Internal Revenue Bulletin 2006-18 (PDF rendition): IRS Notices

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.

Bulletin No. 200
6-18
May 1, 2006
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.
INCOME TAX
Notice 2006–40, page 855.
This notice sets forth interim guidance, pending the issuance
of regulations, relating to the credit under section 45J of the
Code for production of electricity at advanced nuclear power
facilities. Specifically, this notice explains the method that will
be used to allocate the national megawatt capacity limitation
that limits the allowable credit and prescribes the application
process by which taxpayers may request an allocation of the
national megawatt capacity limitation. This notice also pro-
vides guidance on the requirement that the electricity be sold
to an unrelated person and on the effect of grants, tax-exempt
bonds, subsidized energy financing, and other credits.
Notice 2
006–41, page 857.
This noti
ce provides guidance with respect to the information
reporti
ng requirements applicable to Gulf Opportunity Zone
Bonds, G
ulf Opportunity Zone Advance Refunding Bonds, and
Gulf Tax
Credit Bonds. In addition, the notice provides other
guidanc
e with respect to Gulf Tax Credit Bonds including
guidan
ce to issuers of Gulf Tax Credit Bonds with respect to
the cre
dit rate and arbitrage requirements and guidance to
holder
s of Gulf Tax Credit Bonds with respect to the treatment
of the c
redit for income tax purposes.
EXEMPT ORGANIZATIONS
Announcement 2006–27, page 871.
A list is provided of organizations now classified as private foun-
dations.
Announcement 2006–28, page 873.
Ameratrust, Inc., of Delray Beach, FL, no longer qualifies as an
organization to which contributions are deductible under sec-
tion 170 of the Code.
ADMINISTRATIVE
Notice 2006–37, page 855.
Credit for sales of fuel produced from a nonconventional
source, inflation adjustment factor, and reference price.
This notice publishes the nonconventional source fuel credit,
the inflation adjustment factor, and the reference price under
section 29 of the Code for calendar year 2005. This data is
used to determine the credit allowable on sales of fuel pro-
duced from a nonconventional source.
Announcement 2006–25, page 871.
This announcement advises individual taxpayers of the release
of new Form 8898 (March 2006),Statement for Individuals
Who Begin or End Bona Fide Residence in a U.S. Possession.
The form is used to notify the IRS that an individual taxpayer
became or ceased to be abona fideresident of a U.S. posses-
sion in accordance with Code section 937, which was added by
the American Jobs Creation Act of 2004. For this purpose, the
following are considered U.S. possessions: American Samoa,
Guam, the Commonwealth of the Northern Mariana Islands, the
Commonwealth of Puerto Rico, and the U.S. Virgin Islands.
Announcement 2006–26, page 871.
This document contains corrections to final regulations under
section 163(d) of the Code (T.D. 9191, 2005–15 I.R.B. 854)
regarding rules relating to how and when taxpayers may elect
to take qualified dividend income into account as investment in-
come for purposes of calculating the deduction for investment
income expense.
Announcements of Disbarments and Suspensions begin on page 861.
Fi
nding Lists begin on page ii.

The IRS Mission
Provide America’s taxpayers top quality service by helping
them understand and meet their tax responsibilities and by
applying the tax law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, legislation, court decisions, and other items of general
interest. It is published weekly and may be obtained from the
Superintendent of Documents on a subscription basis. Bulletin
contents are compiled 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, mod-
ify, or amend any of those previously published in the Bulletin.
All published rulings apply retroactively unless otherwise indi-
cated. Procedures relating solely to matters of internal man-
agement 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 published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service 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.—19
86 Code.
This part i
ncludes rulings and decisions based on provisions of
the Intern
al Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B, Leg-
islation 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 Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Sec-
retary (Enforcement).
Part IV
.—Items of General Interest.
This par
t includes notices of proposed rulemakings, disbar-
ment an
d suspension lists, and announcements.
The last 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 last Bulletin of each semiannual period.
The c
ontents 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.
May 1, 20062006–18 I.R.B.

Part III. Administrative, Procedural, and Miscellaneous
Nonconventional Source Fuel
Credit, Section 29 Inflation
Adjustment Factor, and
Section 29 Reference Price
Notice 2006–37
This notice publishes the nonconven-
tional source fuel credit, inflation adjust-
ment factor, and reference price under § 29
of the Internal Revenue Code for calen-
dar year 2005. These are used to deter-
mine the credit allowable on fuel produced
from a nonconventional source under § 29.
The calendar year 2005inflation-adjusted
credit applies to the sales of barrel-of-oil
equivalent of qualified fuels sold by a tax-
payer to an unrelated person during the
2005 calendar year, the domestic produc-
tion of which is attributable to the taxpayer.
BACKGROUND
Section 29(a) provides for a credit for
producing fuel from a nonconventional
source, measured in barrel-of-oil equiva-
lent of qualified fuels, the production of
which is attributable to the taxpayer and
sold by the taxpayer to an unrelated person
during the tax year. The credit is equal to
the product of $3.00 and the appropriate
inflation adjustment factor.
Section 29(b)(1) and (2) provides for
a phaseout of the credit. The credit al-
lowable under § 29(a) must be reduced by
an amount which bears the same ratio to
the amount of the credit (determined with-
out regard to § 29(b)(1)) as the amount
by which the reference price for the calen-
dar year in which the sale occurs exceeds
$23.50 bears to $6.00. The $3.00 in § 29(a)
and the $23.50 and $6.00 must each be ad-
justed by multiplying these amounts by the
2005 inflation adjustment factor.
Section 29(c)(1), in part, defines the
term “qualified fuels” to include gas pro-
duced from biomass and liquid, gaseous,
or solid synthetic fuels produced from coal
(including lignite), including such fuels
when used as feedstocks.
Section 29(d)(1) provides that the credit
is to be applied only for sale of qualified
fuels the production of which is within
the United States (within the meaning of
§ 638(1)) or a possession of the United
States (within the meaning of § 638(2)).
Section 29(d)(2)(A)requires that the
Secretary, not later than April 1 of each cal-
endar year, determine and publish in the
Federal Register the inflation adjustment
factor and the reference price for the pre-
ceding calendar year.
Section 29(d)(2)(B) defines “inflation
adjustment factor” for a calendar year as
the fraction the numerator of which is the
GNP implicit price deflator for the calen-
dar year and the denominator of which is
the GNP implicit price deflator for calen-
dar year 1979. The term “GNP implicit
price deflator” means the first revision of
the implicit price deflator for the gross na-
tional product as computed and published
by the Department of Commerce.
Section 29(d)(2)(C) defines “reference
price” to mean with respect to a calendar
year the Secretary’s estimate of the annual
average wellhead price per barrel for all
domestic crude oil the price of which is not
subject to regulation by the United States.
Section 29(d)(5) provides that the term
“barrel-of-oil equivalent” with respect to
any fuel generally means that amount of
the fuel which has a Btu content of 5.8
million.
INFLATION ADJUSTMENT FACTOR
AND REFERENCE PRICE
The inflation adjustment factor for cal-
endar year 2005 is 2.2640. The reference
price for calendar year 2005 is $50.26.
These amounts were published in the Fed-
eral Register on April 10, 2006.
PHASEOUT CALCULATION
Because the calendar year 2005 refer-
ence price does not exceed $23.50 mul-
tiplied by the inflation adjustment factor,
the phaseout of the credit provided for in
§ 29(b)(1) does not occur for any qualified
fuel sold in calendar year 2005.
CREDIT AMOUNT
The nonconventional source fuel credit
under § 29(a) is $6.79 per barrel-of-oil
equivalent of qualified fuels ($3.00 x
2.2640). This amount was published in
the Federal Register on April 10, 2006.
DRAFTING INFORMATION
CONTACT
The principal author of this notice is
Jaime C. Park of the Office of Associate
Chief Counsel (Passthroughs and Special
Industries). For further information re-
garding this notice, contact Ms. Park at
(202) 622–3120 (not a toll-free call).
Credit for Production From
Advanced Nuclear Facilities
Notice 2006–40
SECTION 1. PURPOSE
This notice sets forth interim guidance,
pending the issuance of regulations, relat-
ing to the credit under § 45J of the Inter-
nal Revenue Code for production of elec-
tricity at advanced nuclear power facili-
ties. Specifically, this notice specifies the
method that will be used to allocate the
national megawatt capacity limitation that
limits the allowable credit and prescribes
the application process by which taxpayers
may request an allocation of the national
megawatt capacity limitation. This notice
also provides guidance on the requirement
that the electricity be sold to an unrelated
person and on the effect of grants, tax-ex-
empt bonds, subsidized energy financing,
and other credits. The Internal Revenue
Service and the Treasury Department ex-
pect that the regulations will incorporate
the rules set forth in this notice.
SECTION 2. BACKGROUND
.01 Section 45J was enacted by sec-
tion 1306 of the Energy Policy Act of
2005, Public Law 109–58 (119 Stat. 594).
Section 45J permits a taxpayer to claim a
credit for electricity that the taxpayer (1)
produces at an advanced nuclear power fa-
cility during the eight-year period begin-
ning when the facility is placed in service
and (2) sells to an unrelated person (quali-
fying electricity).
.02 Under § 45J(d), an advanced nu-
clear power facility is a nuclear facility that
meets all of the following requirements:
(1) The facility consists of a nuclear
power reactor that uses nuclear energy to
produce electricity. For purposes of this
2006–18 I.R.B.855May 1, 2006

notice, each nuclear power reactor located
on a multi-reactor site isa separate facility.
(2) The facility is owned by the tax-
payer.
(3) The reactor design for the facility
is approved by the Nuclear Regulatory
Commission after December 31, 1993
(and such design or a substantially similar
design of comparable capacity was not
approved on or before that date).
(4) The facility is placed in service be-
fore January 1, 2021.
.03 Under § 45J(b)(1), a taxpayer may
claim a credit for qualifying electricity
produced at an advanced nuclear power fa-
cility only if part of the national megawatt
capacity limitationhas been allocated to
the facility.
.04 Under § 45J(b)(1) and (c), the credit
allowed for a taxable year with respect to
the qualified electricity produced at an ad-
vanced nuclear power facility is computed
under the following rules:
(1) A tentative credit for the taxable
year is computed for the facility. The
facility’s tentative credit for the taxable
year is equal to 1.8 cents multiplied by the
kilowatt hours of qualified electricity pro-
duced at the facility and sold during the
taxable year to an unrelated person.
(2) The credit percentage is computed
for the facility. If the nameplate capacity of
the facility exceeds the national megawatt
capacity limitation allocated to the facil-
ity, the credit percentage for the facility is
determined by dividing the national capac-
ity limitation allocated to the facility by its
nameplate capacity. If the nameplate ca-
pacity of the facility does not exceed the
national megawatt capacity limitation al-
located to the facility, the credit percentage
for the facility is 100 percent.
(3) The credit allowed is the lesser
of (a) the tentative credit for the facility
multiplied by the credit percentage for
the facility, or (b) $125,000,000 per 1000
megawatts of national megawatt capacity
limitation allocated to the facility.
.05 Section 45J(b)(2) provides that
the national megawatt capacity limitation
is 6,000 megawatts. Section 45J(b)(3)
requires the Secretary to allocate this
national megawatt capacity limitation.
Section 45J(b)(4) requires the Secretary
to provide a certification process under
which the Secretary, after consultation
with the Secretary of Energy, shall ap-
prove and allocate the national megawatt
capacity limitation.
SECTION 3. ALLOCATION OF
NATIONAL MEGAWATT CAPACITY
LIMITATION
.01Allocation Limited to Qualifying
Facilities. The Service will allocate the
national megawatt capacity limitation only
to advanced nuclear facilities (within the
meaning of § 45J(d)(2)) that satisfy the re-
quirements of this section 3.01 (qualifying
facilities). An advanced nuclear facility
is a qualifying facility only if each of the
following requirements is satisfied:
(1) An application for a construc-
tion/operating license for the facility is
filed with the Nuclear Regulatory Com-
mission on or before the later of (i) Decem-
ber31,2008,or(ii)thedateonwhichthe
aggregate nameplatecapacity of advanced
nuclear facilities for which applications
for a construction/operating license have
been filed with the Nuclear Regulatory
Commission first equals or exceeds 6,000
megawatts.
(2) Construction on the facility begins
before January 1, 2014. For this purpose,
construction begins when a person who
has applied for or been granted a com-
bined license for an advanced nuclear fa-
cility initiates the pouring of safety-related
concrete for the reactor building.
(3) The U.S. Department of Energy
(DOE) provides a certification that the
facility qualifies as an advanced nuclear
facility, that the requirements of section
3.01(1) and (2) are satisfied, and that it is
feasible for the facility to placed in service
prior to January 1, 2021 (“DOE certifica-
tion”).
.02Application Required.
The Service will allocate the national
megawatt capacity limitation only to qual-
ifying facilities for which the applications
are submitted in accordance with section 4
of this notice.
.03Allocation Method.
The national megawatt capacity limita-
tion will be allocated as follows:
(1) If the total nameplate capacity of all
qualifying facilities for which applications
are submitted does not exceed the national
megawatt capacity limitation, each of
those facilities will be allocated an amount
of national megawattcapacity limitation
equal to its nameplate capacity.
(2) If the total nameplate capacity of
all qualifying facilities for which applica-
tions are submitted exceeds the national
megawatt capacity limitation, the national
megawatt capacity limitation will be allo-
cated among the facilities in proportion to
their nameplate capacities.
.04Service Action.
On or before December 31, 2014, the
Service will accept or reject the taxpayer’s
application and will notify the taxpayer, by
letter, of its decision. If the taxpayer’s ap-
plication is accepted, the acceptance let-
ter will state the amount of the national
megawatt capacity limitation allocated to
the facility.
SECTION 4. APPLICATIONS FOR
ALLOCATION OF NATIONAL
MEGAWATT CAPACITY LIMITATION
.01 A taxpayer must submit, for each
facility for which an allocation of the na-
tional megawatt capacity limitation is re-
quested (1) an application to the Service
for an allocation under§ 45J(b) (“applica-
tion for § 45J allocation”) and (2) an ap-
plication to DOE for a DOE certification
(“application for DOE certification”).
.02 Applications for § 45J allocation
and applications for DOE certification
must be submitted before January 31,
2014. For purposes of this notice, an ap-
plication that is submitted by U.S. mail
will be treated as received by the Service
on the date of the postmark and an applica-
tion submitted by a private delivery service
will be treated as received by the Service
on the date recorded or the date marked in
accordance with § 7502(f)(2)(C).
.03 The application for § 45J allocation
must include all of the following:
(1) The name and taxpayer identifica-
tion number of the taxpayer who will place
the facility in service;
(2) The name and location of the facil-
ity;
(3) The nameplate capacity of the facil-
ity;
(4) The date on which the application
for a construction/operating license for the
facility was filed with the Nuclear Regula-
tory Commission;
(5) The date on which construction on
the facility began;
(6) Documentation establishing that the
facility is expected to be placed in service
prior to January 1, 2021; and
May 1, 20068562006–18 I.R.B.

(7) A copy of the application for DOE
certification for the facility.
.04 Applications for § 45J allocation
should be marked: SECTION 45J APPLI-
CATION FOR ALLOCATION. There is
not any user fee for these applications.
(1) These applications should be sent to
the following address:
Internal Revenue Service
Attn: CC:PSI:6, Room 5114
P.O. Box 7604
Ben Franklin Station
Washington, DC 20044
If a private delivery service is used, the
address is:
Internal Revenue Service
Attn: CC:PSI:6, Room 5114
1111 Constitution Ave., N.W.
Washington, DC 20224
(2) Applications for certification may
also be hand delivered Monday through
Friday between the hours of 8 a.m. and
4p.m. to:
Courier’s Desk
Internal Revenue Service
Attn: CC:PSI:6, Room 5114
1111 Constitution Avenue, N.W.
Washington, DC 20224
.05 The application for DOE certifica-
tion must be submitted to DOE in such
manner and contain such information as
DOE may require. If DOE determines that
the conditions for certification are satis-
fied (see section 3.01 of this notice), it will
provide the DOE certification to the Ser-
vice. The DOE certification will be subject
to such requirements and conditions as the
Secretary of Energy may prescribe.
SECTION 5. REALLOCATION OF
NATIONAL MEGAWATT CAPACITY
LIMITATION IN CERTAIN CASES
If an amount of national megawatt ca-
pacity limitation is allocated to a facility
and the facility is not placed in service be-
fore January 1, 2021, or the DOE informs
the Service that the DOE certification
for the facility has been withdrawn, the
amount of the national megawatt capacity
limitation allocated to that facility will
be withdrawn and the national megawatt
capacity limitation will be reallocated un-
dertherulesofsection3.03ofthisnotice
among the remaining qualifying facilities.
SECTION 6. ADDITIONAL ISSUES
.01Sale to Unrelated Person.The
credit under § 45J is allowed only for elec-
tricity that the taxpayer produces and sells
to an unrelated person. Electricity will be
treated as sold to an unrelated person for
this purpose if the ultimate purchaser of the
electricity is not related to the person that
produces the electricity. The requirement
of a sale to an unrelated person will be
treated as satisfied in these circumstances
even if the producer sells the electricity to
a related person for resale by the related
person to a person that is not related to
the producer. For rules for determining
whether a person is related to the producer
of the electricity, see § 45(e)(4).
.02Effect of Grants, Tax-Exempt
Bonds, Subsidized Energy Financing, and
Other Credits. The amount of the credit
under § 45J is not reduced on account
of any grants, tax-exempt bonds, subsi-
dized energy financing, or other credits
described in § 45(b)(3).
SECTION 7. PAPERWORK
REDUCTION ACT
The collection of information contained
in this notice has been reviewed and ap-
proved by the Office of Management and
Budget in accordance with the Paperwork
Reduction Act (44 U.S.C. 3507) under
control number 1545–2000.
An agency may not conduct or sponsor,
and a person is not required to respond
to, a collection of information unless the
collection of information displays a valid
OMB control number.
The collections of information in this
notice are in section 3. This informa-
tion is required to be collected and re-
tained in order for taxpayers to claim the
new credit for the production of electric-
ity from advanced nuclear power facilities
under § 45J. The information will be used
to determine the portion of the national
megawatt capacity limitation to which a
taxpayer’s facility is entitled. The collec-
tionofinformationisrequiredtoobtaina
benefit. The likely respondents are corpo-
rations and partnerships.
The estimated total annual reporting
burden is 600 hours.
The estimated annual burden per re-
spondent varies from 10 to 60 hours, de-
pending on individual circumstances, with
an estimated average of 40 hours. The es-
timated number of respondents is 15.
The estimated annual frequency of re-
sponses is on occasion.
Books or records relating to a collection
of information must be retained as long
as their contents may become material in
the administration of any internal revenue
law. Generally, tax returns and tax return
information are confidential, as required
by 26 U.S.C. 6103.
SECTION 8. DRAFTING
INFORMATION
The principal author of this notice is
Patrick S. Kirwan of the Office of Asso-
ciate Chief Counsel (Passthroughs & Spe-
cial Industries). For further information
regarding this notice, contact Mr. Kirwan
at (202) 622–3110 (not a toll-free call).
Gulf Opportunity Zone
Bonds, Gulf Opportunity
Zone Advance Refunding
Bonds, and Gulf Tax Credit
Bonds
Notice 2006–41
SECTION 1. PURPOSE
This notice provides guidance with
respect to the information reporting re-
quirements applicable to Gulf Opportu-
nity Zone Bonds, Gulf Opportunity Zone
Advance Refunding Bonds, and Gulf Tax
Credit Bonds issued pursuant to § 1400N
of the Internal Revenue Code. This notice
also provides additional guidance with
respect to the credit rate and arbitrage re-
quirements applicable to Gulf Tax Credit
Bonds and with respect to the treatment of
the credit by holders of Gulf Tax Credit
Bonds.
SECTION 2. INTRODUCTION
Section 101 of the Gulf Opportunity
Zone Act of 2005, Pub. L. No. 109–135
(the Act), added §§ 1400M and 1400N
to the Internal Revenue Code. Section
1400M(1) defines the term Gulf Oppor-
tunity Zone (“GO Zone”) as that portion
2006–18 I.R.B.857May 1, 2006

of the Hurricane Katrina disaster area de-
termined by the President to warrant in-
dividual or individual and public assis-
tance from the Federal Government under
the Robert T. Stafford Disaster Relief and
Emergency Assistance Act by reason of
Hurricane Katrina.
In general, § 1400N authorizes
the states of Alabama, Louisiana and
Mississippi to issue: (1) certain exempt
facility bonds and qualified mortgage
bonds pursuant to § 1400N(a) (“Gulf
Opportunity Zone Bonds”), (2) advance
refunding bonds pursuant to § 1400N(b)
(“Gulf Opportunity Zone Advance Re-
funding Bonds”) and (3) tax credit bonds
pursuant to § 1400(N)(l) (“Gulf Tax Credit
Bonds”). Gulf Opportunity Zone Bonds
and Gulf Opportunity Zone Advance Re-
funding Bonds must be issued before
January 1, 2011. Gulf Tax Credit Bonds
must be issued before January 1, 2007.
SECTION 3. BACKGROUND
3.01. Gulf Opportunity Zone Bonds
Section 1400N(a)(1) provides that any
qualified Gulf Opportunity Zone Bond de-
scribed in § 1400N(a)(2)(A)(i) shall be
treated as an exempt facility bond and any
qualified Gulf Opportunity Zone Bond de-
scribed in § 1400N(a)(2)(A)(ii) shall be
treated as a qualified mortgage bond.
Section 1400N(a)(2) defines a qualified
Gulf Opportunity Zone Bond as any bond
issued as part of an issue if (1) 95 per-
cent or more of the net proceeds (as de-
finedin§150(a)(3))ofsuchissueareto
be used for qualified project costs, or such
issue meets the requirements of a qualified
mortgage issue, exceptasotherwisepro-
vided in § 1400N(a); (2) such bond is is-
sued by the State of Alabama, Louisiana
or Mississippi or any political subdivision
thereof; (3) such bond is designated for
purposes of § 1400N(a) either by the Gov-
ernor of such State, or in the case of a bond
which is required under State law to be ap-
proved by the bond commission of such
state, by such bond commission; (4) the
bond is issued after December 21, 2005,
and before January 1, 2011; and (5) no por-
tion of the proceeds of such issue is to be
used to provide any property described in
§ 144(c)(6)(B). Section 144(c)(6)(B) states
that no portion of the proceeds of such is-
sueistobeusedtoprovide(includingthe
provision of land for) any private or com-
mercial golf course, country club, massage
parlor, hot tub facility, suntan facility, race-
track or other facility used for gambling, or
any store the principal business of which
is the sale of alcoholic beverages for con-
sumption off premises.
Section 1400N(a)(4) defines qualified
project costs as the cost of any qualified
residential rental project (as defined in
§ 142(d)) located in the GO Zone, the cost
of acquisition, construction, reconstruc-
tion and renovation of nonresidential real
property (including fixed improvements
associated with such property) located in
the GO Zone, and the cost of acquisition,
construction, reconstruction and renova-
tion of public utility property (as defined
in § 168(i)(10)) located in the GO Zone.
Section 1400N(a)(3)(B) provides that
Gulf Opportunity Zone Bonds shall not be
used for movable fixtures and equipment.
Section 1400N(d)(2)(B)(ii) provides
that the special depreciation allowance (or
“bonus depreciation”) provided for under
§ 1400N(d)(1) is not available for Quali-
fied Gulf Opportunity Zone property (as
defined in § 1400N(d)(2)) if any portion
of such property is financed with the pro-
ceeds of any obligation, including Gulf
Opportunity Zone Bonds, the interest on
which is exempt from tax under § 103.
3.02. Gulf Opportunity Zone Advance
Refunding Bonds
Section 1400N(b)(1) permits the is-
suance of Gulf Opportunity Zone Ad-
vance Refunding Bonds to provide one
additional advance refunding of bonds
described in § 1400N(b)(3) under the
applicable rules of § 149(d) between De-
cember 21, 2005, and January 1, 2011, if
the Governor of the State designates the
Gulf Opportunity Zone Advance Refund-
ing Bonds for purposes of § 1400N(b) and
the requirements of § 1400N(b)(5) are met.
A bond is described under § 1400N(b)(3)
if such bond was outstanding on August
28, 2005, and is issued by the State of
Alabama, Louisiana, or Mississippi or a
political subdivision thereof.
Section 1400N(b)(2) provides that
with respect to bonds described in
§ 1400N(b)(3) that are exempt facility
bonds described in paragraph (1) or (2)
of § 142(a), Gulf Opportunity Zone Ad-
vance Refunding Bonds may be issued
to provide one advance refunding under
the applicable rules of § 149(d) (notwith-
standing § 149(d)(2)) after December 21,
2005, and before January 1, 2011, if the
Governor of the State designates the Gulf
Opportunity Zone Advance Refunding
Bonds for purposes of § 1400N(b) and the
requirements of § 1400N(b)(5) are met.
Section 1400N(b)(5) provides that the
requirements of § 1400N(b)(5) are met
with respect to any advance refunding of a
bond described in § 1400N(b)(3) if: (1) no
advance refundings of such bond would
be allowed under the Internal Revenue
Code on or after August 28, 2005; (2) the
Gulf Opportunity Zone Advance Refund-
ing Bonds is the only other outstanding
bond with respect to the refunded bond;
and (3) the requirements of § 148 are met
with respect to all bonds issued under
§ 1400N(b).
Section 1400N(b)(6) provides that
§ 1400N(b) does not apply to any advance
refunding of a bond which is issued as part
of an issue if any portion of the proceeds
of such issue (or any prior issue) was or
(is to be) used to provide any property
described in § 144(c)(6)(B).
3.03. Gulf Tax Credit Bonds
Section 1400N(l)(1) provides that a tax-
payer that holds a Gulf Tax Credit Bond on
one or more credit allowance dates of the
bond occurring during any taxable year is
allowed as a credit against Federal income
tax for the taxable year an amount equal
to the sum of the credits determined under
§ 1400N(l)(2) with respect to such dates.
In general, § 1400N(l)(2)(B) provides
that the annual credit determined with
respect to any Gulf Tax Credit Bond is
the product of the credit rate determined
by the Secretary for the day on which
such bond was sold, multiplied by the
outstanding face amount of the bond. Un-
der § 1400N(l)(2)(C), with respect to any
Gulf Tax Credit Bond, the Secretary shall
determine daily or cause to be determined
daily a credit rate which shall apply to
the first day on which there is a binding,
written contract for the sale or exchange
of the bond. The credit rate for any day
is the credit rate which the Secretary esti-
mates will permit the issuance of Gulf Tax
Credit Bonds with a specified maturity
or redemption date without discount and
withoutinterestcosttotheissuer.
May 1, 20068582006–18 I.R.B.

Section 1400N(l)(4)(A) provides that a
Gulf Tax Credit Bond means any bond is-
sued as part of an issue if: (1) the bond is
issued by the State of Alabama, Louisiana
or Mississippi; (2) 95 percent or more of
the proceeds of the issue are to be used
to pay principal, interest, or premiums on
qualified bonds issued by such State or
any political subdivision of such State, or
to make a loan to any political subdivi-
sion of such State to pay principal, interest
or premiums on qualified bonds issued by
such subdivision; (3) the Governor of such
State designates such bond for purposes of
§1400N(l); (4) the bond is a general obli-
gation of such State and is in registered
form (within the meaning of § 149(a)); (5)
the maturity of such bond does not exceed
2 years; and (6) the bond is issued after
December 31, 2005, and before January 1,
2007.
Section 1400N(l)(4)(D) provides that a
bond that is part of an issue of Gulf Tax
Credit Bonds shall not be treated as a Gulf
Tax Credit Bond unless, with respect to
theissueofwhichthebondisapart,the
issuer satisfies the arbitrage requirements
of § 148 with respect to the proceeds of
the issue and any loans made with such
proceeds.
Section 1400N(l)(5)(A) provides that
the term qualified bond for purposes of
§ 1400N(l) means any obligation of a State
or political subdivision thereof which was
outstanding on August 28, 2005. Sections
1400N(l)(5)(B), (C), and (D) further pro-
vide that such term does not include any
private activity bond, any bond with re-
spect to which there is any outstanding re-
funded or refunding bond during the pe-
riod in which a Gulf Tax Credit Bond is
outstanding with respect to such bond, or
any bond issued as part of an issue if any
portion of the proceeds of such issue was
(or is to be) used to provide any property
described in § 144(c)(6)(B).
Section 1400N(l)(6) provides that the
amount of credit allowed to a taxpayer un-
der § 1400N(l) (determined without regard
to § 1400N(l)(3)) shall be treated as inter-
est and included in the gross income of the
taxpayer.
Section 1400N(l)(7)(D) requires issuers
of Gulf Tax Credit Bonds to submit re-
ports similar to the reports required un-
der § 149(e) for tax-exempt State or local
bonds. Section 149(e) generally requires
issuers of tax exempt bonds to file an infor-
mation return with the Secretary not later
than the 15
th
day of the 2
nd
calendar month
after the close of the calendar quarter in
which the bond is issued.
SECTION 4. INFORMATION
REPORTING
4.01. Information Reporting for Gulf
Opportunity Zone Bonds
In order to satisfy the information
reporting requirement of § 149(e) with
respect to Gulf Opportunity Zone Bonds
issued pursuant to § 1400N(a), in addition
to completing the Form 8038,Information
Return for Tax-Exempt Private Activity
Bond Issues, in accordance with the in-
structions, issuers should: (1) write or type
“Filed in Accordancewith Notice 2006–41
— Gulf Opportunity Zone Bonds” at the
top of the Form 8038; (2) complete Part
II of the Form 8038 by checking the box
on Line 11(m)(other) for exempt facility
bonds or Line 20 for qualified mortgage
bonds, writing “Gulf Opportunity Zone
Bonds” in the space provided for the bond
description, and entering the amount of
thebondsintheIssuePricecolumn;and
(3) attach a copy of the document used
by the Governor or the State Bond Com-
missioner to designate the bonds as Gulf
Opportunity Zone Bonds.
4.02. Information Reporting for Gulf
Zone Advance Refunding Bonds
In order to satisfy the information
reporting requirement of § 149(e) with
respect to Gulf Opportunity Zone Ad-
vance Refunding Bonds issued pursuant
to § 1400N(b), in addition to completing
either the Form 8038,Information Return
for Tax-Exempt Private Activity Bond Is-
sues, Form 8038–G,Information Return
for Tax-Exempt Governmental Obliga-
tions, or Form 8038–GC,Information
Return for Small Tax-Exempt Governmen-
tal Bond Issues, Leases, and Installment
Sales, as appropriate, in accordance with
the instructions for refunding bonds, is-
suers should (1) write or type “Filed in
Accordance with Notice 2006–41 — Gulf
Opportunity Zone Advance Refunding
Bonds” at the top of the Form 8038,
8038–G or 8038–GC and (2) attach a copy
of the document used by the Governor to
designate the bonds as Gulf Opportunity
Zone Advance Refunding Bonds.
4.03. Information Reporting for Gulf
Tax Credit Bonds
Section 1400N(l)(7)(D) requires issuers
of Gulf Tax Credit Bonds to submit re-
ports similar to the reports required un-
der § 149(e) for tax-exempt State or lo-
cal bonds. In order to satisfy this require-
ment, in addition to completing the Form
8038–G,Information Return for Tax-Ex-
empt Governmental Obligations, in accor-
dance with the instructions, issuers should:
(1) write or type “Filed in Accordance
with Notice 2006–41 — Gulf Tax Credit
Bonds” at the top of the Form 8038–G;
(2) complete Part II of Form 8038–G by
checkingtheboxonLine18(Other),writ-
ing “Gulf Tax Credit Bonds” in the space
provided for the bond description, and en-
tering the amount of the bonds in the Issue
Price column; and (3) attach a copy of the
document used by the Governor to desig-
nate the bonds as Gulf Tax Credit Bonds.
SECTION 5. CREDIT RATE FOR
GULF TAX CREDIT BONDS
ThecreditrateforanissueofGulf
Tax Credit Bonds is the applicable Gulf
Tax Credit Bond credit rate published
each business day by the Bureau of Pub-
lic Debt on its Internet site for State and
Local Government Series securities at:
http://www.publicdebt.treas.gov.Theap-
plicable Gulf Tax Credit Bond credit rate
shall be applied to an issue of Gulf Tax
Credit Bonds on the day the issue is sold.
For this purpose, the issue is sold on the
first day there is a binding, written con-
tract for the sale or exchange of the bonds.
The credit rates will be determined by the
Treasury Department based on its estimate
of the yield on outstanding AA rate cor-
porate bonds of a similar maturity for the
business day immediately prior to the date
on which the issue is sold.
SECTION 6. ARBITRAGE
REQUIREMENTS FOR GULF
TAX CREDIT BONDS
Section 1400N(l)(4)(D) generally pro-
vides that the arbitrage requirements of
§ 148 applicable to tax-exempt State or lo-
cal bonds apply to Gulf Tax Credit Bonds
and any loans made with the proceeds of
such bonds. In applying § 148 to Gulf Tax
Credit Bonds the following special rules
apply—
2006–18 I.R.B.859May 1, 2006

(1) The credit allowed under
§ 1400N(l)(1) shall be disregarded for
purposes of computing the yield on the
issue under § 1.148–4;
(2) Section 148(b)(3) (relating to excep-
tion to the definition of “investment prop-
erty” for certain tax-exempt bonds) shall
not apply.
SECTION 7. TREATMENT OF
CREDIT BY HOLDERS OF GULF
TAX CREDIT BONDS
The following rules are applicable to
holders of Gulf Tax Credit Bonds:
(1) The holder of a Gulf Tax Credit
Bond must treat the bond as if it pays qual-
ified stated interest (within the meaning of
§ 1.1273–1(c)) on each credit allowance
date. Thus, for example, if the holder
uses an accrual method of accounting, the
holder must accrue as interest income the
amount of the credit over each period that
ends on a credit allowance date.
(2) If a holder holds a Gulf Tax Credit
Bond on a credit allowance date but can-
not use all or a portion of the credit to re-
duce its income tax liability (for example,
because the limitation in § 1400N(l)(3) ap-
plies), the holder is allowed a deduction
for the taxable year that includes the credit
allowance date (or, at the option of the
holder, the next succeeding taxable year).
The amount of the deduction is equal to the
amount of the unused credit deemed paid
on each credit allowance date during the
taxable year.
(3) If a person is a partner in a part-
nership, a beneficiary of an estate or
trust, a shareholder in an S corporation,
or the owner of an interest in another
pass-through entity except for a regu-
lated investment company (collectively,
pass-through entity), and the pass-through
entity owns a Gulf Tax Credit Bond, then
the amount of the credit under § 1400(l)(1)
allowedtosuchpersonforanytaxable
year shall not exceed an amount (sep-
arately computed with respect to such
person’s interest in such entity) equal to
the amount of tax attributable to that por-
tion of the person’s taxable income in such
year that is allocableor apportionable to
the person’s interest in such entity.
SECTION 8. DRAFTING
INFORMATION
The principal authors of this notice
areTimothyL.JonesandAvivaM.Roth
of the Office of Associate Chief Counsel
(Tax Exempt & Government Entities).
However, other personnel from the IRS
and the Treasury Department partici-
pated in its development. For further
information regarding this notice, contact
Timothy L. Jones or Aviva M. Roth at
(202) 622–3980 (not a toll-free call).
May 1, 20068602006–18 I.R.B.

Part IV. Items of General Interest
Announcement of Disciplinary Actions Involving
Attorneys, Certified Public Accountants, Enrolled Agents,
and Enrolled Actuaries — Suspensions, Censures,
Disbarments, and Resignations
Announcement 2006-23
Under Title 31, Code of Federal Regu-
lations, Part 10, attorneys, certified public
accountants, enrolled agents, and enrolled
actuaries may not accept assistance from,
or assist, any person who is under disbar-
ment or suspension from practice before
the Internal Revenue Service if the assis-
tance relates to a matter constituting prac-
tice before the Internal Revenue Service
and may not knowingly aid or abet another
person to practice before the Internal Rev-
enue Service during a period of suspen-
sion, disbarment, or ineligibility of such
other person.
To enable attorneys, certified public
accountants, enrolled agents, and enrolled
actuaries to identify persons to whom
these restrictions apply, the Director, Of-
fice of Professional Responsibility, will
announce in the Internal Revenue Bulletin
their names, their city and state, their pro-
fessional designation, the effective date
of disciplinary action, and the period of
suspension. This announcement will ap-
pear in the weekly Bulletin at the earliest
practicable date after such action and will
continue to appear in the weekly Bulletins
for five successive weeks.
Consent Suspensions From Practice Before the Internal
Revenue Service
Under Title 31, Code of Federal Regu-
lations, Part 10, an attorney, certified pub-
lic accountant, enrolled agent, or enrolled
actuary, in order to avoid the institution
or conclusion of a proceeding for his or
her disbarment or suspension from prac-
tice before the Internal Revenue Service,
may offer his or her consent to suspension
from such practice. The Director, Office
of Professional Responsibility, in his dis-
cretion, may suspend an attorney, certified
public accountant, enrolled agent, or en-
rolled actuary in accordance with the con-
sent offered.
The following individuals have been
placed under consent suspension from
practice before the Internal Revenue Ser-
vice:
NameAddressDesignationDate of Suspension
Hoft, James D.Nutley, NJCPAIndefinite
from
August 10, 2005
Salver, IsaacBay Harber Islands, FLCPASeptember 19, 2005
to
June 18, 2007
Woods, Dalton C.Carrollton, TXEnrolled AgentIndefinite
from
October 15, 2005
Morrissette, Doris G.Lowell,MAEnrolled AgentIndefinite
from
November 1, 2005
Dale, Edward R.Stockton, CACPAIndefinite
from
November 1, 2005
2006–18 I.R.B.861May 1, 2006

NameAddressDesignationDate of Suspension
Grossman, Israel G.New York, NYAttorneyNovember 15, 2005
to
May 14, 2007
Edmonds, Joseph M.Charlotte, NCEnrolled ActuaryNovember 16, 2005
to
March 15, 2006
Rubin, Stuart L.Coral Springs, FLCPAIndefinite
from
December 7, 2005
Sanger, Brett D.Oklahoma City, OKAttorneyIndefinite
from
January 1, 2006
Berkowitz, Ira T.Simi Valley, CACPAIndefinite
from
January 9, 2006
Caylor, John D.Long Lake, MNCPAIndefinite
from
January 12, 2006
Saldana, Oscar M.Laredo, TXCPAIndefinite
from
January 15, 2006
Bruck, Lawrence S.Newton, PACPAIndefinite
from
January 16, 2006
Sneathen, Lowell D.Orange, CACPAIndefinite
from
January 18, 2006
Roberson, GeorgeLeesburg, VACPAIndefinite
from
January 17, 2006
Dugan, Lawrence E.Alta, IAAttorneyIndefinite
from
February 1, 2006
Frascella, RussellPound Ridge, NYCPAIndefinite
from
February 1, 2006
Smith, David B.Kettering, OHEnrolled AgentIndefinite
from
February 13, 2006
Whiteside, Thomas L.Atlanta, GAAttorneyIndefinite
from
February 13, 2006
Bednarz, Jr., MichaelFramingham, MAAttorneyIndefinite
from
February 13, 2006
May 1, 20068622006–18 I.R.B.

NameAddressDesignationDate of Suspension
Alexander, Herald J.A.Atlanta, GAAttorneyIndefinite
from
February 20, 2006
Bartels, KyleNorth Salem, NYEnrolled AgentIndefinite
from
February 21, 2006
Baker, Jibade A.Indianapolis, INCPAMarch 13, 2006
to
March 12, 2008
Morris, R. ScottCorpus Christi, TXCPAIndefinite
from
March 16, 2006
Kenny, Stan M.Wichita, KSAttorneyIndefinite
from
May 1, 2006
Expedited Suspensions From Practice Before the Internal
Revenue Service
Under Title 31, Code of Federal Regu-
lations, Part 10, the Director, Office of Pro-
fessional Responsibility, is authorized to
immediately suspend from practice before
the Internal RevenueService any practi-
tioner who, within five years from the date
the expedited proceeding is instituted (1)
has had a license to practice as an attor-
ney, certified public accountant, or actuary
suspended or revoked for cause or (2) has
been convicted of certain crimes.
The following individuals have been
placed under suspension from practice be-
fore the Internal Revenue Service by virtue
of the expedited proceeding provisions:
NameAddressDesignationDate of Suspension
Haugabrook, EarlUpper Montclair, NJCPAIndefinite
from
September 27, 2005
Patterson, Kenneth R.Plano, TXCPAIndefinite
from
October 19, 2005
Blackburn, Randall D.Laurinburg, NCCPAIndefinite
from
October 19, 2005
Coe, Sean M.Sahuarita,AZAttorneyIndefinite
from
October 12, 2005
Lim, Ricarda L.Sacramento, CAAttorneyIndefinite
from
November 1, 2005
Bridges, Lynden P.Golden, COCPAIndefinite
from
November 14, 2005
2006–18 I.R.B.863May 1, 2006

NameAddressDesignationDate of Suspension
Curcio, Gregory J.New York, NYAttorneyIndefinite
from
November 14, 2005
Silverton, Ronald R.Pacific Palisades, CAAttorneyIndefinite
from
November 14, 2005
Hartigan, Seth P.Minneapolis, MNAttorneyIndefinite
from
November 14, 2005
Carlson, Richard E.Chappell, NEAttorneyIndefinite
from
November 14, 2005
Veres, Robert D.Phoenix, AZCPAIndefinite
from
November 14, 2005
Noble, Gregory P.Corvallis, ORAttorneyIndefinite
from
December 2, 2005
Parker, Oscie K.Thomasville, NCAttorneyIndefinite
from
December 15, 2005
Connor, Jr. William J.Kernersville, NCAttorneyIndefinite
from
December 15, 2005
Cassidy, Maureen E.Murphy, IDAttorneyIndefinite
from
December 15, 2005
Harrison, Rodney L.Urbana, ILAttorneyIndefinite
from
December 15, 2005
Cagle, Carol L.Alton, ILAttorneyIndefinite
from
December 15, 2005
Knaff, Philip J.Burr Ridge, ILAttorneyIndefinite
from
December 15, 2005
Pence, Thomas R.Cedar Rapids, IAAttorneyIndefinite
from
December 15, 2005
Tunney, John A.Freehold, NJAttorneyIndefinite
from
December 15, 2005
Dasent, CarltonMattapoisett, MAAttorneyIndefinite
from
December 15, 2005
May 1, 20068642006–18 I.R.B.

NameAddressDesignationDate of Suspension
Robeznieks, John O.Palatine, ILAttorneyIndefinite
from
December 15, 2005
Landman, Nathaniel M.St. Peters, MOAttorneyIndefinite
from
December 15, 2005
Levin, Herbert M.Bolingbrook, ILAttorneyIndefinite
from
December 15, 2005
Wade, Jeffrey L.Louisville, KYAttorneyIndefinite
from
December 15, 2005
Cozzarelli, Frank J.North Caldwell, NJAttorneyIndefinite
from
December 15, 2005
Brooks, Jane E.St. Paul, MNAttorneyIndefinite
from
December 15, 2005
Mulvahill, James P.Plymouth, MNAttorneyIndefinite
from
December 15, 2005
Bernstein, RalphChicago, ILAttorneyIndefinite
from
December 15, 2005
Tousey, Robert R.Ellicott City, MDAttorneyIndefinite
from
December 15, 2005
Schatz, Allen E.Shorewood, WIAttorneyIndefinite
from
December 16, 2005
Olson, David E.New Port Richey, FLAttorneyIndefinite
from
December 16, 2005
Shagory, Edward J.Boston, MAAttorneyIndefinite
from
December 20, 2005
Wintroub, Edward L.Omaha, NEAttorneyIndefinite
from
December 20, 2005
Johnson, Jr. Walter T.Greensboro, NCAttorneyIndefinite
from
December 27, 2005
Szaro, Stanley J.New York, NYAttorneyIndefinite
from
December 27, 2005
Recchione, LouisWoodcliff Lake, NJAttorneyIndefinite
from
December 27, 2005
2006–18 I.R.B.865May 1, 2006

NameAddressDesignationDate of Suspension
Pepper, LouisGreat Neck, NYAttorneyIndefinite
from
January 2, 2006
Fritzshall, Robert S.Skokie, ILAttorneyIndefinite
from
January 9, 2006
DiCaprio, Joseph A.Cherry Valley, ILAttorneyIndefinite
from
January 9, 2006
Rosenberg, Keith A.N. Bethesda, MDAttorneyIndefinite
from
January 9, 2006
Boudreau, Patricia L.Lexington, MAAttorneyIndefinite
from
January 9, 2006
Webb, Daniel F.Milwaukee, WIAttorneyIndefinite
from
January 9, 2006
Miranda, Jesse R.Phoenix, AZAttorneyIndefinite
from
January 9, 2006
Kuzel, GaryPlainfield, ILCPAIndefinite
from
January 9, 2006
Nomura, Edmund Y.Phoenix, AZAttorneyIndefinite
from
January 9, 2006
Mason, Robert J.Colorado Springs, COAttorneyIndefinite
from
January 9, 2006
Land, Janet P.Stedman, NCAttorneyIndefinite
from
January 9, 2006
Fitzgerald, MauriceLexington, MAAttorneyIndefinite
from
January 9, 2006
Valadez, Librado R.San Antonio, TXCPAIndefinite
from
January 9, 2006
Williams, Frank C.Houston, TXAttorneyIndefinite
from
January 9, 2006
LaGrand, TaraNaples, FLCPAIndefinite
from
January 9, 2006
Harris, Susan L.Houston, TXAttorneyIndefinite
from
January 9, 2006
May 1, 20068662006–18 I.R.B.

NameAddressDesignationDate of Suspension
Hobbs, James B.Amherst, NHAttorneyIndefinite
from
January 9, 2006
Momsen, JoelNapa, CAAttorneyIndefinite
from
January 10, 2006
Lambert, Brett J.Fort Collins, COAttorneyIndefinite
from
January 10, 2006
Lefevre, Keith H.Longwood, FLAttorneyIndefinite
from
January 13, 2006
Bronner, BernardGreat Neck, NYAttorneyIndefinite
from
January 18, 2006
Kuhnreich, Robert M.New York, NYAttorneyIndefinite
from
January 20, 2006
Walser, Vicki L.Valencia, CAAttorneyIndefinite
from
January 20, 2006
Menter, JeffreyCentennial, COAttorneyIndefinite
from
January 23, 2006
Catagnus, Patricia A.Richardson, TXCPAIndefinite
from
January 23, 2006
Matthews, Elizabeth B.Denver, COAttorneyIndefinite
from
January 23, 2006
Sisselman, Barry A.Temecula, CAAttorneyIndefinite
from
January 23, 2006
Armstrong, Thomas I.Irvine, CAAttorneyIndefinite
from
January 23, 2006
Chestnut, A. JohnsonFayetteville, NCCPAIndefinite
from
January 24, 2006
Kerby, John C.Desoto, TXCPAIndefinite
from
February 2, 2006
Phillips, John D.Albuquerque, NMAttorneyIndefinite
from
February 2, 2006
Broomas, JamesBaytown, TXAttorneyIndefinite
from
February 2, 2006
2006–18 I.R.B.867May 1, 2006

NameAddressDesignationDate of Suspension
Wilson, Joel M.Denver, NCCPAIndefinite
from
February 2, 2006
Olivieri Jr., Robert C.Bensalem, PACPAIndefinite
from
February 7, 2006
Scher, Robert A.Port Washington, NYAttorneyIndefinite
from
February 15, 2006
Mintz, David J.Evergreen, COAttorneyIndefinite
from
February 15, 2006
Abelson, Richard H.White Plains, NYAttorneyIndefinite
from
February 15, 2006
Drum, Joel A.Van Nuys, CAAttorneyIndefinite
from
February 17, 2006
Nissenbaum, SusanGrafton, MAAttorneyIndefinite
from
February 22, 2006
Mahon, Edward J.Warenville, ILAttorneyIndefinite
from
February 22, 2006
Nash, BruceChicago, ILAttorneyIndefinite
from
February 22, 2006
Duru, Ike E.Powder Springs, GAAttorneyIndefinite
from
February 22, 2006
Hirth, Gary E.Phoenix, AZAttorneyIndefinite
from
February 22, 2006
Madden, James G.Hudson, ILAttorneyIndefinite
from
February 22, 2006
Thomas, Robert C.Chicago,ILAttorneyIndefinite
from
February 22, 2006
Moore, Jr. William D.Libertyville, ILAttorneyIndefinite
from
February 22, 2006
Weit Jr., John V.Homewood, ILAttorneyIndefinite
from
February 22, 2006
Berlin, Marc D.Chicago, ILAttorneyIndefinite
from
February 22, 2006
May 1, 20068682006–18 I.R.B.

NameAddressDesignationDate of Suspension
Lebensbaum, HenryAndover, MDAttorneyIndefinite
from
February 22, 2006
Leonhart, Georgia L.Ocean View, DEAttorneyIndefinite
from
February 22, 2006
Wolf, Marvin H.Boynton Beach, FLAttorneyIndefinite
from
February 22, 2006
Dorsa, Lawrence R.Oceanside, CAAttorneyIndefinite
from
February 23, 2006
Battista Jr., Gerard F.Norwell, MAAttorneyIndefinite
from
February 27, 2006
Koehn, Charles R.Green Bay, WIAttorneyIndefinite
from
February 28, 2006
Phillips, Claudia L.Oak Park, CAAttorneyIndefinite
from
March 9, 2006
Zarate, Gustavo A.Pasadena, CAAttorneyIndefinite
from
March 9, 2006
Schorling, Douglas D.Fresno, CAAttorneyIndefinite
from
March 9, 2006
Bowman Jr., John J.Gibsonia, PAEnrolled AgentIndefinite
from
March 9, 2006
Jordan, Richard W.Austin, TXCPAIndefinite
from
March 9, 2006
Rothenberg, Steven G.Kingston, NYAttorneyIndefinite
from
March 24, 2006
Osterloh, Douglas D.Boring, ORAttorneyIndefinite
from
March 24, 2006
Benevenia, EugeneTucson, AZAttorneyIndefinite
from
March 24, 2006
Krombach, CharlesBrookfield, WIAttorneyIndefinite
from
March 24, 2006
Caldwell, David G.Austin, TXAttorneyIndefinite
from
March 24, 2006
2006–18 I.R.B.869May 1, 2006

NameAddressDesignationDate of Suspension
Zwibel, DavidLawrence, NYCPAIndefinite
from
March 31, 2006
Suspensions From Practice Before the Internal Revenue
Service After Notice and an Opportunity for a Proceeding
Under Title 31, Code of Federal Reg-
ulations, Part 10, after notice and an op-
portunity for a proceeding before an ad-
ministrative law judge, the following indi-
viduals have been placed under suspension
from practice before the Internal Revenue
Service:
NameAddressDesignationEffective Date
Fitzpatrick, PamelaArroyo Grande, CACPANovember 14, 2005
to
November 13, 2009
Disbarments From Practice Before the Internal Revenue
Service After Notice and an Opportunity for a Proceeding
Under Title 31, Code of Federal Regu-
lations, Part 10, after notice and an oppor-
tunity for a proceeding before an adminis-
trative law judge, the following individu-
als have been disbarred from practice be-
fore the Internal Revenue Service:
NameAddressDesignationEffective Date
Edgar, Richard A.Los Angeles, CACPAOctober 3, 2005
Censure Issued by Consent
Under Title 31, Code of Federal Reg-
ulations, Part 10, in lieu of a proceeding
being instituted or continued, an attorney,
certified public accountant, enrolled agent,
or enrolled actuary, may offer his or her
consent to the issuance of a censure. Cen-
sure is a public reprimand.
The following individuals have con-
sented to the issuance of a Censure:
NameAddressDesignationDate of Censure
Porter, Donald E.Burleson, TXCPAFebruary 10, 2006
May 1, 20068702006–18 I.R.B.

Resignations of Enrolled Agents
Under Title 31, Code of Federal Regu-
lations, Part 10, an enrolled agent, in or-
der to avoid the institution or conclusion
of a proceeding for his or her disbarment
or suspension from practice before the In-
ternal Revenue Service, may offer his or
her resignation as an enrolled agent. The
Director, Office of Professional Responsi-
bility, in his discretion, may accept the of-
fered resignation.
The Director, Office of Professional
Responsibility, has accepted offers of res-
ignation as an enrolled agent from the
following individuals:
NameAddressDate of Resignation
Casagna, Ronald M.Tustin, CANovember 25, 2005
NewForm8898,Statement
for Individuals Who Begin or
End Bona Fide Residence in
a U.S. Possession,andits
Instructions are Now Available
Announcement 2006–25
Beginning with tax year 2001, an in-
dividual with worldwide gross income of
more than $75,000 must file Form 8898
for the tax year in which the individual be-
comes or ceases to be abona fideresident
of one of the following U.S. possessions:
American Samoa, Guam, the Common-
wealth of the Northern Mariana Islands,
the Commonwealth of Puerto Rico, or the
U.S. Virgin Islands. The form is required
to be filed by Internal Revenue Code sec-
tion 937, which was added by the Ameri-
can Jobs Creation Act of 2004 (Public Law
108–357), and Treasury Regulation sec-
tion 1.937–1(h).
For married individuals, the $75,000
filing threshold applies to each spouse sep-
arately.
Individuals who are required to file
Form 8898 generally must do so by the
duedate(includingextensions) for filing
Form 1040 or Form 1040NR. However,
for tax years 2001 through 2005, Form
8898 must be filed by July 17, 2006. Indi-
viduals who have an extension to file their
2005 return must file Form 8898 for 2005
by the extended due date. Form 8898 must
be filed by itself and not with Form 1040
or Form 1040NR.
Form 8898 and its instructions can be
ordered by calling 1–800–829–3676 or can
be downloaded atwww.irs.gov.
Time and Manner of Making
Section 163(d)(4)(B) Election
to Treat Qualified Dividend
Income as Investment Income;
Correction
Announcement 2006–26
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations and removal
of temporary regulations.
SUMMARY: This document contains a
correction to temporary regulations (T.D.
9191, 2005–15 I.R.B. 854) that was pub-
lished in theFederal Registeron Friday,
March 18, 2005 (70 FR 13100) relating
to the time and manner of making section
163(d)(4)(B) election to treat qualified
dividend income as investment income.
DATES: This correction is effective March
18, 2005.
FOR FURTHER INFORMATION
CONTACT: Amy Pfalzgraf, (202)
622–4950 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulation (T.D. 9191) that is
the subject of this correction is under sec-
tion 163 of the Internal Revenue Code.
Need for Correction
As published, T.D. 9191, contains an
error that may prove to be misleading and
is in need of clarification.
*****
Correction of Publication
Accordingly, 26 CFR Part 1 is cor-
rected by making the following correcting
amendment:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 continues to read as follows:
Authority:26USC7805***
§1.163(d)–1T [Removed]
Section 1.163(d)–1T is removed.
Guy R. Traynor,
Chief, Publications & Regulations Branch,
Legal Processing Division,
Associate Chief Counsel
(Procedure & Administration).
(Filed by the Office of the Federal Register on April 11, 2006,
8:45 a.m., and published in the issue of the Federal Register
for April 12, 2006, 71 F.R. 18623)
Foundations Status of Certain
Organizations
Announcement 2006–27
The following organizations have failed
to establish or have been unable to main-
tain their status as public charities or as op-
erating foundations. Accordingly, grantors
and contributors maynot, 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 sec-
tion 508(b) of the Code. This listing does
notindicate that the organizations have lost
their status as organizations described in
section 501(c)(3), eligible to receive de-
ductible contributions.
2006–18 I.R.B.871May 1, 2006

Former Public Charities.The follow-
ing organizations (which have been treated
as organizations thatare not private foun-
dations described in section 509(a) of the
Code) are now classified as private foun-
dations:
ADA AJOKU Foundation,
Pembroke Pines, FL
Advance Care Services, Incorporated,
Detroit, MI
African Nation Out-Reach, Inc.,
Los Angeles, CA
Alices Wonderland Child Care of
Grace Memorial Baptist Church,
Baltimore, MD
American Business and Education
Partnership Association, Inc.,
South Glastonbury, CT
American Samoa Humane Society, Inc.,
Pago Pago, AS
An House of Prayer Word Center, Inc.,
Toledo, OH
Aspen Suite Foundation,
Stevenson Ranch, CA
Badasht Institute, Inc., Mystic, CT
Beacon Senior Housing Corp.,
Pasadena, CA
Bordentown Regional School
District Education Foundation,
Inc., Bordentown, NJ
Caring Hands of NJ, Inc., Piscataway, NJ
Chasing for Charities, Northport, NY
Chicago Principals & Administrators
Association, Chicago, IL
China Project Hope, Inc., Addison, TX
Circle R Youth Ranch, Inc.,
Fall Branch, TN
Clayton 20-20 Foundation, Inc.,
Jonesboro, GA
College of John Paul in the Desert,
Tucson, AZ
Commercial Development Fund,
St. Paul, MN
Cornerstone Environmental Conservancy
Corporation, Rochester, NY
CPIN,Inc.,Washington,DC
David Chapman Ministries, Inc.,
Stillwater, OK
Dayan Foundation, Los Altos, CA
Descendants of Signers of Declaration
of Independence Foundation, Inc.,
New York, NY
Disciples of Faith, Inc.,
Randallstown, MD
Eagle Condor Institute,
Sault Ste Marie, MI
Educational Initiatives Organization,
Lakewood, WA
Esthers House, Inc., Russelville, AR
First Step Academy, Richmond, VA
First Step Wellness Services, Inc.,
Lincoln, NE
Florida Amputee Support Team, Inc.,
Ft. Lauderdale, FL
Forward By Design, Inc., Columbia, SC
Foster Care Parents Services, Inc.,
Los Angeles, CA
Freedom-Hill Community Development
Corporation, Dayton, OH
Friends of Las Vegas Academy,
Las Vegas, NV
Friends of Longshore Sailing School, Inc.,
Westport, CT
Genesis Ministries, Inc., St. Albans, WV
Global Church Mission, Inc.,
Charlotte, NC
Greasy Creek Volunteer Fire Department,
Inc., Shelbiana, KY
Ground Zero Youth Outreach and
Development Programs, Inc.,
Atlanta, GA
Hampden Meadows School PTO,
Barrington, RI
Helena Celtic Association, Helena, MT
Hidalgo Independent School District
Scholarship Foundation, Hidalgo, TX
His Hands Foundation, Ashland, OR
Holdenville General Hospital Foundation,
Holdenville, OK
Homeless Low Income Housing and
Childcare, San Francisco, CA
Housing Opportunities Arizona One, Inc.,
Porter Ranch, CA
Human Potential Research Institute,
Stockton, CA
Hyasa Cultural Center, Burbank, CA
If One Reach One, Inc.,
Stone Mountain, GA
Innovative Ideas, Inc., Mount Horeb, WI
International Educational Exchange
Service, Inc., Dallas, TX
International Pain Research and Treatment
Foundation, Inc., Brooklyn, NY
Island Acts, Inc., New York, NY
Italian American Cultural Arts Corp.,
Yonkers, NY
JJK Charitable Trust, Ltd., St. Louis, MO
K A T S Association of Illinois, Inc.,
Chicago, IL
Kaumari Universal Corporation,
Decatur, GA
King George Band Parents Corp.,
King George, VA
Knights of Columbus Council 1959
Scholarship Fund, Wolf Point, MI
Leaders Loving Care, Inc.,
Stone Mountain, GA
Leadership Forum International,
Washington, DC
Lemhi River Salmon Recovery
Foundation, Inc., Missoula, MT
Little Lucys Child Care Center, Inc.,
North Las Vegas, NV
Living Hope Media, Arcamum, OH
Lizard Head Theatre Company,
Telluride, CO
MaDear, Inc., Riverside, CA
Margaret Patton Diabetes Foundation,
Los Angeles, CA
Master Preservation Foundation,
Cincinnati, OH
Morning Star Freedom Foundation,
Wauseon, OH
New Life Alpha Omega Ministries, Inc.,
Coconut Creek, FL
Nickelsville Area Recreation Association,
Inc., Nickelsville, VA
Northern Tier Neighborhood Crime
Watch, Great Bend, PA
Novosel Angels, Inc., N. Royalton, OH
Nu Dawn Living Arts Center,
Cleveland, OH
Oklahoma Endowment for Literacy and
Reading, Inc., Oklahoma City, OK
Omar Family Magnate Foundation, Inc.,
Valley Stream, NY
One Life-One Planet, Blacksburg, VA
Oppenheimer Institute for Science
and International Cooperation,
Albuquerque, NM
Pacific Islanders Learning and Support
Center, Newport Beach, CA
Parent Teacher Organization of Woodrow
Wilson Academy, Westminster, CO
Patricia Henley Foundation,
Santa Barbara, CA
PIMS, Seattle, WA
Pinellas County African American
History Museum, Inc., Clearwater, FL
Pointes Area Youth Orchestra,
Gross Pointe Park, MI
Portland Affordable Housing Preservation
Trust, Portland, OR
Promociones Evangelisticas De Dios,
Flushing, NY
Rain of Palm Beach County, Inc.,
Riviera Beach, FL
Rebirth Technologies, Inc.,
West Palm Beach, FL
River Cities Rollers, Sterling, IL
May 1, 20068722006–18 I.R.B.

Riverhead Revitalization & Preservation
Corporation, Riverhead, NY
Roger Savoy Foundation, Inc.,
New Orleans, LA
Santa Clara Speech & Debate Club,
Livermore, CA
Schola Cantorum Angelorum, Walnut, CA
Seattle Urban NatureProject, Seattle, WA
Sibley County Choral Society, Inc.,
Arlington, MN
Small Dog Rescue, Inc., Ypsilanti, MI
Southwest Dekalb Extra Point Club,
Decatur, GA
Storks Nest of Chattanooga,
Chattanooga, TN
Time Out for You, Inc., New Orleans, LA
TLC Play and Learn Campus, Inc.,
Fairhaven, MA
Touch of Hope, Inc., Newell, NC
Ujima, Inc., Chicago, IL
Union Hose and Engine Company, Inc.,
Union Springs, NY
United Churches of Galena, Inc.,
Galena, IL
United Coalition for Charitable,
Arlington, VA
Van Zandt County Blood Hound Team,
Wills Point, TX
Vivace Choral Program, Kapowsin, WA
Voices of Triumph Gospel Choir,
Parkersburg, WV
Vow Ministries, Houston, TX
Walltown Community, Durham, NC
Wayne Oakland McComb Support Group
& Foundation, Southfield, MI
Wisconsin Intramural Recreational Sports
Association, Eau Claire, WI
Women of Brooks Mill, Lithonia, GA
Women Working the Word, Inc.,
Philadelphia, PA
Yaco, Inc., Newport Beach, CA
Zakhat, Incorporated, Aliso Viejo, CA
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 Inter-
nal Revenue Service will issue a ruling or
determination letter with the revised clas-
sification 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.
Deletions From Cumulative
List of Organizations
Contributions to Which
are Deductible Under Section
170 of the Code
Announcement 2006–28
The name of an organization that no
longer qualifies as an organization de-
scribed in section 170(c)(2) of the Internal
Revenue Code of 1986 is 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
Bulletinthatanorganizationnolonger
qualifies. However, the Service is not
precluded from disallowing a deduction
for any contributions made after an or-
ganization ceases to qualify under section
170(c)(2) if the organization 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 determination 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 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 May 1, 2006, and
would end on the date the court first deter-
mines that the organization is not described
in section 170(c)(2) as more particularly
set forth in section 7428(c)(1). For indi-
vidual contributors, the maximum deduc-
tion protected is $1,000, with a husband
and wife treated as one contributor. This
benefit is not extended to any individual, in
wholeorinpart,fortheactsoromissions
of the organization that were the basis for
revocation.
Ameratrust, Inc.
Delray Beach, FL
2006–18 I.R.B.873May 1, 2006

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 describe the ef-
fect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is be-
ingextendedtoapplytoavariationofthe
fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that the
same principle also applies to B, the earlier
ruling is amplified. (Compare withmodi-
fied,below).
Clarifiedis used in those instances
where the language in a prior ruling is be-
ing made clear because the language has
caused, or may cause, some confusion.
It is not used where a position in a prior
ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
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 published position. (Compare
withamplifiedandclarified, above).
Obsoleteddescribes 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 rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
beingstatedinanewruling.
Supersededdescribes a situation where
the new ruling does nothing more than re-
state the substance and situation of a previ-
ously published ruling (or rulings). Thus,
the term is used to republish under the
1986 Code and regulations the same po-
sition published under the 1939 Code and
regulations. The term is also used when
it is desired to republish in a single rul-
ing a series of situations, names, etc., that
were previously published over a period of
time in separate rulings. If the new rul-
ing does more than restate the substance
of a prior ruling, a combination of terms
is used. For example,modifiedandsu-
persededdescribes a situation where the
substance of a previously published 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 pub-
lished ruling is first modified and then, as
modified, is superseded.
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 rul-
ing has been supplemented several times, a
new ruling may be published that includes
the list in the original ruling and the ad-
ditions, and supersedes all prior rulings in
the series.
Suspendedis used in rare situations
to show that the previous published rul-
ings 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 fol
lowing abbreviations in current use
and for
merly used will appear in material
publis
hedintheBulletin.
A—Individual.
Acq.—A
cquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank
.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cu
mulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Coo
perative.
Ct.D.—Court Decision.
CY—County.
D—Decede
nt.
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—Emp
loyer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduc
iary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Fo
reign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Fed
eral Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grante
e.
GP—General Partner.
GR—Grantor.
IC—Insura
nce Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited
Partner.
LR—Lessor.
M—Minor.
Nonacq.—No
nacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Persona
l Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Pa
rtnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Re
al Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsi
diary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target
Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Trans
feree.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpay
er.
TR—Trust.
TT—Trustee.
U.S.C.—Uni
ted States Code.
X—Corporation.
Y—Corporation.
Z—Corporat
ion.
May 1, 2006i2006–18 I.R.B.

Numerical Finding List
1
Bulletin 2006–1 through 2006–18
Announcements:
2006-1, 2006-1 I.R.B.260
2006-2, 2006-2 I.R.B.300
2006-3, 2006-3 I.R.B.327
2006-4, 2006-3 I.R.B.328
2006-5, 2006-4 I.R.B.378
2006-6, 2006-4 I.R.B.340
2006-7, 2006-4 I.R.B.342
2006-8, 2006-4 I.R.B.344
2006-9, 2006-5 I.R.B.392
2006-10, 2006-5 I.R.B.393
2006-11, 2006-6 I.R.B.420
2006-12, 2006-6 I.R.B.421
2006-13, 2006-7 I.R.B.462
2006-14, 2006-8 I.R.B.516
2006-15, 2006-11 I.R.B.632
2006-16, 2006-12 I.R.B.653
2006-17, 2006-12 I.R.B.653
2006-18, 2006-12 I.R.B.654
2006-19, 2006-13 I.R.B.674
2006-20, 2006-13 I.R.B.675
2006-21, 2006-14 I.R.B.703
2006-22, 2006-16 I.R.B.779
2006-23, 2006-14 I.R.B.729
2006-24, 2006-16 I.R.B.820
2006-25, 2006-18 I.R.B.871
2006-26, 2006-18 I.R.B.871
2006-27, 2006-18 I.R.B.871
2006-28, 2006-18 I.R.B.873
Court Decisions:
2081, 2006-13 I.R.B.656
2082, 2006-14 I.R.B.697
Notices:
2006-1, 2006-4 I.R.B.347
2006-2, 2006-2 I.R.B.278
2006-3, 2006-3 I.R.B.306
2006-4, 2006-3 I.R.B.307
2006-5, 2006-4 I.R.B.348
2006-6, 2006-5 I.R.B.385
2006-7, 2006-10 I.R.B.559
2006-8, 2006-5 I.R.B.386
2006-9, 2006-6 I.R.B.413
2006-10, 2006-5 I.R.B.386
2006-11, 2006-7 I.R.B.457
2006-12, 2006-7 I.R.B.458
2006-13, 2006-8 I.R.B.496
2006-14, 2006-8 I.R.B.498
2006-15, 2006-8 I.R.B.501
2006-16, 2006-9 I.R.B.538
2006-17, 2006-10 I.R.B.559
Notices— Continued:
2006-18, 2006-8 I.R.B.502
2006-19, 2006-9 I.R.B.539
2006-20, 2006-10 I.R.B.560
2006-21, 2006-12 I.R.B.643
2006-22, 2006-11 I.R.B.593
2006-23, 2006-11 I.R.B.594
2006-24, 2006-11 I.R.B.595
2006-25, 2006-11 I.R.B.609
2006-26, 2006-11 I.R.B.622
2006-27, 2006-11 I.R.B.626
2006-28, 2006-11 I.R.B.628
2006-29, 2006-12 I.R.B.644
2006-31, 2006-15 I.R.B.751
2006-32, 2006-13 I.R.B.677
2006-33, 2006-15 I.R.B.754
2006-34, 2006-14 I.R.B.705
2006-35, 2006-14 I.R.B.708
2006-36, 2006-15 I.R.B.756
2006-37, 2006-18 I.R.B.855
2006-38, 2006-16 I.R.B.777
2006-39, 2006-17 I.R.B.841
2006-40, 2006-18 I.R.B.855
2006-41, 2006-18 I.R.B.857
Proposed Regulations:
REG-107722-00, 2006-4 I.R.B.354
REG-104385-01, 2006-5 I.R.B.389
REG-122380-02, 2006-10 I.R.B.563
REG-137243-02, 2006-3 I.R.B.317
REG-133446-03, 2006-2 I.R.B.299
REG-113365-04, 2006-10 I.R.B.580
REG-148568-04, 2006-6 I.R.B.417
REG-106418-05, 2006-7 I.R.B.461
REG-138879-05, 2006-8 I.R.B.503
REG-143244-05, 2006-6 I.R.B.419
REG-146384-05, 2006-17 I.R.B.843
REG-146459-05, 2006-8 I.R.B.504
REG-157271-05, 2006-12 I.R.B.652
REG-164247-05, 2006-15 I.R.B.758
Revenue Procedures:
2006-1, 2006-1 I.R.B.1
2006-2, 2006-1 I.R.B.89
2006-3, 2006-1 I.R.B.122
2006-4, 2006-1 I.R.B.132
2006-5, 2006-1 I.R.B.174
2006-6, 2006-1 I.R.B.204
2006-7, 2006-1 I.R.B.242
2006-8, 2006-1 I.R.B.245
2006-9, 2006-2 I.R.B.278
2006-10, 2006-2 I.R.B.293
2006-11, 2006-3 I.R.B.309
2006-12, 2006-3 I.R.B.310
2006-13, 2006-3 I.R.B.315
2006-14, 2006-4 I.R.B.350
Revenue Procedures— Continued:
2006-15, 2006-5 I.R.B.387
2006-16, 2006-9 I.R.B.539
2006-17, 2006-14 I.R.B.709
2006-18, 2006-12 I.R.B.645
2006-19, 2006-13 I.R.B.677
2006-20, 2006-17 I.R.B.841
Revenue Rulings:
2006-1, 2006-2 I.R.B.261
2006-2, 2006-2 I.R.B.261
2006-3, 2006-2 I.R.B.276
2006-4, 2006-2 I.R.B.264
2006-5, 2006-3 I.R.B.302
2006-6, 2006-5 I.R.B.381
2006-7, 2006-6 I.R.B.399
2006-8, 2006-9 I.R.B.520
2006-9, 2006-9 I.R.B.519
2006-10, 2006-10 I.R.B.557
2006-11, 2006-12 I.R.B.635
2006-12, 2006-12 I.R.B.637
2006-13, 2006-13 I.R.B.656
2006-14, 2006-15 I.R.B.740
2006-15, 2006-13 I.R.B.661
2006-16, 2006-14 I.R.B.694
2006-17, 2006-15 I.R.B.748
2006-18, 2006-15 I.R.B.743
2006-19, 2006-15 I.R.B.749
2006-20, 2006-15 I.R.B.746
2006-21, 2006-15 I.R.B.745
2006-22, 2006-14 I.R.B.687
2006-23, 2006-17 I.R.B.839
Tax Conventions:
2006-6, 2006-4 I.R.B.340
2006-7, 2006-4 I.R.B.342
2006-8, 2006-4 I.R.B.344
2006-19, 2006-13 I.R.B.674
2006-20, 2006-13 I.R.B.675
2006-21, 2006-14 I.R.B.703
Treasury Decisions:
9231, 2006-2 I.R.B.272
9232, 2006-2 I.R.B.266
9233, 2006-3 I.R.B.303
9234, 2006-4 I.R.B.329
9235, 2006-4 I.R.B.338
9236, 2006-5 I.R.B.382
9237, 2006-6 I.R.B.394
9238, 2006-6 I.R.B.408
9239, 2006-6 I.R.B.401
9240, 2006-7 I.R.B.454
9241, 2006-7 I.R.B.427
9242, 2006-7 I.R.B.422
9243, 2006-8 I.R.B.475
9244, 2006-8 I.R.B.463
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2005–27 through 2005–52 is in Internal Revenue Bulletin
2005–52, dated December 27, 2005.
2006–18 I.R.B.iiMay 1, 2006

Treasury Decisions— Continued:
9245, 2006-14 I.R.B.696
9246, 2006-9 I.R.B.534
9247, 2006-9 I.R.B.521
9248, 2006-9 I.R.B.524
9249, 2006-10 I.R.B.546
9250, 2006-11 I.R.B.588
9251, 2006-11 I.R.B.590
9252, 2006-12 I.R.B.633
9253, 2006-14 I.R.B.689
9254, 2006-13 I.R.B.662
9255, 2006-15 I.R.B.741
9256, 2006-16 I.R.B.770
9257, 2006-17 I.R.B.821
May 1, 2006iii2006–18 I.R.B.

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2006–1 through 2006–18
Announcements:
2000-48
Modified by
Notice 2006-35, 2006-14 I.R.B.708
Notices:
2001-4
Sections (V)(C), (D), and (E) superseded by
T.D. 9253, 2006-14 I.R.B.689
2001-11
Superseded by
T.D. 9253, 2006-14 I.R.B.689
2001-43
Modified by
Notice 2006-35, 2006-14 I.R.B.708
Sections 2 and 3 superseded by
T.D. 9253, 2006-14 I.R.B.689
2002-35
Clarified and modified by
Notice 2006-16, 2006-9 I.R.B.538
2005-30
Modified and superseded by
Notice 2006-31, 2006-15 I.R.B.751
2005-44
Supplemented by
Notice 2006-1, 2006-4 I.R.B.347
2005-66
Supplemented by
Notice 2006-20, 2006-10 I.R.B.560
2005-73
Supplemented by
Notice 2006-20, 2006-10 I.R.B.560
2005-81
Supplemented by
Notice 2006-20, 2006-10 I.R.B.560
2005-98
Supplemented by
Notice 2006-7, 2006-10 I.R.B.559
Proposed Regulations:
REG-103829-99
Withdrawn by
Ann. 2006-16, 2006-12 I.R.B.653
REG-131739-03
Corrected by
Ann. 2006-10, 2006-5 I.R.B.393
Proposed Regulations— Continued:
REG-138647-04
Corrected by
Ann. 2006-4, 2006-3 I.R.B.328
REG-158080-04
Corrected by
Ann. 2006-11, 2006-6 I.R.B.420
Revenue Procedures:
96-52
Superseded by
Rev. Proc. 2006-10, 2006-2 I.R.B.293
97-27
Modified by
Rev. Proc. 2006-11, 2006-3 I.R.B.309
Modified and amplified by
Rev. Proc. 2006-12, 2006-3 I.R.B.310
2002-9
Modified by
Rev. Proc. 2006-11, 2006-3 I.R.B.309
Modified and amplified by
Rev. Proc. 2006-12, 2006-3 I.R.B.310
Rev. Proc. 2006-14, 2006-4 I.R.B.350
Rev. Proc. 2006-16, 2006-9 I.R.B.539
2002-17
Modified by
Rev. Proc. 2006-14, 2006-4 I.R.B.350
2003-31
Superseded by
Rev. Proc. 2006-19, 2006-13 I.R.B.677
2003-38
Modified by
Rev. Proc. 2006-16, 2006-9 I.R.B.539
2004-23
Superseded for certain taxable years by
Rev. Proc. 2006-12, 2006-3 I.R.B.310
2004-40
Superseded by
Rev. Proc. 2006-9, 2006-2 I.R.B.278
2005-1
Superseded by
Rev. Proc. 2006-1, 2006-1 I.R.B.1
2005-2
Superseded by
Rev. Proc. 2006-2, 2006-1 I.R.B.89
2005-3
Superseded by
Rev. Proc. 2006-3, 2006-1 I.R.B.122
2005-4
Superseded by
Rev. Proc. 2006-4, 2006-1 I.R.B.132
Revenue Procedures— Continued:
2005-5
Superseded by
Rev. Proc. 2006-5, 2006-1 I.R.B.174
2005-6
Superseded by
Rev. Proc. 2006-6, 2006-1 I.R.B.204
2005-7
Superseded by
Rev. Proc. 2006-7, 2006-1 I.R.B.242
2005-8
Superseded by
Rev. Proc. 2006-8, 2006-1 I.R.B.245
2005-9
Superseded for certain taxable years by
Rev. Proc. 2006-12, 2006-3 I.R.B.310
2005-12
Section 10 modified and superseded by
Rev. Proc. 2006-1, 2006-1 I.R.B.1
2005-15
Obsoleted in part by
Rev. Proc. 2006-17, 2006-14 I.R.B.709
2005-22
Obsoleted by
Rev. Proc. 2006-20, 2006-17 I.R.B.841
2005-24
Modified by
Notice 2006-15, 2006-8 I.R.B.501
2005-61
Superseded by
Rev. Proc. 2006-3, 2006-1 I.R.B.122
2005-68
Superseded by
Rev. Proc. 2006-1, 2006-1 I.R.B.1
Rev. Proc. 2006-3, 2006-1 I.R.B.122
Revenue Rulings:
55-355
Obsoleted by
T.D. 9244, 2006-8 I.R.B.463
74-503
Revoked by
Rev. Rul. 2006-2, 2006-2 I.R.B.261
77-230
Obsoleted by
T.D. 9249, 2006-10 I.R.B.546
91-5
Modified by
T.D. 9250, 2006-11 I.R.B.588
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2005–27 through 2005–52 is in Internal Revenue Bulletin 2005–52, dated December 27,
2005.
2006–18 I.R.B.ivMay 1, 2006

Revenue Rulings— Continued:
92-86
Modified by
T.D. 9250, 2006-11 I.R.B.588
Treasury Decisions:
9191
Corrected by
Ann. 2006-26, 2006-18 I.R.B.871
9192
Corrected by
Ann. 2006-15, 2006-11 I.R.B.632
9203
Corrected by
Ann. 2006-12, 2006-6 I.R.B.421
May 1, 2006v2006–18 I.R.B.
U.S. GPO: 2006—320–797/20055