Internal Revenue Bulletin 1998-48 (PDF rendition): IRS Revenue Procedures

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.

EMPLOYEE PLANS
Announcement 98–106, page 9.
The Service announces a change to the distribution codes to
be used on Form 1099–R, Distributions From Pensions,
Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance
Contracts, Etc., when reporting distributions from Roth IRAs.
EXEMPT ORGANIZATIONS
Announcement 98–107, page 10.
A list is given of organizations now classified as private foun-
dations.
Announcement 98–108, page 11.
A public hearing on proposed regulations REG–121268–97,
1998–20 I.R.B. 12, which clarify when the travel and tour
activities of tax exempt organizations are substantially relat-
ed to the purposes for which exemption was granted, will be
held on February 10, 1999.
ADMINISTRATIVE
REG–102023–98, page 6.
Proposed regulations under section 6011 of the Code relate
to the requirements for filing partnership returns on mag-
netic media. A public hearing will be held January 13, 1999.
Rev. Proc. 98–57, page 5.
Qualified Zone Academy Bond Limitations for 1999.
This procedures sets forth the maximum face amount of
Qualified Zone Academy Bonds that may be issued for each
State in 1999. For this purpose “State” includes the District
of Columbia and the possessions of the United States.
Internal Revenue
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Bulletin No. 1998–48
November 30, 1998
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
Department of the Treasury
Internal Revenue Service
Finding Lists begin on page 14.
IRB 1998-48 11/25/98 3:35 PM Page 1

The IRS Mission
Provide America’s taxpayers top quality service by help-
ing them understand and meet their tax responsibilities
and by applying the tax law with integrity and fairness to
all.
2
Statement of Principles
of Internal Revenue
Tax Administration
The function of the Internal Revenue Service is to adminis-
ter the Internal Revenue Code. Tax policy for raising revenue
is determined by Congress.
With this in mind, it is the duty of the Service to carry out that
policy by correctly applying the laws enacted by Congress;
to determine the reasonable meaning of various Code provi-
sions in light of the Congressional purpose in enacting them;
and to perform this work in a fair and impartial manner, with
neither a government nor a taxpayer point of view.
At the heart of administration is interpretation of the Code. It
is the responsibility of each person in the Service, charged
with the duty of interpreting the law, to try to find the true
meaning of the statutory provision and not to adopt a
strained construction in the belief that he or she is “protect-
ing the revenue.” The revenue is properly protected only
when we ascertain and apply the true meaning of the statute.
The Service also has the responsibility of applying and
administering the law in a reasonable, practical manner.
Issues should only be raised by examining officers when
they have merit, never arbitrarily or for trading purposes.
At the same time, the examining officer should never hesi-
tate to raise a meritorious issue. It is also important that
care be exercised not to raise an issue or to ask a court to
adopt a position inconsistent with an established Service
position.
Administration should be both reasonable and vigorous. It
should be conducted with as little delay as possible and
with great courtesy and considerateness. It should never
try to overreach, and should be reasonable within the
bounds of law and sound administration. It should, howev-
er, be vigorous in requiring compliance with law and it
should be relentless in its attack on unreal tax devices and
fraud.
IRB 1998-48 11/25/98 3:35 PM Page 2

The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing offi-
cial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
general interest. It is published weekly and may be obtained
from the Superintendent of Documents on a subscription
basis. Bulletin contents of a permanent nature are consoli-
dated semiannually into Cumulative Bulletins, which are sold
on a single-copy basis.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of in-
ternal management are not published; however, statements
of internal practices and procedures that affect the rights
and duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the
revenue ruling. In those based on positions taken in rulings
to taxpayers or technical advice to Service field offices,
identifying details and information of a confidential nature
are deleted to prevent unwarranted invasions of privacy and
to comply with statutory requirements.
Rulings and procedures reported in the Bulletin do not have
the force and effect of Treasury Department Regulations,
but they may be used as precedents. Unpublished rulings
will not be relied on, used, or cited as precedents by Service
personnel in the disposition of other cases. In applying pub-
lished rulings and procedures, the effect of subsequent leg-
islation, regulations, court decisions, rulings, and proce-
dures must be considered, and Service personnel and oth-
ers concerned are cautioned against reaching the same con-
clusions in other cases unless the facts and circumstances
are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions, and Subpart B, Legislation and Related
Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to
these subjects are contained in the other Parts and Sub-
parts. Also included in this part are Bank Secrecy Act Admin-
istrative Rulings. Bank Secrecy Act Administrative Rulings
are issued by the Department of the Treasury’s Office of the
Assistant Secretary (Enforcement).
Part IV.—Items of General Interest.
With the exception of the Notice of Proposed Rulemaking
and the disbarment and suspension list included in this part,
none of these announcements are consolidated in the Cumu-
lative Bulletins.
The first Bulletin for each month includes a cumulative index
for the matters published during the preceding months.
These monthly indexes are cumulated on a semiannual basis
and are published in the first Bulletin of the succeeding semi-
annual period, respectively.
3
Introduction
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402.
IRB 1998-48 11/25/98 3:35 PM Page 3

Section 1397E.—Credit to
Holders of Qualified Zone
Academy Bonds
What is the 1999 qualified zone academy bond
national limitation for each State, the District of Co-
lumbia, and the possessions of the United States?
See Rev. Proc. 98–57, page 5.
November 30, 199841998–48 I.R.B.
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
IRB 1998-48 11/25/98 3:35 PM Page 4

26 CFR 601.601: Rules and regulations.
(Also Part I, § 1397E)
Rev. Proc. 98–57
SECTION 1. PURPOSE
This revenue procedure sets forth the
maximum face amount of Qualified Zone
Academy Bonds (“Bond” or “Bonds”)
that may be issued for each State during
1999. For this purpose “State” includes
the District of Columbia and the posses-
sions of the United States.
SECTION 2. BACKGROUND
.01 Section 226 of the Tax Relief Act
of 1997, Pub. L. 105–34, 111 Stat. 788
(1997), added § 1397E to the Internal
Revenue Code to provide a credit to hold-
ers of Bonds under certain circumstances
so that the Bonds generally can be issued
without discount or interest. Ninety-five
percent of Bond proceeds are to be used
for qualified purposes, as defined by
§ 1397E(d)(5), with respect to a qualified
zone academy, as defined by
§ 1397E(d)(4).
.02 The aggregate amount of Bonds
that may be issued for the States is limited
to $400 million for 1998 and $400 million
for 1999 (the “national limitation”), un-
less the carryover provisions of
§ 1397E(e)(4) apply. This amount is to be
allocated among the States by the Secre-
tary on the basis of their respective popu-
lations below the poverty level (as de-
fined by the Office of Management and
Budget) and is to be further allocated by
the State to qualified zone academies
within the State or possession. A State
may carry forward to the next calendar
year any amount of an allocation of the
national limitation for a calendar year that
is in excess of the amount of Bonds issued
during that calendar year that are desig-
nated with respect to qualified academies
within the State.
.03 Rev. Proc. 98–9, 1998–3 I.R.B. 56,
allocated the national limitation for 1998
among the States and possessions.
SECTION 3. SCOPE
This revenue procedure applies to
Bonds issued under § 1397E during 1999.
SECTION 4. NATIONAL QUALIFIED
ZONE ACADEMY BOND
LIMITATION FOR 1999
The total face amount of bonds that
may be issued in 1999 is $400 million.
This amount is allocated among the States
as follows:
MAXIMUM FACE
AMOUNT OF
BONDS THAT
MAY BE ISSUED
DURING 1999
STATE(thousands of dollars)
ALABAMA$ 7,015
ALASKA591
ARIZONA8,408
ARKANSAS5,433
CALIFORNIA57,589
COLORADO3,376
CONNECTICUT2,975
DELAWARE760
DISTRICT OF
COLUMBIA1,192
FLORIDA21,689
GEORGIA11,699
HAWAII1,730
IDAHO1,931
ILLINOIS14,231
INDIANA5,433
IOWA2,848
KANSAS2,637
KENTUCKY6,572
LOUISIANA7,290
MAINE1,308
MARYLAND4,452
MASSACHUSETTS7,722
MICHIGAN10,613
MINNESOTA4,821
MISSISSIPPI4,800
MISSOURI6,614
MONTANA1,466
NEBRASKA1,720
NEVADA2,004
NEW HAMPSHIRE1,150
MAXIMUM FACE
AMOUNT OF
BONDS THAT
MAY BE ISSUED
DURING 1999
STATE(thousands of dollars)
NEW JERSEY$ 7,775
NEW MEXICO4,083
NEW YORK31,426
NORTH CAROLINA8,851
NORTH DAKOTA918
OHIO12,986
OKLAHOMA4,810
OREGON4,030
PENNSYLVANIA14,104
RHODE ISLAND1,266
SOUTH CAROLINA5,275
SOUTH DAKOTA1,234
TENNESSEE8,345
TEXAS34,781
UTAH1,952
VERMONT570
VIRGINIA9,051
WASHINGTON5,581
WEST VIRGINIA3,017
WISCONSIN4,452
WYOMING696
AMERICAN SAMOA367
GUAM217
NORTHERN
MARIANAS337
PUERTO RICO23,484
VIRGIN ISLANDS323
SECTION 6. EFFECTIVE DATE
This revenue procedure applies to
Bonds issued after December 31, 1998.
DRAFTING INFORMATION
The principal author of this revenue
procedure is Rose Weber of the Office of
Assistant Chief Counsel (Financial Insti-
tutions & Products). For further informa-
tion regarding this revenue procedure
contact Ms. Weber on (202) 622-3980
(not a toll free call).
1998–48 I.R.B.5November 30, 1998
Part III. Administrative, Procedural, and Miscellaneous
IRB 1998-48 11/25/98 3:35 PM Page 5

November 30, 199861998–48 I.R.B.
Notice of Proposed Rulemaking
and Notice of Public Hearing
Partnership Returns Required on
Magnetic Media
REG–102023–98
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of proposed rulemak-
ing and notice of public hearing.
SUMMARY: This document contains
proposed regulations relating to the re-
quirements for filing partnership returns
on magnetic media under section 6011(e)
of the Internal Revenue Code. The pro-
posed regulations reflect changes to the
law made by the Taxpayer Relief Act of
1997. The proposed regulations affect
partnerships with more than 100 partners.
This document also provides a notice of a
public hearing on these proposed regula-
tions.
DATES: Written comments must be re-
ceived by January 21, 1999. Requests to
speak (with outlines of oral comments) at
the public hearing scheduled for January
13, 1999, must be received by December
23, 1998.
ADDRESSES: Send submissions to:
CC:DOM:CORP:R (REG–102023–98),
Room 5228, Internal Revenue Service,
POB 7604, Ben Franklin Station, Wash-
ington, DC 20044. Submissions may be
hand delivered Monday through Friday
between the hours of 8 a.m. and 5 p.m. to:
CC:DOM:CORP:R (REG–102023–98),
Courier’s Desk, Internal Revenue Ser-
vice, 1111 Constitution Avenue NW,
Washington, DC.
Alternatively, taxpayers may submit com-
ments electronically via the Internet by
selecting the “Tax Regs” option on the
IRS Home Page, or by submitting com-
ments directly to the IRS Internet site at
htpp://www.irs.ustreas.gov/prod/tax_regs/
comments.html. The public hearing will
be held in Room 2615, Internal Revenue
Building, 1111 Constitution Avenue, NW,
Washington, DC 20224.
FOR FURTHER INFORMATION CON-
TACT: Concerning the proposed regula-
tions, Bridget E. Finkenaur, 202-622-
4940; concerning submissions of
comments, the hearing, and/or to be
placed on the building access list to attend
the hearing, Mike Slaughter, 202-622-
7190 (not toll-free numbers).
SUPPLEMENTARY INFORMATION:
Background
This document contains proposed
amendments to the Regulations on Proce-
dure and Administration (26 CFR part
301) relating to the filing of partnership
returns on magnetic media under section
6011(e)(2) of the Internal Revenue Code.
Section 6011(e)(2) was amended by sec-
tion 1224 of the Taxpayer Relief Act of
1997, Public Law 105–34 (111 Stat. 788
(1997)) (the Act), effective for taxable
years ending on or after December 31,
1997. Section 6012(e) of the Internal
Revenue Service Restructuring and Re-
form Act of 1998, Public Law 105–206
(112 Stat. 685 (1998)), changes the effec-
tive date of section 1224 of the Act to tax-
able years beginning after December 31,
1997.
Section 6011(e) authorizes the Secre-
tary to prescribe regulations providing the
standards for determining which returns
must be filed on magnetic media or in
other machine-readable form. Section
6011(e)(2)(A) provides that the regula-
tions may not require any person to file
returns on magnetic media unless the per-
son is required to file at least 250 returns
during the calendar year. However, the
last sentence of section 6011(e)(2), which
was added by section 1224 of the Act,
provides that the Secretary must prescribe
regulations requiring partnerships with
more than 100 partners to file returns on
magnetic media. In addition, section
6011(e)(2)(B) requires that the regula-
tions take into account (among other rele-
vant factors) the ability of the taxpayer to
comply at reasonable cost with the re-
quirements of the regulations.
Currently, the IRS permits certain part-
nerships to file their partnership returns on
magnetic media (including magnetic tape,
floppy disk, and electronic filing) with the
Internal Revenue Service Center in An-
dover, Massachusetts. Under this volun-
tary program, participants have the option
of: (1) submitting the entire partnership
tax return (including Form 1065, U.S.
Partnership Return of Income, Schedules
K-1, Partner’s Share of Income, Credits,
Deductions, etc., and all other related
forms and schedules) on magnetic media,
or (2) submitting only the Schedules K-1
on magnetic media and filing the rest of
the partnership return on paper.
In Notice 97–77 (1997–52 I.R.B. 18
(December 29, 1997)), the IRS notified
taxpayers that the Act’s amendment to
section 6011(e)(2) is not self-executing.
Rather, the IRS must first issue regula-
tions that would require partnerships with
more than 100 partners to file their part-
nership returns on magnetic media. Ac-
cordingly, partnerships were not required
to file their 1997 partnership returns on
magnetic media.
Explanation of Provisions
In General
The proposed regulations provide that
partnerships with more than 100 partners
must file their partnership returns on mag-
netic media. The determination of
whether a partnership has more than 100
partners is made by counting the number
of partners the partnership had over the
partnership’s taxable year, regardless of
whether a partner was a partner for the en-
tire year or whether the partnership had
over 100 partners on any particular day in
the year.
The proposed regulations provide that a
partnership return is a form in Series 1065
(including Form 1065, U.S. Partnership
Return of Income, and Form 1065–B,
U.S. Return of Income for Electing Large
Partnerships), along with the correspond-
ing Schedules K-1 and all other related
forms and schedules that are required to
be attached to the Series 1065 form.
Magnetic media means any magnetic
media permitted under applicable regula-
tions, revenue procedures, or publica-
tions. The IRS will prescribe procedures
for participation in the mandatory mag-
netic media filing program for partner-
ships with more than 100 partners. In-
Part IV. Items of General Interest
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1998–48 I.R.B.7November 30, 1998
cluded in those procedures will be meth-
ods for registering for the program and
signing the partnership return. The proce-
dures will be contained in applicable rev-
enue procedures or publications.
The term magnetic media generally in-
cludes magnetic tape, tape cartridge, and
diskette, as well as other media (such as
electronic filing). Consistent with the de-
finition of magnetic media in other regu-
lations, the proposed regulations define
magnetic media broadly. However, under
these regulations, the Service plans to re-
quire partnerships with more than 100
partners to file their partnership returns
electronically. These requirements for
electronic filing will be detailed in applic-
able revenue procedures or publications.
The IRS and Treasury Department be-
lieve that requiring affected partnerships
to file electronically will enhance the
quality of IRS’s customer service and will
reduce the costs associated with maintain-
ing the ability to accept forms in a variety
of magnetic media. Furthermore, the IRS
and Treasury Department believe that
electronic filing has less burden on tax-
payers than filing using other forms of
magnetic media.
Electronic filing reduces the normal
processing time associated with paper re-
turns in that there is minimal hands-on
processing and, therefore, there are no pa-
perwork delays. Faster processing means
faster settling of accounts and better cus-
tomer service. Electronic filing also re-
duces errors and increases security by re-
ducing duplicate or erroneous returns. In
addition, taxpayers receive prompt ac-
knowledgment that their returns have
been received and accepted by the Inter-
nal Revenue Service. Finally, electronic
filing reduces the operating costs for tax-
payers whose data already resides on a
computer system. Overall, electronic fil-
ing of partnership returns should increase
customer satisfaction and confidence in
the filing process, and be more cost effec-
tive for partnerships.
Although the IRS Service Center in
Andover, Massachusetts currently accepts
returns in the voluntary program on vari-
ous forms of magnetic media, the systems
at this facility are not year 2000 compliant
and will not be in operation after 1999.
Accordingly, in designing its new mag-
netic media systems to accept electroni-
cally filed returns only, the IRS antici-
pates that it will no longer be able to ac-
cept returns filed in the form currently
used by some partnerships in the volun-
tary program.
Hardship Waiver
The proposed regulations provide pro-
cedures for granting waivers of the mag-
netic media filing requirements for one or
more years in cases of hardship. A deter-
mination of hardship will be based upon
all of the facts and circumstances. Some
factors that will be considered in granting
waivers include the reasonableness of the
incremental cost to the partnership of
complying with the magnetic media filing
requirements as well as temporary equip-
ment breakdowns and destruction of mag-
netic media filing equipment.
Penalties
The proposed regulations provide that
if a partnership has more than 100 part-
ners and is required to file a partnership
return, but fails to file its Series 1065
form, accompanying Schedules K-1, and
all other related forms and schedules in
the manner required, the partnership is
deemed to have failed to file correct infor-
mation returns for purposes of the infor-
mation reporting penalty under section
6721. Penalties for failure to file correct
information returns would apply for each
Schedule K-1 that is not filed using per-
missible magnetic media.
Proposed Effective Dates
The IRS is currently focusing a signifi-
cant portion of its resources on the Year
2000 date change. In addition, the IRS is
developing new programs to accommo-
date the new Form 1065–B and partner-
ship returns filed with a foreign address
on the Series 1065 form. Further, partner-
ships will have to update their processes
and technology to implement the elec-
tronic filing requirements.
Taking these factors into consideration,
the proposed regulations would delay the
effective date for filing partnership re-
turns on magnetic media, and phase in the
magnetic media filing of certain partner-
ship returns. Thus, the proposed regula-
tions would be generally effective for
partnership returns for partnership taxable
years ending on or after December 31,
1999. However, electing large partner-
ships under section 775 and partnerships
using foreign addresses on their Series
1065 forms would not be required to file
their partnership returns using magnetic
media for taxable years ending before
January 1, 2001.
Special Analyses
It is hereby certified that the regula-
tions in this document will not have a sig-
nificant economic impact on a substantial
number of small entities. This certifica-
tion is based on a determination that these
regulations will impose no additional re-
porting or recordkeeping requirement and
will prescribe only the method for filing
partnership returns that are already re-
quired to be filed under section 6031. Ac-
cordingly, a Regulatory Flexibility Analy-
sis under the Regulatory Flexibility Act (5
U.S.C. chapter 6) is not required.
It has been determined that this notice
of proposed rulemaking is not a signifi-
cant regulatory action as defined in EO
12866. Therefore, a regulatory assess-
ment is not required.
Pursuant to section 7805(f) of the Inter-
nal Revenue Code, this notice of pro-
posed rulemaking will be submitted to the
Chief Counsel for Advocacy of the Small
Business Administration for comment on
its impact on small business.
Comments and Public Hearing
Before these proposed regulations are
adopted as final regulations, considera-
tion will be given to any comments that
are submitted timely to the IRS. All com-
ments will be available for public inspec-
tion and copying.
A public hearing has been scheduled
for Wednesday, January 13, 1999, at 10
a.m. in Room 2615 of the Internal Rev-
enue Building, 1111 Constitution Av-
enue, NW, Washington, DC. Due to
building security procedures, visitors
must enter at the 10th Street entrance, lo-
cated between Constitution and Pennsyl-
vania Avenues, NW. In addition, all visi-
tors must present photo identification to
enter the building. Because of access re-
strictions, visitors will not be admitted be-
yond the immediate entrance area more
than 15 minutes before the hearing starts.
For information about having your name
IRB 1998-48 11/25/98 3:35 PM Page 7

November 30, 199881998–48 I.R.B.
placed on the building access list to attend
the hearing, see the “FOR FURTHER IN-
FORMATION CONTACT” section of
this preamble.
The rules of 26 CFR 601.601(a)(3)
apply to the hearing.
Persons that wish to present oral com-
ments at the hearing must submit com-
ments and an outline of the topics to be
discussed and the time to be devoted to
each topic by December 23, 1998.
A period of 10 minutes will be allotted
to each person for making comments.
An agenda showing the scheduling of
the speakers will be prepared after the
deadline for receiving outlines has
passed. Copies of the agenda will be
available free of charge at the hearing.
Drafting Information
The principal author of these proposed
regulations is Bridget E. Finkenaur, Of-
fice of the Assistant Chief Counsel (In-
come Tax and Accounting). However,
other personnel from the IRS and Trea-
sury Department participated in the devel-
opment of these proposed regulations.
*****
Proposed Amendments to the Regulations
Accordingly, 26 CFR parts 1 and 301
are proposed to be amended as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 continues to read as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2 Section 1.6031(a) as proposed to
be added at 63 F.R. 3679 is amended by
adding paragraph (e)(i)(iv) read as fol-
lows:
§1.6031(a)–1 Return of partnership
income.
* * * * *
(e) * * *
(1)* * *
(iv) Returns filed on magnetic media.
Notwithstanding the provisions of para-
graphs (e)(1)(i) and (ii) of this section, the
return of a partnership that is required to
be filed on magnetic media under
§301.6011–3 of this chapter must be filed
at the Service Center indicated in relevant
Internal Revenue Service revenue proce-
dures, publications, forms, or instructions.
* * * * *
PART 301—PROCEDURE AND
ADMINISTRATION
Par. 4. The authority citation for part
301 is amended by adding an entry in nu-
merical order to read as follows:
Authority: 26 U.S.C. 7805 * * *
Section 301.6011–3 also issued under 26
U.S.C. 6011; * * *
Par. 5. Section 301.6011–3 is added to
read as follows:
§301.6011–3 Required use of magnetic
media for partnership returns.
(a) Partnership returns required on
magnetic media.If a partnership with
more than 100 partners is required to file
a partnership return pursuant to
§1.6031(a)–1 of this chapter, the informa-
tion required by the applicable forms and
schedules must be filed on magnetic
media, except as otherwise provided in
paragraph (b) of this section. Returns
filed on magnetic media must be made in
accordance with applicable revenue pro-
cedures or publications. In prescribing
revenue procedures or publications, the
Commissioner may determine that part-
nerships will be required to use any one
form of magnetic media filing. For exam-
ple, the Commissioner may determine
that partnerships with more than 100 part-
ners must file their partnership returns
electronically. In filing its return, a part-
nership must register to participate in the
magnetic media filing program in the
manner prescribed by the Internal Rev-
enue Service in applicable revenue proce-
dures or publications.
(b) Waiver. The Commissioner may
waive the requirements of this section if
hardship is shown in a request for waiver
filed in accordance with this paragraph
(b). A determination of hardship will be
based upon all of the facts and circum-
stances. One factor in determining hard-
ship will be the reasonableness of the in-
cremental cost to the partnership of
complying with the magnetic media filing
requirements. Other factors, such as
equipment breakdowns or destruction of
magnetic media filing equipment, also
may be considered. A request for waiver
must be made in accordance with applica-
ble revenue procedures or publications.
The waiver will specify the type of part-
nership return and the period to which it
applies. The waiver will also be subject
to such terms and conditions regarding
the method of filing as may be prescribed
by the Commissioner.
(c) Failure to file.If a partnership
fails to file a partnership return on mag-
netic media in the manner required and
when required to do so by this section, the
partnership will be deemed to have failed
to file the return in the manner prescribed
for purposes of the information return
penalty under §6721. See §301.6724–
1(c)(3) for rules regarding the waiver of
penalties for undue economic hardship
relating to filing returns on magnetic
media.
(d) Meaning of terms.The following
definitions apply for purposes of this sec-
tion:
(1) Magnetic media.The term mag-
netic media means any magnetic media
permitted under applicable regulations,
revenue procedures, or publications.
These generally include magnetic tape,
tape cartridge, and diskette, as well as
other media (such as electronic filing)
specifically permitted under the applicable
regulations, procedures, or publications.
(2) Partnership.The term partnership
means a partnership as defined in §1.761-
1(a) of this chapter.
(3) Partner.The term partnermeans a
member of a partnership as defined in
§7701(a)(2).
(4) Partnership return.The term part-
nership returnmeans a form in Series
1065 (including Form 1065, U.S. Partner-
ship Return of Income, and Form 1065-B,
U.S. Return of Income for Electing Large
Partnerships), along with the correspond-
ing Schedules K-1 and all other related
forms and schedules that are required to
be attached to the Series 1065 form.
(5) Partnerships with more than 100
partners.A partnership has more than
100 partners if, over the course of the
partnership’s taxable year, the partnership
had more than 100 partners, regardless of
whether a partner was a partner for the en-
tire year or whether the partnership had
over 100 partners on any particular day in
the year. For purposes of this paragraph
(d)(5), however, only those persons hav-
ing a direct interest in the partnership
IRB 1998-48 11/25/98 3:35 PM Page 8

1998–48 I.R.B.9November 30, 1998
must be considered partners for purposes
of determining the number of partners
during the partnership’s taxable year.
(e) Examples.The following examples
illustrate the provisions of paragraph
(d)(5) of this section. In the examples, the
partnerships utilize the calendar year, and
the taxable year in question is 1999:
Example 1. Partnership P had five general part-
ners and 90 limited partners on January 1, 1999. On
March 15, 1999, 10 more limited partners acquired
an interest in P. On September 30, 1999, the 10
newest partners sold their individual partnership in-
terests to C, a corporation which was one of the orig-
inal 90 limited partners. On December 31, 1999, P
had the same five general partners and 90 limited
partners it had on January 1, 1999. P had a total of
105 partners over the course of partnership taxable
year 1999. Therefore, P must file its 1999 partner-
ship return on magnetic media.
Example 2. Partnership Q is a general partner-
ship that had 95 partners on January 1, 1999. On
March 15, 1999, 10 partners sold their individual
partnership interests to corporation D, which was
not previously a partner in Q. On September 30,
1999, corporation D sold one-half of its partnership
interest in equal shares to five individuals, who were
not previously partners in Q. On December 31,
1999, Q had a total of 91 partners, and on no date in
the year did Q have more than 100 partners. Over
the course of the year, however, Q had 101 partners.
Therefore, Q must file its 1999 partnership return on
magnetic media.
Example 3.Partnership G is a general partner-
ship with 100 partners on January 1, 1999. There
are no new partners added to G in 1999. One of G’s
partners, A, is a partnership with 53 partners. A is
one partner, regardless of the number of partners A
has. Therefore, G has 100 partners and is not re-
quired to file its 1999 partnership return on magnetic
media.
(f) Effective date.In general, this sec-
tion applies to partnership returns for tax-
able years ending on or after December
31, 1999. However, electing large part-
nerships under §775 and partnerships
using foreign addresses on their Series
1065 forms are not required to file using
magnetic media for taxable years ending
before January 1, 2001.
Par. 6. Section 301.6031–1 is revised
to read as follows:
§301.6031–1 Return of partnership
income.
For provisions relating to the require-
ment of returns of partnership income, see
§1.6031(a)–1 of this chapter. For provi-
sions relating to magnetic media filing of
partnership returns, see §301.6011–3.
Par. 7. Section 301.6721–1 is amended
by removing the third, fourth, and fifth
sentences of paragraph (a)(2)(ii) and
adding four sentences in their place to
read as follows:
§301.6721–1 Failure to file correct
information returns.
(a) * * *
(2) * * *
(ii) * * * However, no penalty is im-
posed under paragraph (a)(1) of this sec-
tion solely by reason of any failure to
comply with the requirements of
§6011(e)(2), except to the extent that such
a failure occurs with respect to more than
250 information returns (the 250-thresh-
old requirement) or in the case of a part-
nership with more than 100 partners,
more than 100 information returns (the
100-threshold requirement) (collectively,
the threshold requirements). Each Sched-
ule K-1 considered in applying the 100-
threshold requirement will be treated as a
separate information return. These
threshold requirements apply separately
to each type of information return re-
quired to be filed. Further, these thresh-
old requirements apply separately to orig-
inal and corrected returns. * * *
* * * * *
Michael P. Dolan,
Deputy Commissioner of
Internal Revenue.
(Filed by the Office of the Federal Register on
October 22, 1998, 8:45 a.m., and published in the
issue of the Federal Register for October 23, 1998,
63 F.R. 56878)
Changes to Codes for Roth IRAs on Form 1099–R
Announcement 98–106
PurposeThe purpose of this announcement is to advise payers making distributions from Roth IRAs of
changes to the distributions codes on Form 1099–R, Distributions From Pensions, Annuities, Retire-
ment or Profit-Sharing Plans, IRAs, Insurance Contracts, etc.
BackgroundThe Internal Revenue Service Restructuring and Reform Act of 1998 (Public Law 105–206) amended
Internal Revenue Code section 408A, dealing with Roth IRAs. Because of these amendments, the
Service has concluded that code K (Distribution from a 1998 Roth conversion IRA in the first 5 years)
on the 1998 Form 1099–R may not be needed. In addition, a new code for recharacterizations is
needed.
1998 Form 1099–RCode K, to be used in box 7 on the 1998 Form 1099–R, is now optional. All distributions from a Roth
IRA or Roth conversion IRA can be reported using code J, Distribution from a Roth IRA in first 5
years, in box 7.
1999 Form 1099–RCode K will be eliminated on the 1999 Form 1099–R. Code J will be changed to “Distribution from a
Roth IRA.” Use Code J when reporting any distribution from a Roth IRA or Roth conversion IRA.
Code R, Recharacterized IRA contribution, will be added to identify a recharacterization of an IRA
contribution.
IRB 1998-48 11/25/98 3:35 PM Page 9

Foundations Status of Certain
Organizations
Announcement 98–107
The following organizations have
failed to establish or have been unable to
maintain their status as public charities or
as operating foundations. Accordingly,
grantors and contributors may not, after
this date, rely on previous rulings or des-
ignations in the Cumulative List of Orga-
nizations (Publication 78), or on the pre-
sumption arising from the filing of notices
under section 508(b) of the Code. This
listing does notindicate that the organiza-
tions have lost their status as organiza-
tions described in section 501(c)(3), eligi-
ble to receive deductible contributions.
Former Public Charities.The following
organizations (which have been treated as
organizations that are not private founda-
tions described in section 509(a) of the
Code) are now classified as private foun-
dations:
Austin Metropolitan Economic
Development Corporation, Austin, TX
Autonomous Zone Foundation, Chicago,
IL
Avery County Agricultural and
Horticultural Fair Inc., Newland, NC
Awakening Inc., Milwaukee, WI
Awareness Communication Incorporated,
Williamsport, PA
B & J Community Care Home,
Columbia, SC
B A I R, South San Francisco, CA
B A Y Theatre Co. Inc., Birmingham,
AL
BABC Inc., Denver, CO
Babe Ruth League of Brockton,
Brockton, MA
Babe Ruth League of Somerville Inc.,
Somerville, MA
Backcountry Volunteers Inc., N. Scituate,
MA
Backstage Inc., Decatur, AL
Backstage Productions Inc., Atlanta, GA
Bainbridge Educational Foundation Inc.,
Princeton, NJ
Bakersfield Alliance Soccer Club,
Bakersfield, CA
Balkan Rape Trauma Response Coalition,
Chicago, IL
Ballet Theatre North, Northbrook, IL
Baltimore Softball Club, Baltimore, MD
Banyan House Inc., Sarasota, FL
Barnell Communications Inc., Miami, FL
Baroda Charitable Educational Fund Inc.,
Bristol, PA
Barren River Imaginative Museum of
Science Inc., Bowling Green, KY
Basic 4 Food and Nutrition Program,
Houston, TX
Basic of Louisiana Inc., New Orleans,
LA
Batesville Community Day Care Inc.,
Batesville, IN
Battered and Harassed Women and
Children Incorporated, Houston, TX
Battered Womens Fund, Tyler, TX
Bay Area Homes Network, Antioch, CA
Bay Area Multicultural
Telecommunications Association, San
Francisco, CA
Bay City Youth Football Association,
Bay City, TX
Bay Minette Rotary Village Inc., Bay
Minette, AL
Bayards Chimney Rock Museum,
Bayard, NE
Baylor Ministries Inc., Moreno Valley,
CA
BBB Housing Inc., Youngstown, OH
BCCU Inc. Clearfield, Clearfield, UT
BDC Brokerage Management
Corporation, Baltimore, MD
Be True To Yourself Foundation, Seattle,
WA
Beaverhead Community Food Pantry
Inc., Ellon, MT
Beck Hilderbrand Historic Preservation
Commission Inc., Bixby, OK
Becky Bos Memorial Scholarship Fund,
East Jordan, MI
Beeches Crabtree Foundation Inc.,
Guthrie, OK
Believe Inc., Fort Worth, TX
Bells for Books Inc., Boise, ID
Bellwether Community Loan Fund Inc.,
Toledo, OH
Belmont Dare Inc., Belmont, MA
Beloved Ministries, Corpus Christi, TX
Beltway Lady Cougars Inc., Upper
Marlboro, MD
Ben Radar Youth Foundation, Lewes, DE
Bergen Girls Recreational Softball
League Inc., Montvale, NJ
Berkshire School of Creative Speech Inc.,
Great Barriugton, MA
Berry Basket Quilters Inc., Medford, NJ
Best Care Help Services, Humble, TX
Beta Beta Educational Foundation Inc.,
Indianapolis, IN
Beth Dudley Scholarship Fund, Marietta,
GA
Bethabara Shoppes Inc., Winston Salem,
NC
Bethel Cultural Community
Development Center Inc., Brooklyn,
NY
Bethesda After-School Care Program
Inc., Aberdeen, NC
Bethesda House Inc., Brooklyn, NY
Bethlehem Inc., Bethany, OK
Bettendorf Jaycees Foundation,
Bettendorf, IA
Better Quality of Life Inc., Landover,
MD
Between Us Sisters Starting to Operate
Proficiently, Stockton, CA
BEU Community Housing Development
Organization Inc., Cleveland, OH
Beverly Park Playground Project,
Livonia, MI
Bi-State Illinois and Iowa Chapter of the
Southern Christian, Rock Island, IL
Bicycle Transportation Alliance of
Portland Inc., Portland, ME
Big Brother and Big Sister Inc.,
Bismarck, ND
Big Brother Big Sister of the Midlands,
Santee, SC
Big Brothers and Big Sisters of N.
Central Arkansas Inc., Conway, AR
Big Brothers Big Sisters Foundation of
Manatee County Florida Inc.,
Bradenton, FL
Big Lake Elementary School Parent
Teacher Student Organization, Elk
River, MN
Big Sky Sculpture Council, Billings, MT
Big World Ventures Inc., Albuquerque,
NM
Bill Cobb Ministries Inc., Bethany, OK
Billerica Youth Soccer Association,
Billerica, MA
Binghamton Outreach Center Inc.,
Binghamton, NY
Bios the Western New York Lead
Institute, Buffalo, NY
Birmingham Association of Black
Journalists Inc., Birmingham, AL
Birth Parents Support, Cincinnati, OH
Birthright of Greater Meriden Inc.,
Meriden, CT
Black Family Foundation Inc., Brooklyn,
NY
Black Healthcare Initiative Coalition Inc.,
Rockford, IL
Black Sheep Theater Company Inc.,
New York, NY
Black United Federation of Texas
Charities Inc., Houston, TX
November 30, 1998101998–48 I.R.B.
IRB 1998-48 11/25/98 3:35 PM Page 10

1998–48 I.R.B.11November 30, 1998
Black Women Community Organization
Inc., Kansas City, KS
Blackhawk Central City Railway &
Mining Museum LTD., Englewood,
CO
Blacks United to Save Our Youths,
Cleveland, OH
Blanchard School Parent Advisory
Council Inc., Uxbridge, MA
Blink Inc., Visalia, CA
Bloomfield Academy Inc., Bloomfield,
CT
Bludance Theatre Inc., Kent, CT
Blue Veil Ministry Inc., Tucson, AZ
Blue World Conservancy LTS., Haddam,
CT
Bluff Swamp Wildlife Refuge &
Botanical Garden Inc., Prairieville, LA
Blunt Park Athletic Assoc. of Springfield
Massachusetts, Springfield, MA
BNS Family Solutions, Kalamazoo, MI
Bob Fry Memorial Golf Tournament,
Walcott, IA
Bob Smith Ministries Inc., Boca Raton,
FL
Boise Basin Interpretive Association Inc.,
Idaho City, ID
Book-Link Foundation Inc., Tupelo, MS
Books Building a Childs Future, Irving,
TX
Books for Life, Pittsford, VT
Bookworms Resource Center,
Philadelphia, PA
Boone County Court Appointed Special
Advocate Inc., Florence, KY
Bosque County Tourism Council
Incorporated, Meridian, TX
Boulder County Business Hall of Fame
Inc., Boulder, CO
Boulder-Dushanbe Teahouse Trust,
Boulder, CO
Boulder Valley Hockey Foundation,
Boulder, CO
Boulderiety Inc., Boulder, CO
Bound for Success, Dallas, TX
Boyd Adult Care Group Homes
Incorporated, Toledo, OH
Boys & Girls Club of Warren Inc.,
Warren, MA
Boys and Girls Club of Chico California
Inc., Chico, CA
Boys and Girls Club of Wayne and Pike
Counties Inc., Hamlin, PA
Brad Smith Music Ministries,
Brentwood, TN
Brazos 2020 Vision Inc., Bryan, TX
Brazos Summer Explorers Inc., Bryan,
TX
Brazos Valley Regional Advisory
Council, College Station, TX
Bread of Life Christian Mission, Plant
City, FL
Breast Cancer Coalition of NJ Inc.,
Trenton, NJ
Brenham-Washington County Swim Club
Inc., Brenham, TX
Bridge and Gate Productions Inc.,
Sunnyvale, CA
Bridge to Victory Inc., Ft. Lauderdale, FL
Bridgeport Cultural Trust Inc.,
Bridgeport, CT
Bridges to Community Inc., Chappaqua,
NY
Bridgewater Partnership Inc.,
Bridgewater, MA
Bridgework for a Better Tomorrow
Association, Raleigh, NC
Briggs-Delaine Cultural Center,
Summerton, SC
Bristow Education Foundation Inc.,
Bristow, OK
British American Drama Academy,
San Francisco, CA
Broadhurst Charity Foundation,
Manchester, MO
Bronx Second Chance Project Inc.,
Bronx, NY
Brooks Brothers Christian Alliance
Incorporated, Tulsa, OK
Brookside Housing Services Corp., South
Plainfield, NJ
Broome County Sheriffs Foundation,
Vestal, NY
Brotherhood Association of America
Development Inc., Oklahoma City, OK
Broussards Nutrition Program, Houston,
TX
Brownsville Area Redstone Field Light
Committee, Brownsville, PA
Brownsville Boxing Club, Brownsville,
TX
Brownsville Community Neighborhood
Action Center No. 1, Brooklyn, NY
Bruce Williams Ministries Inc.,
Columbia, SC
Bryan Police Activities League Inc.,
Bryan, TX
Buckeye Cheerleading Coaches
Association Inc., Canton, OH
Bucks County Christian Action Council,
Doylestown, PA
Buffalo Coalition for Common Ground,
Buffalo, NY
Buffalo Public Housing Resident Council
Corp., Buffalo, NY
Build America Inc., Overland Park, KS
Builders for Peace Inc., Washington, DC
Building Bridges Inc., Monticello, MN
Bunker Softball Association, Bunker, MO
Burlington Symphony Orchestra,
Burlington, NJ
Business-Higher Education Federation,
Washington, DC
Butler County Men Mission Inc.,
Eldorado, KS
By His Spirit Ministries, Titusville, FL
If an organization listed above submits
information that warrants the renewal of
its classification as a public charity or as a
private operating foundation, the Internal
Revenue Service will issue a ruling or de-
termination letter with the revised classi-
fication as to foundation status. Grantors
and contributors may thereafter rely upon
such ruling or determination letter as pro-
vided in section 1.509(a)–7 of the Income
Tax Regulations. It is not the practice of
the Service to announce such revised clas-
sification of foundation status in the Inter-
nal Revenue Bulletin.
Travel and Tour Activities of
Exempt Organizations; Hearing
Announcement 98–108
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of public hearing on
proposed rulemaking.
SUMMARY: This document contains a
notice of public hearing on proposed reg-
ulations that clarify when the travel and
tour activities of tax exempt organizations
are substantially related to the purposes
for which exemption was granted.
DATES: The public hearing is being held
on Wednesday, February 10, 1999, at 10
a.m. The IRS must receive outlines of
topics to be discussed at the hearing by
January 20, 1999.
ADDRESSES: The public hearing is
being held in room 2615, Internal Rev-
enue Building, 1111 Constitution Avenue,
NW, Washington, DC. Due to building
security procedures, visitors must enter at
the 10th Street entrance, located between
Constitution and Pennsylvania Avenues,
NW. In addition, all visitors must present
photo identification to enter the building.
IRB 1998-48 11/25/98 3:35 PM Page 11

Mail outlines to: CC:DOM:CORP:R
(REG–121268–97), room 5226, Internal
Revenue Service, POB 7604, Ben
Franklin Station, Washington, DC 20044.
Hand deliver outlines Monday through
Friday between the hours of 8 a.m. and 5
p.m. to: CC:DOM:CORP:R (REG–
121268–97), Courier’s Desk, Internal
Revenue Service, 1111 Constitution
Avenue, NW, Washington, DC. Submit
outlines electronically via the Internet by
selecting the “Tax Regs” option on the
IRS Home Page, or by submitting them
directly to the IRS Internet site at
http://www.irs.ustreas.gov/prod/tax_regs/
comments.html.
FOR FURTHER INFORMATION CON-
TACT: Concerning submissions of com-
ments, the hearing, and/or to be placed on
the building access list to attend the hear-
ing LaNita VanDyke, (202) 622-7190 (not
a toll-free number).
SUPPLEMENTARY INFORMATION:
The subject of the public hearing is
proposed regulations (REG–121268–97)
that were published in the Federal Regis-
teron April 23, 1998 (63 F.R. 20156
[1998–20 I.R.B. 12]).
The rules of 26 CFR 601.601(a)(3)
apply to the hearing.
Persons who have submitted written
comments and wish to present oral com-
ments at the hearing, must submit an out-
line of the topics to be discussed and the
amount of time to be devoted to each
topic (signed original and eight (8)
copies) by January 20, 1999.
A period of 10 minutes is allotted to
each person for presenting oral com-
ments.
After the deadline for receiving out-
lines has passed, the IRS will prepare an
agenda containing the schedule of speak-
ers. Copies of the agenda will be made
available, free of charge, at the hearing.
Because of access restrictions, the IRS
will not admit visitors beyond the imme-
diate entrance area more than 15 minutes
before the hearing starts. For information
about having your name placed on the
building access list to attend the hearing,
see the “FOR FURTHER INFORMA-
TION CONTACT” section of this docu-
ment.
Cynthia E. Grigsby,
Chief, Regulations Unit,
Assistant Chief Counsel (Corporate).
(Filed by the Office of the Federal Register on
November 9, 1998, 8:45 a.m., and published in the
issue of the Federal Register for November 10, 1998,
63 F.R. 63016)
November 30, 1998121998–48 I.R.B.
IRB 1998-48 11/25/98 3:35 PM Page 12

1998–48 I.R.B.13November 30, 1998
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus,
if an earlier ruling held that a principle
applied to A, and the new ruling holds
that the same principle also applies to B,
the earlier ruling is amplified. (Compare
with modified, below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously
published ruling and points out an essen-
tial difference between them.
Modified is used where the substance
of a previously published position is
being changed. Thus, if a prior ruling
held that a principle applied to A but not
to B, and the new ruling holds that it ap-
plies to both A and B, the prior ruling is
modified because it corrects a published
position. (Compare with amplified and
clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used
in a ruling that lists previously published
rulings that are obsoleted because of
changes in law or regulations. A ruling
may also be obsoleted because the sub-
stance has been included in regulations
subsequently adopted.
Revoked describes situations where the
position in the previously published rul-
ing is not correct and the correct position
is being stated in the new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a pe-
riod of time in separate rulings. If the
new ruling does more than restate the
substance of a prior ruling, a combination
of terms is used. For example, modified
and superseded describes a situation
where the substance of a previously pub-
lished ruling is being changed in part and
is continued without change in part and it
is desired to restate the valid portion of
the previously published ruling in a new
ruling that is self contained. In this case
the previously published ruling is first
modified and then, as modified, is super-
seded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and
that list is expanded by adding further
names in subsequent rulings. After the
original ruling has been supplemented
several times, a new ruling may be pub-
lished that includes the list in the original
ruling and the additions, and supersedes
all prior rulings in the series.
Suspended is used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current use and for-
merly used will appear in material published in the
Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C.—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contribution Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign Corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statements of Procedral Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Definition of Terms
IRB 1998-48 11/25/98 3:35 PM Page 13

November 30, 1998141998–48 I.R.B.
Numerical Finding List
1
Bulletins 1998–29 through 47
Announcements:
98–62, 1998–29 I.R.B. 13
98–68, 1998–29 I.R.B. 14
98–69, 1998–30 I.R.B. 16
98–70, 1998–30 I.R.B. 17
98–71, 1998–30 I.R.B. 17
98–72, 1998–31 I.R.B.14
98–73, 1998–31 I.R.B.14
98–74, 1998–31 I.R.B.15
98–75, 1998–31 I.R.B.15
98–76, 1998–32 I.R.B.64
98–77, 1998–34 I.R.B.30
98–78, 1998–34 I.R.B.30
98–79, 1998–34 I.R.B.31
98–80, 1998–34 I.R.B.32
98–81, 1998–36 I.R.B.35
98–82, 1998–35 I.R.B. 17
98–83, 1998–36 I.R.B. 36
98–84, 1998–38 I.R.B.30
98–85, 1998–38 I.R.B.30
98–86, 1998–38 I.R.B.31
98–87, 1998–40 I.R.B.11
98–88, 1998–41 I.R.B. 14
98–89, 1998–40 I.R.B.11
98–90, 1998–42 I.R.B.22
98–91, 1998–40 I.R.B.12
98–92, 1998–41 I.R.B.15
98–93, 1998–43 I.R.B.10
98–94, 1998–43 I.R.B.32
98–95, 1998–44 I.R.B.13
98–96, 1998–44 I.R.B.18
98–97, 1998–44 I.R.B.18
98–98, 1998–44 I.R.B.18
98–99, 1998–46 I.R.B.34
98–100, 1998–46 I.R.B.42
98–101, 1998–45 I.R.B.27
98–102, 1998–45 I.R.B.28
98–103, 1998–47 I.R.B.12
98–104, 1998–47 I.R.B. 13
Court Decisions:
2063, 1998–36 I.R.B. 13
2064, 1998–37 I.R.B. 4
2065, 1998–39 I.R.B.7
Notices:
98–36, 1998–29 I.R.B. 8
98–37, 1998–30 I.R.B.13
98–38, 1998–34 I.R.B.7
98–39, 1998–33 I.R.B.11
98–40, 1998–35 I.R.B. 7
98–41, 1998–33 I.R.B.12
98–42, 1998–33 I.R.B.12
98–43, 1998–33 I.R.B.13
98–44, 1998–34 I.R.B.7
98–45, 1998–35 I.R.B.7
98–46, 1998–36 I.R.B. 21
98–47, 1998–37 I.R.B. 8
98–48, 1998–39 I.R.B.17
98–49, 1998–38 I.R.B.5
98–50, 1998–44 I.R.B.10
98–51, 1998–44 I.R.B. 11
98–52, 1998–46 I.R.B. 16
98–53, 1998–46 I.R.B. 24
Notices—Continued
98–54, 1998–46 I.R.B. 25
98–55, 1998–46 I.R.B. 26
98–56, 1998–47 I.R.B.9
98–57, 1998–47 I.R.B.9
Railroad Retirement Quarterly Rate:
1998–31 I.R.B. 7
Proposed Regulations:
REG–209446–82, 1998–36 I.R.B. 24
REG–209060–86, 1998–39 I.R.B. 18
REG–209769–95, 1998–41 I.R.B.8
REG–209813–96, 1998–35 I.R.B. 9
REG–246256–96, 1998–34 I.R.B.9
REG–104641–97, 1998–29 I.R.B. 9
REG–104565–97, 1998–39 I.R.B.21
REG–106177–97, 1998–37 I.R.B.33
REG–109708–97, 1998–45 I.R.B.29
REG–115446–97, 1998–36 I.R.B. 23
REG–116608–97, 1998–29 I.R.B. 12
REG–118926–97, 1998–39 I.R.B.23
REG–118966–97, 1998–39 I.R.B.29
REG–119227–97, 1998–30 I.R.B. 13
REG–122488–97, 1998–42 I.R.B. 19
REG–101363–98, 1998–40 I.R.B.10
REG–106221–98, 1998–41 I.R.B.10
REG–110332–98, 1998–33 I.R.B.18
REG–110403–98, 1998–29 I.R.B.11
REG–115393–98, 1998–39 I.R.B.34
Revenue Procedures:
98–40, 1998–32 I.R.B. 6
98–41, 1998–32 I.R.B. 7
98–42, 1998–28 I.R.B. 9
98–43, 1998–29 I.R.B. 8
98–44, 1998–32 I.R.B. 11
98–45, 1998–34 I.R.B.8
98–46, 1998–36 I.R.B. 21
98–47, 1998–37 I.R.B. 8
98–48, 1998–38 I.R.B.7
98–49, 1998–37 I.R.B. 9
98–50, 1998–38 I.R.B.8
98–51, 1998–38 I.R.B.20
98–52, 1998–37 I.R.B. 12
98–53, 1998–40 I.R.B.9
98–54, 1998–43 I.R.B.7
98–55, 1998–46 I.R.B.27
98–56, 1998–46 I.R.B.33
Revenue Rulings:
98–34, 1998–31 I.R.B. 12
98–35, 1998–30 I.R.B. 4
98–36, 1998–31 I.R.B.6
98–37, 1998–32 I.R.B.5
98–38, 1998–32 I.R.B.4
98–39, 1998–33 I.R.B.4
98–40, 1998–33 I.R.B.4
98–41, 1998–35 I.R.B.6
98–42, 1998–35 I.R.B. 5
98–43, 1998–36 I.R.B. 9
98–44, 1998–37 I.R.B.4
98–45, 1998–38 I.R.B.4
98–46, 1998–39 I.R.B. 10
98–47, 1998–39 I.R.B. 4
98–48, 1998–39 I.R.B. 6
Revenue Rulings—Continued
98–49, 1998–40 I.R.B.4
98–50, 1998–40 I.R.B.7
98–51, 1998–43 I.R.B.4
98–52, 1998–45 I.R.B.4
98–53, 1998–46 I.R.B.12
98–54, 1998–46 I.R.B.24
98–55, 1998–47 I.R.B. 5
98–56, 1998–47 I.R.B.5
Tax Conventions:
1998–43 I.R.B. 6
Treasury Decisions:
8771, 1998–29 I.R.B. 6
8772, 1998–31 I.R.B. 8
8773, 1998–29 I.R.B. 4
8774, 1998–30 I.R.B. 5
8775, 1998–31 I.R.B.4
8776, 1998–33 I.R.B.6
8777, 1998–34 I.R.B.4
8778, 1998–36 I.R.B. 4
8779, 1998–36 I.R.B. 11
8780, 1998–39 I.R.B.14
8781, 1998–40 I.R.B. 4
8782, 1998–41 I.R.B.5
8783, 1998–41 I.R.B.4
8784, 1998–42 I.R.B.4
8785, 1998–42 I.R.B.5
8786, 1998–44 I.R.B. 4
8787, 1998–46 I.R.B. 5
8788, 1998–45 I.R.B.6
1
A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 1998–1 through 1998–28
will be found in Internal Revenue Bulletin 1998–29,
dated July 20, 1998.
IRB 1998-48 11/25/98 3:35 PM Page 14

1998–48 I.R.B.15November 30, 1998
Finding List of Current Action on
Previously Published Items
1
Bulletins 1998–29 through 47
*Denotes entry since last publication
Notices:
87–13
Modified by
98–49, 1998–38 I.R.B. 5
87–16
Modified by
98–49, 1998–38 I.R.B. 5
Revenue Procedures:
83–58
Obsoleted by
98–37, 1998–32 I.R.B. 5
88–17
Clarified, modified, and superseded by
98–54, 1998–43 I.R.B. 7
94–23
Amplified and superseded by
98–55, 1998–46 I.R.B. 27
97–40
Amplified and superseded by
98–55, 1998–46 I.R.B. 27
97–60
Superseded by
98–50, 1998–38 I.R.B. 8
97–61
Superseded by
98–51, 1998–38 I.R.B. 20
98–14
Modified by
98–53, 1998–40 I.R.B. 9
Revenue Rulings:
57–271
Obsoleted by
98–37, 1998–32 I.R.B. 5
67–301
Modified by
98–41, 1998–35 I.R.B. 6
70–225
Obsoleted by
98–44, 1998–37 I.R.B. 4
71–277
Obsoleted by
98–37, 1998–32 I.R.B. 5
71–434
Obsoleted by
98–37, 1998–32 I.R.B. 5
71–574
Obsoleted by
98–37, 1998–32 I.R.B. 5
72–75
Obsoleted by
98–37, 1998–32 I.R.B. 5
72–120
Obsoleted by
98–37, 1998–32 I.R.B. 5
Revenue Rulings—Continued
72–121
Obsoleted by
98–37, 1998–32 I.R.B. 5
72–122
Obsoleted by
98–37, 1998–32 I.R.B. 5
74–77
Obsoleted by
98–37, 1998–32 I.R.B. 5
75–19
Obsoleted by
98–37, 1998–32 I.R.B. 5
76–562
Obsoleted by
98–37, 1998–32 I.R.B. 5
77–214
Obsoleted by
98–37, 1998–32 I.R.B. 5
79–106
Obsoleted by
98–37, 1998–32 I.R.B. 5
83–113
Obsoleted by
98–37, 1998–32 I.R.B. 5
85–143
Obsoleted by
98–37, 1998–32 I.R.B. 5
88–8
Obsoleted by
98–37, 1998–32 I.R.B. 5
88–76
Obsoleted by
98–37, 1998–32 I.R.B. 5
88–79
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–4
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–5
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–6
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–30
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–38
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–49
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–50
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–53
Obsoleted by
98–37, 1998–32 I.R.B. 5
Revenue Rulings—Continued
93–81
Obsoleted by
98–37, 1998–32 I.R.B. 5
3–91
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–92
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–93
Obsoleted by
98–37, 1998–32 I.R.B. 5
94–5
Obsoleted by
98–37, 1998–32 I.R.B. 5
94–6
Obsoleted by
98–37, 1998–32 I.R.B. 5
94–30
Obsoleted by
98–37, 1998–32 I.R.B. 5
94–51
Obsoleted by
98–37, 1998–32 I.R.B. 5
94–79
Obsoleted by
98–37, 1998–32 I.R.B. 5
95–2
Obsoleted by
98–37, 1998–32 I.R.B. 5
95–9
Obsoleted by
98–37, 1998–32 I.R.B. 5
97–37
Obsoleted by
98–39, 1998–33 I.R.B. 4
1
A cumulative finding list for previously published
items mentioned in Internal Revenue Bulletins
1998–1 through 1998–28 will be found in Internal
Revenue Bulletin 1998–29, dated July 20, 1998.
IRB 1998-48 11/25/98 3:35 PM Page 15

Notes
November 30, 1998161998–48 I.R.B.
IRB 1998-48 11/25/98 3:35 PM Page 16

Notes
1998–48 I.R.B.17November 30, 1998
IRB 1998-48 11/25/98 3:35 PM Page 17

Notes
November 30, 1998181998–48 I.R.B.
IRB 1998-48 11/25/98 3:35 PM Page 18

IRB 1998-48 11/25/98 3:35 PM Page 19

INTERNAL REVENUE BULLETIN
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IRB 1998-48 11/25/98 3:35 PM Page 20