SEQ 0001 JOB C48-001-007 PAGE-0003 COVER

Agency decision

Ask Donna

What actually matters in this document.

Text

REVISED 30JUN96 AT 22:14 BY LR DEPTH: 66.04 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-001

Bulletin No. 1996–15

April 8, 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.

SPECIAL ANNOUNCEMENT

amended by the Uruguay Round Amendments Act,

which includes the Retirement Protection Act of 1994,

are set forth.

Announcement 96–22, page 16.

A public hearing will be held on April 24, 1996, on

proposed regulations that provide guidance concerning

the notice and consent requirements under section

411(a)(11) and the notice and election requirements of

section 417.

Announcement 96–18, page 15.

This announcement describes two revenue rulings that

are being issued with respect to the additional funding

requirements under section 412(l) of the Internal

Revenue Code as they relate to the Form 5500

(Schedule B) for 1995.

INCOME TAX

EXEMPT ORGANIZATIONS

Rev. Rul. 96–22, page 9.

LIFO; price indexes; department stores. The February

1996 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, February 29, 1996.

Announcement 96–21, page 16.

A list is given of organizations now classified as private

foundations.

ESTATE TAX

Rev. Rul. 96–23, page 11.

Special use value; farms; interest rates. The 1996

interest rates to be used in computing the special use

value of farm real property for which an election is

made under section 2032A of the Code are listed for

estates of decedents.

EMPLOYEE PLANS

Rev. Rul. 96–20, page 5.

Additional funding requirements for certain plans. Questions and answers with respect to the establishment

and maintenance of amortization bases for certain

plans that have additional funding requirements described in section 412(l) of the Internal Revenue Code

as amended by the Uruguay Round Agreements Act,

which includes the Retirement Protection Act of 1994,

are set forth.

ADMINISTRATIVE

Rev. Proc. 96–24A, page 12.

General rules and specifications for private printing of

Forms W–2 and W–3. Specifications are set forth for the

private printing of paper substitutes for tax year 1996

Form W–2, Wage and Tax Statement, and Form W–3,

Transmittal of Wage and Tax Statements. Rev. Proc.

96–24 modified and amplified.

Rev. Rul. 96–21, page 7.

Phase-in of increases in funding. Questions and answers

pertaining to the election to phase in increases in

additional funding requirements for certain plans under

section 412(l)(11) of the Internal Revenue Code as

(Continued on page 4)

Finding Lists begins on page 21.

Announcement of Disbarments and Suspensions begin on page 18.

SEQ 0003 JOB C48-002-001 PAGE-0002 MISSION

REVISED 30JUN96 AT 22:14 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-002

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 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.

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.

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.

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.

SEQ 0004 JOB C48-002-001 PAGE-0003 MISSION

REVISED 30JUN96 AT 22:14 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-002

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.

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.

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.

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 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.

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).

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.

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 Bulletin Index-Digest System, a research and

reference service supplementing the Bulletin, may be

obtained from the Superintendent of Documents on a

subscription basis. It consists of four Services: Service

No. 1, Income Tax; Service No. 2, Estate and Gift

Taxes; Service No. 3, Employment Taxes; Service No.

4, Excise Taxes. Each Service consists of a basic

volume and a cumulative supplement that provides (1)

finding lists of items published in the Bulletin, (2)

digests of revenue rulings, revenue procedures, and

other published items, and (3) indexes of Public Laws,

Treasury Decisions, and Tax Conventions.

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.

SEQ 0002 JOB C48-001-007 PAGE-0004 COVER

REVISED 30JUN96 AT 22:14 BY LR DEPTH: 66.04 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-001

HIGHLIGHTS

OF THIS ISSUE—Continued

ADMINISTRATIVE—Continued

Announcement 96–20, page 15.

EE–24–93, 1995–41 I.R.B. 33, providing guidance

concerning the notice and consent requirements under

section 411(a)(11) and the notice and election requirements of section 417, is corrected.

Announcement 96–19, page 15.

T.D. 8634, 1996–3 I.R.B. 17, relating to the income

tax withholding requirement on distributions of profits

from certain gaming activities made to members of

Indian tribes, is corrected.

SEQ 0005 JOB C48-003-008 PAGE-0005 PART I PAGE 4

REVISED 30JUN96 AT 22:14 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-003

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

Section 412.—Minimum Funding

Standards

Additional funding requirements for

certain plans. Questions and answers

with respect to the establishment and

maintenance of amortization bases for

certain plans that have additional funding requirements described in section

412(1) of the Internal Revenue Code as

amended by the Uruguay Round Agreements Act, which includes the Retirement Protection Act of 1994, are set

forth.

Rev. Rul. 96–20

PURPOSE

This revenue ruling provides questions and answers relating to the

establishment and maintenance of certain amortization bases under § 412(l)

of the Internal Revenue Code, as

amended by the Retirement Protection

Act of 1994 (RPA ’94), which is part

of the Uruguay Round Agreements Act,

Pub. L. 103–65 (GATT).

BACKGROUND

Section 412 of the Code imposes

minimum funding requirements with

respect to defined benefit and money

purchase pension plans. Section 412(l)

sets forth additional funding requirements for certain underfunded defined

benefit pension plans that have more

than 100 participants and that are not

multiemployer plans.

The additional funding charge under

§ 412(l)(1) is determined as the sum of

(1) the excess (if any) of (A) the deficit

reduction contribution determined under § 412(l)(2) for the plan year over

(B) the sum of certain charges for the

plan year under § 412(b)(2) reduced by

the sum of certain credits for the plan

year under § 412(b)(3), and (2) the

unpredictable contingent event amount

(if any) for the plan year.

The deficit reduction contribution is

determined as the sum of the unfunded

new liability amount, the expected

increase in current liability due to

benefits accruing during the plan year,

and the amortization amounts for certain amortization bases. These amortization bases (unfunded old liability,

unfunded existing benefit increase lia-

bility, additional unfunded old liability,

and the liability for unfunded mortality

increase) are collectively referred to in

this revenue ruling as ‘‘DRC amortization bases.’’ The unfunded new liability amount is the applicable percentage of the unfunded new liability. The

applicable percentage is based upon the

plan’s funded current liability percentage. The unfunded new liability is the

excess, if any, of the unfunded current

liability for the plan year over the sum

of (1) the unamortized portions of the

DRC amortization bases, and (2) the

liability with respect to any unpredictable contingent event benefits for

which the unpredictable contingent

event has occurred.

The amortization base for the unfunded old liability described in

§ 412(l)(3)(B) is established, if appropriate, for the plan year beginning in

1989. This unfunded old liability is

amortized over 18 years, beginning

with the 1989 plan year.

The amortization base for the unfunded existing benefit increase liability described in § 412(l)(3)(C)(ii) is

established, if appropriate, for the plan

year in which the benefit increase

relating to the liability becomes effective, or, at the election of the employer,

for the plan year beginning in 1989.

This unfunded existing benefit increase

liability is amortized over 18 years

beginning with the plan year for which

the base is established.

RPA ’94 amended § 412(l), effective

for plan years beginning after December 31, 1994, to further specify the

actuarial assumptions used to determine

current liability for purposes of

§ 412(l). Section 412(l)(9)(A), added

by RPA ’94, provides that § 412(l)

does not apply to plans with a funded

current liability percentage of at least

90 percent. Section 412(l)(9)(B)

provides a volatility rule under which

§ 412(l) also does not apply (for up to

a two-year period) to certain plans with

funded current liability percentages of

at least 80 percent.

Under RPA ’94, the amortization

base for the additional unfunded old

liability described in § 412(l)(3)(D) is

established, if appropriate, for the 1995

plan year. Section 412(l)(3)(E) provides

an optional alternative calculation for

the additional unfunded old liability.

The additional unfunded old liability is

amortized over 12 years, beginning

with the 1995 plan year.

Under RPA ’94, the amortization

base for the unfunded mortality increase described in § 412(l)(10)(B) (the

increase in current liability resulting

from changes in the mortality table

used to determine current liability after

1999) is established, if appropriate, in

the first plan year a new mortality table

issued under § 412(l)(7)(C)(ii)(II) or

(III) is used for the plan. This unfunded

mortality increase is amortized over a

period of 10 years beginning with the

plan year in which the base is

established.

Any plan year described above for

which an amortization base is

established, if appropriate, for purposes

of § 412(l) is referred to in this

revenue ruling as a ‘‘DRC base year.’’

QUESTIONS AND ANSWERS ON

THE ESTABLISHMENT OF DRC

AMORTIZATION BASES

Q-1. If § 412(l) applies to a plan for

a plan year that is a DRC base year,

must the appropriate DRC amortization

base be established for that plan year?

A-1. If § 412(l) applies to a plan for

a plan year that is a DRC base year,

the appropriate DRC amortization base

must be established for that year. Thus,

for example, if § 412(l) applies to a

plan for the 1995 plan year, the

increase in current liability resulting

from the required change in actuarial

assumptions must be included in the

additional unfunded old liability as

provided under §§ 412(l)(3)(D) or

412(l)(3)(E) and may not be included

in unfunded new liability.

Q-2. If § 412(l) does not apply to a

plan for a plan year that is a DRC base

year, are any DRC amortization bases

established for that year to prepare for

the contingency that § 412(l) may

apply to the plan in a future plan year?

A-2. If § 412(l) does not apply to a

plan for a plan year that is a DRC base

year, then except as provided under

Q&A-3, no DRC amortization base is

established to prepare for the contingency that § 412(l) may apply to the

plan in a future plan year. For example,

if for the plan year beginning in 1989,

a plan had no unfunded current liability, was a multiemployer plan, or

had 100 or fewer participants within

the meaning of § 412(l)(6), no amortization base for unfunded old liability is

SEQ 0006 JOB C48-003-008 PAGE-0006 PART I PAGE 4

REVISED 30JUN96 AT 22:14 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-003

established. Similarly, if for the plan

year beginning in 1995, a plan had a

funded current liability percentage (determined under § 412(l)(9)(C)) of 90

percent or greater, was a multiemployer

plan, or had 100 or fewer participants

within the meaning of § 412(l)(6), no

amortization base for additional unfunded old liability is established.

Q-3. In the case of a plan year that

is a DRC base year, if § 412(l) does

not apply to a plan for that plan year

solely by reason of the application of

the exception provided under

§ 412(l)(9)(B) (taking into account the

special rules of § 412(l)(9)(D)), are any

DRC amortization bases established for

that plan year to prepare for the

contingency that § 412(l) may apply to

the plan in a future plan year?

A-3. In the case of a plan year that

is a DRC base year, if § 412(l) does

not apply to a plan for that plan year

solely by reason of the application of

the exception provided under

§ 412(l)(9)(B) (taking into account the

special rules in § 412(l)(9)(D)), the

appropriate DRC amortization base is

established for that plan year. Thus, for

example, if § 412(l) does not apply to a

plan with a funded current liability

percentage (determined under

§ 412(l)(9)(C)) that is at least 80

percent but that is less than 90 percent

for the plan year beginning in 1995,

solely because of the exception under

§ 412(l)(9)(B) (taking into account the

special rules under § 412(l)(9)(D)), an

additional unfunded old liability base is

established for that plan year. In such a

case, if the optional rule under

§ 412(l)(3)(E) is to be used to determine the additional unfunded old liability, an employer must make an

election which is reported on a timely

filed 1995 Form 5500.

Q-4. If § 412(l) does not apply to a

plan for a plan year (other than by

reason of § 412(l)(9)(B) and (D)) that

is a DRC base year (and, thus, no

amortization base is established for that

plan year in accordance with Q&A-2),

is the DRC amortization base that

would otherwise have been established

if § 412(l) had applied to the plan for

that plan year established in any

subsequent year?

A-4. If § 412(l) does not apply to a

plan for a plan year (other than by

reason of § 412(l)(9)(B) and (D)) that

is a DRC base year (and, thus, no

amortization base is established for that

plan year in accordance with Q&A-2),

the DRC amortization base that otherwise would have been established if

§ 412(l) had applied to the plan for that

plan year is not established or recreated

in any subsequent year. Thus, for

example, if a plan’s funded current

liability percentage (determined under

§ 412(l)(9)(C)) is at least 90 percent

for the 1995 plan year (and, thus,

§ 412(l) does not apply to the plan for

the 1995 plan year), and if § 412(l)

applies to the plan for the 1996 plan

year, then for the 1996 plan year all of

the plan’s unfunded current liability

will be unfunded new liability (with the

possible exception of the liability with

respect to any unpredictable contingent

event benefits resulting from an unpredictable contingent event that occurs in

1996).

QUESTIONS AND ANSWERS ON

THE MAINTENANCE OF DRC

AMORTIZATION BASES

Q-5. How is the unamortized portion

of a DRC amortization base

determined?

A-5. For the plan year for which a

DRC amortization base is established,

the unamortized portion of that base is

the amount of the liability that gives

rise to the base, as determined under

§ 412(l)(3) or (10), as applicable. For

any subsequent plan year, the unamortized portion of a DRC amortization

base is determined by reducing the

unamortized portion as of the valuation

date for the prior plan year by the

amortization amount for the prior plan

year, and adjusting the result with

interest to the valuation date in the

current plan year at the appropriate

current liability interest rate.

Q-6. How is the annual amortization

amount for a DRC amortization base

determined?

A-6. The annual amortization amount

for a DRC amortization base is determined by amortizing the unamortized

portion of the DRC amortization base

over the remainder of the statutory

amortization period using the appropriate current liability interest rate for the

plan year. These annual amortization

amounts are included in the calculation

of the deficit reduction contribution

under § 412(l)(2), until the DRC amortization base is fully amortized or

considered to be fully amortized.

Q-7. When is a DRC amortization

base considered to be fully amortized

prior to the end of the scheduled

amortization period?

A-7. Except as otherwise provided in

this Q&A-7, a DRC amortization base

that was established in a prior DRC

base year is considered to be fully

amortized for the first plan year for

which § 412(l) does not apply to the

plan. However, if § 412(l) does not

apply to the plan for a plan year solely

by reason of the exception provided

under § 412(l)(9)(B) (taking into account the special rules in

§ 412(l)(9)(D)), then any DRC amortization bases are not considered to be

fully amortized for that plan year, but

are maintained in accordance with

Q&A-5 above. For example, under the

provisions of § 412(l) as in effect prior

to amendment by RPA ’94, any DRC

amortization base is considered to be

fully amortized in the first plan year

after establishment of such base for

which (1) the plan’s funded current

liability percentage (determined under

§ 412(l)(8)(B)) is 100 percent or

greater, (2) the plan is reestablished as

a multiemployer plan, or (3) the plan

has 100 or fewer participants within the

meaning of § 412(l)(6). Similarly, under the provisions of § 412(l) as in

effect after amendment by RPA ’94,

any DRC amortization base (whether or

not created prior to the effective date

of RPA ’94) is considered to be fully

amortized for the first plan year after

establishment of such base for which

(1) the plan’s funded current liability

percentage (determined under

§ 412(l)(9)(C)) is 90 percent or greater,

(2) the plan is reestablished as a

multiemployer plan, or (3) the plan has

100 or fewer participants within the

meaning of § 412(l)(6).

DRAFTING INFORMATION

The principal author of this revenue

ruling is Martin L. Pippins of the

Employee Plans Division. For further

information regarding this revenue ruling, please contact the Employee Plans

Division’s taxpayer assistance telephone service between 2:30 p.m. and

4:00 p.m. Eastern Time, Monday

through Thursday on (202) 622-6076

(Actuarial Hotline) (not a toll-free

telephone number). Mr. Pippins’ telephone number is (202) 622-6261 (also

not a toll-free number).

SEQ 0007 JOB C48-003-008 PAGE-0007 PART I PAGE 4

REVISED 30JUN96 AT 22:14 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-003

(Also see, § 7805; 26 CFR 301.7805–1.)

Phase-in of increases in funding.

Questions and answers pertaining to the

election to phase in increases in additional funding requirements for certain

plans under section 412(l)(11) of the

Internal Revenue Code as amended by

the Uruguay Round Amendments Act,

which includes the Retirement Protection Act of 1994, are set forth.

Rev. Rul. 96–21

PURPOSE

This revenue ruling provides questions and answers relating to the

transition rule of § 412(l)(11) of the

Internal Revenue Code, as amended by

the Retirement Protection Act of 1994

(RPA ’94), which is part of the

Uruguay Round Agreements Act, Pub.

L. 103–465 (GATT).

BACKGROUND

Section 412 of the Code imposes

minimum funding requirements with

respect to defined benefit and money

purchase pension plans. Section 412(l)

sets forth additional funding requirements for certain underfunded defined

benefit pension plans that have more

than 100 participants and that are not

multiemployer plans. The additional

funding requirements are in the form of

an additional funding charge under

§ 412(l)(1) and are generally based on

a plan’s unfunded current liability, as

defined in § 412(l)(8).

RPA ’94 amended § 412(l) to modify the additional funding charge in

order to produce faster funding of a

plan’s unfunded current liability. The

amendments increased the unfunded

new liability amount, changed the way

in which the additional charge was

integrated with the charges and credits

under § 412(b), and further specified

the actuarial assumptions used to determine current liability for purposes of

§ 412(l). RPA ’94 also provided certain

transition rules to be used in determining the amount of the additional

funding charge.

Section 412(l)(11) of the Code

provides a temporary transition rule

that allows employers to phase in

increases in the additional funding

charge due to changes made by RPA

’94. This transition rule applies for

plan years beginning after December

31, 1994, and before January 1, 2002.

Section 412(l)(11) provides that, at the

election of the employer, the additional

funding charge computed for a plan

year under § 412(l)(1) shall not exceed

the greater of (1) the additional funding

charge for the plan year that would

have been required under § 412(l)(1),

as in effect prior to amendment by

RPA ’94, or (2) the amount that, after

taking into account charges (other than

the additional funding charge) and

credits under § 412(b), is necessary to

increase the funded current liability

percentage of the plan for the plan year

to the sum of the initial funded current

liability percentage and the applicable

number of percentage points determined under § 412(l)(11)(B).

QUESTIONS AND ANSWERS ON

THE ELECTION UNDER

§ 412(l)(11)

Q-1. What is the election under

§ 412(l)(11)?

A-1. Under § 412(l)(11), an election

may be made to limit the additional

funding charge under § 412(l)(1) for a

plan year. If the transition rule under

§ 412(l)(11) is elected for a plan year,

the additional funding charge under

§ 412(l)(1) for the plan year is equal to

the lesser of (1) the additional funding

charge for the plan year determined

without regard to § 412(l)(11), or (2)

the greater of (A) the additional funding charge that would have been

required for the plan year under

§ 412(l)(1) as in effect prior to amendment by RPA ’94, and (B) the additional amount necessary to increase the

funded current liability percentage of

the plan to the ‘‘target percentage’’ (as

defined in Q&A-6) for that plan year.

Q-2. For what plans may the election

under § 412(l)(11) be made?

A-2. An election under § 412(l)(11)

may be made for any ‘‘eligible plan.’’

For this purpose, an ‘‘eligible plan’’ is

any plan to which § 412(l) applies for

the plan year beginning in 1995, or any

plan to which § 412(l) does not apply

for the plan year beginning in 1995

solely by reason of the exception

provided under § 412(l)(9)(B) (taking

into account the special rules of

§ 412(l)(9)(D)). The election under

§ 412(l)(11) may not be made for a

plan that is not an ‘‘eligible plan.’’

Q-3. For what plan years may an

election under § 412(l)(11) be made for

an ‘‘eligible plan?’’

A-3. For an ‘‘eligible plan,’’ an

election under § 412(l)(11) may be

made for any plan year beginning after

December 31, 1994, and before January

1, 2002, regardless of whether an

election under § 412(l)(11) has been

made for any prior plan year. An

election made under § 412(l)(11) for a

plan year is irrevocable for that plan

year.

Q-4. Who makes the election under

§ 412(l)(11), and must the election be

reported?

A-4. Any election under § 412(l)(11)

is made by the employer maintaining

the plan. An election under

§ 412(l)(11) for a plan year is effective

only if the first Form 5500 filed for the

plan year reports that the election has

been made for the plan year, and the

Form 5500 is filed not later than the

due date, including extensions.

QUESTIONS AND ANSWERS ON

THE CALCULATIONS UNDER

§ 412(l)(11)

Q-5. For purposes of applying

§ 412(l)(11) to a plan year, how is the

additional amount necessary to increase

the funded current liability percentage

of the plan to the ‘‘target percentage’’

determined for that plan year?

A-5. For purposes of applying

§ 412(l)(11) to a plan year, the additional amount (the ‘‘target amount’’)

necessary to increase the funded current liability percentage of a plan to the

‘‘target percentage’’ for that plan year

is the excess, if any, of the product of

the ‘‘target percentage’’ and the ‘‘adjusted current liability’’ of the plan,

over the ‘‘adjusted assets’’ of the plan.

Q-6. How is the ‘‘target percentage’’

determined for purposes of computing

the ‘‘target amount’’ for a plan year?

A-6. For purposes of computing the

‘‘target amount’’ for a plan year, the

‘‘target percentage’’ for the plan year

is the plan’s initial funded current

liability percentage, plus the applicable

number of percentage points computed

under § 412(l)(11)(B) for the plan year.

The plan’s initial funded current

liability percentage is the funded current liability percentage of the plan for

the plan year beginning in 1995. This

percentage is calculated as of the

valuation date for that plan year, and is

equal to the actuarial value of assets

divided by the current liability of the

plan computed under § 412(l)(7). For

purposes of computing the initial

SEQ 0008 JOB C48-003-008 PAGE-0008 PART I PAGE 4

REVISED 30JUN96 AT 22:14 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-003

funded current liability percentage, the

actuarial value of assets is reduced by

any credit balance in the plan’s funding

standard account as of the end of the

prior plan year, adjusted with interest

to the valuation date (using the valuation interest rate). Also, for this purpose, the current liability does not

include the expected increase in current

liability due to benefits accruing during

the plan year beginning in 1995.

Q-7. How is the ‘‘adjusted current

liability’’ determined for purposes of

computing the ‘‘target amount’’ for a

plan year?

A-7. For purposes of computing the

‘‘target amount’’ for a plan year, the

adjusted current liability is equal to the

excess of (1) the current liability of the

plan for the plan year, including the

expected increase in current liability

due to benefits accruing during the plan

year, computed under § 412(l)(7), over

(2) the expected release from current

liability on account of disbursements

(including single sum distributions)

from the plan expected to be paid after

the valuation date but prior to the end

of the plan year. The components of

this calculation are determined as of

the valuation date, and each is appropriately adjusted with interest to the

end of the plan year using the interest

rate used to determine current liability

under § 412(l)(7).

Q-8. How are the ‘‘adjusted assets’’

determined for purposes of computing

the ‘‘target amount’’ for a plan year?

A-8. For purposes of computing the

‘‘target amount’’ for a plan year, the

‘‘adjusted assets’’ are equal to the

actuarial value of assets for the plan

year adjusted by (1) subtracting any

credit balance (or adding any debit

balance) in the plan’s funding standard

account as of the end of the prior plan

year, adjusted with interest to the

valuation date at the valuation interest

rate, (2) subtracting the disbursements

from the plan (including single sum

distributions) expected to be paid after

the valuation date but prior to the end

of the plan year, (3) adding the charges

to the funding standard account as

maintained under § 412(b) for the plan

year (other than the additional funding

charge under § 412(l)), and (4) subtracting the credits to the funding

standard account as maintained under

§ 412(b) for the plan year (other than

credits under §§ 412(b)(3)(A) and

412(b)(3)(C)). The actuarial value of

assets and the adjustments described

above are determined as of the valuation date, and each is appropriately

adjusted with interest to the end of the

plan year at the valuation interest rate.

The result of this calculation may be a

negative number, which would increase

the ‘‘target amount’’.

Q-9. How is the additional funding

charge that would have been required

under § 412(l)(1), as in effect prior to

amendment by RPA ’94, determined?

A-9. The determination of the additional funding charge that would have

been required under § 412(l)(1), as in

effect prior to amendment by RPA ’94,

is the same as the determination of the

additional funding charge required under 412(l)(1), as amended by RPA ’94,

with the following exceptions:

(1) If the current liability under

§ 412(l), as amended by RPA ’94, is

determined using an interest rate that is

the highest rate in the permissible

range under § 412(l)(7)(C), the current

liability under § 412(l) as in effect

prior to amendment by RPA ’94 is

determined using the interest rate used

for purposes of § 412(c)(7)(A). In such

a case, the latter interest rate must be

the interest rate under § 412(l)(7)(C) or

any higher rate permitted under

§ 412(b)(5)(B). On the other hand, if

the current liability under § 412(l), as

amended by RPA ’94, is determined

using an interest rate that is less than

the highest interest rate in the permissible range under § 412(l)(7)(C), the

current liability under § 412(l) as in

effect prior to amendment by RPA ’94

(and the current liability for purposes

of the full funding limitation under

§ 412(c)(7)(A)) is determined using the

same interest rate used to determine

current liability under § 412(l), as

amended by RPA ’94.

(2) The mortality table used to

determine current liability is the mortality table used to determine costs and

liabilities under the plan in accordance

with § 412(c)(3).

(3) In determining the additional

funding charge, the deficit reduction

contribution is offset under

§ 412(l)(1)(A)(ii) solely by amortization charges under § 412(b)(2)(B)

(other than clauses (iv) and (v) thereof)

and § 412(b)(2)(C) and (D), reduced by

the sum of credits under

§ 412(b)(3)(B)(i).

(4) The amount of the additional

funding charge is limited to the unfunded current liability, rather than the

amount that, after taking into account

charges (other than the additional funding charge) and credits under § 412(b),

is necessary to increase the funded

current liability percentage (taking into

account the expected increase in current liability due to benefits accruing

during the plan year) of the plan to 100

percent.

(5) The deficit reduction contribution

under § 412(l)(2) does not include the

expected increase in current liability

due to benefits accruing during the plan

year and the aggregate of the unfunded

mortality increase amounts.

(6) The unfunded old liability

amount under § 412(l)(3) is determined

without including any amortization of

additional unfunded old liability under

§ 412(l)(3)(D) or (E).

(7) The applicable percentage under

§ 412(l)(4)(C) for computing the unfunded new liability amount is equal to

30 percent reduced by the product of

.25 multiplied by the number of percentage points by which the funded

current liability percentage exceeds 35

percent.

(8) The unfunded new liability under

§ 412(l)(4)(B) is determined by subtracting from the unfunded current

liability of the plan the unamortized

portion of the unfunded old liability,

the unamortized portion of the unfunded existing benefit increase liability, and the liability with respect to

any unpredictable contingent event benefits (without regard to whether the

event has occurred).

(9) In determining the deficit reduction contribution, any unfunded old

liability base or unfunded existing

benefit increase liability base continues

to be amortized for the duration of the

original amortization period, or until an

earlier time determined under Q&A-7

of Rev. Rul. 96–20 (as those rules

would be applied under § 412(l) as in

effect prior to amendment by RPA

’94).

(10) The unpredictable contingent

event amount under § 412(l)(5) is

determined without regard to

§ 412(l)(5)(A)(iii) and § 412(l)(5)(E).

(11) Sections 412(l)(9) and

412(l)(11), as added by RPA ’94, are

not taken into account.

In addition, for purposes of computing

the additional funding charge that

would have been required under

§ 412(l)(1), as in effect prior to RPA

’94, the credit balance used should be

the actual credit balance of the plan for

the plan year.

SEQ 0009 JOB C48-003-008 PAGE-0009 PART I PAGE 4

REVISED 30JUN96 AT 22:14 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-003

Q-10. How is the target amount computed given the following fact pattern?

General facts:

The employer elects the transition rule under § 412(l)(11) for the 1995 plan year. The plan year is the calendar year, and

the valuation date is January 1, 1995. The valuation interest rate is 8.5 percent and the § 412(l)(7)(C) interest rate is 7.93

percent.

The valuation results are as follows:

RPA ’94 current liability

$1,000,000

Expected increase in current liability due to benefits accruing during the plan year

Actuarial value of assets

$ 720,000

Prior year credit balance

20,000

Expected disbursements (expected to be paid on 12/31/95)

50,000

Expected release from current liability as a result of expected disbursements (valued as of

1/1/95)

40,000

§ 412(b) charges (other than the additional funding charge), including interest to 12/31/95

$ 100,000

§ 412(b) credits, including interest to 12/31/95

A-10. The ‘‘target amount’’ is the

excess, if any, of the product of the

‘‘target percentage’’ and the ‘‘adjusted

current liability’’, over the ‘‘adjusted

assets’’.

The ‘‘target percentage’’ for the plan

is the plan’s ‘‘initial funded current

liability percentage’’ plus the applicable number of percentage points under

§ 412(l)(11)(B). The plan’s ‘‘initial

funded current liability percentage’’ is

equal to the actuarial value of assets

(reduced by the prior year credit

balance), divided by the plan’s current

liability as of the valuation date. Thus,

the plan’s ‘‘initial funded current liability percentage’’ is 70 percent

($720,000 minus $20,000, divided by

$1,000,000), and the ‘‘target percentage’’ is 73 percent (70 percent plus 3

percent, the applicable number of percentage points under § 412(l)(11)(B)).

The ‘‘adjusted current liability’’ of

the plan is equal to the excess of

$1,070,000 (the sum of $1,000,000 and

$70,000) over $40,000, each adjusted

with interest to the end of the plan year

at the § 412(l)(7)(C) interest rate. The

$1,070,000 is adjusted with a full

year’s interest ($1,070,000 times

1.0793, or $1,154,851) and the $40,000

is adjusted with a full year’s interest at

the same rate ($40,000 times 1.0793, or

$43,172). The resulting ‘‘adjusted current liability’’ is $1,111,679

($1,154,851 minus $43,172).

The ‘‘adjusted assets’’ of the plan

are equal to $720,000 minus $20,000,

minus $50,000, plus $100,000, minus

70,000

75,000

$75,000, each adjusted with interest

from the appropriate date to the end of

the plan year at the valuation interest

rate. The $720,000 and $20,000 as

adjusted with a full year’s interest at

the valuation interest rate equals

$759,500 ($720,000 minus $20,000,

times 1.085). The $50,000 receives no

interest adjustment, as benefit payments

are expected to be paid at the end of

the year. The charges and credits

already are calculated with interest to

the end of the year. The resulting

‘‘adjusted assets’’ is $734,500

($759,500, minus $50,000, plus

$100,000, minus $75,000).

The ‘‘target amount’’ is equal to the

excess of the product of 73 percent (the

‘‘target percentage’’) and $1,111,679

(the ‘‘adjusted current liability’’), over

$734,500 (the ‘‘adjusted assets’’), or

$77,026.

ing, please contact the Employee Plans

Division’s taxpayer assistance telephone service between 2:30 p.m. and

4:00 p.m. Eastern Time, Monday

through Thursday on (202) 622-6076

(Actuarial Hotline) (not a toll-free

telephone number). Mr. Pippins’ telephone number is (202) 622-6261 (also

not a toll-free number).

APPLICATION OF § 7805(b)

Rev. Rul. 96–22

Pursuant to § 7805(b), this revenue

ruling shall not be applied for purposes

of determining the amount of any

required installment under § 412(m)(4),

if the due date for that required

installment is on or before April 15,

1996.

The following Department Store Inventory Price Indexes for February

1996 were issued by the Bureau of

Labor Statistics on March 15, 1996.

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 lastin, first-out inventory methods for tax

years ended on, or with reference to,

February 29, 1996.

DRAFTING INFORMATION

The principal author of this revenue

ruling is Martin L. Pippins of the

Employee Plans Division. For further

information regarding this revenue rul-

§ 472.—Last-in, First-out Inventories

26 CFR 1.472–1: Last-in, first-out inventories.

LIFO; price indexes; department

stores. The February 1996 Bureau of

Labor Statistics price indexes are accepted for use by department stores

employing the retail inventory and lastin, first-out inventory methods for

valuing inventories for tax years ended

on, or with reference to, February 29,

1996.

SEQ 0010 JOB C48-003-008 PAGE-0010 PART I PAGE 4

REVISED 30JUN96 AT 22:14 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-003

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, foods, liquor,

tobacco, and contract departments.

BUREAU OF LABOR STATISTICS, DEPARTMENT STORE

INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS

(February 1941 = 100, unless otherwise noted)

Feb. 1995

Feb. 1996

Percent Change from

Feb. 1995 to Feb.

1996 1

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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

480.0

645.9

633.8

925.5

617.3

518.2

283.0

542.0

413.0

602.4

560.5

488.9

995.5

750.7

839.3

654.9

579.6

771.1

246.4

85.6

114.7

121.3

107.0

505.1

651.2

644.5

895.1

645.3

522.3

289.3

552.3

402.0

619.5

570.8

476.6

1003.4

813.7

871.0

666.9

563.4

799.7

249.2

79.0

113.6

123.1

107.3

5.2

0.8

1.7

–3.3

4.5

0.8

2.2

1.9

–2.7

2.8

1.8

–2.5

0.8

8.4

3.8

1.8

–2.8

3.7

1.1

–7.7

–1.0

1.5

0.3

Groups 1—15: Soft Goods . . . . . . . . . . . . . . . . . . . . . . . . . . .

586.4

590.0

0.6

Groups 16—20: Durable Goods . . . . . . . . . . . . . . . . . . . . . . .

465.1

467.3

0.5

Groups 21—23: Misc. Goods2 . . . . . . . . . . . . . . . . . . . . . . . .

114.3

113.8

–0.4

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

545.8

548.3

0.5

Groups

1Absence

of a minus sign before percentage change in this column signifies price increase.

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, tobacco, and contract departments.

2Indexes

DRAFTING INFORMATION

The principal author of this revenue

ruling is Stan Michaels of the Office of

Assistant Chief Counsel (Income Tax

and Accounting). For further information regarding this revenue ruling,

contact Mr. Michaels on (202)

622-4970 (not a toll-free call).

Section 2032A.—Valuation of Certain

Farm, Etc., Real Property

26 CFR 20.2032A–4: Method of valuing farm

real property.

Special use value; farms; interest

rates. The 1996 interest rates to be

used in computing the special use value

of farm real property for which an

election is made under section 2032A

of the Code are listed for estates of

decedents.

SEQ 0011 JOB C48-004-009 PAGE-0011 PART I PAGE 10

REVISED 30JUN96 AT 22:14 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-004

Rev. Rul. 96–23

This revenue ruling contains a list of

the average annual effective interest

rates on new loans under the Farm

Credit Bank system. This revenue

ruling also contains a list of the states

within each Farm Credit Bank District.

Under § 2032A(e)(7)(A)(ii) of the

Internal Revenue Code, rates on new

Farm Credit Bank loans are used

in computing the special use value of

real property used as a farm for which

an election is made under § 2032A.

The rates in this revenue ruling may be

used by estates that value farmland

under § 2032A as of a date in 1996.

Average annual effective interest

rates, calculated in accordance with

§ 2032A(e)(7)(A) and § 20.2032A–4(e)

of the Estate Tax Regulations, to be

used under § 2032A(e)(7)(A)(ii), are

set forth in the accompanying Table of

Interest Rates (Table 1). The states

within each Farm Credit Bank District

are set forth in the accompanying Table

of Farm Credit Bank Districts (Table

2).

Rev. Rul. 81–170, 1981–1 C.B. 454,

contains an illustrative computation of

an average annual effective interest

rate. The rates applicable for valuation

in 1995 are in Rev. Rul. 95–38, 1995–1

C.B. 184. For rate information for

years prior to 1995, see Rev. Rul. 94–

33, 1994–1 C.B. 235, and other revenue rulings that are cited therein.

DRAFTING INFORMATION

The principal author of this revenue

ruling is Lane Damazo of the Office of

Assistant Chief Counsel (Passthroughs

and Special Industries). For further

information regarding this revenue ruling, contact Lane Damazo on (202)

622-3090 (not a toll-free call).

REV. RUL. 96–23 TABLE 1

TABLE OF INTEREST RATES

(Year of Valuation 1996)

Farm Credit Bank District in Which Property Is Located

Interest

Rate

Columbia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Omaha . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Sacramento . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

St. Paul . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Spokane . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Springfield . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Texas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Wichita. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

8.98

8.38

9.28

8.73

8.48

8.59

8.86

8.44

REV. RUL. 96–23 TABLE 2

TABLE OF FARM CREDIT BANK DISTRICTS

District

States

Columbia . . . . . . . . . . . . . . . . . . . .

Delaware, District of Columbia, Florida, Georgia, Maryland, North

Carolina, Pennsylvania, South Carolina, Virginia, West Virginia.

Iowa, Nebraska, South Dakota, Wyoming.

Arizona, California, Hawaii, Nevada, Utah.

Arkansas, Illinois, Indiana, Kentucky, Michigan, Minnesota, Missouri,

North Dakota, Ohio, Tennessee, Wisconsin.

Alaska, Idaho, Montana, Oregon, Washington.

Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New

York, Rhode Island, Vermont.

Alabama, Louisiana, Mississippi, Texas.

Colorado, Kansas, New Mexico, Oklahoma.

Omaha . . . . . . . . . . . . . . . . . . . . . .

Sacramento . . . . . . . . . . . . . . . . . .

St. Paul . . . . . . . . . . . . . . . . . . . . .

Spokane . . . . . . . . . . . . . . . . . . . . .

Springfield . . . . . . . . . . . . . . . . . . .

Texas . . . . . . . . . . . . . . . . . . . . . . .

Wichita . . . . . . . . . . . . . . . . . . . . . .

Sec. 7805.—Rules And Regulations

26 CFR 301.7805–1: Rules and regulations.

required installment under § 412(m)(4) that is

due on or before April 15, 1996. See Rev. Rul.

96–21, page 7.

Whether § 7805 of the Code will be applied

for purposes of determining the amount of any

SEQ 0012 JOB C48-005-004 PAGE-0012 PART III PAGE 12

REVISED 30JUN96 AT 22:14 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-005

Part III. Administrative, Procedural, and Miscellaneous

General Rules and Specifications for

Private Printing of Form W-2, Wage

and Tax Statement and Form W-3,

Transmittal of Wage and Tax

Statements

Rev. Proc. 96–24A

This revenue procedure modifies and

amplifies Part A, Sections 2.03 and

2.07, Part B, Section 1.10 and 2.02,

and Part C, Section 1.02, of Revenue

Procedure 96–24, 1996–5 I.R.B. 5,

which provides the General Rules and

Specifications for Private Printing of

Form W-2, Wage and Tax Statement,

and Form W-3, Transmittal of Wage

and Tax Statements. The requirement

to place a barcode on copies B, C, 1,

and 2 of Form W-2, as stated in Part

A, Section 2.03, and Part B, Section

2.02, has been repealed for Tax Year

1996. However, this requirement may

be reinstated for Tax Year 1997.

In addition, the term OCRA Font

found throughout the text, has been

changed to OCR–A Font. The term

OCR–A Font was excluded from Part

A, Section 2.07, and Part C, Section

1.02. The revised language reads as

follows: The tax year must be printed

in black ink on Form W-3. The tax

year must also be printed in black ink

using OCR–A Font, only on Form

W-2, Copy A (See Exhibit A). The

form number and title must be printed

in red OCR drop-out ink on Form W-2,

Copy A, and Form W-3.

Also, the language in Part B, Section

1.10 has been revised because the

Social Security Administration’s address was removed from the first page

of Form W-3. The revised language

reads as follows: The section ‘‘Where

to File’’ in the general instructions on

the employer’s copy of the official

Form W-3 must be printed in its

entirety on all substitute Forms W-3

(See Exhibit B).

EFFECT ON OTHER DOCUMENTS

Rev. Proc. 96–24 is modified and

amplified.

SEQ 0013 JOB C48-005-004 PAGE-0013 PART III PAGE 12

REVISED 30JUN96 AT 22:14 BY LR DEPTH: 65.01 PICAS WIDTH 32.10 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-005

SEQ 0014 JOB C48-005-004 PAGE-0014 PART III PAGE 12

REVISED 30JUN96 AT 22:14 BY LR DEPTH: 65.01 PICAS WIDTH 24.07 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-005

SEQ 0015 JOB C48-006-007 PAGE-0015 PART IV PAGE 15

REVISED 30JUN96 AT 22:14 BY LR DEPTH: 66.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-006

Part IV. Items of General Interest

Guidance Issued for Computation of

Additional Funding Requirements

under § 412(l) of the Internal

Revenue Code

Announcement 96–18

The Internal Revenue Service has

issued Rev. Rul. 96–20 and Rev. Rul.

96–21, to provide guidance on the

additional funding requirements under

§ 412(l) of the Internal Revenue Code,

as amended by the Retirement Protection Act of 1994 (RPA ’94). Section

412(l) provides additional funding requirements for certain underfunded defined benefit plans that have more than

100 participants and that are not

multiemployer plans.

Rev. Rul. 96–20 provides guidance

on the requirements for the establishment and maintenance of certain amortization bases under § 412(l). The

guidance is needed, in part, because the

amortization base for additional unfunded old liability is scheduled to be

established for the 1995 plan year. If

the optional rule under § 412(l)(3)(E) is

used to determine the additional unfunded old liability, an employer must

make an election which is reported on

a timely filed 1995 Form 5500 (see line

20a on Form 5500).

Rev. Rul. 96–21 provides guidance

for employers who desire to make

elections in certain years under

§ 412(l)(11) to phase in the increase in

the additional funding requirement under RPA ’94. Elections under

§ 412(l)(11) are made on line 20b of

the 1995 Form 5500.

Recently, the Service released the

1995 Forms 5500 and accompanying

instructions, including the 1995 Schedule B (Actuarial Information). Instructions for several lines on the Schedule

B were reserved pending published

guidance. The guidance in Rev. Rul.

96–21 is used to complete line 14 of

the 1995 Schedule B. The ‘‘target

amount’’ computed under Q&A-5 of

Rev. Rul. 96–21 is entered on line 14d

of the 1995 Schedule B.

The amount in line 12o of the 1995

Schedule B (the contributions needed

to increase the funded current liability

percentage of the plan to 100 percent

under § 412(l)(1)) is calculated in the

same manner as the ‘‘target amount’’,

except that 100 percent is substituted

for the ‘‘target percentage’’ (as defined

in Q&A-6 of Rev. Rul. 96–21).

Guidance relating to the calculations

of the amounts reported on lines 91(1),

91(2), and 91(3) of the 1995 Schedule

B is expected to be provided in

separate published guidance that is not

anticipated to apply to plan years

beginning in 1995.

COMMENTS REQUESTED

Public comments may be submitted

concerning issues arising under

§ 412(l), including issues related to the

topics addressed in these revenue rulings. Comments should be sent to the

following address:

Internal Revenue Service

1111 Constitution Avenue, N.W.

Washington, DC 20224

Attn: CP:E:EP

the income tax withholding requirement

on distributions of profits from certain

gaming activities made to members of

Indian tribes.

EFFECTIVE DATE: December 19,

1995.

FOR FURTHER INFORMATION

CONTACT: Rebecca Wilson (202)

622-6040 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final regulations that are the

subject to this correction are under

section 3402 of the Internal Revenue

Code.

Need for Correction

As published, TD 8634 contains an

error that is in need of clarification.

DRAFTING INFORMATION

The principal author of this announcement is Martin L. Pippins of the

Employee Plans Division. For further

information regarding this announcement, please contact the Employee

Plans Division’s taxpayer assistance

telephone service between 2:30 p.m.

and 4:00 p.m. Eastern Time, Monday

through Thursday on (202) 622-6076

(Actuarial Hotline) (not a toll-free

telephone number). Mr. Pippins’ telephone number is (202) 622-6261 (also

not a toll-free number).

Correction of Publication

Accordingly, the publication of final

regulations which are the subject of FR

Doc. 95–30683, is corrected as follows:

On page 65237, column one, in the

heading, the ‘‘RIN’’ ‘‘1545–AT12’’ is

corrected to read ‘‘1545–AT11’’.

Cynthia E. Grigsby,

Chief, Regulations Unit, Assistant Chief

Counsel (Corporate).

(Filed by the Office of the Federal Register on

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

issue of the Federal Register for March 11,

1996, 61 F.R. 9639)

Withholding on Distributions of

Indian Gaming Profits to Tribal

Members; Correction

Notice, Consent, and Election

Requirements Under Sections

411(a)(11) and 417; Correction

Announcement 96–19

AGENCY: Internal Revenue Service,

Treasury.

Announcement 96–20

ACTION:

regulations.

final

AGENCY: Internal Revenue Service,

Treasury.

SUMMARY: This document contains a

correction to final regulations [TD

8634 [1996–3 I.R.B. 17]] which were

published in the Federal Register for

Tuesday, December 19, 1995 (60 FR

65237). The final regulations relate to

ACTION: Correction to notice of proposed rulemaking by cross-reference to

temporary regulations.

Correction

SUMMARY: This document contains a

correction to proposed regulations by

1996– 27 I.R.B.

SEQ 0016 JOB C48-006-007 PAGE-0016 PART IV PAGE 15

REVISED 30JUN96 AT 22:14 BY LR DEPTH: 66.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-006

cross-reference to temporary regulations which were published in the

Federal Register for Friday, September

22, 1995 (60 FR 49236 [EE–24–93

1995–41 I.R.B. 33]). The proposed

regulations provide guidance concerning the notice and consent requirements

under section 411(a)(11) and the notice

and election requirements of section

417.

FOR FURTHER INFORMATION

CONTACT: Thomas Foley, (202)

622-6050 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The notice of proposed rulemaking

by cross-reference to temporary regulations that is the subject of this correction is under sections 411 and 417 of

the Internal Revenue Code.

Need for Correction

SUMMARY: This document provides

notice of a public hearing on proposed

Income Tax Regulations that provide

guidance concerning the notice and

consent requirements under section

411(a)(11) and the notice and election

requirements of section 417.

DATE: The public hearing will be held

Wednesday, April 24, 1996, beginning

at 10:00 a.m. Requests to speak and

outlines of oral comments must be

received by Wednesday, April 3, 1996.

ADDRESSES: The public hearing will

be held in the Commissioner’s Conference Room, third floor, Room 3313,

Internal Revenue Building, 1111 Constitution Avenue NW, Washington, DC.

Requests to speak and outlines of oral

comments should be mailed to the

Internal Revenue Service, P.O. Box

7604, Ben Franklin Station, Attn:

CC:DOM:CORP:R [EE–24–93], room

5228, Washington, DC 20044.

As published, the notice of proposed

rulemaking by cross-reference to temporary regulations contains an error

that is in need of correction.

FOR FURTHER INFORMATION

CONTACT: Christina Vasquez of the

Regulations Unit, Assistant Chief

Counsel (Corporate), (202) 622-6803

(not a toll-free number).

Correction of Publication

SUPPLEMENTARY INFORMATION:

Accordingly, the publication of the

notice of proposed rulemaking by

cross-reference to temporary regulations which is the subject of FR Doc.

95–23264, is corrected as follows:

On page 49236, in the heading, the

‘‘RIN’’ ‘‘1545–AT75’’ is corrected to

read ‘‘1545–AU05’’.

The subject of the public hearing is

proposed amendments to the Income

Tax Regulations under sections 411

and 417 of the Internal Revenue Code

of 1986. The proposed regulations

appeared in the Federal Register for

Friday, September 22, 1995 (60 FR

49236).

The rules of § 601.601(a)(3) of the

‘‘Statement of Procedural Rules’’ (26

CFR part 601) shall apply with respect

to the public hearing. Persons who

have submitted written comments

within the time prescribed in the notice

of proposed rulemaking and who also

desire to present oral comments at the

hearing on the proposed regulations

should submit not later than Wednesday, April 3, 1996, an outline of the

oral comments/testimony to be presented at the hearing and the time they

wish to devote to each subject.

Each speaker (or group of speakers

representing a single entity) will be

limited to 10 minutes for an oral

presentation exclusive of the time

consumed by the questions from the

panel for the government and answer

thereto.

Cynthia E. Grigsby,

Chief, Regulations Unit Assistant Chief

Counsel (Corporate).

(Filed by the Office of the Federal Register on

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

issue of the Federal Register for March 11,

1996, 61 F.R. 9660)

Notice, Consent, and Election

Requirements Under Sections

411(a)(11) and 417; Hearing

Announcement 96–22

AGENCY: Internal Revenue Service,

Treasury.

ACTION: Notice of public hearing on

proposed rulemaking.

1996– 27 I.R.B.

Because of controlled access restrictions, attenders cannot be admitted

beyond the lobby of the Internal

Revenue Building until 9:45 a.m.

An agenda showing the scheduling

of the speakers will be made after

outlines are received from the persons

testifying. Copies of the agenda will be

available free of charge at the hearing.

Cynthia E. Grigsby,

Chief, Regulations Unit,

Assistant Chief Counsel (Corporate)

(Filed by the Office of the Federal Register on

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

issue of the Federal Register for March 11,

1996, 61 F.R. 9659)

Foundations Status of Certain

Organizations

Announcement 96–21

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:

Alliance For The Mentally Ill In

Ruston Louisiana Inc., Ruston, LA

Art League Of Bonita Springs Inc.,

Bonita Springs, FL

Beating The Odds Development

Corp., Greenville, MS

Brevard Heritage Council Inc.,

Indiatlantic, FL

Broward Independent Living Center

Inc., Fort Lauderdale, FL

Caddo Bossier Council For Self

Esteem, Shreveport, LA

Cenla Alcohol And Drug Abuse

Advisory Council, Pineville, LA

Choral Parents Association Of Nova

High School, Davie, FL

SEQ 0017 JOB C48-006-007 PAGE-0017 PART IV PAGE 15

REVISED 30JUN96 AT 22:14 BY LR DEPTH: 66.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-006

Citizens For A Barrier Free Community

Inc., Port St Lucie, FL

Clemson University Tiger Band Assoc.,

Clemson, SC

Clinton Education Foundation For

Excellence Inc., Clinton, MS

Creative Learning Day Care Center,

Kentwood, LA

Creative Legal Solutions Inc., Miami

Beach, FL

Depression Initiative Inc., Wilson,

Wyoming

Dreher High School Athletic Booster

Club, Columbia, SC

East Cooper Community Theatre Inc.,

Isle Of Palms, SC

Ebony City Soccer Club And Youth

Development Program, Charleston,

Florida Blueberry Festival And County

Fair Inc., Ocala, FL

Foster Angels Of Broward Inc.,

Hollywood, FL

Friends Alliance Housing Inc., New

Orleans, LA

Friends Of Bet Shira Congregation

Inc., Miami, FL

Friends Of The Pasco County Library

System Inc., Hudson, FL

Great Falls Economic Development

Commission Inc., Great Falls, SC

Green Bridge Fan Club Inc., Palmetto,

Greenwood Youth Foundation Inc.,

Schlater, MS

Grimke Center, N Charleston, SC

Improvisational Composers Network

Inc., Miami, FL

Independent Educational Media Inc.,

Winter Park, FL

Irmo High School Academic Quiz

Team Booster Club, Columbia, SC

Johnny Tanner Foundation, Spartanburg, SC

Lake City Concert Series, Lake City,

League, Inc., Longwood, FL

Lealman Avenue Elementary School

PTO, St Petersburg, FL

Little Star Helping Hands Inc., Sumter,

Louisiana Bangladesh Society, New

Orleans, LA

Louisiana Sinfonietta Inc., Baton

Rouge, LA

Moultrie District Two Band Booster

Club, Mount Pleasant, SC

Mt Olive Family Training And

Counseling Center Corp., Slidell, LA

New Smyrna Beach High School Band

Parents Assoc., New Smyrna Beach,

North Baton Rouge Tutorial Program

Inc., Baton Rouge, LA

NWR Cougar Booster Club Inc.,

Brandon, MS

Opera Charleston Inc., Charleston, SC

Plaquemines Council On Aging, Port

Sulphur, LA

Raiz Inc., Miami, FL

Renes Day Care And Preschool Inc.,

New Orleans, LA

Riverfront Floodwall Corridor

Committee Inc., New Orleans, LA

Senior And Junior Services Inc., New

Orleans, LA

Service Through Economic Progress,

Pascagoula, MS

Singg Inc., Columbia, SC

Theophilus Community Living Corp.,

New Orleans, LA

Vineyards Elementary School Parent

Teacher Organization Inc., Naples,

Wright For The Riverwalk Inc., Ft

Lauderdale, FL

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.

1996– 27 I.R.B.

SEQ 0018 JOB C48-007-002 PAGE-0018 ANN DISBARMENT

REVISED 30JUN96 AT 22:15 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-007

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

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 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 attor-

ney, 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

Miller, Gorden A.

Barnes, Charles E.

Mineral Wells, WV

Louisville, KY

February 1, 1996 to April 30, 1996

Indefinite from February 1, 1996

Polizzi, Angelo J.

Pegler, Charles R.

Foster, David M.

Smith, Jerry A.

Penn, Michael J.

Mueller, E. Laird

Zezima, Paul P.

Van Houten, Robert R.

Grosse Point, MI

Islandia, NY

Birmingham, MI

Evansville, IN

Dearborn, MI

Seal Beach, CA

Norwalk, CT

Danbury, CT

CPA

Enrolled

Agent

Attorney

CPA

Attorney

CPA

Under Section 330, Title 31 of the

United States Code, the Secretary of

the Treasury, after due notice and

opportunity for hearing, is authorized

to suspend or disbar from practice

before the Internal Revenue Service

any person who has violated the rules

and regulations governing the recognition of attorneys, certified public accountants, enrolled agents or enrolled

actuaries to practice before the Internal

Revenue Service.

Attorneys, certified public accountants, enrolled agents, and enrolled

actuaries are prohibited in any Internal

Revenue Service matter from directly

Indefinite from February 6, 1996

Indefinite from February 7, 1996

Indefinite from February 9, 1996

February 9, 1996 to November 8, 1996

February 9, 1996 to February 8, 1997

February 12, 1996 to June 11, 1996

April 1, 1996 to May 31, 1996

May 1, 1996 to April 30, 1997

or indirectly employing, accepting assistance from, being employed by or

sharing fees with, any practitioner

disbarred or under suspension from

practice before the Internal Revenue

Service.

To enable attorneys, certified public

accountants, enrolled agents and

enrolled actuaries to identify such

disbarred or suspended practitioners,

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 the date

of disbarment or period of suspension.

This announcement will appear in the

weekly Bulletin for five successive

weeks or as long as it is practicable for

each attorney, certified public accountant, enrolled agent or enrolled actuary

so suspended or disbarred and will be

consolidated and published in the

Cumulative Bulletin.

After due notice and opportunity

for hearing before an administrative

law judge, the following individuals

have been disbarred from further practice before the Internal Revenue

Service:

SEQ 0019 JOB C48-008-003 PAGE-0019 ANN DIS

REVISED 30JUN96 AT 22:15 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-008

Name

Address

Designation

Effective Date

Gimbel, Stephen

Tropsa, Donna C.

Seifert, Frank J.

Hansen, Joe B.

Columbia, SC

Stamford, CT

Birmingham, AL

Lubbock, TX

CPA

Attorney

CPA

January 20, 1996

March 2, 1996

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, 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

Ginsberg, Melvin R.

Lahey, Charles W.

DePiano, Robert

Kraig, Jerry B.

Brown, David M.

Hanke Jr., Dale L.

Guillory, Patrick R.

Miller, Brian R.

McLeod, Timothy R.

Simone, Robert F.

Bowen, David Lee

Lindley, Clarkson

Univ. Heights, OH

South Bend, IN

Venice, CA

Shaker Hgts, OH

Los Angeles, CA

Duluth, MN

San Francisco, CA

Grove, OK

Saginaw, MI

Philadelphia, PA

Frisco City, AL

Wayazata, MN

Attorney

CPA

Attorney

CPA

Attorney

Indefinite from January 24, 1996

Indefinite from January 29, 1996

Indefinite from February 1, 1996

Indefinite from February 23, 1996

Indefinite from February 26, 1996

Indefinite from February 27, 1996

SEQ 0020 JOB C48-051-002 PAGE-0020 TERMS

REVISED 30JUN96 AT 22:15 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/30JUN96/C48-051

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.

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 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.

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.

SEQ 0021 JOB C48-053-006 PAGE-0021 NEW FINDING LIST

REVISED 30JUN96 AT 22:15 BY LR DEPTH: 65.01 PICAS WIDTH 40.11 PICAS

COMPOSITE COLOR

778/20054/30JUN96/C48-053

Numerical Finding List1

Bulletins 1996–1 through 1996–14

Announcements:

96–1, 1996–2 I.R.B. 57

96–2, 1996–2 I.R.B. 57

96–3, 1996–2 I.R.B. 57

96–4, 1996–3 I.R.B. 50

96–5, 1996–4 I.R.B. 99

96–6, 1996–5 I.R.B. 43

96–7, 1996–5 I.R.B. 44

96–8, 1996–7 I.R.B. 56

96–9, 1996–8 I.R.B. 30

96–10, 1996–8 I.R.B. 30

96–11, 1996–9 I.R.B. 11

96–12, 1996–11 I.R.B. 30

96–13, 1996–12 I.R.B. 33

96–14, 1996–12 I.R.B. 35

96–15, 1996–11 I.R.B. 9

96–16, 1996–11 I.R.B. 4

96–17, 1996–13 I.R.B. 5

96–18, 1996–13 I.R.B. 4

Delegations Orders:

232 (Rev. 2), 1996–7 I.R.B. 49

239 (Rev. 1), 1996–7 I.R.B. 49

Notices:

96–2, 1996–2 I.R.B. 15

96–1, 1996–3 I.R.B. 30

96–4, 1996–4 I.R.B. 69

96–5, 1996–6 I.R.B. 22

96–6, 1996–5 I.R.B. 27

96–7, 1996–6 I.R.B. 22

96–8, 1996–6 I.R.B. 23

96–9, 1996–6 I.R.B. 26

96–10, 1996–7 I.R.B. 47

96–11, 1996–8 I.R.B. 19

96–12, 1996–10 I.R.B. 29

96–13, 1996–10 I.R.B. 29

96–14, 1996–12 I.R.B. 11

96–15, 1996–13 I.R.B. 19

96–16, 1996–13 I.R.B. 20

96–17, 1996–13 I.R.B. 20

96–18, 1996–14 I.R.B. 27

96–19, 1996–14 I.R.B. 28

96–20, 1996–14 I.R.B. 30

96–21, 1996–14 I.R.B. 30

96–22, 1996–14 I.R.B. 30

Proposed Regulations:

DL–1–95, 1996–6 I.R.B. 28

EE–20–95, 1996–5 I.R.B. 15

EE–34–95, 1996–3 I.R.B. 49

EE–35–95, 1996–5 I.R.B. 19

EE–53–95, 1996–5 I.R.B. 23

Proposed Regulations—Continued

Revenue Rulings—Continued

EE–55–95, 1996–12 I.R.B. 12

EE–106–82, 1996–10 I.R.B. 31

EE–142–87, 1996–12 I.R.B. 13

EE–148–81, 1996–11 I.R.B. 29

IA–33–95, 1996–4 I.R.B. 99

IA–41–93, 1996–11 I.R.B. 29

INTL–3–95, 1996–6 I.R.B. 29

INTL–9–95, 1996–5 I.R.B. 25

INTL–54–95, 1996–14 I.R.B. 39

PS–2–95, 1996–7 I.R.B. 50

96–14, 1996–6 I.R.B. 20

96–15, 1996–11 I.R.B. 9

96–16, 1996–11 I.R.B. 4

96–17, 1996–13 I.R.B. 5

96–18, 1996–13 I.R.B. 4

96–19, 1996–14 I.R.B. 24

Revenue Procedures:

96–1, 1996–1 I.R.B. 8

96–2, 1996–1 I.R.B. 60

96–3, 1996–1 I.R.B. 82

96–4, 1996–1 I.R.B. 94

96–5, 1996–1 I.R.B. 129

96–6, 1996–1 I.R.B. 151

96–7, 1996–1 I.R.B. 185

96–8, 1996–1 I.R.B. 187

96–8A, 1996–9 I.R.B. 10

96–9, 1996–2 I.R.B. 15

96–10, 1996–2 I.R.B. 17

96–11, 1996–2 I.R.B. 18

96–12, 1996–3 I.R.B. 30

96–13, 1996–3 I.R.B. 31

96–14, 1996–3 I.R.B. 41

96–15, 1996–3 I.R.B. 41

96–16, 1996–3 I.R.B. 45

96–17, 1996–4 I.R.B. 69

96–18, 1996–4 I.R.B. 73

96–19, 1996–4 I.R.B. 80

96–20, 1996–4 I.R.B. 88

96–21, 1996–4 I.R.B. 96

96–22, 1996–5 I.R.B. 27

96–23, 1996–5 I.R.B. 27

96–24, 1996–5 I.R.B. 28

96–25, 1996–8 I.R.B. 19

96–26, 1996–8 I.R.B. 22

96–27, 1996–11 I.R.B. 27

96–28, 1996–14 I.R.B. 31

Revenue Rulings:

96–1, 1996–1 I.R.B. 7

96–2, 1996–2 I.R.B. 5

96–3, 1996–2 I.R.B. 14

96–6, 1996–2 I.R.B. 8

96–4, 1996–3 I.R.B. 16

96–5, 1996–3 I.R.B. 29

96–7, 1996–3 I.R.B. 12

96–8, 1996–4 I.R.B. 62

96–9, 1996–4 I.R.B. 5

96–10, 1996–4 I.R.B. 27

96–11, 1996–4 I.R.B. 28

96–12, 1996–9 I.R.B. 4

96–13, 1996–10 I.R.B. 19

cumulative list of all Revenue Rulings,

Revenue Procedures, Treasury Decisions, etc.,

published in Internal Revenue Bulletins 1995–27

through 1995–52 will be found in Internal

Revenue Bulletin 1996–1, dated January 2, 1996.

Treasury Decisions:

8630, 1996–3 I.R.B. 19

8631, 1996–3 I.R.B. 7

8632, 1996–4 I.R.B. 6

8633, 1996–4 I.R.B. 20

8634, 1996–3 I.R.B. 17

8635, 1996–3 I.R.B. 5

8636, 1996–4 I.R.B. 64

8637, 1996–4 I.R.B. 29

8638, 1996–5 I.R.B. 5

8639, 1996–5 I.R.B. 12

8640, 1996–2 I.R.B. 10

8641, 1996–6 I.R.B. 4

8642, 1996–7 I.R.B. 4

8643, 1996–11 I.R.B. 4

8644, 1996–7 I.R.B. 16

8645, 1996–8 I.R.B. 4

8646, 1996–8 I.R.B. 10

8647, 1996–9 I.R.B. 7

8648, 1996–10 I.R.B. 23

8649, 1996–9 I.R.B. 5

8650, 1996–10 I.R.B. 5

8651, 1996–11 I.R.B. 24

8652, 1996–11 I.R.B. 11

8653, 1996–12 I.R.B. 4

8654, 1996–11 I.R.B. 14

8655, 1996–12 I.R.B. 9

8656, 1996–13 I.R.B. 9

8657, 1996–14 I.R.B. 4

8658, 1996–14 I.R.B. 13

SEQ 0022 JOB C48-053-006 PAGE-0022 NEW FINDING LIST

REVISED 30JUN96 AT 22:15 BY LR DEPTH: 65.01 PICAS WIDTH 41.11 PICAS

COMPOSITE COLOR

778/20054/30JUN96/C48-053

Finding List of Current Action on

Previously Published Items1

Bulletins 1996–1 through 1996–14

*Denotes entry since last publication

Delegation Orders:

232 (Rev. 1)

Superseded by

232 (Rev. 2), 1996–7 I.R.B. 49

239

Amended by

239 (Rev. 1), 1996–7 I.R.B. 49

Revenue Procedures:

65–17

Modified by

96–14, 1996–3 I.R.B. 41

66–49

Modified by

96–15, 1996–3 I.R.B. 41

Revenue Procedures—Continued

92–85

Modified by

96–1, 1996–1 I.R.B. 8

95–13

Superseded by

96–20, 1996–4 I.R.B. 88

93–16

Superseded by

96–11, 1996–2 I.R.B. 18

95–20

Superseded by

96–24, 1996–5 I.R.B. 28

93–46

Superseded in part by

96–17, 1996–4 I.R.B. 69

Superseded by

96–18, 1996–4 I.R.B. 73

94–18

Superseded in part by

96–17, 1996–4 I.R.B. 69

Superseded by

96–18, 1996–4 I.R.B. 73

94–59

Superseded in part by

96–17, 1996–4 I.R.B. 69

88–32

Obsoleted by

96–15, 1996–3 I.R.B. 41

Superseded by

96–18, 1996–4 I.R.B. 73

88–33

Obsoleted by

96–15, 1996–3 I.R.B. 41

94–77

Superseded by

96–28, 1996–14 I.R.B. 31

89–19

Superseded by

96–17, 1996–4 I.R.B. 69

95–1

Superseded by

96–1, 1996–1 I.R.B. 8

89–48

Superseded in part by

96–17, 1996–4 I.R.B. 69

95–2

Superseded by

96–2, 1996–1 I.R.B. 60

91–22

Modified by

96–1, 1996–1 I.R.B. 8

95–3

Superseded by

96–3, 1996–1 I.R.B. 82

91–22

Amplified by

96–13, 1996–3 I.R.B. 31

95–4

Superseded by

96–4, 1996–1 I.R.B. 94

91–23

Superseded by

96–13, 1996–3 I.R.B. 31

95–5

Superseded by

96–5, 1996–1 I.R.B. 129

91–24

Superseded by

96–14, 1996–3 I.R.B. 41

95–6

Superseded by

96–6, 1996–1 I.R.B. 151

91–26

Superseded by

96–13, 1996–3 I.R.B. 31

95–7

Superseded by

96–7, 1996–1 I.R.B. 185

92–20

Modified by

96–1, 1996–1 I.R.B. 8

95–8

Superseded by

96–8, 1996–1 I.R.B. 187

1A cumulative finding list for previously

published items mentioned in Internal Revenue

Bulletins 1995–27 through 1995–52 will be

found in Internal Revenue Bulletin 1996–1, dated

January 2, 1996.

95–50

Superseded by

96–3, 1996–1 I.R.B. 82

96–3

Amplified by

96–12, 1996–3 I.R.B. 30

Revenue Rulings:

66–307

Obsoleted by

96–3, 1996–2 I.R.B. 14

72–437

Modified by

96–13, 1996–3 I.R.B. 31

80–80

Obsoleted by

96–3, 1996–2 I.R.B. 14

82–80

Modified by

96–14, 1996–3 I.R.B. 41

92–19

Supplemented in part

96–2, 1996–2 I.R.B. 5

92–75

Clarified by

96–13, 1996–3 I.R.B. 31

95–10

Supplemented and superseded by

96–4, 1996–3 I.R.B. 16

95–11

Supplemented and superseded by

96–5, 1996–3 I.R.B. 29

SEQ 0023 JOB C48-053-006 PAGE-0023 NEW FINDING LIST

REVISED 30JUN96 AT 22:15 BY LR DEPTH: 65.01 PICAS WIDTH 32.10 PICAS

COMPOSITE COLOR

778/20054/30JUN96/C48-053

NOTES

SEQ 0024 JOB C48-053-006 PAGE-0024 NEW FINDING LIST

REVISED 30JUN96 AT 22:15 BY LR DEPTH: 65.01 PICAS WIDTH 32.10 PICAS

COMPOSITE COLOR

778/20054/30JUN96/C48-053

NOTES

SEQ 0025 JOB C48-053-006 PAGE-0025 NEW FINDING LIST

REVISED 30JUN96 AT 22:15 BY LR DEPTH: 65.01 PICAS WIDTH 32.10 PICAS

COMPOSITE COLOR

778/20054/30JUN96/C48-053

NOTES

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.