Internal Revenue Bulletin 2000-52 (PDF rendition): IRS Announcements

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. 2000–55, page 595.
Section 1274A inflation-adjusted numbers for 2001.
This ruling provides the dollar amounts, increased by the
2001 inflation adjustment, for section 1274A of the Code.
Rev. Rul. 99–50 supplemented and superseded.
Rev. Rul. 2000–56, page 598.
CPI adjustment for below-market loans for 2001. The
amount that section 7872(g) of the Code permits a taxpay-
er to lend to a qualified continuing care facility without incur-
ring imputed interest is adjusted for years 1987–2001. Rev.
Rul. 99–49 supplemented and superseded.
Rev. Proc. 2000–50, page 601.
Tax treatment of computer software expenditures. This
procedure updates the guidelines contained in Rev. Proc.
69–21, relating to costs incurred to develop, purchase,
lease, or license computer software, to be consistent with
sections 167(f)(1) and 197 of the Code and the regulations
thereunder. It also provides safe harbors and procedures for
taxpayers to obtain consent to change to a method under
this revenue procedure. Rev. Proc. 69–21 superseded. Rev.
Procs. 97–50 and 99–49 modified.
EMPLOYEE PLANS
Notice 2000–66, page 600.
Retirement plans; year 2001 section 415(d) lim-
itations.
Cost-of-living adjustments effective January 1,
2001, applicable to the dollar limits on benefits under quali-
fied defined benefit pension plans and to other provisions
affecting (1) certain plans of deferred compensation and (2)
“control employees,” are set forth.
EMPLOYMENT TAX
T.D. 8909, page 596.
REG–114423–00, page 604.
Final, temporary, and proposed regulations under section 6302
of the Code relate to the deposit of federal employment taxes.
Page 602.
2001 social security contribution and benefit base;
domestic employee coverage threshold.The
Commissioner of the Social Security Administration has
announced (1) the OASDI contribution and benefit base for
remuneration paid in 2001 and self-employment income
earned in taxable years beginning in 2001, and (2) the
domestic employee coverage threshold amount for 2001.
TAX CONVENTIONS
Rev. Rul. 2000–59, page 593.
“Liable to Tax” treaty residence standard. Guidance is
provided on the “liable to tax” standard for residence under
U.S. income tax treaties.
ADMINISTRATIVE
Notice 2000–65, page 599.
LMSB industry issue resolution pilot program.
This
notice announces the pilot program to provide guidance to
resolve frequently disputed tax issues that are common to a
significant number of large or mid-size business taxpayers.
This effort is part of the Service’s strategy to resolve issues
in a manner other than the traditional post-filing examination
process. Taxpayers, as well as industry associations and
other groups representing taxpayers, are invited to suggest
issues and possible options for resolution.
Internal Revenue
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Bulletin No. 2000–52
December 26, 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
Finding Lists begin on page ii.
(Continued on the next page)

December 26, 20002000–52 I.R.B.
Announcement 2000–101, page 604.
This announcement includes the procedures for partner-
ships to request a waiver of the requirement for partner-
ships with more than 100 partners to electronically file
Form 1065, U.S. Partnership Return of Income.
Announcement 2000–102, page 605.
This document contains corrections to the footnotes for the
Actions Relating to Court Decisions published in 1999-40
I.R.B. on the page following the Introduction.

2000–52 I.R.B.December 26, 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 oth-
erwise 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 Ser-
vice personnel in the disposition of other cases. In applying
published rulings and procedures, the effect of subsequent
legislation, regulations, court decisions, rulings, and proce-
dures must be considered, and Service personnel and oth-
ers concerned are cautioned against reaching the same
conclusions in other cases unless the facts and circum-
stances 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 Ad-
ministrative Rulings. Bank Secrecy Act Administrative Rul-
ings 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 succeed-
ing semiannual 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.

Section 162.—Trade or
Business Expenses
Under what circumstances may a taxpayer ex-
pense the costs of self-created computer software?
See Rev. Proc. 2000–50, page 601.
Section 167.—Depreciation
How is the capitalized cost of computer software
amortized? See Rev. Proc. 2000–50, page 601.
Section 197.—Amortization of
Goodwill and Certain Other
Intangibles
What is the proper tax treatment of the cost of
computer software that is excluded from section
197? See Rev. Proc. 2000–50, page 601.
Section 446.—General Rule for
Methods of Accounting
If a taxpayer changes to a method provided for in
Rev. Proc. 2000–50, is this a change in method of
accounting? See Rev. Proc. 2000–50, page 601.
Section 481.—Adjustments
Required by Changes in Method
of Accounting
Is a section 481(a) adjustment required for a
change in the method of accounting under Rev. Proc.
2000–50 for the cost of computer software? See Rev.
Proc. 2000–50, page 601.
Section 483.—Interest on
Certain Deferred Payments
26 CFR 1.483–1: Computation of interest on
certain deferred payments.
As defined by section 1274A, the definitions for
both “qualified debt instruments” and “cash method
debt instuments” have dollar ceilings on the stated
principal amount. The limits to the stated principal
amount are adjusted for inflation for sales or ex-
changes occurring in the 2001 calendar year. See
Rev. Rul. 2000–55, page 595.
Section 894(a).—Income
Affected by Treaty
26 CFR 1.894–1(a): Income affected by treaty.
(Also sections 894(c); 1.894–1(d))
“Liable to Tax” treaty residence
standard. Guidance is provided on the
“liable to tax” standard for residence
under U.S. income tax treaties.
Rev. Rul. 2000–59
This revenue ruling provides guidance
on whether certain entities will be consid-
ered liable to tax under the laws of a for-
eign country for purposes of determining
if such entities are residents within the
meaning of the relevant Treaty. In order
to obtain treaty benefits a person must be
a resident of the applicable treaty jurisdic-
tion and must meet all other applicable re-
quirements for obtaining treaty benefits,
including any applicable limitation on
benefits provision and, in the case of an
entity that is fiscally transparent under the
laws of the United States or the entity’s
jurisdiction, the requirement that the en-
tity derive the item of income for which
treaty benefits are sought within the
meaning of Treas. Reg. § 1.894–1(d).
FACTS
Situation 1
Entity A is a business organization in
Country X, which has an income tax treaty
in effect with the United States that is identi-
cal to the 1996 United States Model Income
Tax Treaty (1996 U.S. Model). Under the
laws of Country X, Entity A is an invest-
ment company taxable on income from all
sources at the entity level by reason of being
incorporated in Country X. Similar to other
domestic corporations, distributions from a
Country X investment company are gener-
ally treated as dividends and do not retain
the character or source of the underlying in-
come. However, net capital gains and, in
some cases, tax exempt interest, retain their
character when they are distributed to the in-
vestment company’s interest holders. Fur-
ther, a Country X investment company may
deduct distributions of current income to its
interest holders in computing taxable in-
come. Entity A distributes its net income
and capital gains on a current basis to its in-
terest holders so that it will not actually bear
a tax. Country X imposes a withholding tax
on Entity A’s dividend distributions to its
foreign interest holders regardless of the
source of Entity A’s underlying income. If
Entity A did not distribute such amounts,
Entity A would be taxed by Country X on
such amounts. Entity A receives dividend
income from the United States.
Country X has not announced by public
notice that investment companies such as
Entity A are not residents of Country X, and
there is no competent authority agreement
providing that such entities are not residents
of Country X. Further, the U.S. competent
authority has not issued a public notice indi-
cating that treaty benefits to such entities are
being denied because, and to the extent that,
Country X will not grant treaty benefits to
similar U.S. entities.
Situation 2
Entity B is an investment company or-
ganized in Country Y, which has an in-
come tax treaty in effect with the United
States that is identical to the 1996 U.S.
Model. Under the laws of Country Y, cor-
porations organized in Country Y are gen-
erally taxable on income from all sources
at the entity level by reason of being in-
corporated in Country Y. A specific pro-
vision in Country Y law, however, ex-
empts the income of investment
companies such as Entity B from taxa-
tion. Under Country Y law, the character
and source of distributions from Entity B
to all its interest holders are determined
based on the distributions themselves
rather than on the character and source of
Entity B’s underlying income. Further,
Country Y imposes a withholding tax on
distributions to its foreign interest holders
regardless of the source of the underlying
income. Entity B receives dividend in-
come from the United States.
Country Y has not announced by public
notice that investment companies such as
Entity B are not residents of Country Y,
and there is no competent authority agree-
ment providing that such entities are not
residents of Country Y. Further, the U.S.
competent authority has not issued a public
notice indicating that treaty benefits to
such entities are being denied because, and
to the extent that, Country Y will not grant
treaty benefits to similar U.S. entities.
Situation 3
Entity C is a trust established and ad-
ministered in Country Z, which has an in-
2000–52 I.R.B.593December 26, 2000
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

December 26, 20005942000–52 I.R.B.
come tax treaty with the United States
identical to the 1981 U.S. Model Income
Tax treaty (1981 U.S. Model). The trust
exclusively provides pension benefits.
Entity C’s trustee is a resident of Country
Z. Under the laws of Country Z, because
Entity C’s trustee is a resident of Country
Z, Entity C is treated as a resident trust
taxable at the entity level. However, be-
cause Entity C is established and operated
exclusively to provide pension benefits, a
provision of Country Z law exempts En-
tity C from Country Z income tax. Entity
C receives dividend income from the
United States.
Country Z has not announced by public
notice that entities such as Entity C are
not residents of Country Z, and there is no
competent authority agreement providing
that such entities are not residents of
Country Z. Further, the U.S. competent
authority has not issued a public notice
indicating that treaty benefits to such enti-
ties are being denied because, and to the
extent that, Country Z will not grant
treaty benefits to similar U.S. entities.
LAW AND ANALYSIS
Article 4 of the 1996 U.S. Model pro-
vides in relevant part:
1. Except as provided in this paragraph,
for the purposes of this Convention, the
term “resident of a Contracting State”
means any person who, under the laws
of that State, is liable to tax therein by
reason of his domicile, residence, citi-
zenship, place of management, place of
incorporation, or any other criterion of
a similar nature.
a) The term “resident of a Contract-
ing State” does not include any person
who is liable to tax in that state in respect
only of income from sources in that State
or of profits attributable to a permanent
establishment.
b) A legal person organized under
the laws of a Contracting State and that is
generally exempt from tax in that State
and is established and maintained in that
State either:
i) exclusively for a religious, char-
itable, educational, scientific, or other
similar purpose; or
ii) to provide pension or other simi-
lar benefits to employees pursuant to a plan
is to be treated as a resident of the Con-
tracting State where it is established.
The analogous portion of Article 4 of
the 1981 U.S. Model provides:
1. For the purposes of this Convention,
the term “resident of a Contracting
State” means any person who under the
laws of the State, is liable to tax therein
by reason of his domicile, residence,
citizenship, place of management,
place of incorporation, or any other cri-
terion of a similar nature, provided,
however, that
(a) this term does not include any per-
son who is liable to tax in that State in re-
spect only of income from sources within
that State or capital situated therein;
The phrase “liable to tax” as used in the
above articles does not require actual tax-
ation. Thus, the fact that a person is only
nominally taxable does not preclude that
person from meeting the applicable “li-
able to tax” standard of these residence
articles. This is consistent with the posi-
tion taken in the 1996 U.S. Model Techni-
cal Explanation to Article 4(1), which
provides: “[c]ertain entities that are nomi-
nally subject to tax but that in practice
rarely pay tax also would generally be
treated as residents and therefore ac-
corded treaty benefits. For example,
RICs, REITs, and REMICs, are all resi-
dents of the United States for purposes of
the treaty.”
For purposes of these residence arti-
cles, whether a person will be liable to tax
in, and thus a resident of, a jurisdiction
depends on the facts and circumstances.
However, in the context of a bilateral in-
come tax treaty, a person will not be con-
sidered a resident of a contracting state if
(1) the treaty partner has announced by
public notice that such persons are not
residents of that state; (2) there is a com-
petent authority agreement or separate
specific treaty provision providing that
such persons are not residents of that
state; or (3) the treaty partner would not
treat similar U.S. persons as residents of
the United States, and the Internal Rev-
enue Service has issued a public notice
indicating that treaty benefits to such enti-
ties are consequently being denied. Con-
versely, a person may be treated as a resi-
dent of a contracting state if there is a
competent authority agreement or sepa-
rate specific treaty provision providing
that such persons are residents of that
state. The Internal Revenue Service shall
announce the terms of any relevant com-
petent authority agreement or treaty part-
ner’s position.
Situation 1
Under the facts of Situation 1, notwith-
standing that Entity A is only nominally
taxable in Country X, Entity A is “liable
to tax in [Country X] by reason of its
place of incorporation,” within the mean-
ing of the U.S.- Country X treaty, because
of the following factors. First, as a corpo-
ration incorporated in Country X, Entity
A may be taxed by Country X on its
worldwide income. Second, but for the
deduction regime, Country X would have
imposed a tax on Entity A as it would any
corporation incorporated in Country X.
Third, the character and source of certain
distributions by Entity A are determined
independent of the character and source
of Entity A’s income, and Country X im-
poses a withholding tax on such distribu-
tions by Entity A to its foreign interest
holders regardless of the source of Entity
A’s underlying income.
Finally, Country X has not announced
by public notice that persons such as En-
tity A are not residents of Country X;
there is no competent authority agreement
providing that such persons are not resi-
dents of Country X; and the U.S. compe-
tent authority has not issued a public no-
tice indicating that treaty benefits to such
persons are being denied because Country
X will not grant treaty benefits to similar
U.S. persons.
Accordingly, Entity A is liable to tax in
Country X by reason of its place of incor-
poration within the meaning of Article 4
(1) of the U.S.-Country X treaty, and thus
is a resident of Country X for purposes of
the U.S.-Country X treaty. In order to ob-
tain treaty benefits, however, Entity A
must still meet all other applicable re-
quirements for such benefits, including
the applicable limitation on benefits pro-
vision and, if Entity A is viewed as fis-
cally transparent under the laws of either
the United States or Country X, those
provisions of Treas. Reg. § 1.894–1(d).
Situation 2
Under the facts of Situation 2, notwith-
standing that Entity B is only nominally
liable to tax in Country Y, Entity B is li-
able to tax by reason of its place of incor-
poration, within the meaning of the U.S.-
Country Y treaty, because of the follow-

ing factors. First, as a corporation incor-
porated in Country Y, Entity B may be
taxed by Country Y on its worldwide in-
come. Second, but for the specific ex-
emption in Country Y law, Country Y
would have imposed a tax on Entity B as
it would any corporation incorporated in
Country Y. Third, the character and
source of distributions by Entity B are de-
termined independent of the character and
source of the Entity B’s underlying in-
come, and Country Y imposes a withhold-
ing tax on distributions by Entity B to its
foreign interest holders regardless of the
source of Entity B’s underlying income.
Finally, Country Y has not announced
by public notice that persons such as En-
tity A are not residents of Country Y; there
is no competent authority agreement pro-
viding that such persons are not residents
of Country Y; and the U.S. competent au-
thority has not issued a public notice indi-
cating that treaty benefits to such persons
are being denied because Country Y will
not grant treaty benefits to similar U.S.
persons.
Accordingly, Entity B is liable to tax in
Country Y by reason of its place of incor-
poration within the meaning of Article 4
(1) of the U.S.-Country Y treaty, and thus
B is a resident of Country Y for purposes
of the U.S.-Country Y treaty. In order to
obtain treaty benefits, however, Entity B
must still meet all other applicable re-
quirements for such benefits, including
the applicable limitation on benefits pro-
vision and, if Entity B is viewed as fis-
cally transparent under the laws of either
the United States or Country Y, those pro-
visions of Treas. Reg. § 1.894–1(d).
Situation 3
Under the facts of Situation 3, notwith-
standing that Entity C is only nominally
taxable in Country Z, Entity C is liable to
tax within the meaning of the U.S.-Coun-
try Z treaty because of the following. But
for the exemption from tax for Country Z
entities that provide pension benefits, En-
tity C would be taxable by Country Z at
the entity level as a resident trust in
Country Z. While the 1981 U.S. Model
does not specifically provide that persons
organized under the laws of a state that
are generally exempt from tax and estab-
lished and maintained exclusively to pro-
vide pension or other similar benefits are
residents of that state (and the 1996 U.S.
Model does so provide), the Treasury De-
partment’s Technical Explanation to the
1996 U.S. Model confirms that the spe-
cific provision in the 1996 U.S. Model
merely clarifies the generally accepted
practice that these entities are residents
even though they may be entitled to a
complete or partial exemption from tax.
Further, Country Z has not announced by
public notice that persons such as Entity A
are not residents of Country Z; there is no
competent authority agreement providing
that such persons are not residents of Coun-
try Z; and the U.S. competent authority has
not issued a public notice indicating that
treaty benefits to such persons are being de-
nied because Country Z will not grant
treaty benefits to similar U.S. persons.
Accordingly, Entity C is liable to tax
in Country Z within the meaning of Arti-
cle 4(1) of the Treaty, and thus is a resi-
dent of Country Z for purposes of the
Treaty. In order to obtain treaty benefits,
however, Entity C must still meet all
other applicable requirements for such
benefits, including the applicable limita-
tion on benefits provision and, if Entity
C is viewed as fiscally transparent under
the laws of either the United States or
Country Z, those provisions of Treas.
Reg. § 1.894–1(d).
DRAFTING INFORMATION
The principal author of this revenue
ruling is Shawn R. Pringle of the Office of
Associate Chief Counsel (International).
For further information regarding this rev-
enue ruling, contact Elizabeth U. Karzon
or Karen Rennie-Quarrie at (202) 622-
3880 (not a toll-free call).
Section 1274.—Determination
of Issue Price in the Case of
Certain Debt Instruments Issued
for Property
26 CFR 1.1274A–1: Special rules for certain
transactions where stated principal amount does
not exceed $2,800,000.
As defined by section 1274A, the definitions for
both “qualified debt instruments” and “cash method
debt instruments” have dollar ceilings on the stated
principal amount. The limits to the stated principal
amount are adjusted for inflation for sales or ex-
changes occurring in the 2001 calendar year. See
Rev. Rul. 2000–55 on this page.
Section 1274A.—Special Rules
for Certain Transactions Where
Stated Principal Amount Does
Not Exceed $2,800,000
(Also §§ 1274, 483; 1.1274A-1, 1.483–1)
Section 1274A inflation-adjusted
numbers for 2001.This ruling provides
the dollar amounts, increased by the 2001
inflation adjustment, for section 1274A of
the Code. Rev. Rul. 99–50 supplemented
and superseded.
Rev. Rul. 2000-55
This revenue ruling provides the dollar
amounts, increased by the 2001 inflation
adjustment, for § 1274A of the Internal
Revenue Code.
BACKGROUND
In general, §§ 483 and 1274 determine
the principal amount of a debt instrument
given in consideration for the sale or ex-
change of nonpublicly traded property. In
addition, any interest on a debt instrument
subject to § 1274 is taken into account
under the original issue discount provi-
sions of the Code. Section 1274A, how-
ever, modifies the rules under §§ 483 and
1274 for certain types of debt instru-
ments.
In the case of a “qualified debt instru-
ment,” the discount rate used for purposes
of §§ 483 and 1274 may not exceed 9 per-
cent, compounded semiannually. Section
1274A(b) defines a qualified debt instru-
ment as any debt instrument given in con-
sideration for the sale or exchange of
property (other than new § 38 property
within the meaning of § 48(b), as in effect
on the day before the date of enactment of
the Revenue Reconciliation Act of 1990)
if the stated principal amount of the in-
strument does not exceed the amount
specified in § 1274A(b). For debt instru-
ments arising out of sales or exchanges
before January 1, 1990, this amount is
$2,800,000.
In the case of a “cash method debt in-
strument,” as defined in § 1274A(c), the
borrower and lender may elect to use the
cash receipts and disbursements method
of accounting. In particular, for any cash
method debt instrument, § 1274 does not
apply, and interest on the instrument is ac-
2000–52 I.R.B.595December 26, 2000

counted for by both the borrower and the
lender under the cash method of account-
ing. A cash method debt instrument is a
qualified debt instrument that meets the
following additional requirements: (A) In
the case of instruments arising out of
sales or exchanges before January 1,
1990, the stated principal amount does
not exceed $2,000,000; (B) the lender
does not use an accrual method of ac-
counting and is not a dealer with respect
to the property sold or exchanged; (C)
§ 1274 would have applied to the debt in-
strument but for an election under
§ 1274A(c); and (D) an election under
§ 1274A(c) is jointly made with respect to
the debt instrument by the borrower and
lender. Section 1.1274A–1(c)(1) of the
Income Tax Regulations provides rules
concerning the time for, and manner of,
making this election.
Section 1274A(d)(2) provides that, for
any debt instrument arising out of a sale
or exchange during any calendar year
after 1989, the dollar amounts stated in
§ 1274A(b) and § 1274A(c)(2)(A) are in-
creased by the inflation adjustment for the
calendar year. Any increase due to the in-
flation adjustment is rounded to the near-
est multiple of $100 (or, if the increase is
a multiple of $50 and not of $100, the in-
crease is increased to the nearest multiple
of $100). The inflation adjustment for
any calendar year is the percentage (if
any) by which the CPI for the preceding
calendar year exceeds the CPI for calen-
dar year 1988. Section 1274A(d)(2)(B)
defines the CPI for any calendar year as
the average of the Consumer Price Index
as of the close of the 12-month period
ending on September 30 of that calendar
year.
INFLATION-ADJUSTED AMOUNTS
For debt instruments arising out of
sales or exchanges after December 31,
1989, the inflation-adjusted amounts
under § 1274A are shown in Table 1.
December 26, 20005962000–52 I.R.B.
Rev. Rul. 2000–55 Table 1
Inflation-Adjusted Amounts Under § 1274A
Calendar Year1274A(b) Amount1274A(c)(2)(A) Amount
of Sale(qualified debt(cash method debt
or Exchangeinstrument)instrument)
1990$2,933,200$2,095,100
1991$3,079,600$2,199,700
1992$3,234,900$2,310,600
1993$3,332,400$2,380,300
1994$3,433,500$2,452,500
1995$3,523,600$2,516,900
1996$3,622,500$2,587,500
1997$3,723,800$2,659,900
1998$3,823,100$2,730,800
1999$3,885,500$2,775,400
2000$3,960,100$2,828,700
2001$4,085,900$2,918,500
Note: These inflation adjustments were computed using the All-Urban, Consumer Price Index, 1982-1984 base, pub-
lished by the Bureau of Labor Statistics.
EFFECT ON OTHER DOCUMENTS
Rev. Rul. 99–50, 1999–50 I.R.B. 656 is
supplemented and superseded.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Courtney Shepardson of the Of-
fice of Assistant Chief Counsel (Financial
Institutions and Products). For further in-
formation regarding this revenue ruling,
contact Ms. Shepardson at (202) 622-
3930 (not a toll-free call).
Section 6302.—Mode or Time of
Collection
26 CFR 31.6302–1: Federal tax deposit rules for
withheld income taxes and taxes under the Federal
Insurance Contributions Act (FICA) attributable to
payments made after December 31, 1992.
T.D. 8909
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 31
Federal Employment Tax
Deposits—De MinimisRule
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Temporary and final regula-
tions.
SUMMARY: This document contains
temporary and final regulations relating to
the deposit of Federal employment taxes.
The regulations change the de minimis de-
posit rule for quarterly and annual return

periods. The regulations affect taxpayers
required to make deposits of Federal em-
ployment taxes. The text of the tempo-
rary regulations also serves as the text of
the proposed regulations (REG–
114423–00) set forth in the notice of pro-
posed rulemaking on page 604.
DATES:Effective date: These regulations
are effective Wednesday, December 6,
2000.
Applicability date: For dates of applic-
ability, see §31.6302–1T(f)(4).
FOR FURTHER INFORMATION CON-
TACT: Brinton T. Warren, (202) 622-
4940 (not a toll-free call).
SUPPLEMENTARY INFORMATION:
Background and Explanation of
Provisions
This document contains amendments
to 26 CFR part 31, Employment Taxes
and Collection of Income Tax at the
Source. Section 31.6302-1(f)(4) provides
that if the total amount of accumulated
employment taxes for a return period is
less than $1,000 and the amount is fully
deposited or remitted with a timely filed
return for the quarter, the amount de-
posited or remitted will be deemed to be
timely deposited.
The temporary regulations change the
$1,000 threshold to $2,500. Thus, a tax-
payer that has accumulated employment
taxes of less than $2,500 for a return pe-
riod (quarterly or annual, as the case may
be) does not have to make deposits but
may remit its full liability with a timely
filed return for the return period.
The de minimisthreshold is being raised
as part of the IRS and Treasury’s continued
efforts to reduce burden on the small busi-
ness community. On June 16, 1998, tem-
porary regulations (T.D. 8771, 1998–2 C.B.
72) that raised the de minimisthreshold
from $500 to $1,000 were published in the
Federal Register(63 F.R. 32735). This in-
crease of the threshold to $1,000 was made
final on June 17, 1999, (T.D. 8822, 1999–2
C.B. 5) in regulations published in the Fed-
eral Register(64 F.R. 32408).
Having conducted further study, the
IRS now seeks additional changes in de-
posit requirements to reduce taxpayer
burden. The IRS and Treasury have de-
termined that another increase in the de
minimisthreshold is a simple and
straightforward step that will reduce bur-
den on small businesses.
Special Analyses
It has been determined that this Trea-
sury decision is not a significant regula-
tory action as defined in Executive Order
12866. Therefore, a regulatory assess-
ment is not required. It also has been de-
termined that section 553(b) of the Ad-
ministrative Procedure Act (5 U.S.C.
chapter 5) does not apply to these regula-
tions, and, because these regulations do
not impose a collection of information on
small entities, the Regulatory Flexibility
Act (5 U.S.C. chapter 6) does not apply.
Pursuant to section 7805(f) of the Internal
Revenue Code, these regulations will be
submitted to the Chief Counsel for Advo-
cacy of the Small Business Administra-
tion for comment on their impact on small
businesses.
Drafting Information
The principal author of the regulations
is Brinton T. Warren of the Office of As-
sociate Chief Counsel, Procedure and Ad-
ministration (Administrative Provisions
and Judicial Practice Division). However,
other personnel from the IRS and Trea-
sury Department participated in their de-
velopment.
* * * * *
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR part 31 is
amended as follows:
PART 31—EMPLOYMENT TAXES
AND COLLECTION OF INCOME TAX
AT SOURCE
Paragraph 1. The authority citation for
part 31 is amended by adding an entry in
numerical order to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Section 31.6302–1T also issued under
26 U.S.C. 6302(a) and (c). * * *
Par. 2. In §31.6302–1, a new sentence
is added at the end of paragraph (f)(4) to
read as follows:
§31.6302–1 Federal tax deposit rules for
withheld income taxes and taxes under
the Federal Insurance Contributions Act
(FICA) attributable to payments made
after December 31, 1992.
* * * * *
(f) * * *
(4) * * * For guidance regarding de
minimisamounts for quarterly or annual
return periods beginning on or after Janu-
ary 1, 2001, see §31.6302–1T(f)(4).
* * * * *
Par. 3. Section 31.6302–1T is added to
read as follows:
§31.6302–1T Federal tax deposit rules for
withheld income taxes and taxes under the
Federal Insurance Contributions Act
(FICA) attributable to payments made
after December 31, 1992 (temporary).
(a) through (f)(3). [Reserved] For fur-
ther guidance, see §31.6302–1(a) through
(f)(3).
(f)(4) De Minimis rule. For quarterly
and annual return periods beginning on or
after January 1, 2001, if the total amount
of accumulated employment taxes for the
return period is less than $2,500 and the
amount is fully deposited or remitted with
a timely filed return for the return period,
the amount deposited or remitted will be
deemed to have been timely deposited.
(f)(5) through (n). [Reserved] For fur-
ther guidance, see §31.6302–1(f)(5)
through (n).
Charles O. Rossotti,
Commissioner of Internal Revenue.
Approved November 21, 2000.
Jonathan Talisman,
Assistant Secretary for Tax Policy.
(Filed by the Office of the Federal Register on De-
cember 5, 2000, 8:45 a.m., and published in the
issue of the Federal Register for December 6, 2000,
65 F.R. 76152)
Section 7872.—Treatment of
Loans with Below-Market
Interest Rates
CPI adjustment for below-market
loans for 2001. The amount that section
7872(g) of the Code permits a taxpayer to
lend to a qualified continuing care facility
without incurring imputed interest is pub-
lished and adjusted for inflation for years
2000–52 I.R.B.597December 26, 2000

1987–2001. Rev. Rul. 99–49 supple-
mented and superseded.
Rev. Rul. 2000–56
This revenue ruling publishes the
amount that § 7872(g) of the Internal
Revenue Code permits a taxpayer to lend
to a qualifying continuing care facility
without incurring imputed interest. The
amount is adjusted for inflation for the
years after 1986.
Section 7872 generally treats loans
bearing a below-market interest rate as if
they bore interest at the market rate.
Section 7872(g)(1) provides that, in gen-
eral, § 7872 does not apply for any calendar
year to any below-market loan made by a
lender to a qualified continuing care facility
pursuant to a continuing care contract if the
lender (or the lender’s spouse) attains age
65 before the close of the year.
Section 7872(g)(2) provides that, in the
case of loans made after October 11,
1985, and before 1987, § 7872(g)(1) ap-
plies only to the extent that the aggregate
outstanding amount of any loan to which
§ 7872(g) applies (determined without re-
gard to § 7872(g)(2)), when added to the
aggregate outstanding amount of all other
previous loans between the lender (or the
lender’s spouse) and any qualified contin-
uing care facility to which § 7872(g)(1)
applies, does not exceed $90,000.
Section 7872(g)(5) provides that, for
loans made during any calendar year after
1986 to which § 7872(g)(1) applies, the
$90,000 limit specified in § 7872(g)(2) is
increased by an inflation adjustment. The
inflation adjustment for any calendar year
is the percentage (if any) by which the
Consumer Price Index (CPI) for the pre-
ceding calendar year exceeds the CPI for
calendar year 1985. Section 7872(g)(5)
states that the CPI for any calendar year is
the average of the CPI as of the close of
the 12-month period ending on September
30 of that calendar year.
Table 1 sets forth the amount specified
in § 7872(g)(2) of the Code. The amount
is increased by the inflation adjustment
for the years 1987-2001.
December 26, 20005982000–52 I.R.B.
REV. RUL. 2000–56 TABLE 1
Limit under 7872(g)(2)
Y
earAmount
Before 1987$ 90,000
1987$ 92,200
1988$ 94,800
1989$ 98,800
1990$103,500
1991$108,600
1992$114,100
1993$117,500
1994$121,100
1995$124,300
1996$127,800
1997$131,300
1998$134,800
1999$137,000
2000$139,700
2001$144,111
Note: These inflation adjustments were computed using the All-Urban, Consumer Price Index 1982-1984 base, pub-
lished by the Bureau of Labor Statistics.
EFFECT ON OTHER DOCUMENTS
Rev. Rul. 99–49, 1999–50 I.R.B. 667,
is supplemented and superseded.
DRAFTING INFORMATION
The author of this revenue ruling is
Courtney Shepardson of the Office of As-
sistant Chief Counsel (Financial Institu-
tions and Products). For further informa-
tion regarding this revenue ruling, contact
Ms. Shepardson at (202) 622-3930 (not a
toll-free call).

Industry Issue Resolution Pilot
Program
Notice 2000–65
1. INTRODUCTION OF A PILOT
PROGRAM
This Notice announces the Industry
Issue Resolution Pilot Program. The ob-
jective of the program is to provide guid-
ance to resolve frequently disputed tax is-
sues that are common to a significant
number of large or mid-size business tax-
payers. This effort is part of the IRS’s
strategy to resolve issues in a manner
other than the traditional post-filing ex-
amination process. The Large and Mid-
size Business Division (LMSB) of the
IRS will undertake much of the opera-
tional responsibility for the projects in the
program.
We invite taxpayers as well as industry
associations and other groups represent-
ing taxpayers to suggest issues and possi-
ble options for resolution. Parties submit-
ting suggestions may be asked to meet
with government representatives and to
provide additional information. After
analysis and review, the IRS and Treasury
intend to select issues to address in this
pilot program. Taxpayers or groups may
contact Richard Druk of LMSB’s Pre-fil-
ing and Technical Guidance Office at
(202) 283-8387 (not a toll-free number) to
ask questions or to discuss this program.
The form of resulting guidance may
vary depending on the issue. However,
the most likely form of guidance will be a
Revenue Procedure that permits taxpayers
to adopt a recommended treatment of the
issue on future returns. In many cases,
this may require filing a request for a
change in method of accounting. Exam-
ples of the types of Revenue Procedures
that could be issued under this program
include: Rev. Proc. 2000–38, 2000–40
I.R.B. 310, on the treatment of mutual
fund distributor commissions; Rev. Proc.
99–26, 1999–24 I.R.B. 38, on employee
benefits secured by letters of credit; Rev.
Proc. 97–44, 1997–2 C.B. 496, on the
LIFO conformity requirement for auto-
mobile dealers.
The principal focus of the program is to
resolve issues arising in future years.
However, depending on the circum-
stances, resolution also may be provided
for certain issues for prior years.
Suggestions for issues for the pilot pro-
gram should be forwarded as provided in
section 3 of this Notice by February 28,
2001. LMSB, the IRS Office of Chief
Counsel and the Treasury Office of Tax
Policy will evaluate the suggestions with
a view to selecting approximately five is-
sues, drawn from diverse industries, for
the pilot program. In reviewing potential
issues for the program, the selection crite-
ria will include the suitability of the issue
for the program, the likelihood that
timely guidance can be provided, and the
availability of appropriate staffing and
other resources. Projects selected for this
program will be handled in a manner sim-
ilar to items listed on the Treasury and
IRS Guidance Priority List.
Parties whose topics are included in the
pilot will be notified and may be asked to
provide additional information and legal
analysis of the issue. The issues selected
for the pilot program will be announced
publicly. After completing the pilot, the
IRS and Treasury will evaluate the pro-
gram and may then continue the program
on a permanent basis.
We believe that the Industry Issue Res-
olution program offers significant and
timely benefits for taxpayers as well as
the IRS, and invites interested parties to
participate.
2. ISSUES APPROPRIATE FOR THE
PROGRAM
The objective of this program is to pro-
vide guidance to resolve frequently dis-
puted tax issues that are common to a sig-
nificant number of large or mid-size
taxpayers. Therefore, issues most appro-
priate to the program generally will have
the following characteristics:
• There is uncertainty about the appro-
priate tax treatment of a given factual
situation.
• The uncertainty has resulted in fre-
quent, often repetitive examinations of
the same issue.
• The issue impacts a significant number of
taxpayers within an industry group, many
of which are larger businesses (those with
gross assets in excess of $5 million).
• Factual determination is a major com-
ponent of the issue.
For purposes of the pilot, the following
issues would not be suitable:
• Issues unique to one or a small number
of taxpayers.
• Issues under the jurisdiction of the
Commissioner, Tax Exempt and Gov-
ernment Entities Division (e.g., em-
ployee plans).
• Issues regarding transactions that lack
a bona fidebusiness purpose or have as
their principal purpose the reduction of
federal taxes.
• Issues involving transfer pricing or in-
ternational tax treaties.
3. REQUESTING CONSIDERATION
UNDER THE PROGRAM
No particular format is required for
submissions in response to this Notice.
However, submissions should briefly de-
scribe the issue recommended for the
pilot and explain why there is a need for
guidance. Submissions may include an
analysis of how the issue may be re-
solved. In addition, submissions should
state the number of taxpayers estimated
to be affected by the issue. All submis-
sions will be available for public inspec-
tion and copying in their entirety.
Therefore, comments should not include
taxpayer-specific information of a confi-
dential nature. Letters should include
the name and telephone number of a
person to contact should further clarifi-
cation be needed.
The address to submit an issue for
consideration under the pilot program is:
Internal Revenue Service
Att’n: Richard Druk
Large and Mid-size Business Division
LM:PFTG
Mint Building. 3rd Floor M-3-321
1111 Constitution Avenue NW
Washington, DC 20224
Alternatively, submissions may be
faxed to 202-283-8427 or e-mailed to
pftg2@irs.gov.
4. ADDITIONAL INFORMATION
ABOUT THE PROGRAM
Project staffing. The IRS and Treasury
intend to staff each project with a team
2000–52 I.R.B.599December 26, 2000
Part III. Administrative, Procedural, and Miscellaneous

(the IIR team) that will analyze such in-
formation as may be appropriate and pro-
pose a resolution. This resolution will re-
quire the approval of those officials
normally responsible for approving the
type of guidance to be issued.
An IIR team will be composed of ap-
propriate personnel from the IRS field,
the IRS Office of Chief Counsel, Appeals,
the LMSB Office of Pre-filing and Tech-
nical Guidance, and the Treasury Office
of Tax Policy. A Technical Advisor (for-
mally referred to as an Industry Special-
ist) also may be a team member. In some
circumstances, the IRS may find it neces-
sary to hire outside experts.
Communication with requesting tax-
payer or group and other interested par-
ties. As part of its efforts to formulate a
recommendation for a resolution position,
the IIR team may meet with the submit-
ting taxpayer or group, and possibly with
other interested parties. It is anticipated
that the submitting party and other inter-
ested parties will be given the opportunity
to present factual data and legal analysis.
The IIR team may seek additional factual
development or legal analysis from the
submitting party or other sources.
Any solicitation of input from affected
persons will be done within the require-
ments of the Federal Advisory Committee
Act (FACA). The IRS does not intend to
form advisory committees during this
process. Input is welcome from interested
parties, but they will not be invited to enter
into negotiations or to participate in the
decision-making process with respect to
the proposed resolution of the issue.
Potential inspection of books and
records. An IIR team may consider the in-
spection of an individual taxpayer’s
records desirable as part of the factual re-
search necessary to develop its position.
Although a team may request such inspec-
tion, any such inspection will be volun-
tary. Any inspection of a taxpayer’s
records under this program, whether at the
initiative of the taxpayer or the team, will
not preclude or impede (under section
7605(b) of the Internal Revenue Code or
any IRS administrative provisions) a later
examination or inspection of records with
respect to any tax year, nor subject the IRS
to any procedural restrictions (such as
providing notice under section 7605(b))
that otherwise might apply before begin-
ning such examination or inspection.
Disclosure of information provided by
interested parties. Interested parties are
encouraged to provide whatever informa-
tion is necessary to permit the IRS and
Treasury to reach an appropriate resolu-
tion of an issue. However, this informa-
tion may be subject to disclosure under
the Freedom of Information Act (FOIA).
5. COMMENTS
The IRS invites interested persons to
comment and provide feedback on this
program. Comments should be sent to the
address provided in section 3 of this No-
tice.
6. FURTHER INFORMATION
For further information regarding this
Notice, contact Richard Druk of the
LMSB Pre-filing and Technical Guidance
Office at (202) 283-8387 (not a toll-free
number).
2001 Limitations Adjusted as
Provided in Section 415(d),
Etc.
1
Notice 2000–66
Section 415 of the Internal Revenue
Code (the Code) provides for dollar limi-
tations on benefits and contributions
under qualified retirement plans. Section
415 also requires that the Commissioner
annually adjust these limits for
cost-of-living increases. Other limitations
applicable to qualified retirement plans,
other deferred compensation plans, and
fringe benefits are also affected by these
adjustments.
Effective January 1, 2001, the limita-
tion for the annual benefit under
§ 415(b)(1)(A) for a defined benefit plan
is increased from $135,000 to $140,000.
For participants who separated from ser-
vice before January 1, 2001, the limitation
for defined benefit plans under
§ 415(b)(1)(B) is computed by multiply-
ing the participant’s compensation limita-
tion, as adjusted through 2000 by 1.0351.
The limitation for defined contribution
plans under § 415(c)(1)(A) is increased
from $30,000 to $35,000.
The Code provides that various other
dollar amounts are to be adjusted at the
same time and in the same manner as the
dollar limitation of § 415(b)(1)(A) is ad-
justed. These dollar amounts and the ad-
justed amounts are as follows:
The limitation under § 402(g)(1) on the
exclusion for elective deferrals described
in § 402(g)(3) remains unchanged at
$10,500. This limitation affects elective
deferrals to § 401(k) plans and to the fed-
eral government’s Thrift Savings Plan,
among other plans.
The dollar amount under
§ 409(o)(1)–(C)(ii) for determining the
maximum account balance in an em-
ployee stock ownership plan subject to a
5-year distribution period is increased
from $755,000 to $780,000, while the
dollar amount used to determine the
lengthening of the 5-year distribution pe-
riod is increased from $150,000 to
$155,000.
The limitation used in the definition of
a highly compensated employee under
§ 414(q)(1)(B) remains unchanged at
$85,000.
The annual compensation limit under
§§ 401(a)(17) and 404(l) remains un-
changed at $170,000. The annual com-
pensation limit under § 401(a)(17) for eli-
gible participants in certain governmental
plans that, under the plan as in effect on
July 1, 1993, allowed cost-of-living ad-
justments to the compensation limitation
under the plan under § 401(a)(17) to be
taken into account, is increased from
$275,000 to $285,000.
The compensation amount under
§ 408(k)(2)(C) regarding simplified em-
ployee pension plans (SEPs) remains un-
changed at $450. The compensation
amount under § 408(k)(3)(C) for SEPs re-
mains unchanged at $170,000.
The limitation under § 408(p)(2)(A) re-
garding simple retirement accounts is in-
creased from $6,000 to $6,500.
The limitation on deferrals under
§ 457(b)(2) and (c)(1) concerning eligible
deferred compensation plans of state and
local governments and of tax-exempt or-
ganizations is increased from $8,000 to
$8,500.
The compensation amount under
§ 1.61–21(f)(5)(i) of the Income Tax Reg-
ulations concerning the definition of
“control employee” for fringe benefit val-
uation purposes remains unchanged at
December 26, 20006002000–52 I.R.B.
1
Based on News Release IR-2000-82, dated
November 20, 2000.

$75,000. The compensation amount
under § 1.61–21(f)(5)(iii) is increased
from $150,000 to $155,000.
Administrators of defined benefit or de-
fined contribution plans that have received
favorable determination letters should not
request new determination letters solely
because of yearly amendments to adjust
maximum limitations in the plans.
26 CFR 601.201: Rulings and determination letters.
(Also Part I, §§ 162, 167, 197, 446, 481; 1.162–11,
1.167(a)–14, 1.197–2, 1.446–1.)
REV. PROC. 2000–50
SECTION 1. PURPOSE
This revenue procedure provides guide-
lines on the treatment of the costs of com-
puter software.
SECTION 2. DEFINITION
For the purpose of this revenue procedure,
“computer software” is any program or rou-
tine (that is, any sequence of machine-read-
able code) that is designed to cause a com-
puter to perform a desired function or set of
functions, and the documentation required to
describe and maintain that program or rou-
tine. It includes all forms and media in
which the software is contained, whether
written, magnetic, or otherwise. Computer
programs of all classes, for example, operat-
ing systems, executive systems, monitors,
compilers and translators, assembly routines,
and utility programs as well as application
programs, are included. Computer software
also includes any incidental and ancillary
rights that are necessary to effect the acquisi-
tion of the title to, the ownership of, or the
right to use the computer software, and that
are used only in connection with that spe-
cific computer software. Computer software
does not include any data or information
base described in § 1.197–2(b)(4) of the In-
come Tax Regulations (for example, data
files, customer lists, or client files) unless the
data base or item is in the public domain and
is incidental to a computer program. Nor
does it include any cost of procedures that
are external to the computer’s operation.
SECTION 3. BACKGROUND
.01 In the preamble to the final regula-
tions issued January 25, 2000, under
§§ 167(f) and 197 of the Internal Revenue
Code (T.D. 8865, 2000–7 I.R.B. 589), the
Internal Revenue Service advised taxpay-
ers that they may not rely on the proce-
dures in Rev. Proc. 69–21, 1969–2 C.B.
303, to the extent the procedures are in-
consistent with § 167(f) or § 197, or the
final regulations thereunder.
.02 Except as otherwise expressly pro-
vided, §§ 446(e) and 1.446–1(e) provide
that a taxpayer must obtain the consent of
the Commissioner of Internal Revenue
before changing a method of accounting
for federal income tax purposes. Section
1.446–1(e)(3)(ii) authorizes the Commis-
sioner to prescribe administrative proce-
dures setting forth the limitations, terms,
and conditions deemed necessary to per-
mit a taxpayer to obtain consent to change
a method of accounting.
SECTION 4. SCOPE
This revenue procedure applies to all
costs of computer software as defined in
section 2 of this revenue procedure. This
revenue procedure does not apply to any
computer software that is subject to amor-
tization as an “amortizable section 197 in-
tangible” as defined in § 197(c) and the
regulations thereunder, or to costs that a
taxpayer has treated as a research and ex-
perimentation expenditure under § 174.
SECTION 5. COSTS OF DEVELOPING
COMPUTER SOFTWARE
.01 The costs of developing computer
software (whether or not the particular
software is patented or copyrighted) in
many respects so closely resemble the
kind of research and experimental expen-
ditures that fall within the purview of
§ 174 as to warrant similar accounting
treatment. Accordingly, the Service will
not disturb a taxpayer’s treatment of costs
paid or incurred in developing software
for any particular project, either for the
taxpayer’s own use or to be held by the
taxpayer for sale or lease to others, where:
(1) All of the costs properly attribut-
able to the development of software by
the taxpayer are consistently treated as
current expenses and deducted in full in
accordance with rules similar to those ap-
plicable under § 174(a); or
(2) All of the costs properly attribut-
able to the development of software by
the taxpayer are consistently treated as
capital expenditures that are recoverable
through deductions for ratable amortiza-
tion, in accordance with rules similar to
those provided by § 174(b) and the regu-
lations thereunder, over a period of 60
months from the date of completion of the
development or, in accordance with rules
provided in § 167(f)(1) and the regula-
tions thereunder, over 36 months from the
date the software is placed in service.
SECTION 6. COSTS OF ACQUIRED
COMPUTER SOFTWARE
.01 With respect to costs of acquired
computer software, the Service will not
disturb the taxpayer’s treatment of:
(1) Costs that are included, without
being separately stated, in the cost of the
hardware (computer) if the costs are con-
sistently treated as a part of the cost of the
hardware that is capitalized and depreci-
ated; or
(2) Costs that are separately stated if
the costs are consistently treated as capital
expenditures for an intangible asset the
cost of which is to be recovered by amor-
tization deductions ratably over a period
of 36 months beginning with the month
the software is placed in service, in accor-
dance with the rules under § 167(f)(1).
See§ 1.167(a)–14(b)(1).
SECTION 7. LEASED OR LICENSED
COMPUTER SOFTWARE
Where a taxpayer leases or licenses
computer software for use in the tax-
payer’s trade or business, the Service will
not disturb a deduction properly allow-
able under the provisions of § 1.162–11
as rental. However, an amount described
in § 1.162–11 is not currently deductible
if, without regard to § 1.162–11, the
amount is properly chargeable to capital
account. See§ 1.197–2(a)(3).
SECTION 8. APPLICATION
.01 A change in a taxpayer’s treatment of
costs paid or incurred to develop, purchase,
lease, or license computer software to a
method described in section 5, 6, or 7 of
this revenue procedure is a change in
method of accounting to which §§ 446 and
481 apply. However, a change in useful life
under the method described in section
5.01(2) or 6.01(2) of this revenue procedure
is not a change in method of accounting.
Section 1.446–1(e)(2)(ii)(b).
2000–52 I.R.B.601December 26, 2000

.02 A taxpayer that wants to change the
taxpayer’s method of accounting under
this revenue procedure must follow the
automatic change in method of account-
ing provisions in Rev. Proc. 99–49,
1999–2 C.B. 725 (or its successor), with
the following modifications:
(1) In order to assist the Service in
processing changes in method of account-
ing under this section and to ensure
proper handling, section 6.02(3)(a) of
Rev. Proc. 99–49 is modified to require
that a Form 3115, Application for Change
in Accounting Method, filed under this
section include the statement: “Automatic
Change Filed Under Section 8.01 of Rev.
Proc. 2000–50.” This statement must be
legibly printed or typed at the top of any
Form 3115 filed under this revenue proce-
dure.
(2) If a taxpayer is changing to the
method described in section 5.01(2) of
this revenue procedure, the taxpayer must
attach a statement to the Form 3115 stat-
ing whether the taxpayer is choosing the
60-month period from the date of comple-
tion of the development of the software,
or the 36-month period from the placed-
in-service date of the software.
.03 For taxable years ending on or after
December 1, 2000, the Service will not
disturb the taxpayer’s treatment of costs
of computer software that are handled in
accordance with the practices described in
this revenue procedure.
.04 For taxable years ending prior to
December 1, 2000, the Service will not
disturb the taxpayer’s treatment of costs
of computer software except to the extent
that the taxpayer’s treatment is markedly
inconsistent with the practices described
in this revenue procedure. For the pur-
pose of applying the preceding sentence
to costs described in section 5 of this rev-
enue procedure, the absence of any formal
election similar to that required by
§ 174 or the amortization of capitalized
software costs over a period shorter than
the 5-year period specified in § 174(b)
(but not less than 36 months for costs paid
or incurred after August 10, 1993, or, if a
valid retroactive election has been made
under § 1.197–1T, July 25, 1991) will not
characterize the taxpayer’s treatment of
the costs as markedly inconsistent with
the principles of this revenue procedure.
In addition, the amortization of acquired
software described in section 6 of this
revenue procedure treated as an intangible
asset over a period of 60 months or less,
but in no case less than 36 months for
costs paid or incurred after August 10,
1993 (or after July 25, 1991, if a valid
retroactive election has been made under
§ 1.197–1T) will not characterize the tax-
payer’s treatment of these costs as
markedly inconsistent with the principles
of this revenue procedure.
SECTION 9. EFFECT ON OTHER
DOCUMENTS
.01 Rev. Proc. 69–21, 1969–1 C.B. 303,
is superseded.
.02 Rev. Proc. 97–50, 1997–2 C.B. 525,
is modified by deleting all references to
Rev. Proc. 69–21 and replacing them with
references to this revenue procedure.
Section 3 of Rev. Proc. 97–50 is modified
by deleting references to section 3, sec-
tion 4, and section 5 of Rev. Proc. 69–21,
and replacing them with references to sec-
tion 5, section 6, and section 7 of this rev-
enue procedure.
.03 Rev. Proc. 99–49 is modified and
amplified to include this accounting
method change in the APPENDIX.
.04 Section 1.02 of the APPENDIX of
Rev. Proc. 99–49 is modified by deleting
all references to Rev. Proc. 69–21 and re-
placing them with references to this rev-
enue procedure.
SECTION 10. EFFECTIVE DATE
This revenue procedure is effective for
a Form 3115 filed on or after December 1,
2000, for taxable years ending on or after
December 1, 2000. The Service will re-
turn any Form 3115 that is filed on or
after December 1, 2000, for taxable years
ending on or after December 1, 2000, if
the Form 3115 is filed with the national
office pursuant to the Code, regulations,
or administrative guidance other than this
revenue procedure and the change in
method of accounting is within the scope
of this revenue procedure.
DRAFTING INFORMATION
The principal author of this revenue
procedure is John Huffman of the Office
of the Associate Chief Counsel
(Passthroughs & Special Industries). For
further information regarding this revenue
procedure, contact Mr. Huffman at (202)
622-3110 (not a toll-free call).
Social Security Contribution and
Benefit Base for 2001
Under authority contained in the Social
Security Act (“the Act”), the Commis-
sioner, Social Security Administration,
has determined and announced (65 F.R.
63663, dated October 24, 2000) that the
contribution and benefit base for remuner-
ation paid in 2001, and self-employment
income earned in taxable years beginning
in 2001 is $80,400.
“Old-Law” Contribution and Benefit
Base
General
The “old-law” contribution and benefit
base for 2001 is $59,700. This is the base
that would have been effective under the
Act without the enactment of the 1977
amendments. We compute the base under
section 230(b) of the Act as it read prior to
the 1977 amendments.
The “old-law” contribution and benefit
base is used by:
(a) The Railroad Retirement pro-
gram to determine certain tax liabilities
and tier II benefits payable under that pro-
gram to supplement the tier I payments
which correspond to basic Social Security
benefits,
(b) The Pension Benefit Guaranty
Corporation to determine the maximum
amount of pension guaranteed under the
Employee Retirement Income Security
Act (as stated in section 230(d) of the So-
cial Security Act),
(c) Social Security to determine a
year of coverage in computing the special
minimum benefit, as described earlier,
and
(d) Social Security to determine a
year of coverage (acquired whenever
earnings equal or exceed 25 percent of the
“old-law’’ base for this purpose only) in
computing benefits for persons who are
also eligible to receive pensions based on
employment not covered under section
210 of the Act.
Domestic Employee Coverage
Threshold
General
Section 2 of the “Social Security Do-
mestic Employment Reform Act of 1994’’
(Pub. L. 103–387) increased the threshold
for coverage of a domestic employee’s
December 26, 20006022000–52 I.R.B.

wages paid per employer from $50 per
calendar quarter to $1,000 per annum in
calendar year 1994. The statute held the
coverage threshold at the $1,000 level for
1995 and then increased the threshold in
$100 increments for years after 1995.
Section 3121(x) of the Internal Revenue
Code provides the formula for increasing
the threshold.
Computation
Under the formula, the domestic em-
ployee coverage threshold amount for
2001 shall be equal to the 1995 amount
of $1,000 multiplied by the ratio of the
national average wage index for 1999 to
that for 1993. If the resulting amount is
not a multiple of $100, it shall be
rounded to the next lower multiple of
$100.
Domestic Employee Coverage Threshold
Amount
The ratio of the national average wage
index for 1999, $30,469.84, compared to
that for 1993, $23,132.67, is 1.3171778.
Multiplying the 1995 domestic em-
ployee coverage threshold amount of
$1,000 by the ratio of 1.3171778 pro-
duces the amount of $1,317.18, which
must then be rounded to $1,300. Ac-
cordingly, the domestic employee cover-
age threshold amount is $1,300 for
2001.
(Filed by the Office of the Federal Register on Octo-
ber 23, 2000, 8:45 a.m., and published in the issue of
the Federal Register for October 24, 2000, 65 F.R.
63663)
2000–52 I.R.B.603December 26, 2000

December 26, 20006042000–52 I.R.B.
Notice of Proposed Rulemaking
by Cross-Reference to
Temporary Regulations
Federal Employment Tax
Deposits—De MinimisRule
REG–114423–00
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of proposed rulemaking
by cross-reference to temporary regula-
tions.
SUMMARY: These proposed regulations
affect taxpayers required to make deposits
of Federal employment taxes. This docu-
ment contains proposed regulations which
change the de minimisdeposit rule for
quarterly and annual return periods.
In T.D. 8909 on page 596, the IRS is is-
suing temporary regulations relating to the
deposit of Federal employment taxes. The
text of those regulations also serves as the
text of these proposed regulations.
DATES: Written or electronically gener-
ated comments and requests for a public
hearing must be received by Tuesday,
March 6, 2001.
ADDRESSES: Send submissions to:
CC:M&SP:RU (REG–114423–00), room
5226, Internal Revenue Service, POB 7604,
Ben Franklin Station, Washington, DC
20044. Submissions may be hand deliv-
ered Monday through Friday between the
hours of 8 a.m. and 5 p.m. to:
CC:M&SP:RU (REG–114423–00),
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.gov/tax_regs/regslist.html.
FOR FURTHER INFORMATION CON-
TACT: Concerning the proposed regula-
tions, Brinton T. Warren, (202) 622-4940;
concerning submissions of comments and
requests for a public hearing, Treena Gar-
rett of the Regulations Unit at (202) 622-
7180 (not toll-free numbers).
SUPPLEMENTARY INFORMATION:
Background and Explanation of
Provisions
Temporary regulations in T.D. 8909
amend the Employment Tax and Collection
of Income Tax at Source Regulations (26
CFR part 31) relating to section 6302. The
temporary regulations change the de min-
imisrule for the deposit of Federal employ-
ment taxes. The text of those regulations
also serves as the text of these proposed
regulations. The preamble to the temporary
regulations explains the amendments.
Special Analyses
It has been determined that this notice of
proposed rulemaking is not a significant
regulatory action as defined in Executive
Order 12866. Therefore, a regulatory as-
sessment is not required. It also has been
determined that section 553(b) of the Ad-
ministrative Procedure Act (5 U.S.C. chap-
ter 5) does not apply to these regulations,
and, because these regulations do not im-
pose a collection of information on small
entities, the Regulatory Flexibility Act (5
U.S.C. chapter 6) does not apply. Pursuant
to section 7805(f) of the Internal Revenue
Code, this notice of proposed rulemaking
will be submitted to the Chief Counsel for
Advocacy of the Small Business Adminis-
tration for comment on their impact.
Comments and Requests for a Public
Hearing
Before these proposed regulations are
adopted as final regulations, consideration
will be given to any written (a signed origi-
nal and 8 copies) and electronic comments
that are submitted timely to the IRS. The
IRS and Treasury specifically request com-
ments on the clarity of the proposed regula-
tions and how they can be made easier to
understand. All comments will be available
for public inspection and copying. A public
hearing will be scheduled if requested in
writing by any person that timely submits
comments. If a public hearing is sched-
uled, notice of the date, time, and place for
the public hearing will be published in the
Federal Register.
Drafting Information
The principal author of the regulations
is Brinton T. Warren of the Office of As-
sociate Chief Counsel, Procedure and Ad-
ministration (Administrative Provisions
and Judicial Practice Division). However,
other personnel from the IRS and Trea-
sury Department participated in their de-
velopment.
* * * * *
Proposed Amendments to the
Regulations
Accordingly, 26 CFR part 31 is pro-
posed to be amended as follows:
PART 31—EMPLOYMENT TAXES
AND COLLECTION OF INCOME
TAX AT SOURCE
Paragraph 1. The authority citation for
part 31 continues to read in part as fol-
lows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. In §31.6302–1, paragraph (f)(4)
is revised to read as follows:
§31.6302–1 Federal tax deposit rules for
withheld income taxes and taxes under
the Federal Insurance Contributions Act
(FICA) attributable to payments made
after December 31, 1992.
* * * * *
(f) * * *
(4) [The text of proposed
§31.6302–1(f)(4) is the same as the text
of §31.6302–1T(f)(4)].
* * * * *
Charles O. Rossotti,
Commissioner of Internal Revenue.
(Filed by the Office of the Federal Register on De-
cember 5, 2000, 8:45 a.m., and published in the
issue of the Federal Register for December 6, 2000,
65 F.R. 76194)
Form 1065 Electronic Filing
Waiver Request Procedures
Announcement 2000–101
Section 6011(e) of the Internal Rev-
enue Code and section 301.6011–3(a) of
the Regulations on Procedure and Admin-
istration require partnerships with more
than 100 partners to file their partnership
returns (Form 1065 series) on magnetic
media. The regulations define “magnetic
Part IV. Items of General Interest

media” to include electronic filing, if
electronic filing is required by the Internal
Revenue Service (Service).
Beginning with taxable years ending on
or after December 31, 2000, the Service
will require partnerships with more than
100 partners to file their partnership re-
turns electronically. IRS Publication
1524 contains instructions for filing part-
nership returns electronically, and ex-
cludes certain partnerships from the elec-
tronic filing requirement. For Tax Year
2000, the IRS has excluded Partnerships
with the following type of returns from
the electronic filing requirement:
1) fiscal year filers
2) final year tax returns
3) short year returns
4) foreign address partnerships
5) delinquent and amended returns
For a detailed list of the exclusions,
refer to Publication 1524.
Section 301.6011–3(b) of the regula-
tions permits the Commissioner of Inter-
nal Revenue to waive the electronic filing
requirement if the partnership demon-
strates that a hardship would result if it
were required to file its return electroni-
cally. The regulations require partner-
ships seeking a waiver to request one in
the manner prescribed by the Service.
To request a waiver for the taxable year
ending December 31, 2000, partnerships
must file a written request containing the
following information:
(1) A notation at the top of the request
stating, in large letters,“Waiver Request:
IRC Section 6011(e)(2)”;
(2) The name, federal tax identification
number, and mailing address of the part-
nership;
(3) The taxable year for which the waiver
is requested;
(4) A detailed statement which lists:
a) what steps the partnership has
taken in an attempt to meet its re-
quirement to file its return elec-
tronically,
b) why the steps were unsuccessful,
c) the hardship that would result, in-
cluding any incremental cost to the
partnership of complying with the
electronic filing requirements. In-
cremental costs are those costs that
are above and beyond the costs to
file on paper.
(5) A statement as to what steps the part-
nership will take to assure its ability to
electronically file its partnership return
for the next tax year.
(6) A statement (signed by the Tax Mat-
ters Partner, as defined in section
6231(a)(7) of the Code) indicating:
“Under penalties of perjury, I declare
that the information contained in this
waiver request is true, correct and com-
plete to the best of my knowledge and be-
lief.”
All requests for waiver must be filed
with the Memphis Submission Processing
Center during one of the following peri-
ods:
1) For returns due April 16, 2001 (Form
8736 not filed); January 2, 2001 to
February 2, 2001,
2) For returns due July 16, 2001 (Form
8736 filed); February 3, 2001 to May
1, 2001,
3) For returns due October 15, 2001
(Form 8800 filed and approved); May
2, 2001 to August 1, 2001.
Requests from the partnership’s tax ad-
visor/preparer must be accompanied by a
valid power of attorney. The address for
the Memphis Submission Processing
Center is:
Internal Revenue Service
P.O. Box 420
Memphis, TN 38101-0420
(Note: Do not attach the waiver request
to the partnership’s paper tax return.
Also, do not file extension requests
with the waiver.)
The Service will approve or deny
waiver requests based on the facts and
circumstances of each request. In deter-
mining whether to approve or deny a
waiver request, the Service will con-
sider the ability of the partnership to file
its return electronically without incur-
ring an undue economic hardship.
Within 30 days after receipt of the
waiver request, the Service will send a
letter to the partnership either approv-
ing or denying the request for waiver.
Partnerships may not appeal a denial of
a waiver request. However, partner-
ships may request a waiver of any
penalty imposed by the Service for fail-
ing to file their partnership returns elec-
tronically. For further information re-
garding penalty waivers, see IRS Notice
746.
For questions concerning a request for
waiver, contact the Memphis Submission
Processing Center at 901-546-2690 (not a
toll free call).
1999 AOD Footnotes; Correction
Announcement 2000–102
This document contains corrections to
the footnotes for the Actions on Court De-
cisions published in Internal Revenue
Bulletin 1999–40 on the page following
the Introduction and in 1999–2 C.B. xvi.
The correct text for these footnotes is as
follows:
James J. and Sandra A. Gales v. Com-
missioner,
1
T.C. Memo. 1999–27
Dubin v. Commissioner,
2
99 T.C. 325
(1992)
2000–52 I.R.B.605December 26, 2000
1
This AOD reflects the Service’s acquiescence as to
whether advance commissions received on insurance
written by taxpayer husband were income at the time
paid or were loans such that income was reportable
only as the commissions were subsequently earned.
2
This AOD reflects the Service’s acquiescence as to
whether partnership items reported on a joint return
convert to nonpartnership items with respect to both
spouses when a TEFRA conversion event, pursuant
to I.R.C. § 6231, occurs as to only one spouse.

December 26, 2000i2000–52 I.R.B.
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”)
that have an effect on previous rulings
use the following defined terms to de-
scribe the effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus,
if an earlier ruling held that a principle
applied to A, and the new ruling holds
that the same principle also applies to B,
the earlier ruling is amplified. (Compare
with modified, below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously
published ruling and points out an essen-
tial difference between them.
Modified is used where the substance
of a previously published position is
being changed. Thus, if a prior ruling
held that a principle applied to A but not
to B, and the new ruling holds that it ap-
plies to both A and B, the prior ruling is
modified because it corrects a published
position. (Compare with amplified and
clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used
in a ruling that lists previously published
rulings that are obsoleted because of
changes in law or regulations. A ruling
may also be obsoleted because the sub-
stance has been included in regulations
subsequently adopted.
Revoked describes situations where the
position in the previously published rul-
ing is not correct and the correct position
is being stated in the new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a pe-
riod of time in separate rulings. If the
new ruling does more than restate the
substance of a prior ruling, a combination
of terms is used. For example,modified
and superseded describes a situation
where the substance of a previously pub-
lished ruling is being changed in part and
is continued without change in part and it
is desired to restate the valid portion of
the previously published ruling in a new
ruling that is self contained. In this case
the previously published ruling is first
modified and then, as modified, is super-
seded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and
that list is expanded by adding further
names in subsequent rulings. After the
original ruling has been supplemented
several times, a new ruling may be pub-
lished that includes the list in the original
ruling and the additions, and supersedes
all prior rulings in the series.
Suspended is used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current use and for-
merly used will appear in material published in the
Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions 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 Procedural 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

2000–52 I.R.B.iiDecember 26, 2000
Numerical Finding List
1
Bulletins 2000–27 through 2000–51
Announcements:
2000–57, 2000–28 I.R.B. 115
2000–58, 2000–30 I.R.B. 135
2000–59, 2000–29 I.R.B. 120
2000–60, 2000–31 I.R.B. 149
2000–61, 2000–30 I.R.B. 136
2000–62, 2000–30 I.R.B. 137
2000–63, 2000–31 I.R.B. 149
2000–64, 2000–31 I.R.B. 149
2000–65, 2000–31 I.R.B. 150
2000–66, 2000–32 I.R.B. 160
2000–67, 2000–32 I.R.B. 160
2000–68, 2000–32 I.R.B. 161
2000–69, 2000–33 I.R.B. 183
2000–70, 2000–34 I.R.B. 204
2000–71, 2000–44 I.R.B. 456
2000–72, 2000–35 I.R.B. 226
2000–73, 2000–35 I.R.B. 230
2000–74, 2000–35 I.R.B. 230
2000–75, 2000–37 I.R.B. 268
2000–76, 2000–36 I.R.B. 260
2000–77, 2000–36 I.R.B. 260
2000–78, 2000–43 I.R.B. 428
2000–79, 2000–39 I.R.B. 303
2000–80, 2000–40 I.R.B. 320
2000–81, 2000–41 I.R.B. 348
2000–82, 2000–42 I.R.B. 385
2000–83, 2000–41 I.R.B. 348
2000–84, 2000–42 I.R.B. 385
2000–85, 2000–43 I.R.B. 429
2000–86, 2000–44 I.R.B. 456
2000–87, 2000–44 I.R.B. 457
2000–88, 2000–44 I.R.B. 460
2000–89, 2000–45 I.R.B. 467
2000–90, 2000–47 I.R.B. 515
2000–91, 2000–46 I.R.B. 484
2000–92, 2000–46 I.R.B.486
2000–93, 2000–46 I.R.B.487
2000–94, 2000–47 I.R.B.515
2000–95, 2000–48 I.R.B.556
2000–96, 2000–48 I.R.B.556
2000–97, 2000–48 I.R.B. 557
2000–98, 2000–50 I.R.B.584
2000–99, 2000–51 I.R.B.591
2000–100, 2000–51 I.R.B.591
Court Decisions:
2068, 2000–28 I.R.B. 109
Delegation Orders:
No. 5, 2000–51 I.R.B. 587
No. 264, 2000–51 I.R.B. 587
Notices:
2000–33, 2000–27 I.R.B. 97
2000–34, 2000–33 I.R.B. 172
2000–35, 2000–29 I.R.B. 118
2000–36, 2000–33 I.R.B. 173
2000–37, 2000–29 I.R.B. 118
2000–38, 2000–33 I.R.B. 174
2000–39, 2000–30 I.R.B. 132
2000–40, 2000–30 I.R.B. 134
2000–41, 2000–33 I.R.B. 177
2000–42, 2000–39 I.R.B. 302
2000–43, 2000–35 I.R.B. 209
Notices—Continued:
2000–44, 2000–36 I.R.B. 255
2000–45, 2000–36 I.R.B. 256
2000–46, 2000–37 I.R.B. 265
2000–47, 2000–46 I.R.B. 480
2000–48, 2000–37 I.R.B. 265
2000–49, 2000–37 I.R.B. 266
2000–50, 2000–38 I.R.B. 291
2000–51, 2000–38 I.R.B. 291
2000–52, 2000–38 I.R.B. 292
2000–53, 2000–38 I.R.B. 293
2000–54, 2000–42 I.R.B. 356
2000–55, 2000–43 I.R.B. 393
2000–56, 2000–43 I.R.B. 393
2000–57, 2000–43 I.R.B. 389
2000–58, 2000–47 I.R.B. 491
2000–59, 2000–48 I.R.B. 519
2000–60, 2000–49 I.R.B. 568
2000–61, 2000–49 I.R.B. 569
2000–62, 2000–51 I.R.B. 587
2000–63, 2000–51 I.R.B. 588
2000–64, 2000–51 I.R.B. 589
Proposed Regulations:
REG–209038–89, 2000–34 I.R.B. 191
REG–246249–96, 2000–44 I.R.B. 439
REG–105316–98, 2000–27 I.R.B. 98
REG–110311–98, 2000–36 I.R.B. 258
REG–103805–99, 2000–42 I.R.B. 376
REG–105235–99, 2000–44 I.R.B. 447
REG–116050–99, 2000–48 I.R.B. 520
REG–116495–99, 2000–33 I.R.B. 179
REG–103735–00, 2000–36 I.R.B. 258
REG–103736–00, 2000–36 I.R.B. 258
REG–106511–00, 2000–45 I.R.B. 465
REG–107279–00, 2000–51 I.R.B. 590
REG–108522–00, 2000–34 I.R.B. 187
REG–108553–00, 2000–44 I.R.B. 452
REG–112502–00, 2000–40 I.R.B. 316
REG–114697–00, 2000–43 I.R.B. 421
Railroad Retirement Quarterly Rate:
2000–28, I.R.B. 112
2000–29, I.R.B. 117
2000–42, I.R.B. 354
Revenue Procedures:
2000–28, 2000–27 I.R.B. 60
2000–29, 2000–28 I.R.B. 113
2000–30, 2000–28 I.R.B. 113
2000–31, 2000–31 I.R.B. 146
2000–32, 2000–33 I.R.B. 172
2000–33, 2000–36 I.R.B. 257
2000–34, 2000–34 I.R.B. 186
2000–35, 2000–35 I.R.B. 211
2000–36, 2000–37 I.R.B. 267
2000–37, 2000–40 I.R.B. 308
2000–38, 2000–40 I.R.B. 310
2000–39, 2000–41 I.R.B. 340
2000–40, 2000–42 I.R.B. 357
2000–41, 2000–42 I.R.B. 371
2000–42, 2000–43 I.R.B. 394
2000–43, 2000–43 I.R.B. 404
2000–44, 2000–43 I.R.B. 409
2000–45, 2000–43 I.R.B. 417
2000–46, 2000–44 I.R.B. 438
2000–47, 2000–46 I.R.B.482
2000–48, 2000–49 I.R.B.570
2000–49, 2000–47 I.R.B.491
Revenue Rulings:
2000–32, 2000–27 I.R.B. 1
2000–33, 2000–31 I.R.B. 142
2000–34, 2000–29 I.R.B. 116
2000–35, 2000–31 I.R.B. 138
2000–36, 2000–31 I.R.B. 140
2000–37, 2000–32 I.R.B. 156
2000–38, 2000–32 I.R.B. 157
2000–39, 2000–34 I.R.B. 184
2000–40, 2000–35 I.R.B. 208
2000–41, 2000–36 I.R.B. 248
2000–42, 2000–39 I.R.B. 297
2000–43, 2000–41 I.R.B. 333
2000–44, 2000–41 I.R.B. 336
2000–45, 2000–41 I.R.B. 337
2000–46, 2000–41 I.R.B. 334
2000–47, 2000–37 I.R.B. 264
2000–48, 2000–42 I.R.B. 349
2000–49, 2000–44 I.R.B. 430
2000–50, 2000–45 I.R.B. 462
2000–51, 2000–46 I.R.B.469
2000–52, 2000–48 I.R.B.516
2000–53, 2000–47 I.R.B.488
2000–54, 2000–49 I.R.B.566
2000–57, 2000–50 I.R.B.579
2000–58, 2000–50 I.R.B.578
Tax Conventions:
2000–46 I.R.B. 475
Treasury Decisions:
8886, 2000–27 I.R.B. 3
8888, 2000–27 I.R.B. 3
8889, 2000–30 I.R.B. 124
8890, 2000–30 I.R.B. 122
8891, 2000–32 I.R.B. 152
8892, 2000–32 I.R.B. 158
8893, 2000–31 I.R.B. 143
8894, 2000–33 I.R.B. 162
8895, 2000–40 I.R.B. 304
8896, 2000–36 I.R.B. 249
8897, 2000–36 I.R.B. 234
8898, 2000–38 I.R.B. 276
8899, 2000–38 I.R.B. 288
8900, 2000–38 I.R.B. 279
8901, 2000–38 I.R.B. 272
8902, 2000–41 I.R.B. 323
8903, 2000–42 I.R.B. 352
8904, 2000–42 I.R.B. 350
8905, 2000–44 I.R.B. 435
8906, 2000–46 I.R.B.470
8907, 2000–49 I.R.B.558
8908, 2000–51 I.R.B.585
1
A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 2000–1 through 2000–26
is in Internal Revenue Bulletin 2000–27, dated July
3, 2000.

December 26, 2000iii2000–52 I.R.B.
Finding List of Current Actions on
Previously Published Items
1
Bulletins 2000–27 through 2000–51
Notices:
87–76
Obsoleted by
T.D. 8897, 2000–36 I.R.B. 234
88–24
Obsoleted by
T.D. 8897, 2000–36 I.R.B. 234
88–86
Obsoleted by
T.D. 8897 (section V), 2000–36 I.R.B. 234
97–3
Modified by
Notice 2000–62, 2000–51 I.R.B. 587
97–4
Superseded by
Notice 2000–58, 2000–47 I.R.B. 491
98–7
Modified by
Notice 2000–62, 2000–51 I.R.B. 587
98–46
Modified by
Notice 2000–62, 2000–51 I.R.B. 587
98–54
Modified by
Notice 2000–62, 2000–51 I.R.B. 587
98–59
Modified by
Notice 2000–62, 2000–51 I.R.B. 587
99–37
Modified by
Notice 2000–62, 2000–51 I.R.B. 587
2000–48
Superseded by
Rev. Proc. 2000–39, 2000–41 I.R.B. 340
Proposed Regulations:
LR–97–79
Partial withdrawal by
REG–103805–99, 2000–42 I.R.B. 376
FI–42–90
Withdrawn by
Announcement 2000–63, 2000–31 I.R.B. 149
IA–38–93
Withdrawn by
Announcement 2000–68, 2000–32 I.R.B. 161
REG–107644–98
Corrected by
Announcement 2000–66, 2000–32 I.R.B. 160
REG–108522–00
Corrected by
Announcement 2000–85, 2000–43 I.R.B. 428
Revenue Procedures:
88–23
Superseded by
Rev. Proc. 2000–35, 2000–35 I.R.B. 211
98–50
Modified and superseded by
Rev. Proc. 2000–31, 2000–31 I.R.B. 146
98–51
Modified and superseded by
Rev. Proc. 2000–31, 2000–31 I.R.B. 146
99–18
Modified by
Rev. Proc. 2000–29, 2000–28 I.R.B. 113
99–34
Superseded by
Rev. Proc. 2000–28, 2000–27 I.R.B. 60
99–38
Superseded by
Rev. Proc. 2000–48, 2000–49 I.R.B. 570
99–49
Modified and amplified by
Rev. Proc. 2000–38, 2000–40 I.R.B. 310
2000–3
Amplified by
Rev. Proc. 2000–46, 2000–44 I.R.B. 438
Rev. Proc. 2000–47, 2000–46 I.R.B.482
2000–9
Superseded by
Rev. Proc. 2000–39, 2000–41 I.R.B. 340
Treasury Decisions:
8873
Corrected by
Announcement 2000–74, 2000–35 I.R.B. 230
8883
Corrected by
Announcement 2000–57, 2000–28 I.R.B. 115
8884
Corrected by
Announcement 2000–73, 2000–35 I.R.B. 230
8892
Corrected by
Announcement 2000–81, 2000–41 I.R.B. 348
1
A cumulative list of current actions on previously
published items in Internal Revenue Bulletins
2000–1 through 2000–26 is in Internal Revenue
Bulletin 2000–27, dated July 3, 2000.

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