Internal Revenue Bulletin 2000-46 (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.

SPECIAL ANNOUNCEMENT
Announcement 2000–93, page 487.
The Thirteenth Annual Institute on Current Issues in
International Taxation, jointly sponsored by the Internal
Revenue Service and The George Washington University, will
be held on December 7 and 8, 2000, at the J.W. Marriott
Hotel in Washington, DC.
INCOME TAX
Rev. Rul. 2000–51, page 469.
LIFO; price indexes; department stores. The September
2000 Bureau of Labor Statistics price indexes are accepted
for use by department stores employing the retail inventory
and last-in, first-out inventory methods for valuing inventories
for tax years ended on, or with reference to, September 30,
2000.
T.D. 8906, page 470.
Final regulations under section 752 of the Code relate to the
allocation of nonrecourse liabilities by a partnership.
Rev. Proc. 2000–47, page 482.
This procedure informs the public of the Service’s decision
to reconsider its interpretation of section 29(c)(1)(C) of the
Code and to issue no further private letter rulings regarding
whether a solid fuel (other than coke and solid fuel produced
from waste coal fines) is a qualified fuel under section
29(c)(1)(C) pending its reconsideration. Public comments
regarding the proper interpretation of section 29(c)(1)(C)
are requested by November 27, 2000. Rev. Proc. 2000–3
amplified.
EXEMPT ORGANIZATIONS
Announcement 2000–91, page 484.
A list is given of organizations now classified as private foun-
dations.
EMPLOYMENT TAX
Notice 2000–47, page 480.
This notice provides tables that show the amount of an indi-
vidual’s income that is exempt from a notice of levy used to
collect delinquent tax in 2001.
TAX CONVENTIONS
Page 475.
The bilateral agreement between the United States and the
State of Bahrain, providing for the reciprocal tax exemption
of income from the international operation of ships and/or
aircraft, is set forth.
ADMINISTRATIVE
Announcement 2000–92, page 486.
This document contains corrections to proposed regula-
tions (REG–117162–99, 2000–15, I.R.B. 871) relating to
the tax treatment of cafeteria plans.
Internal Revenue
bbuulllleettiinn
Bulletin No. 2000–46
November 13, 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.

November 13, 20002000–46 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.

2000–46 I.R.B.469November 13, 2000
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
Section 29.—Credit for
Producing Fuel From a
Nonconventional Source
May a taxpayer obtain a private letter ruling
under section 29(c)(1)(C) that a solid fuel (other than
coke and solid fuel produced from waste coal fines)
is a qualified fuel? See Rev. Proc. 2000–47, page
482.
Section 472.—Last-in, First-out
Inventories
26 CFR 1.472–1: Last-in, first-out inventories.
LIFO; price indexes; department
stores. The September 2000 Bureau of
Labor Statistics price indexes are accepted
for use by department stores employing
the retail inventory and last-in, first-out
inventory methods for valuing inventories
for tax years ended on, or with reference
to, September 30, 2000.
Rev. Rul. 2000–51
The following Department Store Inven-
tory Price Indexes for September 2000
were issued by the Bureau of Labor Statis-
tics. The indexes are accepted by the In-
ternal Revenue Service, under
§ 1.472–1(k) of the Income Tax Regula-
tions and Rev. Proc. 86–46, 1986–2 C.B.
739, for appropriate application to inven-
tories of department stores employing the
retail inventory and last-in, first-out in-
ventory methods for tax years ended on,
or with reference to, September 30, 2000.
The Department Store Inventory Price
Indexes are prepared on a national basis
and include (a) 23 major groups of depart-
ments, (b) three special combinations of
the major groups - soft goods, durable
goods, and miscellaneous goods, and (c) a
store total, which covers all departments,
including some not listed separately, ex-
cept for the following: candy, food,
liquor, tobacco, and contract departments.

November 13, 20004702000–46 I.R.B.
DRAFTING INFORMATION
The principal author of this revenue rul-
ing is Alan J. Tomsic of the Office of Asso-
ciate Chief Counsel (Income Tax and Ac-
counting). For further information
regarding this revenue ruling, contact Mr.
Tomsic at (202) 622-4970 (not a toll-free
call).
Section 752.—Treatment of
Certain Liabilities
26 CFR 1.752–3: Partner’s share of nonrecourse
liabilities.
T.D. 8906
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
Allocation of Partnership Debt
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations.
SUMMARY: This document contains final
regulations relating to the allocation of non-
recourse liabilities by a partnership. The
final regulations revise tier three of the
three-tiered allocation structure contained
in the current nonrecourse liability regula-
tions, and also provide guidance regarding
the allocation of a single nonrecourse liabil-
ity secured by multiple properties.
DATES: Effective Date: These regulations
are effective October 31, 2000.
Applicability Date: For dates of applica-
bility of these regulations, see §1.752–
5(a).
FOR FURTHER INFORMATION CON-
TACT: Dan Carmody, (202) 622-3070 (not
a toll-free number).
BUREAU OF LABOR STATISTICS, DEPARTMENT STORE
INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS
(January 1941 = 100, unless otherwise noted)
Percent Change
GroupsSep.Sep.from Sep. 1999
19992000to Sep. 2000
1
1. Piece Goods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 543.6496.1-8.7
2. Domestics and Draperies . . . . . . . . . . . . . . . . . . . . 629.3609.3-3.2
3. Women’s and Children’s Shoes . . . . . . . . . . . . . . . 645.4660.62.4
4. Men’s Shoes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 883.1913.63.5
5. Infants’ Wear . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 633.6633.70.0
6. Women’s Underwear . . . . . . . . . . . . . . . . . . . . . . . 566.1584.93.3
7. Women’s Hosiery . . . . . . . . . . . . . . . . . . . . . . . . . . 326.7342.9 5.0
8. Women’s and Girls’ Accessories . . . . . . . . . . . . . . 536.2540.00.7
9. Women’s Outerwear and Girls’ Wear . . . . . . . . . . . 408.9400.2-2.1
10. Men’s Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . 619.3606.3-2.1
11. Men’s Furnishings . . . . . . . . . . . . . . . . . . . . . . . . . 618.4624.81.0
12. Boys’ Clothing and Furnishings . . . . . . . . . . . . . . 498.5481.7 -3.4
13. Jewelry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 960.4933.7-2.8
14. Notions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 767.0788.02.7
15. Toilet Articles and Drugs. . . . . . . . . . . . . . . . . . . . 982.5969.9-1.3
16. Furniture and Bedding. . . . . . . . . . . . . . . . . . . . . . 696.6707.21.5
17. Floor Coverings. . . . . . . . . . . . . . . . . . . . . . . . . . . 602.8614.82.0
18. Housewares . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 796.1777.5-2.3
19. Major Appliances . . . . . . . . . . . . . . . . . . . . . . . . . 235.7230.6-2.2
20. Radio and Television . . . . . . . . . . . . . . . . . . . . . . . 64.658.3-9.8
21. Recreation and Education
2
. . . . . . . . . . . . . . . . . . 96.492.3-4.3
22. Home Improvements
2
. . . . . . . . . . . . . . . . . . . . . . 127.8128.30.4
23. Auto Accessories
2
. . . . . . . . . . . . . . . . . . . . . . . . . 107.1106.5-0.6
Groups 1 - 15: Soft Goods . . . . . . . . . . . . . . . . . . . . . 605.2600.3-0.8
Groups 16 - 20: Durable Goods . . . . . . . . . . . . . . . . . 450.6438.9-2.6
Groups 21 - 23: Misc. Goods
2
. . . . . . . . . . . . . . . . . . . 102.799.8-2.8
Store Total
3
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 547.0539.4-1.4
1
Absence of a minus sign before the percentage change in this column signifies a price increase.
2
Indexes on a January 1986=100 base.
3
The store total index covers all departments, including some not listed separately, except for the following: candy, food, liquor, tobacco, and contract departments.

2000–46 I.R.B.471November 13, 2000
SUPPLEMENTARY INFORMATION:
Introduction
This document revises §1.752–3 of the
Income Tax Regulations (26 CFR part 1)
relating to the allocation by a partnership
of nonrecourse liabilities.
Background
On January 13, 2000, the IRS pub-
lished in the Federal Registera notice of
proposed rulemaking (REG–103831–99,
2000–5 I.R.B. 452 [65 F.R. 2084]) to pro-
vide guidance relating to the allocation of
nonrecourse liabilities by a partnership.
The IRS and Treasury received public
comments concerning the proposed regu-
lations, and a public hearing was held on
May 3, 2000. After consideration of the
comments received, the proposed regula-
tions are adopted as revised by this Trea-
sury decision.
Explanation of Revisions and
Summary of Comments
1. In General
Treasury regulation §1.752–3 currently
provides a three-tiered system for allocat-
ing nonrecourse liabilities. The three-
tiered system applies sequentially. Under
the first tier, a partner is allocated an
amount of the liability equal to that part-
ner’s share of partnership minimum gain
under section 704(b). See §1.704–2
(g)(1). Under the second tier, to the ex-
tent the entire liability has not been allo-
cated under the first tier, a partner will be
allocated an amount of liability equal to
the gain that partner would be allocated
under section 704(c) if the partnership
disposed of all partnership property sub-
ject to one or more nonrecourse liabilities
in full satisfaction of the liabilities (sec-
tion 704(c) minimum gain). Under the
third tier, a partner is allocated any excess
nonrecourse liabilities (i.e., nonrecourse
liabilities in excess of the portion alloca-
ble in the first and second tiers) under
one of several methods (i.e., partner’s
share of profits or certain reasonably ex-
pected deductions) that the partnership
may choose.
The proposed regulations modified the
third tier to allow an additional method
under which a partnership may allocate
an excess nonrecourse liability based on
the excess section 704(c) gain (i.e., the
excess of the amount of section 704(c)
built-in gain attributable to an item of
property over the amount of section
704(c) minimum gain on that property)
attributable to the properties that are sub-
ject to the liability. In addition, for pur-
poses of determining section 704(c) mini-
mum gain under the second tier, the
proposed regulations provided that if a
partnership holds multiple properties sub-
ject to a single liability, the liability may
be allocated among the properties based
on any reasonable method. A method is
not reasonable under the proposed regu-
lations if it allocates to any property an
amount that exceeds the fair market value
of the property.
2.Allocation of Debt in Accordance With
Reverse Section 704(c) Gain
One commentator noted that the addi-
tional method provided in the proposed
regulations under the third tier covers
only built-in gain on section 704(c) prop-
erty, which includes built-in gain (i.e.,
book value minus adjusted basis) attribut-
able to contributed property, but not built-
in gain attributable to property subject to
a revaluation (pursuant to
§1.704–1(b)(2)(iv)(f)) (i.e., reverse sec-
tion 704(c) gain). The commentator
noted that this distinction is not made in
allocating nonrecourse liabilities in accor-
dance with section 704(c) minimum gain
under the second tier and questioned the
policy reason for excluding the reverse
section 704(c) gain in applying the third
tier. In response to this comment, the
final regulations provide that an excess
nonrecourse liability may be allocated
under the third tier in accordance with ex-
cess section 704(c) gain as well as excess
reverse section 704(c) gain (i.e., the ex-
cess of the amount of reverse section
704(c) gain attributable to an item of
property over the section 704(c) mini-
mum gain on that property) with respect
to property that is subject to such liability.
3. Interplay With the Disguised Sales
Rules
One commentator noted that the pro-
posed amendments to §1.752–3 would
impact the disguised sales rules relating
to transfers of encumbered property. The
disguised sale rules treat a contribution of
property encumbered by a “non-quali-
fied” liability (generally, a liability in-
curred within two years of the contribu-
tion to the partnership that is incurred in
anticipation of such contribution) as a
disguised sale to the extent that the
amount of the liability exceeds the con-
tributing partner’s share of the liability
immediately after the contribution. Sec-
tion 1.707–5(a)(2)(ii) provides that a
partner’s share of a nonrecourse liability,
for purposes of the disguised sale rules, is
determined by applying the same per-
centage used to determine the partner’s
share of the excess nonrecourse liability
under §1.752–3(a)(3).
Because the proposed amendments to
§1.752–3(a)(3) would allow excess nonre-
course liabilities to be allocated according
to an amount, rather than a percentage, the
potential for ambiguity exists. The com-
mentator suggested that the disguised sale
rules should be modified to define a part-
ner’s share of a nonrecourse liability by
cross-reference to §1.752–3(a), rather than
limiting the definition to the third tier. The
commentator noted that maintaining sepa-
rate definitions for the same term was bur-
densome and confusing for practitioners,
and noted that the disguised sale rules pro-
vide consistency between sections 707(a)
and 752 with respect to the definition of a
partner’s share of a recourse liability by
reference to §1.752–2 without limitation.
The preamble to §1.707–5 explains that
the cross-reference defining a partner’s
share of nonrecourse liabilities is limited
to the third tier of §1.752–3(a) because the
adoption of the full three-tier approach in
the disguised sale context would provide
an inverse relationship between the gain
inherent in the contributed property and
the extent to which a disguised sale of the
property results from the encumbrance.
See preamble (57 F.R. 44974). The con-
tributing partner’s share of the liability
under §1.752–3(a) generally will increase
as the amount of built-in gain on the prop-
erty increases, which in turn would reduce
the extent to which the contribution would
be treated as a disguised sale.
The same problem would exist if the
proposed modifications to the third tier
were taken into account for purposes of
§1.707–5(a)(2)(ii). To the extent that ex-
cess section 704(c) gain exists with re-
spect to a property, the partnership could

November 13, 20004722000–46 I.R.B.
allocate excess nonrecourse liabilities to
the contributing partner. The greater the
built-in gain with respect to a property,
the less likely it would be that a disguised
sale would result from the contribution.
In order to avoid this inappropriate result,
the final regulations clarify that the modi-
fications made to the third tier do not
apply for purposes of §1.707–5(a)(2)(ii).
Thus, for purposes of the disguised sale
rules, the partner’s share of nonrecourse
liabilities continues to be determined
under the third tier by reference to the
partner’s share of profits or certain rea-
sonably expected deductions.
4. Treatment of “Extra” Excess Section
704(c) Gain
Rev. Rul. 95–41 (1995–1 C.B. 132)
holds that if a partnership determines the
partners’ interests in partnership profits
based on all of the facts and circum-
stances relating to the economic arrange-
ment of the partners, excess section
704(c) gain is one factor, but not the only
factor, to be considered under
§1.752–3(a)(3). The preamble to the pro-
posed regulations provides that this hold-
ing will remain relevant where a partner-
ship does not allocate nonrecourse debt
under the third tier based on the excess
section 704(c) gain attributable to the
property that is subject to the debt. The
preamble also provides that once a part-
nership has allocated nonrecourse indebt-
edness pursuant to the rule in the pro-
posed regulations based upon excess
section 704(c) gain, that excess section
704(c) gain cannot again be considered in
determining a partner’s interest in part-
nership profits.
One commentator asked, in situations
where the amount of a liability allocated
to a partner under the third tier pursuant to
the rule contained in the proposed regula-
tions is less than the partner’s share of ex-
cess 704(c) gain, whether the remaining
excess 704(c) gain should be taken into
account for purposes of determining a
partner’s interest in partnership profits
under the third tier with regard to other li-
abilities.
The statement contained in the pream-
ble regarding the impact of the proposed
regulations on Rev. Rul. 95–41 reflects a
concern on the part of IRS and Treasury
that taxpayers might count the same ex-
cess section 704(c) gain in applying the
rule in the proposed regulations and then
again in determining a partner’s interest
in partnership profits under the third tier.
To the extent that a portion of excess sec-
tion 704(c) gain remains after a liability
has been fully allocated, there is no dou-
ble-counting, and the remaining portion
of the gain should be taken into account
as one factor to be considered in deter-
mining a partner’s interest in partnership
profits under §1.752–3(a)(3) and Rev.
Rul. 95–41.
5. Applicability of §1.752–3(b) to Third-
Tier Allocations
The proposed regulations provide rules
regarding the allocation of a single liability
among multiple properties. The proposed
regulations generally provide that if a part-
nership has multiple properties subject to a
single liability, for purposes of determining
the amount of section 704(c) minimum
gain in applying the second tier, the part-
nership may allocate to each property an
amount of the liability that, when combined
with any other liabilities allocated to the
property, do not exceed the property’s fair
market value. The portion of the liability
allocated to each property will be treated as
a separate loan in determining the section
704(c) minimum gain attributable to the
property.
One commentator asked that the rule for
allocating a single liability among multiple
properties under the second tier also apply
to third tier allocations. For purposes of the
second tier, where nonrecourse debt is
cross-collateralized, it is necessary to deter-
mine how much of the nonrecourse debt is
attributable to each partnership property,
since debt is allocated among the partners
under that tier based upon the amount by
which the debt attributable to each specific
property exceeds the tax basis of such prop-
erty. (See §1.704–3(a)(2), which provides
that, except in limited circumstances, sec-
tion 704(c) applies on a property-by-prop-
erty basis.) Under the proposed modifica-
tion to the third tier, any remaining
nonrecourse liability of the partnership
could be allocated to a partner up to the ex-
cess section 704(c) gain allocable to the
partner on property subject to that liability.
There is no need to bifurcate cross-collater-
alized debt under this tier, since excess sec-
tion 704(c) gain is not limited by the
amount of debt attributable to specific part-
nership property. So long as a partner’s
share of excess section 704(c) gain is attrib-
utable to property that is “subject to” the
debt being allocated, the debt may be allo-
cated in accordance with that partner’s
share of such excess section 704(c) gain.
Multiple properties may be “subject to” the
same indebtedness. Bifurcating the debt
among multiple properties so that each
property is treated as subject to only a por-
tion of the debt actually would limit taxpay-
ers’ flexibility and narrow the scope of the
proposed change to the third tier. Accord-
ingly, the commentator’s recommendation
is not adopted. However, the final regula-
tions add an example which clarifies the
operation of this rule.
6. Retroactive Effective Date
One commentator suggested that the reg-
ulations should apply on a retroactive basis.
This suggestion has not been adopted.
However, the final regulations respond to
this recommendation by providing an op-
tional effective date for those taxpayers
who wish to apply the rules currently to lia-
bilities incurred prior to the issuance of
these regulations.
7. Additional Comments Requested
The preamble to the proposed regula-
tions requested comments regarding the al-
location of a single liability among multiple
partnerships. Although no formal com-
ments were submitted on this issue, several
commentators have indicated that addi-
tional guidance regarding appropriate
methods of allocating such liabilities would
be helpful. The IRS and Treasury again re-
quest comments regarding this issue.
Special Analyses
It has been determined that this Treasury
decision is not a significant regulatory ac-
tion as defined in Executive Order 12866.
Therefore, a regulatory assessment is not
required. It also has been determined that
section 553(b) of the Administrative Proce-
dure Act (5 U.S.C. chapter 5) and the Regu-
latory Flexibility Act (5 U.S.C. chapter 6)
do not apply to these regulations and, there-
fore, a Regulatory Flexibility Analysis is
not required. Pursuant to section 7805(f) of
the Internal Revenue Code, the notice of
proposed rulemaking preceding these regu-
lations was submitted to the Small Business
Administration for comment on its impact
on small business.

2000–46 I.R.B.473November 13, 2000
Drafting Information
The principal author of these regulations
is Christopher T. Kelley, Office of Chief
Counsel (Passthroughs and Special Indus-
tries). However, other personnel from the
IRS and Treasury participated in their de-
velopment.
* * * * *
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR part 1 is amended
as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 continues to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 1.752–3 is amended as
follows:
1. Paragraph (a)(3) is amended by
adding three sentences immediately be-
fore the last sentence in the paragraph.
2. Paragraph (b) is redesignated as
paragraph (c).
3. New paragraph (b) is added.
4. Newly designated paragraph (c) is
amended by revising the introductory text
and adding a new Example 3.
The revisions and addition read as fol-
lows:
§1.752–3 Partner’s share of nonrecourse
liabilities.
(a) * * *
(3) * * * Additionally, the partnership
may first allocate an excess nonrecourse
liability to a partner up to the amount of
built-in gain that is allocable to the part-
ner on section 704(c) property (as defined
under §1.704–3(a)(3)(ii)) or property for
which reverse section 704(c) allocations
are applicable (as described in §1.704–3
(a)(6)(i)) where such property is subject
to the nonrecourse liability to the extent
that such built-in gain exceeds the gain
described in paragraph (a)(2) of this sec-
tion with respect to such property. This
additional method does not apply for pur-
poses of §1.707–5(a)(2)(ii). To the extent
that a partnership uses this additional
method and the entire amount of the ex-
cess nonrecourse liability is not allocated
to the contributing partner, the partnership
must allocate the remaining amount of the
excess nonrecourse liability under one of
the other methods in this paragraph (a)(3).
* * *
(b) Allocation of a single nonrecourse
liability among multiple properties—(1)
In general. For purposes of determining
the amount of taxable gain under para-
graph (a)(2) of this section, if a partner-
ship holds multiple properties subject to a
single nonrecourse liability, the partner-
ship may allocate the liability among the
multiple properties under any reasonable
method. A method is not reasonable if it
allocates to any item of property an
amount of the liability that, when com-
bined with any other liabilities allocated
to the property, is in excess of the fair
market value of the property at the time
the liability is incurred. The portion of
the nonrecourse liability allocated to each
item of partnership property is then
treated as a separate loan under paragraph
(a)(2) of this section. In general, a part-
nership may not change the method of al-
locating a single nonrecourse liability
under this paragraph (b) while any portion
of the liability is outstanding. However, if
one or more of the multiple properties
subject to the liability is no longer subject
to the liability, the portion of the liability
allocated to that property must be reallo-
cated among the properties still subject to
the liability so that the amount of the lia-
bility allocated to any property does not
exceed the fair market value of such prop-
erty at the time of reallocation.
(2) Reductions in principal. For pur-
poses of this paragraph (b), when the out-
standing principal of a partnership liabil-
ity is reduced, the reduction of
outstanding principal is allocated among
the multiple properties in the same pro-
portion that the partnership liability origi-
nally was allocated to the properties under
paragraph (b)(1) of this section.
(c) Examples. The following examples
illustrate the principles of this section:
* * * * *
Example 3. Allocation of liability among multiple
properties. (i) A and B are equal partners in a part-
nership (PRS). A contributes $70 of cash in ex-
change for a 50-percent interest in PRS. B con-
tributes two items of property, X and Y, in exchange
for a 50-percent interest in PRS. Property X has a
fair market value (and book value) of $70 and an ad-
justed basis of $40, and is subject to a nonrecourse
liability of $50. Property Y has a fair market value
(and book value) of $120, an adjusted basis of $40,
and is subject to a nonrecourse liability of $70. Im-
mediately after the initial contributions, PRS refi-
nances the two separate liabilities with a single $120
nonrecourse liability. All of the built-in gain attrib-
utable to Property X ($30) and Property Y ($80) is
section 704(c) gain allocable to B.
(ii) The amount of the nonrecourse liability
($120) is less than the total book value of all of the
properties that are subject to such liability ($70 +
$120 = $190), so there is no partnership minimum
gain. §1.704–2(d). Accordingly, no portion of the
liability is allocated pursuant to paragraph (a)(1) of
this section.
(iii) Pursuant to paragraph (b)(1) of this section,
PRS decides to allocate the nonrecourse liability
evenly between the Properties X and Y. Accord-
ingly, each of Properties X and Y are treated as being
subject to a separate $60 nonrecourse liability for
purposes of applying paragraph (a)(2) of this sec-
tion. Under paragraph (a)(2) of this section, B will
be allocated $20 of the liability for each of Proper-
ties X and Y (in each case, $60 liability minus $40
adjusted basis). As a result, a portion of the liability
is allocated pursuant to paragraph (a)(2) of this sec-
tion as follows:
PartnerPropertyTier 1Tier 2
AX$0$0
Y$0$0
BX$0$20
Y$0$20
(iv) PRS has $80 of excess nonrecourse liability
that it may allocate in any manner consistent with
paragraph (a)(3) of this section. PRS determines to
allocate the $80 of excess nonrecourse liabilities to
the partners up to their share of the remaining sec-
tion 704(c) gain on the properties, with any remain-
ing amount of liabilities being allocated equally to A
and B consistent with their equal interests in partner-
ship profits. B has $70 of remaining section 704(c)
gain ($10 on Property X and $60 on Property Y),
and thus will be allocated $70 of the liability in ac-
cordance with this gain. The remaining $10 is di-
vided equally between A and B. Accordingly, the
overall allocation of the $120 nonrecourse liability
is as follows:

November 13, 20004742000–46 I.R.B.
PartnerTier 1Tier 2Tier 3Total
A$0$0$5$5
B$0$40$75$115
Par. 3. In §1.752–5, paragraph (a) is
amended by adding three sentences after
the first sentence:
Section 1.752–5 Effective dates and
transition rules.
(a) In general. * * * However,
§1.752–3(a)(3) fifth, sixth, and seventh
sentences, (b), and (c) Example 3, do not
apply to any liability incurred or assumed
by a partnership prior to October 31,
2000. Nevertheless, §1.752–3(a)(3)
fifth, sixth, and seventh sentences, (b),
and (c) Example 3, may be relied upon for
any liability incurred or assumed by a
partnership prior to October 31, 2000 for
taxable years ending on or after October
31, 2000. * * *
* * * * *
David A. Mader,
Acting Deputy Commissioner
of Internal Revenue.
Approved October 11, 2000.
Jonathan Talisman,
Acting Assistant Secretary
of the Treasury.
(Filed by the Office of the Federal Register on Octo-
ber 30, 2000, 8:45 a.m., and published in the issue
of the Federal Register for October 31, 2000, 65
F.R. 64888)

2000–46 I.R.B.475November 13, 2000
Part II. Treaties and Tax Legislation
Subpart A.—Tax Conventions

November 13, 20004762000–46 I.R.B.

2000–46 I.R.B.477November 13, 2000

November 13, 20004782000–46 I.R.B.

2000–46 I.R.B.479November 13, 2000

Tables for Figuring Amount Exempt From Levy on Wages, Salary, and Other Income
Notice 2000–47
1. Table for Figuring Amount Exempt From Levy on Wages, Salary, and Other Income
(Forms 668-W(c) & 668-W(c)(DO)) 2001
Publication 1494, shown below, provides tables that show the amount of an individual’s income that is exempt from a notice of levy
used to collect delinquent tax in 2001.
(Amounts are for each pay period.)
November 13, 20004802000–46 I.R.B.
Part III. Administrative, Procedural, and Miscellaneous
Filing Status: Single
Number of Exemptions Claimed on Statement
Pay
Period123456More Than 6
Daily28.6539.8150.9662.1273.2784.4217.50 plus 11.54 for
each exemption
Weekly143.27199.04254.81310.58366.35422.1287.50 plus 55.77 for
each exemption
Biweekly286.54398.08509.62621.15732.69844.23175.00 plus 111.54 for
each exemption
Semi-310.42431.25552.08672.92793.75914.58189.58 plus 120.83 for
monthlyeach exemption
Monthly620.83862.501104.171345.831587.501829.17379.17 plus 241.67 for
each exemption
Filing Status: Unmarried Head of Household
Number of Exemptions Claimed on Statement
Pay
Period123456More Than 6
Daily36.7347.8859.0470.1981.3592.5025.58 plus 11.54 for
each exemption
Weekly183.65239.42295.19350.96406.73462.50127.88 plus 55.77 for
each exemption
Biweekly367.31478.85590.38701.92813.46925.00255.77 plus 111.54 for
each exemption
Semi-397.92518.75639.58760.42881.251002.08277.08 plus 120.83 for
monthlyeach exemption
Monthly795.831037.501279.171520.831762.502004.17554.17 plus 241.67 for
each exemption

2000–46 I.R.B.481November 13, 2000
Filing Status: Married Filing Joint (and Qualifying Widow(er)s)
Number of Exemptions Claimed on Statement
Pay
Period123456More Than 6
Daily40.3851.5462.6973.8585.0096.1529.23 plus 11.54 for
each exemption
Weekly201.92257.69313.46369.23425.00480.77146.15 plus 55.77 for
each exemption
Biweekly403.85515.38626.92738.46850.00961.54292.31 plus 111.54 for
each exemption
Semi-437.50558.33679.17800.00920.831041.67316.67 plus 120.83 for
monthlyeach exemption
Monthly875.001116.671358.331600.001841.672083.33633.33 plus 241.67 for
each exemption
Filing Status: Married Filing Seperate
Number of Exemptions Claimed on Statement
Pay
Period123456More Than 6
Daily25.7736.9248.0859.2370.3881.5414.62 plus 11.54 for
each exemption
Weekly128.85184.62240.38296.15351.92407.6973.07 plus 55.77 for
each exemption
Biweekly257.69369.23480.77592.31703.85815.38146.15 plus 111.54 for
each exemption
Semi-279.17400.00520.83641.67762.50883.33158.33 plus 120.83 for
monthlyeach exemption
Monthly558.33800.001041.671283.331525.001766.67316.67 plus 241.67 for
each exemption
Filing Status*DailyWklyBi-WklySemi-MoMonthly
Single or Head 14.2321.1542.3145.8391.67
of Household28.4642.3184.6291.67183.33
Any Other13.4617.3134.6237.5075.00
Filing Status26.9234.6269.2375.00150.00
310.3851.92103.85112.50225.00
413.8569.23138.46150.00300.00
2. Table for Figuring Additional Exempt Amount for Taxpayers at Least 65 Years Old and/or Blind
Additional Exempt Amount
* ADDITIONAL STANDARD DEDUCTION claimed on Parts 3, 4, & 5 of levy.

November 13, 20004822000–46 I.R.B.
Examples
These tables show the amount exempt from a levy on wages, salary, and other income.
For example:
1. A single taxpayer who is paid weekly and claims three exemptions (including one for the taxpayer) has $254.81 exempt from levy.
2. If the taxpayer in number 1 is over 65 and writes 1 in the ADDITIONAL STANDARD DEDUCTION space on Parts 3, 4, & 5
of the levy, $275.96 is exempt from this levy ($254.81 plus $21.15).
3. A taxpayer who is married, files jointly, is paid bi-weekly, and claims two exemptions (including one for the taxpayer) has
$515.38 exempt from levy.
4. If the taxpayer in number 3 is over 65 and has a spouse who is blind, this taxpayer should write 2 in the ADDITIONAL STAN-
DARD DEDUCTION space on Parts 3, 4, & 5 of the levy. Then, $584.61 is exempt from this levy ($515.38 plus $69.23).
26 CFR 601.201: Rulings and determination
letters.
(Also Part I, section 29.)
Rev. Proc. 2000–47
SECTION 1. PURPOSE
This revenue procedure amplifies Rev.
Proc. 2000–3, 2000–1 I.R.B. 103, which
sets forth areas of the Internal Revenue
Code in which the Internal Revenue Ser-
vice will not issue advance rulings or de-
termination letters.
SECTION 2. BACKGROUND
Section 5 of Rev. Proc. 2000–3 sets
forth those areas under extensive study
in which rulings or determination letters
will not be issued until the Service re-
solves the issue through publication of a
revenue ruling, revenue procedure, regu-
lations, or otherwise.
The purpose of § 29 of the Internal
Revenue Code is to reduce United States
dependence on imported energy. S. Rep.
No. 394, 96th Cong., 1st Sess. 87 (1979),
1980–3 C.B. 131, 205.
Section 29 provides a credit against
income tax for the production and sale of
“qualified fuels” produced from a non-
conventional source. Section
29(c)(1)(C) provides that qualified fuels
include liquid, gaseous, or solid syn-
thetic fuels produced from coal (includ-
ing lignite).
Rev. Rul. 86–100, 1986–2 C.B. 3,
adopts for purposes of § 29(c)(1)(C) the
definition of synthetic fuel in § 1.48–9
(c)(5) of the Income Tax Regulations be-
cause of the similar purpose and lan-
guage of § 29 and former § 48(l) of the
Internal Revenue Code of 1954. Section
1.48–9(c)(5)(ii) provides that, to be
“synthetic,” a fuel must differ signifi-
cantly in chemical composition, as op-
posed to physical composition, from the
substance used to produce it.
The Service has issued a number of
rulings that allow taxpayers to claim the
§ 29 credit with respect to coke and solid
fuels produced from waste coal and coal
fines. Concern has been raised that tax-
payers are also claiming the § 29 credit
for processing coal in other ways that
may not have been intended by the Con-
gress. The Treasury Department and the
Service are seeking information concern-
ing the processes currently used in pro-
ducing solid fuel for which the credit is
claimed.
SECTION 3. PROCEDURE
Rev. Proc. 2000–3 is amplified by
adding the following to section 5:
Section 29.—Credit for Production
and Sale of Qualified Fuels.—Whether a
solid fuel other than coke or a fuel pro-
duced from waste coal is a qualified fuel
under § 29(c)(1)(C). Waste coal for this
purpose is limited to waste coal fines
from normal mining and crushing opera-
tions and does not include fines pro-
duced (for example, by crushing run-of-
mine coal) for the purpose of claiming
the credit.
SECTION 4. EFFECTIVE DATE
This revenue procedure applies to all
ruling requests, including any pending in
the national office and any submitted
after the date of publication of this rev-
enue procedure. Taxpayers that have
pending ruling requests involving solid
fuel other than coke but whose ruling re-
quests do not indicate that the fuel is pro-
duced from waste coal fines may modify
their ruling requests if they meet the
standard described in section 3 of this
revenue procedure so that the Service
may continue to consider their requests.
SECTION 5. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2000–3 is amplified.
SECTION 6. REQUEST FOR
COMMENTS
The Service requests comments con-
cerning this revenue procedure and the
standard to be applied in determining
whether fuel produced from coal is a solid
synthetic fuel. In particular, the Service
requests comments on whether significant
chemical change is an appropriate test
and, if so, what constitutes such a change.
The Service also requests comments on
whether, in the case of solid fuels other
than coke, additional or alternative tests
are needed. Comments are specifically
requested with respect to the following:
(1) should the § 29 credit for solid syn-
thetic fuel under § 29(c)(1)(C) be allowed
only where domestic energy production is
increased; (2) under what circumstances
should the § 29 credit for solid synthetic
fuel under § 29(c)(1)(C) be allowed with
respect to fuel produced from waste coal
and coal fines; and (3) must a solid syn-
thetic fuel have a market value that is sig-
nificantly greater than the market value of
the coal and any additives from which it
is produced.
To facilitate speedy resolution, the Ser-
vice requests that comments be submitted
by November 27, 2000. An original and
eight copies of written comments should
be mailed to:
Internal Revenue Service
Attn: CC:MSP:R (Rev. Proc. 2000–47)
Room 5228 (PSI:Br6)
PO Box 7604
Ben Franklin Station
Washington, DC 20044

or hand delivered between the hours of
8:00 a.m. and 5:00 p.m. to:
Courier’s Desk
Internal Revenue Service
Attn: CC:MSP:R (Rev. Proc. 2000–47)
Room 5228 (PSI:Br6)
1111 Constitution Avenue, NW
Washington, DC
In addition, comments may be submitted
electronically at:
joel.s.rutstein@m1.irscounsel.treas.gov.
DRAFTING INFORMATION
The principal author of this revenue
procedure is David McDonnell of the Of-
fice of Associate Chief Counsel
(Passthroughs and Special Industries).
However, other personnel from the IRS
and Treasury participated in its develop-
ment. For further information regarding
this revenue procedure contact Mr. Mc-
Donnell at (202) 622-3110 (not a toll-free
call).
2000–46 I.R.B.483November 13, 2000

Foundations Status of Certain
Organizations
Announcement 2000–91
The following organizations have failed
to establish or have been unable to main-
tain their status as public charities or as op-
erating foundations. Accordingly, grantors
and contributors may not, after this date,
rely on previous rulings or designations in
the Cumulative List of Organizations
(Publication 78), or on the presumption
arising from the filing of notices under sec-
tion 508(b) of the Code. This listing does
notindicate that the organizations have lost
their status as organizations described in
section 501(c)(3), eligible to receive de-
ductible 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:
Afghanistan Peace Association, Inc.,
Flushing, NY
Alameda County Cancer League, Inc.,
Piedmont, CA
Alameda Ladies Relief Society,
Alameda, CA
Alfred J. Friend Memorial Fund, Inc.,
Rockville Centre, NY
Alliance for Advanced Coatings
Research, Rolla, MO
Alternative Home Care, Inc.,
Mount Sinai, NY
American Friends of Birkat Peretz,
Brooklyn, NY
American Friends of Gifted Young
Musicians in Israel, Inc.,
New York, NY
American Friends of Ora, Brooklyn, NY
American Friends of Yeshiva Nezer
Hatorah, Inc., Brooklyn, NY
American Friends of Yeshivat Imrei Datt,
Inc., Brooklyn, NY
American Philharmonic & Theatre
Company, Inc., New York, NY
Angels on Earth, Inc., Lawrence, NY
Another Door, Ltd., Glencove, NY
Appomattox Primary School Parent-
Teacher Organization, Appomattox, VA
Arizona Hispanic Association,
Apache Junction, AZ
Arkansas Osteopathic Foundation,
Little Rock, AR
Association for Legal Learning,
Pelham, NY
Atlanta Outreach Foundation for the
Homeless, Atlanta, GA
B. Stephen Demchuk Foundation,
South Salem, NY
Bakersfield Storm Soccer Club,
Bakersfield, CA
Bath Civil War Preservation Society, Inc.,
Bath, ME
Battered Womens Resource Center, Inc.,
Brooklyn, NY
Benjamin Church Development
Corporation, Bristol, RI
Bishop Henry B. Hucles Nursing Home,
Inc., Uniondale, NY
Bluff City Middle School Athletic Booster
Club, Bluff City, TN
Boles Junior High Athletic Booster Club,
Inc., Arlington, TX
Bosnian Refugees Association, Corp.,
Long Island City, NY
Brain Injury Association Texas Gulf Coast
Area, Houston, TX
Brass Band of Minot, Milnot, ND
Brazilian Community Center,
Malden, MA
Break O’Day Farm and Metcalfe Museum,
Inc., Durham, OK
Bridges of Milwaukee, Inc.,
Wauwatosa, WI
Brookdale Residence Housing Development
Fund Corporation, Brooklyn, NY
Brotherhood for HIV Economic Support,
Inc., Evansville, IN
Buckeye Academic Booster Club,
Buckeye, AZ
Buenos Aires Yoga School Foundation,
Chicago, IL
Building Blocks Non-Profit Housing
Corporation, Royal Oak, MI
California Capital Access Forum, Inc.,
San Francisco, CA
Catch and Release Foundation, Inc.,
Pound Ridge, NY
Catholics for Life, Inc., Deer Park, NY
C C L Chinese-American Culture Learning
Center, Inc., Flushing, NY
Cedarburg Junior Womans Club, Inc.,
Cedarburg, WI
Center for Childrens Advocacy, Inc.,
Nutley, NJ
Center for Policy Studies in Russia,
Monterey, CA
Center for the Urban Environment, Inc.,
Brooklyn, NY
Chassidic Discover Center, Inc.,
Brooklyn, NY
Chen V’Chesed, Brooklyn, NY
Child Identification & Data Services,
Incorporated, Brooklyn, NY
Children Mishnayos Memorial
Foundation, Inc., Brooklyn, NY
Childrens Fund USA, Inc., Brooklyn, NY
Christmas in April - El Paso, Inc.,
El Paso, CA
Christmas in the Valley, Arcadia, MO
City Club of Boise, Inc., Boise, ID
Clinton Residence, Inc., Hempstead, NY
Coalition for Pregnant Teens Services for
Youth and Families,
West Hempstead, NY
Community Ministries of Virginia, Inc.,
Newport News, VA
Contemporary Chamber Opera of
Minnesota, Inc., Minneapolis, MN
Contending for the Faith Bible Study,
Tampa, FL
Corporate Kingdom, Ltd.,
Garden City, NY
Corporation for Musical Development,
Middle Village, NY
Counsel of Substance Abuse
Professionals, Inc., Rome, GA
Cultural Center of the Taino Nation of the
Antilles, Inc., New York, NY
Cystic Fibrosis Support Group of
Oregon, Clackamas, OR
Dark Horse Productions, Inc.,
Amagansett, NY
David Rosenthal Foundation,
Great Neck, NY
Deaf and Hearing Ventures, Incorporated,
Birmingham, AL
DEAF, Inc., New York, NY
Desnick Family Charitable Foundation,
Chicago, IL
Disability Group, Inc., Los Angeles, CA
Donation for Life Coalition, Inc.,
San Francisco, CA
Earthspan, Stewartstown, PA
East Central Upper Peninsula Health and
Education Foundation, Newberry, MI
Ebony Zawadi, Inc., Brandywine, MD
Elderly Housing Services, Inc.,
Johnson City, TN
Emilys Store, Inc., Columbia, MD
End Time Full Gospel Harvestors, Inc.,
Floral Park, NY
Families of Abused Children Traumatized
Sexually, Inc., Virginia Beach, VA
Family Link-up, Inc., Brooklyn, NY
November 13, 20004842000–46 I.R.B.
Part IV. Items of General Interest

Far Rockaway Panther Football, Inc.,
Far Rockaway, NY
Farm Workers Development Center,
Granger, WA
Fathers and Mothers in Legal Yearning,
Inc., Tucson, AZ
Flatbush Youth Association, Inc.,
Brooklyn, NY
Focus Information Service, Ltd.,
Dayton, OH
Fontana Academy of Martial Arts,
Fontana, CA
Foundation for Clean Air Progress,
Washington, DC
Foundation for Peace, Inc.,
Brookville, NY
Foundation for the Children of Haiti,
Dix Hills, NY
Foundation for the Prevention and
Recovery of Missing Children,
Boca Raton, FL
Friends of Beth Yisrael Institutions,
Brooklyn, NY
Friends of Rye Brook, Inc.,
Rye Brook, NY
Friends of the William Floyd Estate,
Inc., Patchogue, NY
Frontier Fertilizer Superfund Oversight
Group, Davis, CA
Fund for the Children of Chernobyl
Northwest United States of America,
Kent, WA
Garland Genealogical Society, Inc.,
Garland, TX
Give a Helping Hand Corporation,
Bay Shore, NY
Griffin-Spalding Clean Community
Commission, Inc., Griffin, GA
Habitat for Elderly & Handicapped, Inc.,
Shirley, NY
Hampton Roads Boys-Girls Club
Alumni Association,
Newport News, VA
Hashevaynu, Inc., Monsey, NY
Health Care Resources Interlink, Inc.,
Care Resources, San Jose, CA
High Thoughts Ministries, Inc.,
Newbury Park, CA
Hmong American Womens Association,
Milwaukee, WI
Homeowners Assistance Corporation of
New York, St. Albans, NY
Inner-Outer Partnership,
Pacific Palisades, CA
Institute for Community Leadership
Training, Inc., Brooklyn, NY
Institute of World Traditional Medicine,
Santa Monica, CA
Interactive Trust - A Foundation for
America, Des Moines, IA
International Center for Jewish
Peoplehood, Memphis, TN
International Skating Center of
Connecticut Scholarship Foundation,
Avon, CT
International Used Oil Research Institute,
Mobile, AL
Internet Nonprofit Center, Inc.,
Brooklyn, NY
Irish Services, Inc., Woodside, NY
Island Park Playground Fund
Organization, Inc., Island Park, NY
It Takes a Village, Inc., Chicago, IL
Jesus the Living Word Ministries, Inc.,
Hughson, CA
Jim Clark Community Services, Inc.,
Inglewood, CA
June and Roy Metcalf Elementary Parent-
Teacher Organization, Houston, TX
Kansas Community Corporation,
Kansas, IL
Keeping Brothers in School, Inc.,
Brooklyn, NY
Keren Aniyai Irchoh, Inc., Brooklyn, NY
Kids Instilled with Dignity Survive Kids,
Inc., Ponte Verde, FL
Kids Nutritional Services, Slidell, LA
Kincraig Housing, Inc., Brooklyn, NY
King Kekaulike High School Band
Boosters, Pukalani, HI
Koakos Syllogos Ippocrates, Inc.,
Astoria, NY
Kolel Zichron Yoseph, Inc.,
Brooklyn, NY
Laneville Christmas Light Display,
Laneville, TX
Lantern Theatre, Inc., Wantagh, NY
Law Review, Inc., Edina, MN
League of Muslim Women of Rochester,
Rochester, NY
Light to the Nations, Inc., Brooklyn, NY
Long Island Counseling Center, Inc.,
Mineola, NY
Machne Menachem, Inc., Brooklyn, NY
Marcus High School Basketball Booster
Club, Flower Mound, TX
Masumeen Charitable Trust,
North Reading, MA
Maumee High School Ice Hockey
Association, Maumee, OH
Mesorah Center for Jewish Studies
Charitable Trust, Highland Park, NJ
Mindpaint Workshop, Lincoln, NE
Mishkan Yaakov Charitable Trust,
New York, NY
Mission Crusade, Inc., Forest Hills, NY
Moharil Ashlag Torah Center, Inc.,
Brooklyn, NY
Monsignor Michael Fleming Catholic
Youth Foundation, Inc., Bayside, NY
Moscow State University Center for
Social Services and Humanities,
Arlington, VA
MRC Housing Development Fund
Company, Inc., Brooklyn, NY
Municipal Training Center Queens, Inc.,
Jamaica, NY
Nassau Community Outreach
Consortium, Inc., Lawrence, NY
National Educator Foundation,
Los Angeles, CA
National Independence Day Parade, Inc.,
Washington, DC
National Organization for Von
Willebrand Patients & Carriers, Inc.,
Cockeysville, MD
Neurodegenerative Disease Foundation,
Inc., Huntington, NY
New Creation Ministries,
Wenatchee, WA
New Dialogue Study Group, Inc.,
Rego Park, NY
New Horizon Childrens Enrichment
Center, Dothan, AL
New York Guard Foundation, Inc.,
White Plains, NY
Northeast Community Feed-a-Meal
Program, Mer Rouge, LA
North Haven Historical Cemetary
Association, Inc., Sag Harbor, NY
North Posey Athletic Booster Club, Inc.,
Poseyville, IN
Oklahoma Association of Urban Bankers,
Oklahoma City, OK
Olympic Peninsula Intertribal Cultural
Advisory Committee, Kingston, WA
Osage Resident Council Association,
Skiatook, OK
Outreach Childrens Home,
Nashville, TN
Oxbridge Study Abroad Center,
Washington, DC
Palm Beaches Alive, Inc.,
West Palm Beach, FL
Parker Youth, Inc., Parker, CO
Parsippany High School Wrestling
Boosters Parents Association,
Parsippany, NJ
Pathways Spiritual Foundation,
Laguna Beach, CA
Project Destiny International Scholarship
Foundation, Inc., Jamaica, NY
Project Intercept, Inc., St. Paul, MN
Project Pass, St. Louis, MO
2000–46 I.R.B.485November 13, 2000

Protestant Lawyers Association of New
York Scholarship Fund, Inc.,
Brooklyn, NY
Pursuit Soccer Club, Spring, TX
Quick Social Services, Inc.,
Wyandanch, NY
Quota Club of Tulsa Charitable and
Educational Foundation, Inc.,
Talala, OK
Rabbi Yisroel Aryeh Leib Research
Institute on Moshiach and the Scie,
Brooklyn, NY
Rabbinical Study - Ohel Shlomo, Inc.,
Brooklyn, NY
Radcliffe Sorority Sisters, Inc.,
Radcliffe, IA
Reach Foundation,
Shaker Heights, OH
Reaching Out the African-American
Youth Mentoring Service, Tacoma, WA
Rebel Alliance Theatre, Inc.,
Oshkosh, WI
Renaissance Alano Club, Santa Ana, CA
Rhode Island Breast Cancer Coalition,
Inc., Coventry, RI
River Run Arts - Earth Studies Camp,
Inc., Peninsula, OH
Rivers Bend Playhouse, Inc.,
Evansville, IN
Rosemary Fund, Inc., Franklin Sq, NY
Rwanda Reconstruction Fund, Inc.,
Rockville, MD
Santa Paula Foundation for Youth,
Ventura, CA
Sarajevo Fund, Incorporated,
New York, NY
Save Our Selves, Inc., Bowie, MD
Save our Smile SOS, Inc., Dix Hills, NY
Save the Horse, Inc., Old Bethpage, NY
Scholar Athletes, Inc., Westbury, NY
Selig Gourson Tapemobile, Inc.,
Brooklyn, NY
Seven Loaves & Five Fishes, Inc.,
Mission, Brooklyn, NY
Seventh Principle, Inc., South Orange, NJ
Sigma Phi Omega National Honor
Society, Washington, DC
Sixty-Five Roses Auxiliary, Inc.,
Phoenix, AZ
Sonoma County Braillists, Inc.,
Santa Rosa, CA
Southern California Support for Children,
Inc., Yucaipa, CA
Special Forces Ministries, Inc.,
Brusly, LA
Starbrite Foundation, Phoenix, AZ
Stillwater Volunteer Fire Association,
Cincinnati, OH
Stonewall Jackson Middle School,
Mechanicsville, VA
Stop Abuse, Inc., Canoga Park, CA
Supportive Living Program, Inc.,
Quincy, MA
Substainable Communities, Inc.,
Santa Fe, NM
Tanitas, Inc., Chevy Chase, MD
Tax History Foundation and Museum,
Northfield, IL
Teal Lost Land & Ghost Lakes
Improvement Assn., Hayward, WI
Telos Institute, Inc., Candor, NY
Toaster Museum Foundation, Inc.,
Charlottesville, VA
Tov-Roi Foundation, Inc., Brooklyn, NY
TRRE Foundation, Seattle, WA
Tulsa Area Wheelchair Sports
Association, Inc., Tulsa, OK
Tunbridge Engine Company, Inc.,
Tunbridge, VT
United Ethiopian Services, Inc.,
Cambridge, MA
Universal Peace Mission, Inc.,
Pittsburgh, PA
Vaad L’Hatzolas Nidchei Yisroel, Inc.,
Brooklyn, NY
Valley Coalition for the Homeless,
San Benito, CA
Vermilion Schools Athletic Boosters,
Inc., Vermilion, OH
Veuhsesuh Hayushor Vehatov, Inc.
Monroe, NY
Victorious Overcomers Community
Alliance, Inc., Amityville, NY
Vietnam Veterans for Christ, Phoenix, AZ
Walk for a Cure Foundation, Salem, OR
Wellness Education Foundation,
Carlsbad, CA
Wellston Community Support Assoc.,
St. Louis, MO
Whiteman Officers Wives Club,
Warrensburg, MO
Worldwide Gospel Tracts, Inc.,
Pasadena, CA
Yamim, Inc., New York, NY
Yeshiva Chasidei Belz of Jerusalem,
Brooklyn, NY
Yeshiva Shalom Rav, Far Rockaway, NY
Youth Frontiers, Inc., Bronx, NY
YSI International, Hollywood, FL
Yvettes Creative Learning, Inc.,
Marietta, GA
Zomet, Woodmere, NY
1884 Oakhurst Links Foundation,
White Sulphur Springs, WV
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.
Tax Treatment of Cafeteria
Plans; Correction
Announcement 2000–92
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Correction to notice of pro-
posed rulemaking.
SUMMARY: This document contains a
correction to proposed regulations that
were published in the Federal Register
on Thursday, March 23, 2000 (65 F.R.
15587), relating to tax treatment of cafe-
teria plans.
FOR FURTHER INFORMATION CON-
TACT: Christine L. Keller at (202) 622-
6080 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The notice of proposed rulemaking that
is the subject of this correction is under
section 125 of the Internal Revenue Code.
Need for Correction
As published, the proposed regulations
contain an error that may prove to be mis-
leading and is in need of clarification.
Correction of Publication
Accordingly, the publication of the pro-
posed regulations (REG–117162–99,
2000–15 I.R.B. 871), that were the sub-
ject of FR Doc. 00–5818, is corrected as
follows:
On page 15587, column 2, the regula-
tion heading in the middle of the column,
line 5, the “RIN 1545–AX59” is corrected
to read “RIN 1545–AY23”.
November 13, 20004862000–46 I.R.B.

Cynthia E. Grigsby,
Chief, Regulations Unit,
Office of Special Counsel
(Modernization and Strategic Planning)
(Filed by the Office of the Federal Register on Octo-
ber 24, 2000, 8:45 a.m., and published in the issue of
the Federal Register for October 25, 2000, 65 F.R.
63824)
IRS and George Washington
University to Sponsor Institute
on International Tax Issues
Announcement 2000–93
Director, International, LMSB, Carol
A. Dunahoo has announced the Thirteenth
Annual Institute on Current Issues in In-
ternational Taxation, jointly sponsored by
the Internal Revenue Service and The
George Washington University, to be held
on December 7 and 8, 2000 at the J.W.
Marriott Hotel in Washington, DC. Reg-
istration is currently underway for the In-
stitute, which is intended for profession-
als in international tax law.
The program will present a unique op-
portunity for top IRS and Treasury officials
and tax experts, as well as leading private
sector specialists, to address breaking is-
sues and present key perspectives on new
developments. The Institute will open with
an address by Jeffrey Owens, Head of Fis-
cal Affairs Division, Organisation for Eco-
nomic Co-operation and Development.
The first day will also feature sessions on
corporate tax shelters from an international
perspective, new ways of handling tax con-
troversies, and inbound and outbound up-
dates. Competent Authority officials from
Canada, Japan, the United Kingdom, and
the United States will discuss current and
emerging issues. Larry Langdon, Com-
missioner of the IRS Large and Mid-Size
Business Division, will provide the lun-
cheon address.
The second day will focus on interna-
tional tax issues in the New Economy, in-
cluding character of income and perma-
nent establishment, e-commerce
implications for Subpart F, income sourc-
ing rules and transfer pricing, e-com-
merce and the EU VAT proposal, and vir-
tual relationships in an e-commerce
world. Jonathan Talisman, Acting Assis-
tant Secretary for Tax Policy, Department
of the Treasury, will provide the luncheon
address. The second day will also in-
clude an “Ask the IRS” panel.
Those interested in attending or obtain-
ing more information should contact The
George Washington University, Confer-
ence Management Services, by phone at
(202) 973-1110 or by visiting their web
site at http://www.gwu.edu/~cms/iti13.
2000–46 I.R.B.487November 13, 2000

November 13, 2000i2000–46 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 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 Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign Corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statements of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Definition of Terms

2000–46 I.R.B.iiNovember 13, 2000
Numerical Finding List
1
Bulletins 2000–27 through 2000–45
Announcements:
2000–57, 2000–28 I.R.B. 115
2000–58, 2000–30 I.R.B. 135
2000–59, 2000–29 I.R.B. 120
2000–60, 2000–31 I.R.B. 149
2000–61, 2000–30 I.R.B. 136
2000–62, 2000–30 I.R.B. 137
2000–63, 2000–31 I.R.B. 149
2000–64, 2000–31 I.R.B. 149
2000–65, 2000–31 I.R.B. 150
2000–66, 2000–32 I.R.B. 160
2000–67, 2000–32 I.R.B. 160
2000–68, 2000–32 I.R.B. 161
2000–69, 2000–33 I.R.B. 183
2000–70, 2000–34 I.R.B. 204
2000–71, 2000–44 I.R.B. 456
2000–72, 2000–35 I.R.B. 226
2000–73, 2000–35 I.R.B. 230
2000–74, 2000–35 I.R.B. 230
2000–75, 2000–37 I.R.B. 268
2000–76, 2000–36 I.R.B. 260
2000–77, 2000–36 I.R.B. 260
2000–78, 2000–43 I.R.B. 428
2000–79, 2000–39 I.R.B. 303
2000–80, 2000–40 I.R.B. 320
2000–81, 2000–41 I.R.B. 348
2000–82, 2000–42 I.R.B. 385
2000–83, 2000–41 I.R.B. 348
2000–84, 2000–42 I.R.B. 385
2000–85, 2000–43 I.R.B. 429
2000–86, 2000–44 I.R.B. 456
2000–87, 2000–44 I.R.B. 457
2000–88, 2000–44 I.R.B. 460
2000–89, 2000–45 I.R.B. 467
Court Decisions:
2068, 2000–28 I.R.B. 109
Notices:
2000–33, 2000–27 I.R.B. 97
2000–34, 2000–33 I.R.B. 172
2000–35, 2000–29 I.R.B. 118
2000–36, 2000–33 I.R.B. 173
2000–37, 2000–29 I.R.B. 118
2000–38, 2000–33 I.R.B. 174
2000–39, 2000–30 I.R.B. 132
2000–40, 2000–30 I.R.B. 134
2000–41, 2000–33 I.R.B. 177
2000–42, 2000–39 I.R.B. 302
2000–43, 2000–35 I.R.B. 209
2000–44, 2000–36 I.R.B. 255
2000–45, 2000–36 I.R.B. 256
2000–46, 2000–37 I.R.B. 265
2000–48, 2000–37 I.R.B. 265
2000–49, 2000–37 I.R.B. 266
2000–50, 2000–38 I.R.B. 291
2000–51, 2000–38 I.R.B. 291
2000–52, 2000–38 I.R.B. 292
2000–53, 2000–38 I.R.B. 293
2000–54, 2000–42 I.R.B. 356
2000–55, 2000–43 I.R.B. 393
2000–56, 2000–43 I.R.B. 393
2000–57, 2000–43 I.R.B. 389
Proposed Regulations:
REG–209038–89, 2000–34 I.R.B. 191
Proposed Regulations—Continued
REG–246249–96, 2000–44 I.R.B. 439
REG–105316–98, 2000–27 I.R.B. 98
REG–110311–98, 2000–36 I.R.B. 258
REG–103805–99, 2000–42 I.R.B. 376
REG–105235–99, 2000–44 I.R.B. 447
REG–116495–99, 2000–33 I.R.B. 179
REG–103735–00, 2000–36 I.R.B. 258
REG–103736–00, 2000–36 I.R.B. 258
REG–106511–00, 2000–45 I.R.B. 465
REG–108522–00, 2000–34 I.R.B. 187
REG–108553–00, 2000–44 I.R.B. 452
REG–112502–00, 2000–40 I.R.B. 316
REG–114697–00, 2000–43 I.R.B. 421
Railroad Retirement Quarterly Rate:
2000–28, I.R.B. 112
2000–29, I.R.B. 117
2000–42, I.R.B. 354
Revenue Procedures:
2000–28, 2000–27 I.R.B. 60
2000–29, 2000–28 I.R.B. 113
2000–30, 2000–28 I.R.B. 113
2000–31, 2000–31 I.R.B. 146
2000–32, 2000–33 I.R.B. 172
2000–33, 2000–36 I.R.B. 257
2000–34, 2000–34 I.R.B. 186
2000–35, 2000–35 I.R.B. 211
2000–36, 2000–37 I.R.B. 267
2000–37, 2000–40 I.R.B. 308
2000–38, 2000–40 I.R.B. 310
2000–39, 2000–41 I.R.B. 340
2000–40, 2000–42 I.R.B. 357
2000–41, 2000–42 I.R.B. 371
2000–42, 2000–43 I.R.B. 394
2000–43, 2000–43 I.R.B. 404
2000–44, 2000–43 I.R.B. 409
2000–45, 2000–43 I.R.B. 417
2000–46, 2000–44 I.R.B. 438
Revenue Rulings:
2000–32, 2000–27 I.R.B. 1
2000–33, 2000–31 I.R.B. 142
2000–34, 2000–29 I.R.B. 116
2000–35, 2000–31 I.R.B. 138
2000–36, 2000–31 I.R.B. 140
2000–37, 2000–32 I.R.B. 156
2000–38, 2000–32 I.R.B. 157
2000–39, 2000–34 I.R.B. 184
2000–40, 2000–35 I.R.B. 208
2000–41, 2000–36 I.R.B. 248
2000–42, 2000–39 I.R.B. 297
2000–43, 2000–41 I.R.B. 333
2000–44, 2000–41 I.R.B. 336
2000–45, 2000–41 I.R.B. 337
2000–46, 2000–41 I.R.B. 334
2000–47, 2000–37 I.R.B. 264
2000–48, 2000–42 I.R.B. 349
2000–49, 2000–44 I.R.B. 430
2000–50, 2000–45 I.R.B. 462
Treasury Decisions:
8886, 2000–27 I.R.B. 3
8888, 2000–27 I.R.B. 3
8889, 2000–30 I.R.B. 124
8890, 2000–30 I.R.B. 122
8891, 2000–32 I.R.B. 152
8892, 2000–32 I.R.B. 158
8893, 2000–31 I.R.B. 143
Treasury Decisions—Continued
8894, 2000–33 I.R.B. 162
8895, 2000–40 I.R.B. 304
8896, 2000–36 I.R.B. 249
8897, 2000–36 I.R.B. 234
8898, 2000–38 I.R.B. 276
8899, 2000–38 I.R.B. 288
8900, 2000–38 I.R.B. 279
8901, 2000–38 I.R.B. 272
8902, 2000–41 I.R.B. 323
8903, 2000–42 I.R.B. 352
8904, 2000–42 I.R.B. 350
8905, 2000–44 I.R.B. 435
1
A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 2000–1 through 2000–26
is in Internal Revenue Bulletin 2000–27, dated July
3, 2000.

November 13, 2000iii2000–46 I.R.B.
Finding List of Current Actions on
Previously Published Items
1
Bulletins 2000–27 through 2000–45
Notices:
87–76
Obsoleted by
T.D. 8897, 2000–36 I.R.B. 234
88–24
Obsoleted by
T.D. 8897, 2000–36 I.R.B. 234
88–86
Obsoleted by
T.D. 8897 (section V), 2000–36 I.R.B. 234
2000–48
Superseded by
Rev. Proc. 2000–39, 2000–41 I.R.B. 340
Proposed Regulations:
LR–97–79
Partial withdrawal by
REG–103805–99, 2000–42 I.R.B. 376
FI–42–90
Withdrawn by
Announcement 2000–63, 2000–31 I.R.B. 149
IA–38–93
Withdrawn by
Announcement 2000–68, 2000–32 I.R.B. 161
REG–107644–98
Corrected by
Announcement 2000–66, 2000–32 I.R.B. 160
REG–108522–00
Corrected by
Announcement 2000–85, 2000–43 I.R.B. 428
Revenue Procedures:
88–23
Superseded by
Rev. Proc. 2000–35, 2000–35 I.R.B. 211
98–50
Modified and superseded by
Rev. Proc. 2000–31, 2000–31 I.R.B. 146
98–51
Modified and superseded by
Rev. Proc. 2000–31, 2000–31 I.R.B. 146
99–18
Modified by
Rev. Proc. 2000–29, 2000–28 I.R.B. 113
99–34
Superseded by
Rev. Proc. 2000–28, 2000–27 I.R.B. 60
99–49
Modified and amplified by
Rev. Proc. 2000–38, 2000–40 I.R.B. 310
2000–3
Amplified by
Rev. Proc. 2000–46, 2000–44 I.R.B. 438
2000–9
Superseded by
Rev. Proc. 2000–39, 2000–41 I.R.B. 340
Treasury Decisions:
8873
Corrected by
Announcement 2000–74, 2000–35 I.R.B. 230
8883
Corrected by
Announcement 2000–57, 2000–28 I.R.B. 115
8884
Corrected by
Announcement 2000–73, 2000–35 I.R.B. 230
8892
Corrected by
Announcement 2000–81, 2000–41 I.R.B. 348
1
A cumulative list of current actions on previously
published items in Internal Revenue Bulletins
2000–1 through 2000–26 is in Internal Revenue
Bulletin 2000–27, dated July 3, 2000.

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.
ACCESS THE INTERNAL REVENUE BULLETIN ON THE INTERNET
You may view the Internal Revenue Bulletin on the Internet at www.irs.gov. Select Tax Info for Business at the bottom of the
page. Then select Internal Revenue Bulletins.
INTERNAL REVENUE BULLETINS ON CD–ROM
Internal Revenue Bulletins are available annually as part of Publication 1796 (Tax Products CD–ROM). The CD–ROM can be
purchased from National Technical Information Service (NTIS) on the Internet at www.irs.gov/cdorders(discount for online orders)
or by calling 1-877-233-6767. The first release is available in mid-December and the final release is available in late January.
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, P.O. Box 371954, Pittsburgh, PA 15250–7954. 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, W:CAR:MP:FP, Washington, DC 20224.
Internal Revenue Service
Washington, DC 20224
Official Business
Penalty for Private Use, $300