Internal Revenue Bulletin 2000-20 (PDF rendition): IRS Revenue Procedures

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INCOME TAX
Rev. Rul. 2000–25, page 1006.
LIFO; price indexes; department stores.The March 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, March 31, 2000.
Rev. Proc. 2000–22, page 1008.
Methods of accounting; inventories; small taxpayers.
This revenue procedure provides that the Commissioner will
exercise his discretion to except a qualifying taxpayer with av-
erage annual gross receipts of $1,000,000 or less from the
requirements to account for inventories and to use an accrual
method of accounting for purchases and sales of merchan-
dise.
EMPLOYEE PLANS
T.D. 8880, page 1003.
Final regulations under section 401(a)(31) of the Code pro-
vide relief from disqualification to an eligible retirement plan
that inadvertently accepts an invalid rollover contribution.
Internal Revenue
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Bulletin No. 2000–20
May 15, 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 Disbarments and Suspensions begins on page 1011.

May 15, 20002000–20 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 162.—Trade or
Business Expenses
26 CFR 1.162–3: Cost of materials.
Will the Commissioner exercise his discretion to
except a qualifying taxpayer with average annual
gross receipts of $1,000,000 or less from the re-
quirements to account for inventories and to use an
accural method of accounting for purchases and
sales of merchandise. See Rev. Proc. 2000–22, page
1008.
Section 263A.—Capitalization
and Inclusion in Inventory Costs
of Certain Expenses
26 CFR 1.263A–2: Rules relating to property
produced by the taxpayer.
Will the Commissioner exercise his discretion to
except a qualifying taxpayer with average annual
gross receipts of $1,000,000 or less from the re-
quirements to account for invetories and to use an
accrual method of accounting for purchases and
sales of merchandise. See Rev. Proc. 2000–22, page
1008.
Section 401.—Qualified
Pension, Profit-Sharing, and
Stock Bonus Plans
26 CFR 1.401(a)(31)–1: Requirement to offer direct
rollover of eligible rollover distributions; questions
and answers.
T.D. 8880
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Parts 1 and 31
Relief From Disqualification for
Plans Accepting Rollovers
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations.
SUMMARY: This document contains
final regulations under section 401(a)(31)
of the Internal Revenue Code. These final
regulations provide specific rules that
grant relief from disqualification to an eli-
gible retirement plan that inadvertently
accepts an invalid rollover contribution.
The final regulations also clarify that it is
not necessary for a distributing plan to
have a favorable IRS determination letter
in order for a plan administrator of a re-
ceiving plan to reach a reasonable conclu-
sion that a contribution is a valid rollover
contribution.
DATES: These regulations are effective
on April 21, 2000.
FOR FURTHER INFORMATION CON-
TACT: Pamela R. Kinard, (202) 622-6030
(not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
On September 22, 1995, the Treasury
Department and the IRS published in the
Federal Register (60 F.R. 49199) final in-
come tax regulations (T.D. 8619, 1995–2
C.B. 41) under sections 401(a)(31) and
402(c). The final regulations provide
guidance for complying with the Unem-
ployment Compensation Amendments of
1992 (UCA). A proposed amendment to
the regulations (REG–245562–96,
1999–9 I.R.B. 45) under section
401(a)(31) was published in the Federal
Register (61 F.R. 49279) on September
19, 1996. The 1996 proposed regulations
under sections 401(a)(31) and 402(c) ex-
pand and clarify the guidance previously
issued in the final income tax regulations.
On December 17, 1998, an amendment to
the proposed regulations (REG–
245562–96) under section 401(a)(31) was
published in the Federal Register (63 F.R.
69584). This amendment to the proposed
regulations was issued in response to the
congressional directive in section 1509 of
Taxpayer Relief Act of 1997 (TRA ’97),
which directs the IRS to issue guidance
clarifying that it is not necessary for a dis-
tributing plan to have a favorable IRS de-
termination letter in order for a plan ad-
ministrator of a receiving plan to
reasonably conclude that a contribution is
a valid rollover contribution. Written
comments responding to the 1996 pro-
posed regulations were received. There
were no written comments responding to
the 1998 amendment to the proposed reg-
ulations. No public hearing was requested
or held. After consideration of the com-
ments, the amended proposed regulations
under section 401(a)(31) are adopted by
this Treasury decision.
Explanation of Provisions and
Summary of Comments
A. Relief From Disqualification
The final regulations under section
401(a)(31) of the Internal Revenue Code
provide that an eligible retirement plan
which accepts a direct rollover from an-
other plan will not fail to satisfy section
401(a) or 403(a) merely because the plan
making the distribution is, in fact, not
qualified under section 401(a) or 403(a) at
the time of the distribution if, prior to ac-
cepting the rollover, the plan administra-
tor of the receiving plan reasonably con-
cluded that the distributing plan was
qualified under section 401(a) or 403(a).
The proposed regulations clarify and
expand upon this relief. Under the pro-
posed regulations, an eligible retirement
plan that accepts an invalid rollover con-
tribution, whether as a direct rollover or
as a rollover contribution other than a di-
rect rollover, will be treated, for purposes
of section 401(a) or 403(a), as accepting a
valid rollover contribution, if the plan ad-
ministrator of the receiving plan satisfies
two conditions. First, when accepting the
rollover contribution, the plan administra-
tor of the receiving plan must reasonably
conclude that the rollover contribution is
a valid rollover contribution. Second, if
the plan administrator of the receiving
plan later determines that the rollover
contribution was an invalid rollover con-
tribution, the plan must distribute the
amount of the invalid rollover contribu-
tion, plus earnings attributable thereto, to
the employee within a reasonable period
of time.
B. Documentation Offered as Evidence
to Support a Reasonable Conclusion
The 1996 proposed regulations do not
mandate any particular documentation or
procedures that a plan administrator must
use in order to reach a reasonable conclu-
sion that a rollover contribution is a valid
rollover contribution. The 1996 proposed
regulations contain a series of examples
to illustrate the types of documentation
and procedures that would be sufficient to
support a reasonable conclusion. In each
example, the employee making the
2000–20 I.R.B.1003May 15, 2000
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

rollover contribution provides the plan
administrator of the receiving plan with a
letter from the plan administrator of the
distributing plan stating that the distribut-
ing plan has received an IRS determina-
tion letter indicating that the distributing
plan is qualified under section 401(a).
Several commentators stated that the
examples in the 1996 proposed regula-
tions appear to imply that the acknowl-
edgment of the receipt of a favorable IRS
determination letter by a distributing plan
is a prerequisite to a plan administrator of
a receiving plan reaching a reasonable
conclusion that a rollover contribution is a
valid rollover contribution. Commenta-
tors argued that the public policy goal of
pension portability would be impeded if
an eligible retirement plan is subject to
complex administrative procedures when
accepting rollover contributions. These
concerns were addressed in the 1998
amendment to the proposed regulations
implementing the congressional directive
in section 1509 of TRA ‘97. That amend-
ment clarifies that it is not necessary for a
distributing plan to have a favorable IRS
determination letter in order for a plan ad-
ministrator of a receiving plan to reach a
reasonable conclusion that a contribution
is a valid rollover contribution. In addi-
tion, an example was added to the pro-
posed regulations in which an employee
does not provide a statement from the dis-
tributing plan administrator that the dis-
tributing plan has received a favorable
IRS determination letter, but instead the
employee provides a statement from the
distributing plan administrator relating to
the qualification of the distributing plan.
In the preamble to the 1998 amendment to
the proposed regulations, it is stressed
that none of the examples in the proposed
regulations are intended to describe the
only types of information that a plan ad-
ministrator can find to be sufficient and
the examples are not intended to preclude
reliance on other types of information,
such as opinions or statements regarding
the plan’s qualification provided by ap-
propriate professionals with expertise in
plan qualification requirements.
C. Miscellaneous Comments
One commentator stated that both Ex-
amples 1and 3in the proposed regulations,
which provide that Employee A will not
have attained age 70 1/2 by the end of the
year in which the rollover contribution will
occur, imply that if an employee were age
70 1/2 or older, a rollover option would be
unavailable. This implication was not in-
tended. The fact was included merely to il-
lustrate the more common scenario of an
employee who is under age 70 1/2 and
rolls over a retirement plan distribution.
Some commentators proposed that guid-
ance is needed regarding the procedures for
correcting invalid rollover contributions.
One commentator suggested that relief,
similar to that provided to plans receiving
invalid rollover contributions, should also
be afforded to plans receiving assets and li-
ability transfers in the event that a trans-
feror’s plan does not satisfy the qualifica-
tion requirements under the Code. These
comments will be taken into account in de-
veloping future guidance priorities.
Special Analyses
It has been determined that this Trea-
sury decision is not a significant regula-
tory action as defined in Executive Order
12866. Therefore, a regulatory assess-
ment is not required. It also has been de-
termined that section 553(b) of the Ad-
ministrative Procedure Act (5 U.S.C.
chapter 5) does not apply to these regula-
tions, and because these regulations do
not impose a collection of information on
small entities, the Regulatory Flexibility
Act (5 U.S.C. chapter 6) does not apply.
Therefore, a Regulatory Flexibility
Analysis is not required. Pursuant to sec-
tion 7805(f) of the Internal Revenue
Code, the notice of proposed rulemaking
preceding these regulations was submit-
ted to the Chief Counsel for Advocacy of
the Small Business Administration for
comment on its impact on small business.
Drafting Information
The principal author of these regula-
tions is Pamela R. Kinard, Office of the
Associate Chief Counsel (Employee Ben-
efits and Exempt Organizations), IRS.
However, other personnel from the IRS
and Treasury Department participated in
their development.
* * * * *
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR parts 1 and 31 are
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 1.401(a)(31)–1 is
amended as follows:
1. Under the heading “List of Ques-
tions,” redesignating Q-14 through Q-18
as Q-15 through Q-19, respectively, and
adding new Q-14.
2. Under the heading “Questions and
Answers,” removing the paragraph desig-
nation (a) and the paragraph heading, and
removing paragraph (b) from A-13.
3. Under the heading “Questions and
Answers,” redesignating Q&A-14
through Q&A-18 as Q&A-15 through
Q&A-19, respectively, and adding new
Q&A-14.
4. Under the heading “Questions and
Answers,” removing the language “Q&A-
15” in the fourth sentence of the newly
designated A-16 and adding “Q&A-16” in
its place.
5. Under the heading “Questions and
Answers,” removing the language “Q&A-
17” in the first sentence of the newly des-
ignated A-18 and adding “Q&A-18” in its
place.
The additions read as follows:
§1.401(a)(31)–1 Requirement to offer
direct rollover of eligible rollover
distributions; questions and answers.
* * * * *
List of Questions
* * * * *
Q-14. If a plan accepts an invalid
rollover contribution, whether or not as a
direct rollover, how will the contribution
be treated for purposes of applying the
qualification requirements of section
401(a) or 403(a) to the plan?
* * * * *
Questions and Answers
* * * * *
Q-14. If a plan accepts an invalid
rollover contribution, whether or not as a
direct rollover, how will the contribution
be treated for purposes of applying the
qualification requirements of section
401(a) or 403(a) to the plan?
A-14. (a) Acceptance of invalid
rollover contribution. If a plan accepts an
invalid rollover contribution, the contri-
bution will be treated, for purposes of ap-
plying the qualification requirements of
May 15, 200010042000–20 I.R.B.

section 401(a) or 403(a) to the receiving
plan, as if it were a valid rollover contri-
bution, if the following two conditions are
satisfied. First, when accepting the
amount from the employee as a rollover
contribution, the plan administrator of the
receiving plan reasonably concludes that
the contribution is a valid rollover contri-
bution. While evidence that the distribut-
ing plan is the subject of a determination
letter from the Commissioner indicating
that the distributing plan is qualified
would be useful to the receiving plan ad-
ministrator in reasonably concluding that
the contribution is a valid rollover contri-
bution, it is not necessary for the distrib-
uting plan to have such a determination
letter in order for the receiving plan ad-
ministrator to reach that conclusion. Sec-
ond, if the plan administrator of the re-
ceiving plan later determines that the
contribution was an invalid rollover con-
tribution, the amount of the invalid
rollover contribution, plus any earnings
attributable thereto, is distributed to the
employee within a reasonable time after
such determination.
(b) Definitions. For purposes of this
Q&A-14:
(1) An invalid rollover contribution is
an amount that is accepted by a plan as a
rollover within the meaning of
§1.402(c)–2, Q&A-1 (or as a rollover
contribution within the meaning of sec-
tion 408(d)(3)(A)(ii)) but that is not an el-
igible rollover distribution from a quali-
fied plan (or an amount described in
section 408(d)(3)(A)(ii)) or that does not
satisfy the other requirements of section
401(a)(31), 402(c), or 408(d)(3) for treat-
ment as a rollover or a rollover contribu-
tion.
(2) A valid rollover contribution is a
contribution that is accepted by a plan as a
rollover within the meaning of
§1.402(c)–2, Q&A-1 or as a rollover con-
tribution within the meaning of section
408(d)(3) and that satisfies the require-
ments of section 401(a)(31), 402(c), or
408(d)(3) for treatment as a rollover or a
rollover contribution.
(c) Examples. The provisions of para-
graph (a) of this Q&A-14 are illustrated
by the following examples:
Example 1. (i) Employer X maintains for its em-
ployees Plan M, a profit sharing plan qualified under
section 401(a). Plan M provides that any employee
of Employer X may make a rollover contribution to
Plan M. Employee A is an employee of Employer
X, will not have attained age 70 1/2 by the end of the
year, and has a vested account balance in Plan O (a
plan maintained by Employee A’s prior employer).
Employee A elects a single sum distribution from
Plan O and elects that it be paid to Plan M in a direct
rollover.
(ii) Employee A provides the plan administrator
of Plan M with a letter from the plan administrator
of Plan O stating that Plan O has received a determi-
nation letter from the Commissioner indicating that
Plan O is qualified.
(iii) Based upon such a letter, absent facts to the
contrary, a plan administrator may reasonably con-
clude that Plan O is qualified and that the amount
paid as a direct rollover is an eligible rollover distri-
bution.
Example 2. (i) The facts are the same as Example
1, except that, instead of the letter provided in para-
graph (ii) of Example 1, Employee A provides the
plan administrator of Plan M with a letter from the
plan administrator of Plan O representing that Plan
O satisfies the requirements of section 401(a) (or
representing that Plan O is intended to satisfy the re-
quirements of section 401(a) and that the adminis-
trator of Plan O is not aware of any Plan O provision
or operation that would result in the disqualification
of Plan O).
(ii) Based upon such a letter, absent facts to the
contrary, a plan administrator may reasonably con-
clude that Plan O is qualified and that the amount
paid as a direct rollover is an eligible rollover distri-
bution.
Example 3. (i) Same facts as Example 1, except
that Employee A elects to receive the distribution
from Plan O and wishes to make a rollover contribu-
tion described in section 402 rather than a direct
rollover.
(ii) When making the rollover contribution, Em-
ployee A certifies that, to the best of Employee A’s
knowledge, Employee A is entitled to the distribu-
tion as an employee and not as a beneficiary, the dis-
tribution from Plan O to be contributed to Plan M is
not one of a series of periodic payments, the distrib-
ution from Plan O was received by Employee A not
more than 60 days before the date of the rollover
contribution, and the entire amount of the rollover
contribution would be includible in gross income if
it were not being rolled over.
(iii) As support for these certifications, Employee
A provides the plan administrator of Plan M with
two statements from Plan O. The first is a letter
from the plan administrator of Plan O, as described
in Example 1, stating that Plan O has received a de-
termination letter from the Commissioner indicating
that Plan O is qualified. The second is the distribu-
tion statement that accompanied the distribution
check. The distribution statement indicates that the
distribution is being made by Plan O to Employee A,
indicates the gross amount of the distribution, and
indicates the amount withheld as Federal income
tax. The amount withheld as Federal income tax is
20 percent of the gross amount of the distribution.
Employee A contributes to Plan M an amount not
greater than the gross amount of the distribution
stated in the letter from Plan O and the contribution
is made within 60 days of the date of the distribution
statement from Plan O.
(iv) Based on the certifications and documenta-
tion provided by Employee A, absent facts to the
contrary, a plan administrator may reasonably con-
clude that Plan O is qualified and that the distribu-
tion otherwise satisfies the requirements of section
402(c) for treatment as a rollover contribution.
Example 4. (i) The facts are the same as in Ex-
ample 3, except that, rather than contributing the
distribution from Plan O to Plan M, Employee A
contributes the distribution from Plan O to IRA P, an
individual retirement account described in section
408(a). After the contribution of the distribution
from Plan O to IRA P, but before the year in which
Employee A attains age 70 _, Employee A requests a
distribution from IRA P and decides to contribute it
to Plan M as a rollover contribution. To make the
rollover contribution, Employee A endorses the
check received from IRA P as payable to Plan M.
(ii) In addition to providing the certifications de-
scribed in Example 3 with respect to the distribution
from Plan O, Employee A certifies that, to the best
of Employee A’s knowledge, the contribution to IRA
P was not made more than 60 days after the date
Employee A received the distribution from Plan O,
no amount other than the distribution from Plan O
has been contributed to IRA P, and the distribution
from IRA P was received not more than 60 days ear-
lier than the rollover contribution to Plan M.
(iii) As support for these certifications, in addi-
tion to the two statements from Plan O described in
Example 3, Employee A provides copies of state-
ments from IRA P. The statements indicate that the
account is identified as an IRA, the account was es-
tablished within 60 days of the date of the letter
from Plan O informing Employee A that an amount
had been distributed, and the opening balance in the
IRA does not exceed the amount of the distribution
described in the letter from Plan O. There is no indi-
cation in the statements that any additional contribu-
tions have been made to IRA P since the account
was opened. The date on the check from IRA P is
less than 60 days before the date that Employee A
makes the contribution to Plan M.
(iv) Based on the certifications and documenta-
tion provided by Employee A, absent facts to the
contrary, a plan administrator may reasonably con-
clude that Plan O is qualified and that the contribu-
tion by Employee A is a rollover contribution de-
scribed in section 408(d)(3)(A)(ii) that satisfies the
other requirements of section 408(d)(3) for treat-
ment as a rollover contribution.
* * * * *
Par. 3. Section 1.402(c)–2 is amended
as follows:
1. Section 1.402(c)–2 is amended by
adding a sentence to the end of A-11.
2. Under the heading “List of Questions,”
removing the language “§1.401(a)(31)–1,
Q&A-17” in Q-15 and adding
“§1.401(a)(31)–1, Q&A-18” in its place.
3. Under the heading “Questions and
Answers,” removing the language
“§1.401(a)(31)–1, Q&A-15” in the third
sentence of A-9(a) and adding
“§1.401(a)(31)–1, Q&A-16” in its place.
4. Under the heading “Questions and
Answers,” removing the language
“§1.401(a)(31)–1, Q&A-15” in the intro-
ductory text of A-9(c) and adding
2000–20 I.R.B.1005May 15, 2000

“§1.401(a)(31)–1, Q&A-16” in its place.
5. Under the heading “Questions and
Answers,” removing the language
“§1.401(a)(31)–1, Q&A-15” in the last
sentence of Example 1(b) of A-9(c) and
adding “§1.401(a)(31)–1, Q&A-16” in its
place.
6. Under the heading “Questions and
Answers,” removing the language
“§1.401(a)(31)–1, Q&A-16” in the last
sentence of A-10(b) and adding
“§1.401(a)(31)–1, Q&A-17” in its place.
7. Under the heading “Questions and
Answers,” removing the language
“§1.401(a)(31)–1, Q&A-17” in the last
sentence of A-14 and adding
“§1.401(a)(31)–1, Q&A-18” in its place.
8. Under the heading “Questions and
Answers,” removing the language
“§1.401(a)(31)–1, Q&A-17” in Q-15 and
adding “§1.401(a)(31)–1, Q&A-18” in its
place.
9. Under the heading “Questions and
Answers,” removing the language
“§1.401(a)(31)–1, Q&A-17” in the third
sentence of A-15 and adding
“§1.401(a)(31)–1, Q&A-18” in its place.
The addition reads as follows:
§1.402(c)–2 Eligible rollover distribu-
tions; questions and answers.
* * * * *
A-11. * * * See §1.401(a)(31)–1,
Q&A-14, for guidance concerning the
qualification of a plan that accepts a
rollover contribution.
* * * * *
§1.403(b)–2 [Amended]
Par. 4. Section 1.403(b)–2 is amended
as follows:
1. Under the heading “Questions and
Answers,” removing the language
“§1.401(a)(31)–1, Q&A-14” in the next
to last sentence of A-2(a) and adding
“§1.401(a)(31)–1, Q&A-15” in its place.
2. Under the heading “Questions and
Answers,” removing the language
“§1.401(a)(31)–1, Q&A-18” in the sec-
ond sentence of A-4(a)(1) and adding
“§1.401(a)(31)–1, Q&A-19” in its place.
PART 31—EMPLOYMENT TAXES
AND COLLECTION OF INCOME TAX
AT SOURCE
Par. 5. The authority citation for part
31 continues to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
§31.3405(c)–1 [Amended]
Par. 6. Section 31.3405(c)–1 is
amended as follows:
1. Under the heading “Questions and
Answers,” removing the language “Q&A-
17 of §1.401(a)(31)–1” in the next to last
sentence of A-10(a) and adding “Section
1.401(a)(31)–1, Q&A-18” in its place.
2. Under the heading “Questions and
Answers,” removing the language
“§1.401(a)(31)–1, Q&A-16” in the third
sentence of A-13 and adding
“§1.401(a)(31)–1, Q&A-17” in its place.
Robert E. Wenzel,
Deputy Commissioner of
Internal Revenue.
Approved April 16, 2000.
Jonathan Talisman,
Acting Assistant Secretary of
the Treasury (Tax Policy).
(Filed by the Office of the Federal Register on April
20, 2000, 8:45 a.m., and published in the issue of the
Federal Register for April 21, 2000, 65 F.R. 21312)
Section 446.—General Rule for
Methods of Accounting
26 CFR 1.446–1: General rule for methods of
accounting.
Will the Commissioner exercise his discretion to
except a qualifying taxpayer with average annual
gross receipts of $1,000,000 or less from the re-
quirements to account for inventories and to use an
accrual method of accounting for purchases and
sales of merchandise. See Rev. Proc. 2000–22, page
1008.
Section 471.—General Rule for
Inventories
26 CFR 1.471–1: Need for inventories.
Will the Commissioner exercise his discretion to
except a qualifying taxpayer with average annual
gross receipts of $1,000,000 or less from the re-
quirements to account for inventories and to use an
accrual method of accounting for purchases and
sales of merchandise. See Rev. Proc. 2000–22, page
1008.
Section 472.—Last-in, First-out
Inventories
26 CFR 1.472–1: Last-in, first-out inventories.
LIFO; price indexes; department
stores.The March 2000 Bureau of Labor
Statistics price indexes are accepted for
use by department stores employing the
retail inventory and last-in, first-out in-
ventory methods for valuing inventories
for tax years ended on, or with reference
to, March 31, 2000.
Rev. Rul. 2000–25
The following Department Store Inven-
tory Price Indexes for March 2000 were
issued by the Bureau of Labor Statistics.
The indexes are accepted by the Internal
Revenue Service, under
§ 1.472–1(k) of the Income Tax Regu-
lations and Rev. Proc. 86–46, 1986–2
C.B. 739, for appropriate application to
inventories of department stores employ-
ing the retail inventory and last-in, first-
out inventory methods for tax years ended
on, or with reference to, March 31, 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.
May 15, 200010062000–20 I.R.B.

BUREAU OF LABOR STATISTICS, DEPARTMENT STORE
INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS
(January 1941 = 100, unless otherwise noted)
Percent Change
GroupsMar.Mar.from Mar. 1999
19992000to Mar. 2000
1
1. Piece Goods - - - - - - - - - - - - - - - - - - - - -555.8511.5-8.0
2. Domestics and Draperies - - - - - - - - - - - - -619.9614.4-0.9
3. Women’s and Children’s Shoes - - - - - - - -651.0638.9-1.9
4. Men’s Shoes - - - - - - - - - - - - - - - - - - - - -887.6902.41.7
5. Infants’ Wear - - - - - - - - - - - - - - - - - - - - -617.2649.85.3
6. Women’s Underwear - - - - - - - - - - - - - - -577.4582.70.9
7. Women’s Hosiery - - - - - - - - - - - - - - - - - -321.4337.5 5.0
8. Women’s and Girls’ Accessories - - - - - - - -557.4548.1-1.7
9. Women’s Outerwear and Girls’ Wear - - - - -408.4409.50.3
10. Men’s Clothing - - - - - - - - - - - - - - - - - - -623.1626.20.5
11. Men’s Furnishings - - - - - - - - - - - - - - - - -611.1623.22.0
12. Boys’ Clothing and Furnishings - - - - - - - -488.6498.1 1.9
13. Jewelry - - - - - - - - - - - - - - - - - - - - - - - -977.8965.3-1.3
14. Notions - - - - - - - - - - - - - - - - - - - - - - - -785.7746.6-5.0
15. Toilet Articles and Drugs - - - - - - - - - - - - -957.3968.01.1
16. Furniture and Bedding - - - - - - - - - - - - - -690.9693.10.3
17. Floor Coverings - - - - - - - - - - - - - - - - - - -602.4606.80.7
18. Housewares - - - - - - - - - - - - - - - - - - - - -803.5787.4-2.0
19. Major Appliances - - - - - - - - - - - - - - - - - -233.9235.70.8
20. Radio and Television - - - - - - - - - - - - - - -67.961.0 -10.2
21. Recreation and Education
2
- - - - - - - - - - -99.994.8-5.1
22. Home Improvements
2
- - - - - - - - - - - - - - -128.5128.0-0.4
23. Auto Accessories
2
- - - - - - - - - - - - - - - - -107.4107.60.2
Groups 1 - 15: Soft Goods - - - - - - - - - - - - - -603.6606.30.4
Groups 16 - 20: Durable Goods - - - - - - - - - - -454.6444.3-2.3
Groups 21 - 23: Misc. Goods
2
- - - - - - - - - - - -105.1101.7-3.2
Store Total
3
- - - - - - - - - - - - - - - - - - - - -548.5545.5-0.5
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.
2000–20 I.R.B.1007May 15, 2000
DRAFTING INFORMATION
The principal author of this revenue
ruling is Alan J. Tomsic of the Office of
Assistant Chief Counsel (Income Tax and
Accounting). For further information re-
garding this revenue ruling, contact Mr.
Tomsic on (202) 622-4970 (not a toll-free
call).
Section 481.—Adjustments
Required by Changes in Method
of Accounting
26 CFR 1.481–4: Adjustments taken into account
with consent.
Will the Commissioner exercise his discretion to
except a qualifying taxpayer with average annual
gross receipts of $1,000,000 or less from the re-
quirements to account for inventories and to use an
accrual method of accounting for purchases and
sales of merchandise. See Rev. Proc. 2000–22, page
1008.

26 CFR 601.204: Changes in accounting periods and
in methods of accounting.
(Also Part 1 , §§ 162, 263A, 446, 471, 481; 1.162–3,
1.263A–1, 1.446–1, 1.471–1, 1.481–1, 1.481–4.)
Rev. Proc. 2000–22
SECTION 1. PURPOSE
This revenue procedure provides that the
Commissioner of Internal Revenue will ex-
ercise his discretion to except a qualifying
taxpayer with average annual gross receipts
of $1,000,000 or less from the requirements
to account for inventories and to use an ac-
crual method of accounting for purchases
and sales of merchandise. This revenue
procedure also provides the procedures by
which a qualifying taxpayer may obtain au-
tomatic consent to change to the cash re-
ceipts and disbursements method of ac-
counting (the cash method).
SECTION 2. BACKGROUND
.01 Section 446(c) of the Internal Rev-
enue Code generally allows a taxpayer to
select the method of accounting it will use
to compute its taxable income. A tax-
payer is entitled to adopt any one of the
permissible methods for each separate
trade or business, subject to certain re-
strictions. For example, § 446(b) pro-
vides that the selected method must
clearly reflect income. In addition,
§ 1.446–1(c)(2)(i) of the Income Tax Reg-
ulations requires that a taxpayer use an
accrual method of accounting with regard
to purchases and sales of merchandise
whenever § 471 requires the taxpayer to
account for inventories, unless otherwise
authorized by the Commissioner under
§ 1.446–1(c)(2)(ii). Under § 1.446–
1(c)(2)(ii), the Commissioner has the au-
thority to permit a taxpayer to use a
method of accounting that clearly reflects
income even though the method is not
specifically authorized by the regulations.
.02 Section 471 provides that when-
ever, in the opinion of the Secretary, the
use of inventories is necessary to clearly
determine the income of the taxpayer, in-
ventories must be taken by the taxpayer.
Section 1.471–1 requires a taxpayer to ac-
count for inventories when the produc-
tion, purchase, or sale of merchandise is
an income-producing factor in the tax-
payer’s business.
.03 Section 1.162–3 requires taxpayers
carrying materials and supplies (other
than incidental materials and supplies) on
hand to deduct the cost of materials and
supplies only in the amount that they are
actually consumed and used in operations
during the tax year.
.04 Section 263A generally requires
direct costs and an allocable portion of in-
direct costs of certain personal property
produced or acquired for resale by a tax-
payer to be included in inventory costs, in
the case of property that is inventory, or to
be capitalized, in the case of other prop-
erty. However, resellers with gross re-
ceipts of $10,000,000 or less and produc-
ers with $200,000 or less of indirect costs
are not required to capitalize costs under
§ 263A. See § 263A(b)(2)(B) and
§ 1.263A– 2(b)(3)(iv).
.05 Section 446(e) and § 1.446–1(e)
state that, except as otherwise provided, a
taxpayer must secure the consent of the
Commissioner before changing a method
of accounting for federal income tax pur-
poses. Section 1.446–1(e)(3)(ii) autho-
rizes the Commissioner to prescribe ad-
ministrative procedures setting forth the
limitations, terms, and conditions deemed
necessary to permit a taxpayer to obtain
consent to change a method of accounting
in accordance with § 446(e).
.06 Section 481(a) requires those ad-
justments necessary to prevent amounts
from being duplicated or omitted to be
taken into account when the taxpayer’s
taxable income is computed under a
method of accounting different from the
method used to compute taxable income
for the preceding tax year.
SECTION 3. SCOPE
This revenue procedure applies to a
taxpayer with “average annual gross re-
ceipts” of $1,000,000 or less (as defined
in section 5.01 of this revenue procedure)
that satisfies the “conformity” require-
ment (as described in section 5.07 of this
revenue procedure).
SECTION 4. SMALL TAXPAYER
EXCEPTION
Pursuant to the discretion under
§§ 446(b) and 471, and to simplify book-
keeping requirements for small taxpayers,
the Commissioner, as a matter of adminis-
trative convenience, will except taxpayers
described in section 3 of this revenue pro-
cedure from any requirement to account
for inventories under § 471 or to use an
accrual method under § 446. A taxpayer
described in section 3 that does not want
to account for inventories must treat mer-
chandise inventory in the same manner as
a material or supply that is not incidental
under § 1.162–3. Section 263A does not
apply to such merchandise inventory.
SECTION 5. DEFINITIONS
.01 Average annual gross receipts de-
fined. A taxpayer has average annual
gross receipts of $1,000,000 or less if, for
each prior tax year ending on or after De-
cember 17, 1998, the taxpayer’s average
annual gross receipts for the 3-tax-year
period ending with the applicable prior
tax year does not exceed $1,000,000.
.02 Gross receipts defined. Gross re-
ceipts is defined consistent with § 1.448–
1T(f)(2)(iv) of the temporary regulations.
Thus, gross receipts for a tax year equal
all receipts derived from all of the tax-
payer’s trades or businesses that must be
recognized under the method of account-
ing actually used by the taxpayer for that
tax year for federal income tax purposes.
For example, gross receipts include total
sales (net of returns and allowances), all
amounts received from services, interest,
dividends, and rents. However, gross re-
ceipts do not include amounts received by
the taxpayer with respect to sales tax or
other similar state and local taxes if,
under the applicable state or local law, the
tax is legally imposed on the purchaser of
the good or service, and the taxpayer
merely collects and remits the tax to the
taxing authority.
.03 Aggregation of gross receipts. For
purposes of computing gross receipts, all
taxpayers treated as a single employer
under subsection (a) or (b) of § 52 or sub-
section (m) or (o) of § 414 (or that would
be treated as a single employer under these
sections if the taxpayers had employees)
will be treated as a single taxpayer. How-
ever, when transactions occur between tax-
payers that are treated as a single taxpayer
by the previous sentence, gross receipts
arising from these transactions will not be
May 15, 200010082000–20 I.R.B.
Part III. Administrative, Procedural, and Miscellaneous

treated as gross receipts for purposes of the
average annual gross receipts limitation.
See § 1.448–1T(f)(2)(ii).
.04 Taxpayer not in existence for 3 tax
years. If a taxpayer has been in existence
for less than the 3-tax-year period referred
to in section 5.01 of this revenue proce-
dure, the taxpayer must determine its av-
erage annual gross receipts for the num-
ber of years (including short tax years)
that the taxpayer has been in existence.
.05 Treatment of short tax years. In the
case of a short tax year, the taxpayer’s
gross receipts must be annualized by mul-
tiplying the gross receipts of the short tax
year by 12 and then dividing the product
by the number of months in the short tax
year. See § 1.448–1T(f)(2)(iii).
.06 Treatment of predecessors. Any
reference to taxpayer in this section 5 in-
cludes a reference to any predecessor of
such taxpayer.
.07 Conformity. A taxpayer satisfies
the conformity requirement of this rev-
enue procedure if the taxpayer does not
regularly use any method other than the
cash method to ascertain the income,
profit or loss of the trade or business for
purposes of its books and records and re-
ports (including financial statements) to
shareholders, partners, other proprietors,
or beneficiaries and for credit purposes
for the current and prior 3 tax years (ex-
cluding tax years ending before Decem-
ber 17, 2000). A taxpayer that uses the
cash method of accounting for purposes
of its books and records and reports but,
on an isolated basis, prepares financial re-
ports using an accrual method (for exam-
ple, on a one-time basis to obtain a bank
loan) will not be considered to violate the
conformity requirement.
.08 Example. Taxpayer A, a calendar
year taxpayer, manufactures and sells
widgets. For federal income tax pur-
poses, Taxpayer A uses an overall accrual
method of accounting. Further, Taxpayer
A complies with the requirements of
§ 1.471–1 to use inventory accounts and
§ 263A to capitalize direct and indirect
costs.
Taxpayer A has gross receipts (as de-
fined in section 5.02 of this revenue pro-
cedure) of $200,000 in 1996, $800,000 in
1997 and $1,100,000 in 1998.
To determine whether it qualifies for
the small taxpayer exception set forth in
section 4 of this revenue procedure begin-
ning with the 1999 tax year, Taxpayer A
computes its average annual gross re-
ceipts each prior tax year ending on or
after December 17, 1998, that is, its 1998
tax year. Taxpayer A’s average annual
gross receipts for 1998 is $700,000
($200,000 (1996) + $800,000 (1997) +
$1,100,000 (1998) = $2,100,000/3).
Taxpayer A’s average annual gross re-
ceipts for each prior tax year ending after
December 17, 1998, does not exceed
$1,000,000. Therefore, Taxpayer A quali-
fies for the small taxpayer exception for
its 1999 tax year. By following the proce-
dures set forth in section 6.02 of this rev-
enue procedure, Taxpayer A may change
to the cash method and a method of treat-
ing merchandise inventory in the same
manner as a material or supply that is not
incidental under § 1.162–3 for the tax
year ending December 31, 1999.
Taxpayer A must determine its applica-
bility for the small taxpayer exception set
forth in section 4 of this revenue proce-
dure each year. Thus, to qualify for the
exception for its 2000 tax year, Taxpayer
A’s average annual gross receipts for 1999
(that is, the average of A’s gross receipts
for 1999, 1998, and 1997) also must be
$1,000,000 or less and Taxpayer A must
meet the conformity requirement of sec-
tion 5.07 of this revenue procedure. If, in
any later year, Taxpayer A ceases to qual-
ify for the small taxpayer exception set
forth in section 4 of this revenue proce-
dure, it must change to an inventory
method and an accrual method with re-
spect to purchases and sales of merchan-
dise in accordance with section 6.03 of
this revenue procedure.
SECTION 6. CHANGE IN
ACCOUNTING METHOD
.01 In general. Any change in a tax-
payer’s method of accounting pursuant to
this revenue procedure is a change in
method of accounting to which the provi-
sions of §§ 446 and 481 and the regula-
tions thereunder apply.
.02 Automatic change for taxpayers
within the scope of this revenue proce-
dure.
(1) Automatic change to the cash
method. A taxpayer that qualifies for the
small taxpayer exception described in
section 4 of this revenue procedure that
wants to change to the cash method must
follow the automatic change in account-
ing method provisions of Rev. Proc.
99–49, 1999–52 I.R.B. 725 (or its succes-
sor) with the following modifications:
(a) The scope limitations in sec-
tion 4.02 of Rev. Proc. 99–49 do not
apply. However, if the taxpayer is under
examination, before an appeals office, or
before a federal court with respect to any
income tax issue, the taxpayer must pro-
vide a copy of the Form 3115, Application
for Change in Accounting Method, to the
examining agent(s), appeals officer, or
counsel for the government, as appropri-
ate, at the same time that it files the copy
of the Form 3115 with the national office.
The Form 3115 must contain the name(s)
and telephone number(s) of the examin-
ing agent(s), appeals officer, or counsel
for the government, as appropriate.
(b) A taxpayer making a change
under section 6.02 of this revenue proce-
dure for its first tax year ending on or after
December 17, 1999, that, on or before July
14, 2000, files its original federal income
tax return for such year, is not subject to
the filing requirement in section 6.02(2)(a)
of Rev. Proc. 99–49, provided the tax-
payer complies with the following filing
requirement. The taxpayer must complete
and file a Form 3115 in duplicate. The
original must be attached to the taxpayer’s
amended federal income tax return for the
taxpayer’s first tax year ending on or after
December 17, 1999. This amended return
must be filed no later than November 13,
2000. A copy of the Form 3115 must be
filed with the national office (see section
6.02(5) of Rev. Proc. 99–49 for the ad-
dress) no later than when the taxpayer’s
amended return is filed.
(c) For a change in method of ac-
counting within the scope of this revenue
procedure, the provisions of Rev. Proc.
99–49 are effective for tax years ending
on or after December 17, 1999.
(d) Taxpayers filing Form 3115
for a change in method of accounting
under section 6.02 of this revenue proce-
dure are reminded to complete all applica-
ble parts of the form, including Part II,
line 17 (regarding information on gross
receipts in previous years) and Part III
(regarding the § 481 adjustment). Such
taxpayers must also complete Part I of
Schedule A of Form 3115, but need not
complete Part II. Taxpayers should write
“Filed under Rev. Proc. 2000–22” at the
top of the form.
2000–20 I.R.B.1009May 15, 2000

(2) Change to comply with
§ 1.162–3. A taxpayer that qualifies for
the small taxpayer exception described in
section 4 of this revenue procedure that
does not want to account for inventories
must make any necessary change from the
taxpayer’s inventory method (and, if ap-
plicable, from the method of capitalizing
costs under § 263A) to treat merchandise
inventory in the same manner as a mater-
ial or supply that is not incidental under
§ 1.162–3. For purposes of such a
change, the rules of section 6.02(1) of this
revenue procedure apply. Taxpayers may
file a single Form 3115 for both changes
described in sections 6.02(1) and (2).
.03 Taxpayers not within the scope of
this revenue procedure. A taxpayer that
ceases to qualify for the small taxpayer ex-
ception described in section 4 of this rev-
enue procedure and otherwise is required to
account for inventories must change to an
inventory method that complies with
§§ 263A and 471 and an accrual method
with respect to purchases and sales of mer-
chandise using either the automatic change
in accounting method provisions of section
5.01 of the APPENDIX to Rev. Proc.
99–49, if applicable, or the advance con-
sent provisions of Rev. Proc. 97–27,
1997–1 C.B. 680 (or its successor).
SECTION 7. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 99–49 is modified and am-
plified to include this automatic change in
section 5 of the APPENDIX.
SECTION 8. EFFECTIVE DATE
This revenue procedure is effective for
tax years ending on or after December 17,
1999. However, the Service will not chal-
lenge a taxpayer’s use of the cash method
under § 446 (and a taxpayer’s failure to
account for inventories under § 471) in an
earlier year if the taxpayer consistently
used the cash method (and consistently
did not account for inventories) and
would satisfy the 3-tax-year-period gross
receipts test of section 5.01 of this rev-
enue procedure (applied by testing the 3-
tax-year period ending prior to such ear-
lier year), and the conformity requirement
of section 5.07 (applied by testing the ear-
lier year and the 3 tax years prior to such
earlier year).
DRAFTING INFORMATION
The principal author of this revenue
procedure is Cheryl Lynn Oseekey of the
Office of Assistant Chief Counsel (In-
come Tax and Accounting). For further
information regarding this revenue proce-
dure, contact Ms. Oseekey on (202) 622-
4970 (not a toll-free call).
May 15, 200010102000–20 I.R.B.

2000–20 I.R.B.1011May 15, 2000
Announcement of the Disbarment and Suspension of Attorneys,
Certified Public Accountants, Enrolled Agents, and Enrolled Actuaries
From Practice Before the Internal Revenue Service
Part IV. Items of General Interest
Under Section 330, Title 31 of the
United States Code, the Secretary of the
Treasury, after due notice and opportunity
for hearing, is authorized to suspend or
disbar from practice before the Internal
Revenue Service any person who has vio-
lated the rules and regulations governing
the recognition of attorneys, certified
public accountants, enrolled agents or en-
rolled actuaries to practice before the In-
ternal Revenue Service.
Attorneys, certified public accountants,
enrolled agents, and enrolled actuaries are
prohibited in any Internal Revenue Service
matter from directly or indirectly employing,
accepting assistance from, being employed
by or sharing fees with, any practitioner dis-
barred or under suspension from practice be-
fore the Internal Revenue Service.
To enable attorneys, certified public ac-
countants, enrolled agents and enrolled
actuaries to identify such disbarred or sus-
pended practitioners, the Director of Prac-
tice will announce in the Internal Revenue
Bulletin the names and addresses of prac-
titioners who have been suspended from
such practice, their designation as attor-
ney, certified public accountant, enrolled
agent or enrolled actuary, and the date of
disbarment or period of suspension. This
announcement will appear in the weekly
Bulletin for five successive weeks or as
long as it is practicable for each attorney,
certified public accountant, enrolled agent
or enrolled actuary so suspended or dis-
barred and will be consolidated and pub-
lished in the Cumulative Bulletin.
After due notice and opportunity for
hearing before an administrative law
judge, the following individuals has been
disbarred from ffifther practice before the
Internal Revenue Service:
NameAddressDesignationEffective Date
Kolesar, GaryN. Patchogue, NYCPAOctober 27, 1999
Announcement of the Consent Voluntary Suspension of Attorneys,
Certified Public Accountants, Enrolled Agents, and Enrolled Actuaries
From Practice Before the Internal Revenue Service
Under 31 Code of Federal Regulations,
Part 10, an attorney, certified public ac-
countant, enrolled agent or enrolled actu-
ary, in order to avoid the institution or
conclusion of a proceeding for his disbar-
ment or suspension from practice before
the Internal Revenue Service, may offer
his consent to suspension from such prac-
tice. The Director of Practice, in his dis-
cretion, may suspend an attorney, certi-
fied public accountant, enrolled agent or
enrolled actuary in accordance with the
consent offered.
Attorneys, certified public accountants,
enrolled agents and enrolled actuaries are
prohibited in any Internal Revenue Service
matter from directly or indirectly employ-
ing, accepting assistance from, being em-
ployed by or sharing fees with, any practi-
tioner disbarred or suspended from practice
before the Internal Revenue Service.
To enable attorneys, certified public ac-
countants, enrolled agents and enrolled ac-
tuaries to identify practitioners under con-
sent suspension from practice before the
Internal Revenue Service, the Director of
Practice will announce in the Internal Rev-
enue Bulletin the names and addresses of
practitioners who have been suspended
from such practice, their designation as at-
torney, certified public accountant, enrolled
agent or enrolled actuary, and date or pe-
riod of suspension. This announcement will
appear in the weekly Bulletin at the earliest
practicable date after such action and will
continue to appear in the weekly Bulletins
for five successive weeks or for as many
weeks as is practicable for each attorney,
certified public accountant, enrolled agent
or enrolled actuary so suspended and will
be consolidated and published in the Cu-
mulative Bulletin.
The following individuals have been
placed under consent suspension from prac-
tice before the Internal Revenue Service:
Date of
NameAddressDesignationSuspension
Quann, WarrenElk Grove, CAAttorneyIndefinite
from
March 1, 1999
Helms, W. RichardWestern Springs, ILAttorneyMarch 1, 1999
to
August 31, 2002

May 15, 200010122000–20 I.R.B.
Dillahunty, Larry L.St. Petersburg, FLAttorneyMarch 1, 1999
to
February 28, 2003
Friesen, AlanLincoln, NECPAMarch 8, 1999
to
July 7, 2002
Cummins, Richard L.Torrance, CACPAMarch 20, 1999
to
March 19, 2002
Potter, Thomas C.Oneonta, NYCPAApril 16, 1999
to
October 15, 2000
Jenkins, GordonIdaho Falls, IDAttorneyMay 1, 1999
to
October 31, 2002
Blair Jr., John D.Charleston, WVCPAJune 1, 1999
to
May 31, 2002
Caudle, LarryAnchorage, AKAttorneyJune 21, 1999
to
December 31, 2001
Schorr, HarveyVoorheese, NJCPAJuly 1, 1999
to
December 31, 2001
Fernandez, Michael J. Camillus, NYCPAJuly 7, 1999
to
July 6, 2000
Polking, William G.Carol, IAAttorneySeptember 27, 1999
to
September 26, 2000
Luxen, Robert J.Oak Lawn, ILCPAOctober 1, 1999
to
June 30, 2001
Underwood, KennethChattanooga, TNCPAOctober 14, 1999
to
April 13, 2001
Vancho, JohnGreenwich, CTCPANovember 1, 1999
to
October 31, 2001
Enkulenko, ThomasMoscow, PACPANovember 15, 1999
to
November 14, 2000
Moody, James E.Pittsburgh, PACPADecember 1, 1999
to
November 30, 2000
Patterson, Robert A. Marietta, GACPADecember 13, 1999
to
December 12, 2002
Hanson, Raymond L. Boise, IDCPAJanuary 1, 2000
to
December 31, 2001
Wallach, StevenNorth Brook, ILCPAFebruary 25, 2000
to
February 24, 2002

Watkins Sr., RichardWashington, MOCPAMarch 15, 2000
to
September 14, 2002
Peltin, RonaldEscanaba, MIEnrolledMarch 15, 2000
Agentto
March 14, 2003
Arwood, B. JoeChuckey, TNCPAMarch 20, 2000
to
June 19, 2001
Gazzola, Frank L.N. Mankato, MNCPAMay 1, 2000
to
October 31, 2002
O’Hearn, JamesBakersfield, CAEnrolledJune 1, 2000
Agentto
May 31, 2002
Dooner Jr., WilliamToms River, NJEnrolledJune 1, 2000
Agentto
August 31, 2000
2000–20 I.R.B.1013May 15, 2000
Announcement of the Expedited Suspension of Attorneys, Certified
Public Accountants, Enrolled Agents, and Enrolled Actuaries From
Practice Before the Internal Revenue Service
Under title 31 of the Code of Federal
Regulations, section 10.76, the Director
of Practice is authorized to immediately
suspend from practice before the Internal
Revenue Service any practitioner who,
within five years, from the date the expe-
dited proceeding is instituted, (1) has had
a license to practice as an attorney, certi-
fied public accountant, or actuary sus-
pended or revoked for cause; or (2) has
been convicted of any crime under title 26
of the United States Code or, of a felony
under title 18 of the United States Code
involving dishonesty or breach of trust.
Attorneys, certified public accountants,
enrolled agents, and enrolled actuaries are
prohibited in any Internal Revenue Service
matter from directly or indirectly employ-
ing, accepting assistance from, being em-
ployed by, or sharing fees with, any practi-
tioner disbarred or suspended from practice
before the Internal Revenue Service.
To enable attorneys, certified pubic ac-
countants, enrolled agents, and enrolled ac-
tuaries to identify practitioners under expe-
dited suspension from practice before the
Internal Revenue Service, the Director of
Practice will announce in the Internal Rev-
enue Bulletin the names and addresses of
practitioners who have been suspended
from such practice, their designation as at-
torney, certified public accountant, enrolled
agent, or enrolled actuary, and date or pe-
riod of suspension. This announcement will
appear in the weekly Bulletin at the earliest
practicable date after such action and will
continue to appear in the weekly Bulletins
for five successive weeks or for as many
weeks as is practicable for each attorney,
certified public accountant, enrolled agent,
or enrolled actuary so suspended and will
be consolidated and published in the Cu-
mulative Bulletin.
The following individuals have been
placed under suspension from practice be-
fore the Internal Revenue Service by
virtue of the expedited proceeding provi-
sions of the applicable regulations:
Date of
NameAddressDesignationSuspension
Moeller, David G.Golden Valley, MNAttorneyIndefinite
from
March 8, 1999
Dais, Robert E.Plano, TXCPAIndefinite
from
March 15, 1999
Taylor, Donald J.Sequim, WACPAIndefinite
from
March 15, 1999
Thurson, Terrance N.Jacksonville, FLCPAIndefinite
from
March 15, 1999

Hartman, RichardMerrick, NYAttorneyIndefinite
from
March 15, 1999
Mandel, Stewart I.Univ. Heigths, OHAttorneyIndefinite
from
March 15, 1999
Gowin, Dennis L.Falls Church, VACPAIndefinite
from
March 15, 1999
Kelly, RichardLloyd Harbor, NYAttorneyIndefinite
from
March 16, 1999
Nagel, Maxine M.Renton, WACPAIndefinite
from
March 16, 1999
Cox, James L.Bedford, TXCPAIndefinite
from
March 23, 1999
Shields, Morris R.Omaha, NECPAIndefinite
from
March 23, 1999
Stradone, Mark A.San Antonio, TXCPAIndefinite
from
March 24, 1999
Anderson, David J.Minnetonka, MNCPAIndefinite
from
March 28, 1999
Budenz, Lawrence J.Miamisburg, OHCPAIndefinite
from
March 28, 1999
Hogan, Kelly M.Ogallala, NEAttorneyIndefinite
from
March 28, 1999
Fernez, Daniel J.Monroe, CTCPAIndefinite
from
March 28, 1999
Fitsos, JohnSacramento, CAAttorneyIndefinite
from
March 28, 1999
Schweitzer, Clifford A.Aberdeen, SDCPAIndefinite
from
April 2, 1999
Magdalena, Lynn JosephMcAlester, OKCPAIndefinite
from
April 2, 1999
Parrott, GeorgeNashville, TNCPAIndefinite
from
April 2, 1999
Elder Jr., Wilton K.Burlington, NCAttorneyIndefinite
from
May 6, 1999
Passero, RobertSeal Beach, CACPAIndefinite
from
July 8, 1999
May 15, 200010142000–20 I.R.B.

Stringham, RichardColumbia, MOCPAIndefinite
from
July 8, 1999
Koseluk, Alexander F.Omaha, NEAttorneyIndefinite
from
July 19, 1999
Dotson, Marshall F.Jacksonville, NCAttorneyIndefinite
from
July 27, 1999
Schaffer, Clark D.Atlantic Beach, FLCPAIndefinite
from
July 27, 1999
Zimmerman, RobertAlpharetta, GACPAIndefinite
from
January 17, 2000
2000–20 I.R.B.1015May 15, 2000

May 15, 2000i2000–20 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 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

2000–20 I.R.B.iiMay 15, 2000
Numerical Finding List
1
Bulletins 2000–1 through 2000–19
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, 2000–19 I.R.B. 998
2000–49, 2000–19 I.R.B. 998
2000–50, 2000–19 I.R.B. 998
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
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
Notices—continued:
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
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–109101–98, 2000–16 I.R.B. 903
REG–110311–98, 2000–11 I.R.B. 767
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
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
Revenue Procedures—continued:
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
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
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
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
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.

May 15, 2000iii2000–20 I.R.B.
Finding List of Current Actions on
Previously Published Items
1
Bulletins 2000–1 through 2000–19
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
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
98–52
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–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
Revenue Procedures—Continued:
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
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
Revenue Procedures—Continued:
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
Rev. Proc. 2000–21, 2000–19 I.R.B. 971
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
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:
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
78–218
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
86–62
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
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.

2000–20 I.R.B.ivMay 15, 2000
Revenue Rulings—continued:
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
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

insert
missing
children
here
Meriah
Widboom
May 15, 20002000–20 I.R.B.

insert
missing
children
here
Brianna
Warnes
2000–20 I.R.B.May 15, 2000

insert
missing
children
here
Lucy
Meadows
May 15, 20002000–20 I.R.B.

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