us-irs-revenue-procedures-irb-1999-15-pdf•Internal Revenue Bulletin 1999-15 (PDF rendition): IRS Revenue Procedures
Internal Revenue Bulletin 1999-15 (PDF rendition): IRS Revenue Procedures
us-irs-revenue-procedures-irb-1999-15-pdfInternal Revenue Bulletin 1999-15 (PDF rendition): IRS Revenue ProceduresGuidance
Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.
INCOME TAX Rev. Rul. 99–19, page 3. LIFO; price indexes; department stores.The February 1999 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with reference to, February 28, 1999. EXEMPT ORGANIZATIONS Announcement 99–23, page 7. A list is given of organizations now classified as private foun- dations. ADMINISTRATIVE Rev. Proc. 99–22, page 5. Qualified mortgage bonds; mortgage credit certifi- cates; national median gross income.Guidance is pro- vided concerning the use of the national and area median gross income figures by issuers of qualified mortgage bonds and mortgage credit certificates in determining the housing cost/income ratio described in section 143(f)(5) of the Code. Rev. Proc. 98–28 is obsolete except as provided in section 5.02 of this revenue procedure. Announcement 99–34, page 8. The Service announces an additional delay in format changes to Form W-2 and W-3 until tax year 2001. Announcement 99–37, page 9. Effective immediately, all applications for extension of time to file Forms 5500, 5500–C/R, and 5500–EZ will be auto- matically approved if the request (Form 5558) is filed on or before the normal due date of the return or report. Announcement 99–38, page 9. This document contains a notice of public hearing on pro- posed regulations REG–105170–97, 1998–50 I.R.B. 10, re- lating to the computation of the credit under section 41(c) and the definition of qualified research under section 41(d). A public hearing is scheduled for April 29, 1999. Announcement 99–39, page 10. This document contains corrections to T.D. 8812, 1999–8 I.R.B. 19, which was published in the Federal Register on February 3, 1999 (64 F.R. 5160), relating to continuation coverage requirements applicable to group health plans. Internal Revenue bbuulllleettiinn Bulletin No. 1999–15 April 12, 1999 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 16. Announcement of Disbarments and Suspensions begins on page 11. IRB 1999-15 4/7/99 12:57 PM Page 1 The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing offi- cial rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It is published weekly and may be obtained from the Superintendent of Documents on a subscription basis. Bulletin contents are consolidated semiannually into Cumulative Bulletins, which are sold on a single-copy basis. It is the policy of the Service to publish in the Bulletin all sub- stantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless other- wise indicated. Procedures relating solely to matters of in- ternal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published. Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements. Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying pub- lished rulings and procedures, the effect of subsequent leg- islation, regulations, court decisions, rulings, and proce- dures must be considered, and Service personnel and oth- ers concerned are cautioned against reaching the same con- clusions in other cases unless the facts and circumstances are substantially the same. The Bulletin is divided into four parts as follows: Part I.—1986 Code. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1986. Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions, and Subpart B, Legislation and Related Committee Reports. Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Sub- parts. Also included in this part are Bank Secrecy Act Admin- istrative Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement). Part IV.—Items of General Interest. This part includes notices of proposed rulemakings, disbar- ment and suspension lists, and announcements. The first Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the first Bulletin of the succeeding semi- annual period, respectively. Mission of the Service 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 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 1999-15 4/7/99 12:57 PM Page 2 Section 25.—Interest on Certain Home Mortgages 26 CFR 1.25–4T: Qualified mortgage credit certificate program (temporary). Guidance is provided for the use of the national and area median gross income figures by issuers of qualified mortgage bonds and mortgage credit cer- tificates in determining the housing cost/income ratio described in section 143(f)(5) of the Code. See Rev. Proc. 99–22, page 5. Section 103.—State and Local Bonds 26 CFR 1.103–1: Interest upon obligations of a State, Territory, etc. Guidance is provided for the use of the national and area median gross income figures by issuers of qualified mortgage bonds and mortgage credit cer- tificates in determining the housing cost/income ratio described in section 143(f)(5) of the Code. See Rev. Proc. 99–22, page 5. Section 143.—Mortgage Revenue Bonds: Qualified Mortgage Bond and Qualified Veterans’ Mortgage Bond 26 CFR 6a.103A–2: Qualified mortgage bond. Guidance is provided for the use of the national and area median gross income figures by issuers of qualified mortgage bonds and mortgage credit cer- tificates in determining the housing cost/income ratio described in section 143(f)(5) of the Code. See Rev. Proc. 99–22, page 5. Section 472.—Last-in, First-out Inventories 26 CFR 1.472–1: Last-in, first-out inventories. LIFO; price indexes; department stores.The February 1999 Bureau of Labor Statistics price indexes are ac- cepted for use by department stores em- ploying the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with reference to, February 28, 1999. Rev. Rul. 99–19 The following Department Store In- ventory Price Indexes for February 1999 were issued by the Bureau of Labor Sta- tistics. The indexes are accepted by the Internal Revenue Service, under § 1.472– 1(k) of the Income Tax Regulations and Rev. Proc. 86–46, 1986–2 C.B. 739, for appropriate application to inventories of department stores employing the retail inventory and last-in, first-out inventory methods for tax years ended on, or with reference to, February 28, 1999. The Department Store Inventory Price Indexes are prepared on a national basis and include (a) 23 major groups of de- partments, (b) three special combinations of the major groups - soft goods, durable goods, and miscellaneous goods, and (c) a store total, which covers all depart- ments, including some not listed sepa- rately, except for the following: candy, food, liquor, tobacco, and contract de- partments. 1999–15 I.R.B.3April 12, 1999 Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 BUREAU OF LABOR STATISTICS, DEPARTMENT STORE INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS (January 1941 = 100, unless otherwise noted) Percent Change Feb.Feb.from Feb.1998 Groups1998 1999 to Feb. 1999 1 1. Piece Goods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .535.8496.2–7.4 2. Domestics and Draperies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .639.3643.10.6 3. Women’s and Children’s Shoes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .656.9632.3–3.7 4. Men’s Shoes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .886.5889.80.4 5. Infants’ Wear . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .612.6619.61.1 6. Women’s Underwear . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .565.2565.80.1 7. Women’s Hosiery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .308.1320.0 3.9 8. Women’s and Girls’ Accessories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .548.2549.60.3 9. Women’s Outerwear and Girls’ Wear . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .408.9380.3–7.0 10. Men’s Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .624.0617.4–1.1 11. Men’s Furnishings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .590.4592.20.3 12. Boys’ Clothing and Furnishings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .499.3478.3–4.2 13. Jewelry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1001.0983.3–1.8 14. Notions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .802.0741.9–7.5 15. Toilet Articles and Drugs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .926.5951.62.7 16. Furniture and Bedding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .668.3679.21.6 17. Floor Coverings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .583.7602.73.3 18. Housewares . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .810.3808.2–0.3 19. Major Appliances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .242.0233.8–3.4 20. Radio and Television . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .73.669.0–6.3 IRB 1999-15 4/7/99 12:57 PM Page 3 BUREAU OF LABOR STATISTICS, DEPARTMENT STORE INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS (Continued) (January 1941 = 100, unless otherwise noted) Percent Change Feb.Feb.from Feb.1998 Groups1998 1999 to Feb. 1999 1 21. Recreation and Education 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .107.7100.1–7.1 22. Home Improvements 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .134.0129.8–3.1 23. Auto Accessories 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .107.7107.70.0 Groups 1 – 15: Soft Goods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .601.1590.3–1.8 Groups 16 – 20: Durable Goods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .462.4455.6–1.5 Groups 21 – 23: Misc. Goods 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .111.0105.5–5.0 Store Total 3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .552.3540.7–2.1 1 Absence of a minus sign before percentage change in this column signifies price increase. 2 Indexes on a January 1986=100 base. 3 The store total index covers all departments, including some not listed separately, except for the following: candy, food, liquor, tobacco, and contract departments. April 12, 199941999–15 I.R.B. DRAFTING INFORMATION The principal author of this revenue ruling is Richard C. Farley, Jr. of the Of- fice of Assistant Chief Counsel (Income Tax and Accounting). For further infor- mation regarding this revenue ruling, con- tact Mr. Farley on (202) 622-4970 (not a toll-free call). IRB 1999-15 4/7/99 12:57 PM Page 4 1999–15 I.R.B.5April 12, 1999 26 CFR 601.201: Rulings and determination letters. (Also Part I, sections 25, 103, 143; 1.25–4T, 1.103–1, 6a.103A–2.) Rev. Proc. 99–22 SECTION 1. PURPOSE This revenue procedure provides guid- ance concerning the United States and area median gross income figures that are to be used by issuers of qualified mort- gage bonds, as defined in § 143(a) of the Internal Revenue Code, and issuers of mortgage credit certificates, as defined in § 25(c), in computing the housing cost/in- come ratio described in § 143(f)(5). SECTION 2. BACKGROUND .01 Section 103(a) provides that, except as provided in § 103(b), gross income does not include interest on any state or local bond. Section 103(b)(1) provides that § 103(a) shall not apply to any private activity bond that is not a “qualified bond” within the meaning of § 141. Sec- tion 141(e) provides that the term “quali- fied bond” includes any private activity bond that (1) is a qualified mortgage bond, (2) meets the volume cap require- ments under § 146, and (3) meets the ap- plicable requirements under § 147. .02 Section 143(a)(1) provides that the term “qualified mortgage bond” means a bond that is issued as part of a “qualified mortgage issue”. Section 143(a)(2)(A) provides that the term “qualified mort- gage issue” means an issue of one or more bonds by a state or political subdivision thereof, but only if (i) all proceeds of the issue (exclusive of issuance costs and a reasonably required reserve) are to be used to finance owner-occupied resi- dences; (ii) the issue meets the require- ments of subsections (c),(d),(e),(f),(g), (h),(i), and (m)(7) of § 143; (iii) the issue does not meet the private business tests of paragraphs (1) and (2) of § 141(b); and (iv) with respect to amounts received more than 10 years after the date of is- suance, repayments of $250,000 or more of principal on financing provided by the issue are used not later than the close of the first semi-annual period beginning after the date the prepayment (or com- plete repayment) is received to redeem bonds that are part of the issue. .03 Section 143(f) imposes eligibility requirements concerning the maximum income of mortgagors for whom financ- ing may be provided by qualified mort- gage bonds. Section 25(c)(2)(A)(iii)(IV) provides that recipients of mortgage credit certificates must meet the income requirements of § 143(f). Generally, under §§ 143(f)(1) and 25(c)(2)(A)- (iii)(IV), these income requirements are met only if all owner-financing under a qualified mortgage bond and all certified indebtedness amounts under a mortgage credit certificate program are provided to mortgagors whose family income is 115 percent or less of the applicable median family income. Under § 143(f)(6), the in- come limitation is reduced to 100 percent of the applicable median family income if there are fewer than three individuals in the family of the mortgagor. .04 Section 143(f)(4) provides that the term “applicable median family income” means the greater of (A) the area median gross income for the area in which the residence is located or (B) the statewide median gross income for the state in which the residence is located. .05 Section 143(f)(5) provides for an upward adjustment of the income limita- tions in certain high housing cost areas. Under § 143(f)(5)(C), a high housing cost area is a statistical area for which the housing cost/income ratio is greater than 1.2. The housing cost/income ratio is de- termined under § 143(f)(5)(D) by divid- ing (a) the applicable housing price ratio by (b) the ratio that the area median gross income bears to the median gross income for the United States. The applicable housing price ratio is the new housing price ratio (new housing average pur- chase price for the area divided by the new housing average purchase price for the United States) or the existing housing price ratio (existing housing average area purchase price divided by the existing housing average purchase price for the United States), whichever results in the housing cost/income ratio being closer to 1. This income adjustment applies only to bonds issued and nonissued bond amounts elected after December 31, 1988. .06 The Department of Housing and Urban Development (HUD) has com- puted the median gross income for the United States, the states, and statistical areas within the states. The income infor- mation was released to the HUD regional offices on January 27, 1999, and may be obtained by calling the HUD reference service at 1-800-245-2691. The income information is also available at HUD’s World Wide Web site, which provides a menu from which you may select the year and type of data of interest ((http:// huduser.org/data/factors.html). The Inter- nal Revenue Service annually publishes only the median gross income for the United States. .07 The most recent nationwide aver- age purchase prices and average area pur- chase price safe harbor limitations were published on September 6, 1994, in Rev. Proc. 94–55, 1994–2 C.B. 716. SECTION 3. APPLICATION .01 When computing the housing cost/income ratio under § 143(f)(5), is- suers of qualified mortgage bonds and mortgage credit certificates must use $47,800 as the median gross income for the United States. See section 2.06 of this revenue procedure. .02 When computing the housing cost/income ratio under § 143(f)(5), is- suers of qualified mortgage bonds and mortgage credit certificates must use the area median gross income figures re- leased by HUD on January 27, 1999. See section 2.06 of this revenue procedure. SECTION 4. EFFECT ON OTHER REVENUE PROCEDURES .01 Rev. Proc. 98–28, 1998–15 I.R.B. 14, is obsolete except as provided in sec- tion 5.02 of this revenue procedure. .02 This revenue procedure does not af- fect the effective date provisions of Rev. Rul. 86–124, 1986–2 C.B. 27. Those ef- fective date provisions will remain opera- tive at least until the Service publishes a new revenue ruling that conforms the ap- proach to effective dates set forth in Rev. Rul. 86–124 to the general approach taken in this revenue procedure. Part III. Administrative, Procedural, and Miscellaneous IRB 1999-15 4/7/99 12:57 PM Page 5 SECTION 5. EFFECTIVE DATES .01 Issuers must use the United States and area median gross income figures specified in section 3 of this revenue pro- cedure for commitments to provide fi- nancing that are made, or (if the purchase precedes the financing commitment) for residences that are purchased, in the pe- riod that begins on January 27, 1999, and ends on the date when these United States and area median gross income figures are rendered obsolete by a new revenue pro- cedure. .02 Notwithstanding section 5.01 of this revenue procedure, issuers may con- tinue to rely on the United States and area median gross income figures specified in Rev. Proc. 98-28 with respect to bonds originally sold and nonissued bond amounts elected not later than May 12, 1999, if the commitments or purchases described in section 5.01 are made not later than July 12, 1999. DRAFTING INFORMATION The principal author of this revenue procedure is Patricia M. Monahan of the Office of Assistant Chief Counsel (Finan- cial Institutions and Products). For fur- ther information regarding this revenue procedure contact Ms. Monahan at (202) 622-4431 (not a toll-free call). April 12, 199961999–15 I.R.B. IRB 1999-15 4/7/99 12:57 PM Page 6 1999–15 I.R.B.7April 12, 1999 Part IV. Items of General Interest Foundations Status of Certain Organizations Announcement 99–23 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: Adult and Children Transitional Shelter, Denver, CO Al Simon Center for Telecommunication Law, Inc., San Diego, CA Amelia Lighthouse & Museum Inc., Fernandina Beach, FL American Atheist Veterans Inc., Escondido, CA American Friends of Yeshivat Eretz Hatzvi TR, Brooklyn, NY Barberton Moose Charity and Scholarship Fund Inc., Piqua, OH Benton Park Arts Council, St. Louis, MO Calvin Browns Alcohol & Drug-Free Living Centers, Pasadena, CA Children’s Education Fund, Inc., Lincolndale, NY Cuban Humanitarian Assistance Society, Inc., Dade County, FL Dreams for Kids Inc., Chicago, IL Faith House of America, Buffalo, NY Gleasons Athletic Club, Inc., Brooklyn, NY House of Coverance, Markham, IL International Foundation, Broken Arrow, OK Institute Paso Del Norte, El Paso, TX Jeanette Lyons Surina Scholarship Fund, Inc., Greenwood, IN Let It Shine Center for the Learning Impaired, West Linn, OR Lewis IDA Community Development Corporation, Lowville, NY Magical Helping Hands, Inc., Brockton, MA Metropolitan Entertainment, Sterling Heights, MI Music and Living, Inc., New York, NY Nagis Dutt Memorial Care Fdn., Ann Arbor, MI Oasis Mission Incorporated, Radcliff, KY Ohio Elks Charitable Trust, Marysville, OH Praise Mountain Ministry, Inc., Conyers, GA Preston Road Literacy Society, Dallas, TX Prince Hall African Lodge Urban Renewal Corporation, Newark, NJ Reef USA Inc., Florham, NJ Robinson Tennis Academy, Howell, MI Rocky Mountain Community Development Inc., Stillwell, OK Siskiyou Institute, Etna, CA Southern Tier West Development Fnd., Salamanca, NY The Spruell Community Learning Center, Compton, CA Studio E Repertory Inc., New York, NY Texas Society of Certified Public Accountants Peer Assistance Foundation, Inc., Dallas, TX Voices of Hope, Greenville, SC Waianae Coast Coalition for Human Services, Waianae, HI William C Pryor Portrait Trust Fund, Washington, DC Williams Foundation, Houston, TX Williamsburg Court HDFC, Brooklyn, NY Williamsburg Fire Department Auxiliary Inc., Williamsburg, IN Williamsburg Heights Community Block Club Association Inc., Milwaukee, WI Willowtree Counseling Center Inc., Phoenix, AZ Wilson House Inc., Bartow, FL Wimbly Club Inc., Jacksonville Beach, FL Win, Baltimore, MD Win-Good Sand Island Association, Winona, MN Window Rock Unified School District 8 Foundation Inc., Fort Defiance, AZ Wings for Christ Inc., Beach Grove, IN Wings of Freedom, Edmonds, WA Wings Through TLC Inc., Crockett, TX Winnebago Veterans Association Inc., Winnebago, NE Winnies Nursery School Inc., Cleveland, OH Wintergreen House Inc., Lutherville, MD Wiregrass Community Outreach, Dothan, AL Wisconsin Masonic Soccer Foundation Inc., Dousman, WI Wishes are Horses, Loveland, CO Wishing Well Foundation Inc., Louisville, KY With in Reach Kids Inc., Moorestown, NJ Wolf River Pipes and Drums Inc., Byhalia, MS Wolverine State Community Development Corporation, Flint, MI Womans Club of Warren Educational Scholarship & Historical Preservation Group, Warren, PA Women Changing the World, Lowell, IN Women Executives in Business, Mankato, MN Womenfirst Inc., Paterson, NJ Womens Implant Foundation, Dallas, TX Womens Media Project, Austin, TX Womens Opportunity Network, So Portland, ME Womens Outreach Inc., Goldsboro, NC Womens Self-Defense League Inc., Rutherfordton, NC Womens Task Force Inc., Greenville, SC Woodbin 2 Project, Cary, NC Woodburn Inc., Cincinnati, OH Woodcrest Foundation Inc., Syosset, NY Woodruff Mountain Foundation Inc., Great Barrington, MA Woodson County Follies Community Theatre Corporation Inc., Yates Center, KS Word of Grace International Ministries Inc., Delray Beach, FL Word of Truth Community Housing Association, Detroit, MI Wordcraft Circle of Native Writers, Fairfax, VA Working Families Inc., Raleigh, NC Workplace Institute, Tacoma, WA World Ambassadors Ltd., Coralville, IA World Childrens Foundation Inc., New Orleans, LA World Class, Maryville, TN World Class Foundation, Normal, IL World Class Partnership, Columbia, SC IRB 1999-15 4/7/99 12:57 PM Page 7 April 12, 199981999–15 I.R.B. Format Changes to Forms W-2 and W-3 Postponed Until Tax Year 2001 Announcement 99–34 BackgroundIn Announcement 98–55, 1998–26 I.R.B. 41, the IRS asked for comments on proposed format changes to Form W-2, Wage and Tax Statement, and Form W-3, Transmittal of Wage and Tax Statements. These changes were proposed for the 1999 forms to be filed in 2000. In Announcement 98–84, 1998–38 I.R.B. 30, the IRS postponed making major format changes to Forms W-2 and W-3 until the 2000 forms to be filed in 2001. Changes PostponedBased on concerns expressed by industry representatives and others, the IRS is again postponing major Until Tax Year 2001format changes to Forms W-2 and W-3. The IRS intends to make format changes similar to those first pro- posed in Announcement 98–55 to the 2001 forms to be filed in 2002. World Congregational Fellowship Church of Somers, Somers, CT World Evangelical Mission Team of New England Inc., Mattapan, MA World Interdependence Fund of New Mexico, Santa Fe, NM World Mission Mobilization Center Inc., Yoakum, TX World of Learning Inc., Austin, TX World Peace Foundation Inc., Tampa, FL World Refuge Charity Inc., St. Petersburg, FL World Salmonid Research Institute Inc., Nederland, CO World Sports Mission of America, Huntington Beach, CA World Telugu Federation, West Bloomfield, MI World View Foundation Inc., Boston, MA World Vision Mission Town, Cerritos, CA Worldaid Foundation Inc., Orlando, FL Wounded Eagles, Richardson, TX Wray Cultural Enrichment Council, Wray, CO Writers Inc., Lawrence, KS Writers Room of Boston Inc., Boston, MA Writings on the Wall Inc., San Anselmo, CA WXRT-WSCR Foundation, Chicago, IL Wyoming Farmers Union Community Services Incorporated, Pine Bluffs, WY Wyoming Observer Inc., Laramie, WY Wyoming State AIB Committee, Casper, WY X-Treme Football Club Inc., Powell, OH Xilin Childrens Foundation for Chinese Education, Roselle, IL Y & E Foundation, Yakima, WA Y E S Kids Inc., Sarasota, FL Yachad-Immanuel Ministry Inc., Bradenton, FL Yakima Gateway Tower Foundation, Yakima, WA Yellowstone Project to Promote Tolerance, Billings, MT Yerakas Society of Greater New England Inc., Peabody, MA Yes Lord Ministries Inc., Indianapolis, IN Yeshiva Hayisodos Inc., New York, NY Yonkers Beautification Conservancy Inc., Yonkers, NY Yonkers Job Development Corp., Yonkers, NY York Skating Rink Inc., York, ME Young Ambassador Center, Chicago Heights, IL Young Artists Inc., N. Myrtle Beach, SC Young Blacks Making a Difference Foundation, Stafford, TX Young Leaders Academy of Baton Rouge, Baton Rouge, LA Young Leaders Council Inc., Nashville, TN Young Peoples Marketing Society Inc., Denver, CO Younger Family Home & Study Center Inc., Lees Summit, MO Youth Achievers U S A Inc., Landover, MD Youth Alternative for Christ Inc., Springfield, NJ Youth Awareness Program Inc., Tulsa, OK Youth Challenge International Inc., Winston Salem, NC Youth Courts of the Capital District Inc., Latham, NY Youth Encouragement Systems, Linden, MI Youth Entrepreneur Program Inc., Columbus, OH Youth Forever, Long Lake, MN Youth Job Training Center of Slaton Lubbock, Lubbock, TX Youth Leadership Council, Houston, TX Youth Medical Home Inc., New Orleans, LA Youth Services America Corp., Elliccott City, MD Youth Today Leaders Tomorrow Inc., Golden Valley, MN Youth Unlimited Inc., Fort Collins, CO Youth Vision Inc., Miami Beach, FL Youth with a Mission-Philadelphia Inc., Essington, PA Youth with a Mission Salt Lake City, Ogden, UT Youthserveusa, Washington, DC Zainabia Islamic Society, Fontana, CA Zato-Durami Water Project Inc., Amherst, MA Zion Community Empowerment Center Inc., College Park, GA Zion Ministries Inc., Terre Haute, IN Zook Community Club Inc., Larned, KS 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. IRB 1999-15 4/7/99 12:57 PM Page 8 The IRS will announce and request comments on proposed changes to the 2001 Forms W-2 and W-3 by early 2000. 2000 Forms W-2The 2000 Forms W-2 and W-3 will remain the same size and retain the same format as the 1999 forms. The and W-3forms may, however, be revised to reflect changes in the law or to allow for the reporting of additional items in box 13. 1999–15 I.R.B.9April 12, 1999 Automatic Extension of Time To File Certain Employee Plan Returns (Forms 5500, 5500- C/R, and 5500-EZ) Announcement 99–37 Effective immediately, all applications for extension of time to file Forms 5500, 5500-C/R, and 5500-EZ will be automati- cally approved if the request (Form 5558) is filed on or before the normal due date of the return or report. The Form 5558, Application for Extension of Time To File Certain Employee Plan Returns, must be properly completed and signed in order for the filer to receive an automatic ap- proval of up to 2-1/2 months. Because the extension is automatically approved, the IRS will no longer return approved copies of Form 5558 to the filer to be filed with the return. Instead, filers will be required to attach a photocopy of the completed and signed Form 5558 to the return or report. This change in procedure does not apply to filers of Form 5330, Return of Excise Taxes Related to Employee Bene- fit Plans. Applications for extension of time to file Form 5330 will continue to be returned to the applicant as approved or not approved. These new procedures are reflected in the instructions for the March 1999 revi- sion of Form 5558. The form is now available at the IRS’s Internet Web Site. You can also get copies of Form 5558 from the IRS Distribution Centers when it becomes available in early May 1999. Request by —Number or Address Telephone1-800-TAX FORM (1-800-829-3676) Personal computer: World Wide Webwww.irs.ustreas.gov File Transfer Protocolftp.irs.ustreas.gov Telnetiris.irs.ustreas.gov Direct Dial (by modem)703-321-8020 Credit for Increasing Research Activities; Hearing Announcement 99–38 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Notice of public hearing on proposed rulemaking. SUMMARY: This document contains a notice of a public hearing on proposed regulations relating to the computation of the credit under section 41(c) and the def- inition of qualified research under section 41(d). DATES: The public hearing is being held on Thursday, April 29, 1999, at 10 a.m. The IRS must receive outlines of topics to be discussed at the hearing by April 15, 1999. ADDRESSES: The public hearing is being held in room 2615, 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. Mail outlines to: CC:DOM:CORP:R (REG–105170–97), 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– 105170–97), Courier’s Desk, Internal Revenue Service, 1111 Constitution Av- enue, NW, Washington, DC. Submit out- lines electronically via the Internet by se- lecting the “Tax Regs” option on the IRS Home Page, or by submitting them di- rectly to the IRS Internet site at:http:// www.irs.ustreas.gov/ prod/tax_regs/com- ments.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 Guy Traynor, (202) 622-7180 (not a toll free number). IRB 1999-15 4/7/99 12:57 PM Page 9 SUPPLEMENTARY INFORMATION: The subject of the public hearing is proposed regulations (REG-105170-97) that were published in the Federal Regis- ter on December 2, 1998 (63 F.R. 66503 [1998–50 IRB 10 (see §601.601(d)(2)]). 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 April 15, 1999. A period of 10 minutes is allotted to each person for presenting oral comments. After the deadline for receiving outlines has passed, the IRS will prepare an agenda containing the schedule of speakers. Copies of the agenda will be made avail- able, free of charge, at the hearing. Because of access restrictions, the IRS will not admit visitors beyond the immedi- ate entrance area more than 15 minutes be- fore the hearing starts. For information about having your name placed on the building access list to attend the hearing, see the “FOR FURTHER INFORMATION CONTACT” section of this document. Cynthia E. Grigsby, Chief, Regulations Unit, Assistant Chief Counsel (Corporate). (Filed by the Office of the Federal Register on March 24, 1999, 8:45 a.m., and published in the issue of the Federal Register for March 25, 1999, 64 F.R. 14412) Continuation Coverage Requirements Applicable to Group Health Plans; Correction Announcement 99–39 AGENCY: Internal Revenue Service (IRS), Treasury ACTION: Correction to final regulations. SUMMARY: This document contains corrections to Treasury Decision 8812, 1999–8 I.R.B. 19, which was published in the Federal Registeron Wednesday, February 3, 1999 (64 F.R. 5160), relating to continuation coverage requirements ap- plicable to group health plans. DATES: This correction is effective Feb- ruary 3, 1999. FOR FURTHER INFORMATION CON- TACT: Yurlinda Mathis at 202-622-4695 (not a toll free call). SUPPLEMENTAL INFORMATION: Background The final regulations that are subject to these corrections are under section 4980B of the Internal Revenue Code. Need for Correction As published, T.D. 8812 contains errors that may prove to be misleading and are in need of clarification. Correction of Publication Accordingly, the publication of the final regulations (T.D. 8812), which were the subject of FR Doc. 99–1520, is cor- rected as follows: 1. On page 5166, column 2, in the pre- amble under the heading, “COBRA Con- tinuation Coverage”, first full paragraph, line 4 from the bottom of paragraph, the language “offer for core coverage sepa- rately.” is corrected to read “offer core coverage separately.” 2. On page 5170, column 1, in the pre- amble under the heading, “Paying for COBRA Continuation Coverage”, last paragraph in the column, line 14, the lan- guage “beginning. Therefore, the final” is corrected to read “beginning of the pe- riod. Therefore, the final”. §54.4980B–1 [Corrected] 3. On page 5174, column 1, §54.4980B–1, paragraph (b), line 7 from the bottom of the paragraph, the language “rules in §§54.4980B–1 though” is cor- rected to read “rules in §§54.4980B–1 through”. Michael Slaughter, Acting Chief, Regulations Unit, Assistant Chief Counsel (Corporate). (Filed by the Office of the Federal Register on March 24, 1999, 8:45 a.m., and published in the issue of the Federal Register for March 25, 1999, 64 F.R. 14382) April 12, 1999101999–15 I.R.B. IRB 1999-15 4/7/99 12:57 PM Page 10 1999–15 I.R.B.11April 12, 1999 NameAddressDate of Resignation Ellis, Ronald C.Billings, MTOctober 6, 1998 Announcement of the Consent Voluntary Suspension of Attorneys, Certified Public Accountants, Enrolled Agents, and Enrolled Actuaries From Practice Before the Internal Revenue Service Under 31 Code of Federal Regulations, Part 10, an enrolled agent, in order to avoid the institution or conclusion of a proceeding for his disbarment or suspen- sion from practice before the Internal Revenue Service, may offer his resigna- tion from such practice. The Director of Practice, in his discretion, may suspend an enrolled agent in accordance with the consent offered. Attorneys, certified public accountants, enrolled agents, and enrolled actuaries are prohibited in any Internal Revenue Ser- vice matter from directly or indirectly em- ploying, accepting assistance from, being employed by or sharing fees with, any en- rolled agent who has resigned from prac- tice before the Internal Revenue Service. To enable attorneys, certified public ac- countants, enrolled agents, and enrolled actuaries to identify former enrolled agents who have resigned from practice before the Internal Revenue Service, the Director of Practice will announce in the Internal Revenue Bulletin the names and addresses of former enrolled agents who have resigned from such practice, and date of resignation. This announcement will appear 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 or for as many weeks as is practicable for each enrolled agent, who has resigned, and will be consolidated and published in the Cu- mulative Bulletin. The following individual has offered his resignation as an enrolled agent: IRB 1999-15 4/7/99 12:57 PM Page 11 April 12, 1999121999–15 I.R.B. Announcement of the Expedited Suspension of Attorneys, Certified Public Accountants, Enrolled Agents, and Enrolled Actuaries From Practice Before the Internal Revenue Service Under Title 31 of the Code of Federal Regulations, section 10.76, the Director of Practice is authorized to immediately suspend from practice before the Internal Revenue Service any practitioner who, within five years, from the date the expe- dited proceeding is instituted, (1) has had a license to practice as an attorney, certi- fied public accountant, or actuary sus- pended or revoked for cause; or (2) has been convicted of any crime under title 26 of the United States Code or, of a felony under title 18 of the United States Code involving dishonesty or breach of trust. Attorneys, certified public accountants, enrolled agents, and enrolled actuaries are prohibited in any Internal Revenue Service matter from directly or indirectly employ- ing, accepting assistance from, being em- ployed by, or sharing fees with, any practi- tioner disbarred or suspended from practice before the Internal Revenue Service. To enable attorneys, certified public ac- countants, enrolled agents, and enrolled ac- tuaries to identify practitioners under expe- dited suspension from practice before the Internal Revenue Service, the Director of Practice will announce in the Internal Rev- enue Bulletin the names and addresses of practitioners who have been suspended from such practice, their designation as at- torney, certified public accountant, en- rolled agent, or enrolled actuary, and date or period of suspension. This announce- ment will appear in the weekly Bulletin at the earliest practicable date after such ac- tion and will continue to appear in the weekly Bulletins for five successive weeks or for as many weeks as is practicable for each attorney, certified public accountant, enrolled agent, or enrolled actuary so sus- pended and will be consolidated and pub- lished in the Cumulative Bulletin. The following individual have been placed under suspension from practice be- fore the Internal Revenue Service by virtue of the expedited proceeding provisions of the applicable regulations: NameAddressDesignationDate of Suspension Pierce, Steven J.Aventura, FLAttorneyIndefinite from October 15, 1998 Baker, Charles C.Monteagle, TNAttorneyIndefinite from October 15, 1998 Kantor, Stanley L.New York, NYAttorneyIndefinite from October 15, 1998 Wagner, Richard E.Spencerport, NYEnrolled AgentIndefinite from October 15, 1998 Tuohey, SeamusMontclair, NJAttorneyIndefinite from October 15, 1998 Burke, Beau E.Santa Rosa, CACPAIndefinite from October 15, 1998 Marn, Eric Y.Honolulu, HIAttorneyIndefinite from October 15, 1998 Todd, KennethTulsa, OKAttorneyIndefinite from November 4, 1998 IRB 1999-15 4/7/99 12:57 PM Page 12 1999–15 I.R.B.13April 12, 1999 NameAddressDesignationEffective Date Shaw-Boatner, DeborahAustin, TXCPASeptember 24, 1998 Hannum, DavidPhiladelphia, PAEnrolled AgentSeptember 30, 1998 Miller, TheodoreNeshaminy Valley, PACPAFebruary 27, 1999 Announcement of the Disbarment and Suspension of Attorneys, Certified Public Accountants, Enrolled Agents, and Enrolled Actuaries From Practice Before the Internal Revenue Service Under 330, Title 31 of the United States Code, the Secretary of the Trea- sury, after due notice and opportunity for hearing, is authorized to suspend or dis- bar from practice before the Internal Rev- enue Service any person who has vio- lated the rules and regulations governing the recognition of attorneys, certified public accountants, enrolled agents, or enrolled actuaries to practice before the Internal Revenue Service. Attorneys, certified public accountants, enrolled agents, and enrolled actuaries are prohibited in any Internal Revenue Service matter from directly or indirectly employ- ing, accepting assistance from, being em- ployed by, or sharing fees with, any practi- tioner disbarred or under suspension from practice before the Internal Revenue Ser- vice. To enable attorneys, certified public ac- countants, enrolled agents, and enrolled actuaries to identify such disbarred or sus- pended practitioners, the Director of Practice will announce in the Internal Revenue Bulletin the names and ad- dresses of practitioners who have been suspended from such practice, their desig- nation as attorney, certified public ac- countant, enrolled agent, or enrolled actu- ary, and date of disbarment or period of suspension. This announcement will ap- pear in the weekly Bulletin for five suc- cessive weeks or as long as it is practica- ble for each attorney, certified public accountant, enrolled agent, or enrolled ac- tuary so suspended or disbarred and will be consolidated and published in the Cu- mulative Bulletin. After due notice and opportunity for hearing before an administrative law judge, the following individuals have been disbarred from further practice be- fore the Internal Revenue Service: IRB 1999-15 4/7/99 12:57 PM Page 13 April 12, 1999141999–15 I.R.B. NameAddressDesignationDate of Suspension Cohn, IrvingBaltimore, MDAttorneySeptember 4, 1998 to September 3, 2000 Hwang, Catherine T.Livingston, NJCPAOctober 1, 1998 to September 30, 1999 Bratek, RonaldN. Brunswick, NJCPAOctober 5, 1998 to July 4, 2000 Walker, Frank O.Bay City, TXCPAOctober 5, 1998 to April 4, 2001 Ng, Peter J.Monticello, NYAttorneyOctober 5, 1998 to May 4, 2002 Sopkovich, CarolGirard, OHAttorneyOctober 5, 1998 to October 4, 2001 Kappler, John E.Evansville, INCPAOctober 8, 1998 to October 7, 1999 Sarcia, Jerry J.Libertyville, ILCPAOctober 30, 1998 to August 29, 2002 Spey, Gregory E.Youngstown, OHCPANovember 1, 1998 to April 30, 2001 Jacobson, KennethJacksonville, FLCPANovember 9, 1998 to November 8, 2000 Lopshire, LarryWhiteland, INCPADecember 2, 1998 to December 1, 1999 Lederer, Christine L.Somers, CTAttorneyDecember 7, 1998 to December 6, 2001 Kieffer, Richard D.Olney, ILCPADecember 15, 1998 to December 14, 1999 Cleaver Jr., Thomas E.Severna Park, MDEnrolled AgentDecember 23, 1998 to June 22, 2002 Trent, Douglas I.Allen, TXCPAJanuary 1, 1999 to December 31, 1999 Winters, John E. Bayonne, NJCPAJanuary 1, 1999 to September 30, 1999 Todd Jr., Emory S.Chester SpringsCPAJanuary 15, 1999 to July 14, 1999 Hawkins, William M.Indianapolis, INAttorneyFebruary 1, 1999 to January 31, 2002 Gimbal, PeterUnion City, NJCPAApril 1, 1999 to September 30, 2000 Ryan, Thomas J.Danbury, CTAttorneyMay 1, 1999 to October 30, 2000 Announcement of the Consent Voluntary Suspension of Attorneys, Certified Public Accountants, Enrolled Agents, and Enrolled Actuaries From Practice Before the Internal Revenue Service Under 31 Code of Federal Regulations, Part 10, an attorney, certified public ac- countant, enrolled agent, or enrolled ac- tuary, in order to avoid the institution or conclusion of a proceeding for his disbar- ment or suspension from practice before the Internal Revenue Service, may offer his consent to suspension from such prac- tice. The Director of Practice, in his dis- cretion, may suspend an attorney, certi- fied public accountant, enrolled agent, or enrolled actuary in accordance with the consent offered. Attorneys, certified public accountants, enrolled agents, and enrolled actuaries are prohibited in any Internal Revenue Ser- vice matter from directly or indirectly em- ploying, accepting assistance from, being employed by, or sharing fees with any practitioner disbarred or suspended from practice before the Internal Revenue Ser- vice. To enable attorneys, certified public ac- countants, enrolled agents, and enrolled actuaries to identify practitioners under consent suspension from practice before the Internal Revenue Service, the Director of Practice will announce in the Internal Revenue Bulletin the names and ad- dresses of practitioners who have been suspended from such practice, their desig- nation as attorney, certified public ac- countant, enrolled agent, or enrolled actu- ary, and date or period of suspension. This announcement will appear in the weekly Bulletin at the earliest practicable date after such action and will continue to ap- pear in the weekly Bulletins for five suc- cessive weeks or for as many weeks as is practicable for each attorney, certified public accountant, enrolled agent, or en- rolled actuary so suspended and will be consolidated and published in the Cumu- lative Bulletin. The following individuals have been placed under consent suspension from practice before the Internal Revenue Ser- vice: IRB 1999-15 4/7/99 12:57 PM Page 14 1999–15 I.R.B.15April 12, 1999 Revenue rulings and revenue procedures (hereinafter referred to as “rulings”) that have an effect on previous rulings use the following defined terms to de- scribe the effect: 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 1999-15 4/7/99 12:57 PM Page 15 April 12, 1999161999–15 I.R.B. 1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 1998–1 through 1998–52 will be found in Internal Revenue Bulletin 1999–1, dated January 4, 1999. Numerical Finding List 1 Bulletins 1999–1 through 1999–14 Announcements: 99–1, 1999–2 I.R.B. 41 99–2, 1999–2 I.R.B. 44 99–3, 1999–3 I.R.B. 15 99–4, 1999–3 I.R.B. 15 99–5, 1999–3 I.R.B. 16 99–6, 1999–4 I.R.B.24 99–7, 1999–2 I.R.B. 45 99–8, 1999–4 I.R.B.24 99–9, 1999–4 I.R.B. 24 99–10, 1999–5 I.R.B. 63 99–11, 1999–5 I.R.B. 64 99–12, 1999–5 I.R.B. 65 99–13, 1999–6 I.R.B. 18 99–14, 1999–7 I.R.B.60 99–15, 1999–8 I.R.B.78 99–16, 1999–8 I.R.B. 80 99–17, 1999–9 I.R.B. 59 99–18, 1999–13 I.R.B. 22 99–19, 1999–10 I.R.B. 63 99–20, 1999–11 I.R.B.53 99–21, 1999–11 I.R.B.55 99–22, 1999–12 I.R.B. 32 99–24, 1999–14 I.R.B. 12 99–25, 1999–12 I.R.B. 35 99–26, 1999–14 I.R.B. 20 99–27, 1999–13 I.R.B. 23 99–28, 1999–13 I.R.B. 26 99–29, 1999–13 I.R.B. 26 99–30, 1999–13 I.R.B. 27 99–31, 1999–13 I.R.B. 27 99–32, 1999–14 I.R.B.20 99–33, 1999–14 I.R.B. 21 99–35, 1999–14 I.R.B. 22 Notices: 99–1, 1999–2 I.R.B. 8 99–2, 1999–2 I.R.B. 8 99–3, 1999–2 I.R.B. 10 99–4, 1999–3 I.R.B. 9 99–5, 1999–3 I.R.B. 10 99–6, 1999–3 I.R.B. 12 99–7, 1999–4 I.R.B.23 99–8, 1999–5 I.R.B. 26 99–9, 1999–4 I.R.B. 23 99–10, 1999–6 I.R.B. 14 99–11, 1999–8 I.R.B.56 99–12, 1999–9 I.R.B. 44 99–13, 1999–10 I.R.B. 26 99–14, 1999–11 I.R.B.7 99–15, 1999–12 I.R.B.20 99–16, 1999–13 I.R.B.10 99–17, 1999–14 I.R.B.6 Proposed Regulations: REG–209103–89, 1999–11 I.R.B. 10 REG–209619–93, 1999–10 I.R.B. 28 REG–245562–96, 1999–9 I.R.B. 45 REG–104072–97, 1999–11 I.R.B. 12 REG–114663–97, 1999–6 I.R.B. 15 REG–114664–97, 1999–11 I.R.B. 21 REG–116826–97, 1999–10 I.R.B. 40 REG–118620–97, 1999–9 I.R.B. 46 REG–120168–97, 1999–12 I.R.B. 21 REG–121806–97, 1999–10 I.R.B. 46 REG–100729–98, 1999–14 I.R.B. 9 Proposed Regulations—Continued REG–104924–98, 1999–10 I.R.B.47 REG–105964–98, 1999–12 I.R.B. 22 REG–106177–98, 1999–12 I.R.B. 25 REG–106219–98, 1999–9 I.R.B. 51 REG–106386–98, 1999–12 I.R.B. 31 REG–106388–98, 1999–11 I.R.B. 27 REG–106564–98, 1999–10 I.R.B.53 REG–106902–98, 1999–8 I.R.B. 57 REG–106905–98, 1999–11 I.R.B. 39 REG–110524–98, 1999–10 I.R.B. 55 REG–111435–98, 1999–7 I.R.B. 55 REG–113694–98, 1999–7 I.R.B. 56 REG–111435–98, 1999–7 I.R.B. 55 REG–113744–98, 1999–10 I.R.B. 59 REG–114841–98, 1999–11 I.R.B. 41 REG–115433–98, 1999–9 I.R.B. 54 REG–116099–98, 1999–12 I.R.B. 34 REG–116824–98, 1999–7 I.R.B.57 REG–117620–98, 1999–7 I.R.B. 59 REG–118662–98, 1999–13 I.R.B. 14 REG–119192–98, 1999–11 I.R.B. 45 REG–121865–98, 1999–8 I.R.B.63 Revenue Procedures: 99–1, 1999–1 I.R.B. 6 99–2, 1999–1 I.R.B. 73 99–3, 1999–1 I.R.B. 103 99–4, 1999–1 I.R.B. 115 99–5, 1999–1 I.R.B. 158 99–6, 1999–1 I.R.B. 187 99–7, 1999–1 I.R.B. 226 99–8, 1999–1 I.R.B. 229 99–9, 1999–2 I.R.B. 17 99–10, 1999–2 I.R.B. 11 99–11, 1999–2 I.R.B. 14 99–12, 1999–3 I.R.B. 13 99–13, 1999–5 I.R.B. 52 99–14, 1999–5 I.R.B. 56 99–15, 1999–7 I.R.B. 42 99–16, 1999–7 I.R.B. 50 99–17, 1999–7 I.R.B. 52 99–18, 1999–11 I.R.B.7 99–19, 1999–13 I.R.B.10 99–20, 1999–14 I.R.B.7 Revenue Rulings: 99–1, 1999–2 I.R.B. 4 99–2, 1999–2 I.R.B. 5 99–3, 1999–3 I.R.B. 4 99–4, 1999–4 I.R.B.19 99–5, 1999–6 I.R.B.8 99–6, 1999–6 I.R.B. 6 99–7, 1999–5 I.R.B. 4 99–8, 1999–6 I.R.B.8 99–9, 1999–7 I.R.B.14 99–10, 1999–10 I.R.B. 10 99–11, 1999–10 I.R.B. 18 99–12, 1999–11 I.R.B. 6 99–13, 1999–10 I.R.B. 4 99–14, 1999–13 I.R.B. 3 99–15, 1999–12 I.R.B.4 99–16, 1999–13 I.R.B.5 99–17, 1999–14 I.R.B. 4 99–18, 1999–14 I.R.B. 3 Treasury Decisions: 8789, 1999–3 I.R.B. 5 8791, 1999–5 I.R.B. 7 8792, 1999–7 I.R.B.36 Treasury Decisions—Continued 8793, 1999–7 I.R.B.15 8794, 1999–7 I.R.B.4 8795, 1999–7 I.R.B.8 8796, 1999–4 I.R.B. 16 8797, 1999–5 I.R.B. 5 8798, 1999–12 I.R.B. 16 8799, 1999–6 I.R.B. 10 8800, 1999–4 I.R.B. 20 8801, 1999–4 I.R.B. 5 8802, 1999–4 I.R.B. 10 8803, 1999–12 I.R.B. 15 8804, 1999–12 I.R.B. 5 8805, 1999–5 I.R.B. 14 8806, 1999–6 I.R.B.4 8807, 1999–9 I.R.B. 33 8808, 1999–10 I.R.B. 21 8809, 1999–7 I.R.B.27 8810, 1999–7 I.R.B.19 8811, 1999–10 I.R.B. 19 8812, 1999–8 I.R.B. 19 8813, 1999–9 I.R.B. 34 8814, 1999–9 I.R.B. 4 8815, 1999–9 I.R.B. 31 8816, 1999–8 I.R.B. 4 8817, 1999–8 I.R.B. 51 IRB 1999-15 4/7/99 12:57 PM Page 16 1999–15 I.R.B.17April 12, 1999 Finding List of Current Action on Previously Published Items 1 Bulletins 1999–1 through 1999–14 Revenue Procedures: 78–10 Obsoleted by 99–12, 1999–3 I.R.B. 13 94–56 Superseded by 99–9, 1999–2 I.R.B. 17 97–23 Superseded by 99–3, 1999–1 I.R.B. 103 98–1 Superseded by 99–1, 1999–1 I.R.B. 6 98–2 Superseded by 99–2, 1999–1 I.R.B. 73 98–3 Superseded by 99–3, 1999–1 I.R.B. 103 98–4 Superseded by 99–4, 1999–1 I.R.B. 115 98–5 Superseded by 99–5, 1999–1 I.R.B. 158 98–6 Superseded by 99–6, 1999–1 I.R.B. 187 98–7 Superseded by 99–7, 1999–1 I.R.B. 226 98–8 Superseded by 99–8, 1999–1 I.R.B. 229 98–22 Modified and amplified by 99–13, 1999–5 I.R.B. 52 98–56 Superseded by 99–3, 1999–1 I.R.B. 103 98–63 Modified by announcement 99–7, 1999–2 I.R.B. 45 Revenue Rulings: 92–19 Supplemented in part by 99–10, 1999–10 I.R.B. 10 1 A cumulative finding list for previously published items mentioned in Internal Revenue Bulletins 1998–1 through 1998–52 will be found in Internal Revenue Bulletin 1999–1, dated January 4, 1999. IRB 1999-15 4/7/99 12:57 PM Page 17 Notes April 12, 1999181999–15 I.R.B. IRB 1999-15 4/7/99 12:57 PM Page 18 IRB 1999-15 4/7/99 12:57 PM Page 19 INTERNAL REVENUE BULLETIN The Introduction on page 3 describes the purpose and content of this publication. The weekly Internal Revenue Bulletin is sold on a yearly subscription basis by the Superintendent of Documents. Current subscribers are notified by the Superintendent of Documents when their subscriptions must be renewed. CUMULATIVE BULLETINS The contents of this weekly Bulletin are consolidated semiannually into a permanent, indexed, Cumulative Bulletin. These are sold on a single copy basis and are not included as part of the subscription to the Internal Revenue Bulletin. Subscribers to the week- ly Bulletin are notified when copies of the Cumulative Bulletin are available. Certain issues of Cumulative Bulletins are out of print and are not available. Persons desiring available Cumulative Bulletins, which are listed on the reverse, may purchase them from the Superintendent of Documents. HOW TO ORDER Check the publications and/or subscription(s) desired on the reverse, complete the order blank, enclose the proper remittance, detach entire page, and mail to the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402. Please allow two to six weeks, plus mailing time, for delivery. WE WELCOME COMMENTS ABOUT THE INTERNAL REVENUE BULLETIN If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we would be pleased to hear from you. You can e-mail us your suggestions or comments through the IRS Internet Home Page (www.irs.ustreas.gov) or write to the IRS Bulletin Unit, OP:FS:FP:P:1, Room 5617, 1111 Constitution Avenue NW, Washington, DC 20224. IRB 1999-15 4/7/99 12:57 PM Page 20
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