SEQ 0029 JOB E18-001-004 PAGE-0003 COVER

Agency decision

Ask Donna

What actually matters in this document.

Text

REVISED 01JUL96 AT 02:57 BY LR DEPTH: 66.04 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/1JUL96/E18-001

Bulletin No. 1996–21

May 20, 1996

HIGHLIGHTS

OF THIS ISSUE

These synopses are intended only as aids to the reader in

identifying the subject matter covered. They may not be

relied upon as authoritative interpretations.

INCOME TAX

Del. Order 247, page 7.

This order delegates authority to examination case

managers to accept settlement offers and execute

closing agreements on Industry Specialization Program

(ISP) and International Field Assistance Specialization

Program (IFASP) issues.

Rev. Rul. 96–26, page 5.

LIFO; price indexes; department stores. The March 1996

Bureau of Labor Statistics price indexes are accepted

for use by department stores employing the retail

inventory and last-in, first-out inventory methods for

valuing inventories for tax years ended on, or with

reference to, March 31, 1996.

GL–1–96, page 9.

Proposed regulations provide that the authority to

modify or rescind taxpayer assistance orders is limited

to the Commissioner, the Deputy Commissioner, or the

Taxpayer Ombudsman.

T.D. 8665, page 4.

Final regulations concerning transfers of cash to a

corporation or a partnership. These regulations affect

taxpayers in transactions under sections 351 or 721 of

the Code when there is an offering of stock or

partnership interest through an underwriter. Rev. Rul.

78–294 obsoleted.

Announcement 96–44, page 10.

Filers of Form 8233, Exemption From Withholding on

Compensation for Independent Personal Services of a

Nonresident Alien Individual, can apply for exemption

from withholding using the current Form 8233 (Rev.

April 1993).

ADMINISTRATIVE

Announcement 96–45, page 10.

T.D. 8175, 1988–1 C.B. 191, relating to the limitations on passive activity credits, is corrected.

Del. Order 236 (Rev. 2), page 7.

This order has been revised to eliminate terms that are

causing confusion in applying this order and to expand

the scope to include certain directly related parties to

covered transactions. Del. Order 236 (Rev. 1)

superseded.

Announcement 96–46, page 10.

T.D. 8212, 1988–2 C.B. 83, relating to the availability

of optional forms of benefit, is corrected.

Finding Lists begin on page 14.

Announcement of Disbarments and Suspensions begin on page 11.

SEQ 0030 JOB E18-002-003 PAGE-0002 MISSION

REVISED 01JUL96 AT 02:57 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/1JUL96/E18-002

Mission of the Service

The purpose of the Internal Revenue Service is to

collect the proper amount of tax revenue at the least

cost; serve the public by continually improving the

quality of our products and services; and perform in a

manner warranting the highest degree of public

confidence in our integrity, efficiency and fairness.

Statement of Principles

of Internal Revenue

Tax Administration

The function of the Internal Revenue Service is to

administer the Internal Revenue Code. Tax policy

for raising revenue is determined by Congress.

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

carry out that policy by correctly applying the laws

enacted by Congress; to determine the reasonable

meaning of various Code provisions in light of the

Congressional purpose in enacting them; and to

perform this work in a fair and impartial manner,

with neither a government nor a taxpayer point of

view.

At the heart of administration is interpretation of the

Code. It is the responsibility of each person in the

Service, charged with the duty of interpreting the

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

provision and not to adopt a strained construction in

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

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

The Service also has the responsibility of applying

and administering the law in a reasonable,

practical manner. Issues should only be raised by

examining officers when they have merit, never

arbitrarily or for trading purposes. At the same

time, the examining officer should never hesitate

to raise a meritorious issue. It is also important

that care be exercised not to raise an issue or to

ask a court to adopt a position inconsistent with

an established Service position.

Administration should be both reasonable and

vigorous. It should be conducted with as little

delay as possible and with great courtesy and

considerateness. It should never try to overreach,

and should be reasonable within the bounds of law

and sound administration. It should, however, be

vigorous in requiring compliance with law and it

should be relentless in its attack on unreal tax

devices and fraud.

SEQ 0031 JOB E18-002-003 PAGE-0003 MISSION

REVISED 01JUL96 AT 02:57 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/1JUL96/E18-002

Introduction

The Internal Revenue Bulletin is the authoritative

instrument of the Commissioner of Internal Revenue for

announcing official rulings and procedures of the

Internal Revenue Service and for publishing Treasury

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

interest. It is published weekly and may be obtained

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

consolidated semiannually into Cumulative Bulletins,

which are sold on a single-copy basis.

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

all substantive rulings necessary to promote a uniform

application of the tax laws, including all rulings that

supersede, revoke, modify, or amend any of those

previously published in the Bulletin. All published

rulings apply retroactively unless otherwise indicated.

Procedures relating solely to matters of internal

management are not published; however, statements of

internal practices and procedures that affect the rights

and duties of taxpayers are published.

Revenue rulings represent the conclusions of the

Service on the application of the law to the pivotal facts

stated in the revenue ruling. In those based on

positions taken in rulings to taxpayers or technical

advice to Service field offices, identifying details and

information of a confidential nature are deleted to

prevent unwarranted invasions of privacy and to comply

with statutory requirements.

Rulings and procedures reported in the Bulletin do not

have the force and effect of Treasury Department

Regulations, but they may be used as precedents.

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

as precedents by Service personnel in the disposition of

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

court decisions, rulings, and procedures must be

considered, and Service personnel and others concerned are cautioned against reaching the same

conclusions in other cases unless the facts and

circumstances are substantially the same.

The Bulletin is divided into four parts as follows:

Part I.—1986 Code.

This part includes rulings and decisions based on

provisions of the Internal Revenue Code of 1986.

Part II.—Treaties and Tax Legislation.

This part is divided into two subparts as follows:

Subpart A, Tax Conventions, and Subpart B, Legislation

and Related Committee Reports.

Part III.—Administrative, Procedural, and Miscellaneous.

To the extent practicable, pertinent cross references to

these subjects are contained in the other Parts and

Subparts. Also included in this part are Bank Secrecy

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

Treasury’s Office of the Assistant Secretary

(Enforcement).

Part IV.—Items of General Interest.

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

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

The first Bulletin for each month includes an index for

the matters published during the preceding month.

These monthly indexes are cumulated on a quarterly

and semiannual basis, and are published in the first

Bulletin of the succeeding quarterly and semi-annual

period, respectively.

The Bulletin Index-Digest System, a research and

reference service supplementing the Bulletin, may be

obtained from the Superintendent of Documents on a

subscription basis. It consists of four Services: Service

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

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

4, Excise Taxes. Each Service consists of a basic

volume and a cumulative supplement that provides (1)

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

digests of revenue rulings, revenue procedures, and

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

Treasury Decisions, and Tax Conventions.

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

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

SEQ 0032 JOB E18-003-005 PAGE-0004 PT 1 PGS 4REVISED 01JUL96 AT 02:57 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/1JUL96/E18-003

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

Section 351.—Transfer to

Corporation Controlled by Transferor

26 CFR 1.351–1: Transfer to corporation

controlled by transferor.

T.D. 8665

DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

Treatment of Underwriters in Section

351 and Section 721 Transactions

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Final regulations.

SUMMARY: This document contains

final regulations concerning transfers of

cash to a corporation or a partnership.

The final regulations will affect taxpayers in transactions under section

351 or section 721 when there is an

offering of stock or partnership interests through an underwriter.

EFFECTIVE DATE: May 1, 1996.

FOR FURTHER INFORMATION

CONTACT: Concerning the regulation

under section 351(a), Susan T.

Edlavitch, (202) 622-7750; concerning

the regulation under section 721(a),

James A. Quinn, (202) 622-3060 (not

toll-free numbers).

SUPPLEMENTARY INFORMATION:

Background

This document contains final regulations under section 351 and section

721. The final regulations provide for

the treatment of transfers of cash to a

corporation or a partnership pursuant to

an offering of stock or partnership

interests through an underwriter.

Section 351(a) provides that no gain

or loss is recognized if property is

transferred to a corporation by one or

more persons solely in exchange for

stock in the corporation and immediately after the exchange the person or

persons are in control (as defined in

section 368(c)) of the corporation.

Section 721(a) provides that no gain

or loss is recognized to a partnership or

to any of its partners in the case of a

contribution of property to the partnership in exchange for an interest in

the partnership.

On August 10, 1995, the IRS published in the Federal Register a notice

of proposed rulemaking (CO–26–95

[1995–2 C.B. 466]), adding regulations

under section 351 and section 721 of

the Internal Revenue Code relating to

transfers of cash to a corporation or a

partnership (60 FR 40792). The proposed rules were based on the conclusion that Situation 2 of Rev. Rul. 78–

294 (1978–2 C.B. 141) does not reflect

current underwriting practices. The proposed rules were also based on the

conclusion that underwritings of partnership interests should be treated

similarly to underwritings of stock. The

rules, under certain circumstances, disregard underwriters of stock and partnership interests for purposes of section

351 and section 721.

Public comments and the final

regulations

The IRS received few comments

from the public on the proposed

regulations. The comments received

were generally supportive of the proposed regulations but sought guidance

beyond the intended scope of the rules.

No public hearing was requested and

none was held. After consideration of

all the comments, the regulations proposed by CO–26–95 are adopted by

this Treasury decision.

In the notice of proposed rulemaking, the IRS and Treasury invited

public comment with respect to three

issues: (a) Whether the proposed rules

should apply for all tax purposes; (b)

whether the proposed rules should be

limited to underwriters; and (c) whether

the proposed rules should be limited to

cash transactions. After consideration

of these issues, the regulations proposed by CO–26–95 are adopted without any change in language. However,

although the regulations specifically

concern underwriters, it is intended that

its principles could apply equally in

factually analogous situations. For example, if the ownership by other

intermediaries in the distribution of

stock or partnership interests, such as

broker-dealers, is transitory, that

ownership should also be disregarded.

Effect on other documents

The following publication is obsolete

as of May 1, 1996: Rev. Rul. 78–294

(1978–2 C.B. 141).

Special Analyses

It has been determined that this

Treasury decision is not a significant

regulatory action as defined in EO

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

determined that section 553(b) of the

Administrative Procedure Act (5 U.S.C.

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

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

is not required. Pursuant to section

7805(f) of the Internal Revenue Code,

the notice of proposed rulemaking

preceding these regulations was submitted to the Chief Counsel for Advocacy

of the Small Business Administration

for comment on its impact on small

business.

Drafting Information

The principal authors of these regulations are Susan T. Edlavitch of the

Office of Assistant Chief Counsel

(Corporate) and Brian J. O’Connor,

formerly of the Office of Assistant

Chief Counsel (Passthroughs and Special Industries). However, other personnel from the IRS and Treasury participated in their development.

Adoption of Amendments to the

Regulations

Accordingly, 26 CFR part 1 is

amended as follows:

PART 1—INCOME TAXES

Paragraph 1. The authority citation

for part 1 is amended by adding entries

in numerical order to read as follows:

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

Section 1.351–1 also issued under 26

U.S.C. 351. * * *

Section 1.721–1 also issued under 26

U.S.C. 721. * * *

Par. 2. In §1.351–1, paragraph (a)(3)

is added to read as follows:

SEQ 0033 JOB E18-003-005 PAGE-0005 PT 1 PGS 4REVISED 01JUL96 AT 02:57 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/1JUL96/E18-003

§1.351–1 Transfer to corporation

controlled by transferor.

(a) * * *

(3) Underwritings of stock—(i) In

general. For the purpose of section

351, if a person acquires stock of a

corporation from an underwriter in

exchange for cash in a qualified

underwriting transaction, the person

who acquires stock from the underwriter is treated as transferring cash

directly to the corporation in exchange

for stock of the corporation and the

underwriter is disregarded. A qualified

underwriting transaction is a transaction

in which a corporation issues stock for

cash in an underwriting in which either

the underwriter is an agent of the

corporation or the underwriter’s ownership of the stock is transitory.

(ii) Effective date. This paragraph

(a)(3) is effective for qualified underwriting transactions occurring on or

after May 1, 1996.

§1.721–1 Nonrecognition of gain or

loss on contribution.

Margaret Milner Richardson,

Commissioner of Internal Revenue.

Approved March 26, 1996.

Leslie Samuels,

Assistant Secretary of Treasury.

Par. 3. In §1.721–1, paragraph (c) is

added to read as follows:

quires a partnership interest from an

underwriter in exchange for cash in a

qualified underwriting transaction, the

person who acquires the partnership

interest is treated as transferring cash

directly to the partnership in exchange

for the partnership interest and the

underwriter is disregarded. A qualified

underwriting transaction is a transaction

in which a partnership issues partnership interests for cash in an underwriting in which either the underwriter

is an agent of the partnership or the

underwriter’s ownership of the partnership interests is transitory.

(2) Effective date. This paragraph (c)

is effective for qualified underwriting

transactions occurring on or after May

1, 1996.

(Filed by the Office of the Federal Register on

April 30, 1996, 8:45 a.m., and published in the

issue of the Federal Register for May 1, 1996,

61 F.R. 19188)

Section 472.—Last-in, First-out

Inventories

Labor Statistics price indexes are accepted for use by department stores

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

valuing inventories for tax years ended

on, or with reference to, March 31,

1996.

Rev. Rul. 96–26

The following Department Store Inventory Price Indexes for March 1996

were issued by the Bureau of Labor

Statistics on April 12, 1996. The

indexes are accepted by the Internal

Revenue Service, under § 1.472–1(k)

of the Income Tax Regulations and

Rev. Proc. 86–46, 1986–2 C.B. 739, for

appropriate application to inventories of

department stores employing the retail

inventory and last-in, first-out inventory methods for tax years ended on, or

with reference to, March 31, 1996.

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.

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

interests—(1) In general. For the purpose of section 721, if a person ac-

LIFO; price indexes; department

stores. The March 1996 Bureau of

BUREAU OF LABOR STATISTICS, DEPARTMENT STORE

INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS

(January 1941 = 100, unless otherwise noted)

Groups

Mar. 1995

Mar. 1996

Percent Change from

Mar. 1995 to Mar. 19961

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

501.4

648.8

636.3

920.3

623.9

522.8

280.4

540.3

445.9

616.9

580.0

489.2

1026.6

778.5

839.5

507.9

652.3

651.5

897.6

643.0

535.9

284.4

556.5

426.9

625.5

590.5

490.9

1052.5

781.1

870.4

1.3

0.5

2.4

–2.5

3.1

2.5

1.4

3.0

–4.3

1.4

1.8

0.3

2.5

0.3

3.7

SEQ 0034 JOB E18-003-005 PAGE-0006 PT 1 PGS 4REVISED 01JUL96 AT 02:57 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/1JUL96/E18-003

BUREAU OF LABOR STATISTICS, DEPARTMENT STORE

INVENTORY PRICE INDEXES BY DEPARTMENT GROUPS

(January 1941 = 100, unless otherwise noted)—Continued

Groups

Mar. 1995

Mar. 1996

Percent Change from

Mar. 1995 to Mar. 19961

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

651.5

571.3

773.3

247.5

85.2

114.7

121.7

106.6

672.8

570.6

808.1

248.5

79.6

113.6

123.3

107.1

3.3

–0.1

4.5

0.4

–6.6

–1.0

1.3

0.5

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

603.7

606.1

0.4

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

465.1

470.7

1.2

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

114.2

113.8

–0.4

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

556.4

559.0

0.5

Groups 21—23: Misc.

1Absence

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

on a January 1986=100 base.

3The store total index covers all departments, including some not listed separately, except for the following: candy, foods,

liquor, tobacco, and contract departments.

2Indexes

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).

SEQ 0035 JOB E18-004-006 PAGE-0007 PT 3 PGS 7REVISED 01JUL96 AT 02:57 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/1JUL96/E18-004

Part III. Administrative, Procedural, and Miscellaneous

Delegation Order No. 236 (Rev. 2)

Delegation of Authority

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Delegation of Authority.

SUMMARY: The delegation order has

been revised to eliminate terms that are

causing unnecessary confusion in applying the delegation order and to

expand the scope to include certain

directly-related parties to covered transactions. The text of the delegation

order appears below.

EFFECTIVE DATE: March 15, 1996.

FOR FURTHER INFORMATION

CONTACT: Harry E. Lebedun,

CP:EX:C:C, Room 2036, 1111 Constitution Ave., NW, Washington, DC.

20224, (202) 622-3654 (not a toll free

number).

Delegation Order No. 236 (Rev. 2)

Effective date: March 15, 1996.

Application of Appeals Settlement to

Coordinated Examination Program

Taxpayers

The authority vested in the Commissioner of the Internal Revenue by

Treasury Order Nos. 150–07, 150–09

and 150–10 and the authority contained

in 26 U.S.C. Section 7121 is hereby

delegated as follows:

1. All examination case managers

are delegated discretionary authority

under section 7121 of the Internal

Revenue Code to accept settlement

offers on any issue in a Coordinated

Examination Program case under their

respective jurisdiction. This authority

applies, regardless of the amount of

liability sought to be compromised,

where a settlement (including a hazards

settlement) has been effected by Appeals in a previous, subsequent or the

same tax period (the settled period)

with respect to the same issue of the

same taxpayer, or of another taxpayer

who was directly involved in the

transaction or taxable event. Prior to

finalization, the proposed settlement,

together with any related closing agreement or Form 870–AD, Offer of

Waiver of Restrictions on Assessment

and Collection of Deficiency in Tax

and of (to be completed by case

manager), shall be reviewed and approved by the appropriate branch chief

within the Examination function.

2. For purposes of this delegation of

limited settlement authority, no settlement shall be effected unless all of the

following factors are present in the tax

year currently under Examination jurisdiction:

(a) The facts surrounding a transaction or taxable event in the tax period

under examination are substantially the

same as the facts in the settled period.

(b) The legal authority relating to

such issue must have remained

unchanged.

been settled by Appeals independently

of other issues (e.g. no trading of

issues) in the settled tax period.

(d) The issue must have been settled

in Appeals with respect to the same

taxpayer (including consolidated and

unconsolidated subsidiaries) or another

taxpayer who was directly involved in

the transaction or taxable event in the

settled tax period.

3. The criteria in section 2 apply to

taxpayers ‘‘directly involved’’ in the

transaction. Illustrations of a taxpayer

‘‘directly involved’’ in the transaction

are as follows:

(a) Taxpayers A and B are directly

involved in the same transaction or

taxable event in tax period 19xx where

A and B would logically receive

similar tax treatment. Taxpayer A’s

treatment of the transaction is adjusted

by Examination and settled in Appeals.

The adjustment involves the same legal

issue with respect to taxpayer B.

Examination may resolve Taxpayer B’s

case in a manner consistent with the

Appeals settlement of Taxpayer A.

(b) Taxpayers A and B are directly

involved in the same transaction or

taxable event in tax period 19xx where

A and B would logically receive

similar tax treatment. Taxpayer A’s

treatment of the transaction is adjusted

by Examination and settled by Appeals.

In addition, taxpayer A or B (or both)

is directly involved in a separate, but

similar transaction or taxable event in

the same, prior, or subsequent tax

period involving the same legal issue

as above. Such issue for taxpayers A or

B only may also be settled in a

consistent manner provided it involves

substantially the same facts.

4. All examination case managers

are delegated authority to execute

closing agreements and the Form 870–

AD in order to effect any final

settlement reached in a Coordinated

Examination case.

5. For settlement authority of Industry Specialization and International

Field Assistance Specialization Program coordinated issues, see Delegation Order No. 247.

6. The authority delegated in this

Order may not be redelegated.

7. The authority contained in this

Order supplements the authority contained in Delegation Order 97 (as

revised).

8. Delegation Order No. 236 (Rev.

1), effective June 3, 1994, is

superseded.

Dated: March 15, 1996.

Michael P. Dolan,

Deputy Commissioner.

(Filed by the Office of the Federal Register on

April 2, 1996, 8:45 a.m., and published in the

issue of the Federal Register for April 3, 1996,

61 F.R. 14852)

Delegation Order No. 247

Delegation of Authority

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Delegation of authority.

SUMMARY: Provides resolution authority to Examination on coordinated

issues in the Industry Specialization

Program (ISP) and International Field

Assistance Specialization Program

(IFASP) for those issues on which

Appeals has coordinated issue papers

containing settlement guidelines or

positions. Examination resolution may

be reached only subject to the concurrence of both the Examination and

Appeals ISP and/or IFASP Coordinators. The text of the delegation order

appears below.

SEQ 0036 JOB E18-004-006 PAGE-0008 PT 3 PGS 7REVISED 01JUL96 AT 02:57 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/1JUL96/E18-004

EFFECTIVE DATE: March 15, 1996.

FOR FURTHER INFORMATION

CONTACT: Harry E. Lebedun,

CP:EX:C:C, Room 2036, 1111 Constitution Ave., NW, Washington, DC.

20224, (202) 622-3654 (Not a toll free

number).

Order No. 247

Effective Date: March 15, 1996.

Authority of Examination Case

Managers to Accept Settlement Offers

and Execute Closing Agreements on

Industry Specialization Program (ISP)

and International Field Assistance

Specialization Program (IFASP)

Issues.

The authority vested in the Commissioner of the Internal Revenue by

Treasury Order Nos. 150–07, 150–09,

150–10 and the authority contained in

26 U.S.C. Section 7121 is hereby

delegated as follows:

1. All examination case managers

are delegated discretionary authority in

Coordinated Examination Program

cases under their jurisdiction to accept

settlement offers, regardless of the

amount of the liability sought to be

compromised, with respect to coordinated issues within the ISP and IFASP

on which Appeals has coordinated

issue papers containing settlement

guidelines or positions. Prior to finalization, the proposed settlement, together

with any related closing agreement and/

or Form 870–AD, Offer of Waiver of

Restrictions on Assessment and Collection of Deficiency in Tax and of (to be

completed by case manager), and supporting documentation, shall be reviewed and approved by the appropriate specialists/coordinators for ISP and

IFASP within Examination, International and the Appeals functions.

2. For purposes of this limited dele-

gation of settlement authority, coordinated issues within the ISP and IFASP

are those issues published in the

Internal Revenue Manual.

3. All examination case managers

are delegated authority to execute

closing agreements and/or the Form

870–AD in order to effect any settlement reached in a Coordinated Examination case involving ISP and

IFASP issues.

4. This authority delegated in this

order may not be redelegated.

5. The authority contained in this

Order supplements the authority contained in Delegation Order 97 (as

revised).

Dated: March 15, 1996.

Michael P. Dolan,

Deputy Commissioner.

(Filed by the Office of the Federal Register on

April 2, 1996, 8:45 a.m., and published in the

issue of the Federal Register for April 3, 1996,

61 F.R. 14852)

SEQ 0037 JOB E18-005-004 PAGE-0009 PT 4 PGS 9REVISED 01JUL96 AT 02:57 BY LR DEPTH: 66.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/1JUL96/E18-005

Part IV. Items of General Interest

Notice of Proposed Rulemaking

Authority to Modify or Rescind

Taxpayer Assistance Orders

GL–1–96

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Notice

rulemaking.

proposed

SUMMARY: This document contains

proposed regulations regarding taxpayer

assistance orders. The proposed regulations provide that the authority to

modify or rescind taxpayer assistance

orders is limited to the Commissioner,

the Deputy Commissioner, or the Ombudsman. The proposed regulations

affect all taxpayers with respect to

whom a taxpayer assistance order is

issued.

DATES: Written comments and requests for a public hearing must be

received by July 18, 1996.

ADDRESSES: Send submissions to:

CC:DOM:CORP:R (GL–001–96),

Room 5228, Internal Revenue Service,

POB 7604, Ben Franklin Station,

Washington, DC 20044. In the alternative, submissions may be hand delivered between the hours of 8 a.m. and 5

p.m. to: CC:DOM:CORP:R (GL–001–

96), Courier’s Desk, Internal Revenue

Service, 1111 Constitution Avenue

NW., Washington, DC.

FOR FURTHER INFORMATION

CONTACT: Robert A. Miller, (202)

622-3640 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Explanation of Provisions

This document contains a proposed

amendment to the Procedure and Administration Regulations (26 CFR part

301) under section 7811 of the Internal

Revenue Code. In Announcement 96–5

(1996–4 I.R.B. 99), Administrative Initiatives to Enhance Taxpayer Rights,

IRS indicated it was increasing the

power of the Ombudsman to assist taxpayers by affording greater protection

for taxpayer assistance orders. Effective

on the date of the Announcement 96–5,

January 4, 1996, the power to modify

or rescind a taxpayer assistance order

issued under section 7811 is limited to

the Commissioner, Deputy Commissioner, or the Ombudsman.

The current regulations provide that

taxpayer assistance orders may be

modified or rescinded by the Commissioner, Deputy Commissioner, or Ombudsman and, additionally, the following IRS officials: a district director, a

service center director, a compliance

center director, a regional director of

appeals, or the superiors of those

officials. Announcement 96–5 indicates

that proposed regulations would be

published in early 1996 to reflect the

policy restriction in authority to modify

or rescind taxpayer assistance orders.

Under the proposed regulations, officials other than the Commissioner,

Deputy Commissioner, or the Ombudsman may modify or rescind a taxpayer

assistance order only with the specific

written authorization of the Commissioner, Deputy Commissioner, or Ombudsman.

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 also has

been determined that section 553(b) of

the Administrative Procedure Act (5

U.S.C. chapter 5) and the Regulatory

Flexibility Act (5 U.S.C. chapter 6) do

not apply to these regulations, and,

therefore, a Regulatory Flexibility

Analysis is not required. Pursuant to

section 7805(f) of the Internal Revenue

Code, 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 Requests for a Public

Hearing

Before these proposed regulations

are adopted as final regulations, consideration will be given to any written

comments that are submitted timely (a

signed original and eight copies) to the

IRS. All comments will be available

for public inspection and copying. A

public hearing may be scheduled if

requested in writing by a person that

timely submits written comments. If a

public hearing is scheduled, notice of

the date, time, and place for the

hearing will be published in the Federal

Drafting Information

The principal author of these regulations is Robert A. Miller, Office of

Assistant Chief Counsel (General Litigation), CC:EL:GL. However, other

personnel from the IRS and Treasury

Department participated in their

development.

Proposed Amendments to the

Regulations

Accordingly, 26 CFR part 301 is

proposed to be amended as follows:

PART 301—PROCEDURE AND

ADMINISTRATION

Paragraph 1. The authority citation

for part 301 continues to read in part as

follows:

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

Par. 2. Section 301.7811–1 is

amended by revising paragraphs (d)

and (h) to read as follows:

§301.7811–1 Taxpayer Assistance

Orders.

(d) Authority to modify or rescind

limited to Commissioner, Deputy Commissioner, or Taxpayer Ombudsman.

The Commissioner, the Deputy Commissioner, and the Ombudsman may

modify or rescind a taxpayer assistance

order. A district director, a service

center director, a compliance center

director, a regional director of appeals,

or the superiors of those officials, may

modify or rescind a taxpayer assistance

order only with the specific written

authorization of the Commissioner, Deputy Commissioner, or the Ombudsman.

(h) Effective dates. This section is

effective on March 20, 1992, except

paragraph (d) of this section which is

1996– 27 I.R.B.

SEQ 0038 JOB E18-005-004 PAGE-0010 PT 4 PGS 9REVISED 01JUL96 AT 02:57 BY LR DEPTH: 66.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/1JUL96/E18-005

effective on the date 90 days after the

date of publication of these regulations

as final regulations in the Federal

Margaret Milner Richardson,

Commissioner of Internal Revenue.

(Filed by the Office of the Federal Register on

April 18, 1996, 8:45 a.m., and published in the

issue of the Federal Register for April 19,

1996, 61 F.R. 17265)

Filers of Form 8233, Exemption From

Withholding on Compensation for

Independent Personal Services of a

Nonresident Alien Individual

Announcement 96–44

Under Internal Revenue Code section

1441, payments made to nonresident

alien independent contractors, students,

professors, teachers, and researchers are

normally subject to 30% Federal income tax withholding. However, some

payments may be exempted from withholding because of a tax treaty or the

personal exemption amount. Form 8233

is used to establish that the amounts

concerned qualify for the exemption

from withholding.

Form 8233 is being revised and

should be available by January 1997.

Until then, filers can still apply for

exemption from withholding using the

current Form 8233 (Rev. April 1993)

that has an (OMB) expiration date of

April 30, 1996. You can order Form

8233 by calling 1-800-TAX-FORM

(1-800-829-3676).

Income Tax; Taxable Years Beginning

After December 31, 1953; Limitations

on Passive Activity Losses and

Credits; Correction

Announcement 96–45

Thursday, February 25, 1988 (53 FR

5686), relating to the limitations on

passive activity credits.

EFFECTIVE

1988.

DATE:

February

25,

FOR FURTHER INFORMATION

CONTACT: Michael L. Slaughter,

(202) 622-7190 (not a toll-free

number).

SUPPLEMENTARY INFORMATION:

Background

The temporary regulations that are

the subject of these correction are

under sections 469 of the Internal

Revenue Code.

SUMMARY: This document contains a

correction to temporary regulations (TD

8175 [1988–1 C.B. 191]), which were

published in the Federal Register

1996– 27 I.R.B.

SUMMARY: This document contains a

correction to final regulations (TD

8212 [1988–2 C.B. 83]), which were

published in the Federal Register Monday, July 11, 1988 (53 FR 26050),

relating to the availability of optional

forms of benefit.

EFFECTIVE DATE: July 11, 1988.

FOR FURTHER INFORMATION

CONTACT: David Munroe,

(202) 622-6080 (not a toll-free

number).

SUPPLEMENTARY INFORMATION:

Background

Need for Correction

As published, the temporary regulations (TD 8175) contain errors which

may prove to be misleading and are in

need of clarification.

PART 1—INCOME TAXES

Paragraph 1. The authority citation

for part 1 continues to read in part as

follows:

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

§ 1.469–5T [Corrected]

Par. 2. In § 1.469–5T, paragraphs

(d)(A) and (d)(B) are correctly designated as paragraphs (d)(1) and (d)(2).

Cynthia E. Grigsby,

Chief, Regulations Unit,

Assistant Chief Counsel (Corporate).

(Filed by the Office of the Federal Register on

March 29, 1996, 8:45 a.m., and published in

the issue of the Federal Register for April 1,

1996, 61 F.R. 14247)

AGENCY: Internal Revenue Service,

Treasury.

ACTION: Correcting amendment.

Limitations on Availability of

Benefits; Correction

Announcement 96–46

AGENCY: Internal Revenue Service,

Treasury.

The final regulations that are the

subject of this correction is under

sections 401, and 411 of the Internal

Revenue Code.

Need for Correction

As published, the final regulations

(TD 8212) contains an error which may

prove to be misleading and is in need

of clarification.

PART 1—INCOME TAXES

Paragraph 1. The authority citation

for part 1 continues to read in part as

follows:

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

§ 1.401(a)–4 [Corrected]

Par. 2. Section 1.401(a)–4 is

amended by removing paragraph

(a)(2)(ii)(B) in ‘‘A–2’’.

Cynthia E. Grigsby,

Chief, Regulations Unit,

Assistant Chief Counsel (Corporate).

(Filed by the Office of the Federal Register on

March 29, 1996, 8:45 a.m., and published in

the issue of the Federal Register for April 1,

1996, 61 F.R. 14247)

SEQ 0040 JOB E18-050-003 PAGE-0011 ANN DISBARMENT

REVISED 01JUL96 AT 02:57 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/1JUL96/E18-050

Announcement of the Disbarment, Suspension, or Consent to Voluntary

Suspension of Attorneys, Certified Public Accountants, Enrolled Agents and

Enrolled Actuaries From Practice Before the Internal Revenue Service

Under 31 Code of Federal Regulations, Part 10, an attorney, certified

public accountant, enrolled agent or enrolled actuary, in order to avoid the institution or conclusion of a proceeding

for his disbarment or suspension from

practice before the Internal Revenue

Service, may offer his consent to

suspension from such practice. The

Director of Practice, in his discretion,

may suspend an attorney, certified

public accountant, enrolled agent or

enrolled actuary in accordance with the

consent offered.

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

Revenue Service matter from directly

or indirectly employing, accepting

assistance from, being employed by,

or sharing fees with, any practitioner disbarred or suspended from

practice before the Internal Revenue

Service.

To enable attorneys, certified public

accountants, enrolled agents and enrolled actuaries to identify practitioners

under consent suspension from practice

before the Internal Revenue Service,

the Director of Practice will announce

in the Internal Revenue Bulletin the

names and addresses of practitioners

who have been suspended from such

practice, their designation as attor-

ney, certified public accountant, enrolled agent or enrolled actuary and

date or period of suspension. This announcement will appear in the weekly

Bulletin at the earliest practicable date

after such action and will continue to

appear in the weekly Bulletins for five

successive weeks or for as many weeks

as is practicable for each attorney,

certified public accountant, enrolled

agent or enrolled actuary so suspended

and will be consolidated and published

in the Cumulative Bulletin.

The following individuals have been

placed under consent suspension from

practice before the Internal Revenue

Service:

Name

Address

Designation

Date of Suspension

Behrens, William

Warter, J. Christopher

Leckie, Jerry B.

Retzlaff, Gene

Cahill, Donal

Guidera, George C.

Kirk, Gregg T.

Brock, Guy Charles

Mathews, Thomas

Farnsworth Jr., Harold

King, John C.

Kenosha, WI

South Bend, IN

Macon, GA

Hortonville, WI

Stratford, CT

Straford, CT

Dallas, TX

Spokane, WA

Cincinnati, OH

Starke, FL

Wichita, KS

Enrolled Agent

Attorney

Enrolled Agent

Attorney

CPA

Attorney

March 6, 1996 to May 5, 1996

Indefinite from March 8, 1996

March 9, 1996 to March 8, 1999

March 18, 1996 to July 17, 1996

April 4, 1996 to April 3, 1997

April 11, 1996 to October 10, 1996

Indefinite from May 1, 1996

May 1, 1996 to August 31, 1996

May 1, 1996 to April 30, 1998

May 1, 1996 to August 31, 1996

Announcement of the Expedited Suspension of Attorneys, Certified Public

Accountants, Enrolled Agents, and Enrolled Actuaries From Practice Before the

Internal Revenue Service

Under title 31 of the Code of Federal

Regulations, section 10.76, the Director

of Practice is authorized to immediately

suspend from practice before the Internal Revenue Service any practitioner

who, within five years, from the date

the expedited proceeding is instituted,

(1) has had a license to practice as an

attorney, certified public accountant, or

actuary suspended or revoked for

cause; or (2) has been convicted of any

crime under title 26 of the United

States Code or, of a felony under title

18 of the United States Code involving

dishonesty or breach of trust.

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

Revenue Service matter from directly

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

sharing fees with, any practitioner

disbarred or suspended from practice

before the Internal Revenue Service.

To enable attorneys, certified public

accountants, enrolled agents, and enrolled actuaries to identify practitioners

under expedited suspension from practice before the Internal Revenue Service, the Director of Practice will announce in the Internal Revenue Bulletin

the names and addresses of practitioners who have been suspended from such

practice, their designation as attorney,

certified public accountant, enrolled

agent, or enrolled actuary, and date or

period of suspension. This announcement will appear in the weekly Bulletin

at the earliest practicable date after

such action and will continue to appear

in the weekly Bulletins for five successive weeks or for as many weeks as is

practicable for each attorney, certified

public accountant, enrolled agent, or

enrolled actuary so suspended and will

be consolidated and published in the

Cumulative Bulletin.

The following individuals have been

placed under suspension from practice

before the Internal Revenue Service by

virtue of the expedited proceeding

provisions of the applicable regulations:

SEQ 0041 JOB E18-050-003 PAGE-0012 ANN DISBARMENT

REVISED 01JUL96 AT 02:57 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/1JUL96/E18-050

Name

Address

Designation

Date of Suspension

Noske, Joan M.

Wahl, Roger W.

Stojanov, Dragan

Gay, Randall D.

Sheffey, Ralph

Doyle, Robert

Singer, Michael G.

Mohme, Robert H.

Vogelei, George Mac

Gaskins, Oscar N.

Gawel, Michael S.

Richmond, MN

Martinez, GA

Detroit, MI

Honolulu, HI

LaCrosse, WI

Sacramento, CA

Minnetonka, MN

St. Louis, MO

Novato, CA

Cherry Hill, NJ

Niagara Falls, NY

CPA

Attorney

CPA

Attorney

CPA

Attorney

Indefinite from March 1, 1996

Indefinite from March 13, 1996

Indefinite from March 19, 1996

Indefinite from March 20, 1996

Indefinite from March 26, 1996

Indefinite from March 29, 1996

SEQ 0042 JOB E18-051-002 PAGE-0013 TERMS

REVISED 01JUL96 AT 02:58 BY LR DEPTH: 65.01 PICAS WIDTH 46 PICAS

COMPOSITE COLOR

778/20052/1JUL96/E18-051

Definition of Terms

Revenue rulings and revenue procedures (hereinafter referred to as ‘‘rulings’’) that have an effect on previous

rulings use the following defined terms

to describe the effect:

Amplified describes a situation where

no change is being made in a prior

published position, but the prior position is being extended to apply to a

variation of the fact situation set forth

therein. Thus, if an earlier ruling held

that a principle applied to A, and the

new ruling holds that the same principle also applies to B, the earlier ruling

is amplified. (Compare with modified,

below).

Clarified is used in those instances

where the language in a prior ruling is

being made clear because the language

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

a prior ruling is being changed.

Distinguished describes a situation

where a ruling mentions a previously

published ruling and points out an

essential difference between them.

Modified is used where the substance

of a previously published position is

being changed. Thus, if a prior ruling

held that a principle applied to A but

not to B, and the new ruling holds that

it applies to both A and B, the prior

ruling is modified because it corrects a

published position. (Compare with amplified and clarified, above).

Obsoleted describes a previously

published ruling that is not considered

determinative with respect to future

transactions. This term is most commonly used in a ruling that lists

previously published rulings that are

obsoleted because of changes in law or

regulations. A ruling may also be

obsoleted because the substance has

been included in regulations subsequently adopted.

Revoked describes situations where

the position in the previously published

ruling is not correct and the correct

position is being stated in the new

ruling.

Superseded describes a situation

where the new ruling does nothing

more than restate the substance and

situation of a previously published

ruling (or rulings). Thus, the term is

used to republish under the 1986 Code

and regulations the same position published under the 1939 Code and regulations. The term is also used when it is

desired to republish in a single ruling a

series of situations, names, etc., that

were previously published over a

period of time in separate rulings.

If the new ruling does more than

restate the substance of a prior ruling, a

combination of terms is used. For

example, modified and superseded describes a situation where the substance

of a previously published ruling is

being changed in part and is continued

without change in part and it is desired

to restate the valid portion of the

previously published ruling in a new

ruling that is self contained. In this

case the previously published ruling is

first modified and then, as modified, is

superseded.

Supplemented is used in situations in

which a list, such as a list of the names

of countries, is published in a ruling

and that list is expanded by adding

further names in subsequent rulings.

After the original ruling has been

supplemented several times, a new

ruling may be published that includes

the list in the original ruling and the

additions, and supersedes all prior

rulings in the series.

Suspended is used in rare situations

to show that the previous published

rulings will not be applied pending

some future action such as the issuance

of new or amended regulations, the

outcome of cases in litigation, or the

outcome of a Service study.

Abbreviations

E.O.—Executive Order.

ER—Employer.

ERISA—Employee Retirement Income Security Act.

EX—Executor.

F—Fiduciary.

FC—Foreign Country.

FICA—Federal Insurance Contribution Act.

FISC—Foreign International Sales Company.

FPH—Foreign Personal Holding Company.

F.R.—Federal Register.

FUTA—Federal Unemployment Tax Act.

FX—Foreign Corporation.

G.C.M.—Chief Counsel’s Memorandum.

GE—Grantee.

GP—General Partner.

GR—Grantor

IC—Insurance Company.

I.R.B.—Internal Revenue Bulletin.

LE—Lessee.

LP—Limited Partner.

LR—Lessor.

M—Minor.

Nonacq.—Nonacquiescence.

O—Organization.

P—Parent Corporation.

PHC—Personal Holding Company.

PO—Possession of the U.S.

PR—Partner.

PRS—Partnership.

PTE—Prohibited Transaction Exemption.

Pub. L.—Public Law.

REIT—Real Estate Investment Trust.

Rev. Proc.—Revenue Procedure.

Rev. Rul.—Revenue Ruling.

S—Subsidiary.

S.P.R.—Statements of Procedural Rules.

Stat.—Statutes at Large.

T—Target Corporation.

T.C.—Tax Court.

T.D.—Treasury Decision.

TFE—Transferee.

TFR—Transferor.

T.I.R.—Technical Information Release.

TP—Taxpayer.

TR—Trust.

TT—Trustee.

U.S.C.—United States Code.

X—Corporation.

Y—Corporation.

Z—Corporation.

The following abbreviations in current use and

formerly used will appear in material published

in the Bulletin.

A—Individual.

Acq.—Acquiescence.

B—Individual.

BE—Beneficiary.

BK—Bank.

B.T.A.—Board of Tax Appeals.

C.—Individual.

C.B.—Cumulative Bulletin.

CFR—Code of Federal Regulations.

CI—City.

COOP—Cooperative.

Ct.D.—Court Decision.

CY—County.

D—Decedent.

DC—Dummy Corporation.

DE—Donee.

Del. Order—Delegation Order.

DISC—Domestic International Sales Corporation.

DR—Donor.

E—Estate.

EE—Employee.

SEQ 0043 JOB E18-052-002 PAGE-0014 FINDING LIST

REVISED 01JUL96 AT 02:58 BY LR DEPTH: 65.01 PICAS WIDTH 41.11 PICAS

COMPOSITE COLOR

778/20052/1JUL96/E18-052

Numerical Finding List1

Bulletins 1996–1 through 1996–20

Announcements:

96–1, 1996–2 I.R.B. 57

96–2, 1996–2 I.R.B. 57

96–3, 1996–2 I.R.B. 57

96–4, 1996–3 I.R.B. 50

96–5, 1996–4 I.R.B. 99

96–6, 1996–5 I.R.B. 43

96–7, 1996–5 I.R.B. 44

96–8, 1996–7 I.R.B. 56

96–9, 1996–8 I.R.B. 30

96–10, 1996–8 I.R.B. 30

96–11, 1996–9 I.R.B. 11

96–12, 1996–11 I.R.B. 30

96–13, 1996–12 I.R.B. 33

96–14, 1996–12 I.R.B. 35

96–15, 1996–11 I.R.B. 9

96–16, 1996–13 I.R.B. 22

96–17, 1996–13 I.R.B. 22

96–18, 1996–15 I.R.B. 15

96–19, 1996–15 I.R.B. 15

96–20, 1996–15 I.R.B. 15

96–21, 1996–15 I.R.B. 15

96–22, 1996–15 I.R.B. 16

96–23, 1996–18 I.R.B. 7

96–24, 1996–16 I.R.B. 35

96–25, 1996–17 I.R.B. 13

96–26, 1996–17 I.R.B. 13

96–27, 1996–17 I.R.B. 16

96–28, 1996–17 I.R.B. 16

96–29, 1996–17 I.R.B. 17

96–30, 1996–17 I.R.B. 17

96–31, 1996–17 I.R.B. 18

96–32, 1996–17 I.R.B. 18

96–33, 1996–18 I.R.B. 12

96–34, 1996–18 I.R.B. 13

96–35, 1996–18 I.R.B. 13

96–36, 1996–18 I.R.B. 13

96–37, 1996–18 I.R.B. 14

96–38, 1996–19 I.R.B. 84

96–39, 1996–19 I.R.B. 84

96–40, 1996–19 I.R.B. 85

96–41, 1996–20 I.R.B. 18

96–42, 1996–20 I.R.B. 18

96–43, 1996–20 I.R.B. 18

Delegations Orders:

232 (Rev. 2), 1996–7 I.R.B. 49

239 (Rev. 1), 1996–7 I.R.B. 49

Notices:

96–2, 1996–2 I.R.B. 15

96–1, 1996–3 I.R.B. 30

96–4, 1996–4 I.R.B. 69

96–5, 1996–6 I.R.B. 22

96–6, 1996–5 I.R.B. 27

96–7, 1996–6 I.R.B. 22

96–8, 1996–6 I.R.B. 23

Notices—Continued

Revenue Procedures—Continued

96–9, 1996–6 I.R.B. 26

96–10, 1996–7 I.R.B. 47

96–11, 1996–8 I.R.B. 19

96–12, 1996–10 I.R.B. 29

96–13, 1996–10 I.R.B. 29

96–14, 1996–12 I.R.B. 11

96–15, 1996–13 I.R.B. 19

96–16, 1996–13 I.R.B. 20

96–17, 1996–13 I.R.B. 20

96–18, 1996–14 I.R.B. 27

96–19, 1996–14 I.R.B. 28

96–20, 1996–14 I.R.B. 30

96–21, 1996–14 I.R.B. 30

96–22, 1996–14 I.R.B. 30

96–23, 1996–16 I.R.B. 23

96–24, 1996–16 I.R.B. 23

96–25, 1996–17 I.R.B. 11

96–26, 1996–18 I.R.B. 4

96–27, 1996–18 I.R.B. 4

96–28, 1996–19 I.R.B. 7

96–29, 1996–19 I.R.B. 7

96–30, 1996–20 I.R.B. 11

96–13, 1996–3 I.R.B. 31

96–14, 1996–3 I.R.B. 41

96–15, 1996–3 I.R.B. 41

96–16, 1996–3 I.R.B. 45

96–17, 1996–4 I.R.B. 69

96–18, 1996–4 I.R.B. 73

96–19, 1996–4 I.R.B. 80

96–20, 1996–4 I.R.B. 88

96–21, 1996–4 I.R.B. 96

96–22, 1996–5 I.R.B. 27

96–23, 1996–5 I.R.B. 27

96–24, 1996–5 I.R.B. 28

96–24A, 1996–15 I.R.B. 12

96–25, 1996–8 I.R.B. 19

96–26, 1996–8 I.R.B. 22

96–27, 1996–11 I.R.B. 27

96–28, 1996–14 I.R.B. 31

96–29, 1996–16 I.R.B. 24

96–30, 1996–19 I.R.B. 8

96–31, 1996–20 I.R.B. 11

96–32, 1996–20 I.R.B. 14

Proposed Regulations:

96–1, 1996–1 I.R.B. 7

96–2, 1996–2 I.R.B. 5

96–3, 1996–2 I.R.B. 14

96–6, 1996–2 I.R.B. 8

96–4, 1996–3 I.R.B. 16

96–5, 1996–3 I.R.B. 29

96–7, 1996–3 I.R.B. 12

96–8, 1996–4 I.R.B. 62

96–9, 1996–4 I.R.B. 5

96–10, 1996–4 I.R.B. 27

96–11, 1996–4 I.R.B. 28

96–12, 1996–9 I.R.B. 4

96–13, 1996–10 I.R.B. 19

96–14, 1996–6 I.R.B. 20

96–15, 1996–11 I.R.B. 9

96–16, 1996–11 I.R.B. 4

96–17, 1996–13 I.R.B. 5

96–18, 1996–13 I.R.B. 4

96–19, 1996–14 I.R.B. 24

96–20, 1996–15 I.R.B. 5

96–21, 1996–15 I.R.B. 7

96–22, 1996–15 I.R.B. 9

96–23, 1996–15 I.R.B. 11

96–24, 1996–19 I.R.B. 5

96–25, 1996–19 I.R.B. 4

DL–1–95, 1996–6 I.R.B. 28

EE–20–95, 1996–5 I.R.B. 15

EE–34–95, 1996–3 I.R.B. 49

EE–35–95, 1996–5 I.R.B. 19

EE–53–95, 1996–5 I.R.B. 23

EE–55–95, 1996–12 I.R.B. 12

EE–106–82, 1996–10 I.R.B. 31

EE–142–87, 1996–12 I.R.B. 13

EE–148–81, 1996–11 I.R.B. 29

IA–3–94, 1996–17 I.R.B. 12

IA–33–95, 1996–4 I.R.B. 99

IA–41–93, 1996–11 I.R.B. 29

INTL–3–95, 1996–6 I.R.B. 29

INTL–9–95, 1996–5 I.R.B. 25

INTL–54–95, 1996–14 I.R.B. 39

INTL–62–90; INTL–32–93;

INTL–52–86; INTL–52–94,

1996–19 I.R.B. 26

PS–2–95, 1996–7 I.R.B. 50

PS–4–96, 1996–18 I.R.B. 5

PS–6–95, 1996–16 I.R.B. 27

Revenue Procedures:

96–1, 1996–1 I.R.B. 8

96–2, 1996–1 I.R.B. 60

96–3, 1996–1 I.R.B. 82

96–4, 1996–1 I.R.B. 94

96–5, 1996–1 I.R.B. 129

96–6, 1996–1 I.R.B. 151

96–7, 1996–1 I.R.B. 185

96–8, 1996–1 I.R.B. 187

96–8A, 1996–9 I.R.B. 10

96–9, 1996–2 I.R.B. 15

96–10, 1996–2 I.R.B. 17

96–11, 1996–2 I.R.B. 18

96–12, 1996–3 I.R.B. 30

See footnote at the end of list.

Revenue Rulings:

Treasury Decisions:

8630, 1996–3 I.R.B. 19

8631, 1996–3 I.R.B. 7

8632, 1996–4 I.R.B. 6

8633, 1996–4 I.R.B. 20

8634, 1996–3 I.R.B. 17

8635, 1996–3 I.R.B. 5

8636, 1996–4 I.R.B. 64

8637, 1996–4 I.R.B. 29

8638, 1996–5 I.R.B. 5

8639, 1996–5 I.R.B. 12

SEQ 0044 JOB E18-052-002 PAGE-0015 FINDING LIST

REVISED 01JUL96 AT 02:58 BY LR DEPTH: 65.01 PICAS WIDTH 32.08 PICAS

COMPOSITE COLOR

778/20052/1JUL96/E18-052

Numerical Finding List1—Continued

Bulletins 1996–1 through 1996–20

Treasury Decisions—Continued

8640, 1996–2 I.R.B. 10

8641, 1996–6 I.R.B. 4

8642, 1996–7 I.R.B. 4

8643, 1996–11 I.R.B. 4

8644, 1996–7 I.R.B. 16

8645, 1996–8 I.R.B. 4

8646, 1996–8 I.R.B. 10

8647, 1996–9 I.R.B. 7

8648, 1996–10 I.R.B. 23

8649, 1996–9 I.R.B. 5

8650, 1996–10 I.R.B. 5

8651, 1996–11 I.R.B. 24

8652, 1996–11 I.R.B. 11

8653, 1996–12 I.R.B. 4

8654, 1996–11 I.R.B. 14

8655, 1996–12 I.R.B. 9

8656, 1996–13 I.R.B. 9

8657, 1996–14 I.R.B. 4

8658, 1996–14 I.R.B. 13

8659, 1996–16 I.R.B. 4

8660, 1996–17 I.R.B. 4

8661, 1996–17 I.R.B. 7

8664, 1996–20 I.R.B. 7

8667, 1996–20 I.R.B. 4

1A cumulative list of all Revenue Rulings,

Revenue Procedures, Treasury Decisions, etc.,

published in Internal Revenue Bulletins 1995–

27 through 1995–52 will be found in Internal

Revenue Bulletin 1996–1, dated January 2,

1996.

SEQ 0045 JOB E18-052-002 PAGE-0016 FINDING LIST

REVISED 01JUL96 AT 02:58 BY LR DEPTH: 65.01 PICAS WIDTH 41.11 PICAS

COMPOSITE COLOR

778/20052/1JUL96/E18-052

Revenue Procedures—Continued

92–85

Modified by

96–1, 1996–1 I.R.B. 8

95–7

Superseded by

96–7, 1996–1 I.R.B. 185

93–16

Superseded by

96–11, 1996–2 I.R.B. 18

95–8

Superseded by

96–8, 1996–1 I.R.B. 187

93–46

Superseded in part by

96–17, 1996–4 I.R.B. 69

95–13

Superseded by

96–20, 1996–4 I.R.B. 88

239

Amended by

239 (Rev. 1), 1996–7 I.R.B. 49

Superseded by

96–18, 1996–4 I.R.B. 73

Revenue Procedures:

94–16

Modified by

96–29, 1996–16 I.R.B. 24

95–20

Superseded by

96–24, 1996–5 I.R.B. 28

Finding List of Current Action on

Previously Published Items1

Bulletins 1996–1 through 1996–20

*Denotes entry since last publication

Delegation Orders:

232 (Rev. 1)

Superseded by

232 (Rev. 2), 1996–7 I.R.B. 49

65–17

Modified by

96–14, 1996–3 I.R.B. 41

66–49

Modified by

96–15, 1996–3 I.R.B. 41

94–18

Superseded in part by

96–17, 1996–4 I.R.B. 69

Superseded by

96–18, 1996–4 I.R.B. 73

88–32

Obsoleted by

96–15, 1996–3 I.R.B. 41

94–59

Superseded in part by

96–17, 1996–4 I.R.B. 69

88–33

Obsoleted by

96–15, 1996–3 I.R.B. 41

Superseded by

96–18, 1996–4 I.R.B. 73

89–19

Superseded by

96–17, 1996–4 I.R.B. 69

89–48

Superseded in part by

96–17, 1996–4 I.R.B. 69

91–22

Modified by

96–1, 1996–1 I.R.B. 8

91–22

Amplified by

96–13, 1996–3 I.R.B. 31

91–23

Superseded by

96–13, 1996–3 I.R.B. 31

91–24

Superseded by

96–14, 1996–3 I.R.B. 41

91–26

Superseded by

96–13, 1996–3 I.R.B. 31

92–20

Modified by

96–1, 1996–1 I.R.B. 8

96–31, 1996–20 I.R.B. 11

94–62

Modified by

96–29, 1996–16 I.R.B. 24

94–77

Superseded by

96–28, 1996–14 I.R.B. 31

95–1

Superseded by

96–1, 1996–1 I.R.B. 8

95–2

Superseded by

96–2, 1996–1 I.R.B. 60

95–3

Superseded by

96–3, 1996–1 I.R.B. 82

95–4

Superseded by

96–4, 1996–1 I.R.B. 94

95–5

Superseded by

96–5, 1996–1 I.R.B. 129

95–6

Superseded by

96–6, 1996–1 I.R.B. 151

95–66

Modified by

96–25, 1996–19 I.R.B. 4

1A cumulative finding list for previously

published items mentioned in Internal Revenue

Bulletins 1995–27 through 1995–52 will be

found in Internal Revenue Bulletin 1996–1, dated

January 2, 1996.

95–50

Superseded by

96–3, 1996–1 I.R.B. 82

96–3

Amplified by

96–12, 1996–3 I.R.B. 30

Revenue Rulings:

66–307

Obsoleted by

96–3, 1996–2 I.R.B. 14

72–437

Modified by

96–13, 1996–3 I.R.B. 31

80–80

Obsoleted by

96–3, 1996–2 I.R.B. 14

82–80

Modified by

96–14, 1996–3 I.R.B. 41

92–19

Supplemented in part

96–2, 1996–2 I.R.B. 5

92–75

Clarified by

96–13, 1996–3 I.R.B. 31

95–10

Supplemented and superseded by

96–4, 1996–3 I.R.B. 16

95–11

Supplemented and superseded by

96–5, 1996–3 I.R.B. 29

96–24

Modified and amplified by

96–24A, 1996–15 I.R.B. 12

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.