us-irs-announcements-irb-1999-16-pdf•Internal Revenue Bulletin 1999-16 (PDF rendition): IRS Announcements
Internal Revenue Bulletin 1999-16 (PDF rendition): IRS Announcements
us-irs-announcements-irb-1999-16-pdfInternal Revenue Bulletin 1999-16 (PDF rendition): IRS AnnouncementsGuidance
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 Notice 99–18, page 4. Credit for producing fuel from a nonconventional source, section 29 inflation adjustment factor and ref- erence price.This notice publishes the nonconventional source fuel credit, the inflation adjustment factor, and the reference price under section 29 of the Code for calendar year 1998. This data is used to determine the credit allow- able on fuel produced from a nonconventional source. EMPLOYEE PLANS Rev. Proc. 99–23, page 5. Qualified plans; remedial amendment period.This pro- cedure extends the remedial amendment period under sec- tion 401(b) of the Code for amending qualified plans within the meaning of section 401(a) or 403(a) for changes in the qualification requirements made by the Small Business Job Protection Act of 1996 and other recent legislation. In addi- tion, this procedure extends the remedial amendment period for amending governmental and nonelecting church plans for the Tax Reform Act of 1986. Rev. Procs. 89–9, 89–13, sec- tion 13 of 93–39, 95–12, 97–41, and 98–14, modified. No- tices 92–36, 96–64, 98–39, 98–52, and 99–5, modified. EXEMPT ORGANIZATIONS Announcement 99–45, page 12. The Abraham Lincoln Opportunity Foundation, Pine Moun- tain, GA, no longer qualifies as an organization to which con- tributions are deductible under section 170 of the Code. EXCISE TAX Announcement 99–40, page 10. This announcement describes provisions that will be in- cluded in the final kerosene tax regulations. ADMINISTRATIVE Notice 99–19, page 4. Accounting periods; changes.This notice invites public comments on possible changes to published guidance con- cerning accounting period changes. Possible changes may include revising the criteria used to establish a substantial business purpose and allowing more automatic accounting period changes. Announcement 99–36, page 10. The Service will continue to publish the cumulative bulletin (CB) but in a new format. This decision was based on the re- sponses from taxpayers, tax practitioners, and government agencies to the Service’s proposal to discontinue the CB. Announcement 99–41, page 10. This document contains corrections to T.D. 8814, 1999–9 I.R.B. 4, that provides guidance as to when amounts de- ferred under or paid from a nonqualified deferred compensa- tion plan are taken into account as wages for purposes of the employment taxes imposed by the Federal Insurance Contributions Act (FICA). Announcement 99–42, page 11. This document contains corrections to T.D. 8770, 1998–27 I.R.B. 4, relating to certain transfers of stock or securities by U.S. persons to foreign corporations and related report- ing requirements. Announcement 99–43, page 11. This document contains corrections to T.D. 8817, 1999–8 I.R.B. 51, relating to certain transfers to foreign partner- ships and corporations by U.S. persons. Announcement 99–44, page 12. This document contains corrections to T.D. 8011, 1985–1 C.B. 397, relating to the displaying of OMB control numbers on IRS regulations that solicit or obtain information from the public. Announcement 99–46, page 13. This document contains corrections to Announcement 99–24, 1999–14 I.R.B. 12, in which proposed revisions to Form 1042-S were poorly reproduced. We are providing more legible copies of Form 1042-S, and we are extending the date for receiving comments to May 19, 1999. Internal Revenue bbuulllleettiinn Bulletin No. 1999–16 April 19, 1999 HIGHLIGHTS OF THIS ISSUE These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations. Department of the Treasury Internal Revenue Service Finding Lists begin on page 26. Announcement of Disbarments and Suspensions begins on page 21. The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing offi- cial rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It is published weekly and may be obtained from the Superintendent of Documents on a subscription basis. Bulletin contents are consolidated semiannually into Cumulative Bulletins, which are sold on a single-copy basis. It is the policy of the Service to publish in the Bulletin all sub- stantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless other- wise indicated. Procedures relating solely to matters of in- ternal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published. Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements. Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying pub- lished rulings and procedures, the effect of subsequent leg- islation, regulations, court decisions, rulings, and proce- dures must be considered, and Service personnel and oth- ers concerned are cautioned against reaching the same con- clusions in other cases unless the facts and circumstances are substantially the same. The Bulletin is divided into four parts as follows: Part I.—1986 Code. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1986. Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions, and Subpart B, Legislation and Related Committee Reports. Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Sub- parts. Also included in this part are Bank Secrecy Act Admin- istrative Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement). Part IV.—Items of General Interest. This part includes notices of proposed rulemakings, disbar- ment and suspension lists, and announcements. The first Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the first Bulletin of the succeeding semi- annual period, respectively. Mission of the Service Provide America’s taxpayers top quality service by help- ing them understand and meet their tax responsibilities and by applying the tax law with integrity and fairness to all. 2 Introduction The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate. For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402. Section 401.—Qualified Pension, Profit-Sharing and Stock Bonus Plans 26 CFR 1.401(b)–1: Certain retroactive changes in plan. A remedial amendment period for changes in plan qualification requirements made by the Small Business Job Protection Act of 1996 and other re- cent legislation is provided. See Rev. Proc. 99–23, page 5 1999–16 I.R.B.3April 19, 1999 Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 April 19, 199941999–16 I.R.B. Nonconventional Source Fuel Credit, § 29 Inflation Adjustment Factor, and § 29 Reference Price Notice 99–18 This notice publishes the nonconven- tional source fuel credit, inflation adjust- ment factor, and reference price under § 29 of the Internal Revenue Code for cal- endar year 1998. These are used to deter- mine the credit allowable on fuel pro- duced from a nonconventional source under § 29 of the Internal Revenue Code. The calendar year 1998 inflation-adjusted credit applies to the sales of barrel-of-oil equivalent of qualified fuels sold by a tax- payer to an unrelated person during the 1998 calendar year, the domestic produc- tion of which is attributable to the tax- payer. BACKGROUND Section 29(a) provides for a credit for producing fuel from a nonconventional source, measured in barrel-of-oil equiva- lent of qualified fuels, the production of which is attributable to the taxpayer and sold by the taxpayer to an unrelated per- son during the tax year. The credit is equal to the product of $3.00 and the ap- propriate inflation adjustment factor. Section 29(b)(1) and (2) provides for a phase out of the credit. The credit allow- able under § 29(a) must be reduced by an amount which bears the same ratio to the amount of the credit (determined without regard to § 29(b)(1)) as the amount by which the reference price for the calendar year in which the sale occurs exceeds $23.50 bears to $6.00. The $3.00 in § 29(a) and the $23.50 and $6.00 must each be adjusted by multiplying these amounts by the 1998 inflation adjustment factor. In the case of gas from a tight for- mation, the $3.00 amount in § 29(a) must not be adjusted. Section 29(c)(1) defines the term “qualified fuels” to include oil produced from shale and tar sands; gas produced from geopressurized brine, Devonian shale, coal seams, or a tight formation, or biomass; and liquid, gaseous, or solid synthetic fuels produced from coal (in- cluding lignite), including such fuels when used as feedstocks. Section 29(d)(1) provides that the credit is to be applied only for sale of qualified fuels the production of which is within the United States (within the meaning of § 638(1)) or a possession of the United States (within the meaning of § 638(2)). Section 29(d)(2)(A) requires that the Secretary, not later than April 1 of each calendar year, determine and publish in the Federal Register the inflation adjust- ment factor and the reference price for the preceding calendar year. Section 29(d)(2)(B) defines “inflation adjustment factor” for a calendar year as the fraction the numerator of which is the GNP implicit price deflator for the calen- dar year and the denominator of which is the GNP implicit price deflator for calen- dar year 1979. The term “GNP implicit price deflator” means the first version of the implicit price deflator for the gross na- tional product as computed and published by the Department of Commerce. Section 29(d)(2)(C) defines “reference price” to mean with respect to a calendar year the Secretary’s estimate of the annual average wellhead price per barrel of all domestic crude oil the price of which is not subject to regulation by the United States. Section 29(d)(3) provides that in the case of a property or facility in which more than one person has an interest, ex- cept to the extent provided by regulations prepared by the Secretary, production from the property or facility (as the case may be) must be allocated among the per- sons in proportion to their respective in- terests in the gross sales from the property or facility. Section 29(d)(5) and (6) provides that the term “barrel-of-oil equivalent” with respect to any fuel generally means that amount of the fuel which has a Btu con- tent of 5.8 million. INFLATION ADJUSTMENT FACTOR AND REFERENCE PRICE The inflation adjustment factor for cal- endar year 1998 is 2.0384. The reference price for calendar year 1998 is $10.88. As required by § 29(d)(2)(A), the inflation adjustment factor and reference price for calendar year 1998 will be published in the Federal Register on April 6, 1999. PHASE-OUT CALCULATION Because the calendar year 1998 refer- ence price does not exceed $23.50 multi- plied by the inflation adjustment factor, the phase out of the credit provided for in § 29(b)(1) does not occur for any quali- fied fuel sold in calendar year 1998. CREDIT AMOUNT The nonconventional source fuel credit under § 29(a) is $6.12 per barrel-of-oil equivalent of qualified fuels ($3.00 3 2.0284). This amount will be published in the Federal Register on April 6, 1999. DRAFTING INFORMATION CONTACT The principal author of this notice is Alan H. Cooper of the Office of Assistant Chief Counsel (Passthroughs and Special Industries). For further information re- garding this notice contact Alan H. Cooper at (202) 622-3110 (not a toll-free call). Accounting Period Guidance Notice 99–19 PURPOSE This notice invites public comment on possible changes to published guidance concerning accounting period changes. Among possible changes under considera- tion are: (1) revising the criteria used to es- tablish a substantial business purpose, in- cluding what constitutes a natural business year; and (2) allowing more accounting pe- riod changes to be made automatically. BACKGROUND Section 441 of the Internal Revenue Code provides that taxable income must be computed on the basis of the tax- payer’s taxable year. In general, the term “taxable year” means the taxpayer’s an- nual accounting period, which can be a calendar or fiscal year, or a period of less than 12 months for which a return is made Part III. Administrative, Procedural, and Miscellaneous (i.e.,a short period). The term “annual accounting period” means the annual pe- riod on the basis of which the taxpayer regularly computes its income in keeping its books. Special rules under the Code and Income Tax Regulations require par- ticular accounting periods for certain tax- payers such as domestic international sales corporations and foreign sales cor- porations (§ 441(h)), personal service cor- porations (§ 441(i)), certain trusts (§ 644), partnerships (§ 706), real estate invest- ment trusts (§ 859), real estate mortgage investment conduits (§ 860D(a)(5)), spec- ified foreign corporations (§ 898), S cor- porations (§ 1378), and members of affili- ated groups that file consolidated returns (Treas. Reg. § 1.1502–76). Section 442 provides that if a taxpayer changes its annual accounting period, the new accounting period becomes the tax- payer’s taxable year only if the change is approved by the Secretary. In addition, adoptions of fiscal years by certain tax- payers are treated as accounting period changes and thus can become the tax- payer’s taxable year only with the ap- proval of the Secretary. (See e.g., § 706(b)(1)(C)). Section 1.442–1(b) provides that ap- proval for an accounting period change will not be granted unless the taxpayer and the Commissioner agree to the terms, conditions, and adjustments under which the change will be effected. In general, a change of annual accounting period will be approved where the taxpayer estab- lishes a substantial business purpose for making the change. Under the Code and regulations, cer- tain taxpayers are allowed to change their annual accounting periods automatically without securing the prior approval of the Commissioner (see, e.g., § 859(b) and Treas. Reg. §§ 1.442-1(c), (d), and (e)). In addition, the Service has issued several revenue procedures, such as Rev. Proc. 92–13, 1992–1 C.B. 665; Rev. Proc. 87– 32, 1987–2 C.B. 396; and Rev. Proc. 66– 50, 1966–2 C.B. 1260, that enable taxpay- ers to obtain automatic approval of changes in their accounting periods, if specific conditions are satisfied. REQUEST FOR PUBLIC COMMENT The Service is considering what, if any, changes should be made in order to clar- ify and simplify published guidance con- cerning accounting period changes. Ac- cordingly, the Service and Treasury re- quest comments on possible changes to current accounting period guidance in- cluding, but not limited to, the following: (1) What changes should be made to the rules governing the approval of ac- counting period change requests? For ex- ample, what changes, if any, should be made to the substantial business purpose requirement? SeeTreas. Reg. § 1.442- 1(b)(1). How should deferral or shifting of income, or acceleration or shifting of deductions, (“deferral”) be considered in determining whether to approve an ac- counting period change request? For ex- ample, should safe harbors permitting de minimis deferral be established? If an ac- counting period change that creates defer- ral is permitted, what terms and condi- tions should apply to the change? Should all taxpayers, regardless of their form (e.g., corporation, partnership, S corpora- tion), be subject to the same criteria for approval? Should the rules for establish- ing a natural business year be revised, and if so, how? SeeRev. Proc. 74–33, 1974–2 C.B. 489. (2) How should the current automatic accounting period change procedures be organized, clarified, and simplified? See, e.g.,Treas. Reg. § 1.442–1, Rev. Proc. 92–13, Rev. Proc. 87–32, and Rev. Proc. 66–50. Should the Service provide proce- dures for automatic approval to change accounting periods in additional situa- tions? If so, what types of situations would warrant such automatic approval, and what, if any, terms and conditions should apply to such changes? Taxpayers may submit comments in writing to: Internal Revenue Service Attn: CC:DOM:CORP:R (Notice 99–19, Room 5226). P.O. Box 7604 Ben Franklin Station Washington, D.C. 20044 Alternatively, taxpayers may submit comments electronically at: http://www.irs.ustreas.gov/prod/cover. html (the IRS Internet site). All comments should be received by June 18, 1999. The comments submitted will be available for public inspection and copying. DRAFTING INFORMATION The principal author of this notice is Martin Scully of the Office of Assistant Chief Counsel (Income Tax and Account- ing). For further information regarding this notice contact Mr. Scully on (202) 622-4960 (not a toll-free call). 26 CFR 601.201: Rulings and determination letters (Also, Part I, section 401; 1.401(b)–1.) Rev. Proc. 99–23 SECTION 1. PURPOSE .01 This revenue procedure extends until the last day of the first plan year be- ginning on or after January 1, 2000, the remedial amendment period under § 401(b) of the Code for amending plans that are qualified under § 401(a) or § 403(a) for changes made by the Small Business Job Protection Act of 1996, Pub. L. 104–188 (“SBJPA”) and for other re- cent changes in the law. It also designates as a disqualifying provision for which this extended remedial amendment period is available any plan provision that causes a plan to fail to satisfy the qualification re- quirements of the Code because of the re- peal of the combined plan limitation under § 415(e) or that is integral to this re- pealed qualification requirement. The re- peal of § 415(e) is effective for limitation years beginning after December 31, 1999. .02 This revenue procedure provides that the extension of the remedial amend- ment period also applies: 1 to all disqualifying provisions of new plans adopted or effective after December 7, 1994, and all disqualifying provisions of existing plans arising from a plan amendment adopted after December 7, 1994; 2 to the deadline for adopting certain amendments relating to § 415(b)(2)(E); 3 to the deadline for adopting amend- ments of disqualifying provisions that are integral to a qualification requirement changed by a provision of SBJPA that be- came effective on the first day of the first plan year beginning after December 31, 1998; and 4 to the deadline for adopting amend- ments of disqualifying provisions that are integral to the requirements of § 401(a)- (31) to reflect the change made by 1999–16 I.R.B.5April 19, 1999 § 6005(c)(2) of the Internal Revenue Ser- vice Restructuring and Reform Act of 1998, Pub. L. 105–206 (“RRA 98”). .03 This revenue procedure also pro- vides that the extension of the remedial amendment period applies to the time for adopting amendments of defined benefit plans to provide that benefits will be de- termined in accordance with the applica- ble interest rate rules and applicable mor- tality table rules of § 1.417(e)–1(d) of the Income Tax Regulations. However, such a plan amendment must provide that, with respect to distributions with annuity start- ing dates that are on or after the effective date of the amendment but before the adoption date of the amendment, the dis- tribution will be the greater of the amount that would be determined under the plan without regard to the amendment and the amount determined under the plan with regard to the amendment. .04 This revenue procedure extends by one year the period of extended reliance for certain plans that received favorable determination, opinion, or notification let- ters under the Tax Reform Act of 1986, Pub. L. 99–514 (“TRA 86”). .05 Finally, this revenue procedure ex- tends the TRA 86 remedial amendment period for governmental and nonelecting church plans to the end of the remedial amendment period for SBJPA. This ex- tension ensures that no such plan need be submitted for a determination letter until the end of the SBJPA remedial amend- ment period. Sponsors of nonelecting church plans continue to have until the end of the 2001 plan year to adopt amend- ments relating to the nondiscrimination requirements. SECTION 2. BACKGROUND .01 In recent years, the following pub- lic laws have made changes affecting the requirements for qualification of pension, profit-sharing, and stock bonus plans under § 401(a) or § 403(a): 1 the Uruguay Round Agreements Act, Pub. L. 103–464 (“GATT”); 2 the Uniformed Services Employment and Reemployment Rights Act of 1994, Pub. L. 103–353 (“USERRA”); 3 SBJPA; 4 the Taxpayer Relief Act of 1997, Pub. L. 105–34 (“TRA 97”); and 5 RRA 98. .02 Rev. Proc. 97–41, 1997–33 I.R.B. 51, provided a remedial amendment pe- riod under § 401(b) with respect to certain amendments for GATT, SBJPA, and USERRA. The remedial amendment pe- riod that was provided under Rev. Proc. 97–41 generally permits plan amend- ments to be made retroactively effective if they are adopted before the end of the re- medial amendment period and they relate to GATT, SBJPA, and USERRA qualifi- cation changes that are effective before the first day of the first plan year begin- ning on or after January 1, 1999. Rev. Proc. 98–14, 1998–4 I.R.B. 22, provided that the remedial amendment period de- scribed in Rev. Proc. 97–41 will also apply to plan amendments that relate to TRA 97. For plans other than govern- mental plans, the remedial amendment period under Rev. Proc. 97–41 and Rev. Proc. 98–14 ends on the last day of the first plan year beginning on or after Janu- ary 1, 1999. For governmental plans, as defined in § 414(d), the remedial amend- ment period ends on the later of (i) the last day of the last plan year beginning be- fore January 1, 2001, or (ii) the last day of the first plan year beginning on or after the “1999 legislative date” (that is, the 90th day after the opening of the first leg- islative session beginning after Decem- ber 31, 1998, of the governing body with authority to amend the plan, if that body does not meet continuously). Those amendments that are required to be made to retain qualified status as a result of changes in the qualification requirements must be made retroactively effective as of the date on which the qualification change became effective with respect to the plan, and, in general, operational compliance prior to actual amendment is required. Those amendments that are not required but that amend plan provisions that are in- tegrally related to qualification changes may be made retroactively effective as of the first day on which the plan was oper- ated in accordance with the amended plan provision. .03 The remedial amendment period described in Rev. Proc. 97–41 also applies with respect to all disqualifying provi- sions of new plans adopted or effective after December 7, 1994, and with respect to all plan amendments adopted after De- cember 7, 1994, which would cause an existing plan to fail to be qualified. .04 The end of the remedial amend- ment period described in Rev. Proc. 97–41 is also the deadline for adopting plan amendments applying the changes under § 415(b)(2)(E). It is, likewise, the deadline for adopting a plan amendment repealing a pre-August 20, 1996, GATT plan amendment, thereby permitting the earlier plan amendment to be disregarded in applying § 767(d)(3)(A) of GATT, as modified by § 1449(a) of SBJPA. .05 Notice 98–52, 1998–46 I.R.B. 16, provided guidance on the nondiscrimina- tion safe harbor methods in § 401(k)(12) and § 401(m)(11). This notice designates as disqualifying provisions under § 401(b) plan provisions that are integral to a qualification requirement changed by a provision of SBJPA that becomes effec- tive on the first day of the first plan year beginning after December 31, 1998, pro- vided two conditions are satisfied. First, the plan provisions must generally be amended by no later than the last day of the first plan year beginning after Decem- ber 31, 1998. Second, the plan provi- sions, as amended, must be effective as of the first day of the first plan year begin- ning after December 31, 1998. Notice 98–52 also provides that a plan amend- ment that satisfies these conditions will not be treated as violating § 411(d)(6) merely because the plan amendment im- poses the withdrawal restrictions required by § 401(k)(12)(E)(i), provided that those withdrawal restrictions do not apply with respect to contributions allocated as of a date before the first day of the first plan year beginning after December 31, 1998. .06 Notice 99–5, 1999–3 I.R.B. 10, provided guidance relating to the excep- tion to the definition of eligible rollover distribution for certain hardship distribu- tions which was added to §§ 402(c)(4) and 403(b)(8)(B) by § 6005(c)(2)(A) and (B) of RRA 98. This definition is relevant in the application of the direct rollover re- quirements of § 401(a)(31). This notice designates as disqualifying provisions under § 401(b) plan provisions that are in- tegral to the requirements of § 401(a)(31), but only to the extent such provisions are amended to reflect the change made by § 6005(c)(2) of RRA 98, provided two conditions are satisfied. First, the plan provisions must generally be amended to reflect the change made by § 6005(c)(2) April 19, 199961999–16 I.R.B. of RRA 98 by no later than the last day of the first plan year beginning after Decem- ber 31, 1998. Second, the plan provi- sions, as amended, must be effective as of the first day the plan operates in accor- dance with the change made by § 6005(c)(2) of RRA 98. .07 Under § 417(e)(3), as amended by § 767 of the Retirement Protection Act of 1994 (“RPA 94,” which is part of GATT), and § 1.417(e)–1(d), a defined benefit plan must provide that the present value of any accrued benefit and the amount of any distribution must not be less than the amount calculated using the applicable in- terest rate described in § 1.417(e)–1(d)(3) and the applicable mortality table de- scribed in § 1.417(e)–1(d)(2). Prior to amendment by § 767 of RPA 94, § 417(e)- (3) required, instead of the applicable in- terest rate, an interest rate based on the rate that would be used by the Pension Benefit Guaranty Corporation (“PBGC”) for a trusteed single-employer plan to value the participant’s vested benefit (“PBGC rate”), and it did not impose any restrictions on the mortality table to be used. Section 767 of RPA 94 and § 1.417(e)–1(d) are generally effective for distributions with annuity starting dates in plan years beginning after December 31, 1994. However, § 417(e)(3)(B) provides a transition rule for plans adopted and in effect as of December 7, 1994 (“pre- GATT plans”). In general, under this rule, the present value of a distribution from a pre-GATT plan that is made before the earlier of (i) the first plan year beginning after December 31, 1999, or (ii) the later of the adoption or effective date of a plan amendment applying the changes made to § 417(e)(3) to the plan is to be determined under the plan’s pre-GATT terms. Thus, for pre-GATT plans, amendments apply- ing the changes to § 417(e)(3) to plan years beginning before January 1, 2000, could not be adopted retroactively, and these plans could not be operated in ac- cordance with the changes prior to plan amendment. .08 Section 767(d)(2) of RPA 94 pro- vides that a participant’s accrued benefit is not considered to be reduced in viola- tion of § 411(d)(6) merely because the benefit is determined in accordance with the applicable interest rate rules and the applicable mortality table rules of § 417(e)(3)(A), as amended by RPA 94. Section 1.417(e)–1(d)(10) explains the scope of relief from the requirements of § 411(d)(6). A plan amendment to comply with the applicable interest rate rules and the applicable mortality table rules of § 417(e)(3)(A), as amended by RPA 94, must apply to all distributions with annu- ity starting dates that occur in plan years beginning after December 31, 1999. .09 Section 1.401(b)–1T(c)(3) autho- rizes the Commissioner to impose limits and provide additional rules regarding the amendments that may be made within the remedial amendment period with respect to a plan provision that has been desig- nated by the Commissioner as a disquali- fying provision under § 401(b). .10 Under Rev. Proc. 89–9, 1989–1 C.B. 780, Rev. Proc. 89–13, 1989–1 C.B. 801 (both as modified by Rev. Proc. 93–9, 1993–1 C.B. 474), Rev. Proc. 93–39, 1993–2 C.B. 513, Announcement 94–85, 1994–26 I.R.B. 23, and Rev. Proc. 95–12, 1995–1 C.B. 508, plans that were submit- ted to the Service within certain deadlines for determination, opinion, or notification letters under TRA 86 and received favor- able letters are entitled to extended re- liance. The sponsor of a plan that is enti- tled to extended reliance on a favorable TRA 86 letter may rely on that letter until the earlier of the last day of the last plan year commencing prior to January 1, 1999, or the date established for plan amendment by any legislation that is ef- fective after the date of the plan’s letter. A plan with extended reliance must be amended by the last day of the first plan year beginning on or after January 1, 1999, to the extent necessary to comply with regulations or administrative guid- ance of general applicability that has been issued since the date of the plan’s favor- able TRA 86 letter. These amendments must be made effective no later than the first day of the first plan year beginning on or after January 1, 1999, and no earlier than the first day of the plan year in which the amendments are adopted. (But see Rev. Rul. 94–76, 1994–2 C.B. 46, and Rev. Rul. 96–47, 1996–2 C.B. 35.) .11 For nonelecting church plans, No- tice 98–39, 1998–33 I.R.B. 11, extended the remedial amendment period for plan amendments relating to regulations under §§ 401(a)(4), 401(a)(5), 401(l), and 414(s) (“TRA 86 remedial amendment period”) until the last day of the first plan year be- ginning on or after January 1, 2001. The remedial amendment period was not ex- tended for other amendments covered by the TRA 86 remedial amendment period, such as amendments required to satisfy the Omnibus Budget Reconciliation Act of 1993 (“OBRA 93”), the Unemployment Compensation Act of 1992 (“UCA”), or the changes to the law under TRA 86 other than changes to the nondiscrimination rules. Sponsors of nonelecting church plans were required by Notice 96–64, 1996–2 C.B. 229, to adopt amendments satisfying those changes in law by the last day of the first plan year beginning on or after January 1, 1999. .12 For governmental plans, Notice 96–64, citing Announcement 95–48, 1995–23 I.R.B. 13, provided that the TRA 86 remedial amendment period for plan amendments relating to regulations under §§ 401(a)(4), 401(a)(26), 401(k), 401(m), 410(b), and 414(s) was extended to the last day of the first plan year beginning on or after the later of January 1, 1999, or 90 days after the opening of the first legisla- tive session beginning on or after January 1, 1999 (“1999 legislative date”). This extension of the TRA 86 remedial amend- ment period for governmental plans ap- plied to all amendments relating to TRA 86, UCA, and OBRA 93, not just the nondiscrimination requirements. SECTION 3. EXTENSION OF REMEDIAL AMENDMENT PERIOD .01 The remedial amendment period described in Rev. Proc. 97–41 and Rev. Proc. 98–14, hereafter referred to as the “GUST” remedial amendment period, is, in the case of nongovernmental plans, hereby extended to the last day of the first plan year beginning on or after January 1, 2000. This extension does not alter the GUST remedial amendment period for governmental plans described in Rev. Proc. 98–14. .02 This extension also applies to the remedial amendment period with respect to disqualifying provisions of new plans adopted or effective after December 7, 1994, and with respect to plan amend- ments adopted after December 7, 1994, which would cause an existing plan to fail to be qualified. .03 This extension also extends the deadline for adopting plan amendments 1999–16 I.R.B.7April 19, 1999 applying the changes under § 415(b)- (2)(E) and the deadline for adopting a plan amendment repealing a pre-August 20, 1996, GATT plan amendment, thereby permitting the earlier plan amendment to be disregarded in applying § 767(d)(3)(A) of GATT, as modified by § 1449(a) of SBJPA. .04 The deadline, under Notice 98–52, for amending plan provisions that are in- tegral to a qualification requirement changed by a provision of SBJPA that be- comes effective on the first day of the first plan year beginning after December 31, 1998, is also extended to the end of the GUST remedial amendment period. In addition, the requirement, under Notice 98–52, that such plan provisions, as amended, must be effective as of the first day of the first plan year beginning after December 31, 1998, is eliminated. In- stead, such plan provisions, as amended, must be effective no earlier than the first day of the first plan year beginning after December 31, 1998. Thus, for example, an existing § 401(k) plan may be amended by the last day of the 2000 plan year, retroactive to the first day of that year (or to the first day of the 1999 plan year), to satisfy the safe harbors in § 401(k)(12) and § 401(m)(11) for the 2000 plan year (or for both the 1999 and 2000 plan years). Lastly, Notice 98–52 is modified to provide that a plan amend- ment that is made within the GUST reme- dial amendment period will not be treated as violating § 411(d)(6) merely because the plan amendment imposes the with- drawal restrictions required by § 401(k)- (12)(E)(i), but only if those withdrawal restrictions do not apply with respect to contributions allocated as of a date before the first day of the first plan year for which the plan satisfies the safe harbor. .05 The deadline, under Notice 99–5, for amending plan provisions that are in- tegral to the requirements of § 401(a)(31) to reflect the change made by § 6005(c)- (2) of RRA 98 is also extended to the end of the GUST remedial amendment period. The requirement, under Notice 99–5, that such plan provisions, as amended, must be effective as of the first day the plan op- erates in accordance with the change made by § 6005(c)(2) of RRA 98 contin- ues to apply. .06 Finally, the extension of the reme- dial amendment period also applies to the time for adopting amendments of defined benefit plans to provide that benefits will be determined in accordance with the ap- plicable interest rate rules and applicable mortality table rules of § 1.417(e)–1(d). Thus, such a plan amendment may be adopted at any time up to the last day of the extended remedial amendment period, provided the amendment is made effec- tive for distributions with annuity starting dates occurring in plan years beginning after December 31, 1999. However, pur- suant to the Commissioner’s authority in §1.401(b)–1T(c)(3), if such a plan amendment is adopted after the last day of the last plan year beginning before Janu- ary 1, 2000, the amendment must provide that, with respect to distributions with an- nuity starting dates that are after the last day of that plan year but before the date of adoption of the amendment, the distribu- tion will be the greater of the amount that would be determined under the plan with- out regard to the amendment and the amount determined under the plan with regard to the amendment. .07 The TRA 86 remedial amendment period for governmental plans is hereby extended to the end of the GUST remedial amendment period for governmental plans described in Rev. Proc. 98–14, and the TRA 86 remedial amendment period for nonelecting church plans is hereby ex- tended to the last day of the first plan year beginning on or after January 1, 2000. Accordingly, governmental plans need not be amended to comply with TRA 86, UCA, or OBRA 93 (to the extent the pro- visions of those acts apply) until the date described in Rev. Proc. 98–14. In accor- dance with Notice 98–39, nonelecting church plans need not be amended to comply with the regulations under §§ 401(a)(4), 401(l), 410(b), or 414(s) until the last day of the first plan year begin- ning on or after January 1, 2001. For all other applicable provisions of those acts, however, nonelecting church plans must be amended by the last day of the first plan year beginning on or after January 1, 2000. The additional administrative relief provided under Notice 92–36, 1992–2 C.B. 364, continues to be available to governmental and nonelecting church plans through the end of their respective remedial amendment periods with respect to the applicable nondiscrimination re- quirements. SECTION 4. DESIGNATION OF PLAN PROVISIONS INTEGRAL TO § 415(e) AS DISQUALIFYING PROVISIONS A plan provision is hereby designated as a disqualifying provision under § 1.401(b)–1(b) if the plan provision causes a plan to fail to satisfy the qualifi- cation requirements of the Code because of the repeal of the combined plan limita- tion of § 415(e) by § 1452(a) of SBJPA or if the provision is integral to the limitation of § 415(e), as in effect prior to its repeal by § 1452(a) of SBJPA, provided the fol- lowing conditions are satisfied. First, the plan provision must be amended to reflect the repeal of § 415(e) by the end of the GUST remedial amendment period. Sec- ond, in the case of a plan provision that is integral to the limitation of § 415(e), the plan provision, as amended, may not be effective earlier than the first day on which the plan was operated in accor- dance with the amended provision. SECTION 5. EXTENSION OF EXTENDED RELIANCE PERIOD The TRA 86 extended reliance period is extended by one year. A plan with ex- tended reliance must therefore be amended by the end of the GUST remedial amend- ment period to the extent necessary to comply with regulations or administrative guidance of general applicability that have been issued since the date of the plan’s fa- vorable TRA 86 letter. These amendments must be made effective no later than the first day of the first plan year beginning on or after January 1, 2000, and, except in the case of master or prototype or other pre- approved plans, no earlier than the first day of the plan year in which the amendments are adopted. (But see Rev. Rul. 94–76 and Rev. Rul. 96–47.) SECTION 6. EFFECT ON OTHER DOCUMENTS The following revenue procedures and notices are modified: Rev. Proc. 89–9, Rev. Proc. 89–13, section 13 of Rev. Proc. 93–39, Rev. Proc. 95–12, Rev. Proc. 97–41, Rev. Proc. 98–14, Notice 92–36, Notice 96–64, Notice 98–39, Notice 98–52, and Notice 99–5. SECTION 7. EFFECTIVE DATE This revenue procedure is effective April 19, 1999. April 19, 199981999–16 I.R.B. DRAFTING INFORMATION The principal author of this revenue procedure is James Flannery of the Em- ployee Plans Division. For further infor- mation regarding this revenue procedure, contact the Employee Plans Division’s telephone assistance service between the hours of 1:30 and 3:30 p.m. Eastern time, Monday through Thursday, on (202) 622- 6074/75. (These telephone numbers are not toll-free.) 1999–16 I.R.B.9April 19, 1999 April 19, 1999101999–16 I.R.B. Part IV. Items of General Interest Cumulative Bulletin Continued With a New Format Announcement 99–36 Last year the Service solicited com- ments on a proposal to discontinue publi- cation of the cumulative bulletin (CB). The proposal was printed in the Federal Register dated October 2, 1998. Based on responses from taxpayers, tax practition- ers, and government agencies, the Service has decided to continue publishing the CB. Beginning with CB 1998–1, the CB will contain the same information but will have a new format. 1. Reprints of the weekly Internal Rev- enue Bulletins (IRBs) issued during the year will now be bound together to form the CB. Volume 1 will contain the first 26 issues of the IRB (1998–27 to 1998–52). Previously, the CB was created by consol- idating Parts I-IV of the IRBs into Parts I- IV of the CB. 2. The CB will now include a new cu- mulative list titled “List of Rulings and Decisions Under the Internal Revenue Code of 1986.” This list will be organized by code section and will identify, by cita- tion only, the revenue rulings, revenue procedures, notices, and announcements that impact each code section. It will con- tain the page numbers in the CB. It can be used in the same manner as the “Numeri- cal Finding List,” which will now provide both the page number in the IRB and the page number in the CB. 3. The cumulative “Finding List of Current Actions on Previously Published Items” and the “Index” will also identify both the IRB and CB page numbers. There will be no change to the manner in which the CB is cited. 4. Announcements that are published in the IRBs will be included in the CB. Pre- vious CBs did not include announcements. 5. A list of “Actions Relating to Deci- sions of the Tax Court” and a list of “Dis- barments and Suspensions” will remain as components of the CB. 6. Public laws relating to taxes will continue to be provided in volume 3 of the CB. If additional volumes are needed to published public laws, the CBs will be labeled consecutively as volume 4, 5, etc. Announcement 99–40 On July 1, 1998, temporary regulations T.D. 8774, 1998–30 I.R.B. 5, were pub- lished in the Federal Register (63 F.R. 35799) relating to the kerosene excise tax. Recently, a group of taxpayers has ad- vised the Internal Revenue Service that the taxpayers were unaware that they needed to be registered by the IRS for purposes of this tax. To address the prob- lem, the final kerosene tax regulations will provide the following rules: (1) The period during which persons are treated as registered under the transitional registra- tion rule, which currently is scheduled to expire on April 1, 1999, will instead ex- pire on July 1, 1999; (2) Airlines, other aircraft operators, and fixed base opera- tors that store kerosene in a terminal, and kerosene terminal operators will be treated as registered for purposes of the kerosene tax under the transitional regis- tration rule. Further, the IRS will provide an expedited kerosene tax registration procedure. Under the expedited procedure, per- sons that apply for registration with their IRS district office by May 14, 1999, will be given either a conditional Letter of Registration or a denial by June 30, 1999. To apply, an applicant files Form 637, Ap- plication for Registration (For Certain Ex- cise Tax Activities), under activity S. An “S” registration is in addition to any “H” or “Y” registration an applicant may have received. Form 637 is filed with the IRS district director for the district where the applicant has its principal place of busi- ness. An applicant may obtain the ad- dress of its district director by calling 1- 800-829-1040. Applicants who do not have a principal place of business in the United States file Form 637 with the IRS, Office of Assistant Commissioner (Inter- national), 950 L’Enfant Plaza South, SW, Attention: OP:IN:D:C:E, Washington, DC 20024. The principal author of this announce- ment is Frank Boland of the Office of As- sistant Chief Counsel (Passthroughs and Special Industries) . For further informa- tion regarding this announcement contact Frank Boland at (202) 622-3130 (not a toll-free call). Announcement 99–41 Federal Insurance Contributions Act (FICA) Taxation of Amounts Under Employee Benefit Plans; Correction AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Correction to final regulations. SUMMARY: This document contains corrections to Treasury Decision 8814, 1999–9 I.R.B. 4, which was published in the Federal Registeron Friday, January 29, 1999 (64 F.R. 4542) that provides guidance as to when amounts deferred under or paid from a nonqualified de- ferred compensation plan are taken into account as wages for purposes of the em- ployment taxes imposed by the Federal Insurance Contributions Act (FICA). DATES: This correction is effective Jan- uary 29, 1999. FOR FURTHER INFORMATION CON- TACT: Janine Cook, Linda E. Alsalihi, or Margaret Owens, (202) 622-6040 (not a toll-free number). SUPPLEMENTARY INFORMATION: Background The final regulations that are the sub- ject of these corrections are under section 3121 of the Internal Revenue Code. Need for Correction As published, T.D. 8814 contains errors which may prove to be misleading and are in need of clarification. Correction of Publication Accordingly, the publication of the final regulations (T.D. 8814), which was the subject of FR Doc. 99–1663, is cor- rected as follows: 1. On page 4542, column 1, in the reg- ulation heading, the language “RIN 1545–AT27” is corrected to read “RIN 1545–AF97”. §31.3121(v)(2)–1 [Corrected] 2. On page 4550, column 3, §31.3121(v)(2)–1(b)(5), paragraph (i) of Example 10,line 9, the language “em- ployee’s designated beneficiary in a sin- gle” is corrected to read “employee’s des- ignated beneficiary in a single lump”. 3. On page 4551, column 1, §31.3121(v)(2)–1(b)(5), paragraph (ii) of Example 10,line 3 from the bottom of the paragraph, the language “payable in the event of the Employee E’s” is corrected to read “payable in the event of Employee E’s”. 4. On page 4551, column 1, §31.3121(v)(2)–1(b)(5), paragraph (ii) of Example 11,line 4 from the bottom of the paragraph, the language “E under the plan during the Employee E’s” is corrected to read “E under the plan during Employee E’s”. 5. On page 4566, column 3, §31.3121(v)(2)–1(g)(5), paragraph (i) of Example 8,line 14, the language “Based Employer R’s estimate that Employee” is corrected to read “Based on Employer R’s estimate that Employee”. 6. On page 4566, column 3, §31.3121(v)(2)–1(g)(5), paragraph (i) of Example 8,line 5 from the bottom of the paragraph, the language “which Em- ployee R has a legally binding right” is corrected to read “which Employee F has a legally binding right”. Cynthia E. Grigsby, Chief, Regulations Unit, Assistant Chief Counsel (Corporate). (Filed by the Office of the Federal Register on March 31, 1999, 8:45 a.m., and published in the issue of the Federal Register for April 1, 1999, 64 F.R. 15687) Announcement 99–42 Certain Transfers of Stock or Securities by U.S. Persons to Foreign Corporations and Related Reporting Requirements; Correction AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Correction to final regulations. SUMMARY: This document contains corrections to Treasury Decision 8770, 1998–27 I.R.B. 4, which was published in the Federal Registeron Friday, June 19, 1998 (63 F.R. 33550) relating to certain transfers of stock or securities by U.S. persons to foreign corporations pursuant to the corporate organization and reorga- nization provisions of the Internal Rev- enue Code, and the reporting require- ments related to such transfers. DATES: These corrections are effective July 20, 1998. FOR FURTHER INFORMATION CON- TACT: Philip L. Tretiak, (202) 622-3860 (not a toll-free number). SUPPLEMENTARY INFORMATION: Background The final regulations that are the sub- ject of these corrections are under sec- tions 367 and 6038B of the Internal Rev- enue Code. Need for Correction As published, T.D. 8770 contains errors which may prove to be misleading and are in need of clarification. Correction of Publication Accordingly, the publication of the final regulations (T.D. 8770), which was the subject of FR Doc. 98–15454, is cor- rected as follows: 1. On page 33555, column 2, in the preamble under the paragraph heading “Effective Dates”, line 19, the language “ a United States shareholder but does” is corrected to read “ a United States share- holder but does not”. §1.367(a)–3 [Corrected] 2. On page 33556, column 1, §1.367(a)–3(a), lines 22 through 24, the language “a U.S. person exchanges stock of one foreign corporation for stock of an- other foreign corporation in a reorganiza- tion” is corrected to read “a U.S. person exchanges stock of a foreign corporation in a reorganization”. 3. On page 33556, column 1, §1.367(a)–3(a), line 27, the language “do- mestic corporation for stock of a” is cor- rected to read “domestic or foreign corpo- ration for stock of a”. 4. On page 33559, column 1, §1.367(a)–3(d)(3), paragraph (ii) of Ex- ample 6,line 10, the language “§1.367(a)- 8(g)(3)(i) (which includes the” is cor- rected to read §1.367(a)–8(g)(3) (which includes the”. §1.367(b)–4 [Corrected] 5. On page 33568, column 1, §1.367(b)–4(b)(5)(i), line 4, the language “transaction described in paragraph (b)(1)” is corrected to read “transaction described in paragraph (a)”. 6. On page 33568, column 2, §1.367(b)–4(b)(5)(ii), paragraph (ii) of the Example,line 2, the language “an ex- change described in paragraph (b) of” is corrected to read “an exchange described in paragraph (a) of”. §1.6038B–1 [Corrected] 7. On page 33569, column 1, § 1.6038B–1(b)(2)(i) introductory text, line 4, the language “in section 6038(a)(1)(A) will be” is corrected to read “in section 6038B(a)(1)(A) will be”. Cynthia E. Grigsby, Chief, Regulations Unit, Assistant Chief Counsel (Corporate). (Filed by the Office of the Federal Register on March 31, 1999, 8:45 a.m., and published in the issue of the Federal Register for April 1, 1999, 64 F.R. 15687) Announcement 99–43 Notice of Certain Transfers to Foreign Partnerships and Foreign Corporations; Correction AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Correction to final regulations. SUMMARY: This document contains corrections to final income tax regula- tions T.D. 8817, 1999–8 I.R.B. 51, that were published in the Federal Register on Friday, February 5, 1999 (64 F.R. 5713) relating to certain transfers to for- eign partnerships and corporations by U.S. persons. DATES: This correction is effective Feb- ruary 5, 1999. FOR FURTHER INFORMATION CON- TACT: Eliana Dolgoff (202)622-3860 (not a toll-free number). 1999–16 I.R.B.11April 19, 1999 SUPPLEMENTARY INFORMATION: Background The final regulations that are the sub- ject of this correction are under section 6038B of the Internal Revenue Code. Need for Correction As published, the final regulations con- tain errors that may prove to be mislead- ing and are in need of clarification. Correction of Publication Accordingly, the publication of the final regulations (T.D. 8817), that were the subject of FR Doc. 99–2798 is cor- rected as follows: §1.6038B–1 [Corrected] 1. On page 5715, column 1, §1.6038B– 1(b)(1)(i), lines 4 through 7, the language “paragraph (b)(2) of this section, or cash, which is subject to special rules contained in paragraph (b)(3) of this section, any U.S. person that makes a” is corrected to read ”paragraph (b)(2) of this section, any U.S. person that makes a”. In §1.6038B– 1(b)(1)(i), the last line, the language “Property to a Foreign Corporation.” is corrected to read “Property to a Foreign Corporation. For special rules regarding cash transfers made in tax years begin- ning after February 5, 1999, see para- graphs (b)(3) and (g) of this section.”. 2. On page 5715, column 1, §1.6038B– 1(b)(3) introductory text, line 2, the lan- guage “foreign corporation must report the” is corrected to read “foreign corpora- tion in a transfer described in section 6038B(a)(1)(A) must report the”. 3. On page 5715, column 2, §1.6038B– 1(c), line 6, the language “section 6038B(a)(1)(A) (including cash” is cor- rected to read “section 6038B(a)(1)(A) (including cash transferred in taxable years beginning after February 5, 1999,”. 4. On page 5715, column 2, §1.6038B– 1(g), lines 3 through 8, the language “July 20, 1998, except that the first sentence of paragraph (b)(1)(i), paragraph (b)(3), and the first sentence of paragraph (c) apply to transfers occurring in taxable years begin- ning after February 5, 1999. See §1.6038B–” is corrected to read “July 20, 1998, except that transfers of cash made in taxable years beginning on or before February 5, 1999 are not required to be reported under section 6038B. See §1.6038B–“. §1.6038B–2 [Corrected] 5. On page 5717, column 2, §1.6038B– 2(j)(1)(ii), line 1, the language, “Filing a Form 926 with the” is corrected to read “Filing a Form 926 (modified to reflect that the transferee is a partnership, not a corporation) with the”. Cynthia E. Grigsby, Chief, Regulations Unit, Assistant Chief Counsel (Corporate). (Filed by the Office of the Federal Register on March 31, 1999, 8:45 a.m., and published in the issue of the Federal Register for April 1, 1999, 64 F.R. 15686) Announcement 99–44 OMB Control Numbers Assigned Pursuant to the Paperwork Reduction Act; Correction AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Correcting amendment. SUMMARY: This document contains corrections to final regulations T.D. 8011, 1985–1 C.B. 397, which were published in the Federal Registeron Thursday, March 14, 1985 (50 F.R. 10221) relating to the displaying of OMB control numbers on this agency’s regulations that solicit or ob- tain information from the public. DATES: This correction is effective No- vember 12, 1996. FOR FURTHER INFORMATION CON- TACT: Marshall Feiring, (202) 622-3940, (not a toll-free number). SUPPLEMENTARY INFORMATION: Background The final regulations that are the sub- ject of these corrections displays this agency’s control numbers and imple- mented requirements of regulations pro- mulgated by the Office of Management and Budget pursuant to the Paperwork Reduction Act of 1980. Need for Correction As published, final regulations (T.D. 8011) contain errors which may prove to be misleading and are in need of clarifica- tion. List of Subjects in 26 CFR Part 602 Reporting and recordkeeping require- ments. Correcting Amendment to Regulations Accordingly, 26 CFR part 602 is cor- rected by making the following correcting amendments: PART 602 — OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT Paragraph 1. The authority citation for part 602 continues to read as follows: Authority: 26 U.S.C. 7805. §602.101 [Corrected] Par. 2. In §602.101, paragraph (a), sec- ond sentence, the language “(together with 26 CFR 601.9000)” is removed. Par. 3. In §602.101, paragraph (b) is removed and paragraph (c) is redesig- nated as paragraph (b). Cynthia E. Grigsby, Chief, Regulations Unit, Assistant Chief Counsel (Corporate). (Filed by the Office of the Federal Register on March 31, 1999, 8:45 a.m., and published in the issue of the Federal Register for April 1, 1999, 64 F.R. 15688) Deletions From Cumulative List of Organizations Contributions to Which are Deductible Under Section 170 of the Code Announcement 99–45 The name of an organization that no longer qualifies as an organization de- scribed in section 170(c)(2) of the Internal Revenue Code of 1986 is listed below. Generally, the Service will not disallow deductions for contributions made to a listed organization on or before the date of announcement in the Internal Revenue Bulletin that an organization no longer qualifies. However, the Service is not pre- April 19, 1999121999–16 I.R.B. cluded from disallowing a deduction for any contributions made after an organiza- tion ceases to qualify under section 170(c)(2) if the organization has not timely filed a suit for declaratory judg- ment under section 7428 and if the con- tributor (1) had knowledge of the revoca- tion of the ruling or determination letter, (2) was aware that such revocation was imminent, or (3) was in part responsible for or was aware of the activities or omis- sions of the organization that brought about this revocation. If on the other hand a suit for declara- tory judgment has been timely filed, con- tributions from individuals and organiza- tions described in section 170(c)(2) that are otherwise allowable will continue to be deductible. Protection under section 7428(c) would begin on April 19, 1999, and would end on the date the court first determines that the organization is not de- scribed in section 170(c)(2) as more par- ticularly set forth in section 7428(c)(1). For individual contributors, the maximum deduction protected is $1,000, with a hus- band and wife treated as one contributor. This benefit is not extended to any indi- vidual, in whole or in part, for the acts or omissions of the organization that were the basis for revocation. Abraham Lincoln Opportunity Foundations, Pine Mountain, GA Proposed Form 1042–S, Foreign Person’s U.S. Source Income Subject to Withholding; Correction Announcement 99–46 Announcement 99–24, 1999–14 I.R.B. 12, contained copies of proposed Form 1042–S that were poorly reproduced. We are providing more legible copies of Form 1042–S in this announcement. As a result, we have extended the date for receiving comments for that form to May 19, 1999. Please send your com- ments to Chairman, Tax Forms Coordi- nating Committee, Internal Revenue Ser- vice, OP:FS:FP, Room 5577, 1111 Constitution Avenue, NW, Washington, DC 20224. Alternatively, you may e-mail your comments to tfpmail@publish.no. irs.gov. 1999–16 I.R.B.13April 19, 1999 April 19, 1999141999–16 I.R.B. 1999–16 I.R.B.15April 19, 1999 April 19, 1999161999–16 I.R.B. 1999–16 I.R.B.17April 19, 1999 April 19, 1999181999–16 I.R.B. 1999–16 I.R.B.19April 19, 1999 April 19, 1999201999–16 I.R.B. 1999–16 I.R.B.21April 19, 1999 NameAddressDate of Resignation Ellis, Ronald C.Billings, MTOctober 6, 1998 Announcement of the Consent Voluntary Suspension of Attorneys, Certified Public Accountants, Enrolled Agents, and Enrolled Actuaries From Practice Before the Internal Revenue Service Under 31 Code of Federal Regulations, Part 10, an enrolled agent, in order to avoid the institution or conclusion of a proceeding for his disbarment or suspen- sion from practice before the Internal Revenue Service, may offer his resigna- tion from such practice. The Director of Practice, in his discretion, may suspend an enrolled agent in accordance with the consent offered. Attorneys, certified public accountants, enrolled agents, and enrolled actuaries are prohibited in any Internal Revenue Ser- vice matter from directly or indirectly em- ploying, accepting assistance from, being employed by or sharing fees with, any en- rolled agent who has resigned from prac- tice before the Internal Revenue Service. To enable attorneys, certified public ac- countants, enrolled agents, and enrolled actuaries to identify former enrolled agents who have resigned from practice before the Internal Revenue Service, the Director of Practice will announce in the Internal Revenue Bulletin the names and addresses of former enrolled agents who have resigned from such practice, and date of resignation. This announcement will appear in the weekly Bulletin at the earliest practicable date after such action and will continue to appear in the weekly Bulletins for five successive weeks or for as many weeks as is practicable for each enrolled agent, who has resigned, and will be consolidated and published in the Cu- mulative Bulletin. The following individual has offered his resignation as an enrolled agent: April 19, 1999221999–16 I.R.B. Announcement of the Expedited Suspension of Attorneys, Certified Public Accountants, Enrolled Agents, and Enrolled Actuaries From Practice Before the Internal Revenue Service Under Title 31 of the Code of Federal Regulations, section 10.76, the Director of Practice is authorized to immediately suspend from practice before the Internal Revenue Service any practitioner who, within five years, from the date the expe- dited proceeding is instituted, (1) has had a license to practice as an attorney, certi- fied public accountant, or actuary sus- pended or revoked for cause; or (2) has been convicted of any crime under title 26 of the United States Code or, of a felony under title 18 of the United States Code involving dishonesty or breach of trust. Attorneys, certified public accountants, enrolled agents, and enrolled actuaries are prohibited in any Internal Revenue Service matter from directly or indirectly employ- ing, accepting assistance from, being em- ployed by, or sharing fees with, any practi- tioner disbarred or suspended from practice before the Internal Revenue Service. To enable attorneys, certified public ac- countants, enrolled agents, and enrolled ac- tuaries to identify practitioners under expe- dited suspension from practice before the Internal Revenue Service, the Director of Practice will announce in the Internal Rev- enue Bulletin the names and addresses of practitioners who have been suspended from such practice, their designation as at- torney, certified public accountant, en- rolled agent, or enrolled actuary, and date or period of suspension. This announce- ment will appear in the weekly Bulletin at the earliest practicable date after such ac- tion and will continue to appear in the weekly Bulletins for five successive weeks or for as many weeks as is practicable for each attorney, certified public accountant, enrolled agent, or enrolled actuary so sus- pended and will be consolidated and pub- lished in the Cumulative Bulletin. The following individual have been placed under suspension from practice be- fore the Internal Revenue Service by virtue of the expedited proceeding provisions of the applicable regulations: NameAddressDesignationDate of Suspension Pierce, Steven J.Aventura, FLAttorneyIndefinite from October 15, 1998 Baker, Charles C.Monteagle, TNAttorneyIndefinite from October 15, 1998 Kantor, Stanley L.New York, NYAttorneyIndefinite from October 15, 1998 Wagner, Richard E.Spencerport, NYEnrolled AgentIndefinite from October 15, 1998 Tuohey, SeamusMontclair, NJAttorneyIndefinite from October 15, 1998 Burke, Beau E.Santa Rosa, CACPAIndefinite from October 15, 1998 Marn, Eric Y.Honolulu, HIAttorneyIndefinite from October 15, 1998 Todd, KennethTulsa, OKAttorneyIndefinite from November 4, 1998 1999–16 I.R.B.23April 19, 1999 NameAddressDesignationEffective Date Shaw-Boatner, DeborahAustin, TXCPASeptember 24, 1998 Hannum, DavidPhiladelphia, PAEnrolled AgentSeptember 30, 1998 Miller, TheodoreNeshaminy Valley, PACPAFebruary 27, 1999 Announcement of the Disbarment and Suspension of Attorneys, Certified Public Accountants, Enrolled Agents, and Enrolled Actuaries From Practice Before the Internal Revenue Service Under 330, Title 31 of the United States Code, the Secretary of the Trea- sury, after due notice and opportunity for hearing, is authorized to suspend or dis- bar from practice before the Internal Rev- enue Service any person who has vio- lated the rules and regulations governing the recognition of attorneys, certified public accountants, enrolled agents, or enrolled actuaries to practice before the Internal Revenue Service. Attorneys, certified public accountants, enrolled agents, and enrolled actuaries are prohibited in any Internal Revenue Service matter from directly or indirectly employ- ing, accepting assistance from, being em- ployed by, or sharing fees with, any practi- tioner disbarred or under suspension from practice before the Internal Revenue Ser- vice. To enable attorneys, certified public ac- countants, enrolled agents, and enrolled actuaries to identify such disbarred or sus- pended practitioners, the Director of Practice will announce in the Internal Revenue Bulletin the names and ad- dresses of practitioners who have been suspended from such practice, their desig- nation as attorney, certified public ac- countant, enrolled agent, or enrolled actu- ary, and date of disbarment or period of suspension. This announcement will ap- pear in the weekly Bulletin for five suc- cessive weeks or as long as it is practica- ble for each attorney, certified public accountant, enrolled agent, or enrolled ac- tuary so suspended or disbarred and will be consolidated and published in the Cu- mulative Bulletin. After due notice and opportunity for hearing before an administrative law judge, the following individuals have been disbarred from further practice be- fore the Internal Revenue Service: April 19, 1999241999–16 I.R.B. NameAddressDesignationDate of Suspension Cohn, IrvingBaltimore, MDAttorneySeptember 4, 1998 to September 3, 2000 Hwang, Catherine T.Livingston, NJCPAOctober 1, 1998 to September 30, 1999 Bratek, RonaldN. Brunswick, NJCPAOctober 5, 1998 to July 4, 2000 Walker, Frank O.Bay City, TXCPAOctober 5, 1998 to April 4, 2001 Ng, Peter J.Monticello, NYAttorneyOctober 5, 1998 to May 4, 2002 Sopkovich, CarolGirard, OHAttorneyOctober 5, 1998 to October 4, 2001 Kappler, John E.Evansville, INCPAOctober 8, 1998 to October 7, 1999 Sarcia, Jerry J.Libertyville, ILCPAOctober 30, 1998 to August 29, 2002 Spey, Gregory E.Youngstown, OHCPANovember 1, 1998 to April 30, 2001 Jacobson, KennethJacksonville, FLCPANovember 9, 1998 to November 8, 2000 Lopshire, LarryWhiteland, INCPADecember 2, 1998 to December 1, 1999 Lederer, Christine L.Somers, CTAttorneyDecember 7, 1998 to December 6, 2001 Kieffer, Richard D.Olney, ILCPADecember 15, 1998 to December 14, 1999 Cleaver Jr., Thomas E.Severna Park, MDEnrolled AgentDecember 23, 1998 to June 22, 2002 Trent, Douglas I.Allen, TXCPAJanuary 1, 1999 to December 31, 1999 Winters, John E. Bayonne, NJCPAJanuary 1, 1999 to September 30, 1999 Todd Jr., Emory S.Chester SpringsCPAJanuary 15, 1999 to July 14, 1999 Hawkins, William M.Indianapolis, INAttorneyFebruary 1, 1999 to January 31, 2002 Gimbal, PeterUnion City, NJCPAApril 1, 1999 to September 30, 2000 Ryan, Thomas J.Danbury, CTAttorneyMay 1, 1999 to October 30, 2000 Announcement of the Consent Voluntary Suspension of Attorneys, Certified Public Accountants, Enrolled Agents, and Enrolled Actuaries From Practice Before the Internal Revenue Service Under 31 Code of Federal Regulations, Part 10, an attorney, certified public ac- countant, enrolled agent, or enrolled ac- tuary, in order to avoid the institution or conclusion of a proceeding for his disbar- ment or suspension from practice before the Internal Revenue Service, may offer his consent to suspension from such prac- tice. The Director of Practice, in his dis- cretion, may suspend an attorney, certi- fied public accountant, enrolled agent, or enrolled actuary in accordance with the consent offered. Attorneys, certified public accountants, enrolled agents, and enrolled actuaries are prohibited in any Internal Revenue Ser- vice matter from directly or indirectly em- ploying, accepting assistance from, being employed by, or sharing fees with any practitioner disbarred or suspended from practice before the Internal Revenue Ser- vice. To enable attorneys, certified public ac- countants, enrolled agents, and enrolled actuaries to identify practitioners under consent suspension from practice before the Internal Revenue Service, the Director of Practice will announce in the Internal Revenue Bulletin the names and ad- dresses of practitioners who have been suspended from such practice, their desig- nation as attorney, certified public ac- countant, enrolled agent, or enrolled actu- ary, and date or period of suspension. This announcement will appear in the weekly Bulletin at the earliest practicable date after such action and will continue to ap- pear in the weekly Bulletins for five suc- cessive weeks or for as many weeks as is practicable for each attorney, certified public accountant, enrolled agent, or en- rolled actuary so suspended and will be consolidated and published in the Cumu- lative Bulletin. The following individuals have been placed under consent suspension from practice before the Internal Revenue Ser- vice: 1999–16 I.R.B.25April 19, 1999 Revenue rulings and revenue procedures (hereinafter referred to as “rulings”) that have an effect on previous rulings use the following defined terms to de- scribe the effect: Amplified describes a situation where no change is being made in a prior pub- lished position, but the prior position is being extended to apply to a variation of the fact situation set forth therein. Thus, if an earlier ruling held that a principle applied to A, and the new ruling holds that the same principle also applies to B, the earlier ruling is amplified. (Compare with modified, below). Clarified is used in those instances where the language in a prior ruling is being made clear because the language has caused, or may cause, some confu- sion. It is not used where a position in a prior ruling is being changed. Distinguisheddescribes a situation where a ruling mentions a previously published ruling and points out an essen- tial difference between them. Modified is used where the substance of a previously published position is being changed. Thus, if a prior ruling held that a principle applied to A but not to B, and the new ruling holds that it ap- plies to both A and B, the prior ruling is modified because it corrects a published position. (Compare with amplified and clarified, above). Obsoleted describes a previously pub- lished ruling that is not considered deter- minative with respect to future transac- tions. This term is most commonly used in a ruling that lists previously published rulings that are obsoleted because of changes in law or regulations. A ruling may also be obsoleted because the sub- stance has been included in regulations subsequently adopted. Revoked describes situations where the position in the previously published rul- ing is not correct and the correct position is being stated in the new ruling. Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings). Thus, the term is used to republish under the 1986 Code and regulations the same position published under the 1939 Code and regulations. The term is also used when it is desired to republish in a single ruling a series of situations, names, etc., that were previously published over a pe- riod of time in separate rulings. If the new ruling does more than restate the substance of a prior ruling, a combination of terms is used. For example, modified and superseded describes a situation where the substance of a previously pub- lished ruling is being changed in part and is continued without change in part and it is desired to restate the valid portion of the previously published ruling in a new ruling that is self contained. In this case the previously published ruling is first modified and then, as modified, is super- seded. Supplemented is used in situations in which a list, such as a list of the names of countries, is published in a ruling and that list is expanded by adding further names in subsequent rulings. After the original ruling has been supplemented several times, a new ruling may be pub- lished that includes the list in the original ruling and the additions, and supersedes all prior rulings in the series. Suspended is used in rare situations to show that the previous published rulings will not be applied pending some future action such as the issuance of new or amended regulations, the outcome of cases in litigation, or the outcome of a Service study. Abbreviations The following abbreviations in current use and for- merly used will appear in material published in the Bulletin. A—Individual. Acq.—Acquiescence. B—Individual. BE—Beneficiary. BK—Bank. B.T.A.—Board of Tax Appeals. C.—Individual. C.B.—Cumulative Bulletin. CFR—Code of Federal Regulations. CI—City. COOP—Cooperative. Ct.D.—Court Decision. CY—County. D—Decedent. DC—Dummy Corporation. DE—Donee. Del. Order—Delegation Order. DISC—Domestic International Sales Corporation. DR—Donor. E—Estate. EE—Employee. E.O.—Executive Order. ER—Employer. ERISA—Employee Retirement Income Security Act. EX—Executor. F—Fiduciary. FC—Foreign Country. FICA—Federal Insurance Contribution Act. FISC—Foreign International Sales Company. FPH—Foreign Personal Holding Company. F.R.—Federal Register. FUTA—Federal Unemployment Tax Act. FX—Foreign Corporation. G.C.M.—Chief Counsel’s Memorandum. GE—Grantee. GP—General Partner. GR—Grantor. IC—Insurance Company. I.R.B.—Internal Revenue Bulletin. LE—Lessee. LP—Limited Partner. LR—Lessor. M—Minor. Nonacq.—Nonacquiescence. O—Organization. P—Parent Corporation. PHC—Personal Holding Company. PO—Possession of the U.S. PR—Partner. PRS—Partnership. PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Real Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul.—Revenue Ruling. S—Subsidiary. S.P.R.—Statements of Procedral Rules. Stat.—Statutes at Large. T—Target Corporation. T.C.—Tax Court. T.D.—Treasury Decision. TFE—Transferee. TFR—Transferor. T.I.R.—Technical Information Release. TP—Taxpayer. TR—Trust. TT—Trustee. U.S.C.—United States Code. X—Corporation. Y—Corporation. Z—Corporation. Definition of Terms April 19, 1999261999–16 I.R.B. 1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 1998–1 through 1998–52 will be found in Internal Revenue Bulletin 1999–1, dated January 4, 1999. Numerical Finding List 1 Bulletins 1999–1 through 1999–15 Announcements: 99–1, 1999–2 I.R.B. 41 99–2, 1999–2 I.R.B. 44 99–3, 1999–3 I.R.B. 15 99–4, 1999–3 I.R.B. 15 99–5, 1999–3 I.R.B. 16 99–6, 1999–4 I.R.B.24 99–7, 1999–2 I.R.B. 45 99–8, 1999–4 I.R.B.24 99–9, 1999–4 I.R.B. 24 99–10, 1999–5 I.R.B. 63 99–11, 1999–5 I.R.B. 64 99–12, 1999–5 I.R.B. 65 99–13, 1999–6 I.R.B. 18 99–14, 1999–7 I.R.B.60 99–15, 1999–8 I.R.B.78 99–16, 1999–8 I.R.B. 80 99–17, 1999–9 I.R.B. 59 99–18, 1999–13 I.R.B. 21 99–19, 1999–10 I.R.B. 63 99–20, 1999–11 I.R.B.53 99–21, 1999–11 I.R.B.55 99–22, 1999–12 I.R.B. 32 99–23, 1999–15 I.R.B. 7 99–24, 1999–14 I.R.B. 12 99–25, 1999–12 I.R.B. 35 99–26, 1999–14 I.R.B. 20 99–27, 1999–13 I.R.B. 22 99–28, 1999–13 I.R.B. 25 99–29, 1999–13 I.R.B. 25 99–30, 1999–13 I.R.B. 26 99–31, 1999–13 I.R.B. 26 99–32, 1999–14 I.R.B.20 99–33, 1999–14 I.R.B. 21 99–34, 1999–15 I.R.B. 8 99–35, 1999–14 I.R.B. 22 99–37, 1999–15 I.R.B. 9 99–38, 1999–15 I.R.B. 9 99–39, 1999–15 I.R.B. 10 Notices: 99–1, 1999–2 I.R.B. 8 99–2, 1999–2 I.R.B. 8 99–3, 1999–2 I.R.B. 10 99–4, 1999–3 I.R.B. 9 99–5, 1999–3 I.R.B. 10 99–6, 1999–3 I.R.B. 12 99–7, 1999–4 I.R.B.23 99–8, 1999–5 I.R.B. 26 99–9, 1999–4 I.R.B. 23 99–10, 1999–6 I.R.B. 14 99–11, 1999–8 I.R.B.56 99–12, 1999–9 I.R.B. 44 99–13, 1999–10 I.R.B. 26 99–14, 1999–11 I.R.B.7 99–15, 1999–12 I.R.B.20 99–16, 1999–13 I.R.B.10 99–17, 1999–14 I.R.B.6 Proposed Regulations: REG–209103–89, 1999–11 I.R.B. 10 REG–209619–93, 1999–10 I.R.B. 28 REG–245562–96, 1999–9 I.R.B. 45 REG–104072–97, 1999–11 I.R.B. 12 REG–114663–97, 1999–6 I.R.B. 15 REG–114664–97, 1999–11 I.R.B. 21 Proposed Regulations—Continued REG–116826–97, 1999–10 I.R.B. 40 REG–118620–97, 1999–9 I.R.B. 46 REG–120168–97, 1999–12 I.R.B. 21 REG–121806–97, 1999–10 I.R.B. 46 REG–100729–98, 1999–14 I.R.B. 9 REG–104924–98, 1999–10 I.R.B.47 REG–105964–98, 1999–12 I.R.B. 22 REG–106177–98, 1999–12 I.R.B. 25 REG–106219–98, 1999–9 I.R.B. 51 REG–106386–98, 1999–12 I.R.B. 31 REG–106388–98, 1999–11 I.R.B. 27 REG–106564–98, 1999–10 I.R.B.53 REG–106902–98, 1999–8 I.R.B. 57 REG–106905–98, 1999–11 I.R.B. 39 REG–110524–98, 1999–10 I.R.B. 55 REG–111435–98, 1999–7 I.R.B. 55 REG–113694–98, 1999–7 I.R.B. 56 REG–111435–98, 1999–7 I.R.B. 55 REG–113744–98, 1999–10 I.R.B. 59 REG–114841–98, 1999–11 I.R.B. 41 REG–115433–98, 1999–9 I.R.B. 54 REG–116099–98, 1999–12 I.R.B. 34 REG–116824–98, 1999–7 I.R.B.57 REG–117620–98, 1999–7 I.R.B. 59 REG–118662–98, 1999–13 I.R.B. 13 REG–119192–98, 1999–11 I.R.B. 45 REG–121865–98, 1999–8 I.R.B.63 Revenue Procedures: 99–1, 1999–1 I.R.B. 6 99–2, 1999–1 I.R.B. 73 99–3, 1999–1 I.R.B. 103 99–4, 1999–1 I.R.B. 115 99–5, 1999–1 I.R.B. 158 99–6, 1999–1 I.R.B. 187 99–7, 1999–1 I.R.B. 226 99–8, 1999–1 I.R.B. 229 99–9, 1999–2 I.R.B. 17 99–10, 1999–2 I.R.B. 11 99–11, 1999–2 I.R.B. 14 99–12, 1999–3 I.R.B. 13 99–13, 1999–5 I.R.B. 52 99–14, 1999–5 I.R.B. 56 99–15, 1999–7 I.R.B. 42 99–16, 1999–7 I.R.B. 50 99–17, 1999–7 I.R.B. 52 99–18, 1999–11 I.R.B.7 99–19, 1999–13 I.R.B.10 99–20, 1999–14 I.R.B.7 99–22, 1999–15 I.R.B.5 Revenue Rulings: 99–1, 1999–2 I.R.B. 4 99–2, 1999–2 I.R.B. 5 99–3, 1999–3 I.R.B. 4 99–4, 1999–4 I.R.B.19 99–5, 1999–6 I.R.B.8 99–6, 1999–6 I.R.B. 6 99–7, 1999–5 I.R.B. 4 99–8, 1999–6 I.R.B.8 99–9, 1999–7 I.R.B.14 99–10, 1999–10 I.R.B. 10 99–11, 1999–10 I.R.B. 18 99–12, 1999–11 I.R.B. 6 99–13, 1999–10 I.R.B. 4 99–14, 1999–13 I.R.B. 3 99–15, 1999–12 I.R.B.4 99–16, 1999–13 I.R.B.5 99–17, 1999–14 I.R.B. 4 Revenue Rulings—Continued 99–18, 1999–14 I.R.B. 3 99–19, 1999–15 I.R.B. 3 Treasury Decisions: 8789, 1999–3 I.R.B. 5 8791, 1999–5 I.R.B. 7 8792, 1999–7 I.R.B.36 8793, 1999–7 I.R.B.15 8794, 1999–7 I.R.B.4 8795, 1999–7 I.R.B.8 8796, 1999–4 I.R.B. 16 8797, 1999–5 I.R.B. 5 8798, 1999–12 I.R.B. 16 8799, 1999–6 I.R.B. 10 8800, 1999–4 I.R.B. 20 8801, 1999–4 I.R.B. 5 8802, 1999–4 I.R.B. 10 8803, 1999–12 I.R.B. 15 8804, 1999–12 I.R.B. 5 8805, 1999–5 I.R.B. 14 8806, 1999–6 I.R.B.4 8807, 1999–9 I.R.B. 33 8808, 1999–10 I.R.B. 21 8809, 1999–7 I.R.B.27 8810, 1999–7 I.R.B.19 8811, 1999–10 I.R.B. 19 8812, 1999–8 I.R.B. 19 8813, 1999–9 I.R.B. 34 8814, 1999–9 I.R.B. 4 8815, 1999–9 I.R.B. 31 8816, 1999–8 I.R.B. 4 8817, 1999–8 I.R.B. 51 1999–16 I.R.B.27April 19, 1999 Finding List of Current Action on Previously Published Items 1 Bulletins 1999–1 through 1999–15 Revenue Procedures: 78–10 Obsoleted by 99–12, 1999–3 I.R.B. 13 94–56 Superseded by 99–9, 1999–2 I.R.B. 17 97–23 Superseded by 99–3, 1999–1 I.R.B. 103 98–1 Superseded by 99–1, 1999–1 I.R.B. 6 98–2 Superseded by 99–2, 1999–1 I.R.B. 73 98–3 Superseded by 99–3, 1999–1 I.R.B. 103 98–4 Superseded by 99–4, 1999–1 I.R.B. 115 98–5 Superseded by 99–5, 1999–1 I.R.B. 158 98–6 Superseded by 99–6, 1999–1 I.R.B. 187 98–7 Superseded by 99–7, 1999–1 I.R.B. 226 98–8 Superseded by 99–8, 1999–1 I.R.B. 229 98–22 Modified and amplified by 99–13, 1999–5 I.R.B. 52 98–28 Obsoleted by (except as provided in section 5.02 of) 99–22, 1999–15 I.R.B. 5 98–56 Superseded by 99–3, 1999–1 I.R.B. 103 98–63 Modified by announcement 99–7, 1999–2 I.R.B. 45 Revenue Rulings: 92–19 Supplemented in part by 99–10, 1999–10 I.R.B. 10 1 A cumulative finding list for previously published items mentioned in Internal Revenue Bulletins 1998–1 through 1998–52 will be found in Internal Revenue Bulletin 1999–1, dated January 4, 1999. April 19, 1999281999–16 I.R.B. Notes 1999–16 I.R.B.29April 19, 1999 Notes Notes April 19, 1999301999–16 I.R.B. INTERNAL REVENUE BULLETIN The Introduction on page 3 describes the purpose and content of this publication. The weekly Internal Revenue Bulletin is sold on a yearly subscription basis by the Superintendent of Documents. Current subscribers are notified by the Superintendent of Documents when their subscriptions must be renewed. CUMULATIVE BULLETINS The contents of this weekly Bulletin are consolidated semiannually into a permanent, indexed, Cumulative Bulletin. These are sold on a single copy basis and are not included as part of the subscription to the Internal Revenue Bulletin. Subscribers to the week- ly Bulletin are notified when copies of the Cumulative Bulletin are available. Certain issues of Cumulative Bulletins are out of print and are not available. Persons desiring available Cumulative Bulletins, which are listed on the reverse, may purchase them from the Superintendent of Documents. HOW TO ORDER Check the publications and/or subscription(s) desired on the reverse, complete the order blank, enclose the proper remittance, detach entire page, and mail to the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402. Please allow two to six weeks, plus mailing time, for delivery. WE WELCOME COMMENTS ABOUT THE INTERNAL REVENUE BULLETIN If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we would be pleased to hear from you. You can e-mail us your suggestions or comments through the IRS Internet Home Page (www.irs.ustreas.gov) or write to the IRS Bulletin Unit, OP:FS:FP:P:1, Room 5617, 1111 Constitution Avenue NW, Washington, DC 20224.
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