us-irs-revenue-rulings-irb-1996-35-pdf•Internal Revenue Bulletin 1996-35 (PDF rendition): IRS Revenue Rulings
Internal Revenue Bulletin 1996-35 (PDF rendition): IRS Revenue Rulings
us-irs-revenue-rulings-irb-1996-35-pdfInternal Revenue Bulletin 1996-35 (PDF rendition): IRS Revenue RulingsGuidance
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. 96–42, page 4. Mutual life insurance companies; differential earn- ings rate.The differential earnings rate for 1995 and the recomputed differential earnings rate for 1994 are set forth for use by mutual life insurance companies to compute their income tax liabilities for 1995. Notice 96–41, page 6. 1996 section 43 inflation adjustment factor.This notice announces the inflation adjustment factor to be used in determining the enhanced oil recovery credit for tax years beginning in the 1996 calendar year. Notice 96–42, page 6. 1996 marginal production rates.This notice an- nounces the applicable percentage to be used in deter- mining percentage depletion for marginal properties for the 1996 calendar year. EXEMPT ORGANIZATIONS Announcement 96–80, page 16. A list is given of organizations now classified as private foundations. ADMINISTRATIVE Rev. Proc. 96–43, page 6. Section 355 ‘‘No Rule.’’This procedure amplifies the ‘‘No Rule’’ Rev. Proc. 96–3, 1996–1 I.R.B. 82, to include certain transactions under section 355 of the Code. Rev. Proc. 96–44, page 7. Insurance companies; loss reserves; discounting un- paid losses.The loss payment patterns and discount factors are set forth for the 1996 accident year. These factors will be used for computing discounted unpaid losses under section 846 of the Code. Rev. Proc. 96–45, page 12. Insurance companies; discounting estimated salvage recoverable.The salvage discount factors are set forth for the 1996 accident year. These factors will be used for computing estimated salvage recoverable under sec- tion 832 of the Code. Announcement 96–77, page 15. Backup withholding; substitute Form W–9.The effec- tive date of Rev. Proc. 96–26, 1996–8 I.R.B. 22, is extended for certain payors who must secure regulatory approval of changes to their substitute Forms W–9. Announcement 96–78, page 15. T.D. 8670, 1996–24 I.R.B. 6, relating to qualified cost sharing arrangements, is corrected. Announcement 96–79, page 15. T.D. 8671, 1996–26 I.R.B. 8, relating to requirements for furnishing a taxpayer identifying number on returns, statements, and other documents, is corrected. Finding Lists begin on page 17. Bulletin No. 1996–35 August 26, 1996 HIGHLIGHTS OF THIS ISSUE These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations. Mission of the Service The purpose of the Internal Revenue Service is to collect the proper amount of tax revenue at the least cost; serve the public by continually improving the quality of our products and services; and perform in a manner warranting the highest degree of public confidence in our integrity, efficiency and fairness. Statement of Principles of Internal Revenue Tax Administration The function of the Internal Revenue Service is to administer the Internal Revenue Code. Tax policy for raising revenue is determined by Congress. With this in mind, it is the duty of the Service to carry out that policy by correctly applying the laws enacted by Congress; to determine the reasonable meaning of various Code provisions in light of the Congressional purpose in enacting them; and to perform this work in a fair and impartial manner, with neither a government nor a taxpayer point of view. At the heart of administration is interpretation of the Code. It is the responsibility of each person in the Service, charged with the duty of interpreting the law, to try to find the true meaning of the statutory provision and not to adopt a strained construction in the belief that he or she is ‘‘protecting the revenue.’’ The revenue is properly protected only when we as- certain and apply the true meaning of the statute. The Service also has the responsibility of applying and administering the law in a reasonable, practical manner. Issues should only be raised by examining officers when they have merit, never arbitrarily or for trading purposes. At the same time, the examining officer should never hesitate to raise a meritorious issue. It is also important that care be exercised not to raise an issue or to ask a court to adopt a position inconsistent with an established Service position. Administration should be both reasonable and vigorous. It should be conducted with as little delay as possible and with great courtesy and considerateness. It should never try to overreach, and should be reasonable within the bounds of law and sound administration. It should, however, be vigorous in requiring compliance with law and it should be relentless in its attack on unreal tax devices and fraud. 2 Introduction The Internal Revenue Bulletin is the authoritative instru- ment of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Inter- nal Revenue Service and for publishing Treasury Deci- sions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It is published weekly and may be obtained from the Superin- tendent of Documents on a subscription basis. Bulletin contents of a permanent nature are consolidated semi- annually into Cumulative Bulletins, which are sold on a single-copy basis. It is the policy of the Service to publish in the Bulletin all substantive 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 otherwise indicated. Proce- dures relating solely to matters of internal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published. Revenue rulings represent the conclusions of the Ser- vice on the application of the law to the pivotal facts stated in the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwar- ranted invasions of privacy and to comply with statutory requirements. Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying published rulings and proce- dures, the effect of subsequent legislation, regulations, court decisions, rulings, and procedures must be consid- ered, and Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same. The Bulletin is divided into four parts as follows: Part I.—1986 Code. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1986. Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions, and Subpart B, Legislation and Related Committee Reports. Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Subparts. Also included in this part are Bank Secrecy Act Administrative Rulings. Bank Secrecy Act Administra- tive Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforce- ment). Part IV.—Items of General Interest. With the exception of the Notice of Proposed Rulemak- ing and the disbarment and suspension list included in this part, none of these announcements are consoli- dated in the Cumulative Bulletins. The first Bulletin for each month includes an index for the matters published during the preceding month. These monthly indexes are cumulated on a quarterly and semiannual basis, and are published in the first Bulletin of the succeeding quarterly and semi-annual period, respectively. The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate. For sale by the Superintendent of Documents U.S. Government Printing Office, Washington, D.C. 20402. 3 Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 Section 355.—Distribution of Stock and Securities of a Controlled Corporation 26 CFR 1.355–3: Active conduct of a trade or business. The revenue procedure amplifies the ‘‘No Rule’’ revenue procedure, Rev. Proc. 96–3, 1996–1 I.R.B. 82, to include certain transactions under § 355 of the Code. See Rev. Proc. 96–43, page 6. Section 809.—Reduction in Certain Deductions of Mutual Life Insurance Companies 26 CFR 1.809–9: Computation of the differential earnings rate and the recomputed differential earnings rate. Mutual life insurance companies; differential earnings rate.The differen- tial earnings rate for 1995 and the recomputed differential earnings rate for 1994 are set forth for use by mutual life insurance companies to compute their income tax liabilities for 1995. Rev. Rul. 96–42 This revenue ruling contains the dif- ferential earnings rate for 1995 and the recomputed differential earnings rate for 1994. Under § 809 of the Internal Rev- enue Code, mutual life insurance com- panies use these rates in computing their Federal income tax liability for taxable years beginning in 1995. This revenue ruling also contains the figures on which the determinations of these rates are based. Notice 96–15, 1996–13 I.R.B. 19, contained tentative determinations of these rates. Section 809(a) provides that, in the case of any mutual life insurance com- pany, the amount of the deduction al- lowable under § 808 for policyholder dividends is reduced (but not below zero) by the ‘‘differential earnings amount.’’ Any excess of the differential earnings amount over the amount of the deduction allowable under § 808 is taken into account as a reduction in the closing balance of reserves under sub- sections (a) and (b) of § 807. The ‘‘differential earnings amount’’ for any taxable year is the amount equal to the product of (a) the life insurance compa- ny’s average equity base for the taxable year multiplied by (b) the ‘‘differential earnings rate’’ for that taxable year. The ‘‘differential earnings rate’’ for the tax- able year is the excess of (a) the ‘‘imputed earnings rate’’ for the taxable year over (b) the ‘‘average mutual earn- ings rate’’ for the second calendar year preceding the calendar year in which the taxable year begins. The ‘‘imputed earn- ings rate’’ for any taxable year is the amount that bears the same ratio to 16.5 percent as the ‘‘current stock earnings rate’’ for the taxable year bears to the ‘‘base period stock earnings rate.’’ Section 809(f) provides that, in the case of any mutual life insurance com- pany, if the ‘‘recomputed differential earnings amount’’ for any taxable year exceeds the differential earnings amount for that taxable year, the excess is included in life insurance gross income for the succeeding taxable year. If the differential earnings amount for any tax- able year exceeds the recomputed differ- ential earnings amount for that taxable year, the excess is allowed as a life insurance deduction for the succeeding taxable year. The ‘‘recomputed differen- tial earnings amount’’ for any taxable year is an amount calculated in the same manner as the differential earnings amount for that taxable year, except that the average mutual earnings rate for the calendar year in which the taxable year begins is substituted for the average mutual earnings rate for the second calendar year preceding the calendar year in which the taxable year begins. The stock earnings rates and mutual earnings rates taken into account under § 809 generally are determined by di- viding statement gain from operations by the average equity base. For this purpose, the term ‘‘statement gain from operations’’ means ‘‘the net gain or loss from operations required to be set forth in the annual statement, determined without regard to Federal income taxes, and . . . properly adjusted for realized capital gains and losses. . . .’’ See § 809(g)(1). The term ‘‘equity base’’ is defined as an amount determined in the manner prescribed by regulations equal to surplus and capital increased by the amount of nonadmitted financial assets, the excess of statutory reserves over the amount of tax reserves, the sum of certain other reserves, and 50 percent of any policyholder dividends (or other similar liability) payable in the follow- ing taxable year. See § 809(b)(2), (3), (4), (5) and (6). Section 1.809–10 of the Income Tax Regulations provides that the equity base includes both the asset valuation reserve and the interest main- tenance reserve for taxable years ending after December 31, 1991. Section 1.809–9(a) of the regulations provides that neither the differential earnings rate under § 809(c) nor the recomputed differential earnings rate that is used in computing the recom- puted differential earnings amount under § 809(f)(3) may be less than zero. For purposes of § 809, the differen- tial earnings rate for 1995 and the rate used to calculate the recomputed differ- ential earnings amount for 1994 (the recomputed differential earnings rate for 1994), and the figures on which these two rates are based are set forth in Table 1. Rev. Rul. 96–42 TABLE 1 Determination of Rates To Be Used For Taxable Years Beginning in 1995 Differential earnings rate for 1995. . . . . . . . . . . . . . . . . . . 0 Recomputed differential earn- ings rate for 1994 . . . . . . . . 5.887 Imputed earnings rate for 1994. . . . . . . . . . . . . . . . . . . 15.109 Imputed earnings rate for 1995. . . . . . . . . . . . . . . . . . . 12.625 Base period stock earnings rate. . . . . . . . . . . . . . . . . . . . 18.221 Current stock earnings rate for 1995. . . . . . . . . . . . . . . . 13.942 Stock earnings rate for 1992 . 7.004 Stock earnings rate for 1993 . 23.385 Stock earnings rate for 1994 . 11.437 Average mutual earnings rate for 1993. . . . . . . . . . . . . . . . 18.406 Average mutual earnings rate for 1994. . . . . . . . . . . . . . . . 9.222 DRAFTING INFORMATION The principal author of this revenue ruling is Katherine A. Hossofsky of the Assistant Chief Counsel (Financial Insti- tutions and Products). For further infor- mation regarding this revenue ruling contact Ms. Hossofsky on (202) 622- 3477 (not a toll-free number). Section 832.—Insurance Company Taxable Income 26 CFR 1.832–4: Gross Income. The salvage discount factors are set forth for the 1996 accident year. These factors will be used for computing estimated salvage recoverable for pur- poses of section 832 of the Code. See Rev. Proc. 96–45, page 12. 4 Section 846.—Discounted Unpaid Losses Defined 26 CFR 1.846–1: Application of discount factors. The loss payment patterns and discount factors are set forth for the 1996 accident year. These factors will be used for computing discounted unpaid losses under section 846 of the Code. See Rev. Proc. 96–44, page 7. The salvage discount factors are set forth for the 1996 accident year. These factors will be used for computing estimated salvage recoverable for pur- poses of section 832 of the Code. See Rev. Proc. 96–45, page 12. 5 Part III. Administrative, Procedural, and Miscellaneous 1996 Section 43 Inflation Adjustment Notice 96–41 Section 43(b)(3)(B) of the Internal Revenue Code requires the Secretary to publish an inflation adjustment factor. The enhanced oil recovery credit under § 43 for any taxable year is reduced if the ‘‘reference price,’’ determined under § 29(d)(2)(C), for the calendar year pre- ceding the calendar year in which the taxable year begins is greater than $28 multiplied by the inflation adjustment factor for that year. The term ‘‘inflation adjustment fac- tor’’ means, with respect to any calendar year, a fraction the numerator of which is the GNP implicit price deflator for the preceding calendar year and the denomi- nator of which is the GNP implicit price deflator for 1990. Because the reference price for the 1995 calendar year ($14.26) does not exceed $28 multiplied by the inflation adjustment factor for the 1996 calendar year, the enhanced oil recovery credit for qualified costs paid or incurred in 1996 is determined without regard to the phase-out for crude oil price increases. Table 1 contains the GNP implicit price deflator used for the 1996 calendar year, as well the previously published GNP implicit price deflators used for the 1991 through 1995 calendar years. Notice 96–41 TABLE 1 GNP IMPLICIT PRICE DEFLATORS Calendar Year GNP Implicit Price Deflator 1990112.9 (used for 1991) 1991117.0 (used for 1992) 1992120.9 (used for 1993) 1993124.1 (used for 1994) 1994126.0 (used for 1995) 1995107.5 (used for 1996)* *Beginning in 1995, the GNP im- plict price deflator was rebased rela- tive to 1992. The 1990 GNP implicit price deflator used to compute the 1996 § 43 inflation adjustment fac- tor is 93.6 Table 2 contains the inflation adjust- ment factor and the phase-out amount for taxable years beginning in the 1996 calendar year as well as the previously published inflation adjustment factors and phase-out amounts for the 1991 through 1995 calendar years. Notice 96–41 TABLE 2 INFLATION ADJUSTMENT FACTORS AND PHASE-OUT AMOUNTS Calendar Year Inflation Adjustment Factor Phase-out Amount 19911.00000 19921.03630 19931.07080 19941.09920 19951.11600 19961.14850 DRAFTING INFORMATION The principal author of this notice is Brenda M. Stewart of the Office of Assistant Chief Counsel (Passthroughs and Special Industries). For further in- formation regarding this notice contact Ms. Stewart on (202) 622–3120 (not a toll-free call). 1996 Marginal Production Rates Notice 96–42 Section 613A(c)(6)(C) of the Internal Revenue Code defines the term ‘‘appli- cable percentage’’ for purposes of deter- mining percentage depletion for oil and gas produced from marginal properties. The applicable percentage is the per- centage (not greater than 25 percent) equal to the sum of 15 percent, plus one percentage point for each whole dollar by which $20 exceeds the reference price (determined under § 29(d)(2)(C)) for crude oil for the calendar year preceding the calendar year in which the taxable year begins. The reference price determined under § 29(d)(2)(C) for the 1995 calendar year is $14.26. Table 1 contains the applicable per- centages for marginal production for taxable years beginning in calendar years 1991 through 1996. Notice 96–42 TABLE 1 APPLICABLE PERCENTAGE FOR MARGINAL PRODUCTION Calendar Year Applicable Percentage 199115 percent 199218 percent 199319 percent 199420 percent 199521 percent 199620 percent DRAFTING INFORMATION The principal author of this notice is Brenda M. Stewart of the Office of Assistant Chief Counsel (Passthroughs and Special Industries). For further in- formation regarding this notice contact Ms. Stewart on (202) 622–3120 (not a toll-free call). 26 CFR 601.201: Rulings and determination let- ters. (Also §§ 355; 1.355–3.) Rev. Proc. 96–43 SECTION 1. PURPOSE This revenue procedure amplifies Rev. Proc. 96–3, 1996–1 I.R.B. 82, which sets forth the areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (Domestic) and the Associate Chief Counsel (Em- ployee Benefits and Exempt Organiza- tions) relating to issues on which the Internal Revenue Service will not issue advance rulings or determination letters. SECTION 2. BACKGROUND Section 4 of Rev. Proc. 96–3 sets forth those areas in which rulings or determination letters will not ordinarily be issued. Section 355(a) of the Internal Revenue Code applies to distributions of stock or securities of a corporation con- trolled by the distributing corporation if each of the corporations is engaged in the active conduct of a trade or busi- ness. Section 355(b) provides that a corporation is engaged in such conduct if, among other things, it is directly engaged in the active conduct of a trade or business, or substantially all of its assets consist of stock and securities of a corporation controlled by it (immedi- ately after the transaction) which is so engaged. SECTION 3. PROCEDURE Rev. Proc. 96–3 is amplified by add- ing to section 4 the following: Section 355.—Distribution of Stock and Securities of a Controlled Corpora- tion.—Whether a distribution of stock or securities is described in § 355(a)(1) when the gross assets of the trades or businesses relied on to satisfy the active trade or business requirement of § 355(b) will have a fair market value that is less than 5 percent of the total fair market value of the gross assets of the corporation directly conducting the 6 trades or businesses. The Service may rule that the trades or businesses satisfy the active trade or business requirement of § 355(b) if it can be established that, based upon all relevant facts and cir- cumstances, the trades or businesses are not de minimis compared with the other assets or activities of the corporation and its subsidiaries. SECTION 4. EFFECTIVE DATE This revenue procedure will apply to all ruling requests postmarked or, if not mailed, received on or after August 8, 1996. FURTHER INFORMATION For further information regarding this revenue procedure contact Robert Hawkes of the Office of Assistant Chief Counsel (Corporate) at (202) 622–7530 (not a toll-free call). 26 CFR 601.201: Rulings and determination let- ters (Also Part I, Sections 846; 1.846–1.) Rev. Proc. 96–44 SECTION 1. PURPOSE This revenue procedure prescribes the loss payment patterns and discount fac- tors for the 1996 accident year. These factors will be used for computing dis- counted unpaid losses under § 846 of the Internal Revenue Code. See Rev. Proc. 92–47, 1992–1 C.B. 980, for back- ground concerning the loss payment patterns and application of the discount factors. SEC. 2. SCOPE This revenue procedure applies to any taxpayer that is required to discount its unpaid losses under § 846 for a line of business using discount factors pub- lished by the Secretary. SEC. 3. TABLES OF DISCOUNT FACTORS .01 The following tables present separately for each line of business the discount factors under § 846 for acci- dent year 1996. All the discount factors presented in this section were deter- mined using the applicable interest rate under § 846(c) for 1996, which is 6.63 percent, and by assuming all loss pay- ments occur in the middle of the calen- dar year. .02 If the groupings of individual lines of business on the annual state- ment changes, taxpayers must discount the unpaid losses on the resulting lines of business in accordance with the dis- counting patterns that would have ap- plied to those unpaid losses based on their classification on the 1990 annual statement. .03 Tables Tables of Discount Factors Section 846 - 1996 - Interest rate: 6.63 percent Homeowners/Farmowners Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 066.875366.875330.632533.124792.4763 AY+ 190.463323.58808.30609.536787.0955 AY+ 293.39142.92815.83316.608688.2656 AY+ 395.70812.31673.82764.291989.1817 AY+ 497.40811.70002.32592.591989.7376 AY+ 598.62711.21901.22141.372988.9620 AY+ 699.15280.52570.75950.847289.6468 AY+ 799.54250.38970.40740.457589.0559 AY+ 899.73180.18930.23900.268289.1020 AY+ 999.80630.07450.17790.193791.8346 AY+10N/A0.07450.11270.119294.5850 AY+11N/A0.07450.04320.044796.8412 AY+12N/A0.04470.00000.0000N/A Private Passenger Auto Liability/Medical Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 034.761734.761758.901665.238390.2868 AY+ 166.296331.534630.243533.703789.7336 AY+ 281.214014.917716.844418.786089.6646 AY+ 389.82728.61329.067110.172889.1303 AY+ 494.45494.62774.88955.545188.1776 AY+ 596.87882.42392.71073.121286.8495 Continued on next page 7 Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 698.15261.27381.57511.847485.2614 AY+ 798.69620.54361.11821.303885.7661 AY+ 899.04850.35230.82860.951587.0805 AY+ 999.26670.21820.65820.733389.7569 AY+10N/A0.21820.47650.515192.5079 AY+11N/A0.21820.28280.296995.2452 AY+12N/A0.21820.07620.078796.8412 AY+13N/A0.07870.00000.0000N/A Commercial Auto/Truck Liability/Medical Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 020.843920.843969.000479.156187.1701 AY+ 147.313626.469746.242152.686487.7685 AY+ 265.647518.334030.376034.352588.4244 AY+ 379.048113.400518.552220.951988.5467 AY+ 486.89457.846511.679813.105589.1220 AY+ 592.45035.55586.71727.549788.9736 AY+ 695.57513.12473.93594.424988.9483 AY+ 797.30521.73022.41032.694889.4420 AY+ 898.14690.84171.70091.853191.7885 AY+ 998.85490.70801.08261.145194.5428 AY+10N/A0.70800.42330.437196.8412 AY+11N/A0.43710.00000.0000N/A Workers’ Compensation Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 022.336622.336664.248477.663482.7268 AY+ 150.694128.357539.225649.305979.5557 AY+ 266.188615.494525.826433.811476.3837 AY+ 374.42288.234219.035925.577274.4253 AY+ 479.56635.143414.986720.433773.3432 AY+ 583.72274.156411.688316.277371.8077 AY+ 686.13162.40899.975813.868471.9321 AY+ 788.44522.31368.248211.554871.3830 AY+ 888.96250.51738.260811.037574.8434 AY+ 989.92660.96417.813010.073477.5606 AY+10N/A0.96417.33559.109380.5270 AY+11N/A0.96416.82638.145383.8070 AY+12N/A0.96416.28337.181287.4975 AY+13N/A0.96415.70446.217191.7536 AY+14N/A0.96415.08715.253096.8412 AY+15N/A5.25300.00000.0000N/A Commercial Multiple Peril Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 033.419333.419356.761366.580785.2519 AY+ 159.129625.710333.975740.870483.1303 AY+ 267.40808.278427.679932.592084.9284 Continued on next page 8 Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 375.75718.349120.893624.242986.1844 AY+ 483.86738.110213.904116.132786.1858 AY+ 589.57995.71268.927010.420185.6710 AY+ 693.41243.83255.56146.587684.4217 AY+ 795.64552.23313.62424.354583.2276 AY+ 896.95711.31162.51013.042982.4887 AY+ 997.44970.49262.16782.550385.0017 AY+10N/A0.49261.80292.057787.6150 AY+11N/A0.49261.41371.565190.3275 AY+12N/A0.49260.99881.072593.1260 AY+13N/A0.49260.55630.579995.9349 AY+14N/A0.49260.08450.087396.8412 AY+15N/A0.08730.00000.0000N/A Medical Malpractice Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 03.70263.702669.623196.297472.3001 AY+ 111.55357.851066.132188.446574.7708 AY+ 221.929610.376159.802278.070476.6003 AY+ 332.855510.925952.484867.144578.1669 AY+ 446.616413.760941.754853.383678.2165 AY+ 560.909214.292829.764139.090876.1409 AY+ 669.23498.325723.140230.765175.2157 AY+ 771.65742.422522.172828.342678.2316 AY+ 873.76102.103621.470726.239081.8275 AY+ 977.83954.078618.682622.160584.3062 AY+10N/A4.078615.709718.081986.8808 AY+11N/A4.078612.539614.003389.5476 AY+12N/A4.07869.15949.924892.2886 AY+13N/A4.07865.55515.846295.0206 AY+14N/A4.07861.71181.767696.8412 AY+15N/A1.76760.00000.0000N/A Special Liability (Ocean Marine, Aircraft (all Perils), Boiler and Machinery) Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 031.223131.223161.162668.776988.9290 AY+ 168.224737.001627.009131.775385.0004 AY+ 280.285812.061116.345319.714282.9115 AY+ 385.41665.130812.130814.583483.1827 AY+ 489.40283.98628.818910.597283.2194 AY+ 593.24933.84655.43166.750780.4607 AY+ 694.05150.80224.96345.948583.4397 AY+ 795.89011.83863.39394.109982.5788 AY+ 897.79951.90931.64732.200574.8580 AY+ 997.99200.19251.55772.008077.5737 AY+10N/A0.19251.46211.815580.5381 AY+11N/A0.19251.36031.623083.8157 AY+12N/A0.19251.25171.430487.5033 AY+13N/A0.19251.13591.237991.7563 AY+14N/A0.19251.01241.045496.8412 AY+15N/A1.04540.00000.0000N/A 9 Other Liability Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 09.97379.973768.408690.026375.9874 AY+ 121.881911.908260.647578.118177.6356 AY+ 232.558310.676453.643867.441779.5409 AY+ 341.45438.896048.014258.545782.0115 AY+ 456.358314.904035.807443.641782.0485 AY+ 571.676315.318022.363828.323778.9578 AY+ 678.03976.363517.275521.960378.6670 AY+ 782.25664.216814.066517.743479.2771 AY+ 885.27543.018811.881814.724680.6934 AY+ 987.40142.126010.474212.598683.1378 AY+10N/A2.12608.973410.472785.6836 AY+11N/A2.12607.37308.346788.3341 AY+12N/A2.12605.66656.220791.0905 AY+13N/A2.12603.84694.094893.9461 AY+14N/A2.12601.90661.968896.8412 AY+15N/A1.96880.00000.0000N/A Special Property (Fire, Allied Lines, Inland Marine, Earthquake, Glass, Burglary, and Theft) Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 057.781757.781739.853342.218394.3982 AY+ 188.339030.557310.941511.661093.8306 AY+ 2N/A5.83055.64635.830596.8412 AY+ 3N/A5.83050.00000.0000N/A Auto Physical Damage Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 084.182784.182715.217715.817396.2092 AY+ 198.869714.68701.06061.130393.8306 AY+ 2N/A0.56510.54730.565196.8412 AY+ 3N/A0.56510.00000.0000N/A Fidelity, Surety, Financial Guaranty, Mortgage Guaranty Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 025.172825.172868.715874.827291.8327 AY+ 157.628132.455339.757842.371993.8306 AY+ 2N/A21.185920.516721.185996.8412 AY+ 3N/A21.18590.00000.0000N/A Other (including Credit, Accident and Health) Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 063.672563.672534.197636.327594.1369 AY+ 188.892725.220210.422011.107393.8306 AY+ 2N/A5.55365.37825.553696.8412 AY+ 3N/A5.55360.00000.0000N/A 10 International (Composite) Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 030.800630.800658.621369.199484.7137 AY+ 156.923526.122935.533043.076582.4881 AY+ 268.690611.767125.737931.309482.2050 AY+ 376.76978.079119.101723.230382.2275 AY+ 483.53366.763913.383716.466481.2783 AY+ 588.97255.43908.654611.027578.4822 AY+ 691.62182.64936.49278.378277.4953 AY+ 793.43051.80875.05546.569576.9538 AY+ 894.36380.93334.42695.636278.5443 AY+ 995.05950.69574.00204.940581.0046 AY+10N/A0.69573.54904.244883.6078 AY+11N/A0.69573.06593.549286.3851 AY+12N/A0.69572.55092.853589.3943 AY+13N/A0.69572.00162.157892.7611 AY+14N/A0.69571.41601.462296.8412 AY+15N/A1.46220.00000.0000N/A Reinsurance A Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 035.804435.804458.766864.195691.5432 AY+ 172.267136.462825.010927.732990.1850 AY+ 279.12946.862219.583020.870693.8306 AY+ 3N/A10.435310.105710.435396.8412 AY+ 4N/A10.43530.00000.0000N/A Reinsurance B (Composite) Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 030.800630.800658.621369.199484.7137 AY+ 156.923526.122935.533043.076582.4881 AY+ 268.690611.767125.737931.309482.2050 AY+ 376.76978.079119.101723.230382.2275 AY+ 483.53366.763913.383716.466481.2783 AY+ 588.97255.43908.654611.027578.4822 AY+ 691.62182.64936.49278.378277.4953 AY+ 793.43051.80875.05546.569576.9538 AY+ 894.36380.93334.42695.636278.5443 AY+ 995.05950.69574.00204.940581.0046 AY+10N/A0.69573.54904.244883.6078 AY+11N/A0.69573.06593.549286.3851 AY+12N/A0.69572.55092.853589.3943 AY+13N/A0.69572.00162.157892.7611 AY+14N/A0.69571.41601.462296.8412 AY+15N/A1.46220.00000.0000N/A Reinsurance C Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 023.051323.051369.111076.948789.8144 AY+ 147.156524.105148.801652.843592.3512 Continued on next page 11 Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 273.174226.017725.170826.825893.8306 AY+ 3N/A13.412912.989213.412996.8412 AY+ 4N/A13.41290.00000.0000N/A Miscellaneous Casualty (Composite) Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 073.950373.950324.675026.049794.7226 AY+ 193.760119.80995.85496.239993.8306 AY+ 2N/A3.11993.02143.119996.8412 AY+ 3N/A3.11990.00000.0000N/A Long Lines (Composite) Tax Year Cumulative Losses Paid (%) Estimated Losses Paid Each Year (%) Discounted Unpaid Losses at Year End (%) Unpaid Losses at Year End (%) Discount Factor (%) AY+ 030.800630.800658.621369.199484.7137 AY+ 156.923526.122935.533043.076582.4881 AY+ 268.690611.767125.737931.309482.2050 AY+ 376.76978.079119.101723.230382.2275 AY+ 483.53366.763913.383716.466481.2783 AY+ 588.97255.43908.654611.027578.4822 AY+ 691.62182.64936.49278.378277.4953 AY+ 793.43051.80875.05546.569576.9538 AY+ 894.36380.93334.42695.636278.5443 AY+ 995.05950.69574.00204.940581.0046 AY+10N/A0.69573.54904.244883.6078 AY+11N/A0.69573.06593.549286.3851 AY+12N/A0.69572.55092.853589.3943 AY+13N/A0.69572.00162.157892.7611 AY+14N/A0.69571.41601.462296.8412 AY+15N/A1.46220.00000.0000N/A DRAFTING INFORMATION The principal author of this revenue procedure is Katherine A. Hossofsky of the Office of the Assistant Chief Coun- sel (Financial Institutions and Products). For further information regarding this revenue procedure, contact Ms. Hos- sofsky on (202) 622–3477 (not a toll- free number). 26 CFR 601.201: Rulings and determination let- ters (Also Part I, Sections 832, 846; 1.832–4, 1.846– 1.) Rev. Proc. 96–45 SECTION 1. PURPOSE This revenue procedure prescribes the salvage discount factors for the 1996 accident year. These factors will be used for computing discounted estimated sal- vage recoverable under § 832 of the Internal Revenue Code. SEC. 2. BACKGROUND Section 832(b)(5)(A) requires that all estimated salvage recoverable (including that which cannot be treated as an asset for state accounting purposes) be taken into account in computing the deduction for losses incurred. Under § 832(b)- (5)(A), paid losses are to be reduced by salvage and reinsurance recovered dur- ing the taxable year. This amount is adjusted to reflect changes in discounted unpaid losses on nonlife insurance con- tracts and in unpaid losses on life insurance contracts. An adjustment is then made to reflect any changes in discounted estimated salvage recover- able and in reinsurance recoverable. Pursuant to § 832(b), the amount of estimated salvage is determined on a discounted basis in accordance with pro- cedures established by the Secretary. SEC. 3. SCOPE This revenue procedure applies to any taxpayer that is required to discount estimated salvage recoverable under § 832. SEC. 4. APPLICATION .01 The following tables present separately for each line of business the discount factors under § 832 for the 1995 accident year. All the discount factors presented in this section were determined using the applicable interest rate under § 846(c) for 1996, which is 6.63 percent, and by assuming all esti- mated salvage is recovered in the 12 middle of each calendar year. See Rev. Proc. 91–48, 1991–2 C.B. 760, for back- ground regarding the tables. .02 These tables must be used by taxpayers irrespective of whether they elected to discount unpaid losses using their own historical experience under § 846. .03 Tables. Tables of Discount Factors Salvage Recoverable - 1996 - Interest rate: 6.63 percent Homeowners/Farmowners Tax Year Discount Factor (%) AY+ 092.4763 AY+ 187.0955 AY+ 288.2656 AY+ 389.1817 AY+ 489.7376 AY+ 588.9620 AY+ 689.6468 AY+ 789.0559 AY+ 889.1020 AY+ 991.8346 AY+1094.5850 AY+1196.8412 Private Passenger Auto Liability/Medical Tax Year Discount Factor (%) AY+ 090.2868 AY+ 189.7336 AY+ 289.6646 AY+ 389.1303 AY+ 488.1776 AY+ 586.8495 AY+ 685.2614 AY+ 785.7661 AY+ 887.0805 AY+ 989.7569 AY+1092.5079 AY+1195.2452 AY+1296.8412 Commercial Auto/Truck Liability/ Medical Tax Year Discount Factor (%) AY+ 087.1701 AY+ 187.7685 AY+ 288.4244 AY+ 388.5467 AY+ 489.1220 AY+ 588.9736 AY+ 688.9483 Tax Year Discount Factor (%) AY+ 789.4420 AY+ 891.7885 AY+ 994.5428 AY+1096.8412 Workers’ Compensation Tax Year Discount Factor (%) AY+ 082.7268 AY+ 179.5557 AY+ 276.3837 AY+ 374.4253 AY+ 473.3432 AY+ 571.8077 AY+ 671.9321 AY+ 771.3830 AY+ 874.8434 AY+ 977.5606 AY+1080.5270 AY+1183.8070 AY+1287.4975 AY+1391.7536 AY+1496.8412 Commercial Multiple Peril Tax Year Discount Factor (%) AY+ 085.2519 AY+ 183.1303 AY+ 284.9284 AY+ 386.1844 AY+ 486.1858 AY+ 585.6710 AY+ 684.4217 AY+ 783.2276 AY+ 882.4887 AY+ 985.0017 AY+1087.6150 AY+1190.3275 AY+1293.1260 AY+1395.9349 AY+1496.8412 Medical Malpractice Tax Year Discount Factor (%) AY+ 072.3001 AY+ 174.7708 AY+ 276.6003 AY+ 378.1669 AY+ 478.2165 AY+ 576.1409 AY+ 675.2157 AY+ 778.2316 AY+ 881.8275 Tax Year Discount Factor (%) AY+ 984.3062 AY+1086.8808 AY+1189.5476 AY+1292.2886 AY+1395.0206 AY+1496.8412 Special Liability (Ocean Marine, Aircraft (all Perils), Boiler and Machinery) Tax Year Discount Factor (%) AY+ 088.9290 AY+ 185.0004 AY+ 282.9115 AY+ 383.1827 AY+ 483.2194 AY+ 580.4607 AY+ 683.4397 AY+ 782.5788 AY+ 874.8580 AY+ 977.5737 AY+1080.5381 AY+1183.8157 AY+1287.5033 AY+1391.7563 AY+1496.8412 Other Liability Tax Year Discount Factor (%) AY+ 075.9874 AY+ 177.6356 AY+ 279.5409 AY+ 382.0115 AY+ 482.0485 AY+ 578.9578 AY+ 678.6670 AY+ 779.2771 AY+ 880.6934 AY+ 983.1378 AY+1085.6836 AY+1188.3341 AY+1291.0905 AY+1393.9461 AY+1496.8412 Special Property (Fire, Allied Lines, Inland Marine, Earthquake, Glass, Burglary, and Theft) Tax Year Discount Factor (%) AY+ 089.4016 AY+ 191.1418 AY+ 292.1391 Continued on next page 13 Tax Year Discount Factor (%) AY+ 393.5634 AY+ 494.5558 AY+ 596.2074 AY+ 696.8412 Auto Physical Damage Tax Year Discount Factor (%) AY+ 095.1966 AY+ 195.6676 AY+ 296.8412 Fidelity, Surety, Financial Guaranty, Mortgage Guaranty Tax Year Discount Factor (%) AY+ 084.0469 AY+ 186.4207 AY+ 287.7821 AY+ 389.4142 AY+ 491.0835 AY+ 592.7170 AY+ 693.9699 AY+ 795.0086 AY+ 896.8412 Other (including Credit, Accident and Health) Tax Year Discount Factor (%) AY+ 089.9648 AY+ 191.7311 AY+ 292.9067 AY+ 394.5018 AY+ 495.8377 AY+ 596.8412 International (Composite) Tax Year Discount Factor (%) AY+ 084.7137 AY+ 182.4881 AY+ 282.2050 AY+ 382.2275 AY+ 481.2783 AY+ 578.4822 AY+ 677.4953 Tax Year Discount Factor (%) AY+ 776.9538 AY+ 878.5443 AY+ 981.0046 AY+1083.6078 AY+1186.3851 AY+1289.3943 AY+1392.7611 AY+1496.8412 Reinsurance A Tax Year Discount Factor (%) AY+ 077.0244 AY+ 180.3308 AY+ 282.0405 AY+ 383.8941 AY+ 486.0620 AY+ 588.4270 AY+ 691.0715 AY+ 793.8805 AY+ 896.8412 Reinsurance B (Composite) Tax Year Discount Factor (%) AY+ 084.7137 AY+ 182.4881 AY+ 282.2050 AY+ 382.2275 AY+ 481.2783 AY+ 578.4822 AY+ 677.4953 AY+ 776.9538 AY+ 878.5443 AY+ 981.0046 AY+1083.6078 AY+1186.3851 AY+1289.3943 AY+1392.7611 AY+1496.8412 Reinsurance C Tax Year Discount Factor (%) AY+ 077.0244 AY+ 180.3308 AY+ 282.0405 AY+ 383.8941 Tax Year Discount Factor (%) AY+ 486.0620 AY+ 588.4270 AY+ 691.0715 AY+ 793.8805 AY+ 896.8412 Miscellaneous Casualty (Composite) Tax Year Discount Factor (%) AY+ 085.0124 AY+ 186.9026 AY+ 287.8050 AY+ 389.0382 AY+ 490.2502 AY+ 591.6718 AY+ 692.9603 AY+ 794.5573 AY+ 896.8412 Long Lines (Composite) Tax Year Discount Factor (%) AY+ 084.7137 AY+ 182.4881 AY+ 282.2050 AY+ 382.2275 AY+ 481.2783 AY+ 578.4822 AY+ 677.4953 AY+ 776.9538 AY+ 878.5443 AY+ 981.0046 AY+1083.6078 AY+1186.3851 AY+1289.3943 AY+1392.7611 AY+1496.8412 DRAFTING INFORMATION The principal author of this revenue procedure is Katherine A. Hossofsky of the Office of the Assistant Chief Coun- sel (Financial Institutions and Products). For further information regarding this revenue procedure, contact Ms. Hos- sofsky on (202) 622–3477 (not a toll- free number). 14 Part IV. Items of General Interest Effective Date Extension for Certain Payors Revising Their Substitute Forms W–9 Announcement 96–77 This announcement extends the Janu- ary 1, 1997, effective date of certain provisions of Rev. Proc. 96–26, 1996–8 I.R.B. 22, for certain payors. That rev- enue procedure provides requirements for payors of interest, dividends, and patronage dividends, and brokers that want to design and provide their own substitute Form W–9, Request for Tax- payer Identification Number and Certifi- cation, to obtain the required taxpayer identification number and ‘‘no backup withholding’’ certifications from their payees. The effective date of Rev. Proc. 96–26 (other than for section 5 relating to certain impermissible uses of the required certifications) is extended to July 1, 1997, if a payor (1) is required to obtain the approval of a governmental authority for changes to the format of its substitute Form W–9 required by Rev. Proc. 96–26, (2) applies, on or before September 30, 1996, for that approval, and (3) thereafter actively pursues that approval. The principal author of this announce- ment is John Coulter of the Office of Assistant Chief Counsel (Income Tax and Accounting). For further information regarding this announcement contact Mr. Coulter at (202) 622–4910 (not a toll- free call). Revision of Section 482 Cost Sharing Regulations; Correction Announcement 96–78 AGENCY: Internal Revenue Service, Treasury. ACTION: Correction to final regula- tions. SUMMARY: This document contains corrections to final regulations (TD 8670 [1996–24 I.R.B. 6]), which were published in theFederal Registeron Monday, May 13, 1996 (61 FR 21955) relating to qualified cost sharing ar- rangements. EFFECTIVE DATE: May 13, 1996. FOR FURTHER INFORMATION CON- TACT: Lisa Sams (202) 622–3840, (not a toll-free number). SUPPLEMENTARY INFORMATION: Background The final regulations that are the subject of these corrections are under section 482 of the Internal Revenue Code. Need for Correction As published, the final regulations contain errors which may prove to be misleading and are in need of clarifica- tion. Correction of Publication Accordingly, the publication of the final regulations (TD 8670), which are the subject of FR Doc. 96–11781, is corrected as follows: § 1.482–7 [Corrected] On page 21956, column 2, instruc- tional ‘‘Par. 3.’’, is corrected by revising item g. to read as follows: g. By redesignating the introductory text of paragraph (j)(2) following the heading and paragraphs (j)(2)(i) through (j)(2)(v) as the introductory text of paragraph (j)(2)(i) and paragraphs (j)(2)(i)(A) through (j)(2)(i)(E), respectively; and, by adding a heading to newly desig- nated paragraph (j)(2)(i). Cynthia E. Grigsby, Chief, Regulations Unit, Assistant Chief Counsel (Corporate). (Filed by the Office of the Federal Register on June 27, 1996, 8:45 a.m., and published in the issue of the Federal Register for June 28, 1996, 61 F.R. 33656) Taxpayer Identifying Numbers (TINs); Correction Announcement 96–79 AGENCY: Internal Revenue Service, Treasury. ACTION: Correction to final regula- tions. SUMMARY: This document contains corrections to final regulations (TD 8671 [1996–26 I.R.B. 8]) which were published in theFederal Registeron Wednesday, May 29, 1996 (61 FR 26788). The final regulations relate to requirements for furnishing a taxpayer identifying number on returns, state- ments or other documents. EFFECTIVE DATE: May 29, 1996. FOR FURTHER INFORMATION CON- TACT: Lilo A. Hester, (202) 874–1490 (not a toll-free number). SUPPLEMENTARY INFORMATION: Background The final regulations that are the subject of these corrections are under section 6109 of the Internal Revenue Code. Need for Correction As published, TD 8671 contains er- rors that are in need of correction. Correction of Publication Accordingly, the publication of final regulations which are the subject of FR Doc. 96–13397 is corrected as follows: 1. On page 26790, column 1, in amendatory instruction ‘‘Par 2.’’, line 1, the language ‘‘Section § 301.6109–1 is’’ is corrected to read ‘‘Section 301.6109–1 is’’. § 301.6109–1 [Corrected] 2. On page 26791, columns 1 and 2, § 301.6109–1(d)(3)(iv)(A)(1) is cor- rected to read as follows: § 301.6109–1 Identifying numbers. * * * * * (d) * * * (3) * * * (iv) * * * (A) * * * (1) Procedures for providing Form SS–4 and Form W–7, or such other necessary form to applicants for obtain- ing a taxpayer identifying number; * * * * * 3. On page 26792, column 2, § 301.6109–1(h)(1), line 8, the language ‘‘identification numbers apply after 151996–35 I.R.B. May’’ is corrected to read ‘‘identifica- tion numbers apply on and after May’’. Cynthia E. Grigsby, Chief, Regulations Unit, Assistant Chief Counsel (Corporate). (Filed by the Office of the Federal Register on June 27, 1996, 8:45 a.m., and published in the issue of the Federal Register for June 28, 1996, 61 F.R. 33657) Foundations Status of Certain Organizations Announcement 96–80 The following organizations have failed to establish or have been unable to maintain their status as public chari- ties or as operating foundations. Accord- ingly, grantors and contributors may not, after this date, rely on previous rulings or designations in the Cumulative List of Organizations (Publication 78), or on the presumption arising from the filing of notices under section 508(b) of the Code. This listing doesnotindicate that the organizations have lost their status as organizations described in section 501(c)(3), eligible to receive deductible contributions. Former Public Charities.The follow- ing organizations (which have been treated as organizations that are not private foundations described in section 509(a) of the Code) are now classified as private foundations: AFTL Ambassadors for the Lord Ministries, Garland, TX American Laryngeal Papilloma Foundation, Lake Hiawatha, NJ American Values, Washington, DC Apostolic Christian Village Inc., Francesville, IN Applewick Sports Fitness Club, East Chicago, IN Aspens Celebration of Indigenous Cultures, Aspen, CO Balloon Project, Inc., Port Chester, NY Beatrice K. Compten Memorial Trust, Beaver Falls, PA Bicycle Service Racing Team, Wichita, KS Bogota Resque Squad, Bogota, NJ Books for Democracy Incorporated, Alexandria, VA Breakthrough Breast Cancer, Bloomfield Hills, MI Breast Cancer Resource Committee Inc., Washington, DC Center for Family Resources Inc., Metuchen, NJ Center for Industrial Preservation Inc., Petersburg, VA Center for Justice and International Law, Washington, DC Center for Language Development Inc., East Orange, NJ Center for Public Information on Electromagnetic Radiation Inc., Milltown, NJ Central Roxborough Civic Assoc., Philadelphia, PA Centre County Columbus Celebration, State College, PA Charitable Foundation of the Rotary Club of Roanoke Valley Inc., Roanoke, VA Charles County Dive Rescue Inc., Waldorf, MD Chinese Academic Link USA Inc., Hyattsville, MD Christe Inc., Cincinnati, OH Citizens Information Inc., Chester, NJ College Bound Inc., Washington, DC College of Exploration, Vienna, VA Committee of 100 Dorchester Inc., Cambridge, MD Common Concerns Broadcasting Inc., Trenton, NJ Community Council for the Homeless, Washington, DC Concerned African American Parents of Westfield, Westfield, NJ Conservative Christian Action Group Inc., Elkhart, WI Corrigan Ministries, Inc., Cincinnati, OH Creative Playgrounds of Nutley a New Jersey Non-Profit Corporation, Nutley, NJ Cumberland-Goodwill Fire & Rescue, Carlisle, PA Cure (Citizens Urge Rescue of the Environment), Hanover, PA Curwensville Development Corp., Curwensville, PA Daffodil West Hermitage, Cimarron, NM Dallas Contemporary Art Museum, Dallas, TX Damocles Inc., Arlington, VA Dancers Unlimited Performing Ensemble, Wilmington, DE Dawson Bucs Little League Teams, Rawlings, MD Debate America, Washington, DC Delaware Valley Alliance for RIF, Norristown, PA Desert Shield-Storm Family Foundation Inc., Wall, NJ De Unique Incorporated, Cheverly, MD Elizabeth Williams Group Home, Akron, OH Environmental Awareness Group, Inc., Boston, MA Holiday House II, Philadelphia, PA Indian Head Literacy Coalition, New Richmond, WI International Human Rights Consulting Group, Washington, DC Lommen Nelson Cole & Stageberg Foundation, Minneapolis, MN Manchester Supportive Housing Inc., Oakmont, PA Mathieu Mategot Foundation for Contemporary Tapestry Inc., Bethesda, MD Medical Foundation of Cincinnati, Cincinnati, OH Paul Morgan Academy, Fort Worth, TX Networking for Jesus, Houston, TX Northeast Scattered Site Resident Management Corp., Chicago, IL Northwest Perry Township Revitalization Group, Lima, OH Out of Bondage Ministries, Inc., La Salle, CO Prime Life Foundation, Reston, VA Recreational Boating Industries Educational Foundation, Romeo, MI Remote Sensing Research Incorporated, Fort Collins, CO Reverend Charles Brink Scholarship Trust, Inc., Kansas City, KS Shelter Company, Lebanon, VA Tri-County Recreational Center Inc., Chestertown, NY Virginia Beach Lifeguard Association Inc., Virginia Beach, VA Wings to Needs Incorporated, LaGrange, KY If an organization listed above sub- mits information that warrants the re- newal of its classification as a public charity or as a private operating founda- tion, the Internal Revenue Service will issue a ruling or determination letter with the revised classification as to foundation status. Grantors and contribu- tors may thereafter rely upon such rul- ing or determination letter as provided in section 1.509(a)–7 of the Income Tax Regulations. It is not the practice of the Service to announce such revised classi- fication of foundation status in the Inter- nal Revenue Bulletin. 161996–35 I.R.B. Numerical Finding List 1 Bulletins 1996–27 through 1996–34 Announcements: 96–61, 1996–27 I.R.B.72 96–62, 1996–28 I.R.B.55 96–63, 1996–29 I.R.B.18 96–64, 1996–29 I.R.B.18 96–65, 1996–29 I.R.B.18 96–66, 1996–29 I.R.B.19 96–67, 1996–30 I.R.B.27 96–68, 1996–31 I.R.B.45 96–69, 1996–32 I.R.B.38 96–70, 1996–32 I.R.B.40 96–71, 1996–33 I.R.B.16 96–72, 1996–33 I.R.B.16 96–73, 1996–33 I.R.B.18 96–74, 1996–33 I.R.B.19 96–75, 1996–34 I.R.B.29 96–76, 1996–34 I.R.B.29 Court Decisions: 2058, 1996–34 I.R.B.13 2059, 1996–34 I.R.B.10 2060, 1996–34 I.R.B.5 Notices: 96–36, 1996–27 I.R.B.11 96–37, 1996–31 I.R.B.29 96–38, 1996–31 I.R.B.29 96–39, 1996–32 I.R.B.8 96–40, 1996–33 I.R.B.11 Proposed Regulations: CO–9–96, 1996–34 I.R.B.20 CO–24–96, 1996–30 I.R.B.22 CO–25–96, 1996–31 I.R.B.30 CO–26–96, 1996–31 I.R.B.31 FI–28–96, 1996–31, I.R.B.33 FI–32–95, 1996–34 I.R.B.21 FI–48–95, 1996–31 I.R.B.36 FI–59–94, 1996–30 I.R.B.23 GL–7–96, 1996–33 I.R.B.13 IA–26–94, 1996–30 I.R.B.24 IA–29–96, 1996–33 I.R.B.14 IA-292-84, 1996–28 I.R.B.38 PS–22–96, 1996–33 I.R.B.15 PS–39–93, 1996–34 I.R.B.27 Public Laws: 104–117, 1996–34 I.R.B.19 Railroad Retirement Quarterly Rate 1996–29 I.R.B.14 Revenue Procedures: 96–36, 1996–27 I.R.B.11 96–37, 1996–29 I.R.B.16 96–39, 1996–33 I.R.B.11 96–40, 1996–32 I.R.B.8 96–41, 1996–32 I.R.B.9 96–42, 1996–32 I.R.B.14 Revenue Rulings: 96–33, 1996–27 I.R.B.4 96–34, 1996–28 I.R.B.4 96–35, 1996–31 I.R.B.4 96–36, 1996–30 I.R.B.6 96–37, 1996–32 I.R.B.4 96–38, 1996–33 I.R.B.4 96–39, 1996–34 I.R.B.4 Tax Conventions: 1996–28 I.R.B. 36 Treasury Decisions: 8673, 1996–27 I.R.B.4 8674, 1996–28 I.R.B.7 8675, 1996–29 I.R.B.5 8676, 1996–30 I.R.B.4 8677, 1996–30 I.R.B.7 8678, 1996–31 I.R.B.11 8679, 1996–31 I.R.B.4 8680, 1996–33 I.R.B.5 1 A cumulative list of all Revenue Rulings, Rev- enue Procedures, Treasury Decisions, etc., pub- lished in Internal Revenue Bulletins 1996–1 through 1996–26 will be found in Internal Rev- enue Bulletin 1996–27, dated July 1, 1996. 17 Finding List of Current Action on Previously Published Items 1 Bulletins 1996–27 through 1996–34 *Denotes entry since last publication Revenue Procedures: 80–27 Modified by 96–40, 1996–32 I.R.B.8 87–32 Modified by TD 8680, 1996–33 I.R.B.5 92–20 Modified by TD 8680, 1996–33 I.R.B.5 95–29 Superseded by 96–36, 1996–27 I.R.B.11 95–29A Superseded by 96–36, 1996–27 I.R.B.11 95–30 Superseded by 96–42, 1996–32 I.R.B.14 1 A cumulative finding list for previously published items mentioned in Internal Revenue Bulletins 1996–1 through 1996–26 will be found in Internal Revenue Bulletin 1996–27, dated July 1, 1996. 18
Continue your research in ChatGPT or Claude
Connect Omnilex to search the legal corpus from your AI assistant.