Internal Revenue Bulletin 2000-25 (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. 2000–30, page 1262.
Interest rates; underpayments and overpayments.The
rate of interest determined under section 6621 of the Code
for the calendar quarter beginning July 1, 2000, will be 9
percent for overpayments (8 percent in the case of a corpo-
ration), 9 percent for underpayments, and 11 percent for
large corporate underpayments. The rate of interest paid on
the portion of a corporate overpayment exceeding $10,000
is 6.5 percent.
T.D. 8885, page 1260.
Final regulations under section 368(a)(1)(C) of the Code re-
late to the solely for voting stock requirement in certain cor-
porate reorganizations. Rev. Rul. 54–396 obsoleted.
Notice 2000–30, page 1266.
Individual Retirement Arrangements (IRAs); reporting
requirements.This notice provides guidance relating to the
completion of Forms 1099-R and 5498 to report IRA rechar-
acterizations and reconversions occurring after 2000. Pub-
lic comments are requested. Notice 98–49 modified.
ADMINISTRATIVE
Announcement 2000–55, page 1268.
Submission of tax shelter information. This announce-
ment provides the mailing address, telephone number, fax
number, and e-mail address for persons who wish to submit
information to the Office of Tax Shelter Analysis.
Internal Revenue
bbuulllleettiinn
Bulletin No. 2000–25
June 19, 2000
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
Department of the Treasury
Internal Revenue Service
Finding Lists begin on page ii.

June 19, 20002000–25 I.R.B.
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing offi-
cial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
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stantive rulings necessary to promote a uniform application
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wise indicated. Procedures relating solely to matters of in-
ternal management are not published; however, statements
of internal practices and procedures that affect the rights
and duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the
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clusions in other cases unless the facts and circumstances
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The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal Revenue Code of 1986.
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This part is divided into two subparts as follows: Subpart A,
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To the extent practicable, pertinent cross references to
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Provide America’s taxpayers top quality service by help-
ing them understand and meet their tax responsibilities
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Introduction
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402.

Section 368.—Definitions
Relating to Corporate
Reorganizations
26 CFR 1.368–2: Definition of terms.
T.D. 8885
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
The Solely for Voting Stock
Requirement in Certain
Corporate Reorganizations
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulation.
SUMMARY: This document contains
final regulations relating to the solely for
voting stock requirement in certain corpo-
rate reorganizations under section
368(a)(1)(C). The final regulations pro-
vide that a prior acquisition of a target
corporation’s stock by an acquiring cor-
poration generally will not prevent the
solely for voting stock requirement in a
“C” reorganization of the target corpora-
tion and the acquiring corporation from
being satisfied. They affect persons en-
gaging in certain transactions occurring
after December 31, 1999.
DATES: Effective Date: These regula-
tions are effective May 19, 2000.
Applicability Date: These regulations
apply to transactions occurring after De-
cember 31, 1999, unless the transaction
occurs pursuant to a written agreement
that is (subject to customary conditions)
binding on that date and at all times there-
after.
FOR FURTHER INFORMATION CON-
TACT: Marnie Rapaport, (202) 622-7550
(not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
On June 14, 1999, the IRS and Treasury
issued a notice of proposed rulemaking in
the Federal Register (REG–115086–98,
1999–26 I.R.B. 6 [64 F.R. 31770]) setting
forth rules relating to the solely for voting
stock requirement in reorganizations under
section 368(a)(1)(C). The proposed regu-
lations provided that prior ownership of
stock of a target corporation by an acquir-
ing corporation will not by itself prevent
the solely for voting stock requirement of a
“C” reorganization from being satisfied.
The regulations propose to reverse the
IRS’s previous position that the acquisition
of assets of a partially controlled sub-
sidiary does not qualify as a tax-free “C”
reorganization. See Rev. Rul. 54–396
(1954–2 C.B. 147). This position subse-
quently was sustained in litigation in
Bausch & Lomb Optical Co. v. Commis-
sioner, 267 F.2d 75 (2d Cir.), cert. denied,
361 U.S. 835 (1959) (the Bausch & Lomb
doctrine). A public hearing regarding
these proposed regulations was held on
October 5, 1999. Written comments to the
notice were received. After consideration
of all the comments, the proposed regula-
tions are adopted as revised by this Trea-
sury decision.
Explanation of Revisions and Summary
of Comments
The Applicability Date
The proposed regulations apply to
transactions occurring after the date that a
Treasury decision adopting the regula-
tions is published in the Federal Register,
except that they do not apply to any trans-
actions occurring pursuant to a written
agreement which is (subject to customary
conditions) binding on the date that the
regulations are published as final regula-
tions in the Federal Register, and at all
times thereafter.
A commentator requested that taxpay-
ers be allowed to apply the proposed reg-
ulations to transactions occurring before
the proposed regulations are published as
final regulations.
The IRS and Treasury Department de-
termined that the increased flexibility that
results from the proposed regulations
should be available to taxpayers in struc-
turing transactions before their publication
as final regulations. Accordingly, the IRS
and the Treasury Department issued No-
tice 2000–1 (2000–2 I.R.B. 288), which
changes the proposed effective date of the
proposed regulations to apply to any trans-
actions occurring after December 31,
1999, unless the transaction occurs pur-
suant to a written agreement binding on
that date. Notice 2000–1 further provides
that the proposed regulations, when final-
ized, will adopt this effective date rule and
that taxpayers may rely on Notice 2000–1
until final regulations are issued. Accord-
ingly, the final regulations adopt this ef-
fective date rule.
Finally, Notice 2000–1 provides that
taxpayers may request a private letter rul-
ing permitting them to apply the final reg-
ulations to transactions occurring on or
after June 11, 1999 (the date the proposed
regulations were filed with the Federal
Register) to which the final regulations
would not otherwise apply, and for which
there was not a written agreement (subject
to customary conditions) binding on June
11, 1999 and at all times thereafter. The
Notice cautions, however, that a private
letter ruling will not be issued unless the
taxpayer establishes to the satisfaction of
the IRS that there is not a significant risk
of different parties to the transaction tak-
ing inconsistent positions, for U.S. tax
purposes, with respect to the applicability
of the final regulations to the transaction.
Any such requests for a ruling will con-
tinue to be considered.
Extension of the Repeal of the Bausch &
LombDoctrine to “B” Reorganizations
A comment was received requesting that
the IRS reconsider its position in Rev. Rul.
69–294 (1969–1 C.B. 110), where the
Bausch & Lombdoctrine was applied to
disqualify a purported section 368(a)(1)(B)
reorganization that followed a tax-free sec-
tion 332 liquidation. In Rev. Rul. 69–294,
X owned all of the stock of Y and Y owned
80 percent of the stock of Z. Y com-
pletely liquidated into X in a section 332
liquidation. As part of the plan, X (now
owning 80 percent of the stock of Z) ac-
quired the minority 20 percent stock inter-
est in Z in exchange for X voting stock in
a purported “B” reorganization. The rul-
ing holds that the exchange with the 20
percent minority shareholders was not a
“B” reorganization. The rationale is that
although the acquisition from the minor-
ity shareholders was “solely for voting
stock,” the liquidation of Y, as part of the
same plan, resulted in X acquiring 80 per-
cent of the Z stock in exchange for Y
stock surrendered back to Y on the liqui-
June 19, 200012602000–25 I.R.B.
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

dation of Y and not solely in exchange for
X voting stock.
The commentator’s suggestion is be-
yond the scope of this regulations project,
which relates to “C” reorganizations. In
light of these regulations, the IRS and
Treasury Department may reconsider
Rev. Rul. 69–294.
Effect on Other Documents
The following publication is obsolete
as of January 1, 2000: Rev. Rul. 54–396
(1954–2 C.B. 147).
Special Analyses
It has been determined that this Trea-
sury decision is not a significant regula-
tory action as defined in Executive Order
12866. Therefore, a regulatory assess-
ment is not required. It also has been de-
termined that section 553(b) of the Ad-
ministrative Procedure Act (5 U.S.C.
chapter 5) does not apply to these regula-
tions and, because these regulations do
not impose a collection of information on
small entities, the Regulatory Flexibility
Act (5 U.S.C. chapter 6) does not apply.
Therefore, a Regulatory Flexibility
Analysis is not required. Pursuant to sec-
tion 7805(f) of the Internal Revenue
Code, these regulations were submitted to
the Chief Counsel for Advocacy of the
Small Business Administration for com-
ment on its impact on small business.
Drafting Information
The principal author of these regula-
tions is Marnie Rapaport of the Office of
the Assistant Chief Counsel (Corporate),
IRS. However, other personnel from the
IRS and Treasury Department partici-
pated in their development.
* * * * *
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR part 1 is amended
as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 continues to
read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 1.368–2 is amended by
adding paragraph (d)(4) to read as follows:
§1.368–2 Definition of terms.
* * * * *
(d) * * *
(4) (i) For purposes of paragraphs
(d)(1) and (2)(ii) of this section, prior
ownership of stock of the target corpora-
tion by an acquiring corporation will not
by itself prevent the solely for voting
stock requirement of such paragraphs
from being satisfied. In a transaction in
which the acquiring corporation has prior
ownership of stock of the target corpora-
tion, the requirement of paragraph
(d)(2)(ii) of this section is satisfied only if
the sum of the money or other property
that is distributed in pursuance of the plan
of reorganization to the shareholders of
the target corporation other than the ac-
quiring corporation and to the creditors of
the target corporation pursuant to section
361(b)(3), and all of the liabilities of the
target corporation assumed by the acquir-
ing corporation (including liabilities to
which the properties of the target corpora-
tion are subject), does not exceed 20 per-
cent of the value of all of the properties of
the target corporation. If, in connection
with a potential acquisition by an acquir-
ing corporation of substantially all of a
target corporation’s properties, the ac-
quiring corporation acquires the target
corporation’s stock for consideration
other than the acquiring corporation’s
own voting stock (or voting stock of a
corporation in control of the acquiring
corporation if such stock is used in the ac-
quisition of the target corporation’s prop-
erties), whether from a shareholder of the
target corporation or the target corpora-
tion itself, such consideration is treated,
for purposes of paragraphs (d)(1) and (2)
of this section, as money or other property
exchanged by the acquiring corporation
for the target corporation’s properties.
Accordingly, the transaction will not
qualify under section 368(a)(1)(C) unless,
treating such consideration as money or
other property, the requirements of sec-
tion 368(a)(2)(B) and paragraph (d)(2)(ii)
of this section are met. The determination
of whether there has been an acquisition
in connection with a potential reorganiza-
tion under section 368(a)(1)(C) of a target
corporation’s stock for consideration
other than an acquiring corporation’s own
voting stock (or voting stock of a corpora-
tion in control of the acquiring corpora-
tion if such stock is used in the acquisition
of the target corporation’s properties) will
be made on the basis of all of the facts
and circumstances.
(ii) The following examples illustrate
the principles of this paragraph (d)(4):
Example 1. Corporation P (P) holds 60 percent
of the Corporation T (T) stock that P purchased sev-
eral years ago in an unrelated transaction. T has 100
shares of stock outstanding. The other 40 percent of
the T stock is owned by Corporation X (X), an unre-
lated corporation. T has properties with a fair mar-
ket value of $110 and liabilities of $10. T transfers
all of its properties to P. In exchange, P assumes the
$10 of liabilities, and transfers to T $30 of P voting
stock and $10 of cash. T distributes the P voting
stock and $10 of cash to X and liquidates. The
transaction satisfies the solely for voting stock re-
quirement of paragraph (d)(2)(ii) of this section be-
cause the sum of $10 of cash paid to X and the as-
sumption by P of $10 of liabilities does not exceed
20% of the value of the properties of T.
Example 2. The facts are the same as in Example
1except that P purchased the 60 shares of T for $60
in cash in connection with the acquisition of T’s as-
sets. The transaction does not satisfy the solely for
voting stock requirement of paragraph (d)(2)(ii) of
this section because P is treated as having acquired
all of the T assets for consideration consisting of $70
of cash, $10 of liability assumption and $30 of P
voting stock, and the sum of $70 of cash and the as-
sumption by P of $10 of liabilities exceeds 20% of
the value of the properties of T.
(iii) This paragraph (d)(4) applies to
transactions occurring after December 31,
1999, unless the transaction occurs pur-
suant to a written agreement that is (sub-
ject to customary conditions) binding on
that date and at all times thereafter.
* * * * *
David A. Mader,
Acting Deputy Commissioner
of Internal Revenue.
Approved May 9, 2000.
Jonathan Talisman,
Deputy Assistant Secretary
of the Treasury.
(Filed by the Office of the Federal Register on May
18, 2000, 8:45 a.m., and published in the issue of the
Federal Register for May 19, 2000, 65 F.R. 31805)
Section 6621.— Determination
of Interest Rate
26 CFR 301.6621–1: Interest rate.
Interest rates; underpayments and
overpayments.The rate of interest deter-
mined under section 6621 of the Code for
the calendar quarter beginning July 1,
2000, will be 9 percent for overpayments
(8 percent in the case of a corporation), 9
2000–25 I.R.B.1261June 19, 2000

percent for underpayments, and 11 per-
cent for large corporate underpayments.
The rate of interest paid on the portion of
a corporate overpayment exceeding
$10,000 is 6.5 percent.
Rev. Rul. 2000–30
Section 6621 of the Internal Revenue
Code establishes the rates for interest on
tax overpayments and tax underpayments.
Under § 6621(a)(1), the overpayment rate
beginning July 1, 2000, is the sum of the
federal short-term rate plus 3 percentage
points (2 percentage points in the case of
a corporation), except the rate for the por-
tion of a corporate overpayment of tax ex-
ceeding $10,000 for a taxable period is
the sum of the federal short-term rate plus
0.5 of a percentage point for interest com-
putations made after December 31, 1994.
Under § 6621(a)(2), the underpayment
rate is the sum of the federal short-term
rate plus 3 percentage points.
Section 6621(c) provides that for pur-
poses of interest payable under § 6601 on
any large corporate underpayment, the un-
derpayment rate under § 6621(a)(2) is de-
termined by substituting “5 percentage
points” for “3 percentage points.” See
§ 6621(c) and § 301.6621–3 of the Regu-
lations on Procedure and Administration
for the definition of a large corporate un-
derpayment and for the rules for determin-
ing the applicable date. Section 6621(c)
and § 301.6621–3 are generally effective
for periods after December 31, 1990.
Section 6621(b)(1) provides that the
Secretary will determine the federal short-
term rate for the first month in each calen-
dar quarter.
Section 6621(b)(2)(A) provides that the
federal short-term rate determined under
§ 6621(b)(1) for any month applies during
the first calendar quarter beginning after
such month.
Section 6621(b)(3) provides that the
federal short-term rate for any month is
the federal short-term rate determined
during such month by the Secretary in ac-
cordance with § 1274(d), rounded to the
nearest full percent (or, if a multiple of
1/2 of 1 percent, the rate is increased to
the next highest full percent).
Notice 88–59, 1988–1 C.B. 546, an-
nounced that, in determining the quarterly
interest rates to be used for overpayments
and underpayments of tax under § 6621,
the Internal Revenue Service will use the
federal short-term rate based on daily
compounding because that rate is most
consistent with § 6621 which, pursuant to
§ 6622, is subject to daily compounding.
Rounded to the nearest full percent, the
federal short-term rate based on daily
compounding determined during the
month of April 2000 is 6 percent. Accord-
ingly, an overpayment rate of 9 percent (8
percent in the case of a corporation) and
an underpayment rate of 9 percent are es-
tablished for the calendar quarter begin-
ning July 1, 2000. The overpayment rate
for the portion of a corporate overpayment
exceeding $10,000 for the calendar quar-
ter beginning July 1, 2000, is 6.5 percent.
The underpayment rate for large corporate
underpayments for the calendar quarter
beginning July 1, 2000, is 11 percent.
These rates apply to amounts bearing in-
terest during that calendar quarter.
Interest factors for daily compound in-
terest for annual rates of 6.5 percent, 8
percent, 9 percent, and 11 percent are
published in Tables 66, 69, 71, and 75 of
Rev. Proc. 95–17, 1995–1 C.B. 556, 620,
623, 625, and 629.
Annual interest rates to be compounded
daily pursuant to § 6622 that apply for
prior periods are set forth in the tables ac-
companying this revenue ruling.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Raymond Bailey of the Office of
Assistant Chief Counsel (Income Tax and
Accounting). For further information re-
garding this revenue ruling, contact Mr.
Bailey on (202) 622-6226 (not a toll-free
call).
June 19, 200012622000–25 I.R.B.
TABLE OF INTEREST RATES
PERIODS BEFORE JUL. 1, 1975 - PERIODS ENDING DEC. 31, 1986
OVERPAYMENTS AND UNDERPAYMENTS
In 1995–1 C.B.
PERIODRATEDAILY RATE TABLE
Before Jul. 1, 19756%Table 2, pg. 557
Jul. 1, 1975—Jan. 31, 19769%Table 4, pg. 559
Feb. 1, 1976—Jan. 31, 19787%Table 3, pg. 558
Feb. 1, 1978—Jan. 31, 19806%Table 2, pg. 557
Feb. 1, 1980—Jan. 31, 198212%Table 5, pg. 560
Feb. 1, 1982—Dec. 31, 198220%Table 6, pg. 560
Jan. 1, 1983—Jun. 30, 198316%Table 37, pg. 591
Jul. 1, 1983—Dec. 31, 198311%Table 27, pg. 581
Jan. 1, 1984—Jun. 30, 198411%Table 75, pg. 629
Jul. 1, 1984—Dec. 31, 198411%Table 75, pg. 629
Jan. 1, 1985—Jun. 30, 198513%Table 31, pg. 585
Jul. 1, 1985—Dec. 31, 198511%Table 27, pg. 581
Jan. 1, 1986—Jun. 30, 198610%Table 25 pg. 579
Jul. 1, 1986—Dec. 31, 19869%Table 23, pg. 577

TABLE OF INTEREST RATES
FROM JAN. 1, 1987 - Dec. 31, 1998
OVERPAYMENTSUNDERPAYMENTS
1995–1 C.B.1995–1 C.B.
RATETABLEPGRATETABLEPG
Jan. 1, 1987—Mar. 31, 19878%215759%23577
Apr. 1, 1987—Jun. 30, 19878%215759%23577
Jul. 1, 1987—Sep. 30, 19878%215759%23577
Oct. 1, 1987—Dec. 31, 19879%2357710%25579
Jan. 1, 1988—Mar. 31, 198810%7362711%75629
Apr. 1, 1988—Jun. 30, 19889%7162510%73627
Jul. 1, 1988—Sep. 30, 19889%7162510%73627
Oct. 1, 1988—Dec. 31, 198810%7362711%75629
Jan. 1, 1989—Mar. 31, 198910%2557911%27581
Apr. 1, 1989—Jun. 30, 198911%2758112%29583
Jul. 1, 1989—Sep. 30, 198911%2758112%29583
Oct. 1, 1989—Dec. 31, 198910%2557911%27581
Jan. 1, 1990—Mar. 31, 199010%2557911%27581
Apr. 1, 1990—Jun. 30, 199010%2557911%27581
Jul. 1, 1990—Sep. 30, 199010%2557911%27581
Oct. 1, 1990—Dec. 31, 199010%2557911%27581
Jan. 1, 1991—Mar. 31, 199110%2557911%27581
Apr. 1, 1991—Jun. 30, 19919%2357710%25579
Jul. 1, 1991—Sep. 30, 19919%2357710%25579
Oct. 1, 1991—Dec. 31, 19919%2357710%25579
Jan. 1, 1992—Mar. 31, 19928%696239%71625
Apr. 1, 1992—Jun. 30, 19927%676218%69623
Jul. 1, 1992—Sep. 30, 19927%676218%69623
Oct. 1, 1992—Dec. 31, 19926%656197%67621
Jan. 1, 1993—Mar. 31, 19936%175717%19573
Apr. 1, 1993—Jun. 30, 19936%175717%19573
Jul. 1, 1993—Sep. 30, 19936%175717%19573
Oct. 1, 1993—Dec. 31, 19936%175717%19573
Jan. 1, 1994—Mar. 31, 19946%175717%19573
Apr. 1, 1994—Jun. 30, 19946%175717%19573
Jul. 1, 1994—Sep. 30, 19947%195738%21575
Oct. 1, 1994—Dec. 31, 19948%215759%23577
Jan. 1, 1995—Mar. 31, 19958%215759%23577
Apr. 1, 1995—Jun. 30, 19959%2357710%25579
Jul. 1, 1995—Sep. 30, 19958%215759%23577
Oct. 1, 1995—Dec. 31, 19958%215759%23577
Jan. 1, 1996—Mar. 31, 19968%696239%71625
Apr. 1, 1996—Jun. 30, 19967%676218%69623
Jul. 1, 1996—Sep. 30, 19968%696239%71625
Oct. 1, 1996—Dec. 31, 19968%696239%71625
Jan. 1, 1997—Mar. 31, 19978%215759%23577
Apr. 1, 1997—Jun. 30, 19978%215759%23577
Jul. 1, 1997—Sep. 30, 19978%215759%23577
Oct. 1, 1997—Dec. 31, 19978%215759%23577
Jan. 1, 1998—Mar. 31, 19988%215759%23577
Apr. 1, 1998—Jun. 30, 19987%195738%21575
Jul. 1, 1998—Sep. 30, 19987%195738%21575
Oct. 1, 1998—Dec. 31, 19987%195738%21575
2000–25 I.R.B.1263June 19, 2000

TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 - PRESENT
NONCORPORATE OVERPAYMENTS AND UNDERPAYMENTS
1995–1 C.B.
RATETABLEPAGE
Jan. 1, 1999—Mar. 31, 19997%19573
Apr. 1, 1999—Jun. 30, 19998%21575
Jul. 1, 1999—Sep. 30, 19998%21575
Oct. 1, 1999—Dec. 31, 19998%21575
Jan. 1, 2000—Mar. 31, 20008%69623
Apr. 1, 2000—Jun. 30, 20009%71625
Jul. 1, 2000—Sep. 30, 20009%71625
June 19, 200012642000–25 I.R.B.
TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 - PRESENT
CORPORATE OVERPAYMENTS AND UNDERPAYMENTS
OVERPAYMENTSUNDERPAYMENTS
1995–1 C.B.1995–1 C.B.
RATETABLEPGRATETABLEPG
Jan. 1, 1999—Mar. 31, 19996%175717%19573
Apr. 1, 1999—Jun. 30, 19997%195738%21575
Jul. 1, 1999—Sep. 30, 19997%195738%21575
Oct. 1, 1999—Dec. 31, 19997%195738%21575
Jan. 1, 2000—Mar. 31, 20007%676218%69623
Apr. 1, 2000—Jun. 30, 20008%696239%71625
Jul. 1, 2000—Sep. 30, 20008%696239%71625
TABLE OF INTEREST RATES FOR
LARGE CORPORATE UNDERPAYMENTS
FROM JANUARY 1, 1991 - PRESENT
1995–1 C.B.
RATETABLEPG
Jan. 1, 1991—Mar. 31, 199113%31585
Apr. 1, 1991—Jun. 30, 199112%29583
Jul. 1, 1991—Sep. 30, 199112%29583
Oct. 1, 1991—Dec. 31, 199112%29583
Jan. 1, 1992—Mar. 31, 199211%75629
Apr. 1, 1992—Jun. 30, 199210%73627
Jul. 1, 1992—Sep. 30, 199210%73627
Oct. 1, 1992—Dec. 31, 19929%71625
Jan. 1, 1993—Mar. 31, 19939%23577
Apr. 1, 1993—Jun. 30, 19939%23577
Jul. 1, 1993—Sep. 30, 19939%23577
Oct. 1, 1993—Dec. 31, 19939%23577
Jan. 1, 1994—Mar. 31, 19949%23577

Apr. 1, 1994—Jun. 30, 19949%23577
Jul. 1, 1994—Sep. 30, 199410%25579
Oct. 1, 1994—Dec. 31, 199411%27581
Jan. 1, 1995—Mar. 31, 199511%27581
Apr. 1, 1995—Jun. 30, 199512%29583
Jul. 1, 1995—Sep. 30, 199511%27581
Oct. 1, 1995—Dec. 31, 199511%27581
Jan. 1, 1996—Mar. 31, 199611%75629
Apr. 1, 1996—Jun. 30, 199610%73627
Jul. 1, 1996—Sep. 30, 199611%75629
Oct. 1, 1996—Dec. 31, 199611%75629
Jan. 1, 1997—Mar. 31, 199711%27581
Apr. 1, 1997—Jun. 30, 199711%27581
Jul. 1, 1997—Sep. 30, 199711%27581
Oct. 1, 1997—Dec. 31, 199711%27581
Jan. 1, 1998—Mar. 31, 199811%27581
Apr. 1, 1998—Jun. 30, 199810%25579
Jul. 1, 1998—Sep. 30, 199810%25579
Oct. 1, 1998—Dec. 31, 199810%25579
Jan. 1, 1999—Mar. 31, 19999%23577
Apr. 1, 1999—Jun. 30, 199910%25579
Jul. 1, 1999—Sep. 30, 199910%25579
Oct. 1, 1999—Dec. 31, 199910%25579
Jan. 1, 2000—Mar. 31, 200010%73627
Apr. 1, 2000—Jun. 30, 200011%75629
Jul. 1, 2000—Sep. 30, 200011%75629
2000–25 I.R.B.1265June 19, 2000
TABLE OF INTEREST RATES FOR CORPORATE
OVERPAYMENTS EXCEEDING $10,000
FROM JANUARY 1, 1995 - PRESENT
1995–1 C.B.
RATETABLEPG
Jan. 1, 1995—Mar. 31, 19956.5%18572
Apr. 1, 1995—Jun. 30, 19957.5%20574
Jul. 1, 1995—Sep. 30, 19956.5%18572
Oct. 1, 1995—Dec. 31, 19956.5%18572
Jan. 1, 1996—Mar. 31, 19966.5%66620
Apr. 1, 1996—Jun. 30, 19965.5%64618
Jul. 1, 1996—Sep. 30, 19966.5%66620
Oct. 1, 1996—Dec. 31, 19966.5%66620
Jan. 1, 1997—Mar. 31, 19976.5%18572
Apr. 1, 1997—Jun. 30, 19976.5%18572
Jul. 1, 1997—Sep. 30, 19976.5%18572
Oct. 1, 1997—Dec. 31, 19976.5%18572
Jan. 1, 1998—Mar. 31, 19986.5%18572
Apr. 1, 1998—Jun. 30, 19985.5%16570
Jul. 1. 1998—Sep. 30, 19985.5%16570
Oct. 1, 1998—Dec. 31, 19985.5%16570
Jan. 1, 1999—Mar. 31, 19994.5%14568
Apr. 1, 1999—Jun. 30, 19995.5%16570
Jul. 1, 1999—Sep. 30, 19995.5%16570
Oct. 1, 1999—Dec. 31, 19995.5%16570
Jan. 1, 2000—Mar. 31, 20005.5%64618
Apr. 1, 2000—Jun. 30, 20006.5%66620
Jul. 1, 2000—Sep. 30, 20006.5%66620

Reporting IRA
Recharacterizations and
Reconversions
Notice 2000–30
I. PURPOSE
This notice specifies a new method to
be used by IRA trustees, issuers, and cus-
todians (hereinafter referred to as
“trustees”) for reporting IRA recharacteri-
zations and reconversions occurring after
2000. The new method is similar to cur-
rent reporting practices and is designed to
ensure consistent reporting among
trustees. This notice does not otherwise
affect the reporting rules governing con-
versions, contributions to, or distributions
from IRAs.
II. BACKGROUND
A. Recharacterizations and
Reconversions
A “recharacterization” is a trustee-to-
trustee transfer, made in accordance with
§ 408A(d)(6) of the Internal Revenue
Code and the regulations thereunder, of a
contribution (or a portion of a contribu-
tion), plus earnings, from one IRA (the
“FIRST IRA”) to another IRA (the “SEC-
OND IRA”). A properly recharacterized
contribution is treated, for Federal tax
purposes, as a contribution made to the
SECOND IRA, instead of to the FIRST
IRA. Recharacterizations are permitted
only between different types of IRAs; for
example, from a traditional IRA to a Roth
IRA and vice versa. See § 1.408A–5 of
the Income Tax Regulations.
A “conversion” is the transfer, by
rollover or other means, of an amount in a
nonRoth IRA to a Roth IRA. A “nonRoth
IRA” is an individual retirement account
or annuity described in § 408(a) or (b),
other than a Roth IRA. Any converted
amount is treated as a distribution from
the nonRoth IRA and a rollover to the
Roth IRA. See § 1.408A–4, Q&A-1.
A “reconversion” is a conversion from
a nonRoth IRA to a Roth IRA of an
amount that had previously been rechar-
acterized as a contribution to the nonRoth
IRA after having been earlier converted to
a Roth IRA.
In general, a recharacterization of a
contribution must be made on or before
the due date (including extensions) for fil-
ing the individual’s Federal income tax
return for the taxable year for which the
contribution was made to the FIRST IRA.
(See §§ 1.408A–5, Q&A-1(b).) Section
1.408A–5, Q&A-9, sets forth special tim-
ing rules for reconversions.
B. IRA Reporting Generally
A distribution from an IRA is reported
on a Form 1099-R by the trustee of the
IRA from which the distribution is made.
Amounts that are reported as distributions
on Form 1099-R include a contribution
that has been recharacterized from the
FIRST IRA to the SECOND IRA. When
a recharacterization occurs, the trustee of
the FIRST IRA issues a Form 1099-R.
The instructions to Form 1099-R provide
detailed information on how the form
should be completed.
A contribution to an IRA is reported on
a Form 5498 by the trustee of the IRA to
which the contribution is made. Contri-
butions that are reported on Form 5498
include a contribution that has been
recharacterized from the FIRST IRA to
the SECOND IRA. When a recharacteri-
zation occurs, the trustee of the SECOND
IRA issues a Form 5498. The instructions
to Form 5498 provide detailed informa-
tion on how the form should be com-
pleted.
C. Prior Guidance on Reporting
Recharacterizations and
Reconversions
Pursuant to §§ 408(i), 408A(d)(3)(D),
and 6047 of the Code and § 1.408A–7 of
the regulations, the Internal Revenue Ser-
vice has previously issued guidance on
the reporting of transactions involving
IRAs, including guidance relating to the
reporting of recharacterizations and re-
conversions. Notice 98-49, 1998–2 C.B.
365 (September 21, 1998), sets forth a
general rule for reporting recharacteriza-
tions. Under Notice 98–49, the gross
amount transferred in a recharacterization
is reported by the trustee of the FIRST
IRA on a Form 1099-R. That same
amount is also reported by the trustee of
the SECOND IRA on a Form 5498 that is
separate from any Form 5498 otherwise
required for the SECOND IRA.
Announcement 99–5, 1999–3 I.R.B. 16
(January 19, 1999), provides that, in lieu
of the reporting method described in No-
tice 98–49, an alternative method of re-
porting may be used with respect to
recharacterizations that occur in 1998 and
1999 using the same trustee. Announce-
ment 99–106, 1999–45 I.R.B. 561 (No-
vember 8, 1999), extended the alternative
method provided for in Announcement
99–5 through 2000. Announcements 99–5
and 99–106 also apply to reconversions.
III. FORMS 5498 AND 1099-R
REPORTING REQUIREMENTS FOR
IRA RECHARACTERIZATIONS AND
RECONVERSIONS AFTER 2000
To simplify IRA administration and to
enhance IRA owners’ understanding of
the Forms 5498 and 1099-R they receive
from the financial institutions maintaining
their IRAs, the Service and Treasury be-
lieve that there should be a consistent
method for reporting recharacterizations
and reconversions. After consideration of
comments from trustees and other organi-
zations involved in the administration of
IRAs and from other interested parties,
the Service and Treasury believe the fol-
lowing method best accommodates cur-
rent industry practices and simplification
of reporting these transactions.
The new reporting method generally
retains the requirement of Notice 98–49
that amounts recharacterized be identified
separately from other types of distribu-
tions and contributions. The new method
replaces the alternative methods permit-
ted by Announcements 99–5 and 99–106.
It is effective for recharacterizations and
reconversions that occur after 2000.
Each recharacterization or reconver-
sion occurring after December 31, 2000
(including a recharacterization or recon-
version of an amount contributed before
January 1, 2001), whether or not using the
same trustee, must be reported as pro-
vided in Forms 5498 and 1099-R and the
accompanying instructions. It is antici-
pated that these forms and instructions
will prescribe the rules set forth in A
June 19, 200012662000–25 I.R.B.
Part III. Administrative, Procedural, and Miscellaneous

through C below.
A. Form 1099-R Reporting of
Recharacterizations by the Trustee
of the FIRST IRA
Gross Amount Reported.The gross
amount transferred in a recharacterization
(contribution plus earnings) is reported on
Form 1099-R.
Prior and Current Year Recharacteri-
zations Distinguished.Recharacteriza-
tions that occur after the year for which
the contributions being recharacterized
were made (“prior year recharacteriza-
tions”) and recharacterizations that occur
in the same year as the year for which the
contributions being recharacterized were
made (“same year recharacterizations”)
must be reported on separate Forms 1099-
R. Prior year recharacterizations will be
coded with the existing Code R in Box 7,
while same year recharacterizations will
be coded with a new code, N, in Box 7.
Because prior year recharacterizations
and same year recharacterizations will be
separately coded, these amounts may not
be reported together on the same Form
1099-R. Similarly, because a recharacter-
ization will have a different code than
other reportable distributions, a recharac-
terization may not be reported together
with another reportable distribution on the
same Form 1099-R.
Combined Reporting of Similar
Recharacterizations.All prior year
recharacterizations from the same FIRST
IRA must be reported together on a single
Form 1099-R using Code R in Box 7. All
same year recharacterizations from the
same FIRST IRA must be reported on a
single Form 1099-R using the new code
in Box 7.
Example 1.(i) On December 15, 2000, Taxpayer
B makes an initial contribution of $2,000 to a tradi-
tional IRA (the FIRST IRA). On January 16, 2001,
B makes another contribution to this IRA in the
amount of $1,000 for the year 2001. On February
15, 2001, B makes another contribution to this IRA,
again in the amount of $1,000 for the year 2001.
Pursuant to B’s election, all three contributions
are recharacterized as contributions to a Roth IRA
(the SECOND IRA) on April 2, 2001. As of April 2,
2001, the earnings attributable to the initial contribu-
tion are $300, the earnings attributable to the second
contribution are $200, and the earnings attributable
to the third contribution are $150.
(ii) The trustee of the FIRST IRA issues B a
2001 Form 1099-R for the prior year recharacteriza-
tion of the initial contribution. The gross amount of
the transfer ($2,300) made in connection with the
recharacterization of the initial contribution is
shown in Box 1 and Code R is used in Box 7.
The trustee of the FIRST IRA also issues B a sec-
ond 2001 Form 1099-R for the two same year
recharacterizations. This Form 1099-R will show
$2,350 (the combined gross amount of the transfers
made in connection with the recharacterization of
the two 2001 contributions ($1,000 + $200 + $1,000
+ $150)) in Box 1 and will use the new Code N for
same year recharacterizations in Box 7.
B. Form 5498 Reporting of
Recharacterizations by the Trustee
of the SECOND IRA
Gross Amount Reported.The gross
amount received in a recharacterization
(contribution plus earnings) is reported on
Form 5498.
Recharacterization Contributions Dis-
tinguished from Rollover Contributions.
Recharacterizations will be reported in a
new box on Form 5498 titled “Recharac-
terized contributions” (instead of in Box 2
as provided in Notice 98–49) and the
checkbox titled “Rechar.” will be elimi-
nated.
Requirement of Separate Forms 5498
for each Recharacterization Eliminated.
All recharacterized contributions received
by an IRA in the same year are permitted
to be totaled and reported on one Form
5498. Alternatively, each recharacterized
contribution can be reported on a separate
Form 5498.
Single Form 5498 Covering All Contri-
butions Permitted.A single Form 5498 is
permitted to be used to report all contribu-
tions (including recharacterized contribu-
tions) made to an IRA in a year. Alterna-
tively, each contribution can be reported
on a separate Form 5498.
Example 2.(i) Taxpayer C has made two contri-
butions to her traditional IRA (the FIRST IRA). The
first contribution, in the amount of $2,000, was
made on November 1, 2000. The second contribu-
tion, also in the amount of $2,000, was made on
February 1, 2001, for 2001.
Pursuant to C’s election, the November 1, 2000,
contribution is recharacterized as a contribution to a
Roth IRA (the SECOND IRA) on April 2, 2001, at
which time the earnings attributable to the Novem-
ber 1, 2000, contribution are $100. Then, pursuant
to C’s election, the February 1, 2001, contribution is
recharacterized as a contribution to the SECOND
IRA on December 12, 2001, at which time the earn-
ings attributable to the February 1, 2001, contribu-
tion are $850.
(ii) The trustee of the SECOND IRA issues C a
single 2001 Form 5498 on which both recharacteri-
zations are reported. That Form 5498 will show, in a
new box, $4,950 ($2,000 + $100 + $2,000 + $850).
Alternatively, consistent with Notice 98–49, the
trustee of the SECOND IRA may issue two 2001
Forms 5498, one reporting $2,100 and one reporting
$2,850.
C. Form 1099-R and Form 5498
Reporting of Reconversions
Reconversions are reported on Forms
1099-R and 5498 in the same manner as
other conversions. The alternative method
described in Announcements 99–5 and
99–106 will not be available for reconver-
sions occurring in 2001 and thereafter.
EFFECT ON OTHER DOCUMENTS
Notice 98–49 is modified.
REQUEST FOR COMMENTS
The Service and Treasury invite com-
ments and suggestions concerning the
guidance provided in this notice. Any
correspondence received will be evalu-
ated, together with the needs of the Ser-
vice, to determine whether further guid-
ance on this subject is needed.
Comments can be submitted to
CC:DOM:CORP:R (Notice 2000–30),
room 5226, Internal Revenue Service,
POB 7604, Ben Franklin Station, Wash-
ington, DC 20044. Comments may be
hand delivered between the hours of 8
a.m. and 5 p.m. to CC:DOM:CORP:R
(Notice 2000–30), Courier’s Desk, Inter-
nal Revenue Service, 1111 Constitution
Avenue N.W., Washington, DC. All com-
ments will be available for public inspec-
tion and copying.
DRAFTING INFORMATION
The principal author of this notice is
Roger Kuehnle of Employee Plans (Tax
Exempt and Government Entities Divi-
sion). For further information regarding
this notice, please contact the Employee
Plans’ taxpayer assistance telephone ser-
vice at (202) 622-6074/6075 (not toll-free)
between the hours of 1:30 and 3:30 p.m.
Eastern Time, Monday through Thursday.
2000–25 I.R.B.1267June 19, 2000

Submission of Information to the
Office of Tax Shelter Analysis
Announcement 2000–55
In Announcement 2000–12, 2000–12
I.R.B. 835, the Internal Revenue Service
announced the formation of the Office of
Tax Shelter Analysis, to serve as a clear-
inghouse for information that comes to
the attention of the Service relating to po-
tentially improper tax shelter activity by
corporate and noncorporate taxpayers.
That announcement provided a mailing
address to be used by persons who wish to
submit information to the Office of Tax
Shelter Analysis relating to particular tax
shelter transactions and indicated that a
telephone number and e-mail address for
the office would be announced thereafter.
Persons wishing to submit information
to the Office of Tax Shelter Analysis relat-
ing to tax shelter transactions and activi-
ties may do so via mail, telephone, fax, or
e-mail, as follows:
June 19, 200012682000–25 I.R.B.
Part IV. Items of General Interest
Mailing address:Internal Revenue Service LM:PFTG
Office of Tax Shelter Analysis
1111 Constitution Avenue, NW
Washington, DC 20224
Telephone number:(202) 283-8740
Fax number:(202) 283-8354
E-mail address:irs.tax.shelter.hotline@irs.gov
The principal author of this announce-
ment is David A. Shulman of the Office of
Chief Counsel (Passthroughs and Special
Industries). For further information regard-
ing this announcement contact Mr. Shul-
man at (202) 622-3080 (not a toll-free
call).

2000–25 I.R.B.iJune 19, 2000
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
effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus,
if an earlier ruling held that a principle
applied to A, and the new ruling holds
that the same principle also applies to B,
the earlier ruling is amplified. (Compare
with modified, below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously
published ruling and points out an essen-
tial difference between them.
Modified is used where the substance
of a previously published position is
being changed. Thus, if a prior ruling
held that a principle applied to A but not
to B, and the new ruling holds that it ap-
plies to both A and B, the prior ruling is
modified because it corrects a published
position. (Compare with amplified and
clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used
in a ruling that lists previously published
rulings that are obsoleted because of
changes in law or regulations. A ruling
may also be obsoleted because the sub-
stance has been included in regulations
subsequently adopted.
Revoked describes situations where the
position in the previously published rul-
ing is not correct and the correct position
is being stated in the new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a pe-
riod of time in separate rulings. If the
new ruling does more than restate the
substance of a prior ruling, a combination
of terms is used. For example, modified
and superseded describes a situation
where the substance of a previously pub-
lished ruling is being changed in part and
is continued without change in part and it
is desired to restate the valid portion of
the previously published ruling in a new
ruling that is self contained. In this case
the previously published ruling is first
modified and then, as modified, is super-
seded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and
that list is expanded by adding further
names in subsequent rulings. After the
original ruling has been supplemented
several times, a new ruling may be pub-
lished that includes the list in the original
ruling and the additions, and supersedes
all prior rulings in the series.
Suspended is used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current use and for-
merly used will appear in material published in the
Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C.—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance 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 Procedral Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Definition of Terms

June 19, 2000ii2000–25 I.R.B.
Numerical Finding List
1
Bulletins 2000–1 through 2000–24
Announcements:
2000–1, 2000–2 I.R.B. 294
2000–2, 2000–2 I.R.B. 295
2000–3, 2000–2 I.R.B. 296
2000–4, 2000–3 I.R.B. 317
2000–5, 2000–4 I.R.B. 427
2000–6, 2000–4 I.R.B. 428
2000–7, 2000–6 I.R.B. 586
2000–8, 2000–6 I.R.B. 586
2000–9, 2000–9 I.R.B. 733
2000–10, 2000–9 I.R.B. 733
2000–11, 2000–10 I.R.B. 739
2000–12, 2000–12 I.R.B. 835
2000–13, 2000–11 I.R.B. 771
2000–14, 2000–11 I.R.B. 772
2000–15, 2000–12 I.R.B. 837
2000–16, 2000–12 I.R.B. 837
2000–17, 2000–13 I.R.B. 846
2000–18, 2000–13 I.R.B. 846
2000–19, 2000–19 I.R.B. 973
2000–20, 2000–19 I.R.B. 977
2000–21, 2000–19 I.R.B. 983
2000–22, 2000–19 I.R.B. 987
2000–23, 2000–19 I.R.B. 992
2000–24, 2000–14 I.R.B. 855
2000–25, 2000–14 I.R.B. 855
2000–26, 2000–15 I.R.B. 876
2000–27, 2000–15 I.R.B. 876
2000–28, 2000–15 I.R.B. 876
2000–29, 2000–15 I.R.B. 877
2000–30, 2000–15 I.R.B. 877
2000–31, 2000–15 I.R.B. 877
2000–32, 2000–15 I.R.B. 879
2000–33, 2000–15 I.R.B. 878
2000–34, 2000–15 I.R.B. 879
2000–35, 2000–16 I.R.B. 922
2000–36, 2000–16 I.R.B. 947
2000–37, 2000–16 I.R.B. 947
2000–38, 2000–16 I.R.B. 948
2000–39, 2000–16 I.R.B. 948
2000–40, 2000–16 I.R.B. 948
2000–41, 2000–16 I.R.B. 949
2000–42, 2000–16 I.R.B. 949
2000–43, 2000–17 I.R.B. 957
2000–44, 2000–17 I.R.B. 958
2000–45, 2000–18 I.R.B. 962
2000–46, 2000–19 I.R.B. 997
2000–47, 2000–21 I.R.B. 1118
2000–48, 2000–23 I.R.B. 1243
2000–49, 2000–19 I.R.B. 998
2000–50, 2000–19 I.R.B. 998
2000–51, 2000–22 I.R.B. 1141
2000–52, 2000–22 I.R.B. 1142
2000–53, 2000–22 I.R.B. 1144
Court Decisions:
2066, 2000–15 I.R.B. 867
2067, 2000–15 I.R.B. 863
Notices:
2000–1, 2000–2 I.R.B. 288
2000–2, 2000–9 I.R.B. 727
2000–3, 2000–4 I.R.B. 413
2000–4, 2000–3 I.R.B. 313
2000–5, 2000–3 I.R.B. 314
Notices—continued:
2000–6, 2000–3 I.R.B. 315
2000–7, 2000–4 I.R.B. 419
2000–8, 2000–4 I.R.B. 420
2000–9, 2000–5 I.R.B. 449
2000–10, 2000–5 I.R.B. 451
2000–11, 2000–6 I.R.B. 572
2000–12, 2000–9 I.R.B. 727
2000–13, 2000–9 I.R.B. 732
2000–14, 2000–10 I.R.B. 737
2000–15, 2000–12 I.R.B. 826
2000–16, 2000–12 I.R.B. 826
2000–17, 2000–12 I.R.B. 827
2000–18, 2000–13 I.R.B. 845
2000–19, 2000–13 I.R.B. 845
2000–20, 2000–14 I.R.B. 851
2000–21, 2000–19 I.R.B. 967
2000–22, 2000–16 I.R.B. 902
2000–23, 2000–17 I.R.B. 952
2000–24, 2000–17 I.R.B. 952
2000–25, 2000–17 I.R.B. 954
2000–26, 2000–17 I.R.B. 954
2000–27, 2000–21 I.R.B. 1116
2000–28, 2000–21 I.R.B. 1116
2000–29, 2000–23 I.R.B. 1241
Proposed Regulations:
REG–208280–86, 2000–8 I.R.B. 654
REG–209135–88, 2000–8 I.R.B. 681
REG–208254–90, 2000–6 I.R.B. 577
REG–209601–92, 2000–12 I.R.B. 829
REG–100276–97, 2000–8 I.R.B. 682
REG–101492–98, 2000–3 I.R.B. 326
REG–106012–98, 2000–2 I.R.B. 290
REG–106186–98, 2000–23 I.R.B. 1226
REG–107644–98, 2000–23 I.R.B. 1229
REG–109101–98, 2000–16 I.R.B. 903
REG–110311–98, 2000–11 I.R.B. 767
REG–122450–98, 2000–8 I.R.B. 682
REG–103831–99, 2000–5 I.R.B. 452
REG–103882–99, 2000–8 I.R.B. 706
REG–105089–99, 2000–6 I.R.B. 580
REG–105279–99, 2000–8 I.R.B. 707
REG–105606–99, 2000–4 I.R.B. 421
REG–107872–99, 2000–16 I.R.B. 911
REG–111119–99, 2000–5 I.R.B. 455
REG–113572–99, 2000–7 I.R.B. 624
REG–116048–99, 2000–6 I.R.B. 584
REG–116567–99, 2000–5 I.R.B. 463
REG–116704–99, 2000–3 I.R.B. 325
REG–117162–99, 2000–15 I.R.B. 871
REG–100163–00, 2000–7 I.R.B. 633
REG–100291–00, 2000–16 I.R.B. 917
REG–103735–00, 2000–11 I.R.B. 770
REG–103736–00, 2000–11 I.R.B. 768
Railroad Retirement Quarterly Rate:
2000–9 I.R.B. 721
Revenue Procedures:
2000–1, 2000–1 I.R.B. 4
2000–2, 2000–1 I.R.B. 73
2000–3, 2000–1 I.R.B. 103
2000–4, 2000–1 I.R.B. 115
2000–5, 2000–1 I.R.B. 158
2000–6, 2000–1 I.R.B. 187
2000–7, 2000–1 I.R.B. 227
2000–8, 2000–1 I.R.B. 230
2000–9, 2000–2 I.R.B. 280
Revenue Procedures—continued:
2000–10, 2000–2 I.R.B. 287
2000–11, 2000–3 I.R.B. 309
2000–12, 2000–4 I.R.B. 387
2000–13, 2000–6 I.R.B. 515
2000–14, 2000–18 I.R.B. 960
2000–15, 2000–5 I.R.B. 447
2000–16, 2000–6 I.R.B. 518
2000–17, 2000–11 I.R.B. 766
2000–18, 2000–9 I.R.B. 722
2000–19, 2000–12 I.R.B. 785
2000–20, 2000–6 I.R.B. 553
2000–21, 2000–19 I.R.B. 971
2000–22, 2000–20 I.R.B. 1008
2000–23, 2000–21 I.R.B. 1018
2000–24, 2000–22 I.R.B. 1133
2000–25, 2000–21 I.R.B. 1033
2000–26, 2000–24 I.R.B. 1257
Revenue Rulings:
2000–1, 2000–2 I.R.B. 250
2000–2, 2000–3 I.R.B. 305
2000–3, 2000–3 I.R.B. 297
2000–4, 2000–4 I.R.B. 331
2000–5, 2000–5 I.R.B. 436
2000–6, 2000–6 I.R.B. 512
2000–7, 2000–9 I.R.B. 712
2000–8, 2000–7 I.R.B. 617
2000–9, 2000–6 I.R.B. 497
2000–10, 2000–8 I.R.B. 643
2000–11, 2000–10 I.R.B. 734
2000–12, 2000–11 I.R.B. 744
2000–13, 2000–12 I.R.B. 774
2000–14, 2000–12 I.R.B. 779
2000–15, 2000–12 I.R.B. 774
2000–16, 2000–12 I.R.B. 780
2000–17, 2000–13 I.R.B. 842
2000–18, 2000–14 I.R.B. 847
2000–19, 2000–14 I.R.B. 849
2000–20, 2000–16 I.R.B. 880
2000–21, 2000–16 I.R.B. 881
2000–22, 2000–16 I.R.B. 880
2000–23, 2000–19 I.R.B. 964
2000–24, 2000–19 I.R.B. 963
2000–25, 2000–20 I.R.B. 1006
2000–26, 2000–22 I.R.B. 1124
2000–27, 2000–21 I.R.B. 1016
2000–28, 2000–23 I.R.B. 1157
2000–29, 2000–24 I.R.B. 1249
Tax Conventions:
2000–22 I.R.B. 1126
Treasury Decisions:
8849, 2000–2 I.R.B. 245
8850, 2000–2 I.R.B. 265
8851, 2000–2 I.R.B. 275
8852, 2000–2 I.R.B.253
8853, 2000–4 I.R.B.377
8854, 2000–3 I.R.B.306
8855, 2000–4 I.R.B.374
8856, 2000–3 I.R.B.298
8857, 2000–4 I.R.B.365
8858, 2000–4 I.R.B.332
8859, 2000–5 I.R.B.429
8860, 2000–5 I.R.B.437
8861, 2000–5 I.R.B.441
8862, 2000–6 I.R.B.466
8863, 2000–6 I.R.B.488
1
A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 1999–27 through
1999–52 is in Internal Revenue Bulletin 2000–1,
dated January 3, 2000.

2000–25 I.R.B.iiiJune 19, 2000
Treasury Decisions—continued:
8864, 2000–7 I.R.B.614
8865, 2000–7 I.R.B.589
8866, 2000–6 I.R.B.495
8867, 2000–7 I.R.B.620
8868, 2000–6 I.R.B.491
8869, 2000–6 I.R.B.498
8870, 2000–8 I.R.B.647
8871, 2000–8 I.R.B.641
8872, 2000–8 I.R.B.639
8873, 2000–9 I.R.B.713
8874, 2000–8 I.R.B.644
8875, 2000–11 I.R.B.761
8876, 2000–11 I.R.B.753
8877, 2000–11 I.R.B.747
8878, 2000–15 I.R.B.857
8879, 2000–16 I.R.B.882
8880, 2000–20 I.R.B.1003
8881, 2000–23 I.R.B.1158
8882, 2000–23 I.R.B.1150
8883, 2000–23 I.R.B.1151
8884, 2000–24 I.R.B.1250

June 19, 2000iv2000–25 I.R.B.
Finding List of Current Actions on
Previously Published Items
1
Bulletins 2000–1 through 2000–24
Announcements:
99–40
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
99–50
Modified by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
99–59
Superseded by
Announcement 2000–47, 2000–21 I.R.B. 1118
2000–18
Corrected by
Announcement 2000–32, 2000–15 I.R.B. 878
Notices:
88–125
Obsoleted by
T.D. 8870, 2000–8 I.R.B. 647
92–48
Obsoleted by
Notice 2000–11, 2000–6 I.R.B. 572
97–19
Modified by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
98–22
Obsoleted by
T.D. 8870, 2000–8 I.R.B. 647
98–52
Modified by
Notice 2000–3, 2000–4 I.R.B. 413
98–61
Modified and superseded by
Rev. Proc. 2000–15, 2000–5 I.R.B. 447
99–8
Obsoleted by
Rev. Proc. 2000–12, 2000–4 I.R.B. 387
2000–4
Corrected by
Announcement 2000–9, 2000–9 I.R.B. 733
Proposed Regulations:
REG–209601–92
Corrected by
Announcement 2000–40, 2000–16 I.R.B. 948
REG–100276–97
Corrected by
Announcement 2000–38, 2000–16 I.R.B. 948
REG–101492–98
Corrected by
Announcement 2000–16, 2000–12 I.R.B. 837
REG–122450–98
Corrected by
Announcement 2000–38, 2000–16 I.R.B. 948
REG–113572–99
Corrected by
Announcement 2000–41, 2000–16 I.R.B. 949
Proposed Regulations—Continued:
REG–103736–00
Corrected by
Announcement 2000–44, 2000–17 I.R.B. 958
Revenue Procedures:
80–18
Modified by
Rev. Proc. 2000–13, 2000–6 I.R.B. 515
89–9
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
89–13
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
90–21
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
91–66
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
92–13
Modified, amplified, and superseded by
Rev. Proc. 2000–11, 2000–3 I.R.B. 309
92–13A
Modified, amplified, and superseded by
Rev. Proc. 2000–11, 2000–3 I.R.B. 309
92–41
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
93–9
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
93–10
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
94–12
Modified, amplified, and superseded by
Rev. Proc. 2000–11, 2000–3 I.R.B. 309
95–42
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
96–13
Modified by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
98–22
Modified and superseded by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
98–27
Superseded by
Rev. Proc. 2000–12, 2000–4 I.R.B. 387
98–64
Superseded by
Rev. Proc. 2000–9, 2000–2 I.R.B. 280
98–65
Superseded by
Rev. Proc. 2000–19, 2000–12 I.R.B. 785
99–1
Superseded by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
Revenue Procedures—Continued:
99–2
Superseded by
Rev. Proc. 2000–2, 2000–1 I.R.B. 73
99–3
Superseded by
Rev. Proc. 2000–3, 2000–1 I.R.B. 103
99–4
Superseded by
Rev. Proc. 2000–4, 2000–1 I.R.B. 115
99–5
Superseded by
Rev. Proc. 2000–5, 2000–1 I.R.B. 158
99–6
Superseded by
Rev. Proc. 2000–6, 2000–1 I.R.B. 187
99–7
Superseded by
Rev. Proc. 2000–7, 2000–1 I.R.B. 227
99–8
Superseded by
Rev. Proc. 2000–8, 2000–1 I.R.B. 230
99–13
Modified and superseded by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
99–20
Supplemented by
Rev. Proc. 2000–14, 2000–18 I.R.B. 960
99–22
Obsoleted by
(except as provided in section 5.02 of)
Rev. Proc. 2000–21, 2000–19 I.R.B. 971
99–24
Superseded by
Rev. Proc. 2000–23, 2000–21 I.R.B. 1018
99–25
Superseded by
Rev. Proc. 2000–24, 2000–22 I.R.B. 1133
99–29
Superseded by
Rev. Proc. 2000–25, 2000–21 I.R.B. 1033
99–31
Modified and superseded by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
99–49
Modified and amplified by
Rev. Rul. 2000–4, 2000–4 I.R.B. 331
Rev. Rul. 2000–7, 2000–9 I.R.B. 712
Notice 2000–4, 2000–3 I.R.B. 313
99–51
Superseded by
Rev. Proc. 2000–3, 2000–1 I.R.B. 103
2000–6
Modified by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
2000–8
Modified by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
1
A cumulative list of current actions on previously
published items in Internal Revenue Bulletins
1999–27 through 1999–52 is in Internal Revenue
Bulletin 2000–1, dated January 3, 2000.

2000–25 I.R.B.vJune 19, 2000
Revenue Procedures—Continued:
2000–12
Corrected by
Announcement 2000–50, 2000–19 I.R.B. 998
2000–16
Corrected by
Announcement 2000–17, 2000–13 I.R.B. 846
Revenue Rulings:
57–259
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
57–499
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
73–292
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
76–79
Distinguised by
Rev. Rul. 2000–24, 2000–19 I.R.B. 963
78–218
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
80–76
Obsoleted by
T.D. 8883, 2000–23 I.R.B. 1151
86–62
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
88–36
Modified by
Rev. Rul. 2000–6, 2000–6 I.R.B. 512
89–89
Obsoleted by
Rev. Rul. 2000–2, 2000–3 I.R.B. 305
92–19
Supplemented by
Rev. Rul. 2000–17, 2000–13 I.R.B. 842
98–30
Amplified and superseded by
Rev. Rul. 2000–8, 2000–7 I.R.B. 617
Treasury Decisions:
8734
Modified by
T.D. 8856, 2000–3 I.R.B. 298
8804
Modified by
T.D. 8856, 2000–3 I.R.B. 298
8845
Corrected by
Announcement 2000–6, 2000–4 I.R.B. 428
8846
Corrected by
Announcement 2000–3, 2000–2 I.R.B. 296
8847
Corrected by
Announcement 2000–13, 2000–11 I.R.B. 771
8849
Corrected by
Announcement 2000–28, 2000–15 I.R.B. 876
8852
Corrected by
Announcement 2000–18, 2000–13 I.R.B. 846
8853
Corrected by
Announcement 2000–33, 2000–15 I.R.B. 878
Treasury Decisions—continued:
8856
Corrected by
Announcement 2000–31, 2000–15 I.R.B. 877
8859
Corrected by
Announcement 2000–27, 2000–15 I.R.B. 876
8864
Corrected by
Announcement 2000–26, 2000–15 I.R.B. 876
8865
Corrected by
Announcement 2000–37, 2000–16 I.R.B. 947
8867
Corrected by
Announcement 2000–30, 2000–15 I.R.B. 877
8869
Corrected by
Announcement 2000–36, 2000–16 I.R.B. 947
8870
Corrected by
Announcement 2000–34, 2000–15 I.R.B. 879
8874
Corrected by
Announcement 2000–29, 2000–15 I.R.B. 877
8879
Corrected by
Announcement 2000–53, 2000–22 I.R.B. 1144

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