Notice of Certain Transfers to Foreign Partnerships and Foreign Corporations

DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Parts 1 and 602

[TD 8817]

RIN 1545-AV70

Notice of Certain Transfers to Foreign Partnerships and Foreign

Corporations

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final regulations.

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SUMMARY: This document contains final regulations under section 6038B

relating to information reporting requirements for certain transfers by

United States persons to foreign partnerships. The regulations

implement amendments made by the Taxpayer Relief Act of 1997 that

require a United States person who transfers property to a foreign

partnership to furnish certain information with respect to such

transfer. This document also contains final regulations that require

certain cash transfers to foreign corporations to be reported. The

regulations provide guidance needed to comply with the reporting

requirements with respect to transfers of cash to foreign corporations

and transfers of property to foreign partnerships.

DATES: Effective Dates: These regulations are effective January 1,

1998, except that the amendments to Sec. 1.6038B-1 are effective

February 5, 1999.

Dates of Applicability: For dates of applicability of the

amendments to Sec. 1.6038B-1, see Sec. 1.6038B-1(g). For dates of

applicability of Sec. 1.6038B-2, see Sec. 1.6038B-2(j).

FOR FURTHER INFORMATION CONTACT: Eliana Dolgoff, 202-622-3860 (not a

toll-free number).

SUPPLEMENTARY INFORMATION:

Paperwork Reduction Act

The collections of information contained in these final regulations

have been reviewed and approved by the Office of Management and Budget

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

control number 1545-1615. Responses to these collections of information

are mandatory.

An agency may not conduct or sponsor, and a person is not required

to respond to, a collection of information unless the collection of

information displays a valid control number.

The collections of information contained in these final regulations

are in Secs. 1.6038B-1(b) and 1.6038B-2. The burden of complying with

the collection of information required to be reported on Form 8865 is

reflected in the burden for Form 8865. The burden of complying with the

collection of information required to be reported on Form 926 is

reflected in the burden for Form 926.

Comments concerning the accuracy of the burden estimates and

suggestions for reducing the burden should be sent to the Internal

Revenue Service, Attn: IRS Reports Clearance Officer, OP:FS:FP,

Washington, DC 20224, and to the Office of Management and Budget, Attn:

Desk Officer for the Department of the Treasury, Office of Information

and Regulatory Affairs, Washington, DC 20503.

Books or records relating to these collections of information must

be retained as long as their contents may become material in the

administration of any internal revenue law. Generally, tax returns and

tax return information are confidential, as required by 26 U.S.C. 6103.

Background

On September 9, 1998, the IRS published in the Federal Register

proposed regulations relating to the reporting of certain transfers to

foreign corporations and foreign partnerships under section 6038B. A

public hearing was held on November 10, 1998, even though no requests

to speak at the hearing were received. Written comments regarding the

proposed regulations, however, were received. After consideration of

all of the comments received, the proposed regulations under section

6038B are adopted as revised by this Treasury decision. The revisions

are discussed below.

[[Page 5714]]

Public Comments

Some commentators suggested that the final regulations provide that

state and local government employee retirement plans be exempt from the

section 6038B reporting requirements, asserting that contributions from

such plans to foreign partnerships will not have federal income tax

consequences. The final regulations provide that trusts relating to

state and local government employee retirement plans are not required

to report transfers to foreign partnerships under section 6038B, unless

required to do so in the instructions to Form 8865.

One commentator noted that under the proposed regulations, if a

United States person transfers property other than cash with a value in

excess of $100,000 to a foreign partnership, such person must report

the names and addresses of all the other partners of the partnership,

regardless of the size of the person's ownership interest in the

foreign partnership after the transfer. The commentator requested that

the final regulations provide that if a United States person owns less

than a 10 percent interest in the foreign partnership after the

transfer, regardless of the type of property transferred, such person

does not have to report the names and addresses of all the other

partners. Alternatively, the commentator requested that it be

recognized that a person that makes a good faith effort to obtain such

information will have reasonable cause preventing the imposition of any

penalties under section 6038B if such person fails to obtain and submit

the information.

The final regulations do not adopt the commentator's

recommendations. As in the proposed regulations, the final regulations

contain a reasonable cause exception that, if satisfied, prevents the

IRS from imposing penalties under section 6038B. Whether reasonable

cause exists for a failure to comply with the requirements of section

6038B is determined by the district director under all the facts and

circumstances. Although the final regulations do not explicitly say so,

a failure to submit the names and addresses of the other partners will

constitute a failure to comply with the requirements of section 6038B

and therefore will always be subject to the reasonable cause exception.

Commentators also questioned whether United States persons must

report indirect transfers from a foreign partnership to another foreign

partnership. The final regulations reserve on such reporting. If a

foreign partnership transfers property to another foreign partnership,

a United States person that is a partner of the transferor partnership

is not required to report that transfer until such time as the IRS and

Treasury implement rules requiring such reporting. However, the IRS

remains concerned about transfers from one foreign partnership to

another. In conjunction with its study of section 721(c), the IRS is

evaluating whether there is a need for the reporting of transfers from

foreign partnerships to foreign partnerships.

The final regulations also clarify that if a domestic partnership

contributes property to a foreign partnership, the partners of the

domestic partnership will be considered to have contributed a

proportionate share of the property transferred. Therefore, the

partners of the transferor domestic partnership may be required to

report under section 6038B transfers made by the transferor

partnership. The proposed regulations provide, however, that an

indirect transferor does not have to report the contribution on Form

8865 if certain conditions are satisfied, including the filing by the

indirect transferor of a statement with the IRS. In an attempt to

reduce the burden imposed on taxpayers, the final regulations eliminate

the requirement that indirect transferors must file a statement. If the

domestic transferor partnership properly reports the transfer of

property to a foreign partnership, a United States person that is an

indirect transferor need not report the transfer.

The final regulations also modify the reporting requirements with

respect to deemed contributions. The proposed regulations provided that

if by reason of an adjustment under section 482 a contribution required

to be reported under section 6038B is deemed to have been made, the

information required to be reported will be furnished timely if filed

by the due date (including extensions) of the income tax return for the

taxable year during which the adjustment is made. The final regulations

provide that deemed contributions resulting from IRS-initiated section

482 adjustments are not required to be reported under section 6038B.

However, taxpayers must report deemed contributions resulting from

taxpayer-initiated adjustments. Such information will be furnished

timely if filed by the due date, including extensions, for filing the

taxpayer's income tax return for the year in which the taxpayer makes

the section 482 adjustment.

Additionally, the final regulations clarify that a transfer to a

foreign partnership made on or after January 1, 1998, but before

January 1, 1999, will be considered timely reported either if it is

reported on a Form 8865 attached to the taxpayer's income tax return

for the first taxable year beginning on or after January 1, 1999, or it

is reported on a Form 926 attached to the taxpayer's income tax return

for the taxable year in which the transfer occurred.

The final regulations also clarify that transfers that were made

between August 5, 1997, and January 1, 1998, may be reported in

accordance with the provisions of the final section 6038B regulations

or in accordance with Notice 98-17(1998-11 IRB 6).

Special Analyses

It has been determined that this regulation is not a significant

regulatory action as defined in EO 12866. Therefore, a regulatory

assessment is not required. It is hereby certified that the collections

of information contained in this regulation will not have a significant

economic impact on a substantial number of small entities. This

certification is based upon the fact that these final regulations

reduce or eliminate the reporting requirements for certain United

States persons. Moreover, in general, only a United States person that

owns a significant interest in a foreign partnership, or transfers a

substantial amount to a foreign partnership, will be subject to these

regulations. Thus, a Regulatory Flexibility Analysis under the

Regulatory Flexibility Act (5 U.S.C. chapter 6) 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 the impact of the proposed regulations on small

business.

Drafting information. The principal authors of these regulations

are Eliana Dolgoff and Philip Tretiak of the Office of Associate Chief

Counsel (International). However, other personnel from the IRS and

Treasury Department participated in their development.

List of Subjects

26 CFR Part 1

Income taxes, Reporting and recordkeeping requirements.

26 CFR Part 602

Reporting and recordkeeping requirements.

[[Page 5715]]

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 in part as follows:

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

Section 1.6038B-1 also issued under 26 U.S.C. 6038B.

Section 1.6038B-2 also issued under 26 U.S.C. 6038B. * * *

Par. 2. Section 1.6038B-1 is amended as follows:

1. The section heading is revised.

2. Paragraph (b)(1)(i), first sentence, is revised.

3. The text of paragraph (b)(3) is added.

4. Paragraph (c), first sentence, is revised

5. Paragraph (g) is revised.

The additions and revisions read as follows:

Sec. 1.6038B-1 Reporting of certain transfers to foreign corporations.

* * * * *

(b) Time and manner of reporting--(1) In general--(i) Reporting

procedure. Except for stock or securities qualifying under the special

reporting rule of paragraph (b)(2) of this section, or cash, which is

subject to special rules contained in paragraph (b)(3) of this section,

any U.S. person that makes a transfer described in section

6038B(a)(1)(A), 367(d) or (e)(1), is required to report pursuant to

section 6038B and the rules of this section and must attach the

required information to Form 926, ``Return by Transferor of Property to

a Foreign Corporation.'' * * *

* * * * *

(3) Special rule for transfers of cash. A U.S. person that

transfers cash to a foreign corporation must report the transfer if--

(i) Immediately after the transfer such person holds directly,

indirectly, or by attribution (determined under the rules of section

318(a), as modified by section 6038(e)(2)) at least 10 percent of the

total voting power or the total value of the foreign corporation; or

(ii) The amount of cash transferred by such person or any related

person (determined under section 267(b)(1) through (3) and (10) through

(12)) to such foreign corporation during the 12-month period ending on

the date of the transfer exceeds $100,000.

* * * * *

(c) Information required with respect to transfers described in

section 6038B(a)(1)(A). A United States person that transfers property

to a foreign corporation in an exchange described in section

6038B(a)(1)(A) (including cash and other unappreciated property) must

provide the following information, in paragraphs labeled to correspond

with the number or letter set forth in this paragraph (c) and

Sec. 1.6038B-1T(c)(1) through (5). * * *

* * * * *

(g) Effective dates. This section applies to transfers occurring on

or after July 20, 1998, except that the first sentence of paragraph

(b)(1)(i), paragraph (b)(3), and the first sentence of paragraph (c)

apply to transfers occurring in taxable years beginning after February

5, 1999. See Sec. 1.6038B-1T for transfers occurring prior to July 20,

1998.

Par. 3. Section 1.6038B-2 is added to read as follows:

Sec. 1.6038B-2 Reporting of certain transfers to foreign partnerships.

(a) Reporting requirements--(1) Requirement to report transfers. A

United States person that transfers property to a foreign partnership

in a contribution described in section 721 (including section 721(b))

must report that transfer on Form 8865 ``Information Return of U.S.

Persons With Respect to Certain Foreign Partnerships'' pursuant to

section 6038B and the rules of this section, if--

(i) Immediately after the transfer, the United States person owns,

directly, indirectly, or by attribution, at least a 10-percent interest

in the partnership, as defined in section 6038(e)(3)(C) and the

regulations thereunder; or

(ii) The value of the property transferred, when added to the value

of any other property transferred in a section 721 contribution by such

person (or any related person) to such partnership during the 12-month

period ending on the date of the transfer, exceeds $100,000.

(2) Indirect transfer through a domestic partnership--For purposes

of this section, if a domestic partnership transfers property to a

foreign partnership in a section 721 transaction, the domestic

partnership's partners shall be considered to have transferred a

proportionate share of the property to the foreign partnership.

However, if the domestic partnership properly reports all of the

information required under this section with respect to the

contribution, no partner of the transferor partnership, whether direct

or indirect (through tiers of partnerships), is also required to report

under this section. For illustrations of this rule, see Examples 4 and

5 of paragraph (a)(7) of this section.

(3) Indirect transfer through a foreign partnership. [Reserved]

(4) Requirement to report dispositions--(i) In general. If a United

States person was required to report a transfer to a foreign

partnership of appreciated property under paragraph (a)(1) or (2) of

this section, and the foreign partnership disposes of the property

while such United States person remains a direct or indirect partner,

that United States person must report the disposition by filing Form

8865. The form must be attached to, and filed by the due date

(including extensions) of, the United States person's income tax return

for the year in which the disposition occurred.

(ii) Disposition of contributed property in nonrecognition

transaction. If a foreign partnership disposes of contributed

appreciated property in a nonrecognition transaction and substituted

basis property is received in exchange, and the substituted basis

property has built-in gain under Sec. 1.704-3(a)(8), the original

transferor is not required to report the disposition. However, the

transferor must report the disposition of the substituted basis

property in the same manner as provided for the contributed property.

(5) Time for filing Form 8865--(i) General rule. The Form 8865 on

which a transfer is reported must be attached to the transferor's

timely filed (including extensions) income tax return (including a

partnership return of income) for the tax year that includes the date

of the transfer.

(ii) Time for filing when transferor also required to report

information about the partnership under section 6038. If the United

States person required to file under this section is also required to

file a Form 8865 under section 6038 for the period in which the

transfer occurs, then the United States person must report under this

section on the Form 8865 for the foreign partnership's annual

accounting period in which the transfer occurred (not its own taxable

year) and file with its income tax return for that year as provided in

Section 6038 and the regulations thereunder.

(6) Returns to be made--(i) Separate returns for each partnership.

If a United States person transfers property reportable under this

section to more than one foreign partnership in a taxable year, the

United States person must submit a separate Form 8865 for each

partnership.

(ii) Duplicate form to be filed. If required by the instructions

[[Page 5716]]

accompanying Form 8865, a duplicate Form 8865 (including attachments

and schedules) must also be filed by the due date for submitting the

original Form 8865 under paragraph (a)(5)(i) or (ii) of this section,

as applicable.

(7) Examples. The application of this paragraph (a) may be

illustrated by the following examples:

Example 1. On November 1, 2001, US, a United States person that

uses the calendar year as its taxable year, contributes $200,000 to

FP, a foreign partnership, in a transaction subject to section 721.

After the contribution, US owns a 5% interest in FP. US must report

the contribution by filing Form 8865 for its taxable year ending

December 31, 2001. On March 1, 2002, US makes a $40,000 section 721

contribution to FP, after which US owns a 6% interest in FP. US must

report the $40,000 contribution by filing Form 8865 for its taxable

year ending December 31, 2002, because the contribution, when added

to the value of the other property contributed by US to FP during

the 12-month period ending on the date of the transfer, exceeds

$100,000.

Example 2. F, a nonresident alien, is the brother of US, a

United States person. F owns a 15% interest in FP, a foreign

partnership. US contributes $99,000 to FP, in exchange for a 1-

percent partnership interest. Under sections 6038(e)(3)(C) and

267(c)(2), US is considered to own at least a 10-percent interest in

FP and, therefore, US must report the $99,000 contribution under

this section.

Example 3. US, a United States person, owns 40 percent of FC, a

foreign corporation. FC owns a 20-percent interest in FP, a foreign

partnership. Under section 267(c)(1), US is considered to own 8

percent of FP due to its ownership of FC. US contributes $50,000 to

FP in exchange for a 5-percent partnership interest. Immediately

after the contribution, US is considered to own at least a 10-

percent interest in FP and, therefore, must report the $50,000

contribution under this section.

Example 4. US, a United States person, owns a 60-percent

interest in USP, a domestic partnership. On March 1, 2001, USP

contributes $200,000 to FP, a foreign partnership, in exchange for a

5-percent partnership interest. Under paragraph (a)(2) of this

section, US is considered as having contributed $120,000 to FP

($200,000 x 60%). However, under paragraph (a)(2), if USP properly

reports the contribution to FP, US is not required to report its

$120,000 contribution. If US directly contributes $5,000 to FP on

June 10, 2001, US must report the $5,000 contribution because US is

considered to have contributed more than $100,000 to FP in the 12-

month period ending on the date of the $5,000 contribution.

Example 5. US, a United States person, owns an 80-percent

interest in USP, a domestic partnership. USP owns an 80-percent

interest in USP1, a domestic partnership. On March 1, 2001, USP1

contributes $200,000 to FP, a foreign partnership, in exchange for a

3-percent partnership interest. Under paragraph (a)(2) of this

section, USP is considered to have contributed $160,000 ($200,000

x 80%) to FP. US is considered to have contributed $128,000 to FP

($200,000 x 80% x 80%). However, if USP1 reports the transfer of

the $200,000 to FP, neither US nor USP are required to report under

this section the amounts they are considered to have contributed.

Additionally, regardless of whether USP1 reports the $200,000

contribution, if USP reports the $160,000 contribution it is

considered to have made, US does not have to report under this

section the $128,000 contribution US is considered to have made.

(b) Transfers by trusts relating to state and local government

employee retirement plans. Trusts relating to state and local

government employee retirement plans are not required to report

transfers under this section, unless otherwise specified in the

instructions to Form 8865.

(c) Information required with respect to transfers of property.

With respect to transfers required to be reported under paragraph

(a)(1) or (2) of this section, the return must contain information in

such form or manner as Form 8865 (and its accompanying instructions)

prescribes with respect to reportable events, including--

(1) The name, address, and U.S. taxpayer identification number of

the United States person making the transfer;

(2) The name, U.S. taxpayer identification number (if any), and

address of the transferee foreign partnership, and the type of entity

and country under whose laws the partnership was created or organized;

(3) A general description of the transfer, and of any wider

transaction of which it forms a part, including the date of transfer;

(4) The names and addresses of the other partners in the foreign

partnership, unless the transfer is solely of cash and the transferor

holds less than a 10-percent interest in the transferee foreign

partnership immediately after the transfer;

(5) A description of the partnership interest received by the

United States person, including a change in partnership interest;

(6) A separate description of each item of contributed property

that is appreciated property subject to the allocation rules of section

704(c)(except to the extent that the property is permitted to be

aggregated in making allocations under section 704(c)), or is

intangible property, including its estimated fair market value and

adjusted basis.

(7) A description of other contributed property, not specified in

paragraph (c)(6) of this section, aggregated by the following

categories (with, in each case, a brief description of the property)--

(i) Stock in trade of the transferor (inventory);

(ii) Tangible property (other than stock in trade) used in a trade

or business of the transferor;

(iii) Cash;

(iv) Stock, notes receivable and payable, and other securities; and

(v) Other property.

(d) Information required with respect to dispositions of property.

In respect of dispositions required to be reported under paragraph

(a)(4) of this section, the return must contain information in such

form or manner as Form 8865 (and its accompanying instructions)

prescribes with respect to reportable events, including--

(1) The date and manner of disposition;

(2) The gain and depreciation recapture amounts, if any, realized

by the partnership; and

(3) Any such amounts allocated to the United States person.

(e) Method of reporting. Except as otherwise provided on Form 8865,

or the accompanying instructions, all amounts reported as required

under this section must be expressed in United States currency, with a

statement of the exchange rates used. All statements required on or

with Form 8865 pursuant to this section must be in the English

language.

(f) Reporting under this section not required of partnerships

excluded from the application of subchapter K--(1) Election to be

wholly excluded. The reporting requirements of this section will not

apply to any United States person in respect of an eligible partnership

as described in Sec. 1.761-2(a), if such partnership has validly

elected to be excluded from all of the provisions of subchapter K of

chapter 1 of the Internal Revenue Code in the manner specified in

Sec. 1.761-2(b)(2)(i).

(2) Deemed excluded. The reporting requirements of this section

will not apply to any United States person in respect of an eligible

partnership as described in Sec. 1.761-2(a), if such partnership is

validly deemed to have elected to be excluded from all of the

provisions of subchapter K of chapter 1 of the Internal Revenue Code in

accordance with the provisions of Sec. 1.761-2(b)(2)(ii).

(g) Deemed contributions. Deemed contributions resulting from IRS-

initiated section 482 adjustments are not required to be reported under

section 6038B. However, taxpayers must report deemed contributions

resulting from taxpayer-initiated adjustments. Such information will be

furnished timely if filed by the due date, including extensions, for

filing the taxpayer's

[[Page 5717]]

income tax return for the year in which the adjustment is made.

(h) Failure to comply with reporting requirements--(1) Consequences

of failure. If a United States person is required to file a return

under paragraph (a) of this section and fails to comply with the

reporting requirements of section 6038B and this section, then such

person is subject to the following penalties:

(i) The United States person is subject to a penalty equal to 10

percent of the fair market value of the property at the time of the

contribution. Such penalty with respect to a particular transfer is

limited to $100,000, unless the failure to comply with respect to such

transfer was due to intentional disregard.

(ii) The United States person must recognize gain (reduced by the

amount of any gain recognized, with respect to that property, by the

transferor after the transfer) as if the contributed property had been

sold for fair market value at the time of the contribution. Adjustments

to the basis of the partnership's assets and any relevant partner's

interest as a result of gain being recognized under this provision will

be made as though the gain was recognized in the year in which the

failure to report was finally determined.

(2) Failure to comply. A failure to comply with the requirements of

section 6038B includes--

(i) The failure to report at the proper time and in the proper

manner any information required to be reported under the rules of this

section; and

(ii) The provision of false or inaccurate information in purported

compliance with the requirements of this section.

(3) Reasonable cause exception. Under section 6038B(c)(2) and this

section, the provisions of paragraph (h)(1) of this section will not

apply if the transferor shows that a failure to comply was due to

reasonable cause and not willful neglect. The transferor may attempt to

do so by providing a written statement to the district director having

jurisdiction of the taxpayer's return for the year of the transfer,

setting forth the reasons for the failure to comply. Whether a failure

to comply was due to reasonable cause will be determined by the

district director under all the facts and circumstances.

(4) Statute of limitations. For exceptions to the limitations on

assessment in the event of a failure to provide information under

section 6038B, see section 6501(c)(8).

(i) Definitions--(1) Appreciated property. Appreciated property is

property that has a fair market value in excess of basis.

(2) Domestic partnership. A domestic partnership is a partnership

described in section 7701(a)(4).

(3) Foreign partnership. A foreign partnership is a partnership

described in section 7701(a)(5).

(4) Related person. Persons are related persons if they bear a

relationship described in section 267(b)(1) through (3) or (10) through

(12), after application of section 267(c) (except for (c)(3)), or in

section 707(b)(1)(B).

(5) Substituted basis property. Substituted basis property is

property described in section 7701(a)(42).

(6) Taxpayer-initiated adjustment. A taxpayer-initiated adjustment

is a section 482 adjustment that is made by the taxpayer pursuant to

Sec. 1.482-1(a)(3).

(7) United States person. A United States person is a person

described in section 7701(a)(30).

(j) Effective dates--(1) In general. This section applies to

transfers made on or after January 1, 1998. However, for a transfer

made on or after January 1, 1998, but before January 1, 1999, the

filing requirements of this section may be satisfied by--

(i) Filing a Form 8865 with the taxpayer's income tax return

(including a partnership return of income) for the first taxable year

beginning on or after January 1, 1999; or

(ii) Filing a Form 926 with the taxpayer's income tax return

(including a partnership return of income) for the taxable year in

which the transfer occurred.

(2) Transfers made between August 5, 1997 and January 1, 1998. A

United States person that made a transfer of property between August 5,

1997, and January 1, 1998, that is required to be reported under

section 6038B may satisfy its reporting requirement by reporting in

accordance with the provisions of this section or in accordance with

the provisions of Notice 98-17 (1998-11 IRB 6)(see Sec. 601.601(d)(2)

of this chapter).

* * * * *

PART 602--OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT

Par. 4. The authority citation for part 602 continues to read as

follows:

Authority: 26 U.S.C. 7805.

Par. 5. In Sec. 602.101, paragraph (c) is amended by adding an

entry in numerical order to the table to read as follows:

Sec. 602.101 OMB Control numbers.

* * * * *

(c) * * *

------------------------------------------------------------------------

Current OMB

CFR part or section where identified and described Control No.

------------------------------------------------------------------------

* * * * *

1.6038B-1.................................................. 1545-1615

* * * * *

1.6038B-2.................................................. 1545-1615

------------------------------------------------------------------------

Robert E. Wenzel,

Deputy Commissioner of Internal Revenue.

Approved: January 29, 1999.

Donald C. Lubick,

Assistant Secretary of the Treasury.

[FR Doc. 99-2798 Filed 2-4-99; 8:45 am]

BILLING CODE 4830-01-U