K in §20.2031–7(d)(6) of this chapter at the appropriate interest rate component for payments made at the end of the specified periods. The provisions of this paragraph (d)(2)(iv)(B) are illustrated by the follow- ing example: Example. In July, the donor agreed to pay the an- nuitant the sum of $10,000 per year, payable in equal semiannual installments at the end of each pe- riod. The semiannual installments are to be made on each December 31st and June 30th. The annuity is payable until the annuitant’s death. On the date of the agreement, the annuitant is 68 years and 5 months old. The donee annuitant’s age is treated as 68 for purposes of computing the present value of the annuity. The section 7520 rate on the date of the agreement is 10.6 percent. Under Table S in §20.2031–7(d)(7) of this chapter, the factor at 10.6 percent for determining the present value of a re- mainder interest payable at the death of an individ- ual aged 68 is .29691. Converting the remainder factor to an annuity factor, as described above, the annuity factor for determining the present value of an annuity transferred to an individual age 68 is 6.6329 (1.00000 minus .29691 divided by .106). The adjustment factor from Table K in §20.2031–7(d)(6) of this chapter in the column for payments made at the end of each semiannual period at the rate of 10.6 percent is 1.0258. The aggregate annual amount of the annuity, $10,000, is multiplied by the factor 6.6329 and the product multiplied by 1.0258. The present value of the donee’s annuity is, therefore, $68,040.29 ($10,000 X 6.6329 X 1.0258). (C) If an annuity is payable at the be- ginning of annual, semiannual, quarterly, monthly, or weekly periods for a term of years, the value of the annuity is com- puted by multiplying the aggregate amount payable annually by the annuity factor described in paragraph (d)(2)(iv)(A) of this section; and the prod- uct so obtained is then multiplied by the adjustment factor in Table J in §20.2031–7(d)(6) of this chapter at the appropriate interest rate component for payments made at the beginning of speci- fied periods. If an annuity is payable at the beginning of annual, semiannual, quarterly, monthly, or weekly periods for one or more lives, the value of the annuity is the sum of the first payment plus the present value of a similar annuity, the first payment of which is not to be made until the end of the payment period, deter- mined as provided in paragraph (d)(2)(iv)(B) of this section. (v) Annuity and unitrust interests for a term of years or until the prior death of an individual—(A) Annuity interests. The present value of an annuity interest that is payable until the earlier to occur of the lapse of a specific number of years or the death of an individual may be computed with values from the tables in §20.2031–7(d)(6) and (d)(7) of this chap- ter as described in the following example: Example. The donor transfers $100,000 into a trust and retains the right to receive an annuity from the trust in the amount of $6,000 per year, payable in equal semiannual installments at the end of each pe- riod. The semiannual installments are to be made on each June 30th and December 31st. The annuity is payable for 10 years or until the donor’s prior death. At the time of the transfer, the donor is 59 years and 6 months old. The donor’s age is taken as 60 for purposes of computing the present value of the re- tained annuity. The section 7520 rate for the month in which the transfer occurred is 9.8 percent. The present value of the donor’s retained interest is $35,709.13, determined as follows: July 3, 2000562000–27 I.R.B. TABLE S value at 9.8 percent, age 60 . . . . . . . . . . . . . . . . . . ..21669 TABLE S value at 9.8 percent, age 70 . . . . . . . . . . . . . . ..34762 TABLE 90CM value at age 70 . . . . . . . . . . . . . . . . . . . . .71357 TABLE 90CM value at age 60 . . . . . . . . . . . . . . . . . . . . .85537 TABLE B value at 9.8 percent, 10 years . . . . . . . . . . . . ..392624 TABLE K value at 9.8 percent . . . . . . . . . . . . . . . . . . . . .1.0239 Factor for donor’s retained interest at 9.8 percent: (1.00000 - .21669) - (.392624 X (71357/85537) X (1.00000 - .34762))= 5.8126 .098 Present value of donor’s retained interest: ($6,000 X 5.8126 X 1.0239) ........... $35,709.13 (B) Unitrust interests. The present value of a unitrust interest that is payable until the earlier to occur of the lapse of a specific number of years or the death of an individual may be computed with val- ues from the tables in §§1.664–4(e)(6) and (e)(7) and §20.2031–7(d)(7) of this chapter as described in the following ex- ample: Example. The donor who, as of the nearest birth- day, is 60 years old, transfers $100,000 to a unitrust on January 1 st . The trust instrument requires that each year the trust pay to the donor, in equal semian- nual installments on June 30th and December 31st, 6 percent of the fair market value of the trust assets, valued as of January 1st each year, for 10 years or until the prior death of the donor. The section 7520 rate for the January in which the transfer occurred is 9.8 percent. Under Table F(9.8) in §1.664–4(e)(6) of this chapter, the appropriate adjustment factor is .932539 for semiannual payments payable at the end of the semiannual period. The adjusted payout rate is 5.595 percent (6% X .932539). The present value of the donor’s retained interest is $40,848.00 deter- mined as follows: TABLE U(1) value at 5.6 percent, age 60 . . . . . . . . . . . ..35375 TABLE U(1) value at 5.6 percent, age 70 . . . . . . . . . . . .49342 TABLE 90CM value at age 70 . . . . . . . . . . . . . . . . . . . . .71357 TABLE 90CM value at age 60 . . . . . . . . . . . . . . . . . . . . .85537 TABLE D value at 5.6 percent, 10 years . . . . . . . . . . . . ..561979 Factor for donor’s retained interest at 5.6 percent: (1.000000 - .35375) - (.561979 X (71357/85537) X (1.000000 - .49342)) = .40876 TABLE U(1) value at 5.4 percent, age 60 . . . . . . ..36542 TABLE U(1) value at 5.4 percent, age 70 . . . . . . ..50473 TABLE 90CM value at age 70 . . . . . . . . . . . . . . .71357 TABLE 90CM value at age 60 . . . . . . . . . . . . . . . .85537 TABLE D value at 5.4 percent, 10 years . . . . . . ..573999 Factor for donor’s retained interest at 5.4 percent: (1.000000 - .36542) - (.573999 X (71357/85537) X (1.000000 - .50473)) = .39742 Difference.01134 Interpolation adjustment: 5.595% - 5.4%= x 0.2% .01134 x = .01106 Factor at 5.4 percent, age 60 . . . . . . . . . . . . . . . . . ..39742 Plus: Interpolation adjustment . . . . . . . . . . . . . . . ..01106 Interpolated Factor . . . . . . . . . . . . . . . . . . . . . . . . ..40848 Present value of donor’s retained interest: ($100,000 X .40848) . . . . . .$40,848.00 2000–27 I.R.B.57July 3, 2000 (3) Transitional rule. If the valuation date of a transfer of property by gift is after April 30, 1999, and before July 1, 1999, the fair market value of the interest transferred is determined by use of the section 7520 interest rate for the month in which the valuation date occurs (see §§25.7520–1(b) and 25.7520–2(a)(2)) and the appropriate actuarial tables under either paragraph (d)(2) of this section or §25.2512–5A(e), at the option of the donor. However, with respect to each in- dividual transaction and with respect to all transfers occurring on the valuation date, the donor must use the same actuar- ial tables (for example, gift and income tax charitable deductions with respect to the same transfer must be determined based on the same tables, and all transfers made on the same date must be valued based on the same tables). (4) Publications and actuarial compu- tations by the Internal Revenue Service. Many standard actuarial factors not in- cluded in §§20.2031–7(d)(6) or (d)(7) of this chapter are included in Internal Rev- enue Service Publication 1457, “Actuarial Values, Book Aleph,” (7-1999). Internal Revenue Service Publication 1457 also includes examples that illustrate how to compute many special factors for more unusual situations. A copy of this publi- cation is available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402. See §25.2512–5A for publications containing actuarial factors for valuing interests for which the valuation date is before May 1, 1999. If a special factor is required in the case of a completed gift, the Service may furnish the factor to the donor upon a re- quest for a ruling. The request for a rul- ing must be accompanied by a recitation of the facts including a statement of the date of birth for each measuring life, the date of the gift, any other applicable dates, and a copy of the will, trust, or other relevant documents. A request for a ruling must comply with the instructions for requesting a ruling published periodi- cally in the Internal Revenue Bulletin (see §§601.201 and 601.601(d)(2)(ii)(b) of this chapter) and include payment of the required user fee. (e) Effective dates. This section applies after April 30, 1999. §25.2512–5T [Removed] Par. 19. Section 25.2512–5T is re- moved. Par. 20. Section 25.7520–1 is amended by revising paragraphs (b)(2), (c)(1), (c)(2) and (d) to read as follows: §25.7520–1 Valuation of annuities, uni- trust interests, interests for life or term of years, and remainder or reversionary in- terests. * * * * * (b) * * * (2) Mortality component. The mortal- ity component reflects the mortality data most recently available from the United States Census. As new mortality data be- comes available after each decennial cen- sus, the mortality component described in this section will be revised periodically and the mortality component tables will be published in the regulations at that time. For gifts with valuation dates after April 30, 1999, the mortality component table (Table 90CM) is included in §20.2031–7(d)(7) of this chapter. See §20.2031–7A of this chapter for mortality component tables applicable to decedent’s estates with valuation dates before May 1, 1999. (c) * * * (1) Regulation sections containing ta- bles with interest rates between 4.2 and 14 percent for valuation dates after April 30, 1999. Section 1.642(c)–6(e)(6) of this chapter contains Table S used for deter- mining the present value of a single life re- mainder interest in a pooled income fund as defined in §1.642(c)–5 of this chapter. See §1.642(c)–6A for single life remainder factors applicable to valuation dates before May 1, 1999. Section 1.664–4(e)(6) of this chapter contains Table F (payout factors) and Table D (actuarial factors used in de- termining the present value of a remainder interest postponed for a term of years). Section 1.664–4(e)(7) of this chapter con- tains Table U(1) (unitrust single life re- mainder factors). These tables are used in determining the present value of a remain- der interest in a charitable remainder uni- trust as defined in §1.664–3 of this chapter. See §1.664–4A for unitrust single life re- mainder factors applicable to valuation dates before May 1, 1999. Section 20.2031–7(d)(6) of this chapter contains Table B (actuarial factors used in determin- ing the present value of an interest for a term of years), Table K (annuity end-of-in- terval adjustment factors), Table J (term certain annuity beginning-of-interval ad- justment factors). Section 20.2031–7(d)(7) of this chapter contains Table S (single life remainder factors) and Table 90CM (mortality components). These tables are used in determining the present value of annuities, life estates, re- mainders, and reversions. See §20.2031–7A of this chapter for single life remainder factors and mortality compo- nents applicable to valuation dates before May 1, 1999. (2) Internal Revenue Service publica- tions containing tables with interest rates between 2.2 and 22 percent for valuation dates after April 30, 1999. The following documents are available for purchase from the Superintendent of Documents, United States Government Printing Of- fice, Washington, DC 20402: (i) Internal Revenue Service Publica- tion 1457, “Actuarial Values, Book Aleph,” (7-1999). This publication in- cludes tables of valuation factors, as well as examples that show how to compute other valuation factors, for determining the present value of annuities, life estates, terms of years, remainders, and rever- sions, measured by one or two lives. These factors may also be used in the val- uation of interests in a charitable remain- der annuity trust as defined in §1.664–2 of this chapter and a pooled income fund as defined in §1.642(c)–5 of this chapter. See §25–2512–5A for publications con- taining tables for valuation dates before May 1, 1999. (ii) Internal Revenue Service Publication 1458, “Actuarial Values, Book Beth,” (7- 1999). This publication includes term cer- tain tables and tables of one and two life valuation factors for determining the present value of remainder interests in a charitable remainder unitrust as defined in §1.664–3 of this chapter. See §1.664–4A of this chapter for publications containing tables for valua- tion dates before May 1, 1999. (iii) Internal Revenue Service Publica- tion 1459, “Actuarial Values, Book Gimel,” (7-1999). This publication in- cludes tables for computing depreciation adjustment factors. See §1.170A–12 of this chapter. (d) Effective date. This section applies after April 30, 1989. §25.7520–1T [Removed] Par. 21. Section 25.7520–1T is re- moved. PARTS 1, 20 AND 25 [AMENDED] Par. 22. In the list below, for each sec- tion indicated in the left column, remove the language in the middle column and add the language in the right column: July 3, 2000582000–27 I.R.B. SectionRemoveAdd 1.170A–12(e)(2),§20.2031–7T§20.2031–7 following the formula 1.642(c)–6A(e)(2)(ii),§1.642(c)–6T(e)(3)(ii)§1.642(c)–6(e)(3)(ii) last sentence 1.642(c)–6A(e)(3)§1.642(c)–6T(e)(4)§1.642(c)–6(e)(4) 1.642(c)–6A(e)(4),§1.642(c)–6T(e)(5)§1.642(c)–6(e)(5) last sentence 1.664–1(a)(6),§§1.664–4T(e), §§1.664–4(e) and introductory text1.664–4T(e) and1.664–4A(d) and (e) 1.664–4A(d) and (e) 1.664–4(e)(6),§1.664–4T(e)(7)paragraph (e)(5) of second sentencethis section 1.664–4A(e)(4),§1.664–4T(e)(4)§1.664–4(e)(4) fifth sentence 1.664–4A(e)(4),§1.664–4T(e)(4)§1.664–4(e)(4) last sentence SectionRemoveAdd 1.664–4A(e)(5),§1.664–4T(e)(5)§1.664–4(e)(5) fourth sentence 1.664–4A(e)(5),§1.664–4T(e)(5)§1.664–4(e)(5) last sentence 1.7520–1(a)(2)§1.642(c)–6T(e)§1.642(c)–6(e) 20.2031–7A(e)(1),§20.2031–7T(d)§20.2031–7(d) first sentence 20.2055–2(f)(4)§20.2031–7T(d)§20.2031–7(d) 25.2512–5A(e)(1),§25.2512–5T(d)§25.2512–5(d) first sentence 25.7520–1(a)(2)§1.642(c)–6T(e)§1.642(c)–6(e) 25.7520–3(b)(2)(v),§20.2031–7T(d)(7)§20.2031–7(d)(7) Example 5 (iii) 2000–27 I.R.B.59July 3, 2000 Robert E. Wenzel, Deputy Commissioner of Internal Revenue. Approved May 17, 2000. Jonathan Talisman, Deputy Assistant Secretary of the Treasury (Tax Policy). (Filed by the Office of the Federal Ragister on June 9, 2000, 8:45 a.m., and published in the issue of the Federal Register for June 12, 2000, 65 F.R. 36908) Section 7872.—Treatment of Loans with Below-Market Interest Rates The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of July 2000. See Rev. Rul. 2000–32, page 1. 26 CFR 601.602: Forms and instructions. (Also Part 1, Sections 220, 408, 408A, 6041, 6041A, 6042, 6043, 6044, 6045, 6047, 6049, 6050A, 6050B, 6050D, 6050E, 6050H, 6050J, 6050N, 6050P, 6050Q, 6050R, 6050S, 1.408–5, 1.408–7, 1.408A–7, 1.6041–1, 7.6041–1, 1.6042–2, 1.6042–4, 1.6044–2, 1.6044–5, 1.6045–1, 5f.6045–1, 1.6045–2, 1.6045–4, 1.6047–1, 1.6049–4, 1.6049–6, 1.6049–7, 1.6050A–1, 1.6050B–1, 1.6050D–1, 1.6050E–1, 1.6050H–1, 1.6050H–2, 1.6050J–1T, 1.6050N–1, 1.6050P–1). Rev. Proc. 2000–28 TABLE OF CONTENTS PART 1 - GENERAL INFORMATION Section 1.1 - Overview of Revenue Procedure 2000–28 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .61 Section 1.2 - General Requirements for Acceptable Substitute Forms 1096, 1098, 1099, 5498, and W-2G . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .62 Section 1.3 - Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .63 PART 2 - SPECIFICATIONS FOR SUBSTITUTE FORMS 1096 AND COPIES A OF FORMS 1098, 1099, AND 5498 (ALL FILED WITH THE IRS) Section 2.1 - Specifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .64 Section 2.2 - Instructions for Preparing Paper Forms That Will Be Filed With the IRS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .66 PART 3 - SPECIFICATIONS FOR SUBSTITUTE FORM W-2G (FILED WITH THE IRS) Section 3.1 - General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .68 Section 3.2 - Specifications for Copy A of Form W-2G . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .68 PART 4 - SUBSTITUTE STATEMENTS TO FORM RECIPIENTS AND FORM RECIPIENT COPIES Section 4.1 - Specifications. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .69 Section 4.2 - Composite Statements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .71 Section 4.3 - Required Legends. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .72 Section 4.4 - Miscellaneous Instructions for Copies B, C, D 1, and 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . .73 PART 5 - ADDITIONAL INSTRUCTIONS FOR SUBSTITUTE FORMS 1098, 1099, 5498, AND W-2G Section 5.1 - OMB Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .74 Section 5.2 - Reproducible Copies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .74 Section 5.3 - Effect on Other Revenue Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .75 PART 6 - EXHIBITS Section 6.1 - Exhibits of Forms in the Revenue Procedure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .76 July 3, 2000602000–27 I.R.B. Part III. Administrative, Procedural, and Miscellaneous Part 1 General Information Section 1.1 - Overview of Revenue Procedure 2000–28 1.1.1 PurposeThe purpose of this revenue procedure is to set forth the requirements for the year 2000 for: •Using official Internal Revenue Service (IRS) forms to file information returns with the IRS, •Preparing acceptable substitutes of the official IRS forms to file information returns with the IRS, and •Using official or acceptable substitute forms to furnish information to recipients. 1.1.2 Which This revenue procedure contains specifications for these information returns: Forms Are Covered? 1.1.3 ScopeFor purposes of this revenue procedure, a substitute form or statement is one that is not printed by the IRS. For a substitute form or statement to be acceptable to the IRS, it must conform to the official form or the specifications outlined in this revenue procedure. Do not submit any substitute forms or statements listed above to the IRS for approval. Privately printed forms may not state “This is an IRS approved form.” Filers making payments to certain recipients during a calendar year are required by the Internal Revenue Code (the Code) to file information returns with the IRS for these payments. These filers must also provide this information to their recipients. In some cases, this also applies to payments received. See Part 4for specifications that apply to recipient statements (generally Copy B). In general, section 6011 of the Code contains requirements for filers of information returns. A filer must file information returns on magnetic media, through electronic filing, or on paper. A filer who is required to file 250 or more information returns of any one type during a calendar year must file those returns by magnetic media or electronic filing. 2000–27 I.R.B.61July 3, 2000 FormTitle 1096 Annual Summary and Transmittal of U.S. Information Returns 1098Mortgage Interest Statement 1098-EStudent Loan Interest Statement 1098-TTuition Payments Statement 1099-AAcquisition or Abandonment of Secured Property 1099-BProceeds From Broker and Barter Exchange Transactions 1099-CCancellation of Debt 1099-DIVDividends and Distributions 1099-GCertain Government and Qualified State Tuition Program Payments 1099-INTInterest Income 1099-LTCLong-Term Care and Accelerated Death Benefits 1099-MISCMiscellaneous Income 1099-MSADistributions From an MSA or Medicare+Choice MSA 1099-OIDOriginal Issue Discount 1099-PATRTaxable Distributions Received From Cooperatives 1099-RDistributions From Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts, etc. 1099-SProceeds From Real Estate Transactions 5498IRA Contribution Information 5498-MSAMSA or Medicare+Choice MSA Information W-2GCertain Gambling Winnings Exception.Filers are not required to use magnetic media or electronic filing when filing 250 or more Forms 1098-Eor 1098-T. Although not required, small volume filers (fewer than 250 returns during a calendar year) and Form 1098-E and 1098-T filers may file the forms on magnetic media or electronically. See the legal requirements for fil- ing information returns (and providing a copy to a payee) in the 2000 General Instructions for Forms 1099, 1098, 5498, and W-2G.In addition, see Pub. 1220,Specifications for Filing Forms 1098, 1099, 5498, and W-2G Magnetically or Electronically. 1.1.4 For More The IRS prints and provides the forms on which various payments must be reported. Alternatively, filers may Informationprepare substitute copies of these IRS forms and use such forms to report payments to the IRS. •For copies of the official forms and the instruction booklet for the reporting year, call our toll-free num- ber at 1-800-TAX-FORM (1-800- 829-3676). •The IRS operates a central call site in Martinsburg, WV, to answer questions related to information returns, penalties, and backup withholding. Call 304-263-8700 Monday through Friday 8:30 a.m. to 4:30 p.m. eastern time. The TTY/TDD number is 304-267-3367. 1.1.5 Changes The following changes have been made to this year’s Revenue Procedure: to the Revenue •A new Part 4, made up of sections from other Parts, has been added to better address recipient Procedurestatements. (Old Part 4 is now Part 5.) •We have rearranged certain sections in the document for easier understanding. For instance, Section 1.4of last year’s Revenue Procedure is now Section 2.2. •We are now providing general and specific form instructions as separate products for 2000. The 2000 General Instructions for Forms 1099, 1098, 5498, and W-2G contain general information for all forms. Separate specific instructions provide information for specific 2000 forms. These new products are referred to on the faces and in the notes on the backs of the forms. •We slightly revised Section 5.1 (OMB Requirements). •The form dimensions shown on the exhibits have been slightly revised to reflect the actual dimensions of official IRS forms. Section 1.2 - General Requirements for Acceptable Substitute Forms 1096, 1098, 1099, 5498, and W-2G 1.2.1 Paper substitutes for Form 1096 and Copy A of Forms 1098, 1099, 5498, and W-2G that totally conform to Introductionthe specifications listed in this revenue procedure may be privately printed and filed as returns with the IRS. The reference to the Department of the Treasury - Internal Revenue Service should be included on all such forms. If you are uncertain of any specification and want it clarified, you may submit a letter citing the spec- ification, stating your understanding and interpretation of the specification, and enclosing an example of the form (if appropriate) to: Internal Revenue Service Attn: Substitute Forms Program OP:FS:FP:F:CD 1111 Constitution Ave., NW Room 5244 IR Washington, DC 20224 Note:Allow at least 45 days for the IRS to respond. Forms 1096, 1098, 1099, 5498, and W-2G are subject to annual review and possible change. Therefore, filers are cautioned against overstocking supplies of privately printed substitutes. The specifications contained in this revenue procedure apply to 2000 forms only. 1.2.2 Copy AProposed substitutes for Copy A that do not conform to the specifications in this revenue procedure are not Specificationsacceptable. Further, if you file such forms with the IRS, you may be subject to a penalty for failure to file an information return under section 6721 of the Code. Generally, the penalty is $50 for each failure to file a form (up to $250,000) that the IRS cannot accept as a return because it does not meet the provisions in this revenue procedure. No IRS office is authorized to allow deviations from this revenue procedure. July 3, 2000622000–27 I.R.B. 1.2.3 Copy B Copies B and Copies C of the following forms must contain the information in Section 1.5to be considered a and Copy C “statement” or “official form” under the applicable provisions of the Code. The format of this information is Specificationsat the discretion of the filer with the exception of the location of the tax year, form number, form name, and the information for composite Form 1099 statements as outlined under Section 4.2. Copy B of the following forms are: Copy C of the following forms are: Note: On Copy C, Form 1099-LTC, you may reverse the locations of the policyholder’s and the insured’s name, street address, city, state, and ZIP code for easier mailing. Section 1.3 - Definitions 1.3.1 Form Form recipientmeans the person to whom you are required by law to furnish a copy of the official form or Recipientinformation statement. The form recipient may be referred to by different names on various Forms 1099 and related forms (“payer/borrower,” “borrower,” “student,” “debtor,” “policyholder,” “insured,” “transferor,” “payment recipient,” “participant,” or, in the case of Form W-2G, the “winner”). See Section 1.2.3 earlier. 1.3.2 FilerFilermeans the person or organization required by law to file a form listed in Section 1.1.2with the IRS. As outlined earlier, a filer may be a payer, creditor, recipient of mortgage or student loan interest payments, edu- cational institution, broker, barter exchange, person reporting real estate transactions, trustee or issuer of any individual retirement arrangement or medical savings account, or lender who acquires an interest in secured property or who has reason to know that the property has been abandoned. 1.3.3 Substitute Substitute formmeans a paper substitute of Copy A of an official form listed in Section 1.1.2that totally Formconforms to the provisions in this revenue procedure. 1.3.4 Substitute Substitute form recipient statement means a paper statement of the information reported on a form listed in Form Recipient Section 1.1.2. This statement must be furnished to a person (form recipient), as defined under the applicable Statementprovisions of the Code and the applicable regulations. 2000–27 I.R.B.63July 3, 2000 FormRecipient 1098For Payer/Borrower 1098-E; 1099-AFor Borrower 1098-TFor Student 1099-CFor Debtor 1099-LTCFor Policyholder 1099-R; W-2G(These forms may require Copy B to be attached to the Federal income tax return.) 1099-SFor Transferor All other Forms 1099For Recipient 5498; 5498-MSAFor Participant Form Recipient 1099-LTCFor Insured 1099-RFor Recipient’s Records W-2GFor Winner’s Records 1.3.5 Composite Composite substitute statementmeans one in which two or more required statements (e.g., Forms 1099- Substitute INT and 1099-DIV) are furnished to the recipient on one document. However, each statement must be desig- Statementnated separately and must contain all the requisite Form 1099 information except as provided under Section 4.2. A composite statement may notbe filed with the IRS. Part 2 Specifications for Substitute Forms 1096 and Copies A of Forms 1098, 1099,and 5498 (All Filed With the IRS) Section 2.1 - Specifications 2.1.1 General Form identifying numbers (e.g., 9191 for Form 1099-DIV) must be printed in nonreflective black carbon- Requirementsbased ink in print positions 15 through 19 using an OCR A font. The checkboxes to the right of the form identifying numbers must be 10-point boxes. The “VOID” checkbox is in print position 25. The “COR- RECTED” checkbox is in position 33. Measurements are from the left edge of the paper, not including the perforated strip. See Exhibits D and K. The substitute form must be an exact replica of the official IRS form with respect to layout and content. To determine the correct form measurements, see Exhibits A through Tat the end of this publication. Hot wax and cold carbon spots are not permitted on any of the internal form plies. These spots are permitted on the back of a mailer top envelope ply. Use of chemical transfer paper for Copy A is acceptable. The Government Printing Office (GPO) symbol must be deleted. 2.1.2 Color and Color and paper quality for Copy A (cut sheets and continuous pinfeed forms) as specified by JCP Code 0-25, Paper Qualitydated November 29, 1978, must be white 100% bleached chemical wood, optical character recognition (OCR) bond produced in accordance with the following specifications. Note: Reclaimed fiber in any percentage is permitted provided the requirements of this standard are met. •Acidity: Ph value, average, not less than . . . . . . . . . . . . . . . . . . . . . . . . . .4.5 •Basis Weight: 17 x 22-500 cut sheets . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18-20 Metric equivalent—g/m 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .75 A tolerance of +5 pct. is allowed. •Stiffness: Average, each direction, not less than—milligrams . . . . . . . . . . .50 •Tearing strength: Average, each direction, not less than—grams . . . . . . . . .40 •Opacity: Average, not less than—percent . . . . . . . . . . . . . . . . . . . . . . . . . .82 •Thickness: Average—inch . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .0.0038 Metric equivalent—mm . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .0.097 A tolerance of +0.0005 inch (0.0127 mm) is allowed. Paper cannot vary more than 0.0004 inch (0.0102 mm) from one edge to the other. •Porosity: Average, not less than—seconds . . . . . . . . . . . . . . . . . . . . . . . . .10 •Finish (smoothness): Average, each side—seconds . . . . . . . . . . . . . . . . . .20-55 For information only, the Sheffield equivalent—units . . . . . . . . . . . . . . . . . . . . . . 170-100 •Dirt: Average, each side, not to exceed—parts per million . . . . . . . . . . . . .8 July 3, 2000642000–27 I.R.B. 2.1.3 Chemical Chemical transfer paper is permitted for Copy A only if the following standards are met: Transfer Paper•Only chemically backed paper is acceptable for Copy A. Front and back chemically treated paper can- not be processed properly by machine. •Carbon-coated forms are not permitted. •Chemically transferred images must be black. All copies must be clearly legible.Hot wax and cold carbon spots are notpermitted for Copy A. Interleaved carbonshould be black and must be of good quality to assure legibility on all copies and to avoid smudging. Fading must be minimized to assure legibility. 2.1.4 Printing All print on Copy A of Forms 1098, 1099, 5498,and the print on Form 1096above the statement “Please return this entire page to the Internal Revenue Service. Photocopies are NOT acceptable.”must be in Flint J-6983 red OCR dropout ink or an exact match. However, the four-digit form identifying number mustbe in nonreflective carbon-based blackink in OCR A font. The shaded areas of any substitute form should generally correspond to the format of the official form. The printing for the Form 1096statement and the following text may be in any shade or tone of black ink. Black ink should only appear on the lower part of the reverse side of Form 1096 where it will not bleed through and interfere with scanning. Note: The instructions on the front and back of Form 1096, which include filing addresses, must be printed. Separation between fields must be 0.1 inch. Except for Form 1099-R, the numbered captions are printed as solid with no shaded background. Other printing requirements are discussed below. 2.1.5 OCR The contractor must initiate or have a quality control program to assure OCR ink density. Readings will be Specificationsmade when printed on approved 20 lb. white OCR bond with a reflectance of not less than 80%. Black ink must not have a reflectance greater than 15%. These readings are based on requirements of the “Scan-Optics Series 9000” Optical Scanner using Flint J-6983 red OCR dropout ink or an exact match. The following testers and ranges are acceptable: •MacBeth PCM-II.The tested Print Contrast Signal (PCS) values when using the MacBeth PCM-II tester on the “C” scale must range from .01 minimum to .06 maximum. •Kidder 082A. The tested PCS values when using the Kidder 082A tester on the Infra Red (IR) scale must range from .12 minimum to .21 maximum. White calibration disc must be 100%. Sensitivity must be set at one (1). •Alternative testers.Alternative testers must be approved by the Government so that tested PCS values can be established. You may obtain approval by writing to the following address: Commissioner of Internal Revenue Attn: OP:FS:M:T:M, Room 1225 Tax Products 1111 Constitution Avenue, NW Washington, DC 20224 2.1.6 Type must be substantially identical in size and shape to the official form. All rules are either 1/2-point or Typography3/4-point. Rules must be identical to that on the official IRS form. Note:The form identifying number must be nonreflective carbon-based black ink in OCR A font. 2.1.7 Three Forms 1098, 1099, or 5498 (Copy A)are contained on a single page, Dimensions8 inches wide (without any snap-stubs and/or pinfeed holes) by 11 inches deep. Exception. Form 1099-Rcontains two documents per page. There is a .33 inch top margin from the top of the corrected box, and a .25 inch right margin. There is a 1/32” (0.0313”) tolerance for the right margin. If the right and top margins are properly aligned, the left mar- 2000–27 I.R.B.65July 3, 2000 July 3, 2000662000–27 I.R.B. gin for all forms will be correct. All margins must be free of print. See Exhibits A through Tin this publi- cation for the correct form measurements. These measurements are constant for all Forms 1098, 1099, and 5498.These measurements are shown only once in this publication, on Form 1098 (Exhibit B). Exceptions to these measurements are shown on the rest of the exhibits. The depth of the individual trim size of each form on a page must be 32/3 inches, the same depth as the offi- cial form. Exception. The depth of Form 1099-Ris 51/2 inches. 2.1.8 Copy A (three per page; two per page for Form 1099-R) of privately printed continuous substitute forms Perforationmust be perforated at each 11” page depth. No perforations are allowed between the 3_” forms (5_” for Form 1099-R) on a single copy page of Copy A. The words “Do NOT Cut or Separate Forms on This Page” must be printed in red dropout ink (as required by form specifications) between the three forms (two for Form 1099-R). Note: Perforations are required between all the other individual copies (Copies B and C, and Copies 1 and 2 for Forms 1099-Rand 1099- MISC,and Copy D for Forms 1099-LTCand 1099-R) in the set. 2.1.9 What You must include the OMB Number on Copies Aand Form 1096in the same location as on the official To Includeform. The words “For Privacy Act and Paperwork Reduction Act Notice, see the 2000 General Instructions for Forms 1099, 1098, 5498, and W-2G”must be printed on Copy A; “For more information and the Privacy Act and Paperwork Reduction Act Notice, see the 2000 General Instructions for Forms 1099, 1098, 5498, and W-2G” mustbe printed on Form 1096. A postal indicia may be used if it meets the following criteria: •It is printed in the OCR ink color prescribed for the form, and •No part of the indicia is within one print position of the scannable area. Printer’s symbol — The GPO symbol must not be printed on substitute Copy A. Instead, the employer iden- tification number (EIN) of the forms printer must be entered in the bottom margin on the face of each indi- vidual form of Copy A,or the bottom margin on the reverse side of each Form 1096. The Catalog Number (Cat. No.) shown on the 2000 forms is used for IRS distribution purposes and need not be printed on any substitute forms. The form must notcontain the statement “IRS approved” or any similar statement. Section 2.2 - Instructions for Preparing Paper Forms That Will Be Filed With the IRS 2.2.1 Recipient The form recipient’s name, street address, city, state, and ZIP code information should be typed or machine Informationprinted in black inkin the same format as shown on the official IRS form. The city, state, and ZIP code must be on the same line. The following rules apply to the form recipient’s name(s): •The name of the appropriate form recipient must be shown on the first or second name line in the area provided for the form recipient’s name. •No descriptive information or other name may precede the form recipient’s name. •Only oneform recipient’s name may appear on the first name line of the form. •If the multiple recipients’ names are required on the form, enter on the first name line the recipient name that corresponds to the recipient taxpayer identification number (TIN) shown on the form. Place the other form recipients’ names on the second name line (only 2 name lines are allowable). Because certain states require that trust accounts be provided in a different format, generally filers should provide information returns reflecting payments to trust accounts with the: •Trust’s employer identification number (EIN) in the recipient’s TIN area, 2000–27 I.R.B.67July 3, 2000 •Trust’s name on the recipient’s first name line, and •Name of the trustee on the recipient’s second name line. Although handwritten forms will be accepted, the IRS prefers that filers type or machine printdata entries. Also, filers should insert data in the middle of blockswell separated from other printing and guidelines, and take measures to guarantee clear, dark black, sharp images. Carbon copies and photocopies are not acceptable. 2.2.2 Account You should use the account number box for an account number designation. This number must not appear Number Boxanywhere else on the form, and this box may not be used for any other item. Showing the account number is optional. However, it may be to your benefit to include the recipient’s account number or designation on paper documents if your recordkeeping system uses, for identification pur- poses, the account number or designation in conjunction with, or instead of, the name, social security number, or employer identification number. If you furnish the account number, the IRS will include it in future notices to you about backup withholding. If you use window envelopes and a reduced rate to mail statements to recipients, be sure the account number does not appear in the window. Otherwise, the Postal Service may not accept them for mailing. 2.2.3 Machine-printed forms should be printed using a 6 lines/inch option, and should be printed in 10 pitch pica Specifications (10 print positions per inch) or 12 pitch elite (12 print positions per inch). Proportional spaced fonts are and Restrictionsunacceptable. Substitute forms prepared in continuous or strip form must be burst and stripped to conform to the size specified for a single sheet before they are filed with the IRS. The size specified does not include pinfeed holes.Pinfeed holes must notbe present on forms filed with the IRS. DO NOT: •Use a felt tip marker. The machine used to “read” paper forms generally cannot read this ink type. •Use dollar signs ($), ampersands (&), asterisks (*), commas (,), or other special characters in the num- bered money boxes. Exception.Use decimal points to indicate dollars and cents (e.g., 2000.00 is acceptable). •Fold Forms 1096, 1098, 1099, or 5498mailed to the IRS. Mail these forms flat in an appropriately sized envelope or box. Folded documents cannot be readily moved through the machine used in IRS processing. •Staple Forms 1096 to the transmitted returns. Any staple holes near the return code number may impair the IRS’s ability to machine scan the type of documents. •Type other information on Copy A. •Cut or separate the individual forms on the sheet of forms of Copy A (except Forms W-2G). 2.2.4 Where Mail completed paper forms to the IRS service center shown on the back of Form 1096 and in the 2000 To FileGeneral Instructions for Forms 1099, 1098, 5498, and W-2G.Specific information needed to complete the forms mentioned in this revenue procedure are given in the specific form instructions. A chart is included in the 2000 General Instructions for Forms 1099, 1098, 5498, and W-2Ggiving a quick guide to which form must be filed to report a particular payment. Part 3 Specifications for Substitute Form W-2G (Filed With the IRS) Section 3.1 - General 3.1.1 PurposeThe following specifications give the format requirements for substitute Form W-2G (Copy A only), which is filed with the IRS. A filer may use a substitute Form W-2Gto file with the IRS (referred to as “substitute Copy A”).The sub- stitute form must be an exact replica of the official form with respect to layout and content. Section 3.2 - Specifications for Copy A of Form W-2G 3.2.1 Substitute You must follow these specifications when printing substitute Copy A of Form W-2G. Form W-2G (Copy A) July 3, 2000682000–27 I.R.B. ItemSubstitute Form W-2G (Copy A) Paper Color and QualityPaper for Copy A must be white chemical wood bond, or equiva- lent, 20 pound (basis 17 x 22-500), plus or minus 5 percent. The paper must consist substantially of bleached chemical wood pulp. It must be free from unbleached or ground wood pulp or post- consumer recycled paper. It also must be suitably sized to accept ink without feathering. Ink Color and QualityAll printing must be in a high quality nongloss black ink. TypographyThe type must be substantially identical in size and shape to the official form. All rules on the document are either 1/2 point (.007 inch), 1 point (0.015 inch), or 3 point (0.045). Vertical rules must be parallel to the left edge of the document, horizontal rules to the top edge. DimensionsThe official form is 8 inches wide x 3 2/3 inches deep, exclusive of a 2/3 inch snap stub on the left side of the form. Any substitute Copy A must be the same dimensions. The snap feature is not required on substitutes. All margins must be free of print. The top and right margins must be 1/4 inch plus or minus .0313. If the top and right margins are properly aligned, the left margin for all forms will be correct. If the substitute forms are in contin- uous or strip form, they must be burst and stripped to conform to the size specifiedfor a single form. Hot Wax and Cold Carbon SpotsHot wax and cold carbon spots are not permitted on any of the internal form plies. These spots are permitted on the back of a mailer top envelope ply. Interleaved carbons, if used, should be black and of good quality to avoid smudging. Printer’s SymbolThe Government Printing Office (GPO) symbol must not be print- ed on substitute Forms W-2G. Instead, the employer identifica- tion number (EIN) of the forms printer must be printed in the bot- tom margin on the face of each individual Copy A on a sheet. The form must not contain the statement “IRS approved” or any simi- lar statement. Catalog NumberThe Catalog Number (Cat. No.) shown on Form W-2G is used for IRS distribution purposes and need not be printed on any substi- tute forms. Part 4 Substitute Statements to Form Recipients and Form Recipient Copies Section 4.1 - Specifications 4.1.1 IntroductionIf you do not use the official IRS form to furnish statements to recipients, you must furnish an acceptable substitute statement. To be acceptable, your substitute statement must comply with the rules in this section. In general, see Regulations sections 1.6042–4, 1.6044–5, 1.6049–6, and 1.6050N–1 to determine how certain statements must be provided to recipients (statement mailing requirements for most Forms 1099-DIVand 1099-INT,all Forms 1099-OIDand 1099-PATR,and Form 1099-MISC or 1099-Sfor royalties). Note: A trustee of a grantor-type trust may choose to file Forms 1099and furnish a statement to the grantor under Regulations sections 1.671–4(b)(2)(iii) and (b)(3)(ii). The statement required by those regulations is not subject to the requirements outlined in this section. 4.1.2 Substitute The rules in this section apply to Form 1099-INT(except for interest reportable under section 6041), 1099- Statements to DIV(except for section 404(k) dividends), 1099-OID,and 1099-PATR only.You may furnish form recipi- Recipients forents with Copy Bof the official Form 1099 or a substitute Form 1099 (form recipient statement) if it contains Certain Forms the same language as the official IRS form (such as aggregate amounts paid to the form recipient, any backup 1099-INT and withholding, the name, address, and TIN of the person making the return, and any other information required 1099-DIV, and by the official form). Except for state income tax withholding information, information not required by the for Forms official form should not be included on the substitute form. 1099-OID and 1099-PATRYou may enter a total of the individual accounts listed on the form only if they have been paid by the same payer. For example, if you are listing interest paid on several accounts by one financial institution on Form 1099-INT, you may also enter the total interest amount. You may also enter a date next to the corrected box if that box is checked. A substitute form recipient statement for Forms 1099-INT, 1099-DIV, 1099- OID, or 1099-PATRmust com- ply with the following requirements: 1.Box captions and numbers that are applicable must be clearly identified, using the same wording and numbering as on the official form. Note:For Form 1099-INT,if box 3 is not on your substitute form, you may drop “not included in box 3” from the box 1 caption. 2.The form recipient statement must contain all applicable form recipient instructions provided on the front and back of the official IRS form. Those instructions may be provided on a separate sheet of paper. 3.The form recipient statement must contain the following in bold and conspicuous type: This is important tax information and is being furnished to the Internal Revenue Service. If you are required to file a return, a negligence penalty or other sanction may be imposed on you if this income is taxable and the IRS determines that it has not been reported. 4. The box caption “Federal income tax withheld”must be in boldface type on the form recipient statement. 5.The form recipient statement must contain the Office of Management and Budget (OMB) number as shown on the official IRS form. See Part 5. 6.The form recipient statement must contain the tax year (e.g., 2000), form number (e.g., Form 1099-INT), and form name (e.g., Interest Income) of the official IRS Form 1099. This information must be displayed prominently together in one area of the statement. For example, the tax year, form number, and form name could be shown in the upper right part of the statement. Each copy must be appropriately labeled (such as Copy B, For Recipient). See Section 4.4for applicable labels and arrangement of assembly of forms. Note:Do not include the words “Substitute for” or “In lieu of” on the form recipient statement. 7.Layout and format of the form is at the discretion of the filer. However, the IRS encourages the use of boxes so that the statement has the appearance of a form and can be easily distinguished from other nontax statements. 8.Each recipient statement of Forms 1099-DIV, 1099-INT, 1099-OID,and 1099-PATRmustinclude the direct access telephone number of an individual who can answer questions about the statement. Include that telephone number conspicuously anywhere on the recipient statement. 9.Until new regulations are issued, the IRS will not assess penalties for use of a logo (e.g., the name of the payer in any typeface, font, or style, and/or a symbolic icon) or slogan on a recipient statement if 2000–27 I.R.B.69July 3, 2000 the logo or slogan is used by the payer in the ordinary course of its trade or business. In addition, use of the logo or slogan must not make it less likely for a reasonable payee to recognize the importance of the statement for tax reporting purposes. 10. A mutual fund family may state separately on one document (e.g., one piece of paper) the dividend income earned by a recipient from each fund within the family of funds as required by Form 1099- DIV.However, each fund and its earnings must be stated separately. The form must contain an instruction to the recipient that each fund’s dividends and name, not the name of the mutual fund fami- ly, must be reported on the recipient’s tax return. The form cannot contain an aggregate total of all funds. In addition, a mutual fund family may furnish a single statement (as a single filer) for Forms 1099-INT, 1099-DIV,and 1099- OIDinformation. Each fund and its earnings must be stated separate- ly. The form must contain an instruction to the recipient that each fund’s earnings and name, not the name of the mutual fund family, must be reported on the recipient’s tax return. The form cannot con- tain an aggregate total of all funds. 4.1.3 Substitute Statements to form recipients for Forms 1098, 1098-E, 1098-T, 1099-A, 1099-B, 1099-C, 1099-G, 1099- Statements to LTC, 1099-MISC, 1099-MSA, 1099-R, 1099-S, 5498, 5498-MSA, W-2G, 1099-DIV(only for section Recipients for404(k) dividends reportable under section 6047), and 1099-INT(only for interest of $600 or more made in Certain Forms the course of a trade or business reportable under section 6041) can be copies of the official forms or an 1098, 1099, acceptable substitute. To be acceptable, a substitute form recipient statement must meet the following 5498, and requirements. W-2G1.The tax year, form number, and form name must be the same as the official form and must be displayed prominently together in one area on the statement. For example, they may be shown in the upper right part of the statement. 2.The filer’s and the form recipient’s identifying information required on the official IRS form must be included. 3.Each substitute recipient statement for Forms W-2G, 1098, 1098-E, 1098-T, 1099-A, 1099-B, 1099- DIV, 1099-G(excluding state and local income tax refunds), 1099-INT, 1099-LTC, 1099-MISC (excluding fishing boat proceeds), 1099-OID, 1099-PATR,and 1099-Smustinclude the direct access telephone number of an individual who can answer questions about the statement.You may include the telephone number conspicuously anywhere on the recipient statement. Although not required, payers reporting on Forms 1099-C, 1099-MSA, 1099-R, 5498,and 5498-MSAare encouraged to fur- nish telephone numbers. 4.All applicable money amounts and information, including box numbers, required to be reported to the form recipient must be titled on the form recipient statement in substantially the same manner as those on the official IRS form. The box caption“Federal income tax withheld” must be in boldface type on the form recipient statement. Exception. If you are reporting a payment as “Other income” in box 3 of Form 1099-MISC, you may substitute appropriate language for the box title. For example, for payments of accrued wages and leave to a beneficiary of a deceased employee, you might change the title of box 3 to “Beneficiary payments” or something similar. Note: You cannot make this change on Copy A. 5.You must provide appropriate instructions to the form recipient, similar to those on the official IRS form, to aid in the proper reporting on the form recipient’s income tax return. For payments reported on Form 1099-B,the requirement to include instructions substantially similar to those on the official IRS form may be satisfied by providing form recipients with a single set of instructions for all Forms 1099-Bstatements required to be furnished in a calendar year. Note: If Federal income tax is withheld and shown on Form 1099-Ror W-2G, Copy B and Copy C must be furnished to the recipient. If Federal income tax is not withheld, only Copy C of Form 1099-Rand W-2Gmust be furnished. However, for Form 1099-R,instructions simi- lar to those on the back of the official Copy B and Copy C of Form 1099-Rmust be furnished to the recipient. For convenience, you may choose to provide both Copies B and C of Form 1099-Rto the recipient. 6.If you use carbon to produce recipient statements, the quality of the carbon must meet the following standards: •All copies must beclearly legible, •All copies must be able to be photocopied, and •Fading must not diminish legibility and the ability to photocopy. In general, black chemical transfer inks are preferred, but other colors are permitted if the above stan- dards are met. Hot wax and cold carbon spots are not permitted on any of the internal form plies. The July 3, 2000702000–27 I.R.B. back of a mailer top envelope ply may contain these spots. 7.A mutual fund family may state separately on one document (e.g., one piece of paper) the Form 1099- Binformation for a recipient from each fund as required by Form 1099-B. However, the gross pro- ceeds, etc., from each transaction within a fund must be stated separately. The form must contain an instruction to the recipient that each fund’s (not the mutual fund family’s) name and amount must be reported on the recipient’s tax return. The form cannot contain an aggregate total of all funds. 8.You may use a Uniform Settlement Statement (under the Real Estate Settlement Procedures Act of 1974 (RESPA)) for Form 1099-S.The Uniform Settlement Statement is acceptable as the written statement to the transferor if you include the legend for Form 1099-Sin Section 4.3.2and indicate which information on the Uniform Settlement Statement is being reported to the IRS on Form 1099-S. 9.For reporting state income tax withholding and state payments, you may add an additional box(es) to recipient copies as appropriate. Note:You cannot make this change on Copy A. 10.On Copy C of Form 1099-LTC,you may reverse the location of the policyholder’s and the insured’s name, street address, city, state, and ZIP code for easier mailing. 11.Logos are permitted on substitute recipient statements for the forms listed in this section (Section 4.1.3). Section 4.2 - Composite Statements 4.2.1 Composite A composite form recipient statement is permitted for reportable payments of interest, dividends, original Substitute issue discount, patronage dividends, and royalties (Forms 1099-INT(except for interest reportable under Statements forsection 6041), 1099- DIV(except for section 404(k) dividends), 1099-MISCor 1099-S (for royalties only), Certain Forms 1099-OID,or 1099-PATR) when one payer is reporting more than one of these payments during a calendar 1099-INT, year to the same form recipient. Generally, do not include any other Form 1099information (e.g., 1098 or 1099-DIV, 1099-A)on a composite statement with the information required on the forms listed in the preceding sentence 1099-MISC, and 1099-S, Exception. A filer may include Form 1099-Binformation on a composite form with the forms listed above. and for Forms 1099-OID and Although the composite form recipient statement may be on one sheet, the format of the composite form 1099-PATRrecipient statement must satisfy the following requirements in addition to the requirements listed earlier in Section 4.1.2. •All information pertaining to a particular type of payment must be located and blocked together on the form and separate from any information covering other types of payments included on the form. For example, if you are reporting interest and dividends, the Form1099-INTinformation must be presented separately from the Form 1099-DIVinformation. •The composite form recipient statement must prominently display the tax year, form number, and form name of the official IRS form together in one area at the beginning of each appropriate block of infor- mation. •Any information required by the official IRS forms that would otherwise be repeated in each informa- tion block is required to be listed only once in the first information block on the composite form. For example, there is no requirement to report the name of the filer in each information block. This rule does not apply to any money amounts (e.g., Federal income tax withheld) or to any other information that applies to money amounts. •A composite statement is an acceptable substitute only if the type of payment and the recipient’s tax obligation with respect to the payment are as clear as if each required statement were furnished sepa- rately on an official form. 4.2.2 Composite A composite form recipient statement for the forms specified in Section 4.1.3 is permitted when one filer is Substitute reporting more than one type of payment during a calendar year to the same form recipient. A composite Statements to statement is not allowed for a combination of forms listed in Section 4.1.3and forms listed in Section 4.1.2. Recipients for Forms Specified Exceptions. Form 1099-Binformation may be reported on a composite form with the forms specified in in Section 4.1.3Section 4.1.2as described in Section 4.2.1.In addition, royalties reported on Form 1099-MISC or 1099-Smay be reported on a composite form only with the forms specified in Section 4.1.2. 2000–27 I.R.B.71July 3, 2000 Although the composite form recipient statement may be on one sheet, the format of the composite form recipient statement must satisfy the requirements listed in Section 4.2.1 as well as the requirements in Section 4.1.3. A composite statement of Forms 1098 and 1099-INT(for interest reportable under section 6049) is notallowed. Section 4.3 - Required Legends 4.3.1 Required Form 1098recipient statements (Copy B) must contain the following legends: Legends for•Form 1098 Forms 10981.“The information in boxes 1, 2, and 3 is important tax information and is being furnished to the Internal Revenue Service. If you are required to file a return, a negligence penalty or other sanction may be imposed on you if the IRS determines that an underpayment of tax results because you overstated a deduction for this mortgage interest or for these points or because you did not report this refund of interest on your return.” 2.“Caution: The amount shown may not be fully deductible by you. Limits based on the loan amount and the cost and value of the secured property may apply. Also, you may only deduct interest to the extent it was incurred by you, actually paid by you, and not reimbursed by another person.” •Form 1098-E –“This is important tax information and is being furnished to the Internal Revenue Service. If you are required to file a return, a negligence penalty or other sanction may be imposed on you if the IRS determines that an underpayment of tax results because you overstated a deduction for student loan interest.” •Form 1098-T – “This is important tax information and is being furnished to the Internal Revenue Service.” 4.3.2 Required Forms 1099 and W-2G recipient statements must contain the following legends: Legends for•Forms 1099-A and 1099-C – Copy B Forms 1099 “This is important tax information and is being furnished to the Internal Revenue Service. If you are required to file a return, a negligence penalty or other sanction may be imposed on you if taxable income results from this transaction and the IRS determines that it has not been reported.” and W-2G •Forms 1099-B, 1099-DIV, 1099-G, 1099-INT, 1099-MISC, 1099-OID, 1099-PATR, and W-2G – Copy C “This is important tax information and is being furnished to the Internal Revenue Service. If you are required to file a return, a negligence penalty or other sanction may be imposed on you if this income is taxable and the IRS determines that it has not been reported.” •Form 1099-LTC Copy B – “This is important tax information and is being furnished to the Internal Revenue Service. If you are required to file a return, a negligence penalty or other sanction may be imposed on you if this item is required to be reported and the IRS determines that it has not been reported.” Copy C – “Copy C is provided to you for information only. Only the policyholder is required to report this information on a tax return.” •Form 1099-MSA – Copy B “This information is being furnished to the Internal Revenue Service.” •Form 1099-R – Copy B – “Report this income on your Federal tax return. If this form shows Federal income tax with- held in box 4, attach this copy to your return. This information is being furnished to the Internal Revenue Service.” Copy C – “This information is being furnished to the Internal Revenue Service.” •Form 1099-S – Copy B “This is important tax information and is being furnished to the Internal Revenue Service. If you are required to file a return, a negligence penalty or other sanction may be imposed on you if this item is required to be reported and the IRS determines that it has not been reported.” •Form W-2G – Copy B “This information is being furnished to the Internal Revenue Service. Report this income on your Federal tax return. If this form shows Federal income tax withheld in box 2, attach this copy to your return.” July 3, 2000722000–27 I.R.B. 4.3.3 Required Form 5498 recipient statements (Copy B)must contain the following legends: Legends for•Form 5498 – “This information is being furnished to the Internal Revenue Service.” Forms 5498Note: If you do not furnish another statement to the participant because no contributions were made for the year, the statement of the fair market value of the account must contain this legend and a designation of which information is being furnished to the Internal Revenue Service. •Form 5498-MSA – “The information in boxes 1 through 6 is being furnished to the Internal Revenue Service.” Section 4.4 - Miscellaneous Instructions for Copies B, C, D, 1, and 2 4.4.1 CopiesCopies B, C,and in some cases, D, 1, and 2are included in the official assembly for the convenience of the filer. You are not legally required to include all these copies with the privately printed substitute forms. Furnishing Copies B and, in some cases, C will satisfy the legal requirement to provide statements of infor- mation to form recipients. Note: If an amount of Federal income tax withheld is shown on Form 1099- R or W-2G, Copy B(to be attached to the tax return) and Copy Cmust be furnished to the recipient. Copy D (Forms 1099-R and W-2G)may be used for filer records. Only Copy Ashould be filed with the IRS. 4.4.2 Copy A (“For Internal Revenue Service Center”) of all forms must be on top. The rest of the assembly Arrangement must be arranged, from top to bottom, as follows. For: of Assembly•Form 1098—Copy B “For Payer”; Copy C “For Recipient.” •Form 1098-E—Copy B “For Borrower”; Copy C “For Recipient.” •Form 1098-T—Copy B “For Student”; Copy C “For Filer.” •Form 1099-A—Copy B “For Borrower”; Copy C “For Lender.” •Forms 1099-B, 1099-DIV, 1099-G, 1099-INT, 1099-MSA, 1099-OID, and 1099-PATR—Copy B “For Recipient”; Copy C “For Payer.” •Form 1099-C—Copy B “For Debtor”; Copy C “For Creditor.” •Form 1099-LTC—Copy B “For Policyholder”; Copy C “For Insured”; and Copy D “For Payer.” •Form 1099-MISC—Copy 1 “For State Tax Department”; Copy B “For Recipient”; Copy 2 “To be filed with recipient’s state income tax return, when required”; and Copy C “For Payer.” •Form 1099-R—Copy 1 “For State, City, or Local Tax Department”; Copy B “Report this income on your Federal tax return. If this form shows Federal income tax withheld in box 4, attach this copy to your return”; Copy C “For Recipient’s Records”; Copy 2 “File this copy with your state, city, or local income tax return, when required”; Copy D “For Payer.” •Form 1099-S—Copy B “For Transferor”; Copy C “For Filer.” •Form 5498—Copy B “For Participant”; Copy C “For Trustee or Issuer.” •Form 5498-MSA—Copy B “For Participant”; Copy C “For Trustee.” •Form W-2G—Copy 1 “For State Tax Department”; Copy B “Report this income on your Federal tax return. If this form shows Federal income tax withheld in box 2, attach this copy to your return”; Copy C “For Winner’s Records”; Copy 2 “Attach this copy to your state income tax return, if required.”; Copy D “For Payer.” 4.4.3 Perforations are required between forms on all copies except Copy A to make separating the forms easier. Perforations(Copy A of Form W-2G may be perforated.) 2000–27 I.R.B.73July 3, 2000 Part 5 Additional Instructions for Substitute Forms 1098, 1099, 5498, and W-2G Section 5.1 - OMB Requirements 5.1.1 OMB The Paperwork Reduction Act of 1995 (Public Law 104-13) requires that: Requirements•The OMB approves all IRS tax forms that are subject to the Paperwork Reduction Act. •Each form shows the OMB approval number in or near the upper right corner. (The official OMB numbers may be found on the official IRS printed forms and are also shown on the forms in the exhibits in Part 6.) •The form (or its instructions) states: 1.Why the IRS needs the information, 2.How it will be used, and 3.Whether or not the information is required to be furnished to the IRS. Any users of official or substitute IRS forms or instructions must be provided with this information. 5.1.2 Substitute The OMB requirements for substitute IRS forms are: Form •Any substitute form or substitute statement to a recipient must show the OMB number as it appears on Requirementsthe official IRS form. •For Copy A, the OMB number must appear exactly as shown on the official IRS form. •For any copy other than Copy A, the OMB number must use one of the following formats. 1.OMB No. XXXX-XXXX (preferred) or 2.OMB # XXXX-XXXX 5.1.3 Required All substitute forms (Copy A only)must state “For Privacy Act and Paperwork Reduction Act Notice, see the Explanation 2000 General Instructions for Forms 1099, 1098, 5498, and W-2G.” to Users If no instructions are provided to users of your forms, you must furnish them the exact text of the Privacy Act and Paperwork Reduction Act Notice. Section 5.2 - Reproducible Copies 5.2.1 The IRS does not take orders for reproducible and information copies of Federal tax materials. However, Introductionother ways to get Federal tax material include: •The Internet. •CD-ROM. •GPO Superintendent of Documents Bookstores. Forms 1096, 1098, 1099 series, and 5498 series are provided electronically on the IRS home page and on the Federal Tax Forms CD-ROM, but cannot be used for filing with the IRS when printed from a conventional printer. These forms contain drop-out ink requirements as described in Part 2 of this publication. 5.2.2 InternetYou can download tax materials from the Internet. 5.2.3 IRSThe IRS also offers an alternative to downloading electronic files and provides current and prior-year access Federal Tax to tax forms and instructions through its Federal Tax Forms CD-ROM. The CD will be available for the Formsupcoming filing season. Order Pub. 1796, Federal Tax Products on CD-ROM, by using the IRS’s Internet CD-ROMWeb Site at www.irs.gov/cdorders. July 3, 2000742000–27 I.R.B. You Can Access the Internet by...Using... File Transfer Protocol (FTP)ftp.irs.gov World Wide Webwww.irs.gov 5.2.4 GPO The Government Printing Office (GPO) Superintendent of Documents Bookstores also sell individual copies Supt. of of tax forms, instructions, and publications. Documents Bookstores Section 5.3 - Effect on Other Revenue Procedures 5.3.1 OtherRevenue Procedure 99–34, 1999–40 I.R.B. 450,which provides rules and specifications for private printing of Revenue 1999 substitute forms and statements to recipients, is superseded. Procedures 2000–27 I.R.B.75July 3, 2000 Part 6 Exhibits Section 6.1 - Exhibits of Forms in the Revenue Procedure 6.1.1 Purpose Exhibits A through T illustrate some of the specifications that were discussed earlier in this revenue proce- dure. The dimensions apply to the actual size forms, but the exhibits have been reduced in size. Generally, the illustrated dimensions apply to all like forms. For example, Exhibit B shows 11.00” from the top edge to the bottom edge of Form 1098 and .85” between the bottom rule of the top form and the top rule of the second form on the page. These dimensions apply to all forms that are printed three to a page. 6.1.2 Keep in mind the following guidelines when printing substitute forms. Guidelines•Closely follow the specifications to avoid delays in processing the forms. •Always use the specifications as outlined in this revenue procedure and illustrated in the exhibits. •Do not add the text line “Do NOT Cut or Separate Forms on This Page” to the bottom form. This will cause inconsistency with the specifications. July 3, 2000762000–27 I.R.B. 2000–27 I.R.B.77July 3, 2000 July 3, 2000782000–27 I.R.B. 2000–27 I.R.B.79July 3, 2000 July 3, 2000802000–27 I.R.B. 2000–27 I.R.B.81July 3, 2000 July 3, 2000822000–27 I.R.B. 2000–27 I.R.B.83July 3, 2000 July 3, 2000842000–27 I.R.B. 2000–27 I.R.B.85July 3, 2000 July 3, 2000862000–27 I.R.B. 2000–27 I.R.B.87July 3, 2000 July 3, 2000882000–27 I.R.B. 2000–27 I.R.B.89July 3, 2000 July 3, 2000902000–27 I.R.B. 2000–27 I.R.B.91July 3, 2000 July 3, 2000922000–27 I.R.B. 2000–27 I.R.B.93July 3, 2000 July 3, 2000942000–27 I.R.B. 2000–27 I.R.B.95July 3, 2000 July 3, 2000962000–27 I.R.B. 2000–27 I.R.B.97July 3, 2000 Taxable Fuel Measurement Notice 2000–33 Section 48.4081–8(a) of the Manufac- turers and Retailers Excise Tax Regula- tions provides that volumes of taxable fuel may be measured on the basis of ei- ther actual volumetric gallons or gallons adjusted to 60 degrees Fahrenheit. Sec- tion 48.4081–8(a) also provides, however, that beginning July 1, 2000, for each pe- riod from July 1 through the following June 30, a person liable for tax on a re- moval may use only one of the two bases of measurement with respect to taxable fuel removed from any particular termi- nal, refinery, or blending facility. This rule also applies to taxable entries and sales. The Internal Revenue Service and the Treasury Department have determined that many taxpayers will have to change their accounting systems to comply with the rule applicable beginning July 1, 2000, and will be unable to complete the necessary changes by that date. Accord- ingly, taxpayers will not be required to comply with the rule before July 1, 2001. In the meantime, a taxpayer may use ei- ther basis of measurement for each tax- able removal, entry, or sale of taxable fuel. The principal author of this notice is Frank Boland of the Office of Assistant Chief Counsel (Passthroughs and Special Industries). For further information re- garding this notice, contact Mr. Boland at (202) 622-3130 (not a toll-free call). July 3, 2000982000–27 I.R.B. Notice of Proposed Rulemaking and Notice of Public Hearing Information Reporting for Payments of Qualified Tuition and Payments of Interest on Qualified Education Loans; Magnetic Media Filing Requirements for Information Returns REG–105316–98 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Notice of proposed rulemak- ing and requests to videoconference the public hearing. SUMMARY: This document contains pro- posed regulations relating to the informa- tion reporting requirements under section 6050S of the Internal Revenue Code for payments of qualified tuition and related expenses and interest on qualified educa- tion loans, including the filing of informa- tion returns on magnetic media. The regu- lations reflect changes to the law made by the Taxpayer Relief Act of 1997. The regu- lations provide guidance to eligible educa- tional institutions and insurers receiving payments of, or making reimbursements or refunds of, qualified tuition and related ex- penses. The regulations also provide guid- ance to payees receiving interest payments on qualified education loans. This docu- ment also announces that a public hearing will be held on the proposed regulations upon request and that persons outside the Washington, DC, area who wish to testify at the hearing may request that the IRS videoconference the hearing to their sites. DATES: Written or electronically gener- ated comments must be received by Sep- tember 14, 2000. Requests to videoconfer- ence the hearing to other sites must be received by August 15, 2000. AD- DRESSES: Send submissions to: CC:DOM:CORP:R (REG–105316–98), 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 (REG–105316–98), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue, NW., Washing- ton, DC. Taxpayers may also submit com- ments electronically via the internet by se- lecting the “Tax Regs” option on the IRS Home Page, or by submitting comments di- rectly to the IRS internet site at http://www.irs.ustreas.gov/prod/tax_regs/re gslist.html. The IRS will publish the time and date of the public hearing and the loca- tions of any videoconferencing sites in the Federal Register. FOR FURTHER INFORMATION CON- TACT: Concerning the regulations, Donna Welch, (202) 622-4910; concerning sub- missions of comments, the hearing, and/or to be placed on the building access list to attend the hearing, Guy Traynor, (202) 622- 7180; concerning the magnetic media filing specifications, waivers for filing on mag- netic media, and extensions of time, contact the Internal Revenue Service, Martinsburg Computing Center, (304) 263-8700 (not toll-free numbers). SUPPLEMENTARY INFORMATION: Paperwork Reduction Act The collection of information con- tained in this notice of proposed rulemak- ing has been submitted to the Office of Management and Budget for review in ac- cordance with the Paperwork Reduction Act of 1995 (44 U.S.C. 3507(d)). Com- ments on the collection of information should be sent to the Office of Manage- ment and Budget, Attn: Desk Officer for the Department of the Treasury, Office of Information and Regulatory Affairs, Washington, DC 20503, with copies to the Internal Revenue Service, Attn: IRS Reports Clearance Officer, OP:FS:FP, Washington, DC 20224. Comments on the collection of information should be re- ceived by August 15, 2000. Comments are specifically requested concerning: Whether the proposed collection of in- formation is necessary for the proper per- formance of the functions of the IRS, in- cluding whether the information will have practical utility; The accuracy of the estimated burden associated with the proposed collection of information (see below); How the quality, utility, and clarity of the information to be collected may be en- hanced; How the burden of complying with the proposed collection of information may be minimized, including through the ap- plication of automated collection tech- niques or other forms of information tech- nology; and Estimates of capital or start-up costs and costs of operation, maintenance, and purchase of services to provide informa- tion. The collection of information in this pro- posed regulation is in §§1.6050S–1 and 1.6050S–2. In general, eligible educational institutions and insurers must file a Form 1098-T, “Tuition Payments Statement,” with the IRS for each individual with re- spect to whom payments of qualified tu- ition and related expenses were received, or reimbursements or refunds of such ex- penses were made, and furnish an informa- tion statement to such individual. This col- lection of information is required in order to assist the IRS and taxpayers in calculat- ing the amount of any education tax credit allowable under section 25A. In addition, payees who receive from any payor interest payments aggregating $600 or more on one or more qualified education loans must file a Form 1098-E, “Student Loan Interest Statement,” with the IRS and furnish an in- formation statement to the payor. This col- lection of information is required in order to assist the IRS and taxpayers in calculat- ing the amount of any student loan interest deduction allowable under section 221. The likely respondents are businesses or other for-profit institutions and nonprofit institutions. Estimated total annual reporting burden for 1998 for Form 1098-T: 2,419,438 hours. Estimated average annual burden hours per response for Form 1098-T: 7 minutes. Estimated number of responses for 1998 for Form 1098-T: 20,738,039. Estimated annual frequency of responses: Once. Estimated total annual reporting burden for 1998 for Form 1098-E: 437,691 hours. Estimated average annual burden hours per response for Form 1098-E: 3 minutes. Estimated number of responses for 1998 for Form 1098-E: 8,753,819. Part IV. Items of General Interest 2000–27 I.R.B.99July 3, 2000 Estimated annual frequency of responses: Once. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it dis- plays a valid control number assigned by the Office of Management and Budget. Books or records relating to a collec- tion of information must be retained as long as their contents may become mater- ial in the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by 26 U.S.C. 6103. Background 1. Information Reporting Requirements This document contains proposed amendments to the Income Tax Regula- tions (26 CFR part 1) relating to informa- tion reporting requirements under section 6050S. The Taxpayer Relief Act of 1997 (Public Law 105-34 (111 Stat. 788) (TRA ‘97)) added section 25A of the Internal Revenue Code to provide the Hope Schol- arship Credit and the Lifetime Learning Credit (education tax credits). In general, the Hope Scholarship Credit and the Life- time Learning Credit allow certain tax- payers who pay qualified tuition and re- lated expenses to an eligible educational institution to claim a nonrefundable credit against their Federal income tax liability. On January 6, 1999, the IRS issued pro- posed regulations under section 25A. See 64 F.R. 794 (1999). TRA ‘97 also added section 221 of the Internal Revenue Code to allow certain taxpayers who pay interest on qualified education loans to claim a Federal income tax deduction for their interest payments. In general, a deduction is allowed for in- terest payments made during the first 60 months in which interest payments are re- quired on a qualified education loan. However, no interest deduction is allowed for any interest paid before January 1, 1998. On January 21, 1999, the IRS is- sued proposed regulations under section 221. See 64 F.R. 3257 (1999). In addition, TRA ‘97 added section 6050S of the Internal Revenue Code, which requires eligible educational insti- tutions to file information returns and to furnish written information statements to assist taxpayers and the IRS in determin- ing any education tax credit allowable under section 25A. Similarly, section 6050S requires any person engaged in a trade or business of making payments to any individual under an insurance agree- ment as reimbursements or refunds of qualified tuition and related expenses to file information returns and to furnish written information statements. Lastly, section 6050S requires certain payees who receive payments of interest on one or more qualified education loans to file information returns and to furnish written information statements to assist taxpayers and the IRS in determining any interest deduction allowable under section 221. The IRS has published several notices prescribing limited information reporting for eligible educational institutions for the years 1998, 1999, and 2000. On Decem- ber 22, 1997, the IRS published Notice 97–73 (1997–2 C.B. 335), which de- scribes the information that an eligible ed- ucational institution must report for 1998. On September 8, 1998, the IRS published Notice 98–46 (1998–36 I.R.B. 21), which extends the application of Notice 97–73 to information returns required under sec- tion 6050S for 1999. On December 7, 1998, the IRS published Notice 98–59 (1998–49 I.R.B. 16), which modifies the prior Notices by providing that an institu- tion is not required to file information re- turns for students who are: (1) enrolled during the year only in courses for which the student receives no academic credit; or (2) nonresident alien students, unless the student requests the institution to re- port. On July 26, 1999, the IRS published Notice 99–37 (1999–30 I.R.B. 124), which extends the application of Notice 97–73 (as modified) to information re- turns required under section 6050S for 2000. In addition, the IRS has published sev- eral notices describing the information re- porting for certain payees who receive in- terest on qualified education loans during the years 1998, 1999, and 2000. On Janu- ary 20, 1998, the IRS published Notice 98–7 (1998–1 C.B. 339), which describes the information reporting required under section 6050S for 1998. On November 16, 1998, the IRS published Notice 98–54 (1998–2 C.B. 641), which modifies No- tice 98–7 to reflect a technical change to section 221 made by the Internal Revenue Service Restructuring and Reform Act of 1998 (Public Law 105-206 (112 Stat. 685)), and extends the application of No- tice 98–7 (as modified) to information re- porting required under section 6050S for 1999. On July 26, 1999, the IRS pub- lished Notice 99–37, which extends the application of Notice 98–7 (as modified) to information returns required under sec- tion 6050S for 2000. 2. Magnetic Media Requirements This document also contains proposed amendments to the Regulations on Proce- dure and Administration (26 part 301) re- lating to the filing of information returns on magnetic media under section 6011(e). Section 6011(e) authorizes the Secretary to prescribe regulations providing the standards for determining which returns must be filed on magnetic media. Section 6011(e)(2)(A) provides that the Secretary shall not require any person to file returns on magnetic media unless the person is required to file at least 250 returns during the calendar year. Section 6011(e)(2)(B) provides that, in prescribing regulations, the Secretary shall consider the ability of the taxpayer to comply at reasonable cost with the requirements of the regulations. Explanation of Provisions 1. Information Reporting for Payments and Reimbursements or Refunds of Quali- fied Tuition and Related Expenses The proposed regulations require an el- igible educational institution (as defined in section 25A(f)(2) and the regulations thereunder) (an institution) that receives payments of qualified tuition and related expenses (as defined in section 25A(f)(1) and the regulations thereunder) with re- spect to any individual, or makes reim- bursements or refunds of such amounts, to file a Form 1098-T with the IRS. In addition, the proposed regulations require any person engaged in a trade or business of making payments under an insurance arrangement as reimbursements or re- funds (or other similar amounts) of quali- fied tuition and related expenses (an in- surer) to file a Form 1098-T with the IRS. Under the proposed regulations, the following information must be reported on Form 1098-T: (a) the name, address, and taxpayer identification number (TIN)(as defined in section 7701(a)(41)) of the institution or the insurer; (b) the name, address, and TIN of the individual July 3, 20001002000–27 I.R.B. with respect to whom payments of quali- fied tuition and related expenses were re- ceived, or reimbursements or refunds were made; (c) the aggregate amount of payments of qualified tuition and related expenses from any source that the institu- tion received with respect to the individ- ual during the calendar year; (d) the ag- gregate amount of reimbursements or refunds of qualified tuition and related ex- penses that the institution or insurer made with respect to the individual during the calendar year; (e) the aggregate amount of any scholarships or grants that the institu- tion processed during the calendar year for the payment of the individual’s costs of attendance; (f) an indication by the in- stitution whether the individual was en- rolled for at least half of the normal full- time work load for the course of study the individual is pursuing for at least one aca- demic period that begins during the calen- dar year; (g) an indication by the institu- tion whether the individual was enrolled in a program leading to a graduate-level degree, graduate-level certificate, or other recognized graduate-level educational credential; and (h) any other information required by Form 1098-T and its instruc- tions. The proposed regulations reserve the requirement in section 6050S(b)(2)(B) that an institution or insurer obtain and re- port the name, address, and TIN of any taxpayer who will claim the individual with respect to whom payments are re- ceived, or reimbursements or refunds are made, as a dependent for purposes of the deduction allowable under section 151 for the taxable year. Thus, under the pro- posed regulations, there is no requirement to obtain and report the name, address, and TIN of any taxpayer who will claim the individual as a dependent on the tax- payer’s Federal income tax return. Consistent with the exceptions to re- quired reporting in Notice 98–59, the pro- posed regulations provide that an institu- tion or insurer is not required to file a Form 1098-T for an individual who is a nonresident alien, unless the individual requests that the institution or insurer re- port. In addition, an institution is not re- quired to file a Form 1098-T for an indi- vidual who is enrolled during the calendar year only in courses for which the indi- vidual receives no academic credit. Under the proposed regulations, the term academic creditmeans credit awarded by an institution for the completion of coursework leading toward a post-sec- ondary degree, certificate, or other recog- nized post-secondary educational creden- tial. The proposed regulations provide that, in determining the payments for qualified tuition and related expenses that an insti- tution must report, payments received with respect to an individual from any source (except for any scholarship or grant that, by its terms, must be applied to expenses other than qualified tuition and related expenses, such as room and board) are treated as payments of qualified tu- ition and related expenses up to the total amount billed for such expenses. The proposed regulations provide that an institution or insurer must furnish an information statement to each individual for whom it is required to file a Form 1098-T. The proposed regulations pro- vide that the statement must include the information included on the Form 1098-T filed with the IRS and a legend that iden- tifies the statement as important tax infor- mation being furnished to the IRS. The statement must include instructions that state that the taxpayer may not be able to claim an education tax credit under sec- tion 25A and the regulations thereunder with respect to the total payments of qual- ified tuition and related expenses reported for the calendar year. The instructions must state that the amount of the scholar- ships, grants, reimbursements, or refunds reported for the calendar year and other similar amounts not reported (because they are not processed by the institution) may reduce the amount of any allowable education tax credit for the taxable year or a prior taxable year. The instructions must state that the taxpayer should refer to relevant IRS forms and publications (such as Form 8863, “Education Credits,” and Publication 970, “Tax Benefits for Higher Education”) for explanations re- lating to the eligibility requirements for, and the calculation of, any allowable edu- cation tax credit. The proposed regulations reserve the requirement in section 6050S(d) that an institution or insurer furnish a statement to any taxpayer who will claim the indi- vidual with respect to whom payments are received, or reimbursements or refunds are made, as a dependent for purposes of the deduction allowable under section 151 for the taxable year. Thus, under the pro- posed regulations, there is no requirement to furnish a statement to any taxpayer who will claim the individual as a depen- dent on the taxpayer’s Federal income tax return. The proposed regulations describe the rules for the time and manner of filing in- formation returns with the IRS and fur- nishing information statements. Forms 1098-T must generally be filed with the IRS on or before February 28 (March 31 if filed electronically) of the year follow- ing the calendar year in which the pay- ments were received, or reimbursements or refunds were made. In general, an in- stitution or insurer must furnish an infor- mation statement to each individual with respect to whom payments of qualified tu- ition and related expenses were received, or reimbursements or refunds were made, on or before January 31 of the year fol- lowing the calendar year in which pay- ments were received, or reimbursements or refunds were made. Although the reg- ulations do not specifically address the issue of electronic transmission of infor- mation statements, the IRS is currently studying the issue. Accordingly, the IRS may address that issue in future guidance. Under the proposed regulations, an in- stitution or insurer may be subject to a penalty under section 6721 for failure to file correct Forms 1098-T and a penalty under section 6722 for failure to furnish correct information statements. The pro- posed regulations generally follow the rules under section 6724 for waivers of penalties for certain failures due to rea- sonable cause. The regulations also pro- vide special rules for soliciting an individ- ual’s TIN. An institution or insurer that complies with those rules will not be pe- nalized for any failure to obtain or include a correct TIN on a Form 1098-T or the re- lated information statement. 2. Information Reporting for Payments of Interest on Qualified Education Loans The proposed regulations require any person engaged in a trade or business that receives from any payor interest of $600 or more for any calendar year on one or more qualified education loans (as de- fined in section 221(e)(1) and the regula- tions thereunder) (a payee) to file a Form 1098-E with the IRS. Under the proposed 2000–27 I.R.B.101July 3, 2000 regulations, a payee must report the name, address, and taxpayer identification num- ber (TIN) of the payee; the name, address, and TIN of the payor; and the aggregate amount of interest received during the calendar year from the payor. The payee may be the lender, the holder of the loan, or the loan servicer. The regulations de- fine the payoras the individual carried on the books and records of the payee as the borrower on a qualified education loan. If there are multiple borrowers, the principal borrower indicated on the payee’s books and records is treated as the payor for pur- poses of section 6050S. Under the proposed regulations, a payee is required to report only interest payments received on a qualified educa- tion loan during the first 60 months in which interest payments are required on the loan. The proposed regulations, in general, incorporate the rules of section 221 and the regulations thereunder to de- termine the 60-month period for which in- terest payments must be reported. Under the proposed regulations, the 60-month period generally begins on the date the qualified education loan first enters re- payment status. However, for qualified education loans made before January 1, 1998, if the payee does not know, and does not have reason to know, the date on which the loan entered repayment status, then, for information reporting purposes, the 60-month period begins on January 1, 1998. For defaulted loans made before January 1, 1998, if the payee does not know, and does not have reason to know, the date on which the loan entered repay- ment status, then, for information report- ing purposes, the 60-month period begins on the earlier of the date the loan went into default or January 1, 1998. If the payee does not know, and does not have reason to know, either the date the loan entered repayment status or the default date, then, for information reporting pur- poses, the 60-month period begins on Jan- uary 1, 1998. The proposed regulations provide that, in determining the aggregate amount of interest payments to be reported by a payee, the term interestincludes stated in- terest, loan origination fees (other than any fees for services), and capitalized in- terest as described in proposed regula- tions §1.221–1(h)(2). However, in order to provide payees sufficient time to de- velop systems to report amounts other than stated interest, the proposed regula- tions do not require payees to report loan origination fees and capitalized interest for loans made before January 1, 2002. The proposed regulations provide rules to determine which loans are qualified ed- ucation loans subject to information re- porting under section 6050S. The regula- tions provide that, unless the loan is subsidized, guaranteed, financed, or oth- erwise treated as a student loan under a program of the Federal, state, or local government or an eligible educational in- stitution, the payee must request and ob- tain a certification from the payor that the loan will be used solely to pay qualified higher education expenses. The regula- tions provide that the payee may use Form W-9S, “Request for Student’s So- cial Security Number and Borrower Certi- fication,” to request and obtain the certifi- cation. If a payee fails to obtain a required certification, the loan is not treated as a qualified education loan for purposes of section 6050S. The proposed regulations provide that a payee must furnish an information state- ment to each payor for whom it is re- quired to file a Form 1098-E. The pro- posed regulations provide that the statement must include the information included on the Form 1098-E filed with the IRS and a legend that identifies the statement as important tax information being furnished to the IRS. The statement must include instructions that state that, under section 221 and the regulations thereunder, the payor may not be able to deduct the full amount of interest reported on the statement. The instructions must state that interest payments are deductible only during the first 60-months that inter- est payments are required. If the payee reports only stated interest, the instruc- tions must state that the payor may be able to deduct additional amounts (e.g., certain loan origination fees and capital- ized interest) not reported on the state- ment. The instructions must also state that the payor should refer to relevant IRS forms and publications (such as Publica- tion 970) for explanations relating to the eligibility requirements for, and the calcu- lation of, any allowable interest deduction on qualified education loans. The proposed regulations describe the rules for the time and manner of filing in- formation returns with the IRS and fur- nishing information statements to payors. Forms 1098-E must generally be filed with the IRS on or before February 28 (March 31 if filed electronically) of the year following the calendar year in which the interest payments were received. In general, a payee must furnish an informa- tion statement to the payor on or before January 31 of the year following the cal- endar year in which interest payments were received. Although the regulations do not specifically address the issue of electronic transmission of information statements, the IRS is currently studying the issue. Accordingly, the IRS may ad- dress that issue in future guidance. Under the proposed regulations, a payee may be subject to a penalty under section 6721 for failure to file correct Forms 1098-E and a penalty under section 6722 for a failure to furnish correct infor- mation statements. The proposed regula- tions generally follow the rules under sec- tion 6724 for waivers of penalties for certain failures due to reasonable cause. The regulations also provide special rules for soliciting the payor’s TIN. A payee that complies with those rules will not be penalized for any failure to obtain or in- clude a correct TIN on a Form 1098-E or the related information statement. 3. Requirement to File Information Returns on Magnetic Media The proposed regulations amend the regulations under section 6011(e) to re- quire eligible educational institutions, in- surers, and payees who are required to file 250 or more Forms 1098-T or 1098-E to file on magnetic media. Under §301.6011–2(a)(1), the term magnetic mediameans any media permitted under applicable regulations, revenue proce- dures, or publications, including magnetic tape, tape cartridge, and diskette, as well as other media (such as electronic filing). Proposed Effective Date These regulations are proposed to apply to information returns required to be filed, and information statements re- quired to be furnished, after December 31, 2001. Taxpayers may rely on these proposed regulations for guidance pend- ing the issuance of final regulations. If, and to the extent, future guidance is more restrictive than the guidance in the pro- July 3, 20001022000–27 I.R.B. posed regulations, the future guidance will be applied without retroactive effect. Special Analyses It has been determined that these pro- posed regulations are not a significant regulatory action as defined in Executive Order 12866. Therefore, a regulatory as- sessment is not required. It has also been determined that section 553(b) of the Ad- ministrative Procedure Act (5 U.S.C. chapter 5) does not apply to these regula- tions. An initial regulatory flexibility analysis has been prepared for this notice of proposed rulemaking under 5 U.S.C. 603 and is set forth under the heading “Initial Regulatory Flexibility Analysis” in this preamble. Pursuant to section 7805(f), this notice of proposed rulemak- ing will be submitted to the Chief Counsel for Advocacy of the Small Business Ad- ministration for comment on its impact on small business. Initial Regulatory Flexibility Analysis The collection of information con- tained in §§1.6050S–1(a) and (b) and 1.6050S–2(a) and (c) is needed to assist the IRS and taxpayers in determining the amount of any education credit allowable under section 25A and the amount of any interest deduction allowable under section 221. The objectives of the proposed regu- lations are to provide uniform, practica- ble, and administrable rules under section 6050S. The types of small entities to which the proposed regulations may apply are small eligible educational insti- tutions (such as colleges and universities), certain insurers who reimburse educa- tional expenses, and certain payees who receive payments of interest on qualified education loans. As of the end of Decem- ber 1999, a total of 20,738,039 Forms 1098-T were filed with the IRS for 1998 and a total of 8,753,819 Forms 1098-E were filed with the IRS for 1998. The current estimated reporting burden is 7 minutes per Form 1098-T and 3 minutes per Form 1098-E. No special profes- sional skills are necessary for preparation of the reports or records. There are no known Federal rules that duplicate, over- lap, or conflict with these proposed regu- lations. The regulations proposed are considered to have the least economic im- pact on small entities of all alternatives considered. Moreover, the proposed regulations re- quiring filing Forms 1098-T and 1098-E on magnetic media impose no additional reporting or recordkeeping and only pre- scribe the method of filing information re- turns that are already required to be filed. Further, these regulations are consistent with the statutory requirement that an eli- gible educational institution, insurer, or payee is not required to file Forms 1098-T or 1098-E on magnetic media unless re- quired to file at least 250 or more returns during the year. Finally, the economic im- pact caused by requiring Forms 1098-T and 1098-E on magnetic media should be minimal because most institution’s, in- surer’s, and payee’s operations are com- puterized. Even if their operations are not computerized, the incremental cost of magnetic media reporting should be mini- mal in most cases because of the availabil- ity of computer service bureaus. In addi- tion, the existing regulations under section 6011(e) provide that the IRS may waive the magnetic media filing requirements on a showing of hardship. The waiver au- thority will be exercised so as not to un- duly burden institutions, insurers, and pay- ees lacking both the necessary data processing facilities and access at a rea- sonable cost to computer service bureaus. Comments and Public Hearing Before these proposed regulations are adopted as final regulations, considera- tion will be given to any written and elec- tronic comments that are submitted timely to the IRS. The IRS and Treasury specifi- cally request comments on the clarity of the proposed regulations and how they can be made easier to understand. All comments will be available for public in- spection and copying. A public hearing will be scheduled in the Internal Revenue Building, 1111 Con- stitution Avenue, NW., Washington, DC. The IRS recognizes that persons outside the Washington, DC, area may also wish to testify at the public hearing through videoconferencing. Requests to include videoconferencing sites must be received by August 15, 2000. If the IRS receives sufficient indications of interest to war- rant videoconferencing to a particular city, and if the IRS has videoconferencing facilities available in that city on the date the public hearing is to be scheduled, the IRS will try to accommodate the requests. The IRS will publish the time and date of the public hearing and the locations of any videoconferencing sites in a docu- ment in the Federal Register. Drafting Information The principal author of the regulations is Donna Welch, Office of Assistant Chief Counsel (Income Tax and Accounting). However, other personnel from the IRS and the Treasury Department participated in the development of the regulations. * * * * * Proposed Amendments to the Regulations Accordingly, 26 CFR parts 1 and 301 are proposed to be amended as follows: PART 1—INCOME TAXES Paragraph 1. The authority citation for part 1 is amended by adding entries in nu- merical order to read in part as follows: Authority: 26 U.S.C. 7805 * * * Section 1.6050S–1 also issued under sec- tion 26 U.S.C. 6050S(g). Section 1.6050S–2 also issued under sec- tion 26 U.S.C. 6050S(g). * * * Par. 2. Sections 1.6050S–0 through 1.6050S–2 are added to read as follows: §1.6050S–0 Table of contents This section lists captions contained in §§1.6050S–1 and 1.6050S–2. §1.6050S–1 Information reporting for payments and reimbursements or refunds of qualified tuition and related expenses. (a) Information reporting requirement. (1) In general. (2) Exceptions. (i) No reporting for nonresident alien in- dividuals. (ii) No reporting for individuals enrolled in noncredit courses. (A) In general. (B) Academic credit defined. (C) Example. (b) Requirement to file return. (1) Form of return. (2) Information included on return. (i) In general. (ii) Requirement to include name, ad- dress, and TIN of any taxpayer who will claim the individual as a dependent on the taxpayer’s Federal income tax return. [Reserved] (3) Time and place for filing return. 2000–27 I.R.B.103July 3, 2000 (i) In general. (ii) Return for nonresident alien individ- ual. (iii) Extensions of time. (4) Use of magnetic media. (c) Requirement to furnish statement. (1) In general. (2) Statement furnished to any taxpayer who will claim the individual as a depen- dent on the taxpayer’s Federal income tax return. [Reserved] (3) Time and manner for furnishing state- ment. (i) In general. (ii) Statement to nonresident alien indi- vidual. (iii) Extensions of time. (4) Time and manner for furnishing state- ment to any taxpayer who will claim the individual as a dependent on the tax- payer’s Federal income tax return. [Re- served] (5) Copy of Form 1098-T. (d) Special rules. (1) Payments received for qualified tu- ition and related expenses determined. (i) In general. (ii) Example. (2) Payments of qualified tuition and re- lated expenses received or collected on behalf of an institution. (i) In general. (ii) Exception. (3) Governmental units. (e) Penalty provisions. (1) Failure to file correct returns. (2) Failure to furnish correct information statements. (3) Waiver of penalties for failures to in- clude a correct TIN. (i) In general. (ii) Acting in a responsible manner. (iii) Manner of soliciting TIN. (4) Requirement to request and obtain TIN of any taxpayer who will claim the individual as a dependent on the tax- payer’s Federal income tax return. [Re- served] (5) Failure to furnish TIN. (f) Effective date. §1.6050S–2 Information reporting for payments of interest on qualified educa- tion loans. (a) Information reporting requirement. (1) In general. (2) Reporting period. (i) In general. (ii) Calculation of 60-month period. (iii) Transitional rules for reporting on loans made before January 1, 1998. (b) Definitions. (c) Requirement to file return. (1) Form of return. (2) Information included on return. (3) Time and place for filing return. (i) In general. (ii) Extensions of time. (4) Use of magnetic media. (d) Requirement to furnish statement. (1) In general. (2) Time and manner for furnishing state- ment. (i) In general. (ii) Extensions of time. (3) Copy of Form 1098-E. (e) Special rules. (1) Transitional rule for reporting of loan origination fees and capitalized interest. (2) Qualified education loan certification. (3) Payments of interest received or col- lected by one or more persons. (i) In general. (ii) Exception. (4) Reporting by foreign persons. (5) Governmental units. (f) Penalty provisions. (1) Failure to file correct returns. (2) Failure to furnish correct information statements. (3) Waiver of penalties for failures to in- clude a correct TIN. (i) In general. (ii) Acting in a responsible manner. (iii) Manner of soliciting TIN. (4) Failure to furnish TIN. (g) Effective date. §1.6050S–1 Information reporting for payments and reimbursements or refunds of qualified tuition and related expenses. (a) Information reporting requirement— (1) In general. Except as provided in paragraph (a)(2) of this section, any eligi- ble educational institution (as defined in section 25A(f)(2) and §1.25A–2(b))(an in- stitution) that receives payments of quali- fied tuition and related expenses (as de- fined in section 25A(f)(1) and §1.25A–2(d)) from any source for any cal- endar year, or that makes reimbursements or refunds (or similar payments) of such amounts, and any person engaged in a trade or business of making payments under an insurance arrangement as reim- bursements or refunds (or other similar amounts) of qualified tuition and related expenses (an insurer) must— (i) File an information return, as de- scribed in paragraph (b) of this section, with the Internal Revenue Service (IRS) with respect to each individual for whom such payments are received, or reim- bursements or refunds are made; and (ii) Furnish a statement, as described in paragraph (c) of this section,to each indi- vidual described in paragraph (c) of this section. (2) Exceptions—(i) No reporting for non- resident alien individuals. The information reporting requirements of this section do not apply with respect to any individual who is a nonresident alien (as defined in section 7701(b) and §301.7701(b)–3 of this chap- ter) during the calendar year, unless the in- dividual requests the institution or insurer to report. If a nonresident alien individual re- quests an institution or insurer to report, the institution or insurer must comply with the requirements of this section for the year with respect to which the request is made and all years after such request in which it receives payments of qualified tuition and related expenses or makes reimbursements or refunds of such amounts with respect to such individual. (ii) No reporting for individuals en- rolled in noncredit courses—(A) In gen- eral. The information reporting require- ments of this section do not apply with respect to any individual who is enrolled during the calendar year only in courses for which the individual receives no acad- emic credit. (B) Academic credit defined. Acade- mic creditmeans credit awarded by an in- stitution for the completion of coursework leading toward a post-secondary degree, certificate, or other recognized post-sec- ondary educational credential. (C) Example. The following example illustrates the rules of this paragraph (a)(2)(ii): Example. Student A, a medical doctor, takes a course at University X’s medical school. Student A takes the course to fulfill State Y’s licensing require- ment that medical doctors attend continuing medical education courses each year. Student A is not en- rolled in a degree program at University X and takes the medical course through University X’s continu- ing professional education division. University X does not award Student A credit toward a post-sec- ondary degree on an academic transcript for the completion of the course but gives Student A a cer- tificate of attendance upon completion. Under this paragraph (a)(2)(ii), University X is not subject to the information reporting requirements of section 6050S and this section for the medical education course taken by Student A. July 3, 20001042000–27 I.R.B. (b) Requirement to file return—(1) Form of return. Except as otherwise pro- vided in this section, an institution or in- surer must file an information return for each individual with respect to whom payments of qualified tuition and related expenses are received, or reimbursements or refunds of such amounts are made, dur- ing the calendar year on Form 1098-T, “Tuition Payments Statement.” An insti- tution or insurer may use a substitute for Form 1098-T if the substitute form com- plies with applicable revenue procedures relating to substitute forms. (2) Information included on return—(i) In general. An institution or insurer must include on Form 1098-T— (A) The name, address, and taxpayer identification number (TIN)(as defined in section 7701(a)(41)) of the institution or the insurer; (B) The name, address, and TIN of the individual with respect to whom pay- ments of qualified tuition and related ex- penses were received, or reimbursements or refunds of such amounts were made; (C) The aggregate amount of payments of qualified tuition and related expenses from any source that the institution re- ceived with respect to the individual dur- ing the calendar year; (D) The aggregate amount of reim- bursements or refunds of qualified tuition and related expenses that the institution or insurer made with respect to the individ- ual during the calendar year; (E) The aggregate amount of any schol- arships or grants that the institution processed during the calendar year for the payment of the individual’s costs of atten- dance; (F) An indication by the institution whether the individual was enrolled for at least half of the normal full-time work load for the course of study the individual is pursuing for at least one academic pe- riod that begins during the calendar year (see §1.25A–3(d)(1)(ii)); (G) An indication by the institution whether the individual was enrolled in a program leading to a graduate-level de- gree, graduate-level certificate, or other recognized graduate-level educational credential; and (H) Any other information required by Form 1098-T and its instructions. (ii) Requirement to include name, ad- dress, and TIN of any taxpayer who will claim the individual as a dependent on the taxpayer’s Federal income tax return. [Reserved] (3) Time and place for filing return— (i) In general. Except as provided in paragraphs (b)(3)(ii) and (iii) of this sec- tion, Form 1098-T must be filed on or be- fore February 28 (March 31 if filed elec- tronically) of the year following the calendar year in which payments of quali- fied tuition or related expenses were re- ceived, or reimbursements or refunds of such amounts were made. An institution or insurer must file Form 1098-T with the IRS according to the instructions to Form 1098-T. (ii) Return for nonresident alien indi- vidual. In general, an institution or in- surer is not required to file a return on be- half of a nonresident alien individual. However, if a nonresident alien individual requests an institution or insurer to report, the institution or insurer must file a return described in paragraph (b)(2) of this sec- tion with the IRS on or before the date prescribed in paragraph (b)(3)(i) of this section, or on or before the thirtieth day after the request, whichever is later. (iii) Extensions of time. The IRS may grant an institution or insurer an extension of time to file returns required in this sec- tion upon a showing of good cause. See the instructions to Form 1098-T and ap- plicable revenue procedures for rules re- lating to extensions of time to file. (4) Use of magnetic media. See section 6011(e) and §301.6011–2 of this chapter for rules relating to the requirement to file Forms 1098-T on magnetic media. (c) Requirement to furnish statement— (1) In general. An institution or insurer must furnish a statement to each individ- ual for whom it is required to file a Form 1098-T. The statement must include— (i) The information required under paragraph (b)(2) of this section; (ii) A legend that identifies the state- ment as important tax information that is being furnished to the IRS; (iii) Instructions that— (A) State that the taxpayer may not be able to claim an education tax credit under section 25A and the regulations thereunder with respect to the total pay- ments of qualified tuition and related ex- penses reported for the calendar year; (B) State that the amount of any schol- arships, grants, refunds, or reimburse- ments reported for the calendar year and other similar amounts not reported (be- cause they are not processed by the insti- tution) may reduce the amount of any al- lowable education tax credit for the taxable year or a prior taxable year; (C) State that the taxpayer should refer to relevant IRS forms and publications for explanations relating to the eligibility re- quirements for, and calculation of, any al- lowable education tax credit; and (D) Include the name, address, and phone number of the individual who is the information contact for the institution or insurer that filed the Form 1098-T. (2) Statement furnished to any taxpayer who will claim the individual as a depen- dent on the taxpayer’s Federal income tax return. [Reserved] (3) Time and manner for furnishing statement—(i) In general. Except as pro- vided in paragraphs (c)(3)(ii) and (iii) of this section, an institution or insurer must furnish the statement described in para- graph (c)(1) of this section to each indi- vidual with respect to whom payments of qualified tuition and related expenses were received, or reimbursements or re- funds were made, on or before January 31 of the year following the calendar year in which payments were received or reim- bursements or refunds were made. If mailed, the statement must be sent to the individual’s permanent address, or the in- dividual’s temporary address if the insti- tution or insurer does not know the indi- vidual’s permanent address. (ii) Statement to nonresident alien indi- vidual. If an information return is filed for a nonresident alien individual, the in- stitution or insurer must furnish a state- ment described in paragraph (c)(1) of this section to the individual in the manner and on or before the date prescribed in paragraph (c)(3)(i) of this section, or on or before the thirtieth day after the non- resident alien’s request to report, whichever is later. (iii) Extensions of time. The IRS may grant an institution or insurer an extension of time to furnish the statements required in this section upon a showing of good cause. See the instructions to Form 1098- T and applicable revenue procedures for rules relating to extensions of time to fur- nish statements. (4) Time and manner for furnishing statement to any taxpayer who will claim 2000–27 I.R.B.105July 3, 2000 the individual as a dependent on the tax- payer’s Federal income tax return. [Re- served] (5) Copy of Form 1098-T. An institu- tion or insurer may satisfy the require- ment of this paragraph (c) by furnishing either a copy of Form 1098-T and its in- structions or another document that con- tains all of the information filed with the IRS and the information required by para- graph (c)(1) of this section if the docu- ment complies with applicable revenue procedures relating to substitute state- ments. (d) Special rules—(1) Payments re- ceived for qualified tuition and related ex- penses determined—(i) In general. In de- termining the aggregate amount of payments of qualified tuition and related expenses that an institution must report, payments received with respect to an indi- vidual during the calendar year from any source (except for any scholarship or grant that, by its terms, must be applied to expenses other than qualified tuition and related expenses, such as room and board) will be treated as payments of qualified tuition and related expenses up to the total amount billed by the institution for such expenses. (ii) Example. The following example illustrates the rules of this paragraph (d)(1): Example. (i) During the 2002 Spring semester, Student C attends College X and enrolls in a pro- gram leading toward an associate’s degree. Student C lives on-campus. In December 2001, College X charges Student C $2,000 for room and board for the 2002 Spring semester. In addition, in December 2001, College X charges Student C $4,000 for quali- fied tuition and related expenses for the 2002 Spring semester. In December 2001, Student C pays Col- lege X $1,500. In early January 2002, College X re- ceives and processes a $4,500 scholarship that may be applied to any of Student C’s costs of attendance. Assume that there are no other payments during the calendar years 2001 and 2002. (ii) Under this paragraph (d)(1), for the calendar year 2001, College X must report $1,500 for pay- ments of qualified tuition and related expenses re- ceived during the calendar year 2001. In addition, for the calendar year 2002, College X must report: (A) $2,500 for payments of qualified tuition and related expenses received during the calendar year 2002 ($4,000 total charges for qualified tuition and related expenses less the $1,500 payments received during 2001); and (B) $4,500 of scholarships processed during the calendar year 2002. (2) Payments of qualified tuition and related expenses received or collected on behalf of an institution—(i) In general. If an institution contracts with another per- son to receive or collect payments of qualified tuition and related expenses on its behalf, the other person must satisfy the information reporting requirements of this section. (ii) Exception. If the institution does not provide the other person with the in- formation necessary to comply with the reporting requirements of this section, the other person must request the information necessary to comply with the information reporting requirements from the institu- tion. If the institution does not provide the other person with the necessary infor- mation upon request, the institution must satisfy the information reporting require- ments of this section. (3) Governmental units. An institution or insurer that is a governmental unit, or an agency or instrumentality of a govern- mental unit, is subject to the information reporting requirements of this section and an appropriately designated officer or em- ployee of the governmental entity must satisfy the information reporting require- ments of this section. (e) Penalty provisions—(1) Failure to file correct returns. The section 6721 penalty may apply to an institution or in- surer that fails to file information returns required by section 6050S and this section on or before the required filing date; that fails to include all of the required infor- mation on the return; or that includes in- correct information on the return. See section 6721, and the regulations thereun- der, for rules relating to penalties for fail- ure to file correct returns. See section 6724, and the regulations thereunder, for rules relating to waivers of penalties for certain failures due to reasonable cause. (2) Failure to furnish correct informa- tion statements. The section 6722 penalty may apply to an institution or insurer that fails to furnish statements required by section 6050S and this section on or be- fore the prescribed date; that fails to in- clude all the required information on the statement; or that includes incorrect infor- mation on the statement. See section 6722, and the regulations thereunder, for rules relating to penalties for failure to furnish correct statements. See section 6724, and the regulations thereunder, for rules relating to waivers of penalties for certain failures due to reasonable cause. (3) Waiver of penalties for failures to include a correct TIN—(i) In general. In the case of a failure to include a correct TIN on Form 1098-T or a related infor- mation statement, penalties may be waived if the failure is due to reasonable cause. Reasonable cause may be estab- lished if the failure arose from events be- yond the institution’s or insurer’s control, such as a failure of the individual to fur- nish a correct TIN. However, the institu- tion or insurer must establish that it acted in a responsible manner both before and after the failure. (ii) Acting in a responsible manner. An institution or insurer must request the TIN of each individual with respect to whom payments of qualified tuition were re- ceived, or reimbursements or refunds were made, if it does not already have a record of the individual’s correct TIN. If the institution or insurer does not have a record of the individual’s correct TIN, then it must solicit the TIN in the manner described in paragraph (e)(3)(iii) of this section on or before December 31 of each year during which it receives payments of, or makes reimbursements of, qualified tuition and related expenses with respect to the individual. If an individual refuses to provide his or her TIN upon request, the institution or insurer must file the re- turn and furnish the statement required by this section without the individual’s TIN, but with all other required information. The specific solicitation requirements of paragraph (e)(3)(iii) of this section apply in lieu of the solicitation requirements of §301.6724–1(e) and (f) of this chapter for the purpose of determining whether an in- stitution or insurer acted in a responsible manner in attempting to obtain a correct TIN. An institution or insurer that com- plies with the requirements of this para- graph (e)(3) will be considered to have acted in a responsible manner within the meaning of §301.6724–1(d) of this chap- ter with respect to any failure to include the correct TIN of an individual on a re- turn or statement required by section 6050S and this section. (iii) Manner of soliciting TIN. An insti- tution or insurer must request the individ- ual’s TIN in writing and must clearly no- tify the individual that the law requires the individual to furnish a TIN so that it may be included on an information return filed by the institution or insurer. An in- stitution or insurer must notify the indi- vidual that the individual’s failure to fur- July 3, 20001062000–27 I.R.B. nish his or her TIN to the institution or in- surer may result in a $50 penalty being imposed against the individual as autho- rized by law. A request for a TIN made on Form W-9S, “Request for Student’s or Borrower’s Social Security Number and Certification,” satisfies the requirements of this paragraph (e)(3)(iii). An institu- tion or insurer may establish a system for individuals to submit Forms W-9S elec- tronically as described in applicable forms and instructions. An institution or insurer may also develop a separate form to request the individual’s TIN or incor- porate the request into other forms cus- tomarily used by the institution or insurer, such as financial aid applications. (4) Requirement to request and obtain TIN of any taxpayer who will claim the in- dividual as a dependent on the taxpayer’s Federal income tax return. [Reserved] (5) Failure to furnish TIN. The section 6723 penalty may apply to any individual who is required (but fails) to furnish his or her TIN to an institution or insurer. See section 6723, and the regulations thereun- der, for rules relating to the penalty for failure to furnish a TIN. (f) Effective date. The rules in this sec- tion apply to information returns required to be filed, and information statements re- quired to be furnished, after December 31, 2001. §1.6050S–2 Information reporting for payments of interest on qualified educa- tion loans. (a) Information reporting requirement— (1) In general. Except as otherwise pro- vided in this section, any person engaged in a trade or business that, in the course of that trade or business, receives from any payor (as defined in paragraph (b)(2) of this sec- tion) interest payments that aggregate $600 or more for any calendar year on one or more qualified education loans (as defined in section 221(e)(1) and §1.221–1(f)(3))(a payee) must— (i) File an information return, as de- scribed in paragraph (c) of this section, with the IRS with respect to the payor; and (ii) Furnish a statement, as described in paragraph (d) of this section, to the payor. (2) Reporting period—(i) In general. The information reporting requirements of this section apply only to interest pay- ments received on a qualified education loan during the first 60 months in which interest payments are required on the loan. (ii) Calculation of 60-month period. In general, the 60-month period described in paragraph (a)(2)(i) of this section begins on the date the qualified education loan first enters repayment status and ends 60 months later. However, if the payee knows, or has reason to know, of any peri- ods of deferment or forbearance during which the 60-month period is suspended under the rules described in §1.221–1(e)(3), the 60-month period de- scribed in paragraph (a)(2)(i) of this sec- tion is extended by the period of such de- ferment or forbearance. The date on which the qualified education loan first enters repayment status is determined under the terms of the loan agreement or, in the case of a loan issued or guaranteed under a federal post-secondary education loan program, under applicable federal regulations. For purposes of reporting under section 6050S and this section for refinanced loans and consolidated and collapsed loans, the rules of §1.221–1(h)(1), relating to the date on which the 60-month period begins, apply. (iii) Transitional rules for reporting on loans made before January 1, 1998. For qualified education loans made before January 1, 1998, the 60-month period de- scribed in paragraph (a)(2)(i) of this sec- tion is determined in accordance with the rules of paragraph (a)(2)(ii) of this sec- tion, except that if the payee does not know, and does not have reason to know, the date on which the loan entered repay- ment status, then, for reporting purposes only, the 60-month period begins on Janu- ary 1, 1998. For defaulted loans made be- fore January 1, 1998, if the payee does not know, and does not have reason to know, the date on which the loan entered repay- ment status, then, for reporting purposes only, the 60-month period begins on the earlier of the date the loan went into de- fault or January 1, 1998. If the payee does not know, and does not have reason to know, either the date the loan entered repayment status or the default date, then, for reporting purposes only, the 60-month period begins on January 1, 1998. For purposes of this paragraph (a)(2)(iii), a defaulted loan is a loan with respect to which required payments of interest and principal have not been made when due over a period of time such that the holder has declared the loan in default based on its terms and conditions, and, if applica- ble, has sought recourse against the ulti- mate guarantor of the loan. (b) Definitions. The following defini- tions apply for purposes of this section: (1) Interestincludes stated interest, loan origination fees (other than fees for services), and capitalized interest as de- scribed in §1.221–1(h)(2). See paragraph (e)(1) of this section for a special transi- tional rule relating to reporting of loan origination fees and capitalized interest. (2) Payormeans the individual who is carried on the books and records of the payee as the borrower on a qualified edu- cation loan. If there are multiple borrow- ers, the principal borrower on the payee’s books and records is treated as the payor for purposes of section 6050S and this section. (c) Requirement to file return—(1) Form of return. A payee must file an in- formation return for the payor on Form 1098-E, “Student Loan Interest State- ment.” A payee may use a substitute for Form 1098-E if the substitute form com- plies with the applicable revenue proce- dures relating to substitute forms. (2) Information included on return. A payee must include on Form 1098-E— (i) The name, address, and taxpayer identification number (TIN)(as defined in section 7701(a)(41)) of the payee; (ii) The name, address, and TIN of the payor; (iii) The aggregate amount of interest payments received during the calendar year from the payor; and (iv) Any other information required by Form 1098-E and its instructions. (3) Time and place for filing return— (i) In general. Except as provided in paragraph (c)(3)(ii) of this section, the Form 1098-E must be filed on or before February 28 (March 31 if filed electroni- cally) of the year following the calendar year in which interest payments were re- ceived. A payee must file Form 1098-E with the IRS according to the instructions to Form 1098-E. (ii) Extensions of time. The IRS may grant a payee an extension of time to file returns required in this section upon a showing of good cause. See the instruc- tions to Form 1098-E and applicable rev- enue procedures for rules relating to ex- tensions of time to file. 2000–27 I.R.B.107July 3, 2000 (4) Use of magnetic media. See section 6011(e) and §301.6011–2 of this chapter for rules relating to the requirement to file Forms 1098-E on magnetic media. (d) Requirement to furnish statement— (1) In general. A payee must furnish a statement to each payor for whom it is re- quired to file a Form 1098-E. The state- ment must include— (i) The information required under paragraph (c)(2) of this section; (ii) A legend that identifies the state- ment as important tax information that is being furnished to the IRS; (iii) Instructions that— (A) State that, under section 221 and the regulations thereunder, the payor may not be able to deduct the full amount of interest reported on the statement; (B) State that interest payments are de- ductible only during the first 60 months that interest payments are required; (C) In the case of qualified education loans made before January 1, 2002, for which the payee does not report payments of interest other than stated interest, state that the payor may be able to deduct addi- tional amounts (such as certain loan origi- nation fees and capitalized interest) not reported on the statement; (D) State that the payor should refer to relevant IRS forms and publications for explanations relating to the eligibility re- quirements for, and calculation of, any al- lowable deduction for interest paid on a qualified education loan; and (E) Include the name, address, and phone number of the individual who is the information contact for the payee that filed the Form 1098-E. (2) Time and manner for furnishing statement—(i) In general. Except as pro- vided in paragraph (d)(2)(ii) of this sec- tion, a payee must furnish the statement described in paragraph (d)(1) of this sec- tion to the payor on or before January 31 of the year following the calendar year in which payments of interest on a qualified education loan were received. If mailed, the statement must be sent to the payor’s last known address. (ii) Extensions of time. The IRS may grant a payee an extension of time to fur- nish statements required in this section upon a showing of good cause. See the in- structions to Form 1098-E and applicable revenue procedures for rules relating to extensions of time to furnish statements. (3) Copy of Form 1098-E. A payee may satisfy the requirement of this para- graph (d) by furnishing either a copy of Form 1098-E and its instructions or an- other document that contains all the infor- mation filed with the IRS and the infor- mation required by paragraph (d)(1) of this section if the document complies with applicable revenue procedures relating to substitute statements. (e) Special rules—(1) Transitional rule for reporting of loan origination fees and capitalized interest. For qualified educa- tion loans made before January 1, 2002, a payee is not required to report payments of loan origination fees and capitalized in- terest as interest under section 6050S and this section. (2) Qualified education loan certifica- tion. If a loan is not subsidized, guaran- teed, financed, or is not otherwise treated as a student loan under a program of the Federal, state, or local government or an eligible educational institution, a payee must request a certification from the payor that the loan will be used solely to pay for qualified higher education ex- penses. A payee may use Form W-9S, “Request for Student’s or Borrower’s So- cial Security Number and Certification,” to obtain the certification. A payee may establish an electronic system for payors to submit Forms W-9S electronically as described in applicable forms and instruc- tions. A payee may also develop a sepa- rate form to obtain the payor certification or may incorporate certification into other forms customarily used by the payee, such as loan applications, provided the certification is clearly set forth. If the cer- tification is not received, the loan is not a qualified education loan for purposes of section 6050S and this section. (3) Payments of interest received or collected by one or more persons—(i) In general. If a payee contracts with another person to receive or collect payments on a qualified education loan on its behalf, the other person must satisfy the information reporting requirements of this section. (ii) Exception. If the payee does not provide the other person with information necessary to comply with the information reporting requirements of this section, the other person must request the information necessary to comply with the information reporting requirements from the payee. If the payee does not provide the other per- son with the necessary information upon request, the payee must satisfy the infor- mation reporting requirements of this sec- tion. (4) Reporting by foreign persons. A payee that is not a United States person (as defined in section 7701(a)(30)) must report payments of interest it receives on a qualified education loan only if it re- ceives the payment— (i) At a location in the United States; or (ii) At a location outside the United States if the payee is– (A) A controlled foreign corporation (within the meaning of section 957(a)); or (B) A person 50 percent or more of the gross income of which, from all sources for the three-year period ending with the close of the taxable year preceding the taxable year in which interest payments were received (or for such part of the pe- riod as the person was in existence), was effectively connected with the conduct of a trade or business within the United States. (5) Governmental units. A governmen- tal unit, or an agency or instrumentality of a governmental unit, that receives from any payor interest payments that aggre- gate $600 or more for any calendar year on one or more qualified education loans is a payee, without regard to the require- ment of paragraph (a)(1) of this section that the interest be received in the course of a trade or business. (f) Penalty provisions—(1) Failure to file correct returns. The section 6721 penalty may apply to a payee that fails to file information returns required by sec- tion 6050S and this section on or before the required filing date; that fails to in- clude all of the required information on the return; or that includes incorrect infor- mation on the return. See section 6721, and the regulations thereunder, for rules relating to penalties for failure to file cor- rect returns. See section 6724, and the regulations thereunder, for rules relating to waivers of penalties for certain failures due to reasonable cause. (2) Failure to furnish correct informa- tion statements. The section 6722 penalty may apply to a payee that fails to furnish statements required by section 6050S and this section on or before the prescribed date; that fails to include all the required information on the statement; or that in- cludes incorrect information on the state- July 3, 20001082000–27 I.R.B. ment. See section 6722, and the regula- tions thereunder, for rules relating to penalties for failure to furnish correct statements. See section 6724, and the regulations thereunder, for rules relating to waivers of penalties for certain failures due to reasonable cause. (3) Waiver of penalties for failures to include a correct TIN—(i) In general. In the case of a failure to include a correct TIN on Form 1098-E or a related infor- mation statement, penalties may be waived if the failure is due to reasonable cause. Reasonable cause may be estab- lished if the failure arose from events be- yond the payee’s control, such as a failure of the payor to furnish a correct TIN. However, the payee must establish that it acted in a responsible manner both before and after the failure. (ii) Acting in a responsible manner. A payee must request the TIN of each payor if it does not already have a record of the payor’s correct TIN. If the payee does not have a record of the payor’s correct TIN, then it must solicit the TIN in the manner described in paragraph (f)(3)(iii) of this section on or before December 31 of each year during which it receives payments of interest. If a payor refuses to provide his or her TIN upon request, the payee must file the return and furnish the statement required by this section without the payor’s TIN, but with all other required information. The specific solicitation re- quirements of paragraph (f)(3)(iii) of this section apply in lieu of the solicitation re- quirements of §301.6724–1(e) and (f) of this chapter for the purpose of determin- ing whether a payee acted in a responsible manner in attempting to obtain a correct TIN. A payee that complies with the re- quirements of this paragraph (f)(3) will be considered to have acted in a responsible manner within the meaning of §301.6724–1(d) of this chapter with re- spect to any failure to include the correct TIN of a payor on a return or statement required by section 6050S and this sec- tion. (iii) Manner of soliciting TIN. A payee must request the payor’s TIN in writing and must clearly notify the payor that the law requires the payor to furnish a TIN so that it may be included on an information return filed by the payee. A payee must notify the payor that the payor’s failure to furnish his or her TIN to the payee may result in a $50 penalty being imposed against the individual as authorized by law. A request for a TIN made on Form W-9S, “Request for Student’s or Bor- rower’s Social Security Number and Cer- tification,” satisfies the requirements of this paragraph (f)(3)(iii). A payee may es- tablish a system for payors to submit Forms W-9S electronically as described in applicable forms and instructions. A payee may also develop a separate form to request the payor’s TIN or incorporate the request into other forms customarily used by the payee, such as loan applica- tions. (4) Failure to furnish TIN. The section 6723 penalty may apply to any payor who is required (but fails) to furnish his or her TIN to a payee. See section 6723, and the regulations thereunder, for rules relating to the penalty for failure to furnish a TIN. (g) Effective date. The rules in this sec- tion apply to information returns required to be filed, and information statements re- quired to be furnished, after December 31, 2001. PART 301—PROCEDURE AND ADMINISTRATION Par. 3. The authority citation for part 301 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * * Par. 4. Section 301.6011–2 is amended by: 1. Revising the first sentence of para- graph (b)(1). 2. Revising paragraph (g)(1). 3. Adding paragraph (g)(3). The revisions and additions read as fol- lows: §301.6011–2 Required use of magnetic media. * * * * * (b) Returns required on magnetic media. (1) If the use of Form 1042-S, 1098 series, 1099 series, 5498, 8027, W-2G, or other form treated as a form specified in this paragraph (b)(1) is re- quired by the applicable regulations or revenue procedures for the purpose of making an information return, the infor- mation required by the form must be sub- mitted on magnetic media, except as oth- erwise provided in paragraph (c) of this section. * * * * * * * * (g) Effective dates. (1) Except as other- wise provided in paragraph (g)(2) or (g)(3) of this section, this section applies to returns required to be filed after De- cember 31, 1986. * * * * * (3) This section applies to returns on Forms 1098-T and 1098-E required to be filed after December 31, 2001. Robert E. Wenzel, Deputy Commissioner of Internal Revenue. (Filed by the office of the Federal Register on June 15, 2000, 8:45 a.m., and published in the issue of the Federal Register for June 16, 2000, 65 F.R. 37728) 2000–27 I.R.B.iJuly 3, 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 Procedural Rules. Stat.—Statutes at Large. T—Target Corporation. T.C.—Tax Court. T.D.—Treasury Decision. TFE—Transferee. TFR—Transferor. T.I.R.—Technical Information Release. TP—Taxpayer. TR—Trust. TT—Trustee. U.S.C.—United States Code. X—Corporation. Y—Corporation. Z—Corporation. Definition of Terms July 3, 2000ii2000–27 I.R.B. Numerical Finding List 1 Bulletins 2000–1 through 2000–26 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 2000–19, 2000–19 I.R.B. 973 2000–20, 2000–19 I.R.B. 977 2000–21, 2000–19 I.R.B. 983 2000–22, 2000–19 I.R.B. 987 2000–23, 2000–19 I.R.B. 992 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. 878 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 2000–43, 2000–17 I.R.B. 957 2000–44, 2000–17 I.R.B. 958 2000–45, 2000–18 I.R.B. 962 2000–46, 2000–19 I.R.B. 997 2000–47, 2000–21 I.R.B. 1118 2000–48, 2000–23 I.R.B. 1243 2000–49, 2000–19 I.R.B. 998 2000–50, 2000–19 I.R.B. 998 2000–51, 2000–22 I.R.B. 1141 2000–52, 2000–22 I.R.B. 1142 2000–53, 2000–22 I.R.B. 1144 2000–54, 2000–26 I.R.B. 1276 2000–55, 2000–25 I.R.B. 1268 2000–56, 2000–26 I.R.B. 1281 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 Notices—continued: 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 2000–19, 2000–13 I.R.B. 845 2000–20, 2000–14 I.R.B. 851 2000–21, 2000–19 I.R.B. 967 2000–22, 2000–16 I.R.B. 902 2000–23, 2000–17 I.R.B. 952 2000–24, 2000–17 I.R.B. 952 2000–25, 2000–17 I.R.B. 954 2000–26, 2000–17 I.R.B. 954 2000–27, 2000–21 I.R.B. 1116 2000–28, 2000–21 I.R.B. 1116 2000–29, 2000–23 I.R.B. 1241 2000–30, 2000–25 I.R.B. 1266 2000–31, 2000–26 I.R.B. 1274 2000–32, 2000–26 I.R.B. 1274 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–106186–98, 2000–23 I.R.B. 1226 REG–107644–98, 2000–23 I.R.B. 1229 REG–109101–98, 2000–16 I.R.B. 903 REG–110311–98, 2000–11 I.R.B. 767 REG–122450–98, 2000–8 I.R.B. 682 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 Revenue Procedures—continued: 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 2000–14, 2000–18 I.R.B. 960 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 2000–21, 2000–19 I.R.B. 971 2000–22, 2000–20 I.R.B. 1008 2000–23, 2000–21 I.R.B. 1018 2000–24, 2000–22 I.R.B. 1133 2000–25, 2000–21 I.R.B. 1033 2000–26, 2000–24 I.R.B. 1257 2000–27, 2000–26 I.R.B. 1272 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 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 2000–23, 2000–19 I.R.B. 964 2000–24, 2000–19 I.R.B. 963 2000–25, 2000–20 I.R.B. 1006 2000–26, 2000–22 I.R.B. 1124 2000–27, 2000–21 I.R.B. 1016 2000–28, 2000–23 I.R.B. 1157 2000–29, 2000–24 I.R.B. 1249 2000–30, 2000–25 I.R.B. 1262 2000–31, 2000–26 I.R.B. 1269 Tax Conventions: 2000–22 I.R.B. 1126 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 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. 2000–27 I.R.B.iiiJuly 3, 2000 Treasury Decisions—continued: 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 8880, 2000–20 I.R.B.1003 8881, 2000–23 I.R.B.1158 8882, 2000–23 I.R.B.1150 8883, 2000–23 I.R.B.1151 8884, 2000–24 I.R.B.1250 8885, 2000–25 I.R.B.1260 8887, 2000–26 I.R.B.1269 July 3, 2000iv2000–27 I.R.B. Finding List of Current Actions on Previously Published Items 1 Bulletins 2000–1 through 2000–26 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 99–59 Superseded by Announcement 2000–47, 2000–21 I.R.B. 1118 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 97–15 Obsoleted by T.D.8887, 2000–26 I.R.B. 1269 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 98–49 Modified by Notice 2000–30, 2000–25 I.R.B. 1266 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 99–5 Modified by Notice 2000–32, 2000–26 I.R.B. 1274 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 Proposed Regulations—Continued: REG–101492–98 Corrected by Announcement 2000–16, 2000–12 I.R.B. 837 REG–122450–98 Corrected by Announcement 2000–38, 2000–16 I.R.B. 948 REG–113572–99 Corrected by Announcement 2000–41, 2000–16 I.R.B. 949 REG–103736–00 Corrected by Announcement 2000–44, 2000–17 I.R.B. 958 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 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 98–14 Modified by Rev. Proc. 2000–27, 2000–26 I.R.B. 1272 98–22 Modified and superseded by Rev. Proc. 2000–16, 2000–6 I.R.B. 518 Revenue Procedures—Continued: 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 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 99–20 Supplemented by Rev. Proc. 2000–14, 2000–18 I.R.B. 960 99–22 Obsoleted by (except as provided in section 5.02 of) Rev. Proc. 2000–21, 2000–19 I.R.B. 971 99–23 Modified by Rev. Proc. 2000–27, 2000–26 I.R.B. 1272 99–24 Superseded by Rev. Proc. 2000–23, 2000–21 I.R.B. 1018 99–25 Superseded by Rev. Proc. 2000–24, 2000–22 I.R.B. 1133 99–29 Superseded by Rev. Proc. 2000–25, 2000–21 I.R.B. 1033 99–31 Modified and superseded by Rev. Proc. 2000–16, 2000–6 I.R.B. 518 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. 2000–27 I.R.B.vJuly 3, 2000 Revenue Procedures—Continued: 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 2000–12 Corrected by Announcement 2000–50, 2000–19 I.R.B. 998 2000–16 Corrected by Announcement 2000–17, 2000–13 I.R.B. 846 2000–20 Modified by Rev. Proc. 2000–27, 2000–26 I.R.B. 1272 Revenue Rulings: 54–396 Obsoleted by T.D. 8885, 2000–25 I.R.B. 1260 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 76–79 Distinguised by Rev. Rul. 2000–24, 2000–19 I.R.B. 963 78–218 Obsoleted by T.D. 8879, 2000–16 I.R.B. 882 80–76 Obsoleted by T.D. 8883, 2000–23 I.R.B. 1151 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 Treasury Decisions: 8734 Modified by T.D. 8856, 2000–3 I.R.B. 298 Treasury Decisions—continued: 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 8879 Corrected by Announcement 2000–53, 2000–22 I.R.B. 1144 July 3, 2000vi2000–27 I.R.B. Index Internal Revenue Bulletins 2000–1 Through 2000–26 The abbreviation and number in paren- thesis following the index entry refer to the specific item; numbers in roman and italic type following the parenthesis refer to the Internal Revenue Bulletin in which the item may be found and the page number on which it appears. Key to Abbreviations: AnnAnnouncement CDCourt Decision DODelegation Order EOExecutive Order PLPublic Law PTEProhibited Transaction Exemption RPRevenue Procedure RRRevenue Ruling SPRStatement of Procedural Rules TCTax Convention TDTreasury Decision TDOTreasury Department Order EMPLOYEE PLANS Advance letter rulings and determination letters, areas which will not be issued from: Associate Chief Counsel, Domestic (RP 3) 1, 103 Associate Chief Counsel, International (RP 7) 1, 227 Cafeteria plans, treatment of (TD 8878) 15, 857; (REG–117162–99) 15, 871 Cash or deferred arrangements: Nondiscrimination (Notice 3) 4, 413 Nonqualified deferred compensation (RR 8) 7, 617 Separation from service, transferred employees (RR 27) 21,1016 Determination letters: Issuing procedures (RP 6) 1, 187 Remedial amendment GUST (RP 27) 26,1272 Eligible rollover distributions: Hardship distributions, recordkeeping requirements (Notice 32) 26, 1274 Safe harbor explanations (Notice 11) 6, 572 EPCRS, closing agreements (RP 16) 6,518; correction (Ann 17) 13,846 Full funding limitations, weighted aver- age interest rate for: January (Notice 8) 4, 420 February (Notice 2) 9,727 March (Notice 18) 13, 845 April (Notice 25) 17, 954 May (Notice 27) 21,1116 June (Notice 31) 26,1274 Letter rulings, determination letters and information letters issued by Associate Chief Counsel (RP 1) 1, 4 Letter rulings, information letters, etc. (RP 4) 1, 115 Master and prototype plans, unified pro- cedures (RP 20) 6, 553 Minimum funding standards: Amortization bases (RR 20) 16, 880 Waiver of the 100 percent tax (RP 17) 11, 766 Mortality tables (Ann 7) 6, 586 New comparability plans, nondiscrimina- tion (Notice 14) 10, 737 New technologies in retirement plans, distribution notices and consents (TD 8873) 9, 713 Proposed Regulations: 26 CFR 1.125–1, amended; 1.125–2, amended; 1.125–4, amended; tax treatment of cafeteria plans (REG–117162–99) 15, 871 26 CFR 1.411(d)–4, amended; special rules regarding optional forms of benefit under qualified retirement plans (REG–109101–98) 16, 903 Qualified retirement plans: Eligible rollover distributions, relief from disqualification of (TD 8880) 20, 1003 Optional forms of benefit (REG–109101–98) 16, 903 Remedial amendment period (TD 8871) 8, 641 Regulations: 26 CFR 1.125–4, added; 1.125–4T, amended; tax treatment of cafeteria plans (TD 8878) 15, 857 26 CFR 1.401(a)(31)–1, amended; 1.402(c)–2, amended; 1.403(b)–2, amended; relief from disqualifica- tion for plans accepting rollovers (TD 8880) 20, 1003 26 CFR 1.401(b)–1T, removed; reme- dial amendment period (TD 8871) 8, 641 26 CFR 1.402(f)–1, amended; 1.411(a)–11, amended; new tech- nologies in retirement plans (TD 8873) 9,713 Reporting requirements, section 457 plans (Ann 1) 2, 294 Technical advice to district directors and chiefs, appeals offices, from Associate Chief Counsel (RP 2) 1, 73 Technical advice to IRS employees (RP 5) 1, 158 User fees, request for letter rulings (RP 8) 1, 230 EMPLOYMENT TAX Electronic filing; magnetic media: Form 1040NR (RP 24) 22, 1133 Information reporting seminars for 2000 (Ann 47) 21, 1118 Publication 1220, Specifications for Filing Forms 1098, 1099, 5498, and W-2G, Magnetically or Electronically (RP 25) 21, 1033 Electronically filed information returns, due dates (REG–105279–99) 8, 707 EmTrac program requirements, food and beverage industry (Notice 21) 19, 967 EPCRS, closing agreements (RP 16) 6, 518; correction (Ann 17) 13, 846 Forms: Electronic filing; magnetic media: 1040 NR (RP 24) 22, 1133 1098, 1099, 5498, and W-2G, speci- fications for filing forms electroni- cally or magnetically (RP 25) 21, 1033 W-2 and W-3, specifications for private printing of paper substitutes (RP 23) 21, 1018 Information reporting, election workers (RR 6) 6,512 New technologies in retirement plans, distribution notices and consents (TD 8873) 9, 713 Proposed Regulations: 26 CFR 31.3402(q)–1, revised; 31.6053–3, revised; 31.6071(a)–1, revised; extension of due date for electronically filed information returns (REG–105279–99) 8, 707 Publication 1220, Specifications for Filing Forms 1098, 1099, 5498, and W-2G, Magnetically or Electronically (RP 25) 21, 1033 EMPLOYEE PLANS— cont. EMPLOYEE PLANS— cont. 2000–27 I.R.B.viiJuly 3, 2000 Qualified retirements plans, eligible rollover distributions, relief from dis- qualification of (TD 8880) 20, 1003 Railroad retirement: Rate determination (January 2000) 9, 721 Regulations: 26 CFR 31.3405(c)–1, amended; relief from disqualification for plans accepting rollovers (TD 8880) 20, 1003 26 CFR 35.3405–1, redesignated as 35.3405–1T, revised; 35.3405–1, added; new technologies in retire- ment plans (TD 8873) 9, 713 Substitute for Forms W-2 and W-3, for private printing and general rules and specifications (RP 23) 21, 1018 Tips: Tip rate determination agreement (TRDA): Food and beverage industry (Ann 23) 19,992 Generic agreement (Ann 20) 19, 977 Tip reporting alternative commitment (TRAC) agreement: Cosmetology and barber industry (Ann 21) 19,983 Food and beverage industry (Ann 22) 19,987 Generic agreement (Ann 19) 19, 973 ESTATE TAX Guaranteed annuity interests and unitrust interests (REG–100291–00) 16, 917 Interest rates; special use value of farm real property (RR 26) 22, 1124 Marital / charitable deduction, valuation of property; administration expenses (Ann 3) 2, 296 Proposed Regulations: 26 CFR 1.170A–6, amended; 20.2055–2, amended; 25.2522(c)–3, amended; guaranteed annuity inter- ests and unitrust interests (REG–100291–00) 16, 917 QTIP elections, individual retirement accounts and testamentary trusts (RR 2) 3, 305 Valuation tables (Ann 25) 14, 855 EXCISE TAX Coal exports, nontaxable sale (Notice 28) 21, 1116 Gasoline and diesel fuel dye injection systems, partial withdrawal of REG–209735–95 (Ann 42) 16, 949 Imported substances, tax on (Ann 43) 17, 957 Kerosene tax; aviation fuel tax; taxable fuel measurement and reporting; tax on heavy trucks and trailers; highway use tax (TD 8879) 16,882; correction (Ann 53) 22,1144 Minimum funding standards, waiver of (RP 17) 11, 766 Prepaid telephone cards (TD 8855) 4, 374 Regulations: 26 CFR 40.0–1, amended; 40.0–1T, removed; 40.6011(a)–1, added; 40.6011(a)–1T, removed; 40.6302(c)–1, amended; 40.6302(c)–1T, –2T, removed; 40.6302(c)–2, added; safe harbor deposit rule (TD 8887) 26, 1269 26 CFR 40.6011(a)–1, amended; 41.0–1, revised; 41.02–2, –3, removed; 41.4481–1T, 41.4481–1, –2, amended; 41.4481–1T, removed; 41.4482(a)–1, amended; 41.4482(b)–1, amended; 41.4482(b)–1T, removed; 41.4482(c)–1, amended; 41.4483–1, revised; 41.4483–2, –3, amended; 41.4483–5, removed; 41.4484–1, removed; 41.6001–1, –2, amended; 41–6011(a)–1, revised; 41.6071(a)–1, amended; 41.6081(a)–1, removed; 41.6091–1, revised; 41–6101–1, revised; 41.6109–1, revised; 41.6151(a)–1, revised; 41.6161(a)(1)–1, removed; 41.6302(b)–1, removed; 41.7805–1, removed; Part 47, removed; 48.0–2, amended; 48.4041–21, amended; 48.4052–1, added; 48.4081–1, amended; 48.4081–1T, removed; 48.4081–2, –3, –6, –7, –8, amended; 48.4081–9, removed; 48.4082–1, amended; 48.4082–2, –3, revised; 48.4082–4, –5, amended; 48.4082–6, –7, added; 48.4082–6T, –7T, –8T, –9T, –10T, removed; 48.4083–1, amended; 48.4091–3T, redesignated as 48.4091–3, amend- ed; 48.4101–3T, removed; 48.4101–1, –2, amended; 48.4102–2T, removed; 48.4221–1, amended; 48.4222(b)–1, amended; 48.6416(b)(2)–1, –2, amended; 48.6420–7, removed; 48.6420(c)–2, removed; 48.6421–2, amended; 48.6427–8, –9, amended; 48.6427–10, –11, added; 48.6427–10T, –11T, removed; 48.6715–1, amended; 145.4051–1, amended; 145.4052–1, amended; kerosene tax; aviation fuel tax; tax- able fuel measurement and report- ing; tax on heavy trucks and trailers; highway use tax (TD 8879) 16, 882; correction (Ann 53) 22,1144 26 CFR 49.4251–4, added; 602.101, amended; prepaid telephone cards (TD 8855) 4, 374 Return filing and deposits (Ann 5) 4, 427 Safe harbor deposit rule and floor stocks taxes (TD 8887) 26,1269 EXEMPT ORGANIZATIONS Advance letter rulings and determination letters, areas which will not be issued from Associate Chief Counsel, Domestic (RP 3) 1, 103 Charitable split dollar insurance, report- ing requirements (Notice 24) 17, 952 Information letters available for public inspection (Ann 2) 2, 295 Letter rulings, information letters, etc. (RP 4) 1, 115 List of organizations classified as private foundations (Ann 8) 6, 586; (Ann 52) 22,1142 Private foundation disclosure rules (TD 8861) 5, 441 Proposed Regulations: 26 CFR 1.170A–9(e)(6)(i), amended; 1.509(a)–3(f)(1), amended; 1.512(a)–1(e), amended; 1.513–4, withdrawn; 1.513–4, added; taxation of tax-exempt organizations’ income from corporate sponsorship (REG–209601–92) 12, 829; correc- tion (Ann 40) 16, 948 Regulations: 26 CFR 1.513–7, added; travel and EMPLOYMENT TAX— cont. EXCISE TAX— cont. July 3, 2000viii2000–27 I.R.B. tour activities of tax-exempt organi- zations (TD 8874) 8, 644; correction (Ann 29) 15, 877 26 CFR 301.6104(d)–1, removed; 301.6104(d)–2, redesignated as 301.6104(d)–0, revised; 301.6104(d)–3, redesignated as 301.6104(d)–1, amended; 301.6104(d)–4, redesignated as 301.6104(d)–2, amended; 301.6104(d)–5, redesignated as 301.6104(d)–3, amended; private foundation disclosure rules (TD 8861) 5, 441 Revocations: (Ann 15) 12, 837 (Ann 39) 16, 948 (Ann 56) 26,1281 Sponsorship payments, taxation of (REG–209601–92) 12, 829; correction (Ann 40) 16, 948 Technical advice to district directors and chiefs, appeals offices, from Associate Chief Counsel (RP 2) 1, 73 Technical advice to IRS employees (RP 5) 1, 158 Travel tours, taxation of (TD 8874) 8, 644; correction (Ann 29) 15, 877 User fees, request for letter rulings (RP 8) 1, 230 GIFT TAX Guaranteed annuity interests and unitrust interests (REG–100291–00) 16, 917 Proposed Regulations: 26 CFR 1.170A–6, amended; 20.2055–2, amended; 25.2522(c)–3, amended; guaranteed annuity inter- ests and unitrust interests (REG–100291–00) 16, 917 INCOME TAX Accounting period change, automatic consent (RP 11) 3, 309 Acquisitions, recognition of gain on dis- tributions (Ann 10) 9, 733 Adequate disclosure of gifts (Ann 6) 4, 428 Advance letter rulings and determination letters, areas which will not be issued from: Associate Chief Counsel, Domestic (RP 3) 1, 103 Associate Chief Counsel, International (RP 7) 1,227 Advance pricing agreements (Ann 35) 16, 922 Allocation of partnership debt, nonre- course liabilities (REG–103831–99) 5, 452 Amortization of intangible property (TD 8865) 7, 589; correction (Ann 37) 16,947 Appeals, test of arbitration procedure (Ann 4) 3, 317 Asset acquisitions, allocation of purchase price (TD 8858) 4, 332 Automobile owners and lessees (RP 18) 9, 722 Barter exchanges, information reporting (Notice 6) 3, 315 Business expenses: ISO 9000 costs (RR 4) 4, 331 Substantiation (TD 8864) 7,614; cor- rection (Ann 26) 15,876 Traveling expenses, per diem allowances (RP 9) 2, 280 Canadian banking legislation, repeal, deferral of termination (Notice 7) 4, 419 Closely-held real estate investment trust, estimated tax payments, penalty relief (Notice 5) 3, 314 Consolidated returns, limitations on the use of certain credits (TD 8884) 24, 1250 Contribution in aid of construction, defi- nition (REG–106012–98) 2, 290 Corporations, disposition of stock in a taxable transactions (TD 8883) 23, 1151 Credits: Low-income housing credit: Compliance monitoring (TD 8859) 5, 429; correction (Ann 27) 15, 876 Resident population estimates (Notice 13) 9, 732 Satisfactory bond; “bond factor” amounts for the period: January through March 2000 (RR 22) 16, 880 April through June 2000 (RR 31) 26, 1269 Puerto Rico and possession tax credit, termination of (TD 8868) 6, 491 Research credit, controlled group (REG–105606–99) 4, 421 Debt instrument (RR 12) 11, 744 Depletion, treatment of delay rental (REG–103882–99) 8, 706 Depreciation: MACRS property, involuntary conver- sion or like-kind exchange (Notice 4) 3, 313; correction (Ann 9) 9, 733 Determination of underwriting income, non-life insurance companies (TD 8857) 4, 365 Disclosure of return information, Census of Agriculture (TD 8854) 3,306; (REG–116704–99) 3, 325 Electronic filing; magnetic media: Form 1040NR (RP 24) 22, 1133 Information reporting seminars for 2000 (Ann 47) 21, 1118 Publication 1220, Specifications for Filing Forms 1098, 1099, 5498, and W-2G, Magnetically or Electronically (RP 25) 21, 1033 Electronically filed information returns, due dates of (REG–105279–99) 8, 707 Equity options with flexible terms, special rules and definitions (TD 8866) 6, 495 Estimated taxes: Closely-held real estate investment trust, penalty relief (Notice 5) 3, 314 Date deemed paid (CD 2066) 15, 867 Filing requirements: Northeastern taxpayers, due dates (Notice 17) 12, 827 Financial asset securitization investment trusts, general (REG–100276–97; REG–122450–98) 8, 682; correction (Ann 38) 16, 948 Foreign corporations: Exclusion of shipping income (REG–208280–86) 8, 654; correc- tion (Ann 45) 18,962 Information reporting (TD 8850) 2,265 Stock transfer rules: General provisions (TD 8862) 6, 466 Nonrecognition (TD 8863) 6, 488; (REG–116048–99) 6, 584 Foreign currency: Gains and losses, qualified business units (Notice 20) 14, 851 Hyperinflation; definition (REG–116567–99) 5, 463; (TD 8860) 5, 437 EXEMPT ORGANIZA- TIONS—cont. INCOME TAX— cont. INCOME TAX— cont. 2000–27 I.R.B.ixJuly 3, 2000 Foreign partnerships: Information reporting (TD 8850) 2, 265 U.S. persons with reportable event, reporting requirement (TD 8851) 2, 275 Foreign persons, distributions to (Ann 24) 14, 855 Forms: 1040NR, electronic filing, magnetic media (RP 24) 22, 1133 1042-S, proposed revisions (Ann 54) 26, 1276 1098, 1099, 5498, and W-2G, specifi- cations for filing forms magnetically or electronically (RP 25) 21, 1033 1099-R and 5498, procedures for reporting recharacterizations and reconversions (Notice 30) 25, 1266 SS-4, interim waiver of signature (Notice 19) 13,845 Fringe benefits: Aircraft valuation (RR 13) 12, 774 Qualified transportation (REG–113572–99) 7,624; correc- tion (Ann 41) 16,949 Guaranteed annuity interests and unitrust interests, definition of (REG–100291– 00) 16, 917 Guidance priority list (Notice 10) 5, 451 Individual retirement arrangements, reporting recharacterizations and reconversions (Notice 30) 25, 1266 Information letters available for public inspection (Ann 2) 2, 295 Information reporting: Barter exchange (Notice 6) 3, 315 Discharges of indebtedness, penalties for (Notice 22) 16, 902 Foreign partnerships and foreign cor- porations (TD 8850) 2, 265 Innocent spouse, equitable relief (RP 15) 5, 447 Installment agreements, limitation of fail- ure to pay penalty (REG–105279–99) 8, 707 Installment sales (Notice 26) 17, 954 Insurance companies: Differential earnings rate, tentative (Notice 16) 12, 826 Prevailing state assumed interest rates (RR 17) 13, 842 Interest: Investment: Federal short-term, mid-term, and long-term rates for: January 2000 (RR 1) 2, 250 February 2000 (RR 9) 6,497 March 2000 (RR 11) 10, 734 April 2000 (RR 19) 14, 849 May 2000 (RR 23) 19, 964 June 2000(RR 28) 23,1157 Rates: Underpayments and overpayments, quarter beginning: April 1, 2000 (RR 16) 12, 780 July 1, 2000 (RR 30) 25,1262 Interest netting on tax payments (RP 26) 24, 1257 International operation of ships and/or aircraft, Kingdom of Saudi Arabia, 22, 1126 Inventory: Dollar-value LIFO and inventory price index computation (IPIC) methods (REG–107644–98) 23, 1229 LIFO: Price indexes, department stores: November 1999 (RR 3) 3, 297 December 1999 (RR 10) 8,643 January 2000 (RR 14) 12,779 February 2000 (RR 21) 16, 881 March 2000 (RR 25) 20,1006 April 2000 (RR 29) 24, 1249 Last known address, definition of (Ann 49) 19, 998 Letter rulings, determination letters and information letters issued by Associate Chief Counsel (RP 1) 1, 4 Major disaster and emergency areas, losses (RR 15 ) 12, 774 Medical conference expenses, deductibil- ity of (RR 24) 19, 963 Methods of accounting; inventories, small taxpayers (RP 22) 20, 1008 Mortgage credit certificates, median income figures (RP 21) 19, 971 Nonconventional source fuel credit, inflation adjustment factor and refer- ence price (Notice 23) 17, 952 Nonqualified preferred stock, exchanges and distributions (REG–105089–99) 6, 580 Office of Tax Shelter Analysis: Address and phone number (Ann 55) 25, 1268 Newly established office (Ann 12) 12, 835 Partnerships: Adjustments following sales (Ann 13) 11, 771 Allocation of basis adjustments among partnership assets (REG–107872–99) 16, 911 Allocation of nonrecourse liabilities (REG–103831–99) 5,452 Amortization of intangible property (REG–100163–00) 7, 633 Basis adjustments, residual method, valuation of partnership assets including goodwill (REG–107872–99) 16, 911 Disposition of stock in a taxable trans- action (TD 8883) 23, 1151 Mergers and divisions (REG–111119–99) 5, 455 Options and convertible instruments (Notice 29) 23, 1241 Qualified replacement property, trans- fer to (RR 18) 14, 847 Passive foreign investment companies: Marketable stock (TD 8867) 7, 620; correction (Ann 30) 15,877 Qualified electing fund (TD 8870) 8, 647; correction (Ann 34) 15, 879 Practice before the Internal Revenue Service, governing regulations (Ann 51) 22, 1141 Pre-filing agreement pilot program (Notice 12) 9, 727 Presidentially declared disaster and com- bat zone, relief (REG–101492–98) 3, 326; correction (Ann 16) 12, 837 Private foundations: Disclosure rules (TD 8861) 5, 441 Organizations now classified as (Ann 8) 6, 586; (Ann 52) 22, 1142 Proposed Regulations: 26 CFR 1.41–0, amended; 1.41–8, revised; credit for increasing research activities (REG–105606–99) 4, 421 26 CFR 1.118–2, added; contribution in aid of construction, definition (REG–106012–98) 2, 290 26 CFR 1.132–0, amended; 1.132–9, added; qualified transportation fringe benefits (REG–113572–99) 7, 624; correction (Ann 41) 16, 949 26 CFR 1.170A–6, amended; 20.2055–2, amended; 25.2522(c)–3, amended; lifetime charitable lead INCOME TAX— cont. INCOME TAX— cont. INCOME TAX— cont. July 3, 2000x2000–27 I.R.B. trusts (REG–100291–00) 16, 917 26 CFR 1.197–2, amended; amortiza- tion of intangible property (REG–100163–00) 7, 633 26 CFR 1.337(d)–5T, added, 1.852–12, added; 1.857–11, added; certain asset transfers to regulated investment companies and real estate investment trusts (REG–209135–88) 8, 681 26 CFR 1.354–1, amended; 1.355–1, amended; 1.356–7, added; 1.1036–1, amended; treatment of nonqualified perferred stock and other preferred stock in certain exchanges and distributions (REG–105089–99) 6, 580 26 CFR 1.367(b)–3, amended; stock transfer rules (REG–116048–99) 6, 584 26 CFR 1.368–2, amended; certain corporate reorganizations involving disregarded entities (REG–106186–98) 23, 1226 26 CFR 1.472–8, amended; dollar- value LIFO regulations, inventory price index computation method (REG–107644–98) 23, 1229 26 CFR 1.612–3, amended; depletion, treatment of delay rental (REG–103882–99) 8, 706 26 CFR 1.708–1, amended; 1.743–1, amended; treatment of partnership mergers and divisions (REG–111119–99) 5, 455 26 CFR 1.752–3, amended; 1.752–5, revised; allocation of nonrecourse liabilities by a partnership (REG–103831–99) 5, 452 26 CFR 1.755–2, added; 1.755–2T, removed; allocation of basis adjust- ments among partnership assets (REG–107872–99) 16, 911 26 CFR 1.860E–1, amended; 1.860H–0, –1, –2, –3, –4, –5, –6, added; 1.860I–1, –2, added; 1.860J–1, added; 1.860L–1, –2, –3, –4, added; 1.861–9T, amended; 1.861–10T, amended; financial asset securitization investment trusts; real estate mortgage investment conduits (REG–100276–97; REG–122450–98) 8, 682; correction (Ann 38) 16,948 26 CFR 1.861–4, amended; source of compensation for labor or personal services (REG–208254–90) 6, 577 26 CFR 1.883–0, added; 1.883–1, revised; 1.883–2, –3, –4, –5, added; exclusions from gross income of foreign corporations (REG–208280–86) 8, 654 26 CFR 1.988–1, revised; hyperinfla- tionary currencies, definition (REG–116567–99) 5, 463 26 CFR 1.6011–4, added; tax shelter disclosure statements (REG–103735–00) 11, 770 26 CFR 1.6041–2, revised; 1.6041–6, revised; 1.6042–2, revised; 1.6043–2, revised; 1.6044–2, revised; 1.6045–1, added; 1.6045–2, revised; 1.6045–4, revised; 1.6047–1, revised; 1.6049–4, revised; 1.6049–7, revised; 1.6050A–1, revised; 1.6050D–1, revised; 1.6050E–1, revised; 1.6050H–2, revised; 1.6050J–1T, revised; 1.6050P–1, revised; 1.6052–1, revised; 301.6651–1, amended; extension of due date for electronically filed information returns; limitation of failure to pay penalty for individuals during peri- od of installment agreement (REG–105279–99) 8, 707 26 CFR 301.6103(j)(5)–1, added; dis- closure of return information; Census of Agriculture (REG–116704–99) 3, 325 26 CFR 301.6111–2, added; corporate tax shelter registration (REG–110311–98) 11, 767 26 CFR 301.6112–1, amended; requirements to maintain list of investors in potentially abusive tax shelters (REG–103736–00) 11, 768; correction (Ann 44) 17, 958 26 CFR 301.7508–1, added; 301.7508A–1, added; relief for ser- vice in combat zone and for Presidentially declared disaster (REG–101492–98) 3, 326; correc- tion (Ann 16) 12, 837 Publications: 515, changes to Tables 1 and 2 (Ann 11) 10, 739 1167, substitute forms, general requirements (RP 19) 12, 785 1212, supplemental information (Ann 14) 11, 772 1220, Specifications for Filing Forms 1098, 1099, 5498, and W-2G, Magnetically or Electronically (RP 25) 21, 1033 Circular 230 (Ann 51) 22,1141 Qualified intermediary withholding agreements (RP 12) 4, 387; correction (Ann 50) 19, 998 Qualified mortgage bond, median income figures (RP 21) 19, 971 Qualified Zone Academy Bonds (RP 10) 2, 287 Real estate investment trusts, asset trans- fers to (TD 8872) 8, 639; (REG–209135–88) 8, 681 Real estate mortgage investment con- duits, safe harbor (REG–100276–97; REG–122450–98) 8, 682; correction (Ann 38) 16,948 Recharacterizing financing arrangements, fast-pay stock (TD 8853) 4, 377; cor- rection (Ann 33) 15, 878 Regulated investment companies, asset transfers to (TD 8872) 8, 639; (REG–209135–88) 8, 681 Regulations: 26 CFR 1.42–5, –6, amended; 1.42 –11, –12, –13, amended; 1.42–17, added; compliance monitoring and miscellaneous issues relating to the low-income housing credit (TD 8859) 5, 429 26 CFR 1.62–2, amended; 1.62–2T, removed; 1.274–5, added; 1.274–5T, amended; substantiation of business expenses (TD 8864) 7, 614; correction (Ann 26) 15, 876 26 CFR 1.83–6, amended; 1.1032–2, amended; 1.1032–3, added; 1.1502–13, amended; disposition of stock in taxable transaction (TD 8883) 23, 1151 26 CFR 1.162–11, amended; 1.167(a)–3, amended; 1.167(a)–6, amended; 1.167(a)–14, added; 1.197–0, added; 1.197–2, added; amortization of goodwill and certain other intangibles (TD 8865) 7, 589; correction (Ann 37) 16, 947 26 CFR 1.337(d)–5, added, certain asset transfers to regulated invest- ment companies and real estate INCOME TAX— cont. INCOME TAX— cont. INCOME TAX— cont. 2000–27 I.R.B.xiJuly 3, 2000 investment trusts (TD 8872) 8, 639 26 CFR 1.338–0, –1, –2, –3, removed; 1.338–4, redesignated as 1.338–8; 1.338–5, redesignated as 1.338–9; 1.338–4T, –5T, –6T, –7T, –10T, added; 1.338(b)–1, added; 1.338(b)–2T, –3T, removed; 1.338(h)(10)–1, removed; 1.338(i)–1, removed; 1.338(i)–1T, added; 1.1060–1T, revised; purchase price allocations in deemed and actual asset acquisitions (TD 8858) 4, 332 26 CFR 1.354–1, amended; 1.355–1, amended; 1.356–3, amended; 1.356–6T, redesignated as 1.356–6; reorganizations, nonqualified pre- ferred stock (TD 8882) 23, 1150 26 CFR 1.367(a)–3, amended; 1.367(b)–0, added; 1.367(b)–1, –2, revised; 1.367(b)–3, added; 1.367(b)–4, revised; 1.367(b)–5, –6, added; 1.367(b)–7, –8, –9, removed; 1.381(b)–1, amended; 7.367(b)–1, –2, –3, –4, –5, –6, –7, –8, –9, –10, –11, removed; 7.367(b)–12, amend- ed; 7.367(b)–13, removed; stock transfers rules (TD 8862) 6, 466 26 CFR 1.367(b)–3T, added; stock transfer rules, (TD 8863) 6, 488 26 CFR 1.367(e)–1, –2, corrected; treatment of distributions to foreign persons (Ann 24) 14, 855 26 CFR 1.368–2, amended; solely for voting stock requirement in certain corporate reorganizations (TD 8885) 25, 1260 26 CFR 1.401(b)–1, amended; 1.401(b)–1T, removed; remedial amendment period (TD 8871) 8, 641 26 CFR 1.663(a)–1, amended; 1.663(c)–1, amended; 1.663(c)–2, revised; 1.663(c)–3, amended; 1.663(c)–4, redesignated as 1.663(c)–5, amended; 1.663(c)–4, added; 1.663(c)–6, added; separate shares rule applicable to estates (TD 8849) 2, 245; correction (Ann 28) 15,876 26 CFR 1.664–2, corrected; use of actuarial tables in valuing annuities, interests for life or term of years, and remainder or reversionary inter- ests (Ann 25) 14, 855 26 CFR 1.743–1, 1.754–1, 1.755–1, corrected; adjustments following sales of partnership interests (Ann 13) 11, 771 26 CFR 1.871–14, revised; 1.1441–1, –4, –5, –6, –8, –9, revised; 1.1443–1, revised; 1.6042–3, revised; 1.6045–1, revised; 1.6049–5, revised; withholding of tax on certain U.S. source income paid to foreign persons; delay of effective date (TD 8856) 3, 298; correction (Ann 31) 15, 877 26 CFR 1.883–0, added; 1.883–1, revised; 1.883–2, –3, –4, –5, added; exclusions from gross income of foreign corporations (REG–208280–86) 8, 654; change of date for public hearing (Ann 45) 18, 962 26 CFR 1.936–11T, removed; 1.936–11, added; termination of Puerto Rico and possession tax credit (TD 8868) 6, 491 26 CFR 1.988–0, amended; 1.988–2, amended; treatment of income and expenses from certain hyperinfla- tionary currencies; nonperiodic pay- ments (TD 8860) 5, 437 26 CFR 1.1092(c)–1, added; equity options with flexible terms (TD 8866) 6, 495 26 CFR 1.1291–1T, redesignated as 1.1291–1, revised; 1.1293–1T, redesignated as 1.1293–1, revised; 1.1295–0, amended; 1.1295–1T, redesignated as 1.1295–1, amended; 1.1295–3T, redesignated as 1.1295–3, amended; general rules for making and maintaining quali- fied electing fund elections (TD 8870) 8, 647; correction (Ann 34) 15,879 26 CFR 1.1296(e)–1, added; passive foreign investment companies, mar- ketable stock (TD 8867) 7, 620; cor- rection (Ann 30) 15,877 26 CFR 1.1361–0, –1; amended; 1.1361–2, –3, –4, –5, –6, added; 1.1362–0, amended; 1.1362–2, amended; 1.1362–8, added; 1.1368–0, amended; 1.1368–2, amended; 1.1374–8, amended; 301.6109–1, amended; subchapter S subsidiaries (TD 8869) 6, 498; cor- rection (Ann 36) 16,947 26 CFR 1.1366–0, –1, added; 1.1366–2, revised; 1.1366–3, –4, –5, added; 1.1367–0, –1, amended; 1.1367–3, revised; 1.1368–0, –1, –2, –3, amended; 1.1368–4, revised; passthrough of items of an S corpo- ration to its shareholders (TD 8852) 2, 253; correction (Ann 18) 13,846; correction (Ann 32) 15,878 26 CFR 1.1441–0, –1, –2, –3, –4, –6, –7, –9, amended; 1.1441–5, revised; 1.1461–1, amended; 1.6041–1, –4, amended; 1.6041A–1, amended; 1.6042–3, amended; 1.6045–1, amended; 1.6049–4, –5, amended; U.S. source income paid to foreign persons; reporting and recordkeeping requirements (TD 8881) 23, 1158 26 CFR 1.1441–10, added; 1.7701(1)–0, added; 1.7701(1)–3, added; 602.101(b), amended; recharacteriz- ing financing arrangements involving fast–pay stock (TD 8853) 4, 377; cor- rection (Ann 33) 15,878 26 CFR 1.1502–3, –4, –9A, –21, –98, amended; 1.1502–3T, -4T, -55T, removed; 1.1502–55, added; consol- idated returns, limitations on use of certain credits (TD 8884) 24, 1250 26 CFR 1.6011–4T, added; tax shelter disclosure statements (TD 8877) 11, 747 26 CFR 1.6038–3, added; 1.6038–2, amended; 1.6038B–1, amended; 1.6038B–2, amended; information reporting with respect to certain for- eign partnerships and certain foreign corporations (TD 8850) 2, 265 26 CFR 1.6046A–1, added; return requirement for U.S. persons acquir- ing or disposing of an interest in a foreign partnership (TD 8851) 2, 275 26 CFR 301.6103(j)(5)–1T, added; disclosure of return information; Census of Agriculture (TD 8854) 3, 306 26 CFR 301.6104(d)–1, removed; 301.6104(d)–2, redesignated as 301.6104(d)–0, revised; 301.6104(d)–3, redesignated as INCOME TAX— cont. INCOME TAX— cont. INCOME TAX— cont. July 3, 2000xii2000–27 I.R.B. 301.6104(d)–1, amended; 301.6104(d)–4, redesignated as 301.6104(d)–2, amended; 301.6104(d)–5, redesignated as 301.6104(d)–3, amended; 602.101(b), amended; private foun- dation disclosure rules (TD 8861) 5, 441 26 CFR 301.6111–2T, added; corpo- rate tax shelter registration (TD 8876) 11, 753 26 CFR 301.6112–1T, amended; requirements to maintain list of investors in potentially abusive tax shelters (TD 8875) 11, 761 Removal costs, capital expenditures (RR 7) 9, 712 Reorganizations: Divisive mergers, definition (RR 5) 5, 436 Mergers and disregarded entities (REG–106186–98) 23, 1226 Nonqualified preferred stock (TD 8882) 23, 1150 Revocations, exempt organizations (Ann 15) 12, 837; (Ann 39) 16, 948; (Ann 56) 26, 1281 S corporations: Passthrough items (TD 8852) 2, 253; correction (Ann 18) 13,846; correc- tion (Ann 32) 15,878 Subsidiaries (TD 8869) 6, 498; correc- tion (Ann 36) 16,947 Section 911(d)(4) waiver; 1999 update (RP 14) 18, 960 Separate shares rules (TD 8849) 2, 245; correction (Ann 28) 15,876 Short-term Treasury bills (Ann 14) 11, 772 Solely for voting stock requirement: Advance notice of final regulations (Notice 1) 2, 288 Final regulations (TD 8885) 25,1260 Sources of income, compensation for labor or services (REG–208254–90) 6, 577 Tax conventions: New treaties with Estonia, Latvia, Lithuania, Venezuela; Publication 515 changes (Ann 11) 10, 739 Shipping and aircraft agreement, Kingdom of Saudi Arabia, 22, 1126 Treaties with Austria, Ireland, South Africa; Publication 515 changes (Ann 11) 10,739 United Kingdom; repeal of advance corporation tax (RP 13) 6, 515 Tax liens, determination of property or rights to property (CD 2067) 15, 863 Tax shelters: Circular 230 (Ann 51) 22, 1141 Confidential corporate, registration (TD 8876) 11, 753; (REG–110311–98) 11,767 Disclosure statements (TD 8877) 11, 747; (REG–103735–00) 11, 770 Listed transactions (Notice 15) 12, 826 Office of Tax Shelter Analysis (Ann 12) 12,835 Potentially abusive, list of investors (TD 8875) 11, 761; (REG–103736–00) 11, 768; correc- tion (Ann 44) 17,958 Technical advice to district directors and chiefs, appeals office, from Associate Chief Counsel (RP 2) 1, 73 Treasury bonds, call for redemption of (Ann 46) 19, 997 Valuation tables (Ann 25) 14, 855 Variable annuity contracts, closing agree- ments (Notice 9) 5, 449 Withholdings: Date deemed paid (CD 2066) 15, 867 Qualified intermediary withholding agreements: Application procedures (RP 12) 4, 387 Guidance for financial institutions (Ann 48) 23,1243 U.S. source income paid to foreign persons: Delay of effective date (TD 8856) 3, 298; correction (Ann 31) 15, 877 Reporting and recordkeeping requirements (TD 8881) 23, 1158 INCOME TAX— cont. INCOME TAX— cont. INTERNAL REVENUE BULLETIN The Introduction at the beginning of this issue 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 sold on a single copy basis and are not included as part of the subscription to the Internal Revenue Bulletin. Subscribers to the week- 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 Superintendent of Documents. HOW TO ORDER 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.gov) or write to the IRS Bulletin Unit, OP:FS:FP:P:1, Room 5617, 1111 Constitution Avenue NW, Washington, DC 20224. Internal Revenue Service Washington, DC 20224 Official Business Penalty for Private Use, $300
Setzen Sie Ihre Recherche in ChatGPT oder Claude fort
Verbinden Sie Omnilex, um den Rechtskorpus über Ihren KI-Assistenten zu durchsuchen.