Bulletin No. 1997–49

Internal Revenue

bulletin

Bulletin No. 1997–49

December 8, 1997

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

EXEMPT ORGANIZATIONS

Rev. Rul. 97–48, page 5.

Announcement 97–117, page 12.

This ruling revokes Rev. Rul 75–7, 1975–1 C.B. 244, and

holds that the activities of a contract manufacturer cannot

be attributed to a controlled foreign corporation for purposes of either section 954(d)(1) or section 954(d)(2) of the

Code to determine whether the income of a controlled foreign corporation is foreign base company sales income. The

ruling, however, provides section 7805(b) relief for taxable

years of a controlled foreign corporation beginning before

December 8, 1997. Rev. Rul. 75–7 revoked.

A list is provided of organizations now classified as private

foundations.

Rev. Rul. 97–50, page 5.

Notice 97–62, page 8.

Announcement 97–118, page 13.

A list is provided of organizations that no longer qualify as

organizations for which contributions are deductible under

section 170 of the Code.

ADMINISTRATIVE

Federal rates; adjusted federal rates; adjusted federal

long-term rate, and the long-term exempt rate. For

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

of the Code, tables set forth the rates for December 1997.

This notice provides up to a 90-day extension of time to perform any act described in section 7508(a)(1) of the Code for

taxpayers located in Grand Forks County, North Dakota, and

Polk County, Minnesota, including filing and paying federal

income tax.

Rev. Rul. 97–51, page 4.

Notice 97–70, page 9.

Loan to community development corporation is eligible for general business credit. The full amount of the

loan made to a community development corporation (CDC)

is a “transfer of cash” to the CDC for purposes of the definition of a “qualified CDC contribution.”

This notice modifies Notice 97–9, 1997–2 I.R.B. 35, to

incorporate the amendment made to adoption credit rules

regarding the year(s) in which the credit for certain qualified

adoption expenses is allowed.

Notice 97–71, page 9.

This notice provides tables which show the amount of an individual’s income that is exempt from a notice of levy used to

collect delinquent tax in 1998.

Finding Lists begin on page 15.

Announcement of Declaratory Judgement Proceedings Under Section 7428 begins on page 13.

Department of the Treasury

Internal Revenue Service

Mission of the Service

ucts and services; and perform in a manner warranting

the highest degree of public confidence in our integrity, efficiency, and fairness.

The purpose of the Internal Revenue Service is to collect

the proper amount of tax revenue at the least cost; serve

the public by continually improving the quality of our prod-

Statement of Principles

of Internal Revenue

Tax Administration

The Service also has the responsibility of applying and

administering the law in a reasonable, practical manner.

Issues should only be raised by examining officers when

they have merit, never arbitrarily or for trading purposes.

At the same time, the examining officer should never hesitate to raise a meritorious issue. It is also important that

care be exercised not to raise an issue or to ask a court to

adopt a position inconsistent with an established Service

position.

The function of the Internal Revenue Service is to administer the Internal Revenue Code. Tax policy for raising revenue

is determined by Congress.

With this in mind, it is the duty of the Service to carry out that

policy by correctly applying the laws enacted by Congress;

to determine the reasonable meaning of various Code provisions in light of the Congressional purpose in enacting them;

and to perform this work in a fair and impartial manner, with

neither a government nor a taxpayer point of view.

Administration should be both reasonable and vigorous. It

should be conducted with as little delay as possible and

with great courtesy and considerateness. It should never

try to overreach, and should be reasonable within the

bounds of law and sound administration. It should, however, be vigorous in requiring compliance with law and it

should be relentless in its attack on unreal tax devices and

fraud.

At the heart of administration is interpretation of the Code. It

is the responsibility of each person in the Service, charged

with the duty of interpreting the law, to try to find the true

meaning of the statutory provision and not to adopt a

strained construction in the belief that he or she is “protecting the revenue.” The revenue is properly protected only

when we ascertain and apply the true meaning of the statute.

2

Introduction

The Internal Revenue Bulletin is the authoritative instrument

of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service

and for publishing Treasury Decisions, Executive Orders, Tax

Conventions, legislation, court decisions, and other items of

general interest. It is published weekly and may be obtained

from the Superintendent of Documents on a subscription

basis. Bulletin contents of a permanent nature are consolidated semiannually into Cumulative Bulletins, which are sold

on a single-copy basis.

dures must be considered, and Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances

are substantially the same.

The Bulletin is divided into four parts as follows:

Part I.—1986 Code.

This part includes rulings and decisions based on provisions

of the Internal Revenue Code of 1986.

It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application

of the tax laws, including all rulings that supersede, revoke,

modify, or amend any of those previously published in the

Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements

of internal practices and procedures that affect the rights

and duties of taxpayers are published.

Part II.—Treaties and Tax Legislation.

This part is divided into two subparts as follows: Subpart A,

Tax Conventions, and Subpart B, Legislation and Related

Committee Reports.

Part III.—Administrative, Procedural, and Miscellaneous.

To the extent practicable, pertinent cross references to

these subjects are contained in the other Parts and Subparts. Also included in this part are Bank Secrecy Act Administrative Rulings. Bank Secrecy Act Administrative Rulings

are issued by the Department of the Treasury’s Office of the

Assistant Secretary (Enforcement).

Revenue rulings represent the conclusions of the Service on

the application of the law to the pivotal facts stated in the

revenue ruling. In those based on positions taken in rulings

to taxpayers or technical advice to Service field offices,

identifying details and information of a confidential nature

are deleted to prevent unwarranted invasions of privacy and

to comply with statutory requirements.

Part IV.—Items of General Interest.

With the exception of the Notice of Proposed Rulemaking

and the disbarment and suspension list included in this part,

none of these announcements are consolidated in the Cumulative Bulletins.

Rulings and procedures reported in the Bulletin do not have

the force and effect of Treasury Department Regulations,

but they may be used as precedents. Unpublished rulings

will not be relied on, used, or cited as precedents by Service

personnel in the disposition of other cases. In applying published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and proce-

The first Bulletin for each month includes a cumulative index

for the matters published during the preceding months.

These monthly indexes are cumulated on a quarterly and

semiannual basis, and are published in the first Bulletin of the

succeeding quarterly and semiannual period, respectively.

The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.

For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402.

3

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

Section 38.—General Business

Credit

Loan to community development

corporation is eligible for general business credit. The full amount of the loan

made to a community development corporation (CDC) is a “transfer of cash” to

the CDC for purposes of the definition of

a “qualified CDC contribution.”

Rev. Rul. 97–51

ISSUE

What amount of a loan may a community development corporation (CDC) treat

as a “transfer of cash” for purposes of the

definition of a “qualified CDC contribution”?

FACTS

Bank wishes to lend money to X, a

CDC, that X will use to provide employment and business opportunities for lowincome residents in its operational area.

In June 1994, the Secretary of Housing

and Urban Development (HUD) designated X a “selected community development corporation” under § 13311 of the

Omnibus Revenue Reconciliation Act of

1993, 1993–3 C.B. 144 (the Act). Bank

and X have negotiated an agreement that

Bank will lend X $2,000,000 on December 31, 1997, for 10 years at a stated rate

of interest. Under the terms of the loan, X

does not have to repay the loan before the

end of 10 years.

LAW AND ANALYSIS

Section 13311 of the Act provides a

business credit under § 38 of the Internal

Revenue Code for a qualified CDC contribution made by a taxpayer to a CDC. A

qualified CDC contribution is any transfer

of cash (1) made to a CDC during the 5year period beginning June 30, 1994, (2)

that is available for use by the CDC for at

least 10 years, (3) that the CDC uses to

provide employment and business opportunities for low-income individuals who

are residents of the operational area of the

CDC, and (4) that the CDC designates as

a qualified CDC contribution. The Secretary of HUD selects the 20 qualifying

CDCs and determines whether those

December 8, 1997

CDCs spend the money received appropriately.

A contributing taxpayer may claim an

annual credit during a 10-year period

equal to 5 percent of its contribution that

is designated by the CDC as a qualified

CDC contribution. The aggregate amount

of contributions that a CDC can designate

as eligible for the credit may not exceed

$2,000,000. The credit period begins

with the taxable year during which the

taxpayer made the qualified CDC contribution.

A qualified contribution to a CDC need

not be in the form of an outright gift. A

qualified contribution may also be made

in the form of a loan, the principal of

which is to be returned to the lender taxpayer after the 10-year period. H.R. Rep.

No. 2264, 103d Cong., 1st Sess. 801

n.196 (1993), 1993–3 C.B. 377.

In the present case, Bank is lending

$2,000,000 to X for 10 years. To the extent of the amount of the loan designated

by X as a qualified CDC contribution,

Bank is eligible to claim the CDC credit.

HOLDING

The full amount of the loan made to a

CDC is a “transfer of cash” to the CDC

for purposes of the definition of a “qualified CDC contribution.”

DRAFTING INFORMATION

The principal author of this revenue

ruling is Paul Handleman of the Office of

the Assistant Chief Counsel (Passthroughs and Special Industries). For further information regarding this revenue

ruling contact Mr. Handleman on (202)

622-3040 (not a toll free number).

Section 382.—Limitation on Net

Operating Loss Carryforwards

and Certain Built-In Losses

Following Ownership Change

The adjusted federal long-term rate is set forth for

the month of December 1997. Rul. 97–50, page 5.

Section 412.—Minimum

Funding Standards

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

of December 1997. See Rev. Rul. 97–50, page 5.

Section 467.—Certain

Payments for the Use of

Property or Services

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

of December 1997. See Rev. Rul. 97–50, page 5.

Section 468.—Special Rules

for Mining and Solid Waste

Reclamation and Closing Costs

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

of December 1997. See Rev. Rul. 97–50, page 5.

Section 482.—Allocation of

Income and Deductions

Among Taxpayers

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

rates are set forth for the month of December 1997.

See Rev. Rul. 97–50, page 5.

Section 483.—Interest on

Certain Deferred Payments

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

of December 1997. See Rev. Rul. 97–50, page 5.

Section 42.—Low-Income

Housing Credit

Section 642.—Special Rules for

Credits and Deductions

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

of December 1997. See Rev. Rul. 97–50, page 5.

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

rates are set forth for the month of December 1997.

See Rev. Rul. 97–50, page 5.

Section 280G.—Golden

Parachute Payments

Section 807.—Rules for

Certain Reserves

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

rates are set forth for the month of December 1997.

See Rev. Rul. 97–50, page 5.

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

of December 1997. See Rev. Rul. 97–50, page 5.

4

1997–49 I.R.B.

Section 846.—Discounted

Unpaid Losses Defined

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

of December 1997. See Rev. Rul. 97–50, on this

page.

Section 954.—Foreign Base

Company Income.

26 CFR 1.954-3: Foreign base company

sales income. (Also sections 7805,

301.7805–1.)

This ruling revokes Rev. Rul. 75–7,

1975–1 C.B. 244, and holds that the activities of a contract manufacturer cannot

be attributed to a controlled foreign corporation for purposes of either section

954(d)(1) or section 954(d)(2) of the

Code to determine whether the income

of a controlled foreign corporation is foreign base company sales income. The

ruling, however, provides 7805(b) relief

for taxable years of a controlled foreign

corporation beginning before December

8, 1997.

Rev. Rul. 97–48

In Rev. Rul. 75–7, 1975–1 C.B. 244, a

controlled foreign corporation entered

into an arm’s length contract with an unrelated contract manufacturer located outside of its country of incorporation.

Under the contract, the unrelated contract

manufacturer agreed to perform manufacturing services for the controlled foreign

corporation. Under the facts described in

Rev. Rul. 75–7, the processing activities

of the unrelated contract manufacturer

were considered to be performed by the

controlled foreign corporation outside its

country of incorporation through a branch

or similar establishment for purposes of

section 954(d)(1) and (2) of the Internal

Revenue Code.

In Ashland Oil Co. v. Commissioner,

95 T.C. 348 (1990), the Tax Court held

that a manufacturing corporation

unrelated to a controlled foreign corporation cannot be a branch or similar

establishment of the controlled foreign

corporation. See also, Vetco, Inc. v. Commissioner, 95 T.C. 579 (1990) (wholly-

1997–49 I.R.B.

owned subsidiary of a controlled foreign

corporation cannot be a branch or similar

establishment of the controlled foreign

corporation).

The Service will follow the Ashland

and Vetco opinions. The activities of a

contract manufacturer cannot be attributed to a controlled foreign corporation

for purposes of either section 954(d)(1) or

section 954(d)(2) of the Code to determine whether the income of a controlled

foreign corporation is foreign base company sales income. Accordingly, Rev.

Rul. 75–7 is revoked.

Pursuant to the authority of section

7805(b), for taxable years of a controlled

foreign corporation beginning before December 8, 1997, the principles of Rev.

Rul. 75–7 may be relied upon to attribute

the activities of a contract manufacturer to

the controlled foreign corporation. A taxpayer that relies on Rev. Rul. 75–7 to attribute the activities of a contract manufacturer to a controlled foreign

corporation for purposes of section

954(d)(1), however, must treat the contract manufacturing activities as being

performed through a branch or similar establishment of the controlled foreign corporation for purposes of section

954(d)(2). The Service has never been of

the view that Rev. Rul. 75–7 allows the

activities of a contract manufacturer performed outside the controlled foreign corporation’s country of incorporation to be

attributed to the controlled foreign corporation without treating those activities as

performed through a branch or similar establishment of the controlled foreign corporation.

With the revocation of Rev. Rul. 75–7,

the Service’s position on the treatment of

contract manufacturing for purposes section 954(d) is harmonized with its position on the treatment of contract manufacturing for purposes of section 863(b)

(see § 1.863–3(c) of the Income Tax

Regulations (production activity limited

to activity conducted directly by taxpayer)).

EFFECT ON OTHER

REVENUE RULINGS

Rev. Rul. 75–7, 1975–1 C.B. 244, is revoked effective December 8, 1997.

5

The principal author of this revenue

ruling is Valerie Mark of the Office of the

Associate Chief Counsel (International).

For further information regarding this

revenue ruling, contact Ms. Mark at (202)

622-3840 (not a toll-free call).

Section 1274.—Determination

of Issue Price in the Case of

Certain Debt Instruments

Issued for Property

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

483, 642, 807, 846, 1288, 7520, 7872.)

Federal rates; adjusted federal rates;

adjusted federal long-term rate, and

the long-term exempt rate. For purposes

of sections 1274, 1288, 382, and other

sections of the Code, tables set forth the

rates for December 1997.

Rev. Rul. 97–50

This revenue ruling provides various

prescribed rates for federal income tax

purposes for December 1997 (the current

month.) Table 1 contains the short-term,

mid-term, and long-term applicable federal rates (AFR) for the current month for

purposes of section 1274(d) of the Internal Revenue Code. Table 2 contains the

short-term, mid-term, and long-term adjusted applicable federal rates (adjusted

AFR) for the current month for purposes

of section 1288(b). Table 3 sets forth the

adjusted federal long-term rate and the

long-term tax-exempt rate described in

section 382(f). Table 4 contains the appropriate percentages for determining the

low-income housing credit described in

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

service during the current month. Table 5

contains the federal rate for determining

the present value of an annuity, an interest

for life or for a term of years, or a remainder or a reversionary interest for purposes

of section 7520. Finally, Table 6 contains

the 1998 interest rate for sections 846 and

807.

December 8, 1997

REV. RUL. 97-50 TABLE 1

Applicable Federal Rates (AFR) for December 1997

Period for Compounding

Annual

Semiannual

Quarterly

Monthly

5.68%

6.25%

6.83%

7.41%

5.60%

6.16%

6.72%

7.28%

5.56%

6.11%

6.66%

7.21%

5.54%

6.08%

6.63%

7.17%

6.02%

6.63%

7.25%

7.86%

9.10%

10.65%

5.93%

6.52%

7.12%

7.71%

8.90%

10.38%

5.89%

6.47%

7.06%

7.64%

8.80%

10.25%

5.86%

6.43%

7.02%

7.59%

8.74%

10.16%

6.31%

6.95%

7.59%

8.23%

6.21%

6.83%

7.45%

8.07%

6.16%

6.77%

7.38%

7.99%

6.13%

6.73%

7.34%

7.94%

Short-Term

AFR

110% AFR

120% AFR

130% AFR

Mid-Term

AFR

110% AFR

120% AFR

130% AFR

150% AFR

175% AFR

Long-Term

AFR

110% AFR

120% AFR

130% AFR

REV. RUL. 97-50 TABLE 2

Adjusted AFR for December 1997

Period for Compounding

Short-term

adjusted AFR

Mid-term

adjusted AFR

Long-term

adjusted AFR

Annual

Semiannual

Quarterly

Monthly

3.92%

3.88%

3.86%

3.85%

4.37%

4.32%

4.30%

4.28%

5.23%

5.16%

5.13%

5.11%

REV. RUL. 97-50 TABLE 3

Rates Under Section 382 for December 1997

Adjusted federal long-term rate for the current month

5.23%

Long-term tax-exempt rate for ownership changes

during the current month (the highest of the adjusted

federal long-term rates for the current month and the

prior two months.)

5.27%

REV. RUL. 97-50 TABLE 4

Appropriate Percentages Under Section 42(b)(2) for December 1997

Appropriate percentage for the 70% present

value low-income housing credit

8.45%

Appropriate percentage for the 30% present

value low-income housing credit

December 8, 1997

6

3.62%

1997–49 I.R.B.

REV. RUL. 97-50 TABLE 5

Rate Under Section 7520 for December 1997

Applicable federal rate for determining the present

value of an annuity, an interest for life or a term

of years, or a remainder or reversionary interest

7.2%

REV. RUL. 97-50 TABLE 6

Rate under Sections 846 and 807

Applicable rate of interest for 1998 for purposes

of sections 846 and 807

6.31%

Section 1288.—Treatment of

Original Issue Discount on

Tax-Exempt Obligations

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

of December 1997. See Rev. Rul. 97–50, page 5.

Section 6081.—Extension of

Time for Filing Returns

26 CFR 301.6081–1: Extension of time for filing returns.

Up to a 6-month extension of time to file federal

tax returns is provided to taxpayers located in Grand

Forks County, North Dakota, and Polk County, Minnesota. See Notice 97–62, page 8.

Up to a 6-month extension of time to pay federal

tax is provided to taxpayers located in Grand Forks

County, North Dakota, and Polk County, Minnesota.

See Notice 97–62, page 8.

ers located in Grand Forks County, North Dakota,

and Polk County, Minnesota. See Notice 97–62,

page 8.

Section 6601.—Interest on

Underpayment, Nonpayment, or

Extension of Time for Payment,

of Tax

Section 7520.—Valuation Tables

26 CFR 301.6601–1: Interest on underpayments.

Section 7872.—Treatment of

Loans with Below-Market

Interest Rates

Interest is abated with respect to federal individual income tax returns for certain taxpayers located

in Grand Forks County, North Dakota, and Polk

County, Minnesota. See Notice 97–62, page 8.

Section 6161.—Extension of

Time for Paying Tax

Section 7508.—Time for

Performing Certain Acts

Postponed by Reason of Service

in Combat Zone

26 CFR 1.6161–1: Extension of time for paying tax

or deficiency.

The time for performing certain acts under the Internal Revenue laws is postponed for certain taxpay-

1997–49 I.R.B.

7

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

of December 1997. See Rev. Rul. 97–50, page 5.

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

of December 1997. See Rev. Rul. 97–50, page 5.

December 8, 1997

Part III. Administrative, Procedural, and Miscellaneous

Presidentially Declared

Disasters in North Dakota and

Minnesota

Notice 97-62

PURPOSE

This notice provides immediate additional federal tax relief under §§ 6081,

6161, and 7508A of the Internal Revenue

Code for taxpayers located in Grand

Forks County, North Dakota, and Polk

County, Minnesota, which were declared

major disaster areas by the President on

April 7 and 8, 1997. This notice specifically provides up to a 90-day extension of

the time to perform any act described in §

7508(a)(1), and generally provides an extension through January 13, 1998 for filing and paying federal income tax. In addition, the Treasury Department intends

to issue regulations under § 7508A regarding the postponement of certain taxrelated deadlines by reason of a Presidentially declared disaster.

SUMMARY OF RELIEF

As a result of this notice:

(1) Taxpayers located in Grand Forks

County, North Dakota, and Polk County,

Minnesota, will have an extension to January 13, 1998 to file certain federal tax returns originally due on or after April 15,

1997, and to pay the amount (or any installments) of tax shown or required to be

shown on those returns, including — individual income tax returns (Forms 1040,

1040A, 1040EZ, 1040NR, 1040NR–EZ,

or 1040PC), gift tax returns (Forms 709

and 709–A), partnership returns (Form

1065), corporate income tax returns

(Forms 1120, 1120–A, 1120–H, or

1120S), estate and trust income tax returns (Form 1041), and annual returns

filed by tax-exempt organizations (Forms

990, 990–EZ, or 990–T).

(2) For any quarterly estimated tax

payment originally due on or after April

15, 1997 for taxpayers located in these

two counties, the payment deadline is extended to January 13, 1998 and no estimated tax penalties will be assessed. This

extension includes estimated tax pay-

December 8, 1997

ments made by individuals, corporations,

estates, or trusts. The deadline for filing

or paying employment or excise taxes

cannot be extended.

(3) Interest (and penalties relating to

the failure to file or pay) will be abated

(and waived) through January 13, 1998

with respect to federal individual income

tax returns originally due on or after April

15, 1997 for individuals (not including estates and trusts) located in these two

counties.

For additional details on the relief provided in this notice, see the portion below

headed “GRANT OF RELIEF.”

BACKGROUND

Section 6081 provides that the Secretary may grant a reasonable extension of

time (generally not to exceed 6 months)

for filing any return, declaration, statement, or other document required by the

Internal Revenue Code or by regulations

thereunder.

Section 6161 provides that the Secretary may grant a reasonable extension of

time (generally not to exceed 6 months)

for paying the amount (or any installments) of tax shown or required to be

shown on any return or declaration required by the Code or by regulations

thereunder.

Section 7508A, as added to the Code

by section 911 of the Taxpayer Relief Act

of 1997 (Act), Pub. L. No. 105-34, 111

Stat. 788 (August 5, 1997), provides the

Secretary with authority to postpone the

time for performing certain acts under the

internal revenue laws (as provided in §

7508(a)(1)) for a taxpayer affected by a

Presidentially declared disaster (as defined in § 1033(h)(3)). Pursuant to §

7508A(a), the Secretary may prescribe

regulations under which a period of up to

90 days may be disregarded in determining, under the internal revenue laws and

in respect of any tax liability (including

any penalty, additional amount, or addition to the tax) of such taxpayer,

(1) whether any of the acts described in

§ 7508(a)(1) (including filing and paying

federal taxes) were performed within the

time prescribed therefor, and

(2) the amount of any credit or refund.

8

Section 7508A applies to any period for

performing an act that has not expired before August 5, 1997.

Section 915(a) of the Act further provides that under certain circumstances the

assessment of interest with respect to income tax must be abated for any individual located in an area designated during

1997 as a Presidentially declared disaster

area. This abatement is applicable for any

period the Secretary has extended the

time for filing income tax returns under §

6081 and the time for paying income tax

with respect to such returns under § 6161

(and has waived any penalties relating to

the failure to so file or so pay). For this

purpose, the term “individual” does not

include any estate or trust.

Prior federal tax relief was provided to

taxpayers located in North Dakota, South

Dakota, and Minnesota in IRS News Release IR–97–21 dated April 8, 1997, and

in a News Release dated April 29, 1997

issued by the IRS North Central District

Office.

GRANT OF RELIEF

The Secretary, by the exercise of his

authority under § 7508A, has granted an

extension of time to perform any act described in § 7508(a)(1) to all taxpayers located in Grand Forks County, North

Dakota, and Polk County, Minnesota, for

which the period for performance of the

act (taking extensions into account) had

not expired by August 5, 1997 and had

commenced no later than November 2,

1997 (affected act). For affected acts for

which the period for performance commenced prior to August 5, 1997 (such as

the filing of a 1996 income tax return by

an individual calendar year taxpayer for

which the period for performance commenced on January 1, 1997), this extension is for 90 days. For affected acts for

which the period for performance commenced on or after August 5, 1997 and on

or before November 2, 1997, this extension is equal to the number of days from

that commencement date through November 2, 1997.

In addition, the Secretary, by exercise

of his authority under §§ 6081 and 6161,

further extends the time for filing and

1997–49 I.R.B.

paying federal taxes through January 13,

1998 for those taxpayers located in these

two counties for whom the filing and payment date was originally on or after April

15, 1997 and would be before January 13,

1998 even with the applicable § 7508A

extension.

Further, pursuant to the authority provided in § 915 of the Act, the Secretary

will abate the assessment of any interest

prescribed under § 6601 (and waive any

penalties relating to the failure to file or

pay) through January 13, 1998 with respect to federal individual income tax returns originally due on or after April 15,

1997 for individuals (not including estates

and trusts) located in these two counties.

DRAFTING INFORMATION

The principal author of this notice is

Vincent G. Surabian of the Office of the

Assistant Chief Counsel (Income Tax and

Accounting). For further information regarding this notice, contact Mr. Surabian

at (202) 622-4940 (not a toll-free call).

Adoption Assistance

Notice 97-70

This notice modifies Notice 97–9,

1997–2 I.R.B. 35, which provides, in part,

general guidance concerning the income

tax credit under § 23 of the Internal Revenue Code for qualified adoption expenses paid or incurred by an individual.

Notice 97-9 is modified to incorporate the

amendment made to § 23(a)(2) (relating

to the year(s) in which the credit for certain qualified adoption expenses is allowed) by § 1601(h)(2)(A) of the Taxpayer Relief Act of 1997, Pub. L. No.

105-34, 111 Stat. 788, 1092 (1997), effective for taxable years beginning after December 31, 1996. Notice 97-9 will appear

in 1997–1 C.B. as modified by this notice.

Section I.E.1 and the first paragraph of

section I.E.2 of Notice 97–9 are modified

to read as follows:

E.Year of Credit.

1. Domestic adoptions.

The credit for qualified adoption expenses paid or incurred to adopt an eligible child who is a citizen or a resident of

the United States at the time the adoption

commenced (including such amounts paid

or incurred in an unsuccessful effort to

adopt such a child) is allowed in the next

taxable year unless the expenses are paid

or incurred during or after the taxable

year the adoption becomes final. The

credit for qualified adoption expenses

paid or incurred during or after the tax-

able year in which an adoption becomes

final is allowed in the taxable year in

which the expenses are paid or incurred.

2. Foreign adoptions.

A special rule applies in the case of the

adoption of an eligible child who is not a

citizen or resident of the United States at

the time the adoption commenced. The

credit is only available for adoptions that

become final. Qualified adoption expenses paid or incurred in any taxable

year before the taxable year in which the

adoption becomes final are treated as paid

or incurred in the taxable year in which

the adoption becomes final. Therefore,

the credit for qualified adoption expenses

paid or incurred in the taxable year in

which the adoption is final, or in any earlier taxable year, is allowed in the taxable

year the adoption becomes final. The

credit for qualified adoption expenses

paid or incurred after the taxable year in

which the adoption becomes final is allowed in the taxable year in which the expenses are paid or incurred.

The principal author of this notice is

Marilyn E. Brookens of the Office of the

Assistant Chief Counsel (Income Tax and

Accounting). For further information regarding this notice, contact Ms. Brookens

at (202) 622-4920 (not a toll-free call).

Tables for Figuring Amount Exempt From Levy on Wages, Salary, and Other Income

Notice 97–71

1. Table for Figuring Amount Exempt From Levy on Wages, Salary, and Other Income

(Forms 668-W, 668-W(c), & 668-W(c)(DO)) 1998

Publication 1494, shown below, provides tables which show the amount of an individual’s income that is exempt from a notice of

levy used to collect delinquent tax in 1998.

(Amounts are for each pay period.)

Filing Status: Single

Pay Period

Number of Exemptions Claimed on Statement

1

2

3

4

5

6

More Than 6

Daily

26.73

37.12

47.50

57.88

68.27

78.65

16.35 plus 10.38 for each exemption

Weekly

133.65

185.58

237.50

289.42

341.35

393.27

81.73 plus 51.92 for each exemption

Biweekly

267.31

371.15

475.00

578.85

682.69

786.54

163.46 plus 103.85 for each exemption

Semi-monthly

289.58

402.08

514.58

627.08

739.58

852.08

177.08 plus 112.50 for each exemption

Monthly

579.17

804.17

1029.17

1254.17

1479.17

1704.17

354.17 plus 225.00 for each exemption

1997–49 I.R.B.

9

December 8, 1997

Filing Status: Unmarried Head of Household

Pay Period

Number of Exemptions Claimed on Statement

1

2

3

4

5

6

More Than 6

Daily

34.42

44.81

55.19

65.58

75.96

86.35

24.04 plus 10.38 for each exemption

Weekly

172.12

224.04

275.96

327.88

379.81

431.73

120.19 plus 51.92 for each exemption

Biweekly

344.23

448.08

551.92

655.77

759.62

863.46

240.38 plus 103.85 for each exemption

Semi-monthly

372.92

485.42

597.92

710.42

822.92

935.42

260.42 plus 112.50 for each exemption

Monthly

745.83

970.83

1195.83

1420.83

1645.83

1870.83

520.83 plus 225.00 for each exemption

Filing Status: Married Filing Joint (and Qualifying Widow(er)s)

Pay Period

Number of Exemptions Claimed on Statement

1

2

3

4

5

6

More Than 6

Daily

37.69

48.08

58.46

68.85

79.23

89.62

27.31 plus 10.38 for each exemption

Weekly

188.46

240.38

292.31

344.23

396.15

448.08

136.54 plus 51.92 for each exemption

Biweekly

376.92

480.77

584.62

688.46

792.31

896.15

273.08 plus 103.85 for each exemption

Semi-monthly

408.33

520.83

633.33

745.83

858.33

970.83

295.83 plus 112.50 for each exemption

Monthly

816.67

1041.67

1266.67

1491.67

1716.67

1941.67

591.67 plus 225.00 for each exemption

Filing Status: Married Filing Separate

Pay Period

Number of Exemptions Claimed on Statement

1

2

3

4

5

6

More Than 6

Daily

24.04

34.42

44.81

55.19

65.58

75.96

13.65 plus 10.38 for each exemption

Weekly

120.19

172.12

224.04

275.96

327.88

379.81

68.27 plus 51.92 for each exemption

Biweekly

240.38

344.23

448.08

551.92

655.77

759.62

136.54 plus 103.85 for each exemption

Semi-monthly

260.42

372.92

485.42

597.92

710.42

822.92

147.92 plus 112.50 for each exemption

Monthly

520.83

745.83

970.83

1195.83

1420.83

1645.83

295.83 plus 225.00 for each exemption

December 8, 1997

10

1997–49 I.R.B.

2. Table for Figuring Additional Exempt Amount

for Taxpayers at Least 65 Years Old and/or Blind

Additional Exempt Amount

Filing Status

Single or Head

of Household

*

Daily

Wkly

Bi-Wkly

Semi-Mo

Monthly

1

2

4.04

8.08

20.19

40.38

40.38

80.77

43.75

87.50

87.50

175.00

Any Other

Filing Status

1

2

3

4

3.27

6.54

9.81

13.08

16.35

32.69

49.04

65.38

32.69

65.38

98.08

130.77

35.42

70.83

106.25

141.67

70.83

141.67

212.50

283.33

* ADDITIONAL STANDARD DEDUCTION claimed on Parts 3, 4, & 5 of levy.

Examples

These tables show the amount exempt from a levy on wages, salary, and other income.

For example:

1. A single taxpayer who is paid weekly and claims three exemptions (including one for the taxpayer) has $237.50 exempt from

levy.

2. If the taxpayer in number 1 is over 65 and writes 1 in the ADDITIONAL STANDARD DEDUCTION space on Parts 3, 4, & 5

of the levy, $257.69 is exempt from this levy ($237.50 plus $20.19).

3. A taxpayer who is married, files jointly, is paid bi-weekly, and claims two exemptions (including one for the taxpayer) has

$480.77 exempt from levy.

4. If the taxpayer in number 3 is over 65 and has a spouse who is blind, this taxpayer should write 2 in the ADDITIONAL STANDARD DEDUCTION space on Parts 3, 4, & 5 of the levy. Then, $546.15 is exempt from this levy ($480.77 plus $65.38).

1997–49 I.R.B.

11

December 8, 1997

Part IV. Items of General Interest

Foundations Status of Certain

Organizations

Announcement 97–117

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:

100 Black Men of Indianapolis Inc.,

Indianapolis, IN

100 Black Men of Milwaukee Inc.,

Milwaukee, WI

100 Percent Charity Inc., Jonesboro, GA

100 Black Men Coalition,

Oklahoma City, OK

12 Miles West Theatre Company Inc.,

Montclair, NJ

14th ILA Congress, Greenville, SC

1st District Adopt-A-Rec Center Fund,

Inc., Philadelphia, PA

2 Christ-The-Solution Inc.,

Marco Island, FL

4 Youngsters Inc., Sandy, UT

710 AA Group, Midland, TX

Acorn Community Land Association of

Illinois, New Orleans, LA

Act Right Inc., Edmond, OK

Action Theatre Conservatory Inc.,

Clifton, NJ

Actors Community Theater of Naples,

Inc., Naples, FL

Actors Rep Company Inc., Ewing, NJ

Acts 29 Ministries Inc., Valdosta, GA

Admit Center, Devils Lake, ND

Adobe Theatre Inc., Corrales, NM

Adolescent Resource Center Inc.,

Longview, TX

Adopt-A-Family of Jefferson County,

Golden, CO

December 8, 1997

Adopt-A-Greyhound of Central Florida,

Inc., Melbourne, FL

Adopt-A-Pet—N.P.C.,

Houghton Lake, MI

Adult Attention Deficit Foundation,

Birmingham, MI

Adult Literacy Project of Sabinal,

Sabinal, TX

Advanced Data Control Inc.,

St. Clairsville, OH

Advertising Professionals of Des Moines

Scholarship FDN, Des Moines, IA

Advisory Board for the Spokane Industrial Technologies Dept., Spokane, MO

Advocates for At-Risk Kids Inc–Child &

Adolescent Advocacy Bureau,

Baytown, TX

Advocates for Humanity Inc.,

Salt Lake City, UT

Affiliated Boards of Officials,

Colorado Springs, CO

Affiliation of Christian Disciples,

Colorado Springs, CO

Affordable Home Ownership Inc.,

Pataskala, OH

Affordable Homes Through Creative

Capitalism, Inc., Decatur, GA

Affordable Housing Alliance,

Farmington Hills, MI

Affordable Housing Corporation of Lake

County, Gurnee, IL

Affordable Housing Corporation of

Pinellas County, Inc.,

St. Petersburg, FL

Affordable Housing of East Tampa Bay,

Inc., Sun City Center, FL

Affordable Housing of Jennings Inc.,

Jennings, MO

Affordable Housing Solutions for

Florida, Inc., Miami, FL

Afghan Student Association Inc.,

Alexandria, VA

African American Cultural Center–The

American Youth Foundation,

Nashville, TN

African American Cultural Garden,

Cleveland, OH

African American Heritage Preservation

Society, Inc., Columbus, GA

African Christians Fellowship International, Inc., Charlotte, NC

African Family Inc., Archer, FL

Agape Christian Center Inc.,

Louisburg, KS

Agape Foundation, Chicago, IL

12

Agape Love Inc., Fort Lauderdale, FL

Agate Award Charitable Trust, Bloomington, MN

Agency for International

Understanding, Inc., Spartanburg, SC

Agrape Missionary Association International, Inc., Toccoa, GA

Aid to Lithuania Inc., Chicago, IL

Aids Countrywide Testing Information

Act I, Kenner, LA

Aids Education Help Network Inc.,

Houston, TX

Aids Outreach of Northern Arizona, Inc.,

Flagstaff, AZ

Aids Prevention Foundation of America,

Kansas City, MO

Aikikai International Inc., Miami, FL

AIMO Inc., Cleveland, OH

Airborne Police Assistance Group, Inc.,

Wilmington, DE

Airport Construction Scholarship Fund,

Inc., Miami, FL

Airway, Kingwood, TX

Aishlinn Womens Center,

Grosse Pointe Farms, MI

Alabama Citizens Coalition for

Enforcement of Support Services,

Duncanville, AL

Alabama Demolay Foundation Inc.,

Gadsden, AL

Alabama Nursing Home Association Education Foundation, Montgomery, AL

Alabama Power Service Organization,

Inc., Mobile, AL

Alabama Power Service Organization,

Inc., Eufaula, AL

Alabama Power Service Organization,

Inc., Tuscaloosa, AL

Alabama Power Service Organization,

Inc., Birmingham, AL

Alabama Power Service Organization,

Inc., Anniston, AL

Alabama Power Service Organization,

Inc., Parrish, AL

Alabama Power Service Organization,

Inc., Graysville, AL

Alabama Power Service Organization,

Inc., Montgomery, AL

Alabama Power Service Organization,

Inc., Birmingham, AL

Alabama Visual Arts Hall of Fame, Inc.,

Gadsden, AL

1997–49 I.R.B.

Alabama Waterfowl Association Inc.,

Guntersville, AL

Alameda Theater Facilities,

San Antonio, TX

Albuquerques Finest Inc.,

Albuquerque, NM

Alcor Arizona Chapter Inc.,

Phoenix, AZ

Alexander Foundation Inc., Fremont, NE

Algonac-Clay Township Historical

Society, Algonac, MI

Algonac Fire Department Auxiliary,

Algonac, MI

Alice Avenue Church of Christ Child

Care Center, Memphis, TN

Alkebu-Lan Center for Martial Arts,

Detroit, MI

Alkebu-Lan Economic Development

Systems, Inc., Phoenix, AZ

All Aboard-The Training Junction, Inc.,

Provo, UT

All Animal Rescue Organization,

Wheat Ridge, CO

All Christian Center Ministry Bible Club

America, Inc., Wichita, KS

All Generations Inc., Monroe, LA

All Saints Foundation,

Pawleys Island, SC

All Souls Indoor-Outdoor Association,

Washington, DC

All Star Athletic Association Inc.,

Smyrna, GA

All-Star Scholarship Foundation,

Plano, TX

Allegheny Comprehensive Adolescent

Programs, Inc–ACAP,

Pittsburgh, PA

Allegheny County Alliance for Public

Schools, Pittsburgh, PA

Allen County Tenant Council, Lima, OH

Allen Road Mid-Rise Tenants

Association, Inc., Atlanta, GA

Alliance for Catholic Education An Oklahoma Not for Profit Corporation,

Norman, OK

Alliance for Life Long Learning,

Detroit, MI

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

1997–49 I.R.B.

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.

Deletions from Cumulative List

of Organizations Contributions

to Which Are Deductible Under

Section 170 of the Code

Announcement 97–118

The names of organizations that no

longer qualify as organizations described

in section 170(c)(2) of the Internal Revenue Code of 1986 are listed below.

Generally, the Service will not disallow

deductions for contributions made to a

listed organization on or before the date

of announcement in the Internal Revenue

Bulletin that an organization no longer

qualifies. However, the Service is not

precluded from disallowing a deduction

for any contributions made after an organization ceases to qualify under section

170(c)(2) if the organization has not

timely filed a suit for declaratory judgment under section 7428 and if the contributor (1) had knowledge of the revocation of the ruling or determination letter,

(2) was aware that such revocation was

imminent, or (3) was in part responsible

for or was aware of the activities or omissions of the organization that brought

about this revocation.

If on the other hand a suit for declaratory judgment has been timely filed, contributions from individuals and organizations described in section 170(c)(2) that are

otherwise allowable will continue to be deductible. Protection under section 7428(c)

would begin on December 8, 1997, and

would end on the date the court first determines that the organization is not described

in section 170(c)(2) as more particularly

set forth in section 7428(c)(1). For individual contributors, the maximum deduction protected is $1,000, with a husband

and wife treated as one contributor. This

benefit is not extended to any individual

who was responsible, in whole or in part,

for the acts or omissions of the organization that were the basis for revocation.

13

Alpha Housing & Health Care, Inc.

New Castle, PA

Charles S. Meyer Family Fund

Chicago, IL

Muscular Dystrophy Aid Society, Inc.

Houston, TX

Muscular Dystrophy Aid Society Gout &

Arthritis Association

Houston, TX

Muscular Dystrophy Aid Society High

Blood Pressure Society

Houston, TX

Muscular Dystrophy Aid Society 111 Pull

for Youth, Houston, TX

Section 7428(c) Validation of

Certain Contributions Made

During Pendency of Declaratory

Judgment Proceedings

This announcement serves notice to potential donors that the organization listed

below has recently filed a timely declaratory judgment suit under section 7428 of

the Code, challenging revocation of its

status as an eligible donee under section

170(c)(2).

Protection under section 7428(c) of the

Code begins on the date that the notice of

revocation is published in the Internal

Revenue Bulletin and ends on the date on

which a court first determines that an organization is not described in section

170(c)(2), as more particularly set forth in

section 7428(c)(1). In the case of individual contributors, the maximum amount of

contributions protected during this period

is limited to $1,000.00, with a husband

and wife being treated as one contributor.

This protection is not extended to any individual who was responsible, in whole or

in part, for the acts or omissions of the organization that were the basis for the revocation. This protection also applies

(but without limitation as to amount) to

organizations described in section

170(c)(2) which are exempt from tax

under section 501(a). If the organization

ultimately prevails in its declaratory judgment suit, deductibility of contributions

would be subject to the normal limitations

set forth under section 170.

The Children’s Learning Center, Inc.

Rockville, MD

December 8, 1997

Definition of Terms

Revenue rulings and revenue procedures

(hereinafter referred to as “rulings”) that

have an effect on previous rulings use the

following defined terms to describe the

effect:

Amplified describes a situation where

no change is being made in a prior published position, but the prior position is

being extended to apply to a variation of

the fact situation set forth therein. Thus,

if an earlier ruling held that a principle

applied to A, and the new ruling holds

that the same principle also applies to B,

the earlier ruling is amplified. (Compare

with modified, below).

Clarified is used in those instances

where the language in a prior ruling is

being made clear because the language

has caused, or may cause, some confusion. It is not used where a position in a

prior ruling is being changed.

Distinguished describes a situation

where a ruling mentions a previously

published ruling and points out an essential difference between them.

Modified is used where the substance

of a previously published position is

being changed. Thus, if a prior ruling

held that a principle applied to A but not

to B, and the new ruling holds that it ap-

plies to both A and B, the prior ruling is

modified because it corrects a published

position. (Compare with amplified and

clarified, above).

Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions. This term is most commonly used

in a ruling that lists previously published

rulings that are obsoleted because of

changes in law or regulations. A ruling

may also be obsoleted because the substance has been included in regulations

subsequently adopted.

Revoked describes situations where the

position in the previously published ruling is not correct and the correct position

is being stated in the new ruling.

Superseded describes a situation where

the new ruling does nothing more than

restate the substance and situation of a

previously published ruling (or rulings).

Thus, the term is used to republish under

the 1986 Code and regulations the same

position published under the 1939 Code

and regulations. The term is also used

when it is desired to republish in a single

ruling a series of situations, names, etc.,

that were previously published over a period of time in separate rulings. If the

new ruling does more than restate the

substance of a prior ruling, a combination

of terms is used. For example, modified

and superseded describes a situation

where the substance of a previously published ruling is being changed in part and

is continued without change in part and it

is desired to restate the valid portion of

the previously published ruling in a new

ruling that is self contained. In this case

the previously published ruling is first

modified and then, as modified, is superseded.

Supplemented is used in situations in

which a list, such as a list of the names of

countries, is published in a ruling and

that list is expanded by adding further

names in subsequent rulings. After the

original ruling has been supplemented

several times, a new ruling may be published that includes the list in the original

ruling and the additions, and supersedes

all prior rulings in the series.

Suspended is used in rare situations to

show that the previous published rulings

will not be applied pending some future

action such as the issuance of new or

amended regulations, the outcome of

cases in litigation, or the outcome of a

Service study.

Abbreviations

E.O.—Executive Order.

ER—Employer.

ERISA—Employee Retirement Income Security Act.

EX—Executor.

F—Fiduciary.

FC—Foreign Country.

FICA—Federal Insurance Contribution Act.

FISC—Foreign International Sales Company.

FPH—Foreign Personal Holding Company.

F.R.—Federal Register.

FUTA—Federal Unemployment Tax Act.

FX—Foreign Corporation.

G.C.M.—Chief Counsel’s Memorandum.

GE—Grantee.

GP—General Partner.

GR—Grantor.

IC—Insurance Company.

I.R.B.—Internal Revenue Bulletin.

LE—Lessee.

LP—Limited Partner.

LR—Lessor.

M—Minor.

Nonacq.—Nonacquiescence.

O—Organization.

P—Parent Corporation.

PHC—Personal Holding Company.

PO—Possession of the U.S.

PR—Partner.

PRS—Partnership.

PTE—Prohibited Transaction Exemption.

Pub. L.—Public Law.

REIT—Real Estate Investment Trust.

Rev. Proc.—Revenue Procedure.

Rev. Rul.—Revenue Ruling.

S—Subsidiary.

S.P.R.—Statements of Procedral Rules.

Stat.—Statutes at Large.

T—Target Corporation.

T.C.—Tax Court.

T.D.—Treasury Decision.

TFE—Transferee.

TFR—Transferor.

T.I.R.—Technical Information Release.

TP—Taxpayer.

TR—Trust.

TT—Trustee.

U.S.C.—United States Code.

X—Corporation.

Y—Corporation.

Z—Corporation.

The following abbreviations in current use and formerly used will appear in material published in the

Bulletin.

A—Individual.

Acq.—Acquiescence.

B—Individual.

BE—Beneficiary.

BK—Bank.

B.T.A.—Board of Tax Appeals.

C.—Individual.

C.B.—Cumulative Bulletin.

CFR—Code of Federal Regulations.

CI—City.

COOP—Cooperative.

Ct.D.—Court Decision.

CY—County.

D—Decedent.

DC—Dummy Corporation.

DE—Donee.

Del. Order—Delegation Order.

DISC—Domestic International Sales Corporation.

DR—Donor.

E—Estate.

EE—Employee.

December 8, 1997

14

1997–49 I.R.B.

Numerical Finding List1

Bulletins 1997–27 through 1997–48

Announcements:

97–61, 1997–29 I.R.B. 13

97–67, 1997–27 I.R.B. 37

97–68, 1997–28 I.R.B. 13

97–69, 1997–28 I.R.B. 13

97–70, 1997–29 I.R.B. 14

97–71, 1997–29 I.R.B. 15

97–72, 1997–29 I.R.B. 15

97–73, 1997–30 I.R.B. 86

97–74, 1997–31 I.R.B. 16

97–75, 1997–32 I.R.B. 28

97–76, 1997–32 I.R.B. 28

97–77, 1997–33 I.R.B. 58

97–78, 1997–34 I.R.B. 11

97–79, 1997–35 I.R.B. 8

97–80, 1997–34 I.R.B. 12

97–81, 1997–34 I.R.B. 12

97–82, 1997–34 I.R.B. 12

97–83, 1997–34 I.R.B. 13

97–84, 1997–34 I.R.B. 13

97–85, 1997–35 I.R.B. 8

97–86, 1997–35 I.R.B. 9

97–87, 1997–35 I.R.B. 9

97–88, 1997–35 I.R.B. 9

97–89, 1997–36 I.R.B. 10

97–90, 1997–36 I.R.B. 10

97–91, 1997–37 I.R.B. 25

97–92, 1997–37 I.R.B. 26

97–93, 1997–36 I.R.B. 11

97–94, 1997–36 I.R.B. 12

97–95, 1997–36 I.R.B. 12

97–96, 1997–39 I.R.B. 15

97–97, 1997–38 I.R.B. 22

97–98, 1997–39 I.R.B. 15

97–99, 1997–40 I.R.B. 7

97–100, 1997–40 I.R.B. 8

97–101, 1997–41 I.R.B. 13

97–102, 1997–41 I.R.B. 15

97–103, 1997–41 I.R.B. 16

97–104, 1997–42 I.R.B. 39

97–105, 1997–42 I.R.B. 40

97–106, 1997–45 I.R.B. 11

97–107, 1997–43 I.R.B. 25

97–108, 1997–43 I.R.B. 25

97–109, 1997–45 I.R.B. 12

97–110, 1997–45 I.R.B. 14

97–111, 1997–47 I.R.B. 15

97–112, 1997–46 I.R.B. 20

97–113, 1997–46 I.R.B. 21

97–114, 1997–46 I.R.B. 21

97–115, 1997–47 I.R.B. 17

97–116, 1997–48 I.R.B. 25

Court Decisions:

2061, 1997–31 I.R.B. 5

2062, 1997–32 I.R.B. 8

Delegation Orders:

97 (Rev. 34), 1997–41 I.R.B. 14

172 (Rev. 5), 1997–28 I.R.B. 6

Notices:

97–37, 1997–27 I.R.B. 4

Notices–Continued

97–38, 1997–27 I.R.B. 8

97–39, 1997–27 I.R.B. 8

97–40, 1997–28 I.R.B. 6

97–41, 1997–28 I.R.B. 6

97–42, 1997–29 I.R.B. 12

97–43, 1997–30 I.R.B. 9

97–44, 1997–31 I.R.B. 15

97–45, 1997–33 I.R.B. 7

97–46, 1997–34 I.R.B. 10

97–47, 1997–35 I.R.B. 5

97–48, 1997–35 I.R.B. 5

97–49, 1997–36 I.R.B. 8

97–50, 1997–37 I.R.B. 21

97–51, 1997–38 I.R.B. 20

97–52, 1997–38 I.R.B. 20

97–53, 1997–40 I.R.B. 6

97–54, 1997–41 I.R.B. 7

97–55, 1997–40 I.R.B. 6

97–56, 1997–43 I.R.B. 19

97–57, 1997–43 I.R.B. 19

97–58, 1997–45 I.R.B. 7

97–59, 1997–45 I.R.B. 7

97–60, 1997–46 I.R.B. 8

97–61, 1997–48 I.R.B. 8

97–63, 1997–47 I.R.B. 6

97–64, 1997–47 I.R.B. 7

97–66, 1997–48 I.R.B. 8

97–67, 1997–48 I.R.B. 10

97–68, 1997–48 I.R.B. 11

97–69, 1997–48 I.R.B. 12

97–47, 1997–42 I.R.B. 19

97–48, 1997–43 I.R.B. 19

97–49, 1997–43 I.R.B. 22

97–50, 1997–45 I.R.B. 8

97–51, 1997–45 I.R.B. 9

97–52, 1997–46 I.R.B. 17

97–53, 1997–47 I.R.B. 10

Revenue Rulings:

97–27, 1997–27 I.R.B. 4

97–28, 1997–28 I.R.B. 4

97–29, 1997–28 I.R.B. 4

97–30, 1997–31 I.R.B. 12

97–31, 1997–32 I.R.B. 4

97–32, 1997–33 I.R.B. 4

97–33, 1997–34 I.R.B. 4

97–34, 1997–34 I.R.B. 14

97–35, 1997–35 I.R.B. 4

97–36, 1997–36 I.R.B. 5

97–37, 1997–37 I.R.B. 15

97–38, 1997–38 I.R.B. 14

97–39, 1997–39 I.R.B. 4

97–40, 1997–39 I.R.B. 8

97–41, 1997–40 I.R.B. 4

97–42, 1997–41 I.R.B. 4

97–43, 1997–42 I.R.B. 8

97–44, 1997–45 I.R.B. 5

97–45, 1997–46 I.R.B. 4

97–46, 1997–46 I.R.B. 7

97–47, 1997–47 I.R.B. 4

97–49, 1997–48 I.R.B. 4

Railroad Retirement Quarterly Rate:

Treasury Decisions:

1997–28 I.R.B. 5

8722, 1997–29 I.R.B. 4

8723, 1997–30 I.R.B. 4

8724, 1997–36 I.R.B. 4

8725, 1997–37 I.R.B. 16

8726, 1997–34 I.R.B. 7

8727, 1997–34 I.R.B. 5

8728, 1997–37 I.R.B. 4

8729, 1997–38 I.R.B. 4

8730, 1997–38 I.R.B. 16

8731, 1997–42 I.R.B. 6

8732, 1997–42 I.R.B. 4

8733, 1997–43 I.R.B. 8

8734, 1997–44 I.R.B. 5

8735, 1997–43 I.R.B. 4

Public Laws

105–35, 1997–43 I.R.B. 13

Proposed Regulations:

REG–104893–97, 1997–29 I.R.B. 13

REG–105160–97, 1997–37 I.R.B. 22

REG–105162–97, 1997–48 I.R.B. 13

REG–106043–97, 1997–37 I.R.B. 24

REG–107644–97, 1997–32 I.R.B. 24

REG–107872–97, 1997–47 I.R.B. 11

REG–114000–97, 1997–47 I.R.B. 13

REG–208151–91, 1997–38 I.R.B. 21

REG–246250–96, 1997–42 I.R.B. 30

REG–251985–96, 1997–48 I.R.B. 18

Revenue Procedures:

97–32, 1997–27 I.R.B. 9

97–32A, 1997–34 I.R.B. 10

97–33, 1997–30 I.R.B. 10

97–34, 1997–30 I.R.B. 14

97–35, 1997–33 I.R.B. 11

97–36, 1997–33 I.R.B. 14

97–37, 1997–33 I.R.B. 18

97–38, 1997–33 I.R.B. 43

97–39, 1997–33 I.R.B. 48

97–40, 1997–33 I.R.B. 50

97–41, 1997–33 I.R.B. 5

97–42, 1997–33 I.R.B. 57

97–43, 1997–39 I.R.B. 12

97–44, 1997–41 I.R.B. 8

97–45, 1997–41 I.R.B. 10

97–46, 1997–42 I.R.B. 10

1 A cumulative list of all revenue rulings, revenue

procedures, Treasury decisions, etc., published in

Internal Revenue Bulletins 1997–1 through 1997–26

will be found in Internal Revenue Bulletin 1997–27,

dated July 7, 1997.

1997–49 I.R.B.

15

December 8, 1997

Finding List of Current Action on

Previously Published Items1

Bulletins 1997–27 through 1997–48

*Denotes entry since last publication

Revenue Procedures:

82–36

Modified and superseded by

97–49, 1997–43 I.R.B. 22

96–36

Superseded by

97–34, 1997–30 I.R.B. 14

96–42

Superseded by

97–27, 1997–27 I.R.B. 9

97–32

Modified and amplified by

97–32A, 1997–34 I.R.B. 10

Revenue Rulings:

73–67

Revoked by

97–46, 1997–46 I.R.B. 7

89–42

Supplemented by

97–31, 1997–32 I.R.B. 4

93–76

Clarified, modified, partially

obsoleted, and superceded by

97–39, 1997–39 I.R.B 4

94–7

Clarified, modified, partially

obsoleted, and superceded by

97–39, 1997–39 I.R.B 4

1 A cumulative finding list for previously published

items mentioned in Internal Revenue Bulletins

1997–1 through 1997–26 will be found in Internal

Revenue Bulletin 1997–27, dated July 7, 1997.

December 8, 1997

16

1997–49 I.R.B.

Notes

1997–49 I.R.B.

17

December 8, 1997

Notes

December 8, 1997

18

1997–49 I.R.B.

Notes

1997–49 I.R.B.

19

December 8, 1997

Notes

December 8, 1997

20

1997–49 I.R.B.

Notes

1997–49 I.R.B.

21

December 8, 1997

Notes

December 8, 1997

22

1997–49 I.R.B.

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