Internal Revenue Bulletin 2000-19 (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.

INCOME TAX
Rev. Rul. 2000–23, page 964.
Federal rates; adjusted federal rates; adjusted federal
long-term rate, and the long-term exempt rate.For pur-
poses of sections 1274, 1288, 382, and other sections of the
Code, tables set forth the rates for May 2000.
Rev. Rul. 2000–24, page 963.
Medical expenses.Amounts paid by an individual for ex-
penses of admission and transportation to a medical confer-
ence relating to the chronic disease of the individual’s depen-
dent are deductible as medical expenses under section 213 of
the Code (subject to the limitations of that section), if the costs
are primarily for and essential to the medical care of the de-
pendent. The cost of meals and lodging while attending the
conference are not deductible as medical expenses under
Code section 213.
EMPLOYMENT TAX
Notice 2000–21, page 967.
This notice sets forth the requirements employers must
meet and the procedures for obtaining approval of em-
ployer-designed tip reporting alternative commitment (Em-
TRAC) programs for the food and beverage industry. This
notice also solicits comments on the EmTRAC program.
Comments must be received by July 7, 2000.
Announcement 2000–19, page 973.
Public comments are requested on the proposed tip report-
ing alternative commitment (TRAC) agreement for use in in-
dustries other than the food and beverage industry and the
cosmetology and barber industry, where employees receive
both cash and charged tips. Comments must be received by
July 7, 2000.
Announcement 2000–20, page 977.
Public comments are requested on the proposed tip rate de-
termination agreement (TRDA) for use in industries other
than food and beverage industry and the gaming industry.
Comments must be received by July 7, 2000.
Announcement 2000–21, page 983.
Public comments are requested on the proposed revision of
the tip reporting alternative commitment (TRAC) agreement
used in the cosmetology and barber industry. Comments
must be received by July 7, 2000.
Announcement 2000–22, page 987.
Public comments are requested on the proposed revision of the
tip reporting alternative commitment (TRAC) agreement used in
the food and beverage industry. Comments must be received by
July 7, 2000.
Announcement 2000–23, page 992.
Public comments are requested on the proposed revision of the
tip rate determination agreement (TRDA) used in the food and
beverage industry. Comments must be received by July 7,
2000.
Internal Revenue
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Bulletin No. 2000–19
May 8, 2000
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
Actions Relating to Court Decisions is on the page following the Introduction.
Finding Lists begin on page ii.
Announcements of Disbarments and Suspensions begin on page 998.
(Continued on the next page)

May 8, 20002000–19 I.R.B.
ADMINISTRATIVE
Rev. Proc. 2000–21, page 971.
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) of the
Code. Rev. Proc. 99–22 is obsolete except as provided in
section 5.02 of this revenue procedure.
Announcement 2000–46, page 997.
Notice of call for redemption: 8 1/4 percent Treasury
Bonds of 2000–5.Treasury bonds dated May 15, 1975, and
due on May 15, 2005, are called for redemption at par on May
15, 2000, on which date interest on these bonds will cease.
Announcement 2000–49, page 998.
This announcement informs the public of a delay in finalizing
proposed regulations (REG–104939–99, 1999–49, I.R.B.
643) under section 6212(b) of the Code regarding a tax-
payer’s last known address published in the Federal Register
(64 FR 63768) on November 22, 1999. The regulations
were proposed to be effective May 1, 2000, but will not be
effective until all necessary steps are taken to implement the
regulations.
Announcement 2000–50, page 998.
This announcement contains the section pertaining to the
Paperwork Reduction Act which was omitted from Revenue
Procedure 2000–12 (2000–4 I.R.B. 387).

2000–19 I.R.B.May 8, 2000
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.
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.
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.

May 8, 20002000–19 I.R.B.
It is the policy of the Internal Revenue
Service to announce at an early date
whether it will follow the holdings in cer-
tain cases. An Action on Decision is the
document making such an announcement.
An Action on Decision will be issued at
the discretion of the Service only on un-
appealed issues decided adverse to the
government. Generally, an Action on De-
cision is issued where its guidance would
be helpful to Service personnel working
with the same or similar issues. Unlike a
Treasury Regulation or a Revenue Ruling,
an Action on Decision is not an affirma-
tive statement of Service position. It is not
intended to serve as public guidance and
may not be cited as precedent.
Actions on Decisions shall be relied
upon within the Service only as conclu-
sions applying the law to the facts in the
particular case at the time the Action on
Decision was issued. Caution should be
exercised in extending the recommenda-
tion of the Action on Decision to similar
cases where the facts are different. More-
over, the recommendation in the Action
on Decision may be superseded by new
legislation, regulations, rulings, cases, or
Actions on Decisions.
Prior to 1991, the Service published ac-
quiescence or nonacquiescence only in
certain regular Tax Court opinions. The
Service has expanded its acquiescence
program to include other civil tax cases
where guidance is determined to be help-
ful. Accordingly, the Service now may ac-
quiesce or nonacquiesce in the holdings
of memorandum Tax Court opinions, as
well as those of the United States District
Courts, Claims Court, and Circuit Courts
of Appeal. Regardless of the court decid-
ing the case, the recommendation of any
Action on Decision will be published in
the Internal Revenue Bulletin.
The recommendation in every Action
on Decision will be summarized as ac-
quiescence, acquiescence in result only,
or nonacquiescence. Both “acquies-
cence” and “acquiescence in result only”
mean that the Service accepts the holding
of the court in a case and that the Service
will follow it in disposing of cases with
the same controlling facts. However, “ac-
quiescence” indicates neither approval
nor disapproval of the reasons assigned
by the court for its conclusions; whereas,
“acquiescence in result only” indicates
disagreement or concern with some or all
of those reasons. “Nonacquiescence” sig-
nifies that, although no further review
was sought, the Service does not agree
with the holding of the court and, gener-
ally, will not follow the decision in dis-
posing of cases involving other taxpay-
ers. In reference to an opinion of a circuit
court of appeals, a “nonacquiescence” in-
dicates that the Service will not follow
the holding on a nationwide basis. How-
ever, the Service will recognize the
precedential impact of the opinion on
cases arising within the venue of the de-
ciding circuit.
The Actions on Decisions published in
the weekly Internal Revenue Bulletin are
consolidated semiannually and appear in
the first Bulletin for July and the Cumu-
lative Bulletin for the first half of the
year. A semiannual consolidation also ap-
pears in the first Bulletin for the follow-
ing January and in the Cumulative Bul-
letin for the last half of the year.
The Commissioner NONACQUI-
ESCES in the following decision:
Estate of Smith v. Commissioner,
1
198 F.3d 515 (5
th
Cir. 1999), rev’g,
108 T.C. 412 (1997)
Actions Relating to Decisions of the Tax Court
1
Nonacquiescence relating to whether post-death events should be considered in determining the amount deductible under Internal Revenue Code section 2053(a)(3)
for claims against the estate that are contigent or contested at the date of death.

Section 42.—Low-Income
Housing Credit
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 2000. See Rev. Rul. 2000–23, page 964.
Section 213.—Medical, Dental,
etc., Expenses
26 CFR 1.213-1: Medical, dental, etc., expenses.
(Also § 262; 1.262-1.)
Medical expenses.Amounts paid by
an individual for expenses of admission
and transportation to a medical confer-
ence relating to the chronic disease of the
individual’s dependent are deductible as
medical expenses under section 213 of the
Code (subject to the limitations of that
section), if the costs are primarily for and
essential to the medical care of the depen-
dent. The cost of meals and lodging while
attending the conference are not de-
ductible as medical expenses under sec-
tion 213.
Rev. Rul. 2000-24
ISSUE
Are amounts paid by an individual for
expenses (including transportation costs,
registration fee, meals and lodging) of at-
tending a medical conference relating to
the chronic disease of the individual’s de-
pendent deductible as medical expenses
under § 213 of the Internal Revenue
Code?
FACTS
Taxpayer Aresides in City Xand is the
parent of B, who is A’s dependent. Bsuf-
fers from a chronic disease and is being
treated by physician C.
At C’s recommendation and for the
purpose of obtaining medical information
that may be useful in making decisions
concerning B’s treatment or in providing
care to B, Atravels to City Yto attend a
conference sponsored by an association
that supports research and education con-
cerning the disease. The conference is at-
tended by medical practitioners and indi-
viduals with the disease and their
families. Aspends the majority of A’s
time at the conference attending sessions
that disseminate medical information con-
cerning B’s disease. Other sessions at the
conference involve presentations or dis-
cussions on legal issues, family finances,
and other matters commonly arising in
families in which a member has the dis-
ease. While in City Y, A’s social and
recreational activities outside of the con-
ference are secondary to A’s attendance at
the conference.
Apays the following expenses in con-
nection with the conference: transporta-
tion to City Y, local transportation to the
conference site, a registration fee, meals
while attending the conference, and lodg-
ing at a hotel while attending the confer-
ence.
LAW AND ANALYSIS
Section 213(a) allows a deduction for
uncompensated expenses for medical care
of an individual, the individual’s spouse,
or a dependent, to the extent the expenses
exceed 7.5 percent of adjusted gross in-
come. Section 213(d)(1) provides that
medical care means amounts paid for the
diagnosis, cure, mitigation, treatment, or
prevention of disease, or for the purpose
of affecting any structure or function of
the body.
Section 1.213-1(e)(1)(ii) of the Income
Tax Regulations provides, in part, that the
deduction for medical care expenses will
be confined strictly to expenses incurred
primarily for the prevention or alleviation
of a physical or mental defect or illness.
Whether an expenditure is “primarily for”
medical care is a question of fact. An ex-
pense that is merely beneficial to the gen-
eral health of an individual is not an ex-
pense for medical care.
Section 213(d)(1)(B) provides that
“medical care” also includes transporta-
tion that is “primarily for and essential to”
medical care referred to in §
213(d)(1)(A). A taxpayer who, for purely
personal reasons, travels to another local-
ity to obtain an operation or other medical
care prescribed by a doctor may not
deduct the costs of transportation under §
213. Section 1.213-1(e)(1)(iv).
Section 213(d)(2) provides that the cost
of lodging (up to $50 per night) while
away from home that is primarily for and
essential to medical care (as defined in §
213(d)(1)(A)) is an amount paid for med-
ical care if (A) the medical care is pro-
vided by a physician in a licensed hospital
or a related or equivalent facility, and (B)
there is no significant element of personal
pleasure, recreation, or vacation in the
travel away from home.
Meal expenses are not deductible as ex-
penses for medical care unless they are
provided at a hospital or similar institu-
tion at which the taxpayer, the taxpayer’s
spouse, or dependent is receiving medical
care. Section 1.213-1(e)(1)(iv) and (v).
Section 262 provides that, except as
otherwise expressly provided by the
Code, no deduction is allowed for per-
sonal, living, or family expenses.
In Rev. Rul. 58-533, 1958-2 C.B. 108,
the parents of a child who lives away
from home at a psychiatric center incur
transportation costs to visit the child at
regular intervals on the advice of the
child’s doctors and as an essential part of
the child’s therapy. The ruling holds that
the transportation costs are primarily for
and essential to medical care and are de-
ductible under § 213.
By contrast, Rev. Rul. 76-79, 1976-1
C.B. 70, holds that a deduction under §
213 is not allowed for transportation costs
incurred by an individual to take a cruise
(upon the recommendation of a physi-
cian) on which a group of doctors provide
both instructional seminars relating to the
individual’s medical condition and certain
medical services. The seminars are for
the preservation of the individual’s gen-
eral health only and the medical services
are available in the individual’s home
town. The ruling holds that the transporta-
tion costs are not primarily for and essen-
tial to medical care.
In the present case, Atravels to the con-
ference in City Yon the recommendation
of C, the physician treating A’s child B, to
obtain medical information that may be
useful in making decisions concerning B’s
treatment or in providing care to B. A
spends the majority of A’s time at the con-
ference attending sessions that dissemi-
nate medical information concerning B’s
disease. While in City Y, A’s social and
recreational activities outside of the con-
ference are secondary to A’s attendance at
the conference. Under these facts, the
2000–19 I.R.B.963May 8, 2000
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

registration fee paid by Ato attend the
conference is primarily for medical care,
and A’s travel is primarily for and essen-
tial to medical care. Accordingly, Amay
deduct the registration fee and transporta-
tion expenses under § 213 (subject to the
limitations of that section). Amay not
deduct the cost of meals and lodging
while attending the conference because
neither A, A’s spouse, nor a dependent is
receiving medical care from a physician
at a licensed hospital or similar institu-
tion. See§§ 213(d)(2) and 1.213-
1(e)(1)(iv). The result would be the same
if A, and not A’s dependent, was the indi-
vidual with the disease.
HOLDING
Amounts paid by an individual for ex-
penses of admission and transportation to
a medical conference relating to the
chronic disease of the individual’s depen-
dent are deductible as medical expenses
under § 213 (subject to the limitations of
that section), if the costs are primarily for
and essential to the medical care of the
dependent. The cost of meals and lodging
while attending the conference are not de-
ductible as medical expenses under § 213.
EFFECT ON OTHER DOCUMENTS
Rev. Rul. 76-79 is distinguished.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Donna M. Crisalli of the Office
of Assistant Chief Counsel (Income Tax
and Accounting). For further information
regarding this revenue ruling, contact Ms.
Crisalli on (202) 622-4920 (not a toll-free
call).
Section 262.—Personal, Living,
and Family Expenses
26 CFR 1.262–1: Personal, living, and family
expenses.
Are amounts paid by an individual for
expenses (including transportation costs,
registration fee, meals and lodging) of at-
tending a medical conference relating to
the chronic disease of the individual’s de-
pendent deductible as medical expenses
under section 213 of the Code. See Rev.
Rul. 2000–24, page 963.
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term
rates are set forth for the month of May 2000. See
Rev. Rul. 2000–23, on this page.
Section 382.—Limitation on Net
Operating Loss Carryforwards
and Certain Built-in Losses
Following Ownership Change
The adjusted applicable federal long-term rate is
set forth for the month of May 2000. See Rev. Rul.
2000–23, on this page.
Section 412.—Minimum Funding
Standards
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 2000. See Rev. Rul. 2000–23, on this page.
Section 467.—Certain Payments
for the Use of Property or
Services
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 2000. See Rev. Rul. 2000–23, on this page.
Section 468.—Special Rules for
Mining and Solid Waste
Reclamation and Closing Costs
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 2000. See Rev. Rul. 2000–23, on this page.
Section 482.—Allocation of
Income and Deductions Among
Taxpayers
Federal short-term, mid-term, and long-term
rates are set forth for the month of May 2000. See
Rev. Rul. 2000–23, on this page.
Section 483.—Interest on
Certain Deferred Payments
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 2000. See Rev. Rul. 2000–23, on this page.
Section 642.—Special Rules for
Credits and Deductions
Federal short-term, mid-term, and long-term
rates are set forth for the month of May 2000. See
Rev. Rul. 2000–23, on this page.
Section 807.—Rules for Certain
Reserves
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 2000. See Rev. Rul. 2000–23, on this page.
Section 846.—Discounted
Unpaid Losses Defined
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 2000. See Rev. Rul. 2000–23, on this page.
Section 1274.—Determination
of Issue Price in the Case of
Certain Debt Instruments Issued
for Property
(Also sections 42, 280G, 382, 412, 467, 468, 482,
483, 642, 807, 846, 1288, 7520, 7872.)
Federal rates; adjusted federal rates;
adjusted federal long-term rate, and
the long-term exempt rate.For purposes
of sections 1274, 1288, 382, and other
sections of the Code, tables set forth the
rates for May 2000.
Rev. Rul. 2000-23
This revenue ruling provides various
prescribed rates for federal income tax
purposes for May 2000 (the current
month.) Table 1 contains the short-term,
mid-term, and long-term applicable fed-
eral rates (AFR) for the current month for
purposes of section 1274(d) of the Inter-
nal Revenue Code. Table 2 contains the
short-term, mid-term, and long-term ad-
justed applicable federal rates (adjusted
AFR) for the current month for purposes
of section 1288(b). Table 3 sets forth the
adjusted federal long-term rate and the
long-term tax-exempt rate described in
section 382(f). Table 4 contains the ap-
propriate percentages for determining the
low-income housing credit described in
section 42(b)(2) for buildings placed in
service during the current month. Finally,
Table 5 contains the federal rate for deter-
May 8, 20009642000–19 I.R.B.

mining the present value of an annuity, an
interest for life or for a term of years, or a
remainder or a reversionary interest for
purposes of section 7520.
2000–19 I.R.B.965May 8, 2000
REV. RUL. 2000-23 TABLE 1
Applicable Federal Rates (AFR) for May 2000
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-Term
AFR6.42%6.32%6.27%6.24%
110% AFR7.07%6.95%6.89%6.85%
120% AFR7.72%7.58%7.51%7.46%
130% AFR8.39%8.22%8.14%8.08%
Mid-Term
AFR6.40%6.30%6.25%6.22%
110% AFR7.05%6.93%6.87%6.83%
120% AFR7.70%7.56%7.49%7.44%
130% AFR8.36%8.19%8.11%8.05%
150% AFR9.67%9.45%9.34%9.27%
175% AFR11.33%11.03%10.88%10.78%
Long-Term
AFR6.20%6.11%6.06%6.03%
110% AFR6.83%6.72%6.66%6.63%
120% AFR7.46%7.33%7.26%7.22%
130% AFR8.10%7.94%7.86%7.81%
REV. RUL. 2000-23 TABLE 2
Adjusted AFR for May 2000
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
adjusted AFR4.34%4.29%4.27%4.25%
Mid-term
adjusted AFR 4.91%4.85%4.82%4.80%
Long-term
adjusted AFR5.57%5.49%5.45%5.43%
REV. RUL. 2000-23 TABLE 3
Rates Under Section 382 for May 2000
Adjusted federal long-term rate for the current month5.57%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the
adjusted federal long-term rates for the current month and the prior two months.)5.84%
REV. RUL. 2000-23 TABLE 4
Appropriate Percentages Under Section 42(b)(2) for May 2000
Appropriate percentage for the 70% present value low-income housing credit8.48%
Appropriate percentage for the 30% present value low-income housing credit3.63%

Section 1288.—Treatment of
Original Issue Discounts on Tax-
Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 2000. See Rev. Rul. 2000–23, page 964.
Section 7520.—Valuation Tables
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 2000. See Rev. Rul. 2000–23, page 964.
Section 7872.—Treatment of
Loans with Below-Market
Interest Rates
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 2000. See Rev. Rul. 2000–23, page 964.
May 8, 20009662000–19 I.R.B.
REV. RUL. 2000-23 TABLE 5
Rate Under Section 7520 for May 2000
Applicable federal rate for determining the present value of an annuity, an interest for life or a
term of years, or a remainder or reversionary interest7.8%

Employer-designed Tip
Reporting Program for the Food
and Beverage Industry
Notice 2000-21
I. BACKGROUND
In 1993, the Internal Revenue Service
introduced its Tip Rate Determination/Ed-
ucation Program (TRD/EP), which is de-
signed to enhance tax compliance among
tipped employees through taxpayer edu-
cation and voluntary advance agreements
instead of traditional audit techniques.
The TRD/EP was developed as a means
of enhancing tax compliance while reduc-
ing taxpayer burden. In essence, the
TRD/EP envisions that the Service and
taxpayers in industries in which tipping is
common will work together to improve
tax compliance.
The TRD/EP currently offers employ-
ers the opportunity of entering into one of
two types of agreements. The Tip Rate
Determination Agreement (TRDA) re-
quires the determination of tip rates; the
Tip Reporting Alternative Commitment
(TRAC) agreement emphasizes education
and tip reporting procedures. The agree-
ments also set forth an understanding that
both the employer and employees who
comply with the terms of the agreement
will not be subject to challenge by the
Service. The decision to enter into either
a TRDA or a TRAC agreement is entirely
voluntary on the part of the employer.
TRDAs are currently in use in the food
and beverage industry and the gaming in-
dustry. TRAC agreements are currently
in use in the food and beverage industry
and the hairstyling industry. The Service
expects to begin making these agreements
available to other industries during 2000.
Taxpayers in the food and beverage in-
dustry have expressed interest in design-
ing their own TRAC programs. This no-
tice sets forth the requirements employers
must meet and the procedures for obtain-
ing approval of their individual programs.
Because the basic premise of the em-
ployer-designed program is similar to the
TRAC program, the employer-designed
program is designated the EmTRAC pro-
gram. The Service believes that employ-
ers that have already developed their own
educational programs and tip reporting
procedures will find that the EmTRAC
program meets their needs.
II. EmTRAC PROGRAM
The EmTRAC program is available
only to employers in the food and bever-
age industry that have employees who re-
ceive both cash and charged tips. The
employer may have one place of business
or many places of business. For purposes
of the program, each place of business is
called an establishment. If an employer
has more than one establishment, it can
choose which establishments to include in
its EmTRAC program.
The EmTRAC program retains many
of the provisions in the TRAC agree-
ments. The employer must establish an
educational program that trains employ-
ees that the law requires them to report all
their cash and charged tips to their em-
ployer. Education must be furnished for
newly hired employees and quarterly for
existing employees.
The employer must establish tip report-
ing procedures, under which a written or
electronic statement is prepared and
processed on a regular basis (no less fre-
quently than monthly), reflecting all tips for
services attributable to each employee.
The employer has considerable latitude
in designing its educational program and
tip reporting procedures and may combine
them. For example, a point-of-sale tip re-
porting system would meet both of these
requirements, because the employee is
prompted of the tip reporting requirement
at the end of each sale and because the re-
porting occurs at the end of each sale.
The employer must agree–
1. to comply with the requirements
for filing all required federal tax returns
and paying and depositing all federal
taxes;
2. to maintain the following records
for at least 4 years after the April 15 fol-
lowing the calendar year to which the
records relate:
a. gross receipts subject to tip-
ping, and
b. charge receipts showing
charged tips; and
3. upon the request of the Service, to
make the following quarterly totals avail-
able, by establishment, for statistical sam-
plings of its establishments:
a. Gross receipts subject to tip-
ping,
b. Charge receipts showing
charged tips,
c. Total charged tips, and
d. Total tips reported.
The Service agrees–
1. not to initiate any tip examina-
tions of the employer or an establishment
included in the EmTRAC for any period
for which the EmTRAC program is in ef-
fect;
2. to base any section 3121(q) notice
and demand issued to the employer or an
establishment included in the EmTRAC
and relating to any period during which
the EmTRAC program is in effect solely
on amounts reflected on–
a. Form 4137, Social Security and
Medicare Tax on Unreported Tip Income,
filed by an Employee with his or her
Form 1040, or
b. Form 885-T,Adjustment of So-
cial Security Tax on Tip Income Not Re-
ported to Employer, prepared at the conclu-
sion of an employee tip examination; and
3. not to evaluate the employer for
compliance with the provisions of its Em-
TRAC program for the first two calendar
quarters for which the EmTRAC program
is effective.
Both parties agree that, for purposes of
the EmTRAC program, a compliance re-
view is not treated as an examination or
an inspection of books of account or
records, and an inspection of books of ac-
count or records pursuant to a tip exami-
nation is not an inspection of books or
records for purposes of section 7605(b) of
the Code, and is not a prior audit for pur-
poses of section 530 of the Revenue Act
of 1978.
The effective date of an EmTRAC pro-
gram is the first day of the quarter begin-
ning on or after the date the Service signs
an approval letter.
An employer may at any time terminate
its EmTRAC program either completely
or with respect to one or more establish-
ments. The Service may terminate its ap-
proval only if–
1. the Service determines that the
employer has failed to comply with the
required provisions; or
2000–19 I.R.B.967May 8, 2000
Part III. Administrative, Procedural, and Miscellaneous

2. the Service pursues an adminis-
trative or judicial action relating to the
employer, an establishment included in
the EmTRAC, or any other related party
to the employer’s EmTRAC program.
Any termination is effective the first day
of the first calendar quarter after the ter-
minating party notifies the other party in
writing.
III. PROCEDURES FOR
REQUESTING APPROVAL
The employer must request approval of
its EmTRAC program. For this purpose,
the Service has developed a pro forma let-
ter that employers must use to request ap-
proval of their EmTRAC program. The
letter requests approval of the employer’s
EmTRAC program and states that the em-
ployer will comply with the provisions set
forth in the letter (and also set forth in
section II above).
A copy of the approval request letter is
attached to this notice. It can be obtained
by mail by contacting the tips coordinator
in any local IRS office or by calling (202
622-4177 (not a toll-free call).
The completed approval request letter
and a copy of the employer’s EmTRAC
program should be sent to:
Internal Revenue Service
OP:EX:ST:ET Room 2404
Attn: EmTRAC Coordinator
1111 Constitution Avenue, NW
Washington, DC 20224
IV. PROCEDURES FOR APPROVING
REQUESTS
After it receives the approval request
letter, the Service will review the em-
ployer’s program. If the program meets
the necessary requirements, the Service
will send the employer an approval letter,
a copy of which is attached to this notice.
The approval letter will specify the effec-
tive date of the employer’s EmTRAC pro-
gram.
If the IRS determines that the em-
ployer’s EmTRAC program fails to meet
all the requirements, the IRS will contact
the employer and offer assistance in
working out a program that will meet both
the employer’s needs and the IRS’s re-
quirements.
V. MISCELLANEOUS
Upon request to the local tips coordina-
tor or the EmTRAC Coordinator, the Ser-
vice will assist any employer in establish-
ing, maintaining, or improving its
educational program or tip reporting pro-
cedures.
The Commissioner of Internal Revenue
may terminate all EmTRAC programs at
any time following a significant statutory
change in the FICA taxation of tips. After
May 31, 2005, the Commissioner may
terminate prospectively the Tip Rate De-
termination/Education Program and all
EmTRAC programs.
VI. PAPERWORK REDUCTION ACT
The collections of information con-
tained in this notice will be submitted to
the Office of Management and Budget for
review in accordance with the Paperwork
Reduction Act (44 U.S.C. 3507).
An agency may not conduct or sponsor,
and a person is not required to respond to,
a collection of information unless the col-
lection of information displays a valid
control number. The collections of infor-
mation in this document are in sections II
and III. This information is required to
comply with sections 6053(a) and 6001 of
the Internal Revenue Code and to assist
the Internal Revenue Service in its com-
pliance efforts. This information will be
used to monitor the Employer’s perfor-
mance under its EmTRAC program. The
collections of information are required to
obtain the benefits available under the
EmTRAC program. The likely respon-
dents are business or other for-profit insti-
tutions.
The estimated total annual reporting
and/or recordkeeping burden is 870
hours.
The estimated annual burden per respon-
dent/recordkeeper varies from 8 hours to 44
hours, depending on individual circum-
stances, with an estimated average of 13
hours. The estimated number of respon-
dents and/or recordkeepers is 20.
The estimated annual frequency of re-
sponses (used for reporting requirements
only) is on occasion.
Books or records relating to a collec-
tion of information must be retained as
long as their contents may become mater-
ial in the administration of any internal
revenue law. Generally, tax returns and
tax return information are confidential, as
required by section 6103 of the Code.
VII. COMMENTS
The IRS invites interested persons to
comment on the EmTRAC program. In
particular, the Service requests comments
from the industry regarding whether elec-
tronic tip reporting systems, other than
the point-of-sale system, would also meet
the educational requirement.
Written comments must be received by
July 7, 2000. Send submissions to Office of
Specialty Taxes, c/o CC:DOM:CORP:R
(Notice 2000-21), room 5226, Internal
Revenue Service, POB 7604, Ben Franklin
Station, Washington, DC 20044. Submis-
sions may be hand delivered Monday
through Friday between the hours of 8 a.m.
and 5 p.m. to: Specialty Taxes, c/o
CC:DOM:CORP:R (Notice 2000-21),
Courier’s desk, Internal Revenue Service,
1111 Constitution Avenue, NW, Washing-
ton, DC. Alternatively, taxpayers may sub-
mit comments electronically via the Inter-
net by selecting the “Tax Regs” option on
the IRS Home Page, or by submitting com-
ments directly to the IRS Internet site at
http://www
.irs.ustreas.gov/tax_regs/regslist
.html.
DRAFTING INFORMATION
The principal author of this notice is
Karin Loverud of the Office of the Asso-
ciate Chief Counsel (Employee Benefits
and Exempt Organizations). For further
information regarding this announcement,
contact Ida Volz of the Office of Specialty
Taxes on (202) 622-4177 (not a toll-free
call).
May 8, 20009682000–19 I.R.B.

Letter — Request for EmTRAC approval
Tip Coordinator
Internal Revenue Service
Re: Request for EmTRAC Approval
Dear Internal Revenue Service:
Pursuant to the Employer Tip Reporting Alternative Commitment Program (EmTRAC), I request your approval of the enclosed pro-
gram for(name of business).
In accordance with Notice 2000-21, 2000-19 I.R.B. , if you approve this program, (name
of business) agrees to:
(1) comply with the requirements for filing all required federal tax returns and paying and depositing all federal taxes;
(2) maintain the following records for at least 4 years after the April 15 following the calendar year to which the records relate:
a. gross receipts subject to tipping, and
b. charge receipts showing charged tips;
(3) upon your request, make the following quarterly totals available, by establishment, for statistical samplings:
a. gross receipts subject to tipping,
b. charge receipts showing charged tips,
c. total charged tips, and
d. total tips reported;
(4) operate its EmTRAC program as indicated in the program documents attached to this letter; and
(5) comply with the terms of your approval described in Notice 2000-21.
Also in accordance with Notice 2000-21,
_(name of business)
agrees that a compliance review will not be treated as an examination or an inspection of its books of account or records and that
your inspection of books of account or records pursuant to a tip examination is not an inspection of books or records for purposes of
section 7605(b) of the Internal Revenue Code, and will not be treated as a prior audit for purposes of section 530 of the Revenue Act
of 1978.
All correspondence pertaining to this EmTRAC program (including a notice of termination) should be sent to the address indicated
below, unless we notify you in writing of a change of address. (name
of business) will send correspondence to you in the manner indicated in your approval letter. All correspondence is effective on the
date of the postmark stamped on the envelope or, in the case of a notice sent by certified mail, on the sender’s receipt.
I represent that I have the authority to agree to these terms on behalf of (name
of business).
If you have any questions, please contact
at (telephone number)
or (e-mail address).
Name of Business
\s\
By:
Title:
Date:
Enclosure: EmTRAC program documents
2000–19 I.R.B.969May 8, 2000

Letter – EmTRAC approval
Internal Revenue ServiceDepartment of the Treasury
Service Representative
Person to Contact:
Identification Number:
Contact Telephone Number:
Re: EmTRAC Approval
Dear (Taxpayer):
Thank you for your letter of requesting our approval of your EmTRAC program and containing your agree-
ments with respect to that program. We are pleased to inform you that your EmTRAC Program meets the requirements of Notice
2000-21.
Accordingly, we agree as follows:
Your EmTRAC program will be effective on [insert the first day of the quarter beginning on or after the
date the Service signs the letter]. The Service agrees not to initiate any new tip examinations of you or any of the establishments in-
cluded in your letter for any period during which your EmTRAC program is in effect.
Any section 3121(q) notice and demand that we issue to you (or an establishment) relating to any period during which your Em-
TRAC program is in effect will be based solely on amounts reflected on Form 4137, Social Security and Medicare Tax on Unre-
ported Tip Income, filed by an employee with his or her Form 1040, or Form 885-T,Adjustment of Social Security Tax on Tip Income
Not Reported to Employer, prepared at the conclusion of an employee tip examination.
The Service will not evaluate your EmTRAC program for compliance until
[insert the first day of the
second calendar quarter following the date on which the EmTRAC program becomes effective]. The Service may, however, review
your progress in implementing your EmTRAC program before then.
Your EmTRAC program will remain in effect until you terminate it or the Service terminates it approval. If you no longer wish your
EmTRAC program to apply to one or more of your establishments, you may terminate the program with respect to any establish-
ment(s) by identifying the establishment(s) in writing to the Service Representative described below. If you want to completely ter-
minate your EmTRAC program, please say that in your letter to the Service Representative.
The Service may terminate its approval only (1) if you fail to comply with your agreements described in your letter, (2) if the Service
pursues an administrative or judicial action relating to you, an establishment, or any other related party to your EmTRAC program,
(3) following a significant statutory change in the FICA taxation of tips, or (4) after May 31, 2005.
Any termination will be effective the first day of the first calendar quarter after the terminating party notifies the other party in writ-
ing, unless you (or an establishment) fail to comply with your agreements. In that case, the Service may terminate your EmTRAC
program effective as of the first day of the quarter in which you ceased to comply.
Please send all correspondence relating to your EmTRAC program to (name
and address), unless we notify you in writing otherwise.
If you have any questions regarding this agreement, please contact
(ID )
at (telephone number) or (e-mail address).
Thank you for your participation in the program.
INTERNAL REVENUE SERVICE
By:
ID:
Date:
May 8, 20009702000–19 I.R.B.

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. 2000–21
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-
plicablerequirements 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 mortgage
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 residences; (ii)
the issue meets the requirements of subsec-
tions (c),(d),(e),(f),(g),(h),(i), and (m)(7) of
§ 143; (iii) the issue does not meet the pri-
vate 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 issuance, 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 pe-
riod beginning after the date the prepay-
ment (or complete repayment) is received
to redeem bonds that are part of the issue.
.03 Section 143(f) imposes eligibility re-
quirements concerning the maximum in-
come of mortgagors for whom financing
may be provided by qualified mortgage
bonds. Section 25(c)(2)(A)(iii)(IV) pro-
vides that recipients of mortgage credit
certificates must meet the income require-
ments 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 mort-
gage bond and all certified indebtedness
amounts under a mortgage credit certifi-
cate program are provided to mortgagors
whose family income is 115 percent or less
of the applicable median family income.
Under § 143(f)(6), the income 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 purchase
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 computed
the median gross income for the United
States, the states, and statistical areas
within the states. The income information
was released to the HUD regional offices
on March 9, 2000, 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 in-
terest(http:\\huduser.org\datasets\il.html).
The Internal 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
$50,200 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 March 9, 2000. See
section 2.06 of this revenue procedure.
SECTION 4. EFFECT ON OTHER
REVENUE PROCEDURES
.01 Rev. Proc. 99-22, 1999-15 I.R.B. 5,
is obsolete except as provided in section
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.
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 March 9, 2000, and
ends on the date when these United States
and area median gross income figures are
2000–19 I.R.B.971May 8, 2000

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. 99-22 with respect to bonds
originally sold and nonissued bond
amounts elected not later than June 7,
2000 if the commitments or purchases de-
scribed in section 5.01 are made not later
than August 7, 2000.
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).
May 8, 20009722000–19 I.R.B.

2000–19 I.R.B.973May 8, 2000
Proposed Tip Reporting
Alternative Commitment (TRAC)
Agreement for Use Where
Tipped Employees Receive Both
Cash and Charged Tips (Other
Than in the Food and Beverage
Industry and the Cosmetology
and Barber Industry)
Announcement 2000-19
The Internal Revenue Service is ex-
panding its Tip Rate Determination/Edu-
cation Program (TRD/EP), which is de-
signed to enhance tax compliance among
tipped employees through taxpayer edu-
cation and voluntary advance agreements
instead of traditional audit techniques.
This announcement solicits comments on
a draft agreement for use in industries
other than the food and beverage industry
and the cosmetology and barber industry.
The agreement is entitled Tip Reporting
Alternative Commitment (For use only
where tipped employees receive both cash
and charged tips, other than in the food
and beverage industry and the cosmetol-
ogy and barber industry).
OVERVIEW
The Service developed its TRD/EP in
1993 as a means of enhancing tax compli-
ance while reducing taxpayer burden. In
essence, the TRD/EP envisioned that the
Service and taxpayers in industries in
which tipping is common would work to-
gether to improve tax compliance. The
TRD/EP currently offers employers the
opportunity of entering into one of two
types of agreements. The Tip Rate Deter-
mination Agreement (TRDA) requires the
determination of tip rates; the Tip Report-
ing Alternative Commitment (TRAC)
agreement emphasizes education and tip
reporting procedures. The agreements
also set forth an understanding that em-
ployers that comply with the terms of the
agreement will not be subject to challenge
by the Service. The TRDAs set forth sim-
ilar understandings with respect to em-
ployees who participate in the agree-
ments. Although not set forth in the
TRAC agreements, employees who prop-
erly report tips also will not be subject to
challenge by the Service. The decision to
enter into either a TRDA or a TRAC
agreement is entirely voluntary on the
part of the employer.
In 1995, the Service developed the
TRAC agreement for use in the food and
beverage industry. In 1997, the Service
developed a TRAC agreement for em-
ployers in the hairstyling industry. The
agreements have been both popular and
effective. Other industries have ex-
pressed interest in TRAC agreements tai-
lored to their industries. Because the
number of employees who receive both
cash and charged tips in industries other
than the food and beverage industry and
the cosmetology and barber industry is
relatively small, the Service has designed
a general TRAC agreement for use in
other industries.
To ensure consistency in the agree-
ments offered to taxpayers and to provide
an opportunity for public comment before
making agreements available for use, a
TRAC agreement for use in other indus-
tries is attached to this announcement.
The Service requests comments from in-
dustries that might use the agreement.
The Service plans to allow electronic
systems (including point-of-sale systems)
to satisfy the TRAC education require-
ment. The Service requests comments on
what information the system must provide
to employees to satisfy the education re-
quirement.
COMMENTS
Written comments must be received by
July 7, 2000. Send submissions to Office
of Specialty Taxes, c/o CC:DOM:CORP:R
(Announcement 2000-19), room 5226, In-
ternal Revenue Service, POB 7604, Ben
Franklin Station, Washington, DC 20044.
Submissions may be hand delivered Mon-
day through Friday between the hours of 8
a.m. and 5 p.m. to: Specialty Taxes, c/o
CC:DOM:CORP:R (Ann. 2000-19),
Courier’s desk, Internal Revenue Service,
1111 Constitution Avenue, NW, Washing-
ton, DC. Alternatively, taxpayers may sub-
mit comments electronically via the Inter-
net by selecting the “Tax Regs” option on
the IRS Home Page, or by submitting com-
ments directly to the IRS Internet site at
http://www.irs.ustreas.gov/tax_regs/regslist
.html.
OTHER TRDA AND TRAC
AGREEMENTS
The Service is simultaneously propos-
ing by announcement in this Internal Rev-
enue Bulletin four other agreements: (1) a
revised TRAC agreement for use in the
food and beverage industry (Announce-
ment 2000-22), (2) a revised TRAC
agreement for use in the cosmetology and
barber industry (Announcement 2000-
21), (3) a revised TRDA for use in the
food and beverage industry (Announce-
ment 2000-23), and (4) a new TRDA for
use in any industry other than the food
and beverage industry and the gaming in-
dustry (Announcement 2000-20).
DRAFTING INFORMATION
The principal author of this announce-
ment is Karin Loverud of the Office of the
Associate Chief Counsel (Employee Ben-
efits and Exempt Organizations). For fur-
ther information regarding this announce-
ment, contact Ida Volz of the Office of
Specialty Taxes on (202) 622-4177 (not a
toll-free call).
Part IV. Items of General Interest

May 8, 20009742000–19 I.R.B.
Release date: April 24, 2000
TIP REPORTING ALTERNATIVE COMMITMENT
(For use only where tipped employees receive both cash and charged tips, other than in the food and beverage
industry and the cosmetology and barber industry)
between
Department of the Treasury–Internal Revenue Service
and
[Name of Employer]
This Tip Reporting Alternative Commitment (TRAC) agreement is part of the Tip Rate Determination/Education Program that the
Internal Revenue Service implemented in 1993 to promote tip reporting compliance by employees in accordance with the Internal
Revenue Code of 1986.
Section 6053(a) of the Code requires employees to furnish one or more written statements to their employers reporting all tips re-
ceived in each calendar month. The statements must be furnished to the employer by the 10th day of the following month.
I. DEFINITIONS
A. Service Representativemeans the Internal Revenue Service employee or delegate authorized to execute or terminate this
TRAC agreement on behalf of the Internal Revenue Service.
B. Employer means
[insert name, address, and EIN].
C. Establishmentmeans each of the establishments or divisions listed by name, address, and identifying number in Attachment
A. [sample attached]
1. One place of business. If the Employer has one place of business, that place of business is an Establishment, and no attach-
ment is necessary.
2. Additional establishment. If the Employer subsequently wishes to include an additional establishment in this TRAC agree-
ment, the Employer must notify the Service Representative in writing. The notification must include the name, address, and identi-
fying number of the additional establishment.
D. Employeemeans a person employed by the Establishment who directly or indirectly receives tips of at least $20.00 per month
during the course of the employee’s employment.
II. COMMITMENT OF EMPLOYER
A. Education.
1. New Employees. The Employer will establish an educational program that trains newly hired Employees that the law re-
quires them to report all their cash and charged tips to their employer. At a minimum, the program will give each Employee–
a. A short oral explanation of the reporting requirements and the records maintenance requirements. The material in IRS
Publication 1244, Employee’s Daily Record of Tips and Report to Employer, is suitable for this purpose;
b. Written informational materials, which may include any of the following IRS documents: Publication 1244, Employee’s Daily
Record of Tips and Report to Employer, Publication 531, Reporting Tip Income, and Publication 3148, Tips on Tips for employees; and
c. An explanation of the Employer’s tip reporting procedures.
2. Existing Employees. The Employer will establish a quarterly education program for existing Employees.
B. Employee tip-reporting procedures. Each Establishment will establish a procedure or procedures under which a written or
electronic statement is prepared and processed on a regular basis (no less frequently than monthly), reflecting all tips for services at-
tributable to each Employee. These procedures are to enable Employees to meet their reporting requirements under section 6053(a)
of the Code. An Employer may provide different procedures for cash and charged tips, as well as for directly tipped and indirectly
tipped Employees. IRS Publication 3144, Tips on Tipsfor employers, includes an example of an acceptable TRAC statement that an
employer can use for both directly and indirectly tipped Employees.
C. Returns, taxes, and records.
1. Filing returns and paying and depositing taxes. The Employer (or employing Establishment) will comply with the require-
ments for filing all required federal tax returns and paying and depositing all federal taxes.
2. Maintaining records. Each Establishment will maintain records of the following:
a. Gross receipts subject to tipping, and
b. Charge receipts showing charged tips.
The Employer will retain these records for at least 4 years after the April 15 following the calendar year to which the records relate.
3. Making records available. Upon the request of the Service Representative, the Employer will make the following quarterly
totals available, by Establishment, for statistical samplings of its Establishments:
a. Gross receipts subject to tipping,
b. Charge receipts showing charged tips,

c. Total charged tips, and
d. Total tips reported.
III. COMMITMENT OF INTERNAL REVENUE SERVICE
A. Tip examinations. The IRS will not initiate any tip examinations of the Employer (or Establishment) for any period for which
this TRAC agreement is in effect.
B. Section 3121(q) notice and demand. Any section 3121(q) notice and demand issued to the Employer (or Establishment) relat-
ing to any period during which this TRAC agreement is in effect will be based solely on amounts reflected on–
1. Form 4137, Social Security and Medicare Tax on Unreported Tip Income, filed by an Employee with his or her Form 1040, or
2. Form 885-T,Adjustment of Social Security Tax on Tip Income Not Reported to Employer, prepared at the conclusion of an
employee tip examination.
C. Compliance review. The IRS may evaluate the Employer for compliance with the provisions of this TRAC agreement.
D. Assistance.Upon request, the IRS will assist any Employer or Establishment in establishing, maintaining, or improving its ed-
ucational program or tip reporting procedures.
IV. TERMINATION OF AGREEMENT
A. Termination by Employer. If the Employer no longer wishes this TRAC agreement to apply to one or more Establishments,
the Employer may terminate this TRAC agreement with respect to the Establishment(s) by providing written notification to the Ser-
vice Representative identifying the Establishments(s). If the termination applies to all the Establishments of the Employer, the
TRAC agreement will be terminated.
B. Termination by Internal Revenue Service. The IRS may terminate this TRAC agreement only if–
1. The Service Representative determines that the Employer (or any Establishment) has failed to substantially comply with sec-
tion II.A (pertaining to Education for Employees) or II.B (pertaining to Employee tip reporting procedures);
2. The Employer (or any Establishment) fails to meet any of the requirements of section II.C (pertaining to filing returns and
paying and depositing taxes, maintaining records, and making records available); or
3. The IRS pursues an administrative or judicial action relating to the Employer, Establishment, or any other related party to
this TRAC agreement.
C. Effective date of termination.Except for a termination described in section IV.B.1, any termination will be effective the first
day of the first calendar quarter after the terminating party notifies the other party in writing. In the case of a termination under sec-
tion IV.B.1, the Service Representative may elect an earlier termination date, but no earlier than the first day of the first calendar
quarter of the substantial noncompliance.
D. Renewal after termination. The Employer and the Service Representative may at any time enter into a new TRAC agreement.
V. EFFECTIVE DATE OF AGREEMENT
A. General rule.This TRAC agreement is effective on the first day of the first calendar quarter following the date the Service
Representative signs the TRAC agreement.
B. Additional establishment. This TRAC agreement is effective with respect to an additional establishment on the first day of the
quarter in which notification of the additional establishment is made.
VI. MISCELLANEOUS
A. Examinations and/or inspections of books and records. For purposes of this TRAC agreement–
1. Compliance review. A compliance review is not an examination or an inspection of the taxpayer’s books of account or
records for purposes of section 7605(b) of the Code, and is not a prior audit for purposes of section 530 of the Revenue Act of 1978.
2. Examination. The inspection of books of account or records pursuant to a tip examination is not an inspection of books or
records for purposes of section 7605(b) of the Code, and is not a prior audit for purposes of section 530 of the Revenue Act of 1978.
B. Notices. The parties will send all correspondence pertaining to this TRAC agreement, including a notice of termination, to the
addresses stated below, unless notified in writing of a change of address. In the event of a change of address, the parties must send
all correspondence to the new address. All notices are deemed to be sent or submitted on the date of the postmark stamped on the en-
velope or, in the case of a notice sent by certified mail, the sender’s receipt.
C. Authority. The Employer represents that it has the authority to enter into this TRAC agreement on behalf of itself and the Es-
tablishment(s) listed in Attachment A.
D. General termination and sunset provision. The Commissioner of Internal Revenue may terminate all TRAC agreements at
any time following a significant statutory change in the FICA taxation of tips. After May 31, 2005, the Commissioner may terminate
prospectively the Tip Rate Determination/Education Program and all TRAC agreements.
VII. PAPERWORK REDUCTION ACT
The collections of information contained in this document will be submitted to the Office of Management and Budget for review
2000–19 I.R.B.975May 8, 2000

in accordance with the Paperwork Reduction Act (44 U.S.C. 3507).
An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection
of information displays a valid control number. The collections of information in this document are in sections I.C, II.A, II.B, II.C.2
and 3, and IV.A. This information is required to comply with sections 6053(a) and 6001 of the Internal Revenue Code and to assist
the Internal Revenue Service in its compliance efforts. This information will be used to monitor the Employer’s performance under
the TRAC agreement. The collections of information are required to obtain the benefits available under the TRAC agreement. The
likely respondents are business or other for-profit institutions.
The estimated total annual reporting and/or recordkeeping burden is 4,877 hours.
The estimated annual burden per respondent/recordkeeper varies from 13 hours to 30 hours, depending on individual circum-
stances, with an estimated average of 20 hours. The estimated number of respondents and/or recordkeepers is 300.
The estimated annual frequency of responses (used for reporting requirements only) is on occasion.
Books or records relating to a collection of information must be retained as long as their contents may become material in the ad-
ministration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by section
6103 of the Code.
VIII. SIGNATURES
By signing this TRAC agreement, the parties certify that they have read and agreed to the terms of this document, including At-
tachment A, Establishments.
EMPLOYER:INTERNAL REVENUE SERVICE:
(Name of Employer)
(Signature)(Signature)
BY:BY:
(Service Representative’s Name)
TITLE:TITLE:
ADDRESS:ADDRESS:
(Headquarters street address)(Street address)
(City, state, ZIP code)(City, state, ZIP code)
DATE:DATE:
ATTACHMENT A
ESTABLISHMENTS
[format for individual establishments]
Employer
A & B Company
xx-xxxxxxx
Street address
City, state, zip code
[format for chains]
Employer(parent, if applicable)
XYZ Corp.
yy-yyyyyyy
Street address
City, state, zip code
Establishments (if applicable)
AB Enterprises
Street address
May 8, 20009762000–19 I.R.B.

City, state, zip code
CD Enterprises
Street address
City, state, zip code
Related entity(if applicable)
UVW Corp.
zz-zzzzzzz
Street address
City, state, zip code
Establishments(if applicable)
EF Enterprises
Street address
City, state, zip code
GH Enterprises
Street address
City, state, zip code
2000–19 I.R.B.977May 8, 2000
Proposed Tip Rate
Determination Agreement
(TRDA) for Use by Any Employer
With Tipped Employees (Other
Than in the Food and Beverage
Industry and the Gaming
Industry)
Announcement 2000-20
The Internal Revenue Service is ex-
panding its Tip Rate Determination/Edu-
cation Program (TRD/EP), which is de-
signed to enhance tax compliance among
tipped employees through taxpayer edu-
cation and voluntary advance agreements
instead of traditional audit techniques.
This announcement solicits comments on
a draft agreement for use in industries
other than the food and beverage industry
and the gaming industry. This agreement
is entitled Tip Rate Determination Agree-
ment (For use by any employer with
tipped employees, other than in the food
and beverage industry and the gaming in-
dustry).
OVERVIEW
The Service developed its TRD/EP in
1993 as a means of enhancing tax compli-
ance while reducing taxpayer burden. In
essence, the TRD/EP envisions that the
Service and taxpayers in industries in
which tipping is common would work to-
gether to improve tax compliance. The
TRD/EP currently offers employers the
opportunity of entering into one of two
types of agreements. The Tip Rate Deter-
mination Agreement (TRDA) requires the
determination of tip rates; the Tip Report-
ing Alternative Commitment (TRAC)
agreement emphasizes education and tip
reporting procedures. The agreements
also set forth an understanding that em-
ployers that comply with the terms of the
agreement will not be subject to challenge
by the Service. The TRDAs set forth sim-
ilar understandings with respect to em-
ployees who participate in the agree-
ments. Although not set forth in the
TRAC agreements, employees who prop-
erly report tips also will not be subject to
challenge by the Service. The decision to
enter into either a TRDA or a TRAC
agreement is entirely voluntary on the
part of the employer.
In 1993, the Service developed the
TRDA for use in the food and beverage
industry. In 1997, the Service developed
a TRDA for use in the gaming industry.
Other industries have expressed interest
in TRDAs tailored to their industries. Be-
cause the number of tipped employees in
these other industries is diverse, the Ser-
vice has designed a TRDA for use in in-
dustries other than the food and beverage
industry and the gaming industry.
To ensure consistency in the agreements
offered to taxpayers and to provide an op-
portunity for public comment before mak-
ing agreements available for use, a TRDA
for use in industries other than the food and
beverage industry and the gaming industry
is attached to this announcement. The Ser-
vice requests comments from industries
that might use the agreement.
COMMENTS
Written comments must be received by
July 7, 2000. Send submissions to Office
of Specialty Taxes, c/o CC:DOM:CORP:R
(Announcement 2000-20), room 5226, In-
ternal Revenue Service, POB 7604, Ben
Franklin Station, Washington, DC 20044.
Submissions may be hand delivered Mon-
day through Friday between the hours of 8
a.m. and 5 p.m. to: Specialty Taxes, c/o
CC:DOM:CORP:R (Ann. 2000-20),
Courier’s desk, Internal Revenue Service,
1111 Constitution Avenue, NW, Washing-
ton, DC. Alternatively, taxpayers may sub-
mit comments electronically via the Inter-
net by selecting the “Tax Regs” option on
the IRS Home Page, or by submitting com-
ments directly to the IRS Internet site at
http://www
.irs.ustreas.gov/tax_regs/regslist
.html.
OTHER TRDA AND TRAC
AGREEMENTS
The Service is simultaneously propos-
ing by announcement in this Internal Rev-
enue Bulletin four other agreements: (1) a
revised TRAC agreement for use in the
food and beverage industry (Announce-
ment 2000-22), (2) a revised TRDA for
use in the food and beverage industry
(Announcement 2000-23), (3) a revised
TRAC agreement for use in the cosmetol-
ogy and barber industry (Announcement
2000-21), and (4) a new TRAC agreement
for use in industries, other than the food
and beverage industry and the cosmetol-
ogy and barber industry, in which tipped

employees receive both cash and charged
tips (Announcement 2000-19).
DRAFTING INFORMATION
The principal author of this announce-
ment is Karin Loverud of the Office of the
Associate Chief Counsel (Employee Ben-
efits and Exempt Organizations). For fur-
ther information regarding this announce-
ment, contact Ida Volz of the Office of
Specialty Taxes, on (202) 622-4177 (not a
toll-free call).
May 8, 20009782000–19 I.R.B.
Release date: April 24, 2000
TIP RATE DETERMINATION AGREEMENT
(For use by any employer with tipped employees, other than in the food and beverage
industry and the gaming industry)
between
Department of the Treasury–Internal Revenue Service
and
[Name of Employer]
This Tip Rate Determination Agreement (TRDA) is part of the Tip Rate Determination/Education Program implemented by the In-
ternal Revenue Service in 1993 to promote tip reporting compliance by employees in accordance with the Internal Revenue Code of
1986.
Section 6053(a) of the Code requires employees to furnish one or more written statements to their employers reporting all tips re-
ceived in each calendar month. The statements must be furnished to the employer by the 10th day of the following month.
I. DEFINITIONS AND ATTACHMENTS
A. Definitions.
1. Service Representativemeans the Internal Revenue Service employee or delegate authorized to execute or terminate this
TRDA on behalf of the Internal Revenue Service.
2. Employermeans
[insert name, address, and EIN].
3. Establishmentmeans each of the establishments or divisions listed by name, address, and EIN in Attachment A [sample at-
tached].
a. One place of business. If the Employer has one place of business, that place of business is an Establishment, and no at-
tachment is necessary.
b. Additional establishment. If the Employer subsequently wishes to include an additional establishment in this TRDA, the
Employer must notify the Service Representative in writing. The notification must include the name, address, and identifying num-
ber of the additional establishment.
4. Employeemeans a person whose Occupational Category is listed in Attachment B [sample attached], and who is employed
by an Establishment, and who directly or indirectly receives tips of at least $20.00 per month during the course of the employee’s
employment.
5. Occupational Categorydescribes a group of employees performing a particular type of service to which a stated tip rate is
assigned. Employees performing the same service at different locations or during different shifts may be assigned different Occupa-
tional Categories.
6. Participating Employeemeans an Employee who gives to the Employer a signed Tipped Employee Participation Agreement
(TEPA), which includes the language set forth in Attachment C, indicating participation in the tip reporting program.
7. Tip Ratemeans the applicable rate described in Section III.
B. Attachments
1. Attachment A, Establishments, lists the Employer’s establishments participating in this TRDA.
2. Attachment B, Occupational Categories and Initial Tip Rates, lists the Employee occupational categories and tip rates subject
to this TRDA.
3. Attachment C, Tipped Employee Participation Agreement, is the document signed by an Employee agreeing to report tips at
or above the rate established for the Employee’s Occupational Category.
4. Attachment D, Formula for Tip Rate Calculation, is the calculation described in section III.A.1 for determining tip rates.
II. COMMITMENT OF EMPLOYER
A. Maintaining records. While this TRDA is in effect, and in addition to records otherwise required to be maintained, the Em-
ployer will maintain the following records:
1. Employee records. For each Employee, the Employee’s name, address, social security number, reported tips, and shift(s)
and hours.

2. Tip rates records. All records of data used to determine the tip rates.
The Employer will retain the records listed in this section II.A. for at least 4 years after the April 15 following the calendar year to
which the records relate.
B. Furnishing information. The Employer will furnish to the Service Representative the following documents:
1. Quarterly report of employees. A quarterly report showing, as of the last day of each quarter, (1) the total number of Em-
ployees, and (2) the total number of Participating Employees. The report is due on the last day of the month following each calendar
quarter.
2. Annual report of nonparticipating Employees.
a. General rule. For each Employee who is a nonparticipating Employee on the last day of the calendar year, an annual re-
port showing the Employee’s name, address, social security number, shift(s), and hours. The report may list all Employees, indicat-
ing those Employees who are nonparticipating Employees, as long as the required information is included for all nonparticipating
Employees. The report is due on March 31 following each calendar year.
b. Exception. No report is required for an Occupational Category for any calendar year for which all the Employees in the
Occupational Category reported tips at a rate equal to or greater than the rates established under section III of this TRDA.
C. Making records available. At the request of the Service Representative, the Employer will furnish any of the records identified
in section II.A.
D. Filing returns and paying and depositing taxes. The Employer or employing Establishment will comply with the requirements
for filing all required federal tax returns and paying and depositing all federal taxes.
III. TIP RATES
A. Tip rates.
1. Determining tip rates. The Employer will determine tip rates based on the formula set forth in Attachment D, Formula for
Tip Rate Calculation. If information necessary for the formula is unavailable or insufficient, the Employer will determine tip rates
based on information available to the Employer, historical information provided by the Service Representative, and generally ac-
cepted accounting principles. The rates will generally be based on a dollar amount per hour, but a different measure may be used.
2. Initial tip rates. The initial tip rates are identified in Attachment B, Occupational Categories and Initial Tip Rates. They will
remain in effect through December 31 of the calendar year following the year in which this TRDA takes effect.
B. Determining subsequent tip rates and Occupational Categories.
1. Annual review. The Employer will review annually, on a calendar year basis, its Occupational Categories and the tip rates
assigned to its Occupational Categories.
2. Procedures.
a. Employer submission. If the Employer believes that a change in Occupational Categories or a revision of one or more rates is
appropriate, the Employer will submit proposed revisions to the Service Representative by September 30. If the Employer fails to submit
a proposed rate revision by September 30, the Employer will be treated as having submitted the rate in effect for the current year.
b. Internal Revenue Service review. The Service Representative will review the proposed rates and notify the Employer in
writing of the IRS’s approval or disapproval by November 30. If the IRS does not approve one or more proposed rates, the existing
rate or rates will be continued until no later than the last day of the following February. If the Employer and the IRS are unable to
agree upon a rate or rates by the last day of the following February, this TRDA will terminate pursuant to section V.C.
3. Effective date of revised rates and Occupational Categories. Approved revised rates for a calendar year will become effec-
tive on the later of (1) January 1 of the calendar year, or (2) the first day of the month following the date the Employer and the Ser-
vice Representative agree upon a revised rate.
IV. COMMITMENT OF INTERNAL REVENUE SERVICE
A. Participating Employee. The IRS will not examine a Participating Employee’s tip income for any period for which a TEPA is
in effect, if the Employee reports tips to the Employer at or above the tip rate established for the Employee.
B. Employer.
1. Tip examinations. The IRS will not initiate any tip examinations of the Employer (or Establishment) for any period for
which this TRDA is in effect.
2. Section 3121(q) notice and demand. Any section 3121(q) notice and demand issued to the Employer (or Establishment) re-
lating to any period during which this TRDA is in effect will be based solely on amounts reflected on–
a. Form 4137, Social Security and Medicare Tax on Unreported Tip Income, filed by an Employee with his or her Form 1040, or
b. Form 885-T,Adjustment of Social Security Tax on Tip Income Not Reported to Employer, prepared at the conclusion of an
employee tip examination.
C. Compliance review. The IRS may evaluate the Employer and its Participating Employees for compliance with the provisions
of this TRDA.
2000–19 I.R.B.979May 8, 2000

V. TERMINATION OF AGREEMENT
A. Termination by Employer. If the Employer no longer wishes this TRDA to apply to one or more Establishments, the Employer
may terminate this TRDA with respect to the Establishment(s), by providing written notification to the Service Representative iden-
tifying the Establishments(s). If the termination applies to all the Establishments of the Employer, the TRDA will be terminated.
B. Termination by Internal Revenue Service. The IRS may terminate this TRDA only if–
1. As of any December 31, less than 75 percent of the Employees are Participating Employees,
2. The Employer fails to meet any of the requirements of section II, Commitment of Employer, or
3. The IRS pursues an administrative or judicial action relating to the Employer, Establishment, or any other related party to
this TRDA.
C. Termination upon failure of parties to agree to revision of tip rates. This TRDA will terminate if the Employer and the Service
Representative fail to agree to a revision of the tip rates under the procedures set forth in section III.B.2.
D. Notice of termination and effective date. Any termination will be effective the first day of the first calendar quarter after the
terminating party notifies the other party in writing.
E. Renewal after termination. The Employer and the Service Representative may at any time enter into a new TRDA.
VI. EFFECTIVE DATE OF AGREEMENT
A. General rule. This TRDA is effective on the first day of the first calendar quarter following the date the Service Representa-
tive signs the TRDA.
B. Additional establishment. This TRDA is effective with respect to an additional establishment on the first day of the quarter in
which notification of the additional establishment is made.
VII. MISCELLANEOUS
A. Examinations and/or inspections of books and records. For purposes of this TRDA–
1. Compliance review. A compliance review is not an examination or an inspection of the taxpayer’s books of account or
records for purposes of section 7605(b) of the Code, and is not a prior audit for purposes of section 530 of the Revenue Act of 1978.
2. Examination. The inspection of books of account or records pursuant to a tip examination is not an inspection of books or
records for purposes of section 7605(b) of the Code, and is not a prior audit for purposes of section 530 of the Revenue Act of 1978.
B. Notices. The parties will send all correspondence pertaining to this TRDA to the addresses stated below, unless notified in
writing of a change of address. In the event of a change of address, the parties must send all correspondence to the new address. All
notices are deemed to be sent or submitted on the date of the postmark stamped on the envelope or, in the case of a notice sent by
certified mail, the sender’s receipt.
C. Authority. The Employer represents that it has the authority to enter into this TRDA.
D. General termination and sunset provision. The Commissioner of Internal Revenue may terminate all TRDAs at any time fol-
lowing a significant statutory change in the FICA taxation of tips. After May 31, 2005, the Commissioner may terminate prospec-
tively the Tip Rate Determination/Education Program and all TRDAs.
VIII. PAPERWORK REDUCTION ACT
The collections of information contained in this document will be submitted to the Office of Management and Budget for review
in accordance with the Paperwork Reduction Act (44 U.S.C. 3507).
An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection
of information displays a valid control number. The collections of information in this document are in sections I.A.3, 4, and 5, II.A,
II.B, II.C, III, and V.A. This information is required to comply with sections 6053(a) and 6001 of the Internal Revenue Code and to
assist the IRS in its compliance efforts. This information will be used to monitor the Employer’s performance under the TRDA. The
collections of information are required to obtain the benefits available under the TRDA. The likely respondents are business or other
for-profit institutions.
The estimated total annual reporting and/or recordkeeping burden is 1,897 hours.
The estimated annual burden per respondent/recordkeeper varies from 6 hours to 21 hours, depending on individual circum-
stances, with an estimated average of 11 hours. The estimated number of respondents and/or recordkeepers is 100.
The estimated annual frequency of responses (used for reporting requirements only) is on occasion.
Books or records relating to a collection of information must be retained as long as their contents may become material in the ad-
ministration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by section
6103 of the Code.
IX. SIGNATURES
By signing this TRDA, the parties certify that they have read and agreed to the terms of this document, including Attachments A,
B, and C.
May 8, 20009802000–19 I.R.B.

EMPLOYER:INTERNAL REVENUE SERVICE:
(Name of Employer)
(Signature)(Signature)
BY:BY:
(Service Representative’s Name)
TITLE:TITLE:
ADDRESS:ADDRESS:
(Headquarters street address)(Street address)
(City, state, ZIP code)(City, state, ZIP code)
DATE:DATE:
ATTACHMENT A
ESTABLISHMENTS
[format for individual establishments]
Employer
A & B Company
xx-xxxxxxx
Street address
City, state, zip code
[format for chains]
Employer(parent, if applicable)
XYZ Corp.
yy-yyyyyyy
Street address
City, state, zip code
Establishments (if applicable)
AB Enterprises
Street address
City, state, zip code
CD Enterprises
Street address
City, state, zip code
Related entity(if applicable)
UVW Corp.
zz-zzzzzzz
Street address
City, state, zip code
Establishments(if applicable)
EF Enterprises
Street address
City, state, zip code
2000–19 I.R.B.981May 8, 2000

ATTACHMENT B
OCCUPATIONAL CATEGORIES AND INITIAL TIP RATES
[sample format]
Occupational CategoriesInitial Tip Rates
Category A actual tips
Category B — 1st shift___ % of sales
Category B — 2nd shift% of sales
Category B — 3rd shift% of sales
Category C — location 1$ /
Category C — location 2$ /
May 8, 20009822000–19 I.R.B.
ATTACHMENT C
TIPPED EMPLOYEE PARTICIPATION AGREEMENT
I am an employee of and wish to participate in my employer’s tip
reporting program.
In accordance with a Tip Rate Determination Agreement between my employer and the Internal Revenue Service, I agree to report
my tips to my employer, as required by law, at or above the tip rate established by my employer and approved by the IRS for my Oc-
cupational Category.
I also acknowledge that, to continue participation in my employer’s tip reporting program, I must file all federal tax returns required
by law and pay all federal taxes for which I am liable.
EMPLOYEE
Name (printed):
Signature:
Home address:
Social Security Number:
DATE:
Attachments:
Copy of TRDA and Attachment B (Occupational Categories and Tip Rates)
Copy of TRDA Information for Employees
ATTACHMENT D
FORMULA FOR TIP RATE CALCULATION
Directly tipped employees
Step 1: Determine charged and cash tip rates.
Charged tip rate = Total charged tips
Total charged receipts with charged tips*
Cash tip rate = Charged tip rate
less: difference between charged and cash tips
Step 2:Calculate tip rate per hour (or per receipts)
1. Gross receipts subject to tipping
2. minus:stiff factor
charged receipts with charged tips
other factors
3. equals:receipts subject to cash tipping
4. timescash tip rate
5. equals:cash tips received
6. plus:charged tips
tips received from other employees
7. equals:total tips received
8. minus:tip outs (if applicable)
9. equals:adjusted tips
10. divided by:total hours worked (or total receipts)

11. equals:tip rate per hour (or per receipts)
Indirectly tipped employees
Calculate tip rate per hour:
Tip rate per hour = Tips received from other workers
Total hours worked
* If this figure is unavailable, use “total charged receipts” for the denominator to figure the charged tip rate.
2000–19 I.R.B.983May 8, 2000
Proposed Revised Tip Reporting
Alternative Commitment (TRAC)
Agreement for Use in the
Cosmetology and Barber
Industry
Announcement 2000-21
The Internal Revenue Service is ex-
panding its Tip Rate Determination/Edu-
cation Program (TRD/EP), which is de-
signed to enhance tax compliance among
tipped employees through taxpayer edu-
cation and voluntary advance agreements
instead of traditional audit techniques.
This announcement solicits comments on
a draft agreement entitled Tip Reporting
Alternative Commitment (For use in the
cosmetology and barber industry).
OVERVIEW
The Service developed its TRD/EP in
1993 as a means of enhancing tax compli-
ance while reducing taxpayer burden. In
essence, the TRD/EP envisioned that the
Service and taxpayers in industries in
which tipping is common would work to-
gether to improve tax compliance. The
TRD/EP currently offers employers the
opportunity of entering into one of two
types of agreements. The Tip Rate Deter-
mination Agreement (TRDA) requires the
determination of tip rates; the Tip Report-
ing Alternative Commitment (TRAC)
agreement emphasizes education and tip
reporting procedures. The agreements
also set forth an understanding that em-
ployers that comply with the terms of the
agreement will not be subject to challenge
by the Service. The TRDAs set forth sim-
ilar understandings with respect to em-
ployees who participate in the agree-
ments. Although not set forth in the
TRAC agreements, employees who prop-
erly report tips also will not be subject to
challenge by the Service. The decision to
enter into either a TRDA or a TRAC
agreement is entirely voluntary on the
part of the employer.
In 1997, the Service developed a
TRAC agreement for use in the hair-
styling industry. The industry has ex-
pressed interest in making the TRAC
agreement available to the entire cosme-
tology and barber industry. The industry
has also advised the Service that a sub-
stantial portion of the industry includes
independent contractors who pay a booth
rental for use of space.
To ensure consistency in the agree-
ments offered to taxpayers and to provide
an opportunity for public comment before
making agreements available for use, a
revised TRAC agreement is attached to
this announcement. The revised agree-
ment addresses workers who are booth
renters and other independent contractors
and will be available to the entire indus-
try. The Service requests comments from
the industry regarding the inclusion of
booth renters and other independent con-
tractors.
The Service plans to allow electronic
systems (including point-of-sale systems)
to satisfy the TRAC education require-
ment. The Service requests comments on
what information the system must provide
to employees to satisfy the education re-
quirement.
COMMENTS
Written comments must be received by
July 7, 2000. Send submissions to Office
of Specialty Taxes, c/o CC:DOM:CORP:R
(Announcement 2000-21), room 5226, In-
ternal Revenue Service, POB 7604, Ben
Franklin Station, Washington, DC 20044.
Submissions may be hand delivered Mon-
day through Friday between the hours of 8
a.m. and 5 p.m. to: Specialty Taxes, c/o
CC:DOM:CORP:R (Ann. 2000-21),
Courier’s desk, Internal Revenue Service,
1111 Constitution Avenue, NW, Washing-
ton, DC. Alternatively, taxpayers may sub-
mit comments electronically via the Inter-
net by selecting the “Tax Regs” option on
the IRS Home Page, or by submitting com-
ments directly to the IRS Internet site at
http://www.irs.ustreas.gov/tax_regs/regslist
.html.
OTHER TRDA AND TRAC
AGREEMENTS
The Service is simultaneously propos-
ing by announcement in this Internal Rev-
enue Bulletin four other agreements: (1) a
revised TRAC agreement for use in the
food and beverage industry (Announce-
ment 2000-22), (2) a revised TRDA for
use in the food and beverage industry
(Announcement 2000-23), (3) a new
TRAC agreement for use in industries,
other than the food and beverage industry
and the cosmetology and barber industry,
in which tipped employees receive both
cash and charged tips (Announcement
2000-19), and (4) a new TRDA for use in
any industry other than the food and bev-
erage industry and the gaming industry
(Announcement 2000-20).
DRAFTING INFORMATION
The principal author of this announce-
ment is Karin Loverud of the Office of the
Associate Chief Counsel (Employee Ben-
efits and Exempt Organizations). For fur-
ther information regarding this announce-
ment, contact Don Segal of the Office of
Specialty Taxes on (202) 622-4177 (not a
toll-free call).

Release date: April 24, 2000
TIP REPORTING ALTERNATIVE COMMITMENT
(For use in the cosmetology and barber industry)
between
Department of the Treasury–Internal Revenue Service
and
[Name of Business]
This Tip Reporting Alternative Commitment (TRAC) agreement is part of the Tip RateDetermination/Education Program that the
Internal Revenue Service implemented in1993 to promote tip reporting compliance by employees in accordance with the Internal
Revenue Code of 1986.
For federal income tax purposes, taxpayers are required to report to the IRS all income from all sources, unless the income is ex-
pressly excluded. Under section 61(a)(1) of the Code, gross income includes compensation for services, including tips. Under sec-
tion 61(a)(2), gross income includes all income from business.
Section 6053(a) of the Code requires employees to furnish one or more written statements to their employers reporting all tips re-
ceived in each calendar month. The statements must be furnished to the employer by the 10th day of the following month.
I. DEFINITIONS
A. Service Representativemeans the Internal Revenue Service employee or delegate authorized to execute or terminate this
TRAC agreement on behalf of the Internal Revenue Service.
B. Businessmeans
[insert name, address, and EIN].
C. Establishmentmeans each of the establishments or divisions listed by name, address, and identifying number in Attachment A
[sample attached].
1. One place of business. If the Business has one place of business, that place of business is an Establishment, and no attach-
ment is necessary.
2. Additional establishment. If the Business subsequently wishes to include an additional establishment in this TRAC agree-
ment, the Business must notify the Service Representative in writing. The notification must include the name, address, and identify-
ing number of the additional establishment.
D. Employeemeans a person employed by the Establishment who directly or indirectly receives tips of at least $20.00 per month
during the course of the employee’s employment.
E. Booth Rentermeans a person who rents a booth from the Business for a fee, receives and retains all fees from customers, gen-
erally selects his or her own customers, and generally sets his or her own work schedule.
F. Independent Contractormeans a person who is neither an Employee nor a Booth Renter, but who performs services at an Es-
tablishment and meets the standards of an independent contractor with respect to that establishment.
Il. COMMITMENT OF BUSINESS
A. Commitment with respect to Employees.
1. Education.
a. New Employees. The Business will establish and maintain an educational program to train newly hired Employees that
the law requires employees to report monthly their cash and charged tips to their employer. At a minimum, the program will give
each Employee–
i. A short oral explanation of the reporting requirements and the records maintenance requirements. The material in IRS
Publication 1244, Employee’s Daily Record of Tips and Report to Employer, is suitable for this purpose;
ii. Written informational materials, which may include any of the following IRS documents: Publication 1244,
Employee’s Daily Record of Tips and Report to Employer, Publication 531, Reporting Tip Income, and Publication 3148, Tips on
Tipsfor employees; and
iii. An explanation of the Business’s tip reporting procedures.
b. Existing Employees. The Business will establish and maintain a quarterly education program for existing Employees.
2. Employee tip-reporting procedures. Each Establishment will establish a procedure or procedures under which a written or
electronic statement is prepared and processed on a regular basis (no less frequently than monthly), reflecting all tips for services at-
tributable to each Employee. These procedures are to enable Employees to meet their reporting requirements under section 6053(a)
of the Code. The Business or Establishment may provide different procedures for cash and charged tips, as well as for directly
tipped and indirectly tipped Employees. IRS Publication 3144, Tips on Tipsfor employers, includes an example of an acceptable
TRAC statement that an employer can use for both directly and indirectly tipped Employees.
May 8, 20009842000–19 I.R.B.

2000–19 I.R.B.985May 8, 2000
B. Educational commitment with respect to Booth Renters and Independent Contractors.
1. New Booth Renters and Independent Contractors. The Business will give each new Booth Renter or Independent Contrac-
tor a copy of Publication 531, Reporting Tip Income, and a copy of Publication 3518, Beauty Industry Federal Tax Guidelines.
2. Existing Booth Renters and Independent Contractors.At the end of each calendar year, the Business will provide a copy of
Publication 531 and Publication 3518 to each Booth Renter and Independent Contractor who performed services on the Business’s
premises at any time during the calendar year.
C. Returns, taxes, and records.
1. Filing returns and paying and depositingtaxes. The Business (or employing Establishment) will comply with the require-
ments for filing all required federal tax returns and paying and depositing all federal taxes.
2. Maintaining records. Each Establishment will maintain records of the following:
a. Gross receipts subject to tipping, and
b. Charge receipts showing charged tips.
The Business will retain these records for at least 4 years after the April 15 following the calendar year to which the records relate.
3. Making records available. Upon the request of the Service Representative, the Business will make the following quarterly
totals available, by Establishment, for statistical samplings of its Establishments:
a. Total charged tips,
b. Charge receipts showing charged tips,
c. Total tips reported, and
d. Gross receipts subject to tipping.
III. COMMITMENT OF INTERNAL REVENUE SERVICE
A. Tip examinations. The IRS will not initiate any tip examinations of the Business (or Establishment) for any period for which
this TRAC agreement is in effect.
B. Section 3121 (q) notice and demand. Any section 3121 (q) notice and demand issued to the Business (or Establishment) relat-
ing to any period during which this TRAC agreement is in effect will be based solely on amounts reflected on–
1. Form 4137, Social Security and Medicare Tax on Unreported Tip Income,filed by an Employee with his or her Form 1040,
or
2. Form 885-T, Adjustment of Social Security Tax on Tip Income Not Reported to Employer, prepared at the conclusion of an
employee tip examination.
C. Compliance review. The IRS may evaluate the Business for compliance with the provisions of this TRAC agreement.
D. Assistance. Upon request, the IRS will assist any Business or Establishment in establishing, maintaining, or improving its ed-
ucational program or tip reporting procedures.
IV. TERMINATION OF AGREEMENT
A. Termination by Business. If the Business no longer wishes this TRAC agreement to apply to one or more Establishments, the
Business may terminate this TRAC agreement with respect to the Establishment(s) by providing written notification to the Service
Representative identifying the Establishments(s). If the termination applies to all the Establishments of the Business, the TRAC
agreement will be terminated.
B. Termination by Internal Revenue Service. The IRS may terminate this
TRAC agreement only if–
1. The IRS determines that the Business (or any Establishment) has failed to substantially comply with section II.A (pertaining
to the Business’s commitment with respect to employees);
2. The Business (or any Establishment) fails to meet any of the requirements of section II.C (pertaining to filing returns and
paying and depositing taxes, maintaining records, and making records available) or II.D (pertaining to Booth Renter and Indepen-
dent Contractor information); or
3. The IRS pursues an administrative or judicial action relating to the Business, Establishment, or any other related party to this
TRAC agreement.
C. Effective date of termination. Except for a termination described in section IV.B.1, any termination will be effective the first
day of the first calendar quarter after the terminating party notifies the other party in writing. In the case of a termination under sec-
tion IV.B.1, the Service Representative may elect an earlier termination date, but no earlier than the first day of the first calendar
quarter of the substantial noncompliance.
D. Renewal after termination.The Business and the Service Representative may at any time enter into a new TRAC agreement.
V. EFFECTIVE DATE OF AGREEMENT
A. General rule. This TRAC agreement is effective on the first day of the first calendar quarter following the date the Service

Representative signs the TRAC agreement.
B. Additional establishment. This TRAC agreement is effective with respect to an additional establishment on the first day of the
quarter in which notification of the additional establishment is made.
VI. MISCELLANEOUS
A. Examinations and/or inspections of books and records. For purposes of this TRAC agreement–
1. Compliance review. A compliance review is not an examination or an inspection of the taxpayer’s books of account or
records for purposes of section 7605(b) of the Code, and is not a prior audit for purposes of section 530 of the Revenue Act of 1978.
2. Examination.The inspection of books of account or records pursuant to a tip examination is not an inspection of books or
records for purposes of section 7605(b) of the Code, and is not a prior audit for purposes of section 530 of the Revenue Act of 1978.
B. Employment tax classification. Nothing in this TRAC agreement is intended to address the classification, for employment tax
purposes, of any person who performs services at or for an Establishment.
C. Notices. The parties will send all correspondence pertaining to this TRAC agreement, including a notice of termination, to the
addresses stated below, unless notified in writing of a change of address. In the event of a change of address, the parties must send
all correspondence to the new address. All notices are deemed to be sent or submitted on the date of the postmark stamped on the en-
velope or, in the case of a notice sent by certified mail, the sender’s receipt.
D. Authority. The Employer represents that it has the authority to enter into this TRAC agreement on behalf of itself and the Es-
tablishment(s) listed in Attachment A.
E. General termination and sunset provision. The Commissioner of Internal Revenue may terminate all TRAC agreements at any
time following a significant statutory change in the FICA taxation of tips. After May 31, 2005, the Commissioner may terminate
prospectively the Tip Rate Determination/Education Program and all TRAC agreements.
VIl. PAPERWORK REDUCTION ACT
The collections of information contained in this document have been reviewed and approved by the Office of Management and
Budget in accordance with the Paperwork Reduction Act (44 U.S.C. 3507) under control number 1545-1529.
An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection
of information displays a valid control number. The collections of information in this document are in sections I.C, II.A, II.B, II.C.1
and 2, and IV.A. This information is required to comply with sections 6053(a) and 6001 of the lnternal Revenue Code and to assist
the Internal Revenue Service in its compliance efforts. This information will be used to monitor the Employees performance under
the TRAC agreement. The collections of information are required to obtain the benefits available under the TRAC agreement. The
likely respondents are business or other for-profit institutions.
The estimated total annual reporting and/or recordkeeping burden is 58,267 hours.
The estimated annual burden per respondent/recordkeeper varies from 9 hours to 30 hours, depending on individual circum-
stances, with an estimated average of 14 hours. The estimated number of respondents and/or recordkeepers is 6,400.
The estimated annual frequency of responses (used for reporting requirements only) is on occasion.
Books or records relating to a collection of information must be retained as long as their contents may become material in the ad-
ministration of any internal revenue law. Generally tax returns and tax return information are confidential, as required by section
6103 of the Code.
VIII. SIGNATURES
By signing this TRAC agreement, the parties certify that they have read and agreed to the terms of this document, including At-
tachment A, Names, Addresses, and Employer Identification Numbers by Employer of Establishments Covered Under TRAC
Agreements.
Business:INTERNAL REVENUE SERVICE:
(Name of Business)
(Signature)(Signature)
BY:BY:
(Service Representative’s Name)
TITLE:TITLE:
May 8, 20009862000–19 I.R.B.

ADDRESS:ADDRESS:
(Headquarters street address)(Street address)
(City, state, ZIP code)(City, state, ZIP code)
DATE:DATE:
ATTACHMENT A
ESTABLISHMENTS
[format for individual establishments]
Business
A & B Hairstylists
xx-xxxxxxx
Street address
City, state, zip code
[format for chains]
Business(parent, if applicable)
XYZ Corp.
yy-yyyyyyy
Street address
City, state, zip code
Establishments(if applicable)
AB Restaurant
Street address
City, state, zip code
CD Restaurant
Street address
City, state, zip code
Related entity(if applicable)
UVW Corp.
zz-zzzzzzz
Street address
City, state, zip code
Establishments(if applicable)
EF Restaurant
Street address
City, state, zip code
2000–19 I.R.B.987May 8, 2000
Proposed Revised Tip Reporting
Alternative Commitment (TRAC)
Agreement for Use in the Food
and Beverage Industry
Announcement 2000-22
The Internal Revenue Service is ex-
panding its Tip Rate Determination/Edu-
cation Program (TRD/EP), which is de-
signed to enhance tax compliance among
tipped employees through taxpayer edu-
cation and voluntary advance agreements
instead of traditional audit techniques.
This announcement solicits comments on
a draft agreement entitled Tip Reporting
Alternative Commitment (For use in the
food and beverage industry).
OVERVIEW
The Service developed its TRD/EP in
1993 as a means of enhancing tax compli-
ance while reducing taxpayer burden. In
essence, the TRD/EP envisioned that the
Service and taxpayers in industries in
which tipping is common would work to-
gether to improve tax compliance. The
TRD/EP currently offers employers the
opportunity of entering into one of two
types of agreements. The Tip Rate Deter-
mination Agreement (TRDA) requires the
determination of tip rates; the Tip Report-
ing Alternative Commitment (TRAC)
agreement emphasizes education and tip
reporting procedures. The agreements
also set forth an understanding that em-
ployers that comply with the terms of the
agreement will not be subject to challenge
by the Service. The TRDAs set forth sim-

ilar understandings with respect to em-
ployees who participate in the agree-
ments. Although not set forth in the
TRAC agreements, employees who prop-
erly report tips also will not be subject to
challenge by the Service. The decision to
enter into either a TRDA or a TRAC
agreement is entirely voluntary on the
part of the employer.
In 1995, the Service developed the
TRAC agreement for use in the food and
beverage industry. The agreement has
been both popular and effective. The in-
dustry has expressed interest in making
the educational program and tip reporting
procedures more flexible.
To ensure consistency in the agree-
ments offered to taxpayers and to provide
an opportunity for public comment before
making agreements available for use, a
revised TRAC agreement is attached to
this announcement. The revised agree-
ment is more flexible.
The Service also announces that it will
treat an electronic system (including point-
of-sale systems) that prompts an employee
to report tips after each sale as meeting the
TRAC requirement that an employer edu-
cate its employee at least quarterly. The
Service requests comments on other elec-
tronic tip reporting system.
COMMENTS
Written comments must be received by
July 7, 2000. Send submissions to Office
of Specialty Taxes, c/o CC:DOM:CORP:R
(Announcement 2000-22), room 5226, In-
ternal Revenue Service, POB 7604, Ben
Franklin Station, Washington, DC 20044.
Submissions may be hand delivered Mon-
day through Friday between the hours of 8
a.m. and 5 p.m. to: Specialty Taxes, c/o
CC:DOM:CORP:R (Ann. 2000-22),
Courier’s desk, Internal Revenue Service,
1111 Constitution Avenue, NW, Washing-
ton, DC. Alternatively, taxpayers may sub-
mit comments electronically via the Inter-
net by selecting the “Tax Regs” option on
the IRS Home Page, or by submitting com-
ments directly to the IRS Internet site at
http://www
.irs.ustreas.gov/tax_regs/regslist
.html.
OTHER TRDA AND TRAC
AGREEMENTS
The Service is simultaneously propos-
ing by announcement in this Internal Rev-
enue Bulletin four other agreements: (1) a
revised TRDA for use in the food and
beverage industry (Announcement 2000-
23), (2) a revised TRAC agreement for
use in the cosmetology and barber indus-
try (Announcement 2000-21), (3) a new
TRAC agreement for use in industries,
other than the food and beverage industry
and the cosmetology and barber industry,
in which tipped employees receive both
cash and charged tips (Announcement
2000-19), and (4) a new TRDA for use in
any industry other than the food and bev-
erage industry and the gaming industry
(Announcement 2000-20).
DRAFTING INFORMATION
The principal author of this announce-
ment is Karin Loverud of the Office of the
Associate Chief Counsel (Employee Ben-
efits and Exempt Organizations). For fur-
ther information regarding this announce-
ment, contact Ida Volz of the Office of
Specialty Taxes on (202) 622-4177 (not a
toll-free call).
May 8, 20009882000–19 I.R.B.
Release date: April 24, 2000
TIP REPORTING ALTERNATIVE COMMITMENT
(For use only in the food and beverage industry)
between
Department of the Treasury–Internal Revenue Service
and
[Name of Employer]
This Tip Reporting Alternative Commitment (TRAC) agreement is part of the Tip Rate Determination/Education Program that the
Internal Revenue Service implemented in 1993 to promote tip reporting compliance by employees in accordance with the Internal
Revenue Code of 1986.
Section 6053(a) of the Code requires employees to furnish one or more written statements to their employers reporting all tips re-
ceived in each calendar month. The statements must be furnished to the employer by the 10th day of the following month.
I. DEFINITIONS
A. Service Representativemeans the Internal Revenue Service employee or delegate authorized to execute or terminate this
TRAC agreement on behalf of the Internal Revenue Service.
B. Employermeans
[insert name, address, and EIN].
C. Establishmentmeans each of the establishments or divisions listed by name, address, and identifying number in Attachment
A. [sample attached]
1. One place of business. If the Employer has one place of business, that place of business is an Establishment, and no attach-
ment is necessary.
2. Additional establishment. If the Employer subsequently wishes to include an additional establishment in this TRAC agree-
ment, the Employer must notify the Service Representative in writing. The notification must include the name, address, and identi-
fying number of the additional establishment.
D. Employeemeans a person employed by the Establishment who directly or indirectly receives tips of at least $20.00 per month
during the course of the employee’s employment.

2000–19 I.R.B.989May 8, 2000
II. COMMITMENT OF EMPLOYER
A. Education.
1. New Employees. The Employer will establish an educational program that trains newly hired Employees that the law re-
quires them to report all their cash and charged tips to their employer. At a minimum, the program will give each Employee–
a. A short oral explanation of the reporting requirements and the records maintenance requirements. The material in IRS
Publication 1244, Employee’s Daily Record of Tips and Report to Employer, is suitable for this purpose;
b. Written informational materials, which may include any of the following IRS documents: Publication 1244, Employee’s
Daily Record of Tips and Report to Employer, Publication 531, Reporting Tip Income, and Publication 1872, Tips on Tips for em-
ployees in the food and beverage industry; and
c. An explanation of the Employer’s tip reporting procedures.
2. Existing Employees. The Employer will establish a quarterly education program for existing Employees.
B. Employee tip-reporting procedures. Each Establishment will establish a procedure or procedures under which a written or
electronic statement is prepared and processed on a regular basis (no less frequently than monthly), reflecting all tips for services at-
tributable to each Employee. These procedures are to enable Employees to meet their reporting requirements under section 6053(a)
of the Code. An Employer may provide different procedures for cash and charged tips, as well as for directly tipped and indirectly
tipped Employees. IRS Publication 1875, Tips on Tipsfor employers in the food and beverage industry, includes an example of an
acceptable TRAC statement that an employer can use for both directly and indirectly tipped Employees.
C. Returns, taxes, and records.
1. Filing returns and paying and depositing taxes.
a. In general.The Employer (or employing Establishment) will comply with the requirements for filing all required federal
tax returns and paying and depositing all federal taxes.
b. Form 8027. For each Establishment that is a “large food or beverage establishment,” the Employer will comply with the
requirements for filing Form 8027, Employer’s Annual Information Return of Tip Income and Allocated Tips, and send an additional
copy of each Form 8027 to the IRS.
2. Maintaining records. Each Establishment will maintain records of the following:
a. Gross receipts subject to tipping, and
b. Charge receipts showing charged tips.
The Employer will retain these records for at least 4 years after the April 15 following the calendar year to which the records relate.
3. Making records available. Upon the request of the Service Representative, the Employer will make the following quarterly
totals available, by Establishment, for statistical samplings of its Establishments:
a. Gross receipts subject to tipping,
b. Charge receipts showing charged tips,
c. Total charged tips, and
d. Total tips reported.
III. COMMITMENT OF INTERNAL REVENUE SERVICE
A. Tip examinations. The IRS will not initiate any tip examinations of the Employer (or Establishment) for any period for which
this TRAC agreement is in effect.
B. Section 3121(q) notice and demand. Any section 3121(q) notice and demand issued to the Employer (or Establishment) relat-
ing to any period during which this TRAC agreement is in effect will be based solely on amounts reflected on–
1. Form 4137, Social Security and Medicare Tax on Unreported Tip Income, filed by an Employee with his or her Form 1040, or
2. Form 885-T,Adjustment of Social Security Tax on Tip Income Not Reported to Employer, prepared at the conclusion of an
employee tip examination.
C. Compliance review. The IRS may evaluate the Employer for compliance with the provisions of this TRAC agreement.
D. Assistance. Upon request, the IRS will assist any Employer or Establishment in establishing, maintaining, or improving its ed-
ucational program or tip reporting procedures.
IV. TERMINATION OF AGREEMENT
A. Termination by Employer. If the Employer no longer wishes this TRAC agreement to apply to one or more Establishments,
the Employer may terminate this TRAC agreement with respect to the Establishment(s) by providing written notification to the Ser-
vice Representative identifying the Establishments(s). If the termination applies to all the Establishments of the Employer, the
TRAC agreement will be terminated.
B. Termination by Internal Revenue Service. The IRS may terminate this TRAC agreement only if–
1. The Service Representative determines that the Employer (or any Establishment) has failed to substantially comply with sec-
tion II.A (pertaining to Education for Employees) or II.B (pertaining to Employee tip reporting procedures);
2. The Employer (or any Establishment) fails to meet any of the requirements of section II.C (pertaining to filing returns and

paying and depositing taxes, maintaining records, and making records available); or
3. The IRS pursues an administrative or judicial action relating to the Employer, Establishment, or any other related party to
this TRAC agreement.
C. Effective date of termination. Except for a termination described in section IV.B.1, any termination will be effective the first
day of the first calendar quarter after the terminating party notifies the other party in writing. In the case of a termination under sec-
tion IV.B.1, the Service Representative may elect an earlier termination date, but no earlier than the first day of the first calendar
quarter of the substantial noncompliance.
D. Renewal after termination. The Employer and the Service Representative may at any time enter into a new TRAC agreement.
V. EFFECTIVE DATE OF AGREEMENT
A. General rule. This TRAC agreement is effective on the first day of the first calendar quarter following the date the Service
Representative signs the TRAC agreement.
B. Additional establishment. This TRAC agreement is effective with respect to an additional establishment on the first day of the
quarter in which notification of the additional establishment is made.
VI. MISCELLANEOUS
A. Examinations and/or inspections of books and records. For purposes of this TRAC agreement–
1. Compliance review. A compliance review is not an examination or an inspection of the taxpayer’s books of account or
records for purposes of section 7605(b) of the Code, and is not a prior audit for purposes of section 530 of the Revenue Act of 1978.
2. Examination. The inspection of books of account or records pursuant to a tip examination is not an inspection of books or
records for purposes of section 7605(b) of the Code, and is not a prior audit for purposes of section 530 of the Revenue Act of 1978.
B. Notices. The parties will send all correspondence pertaining to this TRAC agreement, including a notice of termination, to the
addresses stated below, unless notified in writing of a change of address. In the event of a change of address, the parties must send
all correspondence to the new address. All notices are deemed to be sent or submitted on the date of the postmark stamped on the en-
velope or, in the case of a notice sent by certified mail, the sender’s receipt.
C. Authority. The Employer represents that it has the authority to enter into this TRAC agreement on behalf of itself and the Es-
tablishment(s) listed in Attachment A.
D. General termination and sunset provision. The Commissioner of Internal Revenue may terminate all TRAC agreements at
any time following a significant statutory change in the FICA taxation of tips. After May 31, 2005, the Commissioner may terminate
prospectively the Tip Rate Determination/Education Program and all TRAC agreements.
VII. PAPERWORK REDUCTION ACT
The collections of information contained in this document have been reviewed and approved by the Office of Management and
Budget in accordance with the Paperwork Reduction Act (44 U.S.C. 3507) under control number 1545-1549.
An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection
of information displays a valid control number. The collections of information in this document are in sections I.C, II.A, II.B, II.C.2
and 3, and IV.A. This information is required to comply with sections 6053(a) and 6001 of the Internal Revenue Code and to assist
the Internal Revenue Service in its compliance efforts. This information will be used to monitor the Employer’s performance under
the TRAC agreement. The collections of information are required to obtain the benefits available under the TRAC agreement. The
likely respondents are business or other for-profit institutions.
The estimated total annual reporting and/or recordkeeping burden is 42,296 hours.
The estimated annual burden per respondent/recordkeeper varies from 7 hours to 30 hours, depending on individual circum-
stances, with an estimated average of 14 hours. The estimated number of respondents and/or recordkeepers is 6,600.
The estimated annual frequency of responses (used for reporting requirements only) is on occasion.
Books or records relating to a collection of information must be retained as long as their contents may become material in the ad-
ministration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by section
6103 of the Code.
VIII. SIGNATURES
By signing this TRAC agreement, the parties certify that they have read and agreed to the terms of this document, including At-
tachment A, Establishments.
EMPLOYER:INTERNAL REVENUE SERVICE:
(Name of Employer)
(Signature)(Signature)
May 8, 20009902000–19 I.R.B.

BY:BY:
(Service Representative’s Name)
TITLE:TITLE:
ADDRESS:ADDRESS:
(Headquarters street address)(Street address)
(City, state, ZIP code)(City, state, ZIP code)
DATE:DATE:
ATTACHMENT A
ESTABLISHMENTS
[format for individual establishments]
Employer
A & B Company
xx-xxxxxxx
Street address
City, state, zip code
[format for chains]
Employer(parent, if applicable)
XYZ Corp.
yy-yyyyyyy
Street address
City, state, zip code
Establishments (if applicable)
AB Restaurant
Street address
City, state, zip code
CD Restaurant
Street address
City, state, zip code
Related entity (if applicable)
UVW Corp.
zz-zzzzzzz
Street address
City, state, zip code
Establishments(if applicable)
EF Restaurant
Street address
City, state, zip code
GH Restaurant
Street address
City, state, zip code
2000–19 I.R.B.991May 8, 2000

Proposed Revised Tip Rate
Determination Agreement
(TRDA) for Use by Employers in
the Food and Beverage Industry
Announcement 2000-23
The Internal Revenue Service is ex-
panding its Tip Rate Determination/Edu-
cation Program (TRD/EP), which is de-
signed to enhance tax compliance among
tipped employees through taxpayer edu-
cation and voluntary advance agreements
instead of traditional audit techniques.
This announcement solicits comments on
a draft agreement entitled Tip Rate Deter-
mination Agreement (For Use in the Food
and Beverage Industry).
OVERVIEW
The Service developed its TRD/EP in
1993 as a means of enhancing tax compli-
ance while reducing taxpayer burden. In
essence, the TRD/EP envisions that the
Service and taxpayers in industries in
which tipping is common would work to-
gether to improve tax compliance. The
TRD/EP currently offers employers the
opportunity of entering into one of two
types of agreements. The Tip Rate Deter-
mination Agreement (TRDA) requires the
determination of tip rates; the Tip Report-
ing Alternative Commitment (TRAC)
agreement emphasizes education and tip
reporting procedures. The agreements
also set forth an understanding that em-
ployers that comply with the terms of the
agreement will not be subject to challenge
by the Service. The TRDAs set forth sim-
ilar understandings with respect to em-
ployees who participate in the agree-
ments. Although not set forth in the
TRAC agreements, employees who prop-
erly report tips also will not be subject to
challenge by the Service. The decision to
enter into either a TRDA or a TRAC
agreement is entirely voluntary on the
part of the employer.
In 1993, the Service developed the
TRDA for use in the food and beverage
industry. In 1995, the Service developed
the TRAC agreement for use in the food
and beverage industry. Small employers
often find that the TRDA better meets
their needs and have requested that the
TRDA be simplified.
To ensure consistency in the agree-
ments offered to taxpayers and to provide
an opportunity for public comment before
making the agreement available for use, a
revised TRDA for use in the food and
beverage industry is attached to this an-
nouncement. The Service has simplified
the TRDA.
COMMENTS
Written comments must be received by
July 7, 2000. Send submissions to Office
of Specialty Taxes, c/o CC:DOM:CORP:R
(Announcement 2000-23), room 5226, In-
ternal Revenue Service, POB 7604, Ben
Franklin Station, Washington, DC 20044.
Submissions may be hand delivered Mon-
day through Friday between the hours of 8
a.m. and 5 p.m. to: Specialty Taxes, c/o
CC:DOM:CORP:R (Ann. 2000-23),
Courier’s desk, Internal Revenue Service,
1111 Constitution Avenue, NW, Washing-
ton, DC. Alternatively, taxpayers may sub-
mit comments electronically via the Inter-
net by selecting the “Tax Regs” option on
the IRS Home Page, or by submitting com-
ments directly to the IRS Internet site at
http://www
.irs.ustreas.gov/tax_regs/regslist
.html.
OTHER TRDA AND TRAC
AGREEMENTS
The Service is simultaneously propos-
ing by announcement in this Internal Rev-
enue Bulletin four other agreements: (1) a
revised TRAC agreement for use in the
food and beverage industry (Announce-
ment 2000-22), (2) a revised TRAC
agreement for use in the cosmetology and
barber industry (Announcement 2000-
21), (3) a new TRAC agreement for use in
industries, other than the food and bever-
age industry and the cosmetology and
barber industry, in which tipped employ-
ees receive both cash and charged tips
(Announcement 2000-19), and (4) a new
TRDA for use in any industry other than
the food and beverage industry and the
gaming industry (Announcement 2000-
20).
DRAFTING INFORMATION
The principal author of this announce-
ment is Karin Loverud of the Office of the
Associate Chief Counsel (Employee Ben-
efits and Exempt Organizations). For fur-
ther information regarding this announce-
ment, contact Ida Volz of the Office of
Specialty Taxes, on (202) 622-4177 (not a
toll-free call).
May 8, 20009922000–19 I.R.B.
Release date: April 24, 2000
TIP RATE DETERMINATION AGREEMENT
(For use by employers in the food and beverage industry)
between
Department of the Treasury–Internal Revenue Service
and
[Name of Employer]
This Tip Rate Determination Agreement (TRDA) is part of the Tip Rate Determination/Education Program implemented by the In-
ternal Revenue Service in 1993 to promote tip reporting compliance by employees in accordance with the Internal Revenue Code of
1986.
Section 6053(a) of the Code requires employees to furnish one or more written statements to their employers reporting all tips re-
ceived in each calendar month. The statements must be furnished to the employer by the 10th day of the following month.
I. DEFINITIONS AND ATTACHMENTS
A. Definitions.

2000–19 I.R.B.993May 8, 2000
1. Service Representativemeans the Internal Revenue Service employee or delegate authorized to execute or terminate this
TRDA on behalf of the Internal Revenue Service.
2. Employermeans [insert name, address, and EIN].
3. Establishmentmeans each of the establishments or divisions listed by name, address, and EIN in Attachment A [sample at-
tached].
a. One place of business. If the Employer has one place of business, that place of business is an Establishment, and no at-
tachment is necessary.
b. Additional establishment. If the Employer subsequently wishes to include an additional establishment in this TRDA, the
Employer must notify the Service Representative in writing. The notification must include the name, address, and identifying num-
ber of the additional establishment.
4. Employeemeans a person whose Occupational Category is listed in Attachment B [sample attached], and who is employed
by an Establishment, and who directly or indirectly receives tips of at least $20.00 per month during the course of the employee’s
employment.
5. Occupational Categorydescribes a group of employees performing a particular type of service to which a stated tip rate is
assigned. Employees performing the same service at different locations or during different shifts may be assigned different Occupa-
tional Categories.
6. Participating Employeemeans an Employee who gives to the Employer a signed Tipped Employee Participation Agreement
(TEPA), which includes the language set forth in Attachment C, indicating participation in the tip reporting program.
7. Tip Ratemeans the applicable rate described in Section III.
B. Attachments
1. Attachment A, Establishments, lists the Employer’s establishments participating in this TRDA.
2. Attachment B, Occupational Categories and Initial Tip Rates, lists the Employee occupational categories and tip rates subject
to this TRDA.
3. Attachment C, Tipped Employee Participation Agreement, is the document signed by an Employee agreeing to report tips at
or above the rate established for the Employee’s Occupational Category.
4. Attachment D, Formula for Tip Rate Calculation, is the calculation described in section III.A.1 for determining tip rates.
II. COMMITMENT OF EMPLOYER
A. Maintaining records. While this TRDA is in effect, and in addition to records otherwise required to be maintained, the Em-
ployer will maintain the following records:
1. Employee records. For each Employee, the Employee’s name, address, social security number, reported tips, and shift(s)
and hours.
2. Tip rates records. All records of data used to determine the tip rates.
The Employer will retain the records listed in this section II.A. for at least 4 years after the April 15 following the calendar year to
which the records relate.
B. Furnishing information. The Employer will furnish to the Service Representative the following documents:
1. Quarterly report of employees. A quarterly report showing, as of the last day of each quarter, (1) the total number of Em-
ployees, and (2) the total number of Participating Employees. The report is due on the last day of the month following each calendar
quarter.
2. Annual report of nonparticipating Employees.
a. General rule. For each Employee who is a nonparticipating Employee on the last day of the calendar year, an annual re-
port showing the Employee’s name, address, social security number, shift(s), and hours. The report may list all Employees, indicat-
ing those Employees who are nonparticipating Employees, as long as the required information is included for all nonparticipating
Employees. The report is due on March 31 following each calendar year.
b. Exception. No report is required for an Occupational Category for any calendar year for which all the Employees in the
Occupational Category reported tips at a rate equal to or greater than the rates established under section III of this TRDA.
C. Making records available. At the request of the Service Representative, the Employer will furnish any of the records identified
in section II.A.
D. Filing returns and paying and depositing taxes.
1. In general. The Employer or employing Establishment will comply with the requirements for filing all required federal tax
returns and paying and depositing all federal taxes.
2. Form 8027. For each Establishment that is a “large food or beverage establishment,” the Employer will comply with the re-
quirements for filing Form 8027, Employer’s Annual Information Return of Tip Income and Allocated Tips, and send an additional
copy of each Form 8027 to the IRS.
III. TIP RATES
A. Tip rates.
1. Determining tip rates. The Employer will determine tip rates based on the formula set forth in Attachment D, Formula for

Tip Rate Calculation. If information necessary for the formula is unavailable or insufficient, the Employer will determine tip rates
based on information available to the Employer, historical information provided by the Service Representative, and generally ac-
cepted accounting principles. The rates will generally be based on a dollar amount per hour, but a different measure may be used.
2. Initial tip rates.The initial tip rates are identified in Attachment B, Occupational Categories and Initial Tip Rates. They will
remain in effect through December 31 of the calendar year following the year in which this TRDA takes effect.
B. Determining subsequent tip rates and Occupational Categories.
1. Annual review. The Employer will review annually, on a calendar year basis, its Occupational Categories and the tip rates
assigned to its Occupational Categories.
2. Procedures.
a. Employer submission. If the Employer believes that a change in Occupational Categories or a revision of one or more
rates is appropriate, the Employer will submit proposed revisions to the Service Representative by September 30. If the Employer
fails to submit a proposed rate revision by September 30, the Employer will be treated as having submitted the rate in effect for the
current year.
b. Internal Revenue Service review. The Service Representative will review the proposed rates and notify the Employer in
writing of the IRS’s approval or disapproval by November 30. If the IRS does not approve one or more proposed rates, the existing
rate or rates will be continued until no later than the last day of the following February. If the Employer and the Service Representa-
tive are unable to agree upon a rate or rates by the last day of the following February, this TRDA will terminate pursuant to section
V.C.
3. Effective date of revised tip rates and Occupational Categories.Approved revised rates for a calendar year will become ef-
fective on the later of (1) January 1 of the calendar year, or (2) the first day of the month following the date the Employer and the
Service Representative agree upon a revised rate.
IV. COMMITMENT OF INTERNAL REVENUE SERVICE
A. Participating Employee. The IRS will not examine a Participating Employee’s tip income for any period for which a TEPA is
in effect, if the Employee reports tips to the Employer at or above the tip rate established for the Employee.
B. Employer.
1. Tip examinations. The IRS will not initiate any tip examinations of the Employer (or Establishment) for any period for
which this TRDA is in effect.
2. Section 3121(q) notice and demand. Any section 3121(q) notice and demand issued to the Employer (or Establishment) re-
lating to any period during which this TRDA is in effect will be based solely on amounts reflected on–
a. Form 4137, Social Security and Medicare Tax on Unreported Tip Income, filed by an Employee with his or her Form
1040, or
b. Form 885-T,Adjustment of Social Security Tax on Tip Income Not Reported to Employer, prepared at the conclusion of an
employee tip examination.
C. Compliance review. The IRS may evaluate the Employer and its Participating Employees for compliance with the provisions
of this TRDA.
V. TERMINATION OF AGREEMENT
A. Termination by Employer. If the Employer no longer wishes this TRDA to apply to one or more Establishments, the Employer
may terminate this TRDA with respect to the Establishment(s), by providing written notification to the Service Representative iden-
tifying the Establishments(s). If the termination applies to all the Establishments of the Employer, the TRDA will be terminated.
B. Termination by Internal Revenue Service. The IRS may terminate this TRDA only if–
1. As of any December 31, less than 75 percent of the Employees are Participating Employees,
2. The Employer fails to meet any of the requirements of section II, Commitment of Employer, or
3. The IRS pursues an administrative or judicial action relating to the Employer, Establishment, or any other related party to
this TRDA.
C. Termination upon failure of parties to agree to revision of tip rates.This TRDA will terminate if the Employer and the Service
Representative fail to agree to a revision of the tip rates under the procedures set forth in section III.B.2.
D. Notice of termination and effective date. Any termination will be effective the first day of the first calendar quarter after the
terminating party notifies the other party in writing.
E. Renewal after termination. The Employer and the Service Representative may at any time enter into a new TRDA.
VI. EFFECTIVE DATE OF AGREEMENT
A. General rule. This TRDA is effective on the first day of the first calendar quarter following the date the Service Representa-
tive signs the TRDA.
B. Additional establishment. This TRDA is effective with respect to an additional establishment on the first day of the quarter in
which notification is made.
May 8, 20009942000–19 I.R.B.

2000–19 I.R.B.995May 8, 2000
VII. MISCELLANEOUS
A. Examinations and/or inspections of books and records. For purposes of this TRDA–
1. Compliance review. A compliance review is not an examination or an inspection of the taxpayer’s books of account or
records for purposes of section 7605(b) of the Code, and is not a prior audit for purposes of section 530 of the Revenue Act of 1978.
2. Examination. The inspection of books of account or records pursuant to a tip examination is not an inspection of books or
records for purposes of section 7605(b) of the Code, and is not a prior audit for purposes of section 530 of the Revenue Act of 1978.
B. Notices. The parties will send all correspondence pertaining to this TRDA to the addresses stated below, unless notified in
writing of a change of address. In the event of a change of address, the parties must send all correspondence to the new address. All
notices are deemed to be sent or submitted on the date of the postmark stamped on the envelope or, in the case of a notice sent by
certified mail, the sender’s receipt.
C. Authority. The Employer represents that it has the authority to enter into this TRDA.
D. General termination and sunset provision. The Commissioner of Internal Revenue may terminate all TRDAs at any time fol-
lowing a significant statutory change in the FICA taxation of tips. After May 31, 2005, the Commissioner may terminate prospec-
tively the Tip Rate Determination/Education Program and all TRDAs.
VIII. PAPERWORK REDUCTION ACT
The collections of information contained in this document will be submitted to the Office of Management and Budget for review
in accordance with the Paperwork Reduction Act (44 U.S.C. 3507).
An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection
of information displays a valid control number.
The collections of information in this document are in sections I.A.3, 4, and 5, II.A, II.B, II.C., III, and V.A. This information is
required to comply with sections 6053(a) and 6001 of the Internal Revenue Code and to assist the Internal Revenue Service in its
compliance efforts. This information will be used to monitor the Employer’s performance under the TRDA. The collections of in-
formation are required to obtain the benefits available under the TRDA. The likely respondents are business or other for-profit insti-
tutions.
The estimated total annual reporting and/or recordkeeping burden is 1,737 hours.
The estimated annual burden per respondent/recordkeeper varies from 6 hours to 20 hours, depending on individual circum-
stances, with an estimated average of 11 hours. The estimated number of respondents and/or recordkeepers is 200.
The estimated annual frequency of responses (used for reporting requirements only) is on occasion.
Books or records relating to a collection of information must be retained as long as their contents may become material in the ad-
ministration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by section
6103 of the Code.
IX. SIGNATURES
By signing this TRDA, the parties certify that they have read and agreed to the terms of this document, including Attachments A,
B, and C.
EMPLOYER:INTERNAL REVENUE SERVICE:
(Name of Employer)
(Signature)(Signature)
BY:BY:
(Service Representative’s Name)
TITLE:TITLE:
ADDRESS:ADDRESS:
(Headquarters street address)(Street address)
(City, state, ZIP code)(City, state, ZIP code)
DATE:DATE:

May 8, 20009962000–19 I.R.B.
ATTACHMENT A
ESTABLISHMENTS
[format for individual establishments]
Employer
A & B Company
xx-xxxxxxx
Street address
City, state, zip code
[format for chains]
Employer(parent, if applicable)
XYZ Corp.
yy-yyyyyyy
Street address
City, state, zip code
Establishments(if applicable)
AB Restaurant
Street address
City, state, zip code
CD Restaurant
Street address
City, state, zip code
Related entity(if applicable)
UVW Corp.
zz-zzzzzzz
Street address
City, state, zip code
Establishments(if applicable)
EF Restaurant
Street address
City, state, zip code
ATTACHMENT B
OCCUPATIONAL CATEGORIES AND INITIAL TIP RATES
[sample format]
Occupational CategoriesInitial Tip Rates
Category Aactual tips
Category B — 1st shift
% of sales
Category B — 2nd shift% of sales
Category B — 3rd shift% of sales
Category C — location 1$ /
Category C — location 2$ /
ATTACHMENT C
TIPPED EMPLOYEE PARTICIPATION AGREEMENT
I am an employee of
and wish to participate in my employer’s tip
reporting program.
In accordance with a Tip Rate Determination Agreement between my employer and the Internal Revenue Service, I agree to report
my tips to my employer, as required by law, at or above the tip rate established by my employer and approved by the IRS for my Oc-
cupational Category.
I also acknowledge that, to continue participation in my employer’s tip reporting program, I must file all federal tax returns required
by law and pay all federal taxes for which I am liable.

EMPLOYEE
Name (printed):
Signature:
Home address:
Social Security Number:
DATE:
Attachments:
Copy of TRDA and Attachment B (Occupational Categories and Tip Rates)
Copy of TRDA Information for Employees
2000–19 I.R.B.997May 8, 2000
ATTACHMENT D
FORMULA FOR TIP RATE CALCULATION
Directly tipped employees
Step 1: Determine charged and cash tip rates.
Charged tip rate = Total charged tips
Total charged sales with charged tips*
Cash tip rate = Charged tip rate
less: difference between charged and cash tips
Step 2:Calculate tip rate per hour (or per sales)
1. Gross sales subject to tipping
2. minus:stiff factor
charged sales with charged tips
other factors
3. equals:sales subject to cash tipping
4. timescash tip rate
5. equals:cash tips received
6. plus:charged tips
tips received from other employees
7. equals:total tips received
8. minus:tip outs
9. equals:adjusted tips
10. divided by:total hours worked (or total sales)
11. equals:tip rate per hour (or per sales)
Indirectly tipped employees
Calculate tip rate per hour:
Tip rate per hour = Tips received from other workers
Total hours worked
* If this figure is unavailable, use “total charged sales” for the denominator to figure the charged tip rate.
Notice of Call for Redemption: 8
1/4 Percent Treasury Bonds of
2000–5
Announcement 2000–46
AGENCY: DEPARTMENT OF THE
TREASURY, Office of the Secretary.
January 14, 2000, Washington, D.C.
1. Public notice is hereby given that all
outstanding 8 1/4 percent Treasury Bonds
of 2000–5 (CUSIP no. 912810 BU 1)
dated May 15, 1975, due May 15, 2005,
are hereby called for redemption at par on
May 15, 2000, on which date interest on
such bonds will cease.
2. Full information regarding the pre-
sentation and surrender of such bonds
held in coupon and registered form for re-
demption under this call will be found in
Department of the Treasury Circular No.
3000 dated March 4, 1973, as amended
(31 CFR part 306), and on the Bureau of
the Public Debt’s website, www.pub-
licdebt.treas.gov.
3. Redemption payments for such
bonds held in book-entry form, whether
on the books of the Federal Reserve
Banks or in Treasury-Direct accounts,
will be made automatically on May 15,
2000.

Donald V. Hammond,
Fiscal Assistant Secretary.
(Filed by the Office of the Federal Register on January
14, 2000, 11:00 a.m., and published in the issue of the
Federal Register for January 19, 2000, 65 F.R. 3006)
Delay in Finalizing Proposed
Regulations Regarding Last
Known Address
Announcement 2000-49
This announcement informs the public
of a delay in finalizing proposed regula-
tions (REG–104939–99, 1999–49 I.R.B.
643) under § 6212(b) of the Internal Rev-
enue Code regarding a taxpayer’s last
known address published in the Federal
Register (64 FR 63768) on November 22,
1999. When finalized, the regulations
will modify the definition of “last known
address” to include an address obtained
from the United States Postal Service Na-
tional Change of Address database
(NCOA database). The regulations were
proposed to be effective May 1, 2000.
However, all steps necessary to imple-
ment the regulations will not be com-
pleted by May 1, 2000. Therefore, the In-
ternal Revenue Service will not begin
using the NCOA database to update a tax-
payer’s last known address on May 1,
2000. Final regulations will not be effec-
tive until all the necessary steps are taken
to implement the regulations.
Correction to Rev. Proc. 2000-12
Announcement 2000-50
As published, Rev. Proc. 2000-12
(2000-4 I.R.B. 387) omitted the section
pertaining to the Paperwork Reduction
Act. The following section should be
added to the procedure:
Section 8. Paperwork Reduction Act
The collections of information con-
tained in this revenue procedure have
been reviewed and approved by the Of-
fice of Management and Budget in accor-
dance with the Paperwork Reduction Act
(44 U.S.C. 3507) under control number
1545-1597.
An agency may not conduct or sponser,
and a person is not required to respond to,
a collection of information unless the col-
lection of information displays a valid
OMB control number.
The collections of information are con-
tained in sections 3 an 4 of this revenue
procedure regarding (1) the application
procedures for QI status and withholding
agreements, and (2) the provisions of the
QI withholding agreement requiring
record retention or maintenance, and any
communication or contact with the IRS or
the account holders. This information
will be used to enable the IRS to deter-
mine whether to enter into a withholding
agreement with the QI applicant and, if
accepted, to verify the QI’s compliance
with the agreement. The collection of in-
formation is required to obtain a QI with-
holding agreement. The likely respon-
dents are business or other for-profit
institutions.
The estimated total annual reporting
and/or recordkeeping burden is 301, 393
hours.
The estimated average annual burden is
30 minutes for a QI account holder, and
2.093 hours for a QI, depending on the in-
dividual circumstances. The estimated
number of recordkeepers is 88,504.
The estimated frequency of responses
is on occasion. Books or records relating
to a collection of information must be re-
tained as ling as their contents may be-
come material in the administration of
any internal revenue law. Generally, tax
returns and tax return information are
confidential, as required by 26 U.S.C.
6103.
May 8, 20009982000–19 I.R.B.
Announcement of the Disbarment and Suspension of Attorneys,
Certified Public Accountants, Enrolled Agents, and Enrolled Actuaries
From Practice Before the Internal Revenue Service
Under Section 330, Title 31 of the
United States Code, the Secretary of the
Treasury, after due notice and opportunity
for hearing, is authorized to suspend or
disbar from practice before the Internal
Revenue Service any person who has vio-
lated the rules and regulations governing
the recognition of attorneys, certified
public accountants, enrolled agents or en-
rolled actuaries to practice before the In-
ternal Revenue Service.
Attorneys, certified public accountants,
enrolled agents, and enrolled actuaries are
prohibited in any Internal Revenue Service
matter from directly or indirectly employing,
accepting assistance from, being employed
by or sharing fees with, any practitioner dis-
barred or under suspension from practice be-
fore the Internal Revenue Service.
To enable attorneys, certified public ac-
countants, enrolled agents and enrolled
actuaries to identify such disbarred or sus-
pended practitioners, the Director of Prac-
tice will announce in the Internal Revenue
Bulletin the names and addresses of prac-
titioners who have been suspended from
such practice, their designation as attor-
ney, certified public accountant, enrolled
agent or enrolled actuary, and the date of
disbarment or period of suspension. This
announcement will appear in the weekly
Bulletin for five successive weeks or as
long as it is practicable for each attorney,
certified public accountant, enrolled agent
or enrolled actuary so suspended or dis-
barred and will be consolidated and pub-
lished in the Cumulative Bulletin.
After due notice and opportunity for
hearing before an administrative law
judge, the following individuals has been
disbarred from ffifther practice before the
Internal Revenue Service:
NameAddressDesignationEffective Date
Kolesar, GaryN. Patchogue, NYCPAOctober 27, 1999

Under 31 Code of Federal Regulations,
Part 10, an attorney, certified public ac-
countant, enrolled agent or enrolled actu-
ary, 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 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 con-
sent 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, enrolled
agent or enrolled actuary, and date or pe-
riod of suspension. 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 attorney,
certified public accountant, enrolled agent
or enrolled actuary so suspended and will
be consolidated and published in the Cu-
mulative Bulletin.
The following individuals have been
placed under consent suspension from prac-
tice before the Internal Revenue Service:
2000–19 I.R.B.999May 8, 2000
Announcement of the Consent Voluntary Suspension of Attorneys,
Certified Public Accountants, Enrolled Agents, and Enrolled Actuaries
From Practice Before the Internal Revenue Service
Date of
NameAddressDesignationSuspension
Quann, WarrenElk Grove, CAAttorneyIndefinite
from
March 1, 1999
Helms, W. RichardWestern Springs, ILAttorneyMarch 1, 1999
to
August 31, 2002
Dillahunty, Larry L.St. Petersburg, FLAttorneyMarch 1, 1999
to
February 28, 2003
Friesen, AlanLincoln, NECPAMarch 8, 1999
to
July 7, 2002
Cummins, Richard L.Torrance, CACPAMarch 20, 1999
to
March 19, 2002
Potter, Thomas C.Oneonta, NYCPAApril 16, 1999
to
October 15, 2000
Jenkins, GordonIdaho Falls, IDAttorneyMay 1, 1999
to
October 31, 2002
Blair Jr., John D.Charleston, WVCPAJune 1, 1999
to
May 31, 2002
Caudle, LarryAnchorage, AKAttorneyJune 21, 1999
to
December 31, 2001
Schorr, HarveyVoorheese, NJCPAJuly 1, 1999
to
December 31, 2001

May 8, 200010002000–19 I.R.B.
Fernandez, Michael J. Camillus, NYCPAJuly 7, 1999
to
July 6, 2000
Polking, William G.Carol, IAAttorneySeptember 27, 1999
to
September 26, 2000
Luxen, Robert J.Oak Lawn, ILCPAOctober 1, 1999
to
June 30, 2001
Underwood, KennethChattanooga, TNCPAOctober 14, 1999
to
April 13, 2001
Vancho, JohnGreenwich, CTCPANovember 1, 1999
to
October 31, 2001
Enkulenko, ThomasMoscow, PACPANovember 15, 1999
to
November 14, 2000
Moody, James E.Pittsburgh, PACPADecember 1, 1999
to
November 30, 2000
Patterson, Robert A. Marietta, GACPADecember 13, 1999
to
December 12, 2002
Hanson, Raymond L. Boise, IDCPAJanuary 1, 2000
to
December 31,2001
Wallach, StevenNorth Brook, ILCPAFebruary 25, 2000
to
February 24, 2002
Watkins Sr., RichardWashington, MOCPAMarch 15, 2000
to
September 14, 2002
Peltin, RonaldEscanaba, MIEnrolledMarch 15, 2000
Agentto
March 14, 2003
Arwood B. JoeChuckey, TNCPAMarch 20, 2000
to
June 19, 2001
Gazzola, Frank L.N. Mankato, MNCPAMay 1, 2000
to
October 31, 2002
O’Hearn, JamesBakersfield, CAEnrolledJune 1, 2000
Agentto
May 31, 2002
Dooner Jr., WilliamToms River, NJEnrolledJune 1, 2000
Agentto
August 31, 2000

Announcement of the Expedited Suspension of Attorneys, Certified
Public Accountants, Enrolled Agents, and Enrolled Actuaries From
Practice Before the Internal Revenue Service
2000–19 I.R.B.1001May 8, 2000
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 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 pubic ac-
countants, enrolled agents, and enrolled
actuaries to identify practitioners under
expedited suspension from practice be-
fore the Internal Revenue Service, the Di-
rector of Practice will announce in the In-
ternal Revenue Bulletin the names and
addresses 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 suspension from practice be-
fore the Internal Revenue Service by
virtue of the expedited proceeding provi-
sions of the applicable regulations:
Date of
NameAddressDesignationSuspension
Moeller, David G.Golden Valley, MNAttorneyIndefinite
from
March 8, 1999
Dais, Robert E.Plano, TXCPAIndefinite
from
March 15, 1999
Taylor, Donald J.Sequim, WACPAIndefinite
from
March 15, 1999
Thurson, Terrance N.Jacksonville, FLCPAIndefinite
from
March 15, 1999
Hartman, RichardMerrick, NYAttorneyIndefinite
from
March 15, 1999
Mandel, Stewart I.Univ. Heigths, OHAttorneyIndefinite
from
March 15, 1999
Gowin, Dennis L.Falls Church, VACPAIndefinite
from
March 15, 1999
Kelly, RichardLloyd Harbor, NYAttorneyIndefinite
from
March 16, 1999
Nagel, Maxine M.Renton, WACPAIndefinite
from
March 16, 1999
Cox, James L.Bedford, TXCPAIndefinite
from
March 23, 1999

Shields, Morris R.Omaha, NECPAIndefinite
from
March 23, 1999
Stradone, Mark A.San Antonio, TXCPAIndefinite
from
March 24, 1999
Anderson, David J.Minnetonka, MNCPAIndefinite
from
March 28, 1999
Budenz, Lawrence J.Miamisburg, OHCPAIndefinite
from
March 28, 1999
Hogan, Kelly M.Ogallala, NEAttorneyIndefinite
from
March 28, 1999
Fernez, Daniel J.Monroe, CTCPAIndefinite
from
March 28, 1999
Fitsos, JohnSacramento, CAAttorneyIndefinite
from
March 28, 1999
Schweitzer, Clifford A.Aberdeen, SDCPAIndefinite
from
April 2, 1999
Magdalena, Lynn JosephMcAlester, OKCPAIndefinite
from
April 2, 1999
Parrott, GeorgeNashville, TNCPAIndefinite
from
April 2, 1999
Elder Jr., Wilton K.Burlington, NCAttorneyIndefinite
from
May 6,1999
Passero, RobertSeal Beach, CACPAIndefinite
from
July 8, 1999
Stringham, RichardColumbia, MOCPAIndefinite
from
July 8, 1999
Koseluk, Alexander F.Omaha, NEAttorneyIndefinite
from
July 19, 1999
Dotson, Marshall F.Jacksonville, NCAttorneyIndefinite
from
July 27, 1999
Schaffer, Clark D.Atlantic Beach, FLCPAIndefinite
from
July 27, 1999
Zimmerman, RobertAlpharetta, GACPAIndefinite
from
January 17, 2000
May 8, 200010022000–19 I.R.B.

2000–19 I.R.B.iMay 8, 2000
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

May 8, 2000ii2000–19 I.R.B.
Numerical Finding List
1
Bulletins 2000–1 through 2000–18
Announcements:
2000–1, 2000–2 I.R.B. 294
2000–2, 2000–2 I.R.B. 295
2000–3, 2000–2 I.R.B. 296
2000–4, 2000–3 I.R.B. 317
2000–5, 2000–4 I.R.B. 427
2000–6, 2000–4 I.R.B. 428
2000–7, 2000–6 I.R.B. 586
2000–8, 2000–6 I.R.B. 586
2000–9, 2000–9 I.R.B. 733
2000–10, 2000–9 I.R.B. 733
2000–11, 2000–10 I.R.B. 739
2000–12, 2000–12 I.R.B. 835
2000–13, 2000–11 I.R.B. 771
2000–14, 2000–11 I.R.B. 772
2000–15, 2000–12 I.R.B. 837
2000–16, 2000–12 I.R.B. 837
2000–17, 2000–13 I.R.B. 846
2000–18, 2000–13 I.R.B. 846
2000–24, 2000–14 I.R.B. 855
2000–25, 2000–14 I.R.B. 855
2000–26, 2000–15 I.R.B. 876
2000–27, 2000–15 I.R.B. 876
2000–28, 2000–15 I.R.B. 876
2000–29, 2000–15 I.R.B. 877
2000–30, 2000–15 I.R.B. 877
2000–31, 2000–15 I.R.B. 877
2000–32, 2000–15 I.R.B. 879
2000–33, 2000–15 I.R.B. 878
2000–34, 2000–15 I.R.B. 879
2000–35, 2000–16 I.R.B. 922
2000–36, 2000–16 I.R.B. 947
2000–37, 2000–16 I.R.B. 947
2000–38, 2000–16 I.R.B. 948
2000–39, 2000–16 I.R.B. 948
2000–40, 2000–16 I.R.B. 948
2000–41, 2000–16 I.R.B. 949
2000–42, 2000–16 I.R.B. 949
2000–43, 2000–17 I.R.B. 957
2000–44, 2000–17 I.R.B. 958
2000–45, 2000–18 I.R.B. 962
Court Decisions:
2066, 2000–15 I.R.B. 867
2067, 2000–15 I.R.B. 863
Notices:
2000–1, 2000–2 I.R.B. 288
2000–2, 2000–9 I.R.B. 727
2000–3, 2000–4 I.R.B. 413
2000–4, 2000–3 I.R.B. 313
2000–5, 2000–3 I.R.B. 314
2000–6, 2000–3 I.R.B. 315
2000–7, 2000–4 I.R.B. 419
2000–8, 2000–4 I.R.B. 420
2000–9, 2000–5 I.R.B. 449
2000–10, 2000–5 I.R.B. 451
2000–11, 2000–6 I.R.B. 572
2000–12, 2000–9 I.R.B. 727
2000–13, 2000–9 I.R.B. 732
2000–14, 2000–10 I.R.B. 737
2000–15, 2000–12 I.R.B. 826
Notices—continued:
2000–16, 2000–12 I.R.B. 826
2000–17, 2000–12 I.R.B. 827
2000–18, 2000–13 I.R.B. 845
2000–19, 2000–13 I.R.B. 845
2000–20, 2000–14 I.R.B. 851
2000–22, 2000–16 I.R.B. 902
2000–23, 2000–17 I.R.B. 952
2000–24, 2000–17 I.R.B. 952
2000–25, 2000–17 I.R.B. 954
2000–26, 2000–17 I.R.B. 954
Proposed Regulations:
REG–208280–86, 2000–8 I.R.B. 654
REG–209135–88, 2000–8 I.R.B. 681
REG–208254–90, 2000–6 I.R.B. 577
REG–209601–92, 2000–12 I.R.B. 829
REG–100276–97, 2000–8 I.R.B. 682
REG–101492–98, 2000–3 I.R.B. 326
REG–106012–98, 2000–2 I.R.B. 290
REG–109101–98, 2000–16 I.R.B. 903
REG–110311–98, 2000–11 I.R.B. 767
REG–103831–99, 2000–5 I.R.B. 452
REG–103882–99, 2000–8 I.R.B. 706
REG–105089–99, 2000–6 I.R.B. 580
REG–105279–99, 2000–8 I.R.B. 707
REG–105606–99, 2000–4 I.R.B. 421
REG–107872–99, 2000–16 I.R.B. 911
REG–111119–99, 2000–5 I.R.B. 455
REG–113572–99, 2000–7 I.R.B. 624
REG–116048–99, 2000–6 I.R.B. 584
REG–116567–99, 2000–5 I.R.B. 463
REG–116704–99, 2000–3 I.R.B. 325
REG–117162–99, 2000–15 I.R.B. 871
REG–100163–00, 2000–7 I.R.B. 633
REG–100291–00, 2000–16 I.R.B. 917
REG–103735–00, 2000–11 I.R.B. 770
REG–103736–00, 2000–11 I.R.B. 768
Railroad Retirement Quarterly Rate:
2000–9 I.R.B. 721
Revenue Procedures:
2000–1, 2000–1 I.R.B. 4
2000–2, 2000–1 I.R.B. 73
2000–3, 2000–1 I.R.B. 103
2000–4, 2000–1 I.R.B. 115
2000–5, 2000–1 I.R.B. 158
2000–6, 2000–1 I.R.B. 187
2000–7, 2000–1 I.R.B. 227
2000–8, 2000–1 I.R.B. 230
2000–9, 2000–2 I.R.B. 280
2000–10, 2000–2 I.R.B. 287
2000–11, 2000–3 I.R.B. 309
2000–12, 2000–4 I.R.B. 387
2000–13, 2000–6 I.R.B. 515
2000–14, 2000–18 I.R.B. 960
2000–15, 2000–5 I.R.B. 447
2000–16, 2000–6 I.R.B. 518
2000–17, 2000–11 I.R.B. 766
2000–18, 2000–9 I.R.B. 722
2000–19, 2000–12 I.R.B. 785
2000–20, 2000–6 I.R.B. 553
Revenue Rulings:
2000–1, 2000–2 I.R.B. 250
Revenue Rulings—continued:
2000–2, 2000–3 I.R.B. 305
2000–3, 2000–3 I.R.B. 297
2000–4, 2000–4 I.R.B. 331
2000–5, 2000–5 I.R.B. 436
2000–6, 2000–6 I.R.B. 512
2000–7, 2000–9 I.R.B. 712
2000–8, 2000–7 I.R.B. 617
2000–9, 2000–6 I.R.B. 497
2000–10, 2000–8 I.R.B. 643
2000–11, 2000–10 I.R.B. 734
2000–12, 2000–11 I.R.B. 744
2000–13, 2000–12 I.R.B. 774
2000–14, 2000–12 I.R.B. 779
2000–15, 2000–12 I.R.B. 774
2000–16, 2000–12 I.R.B. 780
2000–17, 2000–13 I.R.B. 842
2000–18, 2000–14 I.R.B. 847
2000–19, 2000–14 I.R.B. 849
2000–20, 2000–16 I.R.B. 880
2000–21, 2000–16 I.R.B. 881
2000–22, 2000–16 I.R.B. 880
Treasury Decisions:
8849, 2000–2 I.R.B. 245
8850, 2000–2 I.R.B. 265
8851, 2000–2 I.R.B. 275
8852, 2000–2 I.R.B.253
8853, 2000–4 I.R.B.377
8854, 2000–3 I.R.B.306
8855, 2000–4 I.R.B.374
8856, 2000–3 I.R.B.298
8857, 2000–4 I.R.B.365
8858, 2000–4 I.R.B.332
8859, 2000–5 I.R.B.429
8860, 2000–5 I.R.B.437
8861, 2000–5 I.R.B.441
8862, 2000–6 I.R.B.466
8863, 2000–6 I.R.B.488
8864, 2000–7 I.R.B.614
8865, 2000–7 I.R.B.589
8866, 2000–6 I.R.B.495
8867, 2000–7 I.R.B.620
8868, 2000–6 I.R.B.491
8869, 2000–6 I.R.B.498
8870, 2000–8 I.R.B.647
8871, 2000–8 I.R.B.641
8872, 2000–8 I.R.B.639
8873, 2000–9 I.R.B.713
8874, 2000–8 I.R.B.644
8875, 2000–11 I.R.B.761
8876, 2000–11 I.R.B.753
8877, 2000–11 I.R.B.747
8878, 2000–15 I.R.B.857
8879, 2000–16 I.R.B.882
1
A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 1999–27 through
1999–52 is in Internal Revenue Bulletin 2000–1,
dated January 3, 2000.

2000–19 I.R.B.iiiMay 8, 2000
Finding List of Current Actions on
Previously Published Items
1
Bulletins 2000–1 through 2000–18
Announcements:
99–40
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
99–50
Modified by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
2000–18
Corrected by
Announcement 2000–32, 2000–15 I.R.B. 878
Notices:
88–125
Obsoleted by
T.D. 8870, 2000–8 I.R.B. 647
92–48
Obsoleted by
Notice 2000–11, 2000–6 I.R.B. 572
97–19
Modified by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
98–22
Obsoleted by
T.D. 8870, 2000–8 I.R.B. 647
98–52
Modified by
Notice 2000–3, 2000–4 I.R.B. 413
98–61
Modified and superseded by
Rev. Proc. 2000–15, 2000–5 I.R.B. 447
99–8
Obsoleted by
Rev. Proc. 2000–12, 2000–4 I.R.B. 387
2000–4
Corrected by
Announcement 2000–9, 2000–9 I.R.B. 733
Proposed Regulations:
REG–209601–92
Corrected by
Announcement 2000–40, 2000–16 I.R.B. 948
REG–100276–97
Corrected by
Announcement 2000–38, 2000–16 I.R.B. 948
REG–101492–98
Corrected by
Announcement 2000–16, 2000–12 I.R.B. 837
REG–113572–99
Corrected by
Announcement 2000–41, 2000–16 I.R.B. 949
REG–103736–00
Corrected by
Announcement 2000–44, 2000–17 I.R.B. 958
Revenue Procedures:
80–18
Modified by
Rev. Proc. 2000–13, 2000–6 I.R.B. 515
Revenue Procedures—Continued:
89–9
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
89–13
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
90–21
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
91–66
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
92–13
Modified, amplified, and superseded by
Rev. Proc. 2000–11, 2000–3 I.R.B. 309
92–13A
Modified, amplified, and superseded by
Rev. Proc. 2000–11, 2000–3 I.R.B. 309
92–41
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
93–9
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
93–10
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
94–12
Modified, amplified, and superseded by
Rev. Proc. 2000–11, 2000–3 I.R.B. 309
95–42
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
96–13
Modified by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
98–22
Modified and superseded by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
98–27
Superseded by
Rev. Proc. 2000–12, 2000–4 I.R.B. 387
98–64
Superseded by
Rev. Proc. 2000–9, 2000–2 I.R.B. 280
98–65
Superseded by
Rev. Proc. 2000–19, 2000–12 I.R.B. 785
99–1
Superseded by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
99–2
Superseded by
Rev. Proc. 2000–2, 2000–1 I.R.B. 73
99–3
Superseded by
Rev. Proc. 2000–3, 2000–1 I.R.B. 103
99–4
Superseded by
Rev. Proc. 2000–4, 2000–1 I.R.B. 115
Revenue Procedures—Continued:
99–5
Superseded by
Rev. Proc. 2000–5, 2000–1 I.R.B. 158
99–6
Superseded by
Rev. Proc. 2000–6, 2000–1 I.R.B. 187
99–7
Superseded by
Rev. Proc. 2000–7, 2000–1 I.R.B. 227
99–8
Superseded by
Rev. Proc. 2000–8, 2000–1 I.R.B. 230
99–13
Modified and superseded by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
99–20
Supplemented by
Rev. Proc. 2000–14, 2000–18 I.R.B. 960
99–31
Modified and superseded by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
99–49
Modified and amplified by
Rev. Rul. 2000–4, 2000–4 I.R.B. 331
Rev. Rul. 2000–7, 2000–9 I.R.B. 712
Notice 2000–4, 2000–3 I.R.B. 313
99–51
Superseded by
Rev. Proc. 2000–3, 2000–1 I.R.B. 103
2000–6
Modified by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
2000–8
Modified by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
2000–16
Corrected by
Announcement 2000–17, 2000–13 I.R.B. 846
Revenue Rulings:
57–259
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
57–499
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
73–292
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
78–218
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
86–62
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
88–36
Modified by
Rev. Rul. 2000–6, 2000–6 I.R.B. 512
89–89
Obsoleted by
Rev. Rul. 2000–2, 2000–3 I.R.B. 305
1
A cumulative list of current actions on previously
published items in Internal Revenue Bulletins
1999–27 through 1999–52 is in Internal Revenue
Bulletin 2000–1, dated January 3, 2000.

May 8, 2000iv2000–19 I.R.B.
Revenue Rulings—continued:
92–19
Supplemented by
Rev. Rul. 2000–17, 2000–13 I.R.B. 842
98–30
Amplified and superseded by
Rev. Rul. 2000–8, 2000–7 I.R.B. 617
Treasury Decisions:
8734
Modified by
T.D. 8856, 2000–3 I.R.B. 298
8804
Modified by
T.D. 8856, 2000–3 I.R.B. 298
8845
Corrected by
Announcement 2000–6, 2000–4 I.R.B. 428
8846
Corrected by
Announcement 2000–3, 2000–2 I.R.B. 296
8847
Corrected by
Announcement 2000–13, 2000–11 I.R.B. 771
8849
Corrected by
Announcement 2000–28, 2000–15 I.R.B. 876
8852
Corrected by
Announcement 2000–18, 2000–13 I.R.B. 846
8853
Corrected by
Announcement 2000–33, 2000–15 I.R.B. 878
8856
Corrected by
Announcement 2000–31, 2000–15 I.R.B. 877
8859
Corrected by
Announcement 2000–27, 2000–15 I.R.B. 876
8864
Corrected by
Announcement 2000–26, 2000–15 I.R.B. 876
8865
Corrected by
Announcement 2000–37, 2000–16 I.R.B. 947
8867
Corrected by
Announcement 2000–30, 2000–15 I.R.B. 877
8869
Corrected by
Announcement 2000–36, 2000–16 I.R.B. 947
8870
Corrected by
Announcement 2000–34, 2000–15 I.R.B. 879
8874
Corrected by
Announcement 2000–29, 2000–15 I.R.B. 877

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