Bulletin No. 1999–20

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Bulletin No. 1999–20

May 17, 1999

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. 99–23, page 3.

Start-up expenditures, business expenses, capital expenditures. Guidance is provided on the types of expenditures that will qualify as investigatory costs that are eligible

for amortization as start-up expenditures under section 195

of the Code when a taxpayer acquires the assets of an active trade or business.

ESTATE AND GIFT TAX

T.D. 8819, page 5.

REG–103851–99, page 93.

Use of actuarial tables in valuing annuities, interests

for life or terms of years, and remainder or reversionary interests. Proposed, temporary and final regulations

under section 7520 of the Code relate to the use of actuarial tables in valuing annuities, interests for life or terms of

years, and remainder or reversionary interests.

ADMINISTRATIVE

REG–106004–98, page 77.

Proposed regulations under section 355 of the Code relate

to recognition of gain on certain distributions of stock or securities of a controlled corporation. A public hearing is

scheduled for September 21, 1999.

Finding Lists begin on page 97.

Department of the Treasury

Internal Revenue Service

Notice 99–23, page 73.

This notice effects interim revisions to Schedule P of Form

1120–FSC (1998) and its instructions, filed by foreign sales

corporations. The notice also solicits public comments by

June 30, 1999, on certain proposed revisions to Schedule P

for subsequent tax years.

Notice 99–24, page 74.

This notice informs taxpayers of the intent of Treasury and

the Service to include in final regulations a one-year extension of the time for foreign sales corporations and their related suppliers to file grouping redeterminations under the

transition rule for Temp. Treas. Reg. section 1.925(a)–

1T(c)(8)(i).

Notice 99–25, page 75.

The Service will extend the effective date of the nonresident

alien withholding regulations under section 1441 of the

Code that were published in T.D. 8734, 1997–2 C.B. 109.

As extended, those regulations will apply to certain payments made to foreign persons after December 31, 2000.

Announcement 99–53, page 95.

This document contains a correction to Notice 99–18,

1999–16 I.R.B. 4, in which the underlying calculation given

to determine the nonconventional source fuel credit amount

contained an erroneous number. However, the amount of the

credit itself was not erroneous.

Mission of the Service

and by applying the tax law with integrity and fairness to

all.

Provide America’s taxpayers top quality service by helping them understand and meet their tax responsibilities

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

Conventions, 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 Bulletins, which are sold on a single-copy basis.

dures 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.

It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application

of the tax laws, including all rulings that supersede, revoke,

modify, or amend any of those previously published in the

Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements

of internal practices and procedures that affect the rights

and duties of taxpayers are published.

Part II.—Treaties and Tax Legislation.

This part is divided into two subparts as follows: Subpart A,

Tax Conventions, and Subpart B, Legislation and Related

Committee Reports.

Part III.—Administrative, Procedural, and Miscellaneous.

To the extent practicable, pertinent cross references to

these subjects are contained in the other Parts and Subparts. Also included in this part are Bank Secrecy Act Administrative Rulings. Bank Secrecy Act Administrative Rulings

are issued by the Department of the Treasury’s Office of the

Assistant Secretary (Enforcement).

Revenue rulings represent the conclusions of the Service on

the application of the law to the pivotal facts stated in the

revenue ruling. In those based on positions taken in rulings

to taxpayers or technical advice to Service field offices,

identifying details and information of a confidential nature

are deleted to prevent unwarranted invasions of privacy and

to comply with statutory requirements.

Part IV.—Items of General Interest.

This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.

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 proce-

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.

Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

Section 162.—Trade or

Business Expenses

26 CFR 1.162–1: Business expenses.

What types of expenditures will qualify as investigatory costs that are eligible for amortization as

start-up expenditures under section 195 of the Code

when a taxpayer acquires the assets of an active

trade or business? See Rev. Rul. 99–23, on this page.

Section 195.—Start-up

Expenditures

(Also sections 162, 263; 26 CFR 1.162–1,

1.263(a)–1)

Start-up expenditures, business expenses, capital expenditures. Guidance

is provided on the types of expenditures

that will qualify as investigatory costs that

are eligible for amortization as start-up

expenditures under section 195 of the

Code when a taxpayer acquires the assets

of an active trade or business.

Rev. Rul. 99–23

ISSUE

When a taxpayer acquires the assets of

an active trade or business, which expenditures will qualify as investigatory costs

that are eligible for amortization as startup expenditures under § 195 of the Internal Revenue Code?

FACTS

Situation 1

In April 1998, corporation U hired an

investment banker to evaluate the possibility of acquiring a trade or business unrelated to U’s existing business. The investment banker conducted research on

several industries and evaluated publicly

available financial information relating to

several businesses. Eventually, U narrowed its focus to one industry. The investment banker evaluated several businesses within the industry, including

corporation V and several of V’s competitors. The investment

banker then commissioned appraisals

of V’s assets and an in-depth review of V’s

books and records in order to determine a

fair acquisition price. On November

1999–20 I.R.B.

1,1998, U entered into an acquisition

agreement with V to purchase all the assets of V. U did not prepare and submit a

letter of intent, or any other preliminary

agreement or written document evidencing an intent to acquire V prior to executing the acquisition agreement.

Situation 2

In May 1998, corporation W began

searching for a trade or business to acquire. In anticipation of finding a suitable

target to acquire, W hired an investment

banker to evaluate three potential businesses and a law firm to begin drafting

regulatory approval documents for a target. Eventually, W decided to purchase

all the assets of corporation X. W and X

entered into an acquisition agreement on

December 1, 1998.

Situation 3

In June 1998, corporation Y hired a law

firm and an accounting firm to assist in

the potential acquisition of corporation Z

by performing certain services that the

parties labeled as “preliminary due diligence.” These “due diligence” services

included conducting research on Z’s industry (including information relating to

competitors of Z), and analyzing financial

projections for Z for 1998 and 1999. In

September 1998, at Y’s request, the law

firm prepared and submitted a letter of intent to Z. The offer contained in the letter

of intent resulted from prior discussions

between Y and Z, and specifically stated

that a binding commitment with respect to

the proposed transaction would result

only upon execution of an acquisition

agreement. Thereafter, the law firm and

accounting firm continued to provide services labeled as “due diligence,” including a review of Z’s internal documents relating to insurance policies, employee

agreements, and lease agreements, an indepth review of Z’s books and records,

and preparation of an acquisition agreement. On October 10, 1998, Y entered

into an acquisition agreement with Z to

purchase all the assets of Z.

In each of the three situations, the

trades or businesses of the targets are active trades or businesses unrelated to the

trades or businesses of U, W, and Y. U,

W, and Y each use an accrual method of

accounting and a calendar taxable year.

Each of the acquisition agreements entered into by U, W, and Y were subject to

customary conditions of closing. Finally,

U, W, and Y each completed the acquisitions in 1998 and timely elected on their

1998 federal income tax returns to amortize start-up expenditures over a period of

not less than 60 months under § 195(b).

LAW AND ANALYSIS

Section 195(a) provides that, except as

otherwise provided in § 195, no deduction

is allowed for start-up expenditures.

Section 195(b) provides that start-up

expenditures may, at the election of the

taxpayer, be treated as deferred expenses

that are allowed as a deduction prorated

equally over a period of not less than 60

months (beginning with the month in

which the active trade or business begins).

Section 195(c)(1) defines “start-up expenditure,” in part, as any amount (A)

paid or incurred in connection with investigating the creation or acquisition of an

active trade or business, and (B) which, if

paid or incurred in connection with the

operation of an existing active trade or

business (in the same field as the trade or

business referred to in subparagraph (A)),

would be allowable as a deduction for the

taxable year in which paid or incurred.

Thus, in order to qualify as start-up expenditures under § 195(c)(1), a taxpayer’s

“investigatory costs” must satisfy the requirements in both §§ 195(c)(1)(A) and

(B). In addition, the term “start-up expenditure” does not include any amount with

respect to which a deduction is allowable

under §163(a), 164, or 174.

Sections 162 and 1.162–1(a) of the Income Tax Regulations allow a deduction

for all the ordinary and necessary expenses paid or incurred during the taxable

year in carrying on any trade or business.

Courts generally have construed § 162 as

containing five conditions that an expenditure must meet to qualify for deduction.

The expenditure must be (1) an expense,

(2) ordinary, (3) necessary, (4) paid or incurred during the taxable year, and (5)

made to carry on a trade or business. See

Commissioner v. Lincoln Savings and

Loan Ass’n., 403 U.S. 345 (1971).

May 17, 1999

Sections 263 and 1.263(a)–1(a) provide

that no deduction is allowed for any

amounts paid out for new buildings or for

permanent improvements or betterments

made to increase the value of any property or estate. Section 1.263(a)–2(a) provides that capital expenditures include the

cost of acquisition, construction, or erection of buildings, machinery and equipment, furniture and fixtures, and similar

property having a useful life substantially

beyond the taxable year.

Through provisions such as §§ 162(a)

and 263(a), the Code generally endeavors

to match expenses with the revenues of

the taxable period to which the expenses

are properly attributable, thereby resulting in a more accurate calculation of

net income for tax purposes. See, e.g.,

INDOPCO, Inc. v. Commissioner, 503

U.S. 79 (1992).

In describing the law prior to § 195,

Congress explained that “investigatory

expenses,” which were “costs incurred in

seeking and reviewing prospective businesses prior to reaching a decision to acquire or enter any business,” normally

were not deductible because they were

not incurred in carrying on a trade or business within the meaning of § 162. See

H.R. Rep. No. 1278, 96th Cong., 2d Sess.

9 (1980) (House Report); S. Rep. No.

1036, 96th Cong., 2d Sess 10 (1980)

(Senate Report). The “carrying on a trade

or business” requirement was not met

where investigatory expenses were incurred by a taxpayer who was not yet carrying on any trade or business, or where a

taxpayer was carrying on a trade or business but incurred costs to investigate the

creation or acquisition of another, unrelated trade or business. Id. However, a

taxpayer incurring costs to investigate the

expansion of an existing business generally could deduct those costs under § 162,

assuming the other requirements of that

section were met. This disparity in the

tax treatment of investigatory expenses

resulting from the “carrying on a trade or

business” requirement discouraged taxpayers from investigating the creation or

acquisition of new trades or businesses.

Section 195 was enacted, in part, to minimize this disparity and thereby encourage

formation of new businesses by providing

an amortization deduction for eligible investigatory expenses.

May 17, 1999

Accordingly, under § 195(c)(1)(B), expenditures described in § 195(c)(1)(A)

that are incurred before the establishment

of an active business are deemed to be

paid or incurred in the operation of an existing active trade or business (in the same

field as the business that the taxpayer is

investigating whether to create or acquire), i.e., they are deemed to satisfy the

carrying on a trade or business requirement. However, because § 195(c)(1)(B)

also requires that an expenditure described in § 195(c)(1)(A) be allowable as

a deduction for the taxable year in which

paid or incurred, the expenditure still

must meet all the other requirements of

§162. Thus, the expenditure must be an

ordinary expense under § 162, and not a

capital expenditure, to be a start-up expenditure under § 195. “Section 195 did

not create a new class of deductible expenditures for existing businesses. . . .

[I]n order to qualify under section

195(c)(1)(B), an expenditure must be one

that would have been allowable as a deduction by an existing trade or business

when it was paid or incurred.” FMR

Corp. v. Commissioner, 110 T.C. No. 30

(June 18, 1998). See also §§ 161 and 261

(deductions are allowed, subject to capitalization provisions). Whether an expenditure is an ordinary expense or is capital

in nature is a question of fact that depends

on the context in which the expenditure is

incurred. See Commissioner v. Idaho

Power Co., 418 U.S. 1 (1974); Deputy v.

duPont, 308 U.S. 488 (1940); Welch v.

Helvering, 290 U.S. 111 (1933).

The legislative history of § 195 provides the following guidance regarding

whether an expenditure is an ordinary investigatory cost that is an eligible start-up

expenditure, or a capital acquisition cost:

Eligible expenses consist of investigatory costs

incurred prior to reaching a final decision to acquire

or enter that business. These costs include expenses

incurred for the analysis or survey of potential markets, products, labor supply, transportation facilities,

etc.

Start-up expenditures eligible for amortization do

not include any amount with respect to which a deduction would not be allowed to an existing trade or

business for the taxable year in which the expenditure was paid or incurred. . . . In addition, the amortization election for start-up expenditures does not

apply to amounts paid or incurred as part of the acquisition cost of a trade or business. Also, start-up

expenditures do not include amounts paid or incurred for the acquisition of property to be held for

sale or property which may be depreciated or amortized based on its useful life. . . Whether an amount

is consideration paid to acquire a business depends

upon the facts and circumstances of the situation.

House Report at pages 10–11; Senate Report at pages 11–12.

Rev. Rul. 77–254, 1977–2 C.B. 63,

which is specifically referenced by the

legislative history of § 195 (House Report

at 9, Senate Report at 10), considers

which costs incurred in the potential acquisition of a new business are capital acquisition costs for purposes of §§ 165 and

263. That ruling provides that expenses

incurred in the course of a general search

for, or an investigation of, a business that

relate to the decisions whether to purchase a business and which business to

purchase are investigatory costs. However, once a taxpayer has focused on the

acquisition of a specific business, expenses that are related to an attempt to acquire that business are capital in nature.

Thus, the “final decision” referred to in

the legislative history of § 195 is the point

at which a taxpayer makes its decision

whether to acquire a business, and which

business to acquire, rather than the point

at which a taxpayer and seller are legally

obligated to complete the transaction.

Courts have long held that legal, brokerage, accounting, appraisal, and similar

costs incurred to acquire a capital asset

are capital expenditures under § 263.

Woodward v. Commissioner, 397 U.S. 572

(1970) (when property is acquired by purchase, nothing is more clearly a part of

the process of acquisition than the establishment of a purchase price); United

States v. Hilton Hotels Corp., 397 U.S.

580 (1970); Beneficial Industrial Loan

Corp. v. Handy, 16 F. Supp. 110, 112 (D.

Del. 1936), aff ’d, 92 F.2d 74 (3d Cir.

1937); Rev. Rul. 73–580, 1973–2 C.B. 86.

For example, in Ellis Banking Corp. v.

Commissioner, T.C. Memo. 1981–123,

aff ’d in part & rem’d in part, 688 F.2d

1376 (11th Cir. 1982), the taxpayer incurred expenses for office supplies, filing

fees, travel, and accounting services in

connection with its examination of target’s books and records. The examination

was performed pursuant to an acquisition

agreement for the purchase of target’s

stock that was contingent on several terms

and conditions, such as regulatory approval. The Tax Court concluded that the

1999–20 I.R.B.

expenses were nondeductible capital expenditures incurred in the acquisition of a

capital asset. The Court of Appeals for

the Eleventh Circuit substantially affirmed, noting that the requirement that

costs be capitalized extends beyond the

price payable to include any costs incurred by the buyer in connection with the

purchase, such as appraisals of the property or the costs of meeting any conditions of sale.

Accordingly, expenditures incurred in

the course of a general search for, or an

investigation of, an active trade or business, i.e., expenditures paid or incurred in

order to determine whether to enter a new

business and which new business to enter

(other than costs incurred to acquire capital assets that are used in the search or investigation), are investigatory costs that

are start-up expenditures under § 195. Alternatively, costs incurred in the attempt

to acquire a specific business are capital

in nature and thus, are not start-up expenditures under § 195. The nature of the

cost must be analyzed based on all the

facts and circumstances of the transaction

to determine whether it is an investigatory

cost incurred to facilitate the whether and

which decisions, or an acquisition cost incurred to facilitate consummation of the

acquisition. The label that the parties use

to describe the cost and the point in time

at which the cost is incurred do not necessarily determine the nature of the cost.

In Situation 1, an examination of the

nature of the costs incurred indicates that

U made its decision to acquire V after the

investment banker conducted research on

several industries and evaluated publicly

available financial information. The costs

incurred to conduct industry research and

review public financial information are

typical of the costs related to a general investigation. Accordingly, the costs incurred to conduct industry research and to

evaluate publicly available financial information are investigatory costs eligible

for amortization as start-up expenditures

under § 195. However, the costs relating

to the appraisals of V’s assets and an indepth review of V’s books and records to

establish the purchase price facilitate consummation of the acquisition, and thus,

are capital acquisition costs. The costs incurred to evaluate V and V’s competitors

also may be investigatory costs, but only

1999–20 I.R.B.

to the extent they were incurred to assist

U in determining whether to acquire a

business and which business to acquire.

If the evaluation of V and V’s competitors

occurred after U had made its decision to

acquire V (for example, in an effort to establish the purchase price for V), such

evaluation costs are capital acquisition

costs.

In Situation 2, the costs incurred to

evaluate potential businesses are investigatory costs eligible for amortization as

start-up expenditures under § 195 to the

extent they relate to the whether and

which decisions. However, the costs incurred to draft regulatory approval documents prior to the time W decided to acquire X are not start-up expenditures under

§ 195. The costs related to such activities,

even if the activities occurred during the

period W is engaged in a general search

for a business, were not incurred in order

to investigate whether to acquire a business and which business to acquire, but

rather to facilitate an acquisition.

In Situation 3, an examination of the

nature of the costs incurred by Y indicates

that Y made its decision to acquire Z in

September 1998, around the time that Y

instructed the law firm to prepare and

submit the letter of intent. The costs related to the “preliminary due diligence”

services provided prior to that time (including the costs of conducting research

on Z’s industry and in reviewing financial

projections of Z) are typical of the costs

incurred during an investigation to determine whether to acquire a new business

and which new business to acquire. Thus,

these costs are investigatory costs that are

eligible for amortization as start-up expenditures under § 195. The costs related

to “due diligence” services provided after

that time, however, relate to the attempt to

acquire the business and must be capitalized under § 263 as acquisition costs.

Thus, the “due diligence” costs incurred

to review T’s internal documents, books

and records, and to draft the acquisition

agreements are not eligible for amortization under § 195.

HOLDING

Expenditures incurred in the course of

a general search for, or investigation of,

an active trade or business in order to determine whether to enter a new business

and which new business to enter (other

than costs incurred to acquire capital assets that are used in the search or investigation) qualify as investigatory costs that

are eligible for amortization as start-up

expenditures under § 195. However, expenditures incurred in the attempt to acquire a specific business do not qualify as

start-up expenditures because they are acquisition costs under § 263. The nature of

the cost must be analyzed based on all the

facts and circumstances of the transaction

to determine whether it is an investigatory

cost incurred to facilitate the whether and

which decisions, or an acquisition cost incurred to facilitate consummation of an

acquisition.

DRAFTING INFORMATION

The principal author of this revenue

ruling is Susie K. Bird of the Office of

Assistant Chief Counsel (Income Tax and

Accounting). For further information regarding this revenue ruling contact Ms.

Bird on (202) 622-4950 (not a toll-free

call).

Section 7520.—Valuation Tables

26 CFR 20.7520–1: Valuation of annuities, unitrust

interests, interests for life or term of years, and

remainder or reversionary interests.

T.D. 8819

DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Parts 1, 20, and 25

Use of Actuarial Tables in

Valuing Annuities, Interests for

Life or Terms of Years, and

Remainder or Reversionary

Interests

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Final and temporary regulations.

SUMMARY: This document contains

regulations relating to the use of actuarial

tables in valuing annuities, interests for

life or terms of years, and remainder or

reversionary interests. These regulations

are necessary because section 7520(c)(3)

directs the Secretary to update the actuar-

May 17, 1999

ial tables to reflect the most recent mortality experience available. These regulations will effect the valuation of inter

vivos and testamentary transfers of interests dependent on one or more measuring

lives. The text of the temporary regulations also serves as the text of the proposed regulations REG–103851–99, page

93 in this Bulletin.

DATES: These regulations are effective

May 1, 1999.

FOR FURTHER INFORMATION CONTACT: Concerning the regulations,

William L. Blodgett, (202) 622-3090 (not

a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

This document contains amendments to

the regulations revising certain tables

used for the valuation of partial interests

in property under section 7520 of the Internal Revenue Code of 1986 (Code) to

reflect the most recent mortality experience available.

In General

Section 7520, effective for transfers for

which the valuation date is after April 30,

1989, provides that the value of an annuity, an interest for life or a term of years,

and a remainder or reversionary interest is

to be determined under tables published

by the Internal Revenue Service based on

a discount rate (rounded to the nearest

two-tenths of one percent) equal to 120

percent of the applicable Federal mid-term

rate in effect under section 1274(d)(1) for

the month in which the valuation date

falls. Section 7520(c)(3) directed the Secretary to issue tables not later than December 31, 1989, utilizing the then most recent

mortality experience. Thereafter, the Secretary is directed to revise the tables used

in valuing interests dependent on mortality

experience not less frequently than once

each 10 years to take into account the

most recent mortality experience available

as of the time of the revision.

These regulations incorporate revised

Table S (Single Life Remainder Factors)

and Table U(1) (Unitrust Single Life Remainder Factors) based on data compiled

from the 1990 census as set forth in Life

Table 90CM, and make conforming

amendments to various sections to reflect

the revised tables. The current tables are

moved to sections containing actuarial

material for historical reference. Table B,

Table D, Tables F(4.2) through F(14.0),

Table J, and Table K, which are not based

on mortality experience, are not changed.

Internal Revenue Service Publications

1457 “Actuarial Values, Book Aleph”

(forthcoming 1999), 1458 “Actuarial Values, Book Beth” (forthcoming 1999), and

1459 “Actuarial Values, Book Gimel”

(forthcoming 1999) will contain a complete set of actuarial tables that include

factors not contained in the regulations

(for example, annuity and life interest factors). Although not available on May 1,

1999, IRS anticipates these publications

will be available by July 1, 1999. These

publications will be available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402.

The following chart summarizes the applicable interest rates and the citations to

textual materials and tables for the various

periods covered under the regulations:

Cross Reference to Regulation Sections

Valuation

Period

Interest

Rate

Regulation

Section

Table

Section 642:

Valuation, in general

before 01/01/52

01/01/52 – 12/31/70

01/01/71 – 11/30/83

12/01/83 – 04/30/89

05/01/89 – 04/30/99

after 04/30/99

—

3.5%

10%

§7520

1.642(c)–6

1.642(c)–6A(a)

1.642(c)–6A(b)

1.642(c)–6A(c)

1.642(c)–6A(d)

1.642(c)–6A(e)

1.642(c)–6T(e)

Table G

Table S (5/1/89 – 4/30/99)

Table S (after 04/30/99)

Section 664:

Valuation, in general

before 01/01/52

01/01/52 – 12/31/70

01/01/71 – 11/30/83

12/01/83 – 04/30/89

05/01/89 – 04/30/99

after 04/30/99

—

3.5%

10%

§7520

1.664–4

1.664–4A(a)

1.664–4A(b)

1.664–4A(c)

1.664–4A(d)

1.664–4A(e)

1.664–4T(e)

1.664–4(e)

Section 2031:

Valuation, in general

before 01/01/52

01/01/52 – 12/31/70

01/01/71 – 11/30/83

—

3.5%

20.2031–7

20.2031–7A(a)

20.2031–7A(b)

20.2031–7A(c)

May 17, 1999

Table E, Table F(1)

Table U(1) (5/1/89 – 4/30/99)

Table U(1) (after 04/30/99)

Table D and

Tables F(4.2) – F(14.0)

1999–20 I.R.B.

Cross Reference to Regulation Sections (Continued)

Valuation

Period

Interest

Rate

Regulation

Section

12/01/83 – 04/30/89

05/01/89 – 04/30/99

10%

§7520

20.2031–7A(d)

20.2031–7A(e)

after 04/30/99

§7520

20.2031–7T(d)

Table

20.2031–7(d)

Section 2512:

Valuation, in general

before 01/01/52

01/01/52 – 12/31/70

01/01/71 – 11/30/83

12/01/83 – 04/30/89

05/01/89 – 04/30/99

after 04/30/99

Effective Dates

These regulations are applicable in the

case of annuities, interests for life or

terms of years, and remainder or reversionary interests created after April 30,

1999.

Transitional Rules

The regulations provide certain transitional rules intended to alleviate any adverse consequences resulting from the

proposed regulatory change. For gift tax

purposes, if the valuation date of a transfer is after April 30, 1999, but before July

1, 1999, the donor may determine the

value of the gift (and/or any applicable

charitable deduction) under tables based

on either Life Table 80CNSMT or Table

90CM (at the donor’s option). Similarly,

for estate tax purposes, if the decedent

dies after April 30, 1999, but before July

1, 1999, the value of any interest (and/or

any applicable charitable deduction) may

be determined under tables based on either Table 80CNSMT or Table 90CM, at

the option of the decedent’s executor.

However, the section 7520 interest rate

utilized is the appropriate rate for the

month in which the valuation date occurs.

In accordance with this transitional rule

and those contained in §§1.7520–2(a)(2),

20.7520–2(a)(2) and 25.7520–2(a)(2), in

cases involving a charitable deduction, if

the valuation date occurs after April 30,

1999, and before July 1, 1999, and the executor or donor elects under section

7520(a) to use the section 7520 interest

rate for March 1999 or April 1999, then

1999–20 I.R.B.

Table A, Table B, Table LN

Table S (5/1/89 – 4/30/99)

Life Table 80CNSMT

Table S (after 04/30/99) and

Life Table 90CM

Table B, Table J, Table K,

25.2512–5

25.2512–5A(a)

25.2512–5A(b)

25.2512–5A(c)

25.2512–5A(d)

25.2512–5A(e)

25.2512–5T(d)

3.5%

10%

§7520

the mortality experience contained in

80CNSMT must be used. If the executor

or donor uses the section 7520 interest

rate for May 1999 or for June 1999, then

the tables based on either Table

80CNSMT or Table 90CM may be used.

However, if the valuation date occurs

after June 30, 1999, the executor or donor

must use the new mortality experience

contained in Table 90CM even if a prior

month interest rate election under section

7520(a) is made.

In addition, for estate tax purposes, the

estate of a mentally incompetent decedent

may elect to value the property interest included in the gross estate under the mortality table and interest rate in effect at the

time the decedent became mentally incompetent or the mortality table and interest rate in effect on the decedent’s date of

death if the decedent was under a mental

incapacity that existed on May 1, 1999,

and continued uninterrupted until the

decedent’s death, or the decedent died

within 90 days of regaining competency

after April 30, 1999.

entities, the Regulatory Flexibility Act (5

U.S.C. chapter 6) does not apply. Therefore, a Regulatory Flexibility Analysis is

not required. Pursuant to section 7805(f)

of the Internal Revenue Code, these regulations will be submitted to the Chief

Counsel for Advocacy of the Small Business Administration for comment on its

impact on small business.

Special Analysis

Paragraph 1. The authority citation for

part 1 is amended by adding entries in

numerical order to read in part as follows:

Authority: 26 U.S.C. 7805 * * *

Section 1.170A–12 also issued under 26

U.S.C. 170(f)(4). * * *

Section 1.642(c)–6 also issued under 26

U.S.C. 642(c)(5).

Section 1.642(c)–6T also issued under 26

U.S.C. 642(c)(5).

Section 1.642(c)–6A also issued under 26

U.S.C. 642(c)(5).

It has been determined that this Treasury decision is not a significant regulatory action as defined in EO 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) does not

apply to these regulations, and because

these regulations do not impose a collection of information requirement on small

Drafting Information

The principal author of these regulations

is William L. Blodgett, Office of Assistant

Chief Counsel (Passthroughs and Special

Industries), IRS. However, other personnel from the IRS and Treasury Department

participated in their development.

* * * * *

Adoption of Amendments to the

Regulations

Accordingly, 26 CFR parts 1, 20, and

25 are amended as follows:

PART 1—INCOME TAXES

May 17, 1999

Section 1.664–1 also issued under 26

U.S.C. 664(a).

Section 1.664–2 also issued under 26

U.S.C. 664(a).

Section 1.664–3 also issued under 26

U.S.C. 664(a).

Section 1.664–4 also issued under 26

U.S.C. 664(a).

Section 1.664–4T also issued under 26

U.S.C. 664(a).

Section 1.664–4A also issued under 26

U.S.C. 664(a). * * *

Section 1.7520–1T also issued under 26

U.S.C. 7520(c)(2). * * *

Par. 2. Section 1.170A–6 is amended

by revising paragraph (c)(5), Example

(2)(b) introductory text to read as follows:

§1.170A–6 Charitable contributions in

trust.

* * * * *

(5) * * *

Example 2. * * *

(b) The section 7520 rate at the time of

Where:

n = the estimated number of years of useful life,

i = the applicable interest rate under section 7520

of the Internal Revenue Code,

v = 1 divided by the sum of 1 plus the applicable

interest rate under section 7520 of the Internal

Revenue Code,

x = the age of the life tenant, and

lx = number of persons living at age x as set forth

in Table 90CM of §20.2031–7T (or, for prior

periods, the tables set forth under §20.2031–

7A) of this chapter.

(3) The following example illustrates the provisions of this paragraph (b):

Example. A, who is 62, donates to Y University a

remainder interest in a personal residence, consisting of a house and land, subject to a reserved life estate in A. At the time of the gift, the land has a value

of $30,000 and the house has a value of $100,000

with an estimated useful life of 45 years, at the end

of which the value of the house is expected to be

$20,000. The portion of the property considered to

be depreciable is $80,000 (the value of the house

($100,000) less its expected value at the end of 45

years ($20,000)). The portion of the property considered to be nondepreciable is $50,000 (the value of

the land at the time of the gift ($30,000) plus the expected value of the house at the end of 45 years

($20,000)). At the time of the gift, the interest rate

prescribed under section 7520 is 8.4 percent. Based

on an interest rate of 8.4 percent, the remainder fac-

May 17, 1999

(a) through (b)(1) [Reserved] For further guidance see §1.170A–12(a) through

(b)(1).

(b)(2) Computation of depreciation

factor after April 30, 1999. If the valuation of the remainder interest in depreciable property is dependent upon the continuation of one life, a special factor must be

used. The factor determined under this

paragraph (b)(2) is carried to the fifth decimal place. The special factor is to be

computed on the basis of the interest rate

and life contingencies prescribed in

§20.2031–7T (or for certain prior periods,

§20.2031–7A) of this chapter (Estate Tax

Regulations) and on the assumption that

the property depreciates on a straight-line

basis over its estimated useful life. For

transfers for which the valuation date is

after April 30, 1999, special factors for

determining the present value of a remainder interest following one life and an

example describing the computation is

contained in Internal Revenue Service

Publication 1459, “Actuarial Values,

Book Gimel,” (1999). A copy of this publication is available for purchase from the

Superintendent of Documents, United

States Government Printing Office,

Washington, DC 20402. See, however,

§1.7520–3(b) (relating to exceptions to

the use of prescribed tables under certain

circumstances). Otherwise, in the case of

the valuation of a remainder interest following one life, the special factor may be

obtained through use of the following

formula:

tor for $1.00 prescribed in §20.2031–7T(d) of this

chapter for a person age 62 is 0.27925. The value of

the nondepreciable remainder interest is $13,962.50

(0.27925 times $50,000). The value of the depreciable remainder interest is $16,148.80 (0.20186, computed under the formula described in paragraph

(b)(2) of this section, times $80,000). Therefore, the

value of the remainder interest is $30,111.30.

(d) and (e) [Reserved]. For further

guidance, see §1.642(c)–6T(d) and (e).

(f) Effective dates. This section applies

after April 30, 1989, and before May 1,

1999.

Par. 5. Section 1.642(c)–6T is added to

read as follows:

guidance see §1.170A–12(c) through (e).

Par. 4. Section 1.642(c)–6 is amended

as follows:

1. Revise the section heading.

2. Paragraph (d) is removed.

3. Paragraph (e) is redesignated as

paragraph (e) of §1.642(c)–6A.

4. New paragraphs (d) and (e) are

added.

5. Paragraph (f) is revised.

The revisions and addition read as follows:

§1.642(c)–6T Valuation of a remainder

interest in property transferred to a

pooled income fund (temporary).

the transfer was 6.0 percent. By reference

to Table F(6.0) in §1.664–4(e)(6), the adjusted payout rate is 4.717% (5% ⫻

0.943396). The present value of the reversion is $6,473.75, computed by reference to Table D in §1.664–4(e)(6), as follows:

* * * * *

Par. 3. Section 1.170A–12T is added to

read as follows:

§1.170A–12T Valuation of a remainder

interest in real property for contributions

made after July 31, 1969 (temporary).

§1.642(c)–6 Valuation of a remainder

interest in property transferred to a

pooled income fund.

(a) through (c) [Reserved]. For further

guidance, see §1.642(c)–6(a) through (c).

(d) Valuation. The present value of the

remainder interest in property transferred

to a pooled income fund after April 30,

1999, is determined under paragraph (e)

of this section. The present value of the

remainder interest in property transferred

to a pooled income fund for which the

valuation date is before May 1, 1999, is

determined under the following sections:

* * * * *

1999–20 I.R.B.

Valuation Dates

After

Before

—

12-31-51

2-31-70

11-30-83

04-30-89

01-01-52

01-01-71

2-01-83

05-01-89

05-01-99

Applicable

Regulations

1.642(c)–6A(a)

1.642(c)-6A(b)

1.642(c)–6A(c)

1.642(c)–6A(d)

1.642(c)–6A(e)

(e) Present value of the remainder interest in the case of transfers to pooled income funds for which the valuation date is

after April 30, 1999—(1) In general. In

the case of transfers to pooled income

funds for which the valuation date is after

April 30, 1999, the present value of a remainder interest is determined under this

section. See, however, §1.7520–3(b) (relating to exceptions to the use of prescribed tables under certain circumstances). The present value of a

remainder interest that is dependent on

the termination of the life of one individual is computed by the use of Table S in

paragraph (e)(6) of this section. For purposes of the computations under this section, the age of an individual is the age at

the individual’s nearest birthday.

(2) Transitional rules for valuation of

transfers to pooled income funds. (i) For

purposes of sections 2055, 2106, or 2624,

if on May 1, 1999, the decedent was mentally incompetent so that the disposition

of the property could not be changed, and

the decedent died after April 30, 1999,

without having regained competency to

dispose of the decedent’s property, or the

decedent died within 90 days of the date

that the decedent first regained competency after April 30, 1999, the present

value of a remainder interest is determined as if the valuation date with respect

to the decedent’s gross estate is either before May 1, 1999, or after April 30, 1999,

at the option of the decedent’s executor.

(ii) For purposes of sections 170, 2055,

2106, 2522, or 2624, in the case of transfers to a pooled income fund for which

the valuation date is after April 30, 1999,

and before July 1, 1999, the present value

of the remainder interest under this section is determined by use of the section

7520 interest rate for the month in which

the valuation date occurs (See §§1.75201(b) and 1.7520–2(a)(2)) and the appropriate actuarial tables under either paragraph (e)(6) of this section or

§1.642(c)–6A(e)(5), at the option of the

1999–20 I.R.B.

donor or the decedent’s executor, as the

case may be.

(iii) For purposes of paragraphs (e)(2)(i)

and (ii) of this section, where the donor or

decedent’s executor is given the option to

use the appropriate actuarial tables under

either paragraph (e)(6) of this section or

§1.642(c)–6A(e)(5), the donor or decedent’s executor must use the same actuarial table with respect to each individual

transaction and with respect to all transfers

occurring on the valuation date (e.g., gift

and income tax charitable deductions with

respect to the same transfer must be determined based on the same tables, and all

assets includible in the gross estate and/or

estate tax deductions claimed must be valued based on the same tables).

(3) Present value of a remainder interest. The present value of a remainder interest in property transferred to a pooled

income fund is computed on the basis

of—

(i) Life contingencies determined from

the values of lx that are set forth in Table

90CM in §20.2031–7T(d)(7) of this chapter (Estate Tax Regulations) (See

§ 20.2031–7A of this chapter for certain

prior periods); and

(ii) Discount at a rate of interest, compounded annually, equal to the highest

yearly rate of return of the pooled income

fund for the 3 taxable years immediately

preceding its taxable year in which the

transfer of property to the fund is made.

For purposes of this paragraph (e), the

yearly rate of return of a pooled income

fund is determined as provided in

§1.642(c)–6(c) unless the highest rate of

return is deemed to be the rate described

in paragraph (e)(4) of this section for

funds in existence less than 3 taxable

years. For purposes of this paragraph

(e)(3)(ii), the first taxable year of a pooled

income fund is considered a taxable year

even though the taxable year consists of

less than 12 months. However, appropriate adjustments must be made to annualize the rate of return earned by the fund

for that period. Where it appears from the

facts and circumstances that the highest

yearly rate of return of the fund for the 3

taxable years immediately preceding the

taxable year in which the transfer of property is made has been purposely manipulated to be substantially less than the rate

of return that would otherwise be reasonably anticipated with the purpose of ob-

taining an excessive charitable deduction,

that rate of return may not be used. In

that case, the highest yearly rate of return

of the fund is determined by treating the

fund as a pooled income fund that has

been in existence for less than 3 preceding

taxable years.

(4) Pooled income funds in existence

less than 3 taxable years. If a pooled income fund has been in existence less than

3 taxable years immediately preceding the

taxable year in which the transfer is made

to the fund and the transfer to the fund is

made after April 30, 1989, the highest rate

of return is deemed to be the interest rate

(rounded to the nearest two-tenths of one

percent) that is 1 percent less than the

highest annual average of the monthly

section 7520 rates for the 3 calendar years

immediately preceding the calendar year

in which the transfer to the pooled income

fund is made. The deemed rate of return

for transfers to new pooled income funds

is recomputed each calendar year using

the monthly section 7520 rates for the 3year period immediately preceding the

calendar year in which each transfer to the

fund is made until the fund has been in existence for 3 taxable years and can compute its highest rate of return for the 3 taxable years immediately preceding the

taxable year in which the transfer of property to the fund is made in accordance

with the rules set forth in the first sentence

of paragraph (e)(3)(ii) of this section.

(5) Computation of value of remainder

interest. The factor that is used in determining the present value of a remainder

interest that is dependent on the termination of the life of one individual is the factor from Table S in paragraph (e)(6) of

this section under the appropriate yearly

rate of return opposite the number that

corresponds to the age of the individual

upon whose life the value of the remainder interest is based (See §1.642(c)–6A

for certain prior periods). The tables in

paragraph (e)(6) of this section include

factors for yearly rates of return from 4.2

to 14 percent. Many actuarial factors not

contained in the tables in paragraph (e)(6)

of this section is contained in Table S in

Internal Revenue Service Publication

1457, “Actuarial Values, Book Aleph,”

(1999). A copy of this publication is

available for purchase from the Superintendent of Documents, United States

Government Printing Office, Washington,

May 17, 1999

DC 20402. For other situations, see

§1.642(c)-6(b). If the yearly rate of return

is a percentage that is between the yearly

rates of return for which factors are provided, a linear interpolation must be

made. The present value of the remainder

interest is determined by multiplying the

fair market value of the property on the

valuation date by the appropriate remainder factor. This paragraph (e)(5) may be

illustrated by the following example:

tains a life income interest in the property. The

highest yearly rate of return earned by the fund for

its 3 preceding taxable years is 9.47 percent. In

Table S, the remainder factor opposite 55 years

under 9.4 percent is .17449 and under 9.6 percent is

.17001. The present value of the remainder interest

is $17,292.00, computed as follows:

Factor at 9.4 percent for age 55 . . . . . . . .17449

Factor at 9.6 percent for age 55 . . . . . . . .17001

Difference . . . . . . . . . . . . . . . . . . . . . . . .00448

Interpolation adjustment:

9.47% – 9.4%

0.2%

Example. A, who is 54 years and 8 months,

transfers $100,000 to a pooled income fund, and re-

.00448

.00157

Factor at 9.4 percent for age 55 . . . . . . . .17449

Less: Interpolation adjustment . . . . . . . .00157

Interpolated factor . . . . . . . . . . . . . . . . . .17292

Present value of remainder interest:

($100,000 3 .17292) . . . . . . . . . . . . $17,292.00

(6) Actuarial tables. In the case of

transfers for which the valuation date is

after April 30, 1999, the present value of a

remainder interest dependent on the termination of one life in the case of a transfer to a pooled income fund is determined

by use of the following Table S:

TABLE S

BASED ON LIFE TABLE 90CM

SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE

4.2%

4.4%

4.6%

4.8%

5.0%

5.2%

5.4%

5.6%

5.8%

6.0%

.06752

.06137

.06325

.06545

.06784

.06130

.05495

.05667

.05869

.06092

.05586

.04932

.05088

.05275

.05482

.05109

.04438

.04580

.04752

.04944

.04691

.04003

.04132

.04291

.04469

.04322

.03620

.03737

.03883

.04048

.03998

.03283

.03388

.03523

.03676

.03711

.02985

.03079

.03203

.03346

.03458

.02721

.02806

.02920

.03052

.03233

.02487

.02563

.02668

.02791

.07040

.07310

.07594

.07891

.08203

.06331

.06583

.06849

.07129

.07423

.05705

.05941

.06191

.06453

.06731

.05152

.05372

.05607

.05853

.06115

.04662

.04869

.05089

.05321

.05567

.04229

.04422

.04628

.04846

.05079

.03845

.04025

.04219

.04424

.04643

.03503

.03672

.03854

.04046

.04253

.03199

.03357

.03528

.03709

.03904

.02928

.03076

.03236

.03407

.03592

.08532

.08875

.09233

.09601

.09974

.07734

.08059

.08398

.08748

.09102

.07024

.07331

.07653

.07985

.08322

.06392

.06683

.06989

.07304

.07624

.05829

.06104

.06394

.06693

.06997

.05326

.05587

.05862

.06146

.06435

.04877

.05124

.05385

.05655

.05929

.04474

.04709

.04957

.05214

.05474

.04114

.04336

.04572

.04816

.05064

.03790

.04002

.04226

.04458

.04694

.10350

.10728

.11108

.11494

.11889

.09460

.09818

.10179

.10545

.10921

.08661

.09001

.09344

.09691

.10047

.07946

.08268

.08592

.08921

.09259

.07303

.07608

.07916

.08227

.08548

.06725

.07014

.07306

.07601

.07904

.06204

.06479

.06755

.07034

.07322

.05735

.05996

.06257

.06521

.06794

.05312

.05559

.05807

.06057

.06315

.04930

.05164

.05399

.05636

.05880

.12298

.12722

.13159

.13613

.14084

.11310

.11713

.12130

.12563

.13014

.10417

.10801

.11199

.11612

.12043

.09610

.09976

.10354

.10748

.11160

.08881

.09228

.09588

.09964

.10357

.08220

.08550

.08893

.09250

.09625

.07622

.07935

.08260

.08601

.08958

.07078

.07375

.07685

.08009

.08349

.06584

.06866

.07160

.07468

.07793

.06135

.06403

.06682

.06975

.07284

.14574

.15084

.15615

.16166

.16737

.13484

.13974

.14485

.15016

.15567

.12493

.12963

.13454

.13965

.14497

.11591

.12041

.12513

.13004

.13516

.10768

.11199

.11652

.12124

.12617

.10018

.10431

.10865

.11319

.11792

.09334

.09728

.10144

.10580

.11035

.08708

.09085

.09484

.09901

.10339

.08135

.08496

.08878

.09279

.09699

.07611

.07956

.08322

.08706

.09109

May 17, 1999

1999–20 I.R.B.

TABLE S

BASED ON LIFE TABLE 90CM

SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE

4.2%

4.4%

4.6%

4.8%

5.0%

5.2%

5.4%

5.6%

5.8%

6.0%

.17328

.17938

.18568

.19220

.19894

.16138

.16728

.17339

.17972

.18627

.15048

.15618

.16210

.16824

.17460

.14047

.14599

.15171

.15766

.16383

.13129

.13661

.14214

.14790

.15388

.12286

.12799

.13333

.13889

.14468

.11510

.12004

.12520

.13058

.13618

.10796

.11272

.11769

.12289

.12831

.10138

.10597

.11076

.11578

.12102

.09532

.09974

.10435

.10920

.11426

.20592

.21312

.22057

.22827

.23623

.19307

.20010

.20737

.21490

.22270

.18121

.18805

.19514

.20251

.21013

.17025

.17691

.18382

.19100

.19845

.16011

.16658

.17331

.18031

.18759

.15073

.15701

.16356

.17038

.17747

.14204

.14814

.15450

.16113

.16805

.13399

.13990

.14608

.15253

.15927

.12652

.13225

.13825

.14452

.15108

.11958

.12514

.13096

.13705

.14344

.24446

.25298

.26178

.27087

.28025

.23078

.23915

.24782

.25678

.26603

.21805

.22626

.23478

.24360

.25273

.20620

.21425

.22262

.23129

.24027

.19516

.20305

.21125

.21977

.22860

.18487

.19259

.20062

.20898

.21766

.17527

.18282

.19069

.19888

.20740

.16631

.17368

.18138

.18941

.19777

.15795

.16514

.17267

.18053

.18873

.15013

.15715

.16450

.17220

.18023

.28987

.29976

.30987

.32023

.33082

.27555

.28533

.29535

.30563

.31615

.26212

.27179

.28171

.29190

.30234

.24953

.25908

.26889

.27897

.28931

.23772

.24714

.25682

.26678

.27702

.22664

.23591

.24546

.25530

.26543

.21622

.22536

.23476

.24447

.25447

.20644

.21542

.22468

.23425

.24412

.19724

.20606

.21518

.22460

.23434

.18858

.19725

.20621

.21549

.22509

.34166

.35274

.36402

.37550

.38717

.32694

.33798

.34924

.36070

.37237

.31306

.32404

.33525

.34668

.35833

.29995

.31085

.32200

.33339

.34500

.28756

.29838

.30946

.32078

.33234

.27586

.28658

.29757

.30882

.32031

.26479

.27541

.28630

.29746

.30888

.25432

.26482

.27561

.28667

.29801

.24441

.25479

.26547

.27643

.28766

.23502

.24528

.25584

.26669

.27782

.39903

.41108

.42330

.43566

.44811

.38424

.39631

.40857

.42098

.43351

.37019

.38227

.39455

.40699

.41956

.35683

.36890

.38118

.39364

.40623

.34413

.35617

.36844

.38089

.39350

.33205

.34405

.35629

.36873

.38133

.32056

.33250

.34469

.35710

.36968

.30961

.32149

.33363

.34600

.35855

.29918

.31099

.32306

.33538

.34789

.28925

.30097

.31297

.32522

.33768

.46066

.47330

.48608

.49898

.51200

.44613

.45887

.47175

.48478

.49793

.43224

.44505

.45802

.47115

.48442

.41896

.43182

.44485

.45807

.47143

.40624

.41914

.43223

.44550

.45895

.39408

.40699

.42011

.43343

.44694

.38243

.39535

.40848

.42184

.43539

.37127

.38418

.39732

.41069

.42427

.36058

.37347

.38660

.39997

.41357

.35033

.36318

.37629

.38966

.40326

.52512

.53835

.55174

.56524

.57882

.59242

.51121

.52461

.53818

.55188

.56568

.57951

.49782

.51137

.52511

.53899

.55299

.56703

.48495

.49862

.51250

.52654

.54071

.55495

.47255

.48634

.50034

.51452

.52885

.54325

.46062

.47449

.48860

.50291

.51737

.53193

.44912

.46307

.47727

.49168

.50627

.52096

.43805

.45206

.46633

.48083

.49552

.51034

.42738

.44143

.45576

.47034

.48513

.50004

.41709

.43118

.44556

.46020

.47506

.49007

1999–20 I.R.B.

May 17, 1999

TABLE S

BASED ON LIFE TABLE 90CM

SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE

4.2%

4.4%

4.6%

4.8%

5.0%

5.2%

5.4%

5.6%

5.8%

6.0%

.60598

.61948

.63287

.64621

.59332

.60707

.62073

.63435

.58106

.59504

.60895

.62282

.56918

.58338

.59751

.61162

.55767

.57206

.58640

.60073

.54651

.56108

.57561

.59015

.53569

.55043

.56513

.57985

.52520

.54009

.55495

.56984

.51503

.53004

.54505

.56009

.50516

.52029

.53543

.55061

.65953

.67287

.68622

.69954

.71278

.64796

.66160

.67526

.68892

.70250

.63671

.65063

.66459

.67856

.69246

.62575

.63995

.65419

.66845

.68265

.61510

.62954

.64404

.65858

.67308

.60473

.61940

.63415

.64895

.66372

.59463

.60952

.62450

.63955

.65457

.58480

.59989

.61509

.63036

.64563

.57523

.59050

.60590

.62140

.63690

.56591

.58135

.59694

.61264

.62836

.72581

.73857

.75101

.76311

.77497

.71588

.72899

.74178

.75423

.76645

.70618

.71962

.73274

.74553

.75809

.69668

.71045

.72389

.73700

.74988

.68740

.70147

.71522

.72864

.74183

.67833

.69268

.70672

.72044

.73393

.66945

.68408

.69840

.71240

.72618

.66077

.67566

.69024

.70451

.71857

.65227

.66741

.68225

.69678

.71110

.64396

.65933

.67441

.68919

.70377

.78665

.79805

.80904

.81962

.82978

.77848

.79025

.80159

.81251

.82302

.77047

.78258

.79427

.80552

.81636

.76260

.77504

.78706

.79865

.80980

.75487

.76764

.77998

.79188

.80335

.74728

.76036

.77301

.78521

.79699

.73982

.75320

.76615

.77865

.79072

.73250

.74617

.75940

.77220

.78455

.72530

.73925

.75277

.76584

.77847

.71823

.73245

.74624

.75958

.77248

.83952

.84870

.85716

.86494

.87216

.83309

.84260

.85136

.85942

.86690

.82676

.83658

.84563

.85396

.86170

.82052

.83064

.83998

.84858

.85657

.81437

.82479

.83441

.84326

.85149

.80831

.81902

.82891

.83801

.84648

.80234

.81332

.82348

.83283

.84153

.79645

.80771

.81812

.82771

.83664

.79064

.80217

.81283

.82266

.83181

.78492

.79671

.80761

.81767

.82704

.87898

.88537

.89127

.89680

.90217

.87397

.88060

.88672

.89245

.89803

.86902

.87587

.88221

.88815

.89393

.86412

.87121

.87775

.88389

.88987

.85928

.86659

.87335

.87968

.88585

.85450

.86203

.86898

.87551

.88187

.84977

.85751

.86467

.87138

.87793

.84510

.85305

.86040

.86730

.87402

.84049

.84864

.85618

.86326

.87016

.83592

.84427

.85200

.85926

.86633

100

101

102

103

104

.90738

.91250

.91751

.92247

.92775

.90344

.90876

.91396

.91912

.92460

.89953

.90504

.91045

.91579

.92148

.89567

.90137

.90696

.91249

.91839

.89183

.89772

.90350

.90922

.91532

.88804

.89412

.90007

.90598

.91227

.88428

.89054

.89668

.90276

.90924

.88056

.88699

.89331

.89957

.90624

.87687

.88348

.88997

.89640

.90326

.87322

.88000

.88666

.89326

.90031

105

106

107

108

109

.93290

.93948

.94739

.95950

.97985

.92996

.93680

.94504

.95767

.97893

.92704

.93415

.94271

.95585

.97801

.92415

.93151

.94039

.95404

.97710

.92127

.92889

.93808

.95224

.97619

.91841

.92628

.93579

.95045

.97529

.91558

.92370

.93351

.94867

.97438

.91276

.92113

.93124

.94689

.97348

.90997

.91857

.92899

.94512

.97259

.90719

.91604

.92675

.94336

.97170

May 17, 1999

1999–20 I.R.B.

TABLE S

BASED ON LIFE TABLE 90CM

SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE

6.2%

6.4%

6.6%

6.8%

7.0%

7.2%

7.4%

7.6%

7.8%

8.0%

.03034

.02279

.02347

.02444

.02558

.02857

.02094

.02155

.02243

.02349

.02700

.01929

.01983

.02065

.02163

.02559

.01782

.01829

.01905

.01996

.02433

.01650

.01692

.01761

.01846

.02321

.01533

.01569

.01632

.01712

.02220

.01427

.01458

.01516

.01590

.02129

.01331

.01358

.01412

.01481

.02047

.01246

.01268

.01317

.01382

.01973

.01168

.01187

.01232

.01292

.02686

.02825

.02976

.03137

.03311

.02469

.02600

.02742

.02894

.03059

.02275

.02398

.02532

.02675

.02832

.02101

.02217

.02343

.02479

.02627

.01945

.02053

.02172

.02301

.02442

.01804

.01906

.02019

.02140

.02274

.01677

.01773

.01880

.01995

.02122

.01562

.01653

.01754

.01864

.01985

.01458

.01544

.01640

.01744

.01859

.01364

.01445

.01536

.01635

.01745

.03499

.03700

.03913

.04135

.04359

.03237

.03428

.03632

.03843

.04057

.03001

.03183

.03377

.03579

.03783

.02788

.02961

.03146

.03339

.03534

.02595

.02760

.02937

.03122

.03308

.02420

.02578

.02748

.02924

.03102

.02262

.02413

.02575

.02744

.02915

.02118

.02262

.02418

.02580

.02744

.01987

.02125

.02275

.02431

.02587

.01867

.02000

.02144

.02294

.02444

.04584

.04806

.05029

.05253

.05484

.04270

.04482

.04692

.04905

.05124

.03986

.04187

.04387

.04588

.04796

.03728

.03919

.04108

.04299

.04496

.03493

.03674

.03855

.04036

.04222

.03279

.03452

.03623

.03795

.03972

.03083

.03248

.03411

.03574

.03742

.02905

.03063

.03218

.03373

.03532

.02742

.02892

.03040

.03187

.03339

.02593

.02736

.02877

.03017

.03161

.05726

.05980

.06246

.06524

.06819

.05354

.05595

.05847

.06112

.06392

.05013

.05242

.05482

.05734

.06001

.04702

.04920

.05147

.05387

.05642

.04418

.04625

.04841

.05069

.05312

.04158

.04354

.04559

.04777

.05008

.03919

.04105

.04301

.04508

.04728

.03700

.03877

.04063

.04260

.04470

.03498

.03667

.03844

.04032

.04232

.03313

.03473

.03642

.03821

.04012

.07131

.07460

.07810

.08179

.08566

.06690

.07005

.07340

.07693

.08065

.06285

.06586

.06907

.07246

.07603

.05913

.06200

.06508

.06833

.07176

.05570

.05845

.06140

.06451

.06780

.05255

.05518

.05800

.06098

.06414

.04964

.05215

.05485

.05772

.06075

.04695

.04936

.05195

.05469

.05761

.04447

.04677

.04925

.05189

.05469

.04218

.04438

.04676

.04929

.05198

.08973

.09398

.09843

.10310

.10799

.08456

.08865

.09294

.09745

.10217

.07978

.08372

.08785

.09220

.09676

.07536

.07915

.08313

.08732

.09173

.07127

.07491

.07875

.08279

.08705

.06748

.07098

.07468

.07858

.08269

.06396

.06733

.07089

.07466

.07862

.06069

.06394

.06737

.07100

.07483

.05766

.06078

.06409

.06759

.07129

.05483

.05785

.06103

.06441

.06798

.11314

.11852

.12416

.13009

.13629

.10715

.11236

.11783

.12359

.12962

.10157

.10662

.11193

.11751

.12338

.09638

.10127

.10641

.11183

.11753

.09155

.09628

.10126

.10652

.11206

.08704

.09162

.09645

.10155

.10693

.08283

.08726

.09194

.09689

.10212

.07890

.08319

.08772

.09253

.09761

.07522

.07938

.08377

.08843

.09337

.07179

.07581

.08006

.08459

.08938

1999–20 I.R.B.

May 17, 1999

TABLE S

BASED ON LIFE TABLE 90CM

SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE

6.2%

6.4%

6.6%

6.8%

7.0%

7.2%

7.4%

7.6%

7.8%

8.0%

.14281

.14966

.15685

.16437

.17224

.13597

.14264

.14966

.15702

.16472

.12955

.13606

.14291

.15010

.15764

.12355

.12989

.13657

.14360

.15098

.11791

.12409

.13061

.13747

.14469

.11262

.11864

.12500

.13171

.13876

.10766

.11352

.11972

.12627

.13317

.10299

.10870

.11475

.12115

.12789

.09860

.10417

.11006

.11631

.12290

.09447

.09989

.10564

.11174

.11819

.18042

.18893

.19775

.20688

.21633

.17274

.18110

.18975

.19873

.20804

.16550

.17370

.18220

.19102

.20018

.15867

.16671

.17505

.18373

.19274

.15223

.16011

.16830

.17682

.18568

.14615

.15387

.16190

.17027

.17898

.14040

.14796

.15584

.16406

.17262

.13496

.14238

.15010

.15817

.16658

.12982

.13708

.14466

.15258

.16084

.12496

.13207

.13950

.14727

.15539

.22612

.23625

.24669

.25742

.26845

.21769

.22769

.23799

.24861

.25952

.20969

.21955

.22973

.24022

.25101

.20210

.21182

.22186

.23222

.24290

.19490

.20448

.21438

.22461

.23516

.18805

.19749

.20726

.21735

.22777

.18155

.19084

.20047

.21043

.22072

.17536

.18452

.19400

.20383

.21399

.16948

.17849

.18784

.19753

.20756

.16388

.17275

.18196

.19151

.20140

.27978

.29140

.30333

.31551

.32790

.27074

.28227

.29411

.30621

.31854

.26212

.27355

.28529

.29731

.30956

.25389

.26522

.27686

.28878

.30095

.24604

.25725

.26879

.28061

.29269

.23853

.24963

.26106

.27278

.28477

.23136

.24233

.25365

.26528

.27716

.22450

.23535

.24656

.25807

.26986

.21793

.22867

.23976

.25116

.26284

.21166

.22227

.23324

.24453

.25610

.34050

.35331

.36639

.37974

.39334

.33107

.34384

.35688

.37020

.38378

.32202

.33473

.34772

.36101

.37456

.31334

.32598

.33892

.35216

.36568

.30500

.31757

.33044

.34363

.35711

.29699

.30948

.32229

.33542

.34884

.28929

.30170

.31443

.32750

.34087

.28190

.29422

.30687

.31986

.33317

.27478

.28701

.29958

.31250

.32574

.26794

.28007

.29255

.30539

.31857

.40718

.42128

.43569

.45038

.46531

.48040

.39761

.41172

.42616

.44089

.45587

.47103

.38838

.40249

.41694

.43170

.44672

.46194

.37947

.39357

.40803

.42281

.43786

.45312

.37087

.38496

.39941

.41419

.42927

.44456

.36257

.37663

.39107

.40585

.42094

.43626

.35455

.36858

.38299

.39777

.41286

.42820

.34681

.36079

.37518

.38994

.40503

.42038

.33932

.35326

.36761

.38235

.39743

.41278

.33208

.34597

.36028

.37499

.39006

.40540

.49558

.51082

.52607

.54139

.48629

.50162

.51697

.53241

.47727

.49268

.50813

.52367

.46851

.48399

.49952

.51515

.46000

.47554

.49114

.50686

.45174

.46733

.48299

.49879

.44371

.45934

.47506

.49092

.43591

.45157

.46733

.48325

.42832

.44401

.45981

.47578

.42095

.43666

.45249

.46849

.55683

.57243

.58819

.60408

.62001

.54798

.56373

.57965

.59572

.61184

.53936

.55524

.57132

.58755

.60385

.53095

.54696

.56318

.57957

.59604

.52276

.53888

.55523

.57177

.58840

.51477

.53100

.54747

.56414

.58092

.50698

.52330

.53988

.55668

.57360

.49938

.51579

.53247

.54939

.56644

.49197

.50846

.52523

.54225

.55943

.48474

.50130

.51815

.53527

.55256

May 17, 1999

1999–20 I.R.B.

TABLE S

BASED ON LIFE TABLE 90CM

SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE

6.2%

6.4%

6.6%

6.8%

7.0%

7.2%

7.4%

7.6%

7.8%

8.0%

.63582

.65142

.66673

.68175

.69657

.62786

.64367

.65920

.67444

.68950

.62007

.63608

.65182

.66728

.68256

.61244

.62864

.64458

.66024

.67574

.60497

.62135

.63748

.65334

.66904

.59765

.61421

.63052

.64656

.66246

.59048

.60721

.62368

.63991

.65599

.58347

.60034

.61698

.63338

.64964

.57659

.59361

.61041

.62696

.64340

.56985

.58701

.60395

.62066

.63727

.71128

.72576

.73981

.75342

.76658

.70446

.71919

.73349

.74735

.76076

.69775

.71272

.72726

.74137

.75503

.69116

.70636

.72114

.73548

.74938

.68467

.70010

.71511

.72968

.74381

.67830

.69394

.70917

.72396

.73832

.67204

.68789

.70333

.71833

.73290

.66587

.68193

.69757

.71279

.72757

.65982

.67606

.69190

.70732

.72231

.65386

.67029

.68632

.70194

.71712

.77928

.79131

.80246

.81274

.82232

.77371

.78600

.79737

.80788

.81766

.76823

.78075

.79235

.80307

.81306

.76281

.77557

.78740

.79832

.80850

.75748

.77046

.78250

.79363

.80401

.75221

.76542

.77767

.78899

.79956

.74702

.76044

.77290

.78441

.79517

.74190

.75553

.76818

.77989

.79082

.73684

.75068

.76353

.77542

.78653

.73186

.74589

.75893

.77100

.78228

.83141

.83996

.84787

.85530

.86255

.82695

.83569

.84378

.85138

.85880

.82254

.83147

.83973

.84750

.85508

.81818

.82729

.83573

.84366

.85140

.81387

.82316

.83176

.83985

.84776

.80961

.81907

.82784

.83609

.84415

.80539

.81503

.82396

.83236

.84057

.80122

.81103

.82012

.82867

.83703

.79710

.80707

.81632

.82502

.83353

.79302

.80315

.81255

.82140

.83005

100

101

102

103

104

.86960

.87655

.88338

.89015

.89737

.86601

.87313

.88012

.88706

.89446

.86246

.86974

.87689

.88399

.89157

.85894

.86638

.87369

.88095

.88871

.85546

.86305

.87052

.87793

.88586

.85200

.85975

.86738

.87494

.88304

.84858

.85648

.86426

.87197

.88024

.84519

.85324

.86116

.86903

.87745

.84183

.85003

.85809

.86611

.87469

.83849

.84684

.85505

.86321

.87195

105

106

107

108

109

.90443

.91351

.92452

.94161

.97081

.90170

.91101

.92230

.93987

.96992

.89898

.90852

.92010

.93814

.96904

.89628

.90605

.91791

.93641

.96816

.89360

.90359

.91573

.93469

.96729

.89094

.90115

.91356

.93298

.96642

.88830

.89873

.91141

.93128

.96555

.88568

.89632

.90927

.92958

.96468

.88307

.89392

.90714

.92790

.96382

.88049

.89154

.90502

.92622

.96296

1999–20 I.R.B.

May 17, 1999

TABLE S

BASED ON LIFE TABLE 90CM

SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE

8.2%

8.4%

8.6%

8.8%

9.0%

9.2%

9.4%

9.6%

9.8%

10.0%

.01906

.01098

.01113

.01155

.01211

.01845

.01034

.01046

.01084

.01137

.01790

.00977

.00986

.01020

.01069

.01740

.00924

.00930

.00962

.01008

.01694

.00876

.00880

.00909

.00952

.01652

.00833

.00834

.00860

.00900

.01613

.00793

.00791

.00816

.00853

.01578

.00756

.00753

.00775

.00810

.01546

.00722

.00717

.00737

.00770

.01516

.00691

.00684

.00702

.00733

.01279

.01356

.01442

.01536

.01641

.01201

.01274

.01356

.01446

.01546

.01130

.01199

.01277

.01363

.01460

.01065

.01131

.01205

.01287

.01380

.01006

.01068

.01140

.01218

.01307

.00952

.01011

.01079

.01154

.01240

.00902

.00959

.01023

.01096

.01178

.00856

.00910

.00972

.01041

.01120

.00814

.00865

.00925

.00991

.01068

.00775

.00824

.00881

.00945

.01019

.01758

.01886

.02024

.02168

.02313

.01659

.01781

.01915

.02054

.02193

.01567

.01686

.01814

.01948

.02083

.01484

.01598

.01721

.01851

.01981

.01407

.01517

.01636

.01762

.01887

.01336

.01442

.01558

.01679

.01801

.01270

.01373

.01485

.01603

.01721

.01210

.01310

.01419

.01533

.01646

.01154

.01251

.01357

.01467

.01578

.01103

.01196

.01299

.01407

.01514

.02456

.02593

.02728

.02861

.02998

.02330

.02462

.02590

.02717

.02847

.02214

.02340

.02463

.02584

.02708

.02107

.02229

.02346

.02462

.02580

.02009

.02126

.02238

.02348

.02461

.01918

.02030

.02138

.02243

.02351

.01834

.01942

.02046

.02146

.02249

.01756

.01860

.01960

.02056

.02154

.01684

.01785

.01880

.01972

.02066

.01617

.01714

.01806

.01894

.01984

.03142

.03295

.03455

.03626

.03809

.02984

.03130

.03283

.03446

.03620

.02839

.02978

.03124

.03279

.03446

.02704

.02837

.02976

.03124

.03283

.02580

.02706

.02839

.02981

.03133

.02465

.02585

.02712

.02847

.02993

.02357

.02473

.02594

.02723

.02863

.02258

.02368

.02484

.02608

.02741

.02165

.02271

.02382

.02500

.02628

.02079

.02180

.02286

.02400

.02522

.04005

.04216

.04444

.04687

.04946

.03808

.04010

.04229

.04463

.04712

.03625

.03819

.04029

.04254

.04493

.03456

.03641

.03843

.04059

.04289

.03298

.03476

.03670

.03877

.04099

.03151

.03322

.03508

.03708

.03922

.03014

.03178

.03357

.03550

.03756

.02887

.03044

.03217

.03402

.03600

.02768

.02919

.03085

.03263

.03455

.02656

.02802

.02962

.03133

.03318

.05221

.05511

.05818

.06144

.06489

.04976

.05255

.05551

.05866

.06200

.04748

.05017

.05302

.05606

.05928

.04534

.04794

.05069

.05363

.05674

.04335

.04585

.04851

.05135

.05436

.04149

.04390

.04647

.04921

.05212

.03975

.04208

.04455

.04720

.05002

.03812

.04037

.04276

.04532

.04805

.03659

.03876

.04107

.04355

.04619

.03515

.03725

.03948

.04188

.04444

.06857

.07246

.07659

.08098

.08563

.06555

.06932

.07332

.07758

.08210

.06273

.06638

.07025

.07439

.07878

.06007

.06361

.06737

.07138

.07565

.05758

.06101

.06466

.06855

.07270

.05524

.05856

.06210

.06588

.06992

.05304

.05626

.05969

.06336

.06729

.05097

.05409

.05742

.06099

.06480

.04902

.05205

.05528

.05874

.06245

.04718

.05012

.05325

.05662

.06023

May 17, 1999

1999–20 I.R.B.

TABLE S

BASED ON LIFE TABLE 90CM

SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE

8.2%

8.4%

8.6%

8.8%

9.0%

9.2%

9.4%

9.6%

9.8%

10.0%

.09059

.09586

.10147

.10742

.11373

.08692

.09206

.09753

.10334

.10950

.08347

.08848

.09381

.09948

.10551

.08021

.08509

.09029

.09583

.10172

.07714

.08189

.08696

.09237

.09813

.07423

.07886

.08381

.08909

.09472

.07149

.07600

.08083

.08598

.09148

.06889

.07329

.07800

.08304

.08841

.06643

.07072

.07531

.08024

.08549

.06411

.06828

.07277

.07758

.08272

.12035

.12732

.13460

.14223

.15020

.11599

.12281

.12995

.13743

.14526

.11185

.11853

.12553

.13287

.14056

.10792

.11447

.12133

.12853

.13608

.10420

.11061

.11733

.12439

.13181

.10066

.10694

.11353

.12046

.12774

.09730

.10345

.10991

.11671

.12385

.09410

.10013

.10646

.11313

.12015

.09106

.09696

.10317

.10972

.11661

.08817

.09395

.10004

.10646

.11322

.15855

.16727

.17634

.18576

.19552

.15347

.16205

.17098

.18027

.18990

.14862

.15707

.16587

.17501

.18451

.14401

.15232

.16097

.16999

.17935

.13960

.14777

.15630

.16518

.17441

.13540

.14344

.15183

.16057

.16968

.13138

.13929

.14755

.15616

.16514

.12754

.13532

.14345

.15194

.16078

.12388

.13153

.13953

.14789

.15661

.12037

.12789

.13577

.14400

.15260

.20564

.21613

.22698

.23816

.24962

.19989

.21025

.22098

.23204

.24339

.19437

.20461

.21522

.22616

.23740

.18908

.19919

.20968

.22051

.23163

.18402

.19400

.20436

.21507

.22608

.17915

.18901

.19925

.20984

.22073

.17449

.18422

.19434

.20481

.21558

.17001

.17962

.18961

.19996

.21062

.16571

.17519

.18507

.19530

.20584

.16157

.17093

.18069

.19080

.20123

.26136

.27339

.28578

.29854

.31164

.25502

.26695

.27925

.29192

.30494

.24892

.26075

.27295

.28553

.29846

.24304

.25477

.26687

.27935

.29221

.23738

.24900

.26100

.27339

.28615

.23192

.24343

.25533

.26762

.28030

.22666

.23806

.24985

.26205

.27463

.22158

.23288

.24456

.25666

.26915

.21669

.22787

.23945

.25145

.26384

.21196

.22304

.23451

.24641

.25870

.32508

.33891

.35318

.36785

.38290

.39823

.31831

.33208

.34630

.36093

.37595

.39127

.31177

.32547

.33963

.35422

.36920

.38450

.30543

.31906

.33316

.34770

.36265

.37791

.29930

.31285

.32689

.34138

.35628

.37151

.29336

.30684

.32081

.33524

.35009

.36529

.28761

.30101

.31491

.32928

.34408

.35924

.28203

.29536

.30918

.32349

.33824

.35335

.27663

.28987

.30363

.31787

.33256

.34762

.27140

.28456

.29823

.31240

.32703

.34204

.41378

.42950

.44535

.46139

.40681

.42253

.43840

.45446

.40003

.41575

.43162

.44771

.39343

.40914

.42502

.44112

.38701

.40271

.41858

.43469

.38076

.39644

.41231

.42842

.37467

.39034

.40619

.42230

.36875

.38438

.40022

.41632

.36298

.37858

.39440

.41049

.35736

.37293

.38872

.40479

.47769

.49430

.51123

.52845

.54584

.47080

.48747

.50447

.52177

.53926

.46408

.48079

.49786

.51523

.53282

.45752

.47427

.49139

.50884

.52650

.45111

.46790

.48506

.50257

.52032

.44485

.46167

.47888

.49645

.51426

.43874

.45558

.47282

.49044

.50833

.43277

.44963

.46690

.48457

.50251

.42693

.44380

.46111

.47881

.49681

.42123

.43811

.45543

.47317

.49122

1999–20 I.R.B.

May 17, 1999

TABLE S

BASED ON LIFE TABLE 90CM

SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE

8.2%

8.4%

8.6%

8.8%

9.0%

9.2%

9.4%

9.6%

9.8%

10.0%

.56325

.58054

.59762

.61448

.63124

.55678

.57419

.59140

.60840

.62531

.55044

.56797

.58530

.60243

.61949

.54423

.56186

.57931

.59657

.61376

.53813

.55587

.57343

.59081

.60813

.53216

.54999

.56766

.58515

.60259

.52630

.54422

.56198

.57958

.59715

.52056

.53856

.55641

.57411

.59179

.51492

.53300

.55094

.56874

.58652

.50939

.52754

.54557

.56346

.58134

.64800

.66461

.68083

.69663

.71201

.64224

.65902

.67541

.69140

.70696

.63657

.65351

.67008

.68624

.70199

.63099

.64810

.66483

.68116

.69708

.62550

.64276

.65965

.67615

.69224

.62010

.63751

.65455

.67121

.68747

.61478

.63233

.64953

.66634

.68276

.60955

.62724

.64458

.66154

.67811

.60441

.62222

.63970

.65680

.67353

.59934

.61728

.63489

.65213

.66900

.72694

.74117

.75439

.76664

.77809

.72209

.73650

.74991

.76233

.77394

.71730

.73190

.74548

.75806

.76983

.71257

.72735

.74110

.75385

.76578

.70791

.72286

.73678

.74969

.76177

.70330

.71842

.73251

.74557

.75780

.69876

.71404

.72829

.74150

.75388

.69427

.70972

.72412

.73748

.75000

.68984

.70545

.72000

.73350

.74616

.68547

.70123

.71593

.72957

.74237

.78899

.79928

.80883

.81781

.82661

.78500

.79544

.80514

.81427

.82320

.78106

.79165

.80149

.81075

.81982

.77715

.78790

.79787

.80727

.81648

.77329

.78418

.79430

.80382

.81316

.76947

.78050

.79075

.80041

.80988

.76569

.77686

.78725

.79703

.80662

.76195

.77326

.78377

.79368

.80340

.75826

.76970

.78033

.79036

.80020

.75460

.76617

.77693

.78708

.79704

100

101

102

103

104

.83519

.84368

.85203

.86034

.86923

.83192

.84055

.84904

.85748

.86653

.82868

.83744

.84607

.85465

.86385

.82547

.83437

.84313

.85184

.86119

.82228

.83131

.84021

.84906

.85855

.81913

.82829

.83731

.84629

.85593

.81600

.82529

.83444

.84355

.85333

.81290

.82231

.83159

.84082

.85074

.80982

.81936

.82876

.83812

.84818

.80678

.81643

.82596

.83544

.84563

105

106

107

108

109

.87792

.88918

.90291

.92455

.96211

.87537

.88683

.90082

.92288

.96125

.87283

.88450

.89873

.92123

.96041

.87032

.88218

.89666

.91958

.95956

.86782

.87987

.89460

.91794

.95872

.86534

.87758

.89255

.91630

.95788

.86287

.87530

.89051

.91468

.95704

.86042

.87304

.88849

.91306

.95620

.85799

.87079

.88647

.91145

.95537

.85557

.86855

.88447

.90984

.95455

May 17, 1999

1999–20 I.R.B.

TABLE S

BASED ON LIFE TABLE 90CM

SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE

10.2%

10.4%

10.6%

10.8%

11.0%

11.2%

11.4%

11.6%

11.8%

12.0%

.01488

.00662

.00654

.00670

.00699

.01463

.00636

.00626

.00641

.00668

.01439

.00612

.00600

.00613

.00639

.01417

.00589

.00576

.00588

.00612

.01396

.00568

.00554

.00564

.00587

.01377

.00548

.00533

.00542

.00563

.01359

.00530

.00514

.00522

.00542

.01343

.00513

.00496

.00502

.00521

.01327

.00497

.00479

.00484

.00502

.01312

.00482

.00463

.00468

.00484

.00739

.00786

.00841

.00902

.00973

.00706

.00751

.00803

.00863

.00931

.00675

.00718

.00769

.00826

.00892

.00646

.00687

.00736

.00791

.00856

.00620

.00659

.00706

.00759

.00822

.00595

.00633

.00678

.00730

.00790

.00571

.00608

.00652

.00702

.00760

.00550

.00585

.00627

.00675

.00733

.00529

.00563

.00604

.00651

.00706

.00510

.00543

.00582

.00628

.00682

.01055

.01146

.01246

.01351

.01455

.01010

.01099

.01196

.01298

.01400

.00969

.01055

.01150

.01249

.01348

.00930

.01014

.01106

.01204

.01300

.00894

.00976

.01066

.01161

.01255

.00861

.00940

.01028

.01121

.01213

.00829

.00907

.00993

.01084

.01173

.00799

.00875

.00960

.01049

.01136

.00772

.00846

.00928

.01016

.01102

.00746

.00818

.00899

.00985

.01069

.01555

.01648

.01737

.01822

.01908

.01497

.01587

.01673

.01754

.01837

.01443

.01530

.01612

.01691

.01770

.01392

.01477

.01556

.01632

.01708

.01345

.01427

.01504

.01576

.01650

.01300

.01380

.01455

.01525

.01595

.01259

.01336

.01408

.01476

.01544

.01220

.01295

.01365

.01430

.01495

.01183

.01257

.01324

.01387

.01450

.01148

.01220

.01286

.01347

.01407

.01999

.02096

.02197

.02306

.02424

.01924

.02017

.02114

.02218

.02331

.01854

.01943

.02036

.02136

.02245

.01788

.01874

.01963

.02059

.02163

.01726

.01809

.01895

.01987

.02087

.01669

.01748

.01830

.01919

.02016

.01615

.01691

.01770

.01855

.01948

.01564

.01637

.01713

.01795

.01885

.01516

.01586

.01660

.01739

.01825

.01471

.01539

.01610

.01686

.01769

.02552

.02692

.02846

.03012

.03190

.02455

.02589

.02738

.02898

.03070

.02364

.02493

.02636

.02791

.02957

.02278

.02403

.02541

.02690

.02851

.02197

.02318

.02451

.02595

.02751

.02122

.02238

.02367

.02506

.02656

.02051

.02162

.02287

.02422

.02567

.01984

.02091

.02212

.02342

.02483

.01920

.02025

.02141

.02267

.02404

.01861

.01961

.02074

.02196

.02329

.03381

.03583

.03799

.04031

.04279

.03254

.03450

.03659

.03883

.04123

.03135

.03324

.03527

.03744

.03976

.03023

.03206

.03402

.03612

.03838

.02917

.03094

.03284

.03488

.03707

.02817

.02989

.03173

.03371

.03583

.02723

.02890

.03068

.03260

.03465

.02634

.02796

.02968

.03155

.03354

.02551

.02707

.02874

.03055

.03249

.02471

.02623

.02785

.02961

.03149

.04545

.04830

.05134

.05462

.05812

.04382

.04658

.04953

.05272

.05613

.04227

.04495

.04782

.05092

.05424

.04081

.04341

.04620

.04921

.05245

.03943

.04196

.04467

.04760

.05075

.03812

.04058

.04321

.04606

.04913

.03688

.03927

.04183

.04461

.04760

.03571

.03803

.04052

.04322

.04614

.03459

.03685

.03928

.04191

.04475

.03354

.03573

.03809

.04066

.04343

1999–20 I.R.B.

May 17, 1999

TABLE S

BASED ON LIFE TABLE 90CM

SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE

10.2%

10.4%

10.6%

10.8%

11.0%

11.2%

11.4%

11.6%

11.8%

12.0%

.06190

.06597

.07035

.07505

.08008

.05981

.06378

.06806

.07265

.07757

.05782

.06170

.06587

.07036

.07518

.05594

.05972

.06380

.06818

.07290

.05415

.05784

.06182

.06611

.07072

.05245

.05605

.05994

.06414

.06865

.05083

.05435

.05815

.06225

.06667

.04929

.05272

.05644

.06045

.06478

.04783

.05118

.05481

.05874

.06298

.04643

.04970

.05326

.05710

.06125

.08542

.09108

.09705

.10335

.10999

.08279

.08834

.09419

.10038

.10690

.08029

.08573

.09147

.09754

.10394

.07791

.08324

.08886

.09482

.10111

.07563

.08085

.08637

.09222

.09840

.07346

.07858

.08399

.08973

.09581

.07138

.07640

.08172

.08735

.09332

.06940

.07432

.07954

.08507

.09093

.06750

.07233

.07745

.08288

.08864

.06569

.07043

.07545

.08078

.08644

.11701

.12441

.13217

.14028

.14875

.11380

.12108

.12871

.13670

.14505

.11073

.11789

.12540

.13327

.14150

.10778

.11482

.12222

.12997

.13808

.10496

.11189

.11916

.12680

.13480

.10225

.10907

.11623

.12375

.13163

.09965

.10636

.11341

.12082

.12859

.09716

.10376

.11071

.11801

.12566

.09477

.10126

.10810

.11529

.12284

.09247

.09886

.10560

.11268

.12012

.15760

.16684

.17648

.18647

.19678

.15378

.16290

.17242

.18229

.19249

.15011

.15911

.16851

.17827

.18835

.14657

.15546

.16474

.17438

.18435

.14317

.15194

.16111

.17064

.18049

.13989

.14855

.15760

.16702

.17676

.13674

.14528

.15422

.16353

.17316

.13370

.14213

.15096

.16015

.16968

.13077

.13909

.14781

.15689

.16631

.12794

.13615

.14477

.15374

.16305

.20740

.21837

.22973

.24152

.25372

.20300

.21385

.22511

.23680

.24890

.19875

.20949

.22064

.23222

.24422

.19464

.20527

.21631

.22779

.23969

.19066

.20119

.21212

.22350

.23529

.18682

.19724

.20807

.21934

.23103

.18311

.19341

.20414

.21530

.22690

.17952

.18971

.20033

.21139

.22289

.17604

.18613

.19664

.20760

.21899

.17268

.18266

.19306

.20392

.21521

.26633

.27940

.29299

.30709

.32166

.33661

.26141

.27439

.28790

.30193

.31643

.33133

.25664

.26953

.28296

.29691

.31134

.32618

.25201

.26481

.27815

.29202

.30639

.32116

.24752

.26023

.27348

.28728

.30157

.31628

.24316

.25577

.26894

.28265

.29687

.31152

.23893

.25145

.26453

.27816

.29230

.30688

.23482

.24724

.26024

.27378

.28785

.30235

.23083

.24316

.25606

.26952

.28351

.29794

.22695

.23918

.25200

.26537

.27928

.29364

.35188

.36742

.38317

.39923

.34654

.36204

.37776

.39380

.34134

.35679

.37248

.38849

.33627

.35168

.36733

.38330

.33133

.34668

.36229

.37823

.32651

.34181

.35738

.37328

.32181

.33706

.35257

.36844

.31722

.33241

.34788

.36370

.31275

.32788

.34330

.35908

.30838

.32345

.33882

.35455

.41566

.43254

.44988

.46765

.48574

.41021

.42709

.44444

.46224

.48037

.40489

.42176

.43912

.45694

.47510

.39968

.41655

.43391

.45174

.46993

.39459

.41144

.42880

.44665

.46487

.38961

.40645

.42380

.44166

.45990

.38474

.40156

.41891

.43677

.45502

.37997

.39677

.41411

.43197

.45024

.37531

.39208

.40940

.42726

.44554

.37074

.38749

.40479

.42265

.44094

May 17, 1999

1999–20 I.R.B.

TABLE S

BASED ON LIFE TABLE 90CM

SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE

10.2%

10.4%

10.6%

10.8%

11.0%

11.2%

11.4%

11.6%

11.8%

12.0%

.50397

.52219

.54029

.55826

.57624

.49865

.51693

.53510

.55315

.57123

.49343

.51176

.53000

.54813

.56629

.48830

.50669

.52499

.54319

.56144

.48327

.50171

.52007

.53834

.55666

.47834

.49682

.51523

.53356

.55195

.47349

.49201

.51047

.52886

.54732

.46873

.48729

.50580

.52424

.54277

.46406

.48265

.50120

.51969

.53828

.45947

.47809

.49667

.51522

.53386

.59435

.61241

.63015

.64753

.66454

.58944

.60762

.62548

.64299

.66013

.58460

.60289

.62087

.63851

.65579

.57984

.59824

.61633

.63409

.65150

.57516

.59365

.61185

.62973

.64726

.57054

.58913

.60744

.62543

.64308

.56599

.58468

.60309

.62118

.63895

.56151

.58029

.59880

.61700

.63488

.55710

.57596

.59456

.61287

.63086

.55275

.57170

.59039

.60879

.62689

.68115

.69706

.71190

.72569

.73861

.67689

.69294

.70792

.72184

.73490

.67268

.68887

.70399

.71804

.73123

.66853

.68486

.70011

.71429

.72759

.66442

.68089

.69627

.71057

.72400

.66037

.67696

.69247

.70689

.72044

.65637

.67309

.68872

.70326

.71692

.65241

.66925

.68501

.69967

.71344

.64851

.66547

.68134

.69611

.71000

.64465

.66173

.67771

.69259

.70659

.75097

.76267

.77356

.78382

.79390

.74739

.75922

.77022

.78059

.79079

.74384

.75579

.76691

.77740

.78771

.74033

.75240

.76363

.77423

.78465

.73686

.74905

.76039

.77110

.78162

.73342

.74572

.75718

.76799

.77862

.73002

.74243

.75399

.76491

.77565

.72665

.73917

.75084

.76186

.77270

.72331

.73595

.74772

.75884

.76978

.72001

.73275

.74463

.75584

.76688

100

101

102

103

104

.80376

.81353

.82318

.83278

.84310

.80076

.81066

.82042

.83014

.84059

.79779

.80780

.81768

.82752

.83810

.79485

.80497

.81496

.82491

.83563

.79193

.80217

.81227

.82233

.83317

.78904

.79938

.80960

.81977

.83073

.78617

.79662

.80694

.81723

.82831

.78333

.79388

.80431

.81470

.82591

.78051

.79117

.80170

.81220

.82352

.77771

.78847

.79911

.80971

.82115

105

106

107

108

109

.85318

.86633

.88247

.90825

.95372

.85079

.86413

.88049

.90666

.95290

.84843

.86193

.87852

.90507

.95208

.84607

.85975

.87656

.90350

.95126

.84374

.85758

.87460

.90193

.95045

.84142

.85543

.87266

.90037

.94964

.83911

.85329

.87073

.89881

.94883

.83682

.85116

.86881

.89727

.94803

.83455

.84904

.86690

.89572

.94723

.83229

.84694

.86500

.89419

.94643

1999–20 I.R.B.

May 17, 1999

TABLE S

BASED ON LIFE TABLE 90CM

SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE

12.2%

12.4%

12.6%

12.8%

13.0%

13.2%

13.4%

13.6%

13.8%

14.0%

.01298

.00468

.00448

.00452

.00468

.01285

.00455

.00435

.00437

.00452

.01273

.00443

.00421

.00423

.00437

.01261

.00431

.00409

.00410

.00423

.01250

.00420

.00398

.00410

.01240

.00410

.00387

.00386

.00397

.01230

.00400

.00376

.00375

.00386

.01221

.00391

.00366

.00365

.00375

.01212

.00382

.00357

.00355

.00364

.01203

.00374

.00348

.00345

.00354

.00493

.00524

.00562

.00606

.00659

.00476

.00506

.00543

.00586

.00637

.00460

.00489

.00525

.00566

.00616

.00445

.00473

.00508

.00548

.00597

.00431

.00458

.00492

.00531

.00579

.00418

.00444

.00477

.00515

.00561

.00405

.00430

.00462

.00499

.00545

.00393

.00418

.00449

.00485

.00529

.00382

.00406

.00436

.00471

.00514

.00371

.00394

.00423

.00458

.00500

.00721

.00792

.00871

.00955

.01038

.00698

.00767

.00845

.00928

.01009

.00676

.00744

.00821

.00902

.00981

.00655

.00722

.00797

.00877

.00955

.00636

.00701

.00775

.00854

.00930

.00617

.00682

.00754

.00831

.00907

.00600

.00663

.00735

.00810

.00885

.00583

.00645

.00716

.00790

.00864

.00567

.00628

.00698

.00771

.00843

.00552

.00612

.00681

.00753

.00824

.01116

.01186

.01250

.01308

.01367

.01085

.01153

.01215

.01272

.01329

.01056

.01123

.01183

.01238

.01293

.01028

.01094

.01152

.01206

.01259

.01002

.01066

.01124

.01175

.01227

.00977

.01040

.01096

.01147

.01196

.00954

.01015

.01070

.01119

.01167

.00932

.00992

.01045

.01093

.01140

.00910

.00969

.01022

.01068

.01113

.00890

.00948

.00999

.01044

.01088

.01428

.01494

.01562

.01635

.01716

.01388

.01451

.01517

.01588

.01665

.01350

.01411

.01475

.01543

.01618

.01314

.01373

.01435

.01501

.01573

.01280

.01337

.01397

.01460

.01530

.01248

.01303

.01361

.01422

.01489

.01217

.01271

.01326

.01386

.01451

.01188

.01240

.01294

.01351

.01415

.01161

.01211

.01263

.01319

.01380

.01134

.01183

.01233

.01287

.01347

.01804

.01902

.02011

.02129

.02258

.01751

.01845

.01951

.02066

.02191

.01701

.01792

.01895

.02006

.02127

.01653

.01741

.01841

.01949

.02067

.01608

.01693

.01790

.01895

.02009

.01565

.01648

.01742

.01844

.01955

.01524

.01604

.01696

.01795

.01903

.01485

.01563

.01652

.01748

.01853

.01448

.01524

.01610

.01704

.01806

.01413

.01487

.01571

.01662

.01762

.02396

.02543

.02701

.02871

.03054

.02325

.02467

.02621

.02786

.02964

.02257

.02396

.02545

.02706

.02879

.02193

.02328

.02472

.02629

.02797

.02132

.02263

.02404

.02556

.02720

.02074

.02201

.02338

.02487

.02646

.02019

.02143

.02276

.02420

.02576

.01966

.02087

.02217

.02357

.02509

.01916

.02034

.02160

.02297

.02445

.01869

.01983

.02106

.02240

.02383

.03253

.03467

.03697

.03947

.04217

.03158

.03366

.03590

.03833

.04096

.03067

.03269

.03488

.03725

.03982

.02981

.03178

.03391

.03622

.03873

.02898

.03090

.03298

.03524

.03768

.02820

.03007

.03209

.03430

.03669

.02745

.02928

.03125

.03340

.03573

.02674

.02852

.03044

.03254

.03482

.02606

.02779

.02967

.03172

.03395

.02541

.02710

.02893

.03094

.03312

May 17, 1999

1999–20 I.R.B.

TABLE S

BASED ON LIFE TABLE 90CM

SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE

12.2%

12.4%

12.6%

12.8%

13.0%

13.2%

13.4%

13.6%

13.8%

14.0%

.04510

.04830

.05177

.05553

.05960

.04383

.04695

.05035

.05404

.05802

.04262

.04567

.04900

.05261

.05651

.04146

.04445

.04770

.05123

.05506

.04035

.04327

.04646

.04992

.05368

.03930

.04215

.04527

.04866

.05235

.03828

.04108

.04413

.04746

.05107

.03732

.04005

.04304

.04630

.04985

.03639

.03907

.04200

.04520

.04867

.03550

.03812

.04100

.04413

.04754

.06395

.06860

.07353

.07877

.08433

.06229

.06685

.07169

.07684

.08231

.06069

.06517

.06992

.07498

.08036

.05917

.06356

.06823

.07320

.07849

.05770

.06202

.06660

.07149

.07669

.05630

.06053

.06504

.06984

.07495

.05495

.05911

.06353

.06826

.07329

.05365

.05774

.06209

.06673

.07168

.05241

.05643

.06070

.06527

.07013

.05121

.05516

.05936

.06385

.06864

.09026

.09655

.10318

.11017

.11750

.08814

.09433

.10086

.10774

.11498

.08609

.09219

.09863

.10541

.11254

.08413

.09013

.09647

.10315

.11019

.08224

.08815

.09439

.10098

.10792

.08042

.08624

.09239

.09888

.10572

.07867

.08440

.09046

.09686

.10361

.07698

.08262

.08860

.09491

.10156

.07535

.08091

.08680

.09302

.09958

.07378

.07926

.08506

.09120

.09767

.12522

.13332

.14183

.15070

.15990

.12258

.13059

.13899

.14775

.15685

.12005

.12794

.13624

.14490

.15389

.11759

.12539

.13359

.14215

.15103

.11522

.12292

.13102

.13948

.14826

.11294

.12054

.12853

.13689

.14558

.11072

.11823

.12613

.13439

.14298

.10859

.11599

.12380

.13197

.14046

.10652

.11383

.12154

.12962

.13801

.10451

.11174

.11936

.12734

.13564

.16942

.17929

.18960

.20035

.21154

.16626

.17603

.18623

.19688

.20797

.16321

.17287

.18297

.19352

.20451

.16024

.16981

.17980

.19025

.20114

.15737

.16684

.17673

.18708

.19787

.15459

.16395

.17375

.18400

.19469

.15189

.16115

.17085

.18100

.19159

.14927

.15844

.16803

.17809

.18859

.14673

.15580

.16530

.17525

.18566

.14426

.15324

.16264

.17250

.18281

.22318

.23532

.24804

.26133

.27516

.28945

.21951

.23156

.24419

.25740

.27114

.28536

.21595

.22790

.24044

.25356

.26723

.28137

.21249

.22434

.23679

.24983

.26341

.27747

.20912

.22088

.23324

.24618

.25969

.27367

.20584

.21751

.22977

.24263

.25605

.26996

.20265

.21422

.22640

.23917

.25251

.26633

.19955

.21102

.22311

.23579

.24905

.26279

.19652

.20791

.21990

.23250

.24567

.25934

.19358

.20487

.21678

.22929

.24237

.25596

.30412

.31913

.33444

.35012

.29996

.31491

.33016

.34579

.29590

.31078

.32597

.34155

.29193

.30675

.32188

.33741

.28806

.30281

.31788

.33335

.28427

.29895

.31396

.32938

.28057

.29519

.31013

.32549

.27696

.29150

.30638

.32168

.27343

.28790

.30271

.31795

.26998

.28438

.29913

.31430

.36628

.38299

.40028

.41812

.43641

.36190

.37858

.39585

.41368

.43198

.35762

.37427

.39151

.40933

.42762

.35343

.37004

.38725

.40506

.42334

.34932

.36589

.38307

.40086

.41914

.34530

.36183

.37898

.39675

.41502

.34136

.35784

.37496

.39271

.41096

.33750

.35394

.37103

.38874

.40698

.33372

.35011

.36716

.38485

.40308

.33001

.34636

.36337

.38103

.39924

1999–20 I.R.B.

May 17, 1999

TABLE S

BASED ON LIFE TABLE 90CM

SINGLE LIFE REMAINDER FACTORS

APPLICABLE AFTER APRIL 30, 1999

INTEREST RATE

AGE

12.2%

12.4%

12.6%

12.8%

13.0%

13.2%

13.4%

13.6%

13.8%

14.0%

.45496

.47360

.49223

.51081

.52951

.45054

.46920

.48785

.50648

.52523

.44619

.46487

.48355

.50221

.52101

.44192

.46061

.47932

.49802

.51686

.43772

.45643

.47516

.49388

.51277

.43360

.45231

.47106

.48982

.50874

.42954

.44827

.46703

.48581

.50477

.42556

.44429

.46307

.48187

.50086

.42164

.44038

.45916

.47799

.49701

.41779

.43653

.45532

.47416

.49321

.54847

.56749

.58627

.60477

.62297

.54425

.56335

.58221

.60079

.61909

.54009

.55926

.57820

.59688

.61527

.53600

.55523

.57425

.59301

.61149

.53196

.55126

.57035

.58919

.60776

.52798

.54734

.56650

.58542

.60408

.52406

.54348

.56270

.58170

.60044

.52019

.53966

.55895

.57802

.59685

.51638

.53591

.55526

.57439

.59330

.51262

.53220

.55161

.57081

.58979

.64084

.65803

.67412

.68911

.70321

.63707

.65437

.67058

.68567

.69988

.63335

.65076

.66707

.68227

.69657

.62968

.64719

.66360

.67890

.69330

.62604

.64366

.66017

.67557

.69006

.62246

.64017

.65678

.67227

.68686

.61891

.63672

.65342

.66901

.68369

.61540

.63330

.65010

.66578

.68055

.61194

.62993

.64682

.66258

.67744

.60851

.62659

.64357

.65942

.67437

.71674

.72959

.74156

.75287

.76401

.71351

.72646

.73853

.74993

.76117

.71031

.72335

.73552

.74702

.75834

.70713

.72028

.73254

.74413

.75555

.70399

.71724

.72959

.74126

.75277

.70088

.71422

.72666

.73842

.75002

.69781

.71123

.72376

.73561

.74730

.69476

.70828

.72089

.73282

.74459

.69174

.70534

.71804

.73006

.74191

.68875

.70244

.71522

.72732

.73926

100

101

102

103

104

.77494

.78580

.79654

.80724

.81879

.77219

.78315

.79399

.80479

.81646

.76946

.78052

.79146

.80236

.81413

.76676

.77791

.78894

.79994

.81183

.76408

.77532

.78645

.79755

.80954

.76142

.77275

.78397

.79517

.80726

.75878

.77021

.78152

.79280

.80501

.75616

.76768

.77908

.79046

.80276

.75357

.76517

.77666

.78813

.80054

.75099

.76268

.77426

.78582

.79832

105

106

107

108

109

.83005

.84485

.86311

.89266

.94563

.82782

.84277

.86124

.89114

.94484

.82560

.84071

.85937

.88963

.94405

.82340

.83866

.85751

.88812

.94326

.82121

.83662

.85566

.88662

.94248

.81904

.83459

.85382

.88513

.94170

.81688

.83257

.85199

.88364

.94092

.81474

.83057

.85017

.88216

.94014

.81260

.82857

.84835

.88068

.93937

.81049

.82659

.84655

.87922

.93860

(f) Effective dates. This section applies

after April 30, 1999.

Par. 6. Immediately following

§1.643(d)–2, the undesignated centerheading is revised to read as follows:

Pooled Income Fund Actuarial Tables

Applicable Before May 1, 1999

Par. 7. Section 1.642(c)–6A is amended

by:

1. Revising the section heading.

2. Amending newly designated paragraph (e) as follows:

a. Paragraph (e) heading is revised.

May 17, 1999

b. Paragraph (e)(1), first sentence is

revised.

c. Paragraph (e)(2)(ii) is revised.

d. Paragraph (e)(3) is revised.

e. Paragraph (e)(4) is revised.

f. Paragraph (e)(5) introductory text is

revised.

g. Paragraph (e)(5), the heading for

Table S is revised.

The revisions read as follows:

§1.642(c)–6A Valuation of charitable

remainder interests for which the

valuation date is before May 1, 1999.

* * * * *

(e) Present value of the remainder interest in the case of transfers to pooled income funds for which the valuation date is

after April 30, 1989, and before May 1,

1999—(1) In general. In the case of

transfers to pooled income funds for

which the valuation date is after April 30,

1989, and before May 1, 1999, the present

value of a remainder interest is determined under this section. * * *

(2) * * *

(ii) Discount at a rate of interest, compounded annually, equal to the highest

1999–20 I.R.B.

yearly rate of return of the pooled income

fund for the 3 taxable years immediately

preceding its taxable year in which the

transfer of property to the fund is made.

The provisions of §1.642(c)–6(c) apply

for determining the yearly rate of return.

However, where the taxable year is less

than 12 months, the provisions of

§1.642(c)–6T(e)(3)(ii) apply for the determining the yearly rate of return.

(3) Pooled income funds in existence

less than 3 taxable years. The provisions

of §1.642(c)–6T(e)(4) apply for determining the highest yearly rate of return when

the pooled income fund has been in existence less than three taxable years.

(4) Computation of value of remainder

interest. The factor that is used in determining the present value of a remainder

interest that is dependent on the termination of the life of one individual is the factor from Table S in paragraph (e)(5) of

this section under the appropriate yearly

rate of return opposite the number that

corresponds to the age of the individual

upon whose life the value of the remainder interest is based. Table S in paragraph

(e)(5) of this section includes factors for

yearly rates of return from 4.2 to 14 percent. Many actuarial factors not contained in Table S in paragraph (e)(5) of

this section are contained in Table S in Internal Revenue Service Publication 1457,

“Actuarial Values, Alpha Volume,”

(8–89). Publication 1457 is no longer

available for purchase from the Superintendent of Documents, United States

Government Printing Office, Washington,

DC 20402. However, pertinent factors in

this publication may be obtained by a

written request to: CC:DOM:CORP:R

(IRS Publication 1457), room 5226,Internal Revenue Service, POB 7604, Ben

Franklin Station, Washington, DC 20044.

For other situations, see §1.642(c)–6(b).

If the yearly rate of return is a percentage

that is between the yearly rates of return

for which factors are provided, a linear interpolation must be made. The present

value of the remainder interest is determined by multiplying the fair market

value of the property on the valuation date

by the appropriate remainder factor. For

an example of a computation of the present value of a remainder interest requiring a linear interpolation adjustment, see

§1.642(c)–6T(e)(5).

1999–20 I.R.B.

TABLE S.—BASED ON LIFE TABLE

80CNSMT SINGLE LIFE REMAINDER

FACTORS

[Applicable After April 30, 1989, and Before May 1, 1999]

value of a charitable remainder unitrust

interest is dependent on the termination

of a life interest , see §1.664–4T(e)(7).

See, however, §1.7520–3(b) (relating to

exceptions to the use of prescribed tables

under certain circumstances). Many actuarial factors not contained in the following tables are contained in Internal Revenue Service Publication 1458, “Actuarial

Values, Book Beth,” (1999). A copy of

this publication is available for purchase

from the Superintendent of Documents,

United States Government Printing Office, Washington, DC 20402.

* * * * *

Par. 8. Section 1.664–4 is amended as

follows:

1. Paragraph (a)(1) is revised.

2. Paragraph (d) is removed.

3. Paragraphs (e) heading, (e)(1)

through (e)(5), and (e)(6) heading, introductory text , and Table U(1) are redesignated as §1.664–4A(e) heading, (e)(1)

through (e)(5) and (e)(6) heading, introductory text, and Table U(1), respectively.

4. New paragraphs (d) through (e)(5)

are added.

5. New paragraph heading and introductory text are added to remaining paragraph (e)(6) preceding Table D.

6. Paragraph (f) is revised.

The additions and revision read as follows:

(f) Effective dates. This section applies

after April 30, 1989, and before May 1,

1999.

Par. 9 Section 1.664–4T is added to

read as follows:

(5) Actuarial tables. In the case of

transfers for which the valuation date is

after April 30, 1989, and before May 1,

1999, the present value of a remainder interest dependent on the termination of one

life in the case of a transfer to a pooled income fund is determined by use of the following tables:

§1.664–4 Calculation of the fair market

value of the remainder interest in a

charitable remainder unitrust.

(a) * * *

(1) [Reserved]. For further guidance,

see §1.664–4T(a)(1).

* * * * *

(d) through (e)(5) [Reserved]. For further guidance, see §1.664–4T(d) through

(e)(5).

(6) Actuarial Table D and F (4.2

through 14.0) for transfers for which the

valuation date is after April 30, 1989. For

transfers for which the valuation date is

after April 30, 1989, the present value of a

charitable remainder unitrust interest that

is dependent upon a term of years is determined by using the section 7520 rate and

the tables in this paragraph (e)(6). For

transfers for which the valuation date is

after April 30, 1999, where the present

§1.664–4T Calculation of the fair market

value of the remainder interest in a

charitable remainder unitrust

(temporary).

(a) [Reserved] For further guidance,

see §1.664–4(a).

(1) Life contingencies determined as to

each life involved, from the values of lx

set forth in Table 90CM contained in

§20.2031–7T(d)(7) of this chapter (Estate

Tax Regulations) in the case of transfers

for which the valuation date is after April

30, 1999; or from Table 80CNSMT contained §20.2031–7A(e)(4) of this chapter

in the case of transfer for which the valuation date is after April 30, 1989, and before May 1, 1999. See §20.2031–7A(a)

through (d) of this chapter, whichever is

applicable, for transfers for which the valuation date is before May 1, 1989;

(a)(2) through (c) [Reserved] For further guidance, see §1,664–4(a)(2) through

(c).

(d) Valuation. The fair market value of

a remainder interest in a charitable remainder unitrust (as described in §1.664–

3) for transfers for which the valuation

date is after April 30, 1999, is its present

value determined under paragraph (e) of

this section. The fair market value of a

remainder interest in a charitable remainder unitrust (as described in §1.664–3) for

transfers for which the valuation date is

before May 1, 1999, is its present value

determined under the following sections:

May 17, 1999

Valuation Dates

After

Before

—

12-31-51

12-31-70

11-30-83

04-30-89

01-01-52

01-01-71

12-01-83

05-01-89

05-01-99

Applicable

Regulations

1.664-4A(a)

1.664–4A(b)

1.664–4A(c)

1.664–4A(d)

1.664–4A(e)

(e) Valuation of charitable remainder

unitrusts having certain payout sequences

for transfers for which the valuation date

is after April 30, 1999—(1) In general.

Except as otherwise provided in paragraph (e)(2) of this section, in the case of

transfers for which the valuation date is

after April 30, 1999, the present value of a

remainder interest is determined under

paragraphs (e)(3) through (e)(6) of this

section, provided that the amount of the

payout as of any payout date during any

taxable year of the trust is not larger than

the amount that the trust could distribute

on such date under §1.664–3(a)(1)(v) if

the taxable year of the trust were to end

on such date. See, however, §1.7520–

3(b) (relating to exceptions to the use of

the prescribed tables under certain circumstances).

(2) Transitional rules for valuation of

charitable remainder unitrusts. (i) For

purposes of sections 2055, 2106, or 2624,

if on May 1, 1999, the decedent was mentally incompetent so that the disposition

of the property could not be changed, and

the decedent died after April 30, 1999,

without having regained competency to

dispose of the decedent’s property, or the

decedent died within 90 days of the date

that the decedent first regained competency after April 30, 1999, the present

value of a remainder interest under this

section is determined as if the valuation

date with respect to the decedent’s gross

estate is either before May 1, 1999, or

after April 30, 1999, at the option of the

decedent’s executor.

(ii) For purposes of sections 170, 2055,

2106, 2522, or 2624, in the case of transfers to a charitable remainder unitrust for

which the valuation date is after April 30,

1999, and before July 1, 1999, the present

value of a remainder interest based on one

or more measuring lives is determined

under this section by use of the section

7520 interest rate for the month in which

the valuation date occurs (See §§1.7520–

1(b) and 1.7520–2(a)(2)) and the appropriate actuarial tables under either para-

May 17, 1999

graph (e)(7) of this section or §1.664–

4A(e)(6), at the option of the donor or the

decedent’s executor, as the case may be.

(iii) For purposes of paragraphs

(e)(2)(i) and (ii) of this section, where the

donor or decedent’s executor is given the

option to use the appropriate actuarial tables under either paragraph (e)(7) of this

section or §1.664–4A(e)(6), the donor or

decedent’s executor must use the same actuarial table with respect to each individual transaction and with respect to all

transfers occurring on the valuation date

(e.g., gift and income tax charitable deductions with respect to the same transfer

must be determined based on the same tables, and all assets includible in the gross

estate and/or estate tax deductions

claimed must be valued based on the

same tables).

(3) Adjusted payout rate. For transfers

for which the valuation date is after April

30, 1989, the adjusted payout rate is determined by using the appropriate Table F

in §1.664–4(e)(6), for the section 7520 interest rate applicable to the transfer. If the

interest rate is between 4.2 and 14 percent, see §1.664–4(e)(6). If the interest

rate is below 4.2 percent or greater than

14 percent, see §1.664–4(b). The adjusted payout rate is determined by multiplying the fixed percentage described in

§1.664–3(a)(1)(i)(a) by the factor describing the payout sequence of the trust and

the number of months by which the valuation date for the first full taxable year of

the trust precedes the first payout date for

such taxable year. If the governing instrument does not prescribe when the distribution or distributions shall be made during the taxable year of the trust, see

§1.664–4(a). In the case of a trust having

a payout sequence for which no figures

have been provided by the appropriate

table, and in the case of a trust that determines the fair market value of the trust assets by taking the average of valuations

on more than one date during the taxable

year, see §1.664–4(b).

(4) Period is a term of years. If the period described in §1.664–3(a)(5) is a term

of years, the factor that is used in determining the present value of the remainder

interest for transfers for which the valuation date is after November 30, 1983, is

the factor under the appropriate adjusted

payout rate in Table D of §1.664–4(e)(6)

corresponding to the number of years in

the term. If the adjusted payout rate is an

amount that is between adjusted payout

rates for which factors are provided in

Table D, a linear interpolation must be

made. The present value of the remainder

interest is determined by multiplying the

net fair market value (as of the appropriate valuation date) of the property placed

in trust by the factor determined under

this paragraph. For purposes of this section, the valuation date is, in the case of

an inter vivos transfer, the date on which

the property is transferred to the trust by

the donor. However, if an election is

made under section 7520 and §1.7520–

2(b) to compute the present value of the

charitable interest by use of the interest

rate component for either of the 2 months

preceding the month in which the date of

transfer falls, the month so elected is the

valuation date for purposes of determining the interest rate and mortality tables.

In the case of a testamentary transfer

under section 2055, 2106, or 2624, the

valuation date is the date of death, unless

the alternate valuation date is elected

under section 2032, in which event, and

within the limitations set forth in section

2032 and the regulations thereunder, the

valuation date is the alternate valuation

date. If the decedent’s estate elects the alternate valuation date under section 2032

and also elects, under section 7520 and

§1.7520–2(b), to use the interest rate

component for one of the 2 months preceding the alternate valuation date, the

month so elected is the valuation date for

purposes of determining the interest rate

and mortality tables. The application of

this paragraph (e)(4) may be illustrated by

the following example:

Example. D transfers $100,000 to a charitable remainder unitrust on January 1. The trust instrument

requires that the trust pay 8 percent of the fair market value of the trust assets as of January 1st for a

term of 12 years to D in quarterly payments (March

31, June 30, September 30, and December 31). The

section 7520 rate for January (the month that the

transfer occurred) is 9.6 percent. Under Table F(9.6)

in §1.664–4(e)(6), the appropriate adjustment factor

is .944628 for quarterly payments payable at the end

of each quarter. The adjusted payout rate is 7.557

(8% ⫻ .944628). Based on the remainder factors in

Table D in §1.664–4(e)(6), the present value of the

remainder interest is $38,950.30, computed as follows:

Factor at 7.4 percent for 12 years ......... .397495

Factor at 7.6 percent for 12 years ......... .387314

Difference ............................................. .010181

1999–20 I.R.B.

Interpolation adjustment:

7.557% – 7.4%

0.2%

.010181

.007992

Factor at 7.4 percent for 12 years ......... .397495

Less: Interpolation adjustment ............... .007992

Interpolated factor .................................. .389503

Present value of remainder interest:

($100,000 ⫻ .389503) . . . . . . . . . . . $38,950.30

(5) Period is the life of one individual.

If the period described in §1.664–3(a)(5)

is the life of one individual, the factor that

is used in determining the present value of

the remainder interest for transfers for

which the valuation date is after April 30,

1999, is the factor in Table U(1) in paragraph (e)(7) of this section under the appropriate adjusted payout. For purposes

of the computations described in this

paragraph, the age of an individual is the

age of that individual at the individual’s

nearest birthday. If the adjusted payout

rate is an amount that is between adjusted

payout rates for which factors are provided in the appropriate table, a linear interpolation must be made. The present

value of the remainder interest is determined by multiplying the net fair market

value (as of the valuation date as deter-

mined in paragraph (e)(4) of this section)

of the property placed in trust by the factor determined under this paragraph

(e)(5). If the adjusted payout rate is between 4.2 and 14 percent, see paragraph

(e)(7) of this section. If the adjusted payout rate is below 4.2 percent or greater

than 14 percent, see §1.664–4(b). The application of this paragraph (e)(5) may be

illustrated by the following example:

Example. A, who is 44 years and 11 months old,

transfers $100,000 to a charitable remainder unitrust

on January 1st. The trust instrument requires that

the trust pay to A semiannually (on June 30 and December 31) 9 percent of the fair market value of the

trust assets as of January 1st during A’s life. The

section 7520 rate for January is 9.6 percent. Under

Table F(9.6) in §1.664–4(e)(6), the appropriate adjustment factor is .933805 for semiannual payments

payable at the end of the semiannual period. The adjusted payout rate is 8.404 (9% ⫻ .933805). Based

on the remainder factors in Table U(1) in this section, the present value of the remainder interest is

$10,109.00, computed as follows:

Factor at 8.4 percent at age 45 . . . . . . . . .10117

Factor at 8.6 percent at age 45 . . . . . . . . .09715

Difference. . . . . . . . . . . . . . . . . . . . . . . . .00402

Interpolation adjustment:

8.404% – 8.4%

0.2%

.00402

.00008

Factor at 8.4 percent at age 45 . . . . . . . . .10117

Less: Interpolation adjustment . . . . . . . . .00008

Interpolated Factor . . . . . . . . . . . . . . . . .10109

Present value of remainder interest:

($100,000 ⫻ .10109) . . . . . . . . $10,109.00

(6) [Reserved].

(7) Actuarial Table U(1) for transfers

for which the valuation date is after April

30, 1999. For transfers for which the valuation date is after April 30, 1999, the

present value of a charitable remainder

unitrust interest that is dependent on a

term of years or the termination of a life

interest is determined by using the section

7520 rate, Table U(1) in this paragraph

(e)(7), and Table D and Table F(4.2)

through (14.0) in §1.664–4(e)(6). See,

however, §1.7520–3(b) (relating to exceptions to the use of prescribed tables under

certain circumstances). Many actuarial

factors not contained in the following tables are contained in Internal Revenue

Service Publication 1458, “Actuarial Values, Book Beth,” (1999). A copy of this

publication is available for purchase from

the Superintendent of Documents, United

States Government Printing Office,

Washington, DC 20402.

TABLE U(1)

BASED ON LIFE TABLE 90CM

UNITRUST SINGLE LIFE REMAINDER FACTORS

APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE

4.2%

4.4%

4.6%

4.8%

5.0%

5.2%

5.4%

5.6%

5.8%

6.0%

.06177

.05543

.05716

.05920

.06143

.05580

.04925

.05081

.05268

.05475

.05061

.04388

.04528

.04699

.04889

.04609

.03919

.04045

.04201

.04376

.04215

.03509

.03622

.03765

.03926

.03871

.03151

.03252

.03382

.03530

.03570

.02838

.02927

.03046

.03182

.03307

.02563

.02642

.02750

.02876

.03075

.02321

.02391

.02490

.02605

.02872

.02109

.02170

.02260

.02366

.06384

.06637

.06905

.07186

.07482

.05697

.05933

.06183

.06445

.06722

.05095

.05315

.05547

.05792

.06052

.04567

.04771

.04987

.05216

.05460

.04103

.04292

.04494

.04708

.04936

.03694

.03870

.04058

.04258

.04471

.03334

.03497

.03673

.03859

.04060

.03016

.03168

.03332

.03506

.03694

.02735

.02876

.03029

.03192

.03369

.02487

.02618

.02761

.02914

.03079

.07793

.08120

.08461

.08812

.09168

.07015

.07323

.07645

.07976

.08313

.06327

.06617

.06920

.07234

.07552

.05718

.05991

.06277

.06574

.06874

.05179

.05435

.05706

.05985

.06269

.04700

.04942

.05197

.05461

.05729

.04274

.04502

.04744

.04993

.05247

.03896

.04111

.04339

.04576

.04815

.03559

.03762

.03978

.04202

.04428

.03259

.03450

.03655

.03867

.04081

1999–20 I.R.B.

May 17, 1999

BASED ON LIFE TABLE 90CM

UNITRUST SINGLE LIFE REMAINDER FACTORS

APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE

4.2%

4.4%

4.6%

4.8%

5.0%

5.2%

5.4%

5.6%

5.8%

6.0%

.09527

.09886

.10249

.10616

.10994

.08652

.08991

.09334

.09680

.10037

.07872

.08192

.08515

.08842

.09178

.07176

.07478

.07782

.08090

.08407

.06554

.06839

.07126

.07415

.07714

.05999

.06267

.06537

.06809

.07091

.05501

.05754

.06008

.06264

.06529

.05055

.05294

.05533

.05774

.06023

.04655

.04880

.05105

.05332

.05566

.04296

.04508

.04720

.04933

.05153

.11384

.11790

.12208

.12643

.13095

.10406

.10790

.11188

.11601

.12031

.09527

.09891

.10267

.10659

.11069

.08737

.09080

.09436

.09808

.10197

.08025

.08349

.08686

.09038

.09408

.07383

.07690

.08008

.08342

.08692

.06805

.07094

.07395

.07710

.08042

.06283

.06555

.06839

.07138

.07452

.05811

.06068

.06336

.06618

.06915

.05384

.05626

.05879

.06146

.06427

.13567

.14058

.14571

.15104

.15656

.12481

.12950

.13442

.13953

.14484

.11497

.11945

.12415

.12904

.13414

.10605

.11032

.11481

.11949

.12438

.09795

.10202

.10631

.11078

.11546

.09060

.09447

.09856

.10284

.10731

.08392

.08760

.09149

.09558

.09986

.07784

.08134

.08505

.08895

.09304

.07230

.07563

.07916

.08288

.08679

.06726

.07042

.07379

.07733

.08106

.16229

.16821

.17433

.18068

.18724

.15034

.15605

.16196

.16810

.17446

.13943

.14493

.15063

.15655

.16270

.12946

.13474

.14023

.14595

.15189

.12034

.12541

.13069

.13620

.14193

.11198

.11685

.12193

.12723

.13275

.10433

.10900

.11387

.11897

.12430

.09732

.10179

.10647

.11137

.11650

.09089

.09517

.09966

.10437

.10930

.08498

.08909

.09339

.09791

.10265

.19405

.20109

.20838

.21593

.22374

.18107

.18791

.19500

.20236

.20998

.16910

.17574

.18263

.18979

.19723

.15808

.16451

.17120

.17816

.18540

.14791

.15414

.16062

.16739

.17443

.13853

.14456

.15083

.15739

.16423

.12987

.13569

.14177

.14813

.15477

.12187

.12749

.13337

.13953

.14597

.11448

.11990

.12558

.13154

.13779

.10764

.11287

.11835

.12412

.13017

.23183

.24021

.24889

.25786

.26712

.21789

.22611

.23463

.24344

.25257

.20496

.21299

.22134

.23000

.23896

.19294

.20079

.20896

.21744

.22625

.18177

.18943

.19741

.20572

.21435

.17138

.17885

.18665

.19477

.20322

.16172

.16899

.17660

.18453

.19281

.15272

.15980

.16721

.17496

.18305

.14434

.15123

.15845

.16601

.17391

.13653

.14322

.15025

.15762

.16534

.27665

.28644

.29647

.30676

.31729

.26196

.27163

.28155

.29173

.30217

.24821

.25774

.26754

.27760

.28794

.23534

.24472

.25438

.26431

.27453

.22328

.23251

.24201

.25181

.26190

.21198

.22105

.23040

.24004

.24999

.20139

.21028

.21947

.22896

.23876

.19145

.20018

.20919

.21852

.22817

.18213

.19068

.19952

.20868

.21817

.17338

.18174

.19041

.19941

.20873

.32808

.33912

.35038

.36185

.37352

.31289

.32387

.33507

.34651

.35815

.29856

.30946

.32060

.33198

.34358

.28505

.29585

.30691

.31821

.32976

.27229

.28299

.29395

.30517

.31664

.26026

.27083

.28168

.29280

.30418

.24889

.25933

.27005

.28106

.29234

.23814

.24845

.25904

.26993

.28110

.22799

.23815

.24861

.25937

.27042

.21839

.22840

.23872

.24934

.26026

May 17, 1999

1999–20 I.R.B.

BASED ON LIFE TABLE 90CM

UNITRUST SINGLE LIFE REMAINDER FACTORS

APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE

4.2%

4.4%

4.6%

4.8%

5.0%

5.2%

5.4%

5.6%

5.8%

6.0%

.38539

.39746

.40971

.42212

.43464

.37002

.38209

.39437

.40682

.41939

.35542

.36748

.37976

.39222

.40482

.34155

.35358

.36584

.37829

.39090

.32836

.34034

.35257

.36500

.37759

.31583

.32774

.33992

.35231

.36488

.30390

.31574

.32785

.34019

.35272

.29256

.30431

.31634

.32862

.34109

.28177

.29342

.30536

.31756

.32996

.27149

.28303

.29488

.30699

.31932

.44726

.45999

.47286

.48589

.49903

.43207

.44488

.45785

.47098

.48426

.41754

.43041

.44345

.45667

.47005

.40364

.41655

.42964

.44293

.45638

.39034

.40326

.41639

.42972

.44324

.37761

.39053

.40367

.41703

.43060

.36542

.37833

.39146

.40484

.41843

.35375

.36662

.37974

.39311

.40671

.34257

.35540

.36848

.38184

.39544

.33186

.34463

.35767

.37100

.38458

.51229

.52568

.53924

.55293

.56671

.58052

.49766

.51121

.52495

.53883

.55283

.56687

.48357

.49726

.51115

.52521

.53940

.55365

.47001

.48381

.49784

.51205

.52640

.54084

.45694

.47084

.48498

.49932

.51382

.52843

.44435

.45833

.47256

.48701

.50165

.51639

.43223

.44626

.46056

.47511

.48985

.50473

.42054

.43461

.44898

.46360

.47844

.49342

.40927

.42337

.43778

.45246

.46738

.48245

.39841

.41252

.42696

.44169

.45666

.47181

.59431

.60804

.62168

.63528

.58091

.59490

.60881

.62268

.56791

.58213

.59629

.61042

.55529

.56973

.58411

.59848

.54306

.55768

.57227

.58686

.53118

.54598

.56076

.57555

.51966

.53461

.54955

.56453

.50847

.52357

.53866

.55380

.49761

.51283

.52806

.54335

.48707

.50239

.51774

.53316

.64887

.66249

.67612

.68975

.70330

.63657

.65049

.66446

.67843

.69233

.62458

.63880

.65307

.66736

.68160

.61290

.62739

.64194

.65654

.67109

.60151

.61625

.63108

.64596

.66081

.59041

.60538

.62046

.63561

.65074

.57959

.59478

.61009

.62548

.64088

.56904

.58443

.59995

.61558

.63123

.55875

.57432

.59005

.60590

.62178

.54872

.56446

.58037

.59643

.61253

.71666

.72975

.74250

.75493

.76712

.70605

.71950

.73263

.74542

.75798

.69566

.70946

.72293

.73608

.74900

.68548

.69961

.71342

.72690

.74016

.67550

.68995

.70407

.71788

.73147

.66573

.68047

.69490

.70902

.72292

.65615

.67117

.68589

.70031

.71451

.64676

.66205

.67705

.69175

.70624

.63755

.65310

.66837

.68333

.69810

.62853

.64433

.65984

.67506

.69010

.77913

.79086

.80218

.81307

.82355

.77037

.78248

.79418

.80544

.81628

.76175

.77423

.78628

.79790

.80909

.75326

.76610

.77850

.79047

.80200

.74491

.75808

.77083

.78313

.79500

.73668

.75019

.76326

.77589

.78808

.72859

.74241

.75580

.76874

.78125

.72061

.73474

.74844

.76169

.77450

.71276

.72719

.74118

.75473

.76783

.70503

.71974

.73402

.74786

.76125

.83360

.84308

.85182

.85985

.86732

.82668

.83650

.84556

.85390

.86164

.81985

.83000

.83937

.84800

.85601

.81309

.82357

.83325

.84215

.85044

.80642

.81721

.82718

.83637

.84491

.79982

.81092

.82119

.83064

.83944

.79330

.80470

.81525

.82497

.83402

.78685

.79855

.80937

.81936

.82865

.78048

.79246

.80356

.81379

.82333

.77418

.78645

.79780

.80829

.81806

1999–20 I.R.B.

May 17, 1999

BASED ON LIFE TABLE 90CM

UNITRUST SINGLE LIFE REMAINDER FACTORS

APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE

4.2%

4.4%

4.6%

4.8%

5.0%

5.2%

5.4%

5.6%

5.8%

6.0%

.87437

.88097

.88708

.89280

.89836

.86895

.87582

.88216

.88810

.89388

.86359

.87070

.87727

.88343

.88943

.85827

.86563

.87243

.87880

.88501

.85300

.86060

.86762

.87420

.88062

.84778

.85561

.86285

.86964

.87626

.84260

.85066

.85811

.86511

.87193

.83746

.84575

.85341

.86061

.86763

.83237

.84088

.84875

.85614

.86336

.82733

.83605

.84413

.85171

.85911

100

101

102

103

104

.90375

.90905

.91424

.91939

.92485

.89948

.90500

.91040

.91575

.92144

.89525

.90097

.90658

.91214

.91805

.89103

.89696

.90278

.90854

.91467

.88685

.89298

.89900

.90496

.91131

.88269

.88902

.89524

.90139

.90796

.87856

.88509

.89150

.89785

.90463

.87445

.88118

.88778

.89432

.90131

.87037

.87729

.88408

.89081

.89800

.86632

.87342

.88040

.88732

.89471

105

106

107

108

109

.93020

.93701

.94522

.95782

.97900

.92701

.93411

.94268

.95583

.97800

.92383

.93122

.94013

.95385

.97700

.92067

.92834

.93760

.95187

.97600

.91751

.92546

.93507

.94989

.97500

.91437

.92260

.93254

.94791

.97400

.91125

.91974

.93002

.94593

.97300

.90813

.91689

.92750

.94396

.97200

.90502

.91405

.92499

.94199

.97100

.90193

.91122

.92249

.94002

.97000

May 17, 1999

1999–20 I.R.B.

TABLE U(1)

BASED ON LIFE TABLE 90CM

UNITRUST SINGLE LIFE REMAINDER FACTORS

APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE

6.2%

6.4%

6.6%

6.8%

7.0%

7.2%

7.4%

7.6%

7.8%

8.0%

.02693

.01922

.01975

.02056

.02155

.02534

.01756

.01802

.01876

.01967

.02395

.01610

.01650

.01717

.01800

.02271

.01480

.01514

.01575

.01652

.02161

.01365

.01393

.01449

.01520

.02063

.01263

.01286

.01336

.01401

.01976

.01171

.01190

.01235

.01296

.01898

.01090

.01104

.01145

.01201

.01828

.01017

.01028

.01064

.01116

.01765

.00951

.00959

.00992

.01039

.02266

.02389

.02522

.02665

.02821

.02071

.02184

.02309

.02444

.02590

.01896

.02003

.02120

.02246

.02384

.01741

.01841

.01950

.02069

.02199

.01603

.01696

.01799

.01910

.02033

.01479

.01566

.01663

.01768

.01884

.01368

.01450

.01540

.01640

.01750

.01269

.01345

.01431

.01524

.01629

.01179

.01251

.01332

.01420

.01520

.01098

.01166

.01242

.01326

.01421

.02990

.03172

.03365

.03566

.03770

.02750

.02922

.03106

.03297

.03490

.02535

.02698

.02872

.03054

.03237

.02342

.02497

.02663

.02835

.03010

.02169

.02316

.02474

.02638

.02804

.02013

.02153

.02303

.02460

.02619

.01872

.02006

.02149

.02299

.02450

.01745

.01872

.02010

.02154

.02298

.01631

.01752

.01884

.02021

.02159

.01526

.01643

.01769

.01901

.02033

.03973

.04173

.04372

.04573

.04780

.03682

.03871

.04059

.04248

.04443

.03419

.03598

.03775

.03953

.04137

.03182

.03352

.03519

.03686

.03859

.02968

.03129

.03287

.03444

.03607

.02775

.02926

.03076

.03224

.03378

.02599

.02743

.02884

.03024

.03169

.02439

.02576

.02710

.02842

.02978

.02294

.02424

.02551

.02676

.02804

.02162

.02286

.02406

.02524

.02646

.04997

.05226

.05465

.05716

.05983

.04647

.04862

.05088

.05325

.05578

.04329

.04532

.04745

.04969

.05208

.04040

.04232

.04432

.04645

.04871

.03778

.03958

.04148

.04348

.04562

.03539

.03709

.03888

.04077

.04280

.03321

.03481

.03650

.03830

.04021

.03122

.03274

.03433

.03603

.03784

.02940

.03083

.03234

.03394

.03566

.02773

.02909

.03052

.03203

.03367

.06266

.06566

.06887

.07225

.07581

.05846

.06131

.06436

.06758

.07099

.05463

.05734

.06024

.06331

.06656

.05112

.05369

.05646

.05938

.06248

.04791

.05035

.05298

.05577

.05873

.04497

.04729

.04979

.05245

.05528

.04227

.04448

.04686

.04940

.05210

.03980

.04189

.04416

.04658

.04916

.03752

.03951

.04168

.04398

.04645

.03543

.03732

.03939

.04159

.04394

.07956

.08348

.08761

.09195

.09651

.07457

.07833

.08228

.08645

.09082

.06998

.07358

.07736

.08136

.08557

.06575

.06920

.07282

.07666

.08070

.06186

.06515

.06863

.07231

.07619

.05827

.06142

.06475

.06828

.07200

.05495

.05797

.06116

.06454

.06812

.05189

.05478

.05783

.06108

.06452

.04906

.05182

.05475

.05786

.06117

.04644

.04908

.05189

.05488

.05805

.10131

.10635

.11165

.11722

.12308

.09545

.10031

.10542

.11081

.11648

.09002

.09470

.09963

.10484

.11032

.08498

.08949

.09424

.09927

.10458

.08030

.08465

.08923

.09409

.09922

.07596

.08015

.08457

.08926

.09422

.07193

.07596

.08022

.08475

.08955

.06818

.07206

.07617

.08054

.08518

.06469

.06842

.07238

.07661

.08109

.06144

.06503

.06885

.07293

.07726

1999–20 I.R.B.

May 17, 1999

TABLE U(1)

BASED ON LIFE TABLE 90CM

UNITRUST SINGLE LIFE REMAINDER FACTORS

APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE

6.2%

6.4%

6.6%

6.8%

7.0%

7.2%

7.4%

7.6%

7.8%

8.0%

.12925

.13575

.14259

.14977

.15731

.12246

.12877

.13542

.14242

.14976

.11612

.12225

.12871

.13552

.14269

.11020

.11614

.12243

.12905

.13604

.10466

.11043

.11654

.12298

.12979

.09949

.10508

.11101

.11729

.12391

.09465

.10007

.10583

.11193

.11838

.09011

.09537

.10097

.10690

.11318

.08587

.09097

.09640

.10217

.10828

.08189

.08683

.09210

.09771

.10367

.16516

.17334

.18184

.19066

.19981

.15743

.16544

.17375

.18240

.19138

.15017

.15800

.16613

.17461

.18342

.14334

.15099

.15895

.16724

.17588

.13691

.14438

.15217

.16029

.16875

.13086

.13816

.14576

.15371

.16201

.12516

.13228

.13972

.14749

.15562

.11979

.12674

.13400

.14161

.14956

.11472

.12150

.12860

.13604

.14383

.10994

.11656

.12349

.13077

.13839

.20931

.21917

.22933

.23981

.25060

.20072

.21042

.22043

.23076

.24141

.19259

.20212

.21198

.22216

.23267

.18489

.19426

.20395

.21399

.22434

.17759

.18679

.19633

.20621

.21642

.17067

.17971

.18909

.19881

.20886

.16412

.17299

.18220

.19176

.20166

.15790

.16660

.17566

.18506

.19480

.15199

.16054

.16943

.17867

.18826

.14639

.15477

.16350

.17258

.18201

.26171

.27313

.28487

.29688

.30913

.25239

.26369

.27531

.28722

.29937

.24351

.25468

.26618

.27798

.29002

.23504

.24608

.25746

.26914

.28107

.22697

.23787

.24912

.26067

.27249

.21927

.23003

.24114

.25257

.26427

.21192

.22254

.23351

.24481

.25639

.20491

.21538

.22621

.23738

.24882

.19821

.20854

.21923

.23025

.24157

.19182

.20199

.21254

.22343

.23461

.32159

.33429

.34728

.36057

.37412

.31175

.32437

.33730

.35053

.36404

.30231

.31485

.32770

.34087

.35433

.29325

.30571

.31847

.33157

.34498

.28457

.29692

.30960

.32262

.33596

.27623

.28848

.30106

.31400

.32726

.26823

.28037

.29285

.30569

.31887

.26055

.27257

.28495

.29769

.31078

.25317

.26507

.27734

.28998

.30298

.24608

.25786

.27001

.28255

.29545

.38794

.40205

.41650

.43126

.44628

.46150

.37783

.39193

.40639

.42117

.43622

.45149

.36809

.38216

.39661

.41139

.42648

.44178

.35868

.37272

.38715

.40193

.41703

.43236

.34961

.36361

.37800

.39277

.40787

.42321

.34085

.35479

.36915

.38390

.39898

.41433

.33239

.34628

.36059

.37530

.39037

.40571

.32422

.33804

.35230

.36697

.38201

.39735

.31633

.33008

.34428

.35890

.37391

.38922

.30871

.32238

.33651

.35108

.36604

.38132

.47683

.49225

.50770

.52324

.46689

.48238

.49793

.51358

.45723

.47279

.48841

.50416

.44785

.46346

.47915

.49498

.43873

.45439

.47013

.48603

.42987

.44556

.46135

.47731

.42126

.43697

.45280

.46880

.41290

.42862

.44447

.46051

.40476

.42048

.43635

.45242

.39685

.41257

.42844

.44454

.53894

.55483

.57091

.58716

.60346

.52939

.54543

.56167

.57809

.59459

.52008

.53624

.55263

.56922

.58590

.51100

.52728

.54380

.56053

.57738

.50214

.51852

.53516

.55203

.56904

.49349

.50996

.52671

.54372

.56086

.48505

.50160

.51845

.53557

.55286

.47681

.49344

.51038

.52760

.54501

.46877

.48546

.50247

.51980

.53732

.46092

.47766

.49475

.51216

.52978

May 17, 1999

1999–20 I.R.B.

TABLE U(1)

BASED ON LIFE TABLE 90CM

UNITRUST SINGLE LIFE REMAINDER FACTORS

APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE

6.2%

6.4%

6.6%

6.8%

7.0%

7.2%

7.4%

7.6%

7.8%

8.0%

.61969

.63571

.65146

.66693

.68222

.61102

.62726

.64324

.65893

.67447

.60252

.61897

.63515

.65108

.66684

.59419

.61082

.62722

.64335

.65934

.58601

.60283

.61942

.63575

.65195

.57800

.59499

.61176

.62828

.64468

.57014

.58729

.60423

.62093

.63753

.56243

.57974

.59683

.61371

.63049

.55487

.57232

.58957

.60660

.62356

.54745

.56503

.58242

.59962

.61674

.69742

.71241

.72696

.74108

.75475

.68993

.70517

.72000

.73438

.74832

.68255

.69805

.71313

.72777

.74198

.67528

.69102

.70635

.72125

.73571

.66812

.68410

.69967

.71480

.72951

.66106

.67727

.69307

.70845

.72339

.65411

.67054

.68656

.70217

.71734

.64727

.66390

.68014

.69597

.71137

.64053

.65736

.67381

.68985

.70547

.63389

.65091

.66756

.68380

.69963

.76796

.78049

.79211

.80283

.81283

.76180

.77460

.78647

.79743

.80765

.75572

.76878

.78089

.79208

.80253

.74971

.76302

.77537

.78679

.79744

.74376

.75732

.76990

.78154

.79240

.73788

.75168

.76449

.77634

.78741

.73207

.74610

.75913

.77119

.78247

.72633

.74058

.75383

.76610

.77756

.72065

.73512

.74858

.76105

.77270

.71503

.72972

.74338

.75604

.76789

.82233

.83126

.83953

.84731

.85490

.81737

.82651

.83498

.84294

.85071

.81245

.82180

.83046

.83860

.84656

.80757

.81712

.82597

.83429

.84243

.80274

.81248

.82152

.83002

.83832

.79795

.80788

.81710

.82577

.83425

.79320

.80332

.81271

.82155

.83020

.78849

.79880

.80836

.81737

.82618

.78382

.79431

.80404

.81321

.82219

.77918

.78985

.79976

.80908

.81822

100

101

102

103

104

.86229

.86958

.87674

.88384

.89143

.85828

.86575

.87310

.88038

.88817

.85431

.86195

.86947

.87694

.88492

.85035

.85818

.86587

.87351

.88169

.84642

.85442

.86229

.87010

.87847

.84252

.85069

.85873

.86671

.87526

.83864

.84698

.85518

.86334

.87207

.83478

.84329

.85166

.85998

.86889

.83095

.83962

.84815

.85663

.86573

.82714

.83597

.84466

.85331

.86258

105

106

107

108

109

.89885

.90840

.91999

.93805

.96900

.89578

.90559

.91750

.93609

.96800

.89272

.90278

.91501

.93412

.96700

.88967

.89999

.91253

.93216

.96600

.88664

.89720

.91005

.93020

.96500

.88361

.89442

.90758

.92824

.96400

.88060

.89165

.90511

.92629

.96300

.87760

.88888

.90265

.92434

.96200

.87461

.88613

.90019

.92239

.96100

.87163

.88338

.89774

.92044

.96000

1999–20 I.R.B.

May 17, 1999

TABLE U(1)

BASED ON LIFE TABLE 90CM

UNITRUST SINGLE LIFE REMAINDER FACTORS

APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE

8.2%

8.4%

8.6%

8.8%

9.0%

9.2%

9.4%

9.6%

9.8%

10.0%

.01709

.00892

.00896

.00926

.00970

.01658

.00839

.00840

.00867

.00908

.01612

.00791

.00790

.00814

.00851

.01570

.00747

.00744

.00765

.00800

.01532

.00708

.00702

.00721

.00753

.01497

.00672

.00664

.00681

.00711

.01466

.00639

.00629

.00644

.00672

.01437

.00609

.00598

.00611

.00636

.01410

.00582

.00569

.00580

.00604

.01386

.00557

.00542

.00552

.00574

.01026

.01089

.01161

.01241

.01331

.00960

.01019

.01088

.01163

.01249

.00900

.00956

.01021

.01093

.01175

.00846

.00899

.00960

.01029

.01107

.00796

.00846

.00905

.00970

.01045

.00751

.00799

.00854

.00917

.00988

.00710

.00755

.00808

.00867

.00936

.00672

.00715

.00765

.00822

.00889

.00637

.00678

.00726

.00781

.00845

.00606

.00644

.00690

.00743

.00804

.01432

.01543

.01664

.01791

.01918

.01346

.01453

.01569

.01691

.01813

.01268

.01370

.01482

.01600

.01717

.01196

.01295

.01403

.01516

.01629

.01131

.01226

.01330

.01440

.01548

.01071

.01162

.01263

.01369

.01474

.01016

.01104

.01202

.01304

.01406

.00965

.01051

.01145

.01245

.01343

.00918

.01001

.01093

.01190

.01285

.00875

.00956

.01045

.01139

.01231

.02041

.02160

.02274

.02386

.02500

.01931

.02044

.02152

.02258

.02367

.01831

.01938

.02041

.02142

.02245

.01738

.01841

.01940

.02035

.02132

.01653

.01752

.01846

.01936

.02029

.01576

.01670

.01760

.01846

.01933

.01504

.01595

.01680

.01762

.01845

.01437

.01525

.01607

.01685

.01764

.01376

.01460

.01539

.01613

.01689

.01320

.01401

.01476

.01547

.01619

.02621

.02749

.02884

.03028

.03183

.02481

.02603

.02730

.02867

.03013

.02353

.02468

.02589

.02718

.02857

.02235

.02344

.02458

.02581

.02713

.02126

.02229

.02338

.02454

.02580

.02025

.02124

.02227

.02337

.02456

.01933

.02026

.02124

.02229

.02342

.01847

.01936

.02029

.02128

.02236

.01768

.01852

.01940

.02035

.02138

.01694

.01774

.01859

.01949

.02047

.03350

.03530

.03727

.03937

.04162

.03172

.03344

.03532

.03732

.03947

.03008

.03172

.03351

.03543

.03748

.02857

.03013

.03183

.03367

.03564

.02717

.02865

.03028

.03204

.03392

.02587

.02729

.02885

.03052

.03233

.02467

.02602

.02751

.02911

.03084

.02355

.02484

.02627

.02780

.02946

.02251

.02375

.02511

.02658

.02818

.02155

.02273

.02404

.02545

.02698

.04401

.04654

.04923

.05210

.05515

.04176

.04419

.04676

.04952

.05245

.03967

.04200

.04447

.04711

.04993

.03773

.03996

.04233

.04487

.04758

.03593

.03807

.04034

.04278

.04538

.03425

.03630

.03849

.04083

.04333

.03269

.03466

.03676

.03901

.04142

.03124

.03312

.03514

.03731

.03962

.02988

.03169

.03363

.03571

.03794

.02861

.03035

.03221

.03422

.03637

.05841

.06187

.06555

.06949

.07368

.05558

.05892

.06247

.06627

.07032

.05295

.05616

.05958

.06325

.06717

.05048

.05358

.05688

.06043

.06421

.04818

.05116

.05435

.05777

.06143

.04603

.04890

.05198

.05528

.05882

.04401

.04678

.04975

.05295

.05637

.04212

.04480

.04766

.05075

.05406

.04035

.04293

.04570

.04868

.05189

.03869

.04118

.04385

.04674

.04984

May 17, 1999

1999–20 I.R.B.

TABLE U(1)

BASED ON LIFE TABLE 90CM

UNITRUST SINGLE LIFE REMAINDER FACTORS

APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE

8.2%

8.4%

8.6%

8.8%

9.0%

9.2%

9.4%

9.6%

9.8%

10.0%

.07816

.08295

.08807

.09352

.09932

.07465

.07930

.08427

.08957

.09521

.07137

.07587

.08069

.08585

.09134

.06827

.07264

.07733

.08233

.08768

.06537

.06960

.07415

.07902

.08423

.06263

.06674

.07116

.07589

.08096

.06006

.06405

.06833

.07294

.07787

.05764

.06150

.06567

.07014

.07495

.05535

.05910

.06315

.06750

.07218

.05320

.05683

.06077

.06500

.06956

.10543

.11189

.11866

.12577

.13323

.10117

.10747

.11408

.12103

.12833

.09715

.10329

.10974

.11654

.12368

.09334

.09933

.10564

.11228

.11926

.08974

.09559

.10174

.10823

.11506

.08634

.09204

.09805

.10439

.11107

.08311

.08867

.09454

.10074

.10728

.08005

.08548

.09121

.09727

.10366

.07716

.08245

.08805

.09397

.10022

.07441

.07958

.08504

.09083

.09695

.14107

.14928

.15785

.16678

.17606

.13601

.14407

.15248

.16124

.17037

.13120

.13910

.14735

.15597

.16493

.12663

.13437

.14247

.15093

.15974

.12228

.12987

.13781

.14612

.15478

.11813

.12558

.13337

.14153

.15004

.11419

.12149

.12913

.13714

.14550

.11043

.11758

.12508

.13294

.14116

.10685

.11386

.12122

.12893

.13700

.10344

.11031

.11752

.12509

.13302

.18570

.19573

.20613

.21688

.22793

.17986

.18974

.20000

.21060

.22151

.17428

.18400

.19412

.20458

.21535

.16893

.17851

.18848

.19880

.20943

.16382

.17325

.18307

.19325

.20374

.15893

.16821

.17789

.18792

.19827

.15424

.16338

.17291

.18280

.19301

.14976

.15875

.16814

.17788

.18795

.14546

.15430

.16355

.17316

.18309

.14134

.15004

.15914

.16861

.17840

.23927

.25092

.26295

.27538

.28817

.23272

.24425

.25616

.26847

.28116

.22642

.23782

.24961

.26180

.27438

.22036

.23163

.24329

.25537

.26783

.21454

.22567

.23721

.24916

.26150

.20893

.21993

.23134

.24316

.25539

.20354

.21440

.22568

.23738

.24949

.19834

.20907

.22021

.23179

.24377

.19334

.20393

.21494

.22639

.23825

.18851

.19898

.20985

.22117

.23291

.30134

.31493

.32899

.34349

.35841

.37366

.29423

.30772

.32170

.33614

.35100

.36620

.28735

.30075

.31464

.32901

.34381

.35896

.28069

.29399

.30780

.32209

.33683

.35193

.27426

.28746

.30118

.31538

.33005

.34509

.26803

.28113

.29475

.30887

.32346

.33844

.26201

.27500

.28852

.30256

.31707

.33197

.25618

.26906

.28248

.29643

.31085

.32568

.25054

.26331

.27663

.29047

.30481

.31957

.24508

.25774

.27095

.28469

.29894

.31362

.38916

.40486

.42074

.43685

.38167

.39736

.41323

.42934

.37440

.39006

.40591

.42202

.36732

.38295

.39878

.41488

.36043

.37602

.39182

.40791

.35372

.36927

.38504

.40110

.34720

.36270

.37843

.39446

.34084

.35629

.37198

.38798

.33466

.35005

.36568

.38165

.32864

.34396

.35955

.37547

.45326

.47004

.48718

.50467

.52239

.44577

.46259

.47979

.49735

.51515

.43846

.45530

.47255

.49017

.50806

.43132

.44818

.46547

.48314

.50110

.42435

.44122

.45853

.47626

.49427

.41754

.43442

.45175

.46951

.48758

.41088

.42776

.44511

.46290

.48102

.40438

.42125

.43861

.45643

.47459

.39802

.41488

.43225

.45008

.46828

.39181

.40865

.42601

.44386

.46209

1999–20 I.R.B.

May 17, 1999

TABLE U(1)

BASED ON LIFE TABLE 90CM

UNITRUST SINGLE LIFE REMAINDER FACTORS

APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE

8.2%

8.4%

8.6%

8.8%

9.0%

9.2%

9.4%

9.6%

9.8%

10.0%

.54018

.55788

.57540

.59274

.61002

.53304

.55085

.56851

.58598

.60341

.52603

.54396

.56173

.57933

.59690

.51916

.53718

.55506

.57279

.59049

.51242

.53053

.54851

.56635

.58418

.50580

.52399

.54207

.56001

.57796

.49930

.51757

.53574

.55378

.57184

.49292

.51126

.52951

.54765

.56582

.48666

.50507

.52339

.54161

.55988

.48052

.49898

.51737

.53567

.55403

.62734

.64455

.66139

.67783

.69387

.62090

.63828

.65531

.67194

.68817

.61454

.63210

.64930

.66612

.68254

.60828

.62600

.64337

.66037

.67698

.60211

.61999

.63752

.65469

.67148

.59603

.61406

.63175

.64908

.66605

.59004

.60821

.62605

.64354

.66068

.58414

.60244

.62043

.63807

.65537

.57832

.59675

.61488

.63267

.65012

.57258

.59113

.60939

.62733

.64493

.70947

.72437

.73823

.75109

.76312

.70398

.71908

.73314

.74618

.75839

.69855

.71385

.72810

.74132

.75370

.69318

.70867

.72310

.73650

.74905

.68786

.70354

.71816

.73173

.74445

.68261

.69847

.71326

.72700

.73988

.67742

.69345

.70841

.72232

.73536

.67228

.68848

.70361

.71768

.73087

.66719

.68357

.69886

.71308

.72643

.66217

.67870

.69415

.70852

.72202

.77459

.78543

.79550

.80498

.81428

.77004

.78105

.79128

.80091

.81036

.76552

.77670

.78709

.79687

.80647

.76104

.77238

.78293

.79286

.80261

.75660

.76810

.77880

.78888

.79877

.75220

.76386

.77470

.78492

.79496

.74783

.75964

.77063

.78099

.79117

.74350

.75546

.76659

.77709

.78741

.73920

.75131

.76258

.77322

.78367

.73494

.74720

.75860

.76937

.77995

100

101

102

103

104

.82336

.83234

.84119

.84999

.85944

.81959

.82873

.83774

.84670

.85632

.81586

.82515

.83431

.84342

.85321

.81214

.82158

.83089

.84016

.85011

.80845

.81804

.82750

.83691

.84703

.80478

.81451

.82412

.83368

.84396

.80113

.81101

.82076

.83046

.84090

.79751

.80753

.81742

.82726

.83786

.79390

.80406

.81409

.82408

.83483

.79032

.80062

.81078

.82091

.83182

105

106

107

108

109

.86866

.88065

.89530

.91849

.95900

.86570

.87792

.89286

.91654

.95800

.86276

.87520

.89042

.91460

.95700

.85982

.87248

.88799

.91266

.95600

.85690

.86978

.88557

.91072

.95500

.85399

.86708

.88315

.90879

.95400

.85109

.86440

.88073

.90685

.95300

.84820

.86172

.87833

.90492

.95200

.84532

.85905

.87592

.90299

.95100

.84245

.85638

.87352

.90106

.95000

May 17, 1999

1999–20 I.R.B.

TABLE U(1)

BASED ON LIFE TABLE 90CM

UNITRUST SINGLE LIFE REMAINDER FACTORS

APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE

10.2%

10.4%

10.6%

10.8%

11.0%

11.2%

11.4%

11.6%

11.8%

12.0%

.01363

.00534

.00518

.00526

.00546

.01342

.00512

.00495

.00502

.00521

.01323

.00493

.00474

.00480

.00497

.01305

.00474

.00455

.00459

.00475

.01288

.00458

.00437

.00440

.00455

.01272

.00442

.00421

.00422

.00436

.01258

.00427

.00405

.00406

.00419

.01244

.00414

.00391

.00402

.01231

.00401

.00377

.00376

.00387

.01219

.00389

.00365

.00363

.00373

.00576

.00613

.00657

.00707

.00766

.00549

.00584

.00626

.00675

.00732

.00524

.00557

.00598

.00644

.00699

.00501

.00532

.00571

.00616

.00669

.00479

.00509

.00547

.00590

.00641

.00459

.00488

.00524

.00565

.00615

.00440

.00468

.00502

.00542

.00591

.00423

.00449

.00482

.00521

.00568

.00406

.00432

.00464

.00501

.00547

.00391

.00415

.00446

.00482

.00527

.00835

.00913

.01000

.01091

.01181

.00798

.00874

.00959

.01048

.01135

.00764

.00838

.00920

.01007

.01092

.00732

.00804

.00884

.00969

.01052

.00702

.00772

.00851

.00933

.01014

.00675

.00743

.00819

.00900

.00979

.00649

.00715

.00790

.00869

.00947

.00624

.00689

.00762

.00840

.00916

.00602

.00665

.00737

.00813

.00887

.00580

.00642

.00712

.00787

.00860

.01267

.01345

.01418

.01486

.01554

.01218

.01294

.01364

.01429

.01494

.01173

.01246

.01313

.01375

.01438

.01130

.01201

.01266

.01326

.01385

.01091

.01160

.01222

.01279

.01336

.01054

.01121

.01181

.01236

.01291

.01019

.01084

.01143

.01196

.01248

.00987

.01050

.01107

.01158

.01208

.00956

.01018

.01073

.01122

.01170

.00928

.00988

.01041

.01088

.01135

.01626

.01702

.01782

.01868

.01962

.01562

.01635

.01711

.01793

.01883

.01503

.01573

.01645

.01724

.01809

.01448

.01514

.01584

.01658

.01740

.01396

.01460

.01526

.01597

.01675

.01348

.01409

.01472

.01540

.01615

.01303

.01361

.01422

.01487

.01558

.01260

.01316

.01374

.01437

.01505

.01220

.01274

.01330

.01390

.01455

.01183

.01235

.01288

.01345

.01408

.02065

.02178

.02303

.02439

.02585

.01981

.02089

.02209

.02339

.02480

.01903

.02006

.02122

.02247

.02382

.01830

.01929

.02040

.02160

.02290

.01762

.01856

.01963

.02079

.02204

.01698

.01789

.01891

.02002

.02123

.01638

.01725

.01824

.01931

.02047

.01581

.01665

.01760

.01863

.01976

.01528

.01609

.01700

.01800

.01908

.01478

.01556

.01644

.01740

.01845

.02742

.02910

.03089

.03282

.03489

.02631

.02793

.02965

.03151

.03350

.02527

.02683

.02849

.03028

.03220

.02430

.02579

.02739

.02912

.03097

.02339

.02482

.02636

.02803

.02982

.02253

.02391

.02540

.02701

.02873

.02172

.02306

.02449

.02604

.02771

.02096

.02225

.02363

.02513

.02674

.02025

.02149

.02282

.02427

.02583

.01957

.02077

.02206

.02346

.02497

.03713

.03953

.04211

.04490

.04791

.03567

.03798

.04048

.04318

.04609

.03429

.03653

.03894

.04155

.04437

.03299

.03515

.03748

.04001

.04274

.03177

.03386

.03611

.03856

.04120

.03061

.03263

.03481

.03719

.03975

.02953

.03148

.03359

.03589

.03837

.02850

.03039

.03243

.03466

.03707

.02753

.02936

.03134

.03350

.03583

.02661

.02838

.03030

.03239

.03466

1999–20 I.R.B.

May 17, 1999

TABLE U(1)

BASED ON LIFE TABLE 90CM

UNITRUST SINGLE LIFE REMAINDER FACTORS

APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE

10.2%

10.4%

10.6%

10.8%

11.0%

11.2%

11.4%

11.6%

11.8%

12.0%

.05116

.05469

.05851

.06263

.06707

.04924

.05267

.05638

.06039

.06472

.04742

.05075

.05436

.05827

.06248

.04571

.04894

.05245

.05625

.06035

.04408

.04722

.05063

.05433

.05834

.04254

.04559

.04891

.05252

.05642

.04108

.04405

.04728

.05079

.05459

.03970

.04258

.04573

.04915

.05286

.03839

.04119

.04425

.04759

.05121

.03714

.03987

.04285

.04610

.04963

.07180

.07685

.08218

.08784

.09382

.06933

.07425

.07946

.08499

.09085

.06698

.07178

.07687

.08228

.08801

.06474

.06943

.07440

.07969

.08530

.06262

.06720

.07205

.07722

.08271

.06059

.06507

.06981

.07487

.08024

.05867

.06304

.06768

.07262

.07788

.05684

.06110

.06564

.07047

.07562

.05509

.05926

.06369

.06842

.07346

.05342

.05750

.06183

.06646

.07140

.10018

.10691

.11399

.12142

.12921

.09707

.10367

.11061

.11791

.12556

.09410

.10057

.10738

.11454

.12206

.09127

.09761

.10429

.11132

.11870

.08856

.09477

.10132

.10823

.11548

.08597

.09206

.09849

.10526

.11239

.08349

.08946

.09577

.10242

.10942

.08112

.08697

.09316

.09969

.10657

.07885

.08459

.09066

.09707

.10383

.07667

.08231

.08826

.09456

.10120

.13738

.14595

.15491

.16424

.17390

.13359

.14202

.15084

.16004

.16955

.12995

.13824

.14693

.15599

.16537

.12646

.13462

.14317

.15209

.16134

.12311

.13113

.13955

.14834

.15746

.11989

.12778

.13607

.14473

.15371

.11679

.12456

.13272

.14125

.15010

.11382

.12146

.12949

.13789

.14662

.11096

.11847

.12638

.13465

.14325

.10820

.11560

.12338

.13153

.14001

.18387

.19420

.20494

.21613

.22774

.17939

.18958

.20020

.21126

.22274

.17507

.18513

.19561

.20654

.21791

.17091

.18084

.19119

.20199

.21322

.16689

.17669

.18691

.19758

.20869

.16302

.17268

.18277

.19331

.20429

.15927

.16881

.17877

.18918

.20004

.15566

.16506

.17490

.18518

.19592

.15217

.16145

.17115

.18131

.19192

.14880

.15795

.16753

.17757

.18805

.23979

.25233

.26543

.27908

.29324

.30783

.23467

.24709

.26009

.27363

.28769

.30219

.22971

.24202

.25489

.26833

.28230

.29671

.22490

.23709

.24985

.26319

.27705

.29137

.22025

.23231

.24496

.25819

.27195

.28618

.21573

.22767

.24021

.25332

.26699

.28112

.21135

.22318

.23560

.24860

.26216

.27619

.20710

.21881

.23111

.24400

.25746

.27139

.20299

.21457

.22676

.23954

.25288

.26672

.19899

.21045

.22252

.23519

.24843

.26216

.32277

.33803

.35356

.36943

.31706

.33225

.34772

.36354

.31150

.32661

.34201

.35778

.30608

.32112

.33645

.35215

.30079

.31575

.33101

.34666

.29564

.31052

.32571

.34129

.29063

.30542

.32053

.33604

.28573

.30044

.31547

.33091

.28096

.29559

.31053

.32590

.27631

.29084

.30571

.32100

.38574

.40256

.41991

.43777

.45602

.37980

.39660

.41394

.43180

.45007

.37400

.39076

.40808

.42594

.44422

.36833

.38505

.40235

.42020

.43849

.36278

.37947

.39674

.41457

.43287

.35735

.37400

.39124

.40906

.42735

.35205

.36864

.38585

.40365

.42193

.34686

.36340

.38056

.39834

.41661

.34178

.35827

.37539

.39314

.41139

.33681

.35324

.37032

.38803

.40627

May 17, 1999

1999–20 I.R.B.

TABLE U(1)

BASED ON LIFE TABLE 90CM

UNITRUST SINGLE LIFE REMAINDER FACTORS

APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE

10.2%

10.4%

10.6%

10.8%

11.0%

11.2%

11.4%

11.6%

11.8%

12.0%

.47449

.49300

.51145

.52983

.46856

.48712

.50563

.52407

.46275

.48134

.49990

.51841

.45704

.47566

.49427

.51284

.45143

.47008

.48873

.50735

.44592

.46460

.48328

.50195

.44051

.45921

.47792

.49663

.43519

.45391

.47265

.49139

.42997

.44870

.46746

.48624

.42484

.44357

.46235

.48116

.54828

.56693

.58560

.60398

.62206

.63980

.54261

.56135

.58013

.59864

.61685

.63474

.53702

.55586

.57474

.59337

.61170

.62972

.53151

.55044

.56943

.58817

.60662

.62477

.52609

.54510

.56418

.58303

.60159

.61987

.52075

.53983

.55901

.57795

.59663

.61503

.51549

.53464

.55390

.57294

.59173

.61024

.51030

.52952

.54886

.56799

.58688

.60551

.50519

.52447

.54389

.56310

.58209

.60083

.50015

.51949

.53898

.55828

.57736

.59620

.65719

.67388

.68949

.70401

.71765

.65227

.66912

.68487

.69954

.71332

.64741

.66440

.68030

.69511

.70902

.64259

.65973

.67577

.69072

.70477

.63783

.65511

.67129

.68637

.70055

.63312

.65053

.66685

.68205

.69636

.62846

.64600

.66245

.67778

.69222

.62385

.64152

.65809

.67355

.68810

.61928

.63708

.65378

.66935

.68403

.61477

.63269

.64950

.66519

.67998

.73072

.74311

.75465

.76555

.77626

.72653

.73906

.75073

.76175

.77260

.72237

.73504

.74684

.75798

.76895

.71825

.73105

.74297

.75424

.76534

.71416

.72709

.73914

.75052

.76174

.71010

.72316

.73533

.74683

.75817

.70608

.71926

.73155

.74317

.75462

.70209

.71539

.72780

.73953

.75109

.69813

.71155

.72407

.73591

.74759

.69421

.70774

.72037

.73232

.74411

100

101

102

103

104

.78676

.79719

.80749

.81775

.82881

.78323

.79379

.80422

.81461

.82582

.77971

.79040

.80096

.81149

.82284

.77622

.78703

.79772

.80838

.81988

.77274

.78368

.79450

.80529

.81693

.76929

.78035

.79130

.80221

.81399

.76586

.77704

.78811

.79914

.81106

.76245

.77375

.78494

.79609

.80815

.75906

.77048

.78178

.79306

.80525

.75569

.76722

.77864

.79003

.80236

105

106

107

108

109

.83959

.85373

.87113

.89913

.94900

.83674

.85108

.86875

.89721

.94800

.83391

.84844

.86636

.89529

.94700

.83108

.84581

.86399

.89337

.94600

.82826

.84319

.86161

.89145

.94500

.82546

.84058

.85925

.88953

.94400

.82267

.83797

.85689

.88762

.94300

.81988

.83537

.85453

.88571

.94200

.81711

.83278

.85218

.88380

.94100

.81435

.83020

.84984

.88189

.94000

1999–20 I.R.B.

May 17, 1999

TABLE U(1)

BASED ON LIFE TABLE 90CM

UNITRUST SINGLE LIFE REMAINDER FACTORS

APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE

12.2%

12.4%

12.6%

12.8%

13.0%

13.2%

13.4%

13.6%

13.8%

14.0%

.01208

.00378

.00353

.00350

.00359

.01197

.00367

.00342

.00339

.00347

.01187

.00358

.00331

.00327

.00335

.01177

.00348

.00322

.00317

.00324

.01168

.00340

.00312

.00307

.00313

.01159

.00331

.00304

.00298

.00303

.01151

.00323

.00295

.00289

.00294

.01143

.00316

.00288

.00281

.00285

.01135

.00309

.00280

.00273

.00276

.01128

.00302

.00273

.00265

.00268

.00377

.00400

.00430

.00465

.00508

.00363

.00386

.00414

.00448

.00490

.00351

.00372

.00400

.00432

.00473

.00339

.00359

.00386

.00417

.00457

.00327

.00347

.00373

.00403

.00442

.00317

.00335

.00360

.00390

.00428

.00306

.00325

.00349

.00378

.00414

.00297

.00314

.00338

.00366

.00402

.00288

.00305

.00327

.00354

.00389

.00279

.00295

.00317

.00344

.00378

.00560

.00620

.00689

.00763

.00834

.00541

.00600

.00668

.00740

.00810

.00523

.00581

.00647

.00718

.00787

.00506

.00563

.00628

.00698

.00766

.00490

.00546

.00610

.00678

.00745

.00475

.00529

.00593

.00660

.00726

.00460

.00514

.00576

.00642

.00707

.00446

.00499

.00560

.00626

.00689

.00433

.00485

.00545

.00610

.00673

.00421

.00472

.00531

.00595

.00657

.00901

.00959

.01011

.01057

.01101

.00875

.00932

.00983

.01027

.01070

.00851

.00907

.00956

.00999

.01040

.00828

.00883

.00930

.00972

.01012

.00807

.00860

.00907

.00947

.00985

.00786

.00839

.00884

.00923

.00960

.00767

.00818

.00862

.00900

.00936

.00748

.00799

.00842

.00879

.00914

.00730

.00780

.00822

.00858

.00892

.00714

.00762

.00804

.00839

.00871

.01148

.01197

.01249

.01304

.01364

.01115

.01162

.01211

.01264

.01322

.01083

.01129

.01176

.01227

.01283

.01054

.01098

.01143

.01192

.01246

.01026

.01068

.01112

.01159

.01210

.00999

.01040

.01082

.01127

.01177

.00974

.01014

.01054

.01098

.01145

.00950

.00988

.01027

.01069

.01115

.00927

.00964

.01002

.01042

.01087

.00905

.00941

.00978

.01017

.01060

.01431

.01506

.01591

.01684

.01785

.01387

.01459

.01541

.01631

.01728

.01345

.01415

.01494

.01580

.01675

.01306

.01373

.01449

.01533

.01624

.01268

.01333

.01407

.01488

.01577

.01233

.01295

.01367

.01445

.01531

.01199

.01260

.01329

.01405

.01488

.01168

.01226

.01293

.01367

.01447

.01137

.01194

.01259

.01330

.01408

.01109

.01163

.01226

.01296

.01372

.01893

.02010

.02134

.02270

.02415

.01833

.01946

.02066

.02197

.02338

.01776

.01885

.02002

.02128

.02265

.01723

.01828

.01940

.02063

.02195

.01672

.01773

.01883

.02002

.02130

.01623

.01722

.01828

.01943

.02067

.01578

.01673

.01776

.01887

.02008

.01534

.01627

.01726

.01835

.01951

.01493

.01582

.01679

.01784

.01897

.01453

.01540

.01634

.01736

.01846

.02574

.02746

.02932

.03135

.03355

.02492

.02658

.02838

.03035

.03249

.02414

.02575

.02750

.02941

.03149

.02340

.02496

.02666

.02851

.03053

.02270

.02422

.02586

.02766

.02962

.02203

.02350

.02510

.02685

.02876

.02140

.02283

.02438

.02608

.02793

.02080

.02218

.02369

.02534

.02715

.02022

.02157

.02303

.02464

.02640

.01967

.02098

.02241

.02397

.02568

May 17, 1999

1999–20 I.R.B.

TABLE U(1)

BASED ON LIFE TABLE 90CM

UNITRUST SINGLE LIFE REMAINDER FACTORS

APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE

12.2%

12.4%

12.6%

12.8%

13.0%

13.2%

13.4%

13.6%

13.8%

14.0%

.03596

.03861

.04152

.04468

.04813

.03484

.03742

.04025

.04333

.04670

.03377

.03628

.03903

.04205

.04533

.03275

.03520

.03788

.04082

.04403

.03178

.03416

.03678

.03965

.04278

.03086

.03318

.03573

.03853

.04159

.02998

.03224

.03473

.03746

.04045

.02914

.03134

.03377

.03644

.03936

.02833

.03048

.03285

.03546

.03832

.02757

.02966

.03198

.03453

.03732

.05183

.05582

.06006

.06459

.06942

.05032

.05421

.05836

.06279

.06752

.04887

.05267

.05673

.06107

.06571

.04748

.05121

.05518

.05943

.06397

.04616

.04980

.05369

.05785

.06230

.04489

.04846

.05226

.05634

.06070

.04368

.04717

.05089

.05488

.05916

.04252

.04593

.04958

.05349

.05768

.04141

.04475

.04832

.05216

.05626

.04034

.04362

.04711

.05087

.05490

.07459

.08012

.08596

.09214

.09867

.07259

.07801

.08375

.08982

.09623

.07068

.07599

.08163

.08759

.09389

.06884

.07406

.07959

.08544

.09164

.06708

.07220

.07763

.08338

.08946

.06538

.07041

.07574

.08139

.08737

.06376

.06869

.07392

.07948

.08536

.06219

.06703

.07218

.07763

.08342

.06069

.06544

.07049

.07586

.08154

.05924

.06391

.06887

.07415

.07974

.10556

.11283

.12050

.12852

.13687

.10301

.11016

.11771

.12562

.13385

.10055

.10759

.11502

.12281

.13092

.09819

.10511

.11243

.12011

.12810

.09591

.10272

.10993

.11749

.12537

.09371

.10042

.10751

.11496

.12273

.09159

.09819

.10518

.11252

.12017

.08955

.09605

.10293

.11016

.11770

.08757

.09397

.10075

.10787

.11531

.08567

.09197

.09864

.10567

.11299

.14554

.15457

.16402

.17393

.18429

.14240

.15130

.16063

.17042

.18065

.13935

.14813

.15734

.16700

.17712

.13641

.14507

.15415

.16370

.17369

.13356

.14210

.15107

.16049

.17036

.13080

.13923

.14808

.15738

.16714

.12813

.13644

.14518

.15437

.16400

.12555

.13375

.14237

.15144

.16096

.12305

.13113

.13964

.14860

.15800

.12063

.12860

.13699

.14584

.15513

.19511

.20645

.21841

.23096

.24409

.25772

.19135

.20257

.21441

.22685

.23987

.25339

.18769

.19880

.21052

.22284

.23575

.24918

.18415

.19513

.20673

.21895

.23175

.24507

.18070

.19157

.20305

.21515

.22784

.24106

.17735

.18810

.19947

.21146

.22404

.23715

.17410

.18473

.19599

.20786

.22033

.23333

.17094

.18146

.19259

.20436

.21672

.22961

.16787

.17827

.18929

.20094

.21320

.22598

.16488

.17517

.18608

.19762

.20976

.22244

.27178

.28622

.30100

.31621

.26735

.28170

.29639

.31152

.26304

.27729

.29189

.30694

.25882

.27298

.28749

.30246

.25471

.26877

.28320

.29807

.25070

.26467

.27899

.29378

.24679

.26065

.27489

.28959

.24296

.25673

.27087

.28548

.23923

.25290

.26694

.28146

.23559

.24915

.26310

.27753

.33195

.34832

.36535

.38302

.40124

.32719

.34350

.36047

.37811

.39630

.32253

.33877

.35570

.37329

.39145

.31797

.33415

.35101

.36856

.38669

.31351

.32961

.34642

.36392

.38201

.30914

.32517

.34192

.35937

.37742

.30486

.32082

.33750

.35490

.37291

.30067

.31656

.33317

.35051

.36848

.29657

.31238

.32892

.34621

.36413

.29255

.30828

.32475

.34198

.35985

1999–20 I.R.B.

May 17, 1999

TABLE U(1)

BASED ON LIFE TABLE 90CM

UNITRUST SINGLE LIFE REMAINDER FACTORS

APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999

ADJUSTED PAYOUT RATE

AGE

12.2%

12.4%

12.6%

12.8%

13.0%

13.2%

13.4%

13.6%

13.8%

14.0%

.41980

.43854

.45733

.47616

.49519

.41485

.43358

.45238

.47123

.49030

.40998

.42871

.44752

.46638

.48548

.40520

.42392

.44273

.46161

.48073

.40050

.41921

.43802

.45690

.47604

.39588

.41457

.43338

.45227

.47143

.39134

.41001

.42881

.44770

.46688

.38688

.40553

.42431

.44320

.46239

.38249

.40112

.41989

.43877

.45797

.37818

.39678

.41553

.43441

.45361

.51458

.53413

.55351

.57268

.59162

.50974

.52935

.54881

.56806

.58710

.50496

.52463

.54416

.56349

.58262

.50025

.51998

.53957

.55898

.57819

.49560

.51538

.53503

.55451

.57382

.49102

.51084

.53055

.55010

.56949

.48650

.50636

.52613

.54574

.56520

.48204

.50194

.52176

.54144

.56097

.47763

.49758

.51744

.53718

.55678

.47329

.49327

.51317

.53296

.55263

.61030

.62834

.64527

.66107

.67597

.60588

.62403

.64107

.65699

.67200

.60151

.61977

.63692

.65294

.66806

.59718

.61554

.63280

.64893

.66415

.59290

.61136

.62872

.64495

.66027

.58866

.60722

.62468

.64101

.65643

.58447

.60312

.62068

.63711

.65262

.58032

.59907

.61672

.63323

.64884

.57621

.59505

.61279

.62940

.64509

.57214

.59107

.60890

.62559

.64138

.69031

.70396

.71670

.72875

.74065

.68645

.70021

.71305

.72521

.73721

.68262

.69648

.70943

.72169

.73379

.67881

.69279

.70584

.71819

.73040

.67504

.68912

.70227

.71472

.72703

.67130

.68548

.69872

.71127

.72368

.66759

.68186

.69520

.70784

.72035

.66390

.67828

.69171

.70444

.71704

.66025

.67471

.68824

.70106

.71375

.65662

.67118

.68480

.69770

.71048

100

101

102

103

104

.75234

.76399

.77552

.78703

.79948

.74901

.76077

.77241

.78404

.79662

.74570

.75757

.76932

.78106

.79377

.74241

.75438

.76625

.77809

.79093

.73914

.75122

.76319

.77514

.78810

.73589

.74807

.76015

.77221

.78528

.73265

.74494

.75712

.76929

.78248

.72944

.74183

.75411

.76638

.77969

.72625

.73873

.75111

.76348

.77691

.72307

.73565

.74813

.76060

.77414

105

106

107

108

109

.81159

.82763

.84749

.87999

.93900

.80885

.82506

.84516

.87808

.93800

.80612

.82250

.84283

.87618

.93700

.80340

.81995

.84051

.87428

.93600

.80069

.81741

.83819

.87238

.93500

.79799

.81488

.83587

.87049

.93400

.79530

.81235

.83356

.86859

.93300

.79262

.80983

.83126

.86670

.93200

.78995

.80732

.82896

.86481

.93100

.78729

.80482

.82666

.86293

.93000

(f) Effective dates. This section applies

after April 30, 1999.

Par. 10. The undesignated center heading immediately preceding §1.664-4A is

revised to read as follows:

Unitrust Actuarial Tables Applicable

Before May 1, 1999

Par. 11. Section 1.664-4A is amended

as follows:

1. The section heading is revised.

2. In paragraph (d)(4), the first sentence is revised.

3. In paragraph (d)(6), the introductory

text is revised and Table D is removed.

May 17, 1999

4. The heading of newly designated

paragraph (e) is revised.

5. In newly designated paragraph

(e)(1), the first sentence is revised.

6. Newly designated paragraphs (e)(3)

through (e)(5) are revised.

7. In newly designated paragraph

(e)(6), the heading and the first sentence

of the introductory text are revised and

the last sentence of introductory text is removed and two new sentences are added

in its place.

8. The heading of Table U(1) is revised.

The addition and revisions read as follows:

§1.664–4A Valuation of charitable

remainder interests for which the

valuation date is before May 1, 1999.

* * * * *

(d) * * *

(4) Period is a term of years. If the period described in §1.664-3(a)(5) is a term

of years, the factor which is used in determining the present value of the remainder

interest is the factor under the appropriate

1999–20 I.R.B.

adjusted payout rate in Table D in

§1.664–4(e)(6) that corresponds to the

number of years in the term. * * *

* * * * *

(6) Actuarial tables for transfers for

which the valuation date is after November 30, 1983, and before May 1, 1989.

Table D in §1.664–4(e)(6) and the following tables shall be used in the application

of the provisions of this section:

* * * * *

(e) Valuation of charitable remainder

unitrusts having certain payout sequences

for transfers for which the valuation date

is after April 30, 1989, and before May 1,

1999—(1) In general. Except as otherwise provided in paragraph (e)(2) of this

section, in the case of transfers for which

the valuation date is after April 30, 1989,

and before May 1, 1999, the present value

of a remainder interest is determined

under paragraphs (e)(3) through (e)(6) of

this section, provided that the amount of

the payout as of any payout date during

any taxable year of the trust is not larger

than the amount that the trust could distribute on such date under §1.6643(a)(1)(v) if the taxable year of the trust

were to end on such date. * * *

* * * * *

(3) Adjusted payout rate. For transfers

for which the valuation date is after April

30, 1989, and before May 1, 1999, the adjusted payout rate is determined by using

the appropriate Table F, contained in

§ 1.664–4(e)(6), for the section 7520 interest rate applicable to the transfer. If the

interest rate is between 4.2 and 14 percent, see §1.664–4(e)(6). If the interest

rate is below 4.2 percent or greater than

14 percent, see §1.664–4(b). See §1.664–

4(e) for rules applicable in determining

the adjusted payout rate.

(4) Period is a term of years. If the period described in §1.664–3(a)(5) is a term

of years, the factor that is used in determining the present value of the remainder

interest for transfers for which the valuation date is after April 30, 1989, and before May 1, 1999, is the factor under the

appropriate adjusted payout rate in Table

D in §1.664–4(e)(6) corresponding to the

number of years in the term. If the adjusted payout rate is an amount that is between adjusted payout rates for which factors are provided in Table D, a linear

1999–20 I.R.B.

interpolation must be made. The present

value of the remainder interest is determined by multiplying th

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