Internal Revenue Bulletin 1999-18 (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. 99–21, page 3.
Federal rates; adjusted federal rates; adjusted federal
long-term rate, and the long-term exempt rate.For
purposes of sections 1274, 1288, 382, and other sections
of the Code, tables set forth the rates for May 1999.
EXEMPT ORGANIZATIONS
Announcement 99–49, page 7.
A list is given of organizations now classified as private foun-
dations.
ESTATE TAX
Rev. Rul. 99–20, page 5.
Special use value; farms; interest rates.The 1999 inter-
est rates to be used in computing the special use value of
farm real property for which an election is made under sec-
tion 2032A of the Code are listed for estates of decedents.
Internal Revenue
bbuulllleettiinn
Bulletin No. 1999–18
May 3, 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 11.
Index for January through April begins on page 13.
IRB 1999-18 4/29/99 1:37 PM Page 1

The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing offi-
cial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
general interest. It is published weekly and may be obtained
from the Superintendent of Documents on a subscription
basis. Bulletin contents are consolidated semiannually into
Cumulative Bulletins, which are sold on a single-copy basis.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of in-
ternal management are not published; however, statements
of internal practices and procedures that affect the rights
and duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the
revenue ruling. In those based on positions taken in rulings
to taxpayers or technical advice to Service field offices,
identifying details and information of a confidential nature
are deleted to prevent unwarranted invasions of privacy and
to comply with statutory requirements.
Rulings and procedures reported in the Bulletin do not have
the force and effect of Treasury Department Regulations,
but they may be used as precedents. Unpublished rulings
will not be relied on, used, or cited as precedents by Service
personnel in the disposition of other cases. In applying pub-
lished rulings and procedures, the effect of subsequent leg-
islation, regulations, court decisions, rulings, and proce-
dures must be considered, and Service personnel and oth-
ers concerned are cautioned against reaching the same con-
clusions in other cases unless the facts and circumstances
are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions, and Subpart B, Legislation and Related
Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to
these subjects are contained in the other Parts and Sub-
parts. Also included in this part are Bank Secrecy Act Admin-
istrative Rulings. Bank Secrecy Act Administrative Rulings
are issued by the Department of the Treasury’s Office of the
Assistant Secretary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The first Bulletin for each month includes a cumulative index
for the matters published during the preceding months.
These monthly indexes are cumulated on a semiannual basis,
and are published in the first Bulletin of the succeeding semi-
annual period, respectively.
Mission of the Service
Provide America’s taxpayers top quality service by help-
ing them understand and meet their tax responsibilities
and by applying the tax law with integrity and fairness to
all.
2
Introduction
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402.
IRB 1999-18 4/29/99 1:37 PM Page 2

Section 42.—Low-Income
Housing Credit
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 1999. See Rev. Rul. 99–21, page 3.
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term
rates are set forth for the month of May 1999. See
Rev. Rul. 99–21, page 3.
Section 382.—Limitation on Net
Operating Loss Carryforwards
and Certain Built-In Losses
Following Ownership Change
The adjusted applicable federal long-term rate is
set forth for the month of May 1999. See Rev. Rul.
99–21, page 3.
Section 412.—Minimum
Funding Standards
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 1999. See Rev. Rul. 99–21, page 3.
Section 467.—Certain
Payments for the Use of
Property or Services
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 1999. See Rev. Rul. 99–21, page 3.
Section 468.—Special Rules for
Mining and Solid Waste
Reclamation and Closing Costs
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 1999. See Rev. Rul. 99–21, page 3.
Section 482.—Allocation of
Income and Deductions Among
Taxpayers
Federal short-term, mid-term, and long-term
rates are set forth for the month of May 1999. See
Rev. Rul. 99–21, page 3.
Section 483.—Interest on
Certain Deferred Payments
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 1999. See Rev. Rul. 99–21, page 3.
Section 642.—Special Rules for
Credits and Deductions
Federal short-term, mid-term, and long-term
rates are set forth for the month of May 1999. See
Rev. Rul. 99–21, page 3.
Section 807.—Rules for Certain
Reserves
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 1999. See Rev. Rul. 99–21, page 3.
Section 846.—Discounted
Unpaid Losses Defined
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 1999. See Rev. Rul. 99–21, page 3.
Section 1274.—Determination
of Issue Price in the Case of
Certain Debt Instruments Issued
for Property
(Also sections 42, 280G, 382, 412, 467, 468, 482,
483, 642, 807, 846, 1288, 7520, 7872.)
Federal rates; adjusted federal rates;
adjusted federal long-term rate, and
the long-term exempt rate.For purposes
of sections 1274, 1288, 382, and other
sections of the Code, tables set forth the
rates for May 1999.
Rev. Rul. 99–21
This revenue ruling provides various
prescribed rates for federal income tax
purposes for May 1999 (the current
month.) Table 1 contains the short-term,
mid-term, and long-term applicable fed-
eral rates (AFR) for the current month for
purposes of section 1274(d) of the Inter-
nal Revenue Code. Table 2 contains the
short-term, mid-term, and long-term ad-
justed applicable federal rates (adjusted
AFR) for the current month for purposes
of section 1288(b). Table 3 sets forth the
adjusted federal long-term rate and the
long-term tax-exempt rate described in
section 382(f). Table 4 contains the ap-
propriate percentages for determining the
low-income housing credit described in
section 42(b)(2) for buildings placed in
service during the current month. Finally,
Table 5 contains the federal rate for deter-
mining the present value of an annuity, an
interest for life or for a term of years, or a
remainder or a reversionary interest for
purposes of section 7520.
1999–18 I.R.B.3May 3, 1999
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
IRB 1999-18 4/29/99 1:37 PM Page 3

REV. RUL. 99–21 TABLE 1
Applicable Federal Rates (AFR) for May 1999
Period for Compounding
AnnualSemiannualQuarterly Monthly
Short-Term
AFR4.90%4.84%4.81%4.79%
110% AFR5.39%5.32%5.29%5.26%
120% AFR5.89%5.81%5.77%5.74%
130% AFR6.39%6.29%6.24%6.21%
Mid-Term
AFR5.22%5.15%5.12%5.10%
110% AFR5.75%5.67%5.63%5.60%
120% AFR6.28%6.18%6.13%6.10%
130% AFR6.81%6.70%6.64%6.61%
150% AFR7.88%7.73%7.66%7.61%
175% AFR9.21%9.01%8.91%8.85%
Long-Term
AFR5.66%5.58%5.54%5.52%
110% AFR6.23%6.14%6.09%6.06%
120% AFR6.81%6.70%6.64%6.61%
130% AFR7.38%7.25%7.19%7.14%
May 3, 199941999–18 I.R.B.
REV. RUL. 99–21 TABLE 2
Adjusted AFR for May 1999
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
adjusted AFR3.30%3.27%3.26%3.25%
Mid-term
adjusted AFR3.96%3.92%3.90%3.89%
Long-term
adjusted AFR4.82%4.76%4.73%4.71%
REV. RUL. 99-21 TABLE 3
Rates Under Section 382 for May 1999
Adjusted federal long-term rate for the current month4.82%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the
adjusted federal long-term rates for the current month and the prior two months.) 4.82%
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REV. RUL. 99–21 TABLE 4
Appropriate Percentages Under Section 42(b)(2) for May 1999
Appropriate percentage for the 70% present value low-income housing credit8.27%
Appropriate percentage for the 30% present value low-income housing credit3.54%
1999–18 I.R.B.5May 3, 1999
REV. RUL. 99–21 TABLE 5
Rate Under Section 7520 for May 1999
Applicable federal rate for determining the present value of an annuity, an interest for life or a term
of years, or a remainder or reversionary interest6.2%
Section 1288.—Treatment of
Original Issue Discount on
Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 1999. See Rev. Rul. 99–21, page 3.
Section 2032A.—Valuation of
Certain Farm, Etc., Real
Property
26 CFR 20.2032A-4: Method of valuing farm real
property.
Special use value; farms; interest
rates. The 1999 interest rates to be used
in computing the special use value of
farm real property for which an election is
made under section 2032A of the Code
are listed for estates of decedents.
Rev. Rul. 99–20
This revenue ruling contains a list of
the average annual effective interest rates
on new loans under the Farm Credit Bank
system. This revenue ruling also contains
a list of the states within each Farm Credit
Bank District.
Under § 2032A(e)(7)(A)(ii) of the Inter-
nal Revenue Code, rates on new Farm
Credit Bank loans are used in computing the
special use value of real property used as a
farm for which an election is made under
§ 2032A. The rates in this revenue ruling
may be used by estates that value farmland
under § 2032A as of a date in 1999.
Average annual effective interest rates,
calculated in accordance with
§ 2032A(e)(7)(A) and § 20.2032A–4(e)
of the Estate Tax Regulations, to be used
under § 2032A(e)(7)(A)(ii), are set forth
in the accompanying Table of Interest
Rates (Table 1). The states within each
Farm Credit Bank District are set forth in
the accompanying Table of Farm Credit
Bank Districts (Table 2).
Rev. Rul. 81–170, 1981–1 C.B. 454,
contains an illustrative computation of an
average annual effective interest rate.
The rates applicable for valuation in 1998
are in Rev. Rul. 98–22, 1998–19 I.R.B. 5.
For rate information for years prior to
1998, see Rev. Rul. 97–13, 1997–1 C.B.
185, and other revenue rulings that are
referenced therein.
DRAFTING INFORMATION
The principal author of this revenue
ruling is of the Office of Assistant Chief
Counsel (Passthroughs and Special Indus-
tries). For further information regarding
this revenue ruling, contact on (202) 622-
3090 (not a toll-free call).
REV. RUL. 99–20 TABLE 1
TABLE OF INTEREST RATES
(Year of Valuation 1999)
Farm Credit Bank District inInterest
Which Property Is LocatedRate
Columbia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9.65
Omaha . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8.07
Sacramento . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8.25
St. Paul . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8.21
Spokane . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8.31
Springfield . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8.78
Texas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8.11
Wichita . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8.25
IRB 1999-18 4/29/99 1:37 PM Page 5

REV. RUL. 99–20 TABLE 2
TABLE OF FARM CREDIT BANK DISTRICTS
DistrictStates
Columbia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Delaware, District of Columbia, Florida, Georgia, Maryland,
North Carolina, Pennsylvania, South Carolina, Virginia, West
Virginia.
Omaha . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Iowa, Nebraska, South Dakota, Wyoming.
Sacramento . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Arizona, California, Hawaii, Nevada, Utah.
St. Paul . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Arkansas, Illinois, Indiana, Kentucky, Michigan, Minnesota,
Missouri, North Dakota, Ohio, Tennessee, Wisconsin.
Spokane . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Alaska, Idaho, Montana, Oregon, Washington.
Springfield . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Connecticut, Maine, Massachusetts, New Hampshire, New
Jersey, New York, Rhode Island, Vermont.
Texas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Alabama, Louisiana, Mississippi, Texas.
Wichita . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Colorado, Kansas, New Mexico, Oklahoma.
May 3, 199961999–18 I.R.B.
Section 7520.—Valuation
Tables
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 1999. See Rev. Rul. 99–21, page 3.
Section 7872.—Treatment of
Loans With Below-Market
Interest Rates
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 1999. See Rev. Rul. 99–21, page 3.
IRB 1999-18 4/29/99 1:37 PM Page 6

1999–18 I.R.B.7May 3, 1999
Part IV. Items of General Interest
Foundations Status of Certain
Organizations
Announcement 99–49
The following organizations have
failed to establish or have been unable to
maintain their status as public charities or
as operating foundations. Accordingly,
grantors and contributors may not, after
this date, rely on previous rulings or des-
ignations in the Cumulative List of Orga-
nizations (Publication 78), or on the pre-
sumption arising from the filing of notices
under section 508(b) of the Code. This
listing does notindicate that the organiza-
tions have lost their status as organiza-
tions described in section 501(c)(3), eligi-
ble to receive deductible contributions.
Former Public Charities.The following
organizations (which have been treated as
organizations that are not private founda-
tions described in section 509(a) of the
Code) are now classified as private foun-
dations:
Center for Technology Transfer Inc.,
Austin, TX
Council Oaks Vocational Enhancement
Services, Austin, TX
Future Leaders Learning Center
Incorporated, Houston, TX
Heartnotes, Inc., Walcott, IA
Institute for Community Based
Rehabilitation, Little Rock, AR
Lynn Vowell Ministries, Valley View, TX
Mandelbrot Foundation for Fractals Inc.,
Scarsdale, NY
Midwest Benefits Education Council,
Minneapolis, MN
Midwest Wheel Chair Tennis Assoc. Inc.,
Brookfield, IL
Mig Inc., Chicago, IL
Mighty Eighth Air Force Foundation Inc.,
Savannah, GA
Mike Pennington Memorial Scholarship
Fund Incorporated, Manassas, VA
Miles Washington Connor Family
Support Center of Sharon BAP C Inc.,
Baltimore, MD
Millenial Arts Incorporated, New York,
NY
Millworks Gallery Inc., Akron, OH
Milton EMT Association Inc., Milton, WI
Milwaukee Academy of Music and
Performing Arts, Inc., Milwaukee, WI
Mind Development Inc., Detroit, MI
Minds Inc., Miami, FL
Mineral County Search & Rescue,
Keyser, WV
Ministry Resources Inc., Kenosa, WI
Minneapolis High Rise Tenants
Organization, Minneapolis, MN
Minnesota Council of Sexual Adiction-
Compulsivity, Duluth, MN
Minnesota Mortgage Foreclosure
Prevention Association, Minneapolis,
MN
Minnesota State Elks Association
Charitable TR, Austin, MN
Minnesotans for the Mississippi,
Hastings, MN
Minority Economic Developers Inc.,
Baton Rouge, LA
Minority Enterprise Development
Council, Chicago, IL
Minority Resume Exchange, Boulder, CO
Mirage Aquatics, Victorville, CA
Miss Dots Small World Inc., Paterson, NJ
Missing Children International Inc.,
Orange, CA
Mission of First Baptist Church of
Vienna Inc., Salisbury, MD
Mission of Jesus Disciple, Irvine, CA
Missionary Care International, Corona,
CA
Missionary Evangelistic Support
Association, Goshen, OH
Mississippi Branch of the Orton Dyslexia
Society, Gulfport, MS
Mississippi Lifeline Inc., Jackson, MS
Mississippi Sickle Cell Anemia
Foundation Inc., Jackson, MS
Missoula Center for Responsible
Planning Inc., Missoula, MT
Missouri Association for Agriculture
Biomedical Research & Education,
St. Louis, MO
Missouri Association of Teaching
Christian Homes, Columbia, MO
MITA Business League Inc., Tifton, GA
Mitchelltown Preservation Society,
Kinston, NC
Mitzva Awareness Program, Southfield,
MI
Mize Informatics Foundation, Dallas, TX
MKS in Recovery Inc., Reynoldsburg,
OH
MLT Foundation Inc., Orlando, FL
MMC Surgie Center Inc., Long Branch,
NJ
MO Better Brothers Inc., Louisville, KY
Mobile Elder Care, Mobile, AL
Mobile Global Laboratories, Tuscaloosa,
AL
Monroe County Public Library
Foundation Inc., Bloomington, IN
Monroe Developmental Disabilities
Education Network, Fairport, NY
Montage Acting Society of Kent, Kent,
WA
Montanans for a Healthy Future, Clancy,
MT
Montclair Chamber ensemble Inc.,
Montclair, NJ
Monte Vista Housing Foundation a CA
Non-Profit Public Benefit Corp.,
Huntington Beach, CA
Montessori NESTPreschool Inc.,
Baton Rouge, LA
Montgomerys Transportation Service
Inc., New Orleans, LA
Moonbird Foundation Inc., Houston, TX
Moreno Valley Spotlighters, Moreno
Valley, CA
Morgan and Canfield Foundation,
Bloomfield Hills, MI
Morgan Family Ministries Inc., Foster,
KY
Morning Glory Manse Inc., Mansfield,
MA
Mother Tierras Inc., Havre de Grace,
MD
Mothers Against Gang Wars, Stockton,
CA
Mothers of Murdered Offspring-Mom-O
Inc., Charlotte, NC
Motor Sports Awareness Group, Houston,
TX
Mount Canaan Baptist Church Lifeline
Enterprises Inc., Talladega, AL
Mt. Carmel Gospel Ministries Inc.,
Columbia, MD
MTB Community Crisis Prevention
Center, Baton Rouge, LA
Muhammed Ali Future Foundation,
Philadelphia, PA
Mulligan Foundation Inc., Whitmore,
Lake, MI
Multi-Color Film & Arts Inc., Brooklyn
Park, MN
Multi Mind Foundation, Carlsbad, CA
Multimedia Learning Consortium,
Stockton, CA
Museum of Education Community &
Cultural Arts Inc., Jacksonville, FL
Museum of Life or Death Incorporated,
Irvington, NJ
Museum of Rock, Simi Valley, CA
IRB 1999-18 4/29/99 1:37 PM Page 7

May 3, 199981999–18 I.R.B.
Museums and Schools Information
Exchange, Washington, DC
Music Ministry – M & M Productions
Inc., Houston, TX
Muskegon Area Toys for Tots Inc.,
Muskegon, MI
Muskogee Dug Out Club, Muskogee, OK
My Jesus Mercy Ministries Inc.,
Philadelphia, PA
QFPM Inc., Detroit, MI
Quad-Cities Fiddlers Jamboree Ltd.,
Long Grove, IA
Qualicenters Patient Support
Corporation, Wheat Ridge, CO
Quality of Life Association of Lowndes
County Inc., Hayneville, AL
Quality of Life Foundation Inc., New
York, NY
Quam Performing Arts & Education
Center, Philadelphia, PA
Quapaw Community Center of Hot
Springs Arkansas, Hot Springs, AR
Quarterback Club – Carmichaels
Pennsylvania Inc., Carmichaels, PA
Queen of Peace Communications Inc.,
Chicago, IL
Queens Korean American Seniors Center
Inc., Elmhurst, NY
Quest for Peace International Inc.,
Naples, FL
Questarium Inc., Windham, ME
Quinlin Sports Association Inc., Quinlan,
TX
Quint-City Roughriders, Rock Island, IL
R D Brady Foundation for Prehospital
Research, Grand Rapids, MI
REAPInc., Georgetown, SC
RESTORE, Fargo, ND
Raccoon Valley Humane Society, Adel,
IA
Racers Against AIDS, Chula Vista, CA
Racing Babies Inc., Chicago, IL
Radiance Technique Association
Midwest, Chicago, IL
Radio Latina Inc., Kansas City, MO
Rahabs Roost, Sparta, TN
Rainbow After School Program Inc.,
Bronx, NY
Rainbow Center Inc. of New York,
Flushing, NY
Rainbow Christian Ministries Distress
Center, Ravena, NY
Rainbow Learning Center, Ypsilanti, MI
Rainbow Redirections Childrens Services
Inc., Pembroke Pines, FL
Rainbow Ridge Retreat, Ohio City, CO
Rainbow Services Incorporated, Harvard,
MA
Rainbows Bend Unlimited Inc., Spencer,
MA
Rainbows End Daycare Inc., Macks
Creek, MO
Rainforest Health Project Inc., Winona,
MN
Rainy Day Foundation, The Dalles, OR
Raisins Inc., Tampa, FL
Rancho Cucamonga Friendship for
Animals, Rancho Cucamonga, CA
Randant Foundation for Women &
Children, Mt. Prospect, IL
Randy Berg Ministries, Lavergne, TN
Ranees Beginnings, West Valley City, UT
Ranger Summer Theater, Hamburg, NJ
Ranken Community Development Corp.,
St. Louis, MO
Rapheal Craft Evangelistic Corporation,
Marshall, TX
Rapid River Scholarship Foundation,
Rapid River, MI
Rapids D A R E Inc., Alexandria, LA
Rapidan Area Country School
Association, Burnsville, MN
Rapport Foundation, Phoenix, AZ
Raulerson Ministries Inc., Punta Gorda,
FL
Ravens Youth Development
Organization, Amherst, MA
Ray of Hope Ministries, Woodburn, OR
Ray Silvious Memorial Golf Committee,
Lavale, MD
Reach for Tomorrow Inc., Fairfax, VA
Reach Ministries, Tyler, TX
Reach Ministries, Peoria, IL
Reach Out America a Non Profit TR
010193, Carmel, CA
Reach Out of Centralia, Centralia, IL
Reach the Children, Tesuave, NM
Reaching the Unreached-USA Ltd., Bay
Shore, NY
Readd, Richmond, IN
Reading Aerofest Inc., Reading, PA
Reading Beautification Inc., Reading, PA
Real Truth Community Service Center,
Kansas City, MO
Real World Foundation, Fryeburg, ME
Rear Guard Ministries Inc., Mobile, AL
Rear Window Art Gallery Inc.,
Winchester, VA
Receive Inc., Overland Park, KS
Recovery Assistance Program Inc.,
Wichita, KS
Recovery Fellowship Ministries Inc.,
Springfield, MO
Recovery From Addictions Inc.,
Southfield, MI
Recovery House Inc., Ocala, FL
Recovery Houston Institute Inc.,
Houston, TX
Recovery Processes Inc., Westerville, OH
Recovery Services Foundation, Wichita,
KS
Recreational Inner City Sports and
Education, Jamaica, NY
Red Powers Foundation Inc., Gold
Beach, OR
Red River Health Promotion Coalition,
Fargo. ND
Red Robin Residential Care Inc.,
Alpaugh, CA
Red Wings Area Bicycle Motocross
Association, Red Wing, MN
Redeeming Care Center Inc., Rahway, NJ
Reep of North Carolina, Durham, NC
Reflections of a Kaleidoscope Inc., Great
Barrington, MA
Regina Cleri High School Foundation,
Tucson, AZ
Regional Arts Association, Wolcott, CT
Regional Neighborhood Community
Development Corporation, New
Orleans, LA
Rehabilitation of Addictions Foundation
Inc., Houston, TX
Rehoboth Beach Jazz Festival Inc.,
Rehoboth Beach, DE
Rejoice Publications Inc., Columbia Hts,
MN
Relevancy Inc., Albuquerque, NM
Renaissance Foundation Inc.,
Washington, DC
Renaissance Healing Arts Center, Green
Bay, WI
Renascent Inc., New Orleans, LA
Renewal Fellowship, Golden Valley, MN
Renton Black Parents Association, Sear,
WA
Repaired of the Breach, Baton Rouge,
LA
Repairs of Broken Walls Inc., Detroit
Lakes, MN
Republic of Vietnam Armed Forces
Veteran Association in Greater,
Cleveland, OH
Research Foundation of the Southwest,
Fort Worth, TX
Research Institute for Computer
Applications, Baton Rouge, LA
Research Institute for the Prevention of
Starvation, Overland Park, KS
Research Institute International Inc.,
Gainesville, FL
Residence One Corporation, Tampa, FL
Residences for People With Autism Inc.,
Port Washington, NY
IRB 1999-18 4/29/99 1:37 PM Page 8

1999–18 I.R.B.9May 3, 1999
Resident Council of the Housing
Authority of Newport, Newport, KY
Resource Center Inc., Guyton, GA
Respect Incorporated, Evansville, IN
Responsive Resources Inc., Columbus,
OH
Restitution Coalition Inc., Amarillo, TX
Restoration Community Resources Inc.,
College Park, GA
Restoration Ministries Incorporated,
Indianapolis, IN
Restoration Project Inc., Acton, MA
Restructuring Education and Family
Opportunities Through Regenerative,
Albuquerque, NM
Resurrection House Inc., Laramie, WY
Resurrection Lutheran Parsonage Inc.,
Boston, MA
Revelation Knowledge Inc., Louisville,
KY
Rhode Island Coalition for Minority
Investment, Providence, RI
Richardo Richards School Project Esteem
Inc., St. Croix, VI
Rice Family Farms Consortium Inc.,
Atlanta, GA
Riceville Community Foundation Inc.,
Riceville, IA
Richard A Wolters Foundation Inc.,
Atlanta, GA
Richard Butch Anderson Memorial Trust
Fund, Clifton Park, NY
Richard Clark Ministries Inc., New
Haven, CT
Richard Miles Decker Memorial
Scholarship Funds, Beachwood, OH
Richland County Pheasants, Wyndmere,
ND
Richmond County Microenterprise Inc.,
Hamlet, NC
Richmond Youth Strive for Excellence
Corp., Richmond, CA
Ridgeland Community Tennis
Association, Ridgeland, MS
Ridglea Roughnecks Peewee Football
Association Inc., Ft. Worth, TX
Riding for America Inc., Fairbanks, AK
Right Moves for Youth Inc., Charlotte,
NC
Right Step Academy, St. Paul, MN
If an organization listed above submits
information that warrants the renewal of
its classification as a public charity or as a
private operating foundation, the Internal
Revenue Service will issue a ruling or de-
termination letter with the revised classi-
fication as to foundation status. Grantors
and contributors may thereafter rely upon
such ruling or determination letter as pro-
vided in section 1.509(a)–7 of the Income
Tax Regulations. It is not the practice of
the Service to announce such revised clas-
sification of foundation status in the Inter-
nal Revenue Bulletin.
IRB 1999-18 4/29/99 1:37 PM Page 9

May 3, 1999101999–18 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 Contribution Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign Corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statements of Procedral Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Definition of Terms
IRB 1999-18 4/29/99 1:37 PM Page 10

1999–18 I.R.B.11May 3, 1999
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 1999–17
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
99–36, 1999–16 I.R.B. 10
99–37, 1999–15 I.R.B. 9
99–38, 1999–15 I.R.B. 9
99–39, 1999–15 I.R.B. 10
99–40, 1999–16 I.R.B. 10
99–41, 1999–16 I.R.B. 10
99–42, 1999–16 I.R.B. 11
99–43, 1999–16 I.R.B. 11
99–44, 1999–16 I.R.B. 12
99–45, 1999–16 I.R.B. 12
99–46, 1999–16 I.R.B. 13
99–48, 1999–17 I.R.B.20
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
Notices—Continued
99–17, 1999–14 I.R.B.6
99–18, 1999–16 I.R.B. 4
99–19, 1999–16 I.R.B. 4
99–20, 1999–17 I.R.B.16
99–21, 1999–17 I.R.B. 19
Proposed Regulations:
REG–209103–89, 1999–11 I.R.B. 10
REG–209619–93, 1999–10 I.R.B. 28
REG–245562–96, 1999–9 I.R.B. 45
REG–104072–97, 1999–11 I.R.B. 12
REG–114663–97, 1999–6 I.R.B. 15
REG–114664–97, 1999–11 I.R.B. 21
REG–116826–97, 1999–10 I.R.B. 40
REG–118620–97, 1999–9 I.R.B. 46
REG–120168–97, 1999–12 I.R.B. 21
REG–121806–97, 1999–10 I.R.B. 46
REG–100729–98, 1999–14 I.R.B. 9
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
99–21, 1999–17 I.R.B. 18
99–22, 1999–15 I.R.B.5
99–23, 1999–16 I.R.B.5
Revenue Rulings:
99–1, 1999–2 I.R.B. 4
99–2, 1999–2 I.R.B. 5
Revenue Rulings—Continued
99–3, 1999–3 I.R.B. 4
99–4, 1999–4 I.R.B.19
99–5, 1999–6 I.R.B.8
99–6, 1999–6 I.R.B. 6
99–7, 1999–5 I.R.B. 4
99–8, 1999–6 I.R.B.8
99–9, 1999–7 I.R.B.14
99–10, 1999–10 I.R.B. 10
99–11, 1999–10 I.R.B. 18
99–12, 1999–11 I.R.B. 6
99–13, 1999–10 I.R.B. 4
99–14, 1999–13 I.R.B. 3
99–15, 1999–12 I.R.B.4
99–16, 1999–13 I.R.B.5
99–17, 1999–14 I.R.B. 4
99–18, 1999–14 I.R.B. 3
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
8818, 1999–17 I.R.B.3
IRB 1999-18 4/29/99 1:37 PM Page 11

May 3, 1999121999–18 I.R.B.
Finding List of Current Action on
Previously Published Items
1
Bulletins 1999–1 through 1999–17
Notices:
92–36
Modified by
Rev. Proc. 99–23, 1999–16 I.R.B. 5
96–64
Modified by
Rev. Proc. 99–23, 1999–16 I.R.B. 5
98–39
Modified by
Rev. Proc. 99–23, 1999–16 I.R.B. 5
98–52
Modified by
Rev. Proc. 99–23, 1999–16 I.R.B. 5
99–5
Modified by
Rev. Proc. 99–23, 1999–16 I.R.B. 5
Revenue Procedures:
78–10
Obsoleted by
99–12, 1999–3 I.R.B. 13
89–9
Modified by
99–23, 1999–16 I.R.B. 5
89–13
Modified by
99–23, 1999–16 I.R.B. 5
93–39, section 13
Modified by
99–23, 1999–16 I.R.B. 5
94–56
Superseded by
99–9, 1999–2 I.R.B. 17
95–12
Modified by
99–23, 1999–16 I.R.B. 5
97–23
Superseded by
99–3, 1999–1 I.R.B. 103
97–41
Modified by
99–23, 1999–16 I.R.B. 5
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
Revenue Procedures—Continued
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
98–14
Modified by
99–23, 1999–16 I.R.B. 5
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.
IRB 1999-18 4/29/99 1:37 PM Page 12

Index
Internal Revenue Bulletins
1999–1 Through 1999–17
For the index of items published during
1998, see I.R.B. 1999–1, dated Janu-
ary 4, 1999.
The abbreviation and number in paren-
thesis following the index entry refer to
the specific item; numbers in roman and
italic type following the parenthesis refer
to the Internal Revenue Bulletin in which
the item may be found and the page
number on which it appears.
Key to Abbreviations:
RRRevenue Ruling
RPRevenue Procedure
TDTreasury Decision
CDCourt Decision
PLPublic Law
EOExecutive Order
DODelegation Order
TDOTreasury Department Order
TCTax Convention
SPRStatement of Procedural
Rules
PTEProhibited Transaction
Exemption
EMPLOYEE PLANS
Automatic extension of time to file cer-
tain employee plan returns (Ann. 37)
15, 9
Determination letters (RP 6) 1, 187
Eligible rollover distributions; transitional
relief (Notice 5) 3, 10
Enrolled actuaries, examination program
(Ann. 25) 12, 35
Extension of remedial amendment period
(RP 23) 16, 5
Funding:
Full funding limitations, weighted aver-
age interest rate for January 1999
(Notice 7) 4, 23; February 1999 (No-
tice 11) 8, 56; March 1999 (Notice
15) 12, 21; April 1999 (Notice 21)
17, 19
Letter rulings, etc. (RP 4) 1, 115
Plan administration (Notice 1) 2, 8
Proposed Regulations:
26 CFR 1.401(a)(31)–1, amended; re-
lief from disqualification for plans
accepting rollovers (REG–245562–
96) 9, 45
EMPLOYEE PLANS—
Continued
26 CFR 1.402(f)–1, amended; required
explanation of eligible rollover dis-
tributions; questions and answers
(REG–118662–98) 13, 13
26 CFR 1.411(a)–7, –11, 1.417(e)–1,
amended; increase in cash-out limit
under sections 411(a)(7), 411(a)(11)
and 417(e)(1) for qualified retire-
ment plans (REG–113694–98) 7, 56
26 CFR 1.411(a)–11, amended; restric-
tion and valuation of distributions
(REG–118662–98) 13, 13
26 CFR 35.3405–1, amended; ques-
tions and answers relating to with-
holding on pensions, annuities, and
certain other deferred income (REG–
118662–98) 13, 13
Tax-sheltered annuities (RP 13) 5, 52
Technical advice (RP 5) 1, 158
User fees (RP 8) 1, 229
EMPLOYMENT TAX
Deferred compensation:
Change in method of accounting
(Notice 16) 13, 10
Disregarded entities (Notice 6) 3, 12
Federal Insurance Contributions Act
(FICA) taxation of amounts under
employee benefit plans; correction
(Ann. 41) 16, 10
Forms W-2 and W-3; format changes
postponed (Ann. 34) 15, 8
Penalty:
Failure to deposit penalty using elec-
tronic funds transfer (Notice 12) 9,
44; (Notice 20) 17, 16
Regulations:
26 CFR 31.3121(v)(2)–1, –2, added;
FICA tax amounts under employee
benefit plans (T.D. 8814) 9, 4
26 CFR 31.3306(r)(2)–1, added; FUTA
tax amounts under employee benefit
plans (T.D. 8815) 9, 31
ESTATE TAX
Proposed regulations:
26 CFR 20.2001–1, revised; valuation
of adjusted taxable gifts and section
2701(d) taxable events (REG–
106177–98) 12, 25
26 CFR 20.2055–1(d)(6), added;
20.2056(b)–4, amended; marital de-
duction; valuation of interest passing
to surviving spouse (REG–114663–
97) 6, 17
Valuation of adjusted taxable gifts and
section 2701(d) taxable events, REG–
106177–98; correction (Ann. 28) 13, 25
EXCISE TAX
Kerosene registration, provisions in final
regulations (Ann. 40) 16, 10
Penalty:
Failure to deposit penalty using elec-
tronic funds transfer (Notice 12) 9,
44; (Notice 20) 17, 16
Regulations:
26 CFR 49.4251–4, added; communi-
cations excise tax; prepaid telephone
cards (REG–118620–97) 9, 46
EXEMPT
ORGANIZATIONS
Letter rulings, etc. (RP 4) 1, 115
List of organizations classified as private
foundations (Ann 10) 5, 63; (Ann 13)
6, 20; (Ann 15) 8, 78; (Ann. 19) 10, 63;
(Ann. 20) 11, 53; (Ann. 22) 12, 32;
(Ann. 23) 15, 7; (Ann. 27) 13, 22;
(Ann. 32) 14,20; (Ann. 48) 17,20
Private foundations (Ann. 9) 4, 24
Regulations:
26 CFR 301.6104(d)–2 through –5, and
intermediary sections, added; public
disclosure of material relating to tax-
exempt organizations (T.D. 8818) 17,
3
Revocations (Ann. 45) 16, 12
Technical advice (RP 5) 1, 158
User fees (RP 8) 1, 229
GIFT TAX
Proposed regulations:
26 CFR 25.2504–2, revised; valuation
of certain gifts for preceding calendar
periods (REG–106177–98) 12, 25
Valuation of adjusted taxable gifts and
section 2701(d) taxable events, REG–
106177–98; correction (Ann. 28) 13, 25
INCOME TAX
Accounting period guidance (Notice 19)
16, 4
1999–18 I.R.B.13May 3, 1999
ESTATE TAX—
Continued
IRB 1999-18 4/29/99 1:37 PM Page 13

INCOME TAX—Continued
Action on Decision; court decisions in
1999–4 I.R.B. 4; correction (Ann. 17)
9, 59
Automobile owners and lessees (RP 14)
5, 56
Business expenses:
Lease-in / lease-out transactions (RR
14) 13, 3
Certain transfers of stock or securities by
U.S. persons to foreign corporations
and related reporting requirements;
correction (Ann. 42) 16, 11
Certain transfers to foreign partnerships
and foreign corporations; correction
(Ann. 43) 16, 11
Chief Counsel advice available for public
inspection (Ann. 4) 3,15
Child support enforcement program (RP
12) 3, 13
Commodities dealers; securities or com-
modities traders; procedures for mak-
ing elections (RP 17) 7, 52
Continuation coverage requirements ap-
plicable to group health plans; correc-
tion (Ann. 39) 15, 10
Credit for increasing research activities;
hearing (Ann. 38) 15, 9
CRT and capital gain modification (No-
tice 17) 14, 6
Cumulative Bulletin continued with a
new format (Ann. 36) 16, 10
Daily transportation expenses; commut-
ing expenses; business expenses; per-
sonal expenses (RR 7) 5, 4
Debt roll-ups; election to treat certain debt
substitutions as realization events (RP
18) 11, 7
Deficiencies:
Interest abatement, Presidentially de-
clared disasters (Notice 2) 2,8
Disregarded entity to partnership (RR 5)
6, 8
Election in respect of losses attributable to
a disaster (RR 13) 10, 4
Electronic:
Filing; magnetic media; 1998 Form
8596 (RP 9) 2, 17
Submission of Form W-5 (Ann. 3) 3,
15; Forms W-4P, W-4S and W-4V
(Ann. 6) 4,24
Enrolled actuaries, examination program
(Ann. 25) 12, 35
Exclusions-inclusions:
Payments for Temporary Assistance for
Needy Families (Notice 3) 2, 10
Failure by certain charitable organizations
to meet certain qualified requirements;
taxes on excess benefit transactions
(Ann. 21) 11, 55
Failure to deposit federal tax; penalties
(RP 10) 2, 11
Forms:
1040NR instructions for 1998, cor-
rected (Ann. 8) 4, 24
1042-S, request for public comments
(Ann. 24) 14, 12
8866 (Ann 16) 8, 80
Individual retirement arrangements:
Payroll deductions (Ann. 2) 2, 44
Recharacterizations and reconversions
(Ann. 5) 3,16
Insurance companies:
Tentative differential earnings rate for
1998 (Notice 13) 10, 26
Prevailing state assumed interest rates
(RR 10) 10, 10
Discounting estimated salvage recover-
able (RP 16) 7, 50
Loss reserves; discounting unpaid
losses (RP 15) 7, 42
Interest:
Investment:
Federal short-term, mid-term, and
long-term rates for January 1999
(RR 2) 2, 5; February (RR 8) 6,
10;March 1999 (RR 11) 10, 18;
April 1999 (RR 17) 14,4
Rates:
Underpayments and overpayments
for calendar quarter beginning
April 1, 1999 (RR 16) 13, 5
Interest netting for interest accruing be-
fore October 1, 1998 (RP 19) 13, 10
Inventory:
LIFO:
Price indexes; department stores for
November 1998 (RR 4) 4, 19;
December 1998 (RR 9) 7, 14;
January 1999 (RR15) 12,4; Feb-
ruary 1999 (RR 19) 15,3
Letter rulings, determination letters, and
information letters issued by Associate
Chief Counsel (Domestic), Associate
Chief Counsel (EBEO), Associate
Chief Counsel (Enforcement Litiga-
tion), and Associate Chief Counsel
(International) (RP 1) 1, 6
Long-term capital gain treatment for
1997-1998 fiscal year filers (Ann 11) 5,
64
Low-income housing tax credit:
Alternative collateral program (RP 11)
2, 14
1999 calendar year resident population
estimates (Notice 10) 6, 16
Satisfactory bond; “bond factor”
amounts for the period October
through December 1998 (RR 1) 2, 4;
January through March 1999 (RR
18) 14,3
Low-income taxpayer clinics grant pro-
gram (Notice 9) 4, 23
Mark-to-market election for regulated
investment companies that are share-
holders of PFICs (Notice 14) 11, 7
Model qualified intermediary withholding
agreement (Notice 8) 5, 26
Mutual holding company conversions
(RR 3) 3, 4
National median income – 1999 (RP 22)
15,5
Nonconventional source fuel credit, sec-
tion 29 inflation adjustment factor and
reference price (Notice 18) 16,4
Notice of significant reduction in the rate
of future benefit accrual, T.D. 8795;
correction (Ann. 31) 13, 26
OMB control numbers assigned pursuant
to the Paperwork Reduction Act; cor-
rection (Ann. 44) 16, 12
Optional standard mileage rates; effective
date (Ann. 7) 2, 45
Partnership to disregarded entity (RR 6) 6,
6
Passive foreign investment companies;
definition of marketable stock; correc-
tion (Ann. 35) 14, 22
Penalties:
Designation of Federal Tax Deposits
(RP 10) 2, 11
Penalty and interest study (Notice 4) 3, 9
Private foundations, organizations classi-
fied as (Ann. 10) 5, 63; (Ann. 13) 6, 20;
(Ann. 15) 8, 78; (Ann. 19) 10, 63;
(Ann. 20) 11, 53; (Ann. 22) 12, 32;
(Ann. 23) 15, 7; (Ann. 27) 13, 22;
(Ann. 32) 14, 20; (Ann. 48) 17, 20
Publications:
547 Revised (Ann. 33) 14, 21
584 Revised (Ann. 33) 14, 21
954 Revised (Ann. 26) 14, 20
Proposed regulations:
26 CFR 1.25A–0 thru 1.25A–5, added;
calculation of education credit and
general eligibility requirements
(REG–106388–98) 11, 27
May 3, 1999141999–18 I.R.B.
INCOME TAX—ContinuedINCOME TAX—Continued
IRB 1999-18 4/29/99 1:37 PM Page 14

26 CFR 1.42–5, –6, –11, –12, –13,
amended; 1.42–17, added; low-in-
come housing credit; compliance
monitoring, etc. (REG–114664–97)
11, 21
26 CFR 1.79–3, amended; group-term
insurance: uniform programs
(REG–209103–89) 11, 10
26 CFR 1.221–1, added; deduction for
interest on qualified education loans
(REG–116826–97), 10, 40
26 CFR 1.446–1, added; 1.471–12,
added; 1.475(c)–1, revised; 1.475(c)–
2, added; 1.475(e)–1, redesignated as
1.475(g)–1; 1.475(e)–1, added;
1.475(f)–1, –2, added; 1.475(g)–1,
amended; mark-to-market account-
ing for dealers in commodities and
traders in securities or commodities
(REG–104924–98) 10, 47
26 CFR 1.453–12, added; capital gains,
installment sales, unrecaptured sec-
tion 1250 gain (REG–110524–98)
10, 55
26 CFR 1.468B–0, amended;
1.468B–1, amended; 1.468B–5,
amended; 1.468B–6 thru 1.468B–9,
and intermediary sections, added;
1.1031(k)–1, amended; escrow funds
and other similar funds (REG–
209619–93) 10, 28
26 CFR 1.663(c)–1, amended;
1.663(c)–2, revised; 1.663(c)–3,
amended; 1.663(c)–4, redesignated;
1.663(c)–4, added; 1.663(c)–5,
amended; 1.663(c)–6, added; sepa-
rate share rules applicable to estates
(REG–114841–98) 11, 41
26 CFR 1.861–8, amended; 1.865–1,
added; 1.865–2, amended; allocation
of loss with respect to stock and
other personal property (REG–
106905–98) 11, 39
26 CFR 1.1296(e)–1, added; passive
foreign investment companies; defin-
itions of marketable stocks (REG–
113744–98), 10, 59
26 CFR 1.1362–3, amended; 1.1502–
76, amended; acquisition of an S cor-
poration by a member of a consoli-
dated group (REG–106219–98) 9, 51
26 CFR 1.1502–3, amended; 1.1502–
9A, added; new 1.1502–9, added;
consolidated overall foreign losses
and separate limitation losses (REG–
106902–98) 8, 57
26 CFR 1.1502–13, amended; inter-
company transactions (REG–
105964–98) 12, 22
26 CFR 1.6302–4, revised; 20.6302–1,
added; 25.6302–1, added; 31.6302–
1, amended; 40.6302(a)–1, added;
electronic funds transfers of federal
deposits (REG–100729–98) 14. 9
26 CFR 1.6695–1, amended; retention
of income tax return preparer’s sig-
nature (REG–106386–98) 12, 15
26 CFR 1.6695–2, added; preparer due
diligence requirements for determin-
ing earned income credit eligibility
(REG–120168–97) 12, 16
26 CFR 1.7701(1)–3, added; 1.1441–7,
amended; recharacterizing financing
arrangements involving fast–pay
stock (REG– 104072–97) 11, 12
26 CFR 54.4980B, amended; continua-
tion coverage requirements of group
health plans (REG–121865–98) 8,
63
26 CFR 301.6103(j)(1)–1, amended;
disclosure of return information to
the Bureau of Census (REG–
121806–97) 10, 46
26 CFR 301.6103(k)(9)–1, added;
301.6311–1(a)(1)(i), amended; pay-
ment of tax by credit card or debit
card (REG–111435–98) 7, 55
26 CFR 301.6221–1, amended;
301.6223(c)–1, amended;
301.6224(c)–3, amended;
301.6229(b)–2, added; 301.6229(f)–
1, added; 301.6231(a)(1)–1,
amended; 301.6231(a)(6)–1,
amended; 301.6231(a)(7)–1,
amended; modifications and addi-
tions to the unified partnership audit
procedures (REG–106564–98) 10, 53
26 CFR 301.6320–1, added; notice and
opportunity for hearing upon filing
of notice of lien (REG–116824–98)
7, 57
26 CFR 301.6330–1, added; notice and
opportunity for hearing prior to levy
(REG–117620–98) 7, 59
26 CFR 301.7502–1, revised;
301.7502–2, added; Timely mailing
treated as timely filing / electronic
postmark (REG–115433–98) 9, 54
26 CFR 801.0–1 thru 801.0–5, and in-
termediary sections, added; estab-
lishment of a balanced measurement
system (REG–119192–98) 11, 45
Proposed update of Rev. Proc. 65–17
(Ann. 1) 2, 41
Recharacterizing financing arrangements
involving fast-pay stock, REG–
104072–97; correction (Ann. 30) 11, 26
Refunds and credits:
Period of limitations, financial disabil-
ity (RP 21) 17, 18
Regulations:
26 CFR 1.411(a)–11(c)(2)(ii), revised;
1.411(a)–11(c)(2)(iii), (iv), (v), and
(c)(8), added; 1.411(a)–11T, re-
moved; 1.417(e)–1(b)(3), revised;
(b)(4), added; 1.417(e)–1T,
amended; qualified retirement plans
(T.D. 8796) 4, 16
26 CFR 1.148–5(d)(6)(iii), revised;
1.148–5(e)(2)(iv), added; arbitrage
restrictions on tax-exempt bond
(T.D. 8801) 4, 5
26 CFR 1.195–1, added; election to
amortize start-up expenditures for
active trades or businesses (T.D.
8797) 5, 5
26 CFR 1.337(d)–4, added; certain
asset transfers to a tax-exempt entity
(T.D. 8802) 4, 10
26 CFR 1.408A–0 through –9, and in-
termediary sections, added; Roth
IRAs (T.D. 8816) 8,4
26 CFR 1.411(a)–7, –11, amended;
1.411(a)–7T, –11T, added; increase
in cash-out limit under sections
411(a)(7), 411(a)(11) and 417(e)(1)
for qualified retirement plans (T.D.
8794) 7, 4
26 CFR 1.411(d)(4), amended;
1.411(d)–4T, removed; employee
stock ownership plans qualified re-
tirement plan benefits (T.D. 8806)
6, 4
26 CFR 1.411(d)–6T, removed;
1.411(d)–6, added; notice of signifi-
cant reduction in the rate of future
benefit accrual (T.D. 8795) 7, 8
26 CFR 1.469–10, revised; 1.7704–3,
added; certain investment income
under the qualifying income provi-
sions and the application of the pas-
sive activity loss rules to publicly
traded partnerships (T.D. 8799) 6, 12
26 CFR 1.664–1(a)(7), (d)(1)(iii),
(f)(4), added; 1.664–2(a)(1)(i), re-
vised; 1.664–3, amended; 25.2702–
1(c)(3), revised; charitable remain-
der trusts and special valuation rules
1999–18 I.R.B.15May 3, 1999
INCOME TAX—ContinuedINCOME TAX—ContinuedINCOME TAX—Continued
IRB 1999-18 4/29/99 1:37 PM Page 15

for transfers of interests in trusts
(T.D. 8791) 5, 7
26 CFR 1.861–8, amended; 1.861–8T,
amended; 1.865–1T, added; 1.865–2,
added; 1.865–2T, added; 1.904–0,
amended; 1.904–4, amended; alloca-
tion of loss with respect to stocks
and other personal property (T.D.
8805) 5, 14
26 CFR 1.871–14, revised; rules relat-
ing to repeal of tax on interest of
nonresident alien individuals and
foreign corporations received from
certain portfolio debt investments
(T.D. 8804) 12, 5
26 CFR 1.881–3, corrected conduit
arrangement regulations (Ann 14) 7,
60
26 CFR 1.1441–1, –5, –6, –9, revised;
1.1441–4, amended; 1.1441–8, re-
designated and amended; 1.1443–1,
revised; requirements for the deduc-
tion and withholding of tax on pay-
ments to foreign persons (T.D. 8804)
12, 5
26 CFR 1.1502–3T, –9(a), –9T(b)(1)(v)
and (vi), amended; consolidated re-
turns, limitation on recapture of
overall foreign loss accounts (T.D.
8800) 4, 20
26 CFR 1.6038B–1, amended;
1.6038B–2, added; notice of certain
transfers to foreign partnerships and
foreign corporations (T.D. 8817) 8,
51
26 CFR 1.6042–3, amended; dividends
subject to reporting; 1.6045–1,
amended; returns of information of
brokers and barter exchanges;
1.6049–5, amended; interest and
original issue discount subject to re-
porting after December 31, 1982
(T.D. 8804) 12, 5
26 CFR 1.6695–1, amended;
1.6695–1T, added; retention of in-
come tax return preparer’s signature
(temporary) (T.D. 8803) 12, 15
26 CFR 1.6695–2T, added; preparer
due diligence requirements for deter-
mining earned income credit eligibil-
ity (temporary) (T.D. 8798) 12, 16
26 CFR 1.7702B–1, –2, added; quali-
fied long-term care insurance con-
tracts (T.D. 8792) 7, 36
26 CFR 54.4980B–0 through –8, and
intermediary sections, added; contin-
uation coverage requirements of
group health plans (T.D. 8812) 8, 19
26 CFR 301.6103(j)(1)–1, amended;
301.6103(j)(1)–1T, added; disclo-
sure of return information to the Bu-
reau of Census (T.D. 8811) 10, 19
26 CFR 301.6103(k)(9)–1T, –2T,
added; payment of tax by credit card
or debit card (T.D. 8793) 7, 15
26 CFR 301.6221–1T, amended;
301.6223(c)–1T, amended;
301.6224(c)–3T, amended;
301.6229(b)–2T, added;
301–6229(f)–1T, added;
301.6231(a)(1)–1T, amended;
301.6231(a)(6)–1T, amended;
301.6231(a)(7)–1, amended;
301.6231(a)(7)–1, added; modifica-
tions and additions to the unified
partnership audit procedures (T.D.
8808) 10, 21
26 CFR 301.6320–1T, added; notice
and opportunity for hearing upon fil-
ing of notice of lien (T.D. 8810) 7, 19
26 CFR 301.6330–1T, added; notice
and opportunity for hearing prior to
levy (T.D. 8809) 7, 27
26 CFR 301.6404–2, added;
301.6404–2T. removed; abatement
of interest (T.D. 8789) 3, 5
26 CFR 301.7502–1, amended;
301.7502–1T, added; timely mailing
treated as timely filing / electronic
postmark (T.D. 8807) 9, 33
26 CFR 301.7701–5, amended;
301.7701–7, added; residence of
trusts and estates (T.D. 8813) 9, 34
26 CFR 602.101(b), amended; OMB
control numbers (T.D. 8818) 17, 3
Requirements for the deduction and with-
holding of tax on certain U.S. source
income paid to foreign persons, T.D.
8804; correction (Ann. 29) 13, 25
Roth IRAs:
Conversions on Form 8606, Nonde-
ductible IRAs (Ann. 18) 13, 21
Rulings:
Areas in which advance rulings will not
be issued:
Associate Chief Counsel (Domes-
tic), Associate Chief Counsel
(EBEO) (RP 3) 1, 103
Associate Chief Counsel (Interna-
tional) (RP 7) 1, 226
Specifications for Form 1042-S:
Rev. Proc. 98–44, 1998–32 I.R.B. 11;
correction (Ann. 12) 5, 65
Ann. 24, 1999–14 I.R.B. 12; correction
(Ann. 46) 16, 13
Section 911(d)(4) waiver; 1998 update
(RP 20) 14, 7
Standard Industry Fare Level (SIFL) rates
for the first half of 1999 (RR 12) 11,6
Technical advice to district directors and
chiefs, appeals offices, Associate Chief
Counsel (Domestic), Associate Chief
Counsel (EBEO), Associate Chief
Counsel (Enforcement Litigation), and
Associate Chief Counsel (International)
(RP 2) 1, 73
May 3, 1999161999–18 I.R.B.
INCOME TAX—Continued INCOME TAX—Continued INCOME TAX—Continued
IRB 1999-18 4/29/99 1:37 PM Page 16

Notes
1999–18 I.R.B.17May 3, 1999
IRB 1999-18 4/29/99 1:37 PM Page 17

Notes
May 3, 1999181999–18 I.R.B.
IRB 1999-18 4/29/99 1:37 PM Page 18

IRB 1999-18 4/29/99 1:37 PM Page 19

INTERNAL REVENUE BULLETIN
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IRB 1999-18 4/29/99 1:37 PM Page 20