Internal Revenue Bulletin 2003-45 (PDF rendition): IRS Revenue Rulings

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Bulletin No. 2003-45
November 10, 2003
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.
SPECIAL ANNOUNCEMENT
Announcement 2003–66, page 1049.
The Sixteenth Annual Institute on Current Issues in International
Taxation jointly sponsored by the Internal Revenue Service and
the George Washington University Law School, will be held on
December 11 and 12, 2003, at the J. W. Marriott Hotel in
Washington, DC.
Announcement 2003–68, page 1050.
This announcement delays the implementat
ion of rolling re-
newals applicable to enrolled agents, wh
ose social security
numbers end with 0, 1, 2, or 3, under se
ction 10.6(d)(1) of
the Regulations Governing Practic
eBeforetheInternalRevenue
Service, Treasury Department Circ
ular No. 230, 31 CFR part
10.
INCOME TAX
Rev. Rul. 2003–111, page 1009.
2003 base period T-bill rate.The „base period T-bill rate‰
for the period ending September 30, 2003, is published as
required by section 995(f) of the Code.
Rev. Rul. 2003–112, page 1
007
.
Work Opportunity Tax Credi
t(WOTC).This ruling concerns
the eligibility criteria
for the Work Opportunity Tax Credit. The
ruling clarifies that an i
ndividual whose family receives assis-
tancefortherequisitep
eriod meets the requirements to be
certified as a qualifi
ed IV-A recipient under section 51(d)(2)(A)
of the Code if the indiv
idual is included on the grant (and thus
receives assistance
) for some portion of the specified period.
Rev. Rul. 2003–114, page 1012.
Federal rates; adjusted federal rates; adjusted federal long-
term rate and the long-term exempt rate.For purposes of
sections 382, 1274, 1288, and other sections of the Code,
tables set forth the rates for November 2003.
EMPLOYEE PLANS
Notice 2003–73, page 1017.
Retirement plans; year 2004 section 415(d)
limitations.This
notice sets forth certain cost-of-living a
djustments effective
January 1, 2004, applicable to the doll
ar limits on benefits un-
der qualified defined benefit pensio
nplansandtootherprovi-
sionsaffecting(1)certainplansof
deferred compensation and
(2) „control employees.‰
EXCISE TAX
Rev. Proc. 2003–78, page 1029.
This procedure provides instructions for establishing exemp-
tion from the section 4371 foreign insurance excise tax under
certain United States income tax treaties. Rev. Proc. 92–39
superseded in part.
(Continued on the next page)
Finding Lists begin on page ii.

TAX CONVENTIONS
Announcement 2003–63, page 1015.
Dutch agreement on MAP Administrative Arrangements.
A copy of the news release issued by the Director, Inter-
national (U.S. Competent Authority), on October 7, 2003
(IR–2003–116), is set forth.
ADMINISTRATIVE
Rev. Proc. 2003–75, page 1018.
Automobile owners and lessees.This procedure provides
owners and lessees of passenger automobiles (including
trucks, vans, and electric automobiles) with tables detailing
the limitations on depreciation deductions for passenger
automobiles first placed in service during calendar year 2003
and the amounts to be included in income for passenger
automobiles first leased during calendar year 2003. Separate
tables are provided for passenger automobiles qualifying for
additional first-year bonus depreciation under section 168(k).
In addition, this procedure provides the maximum allowable
value of employer-provided automobiles first made available
to employees for personal use in calendar year 2003 for
which the vehicle cents-per-mile valuation rule provided under
section 1.61–21(e) of the regulations may be applicable. Rev.
Procs. 2001–19 and 2002–14 amplified.
Rev. Proc. 2003–79, page 1036.
Annual accounting periods; partnerships; S corporations.
Procedures are provided under which partners or sharehold-
ers of S corporations may elect, under certain circumstances,
to take into account ratably over four taxable years the part-
nerÊs or S corporation shareholderÊs share of income from the
partnership or S corporation that is attributable to a short tax-
able year ending on or after May 10, 2002, but before June 1,
2004. Rev. Procs. 2002–38 and 2002–39 modified.
Rev. Proc. 2003–80, page 10
37
.
Per diem allowances.This pr
ocedure provides rules for deem-
ing substantiated the amou
nt of certain reimbursed traveling
expenses of an employee as
well as optional rules for deter-
mining the amount of deduc
tible meals and incidental expenses
while traveling away fro
m home. Rev. Proc. 2002–63 super-
seded.
Rev. Proc. 2003–81, page 1046.
This procedure provides issuers of qualified mortgage bonds,
as defined in section 143(a) of the Code, and issuers of mort-
gage credit certificates, as defined in section 25(c), with a
list of qualified census tracts for the Northern Mariana Islands,
American Samoa, and Guam. The qualified census tracts are
based on data from the 2000 census. Rev. Proc. 2003–49
supplemented.
Announcement 2003–60, page 1049.
This document contains corrections to final regulations (T.D.
9083, 2003-40 I.R.B. 700) that relate to the treatment of
golden parachute payments under section 280G of the Code.
November 10, 20032003-45 I.R.B.

The IRS Mission
Provide AmericaÊs taxpayers top quality service by helping
them understand and meet their tax responsibilities and by
applying the tax law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, 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. Bul-
letin 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, mod-
ify, or amend any of those previously published in the Bulletin.
All published rulings apply retroactively unless otherwise indi-
cated. Procedures relating solely to matters of internal man-
agement 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 published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions 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 decision
s 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 Other Related Items, and Subpart B, Leg-
islation 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 Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the TreasuryÊs Office of the Assistant Sec-
retary (Enforcement).
Part IV.—Items of Gener
al Interest.
This part includes noti
ces of proposed rulemakings, disbar-
ment and suspension l
ists, and announcements.
The last 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 last Bulletin of each semiannual period.*
The content
s 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.
* Beginning with Internal Revenue Bulletin 2003–43, we are publishing the index at the end of the month, rather than at the beginning.
2003-45 I.R.B.November 10, 2003

Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
Section 25.—Interest on
Certain Home Mortgages
26 CFR 1.25-3T: Qualified Mortgage Credit Certifi-
cate.
The qualified census tracts for the Northern Mari-
ana Islands, American Samoa, and Guam are set forth
for use in determining the portion of loans required to
be placed in targeted areas under section 143(h). See
Rev. Proc. 2003-81, page 1046.
Section 42.—Low-Income
Housing Credit
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2003. See Rev. Rul. 2003-114, page
1012.
Section 51.—Amount
of Credit
26 CFR 1.51–1: Amount of credit.
Work Opportunity Tax Credit
(WOTC).This ruling concerns the el-
igibility criteria for the Work Opportunity
Tax Credit. The ruling clarifies that an
individual whose family receives assis-
tance for the requisite period meets the
requirements to be certified as a qualified
IV-A recipient under section 51(d)(2)(A)
of the Code if the individual is included
on the grant (and thus receives assistance)
for some portion of the specified period.
Rev. Rul. 2003–112
ISSUE
Does an individual whose family re-
ceives assistance for the requisite period
meet the requirements to be certified as
a qualified IV-A recipient under section
51(d)(2)(A) of the Internal Revenue Code
(Code) if the individual is included on the
grant (and receives assistance) for less than
the specified period?
FACTS
Situation 1. HandW,amarriedcou-
ple, lived together with their children un-
til March 1, 2002, when H moved away
and established a new residence for him-
self. On March 25, 2002, W applied for
Temporary Assistance for Needy Families
(TANF) payments for herself and her chil-
dren, and TANF payments began on April
1, 2002. On January 1, 2003, H returned to
live with W and their children. H obtained
employment on January 10, 2003 (the hir-
ing date). H was not included on the grant
at any time prior to the hiring date.
Situation 2. The facts are the same as
in Situation 1, except that H was included
on W’s TANF grant effective February 1,
2003, and did not obtain employment until
February 10, 2003 (the hiring date).
Situation 3.HandW,amarriedcouple,
lived together with their children. On
August 25, 2001, H and W applied for
TANF payments for themselves and their
children, and TANF payments began on
September 1, 2001. In November 2001,
H moved away and established a new res-
idence for himself. H was removed from
the grant effective December 1, 2001.
W and the children continued to receive
TANF payments through December 2002.
H obtained employment on August 1,
2002 (the hiring date).
Situation 4.HandW,amarriedcouple,
lived together with their children, S and
D. On January 10, 2002, H and W applied
for TANF payments for themselves, S, and
D. TANF payments began on February 1,
2002. S’s 18
th
birthday was on March 15,
2002. S was removed from the grant ef-
fective April 1, 2002. H, W, and D con-
tinued to receive TANF payments through
December 2002. S obtained employment
on December 15, 2002 (the hiring date).
In each of the situations, the state makes
monthly TANF payments prospectively on
the first day of the month.
LAW AND ANALYSIS
Under section 51 of the Code, an em-
ployer who hires an individual belonging
to one of nine targeted groups may be enti-
tled to a credit equal to 40 percent of qual-
ified first-year wages for the taxable year.
Section 51(d) of the Code lists the tar-
geted groups and defines each of them. An
individual who is a qualified IV-A recipi-
ent is a member of a targeted group. Sec-
tion 51(d)(2)(A) defines a “qualified IV-A
recipient” as an individual who is certi-
fied by the designated local agency (state
employment security agency) as being a
member of a family receiving assistance
under a IV-A program for any 9 months
during the 18-month period ending on the
hiring date. Section 51(d)(2)(B) defines a
“IV-A program” as any program providing
assistance under a state program funded
under part A of title IV of the Social Se-
curity Act (now Temporary Assistance for
Needy Families Block Grants for States;
formerly Aid for Families with Dependent
Children) and any successor of such pro-
gram.
Before the amendment of section 51(d)
by the Small Business Job Protection Act
of 1996, the corresponding targeted group
was limited to individuals who were certi-
fied as "being eligible for financial assis-
tance under part A of title IV of the So-
cial Security Act and as having continu-
ally received such financial assistance dur-
ing the 90-day period which immediately
precedes the [hiring date]. . . ." Section
51(d)(9) as in effect for workers hired be-
fore October 1, 1996.
In its explanation of the amendment of
section 51(d) by the Small Business Job
Protection Act of 1996, the Senate Finance
Committee described a qualified IV-A re-
cipient as follows:
An eligible recipient is an individual
certified by the designated local em-
ployment agency as being a member of
a family receiving benefits under AFDC
or its successor program for a period
of at least nine months part of which
is during the nine-month period ending
on the hiring date. For these purposes,
each member of the family receiving as-
sistance is treated as receiving such as-
sistance and therefore is treated as an el-
igible recipient.
S. Rep. No. 104–291, 104
th
Cong., 2d
Sess. 33–34 (1996).
The language above does not reflect
the amendment of section 51(d) by the
Taxpayer Relief Act of 1997, Pub.L. No.
105–34, § 603(b)(1) (1997). The Taxpayer
Relief Act replaced the requirement that
the family receive assistance for a period of
at least nine months part of which is during
the nine-month period ending on the hir-
ing date with the current requirement that
the family receive assistance for “any nine
months during the 18-month period ending
on the hiring date.”
The 1996 amendment of section 51(d)
and the legislative history evidence a clear
2003-45 I.R.B.1007November 10, 2003

intent to eliminate the requirement that a
IV-A recipient receive assistance for the
entire period specified. The correspond-
ing targeted group before the 1996 amend-
ment was explicitly limited to individuals
who continually received assistance during
a specified period. There is no such limi-
tation in the definition of a qualified IV-A
recipient; instead, aqualified IV-A recip-
ient is required only to be a member of a
family that receives assistance during the
specified period.
Neither section 51(d) nor the legislative
history specifies the persons who are mem-
bers of the family receiving assistance. In
the absence of other guidance, it is appro-
priate to look to the TANF rules to de-
termine who is a family member. Thus,
if an individual receives assistance under
TANF as a member of a family, even if
only for a day, the individual will be treated
as a member of the family for purposes
of section 51(d)(2)(A). Conversely, if the
individual never receives assistance under
TANF as a member of a family, the indi-
vidual will not be treated as a member of
the family for such purposes.
Accordingly, if the family receives as-
sistance for the required period, and the in-
dividual is included on the grant for some
portion of the period, the individual is a
qualified IV-A recipient.
InSituation 1, H was not included on
the family’s TANF grant for any month
and is therefore not a qualified IV-A recip-
ient.
InSituation 2, the family received as-
sistance for at least 9 months during the
18-month period ending on the hiring date
and H was included on the grant for part
of the period during which the family re-
ceived assistance. Accordingly, H is a
qualified IV-A recipient.
InSituation 3, H’s hiring date was Au-
gust 1, 2002. The 18-month period end-
ing on the hiring date began February 2,
2001. The family received assistance for
at least 9 months during the 18-month pe-
riod ending on the hiring date, and H was
included on the grant for part of the pe-
riod during which the family received as-
sistance. Thus, H is a qualified IV-A re-
cipient.
InSituation 4, the family received as-
sistance for at least 9 months during the
18-month period ending on the hiring date
and S was included on the grant for part
of the period during which the family re-
ceived assistance. Accordingly, S is a
qualified IV-A recipient.
HOLDING
An individual whose family receives as-
sistance for the requisite period meets the
requirements to be certified as a qualified
IV-A recipient undersection 51(d)(2)(A)
of the Code if the individual is included on
the grant (and thus receives assistance) for
some portion of the specified period.
The principles of this revenue ruling
also apply for purposes of determining
whether an individual meets the corre-
sponding family membership require-
ments to be certified as a qualified veteran
under section 51(d)(3)(A), a qualified food
stamp recipient under section 51(d)(8)(A),
or a long-term family assistance recipient
under section 51A(c)(1)(A).
DRAFTING INFORMATION
The principal author of this revenue rul-
ing is Shoshanna Tanner of the Office of
Division Counsel/Associate Chief Counsel
(Tax Exempt and Government Entities).
For further information regarding this rev-
enue ruling, contact Ms. Tanner at (202)
622–6080 (not a toll-free call).
Section 61.—Gross Income
Defined
26 CFR 1.61-21: Taxation of fringe benefits.
This procedure provides the maximum value of
employer-provided automobiles first made available
to employees for personal use in calendar year 2003
for which the vehicle cents-per-mile valuation rule
provided under section 1.61-21(e) of the Income
Tax Regulations may be applicable. See Rev. Proc.
2003-75, page 1018.
Section 62.—Adjusted Gross
Income Defined
26 CFR 1.62-2: Reimbursements and other expense
allowance arrangements.
Rules are provided under which a reimbursement
or other expense allowance arrangement for the cost
of lodging, meal, and incidental expenses, or of meal
and incidental expenses, incurred by an employee
while traveling away from home will satisfy the re-
quirements of section 62(c) of the Code as to substan-
tiation of the amount of the expenses. See Rev. Proc.
2003-80, page 1037.
Section 103.—Interest on
State and Local Bonds
26 CFR 1.103-1: Interest upon obligations of a State,
Territory, etc.
The qualified census tracts for the Northern Mari-
ana Islands, American Samoa, and Guam are set forth
for use in determining the portion of loans required to
be placed in targeted areas under section 143(h). See
Rev. Proc. 2003-81, page 1046.
Section 143.—Mortgage
Revenue Bonds: Qualified
Mortgage Bond and Qualified
Veterans’ Mortgage Bond
26 CFR 6a.103A-2: Qualified mortgage bond.
The qualified census tracts for the Northern Mari-
ana Islands, American Samoa, and Guam are set forth
for use in determining the portion of loans required to
be placed in targeted areas under section 143(h). See
Rev. Proc. 2003-81, page 1046.
Section 162.—Trade or
Business Expenses
26 CFR 1.162-17: Reporting and substantiation of
certain business expenses of employees.
Rules are provided for substantiating the amount
of a deduction of an expense for meal and incidental
expenses, or for incidental expenses only, incurred
while traveling away from home. See Rev. Proc.
2003-80, page 1037.
Section 168.—Accelerated
Cost Recovery System
This procedure provides owners and lessees of pas-
senger automobiles (including electric automobiles)
with tables detailing the limitations on depreciation
deductions for automobiles first placed in service dur-
ing calendar year 2003 that qualify for the additional
first-year bonus depreciation allowance under section
168(k) of the Code. See Rev. Proc. 2003-75, page
1018.
Section 274.—Disallowance
of Certain Entertainment,
etc., Expenses
26 CFR 1.274-5: Substantiation
requirements.
Rules are provided for an option
al method for
substantiating the amount of
ordinary and necessary
business expenses of an empl
oyee for lodging, meal,
and incidental expenses, or
for meal and incidental
expenses, incurred while t
ravelingawayfromhome
when a payor provides a per d
iem allowance under a
reimbursement or other ex
pense allowance arrange-
ment. Rules are also provi
ded for an optional method
November 10, 200310082003-45 I.R.B.

for employees and self-employed individuals to use
in computing the deductible costs of business meal
and incidental expenses, or incidental expenses only,
paid or incurred while traveling away from home.
See Rev. Proc. 2003-80, page 1037.
Section 280F.—Limitation
on Depreciation for Luxury
Automobiles; Limitation
Where Certain Property Used
forPersonalPurposes
26 CFR 1.280F-7: Property leased after December
31, 1986.
This procedure provides owners and lessees of pas-
senger automobiles (including electric automobiles)
with tables detailing the limitations on depreciation
deductions for automobiles first placed in service dur-
ing calendar year 2003 and the amounts to be in-
cluded in income for automobiles first leased during
calendar year 2003. See Rev. Proc. 2003-75, page
1018.
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term rates
are set forth for the month of November 2003. See
Rev. Rul. 2003-114, page 1012.
Section 382.—Limitation
on Net Operating Loss
Carryforwards and Certain
Built-In Losses Following
Ownership Change
The adjusted applicable federal long-term rates is
set forth for the month of November 2003. See Rev.
Rul. 2003-114, page 1012.
Section 412.—Minimum
Funding Standards
The adjusted applicable federal sh
ort-term, mid-
term, and long-term rates are set f
orth for the month
of November 2003. See Rev. Rul. 200
3-114, page
1012.
Section 467.—Certain
Payments for the Use of
Property or Services
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2003. See Rev. Rul. 2003-114, page
1012.
Section 468.—Special
Rules for Mining and Solid
Waste Reclamation and
Closing Costs
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2003. See Rev. Rul. 2003-114, page
1012.
Section 482.—Allocation
of Income and Deductions
Among Taxpayers
Federal short-term, mid-term, and long-term rates
are set forth for the month of November 2003. See
Rev. Rul. 2003-114, page 1012.
Section 483.—Interest on
Certain Deferred Payments
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2003. See Rev. Rul. 2003-114, page
1012.
Section 642.—Special Rules
for Credits and Deductions
Federal short-term, mid-term, and long-term rates
are set forth for the month of November 2003. See
Rev. Rul. 2003-114, page 1012.
Section 807.—Rules for
Certain Reserves
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2003. See Rev. Rul. 2003-114, page
1012.
Section 846.—Discounted
Unpaid Losses Defined
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2003. See Rev. Rul. 2003-114, page
1012.
Section 995.—Taxation of
DISC Income to Shareholders
2003 base period T-bill rate.The
“base period T-bill rate” for the period
ending September 30, 2003, is published
as required by section 995(f) of the Code.
Rev. Rul. 2003–111
Section 995(f)(1) of the Internal Rev-
enue Code provides that a shareholder of a
DISC shall pay interest each taxable year
in an amount equal to the product of the
shareholder’s DISC-related deferred tax li-
ability for the year and the “base period
T-bill rate.” Under section 995(f)(4), the
base period T-bill rate is the annual rate
of interest determined by the Secretary to
be equivalent to the average of the 1-year
constant maturity Treasury yields, as pub-
lished by the Board of Governors of the
Federal Reserve System, for the 1-year pe-
riod ending on September 30 of the calen-
dar year ending with (or of the most recent
calendar year ending before) the close of
the taxable year of the shareholder. The
base period T-bill rate for the period end-
ing September 30, 2003, is 1.30 percent.
Pursuant to section 6222 of the Code,
interest must be compounded daily. The
table below provides factors for com-
pounding the base period T-bill rate daily
foranynumberofdaysintheshare-
holder’s taxable year (including a 52–53
week accounting period) for the 2003 base
period T-bill rate. To compute the amount
of the interest charge for the shareholder’s
taxable year, multiply the amount of the
shareholder’s DISC-related deferred tax
liability (as defined in section 995(f)(2))
for that year by the base period T-bill rate
factor corresponding to the number of
days in the shareholder’s taxable year for
which the interest charge is being com-
puted. Generally, one would use the factor
for 365 days. One would use a different
factor only if the shareholder’s taxable
year for which the interest charge being
determined is a short taxable year, if the
shareholder uses the 52–53 week taxable
year, or if the shareholder’s taxable year
is a leap year.
For the base period T-bill rates for the
periods ending in prior years, see Rev. Rul.
2002–68, 2002–2 C.B. 808, Rev. Rul.
2001–56, 2001–2 C.B. 500, and Rev. Rul.
2000–52, 2000–2 C.B. 516.
2003-45 I.R.B.1009November 10, 2003

DRAFTING INFORMATION
The principal author of this revenue rul-
ing is David Bergkuist of the Office of the
Associate Chief Counsel (International).
For further information about this revenue
ruling, contact Mr. Bergkuist at (202)
622–3850 (not a toll-free call).
2003 ANNUAL RATE,
COMPOUNDED DAILY
DAYS
1.30 PERCENT
FACTOR
1.000035616
2.000071234
3.000106853
4.000142473
5.000178095
6.000213718
7.000249342
8.000284967
9.000320594
10.000356221
11.000391851
12.000427481
13.000463113
14.000498746
15.000534380
16.000570015
17.000605652
18.000641290
19.000676929
20.000712570
21.000748212
22.000783855
23.000819499
24.000855145
25.000890792
26.000926440
27.000962089
28.00099
7740
29.001033392
30.001069045
31.001104700
32.001140355
3
3
.
001176012
34.001211671
35.001247330
36.001282991
37.001318653
38.001354317
39.001389981
40.001425647
2003 ANNUAL RATE,
COMPOUNDED DAILY
DAYS
1.30 PERCENT
FACTOR
41.001461315
42.001496983
43.001532653
44.001568324
45.001603996
46.001639670
47.001675345
48.001711021
49.001746698
50.001782377
51.001818057
52.001853738
53.001889420
54.001925104
55.001960789
56.001996475
57.002032163
58.002067852
59.002103542
60.002139233
61.002174926
62.002210620
63.002246315
64.002282011
65.002317709
66.002353408
67.002389108
68.002424810
69.00246051
3
70.002496217
71.00253
1922
72.002567629
73.002603337
74.00
2639046
75.002674756
76.002710468
77.002746181
78.002781895
79.002817611
80.002853327
81.002889045
82.002924765
83.002960485
84.002996207
85.003031930
2003 ANNUAL RATE,
COMPOUNDED DAILY
DAYS
1.30 PERCENT
FACTOR
86.003067655
87.003103381
88.003139107
89.003174836
90.003210565
91.003246296
92.003282028
93.003317761
94.003353496
95.003389232
96.003424969
97.003460707
98.003496447
99.003532188
100.003567930
101.003603674
102.003639419
103.003675165
104.003710912
105.003746661
106.003782411
107.003818162
108.003853914
109.003889668
110.003925423
111.003961179
112.003996937
113.004032695
114.00406845
5
115.004104217
116.00413
9979
117.004175743
118.004211508
119.00
4247275
120.004283043
121.004318812
122.004354582
123.004390353
124.004426126
125.004461900
126.004497676
127.004533452
128.004569230
129.004605009
130.004640790
November 10, 200310102003-45 I.R.B.

2003 ANNUAL RATE,
COMPOUNDED DAILY
DAYS
1.30 PERCENT
FACTOR
131.004676572
132.004712355
133.004748139
134.004783924
135.004819711
136.004855499
137.004891289
138.004927079
139.004962871
140.004998664
141.005034459
142.005070255
143.005106052
144.005141850
145.005177650
146.005213450
147.005249253
148.005285056
149.005320861
150.005356667
151.005392474
152.005428282
153.005464092
154.005499903
155.005535715
156.005571529
157.005607344
158.005643160
159.00567897
7
160.005714796
161.00575
0616
162.005786437
163.005822260
164.00
5858084
165.005893909
166.005929735
167.005965563
168.006001392
169.006037222
170.006073053
171.006108886
172.006144720
173.006180555
174.006216392
175.006252230
2003 ANNUAL RATE,
COMPOUNDED DAILY
DAYS
1.30 PERCENT
FACTOR
176.006288069
177.006323909
178.006359751
179.006395594
180.006431438
181.006467284
182.006503130
183.006538979
184.006574828
185.006610678
186.006646530
187.006682384
188.006718238
189.006754094
190.006789951
191.006825809
192.006861668
193.006897529
194.006933391
195.006969255
196.007005119
197.007040985
198.007076853
199.007112721
200.007148591
201.007184462
202.007220334
203.007256208
204.00729208
3
205.007327959
206.00736
3836
207.007399715
208.007435595
209.00
7471476
210.007507359
211.007543243
212.007579128
213.007615014
214.007650902
215.007686791
216.007722681
217.007758572
218.007794465
219.007830359
220.007866255
2003 ANNUAL RATE,
COMPOUNDED DAILY
DAYS
1.30 PERCENT
FACTOR
221.007902151
222.007938049
223.007973948
224.008009849
225.008045750
226.008081653
227.008117558
228.008153463
229.008189370
230.008225278
231.008261188
232.008297098
233.008333010
234.008368923
235.008404838
236.008440754
237.008476671
238.008512589
239.008548509
240.008584430
241.008620352
242.008656275
243.008692200
244.008728126
245.008764053
246.008799982
247.008835912
248.008871843
249.00890777
5
250.008943709
251.00897
9644
252.009015580
253.009051518
254.00
9087457
255.009123397
256.009159338
257.009195281
258.009231225
259.009267170
260.009303117
261.009339064
262.009375013
263.009410964
264.009446915
265.009482868
2003-45 I.R.B.1011November 10, 2003

2003 ANNUAL RATE,
COMPOUNDED DAILY
DAYS
1.30 PERCENT
FACTOR
266.009518822
267.009554778
268.009590735
269.009626693
270.009662652
271.009698613
272.009734574
273.009770538
274.009806502
275.009842468
276.009878435
277.009914403
278.009950373
279.009986343
280.010022315
281.010058289
282.010094264
283.010130240
284.010166217
285.010202195
286.010238175
287.010274156
288.010310139
289.010346122
290.010382107
291.010418093
292.010454081
293.010490070
294.01052606
0
295.010562051
296.01059
8044
297.010634038
298.010670033
299.01
0706029
300.010742027
301.010778026
302.010814026
303.010850028
304.010886031
305.010922035
306.010958040
307.010994047
308.011030055
309.011066064
310.011102075
2003 ANNUAL RATE,
COMPOUNDED DAILY
DAYS
1.30 PERCENT
FACTOR
311.011138087
312.011174100
313.011210114
314.011246130
315.011282147
316.011318165
317.011354185
318.011390206
319.011426228
320.011462251
321.011498276
322.011534302
323.011570329
324.011606358
325.011642387
326.011678419
327.011714451
328.011750485
329.011786520
330.011822556
331.011858593
332.011894632
333.011930672
334.011966714
335.012002756
336.012038800
337.012074845
338.012110892
339.01214694
0
340.012182989
341.01221
9039
342.012255091
343.012291144
344.01
2327198
345.012363253
346.012399310
347.012435368
348.012471427
349.012507488
350.012543550
351.012579613
352.012615678
353.012651743
354.012687811
355.012723879
2003 ANNUAL RATE,
COMPOUNDED DAILY
DAYS
1.30 PERCENT
FACTOR
356.012759948
357.012796019
358.012832092
359.012868165
360.012904240
361.012940316
362.012976393
363.013012472
364.013048552
365.013084633
366.013120715
367.013156799
368.013192884
369.013228970
370.013265058
371.013301147
Section 1274.—Determina-
tion of Issue Price in the Case
of Certain Debt Instruments
Issued for Property
(Also sections 42, 280G, 382, 412, 467, 468, 482,
483, 642, 807, 846, 1288, 7520, 7872.)
Federal rates; adjusted federal rates;
adjusted federal long-term rate and the
long-term exempt rate.For purposes of
sections 382, 1274, 1288, and other sec-
tions of the Code, tables set forth the rates
for November 2003.
Rev. Rul. 2003–114
This revenue ruling provides various
prescribed rates for federal income tax
purposes for November 2003 (the current
month). Table 1 contains the short-term,
mid-term, and long-term applicable fed-
eral rates (AFR) for the current month
for purposes of section 1274(d) of the
Internal Revenue Code. Table 2 contains
the short-term, mid-term, and long-term
adjusted applicable federal rates (adjusted
AFR) for the current month for purposes
of section 1288(b). Table 3 sets forth
the adjusted federal long-term rate and
the long-term tax-exempt rate described
in section 382(f). Table 4 contains the
appropriate percentages for determining
the low-income housing credit described
November 10, 200310122003-45 I.R.B.

in section 42(b)(2) for buildings placed in
service during the current month. Finally,
Table 5 contains the federal rate for de-
termining the present value of annuity, an
interest for life or for a term of years, or
a remainder or a reversionary interest for
purposes of section 7520.
REV. RUL. 2003–114 TABLE 1
Applicable Federal Rates (AFR) for November 2003
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-Term
AFR1.50%1.49%1.49%1.49%
110% AFR1.65%1.64%1.64%1.63%
120% AFR1.80%1.79%1.79%1.78%
130% AFR1.95%1.94%1.94%1.93%
Mid-Term
AFR3.32%3.29%3.28%3.27%
110% AFR3.65%3.62%3.60%3.59%
120% AFR3.99%3.95%3.93%3.92%
130% AFR4.33%4.28%4.26%4.24%
150% AFR5.00%4.94%4.91%4.89%
175% AFR5.84%5.76%5.72%5.69%
Long-Term
AFR4.99%4.93%4.90%4.88%
110% AFR5.49%5.42%5.38%5.36%
120% AFR6.01%5.92%5.88%5.85%
130% AFR6.51%6.41%6.36%6.33%
REV. RUL. 2003–114 TABLE 2
Adjusted AFR for November 2003
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term adjusted
AFR
1.28%1.28%1.28%1.28%
Mid-term adjusted AFR2.63%2.61%2.60%2.60%
Long-term adjusted
AFR
4.56%4.51%4.48%4.47%
REV. RUL. 2003–114 TABLE 3
Rates Under Section 382 for November 2003
Adjusted federal long-term rate for the current month4.56%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted
federal long-term rates for the currentmonth and the prior two months.)4.74%
2003-45 I.R.B.1013November 10, 2003

REV. RUL. 2003–114 TABLE 4
Appropriate Percentages Under Section 42(b)(2) for November 2003
Appropriate percentage for the 70% present value low-income housing credit7.96%
Appropriate percentage for the 30% present value low-income housing credit3.41%
REV. RUL. 2003–114 TABLE 5
Rate Under Section 7520 for November 2003
Applicable federal rate for determini
ng the present value of an annuity, an interest for life or a
term of years, or a remainder or reversio
nary interest
4.0%
Section 1288.—Treatment of
Original Issue Discounts on
Tax-Exempt Obligations
The adjusted applicable fede
ral short-term, mid-
term, and long-term rates are
set forth for the month
of November 2003. See Rev. Ru
l. 2003-114, page
1012.
Section 7520.—Valuation
Tables
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2003. See Rev. Rul. 2003-114, page
1012.
Section 7872.—Treatment
of Loans With Below-Market
Interest Rates
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of November 2003. See Rev. Rul. 2003-114, page
1012.
November 10, 200310142003-45 I.R.B.

Part II. Treaties and Tax Legislation
Subpart A.—Tax Conventions and Other Related Items
Dutch Administrative
Arrangements MAP Agreement
Announcement 2003–63
Following is a copy of the News Re-
lease issued by the Director, International
(U.S. Competent Authority), on October 7,
2003 (IR–2003–116).
The U.S. And The Netherlands Develop
New Administrative Arrangements for
Mutual Agreement Procedure
IR–2003–116, Oct. 7, 2003
WASHINGTON — The competent au-
thorities of the United States and the
Netherlands have agreed to new Ad-
ministrative Arrangements that outline
guiding principles to follow when us-
ing the Mutual Agreement Procedure
(the MAP) found in Article 29 of the
U.S.-Netherlands income Tax Conven-
tion. The Arrangements were devel-
oped to ensure that the MAP process
works as efficiently and effectively as
possible.
The text of the Agreement is as follows:
Administrative Arrangements for
the Implementation of the Mutual
Agreement Procedure (Article 29) of
the Convention Between the Kingdom
of the Netherlands and the United
States of America for the Avoidance of
Double Taxation and the Prevention of
Fiscal Evasion with Respect to Taxes
on Income and Capital Gains (Signed
on December 18, 1992, as Amended by
Protocols) (the “Convention”)
The competent authorities of the
Netherlands and the United States hereby
enter into an agreement under the Mutual
Agreement Procedure Article (Article 29)
of the Convention, with a view to the
effective administration and resolution
of cases conducted between them under
the process. The Mutual Agreement Pro-
cedure (the “MAP”) of the Convention
provides that the competent authorities of
the two Contracting States shall endeavour
to resolve by mutual agreement cases of
taxation not in accordance with this Con-
vention. The Netherlands and the United
States are committed to assisting taxpay-
ers in the conduct of cases under the MAP,
to ensuring taxpayers know what they can
expect from the competent authorities, and
to making the MAP as expeditious and
effective as possible.
Particular areas in which MAP cases
arise include, but are not limited to:
i. determination of appropriate transfer
pricing methodologies to be applied
to cross-border transactions between
associated enterprises and/or whether
transfer prices used in cross-border
transactions between associated enter-
prises are established at arm’s length;
ii. determination of appropriate attribu-
tions of profits to the permanent estab-
lishments of enterprises; and
iii. determination of residence under Ar-
ticle 4 of the Convention.
In these and other areas of difficulties
and doubts arising as to the interpreta-
tion or application of the Convention, the
Netherlands and the United States are
committed to promoting and supporting
domestic initiatives and programs de-
signed to assist taxpayers and to helping
taxpayers in avoiding or resolving disputes
which might arise.
These Arrangements set out certain ob-
jectives and practices the Netherlands and
the United States will adopt in dealing with
cases under the MAP of the Convention
with a view to ensuring taxation in accor-
dance with the Convention.
Progress of the Mutual Agreement
Procedure
The Netherlands and the United States
agree that requests presented under Article
29 of the Convention shall be dealt with
as expeditiously as possible. The objective
is to resolve cases accepted for considera-
tion by the competent authorities within 18
months from transmittal of a position pa-
per by one Contracting State to the other,
excluding time during which the issues
presented for competent authority consid-
eration are under consideration by appel-
late or judicial authorities where permitted
under applicable national procedures.
In order to ensure timely progress in the
procedure, the competent authority of the
country that made the adjustment (the “rel-
evant competent authority”) will endeav-
our to deliver a position paper to its coun-
terpart (the “responding competent author-
ity”) within 120 days of acceptance of a
case from a taxpayer. The case will be
discussed without a written response un-
less such a response is needed to facili-
tate substantive discussion. If a written re-
sponse is needed in a case concerning at-
tribution of profits or transfer pricing ad-
justments under Article 7 or 9 of the Con-
vention, the responding competent author-
ity will endeavor to provide a position pa-
per within 240 days after receipt of the first
position paper. In all other cases in which
a written response is needed, the respond-
ing competent authority will endeavor to
deliver a position paper within 120 days
of receipt of the first position paper. In
cases of Advance Pricing Agreements or
Arrangements, the competent authorities
will endeavor to agree upon a joint tar-
get timetable for each stage of the consid-
eration, with the aim of securing Mutual
Agreements within a similar overall time-
frame, taking into account the complexi-
ties of the particular cases involved.
The role of the taxpayer during
procedure
The Netherlands and the United States
agree that, in law, the negotiation of a MAP
is a government-to-government process. A
taxpayer has no legal right to attend nego-
tiations between the competent authorities
or to observe the negotiations.
However, it is also recognized that the
taxpayer is a key stakeholder in the MAP
process. The competent authorities there-
fore agree that they will keep taxpayers in-
formed about the progress of a case under
the MAP and will invite them to provide
such further information as may be help-
ful in reaching a resolution. At their dis-
cretion, they may allow information to be
provided to them in a joint presentation by
the taxpayer.
2003-45 I.R.B.1015November 10, 2003

Resolution of cases
While the staff of the respective com-
petent authority offices will continue to
carry on the primary negotiation of cases
arising under Mutual Agreement Article of
the Convention, the Netherlands and the
United States agree that in any case that
extends beyond the applicable timeframe
agreed upon above, senior officials who
have not been present at the competent au-
thority meetings when the case was dis-
cussed or otherwise been personally in-
volved in the decision making on the case
will undertake a review of the case to en-
sure that all appropriate action is being
taken to facilitate resolution of the matter.
The Netherlands and the United States
will upon request also seek to resolve the
issue for subsequent taxable periods, to the
extent permitted under their respective na-
tional procedures.
Collection and interest
It is understood that where the compe-
tent authorities are endeavoring to resolve
a case pursuant to Article 29 of the Con-
vention, the Netherlands and the United
States generally will not seek to collect the
tax in dispute until the mutual agreement
procedure has been completed. Any tax
that is due upon the completion of the mu-
tual agreement procedure shall, however,
be subject to interest charges, and, if ap-
propriate, surcharges or penalties, to the
extent provided by applicable national law.
Any tax that is refunded upon completion
of the mutual agreement procedure will be
subject to interest payable on refunds, to
the extent provided by applicable national
law.
Confidentiality of taxpayer information
The Netherlands and the United States
are committed to ensuring confidentiality
concerning taxpayer information, under
the Convention and their respective laws.
Meetings Schedule
The Netherlands and the United States
agree to meet at least twice a year to
conduct face-to-face discussions. Interim
meetings and other communications also
will be conducted as necessary in an effort
to resolve cases.
The Netherlands and the United
States have agreed to publish these
Arrangements to assist taxpayers in
understanding and making full and
appropriate use of the MAP in the
Convention. The Arrangements will be
reviewed from time to time.
Agreed to August 25, 2003:
For the United States:For the Netherlands:
Carol A. DunahooPaul Vlaanderen
Director for International (LMSB)Director for International Tax Policy and Legislation
Internal Revenue ServiceMinistry of Finance
November 10, 200310162003-45 I.R.B.

Part III. Administrative, Procedural, and Miscellaneous
2004 Limitations Adjusted As
Provided in Section 415(d),
etc.
1
Notice 2003–73
Section 415 of the Internal Revenue
Code (the Code) provides for dollar limi-
tations on benefits and contributions under
qualified retirement plans. Section 415
also requires that the Commissioner annu-
ally adjust these limits for cost-of-living
increases. Other limitations applicable
to deferred compensation plans are also
affected by these adjustments. Many of
the limitations will change for 2004. For
most of the limitations, the increase in
the cost-of-living index met the statutory
thresholds that trigger their adjustment.
Furthermore, several of these limita-
tions, set by the Economic Growth and
Tax Relief Reconciliation Act of 2001
(EGTRRA), are scheduled to increase
at the beginning of 2004. For example,
under EGTRRA, the limitation under
§ 402(g)(1) of the Code on the exclu-
sion for elective deferrals described in
§ 402(g)(3) is increased from $12,000 to
$13,000. This limitation affects elective
deferrals to § 401(k) plans and to the Fed-
eral Government’s Thrift Savings Plan,
among other plans.
Cost-of-Living limits for 2004
Effective January 1, 2004, the limita-
tion on the annual benefit under a defined
benefit plan under § 415(b)(1)(A) is in-
creased from $160,000 to $165,000. For
participants who separated from service
before January 1, 2004, the limitation for
defined benefit plans under § 415(b)(1)(B)
is computed by multiplying the par-
ticipant’s compensation limitation, as
adjusted through 2003, by 1.0220.
The limitation for defined contribution
plans under § 415(c)(1)(A) is increased
from $40,000 to $41,000.
The Code provides that various other
dollar amounts are to be adjusted at the
same time and in the same manner as the
dollar limitation of § 415(b)(1)(A). These
dollar amounts and the adjusted amounts
are as follows:
The annual compensation limit un-
der §§ 401(a)(17), 404(l), 408(k)(3)(C),
and 408(k)(6)(D)(ii) is increased from
$200,000 to $205,000.
The dollar limitation under
§ 416(i)(1)(A)(i) concerning the defi-
nition of key employee in a top-heavy
plan remains unchanged at $130,000.
The dollar amount under
§ 409(o)(1)(C)(ii) for determining the
maximum account balance in an em-
ployee stock ownership plan subject to
a 5-year distribution period is increased
from $810,000 to $830,000, while the
dollar amount used to determine the
lengthening of the 5-year distribution
period is increased from $160,000 to
$165,000.
The limitation used in the definition
of highly compensated employee under
§ 414(q)(1)(B) remains unchanged at
$90,000.
The annual compensation limitation
under § 401(a)(17) for eligible partic-
ipants in certain governmental plans
that, under the plan as in effect on July
1, 1993, allowed cost-of-living adjust-
ments to the compensation limitation
under the plan under § 401(a)(17) to be
taken into account, is increased from
$300,000 to $305,000.
The compensation amount under
§ 408(k)(2)(C) regarding simplified
employee pensions (SEPs) remains
unchanged at $450.
The compensation amounts under
§ 1.61–21(f)(5)(i) of the Income Tax
Regulations concerning the definition
of “control employee” for fringe benefit
valuation purposes remains unchanged
at $80,000. The compensation amount
under § 1.61–21(f)(5)(iii) is increased
from $160,000 to $165,000.
Limitations specified by statute
The Code, as amended by EGTRRA,
specifies the applicable dollar amount for
a particular year for certain limitations.
These applicable dollar amounts are as fol-
lows:
The limitation under § 402(g)(1) on
the exclusion for elective deferrals de-
scribed in § 402(g)(3) is increased from
$12,000 to $13,000.
The limitation under § 408(p)(2)(E)
regarding SIMPLE retirement accounts
is increased from $8,000 to $9,000.
The limitation on deferrals under
§ 457(e)(15) concerning deferred com-
pensation plans of state and local gov-
ernments and tax-exempt organizations
is increased from $12,000 to $13,000.
The dollar limitation under
§ 414(v)(2)(B)(i) for catch-up con-
tributions to an applicable employer
plan other than a plan described in
§ 401(k)(11) or 408(p) for individu-
als aged 50 or over is increased from
$2,000 to $3,000. The dollar limitation
under § 414(v)(2)(B)(ii) for catch-up
contributions to an applicable employer
plan described in § 401(k)(11) or 408(p)
for individuals aged 50 or over is in-
creased from $1,000 to $1,500.
Administrators of defined benefit or de-
fined contribution plans that have received
favorable determination letters should not
request new determination letters solely
because of yearly amendments to adjust
maximum limitations in the plans.
Drafting Information
The principal author of this notice is
John Heil of the Employee Plans, Tax
Exempt and Government Entities Divi-
sion. For further information regarding
the data in this notice, please contact
the Employee Plans’ taxpayer assistance
telephone service at 1–877–829–5500
(a toll-free call) between the hours of 8
a.m. and 6:30 p.m. Eastern time Monday
through Friday. For information regarding
the methodology used at arriving at the
data in this notice, please contact Mr. Heil
at 1–202–283–9888 (not a toll-free call).
1
Based on News Release IR–2003–122 dated October 16, 2003.
2003-45 I.R.B.1017November 10, 2003

26 CFR 601.105: Examination of returns and claims
for refund, credit, or abatement; determination of
correct tax liability.
(Also Part I, §§ 61, 168, 280F; 1.61–21, 1.280F–7.)
Rev. Proc. 2003–75
SECTION 1. PURPOSE
01. This revenue procedure provides:
(1) limitations on depreciation deductions
for owners of passenger automobiles first
placed in service by the taxpayer during
calendar year 2003, including special ta-
bles of limitations on depreciation deduc-
tions for trucks and vans, and for passenger
automobiles designed to be propelled pri-
marily by electricity and built by an orig-
inal equipment manufacturer (electric au-
tomobiles); (2) the amounts to be included
in income by lessees of passenger auto-
mobiles first leased by the taxpayer dur-
ing calendar year 2003, including a sepa-
rate table of inclusion amounts for lessees
of trucks and vans, and a separate table for
lessees of electric automobiles; and (3) the
maximum allowable value of employer-
provided passenger automobiles first made
available to employees for personal use in
calendar year 2003 for which the vehicle
cents-per-mile valuation rule provided un-
der § 1.61–21(e) of the Income Tax Regu-
lations may be applicable.
02. This revenue procedure also pro-
vides: (1) tables of dollar limitations on
depreciation deductions for owners of pas-
senger automobiles to which the additional
30 percent first-year allowance for depre-
ciation available under § 168(k)(1)(A) ap-
plies, including special tables of limita-
tions on depreciation deductions for qual-
ifying trucks and vans and for qualify-
ing electric automobiles; (2) tables of dol-
lar limitations on depreciation deductions
for owners of passenger automobiles to
which the additional 50 percent first-year
allowance for depreciation available under
§ 168(k)(4) applies, including special ta-
bles of limitations on depreciation deduc-
tions for qualifying trucks and vans and
for qualifying electric automobiles; and
(3) revised tables of dollar limitations for
passenger automobiles and electric auto-
mobiles that were placed in service by
the taxpayer during 2001 and 2002 and to
which the additional 30 percent first-year
allowance for depreciation available under
§ 168(k)(1)(A) applies. For purposes of
these tables, the additional 30 percent or
50 percent first-year allowance does not
apply if the taxpayer has elected under
§ 168(k)(2)(C)(iii) not to take the addi-
tional allowance. Similarly, the additional
50 percent first-year allowance does not
apply if the taxpayer has elected under
§ 168(k)(4)(E) to take the additional 30
percent allowance instead of the additional
50 percent allowance.
03. The tables detailing these depre-
ciation limitations and lessee inclusion
amounts reflect the automobile price infla-
tion adjustments required by § 280F(d)(7).
The maximum allowable passenger au-
tomobile value for applying the vehicle
cents-per-mile valuation rule reflects the
automobile price inflation adjustment of
§ 280F(d)(7) of the Internal Revenue Code,
as required by § 1.61–21(e)(1)(iii)(A).
SECTION 2. BACKGROUND
01. For owners of passenger automo-
biles, § 280F(a) imposes dollar limitations
on the depreciation deduction for the
year that the passenger automobile is
placed in service by the taxpayer and
each succeeding year. In the case of elec-
tric automobiles placed in service after
August 5, 1997, and before January 1,
2005, § 280F(a)(1)(C) requires tripling
of these limitation amounts. Section
280F(d)(7) requires the amounts allowable
as depreciation deductions to be increased
by a price inflation adjustment amount for
passenger automobiles placed in service
after 1988. The method of calculating this
price inflation amount for trucks and vans
placed in service in or after calendar year
2003 uses a different CPI “automobile
component” (the “new trucks” compo-
nent) than that used in the price inflation
amount calculation for other passenger
automobiles (the “new cars” component),
resulting in somewhat higher deprecia-
tion deductions for trucks and vans. This
change reflects the higher rate of price
inflation that trucks and vans have been
subject to since 1988. For purposes of
this revenue procedure, the term “trucks
and vans” refers to passenger automobiles
that are built on a truck chassis, including
minivans and sport utility vehicles (SUVs)
that are built on a truck chassis.
02. Section 101 of the Job Creation
and Worker Assistance Act of 2002, Pub.
L. No. 107–147, 116 Stat. 21 (March
9, 2002) added § 168(k) to the Code.
Generally, § 168(k)(1)(A) provides an ad-
ditional 30 percent first-year depreciation
deduction for new property acquired by
the taxpayer after September 10, 2001,
and before September 11, 2004 (subse-
quently extended to January 1, 2005), so
long as no written binding contract for the
acquisition of the property existed prior
to September 11, 2001. In the case of a
passenger automobile to which the 30 per-
cent additional allowance applies (other
than a § 168(k)(4) passenger automobile
describedinsection2.03ofthisrevenue
procedure, or a passenger automobile for
which a taxpayer has made an election
under § 168(k)(2)(C)(iii)), § 168(k)(2)(E)
increases the first-year depreciation al-
lowed under § 280F(a)(1)(A) by $4,600.
For purposes of this revenue procedure,
a passenger automobile to which the ad-
ditional 30 percent first-year allowance
under § 168(k)(1)(A) applies (other than
a § 168(k)(4) passenger automobile de-
scribedinsection2.03ofthisrevenue
procedure, or a passenger automobile for
which a taxpayer has made an election
under § 168(k)(2)(C)(iii)) is referred to as
a “§ 168(k)(1) passenger automobile”.
03. Section 201 of the Jobs and Growth
Tax Relief Reconciliation Act of 2003,
Pub. L. No. 108–27, 117 Stat. 752 (May
28, 2003) added § 168(k)(4) to the Code.
Section 168(k)(4)(A)(i) provides that
§ 168(k)(1) is applied by substituting “50
percent” for “30 percent” for new prop-
erty acquired by the taxpayer after May
5, 2003, and before January 1, 2005, so
long as no written binding contract for the
acquisition of the property existed prior to
May 6, 2003. In the case of a passenger
automobile to which the 50 percent addi-
tional allowance applies (or would apply
but for an election under § 168(k)(4)(E))
and for which no election has been made
under § 168(k)(2)(C)(iii), § 168(k)(4)(D)
increases the first-year depreciation al-
lowed under § 280F(a)(1)(A) by $7,650.
For purposes of this revenue procedure,
a passenger automobile to which the ad-
ditional 50 percent first-year allowance
under § 168(k)(4) applies (or would apply
but for an election under § 168(k)(4)(E))
and for which no election has been made
under § 168(k)(2)(C)(iii) is referred to as
a “§ 168(k)(4) passenger automobile”.
November 10, 200310182003-45 I.R.B.

04. For leased passenger automobiles,
§ 280F(c) requires a reduction in the de-
duction allowed to the lessee of the pas-
senger automobile. The reduction must be
substantially equivalent to the limitations
on the depreciation deductions imposed on
owners of passenger automobiles. Under
§ 1.280F–7(a), this reduction requires the
lessees to include in gross income an in-
clusion amount determined by applying a
formula to the amount obtained from a ta-
ble. There is a table for lessees of electric
automobiles, a tablefor lessees of trucks
and vans, and a table for all other passenger
automobiles. Each table shows inclusion
amounts for a range of fair market values
for each tax year after the passenger auto-
mobile is first leased. These tables should
also be used by lessees of § 168(k)(1) pas-
senger automobiles and § 168(k)(4) pas-
senger automobiles.
05. For passenger automobiles (in-
cluding trucks, vans, and electric au-
tomobiles) first provided by employers
to employees that meet the require-
ments of § 1.61–21(e)(1), the value to
theemployeeoftheuseofthepas-
senger automobile may be determined
under the vehicle cents-per-mile val-
uation rule of § 1.61–21(e). Section
1.61–21(e)(1)(iii)(A) provides that for a
passenger automobile first made avail-
able after 1988 to any employee of the
employer for personal use, the value
of the use of the passenger automobile
may not be determined under the vehicle
cents-per-mile valuation rule for a cal-
endar year if the fair market value of the
passenger automobile (determined pur-
suant to § 1.61–21(d)(5)(i) through (iv))
on the first date the passenger automobile
is made available to the employee exceeds
$12,800 as adjusted by § 280F(d)(7).
SECTION 3. SCOPE AND OBJECTIVE
01. The limitation
s on depreciation de-
ductions in sectio
n 4.02(2) of this revenue
procedure apply t
o passenger automobiles
(other than lease
d passenger automobiles)
that are placed i
n service by the taxpayer in
calendar year 20
03, and continue to apply
for each tax ye
ar that the passenger auto-
mobile remain
s in service.
02. The tables
in section 4.03 of this
revenue proce
dure apply to leased passen-
ger automobi
les for which the lease term
begins durin
g calendar year 2003. Lessees
of such passenger automobiles must use
these tables to determine the inclusion
amount for each tax year during which
the passenger automobile is leased.See
Rev. Proc. 2002–14, 2002–1 C.B. 450, for
passenger automobiles first leased before
January 1, 2003.
03. The maximum fair market value
figure in section 4.04(2) of this revenue
procedure applies to employer-provided
passenger automobiles first made avail-
able to any employee for personal use
in calendar year 2003.SeeRev. Proc.
2002–14 for the maximum fair market
value figure for passenger automobiles
firstmadeavailablebeforeJanuary1,
2003.
04. The revised limitations on depreci-
ation deductions in section 4.05(2) of this
revenue procedure apply to § 168(k)(1)
passenger automobiles placed in service
by the taxpayer during 2001 and 2002.
The tables in section 4.05(2) of this rev-
enue procedure amplify both Rev. Proc.
2001–19, 2001–1 C.B. 732, and Rev.
Proc. 2002–14 by providing tables for
§ 168(k)(1) passenger automobiles to
which those revenue procedures apply.
SECTION 4. APPLICATION
01.In General.
(1)Limitations on Depreciation Ded
uc-
tions for Certain Automobiles.T
he limita-
tions on depreciation deductio
ns for pas-
senger automobiles placed in s
ervice by
the taxpayer for the first time
during cal-
endar year 2003 are found in Ta
bles 1
through9insection4.02(2)
of this rev-
enue procedure. Table 1 of th
is revenue
procedure provides limi
tations on depreci-
ation deductions for a pa
ssenger automo-
bile (other than a truck
, van, electric au-
tomobile, § 168(k)(1)
passenger automo-
bile, or § 168(k)(4) pa
ssenger automobile).
Table 2 of this revenu
eprocedureprovides
limitations on dep
reciation deductions for
a § 168(k)(1) passe
nger automobile (other
than a truck, van,
or electric automobile).
Table 3 of this rev
enue procedure provides
limitations on d
epreciation deductions for
a § 168(k)(4) pa
ssenger automobile (other
than a truck, v
an, or electric automobile).
Table 4 of this
revenue procedure provides
limitations
on depreciation deductions for
atruckorva
n (other than a § 168(k)(1) pas-
senger auto
mobile or § 168(k)(4) passen-
ger automo
bile). Table 5 of this revenue
procedure provides limitations on depreci-
ation deductions for a truck or van that is
a § 168(k)(1) passenger automobile. Ta-
ble 6 of this revenue procedure provides
limitations on depreciation deductions for
a truck or van that is a § 168(k)(4) pas-
senger automobile. Table 7 of this rev-
enue procedure provides limitations on de-
preciation deductions for an electric auto-
mobile (other than a § 168(k)(1) passenger
automobile or § 168(k)(4) passenger au-
tomobile). Table 8 of this revenue proce-
dure provides limitations on depreciation
deductions for an electric automobile that
is a § 168(k)(1) passenger automobile. Ta-
ble 9 of this revenue procedure provides
limitations on depreciation deductions for
an electric automobile that is a § 168(k)(4)
passenger automobile.
(2)Inclusions in Income of Lessees of
Passenger Automobiles. A taxpayer first
leasing a passenger automobile during cal-
endar year 2003 must determine the inclu-
sion amount that is added to gross income
using the tables in section 4.03 of this rev-
enue procedure. The inclusion amount is
determined using Table 10 in the case of a
passenger automobile (other than a truck,
van, or electric automobile), Table 11 in
the case of a truck or van, and Table 12 in
the case of an electric automobile. In addi-
tion, the procedures of § 1.280F–7(a) must
be followed.
(3)Maximum Automobile Value for Us-
ing the Cents-per-mile Valuation Rule.An
employer providing a passenger automo-
bile for the first time in calendar year 2003
for the personal use of any employee may
determine the value of the use of the pas-
senger automobile by using the cents-per-
mile valuation rule in § 1.61–21(e) if the
fair market value of the passenger auto-
mobile does not exceed the amount spec-
ified in section 4.04(2) of this revenue pro-
cedure. If the fair market value of the
passenger automobile exceeds the amount
specified in section 4.04(2) of this rev-
enue procedure, the employer may deter-
mine the value of the use of the passen-
ger automobile under the general valuation
rules of § 1.61–21(b) or under the special
valuation rules of § 1.61–21(d) (Automo-
bile lease valuation) or § 1.61–21(f) (Com-
muting valuation) if the applicable require-
ments are met.
(4)Limitations on Depreciation Deduc-
tions for Certain Passenger Automobiles
2003-45 I.R.B.1019November 10, 2003

Placed in Service in 2001 or 2002.De-
preciation deductions with respect to
§ 168(k)(1) passenger automobiles placed
in service during calendar year 2001 or
2002 are limited to the amounts set forth
in Tables 13 through 16 of section 4.05(2)
of this revenue procedure.
02.Limitations on Depreciation De-
ductions for Certain Automobiles.
(1)Amount of the Inflation Adjustment.
Under § 280F(d)(7)(B)(i), the automobile
price inflation adjustment for any calendar
year is the percentage (if any) by which the
CPI automobile component for October of
the preceding calendar year exceeds the
CPI automobile component for October
1987. The term “CPI automobile com-
ponent” is defined in § 280F(d)(7)(B)(ii)
as the “automobilecomponent” of the
Consumer Price Index for all Urban Con-
sumers published by the Department of
Labor (the CPI). The new car component
of the CPI was 115.2 for October 1987
and 136.7 for October 2002. The October
2002 index exceeded the October 1987
index by 21.5. The Service has, therefore,
determined that the automobile price in-
flation adjustment for 2003 for passenger
automobiles (other than trucks and vans)
is 18.66 percent (21.5/115.2 x 100%).
This adjustment is applicable to all pas-
senger automobiles (other than trucks and
vans) that are first placed in service in
calendar year 2003. The dollar limitations
in § 280F(a) must therefore be multiplied
by a factor of 0.1866, and the resulting
increases, after rounding to the nearest
$100, are added to the 1988 limitations to
give the depreciation limitations applica-
ble to passenger automobiles (other than
trucks, vans, and electric automobiles)
for calendar year 2003. To determine the
dollar limitations applicable to an electric
automobile first placed in service during
calendar year 2003, the dollar limitations
in § 280F(a) are tripled in accordance with
§ 280F(a)(1)(C) and are then multiplied by
a factor of 0.1866; the resulting increases,
after rounding to the nearest $100, are
added to the tripled 1988 limitations to
give the depreciation limitations for cal-
endar year 2003. To determine the dollar
limitations applicable to trucks and vans
first placed in service during calendar
year 2003, the new truck component of
the CPI is used instead of the new car
component. The new truck component
of the CPI was 112.4 for October 1987
and 147.5 for October 2002. The October
2002 index exceeded the October 1987
index by 35.1. The Service has, there-
fore, determined that the automobile price
inflation adjustment for 2003 for trucks
and vans is 31.23 percent (35.1/112.4 x
100%). This adjustment is applicable to
all trucks and vans that are first placed in
service in calendar year 2003. The dollar
limitations in § 280F(a) must therefore be
multiplied by a factor of 0.3123, and the
resulting increases, after rounding to the
nearest $100, are added to the 1988 limi-
tations to give the depreciation limitations
applicable to trucks and vans.
(2)Amount of the Limitation.For
passenger automobiles placed in service
by the taxpayer in calendar year 2003,
Tables 1 through 9 contain the dollar
amount of the depreciation limitation for
each tax year. Use Table 1 for passenger
automobiles (other than trucks, vans, elec-
tric automobiles, § 168(k)(1) passenger
automobiles, and § 168(k)(4) passenger
automobiles) placed in service by the tax-
payer in calendar year 2003. Use Table
2 for § 168(k)(1) passenger automobiles
(other than trucks, vans, and electric auto-
mobiles) placed in service by the taxpayer
in calendar year 2003. Use Table 3 for
§ 168(k)(4) passenger automobiles (other
than trucks, vans, and electric automo-
biles) placed in service by the taxpayer
in calendar year 2003. Use Table 4 for
trucks and vans (other than § 168(k)(1)
passenger automobiles and § 168(k)(4)
passenger automobiles) placed in service
by the taxpayer in calendar year 2003.
Use Table 5 for trucks or vans that are
§ 168(k)(1) passengerautomobiles placed
in service by the taxpayer in calendar
year 2003. Use Table 6 for trucks or vans
that are § 168(k)(4) passenger automo-
biles placed in service by the taxpayer in
calendar year 2003. Use Table 7 for elec-
tric automobiles (other than § 168(k)(1)
passenger automobiles and § 168(k)(4)
passenger automobiles) placed in service
by the taxpayer in calendar year 2003. Use
Table 8 for electric automobiles that are
§ 168(k)(1) passengerautomobiles placed
in service by the taxpayer in calendar year
2003. Use Table 9 for electric automobiles
that are § 168(k)(4) passenger automo-
biles placed in service by the taxpayer in
calendar year 2003.
REV. PROC. 2003–75 TAB
LE 1
DEPRECIATION LIMITATIONS FOR PASSENGER AUTOMOBILES
(THAT ARE NOT § 168(k)(1) PASSENGER AUTOMOBILES,
§ 168(k)(4) PASSENGER AUTOMOBILES
TRUCKS, VANS, OR ELECTRIC AUTOMOBILES)
PLACED IN SERVICE BY THE TAXPAYER DURING CALENDAR YEAR 2003
Tax YearAmount
1st Tax Year
$3,060
2nd Tax Year
$4,900
3rd Tax Year
$2,950
Each Succeeding Year
$1,775
November 10, 200310202003-45 I.R.B.

REV. PROC. 2003–75 TABLE 2
DEPRECIATION LIMITATIONS FOR
§ 168(k)(1) PASSENGER AUTOMOBILES
(THAT ARE NOT TRUCKS, VANS, OR ELECTRIC AUTOMOBILES)
PLACED IN SERVICE BY THE TAXPAYER DURING CALENDAR YEAR 2003
Tax YearAmount
1st Tax Year
$7,660
2nd Tax Year
$4,900
3rd Tax Year
$2,950
Each Succeeding Year
$1,775
REV. PROC. 2003–75 TABLE 3
DEPRECIATION LIMITATIONS FOR
§ 168(k)(4) PASSENGER AUTOMOBILES
(THAT ARE NOT TRUCKS, VANS, OR ELECTRIC AUTOMOBILES)
PLACED IN SERVICE BY THE TAXPAYER DURING CALENDAR YEAR 2003
Tax YearAmount
1st Tax Year
$10,710
2nd Tax Year
$4,900
3rd Tax Year
$2,950
Each Succeeding Year
$1,775
REV. PROC. 2003–75 TABLE 4
DEPRECIATION LIMITATIONS FOR TRUCKS AND VANS
(THAT ARE NOT § 168(k)(1) PASSENGER AUTOMOBILES
OR § 168(k)(4) PASSENGER AUTOMOBILES)
P
LACED IN SERVICE BY THE TAXPAYER DURING CALENDAR YEAR 2003
Tax YearAmount
1st Tax Year
$3,360
2nd
Tax Year
$5
,400
3rd Tax Year
$3,250
Each Succeeding Year
$1,975
2003-45 I.R.B.1021November 10, 2003

REV. PROC. 2003–75 TABLE 5
DEPRECIATION LIMITATIONS FOR TRUCKS AND VANS
THAT ARE § 168(k)(1) PASSENGER AUTOMOBILES
PLACED IN SERVICE BY THE TAXPAYER DURING CALENDAR YEAR 2003
Tax YearAmount
1st Tax Year
$7,960
2nd Tax Year
$5,400
3rd Tax Year
$3,250
Each Succeeding Year
$1,975
REV. PROC. 2003–75 TABLE 6
DEPRECIATION LIMITATIONS FOR TRUCKS AND VANS
(THAT ARE § 168(k)(4) PASSENGER AUTOMOBILES
PLACED IN SERVICE BY THE TAXPAYER DURING CALENDAR YEAR 2003
Tax YearAmount
1st Tax Year
$11,010
2nd Tax Year
$5,400
3rd Tax Year
$3,250
Each Succeeding Year
$1,975
REV. PROC. 2003–75 TABLE 7
DEPRECIATION LIMITATIONS FOR ELECTRIC AUTOMOBILES
(THAT ARE NOT § 168(k)(1) PASSENGER AUTOMOBILES
OR § 168(k)(4) PASSENGER AUTOMOBILES)
PLACED IN SERVICE BY THE TAXPAYER DURING CALENDAR YEAR 2003
Tax YearAmount
1st Tax Year
$9,080
2n
d Tax Year
$
14
,
600
3rd Tax Year
$8,750
Each Succeeding Year
$5,225
REV. PROC. 2003–75 TABLE 8
DEPRECIATION LIMITATIONS FOR ELECTRIC AUTOMOBILES
THAT ARE § 168(k) (1) PASSENGER AUTOMOBILES
PLACED IN SERVICE BY THE TAXPAYER DURING CALENDAR YEAR 2003
Tax YearAmount
1st Tax Year
$22,880
2nd Tax Year
$14,600
3rd Tax Year
$8,750
Each Succeeding Year
$5,225
November 10, 200310222003-45 I.R.B.

REV. PROC. 2003–75 TABLE 9
DEPRECIATION LIMITATIONS FOR ELECTRIC AUTOMOBILES
THAT ARE § 168(k)(4) PASSENGER AUTOMOBILES
PLACED IN SERVICE BY THE TAXPAYER DURING CALENDAR YEAR 2003
Tax YearAmount
1st Tax Year
$32,030
2nd Tax Year
$14,600
3rd Tax Year
$8,750
Each Succeeding Year
$5,225
03.Inclusions in Income of Lessees of
Passenger Automobiles.
The inclusion amounts for passen-
ger automobiles (including § 168(k)(1)
passenger automobiles and § 168(k)(4)
passenger automobiles) first leased in cal-
endar year 2003 are calculated under the
procedures described in § 1.280F–7(a).
Lessees of passenger automobiles other
than trucks, vans, and electric automo-
biles should use Table 10 of this revenue
procedure in applying these procedures,
while lessees of trucks and vans should
use Table 11 of this revenue procedure and
lessees of electric automobiles should use
Table 12 of this revenue procedure.
REV. PROC. 2003–75 TABLE 10
DOLLAR AMOUNTS FOR PASSENGER AUTOMOBILES
(THAT ARE NOT TRUCKS, VANS, OR ELECTRIC AUTOMOBILES)
WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2003
Fair Market Value of Passenger
Automobile
Tax Year During Lease
OverNot Over1st2nd3rd4th5th and Later
$18,000
18,5001022334045
18,50019,0001226394653
19,00019,5001430445361
19,50020,0001534505969
20,00020,5001737566677
20,50021,0001941617385
21,00021,5002145668092
21,50022,00022497287100
22,00023,00025548197111
23,00024,000286292110127
24,00025,0003270103123143
25,00026,0003577115137158
26,00027,0003985125151174
27,00028,0004292137165189
28,00029,00046100148178204
29,00030,00049108159191221
30,00031,00052115171205236
31,00032,00056123182218251
32,00033,00059130194231267
33,0
00
34,0
00
6313
8
20
4
24
5
28
3
34,00035,00066146215259298
35,00036,00070153227272314
36,00037,00073161238285330
37,00038,00077168249299346
38,00039,00080176260313361
39,00040,00083184272326376
40,00041,00087191283340391
2003-45 I.R.B.1023November 10, 2003

REV. PROC. 2003–75 TABLE 10
DOLLAR AMOUNTS FOR PASSENGER AUTOMOBILES
(THAT ARE NOT TRUCKS, VANS, OR ELECTRIC AUTOMOBILES)
WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2003
Fair Market Value of Passenger
Automobile
Tax Year During Lease
OverNot Over1st2nd3rd4th5th and Later
41,00042,00090199294353407
42,00043,00094206306366423
43,00044,00097214317380438
44,00045,000101221328394454
45,00046,000104229339407470
46,00047,000108236351420486
47,00048,000111244362434501
48,00049,000115251374447516
49,00050,000118259385460532
50,00051,000121267396474548
51,00052,000125274407488563
52,00053,000128282418502578
53,00054,000132289430515594
54,00055,000135297441528610
55,00056,000139304452542626
56,00057,000142312463556641
57,00058,000146320474569656
58,00059,000149327486582672
59,00060,000152335497596688
60,00062,000158346514616711
62,00064,000165361537642743
64,00066,000171377559670773
66,00068,000178392581697805
68,00070,000185407604724835
70,00072,000192422626751867
72,00074,000199437649778898
74,00076,000206452672804930
76,00078,000213467694832960
78,00080,000220483716859991
80,00085,0002325097569061,046
85,00090,0002495478129731,124
90,00095,0002665858681,0411,202
95,000100,0002846239241,1081,280
100,000110,0003096801,0091,2091,397
110,000120,0003447551,1221,3441,552
120,000130,0003788311,2341,4791,708
130,000140,0004139071,3461,6141,864
140,000150,0004479831,4591,7492,019
150,000160,0004821,0591,5711,8842,175
160,000170,0005161,1351,6832,0192,331
170,000180,0005511,2101,7962,1542,487
18
0
,0
00
19
0
,0
00
58
5
1,
286
1,
909
2,
288
2,
643
190,000200,0006201,3622,0212,4232,798
200,000210,0006541,4382,1332,5592,953
210,000220,0006891,5132,2462,6943,109
220,000230,0007231,5892,3592,8283,265
230,000240,0007581,6652,4712,9633,421
240,000250,0007921,7412,5833,0983,577
November 10, 200310242003-45 I.R.B.

REV. PROC. 2003–75 TABLE 11
DOLLAR AMOUNTS FOR TRUCKS AND VANS
WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2003
Fair Market Value of Truck or VanTax Year During Lease
OverNot Over1st2nd3rd4th5th and Later
$18,500
19,000714222429
19,00019,500818273236
19,50020,0001022333844
20,00020,5001226384552
20,50021,0001429445260
21,00021,5001534495967
21,50022,0001737556675
22,00023,0002043637686
23,00024,00023517489102
24,00025,000275886102118
25,00026,000306697116133
26,00027,0003373109129149
27,00028,0003781119143165
28,00029,0004089130157180
29,00030,0004496142170196
30,00031,00047104153183212
31,00032,00051111165196227
32,00033,00054119176210242
33,00034,00058126187224258
34,00035,00061134198238273
35,00036,00065141210251289
36,00037,00068149221264305
37,00038,00071157232278320
38,00039,00075164243292336
39,00040,00078172254305352
40,00041,00082179266318367
41,00042,00085187277332383
42,00043,00089194289345398
43,00044,00092202300358414
44,00045,00096209311373429
45,00046,00099217322386445
46,00047,000102225333400460
47,00048,000106232345413476
48,00049,000109240356426492
49,00050,000113247368439507
50,00051,000116255379453523
51,00052,000120263389467538
52,00053,000123270401480554
53,00054,000127278412493570
54,00055,000130285424507585
55,00
0
56,00
0
134293434521601
56,00057,000137301445534617
57,00058,000140308457548632
58,00059,000144316468561647
59,00060,000147323480575663
60,00062,000152335496595687
62,00064,000159350519622717
64,00066,000166365542648749
66,00068,000173380564676780
68,00070,000180395587702811
70,00072,000187410609730842
72,00074,000194426631757873
2003-45 I.R.B.1025November 10, 2003

REV. PROC. 2003–75 TABLE 11
DOLLAR AMOUNTS FOR TRUCKS AND VANS
WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2003
Fair Market Value of Truck or VanTax Year During Lease
OverNot Over1st2nd3rd4th5th and Later
74,00076,000201441654783905
76,00078,000208456676811935
78,00080,000215471699837967
80,00085,0002274977398851,021
85,00090,0002445357959521,099
90,00095,0002615738511,0201,177
95,000100,0002786119071,0881,254
100,000110,0003046689921,1881,372
110,000120,0003397441,1041,3231,527
120,000130,0003738201,2161,4581,683
130,000140,0004088951,3291,5931,839
140,000150,0004429711,4421,7281,994
150,000160,0004771,0471,5541,8622,151
160,000170,0005111,1231,6661,9982,306
170,000180,0005461,1981,7792,1332,462
180,000190,0005801,2741,8922,2672,618
190,000200,0006151,3502,0042,4022,773
200,000210,0006491,4262,1162,5372,929
210,000220,0006841,5022,2282,6723,085
220,000230,0007181,5782,3412,8073,240
230,000240,0007531,6532,4542,9423,396
240,000250,0007871,7292,5663,0773,552
REV. PROC. 2003–75 TABLE 12
DOLLAR AMOUNTS FOR ELECTRIC AUTOMOBILES
WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2003
Fair Market Value of Electric
Automobile
Tax Year During Lease
OverNot Over1st2nd3rd4th5th and Later
$53,000
54,000286090108124
54,00055,0003168101121140
55,00056,0003576112134156
56,00057,0003883124148171
57,00058,0004291134162187
58,00059,0004598146175203
59,00060,00049106157188218
60,00062,00054117174209241
62,00064,00061132197235273
64,00066,00068147219263304
66,00068,00075163241290334
68,00070,00081178264317366
70,00072,00088193287343397
72,00074,00095208309371428
74,00076,000102223332397460
76,00078,000109239353425491
78,00080,000116254376452521
November 10, 200310262003-45 I.R.B.

REV. PROC. 2003–75 TABLE 12
DOLLAR AMOUNTS FOR ELECTRIC AUTOMOBILES
WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2003
Fair Market Value of Electric
Automobile
Tax Year During Lease
OverNot Over1st2nd3rd4th5th and Later
80,00085,000128280416499576
85,00090,000145318472566655
90,00095,000162356528634732
95,000100,000180394584701810
100,000110,000206451668803926
110,000120,0002405277819371,082
120,000130,0002756028941,0721,238
130,000140,0003096781,0061,2071,394
140,000150,0003447541,1181,3421,550
150,000160,0003788301,2311,4771,705
160,000170,0004139051,3441,6121,861
170,000180,0004479811,4561,7472,017
180,000190,0004821,0571,5681,8822,172
190,000200,0005161,1331,6812,0162,329
200,000210,0005511,2081,7942,1512,484
210,000220,0005851,2841,9062,2872,639
220,000230,0006201,3602,0182,4212,796
230,000240,0006541,4362,1312,5562,951
240,000250,0006891,5112,2442,6913,107
04.Maximum Automobile Value for Us-
ing the Cents-per-mile Valuation Rule.
(1)Amount of Adjustment.Under
§ 1.61–21(e)(1)(iii)(A), the limitation on
the fair market value of an employer-pro-
vided passenger automobile first made
available to any employee for personal
use after 1988 is to be adjusted in accor-
dance with § 280F(d)(7). Accordingly,
the adjustment for any calendar year is
the percentage (if any) by which the CPI
automobile component for October of
the preceding calendar year exceeds the
CPI automobile component for October
1987.See, section 4.02(1) of this revenue
procedure. The new car component of
the CPI was 115.2 for October 1987 and
136.7 for October 2002. The October
2002 index exceeded the October 1987
index by 21.5. The Service has, therefore,
determined that the adjustment for 2003
is 18.66 percent (21.5/115.2 x 100%).
This adjustment is applicable to all em-
ployer-provided passenger automobiles
first made available to any employee for
personal use in calendar year 2003. The
maximum fair market value specified in
§ 1.61–21(e)(1)(iii)(A) must therefore
be multiplied by a factor of 0.1866, and
the resulting increase, after rounding to
the nearest $100, is added to $12,800 to
give the maximum value for calendar year
2003.
(2)The Maximum Automobile Value.
For passenger automobiles first made
available in calendar year 2003 to any em-
ployee of the employer for personal use,
the vehicle cents-per-mile valuation rule
may be applicable if the fair market value
of the passenger automobile on the date
it is first made available does not exceed
$15,200.
05.Revised Limitation Amounts for
§ 168(k)(1) Passenger Automobiles Placed
in Service During 2001 and 2002.
(1)Calculation of the Revised Amount.
The revised depreciation limits provided in
this section for § 168(k)(1) passenger auto-
mobiles (other than electric automobiles)
werecalculatedbyaugmentingtheexist-
ing limitations on the first year allowance
in Rev. Proc. 2001–19 (for passenger
automobiles placed in service in calendar
year 2001) and in Rev. Proc. 2002–14 (for
passenger automobiles placed in service
in calendar year 2002) by $4,600. Simi-
larly, the revised depreciation limits pro-
vided in this section for electric automo-
biles that are § 168(k)(1) passenger au-
tomobiles were calculated by augmenting
the existing limitations on the first year al-
lowance in Rev. Proc. 2001–19 (for elec-
tric automobiles placed in service in calen-
dar year 2001) and in Rev. Proc. 2002–14
(for electric automobiles placed in service
in calendar year 2002) by $13,800 ($4,600
tripled).
(2)Amount of the Revised Limitation.
For § 168(k)(1) passenger automobiles
(other than electric automobiles) placed in
service by the taxpayer in calendar year
2001, Table 13 of this revenue procedure
contains the revised dollar amount of
the depreciation limitations for each tax
year. For electric automobiles that are
§ 168(k)(1) passengerautomobiles placed
in service by the taxpayer in calendar
year 2001, Table 14 of this revenue pro-
cedure contains these revised amounts.
For § 168(k)(1) passenger automobiles
(other than electric automobiles) placed in
service by the taxpayer in calendar year
2002, Table 15 of this revenue procedure
contains the revised dollar amount of
2003-45 I.R.B.1027November 10, 2003

the depreciation limitations for each tax
year. For electric automobiles that are
§ 168(k)(1) passenger automobiles placed
in service by the taxpayer in calendar year
2002, Table 16 of this revenue procedure
contains these revised amounts.
REV. PROC. 2003–75 TABLE 13
DEPRECIATION LIMITATIONS FOR
§ 168(k)(1) PASSENGER AUTOMOBILES
(THAT ARE NOT ELECTRIC AUTOMOBILES) FIRST PLACED
IN SERVICE BY THE TAXPAYER IN CALENDAR YEAR 2001
Tax YearAmount
1st Tax Year
$7,660
2nd Tax Year
$4,900
3rd Tax Year
$2,950
Each Succeeding Year
$1,775
REV. PROC. 2003–75 TABLE 14
DEPRECIATION LIMITATIONS FOR ELECTRIC AUTOMOBILES
THAT ARE § 168(k)(1) PASSENGER AUTOMOBILES
FIRST PLACED IN SERVICE BY THE TAXPAYER IN
CALENDAR YEAR 2001
Tax YearAmount
1st Tax Year
$23,080
2nd Tax Year
$14,800
3rd Tax Year
$8,850
Each Succeeding Year
$5,325
REV. PROC. 2003–75 TABLE 15
DEPRECIATION LIMITATIONS FOR
§ 168(k)(1) PASSENGER AUTOMOBILES
(THAT ARE NOT ELECTRIC AUTOMOBILES) FIRST PLACED
IN SERVICE BY THE TAXPAYER IN CALENDAR YEAR 2002
Tax YearAmount
1st Tax Year
$7,660
2
nd Tax Year
$4,900
3rd Tax Year
$2,950
Each Succeeding Year
$1,775
November 10, 200310282003-45 I.R.B.

REV. PROC. 2003–75 TABLE 16
DEPRECIATION LIMITATIONS FOR ELECTRIC AUTOMOBILES
THAT ARE § 168(k)(1) PASSENGER AUTOMOBILES
FIRST PLACED IN SERVICE BY THE TAXPAYER IN
CALENDAR YEAR 2002
Tax YearAmount
1st Tax Year
$22,980
2nd Tax Year
$14,700
3rd Tax Year
$8,750
Each Succeeding Year
$5,325
SECTION 5. EFFECTIVE DATE
This revenue procedure, with the excep-
tion of section 4.05, applies to passenger
automobiles (other than leased passenger
automobiles) that are first placed in service
by the taxpayer during calendar year 2003,
to leased passenger automobiles that are
first leased by the taxpayer during calen-
dar year 2003, and to employer-provided
passenger automobiles first made available
to employees for personal use in calendar
year 2003. Section 4.05 of this revenue
procedure applies to § 168(k)(1) passenger
automobiles that are placed in service by
the taxpayer during calendar year 2001 or
2002.
SECTION 6. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2001–19 and Rev. Proc.
2002–14 are amplified.
DRAFTING INFORMATION
The principal author of this revenue
procedure is Bernard P. Harvey of the
Office of the Associate Chief Counsel
(Passthroughs and Special Industries). For
further information regarding the depre-
ciation limitations and lessee inclusion
amounts in this revenue procedure, con-
tact Mr. Harvey at (202) 622–3110; for
further information regarding the maxi-
mum automobile value for applying the
vehicle cents-per-mile valuation rule, con-
tact John B. Richards of the Office of the
Associate Chief Counsel (Tax Exempt and
Government Entities) at (202) 622–6040
(not toll-free calls).
26 CFR 601.403: Miscellaneo
us excise taxes col-
lected by return.
Rev. Proc. 2003–78
SECTION 1. PURPOSE
This revenue procedure provides in-
structions for establishing exemption from
the section 4371 excise tax on insurance
premiums paid to a foreign insurer or
reinsurer when the exemption is based on
the provisions of an income tax treaty to
which the United States is a party.
SECTION 2. BACKGROUND
.01 Section 4371 o
f the Internal Rev-
enue Code gener
ally imposes a tax (the
"insurance ex
cise tax") on each policy of
insurance or r
einsurance with respect to
United State
s risks issued by any foreign
insurerorr
einsurer, unless the premiums
paid are tax
ed as income effectively con-
nected wi
th the conduct of a United States
trade or b
usiness.
.02 Secti
on 4374 provides that the in-
surance e
xcise tax shall be paid by any per-
son who m
akes, signs, issues, or sells any
of the do
cuments and instruments subject
to the t
ax, or for whose use or benefit the
same a
re made, signed, issued or sold.
.03 Sec
tion 46.4374–1(c) of the Excise
Tax Re
gulations provides that the insur-
ance
excise tax shall be paid on the basis
of a r
eturn. Such return shall be filed and
tax
remittedbythepersonwhomakesthe
pay
ment of a premium to a foreign insurer
or
reinsurer. If the tax is not paid by the
p
erson who makes payment of a premium,
t
he insurance excise tax shall be paid on the
basis of a return by any person who makes,
signs, issues or sells any of
the documents
or instruments subject to t
he tax imposed
by section 4371, or for whos
e use or ben-
efit such document or inst
rument is made,
signed, issued or sold.
.04 Pursuant to income t
ax treaties be-
tween the United State
s and several coun-
tries, policies issu
ed by a foreign insurer
or reinsurer that is
a resident of any of
such countries may
be exempt from the in-
surance excise tax
. This revenue proce-
dure applies to
a treaty excise tax exemp-
tion that is eit
her a qualified exemption
(for example,
the exemption in the treaties
with Germany
and France) or an exemp-
tion subject
to an anti-conduit arrangement
limitation
(for example, the exemption in
the treaty
with the United Kingdom), de-
pending o
n the treaty.
SECTION 3. EXEMPTION
PROCEDURE
.01 A person oth
erwise required to re-
mit the insur
ance excise tax on account
of premiums
paid to a foreign insurance
or reinsura
nce company may consider the
premiums e
xempt from the insurance ex-
cise tax un
der an income tax treaty if the
premiums
are paid to an insurer or rein-
surer th
at is a resident for treaty purposes
of a cou
ntry with which the United States
has a tr
eaty containing an excise tax ex-
empti
on and, prior to filing the return for
the ta
xable period, such person has knowl-
edge
that there was in effect for such tax-
abl
e period a closing agreement between
the
Internal Revenue Service and the for-
ei
gn insurer or reinsurer as provided by
se
ction 3.04(2). As part of the closing
a
greement, the foreign insurer or reinsurer
m
ust agree to be liable as a United States
2003-45 I.R.B.1029November 10, 2003

taxpayer for the insurance excise tax pur-
suant to section 4371et seq., subject to
an applicable exemption under the relevant
treaty or any other United States treaty.
However,apersonrequiredtoremitthe
excise tax may not consider the premiums
exempt if prior to filing the return for the
taxable period such person has knowledge
that the foreign insurer or reinsurer did
not qualify for benefits under the relevant
treaty during the taxable period.
.02 Premiums paid on policies written
by a foreign insurer or reinsurer cannot
qualify for exemption from the insurance
excise tax under a treaty with a qualified
exemption to the extent that the risks cov-
ered by such premiums are reinsured with
a person not entitled to the benefits of the
relevant treaty or any other treaty that pro-
vides exemption from the insurance ex-
cise tax. Premiums paid on policies writ-
ten by a foreign insurer or reinsurer cannot
qualify for exemption from the insurance
excise tax under a treaty with an exemp-
tion subject to an anti-conduit arrangement
limitation to the extent that the premium is
paid pursuant to a conduit arrangement as
defined in the treaty.
.03Inadditiontotherequirementsof
sections 3.01 and 3.02, premiums paid
on policies written by a foreign insurer
or reinsurer cannot qualify for exemption
from the insurance excise tax under a
treaty to which the United States is a party
unless the foreign insurer or reinsurer
qualifies for benefits under the relevant
treaty, including the limitation on benefits
provision.
.04 A foreign insurer or reinsurer that
wishes to enter into a closing agreement
under this revenue procedure must:
(1) Submit the following information
and documentation:
a. A statement signed under penalties
of perjury that:
i. The foreign insurer or reinsurer is
a resident of
(name of
treaty country) for purposes of the in-
come tax treaty between the United States
and
(name of
treaty country); and
ii. The foreign insurer or reinsurer
qualifies for benefits under the Limita-
tion on Benefits Article of the income
tax treaty between the United States and
(name
of treaty country), accompanied by an ex-
planation of the basis on which the foreign
insurer or reinsurer so qualifies;
b. A letter of credit in the amount of
$75,000. The Service may determine at
any time that circumstances warrant a let-
ter of credit in an increased amount and
will notify the taxpayer if such a determi-
nation is made;
c. A completed Form SS–4 (Applica-
tion for Employer Identification Number)
to apply for an EIN if the applicant does
not already have an EIN;
d. A list of the position titles of those
persons who will be the responsible parties
for performance under the closing agree-
ment, and the names, addresses, and tele-
phone numbers of those persons as of the
date the application is submitted; and
(2) Enter into a closing agreement iden-
tical to the form set forth in Appendix A
of this revenue procedure for treaties with
qualified exemptions, or Appendix B of
this revenue procedure for treaties with an
exemption subject to ananti-conduit ar-
rangement limitation.
.05 (1) Any foreign insurer or reinsurer
wishing to enter into a closing agreement
under this revenue procedure should sub-
mit a request for a closing agreement in ac-
cordance with Rev. Proc. 2003–1, 2003–1
I.R.B. 1, or any successor procedure, with
the user fee stated in Appendix A of Rev.
Proc. 2003–1, or any successor procedure,
to the following address:
Internal Revenue Service
Attn: LM:IN:FP
1111 Constitution Avenue, NW
Washington, DC 20224
Telephone: (202) 435–5080
Fax: (202) 435–5082
(2) The request must be accompanied
by three (3) copies of the closing agree-
ment with an original signature on each
copy and the information and documenta-
tion required by section 3.04. The Inter-
nal Revenue Service will sign the closing
agreement and return one (1) copy to the
Taxpayer.
SECTION 4. PERIODIC LISTING OF
AGREEMENTS
The Service may periodically publish
in the Internal Revenue Bulletin a list of
foreign insurers or reinsurers that have en-
tered into closing agreements under this
revenue procedure and also a list of foreign
insurers or reinsurers whose closing agree-
ments are terminated.
SECTION 5. EFFECTIVE DATE
This revenue procedure is effective
October 10, 2003.
SECTION 6. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 92–39, 1992–1 C.B. 860, is
superceded except with respect to existing
closing agreements. With respect to clos-
ing agreements in existence prior to the ef-
fective date of this revenue procedure, the
Internal Revenue Service will treat a tax-
payer as fully complying with the require-
ments of Paragraph 7(b) of a closing agree-
ment under Rev. Proc. 92–39, Rev. Proc.
87–13, 1987–1 C.B. 596, or Rev. Proc.
84–82, 1984–2 C.B. 779 (requiring the tax-
payer (i) to obtain a certificate of residency
from the tax authorities in its home juris-
diction every three years, and/or (ii) to cer-
tify its eligibility for benefits under the rel-
evant treaty on an annual basis), if such
taxpayer complies with the certification of
residency and entitlement to treaty benefits
requirement as provided in paragraph 9 of
the closing agreement set forth in Appen-
dix A of this revenue procedure (requiring
the taxpayer to certify residency and qual-
ification for eligibility for benefits under
the relevant treaty every three years and
without a requirement for obtaining a cer-
tificate of residency from the tax authori-
ties of the taxpayer’s home jurisdiction).
SECTION 7. DRAFTING
INFORMATION
The principal autho
r of this revenue
procedure is Karen
Rennie-Quarrie of the
Office of the Assoc
iate Chief Counsel
(International
). For further information on
this procedure,
call Ms. Rennie-Quarrie
or Mr. W. Edward
Williams at (202)
622–3880 (not
a toll-free call).
November 10, 200310302003-45 I.R.B.

APPENDIX A
FORM OF CLOSING AGREEMENT FOR CONVENTIONS
WITH A QUALIFIED EXEMPTION
CLOSING AGREEMENT ON FINAL
DETERMINATION COVERING
SPECIFIC MATTERS
Undersection 7121 of the Internal Revenue Code of 1986, as amended (the “Code”), the taxpayer (as identified on the signature
page of this agreement by taxpayer’s name and address) (herein referred to as “Taxpayer”) and the Commissioner of Internal Revenue
(the “Commissioner”) make the following closing agreement (this “Closing Agreement”):
WHEREAS, the Business Profits article of the income tax convention between the United States and Treaty Country (as identified
on the signature page of this Closing Agreement), under which benefits are being claimed (the “Convention”), exempts insurance or
reinsurance premiums paid to a resident of Treaty Country from the Federal excise tax imposed by section 4371et seq.oftheCode(the
“Insurance Excise Tax”) only to the extent that (i) Taxpayer does not reinsure such risks with a person not entitled to exemption from
such tax under the Convention or any other income tax convention between the United States and another country, (ii) the premium
was a receipt of a business of insurance carriedon by an enterprise of Treaty Country, and (iii)the insurer or reinsurer qualifies under
the Limitation on Benefits article of the Convention;
WHEREAS, section 3.01 of Rev. Proc. 2003–78 provides that the person otherwise required to remit the Insurance Excise Tax
on account of premiums paid to a foreign insurance or reinsurance company may consider the premium exempt from the Insurance
Excise Tax under an income tax treaty if premiums are paid to an insurer or reinsurer that is a resident for treaty purposes of a country
with which the United States has a treaty containing an excise tax exemption and, prior to filing the return for the taxable period, such
person has knowledge that Taxpayer has in effect for such taxable period a closing agreement with the Internal Revenue Service to be
liable as a United States taxpayer for the Insurance Excise Tax pursuant to section 4371et seq., subject to an applicable exemption
under the Convention or any other convention from the Insurance Excise Tax; and
WHEREAS, Taxpayer represents that it is and anticipates continuing to be eligible for benefits under the Convention.
IT IS HEREBY DETERMINED AND AGREED THAT:
(1) Taxpayer shall, for purposes of this closing agreement, be liable as a United States taxpayer for the Insurance Excise Tax on
premiums pursuant to section 4371et seq., subject to an applicable exemption from the Insurance Excise Tax under the Convention
or any other convention.
(2)(a) Returns of Insurance Excise Tax due under and pursuant to this Closing Agreement and section 4371et seq.of the Code
shall be made by Taxpayer, or by Taxpayer’s authorized representative on Taxpayer’s behalf, by filing Form 720,Quarterly Federal
Excise Tax Return, for each return period covered by this Closing Agreement.
(b) For purposes of determining the tax with respect to premiumsreceived on policies issued by the Taxpayer that do not qualify
for an exemption under the Convention becauseTaxpayer reinsures, in whole or in part, a policy of insurance or reinsurance with any
person(s) not entitled to exemption from the Insurance Excise Tax under the Convention or any other convention, the tax reportable
on the return (Form 720) shall be computed on the basis of the percentage of such policies reinsured. For purposes of the preceding
sentence, Taxpayer may consider a reinsurer to be entitled to exemption from the excise tax if the reinsurer is a party to a closing
agreement with the Internal Revenue Service, pursuant to Rev. Proc. 2003–78 or a predecessor revenue procedure, under the Conven-
tion or an income tax convention between the United States and another country.
(c) Forms 720 shall be filed with the Internal Revenue Service Center, Cincinnati, OH 45999–0009.
(d) Taxpayer, or Taxpayer’s authorized representative, shall make the required Federal tax deposits of the Insurance Excise Tax in
such manner and at such times as are provided in the Federal tax regulations and in the instructions for Form 720.
(3) Taxpayer agrees that this Closing Agreement is not intended to modify the liability for the Insurance Excise Tax under section
4371et seq.of the Code.
(4) Taxpayer agrees that, for purposes of determining its Insurance Excise Tax liability pursuant to this Closing Agreement and for
purposes of verifying Taxpayer’s entitlement to benefits under the Convention, Taxpayer will maintain for a period of 6 years from the
end of each taxable period to which this Closing Agreement applies(i) accounts and records of items of insurance and reinsurance,
and (ii) records to establish eligibility for benefits under the Convention, in each case, that will be made available upon written request
by the Internal Revenue Service at the place mutually agreed uponby the Service and Taxpayer. Taxpayer will be allowed 60 days, or
other period of time determined as reasonable by the Service within which to make available its accounts and records.
(5) If it is determined that there is an underpayment in respect ofany Insurance Excise Tax determined to be due pursuant to this
Closing Agreement and section 4371et seq.of the Code, the Internal Revenue Service shall issue a statement of notice and demand
for the tax due plus any interest and applicable penalties. Notice of any underpayment shall be sent to Taxpayer at the name and
address shown on the Form 720, if a Form 720 was filed for the period for which an underpayment is determined by the Internal
Revenue Service, or otherwise to Taxpayer’s registered addressin Treaty Country. Payment of all additional amounts due shall be
2003-45 I.R.B.1031November 10, 2003

made in accordance with the terms specified inthe statement of notice and demand. Collection of such amounts not paid per notice
and demand shall be in accordancewith paragraph (6) hereof.
(6)(a) As security for payment of tax, Taxpayer shall cause an irrevocable letter of credit to be issued by a United States bank that is
amemberoftheFederalReserveSystem,orbyaUnitedStatesbranchoragencyofaforeignbankthatisontheNationalAssociation
of Insurance Commissioners list of banks from which letters of credit may be accepted, in favor of the Internal Revenue Service in
the amount of $75,000, unless the Internal Revenue Service determines that circumstances warrant a letter of credit in an increased
amount. Such letter of credit must be effective as of the date that the Closing Agreement is signed by the Commissioner or his delegate.
(b) The Service may issue a statement of notice and demand with respect to:
(i) Any tax shown on a Form 720 (original, amended, or substitute for return) that is not paid with such return; or
(ii) Any proposed additional liability for the Insurance Excise Tax sustained by the Internal Revenue Service Regional Director of
Appeals having jurisdiction over such matter, if the time for filinga protest of such proposed liability has expired, provided that the
statement of notice and demand has been issued as provided in paragraph (5) hereof.
(c) If, after the conditions in paragraph (6)(b) hereof have been met, the tax, interest, and any applicable penalties are not paid in
accordance with the terms of the statement ofnotice and demand, collection of such amounts will be made by resorting to such letter
of credit, to the extent thereof, before any levy or proceeding in court for collection is instituted against Taxpayer.
(d) If such letter of credit is drawn upon, it must be reinstated to $75,000, or such higher amount as determined by the Internal
Revenue Service pursuant to paragraph(6)(a) of this Closing Agreement, within 60 days after the date drawn upon.
(7)(a) Solely by reason of the execution by Taxpayer and the Commissioner of this Closing Agreement, any person otherwise
required to remit the Insurance Excise Tax on insurance or reinsurance premiums pursuant to section 46.4374–1(c) of the Excise
Tax Regulations may consider premiums paid to Taxpayer after the effective date of this Closing Agreement as exempt under the
Convention from the Insurance Excise Tax, unless such person has knowledge that the foreign insurer or reinsurer did not qualify for
benefits under the Convention during the relevant taxable period.
(b) Taxpayer agrees that the Commissioner or his or her authorized delegate may disclose,by publication or otherwise, Taxpayer’s
name as an insurer or reinsurer that has entered intoa closing agreement under this revenue procedure.
(8) Taxpayer agrees to promptly notify the Competent Authorityof Treaty Country and the Internal Revenue Service of any change
that results in Taxpayer no longer qualifying for benefits under the Convention with respect to the Insurance Excise Tax. Taxpayer
also agrees to promptly notify any person that has previously relied on this Closing Agreement and is required to remit the Insurance
Excise Tax on account of premiums paid to Taxpayer that Taxpayer is not entitled to exemption from the Insurance Excise Tax.
(9) The statement submitted in accordancewith section 3.04(1)(a) of Rev. Proc. 2003–78 is valid for the period provided in
section 1.1441–1(e)(4)(ii) of the Treasury Regulations, or any successor regulations, beginning on the effective date of this Closing
Agreement. On or before the expiration of the original validity period, or any subsequent validity period, Taxpayer will file with the
Commissioner the same statement, signed under penalties of perjury, along with one copy of the closing agreement to the address set
forth in subparagraph (e) of paragraph (10).
(10)(a) This Closing Agreement shall continue in effect until terminated as providedin subparagraph (b) of this paragraph.
(b) This Closing Agreement may be terminated by either Taxpayer or the Commissioner by giving the other written notice of the
notifying party’s intent to terminate. The decision to terminate is solely at the discretion of the party giving such notice. This Closing
Agreement shall be terminated at the close of the last day of the quarterly return period immediately following the return period within
which the written notice of termination is given. Taxpayer agrees that the Commissioner or his or her authorized delegate may disclose,
by publication or otherwise, Taxpayer’s name as an insurer or reinsurer whose closing agreement under this revenue procedure has
been terminated.
(c) Taxpayer hereby agrees to file a return, Form 720, marked “Final Return” for the taxable period within which this Closing
Agreement terminates pursuant to subparagraph (b) of this paragraph, in accordance with rules provided in the Federal tax regulations
and the instructions for Form 720. Taxpayer also agrees to furnish a duplicate of such “Final Return” to the address set forth in
subparagraph (e) of this paragraph.
(d) Taxpayer agrees that the letter of credit issued pursuant to paragraph (6) hereof shall remain in effect for a period of not less
than 60 days after the “Final Return” has been filed in accordance with subparagraph (c) hereof, or until the examination of Taxpayer’s
returns is completed and any additional tax due has been paid, whichever is later.
(e) Taxpayer agrees to file the statement required by paragraph (9) and the duplicate Form 720 required by subparagraph (c) of this
paragraph at the following address:
Internal Revenue Service
Attn: LM:IN:FP
1111 Constitution Avenue, NW
Washington, DC 20224
WHEREAS, the determinations set forthabove are hereby agreed to by Taxpayer:
This Closing Agreement is final and conclusive except:
(1) the matter it relates to may be reopened in the event of fraud, malfeasance, or misrepresentation of material fact;
November 10, 200310322003-45 I.R.B.

(2) it is subject to the Code sections that expressly provide that effect be given to their provisions (including any stated exception
for section 7122) notwithstanding any other law or rule of law; and
(3) if it relates to a tax period ending after the date of this agreement, it is subject to any change or modification of applicable
statutes or tax conventions that apply to that tax period.
IN WITNESS WHEREOF, the above parties have subscribed their names to these presents, in triplicate.
Date
By
Title
(Name of Taxpayer and authorized representative)
Address
Taxpayer Identification Number
(If the applicant does not already have a TIN, one will be supplied by the Service pursuant to the completed Form SS–4
submitted with the request for the closing agreement)
Treaty Country
Commissioner of the Internal Revenue
By
Associate Chief Counsel (International)
Date
By
Director, International
Date
APPENDIX B
FORM OF CLOSING AGREEMENT FOR CONVENTIONS
WITH AN ANTI-CONDUIT LIMITATION
CLOSING AGREEMENT ON FINAL
DETERMINATION COVERING
SPECIFIC MATTERS
Undersection 7121 of the Internal Revenue Code of 1986, as amended (the “Code”), the taxpayer (as identified on the signature
page of this agreement by taxpayer’s name and address) (herein referred to as “Taxpayer”) and the Commissioner of Internal Revenue
(the “Commissioner”) make the following closing agreement (this “Closing Agreement”):
WHEREAS, the Business Profits article of the income tax convention between the United States and Treaty Country (as identified
on the signature page of this Closing Agreement), under which benefits are being claimed (the “Convention”), exempts insurance or
reinsurance premiums paid to a resident of Treaty Country from the Federal excise tax imposed by section 4371et seq.of the Code
(the “Insurance Excise Tax”) only to the extent that (i) the policy was not entered into as part of a conduit arrangement, (ii) the premium
was a receipt of a business of insurance carriedon by an enterprise of Treaty Country, and (iii)the insurer or reinsurer qualifies under
the Limitation on Benefits article of the Convention;
WHEREAS, section 3.01 of Rev. Proc. 2003–78 provides that the person otherwise required to remit the Insurance Excise Tax
on account of premiums paid to a foreign insurance or reinsurance company may consider the premium exempt from the Insurance
Excise Tax under an income tax treaty if premiums are paid to an insurer or reinsurer that is a resident for treaty purposes of a country
with which the United States has a treaty containing an excise tax exemption and, prior to filing the return for the taxable period, such
person has knowledge that Taxpayer has in effect for such taxable period a closing agreement with the Internal Revenue Service to be
liable as a United States taxpayer for the Insurance Excise Tax pursuant to section 4371et seq., subject to an applicable exemption
under the Convention or any other convention from the Insurance Excise Tax; and
WHEREAS, Taxpayer represents that it is and anticipates continuing to be eligible for benefits under the Convention.
IT IS HEREBY DETERMINED AND AGREED THAT:
(1) Taxpayer shall, for purposes of this closing agreement, be liable as a United States taxpayer for the Insurance Excise Tax on
premiums pursuant to section 4371et seq., subject to an applicable exemption from the Insurance Excise Tax under the Convention
or any other convention.
2003-45 I.R.B.1033November 10, 2003

(2)(a) Returns of Insurance Excise Tax due under and pursuant to this Closing Agreement and section 4371et seq.of the Code
shall be made by Taxpayer, or by Taxpayer’s authorized representative on Taxpayer’s behalf, by filing Form 720,Quarterly Federal
Excise Tax Return, for each return period covered by this Closing Agreement.
(b) For purposes of determining the tax with respect to premiumsreceived on policies issued by the Taxpayer that do not qualify
for an exemption under the Convention becauseTaxpayer, as part of a conduit arrangement, reinsures, in whole or in part, a policy
of insurance or reinsurance with any person(s) not entitled to exemption from the Insurance Excise Tax under the Convention or
any other convention, the tax reportable on the return (Form 720)shall be computed on the basis of the percentage of such policies
reinsured. For purposes of the preceding sentence, Taxpayer may consider a reinsurer to be entitled to exemption from the excise tax
if the reinsurer is a party to a closing agreement with the Internal Revenue Service, pursuant to Rev. Proc. 2003–78 or a predecessor
revenue procedure, under the Convention or an income tax convention between the United States and another country.
(c) Forms 720 shall be filed with the Internal Revenue Service Center, Cincinnati, OH 45999–0009.
(d) Taxpayer, or Taxpayer’s authorized representative, shall make the required Federal tax deposits of the Insurance Excise Tax in
such manner and at such times as are provided in the Federal tax regulations and in the instructions for Form 720.
(3) Taxpayer agrees that this Closing Agreement is not intended to modify the liability for the Insurance Excise Tax under section
4371et seq.of the Code.
(4) Taxpayer agrees that, for purposes of determining its Insurance Excise Tax liability pursuant to this Closing Agreement and for
purposes of verifying Taxpayer’s entitlement to benefits under the Convention, Taxpayer will maintain for a period of 6 years from the
end of each taxable period to which this Closing Agreement applies(i) accounts and records of items of insurance and reinsurance,
and (ii) records to establish eligibility for benefits under the Convention, in each case, that will be made available upon written request
by the Internal Revenue Service at the place mutually agreed uponby the Service and Taxpayer. Taxpayer will be allowed 60 days, or
other period of time determined as reasonable by the Service within which to make available its accounts and records.
(5) If it is determined that there is an underpayment in respect ofany Insurance Excise Tax determined to be due pursuant to this
Closing Agreement and section 4371et seq.of the Code, the Internal Revenue Service shall issue a statement of notice and demand
for the tax due plus any interest and applicable penalties. Notice of any underpayment shall be sent to Taxpayer at the name and
address shown on the Form 720, if a Form 720 was filed for the period for which an underpayment is determined by the Internal
Revenue Service, or otherwise to Taxpayer’s registered addressin Treaty Country. Payment of all additional amounts due shall be
made in accordance with the terms specified inthe statement of notice and demand. Collection of such amounts not paid per notice
and demand shall be in accordancewith paragraph (6) hereof.
(6)(a) As security for payment of tax, Taxpayer shall cause an irrevocable letter of credit to be issued by a United States bank that is
amemberoftheFederalReserveSystem,orbyaUnitedStatesbranchoragencyofaforeignbankthatisontheNationalAssociation
of Insurance Commissioners list of banks from which letters of credit may be accepted, in favor of the Internal Revenue Service in
the amount of $75,000, unless the Internal Revenue Service determines that circumstances warrant a letter of credit in an increased
amount. Such letter of credit must be effective as of the date that the Closing Agreement is signed by the Commissioner or his delegate.
(b) The Service may issue a statement of notice and demand with respect to:
(i) Any tax shown on a Form 720 (original, amended, or substitute for return) that is not paid with such return; or
(ii) Any proposed additional liability for the Insurance Excise Tax sustained by the Internal Revenue Service Regional Director of
Appeals having jurisdiction over such matter, if the time for filinga protest of such proposed liability has expired, provided that the
statement of notice and demand has been issued as provided in paragraph (5) hereof.
(c) If, after the conditions in paragraph (6)(b) hereof have been met, the tax, interest, and any applicable penalties are not paid in
accordance with the terms of the statement ofnotice and demand, collection of such amounts will be made by resorting to such letter
of credit, to the extent thereof, before any levy or proceeding in court for collection is instituted against Taxpayer.
(d) If such letter of credit is drawn upon, it must be reinstated to $75,000, or such higher amount as determined by the Internal
Revenue Service pursuant to paragraph(6)(a) of this Closing Agreement, within 60 days after the date drawn upon.
(7)(a) Solely by reason of the execution by Taxpayer and the Commissioner of this Closing Agreement, any person otherwise
required to remit the Insurance Excise Tax on insurance or reinsurance premiums pursuant to section 46.4374–1(c) of the Excise
Tax Regulations may consider premiums paid to Taxpayer after the effective date of this Closing Agreement as exempt under the
Convention from the Insurance Excise Tax, unless such person has knowledge that the foreign insurer or reinsurer did not qualify for
benefits under the Convention during the relevant taxable period.
(b) Taxpayer agrees that the Commissioner or his or her authorized delegate may disclose,by publication or otherwise, Taxpayer’s
name as an insurer or reinsurer that has entered intoa closing agreement under this revenue procedure.
(8) Taxpayer agrees to promptly notify the Competent Authorityof Treaty Country and the Internal Revenue Service of any change
that results in Taxpayer no longer qualifying for benefits under the Convention with respect to the Insurance Excise Tax. Taxpayer
also agrees to promptly notify any person that has previously relied on this Closing Agreement and is required to remit the Insurance
Excise Tax on account of premiums paid to Taxpayer that Taxpayer is not entitled to exemption from the Insurance Excise Tax.
(9) The statement submitted in accordancewith section 3.04(1)(a) of Rev. Proc. 2003–78 is valid for the period provided in
section 1.1441–1(e)(4)(ii) of the Treasury Regulations, or any successor regulations, beginning on the effective date of this Closing
Agreement. On or before the expiration of the original validity period, or any subsequent validity period, Taxpayer will file with the
November 10, 200310342003-45 I.R.B.

Commissioner the same statement, signed under penalties of perjury, along with one copy of the closing agreement to the address set
forth in subparagraph (e) of paragraph (10).
(10)(a) This Closing Agreement shall continue in effect until terminated as providedin subparagraph (b) of this paragraph.
(b) This Closing Agreement may be terminated by either Taxpayer or the Commissioner by giving the other written notice of the
notifying party’s intent to terminate. The decision to terminate is solely at the discretion of the party giving such notice. This Closing
Agreement shall be terminated at the close of the last day of the quarterly return period immediately following the return period within
which the written notice of termination is given. Taxpayer agrees that the Commissioner or his or her authorized delegate may disclose,
by publication or otherwise, Taxpayer’s name as an insurer or reinsurer whose closing agreement under this revenue procedure has
been terminated.
(c) Taxpayer hereby agrees to file a return, Form 720, marked “Final Return” for the taxable period within which this Closing
Agreement terminates pursuant to subparagraph (b) of this paragraph, in accordance with rules provided in the Federal tax regulations
and the instructions for Form 720. Taxpayer also agrees to furnish a duplicate of such “Final Return” to the address set forth in
subparagraph (e) of this paragraph.
(d) Taxpayer agrees that the letter of credit issued pursuant to paragraph (6) hereof shall remain in effect for a period of not less
than 60 days after the “Final Return” has been filed in accordance with subparagraph (c) hereof, or until the examination of Taxpayer’s
returns is completed and any additional tax due has been paid, whichever is later.
(e) Taxpayer agrees to file the statement required by paragraph (9) and the duplicate Form 720 required by subparagraph (c) of this
paragraph at the following address:
Internal Revenue Service
Attn: LM:IN:FP
1111 Constitution Avenue, NW
Washington, DC 20224
WHEREAS, the determinations set forthabove are hereby agreed to by Taxpayer:
This Closing Agreement is final and conclusive except:
(1) the matter it relates to may be reopened in the event of fraud, malfeasance, or misrepresentation of material fact;
(2) it is subject to the Code sections that expressly provide that effect be given to their provisions (including any stated exception
for section 7122) notwithstanding any other law or rule of law; and
(3) if it relates to a tax period ending after the date of this agreement, it is subject to any change or modification of applicable
statutes or tax conventions that apply to that tax period.
IN WITNESS WHEREOF, the above parties have subscribed their names to these presents, in triplicate.
Date
By
Title
(Name of Taxpayer and authorized representative)
Address
Taxpayer Identification Number
(If the applicant does not already have a TIN, one will be supplied by the Service pursuant to the completed Form SS–4
submitted with the request for the closing agreement)
Treaty Country
Commissioner of the Internal Revenue
By
Associate Chief Counsel (International)
Date
By
Director, International
Date
2003-45 I.R.B.1035November 10, 2003

26 CFR 601.204: Changes in accounting periods and
methods of accounting.
(Also Part I, §§ 442; 1.442–1.)
Rev. Proc. 2003–79
SECTION 1. PURPOSE
Rev. Proc. 2002–38, 2002–1 C.B.
1037, and Rev. Proc. 2002–39, 2002–1
C.B. 1046, provide procedures for a part-
nershiporScorporationtochangeits
annual accounting period if its current tax-
able year no longer qualifies as a natural
business year (or, for certain S corpora-
tions, an ownership taxable year). This
revenue procedure provides procedures
under which a partner or S corporation
shareholder (within the scope of this rev-
enue procedure) of such a partnership
or S corporation may elect to take into
account ratably over four taxable years the
partner’s or S corporation shareholder’s
share of income from the partnership or S
corporation that is attributable to the short
taxable year ending on or after May 10,
2002, but before June 1, 2004.
SECTION 2. BACKGROUND
.01 Section 442 of the Internal Revenue
Code and § 1.442–1(a) of the Income Tax
Regulations generally provide that a tax-
payer that wants to change its annual ac-
counting period and use a new taxable year
must obtain the approval of the Commis-
sioner.
.02 Section 1.442–1(b)(2) provides,
in relevant part, that a change in annual
accounting period will be approved only
where the taxpayer agrees to the Commis-
sioner’s prescribed terms, conditions, and
adjustments for effecting the change.
.03 Section 1.442–1(b)(3) provides that
such terms, conditions, and adjustments
may include adjustments necessary to neu-
tralize the tax effects of a substantial dis-
tortion of income that would otherwise re-
sult from the requested annual accounting
period.
.04 Rev. Proc. 2002–38 provides the
exclusive procedures for certain partner-
ships and S corporations to obtain auto-
matic approval to adopt, change, or re-
tain their annual accounting periods under
§ 442 and § 1.442–1(b). Among the provi-
sions of Rev. Proc. 2002–38:
(1) Section 4 provides that a partner-
ship or S corporation may secure the Com-
missioner’s approval to adopt or change to
its “required taxable year,” a “natural busi-
ness year,” or an “ownership taxable year;”
(2) Section 5.04 defines a “permitted
taxable year” to include a required taxable
year, natural business year, or ownership
taxable year;
(3) Section 5.05 provides that a partner-
ship or S corporation establishes a natural
business year by satisfying a “25-percent
gross receipts test;”
(4) Section 5.06 provides generally that
an S corporation shareholder that is a tax-
exempt entity under § 501(a) and that is not
subject to tax on any income attributable
to the S corporation is disregarded for pur-
poses of determining an ownership taxable
year of the S corporation unless the S cor-
poration is wholly-owned by such tax-ex-
empt entity; and
(5) Sections 6.05 and 6.06 provide that
if a taxpayer changes to or retains a natu-
ral business year or an ownership taxable
year and that year no longer qualifies as
a permitted taxable year, the taxpayer is
using an impermissible annual accounting
period and should change to a permitted
taxable year under Rev. Proc. 2002–38 or
Rev. Proc. 2002–39, whichever applies.
.05 Rev. Proc. 2002–39 provides the
exclusive procedures for taxpayers, in-
cluding partnerships and S corporations,
that do not qualify under one of the auto-
matic approval procedures, to obtain prior
approval of the Commissioner to adopt,
change, or retain their annual accounting
periods under § 442 and § 1.442–1(b).
Among the provisions of Rev. Proc.
2002–39:
(1) Section 5.01 provides that a re-
quest to adopt, change, or retain an
annual accounting period ordinarily will
be approved if the taxpayer establishes a
business purpose;
(2) Section 5.02 provides that a tax-
payer requesting to adopt, change, or re-
tain an annual accounting period that is the
taxpayer’s natural business year has estab-
lished a business purpose to the satisfac-
tion of the Commissioner;
(3)Section5.03providesthatanatu-
ral business year of a taxpayer may be de-
termined under the “annual business cycle
test,” the “seasonal business test,” or the
“25% gross receipts test;” and
(4)Section5.04providesthatifapart-
nership or S corporation changed to or re-
tained under Rev. Proc. 2002–39 a tax-
able year that was its natural business year,
and that taxable year no longer qualifies as
a permitted taxable year, the partnership
or S corporation is using an impermissi-
ble annual accountingperiod and should
change to a permitted taxable year un-
der Rev. Proc. 2002–38 or Rev. Proc.
2002–39, whichever applies.
.06 In the case of a partnership or S cor-
poration that changes its taxable year to a
permitted taxable year, a partner or S cor-
poration shareholder may be required to
include in gross income in a single tax-
able year income items and expense items
from more than one taxable year of the
partnership or S corporation. The Inter-
nal Revenue Service and Treasury Depart-
ment have determined that it is appropriate
to allow partners andS corporation share-
holders within the scope of this revenue
procedure to elect to spread ratably over
a four-year period their share of income
from the partnership’s or S corporation’s
short taxable year.
SECTION 3. DEFINITIONS
For purposes of this revenue proce
dure:
.01Share of income.The term “share
of income” means a partner’s or S co
rpora-
tion shareholder’s share of “i
ncome items”
that exceeds its share of “expe
nse items”
from the partnership or S corp
oration that
are attributable to the shor
t taxable year;
.02Income Items and Expense I
tems.
Theterms“incomeitems”and
“expense
items” have the same meaning
as in
§ 1.702–3T(b); and
.03Short Taxable Year.Th
eterm“short
taxable year” means the s
hort taxable year
of the partnership or S co
rporation that is
requiredtoeffectthec
hange in annual ac-
counting period. An in
itial short year fol-
lowing an election u
nder section 1362(a)
will not be consider
ed a “short taxable
year” for purposes
of this revenue proce-
dure.
SECTION 4. SCOPE
This revenue procedure applies to a
partner or S corporation shareholder, if:
.01 The partnership or S corporation has
changed, or will change, its taxable year
solely because either:
November 10, 200310362003-45 I.R.B.

(1) its current taxable year no longer
qualifies as a natural business year un-
der Rev. Proc. 2002–38 or Rev. Proc.
2002–39, whichever applies; or
(2) in the case of an S corporation, its
current taxable year no longer qualifies as
an ownership taxable year because a tax-
exempt owner is disregarded under section
5.06 of Rev. Proc. 2002–38;
.02 The partnership’s or S corporation’s
short taxable year ends on or after May 10,
2002, but before June 1, 2004 (or, in the
case of a taxpayer that uses a 52–53-week
taxable year, with reference to the last day
of any calendar month after April 30, 2002,
and before June 1, 2004);
.03 As a consequence of the partnership
or S corporation changing its taxable year
to a permitted taxable year, income items
and expense items from more than one tax-
able year of the partnership or S corpora-
tion would, but for the provisions of this
revenue procedure, be includible in the in-
come of the partner or S corporation share-
holder in a single taxable year; and
.04 The partner’s or S corporation
shareholder’s share of income items
exceeds its share of expense items at-
tributable to the short taxable year of the
partnership or S corporation.
SECTION 5. FOUR-YEAR SPREAD
PERIOD
.01 A partner or S corporation sha
re-
holder within the scope of this re
venue pro-
cedure may elect to take into acc
ount its
share of income from the short t
axable year
of the partnership or S corpora
tion ratably
over a four-year period.
.02 A partner or S corporatio
nshare-
holder within the scope of t
his revenue
procedure that elects a ra
table four-year
spread period under this r
evenue procedure
must apply the provision
s of § 1.702–3T
(b), (d), (e), (f) and (g)
with the following
modifications for pur
poses of this section:
(1) the term “partner”
in §1.702–3T
meansanypartnerorSc
orporation share-
holder within the sco
pe of this revenue
procedure;
(2) the term “partner
ship” includes S
corporations;
(3) the term “distri
butive share” in-
cludes a sharehold
er’spro ratashare of S
corporation items
;and
(4) references to “section 806 of the
1986 Act” should be replaced with “Rev.
Proc. 2002–38 or Rev. Proc. 2002–39,
whichever applies.”
SECTION 6. PROCEDURES FOR
ELECTING FOUR-YEAR SPREAD
PERIOD
A partner or S corporation shareholder
within the scope of this revenue procedure
that wants to elect to spread income ratably
over a four-year period under this revenue
procedure must make the election by:
(1) recording the appropriate ratable in-
come amount (i.e., one quarter of its share
of income) on either:
(a) a timely filed original federal in-
come tax return for the taxable year of the
partner or S corporation shareholder with
or within which the partnership’s or S cor-
poration’s short taxable year ends; or
(b)inthecaseofapartnerorScorpo-
ration shareholder within the scope of this
revenueprocedurethatwantstomakethe
four-year spread period election, but prior
to November 24, 2003, has timely filed a
federal income tax return for the taxable
year with or within which the partnership’s
or S corporation’s short taxable year ends,
on an appropriate amended federal income
tax return that is filed on or before April
12, 2004; and
(2) attaching to the original or amended
federal income tax return for the taxable
year with or within which the partnership’s
or S corporation’s short taxable year ends,
and to the federal income tax returns for
every other taxable year of the spread pe-
riod, a completed Form 8082,Notice of
Inconsistent Treatment or Administrative
Adjustment Request, containing an expla-
nation in Part III similar to the following:
“Election under Rev. Proc. 2003–79 to ap-
ply a ratable 4-year spread of the share of
income attributable to a change in annual
accounting period.”
SECTION 7. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2002–38 and Rev. Proc.
2002–39 are modified.
DRAFTING INFORMATION
The principal authors of this revenue
procedure are Roy A. Hirschhorn and
Jeffrey S. Marshall of the Office of As-
sociate Chief Counsel (Income Tax and
Accounting). For further information
regarding this revenue procedure, contact
Mr. Hirschhorn or Mr. Marshall at (202)
622–4960 (not a toll-free call).
26 CFR 601.105: Examination of returns and claims
for refund, credit, or abatement; determination of
correct tax liability.
(Also Part I, §§ 62, 162, 267, 274; 1.62–2, 1.162–17,
1.267(a)–1, 1.274–5.)
Rev. Proc. 2003–80
SECTION 1. PURPOSE
This revenue procedure updates Rev.
Proc. 2002–63, 2002–2 C.B. 691, by pro-
viding rules under which the amount of
ordinary and necessary business expenses
of an employee for lodging, meal, and
incidental expenses or for meal and inci-
dental expenses incurred while traveling
away from home will be deemed substan-
tiated under § 1.274–5 of the Income Tax
Regulations when a payor (the employer,
its agent, or a third party) provides aper
diemallowance under a reimbursement
or other expense allowance arrangement
to pay for the expenses. In addition, this
revenue procedure provides an optional
method for employees and self-employed
individuals who pay or incur meal costs
to use in computing the deductible costs
of business meal and incidental expenses
paid or incurred while traveling away
from home. This revenue procedure also
provides an optional method for use in
computing the deductible costs of inci-
dental expenses paid or incurred while
travelingawayfromhomebyemployees
and self-employed individuals who do not
pay or incur meal costs and who are not
reimbursed for the incidental expenses.
Use of a method described in this revenue
procedure is not mandatory, and a taxpayer
may use actual allowable expenses if the
taxpayer maintains adequate records or
other sufficient evidence for proper sub-
stantiation. This revenue procedure does
not provide rules under which the amount
of an employee’s lodging expenses will
be deemed substantiated when a payor
provides an allowance to pay for those
expenses but not meal and incidental ex-
penses.
2003-45 I.R.B.1037November 10, 2003

SECTION2. BACKGROUNDAND
CHANGES
.01 Section 162(a) of the Internal Rev-
enue Code allows a deduction for all the or-
dinary and necessary expenses paid or in-
curred during the taxable year in carrying
on any trade or business. Under that pro-
vision, an employee or self-employed in-
dividual may deduct expenses paid or in-
curred while traveling away from home in
pursuit of a trade or business. However,
under § 262, no portion of the travel ex-
penses that is attributable to personal, liv-
ing, or family expenses is deductible.
.02 Section 274(n) generally limits the
amount allowable as a deduction under
§ 162 for any expense for food, bever-
ages, or entertainment to 50 percent of
the amount of the expense that otherwise
would be allowable as a deduction. In
the case of any expenses for food or bev-
erages consumed while away from home
(within the meaning of § 162(a)(2)) by an
individual during, or incident to, the pe-
riod of duty subject to the hours of service
limitations of the Department of Trans-
portation, § 274(n)(3) gradually increases
the deductible percentage to 80 percent
for taxable years beginning in 2008. For
taxable years beginning in 2003, the de-
ductible percentage for these expenses is
65 percent. For taxable years beginning in
2004, the deductible percentage for these
expenses is 70 percent.
.03 Section 274(d) provides, in part,
that no deduction shall be allowed under
§ 162 for any traveling expense (includ-
ing meals and lodging while away from
home) unless the taxpayer complies with
certain substantiation requirements. Sec-
tion 274(d) further provides that regula-
tions may prescribe that some or all of
the substantiation requirements do not ap-
ply to an expense that does not exceed an
amount prescribed by such regulations.
.04 Section 1.274–5(g), in part, grants
the Commissioner the authority to pre-
scribe rules relating to reimbursement
arrangements orper diemallowances for
ordinary and necessary expenses paid or
incurred while traveling away from home.
Pursuant to this grant of authority, the
Commissioner may prescribe rules under
which such arrangements or allowances,
if in accordance with reasonable business
practice, will be regarded (1) as equivalent
to substantiation, by adequate records or
other sufficient evidence, of the amount
of such travel expenses for purposes of
§ 1.274–5(c), and (2) as satisfying the
requirements of an adequate accounting to
the employer of the amount of such travel
expenses for purposes of § 1.274–5(f).
.05 For purposes of determining ad-
justed gross income, § 62(a)(2)(A) allows
an employee a deduction for expenses
allowedbyPartVI(§161andfollowing),
subchapter B, chapter 1 of the Code, paid
or incurred by the employee in connection
with the performance of services as an
employee under a reimbursement or other
expense allowance arrangement with a
payor.
.06 Section 62(c) provides that an ar-
rangement will not be treated as a reim-
bursement or other expense allowance ar-
rangement for purposes of § 62(a)(2)(A) if
it—
(1) does not require the employee to
substantiate the expenses covered by the
arrangement to the payor, or
(2) provides the employee with the right
to retain any amount in excess of the sub-
stantiated expenses covered under the ar-
rangement.
Section 62(c) further provides that the sub-
stantiation requirements described therein
shall not apply to any expense to the extent
that, under the grant of regulatory authority
prescribed in § 274(d), the Commissioner
has provided that substantiation is not re-
quired for such expense.
.07 Under § 1.62–2(c)(1) a reimburse-
ment or other expense allowance arrange-
ment satisfies the requirements of § 62(c)
if it meets the requirements of business
connection, substantiation, and returning
amounts in excess of expenses as specified
in the regulations. Section 1.62–2(e)(2)
specifically provides that substantiation of
certain business expenses in accordance
with rules prescribed under the author-
ity of § 1.274–5(g) or 1.274–5(j) will be
treated as substantiation of the amount of
such expenses for purposes of § 1.62–2.
Under § 1.62–2(f)(2), the Commissioner
mayprescriberulesunderwhichanar-
rangement providingper diemallowances
will be treated as satisfying the require-
ment of returning amounts in excess of
expenses, even though the arrangement
does not require the employee to return the
portion of such an allowance that relates
to days of travel substantiated and that
exceeds the amount of the employee’s ex-
penses deemed substantiated pursuant to
rules prescribed under § 274(d), provided
the allowance is reasonably calculated not
to exceed the amount of the employee’s
expenses or anticipated expenses and the
employee is required to return any portion
of such an allowance that relates to days
of travel not substantiated.
.08 Section 1.62–2(h)(2)(i)(B) pro-
vides that if a payor pays aper diem
allowance that meets the requirements of
§ 1.62–2(c)(1), the portion, if any, of the
allowance that relates to days of travel sub-
stantiated in accordance with § 1.62–2(e),
that exceeds the amount of the employee’s
expenses deemed substantiated for such
travel pursuant to rules prescribed under
§ 274(d) and § 1.274–5(g) or § 1.274–5(j),
and that the employee is not required
to return, is subject to withholding and
payment of employment taxes. See
§§ 31.3121(a)–3, 31.3231(e)–1(a)(5),
31.3306(b)–2, and 31.3401(a)–4 of the
Employment Tax Regulations. Because
the employee is not required to return this
excess portion, the reasonable period of
time provisions of § 1.62–2(g) (relating to
the return of excess amounts) do not apply
to this portion.
.09 Under § 1.62–2(h)(2)(i)(B)(4), the
Commissioner has the discretion to pre-
scribe special rules regarding the timing of
withholding and payment of employment
taxes onper diemallowances.
.10 Section 1.274–5(j)(1) grants the
Commissioner the authority to establish a
method under which a taxpayer may elect
to use a specified amount for meals paid or
incurred while traveling away from home
in lieu of substantiating the actual cost of
meals.
.11 Section 1.274–5(j)(3) grants the
Commissioner the authority to establish a
method under which a taxpayer may elect
to use a specified amount for incidental
expenses paid or incurred while traveling
away from home in lieu of substantiating
the actual cost of incidental expenses.
.12 Sections 4.04(5) and 5.06 of this
revenue procedure provide transition rules
for the last 2 months of calendar year 2003.
.13 Section 4.05 of this revenue proce-
dure is revised to provide a new rate for
substantiating only incidental expenses for
any OCONUS locality of travel.
.14 Section 5.02 of this revenue pro-
cedure contains revisions to theper diem
November 10, 200310382003-45 I.R.B.

rates for high-cost localities and for other
localities for purposes of section 5.
.15 Sections 5.03 and 5.04 of this rev-
enue procedure contain revisions to the list
of high-cost localities for purposes of sec-
tion 5.
SECTION 3. DEFINITIONS
.01per diem allowance.The term “per
diemallowance” means a payment under a
reimbursement or other expense allowance
arrangement that meets the requirements
specified in § 1.62–2(c)(1) and that is —
(1) paid with respect to ordinary and
necessary business expenses incurred, or
which the payor reasonably anticipates
will be incurred, by an employee for lodg-
ing, meal, and incidental expenses, or for
meal and incidental expenses for travel
away from home in connection with the
performance of services as an employee
of the employer,
(2) reasonably calculated not to exceed
the amount of the expenses or the antici-
pated expenses, and
(3) paid at or below the applicable fed-
eralper diemrate, a flat rate or stated
schedule, or in accordance with any other
Service-specified rate or schedule.
.02Federal per diem rate and federal
M&IE rate.
(1)General rule.The federalper diem
rate is equal to the sum of the applicab
le
federal lodging expense rate and the
appli-
cable federal meal and incidental e
xpense
(M&IE) rate for the day and locality
of
travel.
(a)CONUS rates.The rates for lo-
calities in the continental Unite
d States
(“CONUS”) are set forth in Appe
ndix A
to 41 C.F.R. ch. 301. However, i
napply-
ing section 4.01, 4.02, or 4.0
3ofthisrev-
enue procedure, a taxpayer m
ay continue
to use the CONUS rates in effe
ct after Oc-
tober 1, 2002, that the taxp
ayer most re-
cently used prior to Octo
ber 1, 2003, for
expenses of all CONUS tr
avel away from
home that are paid or inc
urred during the
last three months of 20
03, in lieu of the
GSA rates that are upda
ted effective Oc-
tober 1, 2003, provid
ed that the taxpayer
consistently uses
those prior rates for the
last three months o
f 2003.
(b)OCONUS rates.T
he rates for local-
ities outside the c
ontinental United States
(“OCONUS”) are established by the Sec-
retary of Defense (rates for non-foreign lo-
calities, including Alaska, Hawaii, Puerto
Rico, the Northern Mariana Islands, and
the possessions of theUnited States) and
by the Secretary of State (rates for for-
eign localities), and are published in the
per diemSupplement to the Standardized
Regulations (Government Civilians, For-
eign Areas) (updated on a monthly basis).
(c)Internet access to the rates.The
CONUS and OCONUS rates may be
found on the Internet atwww.policy
works.gov/perdiem.
(2)Locality of travel.The term “lo-
cality of travel” means the locality where
an employee traveling away from home in
connection with the performance of ser-
vices as an employee of the employer stops
for sleep or rest.
(3)Incidental expenses.The term “in-
cidental expenses” has the meaning given
to it in the Federal Travel Regulations, 41
C.F.R. 300–3.1 (2003). Thus, based on the
current definition of “incidental expenses”
in the Federal Travel Regulations, “inci-
dental expenses” means fees and tips given
to porters, baggage carriers, bellhops, ho-
tel maids, stewards or stewardesses and
others on ships, and hotel servants in
foreign countries; transportation between
places of lodging or business and places
where meals are taken, if suitable meals
cannot be obtained at the temporary duty
site; and the mailingcost associated with
filing travel vouchers and payment of
employer-sponsored charge card billings.
.03Flat rate or stated schedule.
(1)In general.Except as provided in
section 3.03(2) of this revenue procedure,
an allowance is paid at a flat rate or stated
schedule if it is provided on a uniform and
objective basis with respect to the expenses
described in section 3.01 of this revenue
procedure. Such allowance may be paid
with respect to the number of days away
from home in connection with the per-
formance of services as an employee or
on any other basis that is consistently ap-
plied and in accordance with reasonable
business practice. Thus, for example, an
hourly payment to cover meal and inciden-
tal expenses paid to a pilot or flight atten-
dant who is traveling away from home in
connection with the performance of ser-
vices as an employee is an allowance paid
at a flat rate or stated schedule. Likewise,
a payment based on the number of miles
traveled (such as cents per mile) to cover
meal and incidental expenses paid to an
over-the-road truck driver who is traveling
away from home in connection with the
performance of services as an employee is
an allowance paid at a flat rate or stated
schedule.
(2)Limitation.For purposes of this
revenue procedure, an allowance that is
computed on a basis similar to that used
in computing the employee’s wages or
other compensation (such as the number
of hours worked, miles traveled, or pieces
produced) does not meet the business
connection requirement of § 1.62–2(d), is
not aper diemallowance, and is not paid
at a flat rate or stated schedule, unless, as
of December 12, 1989, (a) the allowance
was identified by the payor either by mak-
ing a separate payment or by specifically
identifying the amount of the allowance,
or (b) an allowance computed on that
basiswascommonlyusedintheindustry
in which the employee is employed. See
§ 1.62–2(d)(3)(ii).
SECTION 4. PER DIEM
SUBSTANTIATION METHOD
.01per diem allowance.If a payor
pays aper diemallowance in lieu of reim-
bursing actual expenses for lodging, meal,
and incidental expenses incurred or to be
incurred by an employee for travel away
from home, the amount of the expenses
that is deemed substantiated for each cal-
endar day is equal to the lesser of theper
diemallowance for that day or the amount
computed at the federalper diemrate (see
section 3.02 of this revenue procedure) for
the locality of travel for that day (or partial
day, see section 6.04 of this revenue proce-
dure).
.02Meals and incidental expenses only
per diem allowance.If a payor pays aper
diemallowance only for meal and inciden-
tal expenses in lieu of reimbursing actual
expenses for meal and incidental expenses
incurred or to be incurred by an employee
for travel away from home, the amount of
the expenses that is deemed substantiated
for each calendar day is equal to the lesser
of theper diemallowance for that day or
the amount computed at the federal M&IE
rate for the locality of travel for that day
(or partial day). Aper diemallowance
is treated as paid only for meal and inci-
dental expenses if (1) the payor pays the
2003-45 I.R.B.1039November 10, 2003

employee for actual expenses for lodging
based on receipts submitted to the payor,
(2) the payor provides the lodging in kind,
(3) the payor pays the actual expenses for
lodging directly to the provider of the lodg-
ing, (4) the payor does not have a reason-
able belief that lodging expenses were or
will be incurred by the employee, or (5) the
allowance is computed on a basis similar
to that used in computing the employee’s
wages or other compensation (such as the
number of hours worked, miles traveled, or
pieces produced).
.03Optional method for meal and in-
cidental expenses only deduction.In lieu
of using actual expenses in computing the
amount allowable as a deduction for or-
dinary and necessary meal and inciden-
tal expenses paid or incurred for travel
away from home, employees and self-em-
ployed individuals who pay or incur meal
expenses may use an amount computed at
the federal M&IE rate for the locality of
travel for each calendar day (or partial day)
the employee or self-employed individual
is away from home. Such amount will be
deemed substantiated for purposes of para-
graphs (b)(2) and (c) of § 1.274–5, pro-
vided the employee or self-employed indi-
vidual substantiates the elements of time,
place, and business purpose of the travel
for that day (or partial day) in accordance
with those regulations. See section 6.05(1)
of this revenue procedure for rules related
to the application of the limitation under
§ 274(n) to amounts determined under this
section 4.03. See section 4.05 of this rev-
enue procedure for a method for substanti-
ating incidental expenses that may be used
by employees or self-employed individu-
als who do not pay or incur meal expenses.
.04Special rules for transportation in-
dustry.
(1)In general.This section 4.04 ap-
plies to (a) a payor that pays aper diem
allowance only for meal and incidental ex-
penses for travel away from home as de-
scribedinsection4.02ofthisrevenuepro-
cedure to an employee in the transportation
industry, or (b) an employee or self-em-
ployed individual in the transportation in-
dustry who computes the amount allow-
able as a deduction for meal and incidental
expenses for travel away from home in ac-
cordance with section 4.03 of this revenue
procedure.
(2)Rates.A taxpayer described in sec-
tion 4.04(1) of this revenue procedure may
treat $41 as the federal M&IE rate for any
CONUS locality of travel, and $46 as the
federal M&IE rate for any OCONUS lo-
cality of travel. A payor that uses either (or
both) of these special rates with respect to
an employee must use the special rate(s)
for all amounts subject to section 4.02 of
this revenue procedure paid to that em-
ployee for travel away from home within
CONUS and/or OCONUS, as the case may
be, during the calendar year. Similarly, an
employee or self-employed individual that
uses either (or both) of these special rates
must use the special rate(s) for all amounts
computed pursuant to section 4.03 of this
revenue procedure for travel away from
home within CONUS and/or OCONUS, as
the case may be, during the calendar year.
See section 4.04(5) of this revenue proce-
dure for transition rules.
(3)Periodic rule.A payor described
in section 4.04(1) of this revenue proce-
dure may compute the amount of the em-
ployee’s expenses that is deemed substan-
tiated under section 4.02 of this revenue
procedure periodically (not less frequently
than monthly), rather than daily, by com-
paring the totalper diemallowance paid
for the period to the sum of the amounts
computed at the federal M&IE rate(s) for
the localities of travel for the days (or par-
tial days) the employee is away from home
during the period. For example, assume
an employee in the transportation industry
travels away from home within CONUS on
17 days (including partial days) during a
calendar month and receives aper diemal-
lowance only for meal and incidental ex-
penses from a payor that uses the special
rule under section 4.04(2) of this revenue
procedure. The amount deemed substanti-
ated under section 4.02 of this revenue pro-
cedure is equal to the lesser of the totalper
diemallowance paid for the month or $697
(17 days at $41 per day).
(4)Transportation industry defined.
For purposes of this section 4.04, an em-
ployee or self-employed individual is “in
the transportation industry” only if the
employee’s or individual’s work (a) is of
the type that directly involves moving peo-
ple or goods by airplane, barge, bus, ship,
train, or truck, and (b) regularly requires
travel away from home which, during
anysingletripawayfromhome,usually
involves travel to localities with differ-
ing federal M&IE rates. For purposes
of the preceding sentence, a payor must
determine that an employee or a group of
employees is “in the transportation indus-
try” by using a method that is consistently
applied and in accordance with reasonable
business practice.
(5)Transition rules.Under the calen-
dar-year conventionprovided in section
4.04(2), a taxpayer who used the federal
M&IE rates during the first 10 months
of calendar year 2003 to substantiate the
amount of an individual’s travel expenses
under sections 4.02 or 4.03 of Rev. Proc.
2002–63 may not use, for that individual,
the special transportation industry rates
provided in this section 4.04 until January
1, 2004. Similarly, a taxpayer who used
the special transportation industry rates
during the first 10 months of calendar
year 2003 to substantiate the amount of an
individual’s travel expenses may not use,
for that individual, the federal M&IE rates
until January 1, 2004.
.05Optional method for incidental ex-
penses only deduction.In lieu of using
actual expenses in computing the amount
allowable as a deduction for ordinary and
necessary incidental expenses paid or in-
curred for travel away from home, employ-
ees and self-employed individuals who do
not pay or incur meal expenses for a cal-
endar day (or partial day) of travel away
from home may use, for each calendar day
(or partial day) the employee or self-em-
ployed individual is away from home, an
amount computed at the rate of $3 per
day for any CONUS or OCONUS local-
ity of travel. Such amount will be deemed
substantiated for purposes of paragraphs
(b)(2) and (c) of § 1.274–5, provided the
employee or self-employed individual sub-
stantiates the elements of time, place, and
business purpose of the travel for that day
(or partial day) in accordance with those
regulations. See section 4.03 of this rev-
enue procedure for a method that may be
used by employees or self-employed indi-
viduals who pay or incur meal expenses.
The method authorized by this section 4.05
may not be used by payors that use sec-
tion 4.01, 4.02 or 5.01 of this revenue pro-
cedure, or by employees or self-employed
individuals who use the method described
in section 4.03 of this revenue procedure.
See section 6.05(4) of this revenue proce-
dure for rules related to the application of
the limitation under § 274(n) to amounts
determined under this section 4.05.
November 10, 200310402003-45 I.R.B.

SECTION 5. HIGH-LOW
SUBSTANTIATION METHOD
.01General rule.If a payor pays aper
diemallowance in lieu of reimbursing ac-
tual expenses for lodging, meal, and inci-
dental expenses incurred or to be incurred
by an employee for travel away from home
and the payor uses the high-low substan-
tiation method described in this section 5
for travel within CONUS, the amount of
the expenses that is deemed substantiated
for each calendar day is equal to the lesser
of theper diemallowance for such day or
the amount computed at the rate set forth in
section 5.02 of this revenue procedure for
the locality of travel for such day (or partial
day, see section 6.04 of this revenue proce-
dure). Except as provided in section 5.06
of this revenue procedure, this high-low
substantiation method may be used in lieu
of theper diemsubstantiation method pro-
vided in section 4.01 of this revenue pro-
cedure, but may not be used in lieu of the
meals only substantiationmethodprovided
in section 4.02 or 4.03 of this revenue pro-
cedure.
.02Specific high-low rates.Except as
provided in section 5.06 of this revenue
procedure, theper diemrate set forth in
this section 5.02 is $207 for travel to any
“high-cost locality” specified in section
5.03 of this revenue procedure, or $126 for
travel to any other locality within CONUS.
Whicheverper diemrate applies, it is ap-
plied as if it were the federalper diemrate
for the locality of travel. For purposes
of applying the high-low substantiation
method and the § 274(n) limitation on
meal expenses (see section 6.05 of this
revenue procedure), the federal M&IE
rate shall be treated as $46 for a high-cost
locality and $36 for any other locality
within CONUS.
.03High-cost localities.The following
localities have a federalper diemrate of
$167 or more, and are high-cost localities
for all of the calendar year or the portion
of the calendar year specified in parenthe-
sis under the key city name, except as pro-
vided in section 5.06 of this revenue pro-
cedure:
Key cityCounty or other defined location
California
NapaNapa
(April 1–November 15)
Palm SpringsRiverside
(January 1–May 31)
SanFranciscoSanFrancisco
Santa MonicaCity limits of Santa Monica
Tahoe CityPlacer
Colorado
AspenPitkin
(January 1–April 30)
Silverthorne/KeystoneSummit
TellurideSan Miguel
(December 20–September 30)
VailEagle
(December 1–March 31)
District of Columbia
Washington, D.C. (also the cities of Alexandria, Fairfax, and Falls Church, and the counties of Arlington, Fairfax, and Loudoun,
in Virginia; and the counties of Montgomery and Prince George’s in Maryland)
Florida
Key WestMonroe
(January 1–April 30)
NaplesCollier
(December
16–April 15)
Idaho
Coeur d’AleneKootenai
(June 1–September 30)
Sun ValleyCity limits of Sun Valley
Illinois
ChicagoCook and Lake
2003-45 I.R.B.1041November 10, 2003

Key cityCounty or other defined location
Louisiana
New Orleans/St. BernardOrleans, St. Bernard,
(January 1–May 31)Plaquemine, and Jefferson Parishes
Maine
Kennebunk/Kittery/SanfordYork
(June 15–October 31)
Maryland
(For the counties of Montgomery and Prince George’s, see District of Columbia)
BaltimoreBaltimore
Ocean CityWorcester
(June 15–October 31)
Massachusetts
BostonSuffolk
CambridgeMiddlesex (except Lowell)
Martha’s VineyardDukes
(June 1–October 15)
NantucketNantucket
(June 15–October 15)
Michigan
Mackinac IslandMackinac
Traverse CityGrand Traverse
Montana
Big SkyGallatin (except West Yellowstone)
Nevada
StatelineDouglas
New Jersey
Atlantic CityAtlantic
(June 1–November 3
0)
Cape MayCape May (except Ocean City)
(June 1–November 30)
EdisonMiddlesex (ex
cept Piscataway)
NewarkEssex, Bergen, Hudson and Passaic
Ocean CityCity limits of Ocean City
(June 15–Se
ptember 15)
Piscataway/Belle MeadSomerset; and the city limits of Piscataway
Princeton/TrentonMercer
New York
The Bronx/QueensThe boroughs of The Bronx and Queens
BrooklynThe borough of Brooklyn
ManhattanThe borough of Manhattan
Nassau County/Great NeckNassau
Staten IslandRichmond
Suffolk CountySuffolk
White PlainsCity limits of White Plains
November 10, 200310422003-45 I.R.B.

Key cityCounty or other defined location
Pennsylvania
HersheyCity limits of Hershey
(June 1–September 15)
King of Prussia/Ft. Washington/Bala CynwydMontgomery
PhiladelphiaPhiladelphia
Utah
Park CitySummit
(December 15–March 31)
Virginia
(For the cities of Alexandria, Fairfax, and Falls Church, and th
e counties of Arlington, Fairfax, and Loudoun, see District
of Columbia)
WintergreenNelson
Washington
SeattleKing
.04Changes in high-cost localities.
The list of high-cost localities in section
5.03 of this revenue procedure differs from
the list of high-cost localities in section
5.03 of Rev. Proc. 2002–63.
(1) The following localities (listed by
key cities) have been added to the list of
high-cost localities: Naples, Florida; and
Coeur d’Alene, Idaho.
(2) The portion of the year for which the
following are high-cost localities (listed by
key city) has been changed: Santa Monica,
California; and King of Prussia/Ft. Wash-
ington/Bala Cynwyd, Pennsylvania.
(3) The following localities have been
removed from the list of high-cost locali-
ties: San Mateo/Redwood City, California;
Sunnyvale/Palo Alto/San Jose, California;
Ogden/Layton/Davis County, Utah; Provo,
Utah; and Salt Lake City, Utah.
(4) The borough of Brooklyn is now
separately listed as a high-cost locality and
is no longer combined with the boroughs
of The Bronx and Queens.
.05Specific limitation.
(1) Except as provided in section
5.05(2) of this revenue procedure, a payor
that uses the high-low substantiation
method with respect to an employee must
use that method for all amounts paid to
that employee for travel away from home
within CONUS during the calendar year.
See section 5.06 of this revenue procedure
for transition rules.
(2) With respect to an employee de-
scribed in section 5.05(1) of this revenue
procedure, the payor may reimburse actual
expenses or use the meals onlyper diem
method described in section 4.02 of this
revenue procedure for any travel away
from home, and may use theper diem
substantiation method described in section
4.01 of this revenue procedure for any
OCONUS travel away from home.
.06Transition rules.A payor who used
the substantiation method of section 4.01
of Rev. Proc. 2002–63 for an employee
during the first 10 months of calendar year
2003 may not use the High-Low Substan-
tiationMethodinsection5ofthisrevenue
procedure for that employee until January
1, 2004. A payor who used the High-Low
Substantiation Method of section 5 of Rev.
Proc. 2002–63 for an employee during the
first 10 months of calendar year 2003 must
continue to use the High-Low Substantia-
tion Method for the remainder of calendar
year 2003 for that employee. A payor de-
scribed in the previous sentence may use
the rates and high-cost localities published
in section 5 of Rev. Proc. 2002–63, in lieu
of the updated rates and high-cost locali-
ties provided in section 5 of this revenue
procedure, for travel on or after Novem-
ber 1, 2003, and before January 1, 2004, if
those rates and localities are used consis-
tently during this period for all employees
reimbursed under this method.
SECTION 6. LIMITATIONS AND
SPECIAL RULES
.01In general.The federalper diem
rate and the federal M&IE rate described in
section 3.02 of this revenue procedure for
the locality of travel will be applied in the
same manner as applied under the Federal
Travel Regulations, 41 C.F.R. Part 301–11
(2003), except as provided in sections 6.02
through 6.04 of this revenue procedure.
.02Federal per diem rate.A receipt
for lodging expenses is not required in de-
termining the amount of expenses deemed
substantiated under section 4.01 or 5.01 of
this revenue procedure. See section 7.01 of
this revenue procedure for the requirement
that the employee substantiate the time,
place, and business purpose of the expense.
.03Federal per diem or M&IE rate.A
payor is not required to reduce the federal
per diemrate or the federal M&IE rate for
the locality of travel for meals provided in
kind, provided the payor has a reasonable
belief that meal and incidental expenses
were or will be incurred by the employee
during each day of travel.
.04Proration of the federal per diem
or M&IE rate.Pursuant to the Federal
Travel Regulations, in determining the fed-
eralper diemrate or the federal M&IE rate
for the locality of travel, the full applica-
ble federal M&IE rate is available for a
full day of travel from 12:01 a.m. to 12:00
midnight. The method described in sec-
tion 6.04(1) of this revenue procedure must
be used for purposes of determining the
amount deemed substantiated under sec-
tion 4.03 or 4.05 of this revenue procedure
for partial days of travel away from home.
For purposes of determining the amount
deemed substantiated under section 4.01,
4.02, 4.04 or 5 of this revenue procedure
for partial days of travel away from home,
either of the following methods may be
2003-45 I.R.B.1043November 10, 2003

used to prorate the federal M&IE rate to
determine the federalper diemrate or the
federal M&IE rate for the partial days of
travel:
(1) The rate may be prorated using the
method prescribed by the Federal Travel
Regulations. Currently the Federal Travel
Regulations allow three-fourths of the ap-
plicable federal M&IE rate for each partial
day during which the employee or self-em-
ployed individual is traveling away from
home in connection with the performance
of services as an employee or self-em-
ployed individual. The same ratio may be
applied to prorate the allowance for inci-
dental expenses described in section 4.05
of this revenue procedure; or
(2) The rate may be prorated using any
method that is consistently applied and in
accordance with reasonable business prac-
tice. For example, if an employee travels
away from home from 9 a.m. one day to
5 p.m. the next day, a method of proration
that results in an amount equal to two times
the federal M&IE rate will be treated as
being in accordance with reasonable busi-
ness practice (even though only one and a
half times the federal M&IE rate would be
allowed under the Federal Travel Regula-
tions).
.05Application of the appropriate
§ 274(n) limitation on meal expenses.Ex-
cept as provided in section 6.05(4), all or
part of the amount of an expense deemed
substantiated under this revenue proce-
dure is subject to the appropriate limitation
under § 274(n) (see section 2.02 of this
revenue procedure) on the deductibility of
food and beverage expenses.
(1) If an amount for meal and inciden-
tal expenses is computed pursuant to sec-
tion 4.03 of this revenue procedure, the
taxpayer must treat such amount as an ex-
pense for food and beverages.
(2)Ifaper diemallowance is paid only
for meal and incidental expenses, the payor
must treat an amount equal to the lesser of
theallowanceorthefederalM&IEratefor
the locality of travel for such day (or partial
day, see section 6.04 of this revenue pro-
cedure) as an expense for food and bever-
ages.
(3)Ifaper diemallowance is paid for
lodging, meal, and incidental expenses, the
payor must treat an amount equal to the
federal M&IE rate for the locality of travel
for each calendar day (or partial day) the
employee is away from home as an ex-
pense for food and beverages. For pur-
poses of the preceding sentence, if aper
diemallowance for lodging, meal, and in-
cidental expenses is paid at a rate that is
less than the federalper diemrate for the
locality of travel for such day (or partial
day), the payor may treat an amount equal
to 40 percent of such allowance as the fed-
eral M&IE rate for the locality of travel for
such day (or partial day).
(4) If an amount for incidental expenses
is computed under section 4.05 of this rev-
enue procedure, none of the amount so
computed is subject to limitation under
§ 274(n) on the deductibility of food and
beverage expenses.
.06No double reimbursement or deduc-
tion.If a payor pays aper diemallowance
in lieu of reimbursing actual expenses for
lodging, meal, and incidental expenses or
for meal and incidental expenses in accor-
dance with section 4 or 5 of this revenue
procedure, any additional payment with re-
spect to such expenses is treated as paid un-
der a nonaccountable plan, is included in
the employee’s gross income, is reported
as wages or other compensation on the
employee’s Form W–2, and is subject to
withholding and payment of employment
taxes. Similarly, if an employee or self-
employed individual computes the amount
allowable as a deduction for meal and inci-
dental expenses for travel away from home
in accordance with section 4.03 or 4.04
of this revenue procedure, no other deduc-
tion is allowed to the employee or self-em-
ployed individual with respect to such ex-
penses. For example, assume an employee
receives aper diemallowance from a payor
for lodging, meal, and incidental expenses
or for meal and incidental expenses in-
curred while traveling away from home.
During that trip, the employee pays for din-
ner for the employee and two business as-
sociates. The payor reimburses as a busi-
ness entertainment meal expense the meal
expense for the employee and the two busi-
ness associates. Because the payor also
pays aper diemallowance to cover the cost
of the employee’s meals, the amount paid
by the payor for the employee’s portion of
the business entertainment meal expense
is treated as paid under a nonaccountable
plan, is reported as wages or other compen-
sation on the employee’s Form W–2, and
is subject to withholding and payment of
employment taxes.
.07Related parties.Sections 4.01 and 5
of this revenue procedure will not apply in
any case in which a payor and an employee
are related within the meaning of § 267(b),
but for this purpose the percentage of own-
ership interest referred to in § 267(b)(2)
shall be 10 percent.
SECTION 7. APPLICATION
.01 If the amount of travel expenses
is deemed substantiated under the rules
provided in section 4 or 5 of this rev-
enue procedure, and the employee actually
substantiates to the payor the elements of
time, place, and business purpose of the
travel for that day (or partial day) in accor-
dance with paragraphs (b)(2) and (c) (other
than subparagraph (2)(iii)(A) thereof) of
§ 1.274–5, the employee is deemed to sat-
isfy the adequate accounting requirements
of § 1.274–5(f) as well as the require-
ment to substantiate by adequate records
or other sufficient evidence for purposes of
§ 1.274–5(c). See § 1.62–2(e)(1) for the
rule that an arrangement must require busi-
ness expenses to be substantiated to the
payor within a reasonable period of time.
.02 An arrangement providingper diem
allowances will be treated as satisfying
the requirement of § 1.62–2(f)(2) with re-
spect to returning amounts in excess of ex-
penses if the employee is required to return
within a reasonable period of time (as de-
fined in § 1.62–2(g)) any portion of such
an allowance that relates to days of travel
not substantiated, even though the arrange-
ment does not require the employee to re-
turn the portion of such an allowance that
relates to days of travel substantiated and
that exceeds the amount of the employee’s
expenses deemed substantiated. For exam-
ple, assume a payor provides an employee
an advanceper diemallowance for meal
and incidental expenses of $200, based on
an anticipated 5 days of business travel at
$40 per day to a locality for which the fed-
eral M&IE rate is $34, and the employee
substantiates 3 full days of business travel.
The requirement to return excess amounts
will be treated as satisfied if the employee
is required to return within a reasonable
period of time (as defined in § 1.62–2(g))
the portion of the allowance that is attribut-
able to the 2 unsubstantiated days of travel
($80), even though the employee is not
required to return the portion of the al-
lowance ($18) that exceeds the amount of
November 10, 200310442003-45 I.R.B.

the employee’s expenses deemed substan-
tiated under section 4.02 of this revenue
procedure ($102) for the 3 substantiated
days of travel. However, the $18 excess
portion of the allowance is treated as paid
under a nonaccountable plan as discussed
in section 7.04 of this revenue procedure.
.03 An employee is not required to in-
clude in gross income the portion of a
per diemallowance received from a payor
that is less than or equal to the amount
deemed substantiated under the rules pro-
videdinsection4or5ofthisrevenuepro-
cedure if the employee substantiates the
business travel expenses covered by the
per diemallowance in accordance with
section 7.01 of this revenue procedure. See
§ 1.274–5(f)(2)(i). In addition, such por-
tion of the allowance is treated as paid un-
der an accountable plan, is not reported as
wages or other compensation on the em-
ployee’s Form W–2, and is exempt from
the withholding and payment of employ-
ment taxes. See § 1.62–2(c)(2) and (c)(4).
.04Anemployeeisrequiredtoinclude
in gross income only the portion of theper
diemallowance received from a payor that
exceeds the amount deemed substantiated
under the rules provided in section 4 or 5
of this revenue procedure if the employee
substantiates the business travel expenses
covered by theper diemallowance in ac-
cordance with section 7.01 of this revenue
procedure. See § 1.274–5(f)(2)(ii). In ad-
dition, the excess portion of the allowance
is treated as paid under a nonaccountable
plan, is reported as wages or other compen-
sation on the employee’s Form W–2, and
is subject to withholding and payment of
employment taxes. See § 1.62–2(c)(3)(ii),
(c)(5), and (h)(2)(i)(B).
.05 If the amount of the expenses that
is deemed substantiated under the rules
provided in section 4.01, 4.02, or 5 of this
revenue procedure is less than the amount
of the employee’s business expenses for
travel away from home, the employee
may claim an itemized deduction for the
amount by which the business travel ex-
penses exceed the amount that is deemed
substantiated, provided the employee
substantiates all the business travel ex-
penses, includes on Form 2106,Employee
Business Expenses, the deemed substan-
tiated portion of theper diemallowance
received from the payor, and includes in
gross income the portion (if any) of the
per diemallowance received from the
payor that exceeds the amount deemed
substantiated. See § 1.274–5(f)(2)(iii).
However, for purposes of claiming this
itemized deduction with respect to meal
and incidental expenses, substantiation of
the amount of the expenses is not required
if the employee is claiming a deduction
that is equal to or less than the amount
computed under section 4.03 of this rev-
enue procedure minus the amount deemed
substantiated under sections 4.02 and 7.01
of this revenue procedure. The itemized
deduction is subject to the appropriate
limitation (see section 2.02 of this revenue
procedure) on meal and entertainment
expenses provided in § 274(n) and the
2-percent floor on miscellaneous itemized
deductions provided in § 67.
.06 An employee who pays or incurs
amounts for meal expenses and does not
receive aper diemallowance for meal and
incidental expenses may deduct an amount
computed pursuant to section 4.03 of this
revenue procedure only as an itemized de-
duction. This itemized deduction is sub-
ject to the appropriate limitation on meal
and entertainment expenses provided in
§ 274(n) and the 2-percent floor on miscel-
laneous itemized deductions provided in
§ 67. See section 7.07 of this revenue pro-
cedure for the treatment of an employee
who does not pay or incur amounts for
meal expenses and does not receive aper
diemallowance for incidental expenses.
.07 An employee who does not pay or
incur amounts for meal expenses and does
not receive aper diemallowance for in-
cidental expenses may deduct an amount
computed pursuant to section 4.05 of this
revenue procedure only as an itemized de-
duction. This itemized deduction is sub-
ject to the 2-percent floor on miscellaneous
itemized deductions provided in § 67. See
section 7.06 of this revenue procedure for
the treatment of an employee who pays or
incurs amounts for meal expenses and does
not receive aper diemallowance for meal
and incidental expenses.
.08 A self-employed individual who
pays or incurs meal expenses for a calen-
dar day (or partial day) of travel away from
home may deduct an amount computed
pursuant to section 4.03 of this revenue
procedure in determining adjusted gross
income under § 62(a)(1). This deduction
is subject to the appropriate limitation on
meal and entertainment expenses provided
in § 274(n).
.09 A self-employed individual who
does not pay or incur meal expenses for
a calendar day (or partial day) of travel
away from home may deduct an amount
computed pursuant to section 4.05 of this
revenue procedure in determining adjusted
gross income under § 62(a)(1).
.10 If a payor’s reimbursement or
other expense allowance arrangement ev-
idences a pattern of abuse of the rules of
§ 62(c) and the regulations thereunder, all
payments under the arrangement will be
treated as made under a nonaccountable
plan. Thus, such payments are included in
the employee’s grossincome, are reported
as wages or other compensation on the
employee’s Form W–2, and are subject to
withholding and payment of employment
taxes. See § 1.62–2(c)(3), (c)(5), and
(h)(2).
SECTION 8. WITHHOLDING AND
PAYMENT OF EMPLOYMENT TAXES
.01Theportionofaper diemal-
lowance, if any, that relates to the days
of business travel substantiated and that
exceeds the amount deemed substantiated
for those days under section 4.01, 4.02, or
5 of this revenue procedure is subject to
withholding and payment of employment
taxes. See § 1.62–2(h)(2)(i)(B).
.02 In the case of aper diemallowance
paid as a reimbursement, the excess de-
scribed in section 8.01 of this revenue pro-
cedure is subject to withholding and pay-
ment of employment taxes in the payroll
period in which the payor reimburses the
expenses for the days of travel substanti-
ated. See § 1.62–2(h)(2)(i)(B)(2).
.03 In the case of aper diemallowance
paid as an advance, the excess described
in section 8.01 of this revenue procedure
is subject to withholding and payment of
employment taxes no later than the first
payroll period following the payroll period
in which the days of travel with respect
to which the advance was paid are sub-
stantiated. See § 1.62–2(h)(2)(i)(B)(3). If
some or all of the days of travel with re-
spect to which the advance was paid are
not substantiated within a reasonable pe-
riod of time and the employee does not re-
turn the portion of the allowance that re-
lates to those days within a reasonable pe-
riod of time, the portion of the allowance
that relates to those days is subject to with-
holding and payment of employment taxes
2003-45 I.R.B.1045November 10, 2003

no later than the first payroll period follow-
ing the end of the reasonable period. See
§ 1.62–2(h)(2)(i)(A).
.04 In the case of aper diemallowance
only for meal and incidental expenses for
travel away from home paid to an em-
ployee in the transportation industry by a
payor that uses the rule in section 4.04(3)
of this revenue procedure, the excess of
theper diemallowance paid for the pe-
riod over the amount deemed substanti-
ated for the period under section 4.02 of
this revenue procedure (after applying sec-
tion 4.04(3) of this revenue procedure),
is subject to withholding and payment of
employment taxes no later than the first
payroll period following the payroll pe-
riod in which the excess is computed. See
§ 1.62–2(h)(2)(i)(B)(4).
.05 For example, assume that an em-
ployer pays an employee aper diem
allowance to cover business expenses for
meals and lodging for travel away from
home at a rate of 120 percent of the federal
per diemrate for the localities to which
the employee travels. The employer does
not require the employee to return the 20
percent by which the reimbursement for
those expenses exceeds the federalper
diemrate. The employee substantiates 6
days of travel away from home: 2 days in
a locality in which the federalper diem
rate is $100 and 4 days in a locality in
which the federalper diemrate is $125.
The employer reimburses the employee
$840 for the 6 days of travel away from
home (2 x (120% x $100) + 4 x (120% x
$125)), and does not require the employee
to return the excess payment of $140 (2
days x $20 ($120–$100) + 4 days x $25
($150–$125)). For the payroll period
in which the employer reimburses the
expenses, the employer must withhold
and pay employment taxes on $140. See
section 8.02 of this revenue procedure.
SECTION 9. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2002–63 is her
eby super-
seded(excepttotheexte
nt specified in sec-
tions 4.04(5) and 5.06 o
f this revenue pro-
cedure) forper diema
llowances that are
paid both (1) to an emp
loyee on or after
November 1, 2003, an
d (2) with respect
to lodging, meal, an
d incidental expenses
or with respect to m
eal and incidental ex-
penses paid or incu
rred for travel away
from home on or after November 1, 2003.
Rev. Proc. 2002–63 is also hereby su-
perseded (except to the extent specified in
section 4.04(5) of this revenue procedure)
for purposes of computing the amount al-
lowable as a deduction for meal and inci-
dental expenses or for incidental expenses
only paid or incurred by an employee or
self-employed individual for travel away
from home on or after November 1, 2003.
DRAFTING INFORMATION
The principal author of this revenue
procedure is Sameera Hasan, of the Office
of Associate Chief Counsel (Income Tax
and Accounting). For further information
regarding this revenue procedure, contact
Ms. Hasan at (202) 622–4930 (not a
toll-free call).
26 CFR 601.201: Ruling and determination letter
s
(Also: Part I, sections 25, 103, 143, 1.25–3T,
1.103–1, 6a.103–2.)
Rev. Proc. 2003–81
SECTION 1. PURPOSE
This revenue procedure supplements
Rev. Proc. 2003–49, 2003–29 I.R.B. 89,
and provides 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) with a list of qualified census
tracts for the Northern Mariana Islands,
American Samoa, and Guam.
SECTION 2. BACKGROUND
.01 Section 103(a) provides th
at, ex-
cept as provided in § 103(b), gr
oss income
does not include interest on a
ny State or
local bond. Section 103(b)(
1) provides
that § 103(a) shall not apply
to any pri-
vate activity bond that is
not a “qualified
bond” within the meaning
of § 141. Sec-
tion 141(e) provides th
at the term “qual-
ified bond” includes an
y private activity
bond if that bond: (1) i
s a qualified mort-
gage bond; (2) meets th
evolumecapre-
quirements under § 1
46; and (3) meets the
applicable requir
ements under § 147.
.02 Section 143(a)(
1) provides that the
term “qualified mo
rtgage bond” means a
bond that is issued
as part of a “qualified
mortgage issue”.
Section 143(a)(2)(A)
provides that the term “qualified mortgage
issue” means an issue by a state or political
subdivision thereof of one or more bonds,
but only if (i) all proceeds of the issue (ex-
clusive of issuance costs and a reasonably
required reserve) are to be used to finance
owner-occupied residences; (ii) the issue
meets the requirements of subsections (c),
(d), (e), (f), (g), (h), (i) and (m)(7) of § 143;
(iii) the issue does not meet the private
business 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 beginning
after the date the prepayment (or complete
repayment) is received to redeem bonds
that are part of the issue.
.03 An issue of bonds meets the re-
quirements of § 143(h)(1) only if at least
20 percent of the proceeds of the issue is
made available for owner financing of “tar-
geted area residences” for at least 1 year
after the date on which owner-financing
is first made available with respect to tar-
geted area residences. Section 143(h)(2)
provides, however, that the amount made
available need not exceed 40 percent of the
average annual aggregate principal amount
of mortgages executed during the imme-
diately preceding 3 calendar years for sin-
gle-family, owner-occupied residences lo-
cated in targeted areas within the jurisdic-
tion of the issuing authority.
.04 Targeted area residences are defined
in § 143(j)(1)(A) to include residences in
a qualified census tract. A “qualified cen-
sus tract”, according to § 143(j)(2)(A), is
a census tract in which 70 percent or more
of the families have income that is 80 per-
cent or less of the statewide median fam-
ily income. Section 143(j)(2)(B) provides
that the determinationthat a census tract is
a “qualified census tract” must be based on
the most recent decennial census for which
data are available.
.05 Section 6a.103A–2(b)(4)(ii) of the
Temporary Income Tax Regulations pro-
vides that, with respect to any particular
bond issue, the determination that a cen-
sus tract is a “qualified census tract” may
be based upon the decennial census data
available 3 months prior to the date of is-
suance and shall not be affected by offi-
cial changes to the data during or after that
3-month period.
November 10, 200310462003-45 I.R.B.

.06 Section 143(k)(2)(A) of the Code
provides that the term “statistical area”
means (i) a metropolitan statistical area
(“MSA”) and (ii) any county (or the por-
tion thereof) that is not within an MSA.
.07 An MSA is currently defined as
an area containing at least one urbanized
area with a population of at least 50,000,
plus adjacent territory having a high degree
of social and economic integration with
the core as measured through commut-
ing ties. See Office of Management and
Budget (“OMB”), Standards for Defining
Metropolitan and Micropolitan Statistical
Areas; Notice, 65 FR 249 (December 27,
2000); OMB Bulletin No. 03–04 (June 6,
2003).
.08 A state or local government may
elect to exchange all or part of its qualified
mortgage bond authority to issue mort-
gage credit certificates. Section 25(a)(1)
states, in general, that the recipient of
a mortgage credit certificate may claim
a federal income tax credit equal to the
product of the certificate credit rate and
the interest paid or accrued during the
tax year on the remaining principal of the
certified indebtedness amount. Section
25(c)(2)(A)(iii)(V) of the Code provides
that the indebtedness certified by mort-
gage credit certificates must meet the
requirements of § 143(h) concerning the
portion of loans to be placed in targeted
areas.
.09 The list of qualified census tracts is
developed by the Department of Housing
and Urban Development (“HUD”) for pub-
lication by the Internal Revenue Service.
HUD’s determination is based upon de-
cennial census data received by HUD from
the Bureau of the Census.
.10 Qualified census tracts for the
states, the District of Columbia, and
Puerto Rico, based on the 2000 census,
were most recently published in Rev. Proc.
2003–49, 2003–29 I.R.B. 89. Qualified
census tracts for the Northern Mariana
Islands, American Samoa, and Guam have
not been published in any previous rev-
enue procedure.
SECTION 3. APPLICATION
The qualified census tracts for the
Northern Mariana Islands, American
Samoa, and Guam as listed below are
based on the 2000 census. In 2000, the
Bureau of the Census provided data for all
areas, not only MSAs. Thus, the list of
qualified census tracts includes tracts in
Block Numbering Areas in nonmetropoli-
tan counties as well as tracts in MSAs.
County or EquivalentQualified Census Tracts
NORTHERN MARIANA ISLANDS
Northern Islands Municipality9501
Rota Municipality9501
Saipan Municipality9501950295039504
9505.019505.029506.019506.02
9507950895099510
951195129513.019513.02
95149515
Tinian Municipality9501
AMERICAN SAMOA
Eastern District9501950295039504
9505950695079508
9509
Manu’a District95179518
Rose Island9519
Swains Island9520
Western District951095119512.019512.02
9512.03951395159516
GUAM
Guam9501950295039504
9505950695079508
9509951095119512
9513951495159516
9517951895199520
9521952295239524
9525952695279528
2003-45 I.R.B.1047November 10, 2003

County or EquivalentQualified Census Tracts
Guam (continued)9529953095319532
9533953495359536
9537953895399540
9541954295439544
9545954695479548
9549955095519552
9553955495559556
SECTION 4. EF
FECT ON OTHER
REVENUE PRO
CEDURES
This revenue procedure supplements
Rev. Proc. 2003–49 by providing a list
of qualified census tracts for the Northern
Mariana Islands, American Samoa, and
Guam.
SECTION 5. SCOPE
Anissuermayrelyonthelistofquali-
fied census tracts set forth in this revenue
procedure with respect to a commitment
to provide financing, if that commitment
was made during the period specified in
this section
, or the if purchase of the res-
idence was m
ade during the period speci-
fied in thi
s section. The period begins on
November
10, 2003, the date of publica-
tion of t
his revenue procedure in the In-
terna
l Revenue Bulletin, and ends on the
date a
s of which the list of qualified census
trac
ts is rendered obsolete by a new rev-
enu
e procedure.
SEC
TION 6. EFFECTIVE DATE
This revenue procedure is effective on
November 10, 2003, the date of publica-
tion of this revenue procedure in the In-
ternal Revenue Bulletin, and ends on the
date as of whi
ch the list of qualified census
tracts is re
ndered obsolete by a new rev-
enue proce
dure.
SECTION 7.
DRAFTING
INFORMA
TION
The principal authors of this revenue
procedure are Laura W. Lederman and
TimothyL.JonesoftheOfficeofAs-
sociate Chief Counsel (Tax Exempt and
Government Entities). For further infor-
mation regarding this revenue procedure,
contact Ms. Lederman at (202) 622–3980
(not a toll-free call).
November 10, 200310482003-45 I.R.B.

Part IV. Items of General Interest
Golden Parachute Payments;
Correction
Announcement 2003–60
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Correction to final regulations.
SUMMARY: This document contains cor-
rections to final regulations (T.D. 9083,
2003–40 I. R.B. 700) that were published
in theFederal Registeron Monday,
August 4, 2003 (68 FR 45745), relating to
golden parachute payments under section
280G of the Internal Revenue Code.
EFFECTIVE DATE: This correction is ef-
fective August 4, 2003.
FOR FURTHER INFORMATION
CONTACT: Erinn Madden (202)
622–6030 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations that are the sub-
ject of these corrections are under section
280G of the Internal Revenue Code.
Need for Correction
As published, the final regulations (T.D.
9083) contain errors that may prove to be
misleading and are in need of clarification.
Correction of Publication
Accordingly, the publication of the fi-
nal regulations (T.D. 9083), which are the
subject of FR Doc. 03–19274, is corrected
as follows:
1. On page 45745, column 3, in the pre-
amble, the caption “DATES” is corrected
to read as follows:
DATES:Effective Date: August 4,
2003.
Applicability Date: These regulations
apply to any payment that is contingent
on a change in ownership or control if the
change in ownership or control occurs on
or after January 1, 2004. However, tax-
payers may rely on these regulations after
August 4, 2003, for the treatment of any
parachute payment.
2. On page 45750, column 1, in the pre-
amble under the paragraph heading “Ef-
fective Date and Reliance”, paragraph 1,
line 5, the language “on or after January
1, 2004.” is corrected to read “on or af-
ter January 1, 2004. However, taxpayers
may rely on these regulations after August
4, 2003, for the treatment of any parachute
payment.”.
3. On page 45750, columns 1 and 2, in
the preamble under the paragraph heading
“Effective Date and Reliance”, the last line
inthecolumn1andfirstlineincolumn2,
the language “2002 proposed regulations
until the effective date of the final regula-
tions.” is corrected to read “2002 proposed
regulations until January 1, 2004.”.
§ 1.280G–1 [Corrected]
4.On page 45755, column 2,
§ 1.280G–1, paragraph (a) of A–11,
line 3, the language “to receive cash, or a
transfer of property” is corrected to read
“to receive cash (including the value of
accelerated vesting under Q/4–24(c)), or a
transfer of property.”.
5.On page 45772, column 2,
§ 1.280G–1, A–48, line 5, the language
“on or after January 1, 2004.” is corrected
to read “on or after January 1, 2004. Tax-
payers may rely on these regulations after
August 4, 2003, for the treatment of any
parachute payment.”.
Cynthia E. Grigsby,
Acting Chief, Publications and
Regulations Branch,
Legal Processing Division,
Associate Chief Counsel (Procedures
and Administration).
(Filed by the Office of the Federal Register on October 10,
2003, 8:45 a.m., and published in the issue of the Federal
Register for October 14, 2003, 68 F.R. 59114)
IRS and The George Washington
University Law School
To Sponsor Institute on
International Tax Issues
Announcement 2003–66
The Internal Revenue Service an-
nounces the Sixteenth Annual Institute
on Current Issues in International Tax-
ation, jointly sponsored by the Internal
Revenue Service and The George Wash-
ington University Law School, to be held
on December 11 and 12, 2003, at the
J.W. Marriott Hotel in Washington, DC.
Registration is currently underway for the
Institute, which is intended for interna-
tional tax professionals.
The program will present a unique op-
portunity for top IRS and Treasury officials
and tax experts, and leading private sector
specialists, to address breaking issues and
present key perspectives on new develop-
ments. The first day will feature sessions
on the following:
•Current Competent Authority Issues
(with the Competent Authorities of
France, Japan, Korea, and the United
States;
•Managing the Risks of Permanent Es-
tablishment in a Global Business;
•Latest IRS Transfer Pricing Guidance;
•Highlights of Current US Treaty Policy
and Practice; and
•Updates on Outbound Issues.
The Honorable Pamela F. Olson, Assis-
tant Secretary (Tax Policy), U.S. Depart-
ment of the Treasury, will deliver the lun-
cheon address. The day will begin with
an address by the Honorable George Yin,
Chief of Staff, Joint Committee on Taxa-
tion.
The second day will focus on the fol-
lowing topics:
•Updates on Inbound Issues;
•Foreign Tax Credit — The ABCs of
FTCs;
•Legislative Developments and Other
Breaking News; and
•Application of Tax Shelter Rules to In-
ternational Transactions.
Emily Parker, Acting Chief Counsel,
Internal Revenue Service will deliver the
luncheon address. The second day will
also include an “Ask the IRS” panel fea-
turing senior officials from the Service.
2003-45 I.R.B.1049November 10, 2003

Those interested in attending or ob-
taining more information should contact
The George Washington University Law
School, athttp://www.law.gwu.edu/ciit.
Delay of Rolling Renewal
Schedule for Enrolled Agents
Under Section 10.6(d)(1) of
Treasury Department Circular
No. 230, 31 CFR part 10
Announcement 2003–68
The Internal Revenue Service an-
nounces a delay of the implementation
of the new rolling renewal schedule for
enrolled agents to renew their enrollment
under section 10.6(d)(1) of the Regu-
lations Governing Practice Before the
Internal Revenue Service, Treasury De-
partment Circular No. 230, 31 CFR part
10. Under Treasury Department Circular
No. 230, amended July 26, 2002, approx-
imately one-third of all enrolled agents
will renew their enrollment each year ac-
cordingtoarollingrenewalschedulefor
enrollment. Except for those individuals
who receive their initial enrollment after
November 1, 2003, individuals licensed
to practice before the Internal Revenue
Service who have a social security number
or tax identification number that ends
with the numbers 0, 1, 2, or 3 (affected
enrolled agents) are scheduled to apply for
enrollment between November 1, 2003,
and January 31, 2004.
To ensure an orderly transition to
rolling renewals, the implementation of
the new renewal of enrollment schedule
for affected enrolled agents will be de-
layed until the 2004 calendar year. The
Internal Revenue Service will publish the
schedule for affected enrolled agents to
apply for renewal of enrollment in the In-
ternal Revenue Bulletin and on the Office
of Professional Responsibility webpage at
http://www.irs.gov/taxpros/agents/index
.htmlat least 30 calendar days prior to
the beginning of the period for renewal of
enrollment and no later than June 1, 2004.
The period for renewal of enrollment will
last at least 60 calendar days, but no more
than 90 calendar days.
Affected enrolled agents should not file
an application for renewal of enrollment
before the period for renewal of enrollment
is announced in the Internal Revenue Bul-
letin and on the Office of Professional Re-
sponsibility webpage. This delay will not
impact an affected enrolled agent’s current
status as an enrolled agent in good stand-
ing. This delay will not affect the num-
ber of hours of continuing professional ed-
ucation required for renewal or the time
period within which these hours must be
completed.
The principal author of this announce-
ment is Heather L. Dostaler of the Office
of Associate Chief Counsel (Procedure
and Administration). For further informa-
tion regarding this announcement, contact
Heather L. Dostaler at (202) 622–4940
(not a toll-free call).
November 10, 200310502003-45 I.R.B.

Definition of Terms
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 ef-
fect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is be-
ingextendedtoapplytoavariationofthe
fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that the
same principle also applies to B, the earlier
ruling is amplified. (Compare withmodi-
fied,below).
Clarifiedis used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confusion.
It is not used where a position in a prior
ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis 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 applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
withamplifiedandclarified,above).
Obsoleteddescribes 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 rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
beingstatedinanewruling.
Supersededdescribes a situation where
the new ruling does nothing more than re-
state the substance and situation of a previ-
ously published ruling (or rulings). Thus,
the term is used to republish under the
1986 Code and regulations the same po-
sition published under the 1939 Code and
regulations. The term is also used when
it is desired to republish in a single rul-
ing a series of situations, names, etc., that
were previously published over a period of
time in separate rulings. If the new rul-
ing does more than restate the substance
of a prior ruling, a combination of terms
is used. For example,modifiedandsu-
persededdescribes a situation where the
substance of a previously published 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 pub-
lished ruling is first modified and then, as
modified, is superseded.
Supplementedis 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 rul-
ing has been supplemented several times, a
new ruling may be published that includes
the list in the original ruling and the ad-
ditions, and supersedes all prior rulings in
the series.
Suspendedis used in rare situations
to show that the previous published rul-
ings 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 formerly 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.—Statement 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.
2003-45 I.R.B.iNovember 10, 2003

Numerical Finding List
1
Bulletins 2003–27 through 2003–45
Announcements:
2003-45, 2003-28 I.R.B.73
2003-46, 2003-30 I.R.B.222
2003-47, 2003-29 I.R.B.124
2003-48, 2003-28 I.R.B.73
2003-49, 2003-32 I.R.B.339
2003-50, 2003-30 I.R.B.222
2003-51, 2003-37 I.R.B.555
2003-52, 2003-32 I.R.B.345
2003-53, 2003-32 I.R.B.345
2003-54, 2003-40 I.R.B.762
2003-55, 2003-38 I.R.B.597
2003-56, 2003-39 I.R.B.694
2003-57, 2003-37 I.R.B.555
2003-58, 2003-40 I.R.B.746
2003-59, 2003-40 I.R.B.746
2003-60, 2003-45 I.R.B.1049
2003-61, 2003-42 I.R.B.890
2003-62, 2003-41 I.R.B.821
2003-63, 2003-45 I.R.B.1015
2003-64, 2003-43 I.R.B.934
2003-65, 2003-43 I.R.B.935
2003-66, 2003-45 I.R.B.1049
2003-67, 2003-44 I.R.B.1005
2003-68, 2003-45 I.R.B.1050
Notices:
2003-38, 2003-27 I.R.B.9
2003-39, 2003-27 I.R.B.10
2003-40, 2003-27 I.R.B.10
2003-41, 2003-28 I.R.B.49
2003-42, 2003-28 I.R.B.49
2003-43, 2003-28 I.R.B.50
2003-44, 2003-28 I.R.B.52
2003-45, 2003-29 I.R.B.86
2003-46, 2003-28 I.R.B.53
2003-47, 2003-30 I.R.B.132
2003-48, 2003-30 I.R.B.133
2003-49, 2003-32 I.R.B.294
2003-50, 2003-32 I.R.B.295
2003-51, 2003-33 I.R.B.361
2003-52, 2003-32 I.R.B.296
2003-53, 2003-33 I.R.B.362
2003-54, 2003-33 I.R.B.363
2003-55, 2003-34 I.R.B.395
2003-56, 2003-34 I.R.B.396
2003-57, 2003-34 I.R.B.397
2003-58, 2003-35 I.R.B.429
2003-59, 2003-35 I.R.B.429
2003-60, 2003-39 I.R.B.643
2003-61, 2003-42 I.R.B.851
2003-62, 2003-38 I.R.B.576
Notices— Continued:
2003-63, 2003-38 I.R.B.577
2003-64, 2003-39 I.R.B.646
2003-65, 2003-40 I.R.B.748
2003-67, 2003-40 I.R.B.753
2003-68, 2003-41 I.R.B.824
2003-69, 2003-42 I.R.B.851
2003-70, 2003-43 I.R.B.916
2003-71, 2003-43 I.R.B.922
2003-72, 2003-44 I.R.B.964
2003-73, 2003-45 I.R.B.1017
Proposed Regulations:
REG-209377-89, 2003-36 I.R.B.521
REG-208199-91, 2003-40 I.R.B.757
REG-106486-98, 2003-42 I.R.B.853
REG-108639-99, 2003-35 I.R.B.431
REG-106736-00, 2003-28 I.R.B.60
REG-108524-00, 2003-42 I.R.B.869
REG-115037-00, 2003-44 I.R.B.967
REG-140378-01, 2003-41 I.R.B.825
REG-107618-02, 2003-27 I.R.B.13
REG-122917-02, 2003-27 I.R.B.15
REG-128203-02, 2003-41 I.R.B.828
REG-131997-02, 2003-33 I.R.B.366
REG-133791-02, 2003-35 I.R.B.493
REG-138495-02, 2003-37 I.R.B.541
REG-138499-02, 2003-37 I.R.B.541
REG-140808-02, 2003-38 I.R.B.582
REG-140930-02, 2003-38 I.R.B.583
REG-141402-02, 2003-43 I.R.B.932
REG-141669-02, 2003-34 I.R.B.408
REG-142538-02, 2003-38 I.R.B.590
REG-143679-02, 2003-38 I.R.B.592
REG-144908-02, 2003-38 I.R.B.593
REG-146893-02, 2003-44 I.R.B.967
REG-157164-02, 2003-44 I.R.B.1004
REG-162625-02, 2003-35 I.R.B.500
REG-163974-02, 2003-38 I.R.B.595
REG-108676-03, 2003-36 I.R.B.523
REG-112039-03, 2003-35 I.R.B.504
REG-113112-03, 2003-40 I.R.B.761
REG-116914-03, 2003-32 I.R.B.338
REG-121122-03, 2003-37 I.R.B.550
REG-129709-03, 2003-35 I.R.B.506
REG-130262-03, 2003-37 I.R.B.553
REG-132483-03, 2003-34 I.R.B.410
REG-132760-03, 2003-43 I.R.B.933
Revenue Procedures:
2003-45, 2003-27 I.R.B.11
2003-46, 2003-28 I.R.B.54
2003-47, 2003-28 I.R.B.55
2003-48, 2003-29 I.R.B.86
2003-49, 2003-29 I.R.B.89
Revenue Procedures— Continued:
2003-50, 2003-29 I.R.B.119
2003-51, 2003-29 I.R.B.121
2003-52, 2003-30 I.R.B.134
2003-53, 2003-31 I.R.B.230
2003-54, 2003-31 I.R.B.236
2003-55, 2003-31 I.R.B.242
2003-56, 2003-31 I.R.B.249
2003-57, 2003-31 I.R.B.257
2003-58, 2003-31 I.R.B.262
2003-59, 2003-31 I.R.B.268
2003-60, 2003-31 I.R.B.274
2003-61, 2003-32 I.R.B.296
2003-62, 2003-32 I.R.B.299
2003-63, 2003-32 I.R.B.304
2003-64, 2003-32 I.R.B.306
2003-65, 2003-32 I.R.B.336
2003-66, 2003-33 I.R.B.364
2003-67, 2003-34 I.R.B.397
2003-68, 2003-34 I.R.B.398
2003-69, 2003-34 I.R.B.403
2003-70, 2003-34 I.R.B.406
2003-71, 2003-36 I.R.B.517
2003-72, 2003-38 I.R.B.578
2003-73, 2003-39 I.R.B.647
2003-74, 2003-43 I.R.B.923
2003-75, 2003-45 I.R.B.1018
2003-76, 2003-43 I.R.B.924
2003-77, 2003-44 I.R.B.964
2003-78, 2003-45 I.R.B.1029
2003-79, 2003-45 I.R.B.1036
2003-80, 2003-45 I.R.B.1037
2003-81, 2003-45 I.R.B.1046
Revenue Rulings:
2003-70, 2003-27 I.R.B.3
2003-71, 2003-27 I.R.B.1
2003-72, 2003-33 I.R.B.346
2003-73, 2003-28 I.R.B.44
2003-74, 2003-29 I.R.B.77
2003-75, 2003-29 I.R.B.79
2003-76, 2003-33 I.R.B.355
2003-77, 2003-29 I.R.B.75
2003-78, 2003-29 I.R.B.76
2003-79, 2003-29 I.R.B.80
2003-80, 2003-29 I.R.B.83
2003-81, 2003-30 I.R.B.126
2003-82, 2003-30 I.R.B.125
2003-83, 2003-30 I.R.B.128
2003-84, 2003-32 I.R.B.289
2003-85, 2003-32 I.R.B.291
2003-86, 2003-32 I.R.B.290
2003-87, 2003-29 I.R.B.82
2003-88, 2003-32 I.R.B.292
2003-89, 2003-37 I.R.B.525
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2003-1 through 2003-26 is in Internal Revenue Bulletin 2003-27,
dated July 7, 2003.
November 10, 2003ii2003-45 I.R.B.

Revenue Rulings— Continued:
2003-90, 2003-33 I.R.B.353
2003-91, 2003-33 I.R.B.347
2003-92, 2003-33 I.R.B.350
2003-93, 2003-33 I.R.B.346
2003-94, 2003-33 I.R.B.357
2003-95, 2003-33 I.R.B.358
2003-96, 2003-34 I.R.B.386
2003-97, 2003-34 I.R.B.380
2003-98, 2003-34 I.R.B.378
2003-99, 2003-34 I.R.B.388
2003-100, 2003-34 I.R.B.385
2003-101, 2003-36 I.R.B.513
2003-102, 2003-38 I.R.B.559
2003-103, 2003-38 I.R.B.568
2003-104, 2003-39 I.R.B.636
2003-105, 2003-40 I.R.B.696
2003-106, 2003-44 I.R.B.936
2003-107, 2003-41 I.R.B.815
2003-108, 2003-44 I.R.B.963
2003-109, 2003-42 I.R.B.839
2003-111, 2003-45 I.R.B.1009
2003-112, 2003-45 I.R.B.1007
2003-113, 2003-44 I.R.B.962
2003-114, 2003-45 I.R.B.1012
Tax Conventions:
2003-58, 2003-40 I.R.B.746
2003-59, 2003-40 I.R.B.746
2003-62, 2003-41 I.R.B.821
2003-63, 2003-45 I.R.B.1015
Treasury Decisions:
9061, 2003-27 I.R.B.5
9062, 2003-28 I.R.B.46
9063, 2003-36 I.R.B.510
9064, 2003-36 I.R.B.508
9065, 2003-36 I.R.B.515
9066, 2003-36 I.R.B.509
9067, 2003-32 I.R.B.287
9068, 2003-37 I.R.B.538
9069, 2003-37 I.R.B.525
9070, 2003-38 I.R.B.574
9071, 2003-38 I.R.B.560
9072, 2003-37 I.R.B.527
9073, 2003-38 I.R.B.570
9074, 2003-39 I.R.B.601
9075, 2003-39 I.R.B.608
9076, 2003-38 I.R.B.562
9077, 2003-39 I.R.B.634
9078, 2003-39 I.R.B.630
9079, 2003-40 I.R.B.729
9080, 2003-40 I.R.B.696
9081, 2003-35 I.R.B.420
9082, 2003-41 I.R.B.807
9083, 2003-40 I.R.B.700
9084, 2003-40 I.R.B.742
9085, 2003-41 I.R.B.775
Treasury Decisions— Continued:
9086, 2003-41 I.R.B.817
9087, 2003-41 I.R.B.781
9088, 2003-42 I.R.B.841
9089, 2003-43 I.R.B.906
9090, 2003-43 I.R.B.891
9091, 2003-44 I.R.B.939
2003-45 I.R.B.iiiNovember 10, 2003

Findings List of Current Actions on
Previously Published Items
1
Bulletins 2003-27 through 2003-45
Notices:
87-5
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
87-66
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
87-79
Modified by
Notice 2003-65, 2003-40 I.R.B.748
89-79
Modified and superseded by
Rev. Proc. 2003-47, 2003-28 I.R.B.55
89-94
Modified by
Notice 2003-50, 2003-32 I.R.B.295
94-46
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
95-18
Modified by
Notice 2003-70, 2003-43 I.R.B.916
95-50
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
95-53
Modified and superseded by
Notice 2003-55, 2003-34 I.R.B.395
2001-4
Section III.C. superseded for 2004 and subsequent
calendar years by
Rev. Proc. 2003-64, 2003-32 I.R.B.306
2001-70
Amplified by
Notice 2003-45, 2003-29 I.R.B.86
2001-74
Amplified by
Notice 2003-45, 2003-29 I.R.B.86
2002-1
Amplified by
Notice 2003-49, 2003-32 I.R.B.294
2003-12
Obsoleted by
T.D. 9090, 2003-43 I.R.B.891
REG-141402-02, 2003-43 I.R.B.932
Notices— Continued:
2003-36
Modified by
Notice 2003-59, 2003-35 I.R.B.429
Proposed Regulations:
REG-EE-86-88 (LR-279-81)
Withdrawn by
REG-122917-02, 2003-27 I.R.B.15
REG-105606-99
Withdrawn by
REG-133791-02, 2003-35 I.R.B.493
Revenue Procedures:
66-3
Revoked by
Rev. Proc. 2003-74, 2003-43 I.R.B.923
66-50
Modified, amplified, and superseded by
Rev. Proc. 2003-62, 2003-32 I.R.B.299
68-23
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
68-41
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
70-6
Modified and superseded, in part by
Notice 2003-70, 2003-43 I.R.B.916
77-12
Amplified, modified, and superseded by
Rev. Proc. 2003-51, 2003-29 I.R.B.121
80-4
Modified and amplified by
Notice 2003-70, 2003-43 I.R.B.916
81-40
Modified and superseded by
Rev. Proc. 2003-62, 2003-32 I.R.B.299
84-71
Revoked by
Rev. Proc. 2003-74, 2003-43 I.R.B.923
85–56
Revoked by
Rev. Proc. 2003-74, 2003-43 I.R.B.923
87–21
Revoked by
Rev. Proc. 2003-74, 2003-43 I.R.B.923
89-12
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
Revenue Procedures— Continued:
89-21
Superseded by
Rev. Proc. 2003-53, 2003-31 I.R.B.230
89-31
Obsoleted by
REG-108524-00, 2003-42 I.R.B.869
90-19
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
90-32
Section4supersededby
Rev. Proc. 2003-55, 2003-31 I.R.B.242
Section5supersededby
Rev. Proc. 2003-56, 2003-31 I.R.B.249
Section6supersededby
Rev. Proc. 2003-57, 2003-31 I.R.B.257
Section7supersededby
Rev. Proc. 2003-59, 2003-31 I.R.B.268
Section8supersededby
Rev. Proc. 2003-60, 2003-31 I.R.B.274
91-11
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
91-13
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
91-39
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
92-33
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
92-35
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
92–39
Superseded in part by
Rev. Proc. 2003-78, 2003-43 I.R.B.1029
92-66
Obsoleted by
REG-108524-00, 2003-42 I.R.B.869
92-88
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
93-17
Obsoleted by
REG-132483-03, 2003-34 I.R.B.408
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2003-1 through 2003-26 is in Internal Revenue Bulletin 2003-27, dated July 7, 2003.
November 10, 2003iv2003-45 I.R.B.

Revenue Procedures— Continued:
94-46
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
94-52
Revoked by
Rev. Proc. 2003-74, 2003-43 I.R.B.923
95-10
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
95-11
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
95-39
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
96-17
Modified and superseded by
Rev. Proc. 2003-69, 2003-34 I.R.B.402
96-30
Modified and amplified by
Rev. Proc. 2003-48, 2003-29 I.R.B.86
96-38
Obsoleted by
Rev. Proc. 2003-71, 2003-36 I.R.B.517
97-11
Revoked by
Rev. Proc. 2003-74, 2003-43 I.R.B.923
2000-12
Modified by
Rev. Proc. 2003-64, 2003-32 I.R.B.306
2000-15
Superseded by
Rev. Proc. 2003-61, 2003-32 I.R.B.296
2000-20
Modified by
Rev. Proc. 2003-72, 2003-38 I.R.B.578
2001-19
Amplified by
Rev. Proc. 2003-75, 2003-45 I.R.B. 451018
2002-9
Modified by
T.D. 9090, 2003-43 I.R.B.891
REG-141402-02, 2003-43 I.R.B.932
Rev. Proc. 2003-45, 2003-27 I.R.B.11
Amplified and modified by
Rev. Proc. 2003-50, 2003-29 I.R.B.119
Modified and amplified by
Rev. Proc. 2003-63, 2003-32 I.R.B.304
Rev. Rul. 2003-81, 2003-30 I.R.B.126
2002-13
Revoked by
Rev. Proc. 2003-68, 2003-34 I.R.B.398
Revenue Procedures— Continued:
2002-14
Amplified by
Rev. Proc. 2003-75, 2003-45 I.R.B. 451018
2002-29
Modified by
Rev. Proc. 2003-72, 2003-38 I.R.B.578
2002-33
Amplified and modified by
Rev. Proc. 2003-50, 2003-29 I.R.B.119
2002-34
Superseded by
Rev. Proc. 2003-52, 2003-30 I.R.B.134
2002-38
Modified by
Rev. Proc. 2003-79, 2003-45 I.R.B. 451036
2002-39
Modified by
Rev. Proc. 2003-79, 2003-45 I.R.B. 451036
2002-45
Revoked by
Rev. Proc. 2003-68, 2003-34 I.R.B.398
2002-60
Superseded by
Rev. Proc. 2003-73, 2003-39 I.R.B.647
2002-61
Superseded by
Rev. Proc. 2003-76, 2003-43 I.R.B.924
2002-63
Superseded by
Rev. Proc. 2003-80, 2003-45 I.R.B.1037
2003-3
Modified by
Rev. Proc. 2003-48, 2003-29 I.R.B.86
2003-15
Modified and superseded by
Rev. Proc. 2003-49, 2003-29 I.R.B.89
2003-28
Modified by
Ann. 2003-35, 2003-38 I.R.B.597
2003-44
Modified by
Rev. Proc. 2003-72, 2003-38 I.R.B.578
2003-49
Supplemented by
Rev. Proc. 2003-81, 2003-45 I.R.B.1046
Revenue Rulings:
53-56
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
Revenue Rulings— Continued:
54-139
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
54-396
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
55-105
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
55-372
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
56-128
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
56-160
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
56-212
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
56-220
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
56-271
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
56-344
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
56-448
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
56-451
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
56-586
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
56-680
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
56-681
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
57-116
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
57-296
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
2003-45 I.R.B.vNovember 10, 2003

Revenue Rulings— Continued:
57-542
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
58-92
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
58-618
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
59-108
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
59-120
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
59-122
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
59-233
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
59-326
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
59-356
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
59-400
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
59-412
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
60-49
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
60-246
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
60-262
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
60-307
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
61-96
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
63-157
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
Revenue Rulings— Continued:
63-224
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
63-248
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
64-147
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
64-177
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
64-285
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
65-110
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
65-260
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
65-273
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
66-4
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
66-23
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
66-610
Partially obsoleted by
Rev. Rul. 2003-105, 2003-40 I.R.B.696
66-290
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
67-186
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
67-189
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
67-326
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
68-309
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
68-388
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
Revenue Rulings— Continued:
68-434
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
68-477
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
68-522
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
68-608
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
68-640
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
68-641
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
69-18
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
69-20
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
69-241
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
69-361
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
69-426
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
69-485
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
69-517
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
70-6
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
70-111
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
70-229
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
70-230
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
November 10, 2003vi2003-45 I.R.B.

Revenue Rulings— Continued:
70-264
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
70-286
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
70-378
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
70-409
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
70-496
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
71-13
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
71-384
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
71-440
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
71-453
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
71-454
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
71-495
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
71-518
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
71-565
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
71-582
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
72-61
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
72-116
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
72-212
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
Revenue Rulings— Continued:
72-357
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
72-472
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
72-526
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
72-599
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
72-603
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
73-46
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
73-119
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
73-182
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
73-257
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
73-277
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
73-473
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
73-490
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
73-498
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
74-6
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
74-59
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
74-73
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
74-83
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
Revenue Rulings— Continued:
74-87
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
74-211
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
74-376
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
74-476
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
74-521
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
74-610
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
75-53
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
75-54
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
75-105
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
75-106
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
75-107
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
75-111
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
75-134
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
75-160
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
75-174
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
75-179
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
75-212
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
2003-45 I.R.B.viiNovember 10, 2003

Revenue Rulings— Continued:
75-248
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
75-298
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
75-341
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
75-426
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
75-468
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
75-515
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
75-561
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
76-44
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
76-67
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
76-90
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
76-225
Revoked by
T.D. 9068, 2003–37538
76-239
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
76-329
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
76-347
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
76-535
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
77-41
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
77-81
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
Revenue Rulings— Continued:
77-150
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
77-256
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
77-284
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
77-321
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
77-343
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
77-405
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
77-456
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
77-482
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
77-483
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
78-89
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
78-287
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
78-420
Obsoleted by
Rev. Rul. 2003-105, 2003-40 I.R.B.696
78-441
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
79-29
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
79-50
Obsoleted by
Rev. Rul. 2003-105, 2003-40 I.R.B.696
79-71
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
79-82
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
Revenue Rulings— Continued:
79-104
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
79-116
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
79-314
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
79-410
Amplified by
Rev. Rul. 2003-90, 2003-33 I.R.B.353
79-424
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
80-78
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
80-79
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
80-101
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
80-167
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
80-170
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
80-358
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
81-190
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
81-225
Clarified and amplified by
Rev. Rul. 2003-92, 2003-33 I.R.B.350
81-247
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
82-164
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
82-226
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
83-101
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
November 10, 2003viii2003-45 I.R.B.

Revenue Rulings— Continued:
83-119
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
84-28
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
84-30
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
85-55
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
85-136
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
86-52
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
87-1
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
87-95
Superseded by
Rev. Rul. 2003-109, 2003-42 I.R.B.839
88-7
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
89-72
Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B.388
94-56
Superseded by
Rev. Rul. 2003-109, 2003-42 I.R.B.839
2003-58
Distinguished by
Rev. Rul. 2003-102, 2003-38 I.R.B.559
Treasury Decisions:
9033
Removed by
T.D. 9065, 2003-36 I.R.B.515
9083
Corrected by
Ann. 2003-60, 2003-45 I.R.B.1049
2003-45 I.R.B.ixNovember 10, 2003
*U.S.G.P.O.: 2003—304–774/60108