# Bulletin No. 1998–24

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Internal Revenue

bulletin

Bulletin No. 1998–24
June 15, 1998

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

EMPLOYMENT TAX

Rev. Rul. 98–29, page 4.

Announcement 98–48, page 6.

LIFO; price indexes; department stores. The April 1998
Bureau of Labor Statistics price indexes are accepted for
use by department stores employing the retail inventory
and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with reference to, April 30,
1998.

Rev. Proc. 98–26, 1998–13 I.R.B. 26, relating to the specifications for filing Form W–4, Employee’s Withholding
Allowance Certificate, magnetically or electronically, is
corrected.

ADMINISTRATIVE
Announcement 98–51, page 7.

EXEMPT ORGANIZATIONS
Announcement 98–52, page 37.
The organization Youth Today Leaders Tomorrow, Inc.,
Golden Valley, MN, no longer qualifies as an organization to
which contributions are deductible under section 170 of the
Code.

Announcement 98–53, page 37.
A list is given of organizations now classified as private foundations.

The Service is requesting comments from the public on the
following proposed new forms and instructions; Form W–8,
Certificate of Foreign Status of Beneficial Owner for United
States Tax Withholding; Form W–8A, Foreign Persons’ Claim
of Income Effectively Connected With the Conduct of a
Trade or Business in the United States; Form W–8B, Certification for United States Tax Withholding for Foreign Governments and Other Foreign Organizations; and Form W–8C,
Certificate of Foreign Intermediary, Foreign Partnership, and
Certain U.S. Branches for United States Tax Withholding.
Prior versions of the forms, without instructions, were issued in Announcement 98–15, 1998–10 I.R.B. 36.

Finding Lists begin on page 44.
Announcement of the Consent Voluntary Suspension of Attorneys, Certified Public Accounts, Enrolled Agents, etc., begins on
page 40.
Announcement of the Expedited Suspension of Attorneys, Certified Public Accountants, Enrolled Agents, and Enrolled
Actuaries From Practice Before the Internal Revenue Service begins on page 41.
Announcement of Declaratory Judgment Proceedings Under Section 7428 begins on page 39.

Department of the Treasury
Internal Revenue Service

Mission of the Service
ucts and services; and perform in a manner warranting
the highest degree of public confidence in our integrity, efficiency, and fairness.

The purpose of the Internal Revenue Service is to collect
the proper amount of tax revenue at the least cost; serve
the public by continually improving the quality of our prod-

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

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

Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
Section 472.—Last-in, First-out
Inventories
26 CFR 1.472-1: Last-in, first-out inventories.

LIFO; price indexes; department
stores. The April 1998 Bureau of Labor
Statistics price indexes are accepted for
use by department stores employing the
retail inventory and last-in, first-out inventory methods for valuing inventories
for tax years ended on, or with reference
to, April 30, 1998.

Rev. Rul. 98–29
The following Department Store
Inventory Price Indexes for April
1998 were issued by the Bureau of Labor
Statistics. The indexes are accepted by
the Internal Revenue Service, under
§ 1.472–1(k) of the Income Tax Regulations and Rev. Proc. 86–46, 1986–2 C.B.
739, for appropriate application to
inventories of department stores employing the retail inventory and last-in, firstout inventory methods for tax years

ended on, or with reference to, April 30,
1998.
The Department Store Inventory Price
Indexes are prepared on a national basis
and include (a) 23 major groups of departments, (b) three special combinations of
the major groups - soft goods, durable
goods, and miscellaneous goods, and (c) a
store total, which covers all departments,
including some not listed separately, except for the following: candy, food,
liquor, tobacco, and contract departments.

BUREAU OF LABOR STATISTICS, DEPARTMENT STORE
INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS
(January 1941 = 100, unless otherwise noted)
Groups

Percent Change
from Apr. 1997
to Apr. 19981

Apr.
1997

Apr.
1998

1. Piece Goods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2. Domestics and Draperies . . . . . . . . . . . . . . . . . . . . . . . . . .
3. Women’s and Children’s Shoes . . . . . . . . . . . . . . . . . . . . .
4. Men’s Shoes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5. Infants’ Wear . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6. Women’s Underwear . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
7. Women’s Hosiery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8. Women’s and Girls’ Accessories . . . . . . . . . . . . . . . . . . . . .
9. Women’s Outerwear and Girls’ Wear . . . . . . . . . . . . . . . . .
10. Men’s Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
11. Men’s Furnishings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
12. Boys’ Clothing and Furnishings . . . . . . . . . . . . . . . . . . . . .
13. Jewelry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
14. Notions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
15. Toilet Articles and Drugs . . . . . . . . . . . . . . . . . . . . . . . . . .
16. Furniture and Bedding . . . . . . . . . . . . . . . . . . . . . . . . . . . .
17. Floor Coverings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
18. Housewares . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
19. Major Appliances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
20. Radio and Television . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
21. Recreation and Education2 . . . . . . . . . . . . . . . . . . . . . . . . .
22. Home Improvements2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
23. Auto Accessories2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

533.0
653.6
661.3
904.8
640.6
546.3
294.4
561.0
439.8
622.2
598.9
498.6
1026.2
799.2
912.5
667.5
586.9
815.9
241.9
76.6
110.2
131.4
107.3

547.3
642.9
663.6
902.5
628.1
586.1
305.5
550.1
431.7
633.6
609.6
498.8
1001.8
793.7
936.7
675.9
603.7
821.4
239.4
73.0
105.7
134.0
106.8

2.7
–1.6
0.3
–0.3
–2.0
7.3
3.8
–1.9
–1.8
1.8
1.8
0.0
–2.4
–0.7
2.7
1.3
2.9
0.7
–1.0
–4.7
–4.1
2.0
–0.5

Groups 1 – 15: Soft Goods . . . . . . . . . . . . . . . . . . . . . . . . . . .

614.6

615.3

0.1

Groups 16 – 20: Durable Goods . . . . . . . . . . . . . . . . . . . . . . . .

466.9

464.9

–0.4

Groups 21 – 23: Misc. Goods2 . . . . . . . . . . . . . . . . . . . . . . . . .

112.4

109.5

–2.6

Store Total3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

562.6

560.8

–0.3

1Absence of a minus sign before percentage change in this column signifies price increase.
2Indexes on a January 1986=100 base.
3The store total index covers all departments, including some not listed separately, except for the following: candy, foods, liquor, to-

bacco, and contract departments.

June 15, 1998

4

1998–24 I.R.B.

DRAFTING INFORMATION
The principal author of this revenue
ruling is Stan Michaels of the Office of
Assistant Chief Counsel (Income Tax and

1998–24 I.R.B.

Accounting). For further information regarding this revenue ruling, contact Mr.
Michaels on (202) 622-4970 (not a tollfree call).

5

June 15, 1998

Part IV. Items of General Interest
Rev. Proc. 98–26; Correction
Announcement 98–48
This announcement corrects certain minor errors which appeared in Rev. Proc. 98–26, I.R.B. 1998–13, which provides specifications for filing Forms W–4, Employee’s Withholding Allowance Certificate, magnetically or electronically. Revenue Procedure 9826 is reprinted as Publication 1245, Specifications for Filing Forms W–4, Employee’s Withholding Allowance Certificate, Magnetically or Electronically.
Changes are listed by part and section. The actual changed wording is highlighted using italics and bold print.
26 CFR 601.602: Tax forms and instructions.

PART A. GENERAL
SEC. 7. FILING FORMS W–4 MAGNETICALLY/ELECTRONICALLY
.06 Before submitting your magnetic/electronic file, include the following:
(b) Your media (tape, diskette or cartridge with an external label.) Notice 1027 describes the information which should be included on this self-prepared label.
PART B. MAGNETIC MEDIA/ELECTRONIC SPECIFICATIONS
SEC. 1. GENERAL
.02 An external label must appear on each tape, tape cartridge and diskette submitted. Notice 1027 details what information must
be on the label. The diskettes used must be MS/DOS compatible.
SEC. 7. FORM W–4 RECORD FORMAT AND RECORD LAYOUT
Field
Position

Field Title

140–141

Employee State

Length
2

Description and Remarks
REQUIRED. Enter the two of employees address - must be one the following:

☛ Note 1: For foreign addresses, enter xx from table below.
Location

Code

Location

Code

Location

Code

Alabama
Alaska
American Samoa
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Federated States
of Micronesia
Florida
Georgia
Guam
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas

AL
AK
AS
AZ
AR
CA
CO
CT
DE
DC

Kentucky
Louisiana
Maine
Marshall Islands
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Northern
Mariana Islands

KY
LA
ME
MH
MD
MA
MI
MN
MS
MO
MT
NE
NV
NH
NJ
NM
NY
NC
ND

Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
Foreign Address,
All Others

OH
OK
OR
PA
PR
RI
SC
SD
TN
TX
UT
VT
VA
VI
WA
WV
WI
WY

June 15, 1998

FM
FL
GA
GU
HI
ID
IL
IN
IA
KS

XX

MP

6

1998–24 I.R.B.

FORM W–4 RECORD FORMAT AND RECORD LAYOUT (CONTINUED)
Field
Position
214–247

Field Title
Employer Name
Line 2

Length
34

Description and Remarks
If the employer name requires more space than is available in Employer Name Line 1,
enter the remaining portion of the name in this field. Left-justify and fill with blanks.
Position 214 Must be alpha or numeric; hyphens must be surrounded by alphas or numerics; blanks must be surrounded by alphas or numerics or continued to the field
(e.g., ab...b, aba).

☛ Note: The same exceptions apply as set forth in “Employer Name Line 1” plus the use of a percent sign (%) is not valid—use c/o
if necessary.
248–282

Employer Street

35

REQUIRED. Enter mailing address of employer. Street address should include number, street, apartment or suite number (or P O Box if mail is not delivered to street address). Left-justify and fill unused positions with blanks. Position 248 must be alpha or
numeric; hyphens must be surrounded by alphas or numerics; blanks must be surrounded by alphas or numerics or continued to the end of the field (e.g., ab...b, aba).

☛ Note: The only allowable characters are alphas, blanks, numerics, ampersand, hyphens and slashes. Punctuation such as periods
and commas are not allowed and will cause your file to be returned. For example, the address 210 N. Queen St., Suite #300 must be
entered as 210 N Queen St Suite 300.

Proposed Forms W–8, W–8A,
W–8B, and W–8C, and
Instructions
Announcement 98–51
The Internal Revenue Service announces that it is requesting comments
from the public on proposed new Forms
W–8, W–8A, W–8B, and W–8C and instructions to these forms. These new
forms are being proposed as a result of
final regulations published on October 14,
1997, relating to the withholding of income tax under sections 1441, 1442, and
1443 on certain U.S. source income paid
to foreign persons. T.D. 8734, 62 F.R.
53387; 1997–44 I.R.B. 5. These regulations, which provide for the use of several
withholding certificates, will be effective
January 1, 2000. See Notice 98–16,
1998–15 I.R.B. 12. Prior versions of the
new forms, without instructions, were issued in Announcement 98–15, 1998–10
I.R.B. 36.
Form W–8 (Certificate of Foreign Sta-

1998–24 I.R.B.

tus of Beneficial Owner for United States
Tax Withholding) would be provided to a
withholding agent or payer by a beneficial
owner of certain types of income to establish foreign status, to claim that such person is the beneficial owner of the income
for which the form is being furnished, and
if applicable, to claim a reduced rate of, or
exemption from, withholding as a resident of a foreign country with which the
United States has an income tax treaty.
Form W–8A (Foreign Person’s Claim
of Income Effectively Connected With
the Conduct of a Trade or Business in the
United States) would be provided to a
withholding agent or payer by a foreign
person claiming that certain income is effectively connected with the conduct of a
trade or business in the United States.
Form W–8B (Certification for United
States Tax Withholding for Foreign Governments and Other Foreign Organizations) would be provided to a withholding agent or payer by a foreign
government, international organization,
foreign central bank of issue, or foreign

7

tax-exempt organization to claim that
such organization is the beneficial owner
of the income for which the form is being
furnished, and if applicable, to claim a reduced rate of, or exemption from, withholding as a resident of a foreign country
with which the United States has an income tax treaty.
Form W–8C (Certificate of Intermediary for United States Tax Withholding)
would be provided to a withholding agent
or payer by an intermediary either to
make representations regarding the status
of beneficial owners of the amount paid
or to transmit appropriate documentation
to the withholding agent.
This announcement provides copies of
proposed Forms W–8, W–8A, W–8B,
W–8C, and the accompanying instructions. Comments on the forms and instructions should be submitted in writing
by August 14, 1998, to the Chairman, Tax
Forms Coordinating Committee, Internal
Revenue Service, T:FS:FP, Room 5577,
1111 Constitution Avenue, NW, Washington, DC 20224.

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1998–24 I.R.B.

Deletions From Cumulative List
of Organizations Contributions
to Which Are Deductible Under
Section 170 of the Code
Announcement 98–52
The names of organizations that no
longer qualify as organizations described
in section 170(c)(2) of the Internal Revenue Code of 1986 are listed below.
Generally, the Service will not disallow
deductions for contributions made to a
listed organization on or before the date
of announcement in the Internal Revenue
Bulletin that an organization no longer
qualifies. However, the Service is not
precluded from disallowing a deduction
for any contributions made after an organization ceases to qualify under section
170(c)(2) if the organization has not
timely filed a suit for declaratory judgment under section 7428 and if the contributor (1) had knowledge of the revocation of the ruling or determination letter,
(2) was aware that such revocation was
imminent, or (3) was in part responsible
for or was aware of the activities or omissions of the organization that brought
about this revocation.
If on the other hand a suit for declaratory judgment has been timely filed, contributions from individuals and organizations described in section 170(c)(2) that
are otherwise allowable will continue to
be deductible. Protection under section
7428(c) would begin on (DATE) 1998,
and would end on the date the court first
determines that the organization is not described in section 170(c)(2) as more particularly set forth in section 7428(c)(1).
For individual contributors, the maximum
deduction protected is $1,000, with a husband and wife treated as one contributor.
This benefit is not extended to any individual who was responsible, in whole or
in part, for the acts or omissions of the organization that were the basis for revocation.
Youth Today Leaders Tomorrow, Inc.
Golden Valley, MN

Foundations Status of Certain
Organizations
Announcement 98–53
The following organizations have
failed to establish or have been unable to

1998–24 I.R.B.

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:
AAB Generations Foundation, Irving, TX
AFROTC Cadet Association, Boulder,
CO
Arizona Cowboy Hall of Fame and
Museum Inc., Payson, AZ
Arizona Multi-Cultural Youtheatre and
School of Music Dance Drama,
Scottsdale, AZ
Asia Missionary Evangelism, Garden
Grove, CA
Association for Injured Workers, Fridley,
MN
Baltimore Washington Chapter of the
Health Physics Society Inc., Silver
Spring, MD
Big Sky Family Allergy-Asthma Support
Team Inc., Bozeman, MT
Black Watch Soccer Club Inc., Tampa, FL
Boynton Beach Community
Development Corporation, Boynton
Beach, FL
Bulldog Hocky Club Inc., Washington,
DC
Central Wisconsin Zoological Society
Inc., Wausau, WI
Cherry Creek Touchdown Club Inc.,
Englewood, CO
Christ Centered Counseling Clinic Inc.,
Madison, TN
Christine Gage Upper East Trenton
Outreach Center Inc., Trenton, NJ
Clark County Arts and Humanities
Council, Arkadelphia, AR
Coalition Advocating Marydales
Preservation, Villa Hills, KY
Columbia Central High School Academic
Boosters Association, Columbia, TN
Community Housing Inc., Tampa, FL
Community Services Development
Group, Olympia, WA

37

Community Re-Orientation Program,
Greenville, NC
Community Tutoring School, Mesa, AZ
Corporation for Cardiac Education,
Richmond, VA
Creating Positive Relationships
Incorporated, Carmel, IN
Dixie Hollins Band Boosters Inc.,
St. Petersburg, FL
Funeral Directors Association of
Kentucky Scholarship Trust, Frankfort,
KY
Gentlemens Club, Lufkin, TX
Edgeworth Preservation, Sewickley, PA
Ernest T. Chadwell Parent and Teacher
Organization, Madison, TN
Friends of Bulloch Inc., Roswell, GA
Friends of the Wentzville High School
Math Team Inc., Foristell, MO
Gods Hope, Hillsboro, MO
Good Life Therapeutic Equestrian Center
Inc., Albany, GA
Greater Atlanta Dermatology Foundation
Inc., Atlanta, GA
Greater Collegedale School System
Endowment Fund Inc., Collegedale, TN
Grove City Star, Grove City, OH
Happy Days Daycare & Child
Development Center Inc., Diaz, AR
Hawley-South Granville Choral Parents
Association, Creedmoor, NC
Helen K. Kanoy Endowment Fund,
Thomasville, NC
Help or Motivate Everybody, Inc., Dallas,
TX
Helping Hands of America Association,
Winston Salem, NC
Huntsville Chapter of the American
Institute of Banking, Huntsville, AL
Indiana Minority Consortium on
Substance Abuse Inc., Muncie, IN
International Society of Welding
Educators, Inc., Miami, FL
Irving Schools Crime Stoppers Inc.,
Irving, TX
Journey of the Heart International, Falcon
Heights, MN
Kids School Tools Inc., Macon, GA
Life Change Technologies of Ohio Inc.,
Kent, OH
Matlack Specialized Creative Ministries,
Bayonet, FL
Medford Educational Institute Inc.,
Medford, OR
Metropolitan Milwaukee Civic Alliance,
Milwaukee, WI
Middle East Development and Science
Institute Inc., Potomac, MD

June 15, 1998

Mitchell High School Athletic Booster
Club, Colorado Springs, CO
Monacan Band Boosters Association,
Richmond, VA
Mother Divine Love Foundation,
Burlingame, CA
Mountaintop Soccer Association Inc.,
Swanton, MD
National Foundation for Families,
Auburn, WA
National Service Organization of Cosa
Inc., Louisville, KY
Nehemiah Project Inc., Dysart, PA
North Pittsburgh Quilters Guild,
Wexford, PA
North Springs Baptist Church, Colorado
Springs, CO
Northwest Arkansas Society of
Diagnostic Medical Sonographers,
Springdale, AR
Ohio Association of Casa and Gal
Parachute, Columbus, OH
100 Black Men of West Tennessee,
Jackson, TN
One Byte At A Time Inc., Nampa, ID
Osceola & St. Croix Valley Railway Inc.,
Osceola, WI
Overcoming Christians Inc., Keller, TX
Overseas Medical Foundation, San Jose,
CA
Parents for Parity, Flossmoor, IL
Pearl M. Goodwin Charitable Trust,
Garden City, NY
Permian Basin Childs Play Inc., Odessa,
TX
Pet Adoption Nursery of West County,
Chesterfield, MO
Positive Images Southwest Mississippi
Community Outreach Inc., Tylertown,
MS
Purdue Student Broadcasting Foundation
Inc., Lafayette, IN
Rick Finley Memorial Inc., Newark, AR
Royal Foli Bebe A Ayi Foundation,
Washington, DC
Russellville Womans Club, Russellville,
KY
Safe Medicine for Consumers, San
Andreas, CA
Saginaw Valley Safety and Health
Council, Midland, MI
Salinas Valley Youth Soccer League,
Salinas, CA
San Diego Big Book, Lakeside, CA
San Diego Youth & Adult Coalition, San
Diego, CA
San Jose Kendo Dojo, Santa Clara, CA

June 15, 1998

Santa Monica Youth Athletic Foundation,
Santa Monica, CA
Saturday Seminars, Albany, CA
Sausalito Sister City Committee Inc.,
Sausalito, CA
Save Our Bays and Beaches, Kailua, HI
Save Our Future, Los Angeles, CA
Save Our Youth Arts & Education
Organization, Pasadena, CA
Seattle Kobe Sister City Association,
Seattle, WA
Secular Humanists of Los Angeles, Los
Angeles, CA
See Above Productions, Agoura Hills,
CA
Shirts-N-Skins, Los Angeles, CA
Sibling Communication Network,
Tarzana, CA
Sierra Classic Foundation, Sacramento,
CA
Sigma Tau Educational Foundation,
Mercer Island, WA
Simba-Sis, Pomona, CA
Skating Club of North Carolina Inc.,
Cary, NC
Sober Musicians Fundraiser, Santa
Monica, CA
Sonoma Valley Field of Dreams,
Sonoma, CA
Sonrise Medical Clinic Inc.,
N. Hollywood, CA
South Whittier Community Coordinating
Council, Whittier, CA
Southwest Repertory Theatre at Santa Fe
Inc., Norman, OK
Southwest Shalom Ministries for Women,
Waco, TX
Southwest Sports Inc., Louisville, KY
Sovereign Grace Ministries of Colorado
Inc., Canon City, CO
Space Arts Cener, Inc., Lexington, MA
Spaha, Inc., Saratoga Springs, NY
Spare Parts Theatre, Greensboro, NC
Special Equestrians of the Treasure Coast
Inc., Vero Beach, FL
Special Needs Network, Montrose, CO
Special Therapeutic Equestrian Program,
Greenwood, NE
S P I N Recycling, Provo, UT
Spirit of Truth Foundation, Upper
Marlboro, MD
S P O T Inc., Tahlequah, OK
Spoken for Spinal Cord Injury, Madison,
WI
Sprayberry Band Parents Association
Inc., Marietta, GA
Spring Creek Volunteer Fire Association,
Kentwood, LA

38

Spring Brook Resident Council, Moline,
IL
Spring Hill Z-Bar Ranch Inc., Hays, KS
Spring I S D Education Foundation,
Houston, TX
Spring Lake Centennial Playground
Committee, Spring Lake, NJ
Spring of Life Skills Developers,
Inglewood, CA
Springville Preservation Society,
Springville, AL
Spud Webb Youth Foundation, Dallas,
TX
Square One for Youth, Heath, OH
Squeaky Janitorial Services, Conroe, TX
SS Peter & Pauls Home and School
Association, Boonville, MO
SSOSS Outreach Inc., Hollywood, FL
St. Agape Corporation, Wilmington, DE
St. Barnabas Endowment Foundation,
Chicago, IL
St. Barnard Courthouse Restoration
Corporation, Chalmette, LA
St. Bridgets Educational Foundation,
Minneapolis, MN
St. Charles Chamber of Commerce
Business & Education Foundation,
St. Charles, MO
St. Charles Housing II Inc., Pt. Charlotte,
FL
St. Clouds Area Tenants Union,
St. Cloud, MN
St. Francis County Parents Support
Group, Marianna, AR
St. Francis-St. Joseph Catholic Worker
House, Cincinnati, OH
St. James Housing Trust Inc., San
Antonio, TX
St. John Christian Care Center Inc.,
Oklahoma City, OK
St. John Community Development
Corporation, Camden, NJ
St. Johns County Christian Action
Council Inc., St. Augustine, FL
St. Josephs Home Inc., West Milwaukee,
WI
St. Louis Bicycleworkers Inc., St. Louis,
MO
St. Louis Co. National Steeplechase
Foundation, St. Louis, MO
St. Margaret Shelter Care Inc.,
Minneapolis, MN
St. Mark Outreach Center, Cincinnati,
OH
St. Marthas Senior Care Center,
Claremont, CA
St. Martins Church Foundation Inc.,
Berlin, MD

1998–24 I.R.B.

St. Marys Church Hamilton Village,
Philadelphia, PA
St. Marys Housing Development
Corporation, Glendale, AZ
St. Michaels Store, Perryville, MO
St. Oswalds-in-the-Fields Historic
Corporation, Oregon, MO
St. Paul Ciudad Romero Sister City
Project, St. Paul, MN
St. Petersburg Junior Football Athletic
Association Inc., St. Petersburg, FL
St. Petersburg Martin Luther King Jr.
Commemorative Organization Inc.,
St. Petersburg, FL
St. Tammany Community Housing
Resource Board, Slidell, LA
St. Vincent De Paul Society of the
Chippewa Valley Inc., Altoona, WI
Sta-Home Hospice Inc., Carthage, MS
Stacy Lane Art and Nature Center,
Leonard, MI
Stan-Beck Ministries Inc., Abilene, TX
Stand by Me Boys Ranch Inc., Big
Sandy, TX
Standard Bearer Ministries Inc., Zachary,
LA
Stanley Historic Foundation Inc., Estes
Park, CO
Star Foundation for Children, Inc.,
Melrose, MA
Starbright Pavilion Foundation, Los
Angeles, CA
Stark Citizens Opposing Pollution of the
Environment Inc., Massillon, OH
Stark County Emergency and Homeless
Shelter, Canton, OH
Stark County Golf Charities Inc., Canton,
OH
Stark County Out of Poverty Partnership
Incorporated, Canton, OH
State International Performing Arts
Studios Inc., Benton Harbor, MI
Statesville High School Renaissance
Foundation, Statesville, NC
Statewide Parent Association for the
Childrens Effort Inc., E. Orange, NJ
Steele Creek Library Association,
Charlotte, NC
Steelville Area Historical Society,
Steelville, MO

1998–24 I.R.B.

Stenton Arms Complex Tenants Council,
Philadelphia, PA
Step Ahead Inc., Pinellas Park, FL
Step of Faith Inc., St. Petersburg, FL
Stephen House, W. Bend, WI
Stephens County Food Bank Inc.,
Toccoa, GA
Stepping Stone Foundation Inc., Cape
Coral, FL
Sterling Heights Utica Shelby Township
Crime Stoppers Inc., Sterling Hts., MI
Still Hope Ministries Inc., Mount Laurel,
NJ
Stillpoint Ministries Inc., Black
Mountain, NC
Stingray Aquatic Foundation Inc., Miami,
FL
Stormy Weather Productions, Inc., New
York, NY
Stonevale Press Inc., Towson, MD
Stonewall Estates Group Home Inc.,
Fredericksburg, VA
Stopgap Incorporated, Corpus Christi,
TX
Stow Home Bible Study Ministries
Incorporated, Stow, OH
Straight Street Productions Inc., Kennard,
NE
Straightline Ministries Inc., Lansing, MI
Stride Forward Woodlawn Inc.,
Birmingham, AL
Stroke Association of Kentucky Inc.,
Lexington, KY
Strom Thurmond Educational Fund Inc.,
Washington, DC
Stuarts Draft Crime Prevention Council
Inc., Stuarts Draft, VA
Student Alliance, Chicago, IL
Student Benefit and Aid Committee for
Kids of DC Inc., Washington, DC
Student Planning Association Inc.,
Rockwall, TX
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

39

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.

Section 7428(c) Validation of
Certain Contributions Made
During Pendency of Declaratory
Judgment Proceedings
This announcement serves notice to potential donors that the organization listed
below has recently filed a timely declaratory judgment suit under section 7428 of
the Code, challenging revocation of its
status as an eligible donee under section
170(c)(2).
Protection under section 7428(c) of the
Code begins on the date that the notice of
revocation is published in the Internal
Revenue Bulletin and ends on the date on
which a court first determines that an organization is not described in section
170(c)(2), as more particularly set forth in
section 7428(c)(1). In the case of individual contributors, the maximum amount of
contributions protected during this period
is limited to $1,000.00, with a husband
and wife being treated as one contributor.
This protection is not extended to any individual who was responsible, in whole or
in part, for the acts or omissions of the organization that were the basis for the revocation. This protection also applies
(but without limitation as to amount) to
organizations described in section
170(c)(2) which are exempt from tax
under section 501(a). If the organization
ultimately prevails in its declaratory judgment suit, deductibility of contributions
would be subject to the normal limitations
set forth under section 170.
Fountain of Life, Inc.
Greensboro, NC

June 15, 1998

Announcement of the Consent Voluntary Suspension of Attorneys,
Certified Public Accountants, Enrolled Agents, and Enrolled Actuaries
From Practice Before the Internal Revenue Service
Under 31 Code of Federal Regulations,
Part 10, an attorney, certified public accountant, enrolled agent, or enrolled actuary, in order to avoid the institution or
conclusion of a proceeding for his disbarment or suspension from practice before
the Internal Revenue Service, may offer
his consent to suspension from such practice. The Director of Practice, in his discretion, may suspend an attorney, certified public accountant, enrolled agent, or
enrolled actuary in accordance with the
consent offered.
Attorneys, certified public accountants,
enrolled agents, and enrolled actuaries are
prohibited in any Internal Revenue Ser-

vice matter from directly or indirectly employing, accepting assistance from, being
employed by, or sharing fees with any
practitioner disbarred or suspended from
practice before the Internal Revenue Service.
To enable attorneys, certified public accountants, enrolled agents, and enrolled
actuaries to identify practitioners under
consent suspension from practice before the
Internal Revenue Service, the Director
of Practice will announce in the Internal
Revenue Bulletin the names and addresses of practitioners who have been
suspended from such practice, their designation as attorney, certified public ac-

countant, enrolled agent, or enrolled actuary, and date or period of suspension. This
announcement will appear in the weekly
Bulletin at the earliest practicable date
after such action and will continue to appear in the weekly Bulletins for five successive weeks or for as many weeks as is
practicable for each attorney, certified
public accountant, enrolled agent, or enrolled actuary so suspended and will be
consolidated and published in the Cumulative Bulletin.
The following individuals have been
placed under consent suspension from
practice before the Internal Revenue Service:

Name

Address

Designation

Date of Suspension

Soulides, James C.
Bujan, Frank
Field, Edward L.
Cito, Paul J.
Sproul, Jerry
Hunt, Russell
Oertli, William
Maynard, Richard
McDonald, Bill
Komendant, Howard
Kwiatek, Fabian A.
Brown, Patricia
Marshall, Robert
Baloun, Donald J.
Goldman, Harold J.
Garner, Darrow C.
Klein, Charles U.
Morgan, Robert I.
Teel, Jeffrey J.
Hancock, Randall M.
Allison Jr., Dale A.
Gogel, William A.
Bose, Gautem
Woods, W. Rex
Monahan, John
Swartz, Lewis A.

Berwyn, IL
Orland Park, IL
Topeka, KS
West Orange, NJ
Idaho Falls, ID
Pauls Valley, OK
Rochester, MN
Reno, NV
Reno, NV
Passaic, NJ
Silver Spring, MD
DeKalb, IL
Woodland Hills, CA
Palatine, IL
Summit, NJ
Austin, TX
Dunedin, FL
Brownsville, VT
Hollis, NH
Gardendale, AL
Blairsville, GA
North Hills, NY
Oak Brook, IL
Belleville, KS
Seattle, WA
Syosset, NY

CPA
CPA
CPA
CPA
CPA
CPA
CPA
CPA
Attorney
CPA
CPA
CPA
Attorney
CPA
CPA
CPA
CPA
Attorney
CPA
CPA
Attorney
Attorney
CPA
CPA
Attorney
CPA

January 1, 1998 to June 30, 2000
January 1, 1998 to June 30, 2000
January 27, 1998 to April 26, 1999
February 21, 1998 to May 20, 1999
February 25, 1998 to October 24, 1998
March 1, 1998 to June 30, 1998
Mach 4, 1998 to March 3, 2000
March 10, 1998 to March 9, 2002
March 10, 1998 to March 9, 2002
March 10, 1998 to September 9, 1998
March 16, 1998 to March 15, 2001
March 16, 1998 to September 15, 1999
March 18, 1998 to November 17, 2000
March 25, 1998 to November 24, 1998
March 27 , 1998 to September 26, 1998
April 1, 1998 to March 20, 2000
April 1, 1998 to September 30, 1999
April 2, 1998 to April 1, 2000
April 2, 1998 to April 1, 2001
Indefinite from April 13, 1998
April 15, 1998 to July 14, 2001
April 21, 1998 to April 20, 2002
May 1, 1998 to April 30, 2001
May 1, 1998 to January 31, 1999
May 1, 1998 to April 30, 2001
May 1, 1998 to April 30, 2002

June 15, 1998

40

1998–24 I.R.B.

Name

Address

Designation

Date of Suspension

Eckert, Bruce G.
Rozanski, Lawrence J.
Mangum, Carl E.
Reeser, Richard M.
Bailey, Thomas O.
Johnson, Kenneth E.
Deren, Joseph

Cleveland, OH
Pittsburg, PA
Morris Plains, NJ
Thornton, CO
Dallas, TX
Forest Lake, MN
Lackawanna, NY

CPA
CPA
CPA
CPA
CPA
CPA
Attorney

May 2, 1998 to May 1, 1999
June 1, 1998 to May 30, 2000
July 1, 1998 to December 31, 1999
July 1, 1998 to September 30, 1999
July 1, 1998 to June 30, 2001
July 1, 1998 to November 30, 1999
July 1, 1998 to June 30, 2001

Announcement of the Expedited Suspension of Attorneys, Certified Public
Accountants, Enrolled Agents, and Enrolled Actuaries From Practice
Before the Internal Revenue Service
Under title 31 of the Code of Federal
Regulations, section 10.76, the Director
of Practice is authorized to immediately
suspend from practice before the Internal
Revenue Service any practitioner who,
within five years from the date the expedited proceeding is instituted, (1) has had
a license to practice as an attorney, certified public accountant, or actuary suspended or revoked for cause; or (2) has
been convicted of any crime under title 26
of the United States Code or, of a felony
under title 18 of the United States Code
involving dishonesty or breach of trust.
Attorneys, certified public accountants,
enrolled agents, and enrolled actuaries are

prohibited in any Internal Revenue Service
matter from directly or indirectly employing, accepting assistance from, being employed by, or sharing fees with, any practitioner disbarred or suspended from practice
before the Internal Revenue Service.
To enable attorneys, certified public accountants, enrolled agents, and enrolled actuaries to identify practitioners under expedited suspension from practice before the
Internal Revenue Service, the Director of
Practice will announce in the Internal Revenue Bulletin the names and addresses of
practitioners who have been suspended
from such practice, their designation as attorney, certified public accountant, en-

rolled agent, or enrolled actuary, and date
or period of suspension. This announcement will appear in the weekly Bulletin at
the earliest practicable date after such action and will continue to appear in the
weekly Bulletins for five successive weeks
or for as many weeks as is practicable for
each attorney, certified public accountant,
enrolled agent, or enrolled actuary so suspended and will be consolidated and published in the Cumulative Bulletin.
The following individual has been
placed under suspension from practice before the Internal Revenue Service by virtue
of the expedited proceeding provisions of
the applicable regulations:

Name

Address

Designation

Date of Suspension

McDonald, Milton
Parsons, Gary D.

Stone Mountain, GA
Chattanooga, TN

Attorney
CPA

Indefinite from February 24, 1998
Indefinite from February 24, 1998

Buchanan, Steven

Phoenix, AZ

Attorney

Indefinite from February 24, 1998

Caplan, Alan

San Francisco, CA

Attorney

Indefinite from February 24, 1998

Delany, R. Emmet

Ridgefield, CT

Attorney

Indefinite from February 24, 1998

Hirsch, Sheldon

Brooklyn, NY

CPA

Indefinite from February 24, 1998

Newman, Peter R.

Syossett, NY

Attorney

Indefinite from February 24, 1998

Land, Gary
Hunt, William D.
Hamilton, Robert
Rabinowitz, Emile
McCaffrey, Michael
Eisenstein, Joel

Fayetteville, AR
Tulsa, OK
Corpus Christie, TX
Minnetonka, MN
Wheaton, IL
St. Charles, MO

Enrolled Agent
Attorney
Attorney
Enrolled Agent
CPA
Attorney

Indefinite from February 24, 1998
Indefinite from February 24, 1998
Indefinite from February 24, 1998
Indefinite from February 24, 1998
Indefinite from February 24, 1998
Indefinite from February 24, 1998

1998–24 I.R.B.

41

June 15, 1998

Name

Address

Designation

Date of Suspension

Cannavo Jr., Joseph S.
Tilker, Robert M.
Toms, James H.
Everett, Kenneth
Frederick, Charles
Artho, David
Seale, Forrest I.
Yancey, Quinton E.
Hunnicut, Benjamin
Finkel, Merle
Mullay, Carl P.
Cunning, Dennis A.
Adamson, Steven A.
Bowman, David W.
Beezley, Jack L.
Cunningham, Andrew
Palmquist, Craig S.
Ross, Mark J.
Madoch, Lawrence
Taylor, George M.
Casey, Kenneth J.
Akolt III, John P.
Dowdy, Frank
Eckert, Bruce G.
Rozanski, Lawrence J.
Mangum, Carl E.
Reeser, Richard M.
Bailey, Thomas O.
Johnson, Kenneth E.
Deren, Joseph

St. Louis, MO
Fairfax, VA
Hendersonville, NC
New York, NY
Elk Grove
Lubbock, TX
San Antonio, TX
Stephens City, VA
Reseda, CA
Beverly Hills, CA
Swoyersville, PA
Molalla, OR
Nampa, ID
Colorado Springs, CO
Dallas, TX
Hatfield, PA
Seattle, WA
Columbus, OH
Elgin, IL
Springfield, IL
Corte Madera, CA
Denver, CO
Huntsville, AL
Cleveland, OH
Pittsburgh, PA
Morris Plains, NJ
Thornton, CO
Dallas, TX
Forest Lake, MN
Lackawanna, NY

Attorney
CPA
Attorney
Attorney
Enrolled Agent
CPA
CPA
CPA
CPA
CPA
CPA
CPA
Attorney
Attorney
Attorney
CPA
Attorney
Attorney
CPA
Attorney
CPA
Attorney
CPA
CPA
CPA
CPA
CPA
CPA
CPA
Attorney

Indefinite from February 24, 1998
Indefinite from February 24, 1998
Indefinite from February 24, 1998
Indefinite from February 24, 1998
Indefinite from March 13, 1998
Indefinite from March 18, 1998
Indefinite from March 18, 1998
Indefinite from March 18, 1998
Indefinite from March 18, 1998
Indefinite from March 18, 1998
Indefinite from March 18, 1998
Indefinite from March 18, 1998
Indefinite from April 14, 1998
Indefinite from April 21, 1998
Indefinite from April 21, 1998
Indefinite from April 28, 1998
Indefinite from April 21, 1998
Indefinite from April 21, 1998
Indefinite from April 21, 1998
Indefinite from April 21, 1998
Indefinite from April 21, 1998
Indefinite from April 21, 1998
Indefinite from April 28, 1998
May 2, 1998 to May 1, 1999
June 1, 1998 to May 30, 2000
July 1, 1998 to December 31, 1999
July 1, 1998 to September 30, 1999
July 1, 1998 to June 30, 2001
July 1, 1998 to November 30, 1999
July 1, 1998 to June 30, 2001

June 15, 1998

42

1998–24 I.R.B.

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
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.

1998–24 I.R.B.

43

June 15, 1998

Numerical Finding List1

Notices—Continued

Revenue Procedures—Continued

Bulletins 1998–1 through 1998–23

98–19, 1998–13 I.R.B. 24
98–20, 1998–13 I.R.B. 25
98–21, 1998–15 I.R.B. 14
98–22, 1998–17 I.R.B. 5
98–23, 1998–18 I.R.B. 9
98–24, 1998–17 I.R.B. 5
98–25, 1998–18 I.R.B. 11
98–26, 1998–18 I.R.B. 14
98–27, 1998–18 I.R.B. 14
98–28, 1998–19 I.R.B. 7
98–29, 1998–22 I.R.B. 8
98–30, 1998–22 I.R.B. 9
98–31, 1998–22 I.R.B. 10
98–32, 1998–22 I.R.B. 23

98–22, 1998–12 I.R.B. 11
98–23, 1998–10 I.R.B. 30
98–24, 1998–10 I.R.B. 31
98–25, 1998–11 I.R.B. 7
98–26, 1998–13 I.R.B. 26
98–27, 1998–15 I.R.B. 15
98–28, 1998–15 I.R.B. 14
98–29, 1998–15 I.R.B. 22
98–30, 1998–17 I.R.B. 6
98–31, 1998–23 I.R.B. 9
98–32, 1998–17 I.R.B. 11
98–33, 1998–19 I.R.B. 7
98–34, 1998–18 I.R.B. 15
98–35, 1998–21 I.R.B. 6
98–36, 1998–23 I.R.B. 10

Announcements:
98–1, 1998–2 I.R.B. 38
98–2, 1998–2 I.R.B. 38
98–3, 1998–2 I.R.B. 38
98–4, 1998–4 I.R.B. 31
98–5, 1998–5 I.R.B. 25
98–6, 1998–5 I.R.B. 25
98–7, 1998–5 I.R.B. 26
98–8, 1998–6 I.R.B. 96
98–9, 1998–7 I.R.B. 35
98–10, 1998–7 I.R.B. 35
98–11, 1998–8 I.R.B. 42
98–12, 1998–8 I.R.B. 43
98–13, 1998–8 I.R.B. 43
98–14, 1998–8 I.R.B. 44
98–15, 1998–10 I.R.B. 36
98–16, 1998–9 I.R.B. 17
98–17, 1998–9 I.R.B. 16
98–18, 1998–10 I.R.B. 44
98–19, 1998–10 I.R.B. 44
98–20, 1998–11 I.R.B. 25
98–21, 1998–11 I.R.B. 26
98–22, 1998–12 I.R.B. 33
98–23, 1998–12 I.R.B. 34
98–24, 1998–12 I.R.B. 35
98–25, 1998–13 I.R.B. 43
98–26, 1998–14 I.R.B. 28
98–27, 1998–15 I.R.B. 30
98–28, 1998–15 I.R.B. 30
98–29, 1998–16 I.R.B. 48
98–30, 1998–17 I.R.B. 38
98–32, 1998–17 I.R.B. 39
98–33, 1998–17 I.R.B. 39
98–34, 1998–17 I.R.B. 39
98–35, 1998–17 I.R.B. 40
98–36, 1998–18 I.R.B. 18
98–37, 1998–19 I.R.B. 24
98–38, 1998–19 I.R.B. 26
98–39, 1998–20 I.R.B. 24
98–40, 1998–20 I.R.B. 24
98–41, 1998–20 I.R.B. 25
98–42, 1998–21 I.R.B. 26
98–43, 1998–21 I.R.B. 26
98–44, 1998–22 I.R.B. 24
98–45, 1998–23 I.R.B. 18
98–47, 1998–23 I.R.B. 5
98–49, 1998–23 I.R.B. 19
98–50, 1998–23 I.R.B. 20
Notices:
98–1, 1998–3 I.R.B. 42
98–2, 1998–2 I.R.B. 22
98–3, 1998–3 I.R.B. 48
98–4, 1998–2 I.R.B. 25
98–5, 1998–3 I.B.R. 49
98–6, 1998–3 I.R.B. 52
98–7, 1998–3 I.R.B. 54
98–8, 1998–4 I.R.B. 6
98–9, 1998–4 I.R.B. 8
98–10, 1998–6 I.R.B. 9
98–11, 1998–6 I.R.B. 18
98–12, 1998–5 I.R.B. 12
98–13, 1998–6 I.R.B. 19
98–14, 1998–8 I.R.B. 27
98–15, 1998–9 I.R.B. 8
98–16, 1998–15 I.R.B. 12
98–17, 1998–11 I.R.B. 6
98–18, 1998–12 I.R.B. 11

Proposed Regulations:
PS–158–86, 1998–11 I.R.B. 13
REG–100841–97, 1998–8 I.R.B. 30
REG–102144–98, 1998–15 I.R.B. 25
REG–102894–97, 1998–3 I.R.B. 59
REG–104062–97, 1998–10 I.R.B. 34
REG–104537–97, 1998–16 I.R.B. 21
REG–104691–97, 1998–11 I.R.B. 13
REG–105163–97, 1998–8 I.R.B. 31
REG–109333–97, 1998–9 I.R.B. 9
REG–109704–97, 1998–3 I.R.B. 60
REG–110965–97, 1998–13 I.R.B. 42
REG–115795–97, 1998–8 I.R.B. 33
REG–119449–97, 1998–10 I.R.B. 35
REG–120200–97, 1998–12 I.R.B. 32
REG–120882–97, 1998–14 I.R.B. 25
REG–121268–97, 1998–20 I.R.B. 12
REG–121755–97, 1998–9 I.R.B. 13
REG–208299–90, 1998–16 I.R.B. 26
REG–209276–87, 1998–11 I.R.B. 18
REG–209322–82, 1998–15 I.R.B. 26
REG–209373–81, 1998–14 I.R.B. 26
REG–209463–82, 1998–4 I.R.B. 27
REG–209476–82, 1998–8 I.R.B. 36
REG–209484–87, 1998–8 I.R.B. 40
REG–209485–86, 1998–11 I.R.B. 21
REG–209682–94, 1998–17 I.R.B. 20
REG–209807–95, 1998–8 I.R.B. 40
REG–243025–96, 1998–18 I.R.B. 18
REG–251502–96, 1998–9 I.R.B. 14
REG–251698–96, 1998–20 I.R.B. 14
Revenue Procedures:
98–1, 1998–1 I.R.B. 7
98–2, 1998–1 I.R.B. 74
98–3, 1998–1 I.R.B. 100
98–4, 1998–1 I.R.B. 113
98–5, 1998–1 I.R.B. 155
98–6, 1998–1 I.R.B. 183
98–7, 1998–1 I.R.B. 222
98–8, 1998–1 I.R.B. 225
98–9, 1998–3 I.R.B. 56
98–10, 1998–2 I.R.B. 35
98–11, 1998–4 I.R.B. 9
98–12, 1998–4 I.R.B. 18
98–13, 1998–4 I.R.B. 21
98–14, 1998–4 I.R.B. 22
98–15, 1998–4 I.R.B. 25
98–16, 1998–5 I.R.B. 19
98–17, 1998–5 I.R.B. 21
98–18, 1998–6 I.R.B. 20
98–19, 1998–7 I.R.B. 30
98–20, 1998–7 I.R.B. 32
98–21, 1998–8 I.R.B. 27

Revenue Rulings:
98–1, 1998–2 I.R.B. 5
98–2, 1998–2 I.R.B. 15
98–3, 1998–2 I.R.B. 4
98–4, 1998–2 I.R.B. 18
98–5, 1998–2 I.R.B. 20
98–6, 1998–4 I.R.B. 4
98–7, 1998–6 I.R.B. 6
98–8, 1998–7 I.R.B. 24
98–9, 1998–6 I.R.B. 5
98–10, 1998–10 I.R.B. 11
98–11, 1998–10 I.R.B. 13
98–12, 1998–10 I.R.B. 5
98–13, 1998–11 I.R.B. 4
98–14, 1998–11 I.R.B. 4
98–15, 1998–12 I.R.B. 6
98–16, 1998–13 I.R.B. 18
98–17, 1998–13 I.R.B. 21
98–18, 1998–14 I.R.B. 22
98–19, 1998–15 I.R.B. 5
98–20, 1998–15 I.R.B. 8
98–21, 1998–18 I.R.B. 7
98–22, 1998–19 I.R.B. 5
98–23, 1998–18 I.R.B. 5
98–24, 1998–19 I.R.B. 6
98–25, 1998–19 I.R.B. 4
98–26, 1998–21 I.R.B. 4
98–27, 1998–22 I.R.B. 4
98–28, 1998–22 I.R.B. 5
Treasury Decisions:
8740, 1998–3 I.R.B. 4
8741, 1998–3 I.R.B. 6
8742, 1998–5 I.R.B. 4
8743, 1998–7 I.R.B. 26
8744, 1998–7 I.R.B. 20
8745, 1998–7 I.R.B. 15
8746, 1998–7 I.R.B. 4
8747, 1998–7 I.R.B. 18
8748, 1998–8 I.R.B. 24
8749, 1998–7 I.R.B. 16
8750, 1998–8 I.R.B. 4
8751, 1998–10 I.R.B. 23
8752, 1998–9 I.R.B. 4
8753, 1998–9 I.R.B. 6
8754, 1998–10 I.R.B. 15
8755, 1998–10 I.R.B. 21
8756, 1998–12 I.R.B. 4
8757, 1998–13 I.R.B. 4
8758, 1998–13 I.R.B. 15
8759, 1998–13 I.R.B. 19
8760, 1998–14 I.R.B. 4
8761, 1998–14 I.R.B. 13
8762, 1998–14 I.R.B. 15

1 See footnote at end of list.

June 15, 1998

44

1998–24 I.R.B.

Numerical Finding List—Continued
Bulletins 1998–1 through 1998–23
Treasury Decisions—Continued
8763, 1998–15 I.R.B. 5
8764, 1998–15 I.R.B. 9
8765, 1998–16 I.R.B. 11
8766, 1998–16 I.R.B. 17
8767, 1998–16 I.R.B. 4
8768, 1998–20 I.R.B. 4

1 A cumulative list of all revenue rulings, revenue

procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 1997–27 through
1997–52 will be found in Internal Revenue Bulletin
1998–1, dated January 5, 1998.

1998–24 I.R.B.

45

June 15, 1998

Finding List of Current Action on
Previously Published Items1

Revenue Procedures—Continued

Bulletins 1998–1 through 1998–23

97–53
Superseded by
98–3, 1998–1 I.R.B. 100

Revenue Procedures:

Revenue Rulings:

91–59
Updated and superseded by
98–25, 1998–11 I.R.B. 7

68–352
Obsoleted by
98–24, 1998–19 I.R.B. 6

94–16
Modified and superseded by
98–22, 1998–12 I.R.B. 11

70–225
Modified by
98–27, 1998–22 I.R.B. 4

93–62
Modified and superseded by
98–22, 1998–12 I.R.B. 11

73–198
Modified by
98–24, 1998–19 I.R.B. 6

95–35
95–35A
Superseded by
98–19, 1998–7 I.R.B. 30

75–17
Supplemented and superseded by
98–5, 1998–2 I.R.B. 20

96–29
Modified and superseded by
98–22, 1998–12 I.R.B. 11
97–1
Superseded by
98–1, 1998–1 I.R.B. 7
97–2
Superseded by
98–2, 1998–1 I.R.B. 74

75–406
Obsoleted by
98–27, 1998–22 I.R.B. 4
92–19
Supplemented in part by
98–2, 1998–2 I.R.B. 15
96–30
Obsoleted by
98–27, 1998–22 I.R.B. 4

97–3
Superseded by
98–3, 1998–1 I.R.B. 100
97–4
Superseded by
98–4, 1998–1 I.R.B. 113
97–5
Superseded by
98–5, 1998–1 I.R.B. 155
97–6
Superseded by
98–6, 1998–1 I.R.B. 183
97–7
Superseded by
98–7, 1998–1 I.R.B. 222
97–8
Superseded by
98–8, 1998–1 I.R.B. 225
97–21
Superseded by
98–2, 1998–1 I.R.B. 74
97–24
97–24A
Superseded by
98–33, 1998–19 I.R.B. 7
97–26
Obsoleted by
98–28, 1998–15 I.R.B. 14
97–28
Superseded by
98–36, 1998–23 I.R.B. 10
97–34
Superseded by
98–35, 1998–21 I.R.B. 6

1 A cumulative finding list for previously published

items mentioned in Internal Revenue Bulletins
1997–27 through 1997–52 will be found in Internal
Revenue Bulletin 1998–1, dated January 5, 1998.

June 15, 1998

46

1998–24 I.R.B.

INTERNAL REVENUE BULLETIN
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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3A4ea89535aa10fd10. Public record. Not legal advice.
