Administrative, Procedural, and Miscellaneous

Part III

Administrative, Procedural, and Miscellaneous

26 CFR 601.602. Tax forms and instructions.

(Also, Part I, §§ 1, 23, 24, 25A, 32, 42, 59, 62, 63, 68, 132, 135, 137, 146, 1.148-5, 151,

170, 179, 213, 220, 221, 223, 512, 513, 685, 877, 2032A, 2503, 2523, 4261, 6033,

6039F, 6323, 6334, 6601, 7430, 7702B)

Rev. Proc. 2004-71

Table of Contents

SECTION 1. PURPOSE

SECTION 2. CHANGES

SECTION 3. 2005 ADJUSTED ITEMS

Code Section

.01 Tax Rate Tables

.02 Unearned Income of Minor Children Taxed as if Parent’s

Income ("Kiddie Tax")

1(a)-(e)

1(g)

.03 Adoption Credit

23

.04 Child Tax Credit

24

.05 Hope and Lifetime Learning Credits

25A

.06 Earned Income Credit

32

.07 Low-Income Housing Credit

42(h)

.08 Alternative Minimum Tax Exemption for a Child Subject to the

“Kiddie Tax”

59(j)

.09 Transportation Mainline Pipeline Construction Industry Optional

Expense Substantiation Rules for Payments to Employees under

Accountable Plans

62(c)

.10 Standard Deduction

63

-2.11 Overall Limitation on Itemized Deductions

68

.12 Qualified Transportation Fringe

132(f)

.13 Income from United States Savings Bonds for Taxpayers Who

Pay Qualified Higher Education Expenses

135

.14 Adoption Assistance Programs

137

.15 Private Activity Bonds Volume Cap

146(d)

.16 Safe Harbor Rules for Broker Commissions on Guaranteed

Investment Contracts or Investments Purchased for a Yield

Restricted Defeasance Escrow

1.148-5

.17 Personal Exemption

151

.18 Election to Expense Certain Depreciable Assets

179

.19 Eligible Long-Term Care Premiums

213(d)(10)

.20 Medical Savings Accounts

220

.21 Interest on Education Loans

221

.22 Health Savings Accounts

223

.23 Treatment of Dues Paid to Agricultural or Horticultural

Organizations

512(d)

.24 Insubstantial Benefit Limitations for Contributions Associated

with Charitable Fund-Raising Campaigns

513(h)

.25 Funeral Trusts

685

.26 Expatriation to Avoid Tax

877

.27 Valuation of Qualified Real Property in Decedent's Gross Estate

2032A

.28 Annual Exclusion for Gifts

2503 & 2523

.29 Passenger Air Transportation Excise Tax

4261

.30 Reporting Exception for Certain Exempt Organizations with

6033(e)(3)

-3Nondeductible Lobbying Expenditures

.31 Notice of Large Gifts Received from Foreign Persons

6039F

.32 Persons Against Which a Federal Tax Lien Is Not Valid

6323

.33 Property Exempt from Levy

6334

.34 Interest on a Certain Portion of the Estate Tax Payable

in Installments

.35 Attorney Fee Awards

.36 Periodic Payments Received under Qualified Long-Term Care

Insurance Contracts or under Certain Life Insurance Contracts

6601(j)

7430

7702B(d)

SECTION 4. EFFECTIVE DATE

SECTION 5. DRAFTING INFORMATION

SECTION 1. PURPOSE

This revenue procedure sets forth inflation adjusted items for 2005.

SECTION 2. CHANGES

.01 The amounts in § 1.148-5(e)(2)(iii)(B)(1) of the Income Tax Regulations used to

determine whether a broker’s commission or similar fee with respect to the acquisition

of a guaranteed investment contract or investments purchased for a yield restricted

defeasance escrow is reasonable under § 1.148-5(e)(2)(i) are adjusted for inflation.

(Section 3.16).

.02 The amounts in § 223(b)(2) of the Internal Revenue Code used to determine the

monthly limitation on deductions for health savings accounts under § 223(a) are

adjusted for inflation. The amounts in § 223(c)(2)(A) used to determine whether a

health plan meets the definition of a high deductible health plan are adjusted for

inflation. (Section 3.22).

.03 The new “net worth” amount in § 877(a)(2)(B) used to determine whether an

individual who ceased to be a U.S. citizen or long-term resident is subject to the special

rules of § 877 is not adjusted for inflation. (Section 3.26).

SECTION 3. 2005 ADJUSTED ITEMS

.01 Tax Rate Tables. For taxable years beginning in 2005, the tax rate tables under

-4§ 1 are as follows:

TABLE 1 - Section 1(a). - Married Individuals Filing Joint Returns and Surviving

Spouses

If Taxable Income Is:

The Tax Is:

Not over $14,600

10% of the taxable income

Over $14,600 but

not over $59,400

$1,460 plus 15% of

the excess over $14,600

Over $59,400 but

not over $119,950

$8,180 plus 25% of

the excess over $59,400

Over $119,950 but

not over $182,800

$23,317.50 plus 28% of

the excess over $119,950

Over $182,800 but

not over $326,450

$40,915.50 plus 33% of

the excess over $182,800

Over $326,450

$88,320 plus 35% of

the excess over $326,450

TABLE 2 - Section 1(b). – Heads of Households

If Taxable Income Is:

The Tax Is:

Not over $10,450

10% of the taxable income

Over $10,450 but

not over $39,800

$1,045 plus 15% of

the excess over $10,450

Over $39,800 but

not over $102,800

$5,447.50 plus 25% of

the excess over $39,800

Over $102,800 but

not over $166,450

$21,197.50 plus 28% of

the excess over $102,800

Over $166,450 but

not over $326,450

$39,019.50 plus 33% of

the excess over $166,450

Over $326,450

$91,819.50 plus 35% of

the excess over $326,450

-5TABLE 3 - Section 1(c). – Unmarried Individuals (other than Surviving Spouse and

Heads of Households).

If Taxable Income Is:

The Tax Is:

Not over $7,300

10% of the taxable income

Over $7,300 but

not over $29,700

$730 plus 15% of

the excess over $7,300

Over $29,700 but

not over $71,950

$4,090 plus 25% of

the excess over $29,700

Over $71,950 but

not over $150,150

$14,652.50 plus 28% of

the excess over $71,950

Over $150,150 but

not over $326,450

$36,548.50 plus 33% of

the excess over $150,150

Over $326,450

$94,727.50 plus 35% of

the excess over $326,450

TABLE 4 - Section 1(d). – Married Individuals Filing Separate Returns

If Taxable Income Is:

The Tax Is:

Not over $7,300

10% of the taxable income

Over $7,300 but

not over $29,700

$730 plus 15% of

the excess over $7,300

Over $29,700 but

not over $59,975

$4,090 plus 25% of

the excess over $29,700

Over $59,975 but

not over $91,400

$11,658.75 plus 28% of

the excess over $59,975

Over $91,400 but

not over $163,225

$20,457.75 plus 33% of

the excess over $91,400

Over $163,225

$44,160 plus 35% of

the excess over $163,225

TABLE 5 - Section 1(e). – Estates and Trusts

-6If Taxable Income Is:

The Tax Is:

Not over $2,000

15% of the taxable income

Over $2,000 but

not over $4,700

$300 plus 25% of

the excess over $2,000

Over $4,700 but

not over $7,150

$975 plus 28% of

the excess over $4,700

Over $7,150 but

not over $9,750

$1,661 plus 33% of

the excess over $7,150

Over $9,750

$2,519 plus 35% of

the excess over $9,750

.02 Unearned Income of Minor Children Taxed as if Parent's Income (the "Kiddie

Tax"). For taxable years beginning in 2005, the amount in § 1(g)(4)(A)(ii)(I), which is

used to reduce the net unearned income reported on the child's return that is subject to

the "kiddie tax," is $800. (This amount is the same as the $800 standard deduction

amount provided in section 3.10(2) of this revenue procedure.) The same $800 amount

is used for purposes of § 1(g)(7) (that is, in determining whether a parent may elect to

include a child's gross income in the parent's gross income and for calculating the

"kiddie tax"). For example, one of the requirements for the parental election is that a

child's gross income is more than the amount referenced in § 1(g)(4)(A)(ii)(I) but less

than 10 times such amount; thus, a child's gross income for 2005 must be more than

$800 but less than $8,000 to satisfy that requirement.

.03 Adoption Credit. For taxable years beginning in 2005, under § 23(a)(3) the

maximum credit allowed for an adoption of a child with special needs is $10,630. For

taxable years beginning in 2005, under § 23(b)(1) the maximum credit allowed with

regard to other adoptions is the amount of qualified adoption expenses up to $10,630.

The available adoption credit begins to phase out under § 23(b)(2)(A) for taxpayers with

modified adjusted gross income in excess of $159,450 and is completely phased out for

taxpayers with modified adjusted gross income of $199,450. (See section 3.14 of this

revenue procedure for the adjusted items relating to adoption assistance programs.)

.04 Child Tax Credit. For taxable years beginning in 2005, the value used in

§ 24(d)(1)(B)(i) in determining the amount of credit under § 24 that may be refundable is

$11,000.

.05 Hope and Lifetime Learning Credits.

(1) For taxable years beginning in 2005, 100 percent of qualified tuition and related

-7expenses not in excess of $1,000 and 50 percent of such expenses in excess of $1,000

are taken into account in determining the amount of the Hope Scholarship Credit under

§ 25A(b)(1).

(2) For taxable years beginning in 2005, a taxpayer's modified adjusted gross

income in excess of $43,000 ($87,000 for a joint return) is taken into account in

determining the reduction under § 25A(d)(2)(A)(ii) in the amount of the Hope

Scholarship and Lifetime Learning Credits otherwise allowable under § 25A(a).

.06 Earned Income Credit.

(1) In general. For taxable years beginning in 2005, the following amounts are used

to determine the earned income credit under § 32(b). The "earned income amount" is

the amount of earned income at or above which the maximum amount of the earned

income credit is allowed. The "threshold phaseout amount" is the amount of adjusted

gross income (or, if greater, earned income) above which the maximum amount of the

credit begins to phase out. The "completed phaseout amount" is the amount of

adjusted gross income (or if greater, earned income) at or above which no credit is

allowed.

Number of Qualifying Children

Item

One

Two or More

None

Earned Income Amount

$ 7,830

$11,000

$ 5,220

Maximum Amount of Credit

$ 2,662

$ 4,400

$

Threshold Phaseout Amount

(Single, Surviving Spouse, or

Head of Household)

$14,370

$14,370

$ 6,530

Completed Phaseout Amount

(Single, Surviving Spouse, or

Head of Household)

$31,030

$35,263

$11,750

Threshold Phaseout Amount

(Married Filing Jointly)

$16,370

$16,370

$ 8,530

Completed Phaseout Amount

(Married Filing Jointly)

$33,030

$37,263

$13,750

399

The instructions for the Form 1040 series provide tables showing the amount of the

earned income credit for each type of taxpayer.

-8(2) Excessive investment income. For taxable years beginning in 2005, the earned

income tax credit is denied under § 32(i) if the aggregate amount of certain investment

income exceeds $2,700.

.07 Low-Income Housing Credit. For calendar years beginning in 2005, the amounts

used under § 42(h)(3)(C)(ii) to calculate the State housing credit ceiling for the lowincome housing credit is the greater of (i) $1.85 multiplied by the State population, or (ii)

$2,125,000.

.08 Alternative Minimum Tax Exemption for a Child Subject to the "Kiddie Tax." For

taxable years beginning in 2005, for a child to whom the § 1(g) "kiddie tax" applies, the

exemption amount under §§ 55 and 59(j) for purposes of the alternative minimum tax

under § 55 may not exceed the sum of (i) such child's earned income for the taxable

year, plus (ii) $5,850.

.09 Transportation Mainline Pipeline Construction Industry Optional Expense

Substantiation Rules for Payments to Employees under Accountable Plans. For

calendar years beginning in 2005, an eligible employer may pay certain welders and

heavy equipment mechanics an amount of up to $13 per hour for rig-related expenses

that is deemed substantiated under an accountable plan when paid in accordance with

Rev. Proc. 2002-41. If the employer provides fuel or otherwise reimburses fuel

expenses, up to $8 per hour is deemed substantiated when paid under Rev. Proc.

2002-41.

.10 Standard Deduction.

(1) In general. For taxable years beginning in 2005, the standard deduction

amounts under § 63(c)(2) are as follows:

Filing Status

Standard Deduction

Married Individuals Filing Joint Returns

and Surviving Spouses (§ 1(a))

$10,000

Heads of Households (§ 1(b))

$7,300

Unmarried Individuals (other than Surviving Spouses

and Heads of Households) (§ 1(c))

$5,000

Married Individuals Filing Separate

Returns (§ 1(d))

$5,000

(2) Dependent. For taxable years beginning in 2005, the standard deduction

amount under § 63(c)(5) for an individual who may be claimed as a dependent by

another taxpayer may not exceed the greater of (i) $800, or (ii) the sum of $250 and the

individual's earned income.

-9-

(3) Aged and blind. For taxable years beginning in 2005, the additional standard

deduction amounts under § 63(f) for the aged and for the blind are $1,000 for each.

These amounts are increased to $1,250 if the individual is also unmarried and not a

surviving spouse.

.11 Overall Limitation on Itemized Deductions. For taxable years beginning in 2005,

the "applicable amount" of adjusted gross income under § 68(b), above which the

amount of otherwise allowable itemized deductions is reduced under § 68, is $145,950

(or $72,975 for a separate return filed by a married individual).

.12 Qualified Transportation Fringe. For taxable years beginning in 2005, the monthly

limitation under § 132(f)(2)(A) (regarding the aggregate fringe benefit exclusion amount

for transportation in a commuter highway vehicle and any transit pass) is $105. The

monthly limitation under § 132(f)(2)(B) (regarding the fringe benefit exclusion amount for

qualified parking) is $200.

.13 Income from United States Savings Bonds for Taxpayers Who Pay Qualified

Higher Education Expenses. For taxable years beginning in 2005, the exclusion under

§ 135 (regarding income from United States savings bonds for taxpayers who pay

qualified higher education expenses) begins to phase out for modified adjusted gross

income above $91,850 for joint returns and $61,200 for other returns. This exclusion

completely phases out for modified adjusted gross income of $121,850 or more for joint

returns and $76,200 or more for other returns.

.14 Adoption Assistance Programs. For taxable years beginning in 2005, under

§ 137(a)(2) the maximum amount that can be excluded from an employee’s gross

income in connection with the adoption by the employee of a child with special needs is

$10,630. For taxable years beginning in 2005, under § 137(b)(1) the maximum amount

that can be excluded from an employee’s gross income for the amounts paid or

expenses incurred by the employer for qualified adoption expenses furnished pursuant

to an adoption assistance program in connection with other adoptions by the employee

is $10,630. The amount excludable from an employee’s gross income begins to phase

out under § 137(b)(2)(A) for taxpayers with modified adjusted gross income in excess of

$159,450 and is completely phased out for taxpayers with modified adjusted gross

income of $199,450. (See section 3.03 of this revenue procedure for the adjusted items

relating to the adoption credit.)

.15 Private Activity Bonds Volume Cap. For calendar years beginning in 2005, the

amounts used under § 146(d)(1) to calculate the State ceiling for the volume cap for

private activity bonds is the greater of (i) $80 multiplied by the State population, or (ii)

$239,180,000.

.16 Safe Harbor Rules for Broker Commissions on Guaranteed Investment Contracts

- 10 or Investments Purchased for a Yield Restricted Defeasance Escrow. For calendar

year 2005, under § 1.148-5(e)(2)(iii)(B)(1), a broker’s commission or similar fee with

respect to the acquisition of a guaranteed investment contract or investments

purchased for a yield restricted defeasance escrow is reasonable to the extent that (i)

the amount of the fee that the issuer treats as a qualified administrative cost does not

exceed the lesser of (A) $31,000, or (B) 0.2 percent of the computational base (as

defined in § 1.148-5(e)(2)(iii)(B)(2)) or, if more, $3,000; and (ii) the issuer does not treat

more than $87,000 in brokers’ commissions or similar fees as qualified administrative

costs with respect to all guaranteed investment contracts and investments for yield

restricted defeasance escrows purchased with gross proceeds of the issue.

.17 Personal Exemption.

(1) Exemption amount. For taxable years beginning in 2005, the personal

exemption amount under § 151(d) is $3,200.

(2) Phase out. For taxable years beginning in 2005, the personal exemption amount

begins to phase out at, and is completely phased out after, the following adjusted gross

income amounts:

AGI – Beginning

AGI – Exemption

Filing Status

of Phaseout

Fully Phased Out

Married Individuals Filing Joint Returns and

Surviving Spouses (§ 1(a))

$218,950

$341,450

Heads of Households (§ 1(b))

$182,450

$304,950

Unmarried Individuals (other than Surviving

Spouses and Heads of Households) (§ 1(c))

$145,950

$268,450

Married Individuals Filing Separate

Returns (§ 1(d))

$109,475

$170,725

.18 Election to Expense Certain Depreciable Assets. For taxable years beginning in

2005, under § 179(b)(1) the aggregate cost of any § 179 property a taxpayer may elect

to treat as an expense shall not exceed $105,000. Under § 179(b)(2) the $105,000

limitation shall be reduced (but not below zero) by the amount by which the cost of

§ 179 property placed in service during the 2005 taxable year exceeds $420,000.

.19 Eligible Long-Term Care Premiums. For taxable years beginning in 2005, the

limitations under § 213(d)(10) (regarding eligible long-term care premiums includible in

the term "medical care") are as follows:

- 11 Attained Age Before the Close of the Taxable Year

Limitation on Premiums

40 or less

$ 270

More than 40 but not more than 50

$ 510

More than 50 but not more than 60

$1,020

More than 60 but not more than 70

$2,720

More than 70

$3,400

.20 Medical Savings Accounts.

(1) Self-only coverage. For taxable years beginning in 2005, the term "high

deductible health plan" as defined in § 220(c)(2)(A) means, for self-only coverage, a

health plan that has an annual deductible that is not less than $1,750 and not more than

$2,650, and under which the annual out-of-pocket expenses required to be paid (other

than for premiums) for covered benefits does not exceed $3,500.

(2) Family coverage. For taxable years beginning in 2005, the term "high deductible

health plan" means, for family coverage, a health plan that has an annual deductible

that is not less than $3,500 and not more than $5,250, and under which the annual outof-pocket expenses required to be paid (other than for premiums) for covered benefits

does not exceed $6,450.

.21 Interest on Education Loans. For taxable years beginning in 2005, the $2,500

maximum deduction for interest paid on qualified education loans under § 221 is

reduced under § 221(b)(2)(B) when modified adjusted gross income exceeds $50,000

($105,000 for joint returns), and is completely eliminated when modified adjusted gross

income is $65,000 ($135,000 for joint returns).

.22 Health Savings Accounts.

(1) Monthly contribution limitation. For calendar year 2005, the monthly limitation on

deductions under § 223(b)(2)(A) for an individual with self-only coverage under a high

deductible plan as of the first day of such month is 1/12 of the lesser of (i) the annual

deductible, or (ii) $2,650. For calendar year 2005, the monthly limitation on deductions

under § 223(b)(2)(B) for an individual with family coverage under a high deductible plan

as of the first day of such month is 1/12 of the lesser of (i) the annual deductible, or (ii)

$5,250.

(2) High deductible health plan. For calendar year 2005, a high deductible health

plan is defined under § 223(c)(2)(A) as a health plan with an annual deductible that is

- 12 not less than $1,000 for self-only coverage or $2,000 for family coverage, and the

annual out-of pocket expenses (deductibles, co-payments, and other amounts, but not

premiums) do not exceed $5,100 for self-only coverage or $10,200 for family coverage.

.23 Treatment of Dues Paid to Agricultural or Horticultural Organizations. For taxable

years beginning in 2005, the limitation under § 512(d)(1) (regarding the exemption of

annual dues required to be paid by a member to an agricultural or horticultural

organization) is $127.

.24 Insubstantial Benefit Limitations for Contributions Associated with Charitable

Fund-Raising Campaigns.

(1) Low cost article. For taxable years beginning in 2005, the unrelated business

income of certain exempt organizations under § 513(h)(2) does not include a "low cost

article" of $8.30 or less.

(2) Other insubstantial benefits. For taxable years beginning in 2005, the $5, $25,

and $50 guidelines in section 3 of Rev. Proc. 90-12, 1990-1 C.B. 471 (as amplified and

modified), for disregarding the value of insubstantial benefits received by a donor in

return for a fully deductible charitable contribution under § 170, are $8.30, $41.50, and

$83, respectively.

.25 Funeral Trusts. For a contract entered into during calendar year 2005 for a

"qualified funeral trust," as defined in § 685, the trust may not accept aggregate

contributions by or for the benefit of an individual in excess of $8,200.

.26 Expatriation to Avoid Tax. For calendar year 2005, an individual with “average

annual net income tax” of more than $127,000 for the 5 taxable years ending before the

date of the loss of United States citizenship under § 877(a)(2)(A) is subject to tax under

§ 877(b).

.27 Valuation of Qualified Real Property in Decedent's Gross Estate. For an estate of

a decedent dying in calendar year 2005, if the executor elects to use the special use

valuation method under § 2032A for qualified real property, the aggregate decrease in

the value of qualified real property resulting from electing to use § 2032A that is taken

into account for purposes of the estate tax may not exceed $870,000.

.28 Annual Exclusion for Gifts.

(1) For calendar year 2005, the first $11,000 of gifts to any person (other than gifts

of future interests in property) are not included in the total amount of taxable gifts under

§ 2503 made during that year.

(2) For calendar year 2005, the first $117,000 of gifts to a spouse who is not a

- 13 citizen of the United States (other than gifts of future interests in property) are not

included in the total amount of taxable gifts under §§ 2503 and 2523(i)(2) made during

that year.

.29 Passenger Air Transportation Excise Tax. For calendar year 2005, the tax under

§ 4261(b) on the amount paid for each domestic segment of taxable transportation by

air is $3.20. For calendar year 2005, the tax under § 4261(c) on any amount paid

(whether within or without the United States) for any transportation of any person by air,

if such transportation begins or ends in the United States, generally is $14.10.

However, for a domestic segment beginning or ending in Alaska or Hawaii as described

in § 4261(c)(3), the tax only applies to departures and is at the rate of $7.

.30 Reporting Exception for Certain Exempt Organizations with Nondeductible

Lobbying Expenditures. For taxable years beginning in 2005, the annual per person,

family, or entity dues limitation to qualify for the reporting exception under § 6033(e)(3)

(and section 5.05 of Rev. Proc. 98-19, 1998-1 C.B. 547), regarding certain exempt

organizations with nondeductible lobbying expenditures, is $88 or less.

.31 Notice of Large Gifts Received from Foreign Persons. For taxable years

beginning in 2005, recipients of gifts from certain foreign persons may be required to

report these gifts under § 6039F if the aggregate value of gifts received in a taxable

year exceeds $12,375.

.32 Persons Against Which a Federal Tax Lien Is Not Valid. For calendar year 2005,

a federal tax lien is not valid against (i) certain purchasers under § 6323(b)(4) who

purchased personal property in a casual sale for less than $1,200, or (ii) a mechanic's

lienor under § 6323(b)(7) that repaired or improved certain residential property if the

contract price with the owner is not more than $6,020.

.33 Property Exempt from Levy. For calendar year 2005, the value of property

exempt from levy under § 6334(a)(2) (fuel, provisions, furniture, and other household

personal effects, as well as arms for personal use, livestock, and poultry) may not

exceed $7,200. The value of property exempt from levy under § 6334(a)(3) (books and

tools necessary for the trade, business, or profession of the taxpayer) may not exceed

$3,600.

.34 Interest on a Certain Portion of the Estate Tax Payable in Installments. For an

estate of a decedent dying in calendar year 2005, the dollar amount used to determine

the "2-percent portion" (for purposes of calculating interest under § 6601(j)) of the estate

tax extended as provided in § 6166 is $1,170,000.

.35 Attorney Fee Awards. For fees incurred in calendar year 2005, the attorney fee

award limitation under § 7430(c)(1)(B)(iii) is $150 per hour.

- 14 .36 Periodic Payments Received under Qualified Long-Term Care Insurance

Contracts or under Certain Life Insurance Contracts. For calendar year 2005, the

stated dollar amount of the per diem limitation under § 7702B(d)(4) (regarding periodic

payments received under a qualified long-term care insurance contract or periodic

payments received under a life insurance contract that are treated as paid by reason of

the death of a chronically ill individual) is $240.

SECTION 4. EFFECTIVE DATE

.01 General Rule. Except as provided in section 4.02, this revenue procedure applies

to taxable years beginning in 2005.

.02 Calendar Year Rule. This revenue procedure applies to transactions or events

occurring in calendar year 2005 for purposes of sections 3.07 (low-income housing

credit), 3.09 (pipeline construction industry optional expense substantiation rules), 3.15

(private activity bond volume cap), 3.16 (safe harbor rules for broker commissions on

guaranteed investment contracts or investments purchased for a yield restricted

defeasance escrow), 3.22 (health savings accounts), 3.23 (funeral trusts), 3.24

(expatriation to avoid tax), 3.25 (valuation of qualified real property in decedent's gross

estate), 3.26 (annual exclusion for gifts), 3.27 (passenger air transportation excise tax),

3.30 (persons against which a federal tax lien is not valid), 3.31 (property exempt from

levy), 3.32 (interest on a certain portion of the estate tax payable in installments), 3.33

(attorney fee awards), and 3.34 (periodic payments received under qualified long-term

care insurance contracts or under certain life insurance contracts).

SECTION 5. DRAFTING INFORMATION

The principal author of this revenue procedure is Marnette M. Myers of the Office of

Associate Chief Counsel (Income Tax & Accounting). For further information regarding

this revenue procedure, contact Ms. Myers on (202) 622-4920 (not a toll-free call).