Internal Revenue Bulletin 2001-26 (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. 2001–29, page 1348.
REIT and section 355(b) active conduct of a trade or
business. A REIT can be engaged in the active conduct of a
trade or business within the meaning of section 355(b) of the
Code solely by virtue of functions with respect to rental activ-
ity that produces income qualifying as rents from real prop-
erty within the meaning of section 856(d) of the Code. Rev.
Rul. 73-236 obsoleted.
Rev. Rul. 2001–31, page 1348.
Captive insurance transactions. This ruling explains that
the Service will no longer raise the “economic family theory,”
set forth in Rev. Rul. 77–316 (1977–2 C.B. 53), in address-
ing whether captive insurance transactions constitute valid
insurance. Rather, the Service will address captive insurance
transactions on a case-by-case basis. Rev. Ruls. 77–316,
78–277, 88–72, and 89–61 obsoleted. Rev. Ruls. 78–338,
80–120, 92–93, and 2000–3 modified.
Rev. Rul. 2001–32, page 1350.
Interest rates; underpayments and overpayments. The
rate of interest determined under section 6621 of the Code
for the calendar quarter beginning July 1, 2001, will be 7
percent for overpayments (6 percent in the case of a cor-
poration), 7 percent for underpayments, and 9 percent for
large corporate underpayments. The rate of interest paid on
the portion of a corporate overpayment exceeding $10,000
will be 4.5 percent.
Notice 2001–40, page 1355.
Frivolous filing position based on section 861 of the
Code. There is no basis in law for the view that U.S. citizens
and residents are not subject to tax on wages and other U.S.
source income because the Code only taxes foreign-based
activities.
EXEMPT ORGANIZATIONS
Announcement 2001–67, page 1356.
Wentworth Community Services of Chicago, IL, no longer
qualifies as an organization to which contributions are
deductible under section 170 of the Code.
Announcement 2001–68, page 1356.
A list is provided of organizations now classified as private
foundations.
ADMINISTRATIVE
Announcement 2001–65, page 1356.
The Service announces that an updated edition of Publication
954, Tax Incentives for Empowerment Zones and Other
Distressed Communities (revised June 2001), is now avail-
able.
Internal Revenue
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Bulletin No. 2001–26
June 25, 2001
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
Announcement of Declaratory Judgment Proceedings Under Section 7428 begins on page 1358.
Finding Lists begin on page ii.

June 25, 20012001–26 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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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
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the force and effect of Treasury Department Regulations,
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islation, regulations, court decisions, rulings, and proce-
dures must be considered, and Service personnel and oth-
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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.
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This part is divided into two subparts as follows: Subpart A,
Tax Conventions, and Subpart B, Legislation and Related
Committee Reports.
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To the extent practicable, pertinent cross references to
these subjects are contained in the other Parts and Sub-
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istrative Rulings. Bank Secrecy Act Administrative Rulings
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annual period, respectively.
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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.

2001–26 I.R.B.June 25, 2001
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June 25, 200113482001–26 I.R.B.
Section 118.—Contributions to
the Capital of a Corporation
26 CFR 1.118–1: Contributions to the capital of a
corporation.
The revenue ruling obsoletes Rev. Rul. 77–316
(1977–2 C.B. 53), which provided that payments be-
tween related parties that were disallowed as deduc-
tions for insurance premiums should be recharacter-
ized as contributions to capital under I.R.C. § 118.
See Rev. Rul. 2001–31, on this page.
Section 162.—Trade or Business
Expenses
26 CFR 1.162–1: Business expenses.
The revenue ruling announces that the Service
will not raise the economic family theory, originally
set forth in Rev. Rul. 77–316 (1977–2 C.B. 53), in
determining whether payments between related par-
ties are deductible insurance premiums. See Rev.
Rul. 2001–31, on this page.
26 CFR 1.162–1: Business expenses.
(Also §§ 118, 165, 301, 801, 831; 1.118–1, 1.165–1,
1.301–1, 1.801–3, 1.831–3.)
This ruling explains that the Service
will no longer raise the “economic family
theory” set forth in Rev. Rul. 77–316
(1977–2 C.B. 53), in addressing whether
captive insurance transactions constitute
valid insurance. Rather, the Service will
address captive insurance transactions on
a case-by-case basis.
Rev. Rul. 2001–31
In Rev. Rul. 77–316 (1977–2 C.B. 53),
three situations were presented in which a
taxpayer attempted to seek insurance cov-
erage for itself and its operating sub-
sidiaries through the taxpayer’s wholly-
owned captive insurance subsidiary. The
ruling explained that the taxpayer, its non-
insurance subsidiaries, and its captive in-
surance subsidiary represented one “eco-
nomic family” for purposes of analyzing
whether transactions involved sufficient
risk shifting and risk distribution to con-
stitute insurance for federal income tax
purposes. See Helvering v. Le Gierse,
312 U.S. 531 (1941). The ruling con-
cluded that the transactions were not in-
surance to the extent that risk was re-
tained within that economic family.
Therefore, the premiums paid by the tax-
payer and its non-insurance subsidiaries
to the captive insurer were not deductible.
No court, in addressing a captive insur-
ance transaction, has fully accepted the eco-
nomic family theory set forth in Rev. Rul.
77–316. See, e.g., Humana, Inc. v. Commis-
sioner, 881 F.2d 247 (6
th
Cir. 1989);
Clougherty Packing Co. v. Commissioner,
811 F.2d 1297 (9
th
Cir. 1987) (employing a
balance sheet test, rather than the economic
family theory, to conclude that transaction
between parent and subsidiary was not in-
surance); Kidde Industries, Inc. v. United
States, 40 Fed. Cl. 42 (1997). Accordingly,
the Internal Revenue Service will no longer
invoke the economic family theory with re-
spect to captive insurance transactions.
The Service may, however, continue to
challenge certain captive insurance transac-
tions based on the facts and circumstances of
each case. See, e.g., Malone & Hyde v. Com-
missioner, 62 F.3d 835 (6
th
Cir. 1995) (con-
cluding that brother-sister transactions were
not insurance because the taxpayer guaranteed
the captive’s performance and the captive was
thinly capitalized and loosely regulated);
Clougherty Packing Co. v. Commissioner
(concluding that a transaction between parent
and subsidiary was not insurance).
EFFECT ON OTHER DOCUMENTS
Rev. Rul. 77–316, 1977–2 C.B. 53; Rev.
Rul. 78–277, 1978–2 C.B. 268; Rev. Rul.
88–72, 1988–2 C.B. 31; and Rev. Rul.
89–61, 1989–1 C.B. 75, are obsoleted.
Rev. Rul. 78–338, 1978–2 C.B. 107; Rev.
Rul. 80–120, 1980–1 C.B. 41; Rev. Rul.
92–93, 1992–2 C.B. 45; and Rev. Proc.
2000–3, 2000–1 I.R.B. 103, are modified.
DRAFTING INFORMATION
The principal author of this revenue ruling
is Robert A. Martin of the Office of Associ-
ate Chief Counsel (Financial Institutions &
Products). For further information regarding
this revenue ruling, contact Mr. Martin at
(202) 622-3970 (not a toll-free call).
Section 165.—Losses
26 CFR 1.165–1: Losses.
The revenue ruling obsoletes Rev. Rul. 77–316
(1977–2 C.B. 53), which provided that losses paid
by a captive insurance company pursuant to a re-
lated-party transaction deemed not to be insurance
were deductible by the captive insurer’s respective
parent or affiliate under IRC § 165(a). See Rev. Rul.
2001–31, on this page.
Section 301.—Distributions of
Property
26 CFR 1.301–1: Rules applicable with respect to
distributions of money and other property.
The revenue ruling obsoletes Rev. Rul. 77–316
(1977–2 C.B. 53), which provided that losses paid by
a captive insurance company pursuant to a related-
party transaction deemed not to be insurance were
viewed, to the extent of available earnings and prof-
its, as distributions under IRC § 301 to the respective
parent. See Rev. Rul. 2001–31, on this page.
Section 355.—Distribution of
Stock and Securities of a
Controlled Corporation
26 CFR 1.355–3: Active conduct of a trade or
business.
(Also: § 856)
REIT and section 355(b) active conduct
of a trade or business. A REIT can be
engaged in the active conduct of a trade or
business within the meaning of section
355(b) of the Code solely by virtue of
functions with respect to rental activity
that produces income qualifying as rents
from real property within the meaning of
section 856(d) of the Code.
Rev. Rul. 2001–29
ISSUE
Can a real estate investment trust
(REIT) be engaged in the active conduct
of a trade or business within the meaning
of § 355(b) of the Internal Revenue Code
solely by virtue of functions with respect
to rental activity that produces income
qualifying as rents from real property
within the meaning of § 856(d)?
LAW AND ANALYSIS
Sections 355(a)(1)(C) and (b) require
that both the distributing and controlled
corporations be engaged, immediately
after a distribution, in the active conduct
of a trade or business that has been ac-
tively conducted throughout the five year
period ending on the date of the distribu-
tion. Section 1.355–3(b)(2)(iii) of the In-
come Tax Regulations provides that the
determination of whether a trade or busi-
ness is actively conducted is made from
all the facts and circumstances. Gener-
ally, a corporation is treated as actively
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

2001–26 I.R.B.1349June 25, 2001
conducting a trade or business only if it
performs active and substantial manage-
ment and operational functions. Gener-
ally, activities performed by the corpora-
tion do not include activities performed
by persons outside the corporation, in-
cluding independent contractors. How-
ever, a corporation may satisfy the active
trade or business test through the activi-
ties it performs itself, even though some
of its activities are performed by others.
For an illustration of active and substan-
tial management and operational func-
tions in the context of the rental of real
property, see generallyRev. Rul. 79–394,
1979–2 C.B. 141, as amplified byRev.
Rul. 80–181, 1980–2 C.B. 121.
In Rev. Rul. 73–236, 1973–1 C.B. 183,
X, an unincorporated domestic trust qualify-
ing as an association taxable as a corpora-
tion under § 7701(a)(3), was engaged for
more than five years in the sale of real estate
that it developed and improved, and in the
leasing of buildings that it constructed. In
order to raise capital, X intended to convert
to a REIT, as defined in § 856. In order to
satisfy certain requirements of § 856, X had
to dispose of property that it held primarily
for sale to customers in the ordinary course
of business. To accomplish this, X trans-
ferred this property to Y, a newly formed
corporation, in exchange for all of the Y
stock, which X distributed to its beneficia-
ries pro rata. Immediately following the Y
stock distribution and as part of an overall
plan, X elected REIT status. In order to en-
sure that it would meet the requirements of
§ 856(c), X managed and operated its real
estate leasing operations through indepen-
dent contractors so as to qualify all of its
rental income as “rents from real property”
within the meaning of § 856(d). Section
856(d)(3), as in effect when Rev. Rul.
73–236 was issued, excluded from the term
“rents from real property” amounts received
with respect to such property “if the real es-
tate investment trust furnishes or renders
services to the tenants of such property, or
manages or operates such property, other
than through an independent contractor
from whom the trust itself does not derive
or receive any income.” (In 1976, this pro-
vision was redesignated § 856(d)(2)(C).
SeeTax Reform Act of 1976, Pub. L. No.
94–455, § 1604(b), 90 Stat. 1520, 1749
(1976).)
The only issue that Rev. Rul. 73–236
considered was whether X, after the dis-
tribution and while qualifying as a REIT
under § 856, was engaged in the active
conduct of a trade or business within the
meaning of § 355(b). Because X’s rental
activities conducted as a REIT were de-
signed to qualify all of its rental income
as “rents from real property” within the
meaning of § 856(d), Rev. Rul. 73–236
concluded that X did not directly perform
substantial management and operational
activities and, therefore, that X was not
engaged in an active trade or business
within the meaning of § 355(b) immedi-
ately after the distribution of the Y stock.
Section 663 of the Tax Reform Act of
1986, Pub. L. No. 99–514, 100 Stat. 2085,
2302 (1986), amended § 856(d)(2)(C).
Under the statute, as amended, amounts that
would qualify as rents from real property
under § 512(b)(3) if received by an organiza-
tion described in § 511(a)(2) are not ex-
cluded from rents from real property under
§ 856(d)(2)(C). Section 512(b)(3) excludes
rents from real property from unrelated
business taxable income. Section
1.512(b)–1(c)(5) interprets § 512(b)(3) to
permit an organization to treat rental income
as rents from real property even if, in con-
nection with the rental activity, it furnishes
certain services that are not primarily for the
convenience of the occupant and are usually
or customarily rendered in connection with
the rental of real property. Such services in-
clude, for example, the furnishing of heat
and light; the cleaning of public entrances,
exits, stairways, and lobbies; and the collec-
tion of trash. Consequently, as a result of the
1986 amendment, a REIT is permitted to
perform activities that can constitute active
and substantial management and operational
functions with respect to rental activity that
produces income qualifying as rents from
real property under § 856(d).
HOLDING
A REIT can be engaged in the active con-
duct of a trade or business within the mean-
ing of § 355(b) solely by virtue of functions
with respect to rental activity that produces
income qualifying as rents from real prop-
erty within the meaning of § 856(d).
EFFECT ON OTHER REVENUE
RULING
Rev. Rul. 73–236 is obsoleted.
The obsolescence of Rev. Rul. 73–236,
which denied § 355 treatment to a distrib-
ution of stock by a C corporation that con-
verted to a REIT because the REIT was
not engaged in the active conduct of a
trade or business, does not imply a view
as to whether a distribution of stock in-
volving a REIT election by the distribut-
ing or controlled corporation would other-
wise satisfy the requirements of § 355,
including the corporate business purpose
requirement of § 1.355–2(b).
DRAFTING INFORMATION
The principal author of this revenue
ruling is Richard Passales of the Office of
Associate Chief Counsel (Corporate).
For further information regarding this
revenue ruling, contact Mr. Passales at
(202) 622-7530 (not a toll-free call).
Section 801.—Tax Imposed
26 CFR 1.801–3: Definitions.
The revenue ruling obsoletes Rev. Rul. 77–316
(1977–2 C.B. 53), which provided that certain cap-
tive insurance companies were not taxable as insur-
ance companies pursuant to IRC §§ 801, 831, and
the applicable regulations because the related-party
transactions could not be considered “insurance” for
purposes of determining whether the captive insurer
was “primarily and predominantly engaged in the
insurance business,” as required in Treas. Reg.
§ 1.801–3(a). See Rev. Rul. 2001–31, page 1348.
Section 831.—Tax on Insurance
Companies Other Than Life
Insurance Companies
26 CFR 1.831–3: Tax on insurance companies
(other than life or mutual), mutual marine
insurance companies, mutual fire insurance
companies issuing perpetual policies, and mutual
fire or flood insurance companies operating on the
basis of premium deposits; taxable years beginning
after December 31, 1962.
The revenue ruling obsoletes Rev. Rul. 77–316
(1977–2 C.B. 53), which provided that certain cap-
tive insurance companies were not taxable as insur-
ance companies pursuant to IRC §§ 801, 831, and
the applicable regulations because the related-party
transactions could not be considered “insurance” for
purposes of determining whether the captive insurer
was “primarily and predominantly engaged in the
insurance business,” as required in Treas. Reg.
§ 1.801–3(a). See Rev. Rul. 2001–31, page 1348.
Section 856.—Definition of Real
Estate Investment Trust
26 CFR 1.856–1: Definition of real estate
investment trust.
REIT & § 355(b) active conduct of a trade or
business: The ruling holds that a REIT can be engaged
in the active conduct of a trade or business within the

meaning of § 355(b) solely by virtue of functions with
respect to rental activity that produces income qualify-
ing as rents from real property within the meaning of
§ 856(d). See Rev. Rul. 2001–29, page 1348.
Section 6621.—Determination
of Interest Rate
26 CFR 301.6621–1: Interest rate.
Interest rates; underpayments and over-
payments. The rate of interest determined
under section 6621 of the Code for the cal-
endar quarter beginning July 1, 2001, will be
7 percent for overpayments (6 percent in the
case of a corporation), 7 percent for under-
payments, and 9 percent for large corporate
underpayments. The rate of interest paid on
the portion of a corporate overpayment ex-
ceeding $10,000 will be 4.5 percent.
Rev. Rul. 2001–32
Section 6621 of the Internal Revenue
Code establishes the rates for interest
on tax overpayments and tax underpay-
ments. Under § 6621(a)(1), the over-
payment rate beginning July 1, 2001, is
the sum of the federal short-term rate
plus 3 percentage points (2 percentage
points in the case of a corporation), ex-
cept the rate for the portion of a corpo-
rate 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 computa-
tions 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 Regula-
tions on Procedure and Administration for
the definition of a large corporate under-
payment and for the rules for determining
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 Secre-
tary will determine the federal short-term rate
for the first month in each calendar 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 com-
pounding because that rate is most consis-
tent 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 2001 is 4 percent. Ac-
cordingly, an overpayment rate of 7 per-
cent (6 percent in the case of a corpora-
tion) and an underpayment rate of 7
percent are established for the calendar
quarter beginning July 1, 2001. The over-
payment rate for the portion of a corpo-
rate overpayment exceeding $10,000 for
the calendar quarter beginning July 1,
2001, is 4.5 percent. The underpayment
rate for large corporate underpayments
for the calendar quarter beginning July 1,
2001, is 9 percent. These rates apply to
amounts bearing interest during that cal-
endar quarter.
Interest factors for daily compound in-
terest for annual rates of 4.5 percent, 6
percent, 7 percent, and 9 percent are pub-
lished in Tables 14, 17, 19, and 23 of Rev.
Proc. 95–17, 1995–1 C.B. 556, 568, 571,
573, and 577.
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 rul-
ing is Raymond Bailey of the Office of As-
sociate Chief Counsel (Procedure & Ad-
ministration), Administrative Provisions &
Judicial Practice Division. For further in-
formation regarding this revenue ruling,
contact Mr. Bailey at (202) 622-6226 (not a
toll-free call).
June 25, 200113502001–26 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, 1975 6%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, 1985 11%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%21575 9% 23 577
Jul. 1, 1987—Sep. 30, 19878%215759%23577
Oct. 1, 1987—Dec. 31, 1987 9%2357710%25579
Jan. 1, 1988—Mar. 31, 198810%7362711%75629
Apr. 1, 1988—Jun. 30, 1988 9%7162510%73627
Jul. 1, 1988—Sep. 30, 1988 9%7162510%73627
Oct. 1, 1988—Dec. 31, 1988 10%7362711%75629
Jan. 1, 1989—Mar. 31, 1989 10%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, 1990 10% 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% 65619 7%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, 1993 6%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
2001–26 I.R.B.1351June 25, 2001

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
Jan. 1, 2001—Mar. 31, 20019%23577
Apr. 1, 2001—Jun. 30, 20018%21575
Jul. 1, 2001—Sep. 30, 20017%19573
June 25, 200113522001–26 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
Oct. 1, 2000—Dec. 31, 20008%696239%71625
Jan. 1, 2001—Mar. 31, 20018%215759%23577
Apr. 1, 2001—Jun. 30, 20017%195738%21575
Jul. 1, 2001—Sep. 30, 20016%175717%19573

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. 31, 200011%75629
Jan. 1, 2001—Mar. 31, 200111%27581
Apr. 1, 2001—Jun. 30, 200110%25579
Jul. 1, 2001—Sep. 30, 20019%23577
2001–26 I.R.B.1353June 25, 2001

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, 1998 6.5%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
Jan. 1, 2001—Mar. 31, 20016.5%18572
Apr. 1, 2001—Jun. 30, 20015.5%16570
Jul. 1, 2001—Sep. 30, 20014.5%14568
June 25, 200113542001–26 I.R.B.

Frivolous Filing Position Based
on Section 861
Notice 2001–40
The Internal Revenue Service and the
Treasury Department are aware that cer-
tain persons are promoting the view that
U.S. citizens and residents are not subject
to tax on their wages and other income
earned or derived within the United States
based on the claim that the Internal Rev-
enue Code imposes taxes only on income
derived from certain foreign-based activi-
ties. The Service and Treasury are issuing
this notice to inform taxpayers that this
reporting position has no basis in law.
The proponents of this position misread
the Code and the Treasury Regulations.
Although the proponents acknowledge
that section 1 imposes income tax on
“taxable income,” that “taxable income”
consists of “gross income” minus deduc-
tions (section 63) and that “gross income”
is income “from whatever source de-
rived” (section 61), they assert that sec-
tions 861 through 865 of the Code and the
regulations thereunder (in particular,
Treasury regulation section 1.861–8) limit
taxable “sources” of income to certain
foreign–based activities.
That assertion is refuted by the express
and unambiguous terms of the Code.
Section 61 includes in gross income “all
income from whatever source derived.”
As the Supreme Court stated in Commis-
sioner v. Glenshaw Glass Co., 348 U.S.
426, 429 (1955), “Congress applied no
limitations as to the source of taxable re-
ceipts . . . .” Nothing in sections 861 to
865 of the Code limits the gross income
subject to United States taxation to for-
eign-source income. The rules of sections
861 through 865 have significance in de-
termining whether income is considered
from sources within the United States or
without the United States, which is rele-
vant, for example, in determining whether
a U.S. citizen or resident may claim a
credit for foreign taxes paid. See Great-
West Life Assurance Co. v. United States,
678 F.2d 180, 183 (Ct. Cl. 1982) (stating
that “[t]he determination of where income
is derived or ‘sourced’ is generally of no
moment to either United States citizens or
United States corporations, for such per-
sons are subject to tax under I.R.C. § 1
and I.R.C. § 11, respectively, on their
worldwide income” and that “[l]ikewise,
the income of a resident alien individual
is taxed under I.R.C § 1 without regard to
source”). The source rules do not operate
to exclude from U.S. taxation income
earned by United States persons from
sources within the United States.
Williams v. Commissioner, 114 T.C. 136
(2000) (rejecting the claim that income
was not subject to tax because it was not
from any of the sources listed in Treas.
Reg. sec. 1.861–8(a)); Aiello v. Commis-
sioner, T.C. Memo. 1995–40 (1995) (re-
jecting the claim that section 861 lists the
only sources of income relevant for pur-
poses of section 61).
The courts have categorically rejected
contentions that U.S. citizens are not law-
fully subject to Federal income tax on
their income from all sources and have
upheld criminal convictions of individu-
als who based their refusal to pay Federal
income tax on such contentions. See,
e.g., United States v. Condo, 741 F.2d 238
(9th Cir. 1984).
The Internal Revenue Service and the
Treasury Department advise taxpayers
that if they file returns reflecting this the-
ory that only certain foreign-source in-
come is taxable, they may be subject to
penalties including, but not limited to, the
accuracy-related penalty under section
6662 and the frivolous return penalty
under section 6702. Under some circum-
stances, taxpayers adopting this position
on tax returns may be subject to addi-
tional sanctions, including failure to file
or pay penalties under section 6651 and
civil fraud penalties under section 6663,
and may be prosecuted for criminal viola-
tions of the tax law. In addition, practi-
tioners advocating this position may be
subject, under some circumstances, to the
return preparer penalty under section
6694 or aiding and abetting penalties
under section 6701, and may be prose-
cuted for criminal violations of the tax
law.
The Internal Revenue Service and the
Treasury Department recognize that some
taxpayers may have chosen not to file or
have filed incorrect tax returns, taking the
position that they were not required to re-
port wages or other income earned in the
United States for taxation. We advise
these taxpayers to take prompt action to
file correct returns and to comply with the
tax laws. Taxpayers can obtain tax forms,
including those necessary to amend previ-
ously-filed returns, via the IRS web site
(http://www.irs.gov), obtain them through
the IRS’ TaxFax Services (from a fax ma-
chine call: 703-368-9694 (not a toll-free
number)), or order the forms by phone:
1-800-TAX-FORM (1-800-829-3676).
2001–26 I.R.B.1355June 25, 2001
Part III. Administrative, Procedural, and Miscellanous

June 25, 200113562001–26 I.R.B.
New Revision of Publication
954,
Tax Incentives for
Empowerment Zones and Other
Distressed Communities
Announcement 2001–65
Publication 954, revised June 2001, is
now available from the Internal Revenue
Service. It replaces the February 1999 re-
vision.
This publication is primarily for busi-
ness owners who want to find out whether
they qualify for certain tax incentives cre-
ated to increase business activity in dis-
tressed communities.
You can get a copy of this publication
by calling 1-800-TAX-FORM (1-800-
829-3676). You can also write to the IRS
Forms Distribution Center nearest you.
Check your income tax package for the
address. The publication is also available
on the IRS Internet Web site at
www.irs.gov.
Deletions From Cumulative List
of Organizations Contributions
to Which are Deductible Under
Section 170 of the Code
Announcement 2001–67
The name of an organization that no
longer qualifies as an organization de-
scribed in section 170(c)(2) of the Internal
Revenue Code of 1986 is listed below.
Generally, the Service will not disallow
deductions for contributions made to a
listed organization on or before the date
of announcement in the Internal Revenue
Bulletin that an organization no longer
qualifies. However, the Service is not
precluded from disallowing a deduction
for any contributions made after an orga-
nization ceases to qualify under section
170(c)(2) if the organization has not
timely filed a suit for declaratory judg-
ment under section 7428 and if the con-
tributor (1) had knowledge of the revoca-
tion of the ruling or determination letter,
(2) was aware that such revocation was
imminent, or (3) was in part responsible
for or was aware of the activities or omis-
sions of the organization that brought
about this revocation.
If on the other hand a suit for declara-
tory judgment has been timely filed, con-
tributions from individuals and organiza-
tions described in section 170(c)(2) that
are otherwise allowable will continue to
be deductible. Protection under section
7428(c) would begin on June 25, 2001,
and would end on the date the court first
determines that the organization is not de-
scribed in section 170(c)(2) as more par-
ticularly set forth in section 7428(c)(1).
For individual contributors, the maximum
deduction protected is $1,000, with a hus-
band and wife treated as one contributor.
This benefit is not extended to any indi-
vidual, in whole or in part, for the acts or
omissions of the organization that were
the basis for revocation.
Wentworth Community Services
Chicago, IL
Foundations Status of Certain
Organizations
Announcement 2001–68
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:
100 Black Women of Milwaukee, Inc.,
Milwaukee, WI
Able Group, Inc., San Diego, CA
A.D.D. Foundation, Medina, MN
African International Institute,
Irvine, CA
Africarta, Inc., St. Petersburg, FL
Ahava Incorporated, Baltimore, MD
American Aviation Heritage Foundation,
Inc., Minneapolis, MN
American Lutheran Community Services,
Inc., Eau Claire, WI
Anchor Ministries Incorporated,
Yorkville, IL
Association for Christian Teens-Act, Inc.,
Lake City, MN
Baldwin Conservation Area Corporation,
Howell, MI
Barb Frost Foundation, Inc.,
New Brighton, MN
Bartus Foundation, Inc., Wauwatosa, WI
Bell School Parent Teacher Organization,
Marblehead, MA
Bible Verse Ministries, Montgomery, AL
Black Excel the College Help Network,
New York, NY
Bloomingdale Athletic Club,
Grand Junction, MI
Boston Aids Consortium, Boston, MA
Buddy Ball Sports League,
Laureldale, NJ
Business and Nonprofit Development
Center of Eastern Madera County, Inc.,
North Fork, CA
C. D. Gilmore African-American
Genealogy & Research Center,
East Orange, NJ
Call to Action-Wisconsin,
Milwaukee, WI
Campbell Residential Services, Corp.,
Lancaster, OH
Career Development and Youth
Community Services, Inc., Inkster, MI
Carlton County Electric Tr.,
Kettle River, MN
Carver-Scott Educational Foundation,
Chaska, MN
Catholic Servant, Minneapolis, MN
Cedarburg Community Pool Association,
Cedarburg, WI
Cema Sargent Foundation, St. Paul, MN
Center for Intelligence Studies, Inc.,
Arlington, VA
Consolidated Medical-Jurisprudence
Services, Inc., Edina, MN
Creative Lifelines for Survivors,
Stillwater, MN
Creative Steps Learning World, Chicago,
IL
Cyclone Fire Department, Cyclone, WV
Derek Kuduk Memorial Foundation,
Andover, MN
Earning by Learning Foundation, Inc.,
Fond Du Lac, WI
Part IV. Items of General Interest

2001–26 I.R.B.1357June 25, 2001
East Gull Lake First Responders,
E. Gull Lake, MN
Evansville Minority Community
Development Fund of Indiana, Inc.,
Evansville, IN
Faith Community Impact, Inc.,
Racine WI
Families Fighting Against Crime
Together, Inc., Delavan, MI
Farm City Link, Inc., Milwaukee, WI
Fishnet Ministries International,
Kihei, HI
Five Fold Ministries, Inc., Canton, MN
Flyway Ministries, Inc., Beaver Dam, WI
Furry Critters Wildlife Sanctuary, Inc.,
Sturgeon Bay, WI
Future Home Foundation, Inc.,
Phoenix, MD
Gateway Development Opportunities,
Inc., Minneapolis, MN
Generations Neighborhood Development
Organization, Detroit, MI
Girls Club of Puget Sound, Seattle, WA
Global Environmental Business Research
Institute, San Diego, CA
Gold Coast Driving for the Disabled,
Ojai, CA
Good Company, Prior Lake, MN
Grasslyn Manor Neighborhood
Association Nonstock, Inc.,
Milwaukee, WI
Great Lakes Housing Opportunities, Inc.,
Haslett, MI
Great Taste of La Crosse, Inc.,
La Crosse, WI
Gundersen Lutheran Visiting Nurses,
Inc., La Crosse, WI
Happy Voices, Inc., Medford, OR
Harlem Jazz Society Foundation, Inc.,
New Orleans, LA
Harriet Sloan Memorial Scholarship
Fund, Somers, NY
Healthy Visions Laurens County, Inc.,
Clinton, SC
Hello Friend, Inc., Madison, WI
Hibbing Sister Cities, Inc.,
Hibbing, MN
Hispanic Educational and Support
Outreach Services, Inc., Racine, WI
Hoop Club, Inc., Duluth, MN
Hopkins Family & Youth Preservation
Society, Hopkins, MN
Hudson Benchwarmers Club, Inc.,
Hudson, WI
ICI University Center for Deaf
Ministries, Nerstrand, MN
Independence Square Apartments II,
Fort Gratiot, MI
International Association for Scientific
Study of Intellectual Disabilities,
Birmingham, AL
International Black Aerospace Council
IBAC, Inc., Oklahoma City, OK
International Churchill Society,
Laurel, MD
International Fuel Cell Electric Power
Association, Tulsa, OK
International Marinelife Alliance,
Honolulu, HI
International Society of Refractive
Surgery Foundation, Minneapolis, MN
James and John Apartments, Inc.,
Milwaukee, WI
Jesses Toys for Tots Committee,
New Baltimore, MI
Jim Niessen Foundation for Disabled
Skiers, Forest Lake, MN
Kappa Chapter-Gamma Phi Beta
Foundation, Excelsior, MN
Knights of Columbus Scholastic
Achievement Fund,
Essex Junction, VT
Lakes Area Community Association, Inc.,
Twin Lakes, WI
Lakeshore Child Care Services, Inc.,
Sturgeon Bay, WI
Latin Athletic Club, Inc., Racine, WI
Living Treasures, Inc., Monsey, NY
Mankato School of Arts & Crafts,
Mankato, MN
Mantle Group, Inc., Hempstead, NY
Mechanic Arts Central Alumni
Association, St. Paul, MN
Memory Lane Center, Detroit, MI
Michigan Black Expo, Inc.,
Grand Rapids, MI
Michigan Council on Problem Gambling,
Inc., Grosse Pointe Farms, MI
Michigan Regional Training Agency,
Birch Run, MI
Minds Eye Institute, Inc., Brookfield, WI
Minneapolis St. Paul Tape & Book
Ministry, Burnesville, MN
Minnesota Professional Golfers
Association Scholarship Fund,
Coon Rapids, MN
Minnesota Property Rights Foundation,
Inc., Blaine, MN
Minnesota Valley BMX, Inc.,
Bloomington, MN
Motion of South Fla. Inc., Miami, FL
National Association of Baby Boomers,
Inc., Depere, WI
National Center for Violence Prevention,
Ashland, OR
Natives, Columbia Heights, MN
New Beginnings of Northern Wisconsin,
Inc., Rhinelander, WI
New Beginnings Outreach Ministries,
Inc., Bronx, NY
New Vision Community Organization of
Southeast Wisconsin, Inc., Racine, WI
North Urban Broadcasting, Inc.,
Minneapolis, MN
Northeastern Minnesota Creativity
Council, Duluth, MN
Paideia Educational Foundation,
Parkersburg, WV
Partnership for a Healthier Community,
Joliet, IL
Paul E. Goldstein Family and Childrens
Foundation, Minnetonka, MN
Pazmany Peter Catholic Univ. of
Hungary Chapel, Madison, WI
People Regenerating Opportunities for
Equal Success Corp., Milwaukee, WI
Phoenix Project Community
Development Fdn., Fayette, MS
Planet Savers, Inc.,
Port Washington, NY
Praise Cathedral Ministries, Dallas, TX
Primary Choice Residence Home, Inc.,
Milwaukee, WI
Pro Viviendas I, Inc., Canovas, PR
Progressive Center for Education and
Economic Development, Inc.,
St. Paul, MN
Project Success, Inc., Savannah, GA
Purple Cow & Friends,
Valley Center, CA
Queens Multi-Service, Glendale, NY
Rainforest and Reef Conservation Fund,
Grand Rapids, MI
Range Helping Hands, Inc.,
Hibbing, MN
Read Tampa Bay, Inc., Tampa, FL
Recycled Rhapsodies-Free Musical
Instruments for Needy Children,
Kenosha, WI
Renew Community Services, Inc.,
Milwaukee, WI
Restore Our Waters, Inc.,
New Smyrna Beach, FL
Ripon Community Thrift Store, Inc.,
Ripon, WI
Rivers of Healing Ministries,
Philadelphia, PA
Rochester Youth Self Leadership
Program, Rochester, MN
Rose Cologne Center for Barrier Free
Living, State College, PA
Russian Connection, Inc., Glendale, WI
San Diego Institute for Herbal Studies,
San Diego, CA

June 25, 200113582001–26 I.R.B.
Sheboygan Elite Fussball Club, Inc.,
Sheboygan, WI
Shorewood Girls Softball, Inc.,
Milwaukee, WI
Skill Builders, Inc., Bellevue, NE
Southside Youth Sports Club,
Minneapolis, MN
Staring Art Center, Eden Prairie, MN
State Street Renewal Corp.,
Milwaukee, WI
Stay in the Game, Incorporated,
Milwaukee, WI
Temple Foundation, Westminster, CA
Terwilliger Special Childrens Fund,
Lowman, NY
Timothy Foundation, Sturgeon Bay, WI
Trauma and Abuse Information, Inc.,
Madison, WI
Trillium Society for the Visual and
Performing Arts, Butler, PA
Turning Point Ministries, Inc.,
Two Harbors, MN
Ujima Community Development
Corporation, Milwaukee, WI
United Lao and Hmong Youth of Mn.
Ulhym, St. Paul, MN
Valley Ark, Inc., Oshkosh, WI
White Bear Area Chamber of Commerce
Scholarship Fund,
White Bear Lake, MN
Wild Ground Learning Center,
Missoula, MT
Winnetka Public Schools Foundation,
Winnetka, IL
Wisconsin Alcohol Drug & Disability
Association, Inc., Madison, WI
Wisconsin Fish Stocking Association,
West Bend, WI
Wisconsin Society for the Prevention of
Cruelty to Animals, Mequon, WI
Wondercare Child Care, Inc.,
Camp Verde, AZ
Wonderland Gardens, Inc., Decatur, GA
Yates Charitable Foundation, Inc.,
Boston, MA
Youthful in Roads, Inc., Racine, WI
Zachary James Lea Memorial
Foundation, Incorporated,
Waterford, VA
Zichron Arye, Inc., Brooklyn, NY
If an organization listed above submits
information that warrants the renewal of
its classification as a public charity or as a
private operating foundation, the Internal
Revenue Service will issue a ruling or de-
termination letter with the revised classi-
fication as to foundation status. Grantors
and contributors may thereafter rely upon
such ruling or determination letter as pro-
vided in section 1.509(a)–7 of the Income
Tax Regulations. It is not the practice of
the Service to announce such revised clas-
sification of foundation status in the Inter-
nal Revenue Bulletin.
Notice of Disposition of
Declaratory Judgment
Proceedings Under Section
7428
This announcement serves notice to
donors that on April 26, 2001, the United
States Tax Court entered a Decision ac-
cepting the agreement of the parties that
the organization described below is rec-
ognized as an organization described in
section 501(c)(3) of the Internal Revenue
Code of 1986 which is exempt from tax
under section 501(a) and is an organiza-
tion described in sections 509(a)(1) and
170(b)(1)(A)(iii).
Great Plains Health Alliance, Inc.
Phillipsburg, KS

2001–26 I.R.B.iJune 25, 2001
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:
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

June 25, 2001ii2001–26 I.R.B.
Numerical Finding List
1
Bulletins 2001–1 through 2001–25
Announcements:
2001–1, 2001–2 I.R.B. 277
2001–2, 2001–2 I.R.B. 277
2001–3, 2001–2 I.R.B. 278
2001–4, 2001–2 I.R.B. 286
2001–5, 2001–2 I.R.B. 286
2001–6, 2001–3 I.R.B. 357
2001–7, 2001–3 I.R.B. 357
2001–8, 2001–3 I.R.B. 357
2001–9, 2001–3 I.R.B. 357
2001–10, 2001–4 I.R.B. 431
2001–11, 2001–4 I.R.B. 432
2001–12, 2001–6 I.R.B. 526
2001–13, 2001–9 I.R.B. 752
2001–14, 2001–7 I.R.B. 648
2001–15, 2001–8 I.R.B. 715
2001–16, 2001–8 I.R.B. 715
2001–17, 2001–8 I.R.B. 716
2001–18, 2001–10 I.R.B. 791
2001–19, 2001–10 I.R.B. 791
2001–20, 2001–8 I.R.B. 716
2001–21, 2001–9 I.R.B. 752
2001–22, 2001–11 I.R.B. 895
2001–23, 2001–10 I.R.B. 791
2001–24, 2001–10 I.R.B. 793
2001–25, 2001–11 I.R.B. 895
2001–26, 2001–11 I.R.B. 896
2001–27, 2001–11 I.R.B. 897
2001–28, 2001–13 I.R.B. 975
2001–29, 2001–14 I.R.B. 1014
2001–30, 2001–15 I.R.B. 1065
2001–31, 2001–17 I.R.B. 1113
2001–32, 2001–17 I.R.B. 1113
2001–33, 2001–17 I.R.B. 1137
2001–34, 2001–16 I.R.B. 1087
2001–35, 2001–16 I.R.B. 1087
2001–36, 2001–16 I.R.B. 1089
2001–37, 2001–16 I.R.B. 1090
2001–38, 2001–17 I.R.B. 1138
2001–39, 2001–17 I.R.B. 1141
2001–40, 2001–17 I.R.B. 1141
2001–41, 2001–18 I.R.B. 1147
2001–42, 2001–18 I.R.B. 1147
2001–43, 2001–18 I.R.B. 1147
2001–44, 2001–18 I.R.B. 1148
2001–45, 2001–18 I.R.B. 1148
2001–46, 2001–19 I.R.B. 1165
2001–47, 2001–19 I.R.B. 1165
2001–48, 2001–19 I.R.B. 1168
2001–49, 2001–20 I.R.B. 1183
2001–50, 2001–20 I.R.B. 1184
2001–51, 2001–20 I.R.B. 1185
2001–52, 2001–20 I.R.B. 1186
2001–53, 2001–20 I.R.B. 1186
2001–54, 2001–21 I.R.B. 1284
2001–55, 2001–21 I.R.B. 1284
2001–56, 2001–21 I.R.B. 1286
2001–57, 2001–20 I.R.B. 1187
2001–58, 2001–22 I.R.B. 1295
2001–59, 2001–23 I.R.B. 1331
2001–60, 2001–21 I.R.B. 1287
2001–61, 2001–22 I.R.B. 1296
2001–62, 2001–24 I.R.B. 1337
2001–63, 2001–25 I.R.B. 1344
2001–64, 2001–25 I.R.B. 1344
2001–66, 2001–25 I.R.B. 1345
Court Decisions:
2069, 2001–21 I.R.B. 1191
Notices:
2001–1, 2001–2 I.R.B. 261
2001–2, 2001–2 I.R.B. 265
2001–3, 2001–2 I.R.B. 267
2001–4, 2001–2 I.R.B. 267
2001–5, 2001–3 I.R.B. 327
2001–6, 2001–3 I.R.B. 327
2001–7, 2001–4 I.R.B. 374
2001–8, 2001–4 I.R.B. 374
2001–9, 2001–4 I.R.B. 375
2001–10, 2001–5 I.R.B. 459
2001–11, 2001–5 I.R.B. 464
2001–12, 2001–3 I.R.B. 328
2001–13, 2001–6 I.R.B. 514
2001–14, 2001–6 I.R.B. 516
2001–15, 2001–7 I.R.B. 589
2001–16, 2001–9 I.R.B. 730
2001–17, 2001–9 I.R.B. 730
2001–18, 2001–9 I.R.B. 731
2001–19, 2001–10 I.R.B. 784
2001–20, 2001–11 I.R.B. 818
2001–21, 2001–11 I.R.B. 818
2001–22, 2001–12 I.R.B. 911
2001–23, 2001–12 I.R.B. 911
2001–24, 2001–12 I.R.B. 912
2001–25, 2001–13 I.R.B. 941
2001–26, 2001–13 I.R.B. 942
2001–27, 2001–13 I.R.B. 942
2001–28, 2001–13 I.R.B. 944
2001–29, 2001–14 I.R.B. 989
2001–30, 2001–14 I.R.B. 989
2001–31, 2001–17 I.R.B. 1093
2001–32, 2001–18 I.R.B. 1146
2001–33, 2001–19 I.R.B. 1155
2001–34, 2001–23 I.R.B. 1302
2001–35, 2001–23 I.R.B. 1314
2001–36, 2001–24 I.R.B. 1334
2001–37, 2001–25 I.R.B. 1340
2001–38, 2001–24 I.R.B. 1334
Proposed Regulations:
LR–230–76, 2001–13 I.R.B. 945
REG–209461–79, 2001–8 I.R.B. 712
REG–246256–96, 2001–8 I.R.B. 713
REG–251701–96, 2001–4 I.R.B. 396
REG–101520–97, 2001–15 I.R.B. 1057
REG–106030–98, 2001–11 I.R.B. 820
REG–106446–98, 2001–13 I.R.B. 945
REG–106542–98, 2001–5 I.R.B. 473
REG–121928–98, 2001–6 I.R.B. 520
REG–109481–99, 2001–13 I.R.B. 961
REG–111835–99, 2001–11 I.R.B. 834
REG–114998–99, 2001–14 I.R.B. 992
REG–115560–99, 2001–14 I.R.B. 993
REG–101739–00, 2001–14 I.R.B. 996
REG–103320–00, 2001–8 I.R.B. 714
REG–104683–00, 2001–4 I.R.B. 407
REG–104876–00, 2001–14 I.R.B. 998
REG–105801–00, 2001–13 I.R.B. 965
REG–105946–00, 2001–16 I.R.B. 1069
REG–106513–00, 2001–16 I.R.B. 1076
REG–106702–00, 2001–4 I.R.B. 424
REG–106791–00, 2001–6 I.R.B. 521
REG–106892–00, 2001–15 I.R.B. 1060
REG–107047–00, 2001–14 I.R.B. 1002
REG–107101–00, 2001–16 I.R.B. 1083
REG–107175–00, 2001–13 I.R.B. 971
Proposed Regulations—Continued:
REG–107176–00, 2001–4 I.R.B. 428
REG–107186–00, 2001–13 I.R.B. 973
REG–107566–00, 2001–3 I.R.B. 346
REG–110374–00, 2001–12 I.R.B. 915
REG–110659–00, 2001–12 I.R.B. 917
REG–114082–00, 2001–7 I.R.B. 629
REG–114083–00, 2001–7 I.R.B. 630
REG–114084–00, 2001–7 I.R.B. 633
REG–116468–00, 2001–6 I.R.B. 522
REG–119352–00, 2001–6 I.R.B. 525
REG–121109–00, 2001–15 I.R.B. 1064
REG–125237–00, 2001–12 I.R.B. 919
REG–126100–00, 2001–11 I.R.B. 862
REG–129608–00, 2001–14 I.R.B. 1011
REG–130477–00, 2001–11 I.R.B. 865
REG–130481–00, 2001–11 I.R.B. 865
REG–119436–01, 2001–20 I.R.B. 1183
Railroad Retirement Quarterly Rates:
2001–2, I.R.B. 258
2001–15, I.R.B. 1054
Revenue Procedures:
2001–1, 2001–1 I.R.B. 1
2001–2, 2001–1 I.R.B. 79
2001–3, 2001–1 I.R.B. 111
2001–4, 2001–1 I.R.B. 121
2001–5, 2001–1 I.R.B. 164
2001–6, 2001–1 I.R.B. 194
2001–7, 2001–1 I.R.B. 236
2001–8, 2001–1 I.R.B. 239
2001–9, 2001–3 I.R.B. 328
2001–10, 2001–2 I.R.B. 272
2001–11, 2001–2 I.R.B. 275
2001–12, 2001–3 I.R.B. 335
2001–13, 2001–3 I.R.B. 337
2001–14, 2001–3 I.R.B. 343
2001–15, 2001–5 I.R.B. 465
2001–16, 2001–4 I.R.B. 376
2001–17, 2001–7 I.R.B. 589
2001–18, 2001–8 I.R.B. 708
2001–19, 2001–9 I.R.B. 732
2001–20, 2001–9 I.R.B. 738
2001–21, 2001–9 I.R.B. 742
2001–22, 2001–9 I.R.B. 745
2001–23, 2001–10 I.R.B. 784
2001–24, 2001–10 I.R.B. 788
2001–25, 2001–12 I.R.B. 913
2001–26, 2001–17 I.R.B. 1093
2001–27, 2001–19 I.R.B. 1155
2001–28, 2001–19 I.R.B. 1156
2001–29, 2001–19 I.R.B. 1160
2001–30, 2001–19 I.R.B. 1163
2001–31, 2001–20 I.R.B. 1170
2001–32, 2001–21 I.R.B. 1197
2001–33, 2001–23 I.R.B. 1322
2001–34, 2001–22 I.R.B. 1293
2001–35, 2001–22 I.R.B. 1293
2001–36, 2001–23 I.R.B. 1326
2001–37, 2001–23 I.R.B. 1327
2001–38, 2001–24 I.R.B. 1335
Revenue Rulings:
2001–1, 2001–9 I.R.B. 726
2001–2, 2001–2 I.R.B. 255
2001–3, 2001–3 I.R.B. 319
2001–4, 2001–3 I.R.B. 295
2001–5, 2001–5 I.R.B. 451
2001–6, 2001–6 I.R.B. 491
1
A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 2000–27 through
2000–52 is in Internal Revenue Bulletin 2001–1,
dated January 2, 2001.

2001–26 I.R.B.iiiJune 25, 2001
Revenue Rulings—Continued:
2001–7, 2001–7 I.R.B. 541
2001–8, 2001–9 I.R.B. 726
2001–9, 2001–8 I.R.B. 652
2001–10, 2001–10 I.R.B. 755
2001–11, 2001–10 I.R.B. 780
2001–12, 2001–11 I.R.B. 811
2001–13, 2001–12 I.R.B. 898
2001–14, 2001–12 I.R.B. 898
2001–15, 2001–13 I.R.B. 922
2001–16, 2001–13 I.R.B. 936
2001–17, 2001–15 I.R.B. 1052
2001–18, 2001–17 I.R.B. 1092
2001–19, 2001–18 I.R.B. 1143
2001–20, 2001–18 I.R.B. 1143
2001–21, 2001–18 I.R.B. 1144
2001–22, 2001–19 I.R.B. 1152
2001–23, 2001–20 I.R.B. 1169
2001–24, 2001–22 I.R.B. 1290
2001–25, 2001–22 I.R.B. 1291
2001–26, 2001–23 I.R.B. 1297
2001–27, 2001–23 I.R.B. 1298
2001–28, 2001–25 I.R.B. 1338
Treasury Decisions:
8910, 2001–2 I.R.B. 258
8911, 2001–3 I.R.B. 321
8912, 2001–5 I.R.B. 452
8913, 2001–3 I.R.B. 300
8914, 2001–8 I.R.B. 653
8915, 2001–4 I.R.B. 359
8916, 2001–4 I.R.B. 360
8917, 2001–7 I.R.B. 538
8918, 2001–4 I.R.B. 372
8919, 2001–6 I.R.B. 505
8920, 2001–8 I.R.B. 654
8921, 2001–7 I.R.B. 532
8922, 2001–6 I.R.B. 508
8923, 2001–6 I.R.B. 485
8924, 2001–6 I.R.B. 489
8925, 2001–6 I.R.B. 496
8926, 2001–6 I.R.B. 492
8927, 2001–11 I.R.B. 807
8928, 2001–8 I.R.B. 685
8929, 2001–10 I.R.B. 756
8930, 2001–5 I.R.B. 433
8931, 2001–7 I.R.B. 542
8932, 2001–11 I.R.B. 813
8933, 2001–11 I.R.B. 794
8934, 2001–12 I.R.B. 904
8935, 2001–8 I.R.B. 702
8936, 2001–9 I.R.B. 720
8937, 2001–11 I.R.B. 806
8938, 2001–13 I.R.B. 929
8939, 2001–12 I.R.B. 899
8940, 2001–15 I.R.B. 1016
8941, 2001–14 I.R.B. 977
8942, 2001–13 I.R.B. 929
8943, 2001–15 I.R.B. 1054
8944, 2001–16 I.R.B. 1067
8945, 2001–23 I.R.B. 1300
8946, 2001–24 I.R.B. 1332

June 25, 2001iv2001–26 I.R.B.
Finding List of Current Actions on
Previously Published Items
1
Bulletins 2001–1 through 2001–25
Announcements:
98–99
Modified by
Ann. 2001–9, 2001–3 I.R.B. 357
99–79
Superseded by
Ann. 2001–3, 2001–2 I.R.B. 278
2000–21
Revised by
Ann. 2001–1, 2001-2 I.R.B. 277
2000–22
Revised by
Ann. 2001–1, 2001-2 I.R.B. 277
2000–23
Revised by
Ann. 2001–1, 2001-2 I.R.B. 277
2000–78
Obsoleted by
T.D. 8933, 2001–11 I.R.B. 794
2000–97
Corrected by
Ann. 2001–7, 2001–3 I.R.B. 357
Cumulative Bulletin:
1998–2
Corrected by
Ann. 2001–5, 2001–2 I.R.B. 286
Notices:
84–37
Modified by
Rev. Proc. 2001–1, 2001–1 I.R.B. 1
87–49
Modified by
Notice 2001–14, 2001–6 I.R.B. 516
94–3
Modified by
T.D. 8933, 2001–11 I.R.B. 794
96–13
Modified by
Rev. Proc. 2001–1, 2001–1 I.R.B. 1
97–19
Modified by
Rev. Proc. 2001–1, 2001–1 I.R.B. 1
98–39
Modified by
Notice 2001–9, 2001–4 I.R.B. 375
99–40
Modified by
Notice 2001–9, 2001–4 I.R.B. 375
99–53
Modified and superseded by
Notice 2001–7, 2001–4 I.R.B. 374
2000–21
Superseded by
Notice 2001–1, 2001–2 I.R.B. 261
2000–22
Modified and superseded by
Notice 2001–8, 2001–4 I.R.B. 374
Notices—Continued:
2000–26
Modified by
Notice 2001–22, 2001–12 I.R.B. 911
2000–33
Obsoleted by
T.D. 8945, 2001–23 I.R.B. 1300
2000–43
Extended by
Notice 2001–13, 2001–6 I.R.B. 514
Proposed Regulations:
EE–130–86
Partially withdrawn and amended by
REG–209461–79, 2001–8 I.R.B. 712
REG–106030–98
Corrected by
Ann. 2001–30, 2001–15 I.R.B. 1065
REG–106542–98
Corrected by
Ann. 2001–24, 2001–10 I.R.B. 793
REG–116733–98
Withdrawn by
Ann. 2001–11, 2001–4 I.R.B. 432
REG–105235–99
Corrected by
Ann. 2001–52, 2001–20 I.R.B. 1186
REG–116048–99
Withdrawn by
Ann. 2001–27, 2001–11 I.R.B. 897
REG–116050–99
Corrected by
Ann. 2001–51, 2001–20 I.R.B. 1185
REG–104683–00
Corrected by
Ann. 2001–42, 2001–18 I.R.B. 1147
REG–106702–00
Corrected by
Ann. 2001–28, 2001–13 I.R.B. 975
REG–110374–00
Corrected by
Ann. 2001–44, 2001–18 I.R.B. 1148
REG–126100–00
Corrected by
Ann. 2001–50, 2001–20 I.R.B. 1184
Revenue Procedures:
75–21
Modified and superseded by
Rev. Proc. 2001–28, 2001–19 I.R.B. 1156
75–28
Modified and superseded by
Rev. Proc. 2001–29, 2001–19 I.R.B. 1160
76–30
Modified and superseded by
Rev. Proc. 2001–28, 2001–19 I.R.B. 1156
79–48
Modified and superseded by
Rev. Proc. 2001–28, 2001–19 I.R.B. 1156
Rev. Proc. 2001–29, 2001–19 I.R.B. 1160
83–87
Superseded by
Rev. Proc. 2001–15, 2001–5 I.R.B. 465
Revenue Procedures—Continued:
90–18
Amplified and superseded by
Rev. Proc. 2001–18, 2001–8 I.R.B. 708
92–19
Superseded by
Rev. Proc. 2001–15, 2001–5 I.R.B. 465
96–15
Modified by
Ann. 2001–22, 2001–11 I.R.B. 895
96–17
Modified by
Rev. Proc. 2001–9, 2001–3 I.R.B. 328
97–25
Superseded by
Rev. Proc. 2001–31, 2001–20 I.R.B. 1170
99–18
Modified and superseded by
Rev. Proc. 2001–21, 2001–9 I.R.B. 742
99–47
Superseded by
Rev. Proc. 2001–16, 2001–4 I.R.B. 376
99–49
Modified and amplified by
Notice 2001–23, 2001–12 I.R.B. 911
Rev. Proc. 2001–10, 2001–2 I.R.B. 272
Rev. Proc. 2001–23, 2001–10 I.R.B. 784
Rev. Proc. 2001–24, 2001–10 I.R.B. 788
Rev. Proc. 2001–25, 2001–12 I.R.B. 913
Rev. Rul. 2001–4, 2001–3 I.R.B. 295
Rev. Rul. 2001–8, 2001–9 I.R.B. 726
2000–1
Superseded by
Rev. Proc. 2001–1, 2001–1 I.R.B. 1
2000–2
Superseded by
Rev. Proc. 2001–2, 2001–1 I.R.B. 79
2000–3
Superseded by
Rev. Proc. 2001–3, 2001–1 I.R.B. 111
2000–4
Superseded by
Rev. Proc. 2001–4, 2001–1 I.R.B. 121
2000–5
Superseded by
Rev. Proc. 2001–5, 2001–1 I.R.B. 164
2000–6
Superseded by
Rev. Proc. 2001–6, 2001–1 I.R.B. 194
2000–7
Superseded by
Rev. Proc. 2001–7, 2001–1 I.R.B. 236
2000–8
Superseded by
Rev. Proc. 2001–8, 2001–1 I.R.B. 239
2000–14
Supplemented by
Rev. Proc. 2001–27, 2001–19 I.R.B. 1155
2000–16
Modified and superseded by
Rev. Proc. 2001–17, 2001–7 I.R.B. 589
2000–21
Obsoleted by
Rev. Proc. 2001–35, 2001–22 I.R.B. 1293
1
A cumulative list of current actions on previously
published items in Internal Revenue Bulletins
2000–27 through 2000–52 is in Internal Revenue
Bulletin 2001–1, dated January 2, 2001.

2001–26 I.R.B.vJune 25, 2001
Revenue Procedures—Continued:
2000–22
Modified and superseded by
Rev. Proc. 2001–10, 2001–2 I.R.B. 272
2000–23
Superseded by
Rev. Proc. 2001–26, 2001–17 I.R.B. 1093
2000–25
Superseded by
Rev. Proc. 2001–32, 2001–21 I.R.B. 1197
2000–27
Modified by
Rev. Proc. 2001–6, 2001–1 I.R.B. 194
2000–46
Superseded by
Rev. Proc. 2001–3, 2001–1 I.R.B. 111
2000–47
Superseded by
Rev. Proc. 2001–3, 2001–1 I.R.B. 111
2001–3
Corrected by
Ann. 2001–25, 2001–11 I.R.B. 895
Section 5.01 revoked by
Rev. Proc. 2001–30, 2001–19 I.R.B. 1163
2001–8
Modified by
Rev. Proc. 2001–17, 2001–7 I.R.B. 589
2001–13
Clarified by
Notice 2001–12, 2001–3 I.R.B. 328
2001–26
Corrected by
Ann. 2001–59, 2001–23 I.R.B. 1331
2001–30
Modified by
Rev. Proc. 2001–34, 2001–22 I.R.B. 1293
Revenue Rulings:
55–747
Revoked by
Notice 2001–10, 2001–5 I.R.B. 459
64–328
Modified by
Notice 2001–10, 2001–5 I.R.B. 459
66–110
Modified by
Notice 2001–10, 2001–5 I.R.B. 459
71–52
Obsoleted by
Notice 2001–14, 2001–6 I.R.B. 516
85–30
Clarified by
Rev. Rul. 2001–8, 2001–9 I.R.B. 726
88–95
Clarified by
Rev. Rul. 2001–8, 2001–9 I.R.B. 726
92–19
Supplemented in part by
Rev. Rul. 2001–11, 2001–10 I.R.B. 780
2000–56
Corrected by
Ann. 2001–19, 2001–10 I.R.B. 791
2001–4
Modified by
Notice 2001–23, 2001–12 I.R.B. 911
Treasury Decisions:
7530
Removed by
T.D. 8938, 2001–13 I.R.B. 929
8757
Revised by
T.D. 8941, 2001–14 I.R.B. 977
8881
Corrected by
Ann. 2001–55, 2001–21 I.R.B. 1284
8889
Corrected by
Ann. 2001–4, 2001–2 I.R.B. 286
8912
Corrected by
Ann. 2001–40, 2001–17 I.R.B. 1141
8913
Corrected by
Ann. 2001–26, 2001–11 I.R.B. 896
8916
Corrected by
Ann. 2001–41, 2001–18 I.R.B. 1147
8921
Corrected by
Ann. 2001–43, 2001–18 I.R.B. 1147
8929
Corrected by
Ann. 2001–56, 2001–21 I.R.B. 1286
8931
Technically amended by
Ann. 2001–37, 2001–16 I.R.B. 1090
8933
Corrected by
Ann. 2001–31, 2001–17 I.R.B. 1113
8940
Corrected by
Ann. 2001–53, 2001–20 I.R.B. 1186

June 25, 20012001–26 I.R.B.
insert missing
children
Elisabeth Huster
and
Claudia Jaurequi

2001–26 I.R.B.June 25, 2001
insert
missing
children
Jennifer Douglas
and
Shanythia Greene

insert
missing
children
Guadalupe
Hernandez
and
Edith Henriquez
June 25, 20012001–26 I.R.B.

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