rr-04-25.pdf

us-irs-revenue-rulings-rr-04-25rr-04-25.pdfGuidance

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Part I

Section 1274.--Determination 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.)

Rev. Rul. 2004-25

This revenue ruling provides various prescribed rates for federal income tax purposes
for March 2004 (the current month). Table 1 contains the short-term, mid-term, and
long-term applicable federal 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 in
section 42(b)(2) for buildings placed in service during the current month. Finally, Table 5
contains the federal rate for determining 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. 2004-25 TABLE 1

Applicable Federal Rates (AFR) for March 2004

Period for Compounding

Annual
Semiannual Quarterly Monthly

Short-term

AFR 1.58% 1.57% 1.57% 1.56%
110% AFR 1.74% 1.73% 1.73% 1.72%
120% AFR 1.89% 1.88% 1.88% 1.87%
130% AFR 2.05% 2.04% 2.03% 2.03%

Mid-term

AFR 3.34% 3.31% 3.30% 3.29%
110% AFR 3.67% 3.64% 3.62% 3.61%
120% AFR 4.01% 3.97% 3.95% 3.94%
130% AFR 4.35% 4.30% 4.28% 4.26%
150% AFR 5.03% 4.97% 4.94% 4.92%
175% AFR 5.87% 5.79% 5.75% 5.72%

Long-term

AFR 4.84% 4.78% 4.75% 4.73%
110% AFR 5.33% 5.26% 5.23% 5.20%
120% AFR 5.82% 5.74% 5.70% 5.67%
130% AFR 6.31% 6.21% 6.16% 6.13%

REV. RUL. 2004-25 TABLE 2

Rates Under Section 382 for March 2004

Period for Compounding

Annual
Semiannual Quarterly Monthly

Short-term
adjusted AFR 1.30% 1.30% 1.30% 1.30%
Mid-term
adjusted AFR 2.47% 2.45% 2.44% 2.44%

Long-term
adjusted AFR 4.19% 4.15% 4.13% 4.11%

REV. RUL. 2004-25 TABLE 3
Rates Under Section 382 for March 2004

Adjusted federal long-term rate for the current month 4.19%

Long-term tax-exempt rate for ownership changes during the
current month (the highest of the adjusted federal long-term
rates for the current month and the prior two months.) 4.40%

Rev. Rul. 2004-25 TABLE 4

Appropriate Percentages Under Section 42(b)(2) for March 2004

Appropriate percentage for the 70% present value low-income
housing credit 7.95%

5
Appropriate percentage for the 30% present value low-income
housing credit 3.41%

REV. RUL. 2004-25 TABLE 5

Rate Under Section 7520 for March 2004

Applicable federal rate for determining the present value of an
annuity, an interest for life or a term of years, or a remainder or
reversionary interest 4.0%

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