Internal Revenue Bulletin 2005-49 (PDF rendition): IRS Notices

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.

Bulletin No. 200
5-49
December 5, 2005
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.
INCOME TAX
Rev. Rul. 2005–75, page 1073.
CPI adjustment for below-market loans for 2006.The
amount that section 7872(g) of the Code permits a taxpayer
to lend to a qualified continuing care facility without incurring
imputed interest is published and adjusted for inflation for years
1987–2006. Rev. Rul. 2004–108 supplemented and super-
seded.
Rev. Rul.
2005–76, page 1072.
Section 12
74A – inflation adjusted numbers for 2006.
This ruli
ng provides the dollar amounts, increased by the 2006
inflatio
n adjustment, for section 1274A of the Code. Rev. Rul.
2004–107
supplemented and superseded.
Rev. Rul. 2005–77, page 1071.
Federal rates; adjusted federal rates; adjusted federal
long-term rate and the long-term exempt rate.For pur-
poses of sections 382, 642, 1274, 1288, and other sections
of the Code, tables set forth the rates for December 2005.
Notice 2005–83, page 1075.
This notice provides relief for certain health plans with non-cal-
endar year renewal dates that otherwise qualify as high-de-
ductible health plans (HDHPs), except that the plans provide
state-mandated benefits without regard to a deductible or with
a deductible below the minimum annual deductible specified in
section 223(c)(2) of the Code. Notice 2004–43 amplified.
Notice
2005–86, page 1075.
This not
ice provides guidance on the eligibility to contribute to a
Health
Savings Account (HSA) during the cafeteria plan grace
period
described in Notice 2005–42, 2005–23 I.R.B. 1204.
Rev. Ru
l. 2004–45 and Notice 2005–42 amplified.
Notice 2005–89, page 1077.
This notice provides that the Service will not treat a hotel, mo-
tel, or other establishment that otherwise satisfies the defini-
tion of “lodging facility” under section 856(d)(9) of the Code as
other than a “lodging facility” if it is used to provide temporary
housing to certain persons affected by Hurricane Katrina or
Hurricane Rita, provided certain recordkeeping requirements
are satisfied.
Rev. Proc. 2005–72, page 1078.
Insurance companies; loss reserves; discounting unpaid
losses.The loss payment patterns and discount factors are
set forth for the 2005 accident year. These factors will be used
to compute discounted unpaid losses under section 846 of the
Code.
Rev. Proc. 2005–73, page 1090.
Insurance companies; discounted estimated salvage re-
coverable.The salvage discount factors are set forth for the
2005 accident year. These factors will be used to compute
discounted estimated salvagerecoverable under section 832
of the Code.
Fi
nding Lists begin on page ii.

The IRS Mission
Provide America’s taxpayers top quality service by helping
them understand and meet their tax responsibilities and by
applying the tax law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, 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 compiled 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, mod-
ify, or amend any of those previously published in the Bulletin.
All published rulings apply retroactively unless otherwise indi-
cated. Procedures relating solely to matters of internal man-
agement 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 published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—19
86 Code.
This part i
ncludes rulings and decisions based on provisions of
the Intern
al Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B, Leg-
islation and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Sec-
retary (Enforcement).
Part IV
.—Items of General Interest.
This par
t includes notices of proposed rulemakings, disbar-
ment an
d suspension lists, and announcements.
The last 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 last Bulletin of each semiannual period.
The c
ontents 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.
December 5, 20052005–49 I.R.B.

Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
Section 42.—Low-Income
Housing Credit
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of December 2005. See Rev. Rul. 2005-77, page
1071.
Section 125.—Cafeteria
Plans
A notice provides guidance on the eligibility to
contribute to a Health Savings Account (HSA) dur-
ing the cafeteria plan grace period described in Notice
2005–42, 2005–23 I.R.B. 1204. See Notice 2005-86,
page 1075.
Section 223.—Health
Savings Accounts
A notice provides guidance on the eligibility to
contribute to a Health Savings Account (HSA) dur-
ing the cafeteria plan grace period described in Notice
2005–42, 2005–23 I.R.B. 1204. See Notice 2005-86,
page 1075.
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term rates
are set forth for the month of December 2005. See
Rev. Rul. 2005-77, page 1071.
Section 382.—Limitation
on Net Operating Loss
Carryforwards and Certain
Built-In Losses Following
Ownersh
ip Change
The adju
sted applicable federal long-term rate is
set fort
h for the month of December 2005. See Rev.
Rul. 20
05-77, page 1071.
Section 412.—Minimum
Funding Standards
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of December 2005. See Rev. Rul. 2005-77, page
1071.
Section 467.—Certain
Payments for the Use of
Property or Services
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of December 2005. See Rev. Rul. 2005-77, page
1071.
Section 468.—Special
Rules for Mining and Solid
Waste Reclamation and
Closing Costs
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of December 2005. See Rev. Rul. 2005-77, page
1071.
Section 482.—Allocation
of Income and Deductions
Among Taxpayers
Federal short-term, mid-term, and long-term rates
are set forth for the month of December 2005. See
Rev. Rul. 2005-77, page 1071.
Section 483.—Interest on
Certain Deferred Payments
26 CFR 1.483–1: Computation of interest on certain
deferred payments.
As defined by section 1274A, the definitions for
both “qualified debt instruments” and “cash method
debt instruments” have dollar ceilings on the stated
principal amount. The limits to the stated princi-
pal amount are adjusted for inflation for sales or ex-
changes occurring in the 2006 calendar year. See Rev.
Rul. 2005-76, page 1072.
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of December 2005. See Rev. Rul. 2005-77, page
1071.
Section 642.—Special
Rules for Credits and
Deductions
Federal short-term, mid-term, and long-term rates
are set forth for the month of December 2005. See
Rev. Rul. 2005-77, page 1071.
Section 807.—Rules for
Certain Reserves
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of December 2005. See Rev. Rul. 2005-77, page
1071.
Section 832.—Insurance
Company Taxable Income
26 CFR 1.832–4: Gross income.
The salvage discount factors are set forth for 2005.
These factors must be used to compute discounted
estimated salvage recoverable for purposes of section
832 of the Code. See Rev. Proc. 2005-73, page 1090.
Section 846.—Discounted
Unpaid Losses Defined
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of December 2005. See Rev. Rul. 2005-77, page
1071.
26 CFR 1.846–1: Application of discount factors.
The loss payment patterns and discount factors are
set forth for the 2005 accident year. These factors
will be used for computing discounted unpaid losses
under section 846 of the Code. See Rev. Proc. 2005-
72, page 1078.
26 CFR 1.846–1: Application of discount factors.
The salvage discount factors are set forth for 2005.
These factors must be used to compute discounted
estimated salvage recoverable for purposes of section
832 of the Code. See Rev. Proc. 2005-73, page 1090.
Section 1274.—Determi-
nation of Issue Price in the
Case of Certain Debt Instru-
ments Issued for Property
26 CFR 1.1274A–1: Special rules for certain trans-
actions where stated principal amount does not ex-
ceed $2,800,000.
As defined by section 1274A, the definitions for
both “qualified debt instruments” and “cash method
debt instruments” have dollar ceilings on the stated
principal amount. The limits to the stated princi-
pal amount are adjusted for inflation for sales or ex-
changes occurring in the 2006 calendar year. See Rev.
Rul. 2005-76, page 1072.
2005–49 I.R.B.1070December 5, 2005

(Also Sections 42, 280G, 382, 412, 467, 468, 482,
483, 642, 807, 846, 1288, 7520, 7872.)
Federal rates; adjusted federal rates;
adjusted federal long-term rate and the
long-term exempt rate.For purposes of
sections 382, 642, 1274, 1288, and other
sections of the Code, tables set forth the
rates for December 2005.
Rev. Rul. 2005–77
This revenue ruling provides various
prescribed rates for federal income tax
purposes for December 2005 (the current
month). Table 1 contains the short-term,
mid-term, and long-term applicable fed-
eral rates (AFR) for the current month
for purposes of section 1274(d) of the
Internal Revenue Code. Table 2 contains
the short-term, mid-term, and long-term
adjusted applicable federal rates (adjusted
AFR) for the current month for purposes
of section 1288(b). Table 3 sets forth the
adjusted federal long-term rate and the
long-term tax-exempt rate described in
section 382(f). Table 4 contains the ap-
propriate percentages for determining the
low-income housing credit described in
section 42(b)(2) for buildings placed in
service during the current month. Table 5
contains the federalrate for determining
the present value of an annuity, an interest
for life or for a term of years, or a remain-
der or a reversionary interest for purposes
of section 7520. Finally, Table 6 contains
the 2006 interest rate for sections 846 and
807.
REV. RUL. 20
05–77 TABLE 1
Applicable Federal Rates (AFR) for December 2005
Period for Compounding
AnnualSemiannua
l
QuarterlyMonthly
Short-term
AFR4.34%4.29%4.27%4.25%
110% AFR4.78%4.72%4.69%4.67%
120% AFR5.22%5.15%5.12%5.10%
130% AFR5.66%5.58%5.54%5.52%
Mid-ter
m
AFR4.52%4.47%4.45%4.43%
110% AF
R
4.98%4.92%4.89%4.87%
120% AFR5.43%5.36%5.32%5.30%
130% AFR5.89%5.81%5.77%5.74%
150% A
FR
6.82%6.71%6.65%6.62%
175% AFR7.97%7.82%7.75%7.70%
Long
-term
AFR4.79%4.73%4.70%4.68%
110%
AFR
5.27
%
5.20
%
5.17
%
5.14
%
120% AFR5.76%5.68%5.64%5.61%
130% AFR6.24%6.15%6.10%6.07%
REV. RUL. 2005–77 TABLE 2
Adjusted AFR for December 2005
Pe
riod for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term adjusted
AFR
2.98%2.96%2.95%2.94%
Mid-term adjusted AFR3.51%3.48%3.46%3.46%
Long-term adjusted
AFR
4.40%4.35%4.33%4.31%
December 5, 200510712005–49 I.R.B.

REV. RUL. 2005–
77 TABLE 3
Rates Under Section 382 for December 2005
Adjusted federal long-term rate for the current month4.40%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted
federal long-term rates for the current month and the prior two months.)4.40%
REV. RUL. 2005–77 TABLE 4
Appropriate Percentages Under Section 42(b)(2) for December 2005
Appropriate percentage for the 70% present value low-income housing credit8.08%
Appropriate percentage for the 30% present value low-income housing credit3.46%
REV. RUL. 2005–77 TABLE 5
Rate Under Section 7520 for December 2005
Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years,
or a remainder or reversionary interest5.4%
REV. RUL. 2005–77 TABLE 6
Applicable rate of interest for 2006 for purposes of sections 846 and 8073.98%
Section 1274A.—Special
Rules for Certain
Transactions Where Stated
Principal Amount Does Not
Exceed $2,800,000
(Also §§ 1274, 483; 1.1274A–1, 1.483–1.)
Section 1274A – inflation adjusted
numbers for 2006.This ruling provides
the dollar amounts, increased by the 2006
inflation adjustment, for section 1274A of
the Code. Rev. Rul. 2004–107 supple-
mented and superseded.
Rev. Rul. 2005–76
This revenue ruling provides the dollar
amounts, increased by the 2006 inflation
adjustment, for § 1274A of the Internal
Revenue Code.
BACKGROUND
In general, §§ 483 and 1274 determine
the principal amount of a debt instrument
given in consideration for the sale or ex-
change of nonpublicly traded property. In
addition, any interest on a debt instrument
subject to § 1274 is taken into account un-
der the original issue discount provisions
of the Code. Section 1274A, however,
modifies the rules under §§ 483 and 1274
for certain types of debt instruments.
In the case of a “qualified debt instru-
ment,” the discount rate used for purposes
of §§ 483 and 1274 may not exceed 9 per-
cent, compounded semiannually. Section
1274A(b) defines a qualified debt instru-
ment as any debt instrument given in con-
sideration for the sale or exchange of prop-
erty (other than new § 38 property within
the meaning of § 48(b), as in effect on the
day before the date of enactment of the
Revenue Reconciliation Act of 1990) if the
stated principal amount of the instrument
does not exceed the amount specified in
§ 1274A(b). For debt instruments arising
out of sales or exchanges before January 1,
1990, this amount is $2,800,000.
In the case of a “cash method debt in-
strument,” as defined in § 1274A(c), the
borrower and lender may elect to use the
cash receipts and disbursements method
of accounting. In particular, for any cash
method debt instrument, § 1274 does not
apply, and interest on the instrument is ac-
counted for by both the borrower and the
lender under the cash method of account-
ing. A cash method debt instrument is
a qualified debt instrument that meets the
following additional requirements: (A) In
the case of instruments arising out of sales
or exchanges before January 1, 1990, the
stated principal amount does not exceed
$2,000,000; (B) the lender does not use an
accrual method of accounting and is not a
dealer with respect tothe property sold or
exchanged; (C) § 1274 would have applied
to the debt instrument but for an election
under § 1274A(c); and (D) an election un-
der § 1274A(c) is jointly made with respect
to the debt instrument by the borrower and
lender. Section 1.1274A–1(c)(1) of the In-
come Tax Regulations provides rules con-
cerning the time for, and manner of, mak-
ing this election.
Section 1274A(d)(2) provides that, for
any debt instrument arising out of a sale
or exchange during any calendar year
after 1989, the dollar amounts stated in
§ 1274A(b) and § 1274A(c)(2)(A) are
increased by the inflation adjustment for
the calendar year. Any increase due to
the inflation adjustment is rounded to the
nearest multiple of $100 (or, if the increase
is a multiple of $50 and not of $100, the
increase is increased to the nearest mul-
tiple of $100). The inflation adjustment
2005–49 I.R.B.1072December 5, 2005

for any calendar year is the percentage (if
any) by which the CPI for the preceding
calendar year exceeds the CPI for calendar
year 1988. Section 1274A(d)(2)(B) de-
fines the CPI for any calendar year as the
average of the Consumer Price Index as of
the close of the 12-month period ending
on September 30 of that calendar year.
INFLATION-ADJUSTED AMOUNTS
For debt instruments arising out of sales
or exchanges after December 31, 1989, the
inflation-adjusted amounts under § 1274A
areshowninTable1.
Rev. Rul. 2005–76 Table 1
Inflation-Adjusted Amounts Under § 1274A
Calendar Year
of Sale
or Exchange
1274A(b) Amount
(qualified debt
instrument)
1274A(c)(2)(A) Amount
(cash method debt
instrument)
1990
$2,933,200$2,095,100
1991
$3,079,600$2,199,700
1992
$3,234,900$2,310,600
1993
$3,332,400$2,380,300
1994
$3,433,500$2,452,500
1995
$3,523,600$2,516,900
1996
$3,622,500$2,587,500
1997
$3,723,800$2,659,900
1998
$3,823,100$2,730,800
1999
$3,885,500$2,775,400
2000
$3,960,100$2,828,700
2001
$4,085,900$2,918,500
2002
$4,217,500$3,012,500
2003
$4,280,800$3,057,700
2004
$4,381,300$3,129,500
2005
$4,483,000$3,202,100
2006
$4,630,300$3,307,400
Note:These inflation adjustments were computed using the All-Urban, Consumer Price Index, 1982–1984 base, published
by the Bureau of Labor Statistics.
EFFECT ON OTHER DOCUMENTS
Rev. Rul. 2004–107, 2004–2 C.B. 852,
is supplemented and superseded.
DRAFTING INFORMATION
The author of this revenue ruling is
David B. Silber of the Office of the Asso-
ciate Chief Counsel (Financial Institutions
and Products). For further information
regarding this revenue ruling, please con-
tact Mr. Silber at (202) 622–3930 (not a
toll-free call).
Section 1288.—Treatment
of Original Issue Discount
on Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of December 2005. See Rev. Rul. 2005-77, page
1071.
S
ection 7520.—Valuation
T
ables
T
he adjusted applicable federal short-term, mid-
t
erm, and long-term rates are set forth for the month
o
f December 2005. See Rev. Rul. 2005-77, page
1071.
Section 7872.—Treatment
of Loans With Below-Market
Interest Rates
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of December 2005. See Rev. Rul. 2005-77, page
1071.
CPI adjustment for below-market
loans for 2006.The amount that section
7872(g) of the Code permits a taxpayer
to lend to a qualified continuing care fa-
cility without incurring imputed interest
is published and adjusted for inflation for
years 1987–2006. Rev. Rul. 2004–108
supplemented and superseded.
Rev. Rul. 2005–75
This revenue ruling publishes the
amount that § 7872(g) of the Internal
Revenue Code permits a taxpayer to lend
to a qualifying continuing care facility
without incurring imputed interest. The
amount is adjusted for inflation for the
years after 1986.
Section 7872 generally treats loans
bearing a below-market interest rate as if
they bore interest at the market rate.
Section 7872(g)(1) provides that, in
general, § 7872 does not apply for any
calendar year to any below-market loan
made by a lender to a qualified continu-
ing care facility pursuant to a continuing
December 5, 200510732005–49 I.R.B.

care contract if the lender (or the lender’s
spouse) attains age 65 before the close of
the year.
Section 7872(g)(2) provides that, in
the case of loans made after October 11,
1985, and before 1987, § 7872(g)(1) ap-
plies only to the extent that the aggregate
outstanding amount of any loan to which
§ 7872(g) applies (determined without
regard to § 7872(g)(2)), when added to the
aggregate outstanding amount of all other
previous loans between the lender (or the
lender’s spouse) and any qualified contin-
uing care facility to which § 7872(g)(1)
applies, does not exceed $90,000.
Section 7872(g)(5) provides that, for
loans made during any calendar year af-
ter 1986 to which § 7872(g)(1) applies, the
$90,000 limit specified in § 7872(g)(2) is
increased by an inflation adjustment. The
inflation adjustment for any calendar year
is the percentage (if any) by which the
Consumer Price Index (CPI) for the pre-
ceding calendar year exceeds the CPI for
calendar year 1985. Section 7872(g)(5)
states that the CPI for any calendar year is
the average of the CPI as of the close of the
12-month period ending on September 30
of that calendar year.
Table 1 sets forth the amount specified
in § 7872(g)(2) of the Code. The amount
is increased by the inflation adjustment for
the years 1987–2006.
Rev. Rul. 2005–75 TABLE 1
Limit under § 7872(g)(2)
YearAmount
Before 1987
$ 90,000
1987
$ 92,200
1988
$ 94,800
1989
$ 98,800
1990
$103,500
1991
$108,600
1992
$114,100
1993
$117,500
1994
$121,100
1995
$124,300
1996
$127,800
1997
$131,
300
1998
$134,800
1999
$137,000
2000
$139,700
2001
$144,100
2002
$148,800
200
3
$15
1,000
2004
$154,500
2005
$158,100
2006
$163,300
Note:These inflation adjustments were computed using the All-Urban, Consumer Price Index 1982–1984 base, published
by the Bureau of Labor Statistics.
EFFECT ON OTHER DOCUMENTS
Rev. Rul. 2004–108, 2004–2 C.B. 853,
is supplemented and superseded.
DRAFTING INFORMATION
The author of this revenue ruling is
David B. Silber of the Office of the Asso-
ciate Chief Counsel (Financial Institutions
and Products). For further information
regarding this revenue ruling, please con-
tact Mr. Silber at (202) 622–3930 (not a
toll-free call).
2005–49 I.R.B.1074December 5, 2005

Part III. Administrative, Procedural, and Miscellaneous
Health Savings Accounts -
Guidance on State Mandates
Notice 2005–83
PURPOSE
This notice provides relief for certain
health plans with non-calendar year re-
newal dates that otherwise qualify as high-
deductible health plans (HDHPs), except
that the plans provide state-mandated ben-
efits without regard to a deductible or with
a deductible below the minimum annual
deductible specified in § 223(c)(2) of the
Internal Revenue Code.
BACKGROUND AND APPLICATION
Some states require that health plans
provide certain benefits without regard to
a deductible or with a deductible below
the minimum annual deductible specified
in § 223(c)(2) (e.g., first-dollar cover-
age or coverage with a low deductible).
These health plans are not HDHPs un-
der § 223(c)(2) and individuals covered
under these health plans are generally
not eligible to contribute to Health Sav-
ings Accounts (HSAs). Notice 2004–43,
2004–2 C.B. 10, provides transition relief
that treats health plans as meeting the re-
quirement of § 223(c)(2) when the sole
reason the plans are not HDHPs is because
of certain state-mandated benefits. For
months before January 1, 2006, otherwise
eligible individuals covered under these
health plans will be treated as eligible in-
dividuals for purposes of § 223(c)(1) and
may contribute to an HSA. The transition
period provided in Notice 2004–43 cov-
ers months before January 1, 2006, for
state-mandated requirements in effect on
January 1, 2004.
Generally, a health plan may not re-
duce existing benefits before the plan’s
renewal date. Thus, even though a state
may amend its laws before January 1,
2006, to authorize HDHPs that comply
with § 223(c)(2), non-calendar year plans
may still fail to qualify as HDHPs after
January 1, 2006, because existing benefits
cannot be changed until the next renewal
date. For example, a state amends its laws
to authorize HDHPs, effective November
1, 2005. A health planwith a renewal date
of July 1, 2005, is required to retain the
state-mandated low-deductible coverage
for the plan year July 1, 2005, through
June 30, 2006, because the benefits can
only be modified on the renewal date. As
a result, although the state has amended
its statute, the health plan will fail to be an
HDHP for months after January 1, 2006
(i.e., for the months of January through
June, 2006).
Therefore, additional transitional relief
is appropriate for non-calendar year health
plans. Accordingly, the transition relief
in Notice 2004–43 is amplified to pro-
vide that for any coverage period of twelve
months or less beginning before January 1,
2006, a health plan that otherwise quali-
fies as an HDHP as defined in § 223(c)(2),
except that it complied on its most recent
renewal date before January 1, 2006, with
state-mandated requirements (in effect on
January 1, 2004) to provide certain bene-
fits without regard to a deductible or with
a deductible below the minimum annual
deductible specified in § 223(c)(2), will
be treated as an HDHP. In no event will
the additional transitional relief provided
in this notice extend beyond the earlier of
the health plan’s next renewal date or De-
cember 31, 2006.
EFFECT ON OTHER DOCUMENTS
Notice 2004–43, 2004–2 C.B. 10, is
amplified.
DRAFTING INFORMATION
The principal author of this notice is
Elizabeth Purcell of the Office of Division
Counsel/Associate Chief Counsel (Tax Ex-
empt and Government Entities). For fur-
ther information regarding this notice, con-
tact Ms. Purcell at (202) 622–6080 (not a
toll-free call).
Health Savings Account
Eligibility During A Cafeteria
Plan Grace Period
Notice 2005–86
PURPOSE
This notice provides guidance on eligi-
bility to contribute to a Health Savings Ac-
count (HSA) during a cafeteria plan grace
period as described in Notice 2005–42,
2005–23 I.R.B. 1204. As discussed below,
an individual participating in a health flex-
ible spending arrangement (health FSA)
who is covered by the grace period is gen-
erally not eligible to contribute to an HSA
until the first day of the first month fol-
lowing the end of the grace period, even
if the participant’s health FSA has no un-
used benefits at the end of the prior cafe-
teria plan year. This notice, however, pro-
vides guidance on how an employer may
amend the cafeteria plan document to en-
able a health FSA participant to become
HSA eligible during the grace period.
BACKGROUND
Cafeteria Plans
Section 125(a) states that, in general, no
amount is included in the gross income of
a participant in a cafeteria plan solely be-
cause, under the plan, the participant may
choose among the benefits of the plan.
Section 125(d) defines a cafeteria plan
as a written plan under which all partici-
pants are employees, and the participants
may choose among two or more benefits
consisting of cash and qualified benefits.
“Qualified benefits” mean any benefit
which, with the application of § 125(a), is
not includible in the gross income of the
employee by reason of an express provi-
sion of Chapter 1 of the Internal Revenue
Code, including employer-provided ac-
cident and health coverage under §§ 106
and 105(b). A high deductible health
plan (HDHP) as defined in § 223(c)(2)(A)
can be employer-provided accident and
health coverage. A health FSA, which
pays or reimburses certain § 213(d) med-
ical expenses (other than health insurance
or long-term care services or insurance),
is also employer-provided accident and
health coverage. The term “qualified
medical expenses” as used in this notice,
means expenses which may be paid or
reimbursed under a health FSA.
Cafeteria Plan Grace Period
Notice 2005–42, 2005–23 I.R.B. 1204,
modifies the application of the rule pro-
hibiting deferred compensation under a
cafeteria plan (i.e., the “use-it-or-lose-it”
December 5, 200510752005–49 I.R.B.

rule). The notice permits a cafeteria plan
to be amended, at the employer’s option,
to provide a grace period immediately fol-
lowing the end of each plan year, during
which an individual who incurs expenses
for a qualified benefit during the grace
period, may be paid or reimbursed for
those expenses from the unused benefits
or contributions relating to that benefit. A
plan providing a grace period is required to
provide the grace period to all participants
who are covered on the last day of the
plan year (including participants whose
coverage is extended to the last day of the
plan year through COBRA continuation
coverage). The grace period remains in
effect for the entire period even though the
participant may terminate employment on
or before the last day of the grace period.
But an employer may limit the availability
of the grace period to only certain cafeteria
plan benefits and not others. For exam-
ple, a cafeteria plan offering both a health
FSA and a dependent care FSA may limit
the grace period to the health FSA. The
grace period must not extend beyond the
fifteenth day of the third calendar month
after the end of the immediately preceding
plan year to which it relates, but may be
adopted for a shorter period.
Interaction Between HSAs and Health
FSAs
Section 223(a) allows a deduction for
contributions to an HSA for an “eligible in-
dividual” for any month during the taxable
year. An “eligible individual” is defined
in § 223(c)(1)(A) and means, in general,
with respect to any month, any individual
who is covered under an HDHP on the first
day of such month and is not, while cov-
ered under an HDHP, “covered under any
health plan which is not a high-deductible
health plan, and which provides coverage
for any benefit which is covered under the
high-deductible health plan.”
In addition to coverage under an HDHP,
§ 223(c)(1)(B) provides that an eligible in-
dividual may have disregarded coverage,
including “permitted insurance” and “per-
mitted coverage.” Section 223(c)(2)(C)
also provides a safe harbor for the ab-
sence of a preventive care deductible. See
Notice 2004–23, 2004–1 C.B. 725. There-
fore, under § 223, an individual who is
eligible to contribute to an HSA must be
covered by a health plan that is an HDHP,
and may also have permitted insurance,
permitted coverage and preventive care,
but no other coverage. A health FSA that
reimburses all qualified § 213(d) medi-
cal expenses without other restrictions is
a health plan that constitutes other cov-
erage. Consequently, an individual who
is covered by a health FSA that pays or
reimburses all qualified medical expenses
is not an eligible individual for purposes
of making contributions to an HSA. This
result is the same even if the individual is
covered by a health FSA sponsored by a
spouse’s employer.
However, as described in Rev. Rul.
2004–45, 2004–1 C.B. 971, an individ-
ual who is otherwise eligible for an HSA
may be covered under specific types of
health FSAs and remain eligible to con-
tribute to an HSA. One arrangement is a
limited-purpose health FSA, which pays or
reimburses expenses only for preventive
care and “permitted coverage” (e.g.,dental
care and vision care). Another HSA-com-
patible arrangement is a post-deductible
health FSA, which pays or reimburses pre-
ventive care and for other qualified med-
ical expenses only if incurred after the
minimum annual deductible for the HDHP
under § 223(c)(2)(A) is satisfied. This
means that qualified medical expenses in-
curred before the HDHP deductible is sat-
isfied may not be reimbursed by a post-de-
ductible FSA even after the HDHP de-
ductible has been satisfied. To summa-
rize, an otherwise HSA eligible individ-
ual will remain eligible if covered under a
limited-purpose health FSA or a post-de-
ductible FSA, or a combination of both.
OPTIONS AVAILABLE TO AN
EMPLOYER
An employer may adopt either of the
following two options, which will affect
participants’ HSA eligibility during the
cafeteria plan grace period:
(1) General Purpose Health FSA During
Grace Period
Employer amends the cafeteria plan
document to provide a grace period but
takes no other action with respect to the
general purpose health FSA. Because a
health FSA that pays or reimburses all
qualified medical expenses constitutes
impermissible “other coverage” for HSA
eligibility purposes, an individual who
participated in the health FSA (or a spouse
whose medical expenses are eligible for
reimbursement under the health FSA) for
the immediately preceding cafeteria plan
year and who is covered by the grace
period, is not eligible to contribute to an
HSA until the first day of the first month
following the end of the grace period. For
example, if the health FSA grace period
ends March 15, 2006, an individual who
did not elect coverage by a general health
FSA or other disqualifying coverage for
2006 is HSA eligible on April 1, 2006, and
may contribute 9/12ths of the 2006 HSA
contribution limit. The result is the same
even if a participant’s health FSA has no
unused contributions remaining at the end
of the immediately preceding cafeteria
plan year.
(2) Mandatory Conversion from Health
FSA to HSA-compatible Health FSA for
All Participants
Employer amends the cafeteria plan
document to provide for both a grace
period and a mandatory conversion of
the general purpose health FSA to a lim-
ited-purpose or post-deductible FSA (or
combined limited-purpose and post-de-
ductible health FSA) during the grace
period. The amendments do not permit
an individual participant to elect between
an HSA-compatible FSA or an FSA that
is not HSA-compatible. The amendments
apply to the entire grace period and to all
participants in the health FSA who are
covered by the grace period. The amend-
ments must satisfy all other requirements
of Notice 2005–42. Coverage of these
participants by the HSA-compatible FSA
during the grace period does not disqual-
ify participants who are otherwise eligible
individuals from contributing to an HSA
during the grace period.
TRANSITION RELIEF
For cafeteria plan years ending before
June 5, 2006, an individual participating
in a general purpose health FSA that pro-
vides coverage during a grace period will
be eligible to contribute to an HSA during
the grace period if the following require-
ments are met: (1) If not for the coverage
under a general purpose health FSA de-
scribed in clause (2), the individual would
be an “eligible individual” as defined in
§ 223(c)(1)(A) during the grace period (in
2005–49 I.R.B.1076December 5, 2005

general, is covered under an HDHP and is
not, while covered under an HDHP, cov-
ered under any impermissible other health
coverage); and (2) Either (A) the individ-
ual’s (and the individual’s spouse’s) gen-
eral purpose health FSA has no unused
contributions or benefits remaining at the
end of the immediately preceding cafete-
ria plan year, or (B) in the case of an indi-
vidual who is not covered during the grace
period under a general purpose health FSA
maintained by the employer of the indi-
vidual’s spouse, the individual’s employer
amends its cafeteriaplan document to pro-
vide that the grace period does not pro-
vide coverage to an individual who elects
HDHP coverage.
EFFECT ON OTHER DOCUMENTS
Notice 2005–42 and Rev.Rul.
2004–45 are amplified.
DRAFTING INFORMATION
The principal author of this notice
is Shoshanna Tanner of the Office of
Division Counsel/Associate Chief Coun-
sel (Tax Exempt and Government Enti-
ties). For further information regarding
this notice, contact Ms. Tanner at (202)
622–6080 (not a toll-free call).
Temporary Relief for Certain
REITs and Taxable REIT
Subsidiaries that Provide
Accommodations to Persons
Affected by Hurricanes
Katrina and Rita
Notice 2005–89
The Internal Revenue Service will not
treat a hotel, motel, or other establishment
that otherwise satisfies the definition of
a “lodging facility” under § 856(d)(9) of
the Internal Revenue Code as other than a
“lodging facility” if it is used to provide
temporary housing to certain persons af-
fected by Hurricane Katrina or Hurricane
Rita, provided the recordkeeping require-
ments of this notice are satisfied.
BACKGROUND
On August 28, 2005, and August 29,
2005, the President issued major disas-
ter declarations for the states of Florida,
Alabama, Louisiana, and Mississippi as a
result of Hurricane Katrina. On September
24, 2005, the President declared major dis-
asters for the states of Louisiana and Texas
as a result of Hurricane Rita. These decla-
rations were made pursuant to the Robert
T. Stafford Disaster Relief and Emergency
Assistance Act, 42 U.S.C. 5121–5206.
Subsequently, the Federal Emergency
Management Agency (FEMA) designated
certain counties and parishes as being eli-
gible for individual assistance (or individ-
ual and public assistance). For purposes
of this notice, the term “covered disaster
area” means the counties and parishes
designatedbyFEMAasbeingeligiblefor
individual assistance (or individual and
public assistance) as a result of Hurricane
Katrina and/or Hurricane Rita. For a list
of counties and parishes designated by
FEMA as being eligible for individual
assistance (or individual and public assis-
tance) as a result of Hurricane Katrina, see
Notice 2005–73, 2005–42 I.R.B. 723. For
a list of counties and parishes designated
by FEMA as being eligible for individual
assistance (or individual and public assis-
tance) as a result of Hurricane Rita, see
IR–2005–110 (September 26, 2005).
Certain real estate investment trusts
(REITs) that own lodging facilities have
expressed concern that extended stays
at those facilities by persons affected
by these disasters may cause the REITs
to fail to satisfy the income tests under
§§ 856(c)(2) and (c)(3). Although rents
from real property generally are treated as
qualifying income for purposes of these
tests, amounts received or accrued from a
corporation in which the REIT owns stock
are subject to special rules. Under one of
these rules, if a REIT leases an interest in
real property that is a qualified lodging fa-
cility to a taxable REIT subsidiary (TRS)
of that REIT, then the lease payments may
qualify as rents from real property if the
property is operatedon behalf of the TRS
by a person who is an eligible independent
contractor. Section 856(d)(9)(D)(ii) pro-
vides that a “lodging facility” is a hotel,
motel, or other establishment more than
one-half of the dwelling units in which are
used on a transient basis. Section 856 and
the regulations thereunder do not define
the term “transient basis”.
TRANSIENT BASIS REQUIREMENT
For purposes of § 856(d)(9)(D)(ii), the
Service will treat a dwelling unit within a
lodging facility as beingusedonatransient
basis during any period in which the unit
is used to provide shelter to (a) an indi-
vidual whose principal residence for pur-
poses of § 1033(h)(4) on August 28, 2005,
was located in a covered disaster area and
who has been displaced because the resi-
dence has been destroyed or damaged as
a result of Hurricane Katrina or Hurricane
Rita (a displaced resident); (b) employees
of business entities whose principal place
of business is located in a covered disas-
ter area who have been relocated to other
areas where the business entities have job
openings (a displaced employee); or (c) a
worker assisting in relief activities in the
covered disaster area, whether or not the
worker is affiliatedwith a recognized gov-
ernment or philanthropic organization (a
relief worker).
A TRS that is the lessee of a hotel, mo-
tel, or other establishment and that seeks
to rely on this notice with respect to the
provision of shelter to a displaced resident,
displaced employee, or relief worker for
any period ending on or after November
29, 2005, must keep records indicating the
dates on which shelter was provided and
the name and address of the displaced resi-
dent, displaced employee, or relief worker.
In addition, (a) with respect to a displaced
employee, the TRS must keep records in-
dicating the individual’s employer, and (b)
with respect to any relief worker, the TRS
must keep records indicating the name of
the individual’s employer or sponsoring
organization and the nature of the relief ac-
tivities undertaken during the individual’s
stay.
Thisnoticewillbeeffectiveforsix(6)
months from its effective date.
EFFECTIVE DATE
This notice is effective August 28, 2005
(the date of the President’s first major dis-
aster declaration resulting from Hurricane
Katrina).
PAPERWORK REDUCTION ACT
The collections of information in the
notice have been reviewed and approved
by the Office of Management and Bud-
get (OMB) in accordance with the Paper-
December 5, 200510772005–49 I.R.B.

work Reduction Act (44 U.S.C. 3507) un-
der control number 1545–1977.
An agency may not conduct or sponsor,
and a person is not required to respond
to, a collection of information unless the
collection of information displays a valid
OMB control number.
The collections of information in the
notice are in the section of this notice en-
titled “Transient Basis Requirement”. The
collections of information are required for
compliance with § 856(d)(9)(D). The col-
lections of information are required to ob-
tain a benefit. The likely respondents are
corporations.
The estimated total annual reporting
burden is 500 hours.
The estimated annual burden per re-
spondent varies from 25–75 hours, de-
pending on the circumstances, with an
average of 50 hours. The estimated num-
ber of respondents is 10.
Books or records relating to a collection
of information must be retained as long
as their contents may become material to
the administration of the internal revenue
law. Generally, tax returns and tax return
information are confidential, as required
by 26 U.S.C. 6103.
DRAFTING INFORMATION
The principal author of this notice is
Jonathan D. Silver of the Office of Asso-
ciate Chief Counsel (Financial Institutions
& Products). For further information re-
garding this notice, contact Mr. Silver at
(202) 622–3930 (not a toll-free call).
26 CFR 601.201: Rulings and determination letters.
(Also Part I, Sections 846; 1.846–1.)
Rev. Proc. 2005–72
SECTION 1. PURPOSE
This revenue procedure prescribes the
loss payment patterns and discount factors
for the 2005 accident year. These factors
will be used for computing discounted un-
paid losses under § 846 of the Internal Rev-
enue Code.SeeRev. Proc. 2003–17,
2003–1 C.B. 427, for background concern-
ing the loss payment patterns and applica-
tion of the discount factors.
SEC. 2. SCOPE
This revenue procedure applies to any
taxpayer that is required to discount its un-
paid losses under § 846 for a line of busi-
ness using discount factors published by
the Secretary.
SEC. 3. TABLES OF DISCOUNT
FACTORS
.01 The following tables present sepa-
rately for each line of business the discount
factors under § 846 for accident year 2005.
All the discount factors presented in this
section were determined using the appli-
cable interest rate under § 846(c) for 2005,
which is 4.44 percent, and by assuming all
loss payments occur in the middle of the
calendar year.
.02 If the groupings of individual
lines of business on the annual state-
ment change, taxpayers must discount the
unpaid losses on the affected lines of busi-
ness in accordance with the discounting
patterns that would have applied to those
unpaid losses based on their classification
on the 2000 annual statement.SeeRev.
Proc. 2003–17, 2003–1 C.B. 427, section
2, for additional background on discount-
ing under section 846 and the use of the
Secretary’s tables.
.03 Section V of Notice 88–100,
1988–2 C.B. 439, sets forth a composite
method for computing discounted unpaid
losses for accident years that are not sep-
arately reported on the annual statement.
The tables separately provide discount
factors for taxpayers who elect to use the
composite method of section V of Notice
88–100.SeeRev. Proc. 2002–74, 2002–2
C.B. 980.
.04 Section 2.03(4) of Rev. Proc.
2003–17 requested comments as to
whether a methodology should be adopted
to smooth the raw payment data and thus
produce a more stable pattern of discount
factors. This issue will be addressed in the
new determination year, which is 2007.
Accordingly, taxpayers may still submit
comments that should include a reference
toRev. Proc. 2005–72on this issue to the
following address:
CC:PA:LPD:PR (Rev. Proc. 2005–72),
room 5203, Internal Revenue Service,
POB 7604, Ben Franklin Station,
Washington, DC 20044. Comments may
be hand delivered between the hours of
8a.m.and4p.m. toCC:PA:LPD(Rev.
Proc. 2005–72), Courier’s Desk, Internal
Revenue Service, 1111 Constitution
Avenue, NW, Washington, DC 20224.
Alternatively, e-mail comments to
Notice.Comments@irscounsel.treas.gov.
All comments will be available for public
inspection and copying.
.05 Tables.
2005–49 I.R.B.1078December 5, 2005

Tables of Factors to be Used to Discount
Unpaid Losses Incurred in
Accident Year 2005
(Interest rate: 4.44 percent)
Accident and Health
(Other Than Disability Income or Credit Disability Insurance)
Taxpayers that do not use the composite method of Notice 88–100 should use 97.8513 percent to discount unpaid losses incurred
in this line of business in the 2005 accident year and that are outstanding at theend of the 2005 and later taxable years.
Taxpayers that use the composite method of Notice 88–100 should use 97.8513 percent to discount all unpaid losses in this line of
business that are outstanding at the end of the 2005 taxable year.
Auto Physical Damage
Tax Year
Estimated
Cumulative
Losses
Paid
(%)
Estimated
Losses Paid
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discounted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
200589.646889.646810.353210.111397.6638
200699.684510.03770.31550.302295.7713
Taxpayers that do not use the composite method of Notice 88–100 should use the following factor to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
2007 and later years0.15780.15780.154497.8513
Taxpayers
that use the composite method of Notice 88–100 should use 97.8513 percent to discount unpaid losses incurred in this
line of bu
siness in 2005 and prior years and that are outstanding at the end of the 2007 taxable year.
Commercial Auto/Truck Liability/Medical
Tax Year
Estimated
Cumulative
Losses
Paid
(%)
Estimated
Losses Paid
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discounted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
200528.824428.824471.175665.396591.8806
200654.987126.162645.012941.563092.3357
200772.803917.816827.196125.200492.6616
200885.057212.253314.942813.796992.3312
200991.62766.57048.37247.694891.9064
201094.95143.32395.04864.639691.8992
201197.045
3
2.09382.95472.705891.574
4
201298.15741.11211.84261.689491.6838
201398.73700.57961.26301.172192.7985
201499.10700.37000.89300.846094.7324
December 5, 200510792005–49 I.R.B.

Commercial Auto/Truck Liability/Medical
Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
20150.37000.52300.505496.6342
2016 and later years0.37000.15300.149797.8513
Taxpayers tha
t use the composite method of Notice 88–100 should use 96.8695 percent to discount unpaid losses incurred in this
line of busine
ss in 2005 and prior years and that are outstanding at the end of the 2015 taxable year.
Composite
Tax Year
Estimated
Cumulative
Losses
Paid
(%)
Estimated
Losses Paid
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discounted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
200540.998540.998559.001553.242090.2384
200665.843924.845434.156130.214988.4613
200777.502311.658322.497719.642187.3071
200884.62217.119815.377913.238086.0849
200990.24555.62349.75458.078982.8227
201092.27802.03257.72206.360582.3688
201194.39742.11955.60264.476979.9089
201295.25260.85524.74743.801780.0811
201396.27921.02663.72082.921478.5162
201496.43230.15313.56772.894681.1355
Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
20150.15313.41452.866783.9550
20160.15313.26142.837487.001
2
20170.15313.10832.806990.3057
20180.15312.95512.775193.9070
2019 and later years0.15312.80202.741897.8513
Taxpayers that use the composite method of Notice 88–100 shoulduse 88.8907 percent to discount unpaid losses incurred in this
line of business in 2005 and prior years and that are outstanding at the end of the 2015 taxable year.
Fidelity/Surety
Tax Year
Estimated
Cumulative
Losses
Paid
(%)
Estimated
Losses Paid
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discounted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
200538.332838.332861.667257.810793.7463
200658.848520.515641.151539.411495.7713
Tax
payers that do not use the composite method of Notice 88–100 should use the following factor to discount unpaid losses
inc
urred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
2007 and later years20.575820.575820.133697.8513
Taxpayers that use the composite method of Notice 88–100 shoulduse 97.8513 percent to discount unpaid losses incurred in this
line of business in 2005 and prior years and that are outstanding at the end of the 2007 taxable year.
2005–49 I.R.B.1080December 5, 2005

Financial Guaranty/Mortgage Guaranty
Tax Year
Estimated
Cumulative
Losses
Paid
(%)
Estimated
Losses Paid
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discounted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
20054.07234.072395.927790.222694.0527
200640.763936.691659.236156.731295.7713
Taxpayers that do not use the composite method of Notice 88–100 should use the following factor to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
2007 and later
years
29.618029.618028.981697.8513
Taxpayers that use the composite method of Notice 88–100 shoulduse 97.8513 percent to discount unpaid losses incurred in this
line of business in 2005 and prior years and that are outstanding at the end of the 2007 taxable year.
International (Composite)
Tax Year
Estimated
Cumulative
Losses
Paid
(%)
Estimated
Losses Paid
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discounted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
200540.998540.998559.001553.242090.2384
200665.843924.845434.156130.214988.4613
200777.502311.658322.497719.642187.3071
200884.62217.119815.377913.238086.0849
200990.24555.62349.75458.078982.8227
201092.27802.03257.72206.360582.3688
201194.39742.11955.60264.476979.9089
201295.25260.85524.74743.801780.0811
201396.27921.02663.72082.921478.5162
201496.43230.15313.56772.894681.1355
Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
20150.15313.41452.866783.9550
20160.15313.26142.837487.0012
20170.15313.10832.806990.3057
20180.153
1
2.955
1
2.775
1
93.90
70
2019 and later0.15312.80202.741897.8513
Taxpayers that use the composite method of Notice 88–100 shoulduse 88.8907 percent to discount unpaid losses incurred in this
line of business in 2005 and prior years and that are outstanding at the end of the 2015 taxable year.
December 5, 200510812005–49 I.R.B.

Medical Malpractice — Claims-Made
Tax Year
Estimated
Cumulative
Losses
Paid
(%)
Estimated
Losses Paid
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discounted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
20057.34477.344792.655382.523989.0655
200629.019121.674470.980964.037690.2180
200753.310824.291746.689242.055790.0759
200869.151715.840930.848327.734389.9053
200982.098112.946417.901915.735087.8955
201086.39954.301413.600512.037788.5095
201189.71113.311610.28899.187989.2991
201292.46882.75777.53126.777689.9934
201394.51632.04755.48374.986090.9248
201495.76351.24714.23653.932992.8323
Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
20151.24712.98942.833094.7672
20161.24711.74221.684296.6692
2017 and later years1.24710.49510.484597.8513
Taxpayers that use the composite method of Notice 88–100 shoulduse 95.5661 percent to discount unpaid losses incurred in this
line of business in 2005 and prior years and that are outstanding at the end of the 2015 taxable year.
Medica
l Malpractice — Occurrence
Tax Year
Estimated
Cumulative
Losses
Paid
(%)
Estimated
Losses Paid
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discounted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
20050.83160.831699.168483.108283.8051
20067.45736.625792.542780.027086.4758
200723.557516.100276.442567.126587.8130
200841.006217.448758.993852.275188.61
11
200955.583214.577044.416839.699089.3782
201068.941313.358131.058727.810289.5407
201178.20959.268221.790519.573289.8245
201282.87274.663217.127315.676691.5303
201386.31783.445113.682212.851993.9319
201
4
91.08
34
4.76
56
8.91
66
8.55
23
95.
9147
Taxpayers that do not use the composite method of Notice 88–100 should use the following factor to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
2015 and later years4.76564.15104.061897.8513
Ta
xpayers that use the composite method of Notice 88–100 should use 97.8513 percent to discount unpaid losses incurred in this
li
ne of business in 2005 and prior years and that are outstanding at the end of the 2015 taxable year.
2005–49 I.R.B.1082December 5, 2005

Miscellaneous Casualty
Tax Year
Estimated
Cumulative
Losses
Paid
(%)
Estimated
Losses Paid
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discounted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
200579.779079.779020.221019.475496.3125
200694.941715.16275.05834.844495.7713
Taxpayers that do not use the composite method of Notice 88–100 should use the following factor to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
2007 and later
years
2.52922.52922.474897.8513
Taxpayers that use the composite method of Notice 88–100 shoulduse 97.8513 percent to discount unpaid losses incurred in this
line of business in 2005 and prior years and that are outstanding at the end of the 2007 taxable year.
Multiple Peril Lines
(Homeowners/Farmowners, Commercial Multiple Peril, and Special Liability
(Ocean Marine, Aircraft (All Perils), Boiler and Machinery))
Tax Year
Estimated
Cumulative
Losses
Paid
(%)
Estimated
Losses Paid
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discounted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
200559.744559.744540.255537.144592.2719
200681.034721.290218.965317.036089.8274
200787.33256.297812.667511.356389.6494
200891.06593.73348.93418.045290.0503
200995.17814.11224.82194.199987.1002
201095.76050.58244.23953.791189.4249
201197.05391.29332.94612.637789.5320
201297.64410.59032.35592.151691.3303
201398.70371.05961.29631.164389.8184
201498.6217-0.08211.37831.299994.3059
Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
20150.52260.85580.823596.2318
2016 and later years0.52260.33320.326097.8513
Taxpayers that use the composite method of Notice 88–100 shoulduse 96.6358 percent to discount unpaid losses incurred in this
line of business in 2005 and prior years and that are outstanding at the end of the 2015 taxable year.
December 5, 200510832005–49 I.R.B.

Other (Including Credit)
Tax Year
Estimated
Cumulative
Losses
Paid
(%)
Estimated
Losses Paid
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discounted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
200569.172969.172930.827129.624496.0986
200691.216822.04398.78328.411895.7713
Taxpayers that do not use the composite method of Notice 88–100 should use the following factor to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
2007 and later
years
4.39164.39164.297397.8513
Taxpayers that use the composite method of Notice 88–100 shoulduse 97.8513 percent to discount unpaid losses incurred in this
line of business in 2005 and prior years and that are outstanding at the end of the 2007 taxable year.
Other Liability — Claims-Made
Tax Year
Estimated
Cumulative
Losses
Paid
(%)
Estimated
Losses Paid
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discounted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
200514.961814.961885.038274.365687.4496
200636.211321.249463.788755.951387.7135
200754.287618.076345.712439.962387.4211
200864.21639.928835.783731.589988.2801
200973.27329.056926.726823.736788.8123
201080.57487.301619.425217.328689.2072
201187.62007.045212.380010.898288.0304
201289.91552.295510.08459.036189.6042
201393.39463.47916.60545.881889.0459
201494.61701.22235.38304.893890.9113
Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
20151.22234.16073.861992.8183
20161.22232.93832.784194.7528
20171.22231.71601.658696.6546
2018 a
nd later years
1.222
3
0.493
6
0.483
0
97.85
13
Taxpayers that use the composite method of Notice 88–100 shoulduse 94.1292 percent to discount unpaid losses incurred in this
line of business in 2005 and prior years and that are outstanding at the end of the 2015 taxable year.
2005–49 I.R.B.1084December 5, 2005

Other Liability — Occurrence
Tax Year
Estimated
Cumulative
Losses
Paid
(%)
Estimated
Losses Paid
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discounted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
200519.113319.113380.886768.631184.8484
200636.443417.330163.556653.967784.9128
200752.164815.721547.835240.297284.2417
200863.238311.073436.761730.769883.7006
200972.07808.839727.922023.102182.7380
201075.90213.824124.097920.219883.9068
201182.93057.028417.069513.934881.6357
201285.14412.213614.855912.291382.7368
201389.30064.156510.69948.589380.2780
201489.98980.689210.01028.266382.5786
Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
20150.68929.32107.929085.0657
20160.68928.63187.576787.7764
20170.68927.94267.208790.7606
20180.68927.25336.824494.0867
2019 and
later years
0.68926.56416.423197.8513
Taxpayers that use the composite method of Notice 88–100 shoulduse 88.8152 percent to discount unpaid losses incurred in this
line of business in 2005 and prior years and that are outstanding at the end of the 2015 taxable year.
Private Passenger Auto Liability/Medical
Tax Yea
r
Estim
ated
Cumul
ative
Losses
Paid
(%)
Estim
ated
Losses
Paid
Each Ye
ar
(%)
Unpai
d
Losses
at
Year En
d
(%)
Disco
unted
Unpai
d
Losses
at
Year En
d
(%)
Discou
nt
Factor
s
(%)
200543.192643.192656.807453.178693.6121
200672.200829.008227.799225.894693.1486
200784.56
32
12.362515.436814.410493.35
10
200891.93167.36848.06847.520093.2034
200995.87293.94134.12713.826192.7060
201097.78041.90752.21962.046592.2040
201198.79571.01531.20431.099991.3257
201299.24910.45350.75090.685391.2646
201
3
99.
5195
0.27
03
0.48
05
0.43
94
91.
4469
201499.63530.11590.36470.340593.3821
Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
December 5, 200510852005–49 I.R.B.

Private Passenger Auto Liability/Medical
20150.11590.24880.237395.3548
20160.11590.13300.129497.3165
2017 and later years0.11590.01710.016797.8513
Taxpayers that use the composite method of Notice 88–100 shoulduse 96.0257 percent to discount unpaid losses incurred in this
line of business in 2005 and prior years and that are outstanding at the end of the 2015 taxable year.
Products Liability — Claims-Made
Tax Year
Estimated
Cumulative
Losses
Paid
(%)
Estimated
Losses Paid
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discounted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
20056.58046.580493.419679.005084.5700
200626.718320.137973.281761.932784.5131
200743.183416.465256.816647.855884.2286
200843.92090.737556.079149.226987.7812
200954.380610.459745.619440.723289.2673
201078.363023.982421.637018.022383.2938
201182.86434.501317.135714.222382.9982
201268.2184-14.645931.781629.821393.8320
201379.158210.939920.841819.965395.7947
201489.696310.538110.303710.082397.8513
Taxpayers that do not use the composite method of Notice 88–100 should use the following factor to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
2015 and later years97.8513
Taxpay
ers that use the composite method of Notice 88–100 should use 97.1286 percent to discount unpaid losses incurred in this
line of
business in 2005 and prior years and that are outstanding at the end of the 2015 taxable year.
Products Liability — Occurrence
Tax Year
Estimated
Cumulative
Losses
Paid
(%)
Estimated
Losses Paid
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discounted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
20059.41989.419890.58
02
75.24
56
83.07
07
200620.584511.164779.415567.176684.5888
200736.780716.196263.219353.607484.7959
200855.597418.816744.402636.757682.7827
200966.623811.026333.376227.121281.2591
201077.263610.639922.736417.451976.7576
201
1
79.18
88
1.92
51
20.
8112
16.
2593
78.
1278
201283.68164.492816.318412.389875.9253
201385.55071.869114.449311.029776.3341
201485.72910.178414.270911.337179.4424
Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
2005–49 I.R.B.1086December 5, 2005

Products Liability — Occurrence
20150.178414.092511.658282.7263
20160.178413.914111.993586.1968
20170.178413.735712.343789.8658
20180.178413.557312.709493.7461
2019 and later years0.178413.378913.091497.8513
Taxpayers that use the composite method of Notice 88–100 shoulduse 86.9679 percent to discount unpaid losses incurred in this
line of business in 2005 and prior years and that are outstanding at the end of the 2015 taxable year.
Reinsurance A (Nonproportional Assumed Property)
Tax Year
Estimated
Cumulative
Losses
Paid
(%)
Estimated
Losses Paid
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discounted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
200525.057125.057174.942968.970092.0300
200652.040226.983147.959844.456792.6956
200782.470930.430717.529115.331687.4636
200885.63873.167814.361312.774988.9539
200992.72287.08407.27726.102583.8577
201091.8604-0.86248.13967.254889.1294
201196.50164.64123.49842.833881.0020
201296.1872-0.31433.81283.280986.0493
201397.62061.43332.37941.961782.4450
201497.84190.22142.15811.822684.4552
Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
20150.22141.93671.677386.6060
20160.22141.71541.525688.9357
20170.22141.49401.367191.5049
20180.22141.27271.201694.4149
2019 and later years0.22141.05131.028797.8513
Taxpayers that use the composite method of Notice 88–100 shoulduse 89.0524 percent to discount unpaid losses incurred in this
line of business in 2005 and prior years and that are outstanding at the end of the 2015 taxable year.
Reinsurance B (Nonproportional Assumed Liability)
Tax Year
Estimated
Cumulative
Losses
Paid
(%)
Estimated
Losses Paid
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discounted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
20058.92238.922391.077775.008582.3566
200627.361818.439572.638259.494581.9052
200744.575817.214055.424244.544080.3692
200853.87819.302346.121937.015280.2551
200960.88967.011539.110431.493280.5238
201069.73278.843030.267323.854278.8118
December 5, 200510872005–49 I.R.B.

Reinsurance B (Nonproportional Assumed Liability)
201176.62926.896523.370817.865476.4433
201279.40302.773820.597015.823976.8263
201383.89364.490616.106411.937374.1151
201480.1707-3.722919.829316.271982.0601
Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
20151.180518.648715.787984.6595
20161.180517.468215.282587.4873
20171.180516.287714.754690.5872
20181.180515.107214.203294.0165
2019 and la
ter years
1.180513.926613.627497.8513
Taxpayers that use the composite method of Notice 88–100 shoulduse 87.9189 percent to discount unpaid losses incurred in this
line of business in 2005 and prior years and that are outstanding at the end of the 2015 taxable year.
Reinsurance C (Nonproportional Assumed Financial Lines)
Tax Year
Estimat
ed
Cumulat
ive
Losses
Paid
(%)
Estimat
ed
Losses Pa
id
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discoun
ted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
200517.119517.119582.880573.719788.9470
200646.659029.539553.341046.804787.7462
200767.713521.054532.286527.366084.7599
200878.137910.424421.862117.927782.0037
200989.734611.596710.26546.872366.9470
201092.12682.39217.87324.732860.1128
201189.7323-2.394510.26777.390071.9733
201290.04600.31379.95407.397574.3171
201394.88
67
4.84075.11332.779054.34
81
201486.7041-8.182713.295911.264784.7228
Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
20151.427711.868310.305886.8351
20161.427710.44069.304489.1173
20171.42779.01298.258491.6292
20
18
1.
4277
7.5
852
7.1
661
94
.4744
2019 and later years1.42776.15756.025297.8513
Taxpayers that use the composite method of Notice 88–100 shoulduse 89.1998 percent to discount unpaid losses incurred in this
line of business in 2005 and prior years and that are outstanding at the end of the 2015 taxable year.
2005–49 I.R.B.1088December 5, 2005

Special Property
(Fire, Allied Lines, Inland Marine, Earthquake, Glass, Burglary and Theft)
Tax Year
Estimated
Cumulative
Losses
Paid
(%)
Estimated
Losses Paid
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discounted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
200562.932062.932037.068035.563895.9420
200688.495025.563111.505011.018595.7713
Taxpayers that do not use the composite method of Notice 88–100 should use the following factor to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
2007 and later
years
5.75255.75255.628997.8513
Taxpayers that use the composite method of Notice 88–100 shoulduse 97.8513 percent to discount unpaid losses incurred in this
line of business in 2005 and prior years and that are outstanding at the end of the 2007 taxable year.
Workers’ Compensation
Tax Year
Estimated
Cumulative
Losses
Paid
(%)
Estimated
Losses Paid
Each Year
(%)
Unpaid
Losses at
Year End
(%)
Discounted
Unpaid
Losses at
Year End
(%)
Discount
Factors
(%)
200528.248928.248971.751163.499588.4998
200657.873929.624942.126136.043585.5608
200771.299913.426028.700123.922983.3549
200877.75846.458522.241618.384882.6595
200981.93014.171718.069914.937882.6666
201083.77391.843716.226113.716884.5350
201186.53502.761113.465011.504085.4365
201288.43671.901711.563310.071487.0975
201389.59261.155910.40749.337289.7172
201491.64412.05158.35597.655391.6150
Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses
incurred in this line of business in the 2005 accident year and that are outstanding at the end of the tax year shown.
20152.05156.30455.898793.5633
20162.05154.25304.064195.5573
20172.05152.20162.148097.5677
2018 a
nd later years
2.051
5
0.150
1
0.146
9
97.85
13
Taxpayers that use the composite method of Notice 88–100 shoulduse 95.7822 percent to discount unpaid losses incurred in this
line of business in 2005 and prior years and that are outstanding at the end of the 2015 taxable year.
DRAFTING INFORMATION
The p
rincipal author of this revenue
proc
edure is Katherine A. Hossofsky of
the Office of Associate Chief Counsel
(Financial Institutions & Products). For
further information regarding this revenue
procedure, contact Ms. Hossofsky at (202)
622–8435 (not a toll-free call).
December 5, 200510892005–49 I.R.B.

26 CFR 601.201: Rulings and determination letters.
(Also Part I, Sections 832, 846; 1.832–4, 1.846–1.)
Rev. Proc. 2005–73
SECTION 1. PURPOSE
This revenue p
rocedure prescribes the
salvage disco
unt factors for the 2005 acci-
dent year. Th
ese factors must be used to
compute disc
ounted estimated salvage re-
coverable un
der § 832 of the Internal Rev-
enue Code.
SEC. 2. BACKGROUND
Section 832(b)(5)(A) requires that all
estimated salvage recoverable (including
that which cannot be treated as an asset
for state accounting purposes) be taken
into account in computing the deduction
for losses incurred. Under § 832(b)(5)(A),
paid losses are to be reduced by salvage
and reinsurance recovered during the tax-
able year. This amount is adjusted to re-
flect changes in discounted unpaid losses
on nonlife insurance contracts and in un-
paid losses on life insurance contracts.
An adjustment is then made to reflect any
changes in discounted estimated salvage
recoverable and in reinsurance recover-
able.
Pursuant to § 832(b), the amount of es-
timated salvage is determined on a dis-
counted basis in accordance with proce-
dures established by the Secretary.
SEC. 3. SCOPE
This revenue procedure applies to any
taxpayer that is required to discount esti-
mated salvage recoverable under § 832.
SEC. 4. APPLICATION
.01 The following tables present sepa-
rately for each line of business the discount
factors under § 832 for the 2005 accident
year. All the discount factors presented
in this section were determined using the
applicable interest rate under § 846(c) for
2005, which is 4.44 percent, and by as-
suming all estimated salvage is recovered
in the middle of each calendar year.See
Rev. Proc. 2003–18, 2003–1 C.B. 439, for
background regarding the tables.
.02 These tables must be used by tax-
payers irrespective of whether they elected
to discount unpaid losses using their own
historical experience under § 846.
.03 Section V of Notice 88–100,
1988–2 C.B. 439, provides a composite
discount factor to be used in determining
the discounted unpaid losses for accident
years that are not separately reported on
the NAIC Annual Statement. The tables
separately provide discount factors for
taxpayers who elect to use the composite
method. Rev. Proc. 2002–74, 2002–2
C.B. 980, clarifies that for certain insur-
ance companies subject to tax under § 831
the composite method for discounting un-
paid losses set forth in Notice 88–100,
section V, 1988–2 C.B. 439, is permitted
but not required. This revenue procedure
further provides alternative methods for
computing discounted unpaid losses that
are permitted for insurance companies not
using the composite method, and sets forth
a procedure for insurance companies to
obtain automatic consent of the Commis-
sioner to change to one of the methods
described in Rev. Proc. 2002–74.
.04 Tables.
Tables of Factors to be Used to
Discount Salvage Recoverable
With Respect to Losses Incurred in
Accident Year 2005
(Interest rate: 4.44 percent)
Accident and Health (Other Than
Disability Income or Credit Disability
Insurance)
Taxpayers that do not use the compos-
ite method of Notice 88–100 should use
97.8513 percent to discount salvage re-
coverable with respect to losses incurred
in this line of business in the 2005 acci-
dent year as of the end of the 2005 and
later taxable years.
Taxpayers that use the composite
method of Notice 88–100 should use
97.8513 percent to discount all salvage
recoverable in this line of business as of
the end of the 2005 taxable year.
Auto Physical Damage
Tax Year
Discount
Factors
(%)
200596.8175
200695.7713
Taxpayers tha
t do not use the compos-
ite method of
Notice 88–100 should use
the followin
g factor to discount salvage
recoverable
as of the end of the tax year
shownwithre
spect to losses incurred in
this line of
business in the 2005 accident
year.
2007 and later
years
97.8513
Taxpayers that use the composite
method of Notice 88–100 should use
97.8513 percent to discount salvage
recoverable as of the end of the 2007
taxable year with respect to losses in-
curred in this line of business in 2005
and prior years.
Commerc
ial Auto/Truck
Liabili
ty/Medical
Tax Year
Discount
Factors
(%)
200591.3239
200691.0477
200790.8320
200891.3071
200991.80
90
201091.2746
201192.4705
201293.5064
201393.7878
201495.8004
2005–49 I.R.B.1090December 5, 2005

Commercial Auto/Truck
Liability/Medical
Taxpayers that do not use the compos-
ite method of Notice 88–100 should use
the following factor to discount salvage
recoverable as of the end of the tax year
shown with respect to losses incurred in
this line of business in the 2005 accident
year.
2015 and later
years
97.8513
Taxpayers that use the composite
method of Notice 88–100 should use
97.8513 percent to discount salvage
recoverable as of the end of the 2015
taxable year with respect to losses in-
curred in this line of business in 2005
and prior years.
Composite
Tax Year
Discount
Factors
(%)
200591.2231
200689.9591
200789.4423
200888.8551
200987.7165
201087.7929
201187.5509
201287.51
59
201387.6545
201489.4906
Taxp
ayers that do not use the compos-
ite m
ethod of Notice 88–100 should use
the
following factors to discount salvage
rec
overable as of the end of the tax year
sho
wn with respect to losses incurred in
thi
s line of business in the 2005 accident
yea
r.
201591.3750
201693.3052
2
017
9
5.2703
201897.2162
2019 and later
years
97.8513
Composite
Taxpayers that use the composite
method of Notice 88–100 should use
92.9728 percent to discount salvage
recoverable as of the end of the 2015
taxable year with respect to losses in-
curred in this line of business in 2005
and prior years.
Fidelity/Surety
Tax Year
Discount
Factors
(%)
200593.6793
200695.7713
Taxpayers that do not use the compos-
ite method of Notice 88–100 should use
the following factor to discount salvage
recoverable as of the end of the tax year
shown with respect to losses incurred in
this line of business in the 2005 accident
year.
2007 and
later
years
97.8513
Taxpayers that use the composite
method of Notice 88–100 should use
97.8513 percent to discount salvage
recoverable as of the end of the 2007
taxable year with respect to losses in-
curred in this line of business in 2005
and prior years.
Financial Guaranty/Mortgage
Guaranty
Tax Ye
ar
Disc
ount
Facto
rs
(%)
200595.0705
200695.7713
Financial Guaranty/Mortgage
Guaranty
Taxpayers that do not use the compos-
ite method of Notice 88–100 should use
the following factor to discount salvage
recoverable as of the end of the tax year
shown with respect to losses incurred in
this line of business in the 2005 accident
year.
2007 and later
years
97.8513
Taxpayers that use the composite
method of Notice 88–100 should use
97.8513 percent to discount salvage
recoverable as of the end of the 2007
taxable year with respect to losses in-
curred in this line of business in 2005
and prior years.
International (Composite)
Tax Year
Discount
Factors
(%)
200591.2231
200689.9591
200789.4423
200888.8551
200987.7165
201087.7929
201187.5509
201287.51
59
201387.6545
201489.4906
Taxp
ayers that do not use the compos-
ite m
ethod of Notice 88–100 should use
the
following factors to discount salvage
rec
overable as of the end of the tax year
sho
wn with respect to losses incurred in
thi
s line of business in the 2005 accident
yea
r.
201591.3750
201693.3052
2
017
9
5.2703
201897.2162
2019 and later
years
97.8513
December 5, 200510912005–49 I.R.B.

International (Composite)
Taxpayers that use the composite
method of Notice 88–100 should use
92.9728 percent to discount salvage
recoverable as of the end of the 2015
taxable year with respect to losses in-
curred in this line of business in 2005
and prior years.
Medical Malpractice —
Claims-Made
Tax Year
Discount
Factors
(%)
200586.4755
200681.7167
200786.5261
200884.1162
200985.1368
201079.5241
201189.5664
201292.5368
201396.0623
201497.851
3
Taxpayers that do not use the compos-
ite method of Notice 88–100 should use
the following factor to discount salvage
recoverable as of the end of the tax year
shown with respect to losses incurred in
this line of business in the 2005 accident
year.
2015 and later
years
97.8513
Tax
payers that use the composite
met
hod of Notice 88–100 should use
97.
8513 percent to discount salvage
rec
overable as of the end of the 2015
tax
able year with respect to losses in-
cur
red in this line of business in 2005
an
d prior years.
Medical Malpractice — Occurrence
Tax Year
Discount
Factors
(%)
200582.3660
200683.5715
200787.2656
200888.7913
200976.0729
201086.2799
201191.5010
201294.5994
201396.3703
201497.8513
Taxpayers that do not use the compos-
ite method of Notice 88–100 should use
the following factor to discount salvage
recoverable as of the end of the tax year
shown with respect to losses incurred in
this line of business in the 2005 accident
year.
2015 and
later
years
97.8513
Taxpayers that use the composite
method of Notice 88–100 should use
97.8513 percent to discount salvage
recoverable as of the end of the 2015
taxable year with respect to losses in-
curred in this line of business in 2005
and prior years.
Miscellaneous Casualty
Tax Y
ear
Disc
ount
Fact
ors
(%)
200596.3339
200695.7713
Taxpayers that do not use the compos-
ite method of Notice 88–100 should use
the following factor to discount salvage
recoverable as of the end of the tax year
shown with respect to losses incurred in
this line of business in the 2005 accident
year.
Miscellaneous Casualty
2007 and later
years
97.8513
Taxpayers that use the composite
method of Notice 88–100 should use
97.8513 percent to discount salvage
recoverable as of the end of the 2007
taxable year with respect to losses in-
curred in this line of business in 2005
and prior years.
Multiple Peril Lines (Homeown-
ers/Farmowners, Commercial
Multiple Peril, and Special Liability
(Ocean Marine, Aircraft (All Perils),
Boiler and Machinery))
Tax Year
Discount
Factors
(%)
200592.1974
200690.4717
200791.2273
200890.9380
200990.5278
201091.7899
201191.8465
201292.0455
201393.6189
201495.6204
Taxpayers that do not use the compos-
ite method of Notice 88–100 should use
the following factors to discount salvage
recoverable as of the end of the tax year
shown with respect to losses incurred in
this line of business in the 2005 accident
year.
201
5
97.
6492
2016 and later
years
97.8513
Taxpayers that use the composite
method of Notice 88–100 should use
97.6503 percent to discount salvage
recoverable as of the end of the 2015
taxable year with respect to losses in-
curred in this line of business in 2005
and prior years.
2005–49 I.R.B.1092December 5, 2005

Other (Including Credit)
Tax Year
Discount
Factors
(%)
200596.5291
200695.7713
Taxpayers tha
t do not use the compos-
ite method of
Notice 88–100 should use
the followin
g factor to discount salvage
recoverable
as of the end of the tax year
shown with re
spect to losses incurred in
this line of
business in the 2005 accident
year.
2007 and later
years
97.8513
Taxpayers that use the composite
method of Notice 88–100 should use
97.8513 percent to discount salvage
recoverable as of the end of the 2007
taxable year with respect to losses in-
curred in this line of business in 2005
and prior years.
Other Li
ability — Claims-Made
Tax Year
Discount
Factors
(%)
200590.7061
200681.3335
200767.4471
200888.0410
200984.43
92
201083.6931
201189.9416
201293.4492
201390.2612
201492.1610
Taxpayers that do not use the compos-
ite method of Notice 88–100 should use
the following factors to discount salvage
recoverable as of the end of the tax year
shown with respect to losses incurred in
this line of business in the 2005 accident
year.
Other Liability — Claims-Made
201594.1004
201696.0538
2017 and later
years
97.8513
Taxpayers that use the composite
method of Notice 88–100 should use
95.1292 percent to discount salvage
recoverable as of the end of the 2015
taxable year with respect to losses in-
curred in this line of business in 2005
and prior years.
Other Liability — Occurrence
Tax Year
Discount
Factors
(%)
200585.5304
200686.9478
200788.0380
200884.7457
200988.1991
201090.6498
201191.0248
201293.0642
201394.3646
201496.28
45
Taxpayers that do not use the compos-
ite method of Notice 88–100 should use
the following factor to discount salvage
recoverable as of the end of the tax year
shown with respect to losses incurred in
this line of business in the 2005 accident
year.
2015 and later
years
97.8513
Ta
xpayers that use the composite
me
thod of Notice 88–100 should use
97
.8513 percent to discount salvage
re
coverable as of the end of the 2015
ta
xable year with respect to losses in-
c
urred in this line of business in 2005
a
nd prior years.
Private Passenger Auto
Liability/Medical
Tax Year
Discount
Factors
(%)
200594.1806
200693.9873
200793.7150
200892.9128
200992.6982
201091.6917
201191.6408
201291.7062
201392.8870
201494.8239
Taxpayers that do not use the compos-
ite method of Notice 88–100 should use
the following factors to discount salvage
recoverable as of the end of the tax year
shown with respect to losses incurred in
this line of business in the 2005 accident
year.
201596.726
9
2016 and later
years
97.8513
Taxpayers that use the composite
method of Notice 88–100 should use
96.9284 percent to discount salvage
recoverable as of the end of the 2015
taxable year with respect to losses in-
curred in this line of business in 2005
and prior years.
December 5, 200510932005–49 I.R.B.

Products Liability — Claims-Made
Tax Year
Discount
Factors
(%)
200586.9346
200686.9867
200788.6095
200814.1032
200980.6321
201086.8941
201191.3609
201295.4486
201330.7119
201495.8584
Taxpayers that do not use the compos-
ite method of Notice 88–100 should use
the following factor to discount salvage
recoverable as of the end of the tax year
shown with respect to losses incurred in
this line of business in the 2005 accident
year.
2015 and
later
years
97.8513
Taxpayers that use the composite
method of Notice 88–100 should use
97.8513 percent to discount salvage
recoverable as of the end of the 2015
taxable year with respect to losses in-
curred in this line of business in 2005
and prior years.
Products Liability — Occurrence
Tax Y
ear
Disc
ount
Fact
ors
(%)
200581.4063
200683.9954
200
7
84.
6302
200887.2364
200984.7065
201088.1295
201191.1267
201291.8405
2
013
8
6.5573
201488.3625
Products Liability — Occurrence
Taxpayers that do not use the compos-
ite method of Notice 88–100 should use
the following factors to discount salvage
recoverable as of the end of the tax year
shown with respect to losses incurred in
this line of business in the 2005 accident
year.
201590.2160
201692.1163
201794.0579
201896.0181
2019 and later
years
97.8513
Taxpayers that use the composite
method of Notice 88–100 should use
93.2359 percent to discount salvage
recoverable as of the end of the 2015
taxable year with respect to losses in-
curred in this line of business in 2005
and prior years.
Reinsurance A (Nonproportional
Assumed Property)
Tax Year
Discount
Factors
(%)
200586.3118
200683.4802
200787.5160
200891.17
38
200991.8031
201093.5092
201195.2399
201296.4668
201397.0401
201
4
97.
8513
Taxpayers that do not use the compos-
ite method of Notice 88–100 should use
the following factor to discount salvage
recoverable as of the end of the tax year
shown with respect to losses incurred in
this line of business in the 2005 accident
year.
2015 and later
years
97.8513
Reinsurance A (Nonproportional
Assumed Property)
Taxpayers that use the composite
method of Notice 88–100 should use
97.8513 percent to discount salvage
recoverable as of the end of the 2015
taxable year with respect to losses in-
curred in this line of business in 2005
and prior years.
Reinsurance B (Nonproportional
Assumed Liability)
Tax Year
Discount
Factors
(%)
200585.7554
200683.4923
200786.6760
200884.5425
200977.7160
201081.2321
201180.6015
201282.8262
201377.8936
201485.273
6
Taxpayers that do not use the compos-
ite method of Notice 88–100 should use
the following factors to discount salvage
recoverable as of the end of the tax year
shown with respect to losses incurred in
this line of business in the 2005 accident
year.
201587.3145
201689.5053
201791.9023
201894.6103
201
9 and later
ye
ars
97.
8513
Taxpayers that use the composite
method of Notice 88–100 should use
89.5188 percent to discount salvage
recoverable as of the end of the 2015
taxable year with respect to losses in-
curred in this line of business in 2005
and prior years.
2005–49 I.R.B.1094December 5, 2005

Reinsurance C (Nonproportional
Assumed Financial Lines)
Tax Year
Discount
Factors
(%)
200585.5377
200686.2730
200789.6741
200887.1586
200990.2843
201083.5843
201186.7077
201293.3620
201394.6849
201496.5870
Taxpayers that do not use the compos-
ite method of Notice 88–100 should use
the following factor to discount salvage
recoverable as of the end of the tax year
shown with respect to losses incurred in
this line of business in the 2005 accident
year.
2015 an
d later
years
97.851
3
Taxpayers that use the composite
method of Notice 88–100 should use
97.8513 percent to discount salvage
recoverable as of the end of the 2015
taxable year with respect to losses in-
curred in this line of business in 2005
and prior years.
Special Property (Fire, Allied Lines,
Inland Marine, Earthquake, Glass,
Burglary and Theft)
Tax Year
Discount
Factors
(%)
200594.0942
200695.7713
Taxpayers th
at do not use the compos-
ite method of
Notice 88–100 should use
the followin
g factor to discount salvage
recoverabl
e as of the end of the tax year
shownwithr
espect to losses incurred in
this line of
business in the 2005 accident
year.
2007 and later
years
97.8513
Taxpayers that use the composite
method of Notice 88–100 should use
97.8513 percent to discount salvage
recoverable as of the end of the 2007
taxable year with respect to losses in-
curred in this line of business in 2005
and prior years.
Workers’ Compensation
Tax Year
Discount
Factors
(%)
200586.3894
200687.6481
200788.0853
200888.0120
200987.3618
201088.1750
201187.9837
201288.1613
201388.9764
201490.8396
Taxpayers that do not use the compos-
ite method of Notice 88–100 should use
the following factors to discount salvage
recoverable as of the end of the tax year
shown with respect to losses incurred in
this line of business in the 2005 accident
year.
201592.7444
201694.6769
201796.5791
2018 and later
years
97.8513
Taxpayers that use the composite
method of Notice 88–100 should use
94.0730 percent to discount salvage
recoverable as of the end of the 2015
taxable year with respect to losses in-
curred in this line of business in 2005
and prior years.
DRAFTING INFORMATION
The principal author of this revenue
procedure is Katherine A. Hossofsky of
the Office of the Associate Chief Counsel
(Financial Institutions & Products). For
further information regarding this revenue
procedure, contact Ms. Hossofsky at (202)
622–8435 (not a toll-free call).
December 5, 200510952005–49 I.R.B.

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the ef-
fect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is be-
ingextendedtoapplytoavariationofthe
fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that the
same principle also applies to B, the earlier
ruling is amplified. (Compare withmodi-
fied,below).
Clarifiedis used in those instances
where the language in a prior ruling is be-
ing made clear because the language has
caused, or may cause, some confusion.
It is not used where a position in a prior
ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
withamplifiedandclarified, above).
Obsoleteddescribes 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 rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
beingstatedinanewruling.
Supersededdescribes a situation where
the new ruling does nothing more than re-
state the substance and situation of a previ-
ously published ruling (or rulings). Thus,
the term is used to republish under the
1986 Code and regulations the same po-
sition published under the 1939 Code and
regulations. The term is also used when
it is desired to republish in a single rul-
ing a series of situations, names, etc., that
were previously published over a period of
time in separate rulings. If the new rul-
ing does more than restate the substance
of a prior ruling, a combination of terms
is used. For example,modifiedandsu-
persededdescribes a situation where the
substance of a previously published 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 pub-
lished ruling is first modified and then, as
modified, is superseded.
Supplementedis used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names in
subsequent rulings. After the original rul-
ing has been supplemented several times, a
new ruling may be published that includes
the list in the original ruling and the ad-
ditions, and supersedes all prior rulings in
the series.
Suspendedis used in rare situations
to show that the previous published rul-
ings 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 fol
lowing abbreviations in current use
and for
merly used will appear in material
publis
hedintheBulletin.
A—Individual.
Acq.—A
cquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank
.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cu
mulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Coo
perative.
Ct.D.—Court Decision.
CY—County.
D—Decede
nt.
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—Emp
loyer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduc
iary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Fo
reign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Fed
eral Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grante
e.
GP—General Partner.
GR—Grantor.
IC—Insura
nce Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited
Partner.
LR—Lessor.
M—Minor.
Nonacq.—No
nacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Persona
l Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Pa
rtnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Re
al Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsi
diary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target
Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Trans
feree.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpay
er.
TR—Trust.
TT—Trustee.
U.S.C.—Uni
ted States Code.
X—Corporation.
Y—Corporation.
Z—Corporat
ion.
2005–49 I.R.B.iDecember 5, 2005

Numerical Finding List
1
Bulletins 2005–27 through 2005–49
Announcements:
2005-46, 2005-27 I.R.B.63
2005-47, 2005-28 I.R.B.71
2005-48, 2005-29 I.R.B.111
2005-49, 2005-29 I.R.B.119
2005-50, 2005-30 I.R.B.152
2005-51, 2005-32 I.R.B.283
2005-52, 2005-31 I.R.B.257
2005-53, 2005-31 I.R.B.258
2005-54, 2005-32 I.R.B.283
2005-55, 2005-33 I.R.B.317
2005-56, 2005-33 I.R.B.318
2005-57, 2005-33 I.R.B.318
2005-58, 2005-33 I.R.B.319
2005-59, 2005-37 I.R.B.524
2005-60, 2005-35 I.R.B.455
2005-61, 2005-36 I.R.B.495
2005-62, 2005-36 I.R.B.495
2005-63, 2005-36 I.R.B.496
2005-64, 2005-37 I.R.B.537
2005-65, 2005-38 I.R.B.587
2005-66, 2005-39 I.R.B.613
2005-67, 2005-40 I.R.B.678
2005-68, 2005-39 I.R.B.613
2005-69, 2005-40 I.R.B.681
2005-70, 2005-40 I.R.B.682
2005-71, 2005-41 I.R.B.714
2005-72, 2005-41 I.R.B.692
2005-73, 2005-41 I.R.B.715
2005-74, 2005-42 I.R.B.764
2005-75, 2005-42 I.R.B.764
2005-76, 2005-42 I.R.B.765
2005-77, 2005-44 I.R.B.855
2005-78, 2005-44 I.R.B.918
2005-79, 2005-45 I.R.B.941
2005-80, 2005-46 I.R.B.967
2005-81, 2005-45 I.R.B.941
2005-82, 2005-45 I.R.B.941
2005-83, 2005-45 I.R.B.941
2005-84, 2005-48 I.R.B.1064
2005-85, 2005-48 I.R.B.1065
2005-86, 2005-48 I.R.B.1069
Notices:
2005-48, 2005-27 I.R.B.9
2005-49, 2005-27 I.R.B.14
2005-50, 2005-27 I.R.B.14
2005-51, 2005-28 I.R.B.74
2005-52, 2005-28 I.R.B.75
2005-53, 2005-32 I.R.B.263
2005-54, 2005-30 I.R.B.127
2005-55, 2005-32 I.R.B.265
Notices— Continued:
2005-56, 2005-32 I.R.B.266
2005-57, 2005-32 I.R.B.267
2005-58, 2005-33 I.R.B.295
2005-59, 2005-35 I.R.B.443
2005-60, 2005-39 I.R.B.606
2005-61, 2005-39 I.R.B.607
2005-62, 2005-35 I.R.B.443
2005-63, 2005-35 I.R.B.448
2005-64, 2005-36 I.R.B.471
2005-65, 2005-39 I.R.B.607
2005-66, 2005-40 I.R.B.620
2005-67, 2005-40 I.R.B.621
2005-68, 2005-40 I.R.B.622
2005-69, 2005-40 I.R.B.622
2005-70, 2005-41 I.R.B.694
2005-71, 2005-44 I.R.B.863
2005-72, 2005-47 I.R.B.976
2005-73, 2005-42 I.R.B.723
2005-74, 2005-42 I.R.B.726
2005-75, 2005-45 I.R.B.929
2005-76, 2005-46 I.R.B.947
2005-77, 2005-46 I.R.B.951
2005-78, 2005-46 I.R.B.952
2005-79, 2005-46 I.R.B.952
2005-80, 2005-46 I.R.B.953
2005-81, 2005-47 I.R.B.977
2005-82, 2005-47 I.R.B.978
2005-83, 2005-49 I.R.B.1075
2005-84, 2005-46 I.R.B.959
2005-85, 2005-46 I.R.B.961
2005-86, 2005-49 I.R.B.1075
2005-88, 2005-48 I.R.B.1060
2005-89, 2005-49 I.R.B.1077
Proposed Regulations:
REG-106030-98, 2005-42 I.R.B.739
REG-144615-02, 2005-40 I.R.B.625
REG-150088-02, 2005-43 I.R.B.774
REG-150091-02, 2005-43 I.R.B.780
REG-131739-03, 2005-36 I.R.B.494
REG-130241-04, 2005-27 I.R.B.18
REG-138362-04, 2005-33 I.R.B.299
REG-138647-04, 2005-41 I.R.B.697
REG-144898-04, 2005-48 I.R.B.1062
REG-149436-04, 2005-35 I.R.B.454
REG-156518-04, 2005-38 I.R.B.582
REG-158080-04, 2005-43 I.R.B.786
REG-104143-05, 2005-41 I.R.B.708
REG-105847-05, 2005-47 I.R.B.987
REG-111257-05, 2005-42 I.R.B.759
REG-114371-05, 2005-45 I.R.B.930
REG-114444-05, 2005-45 I.R.B.934
REG-121584-05, 2005-37 I.R.B.523
REG-122857-05, 2005-39 I.R.B.609
REG-129782-05, 2005-40 I.R.B.675
Proposed Regulations— Continued:
REG-133578-05, 2005-39 I.R.B.610
Revenue Procedures:
2005-35, 2005-28 I.R.B.76
2005-36, 2005-28 I.R.B.78
2005-37, 2005-28 I.R.B.79
2005-38, 2005-28 I.R.B.81
2005-39, 2005-28 I.R.B.82
2005-40, 2005-28 I.R.B.83
2005-41, 2005-29 I.R.B.90
2005-42, 2005-30 I.R.B.128
2005-43, 2005-29 I.R.B.107
2005-44, 2005-29 I.R.B.110
2005-45, 2005-30 I.R.B.141
2005-46, 2005-30 I.R.B.142
2005-47, 2005-32 I.R.B.269
2005-48, 2005-32 I.R.B.271
2005-49, 2005-31 I.R.B.165
2005-50, 2005-32 I.R.B.272
2005-51, 2005-33 I.R.B.296
2005-52, 2005-34 I.R.B.326
2005-53, 2005-34 I.R.B.339
2005-54, 2005-34 I.R.B.353
2005-55, 2005-34 I.R.B.367
2005-56, 2005-34 I.R.B.383
2005-57, 2005-34 I.R.B.392
2005-58, 2005-34 I.R.B.402
2005-59, 2005-34 I.R.B.412
2005-60, 2005-35 I.R.B.449
2005-61, 2005-37 I.R.B.507
2005-62, 2005-37 I.R.B.507
2005-63, 2005-36 I.R.B.491
2005-64, 2005-36 I.R.B.492
2005-65, 2005-38 I.R.B.564
2005-66, 2005-37 I.R.B.509
2005-67, 2005-42 I.R.B.729
2005-68, 2005-41 I.R.B.694
2005-69, 2005-44 I.R.B.864
2005-70, 2005-47 I.R.B.979
2005-71, 2005-47 I.R.B.985
2005-72, 2005-49 I.R.B.1078
2005-73, 2005-49 I.R.B.1090
Revenue Rulings:
2005-38, 2005-27 I.R.B.6
2005-39, 2005-27 I.R.B.1
2005-40, 2005-27 I.R.B.4
2005-41, 2005-28 I.R.B.69
2005-42, 2005-28 I.R.B.67
2005-43, 2005-29 I.R.B.88
2005-44, 2005-29 I.R.B.87
2005-45, 2005-30 I.R.B.123
2005-46, 2005-30 I.R.B.120
2005-47, 2005-32 I.R.B.261
2005-48, 2005-32 I.R.B.259
1
A cumulative list of all revenue rulings, revenueprocedures, Treasury decisions, etc., publishedin Internal Revenue Bulletins 2005–1 through 2005–26 is in Internal Revenue Bulletin
2005–26, dated June 27, 2005.
December 5, 2005ii2005–49 I.R.B.

Revenue Rulings— Continued:
2005-49, 2005-30 I.R.B.125
2005-50, 2005-30 I.R.B.124
2005-51, 2005-31 I.R.B.163
2005-52, 2005-35 I.R.B.423
2005-53, 2005-35 I.R.B.425
2005-54, 2005-33 I.R.B.289
2005-55, 2005-33 I.R.B.284
2005-56, 2005-35 I.R.B.427
2005-57, 2005-36 I.R.B.466
2005-58, 2005-36 I.R.B.465
2005-59, 2005-37 I.R.B.505
2005-60, 2005-37 I.R.B.502
2005-61, 2005-38 I.R.B.538
2005-62, 2005-38 I.R.B.557
2005-63, 2005-39 I.R.B.603
2005-64, 2005-39 I.R.B.600
2005-65, 2005-41 I.R.B.684
2005-66, 2005-41 I.R.B.686
2005-67, 2005-43 I.R.B.771
2005-68, 2005-44 I.R.B.853
2005-69, 2005-44 I.R.B.852
2005-70, 2005-45 I.R.B.919
2005-71, 2005-45 I.R.B.923
2005-72, 2005-46 I.R.B.944
2005-73, 2005-48 I.R.B.1050
2005-75, 2005-49 I.R.B.1073
2005-76, 2005-49 I.R.B.1072
2005-77, 2005-49 I.R.B.1071
Social Security Contribution and Benefit
Base; Domestic Employee Coverage
Threshold:
2005-85, 2005-46 I.R.B.961
Tax Conventions:
2005-47, 2005-28 I.R.B.71
2005-72, 2005-41 I.R.B.692
2005-77, 2005-44 I.R.B.855
Treasury Decisions:
9208, 2005-31 I.R.B.157
9209, 2005-31 I.R.B.153
9210, 2005-33 I.R.B.290
9211, 2005-33 I.R.B.287
9212, 2005-35 I.R.B.429
9213, 2005-35 I.R.B.440
9214, 2005-35 I.R.B.435
9215, 2005-36 I.R.B.468
9216, 2005-36 I.R.B.461
9217, 2005-37 I.R.B.498
9218, 2005-37 I.R.B.503
9219, 2005-38 I.R.B.538
9220, 2005-39 I.R.B.596
9221, 2005-39 I.R.B.604
9222, 2005-40 I.R.B.614
9223, 2005-39 I.R.B.591
9224, 2005-41 I.R.B.688
9225, 2005-42 I.R.B.716
Treasury Decisions— Continued:
9226, 2005-43 I.R.B.772
9227, 2005-45 I.R.B.924
9228, 2005-47 I.R.B.972
9229, 2005-48 I.R.B.1051
2005–49 I.R.B.iiiDecember 5, 2005

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2005–27 through 2005–49
Announcements:
84-26
Obsoleted by
REG-149436-04, 2005-35 I.R.B.454
2004-72
Updated and superseded by
Ann. 2005-59, 2005-37 I.R.B.524
2005-36
Modified by
Rev. Proc. 2005-66, 2005-37 I.R.B.509
2005-53
Corrected by
Ann. 2005-61, 2005-36 I.R.B.495
Notices:
89-111
Amplified by
Notice 2005-61, 2005-39 I.R.B.607
2001-42
Modified by
Rev. Proc. 2005-66, 2005-37 I.R.B.509
2004-43
Amplified by
Notice 2005-83, 2005-49 I.R.B.1075
2004-57
Superseded by
Notice 2005-79, 2005-46 I.R.B.952
2005-4
Modified by
Notice 2005-62, 2005-35 I.R.B.443
Notice 2005-80, 2005-46 I.R.B.953
2005-10
Clarified by
Notice 2005-64, 2005-36 I.R.B.471
2005-38
Modified by
Notice 2005-64, 2005-36 I.R.B.471
2005-42
Amplified by
Notice 2005-86, 2005-49 I.R.B.1075
2005-51
Modified and superseded by
Notice 2005-57, 2005-32 I.R.B.267
2005-60
Superseded by
Notice 2005-84, 2005-46 I.R.B.959
Notices— Continued:
2005-66
Supplemented by
Notice 2005-81, 2005-47 I.R.B.977
Proposed Regulations:
REG-108524-00
Corrected by
Ann. 2005-68, 2005-39 I.R.B.613
REG-142686-01
Withdrawn by
Ann. 2005-55, 2005-33 I.R.B.317
REG-100420-03
Corrected by
Ann. 2005-57, 2005-33 I.R.B.318
REG-102144-04
Corrected by
Ann. 2005-56, 2005-33 I.R.B.318
Revenue Procedures:
64-54
Obsoleted by
Rev. Rul. 2005-43, 2005-29 I.R.B.88
66-33
Obsoleted by
Rev. Rul. 2005-43, 2005-29 I.R.B.88
69-13
Obsoleted by
Rev. Rul. 2005-43, 2005-29 I.R.B.88
70-8
Modified by
Rev. Proc. 2005-46, 2005-30 I.R.B.142
71-1
Obsoleted by
Rev. Rul. 2005-43, 2005-29 I.R.B.88
72-22
Obsoleted by
Rev. Rul. 2005-43, 2005-29 I.R.B.88
83-77
Superseded by
Rev. Proc. 2005-63, 2005-36 I.R.B.491
87-8
Obsoleted by
Rev. Proc. 2005-44, 2005-29 I.R.B.110
87-9
Obsoleted by
Rev. Proc. 2005-44, 2005-29 I.R.B.110
89-20
Superseded by
Rev. Proc. 2005-52, 2005-34 I.R.B.326
Revenue Procedures— Continued:
90–11
Modified by
Rev. Proc. 2005-40, 2005-28 I.R.B.83
90-30
Section4supersededby
Rev. Proc. 2005-54, 2005-34 I.R.B.353
Section5supersededby
Rev. Proc. 2005-55, 2005-34 I.R.B.367
Section6supersededby
Rev. Proc. 2005-56, 2005-34 I.R.B.383
Section7supersededby
Rev. Proc. 2005-58, 2005-34 I.R.B.402
Section8supersededby
Rev. Proc. 2005-59, 2005-34 I.R.B.412
90-31
Section4supersededby
Rev. Proc. 2005-52, 2005-34 I.R.B.326
Section5supersededby
Rev. Proc. 2005-54, 2005-34 I.R.B.353
Section6supersededby
Rev. Proc. 2005-55, 2005-34 I.R.B.367
Section7supersededby
Rev. Proc. 2005-56, 2005-34 I.R.B.383
Section8supersededby
Rev. Proc. 2005-58, 2005-34 I.R.B.402
Section9supersededby
Rev. Proc. 2005-59, 2005-34 I.R.B.412
93-22
Obsoleted by
Rev. Proc. 2005-44, 2005-29 I.R.B.110
98-18
Obsoleted by
Rev. Proc. 2005-45, 2005-30 I.R.B.141
99-39
Superseded by
Rev. Proc. 2005-60, 2005-35 I.R.B.449
2000-27
Modified and superseded by
Rev. Proc. 2005-66, 2005-37 I.R.B.509
2000-31
Superseded by
Rev. Proc. 2005-60, 2005-35 I.R.B.449
2000-49
Superseded by
Rev. Proc. 2005-41, 2005-29 I.R.B.90
2001-9
Superseded by
Rev. Proc. 2005-60, 2005-35 I.R.B.449
2001-16
Superseded by
Rev. Proc. 2005-42, 2005-30 I.R.B.128
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2005–1 through 2005–26 is in Internal Revenue Bulletin 2005–26, dated June 27, 2005.
December 5, 2005iv2005–49 I.R.B.

Revenue Procedures— Continued:
2002-9
Modified and amplified by
Rev. Rul. 2005-42, 2005-28 I.R.B.67
Rev. Proc. 2005-35, 2005-28 I.R.B.76
Rev. Proc. 2005-43, 2005-29 I.R.B.107
Rev. Proc. 2005-47, 2005-32 I.R.B.269
2002-49
Modified, amplified, and superseded by
Rev. Proc. 2005-62, 2005-37 I.R.B.507
2004-50
Superseded by
Rev. Proc. 2005-49, 2005-31 I.R.B.165
2004-54
Superseded by
Rev. Proc. 2005-65, 2005-38 I.R.B.564
2004-58
Superseded by
Rev. Proc. 2005-69, 2005-44 I.R.B.864
2004-59
Modified by
Rev. Proc. 2005-71, 2005-47 I.R.B.985
2004-64
Modified by
Ann. 2005-71, 2005-41 I.R.B.714
2005-1
Amplified by
Rev. Proc. 2005-68, 2005-41 I.R.B.694
2005-3
Amplified by
Rev. Proc. 2005-61, 2005-37 I.R.B.507
Rev. Proc. 2005-68, 2005-41 I.R.B.694
2005-6
Modified by
Rev. Proc. 2005-66, 2005-37 I.R.B.509
2005-10
Superseded by
Rev. Proc. 2005-67, 2005-42 I.R.B.729
2005-16
Modified by
Rev. Proc. 2005-66, 2005-37 I.R.B.509
2005-65
Corrected by
Ann. 2005-78, 2005-44 I.R.B.918
Revenue Rulings:
65-109
Obsoleted by
Rev. Rul. 2005-43, 2005-29 I.R.B.88
68-549
Obsoleted by
Rev. Rul. 2005-43, 2005-29 I.R.B.88
Revenue Rulings— Continued:
74-203
Revoked by
Rev. Rul. 2005-59, 2005-37 I.R.B.505
82-29
Modified and clarified by
Rev. Proc. 2005-39, 2005-28 I.R.B.82
2004-45
Amplified by
Notice 2005-86, 2005-49 I.R.B.1075
2004-107
Supplemented and superseded by
Rev. Rul. 2005-76, 2005-49 I.R.B.1072
2004-108
Supplemented and superseded by
Rev. Rul. 2005-75, 2005-49 I.R.B.1073
2005-41
Corrected by
Ann. 2005-50, 2005-30 I.R.B.152
Treasury Decisions:
9149
Removed by
T.D. 9221, 2005-39 I.R.B.604
9186
Corrected by
Ann. 2005-53, 2005-31 I.R.B.258
9193
Corrected by
Ann. 2005-62, 2005-36 I.R.B.495
9205
Corrected by
Ann. 2005-63, 2005-36 I.R.B.496
9206
Corrected by
Ann. 2005-49, 2005-29 I.R.B.119
9207
Corrected by
Ann. 2005-52, 2005-31 I.R.B.257
9210
Corrected by
Ann. 2005-64, 2005-37 I.R.B.537
2005–49 I.R.B.vDecember 5, 2005
U.S. GPO: 2005—320–797/20034