Internal Revenue Bulletin 1998-24 (PDF rendition): IRS Revenue Rulings

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. 98–29, page 4.
LIFO; price indexes; department stores.The April 1998
Bureau of Labor Statistics price indexes are accepted for
use by department stores employing the retail inventory
and last-in, first-out inventory methods for valuing invento-
ries for tax years ended on, or with reference to, April 30,
1998.
EXEMPT ORGANIZATIONS
Announcement 98–52, page 37.
The organization Youth Today Leaders Tomorrow, Inc.,
Golden Valley, MN, no longer qualifies as an organization to
which contributions are deductible under section 170 of the
Code.
Announcement 98–53, page 37.
A list is given of organizations now classified as private foun-
dations.
EMPLOYMENT TAX
Announcement 98–48, page 6.
Rev. Proc. 98–26, 1998–13 I.R.B. 26, relating to the specifi-
cations for filing Form W–4, Employee’s Withholding
Allowance Certificate, magnetically or electronically, is
corrected.
ADMINISTRATIVE
Announcement 98–51, page 7.
The Service is requesting comments from the public on the
following proposed new forms and instructions; Form W–8,
Certificate of Foreign Status of Beneficial Owner for United
States Tax Withholding; Form W–8A, Foreign Persons’ Claim
of Income Effectively Connected With the Conduct of a
Trade or Business in the United States; Form W–8B, Certifi-
cation for United States Tax Withholding for Foreign Govern-
ments and Other Foreign Organizations; and Form W–8C,
Certificate of Foreign Intermediary, Foreign Partnership, and
Certain U.S. Branches for United States Tax Withholding.
Prior versions of the forms, without instructions, were is-
sued in Announcement 98–15, 1998–10 I.R.B. 36.
Internal Revenue
bbuulllleettiinn
Bulletin No. 1998–24
June 15, 1998
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 44.
Announcement of the Consent Voluntary Suspension of Attorneys, Certified Public Accounts, Enrolled Agents, etc., begins on
page 40.
Announcement of the Expedited Suspension of Attorneys, Certified Public Accountants, Enrolled Agents, and Enrolled
Actuaries From Practice Before the Internal Revenue Service begins on page 41.
Announcement of Declaratory Judgment Proceedings Under Section 7428 begins on page 39.

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

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 of a permanent nature are consoli-
dated 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.
With the exception of the Notice of Proposed Rulemaking
and the disbarment and suspension list included in this part,
none of these announcements are consolidated in the Cumu-
lative Bulletins.
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.
3
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.

June 15, 199841998–24 I.R.B.
Section 472.—Last-in, First-out
Inventories
26 CFR 1.472-1: Last-in, first-out inventories.
LIFO; price indexes; department
stores. The April 1998 Bureau of Labor
Statistics price indexes are accepted for
use by department stores employing the
retail inventory and last-in, first-out in-
ventory methods for valuing inventories
for tax years ended on, or with reference
to, April 30, 1998.
Rev. Rul. 98–29
The following Department Store
Inventory Price Indexes for April
1998 were issued by the Bureau of Labor
Statistics. The indexes are accepted by
the Internal Revenue Service, under
§ 1.472–1(k) of the Income Tax Regula-
tions and Rev. Proc. 86–46, 1986–2 C.B.
739, for appropriate application to
inventories of department stores employ-
ing the retail inventory and last-in, first-
out inventory methods for tax years
ended on, or with reference to, April 30,
1998.
The Department Store Inventory Price
Indexes are prepared on a national basis
and include (a) 23 major groups of depart-
ments, (b) three special combinations of
the major groups - soft goods, durable
goods, and miscellaneous goods, and (c) a
store total, which covers all departments,
including some not listed separately, ex-
cept for the following: candy, food,
liquor, tobacco, and contract departments.
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
BUREAU OF LABOR STATISTICS, DEPARTMENT STORE
INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS
(January 1941 = 100, unless otherwise noted)
Percent Change
GroupsApr.Apr.from Apr. 1997
19971998to Apr. 1998
1
1. Piece Goods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .533.0547.32.7
2. Domestics and Draperies . . . . . . . . . . . . . . . . . . . . . . . . . .653.6 642.9–1.6
3. Women’s and Children’s Shoes . . . . . . . . . . . . . . . . . . . . .661.3663.60.3
4. Men’s Shoes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .904.8902.5–0.3
5. Infants’ Wear . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .640.6628.1–2.0
6. Women’s Underwear . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .546.3586.17.3
7. Women’s Hosiery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .294.4305.53.8
8. Women’s and Girls’ Accessories . . . . . . . . . . . . . . . . . . . . .561.0550.1–1.9
9. Women’s Outerwear and Girls’ Wear . . . . . . . . . . . . . . . . .439.8431.7–1.8
10. Men’s Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .622.2633.61.8
11. Men’s Furnishings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .598.9609.61.8
12. Boys’ Clothing and Furnishings . . . . . . . . . . . . . . . . . . . . .498.6498.80.0
13. Jewelry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1026.2 1001.8–2.4
14. Notions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .799.2793.7–0.7
15. Toilet Articles and Drugs . . . . . . . . . . . . . . . . . . . . . . . . . .912.5936.72.7
16. Furniture and Bedding . . . . . . . . . . . . . . . . . . . . . . . . . . . .667.5675.91.3
17. Floor Coverings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .586.9603.72.9
18. Housewares . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .815.9821.40.7
19. Major Appliances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .241.9239.4–1.0
20. Radio and Television . . . . . . . . . . . . . . . . . . . . . . . . . . . . .76.673.0–4.7
21. Recreation and Education
2
. . . . . . . . . . . . . . . . . . . . . . . . .110.2105.7–4.1
22. Home Improvements
2
. . . . . . . . . . . . . . . . . . . . . . . . . . . . .131.4134.02.0
23. Auto Accessories
2
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .107.3106.8–0.5
Groups 1 – 15: Soft Goods . . . . . . . . . . . . . . . . . . . . . . . . . . .614.6615.30.1
Groups 16 – 20: Durable Goods . . . . . . . . . . . . . . . . . . . . . . . .466.9464.9–0.4
Groups 21 – 23: Misc. Goods
2
. . . . . . . . . . . . . . . . . . . . . . . . .112.4109.5–2.6
Store Total
3
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .562.6560.8–0.3
1
Absence of a minus sign before percentage change in this column signifies price increase.
2
Indexes on a January 1986=100 base.
3
The store total index covers all departments, including some not listed separately, except for the following: candy, foods, liquor, to-
bacco, and contract departments.

1998–24 I.R.B.5June 15, 1998
DRAFTING INFORMATION
The principal author of this revenue
ruling is Stan Michaels of the Office of
Assistant Chief Counsel (Income Tax and
Accounting). For further information re-
garding this revenue ruling, contact Mr.
Michaels on (202) 622-4970 (not a toll-
free call).

June 15, 199861998–24 I.R.B.
Part IV. Items of General Interest
Rev. Proc. 98–26; Correction
Announcement 98–48
This announcement corrects certain minor errors which appeared in Rev. Proc. 98–26, I.R.B. 1998–13, which provides specifica-
tions for filing Forms W–4, Employee’s Withholding Allowance Certificate, magnetically or electronically. Revenue Procedure 98-
26 is reprinted as Publication 1245, Specifications for Filing Forms W–4, Employee’s Withholding Allowance Certificate, Magneti-
cally or Electronically.
Changes are listed by part and section. The actual changed wording is highlighted using italics and bold print.
26 CFR 601.602: Tax forms and instructions.
PART A. GENERAL
SEC. 7. FILING FORMS W–4 MAGNETICALLY/ELECTRONICALLY
.06 Before submitting your magnetic/electronic file, include the following:
(b) Your media (tape, diskette or cartridge with an external label.) Notice 1027describes the information which should be in-
cluded on this self-prepared label.
PART B. MAGNETIC MEDIA/ELECTRONIC SPECIFICATIONS
SEC. 1. GENERAL
.02 An external label must appear on each tape, tape cartridge and diskette submitted. Notice 1027details what information must
be on the label. The diskettes used must be MS/DOS compatible.
SEC. 7. FORM W–4 RECORD FORMAT AND RECORD LAYOUT
Field
PositionField TitleLengthDescription and Remarks
140–141Employee State2REQUIRED. Enter the two of employees address - must be one the following:
*Note 1: For foreign addresses, enter xx from table below.
LocationCodeLocationCode Location Code
Alabama ALKentuckyKYOhioOH
AlaskaAKLouisianaLAOklahomaOK
American SamoaASMaineMEOregonOR
Arizona AZMarshall IslandsMHPennsylvaniaPA
ArkansasARMarylandMD Puerto RicoPR
CaliforniaCAMassachusettsMARhode IslandRI
ColoradoCOMichiganMI South CarolinaSC
ConnecticutCTMinnesotaMNSouth DakotaSD
DelawareDEMississippiMSTennesseeTN
District of ColumbiaDCMissouriMOTexasTX
Federated StatesMontanaMTUtah UT
of MicronesiaFMNebraskaNEVermontVT
FloridaFLNevadaNVVirginiaVA
GeorgiaGANew Hampshire NHVirgin IslandsVI
GuamGUNew JerseyNJWashingtonWA
HawaiiHI New MexicoNMWest VirginiaWV
IdahoID New YorkNYWisconsinWI
IllinoisILNorth CarolinaNCWyomingWY
IndianaIN North Dakota NDForeign Address,
IowaIANorthern All OthersXX
KansasKSMariana Islands MP

1998–24 I.R.B.7June 15, 1998
FORM W–4 RECORD FORMAT AND RECORD LAYOUT (CONTINUED)
Field
PositionField TitleLengthDescription and Remarks
214–247Employer Name 34If the employer name requires more space than is available in Employer Name Line 1,
Line 2enter the remaining portion of the name in this field. Left-justify and fill with blanks.
Position 214 Must be alpha or numeric; hyphens must be surrounded by alphas or nu-
merics; blanks must be surrounded by alphas or numerics or continued to the field
(e.g., ab...b, aba).
*Note: The same exceptions apply as set forth in “Employer Name Line 1” plus the use of a percent sign (%) is not valid—use c/o
if necessary.
248–282Employer Street35REQUIRED. Enter mailing address of employer. Street address should include num-
ber, street, apartment or suite number (or P O Box if mail is not delivered to street ad-
dress). Left-justify and fill unused positions with blanks. Position 248 must be alpha or
numeric; hyphens must be surrounded by alphas or numerics; blanks must be sur-
rounded by alphas or numerics or continued to the end of the field(e.g., ab...b, aba).
*Note: The only allowable characters are alphas, blanks, numerics, ampersand, hyphens and slashes. Punctuation such as periods
and commas are not allowed and will cause your file to be returned. For example, the address 210 N. Queen St., Suite #300 must be
entered as 210 N Queen St Suite 300.
Proposed Forms W–8, W–8A,
W–8B, and W–8C, and
Instructions
Announcement 98–51
The Internal Revenue Service an-
nounces that it is requesting comments
from the public on proposed new Forms
W–8, W–8A, W–8B, and W–8C and in-
structions to these forms. These new
forms are being proposed as a result of
final regulations published on October 14,
1997, relating to the withholding of in-
come tax under sections 1441, 1442, and
1443 on certain U.S. source income paid
to foreign persons. T.D. 8734, 62 F.R.
53387; 1997–44 I.R.B. 5. These regula-
tions, which provide for the use of several
withholding certificates, will be effective
January 1, 2000. See Notice 98–16,
1998–15 I.R.B. 12. Prior versions of the
new forms, without instructions, were is-
sued in Announcement 98–15, 1998–10
I.R.B. 36.
Form W–8 (Certificate of Foreign Sta-
tus of Beneficial Owner for United States
Tax Withholding) would be provided to a
withholding agent or payer by a beneficial
owner of certain types of income to estab-
lish foreign status, to claim that such per-
son is the beneficial owner of the income
for which the form is being furnished, and
if applicable, to claim a reduced rate of, or
exemption from, withholding as a resi-
dent of a foreign country with which the
United States has an income tax treaty.
Form W–8A (Foreign Person’s Claim
of Income Effectively Connected With
the Conduct of a Trade or Business in the
United States) would be provided to a
withholding agent or payer by a foreign
person claiming that certain income is ef-
fectively connected with the conduct of a
trade or business in the United States.
Form W–8B (Certification for United
States Tax Withholding for Foreign Gov-
ernments and Other Foreign Organi-
zations) would be provided to a with-
holding agent or payer by a foreign
government, international organization,
foreign central bank of issue, or foreign
tax-exempt organization to claim that
such organization is the beneficial owner
of the income for which the form is being
furnished, and if applicable, to claim a re-
duced rate of, or exemption from, with-
holding as a resident of a foreign country
with which the United States has an in-
come tax treaty.
Form W–8C (Certificate of Intermedi-
ary for United States Tax Withholding)
would be provided to a withholding agent
or payer by an intermediary either to
make representations regarding the status
of beneficial owners of the amount paid
or to transmit appropriate documentation
to the withholding agent.
This announcement provides copies of
proposed Forms W–8, W–8A, W–8B,
W–8C, and the accompanying instruc-
tions. Comments on the forms and in-
structions should be submitted in writing
by August 14, 1998, to the Chairman, Tax
Forms Coordinating Committee, Internal
Revenue Service, T:FS:FP, Room 5577,
1111 Constitution Avenue, NW, Washing-
ton, DC 20224.

June 15, 199881998–24 I.R.B.

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1998–24 I.R.B.37June 15, 1998
Deletions From Cumulative List
of Organizations Contributions
to Which Are Deductible Under
Section 170 of the Code
Announcement 98–52
The names of organizations that no
longer qualify as organizations described
in section 170(c)(2) of the Internal Rev-
enue Code of 1986 are listed below.
Generally, the Service will not disallow
deductions for contributions made to a
listed organization on or before the date
of announcement in the Internal Revenue
Bulletin that an organization no longer
qualifies. However, the Service is not
precluded from disallowing a deduction
for any contributions made after an orga-
nization ceases to qualify under section
170(c)(2) if the organization has not
timely filed a suit for declaratory judg-
ment under section 7428 and if the con-
tributor (1) had knowledge of the revoca-
tion of the ruling or determination letter,
(2) was aware that such revocation was
imminent, or (3) was in part responsible
for or was aware of the activities or omis-
sions of the organization that brought
about this revocation.
If on the other hand a suit for declara-
tory judgment has been timely filed, con-
tributions from individuals and organiza-
tions described in section 170(c)(2) that
are otherwise allowable will continue to
be deductible. Protection under section
7428(c) would begin on (DATE) 1998,
and would end on the date the court first
determines that the organization is not de-
scribed in section 170(c)(2) as more par-
ticularly set forth in section 7428(c)(1).
For individual contributors, the maximum
deduction protected is $1,000, with a hus-
band and wife treated as one contributor.
This benefit is not extended to any indi-
vidual who was responsible, in whole or
in part, for the acts or omissions of the or-
ganization that were the basis for revoca-
tion.
Youth Today Leaders Tomorrow, Inc.
Golden Valley, MN
Foundations Status of Certain
Organizations
Announcement 98–53
The following organizations have
failed to establish or have been unable to
maintain their status as public charities or
as operating foundations. Accordingly,
grantors and contributors may not, after
this date, rely on previous rulings or des-
ignations in the Cumulative List of Orga-
nizations (Publication 78), or on the pre-
sumption arising from the filing of notices
under section 508(b) of the Code. This
listing does notindicate that the organiza-
tions have lost their status as organiza-
tions described in section 501(c)(3), eligi-
ble to receive deductible contributions.
Former Public Charities.The following
organizations (which have been treated as
organizations that are not private founda-
tions described in section 509(a) of the
Code) are now classified as private foun-
dations:
AAB Generations Foundation, Irving, TX
AFROTC Cadet Association, Boulder,
CO
Arizona Cowboy Hall of Fame and
Museum Inc., Payson, AZ
Arizona Multi-Cultural Youtheatre and
School of Music Dance Drama,
Scottsdale, AZ
Asia Missionary Evangelism, Garden
Grove, CA
Association for Injured Workers, Fridley,
MN
Baltimore Washington Chapter of the
Health Physics Society Inc., Silver
Spring, MD
Big Sky Family Allergy-Asthma Support
Team Inc., Bozeman, MT
Black Watch Soccer Club Inc., Tampa, FL
Boynton Beach Community
Development Corporation, Boynton
Beach, FL
Bulldog Hocky Club Inc., Washington,
DC
Central Wisconsin Zoological Society
Inc., Wausau, WI
Cherry Creek Touchdown Club Inc.,
Englewood, CO
Christ Centered Counseling Clinic Inc.,
Madison, TN
Christine Gage Upper East Trenton
Outreach Center Inc., Trenton, NJ
Clark County Arts and Humanities
Council, Arkadelphia, AR
Coalition Advocating Marydales
Preservation, Villa Hills, KY
Columbia Central High School Academic
Boosters Association, Columbia, TN
Community Housing Inc., Tampa, FL
Community Services Development
Group, Olympia, WA
Community Re-Orientation Program,
Greenville, NC
Community Tutoring School, Mesa, AZ
Corporation for Cardiac Education,
Richmond, VA
Creating Positive Relationships
Incorporated, Carmel, IN
Dixie Hollins Band Boosters Inc.,
St. Petersburg, FL
Funeral Directors Association of
Kentucky Scholarship Trust, Frankfort,
KY
Gentlemens Club, Lufkin, TX
Edgeworth Preservation, Sewickley, PA
Ernest T. Chadwell Parent and Teacher
Organization, Madison, TN
Friends of Bulloch Inc., Roswell, GA
Friends of the Wentzville High School
Math Team Inc., Foristell, MO
Gods Hope, Hillsboro, MO
Good Life Therapeutic Equestrian Center
Inc., Albany, GA
Greater Atlanta Dermatology Foundation
Inc., Atlanta, GA
Greater Collegedale School System
Endowment Fund Inc., Collegedale, TN
Grove City Star, Grove City, OH
Happy Days Daycare & Child
Development Center Inc., Diaz, AR
Hawley-South Granville Choral Parents
Association, Creedmoor, NC
Helen K. Kanoy Endowment Fund,
Thomasville, NC
Help or Motivate Everybody, Inc., Dallas,
TX
Helping Hands of America Association,
Winston Salem, NC
Huntsville Chapter of the American
Institute of Banking, Huntsville, AL
Indiana Minority Consortium on
Substance Abuse Inc., Muncie, IN
International Society of Welding
Educators, Inc., Miami, FL
Irving Schools Crime Stoppers Inc.,
Irving, TX
Journey of the Heart International, Falcon
Heights, MN
Kids School Tools Inc., Macon, GA
Life Change Technologies of Ohio Inc.,
Kent, OH
Matlack Specialized Creative Ministries,
Bayonet, FL
Medford Educational Institute Inc.,
Medford, OR
Metropolitan Milwaukee Civic Alliance,
Milwaukee, WI
Middle East Development and Science
Institute Inc., Potomac, MD

June 15, 1998381998–24 I.R.B.
Mitchell High School Athletic Booster
Club, Colorado Springs, CO
Monacan Band Boosters Association,
Richmond, VA
Mother Divine Love Foundation,
Burlingame, CA
Mountaintop Soccer Association Inc.,
Swanton, MD
National Foundation for Families,
Auburn, WA
National Service Organization of Cosa
Inc., Louisville, KY
Nehemiah Project Inc., Dysart, PA
North Pittsburgh Quilters Guild,
Wexford, PA
North Springs Baptist Church, Colorado
Springs, CO
Northwest Arkansas Society of
Diagnostic Medical Sonographers,
Springdale, AR
Ohio Association of Casa and Gal
Parachute, Columbus, OH
100 Black Men of West Tennessee,
Jackson, TN
One Byte At A Time Inc., Nampa, ID
Osceola & St. Croix Valley Railway Inc.,
Osceola, WI
Overcoming Christians Inc., Keller, TX
Overseas Medical Foundation, San Jose,
CA
Parents for Parity, Flossmoor, IL
Pearl M. Goodwin Charitable Trust,
Garden City, NY
Permian Basin Childs Play Inc., Odessa,
TX
Pet Adoption Nursery of West County,
Chesterfield, MO
Positive Images Southwest Mississippi
Community Outreach Inc., Tylertown,
MS
Purdue Student Broadcasting Foundation
Inc., Lafayette, IN
Rick Finley Memorial Inc., Newark, AR
Royal Foli Bebe A Ayi Foundation,
Washington, DC
Russellville Womans Club, Russellville,
KY
Safe Medicine for Consumers, San
Andreas, CA
Saginaw Valley Safety and Health
Council, Midland, MI
Salinas Valley Youth Soccer League,
Salinas, CA
San Diego Big Book, Lakeside, CA
San Diego Youth & Adult Coalition, San
Diego, CA
San Jose Kendo Dojo, Santa Clara, CA
Santa Monica Youth Athletic Foundation,
Santa Monica, CA
Saturday Seminars, Albany, CA
Sausalito Sister City Committee Inc.,
Sausalito, CA
Save Our Bays and Beaches, Kailua, HI
Save Our Future, Los Angeles, CA
Save Our Youth Arts & Education
Organization, Pasadena, CA
Seattle Kobe Sister City Association,
Seattle, WA
Secular Humanists of Los Angeles, Los
Angeles, CA
See Above Productions, Agoura Hills,
CA
Shirts-N-Skins, Los Angeles, CA
Sibling Communication Network,
Tarzana, CA
Sierra Classic Foundation, Sacramento,
CA
Sigma Tau Educational Foundation,
Mercer Island, WA
Simba-Sis, Pomona, CA
Skating Club of North Carolina Inc.,
Cary, NC
Sober Musicians Fundraiser, Santa
Monica, CA
Sonoma Valley Field of Dreams,
Sonoma, CA
Sonrise Medical Clinic Inc.,
N. Hollywood, CA
South Whittier Community Coordinating
Council, Whittier, CA
Southwest Repertory Theatre at Santa Fe
Inc., Norman, OK
Southwest Shalom Ministries for Women,
Waco, TX
Southwest Sports Inc., Louisville, KY
Sovereign Grace Ministries of Colorado
Inc., Canon City, CO
Space Arts Cener, Inc., Lexington, MA
Spaha, Inc., Saratoga Springs, NY
Spare Parts Theatre, Greensboro, NC
Special Equestrians of the Treasure Coast
Inc., Vero Beach, FL
Special Needs Network, Montrose, CO
Special Therapeutic Equestrian Program,
Greenwood, NE
SPIN Recycling, Provo, UT
Spirit of Truth Foundation, Upper
Marlboro, MD
SPOTInc., Tahlequah, OK
Spoken for Spinal Cord Injury, Madison,
WI
Sprayberry Band Parents Association
Inc., Marietta, GA
Spring Creek Volunteer Fire Association,
Kentwood, LA
Spring Brook Resident Council, Moline,
IL
Spring Hill Z-Bar Ranch Inc., Hays, KS
Spring I S D Education Foundation,
Houston, TX
Spring Lake Centennial Playground
Committee, Spring Lake, NJ
Spring of Life Skills Developers,
Inglewood, CA
Springville Preservation Society,
Springville, AL
Spud Webb Youth Foundation, Dallas,
TX
Square One for Youth, Heath, OH
Squeaky Janitorial Services, Conroe, TX
SS Peter & Pauls Home and School
Association, Boonville, MO
SSOSS Outreach Inc., Hollywood, FL
St. Agape Corporation, Wilmington, DE
St. Barnabas Endowment Foundation,
Chicago, IL
St. Barnard Courthouse Restoration
Corporation, Chalmette, LA
St. Bridgets Educational Foundation,
Minneapolis, MN
St. Charles Chamber of Commerce
Business & Education Foundation,
St. Charles, MO
St. Charles Housing II Inc., Pt. Charlotte,
FL
St. Clouds Area Tenants Union,
St. Cloud, MN
St. Francis County Parents Support
Group, Marianna, AR
St. Francis-St. Joseph Catholic Worker
House, Cincinnati, OH
St. James Housing Trust Inc., San
Antonio, TX
St. John Christian Care Center Inc.,
Oklahoma City, OK
St. John Community Development
Corporation, Camden, NJ
St. Johns County Christian Action
Council Inc., St. Augustine, FL
St. Josephs Home Inc., West Milwaukee,
WI
St. Louis Bicycleworkers Inc., St. Louis,
MO
St. Louis Co. National Steeplechase
Foundation, St. Louis, MO
St. Margaret Shelter Care Inc.,
Minneapolis, MN
St. Mark Outreach Center, Cincinnati,
OH
St. Marthas Senior Care Center,
Claremont, CA
St. Martins Church Foundation Inc.,
Berlin, MD

1998–24 I.R.B.39June 15, 1998
St. Marys Church Hamilton Village,
Philadelphia, PA
St. Marys Housing Development
Corporation, Glendale, AZ
St. Michaels Store, Perryville, MO
St. Oswalds-in-the-Fields Historic
Corporation, Oregon, MO
St. Paul Ciudad Romero Sister City
Project, St. Paul, MN
St. Petersburg Junior Football Athletic
Association Inc., St. Petersburg, FL
St. Petersburg Martin Luther King Jr.
Commemorative Organization Inc.,
St. Petersburg, FL
St. Tammany Community Housing
Resource Board, Slidell, LA
St. Vincent De Paul Society of the
Chippewa Valley Inc., Altoona, WI
Sta-Home Hospice Inc., Carthage, MS
Stacy Lane Art and Nature Center,
Leonard, MI
Stan-Beck Ministries Inc., Abilene, TX
Stand by Me Boys Ranch Inc., Big
Sandy, TX
Standard Bearer Ministries Inc., Zachary,
LA
Stanley Historic Foundation Inc., Estes
Park, CO
Star Foundation for Children, Inc.,
Melrose, MA
Starbright Pavilion Foundation, Los
Angeles, CA
Stark Citizens Opposing Pollution of the
Environment Inc., Massillon, OH
Stark County Emergency and Homeless
Shelter, Canton, OH
Stark County Golf Charities Inc., Canton,
OH
Stark County Out of Poverty Partnership
Incorporated, Canton, OH
State International Performing Arts
Studios Inc., Benton Harbor, MI
Statesville High School Renaissance
Foundation, Statesville, NC
Statewide Parent Association for the
Childrens Effort Inc., E. Orange, NJ
Steele Creek Library Association,
Charlotte, NC
Steelville Area Historical Society,
Steelville, MO
Stenton Arms Complex Tenants Council,
Philadelphia, PA
Step Ahead Inc., Pinellas Park, FL
Step of Faith Inc., St. Petersburg, FL
Stephen House, W. Bend, WI
Stephens County Food Bank Inc.,
Toccoa, GA
Stepping Stone Foundation Inc., Cape
Coral, FL
Sterling Heights Utica Shelby Township
Crime Stoppers Inc., Sterling Hts., MI
Still Hope Ministries Inc., Mount Laurel,
NJ
Stillpoint Ministries Inc., Black
Mountain, NC
Stingray Aquatic Foundation Inc., Miami,
FL
Stormy Weather Productions, Inc., New
York, NY
Stonevale Press Inc., Towson, MD
Stonewall Estates Group Home Inc.,
Fredericksburg, VA
Stopgap Incorporated, Corpus Christi,
TX
Stow Home Bible Study Ministries
Incorporated, Stow, OH
Straight Street Productions Inc., Kennard,
NE
Straightline Ministries Inc., Lansing, MI
Stride Forward Woodlawn Inc.,
Birmingham, AL
Stroke Association of Kentucky Inc.,
Lexington, KY
Strom Thurmond Educational Fund Inc.,
Washington, DC
Stuarts Draft Crime Prevention Council
Inc., Stuarts Draft, VA
Student Alliance, Chicago, IL
Student Benefit and Aid Committee for
Kids of DC Inc., Washington, DC
Student Planning Association Inc.,
Rockwall, TX
If an organization listed above submits
information that warrants the renewal of
its classification as a public charity or as a
private operating foundation, the Internal
Revenue Service will issue a ruling or de-
termination letter with the revised classi-
fication as to foundation status. Grantors
and contributors may thereafter rely upon
such ruling or determination letter as pro-
vided in section 1.509(a)–7 of the Income
Tax Regulations. It is not the practice of
the Service to announce such revised clas-
sification of foundation status in the Inter-
nal Revenue Bulletin.
Section 7428(c) Validation of
Certain Contributions Made
During Pendency of Declaratory
Judgment Proceedings
This announcement serves notice to po-
tential donors that the organization listed
below has recently filed a timely declara-
tory judgment suit under section 7428 of
the Code, challenging revocation of its
status as an eligible donee under section
170(c)(2).
Protection under section 7428(c) of the
Code begins on the date that the notice of
revocation is published in the Internal
Revenue Bulletin and ends on the date on
which a court first determines that an or-
ganization is not described in section
170(c)(2), as more particularly set forth in
section 7428(c)(1). In the case of individ-
ual contributors, the maximum amount of
contributions protected during this period
is limited to $1,000.00, with a husband
and wife being treated as one contributor.
This protection is not extended to any in-
dividual who was responsible, in whole or
in part, for the acts or omissions of the or-
ganization that were the basis for the re-
vocation. This protection also applies
(but without limitation as to amount) to
organizations described in section
170(c)(2) which are exempt from tax
under section 501(a). If the organization
ultimately prevails in its declaratory judg-
ment suit, deductibility of contributions
would be subject to the normal limitations
set forth under section 170.
Fountain of Life, Inc.
Greensboro, NC

June 15, 1998401998–24 I.R.B.
NameAddressDesignationDate of Suspension
Soulides, James C. Berwyn, ILCPAJanuary 1, 1998 to June 30, 2000
Bujan, FrankOrland Park, ILCPAJanuary 1, 1998 to June 30, 2000
Field, Edward L.Topeka, KSCPAJanuary 27, 1998 to April 26, 1999
Cito, Paul J.West Orange, NJCPAFebruary 21, 1998 to May 20, 1999
Sproul, JerryIdaho Falls, IDCPAFebruary 25, 1998 to October 24, 1998
Hunt, RussellPauls Valley, OKCPAMarch 1, 1998 to June 30, 1998
Oertli, WilliamRochester, MNCPAMach 4, 1998 to March 3, 2000
Maynard, RichardReno, NVCPAMarch 10, 1998 to March 9, 2002
McDonald, BillReno, NVAttorneyMarch 10, 1998 to March 9, 2002
Komendant, HowardPassaic, NJCPAMarch 10, 1998 to September 9, 1998
Kwiatek, Fabian A.Silver Spring, MDCPAMarch 16, 1998 to March 15, 2001
Brown, PatriciaDeKalb, ILCPAMarch 16, 1998 to September 15, 1999
Marshall, RobertWoodland Hills, CAAttorneyMarch 18, 1998 to November 17, 2000
Baloun, Donald J.Palatine, ILCPAMarch 25, 1998 to November 24, 1998
Goldman, Harold J.Summit, NJCPAMarch 27 , 1998 to September 26, 1998
Garner, Darrow C.Austin, TXCPAApril 1, 1998 to March 20, 2000
Klein, Charles U.Dunedin, FLCPAApril 1, 1998 to September 30, 1999
Morgan, Robert I.Brownsville, VTAttorneyApril 2, 1998 to April 1, 2000
Teel, Jeffrey J.Hollis, NHCPAApril 2, 1998 to April 1, 2001
Hancock, Randall M.Gardendale, ALCPAIndefinite from April 13, 1998
Allison Jr., Dale A.Blairsville, GAAttorneyApril 15, 1998 to July 14, 2001
Gogel, William A.North Hills, NYAttorneyApril 21, 1998 to April 20, 2002
Bose, GautemOak Brook, ILCPAMay 1, 1998 to April 30, 2001
Woods, W. RexBelleville, KSCPAMay 1, 1998 to January 31, 1999
Monahan, JohnSeattle, WAAttorneyMay 1, 1998 to April 30, 2001
Swartz, Lewis A.Syosset, NYCPAMay 1, 1998 to April 30, 2002
Announcement of the Consent Voluntary Suspension of Attorneys,
Certified Public Accountants, Enrolled Agents, and Enrolled Actuaries
From Practice Before the Internal Revenue Service
Under 31 Code of Federal Regulations,
Part 10, an attorney, certified public ac-
countant, enrolled agent, or enrolled ac-
tuary, in order to avoid the institution or
conclusion of a proceeding for his disbar-
ment or suspension from practice before
the Internal Revenue Service, may offer
his consent to suspension from such prac-
tice. The Director of Practice, in his dis-
cretion, may suspend an attorney, certi-
fied public accountant, enrolled agent, or
enrolled actuary in accordance with the
consent offered.
Attorneys, certified public accountants,
enrolled agents, and enrolled actuaries are
prohibited in any Internal Revenue Ser-
vice matter from directly or indirectly em-
ploying, accepting assistance from, being
employed by, or sharing fees with any
practitioner disbarred or suspended from
practice before the Internal Revenue Ser-
vice.
To enable attorneys, certified public ac-
countants, enrolled agents, and enrolled
actuaries to identify practitioners under
consent suspension from practice before the
Internal Revenue Service, the Director
of Practice will announce in the Internal
Revenue Bulletin the names and ad-
dresses of practitioners who have been
suspended from such practice, their desig-
nation as attorney, certified public ac-
countant, enrolled agent, or enrolled actu-
ary, and date or period of suspension. This
announcement will appear in the weekly
Bulletin at the earliest practicable date
after such action and will continue to ap-
pear in the weekly Bulletins for five suc-
cessive weeks or for as many weeks as is
practicable for each attorney, certified
public accountant, enrolled agent, or en-
rolled actuary so suspended and will be
consolidated and published in the Cumu-
lative Bulletin.
The following individuals have been
placed under consent suspension from
practice before the Internal Revenue Ser-
vice:

1998–24 I.R.B.41June 15, 1998
NameAddressDesignationDate of Suspension
Eckert, Bruce G.Cleveland, OHCPAMay 2, 1998 to May 1, 1999
Rozanski, Lawrence J.Pittsburg, PACPAJune 1, 1998 to May 30, 2000
Mangum, Carl E.Morris Plains, NJCPAJuly 1, 1998 to December 31, 1999
Reeser, Richard M. Thornton, COCPAJuly 1, 1998 to September 30, 1999
Bailey, Thomas O.Dallas, TXCPAJuly 1, 1998 to June 30, 2001
Johnson, Kenneth E.Forest Lake, MNCPAJuly 1, 1998 to November 30, 1999
Deren, JosephLackawanna, NYAttorneyJuly 1, 1998 to June 30, 2001
Under title 31 of the Code of Federal
Regulations, section 10.76, the Director
of Practice is authorized to immediately
suspend from practice before the Internal
Revenue Service any practitioner who,
within five years from the date the expe-
dited proceeding is instituted, (1) has had
a license to practice as an attorney, certi-
fied public accountant, or actuary sus-
pended or revoked for cause; or (2) has
been convicted of any crime under title 26
of the United States Code or, of a felony
under title 18 of the United States Code
involving dishonesty or breach of trust.
Attorneys, certified public accountants,
enrolled agents, and enrolled actuaries are
prohibited in any Internal Revenue Service
matter from directly or indirectly employ-
ing, accepting assistance from, being em-
ployed by, or sharing fees with, any practi-
tioner disbarred or suspended from practice
before the Internal Revenue Service.
To enable attorneys, certified public ac-
countants, enrolled agents, and enrolled ac-
tuaries to identify practitioners under expe-
dited suspension from practice before the
Internal Revenue Service, the Director of
Practice will announce in the Internal Rev-
enue Bulletin the names and addresses of
practitioners who have been suspended
from such practice, their designation as at-
torney, certified public accountant, en-
rolled agent, or enrolled actuary, and date
or period of suspension. This announce-
ment will appear in the weekly Bulletin at
the earliest practicable date after such ac-
tion and will continue to appear in the
weekly Bulletins for five successive weeks
or for as many weeks as is practicable for
each attorney, certified public accountant,
enrolled agent, or enrolled actuary so sus-
pended and will be consolidated and pub-
lished in the Cumulative Bulletin.
The following individual has been
placed under suspension from practice be-
fore the Internal Revenue Service by virtue
of the expedited proceeding provisions of
the applicable regulations:
NameAddressDesignationDate of Suspension
McDonald, MiltonStone Mountain, GAAttorneyIndefinite from February 24, 1998
Parsons, Gary D.Chattanooga, TNCPAIndefinite from February 24, 1998
Buchanan, StevenPhoenix, AZAttorneyIndefinite from February 24, 1998
Caplan, AlanSan Francisco, CAAttorneyIndefinite from February 24, 1998
Delany, R. EmmetRidgefield, CTAttorneyIndefinite from February 24, 1998
Hirsch, SheldonBrooklyn, NYCPAIndefinite from February 24, 1998
Newman, Peter R.Syossett, NYAttorneyIndefinite from February 24, 1998
Land, GaryFayetteville, AREnrolled AgentIndefinite from February 24, 1998
Hunt, William D.Tulsa, OKAttorneyIndefinite from February 24, 1998
Hamilton, RobertCorpus Christie, TXAttorneyIndefinite from February 24, 1998
Rabinowitz, EmileMinnetonka, MNEnrolled AgentIndefinite from February 24, 1998
McCaffrey, MichaelWheaton, ILCPAIndefinite from February 24, 1998
Eisenstein, JoelSt. Charles, MOAttorneyIndefinite from February 24, 1998
Announcement of the Expedited Suspension of Attorneys, Certified Public
Accountants, Enrolled Agents, and Enrolled Actuaries From Practice
Before the Internal Revenue Service

June 15, 1998421998–24 I.R.B.
Cannavo Jr., Joseph S.St. Louis, MOAttorneyIndefinite from February 24, 1998
Tilker, Robert M.Fairfax, VACPAIndefinite from February 24, 1998
Toms, James H.Hendersonville, NCAttorneyIndefinite from February 24, 1998
Everett, KennethNew York, NYAttorneyIndefinite from February 24, 1998
Frederick, CharlesElk GroveEnrolled AgentIndefinite from March 13, 1998
Artho, DavidLubbock, TXCPAIndefinite from March 18, 1998
Seale, Forrest I.San Antonio, TXCPAIndefinite from March 18, 1998
Yancey, Quinton E.Stephens City, VACPAIndefinite from March 18, 1998
Hunnicut, BenjaminReseda, CACPAIndefinite from March 18, 1998
Finkel, MerleBeverly Hills, CACPAIndefinite from March 18, 1998
Mullay, Carl P.Swoyersville, PACPAIndefinite from March 18, 1998
Cunning, Dennis A.Molalla, ORCPAIndefinite from March 18, 1998
Adamson, Steven A.Nampa, IDAttorneyIndefinite from April 14, 1998
Bowman, David W.Colorado Springs, COAttorneyIndefinite from April 21, 1998
Beezley, Jack L.Dallas, TXAttorneyIndefinite from April 21, 1998
Cunningham, AndrewHatfield, PACPAIndefinite from April 28, 1998
Palmquist, Craig S.Seattle, WAAttorneyIndefinite from April 21, 1998
Ross, Mark J.Columbus, OHAttorneyIndefinite from April 21, 1998
Madoch, LawrenceElgin, ILCPAIndefinite from April 21, 1998
Taylor, George M.Springfield, ILAttorneyIndefinite from April 21, 1998
Casey, Kenneth J.Corte Madera, CACPAIndefinite from April 21, 1998
Akolt III, John P.Denver, COAttorneyIndefinite from April 21, 1998
Dowdy, FrankHuntsville, ALCPAIndefinite from April 28, 1998
Eckert, Bruce G.Cleveland, OHCPAMay 2, 1998 to May 1, 1999
Rozanski, Lawrence J.Pittsburgh, PACPAJune 1, 1998 to May 30, 2000
Mangum, Carl E.Morris Plains, NJCPAJuly 1, 1998 to December 31, 1999
Reeser, Richard M. Thornton, COCPAJuly 1, 1998 to September 30, 1999
Bailey, Thomas O.Dallas, TXCPAJuly 1, 1998 to June 30, 2001
Johnson, Kenneth E.Forest Lake, MNCPAJuly 1, 1998 to November 30, 1999
Deren, JosephLackawanna, NYAttorneyJuly 1, 1998 to June 30, 2001
NameAddressDesignationDate of Suspension

1998–24 I.R.B.43June 15, 1998
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus,
if an earlier ruling held that a principle
applied to A, and the new ruling holds
that the same principle also applies to B,
the earlier ruling is amplified. (Compare
with modified, below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously
published ruling and points out an essen-
tial difference between them.
Modified is used where the substance
of a previously published position is
being changed. Thus, if a prior ruling
held that a principle applied to A but not
to B, and the new ruling holds that it ap-
plies to both A and B, the prior ruling is
modified because it corrects a published
position. (Compare with amplified and
clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used
in a ruling that lists previously published
rulings that are obsoleted because of
changes in law or regulations. A ruling
may also be obsoleted because the sub-
stance has been included in regulations
subsequently adopted.
Revoked describes situations where the
position in the previously published rul-
ing is not correct and the correct position
is being stated in the new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a pe-
riod of time in separate rulings. If the
new ruling does more than restate the
substance of a prior ruling, a combination
of terms is used. For example, modified
and superseded describes a situation
where the substance of a previously pub-
lished ruling is being changed in part and
is continued without change in part and it
is desired to restate the valid portion of
the previously published ruling in a new
ruling that is self contained. In this case
the previously published ruling is first
modified and then, as modified, is super-
seded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and
that list is expanded by adding further
names in subsequent rulings. After the
original ruling has been supplemented
several times, a new ruling may be pub-
lished that includes the list in the original
ruling and the additions, and supersedes
all prior rulings in the series.
Suspended is used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current use and for-
merly used will appear in material published in the
Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C.—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contribution Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign Corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statements of Procedral Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Definition of Terms

June 15, 1998441998–24 I.R.B.
1
See footnote at end of list.
Numerical Finding List
1
Bulletins 1998–1 through 1998–23
Announcements:
98–1, 1998–2 I.R.B. 38
98–2, 1998–2 I.R.B.38
98–3, 1998–2 I.R.B.38
98–4, 1998–4 I.R.B.31
98–5, 1998–5 I.R.B. 25
98–6, 1998–5 I.R.B. 25
98–7, 1998–5 I.R.B. 26
98–8, 1998–6 I.R.B. 96
98–9, 1998–7 I.R.B. 35
98–10, 1998–7 I.R.B. 35
98–11, 1998–8 I.R.B. 42
98–12, 1998–8 I.R.B. 43
98–13, 1998–8 I.R.B. 43
98–14, 1998–8 I.R.B. 44
98–15, 1998–10 I.R.B.36
98–16, 1998–9 I.R.B. 17
98–17, 1998–9 I.R.B. 16
98–18, 1998–10 I.R.B.44
98–19, 1998–10 I.R.B.44
98–20, 1998–11 I.R.B. 25
98–21, 1998–11 I.R.B. 26
98–22, 1998–12 I.R.B. 33
98–23, 1998–12 I.R.B. 34
98–24, 1998–12 I.R.B. 35
98–25, 1998–13 I.R.B.43
98–26, 1998–14 I.R.B. 28
98–27, 1998–15 I.R.B. 30
98–28, 1998–15 I.R.B. 30
98–29, 1998–16 I.R.B. 48
98–30, 1998–17 I.R.B. 38
98–32, 1998–17 I.R.B. 39
98–33, 1998–17 I.R.B. 39
98–34, 1998–17 I.R.B. 39
98–35, 1998–17 I.R.B. 40
98–36, 1998–18 I.R.B. 18
98–37, 1998–19 I.R.B. 24
98–38, 1998–19 I.R.B. 26
98–39, 1998–20 I.R.B.24
98–40, 1998–20 I.R.B. 24
98–41, 1998–20 I.R.B. 25
98–42, 1998–21 I.R.B. 26
98–43, 1998–21 I.R.B. 26
98–44, 1998–22 I.R.B. 24
98–45, 1998–23 I.R.B. 18
98–47, 1998–23 I.R.B. 5
98–49, 1998–23 I.R.B. 19
98–50, 1998–23 I.R.B. 20
Notices:
98–1, 1998–3 I.R.B. 42
98–2, 1998–2 I.R.B. 22
98–3, 1998–3 I.R.B. 48
98–4, 1998–2 I.R.B. 25
98–5, 1998–3 I.B.R.49
98–6, 1998–3 I.R.B. 52
98–7, 1998–3 I.R.B. 54
98–8, 1998–4 I.R.B. 6
98–9, 1998–4 I.R.B. 8
98–10, 1998–6 I.R.B.9
98–11, 1998–6 I.R.B. 18
98–12, 1998–5 I.R.B.12
98–13, 1998–6 I.R.B.19
98–14, 1998–8 I.R.B. 27
98–15, 1998–9 I.R.B. 8
98–16, 1998–15 I.R.B. 12
98–17, 1998–11 I.R.B. 6
98–18, 1998–12 I.R.B. 11
Notices—Continued
98–19, 1998–13 I.R.B.24
98–20, 1998–13 I.R.B.25
98–21, 1998–15 I.R.B. 14
98–22, 1998–17 I.R.B. 5
98–23, 1998–18 I.R.B. 9
98–24, 1998–17 I.R.B. 5
98–25, 1998–18 I.R.B. 11
98–26, 1998–18 I.R.B. 14
98–27, 1998–18 I.R.B. 14
98–28, 1998–19 I.R.B.7
98–29, 1998–22 I.R.B.8
98–30, 1998–22 I.R.B. 9
98–31, 1998–22 I.R.B. 10
98–32, 1998–22 I.R.B. 23
Proposed Regulations:
PS–158–86, 1998–11 I.R.B. 13
REG–100841–97, 1998–8 I.R.B. 30
REG–102144–98, 1998–15 I.R.B.25
REG–102894–97, 1998–3 I.R.B. 59
REG–104062–97, 1998–10 I.R.B. 34
REG–104537–97, 1998–16 I.R.B. 21
REG–104691–97, 1998–11 I.R.B. 13
REG–105163–97, 1998–8 I.R.B. 31
REG–109333–97, 1998–9 I.R.B. 9
REG–109704–97, 1998–3 I.R.B. 60
REG–110965–97, 1998–13 I.R.B. 42
REG–115795–97, 1998–8 I.R.B.33
REG–119449–97, 1998–10 I.R.B. 35
REG–120200–97, 1998–12 I.R.B. 32
REG–120882–97, 1998–14 I.R.B. 25
REG–121268–97, 1998–20 I.R.B. 12
REG–121755–97, 1998–9 I.R.B. 13
REG–208299–90, 1998–16 I.R.B. 26
REG–209276–87, 1998–11 I.R.B. 18
REG–209322–82, 1998–15 I.R.B. 26
REG–209373–81, 1998–14 I.R.B. 26
REG–209463–82, 1998–4 I.R.B. 27
REG–209476–82, 1998–8 I.R.B. 36
REG–209484–87, 1998–8 I.R.B.40
REG–209485–86, 1998–11 I.R.B. 21
REG–209682–94, 1998–17 I.R.B. 20
REG–209807–95, 1998–8 I.R.B. 40
REG–243025–96, 1998–18 I.R.B. 18
REG–251502–96, 1998–9 I.R.B. 14
REG–251698–96, 1998–20 I.R.B. 14
Revenue Procedures:
98–1, 1998–1 I.R.B. 7
98–2, 1998–1 I.R.B. 74
98–3, 1998–1 I.R.B. 100
98–4, 1998–1 I.R.B. 113
98–5, 1998–1 I.R.B. 155
98–6, 1998–1 I.R.B. 183
98–7, 1998–1 I.R.B. 222
98–8, 1998–1 I.R.B. 225
98–9, 1998–3 I.R.B. 56
98–10, 1998–2 I.R.B. 35
98–11, 1998–4 I.R.B.9
98–12, 1998–4 I.R.B. 18
98–13, 1998–4 I.R.B. 21
98–14, 1998–4 I.R.B. 22
98–15, 1998–4 I.R.B. 25
98–16, 1998–5 I.R.B. 19
98–17, 1998–5 I.R.B. 21
98–18, 1998–6 I.R.B. 20
98–19, 1998–7 I.R.B. 30
98–20, 1998–7 I.R.B. 32
98–21, 1998–8 I.R.B. 27
Revenue Procedures—Continued
98–22, 1998–12 I.R.B. 11
98–23, 1998–10 I.R.B. 30
98–24, 1998–10 I.R.B. 31
98–25, 1998–11 I.R.B. 7
98–26, 1998–13 I.R.B.26
98–27, 1998–15 I.R.B.15
98–28, 1998–15 I.R.B.14
98–29, 1998–15 I.R.B. 22
98–30, 1998–17 I.R.B. 6
98–31, 1998–23 I.R.B. 9
98–32, 1998–17 I.R.B. 11
98–33, 1998–19 I.R.B. 7
98–34, 1998–18 I.R.B. 15
98–35, 1998–21 I.R.B. 6
98–36, 1998–23 I.R.B. 10
Revenue Rulings:
98–1, 1998–2 I.R.B. 5
98–2, 1998–2 I.R.B. 15
98–3, 1998–2 I.R.B. 4
98–4, 1998–2 I.R.B. 18
98–5, 1998–2 I.R.B. 20
98–6, 1998–4 I.R.B. 4
98–7, 1998–6 I.R.B.6
98–8, 1998–7 I.R.B. 24
98–9, 1998–6 I.R.B. 5
98–10, 1998–10 I.R.B. 11
98–11, 1998–10 I.R.B. 13
98–12, 1998–10 I.R.B. 5
98–13, 1998–11 I.R.B. 4
98–14, 1998–11 I.R.B. 4
98–15, 1998–12 I.R.B. 6
98–16, 1998–13 I.R.B. 18
98–17, 1998–13 I.R.B. 21
98–18, 1998–14 I.R.B. 22
98–19, 1998–15 I.R.B. 5
98–20, 1998–15 I.R.B. 8
98–21, 1998–18 I.R.B. 7
98–22, 1998–19 I.R.B.5
98–23, 1998–18 I.R.B. 5
98–24, 1998–19 I.R.B. 6
98–25, 1998–19 I.R.B.4
98–26, 1998–21 I.R.B. 4
98–27, 1998–22 I.R.B. 4
98–28, 1998–22 I.R.B. 5
Treasury Decisions:
8740, 1998–3 I.R.B. 4
8741, 1998–3 I.R.B. 6
8742, 1998–5 I.R.B.4
8743, 1998–7 I.R.B. 26
8744, 1998–7 I.R.B. 20
8745, 1998–7 I.R.B. 15
8746, 1998–7 I.R.B. 4
8747, 1998–7 I.R.B. 18
8748, 1998–8 I.R.B. 24
8749, 1998–7 I.R.B. 16
8750, 1998–8 I.R.B. 4
8751, 1998–10 I.R.B. 23
8752, 1998–9 I.R.B. 4
8753, 1998–9 I.R.B. 6
8754, 1998–10 I.R.B. 15
8755, 1998–10 I.R.B. 21
8756, 1998–12 I.R.B.4
8757, 1998–13 I.R.B.4
8758, 1998–13 I.R.B. 15
8759, 1998–13 I.R.B. 19
8760, 1998–14 I.R.B. 4
8761, 1998–14 I.R.B. 13
8762, 1998–14 I.R.B. 15

1998–24 I.R.B.45June 15, 1998
Numerical Finding List—Continued
Bulletins 1998–1 through 1998–23
Treasury Decisions—Continued
8763, 1998–15 I.R.B. 5
8764, 1998–15 I.R.B. 9
8765, 1998–16 I.R.B. 11
8766, 1998–16 I.R.B. 17
8767, 1998–16 I.R.B. 4
8768, 1998–20 I.R.B.4
1
A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 1997–27 through
1997–52 will be found in Internal Revenue Bulletin
1998–1, dated January 5, 1998.

June 15, 1998461998–24 I.R.B.
Finding List of Current Action on
Previously Published Items
1
Bulletins 1998–1 through 1998–23
Revenue Procedures:
91–59
Updated and superseded by
98–25, 1998–11 I.R.B. 7
94–16
Modified and superseded by
98–22, 1998–12 I.R.B. 11
93–62
Modified and superseded by
98–22, 1998–12 I.R.B. 11
95–35
95–35A
Superseded by
98–19, 1998–7 I.R.B. 30
96–29
Modified and superseded by
98–22, 1998–12 I.R.B. 11
97–1
Superseded by
98–1, 1998–1 I.R.B. 7
97–2
Superseded by
98–2, 1998–1 I.R.B. 74
97–3
Superseded by
98–3, 1998–1 I.R.B. 100
97–4
Superseded by
98–4, 1998–1 I.R.B. 113
97–5
Superseded by
98–5, 1998–1 I.R.B. 155
97–6
Superseded by
98–6, 1998–1 I.R.B. 183
97–7
Superseded by
98–7, 1998–1 I.R.B. 222
97–8
Superseded by
98–8, 1998–1 I.R.B. 225
97–21
Superseded by
98–2, 1998–1 I.R.B. 74
97–24
97–24A
Superseded by
98–33, 1998–19 I.R.B. 7
97–26
Obsoleted by
98–28, 1998–15 I.R.B. 14
97–28
Superseded by
98–36, 1998–23 I.R.B. 10
97–34
Superseded by
98–35, 1998–21 I.R.B. 6
Revenue Procedures—Continued
97–53
Superseded by
98–3, 1998–1 I.R.B. 100
Revenue Rulings:
68–352
Obsoleted by
98–24, 1998–19 I.R.B. 6
70–225
Modified by
98–27, 1998–22 I.R.B. 4
73–198
Modified by
98–24, 1998–19 I.R.B. 6
75–17
Supplemented and superseded by
98–5, 1998–2 I.R.B. 20
75–406
Obsoleted by
98–27, 1998–22 I.R.B. 4
92–19
Supplemented in part by
98–2, 1998–2 I.R.B. 15
96–30
Obsoleted by
98–27, 1998–22 I.R.B. 4
1
A cumulative finding list for previously published
items mentioned in Internal Revenue Bulletins
1997–27 through 1997–52 will be found in Internal
Revenue Bulletin 1998–1, dated January 5, 1998.

INTERNAL REVENUE BULLETIN
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