us-irs-revenue-procedures-irb-2000-26-pdf•Internal Revenue Bulletin 2000-26 (PDF rendition): IRS Revenue Procedures
Internal Revenue Bulletin 2000-26 (PDF rendition): IRS Revenue Procedures
us-irs-revenue-procedures-irb-2000-26-pdfInternal Revenue Bulletin 2000-26 (PDF rendition): IRS Revenue ProceduresGuidance
Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.
INCOME TAX Rev. Rul. 2000–31, page 1269. Low-income housing credit; satisfactory bond; “bond factor” amounts for the period April through June 2000.This ruling announces the monthly bond factor amounts to be used by taxpayers who dispose of qualified low-income buildings or interests therein during the period April through June 2000. EMPLOYEE PLANS Rev. Proc. 2000–27, page 1272. Qualified plans; determination letters; remedial amendment period.This procedure opens the determina- tion letter program to allow sponsors of qualified plans within the meaning of section 401(a) or 403(a) of the Code to request determination letters from the Service that take into account all changes in the plan qualification require- ments made by the Small Business Job Protection Act of 1996 and other recent legislation. It also extends the reme- dial period under section 401(b) of the Code for amending plans for these changes, as well as the remedial amendment period for amending governmental and nonelecting church plans for the Tax Reform Act of 1986. Rev. Procs. 98–14, 99–23, 2000–6, and 2000–20 modified. Notice 2000–31, page 1274. Weighted average interest rate update.The weighted average interest rate for June 2000 and the resulting per- missible range of interest rates used to calculate current lia- bility for purposes of the full funding limitation of section 412(c)(7) of the Code are set forth. Notice 2000–32, page 1274. Rollovers; hardship distributions.This notice provides re- lief relating to the exception to the definition of eligible rollover distribution for hardship distributions, as provided by sections 402(c)(4)(C) and 403(b)(8)(B) of the Code. No- tice 99–5 modified. EXEMPT ORGANIZATIONS Announcement 2000–56, page 1281. A list is provided of organizations that no longer qualify as organizations to which contributions are deductible under section 170 of the Code. EXCISE TAX T.D. 8887, page 1269. Final regulations under section 6302 of the Code relate to deposits of excise tax. Notice 97–15 obsoleted. ADMINISTRATIVE Announcement 2000–54, page 1276. The Service is requesting comments from the public on pro- posed revisions to Form 1042–S, Foreign Person’s U.S. Source Income Subject to Withholding. Internal Revenue bbuulllleettiinn Bulletin No. 2000–26 June 26, 2000 HIGHLIGHTS OF THIS ISSUE These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations. Department of the Treasury Internal Revenue Service Finding Lists begin on page ii. Announcement of Declaratory Judgment Proceedings Under Section 7428 begins on page 1281. June 26, 20002000–26 I.R.B. The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing offi- cial rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It is published weekly and may be obtained from the Superintendent of Documents on a subscription basis. Bulletin contents are consolidated semiannually into Cumulative Bulletins, which are sold on a single-copy basis. It is the policy of the Service to publish in the Bulletin all sub- stantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless other- wise indicated. Procedures relating solely to matters of in- ternal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published. Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements. Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying pub- lished rulings and procedures, the effect of subsequent leg- islation, regulations, court decisions, rulings, and proce- dures must be considered, and Service personnel and oth- ers concerned are cautioned against reaching the same con- clusions in other cases unless the facts and circumstances are substantially the same. The Bulletin is divided into four parts as follows: Part I.—1986 Code. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1986. Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions, and Subpart B, Legislation and Related Committee Reports. Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Sub- parts. Also included in this part are Bank Secrecy Act Admin- istrative Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement). Part IV.—Items of General Interest. This part includes notices of proposed rulemakings, disbar- ment and suspension lists, and announcements. The first Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the first Bulletin of the succeeding semi- annual period, respectively. The IRS Mission Provide America’s taxpayers top quality service by help- ing them understand and meet their tax responsibilities and by applying the tax law with integrity and fairness to all. Introduction The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate. For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402. Section 42.—Low-Income Housing Credit Low-income housing credit; satisfac- tory bond; “bond factor” amounts for the period April through June 2000. This ruling announces the monthly bond factor amounts to be used by taxpayers who dispose of qualified low-income buildings or interests therein during the period April through June 2000. Rev. Rul. 2000–31 In Rev. Rul. 90–60, 1990–2 C.B. 3, the Internal Revenue Service provided guid- ance to taxpayers concerning the general methodology used by the Treasury De- partment in computing the bond factor amounts used in calculating the amount of bond considered satisfactory by the Sec- retary under § 42(j)(6) of the Internal Revenue Code. It further announced that the Secretary would publish in the Inter- nal Revenue Bulletin a table of “bond fac- tor” amounts for dispositions occurring during each calendar month. This revenue ruling provides in Table 1 the bond factor amounts for calculating the amount of bond considered satisfac- tory under § 42(j)(6) for dispositions of qualified low-income buildings or inter- ests therein during the period April through June 2000. 2000–26 I.R.B.1269June 26, 2000 Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 Table 1 Rev. Rul. 2000–31 Monthly Bond Factor Amounts for Dispositions Expressed As a Percentage of Total Credits Calendar Year Building Placed in Service or, if Section 42(f)(1) Election Was Made, the Succeeding Calendar Year Month of 198719881989 19901991199219931994199519961997199819992000 Disposition Apr ’00 31.27 46.78 62.87 79.5082.43 86.7291.1895.67 100.29 105.28 110.55 116.23 121.62 124.35 May ’0031.27 46.78 62.87 79.5082.19 86.4690.9095.3699.96 104.93 110.16 115.80 121.15 124.35 Jun ’0031.27 46.78 62.87 79.5081.95 86.2190.6395.0799.65 104.59 109.80 115.41 120.73 124.35 For a list of bond factor amounts applic- able to dispositions occurring during other calendar years, see the following revenue rulings: Rev. Rul. 98–3, 1998–1 C.B. 248, for dispositions occurring during the cal- endar years 1996 and 1997; Rev. Rul. 98–13, 1998–1 C.B. 686, for dispositions occurring during the period January through March 1998; Rev. Rul. 98–31, 1998–1 C.B. 1269, for dispositions occur- ring during the period April through June 1998; Rev. Rul. 98–45, 1998–2 C.B. 364, for dispositions occurring during the pe- riod July through September 1998; Rev. Rul. 99–1, 1999–2 I.R.B. 4, for disposi- tions occurring during the period October through December 1998; Rev. Rul. 99–54, 1999–51 I.R.B. 675, for dispositions oc- curring during the calendar year 1999; and Rev. Rul. 2000–22, 2000–16 I.R.B. 880, for dispositions occurring during the pe- riod January through March 2000. DRAFTING INFORMATION The principal author of this revenue ruling is Gregory N. Doran of the Office of Assistant Chief Counsel (Passthroughs and Special Industries). For further infor- mation regarding this revenue ruling, con- tact Mr. Doran on (202) 622-3040 (not a toll-free call). Section 401.—Qualified Pension, Profit-Sharing, and Stock Bonus Plans 26 CFR1.401(b)–1: Certain retroactive changes in plan. A procedure describes when plans that are qual- ified under § 401(a) or § 403(a) must be amended for the Uruguay Round Agreements Act, the Uni- formed Services Employment and Reemployment Rights Act of 1994, the Small Business Job Pro- tection Act of 1996, the Taxpayer Relief Act of 1997, and the Internal Revenue Service Restruc- turing and Reform Act of 1998. See Rev. Proc. 2000–27, page 1272. Section 6302.—Mode or Time of Collection 26 CFR 40.6302(c)–1: Use of Government depositaries. T.D. 8887 DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 40 Deposits of Excise Taxes AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Final regulations; and removal of temporary regulations. SUMMARY: This document contains final regulations relating to the availabil- ity of the safe harbor deposit rule based on look-back quarter liability and affects persons required to make deposits of ex- cise taxes. This document also contains final regulations related to floor stocks taxes and affects persons liable for those taxes. The regulations implement changes made by the Small Business Job Protection Act of 1996 and the Airport and Airway Trust Fund Tax Reinstate- ment Act of 1997. DATES: Effective Date: These regula- tions are effective June 8, 2000. Applicability Dates: For dates of ap- plicability of these regulations, see §§40.6302(c)–1(c)(2)(iv)(C) and 40.6302(c)–2(b)(2)(iii)(C). FOR FURTHER INFORMATION CON- TACT: Susan Athy, (202) 622-3130 (not a toll-free number). SUPPLEMENTARY INFORMATION: Background Temporary regulations (T.D. 8740, 1998–1 C.B. 289) relating to the safe har- bor deposit rule based on look-back quar- ter liability and to floor stock taxes were published in the Federal Register on De- cember 29, 1997 (62 F.R. 67568) along with a notice of proposed rulemaking (REG–102894–97, 1998–1 C.B. 344) cross-referencing the temporary regula- tions (62 F.R. 67589). Written comments and requests for a public hearing were so- licited. However, no comments or re- quests were received and no public hear- ing was held. The proposed regulations are adopted without revision by this Treasury deci- sion. Effect on Other Documents The following publication is obsolete as of June 8, 2000: Notice 97–15, 1997–1 C.B. 387. Special Analyses It has been determined that this Trea- sury decision is not a significant regula- tory action as defined in Executive Order 12866. Therefore, a regulatory assess- ment is not required. It also has been de- termined that section 553(b) of the Ad- ministrative Procedure Act (5 U.S.C. chapter 5) does not apply to these regula- tions and, because these regulations do not impose on small entities a collection of information requirement, the Regula- tory Flexibility Act (5 U.S.C. chapter 6) does not apply. Therefore, a Regulatory Flexibility Analysis is not required. Pur- suant to section 7805(f) of the Internal Revenue Code, the notice of proposed rulemaking was submitted to the Chief Counsel for Advocacy of the Small Busi- ness Administration for comment on its impact on small business. Drafting Information The principal author of these regula- tions is Susan Athy, Office of Assistant Chief Counsel (Passthroughs and Special Industries). However, other personnel from the IRS and Treasury Department participated in their development. * * * * * Adoption of Amendments to the Regulations Accordingly, 26 CFR part 40 is amended as follows: PART 40—EXCISE TAX PROCEDURAL REGULATIONS Paragraph 1. The authority citation for part 40 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * * Par. 2. In §40.0–1, paragraph (a) is amended by revising the second sentence to read as follows: §40.0–1 Introduction. (a) * * * The regulations set forth ad- ministrative provisions relating to the ex- cise taxes imposed by chapters 31, 32, 33, 34, 36, 38, and 39 (except for the chapter 32 tax imposed by section 4181 (firearms tax) and the chapter 36 taxes imposed by sections 4461 (harbor maintenance tax) and 4481 (heavy vehicle use tax)), and to floor stocks taxes imposed on articles subject to any of these taxes. * * * * * * * * §40.0–1T [Removed] Par. 3. Section 40.0–1T is removed. Par. 4. In §40.6011(a)–1, paragraph (a)(2)(iii) is added to read as follows: §40.6011(a)–1 Returns. (a) * * * (2) * * * (iii) Floor stocks tax return. A return reporting liability for a floor stocks tax described in §40.0–1(a) is a return for the calendar quarter in which the tax payment is due and not the calendar quarter in which the liability for tax is incurred. * * * * * §40.6011(a)–1T [Removed] Par. 5. Section 40.6011(a)–1T is re- moved. Par. 6. Section 40.6302(c)–1 is amended as follows: 1. Paragraph (c)(2)(iv) is added. 2. Paragraph (f)(1) is amended by adding a sentence to the end of the para- graph. The additions read as follows: §40.6302(c)–1 Use of Government de- positaries. * * * * * (c) * * * (2) * * * (iv) Modification for new or reinstated taxes–(A) Applicability. The safe harbor rule of paragraph (c)(2)(i) of this section is modified for any calendar quarter in which a person’s liability for a class of tax includes liability for any new or reinstated tax. For this purpose, a new or reinstated tax is— (1) Any tax (including an alternative method tax) that was not in effect at all times during the look-back quarter; and (2) Any alternative method tax that was not in effect at all times during the month preceding the look-back quarter. (B) Modification. The safe harbor rule of paragraph (c)(2)(i) of this section does not apply to a class of tax unless the de- posit of taxes in that class for each semi- monthly period in the calendar quarter is not less than the greater of— (1) 1/6 of the net tax liability reported for the class of tax for the look-back quar- ter; or (2) The sum of— (i) 95 percent of the net tax liability in- curred with respect to new or reinstated taxes during the semimonthly period; and (ii) 1/6 of the net tax liability reported for all other taxes in the class for the look- back quarter. (C) Effective date. This paragraph (c)(2)(iv) applies to tax liabilities for new or reinstated taxes incurred after February 28, 1997, except that paragraph (c)(2)(iv)(A)(2) of this section applies only for calendar quarters beginning after December 31, 1997. * * * * * (f) * * * (1) * * * Also, no deposit is re- quired in the case of any floor stocks tax described in §40.0–1(a). * * * * * §40.6302(c)–1T [Removed] Par. 7. Section 40.6302(c)–1T is re- moved. June 26, 200012702000–26 I.R.B. Par. 8. In §40.6302(c)–2, paragraph (b)(2)(iii) is added to read as follows: §40.6302(c)–2 Special rules for use of Government depositaries under section 4681. * * * * * (b) * * * (2) * * * (iii) Modification for new chemicals— (A) Applicability. The safe harbor rule of paragraph (b)(2)(i) of this section is modi- fied for any calendar quarter in which a per- son’s liability for section 4681 tax includes liability with respect to any new chemical. For this purpose, a new chemical is any chemical that was not subject to tax at all times during the look-back quarter. (B) Modification. The safe harbor rule of paragraph (b)(2)(i) of this section does not apply unless the deposit of section 4681 taxes for each semimonthly period in the calendar quarter is not less than the greater of— (1) 1/6 of the net tax liability reported under section 4681 for the look-back quarter; or (2) The sum of— (i) 95 percent of the net tax liability in- curred under section 4681 with respect to the new chemical during the semimonthly period; and (ii) 1/6 of the net tax liability reported under section 4681 with respect to all other chemicals for the look-back quarter. (C) Effective date. This paragraph (b)(2)(iii) applies to tax liabilities for new chemicals incurred after February 28, 1997. * * * * * §40.6302(c)–2T [Removed] Par. 9. Section 40.6302(c)–2T is re- moved. Robert E. Wenzel, Deputy Commissioner of Internal Revenue. Approved May 22, 2000. Jonathan Talisman, Deputy Assistant Secretary of the Treasury. (Filed by the Office of the Federal Register on June 7, 2000, 8:45 a.m., and published in the issue of the Federal Register for June 8, 2000, 65 F.R. 36326) 2000–26 I.R.B.1271June 26, 2000 26 CFR 601.201: Rulings and determination letters. (Also, Part I, § 401; § 1.401(b)–1.) Rev. Proc. 2000–27 SECTION 1. PURPOSE .01 This revenue procedure opens the Internal Revenue Service’s determination letter program to allow sponsors of quali- fied plans to obtain determination letters that take into account all the changes in the qualification requirements made by “GUST,” including those changes made by the Small Business Job Protection Act of 1996, Pub. L. 104–188 (“SBJPA”), that are first effective in plan years beginning after December 31, 1998. This procedure also extends until the last day of the first plan year beginning on or after January 1, 2001, the remedial amendment period under § 401(b) of the Code for amending plans for GUST, as well as the TRA ‘86 remedial amendment period for govern- mental and nonelecting church plans. Fi- nally, this revenue procedure extends by an additional year the period of extended reliance for certain plans that received fa- vorable determination, opinion, or notifi- cation letters under TRA ‘86. .02 The term “GUST” refers to the fol- lowing: 1 the Uruguay Round Agreements Act, Pub. L. 103–465 (“GATT”); 2 the Uniformed Services Employment and Reemployment Rights Act of 1994, Pub. L. 103–353 (“USERRA”); 3 SBJPA; 4 the Taxpayer Relief Act of 1997, Pub. L. 105–34 (“TRA ‘97”); and 5 the Internal Revenue Service Re- structuring and Reform Act of 1998, Pub. L. 105–206 (“RRA ‘98”). SECTION 2. BACKGROUND .01 Prior to June 26, 2000, plan spon- sors could not request determination let- ters under § 401(a) or § 403(a) that take into account the changes in the qualifica- tion requirements made by SBJPA that are first effective in plan years beginning after December 31, 1998, unless the de- termination related to a terminating plan. Instead, sponsors of individually-de- signed plans, including volume submitter plans, could request letters that take into account all the changes in the qualifica- tion requirements made by GUST other than those changes made by SBJPA that are first effective in plan years beginning after December 31, 1998. (These letters are referred to in this revenue procedure as “GUST I letters.”) Alternatively, spon- sors of individually-designed plans, in- cluding volume submitter plans, had the option to request determination letters that do not take into account any of the changes made by GUST, except for changes to § 401(a)(26) and § 414(n). (These letters are referred to as “pre- GATT letters.”) Determination letters for master or prototype (M&P) or regional prototype plans that have not yet been amended by their sponsors for GUST do not consider the changes made by GUST. See Rev. Proc. 98–14, 1998–1 C.B. 371, as modified by Rev. Proc. 98–53, 1998–2 C.B. 456, and section 3.03 of Rev. Proc. 2000–6, 2000–1 I.R.B. 187. .02 Proposed regulations (REG– 109101–98, 2000–16 I.R.B. 903) under § 411(d)(6), which were published in the Federal Registeron March 29, 2000 (65 F.R. 16546), would permit qualified de- fined contribution plans to be amended to eliminate some alternative forms in which an account balance can be paid under cer- tain circumstances, and would permit cer- tain transfers between defined contribu- tion plans that are not permitted under regulations now in effect. The proposed regulations are proposed to be effective upon publication of final regulations in the Federal Registerand cannot be relied upon before finalization. .03 Under § 401(b), plan sponsors have a remedial amendment period in which to adopt GUST plan amendments. Rev. Proc. 99–23, 1999–16 I.R.B. 5, provides that the GUST remedial amendment pe- riod for nongovernmental plans ends on the last day of the first plan year begin- ning on or after January 1, 2000. For gov- ernmental plans, as defined in § 414(d), the GUST remedial amendment period ends on the later of (i) the last day of the last plan year beginning before January 1, 2001, or (ii) the last day of the first plan year beginning on or after the “1999 leg- islative date” (that is, the 90 th day after the opening of the first legislative session beginning after December 31, 1998, of the governing body with authority to amend the plan, if that body does not meet continuously). The remedial amendment period can be further ex- tended by the timely submission of a de- termination letter application. The end of the GUST remedial amendment period is the deadline for making all GUST plan amendments, including plan amendments reflecting the repeal of § 415(e) and other plan amendments specifically enumerated in Rev. Proc. 99–23. The GUST remedial amendment period also applies with re- spect to all disqualifying provisions of new plans adopted or effective after De- cember 7, 1994, and with respect to all plan amendments adopted after December 7, 1994, which would cause an existing plan to fail to be qualified. .04 Rev. Proc. 2000–20, 2000–6 I.R.B. 553, includes a procedure for extending the GUST remedial amendment period for employers adopting M&P or volume submitter plans. To be eligible for the ex- tension, employers must either adopt an M&P or volume submitter plan before the end of the GUST remedial amendment period (determined without regard to the extension) or, before such time, certify their intent to adopt a GUST-approved M&P or volume submitter plan. Addi- tionally, the M&P sponsor or volume sub- mitter practitioner must request a GUST opinion or advisory letter by December 31, 2000. .05 Rev. Proc. 99–23 extended the TRA ‘86 remedial amendment period for gov- ernmental plans to the end of the GUST remedial amendment period for govern- mental plans described above. The plan amendments to which the TRA ‘86 reme- dial amendment period applies are those required to comply with the Tax Reform Act of 1986, Pub. L. 99–514 (“TRA ‘86”) and subsequent legislation through the Omnibus Budget Reconciliation Act of 1993, Pub. L. 103–66 (“OBRA ‘93”). .06 Under Notice 98–39, 1998–2 C.B. 205, nonelecting church plans are not re- quired to be amended to comply with reg- ulations under §§ 401(a)(4), 401(a)(5), 401(l), and 414(s) until the last day of the first plan year beginning on or after Janu- ary 1, 2001. However, under Rev. Proc. 99–23, these plans are required to be amended to comply with other applicable June 26, 200012722000–26 I.R.B. Part III. Administrative, Procedural, and Miscellaneous provisions of TRA ‘86 and subsequent legislation through OBRA ‘93 by the end of the generally applicable GUST reme- dial amendment period, that is, the end of the first plan year beginning on or after January 1, 2000. .07 Plans that were submitted to the Service within certain deadlines for deter- mination, opinion, or notification letters under TRA ‘86 and received favorable letters were entitled to extended reliance on their letters. However, plans with ex- tended reliance are required to be amended to comply with regulations and administrative guidance of general applic- ability issued since the date of the plan’s favorable TRA ‘86 letter. Rev. Proc. 99–23 extended the time for adopting such amendments to the end of the GUST remedial amendment period. SECTION 3. PROGRAM OPENING .01 Applications for determination let- ters under § 401(a) or § 403(a) that are filed with the Service on or after June 26, 2000, for individually-designed plans, in- cluding volume submitter plans, will be reviewed taking into account all the changes in the qualification requirements made by GUST, including those changes made by SBJPA that are first effective in plan years beginning after December 31, 1998, unless the sponsor asks the Service to limit the extent to which the plan is re- viewed for GUST, as described below. (Determination letters that take into ac- count all the GUST changes are referred to in this revenue procedure as “GUST II letters.” Except in the case of terminating plans, the review of applications for de- termination letters for M&P plans will take into account the GUST changes only to the extent that the M&P plan sponsor has amended the plan for GUST and re- ceived a favorable opinion letter. .02 Until further notice, sponsors of in- dividually-designed plans, including vol- ume submitter plans, will continue to have the option of limiting the extent to which their plans are reviewed for GUST by re- questing either a GUST I letter or a pre- GATT letter, rather than a GUST II letter. The sponsor should make this request in a cover letter with the application. (This op- tion does not apply to applications for de- termination on plan termination.) Under this option, the sponsor will need to sub- mit another application and pay another user fee to obtain a GUST II letter. .03 Because the proposed regulations under § 411(d)(6) may not be relied upon prior to finalization, the proposed regula- tions will not be taken into account by the Service for purposes of issuing determi- nation letters. Until such regulations are finalized, the Service will not issue a fa- vorable determination letter for a plan that is amended to eliminate or reduce benefits in a manner that is not permitted under regulations now in effect. Therefore, sponsors who are considering submitting determination letter applications before the proposed regulations under § 411(d)(6) are finalized should also be aware that they may have to submit an- other application and pay another user fee if they wish to adopt plan amendments as a result of the final regulations. .04 In general, plans must be restated when they are submitted for GUST II de- termination letters. For this purpose, sub- mission of a working copy of the plan in a restated format will suffice. A plan is generally exempt from the requirement to restate, however, if there have been fewer than four consecutive amendments since the plan was last restated, excluding amendments making only nonsubstantive plan changes, the plan has a favorable TRA ‘86 determination letter, and the plan meets either of the following condi- tions: 1 The plan is a defined contribution plan under which the only contribu- tions are nonelective employer con- tributions; or 2 The plan has a favorable GUST I determination letter and is not adding provisions designed to sat- isfy the safe harbor requirements of § 401(k)(12) or § 401(m)(11). The Service nevertheless reserves the right to require restatement of a plan or submission of a working copy of a plan in a restated format in any case in which this is determined to be necessary. .05 In general, Form 6406, Short Form Application for Determination for Minor Amendment of Employee Benefit Plan, may not be used to apply for either a GUST I or a GUST II letter. However, if use of Form 6406 is not otherwise pre- cluded by section 11 of Rev. Proc. 2000–6, Form 6406 may be used to apply for a GUST II letter for a defined contribution plan with a favorable GUST I letter which does not include provisions designed to satisfy the safe harbor requirements of § 401(k)(12) or § 401(m)(11). In this case, the applica- tion should include a cover letter indi- cating the application is for a GUST II letter. The Service reserves the right to require the filing of a Form 5300 series application in any case in which it deter- mines that the use of Form 6406 is inap- propriate. .06 The Service will attempt to contact each plan sponsor who has a Form 5300 determination letter application being re- viewed by a determination letter specialist on June 26, 2000, to determine if the sponsor wishes to convert the application to a GUST II application. The Service will continue to process each other pend- ing application in accordance with the procedures in effect prior to June 26, 2000. SECTION 4. EXTENSION OF THE REMEDIAL AMENDMENT PERIOD .01 The GUST remedial amendment period for nongovernmental plans is ex- tended to the last day of the first plan year beginning on or after January 1, 2001. The remedial amendment period for gov- ernmental plans, as defined in § 414(d), is extended to the later of (i) the last day of the first plan year beginning on or after January 1, 2001, or (ii) the last day of the first plan year beginning on or after the “2000 legislative date” (that is, the 90 th day after the opening of the first legisla- tive session beginning after December 31, 1999, of the governing body with author- ity to amend the plan, if that body does not meet continuously). .02 In general, all plan provisions that either cause a plan to fail to satisfy the qualification requirements of the Code because of changes to those requirements made by GUST or are integral to a quali- fication requirement changed by GUST are disqualifying provisions under § 1.401(b)–1(b) of the regulations. Thus, this extension of the GUST remedial amendment period applies to all GUST plan amendments, including all those specifically enumerated in Rev. Proc. 99–23. In addition, this extends the reme- dial amendment period with respect to all disqualifying provisions of new plans adopted or effective after December 7, 1994, and with respect to all plan amend- 2000–26 I.R.B.1273June 26, 2000 ments adopted after December 7, 1994, which would cause an existing plan to fail to be qualified. .03 This extension also applies for pur- poses of the time by which employers must either adopt an M&P or volume sub- mitter plan or certify their intent to adopt a GUST-approved M&P or volume sub- mitter plan in order to be eligible for the extension described in section 19 of Rev. Proc. 2000–20. However, the December 31, 2000, deadline for submission of ap- plications for opinion and advisory letters under section 19 of Rev. Proc. 2000–20 is not extended. .04 The TRA ‘86 remedial amendment period for governmental plans is extended to the end of the GUST remedial amend- ment period for governmental plans de- scribed above. The TRA ‘86 remedial amendment period for nonelecting church plans is extended to the end of the GUST remedial amendment period for non- governmental plans described above. Thus, nonelecting church plans now have a single amendment deadline for all GUST and TRA ‘86 plan amendments, in- cluding amendments relating to the nondiscrimination requirements. The ad- ditional administrative relief provided under Notice 92–36, 1992–2 C.B. 364, continues to be available to governmental and nonelecting church plans through the end of their respective remedial amend- ment periods with respect to the applica- ble nondiscrimination requirements. SECTION 5. EXTENSION OF EXTENDED RELIANCE PERIOD The TRA ‘86 extended reliance period is extended by an additional year. A plan with extended reliance must be amended by the end of the GUST remedial amend- ment period to the extent necessary to comply with regulations or administrative guidance of general applicability issued since the date of the plan’s favorable TRA ‘86 determination letter. These amend- ments must be made effective no later than the first day of the plan year in which the GUST remedial amendment period ends, and, except in the case of M&P or volume submitter plans, no earlier than the first day of the plan year in which the amendments are adopted. (But see Rev. Rul. 94–76, 1994–2 C.B. 46, and Rev. Rul. 96–47, 1996–2 C.B. 35.) SECTION 6. EFFECT ON OTHER DOCUMENTS Rev. Procs. 98–14, 99–23, 2000–6, and 2000–20 are modified. SECTION 7. EFFECTIVE DATE This revenue procedure is effective June 26, 2000. DRAFTING INFORMATION The principal author of this revenue procedure is James Flannery of the Tax Exempt and Government Entities Divi- sion. For further information regarding this revenue procedure, contact the Em- ployee Plans Division’s telephone assis- tance service between the hours of 1:30 and 3:30 p.m. Eastern time, Monday through Thursday, on (202) 622-6074/75. (These telephone numbers are not toll- free.) Weighted Average Interest Rate Update Notice 2000–31 Notice 88–73 provides guidelines for determining the weighted average interest rate and the resulting permissible range of interest rates used to calculate current lia- bility for the purpose of the full funding limitation of § 412(c)(7) of the Internal Revenue Code as amended by the Om- nibus Budget Reconciliation Act of 1987 and as further amended by the Uruguay Round Agreements Act, Pub. L. 103–465 (GATT). The average yield on the 30-year Trea- sury Constant Maturities for May 2000 is 6.15 percent. The following rates were determined for the plan years beginning in the month shown below. June 26, 200012742000–26 I.R.B. 90% to 105%90% to 110% WeightedPermissiblePermissible MonthYearAverageRangeRange June20006.015.41 to 6.315.41 to 6.61 Drafting Information The principal author of this notice is Todd Newman of the Employee Plans, Tax Exempt and Government Entities Di- vision. For further information regarding this notice, call the Employee Plans Actu- arial hotline, (202) 622-6076 between 2:30 and 3:30 p.m. Eastern time (not a toll-free number). Mr. Newman’s number is (202) 622-8458 (also not a toll-free number). Eligible Rollover Distributions Notice 2000–32 I. PURPOSE This notice provides additional relief relating to the exception to the definition of eligible rollover distribution for certain hardship distributions. This exception was added to §§ 402(c)(4) and 403(b)(8)(B) of the Internal Revenue Code (the “Code”) by § 6005(c)(2)(A) and (B) of the Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105–206 (“RRA 98”). Transition relief and guidance relating to the excep- tion was initially provided in Notice 99–5, 1999–3 I.R.B. 10. In response to comments from representatives of plan sponsors and recordkeepers regarding their significant difficulties in implement- ing certain requirements of Notice 99–5, this notice provides permanent relief to sponsors of qualified plans where records pertaining to pre-1989 contributions are unavailable, and also provides transition relief to sponsors of both qualified plans and § 403(b) annuities from certain other requirements of Notice 99–5. II. BACKGROUND Section 401(a)(31) requires a qualified plan to permit distributees to elect to have an eligible rollover distribution paid di- rectly to an eligible retirement plan speci- fied by the distributee. Section 403(b)(10) provides that a § 403(b) annuity must meet requirements similar to the requirements of § 401(a)(31). Section 402(c)(4) generally provides that any distribution of all or any portion of the balance to the credit of an em- ployee in a qualified plan is an eligible rollover distribution. However, as excep- tions to this general rule, that section specifies certain distributions that are not eligible rollover distributions. Prior to amendment by RRA 98, the only exceptions to the definition of eligi- ble rollover distribution provided for in § 402(c) were any distribution that is one of a series of substantially equal periodic payments made for certain periods, any distribution to the extent such distribution is required under § 401(a)(9), and any dis- tribution that is not includible in gross in- come (determined without regard to the exclusion for net unrealized appreciation described in § 402(e)(4)). Section 403(b)(8) provides that rules similar to those in § 402(c)(4) apply for purposes of determining the amount eligi- ble for rollover from a § 403(b) annuity. Section 1.403(b)–2, Q&A-1 provides that an eligible rollover distribution from a § 403(b) annuity is an eligible rollover distribution described in § 402(c)(4) and § 1.402(c)–2, except that the distribution is from a § 403(b) annuity rather than a qualified plan. Section 6005(c)(2)(A) of RRA 98 added § 402(c)(4)(C) to the Code, which specifies an additional exception to the definition of eligible rollover distribution for any hardship distribution described in § 401(k)(2)(B)(i)(IV), effective for distri- butions after December 31, 1998. Section 6005(c)(2)(B) of RRA 98 amended § 403(b)(8)(B) of the Code to include a specific reference to § 402(c)(4)(C). Thus, the new exception also applies to distributions from § 403(b) annuities. Section 401(k)(2)(B)(i) provides that contributions made under a qualified cash or deferred arrangement (“CODA”) are not permitted to be distributed earlier than the occurrence of certain specified events. Under § 401(k)(2)(B)(i)(IV), an em- ployee’s elective contributions may be distributed upon the hardship of the em- ployee. Section 1.401(k)–1(d)(2)(ii) pro- vides that qualified nonelective and quali- fied matching contributions that were treated as elective contributions, plus earnings on these contributions and on elective contributions, credited to an em- ployee’s account as of a date specified in the plan containing the qualified CODA (which date generally was required to be before July 1, 1989) may also be distrib- uted upon the hardship of the employee. The date described in the preceding sen- tence is hereinafter referred to as the “‘89 date” and the amounts described in the preceding sentence are hereinafter re- ferred to as “pre-’89 401(k) amounts.” Contributions not made under a qualified CODA, such as matching contributions or profit-sharing contributions, are not de- scribed in § 401(k)(2)(B)(i)(IV). Sections 403(b)(1) and 403(b)(11) pro- vide that amounts contributed pursuant to a salary reduction agreement for years be- ginning after December 31, 1988, are not permitted to be distributed earlier than the occurrence of certain specified events. Under § 403(b)(11)(B), such amounts may be distributed upon the hardship of the employee. Amounts held in an annu- ity contract described in § 403(b)(1) as of the close of the last year beginning before January 1, 1989, and amounts contributed to the contract as nonelective employer contributions are generally not subject to distribution restrictions. Sections 403(b)(7) and 403(b)(11) pro- vide that amounts contributed to a custo- dial account described in § 403(b)(7) are not permitted to be distributed earlier than the occurrence of certain specified events. Under §§ 403(b)(7) and 403(b)(11), con- tributions made pursuant to a salary re- duction agreement, as well as any other amounts held in the custodial account as of the close of the last year beginning be- fore January 1, 1989, may be distributed upon the hardship of the employee. Notice 99–5 provided transition relief from the requirements of § 6005(c)(2)(A) and (B) of RRA 98 by permitting quali- fied plans and § 403(b) annuities to treat those distributions made in calendar year 1999 that would have been eligible rollover distributions under § 402(c)(4) immediately prior to its amendment by RRA 98 as eligible rollover distributions for all purposes under the Code. Notice 99–5 also provided that, for pur- poses of § 6005(c)(2)(A) and (B) of RRA 98, “a hardship distribution described in § 401(k)(2)(B)(i)(IV)” includes only amounts described in § 1.401(k)–1 (d)(2)(ii), including pre-’89 401(k) amounts, and does not include amounts that are distributable under the Code with- out regard to the hardship of the employee. Similar rules were provided with respect to § 403(b) annuities. In addition, Notice 99–5 provided that if another event occurs, such as the employee’s separation from service or attainment of age 59 1/2, so that distribution of an amount is permitted under the Code, without regard to hard- ship, no amount distributed after that event is ineligible for rollover treatment on ac- count of being a hardship distribution de- scribed in § 401(k)(2)(B)(i)(IV). Lastly, Notice 99–5 provided that if a portion of a distribution that includes a hardship distri- bution is not includible in gross income, the portion of the distribution that is not in- cludible in gross income is first allocated to the hardship distribution. Notice 99–5 provided that the above rules were first ap- plicable to distributions made after De- cember 31, 1999. III. DEFINITIONS For purposes of this notice, a “§ 403(b) annuity” includes an annuity contract, a custodial account, and a retirement in- come account described in § 403(b) (see § 1.403(b)–2, Q&A-1) and a “qualified plan” is an employees’ trust described in § 401(a) that is exempt from tax under § 501(a) or an annuity plan described in § 403(a) (see § 1.402(c)–2, Q&A-2). IV. RELIEF Representatives of plan sponsors and recordkeepers have raised concerns about certain of the requirements of Notice 99–5. Those representatives indicated that, in many cases, plan records were inadequate to comply with the requirement that amounts treated as ineligible for rollover by reason of RRA 98 be limited to the amount 2000–26 I.R.B.1275June 26, 2000 described in § 1.401(k)–1(d)(2)(ii), particu- larly with respect to pre-’89 401(k) amounts. In addition, it was stated that, in light of the extensive revisions to computer systems required to prevent “Y2K” prob- lems, plan sponsors and recordkeepers were unable to modify their systems to comply with certain other requirements of Notice 99–5 by January 1, 2000, the date transition relief under Notice 99–5 became no longer available. In response to these concerns, the re- quirements of Notice 99–5 are modified as follows: (i)Pre-’89 401(k) Amounts.As noted, under Notice 99–5, amounts that are ineligible for rollover by reason of § 6005(c)(2)(A) of RRA 98 are lim- ited to amounts described in § 1.401(k)–1(d)(ii), including pre-’89 401(k) amounts. Concerns have been raised that, in many instances, plan records do not make it possible to dis- tinguish pre-’89 401(k) amounts from other amounts credited to an em- ployee’s account as of the ‘89 date. Accordingly, if a qualified plan’s records are not reasonably available to segregate an employee’s pre-’89 401(k) amounts from other amounts that, as of the ‘89 date, were credited to the employee’s account, then, for purposes of determining what is an eligible rollover distribu- tion, the plan must treat the other amounts as described in § 401(k)(2)– (B)(i)(IV). That is, the other amounts are treated the same as pre-’89 401(k) amounts and elective contributions and are therefore treated as ineligible for rollover when distributed on account of hardship. (ii)Satisfaction of Another Statutory Dis- tributable Event. Notice 99–5 pro- vides that, if another event occurs, such as the employee’s separation from service or attainment of age 59 1/2, so that distribution of an amount is permitted under § 401(k)(2)(B), § 403(b)(7) or § 403(b)(11) without regard to hardship, no amount distrib- uted after that event is ineligible for rollover treatment on account of being a hardship distribution described in § 401(k)(2)(B)(i)(IV), § 403(b)(7) or § 403(b)(11). Plan sponsors and recordkeepers indicated to the Service that, in many instances, their systems are unable to track whether a distribu- tion made on account of hardship under the terms of the plan might also be distributable under another statu- tory provision. Therefore, as an alternative to the rule in Notice 99–5, until further guidance is issued, a distribution that is described in § 401(k)(2)(B)(i)(IV), § 403(b)(7) or § 403(b)(11) and that is made as a hardship distribution under the terms of a qualified plan or § 403(b) annuity may be treated as ineligible for rollover even though another event has occurred that could entitle the recipient to a distribution without regard to hardship under § 401(k)(2–)(B)(i)(IV), § 403(b)(7) or § 403(b)–(11). Thus, for example, if a profit-sharing plan containing a qual- ified CODA provides that in-service distributions are available only upon hardship, an in-service distribution made to a participant aged 62 may, to the extent of elective contributions and other amounts described in § 1.401(k)–1(d)(2)(ii) (including amounts described in (i) above that are treated as pre-’89 401(k) amounts), be treated as ineligible for rollover. Alternatively, if the rule in Notice 99–5 is followed, the distribu- tion in this example to the age-62 par- ticipant may be treated as eligible for rollover. (iii)Allocation of Basis. The plan sponsor and recordkeeper community also raised concerns about the feasibility of timely programming their systems to follow the basis allocation rules of Notice 99–5. Therefore, until further guidance is issued, if a portion of a hardship distribution from a qualified plan or a § 403(b) annuity is not in- cludible in gross income, the portion of the distribution that is not includi- ble in gross income may be allocated to the portion ineligible for rollover or the portion eligible for rollover (or be- tween the two portions) using any rea- sonable method. A qualified plan or § 403(b) annuity generally must, in applying the above rules, be consistent in the treatment of all distributions. V. EFFECT ON OTHER DOCUMENTS Notice 99–5 is modified. VI. DRAFTING INFORMATION The principal author of this notice is Roger Kuehnle of the Tax Exempt and Government Entities Division. For fur- ther information regarding this notice, please contact the Employee Plans’ tax- payer assistance telephone service at (202) 622-6074/6075 (not toll-free num- bers) between the hours of 1:30 and 3:30 p.m. Eastern Time, Monday through Thursday. Proposed 2001 Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding Announcement 2000–54 The Internal Revenue Service announces that it is requesting comments from the public on proposed revisions to the 2001 Form 1042-S. This form is used by U.S. withholding agents to report the withhold- ing of U.S. income tax on certain U.S. source income paid to foreign persons. This announcement provides a draft copy of the 2001 Form 1042-S. The form is being issued so that withholding agents can adapt their systems to comply with the regulations under sections 1441, 1442, and 1443, which were recently amended by T.D. 8881 (published on May 22, 2000, in 65 F.R. 32152 and again on June 5, 2000, in 2000–23 I.R.B 1158). Filers and recipients of the form are advised that the form may be revised based on further developments and comments. Form 1042-S was previously released for public comments on April 19, 1999 (Announcement 99–46, 1999–16 I.R.B. 13). We made the following changes to the form as the result of those comments: •VOID box.This box has been added to the recipient copies (Copies B, C & D). •Box 2 (Gross income), Box 4 (Net in- come), Box 7 (U.S. Federal tax with- held), andBox 8 (Amount reim- bursed to recipient).We increased the width of these boxes. •Box 9 (Withholding agent’s EIN) and Box 14 (Recipient’s U.S. TIN).We increased the width of the checkboxes so that they are easier to line up in a printer. •Box 10 (Withholding agent’s name and address) and Box 13 (Recipient’s name and address). We positioned June 26, 200012762000–26 I.R.B. these boxes so that the information en- tered will show through a standard dou- ble window envelope. In doing so, we increased the vertical size of box 13 so that 6 lines are available in the entry area (allowing for 4 lines of print and 2 extra lines for printer line-up). •Box 11 (Recipient’s account num- ber).We increased the available entry area. •Box 19 (Nonqualified intermedi- ary’s/Flow-through entity’s address). We increased the height of this box. •Income codes on the back of Copy C. We changed the codes back to the way they were on the 2000 form (i.e., income codes 01 through 28 are the same on the 2000 and 2001 forms). New codes 29 through 31 have been added, but are grouped with the other Interest Income codes. New code 32 has been added and placed with the Other Income codes. Form 1042-S, as designed for the year 2001, contains only one income line. Some commentators requested that we restore multiple income reporting lines (i.e., lines 1 through 3 of the current year 2000 form). Although we were not able to accommo- date this comment, in an effort to mitigate the impact of this change, a withholding agent may be permitted to use substitute payee copies of the form (i.e., copies B, C, and D) that contain more than one income line. Under no circumstances, however, will the copy of the form filed with the IRS (copy A) be permitted to contain more than one income line (i.e., boxes 1 through 8). The following change has been made to the form as the result of changes to the regulations made by T.D. 8881: The PRO-RATA BASIS REPORTING box at the top of the form was added as an in- dicator that the withholding agent must use to notify the IRS that a nonqualified intermediary that used the alternative pro- cedures of Regulations section 1.1441–1(e)(3)(iv)(D) (i.e., year-end allo- cation) failed to properly comply with those allocation requirements. If this box is checked, withholding agents will be in- structed to complete box 5 (Tax rate) by including the appropriate rate of withhold- ing in the box, not the rate of withholding actually applied. For example, a with- holding agent that withheld 15% from payments made to a nonqualified interme- diary should place 30% in box 5 for pay- ments it reports under the pro rata report- ing rule of sec. 1.1441–1(e)(3)(iv)(D)(6). Several respondents inquired as to the intended use for box 8. This new box was added to reflect the reimbursement proce- dure described in Regulations section 1.1461–2(a)(2)(i). We anticipate that the instructions for Form 1042-S will state that a qualified in- termediary reporting payments on behalf of a private arrangement intermediary (PAI) must treat each PAI as a separate re- cipient and therefore must file a separate Form 1042-S for each withholding rate pool paid to a PAI. The IRS would like to receive comments on this proposed draft form from all inter- ested persons by July 26, 2000. Please send comments to Chairman, Tax Forms Coordinating Committee, Internal Revenue Service, OP:FS:FP, Room 5577, 1111 Con- stitution Avenue, NW, Washington, DC 20224. Alternatively, you may e-mail your comments to tfpmail@publish.no.irs.gov. 2000–26 I.R.B.1277June 26, 2000 June 26, 200012782000–26 I.R.B. 2000–26 I.R.B.1279June 26, 2000 June 26, 200012802000–26 I.R.B. Deletions from Cumulative List of Organizations Contributions to Which are Deductible Under Section 170 of the Code Announcement 2000–56 The names of organizations that no longer qualify as organizations de- scribed in section 170(c)(2) of the Inter- nal Revenue Code of 1986 are listed below. Generally, the Service will not disal- low deductions for contributions made to a listed organization on or before the date of announcement in the Internal Revenue Bulletin that an organization no longer qualifies. However, the Ser- vice is not precluded from disallowing a deduction for any contributions made after an organization ceases to qualify under section 170(c)(2) if the organiza- tion has not timely filed a suit for de- claratory judgment under section 7428 and if the contributor (1) had knowledge of the revocation of the ruling or deter- mination letter, (2) was aware that such revocation was imminent, or (3) was in part responsible for or was aware of the activities or omissions of the organiza- tion that brought about this revocation. If on the other hand a suit for declara- tory judgment has been timely filed, contributions from individuals and orga- nizations described in section 170(c)(2) that are otherwise allowable will con- tinue to be deductible. Protection under section 7428(c) would begin on June 26, 2000, and would end on the date the court first determines that the organiza- tion is not described in section 170(c)(2) as more particularly set forth in section 7428 (c)(1). For individual contributors, the maximum deduction protected is $1,000, with a husband and wife treated as one contributor. This benefit is not extended to any individual, in whole or in part, for the acts or omissions of the organization that were the basis for re- vocation. Babbie Mason Ministries, Inc. Marietta, GA Sanborn Community Development, Inc. Sanborn, MN Notice of Disposition of Declaratory Judgment Proceedings Under Section 7428 This announcement serves notice to donors that on November 23, 1999, the United States District Court for the District of Columbia entered a Stipulation of Dis- missal in response to the parties’ request. By entering the Stipulation, the Court agreed that the organization listed below is not an organization recognized as tax ex- empt under section 501(a) of the Internal Revenue Code and is not described in sec- tions 170(c)(2) and 501(c)(3) retroactive to January 1, 1991. The organization listed below reapplied to the Service for recogni- tion of exempt status, and the Service has recognized the organization as tax exempt under section 501(a) and as an organiza- tion described in sections 170(c)(2) and 501(c)(3) effective January 1, 1997. The Freedom Alliance Dulles, VA Notice of Disposition of Declaratory Judgment Proceedings Under Section 7428 This announcement serves notice to donors that on January 18, 2000, the United States Tax Court entered a Decision accept- ing the agreement of the parties that the or- ganization listed below is recognized as an organization described in section 170(c)(2) and section 501(c)(3) which is exempt from tax under section 501(a). Oriana House, Inc. Akron, OH Notice of Disposition of Declaratory Judgment Proceedings Under Section 7428 This announcement serves notice to donors that on April 13, 2000, the United States Tax Court entered a Decision ac- cepting the agreement of the parties that the exempt status of the organization listed below is retroactively revoked effective January 1, 1986. Further, by letter dated April 7, 2000, the Commissioner has rec- ognized the organization listed below as an exempt organization described in sec- tions 170(c)(2) and 501(c)(3) for periods of time on and after January 1, 1990. United Cancer Council, Inc. Indianapolis, IN Notice of Disposition of Declaratory Judgment Proceedings Under Section 7428 This announcement serves notice to donors that on May 11, 2000, the United States Tax Court entered a Decision ac- cepting the agreement of the parties that the organization listed below is not recog- nized as an organization described in sec- tion 170(c)(2) and section 501(c)(3) and is not exempt from tax under section 501(a) effective July 1, 1998. Lenox Institute of Water Technology, Inc. Lenox, MA Notice of Disposition of Declaratory Judgment Proceedings Under Section 7428 This announcement serves notice to donors that on May 16, 2000, the Court of Federal Claims entered an Order of Dis- missal in response to the parties’ Stipula- tion for Entry of Judgment. The Court or- dered and agreed that the organization listed below is not an organization de- scribed under sections 170(c)(2) and 501(c)(3) of the Internal Revenue Code and is not recognized as exempt under section 501(a) for the years beginning June 1, 1979 and June 1, 1980. The Court further agreed that the organization listed below is an organization described in sec- tions 170(c)(2) and 501(c)(3) and is rec- ognized as exempt under section 501(a) beginning June 1, 1981. St. Matthew Publishing, Inc. Los Angeles, CA 2000–26 I.R.B.1281June 26, 2000 Part IV. Items of General Interest Section 7428(c) Validation of Certain Contributions Made During Pendency of Declaratory Judgment Proceedings This announcement serves notice to po- tential donors that the organization listed below has recently filed a timely declara- tory judgment suit under section 7428 of the Code, challenging revocation of its status as an eligible donee under section 170(c)(2). Protection under section 7428(c) of the Code begins on the date that the notice of revocation is published in the Internal Revenue Bulletin and ends on the date on which a court first determines that an or- ganization is not described in section 170(c)(2), as more particularly set forth in section 7428(c)(1). In the case of individ- ual contributors, the maximum amount of contributions protected during this period is limited to $1,000.00, with a husband and wife being treated as one contributor. This protection is not extended to any in- dividual who was responsible, in whole or in part, for the acts or omissions of the or- ganization that were the basis for the re- vocation. This protection also applies (but without limitation as to amount) to organizations described in section 170(c)(2) which are exempt from tax under section 501(a). If the organization ultimately prevails in its declaratory judg- ment suit, deductibility of contributions would be subject to the normal limitations set forth under section 170. Program to Aid Drug Abusers, Inc. Lakeland, FL June 26, 200012822000–26 I.R.B. 2000–25 I.R.B.iJune 19, 2000 Revenue rulings and revenue procedures (hereinafter referred to as “rulings”) that have an effect on previous rulings use the following defined terms to describe the effect: Amplified describes a situation where no change is being made in a prior pub- lished position, but the prior position is being extended to apply to a variation of the fact situation set forth therein. Thus, if an earlier ruling held that a principle applied to A, and the new ruling holds that the same principle also applies to B, the earlier ruling is amplified. (Compare with modified, below). Clarified is used in those instances where the language in a prior ruling is being made clear because the language has caused, or may cause, some confu- sion. It is not used where a position in a prior ruling is being changed. Distinguisheddescribes a situation where a ruling mentions a previously published ruling and points out an essen- tial difference between them. Modified is used where the substance of a previously published position is being changed. Thus, if a prior ruling held that a principle applied to A but not to B, and the new ruling holds that it ap- plies to both A and B, the prior ruling is modified because it corrects a published position. (Compare with amplified and clarified, above). Obsoleted describes a previously pub- lished ruling that is not considered deter- minative with respect to future transac- tions. This term is most commonly used in a ruling that lists previously published rulings that are obsoleted because of changes in law or regulations. A ruling may also be obsoleted because the sub- stance has been included in regulations subsequently adopted. Revoked describes situations where the position in the previously published rul- ing is not correct and the correct position is being stated in the new ruling. Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings). Thus, the term is used to republish under the 1986 Code and regulations the same position published under the 1939 Code and regulations. The term is also used when it is desired to republish in a single ruling a series of situations, names, etc., that were previously published over a pe- riod of time in separate rulings. If the new ruling does more than restate the substance of a prior ruling, a combination of terms is used. For example, modified and superseded describes a situation where the substance of a previously pub- lished ruling is being changed in part and is continued without change in part and it is desired to restate the valid portion of the previously published ruling in a new ruling that is self contained. In this case the previously published ruling is first modified and then, as modified, is super- seded. Supplemented is used in situations in which a list, such as a list of the names of countries, is published in a ruling and that list is expanded by adding further names in subsequent rulings. After the original ruling has been supplemented several times, a new ruling may be pub- lished that includes the list in the original ruling and the additions, and supersedes all prior rulings in the series. Suspended is used in rare situations to show that the previous published rulings will not be applied pending some future action such as the issuance of new or amended regulations, the outcome of cases in litigation, or the outcome of a Service study. Abbreviations The following abbreviations in current use and for- merly used will appear in material published in the Bulletin. A—Individual. Acq.—Acquiescence. B—Individual. BE—Beneficiary. BK—Bank. B.T.A.—Board of Tax Appeals. C.—Individual. C.B.—Cumulative Bulletin. CFR—Code of Federal Regulations. CI—City. COOP—Cooperative. Ct.D.—Court Decision. CY—County. D—Decedent. DC—Dummy Corporation. DE—Donee. Del. Order—Delegation Order. DISC—Domestic International Sales Corporation. DR—Donor. E—Estate. EE—Employee. E.O.—Executive Order. ER—Employer. ERISA—Employee Retirement Income Security Act. EX—Executor. F—Fiduciary. FC—Foreign Country. FICA—Federal Insurance Contribution Act. FISC—Foreign International Sales Company. FPH—Foreign Personal Holding Company. F.R.—Federal Register. FUTA—Federal Unemployment Tax Act. FX—Foreign Corporation. G.C.M.—Chief Counsel’s Memorandum. GE—Grantee. GP—General Partner. GR—Grantor. IC—Insurance Company. I.R.B.—Internal Revenue Bulletin. LE—Lessee. LP—Limited Partner. LR—Lessor. M—Minor. Nonacq.—Nonacquiescence. O—Organization. P—Parent Corporation. PHC—Personal Holding Company. PO—Possession of the U.S. PR—Partner. PRS—Partnership. PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Real Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul.—Revenue Ruling. S—Subsidiary. S.P.R.—Statements of Procedral Rules. Stat.—Statutes at Large. T—Target Corporation. T.C.—Tax Court. T.D.—Treasury Decision. TFE—Transferee. TFR—Transferor. T.I.R.—Technical Information Release. TP—Taxpayer. TR—Trust. TT—Trustee. U.S.C.—United States Code. X—Corporation. Y—Corporation. Z—Corporation. Definition of Terms June 26, 2000ii2000–26 I.R.B. Numerical Finding List 1 Bulletins 2000–1 through 2000–25 Announcements: 2000–1, 2000–2 I.R.B. 294 2000–2, 2000–2 I.R.B. 295 2000–3, 2000–2 I.R.B. 296 2000–4, 2000–3 I.R.B. 317 2000–5, 2000–4 I.R.B. 427 2000–6, 2000–4 I.R.B. 428 2000–7, 2000–6 I.R.B. 586 2000–8, 2000–6 I.R.B. 586 2000–9, 2000–9 I.R.B. 733 2000–10, 2000–9 I.R.B. 733 2000–11, 2000–10 I.R.B. 739 2000–12, 2000–12 I.R.B. 835 2000–13, 2000–11 I.R.B. 771 2000–14, 2000–11 I.R.B. 772 2000–15, 2000–12 I.R.B. 837 2000–16, 2000–12 I.R.B. 837 2000–17, 2000–13 I.R.B. 846 2000–18, 2000–13 I.R.B. 846 2000–19, 2000–19 I.R.B. 973 2000–20, 2000–19 I.R.B. 977 2000–21, 2000–19 I.R.B. 983 2000–22, 2000–19 I.R.B. 987 2000–23, 2000–19 I.R.B. 992 2000–24, 2000–14 I.R.B. 855 2000–25, 2000–14 I.R.B. 855 2000–26, 2000–15 I.R.B. 876 2000–27, 2000–15 I.R.B. 876 2000–28, 2000–15 I.R.B. 876 2000–29, 2000–15 I.R.B. 877 2000–30, 2000–15 I.R.B. 877 2000–31, 2000–15 I.R.B. 877 2000–32, 2000–15 I.R.B. 879 2000–33, 2000–15 I.R.B. 878 2000–34, 2000–15 I.R.B. 879 2000–35, 2000–16 I.R.B. 922 2000–36, 2000–16 I.R.B. 947 2000–37, 2000–16 I.R.B. 947 2000–38, 2000–16 I.R.B. 948 2000–39, 2000–16 I.R.B. 948 2000–40, 2000–16 I.R.B. 948 2000–41, 2000–16 I.R.B. 949 2000–42, 2000–16 I.R.B. 949 2000–43, 2000–17 I.R.B. 957 2000–44, 2000–17 I.R.B. 958 2000–45, 2000–18 I.R.B. 962 2000–46, 2000–19 I.R.B. 997 2000–47, 2000–21 I.R.B. 1118 2000–48, 2000–23 I.R.B. 1243 2000–49, 2000–19 I.R.B. 998 2000–50, 2000–19 I.R.B. 998 2000–51, 2000–22 I.R.B. 1141 2000–52, 2000–22 I.R.B. 1142 2000–53, 2000–22 I.R.B. 1144 2000–55, 2000–25 I.R.B. 1268 Court Decisions: 2066, 2000–15 I.R.B. 867 2067, 2000–15 I.R.B. 863 Notices: 2000–1, 2000–2 I.R.B. 288 2000–2, 2000–9 I.R.B. 727 2000–3, 2000–4 I.R.B. 413 2000–4, 2000–3 I.R.B. 313 Notices—continued: 2000–5, 2000–3 I.R.B. 314 2000–6, 2000–3 I.R.B. 315 2000–7, 2000–4 I.R.B. 419 2000–8, 2000–4 I.R.B. 420 2000–9, 2000–5 I.R.B. 449 2000–10, 2000–5 I.R.B. 451 2000–11, 2000–6 I.R.B. 572 2000–12, 2000–9 I.R.B. 727 2000–13, 2000–9 I.R.B. 732 2000–14, 2000–10 I.R.B. 737 2000–15, 2000–12 I.R.B. 826 2000–16, 2000–12 I.R.B. 826 2000–17, 2000–12 I.R.B. 827 2000–18, 2000–13 I.R.B. 845 2000–19, 2000–13 I.R.B. 845 2000–20, 2000–14 I.R.B. 851 2000–21, 2000–19 I.R.B. 967 2000–22, 2000–16 I.R.B. 902 2000–23, 2000–17 I.R.B. 952 2000–24, 2000–17 I.R.B. 952 2000–25, 2000–17 I.R.B. 954 2000–26, 2000–17 I.R.B. 954 2000–27, 2000–21 I.R.B. 1116 2000–28, 2000–21 I.R.B. 1116 2000–29, 2000–23 I.R.B. 1241 2000–30, 2000–25 I.R.B. 1266 Proposed Regulations: REG–208280–86, 2000–8 I.R.B. 654 REG–209135–88, 2000–8 I.R.B. 681 REG–208254–90, 2000–6 I.R.B. 577 REG–209601–92, 2000–12 I.R.B. 829 REG–100276–97, 2000–8 I.R.B. 682 REG–101492–98, 2000–3 I.R.B. 326 REG–106012–98, 2000–2 I.R.B. 290 REG–106186–98, 2000–23 I.R.B. 1226 REG–107644–98, 2000–23 I.R.B. 1229 REG–109101–98, 2000–16 I.R.B. 903 REG–110311–98, 2000–11 I.R.B. 767 REG–122450–98, 2000–8 I.R.B. 682 REG–103831–99, 2000–5 I.R.B. 452 REG–103882–99, 2000–8 I.R.B. 706 REG–105089–99, 2000–6 I.R.B. 580 REG–105279–99, 2000–8 I.R.B. 707 REG–105606–99, 2000–4 I.R.B. 421 REG–107872–99, 2000–16 I.R.B. 911 REG–111119–99, 2000–5 I.R.B. 455 REG–113572–99, 2000–7 I.R.B. 624 REG–116048–99, 2000–6 I.R.B. 584 REG–116567–99, 2000–5 I.R.B. 463 REG–116704–99, 2000–3 I.R.B. 325 REG–117162–99, 2000–15 I.R.B. 871 REG–100163–00, 2000–7 I.R.B. 633 REG–100291–00, 2000–16 I.R.B. 917 REG–103735–00, 2000–11 I.R.B. 770 REG–103736–00, 2000–11 I.R.B. 768 Railroad Retirement Quarterly Rate: 2000–9 I.R.B. 721 Revenue Procedures: 2000–1, 2000–1 I.R.B. 4 2000–2, 2000–1 I.R.B. 73 2000–3, 2000–1 I.R.B. 103 2000–4, 2000–1 I.R.B. 115 2000–5, 2000–1 I.R.B. 158 2000–6, 2000–1 I.R.B. 187 Revenue Procedures—continued: 2000–7, 2000–1 I.R.B. 227 2000–8, 2000–1 I.R.B. 230 2000–9, 2000–2 I.R.B. 280 2000–10, 2000–2 I.R.B. 287 2000–11, 2000–3 I.R.B. 309 2000–12, 2000–4 I.R.B. 387 2000–13, 2000–6 I.R.B. 515 2000–14, 2000–18 I.R.B. 960 2000–15, 2000–5 I.R.B. 447 2000–16, 2000–6 I.R.B. 518 2000–17, 2000–11 I.R.B. 766 2000–18, 2000–9 I.R.B. 722 2000–19, 2000–12 I.R.B. 785 2000–20, 2000–6 I.R.B. 553 2000–21, 2000–19 I.R.B. 971 2000–22, 2000–20 I.R.B. 1008 2000–23, 2000–21 I.R.B. 1018 2000–24, 2000–22 I.R.B. 1133 2000–25, 2000–21 I.R.B. 1033 2000–26, 2000–24 I.R.B. 1257 Revenue Rulings: 2000–1, 2000–2 I.R.B. 250 2000–2, 2000–3 I.R.B. 305 2000–3, 2000–3 I.R.B. 297 2000–4, 2000–4 I.R.B. 331 2000–5, 2000–5 I.R.B. 436 2000–6, 2000–6 I.R.B. 512 2000–7, 2000–9 I.R.B. 712 2000–8, 2000–7 I.R.B. 617 2000–9, 2000–6 I.R.B. 497 2000–10, 2000–8 I.R.B. 643 2000–11, 2000–10 I.R.B. 734 2000–12, 2000–11 I.R.B. 744 2000–13, 2000–12 I.R.B. 774 2000–14, 2000–12 I.R.B. 779 2000–15, 2000–12 I.R.B. 774 2000–16, 2000–12 I.R.B. 780 2000–17, 2000–13 I.R.B. 842 2000–18, 2000–14 I.R.B. 847 2000–19, 2000–14 I.R.B. 849 2000–20, 2000–16 I.R.B. 880 2000–21, 2000–16 I.R.B. 881 2000–22, 2000–16 I.R.B. 880 2000–23, 2000–19 I.R.B. 964 2000–24, 2000–19 I.R.B. 963 2000–25, 2000–20 I.R.B. 1006 2000–26, 2000–22 I.R.B. 1124 2000–27, 2000–21 I.R.B. 1016 2000–28, 2000–23 I.R.B. 1157 2000–29, 2000–24 I.R.B. 1249 2000–30, 2000–25 I.R.B. 1262 Tax Conventions: 2000–22 I.R.B. 1126 Treasury Decisions: 8849, 2000–2 I.R.B. 245 8850, 2000–2 I.R.B. 265 8851, 2000–2 I.R.B. 275 8852, 2000–2 I.R.B.253 8853, 2000–4 I.R.B.377 8854, 2000–3 I.R.B.306 8855, 2000–4 I.R.B.374 8856, 2000–3 I.R.B.298 8857, 2000–4 I.R.B.365 8858, 2000–4 I.R.B.332 8859, 2000–5 I.R.B.429 1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 1999–27 through 1999–52 is in Internal Revenue Bulletin 2000–1, dated January 3, 2000. 2000–26 I.R.B.iiiJune 26, 2000 Treasury Decisions—continued: 8860, 2000–5 I.R.B.437 8861, 2000–5 I.R.B.441 8862, 2000–6 I.R.B.466 8863, 2000–6 I.R.B.488 8864, 2000–7 I.R.B.614 8865, 2000–7 I.R.B.589 8866, 2000–6 I.R.B.495 8867, 2000–7 I.R.B.620 8868, 2000–6 I.R.B.491 8869, 2000–6 I.R.B.498 8870, 2000–8 I.R.B.647 8871, 2000–8 I.R.B.641 8872, 2000–8 I.R.B.639 8873, 2000–9 I.R.B.713 8874, 2000–8 I.R.B.644 8875, 2000–11 I.R.B.761 8876, 2000–11 I.R.B.753 8877, 2000–11 I.R.B.747 8878, 2000–15 I.R.B.857 8879, 2000–16 I.R.B.882 8880, 2000–20 I.R.B.1003 8881, 2000–23 I.R.B.1158 8882, 2000–23 I.R.B.1150 8883, 2000–23 I.R.B.1151 8884, 2000–24 I.R.B.1250 8885, 2000–25 I.R.B.1260 June 26, 2000iv2000–26 I.R.B. Finding List of Current Actions on Previously Published Items 1 Bulletins 2000–1 through 2000–25 Announcements: 99–40 Obsoleted by T.D. 8879, 2000–16 I.R.B. 882 99–50 Modified by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 99–59 Superseded by Announcement 2000–47, 2000–21 I.R.B. 1118 2000–18 Corrected by Announcement 2000–32, 2000–15 I.R.B. 878 Notices: 88–125 Obsoleted by T.D. 8870, 2000–8 I.R.B. 647 92–48 Obsoleted by Notice 2000–11, 2000–6 I.R.B. 572 97–19 Modified by Rev. Proc. 2000–1, 2000–1 I.R.B. 4 98–22 Obsoleted by T.D. 8870, 2000–8 I.R.B. 647 98–49 Modified by Notice 2000–30, 2000–25 I.R.B. 1266 98–52 Modified by Notice 2000–3, 2000–4 I.R.B. 413 98–61 Modified and superseded by Rev. Proc. 2000–15, 2000–5 I.R.B. 447 99–8 Obsoleted by Rev. Proc. 2000–12, 2000–4 I.R.B. 387 2000–4 Corrected by Announcement 2000–9, 2000–9 I.R.B. 733 Proposed Regulations: REG–209601–92 Corrected by Announcement 2000–40, 2000–16 I.R.B. 948 REG–100276–97 Corrected by Announcement 2000–38, 2000–16 I.R.B. 948 REG–101492–98 Corrected by Announcement 2000–16, 2000–12 I.R.B. 837 REG–122450–98 Corrected by Announcement 2000–38, 2000–16 I.R.B. 948 Proposed Regulations—Continued: REG–113572–99 Corrected by Announcement 2000–41, 2000–16 I.R.B. 949 REG–103736–00 Corrected by Announcement 2000–44, 2000–17 I.R.B. 958 Revenue Procedures: 80–18 Modified by Rev. Proc. 2000–13, 2000–6 I.R.B. 515 89–9 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 89–13 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 90–21 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 91–66 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 92–13 Modified, amplified, and superseded by Rev. Proc. 2000–11, 2000–3 I.R.B. 309 92–13A Modified, amplified, and superseded by Rev. Proc. 2000–11, 2000–3 I.R.B. 309 92–41 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 93–9 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 93–10 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 94–12 Modified, amplified, and superseded by Rev. Proc. 2000–11, 2000–3 I.R.B. 309 95–42 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 96–13 Modified by Rev. Proc. 2000–1, 2000–1 I.R.B. 4 98–22 Modified and superseded by Rev. Proc. 2000–16, 2000–6 I.R.B. 518 98–27 Superseded by Rev. Proc. 2000–12, 2000–4 I.R.B. 387 98–64 Superseded by Rev. Proc. 2000–9, 2000–2 I.R.B. 280 98–65 Superseded by Rev. Proc. 2000–19, 2000–12 I.R.B. 785 Revenue Procedures—Continued: 99–1 Superseded by Rev. Proc. 2000–1, 2000–1 I.R.B. 4 99–2 Superseded by Rev. Proc. 2000–2, 2000–1 I.R.B. 73 99–3 Superseded by Rev. Proc. 2000–3, 2000–1 I.R.B. 103 99–4 Superseded by Rev. Proc. 2000–4, 2000–1 I.R.B. 115 99–5 Superseded by Rev. Proc. 2000–5, 2000–1 I.R.B. 158 99–6 Superseded by Rev. Proc. 2000–6, 2000–1 I.R.B. 187 99–7 Superseded by Rev. Proc. 2000–7, 2000–1 I.R.B. 227 99–8 Superseded by Rev. Proc. 2000–8, 2000–1 I.R.B. 230 99–13 Modified and superseded by Rev. Proc. 2000–16, 2000–6 I.R.B. 518 99–20 Supplemented by Rev. Proc. 2000–14, 2000–18 I.R.B. 960 99–22 Obsoleted by (except as provided in section 5.02 of) Rev. Proc. 2000–21, 2000–19 I.R.B. 971 99–24 Superseded by Rev. Proc. 2000–23, 2000–21 I.R.B. 1018 99–25 Superseded by Rev. Proc. 2000–24, 2000–22 I.R.B. 1133 99–29 Superseded by Rev. Proc. 2000–25, 2000–21 I.R.B. 1033 99–31 Modified and superseded by Rev. Proc. 2000–16, 2000–6 I.R.B. 518 99–49 Modified and amplified by Rev. Rul. 2000–4, 2000–4 I.R.B. 331 Rev. Rul. 2000–7, 2000–9 I.R.B. 712 Notice 2000–4, 2000–3 I.R.B. 313 99–51 Superseded by Rev. Proc. 2000–3, 2000–1 I.R.B. 103 2000–6 Modified by Rev. Proc. 2000–20, 2000–6 I.R.B. 553 2000–8 Modified by Rev. Proc. 2000–16, 2000–6 I.R.B. 518 Rev. Proc. 2000–20, 2000–6 I.R.B. 553 1 A cumulative list of current actions on previously published items in Internal Revenue Bulletins 1999–27 through 1999–52 is in Internal Revenue Bulletin 2000–1, dated January 3, 2000. 2000–26 I.R.B.vJune 26, 2000 Revenue Procedures—Continued: 2000–12 Corrected by Announcement 2000–50, 2000–19 I.R.B. 998 2000–16 Corrected by Announcement 2000–17, 2000–13 I.R.B. 846 Revenue Rulings: 54–396 Obsoleted by T.D. 8885, 2000–25 I.R.B. 1260 57–259 Obsoleted by T.D. 8879, 2000–16 I.R.B. 882 57–499 Obsoleted by T.D. 8879, 2000–16 I.R.B. 882 73–292 Obsoleted by T.D. 8879, 2000–16 I.R.B. 882 76–79 Distinguised by Rev. Rul. 2000–24, 2000–19 I.R.B. 963 78–218 Obsoleted by T.D. 8879, 2000–16 I.R.B. 882 80–76 Obsoleted by T.D. 8883, 2000–23 I.R.B. 1151 86–62 Obsoleted by T.D. 8879, 2000–16 I.R.B. 882 88–36 Modified by Rev. Rul. 2000–6, 2000–6 I.R.B. 512 89–89 Obsoleted by Rev. Rul. 2000–2, 2000–3 I.R.B. 305 92–19 Supplemented by Rev. Rul. 2000–17, 2000–13 I.R.B. 842 98–30 Amplified and superseded by Rev. Rul. 2000–8, 2000–7 I.R.B. 617 Treasury Decisions: 8734 Modified by T.D. 8856, 2000–3 I.R.B. 298 8804 Modified by T.D. 8856, 2000–3 I.R.B. 298 8845 Corrected by Announcement 2000–6, 2000–4 I.R.B. 428 8846 Corrected by Announcement 2000–3, 2000–2 I.R.B. 296 8847 Corrected by Announcement 2000–13, 2000–11 I.R.B. 771 8849 Corrected by Announcement 2000–28, 2000–15 I.R.B. 876 8852 Corrected by Announcement 2000–18, 2000–13 I.R.B. 846 Treasury Decisions—continued: 8853 Corrected by Announcement 2000–33, 2000–15 I.R.B. 878 8856 Corrected by Announcement 2000–31, 2000–15 I.R.B. 877 8859 Corrected by Announcement 2000–27, 2000–15 I.R.B. 876 8864 Corrected by Announcement 2000–26, 2000–15 I.R.B. 876 8865 Corrected by Announcement 2000–37, 2000–16 I.R.B. 947 8867 Corrected by Announcement 2000–30, 2000–15 I.R.B. 877 8869 Corrected by Announcement 2000–36, 2000–16 I.R.B. 947 8870 Corrected by Announcement 2000–34, 2000–15 I.R.B. 879 8874 Corrected by Announcement 2000–29, 2000–15 I.R.B. 877 8879 Corrected by Announcement 2000–53, 2000–22 I.R.B. 1144 INTERNAL REVENUE BULLETIN The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue Bulletin is sold on a yearly subscription basis by the Superintendent of Documents. Current subscribers are notified by the Superintendent of Documents when their subscriptions must be renewed. CUMULATIVE BULLETINS The contents of this weekly Bulletin are consolidated semiannually into a permanent, indexed, Cumulative Bulletin. These are sold on a single copy basis and are not included as part of the subscription to the Internal Revenue Bulletin. Subscribers to the week- ly Bulletin are notified when copies of the Cumulative Bulletin are available. Certain issues of Cumulative Bulletins are out of print and are not available. Persons desiring available Cumulative Bulletins, which are listed on the reverse, may purchase them from the Superintendent of Documents. 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