Internal Revenue Bulletin 1997-26 (PDF rendition): IRS Announcements

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

INCOME TAX
Notice 97–36, page 6.
Net operating losses; specified liability losses.Taxpay-
ers are informed that the characterization of certain net
operating losses as specified liability losses under Code
section 172(f) is improper, and that the Ser vice will
closely scrutinize claims for refund and applications for
tentative carr yback adjustments that are attributed to
specified liability losses.
EXEMPT ORGANIZATIONS
Announcement 97–63, page 8.
A list is given of organizations now classified as private
foundations.
Announcement 97–65, page 9.
The Christian Home Endowment Foundation, Wilmington,
DE, no longer qualifies as an organization to which
contributions are deductible under section 170 of the
Code.
Announcement 97–66, page 9.
Announcement 97–54, 1997–22 I.R.B. 23, regarding the
names of organizations that no longer qualify as organi-
zations described in section 170(c)(2) of the Code, is
corrected.
EMPLOYMENT TAX
T.D. 8721, page 4.
Final regulations under section 3406 of the Code relate
to the establishment of Taxpayer Identification Number
(TIN) matching programs and remove the temporar y
regulations pertaining to the establishment of the TIN
matching program.
ADMINISTRATIVE
Rev. Proc. 97–31, page 6.
TIN matching; backup withholding.Procedures are
provided under which federal agencies may submit the
payee name and taxpayer identification number combina-
tions. The Ser vice will inform the agency whether the
names and TINs match the information in the Ser vice’s
database for this program.
Announcement 97–64, page 9.
This announcement clarifies the 1997 Form W–2 instruc-
tions for reporting employer-provided adoption benefits.
Finding Lists begin on page 14.
Announcement of Disbarments and Suspensions begins on page 10.
Bulletin No. 1997–26
June 30, 1997
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be relied
upon as authoritative interpretations.

Mission of the Service
The purpose of the Internal Revenue Ser vice is to
collect the proper amount of tax revenue at the least
cost; ser ve the public by continually improving the
quality of our products and ser vices; and per form in a
manner warranting the highest degree of public
confidence in our integrity, efficiency, and fairness.
Statement of Principles
of Internal Revenue
Tax Administration
The function of the Internal Revenue Ser vice is to
administer the Internal Revenue Code. Tax policy
for raising revenue is determined by Congress.
With this in mind, it is the duty of the Ser vice to
carr y out that policy by correctly applying the laws
enacted by Congress; to determine the reasonable
meaning of various Code provisions in light of the
Congressional purpose in enacting them; and to
per form 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
Ser vice, charged with the duty of interpreting the
law, to tr y to find the true meaning of the statutor y
provision and not to adopt a strained construction in
the belief that he or she is ‘‘protecting the revenue.’’
The revenue is properly protected only when we as-
certain and apply the true meaning of the statute.
The Ser vice also has the responsibility of applying
andadministeringthelawinareasonable,
practical manner. Issues should only be raised by
examining of ficers when they have merit, never
arbitrarily or for trading purposes. At the same
time, the examining officer should never hesitate
to raise a meritorious issue. It is also important
that care be exercised not to raise an issue or to
ask a court to adopt a position inconsistent with
an established Ser vice position.
Administration should be both reasonable and
vigorous. It should be conducted with as little
delay as possible and with great cour tesy and
considerateness. It should never tr y to overreach,
and should be reasonable within the bounds of law
and sound administration. It should, however, be
vigorous in requiring compliance with law and it
should be relentless in its attack on unreal tax
devices and fraud.
2

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

Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
Section 3406.—Backup
Withholding
26 CFR 31.3406(j)–1: Taxpayer Identification
Number (TIN) matching program.
T.D. 8721
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Parts 31 and 35a
Taxpayer Identification Number
(TIN) Matching Program
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final and temporary regula-
tions.
SUMMARY: This document contains fi-
nal regulations on the establishment of
Taxpayer Identification Number (TIN)
matching programs and removes the
temporary regulations on the establish-
ment of a TIN matching program. These
regulations reflect changes to the law
made by the Interest and Dividend Tax
Compliance Act of 1983. They affect
payors, brokers, and payees of certain
reportable payments and provide guid-
ance necessary to comply with the law.
DATES: These regulations are effective
June 18, 1997.
FORFURTHERINFORMATION
CONTACT: Renay France, (202) 622–
6232 (not a toll-free call).
SUPPLEMENTARY INFORMATION:
Background
On March 22, 1994, the Internal
Revenue Service (IRS) published pro-
posed (IA–8–92[1994–1 C.B. 795]) and
temporary regulations (T.D. 8523 [1994–
1 C.B. 271]) in theFederal Register
(59 FR 13470 and 13455, respectively)
for the establishment of a TIN matching
program (the matching program) by the
Commissioner. The proposed regulations
would allow payors to check the accu-
racy of a name/TIN combination before
filing the related information return. The
proposed regulations solicited written
comments and set a date for a public
hearing on the regulations. No one re-
quested to speak at the hearing; there-
fore, none was held.
The proposed regulations provide that
a payor’s decision whether to participate
in the matching program and any match-
ing details received through the match-
ing program are not taken into account
in determining whether a payor has
reasonable cause under section 6724(a)
that will avoid a penalty under section
6721(a) for the failure to file a correct
information return or under section 6722
for the failure to furnish a correct payee
statement. Several commentators sug-
gested that if a payor submits a name/
TIN combination under the matching
program and is not informed by the IRS
that the TIN is incorrect, the payor will
have established reasonable cause under
section 6724(a) should the IRS later
determine that the same TIN filed on a
subsequent information return is incor-
rect. In response to the comment, the
final regulations provide that neither a
payor’s nonparticipation in a matching
program nor the results obtained from
participating in a matching program will
adversely affect the payor’s reasonable
cause defense and that the extent to
which a payor may establish reasonable
cause by participating in a TIN match-
ing program will be set forth in the
guidance establishing the program.
Additional comments suggested modi-
fication of IRS information returns
(Forms 1099). A modified form would
allow a payor to indicate that it con-
tacted the IRS for matching of the
name/TIN combination on the informa-
tion return and was not informed that
the name/TIN combination was incor-
rect. The IRS will consider the feasibil-
ity of adopting this suggestion when a
TIN matching program is established.
The Prototype
On May 9, 1994, the IRS instituted a
two-year prototype of an online TIN
matching program to test its operational
feasibility on a nationwide basis. The
prototype permitted a maximum of 200
payors of reportable payments, as de-
fined in section 3406(b)(1), to volunteer
to participate in the prototype and have
their payees’ name/TIN combinations
matched with records of the IRS prior to
filing the related information return. The
prototype operated for only eleven
months; a fire destroyed the computer
system dedicated to this project. During
the operation of the prototype approxi-
mately 120 payors made 55,795 name/
TIN inquiries.
Due to fiscal constraints, the IRS has
no current plans to implement a TIN
matching program that will be available
to all payors of reportable payments and
has no current plans to replace the
destroyed computer system needed to
implement an online TIN matching pro-
gram.
Explanation of Provisions
The final regulations permit the IRS
to establish varied matching programs
by published guidance as circumstances
warrant. In general, under a matching
program, a participating payor of a
reportable payment (as defined in sec-
tion 3406(b)(1) of the Internal Revenue
Code) may, prior to filing an informa-
tion return, contact the IRS concerning
the TIN furnished by a payee. Upon
receiving the inquiry, the IRS will in-
form the payor whether or not the
name/TINcombinationfurnished
matches any name/TIN combination
maintained by the IRS. (Informing a
payor of a nonmatch will not constitute
a notice to commence backup withhold-
ing under section 3406(a)(1)(B) due to
an incorrect name/TIN combination.) If
the name/TIN combination does not
match, the payor has the opportunity to
contact the payee for correction before
filing an information return, thus reduc-
ing the likelihood that the payor will be
notified to start backup withholding un-
der section 3406(a)(1)(B). In order to
assist a payor to obtain correct name/
TIN combinations, a particular matching
program may categorize nonmatching
name/TIN combinations. For example,
the matching program may indicate that
the TIN is assigned to another name in
the data base being used or that the TIN
is not assigned in the data base being
used.
Pursuant to the authority contained in
the final regulations, the IRS will imple-
ment a TIN matching program for fed-
eral agencies. This program will allow
federal agencies to request that the IRS
match the name/TIN combinations of
vendors to whom the agencies make
payments reportable under section 6041.
The operational details of this matching
program are set forth in Revenue Proce-
dure 97–31, appearing in the Internal
Revenue Bulletin 1997–26, dated June
30, 1997.
Special Analyses
It has been determined that this Trea-
sury decision is not a significant regula-
tory action as defined in EO 12866.
Therefore, a regulatory assessment is not
required. It also has been determined
June 30, 1997
41997–26 I.R.B.

that section 553(b) of the Administrative
Procedure Act (5 U.S.C. chapter 5) does
not apply to these regulations, and be-
cause the notice of proposed rulemaking
preceding the regulations was issued
prior to March 29, 1996, the Regulatory
Flexibility Act (5 U.S.C. chapter 6) does
not apply. Pursuant to section 7805(f) of
the Internal Revenue Code, the IRS
submitted the notice of proposed
rulemaking preceding these regulations
to the Chief Counsel for Advocacy of
the Small Business Administration for
comment on their impact on small busi-
ness.
Drafting Information
The principal author of these regula-
tions is Renay France, Office of the
Assistant Chief Counsel (Income Tax
and Accounting), IRS. However, other
personnel from the IRS and Treasury
Department participated in their devel-
opment.
*****
Adoption of Amendments to the Regula-
tions
Accordingly, 26 CFR parts 31 and
35a are amended as follows:
PART 31—EMPLOYMENT TAXES
AND COLLECTION OF INCOME
TAX AT SOURCE
Paragraph 1. The authority citation
for part 31 is amended by adding the
following entry in numerical order to
read as follows:
Authority: 26 U.S.C. 7805 * * *
Section 31.3406(j)–1 also issued under
26 U.S.C. 3406(i). * * *
Par. 2. Section 31.3406(j)–1 is added
to subpart E to read as follows:
§ 31.3406(j)–1 Taxpayer Identification
Number (TIN) matching program.
(a)The matching program.Under
section 3406(i), the Commissioner has
the authority to establish Taxpayer Iden-
tification Number (TIN) matching pro-
grams. The Commissioner may prescribe
in a revenue procedure (see § 601.601-
(d)(2) of this chapter) or other appropri-
ate guidance the scope of and the terms
and conditions of participating in any
TIN matching program. In general, un-
der a matching program, prior to filing
information returns with respect to re-
portable payments as defined under sec-
tion 3406(b)(1), a payor of those report-
able payments who is entitled to
participate in the matching program may
contact the Internal Revenue Service
(IRS) with respect to the TIN furnished
by a payee who has received or is likely
to receive a reportable payment. The
IRS will inform the payor whether or
not a name/TIN combination furnished
by the payee matches a name/TIN com-
bination maintained in the data base
utilized for the particular matching pro-
gram.
(b)Notice of incorrect TIN.No
matching details received by a payor
through a matching program will
constitute a notice regarding an in-
correct name/TIN combination under
§ 31.3406(d)–5(c) for purposes of im-
posing backup withholding under sec-
tion 3406(a)(1)(B).
(c)Application of section 3406(f).
The provisions of section 3406(f), relat-
ing to confidentiality of information,
apply to any matching details received
by a payor through the matching pro-
gram. A payor may not take into ac-
count any such matching details in de-
termining whether to open or close an
account with a payee.
(d)Reasonable cause.The IRS will
not use either a payor’s decision not to
participate in an available TIN matching
program or the results received by a
payor from participation in a TIN
matching program implemented under
the authority of this section as a basis to
assert that the payor lacks reasonable
cause under section 6724(a) for the
failure to file an information return
under section 6721 or to furnish a
correct payee statement under section
6722. If the establishment of reasonable
cause may be relevant to a substantial
number of the participants in a TIN
matching program implemented under
the authority of this section, the extent
to which, if any, a payor may establish
reasonable cause by participating in the
TIN matching program will be set forth
in the guidance establishing the pro-
gram.
(e)Definition of account.Account
means any account, instrument, or other
relationship with a payor and with re-
spect to which a payor has made or is
likely to make a reportable payment as
defined in section 3406(b)(1).
(f)Effective date. The provisions of
this section are effective on and after
June 18, 1997.
PART 35a—TEMPORARY
EMPLOYMENT TAX REGULATIONS
UNDER THE INTEREST AND
DIVIDEND TAX COMPLIANCE ACT
OF 1983
Par. 3. The authority citation for part
35a is amended by removing the entry
for § 35a.3406–3 to read in part as
follows:
Authority: 26 U.S.C. 7805. * * *
§ 35a.3406–3 [Removed]
Par. 4. Section 35a.3406–3 is re-
moved.
Margaret Milner Richardson,
Commissioner of Internal Revenue.
Donald C. Lubick,
Acting Assistant Secretary of the
Treasury.
(Filed by the Office of the Federal Register on
June 18, 1997, 8:45 a.m., and published in the
issue of the Federal Register for 62 F.R. 33008)
1997–26 I.R.B.5June 30, 1997

Part III. Administrative, Procedural, and Miscellaneous
Specified Liability Losses
Notice 97–36
This notice addresses the improper
characterization by some taxpayers of
net operating losses as specified liability
losses under § 172(f)(1)(B)(i) of the
Internal Revenue Code. In addition, this
notice informs taxpayers that the Inter-
nal Revenue Service will closely scruti-
nize claims for refund and applications
for tentative carryback adjustments un-
der § 6411(a) that the taxpayer at-
tributes to a specified liability loss under
§ 172(f)(1). Claims for refund filed on
Form 1120X, Amended U.S. Corpora-
tion Income Tax Return, after June 11,
1997, must identify the specific type of
specified liability loss claimed.
Section 172(a) permits a deduction
for a taxpayer’s net operating loss car-
ryovers and carrybacks. Section 172(b)-
(1)(A)(i) generally allows a net operat-
ing loss to be carried back up to 3
taxable years preceding the taxable year
of the loss (the ‘‘loss year’’). However,
§ 172(b)(1)(C) generally allows the por-
tion of a net operating loss qualifying as
a specified liability loss to be carried
back up to 10 taxable years preceding
the loss year.
Section172(f)(1)(B)(i)includes
within the term ‘‘specified liability loss’’
the portion of a net operating loss
attributable to an amount allowable as a
deduction under Chapter 1 of the Code
with respect to a liability arising out of
a federal or state law if the act (or
failure to act) giving rise to the liability
occurs at least 3 years before the begin-
ning of the loss year (the ‘‘3-year act
requirement’’).
The Service has received income tax
refund claims based on the carryback of
amounts purported to be specified liabil-
ity losses that rely on incorrect interpre-
tations of § 172(f)(1)(B)(i). These
claims inappropriately treat as specified
liability losses amounts attributable to
routine current year costs. For example,
some taxpayers interpret the 3-year act
requirement to be satisfied if they can
identify a connection between the liabil-
ity and any act (or failure to act)
occurring at least 3 years before the loss
year, no matter how remote the connec-
tion between the liability and the act.
Thus, they claim that current year costs,
such as auditing fees incurred to comply
with federal securities law requirements
to file independently certified annual
financial statements, are specified liabil-
ity losses. The premise of the claim is
that the act giving rise to these annual
fees was the corporation’s first public
stock offering, which caused the corpo-
ration to become subject to federal secu-
rities laws, and this act occurred at least
3 years before the loss year.
The Service believes that interpreting
the specified liability loss provisions in
this manner is plainly contrary to the
intent and purpose of § 172(f)(1)(B)(i),
and that expenses such as those de-
scribed above do not give rise to speci-
fied liability losses. The Treasury De-
partment and the Service intend to issue
regulations that will address the require-
ments of § 172(f)(1)(B). In addition, the
Service will closely scrutinize claims for
refund and applications for tentative
carryback adjustments under § 6411(a)
that the taxpayer attributes to a specified
liability loss under § 172(f)(1)(B). A
taxpayer that files Form 1120X after
June 11, 1997, to claim a refund based,
in whole or in part, on the carryback of
any specified liability loss must identify,
in Part II of the form, the portion of the
loss attributable to a product liability
and the portion attributable to a federal
or state law or tort liability.
DRAFTINGINFORMATION: The
principal author of this notice is Forest
Boone of the Office of Assistant Chief
Counsel (Income Tax and Accounting).
For further information regarding this
notice, contact Mr. Boone at (202) 622–
4960 (not a toll-free call).
26 CFR 601.602: Tax forms and instructions.
(Also Part I, Section 3406; 31.3406(d)–5.)
Rev. Proc. 97–31
SECTION 1. PURPOSE
This revenue procedure sets forth pro-
cedures for the Federal Agency TIN
Matching Program (Program). Under the
Program, a participating federal agency
may, prior to filing an information re-
turn with respect to a payee, submit to
the Internal Revenue Service the Tax-
payer Identification Number (TIN) fur-
nished by the payee. The Service then
will inform the agency whether or not
the name/TIN combination furnished by
the payee matches a name/TIN combi-
nation maintained by the Service in the
data base utilized for the Program. The
Program is intended to reduce the num-
ber of notices of an incorrect name/TIN
combination issued under § 31.3406(d)–
5(c) of the Employment Tax Regulations
for backup withholding purposes under
section 3406(a)(1)(B) of the Internal
Revenue Code.
SECTION 2. BACKGROUND
.01 Section 3406(a)(1) provides that
backup withholding applies when a re-
portable payment is made to an account
if either:
(1) the payor has not received the
payee’s TIN at the time of the payment,
or
(2) the TIN furnished by the payee
to the payor has been determined to be
incorrect and the payee has not fur-
nished the correct TIN in a timely
manner.
.02 Section 31.3406(j)–1(a) provides
that the Commissioner has the authority
to establish TIN matching programs and
may prescribe by revenue procedure or
other guidance the terms and conditions
for participating in such a program.
.03 Section 31.3406(j)–1(b) provides
that no matching details received by a
payor through a TIN matching program
will constitute a notice regarding an
incorrect name/TIN combination under
§ 31.3406(d)–5(c).
.04 Section 31.3406(j)–1(c) provides
that § 3406(f), relating to confidentiality
of information, applies to any matching
details received by a payor through a
TIN matching program. A payor may
not take into account any such matching
details in determining whether to open
or close an account with a payee.
SECTION 3. DEFINITIONS
.01 The term ‘‘agency’’ means a fed-
eral agency that files information returns
reflecting reportable payments made by
that agency.
.02 The term ‘‘participant’’ means an
agency that has been accepted to partici-
pate in the Program.
.03 The term ‘‘payee’’ means a per-
son with respect to whom a reportable
payment (as defined in § 3406(b)(1))
has been made or is likely to be made
by an agency.
.04 The term ‘‘account’’ means any
account, instrument, or other relation-
ship with a payee (such as a contract)
with respect to which an agency has
made or is likely to make a reportable
payment.See§ 31.3406(j)–1(e).
.05 For purposes of this revenue pro-
cedure, the term ‘‘TIN’’ means the Tax-
June 30, 1997
61997–26 I.R.B.

payer Identification Number of a payee
that is either an Employer Identification
Number (EIN), a Social Security Num-
ber (SSN), or an IRS Individual Tax-
payer Identification Number (ITIN).
SECTION 4. SCOPE
This revenue procedure applies only
to agencies that have applied and been
accepted to participate in the Program
under section 5 of this revenue proce-
dure. Agencies may submit data only
after being accepted as participants in
the Program. Further, participants may
submit name/TIN data only with respect
to account payments made on or after
January 1, 1997. Publication 2108,
Specifications for Federal Agencies, TIN
Matching Program, contains the format
and processing specifications for trans-
mitting the name/TIN data and the pro-
cedures for operation of the Program.
The Program does not permit online or
other direct access by a participant to
Service or Social Security Administra-
tion databases.
SECTION 5. APPLICATION AND
ACCEPTANCE
.01Memorandum of Understanding.
To apply to participate in the Program,
an agency must submit two completed
copies of the form Memorandum of
Understanding (MOU), as provided in
Publication 2108, setting forth its under-
standing of, and agreement to comply
with, the requirements of section 6 of
this revenue procedure. The completed
MOU must include the name of the
agency and the name, address, and tele-
phone number of a contact person. The
MOU must be signed by a duly autho-
rized representative of the agency.
.02Address for submitting MOU.The
completed copies of the MOU must be
submitted by the agency to:
Internal Revenue Service
Office of Payer Compliance
CP:EX:ST:PC
1111 Constitution Ave., NW
Washington, DC 20224
.03Acceptance.If an agency is ac-
cepted to participate in the Program, the
Service will return one signed copy of
the MOU to the agency and assign the
agency a Transmitter Control Code
(TCC). Upon receipt of the accepted
MOU, the agency may begin submitting
name/TIN data in accordance with the
instructions in Publication 2108 and the
MOU.
SECTION 6. REQUIREMENTS FOR
PARTICIPATION
Participants in the Program must:
.01 comply with all requirements of
this revenue procedure, Publication
2108, and the MOU;
.02 transmit for matching only name/
TIN combinations relating to accounts
(as defined in section 3.04 of this rev-
enue procedure) with respect to which a
reportable payment is made, or likely to
be made, on or after January 1, 1997;
.03 transmit only name/TIN combina-
tions that have not been previously
transmitted for matching by that partici-
pant;
.04 use information obtained from the
Program only for backup withholding
purposes, and not disclose or use this
information for any unauthorized or pro-
hibited purpose.See§ 3406(f);
.05 use only the TCC provided by the
Service; and
.06 cooperate fully in providing to
the Service necessary information so the
Service can measure the effectiveness
and correct use of the Program.
SECTION 7. EFFECTIVE DATE
The Service intends that the Program
will be operational beginning on the
later of July 1, 1997, or the date the
necessary updates to the relevant sys-
tems of records are effective. However,
the Service will accept an MOU from
an agency wishing to participate in the
Program and name/TIN data transmitted
by a participant beginning on June 18,
1997.
DRAFTING INFORMATION
The principal authors of this revenue
procedure are Luetta Donalds of the
Office of Payer Compliance and Nancy
Rose of the Office of Assistant Chief
Counsel (Income Tax and Accounting).
For further information regarding this
revenue procedure, contact Ms. Donalds
at (202) 622–8753, or Ms. Rose at (202)
622-4910 (not toll-free calls).
1997–26 I.R.B.7June 30, 1997

Part IV. Items of General Interest
Foundations Status of Certain
Organizations
Announcement 97–63
The following organizations have
failed to establish or have been unable
to maintain their status as public chari-
ties or as operating foundations. Accord-
ingly, grantors and contributors may not,
after this date, rely on previous rulings
or designations in the Cumulative List
of Organizations (Publication 78), or on
the presumption arising from the filing
of notices under section 508(b) of the
Code. This listing doesnotindicate that
the organizations have lost their status
as organizations described in section
501(c)(3), eligible to receive deductible
contributions.
Former Public Charities. The follow-
ing organizations (which have been
treated as organizations that are not
private foundations described in section
509(a) of the Code) are now classified
as private foundations:
Alternative Lifestyle Scholarship
Organization, Inc., Los Angeles, CA
American Association for the Advance
of Atheism, Inc., San Diego, CA
American Association of Center Cancer
Registries, Inc., Santa Barbara, CA
American Educational Development
Agency, Oakland, CA
American Homeowners Resource
Center, San Juan Capistrano, CA
American Therapeutic Recreation,
Hattiesburg, MS
Anaktuvuk Pass Health Corporation,
Anaktuvuk Pass, AK
Angelica Group Homes Thomas &
Williams Foundation, La Verne, CA
Animal Support Foundation of Lewis
County, Winlock, WA
Another Helping Hand, Los Angeles,
CA
Barrow-Civic Theatre Foundation,
Pittsburgh, PA
Bedford Historical Foundation Inc.,
Bedford, TX
Boyertown Wrestling Demons,
Boyertown, PA
Breakfast Optimist Club of Dundalk
Foundation, Inc., Dundalk, MD
Broken Heart Ministries, Newport, TN
CAPRA Inc., Charlottesville, VA
Catoctin Foundation, Waterford, VA
Central Florida Alliance of the SE
Consortium Minorities Engineering,
Merritt Island, FL
Central Pecos Valley Jim Wilson
Crusade, Inc., Hope, NM
Child Development and Training
Centers of Virginia, Inc., Virginia
Beach, VA
Coalition Against Substance Abuse for
Jefferson Cocasa, Inc., Madison, IN
Colorado Aquarium Inc., Denver, CO
Community Service Corporation,
Washington, DC
Compassionate Ministries Inc., Tulsa,
OK
Coral Springs City Centre Inc., Coral
Springs, FL
Creative Housing Resources Inc.,
Berkley, MI
Demand-Side Management Training
Institute, Bala Cynwyd, PA
Free Flyght Gym Comet Gymnastics,
Commerce City, CO
Friends & Family Inc., Washington, MI
Friends of the American Pilgram
Chorus, Los Angeles, CA
Friends of the Cape Canaveral Library,
Inc., Cape Canaveral, FL
Friends of the College Park Airport,
Inc., College Park, MD
Galveston Central Little League,
Galveston, TX
Grand Rapids Scottish Society, Grand
Rapids, MI
Greater Morris County Junior School
Coaches Association, Inc., Dover, NJ
Greensboro Childrens Museum,
Greensboro, NC
Guatemalan-Maya Center Inc., Lake
Worth, FL
Harrison County Historic Preservation,
Inc., Marshall, TX
Hollywood & Vine Recovery Center,
Inc., Los Angeles, CA
Horizons Repertory Theatre Inc., Miami,
FL
Hotba Fire Safety House Project, Waco,
TX
Housing Our People Inc., Washington,
DC
Industries for the Blind and Visually
Impaired Payne George, Delhi, LA
International Catacomb Society, Inc.,
Boston, MA
Islandview Village Development
Corporation, Detroit, MI
Joy of Downs Camp Many Stars,
Spanish Fork, UT
Kelly Memorial Geriatric Transporation,
Inc., Kerrville, TX
Koinonia Ministries and Christian
Counseling Center, Ann Arbor, MI
Neighborhood Leadership Council,
Jacksonvile, FL
North Alabama Disabilities Coalition,
Huntsville, AL
North Texas Child Nutrition
Corporation, Plano, TX
Northwest Area Health Education
Center, Charlottesville, VA
Northwest Indiana World Trade Council,
Incorporated, Portage, IN
Ohana Group, Highland Park, MI
Oklahoma Youth Unlimited
Incorporated, Tulsa, OK
Orange Youth Baseball, Orange, TX
Pacific Rim Media Company, Honolulu,
HI
Parents & Friends for Better Education,
Inc., Houma, LA
Parents as Partners in Education, Inc.,
Pueblo, CO
Parkway High School Baseball Dugout
Club, Bossier City, LA
Partnership for the Saginaw Bay
Watershed, University Center, MI
Pawnee Express Club, Pawnee, OK
Pennsylvania Scouters Museum &
Activity Center, Pittsburgh, PA
Pottsburg Park Resident Management
Corporation, Inc., Jacksonville, FL
Precious Children Child Care Center,
Inc., Columbia, SC
Project Win-Winning in Neighborhoods,
Inc., Athens, GA
Public Park and Recreation Board of
Limestone County, Athen, AL
Safe Toys for Kids Foundation,
Edmond, OK
Sarasota Heart Foundation Inc.,
Sarasota, FL
Save Historic Palatka Inc., Palatka, FL
School Clothes Make a Difference, Inc.,
Orlando, FL
Spirit of Carver Chorale, Houston, TX
Tag Tenn, Nashville, TN
Tejano Center for Community Concerns,
Inc., Houston, TX
UBW Inc., New York, NY
United Til Coalition of Harlem Inc.,
New York, NY
Upshur County Senior Citizens Board of
Directors, Inc., Gilmer, TX
Utah Vascular Access Network-UVAN,
Salt Lake City, UT
Utica Kiwanis Michael Monicatti
Scholarship Foundation, Clinton Twp,
MI
Val Harrop Foundation, Houston, TX
Venue Theatre Collective Inc., St.
Petersburg, FL
Veterans Workshop of Texas Inc.,
Dallas, TX
Victims of Hurting Childhood Inc.,
Portland, TN
Volusia County Cooperative Health
Group, Inc., Daytona Beach, FL
June 30, 1997
81997–26 I.R.B.

Washington County Child Development
Corporation, Hudson Falls, NY
Wee-Do-Care Inc., Marks, MS
Wellington Kiwanis Foundation Inc.,
Wellington, FL
Wellington Senior Citizens Bus
Association, Inc., Wellington, OH
Western Colorado Early Childhood
Educators, Inc., Grand Junction, CO
Youthbuild-Dekalb Inc., Decatur, GA
If an organization listed above sub-
mits information that warrants the re-
newal of its classification as a public
charity or as a private operating founda-
tion, the Internal Revenue Service will
issue a ruling or determination letter
with the revised classification as to
foundation status. Grantors and contribu-
tors may thereafter rely upon such rul-
ing or determination letter as provided
in section 1.509(a)–7 of the Income Tax
Regulations. It is not the practice of the
Service to announce such revised classi-
fication of foundation status in the Inter-
nal Revenue Bulletin.
Clarification of 1997 Form W–2
Instructions for Reporting
Employer-Provided Adoption
Benefits
Announcement 97–64
This announcement is to clarify the
instructions for reporting the 1997
employer-provided adoption benefits un-
der code T in box 13 of Form W–2.
Report the total amount paid or reim-
bursed by an employer for qualified
adoption expenses furnished to an em-
ployee under an adoption assistance pro-
gram. Also include adoption benefits
paid or reimbursed from the pre-tax
contributions made by the employee to a
section 125 (cafeteria) plan. However,
do not include adoption benefits for-
feited from a section 125 (cafeteria)
plan.
Report in box 13 the total benefits
paid or reimbursed, including any in
excess of the $5,000 or $6,000 exclu-
sion.
Deletions From Cumulative List of
Organizations Contributions to
Which Are Deductible Under
Section 170 of the Code
Announcement 97–65
The name of an organization that no
longer qualifies as an organization de-
scribed in section 170(c)(2) of the Inter-
nal Revenue Code of 1986 is listed
below.
Generally, the Service will not disal-
low 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 Ser-
vice is not precluded from disallowing a
deduction for any contributions made
after an organization ceases to qualify
under section 170(c)(2) if the organiza-
tion has not timely filed a suit for
declaratory judgment under section 7428
and if the contributor (1) had knowledge
of the revocation of the ruling or deter-
mination letter, (2) was aware that such
revocation was imminent, or (3) was in
part responsible for or was aware of the
activities or omissions of the organiza-
tion that brought about this revocation.
If on the other hand a suit for de-
claratory judgment has been timely
filed, contributions from individuals and
organizations described in section
170(c)(2) that are otherwise allowable
will continue to be deductible. Protec-
tion under section 7428(c) would begin
on June 30, 1997, and would end on the
date the court first determines that the
organization is not described in section
170(c)(2) as more particularly set forth
in section 7428(c)(1). For individual
contributors, the maximum deduction
protected is $1,000, with a husband and
wife treated as one contributor. This
benefit is not extended to any individual
who was responsible, in whole or in
part, for the acts or omissions of the
organization that were the basis for
revocation.
Christian Home Endowment Foundation,
Wilmington, DE
Correction to Announcement 97–54
Announcement 97–66
Announcement Number 97–54, pub-
lished in Internal Revenue Bulletin
Number 1997–22, dated June 2, 1997,
contained a notice stating that Loving
Spirit Foundation, Inc. of Tampa, FL no
longer qualified as an organization de-
scribed in section 170(c)(2) of the Inter-
nal Revenue Code. This notice has been
cancelled and Loving Spirit Foundation,
Inc. continues to be recognized as an
organizationdescribedinsection
170(c)(2) of the Internal Revenue Code.
1997–26 I.R.B.9June 30, 1997

Announcement of the Disbarment, Suspension, or Consent to Voluntary
Suspension of Attorneys, Certified Public Accountants, Enrolled Agents, and
Enrolled Actuaries From Practice Before the Internal Revenue Service
Under 31 Code of Federal Regula-
tions, Part 10, an attorney, certified pub-
lic accountant, enrolled agent, or en-
rolled actuary, in order to avoid the
institution or conclusion of a proceeding
for his disbarment or suspension from
practice before the Internal Revenue Ser-
vice, may offer his consent to suspension
from such practice. The Director of
Practice, in his discretion, may suspend
an attorney, certified public accountant,
enrolled agent, or enrolled actuary in
accordance with the consent offered.
Attorneys, certified public accoun-
tants, enrolled agents, and enrolled actu-
aries are prohibited in any Internal Rev-
enue Service matter from directly or
indirectly employing, accepting assis-
tance from, being employed by or shar-
ing fees with, any practitioner disbarred
or suspended from practice before the
Internal Revenue Service.
To enable attorneys, certified public
accountants, enrolled agents, and en-
rolled actuaries to identify practitioners
under consent suspension from practice
before the Internal Revenue Service, the
Director of Practice will announce in the
Internal Revenue Bulletin the names and
addresses of practitioners who have
been suspended from such practice, their
designation as attorney, certified public
accountant, enrolled agent, or enrolled
actuary and date or period of suspen-
sion. This announcement will appear in
the weekly Bulletin at the earliest practi-
cable date after such action and will
continue to appear in the weekly Bulle-
tins for five successive weeks or for as
many weeks as is practicable for each
attorney, certified public accountant, en-
rolled agent, or enrolled actuary so
suspended and will be consolidated and
published in the Cumulative Bulletin.
The following individuals have been
placed under consent suspension from
practice before the Internal Revenue
Service:
NameAddressDesignationDate of Suspension
Bert Jr., Earol L.Severna Park, MDCPAFebruary 1, 1997 to July 31, 1997
Bernard, Lucius P.Corte Medera, CAAttorneyMarch 10, 1997 to March 9, 2000
Parker, David A.Willmar, MNCPAApril 13, 1997 to April 12, 2000
Sheldon, DonaldNashville, TNCPAApril 24, 1997 to September 23, 1997
Grandt, Lawrence E.Barrington, ILCPAApril 24, 1997 to January 23, 1998
Reese, Rex E.Alexandria, VAAttorneyMay 1, 1997 to April 30, 1999
Glasl, John E.Emporium, PACPAMay 1, 1997 to September 30, 1997
Coulter, Diane E.Monroeville, PACPAMay 1, 1997 to April 30, 1998
Groves, J. RandallMatthews, NCAttorneyMay 1, 1997 to October 31, 1998
Lupiloff, StevenBloomfield, MIAttorneyIndefinite from May 6, 1997
Wilson, Robert L.Spring Hill, FLCPAMay 7, 1997 to October 6, 1998
Sloop, Wayne F.Winston-Salem, NCCPAIndefinite from May 7, 1997
Wilnewic, Mark V.Crystal Lake, ILCPAMay 8, 1997 to November 7, 1997
Lenihan, MichaelCincinnati, OHCPAMay 14, 1997 to July 13, 1997
Bergmann, FrederickTampa, FLCPAJune 1, 1997 to May 30, 1999
Farmer, CraigArlington Hghts, ILCPAJune 1, 1997 to August 31, 1997
Denny, RichardPine Bluff, ARCPAJune 1, 1997 to July 31, 1997
June 30, 1997
101997–26 I.R.B.

Announcement of the Expedited Suspension of Attorneys, Certified Public
Accountants, Enrolled Agents, and Enrolled Actuaries From Practice Before the
Internal Revenue Service
Under title 31 of the Code of Federal
Regulations, section 10.76, the Director
of Practice is authorized to immediately
suspend from practice before the Inter-
nal Revenue Service any practitioner
who, within five years, from the date
the expedited proceeding is instituted,
(1) has had a license to practice as an
attorney, certified public accountant, or
actuary suspended or revoked for cause;
or (2) has been convicted of any crime
under title 26 of the United States Code
or, of a felony under title 18 of the
United States Code involving dishonesty
or breach of trust.
Attorneys, certified public accoun-
tants, enrolled agents, and enrolled actu-
aries are prohibited in any Internal Rev-
enue Service matter from directly or
indirectly employing, accepting assis-
tance from, being employed by, or shar-
ing fees with, any practitioner disbarred
or suspended from practice before the
Internal Revenue Service.
To enable attorneys, certified public
accountants, enrolled agents, and en-
rolled actuaries to identify practitioners
under expedited suspension from prac-
tice before the Internal Revenue Service,
the Director of Practice will announce in
the Internal Revenue Bulletin the names
and addresses of practitioners who have
been suspended from such practice, their
designation as attorney, certified public
accountant, enrolled agent, or enrolled
actuary, and date or period of suspen-
sion. This announcement will appear in
the weekly Bulletin at the earliest practi-
cable date after such action and will
continue to appear in the weekly Bulle-
tins for five successive weeks or for as
many weeks as is practicable for each
attorney, certified public accountant, en-
rolled agent, or enrolled actuary so
suspended and will be consolidated and
published in the Cumulative Bulletin.
The following individuals have been
placed under suspension from practice
before the Internal Revenue Service by
virtue of the expedited proceeding pro-
visions of the applicable regulations:
NameAddressDesignationDate of Suspension
Dally, Candace L.Winston-Salem, NCCPAIndefinite from April 16, 1997
Mellor, Gary D.Norton, KSAttorneyIndefinite from April 16, 1997
Gottesman, MiltonNew York, NYCPAIndefinite from April 16, 1997
Wiener, JamesGermantown, NYAttorneyIndefinite from April 16, 1997
Lunblad, GeraldSacramento, CACPAIndefinite from April 16, 1997
Driscoll, Robert J.Denver, COAttorneyIndefinite from April 16, 1997
Alico, Kenneth N.Orchard Park, NYCPAIndefinite from April 16, 1997
Mack, Roland G.Hyattsville, MDCPAIndefinite from May 1, 1997
Newman, Harry J.Covington, VACPAIndefinite from May 16, 1997
Sehnert, FredDallas, TXCPAIndefinite from May 16, 1997
Gaskins, John D.Valdosta, GACPAIndefinite from May 16, 1997
Turner, Charles L.Goshen, KYAttorneyIndefinite from May 16, 1997
Thornton Jr., Kenneth W.Murrells Inlet, SCAttorneyIndefinite from May 16, 1997
Kellogg, RichardWhite Hall, ARCPAIndefinite from May 16, 1997
Stec, Albert J.Schereville, INCPAIndefinite from May 16, 1997
Huff Jr., James G.Raleigh, NCCPAIndefinite from May 16, 1997
Seall, WilliamDayton, OHAttorneyIndefinite from May 16, 1997
Brunner, L. KeithCenterville, OHAttorneyIndefinite from May 16, 1997
Bart, David R.Oakwood, OHAttorneyIndefinite from May 16, 1997
Shafer, David A.Franklin, OHCPAIndefinite from May 16, 1997
Schouman, JamesMilford, MIAttorneyIndefinite from May 16, 1997
Jones, Milo A.Greensboro, NCCPAIndefinite from May 16, 1997
Dolan, Gary L.Lincoln, NEAttorneyIndedinite from May 16, 1997
Coorey, Edward T.Hampton, NHEnrolled AgentIndefinite from May 16, 1997
Sheehan, Thomas J.Maggie Valley, NCCPAIndefinite from May 16, 1997
Millonig, Arthur F.Dayton, OHAttorneyIndefinite from May 16, 1997
McHaffie, Richard T.St. Paul, MNAttorneyIndefinite from June 4, 1997
Rigler, MichaelGainesville, TXCPAIndefinite from June 4, 1997
1997–26 I.R.B.
11June 30, 1997

NameAddressDesignationDate of Suspension
Hopkins, Diane E.St. Paul, MNAttorneyIndefinite from June 4, 1997
Adae, F. BrianBarrington, RIAttorneyIndefinite from June 4, 1997
Announcement of the Consent Suspension of Attorneys, Certified Public
Accountants, Enrolled Agents, and Enrolled Actuaries From Practice Before the
Internal Revenue Service
Under 31 Code of Federal Regula-
tions, Part 10, an attorney, certified pub-
lic accountant, enrolled agent, or en-
rolled actuary, in order to avoid the
institution or conclusion of a proceeding
for his disbarment or suspension from
practice before the Internal Revenue Ser-
vice, may offer his consent to suspension
from such practice. The Director of
Practice, in his discretion, may suspend
an attorney, certified public accountant,
enrolled agent, or enrolled actuary in
accordance with the consent offered.
Attorneys, certified public accoun-
tants, enrolled agents, and enrolled actu-
aries are prohibited in any Internal Rev-
enue Service matter from directly or
indirectly employing, accepting assis-
tance from, being employed by or shar-
ing fees with, any practitioner disbarred
or suspended from practice before the
Internal Revenue Service.
To enable attorneys, certified public
accountants, enrolled agents, and en-
rolled actuaries to identify practitioners
under consent suspension from practice
before the Internal Revenue Service, the
Director of Practice will announce in the
Internal Revenue Bulletin the names and
addresses of practitioners who have
been suspended from such practice, their
designation as attorney, certified public
accountant, enrolled agent, or enrolled
actuary, and date or period of suspen-
sion. This announcement will appear in
the weekly Bulletin at the earliest practi-
cable date after such action and will
continue to appear in the weekly Bulle-
tins for five successive weeks or for as
many weeks as is practicable for each
attorney, certified public accountant, en-
rolled agent, or enrolled actuary so
suspended and will be consolidated and
published in the Cumulative Bulletin.
The following individuals have been
placed under consent suspension from
practice before the Internal Revenue
Service:
NameAddressDesignationDate of Suspension
Padgett, JohnOrleans, MAAttorneyMay 22, 1997 to October 21, 1998
Crisp, Jerry W.Dallas, TXCPAJune 1, 1997 to May 31, 2000
Kessel, Donald K.Export, PACPAJune 1, 1997 to November 30, 1998
Klimchak, JosephAliquippa, PACPAJune 1, 1997 to February 28, 1998
Steele, Lewis M.Pittsburgh, PACPAJune 1, 1997 to May 31, 1998
Castleberry, Gene A.Oklahoma City, OKAttorneyJune 4, 1997 to August 3, 1997
O’Connor, Paul J.Hanover, MACPAJune 6, 1997 to June 5, 2000
Olshan, Robert M.Washington, DCCPAJune 10, 1997 to December 9, 1998
Johnson, Kirk L.Ann Arbor, MICPAJuly 1, 1997 to June 30, 1999
Mattutat, StephenEllicott City, MDCPAJuly 1, 1997 to March 31, 1998
Trenary, Lloyd R.Oklahoma City, OKCPAAugust 1, 1997 to March 31, 1998
Ritchey Jr., FerrisBirmingham, ALAttorneyAugust 1, 1997 to July 31, 2000
Gold, Howard G.Hamden, CTCPAAugust 1, 1997 to July 31, 1999
Womack, KathleenHammond, LACPAAugust 1, 1997 to July 31, 1999
June 30, 1997
121997–26 I.R.B.

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as ‘‘rulings’’)
that have an effect on previous rulings
use the following defined terms to de-
scribe the effect:
Amplifieddescribes a situation where
no change is being made in a prior
published position, but the prior position
is being extended to apply to a variation
of the fact situation set forth therein.
Thus, if an earlier ruling held that a
principle applied to A, and the new
ruling holds that the same principle also
applies to B, the earlier ruling is ampli-
fied. (Compare withmodified, below).
Clarifiedis used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously
published ruling and points out an es-
sential difference between them.
Modifiedis used where the substance
of a previously published position is
being changed. Thus, if a prior ruling
held that a principle applied to A but not
to B, and the new ruling holds that it
applies to both A and B, the prior ruling
is modified because it corrects a pub-
lished position. (Compare withamplified
andclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered de-
terminative with respect to future trans-
actions. This term is most commonly
used in a ruling that lists previously
published rulings that are obsoleted be-
cause of changes in law or regulations.
A ruling may also be obsoleted because
the substance has been included in regu-
lations subsequently adopted.
Revokeddescribes situations where
the position in the previously published
ruling is not correct and the correct
position is being stated in the new
ruling.
Supersededdescribes a situation
where the new ruling does nothing more
than restate the substance and situation
of a previously published ruling (or
rulings). Thus, the term is used to
republish under the 1986 Code and
regulations the same position published
under the 1939 Code and regulations.
The term is also used when it is desired
to republish in a single ruling a series of
situations, names, etc., that were previ-
ously published over a period of time in
separate rulings. If the new ruling does
more than restate the substance of a
prior ruling, a combination of terms is
used. For example,modifiedandsuper-
sededdescribes a situation where the
substance of a previously published rul-
ing is being changed in part and is
continued without change in part and it
is desired to restate the valid portion of
the previously published ruling in a new
ruling that is self contained. In this case
the previously published ruling is first
modified and then, as modified, is su-
perseded.
Supplementedis used in situations in
which a list, such as a list of the names
of countries, is published in a ruling and
that list is expanded by adding further
names in subsequent rulings. After the
original ruling has been supplemented
several times, a new ruling may be
published that includes the list in the
original ruling and the additions, and
supersedes all prior rulings in the series.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current use and
formerly used will appear in material published in
the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C.—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contribution Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign Corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statements of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
13

Numerical Finding List
1
Bulletins 1997–1 through 1997–25
Announcements:
97–1, 1997–2 I.R.B.63
97–2, 1997–2 I.R.B.63
97–3, 1997–2 I.R.B.63
97–4, 1997–3 I.R.B.14
97–5, 1997–3 I.R.B.15
97–6, 1997–4 I.R.B.11
97–7, 1997–4 I.R.B.12
97–8, 1997–4 I.R.B.12
97–9, 1997–5 I.R.B.27
97–10, 1997–10 I.R.B.64
97–11, 1997–6 I.R.B.19
97–12, 1997–7 I.R.B.55
97–13, 1997–8 I.R.B.38
97–14, 1997–8 I.R.B.38
97–15, 1997–9 I.R.B.23
97–16, 1997–9 I.R.B.23
97–17, 1997–9 I.R.B.23
97–18, 1997–10 I.R.B.67
97–19, 1997–10 I.R.B.68
97–20, 1997–11 I.R.B.22
97–21, 1997–11 I.R.B.23
97–22, 1997–12 I.R.B.47
97–23, 1997–11 I.R.B.23
97–24, 1997–11 I.R.B.24
97–25, 1997–12 I.R.B.47
97–26, 1997–12 I.R.B.48
97–27, 1997–13 I.R.B.30
97–28, 1997–14 I.R.B.15
97–29, 1997–14 I.R.B.16
97–30, 1997–14 I.R.B.16
97–31, 1997–14 I.R.B.16
97–32, 1997–14 I.R.B.17
97–33, 1997–15 I.R.B.8
97–34, 1997–15 I.R.B.8
97–35, 1997–15 I.R.B.9
97–36, 1997–15 I.R.B.10
97–37, 1997–15 I.R.B.10
97–38, 1997–15 I.R.B.10
97–39, 1997–16 I.R.B.27
97–40, 1997–16 I.R.B.28
97–41, 1997–16 I.R.B.28
97–42, 1997–17 I.R.B.19
97–43, 1997–17 I.R.B.19
97–44, 1997–17 I.R.B.19
97–45, 1997–17 I.R.B.20
97–46, 1997–18 I.R.B.53
97–47, 1997–19 I.R.B.94
97–48, 1997–20 I.R.B.8
97–49, 1997–20 I.R.B.8
97–50, 1997–20 I.R.B.8
97–51, 1997–20 I.R.B.9
97–52, 1997–21 I.R.B.22
97–53, 1997–21 I.R.B.22
97–54, 1997–22 I.R.B.23
97–55, 1997–22 I.R.B.23
97–56, 1997–23 I.R.B.17
97–57, 1997–23 I.R.B.18
97–58, 1997–24 I.R.B.13
97–59, 1997–24 I.R.B.13
97–60, 1997-24 I.R.B.14
97–62, 1997–25, I.R.B.34
Delegation Orders:
232 (Rev. 3),21
Notices:
97–1, 1997–2 I.R.B.22
97–2, 1997–2 I.R.B.22
97–3, 1997–1 I.R.B.8
Notices—Continued
97–4, 1997–2 I.R.B.24
97–5, 1997–2 I.R.B.25
97–6, 1997–2 I.R.B.26
97–7, 1997–1 I.R.B.8
97–8, 1997–4 I.R.B.7
97–9, 1997–2 I.R.B.35
97–10, 1997–2 I.R.B.41
97–11, 1997–2 I.R.B.50
97–12, 1997–3 I.R.B.11
97–13, 1997–6 I.R.B.13
97–14, 1997–8 I.R.B.23
97–15, 1997–8 I.R.B.23
97–16, 1997–9 I.R.B.15
97–17, 1997–10 I.R.B.34
97–18, 1997–10 I.R.B.35
97–19, 1997–10 I.R.B.40
97–20, 1997–10 I.R.B.52
97–21, 1997–11 I.R.B.9
97–22, 1997–13 I.R.B.9
97–23, 1997–14 I.R.B.8
97–24, 1997–16 I.R.B.6
97–25, 1997–16 I.R.B.8
97–26, 1997–17 I.R.B.6
97–27, 1997–17 I.R.B.7
97–28, 1997–18 I.R.B.45
97–29, 1997–20 I.R.B.6
97–30, 1997–20 I.R.B.6
97–31, 1997–21 I.R.B.5
97–32, 1997–21 I.R.B.8
97–33, 1997–22 I.R.B.22
97–34, 1997–25 I.R.B.22
97–35, 1997–25 I.R.B.32
Proposed Regulations:
REG–209332–80, 1997–14 I.R.B.9
REG–209040–88, 1997–7 I.R.B.34
REG–209121–89, 1997–11 I.R.B.15
REG–208288–90, 1997–11 I.R.B.14
REG–209494–90, 1997–8 I.R.B.24
REG–208172–91, 1997–10 I.R.B.59
REG–209672–93, 1997–6 I.R.B.15
REG–209709–94 1997–13 I.R.B.12
REG–209729–94, 1997–11 I.R.B.19
REG–209762–95, 1997–3 I.R.B.12
REG–209785–95, 1997–18 I.R.B.46
REG–209817–96, 1997–7 I.R.B.41
REG–209824–96, 1997–11 I.R.B.19
REG–254394–96, 1997–14 I.R.B.14
REG–209823–96, 1997–18 I.R.B.47
REG–209828–96, 1997–6 I.R.B.15
REG–209830–96, 1997–15 I.R.B.7
REG–209834–96, 1997–4 I.R.B.9
REG–209837–96, 1997–23 I.R.B.8
REG–209839–96, 1997–8 I.R.B.26
REG–242996–96, 1997–9 I.R.B.18
REG–246018–96, 1997–8 I.R.B.30
REG–247678–96, 1997–6 I.R.B.17
REG–247862–96, 1997–8 I.R.B.32
REG–248770–96, 1997–8 I.R.B.33
REG–249819–96, 1997–7 I.R.B.50
REG–251703–96, 1997–25 I.R.B.5
REG–252231–96, 1997–7 I.R.B.52
REG–252233–96, 1997–9 I.R.B.19
REG–252487–96, 1997–25 I.R.B.9
REG–252665–96, 1997–12 I.R.B.46
REG–253578–96, 1997–19 I.R.B.93
REG–105299–97, 1997–23 I.R.B.8
Public Law:
105–2, 1997–18 I.R.B.14
Railroad Retirement Quarterly Rate:
1997–21 I.R.B.4
Revenue Procedures:
97–1, 1997–1 I.R.B.11
97–2, 1997–1 I.R.B.64
97–3, 1997–1 I.R.B.84
97–4, 1997–1 I.R.B.96
97–5, 1997–1 I.R.B.132
97–6, 1997–1 I.R.B.153
97–7, 1997–1 I.R.B.185
97–8, 1997–1 I.R.B.187
97–9, 1997–2 I.R.B.56
97–10, 1997–2 I.R.B.59
97–11, 1997–6 I.R.B.13
97–12, 1997–4 I.R.B.7
97–13, 1997–5 I.R.B.18
97–14, 1997–5 I.R.B.20
97–15, 1997–5 I.R.B.21
97–16, 1997–5 I.R.B.25
97–17, 1997–9 I.R.B.15
97–18, 1997–10 I.R.B.53
97–19, 1997–10 I.R.B.55
97–20, 1997–11 I.R.B.10
97–21, 1997–12 I.R.B.44
97–22, 1997–13 I.R.B.9
97–23, 1997–17 I.R.B.7
97–24, 1997–16 I.R.B.10
97–24A, 1997–20 I.R.B.7
97–25, 1997–17 I.R.B.8
97–26, 1997–17 I.R.B.17
97–27, 1997–21 I.R.B.10
97–28, 1997–23 I.R.B.9
97–29, 1997–24 I.R.B.9
97–30, 1997–25 I.R.B.20
Revenue Rulings:
97–1, 1997–2 I.R.B.10
97–2, 1997–2 I.R.B.7
97–3, 1997–2 I.R.B.5
97–4, 1997–3 I.R.B.6
97–5, 1997–4 I.R.B.5
97–6, 1997–4 I.R.B.4
97–7, 1997–5 I.R.B.14
97–8, 1997–7 I.R.B.4
97–9, 1997–9 I.R.B.4
97–10, 1997–10 I.R.B.31
97–11, 1997–10 I.R.B.5
97–12, 1997–11 I.R.B.5
97–13, 1997–16 I.R.B.4
97–14, 1997–11 I.R.B.5
97–15, 1997–12 I.R.B.42
97–16, 1997–13 I.R.B.4
97–17, 1997–14 I.R.B.5
97–18, 1997–15 I.R.B.4
97–19, 1997–18 I.R.B.11
97–20, 1997–19 I.R.B.4
97–21, 1997–18 I.R.B.8
97–22, 1997–20 I.R.B.5
97–23, 1997–22 I.R.B.18
97–24, 1997–22 I.R.B.17
97–25, 1997–23 I.R.B.4
97–26, 1997–24 I.R.B.4
Social Security Domestic Coverage Threshold:
1997–9, I.R.B.17
Tax Conventions:
1997–17 I.R.B.5
14
1
See footnote at end of list.

Numerical Finding List—Continued
Bulletins 1997–1 through 1997–25
Treasury Decisions:
8688, 1997–3 I.R.B.7
8689, 1997–3 I.R.B.9
8690, 1997–5 I.R.B.5
8691, 1997–5 I.R.B.16
8692, 1997–3 I.R.B.4
8693, 1997–6 I.R.B.9
8694, 1997–6 I.R.B.11
8695, 1997–4 I.R.B.5
8696, 1997–6 I.R.B.4
8697, 1997–2 I.R.B.11
8698, 1997–7 I.R.B.29
8699, 1997–6 I.R.B.4
8700, 1997–7 I.R.B.5
8701, 1997–7 I.R.B.23
8702, 1997–8 I.R.B.4
8703, 1997–8 I.R.B.18
8704, 1997–8 I.R.B.12
8705, 1997–8 I.R.B.16
8706, 1997–9 I.R.B.11
8707, 1997–7 I.R.B.17
8708, 1997–10 I.R.B.14
8709, 1997–9 I.R.B.5
8710, 1997–13 I.R.B.4
8711, 1997–12 I.R.B.35
8712, 1997–12 I.R.B.4
8713, 1997–14 I.R.B.4
8714, 1997–15 I.R.B.5
8715, 1997–18 I.R.B.5
8716, 1997–19 I.R.B.5
8717, 1997–24 I.R.B.5
8718, 1997–22 I.R.B.4
8719, 1997–23 I.R.B.4
8720, 1997–23 I.R.B.6
1
A cumulative list of all Revenue Rulings,
Revenue Procedures, Treasury Decisions, etc.,
published in Internal Revenue Bulletins 1996–27
through 1996–53 will be found in Internal
Revenue Bulletin 1997–1, dated January 6, 1997.
15

Finding List of Current Action on
Previously Published Items
1
Bulletins 1997–1 through 1997–25
*Denotes entry since last publication
Delegation Orders:
232 (Rev. 2)
Modified by
232 (Rev. 3), 1997–25 I.R.B.21
Revenue Procedures:
66–3
Modified by
97–11, 1997–6 I.R.B.13
87–21
Modified by
97–11, 1997–6 I.R.B.13
92–20
Modified by
97–1, 1997–1 I.R.B.11
92–20
Modified by
97–10, 1997–2 I.R.B.59
92–90
Superseded by
97–1, 1997–1 I.R.B.11
94–52
Revoked by
97–11, 1997–6 I.R.B.13
96–1
Superseded by
97–1, 1997–1 I.R.B.11
96–2
Superseded by
97–2, 1997–1 I.R.B.64
96–3
Superseded by
97–3, 1997–1 I.R.B.84
96–4
Superseded by
97–4, 1997–1 I.R.B.96
96–5
Superseded by
97–5, 1997–1 I.R.B.132
96–6
Superseded by
97–6, 1997–1 I.R.B.153
96–7
Superseded by
97–7, 1997–1 I.R.B.185
96–8
Superseded by
97–8, 1997–1 I.R.B.187
96–24
96–24A
Superseded by
97–24, 1997–16 I.R.B.10
96–37
Obsoleted by
97–26, 1997–17 I.R.B.17
Revenue Procedures—Continued
97–2
Amplified by
97–21, 1997–12 I.R.B.44
97–3
Amplified by
97–23, 1997–17 I.R.B.7
97–27
Superseded by
97–30, 1997–25 I.R.B.20
Revenue Rulings:
70–480
Revoked by
97–6, 1997–4 I.R.B.4
72–527
Obsoleted by
8704, 1997–8 I.R.B.12
74–59
Revoked by
8708, 1997–10 I.R.B.14
86–73
Obsoleted by
TD 8717, 1997–24 I.R.B.5
87–50
Obsoleted by
TD 8717, 1997–24 I.R.B.5
87–51
Obsoleted by
TD 8717, 1997–24 I.R.B.5
88–42
Obsoleted by
TD 8717, 1997–24 I.R.B.5
92–19
Supplemented in part by
97–2, 1997–2 I.R.B.7
93–90
Obsoleted by
TD 8717, 1997–24 I.R.B. 5
96–12
Superseded by
97–3, 1997–1 I.R.B.84
96–13
Modified by
97–1, 1997–1 I.R.B.11
96–22
Superseded by
97–3, 1997–1 I.R.B.84
96–34
Superseded by
97–3, 1997–1 I.R.B.84
96–39
Superseded by
97–3, 1997–1 I.R.B.84
96–43
Superseded by
97–3, 1997–1 I.R.B.84
96–56
Superseded by
97–3, 1997–1 I.R.B.84
1
A cumulative finding list for previously published
items mentioned in Internal Revenue Bulletins
1996–27 through 1996–53 will be found in Inter-
nal Revenue Bulletin 1997–1, dated January 6,
1997.
16

NOTES
17

NOTES
18

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INTERNAL REVENUE BULLETIN
The Introduction on page 3 describes the purpose and content of this publication. The weekly Internal Revenue Bulletin is
sold on a yearly subscription basis by the Superintendent of Documents. Current subscribers are notified by the Superintendent
of Documents when their subscriptions must be renewed.
CUMULATIVE BULLETINS
The contents of this weekly Bulletin are consolidated semiannually into a permanent, indexed, Cumulative Bulletin. These
are sold on a single copy basis andare notincluded as part of the subscription to the Internal Revenue Bulletin. Subscribers to
the weekly 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, D.C. 20402.
Please allow two to six weeks, plus mailing time, for delivery.
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