Bulletin No. 1999–18

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Page 1

Bulletin No. 1999–18

May 3, 1999

Internal Revenue

bulletin

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

ESTATE TAX

Rev. Rul. 99–21, page 3.

Rev. Rul. 99–20, page 5.

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 May 1999.

EXEMPT ORGANIZATIONS

Announcement 99–49, page 7.

A list is given of organizations now classified as private foundations.

Finding Lists begin on page 11.

Index for January through April begins on page 13.

Department of the Treasury

Internal Revenue Service

Special use value; farms; interest rates. The 1999 interest rates to be used in computing the special use value of

farm real property for which an election is made under section 2032A of the Code are listed for estates of decedents.

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Mission of the Service

and by applying the tax law with integrity and fairness to

all.

Provide America’s taxpayers top quality service by helping them understand and meet their tax responsibilities

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 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.

This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.

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 semiannual basis,

and are published in the first Bulletin of the succeeding 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.

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

Section 42.—Low-Income

Housing Credit

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

of May 1999. See Rev. Rul. 99–21, page 3.

Section 280G.—Golden

Parachute Payments

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

rates are set forth for the month of May 1999. See

Rev. Rul. 99–21, page 3.

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 May 1999. See

Rev. Rul. 99–21, page 3.

Rev. Rul. 99–21

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 May 1999. See Rev. Rul. 99–21, page 3.

Section 382.—Limitation on Net

Operating Loss Carryforwards

and Certain Built-In Losses

Following Ownership Change

Section 642.—Special Rules for

Credits and Deductions

The adjusted applicable federal long-term rate is

set forth for the month of May 1999. See Rev. Rul.

99–21, page 3.

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

rates are set forth for the month of May 1999. See

Rev. Rul. 99–21, page 3.

Section 412.—Minimum

Funding Standards

Section 807.—Rules for Certain

Reserves

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

of May 1999. See Rev. Rul. 99–21, page 3.

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

of May 1999. See Rev. Rul. 99–21, page 3.

Section 467.—Certain

Payments for the Use of

Property or Services

Section 846.—Discounted

Unpaid Losses Defined

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

of May 1999. See Rev. Rul. 99–21, page 3.

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 May 1999. See Rev. Rul. 99–21, page 3.

1999–18 I.R.B.

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 May 1999.

This revenue ruling provides various

prescribed rates for federal income tax

purposes for May 1999 (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. Finally,

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.

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

of May 1999. See Rev. Rul. 99–21, page 3.

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.)

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REV. RUL. 99–21 TABLE 1

Applicable Federal Rates (AFR) for May 1999

Period for Compounding

Annual

Semiannual

Quarterly

Monthly

Short-Term

AFR

110% AFR

120% AFR

130% AFR

4.90%

5.39%

5.89%

6.39%

4.84%

5.32%

5.81%

6.29%

4.81%

5.29%

5.77%

6.24%

4.79%

5.26%

5.74%

6.21%

Mid-Term

AFR

110% AFR

120% AFR

130% AFR

150% AFR

175% AFR

5.22%

5.75%

6.28%

6.81%

7.88%

9.21%

5.15%

5.67%

6.18%

6.70%

7.73%

9.01%

5.12%

5.63%

6.13%

6.64%

7.66%

8.91%

5.10%

5.60%

6.10%

6.61%

7.61%

8.85%

Long-Term

AFR

110% AFR

120% AFR

130% AFR

5.66%

6.23%

6.81%

7.38%

5.58%

6.14%

6.70%

7.25%

5.54%

6.09%

6.64%

7.19%

5.52%

6.06%

6.61%

7.14%

REV. RUL. 99–21 TABLE 2

Adjusted AFR for May 1999

Period for Compounding

Annual

Semiannual

Quarterly

Monthly

Short-term

adjusted AFR

3.30%

3.27%

3.26%

3.25%

Mid-term

adjusted AFR

3.96%

3.92%

3.90%

3.89%

Long-term

adjusted AFR

4.82%

4.76%

4.73%

4.71%

REV. RUL. 99-21 TABLE 3

Rates Under Section 382 for May 1999

Adjusted federal long-term rate for the current month

4.82%

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.)

4.82%

May 3, 1999

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REV. RUL. 99–21 TABLE 4

Appropriate Percentages Under Section 42(b)(2) for May 1999

Appropriate percentage for the 70% present value low-income housing credit

8.27%

Appropriate percentage for the 30% present value low-income housing credit

3.54%

REV. RUL. 99–21 TABLE 5

Rate Under Section 7520 for May 1999

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

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 May 1999. See Rev. Rul. 99–21, page 3.

Section 2032A.—Valuation of

Certain Farm, Etc., Real

Property

26 CFR 20.2032A-4: Method of valuing farm real

property.

Special use value; farms; interest

rates. The 1999 interest rates to be used

in computing the special use value of

farm real property for which an election is

made under section 2032A of the Code

are listed for estates of decedents.

Rev. Rul. 99–20

This revenue ruling contains a list of

the average annual effective interest rates

on new loans under the Farm Credit Bank

system. This revenue ruling also contains

a list of the states within each Farm Credit

Bank District.

Under § 2032A(e)(7)(A)(ii) of the Internal Revenue Code, rates on new Farm

Credit Bank loans are used in computing the

special use value of real property used as a

farm for which an election is made under

§ 2032A. The rates in this revenue ruling

may be used by estates that value farmland

under § 2032A as of a date in 1999.

Average annual effective interest rates,

calculated in accordance with

§ 2032A(e)(7)(A) and § 20.2032A–4(e)

of the Estate Tax Regulations, to be used

under § 2032A(e)(7)(A)(ii), are set forth

in the accompanying Table of Interest

6.2%

Rates (Table 1). The states within each

Farm Credit Bank District are set forth in

the accompanying Table of Farm Credit

Bank Districts (Table 2).

Rev. Rul. 81–170, 1981–1 C.B. 454,

contains an illustrative computation of an

average annual effective interest rate.

The rates applicable for valuation in 1998

are in Rev. Rul. 98–22, 1998–19 I.R.B. 5.

For rate information for years prior to

1998, see Rev. Rul. 97–13, 1997–1 C.B.

185, and other revenue rulings that are

referenced therein.

DRAFTING INFORMATION

The principal author of this revenue

ruling is of the Office of Assistant Chief

Counsel (Passthroughs and Special Industries). For further information regarding

this revenue ruling, contact on (202) 6223090 (not a toll-free call).

REV. RUL. 99–20 TABLE 1

TABLE OF INTEREST RATES

(Year of Valuation 1999)

1999–18 I.R.B.

Farm Credit Bank District in

Which Property Is Located

Interest

Rate

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

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

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

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

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

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

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

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

9.65

8.07

8.25

8.21

8.31

8.78

8.11

8.25

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REV. RUL. 99–20 TABLE 2

TABLE OF FARM CREDIT BANK DISTRICTS

District

States

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

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

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

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

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

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

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

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

Section 7520.—Valuation

Tables

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

of May 1999. See Rev. Rul. 99–21, page 3.

May 3, 1999

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

North Carolina, Pennsylvania, South Carolina, Virginia, West

Virginia.

Iowa, Nebraska, South Dakota, Wyoming.

Arizona, California, Hawaii, Nevada, Utah.

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

Missouri, North Dakota, Ohio, Tennessee, Wisconsin.

Alaska, Idaho, Montana, Oregon, Washington.

Connecticut, Maine, Massachusetts, New Hampshire, New

Jersey, New York, Rhode Island, Vermont.

Alabama, Louisiana, Mississippi, Texas.

Colorado, Kansas, New Mexico, Oklahoma.

Section 7872.—Treatment of

Loans With Below-Market

Interest Rates

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

of May 1999. See Rev. Rul. 99–21, page 3.

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1999–18 I.R.B.

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Part IV. Items of General Interest

Foundations Status of Certain

Organizations

Announcement 99–49

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:

Center for Technology Transfer Inc.,

Austin, TX

Council Oaks Vocational Enhancement

Services, Austin, TX

Future Leaders Learning Center

Incorporated, Houston, TX

Heartnotes, Inc., Walcott, IA

Institute for Community Based

Rehabilitation, Little Rock, AR

Lynn Vowell Ministries, Valley View, TX

Mandelbrot Foundation for Fractals Inc.,

Scarsdale, NY

Midwest Benefits Education Council,

Minneapolis, MN

Midwest Wheel Chair Tennis Assoc. Inc.,

Brookfield, IL

Mig Inc., Chicago, IL

Mighty Eighth Air Force Foundation Inc.,

Savannah, GA

Mike Pennington Memorial Scholarship

Fund Incorporated, Manassas, VA

Miles Washington Connor Family

Support Center of Sharon BAP C Inc.,

Baltimore, MD

Millenial Arts Incorporated, New York,

NY

Millworks Gallery Inc., Akron, OH

Milton EMT Association Inc., Milton, WI

Milwaukee Academy of Music and

Performing Arts, Inc., Milwaukee, WI

Mind Development Inc., Detroit, MI

1999–18 I.R.B.

Minds Inc., Miami, FL

Mineral County Search & Rescue,

Keyser, WV

Ministry Resources Inc., Kenosa, WI

Minneapolis High Rise Tenants

Organization, Minneapolis, MN

Minnesota Council of Sexual AdictionCompulsivity, Duluth, MN

Minnesota Mortgage Foreclosure

Prevention Association, Minneapolis,

MN

Minnesota State Elks Association

Charitable TR, Austin, MN

Minnesotans for the Mississippi,

Hastings, MN

Minority Economic Developers Inc.,

Baton Rouge, LA

Minority Enterprise Development

Council, Chicago, IL

Minority Resume Exchange, Boulder, CO

Mirage Aquatics, Victorville, CA

Miss Dots Small World Inc., Paterson, NJ

Missing Children International Inc.,

Orange, CA

Mission of First Baptist Church of

Vienna Inc., Salisbury, MD

Mission of Jesus Disciple, Irvine, CA

Missionary Care International, Corona,

CA

Missionary Evangelistic Support

Association, Goshen, OH

Mississippi Branch of the Orton Dyslexia

Society, Gulfport, MS

Mississippi Lifeline Inc., Jackson, MS

Mississippi Sickle Cell Anemia

Foundation Inc., Jackson, MS

Missoula Center for Responsible

Planning Inc., Missoula, MT

Missouri Association for Agriculture

Biomedical Research & Education,

St. Louis, MO

Missouri Association of Teaching

Christian Homes, Columbia, MO

MITA Business League Inc., Tifton, GA

Mitchelltown Preservation Society,

Kinston, NC

Mitzva Awareness Program, Southfield,

MI

Mize Informatics Foundation, Dallas, TX

MKS in Recovery Inc., Reynoldsburg,

OH

MLT Foundation Inc., Orlando, FL

MMC Surgie Center Inc., Long Branch,

NJ

MO Better Brothers Inc., Louisville, KY

Mobile Elder Care, Mobile, AL

7

Mobile Global Laboratories, Tuscaloosa,

AL

Monroe County Public Library

Foundation Inc., Bloomington, IN

Monroe Developmental Disabilities

Education Network, Fairport, NY

Montage Acting Society of Kent, Kent,

WA

Montanans for a Healthy Future, Clancy,

MT

Montclair Chamber ensemble Inc.,

Montclair, NJ

Monte Vista Housing Foundation a CA

Non-Profit Public Benefit Corp.,

Huntington Beach, CA

Montessori N E S T Preschool Inc.,

Baton Rouge, LA

Montgomerys Transportation Service

Inc., New Orleans, LA

Moonbird Foundation Inc., Houston, TX

Moreno Valley Spotlighters, Moreno

Valley, CA

Morgan and Canfield Foundation,

Bloomfield Hills, MI

Morgan Family Ministries Inc., Foster,

KY

Morning Glory Manse Inc., Mansfield,

MA

Mother Tierras Inc., Havre de Grace,

MD

Mothers Against Gang Wars, Stockton,

CA

Mothers of Murdered Offspring-Mom-O

Inc., Charlotte, NC

Motor Sports Awareness Group, Houston,

TX

Mount Canaan Baptist Church Lifeline

Enterprises Inc., Talladega, AL

Mt. Carmel Gospel Ministries Inc.,

Columbia, MD

MTB Community Crisis Prevention

Center, Baton Rouge, LA

Muhammed Ali Future Foundation,

Philadelphia, PA

Mulligan Foundation Inc., Whitmore,

Lake, MI

Multi-Color Film & Arts Inc., Brooklyn

Park, MN

Multi Mind Foundation, Carlsbad, CA

Multimedia Learning Consortium,

Stockton, CA

Museum of Education Community &

Cultural Arts Inc., Jacksonville, FL

Museum of Life or Death Incorporated,

Irvington, NJ

Museum of Rock, Simi Valley, CA

May 3, 1999

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Museums and Schools Information

Exchange, Washington, DC

Music Ministry – M & M Productions

Inc., Houston, TX

Muskegon Area Toys for Tots Inc.,

Muskegon, MI

Muskogee Dug Out Club, Muskogee, OK

My Jesus Mercy Ministries Inc.,

Philadelphia, PA

QFPM Inc., Detroit, MI

Quad-Cities Fiddlers Jamboree Ltd.,

Long Grove, IA

Qualicenters Patient Support

Corporation, Wheat Ridge, CO

Quality of Life Association of Lowndes

County Inc., Hayneville, AL

Quality of Life Foundation Inc., New

York, NY

Quam Performing Arts & Education

Center, Philadelphia, PA

Quapaw Community Center of Hot

Springs Arkansas, Hot Springs, AR

Quarterback Club – Carmichaels

Pennsylvania Inc., Carmichaels, PA

Queen of Peace Communications Inc.,

Chicago, IL

Queens Korean American Seniors Center

Inc., Elmhurst, NY

Quest for Peace International Inc.,

Naples, FL

Questarium Inc., Windham, ME

Quinlin Sports Association Inc., Quinlan,

TX

Quint-City Roughriders, Rock Island, IL

R D Brady Foundation for Prehospital

Research, Grand Rapids, MI

R E A P Inc., Georgetown, SC

R E S T O R E, Fargo, ND

Raccoon Valley Humane Society, Adel,

IA

Racers Against AIDS, Chula Vista, CA

Racing Babies Inc., Chicago, IL

Radiance Technique Association

Midwest, Chicago, IL

Radio Latina Inc., Kansas City, MO

Rahabs Roost, Sparta, TN

Rainbow After School Program Inc.,

Bronx, NY

Rainbow Center Inc. of New York,

Flushing, NY

Rainbow Christian Ministries Distress

Center, Ravena, NY

Rainbow Learning Center, Ypsilanti, MI

Rainbow Redirections Childrens Services

Inc., Pembroke Pines, FL

Rainbow Ridge Retreat, Ohio City, CO

Rainbow Services Incorporated, Harvard,

MA

May 3, 1999

Rainbows Bend Unlimited Inc., Spencer,

MA

Rainbows End Daycare Inc., Macks

Creek, MO

Rainforest Health Project Inc., Winona,

MN

Rainy Day Foundation, The Dalles, OR

Raisins Inc., Tampa, FL

Rancho Cucamonga Friendship for

Animals, Rancho Cucamonga, CA

Randant Foundation for Women &

Children, Mt. Prospect, IL

Randy Berg Ministries, Lavergne, TN

Ranees Beginnings, West Valley City, UT

Ranger Summer Theater, Hamburg, NJ

Ranken Community Development Corp.,

St. Louis, MO

Rapheal Craft Evangelistic Corporation,

Marshall, TX

Rapid River Scholarship Foundation,

Rapid River, MI

Rapids D A R E Inc., Alexandria, LA

Rapidan Area Country School

Association, Burnsville, MN

Rapport Foundation, Phoenix, AZ

Raulerson Ministries Inc., Punta Gorda,

FL

Ravens Youth Development

Organization, Amherst, MA

Ray of Hope Ministries, Woodburn, OR

Ray Silvious Memorial Golf Committee,

Lavale, MD

Reach for Tomorrow Inc., Fairfax, VA

Reach Ministries, Tyler, TX

Reach Ministries, Peoria, IL

Reach Out America a Non Profit TR

010193, Carmel, CA

Reach Out of Centralia, Centralia, IL

Reach the Children, Tesuave, NM

Reaching the Unreached-USA Ltd., Bay

Shore, NY

Readd, Richmond, IN

Reading Aerofest Inc., Reading, PA

Reading Beautification Inc., Reading, PA

Real Truth Community Service Center,

Kansas City, MO

Real World Foundation, Fryeburg, ME

Rear Guard Ministries Inc., Mobile, AL

Rear Window Art Gallery Inc.,

Winchester, VA

Receive Inc., Overland Park, KS

Recovery Assistance Program Inc.,

Wichita, KS

Recovery Fellowship Ministries Inc.,

Springfield, MO

Recovery From Addictions Inc.,

Southfield, MI

Recovery House Inc., Ocala, FL

8

Recovery Houston Institute Inc.,

Houston, TX

Recovery Processes Inc., Westerville, OH

Recovery Services Foundation, Wichita,

KS

Recreational Inner City Sports and

Education, Jamaica, NY

Red Powers Foundation Inc., Gold

Beach, OR

Red River Health Promotion Coalition,

Fargo. ND

Red Robin Residential Care Inc.,

Alpaugh, CA

Red Wings Area Bicycle Motocross

Association, Red Wing, MN

Redeeming Care Center Inc., Rahway, NJ

Reep of North Carolina, Durham, NC

Reflections of a Kaleidoscope Inc., Great

Barrington, MA

Regina Cleri High School Foundation,

Tucson, AZ

Regional Arts Association, Wolcott, CT

Regional Neighborhood Community

Development Corporation, New

Orleans, LA

Rehabilitation of Addictions Foundation

Inc., Houston, TX

Rehoboth Beach Jazz Festival Inc.,

Rehoboth Beach, DE

Rejoice Publications Inc., Columbia Hts,

MN

Relevancy Inc., Albuquerque, NM

Renaissance Foundation Inc.,

Washington, DC

Renaissance Healing Arts Center, Green

Bay, WI

Renascent Inc., New Orleans, LA

Renewal Fellowship, Golden Valley, MN

Renton Black Parents Association, Sear,

WA

Repaired of the Breach, Baton Rouge,

LA

Repairs of Broken Walls Inc., Detroit

Lakes, MN

Republic of Vietnam Armed Forces

Veteran Association in Greater,

Cleveland, OH

Research Foundation of the Southwest,

Fort Worth, TX

Research Institute for Computer

Applications, Baton Rouge, LA

Research Institute for the Prevention of

Starvation, Overland Park, KS

Research Institute International Inc.,

Gainesville, FL

Residence One Corporation, Tampa, FL

Residences for People With Autism Inc.,

Port Washington, NY

1999–18 I.R.B.

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Resident Council of the Housing

Authority of Newport, Newport, KY

Resource Center Inc., Guyton, GA

Respect Incorporated, Evansville, IN

Responsive Resources Inc., Columbus,

OH

Restitution Coalition Inc., Amarillo, TX

Restoration Community Resources Inc.,

College Park, GA

Restoration Ministries Incorporated,

Indianapolis, IN

Restoration Project Inc., Acton, MA

Restructuring Education and Family

Opportunities Through Regenerative,

Albuquerque, NM

Resurrection House Inc., Laramie, WY

Resurrection Lutheran Parsonage Inc.,

Boston, MA

Revelation Knowledge Inc., Louisville,

KY

Rhode Island Coalition for Minority

Investment, Providence, RI

1999–18 I.R.B.

Richardo Richards School Project Esteem

Inc., St. Croix, VI

Rice Family Farms Consortium Inc.,

Atlanta, GA

Riceville Community Foundation Inc.,

Riceville, IA

Richard A Wolters Foundation Inc.,

Atlanta, GA

Richard Butch Anderson Memorial Trust

Fund, Clifton Park, NY

Richard Clark Ministries Inc., New

Haven, CT

Richard Miles Decker Memorial

Scholarship Funds, Beachwood, OH

Richland County Pheasants, Wyndmere,

ND

Richmond County Microenterprise Inc.,

Hamlet, NC

Richmond Youth Strive for Excellence

Corp., Richmond, CA

Ridgeland Community Tennis

Association, Ridgeland, MS

9

Ridglea Roughnecks Peewee Football

Association Inc., Ft. Worth, TX

Riding for America Inc., Fairbanks, AK

Right Moves for Youth Inc., Charlotte,

NC

Right Step Academy, St. Paul, MN

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.

May 3, 1999

IRB 1999-18

4/29/99 1:37 PM

Page 10

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.

May 3, 1999

10

1999–18 I.R.B.

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Page 11

Numerical Finding List1

Bulletins 1999–1 through 1999–17

Announcements:

99–1, 1999–2 I.R.B. 41

99–2, 1999–2 I.R.B. 44

99–3, 1999–3 I.R.B. 15

99–4, 1999–3 I.R.B. 15

99–5, 1999–3 I.R.B. 16

99–6, 1999–4 I.R.B. 24

99–7, 1999–2 I.R.B. 45

99–8, 1999–4 I.R.B. 24

99–9, 1999–4 I.R.B. 24

99–10, 1999–5 I.R.B. 63

99–11, 1999–5 I.R.B. 64

99–12, 1999–5 I.R.B. 65

99–13, 1999–6 I.R.B. 18

99–14, 1999–7 I.R.B. 60

99–15, 1999–8 I.R.B. 78

99–16, 1999–8 I.R.B. 80

99–17, 1999–9 I.R.B. 59

99–18, 1999–13 I.R.B. 21

99–19, 1999–10 I.R.B. 63

99–20, 1999–11 I.R.B. 53

99–21, 1999–11 I.R.B. 55

99–22, 1999–12 I.R.B. 32

99–23, 1999–15 I.R.B. 7

99–24, 1999–14 I.R.B. 12

99–25, 1999–12 I.R.B. 35

99–26, 1999–14 I.R.B. 20

99–27, 1999–13 I.R.B. 22

99–28, 1999–13 I.R.B. 25

99–29, 1999–13 I.R.B. 25

99–30, 1999–13 I.R.B. 26

99–31, 1999–13 I.R.B. 26

99–32, 1999–14 I.R.B. 20

99–33, 1999–14 I.R.B. 21

99–34, 1999–15 I.R.B. 8

99–35, 1999–14 I.R.B. 22

99–36, 1999–16 I.R.B. 10

99–37, 1999–15 I.R.B. 9

99–38, 1999–15 I.R.B. 9

99–39, 1999–15 I.R.B. 10

99–40, 1999–16 I.R.B. 10

99–41, 1999–16 I.R.B. 10

99–42, 1999–16 I.R.B. 11

99–43, 1999–16 I.R.B. 11

99–44, 1999–16 I.R.B. 12

99–45, 1999–16 I.R.B. 12

99–46, 1999–16 I.R.B. 13

99–48, 1999–17 I.R.B. 20

Notices:

99–1, 1999–2 I.R.B. 8

99–2, 1999–2 I.R.B. 8

99–3, 1999–2 I.R.B. 10

99–4, 1999–3 I.R.B. 9

99–5, 1999–3 I.R.B. 10

99–6, 1999–3 I.R.B. 12

99–7, 1999–4 I.R.B. 23

99–8, 1999–5 I.R.B. 26

99–9, 1999–4 I.R.B. 23

99–10, 1999–6 I.R.B. 14

99–11, 1999–8 I.R.B. 56

99–12, 1999–9 I.R.B. 44

99–13, 1999–10 I.R.B. 26

99–14, 1999–11 I.R.B. 7

99–15, 1999–12 I.R.B. 20

99–16, 1999–13 I.R.B. 10

Notices—Continued

99–17, 1999–14 I.R.B. 6

99–18, 1999–16 I.R.B. 4

99–19, 1999–16 I.R.B. 4

99–20, 1999–17 I.R.B. 16

99–21, 1999–17 I.R.B. 19

Proposed Regulations:

REG–209103–89, 1999–11 I.R.B. 10

REG–209619–93, 1999–10 I.R.B. 28

REG–245562–96, 1999–9 I.R.B. 45

REG–104072–97, 1999–11 I.R.B. 12

REG–114663–97, 1999–6 I.R.B. 15

REG–114664–97, 1999–11 I.R.B. 21

REG–116826–97, 1999–10 I.R.B. 40

REG–118620–97, 1999–9 I.R.B. 46

REG–120168–97, 1999–12 I.R.B. 21

REG–121806–97, 1999–10 I.R.B. 46

REG–100729–98, 1999–14 I.R.B. 9

REG–104924–98, 1999–10 I.R.B. 47

REG–105964–98, 1999–12 I.R.B. 22

REG–106177–98, 1999–12 I.R.B. 25

REG–106219–98, 1999–9 I.R.B. 51

REG–106386–98, 1999–12 I.R.B. 31

REG–106388–98, 1999–11 I.R.B. 27

REG–106564–98, 1999–10 I.R.B. 53

REG–106902–98, 1999–8 I.R.B. 57

REG–106905–98, 1999–11 I.R.B. 39

REG–110524–98, 1999–10 I.R.B. 55

REG–111435–98, 1999–7 I.R.B. 55

REG–113694–98, 1999–7 I.R.B. 56

REG–111435–98, 1999–7 I.R.B. 55

REG–113744–98, 1999–10 I.R.B. 59

REG–114841–98, 1999–11 I.R.B. 41

REG–115433–98, 1999–9 I.R.B. 54

REG–116099–98, 1999–12 I.R.B. 34

REG–116824–98, 1999–7 I.R.B. 57

REG–117620–98, 1999–7 I.R.B. 59

REG–118662–98, 1999–13 I.R.B. 13

REG–119192–98, 1999–11 I.R.B. 45

REG–121865–98, 1999–8 I.R.B. 63

Revenue Procedures:

99–1, 1999–1 I.R.B. 6

99–2, 1999–1 I.R.B. 73

99–3, 1999–1 I.R.B. 103

99–4, 1999–1 I.R.B. 115

99–5, 1999–1 I.R.B. 158

99–6, 1999–1 I.R.B. 187

99–7, 1999–1 I.R.B. 226

99–8, 1999–1 I.R.B. 229

99–9, 1999–2 I.R.B. 17

99–10, 1999–2 I.R.B. 11

99–11, 1999–2 I.R.B. 14

99–12, 1999–3 I.R.B. 13

99–13, 1999–5 I.R.B. 52

99–14, 1999–5 I.R.B. 56

99–15, 1999–7 I.R.B. 42

99–16, 1999–7 I.R.B. 50

99–17, 1999–7 I.R.B. 52

99–18, 1999–11 I.R.B. 7

99–19, 1999–13 I.R.B. 10

99–20, 1999–14 I.R.B. 7

99–21, 1999–17 I.R.B. 18

99–22, 1999–15 I.R.B. 5

99–23, 1999–16 I.R.B. 5

Revenue Rulings—Continued

99–3, 1999–3 I.R.B. 4

99–4, 1999–4 I.R.B. 19

99–5, 1999–6 I.R.B. 8

99–6, 1999–6 I.R.B. 6

99–7, 1999–5 I.R.B. 4

99–8, 1999–6 I.R.B. 8

99–9, 1999–7 I.R.B. 14

99–10, 1999–10 I.R.B. 10

99–11, 1999–10 I.R.B. 18

99–12, 1999–11 I.R.B. 6

99–13, 1999–10 I.R.B. 4

99–14, 1999–13 I.R.B. 3

99–15, 1999–12 I.R.B. 4

99–16, 1999–13 I.R.B. 5

99–17, 1999–14 I.R.B. 4

99–18, 1999–14 I.R.B. 3

99–19, 1999–15 I.R.B. 3

Treasury Decisions:

8789, 1999–3 I.R.B. 5

8791, 1999–5 I.R.B. 7

8792, 1999–7 I.R.B. 36

8793, 1999–7 I.R.B. 15

8794, 1999–7 I.R.B. 4

8795, 1999–7 I.R.B. 8

8796, 1999–4 I.R.B. 16

8797, 1999–5 I.R.B. 5

8798, 1999–12 I.R.B. 16

8799, 1999–6 I.R.B. 10

8800, 1999–4 I.R.B. 20

8801, 1999–4 I.R.B. 5

8802, 1999–4 I.R.B. 10

8803, 1999–12 I.R.B. 15

8804, 1999–12 I.R.B. 5

8805, 1999–5 I.R.B. 14

8806, 1999–6 I.R.B. 4

8807, 1999–9 I.R.B. 33

8808, 1999–10 I.R.B. 21

8809, 1999–7 I.R.B. 27

8810, 1999–7 I.R.B. 19

8811, 1999–10 I.R.B. 19

8812, 1999–8 I.R.B. 19

8813, 1999–9 I.R.B. 34

8814, 1999–9 I.R.B. 4

8815, 1999–9 I.R.B. 31

8816, 1999–8 I.R.B. 4

8817, 1999–8 I.R.B. 51

8818, 1999–17 I.R.B. 3

Revenue Rulings:

99–1, 1999–2 I.R.B. 4

99–2, 1999–2 I.R.B. 5

1 A cumulative list of all revenue rulings, revenue

procedures, Treasury decisions, etc., published in

Internal Revenue Bulletins 1998–1 through 1998–52

will be found in Internal Revenue Bulletin 1999–1,

dated January 4, 1999.

1999–18 I.R.B.

11

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Finding List of Current Action on

Previously Published Items1

Bulletins 1999–1 through 1999–17

Notices:

92–36

Modified by

Rev. Proc. 99–23, 1999–16 I.R.B. 5

96–64

Modified by

Rev. Proc. 99–23, 1999–16 I.R.B. 5

98–39

Modified by

Rev. Proc. 99–23, 1999–16 I.R.B. 5

98–52

Modified by

Rev. Proc. 99–23, 1999–16 I.R.B. 5

99–5

Modified by

Rev. Proc. 99–23, 1999–16 I.R.B. 5

Revenue Procedures—Continued

98–6

Superseded by

99–6, 1999–1 I.R.B. 187

98–7

Superseded by

99–7, 1999–1 I.R.B. 226

98–8

Superseded by

99–8, 1999–1 I.R.B. 229

98–14

Modified by

99–23, 1999–16 I.R.B. 5

98–22

Modified and amplified by

99–13, 1999–5 I.R.B. 52

98–28

Obsoleted by (except as provided in section 5.02 of)

99–22, 1999–15 I.R.B. 5

Revenue Procedures:

98–56

Superseded by

99–3, 1999–1 I.R.B. 103

78–10

Obsoleted by

99–12, 1999–3 I.R.B. 13

98–63

Modified by announcement

99–7, 1999–2 I.R.B. 45

89–9

Modified by

99–23, 1999–16 I.R.B. 5

Revenue Rulings:

89–13

Modified by

99–23, 1999–16 I.R.B. 5

92–19

Supplemented in part by

99–10, 1999–10 I.R.B. 10

93–39, section 13

Modified by

99–23, 1999–16 I.R.B. 5

94–56

Superseded by

99–9, 1999–2 I.R.B. 17

95–12

Modified by

99–23, 1999–16 I.R.B. 5

97–23

Superseded by

99–3, 1999–1 I.R.B. 103

97–41

Modified by

99–23, 1999–16 I.R.B. 5

98–1

Superseded by

99–1, 1999–1 I.R.B. 6

98–2

Superseded by

99–2, 1999–1 I.R.B. 73

98–3

Superseded by

99–3, 1999–1 I.R.B. 103

98–4

Superseded by

99–4, 1999–1 I.R.B. 115

98–5

Superseded by

99–5, 1999–1 I.R.B. 158

1 A cumulative finding list for previously published

items mentioned in Internal Revenue Bulletins

1998–1 through 1998–52 will be found in Internal

Revenue Bulletin 1999–1, dated January 4, 1999.

May 3, 1999

12

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Page 13

Index

Internal Revenue Bulletins

1999–1 Through 1999–17

For the index of items published during

1998, see I.R.B. 1999–1, dated January 4, 1999.

The abbreviation and number in parenthesis following the index entry refer to

the specific item; numbers in roman and

italic type following the parenthesis refer

to the Internal Revenue Bulletin in which

the item may be found and the page

number on which it appears.

Key to Abbreviations:

RR

Revenue Ruling

RP

Revenue Procedure

TD

Treasury Decision

CD

Court Decision

PL

Public Law

EO

Executive Order

DO

Delegation Order

TDO

Treasury Department Order

TC

Tax Convention

SPR

Statement of Procedural

Rules

PTE

Prohibited Transaction

Exemption

EMPLOYEE PLANS

Automatic extension of time to file certain employee plan returns (Ann. 37)

15, 9

Determination letters (RP 6) 1, 187

Eligible rollover distributions; transitional

relief (Notice 5) 3, 10

Enrolled actuaries, examination program

(Ann. 25) 12, 35

Extension of remedial amendment period

(RP 23) 16, 5

Funding:

Full funding limitations, weighted average interest rate for January 1999

(Notice 7) 4, 23; February 1999 (Notice 11) 8, 56; March 1999 (Notice

15) 12, 21; April 1999 (Notice 21)

17, 19

Letter rulings, etc. (RP 4) 1, 115

Plan administration (Notice 1) 2, 8

Proposed Regulations:

26 CFR 1.401(a)(31)–1, amended; relief from disqualification for plans

accepting rollovers (REG–245562–

96) 9, 45

1999–18 I.R.B.

EMPLOYEE PLANS—

Continued

ESTATE TAX—

Continued

26 CFR 1.402(f)–1, amended; required

explanation of eligible rollover distributions; questions and answers

(REG–118662–98) 13, 13

26 CFR 1.411(a)–7, –11, 1.417(e)–1,

amended; increase in cash-out limit

under sections 411(a)(7), 411(a)(11)

and 417(e)(1) for qualified retirement plans (REG–113694–98) 7, 56

26 CFR 1.411(a)–11, amended; restriction and valuation of distributions

(REG–118662–98) 13, 13

26 CFR 35.3405–1, amended; questions and answers relating to withholding on pensions, annuities, and

certain other deferred income (REG–

118662–98) 13, 13

Tax-sheltered annuities (RP 13) 5, 52

Technical advice (RP 5) 1, 158

User fees (RP 8) 1, 229

duction; valuation of interest passing

to surviving spouse (REG–114663–

97) 6, 17

Valuation of adjusted taxable gifts and

section 2701(d) taxable events, REG–

106177–98; correction (Ann. 28) 13, 25

EMPLOYMENT TAX

Deferred compensation:

Change in method of accounting

(Notice 16) 13, 10

Disregarded entities (Notice 6) 3, 12

Federal Insurance Contributions Act

(FICA) taxation of amounts under

employee benefit plans; correction

(Ann. 41) 16, 10

Forms W-2 and W-3; format changes

postponed (Ann. 34) 15, 8

Penalty:

Failure to deposit penalty using electronic funds transfer (Notice 12) 9,

44; (Notice 20) 17, 16

Regulations:

26 CFR 31.3121(v)(2)–1, –2, added;

FICA tax amounts under employee

benefit plans (T.D. 8814) 9, 4

26 CFR 31.3306(r)(2)–1, added; FUTA

tax amounts under employee benefit

plans (T.D. 8815) 9, 31

ESTATE TAX

Proposed regulations:

26 CFR 20.2001–1, revised; valuation

of adjusted taxable gifts and section

2701(d) taxable events (REG–

106177–98) 12, 25

26 CFR 20.2055–1(d)(6), added;

20.2056(b)–4, amended; marital de-

13

EXCISE TAX

Kerosene registration, provisions in final

regulations (Ann. 40) 16, 10

Penalty:

Failure to deposit penalty using electronic funds transfer (Notice 12) 9,

44; (Notice 20) 17, 16

Regulations:

26 CFR 49.4251–4, added; communications excise tax; prepaid telephone

cards (REG–118620–97) 9, 46

EXEMPT

ORGANIZATIONS

Letter rulings, etc. (RP 4) 1, 115

List of organizations classified as private

foundations (Ann 10) 5, 63; (Ann 13)

6, 20; (Ann 15) 8, 78; (Ann. 19) 10, 63;

(Ann. 20) 11, 53; (Ann. 22) 12, 32;

(Ann. 23) 15, 7; (Ann. 27) 13, 22;

(Ann. 32) 14, 20; (Ann. 48) 17, 20

Private foundations (Ann. 9) 4, 24

Regulations:

26 CFR 301.6104(d)–2 through –5, and

intermediary sections, added; public

disclosure of material relating to taxexempt organizations (T.D. 8818) 17,

3

Revocations (Ann. 45) 16, 12

Technical advice (RP 5) 1, 158

User fees (RP 8) 1, 229

GIFT TAX

Proposed regulations:

26 CFR 25.2504–2, revised; valuation

of certain gifts for preceding calendar

periods (REG–106177–98) 12, 25

Valuation of adjusted taxable gifts and

section 2701(d) taxable events, REG–

106177–98; correction (Ann. 28) 13, 25

INCOME TAX

Accounting period guidance (Notice 19)

16, 4

May 3, 1999

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INCOME TAX—Continued

INCOME TAX—Continued

INCOME TAX—Continued

Action on Decision; court decisions in

1999–4 I.R.B. 4; correction (Ann. 17)

9, 59

Automobile owners and lessees (RP 14)

5, 56

Business expenses:

Lease-in / lease-out transactions (RR

14) 13, 3

Certain transfers of stock or securities by

U.S. persons to foreign corporations

and related reporting requirements;

correction (Ann. 42) 16, 11

Certain transfers to foreign partnerships

and foreign corporations; correction

(Ann. 43) 16, 11

Chief Counsel advice available for public

inspection (Ann. 4) 3, 15

Child support enforcement program (RP

12) 3, 13

Commodities dealers; securities or commodities traders; procedures for making elections (RP 17) 7, 52

Continuation coverage requirements applicable to group health plans; correction (Ann. 39) 15, 10

Credit for increasing research activities;

hearing (Ann. 38) 15, 9

CRT and capital gain modification (Notice 17) 14, 6

Cumulative Bulletin continued with a

new format (Ann. 36) 16, 10

Daily transportation expenses; commuting expenses; business expenses; personal expenses (RR 7) 5, 4

Debt roll-ups; election to treat certain debt

substitutions as realization events (RP

18) 11, 7

Deficiencies:

Interest abatement, Presidentially declared disasters (Notice 2) 2, 8

Disregarded entity to partnership (RR 5)

6, 8

Election in respect of losses attributable to

a disaster (RR 13) 10, 4

Electronic:

Filing; magnetic media; 1998 Form

8596 (RP 9) 2, 17

Submission of Form W-5 (Ann. 3) 3,

15; Forms W-4P, W-4S and W-4V

(Ann. 6) 4, 24

Enrolled actuaries, examination program

(Ann. 25) 12, 35

Exclusions-inclusions:

Payments for Temporary Assistance for

Needy Families (Notice 3) 2, 10

Failure by certain charitable organizations

to meet certain qualified requirements;

taxes on excess benefit transactions

(Ann. 21) 11, 55

Failure to deposit federal tax; penalties

(RP 10) 2, 11

Forms:

1040NR instructions for 1998, corrected (Ann. 8) 4, 24

1042-S, request for public comments

(Ann. 24) 14, 12

8866 (Ann 16) 8, 80

Individual retirement arrangements:

Payroll deductions (Ann. 2) 2, 44

Recharacterizations and reconversions

(Ann. 5) 3, 16

Insurance companies:

Tentative differential earnings rate for

1998 (Notice 13) 10, 26

Prevailing state assumed interest rates

(RR 10) 10, 10

Discounting estimated salvage recoverable (RP 16) 7, 50

Loss reserves; discounting unpaid

losses (RP 15) 7, 42

Interest:

Investment:

Federal short-term, mid-term, and

long-term rates for January 1999

(RR 2) 2, 5; February (RR 8) 6,

10; March 1999 (RR 11) 10, 18;

April 1999 (RR 17) 14, 4

Rates:

Underpayments and overpayments

for calendar quarter beginning

April 1, 1999 (RR 16) 13, 5

Interest netting for interest accruing before October 1, 1998 (RP 19) 13, 10

Inventory:

LIFO:

Price indexes; department stores for

November 1998 (RR 4) 4, 19;

December 1998 (RR 9) 7, 14;

January 1999 (RR15) 12, 4; February 1999 (RR 19) 15, 3

Letter rulings, determination letters, and

information letters issued by Associate

Chief Counsel (Domestic), Associate

Chief Counsel (EBEO), Associate

Chief Counsel (Enforcement Litigation), and Associate Chief Counsel

(International) (RP 1) 1, 6

Long-term capital gain treatment for

1997-1998 fiscal year filers (Ann 11) 5,

64

Low-income housing tax credit:

Alternative collateral program (RP 11)

2, 14

1999 calendar year resident population

estimates (Notice 10) 6, 16

Satisfactory bond; “bond factor”

amounts for the period October

through December 1998 (RR 1) 2, 4;

January through March 1999 (RR

18) 14, 3

Low-income taxpayer clinics grant program (Notice 9) 4, 23

Mark-to-market election for regulated

investment companies that are shareholders of PFICs (Notice 14) 11, 7

Model qualified intermediary withholding

agreement (Notice 8) 5, 26

Mutual holding company conversions

(RR 3) 3, 4

National median income – 1999 (RP 22)

15, 5

Nonconventional source fuel credit, section 29 inflation adjustment factor and

reference price (Notice 18) 16, 4

Notice of significant reduction in the rate

of future benefit accrual, T.D. 8795;

correction (Ann. 31) 13, 26

OMB control numbers assigned pursuant

to the Paperwork Reduction Act; correction (Ann. 44) 16, 12

Optional standard mileage rates; effective

date (Ann. 7) 2, 45

Partnership to disregarded entity (RR 6) 6,

6

Passive foreign investment companies;

definition of marketable stock; correction (Ann. 35) 14, 22

Penalties:

Designation of Federal Tax Deposits

(RP 10) 2, 11

Penalty and interest study (Notice 4) 3, 9

Private foundations, organizations classified as (Ann. 10) 5, 63; (Ann. 13) 6, 20;

(Ann. 15) 8, 78; (Ann. 19) 10, 63;

(Ann. 20) 11, 53; (Ann. 22) 12, 32;

(Ann. 23) 15, 7; (Ann. 27) 13, 22;

(Ann. 32) 14, 20; (Ann. 48) 17, 20

Publications:

547 Revised (Ann. 33) 14, 21

584 Revised (Ann. 33) 14, 21

954 Revised (Ann. 26) 14, 20

Proposed regulations:

26 CFR 1.25A–0 thru 1.25A–5, added;

calculation of education credit and

general eligibility requirements

(REG–106388–98) 11, 27

May 3, 1999

14

1999–18 I.R.B.

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INCOME TAX—Continued

INCOME TAX—Continued

INCOME TAX—Continued

26 CFR 1.42–5, –6, –11, –12, –13,

amended; 1.42–17, added; low-income housing credit; compliance

monitoring, etc. (REG–114664–97)

11, 21

26 CFR 1.79–3, amended; group-term

insurance: uniform programs

(REG–209103–89) 11, 10

26 CFR 1.221–1, added; deduction for

interest on qualified education loans

(REG–116826–97), 10, 40

26 CFR 1.446–1, added; 1.471–12,

added; 1.475(c)–1, revised; 1.475(c)–

2, added; 1.475(e)–1, redesignated as

1.475(g)–1; 1.475(e)–1, added;

1.475(f)–1, –2, added; 1.475(g)–1,

amended; mark-to-market accounting for dealers in commodities and

traders in securities or commodities

(REG–104924–98) 10, 47

26 CFR 1.453–12, added; capital gains,

installment sales, unrecaptured section 1250 gain (REG–110524–98)

10, 55

26 CFR 1.468B–0, amended;

1.468B–1, amended; 1.468B–5,

amended; 1.468B–6 thru 1.468B–9,

and intermediary sections, added;

1.1031(k)–1, amended; escrow funds

and other similar funds (REG–

209619–93) 10, 28

26 CFR 1.663(c)–1, amended;

1.663(c)–2, revised; 1.663(c)–3,

amended; 1.663(c)–4, redesignated;

1.663(c)–4, added; 1.663(c)–5,

amended; 1.663(c)–6, added; separate share rules applicable to estates

(REG–114841–98) 11, 41

26 CFR 1.861–8, amended; 1.865–1,

added; 1.865–2, amended; allocation

of loss with respect to stock and

other personal property (REG–

106905–98) 11, 39

26 CFR 1.1296(e)–1, added; passive

foreign investment companies; definitions of marketable stocks (REG–

113744–98), 10, 59

26 CFR 1.1362–3, amended; 1.1502–

76, amended; acquisition of an S corporation by a member of a consolidated group (REG–106219–98) 9, 51

26 CFR 1.1502–3, amended; 1.1502–

9A, added; new 1.1502–9, added;

consolidated overall foreign losses

and separate limitation losses (REG–

106902–98) 8, 57

26 CFR 1.1502–13, amended; intercompany transactions (REG–

105964–98) 12, 22

26 CFR 1.6302–4, revised; 20.6302–1,

added; 25.6302–1, added; 31.6302–

1, amended; 40.6302(a)–1, added;

electronic funds transfers of federal

deposits (REG–100729–98) 14. 9

26 CFR 1.6695–1, amended; retention

of income tax return preparer’s signature (REG–106386–98) 12, 15

26 CFR 1.6695–2, added; preparer due

diligence requirements for determining earned income credit eligibility

(REG–120168–97) 12, 16

26 CFR 1.7701(1)–3, added; 1.1441–7,

amended; recharacterizing financing

arrangements involving fast–pay

stock (REG– 104072–97) 11, 12

26 CFR 54.4980B, amended; continuation coverage requirements of group

health plans (REG–121865–98) 8,

63

26 CFR 301.6103(j)(1)–1, amended;

disclosure of return information to

the Bureau of Census (REG–

121806–97) 10, 46

26 CFR 301.6103(k)(9)–1, added;

301.6311–1(a)(1)(i), amended; payment of tax by credit card or debit

card (REG–111435–98) 7, 55

26 CFR 301.6221–1, amended;

301.6223(c)–1,

amended;

301.6224(c)–3,

amended;

301.6229(b)–2, added; 301.6229(f)–

1, added; 301.6231(a)(1)–1,

amended;

301.6231(a)(6)–1,

amended;

301.6231(a)(7)–1,

amended; modifications and additions to the unified partnership audit

procedures (REG–106564–98) 10, 53

26 CFR 301.6320–1, added; notice and

opportunity for hearing upon filing

of notice of lien (REG–116824–98)

7, 57

26 CFR 301.6330–1, added; notice and

opportunity for hearing prior to levy

(REG–117620–98) 7, 59

26 CFR 301.7502–1, revised;

301.7502–2, added; Timely mailing

treated as timely filing / electronic

postmark (REG–115433–98) 9, 54

26 CFR 801.0–1 thru 801.0–5, and intermediary sections, added; establishment of a balanced measurement

system (REG–119192–98) 11, 45

Proposed update of Rev. Proc. 65–17

(Ann. 1) 2, 41

Recharacterizing financing arrangements

involving fast-pay stock, REG–

104072–97; correction (Ann. 30) 11, 26

Refunds and credits:

Period of limitations, financial disability (RP 21) 17, 18

Regulations:

26 CFR 1.411(a)–11(c)(2)(ii), revised;

1.411(a)–11(c)(2)(iii), (iv), (v), and

(c)(8), added; 1.411(a)–11T, removed; 1.417(e)–1(b)(3), revised;

(b)(4), added; 1.417(e)–1T,

amended; qualified retirement plans

(T.D. 8796) 4, 16

26 CFR 1.148–5(d)(6)(iii), revised;

1.148–5(e)(2)(iv), added; arbitrage

restrictions on tax-exempt bond

(T.D. 8801) 4, 5

26 CFR 1.195–1, added; election to

amortize start-up expenditures for

active trades or businesses (T.D.

8797) 5, 5

26 CFR 1.337(d)–4, added; certain

asset transfers to a tax-exempt entity

(T.D. 8802) 4, 10

26 CFR 1.408A–0 through –9, and intermediary sections, added; Roth

IRAs (T.D. 8816) 8, 4

26 CFR 1.411(a)–7, –11, amended;

1.411(a)–7T, –11T, added; increase

in cash-out limit under sections

411(a)(7), 411(a)(11) and 417(e)(1)

for qualified retirement plans (T.D.

8794) 7, 4

26 CFR 1.411(d)(4), amended;

1.411(d)–4T, removed; employee

stock ownership plans qualified retirement plan benefits (T.D. 8806)

6, 4

26 CFR 1.411(d)–6T, removed;

1.411(d)–6, added; notice of significant reduction in the rate of future

benefit accrual (T.D. 8795) 7, 8

26 CFR 1.469–10, revised; 1.7704–3,

added; certain investment income

under the qualifying income provisions and the application of the passive activity loss rules to publicly

traded partnerships (T.D. 8799) 6, 12

26 CFR 1.664–1(a)(7), (d)(1)(iii),

(f)(4), added; 1.664–2(a)(1)(i), revised; 1.664–3, amended; 25.2702–

1(c)(3), revised; charitable remainder trusts and special valuation rules

1999–18 I.R.B.

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INCOME TAX—Continued

INCOME TAX—Continued

INCOME TAX—Continued

for transfers of interests in trusts

(T.D. 8791) 5, 7

26 CFR 1.861–8, amended; 1.861–8T,

amended; 1.865–1T, added; 1.865–2,

added; 1.865–2T, added; 1.904–0,

amended; 1.904–4, amended; allocation of loss with respect to stocks

and other personal property (T.D.

8805) 5, 14

26 CFR 1.871–14, revised; rules relating to repeal of tax on interest of

nonresident alien individuals and

foreign corporations received from

certain portfolio debt investments

(T.D. 8804) 12, 5

26 CFR 1.881–3, corrected conduit

arrangement regulations (Ann 14) 7,

60

26 CFR 1.1441–1, –5, –6, –9, revised;

1.1441–4, amended; 1.1441–8, redesignated and amended; 1.1443–1,

revised; requirements for the deduction and withholding of tax on payments to foreign persons (T.D. 8804)

12, 5

26 CFR 1.1502–3T, –9(a), –9T(b)(1)(v)

and (vi), amended; consolidated returns, limitation on recapture of

overall foreign loss accounts (T.D.

8800) 4, 20

26 CFR 1.6038B–1, amended;

1.6038B–2, added; notice of certain

transfers to foreign partnerships and

foreign corporations (T.D. 8817) 8,

51

26 CFR 1.6042–3, amended; dividends

subject to reporting; 1.6045–1,

amended; returns of information of

brokers and barter exchanges;

1.6049–5, amended; interest and

original issue discount subject to reporting after December 31, 1982

(T.D. 8804) 12, 5

26 CFR 1.6695–1, amended;

1.6695–1T, added; retention of income tax return preparer’s signature

(temporary) (T.D. 8803) 12, 15

26 CFR 1.6695–2T, added; preparer

due diligence requirements for determining earned income credit eligibility (temporary) (T.D. 8798) 12, 16

26 CFR 1.7702B–1, –2, added; qualified long-term care insurance contracts (T.D. 8792) 7, 36

26 CFR 54.4980B–0 through –8, and

intermediary sections, added; continuation coverage requirements of

group health plans (T.D. 8812) 8, 19

26 CFR 301.6103(j)(1)–1, amended;

301.6103(j)(1)–1T, added; disclosure of return information to the Bureau of Census (T.D. 8811) 10, 19

26 CFR 301.6103(k)(9)–1T, –2T,

added; payment of tax by credit card

or debit card (T.D. 8793) 7, 15

26 CFR 301.6221–1T, amended;

301.6223(c)–1T,

amended;

301.6224(c)–3T,

amended;

301.6229(b)–2T,

added;

301–6229(f)–1T,

added;

301.6231(a)(1)–1T, amended;

301.6231(a)(6)–1T, amended;

301.6231(a)(7)–1,

amended;

301.6231(a)(7)–1, added; modifications and additions to the unified

partnership audit procedures (T.D.

8808) 10, 21

26 CFR 301.6320–1T, added; notice

and opportunity for hearing upon filing of notice of lien (T.D. 8810) 7, 19

26 CFR 301.6330–1T, added; notice

and opportunity for hearing prior to

levy (T.D. 8809) 7, 27

26 CFR 301.6404–2, added;

301.6404–2T. removed; abatement

of interest (T.D. 8789) 3, 5

26 CFR 301.7502–1, amended;

301.7502–1T, added; timely mailing

treated as timely filing / electronic

postmark (T.D. 8807) 9, 33

26 CFR 301.7701–5, amended;

301.7701–7, added; residence of

trusts and estates (T.D. 8813) 9, 34

26 CFR 602.101(b), amended; OMB

control numbers (T.D. 8818) 17, 3

Requirements for the deduction and withholding of tax on certain U.S. source

income paid to foreign persons, T.D.

8804; correction (Ann. 29) 13, 25

Roth IRAs:

Conversions on Form 8606, Nondeductible IRAs (Ann. 18) 13, 21

Rulings:

Areas in which advance rulings will not

be issued:

Associate Chief Counsel (Domestic), Associate Chief Counsel

(EBEO) (RP 3) 1, 103

Associate Chief Counsel (International) (RP 7) 1, 226

Specifications for Form 1042-S:

Rev. Proc. 98–44, 1998–32 I.R.B. 11;

correction (Ann. 12) 5, 65

Ann. 24, 1999–14 I.R.B. 12; correction

(Ann. 46) 16, 13

Section 911(d)(4) waiver; 1998 update

(RP 20) 14, 7

Standard Industry Fare Level (SIFL) rates

for the first half of 1999 (RR 12) 11,6

Technical advice to district directors and

chiefs, appeals offices, Associate Chief

Counsel (Domestic), Associate Chief

Counsel (EBEO), Associate Chief

Counsel (Enforcement Litigation), and

Associate Chief Counsel (International)

(RP 2) 1, 73

May 3, 1999

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Notes

1999–18 I.R.B.

17

May 3, 1999

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Page 18

Notes

May 3, 1999

18

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Page 20

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