Bulletin No. 1996–45

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Text

November 4, 1996

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

EMPLOYEE PLANS

Rev. Rul. 96–41, page 4.

Educational assistance after termination of employment. Educational assistance plans that provide benefits to participants by reason of their employment with

the employer will not fail to qualify as educational

assistance programs described in section 127(b) of the

Code merely because eligible participants include former

employees.

Announcement 96–112, page 7.

The initial notice and election period for a savings

incentive match plan for employees of small employers

described in section 408(p) of the Code as added by the

Small Business Job Protection Act of 1996, P.L. 104–

188, is being extended.

Rev. Rul. 96–52, page 5.

Federal rates; adjusted federal rates; adjusted federal long-term rate, and the long-term exempt rate.

For purposes of sections 1274, 1288, 382, and other

sections of the Code, tables set forth the rates for

November 1996.

Finding Lists begin on page 13.

Announcements of Disbarments and Suspensions begin on page 10.

Monthly Index for October is on page 15.

EXEMPT ORGANIZATIONS

Announcement 96–114, page 7.

A list is given of organizations now classified as private

foundations.

ADMINISTRATIVE

Announcement 96–115, page 9.

Proposed regulations FI–59–94, 1996–30 I.R.B. 23,

relating to the allowance of a deduction for a partially

worthless debt when the terms of a debt instrument

have been modified, is corrected.

Mission of the Service

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 products and services; and perform in a

manner warranting the highest degree of public

confidence in our integrity, efficiency and fairness.

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 of ficers 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 cour tesy 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.

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.

court decisions, rulings, and procedures must be considered, and Service personnel and others concerned are

cautioned against reaching the same conclusions in

other cases unless the facts and circumstances are

substantially the same.

The Bulletin is divided into four parts as follows:

Part I.—1986 Code.

This part includes rulings and decisions based on

provisions of the Internal Revenue Code of 1986.

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,

The first Bulletin for each month includes an index for

the matters published during the preceding month.

These monthly indexes are cumulated on a quarterly and

semiannual basis, and are published in the first Bulletin

of the succeeding quarterly and semi-annual 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, D.C. 20402.

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

Section 42.—Low-Income Housing

Credit

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the

month of November 1996. See Rev. Rul. 96–52,

page 5.

Section 127.— Educational

Assistance Programs

26 CFR 1.127–2: Educational Assistance Programs.

Educational assistance after termination of employment. Educational assistance plans that provide benefits to

participants by reason of their employment with the employer will not fail to

qualify as educational assistance programs described in section 127(b) of the

Code merely because eligible participants include former employees.

Situation (2). In connection with its

corporate ‘‘downsizing’’ efforts, employer Y adopts a plan that is intended

to be a qualified educational assistance

program. The plan provides educational

assistance to participants to help them

obtain education and training. The participants are former employees of Y

whose employment with Y has terminated in connection with a cutback in

operations affecting a broad range of

personnel. Under the plan, Y pays expenses incurred by or on behalf of plan

participants after termination of employment for instruction and training (including instruction that is part of a

degree program as well as vocational

and technical training) that constitutes

‘‘education’’ as that term is used in

section 127 and the regulations thereunder.

LAW AND ANALYSIS

Rev. Rul. 96–41

ISSUE

Does a plan fail to qualify as an

educational assistance program described in section 127(b) of the Internal

Revenue Code if the plan provides benefits to individuals after their employment has terminated, regardless of the

reason for termination?

FACTS

Situation (1). Employer X maintains a

plan that is intended to be a qualified

educational assistance program. The

plan provides educational assistance to

participants to help them obtain education and training. Under the plan, X

pays expenses incurred by or on behalf

of plan participants for instruction and

training (including instruction that is

part of a degree program as well as

vocational and technical training) that

constitutes ‘‘education’’ as that term is

used in section 127 and the regulations

thereunder. Employees who qualify as

participants earn educational benefits for

hours of service according to a schedule

of benefits. The participants are current

and former employees of X, and a

participant may take courses of instruction either during employment or after

termination of employment with X. The

former employees who are participants

include individuals who terminated their

employment voluntarily (including by

retirement), were laid off, were terminated involuntarily, or terminated because of disability.

Section 127(a) provides that gross

income of an employee does not include

amounts paid or expenses incurred by

the employer for educational assistance

to the employee if the assistance is

furnished pursuant to a program described in § 127(b). Section 127(b)(1)

provides that, for purposes of § 127, an

educational assistance program is a

separate written plan of an employer for

the exclusive benefit of his employees

to provide such employees with educational assistance, and that the program

must meet the other requirements set

forth in § 127(b).

A qualified educational assistance

program is permitted to provide benefits

only to employees, and not to spouses

or dependents of employees. Section

1.127–2(d) of the Income Tax Regulations provides that a qualified educational assistance program is only permitted to benefit employees of the

employer, including, at the employer’s

option, individuals who are employees

within the meaning of section 1.127–

2(h)(1) of the regulations. Under section

1.127–2(h)(1)(i) of the regulations, the

term ‘‘employee’’ includes a retired, disabled or laid-off employee.

HOLDING

In both Situations (1) and (2), the

plans provide benefits to participants by

reason of their employment with the

employer and, accordingly, will not fail

to qualify as educational assistance programs described in section 127(b) merely

because eligible participants include

former employees, regardless of the reason for termination of employment.

FURTHER INFORMATION

For further information regarding this

Revenue Ruling contact Monice

Rosenbaum of the Office of the Associate Chief Counsel (Employee Benefits

and Exempt Organizations) at (202)

622–6070 (not a toll-free call).

Section 280G.—Golden Parachute

Payments

Federal short-term, mid-term, and long-term

rates are set forth for the month of November

1996. See Rev. Rul. 96–52, page 5.

Section 382.—Limitation on Net

Operating Loss Carryforwards and

Certain Built-In Losses Following

Ownership Change

The adjusted federal long-term rate is set forth

for the month of November 1996. See Rev. Rul.

96–52, page 5.

Section 412.—Minimum Funding

Standards

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the

month of November 1996. See Rev. Rul. 96–52,

page 5.

Section 467.—Certain Payments

for the Use of Property or Services

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the

month of November 1996. See Rev. Rul. 96–52,

page 5.

Section 468.—Special Rules for

Mining and Solid Waste

Reclamation and Closing Costs

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the

month of November 1996. See Rev. Rul. 96–52,

page 5.

Section 483.—Interest on Certain

Deferred Payments

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the

month of November 1996. See Rev. Rul. 96–52,

page 5.

Section 807.—Rules for Certain

Reserves

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the

month of November 1996. See Rev. Rul. 96–52,

page 5.

Section 846.—Discounted Unpaid

Losses Defined

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the

month of November 1996. See Rev. Rul. 96–52,

this page.

Section 1274.—Determination of

Issue Price in the Case of Certain

Debt Instruments Issued for

Property

(Also sections 42, 280G, 382, 412, 467, 468, 482,

483, 807, 846, 1288, 7520, 7872.)

Federal rates; adjusted federal

rates; adjusted federal long-term rate,

and the long-term exempt rate. For

purposes of sections 1274, 1288, 382,

and other sections of the Code, tables

set forth the rates for November 1996.

Rev. Rul. 96–52

This revenue ruling provides various

prescribed rates for federal income tax

purposes for November 1996 (the current month.) Table 1 contains the shortterm, mid-term, and long-term applicable federal rates (AFR) for the current

month for purposes of section 1274(d)

of the Internal Revenue Code. Table 2

contains the short-term, mid-term, and

long-term adjusted applicable federal

rates (adjusted AFR) for the current

month for purposes of section 1288(b).

Table 3 sets forth the adjusted federal

long-term rate and the long-term taxexempt rate described in section 382(f).

Table 4 contains the appropriate percentages for determining the low-income

housing credit described in section

42(b)(2) for buildings placed in service

during the current month. Finally, Table

5 contains the federal rate for determining the present value of an annuity, an

interest for life or for a term of years, or

a remainder or a reversionary interest

for purposes of section 7520.

REV. RUL. 96–52 TABLE 1

Applicable Federal Rates (AFR) for November 1996

Period for Compounding

Annual

Semiannual

Quarterly

Monthly

5.96%

6.56%

7.16%

7.78%

5.87%

6.46%

7.04%

7.63%

5.83%

6.41%

6.98%

7.56%

5.80%

6.37%

6.94%

7.51%

6.60%

7.27%

7.94%

8.62%

9.98%

11.68%

6.49%

7.14%

7.79%

8.44%

9.74%

11.36%

6.44%

7.08%

7.72%

8.35%

9.62%

11.20%

6.40%

7.04%

7.67%

8.30%

9.55%

11.10%

7.02%

7.73%

8.45%

9.17%

6.90%

7.59%

8.28%

8.97%

6.84%

7.52%

8.20%

8.87%

6.80%

7.47%

8.14%

8.81%

Short-Term

AFR

110% AFR

120% AFR

130% AFR

Mid-Term

AFR

110% AFR

120% AFR

130% AFR

150% AFR

175% AFR

Long-Term

AFR

110% AFR

120% AFR

130% AFR

REV. RUL. 96–52 TABLE 2

Adjusted AFR for November 1996

Period for Compounding

Annual

Semiannual

Quarterly

Monthly

Short-term

adjusted AFR

3.95%

3.91%

3.89%

3.88%

Mid-term

adjusted AFR

4.73%

4.68%

4.65%

4.64%

Long-term

adjusted AFR

5.60%

5.52%

5.48%

5.46%

REV. RUL. 96–52 TABLE 3

Rates Under Section 382 for November 1996

Adjusted federal long-term rate for the current month

5.60%

Long-term tax-exempt rate for ownership changes during the current month (the highest of

the adjusted federal long-term rates for the current month and the prior two months.)

5.64%

REV. RUL. 96–52 TABLE 4

Appropriate Percentages Under Section 42(b)(2) for November 1996

Appropriate percentage for the 70% present value low-income housing credit

Appropriate percentage for the 30% present value low-income housing credit

8.60%

3.69%

REV. RUL. 96–52 TABLE 5

Rate Under Section 7520 for November 1996

Applicable federal rate for determining the present value of an annuity, an interest for life or

a term of years, or a remainder or reversionary interest

Section 1288.—Treatment of

Original Issue Discount on

Tax-Exempt Obligations

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the

month of November 1996. See Rev. Rul. 96–52,

page 5.

Section 7520.—Valuation Tables

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the

month of November 1996. See Rev. Rul. 96–52,

page 5.

8.0%

Section 7872.—Treatment of Loans

With Below-Market Interest Rates

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the

month of November 1996. See Rev. Rul. 96–52,

page 5.

Part IV. Items of General Interest

Transition Relief for SIMPLES

Announcement 96–112

PURPOSE

Section 1421 of the Small Business

Job Protection Act of 1996 (P.L. 104–

188), signed into law on August 20,

1996, established a simplified taxfavored retirement plan for small employers (the ‘‘SIMPLE plan’’) under

section 408(p) of the Internal Revenue

Code. The purpose of this announcement is to provide transition relief from

the 60-day election period and related

notice requirements in the case of

SIMPLE plans that begin January 1,

1997.

Under this transition relief, for a

SIMPLE plan that allows employees to

begin salary reduction contributions on

January 1, 1997, the employees’ salary

reduction election period may begin as

late as January 1, 1997. During this 60day election period, employees must be

permitted to prospectively make or

modify any salary reduction election.

BACKGROUND

SIMPLE plans can be established for

calendar years beginning after 1996.

Generally, SIMPLE plans can be established by any employer that, for the

prior year, had no more than 100 employees who received at least $5,000 in

compensation from the employer.

Under section 408(p), contributions to

a SIMPLE plan are made to individual

retirement accounts or annuities

(SIMPLE IRAs) that are established

under the SIMPLE plan adopted by the

employer. The Code provides that, if an

employer adopts a SIMPLE plan, all of

the employer’s eligible employees must

be given the opportunity to make salary

reduction contributions to their SIMPLE

IRAs (up to a maximum of $6,000 for

1997). The adopting employer is required to match 100 percent of employees’ salary reduction contributions up to

three percent of compensation. Alternatively, an employer may contribute two

percent of compensation for all eligible

employees or, for up to two out of five

years, match a lower percentage (but not

less than one percent of compensation.)

Section 408(p)(5)(C) provides that,

for each calendar year, each eligible

employee may elect, during the 60-day

period before the beginning of the calendar year (and the 60-day period be-

fore the first day the employee is eligible to participate), to participate in the

qualified salary reduction arrangement

under the SIMPLE plan maintained by

the employer, or to modify the amounts

subject to the arrangement. The statute

requires that the employer notify each

eligible employee immediately before

the election period of the employee’s

opportunity to make salary reduction

contributions and provide certain other

information.

TRANSITION RELIEF FOR PLANS

THAT BEGIN JANUARY 1, 1997

The 60-day period during which eligible employees may elect to make

salary reduction contributions under a

SIMPLE plan, or to modify prior elections, will not be required (but will be

permitted) to begin before January 1,

1997. For plans that begin January 1,

1997, the 60-day election period requirement can be satisfied by providing an

election period, of at least 60 days, that

includes either the date the employee

becomes eligible to make salary reduction contributions or the day immediately before that date. Thus, in the case

of a SIMPLE plan under which eligible

employees may begin making salary

reduction contributions on January 1,

1997, employees who are eligible employees as of that date must have an

election period of at least 60 continuous

days that begins between November 2,

1996, and January 1, 1997. This minimum 60-day election period could

be November 2 through December 31,

1996; January 1 through March 2, 1997;

or any continuous period of at least 60

days beginning between November 2,

1996, and January 1, 1997.

The election period cannot begin until

notice is provided to all eligible employees of their opportunity to make salary

reduction contributions, including the

summary description required by the

statute. An employer may permit an

eligible employee to begin making salary reduction contributions less than 60

days after receiving notice of the opportunity to make these contributions, but

in no event before January 1, 1997. The

employee must be given the opportunity

to prospectively modify the election during the remainder of the 60-day election

period.

PLANS THAT BEGIN AFTER

JANUARY 1, 1997

This announcement does not address

the treatment of SIMPLE plans established for 1997 that are first effective

after January 1, 1997. Further guidance

will be provided regarding those plans.

Foundations Status of Certain

Organizations

Announcement 96–114

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:

Action Foundation Inc., Washington, DC

Adopt Hunger of Utah, Inc., Salt Lake

City, UT

Affirmations III, Inc., Houston, TX

AJO Ambulance, Inc., Ajo, AZ

Altus Public School Foundation, Inc.,

Altus, OK

American Men’s Studies Association

Inc., Northampton, MA

Arizona Council for Sustainable

Development, Tempe, AZ

Association for Community Theatre

Excellence, Inc., Bourne, MA

Astronomical Institute for Research and

Education, Madill, OK

ASU Cycling Devils, Tempe, AZ

Austin Area Youth, Austin, TX

Austin Sickle Cell Anemia Association,

Inc., Austin, TX

Bay Area Veterans and Associates,

LaPorte, TX

Big Bend, Inc., Riverton, WY

Boulder Chorale, Boulder, CO

British American Youth Festival Theatre,

New York, NY

Brother Phi Brother, Inc., Fort Worth,

1996–45

I.R.B.

Buckingham Square Optimist Fund,

Inc., Aurora, CO

Business and Professional Womens

Heritage Association, Merrimack, NH

Cancer Treatment Research Foundation,

Inc., Arlington Heights, IL

Career Development Incorporated,

Holbrook, AZ

Casa Grande Regional Retirement

Community, Casa Grande, AZ

Celebration of Freedom, Inc., Boston,

Center for Indigenous Studies in the

Americas, Phoenix, AZ

Central Arizona Chapter of the A. Philip

Randolph Institute, Phoenix, AZ

Childrens Connection, Inc., Chester, NH

Christfest Productions, Inc., Austin, TX

Cibola County Community Systems,

Grants, NM

Cigarroa High-Crime Stoppers, Laredo,

City Art, Salt Lake City, UT

Clear Creek Project Graduation, Inc.,

League City, TX

Clinton County Council on Alcoholism

Inc., Plattsburgh, NY

Colorado Animal Refuge, Inc., Simla,

Colorado Drug Education Services,

Aurora, CO

Colorado Springs Volleyball Club,

Colorado Springs, CO

Cross Timbers Crisis Center,

Stephenville, TX

Daily Planet Option Store, Inc.,

Colorado Springs, CO

Dallas Womens Coalition, Dallas, TX

Dear Valley High School Band and Flag

Boosters, Inc., Glendale, AZ

Designated Driver Program, Inc., Austin,

Eagle Aquatic Team, Salt Lake City, UT

Edisto Wildlife Sanctuary Fund Edisto

Natural History Museum Inc., Tyrone,

Family Outreach Central, Inc., Houston,

Forth Worth Foreign Film Festival,

Forth Worth, TX

Foundation of Hope, Corpus Christi, TX

Friends of Horn Foundation, Bellaire,

Friends of Martha’s Vineyard Scouting,

Inc., Oak Bluffs, MA

Friends of the Utah Avalanche Forecast

Center, Inc., Holladay, UT

Glendale Kachina Rotary Foundation,

Inc., Glendale, AZ

Global Survival Inc., Riverdale, NY

Greater Houston Nutritional & Support

Service, Houston, TX

Hamshire-Fannett Education Foundation,

Hamshire, TX

1996–45

I.R.B.

Harrington Elementary School PTO,

Plano, TX

Hood-Erath County Foster Parents

Association, Stephenville, TX

Houston Steel Light Orchestra, Houston,

Human Enrichment and Learning

Project, Houston, TX

Hutchinson High School Booster Club,

Inc., Hutchinson, KS

Indian Health Care Clinic, Inc., Salt

Lake City, UT

International Leadership Group, Inc.,

Salt Lake City, UT

Join the Move, Austin, TX

Jones Township Historical Society Inc.,

Wilcox, PA

K.A.C.U., Inc. K.A.C.U.-FM, Abilene,

Kerrville South Volunteer Fire Dept,

Inc., Kerrville, TX

Kids Place, Salt Lake City, UT

Leadership Fort Worth, Forth Worth, TX

Leadership Forum of North Carolina,

Wilmington, NC

Learning Disabilities Association of

Norman, Norman, OK

Manassa Maulers, Inc., Manassa, CO

Mariposa Arts Foundation, Inc., Corpus

Christi, TX

Millennium 2000 Foundation LTD,

Littleton, CO

Millner Elderly Housing, Inc., Atlanta,

Millner Ridge Inc., Atlanta, GA

New Beginning Nutrition Food

Program, Humble, TX

New Mountain Volunteer Fire Dept.

Inc., Ore City, TX

New Southwest Orchestra, Albuquerque,

Northern New Mexico Volleyball

Association, Los Alamos, NM

Northwood Booster Club, Cedar Hill,

Oklahoma Homeless Network, Inc.,

Oklahoma City, OK

Orange Pathways Incorporated, Goshen,

Parents and Educators Achieving

Community Excellence, Mission, TX

Petroglyphs Por Los Ninos Coalition,

Santa Fe, NM

Pharr Chamber of Commerce, Pharr, TX

Piper Denver Outreach, Inc., Denver,

Point of Light, Sinton, TX

RHS, Inc., Albuquerque, NM

Rock Springs Youth Boys Basketball,

Rock Springs, WY

Sail Connecticut Access Program Inc.,

Branford, CT

Sal De Ahi, Santa Fe, NM

Salt Lake Mens Choir A Non-Profit

Utah Corporation DTD, Salt Lake

City, UT

Say Yes San Antonio With Luis Palau,

Inc., San Antonio, TX

Scotcrest, Inc., Houston, TX

S.D.N.C., Cheyenne, WY

Secaucus Lions Charities Inc., Cedar

Grove, NJ

Sedona Repertory Theater An Arizona

Non-Profit Corporation, Sedona, AZ

Serenty Center for Girls, Inc., Marlin,

Shawnee Mission North Band Parents

Club, Shawnee Mission, KS

Southeast Nutritious Food Program,

Houston, TX

South Texas Counsel on Alcohol and

Drug Abuse, Inc., Laredo, TX

South Valley Fire & Rescue Auxiliary,

Albuquerque, NM

Swedish-American Research Foundation

for Diet & Disease Inc., Morris

Plains, NJ

Take Pride in Arizona, Inc., Phoenix,

Task Force for Housing, Lock Haven,

Temple Bar Foundation, Washington,

Texas Bankers Foundation, Austin, TX

T.F.O.C. Incorporated, Conroe, TX

Third Eternal Baptist Community

Outreach, Philadelphia, PA

Thomas McNaughton Foundation for

Liver Transplants Inc., Baltimore, MD

Tri-State Conference Education Fund,

Pittsburgh, PA

Troika Productions, Washington, DC

Ulster Choral Society, Kingston, NY

United Fire Fighters Task of Prince

Georges County Maryland Inc.,

Capitol Heights, MD

Urban Center for Change Housing

Development Fund Corporation,

Brooklyn, NY

Utah Coalition of La Raza, Salt Lake

City, UT

VDT Housing Development Fund

Company, Inc., New York, NY

Veterans Support Services, Inc.,

Portland, ME

Wheat Ridge Coalition, Wheat Ridge,

Whole Brain Connection, Dallas, TX

Will Rogers PTO, Houston, TX

Williams Technology Initiative

Committee, Inc., Austin, TX

Winters A.C.E.S. Inc., Winters, TX

Word of Faith Outreach Food Program,

Channelview, TX

Work Work Opportunities of a

Rehabilitative Kind, Austin, TX

Young Israel Soup Kitchen Incorporated,

New Haven, CT

Youth Sports Systems, Inc.,

Albuquerque, NM

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.

Modifications of Bad Debts and

Dealer Assignments of Notional

Principal Contracts; Correction

Announcement 96–115

AGENCY: Internal Revenue Service,

Treasury.

ACTION: Correction to the notice of

proposed rulemaking by cross-reference

to temporary regulations.

SUMMARY: This document contains a

correction to the notice of proposed

rulemaking by cross-reference to temporary regulations (FI–59–94 [1996–30

I.R.B. 23]) which was published in the

Federal Register on Tuesday, June 25,

1996 (61 FR 32728). The notice of

proposed rulemaking by cross-reference

to temporary regulations relates to the

allowance of a deduction for a partially

worthless debt when the terms of a debt

instrument have been modified.

FOR FURTHER INFORMATION

CONTACT: Craig R. Wojay, (202) 622–

3920 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The notice of proposed rulemaking by

cross-reference to temporary regulations

that is subject to this correction is under

sections 166 and 1001 of the Internal

Revenue Code.

Need for Correction

As published, the notice of proposed

rulemaking by cross-reference to temporary regulations (FI–59–94) contains an

error which may prove to be misleading

and is in need of clarification.

Correction of Publication

Accordingly, the publication of the

notice of proposed rulemaking by crossreference to temporary regulations (FI–

59–94) which is the subject of FR Doc.

96–15831 is corrected as follows:

On page 32728, column 2, in the

heading, the RIN ‘‘RIN 1545–AT08’’ is

corrected to read ‘‘RIN 1545–AU06’’.

Cynthia E. Grigsby,

Chief, Regulations Unit,

Assistant Chief Counsel (Corporate).

(Filed by the Office of the Federal Register on

October 11, 1996, 8:45 a.m., and published in the

issue of the Federal Register for October 15, 1996,

61 F.R. 53688)

1996–45

I.R.B.

Announcement of the Disbarment, Suspension, or Consent to 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 Rev-

enue 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 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

accountant, 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

Lamb, Gordon W.

Anderson, Randall S.

Broderick, William J.

Ruggiero, John M.

Eklund, Mark

Stayner, G. Craig

Allen, Lehman D.

Hardgrove, David L.

Trader, John H.

Schmertz, Carl D.

Bengston, Wessel

Pullman, WA

Arlington Hgts, IL

Farmington Hills, MI

Rutland, VT

Portland, OR

Salt Lake City, UT

Lubbock, TX

Amarillo, TX

Kansas City, MO

Wilmette, IL

Chicago, IL

CPA

Attorney

CPA

Attorney

CPA

September 1, 1996 to January 31, 1997

September 1, 1996 to February 28, 1998

September 1, 1996 to November 30, 1996

September 1, 1996 to October 31, 1996

September 1, 1996 to February 28, 1997

September 15, 1996 to June 14, 1997

September 20, 1996 to September 19, 1998

September 21, 1996 to June 20, 1997

September 30, 1996 to March 29, 1997

October 1, 1996 to March 31, 1999

October 15, 1996 to April 14, 1997

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 actu-

aries 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, 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 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

Alleva, Donald

Rose, Robert M.

McGrath, Gregory

Finch, Kenneth L. Jr.

Mount Vernon, NY

Dallas, TX

New Smyrna Bch, FL

Pelham, AL

Enrolled Agent

Attorney

CPA

Indefinite from September 5, 1996

Indefinite from September 8, 1996

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

applies 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.

PHC—Personal Holding Company.

PO—Possession of the U.S.

FC—Foreign Country.

FICA—Federal Insurance Contribution Act.

Pub. L.—Public Law.

REIT—Real Estate Investment Trust.

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.

Rev. Proc.—Revenue Procedure.

Rev. Rul.—Revenue Ruling.

S—Subsidiary.

S.P.R.—Statements of Procedural Rules.

Stat.—Statutes at Large.

T—Target Corporation.

T.C.—Tax Court.

T.D.—Treasury Decision.

TFE—Transferee.

TFR—Transferor.

T.I.R.—Technical Information Release.

TP—Taxpayer.

TR—Trust.

TT—Trustee.

M—Minor.

U.S.C.—United States Code.

Nonacq.—Nonacquiescence.

X—Corporation.

O—Organization.

Y—Corporation.

P—Parent 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.

PR—Partner.

PRS—Partnership.

PTE—Prohibited Transaction Exemption.

Numerical Finding List1

Bulletins 1996–27 through 1996–44

Announcements:

96–61, 1996–27 I.R.B. 72

96–62, 1996–28 I.R.B. 55

96–63, 1996–29 I.R.B. 18

96–64, 1996–29 I.R.B. 18

96–65, 1996–29 I.R.B. 18

96–66, 1996–29 I.R.B. 19

96–67, 1996–30 I.R.B. 27

96–68, 1996–31 I.R.B. 45

96–69, 1996–32 I.R.B. 38

96–70, 1996–32 I.R.B. 40

96–71, 1996–33 I.R.B. 16

96–72, 1996–33 I.R.B. 16

96–73, 1996–33 I.R.B. 18

96–74, 1996–33 I.R.B. 19

96–75, 1996–34 I.R.B. 29

96–76, 1996–34 I.R.B. 29

96–77, 1996–35 I.R.B. 15

96–78, 1996–35 I.R.B. 15

96–79, 1996–35 I.R.B. 15

96–80, 1996–35 I.R.B. 16

96–81, 1996–36 I.R.B. 13

96–82, 1996–36 I.R.B. 14

96–83, 1996–36 I.R.B. 14

96–84, 1996–36 I.R.B. 14

96–85, 1996–37 I.R.B. 20

96–86, 1996–37 I.R.B. 21

96–87, 1996–37 I.R.B. 21

96–88, 1996–38 I.R.B. 150

96–89, 1996–37 I.R.B. 22

96–90, 1996–37 I.R.B. 22

96–91, 1996–37 I.R.B. 23

96–92, 1996–38 I.R.B. 151

96–93, 1996–38 I.R.B. 151

96–94, 1996–38 I.R.B. 153

96–96, 1996–39 I.R.B. 41

96–97, 1996–39 I.R.B. 41

96–98, 1996–39 I.R.B. 42

96–99, 1996–39 I.R.B. 42

96–100, 1996–40 I.R.B. 10

96–101, 1996–40 I.R.B. 10

96–102, 1996–40 I.R.B. 11

96–103, 1996–40 I.R.B. 12

96–104, 1996–41 I.R.B. 10

96–105, 1996–42 I.R.B. 19

96–106, 1996–42 I.R.B. 23

96–107, 1996–42 I.R.B. 27

96–108, 1996–44 I.R.B. 15

96–109, 1996–43 I.R.B. 76

96–110, 1996–43 I.R.B. 77

96–111, 1996–44 I.R.B. 16

96–113, 1996–44 I.R.B. 18

Notices—Continued

Revenue Rulings—Continued

96–38, 1996–31 I.R.B. 29

96–39, 1996–32 I.R.B. 8

96–40, 1996–33 I.R.B. 11

96–41, 1996–35 I.R.B. 6

96–42, 1996–35 I.R.B. 6

96–43, 1996–36 I.R.B. 7

96–44, 1996–36 I.R.B. 7

96–45, 1996–39 I.R.B. 7

96–46, 1996–39 I.R.B. 7

96–47, 1996–39 I.R.B. 8

96–48, 1996–39 I.R.B. 8

96–49, 1996–41 I.R.B. 6

96–50, 1996–41 I.R.B. 6

96–51, 1996–42 I.R.B. 6

96–52, 1996–42 I.R.B. 8

96–54, 1996–44 I.R.B. 13

96–35, 1996–31 I.R.B. 4

96–36, 1996–30 I.R.B. 6

96–37, 1996–32 I.R.B. 4

96–38, 1996–33 I.R.B. 4

96–39, 1996–34 I.R.B. 4

96–42, 1996–35 I.R.B. 4

96–43, 1996–36 I.R.B. 4

96–44, 1996–38 I.R.B. 4

96–45, 1996–39 I.R.B. 5

96–46, 1996–39 I.R.B. 5

96–47, 1996–40 I.R.B. 7

96–48, 1996–40 I.R.B. 4

96–49, 1996–41 I.R.B. 4

96–50, 1996–42 I.R.B. 4

96–51, 1996–43 I.R.B. 5

Proposed Regulations:

1996–28 I.R.B. 36

1996–36 I.R.B. 6

1996–40 I.R.B. 8

CO–9–96, 1996–34 I.R.B. 20

CO–24–96, 1996–30 I.R.B. 22

CO–25–96, 1996–31 I.R.B. 30

CO–26–96, 1996–31 I.R.B. 31

FI–59–94, 1996–30 I.R.B. 23

FI–32–95, 1996–34 I.R.B. 21

FI–48–95, 1996–31 I.R.B. 36

FI–28–96, 1996–31, I.R.B. 33

GL–7–96, 1996–33 I.R.B. 13

IA–292–84, 1996–28 I.R.B. 38

IA–26–94, 1996–30 I.R.B. 24

IA–29–96, 1996–33 I.R.B. 14

INTL–4–95, 1996–36 I.R.B. 8

PS–39–93, 1996–34 I.R.B. 27

PS–22–96, 1996–33 I.R.B. 15

REG–208215–91, 1996–38 I.R.B. 145

REG–209803–95, 1996–44 I.R.B. 14

REG–209826–96, 1996–42 I.R.B. 10

REG–209827–96, 1996–37 I.R.B. 19

REG–245562–96, 1996–41 I.R.B. 8

Public Laws:

104–117, 1996–34 I.R.B. 19

104–134, 1996–38 I.R.B. 7

104–168, 1996–38 I.R.B. 8

104–191, 1996–43 I.R.B. 7

Railroad Retirement Quarterly Rate

1996–29 I.R.B. 14

Revenue Procedures:

Delegation Orders:

155 (Rev. 4), 1996–40 I.R.B. 9

96–36, 1996–27 I.R.B. 11

96–37, 1996–29 I.R.B. 16

96–39, 1996–33 I.R.B. 11

96–40, 1996–32 I.R.B. 8

96–41, 1996–32 I.R.B. 9

96–42, 1996–32 I.R.B. 14

96–43, 1996–35 I.R.B. 6

96–44, 1996–35 I.R.B. 7

96–45, 1996–35 I.R.B. 12

96–46, 1996–38 I.R.B. 144

96–47, 1996–39 I.R.B. 10

96–48, 1996–39 I.R.B. 10

96–49, 1996–43 I.R.B. 74

Notices:

96–36, 1996–27 I.R.B. 11

96–37, 1996–31 I.R.B. 29

Revenue Rulings:

96–33, 1996–27 I.R.B. 4

96–34, 1996–28 I.R.B. 4

Court Decisions:

2058, 1996–34 I.R.B. 13

2059, 1996–34 I.R.B. 10

2060, 1996–34 I.R.B. 5

A cumulative list of all Revenue Rulings, Revenue Procedures, Treasury Decisions, etc., published in Internal Revenue Bulletins 1996–1

through 1996–26 will be found in Internal Revenue Bulletin 1996–27, dated July 1, 1996.

Tax Conventions:

Treasury Decisions:

8673, 1996–27 I.R.B. 4

8674, 1996–28 I.R.B. 7

8675, 1996–29 I.R.B. 5

8676, 1996–30 I.R.B. 4

8677, 1996–30 I.R.B. 7

8678, 1996–31 I.R.B. 11

8679, 1996–31 I.R.B. 4

8680, 1996–33 I.R.B. 5

8681, 1996–37 I.R.B. 17

8682, 1996–37 I.R.B. 4

8683, 1996–44 I.R.B. 9

8684, 1996–44 I.R.B. 4

Finding List of Current Action on

Previously Published Items1

Bulletins 1996–27 through 1996–44

*Denotes entry since last publication

Revenue Procedures:

80–27

Modified by

96–40, 1996–32 I.R.B. 8

87–32

Modified by

TD 8680, 1996–33 I.R.B. 5

92–20

Modified by

TD 8680, 1996–33 I.R.B. 5

95–16

Superseded by

96–48, 1996–39 I.R.B. 10

95–29

Superseded by

96–36, 1996–27 I.R.B. 11

95–29A

Superseded by

96–36, 1996–27 I.R.B. 11

95–30

Superseded by

96–42, 1996–32 I.R.B. 14

95–46

Superseded by

96–48, 1996–39 I.R.B. 10

96–41

Modified by

Notice 96–49, 1996–41 I.R.B. 6

A cumulative finding list for previously published

items mentioned in Internal Revenue Bulletins

1996–1 through 1996–26 will be found in Internal

Revenue Bulletin 1996–27, dated July 1, 1996.

Index

Internal Revenue Bulletins 1996–27

Through 1996–44

For index of items published during

the first six months of 1996, see

I.R.B. 1996–27, dated July 1, 1996.

The abbreviation and number in parenthesis following the index entry

refer to the specific item; numbers in

roman and italic type following the

parenthesis refer to the Internal Revenue Bulletin in which the item may

be found and the page number on

which it appears.

Key to Abbreviations:

Revenue Ruling

Revenue Procedure

Treasury Decision

Court Decision

Public Law

Executive Order

Delegation Order

TDO

Treasury Department Order

Tax Convention

SPR

Statement of Procedural

Rules

PTE

Prohibited Transaction

Exemption

EMPLOYMENT TAXES

Proposed regulations:

26 CFR 301.9100–1T—301.9100–3T

and intermediary sections, added;

extensions of time to make elections (IA–29–96) 33, 14

Railroad retirement:

Rate determination, quarterly (July 1,

1996) 29, 14

Regulations:

26 CFR 301.9100–1T—301.9100–3T

and intermediary sections, added;

extensions of time to make elections (TD 8680) 33, 5

ESTATE AND GIFT TAX

ADMINISTRATIVE

Proposed regulations:

26 CFR 20.2041–3, 20.2056(d)–2,

25.2511–1, 25.2514–3, 25.2518–1,

–2, amended; 20.2041–3, added;

disclaimer of interests and powers

(REG–208215–91) 38, 145

ESTATE AND GIFT TAXES

ADMINISTRATIVE—

Continued

Proposed regulations—Continued

26 CFR 301.9100–1T—301.9100–3T

and intermediary sections, added;

extensions of time to make elections (IA–29–96) 33, 14

ESTATE TAX

Proposed regulations:

26 CFR 20.2041–3(d)(6)(i), amended; 20.2041–3(d)(6)(iii), added;

20.2056(d)–2, amended; disclaimer

of interests and powers (REG–

208215–91) 38, 145

Regulations:

26 CFR 301.9100–1T—301.9100–3T

and intermediary sections, added;

extensions of time to make elections (TD 8680) 33, 5

EXCISE TAXES

Exempt organizations:

Excess benefit transactions engaged in

(Notice 46) 39, 7

Foreign insurance taxes (Ct.D 2060) 34,

Proposed regulations:

26 CFR 2652–1, amended; generation-skipping transfer tax (PS–22–

96) 33, 15

GIFT TAX

Proposed regulations:

26 CFR 25.2511–1, 25.2514–3,

25.2518–1, –2, amended; disclaimer of interests and powers

(REG–208215–91) 38, 145

INCOME TAX

Accounting methods (Notice 40) 33, 11

Bankruptcy; validity of liens (Ct.D

2059) 34, 10

Bonds:

Qualified mortgage bonds:

Mortgage credit certificates:

National median gross income

(RP 37) 29, 16

Claiming a refund, U.S. v. IBM (Notice

37) 31, 29

Credits against tax:

Low-income housing (RP 46) 38, 144

Satisfactory bond, ‘‘bond factor’’

amounts for the period July through

September 1996 (RR 45) 39, 5

INCOME TAX—Continued

Employee plans:

Funding:

Full funding limitations, weighted

average interest rate, June 1996

(Notice 36) 27, 11; July 1996

(Notice 38) 31, 29

Full funding limitation:

Weighted average interest rate for

August 1996, (Notice 43) 36, 7;

September 1996 (Notice 45) 39,

7; October 1996 (Notice 54) 44,

Nondiscrimination and coverage,

rollover (RR 48) 40, 4

Participant consent, significant detriment (RR 47) 40, 7

Section 414(u); retirement plans;

model amendments (RP 49) 43,

Exempt organizations:

Group letter exemption (RP 40) 32, 8

Private inurement expressly prohibited

(Notice 47) 39, 8

Information returns, copies to the

public and increases to certain penalties (Notice 48) 39, 8

Forms:

Paper substitutes, Forms 1096, 1098,

1099 series, 5498, and W–2G (RP

42) 32, 14

Substitute printed, computer-prepared,

and computer-generated tax forms

and schedules (RP 48) 39, 8

Health Insurance Portability and Accountability Act of 1996 (P.L. 104–

191) 43, 7

Income:

Controlled foreign corporation, partnership, subpart F income (Notice

39) 32, 8

Inflation adjustment factor for 1996

(Notice 41) 35, 6

Inflation-indexed debt instruments (Notice 51) 42, 6

Insurance companies:

Differential earnings rate (RR 42) 35,

Loss reserves, discounting unpaid

losses (RP 44) 35, 7

Discounting estimated salvage recoverable (RP 45) 35, 12

Interest:

Investment:

Federal short-term, mid-term, and

long-term rates, July 1996 (RR

34) 28, 4; August 1996 (RR 37)

32, 4; September 1996 (RR 43)

36, 4; October 1996 (RR 49) 41,

INCOME TAX—Continued

Interest—Continued

Rates, underpayments and overpayments beginning October 1, 1996

(RR 44) 38, 4

Inventories:

LIFO:

Price indexes, department stores,

May 1996 (RR 36) 30, 6; June

1996 (RR 39) 34, 4

Price indexes, department stores,

July 1996 (RR 46) 39, 5

Price indexes, department stores,

August 1996 (RR 50) 42, 4

Low income housing credit:

Bond factor amounts, April–June

1996 (RR 33) 27, 4

FEMA (RR 35) 31, 4

Marginal production rates for 1996 (Notice 42) 35, 6

Omnibus Consolidated Recissions and

Appropriations Act of 1996 (PL 104–

134) 38, 7

Pooled income fund; community trust;

maintenance requirement (RR 38) 33,

Proposed regulations:

26 CFR 1.61–8(b), revised; 1.451–

1(g), added; 1.467–1, amended;

1.467–4, amended; 1.467–0 through

–8, added; rental agreements (IA–

292–84) 28, 38

26 CFR 1.61–12(c), 1.163–7(c),

1.171–1—1.171–4, 1.1016–5(b), revised; 1.163–13, 1.171–5, added;

1.1016–9, removed; amortizable

bond premium (FI–48–95) 31, 36

26 CFR 1.148–5(d)(6)(iv)—(viii) and

intermediary sections; 1.148–

5(e)(2)(iv), added; arbitrage restrictions on tax-exempt bonds (FI–28–

96) 31, 33

26 CFR 1.166–3(a)(3), added; bad

debts modifications and dealer assignments of notional principal

contracts (FI–59–94) 30, 23

26 CFR 1.280B–1, added; structure,

definition (PS–39–93) 34, 27

26 CFR 1.367(e)–1, 1.6038B–

1(b)(2)(i); section 355 distributions

of stock and securities by domestic

corporations to foreign persons

(REG–209827–96) 37, 19

26 CFR 1.382–5, –8, added; 1.382–

2(a)(1)(iv), revised; consolidated returns, short taxable years for controlled groups (CO–26–96) 31, 31

26 CFR 1.401(a)(31)–1; 1.402(c)–2,

amended; relief from disqualification of plans accepting rollovers

(REG–245562–96) 41, 8

Proposed regulations—Continued

26 CFR 1.475(b)–1, –2, –4, 1.475(c)–1, –2, 1.475(e)–1, revised;

mark-to-market equity interests in

related parties and dealer-customer

relationship (FI–32–95) 34, 21

26 CFR 1.671–1(g), (h), 1.671–2(f),

1.1297–4, added; application of the

grantor trust rules to nonexempt

employees’ trusts (REG–209826–

96) 42, 10

26 CFR 1.861–8(e)(7)(iii), 1.865–1,

–2, 1.904–4(c)(2)(ii)(A) and (B),

added; 1.904–0, amended; stock

disposition loss allocation (INTL–

4–95) 36, 8

26 CFR 1.1059(e)–1, added; extraordinary dividends; distributions to

corporate shareholders (CO–9–96)

34, 20

26 CFR 1.1202–0, –2, added; qualified small business stock (IA–26–

94) 30, 24

26 CFR 1.1502–15, –21, –22, –23,

added; consolidated returns, limitations on the use of certain losses

and deductions (CO–24–96) 30, 22

26 CFR 1.1502–90T—1.1502–99T

and intermediary sections, added;

consolidated group, net operating

loss carryforwards and built-in

losses and credits following ownership change, limitation (CO–25–96)

31, 30

26 CFR 1.6045–1, –2, 301.6011–2,

revised; magnetic media filing requirements for information returns

(REG–209803–95) 44, 14

26 CFR 301.9100–1T—301.9100–3T

and intermediary sections, added;

extensions of time to make elections (IA–29–96) 33, 14

Recommendation letters for nonsuit

settlements (Del. Order 155, Rev. 4)

40, 9

Refund claims; Tax Court; return not

filed (Ct.D. 2058) 34, 13

Regulated investment companies, preferential dividends (RP 47) 39, 10

Regulations:

26 CFR 1.110–3, added; debt instruments modifications (TD 8675) 29,

26 CFR 1.163–7(a), added; 1.446–4,

amended; 1.483–2T, removed;

1.483–4, added; 1.1001–1, revised;

1.1012–1(g), revised; 1.1271–0(b),

amended; 1.1272–1(c)(7), added;

1.1274–2(g), revised; 1.1274–2(i)

and (j), added; 1.1275–2(g), (h), (i),

(j), added; 1.1275–2T, removed;

1.1275–4, added; 1.1275–5(a)(5),

Regulations—Continued

(6), added; 1.1275–5(c)(1), (5), revised; 1.1275–6, added; debt instruments with original issue discount,

contingent payments, anti-abuse

rule (TD 8674) 28, 7

26 CFR 1.166–3T, 1.1001–4T, added;

bad debts modifications and dealer

assignments of notional principal

contracts (TD 8676) 30, 4

26 CFR 1.367(e)–0; 1.367(e)–1, removed; 1.367(e)–0T, –1T, added;

section 355 distributions of stock

and securities by domestic corporations to foreign persons (TD 8682)

37, 4

26 CFR 1.382–5T, –8T, –2T(f)(1)(i)—

(iii) and intermediary sections,

added; 1.382–2, –2T, removed;

consolidated groups, short taxable

years for controlled groups (TD

8679) 31, 4

26 CFR 1.1254–2(d)(1)(ii), –3(b)(1)(i)

and (ii), –3(d)(1)(i) and (ii), revised; 1.1254–4, –6, amended;

treatment of gain from disposition

of interest in certain natural resource recapture property by S

corps and their shareholders (TD

8684) 44, 4

26 CFR 1.1394–0, –1, added;

enterprize zone facility bonds (TD

8673) 27, 4

26 CFR 1.1502–0, –1, –2, –11, –21A,

–22A, –23A, –41A, revised;

1.1502–15, –21, redesignated,

1.1502–21T, –23T, –79A, added;

1.1502–79, amended; consolidated

returns, limitations on the use of

certain losses and deductions (TD

8677) 30, 7

26 CFR 1.1502–90T through –99T

and intermediary sections, added;

consolidated groups, net operating

loss carryforwards and built-in

losses and credits following ownership change, limitations (TD 8678)

31, 11

26 CFR 1.6045–1(q), –2, amended;

1.6045–1T, –2T, 301.6011–2T,

added; magnetic media filing requirements for information returns

(TD 8683) 44, 9

26 CFR 301.6355–1, amended; sale

of seized property (GL–7–96) 33,

26 CFR 301.7503–1, amended; time

for performance of acts where last

day falls on Saturday, Sunday, or

legal holiday (TD 8681) 37, 17

INCOME TAX—Continued

Regulations—Continued

26 CFR 301.9100–1T—301.9100–3T

and intermediary sections, added;

extensions of time to make elections (TD 8680) 33, 5

Returns:

Magnetic media reporting, Forms

1098, 1099, 5498, and W–2G (RP

36) 27, 11

Section 355 de minimis limitation (RP

43) 35, 6

Section 355 No Rule (RP 39) 33, 11

Statements required by brokers; correction (Notice 50) 41, 6

Tax benefits for individuals performing

services in certain hazardous duty

areas (PL 104–117) 34, 19

Tax conventions:

Fiji 40, 8

Russia 36, 6

Taxes, accrual of deduction (RR 51)

43, 5

Tax-exempt bonds; arbitrage (RR 41)

32, 9; (Notice 49) 41, 6

Tax treatment of partnership items correction (Notice 44) 36, 7

Taxpayer Bill of Rights 2 (PL 104–168)

38, 8

Work opportunity tax credit (Notice 52)

42, 8

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.