Bulletin No. 1998–47
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Bulletin No. 1998–47
November 23, 1998
Internal Revenue
bulletin
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
EXEMPT ORGANIZATIONS
Rev. Rul. 98–55, page 5.
Announcement 98–103, page 12.
1998 base period T-bill rate. The “base period T-bill rate” for
the period ending September 30, 1998, is published, as required by section 995(f) of the Code.
A list is given of organizations now classified as private foundations.
Rev. Rul. 98–56, page 5.
ADMINISTRATIVE
Earned income credit; disqualified income. Gain that is
treated as long-term capital gain under section 1231(a)(1) of
the Code is not disqualified income for purposes of the
earned income credit.
EMPLOYEE PLANS
Notice 98–56, page 9.
Weighted average interest rate update. The weighted
average interest rate for November 1998 and the resulting
permissible range of interest rates used to calculate current
liability for purposes of the full funding limitation of section
412(c)(7) of the Code are set forth.
Finding Lists begin on page 17.
Announcement Relating to Court Decisions begins on page 4.
Department of the Treasury
Internal Revenue Service
Notice 98–57, page 9.
Identification of census tracts in District of Columbia
Enterprise Zone. This notice provides the identification of
those census tracts in the District of Columbia constituting
the District of Columbia Enterprise Zone for purposes of
section 1400 of the Code and the DC Zone for purposes of
section 1400B.
Announcement 98–104, page 13.
Rev. Proc. 98–35, 1998–21 I.R.B. 6, reprinted as Publication 1220, Specifications for Filing Forms 1098, 1099,
5498, and W–2G Magnetically or Electronically, is corrected.
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The IRS Mission
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
Statement of Principles
of Internal Revenue
Tax Administration
The Service also has the responsibility of applying and
administering the law in a reasonable, practical manner.
Issues should only be raised by examining officers when
they have merit, never arbitrarily or for trading purposes.
At the same time, the examining officer should never hesitate to raise a meritorious issue. It is also important that
care be exercised not to raise an issue or to ask a court to
adopt a position inconsistent with an established Service
position.
The function of the Internal Revenue Service is to administer the Internal Revenue Code. Tax policy for raising revenue
is determined by Congress.
With this in mind, it is the duty of the Service to carry out that
policy by correctly applying the laws enacted by Congress;
to determine the reasonable meaning of various Code provisions in light of the Congressional purpose in enacting them;
and to perform this work in a fair and impartial manner, with
neither a government nor a taxpayer point of view.
Administration should be both reasonable and vigorous. It
should be conducted with as little delay as possible and
with great courtesy and considerateness. It should never
try to overreach, and should be reasonable within the
bounds of law and sound administration. It should, however, be vigorous in requiring compliance with law and it
should be relentless in its attack on unreal tax devices and
fraud.
At the heart of administration is interpretation of the Code. It
is the responsibility of each person in the Service, charged
with the duty of interpreting the law, to try to find the true
meaning of the statutory provision and not to adopt a
strained construction in the belief that he or she is “protecting the revenue.” The revenue is properly protected only
when we ascertain and apply the true meaning of the statute.
2
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Introduction
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
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 of a permanent nature 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.
With the exception of the Notice of Proposed Rulemaking
and the disbarment and suspension list included in this part,
none of these announcements are consolidated in the Cumulative Bulletins.
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.
3
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Announcement Relating to Court Decisions
It is the policy of the Internal Revenue
Service to announce at an early date
whether it will follow the holdings in certain cases. An Action on Decision is the
document making such an announcement.
An Action on Decision will be issued at
the discretion of the Service only on unappealed issues decided adverse to the
government. Generally, an Action on Decision is issued where its guidance would
be helpful to Service personnel working
with the same or similar issues. Unlike a
Treasury Regulation or a Revenue Ruling,
an Action on Decision is not an affirmative statement of Service position. It is not
intended to serve as public guidance and
may not be cited as precedent.
Actions on Decisions shall be relied
upon within the Service only as conclusions applying the law to the facts in the
particular case at the time the Action on
Decision was issued. Caution should be
exercised in extending the recommendation of the Action on Decision to similar
cases where the facts are different. Moreover, the recommendation in the Action
on Decision may be superseded by new
legislation, regulations, rulings, cases, or
Actions on Decisions.
Prior to 1991, the Service published acquiescence or nonacquiescence only in
certain regular Tax Court opinions. The
Service has expanded its acquiescence
program to include other civil tax cases
where guidance is determined to be helpful. Accordingly, the Service now may acquiesce or nonacquiesce in the holdings
of memorandum Tax Court opinions, as
well as those of the United States District
Courts, Claims Court, and Circuit Courts
of Appeal. Regardless of the court deciding the case, the recommendation of any
Action on Decision will be published in
the Internal Revenue Bulletin.
The recommendation in every Action
on Decision will be summarized as acquiescence, acquiescence in result only, or
nonacquiescence. Both “acquiescence”
and “acquiescence in result only” mean
that the Service accepts the holding of the
court in a case and that the Service will
follow it in disposing of cases with the
same controlling facts. However, “acquiescence” indicates neither approval nor
disapproval of the reasons assigned by the
court for its conclusions; whereas, “acquiescence in result only” indicates disagreement or concern with some or all of those
reasons. Nonacquiescence signifies that,
although no further review was sought,
the Service does not agree with the holding of the court and, generally, will not
follow the decision in disposing of cases
involving other taxpayers. In reference to
an opinion of a circuit court of appeals, a
nonacquiescence indicates that the Service will not follow the holding on a nationwide basis. However, the Service will
recognize the precedential impact of the
opinion on cases arising within the venue
of the deciding circuit.
The announcements published in the
weekly Internal Revenue Bulletins are
consolidated semiannually and annually.
The semiannual consolidation appears in
the first Bulletin for July and in the Cumulative Bulletin for the first half of the
year, and the annual consolidation appears in the first Bulletin for the following January and in the Cumulative Bulletin for the last half of the year.
The Commissioner does not ACQUIESCE in the following decisions:
Clark D. and Janis L. Pulliam v.
Commissioner,1
T.C. 1997–274
Fluor v. United States,2
126 F.3d 1397 (Fed. Cir. 1997)
1 Nonacquiescence relating to whether the distribution to a sole shareholder of the stock of a newly formed corporation qualified under section 355 of the Internal
Revenue Code.
2 Nonacquiescence relating to whether the taxpayer owes interest under section 6601(a) on the underpayment of its 1982 tax liability, notwithstanding that such under-
payment subsequently was eliminated by a carryback, under section 904(c), of excess foreign tax credits from its taxable year 1984.
November 23, 1998
4
1998–47 I.R.B.
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Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
Section 32.—Earned Income
26 CFR : 1.32–2: Earned income credit for taxable
years beginning after December 31, 1978.
(Also: § 1231. )
Earned income credit; disqualified
income. Gain that is treated as long-term
capital gain under section 1231(a)(1) of
the Code is not disqualified income for
purposes of the earned income credit.
Rev. Rul. 98–56
Section 32 of the Internal Revenue
Code allows an earned income credit to
eligible individuals whose income does
not exceed certain limits. Section 32(i)
denies the earned income credit to an otherwise eligible individual if the individual’s “disqualified income” exceeds a
specified level for the taxable year for
which the credit is claimed. Disqualified
income is income specified in § 32(i)(2).
Gain that is treated as long-term capital
gain under § 1231(a)(1) is not disqualified income for purposes of § 32(i).
DRAFTING INFORMATION
The principal author of this revenue
ruling is Christie J. Jacobs of the Office of
Assistant Chief Counsel (Income Tax and
Accounting). For further information regarding this revenue ruling contact Ms.
Jacobs on (202) 622-4930 (not a toll-free
call).
Section 995.—Taxation of DISC
Income to Shareholders
1998 base period T-bill rate. The
“base period T-bill rate” for the period
ending September 30, 1998, is published,
as required by section 995(f) of the Code.
Rev. Rul. 98–55
Section 995(f)(1) of the Internal Revenue Code provides that a shareholder of a
DISC shall pay interest each taxable year
in an amount equal to the product of the
shareholder’s DISC-related deferred tax
liability for the year and the “base period
T-bill rate.” Under section 995(f)(4), the
base period T-bill rate is the annual rate of
interest determined by the Secretary to be
equivalent to the average investment yield
1998–47 I.R.B.
of United States Treasury bills with maturities of 52 weeks which were auctioned
during the one-year period ending on September 30 of the calendar year ending
with (or of the most recent calendar year
ending before) the close of the taxable
year of the shareholder. The base period Tbill rate for the period ending September
30, 1998, is 5.34 percent.
Pursuant to section 6622 of the Code,
interest must be compounded daily. The
table below provides factors for compounding the base period T-bill rate daily
for any number of days in the shareholder’s taxable year (including a 52-53
week accounting period) for the 1998
base period T-bill rate. To compute the
amount of the interest charge for the
shareholder’s taxable year, multiply the
amount of the shareholder’s DISC-related
deferred tax liability (as defined in section
995(f)(2)) for that year by the base period
T-bill rate factor corresponding to the
number of days in the shareholder’s taxable year for which the interest charge is
being computed. Generally, one would
use the factor for 365 days. One would
use a different factor only if the shareholder’s taxable year for which the interest charge being determined is a short taxable year, if the shareholder uses the
52-53 week taxable year, or if the shareholder’s taxable year is a leap year.
For the base period T-bill rates for the
periods ending in prior years, see: Rev.
Rul. 86–132, 1986–2 C.B. 137; Rev. Rul.
87–129, 1987–2 C.B. 196; Rev. Rul. 88–
94, 1988–2 C.B. 301; Rev. Rul. 89–116,
1989–2 C.B. 197; Rev. Rul. 90–96, 1990–
2 C.B. 188; Rev. Rul. 91–59, 1991–2 C.B.
347; Rev. Rul. 92–98, 1992–2 C.B. 201;
Rev. Rul. 93–77, 1993–2 C.B. 253; Rev.
Rul. 94–68, 1994–2 C.B. 177; Rev. Rul.
95–77, 1995–2 C.B. 122; Rev. Rul. 96–
55, 1996–2 C.B. 57; and Rev. Rul. 97–49,
1997–48 I.R.B. 4.
DRAFTING INFORMATION
The principal author of this revenue
ruling is David Bergkuist of the Office of
the Associate Chief Counsel (International). For further information about this
revenue ruling, contact Mr. Bergkuist on
(202) 622-3850 (not a toll-free call.
5
1998 ANNUAL RATE, COMPOUNDED
DAILY
DAYS
5.34 PERCENT
FACTOR
1
2
3
4
5
.000146301
.000292624
.000438968
.000585334
.000731721
6
7
8
9
10
.000878129
.001024559
.001171010
.001317483
.001463977
11
12
13
14
15
.001610493
.001757030
.001903588
.002050168
.002196769
16
17
18
19
20
.002343392
.002490036
.002636702
.002783389
.002930098
21
22
23
24
25
.003076828
.003223579
.003370352
.003517147
.003663963
26
27
28
29
30
.003810800
.003957659
.004104539
.004251441
.004398365
31
32
33
34
35
.004545309
.004692276
.004839264
.004986273
.005133304
36
37
38
39
40
.005280356
.005427430
.005574526
.005721643
.005868781
41
42
43
44
45
.006015941
.006163122
.006310325
.006457550
.006604796
November 23, 1998
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46
47
48
49
50
.006752064
.006899353
.007046664
.007193996
.007341350
51
52
53
54
55
.007488725
.007636122
.007783541
.007930981
.008078443
56
57
58
59
60
.008225926
.008373431
.008520957
.008668505
.008816075
61
62
63
64
65
.008963666
.009111279
.009258913
.009406569
.009554247
66
67
68
69
70
.009701946
.009849667
.009997409
.010145173
.010292959
71
72
73
74
75
.010440766
.010588595
.010736445
.010884317
.011032211
76
77
78
79
80
.011180126
.011328064
.011476022
.011624003
.011772005
81
82
83
84
85
.011920028
.012068073
.012216140
.012364229
.012512339
86
87
88
89
90
.012660471
.012808625
.012956800
.013104997
.013253216
91
92
93
94
95
.013401456
.013549718
.013698002
.013846307
.013994634
96
.014142983
November 23, 1998
97
98
99
100
.014291354
.014439746
.014588160
.014736595
101
102
103
104
105
.014885053
.015033532
.015182033
.015330555
.015479099
106
107
108
109
110
.015627665
.015776253
.015924863
.016073494
.016222147
111
112
113
114
115
.016370821
.016519518
.016668236
.016816976
.016965738
116
117
118
119
120
.017114521
.017263326
.017412153
.017561002
.017709873
121
122
123
124
125
.017858765
.018007679
.018156615
.018305573
.018454552
126
127
128
129
130
.018603554
.018752577
.018901622
.019050688
.019199777
131
132
133
134
135
.019348887
.019498019
.019647173
.019796349
.019945547
136
137
138
139
140
.020094766
.020244007
.020393271
.020542555
.020691862
141
142
143
144
145
.020841191
.020990541
.021139914
.021289308
.021438724
146
147
.021588162
.021737621
6
148
149
150
.021887103
.022036607
.022186132
151
152
153
154
155
.022335679
.022485248
.022634839
.022784452
.022934087
156
157
158
159
160
.023083744
.023233422
.023383123
.023532845
.023682589
161
162
163
164
165
.023832355
.023982143
.024131953
.024281785
.024431639
166
167
168
169
170
.024581515
.024731413
.024881332
.025031274
.025181237
171
172
173
174
175
.025331223
.025481230
.025631259
.025781311
.025931384
176
177
178
179
180
.026081479
.026231596
.026381735
.026531896
.026682079
181
182
183
184
185
.026832284
.026982511
.027132760
.027283031
.027433324
186
187
188
189
190
.027583639
.027733976
.027884335
.028034716
.028185118
191
192
193
194
195
.028335543
.028485990
.028636459
.028786950
.028937463
196
197
198
.029087998
.029238555
.029389134
1998–47 I.R.B.
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Page 7
199
200
.029539735
.029690358
201
202
203
204
205
.029841003
.029991670
.030142359
.030293071
.030443804
206
207
208
209
210
.030594559
.030745337
.030896136
.031046958
.031197801
211
212
213
214
215
.031348667
.031499555
.031650464
.031801396
.031952350
216
217
218
219
220
.032103326
.032254324
.032405345
.032556387
.032707451
221
222
223
224
225
.032858538
.033009647
.033160777
.033311930
.033463105
226
227
228
229
230
.033614302
.033765521
.033916763
.034068026
.034219312
231
232
233
234
235
.034370619
.034521949
.034673301
.034824675
.034976072
236
237
238
239
240
.035127490
.035278931
.035430393
.035581878
.035733385
241
242
243
244
245
.035884914
.036036466
.036188039
.036339635
.036491253
246
247
248
249
250
.036642893
.036794555
.036946240
.037097946
.037249675
1998–47 I.R.B.
251
252
253
254
255
.037401426
.037553200
.037704995
.037856813
.038008653
256
257
258
259
260
.038160515
.038312399
.038464306
.038616234
.038768185
261
262
263
264
265
.038920158
.039072154
.039224172
.039376212
.039528274
266
267
268
269
270
.039680358
.039832465
.039984594
.040136745
.040288918
271
272
273
274
275
.040441114
.040593332
.040745572
.040897835
.041050119
276
277
278
279
280
.041202426
.041354756
.041507107
.041659481
.041811878
281
282
283
284
285
.041964296
.042116737
.042269200
.042421685
.042574193
286
287
288
289
290
.042726723
.042879276
.043031850
.043184447
.043337066
291
292
293
294
295
.043489708
.043642372
.043795058
.043947767
.044100498
296
297
298
299
300
.044253251
.044406027
.044558825
.044711645
.044864488
301
.045017353
7
302
303
304
305
.045170241
.045323151
.045476083
.045629037
306
307
308
309
310
.045782014
.045935014
.046088035
.046241080
.046394146
311
312
313
314
315
.046547235
.046700346
.046853480
.047006636
.047159815
316
317
318
319
320
.047313015
.047466239
.047619485
.047772753
.047926043
321
322
323
324
325
.048079356
.048232692
.048386050
.048539430
.048692833
326
327
328
329
330
.048846258
.048999706
.049153176
.049306668
.049460183
331
332
333
334
335
.049613721
.049767281
.049920863
.050074468
.050228095
336
337
338
339
340
.050381745
.050535417
.050689112
.050842829
.050996569
341
342
343
344
345
.051150331
.051304116
.051457923
.051611753
.051765605
346
347
348
349
350
.051919480
.052073377
.052227297
.052381239
.052535204
351
352
.052689191
.052843201
November 23, 1998
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353
354
355
.052997234
.053151289
.053305366
363
364
365
.054538798
.054693078
.054847381
356
357
358
359
360
.053459466
.053613589
.053767734
.053921901
.054076092
366
367
368
369
370
.055001707
.055156055
.055310426
.055464819
.055619235
361
362
.054230304
.054384540
371
.055773674
November 23, 1998
8
Section 1231.—Property Used
in a Trade or Business and
Involuntary Conversions
26 CFR 1.1231–1: Gains and losses from the sale
or exchange of certain property used in the trade or
business.
Is gain that is treated as long-term capital gain
under § 1231(a)(1) of the Code disqualified income
for purposes of the earned income credit. See Rev.
Rul. 98–56, page 5.
1998–47 I.R.B.
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Page 9
Part III. Administrative, Procedural, and Miscellaneous
Weighted Average Interest Rate
Update
Notice 98–56
Notice 88–73 provides guidelines for
determining the weighted average interest
rate and the resulting permissible range of
interest rates used to calculate current liability for the purpose of the full funding
limitation of § 412(c)(7) of the Internal
Revenue Code as amended by the Omnibus Budget Reconciliation Act of 1987
and as further amended by the Uruguay
Round Agreements Act, Pub. L. 103–465
(GATT).
Month
Year
Weighted
Average
November
1998
6.34
Drafting Information
The principal author of this notice is
Todd Newman of the Employee Plans Division. For further information regarding
this notice, call (202) 622-6076 between
2:30 and 3:30 p.m. Eastern time (not a
toll-free number). Mr. Newman’s number
is (202) 622-8458 (also not a toll-free
number).
D.C. Enterprise Zone / Census
Tracts
Notice 98–57
This notice identifies the census tracts
in the District of Columbia (D.C. census
tracts) constituting the District of Columbia Enterprise Zone for purposes of §
1400 of the Internal Revenue Code and
the DC Zone for purposes of § 1400B.
Those sections were added to the Code by
the Taxpayer Relief Act of 1997, Pub. L.
No. 105–34, 111 Stat. 788 (1997), effective August 5, 1997. This notice contains
(1) tables that list the D.C. census tracts
constituting the District of Columbia Enterprise Zone for purposes of § 1400 and
the DC Zone for purposes of § 1400B, (2)
a map of all of the D.C. census tracts, and
(3) a source for obtaining the location of
the boundary of each D.C. census tract.
BACKGROUND
Sections 1400 and 1400B designate
certain economically depressed census
tracts within the District of Columbia,
within which businesses are eligible for
special tax incentives.
1998–47 I.R.B.
90% to 106%
Permissible
Range
90% to 110%
Permissible
Range
5.71 to 6.72
5.71 to 6.98
Section 1400(a) provides that, except
as otherwise provided in subchapter W,
the District of Columbia Enterprise Zone
shall be treated as an empowerment zone
designated under subchapter U. The provisions of subchapter U include the designation and treatment of empowerment
zones and enterprise communities. The
special tax incentives that are available in
the District of Columbia Enterprise Zone
by reason of § 1400 include (1) a 20-percent wage credit for the first $15,000 of
certain qualified wages paid to D.C. residents who work in the District of Columbia Enterprise Zone; (2) an additional
$20,000 of expensing under § 179 for certain qualified zone property; and (3) special tax-exempt financing for certain zone
facilities.
Section 1400(b) provides that for purposes of § 1400(a), the District of Columbia Enterprise Zone means the area consisting of (1) the D.C. census tracts that
are part of an enterprise community designated under subchapter U before the date
of enactment of subchapter W, and (2) all
other D.C. census tracts for which the
poverty rate is not less than 20 percent.
Section 1400B provides that gross income does not include qualified capital
gain from the sale or exchange of any DC
Zone asset held for more than 5 years. In
general, a DC Zone asset means any DC
Zone business stock, partnership interest,
and business property. See § 1400B(b)(1).
Section 1400B(d) provides that for purposes of applying § 1400B (and for purposes of applying subchapter W and subchapter U with respect to § 1400B), the
9
The average yield on the 30-year Treasury Constant Maturities for November
1998 is 5.01 percent.
The following rates were determined
for the plan years beginning in the month
shown below.
DC Zone shall be treated as including all
D.C. census tracts for which the poverty
rate is not less than 10 percent.
IDENTIFICATION OF D.C. CENSUS
TRACTS FOR PURPOSES OF
SECTIONS 1400 AND 1400B
Table 1 identifies the D.C. census tracts
that constitute the District of Columbia
Enterprise Zone for purposes of § 1400.
It lists all D.C. census tracts having a
poverty rate of not less than 20 percent,
which include the D.C. census tracts that
are part of an enterprise community designated under subchapter U before enactment of subchapter W.
Table 2 identifies the D.C. census tracts
that constitute the DC Zone for purposes
of § 1400B. It lists all D.C. census tracts
having a poverty rate of not less than 10
percent.
The map provided identifies the approximate locations of all of the D.C. census tracts and highlights those census
tracts listed in the tables. This map and
the information in the tables were developed by the U.S. Department of Housing
and Urban Development using data from
the 1990 Census.
Information on the boundaries of each
D.C. census tract may be obtained from:
Data Management Division
D.C. Office of Planning
Government of the District of Columbia
801 North Capitol Street, NE
Washington, DC 20002
Herbert Bixhorn, Director
(202) 442-7603 (not a toll-free call)
November 23, 1998
IRB 1998-47
11/19/98 5:54 AM
Page 10
TABLE 1. D.C. CENSUS TRACTS HAVING A POVERTY RATE OF NOT LESS THAN 20 PERCENT
2.01
2.02
28.01
28.02
30.00
31.00
34.00
35.00
36.00
37.00
43.00
45.00
47.00
48.01
49.01
49.02
50.00
57.01
58.00
59.00
60.20
62.02
64.10
71.00
72.00
73.02
73.04
73.08
74.01
74.04
74.06
74.07
74.08
74.09
74.30
75.02
75.03
75.04
77.03
77.08
78.04
78.08
78.60
79.01
84.02
86.00
88.02
88.03
88.04
89.04
90.01
91.02
92.40
96.02
97.00
98.03
98.04
98.05
98.06
98.10
98.20
99.03
99.04
99.05
99.07
TABLE 2. D.C. CENSUS TRACTS HAVING A POVERTY RATE OF NOT LESS THAN 10 PERCENT
2.01
2.02
3.10
7.20
20.01
21.01
22.02
23.02
25.02
27.01
27.02
28.01
28.02
29.00
30.00
31.00
32.00
33.01
33.02
34.00
35.00
36.00
37.00
38.00
39.00
42.02
43.00
45.00
46.00
47.00
48.01
48.02
49.01
49.02
50.00
51.00
52.10
52.20
53.01
54.01
55.01
55.02
56.00
57.01
58.00
59.00
60.20
62.02
64.10
68.01
68.02
69.00
71.00
72.00
73.02
73.04
73.08
74.01
74.04
74.06
74.07
74.08
DRAFTING INFORMATION
CONTACT
The principal author of this notice is
November 23, 1998
74.09
74.30
75.02
75.03
75.04
76.01
76.03
76.04
76.05
77.03
77.07
77.08
77.09
78.03
78.04
78.07
78.08
78.09
78.60
79.01
79.03
80.01
80.02
83.02
84.02
85.10
86.00
87.01
87.02
88.02
88.03
Winston H. Douglas of the Office of the
Assistant Chief Counsel (Passthroughs
and Special Industries). For further infor-
10
88.04
89.03
89.04
90.01
90.02
91.02
91.10
92.03
92.10
92.40
93.02
95.01
96.02
96.03
97.00
98.03
98.04
98.05
98.06
98.07
98.08
98.09
98.10
98.20
99.03
99.04
99.05
99.06
99.07
mation regarding this notice contact Mr.
Douglas on (202) 622-3110 (not a tollfree call).
1998–47 I.R.B.
IRB 1998-47
11/19/98 5:55 AM
1998–47 I.R.B.
Page 11
11
November 23, 1998
IRB 1998-47
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Page 12
Part IV. Items of General Interest
Foundations Status of Certain
Organizations
Announcement 98–103
The following organizations have
failed to establish or have been unable to
maintain their status as public charities or
as operating foundations. Accordingly,
grantors and contributors may not, after
this date, rely on previous rulings or designations in the Cumulative List of Organizations (Publication 78), or on the presumption arising from the filing of notices
under section 508(b) of the Code. This
listing does not indicate that the organizations have lost their status as organizations described in section 501(c)(3), eligible to receive deductible contributions.
Former Public Charities. The following
organizations (which have been treated as
organizations that are not private foundations described in section 509(a) of the
Code) are now classified as private foundations:
Alternative Financing Program Inc., Fort
Lauderdale, FL
Alvin E. Gershen Apartments Inc.,
Pennington, NJ
Amador County Training Officers
Association, Jackson, CA
Amateur Baseball Development,
Riverside, CA
Ambassadors of Love International,
Junction City, KS
Amber Resource & Development Inc.,
Washington, DC
Amberwood Inc., Ojai, CA
Ambler Arts Festival at Temple
University, Spring House, PA
Ameinu Foundation of America Inc.,
New York, NY
American Foundation for Amelioration of
Attention Deficit Disorders &
Learning Disabilities, Ridgeton, MO
Amerasian Information Center Inc.,
Portland, OR
America for Children Inc., Lilburn, GA
America Part II Foundation, Washington,
DC
American Aids Association, New York,
NY
American Alliance for Better Schools
Foundation, Washington, DC
American Amateur Indexed Golf
Association, Stafford, TX
November 23, 1998
American Benevolent Association, Jay,
OK
American Bosnia Relief Association, St.
Louis, MO
American Business Consultants
Association, Ellisville, MO
American Capital Foundation for the
Homeless, Marina Del Rey, CA
American Charity Fund, Oak Brook, IL
American Childrens Theatre Academy
Inc., Denver, CO
American Christian Youth Inc.,
Collingswood, NJ
American City Manufacturing Company,
Baltimore, MD
American Community for Research and
Education Inc., New York, NY
American Council of the Blind of Idaho
Inc., Idaho Falls, ID
American Drug Free Promotions Group,
Kent, WA
American Education Institute, Bigfork,
MT
American Fiction Foundation, Costa
Mesa, CA
American Foundation for Brewing
History and Arts Inc., Ft. Mitchell, KY
American Foundation for Drug
Prevention Inc., Hurst, TX
American Friends of the Seminary of
Judaic Studies-Bet Midrash Inc., South
Orange, NJ
American Friends of Agudath Athava
Veahva, Brooklyn, NY
American Friends of Beit Orot Inc.,
Brooklyn, NY
American Friends of Kol Yehuda Inc.,
Deal, NJ
American Friends of the Lomonosov
Foundation, Houston, TX
American Friends of United Yishuv
Movement, Brooklyn, NY
American Friends of Yeshive Bais
Shlomo, Bel Harbor, NY
American Indian Educational and
Opportunity Fund Inc., Fort Worth,
TX
American Indian Health Clinic, St. Paul,
MN
American Indian Reliance Organization
Inc., Saint Petersburg, FL
American Indian Womens Resource
Center Inc., Denver, CO
American Islamic Community
Development Foundation, Washington,
DC
12
American Italian Heritage Foundation
Inc., Osprey, FL
American Legion Baseball Association
Inc., Mountain Home, AR
American Literacy Guild, Westchester, IL
American Master Chorale Inc., Madison,
WI
American Mobile Medical Assistance,
Cambridge, MA
American Museum for the Preservation
of Historic Aircraft, Long Island City,
NY
American Peace Watch Foundation
Moshe Mirsky, New York, NY
American Relief Service Inc., Goshen, IN
American Religious Movement for Youth
Inc., Benbrook, TX
American-Royal Thai Air Classics
Association and Foundation, Houston,
TX
American Society of Furniture Artists,
Houston, TX
American Society of Payroll
Management Foundation, New York,
NY
American Task Force for Bosnia Inc.,
Washington, DC
American Telemedicine Association,
Austin, TX
American Theatre of Harlem Inc., New
York, NY
American Victory Mariners Memorial
Museum Inc., Teaneck, NJ
American Youth Military Academy,
Johnston, RI
Americans for Legal Reform Inc.,
Noblesville, IN
Americans of Italian Heritage Inc.,
Flushing, NY
Americans Stopping Child Abuse,
Carlsbad, CA
Amidah Inc., Freeport, NY
Amigos International, Millersville, PA
Amurt-Stop Diabetes Inc., San Antonio,
TX
Anderson County We Are Our Brothers
Keeper Inc., Palestine, TX
Andover Recreational Development
Association, Andover, MN
Anew Beginning in Texas Inc., Humble,
TX
Angel Garden Inc., Kokiak, AK
Angel of Grace Foundation Inc.,
Memphis, TN
Angela Gaines Memorial Fund Inc.,
Parker, CO
1998–47 I.R.B.
IRB 1998-47
11/19/98 5:55 AM
Page 13
Angelina County Youth Football Inc.,
Lufkin, TX
Animal Lifeline Inc., Fort Lauderdale, FL
Animal Rescue & Adoption Services
Inc., Ft. Smith, AR
Animal Welfare League of Hilton Head
Island, Hilton Head Island, SC
Annalori Corp, Colorado Springs, CO
Annapolis Baseball Club, Annapolis, MD
Anti Vehicle Crime Association of
Wisconsin Inc., Stevens Point, WI
Antioch Christian Ministries Inc.,
Glendale, AZ
Apologetics for Faith Integrating Reason
Ministries, Irvine, CA
Appalachia Rescue Squad Inc.,
Appalachia, VA
Applied Rehabilitation Ministries Inc.,
Phoenix, AZ
Applied Research Institute for Social
Equality Inc., Wayne, NJ
Aqua-Sports Boating Education,
Bellevue, WA
Aragon Affordable Housing Inc., Irvine,
CA
Arcade Pregnancy Services Inc.,
Yorkshire, NY
Archangel Project Inc., South Darmouth,
MA
Archimedes Group Inc., New Haven, CT
Arizona Aids Services of the Deaf Inc.,
Phoenix, AZ
Arizona Baseball Inc., Scottsdale, AZ
Arizona Family Member Services
Foundation, Scottsdale, AZ
Arizona Foundation for Agricultural
Education Inc., Phoenix, AZ
Arizona Patenet Law Association,
Phoenix, AZ
Arizona Quail Preservation Society,
Phoenix, AZ
Arizona Realtors Affordable Housing
Foundation Inc., Phoenix, AZ
Arizona State Horsemens Foundation
Inc., Phoenix, AZ
Arizona Waste Exchange Inc., Tucson,
AZ
Arkansas Crime Prevention Association,
Little Rock, AR
Arkansas Cultural Complex Study Inc.,
Little Rock, AR
Arkansas Economic Corporation,
Brinkley, AR
Armstrong-Stafford Community Council
Inc., Seagoville, TX
Art Association of Madison County Inc.,
Anderson, IN
Art Factory Inc., Miami Springs, FL
1998–47 I.R.B.
Art Trails Inc., Accord, NY
Artists Relating Together & Exhibiting
Inc., Dallas, TX
Arts & Education Foundation of Alabama
Inc., Birmingham, AL
Arts Council of Gibson County Inc.,
Princeton, IN
Arts New Mexico Inc., Santa Fe, NM
Arts over AIDS, St. Paul, MN
Artserv Incorporated, Dallas, TX
Ascorap Mission, Houston, TX
Ashland Area Girls Fastpitch Promotions
Inc., Ashland, OH
ASI-Austin Texas Inc., St. Paul, MN
Asia Evangelical Ministries, Des Plaines,
IL
Asia Pacific Policy Center Inc., NW,
Washington, DC
Asian Americans of Connecticut Inc., W.
Hartford, CT
Asian Missions Inc., Vancouver, WA
Asian Pacific Womens Center Inc., Los
Angeles, CA
Asociacion Dominicana de la Florida
Central Inc., Orlando, FL
Asociacion Esperanza y Caridad Inc.,
Miami, FL
Assistance Association of Former
Vietnamese Prisoners of War, Houston,
TX
Assistive Technologies Group, Dayton,
OH
Assistive Technology Users Group Inc.,
Louisville, KY
Association of Directors of Geriatric
Academic Programs Inc., Cleveland,
OH
Association of Professionals in RiskRelated Disciplines, Seattle, WA
Associated Resource Management
Services, Norwich, CT
Association for Surgical Education
Foundation, Springfield, IL
Association for the Honorable Order of
Tennessee Colonels Inc., Jackson, TN
Association of Black Secretaries,
Oakland, CA
Asthma Network of Plano, Plano, TX
Astoria Community Service Inc., Astoria,
NY
Atascadero Recreation Center Committee
Inc., Atascadero, CA
Atchison Area Crime Stoppers Inc.,
Atchison, KS
Athletic International Inc., Dallas, TX
Atlanta Braves Foundation Inc., Atlanta,
GA
13
Atlanta Chapter of Health Physics
Society Inc., Doraville, GA
Atlanta Clergy and Laity Concerned Inc.,
Atlanta, GA
Atlanta Home Missions Inc., Austell, GA
Atlanta Housing Association of
Neighborhood-Based Developers,
Atlanta, GA
Atlanta Lesbian and Gay History Inc.,
Atlanta, GA
Atlanta Takedown Association Inc.,
Atlanta, GA
Atlanta Youth Chorale, Atlanta, GA
Attendant Services of Houston, Bellaire,
TX
Auburn Memorial Companies Inc.,
Auburn, NY
Auburn-Opelika Sports Corporation,
Auburn, AL
Audubon Area First Responders,
Audubon, MN
Augusta County Fair, Verona, VA
Aurora Recreation Center, Aurora, IL
Austin Labor Force Intermediary,
Chicago, IL
If an organization listed above submits
information that warrants the renewal of
its classification as a public charity or as a
private operating foundation, the Internal
Revenue Service will issue a ruling or determination letter with the revised classification as to foundation status. Grantors
and contributors may thereafter rely upon
such ruling or determination letter as provided in section 1.509(a)–7 of the Income
Tax Regulations. It is not the practice of
the Service to announce such revised classification of foundation status in the Internal Revenue Bulletin.
Announcement 98–104
This announcement corrects several errors made in Rev. Proc. 98–35, 1998–21
I.R.B. 6, reprinted as Publication 1220,
which describes the specifications for filing Forms 1098, 1099, 5498, and W–2G
Magnetically or Electronically.
A. The IRA/SEP/SIMPLE Indicator for
Form 1099–R found in Field Position 548
of the Payee “B” Record may be used in
certain cases with Distribution Codes G
and H (which are reported in Field Positions 545 or 546). Distribution Code G
may be used with the IRA/SEP/SIMPLE
Indicator for Tax Year 1998 when contributions to a First IRA are recharacterized
November 23, 1998
IRB 1998-47
11/19/98 5:55 AM
Page 14
as contributions to a Second IRA. Distribution Code H may be used when a distribution from a conduit IRA is payable to the
trustee or is transferred to an employer
plan. To incorporate this information, the
following changes should be made to
Publication 1220: (1) In Part A, Section
19, Items 13 and 14 should be deleted.
(2) In Part B, Section 10(14), Field Positions 545-546, the item reading, “**
Distribution Codes G and H cannot be
used in combination with the IRA/SEP
/SIMPLE Indicator in Field Position
548,” should be deleted. (3) Part B, Section 10(14), Field Position 548, should
read, “Enter “1” if the IRA/SEP/SIMPLE Indicator applies. . .”. The bold
statement should read, “Do not use the
indicator for an Education IRA”. The
words “Roth IRA or” should be
deleted.
B. Announcement 98–72, 1998–31
I.R.B. 14, was released erroneously by
IRS/Martinsburg Computing Center regarding the Form 5498 and Form
5498–MSA due dates, which in turn impacted the information contained in Publication 1220. However, this information
may appear correctly in some versions of
this publication, specifically those downloaded from various bulletin boards and
web sites. To clarify this misstatement
and any other misinformation that may be
circulating, that may be circulating, the
due dates for Form 5498 and Form
5498–MSA should read as follows:
Participant Copy – June 1, 1999*
IRS Copy – June 1, 1999*
*This is due to the actual due date falling
on the Memorial Day Holiday (May 31,
1999).
C. In Part A, Section 13, a portion of
the Guidelines for Filing Corrected Returns Magnetically/Electronically was left
out. Under Error Made on the Original
Return #2, step F for filing the corrected
return should read, “Corrected returns
submitted to IRS/MCC using “G” coded
“B” Records may be on the same file as
those returns submitted without the “G”
code; however, separate “A” Records are
required.”
D. In Part A, Section 16, Combined
Federal State Filing Program, the state of
Minnesota and the corresponding code of
27 were dropped from the program in
error. Table 1. Participating States and
Their Codes, and Table 2. Dollar Criteria
For State Reporting should include the
following information:
Table 1. Partricipating States and Their Codes
State
Code
Alabama
Arizona
Arkansas
California
Delaware
District of Columbia
Georgia
Hawaii
Idaho
01
04
05
06
10
11
13
15
16
November 23, 1998
State
Indiana
Iowa
Kansas
Maine
Massachusetts
Minnesota
Mississippi
Missouri
14
Code
State
18
19
20
23
25
27
28
29
Montana
New Jersey
New Mexico
North Dakota
Oregon
South Carolina
Tennessee
Wisconsin
Code
30
34
35
38
41
45
47
55
1998–47 I.R.B.
IRB 1998-47
11/19/98 5:55 AM
Page 15
Table 2. Dollar Criteria for State Reporting
State
1099–DIV
1099–G
1099–INT
1099–MISC
1099–OID
1099–PATR
1099–R
5498
Alabama
Arkansas
District of
Columbiab
Hawaii
Idaho
Iowa
Minnesota
Mississippi
Missouri
Montana
New Jersey
Tennessee
Wisconsin
$1500
100
$ NR
2500
$1500
100
$1500
2500
$1500
2500
$1500
2500
$1500
2500
NR
600
10
NR
10
10
600
NR
10
1000
100
NR
600
600
10
NR
10
10
600
NR
10
1000
100
NR
600
600
600
600
600
600
1200c
600
1000
NR
600
600
10
NR
10
10
600
NR
10
1000
NR
NR
600
10
NR
10
10
600
NR
10
1000
NR
NR
600
600
NR
a
a
a
NR
10
10
600
NR
10
1000
NR
NR
The preceding list is for information
purposes only. The state filing requirements are subject to change by the states.
For complete information on state filing
requirements, contact the appropriate
state tax agencies.
Filing requirements for states in Table
1 not shown in Table 2 are the same as the
federal requirement.
NR = No filing requirement.
Footnotes:
a. All amounts are to be reported.
b. Amounts are for aggregates of several
types of income from the same payer.
c. Missouri would prefer those returns
filed with respect to non-Missouri residents to be sent directly to its state agency.
1998–47 I.R.B.
E. Part B, Section 4.08(b) incorrectly
states the acceptable sizes of Quarter Inch
Cartridges(QIC). Quarter Inch Cartridges with a size of QIC–11 or
QIC–1350 are not acceptable.
F. Part B, Section 5.01(b)(2), incorrectly stated the save command for 51⁄4”
diskettes recorded using EBCDIC on an
AS400 system. The correct statement
should read, “The save command for
AS400 is SAVS36F.”
G. In Part B, Section 6, Field Positions
296–303 of the Transmitter “T” Record,
listing the Total Number of Payees, is
identified as a required field. IRS/MCC
encourages filers to complete the information as requested; however, filers are
15
10
600
600
NR
600
1000
NR
600
a
a
a
a
NR
NR
a
NR
NR
NR
not required to report this information for
Tax Year 1998. The location of the Total
Number of Payees field will be revisited
for Tax Year 1999 filing.
H. In Part B, Section 8, information in
Field Positions 28–39 of the Payer “A”
Record, describing Amount Code 1 for
the Form 5498, was listed incorrectly. The
correct information is as follows:
Amount Code
Amount Type
1
IRA contributions (other
than amounts in Amount
Codes 2, 3, 7, 8, 9 and
A)
November 23, 1998
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11/19/98 5:55 AM
Page 16
Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior published position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus,
if an earlier ruling held that a principle
applied to A, and the new ruling holds
that the same principle also applies to B,
the earlier ruling is amplified. (Compare
with modified, below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confusion. It is not used where a position in a
prior ruling is being changed.
Distinguished describes a situation
where a ruling mentions a previously
published ruling and points out an essential difference between them.
Modified is used where the substance
of a previously published position is
being changed. Thus, if a prior ruling
held that a principle applied to A but not
to B, and the new ruling holds that it ap-
plies to both A and B, the prior ruling is
modified because it corrects a published
position. (Compare with amplified and
clarified, above).
Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions. This term is most commonly used
in a ruling that lists previously published
rulings that are obsoleted because of
changes in law or regulations. A ruling
may also be obsoleted because the substance has been included in regulations
subsequently adopted.
Revoked describes situations where the
position in the previously published ruling is not correct and the correct position
is being stated in the new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a period of time in separate rulings. If the
new ruling does more than restate the
substance of a prior ruling, a combination
of terms is used. For example, modified
and superseded describes a situation
where the substance of a previously published ruling is being changed in part and
is continued without change in part and it
is desired to restate the valid portion of
the previously published ruling in a new
ruling that is self contained. In this case
the previously published ruling is first
modified and then, as modified, is superseded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and
that list is expanded by adding further
names in subsequent rulings. After the
original ruling has been supplemented
several times, a new ruling may be published that includes the list in the original
ruling and the additions, and supersedes
all prior rulings in the series.
Suspended is used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contribution Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign Corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statements of Procedral Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
The following abbreviations in current use and formerly used will appear in material published in the
Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C.—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
November 23, 1998
16
1998–47 I.R.B.
IRB 1998-47
11/19/98 5:55 AM
Page 17
Numerical Finding List1
Railroad Retirement Quarterly Rate:
Tax Conventions:
Bulletins 1998–29 through 46
1998–31 I.R.B. 7
1998–43 I.R.B. 6
Announcements:
Proposed Regulations:
Treasury Decisions:
98–62, 1998–29 I.R.B. 13
98–68, 1998–29 I.R.B. 14
98–69, 1998–30 I.R.B. 16
98–70, 1998–30 I.R.B. 17
98–71, 1998–30 I.R.B. 17
98–72, 1998–31 I.R.B. 14
98–73, 1998–31 I.R.B. 14
98–74, 1998–31 I.R.B. 15
98–75, 1998–31 I.R.B. 15
98–76, 1998–32 I.R.B. 64
98–77, 1998–34 I.R.B. 30
98–78, 1998–34 I.R.B. 30
98–79, 1998–34 I.R.B. 31
98–80, 1998–34 I.R.B. 32
98–81, 1998–36 I.R.B. 35
98–82, 1998–35 I.R.B. 17
98–83, 1998–36 I.R.B. 36
98–84, 1998–38 I.R.B. 30
98–85, 1998–38 I.R.B. 30
98–86, 1998–38 I.R.B. 31
98–87, 1998–40 I.R.B. 11
98–88, 1998–41 I.R.B. 14
98–89, 1998–40 I.R.B. 11
98–90, 1998–42 I.R.B. 22
98–91, 1998–40 I.R.B. 12
98–92, 1998–41 I.R.B. 15
98–93, 1998–43 I.R.B. 10
98–94, 1998–43 I.R.B. 32
98–95, 1998–44 I.R.B. 13
98–96, 1998–44 I.R.B. 18
98–97, 1998–44 I.R.B. 18
98–98, 1998–44 I.R.B. 18
98–99, 1998–46 I.R.B. 34
98–100, 1998–46 I.R.B. 42
98–101, 1998–45 I.R.B. 27
98–102, 1998–45 I.R.B. 28
REG–209446–82, 1998–36 I.R.B. 24
REG–209060–86, 1998–39 I.R.B. 18
REG–209769–95, 1998–41 I.R.B. 8
REG–209813–96, 1998–35 I.R.B. 9
REG–246256–96, 1998–34 I.R.B. 9
REG–104641–97, 1998–29 I.R.B. 9
REG–104565–97, 1998–39 I.R.B. 21
REG–106177–97, 1998–37 I.R.B. 33
REG–109708–97, 1998–45 I.R.B. 29
REG–115446–97, 1998–36 I.R.B. 23
REG–116608–97, 1998–29 I.R.B. 12
REG–118926–97, 1998–39 I.R.B. 23
REG–118966–97, 1998–39 I.R.B. 29
REG–119227–97, 1998–30 I.R.B. 13
REG–122488–97, 1998–42 I.R.B. 19
REG–101363–98, 1998–40 I.R.B. 10
REG–106221–98, 1998–41 I.R.B. 10
REG–110332–98, 1998–33 I.R.B. 18
REG–110403–98, 1998–29 I.R.B. 11
REG–115393–98, 1998–39 I.R.B. 34
8771, 1998–29 I.R.B. 6
8772, 1998–31 I.R.B. 8
8773, 1998–29 I.R.B. 4
8774, 1998–30 I.R.B. 5
8775, 1998–31 I.R.B. 4
8776, 1998–33 I.R.B. 6
8777, 1998–34 I.R.B. 4
8778, 1998–36 I.R.B. 4
8779, 1998–36 I.R.B. 11
8780, 1998–39 I.R.B. 14
8781, 1998–40 I.R.B. 4
8782, 1998–41 I.R.B. 5
8783, 1998–41 I.R.B. 4
8784, 1998–42 I.R.B. 4
8785, 1998–42 I.R.B. 5
8786, 1998–44 I.R.B. 4
8787, 1998–46 I.R.B. 5
8788, 1998–45 I.R.B. 6
Court Decisions:
2063, 1998–36 I.R.B. 13
2064, 1998–37 I.R.B. 4
2065, 1998–39 I.R.B. 7
Notices:
98–36, 1998–29 I.R.B. 8
98–37, 1998–30 I.R.B. 13
98–38, 1998–34 I.R.B. 7
98–39, 1998–33 I.R.B. 11
98–40, 1998–35 I.R.B. 7
98–41, 1998–33 I.R.B. 12
98–42, 1998–33 I.R.B. 12
98–43, 1998–33 I.R.B. 13
98–44, 1998–34 I.R.B. 7
98–45, 1998–35 I.R.B. 7
98–46, 1998–36 I.R.B. 21
98–47, 1998–37 I.R.B. 8
98–48, 1998–39 I.R.B. 17
98–49, 1998–38 I.R.B. 5
98–50, 1998–44 I.R.B. 10
98–51, 1998–44 I.R.B. 11
98–52, 1998–46 I.R.B. 16
98–53, 1998–46 I.R.B. 24
98–54, 1998–46 I.R.B. 25
98–55, 1998–46 I.R.B. 26
Revenue Procedures:
98–40, 1998–32 I.R.B. 6
98–41, 1998–32 I.R.B. 7
98–42, 1998–28 I.R.B. 9
98–43, 1998–29 I.R.B. 8
98–44, 1998–32 I.R.B. 11
98–45, 1998–34 I.R.B. 8
98–46, 1998–36 I.R.B. 21
98–47, 1998–37 I.R.B. 8
98–48, 1998–38 I.R.B. 7
98–49, 1998–37 I.R.B. 9
98–50, 1998–38 I.R.B. 8
98–51, 1998–38 I.R.B. 20
98–52, 1998–37 I.R.B. 12
98–53, 1998–40 I.R.B. 9
98–54, 1998–43 I.R.B. 7
98–55, 1998–46 I.R.B. 27
98–56, 1998–46 I.R.B. 33
Revenue Rulings:
98–34, 1998–31 I.R.B. 12
98–35, 1998–30 I.R.B. 4
98–36, 1998–31 I.R.B. 6
98–37, 1998–32 I.R.B. 5
98–38, 1998–32 I.R.B. 4
98–39, 1998–33 I.R.B. 4
98–40, 1998–33 I.R.B. 4
98–41, 1998–35 I.R.B. 6
98–42, 1998–35 I.R.B. 5
98–43, 1998–36 I.R.B. 9
98–44, 1998–37 I.R.B. 4
98–45, 1998–38 I.R.B. 4
98–46, 1998–39 I.R.B. 10
98–47, 1998–39 I.R.B. 4
98–48, 1998–39 I.R.B. 6
98–49, 1998–40 I.R.B. 4
98–50, 1998–40 I.R.B. 7
98–51, 1998–43 I.R.B. 4
98–52, 1998–45 I.R.B. 4
98–53, 1998–46 I.R.B. 12
98–54, 1998–46 I.R.B. 14
1 A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 1998–1 through 1998–28
will be found in Internal Revenue Bulletin 1998–29,
dated July 20, 1998.
1998–47 I.R.B.
17
November 23, 1998
IRB 1998-47
11/19/98 5:55 AM
Page 18
Finding List of Current Action on
Previously Published Items1
Bulletins 1998–29 through 46
*Denotes entry since last publication
Notices:
87–13
Modified by
98–49, 1998–38 I.R.B. 5
87–16
Modified by
98–49, 1998–38 I.R.B. 5
Revenue Procedures:
83–58
Obsoleted by
98–37, 1998–32 I.R.B. 5
88–17
Clarified, modified, and superseded by
98–54, 1998–43 I.R.B. 7
94–23
Amplified and superseded by
98–55, 1998–46 I.R.B. 27
97–40
Amplified and superseded by
98–55, 1998–46 I.R.B. 27
97–60
Superseded by
98–50, 1998–38 I.R.B. 8
97–61
Superseded by
98–51, 1998–38 I.R.B. 20
98–14
Modified by
98–53, 1998–40 I.R.B. 9
Revenue Rulings:
57–271
Obsoleted by
98–37, 1998–32 I.R.B. 5
67–301
Modified by
98–41, 1998–35 I.R.B. 6
Revenue Rulings—Continued
Revenue Rulings—Continued
72–121
Obsoleted by
98–37, 1998–32 I.R.B. 5
72–122
Obsoleted by
98–37, 1998–32 I.R.B. 5
74–77
Obsoleted by
98–37, 1998–32 I.R.B. 5
75–19
Obsoleted by
98–37, 1998–32 I.R.B. 5
76–562
Obsoleted by
98–37, 1998–32 I.R.B. 5
77–214
Obsoleted by
98–37, 1998–32 I.R.B. 5
79–106
Obsoleted by
98–37, 1998–32 I.R.B. 5
83–113
Obsoleted by
98–37, 1998–32 I.R.B. 5
85–143
Obsoleted by
98–37, 1998–32 I.R.B. 5
88–8
Obsoleted by
98–37, 1998–32 I.R.B. 5
88–76
Obsoleted by
98–37, 1998–32 I.R.B. 5
88–79
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–81
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–92
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–93
Obsoleted by
98–37, 1998–32 I.R.B. 5
94–5
Obsoleted by
98–37, 1998–32 I.R.B. 5
94–6
Obsoleted by
98–37, 1998–32 I.R.B. 5
94–30
Obsoleted by
98–37, 1998–32 I.R.B. 5
94–51
Obsoleted by
98–37, 1998–32 I.R.B. 5
94–79
Obsoleted by
98–37, 1998–32 I.R.B. 5
95–2
Obsoleted by
98–37, 1998–32 I.R.B. 5
95–9
Obsoleted by
98–37, 1998–32 I.R.B. 5
97–37
Obsoleted by
98–39, 1998–33 I.R.B. 4
93–4
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–5
Obsoleted by
98–37, 1998–32 I.R.B. 5
71–277
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–6
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–30
Obsoleted by
98–37, 1998–32 I.R.B. 5
71–434
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–38
Obsoleted by
98–37, 1998–32 I.R.B. 5
71–574
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–49
Obsoleted by
98–37, 1998–32 I.R.B. 5
72–75
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–50
Obsoleted by
98–37, 1998–32 I.R.B. 5
72–120
Obsoleted by
98–37, 1998–32 I.R.B. 5
93–53
Obsoleted by
98–37, 1998–32 I.R.B. 5
70–225
Obsoleted by
98–44, 1998–37 I.R.B. 4
3–91
Obsoleted by
98–37, 1998–32 I.R.B. 5
1 A cumulative finding list for previously published
items mentioned in Internal Revenue Bulletins
1998–1 through 1998–28 will be found in Internal
Revenue Bulletin 1998–29, dated July 20, 1998.
November 23, 1998
18
1998–47 I.R.B.
IRB 1998-47
11/19/98 5:55 AM
Page 19
IRB 1998-47
11/19/98 5:55 AM
Page 20
INTERNAL REVENUE BULLETIN
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