Bulletin No. 1998–47

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Page 1

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.

IRB 1998-47

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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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Page 8

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

11/19/98 5:55 AM

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

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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

IRB 1998-47

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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on a yearly subscription basis by the Superintendent of Documents. Current subscribers are notified by the Superintendent of

Documents when their subscriptions must be renewed.

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