Internal Revenue Bulletin 2009-34 (PDF rendition): IRS Revenue Procedures

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Bulletin No. 200
9-34
August 24, 2009
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
Notice 2009–70, page 255.
The Service invites comments on the proper application of the
rules relating to the creation and maintenance of multiple layers
of forward and reverse section 704(c) gain or loss to partner-
ships and tiered partnerships, including in the context of part-
nership mergers and divisions.
Rev. Proc. 2009–34, page 258.
This procedure provides domestic asset/liability percentages
and domestic investment yields needed by foreign life insur-
ance companies and foreign property and liability insurance
companies to compute their minimum effectively connected
net investment income under section 842(b) of the Code for
taxable years beginning after December 31, 2007.
EMPLOYEE PLANS
Notice 2009–63, page 252.
Weighted average interest rate update; corporate bond
indices; 30–year Treasury securities; segment rates.
This notice contains updates for the corporate bond weighted
average interest rate for plan years beginning in August 2009;
the 24-month average segment rates; the funding transitional
segment rates applicable for August 2009; and the minimum
present value transitional rates for July 2009.
Finding Lists begin on page ii.

The IRS Mission
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a’s taxpayers top quality service by helping them
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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 Secre-
tary (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.
August 24, 20092009–34 I.R.B.

Part III. Administrative, Procedural, and Miscellaneous
Update for Weighted Average
Interest Rates, Yield Curves,
and Segment Rates
Notice 2009–63
This notice provides guidance as to the
corporate bond weighted average interest
rate and the permissible range of interest
rates specified under § 412(b)(5)(B)(ii)(II)
of the Internal Revenue Code as in ef-
fect for plan years beginning before 2008.
It also provides guidance on the corpo-
rate bond monthly yield curve (and the
corresponding spot segment rates), the
24-month average segment rates, and
the funding transitional segment rates
under § 430(h)(2). In addition, this no-
tice provides guidance as to the interest
rate on 30-year Treasury securities un-
der § 417(e)(3)(A)(ii)(II) as in effect for
plan years beginning before 2008, the
30-year Treasury weighted average rate
under § 431(c)(6)(E)(ii)(I), and the min-
imum present value segment rates under
§ 417(e)(3)(D) as in effect for plan years
beginning after 2007.
CORPORATE BOND WEIGHTED
AVERAGE INTEREST RATE
Sections412(b)(5)(B)(ii)and
412(l)(7)(C)(i), as amended by the Pen-
sion Funding Equity Act of 2004 and by
the Pension Protection Act of 2006 (PPA),
provide that the interest rates used to cal-
culate current liability and to determine
the required contribution under § 412(l)
for plan years beginning in 2004 through
2007 must be within a permissible range
based on the weighted average of the rates
of interest on amounts invested conser-
vatively in long term investment grade
corporate bonds during the 4-year period
ending on the last day before the beginning
of the plan year.
Notice 2004–34, 2004–1 C.B. 848, pro-
vides guidelines for determining the cor-
porate bond weighted average interest rate
and the resulting permissible range of in-
terest rates used to calculate current liabil-
ity. That notice establishes that the corpo-
rate bond weighted average is based on the
monthly composite corporate bond rate de-
rived from designated corporate bond in-
dices. The methodology for determining
the monthly composite corporate bond rate
as set forth in Notice 2004–34 continues to
apply in determining that rate. See Notice
2006–75, 2006–2 C.B. 366.
The composite corporate bond rate for
July 2009 is 6.39 percent. Pursuant to No-
tice 2004–34, the Service has determined
this rate as the average of the monthly
yields for the included corporate bond in-
dices for that month.
The following corporate bond weighted
average interest rate was determined for
plan years beginning in the month shown
below.
For Plan Years
Beginning inPermissible Range
MonthYear
Corporate
Bond Weighted
Average90%to100%
August20096.48
5.83
6.48
YIELD CURVE AND SEGMENT
RATES
Generally for plan years beginning
after 2007 (except for delayed effective
dates for certain plans under sections 104,
105, and 106 of PPA), § 430 of the Code
specifies the minimum funding require-
ments that apply to single employer plans
pursuant to § 412. Section 430(h)(2) spec-
ifies the interest rates that must be used
to determine a plan’s target normal cost
and funding target. Under this provision,
present value is generally determined us-
ing three 24-month average interest rates
(“segment rates”), each of which applies
to cash flows during specified periods.
However, an election may be made under
§ 430(h)(2)(D)(ii) to use the monthly yield
curve in place of the segment rates. For
plan years beginning in 2008 and 2009, a
transitional rule under § 430(h)(2)(G) pro-
vides that the segment rates are blended
with the corporate bond weighted average
as specified above. An election may be
made under § 430(h)(2)(G)(iv) to use the
segment rates without applying the transi-
tional rule.
Notice 2007–81, 2007–44 I.R.B. 899,
provides guidelines for determining the
monthly corporate bond yield curve, the
24-month average corporate bond segment
rates, and the funding transitional segment
rates used to compute the target normal
cost and the funding target. Pursuant to
Notice 2007–81, the monthly corporate
bond yield curve derived from July 2009
data is in Table I at the end of this notice.
The spot first, second, and third segment
rates for the month of July 2009 are, re-
spectively, 3.39, 6.28, and 6.47. The three
24-month average corporate bond segment
rates applicable for August 2009 under
the election of § 430(h)(2)(G)(iv) are as
follows:
First
Segment
Second
Segment
Third
Segment
5.12
6.746.83
2009–34 I.R.B.252August 24, 2009

The transitional segment rates under
§ 430(h)(2)(G) applicable for August
2009, taking intoaccount the corporate
bond weighted average of 6.48 stated
above, are as follows:
For Plan Years
Beginning in
First
Segment
Second
Segment
Third
Segment
20086.03
6.57
6.60
2009
5.576.65
6.71
30-YEAR TREASURY SECURITIES
INTEREST RATES
Section 417(e)(3)(A)(ii)(II) (prior to
amendment by PPA) defines the appli-
cable interest rate, which must be used
for purposes of determining the minimum
present value of a participant’s benefit
under § 417(e)(1) and (2), as the annual
rate of interest on 30-year Treasury se-
curities for the month before the date
of distribution or such other time as the
Secretary may by regulations prescribe.
Section 1.417(e)–1(d)(3) of the Income
Tax Regulations provides that the applica-
ble interest rate for a month is the annual
rate of interest on 30-year Treasury secu-
rities as specified by the Commissioner
for that month in revenue rulings, notices
or other guidance published in the Internal
Revenue Bulletin.
The rate of interest on 30-year Trea-
sury securities for July 2009 is 4.41 per-
cent. The Service has determined this rate
as the monthly average of the daily deter-
mination of yield on the 30-year Treasury
bond maturing in May 2039.
Generally for plan years beginning
after 2007, § 431 specifies the mini-
mum funding requirements that apply to
multiemployer plans pursuant to § 412.
Section 431(c)(6)(B)specifies a minimum
amount for the full-funding limitation
described in section 431(c)(6)(A), based
on the plan’s current liability. Section
431(c)(6)(E)(ii)(I) provides that the inter-
est rate used to calculate current liability
for this purpose must be no more than 5
percent above and no more than 10 percent
below the weighted average of the rates of
interest on 30-year Treasury securities dur-
ing the four-year period ending on the last
day before the beginning of the plan year.
Notice 88–73, 1988–2 C.B. 383, provides
guidelines for determining the weighted
average interest rate. The following rates
were determined for plan years beginning
in the month shown below.
For Plan Years
Beginning inPermissible Range
MonthYear
30-Year
Treasury
Weighted
Average
90%to
105%
August20094.403.964.62
MINIMUM PRESENT VALUE
SEGMENT RATES
Generally for plan years beginning af-
ter December 31, 2007, the applicable in-
terest rates under § 417(e)(3)(D) are seg-
ment rates computed without regard to a
24-month average. For plan years begin-
ning in 2008 through 2011, the applica-
ble interest rate is the monthly spot seg-
ment rate blended with the applicable rate
under § 417(e)(3)(A)(ii)(II) as in effect
for plan years beginning in 2007. Notice
2007–81 provides guidelines for determin-
ing the minimum present value segment
rates. Pursuant to that notice, the min-
imum present value transitional segment
rates determined for July 2009, taking into
account the July 2009 30-year Treasury
rate of 4.41 stated above, are as follows:
For Plan Y
ears
Beginning
in
First
Segment
Second
Segment
Third
Segment
20084.214.784.82
20094.00
5.165.23
DRAFTING INFORMATION
The principal author of this notice is
Tony Montanaro of the Employee Plans,
Tax Exempt and Government Entities Di-
vision. Mr. Montanaro may be e-mailed at
RetirementPlanQuestions@irs.gov.
August 24, 20092532009–34 I.R.B.

Table I
Monthly Yield Cu
rve for July 2009
Maturity YieldMaturity YieldMaturity YieldMaturity YieldMaturity Yield
0.5
1.79
20.5
6.60
40.56.4560.5
6.41
80.5
6.39
1.02.2021.06.5941.0
6.45
61.06.4181.0
6.39
1.5
2.59
21.56.5841.56.4561.5
6.41
81.5
6.39
2.0
2.97
22.0
6.57
42.0
6.45
62.06.4182.0
6.39
2.5
3.31
22.56.5642.56.4562.5
6.41
82.5
6.39
3.03.6423.06.5643.06.4463.06.4183.0
6.39
3.5
3.94
23.56.5543.5
6.44
63.5
6.41
83.5
6.39
4.04.2224.0
6.54
44.06.4464.06.4184.0
6.39
4.5
4.48
24.56.5444.5
6.44
64.5
6.41
84.5
6.39
5.0
4.72
25.06.5345.0
6.44
65.0
6.41
85.0
6.39
5.5
4.95
25.56.5245.5
6.44
65.5
6.41
85.5
6.39
6.05.1526.06.5246.06.4466.06.4186.0
6.39
6.55.3426.56.5146.5
6.44
66.5
6.41
86.5
6.39
7.0
5.51
27.0
6.51
47.06.4467.06.4187.0
6.39
7.55.6727.56.5147.5
6.43
67.5
6.41
87.5
6.39
8.0
5.81
28.0
6.50
48.06.4368.06.4188.0
6.39
8.5
5.94
28.56.5048.5
6.43
68.5
6.40
88.5
6.39
9.0
6.06
29.0
6.50
49.0
6.43
69.0
6.40
89.06.39
9.56.1629.56.4949.56.4369.56.4089.56.39
10.0
6.25
30.0
6.49
50.0
6.4370.06.40
90.06.39
10.5
6.33
30.5
6.49
50.5
6.43
70.5
6.4090.5
6.39
11.06.4031.0
6.49
51.0
6.4371.06.40
91.06.39
11.56.4531.5
6.48
51.5
6.43
71.5
6.4091.5
6.39
12.06.5032.06.4852.06.4372.06.40
92.06.39
12.56.5432.5
6.48
52.5
6.43
72.5
6.4092.56.39
13.0
6.58
33.06.48
53.0
6.4273.06.40
93.06.39
13.5
6.60
33.5
6.47
53.5
6.42
73.5
6.4093.5
6.39
14.06.6234.06.47
54.0
6.4274.06.40
94.06.39
14.5
6.63
34.5
6.47
54.5
6.42
74.5
6.4094.5
6.39
15.06.6435.06.4755.06.4275.06.4095.0
6.39
15.56.6535.5
6.47
55.5
6.42
75.5
6.4095.56.39
16.0
6.65
36.06.47
56.0
6.4276.06.40
96.06.39
16.56.6536.5
6.46
56.5
6.42
76.5
6.4096.5
6.39
17.0
6.65
37.06.46
57.0
6.4277.06.40
97.0
6.38
17.5
6.64
37.5
6.46
57.5
6.42
77.5
6.4097.56.38
18.06.6438.06.4658.06.4278.06.40
98.0
6.38
18.5
6.63
38.5
6.46
58.5
6.42
78.5
6.4098.56.38
19.0
6.62
39.0
6.4659.06.42
79.0
6.40
99.0
6.38
19.56.6139.5
6.45
59.56.4179.56.4099.56.38
20.06.6140.0
6.45
60.06.4180.0
6.39
100.06.38
2009–34 I.R.B.254August 24, 2009

Section 704(c) Layers
Relating to Partnership
Mergers, Divisions and Tiered
Partnerships
Notice 2009–70
Section 1. PURPOSE
The Internal Revenue Service invites
public comments on the proper applica-
tion of the rules relating to the creation and
maintenance of multiple layers of forward
and reverse section 704(c) gain and loss
to partnerships and tiered partnerships, in-
cluding in the context of partnership merg-
ers and divisions.
Section 2. BACKGROUND
As discussed in greater detail below, the
IRS and Treasury Department issued pro-
posed regulations in 2007 addressing the
consequences under sections 704(c)(1)(B)
and 737 of certain partnership mergers.
The IRS and the Treasury Department re-
ceived a number of comments in response
to these proposed regulations expressing
concern about the proposed treatment of
section 704(c) layersinconnectionwitha
partnership merger. In addition, the IRS
and the Treasury Department have be-
come aware that practitioners are taking
positions based upon different interpreta-
tions of the current tiered partnership rules
(Treas. Reg. § 1.704–3(a)(9)). A num-
ber of practitioners suggest that the tiered
partnerships rules may need to be clarified
and similar rules be provided with respect
to partnership mergers. The IRS and Trea-
sury believe that further study of certain
aspects of the application of section 704(c)
is necessary before finalizing the Proposed
Merger Regulations.
Section 704(c), in relevant part, pro-
vides:
(c) CONTRIBUTED PROPERTY.—
(1) IN GENERAL.—Under regulations
prescribed by the Secretary—
(A) income, gain, loss, and de-
duction with respect to property con-
tributed to the partnership by a partner
shall be shared among the partners so
as to take account of the variation be-
tween the basis of the property to the
partnership and its fair market value at
the time of contribution,
(B) if any property so contributed
is distributed (directly or indirectly) by
the partnership (other than to the con-
tributing partner) within 7 years of be-
ing contributed—
(i) the contributing partner shall be
treated as recognizing gain or loss (as
the case may be) from the sale of such
property in an amount equal to the gain
or loss which would have been allo-
cated to such partner under subpara-
graph (A) by reason of the variation de-
scribed in subparagraph (A) if the prop-
erty had been sold at its fair market
value at the time of distribution.
Section 704(c)(1)(A) was enacted as
part of the Tax Reform Act of 1984
(P.L. 98–369). Congress determined that
“special rules are needed to prevent an
artificial shifting of tax consequences
between the partners with respect to
pre-contribution gain or loss. This is
particularly important since the various
partners may have different tax positions.”
H.R. Rep. No. 432, Pt. 2, 98
th
Cong.,
2d Sess., 1209 March 5, 1984.Seealso,
Staff of Joint Committee on Taxation, 98
th
Cong., 2d Sess., General Explanation of
H.R. 4170, 212, Dec. 31, 1984.
Section 704(c)(1)(B) was enacted as
part of the Omnibus Budget Reconcilia-
tion Act of 1989 (P.L. 101–239). It was
Congress’s view that the prior law made
it “possible for partners to circumvent the
rule requiring pre-contribution gain on
contributed property to be allocated to the
contributing partner.” S. Finance Comm.
101
st
Cong., Revenue Reconciliation Act
of 1989, Explanation of Provisions Ap-
proved by the Committee on Oct. 3, 1989,
196 (Comm. Print 1989).
While section 704(c)(1)(B) addresses
the recognition of gain by the contributing
partner if property contributed by the part-
ner is distributed to another partner, sec-
tion 737 addresses the tax consequences
when a partner who contributed built-in
gain or loss property receives a distribution
of other property.
Sections 737(a) and (b), in relevant
part, provide:
(a) GENERAL RULE. In the case of
any distribution by a partnership to a part-
ner, such partner shall be treated as recog-
nizing gain in an amount equal to the lesser
of—
(1) the excess (if any) of
(A) the fair market value of property
(other than money) received in the dis-
tribution over
(B) the adjusted basis of such part-
ner’s interest in the partnership imme-
diately before the distribution reduced
(but not below zero) by the amount of
money received in the distribution, or
(2) the net precontribution gain of the
partner.
Gain recognized under the preceding
sentence shall be in addition to any gain
recognized under section 731. The char-
acter of such gain shall be determined by
reference to the proportionate character of
the net precontribution gain.
(b) NET PRECONTRIBUTION
GAIN. For purposes of this section, the
term “net precontribution gain” means
the net gain (if any) which would have
been recognized by the distributee partner
under section 704(c)(1)(B) if all property
which—
(1) had been contributed to the part-
nership by the distributee partner within 7
years of the distribution, and
(2) is held by such partnership imme-
diately before the distribution, had been
distributed by such partnership to another
partner.
Sections 737(a) and (b) were enacted
as part of the Energy Policy Act of 1992
(P.L. 102–486) as a result of Congress’s
concern that “a partner who contributes
appreciated propertyto a partnership may
be able to avoid or defer the recognition of
gain with respect to that property through
the mechanism of having the partnership
distribute other partnership property to
him in partial or complete redemption of
his interest while the partnership contin-
ues to own the contributed property.” H.R.
Rep. 102–631, 102
nd
Cong., 2d. Sess.,
68 (June 30, 1992).Seealso, S. Finance
Comm. Technical Explanation, 138 Cong.
Record S11246, S11265, Aug. 3, 1992
(Daily Ed.). Final regulations under sec-
tions 704(c)(1)(B) and 737 were issued
in T.D. 8642, dated December 22, 1995.
Amendments to these provisions were in-
cluded in T.D. 8717, dated May 8, 1997,
T.D. 9193, dated March 21, 2005 and T.D.
9207, dated May 23, 2005.
On August 22, 2007, the IRS
and the Treasury Department pub-
lished in theFederal Register(72 FR
46932) a notice of proposed rulemak-
ing (REG–143397–05) (the Proposed
August 24, 20092552009–34 I.R.B.

Merger Regulations), consistent with No-
tice 2005–15, 2005–1 C.B. 527, providing
that (1) section 704(c)(1)(B) applies to
newly created section 704(c) gain or loss
in property contributedbythetransferor
partnership to the continuing partnership
in an assets-over merger, but does not ap-
ply to newly created reverse section 704(c)
gain or loss resulting from a revaluation
of property in the continuing partnership,
and (2) for purposes of section 737(b), net
precontribution gain includes newly cre-
ated section 704(c) gain or loss in property
contributed by the transferor partnership
to the continuing partnership in an as-
sets-over merger, but does not include
newly created reverse section 704(c) gain
or loss resulting from a revaluation of
property in the continuing partnership.
On November 6, 2007, corrections to the
proposed regulations were published in
theFederal Register(72 FR 62608).
The proposed regulations include sev-
eral examples.Example (3)of the pro-
posed regulations (see Treas. Proposed
Reg. § 1.704–4(c)(4)(ii)(F),Example (3))
involves a situation where built-in gain
property contributed to the transferor part-
nership has both a revaluation loss in the
transferor partnership and additional gain
upon merger with the transferee partner-
ship. The example concludes that the
section 704(c) layers are collapsed in the
merger and that upon contribution to the
transferee partnership the property had
only built-in gain and no built-in loss.
Example 3 is as follows.
Example (3). Revaluation loss and merger gain.
(i) Facts. On January 1, 2005, A contributes Asset
1, with a basis of $200x and a fair market value of
$300x, to partnership PRS1 in exchange for a 50 per-
cent interest. On the same date, B contributes $300x
of cash to PRS1 in exchange for a 50 percent inter-
est. Also on January 1, 2005, C contributes Asset
2, with a basis of $100x and a fair market value of
$200x, to partnership PRS2 in exchange for a 50 per-
cent interest. On the same date, D contributes $200x
ofcashtoPRS2inexchangefora50percentinterest.
PRS1andPRS2bothhaveprovisionsintheirrespec-
tive partnership agreements requiring the revaluation
of partnership property upon entry of a new partner.
PRS2 would not be treated as an investment company
(within the meaning of section 351) if it were incor-
porated. Neither partnership holds any unrealized re-
ceivables or inventory for purposes of section 751. In
addition, neither partnership has a section 754 elec-
tion in place. Asset 1 and Asset 2 are nondepreciable
capital assets.
Later on in 2005, PRS2 admitted E as a new part-
ner in PRS2 at a time when the fair market value of
Asset 2 was $150x and PRS2’s only other asset was
cash of $200x. In exchange for a contribution of cash
of $175x, E was admitted as a one-third partner in
PRS2. In accordance with the terms of PRS2’s part-
nership agreement, the partnership revalued its assets
upon admission of E so that the unrealized loss of
$50x attributable to Asset 2 was allocated equally be-
tween C and D, or $25x each. On January 1, 2008,
PRS 2 merges into PRS1. At the time of the merger,
PRS1’s only assets are Asset 1, with a fair market
value of $900x, and $300x in cash. PRS2’s only as-
sets are Asset 2, with a fair market value of $600x,
and $375x in cash. After the merger, the partners have
book capital and profits and loss interests in PRS1 as
follows: A, 27.5%; B, 27.5%; C, 15%; D, 15%; and
E, 15%. On January 1, 2013, Asset 2 is distributed to
A when its value is still $600.
(ii)Analysis. On the date of the merger of PRS2
into PRS1, the fair market value of Asset 2 ($600x)
exceeded its adjusted tax basis ($100x). Thus, when
Asset2wascontributedtoPRS1inthemerger,itwas
section 704(c) gain property. The total amount of the
section 704(c) gain was $500x ($600x (fair market
value) - 100x (adjusted basis)). The amount of the
original section 704(c) gain attributable to Asset 2
equals $50x, the difference between its fair market
value ($200x) and adjusted tax basis ($100x) upon
contributiontoPRS2byC,lesstheunrealizedloss
($50x) attributable to the revaluation of PRS2 on the
admission of E as a partner in PRS2. The amount
of the new section 704(c) gain attributable to Asset 2
equals $450x, the total section 704(c) gain ($500x)
less the amount of the original section 704(c) gain
($50x). The distribution of Asset 2 to A occurs more
than seven years after the contribution by C to PRS2.
Therefore, pursuant to § 1.704–4(c)(4)(ii)(A), sec-
tion 704(c)(1)(B) does not apply to the original sec-
tion 704(c) gain. The distribution of Asset 2 to A,
however, occurs within seven years of the contri-
butionofAsset2toPRS1andPRS2. Pursuantto
§ 1.704–4(c)(4)(ii)(B), section 704(c)(1)(B) applies
to the new section 704(c) gain. As the transferees of
PRS2’s partnership interest in PRS1, C, D and E each
succeed to $150 of new section 704(c) gain. Thus, as
a result of the distribution of Asset 2 to A within seven
years of the merger, C, D and E are each required to
recognize $150 of gain.
A number of rules in existing regula-
tions may be relevant to mergers, divi-
sions and tiered partnerships. In particular
Treas. Reg. § 1.704–3(a)(7)-(9) may ap-
ply.
Treas. Reg. § 1.704–3(a)(7) provides
rules when a partner transfers his partner-
ship interest and provides a “step in the
shoes” approach:
(7)Transfer of a partnership inter-
est.—If a contributing partner transfers
a partnership interest, built-in gain or
loss must be allocated to the transferee
partner as it would have been allocated
to the transferor partner. If the con-
tributing partner transfers a portion of
the partnership interest, the share of
built-in gain or loss proportionate to the
interest transferred must be allocated to
the transferee partner. This rule does
not apply to any person who acquired a
partnership interest from a § 1.752–7 li-
ability partner in a transaction in which
paragraph (e)(1) of § 1.752–7 applies.
See § 1.752–7(c)(1).
Treas. Reg. § 1.704–3(a)(8) provides
special rules for certainspecific situations,
including the disposition of section 704(c)
property in a nonrecognition transaction.
Treas. Reg. § 1.704–3(a)(8)(i) states, in
relevant part:
(8)Special rules.—(i)Disposition
in a nonrecognition transaction.—If a
partnership disposes of section 704(c)
property in a nonrecognition trans-
action, the substituted basis prop-
erty (within the meaning of section
7701(a)(42)) is treated as section 704(c)
property with the same amount of
built-in gain or loss as the section
704(c) property disposed of by the
partnership. If gain or loss is recog-
nized in such a transaction, appropriate
adjustments must be made. The allo-
cation method for the substituted basis
property must be consistent with the al-
location method chosen for the original
property.
Guidance on allocations with regard to
the contribution of section 704(c) property
in a tiered partnership structure is provided
in Treas. Reg. § 1.704–3(a)(9):
(9)Tiered partnerships.—If a part-
nership contributes section 704(c)
property to a second partnership (the
lower-tier partnership), or if a part-
ner that has contributed section 704(c)
property to a partnership contributes
that partnership interest to a second
partnership (the upper-tier partnership),
the upper-tier partnership must allo-
cate its distributive share of lower-tier
partnership items with respect to that
section 704(c) property in a manner
that takes into account the contribut-
ing partner’s remaining built-in gain
or loss. Allocations made under this
paragraph will be considered to be
made in a manner that meets the re-
quirements of § 1.704–1(b)(2)(iv)(q)
(relating to capital account adjustments
where guidance is lacking).
Section 3. DISCUSSION
While no requests for a hearing were re-
ceived in response to the proposed regula-
tions issued on August 22, 2007, the IRS
2009–34 I.R.B.256August 24, 2009

and the Treasury Department did receive
comments relating to the proposed regula-
tions and took notice of a number of arti-
cles published in response to the proposed
regulations.
Most of the comments and articles ad-
dressExample (3)which provides that
property either has a built-in gain or
built-in loss upon merger, not both, and
that original section 704(c) gain is reduced
by subsequent revaluation losses. Several
comments discussed not only the specifics
ofExample (3), but also the broader im-
plications of the example. In particular,
the commentators questioned whether the
example implies that a subsequent reval-
uation loss would reduce prior section
704(c) gains rather than create a new sec-
tion 704(c) loss layer where there has been
no partnership merger. Another comment
suggested that the section 704(c) alloca-
tions in the example could be different
if, for example, the transferor partnership
used the remedial method instead of the
traditional method. Other commentators
expressed concerns that the application of
the proposed regulations would result in
tax allocations after the merger that are not
consistent with the economic arrangement
of the partners of thetransferor partner-
ship. For example, if layers of reverse
section 704(c) built-in gain or built-in loss
are collapsed in the merger, then a partner
who prior to the merger was allocated a
net loss for book purposes with respect
to the property would not recognize a
corresponding tax loss until liquidation
of its interest. They contend that if the
transferor partnership had continued in ex-
istence instead of liquidating, the section
704(c) layers would have been preserved
under the tiered partnership rules of Treas.
Reg. § 1.704–3(a)(9). Some practitioners
believe the results should be the same in a
merger.
The IRS and the Treasury Department
have also become aware that there are con-
flicting views among practitioners about
how section 704(c) layers should be main-
tained with respect to tiered partnerships.
One view is that an aggregate approach
should apply or be permitted such that
a tiered partnership arrangement can be
“looked through” and section 704(c) ap-
plied as if the partners of the upper-tier
partnership directly own a portion of the
assets of the lower-tier partnership (the
Aggregate Approach). Another view is
the entity approach under which the up-
per-tier partnership is treated as owning an
interest in the lower-tier partnership but is
not treated as owning any interest in the
section 704(c) property of the lower-tier
partnership (the Entity Approach). Each
approach raises different issues and has
unique consequences.
After extensive consideration of the
concerns raised, the IRS and the Treasury
Department believe that comments would
be helpful to the development of guidance
concerning section 704(c) layers in tiered
partnerships and in mergers and divisions.
The IRS and Treasury Department believe
that it is appropriate to consider the issues
regarding section 704(c) layers in general
before finalizing the Proposed Merger
Regulations.
Section 4. REQUEST FOR COMMENTS
The IRS and Treasury Department
are seeking comments relating to section
704(c) layers, as well as other section
704(c) issues, with respect to tiered part-
nerships, mergers and divisions. The
IRS and the Treasury Department plan
to address these issues as part of a future
guidance project. However, the IRS and
Treasury Department are not requesting
comments on the principles described in
Notice 2005–15, 2005–1 C.B. 527.
The IRS and Treasury Department
include examples below of the types of
comments requested, but comments are
requested on all aspect of these issues, not
only those matters listed.
Single Partnership with Layers — No
Tiers
1.Should any changes be
made to the events in Treas. Reg.
§ 1.704–1(b)(2)(iv)(f), the occurrence of
which allow for a revaluation of assets?
Should additional events be added?
2. After revaluing property, when, if at
all, is it appropriate for taxpayers to net
additional differences between value and
basis against existing section 704(c) layers
and when is it appropriate to create new
section 704(c) layers if the layers offset
one another (e.g., loss and gain layers)?
3. If a partnership has multiple sec-
tion 704(c) layers, how should tax depre-
ciation, depletion, amortization and gain
or loss be allocated between the layers?
When is it appropriate for partnerships to
allocate these items to the latest layers
first, to earlier layers first or to allocate
these itemspro ratato all layers for this
purpose? Are other methods appropri-
ate? How are these amounts allocated be-
tween layers if there are offsetting layers
(e.g., how should depreciation be allocated
between layers if a property has both a
$100 gain layer and a subsequent $100 loss
layer)?
4. What other section 704(c) issues
are raised relating to section 704(c) layers,
e.g., when partnership property is reval-
ued?
Tiers of Partnerships with Layers
5. Are changes necessary to Treas.
Reg. § 1.704–3(a)(7) and (8) to address
compliance with section 704(c) and main-
tenance of section 704(c) layers when
property is either contributed to a partner-
ship or transferred to a partner in a tiered
partnership structure?
6. Are there different considerations
in making property revaluation decisions
in tiered partnership structures than in a
single partnership (e.g., should a revalu-
ation of an upper-tier partnership consti-
tute a revaluation event at the lower-tier
partnership and should revaluation be de-
pendent upon whether the upper-tier part-
nership has a significant interest in the
lower-tier partnership)? Does the order in
which tiered partnerships make property
revaluations affect resulting section 704(c)
layers and does existing guidance permit
taxpayers to make revaluations in the ap-
propriate order as necessary?
7. What issues relating to section
704(c) must taxpayers address in tiered
partnership structures?What addi-
tional issues should be addressed by
the regulations, including Treas. Reg.
§ 1.704–3(a)(9)?
8.When should Treas.Reg.
§ 1.704–3(a)(9) permit taxpayers to use an
Aggregate Approach or Entity Approach?
What should be the results under these
approaches? Should taxpayers be able to
use other methods to track section 704(c)
layers?
9. Under the Aggregate Approach, how
would the section 704(c) layers be main-
tained by the lower-tier partnership?
10. Is the information necessary to
maintain section 704(c) layers under the
Aggregate Approach readily available? If
August 24, 20092572009–34 I.R.B.

the Aggregate Approach is permitted what,
if any, additional rules would be necessary
so that the partnerships may secure the re-
quired information?
11. Under the Entity Approach, if af-
ter allocating the upper-tier partnership’s
distributive share of lower-tier partnership
section 704(c) allocations on the sale of
an asset at the lower-tier level there are
remaining book tax differences in the up-
pertierpartnership,how,ifatall,should
these differences be resolved at the upper
tier level?
Mergers
12. Recognizing that the transferor
partnership terminates in a merger, what
different issues do mergers raise for the
section 704(c) layer rules ?
13. Whether the Aggregate or Entity
Approach is used in tiered partnerships,
how will the approach be affected by a
merger of one of the partnerships in a tiered
arrangement, including a partnership that
directly holds section 704(c) property and
a partnership with an indirect interest in the
property?
14. Under the Aggregate Approach,
how would the transferee partnership
maintain the section 704(c) layers of the
transferor partnership?
15. Under the Entity Approach, when
should the transferee partnership maintain
the layers of the transferor partnership, or
should each asset have a single section
704(c) layer as a result of the merger?
16. Are there different considerations if
the transferor has partnerships as partners
or if the transferee partnership is a partner
in another partnership?
Divisions
17. What issues regarding section
704(c) layers are raised in a division of a
“traditional” single tier partnership and in
the division of a partnership that is part of
a tiered partnership structure?
18. Assuming a partnership division
should not create new section 704(c) prop-
erty (or section 737 net precontribution
gain) when each partner’s overall inter-
est in each partnership property does not
change, how should section 704(c) layers
be created and maintained when a division
is notpro rataor other changes in partners
or property interests occur at the time of
the division?
International Issues
19. What international tax issues are
raised on the application of section 704(c)
layers to tiered partnerships, mergers and
divisions? For example, how should sec-
tion 704(c) layers be created and main-
tained in cross-border tiered partnerships
and mergers and divisions? Should sim-
ilar “layers” be created and maintained to
track and preserve the character of the gain
under international tax provisions, includ-
ing sections 367, 897, and 1248?
Commentsmaybesubmittedonor
before February 22, 2010 to Internal Rev-
enue Service, PO Box 7604, Washington,
DC 20044, Attn: CC:PA:LPD:PR (Notice
2009–70), Room 5203. Submissions may
also be hand-delivered Monday through
Friday between the hours of 8 a.m. and
4 p.m. to the Courier’s Desk at 1111
Constitution Avenue, NW, Washington
DC 20224, Attn: CC:PA:LPD:PR (No-
tice 2009–70), Room 5203. Submissions
may also be sent electronically via the
internet to the following email address:
Notice.comments@irscounsel.treas.gov.
Include the notice number (Notice
2009–70) in the subject line.
Section 5. DRAFTING INFORMATION
The principal author of this notice is
Laura Fields of the Office of Associate
Chief Counsel (Passthroughs & Special In-
dustries). For furtherinformation regard-
ing this notice, contact Ms. Fields at (202)
622–3050 (not a toll-free call).
26 CFR 601.105: Examination of returns and claims
for refund, credit, or abatement; determination of tax
liability.
Rev. Proc. 2009–34
SECTION 1. PURPOSE
This revenue procedure provides the
domestic asset/liability percentages and
domestic investment yields needed by for-
eign life insurance companies and foreign
property and liability insurance compa-
nies to compute their minimum effectively
connected net investment income under
section 842(b) of the Internal Revenue
Code for taxable years beginning after
December 31, 2007. Instructions are pro-
vided for computing foreign insurance
companies’ liabilities for the estimated tax
and installment payments of estimated tax
for taxable years beginning after Decem-
ber 31, 2007. For more specific guidance
regarding the computation of the amount
of net investment income to be included by
a foreign insurance company on its U.S. in-
come tax return, see Notice 89–96, 1989–2
C.B. 417. For the domestic asset/liability
percentage and domestic investment yield,
as well as instructions for computing for-
eign insurance companies’ liabilities for
estimated tax and installment payments of
estimated tax for taxable years beginning
after December 31, 2006, see Rev. Proc.
2008–53, 2008–36 I.R.B. 678.
SECTION 2. CHANGES
DOMESTICASSET/LIABILITY
PERCENTAGES FOR 2008. The Secre-
tary determines the domestic asset/liability
percentage separately for life insurance
companies and property and liability in-
surance companies. For the first taxable
year beginning after December 31, 2007,
the relevant domestic asset/liability per-
centages are:
118.6 percent for foreign life insurance
companies, and
183.4 percent for foreign property and
liability insurance companies.
.02 DOMESTIC INVESTMENT
YIELDS FOR 2008. The Secretary is
required to prescribe separate domestic in-
vestment yields for foreign life insurance
companies and for foreign property and
liability insurance companies. For the first
taxable year beginning after December 31,
2007, the relevant domestic investment
yields are:
5.3 percent for foreign life insurance
companies, and
3.6 percent for foreign property and li-
ability insurance companies.
.03 SOURCE OF DATA FOR 2008.
The section 842(b) percentages to be used
for the 2008 tax year are based on tax re-
turn data following the same methodology
used for the 2007 year.
SECTION 3. APPLICATION—
ESTIMATED TAXES
To compute estimated tax and the in-
stallment payments of estimated tax due
for taxable years beginning after Decem-
ber 31, 2007, a foreign insurance com-
2009–34 I.R.B.258August 24, 2009

pany must compute its estimated tax pay-
ments by adding to its income other than
net investment income the greater of (i) its
net investment income as determined un-
der section 842(b)(5), that is actually ef-
fectively connectedwith the conduct of a
trade or business within the United States
for the relevant period, or (ii) the mini-
mum effectively connected net investment
income under section 842(b) that would re-
sult from using the most recently available
domestic asset/liability percentage and do-
mestic investment yield. Thus, for install-
ment payments due after the publication of
this revenue procedure, the domestic as-
set/liability percentages and the domestic
investment yields provided in this revenue
procedure must be used to compute the
minimum effectively connected net invest-
ment income. However, if the due date of
an installment is less than 20 days after the
date this revenue procedure is published
in the Internal Revenue Bulletin, the as-
set/liability percentages and domestic in-
vestment yields provided in Rev. Proc.
2008–53 may be used to compute the mini-
mum effectively connected net investment
income for such installment. For further
guidance in computing estimated tax, see
Notice 89–96.
SECTION 4. EFFECTIVE DATE
This revenue procedure is effective for
taxable years beginning after December
31, 2007.
SECTION 5. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Sheila Ramaswamy of the
Office of Associate Chief Counsel (In-
ternational). For further information re-
garding this revenue procedure, contact
Sheila Ramaswamy at (202) 622–3870
(not a toll-free call).
August 24, 20092592009–34 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 rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of cases
in litigation, or the outcome of a Service
study.
Abbreviations
The 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.
2009–34 I.R.B.iAugust 24, 2009

Numerical Finding List
1
Bulletins 2009–27 through 2009–34
Announcements:
2009-56, 2009-28 I.R.B.145
2009-57, 2009-29 I.R.B.158
2009-58, 2009-29 I.R.B.158
2009-59, 2009-29 I.R.B.158
2009-60, 2009-30 I.R.B.166
2009-61, 2009-33 I.R.B.246
2009-62, 2009-33 I.R.B.247
2009-63, 2009-33 I.R.B.248
Notices:
2009-51, 2009-28 I.R.B.128
2009-55, 2009-31 I.R.B.170
2009-57, 2009-29 I.R.B.147
2009-58, 2009-30 I.R.B.163
2009-59, 2009-31 I.R.B.170
2009-60, 2009-32 I.R.B.181
2009-61, 2009-32 I.R.B.181
2009-63, 2009-34 I.R.B.252
2009-70, 2009-34 I.R.B.255
Proposed Regulations:
REG-152166-05, 2009-32 I.R.B.183
REG-112994-06, 2009-28 I.R.B.144
REG-113289-08, 2009-33 I.R.B.244
REG-130200-08, 2009-31 I.R.B.174
Revenue Procedures:
2009-30, 2009-27 I.R.B.27
2009-31, 2009-27 I.R.B.107
2009-32, 2009-28 I.R.B.142
2009-33, 2009-29 I.R.B.150
2009-34, 2009-34 I.R.B.258
Revenue Rulings:
2009-18, 2009-27 I.R.B.1
2009-19, 2009-28 I.R.B.111
2009-20, 2009-28 I.R.B.112
2009-21, 2009-30 I.R.B.162
2009-22, 2009-31 I.R.B.167
2009-23, 2009-32 I.R.B.177
Treasury Decisions:
9452, 2009-27 I.R.B.1
9453, 2009-28 I.R.B.114
9454, 2009-32 I.R.B.178
9455, 2009-33 I.R.B.239
9456, 2009-33 I.R.B.188
1
A cumulative list of all revenue rulings, revenueprocedures, Treasury decisions, etc., publishedin Internal Revenue Bulletins 2009–1 through 2009–26 is in Internal Revenue Bulletin
2009–26, dated June 29, 2009.
August 24, 2009ii2009–34 I.R.B.

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2009–27 through 2009–34
Announcements:
2006-93
Superseded by
Ann. 2009-62, 2009-33 I.R.B.247
Notices:
2004-67
Supplemented and superseded by
Notice 2009-59, 2009-31 I.R.B.170
2006-70
Obsoleted by
T.D. 9453, 2009-28 I.R.B.114
2006-109
Superseded in part by
Rev. Proc. 2009-32, 2009-28 I.R.B.142
2008-43
Obsoleted by
REG-113289-08, 2009-33 I.R.B.244
Revenue Procedures:
97-49
Modified and superseded by
Rev. Proc. 2009-31, 2009-27 I.R.B.107
2008-38
Superseded by
Rev. Proc. 2009-30, 2009-27 I.R.B.27
2008-65
Modified by
Rev. Proc. 2009-33, 2009-29 I.R.B.150
2009-16
Modified by
Rev. Proc. 2009-33, 2009-29 I.R.B.150
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2009–1 through 2009–26 is in Internal Revenue Bulletin 2009–26, dated June 29, 2009.
2009–34 I.R.B.iiiAugust 24, 2009

August 24, 20092009–34 I.R.B.

INTERNAL REVENUE BULLETIN
The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue
Bulletin is sold on a yearly subscription basis by the Superintendent of Documents. Current subscribers are notified by the Superin-
tendent of Documents when their subscriptions must be renewed.
CUMULATIVE BULLETINS
The contents of this weekly Bulletin are consolidated semiannually into a permanent, indexed, Cumulative Bulletin. These are
sold on a single copy basis andare notincluded as part of the subscription to the Internal Revenue Bulletin. Subscribers to the weekly
Bulletin are notified when copies of the Cumulative Bulletin are available. Certain issues of Cumulative Bulletins are out of print
and are not available. Persons desiring available Cumulative Bulletins, which are listed on the reverse, may purchase them from the
Superintendent of Documents.
ACCESS THE INTERNAL REVENUE BULLETIN ON THE INTERNET
You may view the Internal Revenue Bulletin on the Internet at www.irs.gov. Select Businesses. Under Businesses Topics, select
More Topics. Then select Internal Revenue Bulletins.
INTERNAL REVENUE BULLETINS ON CD-ROM
Internal Revenue Bulletins are available annually as part ofPublication 1796 (Tax Products CD-ROM). The CD-ROM can be
purchased from National Technical Information Service (NTIS) on the Internet at www.irs.gov/cdorders (discount for online orders)
or by calling 1-877-233-6767. The first release is available in mid-December and the final release is available in late January.
HOW TO ORDER
Check the publications and/or subscription(s) desired on the reverse, complete the order blank, enclose the proper remittance,
detach entire page, and mail to the Superintendent of Documents, P.O. Box 371954, Pittsburgh PA, 15250–7954. Please allow two to
six weeks, plus mailing time, for delivery.
WE WELCOME COMMENTS ABOUT THE INTERNAL
REVENUE BULLETIN
If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we
would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page (www.irs.gov)
or write to the IRS Bulletin Unit, SE:W:CAR:MP:T:T:SP, Washington, DC 20224.
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