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Bulletin No. 1996–9

February 26, 1996

HIGHLIGHTS

OF THIS ISSUE

These synopses are intended only as aids to the reader in

identifying the subject matter covered. They may not be

relied upon as authoritative interpretations.

INCOME TAX

T.D. 8649, page 5.

Final regulations under section 1258 of the Code

relating to conversion transactions.

Rev. Rul. 96–12, page 4.

LIFO; price indexes; department stores. The December

1995 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, December 31, 1995.

EMPLOYEE PLANS

Rev. Proc. 96–8A, page 10.

User fees. Corrections are made to Rev. Proc. 96–8,

1996–1 I.R.B. 187, concerning user fees.

ADMINISTRATIVE

T.D. 8647, page 7.

Final regulations under section 1445 of the Code

relating to withholding upon certain distributions or

dispositions of U.S. real property interests.

Announcement 96–11, page 11.

Supplemental information on Treasury bills for Publication 1212, List of Original Issue Discount Instruments

(Rev. Nov. 95), is given.

Finding Lists begin on page 15.

Announcement of Disbarments and Suspensions begin on page 12.

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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.

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Introduction

The Internal Revenue Bulletin is the authoritative

instrument of the Commissioner of Internal Revenue for

announcing official rulings and procedures of the

Internal Revenue Service and for publishing Treasury

Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general

interest. It is published weekly and may be obtained

from the Superintendent of Documents on a subscription basis. Bulletin contents of a permanent nature are

consolidated semiannually into Cumulative Bulletins,

which are sold on a single-copy basis.

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 Miscellanous.

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.

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

§ 472.—Last-in, First-out Inventories

Rev. Rul. 96–12

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

The following Department Store Inventory Price Indexes for December

1995 were issued by the Bureau of

Labor Statistics on February 1, 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 last-

LIFO; price indexes; department

stores. The December 1995 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, December 31,

1995.

in, first-out inventory methods for tax

years ended on, or with reference to,

December 31, 1995.

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

(January 1941 = 100, unless otherwise noted)

Groups

Dec. 1994

Dec. 1995

Percent Change from

Dec. 1994 to Dec. 19951

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

483.5

630.5

630.9

907.3

620.9

521.9

280.4

560.6

413.9

603.0

558.6

472.4

979.4

720.8

854.2

637.3

564.2

776.3

249.4

83.9

114.5

122.0

106.6

532.6

633.5

625.6

891.0

635.6

521.6

290.2

559.9

407.1

602.1

561.6

481.8

978.1

773.6

870.8

669.0

564.5

782.3

246.1

79.1

112.8

123.7

107.5

10.2

0.5

–0.8

–1.8

2.4

–0.1

3.5

–0.1

–1.6

–0.1

0.5

2.0

–0.1

7.3

1.9

5.0

0.1

0.8

–1.3

–5.7

–1.5

1.4

0.8

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

584.4

585.1

0.1

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

463.4

462.2

–0.3

Goods2. . . . . . . . . . . . . . . .

114.1

113.3

–0.7

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

544.0

543.7

–0.1

Groups 21–23: Misc.

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

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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 1258.—Recharacterization of

Gain from Certain Financial

Transactions

26 CFR 1.1258–1: Netting rule for certain

conversion transactions.

T.D. 8649

DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Parts 1 and 602

Regulations Under Section 1258 of

the Internal Revenue Code of 1986;

Netting Rule For Certain Conversion

Transactions

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Final regulations.

SUMMARY: This document contains

final regulations relating to conversion

transactions. These regulations provide

that certain gains and losses from

positions of the same conversion transaction may be netted for purposes of

determining the amount of gain that is

recharacterized as ordinary income.

These regulations reflect changes to the

law made by the Revenue Reconciliation Act of 1993 and affect persons

who enter into conversion transactions.

DATE: These regulations are effective

December 21, 1995.

For applicability of these regulations,

see EFFECTIVE DATES under the

SUPPLEMENTARY INFORMATION

part of the preamble.

FOR FURTHER INFORMATION

CONTACT: Alan B. Munro, (202)

622-3950 (not a toll-free number).

been reviewed and approved by the

Office of Management and Budget in

accordance with the Paperwork Reduction Act (44 U.S.C. 3507) under

control number 1545–1452. Responses

to this collection of information are

required to obtain netting relief for

conversion transactions.

An agency may not conduct or

sponsor, and a person is not required to

respond to, a collection of information

unless the collection of information

displays a valid control number.

The estimated annual burden per

recordkeeper varies from .05 to 10

hours, depending on individual circumstances, with an estimated average of

.10 hour.

Comments concerning the accuracy

of this burden estimate and suggestions

for reducing this burden should be sent

to the Internal Revenue Service, Attn:

IRS Reports Clearance Officer, T:FP,

Washington, DC 20224, and to the

Office of Management and Budget,

Attn: Desk Officer for the Department

of the Treasury, Office of Information

and Regulatory Affairs, Washington,

DC 20503.

Books or records relating to this

collection of information must be retained as long as their contents may

become material in the administration

of any internal revenue law. Generally,

tax returns and tax return information

are confidential, as required by 26

U.S.C. 6103.

Background

On December 27, 1994, the IRS

published in the Federal Register a

notice of proposed rulemaking and

notice of public hearing at 59 FR

66498 (FI–43–94 [1995–1 C.B. 932])

under section 1258 of the Internal

Revenue Code of 1986.

The IRS received a number of

written comments on the proposed

regulations. No requests to speak at the

public hearing were received, however,

and consequently the hearing was

cancelled.

Explanation of Provisions

A. General

SUPPLEMENTARY INFORMATION:

Paperwork Reduction Act

The collection of information contained in these final regulations has

The proposed regulations allow taxpayers to net gains and losses on the

positions of certain conversion transactions for purposes of section 1258(a).

For a taxpayer to be eligible, the

proposed regulations require the taxpayer to identify, before the close of

the day on which the positions become

part of the conversion transaction, all

the positions that are part of the

conversion transaction. In addition, the

taxpayer has to dispose of all the

positions within a 14-day period that is

within a single taxable year. The

proposed regulations also define builtin loss and prohibit the netting of builtin loss against gain.

The commenters uniformly supported

the netting relief provided by the

proposed regulations. Accordingly, the

final regulations are substantially unchanged from the proposed regulations.

The proposed regulations provide

that the regulations will be effective for

conversion transactions entered into on

or after the date of filing of final

regulations with the Federal Register.

Several commenters requested that the

regulations also apply to conversion

transactions entered into prior to the

filing date. In response to these comments, the final regulations provide for

application of the regulations to any

conversion transaction that is outstanding on December 21, 1995, provided

that all the positions which are part of

the conversion transaction are identified

under §1.1258–1(b)(2) before the close

of business on February 20, 1996. The

final regulations also provide a transition rule for the same-day identification

requirement that allows taxpayers to

identify conversion transactions entered

into prior to February 20, 1996, at any

time on or before February 20, 1996.

Several commenters criticized the

examples for failing to adjust the

applicable imputed income amount

(AIIA) under section 1258(b) for interest and dividends received. The scope

of these regulations, however, is limited to netting relief. The IRS is still

studying various situations to determine

the extent to which it is appropriate to

reduce the AIIA by reason of amounts

capitalized under section 263(g), ordinary income received, or otherwise.

Accordingly, Example 3 has been deleted and Examples 1 and 2 have been

clarified to eliminate any implication

on this issue.

One commenter requested that the

identification requirement be eliminated

as impractical, unnecessary, and a trap

for the unwary. This same-day identification requirement is similar to identification requirements under sections

475 and 1221. Identification of all the

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positions of a conversion transaction

will aid examiners attempting to determine whether conversion transactions

are present and will prevent mismatching of those positions by both taxpayers and agents. The final regulations

retain the same-day identification requirement but provide a transition rule.

Some commenters asked that netting

relief be expanded to cover unrealized

losses in retained positions by allowing

loss positions to be marked to market

when a gain position is disposed of or

terminated. Allowing retained positions

to be marked to market raises valuation

and other potentially complex issues.

For example, many of the issues addressed by the regulations under section 475 would have to be addressed

here. The complexity of these issues

outweighs the potential benefit of allowing retained positions to be marked

to market. Thus, the final regulations

do not include a mark-to-market

provision.

To preserve the character of gain that

arose before a position became part of

a conversion transaction, one commenter requested built-in gain rules similar

to the built-in loss rules in the proposed regulations. The appropriateness

of a built-in gain rule under section

1258 is beyond the scope of these

regulations. Therefore, the final regulations do not address this issue.

The IRS is aware that section 1258

presents a number of issues not addressed by these final regulations. The

IRS continues to study the scope of

section 1258, the types of transactions

that should be included under the

regulatory authority of section

1258(c)(2)(D), and what reductions, if

any, in the AIIA are appropriate under

section 1258(b). The IRS welcomes

comments on these and other issues

under section 1258.

B. Effective Dates

The regulations are effective for

conversion transactions that are outstanding on or after December 21,

1995. In the case of a conversion

transaction entered into before February

20, 1996, the same-day identification

requirement is treated as satisfied if the

identification is made on or before

February 20, 1996.

Special Analyses

It has been determined that this

Treasury decision is not a significant

regulatory action as defined in EO

12866. Therefore, a regulatory assessment is not required. It also has been

determined that section 553(b) of the

Administrative Procedure Act (5 U.S.C.

chapter 5) and the Regulatory Flexibility Act (5 U.S.C. chapter 6) do not

apply to these regulations, and, therefore, a Regulatory Flexibility Analysis

is not required. Pursuant to section

7805(f) of the Internal Revenue Code,

the notice of proposed rulemaking preceding these regulations was submitted

to the Small Business Administration

for comment on its impact on small

business.

Drafting Information

The principal author of these regulations is Alan B. Munro, Office of

Assistant Chief Counsel (Financial Institutions and Products). However,

other personnel from the IRS and

Treasury Department participated in

their development.

Adoption of Amendments to the

Regulations

Accordingly, 26 CFR parts 1 and

602 are amended as follows:

PART 1—INCOME TAXES

Paragraph 1. The authority citation

for part 1 continues to read in part as

follows:

Authority: 26 U.S.C. 7805 * * *

Par. 2. Section 1.1258–1 is added to

read as follows:

§1.1258–1 Netting rule for certain

conversion transactions.

(a) Purpose. The purpose of this

section is to provide taxpayers with a

method to net certain gains and losses

from positions of the same conversion

transaction before determining the

amount of gain treated as ordinary

income under section 1258(a).

(b) Netting of gain and loss for

identified transactions—(1) In general.

If a taxpayer disposes of or terminates

all the positions of an identified netting

transaction (as defined in paragraph

(b)(2) of this section) within a 14-day

period in a single taxable year, all

gains and losses on those positions

taken into account for federal tax

purposes within that period (other than

built-in losses as defined in paragraph

purposes of determining the amount of

gain treated as ordinary income under

section 1258(a). For purposes of the

preceding sentence, a taxpayer is

treated as disposing of any position that

is treated as sold under any provision

of the Code or regulations thereunder

(for example, under section 1256(a)(1)).

(2) Identified netting transaction.

For purposes of this section, an identified netting transaction is a conversion

transaction (as defined in section

1258(c)) that the taxpayer identifies as

an identified netting transaction on its

books and records. Identification of

each position of the conversion transaction must be made before the close of

the day on which the position becomes

part of the conversion transaction. No

particular form of identification is

necessary, but all the positions of a

single conversion transaction must be

identified as part of the same transaction and must be distinguished from all

other positions.

purposes of this section, built-in loss

means—

(1) Built-in loss as defined in section 1258(d)(3)(B); and

(2) If a taxpayer realizes gain or loss

on any one position of a conversion

transaction (for example, under section

1256), as of the date that gain or loss is

realized, any unrecognized loss in any

other position of the conversion transaction that is not disposed of, terminated, or treated as sold under any

provision of the Code or regulations

thereunder within 14 days of and

within the same taxable year as the

realization event.

(d) Examples. These examples illustrate this section:

Example 1. Identified netting transaction with

simultaneous actual dispositions. (i) On December 1, 1995, A purchases 1,000 shares of XYZ

stock for $100,000 and enters into a forward

contract to sell 1,000 shares of XYZ stock on

November 30, 1997, for $110,000. The XYZ

stock is actively traded as defined in §1.1092(d)–

1(a) and is a capital asset in A’s hands. A

maintains books and records on which, on

December 1, 1995, it identifies the two positions

as all the positions of a single conversion

transaction. A owns no other XYZ stock. On

December 1, 1996, when the applicable imputed

income amount for the transaction is $7,000, A

sells the 1,000 shares of XYZ stock for $95,000.

On the same day, A terminates its forward

contract with its counterparty, receiving $10,200.

No dividends were received on the stock during

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the time it was part of the conversion

transaction.

(ii) The XYZ stock and forward contract are

positions of a conversion transaction. Under

section 1258(c)(1), substantially all of A’s

expected return from the overall transaction is

attributable to the time value of the net

investment in the transaction. Under section

1258(c)(2)(B), the transaction is an applicable

straddle as defined in section 1258(d)(1).

(iii) A disposed of or terminated all the

positions of the conversion transaction within 14

days and within the same taxable year as required by paragraph (b)(1) of this section. The

transaction is an identified netting transaction

because it meets the identification requirement of

paragraph (b)(2) of this section. Solely for

purposes of section 1258(a), the $5,000 loss

realized ($100,000 basis less $95,000 amount

realized) on the disposition of the XYZ stock is

netted against the $10,200 gain recognized on the

disposition of the forward contract. Thus, the net

gain from the conversion transaction for purposes

of section 1258(a) is $5,200 ($10,200 gain less

$5,000 loss). Only the $5,200 net gain is recharacterized as ordinary income under section

1258(a) even though the applicable imputed

income amount is $7,000. For federal tax

purposes other than section 1258(a), A has

recognized a $10,200 gain on the disposition of

the forward contract ($5,200 of which is treated

as ordinary income) and realized a separate

$5,000 loss on the sale of the XYZ stock.

Example 2. Identified netting transaction with

built-in loss. (i) The facts are the same as in

Example 1, except that A had purchased the XYZ

stock for $104,000 on May 15, 1995. The XYZ

stock had a fair market value of $100,000 on

December 1, 1995, the date it became part of a

conversion transaction.

(ii) The results are the same as in Example 1,

except that A has built-in loss (in addition to the

$5,000 loss that arose economically during the

period of the conversion transaction), as defined

in section 1258(d)(3)(B), of $4,000 on the XYZ

stock. That $4,000 built-in loss is not netted

against the $10,200 gain on the forward contract

for purposes of section 1258(a). Thus, the net

gain from the conversion transaction for purposes

of section 1258(a) is $5,200, the same as in

Example 1. The $4,000 built-in loss is recognized and has a character determined without

regard to section 1258.

(e) Effective date and transition

rule—(1) In general. These regulations

are effective for conversion transactions

that are outstanding on or after December 21, 1995.

(2) Transition rule for identification

requirements. In the case of a conversion transaction entered into before

February 20, 1996, paragraph (b)(2) of

this section is treated as satisfied if the

identification is made before the close

of business on February 20, 1996.

PART 602—OMB CONTROL

NUMBERS UNDER THE

PAPERWORK REDUCTION ACT

Par. 3. The authority citation for part

602 continues to read as follows:

Authority: 26 U.S.C. 7805.

§602.101 [Amended]

Par. 4. In §602.101, paragraph (c) is

amended by adding the entry ‘‘1.1258–

1 . . . . 1545–1452’’ in numerical order

to the table.

Margaret Milner Richardson,

Commissioner of

Internal Revenue.

Approved November 28, 1995.

Leslie Samuels,

Assistant Secretary of

the Treasury.

(Filed by the Office of the Federal Register on

December 20, 1995, 8:45 a.m., and published

in the issue of the Federal Register for

December 21, 1995, 60 F.R. 66083)

Section 1445.—Withholding of Tax

on Dispositions of United States Real

Property Interests

26 CFR 1.1445–1: Withholding on dispositions

of U.S. real property interests by foreign

persons; in general.

T.D. 8647

DEPARTMENT OF TREASURY

Internal Revenue Service

26 CFR Part 1

Withholding of Tax on Dispositions of

U.S. Real Property Interests by

Foreign Persons.

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Final regulations.

SUMMARY: This document contains

final regulations relating to withholding

upon certain distributions or dispositions of U.S. real property interests.

These regulations reflect changes to the

law made by the Omnibus Budget Reconciliation Act of 1993 and affect

withholding agents required to withhold

tax due on certain dispositions and

distributions of U.S. real property

interests.

DATES: These final regulations are

effective January 22, 1996. These

regulations are applicable to transactions occurring after August 9, 1993.

FOR FURTHER INFORMATION

CONTACT: Gwendolyn A. Stanley

(202) 622-3860 (not a toll free-call).

SUPPLEMENTARY INFORMATION:

Background

This document contains final regulations reflecting changes made by the

Omnibus Budget Reconciliation Act of

1993 to the withholding rates on

certain distributions and dispositions of

U.S. real property interests. These

regulations were not preceded by a

Notice of Proposed Rulemaking because the withholding rates were

changed by the Act. This document

also updates the address of the Assistant Commissioner (International) to

whom various forms must be sent.

Explanation of Provisions

The rate of withholding under section 1445(e)(1) and (2) of the Internal

Revenue Code was increased from 34%

to 35% by the Omnibus Budget Reconciliation Act of 1993. The existing

regulations reflect the prior 34% withholding rate. These regulations reflect

the increase in withholding to 35% (or

the highest rate specified in section

1445(e)(1) or (2)) for dispositions

occurring on or after August 10, 1993.

Special Analyses

It has been determined that this

Treasury decision is not a significant

regulatory action as defined in EO

12866. Therefore, a regulatory assessment is not required. It has also been

determined that section 553(b) of the

Administrative Procedure Act (5 U.S.C.

chapter 5) and the Regulatory Flexibility

Act (5 U.S.C. chapter 6) do not apply to

these regulations, and, therefore, a Regulatory Flexibility Analysis is not required. Pursuant to section 7805(f) of

the Internal Revenue Code, these final

regulations were submitted to the Small

Business Administration for comment

on their impact on small business.

Drafting Information

The principal author of these regulations is Gwendolyn Stanley, Office of

Associate Chief Counsel (International), IRS. However, other personnel

from the IRS and Treasury Department

participated in their development.

* * * * * *

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Adoption of Amendments to the

Regulations

Accordingly, 26 CFR part 1 is

amended as follows:

PART 1—INCOME TAXES

Paragraph 1. The authority citation

for part 1 continues to read in part as

follows:

Authority: 26 U.S.C. 7805. * * *

Section 1.1445–5 also issued under

26 U.S.C. 1445(e)(6).

Section 1.1445–8 also issued under

26 U.S.C. 1445(e)(6). * * *

Par. 2. In section 1.1445–1, the

section heading and paragraph (g)(10)

are revised to read as follows:

§1.1445–1 Withholding on

dispositions of U.S. real property

interests by foreign persons: In

general.

(g) * * *

(10) Address of the Assistant Commissioner International. Any written

communication directed to the Assistant Commissioner (International) is to

be addressed as follows: Director,

Philadelphia Service Center; 11601

Roosevelt Blvd.; Philadelphia, PA

19255; ATTN: Drop Point 543X.

Par. 3. Section 1.1445–5 is amended

as follows:

1. Paragraph (c)(1)(ii) is revised.

2. The third sentence and the last

sentence of paragraph (c)(1)(iii)(A) are

revised.

3. Paragraph (c)(1)(iii)(B) is

removed.

4. Paragraph (c)(1)(iii)(C) is redesignated as (c)(1)(iii)(B) and revised.

5. Paragraph (c)(1)(iv) is revised.

6. Paragraph (c)(3)(ii) is revised.

7. The first sentence of paragraph

(d)(1) is revised.

8. The second sentence of paragraph

(d)(1) is removed.

The revisions read as follows:

§1.1445–5 Special rules concerning

distributions and other transactions

by corporations, partnerships, trusts,

and estates.

(c)(1) * * *

(ii) Disposition by partnership. A

partnership must withhold a tax equal

to 35 percent (or the highest rate

specified in section 1445(e)(1)) of each

foreign partner’s distributive share of

the gain realized by the partnership

upon the disposition of each U.S. real

property interest. Such distributive

share of the gain must be determined

pursuant to the principles of section

704 and the regulations thereunder. For

the rules applicable to partnerships,

interests in which are regularly traded

on an established securities market, see

§1.1445–8.

(iii) Disposition by trust or estate—

(A) In general. * * * The fiduciary

must withhold 35 percent (or the

highest rate specified in section

1445(e)(1)) of any distribution to a

foreign beneficiary that is attributable

to the balance in the U.S. real property

interest account on the day of the

distribution. * * * For rules applicable

to trusts, interests in which are regularly traded on an established securities market and real estate investment trusts, see §1.1445–8.

(B) Example. The following example

illustrates the rules of paragraph

(c)(1)(iii)(A) of this section.

On January 1, 1994, A establishes a domestic

trust (which has as its taxable year, the calendar

year) for the benefit of B, a nonresident alien,

and C, a U.S. citizen. The trust is not a trust

subject to sections 671 through 679. Under the

terms of the trust, the trustee, T, is given

discretion to distribute income and corpus of the

trust to provide for the reasonable needs of B

and C. During the trust’s 1994 tax year, T disposes of three parcels of vacant land located in

the United States. The following chart illustrates

the computation of the amount subject to withholding under section 1445 with respect to

distributions made by T to B and C during 1994.

Section 1445

withholding

35% rate

U.S. real

property

interest

account

1/01/94 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3/01/94 . . . . . . . . . . . . . . . . . .

Parcel 1

140,000

3/05/94 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

5,000

10,000

3,500

3/15/94 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

10,000

5,000

1,750

5/01/94 . . . . . . . . . . . . . . . . . .

Parcel 2

300,000

5/15/94 . . . . . . . . . . . . . . . . . .

Parcel 3

(50,000)

12/01/94 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

170,000

59,500

1/01/95 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

-0140,000

125,000

110,000

410,000

360,000

20,000

-0-

Date

Parcel sold

(iv) Disposition by grantor trust. The

trustee or equivalent fiduciary of a trust

that is subject to the provisions of

subpart E of part I of subchapter J

(sections 671 through 679) must withhold a tax equal to 35 percent (or the

highest rate specified in section

1445(e)(1)) of the gain realized from

each disposition of a U.S. real property

interest to the extent such gain is allocable to a portion of the trust treated

Gains or

(loss) realized

Distributions

to C

as owned by a foreign person under

subpart E of part I of subchapter J.

(3) * * *

(ii) Amount to be withheld. A partnership or trust electing to withhold

under this §1.1445–5(c)(3) shall withhold from each distribution to a foreign

person an amount equal to 35 percent

(or the highest rate specified in section

Distributions

to B (before

withholding)

1445(e)(1)) of the amount attributable

to section 1445(e)(1) transfers.

(d) Distributions of U.S. real property interests by foreign corporations—

(1) In general. A foreign corporation

that distributes a U.S. real property

interest must deduct and withhold a tax

equal to 35 percent (or the rate

specified in section 1445(e)(2)) of the

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amount of gain recognized by the

corporation on the distribution. * * *

Par. 4. Section 1.1445–8(c)(2)(i) is

revised to read as follows:

§ 1.1445–8 Special rules regarding

publicly traded partnerships, publicly

traded trusts and real estate

investment trusts (REITS).

(2) REITS—(i) In general. The

amount to be withheld with respect to a

distribution by a REIT, under this

section shall be equal to 35 percent (or

the highest rate specified in section

1445(e)(1)) of the amount described in

paragraph (c)(2)(ii) of this section.

Margaret Milner Richardson,

Commissioner of

Internal Revenue.

Approved November 28, 1995.

Leslie Samuels,

Assistant Secretary of

the Treasury.

(Filed by the Office of the Federal Register on

December 20, 1995, 8:45 a.m., and published

in the issue of the Federal Register for

December 21, 1995, 60 F.R. 66076)

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Part III. Administrative, Procedural, and Miscellaneous

Rev. Proc. 96–8A

26 CFR 601.201: Rulings and determination

letters.

SECTION 1. PURPOSE

The purpose of this revenue procedure is to correct errors in Rev. Proc.

96–8, 1996–1 I.R.B. 187, relating to

user fees. These corrections will be

incorporated into Rev. Proc. 96–8 when

it is published in the first cumulative

bulletin of 1996.

SECTION 2. CORRECTIONS TO

REV. PROC. 96–8

.01 Section 6.04(5) is corrected to read:

Nonmass submission

(new or amended) by M

& P sponsoring organization, per adoption agreement

$3,000

.02 Paragraphs (4), (5), and

(6) of section 6.05, and

paragraphs (6) and (7) of

section 6.06, are corrected to state that the

fee, in each case, is $400.

.03 Paragraph 6.08(1)(a) is

corrected to state that the

fee is $500.

SECTION 3. EFFECT ON OTHER

DOCUMENTS

Rev. Proc. 96–8 is modified.

SECTION 4. EFFECTIVE DATE

This revenue procedure is effective

January 2, 1996.

DRAFTING INFORMATION

The principal author of this revenue

procedure is John Turner of the

Employee Plans Division. For further

information regarding this revenue procedure, please contact Mr. Turner on

(202) 622-6214. (This is not a toll-free

number.)

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Part IV. Items of General Interest

Supplemental Information on Treasury

Bills for Publication 1212

Announcement 96–11

Banks, brokers, and other middlemen

who report discount on Treasury bill

redemptions on Form 1099–INT must

use the owner’s purchase price, where

available, to determine the amount of

discount to report. This information can

usually be obtained from the owner’s

or middleman’s records. However, if

the owner’s purchase price is not

available from existing records, the

middleman must report the discount as

if the holder had purchased the Treasury bill at its original issue price. In

this case, the middleman must use as

the original issue price the noncompetitive issue price for the longest-maturity

Treasury bill maturing on that date.

For Treasury bill redemptions when

the owner’s purchase price cannot be

determined, the following list gives the

noncompetitive issue prices and corresponding amounts of discount to be

reported on Form 1099–INT for Treasury bills maturing July through December 1996. This list, which should also

help middlemen determine any amounts

subject to backup withholding, supplements the list that appears in Publication 1212, List of Original Issue

Discount Instruments (Rev. Nov. 95).

CUSIP

Number

Maturity

Date

Issue

Date

Issue Price (%

of Principal

Amount)

912794

W42

W59

W67

W75

W83

W91

X25

X33

X41

X58

X66

X74

X82

X90

Y24

Y32

Y40

Y57

Y65

Y73

Y81

Y99

Z23

Z31

Z49

Z56

01/04/96

01/11/96

01/18/96

01/25/96

02/01/96

02/08/96

02/15/96

02/22/96

02/29/96

03/07/96

03/14/96

03/21/96

03/28/96

04/04/96

04/11/96

04/18/96

04/25/96

05/02/96

05/09/96

05/16/96

05/23/96

05/30/96

06/06/96

06/13/96

06/20/96

06/27/96

07/06/95

01/12/95

07/20/95

07/27/95

08/03/95

02/09/95

08/17/95

08/24/95

08/31/95

03/09/95

09/14/95

09/21/95

09/28/95

04/06/95

10/12/95

10/19/95

10/26/95

05/04/95

11/09/95

11/16/95

11/24/95

06/01/95

12/07/95

12/14/95

12/21/95

06/29/95

97.240

93.064

97.270

97.240

97.275

93.337

97.260

97.255

97.300

93.772

97.305

97.361

97.336

93.913

97.310

97.300

97.305

94.034

97.326

97.305

97.360

94.398

97.376

97.371

97.396

94.722

Discount to be

Reported as 1995

Interest (per $1,000

Maturity Value)

27.60

69.36

27.30

27.60

27.25

66.83

27.40

27.45

27.00

62.28

26.95

26.39

26.64

60.87

26.90

27.00

26.95

59.66

26.74

26.95

26.40

56.02

26.24

26.29

26.04

52.78

1996– 24 I.R.B.

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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

Isdaner, Thomas M.

Cacciola, Marlene

Crofton, MD

Pittsburg, CA

October 31, 1995 to October 30, 1996

November 9, 1995 to May 8, 1996

Goldman, William D.

Armstrong, David L.

Heckathorn, Ben

Hot Springs, AR

Norman, OK

Red Oak, TX

Tisdel, Linda

Seattle, WA

Webb, Herbert M.

Hipp, Robert J.

Ruff, James M.

Mulkerin, John J.

Redwitz, Robert

Lind, Stanley L.

Dais, Robert E.

Gainsville, FL

Evanston, IL

Willmar, MN

Wheaton, IL

Irvine, CA

Milwaukee, WI

Plano, TX

CPA

Enrolled

Agent

Attorney

CPA

Attorney

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

November 9, 1995 to November 8, 1996

Indefinite from November 10, 1995

Indefinite from November 28, 1995

November 28, 1995 to May 27, 1997

December 21, 1995 to June 20, 1997

December 28, 1995 to April 27, 1996

January 1, 1996 to March 31, 1996

January 5, 1996 to April 4, 1996

February 15, 1996 to May 14, 1996

March 1, 1996 to February 28, 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:

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Name

Address

Designation

Effective Date

Muraskin, David

Kelsey, Patrick

New York, NY

Poolesville, MD

Attorney

CPA

November 6, 1995

November 13, 1995

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

Trebatch, Henry T.

Roomberg, Alan

Elfenbein, Emanuel B.

Great Neck, NY

Minersville, PA

Miami, FL

Indefinite from November 6, 1995

Indefinite from November 10, 1995

Indefinite from November 27, 1995

Cerullo, Louis, J.

Fogel, Harold

Glover, Paul L.

Miller, John R.

Pofahl, Charles

Walburg, Douglas

Hibler, Thomas M.

Boca Raton, FL

St. Paul, MN

Downers Grove, IL

Akron, OH

Dallas, TX

Mahtomedi, MN

Plymouth, MI

Oringer, Ronald

Butcher, Frederick

Tokars, Frederic

Atkins, Sanford I.

Flanders, NJ

Stillwater, NJ

Atlanta, GA

Moreland Hills, OH

CPA

Enrolled

Agent

CPA

Attorney

CPA

Attorney

CPA

Attorney

Indefinite from November 27, 1995

Indefinite from December 13, 1995

Indefinite from December 18, 1995

Indefinite from December 29, 1995

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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

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 0055 JOB B23-052-003 PAGE-0015 FINDING LIST

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Numerical Finding List1

Bulletins 1996–1 through 1996–8

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

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

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

IA–33–95, 1996–4 I.R.B. 99

INTL–3–95, 1996–6 I.R.B. 29

INTL–9–95, 1996–5 I.R.B. 25

PS–2–95, 1996–7 I.R.B. 50

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

96–9, 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

Revenue Procedures—Continued

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

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

96–14, 1996–6 I.R.B. 20

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

8644, 1996–7 I.R.B. 16

8645, 1996–8 I.R.B. 4

8646, 1996–8 I.R.B. 10

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.

SEQ 0056 JOB B23-052-003 PAGE-0016 FINDING LIST

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Finding List of Current Action on

Previously Published Items1

Bulletins 1996–1 through 1996–8

*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

93–16

Superseded by

96–11, 1996–2 I.R.B. 18

93–46

Superseded in part by

96–17, 1996–4 I.R.B. 69

Superseded by

96–18, 1996–4 I.R.B. 73

Revenue Procedures—Continued

95–20

Superseded by

96–24, 1996–5 I.R.B. 28

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:

94–18

Superseded in part by

96–17, 1996–4 I.R.B. 69

66–307

Obsoleted by

96–3, 1996–2 I.R.B. 14

Superseded by

96–18, 1996–4 I.R.B. 73

72–437

Modified by

96–13, 1996–3 I.R.B. 31

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

95–1

Superseded by

96–1, 1996–1 I.R.B. 8

89–19

Superseded by

96–17, 1996–4 I.R.B. 69

95–2

Superseded by

96–2, 1996–1 I.R.B. 60

89–48

Superseded in part by

96–17, 1996–4 I.R.B. 69

95–3

Superseded by

96–3, 1996–1 I.R.B. 82

91–22

Modified by

96–1, 1996–1 I.R.B. 8

95–4

Superseded by

96–4, 1996–1 I.R.B. 94

91–22

Amplified by

96–13, 1996–3 I.R.B. 31

95–5

Superseded by

96–5, 1996–1 I.R.B. 129

91–23

Superseded by

96–13, 1996–3 I.R.B. 31

95–6

Superseded by

96–6, 1996–1 I.R.B. 151

91–24

Superseded by

96–14, 1996–3 I.R.B. 41

95–7

Superseded by

96–7, 1996–1 I.R.B. 185

91–26

Superseded by

96–13, 1996–3 I.R.B. 31

95–8

Superseded by

96–8, 1996–1 I.R.B. 187

92–20

Modified by

96–1, 1996–1 I.R.B. 8

95–13

Superseded by

96–20, 1996–4 I.R.B. 88

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.

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 0057 JOB B23-052-003 PAGE-0017 FINDING LIST

REVISED 28MAY96 AT 11:34 BY LR DEPTH: 65.01 PICAS WIDTH 32.10 PICAS

COMPOSITE COLOR

778/20049/28MAY96/B23-052

NOTES

SEQ 0058 JOB B23-052-003 PAGE-0018 FINDING LIST

REVISED 28MAY96 AT 11:34 BY LR DEPTH: 65.01 PICAS WIDTH 32.10 PICAS

COMPOSITE COLOR

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NOTES

SEQ 0059 JOB B23-052-003 PAGE-0019 FINDING LIST

REVISED 28MAY96 AT 11:34 BY LR DEPTH: 65.01 PICAS WIDTH 32.10 PICAS

COMPOSITE COLOR

778/20049/28MAY96/B23-052

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.