Internal Revenue Bulletin 1997-15 (PDF rendition): IRS Revenue Rulings

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.

SPECIAL ANNOUNCEMENTS
Announcement 97–35, page 9.
The location of the public hearing on proposed regula-
tions, REG–209824–96, 1996–11 I.R.B. 19, is changed.
Announcement 97–37, page 10.
The date and location of the public hearing on proposed
regulations, REG–209817–96, 1997–7 I.R.B. 41, are
changed.
INCOME TAX
Rev. Rul. 97–18, page 4.
LIFO; price indexes; department stores.The February
1997 Bureau of Labor Statistics price indexes are
accepted for use by department stores employing the
retail inventory and the last-in, first-out inventory meth-
ods for valuing inventories for tax years ended on, or
with reference to, February 28, 1997.
EXEMPT ORGANIZATIONS
Announcement 97–34, page 8.
A list is given of organizations now classified as private
foundations.
ESTATE TAX
T.D. 8714, page 5.
REG–209830–96, page 7.
Temporary and proposed regulations under sections
2044 and 2056 of the Code relate to the estate tax
marital deduction to conform the Estate Tax Regulations
to recent court decisions. A public hearing on the
proposed regulations will be held on June 3, 1997.
ADMINISTRATIVE
Announcement 97–33, page 8.
T.D. 8708, 1997–10 I.R.B. 14, relating to the computa-
tion of foreign taxes deemed paid under section 902 of
the Code, is corrected.
Announcement 97–36, page 10.
T.D. 8701, 1997–7 I.R.B. 23, providing rules for making
the deemed sale and deemed dividend elections under
section 1291 of the Code, is corrected.
Announcement 97–38, page 10.
T.D. 8692, 1997–3 I.R.B. 4, relating to the reissuance
of mortgage credit certificates, is corrected.
Finding Lists begin on page 13.
Announcement of Disbarments and Suspensions begins on page 12.
Announcement of Declaratory Judgment Proceedings Under Section 7428 on page 11.
Bulletin No. 1997–15
April 14, 1997
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.

Mission of the Service
The purpose of the Internal Revenue Service is to
collect the proper amount of tax revenue at the least
cost; serve the public by continually improving the
quality of our products and services; and perform in a
manner warranting the highest degree of public
confidence in our integrity, efficiency and fairness.
Statement of Principles
of Internal Revenue
Tax Administration
The function of the Internal Revenue Service is to
administer the Internal Revenue Code. Tax policy
for raising revenue is determined by Congress.
With this in mind, it is the duty of the Service to
carry out that policy by correctly applying the laws
enacted by Congress; to determine the reasonable
meaning of various Code provisions in light of the
Congressional purpose in enacting them; and to
perform this work in a fair and impartial manner,
with neither a government nor a taxpayer point of view.
At the heart of administration is interpretation of the
Code. It is the responsibility of each person in the
Service, charged with the duty of interpreting the
law, to try to find the true meaning of the statutory
provision and not to adopt a strained construction in
the belief that he or she is ‘‘protecting the revenue.’’
The revenue is properly protected only when we as-
certain and apply the true meaning of the statute.
The Service also has the responsibility of applying
and administering the law in a reasonable,
practical manner. Issues should only be raised by
examining officers when they have merit, never
arbitrarily or for trading purposes. At the same
time, the examining officer should never hesitate
to raise a meritorious issue. It is also important
that care be exercised not to raise an issue or to
ask a court to adopt a position inconsistent with
an established Service position.
Administration should be both reasonable and
vigorous. It should be conducted with as little
delay as possible and with great courtesy and
considerateness. It should never try to overreach,
and should be reasonable within the bounds of law
and sound administration. It should, however, be
vigorous in requiring compliance with law and it
should be relentless in its attack on unreal tax
devices and fraud.
2

Introduction
The Internal Revenue Bulletin is the authoritative instru-
ment of the Commissioner of Internal Revenue for
announcing official rulings and procedures of the Inter-
nal Revenue Service and for publishing Treasury Deci-
sions, Executive Orders, Tax Conventions, legislation,
court decisions, and other items of general interest. It is
published weekly and may be obtained from the Superin-
tendent of Documents on a subscription basis. Bulletin
contents of a permanent nature are consolidated semi-
annually into Cumulative Bulletins, which are sold on a
single-copy basis.
It is the policy of the Service to publish in the Bulletin all
substantive rulings necessary to promote a uniform
application of the tax laws, including all rulings that
supersede, revoke, modify, or amend any of those
previously published in the Bulletin. All published rulings
apply retroactively unless otherwise indicated. Proce-
dures relating solely to matters of internal management
are not published; however, statements of internal
practices and procedures that affect the rights and
duties of taxpayers are published.
Revenue rulings represent the conclusions of the Ser-
vice 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 unwar-
ranted 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 proce-
dures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be consid-
ered, 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.—1986 Code.
This part includes rulings and decisions based on
provisions of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows:
Subpart A, Tax Conventions, and Subpart B, Legislation
and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to
these subjects are contained in the other Parts and
Subparts. Also included in this part are Bank Secrecy
Act Administrative Rulings. Bank Secrecy Act Administra-
tive Rulings are issued by the Department of the
Treasury’s Office of the Assistant Secretary (Enforce-
ment).
Part IV.—Items of General Interest.
With the exception of the Notice of Proposed Rulemak-
ing and the disbarment and suspension list included in
this part, none of these announcements are consoli-
dated in the Cumulative Bulletins.
The first Bulletin for each month includes an index for
the matters published during the preceding month.
These monthly indexes are cumulated on a quarterly and
semiannual basis, and are published in the first Bulletin
of the succeeding quarterly and semi-annual period,
respectively.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
For sale by the Superintendent of Documents U.S. Government Printing Office, Washington, D.C. 20402.
3

Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
Section 472.—Last-in, First-out
Inventories
26 CFR 1.472–1: Last-in, first-out inventories.
LIFO; price indexes; department
stores.The February 1997 Bureau of
Labor Statistics price indexes are ac-
cepted for use by department stores
employing the retail inventory and the
last-in, first-out inventory methods for
valuing inventories for tax years ended
on, or with reference to, February 28,
1997.
Rev. Rul. 97–18
The following Department Store In-
ventory Price Indexes for February 1997
were issued by the Bureau of Labor
Statistics on March 19, 1997. The in-
dexes are accepted by the Internal Rev-
enue Service, under § 1.472–1(k) of the
Income Tax Regulations and Rev. Proc.
86–46, 1986–2 C.B. 739, for appropriate
application to inventories of department
stores employing the retail inventory
and last-in, first-out inventory methods
for tax years ended on, or with reference
to, February 28, 1997.
The Department Store Inventory Price
Indexes are prepared on a national basis
and include (a) 23 major groups of
departments, (b) three special combina-
tions of the major groups - soft goods,
durable goods, and miscellaneous goods,
and (c) a store total, which covers all
departments, including some not listed
separately, except for the following:
candy, foods, liquor, tobacco, and con-
tract departments.
BUREAU OF LABOR STATISTICS, DEPARTMENT STORE
INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS
(January 1941 = 100, unless otherwise noted)
Groups
Feb.
1996
Feb.
1997
Percent Change
from Feb. 1996
to Feb. 1997
1
1. Piece Goods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .505.1526.44.2
2. Domestics and Draperies . . . . . . . . . . . . . . . . . . . . . . . . . . .651.2650.420.1
3. Women’s and Children’s Shoes. . . . . . . . . . . . . . . . . . . . . .644.5640.220.7
4. Men’s Shoes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .895.1897.70.3
5. Infants’ Wear. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .645.3617.724.3
6. Women’s Underwear . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .522.3534.22.3
7. Women’s Hosiery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .289.3296.52.5
8. Women’s and Girls’ Accessories . . . . . . . . . . . . . . . . . . . . .552.3546.921.0
9. Women’s Outerwear and Girls’ Wear . . . . . . . . . . . . . . . . .402.0417.63.9
10. Men’s Clothing. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .619.5615.420.7
11. Men’s Furnishings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .570.8585.12.5
12. Boys’ Clothing and Furnishings . . . . . . . . . . . . . . . . . . . . .476.6469.921.4
13. Jewelry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1003.41004.90.1
14. Notions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .813.7772.025.1
15. Toilet Articles and Drugs. . . . . . . . . . . . . . . . . . . . . . . . . . .871.0912.34.7
16. Furniture and Bedding . . . . . . . . . . . . . . . . . . . . . . . . . . . . .666.9662.020.7
17. Floor Coverings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .563.4581.23.2
18. Housewares. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .799.7817.02.2
19. Major Appliances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .249.2246.121.2
20. Radio and Television . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .79.078.620.5
21. Recreation and Education
2
. . . . . . . . . . . . . . . . . . . . . . . . . .113.6111.122.2
22. Home Improvements
2
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .123.1133.38.3
23. Auto Accessories
2
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .107.3107.90.6
Groups 1–15: Soft Goods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .590.0598.91.5
Groups 16–20: Durable Goods . . . . . . . . . . . . . . . . . . . . . . . . . .467.3470.00.6
Groups 21–23: Misc. Goods
2
. . . . . . . . . . . . . . . . . . . . . . . . . . .113.8113.320.4
Store Total
3
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .548.3554.21.1
1
Absence of a minus sign before percentage change in this column signifies price increase.
2
Indexes on a January 1986=100 base.
3
The store total index covers all departments, including some not listed separately, except for the following: candy, foods, liquor, tobacco, and contract depart-
ments.
4

DRAFTING INFORMATION
The principal author of this revenue
ruling is Stan Michaels of the Office of
Assistant Chief Counsel (Income Tax
and Accounting). For further information
regarding this revenue ruling, contact
Mr. Michaels on (202) 622–4970 (not a
toll-free call).
Section 2044.—Certain Property
for Which Marital Deduction Was
Previously Allowed
26 CFR 20.2044–1T: Certain property for which
marital deduction was previously allowed (tempo-
rary).
T.D. 8714
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 20
Estate and Gift Tax Marital
Deduction
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Temporary regulations.
SUMMARY: This document contains
temporary regulations amending the fi-
nal estate tax marital deduction regula-
tions. The amendments are made to
conform the estate tax regulations to
recent court decisions. The amendments
affect estates of decedents electing the
marital deduction for qualified termi-
nable interest property (QTIP) and the
estates of the surviving spouses of such
decedents. The text of these temporary
regulations also serves as the text of
REG–209830–96, page 7.
DATES: These regulations are effective
February 18, 1997.
For dates of applicability of these
regulations, see Effective Date under
SUPPLEMENTARY INFORMATION.
FOR FURTHER INFORMATION
CONTACT: Susan B. Hurwitz at (202)
622–3090 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
On March 1, 1994, the IRS published
final Estate and Gift Tax Regulations
(26 CFR part 20 and part 25) under
sections 2044, 2056, 2207A, 2519,
2523, and 6019 of the Internal Revenue
Code (Code) in theFederal Register
(59 FR 9642). At the time the regula-
tions were published, the position con-
tained in § 20.2056(b)–7(d)(3) was the
subject of litigation in a number of
cases and had been rejected by two
circuit courts inEstate of Clayton v.
Commissioner, 976 F.2d 1486 (5th Cir.
1992),rev’g97 T.C. 327 (1991), and
Estate of Robertson v. Commissioner, 15
F.3d 779 (8th Cir. 1994),rev’g98 T.C.
678 (1992). Since that time,Estate of
Spencer v. Commissioner, 43 F.3d 226
(6th Cir. 1995),rev’gT.C. Memo.l
1992–579, also rejecting the IRS posi-
tion, has been decided. Additionally, in
Estate of Clack v. Commissioner, 106
T.C. 131 (1996), the Tax Court reversed
the position it had taken previously in
Estate of Clayton,Estate of Robertson,
andEstate of Spencer. This temporary
regulation amends the final regulations
in accordance with the circuit courts’
decisions inEstate of Clayton,Estate of
Robertson, andEstate of Spencer, and
the Tax Court’s decision inEstate of
Clack.
Explanation of Provisions
Section 20.2056(b)–7T(d)(3)(ii) has
been added. As a result of the addition,
an income interest (or life estate) that is
contingent upon the executor’s election
under section 2056(b)(7)(B)(v) will not
be precluded, on that basis, from qualifi-
cation as a ‘‘qualifying income interest
for life’’ within the meaning of section
2056(b)(7)(B)(ii).
In accordance with the addition of
§ 2 0 . 2 0 5 6 ( b ) – 7 T ( d ) ( 3 ) ( i i ) ,
§ 20.2056(b)–7T(h)Example 6(ii) and
§ 20.2044–1TExample 8are added.
Effective Date
These regulations are effective in the
case of qualified terminable interest
property elections made after February
18, 1997.
Special Analyses
It has been determined that this Trea-
sury decision is not a significant regula-
tory action as defined in EO 12866.
Therefore, a regulatory assessment is not
required. It has also been determined
that section 553(b) of the Administrative
Procedure Act (5 U.S.C. chapter 5) does
not apply to these regulations and, be-
cause these regulations do not impose
on small entities a collection of informa-
tion requirement, the Regulatory Flex-
ibility Act (5 U.S.C. chapter 6) does not
apply. Therefore, a Regulatory Flexibil-
ity Analysis is not required. Pursuant to
section 7805(f) of the Internal Revenue
Code, these temporary regulations will
be submitted to the Chief Counsel for
Advocacy of the Small Business Admin-
istration for comment on their impact on
small business.
Drafting Information
The principal author of these regula-
tions is Susan B. Hurwitz, Office of
Assistant Chief Counsel (Passthroughs
and Special Industries). However, other
personnel from the IRS and Treasury
Department participated in their devel-
opment.
* * * * *
Adoption of Amendments to the Regula-
tions
Accordingly, 26 CFR part 20 is
amended as follows:
PART 20—ESTATE TAX; ESTATES
OF DECEDENTS DYING AFTER AU-
GUST 16, 1954
Paragraph 1. The authority citation
for part 20 continues to read in part as
follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 20.2044–1T is added
to read as follows:
§ 20.2044–1T Certain property for
which marital deduction was previously
allowed (temporary).
(a) through (d). [Reserved]. For fur-
ther guidance, see § 20.2044–1(a)
through (d).
(e)Examples.[Reserved]. For further
guidance, see § 20.2044–1(e).
Example 1throughExample 7. [Re-
served]. For further guidance, see
§ 20.2044–1(e)Example 1throughEx-
ample 7.
Example 8. Inclusion of trust property when
surviving spouse dies before first decedent’s estate
tax return is filed.D dies on July 1, 1997. D’s
estate tax return is due after February 18, 1997.
Under the terms of D’s will, a trust is established
for the benefit of D’s spouse, S. The will provides
that S is entitled to receive the income from that
portion of the trust that the executor elects to treat
as qualified terminable interest property. The trust
terms otherwise provide S with a qualifying
income interest for life under section
2056(b)(7)(B)(ii). S dies on February 10, 1998. On
April 1, 1998, D’s executor files D’s estate tax
return on which an election is made to treat a
portion of the trust as qualified terminable interest
property under section 2056(b)(7). S’s estate tax
return is filed on November 10, 1998. The value
on the date of S’s death of the portion of the trust
for which D’s executor made a QTIP election is
includible in S’s gross estate under section 2044.
Par. 3. Section 20.2056(b)–7T is
added to read as follows:
5

§ 20.2056(b)–7T Election with respect
to life estate for surviving spouse (tem-
porary).
(a) through (d)(2) [Reserved]. For
further guidance, see § 20.2056(b)–7(a)
through (d)(2).
(d)(3)Contingent income interests. (i)
[Reserved]. For further guidance, see
§ 20.2056(b)–7(d)(3).
(ii) An income interest for a term of
years, or a life estate subject to termina-
tion upon the occurrence of a specified
event (e.g., remarriage), is not a qualify-
ing income interest for life. However, an
income interest for life (or life estate)
that is contingent upon the executor’s
election under section 2056(b)(7)(B)(v)
will not, on that basis, fail to be a
qualifying income interest for life. This
paragraph (d)(3)(ii) applies with respect
to estates of decedents whose estate tax
returns are due after February 18, 1997.
(d)(4) through (g) [Reserved]. For
further guidance see § 20.2056(b)–
7(d)(4) through (g).
(h)Examples. [Reserved]. See
§ 20.2056(b)–7(h).
Example 1throughExample 5. [Re-
served]. For further guidance, see
§ 20.2056(b)–7(h)Example 1through
Example 5.
Example 6. (i) [Reserved]. For further
guidance, see § 20.2056(b)–7(h)Ex-
ample 6.
(ii) D’s estate tax return is due after February
18, 1997. D’s will established a trust providing
that S is entitled to receive the income from that
portion of the trust that the executor elects to treat
as qualified terminable interest property. S’s inter-
est in the trust otherwise meets the requirements
of a qualifying income interest for life under
section 2056(b)(7)(B)(ii). Accordingly, the execu-
tor may elect qualified terminable interest treat-
ment for any portion of the trust.
Par. 4. Section 20.2056(b)–10T is
added to read as follows:
§ 20.2056(b)–10T Effective dates (tem-
porary).
In addition to the effective dates set
out in § 20.2056(b)–10, § 20.2056(b)–
7T(d)(3)(ii) is effective with respect to
estates of decedents dying after March
1, 1994. For further guidance, see
§ 20.2056(b)–10.
Margaret Milner Richardson,
Commissioner of Internal Revenue.
Approved January 8, 1997.
Donald C. Lubick,
Assistant Secretary of the Treasury.
(Filed by the Office of the Federal Register on
February 14, 1997, 8:45 a.m., and published in the
issue of the Federal Register for February 18,
1997, 62 F.R. 7156)
6

Part IV. Items of General Interest
Notice of Proposed Rulemaking
and Notice of Public Hearing
Estate and Gift Tax Marital
Deduction
REG–209830–96
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of proposed rulemak-
ing by cross-reference to temporary
regulations and notice of public hearing.
SUMMARY: In T.D. 8714, page 5, the
IRS is issuing temporary regulations
relating to the estate tax marital deduc-
tion to conform the Estate Tax Regula-
tions to recent court decisions. The text
of those temporary regulations also
serves as the text of these proposed
regulations. This document also provides
notice of a public hearing on these
proposed regulations.
DATES: Comments must be received by
May 19, 1997. Outlines of topics to be
discussed at the public hearing sched-
uled for June 3, 1997, at 10 a.m. must
be received by May 13, 1997.
ADDRESSES: Send submissions to:
CC:DOM:CORP:R (REG–209830–96),
room 5228, Internal Revenue Service,
POB 7604, Ben Franklin Station, Wash-
ington, DC 20044. Submissions may
also be hand delivered between the
hours of 8 a.m. and 5 p.m. to:
CC:DOM:CORP:R (REG–209830–96),
Courier’s Desk, Internal Revenue Ser-
vice, 1111 Constitution Avenue NW,
Washington, DC. Alternatively, taxpay-
ers may submit comments electronically
via the internet by selecting the ‘‘Tax
Regs’’ option on the IRS Home Page, or
by submitting comments directly to the
IRS internet site at http://www.irs.
ustreas.gov/prod/tax regs/comments.
html. The public hearing will be held in
the Commissioner’s Conference Room,
room 3313, Internal Revenue Building,
1111 Constitution Avenue NW, Washing-
ton, DC.
FOR FURTHER INFORMATION CON-
TACT: Concerning the regulations, Su-
san B. Hurwitz, (202) 622–3090; con-
cerning submissions and the hearing,
Evangelista Lee, (202) 622–7190 (not
toll-free numbers).
SUPPLEMENTARY
INFORMATION:
Background
Temporary regulations in T.D. 8714
amend the Estate Tax Regulations (26
CFR part 20) relating to sections 2044
and 2056. The temporary regulations
conform the estate tax marital deduction
regulations to recent court decisions in
Estate of Clayton v. Commissioner, 976
F.2d 1486 (5th Cir. 1992),rev’g97 T.C.
327 (1991);Estate of Robertson v. Com-
missioner, 15 F.3d 779 (8th Cir. 1994),
rev’g98 T.C. 678 (1992);Estate of
Spencer v. Commissioner, 43 F.3d 226
(6th Cir. 1995),rev’gT.C. Memo. 1992–
579; andEstate of Clack v. Commis-
sioner, 106 T.C. 131 (1996).
The text of those temporary regula-
tions also serves as the text of these
proposed regulations. The preamble to
the temporary regulations explains the
temporary regulations.
Special Analyses
It has been determined that this notice
of proposed rulemaking is not a signifi-
cant regulatory action as defined in EO
12866. Therefore, a regulatory assess-
ment is not required. It has also been
determined that section 553(b) of the
Administrative Procedure Act (5 U.S.C.
chapter 5) does not apply to these
regulations and, because these regula-
tions do not impose on small entities a
collection of information requirement,
the Regulatory Flexibility Act (5 U.S.C.
chapter 6) does not apply. Therefore, a
Regulatory Flexibility Analysis is not
required. Pursuant to section 7805(f) of
the Internal Revenue Code, this notice
of proposed rulemaking will be submit-
ted to the Chief Counsel for Advocacy
of the Small Business Administration for
comment on its impact on small busi-
ness.
Comments and Public Hearing
Before these proposed regulations are
adopted as final regulations, consider-
ation will be given to any comments
that are submitted timely (in the manner
described in ADDRESSES) to the IRS.
All comments will be available for
public inspection and copying.
A public hearing has been scheduled
for June 3, 1997, at 10 a.m. in the
Commissioner’s Conference Room,
room 3313, Internal Revenue Building,
1111 Constitution Avenue NW, Washing-
ton, DC. Because of access restrictions,
visitors will not be admitted beyond the
building lobby more than 15 minutes
before the hearing starts.
The rules of 26 CFR 601.601(a)(3)
apply to the hearing.
Persons that wish to present oral
comments at the hearing must submit
comments by May 19, 1997, and submit
an outline of the topics to be discussed
and the time to be devoted to each topic
by May 13, 1997.
A period of 10 minutes will be allot-
ted to each person for making com-
ments.
An agenda showing the scheduling of
the speakers will be prepared after the
deadline for receiving outlines has
passed. Copies of the agenda will be
available free of charge at the hearing.
Drafting Information
The principal author of the proposed
regulations is Susan B. Hurwitz, Office
of Assistant Chief Counsel
(Passthroughs and Special Industries).
However, other personnel from the IRS
and the Treasury Department partici-
pated in their development.
* * * * *
Proposed Amendments to the Regula-
tions
Accordingly, 26 CFR part 20 is pro-
posed to be amended as follows:
PART 20—ESTATE TAX; ESTATES
OF DECEDENTS DYING AFTER AU-
GUST 16, 1954
Paragraph 1. The authority citation for
part 20 continues to read in part as
follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. In § 20.2044–1, paragraph (e)
Example 8 is added to read as follows:
§ 20.2044–1 Certain property for which
marital deduction was previously al-
lowed.
[The text of paragraph (e)Example 8
as proposed is the same as the text of
§ 20.2044–1T(e)Example 8published
inT.D. 8714].
Par. 3. Section 20.2056(b)–7 is
amended to read as follows:
§ 20.2056(b)–7 Election with respect to
life estate for surviving spouse.
[The text of paragraphs (d)(3), and (h)
Example 6is the same as the text of
71997–15 I.R.B.

§ 20.2056(b)–7T(d)(3)(ii), and (h)Ex-
ample 6published in T.D. 8714].
Par. 4. Section 20.2056(b)–10 is re-
vised to read as follows:
§ 20.2056(b)–10 Effective dates.
Except as specifically provided in
§§ 20.2056(b)–5(c)(3)(ii) and (iii),
20.2056(b)–7T(d)(3), 20.2056(b)–7(e)-
(5), and 20.2056(b)–8(b), the provisions
of §§ 20.2056(b)–5(c), 20.2056(b)–7,
20.2056(b)–8, and 20.2056(b)–9 are ef-
fective with respect to estates of dece-
dents dying after March 1, 1994. With
respect to decedents dying on or before
March 1, 1994, the executor of the
decedent’s estate may rely on any rea-
sonable interpretation of the statutory
provisions. For these purposes, the pro-
visions of §§ 20.2056(b)–5(c),
20.2056(b)–7, 20.2056(b)–8, and
20.2056(b)–9 (as well as project LR–
211–76 (1984–1 C.B. 598), see
§ 601.601(d)(2)(ii)(b) of this chapter),
are considered a reasonable interpreta-
tion of the statutory provisions.
Margaret Milner Richardson,
Commissioner of Internal Revenue.
(Filed by the Office of the Federal Register on
February 14, 1997, 8:45 a.m., and published in the
issue of the Federal Register for February 18,
1997, 62 F.R. 7156)
Computation of Foreign Taxes
Deemed Paid Under Section 902
Pursuant to a Pooling Mechanism
for Undistributed Earnings and
Foreign Taxes; Correction
Announcement 97–33
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Correction to final regula-
tions.
SUMMARY: This document contains a
correction to final income tax regula-
tions which were published in theFed-
eral Registeron Tuesday, January 7,
1997 (62 FR 923 [T.D. 8708, 1997–10
I.R.B. 14]) relating to the computation
of foreign taxes deemed paid under
section 902.
EFFECTIVE DATE: January 7, 1997.
FOR FURTHER INFORMATION CON-
TACT: Caren S. Shein (202) 622–3850,
(not a toll-free number).
SUPPLEMENTARY
INFORMATION:
Background
The final regulations that are the
subject of this correction are under
section 902 of the Internal Revenue
Code. Need for Correction
As published, the final regulations
contain an error which may prove to be
misleading and is in need of clarifica-
tion.
Correction of Publication
Accordingly, the publication of the
final regulations (TD 8708), which are
the subject of FR Doc. 97–153, is
corrected as follows:
On page 940, column 3, § 1.902–3
(l), the sixth line from the bottom of the
paragraph, the language ‘‘See § 1.902–1
(a)(13)(iii). For’’ is corrected to read
‘‘See § 1.902–1 (a)(13)(i). For’’.
Michael L. Slaughter,
Acting Chief, Regulations Unit,
Assistant Chief Counsel (Corporate).
(Filed by the Office of the Federal Register on
February 14, 1997, 8:45 a.m., and published in the
issue of the Federal Register for February 18,
1997, 62 F.R. 7155)
Foundations Status of Certain
Organizations
Announcement 97–34
The following organizations have
failed to establish or have been unable
to maintain their status as public chari-
ties or as operating foundations. Accord-
ingly, grantors and contributors may not,
after this date, rely on previous rulings
or designations in the Cumulative List
of Organizations (Publication 78), or on
the presumption arising from the filing
of notices under section 508(b) of the
Code. This listing doesnotindicate that
the organizations have lost their status
as organizations described in section
501(c)(3), eligible to receive deductible
contributions.
Former Public Charities. The follow-
ing organizations (which have been
treated as organizations that are not
private foundations described in section
509(a) of the Code) are now classified
as private foundations:
Arizona Conservation Alliance, Phoenix,
AZ
Arizona Womens Retreat, Scottsdale, AZ
Arkansas Child Care Consultant Inc.,
Ashdown, AR
Arthur Jones Memorial Center, Houston,
TX
Artsake Foundation, Tucson, AZ
Bridgebuilders International, Inc., Mesa,
AZ
Bright Hopes Foundation, Albuquerque,
NM
Brookstone Human Development Project
Inc., Randleman, NC
Boulder Youth Choir, Boulder, CO
Boys & Girls Club of El Campo Texas,
Inc., El Campo, TX
Childrens Choice Daycare, Ogden, UT
Childrens Fund, Inc., Fort Collins, CO
Childrens Lifeline Network, Houston,
TX
Childrens Treasure Chest, Wichita Falls,
TX
Children United To Save the Planet,
Phoenix, AZ
Desert Hope Inc., Chandler, AZ
Diadem Evangelistic Association Inc.,
Euless, TX
Family Connection, Chester, PA
Fare Share, Inc., Kingston, NY
Fil Am Friendship Coalition,
Framingham, MA
Gallery X, Inc., New Bedford, MA
Gay Info Line of New Hampshire,
Nashua, NH
Genesis 3 Inc., Coffeyville, KS
Harvest International Missions, Inc.,
Dallas, TX
Harvest Ministries International Inc.,
Dallas, TX
Head Injury Events, Carr, CO
Healthy Mothers Healthy Babies Austin
Chapter, Austin, TX
Heart at Home Inc., Austin, TX
Imagination Central, Venice, CA
In Celebration of Life, Santa Rosa, CA
Indian Diggings Volunteer Club,
Somerset, CA
Infection Control Nurses of Connecticut,
Inc., Hamden, CT
In His Service Foundation, Inc., Dallas,
TX
Jail Industries Association, Wakefield,
MA
Jesus & Me Ministries Inc., Colorado
Springs, CO
John A. Reisenback Foundation, Inc.,
New York, NY
John’s Place, Dorchester, MA
Kimball Pines Non-Profit Housing
Corporation, Battle Creek, MI
Kindred Spirit Pictures Inc., Hilton
Head Is, SC
Kingwood Heartbeat Bears, Kingwood,
TX
Las Vegas Development Corporation
LaVedelco, Las Vegas, NM
Linden Firefighters Association, Linden,
MI
81997–15 I.R.B.

Lion and Lamb Edu-Cable, Inc.,
Englewood, CO
Martin Luther King Jr Center for
Nonviolence, Los Angeles, CA
Menezes Group Homes Inc., San
Leandro, CA
Metro Outreach Ministry, Baton Rouge,
LA
Metropolitan Canal Alliance, Inc.,
Tempe, AZ
Mid-Cities Swim Team, Euless, TX
Mid-Kansas Bandits Soccer Club,
Wichita, KS
Missing Link Inc., Tulsa, OK
Native American Cultural Museum Inc.,
Grants, NM
Neighbours International, Wyoming, MI
New Mexico State University Dance
Company, Las Cruces, NM
North County Educational Assistance
Program, NCEAP, Sarasota, FL
Northern Children Network Inc.,
Philadelphia, PA
Orange Avenue Home, Newport Beach,
CA
Oregon Wheelchair Tennis Association,
Portland, OR
Original Kids Under Construction, Inc.,
Anderson, IN
Organization of Professional Emp. of
the US Dept of Argic Opeda
Scholarship Fund, Washington, DC
Our Gang Players Inc., Barnegat Light,
NJ
Parents Against Gangs Education Inc.,
Pueblo, CO
Partners for the Educational
Enhancement Daleville Schools Inc.,
Daleville, AL
Partners in the Community, Kelso, WA
Partners in the Environment Inc.,
Lorton, VA
Pastoral Training of Asia Inc., El Toro,
CA
Pathway to Power Ministries Inc.,
Newark, NJ
Patient Services Inc., Midlothian, VA
PCMSP Housing Corporation,
Pittsburgh, PA
Pearce Outreach International, Rockwall,
TX
Pedro Farela, Falls Church, VA
R and R Residential Homes, Sylmar,
CA
Reflective Image, San Francisco, CA
Renaissance Consort of Ft Worth Inc.,
Ft. Worth, TX
Rescue Our Children Mission, Dallas,
TX
Resurrection Ministries, Inc., Tulsa, OK
South Georgia Nazarene Christian Day
Care, Amarillo, TX
Southside Fire Truck Park Fund,
Houston, TX
South Texas Alcohol and Drug
Rehabilitation Center, Inc., Alice, TX
South Texas Classic Guitar Society, Inc.,
McAllen, TX
Southwest Correctional Arts Network,
Austin, TX
Stop Wasting Americas Taxes, Inc.,
Tulsa, OK
Strawberry Patch Kids, Inc., Layton, UT
Street Intervention Project, Denver, CO
Success Nutrition Food Program,
Houston, TX
Sudden Arrhythmia Death Syndromes
Foundation, Salt Lake City, UT
Theatre for Texas Youth, Inc., Dallas,
TX
Thornton Arts Sciences and Humanities
Council, Inc., Thornton, CO
Tickets to Paradise Inc., Miami, FL
Urban Assisted Housing Coalition, Inc.,
San Francisco, CA
Urban Health Alliance, Inc., San
Francisco, CA
Urban Theatre Project Inc., Denver, CO
U S-Japan Institute of Management and
Technology, Dallas, TX
Vision for Children International
Foundation, Inc., Salt Lake City, UT
Vision 100, Lewisville, TX
Vital Alliance, San Antonio, TX
Wisdom Communications UTH,
Columbus, OH
W L D Johnson Scholarship Foundation,
Dallas, TX
Womens Sanctuary, Denver, CO
Wood County Casa, Inc., Winnsboro,
TX
World Vista Foundation Inc., Bay
Village, OH
If an organization listed above sub-
mits information that warrants the re-
newal of its classification as a public
charity or as a private operating founda-
tion, the Internal Revenue Service will
issue a ruling or determination letter
with the revised classification as to
foundation status. Grantors and contribu-
tors may thereafter rely upon such rul-
ing or determination letter as provided
in section 1.509(a)–7 of the Income Tax
Regulations. It is not the practice of the
Service to announce such revised classi-
fication of foundation status in the Inter-
nal Revenue Bulletin.
Definition of Limited Partner for
Self-Employment Tax Purposes;
Hearing
Announcement 97–35
AGENCY: Internal Revenue Service,
Treasury.
ACTION: Proposed rule; change of lo-
cation of public hearing.
SUMMARY: This document changes
the location of the public hearing on
proposed regulations relating to the self-
employment income tax imposed under
section 1402 of the Internal Revenue
Code of 1986.
DATES: The public hearing is being
held on Wednesday, May 21, 1997,
beginning at 10:00 a.m. Requests to
speak and outlines of oral comments
must be received by April 30, 1997.
ADDRESSES: The public hearing origi-
nally scheduled in the IRS Auditorium,
Internal Revenue Building, 1111 Consti-
tution Avenue NW, Washington, DC is
changed to room 5716, Internal Revenue
Building, 1111 Constitution Avenue NW,
Washington, DC.
FOR FURTHER INFORMATION
CONTACT: Christina Vasquez of the
Regulations Unit, Assistant Chief Coun-
sel (Corporate), (202) 622–7180 (not a
toll-free number).
SUPPLEMENTARY INFORMATION:
A notice of proposed rulemaking and
notice of public hearing appearing in the
Federal Register on Monday, January
13, 1997 (62 FR 1702 [REG–209824–
96, 1996–11 I.R.B. 19]) announced that
a public hearing on proposed regulations
relating to the self-employment income
tax imposed under section 1402 of the
Internal Revenue Code of 1986 would
be held on Wednesday, May 21, 1997,
beginning at 10:00 a.m. in the IRS
Auditorium, Internal Revenue Building,
1111 Constitution Avenue NW, Washing-
ton, DC and that requests to speak and
outlines of oral comments should be
received by Wednesday, April 30, 1997.
The location of the pubic hearing has
changed. The hearing is scheduled for
Wednesday, May 21, 1997, beginning at
10:00 a.m. in room 5716, Internal Rev-
enue Building, 1111 Constitution Avenue
NW, Washington, DC. We must receive
the requests to speak and outlines of
oral comments by Wednesday, April 30,
1997. Because of controlled access re-
strictions, attenders are not admitted
beyond the lobby of the Internal Rev-
enue Building until 9:45 a.m.
The Service will prepare an agenda
showing the scheduling of the speakers
after the outlines are received from the
91997–15 I.R.B.

persons testifying and make copies
available free of charge at the hearing.
Cynthia E. Grigsby,
Chief, Regulations Unit,
Assistant Chief Counsel (Corporate).
(Filed by the Office of the Federal Register on
March 11, 1997, 8:45 a.m., and published in the
issue of the Federal Register for March 12, 1997,
62 F.R. 11394)
Treatment of Shareholders of
Certain Passive Foreign Investment
Companies; Correction
Announcement 97–36
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Correction to final regula-
tions.
SUMMARY: This document contains a
correction to final regulations (T.D.
8701 [1997–7 I.R.B. 23]) which were
published in the Federal Register on
Friday, December 27, 1996 (61 FR
68149). The final regulations provide
rules for making a deemed sale or
deemed dividend election to purge a
shareholder’s holding period of stock of
a PFIC of those taxable years during
which the PFIC was not a QEF.
EFFECTIVE DATE: December 27,
1996.
FOR FURTHER INFORMATION
CONTACT: Gayle Novig (202) 622–
3880 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations that are subject
to this correction is under section 1291
of the Internal Revenue Code.
Need for Correction
As published, the final regulations
(T.D. 8701) contains an error that may
prove to be misleading and is in need of
clarification.
Correction of Publication
Accordingly, the publication of final
and temporary regulations (T.D. 8701)
which is the subject of FR Doc. 96–
32246 is corrected as follows:
§ 1.1291–9 [Corrected]
On page 68152, column 3, § 1.1291–
9, paragraph (d)(2)(i), line 9, the lan-
guage ‘‘taxable year of inclusion of
each’’ is corrected to read ‘‘taxable year
or years of inclusion of each’’.
Michael L. Slaughter,
Acting Chief, Regulations Unit,
Assistant Chief Counsel (Corporate).
(Filed by the Office of the Federal Register on
February 14, 1997, 8:45 a.m., and published in the
issue of the Federal Register for February 18,
1997, 62 F.R. 7155)
Treatment of Obligation-Shifting
Transactions; Hearing
Announcement 97–37
AGENCY: Internal Revenue Service,
Treasury.
ACTION: Proposed rule; change of date
and location of public hearing.
SUMMARY: This document changes
the date and location of the public
hearing on proposed regulations relating
to the treatment of certain multiple-party
financing transactions in which one
party realizes income from leases or
similar agreements and another party
claims deductions related to that income.
DATES: The public hearing is being
held on Wednesday, May 14, 1997,
beginning at 10:00 a.m. Requests to
speak and outlines of oral comments
must be received by April 23, 1997.
ADDRESSES: The public hearing origi-
nally scheduled in the IRS Auditorium,
Internal Revenue Building, 1111 Consti-
tution Avenue NW, Washington, DC is
changed to room 2615, Internal Revenue
Building, 1111 Constitution Avenue NW,
Washington, DC.
FOR FURTHER INFORMATION
CONTACT: Christina Vasquez of the
Regulations Unit, Assistant Chief Coun-
sel (Corporate), (202) 622–7180 (not a
toll-free number).
SUPPLEMENTARY INFORMATION:
A notice of proposed rulemaking and
notice of public hearing appearing in the
Federal Register on Friday, December
27, 1996 (61 FR 68175 [REG–209817–
96, 1997–7 I.R.B. 41]), announced that
a public hearing on proposed regulations
relating to the treatment of certain
multiple-party financing transactions in
which one party realizes income from
leases or similar agreements and another
party claims deductions related to that
income would be held on Tuesday, April
29, 1997, beginning at 10:00 a.m. in the
IRS Auditorium, Internal Revenue
Building, 1111 Constitution Avenue NW,
Washington, DC and that requests to
speak and outlines of oral comments
should be received by Tuesday, April 8,
1997.
The date and location of the pubic
hearing has changed. The hearing is
scheduled for Wednesday, May 14,
1997, beginning at 10:00 a.m. in room
2615, Internal Revenue Building, 1111
Constitution Avenue NW, Washington,
DC. We must receive the requests to
speak and outlines of oral comments by
Wednesday, April 23, 1997. Because of
controlled access restrictions, attenders
are not admitted beyond the lobby of
the Internal Revenue Building until 9:45
a.m.
The Service will prepare an agenda
showing the scheduling of the speakers
after the outlines are received from the
persons testifying and make copies
available free of charge at the hearing.
Cynthia E. Grigsby,
Chief, Regulations Unit,
Assistant Chief Counsel (Corporate).
(Filed by the Office of the Federal Register on
February 4, 1997, 8:45 a.m., and published in the
issue of the Federal Register for February 5, 1997,
62 F.R. 5355)
Reissuance of Mortgage Credit
Certificates; Correction
Announcement 97–38
AGENCY: Internal Revenue Service,
Treasury.
ACTION: Correction to the final and
temporary regulations.
SUMMARY: This document contains a
correction to the final and temporary
regulations (T.D. 8692 [1997–3 I.R.B.
4]) which were published in theFederal
Registeron Tuesday, December 17,
1996 (61 FR 66212). The final and
temporary regulations relates to the reis-
suance of mortgage credit certificates.
EFFECTIVE DATE: December 17,
1996.
FOR FURTHER INFORMATION
CONTACT: Michael Wachtel, (202)
622–3980 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final and temporary regulations
that is subject to this correction is under
section 25 of the Internal Revenue
Code.
101997–15 I.R.B.

Need for Correction
As published, the final and temporary
regulations (T.D. 8692) contains an error
which may prove to be misleading and
is in need of clarification.
Correction of Publication
Accordingly, the publication of the
final and temporary regulations (T.D.
8692) which is the subject of FR Doc.
96–31772 is corrected as follows:
On page 66212, column 3, in the
heading, the RIN‘‘RIN 1545–AR57’’is
corrected to read‘‘RIN 1545–AR76’’.
Cynthia E. Grigsby,
Chief, Regulations Unit,
Assistant Chief Counsel (Corporate).
(Filed by the Office of the Federal Register on
February 13, 1997, 8:45 a.m., and published in the
issue of the Federal Register for February 14,
1997, 62 F.R. 6874)
Section 7428(c) Validation of
Certain Contributions Made During
Pendency of Declaratory Judgment
Proceedings
This announcement serves notice to
potential donors that the organization
listed below has recently filed a timely
declaratory judgment suit under section
7428 of the Code, challenging revoca-
tion of its status as an eligible donee
under section 170(c)(2).
Protection under section 7428(c) of
the Code begins on the date that the
notice of revocation is published in the
Internal Revenue Bulletin and ends on
the date on which a court first deter-
mines that an organization is not de-
scribed in section 170(c)(2), as more
particularly set forth in section
7428(c)(1). In the case of individual
contributors, the maximum amount of
contributions protected during this pe-
riod is limited to $1,000.00, with a
husband and wife being treated as one
contributor. This protection is not ex-
tended to any individual who was re-
sponsible, in whole or in part, for the
acts or omissions of the organization
that were the basis for the revocation.
This protection also applies (but without
limitation as to amount) to organizations
described in section 170(c)(2) which are
exempt from tax under section 501(a). If
the organization ultimately prevails in
its declaratory judgment suit, deductibil-
ity of contributions would be subject to
the normal limitations set forth under
section 170.
Spartanburg Gospel Workshop, Inc.
Spartanburg, SC
111997–15 I.R.B.

Announcement of the Disbarment, Suspension, or Consent to Voluntary
Suspension of Attorneys, Certified Public Accountants, Enrolled Agents and
Enrolled Actuaries From Practice Before the Internal Revenue Service
Under 31 Code of Federal Regula-
tions, Part 10, an attorney, certified pub-
lic accountant, enrolled agent or enrolled
actuary, in order to avoid the institution
or conclusion of a proceeding for his
disbarment or suspension from practice
before the Internal Revenue Service,
may offer his consent to suspension
from such practice. The Director of
Practice, in his discretion, may suspend
an attorney, certified public accountant,
enrolled agent or enrolled actuary in
accordance with the consent offered.
Attorneys, certified public accoun-
tants, enrolled agents and enrolled actu-
aries are prohibited in any Internal Rev-
enue Service matter from directly or
indirectly employing, accepting assis-
tance from, being employed by or shar-
ing fees with, any practitioner disbarred
or suspended from practice before the
Internal Revenue Service.
To enable attorneys, certified public
accountants, enrolled agents and en-
rolled actuaries to identify practitioners
under consent suspension from practice
before the Internal Revenue Service, the
Director of Practice will announce in the
Internal Revenue Bulletin the names and
addresses of practitioners who have
been suspended from such practice, their
designation as attorney, certified public
accountant, enrolled agent or enrolled
actuary, and date or period of suspen-
sion. This announcement will appear in
the weekly Bulletin at the earliest practi-
cable date after such action and will
continue to appear in the weekly Bulle-
tins for five successive weeks or for as
many weeks as is practicable for each
attorney, certified public accountant, en-
rolled agent or enrolled actuary so sus-
pended and will be consolidated and
published in the Cumulative Bulletin.
The following individuals have been
placed under consent suspension from
practice before the Internal Revenue
Service:
NameAddressDesignationDate of Suspension
Vlymen, Neal VanSan Diego, CACPAIndefinite from November 1, 1996
Lombardi, TheresaLivonia, MICPANovember 1, 1996 to October 31, 1998
Orfall, WarrenHood River, ORCPANovember 1, 1996 to June 30, 1997
Oberman, JosephHighland Park, ILCPADecember 1, 1996 to August 31, 1997
Gazzola, FrankN. Mankato, MNCPADecember 1, 1996 to November 30, 1997
Tumminello, Anthony G.St. Louis, MOAttorneyDecember 17, 1996 to June 16, 1997
Heffelfinger, Harry N.Buffalo Grove, ILCPADecember 20, 1996 to June 19, 1998
Zintl Jr., Ernst J.Newport, MNCPADecember 23, 1996 to December 22, 1997
Alms, William R.Lake Forest, CACPAJanuary 1, 1997 to March 31, 1997
Smith, Arthur L.Athens, GACPAJanuary 1, 1997 to December 31, 1997
DeGroote Sr., Kevin J.Mesa, AZCPAJanuary 1, 1997 to October 31, 1997
Oliveri, RobertBensalem, PACPAJanuary 1, 1997 to December 31, 1997
Davies, Preston S.Deerfield, ILCPAJanuary 15, 1997 to December 14, 1997
Elbert, David L.Franktown, COCPAIndefinite from January 21, 1997
Smith Jr., Phillip M.Long Beach, CAAttorneyFebruary 1, 1997 to March 31, 1997
Pennington, Richard A.Vandergrift, PACPAFebruary 1, 1997 to January 31, 2000
Tameron, Joseph A.Chandler, AZCPAFebruary 1, 1997 to September 30, 1998
Kalb, Mary C.Kearny, NECPAFebruary 1, 1997 to March 31, 1997
Pritchard, John J.San Diego, CAEnrolled AgentFebruary 1, 1997 to March 31, 1997
Garrett, RichardTorrance, GAEnrolled AgentMarch 1, 1997 to May 30, 1997
Englert, Larry R.Eaton, OHCPAApril 1, 1997 to May 30, 1997
12

Numerical Finding List
1
Bulletin 1997–1 through 1997–14
Announcements:
97–1, 1997–2 I.R.B.63
97–2, 1997–2 I.R.B.63
97–3, 1997–2 I.R.B.63
97–4, 1997–3 I.R.B.14
97–5, 1997–3 I.R.B.15
97–6, 1997–4 I.R.B.11
97–7, 1997–4 I.R.B.12
97–8, 1997–4 I.R.B.12
97–9, 1997–5 I.R.B.27
97–10, 1997–10 I.R.B.64
97–11, 1997–6 I.R.B.19
97–12, 1997–7 I.R.B.55
97–13, 1997–8 I.R.B.38
97–14, 1997–8 I.R.B.38
97–15, 1997–9 I.R.B.23
97–16, 1997–9 I.R.B.23
97–17, 1997–9 I.R.B.23
97–18, 1997–10 I.R.B.67
97–19, 1997–10 I.R.B.68
97–20, 1997–11 I.R.B.22
97–21, 1997–11 I.R.B.23
97–22, 1997–12 I.R.B.47
97–23, 1997–11 I.R.B.23
97–24, 1997–11 I.R.B.24
97–25, 1997–12 I.R.B.47
97–26, 1997–12 I.R.B.48
97–27, 1997–13 I.R.B.30
97–28, 1997–14 I.R.B.15
97–29, 1997–14 I.R.B.16
97–30, 1997–14 I.R.B.16
97–31, 1997–14 I.R.B.16
97–32, 1997–14 I.R.B.17
Notices:
97–1, 1997–2 I.R.B.22
97–2, 1997–2 I.R.B.22
97–3, 1997–1 I.R.B.8
97–4, 1997–2 I.R.B.24
97–5, 1997–2 I.R.B.25
97–6, 1997–2 I.R.B.26
97–7, 1997–1 I.R.B.8
97–8, 1997–4 I.R.B.7
97–9, 1997–2 I.R.B.35
97–10, 1997–2 I.R.B.41
97–11, 1997–2 I.R.B.50
97–12, 1997–3 I.R.B.11
97–13, 1997–6 I.R.B.13
97–14, 1997–8 I.R.B.23
97–15, 1997–8 I.R.B.23
97–16, 1997–9 I.R.B.15
97–17, 1997–10 I.R.B.34
97–18, 1997–10 I.R.B.35
97–19, 1997–10 I.R.B.40
97–20, 1997–10 I.R.B.52
97–21, 1997–11 I.R.B.9
97–22, 1997–13 I.R.B.9
97–23, 1997–14 I.R.B.8
Proposed Regulations:
REG–209332–80, 1997–14 I.R.B.9
REG–209040–88, 1997–7 I.R.B.34
REG–209121–89, 1997–11 I.R.B.15
REG–208288–90, 1997–11 I.R.B.14
REG–209494–90, 1997–8 I.R.B.24
Proposed Regulations—Continued
REG–208172–91, 1997–10 I.R.B.59
REG–209672–93, 1997–6 I.R.B.15
REG–209709–94 1997–13 I.R.B.12
REG–209729–94, 1997–11 I.R.B.19
REG–209762–95, 1997–3 I.R.B.12
REG–209817–96, 1997–7 I.R.B.41
REG–209824–96, 1997–11 I.R.B.19
REG–254394–96, 1997–14 I.R.B.14
REG–209828–96, 1997–6 I.R.B.15
REG–209834–96, 1997–4 I.R.B.9
REG–209839–96, 1997–8 I.R.B.26
REG–242996–96, 1997–9 I.R.B.18
REG–246018–96, 1997–8 I.R.B.30
REG–247678–96, 1997–6 I.R.B.17
REG–247862–96, 1997–8 I.R.B.32
REG–248770–96, 1997–8 I.R.B.33
REG–249819–96, 1997–7 I.R.B.50
REG–252231–96, 1997–7 I.R.B.52
REG–252233–96, 1997–9 I.R.B.19
REG–252665–96, 1997–12 I.R.B.46
Revenue Procedures:
97–1, 1997–1 I.R.B.11
97–2, 1997–1 I.R.B.64
97–3, 1997–1 I.R.B.84
97–4, 1997–1 I.R.B.96
97–5, 1997–1 I.R.B.132
97–6, 1997–1 I.R.B.153
97–7, 1997–1 I.R.B.185
97–8, 1997–1 I.R.B.187
97–9, 1997–2 I.R.B.56
97–10, 1997–2 I.R.B.59
97–11, 1997–6 I.R.B.13
97–12, 1997–4 I.R.B.7
97–13, 1997–5 I.R.B.18
97–14, 1997–5 I.R.B.20
97–15, 1997–5 I.R.B.21
97–16, 1997–5 I.R.B.25
97–17, 1997–9 I.R.B.15
97–18, 1997–10 I.R.B.53
97–19, 1997–10 I.R.B.55
97–20, 1997–11 I.R.B.10
97–21, 1997–12 I.R.B.44
97–22, 1997–13 I.R.B.9
Revenue Rulings:
97–1, 1997–2 I.R.B.10
97–2, 1997–2 I.R.B.7
97–3, 1997–2 I.R.B.5
97–4, 1997–3 I.R.B.6
97–5, 1997–4 I.R.B.5
97–6, 1997–4 I.R.B.4
97–7, 1997–5 I.R.B.14
97–8, 1997–7 I.R.B.4
97–9, 1997–9 I.R.B.4
97–10, 1997–10 I.R.B.31
97–11, 1997–10 I.R.B.5
97–12, 1997–11 I.R.B.5
97–14, 1997–11 I.R.B.5
97–15, 1997–12 I.R.B.42
97–16, 1997–13 I.R.B.4
97–17, 1997–14 I.R.B.5
Social Security Domestic Coverage Threshold
1997–9, I.R.B.17
Treasury Decisions:
8688, 1997–3 I.R.B.7
8689, 1997–3 I.R.B.9
8690, 1997–5 I.R.B.5
8691, 1997–5 I.R.B.16
8692, 1997–3 I.R.B.4
Treasury Decisions—Continued
8693, 1997–6 I.R.B.9
8694, 1997–6 I.R.B.11
8695, 1997–4 I.R.B.5
8696, 1997–6 I.R.B.4
8697, 1997–2 I.R.B.11
8698, 1997–7 I.R.B.29
8699, 1997–6 I.R.B.4
8700, 1997–7 I.R.B.5
8701, 1997–7 I.R.B.23
8702, 1997–8 I.R.B.4
8703, 1997–8 I.R.B.18
8704, 1997–8 I.R.B.12
8705, 1997–8 I.R.B.16
8706, 1997–9 I.R.B.11
8707, 1997–7 I.R.B.17
8708, 1997–10 I.R.B.14
8709, 1997–9 I.R.B.5
8710, 1997–13 I.R.B.4
8711, 1997–12 I.R.B.35
8712, 1997–12 I.R.B.4
8713, 1997–14 I.R.B.4
1
A cumulative list of all Revenue Rulings,
Revenue Procedures, Treasury Decisions, etc.,
published in Internal Revenue Bulletins 1996–27
through 1996–53 will be found in Internal
Revenue Bulletin 1997–1, dated January 6, 1997.
13

Finding List of Current Action on
Previously Published Items
1
Bulletin 1997–1 through 1997–14
*Denotes entry since last publication
Revenue Procedures:
66–3
Modified by
97–11, 1997–6 I.R.B.13
87–21
Modified by
97–11, 1997–6 I.R.B.13
92–20
Modified by
97–1, 1997–1 I.R.B.11
92–20
Modified by
97–10, 1997–2 I.R.B.59
92–90
Superseded by
97–1, 1997–1 I.R.B.11
94–52
Revoked by
97–11, 1997–6 I.R.B.13
96–1
Superseded by
97–1, 1997–1 I.R.B.11
96–2
Superseded by
97–2, 1997–1 I.R.B.64
96–3
Superseded by
97–3, 1997–1 I.R.B.84
96–4
Superseded by
97–4, 1997–1 I.R.B.96
96–5
Superseded by
97–5, 1997–1 I.R.B.132
96–6
Superseded by
97–6, 1997–1 I.R.B.153
96–7
Superseded by
97–7, 1997–1 I.R.B.185
96–8
Superseded by
97–8, 1997–1 I.R.B.187
97–2
Amplified by
97–21, 1997–12 I.R.B.44
Revenue Rulings:
70–480
Revoked by
97–6, 1997–4 I.R.B.4
72–527
Obsoleted by
8704, 1997–8 I.R.B.12
Revenue Rulings—Continued
74–59
Revoked by
8708, 1997–10 I.R.B.14
92–19
Supplemented in part by
97–2, 1997–2 I.R.B.7
96–12
Superseded by
97–3, 1997–1 I.R.B.84
96–13
Modified by
97–1, 1997–1 I.R.B.11
96–22
Superseded by
97–3, 1997–1 I.R.B.84
96–34
Superseded by
97–3, 1997–1 I.R.B.84
96–39
Superseded by
97–3, 1997–1 I.R.B.84
96–43
Superseded by
97–3, 1997–1 I.R.B.84
96–56
Superseded by
97–3, 1997–1 I.R.B.84
1
A cumulative finding list for previously published
items mentioned in Internal Revenue Bulletins
1996–27 through 1996–53 will be found in Inter-
nal Revenue Bulletin 1997–1, dated January 6,
1997.
14