us-irs-revenue-rulings-irb-2002-11-pdf•Internal Revenue Bulletin 2002-11 (PDF rendition): IRS Revenue Rulings
Internal Revenue Bulletin 2002-11 (PDF rendition): IRS Revenue Rulings
us-irs-revenue-rulings-irb-2002-11-pdfInternal Revenue Bulletin 2002-11 (PDF rendition): IRS Revenue RulingsGuidance
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.
HIGHLIGHTS OF THIS ISSUE These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations. INCOME TAX Rev. Rul. 2002–12, page 624. Insurance companies; interest rate tables.Prevailing state assumed interest rates are provided for the determination of reserves under section 807 of the Code for contracts issued in 2001 and 2002. Rev. Rul. 92–19 supplemented in part. EXEMPT ORGANIZATIONS Announcement 2002–27, page 629. This announcement requests comments regarding the develop- ment of an electronic filing system for exempt organization returns. Comments are due by April 18, 2002. Announcement 2002–28, page 630. A list is provided of organizations now classified as private foundations. Announcement 2002–29, page 631. Families Charity of Broward, Inc. N/K/A Families Against Drugs and Abuse, Inc., of Ft. Lauderdale, FL, no longer qualifies as an organization to which contributions are deductible under sec- tion 170 of the Code. ADMINISTRATIVE Announcement 2002–26, page 629. This announcement updates information concerning question- able Forms W-4 currently published in Rev. Proc. 2001–16 (2001–4 I.R.B. 376). This information is general in nature and does not affect the current filing instructions for questionable Forms W-4. Announcement 2002–30, page 632. This document contains corrections to the language referring taxpayers to the IRS Internet site for several proposed regula- tions and an advance notice of proposed regulations (Ann. 2002–9, 2002–7 I.R.B. 536). Finding Lists begin on page ii. Bulletin No. 2002–11 March 18, 2002 The IRS Mission Provide America’s taxpayers top quality service by helping them understand and meet their tax responsibilities and by applying the tax law with integrity and fairness to all. Introduction The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conven- tions, legislation, court decisions, and other items of general interest. It is published weekly and may be obtained from the Superintendent of Documents on a subscription basis. Bulletin contents are consolidated semiannually into Cumulative Bulle- tins, which are sold on a single-copy basis. It is the policy of the Service to publish in the Bulletin all sub- stantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bul- letin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of inter- nal 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 rev- enue ruling. In those based on positions taken in rulings to tax- payers 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.—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 Other Related Items, and Subpart B, Legisla- tion 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 part includes notices of proposed rulemakings, disbar- ment and suspension lists, and announcements. The first Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the first Bulletin of the succeeding semiannual 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, DC 20402. March 18, 20022002–11 I.R.B. Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 Section 807.—Rules for Certain Reserves Insurance companies; interest rate tables. Prevailing state assumed interest rates are provided for the determination of reserves under section 807 of the Code for contracts issued in 2001 and 2002. Rev. Rul. 92–19 supplemented in part. Rev. Rul. 2002–12 For purposes of § 807(d)(4) of the Internal Revenue Code, for taxable years beginning after December 31, 2000, this ruling supplements the schedules of pre- vailing state assumed interest rates set forth in Rev. Rul. 92–19 (1992–1 C.B. 227). This information is to be used by insurance companies in computing their reserves for (1) life insurance and supple- mentary total and permanent disability benefits, (2) individual annuities and pure endowments, and (3) group annuities and pure endowments. As § 807(d)(2)(B) requires that the interest rate used to com- pute these reserves be the greater of (1) the applicable federal interest rate, or (2) the prevailing state assumed interest rate, the table of applicable federal interest rates in Rev. Rul. 92–19 is also supple- mented. Following are supplements to sched- ules A, B, C, and D to Part III of Rev. Rul. 92–19, providing prevailing state assumed interest rates for insurance prod- ucts with different features issued in 2001 and 2002, and a supplement to the table in Part IV of Rev. Rul. 92–19, providing the applicable federal interest rate under § 807(d) for 2000 and 2001. This ruling does not supplement Parts I and II of Rev. Rul. 92–19. This is the tenth supplement to the interest rates provided in Rev. Rul. 92–19. Earlier supplements were pub- lished in Rev. Rul. 93–58 (1993–2 C.B. 241) (interest rates for insurance products issued in 1992 and 1993); Rev. Rul. 94–11 (1994–1 C.B. 196) (1993 and 1994); Rev. Rul. 95–4 (1995–1 C.B. 141) (1994 and 1995); Rev. Rul. 96–2 (1996–1 C.B. 141) (1995 and 1996); Rev. Rul. 97–2 (1997–1 C.B. 134) (1996 and 1997); Rev. Rul. 98–2 (1998–1 C.B. 259) (1997 and 1998); Rev. Rul. 99–10 (1999–1 C.B. 671) (1998 and 1999); Rev. Rul. 2000–17 (2000–1 C.B. 842) (1999 and 2000); and Rev. Rul. 2001–11 (2001–10 I.R.B. 780). Part III. Prevailing State Assumed Interest Rates — Products Issued in Years After 1982.* Schedule A STATUTORY VALUATION INTEREST RATES BASED ON THE 1980 AMENDMENTS TO THE NAIC STANDARD VALUATION LAW A. Life insurance valuation: Guarantee Duration (years) Calendar Year of Issue 2002 10 or fewer5.00** More than 10 but not more than 20 4.75** More than 204.50** Source: Rates calculated from the monthly averages, ending June 30, 2001, of Moody’s Corporate Bond Yield Average — Monthly Average Corporates. ** As the applicable federal interest rate for 2002 of 5.71 percent exceeds this prevailing state assumed interest rate, the interest rate to be used for this product under § 807 is 5.71 percent. * The terms used in the schedules in this ruling and in Part III of Rev. Rul. 92–19 are those used in the Standard Valuation Law; the terms are defined in Rev. Rul. 92–19. 2002–11 I.R.B.624March 18, 2002 Part III, Schedule B STATUTORY VALUATION INTEREST RATES BASED ON THE 1980 AMENDMENTS TO THE NAIC STANDARD VALUATION LAW B. Single premium immediate annuities and annuity benefits involving life contingencies arising from other annuities with cash settlement options and from guaranteed interest contracts with cash settlement options: Calendar Year of Issue Valuation Interest Rate 20016.75* Source: Rates calculated from the monthly averages, ending June 30, 2001, of Moody’s Corporate Bond Yield Average—Monthly Average Corporates. The terms used in this schedule are those used in the Standard Valuation Law as defined in Rev. Rul. 92–19. *As this prevailing state assumed interest exceeds the applicable federal interest rate for 2001 of 6.00 percent, the valuation inter- est rate of 6.75 percent is to be used for this product under§807. March 18, 20026252002–11 I.R.B. Part III, Schedule C19—2001 STATUTORY VALUATION INTEREST RATES BASED ON NAIC STANDARD VALUATION LAW FOR2001CALENDAR YEAR BUSINESS GOVERNED BY THE 1980 AMENDMENTS C. Valuation interest rates for other annuities and guaranteed interest contracts that are valued on an issue year basis: Cash Settlement Options? Future Interest Guarantee? Guarantee Duration (years) Valuation Interest Rate For Plan Type AB C YesYes5 or fewer6.755.75*5.25* More than 5, but not more than 10 6.505.75*5.25* More than 10, but not more than 20 6.005.25*5.00* More than 205.00*4.50*4.50* YesNo5 or fewer7.006.005.50* More than 5, but not more than 10 6.756.005.50* More than 10, but not more than 20 6.255.50*5.25* More than 205.25*4.75*4.75* NoYes or No5 or fewer6.75 More than 5, but not more than 10 6.50NOT APPLICABLE More than 10, but not more than 20 6.00 More than 205.00* Source: Rates calculated from the monthly averages, ending June 30, 2001, of Moody’s Corporate Bond Yield Average—Monthly Average Corporates. *As the applicable federal interest rate for 2001 of 6.00 percent exceeds this prevailing state assumed interest rate, the interest rate to be used for this product under§807 is 6.00 percent. 2002–11 I.R.B.626March 18, 2002 Part III, Schedule D19—2001 STATUTORY VALUATION INTEREST RATES BASED ON NAIC STANDARD VALUATION LAW FOR2001CALENDAR YEAR BUSINESS GOVERNED BY THE 1980 AMENDMENTS D. Valuation interest rates for other annuities and guaranteed interest contracts that are contracts with cash settlement options and that are valued on a change in fund basis: Cash Settlement Options? Future Interest Guarantee? Guarantee Duration (years) Valuation Interest Rate For Plan Type AB C YesYes5 or fewer7.507.005.50* More than 5, but not more than 10 7.257.005.50* More than 10, but not more than 20 6.756.505.25* More than 205.75*5.75*5.00* YesNo5 or fewer7.757.255.75* More than 5, but not more than 10 7.507.255.75* More than 10, but not more than 20 7.006.755.50* More than 206.006.005.00* Source: Rates calculated from the monthly averages, ending June 30, 2001, of Moody’s Corporate Bond Yield Average—Monthly Average Corporates. *As the applicable federal interest rate for 2001 of 6.00 percent is equal to or exceeds this prevailing state assumed interest rate, the interest rate to be used for this product under§807 is 6.00 percent. Part IV. Applicable Federal Interest Rates. TABLE OF APPLICABLE FEDERAL INTEREST RATES FOR PURPOSES OF§807 Year Interest Rate 20016.00 20025.71 Sources: Rev. Rul. 2000–54 (2000–2 C.B. 566) for the 2001 rate and Rev. Rul. 2001–58 (2001–50 I.R.B. 570) for the 2002 rate. March 18, 20026272002–11 I.R.B. EFFECT ON OTHER REVENUE RULINGS Rev. Rul. 92–19 is supplemented by the addition to Part III of that ruling of prevailing state assumed interest rates under§807 for certain insurance prod ucts issued in 2001 and 2002 and is fur- ther supplemented by an addition to the table in Part IV of Rev. Rul. 92–19 listing applicable federal interest rates. Parts I and II of Rev. Rul. 92–19 are not affected by this ruling. DRAFTING INFORMATION The principal author of this revenue ruling is Ann H. Logan of the Office of Associate Chief Counsel (Financial Insti- tutions and Products). For further infor- mation regarding this revenue ruling, con- tact her at (202) 622–3970 (not a toll-free call). 2002–11 I.R.B.628March 18, 2002 Part IV. Items of General Interest Change to Publication 1245, Specifications for Filing Form W-4, Employee’s Withholding Allowance Certificate, Magnetically or Electronically Announcement 2002–26 This announcement provides updated in- formation to the Publication 1245,Speci- fications for Filing Form W-4, Employ- ee’s Withholding Allowance Certificate, Magnetically or Electronically. This information is general in nature. There are no legislative or format changes. Information provided in Rev. Proc. 2001–16 (2001–4 I.R.B. 376) (dated January 22, 2001) is still valid with the exception of the following items: 1. Information Reporting Program Call Site was reorganized and is now the Customer Service Site. The Customer Service Site continues to provide the same level of service but with the following enhance- ments. •A toll-free number,866-455- 7438, is now available. •An email service,mccirp@irs. gov, provides written responses to questions received via email. 2. Beginning in Tax Year 2003 for cal- endar year 2004, the Martinsburg Computing Center (MCC) will no longer accept 8mm, 4mm, and Quarter Inch Cartridges (QIC) for the filing of Questionable Forms W-4. Publication 1245 is only available in the Internal Revenue Bulletin listed above through the IRS Websitewww.irs.gov. The Publication 3609,Filing Information Returns Electronically, revised 1–2002, provides updated information on elec- tronic filing. If you have any questions concerning this information or other information return issues, please call the Customer Service Site toll-free at 866–455–7438. Request for Comments Regarding Electronic Filing of Exempt Organization Returns Announcement 2002–27 The Internal Revenue Service (IRS) is developing an electronic filing system for tax-exempt organizations’returns. To ensure that this process considers the needs of all who have an interest in the information returns filed by tax-exempt organizations, we are seeking comments from exempt organizations, state regula- tors, research and oversight organizations, practitioners, software vendors, and oth- ers. BACKGROUND The Internal Revenue Service Restruc- turing and Reform Act of 1998 requires the IRS to receive 80 percent of all returns electronically by 2007. Available information suggests that the ability to file exempt organization returns electroni- cally would reduce the filing burden of organizations, as well as provide easier and quicker access to information for users of return data. Studies show that 80 percent of Forms 990 and 990–EZ filed are prepared using software. The IRS transcribes (manually inputs) a large amount of return data which is used by IRS and others. The returns filed by exempt organiza- tions are unique in several respects. They are filed by diverse organizations ranging from volunteer membership organizations to complex hospital systems. In addition, they are primarily information returns rather than tax returns. As such, they typi- cally include a significant amount of nar- rative text in addition to financial data. Another unique aspect is that most exempt organization information returns are subject to public disclosure. Finally, the returns assist with federal tax admin- istration, state regulation, and public oversight of exempt organizations. REQUEST FOR PUBLIC COMMENT The success of an electronic filing sys- tem for tax-exempt organizations will depend on the extent to which exempt organizations can use it to fulfill reporting requirements and the extent to which various stakeholders can use it to satisfy their information needs. Accordingly, the IRS requests comments from exempt organizations and all interested stakehold- ers on factors to be considered in devel- oping an electronic filing system, includ- ing the following: 1. Which Form 990 series returns should be introduced first, and why; 2. What factors or concerns would encourage exempt organizations to file electronically; 3. What factors or concerns would dis- courage exempt organizations from filing electronically; 4. What could be done to address con- cerns that would discourage exempt orga- nizations from filing electronically; 5. How will your experience with any other IRS e-file program (for example, Form 941, Form 1040, or Forms 8871 and 8872) affect your decision to file your exempt organization returns elec- tronically; 6. Should the system be designed so orga- nizations can use it to satisfy multiple fil- ing or reporting requirements (for example, state reporting requirements or grant reports); 7. What specific changes to the current Form 990 series of returns would facili- tate electronic filing of these forms. Exempt organizations and individuals authorized to submit comments on behalf of a specific organization are encouraged to include the following information to help insure that the needs of various types of exempt organizations are met: 1. Organization’s gross receipts and net assets; 2. Who (attorney, accountant, employee, volunteer) prepares the organization’s returns; 3. Form filed (990, 990–EZ, 990–PF, etc.) March 18, 20026292002–11 I.R.B. 4. How the returns are prepared (tax return software, forms software, spread- sheets, etc.). Practitioners are encouraged to pro- vide the following information: 1. Size of their organization (for example, sole practitioner, large accounting firm, large law firm); 2. Reports prepared (for example, 990, charitable solicitation, grant); 3. Volume of reports prepared on an annual basis. All other interested parties are encour- aged to provide a statement explaining their interest in an electronic filing system for exempt organization returns and any other information that will be useful in the development of such a system. Public comments should be submitted in writing on or before April 18, 2002. Comments should be sent to the follow- ing address: Internal Revenue Service 1111Constitution Avenue, NW Washington, DC 20224 Attn: Theresa Pattara T:EO Comments may also be sent via elec- tronic mail totege-eo-efile@irs.gov DRAFTING INFORMATION The principal author of this announce- ment is Theresa Pattara of Exempt Orga- nizations. For further information regard- ing this announcement, contact Theresa Pattara at (202) 283–8946 or Cheryl Cha- sin at (202) 283–8932 (not toll-free calls). Foundations Status of Certain Organizations Announcement 2002–28 The following organizations have failed to establish or have been unable to maintain their status as public charities or as operating foundations. Accordingly, grantors and contributors may not, after this date, rely on previous rulings or des- ignations in the Cumulative List of Orga- nizations (Publication 78), or on the pre- sumption arising from the filing of notices under section 508(b) of the Code. This listing 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 pri- vate foundations described in section 509(a) of the Code) are now classified as private foundations: 66th Avenue Apartments, Inc., Long Beach, CA Advancement Plus, Inc., Cambridge, MA Aid for Asian Women, Van Nuys, CA Ambassador of Peace, Los Angeles, CA American Job Self Help, Inc., Gardina, CA Anahola Homesteaders Council, Anahola, HI Armenian Chamber Music Association, Van Nuys, CA Arts in Performance, Honolulu, HI Baseball Alliance of Hawaii, Inc., Honolulu, HI BBSLE,Inc., Orange, CA Bell Social Service Enterprise, Pomona, CA Better Living Centers, Tarzana, CA B H T, Inc., Chicago, IL Buxmont Christian Educational Institute, Inc., Telford, PA Campus Concerts, Torrance, CA Center for Authentic Church Growth, Duarte, CA Center for Minority Professional Development, Inc., New York, NY Center for Self-Sufficiency, Inc., Silver Spring, MD Cert Advisory Committee, Sherman Oaks, CA Church Helping Urban Restoration of Community & Home, Inc., Detroit, MI Clinton Township - Yasu City Cultural Exchange Board, Inc., Clinton Township, MI Community Action Substance Abuse of West Sacramento, Inc., Sacramento, CA Community Housing for Exceptional People, Inc., Los Angeles, CA Community Information and Resource Center, Inglewood, CA Counseling Response to End Abuse, Van Nuys, CA Docs Educational Learning Center, Inc., Riverdale, GA Downtown Gay & Lesbian Alliance, Los Angeles, CA East Hawaii Blues Association, Kurtistown, HI Ekolu Mea Nui, Pualani, HI Eureka Business Center, Inc., Clayton, LA Filipino-American Professional Care Services, Inc., Los Angeles, CA Focus on AIDS, Los Angeles, CA Food for Body & Soul, Glendale, CA Foundation for Youth Enhancement, El Cajon, CA Friends of the Greek Theatre, Van Nuys, CA Gah Productions, Inc., Blytheville, AR Global Korean Network of Los Angeles, Inc., Beverly Hills, CA Gospel Mission International, Cerritos, CA Grace House Association, Honolulu, HI Grace Shelter of the Antelope Valley, Inc., E. Palmdale, CA Greater Expectations in Transition, Anchorage, AK Hale Mahaolu Eono, Inc., Kahului, HI Hawaii Athlete Development Fund, Inc., Honolulu, HI Hawaii Festival of Wheel, Honolulu, HI Health Care & Policy Institute, Boston, MA Heritage Resources II, Inc., Mercer, PA Higgs Institute, Houston, TX High Desert Youth Football, Lancaster, CA Hispanic Latino Heritage Month, Los Angeles, CA Homeward Bound for Homeless Families, Inc., Los Angeles, CA Hoxworth Ministries, Inc., Mexia, TX ICI of Oregon Foundation, Dallas, OR Institute for the Diffusion of Sufi Ideas, Inc., Los Angeles, CA International School of Beijing Foundation, Princeton, NJ Irano-American Friends Society, Los Angeles, CA Job Brigade, Las Vegas, NV Ka’Ohana O Kahikinui, Inc., Haiku, HI Kau Baseball Booster Club, Pahala, HI Kids Voting MIB, Inc., Mountain Iron, MN Kidz Zone Children Center, California City, CA Leeward Oahu Bobby Sox Softball League, Waipahu, HI 2002–11 I.R.B.630March 18, 2002 Lend-A-Hand Foundation, Los Angeles, CA Liberation Videos, Inc., Brooklyn, NY Lightning Strike-Electric Shock Survivors International, Inc., St. Petersburg, FL Los Angeles Chapter of the National Society for Performance & Instruct, Pasadena, CA Louis B. Johnson, Incorporated, Marina Del Rey, CA Lurling Gardens Tenant Association, Canoga Park, CA Majestic Harmony, Inc., Bronx, NY Malibu Aquatics Club, Malibu, CA Marge Leone Ministries, Glendale, CA Marine Life Institute for Research and Studies, Kailua, HI May-West Roxbury Residences, Inc., Norwood, MA Mile High Childrens Center, Inc., Aurora, CO Nasung Kyomin College, Los Angeles, CA National Conference of Korean- American Leaders, Honolulu, HI National Foundation on Gerontology for Teaching, Research and Special Studies, San Antonio, TX National Traditionalist Foundation, Inc., New York, NY New Direction Youth Services, Inc., Los Angeles, CA Next Generation Productions, Winnetka, CA Noir Educational Foundation, Inc., Los Angeles, CA Nomads 1800 a Not-For-Profit Arts Center, Marina Del Rey, CA Northern Heights Tenants Organization, Glasgow, MT Oxford-Sumner County Historical Museum, Inc., Oxford, KS P. A. C. E. S. - Performing Arts and Cultural Exchange Studios, Kealakekua, HI Pathways of Higher Learning, Inc., Los Angeles, CA PEP Educational Support, Inc., Indianapolis, IN Pitcairn High School Alumni-R.J. Conrad Scholarship Fund, Inc., Oakmont, PA Portland Computer Training Institute, Beaverton, OR Potawatomi Creative Playground Project, Inc., South Bend, IN Prescription for Healing Medical Practice, Inc., Long Beach, CA Prince Albert Foundation, Princeville, HI Project Earth, Inc., Eugene, OR P. U. L. S. E., Jackson, MI Reflections of Real Life, Inc., San Diego, CA Revive Ministries, Arcadia, CA Rogelio Flores Foundation, Los Angeles, CA Rose Petroff Foundation, Fair Oaks Ranch, TX Rotary Club of Hanalei Bay Foundation, Hanalei, HI Saint Jude Project Loaves and Fishes, Taluca Lake, CA Samaritan Way International, Inc., Dallas, TX San Francisco Community AHEC, San Francisco, CA Save our Earth, Inc., Eugene, OR SCSELA Housing & Enterpreneur Development, Inc., Dana Point, CA Second Generation of Los Angeles, Los Angeles, CA Seek Ye First Ministry, West Lebanon, NH Society for the Preservation of Homeopathic, Los Angeles, CA Street Smart System of Selfdefense, Inc., Pukalani, HI Students Interactive Fellowship Union, Incorporated, Long Beach, CA Tanner House a Public Benefit Corporation, Lancaster, CA Terralumina, Inc., Wilmington, DE Terrell Brandon Foundation, Inc., Portland, OR Texas Capital Litigation Assistance Project, Inc., Austin, TX Theater for Youth Midwest, Inc., Michigan City, IN Thomas Group Home, Long Beach, CA Tigara Educational Foundation, Inc., Point Hope, AK Tommys House Venice, Santa Monica, CA Trivalley Indian Medical Association, Inc., Glendale, CA Unutoa Home Care Providers, Los Angeles, CA UWICR, Encino, CA Venice Oakwood Crises Center, Venice, CA Victory Community Outreach Project, Inc., Los Angeles, CA Victory for Children Foundation, Inc., Portland, OR Village Community, Inc., Chattanooga, TN West Valley Community Development Corporation, Canoga Park, CA Western Educational Alliance Corp., Fresno, CA Writers Lab, Los Angeles, CA Yesterdays Artifacts, Inc., Tallahassee, FL Yorkshire Non-Profit Housing Corporation, Los Angeles, CA Youth Educational Support Services, Inc., Van Nuys, CA If an organization listed above submits information that warrants the renewal of its classification as a public charity or as a private operating foundation, the Inter- nal Revenue Service will issue a ruling or determination letter with the revised clas- sification as to foundation status. Grant- ors and contributors may thereafter rely upon such ruling or determination letter as provided in section 1.509(a)–7ofthe Income Tax Regulations. It is not the practice of the Service to announce such revised classification of foundation status in the Internal Revenue Bulletin. Deletions From Cumulative List of Organizations Contributions to Which are Deductible Under Section 170 of the Code Announcement 2002–29 The name of an organization that no longer qualifies as an organization described in section 170(c)(2) of the Internal Revenue Code of 1986 is listed below. Generally, the Service will not disal- low deductions for contributions made to a listed organization on or before the date of announcement in the Internal Revenue Bulletin that an organization no longer qualifies. However, the Service is not pre- cluded from disallowing a deduction for any contributions made after an organiza- tion ceases to qualify under section 170(c)(2) if the organization has not timely filed a suit for declaratory judg- ment under section 7428 and if the con- tributor (1) had knowledge of the revoca- tion of the ruling or determination letter, (2) was aware that such revocation was March 18, 20026312002–11 I.R.B. imminent, or (3) was in part responsible for or was aware of the activities or omis- sions of the organization that brought about this revocation. If on the other hand a suit for declara- tory judgment has been timely filed, con- tributions from individuals and organiza- tions described in section 170(c)(2) that are otherwise allowable will continue to be deductible. Protection under section 7428(c) would begin on March 18, 2002, and would end on the date the court first determines that the organization is not described in section 170(c)(2) as more particularly set forth in section 7428 (c)(1). For individual contributors, the maximum deduction protected is $1,000, with a husband and wife treated as one contributor. This benefit is not extended to any individual, in whole or in part, for the acts or omissions of the organization that were the basis for revocation. Families Charity of Broward, Inc. N/K/A Families Against Drugs and Abuse, Inc. Ft. Lauderdale, FL Miscellaneous Federal Tax Matters; Correction Announcement 2002–30 AGENCY:Internal Revenue Service (IRS), Treasury. ACTION:Correction to notices of pro- posed rulemaking. SUMMARY:This document corrects the language referring taxpayers to the IRS Internet site for several notices of pro- posed rulemaking published in the Bulle- tin. The proposed regulations that need correction are identified in the table set out in this correction notice. (REG– 107100–00, 2002–7 I.R.B. 529), (REG– 112991–01, 2002–4 I.R.B. 40), (REG– 115054–01, 2002–7 I.R.B. 530), (REG– 119436–01, 2002–3 I.R.B. 376), (REG– 120135–01, 2002–8 I.R.B. 552), (REG– 125450–01, 2002–5 I.R.B. 457), (REG– 125626–01, 2002–9 I.R.B. 604), (REG– 126485–01, 2001–49 I.R.B. 555), (REG– 137519–01, 2001–49 I.R.B. 559), (REGs–142299–01 and 209135–88, 2002–4 I.R.B. 418), (REG–142686–01, 2001–49 I.R.B. 561), (REG–159079–01, 2002–6 I.R.B. 493), and an advance notice of proposed rulemaking (REG– 125638–01) published as Announcement 2002–9 (2002–7 I.R.B. 536). FORFURTHERINFORMATION CONTACT:Donna Poindexter, Associ- ate Chief Counsel (Income Tax and Accounting), (202) 622–7180 (not a toll- free number). SUPPLEMENTARY INFORMATION: Background On various dates from November 2001 through February 2002, several notices of proposed rulemaking were published in the Bulletin that contained inaccurate lan- guage referring taxpayers to the IRS Home Page and the IRS Internet site address. This document corrects this lan- guage. Need for Correction For the documents listed in the table, the inaccurate language and IRS Internet site address published in the notices of proposed rulemaking is misleading and in need of correction. Correction of Publications Accordingly, for each entry listed in the table, remove the language from the “ADDRESSES:”caption in the preamble as set out in the“REMOVE”column and add the language in the“ADD”column in its place. PROJECT NUMBER SUBJECTDATE PUBLISHED CITATIONREMOVEADD REG–107100–00Disallowance of Deductions and Credits for Failure to File Timely Return 01–29–0267 FR 4217Alternatively, taxpayers 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 athttp:// www.irs.ustreas.gov/ tax_regs/regslist.html. Alternatively, taxpayers may submit electronic comments directly to the IRS Internet site at www.irs.gov/regs. 2002–11 I.R.B.632March 18, 2002 PROJECT NUMBER SUBJECTDATE PUBLISHED CITATIONREMOVEADD REG–125638–01Guidance Regarding Deduction and Capitalization of Expenditures 01–24–0267 FR 3461Alternatively, taxpayers may send submissions electronically via the Internet by selecting the “Tax Regs”option on the IRS Home Page, or directly to the IRS Internet site athttp:// www.irs.ustreas.gov/ tax_regs/regslist.html. Alternatively, taxpayers may submit electronic comments directly to the IRS Internet site at www.irs.gov/regs. REG–115054–01Treatment of Community Income for Certain Individuals Not Filing Joint Returns 01–22–0267 FR 2841Alternatively, taxpayers 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 athttp:// www.irs.ustreas.gov/ tax_regs/regslist.html. Alternatively, taxpayers may submit electronic comments directly to the IRS Internet site at www.irs.gov/regs. REG–159079–01Taxpayer Identification Number Rule Where Taxpayer Claims Treaty Rate and is Entitled to an Immediate Payment 01–17–0267 FR 2387Alternatively, taxpayers may submit comments electronically via the Internet by selecting the “Tax Regs”option of the IRS Home Page or by submitting comments directly to the IRS internet site athttp://irs.gov/ tax_regs/reglist.html. Alternatively, taxpayers may submit electronic comments directly to the IRS Internet site at www.irs.gov/regs. REG–125450–01Liability for Insurance Premium Excise Tax 01–07–0267 FR 707Alternatively, taxpayers 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 athttp://www.irs.gov/ tax_regs/regslist.html. Alternatively, taxpayers may submit electronic comments directly to the IRS Internet site at www.irs.gov/regs. March 18, 20026332002–11 I.R.B. PROJECT NUMBER SUBJECTDATE PUBLISHED CITATIONREMOVEADD REG–142299–01 REG–209135–88 Certain Transfers of Property to Regulated Investment Companies and Real Estate Investment Trusts 01–02–0267 FR 48Submissions may be hand delivered Monday through Friday between the hours of 8 a.m. and 5 p.m. to CC:ITA:RU [REG– 142299–01], Courier’s Desk, Internal Revenue Service,1111Constitution Avenue NW, Washington, DC or sent to the IRS Internet site at:http:// www.irs.gov/taxregs/ reglist.html. Submissions may be hand delivered Monday through Friday between the hours of 8 a.m and 5 p.m. to CC:ITA:RU [REG– 142299–01], Courier’s Desk, Internal Revenue Service,1111Constitution Avenue NW, Washington, DC. Alternatively, taxpayers may submit electronic comments directly to the IRS Internet site atwww.irs.gov/regs. REG–112991–01Credit for Increasing Research Activities 12–26–0166 FR 66362 Alternatively, taxpayers may submit comments electronically via the Internet by selecting the “Tax Regs”option of the IRS Home Page, or by submitting comments directly to the IRS Internet site athttp://www.irs.gov/ tax_regs/reglist.html. Alternatively, taxpayers may submit electronic comments directly to the IRS Internet site at www.irs.gov/regs. REG–119436–01New Markets Tax Credit 12–26–0166 FR 66376 Alternatively, taxpayers may send submissions electronically via the Internet by selecting the “Tax Regs”option on the IRS Internet site athttp:// www.irs.ustreas.gov/ tax_regs/regslist.html. Alternatively, taxpayers may submit electronic comments directly to the IRS Internet site at www.irs.gov/regs. REG–126485–01Statutory Mergers and Consolidations 11–15–0166 FR 57400 Alternatively, taxpayers may submit comments electronically via the Internet by selecting the Tax Reg option on the IRS Home Page, or by submitting comments directly to the IRS Internet site athttp://www.irs.gov/ tax_regs.reglist.html. Alternatively, taxpayers may submit electronic comments directly to the IRS Internet site at www.irs.gov/regs. 2002–11 I.R.B.634March 18, 2002 PROJECT NUMBER SUBJECTDATE PUBLISHED CITATIONREMOVEADD REG–137519–01Consolidated Returns; Applicability of Other Provisions of Law; Non- Applicability of Section 357(c) 11–14–0166 FR 57021 Alternatively, taxpayers 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 athttp://www.irs.gov/ tax_regs/reglist.html. Alternatively, taxpayers may submit electronic comments directly to the IRS Internet site at www.irs.gov/regs. REG–142686–01Application of the Federal Insurance Contributions Act, Federal Unemployment Tax Act, and Collection of Income Tax at Source to Statutory Stock Options 01–28–0267 FR 3846Alternatively, taxpayers 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 athttp://www.irs.gov/ tax_regs/reglist.html. Alternatively, taxpayers may submit electronic comments directly to the IRS Internet site at www.irs.gov/regs. REG–125626–01Unit Livestock Price Method 02–04–0267 FR 5074Alternatively, taxpayers 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 athttp:// www.irs.ustreas.gov/ tax_regs/regslist.html. Alternatively, taxpayers may submit electronic comments directly to the IRS Internet site at www.irs.gov/regs. REG–120135–01Definition of Agent for Certain Purposes 02–01–0267 FR 4938Alternatively, taxpayers 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 athttp:// www.irs.ustreas.gov/ tax_regs/regslist.html. Alternatively, taxpayers may submit electronic comments directly to the IRS Internet site at www.irs.gov/regs. Cynthia Grigsby, Chief, Regulations Unit, Associate Chief Counsel (Income Tax and Accounting). (Filed by the Office of the Federal Register on Feb- ruary 22, 2002, 2:59 p.m., and published in the issue of the Federal Register for February 27, 2002, 67 F.R. 8912) March 18, 20026352002–11 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 effect: Amplifieddescribes a situation where no change is being made in a prior pub- lished position, but the prior position is being extended to apply to a variation of the fact situation set forth therein. Thus, if an earlier ruling held that a principle applied to A, and the new ruling holds that the same principle also applies to B, the earlier ruling is amplified. (Compare withmodified, below). Clarifiedis used in those instances where the language in a prior ruling is being made clear because the language has caused, or may cause, some confu- sion. It is not used where a position in a prior ruling is being changed. Distinguisheddescribes a situation where a ruling mentions a previously published ruling and points out an essen- tial difference between them. 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 pub- lished position. (Compare withamplified andclarified, 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 rulings that are obsoleted because of changes in law or regulations. A ruling may also be obsoleted because the sub- stance has been included in regulations subsequently adopted. Revokeddescribes situations where the position in the previously published rul- ing is not correct and the correct position is being stated in the new ruling. Supersededdescribes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings). Thus, the term is used to republish under the 1986 Code and regulations the same position published under the 1939 Code and regulations. The term is also used when it is desired to republish in a single ruling a series of situations, names, etc., that were previously published over a period of time in separate rulings. If the new ruling does more than restate the substance of a prior ruling, a combination of terms is used. For example,modified andsupersededdescribes a situation where the substance of a previously pub- lished ruling is being changed in part and is continued without change in part and it is desired to restate the valid portion of the previously published ruling in a new ruling that is self contained. In this case, the previously published ruling is first modified and then, as modified, is super- seded. 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 ruling has been supplemented several times, a new ruling may be published that includes the list in the original ruling and the additions, and supersedes all prior rul- ings 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 following abbreviations in current use and formerly used will appear in material published in the Bulletin. A—Individual. Acq.—Acquiescence. B—Individual. BE—Beneficiary. BK—Bank. B.T.A.—Board of Tax Appeals. C—Individual. C.B.—Cumulative Bulletin. CFR—Code of Federal Regulations. CI—City. COOP—Cooperative. Ct.D.—Court Decision. CY—County. D—Decedent. DC—Dummy Corporation. DE—Donee. Del. Order—Delegation Order. DISC—Domestic International Sales Corporation. DR—Donor. E—Estate. EE—Employee. E.O.—Executive Order. ER—Employer. ERISA—Employee Retirement Income Security Act. EX—Executor. F—Fiduciary. FC—Foreign Country. FICA—Federal Insurance Contributions Act. FISC—Foreign International Sales Company. FPH—Foreign Personal Holding Company. F.R.—Federal Register. FUTA—Federal Unemployment Tax Act. FX—Foreign Corporation. G.C.M.—Chief Counsel’s Memorandum. GE—Grantee. GP—General Partner. GR—Grantor. IC—Insurance Company. I.R.B.—Intemal Revenue Bulletin. LE—Lessee. LP—Limited Partner. LR—Lessor. M—Minor. Nonacq.—Nonacquiescence. O—Organization. P—Parent Corporation. PHC—Personal Holding Company. PO—Possession of the U.S. PR—Partner. PRS—Partnership. PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Real Estate Investment Trust. Rev. Proc—Revenue Procedure. Rev. Rul.—Revenue Ruling. S—Subsidiary. S.P.R.—Statements of Procedural Rules. Stat.—Statutes at Large. T—Target Corporation. T.C.—Tax Court. T.D.—Treasury Decision. TFE—Transferee. TFR—Transferor. T.I.R.—Technical Information Release. TP—Taxpayer. TR—Trust. TT—Trustee. U.S.C.—United States Code. X—Corporation. Y—Corporation. Z—Corporation. 2002–11 I.R.B.iMarch 18, 2002 Numerical Finding List 1 Bulletins 2002–1 through 2002–10 Announcements: 2002–1, 2002–2 I.R.B.304 2002–2, 2002–2 I.R.B.304 2002–3, 2002–2 I.R.B.305 2002–4, 2002–2 I.R.B.306 2002–5, 2002–4 I.R.B.420 2002–6, 2002–5 I.R.B.458 2002–7, 2002–5 I.R.B.459 2002–8, 2002–6 I.R.B.494 2002–9, 2002–7 I.R.B.536 2002–10, 2002–7 I.R.B.539 2002–11, 2002–6 I.R.B.494 2002–12, 2002–8 I.R.B.553 2002–13, 2002–7 I.R.B.540 2002–14, 2002–7 I.R.B.540 2002–15, 2002–7 I.R.B.540 2002–16, 2002–7 I.R.B.541 2002–17, 2002–8 I.R.B.561 2002–18, 2002–10 I.R.B.621 2002–19, 2002–8 I.R.B.561 2002–20, 2002–8 I.R.B.561 2002–21, 2002–8 I.R.B.562 2002–22, 2002–8 I.R.B.562 2002–23, 2002–8 I.R.B.563 2002–24, 2002–9 I.R.B.606 2002–25, 2002–10 I.R.B.621 Notices: 2002–1, 2002–2 I.R.B.283 2002–2, 2002–2 I.R.B.285 2002–3, 2002–2 I.R.B.289 2002–4, 2002–2 I.R.B.298 2002–5, 2002–3 I.R.B.320 2002–6, 2002–3 I.R.B.326 2002–7, 2002–6 I.R.B.489 2002–8, 2002–4 I.R.B.398 2002–9, 2002–5 I.R.B.450 2002–10, 2002–6 I.R.B.490 2002–11, 2002–7 I.R.B.526 2002–12, 2002–7 I.R.B.526 2002–13, 2002–8 I.R.B.547 2002–14, 2002–8 I.R.B.548 2002–15, 2002–8 I.R.B.548 2002–16, 2002–9 I.R.B.567 2002–17, 2002–9 I.R.B.567 2002–19, 2002–10 I.R.B.619 Proposed Regulations: REG–209135–88, 2002–4 I.R.B.418 REG–209114–90, 2002–9 I.R.B.576 REG–107100–00, 2002–7 I.R.B.529 REG–105344–01, 2002–2 I.R.B.302 REG–112991–01, 2002–4 I.R.B.404 REG–115054–01, 2002–7 I.R.B.530 REG–119436–01, 2002–3 I.R.B.376 REG–120135–01, 2002–8 I.R.B.552 Proposed Regulations:—Continued REG–125450–01, 2002–5 I.R.B.457 REG–125626–01, 2002–9 I.R.B.604 REG–142299–01, 2002–4 I.R.B.418 REG–159079–01, 2002–6 I.R.B.493 Revenue Procedures: 2002–1, 2002–1 I.R.B.1 2002–2, 2002–1 I.R.B.82 2002–3, 2002–1 I.R.B.117 2002–4, 2002–1 I.R.B.127 2002–5, 2002–1 I.R.B.173 2002–6, 2002–1 I.R.B.203 2002–7, 2002–1 I.R.B.249 2002–8, 2002–1 I.R.B.252 2002–9, 2002–3 I.R.B.327 2002–10, 2002–4 I.R.B.400 2002–11, 2002–7 I.R.B.526 2002–12, 2002–3 I.R.B.374 2002–13, 2002–8 I.R.B.549 2002–14, 2002–5 I.R.B.450 2002–15, 2002–6 I.R.B.490 2002–16, 2002–9 I.R.B.572 Revenue Rulings: 2002–1, 2002–2 I.R.B.268 2002–2, 2002–2 I.R.B.271 2002–3, 2002–3 I.R.B.316 2002–4, 2002–4 I.R.B.389 2002–5, 2002–6 I.R.B.461 2002–6, 2002–6 I.R.B.460 2002–7, 2002–8 I.R.B.543 2002–8, 2002–9 I.R.B.564 2002–9, 2002–10 I.R.B.614 2002–10, 2002–10 I.R.B.616 2002–11, 2002–10 I.R.B.608 Treasury Decisions: 8968, 2002–2 I.R.B.274 8969, 2002–2 I.R.B.276 8970, 2002–2 I.R.B.281 8971, 2002–3 I.R.B.308 8972, 2002–5 I.R.B.443 8973, 2002–4 I.R.B.391 8974, 2002–3 I.R.B.318 8975, 2002–4 I.R.B.379 8976, 2002–5 I.R.B.421 8977, 2002–6 I.R.B.463 8978, 2002–7 I.R.B.500 8979, 2002–6 I.R.B.466 8980, 2002–6 I.R.B.477 8981, 2002–7 I.R.B.496 8982, 2002–8 I.R.B.544 8983, 2002–9 I.R.B.565 1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2001–27 through 2001–53 is in Internal Revenue Bulletin 2002–1, dated January 7, 2002. March 18, 2002ii2002–11 I.R.B. Finding List of Current Actions on Previously Published Items 2 Bulletins 2002–1 through 2002–10 Notices: 98–43 Modified and superseded by Notice 2002–5, 2002–3 I.R.B.320 2001–10 Revoked by Notice 2002–8, 2002–4 I.R.B.398 2000–11 Obsoleted by Notice 2002–3, 2002–2 I.R.B.289 2001–61 Supplemented by Notice 2002–15, 2002–8 I.R.B.548 2001–68 Supplemented by Notice 2002–15, 2002–8 I.R.B.548 Proposed Regulations: REG–209135–88 Corrected by Ann. 2002–15, 2002–7 I.R.B.540 REG–105344–01 Corrected by Ann. 2002–7, 2002–5 I.R.B.459 REG–142299–01 Corrected by Ann. 2002–15, 2002–7 I.R.B.540 Revenue Procedures: 84–37 Modified by Rev. Proc. 2002–1, 2002–1 I.R.B.1 84–57 Obsoleted by T.D. 8976, 2002–5 I.R.B.421 87–50 Modified by Rev. Proc. 2002–10, 2002–4 I.R.B.400 96–13 Modified by Rev. Proc. 2002–1, 2002–1 I.R.B.1 98–49 Obsoleted by T.D. 8976, 2002–5 I.R.B.421 99–49 Modified and superseded by Rev. Proc. 2002–9, 2002–3 I.R.B.327 Revenue Procedures:—Continued 2002–6 Modified by Notice 2002–1, 2002–2 I.R.B.283 2002–8 Modified by Notice 2002–1, 2002–2 I.R.B.283 2002–9 Modified and clarified by Ann. 2002–17, 2002–8 I.R.B.561 Modified and amplified by Rev. Rul. 2002–9, 2002–10 I.R.B.614 2000–20 Modified by Rev. Proc. 2002–6, 2002–1 I.R.B.203 2001–1 Superseded by Rev. Proc. 2002–1, 2002–1 I.R.B.1 2001–2 Superseded by Rev. Proc. 2002–2, 2002–1 I.R.B.82 2001–3 Superseded by Rev. Proc. 2002–3, 2002–1 I.R.B.117 2001–4 Superseded by Rev. Proc. 2002–4, 2002–1 I.R.B.127 2001–5 Superseded by Rev. Proc. 2002–5, 2002–1 I.R.B.173 2001–6 Superseded by Rev. Proc. 2002–6, 2002–1 I.R.B.203 2001–7 Superseded by Rev. Proc. 2002–7, 2002–1 I.R.B.249 2001–8 Superseded by Rev. Proc. 2002–8, 2002–1 I.R.B.252 2001–13 Corrected by Ann. 2002–5, 2002–4 I.R.B.420 2001–36 Superseded by Rev. Proc. 2002–3, 2002–1 I.R.B.117 2001–41 Superseded by Rev. Proc. 2002–2, 2002–1 I.R.B.82 2001–51 Superseded by Rev. Proc. 2002–3, 2002–1 I.R.B.117 Revenue Rulings: 55–747 Revoked by Notice 2002–8, 2002–4 I.R.B.398 61–146 Distinguished by Rev. Rul. 2002–3, 2002–3 I.R.B.316 64–328 Modified by Notice 2002–8, 2002–4 I.R.B.398 66–110 Modified by Notice 2002–8, 2002–4 I.R.B.398 89–29 Obsoleted by T.D. 8976, 2002–5 I.R.B.421 2002–7 Corrected by Ann. 2002–13, 2002–7 I.R.B.540 Treasury Decisions: 8971 Corrected by Ann. 2002–20, 2002–8 I.R.B.561 8972 Corrected by Ann. 2002–23, 2002–8 I.R.B.563 8973 Corrected by Ann. 2002–14, 2002–7 I.R.B.540 8975 Corrected by Ann. 2002–21, 2002–8 I.R.B.562 8976 Corrected by Ann. 2002–21, 2002–8 I.R.B.562 2 A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2001–27 through 2001–53 is in Internal Revenue Bulletin 2002–1, dated January 7, 2002. 2002–11 I.R.B.iiiMarch 18, 2002
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