Internal Revenue Bulletin 2000-26 (PDF rendition): IRS Announcements

Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.

INCOME TAX
Rev. Rul. 2000–31, page 1269.
Low-income housing credit; satisfactory bond; “bond
factor” amounts for the period April through June
2000.This ruling announces the monthly bond factor
amounts to be used by taxpayers who dispose of qualified
low-income buildings or interests therein during the period
April through June 2000.
EMPLOYEE PLANS
Rev. Proc. 2000–27, page 1272.
Qualified plans; determination letters; remedial
amendment period.This procedure opens the determina-
tion letter program to allow sponsors of qualified plans
within the meaning of section 401(a) or 403(a) of the Code
to request determination letters from the Service that take
into account all changes in the plan qualification require-
ments made by the Small Business Job Protection Act of
1996 and other recent legislation. It also extends the reme-
dial period under section 401(b) of the Code for amending
plans for these changes, as well as the remedial amendment
period for amending governmental and nonelecting church
plans for the Tax Reform Act of 1986. Rev. Procs. 98–14,
99–23, 2000–6, and 2000–20 modified.
Notice 2000–31, page 1274.
Weighted average interest rate update.The weighted
average interest rate for June 2000 and the resulting per-
missible range of interest rates used to calculate current lia-
bility for purposes of the full funding limitation of section
412(c)(7) of the Code are set forth.
Notice 2000–32, page 1274.
Rollovers; hardship distributions.This notice provides re-
lief relating to the exception to the definition of eligible
rollover distribution for hardship distributions, as provided
by sections 402(c)(4)(C) and 403(b)(8)(B) of the Code. No-
tice 99–5 modified.
EXEMPT ORGANIZATIONS
Announcement 2000–56, page 1281.
A list is provided of organizations that no longer qualify as
organizations to which contributions are deductible under
section 170 of the Code.
EXCISE TAX
T.D. 8887, page 1269.
Final regulations under section 6302 of the Code relate to
deposits of excise tax. Notice 97–15 obsoleted.
ADMINISTRATIVE
Announcement 2000–54, page 1276.
The Service is requesting comments from the public on pro-
posed revisions to Form 1042–S, Foreign Person’s U.S.
Source Income Subject to Withholding.
Internal Revenue
bbuulllleettiinn
Bulletin No. 2000–26
June 26, 2000
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
Department of the Treasury
Internal Revenue Service
Finding Lists begin on page ii.
Announcement of Declaratory Judgment Proceedings Under Section 7428 begins on page 1281.

June 26, 20002000–26 I.R.B.
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing offi-
cial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
general interest. It is published weekly and may be obtained
from the Superintendent of Documents on a subscription
basis. Bulletin contents are consolidated semiannually into
Cumulative Bulletins, which are sold on a single-copy basis.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of in-
ternal management are not published; however, statements
of internal practices and procedures that affect the rights
and duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the
revenue ruling. In those based on positions taken in rulings
to taxpayers or technical advice to Service field offices,
identifying details and information of a confidential nature
are deleted to prevent unwarranted invasions of privacy and
to comply with statutory requirements.
Rulings and procedures reported in the Bulletin do not have
the force and effect of Treasury Department Regulations,
but they may be used as precedents. Unpublished rulings
will not be relied on, used, or cited as precedents by Service
personnel in the disposition of other cases. In applying pub-
lished rulings and procedures, the effect of subsequent leg-
islation, regulations, court decisions, rulings, and proce-
dures must be considered, and Service personnel and oth-
ers concerned are cautioned against reaching the same con-
clusions in other cases unless the facts and circumstances
are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions, and Subpart B, Legislation and Related
Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to
these subjects are contained in the other Parts and Sub-
parts. Also included in this part are Bank Secrecy Act Admin-
istrative Rulings. Bank Secrecy Act Administrative Rulings
are issued by the Department of the Treasury’s Office of the
Assistant Secretary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The first Bulletin for each month includes a cumulative index
for the matters published during the preceding months.
These monthly indexes are cumulated on a semiannual basis,
and are published in the first Bulletin of the succeeding semi-
annual period, respectively.
The IRS Mission
Provide America’s taxpayers top quality service by help-
ing them understand and meet their tax responsibilities
and by applying the tax law with integrity and fairness to
all.
Introduction
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402.

Section 42.—Low-Income
Housing Credit
Low-income housing credit; satisfac-
tory bond; “bond factor” amounts for
the period April through June 2000.
This ruling announces the monthly bond
factor amounts to be used by taxpayers
who dispose of qualified low-income
buildings or interests therein during the
period April through June 2000.
Rev. Rul. 2000–31
In Rev. Rul. 90–60, 1990–2 C.B. 3, the
Internal Revenue Service provided guid-
ance to taxpayers concerning the general
methodology used by the Treasury De-
partment in computing the bond factor
amounts used in calculating the amount of
bond considered satisfactory by the Sec-
retary under § 42(j)(6) of the Internal
Revenue Code. It further announced that
the Secretary would publish in the Inter-
nal Revenue Bulletin a table of “bond fac-
tor” amounts for dispositions occurring
during each calendar month.
This revenue ruling provides in Table 1
the bond factor amounts for calculating
the amount of bond considered satisfac-
tory under § 42(j)(6) for dispositions of
qualified low-income buildings or inter-
ests therein during the period April
through June 2000.
2000–26 I.R.B.1269June 26, 2000
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
Table 1
Rev. Rul. 2000–31
Monthly Bond Factor Amounts for Dispositions Expressed
As a Percentage of Total Credits
Calendar Year Building Placed in Service
or, if Section 42(f)(1) Election Was Made,
the Succeeding Calendar Year
Month of 198719881989 19901991199219931994199519961997199819992000
Disposition
Apr ’00 31.27 46.78 62.87 79.5082.43 86.7291.1895.67 100.29 105.28 110.55 116.23 121.62 124.35
May ’0031.27 46.78 62.87 79.5082.19 86.4690.9095.3699.96 104.93 110.16 115.80 121.15 124.35
Jun ’0031.27 46.78 62.87 79.5081.95 86.2190.6395.0799.65 104.59 109.80 115.41 120.73 124.35
For a list of bond factor amounts applic-
able to dispositions occurring during other
calendar years, see the following revenue
rulings: Rev. Rul. 98–3, 1998–1 C.B. 248,
for dispositions occurring during the cal-
endar years 1996 and 1997; Rev. Rul.
98–13, 1998–1 C.B. 686, for dispositions
occurring during the period January
through March 1998; Rev. Rul. 98–31,
1998–1 C.B. 1269, for dispositions occur-
ring during the period April through June
1998; Rev. Rul. 98–45, 1998–2 C.B. 364,
for dispositions occurring during the pe-
riod July through September 1998; Rev.
Rul. 99–1, 1999–2 I.R.B. 4, for disposi-
tions occurring during the period October
through December 1998; Rev. Rul. 99–54,
1999–51 I.R.B. 675, for dispositions oc-
curring during the calendar year 1999; and
Rev. Rul. 2000–22, 2000–16 I.R.B. 880,
for dispositions occurring during the pe-
riod January through March 2000.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Gregory N. Doran of the Office
of Assistant Chief Counsel (Passthroughs
and Special Industries). For further infor-
mation regarding this revenue ruling, con-
tact Mr. Doran on (202) 622-3040 (not a
toll-free call).
Section 401.—Qualified
Pension, Profit-Sharing, and
Stock Bonus Plans
26 CFR1.401(b)–1: Certain retroactive changes in
plan.
A procedure describes when plans that are qual-
ified under § 401(a) or § 403(a) must be amended
for the Uruguay Round Agreements Act, the Uni-
formed Services Employment and Reemployment
Rights Act of 1994, the Small Business Job Pro-
tection Act of 1996, the Taxpayer Relief Act of
1997, and the Internal Revenue Service Restruc-
turing and Reform Act of 1998. See Rev. Proc.
2000–27, page 1272.
Section 6302.—Mode or Time of
Collection
26 CFR 40.6302(c)–1: Use of Government
depositaries.
T.D. 8887
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 40
Deposits of Excise Taxes
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations; and removal
of temporary regulations.
SUMMARY: This document contains
final regulations relating to the availabil-
ity of the safe harbor deposit rule based
on look-back quarter liability and affects
persons required to make deposits of ex-
cise taxes. This document also contains
final regulations related to floor stocks
taxes and affects persons liable for those
taxes. The regulations implement
changes made by the Small Business Job
Protection Act of 1996 and the Airport
and Airway Trust Fund Tax Reinstate-

ment Act of 1997.
DATES: Effective Date: These regula-
tions are effective June 8, 2000.
Applicability Dates: For dates of ap-
plicability of these regulations, see
§§40.6302(c)–1(c)(2)(iv)(C) and
40.6302(c)–2(b)(2)(iii)(C).
FOR FURTHER INFORMATION CON-
TACT: Susan Athy, (202) 622-3130 (not a
toll-free number).
SUPPLEMENTARY INFORMATION:
Background
Temporary regulations (T.D. 8740,
1998–1 C.B. 289) relating to the safe har-
bor deposit rule based on look-back quar-
ter liability and to floor stock taxes were
published in the Federal Register on De-
cember 29, 1997 (62 F.R. 67568) along
with a notice of proposed rulemaking
(REG–102894–97, 1998–1 C.B. 344)
cross-referencing the temporary regula-
tions (62 F.R. 67589). Written comments
and requests for a public hearing were so-
licited. However, no comments or re-
quests were received and no public hear-
ing was held.
The proposed regulations are adopted
without revision by this Treasury deci-
sion.
Effect on Other Documents
The following publication is obsolete
as of June 8, 2000:
Notice 97–15, 1997–1 C.B. 387.
Special Analyses
It has been determined that this Trea-
sury decision is not a significant regula-
tory action as defined in Executive Order
12866. Therefore, a regulatory assess-
ment is not required. It also has been de-
termined that section 553(b) of the Ad-
ministrative Procedure Act (5 U.S.C.
chapter 5) does not apply to these regula-
tions and, because these regulations do
not impose on small entities a collection
of information requirement, the Regula-
tory Flexibility Act (5 U.S.C. chapter 6)
does not apply. Therefore, a Regulatory
Flexibility Analysis is not required. Pur-
suant to section 7805(f) of the Internal
Revenue Code, the notice of proposed
rulemaking was submitted to the Chief
Counsel for Advocacy of the Small Busi-
ness Administration for comment on its
impact on small business.
Drafting Information
The principal author of these regula-
tions is Susan Athy, Office of Assistant
Chief Counsel (Passthroughs and Special
Industries). However, other personnel
from the IRS and Treasury Department
participated in their development.
* * * * *
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR part 40 is
amended as follows:
PART 40—EXCISE TAX
PROCEDURAL REGULATIONS
Paragraph 1. The authority citation for
part 40 continues to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. In §40.0–1, paragraph (a) is
amended by revising the second sentence
to read as follows:
§40.0–1 Introduction.
(a) * * * The regulations set forth ad-
ministrative provisions relating to the ex-
cise taxes imposed by chapters 31, 32, 33,
34, 36, 38, and 39 (except for the chapter
32 tax imposed by section 4181 (firearms
tax) and the chapter 36 taxes imposed by
sections 4461 (harbor maintenance tax)
and 4481 (heavy vehicle use tax)), and to
floor stocks taxes imposed on articles
subject to any of these taxes. * * *
* * * * *
§40.0–1T [Removed]
Par. 3. Section 40.0–1T is removed.
Par. 4. In §40.6011(a)–1, paragraph
(a)(2)(iii) is added to read as follows:
§40.6011(a)–1 Returns.
(a) * * *
(2) * * *
(iii) Floor stocks tax return. A return
reporting liability for a floor stocks tax
described in §40.0–1(a) is a return for the
calendar quarter in which the tax payment
is due and not the calendar quarter in
which the liability for tax is incurred.
* * * * *
§40.6011(a)–1T [Removed]
Par. 5. Section 40.6011(a)–1T is re-
moved.
Par. 6. Section 40.6302(c)–1 is
amended as follows:
1. Paragraph (c)(2)(iv) is added.
2. Paragraph (f)(1) is amended by
adding a sentence to the end of the para-
graph.
The additions read as follows:
§40.6302(c)–1 Use of Government de-
positaries.
* * * * *
(c) * * *
(2) * * *
(iv) Modification for new or reinstated
taxes–(A) Applicability. The safe harbor
rule of paragraph (c)(2)(i) of this section
is modified for any calendar quarter in
which a person’s liability for a class of tax
includes liability for any new or reinstated
tax. For this purpose, a new or reinstated
tax is—
(1) Any tax (including an alternative
method tax) that was not in effect at all
times during the look-back quarter; and
(2) Any alternative method tax that was
not in effect at all times during the month
preceding the look-back quarter.
(B) Modification. The safe harbor rule
of paragraph (c)(2)(i) of this section does
not apply to a class of tax unless the de-
posit of taxes in that class for each semi-
monthly period in the calendar quarter is
not less than the greater of—
(1) 1/6 of the net tax liability reported
for the class of tax for the look-back quar-
ter; or
(2) The sum of—
(i) 95 percent of the net tax liability in-
curred with respect to new or reinstated
taxes during the semimonthly period; and
(ii) 1/6 of the net tax liability reported
for all other taxes in the class for the look-
back quarter.
(C) Effective date. This paragraph
(c)(2)(iv) applies to tax liabilities for new
or reinstated taxes incurred after February
28, 1997, except that paragraph
(c)(2)(iv)(A)(2) of this section applies
only for calendar quarters beginning after
December 31, 1997.
* * * * *
(f) * * * (1) * * * Also, no deposit is re-
quired in the case of any floor stocks tax
described in §40.0–1(a).
* * * * *
§40.6302(c)–1T [Removed]
Par. 7. Section 40.6302(c)–1T is re-
moved.
June 26, 200012702000–26 I.R.B.

Par. 8. In §40.6302(c)–2, paragraph
(b)(2)(iii) is added to read as follows:
§40.6302(c)–2 Special rules for use of
Government depositaries under section
4681.
* * * * *
(b) * * *
(2) * * *
(iii) Modification for new chemicals—
(A) Applicability. The safe harbor rule of
paragraph (b)(2)(i) of this section is modi-
fied for any calendar quarter in which a per-
son’s liability for section 4681 tax includes
liability with respect to any new chemical.
For this purpose, a new chemical is any
chemical that was not subject to tax at all
times during the look-back quarter.
(B) Modification. The safe harbor rule
of paragraph (b)(2)(i) of this section does
not apply unless the deposit of section
4681 taxes for each semimonthly period
in the calendar quarter is not less than the
greater of—
(1) 1/6 of the net tax liability reported
under section 4681 for the look-back
quarter; or
(2) The sum of—
(i) 95 percent of the net tax liability in-
curred under section 4681 with respect to
the new chemical during the semimonthly
period; and
(ii) 1/6 of the net tax liability reported
under section 4681 with respect to all
other chemicals for the look-back quarter.
(C) Effective date. This paragraph
(b)(2)(iii) applies to tax liabilities for new
chemicals incurred after February 28, 1997.
* * * * *
§40.6302(c)–2T [Removed]
Par. 9. Section 40.6302(c)–2T is re-
moved.
Robert E. Wenzel,
Deputy Commissioner of
Internal Revenue.
Approved May 22, 2000.
Jonathan Talisman,
Deputy Assistant Secretary
of the Treasury.
(Filed by the Office of the Federal Register on June
7, 2000, 8:45 a.m., and published in the issue of the
Federal Register for June 8, 2000, 65 F.R. 36326)
2000–26 I.R.B.1271June 26, 2000

26 CFR 601.201: Rulings and determination letters.
(Also, Part I, § 401; § 1.401(b)–1.)
Rev. Proc. 2000–27
SECTION 1. PURPOSE
.01 This revenue procedure opens the
Internal Revenue Service’s determination
letter program to allow sponsors of quali-
fied plans to obtain determination letters
that take into account all the changes in
the qualification requirements made by
“GUST,” including those changes made
by the Small Business Job Protection Act
of 1996, Pub. L. 104–188 (“SBJPA”), that
are first effective in plan years beginning
after December 31, 1998. This procedure
also extends until the last day of the first
plan year beginning on or after January 1,
2001, the remedial amendment period
under § 401(b) of the Code for amending
plans for GUST, as well as the TRA ‘86
remedial amendment period for govern-
mental and nonelecting church plans. Fi-
nally, this revenue procedure extends by
an additional year the period of extended
reliance for certain plans that received fa-
vorable determination, opinion, or notifi-
cation letters under TRA ‘86.
.02 The term “GUST” refers to the fol-
lowing:
1 the Uruguay Round Agreements Act,
Pub. L. 103–465 (“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 the Internal Revenue Service Re-
structuring and Reform Act of 1998, Pub.
L. 105–206 (“RRA ‘98”).
SECTION 2. BACKGROUND
.01 Prior to June 26, 2000, plan spon-
sors could not request determination let-
ters under § 401(a) or § 403(a) that take
into account the changes in the qualifica-
tion requirements made by SBJPA that are
first effective in plan years beginning
after December 31, 1998, unless the de-
termination related to a terminating plan.
Instead, sponsors of individually-de-
signed plans, including volume submitter
plans, could request letters that take into
account all the changes in the qualifica-
tion requirements made by GUST other
than those changes made by SBJPA that
are first effective in plan years beginning
after December 31, 1998. (These letters
are referred to in this revenue procedure
as “GUST I letters.”) Alternatively, spon-
sors of individually-designed plans, in-
cluding volume submitter plans, had the
option to request determination letters
that do not take into account any of the
changes made by GUST, except for
changes to § 401(a)(26) and § 414(n).
(These letters are referred to as “pre-
GATT letters.”) Determination letters for
master or prototype (M&P) or regional
prototype plans that have not yet been
amended by their sponsors for GUST do
not consider the changes made by GUST.
See Rev. Proc. 98–14, 1998–1 C.B. 371,
as modified by Rev. Proc. 98–53, 1998–2
C.B. 456, and section 3.03 of Rev. Proc.
2000–6, 2000–1 I.R.B. 187.
.02 Proposed regulations (REG–
109101–98, 2000–16 I.R.B. 903) under
§ 411(d)(6), which were published in the
Federal Registeron March 29, 2000 (65
F.R. 16546), would permit qualified de-
fined contribution plans to be amended to
eliminate some alternative forms in which
an account balance can be paid under cer-
tain circumstances, and would permit cer-
tain transfers between defined contribu-
tion plans that are not permitted under
regulations now in effect. The proposed
regulations are proposed to be effective
upon publication of final regulations in
the Federal Registerand cannot be relied
upon before finalization.
.03 Under § 401(b), plan sponsors have
a remedial amendment period in which to
adopt GUST plan amendments. Rev.
Proc. 99–23, 1999–16 I.R.B. 5, provides
that the GUST remedial amendment pe-
riod for nongovernmental plans ends on
the last day of the first plan year begin-
ning on or after January 1, 2000. For gov-
ernmental plans, as defined in § 414(d),
the GUST remedial amendment period
ends on the later of (i) the last day of the
last plan year beginning before January 1,
2001, or (ii) the last day of the first plan
year beginning on or after the “1999 leg-
islative date” (that is, the 90
th
day after
the opening of the first legislative session
beginning after December 31, 1998, of
the governing body with authority to
amend the plan, if that body does not
meet continuously). The remedial
amendment period can be further ex-
tended by the timely submission of a de-
termination letter application. The end of
the GUST remedial amendment period is
the deadline for making all GUST plan
amendments, including plan amendments
reflecting the repeal of § 415(e) and other
plan amendments specifically enumerated
in Rev. Proc. 99–23. The GUST remedial
amendment period also applies with re-
spect to all disqualifying provisions of
new plans adopted or effective after De-
cember 7, 1994, and with respect to all
plan amendments adopted after December
7, 1994, which would cause an existing
plan to fail to be qualified.
.04 Rev. Proc. 2000–20, 2000–6 I.R.B.
553, includes a procedure for extending
the GUST remedial amendment period
for employers adopting M&P or volume
submitter plans. To be eligible for the ex-
tension, employers must either adopt an
M&P or volume submitter plan before the
end of the GUST remedial amendment
period (determined without regard to the
extension) or, before such time, certify
their intent to adopt a GUST-approved
M&P or volume submitter plan. Addi-
tionally, the M&P sponsor or volume sub-
mitter practitioner must request a GUST
opinion or advisory letter by December
31, 2000.
.05 Rev. Proc. 99–23 extended the TRA
‘86 remedial amendment period for gov-
ernmental plans to the end of the GUST
remedial amendment period for govern-
mental plans described above. The plan
amendments to which the TRA ‘86 reme-
dial amendment period applies are those
required to comply with the Tax Reform
Act of 1986, Pub. L. 99–514 (“TRA
‘86”) and subsequent legislation through
the Omnibus Budget Reconciliation Act
of 1993, Pub. L. 103–66 (“OBRA ‘93”).
.06 Under Notice 98–39, 1998–2 C.B.
205, nonelecting church plans are not re-
quired to be amended to comply with reg-
ulations under §§ 401(a)(4), 401(a)(5),
401(l), and 414(s) until the last day of the
first plan year beginning on or after Janu-
ary 1, 2001. However, under Rev. Proc.
99–23, these plans are required to be
amended to comply with other applicable
June 26, 200012722000–26 I.R.B.
Part III. Administrative, Procedural, and Miscellaneous

provisions of TRA ‘86 and subsequent
legislation through OBRA ‘93 by the end
of the generally applicable GUST reme-
dial amendment period, that is, the end of
the first plan year beginning on or after
January 1, 2000.
.07 Plans that were submitted to the
Service within certain deadlines for deter-
mination, opinion, or notification letters
under TRA ‘86 and received favorable
letters were entitled to extended reliance
on their letters. However, plans with ex-
tended reliance are required to be
amended to comply with regulations and
administrative guidance of general applic-
ability issued since the date of the plan’s
favorable TRA ‘86 letter. Rev. Proc.
99–23 extended the time for adopting
such amendments to the end of the GUST
remedial amendment period.
SECTION 3. PROGRAM OPENING
.01 Applications for determination let-
ters under § 401(a) or § 403(a) that are
filed with the Service on or after June 26,
2000, for individually-designed plans, in-
cluding volume submitter plans, will be
reviewed taking into account all the
changes in the qualification requirements
made by GUST, including those changes
made by SBJPA that are first effective in
plan years beginning after December 31,
1998, unless the sponsor asks the Service
to limit the extent to which the plan is re-
viewed for GUST, as described below.
(Determination letters that take into ac-
count all the GUST changes are referred
to in this revenue procedure as “GUST II
letters.” Except in the case of terminating
plans, the review of applications for de-
termination letters for M&P plans will
take into account the GUST changes only
to the extent that the M&P plan sponsor
has amended the plan for GUST and re-
ceived a favorable opinion letter.
.02 Until further notice, sponsors of in-
dividually-designed plans, including vol-
ume submitter plans, will continue to have
the option of limiting the extent to which
their plans are reviewed for GUST by re-
questing either a GUST I letter or a pre-
GATT letter, rather than a GUST II letter.
The sponsor should make this request in a
cover letter with the application. (This op-
tion does not apply to applications for de-
termination on plan termination.) Under
this option, the sponsor will need to sub-
mit another application and pay another
user fee to obtain a GUST II letter.
.03 Because the proposed regulations
under § 411(d)(6) may not be relied upon
prior to finalization, the proposed regula-
tions will not be taken into account by the
Service for purposes of issuing determi-
nation letters. Until such regulations are
finalized, the Service will not issue a fa-
vorable determination letter for a plan that
is amended to eliminate or reduce benefits
in a manner that is not permitted under
regulations now in effect. Therefore,
sponsors who are considering submitting
determination letter applications before
the proposed regulations under
§ 411(d)(6) are finalized should also be
aware that they may have to submit an-
other application and pay another user fee
if they wish to adopt plan amendments as
a result of the final regulations.
.04 In general, plans must be restated
when they are submitted for GUST II de-
termination letters. For this purpose, sub-
mission of a working copy of the plan in a
restated format will suffice. A plan is
generally exempt from the requirement to
restate, however, if there have been fewer
than four consecutive amendments since
the plan was last restated, excluding
amendments making only nonsubstantive
plan changes, the plan has a favorable
TRA ‘86 determination letter, and the
plan meets either of the following condi-
tions:
1 The plan is a defined contribution
plan under which the only contribu-
tions are nonelective employer con-
tributions; or
2 The plan has a favorable GUST I
determination letter and is not
adding provisions designed to sat-
isfy the safe harbor requirements of
§ 401(k)(12) or § 401(m)(11).
The Service nevertheless reserves the
right to require restatement of a plan or
submission of a working copy of a plan in
a restated format in any case in which this
is determined to be necessary.
.05 In general, Form 6406, Short
Form Application for Determination for
Minor Amendment of Employee Benefit
Plan, may not be used to apply for either
a GUST I or a GUST II letter. However,
if use of Form 6406 is not otherwise pre-
cluded by section 11 of Rev. Proc.
2000–6, Form 6406 may be used to
apply for a GUST II letter for a defined
contribution plan with a favorable
GUST I letter which does not include
provisions designed to satisfy the safe
harbor requirements of § 401(k)(12) or
§ 401(m)(11). In this case, the applica-
tion should include a cover letter indi-
cating the application is for a GUST II
letter. The Service reserves the right to
require the filing of a Form 5300 series
application in any case in which it deter-
mines that the use of Form 6406 is inap-
propriate.
.06 The Service will attempt to contact
each plan sponsor who has a Form 5300
determination letter application being re-
viewed by a determination letter specialist
on June 26, 2000, to determine if the
sponsor wishes to convert the application
to a GUST II application. The Service
will continue to process each other pend-
ing application in accordance with the
procedures in effect prior to June 26,
2000.
SECTION 4. EXTENSION OF THE
REMEDIAL AMENDMENT PERIOD
.01 The GUST remedial amendment
period for nongovernmental plans is ex-
tended to the last day of the first plan year
beginning on or after January 1, 2001.
The remedial amendment period for gov-
ernmental plans, as defined in § 414(d), is
extended to the later of (i) the last day of
the first plan year beginning on or after
January 1, 2001, or (ii) the last day of the
first plan year beginning on or after the
“2000 legislative date” (that is, the 90
th
day after the opening of the first legisla-
tive session beginning after December 31,
1999, of the governing body with author-
ity to amend the plan, if that body does
not meet continuously).
.02 In general, all plan provisions that
either cause a plan to fail to satisfy the
qualification requirements of the Code
because of changes to those requirements
made by GUST or are integral to a quali-
fication requirement changed by GUST
are disqualifying provisions under
§ 1.401(b)–1(b) of the regulations. Thus,
this extension of the GUST remedial
amendment period applies to all GUST
plan amendments, including all those
specifically enumerated in Rev. Proc.
99–23. In addition, this extends the reme-
dial amendment period with respect to all
disqualifying provisions of new plans
adopted or effective after December 7,
1994, and with respect to all plan amend-
2000–26 I.R.B.1273June 26, 2000

ments adopted after December 7, 1994,
which would cause an existing plan to fail
to be qualified.
.03 This extension also applies for pur-
poses of the time by which employers
must either adopt an M&P or volume sub-
mitter plan or certify their intent to adopt
a GUST-approved M&P or volume sub-
mitter plan in order to be eligible for the
extension described in section 19 of Rev.
Proc. 2000–20. However, the December
31, 2000, deadline for submission of ap-
plications for opinion and advisory letters
under section 19 of Rev. Proc. 2000–20 is
not extended.
.04 The TRA ‘86 remedial amendment
period for governmental plans is extended
to the end of the GUST remedial amend-
ment period for governmental plans de-
scribed above. The TRA ‘86 remedial
amendment period for nonelecting church
plans is extended to the end of the GUST
remedial amendment period for non-
governmental plans described above.
Thus, nonelecting church plans now have
a single amendment deadline for all
GUST and TRA ‘86 plan amendments, in-
cluding amendments relating to the
nondiscrimination requirements. The ad-
ditional 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 amend-
ment periods with respect to the applica-
ble nondiscrimination requirements.
SECTION 5. EXTENSION OF
EXTENDED RELIANCE PERIOD
The TRA ‘86 extended reliance period
is extended by an additional year. A plan
with extended reliance must 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 issued
since the date of the plan’s favorable TRA
‘86 determination letter. These amend-
ments must be made effective no later
than the first day of the plan year in which
the GUST remedial amendment period
ends, and, except in the case of M&P or
volume submitter plans, 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.)
SECTION 6. EFFECT ON OTHER
DOCUMENTS
Rev. Procs. 98–14, 99–23, 2000–6, and
2000–20 are modified.
SECTION 7. EFFECTIVE DATE
This revenue procedure is effective
June 26, 2000.
DRAFTING INFORMATION
The principal author of this revenue
procedure is James Flannery of the Tax
Exempt and Government Entities Divi-
sion. For further information regarding
this revenue procedure, contact the Em-
ployee Plans Division’s telephone assis-
tance 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.)
Weighted Average Interest Rate
Update
Notice 2000–31
Notice 88–73 provides guidelines for
determining the weighted average interest
rate and the resulting permissible range of
interest rates used to calculate current lia-
bility for the purpose of the full funding
limitation of § 412(c)(7) of the Internal
Revenue Code as amended by the Om-
nibus Budget Reconciliation Act of 1987
and as further amended by the Uruguay
Round Agreements Act, Pub. L. 103–465
(GATT).
The average yield on the 30-year Trea-
sury Constant Maturities for May 2000 is
6.15 percent.
The following rates were determined
for the plan years beginning in the month
shown below.
June 26, 200012742000–26 I.R.B.
90% to 105%90% to 110%
WeightedPermissiblePermissible
MonthYearAverageRangeRange
June20006.015.41 to 6.315.41 to 6.61
Drafting Information
The principal author of this notice is
Todd Newman of the Employee Plans,
Tax Exempt and Government Entities Di-
vision. For further information regarding
this notice, call the Employee Plans Actu-
arial hotline, (202) 622-6076 between
2:30 and 3:30 p.m. Eastern time (not a
toll-free number). Mr. Newman’s number
is (202) 622-8458 (also not a toll-free
number).
Eligible Rollover Distributions
Notice 2000–32
I. PURPOSE
This notice provides additional relief
relating to the exception to the definition
of eligible rollover distribution for certain
hardship distributions. This exception
was added to §§ 402(c)(4) and
403(b)(8)(B) of the Internal Revenue
Code (the “Code”) by § 6005(c)(2)(A)
and (B) of the Internal Revenue Service
Restructuring and Reform Act of 1998,
Pub. L. 105–206 (“RRA 98”). Transition
relief and guidance relating to the excep-
tion was initially provided in Notice
99–5, 1999–3 I.R.B. 10. In response to
comments from representatives of plan
sponsors and recordkeepers regarding
their significant difficulties in implement-
ing certain requirements of Notice 99–5,
this notice provides permanent relief to
sponsors of qualified plans where records

pertaining to pre-1989 contributions are
unavailable, and also provides transition
relief to sponsors of both qualified plans
and § 403(b) annuities from certain other
requirements of Notice 99–5.
II. BACKGROUND
Section 401(a)(31) requires a qualified
plan to permit distributees to elect to have
an eligible rollover distribution paid di-
rectly to an eligible retirement plan speci-
fied by the distributee.
Section 403(b)(10) provides that a
§ 403(b) annuity must meet requirements
similar to the requirements of
§ 401(a)(31).
Section 402(c)(4) generally provides
that any distribution of all or any portion
of the balance to the credit of an em-
ployee in a qualified plan is an eligible
rollover distribution. However, as excep-
tions to this general rule, that section
specifies certain distributions that are not
eligible rollover distributions.
Prior to amendment by RRA 98, the
only exceptions to the definition of eligi-
ble rollover distribution provided for in
§ 402(c) were any distribution that is one
of a series of substantially equal periodic
payments made for certain periods, any
distribution to the extent such distribution
is required under § 401(a)(9), and any dis-
tribution that is not includible in gross in-
come (determined without regard to the
exclusion for net unrealized appreciation
described in § 402(e)(4)).
Section 403(b)(8) provides that rules
similar to those in § 402(c)(4) apply for
purposes of determining the amount eligi-
ble for rollover from a § 403(b) annuity.
Section 1.403(b)–2, Q&A-1 provides that
an eligible rollover distribution from a
§ 403(b) annuity is an eligible rollover
distribution described in § 402(c)(4) and
§ 1.402(c)–2, except that the distribution
is from a § 403(b) annuity rather than a
qualified plan.
Section 6005(c)(2)(A) of RRA 98
added § 402(c)(4)(C) to the Code, which
specifies an additional exception to the
definition of eligible rollover distribution
for any hardship distribution described in
§ 401(k)(2)(B)(i)(IV), effective for distri-
butions after December 31, 1998. Section
6005(c)(2)(B) of RRA 98 amended
§ 403(b)(8)(B) of the Code to include a
specific reference to § 402(c)(4)(C).
Thus, the new exception also applies to
distributions from § 403(b) annuities.
Section 401(k)(2)(B)(i) provides that
contributions made under a qualified cash
or deferred arrangement (“CODA”) are
not permitted to be distributed earlier than
the occurrence of certain specified events.
Under § 401(k)(2)(B)(i)(IV), an em-
ployee’s elective contributions may be
distributed upon the hardship of the em-
ployee. Section 1.401(k)–1(d)(2)(ii) pro-
vides that qualified nonelective and quali-
fied matching contributions that were
treated as elective contributions, plus
earnings on these contributions and on
elective contributions, credited to an em-
ployee’s account as of a date specified in
the plan containing the qualified CODA
(which date generally was required to be
before July 1, 1989) may also be distrib-
uted upon the hardship of the employee.
The date described in the preceding sen-
tence is hereinafter referred to as the “‘89
date” and the amounts described in the
preceding sentence are hereinafter re-
ferred to as “pre-’89 401(k) amounts.”
Contributions not made under a qualified
CODA, such as matching contributions or
profit-sharing contributions, are not de-
scribed in § 401(k)(2)(B)(i)(IV).
Sections 403(b)(1) and 403(b)(11) pro-
vide that amounts contributed pursuant to
a salary reduction agreement for years be-
ginning after December 31, 1988, are not
permitted to be distributed earlier than the
occurrence of certain specified events.
Under § 403(b)(11)(B), such amounts
may be distributed upon the hardship of
the employee. Amounts held in an annu-
ity contract described in § 403(b)(1) as of
the close of the last year beginning before
January 1, 1989, and amounts contributed
to the contract as nonelective employer
contributions are generally not subject to
distribution restrictions.
Sections 403(b)(7) and 403(b)(11) pro-
vide that amounts contributed to a custo-
dial account described in § 403(b)(7) are
not permitted to be distributed earlier than
the occurrence of certain specified events.
Under §§ 403(b)(7) and 403(b)(11), con-
tributions made pursuant to a salary re-
duction agreement, as well as any other
amounts held in the custodial account as
of the close of the last year beginning be-
fore January 1, 1989, may be distributed
upon the hardship of the employee.
Notice 99–5 provided transition relief
from the requirements of § 6005(c)(2)(A)
and (B) of RRA 98 by permitting quali-
fied plans and § 403(b) annuities to treat
those distributions made in calendar year
1999 that would have been eligible
rollover distributions under § 402(c)(4)
immediately prior to its amendment by
RRA 98 as eligible rollover distributions
for all purposes under the Code.
Notice 99–5 also provided that, for pur-
poses of § 6005(c)(2)(A) and (B) of RRA
98, “a hardship distribution described in
§ 401(k)(2)(B)(i)(IV)” includes only
amounts described in § 1.401(k)–1
(d)(2)(ii), including pre-’89 401(k)
amounts, and does not include amounts
that are distributable under the Code with-
out regard to the hardship of the employee.
Similar rules were provided with respect to
§ 403(b) annuities. In addition, Notice
99–5 provided that if another event occurs,
such as the employee’s separation from
service or attainment of age 59 1/2, so that
distribution of an amount is permitted
under the Code, without regard to hard-
ship, no amount distributed after that event
is ineligible for rollover treatment on ac-
count of being a hardship distribution de-
scribed in § 401(k)(2)(B)(i)(IV). Lastly,
Notice 99–5 provided that if a portion of a
distribution that includes a hardship distri-
bution is not includible in gross income,
the portion of the distribution that is not in-
cludible in gross income is first allocated
to the hardship distribution. Notice 99–5
provided that the above rules were first ap-
plicable to distributions made after De-
cember 31, 1999.
III. DEFINITIONS
For purposes of this notice, a Ҥ 403(b)
annuity” includes an annuity contract, a
custodial account, and a retirement in-
come account described in § 403(b) (see
§ 1.403(b)–2, Q&A-1) and a “qualified
plan” is an employees’ trust described in
§ 401(a) that is exempt from tax under
§ 501(a) or an annuity plan described in
§ 403(a) (see § 1.402(c)–2, Q&A-2).
IV. RELIEF
Representatives of plan sponsors and
recordkeepers have raised concerns about
certain of the requirements of Notice 99–5.
Those representatives indicated that, in
many cases, plan records were inadequate
to comply with the requirement that
amounts treated as ineligible for rollover by
reason of RRA 98 be limited to the amount
2000–26 I.R.B.1275June 26, 2000

described in § 1.401(k)–1(d)(2)(ii), particu-
larly with respect to pre-’89 401(k)
amounts. In addition, it was stated that, in
light of the extensive revisions to computer
systems required to prevent “Y2K” prob-
lems, plan sponsors and recordkeepers
were unable to modify their systems to
comply with certain other requirements of
Notice 99–5 by January 1, 2000, the date
transition relief under Notice 99–5 became
no longer available.
In response to these concerns, the re-
quirements of Notice 99–5 are modified
as follows:
(i)Pre-’89 401(k) Amounts.As noted,
under Notice 99–5, amounts that are
ineligible for rollover by reason of
§ 6005(c)(2)(A) of RRA 98 are lim-
ited to amounts described in
§ 1.401(k)–1(d)(ii), including pre-’89
401(k) amounts. Concerns have been
raised that, in many instances, plan
records do not make it possible to dis-
tinguish pre-’89 401(k) amounts from
other amounts credited to an em-
ployee’s account as of the ‘89 date.
Accordingly, if a qualified
plan’s records are not reasonably
available to segregate an employee’s
pre-’89 401(k) amounts from other
amounts that, as of the ‘89 date, were
credited to the employee’s account,
then, for purposes of determining
what is an eligible rollover distribu-
tion, the plan must treat the other
amounts as described in § 401(k)(2)–
(B)(i)(IV). That is, the other amounts
are treated the same as pre-’89 401(k)
amounts and elective contributions
and are therefore treated as ineligible
for rollover when distributed on
account of hardship.
(ii)Satisfaction of Another Statutory Dis-
tributable Event. Notice 99–5 pro-
vides that, if another event occurs,
such as the employee’s separation
from service or attainment of age 59
1/2, so that distribution of an amount
is permitted under § 401(k)(2)(B),
§ 403(b)(7) or § 403(b)(11) without
regard to hardship, no amount distrib-
uted after that event is ineligible for
rollover treatment on account of being
a hardship distribution described in
§ 401(k)(2)(B)(i)(IV), § 403(b)(7) or
§ 403(b)(11). Plan sponsors and
recordkeepers indicated to the Service
that, in many instances, their systems
are unable to track whether a distribu-
tion made on account of hardship
under the terms of the plan might also
be distributable under another statu-
tory provision.
Therefore, as an alternative to
the rule in Notice 99–5, until further
guidance is issued, a distribution that
is described in § 401(k)(2)(B)(i)(IV),
§ 403(b)(7) or § 403(b)(11) and that is
made as a hardship distribution under
the terms of a qualified plan or
§ 403(b) annuity may be treated as
ineligible for rollover even though
another event has occurred that could
entitle the recipient to a distribution
without regard to hardship under
§ 401(k)(2–)(B)(i)(IV), § 403(b)(7) or
§ 403(b)–(11). Thus, for example, if a
profit-sharing plan containing a qual-
ified CODA provides that in-service
distributions are available only upon
hardship, an in-service distribution
made to a participant aged 62 may, to
the extent of elective contributions
and other amounts described in
§ 1.401(k)–1(d)(2)(ii) (including
amounts described in (i) above that
are treated as pre-’89 401(k)
amounts), be treated as ineligible for
rollover. Alternatively, if the rule in
Notice 99–5 is followed, the distribu-
tion in this example to the age-62 par-
ticipant may be treated as eligible for
rollover.
(iii)Allocation of Basis. The plan sponsor
and recordkeeper community also
raised concerns about the feasibility of
timely programming their systems to
follow the basis allocation rules of
Notice 99–5. Therefore, until further
guidance is issued, if a portion of a
hardship distribution from a qualified
plan or a § 403(b) annuity is not in-
cludible in gross income, the portion
of the distribution that is not includi-
ble in gross income may be allocated
to the portion ineligible for rollover or
the portion eligible for rollover (or be-
tween the two portions) using any rea-
sonable method.
A qualified plan or § 403(b) annuity
generally must, in applying the above
rules, be consistent in the treatment of all
distributions.
V. EFFECT ON OTHER DOCUMENTS
Notice 99–5 is modified.
VI. DRAFTING INFORMATION
The principal author of this notice is
Roger Kuehnle of the Tax Exempt and
Government Entities Division. For fur-
ther information regarding this notice,
please contact the Employee Plans’ tax-
payer assistance telephone service at
(202) 622-6074/6075 (not toll-free num-
bers) between the hours of 1:30 and 3:30
p.m. Eastern Time, Monday through
Thursday.
Proposed 2001 Form 1042-S,
Foreign Person’s U.S. Source
Income Subject to Withholding
Announcement 2000–54
The Internal Revenue Service announces
that it is requesting comments from the
public on proposed revisions to the 2001
Form 1042-S. This form is used by U.S.
withholding agents to report the withhold-
ing of U.S. income tax on certain U.S.
source income paid to foreign persons.
This announcement provides a draft
copy of the 2001 Form 1042-S. The form
is being issued so that withholding agents
can adapt their systems to comply with
the regulations under sections 1441, 1442,
and 1443, which were recently amended
by T.D. 8881 (published on May 22,
2000, in 65 F.R. 32152 and again on June
5, 2000, in 2000–23 I.R.B 1158). Filers
and recipients of the form are advised that
the form may be revised based on further
developments and comments.
Form 1042-S was previously released
for public comments on April 19, 1999
(Announcement 99–46, 1999–16 I.R.B.
13). We made the following changes to
the form as the result of those comments:
•VOID box.This box has been added to
the recipient copies (Copies B, C & D).
•Box 2 (Gross income), Box 4 (Net in-
come), Box 7 (U.S. Federal tax with-
held), andBox 8 (Amount reim-
bursed to recipient).We increased the
width of these boxes.
•Box 9 (Withholding agent’s EIN) and
Box 14 (Recipient’s U.S. TIN).We
increased the width of the checkboxes
so that they are easier to line up in a
printer.
•Box 10 (Withholding agent’s name
and address) and Box 13 (Recipient’s
name and address). We positioned
June 26, 200012762000–26 I.R.B.

these boxes so that the information en-
tered will show through a standard dou-
ble window envelope. In doing so, we
increased the vertical size of box 13 so
that 6 lines are available in the entry
area (allowing for 4 lines of print and 2
extra lines for printer line-up).
•Box 11 (Recipient’s account num-
ber).We increased the available entry
area.
•Box 19 (Nonqualified intermedi-
ary’s/Flow-through entity’s address).
We increased the height of this box.
•Income codes on the back of Copy C.
We changed the codes back to the way
they were on the 2000 form (i.e., income
codes 01 through 28 are the same on the
2000 and 2001 forms). New codes 29
through 31 have been added, but are
grouped with the other Interest Income
codes. New code 32 has been added and
placed with the Other Income codes.
Form 1042-S, as designed for the year
2001, contains only one income line. Some
commentators requested that we restore
multiple income reporting lines (i.e., lines 1
through 3 of the current year 2000 form).
Although we were not able to accommo-
date this comment, in an effort to mitigate
the impact of this change, a withholding
agent may be permitted to use substitute
payee copies of the form (i.e., copies B, C,
and D) that contain more than one income
line. Under no circumstances, however,
will the copy of the form filed with the IRS
(copy A) be permitted to contain more than
one income line (i.e., boxes 1 through 8).
The following change has been made to
the form as the result of changes to the
regulations made by T.D. 8881: The
PRO-RATA BASIS REPORTING box
at the top of the form was added as an in-
dicator that the withholding agent must
use to notify the IRS that a nonqualified
intermediary that used the alternative pro-
cedures of Regulations section
1.1441–1(e)(3)(iv)(D) (i.e., year-end allo-
cation) failed to properly comply with
those allocation requirements. If this box
is checked, withholding agents will be in-
structed to complete box 5 (Tax rate) by
including the appropriate rate of withhold-
ing in the box, not the rate of withholding
actually applied. For example, a with-
holding agent that withheld 15% from
payments made to a nonqualified interme-
diary should place 30% in box 5 for pay-
ments it reports under the pro rata report-
ing rule of sec. 1.1441–1(e)(3)(iv)(D)(6).
Several respondents inquired as to the
intended use for box 8. This new box was
added to reflect the reimbursement proce-
dure described in Regulations section
1.1461–2(a)(2)(i).
We anticipate that the instructions for
Form 1042-S will state that a qualified in-
termediary reporting payments on behalf
of a private arrangement intermediary
(PAI) must treat each PAI as a separate re-
cipient and therefore must file a separate
Form 1042-S for each withholding rate
pool paid to a PAI.
The IRS would like to receive comments
on this proposed draft form from all inter-
ested persons by July 26, 2000. Please
send comments to Chairman, Tax Forms
Coordinating Committee, Internal Revenue
Service, OP:FS:FP, Room 5577, 1111 Con-
stitution Avenue, NW, Washington, DC
20224. Alternatively, you may e-mail your
comments to tfpmail@publish.no.irs.gov.
2000–26 I.R.B.1277June 26, 2000

June 26, 200012782000–26 I.R.B.

2000–26 I.R.B.1279June 26, 2000

June 26, 200012802000–26 I.R.B.

Deletions from Cumulative List
of Organizations Contributions
to Which are Deductible Under
Section 170 of the Code
Announcement 2000–56
The names of organizations that no
longer qualify as organizations de-
scribed in section 170(c)(2) of the Inter-
nal Revenue Code of 1986 are listed
below.
Generally, the Service will not disal-
low 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 Ser-
vice is not precluded from disallowing a
deduction for any contributions made
after an organization ceases to qualify
under section 170(c)(2) if the organiza-
tion has not timely filed a suit for de-
claratory judgment under section 7428
and if the contributor (1) had knowledge
of the revocation of the ruling or deter-
mination letter, (2) was aware that such
revocation was imminent, or (3) was in
part responsible for or was aware of the
activities or omissions of the organiza-
tion that brought about this revocation.
If on the other hand a suit for declara-
tory judgment has been timely filed,
contributions from individuals and orga-
nizations described in section 170(c)(2)
that are otherwise allowable will con-
tinue to be deductible. Protection under
section 7428(c) would begin on June 26,
2000, and would end on the date the
court first determines that the organiza-
tion is not described in section 170(c)(2)
as more particularly set forth in section
7428 (c)(1). For individual contributors,
the maximum deduction protected is
$1,000, with a husband and wife treated
as one contributor. This benefit is not
extended to any individual, in whole or
in part, for the acts or omissions of the
organization that were the basis for re-
vocation.
Babbie Mason Ministries, Inc.
Marietta, GA
Sanborn Community Development, Inc.
Sanborn, MN
Notice of Disposition of
Declaratory Judgment
Proceedings Under Section
7428
This announcement serves notice to
donors that on November 23, 1999, the
United States District Court for the District
of Columbia entered a Stipulation of Dis-
missal in response to the parties’ request.
By entering the Stipulation, the Court
agreed that the organization listed below is
not an organization recognized as tax ex-
empt under section 501(a) of the Internal
Revenue Code and is not described in sec-
tions 170(c)(2) and 501(c)(3) retroactive to
January 1, 1991. The organization listed
below reapplied to the Service for recogni-
tion of exempt status, and the Service has
recognized the organization as tax exempt
under section 501(a) and as an organiza-
tion described in sections 170(c)(2) and
501(c)(3) effective January 1, 1997.
The Freedom Alliance
Dulles, VA
Notice of Disposition of
Declaratory Judgment
Proceedings Under Section
7428
This announcement serves notice to
donors that on January 18, 2000, the United
States Tax Court entered a Decision accept-
ing the agreement of the parties that the or-
ganization listed below is recognized as an
organization described in section 170(c)(2)
and section 501(c)(3) which is exempt from
tax under section 501(a).
Oriana House, Inc.
Akron, OH
Notice of Disposition of
Declaratory Judgment
Proceedings Under Section
7428
This announcement serves notice to
donors that on April 13, 2000, the United
States Tax Court entered a Decision ac-
cepting the agreement of the parties that
the exempt status of the organization listed
below is retroactively revoked effective
January 1, 1986. Further, by letter dated
April 7, 2000, the Commissioner has rec-
ognized the organization listed below as
an exempt organization described in sec-
tions 170(c)(2) and 501(c)(3) for periods
of time on and after January 1, 1990.
United Cancer Council, Inc.
Indianapolis, IN
Notice of Disposition of
Declaratory Judgment
Proceedings Under Section
7428
This announcement serves notice to
donors that on May 11, 2000, the United
States Tax Court entered a Decision ac-
cepting the agreement of the parties that
the organization listed below is not recog-
nized as an organization described in sec-
tion 170(c)(2) and section 501(c)(3) and
is not exempt from tax under section
501(a) effective July 1, 1998.
Lenox Institute of Water Technology, Inc.
Lenox, MA
Notice of Disposition of
Declaratory Judgment
Proceedings Under Section
7428
This announcement serves notice to
donors that on May 16, 2000, the Court of
Federal Claims entered an Order of Dis-
missal in response to the parties’ Stipula-
tion for Entry of Judgment. The Court or-
dered and agreed that the organization
listed below is not an organization de-
scribed under sections 170(c)(2) and
501(c)(3) of the Internal Revenue Code
and is not recognized as exempt under
section 501(a) for the years beginning
June 1, 1979 and June 1, 1980. The Court
further agreed that the organization listed
below is an organization described in sec-
tions 170(c)(2) and 501(c)(3) and is rec-
ognized as exempt under section 501(a)
beginning June 1, 1981.
St. Matthew Publishing, Inc.
Los Angeles, CA
2000–26 I.R.B.1281June 26, 2000
Part IV. Items of General Interest

Section 7428(c) Validation of
Certain Contributions Made
During Pendency of Declaratory
Judgment Proceedings
This announcement serves notice to po-
tential donors that the organization listed
below has recently filed a timely declara-
tory judgment suit under section 7428 of
the Code, challenging revocation of its
status as an eligible donee under section
170(c)(2).
Protection under section 7428(c) of the
Code begins on the date that the notice of
revocation is published in the Internal
Revenue Bulletin and ends on the date on
which a court first determines that an or-
ganization is not described in section
170(c)(2), as more particularly set forth in
section 7428(c)(1). In the case of individ-
ual contributors, the maximum amount of
contributions protected during this period
is limited to $1,000.00, with a husband
and wife being treated as one contributor.
This protection is not extended to any in-
dividual who was responsible, in whole or
in part, for the acts or omissions of the or-
ganization that were the basis for the re-
vocation. This protection also applies
(but without limitation as to amount) to
organizations described in section
170(c)(2) which are exempt from tax
under section 501(a). If the organization
ultimately prevails in its declaratory judg-
ment suit, deductibility of contributions
would be subject to the normal limitations
set forth under section 170.
Program to Aid Drug Abusers, Inc.
Lakeland, FL
June 26, 200012822000–26 I.R.B.

2000–25 I.R.B.iJune 19, 2000
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus,
if an earlier ruling held that a principle
applied to A, and the new ruling holds
that the same principle also applies to B,
the earlier ruling is amplified. (Compare
with modified, below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously
published ruling and points out an essen-
tial difference between them.
Modified is used where the substance
of a previously published position is
being changed. Thus, if a prior ruling
held that a principle applied to A but not
to B, and the new ruling holds that it ap-
plies to both A and B, the prior ruling is
modified because it corrects a published
position. (Compare with amplified and
clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used
in a ruling that lists previously published
rulings that are obsoleted because of
changes in law or regulations. A ruling
may also be obsoleted because the sub-
stance has been included in regulations
subsequently adopted.
Revoked describes situations where the
position in the previously published rul-
ing is not correct and the correct position
is being stated in the new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a pe-
riod of time in separate rulings. If the
new ruling does more than restate the
substance of a prior ruling, a combination
of terms is used. For example, modified
and superseded describes a situation
where the substance of a previously pub-
lished ruling is being changed in part and
is continued without change in part and it
is desired to restate the valid portion of
the previously published ruling in a new
ruling that is self contained. In this case
the previously published ruling is first
modified and then, as modified, is super-
seded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and
that list is expanded by adding further
names in subsequent rulings. After the
original ruling has been supplemented
several times, a new ruling may be pub-
lished that includes the list in the original
ruling and the additions, and supersedes
all prior rulings in the series.
Suspended is used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current use and for-
merly used will appear in material published in the
Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C.—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contribution Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign Corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statements of Procedral Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Definition of Terms

June 26, 2000ii2000–26 I.R.B.
Numerical Finding List
1
Bulletins 2000–1 through 2000–25
Announcements:
2000–1, 2000–2 I.R.B. 294
2000–2, 2000–2 I.R.B. 295
2000–3, 2000–2 I.R.B. 296
2000–4, 2000–3 I.R.B. 317
2000–5, 2000–4 I.R.B. 427
2000–6, 2000–4 I.R.B. 428
2000–7, 2000–6 I.R.B. 586
2000–8, 2000–6 I.R.B. 586
2000–9, 2000–9 I.R.B. 733
2000–10, 2000–9 I.R.B. 733
2000–11, 2000–10 I.R.B. 739
2000–12, 2000–12 I.R.B. 835
2000–13, 2000–11 I.R.B. 771
2000–14, 2000–11 I.R.B. 772
2000–15, 2000–12 I.R.B. 837
2000–16, 2000–12 I.R.B. 837
2000–17, 2000–13 I.R.B. 846
2000–18, 2000–13 I.R.B. 846
2000–19, 2000–19 I.R.B. 973
2000–20, 2000–19 I.R.B. 977
2000–21, 2000–19 I.R.B. 983
2000–22, 2000–19 I.R.B. 987
2000–23, 2000–19 I.R.B. 992
2000–24, 2000–14 I.R.B. 855
2000–25, 2000–14 I.R.B. 855
2000–26, 2000–15 I.R.B. 876
2000–27, 2000–15 I.R.B. 876
2000–28, 2000–15 I.R.B. 876
2000–29, 2000–15 I.R.B. 877
2000–30, 2000–15 I.R.B. 877
2000–31, 2000–15 I.R.B. 877
2000–32, 2000–15 I.R.B. 879
2000–33, 2000–15 I.R.B. 878
2000–34, 2000–15 I.R.B. 879
2000–35, 2000–16 I.R.B. 922
2000–36, 2000–16 I.R.B. 947
2000–37, 2000–16 I.R.B. 947
2000–38, 2000–16 I.R.B. 948
2000–39, 2000–16 I.R.B. 948
2000–40, 2000–16 I.R.B. 948
2000–41, 2000–16 I.R.B. 949
2000–42, 2000–16 I.R.B. 949
2000–43, 2000–17 I.R.B. 957
2000–44, 2000–17 I.R.B. 958
2000–45, 2000–18 I.R.B. 962
2000–46, 2000–19 I.R.B. 997
2000–47, 2000–21 I.R.B. 1118
2000–48, 2000–23 I.R.B. 1243
2000–49, 2000–19 I.R.B. 998
2000–50, 2000–19 I.R.B. 998
2000–51, 2000–22 I.R.B. 1141
2000–52, 2000–22 I.R.B. 1142
2000–53, 2000–22 I.R.B. 1144
2000–55, 2000–25 I.R.B. 1268
Court Decisions:
2066, 2000–15 I.R.B. 867
2067, 2000–15 I.R.B. 863
Notices:
2000–1, 2000–2 I.R.B. 288
2000–2, 2000–9 I.R.B. 727
2000–3, 2000–4 I.R.B. 413
2000–4, 2000–3 I.R.B. 313
Notices—continued:
2000–5, 2000–3 I.R.B. 314
2000–6, 2000–3 I.R.B. 315
2000–7, 2000–4 I.R.B. 419
2000–8, 2000–4 I.R.B. 420
2000–9, 2000–5 I.R.B. 449
2000–10, 2000–5 I.R.B. 451
2000–11, 2000–6 I.R.B. 572
2000–12, 2000–9 I.R.B. 727
2000–13, 2000–9 I.R.B. 732
2000–14, 2000–10 I.R.B. 737
2000–15, 2000–12 I.R.B. 826
2000–16, 2000–12 I.R.B. 826
2000–17, 2000–12 I.R.B. 827
2000–18, 2000–13 I.R.B. 845
2000–19, 2000–13 I.R.B. 845
2000–20, 2000–14 I.R.B. 851
2000–21, 2000–19 I.R.B. 967
2000–22, 2000–16 I.R.B. 902
2000–23, 2000–17 I.R.B. 952
2000–24, 2000–17 I.R.B. 952
2000–25, 2000–17 I.R.B. 954
2000–26, 2000–17 I.R.B. 954
2000–27, 2000–21 I.R.B. 1116
2000–28, 2000–21 I.R.B. 1116
2000–29, 2000–23 I.R.B. 1241
2000–30, 2000–25 I.R.B. 1266
Proposed Regulations:
REG–208280–86, 2000–8 I.R.B. 654
REG–209135–88, 2000–8 I.R.B. 681
REG–208254–90, 2000–6 I.R.B. 577
REG–209601–92, 2000–12 I.R.B. 829
REG–100276–97, 2000–8 I.R.B. 682
REG–101492–98, 2000–3 I.R.B. 326
REG–106012–98, 2000–2 I.R.B. 290
REG–106186–98, 2000–23 I.R.B. 1226
REG–107644–98, 2000–23 I.R.B. 1229
REG–109101–98, 2000–16 I.R.B. 903
REG–110311–98, 2000–11 I.R.B. 767
REG–122450–98, 2000–8 I.R.B. 682
REG–103831–99, 2000–5 I.R.B. 452
REG–103882–99, 2000–8 I.R.B. 706
REG–105089–99, 2000–6 I.R.B. 580
REG–105279–99, 2000–8 I.R.B. 707
REG–105606–99, 2000–4 I.R.B. 421
REG–107872–99, 2000–16 I.R.B. 911
REG–111119–99, 2000–5 I.R.B. 455
REG–113572–99, 2000–7 I.R.B. 624
REG–116048–99, 2000–6 I.R.B. 584
REG–116567–99, 2000–5 I.R.B. 463
REG–116704–99, 2000–3 I.R.B. 325
REG–117162–99, 2000–15 I.R.B. 871
REG–100163–00, 2000–7 I.R.B. 633
REG–100291–00, 2000–16 I.R.B. 917
REG–103735–00, 2000–11 I.R.B. 770
REG–103736–00, 2000–11 I.R.B. 768
Railroad Retirement Quarterly Rate:
2000–9 I.R.B. 721
Revenue Procedures:
2000–1, 2000–1 I.R.B. 4
2000–2, 2000–1 I.R.B. 73
2000–3, 2000–1 I.R.B. 103
2000–4, 2000–1 I.R.B. 115
2000–5, 2000–1 I.R.B. 158
2000–6, 2000–1 I.R.B. 187
Revenue Procedures—continued:
2000–7, 2000–1 I.R.B. 227
2000–8, 2000–1 I.R.B. 230
2000–9, 2000–2 I.R.B. 280
2000–10, 2000–2 I.R.B. 287
2000–11, 2000–3 I.R.B. 309
2000–12, 2000–4 I.R.B. 387
2000–13, 2000–6 I.R.B. 515
2000–14, 2000–18 I.R.B. 960
2000–15, 2000–5 I.R.B. 447
2000–16, 2000–6 I.R.B. 518
2000–17, 2000–11 I.R.B. 766
2000–18, 2000–9 I.R.B. 722
2000–19, 2000–12 I.R.B. 785
2000–20, 2000–6 I.R.B. 553
2000–21, 2000–19 I.R.B. 971
2000–22, 2000–20 I.R.B. 1008
2000–23, 2000–21 I.R.B. 1018
2000–24, 2000–22 I.R.B. 1133
2000–25, 2000–21 I.R.B. 1033
2000–26, 2000–24 I.R.B. 1257
Revenue Rulings:
2000–1, 2000–2 I.R.B. 250
2000–2, 2000–3 I.R.B. 305
2000–3, 2000–3 I.R.B. 297
2000–4, 2000–4 I.R.B. 331
2000–5, 2000–5 I.R.B. 436
2000–6, 2000–6 I.R.B. 512
2000–7, 2000–9 I.R.B. 712
2000–8, 2000–7 I.R.B. 617
2000–9, 2000–6 I.R.B. 497
2000–10, 2000–8 I.R.B. 643
2000–11, 2000–10 I.R.B. 734
2000–12, 2000–11 I.R.B. 744
2000–13, 2000–12 I.R.B. 774
2000–14, 2000–12 I.R.B. 779
2000–15, 2000–12 I.R.B. 774
2000–16, 2000–12 I.R.B. 780
2000–17, 2000–13 I.R.B. 842
2000–18, 2000–14 I.R.B. 847
2000–19, 2000–14 I.R.B. 849
2000–20, 2000–16 I.R.B. 880
2000–21, 2000–16 I.R.B. 881
2000–22, 2000–16 I.R.B. 880
2000–23, 2000–19 I.R.B. 964
2000–24, 2000–19 I.R.B. 963
2000–25, 2000–20 I.R.B. 1006
2000–26, 2000–22 I.R.B. 1124
2000–27, 2000–21 I.R.B. 1016
2000–28, 2000–23 I.R.B. 1157
2000–29, 2000–24 I.R.B. 1249
2000–30, 2000–25 I.R.B. 1262
Tax Conventions:
2000–22 I.R.B. 1126
Treasury Decisions:
8849, 2000–2 I.R.B. 245
8850, 2000–2 I.R.B. 265
8851, 2000–2 I.R.B. 275
8852, 2000–2 I.R.B.253
8853, 2000–4 I.R.B.377
8854, 2000–3 I.R.B.306
8855, 2000–4 I.R.B.374
8856, 2000–3 I.R.B.298
8857, 2000–4 I.R.B.365
8858, 2000–4 I.R.B.332
8859, 2000–5 I.R.B.429
1
A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 1999–27 through
1999–52 is in Internal Revenue Bulletin 2000–1,
dated January 3, 2000.

2000–26 I.R.B.iiiJune 26, 2000
Treasury Decisions—continued:
8860, 2000–5 I.R.B.437
8861, 2000–5 I.R.B.441
8862, 2000–6 I.R.B.466
8863, 2000–6 I.R.B.488
8864, 2000–7 I.R.B.614
8865, 2000–7 I.R.B.589
8866, 2000–6 I.R.B.495
8867, 2000–7 I.R.B.620
8868, 2000–6 I.R.B.491
8869, 2000–6 I.R.B.498
8870, 2000–8 I.R.B.647
8871, 2000–8 I.R.B.641
8872, 2000–8 I.R.B.639
8873, 2000–9 I.R.B.713
8874, 2000–8 I.R.B.644
8875, 2000–11 I.R.B.761
8876, 2000–11 I.R.B.753
8877, 2000–11 I.R.B.747
8878, 2000–15 I.R.B.857
8879, 2000–16 I.R.B.882
8880, 2000–20 I.R.B.1003
8881, 2000–23 I.R.B.1158
8882, 2000–23 I.R.B.1150
8883, 2000–23 I.R.B.1151
8884, 2000–24 I.R.B.1250
8885, 2000–25 I.R.B.1260

June 26, 2000iv2000–26 I.R.B.
Finding List of Current Actions on
Previously Published Items
1
Bulletins 2000–1 through 2000–25
Announcements:
99–40
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
99–50
Modified by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
99–59
Superseded by
Announcement 2000–47, 2000–21 I.R.B. 1118
2000–18
Corrected by
Announcement 2000–32, 2000–15 I.R.B. 878
Notices:
88–125
Obsoleted by
T.D. 8870, 2000–8 I.R.B. 647
92–48
Obsoleted by
Notice 2000–11, 2000–6 I.R.B. 572
97–19
Modified by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
98–22
Obsoleted by
T.D. 8870, 2000–8 I.R.B. 647
98–49
Modified by
Notice 2000–30, 2000–25 I.R.B. 1266
98–52
Modified by
Notice 2000–3, 2000–4 I.R.B. 413
98–61
Modified and superseded by
Rev. Proc. 2000–15, 2000–5 I.R.B. 447
99–8
Obsoleted by
Rev. Proc. 2000–12, 2000–4 I.R.B. 387
2000–4
Corrected by
Announcement 2000–9, 2000–9 I.R.B. 733
Proposed Regulations:
REG–209601–92
Corrected by
Announcement 2000–40, 2000–16 I.R.B. 948
REG–100276–97
Corrected by
Announcement 2000–38, 2000–16 I.R.B. 948
REG–101492–98
Corrected by
Announcement 2000–16, 2000–12 I.R.B. 837
REG–122450–98
Corrected by
Announcement 2000–38, 2000–16 I.R.B. 948
Proposed Regulations—Continued:
REG–113572–99
Corrected by
Announcement 2000–41, 2000–16 I.R.B. 949
REG–103736–00
Corrected by
Announcement 2000–44, 2000–17 I.R.B. 958
Revenue Procedures:
80–18
Modified by
Rev. Proc. 2000–13, 2000–6 I.R.B. 515
89–9
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
89–13
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
90–21
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
91–66
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
92–13
Modified, amplified, and superseded by
Rev. Proc. 2000–11, 2000–3 I.R.B. 309
92–13A
Modified, amplified, and superseded by
Rev. Proc. 2000–11, 2000–3 I.R.B. 309
92–41
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
93–9
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
93–10
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
94–12
Modified, amplified, and superseded by
Rev. Proc. 2000–11, 2000–3 I.R.B. 309
95–42
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
96–13
Modified by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
98–22
Modified and superseded by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
98–27
Superseded by
Rev. Proc. 2000–12, 2000–4 I.R.B. 387
98–64
Superseded by
Rev. Proc. 2000–9, 2000–2 I.R.B. 280
98–65
Superseded by
Rev. Proc. 2000–19, 2000–12 I.R.B. 785
Revenue Procedures—Continued:
99–1
Superseded by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
99–2
Superseded by
Rev. Proc. 2000–2, 2000–1 I.R.B. 73
99–3
Superseded by
Rev. Proc. 2000–3, 2000–1 I.R.B. 103
99–4
Superseded by
Rev. Proc. 2000–4, 2000–1 I.R.B. 115
99–5
Superseded by
Rev. Proc. 2000–5, 2000–1 I.R.B. 158
99–6
Superseded by
Rev. Proc. 2000–6, 2000–1 I.R.B. 187
99–7
Superseded by
Rev. Proc. 2000–7, 2000–1 I.R.B. 227
99–8
Superseded by
Rev. Proc. 2000–8, 2000–1 I.R.B. 230
99–13
Modified and superseded by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
99–20
Supplemented by
Rev. Proc. 2000–14, 2000–18 I.R.B. 960
99–22
Obsoleted by
(except as provided in section 5.02 of)
Rev. Proc. 2000–21, 2000–19 I.R.B. 971
99–24
Superseded by
Rev. Proc. 2000–23, 2000–21 I.R.B. 1018
99–25
Superseded by
Rev. Proc. 2000–24, 2000–22 I.R.B. 1133
99–29
Superseded by
Rev. Proc. 2000–25, 2000–21 I.R.B. 1033
99–31
Modified and superseded by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
99–49
Modified and amplified by
Rev. Rul. 2000–4, 2000–4 I.R.B. 331
Rev. Rul. 2000–7, 2000–9 I.R.B. 712
Notice 2000–4, 2000–3 I.R.B. 313
99–51
Superseded by
Rev. Proc. 2000–3, 2000–1 I.R.B. 103
2000–6
Modified by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
2000–8
Modified by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
1
A cumulative list of current actions on previously
published items in Internal Revenue Bulletins
1999–27 through 1999–52 is in Internal Revenue
Bulletin 2000–1, dated January 3, 2000.

2000–26 I.R.B.vJune 26, 2000
Revenue Procedures—Continued:
2000–12
Corrected by
Announcement 2000–50, 2000–19 I.R.B. 998
2000–16
Corrected by
Announcement 2000–17, 2000–13 I.R.B. 846
Revenue Rulings:
54–396
Obsoleted by
T.D. 8885, 2000–25 I.R.B. 1260
57–259
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
57–499
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
73–292
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
76–79
Distinguised by
Rev. Rul. 2000–24, 2000–19 I.R.B. 963
78–218
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
80–76
Obsoleted by
T.D. 8883, 2000–23 I.R.B. 1151
86–62
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
88–36
Modified by
Rev. Rul. 2000–6, 2000–6 I.R.B. 512
89–89
Obsoleted by
Rev. Rul. 2000–2, 2000–3 I.R.B. 305
92–19
Supplemented by
Rev. Rul. 2000–17, 2000–13 I.R.B. 842
98–30
Amplified and superseded by
Rev. Rul. 2000–8, 2000–7 I.R.B. 617
Treasury Decisions:
8734
Modified by
T.D. 8856, 2000–3 I.R.B. 298
8804
Modified by
T.D. 8856, 2000–3 I.R.B. 298
8845
Corrected by
Announcement 2000–6, 2000–4 I.R.B. 428
8846
Corrected by
Announcement 2000–3, 2000–2 I.R.B. 296
8847
Corrected by
Announcement 2000–13, 2000–11 I.R.B. 771
8849
Corrected by
Announcement 2000–28, 2000–15 I.R.B. 876
8852
Corrected by
Announcement 2000–18, 2000–13 I.R.B. 846
Treasury Decisions—continued:
8853
Corrected by
Announcement 2000–33, 2000–15 I.R.B. 878
8856
Corrected by
Announcement 2000–31, 2000–15 I.R.B. 877
8859
Corrected by
Announcement 2000–27, 2000–15 I.R.B. 876
8864
Corrected by
Announcement 2000–26, 2000–15 I.R.B. 876
8865
Corrected by
Announcement 2000–37, 2000–16 I.R.B. 947
8867
Corrected by
Announcement 2000–30, 2000–15 I.R.B. 877
8869
Corrected by
Announcement 2000–36, 2000–16 I.R.B. 947
8870
Corrected by
Announcement 2000–34, 2000–15 I.R.B. 879
8874
Corrected by
Announcement 2000–29, 2000–15 I.R.B. 877
8879
Corrected by
Announcement 2000–53, 2000–22 I.R.B. 1144

INTERNAL REVENUE BULLETIN
The Introduction at the beginning of this issue 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.gov) or write to the IRS Bulletin Unit, OP:FS:FP:P:1, Room 5617, 1111 Constitution Avenue NW, Washington,
DC 20224.
Internal Revenue Service
Washington, DC 20224
Official Business
Penalty for Private Use, $300