us-irs-announcements-irb-2000-39-pdf•Internal Revenue Bulletin 2000-39 (PDF rendition): IRS Announcements
Internal Revenue Bulletin 2000-39 (PDF rendition): IRS Announcements
us-irs-announcements-irb-2000-39-pdfInternal Revenue Bulletin 2000-39 (PDF rendition): IRS AnnouncementsGuidance
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. 2000–42, page 297. Interest rates; underpayments and overpayments.The rate of interest determined under section 6621 of the Code for the calendar quarter beginning October 1, 2000, will be 9 percent for overpayments (8 percent in the case of a cor- poration), 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. EMPLOYEE PLANS Notice 2000–42, page 302. Weighted average interest rate update.The weighted average interest rate for September 2000 and the resulting permissible range of interest rates used to calculate current lia- bility for purposes of the full funding limitation of section 412(c)(7) of the Code are set forth. EXEMPT ORGANIZATIONS Announcement 2000–79, page 303. A list is given of organizations now classified as private foundations. Internal Revenue bbuulllleettiinn Bulletin No. 2000–39 September 25, 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. September 25, 20002000–39 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 general interest. It is published weekly and may be obtained from the Superintendent of Documents on a subscription basis. Bulletin contents are consolidated semiannually into Cumulative Bulletins, which are sold on a single-copy basis. It is the policy of the Service to publish in the Bulletin all sub- stantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless other- 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 revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements. Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying pub- lished rulings and procedures, the effect of subsequent leg- islation, regulations, court decisions, rulings, and proce- dures must be considered, and Service personnel and oth- ers concerned are cautioned against reaching the same con- clusions 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 Sub- parts. Also included in this part are Bank Secrecy Act Admin- istrative Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement). Part IV.—Items of General Interest. This part includes notices of proposed rulemakings, disbar- ment and suspension lists, and announcements. The first Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the first Bulletin of the succeeding semi- annual period, respectively. The IRS Mission Provide America’s taxpayers top quality service by help- ing them understand and meet their tax responsibilities and by applying the tax law with integrity and fairness to all. 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 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 October 1, 2000, will be 9 percent for overpayments (8 percent in the case of a corporation), 9 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. 2000–42 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 October 1, 2000, is the sum of the federal short-term rate plus 3 percent- age points (2 percentage points in the case of a corporation), except the rate for the portion of a corporate overpayment of tax exceeding $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 quar- terly interest rates to be used for overpay- ments 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, pur- suant to § 6622, is subject to daily com- pounding. Rounded to the nearest full percent, the federal short- term rate based on daily com- pounding determined during the month of July 2000 is 6 percent. Accordingly, an overpayment rate of 9 percent (8 percent in the case of a corporation) and an underpay- ment rate of 9 percent are established for the calendar quarter beginning October 1, 2000. The overpayment rate for the portion of a corporate overpayment exceeding $10,000 for the calendar quarter beginning October 1, 2000, is 6.5 percent. The under- payment rate for large corporate underpay- ments for the calendar quarter beginning October 1, 2000, is 11 percent. These rates apply to amounts bearing interest 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 (Administrative Provisions and Judicial Practice). For further information regarding this revenue ruling, contact Mr. Bailey at (202) 622- 6226 (not a toll-free call). 2000–39 I.R.B.297September 25, 2000 Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 September 25, 20002982000–39 I.R.B. TABLE OF INTEREST RATES FROM JAN. 1, 1987 - Dec. 31, 1998 OVERPAYMENTSUNDERPAYMENTS 1995–1 C.B.1995–1 C.B. RATE TABLE PGRATE TABLEPG 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 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—Continued FROM JAN. 1, 1987 - Dec. 31, 1998 OVERPAYMENTSUNDERPAYMENTS 1995–1 C.B.1995–1 C.B. RATE TABLE PGRATE TABLEPG 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 2000–39 I.R.B.299September 25, 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 Oct. 1, 2000—Dec 31, 20009%71625 TABLE OF INTEREST RATES FROM JANUARY 1, 1999 - PRESENT CORPORATE OVERPAYMENTS AND UNDERPAYMENTS OVERPAYMENTSUNDERPAYMENTS 1995–1 C.B.1995–1 C.B. RATE TABLE PGRATE TABLEPG 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 Oct. 1, 2000—Dec. 31, 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 Oct. 1, 2000—Dec. 1, 200011%75629 September 25, 20003002000–39 I.R.B. 2000–39 I.R.B.301September 25, 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 Oct. 1, 2000—Dec. 31, 20006.5%66620 September 25, 20003022000–39 I.R.B. Weighted Average Interest Rate Update Notice 2000–42 Notice 88–73 provides guidelines for determining the weighted average interest rate and the resulting permissible range of interest rates used to calculate current lia- bility for the purpose of the full funding limitation of § 412(c)(7) of the Internal Revenue Code as amended by the Om- nibus Budget Reconciliation Act of 1987 and as further amended by the Uruguay Round Agreements Act, Pub. L. 103-465 (GATT). The average yield on the 30-year Trea- sury Constant Maturities for August 2000 is 5.72 percent. The following rates were determined for the plan years beginning in the month shown below. Part III. Administrative, Procedural, and Miscellaneous 90% to 105%90% to 110% WeightedPermissible Permissible MonthYearAverageRangeRange September20005.965.36 to 6.265.36 to 6.56 Drafting Information The principal author of this notice is Todd Newman of the Employee Plans, Tax Exempt and Government Entities Di- vision. For further information regarding this notice, call the Employee Plans Actu- arial hotline, (202) 622-6076 between 2:30 and 3:30 p.m. Eastern time (not a toll-free number). Mr. Newman’s number is (202) 622-8458 (also not a toll-free number). Foundations Status of Certain Organizations Announcement 2000–79 The following organizations have failed to establish or have been unable to maintain their status as public charities or as operating foundations. Accordingly, grantors and contributors may not, after this date, rely on previous rulings or des- ignations in the Cumulative List of Orga- nizations (Publication 78), or on the pre- sumption arising from the filing of notices under section 508(b) of the Code. This listing does notindicate that the organiza- tions have lost their status as organiza- tions described in section 501(c)(3), eligi- ble to receive deductible contributions. Former Public Charities.The follow- ing organizations (which have been treated as organizations that are not pri- vate foundations described in section 509(a) of the Code) are now classified as private foundations: Against All Odds, Inc., Livingston, NJ Agape Multi-Purpose Ministry, Inc., Compton, CA American Advocate, Inc., Baltimore, MD American Family Thrift Stores, Brighton, MA Arkansas Housing Partnership, Inc., Little Rock, AR Ayehu Brehan Foundation, Inc., Ft. Washington, MD Caretuck Farms Foundation, Inc., Lake Toxaway, NC Children’s Pennsylvania Adoption Network, Erie, PA Christian Sports Camp, Inc., Doyle, TN Christmas in April Carroll County, Inc., Westminster, MD Cirik Foundation, Bonifacius, MN Committee Hermandad Pro-Aguilares, Murietta, CA Community Brainstorming Foundation of Milwaukee, Inc., Milwaukee, WI Community Communications Center, Inc., New Haven, CT Cyberlife Eternal, Inc., Fremont, CA Dansville Ambulance Company, Inc., Dansville, NY East Little Rock Community Development Corporation, Little Rock, AR Eastern Maine Conservation Initiative, Portland, ME Edward I. Rich Family Organization, Inc., Salt Lake City, UT ESB Foundation, Tacoma, WA FRP Community Housing Corporation, Philadelphia, PA Good Samaritan Ministries International, Inc., Hillside, IL Hamilton Amateur Figure Skating Association, Inc., Trenton, NJ Health Development International, Santee, CA Hispanic American Medical Scholarship Fund, Houston, TX Idaho Association For Bilingual Education, Rupert, ID IDEC or` Intake-Discharge Evaluation Center, Houston, TX Institute for Better Education Through Resource Technology, Northridge, CA Institute of American Studies, Inc., Sarasota, FL International Cultural League, Rowland Heights, CA Madison Youth Theatre, Madison, CT MBARI Institute for Contemporary African Art, Inc., Washington, DC New Vision Services, Inc., Neenah, WI North Louisiana Child Development Agency, Inc., Jonesboro, LA Oakland Technical High School Library Fund, Inc., Oakland, CA Odyssey for Peace, Bexley, OH Palm Beach Seaport Aquarium, Tequest, FL Pinnacle Foundation, Inc., Milburn, NJ PSI Chapter Diamond Association Charitable Foundation, Inc., Wheeling, WV Ruby Diamond Breast Cancer Foundation, University Heights, OH San Antonio Business Development Corporation, San Antonio, TX SHARE Supportive Housing and Resources for the Elderly, Las Vegas, NV Soccer Association of Warren County, Warren, PA South Plainfield Vision 2001 Education Foundation, Inc., South Plainfield, NJ Springfield Parents Recreation Association, Inc., Springfield, NJ St. Joseph County Courthouse Restoration Corporation, South Bend, IN Sustainable Communities, Inc., Santa Fe, NM Terreverte Foundation, Cliffside Park, NJ Theodora B. Brown Scholarship Fund, Inc., Red Bank, NJ Topeka Shawnee County Child & Adolescent Assessment Center, Inc., Topeka, KS Total Truth Ministries, Inc., Ottawa, IL Trinity Housing Services, Inc., Paoli, PA United States of America Foundation, San Diego, CA United States Water Fitness Association, Inc., Boynton Beach, FL Villa Encantada, Inc., Albuquerque, NM Warthog Productions, Inc., Boston, MA Wasco County Historical Museum, The Dalles, OR Welcome Grove Development Center, Inc., Atlanta, GA Winokur Family Foundation Wynnewood, PA Young People Working for Christ, Wichita, KS If an organization listed above submits in- formation that warrants the renewal of its classification as a public charity or as a pri- vate operating foundation, the Internal Rev- enue Service will issue a ruling or determi- nation letter with the revised classification as to foundation status. Grantors and contribu- tors may thereafter rely upon such ruling 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 classification of foundation sta- tus in the Internal Revenue Bulletin. 2000–39 I.R.B.303September 25, 2000 Part IV. Items of General Interest September 25, 2000i2000–39 I.R.B. 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 Contributions Act. FISC—Foreign International Sales Company. FPH—Foreign Personal Holding Company. F.R.—Federal Register. FUTA—Federal Unemployment Tax Act. FX—Foreign Corporation. G.C.M.—Chief Counsel’s Memorandum. GE—Grantee. GP—General Partner. GR—Grantor. IC—Insurance Company. I.R.B.—Internal Revenue Bulletin. LE—Lessee. LP—Limited Partner. LR—Lessor. M—Minor. Nonacq.—Nonacquiescence. O—Organization. P—Parent Corporation. PHC—Personal Holding Company. PO—Possession of the U.S. PR—Partner. PRS—Partnership. PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Real Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul.—Revenue Ruling. S—Subsidiary. S.P.R.—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. Definition of Terms 2000–39 I.R.B.iiSeptember 25, 2000 Numerical Finding List 1 Bulletins 2000–27 through 2000–38 Announcements: 2000–57, 2000–28 I.R.B. 115 2000–58, 2000–30 I.R.B. 135 2000–59, 2000–29 I.R.B. 120 2000–60, 2000–31 I.R.B. 149 2000–61, 2000–30 I.R.B. 136 2000–62, 2000–30 I.R.B. 137 2000–63, 2000–31 I.R.B. 149 2000–64, 2000–31 I.R.B. 149 2000–65, 2000–31 I.R.B. 150 2000–66, 2000–32 I.R.B. 160 2000–67, 2000–32 I.R.B. 160 2000–68, 2000–32 I.R.B. 161 2000–69, 2000–33 I.R.B. 183 2000–70, 2000–34 I.R.B. 204 2000–72, 2000–35 I.R.B. 226 2000–73, 2000–35 I.R.B. 230 2000–74, 2000–35 I.R.B. 230 2000–75, 2000–37 I.R.B. 268 2000–76, 2000–36 I.R.B. 260 2000–77, 2000–36 I.R.B. 260 Court Decisions: 2068, 2000–28 I.R.B. 109 Notices: 2000–33, 2000–27 I.R.B. 97 2000–34, 2000–33 I.R.B. 172 2000–35, 2000–29 I.R.B. 118 2000–36, 2000–33 I.R.B. 173 2000–37, 2000–29 I.R.B. 118 2000–38, 2000–33 I.R.B. 174 2000–39, 2000–30 I.R.B. 132 2000–40, 2000–30 I.R.B. 134 2000–41, 2000–33 I.R.B. 177 2000–43, 2000–35 I.R.B. 209 2000–44, 2000–36 I.R.B. 255 2000–45, 2000–36 I.R.B. 256 2000–46, 2000–37 I.R.B. 265 2000–48, 2000–37 I.R.B. 265 2000–49, 2000–37 I.R.B. 266 2000–50, 2000–38 I.R.B. 291 2000–51, 2000–38 I.R.B. 291 2000–52, 2000–38 I.R.B. 292 2000–53, 2000–38 I.R.B. 293 Proposed Regulations: REG–209038–89, 2000–34 I.R.B. 191 REG–105316–98, 2000–27 I.R.B. 98 REG–110311–98, 2000–36 I.R.B. 258 REG–116495–99, 2000–33 I.R.B. 179 REG–103735–00, 2000–36 I.R.B. 258 REG–103736–00, 2000–36 I.R.B. 258 REG–108522–00, 2000–34 I.R.B. 187 Railroad Retirement Quarterly Rate: 2000–28, I.R.B. 112 2000–29, I.R.B. 117 Revenue Procedures: 2000–28, 2000–27 I.R.B. 60 2000–29, 2000–28 I.R.B. 113 2000–30, 2000–28 I.R.B. 113 2000–31, 2000–31 I.R.B. 146 2000–32, 2000–33 I.R.B. 172 2000–33, 2000–36 I.R.B. 257 Revenue Procedures—continued: 2000–34, 2000–34 I.R.B. 186 2000–35, 2000–35 I.R.B. 211 2000–36, 2000–37 I.R.B. 267 Revenue Rulings: 2000–32, 2000–27 I.R.B. 1 2000–33, 2000–31 I.R.B. 142 2000–34, 2000–29 I.R.B. 116 2000–35, 2000–31 I.R.B. 138 2000–36, 2000–31 I.R.B. 140 2000–37, 2000–32 I.R.B. 156 2000–38, 2000–32 I.R.B. 157 2000–39, 2000–34 I.R.B. 184 2000–40, 2000–35 I.R.B. 208 2000–41, 2000–36 I.R.B. 248 2000–47, 2000–37 I.R.B. 264 Treasury Decisions: 8886, 2000–27 I.R.B. 3 8888, 2000–27 I.R.B. 3 8889, 2000–30 I.R.B. 124 8890, 2000–30 I.R.B. 122 8891, 2000–32 I.R.B. 152 8892, 2000–32 I.R.B. 158 8893, 2000–31 I.R.B. 143 8894, 2000–33 I.R.B. 162 8896, 2000–36 I.R.B. 249 8897, 2000–36 I.R.B. 234 8898, 2000–38 I.R.B. 276 8899, 2000–38 I.R.B. 288 8900, 2000–38 I.R.B. 279 8901, 2000–38 I.R.B. 272 1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2000–1 through 2000–26 is in Internal Revenue Bulletin 2000–27, dated July 3, 2000. September 25, 2000iii2000–39 I.R.B. Finding List of Current Actions on Previously Published Items 1 Bulletins 2000–27 through 2000–38 Notices: 87–76 Obsoleted by T.D. 8897, 2000–36 I.R.B. 234 88–24 Obsoleted by T.D. 8897, 2000–36 I.R.B. 234 88–86 Obsoleted by T.D. 8897 (section V), 2000–36 I.R.B. 234 Proposed Regulations: FI–42–90 Withdrawn by Announcement 2000–63, 2000–31 I.R.B. 149 IA–38–93 Withdrawn by Announcement 2000–68, 2000–32 I.R.B. 161 REG–107644–98 Corrected by Announcement 2000–66, 2000–32 I.R.B. 160 Revenue Procedures: 88–23 Superseded by Rev. Proc. 2000–35, 2000–35 I.R.B. 211 98–50 Modified and superseded by Rev. Proc. 2000–31, 2000–31 I.R.B. 146 98–51 Modified and superseded by Rev. Proc. 2000–31, 2000–31 I.R.B. 146 99–18 Modified by Rev. Proc. 2000–29, 2000–28 I.R.B. 113 99–34 Superseded by Rev. Proc. 2000–28, 2000–27 I.R.B. 60 Treasury Decisions: 8873 Corrected by Announcement 2000–74, 2000–35 I.R.B. 230 8883 Corrected by Announcement 2000–57, 2000–28 I.R.B. 115 8884 Corrected by Announcement 2000–73, 2000–35 I.R.B. 230 1 A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2000–1 through 2000–26 is in Internal Revenue Bulletin 2000–27, dated July 3, 2000. INTERNAL REVENUE BULLETIN The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue Bulletin is sold on a yearly subscription basis by the Superintendent of Documents. Current subscribers are notified by the Superintendent of Documents when their subscriptions must be renewed. CUMULATIVE BULLETINS The contents of this weekly Bulletin are consolidated semiannually into a permanent, indexed, Cumulative Bulletin. These are sold on a single copy basis and are not included as part of the subscription to the Internal Revenue Bulletin. Subscribers to the week- ly Bulletin are notified when copies of the Cumulative Bulletin are available. Certain issues of Cumulative Bulletins are out of print and are not available. Persons desiring available Cumulative Bulletins, which are listed on the reverse, may purchase them from the Superintendent of Documents. HOW TO ORDER Check the publications and/or subscription(s) desired on the reverse, complete the order blank, enclose the proper remittance, detach entire page, and mail to the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402. Please allow two to six weeks, plus mailing time, for delivery. WE WELCOME COMMENTS ABOUT THE INTERNAL REVENUE BULLETIN If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we would be pleased to hear from you. You can e-mail us your suggestions or comments through the IRS Internet Home Page (www.irs.gov) or write to the IRS Bulletin Unit, OP:FS:FP:P:1, Room 5617, 1111 Constitution Avenue NW, Washington, DC 20224. Internal Revenue Service Washington, DC 20224 Official Business Penalty for Private Use, $300
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