rr-06-61.pdf

us-irs-revenue-rulings-rr-06-61rr-06-61.pdfGuidance

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# 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. 2006-61

This revenue ruling provides various prescribed rates for federal income tax
purposes for December 2006 (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.
Table 5 contains the federal rate for determining the present value of an annuity, an
interest for life or for a term of years, or a remainder or a reversionary interest for
purposes of section 7520. Finally, Table 6 contains contains the 2007 interest rate for
sections 846 and 807.

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# REV. RUL. 2006-61 TABLE 1 Applicable Federal Rates (AFR) for December 2006

Period for Compounding

Annual

Semiannual

Quarterly

Monthly

Short-term

AFR

4.97%

4.91%

4.88%

4.86%

110% AFR

5.47%

5.40%

5.36%

5.34%

120% AFR

5.98%

5.89%

5.85%

5.82%

130% AFR

6.48%

6.38%

6.33%

6.30%

Mid-term

AFR

4.73%

4.68%

4.65%

4.64%

110% AFR

5.22%

5.15%

5.12%

5.10%

120% AFR

5.70%

5.62%

5.58%

5.56%

130% AFR

6.17%

6.08%

6.03%

6.00%

150% AFR

7.14%

7.02%

6.96%

6.92%

175% AFR

8.36%

8.19%

8.11%

8.05%

Long-term

AFR

4.90%

4.84%

4.81%

4.79%

110% AFR

5.39%

5.32%

5.29%

5.26%

120% AFR

5.89%

5.81%

5.77%

5.74%

130% AFR

6.39%

6.29%

6.24%

6.21%

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REV. RUL. 2006-61 TABLE 2 Adjusted AFR for December 2006

Period for Compounding Annual Semiannual Quarterly Monthly

Short-term adjusted AFR

3.42%

3.39%

3.38%

3.37%

Mid-term adjusted AFR

3.59%

3.56%

3.54%

3.53%

Long-term adjusted AFR

4.14%

4.10%

4.08%

4.07%

REV. RUL. 2006-61 TABLE 3
Rates Under Section 382 for December 2006

Adjusted federal long-term rate for the current month
4.14%

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.)
4.22%

# REV. RUL. 2006-61 TABLE 4

Appropriate Percentages Under Section 42(b)(2) for December 2006

Appropriate percentage for the 70% present value low-income

housing credit

8.12%

Appropriate percentage for the 30% present value low-income

housing credit

3.48%

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# REV. RUL. 2006-61 TABLE 5 Rate Under Section 7520 for December 2006

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
5.8%

REV. RUL. 2005-61 TABLE 6

Applicable rate of interest for 2007 for purposes of section
846 and 807
3.97%

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