Bulletin No. 1997–15

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April 14, 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.

SPECIAL ANNOUNCEMENTS

ESTATE TAX

Announcement 97–35, page 9.

The location of the public hearing on proposed regulations, REG–209824–96, 1996–11 I.R.B. 19, is changed.

Announcement 97–37, page 10.

The date and location of the public hearing on proposed

regulations, REG–209817–96, 1997–7 I.R.B. 41, are

changed.

T.D. 8714, page 5.

REG–209830–96, page 7.

Temporary and proposed regulations under sections

2044 and 2056 of the Code relate to the estate tax

marital deduction to conform the Estate Tax Regulations

to recent court decisions. A public hearing on the

proposed regulations will be held on June 3, 1997.

INCOME TAX

ADMINISTRATIVE

Rev. Rul. 97–18, page 4.

LIFO; price indexes; department stores. The February

1997 Bureau of Labor Statistics price indexes are

accepted for use by department stores employing the

retail inventory and the last-in, first-out inventory methods for valuing inventories for tax years ended on, or

with reference to, February 28, 1997.

Announcement 97–33, page 8.

T.D. 8708, 1997–10 I.R.B. 14, relating to the computation of foreign taxes deemed paid under section 902 of

the Code, is corrected.

EXEMPT ORGANIZATIONS

Announcement 97–36, page 10.

T.D. 8701, 1997–7 I.R.B. 23, providing rules for making

the deemed sale and deemed dividend elections under

section 1291 of the Code, is corrected.

Announcement 97–34, page 8.

A list is given of organizations now classified as private

foundations.

Announcement 97–38, page 10.

T.D. 8692, 1997–3 I.R.B. 4, relating to the reissuance

of mortgage credit certificates, is corrected.

Finding Lists begin on page 13.

Announcement of Disbarments and Suspensions begins on page 12.

Announcement of Declaratory Judgment Proceedings Under Section 7428 on page 11.

Mission of the Service

The purpose of the Internal Revenue Service is to

collect the proper amount of tax revenue at the least

cost; serve the public by continually improving the

quality of our products and services; and perform in a

manner warranting the highest degree of public

confidence in our integrity, efficiency and fairness.

Statement of Principles

of Internal Revenue

Tax Administration

The Service also has the responsibility of applying

and administering the law in a reasonable,

practical manner. Issues should only be raised by

examining of ficers when they have merit, never

arbitrarily or for trading purposes. At the same

time, the examining officer should never hesitate

to raise a meritorious issue. It is also important

that care be exercised not to raise an issue or to

ask a court to adopt a position inconsistent with

an established Service position.

The function of the Internal Revenue Service is to

administer the Internal Revenue Code. Tax policy

for raising revenue is determined by Congress.

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

carry out that policy by correctly applying the laws

enacted by Congress; to determine the reasonable

meaning of various Code provisions in light of the

Congressional purpose in enacting them; and to

perform this work in a fair and impartial manner,

with neither a government nor a taxpayer point of view.

Administration should be both reasonable and

vigorous. It should be conducted with as little

delay as possible and with great cour tesy and

considerateness. It should never try to overreach,

and should be reasonable within the bounds of law

and sound administration. It should, however, be

vigorous in requiring compliance with law and it

should be relentless in its attack on unreal tax

devices and fraud.

At the heart of administration is interpretation of the

Code. It is the responsibility of each person in the

Service, charged with the duty of interpreting the

law, to try to find the true meaning of the statutory

provision and not to adopt a strained construction in

the belief that he or she is ‘‘protecting the revenue.’’

The revenue is properly protected only when we ascertain and apply the true meaning of the statute.

Introduction

The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for

announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation,

court decisions, and other items of general interest. It is

published weekly and may be obtained from the Superintendent of Documents on a subscription basis. Bulletin

contents of a permanent nature are consolidated semiannually into Cumulative Bulletins, which are sold on a

single-copy basis.

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

cautioned against reaching the same conclusions in

other cases unless the facts and circumstances are

substantially the same.

The Bulletin is divided into four parts as follows:

Part I.—1986 Code.

This part includes rulings and decisions based on

provisions of the Internal Revenue Code of 1986.

It is the policy of the Service to publish in the Bulletin all

substantive rulings necessary to promote a uniform

application of the tax laws, including all rulings that

supersede, revoke, modify, or amend any of those

previously published in the Bulletin. All published rulings

apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management

are not published; however, statements of internal

practices and procedures that affect the rights and

duties of taxpayers are published.

Part II.—Treaties and Tax Legislation.

This part is divided into two subparts as follows:

Subpart A, Tax Conventions, and Subpart B, Legislation

and Related Committee Reports.

Part III.—Administrative, Procedural, and Miscellaneous.

To the extent practicable, pertinent cross references to

these subjects are contained in the other Parts and

Subparts. Also included in this part are Bank Secrecy

Act Administrative Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the

Treasury’s Office of the Assistant Secretary (Enforcement).

Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts

stated in the revenue ruling. In those based on positions

taken in rulings to taxpayers or technical advice to

Service field offices, identifying details and information

of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory

requirements.

Part IV.—Items of General Interest.

With the exception of the Notice of Proposed Rulemaking and the disbarment and suspension list included in

this part, none of these announcements are consolidated in the Cumulative Bulletins.

Rulings and procedures reported in the Bulletin do not

have the force and effect of Treasury Department

Regulations, but they may be used as precedents.

Unpublished rulings will not be relied on, used, or cited

as precedents by Service personnel in the disposition of

other cases. In applying published rulings and procedures, the effect of subsequent legislation, regulations,

The first Bulletin for each month includes an index for

the matters published during the preceding month.

These monthly indexes are cumulated on a quarterly and

semiannual basis, and are published in the first Bulletin

of the succeeding quarterly and semi-annual period,

respectively.

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

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

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

Section 472.—Last-in, First-out

Inventories

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

LIFO; price indexes; department

stores. The February 1997 Bureau of

Labor Statistics price indexes are accepted for use by department stores

employing the retail inventory and the

last-in, first-out inventory methods for

valuing inventories for tax years ended

on, or with reference to, February 28,

1997.

Rev. Rul. 97–18

The following Department Store Inventory Price Indexes for February 1997

were issued by the Bureau of Labor

Statistics on March 19, 1997. 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-in, first-out inventory methods

for tax years ended on, or with reference

to, February 28, 1997.

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

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

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

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

Groups 21–23: Misc. Goods2 . . . . . . . . . . . . . . . . . . . . . . . . . . .

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

Feb.

1996

Feb.

1997

Percent Change

from Feb. 1996

to Feb. 19971

505.1

651.2

644.5

895.1

645.3

522.3

289.3

552.3

402.0

619.5

570.8

476.6

1003.4

813.7

871.0

666.9

563.4

799.7

249.2

79.0

113.6

123.1

107.3

590.0

467.3

113.8

548.3

526.4

650.4

640.2

897.7

617.7

534.2

296.5

546.9

417.6

615.4

585.1

469.9

1004.9

772.0

912.3

662.0

581.2

817.0

246.1

78.6

111.1

133.3

107.9

598.9

470.0

113.3

554.2

4.2

20.1

20.7

0.3

24.3

2.3

2.5

21.0

3.9

20.7

2.5

21.4

0.1

25.1

4.7

20.7

3.2

2.2

21.2

20.5

22.2

8.3

0.6

1.5

0.6

20.4

1.1

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

Indexes on a January 1986=100 base.

The store total index covers all departments, including some not listed separately, except for the following: candy, foods, liquor, tobacco, and contract departments.

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 2044.—Certain Property

for Which Marital Deduction Was

Previously Allowed

26 CFR 20.2044–1T: Certain property for which

marital deduction was previously allowed (temporary).

T.D. 8714

DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 20

Estate and Gift Tax Marital

Deduction

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Temporary regulations.

SUMMARY: This document contains

temporary regulations amending the final estate tax marital deduction regulations. The amendments are made to

conform the estate tax regulations to

recent court decisions. The amendments

affect estates of decedents electing the

marital deduction for qualified terminable interest property (QTIP) and the

estates of the surviving spouses of such

decedents. The text of these temporary

regulations also serves as the text of

REG–209830–96, page 7.

DATES: These regulations are effective

February 18, 1997.

For dates of applicability of these

regulations, see Effective Date under

SUPPLEMENTARY INFORMATION.

FOR FURTHER INFORMATION

CONTACT: Susan B. Hurwitz at (202)

622–3090 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

On March 1, 1994, the IRS published

final Estate and Gift Tax Regulations

(26 CFR part 20 and part 25) under

sections 2044, 2056, 2207A, 2519,

2523, and 6019 of the Internal Revenue

Code (Code) in the Federal Register

(59 FR 9642). At the time the regulations were published, the position con-

tained in § 20.2056(b)–7(d)(3) was the

subject of litigation in a number of

cases and had been rejected by two

circuit courts in Estate of Clayton v.

Commissioner, 976 F.2d 1486 (5th Cir.

1992), rev’g 97 T.C. 327 (1991), and

Estate of Robertson v. Commissioner, 15

F.3d 779 (8th Cir. 1994), rev’g 98 T.C.

678 (1992). Since that time, Estate of

Spencer v. Commissioner, 43 F.3d 226

(6th Cir. 1995), rev’g T.C. Memo.l

1992–579, also rejecting the IRS position, has been decided. Additionally, in

Estate of Clack v. Commissioner, 106

T.C. 131 (1996), the Tax Court reversed

the position it had taken previously in

Estate of Clayton, Estate of Robertson,

and Estate of Spencer. This temporary

regulation amends the final regulations

in accordance with the circuit courts’

decisions in Estate of Clayton, Estate of

Robertson, and Estate of Spencer, and

the Tax Court’s decision in Estate of

Clack.

Explanation of Provisions

Section 20.2056(b)–7T(d)(3)(ii) has

been added. As a result of the addition,

an income interest (or life estate) that is

contingent upon the executor’s election

under section 2056(b)(7)(B)(v) will not

be precluded, on that basis, from qualification as a ‘‘qualifying income interest

for life’’ within the meaning of section

2056(b)(7)(B)(ii).

In accordance with the addition of

§ 20.2056(b)–7T(d)(3)(ii),

§ 20.2056(b)–7T(h) Example 6(ii) and

§ 20.2044–1T Example 8 are added.

Effective Date

These regulations are effective in the

case of qualified terminable interest

property elections made after February

18, 1997.

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) does

not apply to these regulations and, because these regulations do not impose

on small entities a collection of information requirement, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not

apply. Therefore, a Regulatory Flexibility Analysis is not required. Pursuant to

section 7805(f) of the Internal Revenue

Code, these temporary regulations will

be submitted to the Chief Counsel for

Advocacy of the Small Business Administration for comment on their impact on

small business.

Drafting Information

The principal author of these regulations is Susan B. Hurwitz, Office of

Assistant Chief Counsel (Passthroughs

and Special Industries). However, other

personnel from the IRS and Treasury

Department participated in their development.

Adoption of Amendments to the Regulations

Accordingly, 26 CFR part 20 is

amended as follows:

PART 20—ESTATE TAX; ESTATES

OF DECEDENTS DYING AFTER AUGUST 16, 1954

Paragraph 1. The authority citation

for part 20 continues to read in part as

follows:

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

Par. 2. Section 20.2044–1T is added

to read as follows:

§ 20.2044–1T Certain property for

which marital deduction was previously

allowed (temporary).

(a) through (d). [Reserved]. For further guidance, see § 20.2044–1(a)

through (d).

(e) Examples. [Reserved]. For further

guidance, see § 20.2044–1(e).

Example 1 through Example 7. [Reserved]. For further guidance, see

§ 20.2044–1(e) Example 1 through Example 7.

Example 8. Inclusion of trust property when

surviving spouse dies before first decedent’s estate

tax return is filed. D dies on July 1, 1997. D’s

estate tax return is due after February 18, 1997.

Under the terms of D’s will, a trust is established

for the benefit of D’s spouse, S. The will provides

that S is entitled to receive the income from that

portion of the trust that the executor elects to treat

as qualified terminable interest property. The trust

terms otherwise provide S with a qualifying

income interest for life under section

2056(b)(7)(B)(ii). S dies on February 10, 1998. On

April 1, 1998, D’s executor files D’s estate tax

return on which an election is made to treat a

portion of the trust as qualified terminable interest

property under section 2056(b)(7). S’s estate tax

return is filed on November 10, 1998. The value

on the date of S’s death of the portion of the trust

for which D’s executor made a QTIP election is

includible in S’s gross estate under section 2044.

Par. 3. Section 20.2056(b)–7T is

added to read as follows:

§ 20.2056(b)–7T Election with respect

to life estate for surviving spouse (temporary).

(a) through (d)(2) [Reserved]. For

further guidance, see § 20.2056(b)–7(a)

through (d)(2).

(d)(3) Contingent income interests. (i)

[Reserved]. For further guidance, see

§ 20.2056(b)–7(d)(3).

(ii) An income interest for a term of

years, or a life estate subject to termination upon the occurrence of a specified

event (e.g., remarriage), is not a qualifying income interest for life. However, an

income interest for life (or life estate)

that is contingent upon the executor’s

election under section 2056(b)(7)(B)(v)

will not, on that basis, fail to be a

qualifying income interest for life. This

paragraph (d)(3)(ii) applies with respect

to estates of decedents whose estate tax

returns are due after February 18, 1997.

(d)(4) through (g) [Reserved]. For

further guidance see § 20.2056(b)–

7(d)(4) through (g).

(h) Examples. [Reserved]. See

§ 20.2056(b)–7(h).

Example 1 through Example 5. [Reserved]. For further guidance, see

§ 20.2056(b)–7(h) Example 1 through

Example 5.

Example 6. (i) [Reserved]. For further

guidance, see § 20.2056(b)–7(h) Example 6.

Par. 4. Section 20.2056(b)–10T is

added to read as follows:

(ii) D’s estate tax return is due after February

18, 1997. D’s will established a trust providing

that S is entitled to receive the income from that

portion of the trust that the executor elects to treat

as qualified terminable interest property. S’s interest in the trust otherwise meets the requirements

of a qualifying income interest for life under

section 2056(b)(7)(B)(ii). Accordingly, the executor may elect qualified terminable interest treatment for any portion of the trust.

Approved January 8, 1997.

§ 20.2056(b)–10T Effective dates (temporary).

In addition to the effective dates set

out in § 20.2056(b)–10, § 20.2056(b)–

7T(d)(3)(ii) is effective with respect to

estates of decedents dying after March

1, 1994. For further guidance, see

§ 20.2056(b)–10.

Margaret Milner Richardson,

Commissioner of Internal Revenue.

Donald C. Lubick,

Assistant Secretary of the Treasury.

(Filed by the Office of the Federal Register on

February 14, 1997, 8:45 a.m., and published in the

issue of the Federal Register for February 18,

1997, 62 F.R. 7156)

Part IV. Items of General Interest

Notice of Proposed Rulemaking

and Notice of Public Hearing

SUPPLEMENTARY

INFORMATION:

Estate and Gift Tax Marital

Deduction

Background

REG–209830–96

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Notice of proposed rulemaking by cross-reference to temporary

regulations and notice of public hearing.

SUMMARY: In T.D. 8714, page 5, the

IRS is issuing temporary regulations

relating to the estate tax marital deduction to conform the Estate Tax Regulations to recent court decisions. The text

of those temporary regulations also

serves as the text of these proposed

regulations. This document also provides

notice of a public hearing on these

proposed regulations.

DATES: Comments must be received by

May 19, 1997. Outlines of topics to be

discussed at the public hearing scheduled for June 3, 1997, at 10 a.m. must

be received by May 13, 1997.

ADDRESSES: Send submissions to:

CC:DOM:CORP:R (REG–209830–96),

room 5228, Internal Revenue Service,

POB 7604, Ben Franklin Station, Washington, DC 20044. Submissions may

also be hand delivered between the

hours of 8 a.m. and 5 p.m. to:

CC:DOM:CORP:R (REG–209830–96),

Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue NW,

Washington, DC. Alternatively, taxpayers may submit comments electronically

via the internet by selecting the ‘‘Tax

Regs’’ option on the IRS Home Page, or

by submitting comments directly to the

IRS internet site at http://www.irs.

ustreas.gov/prod/tax regs/comments.

html. The public hearing will be held in

the Commissioner’s Conference Room,

room 3313, Internal Revenue Building,

1111 Constitution Avenue NW, Washington, DC.

FOR FURTHER INFORMATION CONTACT: Concerning the regulations, Susan B. Hurwitz, (202) 622–3090; concerning submissions and the hearing,

Evangelista Lee, (202) 622–7190 (not

toll-free numbers).

Temporary regulations in T.D. 8714

amend the Estate Tax Regulations (26

CFR part 20) relating to sections 2044

and 2056. The temporary regulations

conform the estate tax marital deduction

regulations to recent court decisions in

Estate of Clayton v. Commissioner, 976

F.2d 1486 (5th Cir. 1992), rev’g 97 T.C.

327 (1991); Estate of Robertson v. Commissioner, 15 F.3d 779 (8th Cir. 1994),

rev’g 98 T.C. 678 (1992); Estate of

Spencer v. Commissioner, 43 F.3d 226

(6th Cir. 1995), rev’g T.C. Memo. 1992–

579; and Estate of Clack v. Commissioner, 106 T.C. 131 (1996).

The text of those temporary regulations also serves as the text of these

proposed regulations. The preamble to

the temporary regulations explains the

temporary regulations.

Special Analyses

It has been determined that this notice

of proposed rulemaking 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) does not apply to these

regulations and, because these regulations do not impose on small entities a

collection of information requirement,

the Regulatory Flexibility Act (5 U.S.C.

chapter 6) does not apply. Therefore, a

Regulatory Flexibility Analysis is not

required. Pursuant to section 7805(f) of

the Internal Revenue Code, this notice

of proposed rulemaking will be submitted to the Chief Counsel for Advocacy

of the Small Business Administration for

comment on its impact on small business.

Comments and Public Hearing

Before these proposed regulations are

adopted as final regulations, consideration will be given to any comments

that are submitted timely (in the manner

described in ADDRESSES) to the IRS.

All comments will be available for

public inspection and copying.

A public hearing has been scheduled

for June 3, 1997, at 10 a.m. in the

Commissioner’s Conference Room,

room 3313, Internal Revenue Building,

1111 Constitution Avenue NW, Washing-

ton, DC. Because of access restrictions,

visitors will not be admitted beyond the

building lobby more than 15 minutes

before the hearing starts.

The rules of 26 CFR 601.601(a)(3)

apply to the hearing.

Persons that wish to present oral

comments at the hearing must submit

comments by May 19, 1997, and submit

an outline of the topics to be discussed

and the time to be devoted to each topic

by May 13, 1997.

A period of 10 minutes will be allotted to each person for making comments.

An agenda showing the scheduling of

the speakers will be prepared after the

deadline for receiving outlines has

passed. Copies of the agenda will be

available free of charge at the hearing.

Drafting Information

The principal author of the proposed

regulations is Susan B. Hurwitz, Office

Assistant

Chief

Counsel

(Passthroughs and Special Industries).

However, other personnel from the IRS

and the Treasury Department participated in their development.

Proposed Amendments to the Regulations

Accordingly, 26 CFR part 20 is proposed to be amended as follows:

PART 20—ESTATE TAX; ESTATES

OF DECEDENTS DYING AFTER AUGUST 16, 1954

Paragraph 1. The authority citation for

part 20 continues to read in part as

follows:

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

Par. 2. In § 20.2044–1, paragraph (e)

Example 8 is added to read as follows:

§ 20.2044–1 Certain property for which

marital deduction was previously allowed.

[The text of paragraph (e) Example 8

as proposed is the same as the text of

§ 20.2044–1T(e) Example 8 published

inT.D. 8714].

Par. 3. Section 20.2056(b)–7 is

amended to read as follows:

§ 20.2056(b)–7 Election with respect to

life estate for surviving spouse.

[The text of paragraphs (d)(3), and (h)

Example 6 is the same as the text of

1997–15

I.R.B.

§ 20.2056(b)–7T(d)(3)(ii), and (h) Example 6 published in T.D. 8714].

Par. 4. Section 20.2056(b)–10 is revised to read as follows:

§ 20.2056(b)–10 Effective dates.

Except as specifically provided in

§§ 20.2056(b)–5(c)(3)(ii) and (iii),

20.2056(b)–7T(d)(3), 20.2056(b)–7(e)(5), and 20.2056(b)–8(b), the provisions

of §§ 20.2056(b)–5(c), 20.2056(b)–7,

20.2056(b)–8, and 20.2056(b)–9 are effective with respect to estates of decedents dying after March 1, 1994. With

respect to decedents dying on or before

March 1, 1994, the executor of the

decedent’s estate may rely on any reasonable interpretation of the statutory

provisions. For these purposes, the provisions

§§ 20.2056(b)–5(c),

20.2056(b)–7, 20.2056(b)–8, and

20.2056(b)–9 (as well as project LR–

211–76 (1984–1 C.B. 598), see

§ 601.601(d)(2)(ii)(b) of this chapter),

are considered a reasonable interpretation of the statutory provisions.

Margaret Milner Richardson,

Commissioner of Internal Revenue.

(Filed by the Office of the Federal Register on

February 14, 1997, 8:45 a.m., and published in the

issue of the Federal Register for February 18,

1997, 62 F.R. 7156)

SUPPLEMENTARY

INFORMATION:

Background

The final regulations that are the

subject of this correction are under

section 902 of the Internal Revenue

Code. Need for Correction

As published, the final regulations

contain an error which may prove to be

misleading and is in need of clarification.

Correction of Publication

Accordingly, the publication of the

final regulations (TD 8708), which are

the subject of FR Doc. 97–153, is

corrected as follows:

On page 940, column 3, § 1.902–3

(l), the sixth line from the bottom of the

paragraph, the language ‘‘See § 1.902–1

(a)(13)(iii). For’’ is corrected to read

‘‘See § 1.902–1 (a)(13)(i). For’’.

Michael L. Slaughter,

Acting Chief, Regulations Unit,

Assistant Chief Counsel (Corporate).

(Filed by the Office of the Federal Register on

February 14, 1997, 8:45 a.m., and published in the

issue of the Federal Register for February 18,

1997, 62 F.R. 7155)

Foundations Status of Certain

Organizations

Announcement 97–34

Computation of Foreign Taxes

Deemed Paid Under Section 902

Pursuant to a Pooling Mechanism

for Undistributed Earnings and

Foreign Taxes; Correction

Announcement 97–33

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Correction to final regulations.

SUMMARY: This document contains a

correction to final income tax regulations which were published in the Federal Register on Tuesday, January 7,

1997 (62 FR 923 [T.D. 8708, 1997–10

I.R.B. 14]) relating to the computation

of foreign taxes deemed paid under

section 902.

EFFECTIVE DATE: January 7, 1997.

FOR FURTHER INFORMATION CONTACT: Caren S. Shein (202) 622–3850,

(not a toll-free number).

1997–15

I.R.B.

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:

Arizona Conservation Alliance, Phoenix,

Arizona Womens Retreat, Scottsdale, AZ

Arkansas Child Care Consultant Inc.,

Ashdown, AR

Arthur Jones Memorial Center, Houston,

Artsake Foundation, Tucson, AZ

Bridgebuilders International, Inc., Mesa,

Bright Hopes Foundation, Albuquerque,

Brookstone Human Development Project

Inc., Randleman, NC

Boulder Youth Choir, Boulder, CO

Boys & Girls Club of El Campo Texas,

Inc., El Campo, TX

Childrens Choice Daycare, Ogden, UT

Childrens Fund, Inc., Fort Collins, CO

Childrens Lifeline Network, Houston,

Childrens Treasure Chest, Wichita Falls,

Children United To Save the Planet,

Phoenix, AZ

Desert Hope Inc., Chandler, AZ

Diadem Evangelistic Association Inc.,

Euless, TX

Family Connection, Chester, PA

Fare Share, Inc., Kingston, NY

Fil Am Friendship Coalition,

Framingham, MA

Gallery X, Inc., New Bedford, MA

Gay Info Line of New Hampshire,

Nashua, NH

Genesis 3 Inc., Coffeyville, KS

Harvest International Missions, Inc.,

Dallas, TX

Harvest Ministries International Inc.,

Dallas, TX

Head Injury Events, Carr, CO

Healthy Mothers Healthy Babies Austin

Chapter, Austin, TX

Heart at Home Inc., Austin, TX

Imagination Central, Venice, CA

In Celebration of Life, Santa Rosa, CA

Indian Diggings Volunteer Club,

Somerset, CA

Infection Control Nurses of Connecticut,

Inc., Hamden, CT

In His Service Foundation, Inc., Dallas,

Jail Industries Association, Wakefield,

Jesus & Me Ministries Inc., Colorado

Springs, CO

John A. Reisenback Foundation, Inc.,

New York, NY

John’s Place, Dorchester, MA

Kimball Pines Non-Profit Housing

Corporation, Battle Creek, MI

Kindred Spirit Pictures Inc., Hilton

Head Is, SC

Kingwood Heartbeat Bears, Kingwood,

Las Vegas Development Corporation

LaVedelco, Las Vegas, NM

Linden Firefighters Association, Linden,

Lion and Lamb Edu-Cable, Inc.,

Englewood, CO

Martin Luther King Jr Center for

Nonviolence, Los Angeles, CA

Menezes Group Homes Inc., San

Leandro, CA

Metro Outreach Ministry, Baton Rouge,

Metropolitan Canal Alliance, Inc.,

Tempe, AZ

Mid-Cities Swim Team, Euless, TX

Mid-Kansas Bandits Soccer Club,

Wichita, KS

Missing Link Inc., Tulsa, OK

Native American Cultural Museum Inc.,

Grants, NM

Neighbours International, Wyoming, MI

New Mexico State University Dance

Company, Las Cruces, NM

North County Educational Assistance

Program, NCEAP, Sarasota, FL

Northern Children Network Inc.,

Philadelphia, PA

Orange Avenue Home, Newport Beach,

Oregon Wheelchair Tennis Association,

Portland, OR

Original Kids Under Construction, Inc.,

Anderson, IN

Organization of Professional Emp. of

the US Dept of Argic Opeda

Scholarship Fund, Washington, DC

Our Gang Players Inc., Barnegat Light,

Parents Against Gangs Education Inc.,

Pueblo, CO

Partners for the Educational

Enhancement Daleville Schools Inc.,

Daleville, AL

Partners in the Community, Kelso, WA

Partners in the Environment Inc.,

Lorton, VA

Pastoral Training of Asia Inc., El Toro,

Pathway to Power Ministries Inc.,

Newark, NJ

Patient Services Inc., Midlothian, VA

PCMSP Housing Corporation,

Pittsburgh, PA

Pearce Outreach International, Rockwall,

Pedro Farela, Falls Church, VA

R and R Residential Homes, Sylmar,

Reflective Image, San Francisco, CA

Renaissance Consort of Ft Worth Inc.,

Ft. Worth, TX

Rescue Our Children Mission, Dallas,

Resurrection Ministries, Inc., Tulsa, OK

South Georgia Nazarene Christian Day

Care, Amarillo, TX

Southside Fire Truck Park Fund,

Houston, TX

South Texas Alcohol and Drug

Rehabilitation Center, Inc., Alice, TX

South Texas Classic Guitar Society, Inc.,

McAllen, TX

Southwest Correctional Arts Network,

Austin, TX

Stop Wasting Americas Taxes, Inc.,

Tulsa, OK

Strawberry Patch Kids, Inc., Layton, UT

Street Intervention Project, Denver, CO

Success Nutrition Food Program,

Houston, TX

Sudden Arrhythmia Death Syndromes

Foundation, Salt Lake City, UT

Theatre for Texas Youth, Inc., Dallas,

Thornton Arts Sciences and Humanities

Council, Inc., Thornton, CO

Tickets to Paradise Inc., Miami, FL

Urban Assisted Housing Coalition, Inc.,

San Francisco, CA

Urban Health Alliance, Inc., San

Francisco, CA

Urban Theatre Project Inc., Denver, CO

U S-Japan Institute of Management and

Technology, Dallas, TX

Vision for Children International

Foundation, Inc., Salt Lake City, UT

Vision 100, Lewisville, TX

Vital Alliance, San Antonio, TX

Wisdom Communications UTH,

Columbus, OH

W L D Johnson Scholarship Foundation,

Dallas, TX

Womens Sanctuary, Denver, CO

Wood County Casa, Inc., Winnsboro,

World Vista Foundation Inc., Bay

Village, OH

If an organization listed above submits information that warrants the renewal of its classification as a public

charity or as a private operating foundation, the Internal Revenue Service will

issue a ruling or determination letter

with the revised classification as to

foundation status. Grantors and contributors may thereafter rely upon such ruling or determination letter as provided

in section 1.509(a)–7 of the Income Tax

Regulations. It is not the practice of the

Service to announce such revised classification of foundation status in the Internal Revenue Bulletin.

Definition of Limited Partner for

Self-Employment Tax Purposes;

Hearing

Announcement 97–35

AGENCY: Internal Revenue Service,

Treasury.

ACTION: Proposed rule; change of location of public hearing.

SUMMARY: This document changes

the location of the public hearing on

proposed regulations relating to the selfemployment income tax imposed under

section 1402 of the Internal Revenue

Code of 1986.

DATES: The public hearing is being

held on Wednesday, May 21, 1997,

beginning at 10:00 a.m. Requests to

speak and outlines of oral comments

must be received by April 30, 1997.

ADDRESSES: The public hearing originally scheduled in the IRS Auditorium,

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

changed to room 5716, Internal Revenue

Building, 1111 Constitution Avenue NW,

Washington, DC.

FOR FURTHER INFORMATION

CONTACT: Christina Vasquez of the

Regulations Unit, Assistant Chief Counsel (Corporate), (202) 622–7180 (not a

toll-free number).

SUPPLEMENTARY INFORMATION:

A notice of proposed rulemaking and

notice of public hearing appearing in the

Federal Register on Monday, January

13, 1997 (62 FR 1702 [REG–209824–

96, 1996–11 I.R.B. 19]) announced that

a public hearing on proposed regulations

relating to the self-employment income

tax imposed under section 1402 of the

Internal Revenue Code of 1986 would

be held on Wednesday, May 21, 1997,

beginning at 10:00 a.m. in the IRS

Auditorium, Internal Revenue Building,

1111 Constitution Avenue NW, Washington, DC and that requests to speak and

outlines of oral comments should be

received by Wednesday, April 30, 1997.

The location of the pubic hearing has

changed. The hearing is scheduled for

Wednesday, May 21, 1997, beginning at

10:00 a.m. in room 5716, Internal Revenue Building, 1111 Constitution Avenue

NW, Washington, DC. We must receive

the requests to speak and outlines of

oral comments by Wednesday, April 30,

1997. Because of controlled access restrictions, attenders are not admitted

beyond the lobby of the Internal Revenue Building until 9:45 a.m.

The Service will prepare an agenda

showing the scheduling of the speakers

after the outlines are received from the

1997–15

I.R.B.

persons testifying and make copies

available free of charge at the hearing.

each’’ is corrected to read ‘‘taxable year

or years of inclusion of each’’.

Cynthia E. Grigsby,

Chief, Regulations Unit,

Assistant Chief Counsel (Corporate).

Michael L. Slaughter,

Acting Chief, Regulations Unit,

Assistant Chief Counsel (Corporate).

(Filed by the Office of the Federal Register on

March 11, 1997, 8:45 a.m., and published in the

issue of the Federal Register for March 12, 1997,

62 F.R. 11394)

(Filed by the Office of the Federal Register on

February 14, 1997, 8:45 a.m., and published in the

issue of the Federal Register for February 18,

1997, 62 F.R. 7155)

Treatment of Shareholders of

Certain Passive Foreign Investment

Companies; Correction

Treatment of Obligation-Shifting

Transactions; Hearing

Announcement 97–37

Announcement 97–36

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Correction to final regulations.

SUMMARY: This document contains a

correction to final regulations (T.D.

8701 [1997–7 I.R.B. 23]) which were

published in the Federal Register on

Friday, December 27, 1996 (61 FR

68149). The final regulations provide

rules for making a deemed sale or

deemed dividend election to purge a

shareholder’s holding period of stock of

a PFIC of those taxable years during

which the PFIC was not a QEF.

EFFECTIVE DATE: December 27,

1996.

FOR FURTHER INFORMATION

CONTACT: Gayle Novig (202) 622–

3880 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final regulations that are subject

to this correction is under section 1291

of the Internal Revenue Code.

Need for Correction

As published, the final regulations

(T.D. 8701) contains an error that may

prove to be misleading and is in need of

clarification.

Correction of Publication

Accordingly, the publication of final

and temporary regulations (T.D. 8701)

which is the subject of FR Doc. 96–

32246 is corrected as follows:

§ 1.1291–9 [Corrected]

On page 68152, column 3, § 1.1291–

9, paragraph (d)(2)(i), line 9, the language ‘‘taxable year of inclusion of

1997–15

I.R.B.

AGENCY: Internal Revenue Service,

Treasury.

ACTION: Proposed rule; change of date

and location of public hearing.

SUMMARY: This document changes

the date and location of the public

hearing on proposed regulations relating

to the treatment of certain multiple-party

financing transactions in which one

party realizes income from leases or

similar agreements and another party

claims deductions related to that income.

DATES: The public hearing is being

held on Wednesday, May 14, 1997,

beginning at 10:00 a.m. Requests to

speak and outlines of oral comments

must be received by April 23, 1997.

ADDRESSES: The public hearing originally scheduled in the IRS Auditorium,

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

changed to room 2615, Internal Revenue

Building, 1111 Constitution Avenue NW,

Washington, DC.

FOR FURTHER INFORMATION

CONTACT: Christina Vasquez of the

Regulations Unit, Assistant Chief Counsel (Corporate), (202) 622–7180 (not a

toll-free number).

SUPPLEMENTARY INFORMATION:

A notice of proposed rulemaking and

notice of public hearing appearing in the

Federal Register on Friday, December

27, 1996 (61 FR 68175 [REG–209817–

96, 1997–7 I.R.B. 41]), announced that

a public hearing on proposed regulations

relating to the treatment of certain

multiple-party financing transactions in

which one party realizes income from

leases or similar agreements and another

party claims deductions related to that

income would be held on Tuesday, April

29, 1997, beginning at 10:00 a.m. in the

IRS Auditorium, Internal Revenue

Building, 1111 Constitution Avenue NW,

Washington, DC and that requests to

speak and outlines of oral comments

should be received by Tuesday, April 8,

1997.

The date and location of the pubic

hearing has changed. The hearing is

scheduled for Wednesday, May 14,

1997, beginning at 10:00 a.m. in room

2615, Internal Revenue Building, 1111

Constitution Avenue NW, Washington,

DC. We must receive the requests to

speak and outlines of oral comments by

Wednesday, April 23, 1997. Because of

controlled access restrictions, attenders

are not admitted beyond the lobby of

the Internal Revenue Building until 9:45

a.m.

The Service will prepare an agenda

showing the scheduling of the speakers

after the outlines are received from the

persons testifying and make copies

available free of charge at the hearing.

Cynthia E. Grigsby,

Chief, Regulations Unit,

Assistant Chief Counsel (Corporate).

(Filed by the Office of the Federal Register on

February 4, 1997, 8:45 a.m., and published in the

issue of the Federal Register for February 5, 1997,

62 F.R. 5355)

Reissuance of Mortgage Credit

Certificates; Correction

Announcement 97–38

AGENCY: Internal Revenue Service,

Treasury.

ACTION: Correction to the final and

temporary regulations.

SUMMARY: This document contains a

correction to the final and temporary

regulations (T.D. 8692 [1997–3 I.R.B.

4]) which were published in the Federal

1996 (61 FR 66212). The final and

temporary regulations relates to the reissuance of mortgage credit certificates.

EFFECTIVE DATE: December 17,

1996.

FOR FURTHER INFORMATION

CONTACT: Michael Wachtel, (202)

622–3980 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final and temporary regulations

that is subject to this correction is under

section 25 of the Internal Revenue

Code.

Need for Correction

As published, the final and temporary

regulations (T.D. 8692) contains an error

which may prove to be misleading and

is in need of clarification.

Correction of Publication

Accordingly, the publication of the

final and temporary regulations (T.D.

8692) which is the subject of FR Doc.

96–31772 is corrected as follows:

On page 66212, column 3, in the

heading, the RIN ‘‘RIN 1545–AR57’’ is

corrected to read ‘‘RIN 1545–AR76’’.

Cynthia E. Grigsby,

Chief, Regulations Unit,

Assistant Chief Counsel (Corporate).

(Filed by the Office of the Federal Register on

February 13, 1997, 8:45 a.m., and published in the

issue of the Federal Register for February 14,

1997, 62 F.R. 6874)

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 pe-

riod 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.

Spartanburg Gospel Workshop, Inc.

Spartanburg, SC

1997–15

I.R.B.

Announcement of the Disbarment, Suspension, or Consent to Voluntary

Suspension of Attorneys, Certified Public Accountants, Enrolled Agents and

Enrolled Actuaries From Practice Before the Internal Revenue Service

Under 31 Code of Federal Regulations, Part 10, an attorney, certified public accountant, enrolled agent or enrolled

actuary, in order to avoid the institution

or conclusion of a proceeding for his

disbarment or suspension from practice

before the Internal Revenue Service,

may offer his consent to suspension

from such practice. The Director of

Practice, in his discretion, may suspend

an attorney, certified public accountant,

enrolled agent or enrolled actuary in

accordance with the consent offered.

Attorneys, certified public accountants, enrolled agents and enrolled actuaries are prohibited in any Internal Rev-

enue Service matter from directly or

indirectly employing, accepting assistance from, being employed by or sharing fees with, any practitioner disbarred

or suspended from practice before the

Internal Revenue Service.

To enable attorneys, certified public

accountants, enrolled agents and enrolled actuaries to identify practitioners

under consent suspension from practice

before the Internal Revenue Service, the

Director of Practice will announce in the

Internal Revenue Bulletin the names and

addresses of practitioners who have

been suspended from such practice, their

designation as attorney, certified public

accountant, enrolled agent or enrolled

actuary, and date or period of suspension. This announcement will appear in

the weekly Bulletin at the earliest practicable date after such action and will

continue to appear in the weekly Bulletins for five successive weeks or for as

many weeks as is practicable for each

attorney, certified public accountant, enrolled agent or enrolled actuary so suspended and will be consolidated and

published in the Cumulative Bulletin.

The following individuals have been

placed under consent suspension from

practice before the Internal Revenue

Service:

Name

Address

Designation

Date of Suspension

Vlymen, Neal Van

Lombardi, Theresa

Orfall, Warren

San Diego, CA

Livonia, MI

Hood River, OR

CPA

Indefinite from November 1, 1996

November 1, 1996 to October 31, 1998

November 1, 1996 to June 30, 1997

Oberman, Joseph

Gazzola, Frank

Tumminello, Anthony G.

Highland Park, IL

N. Mankato, MN

St. Louis, MO

CPA

Attorney

December 1, 1996 to August 31, 1997

December 1, 1996 to November 30, 1997

December 17, 1996 to June 16, 1997

Heffelfinger, Harry N.

Zintl Jr., Ernst J.

Alms, William R.

Smith, Arthur L.

DeGroote Sr., Kevin J.

Oliveri, Robert

Buffalo Grove, IL

Newport, MN

Lake Forest, CA

Athens, GA

Mesa, AZ

Bensalem, PA

CPA

December 20, 1996 to June 19, 1998

December 23, 1996 to December 22, 1997

January 1, 1997 to March 31, 1997

January 1, 1997 to December 31, 1997

January 1, 1997 to October 31, 1997

January 1, 1997 to December 31, 1997

Davies, Preston S.

Elbert, David L.

Deerfield, IL

Franktown, CO

CPA

January 15, 1997 to December 14, 1997

Indefinite from January 21, 1997

Smith Jr., Phillip M.

Pennington, Richard A.

Tameron, Joseph A.

Kalb, Mary C.

Pritchard, John J.

Long Beach, CA

Vandergrift, PA

Chandler, AZ

Kearny, NE

San Diego, CA

Attorney

CPA

Enrolled Agent

February 1, 1997 to March 31, 1997

February 1, 1997 to January 31, 2000

February 1, 1997 to September 30, 1998

February 1, 1997 to March 31, 1997

Garrett, Richard

Englert, Larry R.

Torrance, GA

Eaton, OH

Enrolled Agent

CPA

March 1, 1997 to May 30, 1997

April 1, 1997 to May 30, 1997

Numerical Finding List1

Bulletin 1997–1 through 1997–14

Announcements:

97–1, 1997–2 I.R.B. 63

97–2, 1997–2 I.R.B. 63

97–3, 1997–2 I.R.B. 63

97–4, 1997–3 I.R.B. 14

97–5, 1997–3 I.R.B. 15

97–6, 1997–4 I.R.B. 11

97–7, 1997–4 I.R.B. 12

97–8, 1997–4 I.R.B. 12

97–9, 1997–5 I.R.B. 27

97–10, 1997–10 I.R.B. 64

97–11, 1997–6 I.R.B. 19

97–12, 1997–7 I.R.B. 55

97–13, 1997–8 I.R.B. 38

97–14, 1997–8 I.R.B. 38

97–15, 1997–9 I.R.B. 23

97–16, 1997–9 I.R.B. 23

97–17, 1997–9 I.R.B. 23

97–18, 1997–10 I.R.B. 67

97–19, 1997–10 I.R.B. 68

97–20, 1997–11 I.R.B. 22

97–21, 1997–11 I.R.B. 23

97–22, 1997–12 I.R.B. 47

97–23, 1997–11 I.R.B. 23

97–24, 1997–11 I.R.B. 24

97–25, 1997–12 I.R.B. 47

97–26, 1997–12 I.R.B. 48

97–27, 1997–13 I.R.B. 30

97–28, 1997–14 I.R.B. 15

97–29, 1997–14 I.R.B. 16

97–30, 1997–14 I.R.B. 16

97–31, 1997–14 I.R.B. 16

97–32, 1997–14 I.R.B. 17

Notices:

97–1, 1997–2 I.R.B. 22

97–2, 1997–2 I.R.B. 22

97–3, 1997–1 I.R.B. 8

97–4, 1997–2 I.R.B. 24

97–5, 1997–2 I.R.B. 25

97–6, 1997–2 I.R.B. 26

97–7, 1997–1 I.R.B. 8

97–8, 1997–4 I.R.B. 7

97–9, 1997–2 I.R.B. 35

97–10, 1997–2 I.R.B. 41

97–11, 1997–2 I.R.B. 50

97–12, 1997–3 I.R.B. 11

97–13, 1997–6 I.R.B. 13

97–14, 1997–8 I.R.B. 23

97–15, 1997–8 I.R.B. 23

97–16, 1997–9 I.R.B. 15

97–17, 1997–10 I.R.B. 34

97–18, 1997–10 I.R.B. 35

97–19, 1997–10 I.R.B. 40

97–20, 1997–10 I.R.B. 52

97–21, 1997–11 I.R.B. 9

97–22, 1997–13 I.R.B. 9

97–23, 1997–14 I.R.B. 8

Proposed Regulations:

REG–209332–80, 1997–14 I.R.B. 9

REG–209040–88, 1997–7 I.R.B. 34

REG–209121–89, 1997–11 I.R.B. 15

REG–208288–90, 1997–11 I.R.B. 14

REG–209494–90, 1997–8 I.R.B. 24

Proposed Regulations—Continued

Treasury Decisions—Continued

REG–208172–91, 1997–10 I.R.B. 59

REG–209672–93, 1997–6 I.R.B. 15

REG–209709–94 1997–13 I.R.B. 12

REG–209729–94, 1997–11 I.R.B. 19

REG–209762–95, 1997–3 I.R.B. 12

REG–209817–96, 1997–7 I.R.B. 41

REG–209824–96, 1997–11 I.R.B. 19

REG–254394–96, 1997–14 I.R.B. 14

REG–209828–96, 1997–6 I.R.B. 15

REG–209834–96, 1997–4 I.R.B. 9

REG–209839–96, 1997–8 I.R.B. 26

REG–242996–96, 1997–9 I.R.B. 18

REG–246018–96, 1997–8 I.R.B. 30

REG–247678–96, 1997–6 I.R.B. 17

REG–247862–96, 1997–8 I.R.B. 32

REG–248770–96, 1997–8 I.R.B. 33

REG–249819–96, 1997–7 I.R.B. 50

REG–252231–96, 1997–7 I.R.B. 52

REG–252233–96, 1997–9 I.R.B. 19

REG–252665–96, 1997–12 I.R.B. 46

8693, 1997–6 I.R.B. 9

8694, 1997–6 I.R.B. 11

8695, 1997–4 I.R.B. 5

8696, 1997–6 I.R.B. 4

8697, 1997–2 I.R.B. 11

8698, 1997–7 I.R.B. 29

8699, 1997–6 I.R.B. 4

8700, 1997–7 I.R.B. 5

8701, 1997–7 I.R.B. 23

8702, 1997–8 I.R.B. 4

8703, 1997–8 I.R.B. 18

8704, 1997–8 I.R.B. 12

8705, 1997–8 I.R.B. 16

8706, 1997–9 I.R.B. 11

8707, 1997–7 I.R.B. 17

8708, 1997–10 I.R.B. 14

8709, 1997–9 I.R.B. 5

8710, 1997–13 I.R.B. 4

8711, 1997–12 I.R.B. 35

8712, 1997–12 I.R.B. 4

8713, 1997–14 I.R.B. 4

Revenue Procedures:

97–1, 1997–1 I.R.B. 11

97–2, 1997–1 I.R.B. 64

97–3, 1997–1 I.R.B. 84

97–4, 1997–1 I.R.B. 96

97–5, 1997–1 I.R.B. 132

97–6, 1997–1 I.R.B. 153

97–7, 1997–1 I.R.B. 185

97–8, 1997–1 I.R.B. 187

97–9, 1997–2 I.R.B. 56

97–10, 1997–2 I.R.B. 59

97–11, 1997–6 I.R.B. 13

97–12, 1997–4 I.R.B. 7

97–13, 1997–5 I.R.B. 18

97–14, 1997–5 I.R.B. 20

97–15, 1997–5 I.R.B. 21

97–16, 1997–5 I.R.B. 25

97–17, 1997–9 I.R.B. 15

97–18, 1997–10 I.R.B. 53

97–19, 1997–10 I.R.B. 55

97–20, 1997–11 I.R.B. 10

97–21, 1997–12 I.R.B. 44

97–22, 1997–13 I.R.B. 9

Revenue Rulings:

97–1, 1997–2 I.R.B. 10

97–2, 1997–2 I.R.B. 7

97–3, 1997–2 I.R.B. 5

97–4, 1997–3 I.R.B. 6

97–5, 1997–4 I.R.B. 5

97–6, 1997–4 I.R.B. 4

97–7, 1997–5 I.R.B. 14

97–8, 1997–7 I.R.B. 4

97–9, 1997–9 I.R.B. 4

97–10, 1997–10 I.R.B. 31

97–11, 1997–10 I.R.B. 5

97–12, 1997–11 I.R.B. 5

97–14, 1997–11 I.R.B. 5

97–15, 1997–12 I.R.B. 42

97–16, 1997–13 I.R.B. 4

97–17, 1997–14 I.R.B. 5

Social Security Domestic Coverage Threshold

1997–9, I.R.B. 17

Treasury Decisions:

8688, 1997–3 I.R.B. 7

8689, 1997–3 I.R.B. 9

8690, 1997–5 I.R.B. 5

8691, 1997–5 I.R.B. 16

8692, 1997–3 I.R.B. 4

A cumulative list of all Revenue Rulings,

Revenue Procedures, Treasury Decisions, etc.,

published in Internal Revenue Bulletins 1996–27

through 1996–53 will be found in Internal

Revenue Bulletin 1997–1, dated January 6, 1997.

Finding List of Current Action on

Previously Published Items1

Bulletin 1997–1 through 1997–14

Revenue Rulings—Continued

74–59

Revoked by

8708, 1997–10 I.R.B. 14

Revenue Procedures:

92–19

Supplemented in part by

97–2, 1997–2 I.R.B. 7

66–3

Modified by

97–11, 1997–6 I.R.B. 13

96–12

Superseded by

97–3, 1997–1 I.R.B. 84

*Denotes entry since last publication

87–21

Modified by

97–11, 1997–6 I.R.B. 13

92–20

Modified by

97–1, 1997–1 I.R.B. 11

92–20

Modified by

97–10, 1997–2 I.R.B. 59

92–90

Superseded by

97–1, 1997–1 I.R.B. 11

94–52

Revoked by

97–11, 1997–6 I.R.B. 13

96–1

Superseded by

97–1, 1997–1 I.R.B. 11

96–13

Modified by

97–1, 1997–1 I.R.B. 11

96–22

Superseded by

97–3, 1997–1 I.R.B. 84

96–34

Superseded by

97–3, 1997–1 I.R.B. 84

96–39

Superseded by

97–3, 1997–1 I.R.B. 84

96–43

Superseded by

97–3, 1997–1 I.R.B. 84

96–56

Superseded by

97–3, 1997–1 I.R.B. 84

96–2

Superseded by

97–2, 1997–1 I.R.B. 64

96–3

Superseded by

97–3, 1997–1 I.R.B. 84

96–4

Superseded by

97–4, 1997–1 I.R.B. 96

96–5

Superseded by

97–5, 1997–1 I.R.B. 132

96–6

Superseded by

97–6, 1997–1 I.R.B. 153

96–7

Superseded by

97–7, 1997–1 I.R.B. 185

96–8

Superseded by

97–8, 1997–1 I.R.B. 187

97–2

Amplified by

97–21, 1997–12 I.R.B. 44

Revenue Rulings:

70–480

Revoked by

97–6, 1997–4 I.R.B. 4

72–527

Obsoleted by

8704, 1997–8 I.R.B. 12

A cumulative finding list for previously published

items mentioned in Internal Revenue Bulletins

1996–27 through 1996–53 will be found in Internal Revenue Bulletin 1997–1, dated January 6,

1997.

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.