Internal Revenue Bulletin 2001-22 (PDF rendition): IRS Revenue Procedures

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. 2001–24, page 1290.
Forward triangular merger. A controlling corporation’s
transfer of the acquiring corporation’s stock to another con-
trolled subsidiary as part of the plan of reorganization, fol-
lowing the merger of the acquired corporation with and into
the acquiring corporation, will not cause the transaction to
fail to qualify as a reorganization under sections 368(a)(1)(A)
and 368(a)(2)(D) of the Code.
Rev. Rul. 2001–25, page 1291.
Reverse triangular merger. A reverse triangular merger
qualifies as a tax-free reorganization under sections
368(a)(1)(A) and 368(a)(2)(E) of the Code, notwithstanding
that immediately after the merger, and as part of a plan that
includes the merger, the surviving corporation sells a portion
of its assets to an unrelated party for cash that it retains.
EXEMPT ORGANIZATIONS
Announcement 2001–61, page 1296.
Excess benefit transactions. This document contains
notice of a public hearing and submission of outlines of oral
comments on proposed regulations (REG–246256–96,
2001–8 I.R.B. 713) relating to excess benefit transactions.
The hearing is scheduled for July 31, 2001. Comments must
be received by July 10, 2001.
ADMINISTRATIVE
Rev. Proc. 2001–34, page 1293.
Qualified fuel under section 29(c)(1)(C). This procedure
modifies Rev. Proc. 2001–30 (2001–19 I.R.B. 1163) regard-
ing the circumstances under which the Service will issue pri-
vate letter rulings regarding solid synthetic fuels produced
from coal. Rev. Proc. 2001–30 modified.
Rev Proc. 2001–35, page 1293.
Qualified mortgage bonds; mortgage credit certifi-
cates; national median gross income.Guidance is pro-
vided concerning the use of the national and area median
gross income figures by issuers of qualified mortgage bonds
and mortgage credit certificates in determing the housing
cost/income ratio described in section 143(f) of the Code.
Rev. Proc. 2000–21 obsoleted except as provided in section
5.02 of this revenue procedure.
Announcement 2001–58, page 1295.
FOIA administrative appeals. Authority to respond to FOIA
administrative appeals has been transferred to the Chief,
Appeals, from the Assistant Chief Counsel (Disclosure &
Privacy Law). All FOIA administrative appeals must be filed
with the Chief, Appeals, at the address provided in this
announcement.
Internal Revenue
bbuulllleettiinn
Bulletin No. 2001–22
May 29, 2001
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.

May 29, 20012001–22 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
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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
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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
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clusions in other cases unless the facts and circumstances
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The Bulletin is divided into four parts as follows:
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This part includes rulings and decisions based on provisions
of the Internal Revenue Code of 1986.
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To the extent practicable, pertinent cross references to
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ing them understand and meet their tax responsibilities
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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.

May 29, 200112902001–22 I.R.B.
Section 25.—Interest on Certain
Home Mortgages
26 CFR 1.25–4T: Qualified mortgage credit
certificate program (temporary).
Guidance is provided for the use of the na-
tional and area median gross income figures by
issuers of qualified mortgage bonds and mort-
gage credit certificates in determining the hous-
ing cost/income ratio described in section
143(f)(5) of the Code. See Rev. Proc. 2001–35,
page 1293.
Section 29.—Credit for
Producing Fuel From a
Nonconventional Source
Under what circumstances may a taxpayer obtain
a private letter ruling under section 29(c)(1)(C) that
a solid fuel produced from coal is a qualified fuel?
See Rev. Proc. 2001–34, page 1293.
Section 368.—Definitions
Relating to Corporate
Reorganizations
26 CFR 1.368–1: Purpose and scope of exception
for reorganization exchanges.
Forward triangular merger.A con-
trolling corporation’s transfer of the ac-
quiring corporation’s stock to another
controlled subsidiary as part of the plan
of reorganization, following the merger
of the acquired corporation with and
into the acquiring corporation, will not
cause the transaction to fail to qualify as
a reorganization under sections
368(a)(1)(A) and 368(a)(2)(D) of the
Code.
Rev. Rul. 2001–24
ISSUE
Whether a controlling corporation’s
transfer of the acquiring corporation’s
stock to another subsidiary controlled by
the controlling corporation as part of the
plan of reorganization, following the
merger of the acquired corporation with
and into the acquiring corporation, will
cause the transaction to fail to qualify as a
reorganization under §§ 368(a)(1)(A) and
368(a)(2)(D) of the Internal Revenue
Code.
FACTS
Pursuant to a plan of reorganization,
corporation X merges with and into cor-
poration S, a newly organized wholly
owned subsidiary of P, a corporation un-
related to X, in a transaction intended to
qualify as a reorganization under
§§ 368(a)(1)(A) and 368(a)(2)(D). S con-
tinues the historic business of X following
the merger. Following the merger and as
part of the plan of reorganization, P trans-
fers the S stock to S1, a pre-existing,
wholly owned subsidiary of P. Without
regard to P’s transfer of the S stock to S1,
X’s merger with and into S qualifies as a
reorganization under §§ 368(a)(1)(A) and
368(a)(2)(D).
LAW AND ANALYSIS
Section 368(a)(1)(A) provides that the
term reorganization includes a statutory
merger or consolidation. Pursuant to
§ 368(a)(2)(D), the acquisition by one
corporation, in exchange for stock of a
corporation (the “controlling corpora-
tion”) that is in control (as defined in
§ 368(c)) of the acquiring corporation, of
substantially all of the properties of an-
other corporation (the “merged corpora-
tion”) shall not disqualify a transaction
under § 368(a)(1)(A) if -
(i) no stock of the acquiring corpora-
tion is used in the transaction, and
(ii) in the case of a transaction under
§ 368(a)(1)(A), such transaction would
have qualified under § 368(a)(1)(A) had
the merger been into the controlling cor-
poration.
Section 368(b) provides that a party to
a reorganization qualifying under
§§ 368(a)(1)(A) and 368(a)(2)(D) in-
cludes the merged corporation, the acquir-
ing corporation, and the controlling cor-
poration.
Section 368(a)(2)(C) provides that a
transaction otherwise qualifying under
§ 368(a)(1)(A), (1)(B), or (1)(C) is not
disqualified by reason of the fact that part
or all of the assets or stock which were ac-
quired in the transaction are transferred to
a corporation controlled (as defined by
§ 368(c)) by the corporation acquiring
such assets or stock.
Under § 1.368–2(f) of the Income Tax
Regulations, if a transaction otherwise
qualifies as a reorganization, a corpora-
tion remains a party to a reorganization
even though the stock or assets acquired
in the reorganization are transferred in a
transaction described in § 1.368–2(k).
Section 1.368–2(k)(1) restates the general
rule contained in § 368(a)(2)(C) but per-
mits the assets or stock acquired in the re-
organization to be successively trans-
ferred to one or more corporations
controlled (as defined under § 368(c)) in
each transfer by the transferor corporation
without disqualifying the reorganization.
Additionally, § 1.368–2(k)(2) provides
that a transaction qualifying under
§§ 368(a)(1)(A) and 368(a)(2)(E) is not
disqualified by reason of the fact that part
or all of the stock of the surviving corpo-
ration is transferred or successively trans-
ferred to one or more corporations con-
trolled in each transfer by the transferor
corporation, or because part or all of the
assets of the surviving corporation or the
merged corporation are transferred or suc-
cessively transferred to one or more cor-
porations controlled in each transfer by
the transferor corporation.
To qualify as a reorganization under
§ 368(a), a transaction must satisfy the
continuity of business enterprise require-
ment. Section 1.368–1(d)(1) requires that
the issuing corporation, in this case P,
must either continue the target corpora-
tion’s historic business or use a significant
portion of the target’s historic business as-
sets in a business in order for a reorgani-
zation to satisfy the continuity of business
enterprise requirement. The underlying
policy of this rule is to ensure that reorga-
nizations are limited to readjustments of
continuing interests in property under
modified corporate form. Pursuant to
§ 1.368–1(d)(4), the issuing corporation
(the controlling corporation in the case of
a § 368(a)(2)(D) reorganization) is treated
as holding all of the businesses and assets
of all of the members of its qualified
group. Section 1.368–1(d)(4)(ii) defines
a qualified group as one or more chains of
corporations connected through stock
ownership with the issuing corporation,
but only if the issuing corporation owns
directly stock meeting the requirements of
§ 368(c) in at least one other corporation,
and stock meeting the requirements of
§ 368(c) in each of the corporations (ex-
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

cept the issuing corporation) is owned di-
rectly by one of the other corporations.
Therefore, the issuing corporation is
treated as directly holding the businesses
and assets of second-tier and lower-tier
subsidiaries that are part of the qualified
group.
In applying these requirements to the
facts, the continuity of business enterprise
requirement is satisfied. Because S and
S1 are members of P’s qualified group, P
will be treated as directly holding the
businesses and assets of S. Therefore, be-
cause S will continue X’s historic busi-
ness following the merger, the transaction
will satisfy the continuity of business en-
terprise requirement of § 1.368–1(d).
The remaining issue is whether P’s
transfer of the S stock to S1 as part of the
plan of reorganization causes P to fail to
control S for purposes of § 368(a)(2)(D)
and causes P to fail to be a party to the re-
organization. Section 368(a)(2)(C) and
§ 1.368–2(k) do not specifically address
P’s transfer of the stock of S to S1 fol-
lowing an otherwise qualifying reorgani-
zation under §§ 368(a)(1)(A) and
368(a)(2)(D), because assets and not
stock were acquired in the reorganiza-
tion. If the transaction were recast under
the step transaction doctrine so that X’s
assets were viewed as being acquired by
a second-tier subsidiary of P, the transac-
tion would not qualify as a reorganization
under §§ 368(a)(1)(A) and 368(a)(2)(D)
because P would not control S. For the
reasons set forth below, the transaction
will not be recast under the step transac-
tion doctrine.
The legislative history of § 368(a)
(2)(E) suggests that forward and reverse
triangular mergers should be treated sim-
ilarly. SeeS. Rep. No. 1533, 91st Cong.,
2d Sess. 2 (1970). As discussed above,
pursuant to § 1.368–2(k)(2), a controlling
corporation in a merger that qualifies
under §§ 368(a)(1)(A) and 368(a)(2)(E)
may transfer the stock (or assets) of the
surviving corporation to a controlled sub-
sidiary without causing the transaction to
fail to qualify as a reorganization under
§§ 368(a)(1)(A) and 368(a)(2)(E). The
concept that forward and reverse triangu-
lar mergers should be treated similarly
supports permitting P to transfer the S
stock to S1 without causing the transac-
tion to fail to qualify as a reorganization
under §§ 368(a)(1)(A) and 368(a)(2)(D).
This concept also is reflected in the conti-
nuity of business enterprise regulations
under § 1.368–1(d), which do not distin-
guish between § 368(a)(2)(D) and
§ 368(a)(2)(E) reorganizations and do not
differentiate between whether stock or
assets are acquired.
Section 368(a)(2)(C) does not preclude
this transaction from qualifying as a reor-
ganization under §§ 368(a)(1)(A) and
368(a)(2)(D) because of the stock trans-
fer. By its terms, § 368(a)(2)(C) is a per-
missive rather than an exclusive or re-
strictive section. See, e.g., § 1.368–2(k);
Rev. Rul. 64–73, 1964–1 C.B. 142. Fur-
ther, § 368(a)(2)(C) and § 1.368–2(k)
similarly do not cause P to fail to be
treated as a party to the reorganization.
See Rev. Rul. 64–73.
Accordingly, for the reasons set forth
above, P’s transfer of the S stock to S1 as
part of the plan of reorganization, follow-
ing the merger of X with and into S, will
not cause P to be treated as not in control
of S for purposes of § 368(a)(2)(D). Ad-
ditionally, P will be treated as a party to
the reorganization.
HOLDING
A controlling corporation’s transfer of
the acquiring corporation’s stock to a sub-
sidiary controlled by the controlling cor-
poration as part of the plan of reorganiza-
tion, following the merger of the acquired
corporation with and into the acquiring
corporation, will not cause the transaction
to fail to qualify as a reorganization under
§§ 368(a)(1)(A) and 368(a)(2)(D).
DRAFTING INFORMATION
The principal authors of this revenue
ruling are Joseph Calianno and Marnie
Rapaport of the Office of Associate Chief
Counsel (Corporate). For further infor-
mation regarding this revenue ruling, con-
tact Mr. Calianno at (202) 622-7930 or
Ms. Rapaport at (202) 622-7550 (not a
toll-free call).
26 CFR 1.368–1: Purpose and scope of exception
of reorganization exchanges.
Reverse triangular merger. A reverse
triangular merger qualifies as a tax-free
reorganization under sections 368(a)
(1)(A) and 368(a)(2)(E) of the Code,
notwithstanding that immediately after
the merger, and as part of a plan that in-
cludes the merger, the surviving corpora-
tion sells a portion of its assets to an unre-
lated party for cash that it retains.
Rev. Rul. 2001–25
ISSUE
On the facts below, does a merger fail
to qualify as a tax-free reorganization
under §§ 368(a)(1)(A) and 368(a)(2)(E)
of the Internal Revenue Code if, immedi-
ately after the merger and as part of a plan
that includes the merger, the surviving
corporation sells a portion of its assets to
an unrelated party?
FACTS
P is a manufacturing corporation orga-
nized under the laws of state A. T is also
a manufacturing corporation organized
under the laws of state A. P organizes cor-
poration S as a wholly owned state A sub-
sidiary of P, and S merges with and into T
in a statutory merger under the laws of
state A. In the merger, the shareholders of
T holding 90 percent of the T stock ex-
change their T stock for voting stock of P.
The remaining shareholders of T receive
$y cash for their T stock. Immediately
after the merger and as part of a plan that
includes the merger, T sells 50 percent of
its operating assets for $z cash to X, an
unrelated corporation. After the sale of
the assets to X, T retains the sales pro-
ceeds. Without regard to the requirement
that T hold substantially all of the assets
of T and S, the merger satisfies all the
other requirements applicable to reorgani-
zations under §§ 368(a)(1)(A) and
368(a)(2)(E).
LAW AND ANALYSIS
Section 368(a)(1)(A) states that the
term “reorganization” means a statutory
merger or consolidation. Section
368(a)(2)(E) provides that a transaction
otherwise qualifying under § 368(a)
(1)(A) will not be disqualified by reason
of the fact that stock of a corporation (the
“controlling corporation”) that before the
merger was in control of the acquiring
corporation is used in the transaction, if
(1) after the transaction, the corporation
surviving the merger holds substantially
all of its properties and of the properties
2001–22 I.R.B.1291May 29, 2001

May 29, 200112922001–22 I.R.B.
of the merged corporation (other than
stock of the controlling corporation dis-
tributed in the transaction), and (2) in the
transaction, former shareholders of the
surviving corporation exchanged, for an
amount of voting stock of the controlling
corporation, an amount of stock in the
surviving corporation that constitutes
control of such corporation.
Section 1.368–2(j)(3)(iii) of the In-
come Tax Regulations provides that, for
purposes of § 368(a)(2)(E), “[t]he term
‘substantially all’ has the same meaning
as in section 368(a)(1)(C).”
Rev. Rul. 88–48, 1988–1 C.B. 117,
holds that the requirement of
§ 368(a)(1)(C) that the acquiring corpora-
tion acquire “substantially all” of the
properties of a target corporation is satis-
fied when immediately prior to the target
corporation’s transfer of assets to the ac-
quiring corporation, the target corporation
sells 50 percent of its historic assets to un-
related parties for cash and immediately
transfers that cash, along with its other
properties, to the acquiring corporation.
Section 368(a)(2)(E) uses the term
“holds” rather than the term “acquisition”
as do §§ 368(a)(1)(C) and 368(a)(2)(D)
because it would be inapposite to require
the surviving corporation to “acquire” its
own properties. The “holds” requirement
of § 368(a)(2)(E) does not impose re-
quirements on the surviving corporation
before and after the merger that would not
have applied had such corporation trans-
ferred its properties to another corpora-
tion in a reorganization under § 368(a)
(1)(C) or a reorganization under §§ 368(a)
(1)(A) and 368(a)(2)(D).
In this case, T’s post-merger sale of 50
percent of its operating assets for cash to
X prevents T from holding substantially
all of its historic business assets immedi-
ately after the merger. As in Rev. Rul.
88–48, however, the sales proceeds con-
tinue to be held by T. Therefore, the
post-acquisition sale of 50 percent of T’s
operating assets where T holds the pro-
ceeds of such sale along with its other
operating assets does not cause the
merger to violate the requirement of
§ 368(a)(2)(E) that the surviving corpo-
ration hold substantially all of its proper-
ties after the transaction.
Accordingly, the merger qualifies as a
reorganization under §§ 368(a)(1)(A) and
368(a)(2)(E), notwithstanding the sale by
T of a portion of its assets to X immedi-
ately after the merger and as part of a plan
that includes the merger.
HOLDING
On the facts above, a merger qualifies
as a tax-free reorganization under §§ 368
(a)(1)(A) and 368(a)(2)(E), notwithstand-
ing the fact that the surviving corporation
sells a portion of its assets to an unrelated
party immediately after the merger and as
part of a plan that includes the merger.
DRAFTING INFORMATION
The principal authors of this revenue
ruling are Marnie Rapaport and Joseph
M. Calianno of the Office of Associate
Chief Counsel (Corporate). For further
information regarding this revenue ruling,
contact Ms. Rapaport at (202) 622-7550
(not a toll-free call) or Mr. Calianno at
(202) 622-7930 (not a toll-free call).

26 CFR 601.201: Rulings and determination letters.
(Also Part I, §29.)
Rev. Proc. 2001–34
SECTION 1. PURPOSE
.01 This revenue procedure modifies
Rev. Proc. 2001–30, 2001–19 I.R.B.
1163, which provides the circumstances
under which the Internal Revenue Service
will issue private letter rulings regarding
whether a solid fuel produced from coal is
a qualified fuel under § 29(c)(1)(C) of the
Internal Revenue Code. The circum-
stances necessary for the Service to issue
a private letter ruling include the presence
of coal feedstock particles no larger than a
specific size, and the performance of spe-
cific activities in processing the feedstock
in order to effectuate a significant chemi-
cal change.
.02 Rev. Proc. 2001–30 is modified to
expand the range of sizes of coal feed-
stock and to eliminate one particular ac-
tivity as a necessary part of a process that
results in a qualified fuel.
SECTION 2. MODIFICATIONS
.01 Section 3 of Rev. Proc. 2001–30 is
modified by deleting the word “entirely”
after the phrase “The feedstock coal con-
sists”, adding the phrase “the majority of
which, by weight, are” after the word
“particles”, and substituting “3/8” for
“1/8” in the first condition.
.02 Section 3 of Rev. Proc. 2001–30 is
also modified by deleting the phrase “fol-
lowing an acid bath” after the word
“monomers” in the second condition.
.03 Section 3 of Rev. Proc. 2001–30,
as modified, is set forth below as Section
3 of this revenue procedure.
SECTION 3. PROCEDURE
The Service will issue rulings that a
solid fuel (other than coke) produced
from coal is a qualified fuel under
§ 29(c)(1)(C) if the conditions set forth
below are satisfied and evidence is pre-
sented that all, or substantially all, of the
coal used as feedstock undergoes a signif-
icant chemical change. The conditions
are that:
1. The feedstock coal consists of coal
fines or crushed coal comprised of parti-
cles the majority of which, by weight, are
no larger than 3/8 inch;
2. The feedstock coal is thoroughly
mixed in a mixer: (a) with styrene or other
monomers, (b) with quinoline (C
9
H
7
N) or
other organic resin and left to cure for
several days, (c) with ultra heavy hydro-
carbons, or (d) with an aluminum and/or
magnesium silicate binder following heat-
ing to a minimum temperature of 500 de-
grees Fahrenheit; and
3. The treated feedstock is subjected to
elevated temperature and pressure that re-
sults in briquettes, pellets, or an extruded
fuel product, or the taxpayer represents
that the omission of this procedure will
not significantly increase the production
of the facility over the remainder of the
period during which the § 29 credit is al-
lowable.
SECTION 4. EFFECTIVE DATE
This revenue procedure applies to all
ruling requests, including any pending in
the national office and any submitted after
the date of publication of this revenue
procedure.
SECTION 5. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2001–30 is modified.
DRAFTING INFORMATION
The principal author of this revenue
procedure is David McDonnell of the
Office of Associate Chief Counsel
(Passthroughs and Special Industries).
Other personnel from the IRS and Trea-
sury participated in its development. For
further information regarding this revenue
procedure, contact Mr. McDonnell at
(202) 622-3120 (not a toll-free call).
26 CFR 601.201: Rulings and determination
letters.
(Also Part I, Sections 25, 103, 143; 1.25–4T,
1.103–1, 6a.103A–2.)
Rev. Proc. 2001–35
SECTION 1. PURPOSE
This revenue procedure provides guid-
ance concerning the United States and
area median gross income figures that are
to be used by issuers of qualified mort-
gage bonds, as defined in § 143(a) of the
Internal Revenue Code, and issuers of
mortgage credit certificates, as defined in
§ 25(c), in computing the housing cost/in-
come ratio described in § 143(f)(5).
SECTION 2. BACKGROUND
.01 Section 103(a) provides that, except
as provided in § 103(b), gross income
does not include interest on any state or
local bond. Section 103(b)(1) provides
that § 103(a) shall not apply to any private
activity bond that is not a “qualified
bond” within the meaning of § 141. Sec-
tion 141(e) provides that the term “quali-
fied bond” includes any private activity
bond that (1) is a qualified mortgage
bond, (2) meets the volume cap require-
ments under § 146, and (3) meets the ap-
plicable requirements under § 147.
.02 Section 143(a)(1) provides that the
term “qualified mortgage bond” means a
bond that is issued as part of a “qualified
mortgage issue”. Section 143(a)(2)(A)
provides that the term “qualified mort-
gage issue” means an issue of one or more
bonds by a state or political subdivision
thereof, but only if (i) all proceeds of the
issue (exclusive of issuance costs and a
reasonably required reserve) are to be
used to finance owner-occupied resi-
dences; (ii) the issue meets the require-
ments of subsections (c), (d), (e),
(f), (g), (h), (i), and (m)(7) of § 143; (iii)
the issue does not meet the private busi-
ness tests of paragraphs (1) and (2) of
§ 141(b); and (iv) with respect to amounts
received more than 10 years after the date
of issuance, repayments of $250,000 or
more of principal on financing provided
by the issue are used not later than the
close of the first semi-annual period be-
ginning after the date the prepayment (or
complete repayment) is received to re-
deem bonds that are part of the issue.
.03 Section 143(f) imposes eligibility
requirements concerning the maximum in-
come of mortgagors for whom financing
may be provided by qualified mortgage
bonds. Section 25(c)(2)(A)(iii)(IV) pro-
vides that recipients of mortgage credit
certificates must meet the income require-
ments of § 143(f). Generally, under
§§ 143(f)(1) and 25(c)(2)(A)(iii)(IV),
2001–22 I.R.B.1293May 29, 2001
Part III. Administrative, Procedural, and Miscellanous

these income requirements are met only if
all owner-financing under a qualified
mortgage bond and all certified indebted-
ness amounts under a mortgage credit cer-
tificate program are provided to mort-
gagors whose family income is 115
percent or less of the applicable median
family income. Under § 143(f)(6), the in-
come limitation is reduced to 100 percent
of the applicable median family income if
there are fewer than three individuals in
the family of the mortgagor.
.04 Section 143(f)(4) provides that the
term “applicable median family income”
means the greater of (A) the area median
gross income for the area in which the
residence is located or (B) the statewide
median gross income for the state in
which the residence is located.
.05 Section 143(f)(5) provides for an
upward adjustment of the income limita-
tions in certain high housing cost areas.
Under § 143(f)(5)(C), a high housing cost
area is a statistical area for which the
housing cost/income ratio is greater than
1.2. The housing cost/income ratio is de-
termined under § 143(f)(5)(D) by divid-
ing (a) the applicable housing price ratio
by (b) the ratio that the area median gross
income bears to the median gross income
for the United States. The applicable
housing price ratio is the new housing
price ratio (new housing average purchase
price for the area divided by the new
housing average purchase price for the
United States) or the existing housing
price ratio (existing housing average area
purchase price divided by the existing
housing average purchase price for the
United States), whichever results in the
housing cost/income ratio being closer to
1. This income adjustment applies only
to bonds issued and nonissued bond
amounts elected after December 31, 1988.
.06 The Department of Housing and
Urban Development (HUD) has com-
puted the median gross income for the
United States, the states, and statistical
areas within the states. The income infor-
mation was released to the HUD regional
offices on April 6, 2001, and may be ob-
tained by calling the HUD reference ser-
vice at 1-800-245-2691. The income in-
formation is also available at HUD’s
World Wide Web site, http:\\huduser.org
\datasets\il.html,which provides a menu
from which you may select the year and
type of data of interest. The Internal Rev-
enue Service annually publishes only the
median gross income for the United
States.
.07 The most recent nationwide aver-
age purchase prices and average area pur-
chase price safe harbor limitations were
published on September 6, 1994, in Rev.
Proc. 94–55, 1994–2 C.B. 716.
SECTION 3. APPLICATION
.01 When computing the housing
cost/income ratio under § 143(f)(5), is-
suers of qualified mortgage bonds and
mortgage credit certificates must use
$52,500 as the median gross income for
the United States. See section 2.06 of this
revenue procedure.
.02 When computing the housing
cost/income ratio under § 143(f)(5), is-
suers of qualified mortgage bonds and
mortgage credit certificates must use the
area median gross income figures re-
leased by HUD on April 6, 2001. See sec-
tion 2.06 of this revenue procedure.
SECTION 4. EFFECT ON OTHER
REVENUE PROCEDURES
.01 Rev. Proc. 2000–21, 2000–1 C.B.
971, is obsolete except as provided in sec-
tion 5.02 of this revenue procedure.
.02 This revenue procedure does not af-
fect the effective date provisions of Rev.
Rul. 86–124, 1986–2 C.B. 27. Those ef-
fective date provisions will remain opera-
tive at least until the Service publishes a
new revenue ruling that conforms the ap-
proach to effective dates set forth in Rev.
Rul. 86–124 to the general approach
taken in this revenue procedure.
SECTION 5. EFFECTIVE DATES
.01 Issuers must use the United States
and area median gross income figures
specified in section 3 of this revenue pro-
cedure for commitments to provide fi-
nancing that are made, or (if the purchase
precedes the financing commitment) for
residences that are purchased, in the pe-
riod that begins on April 6, 2001, and
ends on the date when these United States
and area median gross income figures are
rendered obsolete by a new revenue pro-
cedure.
.02 Notwithstanding section 5.01 of
this revenue procedure, issuers may con-
tinue to rely on the United States and area
median gross income figures specified in
Rev. Proc. 2000–21 with respect to bonds
originally sold and nonissued bond
amounts elected not later than June 28,
2001, if the commitments or purchases
described in section 5.01 are made not
later than August 27, 2001.
DRAFTING INFORMATION
The principal author of this revenue
procedure is Allan B. Seller of the Office
of Assistant Chief Counsel (Exempt Or-
ganizations/Employment Tax/Govern-
ment Entities). For further information
regarding this revenue procedure contact
Mr. Seller at (202) 622-3980 (not a toll-
free call).
May 29, 200112942001–22 I.R.B.

2001–22 I.R.B.1295May 29, 2001
FOIA Administrative Appeals
Transferred to Appeals
Announcement 2001–58
SUMMARY: Responsibility for an ad-
ministrative appeal under the Freedom of
Information Act from a denial of a request
for information, for a fee waiver, for de-
termination of a favorable fee category, or
for expedited processing by a disclosure
officer of the Internal Revenue Service
(i.e., a FOIA administrative appeal) has
been transferred to the Chief, Appeals
(Appeals). Previously, the Assistant
Chief Counsel (Disclosure & Privacy
Law) was responsible for the FOIA ad-
ministrative appeal function. The Service
transferred responsibility as a result of the
reorganization and restructuring of the In-
ternal Revenue Service. Under this new
transfer of authority, the requester and
Appeals will now attempt to resolve any
disputed request under its jurisdiction for
information, fee waiver, fee category, or
expedited processing pursuant to the
Freedom of Information Act. This proce-
dure is effective for requests received on
or after January 15, 2001. Because Ap-
peals will expand its jurisdiction by this
transfer of authority, we welcome com-
ments on the process. Comments should
be submitted to:
Internal Revenue Service
Bailey’s Crossroads Appeals Office,
Attn: FOIA Coordinator
One Skyline Place – Suite 803
5205 Leesburg Pike
Bailey’s Crossroads, VA 22041
BACKGROUND: Previously, FOIA
administrative appeals were considered
by the Office of Assistant Chief Counsel
(Disclosure & Privacy Law). A recom-
mendation of the Treasury Inspector
General for Tax Administration empha-
sized that the Service should find ways
to timely respond to FOIA administra-
tive appeals. IRS management agreed
with the recommendation; the IRS’
Modernization Plan calls for the transfer
of FOIA administrative appeal responsi-
bility from the Office of Chief Counsel
to Appeals.
OVERVIEW: Appeals has been dele-
gated the authority to respond to FOIA
administrative appeals by the Commis-
sioner. SeeDelegation Order 165 (Rev. 8)
dated October 2, 2000. The mission of
Appeals is to resolve tax controversies,
without litigation, on a basis which is fair
and impartial to both the Government and
the requester. A FOIA administrative ap-
peal is an optional process, initiated by
the requester, where Appeals will provide
a requester with a fair and impartial inde-
pendent determination based upon the
facts and the law.
ORGANIZATIONAL PLACEMENT OF
FOIA ADMINISTRATIVE APPEALS:
The authority to determine FOIA admin-
istrative appeals are placed in Appeals
under the Director, Office of Small Busi-
ness/Self-Employment and Tax Ex-
empt/Governmental Entities. The Chief,
Appeals will provide line authority over
Appeals’ operations and, thus, promote
uniformity and consistency in determina-
tions made under this new appeal author-
ity.
Procedure for Requesting a FOIA
Administrative Appeal
SUMMARY: A FOIA administrative ap-
peal is an independent “fresh look” of an
initial denial of a person’s request for ac-
cess to records, fee waiver, fee category,
or expedited processing under the Free-
dom of Information Act. The initial
FOIA request may be filed with the Inter-
nal Revenue Service at the national head-
quarters, an area office, or a service or
compliance campus. However, a FOIA
administrative appeal mustbe filed with
the Chief, Appeals at the following ad-
dress:
Internal Revenue Service
Richmond Appeals Office –
FOIA Appeal
2727 Enterprise Parkway Suite100
Richmond, VA 23229
SCOPE AND MANNER OF THE FOIA
ADMINISTRATIVE APPEAL: Gener-
ally, effective January 15, 2001, Appeals
has jurisdiction over all FOIA administra-
tive appeals. Some FOIA administrative
appeals received by the Internal Revenue
Service prior to the effective date will re-
main with the Assistant Chief Counsel
(Disclosure & Privacy Law) until com-
pleted. Appeals will respond to certain
FOIA administrative appeals received
prior to the effective date; those re-
questers will be notified by Appeals that
jurisdiction for a response has been trans-
ferred.
A FOIA administrative appeal is made by
filing a letter of appeal to the initial ad-
verse determination letter sent to the re-
quester by a disclosure officer of the In-
ternal Revenue Service. The format for
an appeal is prescribed in the Statement of
Procedural Rules, 26 CFR § 601.702
(c)(8). A FOIA administrative appeal
shall at a minimum specify the date of the
request, the office to which the request
was submitted, the date of the adverse de-
termination letter, and, where possible,
enclose a copy of the initial request and
the adverse determination letter being ap-
pealed.
Disputes of factual matters should include
a statement in writing of the requester’s
view of the facts. Factual matters con-
cern, for example, facts establishing:
• existence of a record;
• fee category of the requester;
• support for a fee waiver determination;
or
• support for a statutory expedited pro-
cessing.
If there is a disagreement as to the matter
of law or other authority, the requester
should state the reason or reasons in writ-
ing for the requester’s position. The rea-
soning may be based on what the re-
quester believes is logical and fair.
Consideration of the appeal is enhanced
and facilitated by including references to
supporting authorities, such as the applic-
able sections of the Freedom of Informa-
tion Act, Treasury regulations, court cases
and policies of the IRS.
The Freedom of Information Act created a
right of access to records, not a right to
personal services. Appeals will not re-
spond to questions that ask the Service to
justify tax policy or law, or similar discus-
sions, nor will Appeals answer questions
about a person’s tax liability in the form
of a FOIA administrative appeal. Many
Internal Revenue Service publications are
available to the public that answer tax
Part IV. Items of General Interest

questions and explain Service policies.
These documents will help persons mak-
ing FOIA administrative appeals under-
stand matters concerning their personal
obligation and liability to pay federal
taxes. In addition, the Service has many
Taxpayer Service personnel that will help
persons making FOIA administrative ap-
peals understand the specific documents
available and how to locate these docu-
ments. Finally, the Internal Revenue
Manual is available for public inspection
in the Internal Revenue Services Freedom
of Information Reading Room.
ISSUES NOT WITHIN APPEALS’ JU-
RISDICTION: Under the Department of
Treasury regulations, the following cir-
cumstances do not give rise to a FOIA ad-
ministrative appeal and are not within the
jurisdiction of Appeals:
• the lack of a timely response from an
initial request;
• a reply to the FOIA request which
states that the Freedom of Information
Act does not require the IRS to provide
explanations or answers in response to
questions concerning tax policies or
tax law; or
• a request for matters that the Internal
Revenue Service has published in the
Federal Register or is required to be
made available for public inspection in
its Freedom of Information Reading
Room, 1111 Constitution Avenue,
N.W., Washington, D.C. The public
should be aware that much of this ma-
terial is available for public inspection
on the Service’s Electronic Freedom
of Information Reading Room
(www.irs.gov/efoia).
If the Internal Revenue Service has not
timely responded to the requester, the law
permits the requester to file a lawsuit in
the United States District Court in the ju-
dicial district in which the requester lives
or works, or where the records subject to
the request are located, or in the District
of Columbia.
EFFECTIVE DATE: The effective date
for Appeals jurisdiction is January 15,
2001.
FOR FURTHER INFORMATION CON-
TACT: Theodore J. Cichaski, Appeals Free-
dom of Information Act Coordinator at 703-
756-6697 Ext. 18 (not a toll-free number).
Failure by Certain Charitable
Organizations to Meet Certain
Qualification Requirements;
Taxes on Excess Benefit
Transactions; Hearing
Announcement 2001–61
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of public hearing on
proposed rulemaking.
SUMMARY: This document contains a
notice of public hearing on proposed reg-
ulations (REG–246256–96, 2001–8
I.R.B. 713) relating to charitable organi-
zations to meet certain qualification re-
quirements and taxes on excess benefit
transactions.
DATES: The public hearing is being held
on July 31, 2001, at 10 a.m. The IRS
must receive outlines of topics to be dis-
cussed at the hearing by July 10, 2001.
ADDRESSES: The public hearing is
being held in the auditorium, room 7218,
Internal Revenue Building, 1111 Consti-
tution Avenue NW., Washington, DC.
Due to building security procedures, visi-
tors must enter at the 10th Street entrance,
located between Constitution and Penn-
sylvania Avenues, NW. In addition, all
visitors must present photo identification
to enter the building.
Mail outlines to: Regulations Unit
CC (REG–246256–96), room 5226, In-
ternal Revenue Service, POB 7604,
Ben Franklin Station, Washington, DC
20044. Hand deliver outlines Monday
through Friday between the hours of 8
a.m. and 5 p.m. to: Regulations Unit
CC (REG–246256–96), Courier’s
Desk, Internal Revenue Service, 1111
Constitution Avenue NW., Washington,
DC. Submit electronic outlines of oral
comments directly to the IRS Internet
site at http://www.irs.gov/tax_regs/
regslist.html.
FOR FURTHER INFORMATION CON-
TACT: Concerning submissions of com-
ments, the hearing, and/or to be placed on
the building access list to attend the hear-
ing, Guy R. Traynor of the Regulations
Unit (202) 622-7180 (not a toll-free num-
ber).
SUPPLEMENTARY INFORMATION:
The subject of the public hearing is the
notice of proposed regulations (REG–
246256–96) that was published in the
Federal Registeron Wednesday, January
10, 2001 (66 FR 2173).
The rules of 26 CFR 601.601(a)(3)
apply to the hearing.
Persons who have submitted written
comments and wish to present oral com-
ments at the hearing must submit an out-
line of the topics to be discussed and the
amount of time to be devoted to each
topic (signed original and eight (8)
copies) by July 10, 2001.
A period of 10 minutes is allotted to
each person for presenting oral com-
ments.
After the deadline for receiving out-
lines has passed, the IRS will prepare an
agenda containing the schedule of speak-
ers. Copies of the agenda will be made
available, free of charge, at the hearing.
Because of access restrictions, the IRS
will not admit visitors beyond the imme-
diate entrance area more than 15 minutes
before the hearing starts. For information
about having your name placed on the
building access list to attend the hearing,
see the “FOR FURTHER INFORMA-
TION CONTACT” section of this docu-
ment.
Cynthia E. Grigsby,
Chief, Regulations Unit,
Office of Special Counsel
(Modernization & Strategic Planning).
(Filed by the Office of the Federal Register on May
14, 2001, 8:45 a.m., and published in the issue of the
Federal Register for May 15, 2001, 66 F.R. 26824)
May 29, 200112962001–22 I.R.B.

2001–22 I.R.B.iMay 29, 2001
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”)
that have an effect on previous rulings
use the following defined terms to de-
scribe the effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus,
if an earlier ruling held that a principle
applied to A, and the new ruling holds
that the same principle also applies to B,
the earlier ruling is amplified. (Compare
with modified, below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously
published ruling and points out an essen-
tial difference between them.
Modified is used where the substance
of a previously published position is
being changed. Thus, if a prior ruling
held that a principle applied to A but not
to B, and the new ruling holds that it ap-
plies to both A and B, the prior ruling is
modified because it corrects a published
position. (Compare with amplified and
clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used
in a ruling that lists previously published
rulings that are obsoleted because of
changes in law or regulations. A ruling
may also be obsoleted because the sub-
stance has been included in regulations
subsequently adopted.
Revoked describes situations where the
position in the previously published rul-
ing is not correct and the correct position
is being stated in the new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a pe-
riod of time in separate rulings. If the
new ruling does more than restate the
substance of a prior ruling, a combination
of terms is used. For example, modified
and superseded describes a situation
where the substance of a previously pub-
lished ruling is being changed in part and
is continued without change in part and it
is desired to restate the valid portion of
the previously published ruling in a new
ruling that is self contained. In this case
the previously published ruling is first
modified and then, as modified, is super-
seded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and
that list is expanded by adding further
names in subsequent rulings. After the
original ruling has been supplemented
several times, a new ruling may be pub-
lished that includes the list in the original
ruling and the additions, and supersedes
all prior rulings in the series.
Suspended is used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current use and for-
merly used will appear in material published in the
Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security
Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign Corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statements of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Definition of Terms

May 29, 2001ii2001–22 I.R.B.
Numerical Finding List
1
Bulletins 2001–1 through 2001–21
Announcements:
2001–1, 2001–2 I.R.B. 277
2001–2, 2001–2 I.R.B. 277
2001–3, 2001–2 I.R.B. 278
2001–4, 2001–2 I.R.B. 286
2001–5, 2001–2 I.R.B. 286
2001–6, 2001–3 I.R.B. 357
2001–7, 2001–3 I.R.B. 357
2001–8, 2001–3 I.R.B. 357
2001–9, 2001–3 I.R.B. 357
2001–10, 2001–4 I.R.B. 431
2001–11, 2001–4 I.R.B. 432
2001–12, 2001–6 I.R.B. 526
2001–13, 2001–96 I.R.B. 752
2001–14, 2001–7 I.R.B. 648
2001–15, 2001–8 I.R.B. 715
2001–16, 2001–8 I.R.B. 715
2001–17, 2001–8 I.R.B. 716
2001–18, 2001–10 I.R.B. 791
2001–19, 2001–10 I.R.B. 791
2001–20, 2001–8 I.R.B. 716
2001–21, 2001–9 I.R.B. 752
2001–22, 2001–11 I.R.B. 895
2001–23, 2001–10 I.R.B. 791
2001–24, 2001–10 I.R.B. 793
2001–25, 2001–11 I.R.B. 895
2001–26, 2001–11 I.R.B. 896
2001–27, 2001–11 I.R.B. 897
2001–28, 2001–13 I.R.B. 975
2001–29, 2001–14 I.R.B. 1014
2001–30, 2001–15 I.R.B. 1065
2001–31, 2001–17 I.R.B. 1113
2001–32, 2001–17 I.R.B. 1113
2001–33, 2001–17 I.R.B. 1136
2001–34, 2001–16 I.R.B. 1087
2001–35, 2001–16 I.R.B. 1087
2001–36, 2001–16 I.R.B. 1089
2001–37, 2001–16 I.R.B. 1090
2001–38, 2001–17 I.R.B. 1137
2001–39, 2001–17 I.R.B. 1141
2001–40, 2001–17 I.R.B. 1141
2001–41, 2001–18 I.R.B. 1147
2001–42, 2001–18 I.R.B. 1147
2001–43, 2001–18 I.R.B. 1147
2001–44, 2001–18 I.R.B. 1148
2001–45, 2001–18 I.R.B. 1148
2001–46, 2001–19 I.R.B. 1165
2001–47, 2001–19 I.R.B. 1165
2001–48, 2001–19 I.R.B. 1168
2001–49, 2001–20 I.R.B. 1183
2001–50, 2001–20 I.R.B. 1184
2001–51, 2001–20 I.R.B. 1185
2001–52, 2001–20 I.R.B. 1186
2001–53, 2001–20 I.R.B. 1186
2001–54, 2001–21 I.R.B. 1284
2001–55, 2001–21 I.R.B. 1284
2001–56, 2001–21 I.R.B. 1286
2001–57, 2001–21 I.R.B. 1187
2001–60, 2001–21 I.R.B. 1287
Court Decisions:
2069, 2001–21 I.R.B. 1191
Notices:
2001–1, 2001–2 I.R.B. 261
2001–2, 2001–2 I.R.B. 265
2001–3, 2001–2 I.R.B. 267
Notices—Continued:
2001–4, 2001–2 I.R.B. 267
2001–5, 2001–3 I.R.B. 327
2001–6, 2001–3 I.R.B. 327
2001–7, 2001–4 I.R.B. 374
2001–8, 2001–4 I.R.B. 374
2001–9, 2001–4 I.R.B. 375
2001–10, 2001–5 I.R.B. 459
2001–11, 2001–5 I.R.B. 464
2001–12, 2001–3 I.R.B. 328
2001–13, 2001–6 I.R.B. 514
2001–14, 2001–6 I.R.B. 516
2001–15, 2001–7 I.R.B. 589
2001–16, 2001–9 I.R.B. 730
2001–17, 2001–9 I.R.B. 730
2001–18, 2001–9 I.R.B. 731
2001–19, 2001–10 I.R.B. 784
2001–20, 2001–11 I.R.B. 818
2001–21, 2001–11 I.R.B. 818
2001–22, 2001–12 I.R.B. 911
2001–23, 2001–12 I.R.B. 911
2001–24, 2001–12 I.R.B. 912
2001–25, 2001–13 I.R.B. 941
2001–26, 2001–13 I.R.B. 942
2001–27, 2001–13 I.R.B. 942
2001–28, 2001–13 I.R.B. 944
2001–29, 2001–14 I.R.B. 989
2001–30, 2001–14 I.R.B. 989
2001–31, 2001–17 I.R.B. 1093
2001–32, 2001–18 I.R.B. 1146
2001–33, 2001–19 I.R.B. 1155
Proposed Regulations:
LR–230–76, 2001–13 I.R.B. 945
REG–209461–79, 2001–8 I.R.B. 712
REG–246256–96, 2001–8 I.R.B. 713
REG–251701–96, 2001–4 I.R.B. 396
REG–101520–97, 2001–15 I.R.B. 1057
REG–106030–98, 2001–11 I.R.B. 820
REG–106446–98, 2001–13 I.R.B. 945
REG–106542–98, 2001–5 I.R.B. 473
REG–121928–98, 2001–6 I.R.B. 520
REG–109481–99, 2001–13 I.R.B. 961
REG–111835–99, 2001–11 I.R.B. 834
REG–114998–99, 2001–14 I.R.B. 992
REG–115560–99, 2001–14 I.R.B. 993
REG–101739–00, 2001–14 I.R.B. 996
REG–103320–00, 2001–8 I.R.B. 714
REG–104683–00, 2001–4 I.R.B. 407
REG–104876–00, 2001–14 I.R.B. 998
REG–105801–00, 2001–13 I.R.B. 965
REG–105946–00, 2001–16 I.R.B. 1069
REG–106513–00, 2001–16 I.R.B. 1076
REG–106702–00, 2001–4 I.R.B. 424
REG–106791–00, 2001–6 I.R.B. 521
REG–106892–00, 2001–15 I.R.B. 1060
REG–107047–00, 2001–14 I.R.B. 1002
REG–107101–00, 2001–16 I.R.B. 1083
REG–107175–00, 2001–13 I.R.B. 971
REG–107176–00, 2001–4 I.R.B. 428
REG–107186–00, 2001–13 I.R.B. 973
REG–107566–00, 2001–3 I.R.B. 346
REG–110374–00, 2001–12 I.R.B. 915
REG–110659–00, 2001–12 I.R.B. 917
REG–114082–00, 2001–7 I.R.B. 629
REG–114083–00, 2001–7 I.R.B. 630
REG–114084–00, 2001–7 I.R.B. 633
REG–116468–00, 2001–6 I.R.B. 522
REG–119352–00, 2001–6 I.R.B. 525
REG–121109–00, 2001–15 I.R.B. 1064
REG–125237–00, 2001–12 I.R.B. 919
REG–126100–00, 2001–11 I.R.B. 862
Proposed Regulations—Continued:
REG–129608–00, 2001–14 I.R.B. 1011
REG–130477–00, 2001–11 I.R.B. 865
REG–130481–00, 2001–11 I.R.B. 865
REG–119436–01, 2001–20 I.R.B. 1183
Railroad Retirement Quarterly Rates:
2001–2, I.R.B. 258
2001–15, I.R.B. 1054
Revenue Procedures:
2001–1, 2001–1 I.R.B. 1
2001–2, 2001–1 I.R.B. 79
2001–3, 2001–1 I.R.B. 111
2001–4, 2001–1 I.R.B. 121
2001–5, 2001–1 I.R.B. 164
2001–6, 2001–1 I.R.B. 194
2001–7, 2001–1 I.R.B. 236
2001–8, 2001–1 I.R.B. 239
2001–9, 2001–3 I.R.B. 328
2001–10, 2001–2 I.R.B. 272
2001–11, 2001–2 I.R.B. 275
2001–12, 2001–3 I.R.B. 335
2001–13, 2001–3 I.R.B. 337
2001–14, 2001–3 I.R.B. 343
2001–15, 2001–5 I.R.B. 465
2001–16, 2001–4 I.R.B. 376
2001–17, 2001–7 I.R.B. 589
2001–18, 2001–8 I.R.B. 708
2001–19, 2001–9 I.R.B. 732
2001–20, 2001–9 I.R.B. 738
2001–21, 2001–9 I.R.B. 742
2001–22, 2001–9 I.R.B. 745
2001–23, 2001–10 I.R.B. 784
2001–24, 2001–10 I.R.B. 788
2001–25, 2001–12 I.R.B. 913
2001–26, 2001–17 I.R.B. 1093
2001–27, 2001–19 I.R.B. 1155
2001–28, 2001–19 I.R.B. 1156
2001–29, 2001–19 I.R.B. 1160
2001–30, 2001–19 I.R.B. 1163
2001–31, 2001–20 I.R.B. 1170
2001–32, 2001–21 I.R.B. 1197
Revenue Rulings:
2001–1, 2001–9 I.R.B. 726
2001–2, 2001–2 I.R.B. 255
2001–3, 2001–3 I.R.B. 319
2001–4, 2001–3 I.R.B. 295
2001–5, 2001–5 I.R.B. 451
2001–6, 2001–6 I.R.B. 491
2001–7, 2001–7 I.R.B. 541
2001–8, 2001–9 I.R.B. 726
2001–9, 2001–8 I.R.B. 652
2001–10, 2001–10 I.R.B. 755
2001–11, 2001–10 I.R.B. 780
2001–12, 2001–11 I.R.B. 811
2001–13, 2001–12 I.R.B. 898
2001–14, 2001–12 I.R.B. 898
2001–15, 2001–13 I.R.B. 922
2001–16, 2001–13 I.R.B. 936
2001–17, 2001–15 I.R.B. 1052
2001–18, 2001–17 I.R.B. 1092
2001–19, 2001–18 I.R.B. 1143
2001–20, 2001–18 I.R.B. 1143
2001–21, 2001–18 I.R.B. 1144
2001–22, 2001–19 I.R.B. 1152
2001–23, 2001–20 I.R.B. 1169
Treasury Decisions:
8910, 2001–2 I.R.B. 258
1
A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 2000–27 through
2000–52 is in Internal Revenue Bulletin 2001–1,
dated January 2, 2001.

2001–22 I.R.B.iiiMay 29, 2001
Treasury Decisions—Continued:
8911, 2001–3 I.R.B. 321
8912, 2001–5 I.R.B. 452
8913, 2001–3 I.R.B. 300
8914, 2001–8 I.R.B. 653
8915, 2001–4 I.R.B. 359
8916, 2001–4 I.R.B. 360
8917, 2001–7 I.R.B. 538
8918, 2001–4 I.R.B. 372
8919, 2001–6 I.R.B. 505
8920, 2001–8 I.R.B. 654
8921, 2001–7 I.R.B. 532
8922, 2001–6 I.R.B. 508
8923, 2001–6 I.R.B. 485
8924, 2001–6 I.R.B. 489
8925, 2001–6 I.R.B. 496
8926, 2001–6 I.R.B. 492
8927, 2001–11 I.R.B. 807
8928, 2001–8 I.R.B. 685
8929, 2001–10 I.R.B. 756
8930, 2001–5 I.R.B. 433
8931, 2001–7 I.R.B. 542
8932, 2001–11 I.R.B. 813
8933, 2001–11 I.R.B. 794
8934, 2001–12 I.R.B. 904
8935, 2001–8 I.R.B. 702
8937, 2001–11 I.R.B. 806
8938, 2001–13 I.R.B. 929
8939, 2001–12 I.R.B. 899
8940, 2001–15 I.R.B. 1016
8941, 2001–14 I.R.B. 977
8942, 2001–13 I.R.B. 929
8943, 2001–15 I.R.B. 1054
8944, 2001–16 I.R.B. 1067

May 29, 2001iv2001–22 I.R.B.
Finding List of Current Actions on
Previously Published Items
1
Bulletins 2001–1 through 2001–21
Announcements:
98–99
Modified by
Ann. 2001–9, 2001–3 I.R.B. 357
99–79
Superseded by
Ann. 2001–3, 2001–2 I.R.B. 278
2000–78
Obsoleted by
T.D. 8933, 2001–11 I.R.B. 794
2000–97
Corrected by
Ann. 2001–7, 2001–3 I.R.B. 357
Cumulative Bulletin:
1998–2
Corrected by
Ann. 2001–5, 2001–2 I.R.B. 286
Notices:
94–3
Modified by
T.D. 8933, 2001–11 I.R.B. 794
98–39
Modified by
Notice 2001–9, 2001–4 I.R.B. 375
98–40
Modified by
Notice 2001–9, 2001–4 I.R.B. 375
99–53
Modified and superseded by
Notice 2001–7, 2001–4 I.R.B. 374
2000–21
Superseded by
Notice 2001–1, 2001–2 I.R.B. 261
2000–22
Modified and superseded by
Notice 2001–8, 2001–4 I.R.B. 374
2000–26
Modified by
Notice 2001–22, 2001–12 I.R.B. 911
2000–43
Extended by
Notice 2001–13, 2001–6 I.R.B. 514
Proposed Regulations:
EE–130–86
Partially withdrawn by
REG–209461–79, 2001–8 I.R.B. 712
REG–106030–98
Corrected by
Ann. 2001–30, 2001–15 I.R.B. 1065
REG–106542–98
Corrected by
Ann. 2001–24, 2001–13 I.R.B. 793
REG–116733–98
Withdrawn by
Ann. 2001–11, 2001–4 I.R.B. 432
Proposed Regulations—Continued:
REG–105235–99
Corrected by
Ann. 2001–52, 2001–20 I.R.B. 1186
REG–116048–99
Withdrawn by
Ann. 2001–27, 2001–11 I.R.B. 897
REG–116050–99
Corrected by
Ann. 2001–51, 2001–20 I.R.B. 1185
REG–104683–00
Corrected by
Ann. 2001–42, 2001–18 I.R.B. 1147
REG–106702–00
Corrected by
Ann. 2001–28, 2001–13 I.R.B. 975
REG–110374–00
Corrected by
Ann. 2001–44, 2001–18 I.R.B. 1148
REG–126100–00
Corrected by
Ann. 2001–50, 2001–20 I.R.B. 1184
Revenue Procedures:
75–21
Modified and superseded by
Rev. Proc. 2001–28, 2001–19 I.R.B. 1156
75–28
Modified and superseded by
Rev. Proc. 2001–29, 2001–19 I.R.B. 1160
76–30
Modified and superseded by
Rev. Proc. 2001–28, 2001–19 I.R.B. 1156
79–48
Modified and superseded by
Rev. Proc. 2001–28, 2001–19 I.R.B. 1156
Rev. Proc. 2001–29, 2001–19 I.R.B. 1160
83–87
Superseded by
Rev. Proc. 2001–15, 2001–5 I.R.B. 465
90–18
Amplified and superseded by
Rev. Proc. 2001–18, 2001–8 I.R.B. 708
92–19
Superseded by
Rev. Proc. 2001–15, 2001–5 I.R.B. 465
96–15
Modified by
Ann. 2001–22, 2001–11 I.R.B. 895
96–17
Modified by
Rev. Proc. 2001–9, 2001–3 I.R.B. 328
97–25
Superseded by
Rev. Proc. 2001–31, 2001–20 I.R.B. 1170
99–18
Modified and superseded by
Rev. Proc. 2001–21, 2001–9 I.R.B. 742
99–47
Superseded by
Rev. Proc. 2001–16, 2001–4 I.R.B. 376
Revenue Procedures—Continued:
99–49
Modified and amplified by
Notice 2001–23, 2001–12 I.R.B. 911
Rev. Proc. 2001–10, 2001–2 I.R.B. 272
Rev. Proc. 2001–23, 2001–10 I.R.B. 784
Rev. Proc. 2001–24, 2001–10 I.R.B. 788
Rev. Proc. 2001–25, 2001–12 I.R.B. 913
Rev. Rul. 2001–8, 2001–9 I.R.B. 762
2000–1
Superseded by
Rev. Proc. 2001–1, 2001–1 I.R.B. 1
2000–2
Superseded by
Rev. Proc. 2001–2, 2001–1 I.R.B. 79
2000–3
Superseded by
Rev. Proc. 2001–3, 2001–1 I.R.B. 111
2000–4
Superseded by
Rev. Proc. 2001–4, 2001–1 I.R.B. 121
2000–5
Superseded by
Rev. Proc. 2001–5, 2001–1 I.R.B. 164
2000–6
Superseded by
Rev. Proc. 2001–6, 2001–1 I.R.B. 194
2000–7
Superseded by
Rev. Proc. 2001–7, 2001–1 I.R.B. 236
2000–8
Superseded by
Rev. Proc. 2001–8, 2001–1 I.R.B. 239
2000–14
Supplemented by
Rev. Proc. 2001–27, 2001–19 I.R.B. 1155
2000–16
Modified and superseded by
Rev. Proc. 2001–17, 2001–7 I.R.B. 589
2000–22
Modified and superseded by
Rev. Proc. 2001–10, 2001–2 I.R.B. 272
2000–23
Superseded by
Rev. Proc. 2001–26, 2001–17 I.R.B. 1093
2001–3
Corrected by
Ann. 2001–25, 2001–11 I.R.B. 895
Section 5.01 revoked by
Rev. Proc. 2001–30, 2001–19 I.R.B. 1163
2001–13
Clarified by
Notice 2001–12, 2001–3 I.R.B. 328
Revenue Rulings:
64–328
Modified by
Notice 2001–10, 2001–5 I.R.B. 459
66–110
Modified by
Notice 2001–10, 2001–5 I.R.B. 459
1
A cumulative list of current actions on previously
published items in Internal Revenue Bulletins
2000–27 through 2000–52 is in Internal Revenue
Bulletin 2001–1, dated January 2, 2001.

2001–22 I.R.B.vMay 29, 2001
Revenue Rulings—Continued:
85–30
Clarified by
Rev. Rul. 2001–8, 2001–9 I.R.B. 762
88–95
Clarified by
Rev. Rul. 2001–8, 2001–9 I.R.B. 762
92–19
Supplemented in part by
Rev. Rul. 2001–11, 2001–10 I.R.B. 780
2000–56
Corrected by
Ann. 2001–19, 2001–10 I.R.B. 791
2001–4
Modified by
Notice 2001–23, 2001–12 I.R.B. 911
Treasury Decisions:
7530
Removed by
T.D. 8938, 2001–13 I.R.B. 929
8757
Revised by
T.D. 8941, 2001–14 I.R.B. 977
8881
Corrected by
Ann. 2001–55, 2001–21 I.R.B. 1284
8889
Corrected by
Ann. 2001–14, 2001–21 I.R.B. 286
8913
Corrected by
Ann. 2001–26, 2001–11 I.R.B. 896
8916
Corrected by
Ann. 2001–41, 2001–18 I.R.B. 1147
8921
Corrected by
Ann. 2001–43, 2001–18 I.R.B. 1147
8929
Corrected by
Ann. 2001–56, 2001–21 I.R.B. 1286
8931
Technically amended by
Ann. 2001–37, 2001–16 I.R.B. 1090
8940
Corrected by
Ann. 2001–53, 2001–20 I.R.B. 1186

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