Internal Revenue Bulletin 1996-47 (PDF rendition): IRS Announcements

Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.

INCOME TAX
Rev. Rul. 96–54, page 5.
LIFO; price indexes; department stores.The Septem-
ber 1996 Bureau of Labor Statistics price indexes are
accepted for use by department stores employing the
retail inventory and last-in, first-out inventory methods
for valuing inventories for tax years ended on, or with
reference to, September 30, 1996.
EMPLOYEE PLANS
Rev. Rul. 96–53, page 4.
Covered compensation tables; 1997.The covered
compensation tables, for the 1997 calendar year for
determining contributions to defined benefit plans and
permitted disparity, are set forth.
Rev. Proc. 96–50, page 10.
Tax-sheltered annuities; correction program; exten-
sion.The TVC program, whereby certain plans within the
meaning of section 403(b) of the Code may voluntarily
correct certain operational defects in section 403(b)
tax-sheltered annuities and receive a “correction state-
ment” from the National Office, is extended.
Notice 96–55, page 7.
Retirement plans; 1997 cost-of-living adjustments.
Cost-of-living adjustments effective January 1, 1997,
applicable to the dollar limits on benefits under qualified
defined benefit pension plans and to other provisions
affecting certain plans of deferred compensation, are
set forth.
EXEMPT ORGANIZATIONS
Announcement 96–120, page 12.
A list is given of organizations now classified as private
foundations.
ADMINISTRATIVE
Rev. Proc. 96–51, page 10.
Low-income housing tax credit.This procedure pub-
lishes the amounts of unused housing credit carryovers
allocated to qualified states under section 42(h)(3)(D) of
the Code for calendar year 1996 in addition to those
published in Rev. Proc. 96–46, 1996–38 I.R.B. 144.
This procedure also publishes the total amounts of
unused housing credit carryovers allocated to qualified
states under section 42(h)(3)(D) for calendar year 1996.
Rev. Proc. 96–46 supplemented.
Notice 96–56, page 7.
This notice shows the amount that is exempt from levy
on an individual’s wages, salary, and other income
under section 6334(d) of the Code.
Notice 96–57, page 9.
Information reporting; Indian tribal casinos.The re-
porting requirements for cash transactions of more than
$10,000, from gaming activities of certain Indian tribal
casinos, are clarified.
Announcement 96–121, page 12.
The Treasury Department and the IRS are soliciting
comments on issues to be considered in developing
guidance under the newly enacted FASIT provisions of
the Code.
Announcement 96–122, page 13.
The 1996 update and future quarterly updates of
Publication 938, Real Estate Mortgage Investment Con-
duits (REMICs) Reporting Information (And Other Col-
lateralized Debt Obligations (CDOs)), will be available
only on the Internet and the IRS Electronic Bulletin
Board.
Finding Lists begin on page 17.
Announcements of Disbarments and Suspensions begin on page 14.
Bulletin No. 1996–47
November 18, 1996
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.

Mission of the Service
The purpose of the Internal Revenue Service is to
collect the proper amount of tax revenue at the least
cost; serve the public by continually improving the
quality of our products and services; and perform in a
manner warranting the highest degree of public
confidence in our integrity, efficiency and fairness.
Statement of Principles
of Internal Revenue
Tax Administration
The function of the Internal Revenue Service is to
administer the Internal Revenue Code. Tax policy
for raising revenue is determined by Congress.
With this in mind, it is the duty of the Service to
carry out that policy by correctly applying the laws
enacted by Congress; to determine the reasonable
meaning of various Code provisions in light of the
Congressional purpose in enacting them; and to
perform this work in a fair and impartial manner,
with neither a government nor a taxpayer point of view.
At the heart of administration is interpretation of the
Code. It is the responsibility of each person in the
Service, charged with the duty of interpreting the
law, to try to find the true meaning of the statutory
provision and not to adopt a strained construction in
the belief that he or she is ‘‘protecting the revenue.’’
The revenue is properly protected only when we as-
certain and apply the true meaning of the statute.
The Service also has the responsibility of applying
and administering the law in a reasonable,
practical manner. Issues should only be raised by
examining officers when they have merit, never
arbitrarily or for trading purposes. At the same
time, the examining officer should never hesitate
to raise a meritorious issue. It is also important
that care be exercised not to raise an issue or to
ask a court to adopt a position inconsistent with
an established Service position.
Administration should be both reasonable and
vigorous. It should be conducted with as little
delay as possible and with great courtesy and
considerateness. It should never try to overreach,
and should be reasonable within the bounds of law
and sound administration. It should, however, be
vigorous in requiring compliance with law and it
should be relentless in its attack on unreal tax
devices and fraud.
2

Introduction
The Internal Revenue Bulletin is the authoritative instru-
ment of the Commissioner of Internal Revenue for
announcing official rulings and procedures of the Inter-
nal Revenue Service and for publishing Treasury Deci-
sions, Executive Orders, Tax Conventions, legislation,
court decisions, and other items of general interest. It is
published weekly and may be obtained from the Superin-
tendent of Documents on a subscription basis. Bulletin
contents of a permanent nature are consolidated semi-
annually into Cumulative Bulletins, which are sold on a
single-copy basis.
It is the policy of the Service to publish in the Bulletin all
substantive rulings necessary to promote a uniform
application of the tax laws, including all rulings that
supersede, revoke, modify, or amend any of those
previously published in the Bulletin. All published rulings
apply retroactively unless otherwise indicated. Proce-
dures relating solely to matters of internal management
are not published; however, statements of internal
practices and procedures that affect the rights and
duties of taxpayers are published.
Revenue rulings represent the conclusions of the Ser-
vice 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 unwar-
ranted 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 proce-
dures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be consid-
ered, 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 decisions based on
provisions of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows:
Subpart A, Tax Conventions, and Subpart B, Legislation
and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to
these subjects are contained in the other Parts and
Subparts. Also included in this part are Bank Secrecy
Act Administrative Rulings. Bank Secrecy Act Administra-
tive Rulings are issued by the Department of the
Treasury’s Office of the Assistant Secretary (Enforce-
ment).
Part IV.—Items of General Interest.
With the exception of the Notice of Proposed Rulemak-
ing and the disbarment and suspension list included in
this part, none of these announcements are consoli-
dated in the Cumulative Bulletins.
The first Bulletin for each month includes an index for
the matters published during the preceding month.
These monthly indexes are cumulated on a quarterly and
semiannual basis, and are published in the first Bulletin
of the succeeding quarterly and semi-annual period,
respectively.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
For sale by the Superintendent of Documents U.S. Government Printing Office, Washington, D.C. 20402.
3

Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
Section 42.—Low-Income Housing
Credit
26 CFR 1.42–14: Allocation rules for post-1989
State housing credit ceiling amounts.
This procedure supplements Rev. Proc. 96–46,
1996–38 I.R.B. 144, by publishing amounts of
unused housing credit carryovers allocated to
qualified states under § 42(h)(3)(D) of the Internal
Revenue Code for calendar year 1996 in addition
to those published in Rev. Proc. 96–46. This
revenue procedure also publishes the total amounts
of unused housing credit carryovers allocated to
qualified states under § 42(h)(3)(D) for calendar
year 1996.
Section 401.—Qualified Pension,
Profit-Sharing, and Stock Bonus
Plans
Covered compensation tables; 1997.
The covered compensation tables for the
1997 calendar year for determining con-
tributions to defined benefit plans and
permitted disparity are set forth.
Rev. Rul. 96–53
This revenue ruling provides tables of
covered compensation under § 401(l)-
(5)(E) of the Internal Revenue Code (the
‘‘Code’’) and the Income Tax Regula-
tions, thereunder, for the 1997 plan year.
Section 401(l)(5)(E)(i) defines cov-
ered compensation with respect to an
employee, as the average of the contri-
bution and benefit bases in effect under
§ 230 of the Social Security Act (the
‘‘Act’’) for each year in the 35-year
period ending with the year in which the
employee attains social security retire-
ment age.
Section 401(l)(5)(E)(ii) of the Code
states that the determination for any
year preceding the year in which the
employee attains social security retire-
ment age shall be made by assuming
that there is no increase in covered
compensation after the determination
year and before the employee attains
social security retirement age.
Section 1.401(l)–1(c)(34) of the regu-
lations defines the taxable wage base as
the contribution and benefit base under
§ 230 of the Act.
Section 1.401(l)–1(c)(7)(i) defines
covered compensation for an employee
as the average (without indexing) of the
taxable wage bases in effect for each
calendar year during the 35-year period
ending with the last day of the calendar
year in which the employee attains (or
will attain) social security retirement
age. A 35-year period is used for all in-
dividuals regardless of the year of birth
of the individual. In determining an
employee’s covered compensation for a
plan year, the taxable wage base for all
calendar years beginning after the first
day of the plan year is assumed to be
the same as the taxable wage base in
effect as of the beginning of the plan
year. An employee’s covered compensa-
tion for a plan year beginning after the
35-year period applicable under
§ 1.401(l)–1(c)(7)(i) is the employee’s
covered compensation for a plan year
during which the 35-year period ends.
An employee’s covered compensation
for a plan year beginning before the
35-year period applicable under
§ 1.401–1(c)(7)(i) is the taxable wage
base in effect as of the beginning of the
plan year.
Section 1.401(l)–1(c)(7)(ii) provides
that, for purposes of determining the
amount of an employee’s covered com-
pensation under § 1.401(l)–1(c)(7)(i), a
plan may use tables, provided by the
Commissioner, that are developed by
rounding the actual amounts of covered
compensation for different years of
birth.
For purposes of determining covered
compensation for the 1997 year the
taxable wage base is $65,400.
The following tables provide covered
compensation for 1997:
1997 Covered Compensation Table
Calendar
Year of
Birth
Calendar Year
of Social
Security
Retirement
Age
1997
Covered
Compensation
19071972$4,488
190819734,704
190919745,004
191019755,316
191119765,664
191219776,060
191319786,480
191419797,044
191519807,692
191619818,460
191719829,300
1918198310,236
1919198411,232
1920198512,276
1921198613,368
1922198714,520
1923198815,708
1924198916,968
1925199018,312
1926199119,728
Calendar
Year of
Birth
Calendar Year
of Social
Security
Retirement
Age
1997
Covered
Compensation
1927199221,192
1928199322,716
1929199424,312
1930199525,920
1931199627,576
1932199729,304
1933199831,032
1934199932,772
1935200034,500
1936200136,180
1937200237,860
1938200441,148
1939200542,792
1940200644,448
1941200746,056
1942200847,616
1943200949,104
1944201050,568
1945201152,008
1946201253,400
1947201354,768
1948201455,980
1949201557,108
1950201658,128
1951201759,064
1952201859,916
1953201960,708
1954202061,440
1955202262,724
1956202363,312
1957202463,804
1958202564,212
1959202664,560
1960202764,836
1961202865,064
1962202965,196
1963203065,316
1964 or
later203165,400
1997 Rounded Covered
Compensation Table
Year of Birth
Covered
Compensation
1932–1933$30,000
193433,000
1935–193636,000
193739,000
1938–193942,000
1940–194145,000
1942–194348,000
1944–194551,000
1946–194754,000
1948–195057,000
1951–195460,000
4

1997 Rounded Covered
Compensation Table—Continued
Year of Birth
Covered
Compensation
1955–195763,000
1958 or later65,400
Drafting Information
The principal author of this revenue
ruling is Donna Prestia of the Employee
Plans Division. For further information
regarding this revenue ruling, call (202)
622–6076 between 2:30 and 4:00 East-
ern time (not a toll free number) Mon-
day thru Thursday. Ms. Prestia’s number
is (202) 622–7377 (also not a toll free
number).
Section 472.—Last-in, First-out
Inventories
26 CFR 1.472–1: Last-in, first-out inventories.
LIFO; price indexes; department
stores.The September 1996 Bureau of
Labor Statistics price indexes are ac-
cepted for use by department stores
employing the retail inventory and last-
in, first-out inventory methods for valu-
ing inventories for tax years ended on,
or with reference to, September 30,
1996.
Rev. Rul. 96–54
The following Department Store In-
ventory Price Indexes for September
1996 were issued by the Bureau of
Labor Statistics on October 16, 1996.
The indexes are accepted by the Internal
Revenue Service, under § 1.472–1(k) of
the Income Tax Regulations and Rev.
Proc. 86–46, 1986–2 C.B. 739, for ap-
propriate application to inventories of
department stores employing the retail
inventory and last-in, first-out inventory
methods for tax years ended on, or with
reference to, September 30, 1996.
The Department Store Inventory Price
Indexes are prepared on a national basis
and include (a) 23 major groups of
departments, (b) three special combina-
tions of the major groups - soft goods,
durable goods, and miscellaneous goods,
and (c) a store total, which covers all
departments, including some not listed
separately, except for the following:
candy, foods, liquor, tobacco, and con-
tract departments.
BUREAU OF LABOR STATISTICS, DEPARTMENT STORE
INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS
(January 1941 = 100, unless otherwise noted)
GroupsSep. 1995Sep. 1996
Percent Change
from Sep. 1995
to Sep. 1996
1
1. Piece Goods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .538.3534.80.7
2. Domestics and Draperies . . . . . . . . . . . . . . . . . . . . . . . . .663.4644.12.9
3. Women’s and Children’s Shoes. . . . . . . . . . . . . . . . . . . .646.4647.90.2
4. Men’s Shoes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .926.9916.11.2
5. Infants’ Wear. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .627.1631.90.8
6. Women’s Underwear . . . . . . . . . . . . . . . . . . . . . . . . . . . .517.1536.03.7
7. Women’s Hosiery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .285.7289.01.2
8. Women’s and Girls’ Accessories . . . . . . . . . . . . . . . . . . .555.5557.10.3
9. Women’s Outerwear and Girls’ Wear . . . . . . . . . . . . . . .418.9407.22.8
10. Men’s Clothing. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .619.5612.01.2
11. Men’s Furnishings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .558.7573.62.7
12. Boys’ Clothing and Furnishings . . . . . . . . . . . . . . . . . . .482.8489.81.4
13. Jewelry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1031.41040.30.9
14. Notions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .803.3795.21.0
15. Toilet Articles and Drugs. . . . . . . . . . . . . . . . . . . . . . . . .863.0895.93.8
16. Furniture and Bedding . . . . . . . . . . . . . . . . . . . . . . . . . . .665.6675.61.5
17. Floor Coverings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .563.1589.94.8
18. Housewares. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .798.9810.01.4
19. Major Appliances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .249.7247.11.0
20. Radio and Television . . . . . . . . . . . . . . . . . . . . . . . . . . . .81.777.25.5
21. Recreation and Education
2
. . . . . . . . . . . . . . . . . . . . . . . .114.3111.42.5
22. Home Improvements
2
. . . . . . . . . . . . . . . . . . . . . . . . . . . .121.7125.93.5
23. Auto Accessories
2
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .106.9107.00.1
Groups 1–15: Soft Goods . . . . . . . . . . . . . . . . . . . . . . . . . . . . .596.7596.80.0
Groups 16–20: Durable Goods . . . . . . . . . . . . . . . . . . . . . . . . .470.1469.00.2
Groups 21–23: Misc. Goods
2
. . . . . . . . . . . . . . . . . . . . . . . . . .114.0112.61.2
Store Total
3
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .553.2552.20.2
1
Absence of a minus sign before percentage change in this column signifies price increase.
2
Indexes on a January 1986=100 base.
3
The store total index covers all departments, including some not listed separately, except for the following: candy, foods,
liquor, tobacco, and contract departments.
5

DRAFTING INFORMATION
The principal author of this reve-
nue ruling is Stan Michaels of the
Office of Assistant Chief Counsel
(Income Tax and Accounting). For
further information regarding this
revenue ruling, contact Mr. Michaels
on (202) 622–4970 (not a toll-free
call).
6

Part III. Administrative, Procedural, and Miscellaneous
1997 Pension Plan Limitations
1
Notice 96–55
Section 415 of the Internal Revenue
Code provides for dollar limitations on
benefits and contributions under quali-
fied plans. Section 415 also requires that
the Commissioner annually adjust these
limits for cost-of-living increases. Other
limitations applicable to deferred com-
pensation plans are also affected by
these adjustments.
Effective January 1, 1997, the limita-
tion for the annual benefit under
§ 415(b)(1)(A) for defined benefit plans
is increased from $120,000 to $125,000.
For participants who separated from
service before January 1, 1997, the
limitation for defined benefit plans un-
der § 415(b)(1)(B) is computed by mul-
tiplying the participant’s compensation
limitation, as adjusted through 1996 by
1.0294. The limitation for defined con-
tribution plans under § 415(c)(1)(A) re-
mains unchanged at $30,000.
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)
is adjusted. These dollar amounts and
the adjusted amounts are as follows:
The special limitation for qualified
police or firefighters under § 415(b)(2)-
(G) is increased from $66,000 to
$70,000.
The limitation on the exclusion for
elective deferrals under § 402(g)(1) re-
mains unchanged at $9,500.
The dollar amount under § 409(o)(1)-
(C)(ii) for determining the maximum
account balance in an employee stock
ownership plan subject to a 5-year dis-
tribution period is increased from
$690,000 to $710,000, while the dollar
amount used to determine the lengthen-
ing of the 5-year distribution period is
increased from $135,000 to $140,000.
The threshold amount under
§ 4980A(c)(1)(B) regarding excess dis-
tributions is increased from $155,000 to
$160,000.
The limitation used in the definition
of highly compensated employee under
§ 414(q)(1)(B), as amended by the
Small Business Job Protection Act of
1996, is $80,000.
The annual compensation limit under
§§ 401(a)(17) and 404(l) is increased
from $150,000 to $160,000.
The compensation amount under
§ 408(k)(2)(C) regarding simplified em-
ployee pension plans (SEPs) remains
unchanged at $400. The compensa-
tion amount under § 408(k)(3)(C) for
SEPs is increased from $150,000 to
$160,000.
The compensation amount under
§ 408(p)(2)(A) regarding simple retire-
ment accounts, as added by § 1421 of
the Small Business Job Protection Act
of 1996, is $6,000.
The limitation on deferrals under
§ 457(b)(2) and (c)(1) concerning eli-
gible deferred compensation plans of
state and local governments and of
tax-exempt organizations remains un-
changed at $7,500.
Administrators of defined benefit or
defined contribution plans that have re-
ceived favorable determination letters
should not request new determination
letters solely because of yearly amend-
ments to adjust maximum limitations in
the plans.
Tables for Figuring Amount Exempt from Levy on Wages, Salary, and Other Income
Notice 96–56
1. Table for Figuring Amount Exempt from Levy on Wages, Salary, and Other Income (Forms 668–W, 668–W(c), &
668–W(c)(DO)) 1997
Publication 1494, shown below, provides tables which show the amount of an individual’s income that is exempt from a
notice of levy used to collect delinquent tax in 1997.
(Amounts are for each pay period.)
Filing Status: Single
Pay
Period
Number of Exemptions Claimed on Statement
123456More Than 6
Daily26.1536.3546.5456.7366.9277.1215.96 plus 10.19 for
each exemption
Weekly130.77181.73232.69283.65334.62385.5879.81 plus 50.96 for
each exemption
Biweekly261.54363.46465.38567.31669.23771.15159.62 plus 101.92 for
each exemption
Semi-
monthly
283.33393.75504.17614.58725.00835.42172.92 plus 110.42 for
each exemption
Monthly566.67787.501008.331229.171450.001670.83345.83 plus 220.83 for
each exemption
1
Based on News Release IR-96-43, dated October
24, 1996.
7

Filing Status: Unmarried Head of Household
Pay
Period
Number of Exemptions Claimed on Statement
123456More Than 6
Daily33.4643.6553.8564.0474.2384.4223.27 plus 10.19 for
each exemption
Weekly167.31218.27269.23320.19371.15422.12116.35 plus 50.96 for
each exemption
Biweekly334.62436.54538.46640.38742.31844.23232.69 plus 101.92 for
each exemption
Semi-
monthly
362.50472.92583.33693.75804.17914.58252.08 plus 110.42 for
each exemption
Monthly725.00945.831166.671387.501608.331829.17504.17 plus 220.83 for
each exemption
Filing Status: Married Filing Joint (and Qualifying Widow(er)s)
Pay
Period
Number of Exemptions Claimed on Statement
123456More Than 6
Daily36.7346.9257.1267.3177.5087.6926.54 plus 10.19 for
each exemption
Weekly183.65234.62285.58336.54387.50438.46132.69 plus 50.96 for
each exemption
Biweekly367.31469.23571.15673.08775.00876.92265.38 plus 101.92 for
each exemption
Semi-
monthly
397.92508.33618.75729.17839.58950.00287.50 plus 110.42 for
each exemption
Monthly795.831016.671237.501458.331679.171900.00575.00 plus 220.83 for
each exemption
Filing Status: Married Filing Separate
Pay
Period
Number of Exemptions Claimed on Statement
123456More Than 6
Daily23.4633.6543.8554.0464.2374.4213.27 plus 10.19 for
each exemption
Weekly117.31168.27219.23270.19321.15372.1266.35 plus 50.96 for
each exemption
Biweekly234.62336.54438.46540.38642.31744.23132.69 plus 101.92 for
each exemption
Semi-
monthly
254.17364.58475.00585.42695.83806.25143.75 plus 110.42 for
each exemption
Monthly508.33729.17950.001170.831391.671612.50287.50 plus 220.83 for
each exemption
8

2. Table for Figuring Additional Exempt Amount for Taxpayers at Least 65 Years Old and/or Blind
Additional Exempt Amount
Filing Status*DailyWklyBi-WklySemi-MthlyMonthly
Single or Head13.8519.2338.4641.6783.33
of Household27.6938.4676.9283.33166.67
Any Other13.0815.3830.7733.3366.67
Filing Status26.1530.7761.5466.67133.33
39.2346.1592.31100.00200.00
412.3161.54123.08133.33266.67
* ADDITIONAL STANDARD DEDUCTION claimed on Parts 3, 4, & 5 of levy.
Examples
These tables show the amount exempt from a levy on wages, salary, and other income. For example:
1. A single taxpayer who is paid weekly and claims three exemptions (including one for the taxpayer) has $232.69 exempt
from levy.
2. If the taxpayer in number 1 is over 65 and writes 1 in the ADDITIONAL STANDARD DEDUCTION space on Parts 3, 4,
& 5 of the levy, $251.92 is exempt from this levy ($232.69 plus $19.23).
3. A taxpayer who is married, files jointly, is paid bi-weekly, and claims two exemptions (including one for the taxpayer) has
$469.23 exempt from levy.
4. If the taxpayer in number 3 is over 65 and has a spouse who is blind, this taxpayer should write 2 in the ADDITIONAL
STANDARD DEDUCTION space on Parts 3, 4, & 5 of the levy. Then, $530.77 is exempt from this levy ($469.23 plus
$61.54).
Indian Tribal Casinos and Reporting
Under Title 31
Notice 96–57
This notice clarifies the reporting re-
quirements under the Internal Revenue
Code for cash transactions of more than
$10,000 from gaming activities for In-
dian tribal casinos with gross annual
gaming revenues in excess of $1 million
and with operations on Indian tribal
lands. Effective August 1, 1996, these
tribal casinos must comply with the
currency transaction reporting, record-
keeping, and compliance-program re-
quirements of the Bank Secrecy Act
(BSA), 31 U.S.C. §§ 5311–5330 (1994).
As a result, these tribal casinos are not
required to report certain transactions
under § 6050I of the Internal Revenue
Code.
Section 6050I(a) generally requires
any person who is engaged in a trade or
business and who, in the course of that
trade or business, receives cash in ex-
cess of $10,000 in one transaction (or
two or more related transactions) to file
an IRS Form 8300 (Report of Cash
Payments Over $10,000 Received in a
Trade or Business) with the Internal
Revenue Service. However, § 6050I(c)
(1) provides an exception from the re-
porting requirements of § 6050I(a) for
cash received in a transaction reported
under Title 31, if the Secretary deter-
mines that reporting under § 6050I
would be duplicative.
The BSA and the regulations under
Title 31 require certain financial institu-
tions to report the receipt (or disburse-
ment) of cash of more than $10,000
from certain transactions. See 31 U.S.C.
§ 5313 (1994) and 31 C.F.R.
§ 103.22(a)(2) (1996). Under § 5312(a)
(2)(x) of the BSA and 31 C.F.R.
§ 103.11(n)(7)(i) the term ‘‘financial in-
stitution’’ includes a casino that has
gross annual gaming revenues (as de-
scribed in 31 C.F.R. § 103.11(n)(7)(ii))
in excess of $1 million.
Effective August 1, 1996, 31 C.F.R.
§ 103.11(n)(7)(i) was amended to pro-
vide that the term ‘‘casino’’ means a
casino or gambling casino that is duly
licensed or authorized to do business as
such in the United States, whether under
the laws of a State or of a Territory or
Insular Possession of the United States,
or under the Indian Gaming Regulatory
Act or other federal, state, or tribal law
or arrangement affecting Indian lands
(including, without limitation, a casino
operating on the assumption or under
the view that no such authorization is
required for casino operation on Indian
lands), and that has gross annual gaming
revenue in excess of $1 million. 61 Fed.
Reg. 7055 (1996). This amendment is
intended to apply only to Class III
casinos.
Accordingly, effective August 1,
1996, any Class III Indian tribal casino
having gross annual gaming revenue in
excess of $1 million that engages in a
cash transaction of more than $10,000
(as defined in 31 C.F.R. § 103.22(a)(2))
with respect to gaming activities must
report that transaction under 31 U.S.C.
§ 5313 and the regulations thereunder
and satisfy applicable recordkeeping and
compliance-program requirements of 31
C.F.R. § 103. Such a casino is not also
required to report that transaction under
§ 6050I of the Code.
Section 6050I continues to apply,
however, to a transaction in which cash
of more than $10,000 is received by
such a casino from a nongaming busi-
ness activity (such as a shop, restaurant,
entertainment, or hotel). See 26 C.F.R.
§ 1.6050I–1(d)(2)(iii).
This notice does not affect the current
reporting requirements applicable to a
Class II gaming establishment.
DRAFTING INFORMATION
The principal author of this notice is
Renay France of the Office of Assistant
9

Chief Counsel (Income Tax and Ac-
counting). For further information on the
provisions in this notice concerning
§ 6050I, contact Ms. France at 202–
622–4940 (not a toll-free number). For
further information on the provisions in
the notice concerning Title 31, contact
Mr. Stephen Kroll at 703–905–3534 or
Mr. Peter Djinis at 703–905–3930 at the
Financial Crimes Enforcement Network
(not toll-free numbers).
26 CFR 601.202: Closing agreements.
Rev. Proc. 96–50
SECTION 1. PURPOSE
This revenue procedure modifies Rev.
Proc. 95–24, 1995–1 C.B. 694, concern-
ing the Tax Sheltered Annuity Voluntary
Correction (TVC) Program by extending
the last day for submissions under the
TVC Program.
SECTION 2. BACKGROUND
Effective May 1, 1995, the Internal
Revenue Service established the TVC
Program as an experimental program
that is available through October 31,
1996, for 403(b) plans that are not under
an Employee Plans or Exempt Organiza-
tions examination. The TVC Program
generally permits an eligible employer
to correct operational defects in the
employer’s 403(b) plan that are specifi-
cally described in Section 7 of Rev.
Proc. 95–24 and not excepted from
coverage under the program under Sec-
tion 5 of that revenue procedure. An
employer pays a voluntary correction
fee based on the number of its employ-
ees and a sanction with respect to the
corrected defects. Correction must be
made for all years of the defects. In
general, excise taxes are not waived
under the TVC Program, and the em-
ployer is still responsible for payment of
Federal Insurance Contributions Act
(FICA) taxes in appropriate circum-
stances. At the end of the TVC process,
the employer will receive a correction
statement setting forth the applicable
corrections and conditions.
SECTION 3. EXTENSION OF TVC
PROGRAM
Section 3.02 of Rev. Proc. 95–24
provides that the TVC Program will be
available through October 31, 1996. In
order to continue to evaluate the TVC
Program, it will continue to be available
through December 31, 1998.
SECTION 4. EXPANSION OF THE
PROGRAM
The Service has received comments
and inquiries regarding the expansion of
the TVC Program to permit the correc-
tion of defects not currently covered
under Rev. Proc. 95–24. The Service
will continue to consider these com-
ments and inquiries and may publish
additional guidance in the future.
SECTION 5. EFFECTIVE DATE
This revenue procedure is effective on
November 1, 1996.
SECTION 6. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 95–24 is modified.
DRAFTING INFORMATION
The principal author of this revenue
procedure is Roz Ferber of the Em-
ployee Plans Division. For more infor-
mation concerning this revenue proce-
dure, call the Employee Plans TVC
Telephone Number, (202) 622–6233 (not
a toll-free number) between the hours of
1:30 and 4:00 pm, Monday through
Thursday. Ms. Ferber may be reached at
(202) 622–6214 (also not a toll-free
number).
26 CFR 601.105: Examination of returns and
claims for refund, credit, or abatement; determina-
tion of correct tax liability.
(Also Part I, § 42; 1.42–14.)
Rev. Proc. 96–51
SECTION 1. PURPOSE
This revenue procedure supplements
Rev. Proc. 96–46, 1996–38 I.R.B. 144,
by publishing amounts of unused hous-
ing credit carryovers allocated to quali-
fied states under § 42(h)(3)(D) of the
Internal Revenue Code for calendar year
1996 in addition to those published in
Rev. Proc. 96–46. This revenue proce-
dure also publishes the total amounts of
unused housing credit carryovers allo-
cated to qualified states under
§ 42(h)(3)(D) for calendar year 1996.
SECTION 2. BACKGROUND
Rev. Proc. 96–46 published a portion
of the unused housing credit carryovers
allocated to qualified states from a na-
tional pool of unused credit authority for
calendar year 1996 (the 1996 National
Pool). Sec. 3.02 of Rev. Proc. 96–46
provides that upon resolution of certain
issues, qualified states may be entitled
to an additional allocation from the
1996 National Pool. These issues have
been resolved and qualified states are
entitled to an additional allocation from
the 1996 National Pool. This revenue
procedure publishes these additional al-
location amounts. Because there will be
no further allocations to qualified states
for the 1996 calendar year, this revenue
procedure also publishes the total
amounts of unused housing credit car-
ryovers allocated to qualified states from
the 1996 National Pool.
SECTION 3. PROCEDURE
.01 The additional amount of unused
housing credit carryover allocated to
each qualified state from the 1996 Na-
tional Pool, and the total amount of
unused housing credit carryover allo-
cated to each qualified state from the
1996 National Pool is as follows:
Qualified StateAdditional AmountTotal Amount
Alabama$ 10,322$ 127,753
Alaska1,48318,350
Arizona9,970123,392
California76,898951,741
Colorado8,945110,705
Connecticut8,01399,168
Florida34,137422,502
Hawaii2,88535,701
10

Qualified StateAdditional AmountTotal Amount
Idaho2,77234,308
Illinois28,752355,855
Indiana14,073174,173
Iowa6,92185,663
Kansas6,24977,336
Kentucky9,363115,883
Maine3,03437,548
Maryland12,248151,583
Massachusetts14,780182,924
Michigan23,233287,542
Minnesota11,173138,290
Mississippi6,53080,818
Missouri12,913159,820
Nebraska3,97149,145
Nevada3,56544,118
New Hampshire2,78234,429
New Jersey19,338239,336
New Mexico4,04750,084
New York44,452550,164
Ohio27,162336,172
Oregon7,55093,445
Pennsylvania29,486364,939
Rhode Island2,43930,190
South Dakota1,76421,832
Tennessee12,661156,701
Utah4,66857,775
Vermont1,41917,563
Virginia16,030198,397
Washington13,072161,788
Wisconsin12,433153,885
(Note: Amounts are rounded)
.02 Any additional amount of unused
housing credit carryover published in
this revenue procedure that a qualified
state fails to allocate before the close of
1996 will not be considered in determin-
ing whether that state qualifies for an
allocation of unused housing credit car-
ryover for calendar year 1997.
SECTION 4. EFFECT ON OTHER
REVENUE PROCEDURES
This revenue procedure supplements
Rev. Proc. 96–46 by increasing the
amounts of unused housing credit car-
ryovers allocated to qualified states from
the 1996 National Pool.
SECTION 5. EFFECTIVE DATE
This revenue procedure is effective
for allocations of housing credit dollar
amounts attributable to the National
Pool component of a qualified state’s
housing credit ceiling for calendar year
1996.
DRAFTING INFORMATION
The principal author of this revenue
procedure is Christopher J. Wilson of
the Office of Assistant Chief Counsel
(Passthroughs and Special Industries).
For further information regarding this
revenue procedure, contact Mr. Wilson
on (202) 622–3040 (not a toll-free
call).
11

Part IV. Items of General Interest
Foundations Status of Certain
Organizations
Announcement 96–120
The following organizations have
failed to establish or have been unable
to maintain their status as public chari-
ties or as operating foundations. Accord-
ingly, grantors and contributors may not,
after this date, rely on previous rulings
or designations in the Cumulative List
of Organizations (Publication 78), or on
the presumption arising from the filing
of notices under section 508(b) of the
Code. This listing doesnotindicate that
the organizations have lost their status
as organizations described in section
501(c)(3), eligible to receive deductible
contributions.
Former Public Charities. The follow-
ing organizations (which have been
treated as organizations that are not
private foundations described in section
509(a) of the Code) are now classified
as private foundations:
ABT Health Care Research Foundation,
Cambridge, MA
Adoptive Families Together AFT,
Houston, TX
Alternative Educational Environments,
Toledo, OH
Amputee Peer Services Inc., N. Little
Rock, AR
Anderson Urban League, Anderson, SC
Apalachicola Bay Oyster Farmers
Association Inc., Apalachicola, FL
Choice Alternative Care Service Inc.,
Greensboro, NC
Committee to Save the RKO Keiths
Theatre of Flushing, Inc., Flushing,
NY
Freeport Saving Lives, Inc., Freeport, IL
Georgia Association for Family Day
Care-Educational Fund, Smyrna, GA
Ichabod Ministries Incorporated,
Pittsfield, MA
Japanese Cultural Exchange, Inc., New
York, NY
Kentucky River Housing Corporation
Inc., Hazard, KY
Midwest Coalition for Affordable
Housing, Clinton Township, MI
New York State Shooting Sports
Foundation Inc., Huntington Sta, NY
Ocean Park Historical Society Inc.,
Ocean Park, ME
Putnam County Child Abuse Prevention
Council Inc., Greencastle, IN
Sachar-Saval Elijah Fund, Inc., Chestnut
Hill, MA
Trinity Building Corporation, Charlotte,
NC
Youth Incorporated, Anderson, IN
Youth Organized for Integrity and
Nuturing Citizenship Inc., Jackson,
MS
If an organization listed above sub-
mits information that warrants the re-
newal of its classification as a public
charity or as a private operating founda-
tion, the Internal Revenue Service will
issue a ruling or determination letter
with the revised classification as to
foundation status. Grantors and contribu-
tors may thereafter rely upon such rul-
ing or determination letter as provided
in section 1.509(a)–7 of the Income Tax
Regulations. It is not the practice of the
Service to announce such revised classi-
fication of foundation status in the Inter-
nal Revenue Bulletin.
Financial Asset Securitization
Investment Trusts (FASITs)
Announcement 96–121
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Solicitation for comments.
SUMMARY: The Treasury Department
and the IRS are soliciting comments on
issues to be considered in developing
guidance under the newly enacted
FASIT provisions of the Internal Rev-
enue Code.
DATES: Comments are requested on or
before December 31, 1996.
ADDRESSES: Send written comments
to: Internal Revenue Service, Attn:
CC:DOM:CORP:R (FASIT solicitation),
room 5226, POB 7604, Ben Franklin
Station, Washington, DC 20044. Alter-
natively, taxpayers may submit com-
ments in writing, by hand delivery to
CC:DOM:CORP:R (FASIT solicitation),
Courier’s Desk, Internal Revenue Ser-
vice, 1111 Constitution Ave., NW.,
Washington, D.C., or, electronically, via
the IRS Internet site at: http://
www.irs.ustreas.gov/prod/tax_regs/
comments.html.
FOR FURTHER INFORMATION CON-
TACT: David L. Meyer at 202–622–
3960 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
Section 1621(a) of the Small Business
Job Protection Act of 1996, Public Law
104–188, 110 Stat. 1755 (August 20,
1996), amends the Internal Revenue
Code (Code) by adding new part V
(sections 860H–860L) to subchapter M
of chapter 1. These provisions authorize
a new statutory vehicle, called a Finan-
cial Asset Securitization Investment
Trust (FASIT), that will facilitate the
securitization of debt obligations, includ-
ing credit card receivables and automo-
bile loans. In general, a FASIT will use
such obligations to issue new, debt-like
securities, referred to as regular inter-
ests. No Federal income tax is imposed
on a FASIT, even if the underlying
arrangement is otherwise regarded for
tax purposes as a corporation, trust,
partnership, or segregated pool of assets.
A FASIT must have a single owner-
ship interest, which has to be held
entirely by a non-exempt domestic C
corporation other than a corporation that
qualifies as a RIC, REIT, REMIC, or
subchapter T cooperative. Because a
FASIT is not subject to income tax, the
holder of the ownership interest gener-
ally includes in its taxable income all of
the FASIT’s items of income, gain,
deduction and loss. In addition, the
holder recognizes gain (but not loss)
when (1) the FASIT acquires property
from the holder or an unrelated third
party, or (2) the holder uses property to
support a regular interest issued by the
FASIT.
A FASIT may issue one or more
classes of regular interests. Regular in-
terests are treated as debt for all pur-
poses of the Code. Ordinarily, a regular
interest may be held by any person,
unless the interest is a high-yield inter-
est, in which case it may be held only
by another FASIT or a corporation that
is allowed to hold an ownership interest.
The FASIT provisions become effec-
tive on September 1, 1997. Special
transitional rules apply to a securitiza-
tion arrangement existing on August 31,
1997, that elects FASIT treatment (a
pre- effective date FASIT).
In addition to the general authority
under section 7805 to prescribe regula-
tions, the Treasury and IRS have spe-
cific authority under section 860L(h) to
issue regulations that carry out the pur-
poses of the FASIT provisions, includ-
121996–47 I.R.B.

ing rules to prevent the abuse of the
purposes of the FASIT provisions
through transactions that are not prima-
rily related to securitization of debt
instruments by a FASIT.
Comments
To develop needed guidance timely,
the Treasury Department and the IRS
invite interested persons to submit com-
ments (in the manner described under
theADDRESSEScaption) on issues
arising under the FASIT provisions.
Treasury and the IRS encourage respon-
dents to give particular attention to the
following: rules that would allow more
than one member of an affiliated group
to hold ownership interests in the same
FASIT; transitional rules for pre-
effective date FASITs; and any other
rules that should be in place before
September 1, 1997.
If a respondent is submitting written
comments, a signed original and eight
(8) copies are requested. All comments
will be available for public inspection
and copying in their entirety.
JUDITH C. DUNN,
Associate Chief Counsel (Domestic).
(Filed by the Office of the Federal Register on
November 1, 1996, 8:45 a.m., and published in the
issue of the Federal Register for November 4,
1996, 61 F.R. 56647)
Availability of Publication 938 on
the Internet and IRS Electronic
Bulletin Board (IRP-BBS) and
Conversion to a Quarterly
Publication
Announcement 96–122
The Service will not produce a
printed version of future updates of
Publication 938, Real Estate Mortgage
Investment Conduits (REMICs) Report-
ing Information (And Other Collateral-
ized Debt Obligations (CDOs)). The
1996 update and future quarterly up-
dates will be available only on the
Internet and the IRP-BBS. You can
download the publication from the IRP-
BBS if you have a computer with a
modem. Dial 1–304–264–7070 and fol-
low the instructions. (This is not a
toll-free call.) To download the publica-
tion from the Internet, connect to the
IRS Home Page at:
http://www.irs.ustreas.gov
The directory portion of Publication
938 will be updated each quarter. The
text portion will be updated only once
each year. The first update will contain
a directory based on the Forms 8811 the
Service receives from September 1
through December 31, 1996.
To order back issues (1991 through
1995) of the printed versions of Publica-
tion 938, call 1–800–TAX–FORM (1–
800–829–3676), or mail Form 6112,
Prior Years’ Tax Forms Order. Be sure
to specify which edition you want.
131996–47 I.R.B.

Announcement of the Disbarment, Suspension, or Consent to Voluntary
Suspension of Attorneys, Certified Public Accountants, Enrolled Agents, and
Enrolled Actuaries From Practice Before the Internal Revenue Service
Under 31 Code of Federal Regula-
tions, Part 10, an attorney, certified pub-
lic accountant, enrolled agent, or en-
rolled actuary, in order to avoid the
institution or conclusion of a proceeding
for his disbarment or suspension from
practice before the Internal Revenue Ser-
vice, may offer his consent to suspension
from such practice. The Director of
Practice, in his discretion, may suspend
an attorney, certified public accountant,
enrolled agent, or enrolled actuary in
accordance with the consent offered.
Attorneys, certified public accoun-
tants, enrolled agents, and enrolled actu-
aries are prohibited in any Internal Rev-
enue Service matter from directly or
indirectly employing, accepting assis-
tance from, being employed by or shar-
ing fees with, any practitioner disbarred
or suspended from practice before the
Internal Revenue Service.
To enable attorneys, certified public
accountants, enrolled agents, and en-
rolled actuaries to identify practitioners
under consent suspension from practice
before the Internal Revenue Service, the
Director of Practice will announce in the
Internal Revenue Bulletin the names and
addresses of practitioners who have
been suspended from such practice, their
designation as attorney, certified public
accountant, enrolled agent, or enrolled
actuary, and date or period of suspen-
sion. This announcement will appear in
the weekly Bulletin at the earliest practi-
cable date after such action and will
continue to appear in the weekly Bulle-
tins for five successive weeks or for as
many weeks as is practicable for each
attorney, certified public accountant, en-
rolled agent, or enrolled actuary so
suspended and will be consolidated and
published in the Cumulative Bulletin.
The following individuals have been
placed under consent suspension from
practice before the Internal Revenue
Service:
NameAddressDesignationDate of Suspension
Lamb, Gordon W.Pullman, WACPASeptember 1, 1996 to January 31, 1997
Anderson, Randall S.Arlington Hgts, ILCPASeptember 1, 1996 to February 28, 1998
Broderick, William J.Farmington Hills, MICPASeptember 1, 1996 to November 30, 1996
Ruggiero, John M.Rutland, VTAttorneySeptember 1, 1996 to October 31, 1996
Eklund, MarkPortland, ORCPASeptember 1, 1996 to February 28, 1997
Stayner, G. CraigSalt Lake City, UTCPASeptember 15, 1996 to June 14, 1997
Allen, Lehman D.Lubbock, TXCPASeptember 20, 1996 to September 19, 1998
Hardgrove, David L.Amarillo, TXCPASeptember 21, 1996 to June 20, 1997
Trader, John H.Kansas City, MOAttorneySeptember 30, 1996 to March 29, 1997
Schmertz, Carl D.Wilmette, ILCPAOctober 1, 1996 to March 31, 1999
Bengston, WesselChicago, ILCPAOctober 15, 1996 to April 14, 1997
14

Announcement of the Expedited Suspension of Attorneys, Certified Public
Accountants, Enrolled Agents, and Enrolled Actuaries From Practice Before The
Internal Revenue Service
Under title 31 of the Code of Federal
Regulations, section 10.76, the Director
of Practice is authorized to immediately
suspend from practice before the Internal
Revenue Service any practitioner who,
within five years, from the date the
expedited proceeding is instituted, (1)
has had a license to practice as an
attorney, certified public accountant, or
actuary suspended or revoked for cause;
or (2) has been convicted of any crime
under title 26 of the United States Code
or, of a felony under title 18 of the
United States Code involving dishonesty
or breach of trust.
Attorneys, certified public accoun-
tants, enrolled agents, and enrolled actu-
aries are prohibited in any Internal Rev-
enue Service matter from directly or
indirectly employing, accepting assis-
tance from, being employed by, or shar-
ing fees with, any practitioner disbarred
or suspended from practice before the
Internal Revenue Service.
To enable attorneys, certified public
accountants, enrolled agents, and en-
rolled actuaries to identify practitioners
under expedited suspension from prac-
tice before the Internal Revenue Service,
the Director of Practice will announce in
the Internal Revenue Bulletin the names
and addresses of practitioners who have
been suspended from such practice, their
designation as attorney, certified public
accountant, enrolled agent, or enrolled
actuary, and date or period of suspen-
sion. This announcement will appear in
the weekly Bulletin at the earliest practi-
cable date after such action and will
continue to appear in the weekly Bulle-
tins for five successive weeks or for as
many weeks as is practicable for each
attorney, certified public accountant, en-
rolled agent, or enrolled actuary so
suspended and will be consolidated and
published in the Cumulative Bulletin.
The following individuals have been
placed under suspension from practice
before the Internal Revenue Service by
virtue of the expedited proceeding pro-
visions of the applicable regulations:
NameAddressDesignationDate of Suspension
Alleva, DonaldMount Vernon, NYEnrolled AgentIndefinite from September 5, 1996
Rose, Robert M.Dallas, TXAttorneyIndefinite from September 5, 1996
McGrath, GregoryNew Smyrna Bch, FLCPAIndefinite from September 8, 1996
Finch, Kenneth L. Jr.Pelham, ALCPAIndefinite from September 8, 1996
15

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 de-
scribe the effect:
Amplifieddescribes a situation where
no change is being made in a prior
published position, but the prior position
is being extended to apply to a variation
of the fact situation set forth therein.
Thus, if an earlier ruling held that a
principle applied to A, and the new
ruling holds that the same principle also
applies to B, the earlier ruling is ampli-
fied. (Compare withmodified, 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 confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously
published ruling and points out an es-
sential 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 pub-
lished position. (Compare withamplified
andclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered de-
terminative with respect to future trans-
actions. This term is most commonly
used in a ruling that lists previously
published rulings that are obsoleted be-
cause of changes in law or regulations.
A ruling may also be obsoleted because
the substance has been included in regu-
lations subsequently adopted.
Revokeddescribes situations where
the position in the previously published
ruling is not correct and the correct
position is being stated in the new
ruling.
Supersededdescribes a situation
where the new ruling does nothing more
than restate the substance and situation
of a previously published ruling (or
rulings). Thus, the term is used to
republish under the 1986 Code and
regulations the same position published
under the 1939 Code and regulations.
The term is also used when it is desired
to republish in a single ruling a series of
situations, names, etc., that were previ-
ously published over a period of time in
separate rulings. If the new ruling does
more than restate the substance of a
prior ruling, a combination of terms is
used. For example,modifiedandsuper-
sededdescribes a situation where the
substance of a previously published rul-
ing is being changed in part and is
continued without change in part and it
is desired to restate the valid portion of
the previously published ruling in a new
ruling that is self contained. In this case
the previously published ruling is first
modified and then, as modified, is su-
perseded.
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 ruling has been supplemented
several times, a new ruling may be
published that includes the list in the
original ruling and the additions, and
supersedes all prior rulings in the series.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current use and
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 Contribution Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign Corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statements of 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.
16

Numerical Finding List
1
Bulletins 1996–27 through 1996–46
Announcements:
96–61, 1996–27 I.R.B.72
96–62, 1996–28 I.R.B.55
96–63, 1996–29 I.R.B.18
96–64, 1996–29 I.R.B.18
96–65, 1996–29 I.R.B.18
96–66, 1996–29 I.R.B.19
96–67, 1996–30 I.R.B.27
96–68, 1996–31 I.R.B.45
96–69, 1996–32 I.R.B.38
96–70, 1996–32 I.R.B.40
96–71, 1996–33 I.R.B.16
96–72, 1996–33 I.R.B.16
96–73, 1996–33 I.R.B.18
96–74, 1996–33 I.R.B.19
96–75, 1996–34 I.R.B.29
96–76, 1996–34 I.R.B.29
96–77, 1996–35 I.R.B.15
96–78, 1996–35 I.R.B.15
96–79, 1996–35 I.R.B.15
96–80, 1996–35 I.R.B.16
96–81, 1996–36 I.R.B.13
96–82, 1996–36 I.R.B.14
96–83, 1996–36 I.R.B.14
96–84, 1996–36 I.R.B.14
96–85, 1996–37 I.R.B.20
96–86, 1996–37 I.R.B.21
96–87, 1996–37 I.R.B.21
96–88, 1996–38 I.R.B.150
96–89, 1996–37 I.R.B.22
96–90, 1996–37 I.R.B.22
96–91, 1996–37 I.R.B.23
96–92, 1996–38 I.R.B.151
96–93, 1996–38 I.R.B.151
96–94, 1996–38 I.R.B.153
96–96, 1996–39 I.R.B.41
96–97, 1996–39 I.R.B.41
96–98, 1996–39 I.R.B.42
96–99, 1996–39 I.R.B.42
96–100, 1996–40 I.R.B.10
96–101, 1996–40 I.R.B.10
96–102, 1996–40 I.R.B.11
96–103, 1996–40 I.R.B.12
96–104, 1996–41 I.R.B.10
96–105, 1996–42 I.R.B.19
96–106, 1996–42 I.R.B.23
96–107, 1996–42 I.R.B.27
96–108, 1996–44 I.R.B.15
96–109, 1996–43 I.R.B.76
96–110, 1996–43 I.R.B.77
96–111, 1996–44 I.R.B.16
96–112, 1996–45 I.R.B.7
96–113, 1996–44 I.R.B.18
96–114, 1996–45 I.R.B.7
96–115, 1996–45 I.R.B.9
96–116, 1996–46 I.R.B.12
96–117, 1996–46 I.R.B.12
96–118, 1996–46 I.R.B.12
96–119, 1996–46 I.R.B.13
Court Decisions:
2058, 1996–34 I.R.B.13
2059, 1996–34 I.R.B.10
2060, 1996–34 I.R.B.5
Delegation Orders:
155 (Rev. 4), 1996–40 I.R.B.9
Notices:
96–36, 1996–27 I.R.B.11
96–37, 1996–31 I.R.B.29
96–38, 1996–31 I.R.B.29
96–39, 1996–32 I.R.B.8
96–40, 1996–33 I.R.B.11
96–41, 1996–35 I.R.B.6
96–42, 1996–35 I.R.B.6
96–43, 1996–36 I.R.B.7
96–44, 1996–36 I.R.B.7
96–45, 1996–39 I.R.B.7
96–46, 1996–39 I.R.B.7
96–47, 1996–39 I.R.B.8
96–48, 1996–39 I.R.B.8
96–49, 1996–41 I.R.B.6
96–50, 1996–41 I.R.B.6
96–51, 1996–42 I.R.B.6
96–52, 1996–42 I.R.B. 8
96–54, 1996–44 I.R.B.13
Proposed Regulations:
CO–9–96, 1996–34 I.R.B.20
CO–24–96, 1996–30 I.R.B.22
CO–25–96, 1996–31 I.R.B.30
CO–26–96, 1996–31 I.R.B.31
FI–59–94, 1996–30 I.R.B.23
FI–32–95, 1996–34 I.R.B.21
FI–48–95, 1996–31 I.R.B.36
FI–28–96, 1996–31, I.R.B.33
GL–7–96, 1996–33 I.R.B.13
IA–292–84, 1996–28 I.R.B.38
IA–26–94, 1996–30 I.R.B.24
IA–29–96, 1996–33 I.R.B.14
INTL–4–95, 1996–36 I.R.B.8
PS–39–93, 1996–34 I.R.B.27
PS–22–96, 1996–33 I.R.B.15
REG–208215–91, 1996–38 I.R.B.145
REG–209803–95, 1996–44 I.R.B.14
REG–209826–96, 1996–42 I.R.B.10
REG–209827–96, 1996–37 I.R.B.19
REG–245562–96, 1996–41 I.R.B.8
Public Laws:
104–117, 1996–34 I.R.B.19
104–134, 1996–38 I.R.B.7
104–168, 1996–38 I.R.B.8
104–191, 1996–43 I.R.B.7
104–193, 1996–46 I.R.B.4
Railroad Retirement Quarterly Rate
1996–29 I.R.B.14
Revenue Procedures:
96–36, 1996–27 I.R.B.11
96–37, 1996–29 I.R.B.16
96–39, 1996–33 I.R.B.11
96–40, 1996–32 I.R.B.8
96–41, 1996–32 I.R.B.9
96–42, 1996–32 I.R.B.14
96–43, 1996–35 I.R.B.6
96–44, 1996–35 I.R.B.7
96–45, 1996–35 I.R.B.12
96–46, 1996–38 I.R.B.144
96–47, 1996–39 I.R.B.10
Revenue Procedures—Continued
96–48, 1996–39 I.R.B.10
96–49, 1996–43 I.R.B.74
Revenue Rulings:
96–33, 1996–27 I.R.B.4
96–34, 1996–28 I.R.B.4
96–35, 1996–31 I.R.B.4
96–36, 1996–30 I.R.B.6
96–37, 1996–32 I.R.B.4
96–38, 1996–33 I.R.B.4
96–39, 1996–34 I.R.B.4
96–41, 1996–45 I.R.B.4
96–42, 1996–35 I.R.B.4
96–43, 1996–36 I.R.B.4
96–44, 1996–38 I.R.B.4
96–45, 1996–39 I.R.B.5
96–46, 1996–39 I.R.B.5
96–47, 1996–40 I.R.B.7
96–48, 1996–40 I.R.B.4
96–49, 1996–41 I.R.B.4
96–50, 1996–42 I.R.B.4
96–51, 1996–43 I.R.B.5
96–52, 1996–45 I.R.B.5
Tax Conventions:
1996–28 I.R.B. 36
1996–36 I.R.B.6
1996–40 I.R.B.8
Treasury Decisions:
8673, 1996–27 I.R.B.4
8674, 1996–28 I.R.B.7
8675, 1996–29 I.R.B.5
8676, 1996–30 I.R.B.4
8677, 1996–30 I.R.B.7
8678, 1996–31 I.R.B.11
8679, 1996–31 I.R.B.4
8680, 1996–33 I.R.B.5
8681, 1996–37 I.R.B.17
8682, 1996–37 I.R.B.4
8683, 1996–44 I.R.B.9
8684, 1996–44 I.R.B.4
1
A cumulative list of all Revenue Rulings, Rev-
enue Procedures, Treasury Decisions, etc., pub-
lished in Internal Revenue Bulletins 1996–1
through 1996–26 will be found in Internal Rev-
enue Bulletin 1996–27, dated July 1, 1996.
17

Finding List of Current Action on
Previously Published Items
1
Bulletins 1996–27 through 1996–46
*Denotes entry since last publication
Revenue Procedures:
80–27
Modified by
96–40, 1996–32 I.R.B.8
87–32
Modified by
TD 8680, 1996–33 I.R.B.5
92–20
Modified by
TD 8680, 1996–33 I.R.B.5
95–16
Superseded by
96–48, 1996–39 I.R.B.10
95–29
Superseded by
96–36, 1996–27 I.R.B.11
95–29A
Superseded by
96–36, 1996–27 I.R.B.11
95–30
Superseded by
96–42, 1996–32 I.R.B.14
95–46
Superseded by
96–48, 1996–39 I.R.B.10
96–41
Modified by
Notice 96–49, 1996–41 I.R.B.6
1
A cumulative finding list for previously published
items mentioned in Internal Revenue Bulletins
1996–1 through 1996–26 will be found in Internal
Revenue Bulletin 1996–27, dated July 1, 1996.
18