Internal Revenue Bulletin 2002-8 (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.

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. 2002–7, page 543.
LIFO; price indexes; department stores.The December
2001 Bureau of Labor Statistics price indexes are accepted for
use by department stores employing the retail inventory and
last-in, first-out inventory methods for valuing inventories for
tax years ended on, or with reference to, December 31, 2001.
T.D. 8982, page 544.
Final regulations under section 1031 of the Code narrow the
definition of the term disqualified person for section 1031 like-
kind exchanges in response to recent changes in the federal
banking law, especially the repeal of section 20 of the Banking
Act of 1933 (the Glass-Steagall Act). The regulations will affect
the eligibility of certain persons to serve as escrow holders of
qualified escrow accounts, trustees of qualified trusts, and
qualified intermediaries.
Notice 2002–13, page 547.
Low-income housing tax credit.This notice reproduces the
proper population figures to be used for determining the 2002
calendar year population-based component of the state hous-
ing credit ceiling under section 42(h) of the Code and the 2002
calendar year volume cap under section 146 of the Code.
Notice 2002–14, page 548.
Automatic change to the cash method of accounting.
Qualifying small business taxpayers within the scope of the pro-
posed revenue procedure set forth in Notice 2001–76
(2001–52 I.R.B. 613) may change to the cash method of
accounting and treat inventoriable items as non-incidental
materials and supplies with respect to its eligible trades or
businesses for any taxable year ending on or after December
31, 2001.
Rev. Proc. 2002–13, page 549.
This procedure provides a safe harbor method for valuing
stock options under the golden parachute payment rules of
section 280G of the Code. Generally, under the safe harbor
valuation method described in the procedure, on the valuation
date, the volatility of the underlying stock, the exercise price of
the option, the value of the stock at the time of the valuation,
and the maximum term of the option are taken into account.
EMPLOYEE PLANS
Announcement 2002–12, page 553.
Nonbank trustees; section 1.408–2(e) of the regulations.
This announcement contains a list of entities previously
approved to act as nonbank trustees and custodians within the
meaning of section 1.408–2(e) of the regulations. In addition,
the announcement contains instructions on how errors in the
list may be corrected.
EMPLOYMENT TAX
Announcement 2002–19, page 561.
This announcement provides an extension of time to February
15, 2002, for employers to furnish Forms W-2 for the 2001 tax
year to household employees.
(Continued on the next page)
Finding Lists begin on page ii.
Bulletin No. 2002–8
February 25, 2002

EXCISE TAX
Rev. Proc. 2002–13, page 549.
This procedure provides a safe harbor method for valuing
stock options under the golden parachute payment rules of
section 280G of the Code. Generally, under the safe harbor
valuation method described in the procedure, on the valuation
date, the volatility of the underlying stock, the exercise price of
the option, the value of the stock at the time of the valuation,
and the maximum term of the option are taken into account.
ADMINISTRATIVE
REG–120135–01, page 552.
Proposed regulations relate to the definition of agent for cer-
tain purposes. The regulations clarify that the term agent in
certain provisions of section 6103 of the Code includes con-
tractors.
Notice 2002–15, page 548.
This notice supplements the tax relief granted in Notices
2001–61 (2001–40 I.R.B. 305) and 2001–68 (2001–47 I.R.B.
504) for taxpayers affected by the September 11, 2001, ter-
rorist attack by providing an additional postponement of time
to apply for a tentative carryback adjustment under section
6411 of the Code.
Announcement 2002–17, page 561.
Changes in method of accounting; automatic consent.
This announcement reflects corrections to Rev. Proc. 2002–9
(2002–3 I.R.B. 327), which provides procedures under which
taxpayers may obtain automatic consent of the Commissioner
to change certain methods of accounting. Rev. Proc. 2002–9
modified and clarified.
Announcement 2002–20, page 561.
This document contains corrections to temporary regulations
(T.D. 8971, 2002–3 I.R.B. 308) relating to guidance on the
new markets tax credit.
Announcement 2002–21, page 562.
This document contains corrections to temporary regulations
(T.D. 8975, 2002–4 I.R.B. 379) relating to certain transfers of
property to a Regulated Investment Company (RIC) or a Real
Estate Investment Trust (REIT).
Announcement 2002–22, page 562.
This document contains corrections to final regulations (T.D.
8976, 2002–5 I.R.B. 421) that provide guidance regarding
methods of valuing dollar-value LIFO pools and affect persons
who elect to use the dollar-value LIFO and inventory price index
computation (IPIC) methods or who receive dollar-value LIFO
inventories in certain nonrecognition transactions.
Announcement 2002–23, page 563.
This document contains corrections to final regulations (T.D.
8972, 2002–5 I.R.B. 443) relating to averaging of farm
income.
February 25, 20022002–8 I.R.B.

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.
2002–8 I.R.B.February 25, 2002

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;priceindexes;department
stores.The December 2001 Bureau of
Labor Statistics price indexes are
accepted for use by department stores
employing the retail inventory and last-in,
first-out inventory methods for valuing
inventories for tax years ended on, or
with reference to, December 31, 2001.
Rev. Rul. 2002–7
The following Department Store
Inventory Price Indexes for December
2001 were issued by the Bureau of Labor
Statistics. The indexes are accepted by
the Internal Revenue Service, under
§ 1.472–1(k) of the Income Tax Regula-
tions and Rev. Proc. 86–46 (1986–2 C.B.
739), for appropriate application to inven-
tories of department stores employing the
retail inventory and last-in, first-out
inventory methods for tax years ended on,
or with reference to, December 31, 2001.
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, food, liquor, tobacco, and contract
departments.
BUREAU OF LABOR STATISTICS, DEPARTMENT STORE
INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS
(January 1941 = 100, unless otherwise noted)
GroupsDec.
2000
Dec.
2001
Percent
Change
from Dec. 2000
to Dec. 2001
1
1.Piece Goods ------------------------------------------------------------489.0484.4-0.9
2.Domestics and Draperies ---------------------------------------------614.5591.0-3.8
3.Women’s and Children’s Shoes -------------------------------------647.4639.8-1.2
4.Men’s Shoes ------------------------------------------------------------901.8889.1-1.4
5.Infants’ Wear -----------------------------------------------------------631.7623.4-1.3
6.Women’s Underwear --------------------------------------------------567.2569.00.3
7.Women’s Hosiery------------------------------------------------------342.9352.92.9
8.Women’s and Girls’ Accessories------------------------------------533.8557.44.4
9.Women’s Outerwear and Girls’ Wear ------------------------------381.8365.4-4.3
10.Men’s Clothing --------------------------------------------------------584.0564.3-3.4
11.Men’s Furnishings -----------------------------------------------------618.3595.3-3.7
12.Boys’ Clothing and Furnishings ------------------------------------487.8473.6-2.9
13.Jewelry ------------------------------------------------------------------910.2895.8-1.6
14.Notions ------------------------------------------------------------------795.1817.82.9
15.Toilet Articles and Drugs---------------------------------------------984.4975.7-0.9
16.Furniture and Bedding ------------------------------------------------692.8625.9-9.7
17.Floor Coverings --------------------------------------------------------628.7625.2-0.6
18.Housewares -------------------------------------------------------------769.3758.9-1.4
19.Major Appliances ------------------------------------------------------229.6226.7-1.3
20.Radio and Television--------------------------------------------------57.151.9-9.1
21.Recreation and Education
2
-------------------------------------------91.887.9-4.2
22.Home Improvements
2
-------------------------------------------------129.3124.2-3.9
23.Auto Accessories
2
-----------------------------------------------------108.2110.42.0
2002–8 I.R.B.543February 25, 2002

BUREAU OF LABOR STATISTICS, DEPARTMENT STORE
INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS
(January 1941 = 100, unless otherwise noted)
GroupsDec.
2000
Dec.
2001
Percent
Change
from Dec. 2000
to Dec. 2001
1
Groups 1–15: Soft Goods -------------------------------------------------589.8575.7-2.4
Groups 16–20: Durable Goods -------------------------------------------433.9417.1-3.9
Groups 21–23: Misc. Goods
2
---------------------------------------------100.097.3-2.7
Store Total
3
--------------------------------------------------------------531.7517.2-2.7
1
Absence of a minus sign before the percentage change in this column signifies a 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, food,
liquor, tobacco, and contract departments.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Michael Burkom of the Office of
Associate Chief Counsel (Income Tax and
Accounting). For further information
regarding this revenue ruling, contact Mr.
Burkom at (202) 622–7718 (not a toll-
free call).
Section 1031.—Exchange of
Property Held for Productive
Use or Investment
26 CFR 1.1031(k)–1: Treatment of deferred
exchanges.
T.D. 8982
DEPARTMENT OF THE
TREASURY
Internal Revenue Service
26 CFR Part 1
Definition of Disqualified
Person
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations.
SUMMARY: This document contains
final regulations narrowing the definition
of the term disqualified person for section
1031 like-kind exchanges. The amend-
ments in the regulations are in response to
recent changes in the federal banking law,
especially the repeal of section 20 of the
Banking Act of 1933 (commonly referred
to as the Glass-Steagall Act). The regula-
tions will affect the eligibility of certain
persons to serve as escrow holders of
qualified escrow accounts, trustees of
qualified trusts, and qualified intermediar-
ies.
DATES:Effective Date: These regula-
tions are effective February 1, 2002.
Dates of Applicability: These regula-
tions apply to transfers of property made
by a taxpayer on or after January 17,
2001.
FOR FURTHER INFORMATION CON-
TACT: Brendan O’Hara, (202) 622–4920
(not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
This document contains amendments
to the Income Tax Regulations (26 CFR
Part 1) under§1.1031(k)–1. On January
17, 2001, the IRS and Treasury Depart-
ment published in theFederal Registera
notice of proposed rulemaking under sec-
tion 1031 (REG–107175–00, 2001–13
I.R.B. 971) (66 FR 3924). The notice pro-
posed to amend§1.1031(k)–1(k) by nar-
rowing the definition of the termdisquali-
fied person. Comments responding to the
notice were received, and a public hear-
ing was held on June 5, 2001. After con-
sidering the comments received in
response to the notice of proposed rule-
making and the statements made at the
public hearing, the proposed regulations
are adopted as revised by this Treasury
decision. The comments and revisions are
discussed below.
Explanation of Provisions
Under section 1031 and the regulations
thereunder, taxpayers may use a qualified
escrow account, qualified trust, or quali-
fied intermediary to facilitate a like-kind
exchange. A requirement common to
qualified escrow accounts, qualified
trusts, and qualified intermediaries is that
the escrow holder, trustee, or intermedi-
ary may not be the taxpayer or a disquali-
fied person.
Section 1.1031(k)–1(k) defines a dis-
qualified person to include an agent of the
taxpayer at the time of the transaction. An
agent includes a person that has acted as
the taxpayer’s employee, attorney,
accountant, investment banker or broker,
or real estate agent or broker within two
years of the taxpayer’s transfer of relin-
quished property. However, in determin-
ing whether a person is a disqualified per-
son, services provided by such person for
the taxpayer with respect to section 1031
exchanges of property and routine finan-
cial, title insurance, escrow, or trust ser-
vices provided to the taxpayer by a finan-
cial institution, title insurance company,
February 25, 20025442002–8 I.R.B.

or escrow company are not taken into
account. Under§1.1031(k)–1(k)(4), a
person that is related to a disqualified per-
son, determined by using the attribution
rules of sections 267(b) and 707(b), but
substituting 10 percent for 50 percent, is
also considered a disqualified person.
As a consequence of the Gramm-
Leach-Bliley Act, Public Law 106–102
(Nov. 12, 1999), 113 Stat. 1341, and other
changes in policy by the Federal Reserve
System in recent years, many banks are,
or are in the process of becoming, mem-
bers of controlled groups that include
investment banking and brokerage firms.
These new relationships between banks
and investment banking and brokerage
firms may make it difficult for some
banks to continue their traditional prac-
tices of providing qualified escrow, quali-
fied trust, and qualified intermediary ser-
vices without violating the disqualified
person rules. To allow banks to continue
to perform these services, the proposed
regulations provide that a bank that is a
member of a controlled group that
includes an investment banking or broker-
age firm as a member will not be a dis-
qualified person merely because the
related investment banking or brokerage
firm provided services to an exchange
customer within a two-year period ending
on the date of the transfer of the relin-
quished property by that customer.
Treasury and the IRS received several
comments on the proposed regulations.
Some commentators argued that the pro-
posed exception to the disqualified person
rules would not fulfill its intended pur-
pose, because most banks use non-bank
subsidiaries or affiliates to serve as
escrow holders of qualified escrow
accounts, trustees of qualified trusts, or
qualified intermediaries. These commen-
tators recommended that the proposed
exception be extended to apply to subsid-
iaries and affiliates of banks. In response
to these comments, the final regulations
extend the proposed exception to bank
affiliates as well as banks. For this pur-
pose, a bank affiliate is a non-bank corpo-
ration whose principal activity is render-
ing services to facilitate exchanges of
property intended to qualify for nonrec-
ognition of gain under section 1031 and
all of whose outstanding stock is owned
by either a bank or a bank holding com-
pany (within the meaning of section 2(a)
of the Bank Holding Company Act of
1956, 12 U.S.C. 1841(a)).
Some commentators noted the discrep-
ancy between the effective date set forth
in the text of the proposed regulations
(i.e., applicable to transfers of relin-
quished property on or after the date of
the final regulations) and the effective
date set forth in the Preamble to those
regulations (i.e., applicable to transfers of
relinquished property on or after January
17, 2001). In response to the comments,
the final regulations adopt the earlier of
the two effective dates, and thus apply in
the case of transfers of relinquished prop-
erty made by a taxpayer on or after Janu-
ary 17, 2001.
Other commentators expressed opposi-
tion to the proposed regulations, request-
ing that the regulations be withdrawn.
The commentators maintained that the
existing regulations provide adequate
exceptions to the definition of disquali-
fied person, and that an exception for the
banking industry will erode the integrity
and purpose of the disqualified person
concept.
Treasury and the IRS continue to
believe that the amendment to the regula-
tions is appropriate and necessary for the
reasons articulated in the Preamble to the
proposed regulations. Banks and their
affiliates are closely regulated institutions
that have historically acted as neutral and
independent holders of funds. Treasury
and the IRS do not believe that recent
changes to federal banking laws are likely
to impinge on this role to any significant
degree.
Finally, one commentator requested
that the final regulations include the
exception from the disqualified person
rule set forth in section 3.03 of Rev. Proc.
2000–37 (2000–2 C.B. 308). Rev. Proc.
2000–37, published to facilitate reverse
like-kind exchanges, provides a safe har-
bor for the qualification under section
1031 of certain arrangements between
taxpayers and exchange accommodation
titleholders and provides for the treatment
of the exchange accommodation title-
holder as the beneficial owner of the
property for federal income tax purposes.
Section 3.03 of the revenue procedure
provides that services performed for the
taxpayer in connection with a person’s
role as the exchange accommodation
titleholder are not taken into account in
determining whether that person or a
related person is a disqualified person.
Treasury and the IRS do not believe that
this rule needs to be restated in these
regulations. Consequently, the final regu-
lations do not include the exception from
the disqualified person rule set forth in
Rev. Proc. 2000–37.
Special Analyses
It has been determined that this Trea-
sury decision is not a significant regula-
tory action as defined in Executive Order
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 regula-
tions, and because these regulations do
not impose a collection of information on
small entities, the Regulatory Flexibility
Act (5 U.S.C. chapter 6) does not apply.
Pursuant to section 7805(f) of the Internal
Revenue Code, the notice of proposed
rulemaking preceding these regulations
was submitted to the Chief Counsel for
Advocacy of the Small Business Admin-
istration for comment on its impact on
small business.
Drafting Information
The principal author of the regulations
is Brendan O’Hara, Office of Associate
Chief Counsel (Income Tax and Account-
ing). However, other personnel from the
IRS and Treasury Department partici-
pated in the development of the regula-
tions.
*****
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR part 1 is
amended as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 continues to read in part as follows:
Authority: 26 U.S.C. 7805***
Par 2. In§1.1031(k)–1, paragraph
(k)(4) is revised to read as follows:
2002–8 I.R.B.545February 25, 2002

§1.1031(k)–1 Treatment of deferred
exchanges.
*****
(k)***
(4)(i) Except as provided in paragraph
(k)(4)(ii) of this section, the person and a
person described in paragraph (k)(2) of
this section bear a relationship described
in either section 267(b) or 707(b) (deter-
mined by substituting in each section“10
percent”for“50 percent”each place it
appears).
(ii) In the case of a transfer of relin-
quished property made by a taxpayer on
or after January 17, 2001, paragraph
(k)(4)(i) of this section does not apply to
a bank (as defined in section 581) or a
bank affiliate if, but for this paragraph
(k)(4)(ii), the bank or bank affiliate would
be a disqualified person under paragraph
(k)(4)(i) of this section solely because it
is a member of the same controlled group
(as determined under section 267(f)(1),
substituting“10 percent”for“50 percent”
where it appears) as a person that has pro-
vided investment banking or brokerage
services to the taxpayer within the 2-year
period described in paragraph (k)(2) of
this section. For purposes of this para-
graph (k)(4)(ii), a bank affiliate is a cor-
poration whose principal activity is ren-
dering services to facilitate exchanges of
property intended to qualify for nonrec-
ognition of gain under section 1031 and
all of whose stock is owned by either a
bank or a bank holding company (within
the meaning of section 2(a) of the Bank
Holding Company Act of 1956 (12
U.S.C. 1841(a)).
*****
Robert E. Wenzel,
Deputy Commissioner of
Internal Revenue.
Approved January 25, 2002.
Mark Weinberger,
Assistant Secretary of
the Treasury.
(Filed by the Office of the Federal Register on Janu-
ary 31, 2002, 8:45 a.m., and published in the issue
of the Federal Register for February 1, 2002, 67 F.R.
4907)
February 25, 20025462002–8 I.R.B.

Part III. Administrative, Procedural, and Miscellaneous
Low-Income Housing Tax
Credit—2002 Calendar Year
Resident Population Estimates
Notice 2002–13
This notice informs (1) state and local
housing credit agencies that allocate low-
income housing tax credits under§42 of
the Internal Revenue Code and (2) states
and other issuers of tax-exempt private
activity bonds under§141, of the proper
population figures to be used for calculat-
ing the 2002 calendar year population-
based component of the state housing
credit ceiling (Credit Ceiling) under
§42(h)(3)(C)(ii) and the 2002 calendar
year volume cap (Volume Cap) under
§146.
The population figures both for the
population-based component of the Credit
Ceiling and for the Volume Cap are deter-
mined by reference to§146(j). That sec-
tion provides generally that determina-
tions of population for any calendar year
are made on the basis of the most recent
census estimate of the resident population
of a state (or issuing authority) released
by the Bureau of the Census before the
beginning of such calendar year.
The proper population figures for cal-
culating the Credit Ceiling and the Vol-
ume Cap for the 2002 calendar year are
the estimates of the resident population of
the 50 states and the District of Colum-
bia, released by the Bureau of the Census
on December 28, 2001, in Press Release
CB01–203. The proper population figures
for calculating the Credit Ceiling and the
Volume Cap for the 2002 calendar year
for Puerto Rico are the estimates of the
resident population for July 1, 2001,
released by the Bureau of the Census on
December 31, 2001, in Press Release
CB01–205. The proper population figures
for calculating the Credit Ceiling and the
Volume Cap for the 2002 calendar year
for the insular areas (American Samoa,
Guam, Northern Mariana Islands, and
U.S. Virgin Islands) are the figures
released by the Bureau of the Census on
July 3, 2001, in press release CB01–
CN.1. For convenience, these estimates
are reprinted below.
Resident Population Figures
Alabama4,464,356
Alaska634,892
American Samoa57,291
Arizona5,307,331
Arkansas2,692,090
California34,501,130
Colorado4,417,714
Connecticut3,425,074
Delaware796,165
D.C.571,822
Florida16,396,515
Georgia8,383,915
Guam154,805
Hawaii1,224,398
Idaho1,321,006
Illinois12,482,301
Indiana6,114,745
Iowa2,923,179
Kansas2,694,641
Kentucky4,065,556
Louisiana4,465,430
Maine1,286,670
Maryland5,375,156
Massachusetts6,379,304
Michigan9,990,817
Minnesota4,972,294
Mississippi2,858,029
Missouri5,629,707
Montana904,433
Nebraska1,713,235
Nevada2,106,074
New Hampshire1,259,181
New Jersey8,484,431
Resident Population Figures
New Mexico1,829,146
New York19,011,378
North Carolina8,186,268
North Dakota634,448
Northern Mariana Islands69,221
Ohio11,373,541
Oklahoma3,460,097
Oregon3,472,867
Pennsylvania12,287,150
Puerto Rico3,839,810
Rhode Island1,058,920
South Carolina4,063,011
South Dakota756,600
Tennessee5,740,021
Texas21,325,018
U.S. Virgin Islands108,612
Utah2,269,789
Vermont613,090
Virginia7,187,734
Washington5,987,973
West Virginia1,801,916
Wisconsin5,401,906
Wyoming494,423
The principal authors of this notice are
Christopher J. Wilson, Office of the Asso-
ciate Chief Counsel (Passthroughs and
Special Industries) and Timothy L. Jones,
Office of the Chief Counsel (Tax-Exempt
and Government Entities). For further
information regarding this notice, contact
Mr. Wilson at (808) 539–2874 or Susan
Reaman at (202) 622–3040 (not toll-free
calls).
2002–8 I.R.B.547February 25, 2002

Permission to Change to the
Cash Method of Accounting
Notice 2002–14
Notice 2001–76 (2001–52 I.R.B. 613)
sets forth a proposed revenue procedure
that would permit certain small busi-
nesses with average annual gross receipts
of $10 million or less to use the cash
receipts and disbursements method of
accounting (“cash method”) and to treat
inventoriable items as non-incidental
materials and supplies (“materials and
supplies method”) with respect to eligible
trades or businesses. Pursuant to the
Commissioner’s discretion under§446(e)
of the Internal Revenue Code, this notice
provides that any qualifying small busi-
ness taxpayer within the scope of the pro-
posed revenue procedure (“small business
taxpayer”) may change to these methods
of accounting with respect to its eligible
trades or businesses for any taxable year
ending on or after December 31, 2001.
Pending publication of a final revenue
procedure in the Internal Revenue Bulle-
tin, a small business taxpayer may obtain
automatic consent to change to the cash
method and the materials and supplies
method by complying with the proce-
dures provided in the proposed revenue
procedure. These procedures state that a
small business taxpayer may change to
the cash method and the materials and
supplies method for any taxable year end-
ing on or after December 31, 2001, by
attaching the original Form 3115,Appli-
cation for Change in Accounting Method,
to its timely filed (including extensions)
federal income tax return for that year (or
on an amended return filed within six
months of the original due date of the
return), filing a duplicate of the Form
3115 with the Internal Revenue Service’s
National Office, and complying with the
provisions of Rev. Proc. 2002–9 (2002–3
I.R.B. 327) as modified by the proposed
revenue procedure. Both changes may be
made on a single Form 3115. A taxpayer
that has fully complied with these proce-
dures has obtained the consent of the
Commissioner under§446(e) to change
its method of accounting to these
methods.
DRAFTING INFORMATION
The principal author of this notice is
Cheryl L. Oseekey of the Office of Asso-
ciate Chief Counsel (Income Tax and
Accounting). For further information
regarding this notice, contact Ms.
Oseekey at (202) 622–4970 (not a toll-
free call).
Additional Disaster Relief for
Taxpayers Affected by the
September 11, 2001,
Terrorist Attack
Notice 2002–15
PURPOSE
This notice supplements the tax relief
granted in Notice 2001–61 (2001–40
I.R.B. 305) (October 1, 2001), and Notice
2001–68 (2001–47 I.R.B. 504) (Novem-
ber 19, 2001), for taxpayers affected by
the September 11, 2001, Terrorist Attack
by providing an additional postponement
of time for certain affected taxpayers to
apply for a tentative carryback adjustment
under I.R.C.§6411. The relief provided
to taxpayers in this notice will apply ret-
roactively to September 11, 2001.
GRANT OF RELIEF
Paragraph (3) of the Additional Grant
of Relief section (Section C) of Notice
2001–68, granted to all affected taxpayers
a 120-day postponement of time to per-
form the acts listed in Rev. Proc. 2001–53
(2001–47 I.R.B 506) (November 19,
2001), if the last day to perform the act
would otherwise fall within the period
beginning on September 11, 2001, and
ending on November 30, 2001 (the“win-
dow period”). One of the acts listed in
Rev. Proc. 2001–53 is the application
under section 6411 for a tentative carry-
back adjustment of the tax for a prior tax-
able year. To apply for a tentative carry-
back adjustment, corporate taxpayers
must file Form 1139 and noncorporate
taxpayers must file Form 1045 on or after
the due date of the return for the taxable
year that generates the net operating loss,
net capital loss, or unused business credit
from which the carryback results and
within 12 months after the end of such
year. This procedure allows a taxpayer to
obtain a refund without having to file an
amended return for the year to which the
taxpayer carries back the loss or credit.
Normally, the twelve month period for
filing for the tentative carryback falls
after the filing due date even if the filing
due date is extended for six months under
section 6081. Taxpayers affected by the
September 11, 2001, Terrorist Attack that
received a filing extension and/or post-
ponement under Notice 2001–61, how-
ever, now have a due date for the return
that falls after the 12 month period pro-
vided by section 6411. In cases where the
due date for filing for the tentative carry-
back under section 6411 falls outside the
window period provided by section C,
paragraph (3) of Notice 2001–68, such
taxpayers would have to file for their ten-
tative carryback before they filed the
return for the year the loss or credit arose.
To remedy this situation, this notice
expands the relief provided by section C,
paragraph (3) of Notice 2001–68 by pro-
viding affected taxpayers with an addi-
tional 120 days in which to file for their
tentative carryback under section 6411 if
Notice 2001–61 extended and/or post-
poned the due date of their income tax
return.
For example, an affected individual
income taxpayer who obtained an exten-
sion of time to file the 2000 tax return
until October 15, 2001, would qualify for
a 120-day postponement of time to file
under Notice 2001–61 until February 12,
2002. Under section 6411, the last day the
taxpayer could file Form 1045 would be
December 31, 2001. This date is not
within the period provided by Notice
2001–61. Thus, without this notice, the
taxpayer would need to file Form 1045
before the return is due. Under this
notice, however, the taxpayer will have
an additional 120 days from December
31, 2001 (the last day for applying for the
tentative carryback under section 6411),
to file Form 1045.
Taxpayers who believe they are
entitled to relief under this notice should
mark“September 11, 2001 Terrorist
Attack”in red ink on the top of their
Form 1139 or 1045 submitted to the IRS.
Taxpayers should not put this notation
on envelopes.Doing so may result in a
delay in the delivery or processing of the
return or document.
February 25, 20025482002–8 I.R.B.

DRAFTING INFORMATION
This notice was drafted by the Office
of Associate Chief Counsel, Procedure
and Administration (Administrative Pro-
visions and Judicial Practice Division).
For further information regarding this
notice, you may call (202) 622–4940 (not
a toll-free call).
26 CFR 601.105: Examination of returns and claims
for refund, credit, or abatement; determination of
correct tax liability.
(Also, Part 1, 280G.)
Rev. Proc. 2002–13
SECTION 1. PURPOSE
This revenue procedure provides guid-
ance for valuing stock options, including
a safe harbor for valuing compensatory
stock options for purposes of§§280G
and 4999 of the Internal Revenue Code.
The Internal Revenue Service will treat
the value of a compensatory stock option
determined in accordance with the
requirements of this revenue procedure
as properly determined for purposes of
§§280G and 4999.
SECTION 2. BACKGROUND
Section 280G denies a deduction to a
corporation for any excess parachute pay-
ment. An excess parachute payment is
defined in§280G(b)(1) as an amount
equal to the excess of any parachute pay-
ment over the portion of the disqualified
individual’s base amount that is allocated
to such payment.
Section 280G(b)(2)(A) defines a para-
chute payment as any payment in the
nature of compensation to (or for the ben-
efit of) a disqualified individual if such
payment is (i) contingent on a change in
the ownership of a corporation, the effec-
tive control of a corporation, or the own-
ership of a substantial portion of the
assets of a corporation (a change in own-
ership or control), and (ii) the aggregate
present value of the payments in the
nature of compensation which are contin-
gent on such change equals or exceeds an
amount equal to 3 times the base amount.
The term parachute payment also
includes any payment in the nature of
compensation to, or for the benefit of, a
disqualified individual if the payment is
pursuant to an agreement that violates any
generally enforced securities laws or
regulations.
A payment in the nature of compensa-
tion for purposes of§280G includes the
transfer of an option (including an option
to which§421 applies), without regard to
whether the option has a readily ascer-
tainable fair market value within the
meaning of§83. The option is considered
transferred not later than the time at
which the option becomes substantially
vested (within the meaning of§1.83–3(b)
and (j)).
An individual’s base amount is, in
general, the individual’s average annual-
ized includible compensation for the most
recent 5 taxable years ending before the
date of the corporation’s change in own-
ership or control. For this purpose, the
portion of the base amount allocated to a
parachute payment is the amount that
bears the same ratio to the base amount as
the present value of the parachute pay-
ment bears to the aggregate present value
of all such payments to the same disquali-
fied individual.
Section 4999 imposes a 20-percent
excise tax on the recipient of any excess
parachute payment, within the meaning of
§280G(b).
Rev. Proc. 98–34 (1998–1 C.B. 983)
provides a methodology for valuation of
certain compensatory stock options for
purposes of gift, estate, and generation-
skipping transfer taxes. The methodology
described in Rev. Proc. 98–34 is an
option pricing model that takes into
account factors similar to those estab-
lished by the Financial Accounting Stan-
dards Board in Accounting for Stock-
Based Compensation, Statement of
Financial Accounting Standards No. 123
(Fin. Accounting Standards Bd. 1995
(FAS 123)). This methodology applies
only to the valuation of a nonpublicly
traded compensatory stock option for
stock that, on the valuation date, is pub-
licly traded on an established securities
market.
SECTION 3. STOCK OPTION
VALUATION
.01 In general, a taxpayer may value a
compensatory stock option using any
valuation method that is consistent with
generally accepted accounting principles
(such as FAS 123) and that takes into
account the factors provided in§1.280G–
1, Q&A 13. A valuation using the valua-
tion safe harbor method provided in Sec-
tion 4 is considered consistent with
generally accepted accounting principles
for purposes of§§280G and 4999 and
this revenue procedure.
.02 If the stock option is one that could
otherwise be valued under Rev. Proc.
98–34 because the stock option is one
that satisfies the definition of“Compen-
satory Stock Option”under section 3 of
Rev. Proc. 98–34, then, for purposes of
§§280G and 4999 and this revenue pro-
cedure, the valuation is not considered
consistent with generally accepted
accounting principles unless the valuation
is made in accordance with Rev. Proc.
98–34 or the valuation safe harbor
method provided in section 4 of this rev-
enue procedure.
SECTION 4. VALUATION SAFE
HARBOR
.01In general. The safe harbor valua-
tion method provided by this revenue pro-
cedure is based on the Black-Scholes
model and takes into account, as of the
valuation date, the following factors: (1)
the volatility of the underlying stock, (2)
the exercise price of the option, (3) the
value of the stock at the time of the valu-
ation (the“spot price”), and (4) the term
of the option on the valuation date. The
safe harbor value of the option is calcu-
lated as the number of options multiplied
by the spot price of the stock multiplied
by a valuation factor determined using the
factors described above and reflected in
the table in the Appendix. Other relevant
factors, including risk-free rate of interest
and assumptions related to dividend
yields are included in the table in the
Appendix. To determine the valuation
factor, the taxpayer must determine the
volatility, spread, and option term factors,
as described below. To rely on this rev-
enue procedure, assumptions made for
purposes of this revenue procedure and
the determination of each factor must be
reasonable and consistent with assump-
tions made with respect to other options
valued in connection with the change in
ownership or control.
.02Volatility. The taxpayer must deter-
mine whether the volatility of the under-
lying stock is low, medium, or high. For
2002–8 I.R.B.549February 25, 2002

this purpose, a low volatility stock has an
annual standard deviation of 30 percent or
less. A medium volatility stock has an
annual standard deviation greater than 30
percent but less than 70 percent. A high
volatility stock has an annual standard
deviation of 70 percent or greater. If the
stock is publicly traded on an established
securities market (or otherwise), the
expected volatility of the underlying
stock used for purposes of volatility under
this revenue procedure must be the vola-
tility used for purposes of complying with
FAS 123 and disclosed in the most recent
financial statements of the corporation. If
the stock is not publicly traded on an
established securities market or other-
wise, but the stock is required to be reg-
istered under the Securities Exchange Act
of 1934, the volatility for such stock is
assumed to be the same as the volatility
for a comparable corporation that is pub-
licly traded. For this purpose, whether a
corporation is considered comparable is
determined by comparing relevant char-
acteristics such as industry, corporate
size, earnings, market capitalization, and
debt-equity structure. If the stock is not
publicly traded and the corporation is not
required to register under the Securities
Exchange Act of 1934, the taxpayer must
assume medium volatility. If the stock is
not required to be registered under the
Securities Exchange Act of 1934, but the
corporation voluntarily registers its stock
and its stock is publicly traded, the corpo-
ration must use the volatility of the under-
lying stock.
.03Spread between exercise price and
spot price. The factor based on the spread
between the exercise price and the spot
price is calculated by dividing the spot
price by the exercise price and subtracting
1. If the stock is not publicly traded, the
determination of the spot price for this
purpose must be reasonable and consis-
tent with the price, if any, otherwise
determined for the stock in connection
with the transaction giving rise to the
change in control under§280G(b)(2)(A).
For purposes of determining the factor
based on spread between the exercise
price and the spot price under the table in
the Appendix, the resulting percentage
may be rounded down to the next lowest
interval. If this factor exceeds 220%, this
safe harbor valuation method cannot be
used to value the stock option.
.04Maximum term of the option. The
term of the option is the number of full
months between the date of the valuation
and the latest date on which the option
will expire. For purposes of determining
the term factor under the table, the num-
ber of full months may be rounded down
to the next lowest six-month interval. If
the term of the option exceeds 10 years
(120 months), then this safe harbor valu-
ation method cannot be used to value the
stock option.
.05Example. Corporation A undergoes
a change in ownership or control within
the meaning of§280G(b)(2). Contingent
on the change in ownership or control,
Employee E, a disqualified individual,
vests in 100 stock options in Corporation
A stock, each of which has a remaining
term of 60 months after vesting. The
volatility for Corporation A is 50%.
Therefore, the stock has medium volatil-
ity. At the time of the change in owner-
ship or control, the value of the stock is
$24 (the spot price). The exercise price
under each of Employee E’s options is
$20. Therefore, the factor based on spread
is 20% (24/20 - 1). The value of the
options under the safe harbor valuation
method described in section 4 of this rev-
enue procedure is $1,219.20 computed as
follows: 100 options times the spot price
of $24 times 50.8% (the factor in the
table in the Appendix for a medium vola-
tility stock with a 20% spread factor and
a 60-month term). Corporation A is per-
mitted to use this value as the value of the
payment under§1.280G–1, Q&A–13.
SECTION 5. REQUEST FOR
COMMENTS
Comments are requested regarding
safe harbor valuation method described in
this revenue procedure. All comments
will be available for public inspection and
copying. Comments must be submitted by
June 5, 2002. Comments should be sent
to CC:ITA:RU (Rev. Proc. 2002–13),
room 5226, Internal Revenue Service,
POB 7604, Ben Franklin Station, Wash-
ington, DC 20044. Comments may also
be hand delivered between the hours of 8
a.m. and 5 p.m. to: CC:ITA:RU (Rev.
Proc. 2002–13), Courier’s Desk, Internal
Revenue Service,1111Constitution
Avenue NW, Washington, DC. In the
alternative, e-mail your comments to:
Notice.Comments@irscounsel.treas.gov.
SECTION 6. EFFECTIVE DATE
This revenue procedure is effective
April 26, 2002.
SECTION 7. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Erinn Madden of the Office
of the Division Counsel/Associate Chief
Counsel (Tax Exempt and Government
Entities). However, other personnel from
the IRS and Treasury Department partici-
pated in its development. For further
information regarding this revenue proce-
dure, contact Ms. Madden at (202) 622–
6060 (not a toll-free call).
Appendix
Term (months)1224364860728496108120
VolatilitySpread Factor*
Low200%67.3% 67.9%68.4%69.0%69.5%69.9%70.3%70.7%71.0%71.2%
180%65.0% 65.7%66.4%67.1%67.7%68.3%68.8%69.3%69.6%69.9%
160%62.4% 63.3%64.1%65.0%65.8%66.5%67.1%67.7%68.1%68.5%
140%59.4% 60.4%61.5%62.5%63.5%64.4%65.1%65.8%66.4%66.9%
120%55.8% 57.1%58.4%59.7%60.9%62.0%62.9%63.7%64.5%65.1%
100%51.5% 53.2%54.8%56.4%57.9%59.1%60.3%61.3%62.2%63.0%
February 25, 20025502002–8 I.R.B.

Term (months)1224364860728496108120
VolatilitySpread Factor*
Low80%46.3%48.5%50.6%52.6%54.3%55.9%57.3%58.5%59.6%60.5%
60%40.0%42.9%45.6%48.0%50.1%52.0%53.7%55.2%56.5%57.6%
40%32.3%36.3%39.7%42.6%45.2%47.4%49.4%51.2%52.7%54.1%
20%23.3%28.5%32.7%36.2%39.3%41.9%44.3%46.4%48.2%49.9%
0%13.6%19.9%24.7%28.8%32.3%35.4%38.1%40.5%42.7%44.7%
-20%5.4%11.2%16.1%20.4%24.2%27.6%30.6%33.4%35.9%38.1%
-40%0.9%4.1%7.9%11.6%15.2%18.5%21.7%24.6%27.3%29.9%
-60%0.0%0.6%2.0%4.0%6.4%9.0%11.6%14.3%16.8%19.3%
Medium200%67.4%68.6%69.9%71.1%72.2%73.1%73.9%74.5%75.0%75.4%
180%65.2%66.7%68.2%69.6%70.9%71.9%72.8%73.5%74.1%74.6%
160%62.7%64.5%66.3%68.0%69.4%70.6%71.6%72.5%73.2%73.7%
140%59.8%62.0%64.2%66.1%67.7%69.1%70.3%71.2%72.0%72.7%
120%56.4%59.2%61.7%63.9%65.8%67.4%68.8%69.9%70.8%71.6%
100%52.5%55.9%58.9%61.5%63.7%65.5%67.0%68.3%69.4%70.3%
80%47.9%52.2%55.7%58.7%61.2%63.2%65.0%66.5%67.7%68.8%
60%42.6%47.8%52.0%55.4%58.3%60.6%62.7%64.3%65.8%67.0%
40%36.3%42.7%47.6%51.6%54.8%57.6%59.9%61.8%63.5%64.9%
20%29.1%36.8%42.5%47.0%50.8%53.9%56.5%58.8%60.7%62.3%
0%21.2%30.0%36.4%41.6%45.8%49.4%52.4%55.0%57.2%59.1%
-20%13.0%22.2%29.2%34.9%39.7%43.7%47.2%50.2%52.8%55.0%
-40%5.7%13.8%20.8%26.8%32.0%36.4%40.4%43.8%46.8%49.5%
-60%1.2%5.9%11.4%16.9%22.1%26.7%31.0%34.8%38.3%41.4%
High200%68.1%70.7%73.1%75.0%76.6%77.8%78.8%79.5%80.0%80.4%
180%66.1%69.1%71.7%73.9%75.6%77.0%78.1%78.9%79.5%79.9%
160%63.8%67.3%70.3%72.7%74.6%76.1%77.3%78.2%78.9%79.4%
140%61.3%65.3%68.6%71.3%73.4%75.1%76.4%77.4%78.2%78.8%
120%58.3%63.0%66.8%69.7%72.1%73.9%75.4%76.6%77.4%78.1%
100%55.0%60.4%64.6%67.9%70.6%72.6%74.3%75.6%76.6%77.3%
80%51.1%57.4%62.2%65.9%68.8%71.1%73.0%74.4%75.6%76.5%
60%46.6%54.0%59.4%63.5%66.8%69.4%71.4%73.1%74.4%75.4%
40%41.4%50.0%56.1%60.7%64.4%67.3%69.6%71.5%73.0%74.2%
20%35.4%45.3%52.1%57.4%61.5%64.8%67.4%69.6%71.3%72.7%
0%28.5%39.6%47.4%53.3%57.9%61.6%64.7%67.1%69.1%70.8%
-20%20.8%32.9%41.5%48.1%53.4%57.6%61.1%64.0%66.4%68.3%
-40%12.7%24.8%34.0%41.4%47.3%52.2%56.3%59.7%62.5%64.8%
-60%5.2%15.2%24.3%32.1%38.8%44.4%49.1%53.2%56.6%59.5%
*Strike Price/Exercise Price-1or(S/X-1)
2002–8 I.R.B.551February 25, 2002

Part IV. Items of General Interest
Notice of Proposed
Rulemaking
Definition of Agent for Certain
Purposes
REG–120135–01
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of proposed rulemak-
ing.
SUMMARY: This document contains
proposed regulations relating to the defi-
nition of agent for certain purposes. The
proposed regulations clarify that the term
agent in certain provisions of section
6103 of the Internal Revenue Code
includes contractors.
DATES: Written and electronic comments
and requests for a public hearing must be
received by May 1, 2002.
ADDRESSES: Send submissions to
CC:ITA:RU (REG–120135–01), room
5226, Internal Revenue Service, POB
7604, Ben Franklin Station, Washington,
DC 20044. Submissions may be delivered
Monday through Friday between the
hours of 8 a.m. and 5 p.m. to CC:ITA:RU
(REG–120135–01), Courier’s Desk,
Internal Revenue Service,1111Constitu-
tion Avenue, NW, Washington, DC. Alter-
natively, 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:http://
www.irs.ustreas.gov/tax_regs/
regslist.html.
FOR FURTHER INFORMATION CON-
TACT: Helene R. Newsome, 202–622–
4580 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
Generally, returns and return informa-
tion are confidential under section 6103
of the Internal Revenue Code (Code)
unless a specific statutory exception
applies. In cases of non-tax-related dis-
closures, returns and return information
generally may only be disclosed to offic-
ers and employees of federal, state, and
local government agencies, and not to
contractors or agents of such agencies. In
certain limited circumstances, however,
Congress has permitted disclosures to
agents of these agencies. See sections
6103(l)(6)(B), 6103(l)(12), 6103(m)(2),
6103(m)(4), 6103(m)(5), and 6103(m)(7).
This document contains proposed
regulations that clarify that the term agent
in sections 6103(l) and (m) includes con-
tractors. Clarification that the term agent
includes contractors is necessary for the
purpose of bringing certain statutory
grants of disclosure authority into align-
ment with the reality of many agencies’
operations. Agencies generally procure
the services of third parties under public
contracting laws, which do not necessar-
ily correlate with common law concepts
of agent. This clarification is also consis-
tent with Congressional intent. For
example, the Senate Finance Committee,
in amending section 6103(m)(2), stated,
“Agents are those who are engaged
directly in performing or assisting in col-
lection functions for the federal govern-
ment, presumably, private collection
agencies who have contracted with the
government to collect claims...”S. Rep.
No. 97–378, at 15 (1982).
This clarification does not provide any
new disclosure authority, nor does it
authorize the disclosure of return infor-
mation to contractors that Congress has
not previously specifically authorized in
the Code. With regard to protection of
taxpayer data, agents/contractors are sub-
ject to safeguard requirements, redisclo-
sure prohibitions, and civil and criminal
penalties for unauthorized disclosures.
Accordingly, the proposed regulations do
not have an impact on taxpayer privacy.
Special Analyses
It has been determined that this notice
of proposed rulemaking is not a signifi-
cant regulatory action as defined in
Executive Order 12866. Therefore, a
regulatory assessment is not required. It
also has been determined that section
553(b) of the Administrative Procedure
Act (5 U.S.C. chapter 5) and the Regula-
tory Flexibility Act (5 U.S.C. chapter 6)
do not apply to these regulations, and,
therefore, a Regulatory Flexibility Analy-
sis is not required. Pursuant to section
7805(f), this notice of proposed rulemak-
ing will be submitted to the Chief Coun-
sel for Advocacy of the Small Business
Administration for comment on its impact
on small businesses.
Comments and Request for a Public
Hearing
Before these proposed regulations are
adopted as final regulations, consideration
will be given to any electronic and writ-
ten comments (a signed original and eight
(8) copies) that are submitted timely to
the IRS. The IRS and Treasury Depart-
ment request comments on the clarity of
the proposed rule and how it may be
made easier to understand. All comments
will be available for public inspection and
copying. A public hearing may be sched-
uled if requested in writing by a person
that timely submits written comments. If
a public hearing is scheduled, notice of
the date, time, and place for the hearing
willbepublishedintheFederal
Register.
Drafting Information
The principal author of these regula-
tions is Helene R. Newsome, Office of
the Associate Chief Counsel (Procedure
& Administration), Disclosure & Privacy
Law Division.
*****
Proposed Amendments to the
Regulations
Accordingly, 26 CFR part 301 is pro-
posed to be amended as follows:
PART 301—PROCEDURE AND
ADMINISTRATION
Paragraph 1. The authority citation for
part 301 is amended by adding an entry in
numerical order to read as follows:
Authority: 26 U.S.C. 7805 ***
Section 301.6103(l)–1 also issued
under 26 U.S.C. 6103(q);***
Section 301.6103(m)–1 also issued
under 26 U.S.C. 6103(q);***
Par. 2. Section 301.6103(l)–1 is added
to read as follows:
February 25, 20025522002–8 I.R.B.

§301.6103(l)–1 Disclosure of returns
and return information for purposes
other than tax administration.
(a)Definition. For purposes of apply-
ing the provisions of section 6103(l) of
the Internal Revenue Code, the term
agentincludes a contractor.
(b)Effective date. This section is
applicable on or after the date of publica-
tion of the Treasury decision adopting
these regulations as final regulations in
theFederal Register.
Par. 3. Section 301.6103(m)–1is
added to read as follows:
§301.6103(m)–1 Disclosure of taxpayer
identity information.
(a)Definition. For purposes of apply-
ing the provisions of section 6103(m) of
the Internal Revenue Code, the term
agentincludes a contractor.
(b)Effective date. This section is
applicable on or after the date of publica-
tion of the Treasury decision adopting
these regulations as final regulations in
theFederal Register.
Robert E. Wenzel,
Deputy Commissioner of
Internal Revenue.
(Filed by the Office of the Federal Register on Janu-
ary 31, 2002, 8:45 a.m., and published in the issue
of the Federal Register for February 1, 2002, 67 F.R.
4938)
List of Nonbank Trustees and
Custodians
Announcement 2002–12
The following is a list of entities that
have been approved by the Commissioner
of the Internal Revenue Service, pursuant
to§1.408–2(e) of the Income Tax Regu-
lations, to serve as a nonbank trustee or
custodian.
Archer medical savings accounts
(Archer MSAs) established under§220
of the Internal Revenue Code, custodial
accounts of a pension plan qualified
under§401, custodial accounts described
in§403(b)(7), trust or custodial accounts
of individual retirement accounts (IRAs)
established under§§408(a), 408A (Roth
IRAs), or 530 (Coverdell Education Sav-
ings Accounts), and custodial accounts of
eligible deferred compensations plans
described in§457(b) will not be tax
exempt if the trustee or custodian of such
accounts is not a bank (as defined in
§408(n)) (and in the case of Archer
MSAs a bank within the meaning of
§408(n) or an insurance company within
the meaning of§816) or an approved
nonbank trustee or custodian.
An entity that is not a bank, as defined
in§408(n), must receive approval from
the Service to serve as a nonbank trustee
or nonbank custodian. A prospective non-
bank trustee or custodian must file a writ-
ten application with the Commissioner of
Internal Revenue demonstrating that the
requirements of§1.408–2(e)(2) through
§1.408–2(e)(7) of the regulations will be
met. If the application is approved, a writ-
ten notice of approval will be issued to
the applicant. The notice of approval will
state the day on which it becomes effec-
tive, and (except as otherwise provided
therein) will remain effective until
revoked by the Service or withdrawn by
the applicant. Entities that have received
such approval from the Service may also
sponsor certain retirement plans, custodial
accounts under§403(b)(7) of the Code
and individual retirement arrangements
established under§408. (See Rev. Proc.
2000–20, 2000–6 I.R.B. 553, and Rev.
Proc. 87–50, 1987–2 C.B. 647, as modi-
fied.)
A prospective nonbank trustee or cus-
todian may not accept any fiduciary
account before such notice of approval
becomes effective. In addition, a nonbank
trustee or custodian may not accept a
fiduciary account until after the plan
administrator or the person for whose
benefit the account is to be established is
furnished with a copy of the written
notice of approval issued to the applicant.
The continued reliance on a notice of
approval is dependent upon the continued
satisfaction of the nonbank trustee
requirements set forth in the regulations.
The notice of approval issued to an appli-
cant will be revoked if the Commissioner
determines that the applicant is unwilling
or unable to administer fiduciary accounts
in a manner consistent with the require-
ments of the regulations. Generally, the
notice will not be revoked unless the
Commissioner determines that the appli-
cant has knowingly, willfully, or repeat-
edly failed to administer fiduciary
accounts in a manner consistent with the
requirements of the regulations, or has
administered a fiduciary account in a
grossly negligent manner.
The written notice of approval to serve
as a nonbank trustee or nonbank custo-
dian is not an endorsement of any invest-
ment made with respect to any retirement
plan or arrangement handled by the
approved nonbank trustee or custodian.
The Internal Revenue Service does not
review or approve investments.
If the trustee or custodian of an
account described above is not a bank or
an approved nonbank trustee or nonbank
custodian, the amounts held in such
account (including earned interest) will
be deemed distributed and includible in
gross income in the year(s) the account’s
trustee or custodian was not a bank or an
approved nonbank trustee or nonbank
custodian. Contributions made to such
account are not deductible from gross
income and will be disallowed if claimed
on an income tax return.
This list of approved nonbank trustees
and nonbank custodians includes their
names, addresses, and the date each appli-
cation was approved.
If an approved nonbank trustee or cus-
todian believes that the information about
it is incorrect, incomplete, or that it has
been incorrectly omitted from this list, it
may, on or before April 26, 2002, which
is 60 days from the date of the publica-
tion of this list in the Internal Revenue
Bulletin, notify the Service in writing of
any changes it proposes to the list. This
notification should include a copy of the
approval letter.
The notification should be addressed
to:
Internal Revenue Service
T:EP:RA:T1
Announcement 2002–12
1111Constitution Ave., NW
Washington, DC 20224
Drafting Information
The principal author of this announce-
ment is Calvin Thompson of the
Employee Plans, Tax Exempt and Gov-
ernment Entities Division. Please contact
Mr. Thompson at 1–202–283–9596 (not a
toll-free number), if there are any ques-
tions regarding the publication of this list.
Written inquiries concerning this
announcement should be addressed to the
Internal Revenue Service at the above
address.
2002–8 I.R.B.553February 25, 2002

APPROVED Nonbank Trustees/Custodians as of December 31, 2001
NameAddressApproval Date
1. A.B. Culbertson & Co.1250 Continental Plaza
Fort Worth, TX 76102
May 15, 1984
2. A.G. Becker & Co.Chicago, ILDecember 12, 1979
3. A.G. Edwards & Sons,
Inc.
One North Jefferson
St. Louis, MO 63103
November 26, 1980
4. ABN AMRO Securities
LLC
55 East 52nd Street
New York, NY 10022
September 7, 2000
5. Adler, Coleman Clearing
Corp.
20 Broad St.
New York, NY 10005
April 7, 1987
6. Advanced Clearing, Inc.4211 South 102nd Street
Omaha, NE 68127-1031
April 18, 1984
7. Advest, Inc.280 Trumbull Street
Hartford, CT 06103
January 24, 1989
8. Aisel & Co.20 Broad Street
New York, NY 10005
April 26, 1991
9. American Brokerage
Services, Inc.
131 Lafayette Ave.
Detroit, MI 48226
September 18, 1991
10. American Capital
Marketing, Inc. (formerly,
American General Capital)
2777 Allen Parkway
Houston, TX 77215
June 25, 1984
11. American Express
Financial Corp.
IDS Tower 10
Minneapolis, MN 55440
August 12, 1977
12. American Heritage Life
Ins. Co.
76 South Laura Street
Jacksonville, FL 32202
December 11, 1984
13. American Transtech,
Inc.
8000 Baymeadows Way
Jacksonville, FL 32256
August 15, 1990
14. Analytic Investment
Management
2222 Martin Street
Suite 230
Irvine, CA 92715-1454
May 9, 1989
15. Aspen Partnership1895 Claremont Road
Hoffman Estates, IL 60195
October 25, 1990
16. B.C. Ziegler & Co.215 North Main Street
West Bend, WI 53095
September 27, 1985
17. Banc One Capital
Corporation
P.O. Box 18277
90 North High Street
Columbus, OH 43218
February 24, 1992
NameAddressApproval Date
18. Bank Hapoulim B.M.6501 Wilshire Blvd.
Los Angeles, CA 90048
May 15, 1986
19. Bank Julius Baer &
Co., LTD
330 Madison Avenue
New York, NY 10017
December 15, 1988
20. Bank Leumi Le - Israel
B.N. Western Hemisphere
Regional Mgt.
242 Fifth Avenue
New York, NY 10022
February 10, 1982
21. Bartlett & Co.36 East Fourth Street
Cincinnati, OH 45202
February 1, 1989
22. Bear, Stearns & Co.,
Inc.
5 Hanover Square
New York, NY 10004
June 2, 1986
23. Bear, Sterns, Securities
Corp.
2 Broadway
12th Floor
New York, NY 10004
June 24, 1991
24. Berklee College of
Music, Inc.
1140 Boylston Street
Boston, MA 02110
May 9, 1989
25. BHC Securities, Inc.100 N. 20th Street
Suite 401
Philadelphia, PA 19103
November 15, 1984
26. Blunt Ellis & Loewi,
Inc.
225 East Mason Street
Milwaukee, WI 53202
January 25, 1982
27. BNY Clearing Services,
LLC (FKA Kemper
Clearing)
111 East Kilbourn
Milwaukee, WI 53202
August 21, 1989
28. Boettcher & Company,
Inc.
828 Seventeenth Street
Denver, CO 80201
August 10, 1987
29. Brown & Company
Securities Corporation
20 Winthrop Square
Boston, MA 02110
February 27, 1985
30. Bruns, Nordeman, Rea
& Co.
New York, NYOctober 31, 1977
31. BT Alex. Brown,
Incorporated
Bankers Trust Plaza
130 Liberty Street
New York, NY 10006
September 1, 1997
32. Burke, Christensen &
Lewis Securities, Inc.
120 S. LaSalle Street
Suite 940
Chicago, IL 60603
March 11, 1986
33. Burton J. Vincent,
Chesley & Co.
105 West Adams Street
Chicago, IL 60603
March 25, 1982
34. Butler Wick & Co.,
Inc.
City Center One Bldg.
Youngstown, OH 44501
October 8, 1992
February 25, 20025542002–8 I.R.B.

NameAddressApproval Date
35. BUYandHold Securities
Corporation
110 Wall Street
New York, NY 10005
October 5, 2000
36. Carolina Securities
Corp.
239 Fayetteville St.
Raleigh, NC 27602
August 29, 1983
37. Chapin, Davis &
Company, Inc.
3 Village Square
Cross Keys
Baltimore, MD 21210
December 7, 1983
38. Charles Schwab & Co.,
Inc.
101 Montgomery Street
San Francisco, CA 94104
January 8, 1982
39. Christian & Missionary
Alliance
P.O. Box C
Nyack, NY 10960
August 15, 1985
40. CIBC World Markets
Corporation
200 Liberty Street
New York, NY 10281
July 26, 1977
41. City Securities Corp.135 North Pennsylvania Street
Indianapolis, IN 46204
December 21, 1982
42. Commerce First ThriftMidvale, UT 84047May 25, 1978
43. Comprehensive
Investment Services, Inc.
One Moody Plaza
Galveston, TX 77550
June 16, 2000
44. Continental Trust Co.17110 Dallas Parkway
Suite 200
Dallas, TX 75248
February 22, 1977
45. D. A. Davidson & Co.Davidson Building
#8 Third Street North
Great Falls, MT 59403
June 11, 1982
46. D.J. St. Germain, Inc.1500 Main Street
Springfield, MA 01115
January 1, 1977
47. Dain Rauscher,
Incorporated
Dain Rauscher Plaza
60 South Sixth Street
Minneapolis, MN 55402-4422
March 2, 1998
48. Dain Rauscher, Inc.Dain Rauscher Plaza
60 South Sixth Street
Minneapolis, MN 55402-4422
January 22, 1982
49. Davenport & Co. of
Virginia, Inc.
901 E. Cary Street
Richmond, VA 23219
February 2, 1987
50. Davenport & Company,
LLC
901 East Cary Street
Richmond, VA 23219
March 31, 1997
51. DB Alex. Brown, LLC1 South Street
Baltimore, MD 21202
April 11, 1994
52. Deutsche Banc Alex.
Brown, Inc.
1 South Street
Baltimore, MD 21202
January 12, 2001
NameAddressApproval Date
53. Deutsche Bank
Securities Corp. d.b.a. C.J.
Lawrence Deutsche
1290 Avenue of the Americas
New York, NY 10104
March 14, 1980
54. Discover Brokerage
Direct, Inc.
333 Market Street
25th Floor
San Francisco, CA 94105-3407
June 11, 1998
55. Donaldson, Lufkin &
Jenrette Securities Corp.
140 Broadway
New York, NY 10005
December 4, 1985
56. Dougherty, Dawkins,
Strand & Yost, Inc.
100 South Fifth Street
Suite 2300
Minneapolis, MN 55402
February 22, 1986
57. Dreyfus Investment
Services, Corp.
Two Mellon Bank Center
Pittsburgh, PA 15259
May 18, 1989
58. Duncan-Williams, Inc.5860 Ridgeway Center
Parkway
Memphis, TN 38120
December 13, 1995
59. E*Trade Securities, Inc.480 California Avenue
Palo Alto, CA 94306
February 1, 1996
60. Eads Generoe TrustSt. Louis, MOFebruary 3, 1977
61. Edward D. Jones & Co.201 Progress Parkway
Maryland Height, MO 63043
May 30, 1985
62. El Paso Electric Co.P.O. Box 982
El Paso, TX 79960
June 15, 1983
63. Elan Investment
Services, Inc.
777 East Wisconsin Avenue
Milwaukee, WI 53282
December 21, 1987
64. Emmett A. Larkin Co.,
Inc.
100 Bush Street
San Francisco, CA 94104
April 17, 1986
65. Eppler, Guerin &
Turner, Inc.
2001 Bryan Tower
Suite 2300
Dallas, TX 75201
September 6, 1984
66. EVEREN Securities,
Inc.
77 West Wacker Drive
Chicago, IL 60601-1694
November 19, 1998
67. Fahnestock & Co., Inc.
(formerly Edward A. Viner
& Co.)
110 Wall Street
New York, NY 10005
April 15, 1982
68. Fechtor, Detwiler &
Co., Inc.
155 Federal Street
Boston, MA 02110
March 26, 1982
69. Ferris, Baker Watts,
Inc. (formerly Ferris &
Company)
1720 Eye Street, NW
Washington, DC 20006
December 4, 1987
70. Financial Data
Services, Inc.
400 Atrium Drive
Somerset, NJ 08873
November 14, 1990
2002–8 I.R.B.555February 25, 2002

NameAddressApproval Date
71. First Albany Corp.41 State Street
Albany, NY 12207
September 26, 1979
72. First Clearing
Corporation
10700 Wheat First Drive
Glen Allen, VA 23060
April 21, 1999
73. First Illinois Capital
Corp.
424 7th Street
Plaza 7
Rockford, IL 61110
May 27, 1982
74. First Investors Corp.120 Wall Street
New York, NY 10005
April 19, 1982
75. First Manhattan Co.437 Madison Avenue
New York, NY 10022
January 26, 1990
76. First of Michigan
Corporation
100 Renaissance Center
26th Floor
Detroit, MI 48243
August 31, 1994
77. Fleet Clearing
Corporation
67 Wall Street
New York, NY 10005
December 3, 1986
78. Fleet Norstar
Securities, Inc.
14 Wall Street
New York, NY 10005
August 30, 1991
79. Folger, Nolan, Fleming
& Douglass
725 15th Street, N.W.
Washington, DC 20015
September 16, 1981
80. Freedom Capital
Management Corporation
One Beacon Street
Boston, MA 02108
August 29, 1991
81. Freeman Welwood &
Co., Inc.
1501 Fourth Avenue
Suite 1700
Seattle, WA 98101
February 13, 1996
82. G.T. Global Investors
Services, Inc.
50 California Street
San Francisco, CA 94111
May 27, 1994
83. General Conference of
the Mennonite Brethren
Churches Board of Trustees
315 South Lincoln
Hillsboro, KS 67063
March 8, 1983
84. Goldman, Sachs & Co.85 Broad Street
New York, NY 10004
December 8, 1982
85. Greek Catholic Union
of the U.S.A.
5400 Tuscarawas Rd.
Beaver, PA 15009-9513
May 24, 2000
86. Gruntal & Co, Inc.14 Wall Street
New York, NY 10005
June 13, 1984
87. H&R Block Financial
Advisors, Inc.
735 Griswold Street
Detroit, MI 48226
December 8, 1983
88. H.G. Wellington & Co.,
Inc.
14 Wall Street
New York, NY 10005
September 13, 1993
NameAddressApproval Date
89. H.M. Payson & Co.One Portland Square
P.O. Box 31
Portland, ME 04112
August 20, 1987
90. Halpert and Company,
Inc.
284 Millburn Avenue
Millburn, NJ 07041
April 17, 1996
91. Hamilton Investments,
Inc. (formerly Illinois
Company, Inc.)
30 North La Salle Street
Chicago, IL 60602
August 6, 1982
92. Hampshire Funding,
Inc.
One Granite Place
P.O. Box 2005
Concord, NH 03301
May 26, 1988
93. Hanifen, Imhoff
Clearing Corp.
1125 17th Street
Denver, CO 80217
April 22, 1997
94. Hanifen, Imhoff, Inc.1125 17th Street
Suite 1700
Denver, CO 80202
December 3, 1985
95. Hartford Life Insurance
Co.
Hartford Plaza
Hartford, CT 06106
March 3, 1982
96. Hazlett, Burt &
Watson, Inc.
1300 Chapline Street
Wheeling, WV 26003
April 11, 1995
97. Heartland Securities,
Inc.
208 South LaSalle Street
Chicago, IL 60604
March 6, 1984
98. Henry Scott, Inc.Philadelphia, PAMarch 23, 1982
99. Herzfeld & Stern, Inc.30 Broad Street
New York, NY 10004
December 12, 1984
100. Herzog, Heine,
Geduld, Inc.
26 Broadway
New York, NY 10004
February 11, 1982
101. Holt & Collins188 Embarcadero
Suite 760
San Francisco, CA 94105
September 8, 1988
102. Home Life Financial
Assurance Corporation
2400 West Bay Drive
Largo, FL 33540
November 13, 1986
103. Howard, Weil,
Labouisse, Friedrichs, Inc.
1100 Paydrus Street
Suite 900
New Orleans, LA 70163
December 28, 1987
104. Howe Barnes
Investments, Inc.
135 S. LaSalle Street
Chicago, IL 60603
July 6, 1994
105. Huntleigh Securities
Corporation
222 South Central Avenue
St. Louis, MO 63102
October 22, 1997
106. I.M. Simon & Co.7730 Forsyth Blvd.
Clayton, MO 63105
November 3, 1981
February 25, 20025562002–8 I.R.B.

NameAddressApproval Date
107. iClearing, LLC100 Wood Avenue South
Iselin, NJ 08830
February 7, 2001
108. Investment Advisers,
Inc.
1100 Dain Tower
Minneapolis, MN 55440
October 9, 1981
109. Isler, Colling &
McAdams
Portland, OROctober 5, 1978
110. J.C. Bradford & Co.330 Commerce Street
Nashville, TN 37201
February 28, 1982
111. J.J.B. Hilliard, W.L.
Lyons, Inc.
Hilliard Lyons Center
501 South Fourth St.
Louisville, KY 40202
February 11, 1992
112. J.W. Charles Clearing
Corp.
980 North Federal Highway
Suite 210
Boca Raton, FL 33432
March 1, 1994
113. Jacob Engle
Foundation, Inc. (The)
P.O. Box 1136
Upland, CA 91786
March 25, 1983
114. Janney Montgomery
Scott, Inc.
1801 Market Street
Philadelphia, PA 19103
March 23, 1982
115. Jefferson Pilot
Investor Services, Inc.
100 North Greene Street
Greensboro, NC 27401
October 22, 1979
116. Jesup, Josephthal &
Co., Inc.
One Whitehall Street
New York, NY 10004
December 18, 1990
117. John Hancock
Clearing Corporation
200 Liberty Street
New York, NY 10281
March 21, 1991
118. John Hancock Mutual
Life Insurance Company
John Hancock Place
200 Clarendon
Boston, MA 02117
August 24, 1993
119. Juran & Moody, Inc.Minnesota Mutual Life Center
400 North Robert Street
Suite 800
Saint Paul, MN 55101
May 27, 1994
120. Kagin Numismatic
Services, Ltd.
1000 Insurance Exchange
Bldg.
Des Moines, IA 50309
March 18, 1980
121. Kirkpatrick, Pettis,
Smith Polian, Inc.
1623 Farnam Street
Suite 700
Omaha, NE 68102
August 18, 1981
122. L.F. Rothchild,
Unterberg, Towbin
55 Water Street
New York, NY 10041
December 23, 1985
123. Legg Mason Wood
Walker, Inc.
111 S. Calvert Street
P.O. Box 1476
Baltimore, MD 21203
June 4, 1985
124. Lehman Brothers, Inc.200 Vesey Street
New York, NY 10285
December 20, 2000
NameAddressApproval Date
125. Lester Sumrall
Evangelistic Association,
Inc.
530 East Ireland Road
South Bend, IN 46614
September 2, 1988
126. Liberty Life Insurance
Co.
P.O. Box 789
Greenville, SC 29602
September 3, 1982
127. Manley, Bennett,
McDonald & Co.
St. Louis, MOJanuary 1, 1977
128. McDonald &
Company Securities, Inc.
580 Walnut Street
Cincinnati, OH 45202
December 15, 1983
129. MEGA Life and
Health Insurance Company
(The)
501 West Interstate 44
Service Road
Oklahoma City, OK 73118
May 29, 1991
130. Menold, Crawford,
Hippler & Co.
23930 Michigan Ave.
Dearborn, MI 40126
December 9, 1988
131. Merrill, Lynch, Pierce,
Fenner & Smith, Inc.
One Liberty Plaza
New York, NY 10006
August 3, 1987
132. Merrimack Valley
Investment, Inc.
367 Kingsbury Ave.
Haverhill, MA 01830
September 28, 1984
133. Mesirow Financial,
Inc.
350 N. Clark Street
Chicago, IL 60610
May 28, 1982
134. Metropolitan Life
Insurance Co.
One Madison Avenue
New York, NY 10010
January 28, 1987
135. Metropolitan
Mortgage & Securities
Corporation
W. 292 Sprague Ave.
Spokane, WA 99204
November 10, 1976
136. Mid-Ohio Securities
Corp.
Spitzer Park Plaza
511 Broad St.
Elyria, OH 44035
August 8, 1989
137. Mid-States
Enterprises, Inc.
Carroll, IADecember 30, 1976
138. Miller Johnson &
Kuehn, Inc.
5500 Wayzata Blvd.
Minneapolis, MN 55416
November 15, 2000
139. Milwaukee Company
(The)
250 East Wisconsin Avenue
Milwaukee, WI 53202
September 15, 1986
140. MKI Securities Corp.61 Broadway
New York, NY 10006
April 17, 1985
141. Money Management
Associates
4922 Fairmont Avenue
Bethesda, MD 20814
May 26, 1987
142. Moore & Schley,
Cameron & Co.
Two Broadway
New York, NY 10004
November 15, 1977
2002–8 I.R.B.557February 25, 2002

NameAddressApproval Date
143. Morgan Keegan &
Company, Inc.
Morgan Keegan Tower
Fifty Front Street
Memphis, TN 38108
January 27, 1982
144. Morgan Stanley DW
Inc.
1585 Broadway
New York, NY 10036
May 29, 1986
145. Mortgage Loan
Services, Inc.
780 Lynnhaven Parkway
Suite 200
Virginia Beach, VA 23452
March 15, 1995
146. Moseley, Hallgarten,
Estabrook & Weeden, Inc.
One New York Plaza
New York, NY 10004
December 10, 1985
147. Murphy Favre, Inc.W. 601 Riverside, 9th Floor
Spokane, WA 99201
August 2, 1976
148. Mutual Service
Cooperative
Two Pine Tree Drive
Arden Hills, MN 55112
June 6, 1996
149. Myriad Corporation1400 50th Street
West Des Moines, IA 50265
July 20, 1977
150. National Bank of
Greece, S.A.
33 State Street
Boston, MA 02109
February 4, 1988
151. National Covenant
Properties
Chicago, ILJune 30, 1978
152. National Investor
Services Corp.
44 Wall Street
New York, NY 10005
March 18, 1996
153. National Life
Insurance Company
One National Life Drive
Montpelier, VT 05604
January 1, 1998
154. National Securities
Corporation
1001 Fourth Avenue
Suite 2200
Seattle, WA 98154
December 31, 1986
155. Nationwide Advisory
Services, Inc. (Nationwide
Financial Services, Inc.)
One Nationwide Plaza
Columbus, OH 43216
September 25, 1985
156. Nationwide Credit
Union
One Nationwide Plaza
Columbus, OH 43216
April 13, 1978
157. NBC Securities, Inc.1927 First Avenue North
Birmingham, AL 35203
July 16, 1996
158. Neuberger & Berman522 Fifth Ave.
New York, NY 10036
October 4, 1983
159. Newhard, Cook & Co.300 North Broadway
St. Louis, MO 63102
June 4, 1985
NameAddressApproval Date
160. Oberweis Securities,
Inc.
841 North Lake Street
Aurora, IL 60506
February 11, 1985
161. PaineWebber,
Incorporated
1285 Avenue of the Americas
New York, NY 10019
May 12, 1989
162. Parker/Hunter, Inc.600 Grant Street
Pittsburgh, PA 15219
June 15, 1990
163. Partnership Services,
Inc.
5520 LBJ Freeway
Suite 430
Dallas, TX 75240
March 31, 1993
164. Peninsular Securities
Co.
Waters Building
Grand Rapids, MI 49503
January 28, 1985
165. PENSCO Pension
Services, Inc.
250 Montgomery Street
Third Floor
San Francisco, CA 94104
June 4, 1990
166. Perelman-Carley &
Associates, Inc.
Twin Towers
3000 Farnam Street
Omaha, NE 68131
January 13, 1989
167. Perkins, Wolf,
McDonnell & Co.
53 West Jackson Boulevard
Chicago, IL 60604
December 30, 1991
168. Pflueger & Baerwald,
Inc.
Mills Building
Room 1000
220 Montgomery Street
San Francisco, CA 94104
November 9, 1981
169. PFS Investments, Inc.3120 Breckenridge Boulevard
Duluth, GA 30199
September 28, 1995
170. Pioneer Financial
Services, Inc.
4233 Roanoke Road
Kansas City, MO 64111
January 25, 1985
171. Pioneer Investment
Management USA
60 State Street
Boston, MA 02109
February 21, 1986
172. Prescott, Ball &
Turben, Inc.
1331 Euclid Ave.
Cleveland, OH 44115
January 27, 1983
173. PrimeVest Financial
Services, Inc.
400 First Street South
St. Cloud, MN 56301-3600
December 8, 1993
174. Principal Life
Insurance Company
711 High Street
Des Moines, IA 50392-0001
July 27, 1988
175. Prudential Securities,
Inc.
100 Gold Street
New York, NY 10292
July 28, 1989
176. R. Rowland & Co.,
Inc.
St. Louis, MOMarch 29, 1984
February 25, 20025582002–8 I.R.B.

NameAddressApproval Date
177. R.G. Dickinson & Co.200 Des Moines Building
405 6th Ave.
Des Moines, IA 50309
July 20, 1983
178. R.J. Steichen &
Company
Midwest Plaza
Suite 100
801 Nicolett Mall
Minneapolis, MN 55402-2526
May 21, 1993
179. Raymond James &
Associates, Inc.
880 Carillon Parkway
P.O. Box 12749
St. Petersburg, FL 33733-2749
March 8, 1982
180. Raymond James &
Associates, Inc.
880 Carrillon Parkway
P.O. Box 12749
St. Petersburg, FL 33733-2749
April 26, 1982
181. Regan MacKenzie,
Incorporated
999 Third Avenue
Suite 4300
Seattle, WA 98104
August 31, 1989
182. Regions Investment
Company, Inc.
2011 Fourth Avenue North
Birmingham, AL 35203
July 20, 2000
183. Reserve Management
Company, Inc.
810 Seventh Avenue
New York, NY 10019
October 18, 1989
184. Robert W. Baird &
Co., Inc.
777 E. Wisconsin Avenue
Milwaukee, WI 53202
July 31, 1986
185. Robinson-Humphrey
Co., Inc (The)
Two Peachtree Street, N.W.
Atlanta, GA 30383
May 24, 1982
186. Romano Bros. & Co.820 Davis Street
Evanston, IL 60201
September 28, 1984
187. Rose & Company
Investment Brokers, Inc.
141 West Jackson Blvd.
Chicago, IL 60604
April 14, 1982
188. Rotan Mosle, Inc.1500 S. Tower Pennzoil Place
P.O. Box 3226
Houston, TX 77001
May 6, 1980
189. Rushmore Investment
Brokers, Inc.
4922 Fairmont Avenue
Bethesda, MD 20814
September 24, 1986
190. Salomon Smith
Barney, Inc.
388 Greenwich St.
New York, NY 10105
July 22, 1985
191. Sanford C. Bernstein
& Co., Inc.
767 Fifth Avenue
New York, NY 10153
November 13, 1986
192. Santa Ana City
Employees Credit Union
800 West Santa Ana Blvd.
Santa Ana, CA 92701
March 25, 1982
193. Saturna Capital
Corporation
101 Prospect Street
Bellingham, WA 98227-2838
March 28, 1991
NameAddressApproval Date
194. SBC Trust Services,
Inc.
2401 Cedar Springs Road
Dallas, TX 75201-1407
April 10, 2001
195. SBCI Swiss Bank
Corporation Investment
Banking, Inc.
222 Broadway
4th Floor
New York, NY 10038
February 11, 1992
196. SBM Financial
Services, Inc.
Suite 1150
8400 Normandale Lake Blvd.
Minneapolis, MN 55437
May 13, 1995
197. Scott & Stringfellow,
Inc. (FKN Craige, Inc.)
823 E. Main Street
Richmond, VA 23219
May 5, 1999
198. Scottsdale Securities,
Inc.
12855 Flushing Meadow Drive
St. Louis, MO 63131
October 9, 1996
199. Securities
Management Research
Two Moody Plaza
Galveston, TX 77550
June 22, 1978
200. Security Management
Company (formerly,
Security Management)
700 SW Harrison Street
Topeka, KS 66636-0001
August 14, 1996
201. SG Cowen Securities
Corporation
1221 Avenue of the Americas
New York, NY 10020
June 30, 1998
202. SMA Services, Inc.35 Lakeshore Drive
Birmingham, AL 35209
August 27, 1998
203. Smith, Moore & Co.400 Locust Street
St. Louis, MO 63102
January 18, 1983
204. Southwest Securities,
Inc.
Suite 4300
Renaissance Tower
1201 Elm Street
Dallas, TX 75270
December 9, 1992
205. Spear Rees & Co.505 North Brand Boulevard
Sixteenth Floor
Glendale, CA 91203
January 13, 1988
206. Spear, Leeds &
Kellogg
120 Broadway
New York, NY 10271
March 29, 1996
207. State Bond and
Mortgage Company
8500 Normandale Lake Blvd.
Minneapolis, MN 55437
December 21, 1990
208. State Employees
Credit Union
801 Hillsborough Street
P.O. Box 26807
Raleigh, NC 27611-6807
January 1, 1977
209. State Farm Investment
Management Corporation
One State Farm Plaza
Bloomington, IL 61410
September 22, 1999
210. Stephens, Inc.111 Center Street
Little Rock, AR 72201
December 4, 1987
2002–8 I.R.B.559February 25, 2002

NameAddressApproval Date
211. Stern Brothers & Co.1100 Main Street
Suite 2200
Kansas City, MO 64199
December 15, 1987
212. Sterne, Agee & Leach,
Inc.
1500 Am South-Sonat Tower
Birmingham, AL 35203
September 11, 1981
213. Stifel, Nicolaus &
Co., Inc.
500 North Broadway
St. Louis, MO 63102
September 9, 1981
214. Summit Discount
Brokerage (FKA Lehigh
Securities Corp.)
1457 MacArthur Road
Lehigh Valley, PA 18002
April 4, 1990
215. Sun Trust Equitable
Securities
Nashville City Center
Suite 800
6th Avenue No. & Union St.
Nashville, TN 37219
May 27, 1982
216. Sunpoint Securities,
Inc.
911 W. Loop 281
Longview, TX 75604
April 1, 1998
217. Sutro & Company,
Inc.
201 California Street
San Francisco, CA 94111-5096
December 8, 1988
218. Swiss American
Securities, Inc.
100 Wall Street
New York, NY 10005
December 2, 1980
219. Texas First Securities
Corporation
1360 Post Oak Blvd.
Suite 120
Houston, TX 77056
November 17, 1988
220. Tucker Anthony,
Incorporated
One Beacon Street
Boston, MA 02108
October 23, 1980
221. U.S. Bancorp Piper
Jaffray, Inc.
800 Micollet Mall
Suite 800
Minneapolis, MN 55402-7020
April 21, 1982
222. U.S. Clearing
Corporation
120 Wall Street
New York, NY 10005
May 3, 1983
223. Unified Financial
Securities, Inc.
429 North Pennsylvania Street
Indianapolis, IN 46204
October 28, 1976
224. United of Omaha Life
Insurance
Mutual of Omaha Plaza
Omaha, NE 68175
March 16, 1982
NameAddressApproval Date
225. USAA Transfer
Agency Company of
Delaware
USAA Building
San Antonio, TX 78288
October 2, 1990
226. W.H. Reaves & Co.,
Inc.
30 Montgomery Street
Jersey City, NJ 07302
December 7, 1990
227. W.H. Turlington &
Co.
509 East Center Street
Lexington, NC 27292
November 3, 1980
228. Wachovia Securities,
Inc.
201 North Tryon Street
Charlotte, NC 28202
April 6, 1990
229. Waterhouse Securities,
Inc.
44 Wall Street
New York, NY 10005
February 23, 1988
230. Wayne Hummer &
Co.
300 South Wacker Drive
Chicago, IL 60606
January 25, 1983
231. Web Street Securities,
Inc.
222 South Riverside Plaza
11th Floor
Chicago, IL 60601
April 27, 2000
232. Wedbush Morgan
Securities
1000 Wilshire Boulevard
Los Angeles, CA 90030
December 24, 1984
233. Weiss, Peck & GreerOne New York Plaza
New York, NY 10004
June 16, 1982
234. Wells Advisors, Inc.3885 Holcomb Bridge Road
Norcross, GA 30092
March 20, 1992
235. Wexford Clearing
Services Corporation
1 New York Plaza
11th Floor
New York, NY 10292
June 30, 1998
236. Wheat, First
Securities, Inc.
707 East Main Street
P.O. Box 135
Richmond, VA 23211
March 23, 1983
237. William R. Hough &
Co., Inc.
Suite 800
100 2nd Avenue South
St. Petersburg, FL 33701
April 18, 1995
February 25, 20025602002–8 I.R.B.

Section 446—Methods of
Accounting
Announcement 2002–17
PURPOSE
This announcement reflects correc-
tions to Rev. Proc. 2002–9 (2002–3 I.R.B.
327) (Jan. 22, 2002), which provides pro-
cedures under which taxpayers may
obtain automatic consent of the Commis-
sioner to change certain methods of
accounting. Rev. Proc. 2002–9 was re-
leased by the Service on January 7, 2002,
in advance of its publication in the Inter-
nal Revenue Bulletin. Except for items 2,
6, and 8 below, the corrections described
in this announcement are already
reflected in Rev. Proc. 2002–9 as pub-
lished in the Internal Revenue Bulletin.
CORRECTIONS
1. In section 6.02(6)(b) the address to
which copies of the application must be
sent in the case of exempt organizations
is changed to:“. . . Commissioner, Tax
Exempt and Government Entities, Atten-
tion: TEGE:EO, P.O. Box 27720,
McPherson Station, Washington, D.C.
20038.”
2. Section 13.01 is changed to read as
follows:“Except as provided in sections
13.02 and 13.03 of this revenue proce-
dure, this revenue procedure is effective
for taxable years ending on or after
December 31, 2001. The Service will
return any application that is filed on or
after January 7, 2002, if the application is
filed with the national office pursuant to
the Code, regulations, or administrative
guidance other than this revenue proce-
dure and the change in method of
accounting is within the scope of this rev-
enue procedure.”
3. In section 13.02, first sentence, the
date is changed from December 31, 2001,
to January 7, 2002.
4. In the DRAFTING INFORMA-
TION paragraph, item (7) is changed to
read:“for changes in methods of account-
ing under section 4B of the APPENDIX
of this revenue procedure, Norm Paul of
the Office of the Division Counsel/
Associate Chief Counsel (Tax Exempt
and Government Entities) at (202) 622–
6060.”
5. The caption for section 4.01 of the
Appendix is changed to read:Certain uni-
form capitalization (UNICAP) methods
used by resellers and reseller-producers.
A conforming change is made to the
Table of Contents.
6. Section 4.01(1)(vi) of the Appendix
is changed to read:“a reseller changing
from a non-UNICAP method to a UNI-
CAP method specifically described in the
regulations (and making any attendant
changes in the identification of costs sub-
ject to§263A) in any taxable year, other
than the first taxable year, that it does not
qualify as a small reseller.”
7. Section 4.01(1)(c) of the Appendix
is changed to read:“This change does not
apply to a taxpayer making an historic
absorption ratio election under
§§1.263A–2(b)(4) or 1.263–3(d)(4), or to
a taxpayer that wants to revoke an elec-
tion to use the historic absorption ratio
with the simplified resale method (see
§1.263A–3(d)(4)(iii)(B)).
8. Section 4.02(1) of the Appendix is
changed to read:“Applicability. This
change applies to a producer of real or
tangible personal property described in
§1.263A–2 that wants to change to a
UNICAP method (or methods) specifi-
cally described in the regulations, and
includes any changes in the identification
of costs subject to section 263A made in
connection therewith, but does not
include a change for purposes of deter-
mining“section 471 costs”under the sim-
plified production method.”
9. In section 5.01(1)(b)(iv)(D) of the
Appendix, the first full sentence is
changed to read:“. . . the simplified pro-
duction method without the historic
absorption ratio election (§1.263A–2(b))
....”
10. Section 10.01(1)(b)(i)(A) of the
Appendix is changed to read:“. . . then
the taxpayer must use that same inventory
method for all of its non-LIFO inventory,
including the inventory that is the subject
of this accounting method change.”
EFFECT ON OTHER DOCUMENTS
Rev. Proc. 2002–9 is modified and
clarified.
Extension of Time for
Employers Required to
Furnish Forms W–2to
Household Employees
Announcement 2002–19
This announcement provides for an
extension of time for employers required
to furnish Forms W-2 (Wage and Tax
Statement) to household employees. Sec-
tion 6051 of the Internal Revenue Code
and section 31.6051–1(d)(1) of the
Employment Tax Regulations require an
employer to furnish employees a Form
W-2 reflecting wages paid and employ-
ment taxes withheld by January 31
st
of
the year subsequent to the one in which
the wages were paid. Package H (Forms
and Instructions for Household Employ-
ers), which is sent to employers of house-
hold employees, contains blank Forms
W-2 and W-3 (Transmittal of Wage and
Tax Statements). The Package H for the
2001 tax year was mailed late. Conse-
quently, the last date for furnishing
household employees their copies of
Form W-2 is extended to February 15,
2002. The date for filing Forms W-2 and
W-3 with the Social Security Administra-
tion remains February 28, 2002.
The principal author of this announce-
ment is Joseph Dewald of the Office of
Associate Chief Counsel, Procedure and
Administration (Administrative Provi-
sions and Judicial Practice Division). For
further information regarding this
announcement, you may call 202–622–
4910 (not a toll-free call).
New Markets Tax Credit;
Correction
Announcement 2002–20
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Corrections to temporary regu-
lations.
SUMMARY: This document contains
corrections to temporary regulations (T.D.
8971, 2002–3 I.R.B. 308) that was pub-
lished in theFederal Registeron Decem-
ber 26, 2001 (66 FR 66307). This docu-
ment contains temporary regulations that
2002–8 I.R.B.561February 25, 2002

provide guidance for taxpayers claiming
the new market tax credit under section
45D.
DATES: This correction is effective
December 26, 2002.
FOR FURTHER INFORMATION CON-
TACT: Paul A. Handleman (202) 622–
3040 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The temporary regulations that are the
subject of this correction are under sec-
tion 45D of Internal Revenue Code.
Need for Correction
As published, the temporary regula-
tions (T.D. 8971) contains errors that may
prove to be misleading and are in need of
clarification.
Correction of Publication
Accordingly, the publication of the
temporary regulations (T.D. 8971), which
is the subject of FR. Doc. 01–31528, is
corrected as follows:
On page 66310, column 1, under the
paragraph heading“Part 1 — Income
Taxes”, following paragraph 1, please
insert the amendatory instruction“Par.
1a.The undesignated center heading
immediately preceding§1.30–1is
revised to read as follows: Credits Allow-
able Under Section 30 through 45D”.
LaNita Van Dyke,
Acting Chief, Regulations Unit,
Associate Chief Counsel
(Income Tax and Accounting).
(Filed by the Office of the Federal Register on Feb-
ruary 1, 2002, 8:45 a.m., and published in the issue
of the Federal Register for February 4, 2002, 67 F.R.
5061)
Certain Transfers of Property
to Regulated Investment
Companies [RICs] and Real
Estate Investment Trusts
[REITs]; Correction
Announcement 2002–21
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Correction to temporary regu-
lations.
SUMMARY: This document contains
corrections to temporary regulations (T.D.
8975, 2002–4 I.R.B. 379) that were pub-
lished in theFederal Registeron
Wednesday, January 2, 2002 (67 FR 8)
relating to certain transactions or events
that result in a Regulated Investment
Company [RIC] or a Real Estate Invest-
ment Trust [REIT] owning property that
has a basis determined by reference to a
C corporation’s basis in the property
under sections 631 and 633.
DATES: This correction is effective Janu-
ary 2, 2002.
FOR FURTHER INFORMATION CON-
TACT: Lisa A. Fuller (202) 622–7750
(not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The temporary regulations that are the
subject of these corrections is under sec-
tions 631 and 633 of the Internal Revenue
Code.
Need for Correction
As published, the T.D. 8975 contain
errors that may prove to be misleading
and are in need of clarification.
Correction of Publication
Accordingly, the publication of T.D.
8975, that were the subject of FR Doc.
01–31969, is corrected as follows:
1. On page 10, column 1, in the pre-
amble under the paragraph heading“Sec-
tion 1374 Operational Rules”, first para-
graph, line 8, the language“The
comments pointed out certain”is cor-
rected to read“The commentators pointed
out certain”.
LaNita Van Dyke,
Acting Chief, Regulations Unit,
Associate Chief Counsel
(Income Tax and Accounting).
(Filed by the Office of the Federal Register on Janu-
ary 28, 2002, 8:45 a.m., and published in the issue
of the Federal Register for January 29, 2002, 67 F.R.
4177)
Dollar-Value LIFO Regulations;
Inventory Price Index
Computation Method;
Correction
Announcement 2002–22
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Corrections to final regula-
tions.
SUMMARY: This document contains
corrections to final regulations (T.D.
8976, 2002–5 I.R.B. 421) that were pub-
lished in theFederal Registeron
Wednesday, January 9, 2002 (67 FR
1075) providing guidance on methods of
valuing dollar-value LIFO pools under
section 472.
DATES: This correction is effective Janu-
ary 9, 2002.
FOR FURTHER INFORMATION CON-
TACT: Leo F. Nolan II (202) 622–4970
(not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations that are the sub-
ject of these corrections are under section
472 of the Internal Revenue Code.
Need for Correction
As published, final regulations (T.D.
8976) contain errors which may prove to
be misleading and are in need of clarifi-
cation.
Correction of Publication
Accordingly, the publication of final
regulations (T.D. 8976), which are the
subject of FR Doc. 02–184, is corrected
as follows:
February 25, 20025622002–8 I.R.B.

1. On page 1075, columns 2 and 3, in
the preamble under the paragraph heading
“Paperwork Reduction Act”, the existing
language is removed and the following
language is added in its place.
The collections of information in this
final rule have been reviewed and, pend-
ing receipt and evaluation of public com-
ments, approved by the Office of Man-
agement and Budget (OMB) under 44
U.S.C. 3507 and assigned control number
1545–1767.
The collections of information in this
regulation are in§1.472–8(e)(3)(iii)(B)
(3) and (e)(3)(iv). To elect the IPIC
method, a taxpayer must file Form 970,
“Application to Use LIFO Inventory
Method.”This information is required to
inform the Commissioner regarding the
taxpayer’s elections under the IPIC
method. This information will be used to
determine whether the taxpayer is prop-
erly accounting for its dollar-value pools
under the IPIC method. The collections of
information are required if the taxpayer
wants to obtain the tax benefits of the
LIFO method. The likely respondents are
business or other for-profit institutions,
and/or small businesses or organizations.
Comments on the collections of infor-
mation should be sent to theOffice of
Management and Budget, Attn: Desk
Officer for the Department of the Trea-
sury, Office of Information and Regula-
tory Affairs, Washington, DC 20503, with
copies to theInternal Revenue Service,
Attn: IRS Reports Clearance Officer,
W:CAR:MP:FP:S, Washington, DC
20224. Comments on the collections of
information should be received by March
20, 2002. Comments are specifically
requested concerning:
Whether the collections of information
are necessary for the proper performance
of the functions of the Internal Revenue
Service, including whether the informa-
tion will have practical utility;
The accuracy of the estimated burden
associated with the collections of infor-
mation (see below);
How the quality, utility, and clarity of
the information to be collected may be
enhanced;
How the burden of complying with the
collections of information may be mini-
mized, including through the application
of automated collection techniques or
other forms of information technology;
and,
Estimates of capital or start-up costs
and costs of operation, maintenance, and
purchase of service to provide informa-
tion.
The reporting burden contained in
§1.472.–8(e)(3)(iii)(B)(3) and (e)(3)(iv)
is reflected in the burden of Form 970.
An agency may not conduct or spon-
sor, and a person is not required to
respond to, a collection of information
unless it displays a valid control number
assigned by the Office of Management
and Budget.
Books or records relating to a collec-
tion of information must be retained as
long as their contents may become mate-
rial in the administration of any internal
revenue law. Generally, tax returns and
tax return information are confidential, as
required by 26 U.S.C. 6103.
§1.472–8 [Corrected]
2. On page 1088, column 3,§1.472–
8(e)(3)(iii)(E)(i),Example 1., line 21, the
language“items in R’s inventories fall
within the 2-digit”is corrected to read
“items in R’s inventory fall within the
2-digit.”
3. On page 1094, column 2,§1.472–
8(e)(3)(v)(B), lines 23 and 24, the lan-
guage“year as required by paragraph
(e)(3)(iv)(B)(1) of this section. Because
a”is corrected to read“year. See para-
graph (e)(3)(iv)(B)(1) of this section for
an example of this computation. Because
a.”
LaNita VanDyke,
Acting Chief, Regulations Unit,
Associate Chief Counsel
(Income Tax and Accounting).
(Filed by the Office of the Federal Register on Feb-
ruary 1, 2002, 8:45 a.m., and published in the issue
of the Federal Register for February 4, 2002, 67 F.R.
5061)
Averaging of Farm Income;
Correction
Announcement 2002–23
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Correction to final regulations.
SUMMARY: This document contains a
correction to final regulations (T.D. 8972,
2002–5 I.R.B. 443) that were published in
theFederal Registeron Tuesday, Janu-
ary 8, 2002 (67 FR 817), relating to the
election to average farm income in com-
puting tax liability.
DATES: This correction is effective Janu-
ary 8, 2002.
FOR FURTHER INFORMATION CON-
TACT: John M. Moran (202) 622–4940
(not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations that are the sub-
ject of this correction are under section
1301 of the Internal Revenue Code.
Need for Correction
As published, the final regulations
contain an error that may prove to be mis-
leading and is in need of clarification.
Correction of Publication
Accordingly, the publication of the
final regulations (T.D. 8972), that were
the subject of FR Doc. 02–183, is cor-
rected as follows:
§1–1301–1 [Corrected]
On page 821, column 1,§1.1301–1,
paragraph (d)(3)(ii),Example(ii), line 9,
the language“years 1990, 2000, and
2001. T’s 2002 tax”is corrected to read
“years 1999, 2000, and 2001. T’s 2002
tax”.
LaNita Van Dyke,
Acting Chief, Regulations Unit,
Office of Special Counsel
(Modernization and Strategic Planning).
(Filed by the Office of the Federal Register on Feb-
ruary 4, 2002, 8:45 a.m., and published in the issue
of the Federal Register for February 5, 2002, 67 F.R.
5203)
2002–8 I.R.B.563February 25, 2002

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.
February 25, 2002i2002–8 I.R.B.

Numerical Finding List
1
Bulletins 2002–1 through 2002–7
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
2002–13, 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
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
Proposed Regulations:
REG–209135–88, 2002–4 I.R.B.418
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–125450–01, 2002–5 I.R.B.457
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
2002–14, 2002–5 I.R.B.450
2002–15, 2002–6 I.R.B.490
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
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
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.
2002–8 I.R.B.iiFebruary 25, 2002

Finding List of Current Actions
on Previously Published Items
2
Bulletins 2002–1 through 2002–7
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
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
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
Revenue Procedures:—Continued
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
Revenue Rulings:—Continued
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
2002–2
Corrected by
Ann. 2002–13, 2002–7 I.R.B.540
Treasury Decisions:
8973
Corrected by
Ann. 2002–14, 2002–7 I.R.B.540
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.
February 25, 2002iii2002–8 I.R.B.