Académique Documents
Professionnel Documents
Culture Documents
2003-41
October 14, 2003
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.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of court decisions, rulings, and procedures must be considered,
the Commissioner of Internal Revenue for announcing official and Service personnel and others concerned are cautioned
rulings and procedures of the Internal Revenue Service and for against reaching the same conclusions in other cases unless
publishing Treasury Decisions, Executive Orders, Tax Conven- the facts and circumstances are substantially the same.
tions, legislation, court decisions, and other items of general
interest. It is published weekly and may be obtained from the
The Bulletin is divided into four parts as follows:
Superintendent of Documents on a subscription basis. Bul-
letin contents are consolidated semiannually into Cumulative
Bulletins, which are sold on a single-copy basis. 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 sub-
stantive rulings necessary to promote a uniform application of
the tax laws, including all rulings that supersede, revoke, mod- Part II.—Treaties and Tax Legislation.
ify, or amend any of those previously published in the Bulletin. This part is divided into two subparts as follows: Subpart A,
All published rulings apply retroactively unless otherwise indi- Tax Conventions and Other Related Items, and Subpart B, Leg-
cated. Procedures relating solely to matters of internal man- islation and Related Committee Reports.
agement are not published; however, statements of internal
practices and procedures that affect the rights and duties of Part III.—Administrative, Procedural, and Miscellaneous.
taxpayers are published. To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
Revenue rulings represent the conclusions of the Service on the included in this part are Bank Secrecy Act Administrative Rul-
application of the law to the pivotal facts stated in the revenue ings. Bank Secrecy Act Administrative Rulings are issued by
ruling. In those based on positions taken in rulings to taxpayers the Department of the TreasuryÊs Office of the Assistant Sec-
or technical advice to Service field offices, identifying details retary (Enforcement).
and information of a confidential nature are deleted to prevent
unwarranted invasions of privacy and to comply with statutory Part IV.—Items of General Interest.
requirements. This part includes notices of proposed rulemakings, disbar-
ment 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 The first Bulletin for each month includes a cumulative index
may be used as precedents. Unpublished rulings will not be for the matters published during the preceding months. These
relied on, used, or cited as precedents by Service personnel in monthly indexes are cumulated on a semiannual basis, and
the disposition of other cases. In applying published rulings and are published in the first Bulletin of the succeeding semiannual
procedures, the effect of subsequent legislation, regulations, 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.
Par. 4. Section 1.897–3 is amended as 1. For each of the paragraphs listed in the second column and add in its place the
follows: the first column, remove the language in language in the third column:
2. In paragraph (c)(1)(i), remove the Par. 5. Section 1.897–5 is added to read Par. 6. In §1.897–5T, paragraph (d)(1)
parenthetical “(if any)” after the words as follows: (iii)(F) is revised to read as follows:
“identifying number”.
3. Paragraph (h) is added to read as §1.897–5 Corporate Distributions. §1.897–5T Corporate distributions
follows: (temporary).
(a) through (d)(1)(iii)(E) [Reserved].
§1.897–3 Election by foreign corporation For further guidance, see §1.897–5T(a) *****
to be treated as a domestic corporation through (d)(1)(iii)(E). (d) * * * (1) * * *
under section 897(i). (d)(1)(iii)(F) Identification by name (iii) * * *
and address of the distributee or transferee, (F) [Reserved]. For further guidance,
***** including the distributee’s or transferee’s see §1.897–5(d)(1)(iii)(F).
(h) Effective date. The requirement in taxpayer identification number;
paragraph (c)(1)(i) of this section that the (d)(1)(iii)(G) through (d)(4) [Re- *****
statement making the section 897(i) elec- served]. For further guidance, see
tion contain the identifying number of the §1.897–5T(d)(1)(iii)(G) through (d)(4). §1.897–6T [Amended]
foreign corporation (in all cases) is appli- (e) Effective date. This section is ap-
cable November 4, 2003. plicable to transfers and distributions after Par. 7. Section 1.897–6T is amended as
November 4, 2003. follows:
[Name of transferor] understands that this certification may be disclosed to the Internal Revenue Service by transferee and that
any false statement contained herein could be punished by fine, imprisonment, or both.
Under penalties of perjury I declare that I have examined this certification and to the best of my knowledge and belief it is true,
correct, and complete, and I further declare that I have authority to sign this document on behalf of [name of transferor].
[Title(s)]”
***** (E) A brief summary of the law and (e) Effective date for taxpayer iden-
(d) * * * facts supporting the claim that recognition tification numbers. The requirement in
(2) * * * of gain or loss is not required with respect paragraphs (d)(2)(i)(B), (d)(2)(iii)(B), and
(iii) Contents of the notice. No partic- to the transfer. (d)(3)(iii)(A)(2) and (3) of this section
ular form is required for a transferor’s no- (iv) No notice allowed. The provisions that taxpayer identification numbers be
tice to a transferee that the transferor is not of this paragraph (d)(2) do not apply to ex- provided (in all cases) is effective for
required to recognize gain or loss with re- clusions from income under section 121, dispositions of U.S. real property interests
spect to a transfer. The notice must be ver- to simultaneous like-kind exchanges un- occurring after November 4, 2003.
ified as true and signed under penalties of der section 1031 that do not qualify for *****
perjury by the transferor, by a responsible nonrecognition treatment in their entirety Par. 10. Section 1.1445–3 is amended
officer in the case of a corporation, by a (see paragraph (d)(2)(ii)(A) of this sec- as follows:
general partner in the case of a partnership, tion), and to non-simultaneous like-kind 1. In paragraph (a), after the seventh
and by a trustee or equivalent fiduciary in exchanges under section 1031 where the sentence, one sentence is added.
the case of a trust or estate. The following transferee cannot determine that the ex- 2. For each of the paragraphs listed in
information must be set forth in paragraphs change has been completed and all the con- the column below, remove the language
labeled to correspond with the designation ditions for nonrecognition have been sat- “Assistant Commissioner (International)”,
set forth as follows— isfied at the time it is otherwise required and add “Director, Philadelphia Service
(A) A statement that the document to pay the section 1445 withholding tax Center” in its place.
submitted constitutes a notice of a non- and file the withholding tax return (Form Paragraphs
recognition transaction or a treaty pro- 8288, “U.S. Withholding Tax Return for (b)(1), first sentence
vision pursuant to the requirements of Dispositions by Foreign Persons of U.S. (f)(1), first sentence
§1.1445–2(d)(2); Real Property Interests”). In these cases, (f)(2)(iii), heading
(B) The name, identifying number, and the transferee is excused from withhold- (f)(2)(iii), first sentence
home address (in the case of an individual) ing only upon the timely application for (g), third sentence, introductory text
or office address (in the case of an entity) and receipt of a withholding certificate un- 3. In paragraph (b)(1), last sentence, re-
of the transferor submitting the notice; der §1.1445–3 (see §1.1445–3(b)(5) and move the language “of this section” and
(C) A statement that the transferor is not (6) for specific rules applicable to transac- add “, and to the extent applicable, para-
required to recognize any gain or loss with tions under sections 121 and 1031). This graph (b)(5) or (6) of this section” in its
respect to the transfer; paragraph (d)(2)(iv) is applicable for dis- place.
(D) A brief description of the transfer; positions and exchanges occurring on or 4. Paragraph (b)(2) is revised.
and after September 5, 2003. 5. Paragraphs (b)(5) and (b)(6) are
***** added.
Robert E. Wenzel, long-term exempt rate. For purposes of appropriate percentages for determining
Deputy Commissioner for sections 382, 1274, 1288, and other sec- the low-income housing credit described
Services and Enforcement. tions of the Code, tables set forth the rates in section 42(b)(2) for buildings placed in
for October 2003. service during the current month. Finally,
Approved July 9, 2003. Table 5 contains the federal rate for de-
Rev. Rul. 2003–107 termining the present value of annuity, an
Pamela F. Olson, interest for life or for a term of years, or
Assistant Secretary of the Treasury. This revenue ruling provides various a remainder or a reversionary interest for
prescribed rates for federal income tax purposes of section 7520.
(Filed by the Office of the Federal Register on August 4,
2003, 8:45 a.m., and published in the issue of the Federal purposes for October 2003 (the current
Register for August 5, 2003, 68 F.R. 46081) month). Table 1 contains the short-term,
mid-term, and long-term applicable fed-
eral rates (AFR) for the current month
Section 1274.—Determina- for purposes of section 1274(d) of the
tion of Issue Price in the Case Internal Revenue Code. Table 2 contains
of Certain Debt Instruments the short-term, mid-term, and long-term
Issued for Property adjusted applicable federal rates (adjusted
(Also sections 42, 280G, 382, 412, 467, 468, 482,
AFR) for the current month for purposes
483, 642, 807, 846, 1288, 7520, 7872.) of section 1288(b). Table 3 sets forth
the adjusted federal long-term rate and
Federal rates; adjusted federal rates; the long-term tax-exempt rate described
adjusted federal long-term rate and the in section 382(f). Table 4 contains the
Mid-Term
AFR 3.65% 3.62% 3.60% 3.59%
110% AFR 4.02% 3.98% 3.96% 3.95%
120% AFR 4.39% 4.34% 4.32% 4.30%
130% AFR 4.77% 4.71% 4.68% 4.66%
150% AFR 5.50% 5.43% 5.39% 5.37%
175% AFR 6.44% 6.34% 6.29% 6.26%
Long-Term
AFR 5.23% 5.16% 5.13% 5.11%
110% AFR 5.76% 5.68% 5.64% 5.61%
120% AFR 6.29% 6.19% 6.14% 6.11%
130% AFR 6.82% 6.71% 6.65% 6.62%
of property that is owned by the taxpayer The family members may not be joined as 2003, 8:45 a.m., and published in the issue of the Federal
Register for August 19, 2003, 68 F.R. 49729)
and used as the principal residence of the parties to the judicial proceeding because
taxpayer, the taxpayer’s spouse, the tax- the levy attaches only to the taxpayer’s le-
gal interest in the subject property and the
payer’s former spouse, or the taxpayer’s Notice of Proposed Rulemaking
minor child. family members have no legal standing to
contest the proposed levy.
(1) Nature of judicial proceeding. The
(e) Levy allowed on certain business Partnership Transactions
Government will initiate a proceeding for
judicial approval of levy on a principal res- assets. The property described in sec- Involving Long-Term Contracts
idence by filing a petition with the appro- tion 6334(a)(13)(B)(ii) shall not be exempt
from levy if— REG–128203–02
priate United States District Court demon-
strating that the underlying liability has not (1) An Area Director of the Service per-
AGENCY: Internal Revenue Service
been satisfied, the requirements of any ap- sonally approves (in writing) the levy of
(IRS), Treasury.
plicable law or administrative procedure such property; or
relevant to the levy have been met, and no (2) The Secretary finds that the collec- ACTION: Notice of proposed rulemaking.
reasonable alternative for collection of the tion of tax is in jeopardy. An Area Di-
taxpayer’s debt exists. The petition will rector may not approve a levy under para- SUMMARY: This document contains pro-
ask the court to issue to the taxpayer an or- graph (e)(1) unless the Area Director de- posed regulations relating to partnership
der to show cause why the principal res- termines that the taxpayer’s other assets transactions involving contracts accounted
idence property should not be levied and subject to collection are insufficient to pay for under a long-term contract method of
will also ask the court to issue a notice of the amount due, together with expenses of accounting. The regulations are necessary
hearing. the proceeding. When other assets of an to resolve issues that were reserved in fi-
(2) The taxpayer will be granted a hear- individual taxpayer include permits issued nal regulations under section 460 that were
ing to rebut the Government’s prima fa- by a state and required under state law for published in the Federal Register on May
cie case if the taxpayer files an objec- the harvest of fish or wildlife in the tax- 15, 2002, addressing other mid-contract
tion within the time period required by the payer’s trade or business, the taxpayer’s changes in taxpayer engaged in complet-
court raising a genuine issue of material other assets also include future income that ing such contracts. The effect of the regu-
fact demonstrating that the underlying tax may be derived by such taxpayer from the lations is to explain the tax consequences
liability has been satisfied, that the tax- commercial sale of fish or wildlife under of these partnership transactions.
payer has other assets from which the li- such permit.
(f) Levy allowed on certain specified DATES: Written and electronic comments
ability can be satisfied, or that the Service
payments. Any payment described in sec- and requests for a public hearing must be
did not follow the applicable laws or proce-
tion 6331(h)(2)(B) or (C) shall not be ex- received by November 4, 2003.
dures pertaining to the levy. The taxpayer
is not permitted to challenge the merits un- empt from levy if the Secretary approves
ADDRESSES: Send submissions to:
derlying the tax liability in the proceeding. the levy thereon under section 6331(h).
CC:PA:RU (REG–128203–02), room
5226, Internal Revenue Service, POB
Abbreviations
The following abbreviations in current use ER—Employer. PR—Partner.
and formerly used will appear in material ERISA—Employee Retirement Income Security Act. PRS—Partnership.
EX—Executor. PTE—Prohibited Transaction Exemption.
published in the Bulletin.
F—Fiduciary. Pub. L.—Public Law.
A—Individual. FC—Foreign Country. REIT—Real Estate Investment Trust.
FICA—Federal Insurance Contributions Act. Rev. Proc.—Revenue Procedure.
Acq.—Acquiescence.
FISC—Foreign International Sales Company. Rev. Rul.—Revenue Ruling.
B—Individual.
BE—Beneficiary. FPH—Foreign Personal Holding Company. S—Subsidiary.
F.R.—Federal Register. S.P.R.—Statement of Procedural Rules.
BK—Bank.
FUTA—Federal Unemployment Tax Act. Stat.—Statutes at Large.
B.T.A.—Board of Tax Appeals.
C—Individual. FX—Foreign corporation. T—Target Corporation.
G.C.M.—Chief Counsel’s Memorandum. T.C.—Tax Court.
C.B.—Cumulative Bulletin.
GE—Grantee. T.D. —Treasury Decision.
CFR—Code of Federal Regulations.
CI—City. GP—General Partner. TFE—Transferee.
GR—Grantor. TFR—Transferor.
COOP—Cooperative.
IC—Insurance Company. T.I.R.—Technical Information Release.
Ct.D.—Court Decision.
CY—County. I.R.B.—Internal Revenue Bulletin. TP—Taxpayer.
LE—Lessee. TR—Trust.
D—Decedent.
LP—Limited Partner. TT—Trustee.
DC—Dummy Corporation.
DE—Donee. LR—Lessor. U.S.C.—United States Code.
M—Minor. X—Corporation.
Del. Order—Delegation Order.
Nonacq.—Nonacquiescence. Y—Corporation.
DISC—Domestic International Sales Corporation.
DR—Donor. O—Organization. Z —Corporation.
P—Parent Corporation.
E—Estate.
PHC—Personal Holding Company.
EE—Employee.
E.O.—Executive Order. PO—Possession of the U.S.
Bulletins 2003–27 through 2003–41 REG-108639-99, 2003-35 I.R.B. 431 2003-71, 2003-36 I.R.B. 517
REG-106736-00, 2003-28 I.R.B. 60 2003-72, 2003-38 I.R.B. 578
Announcements: REG-140378-01, 2003-41 I.R.B. 825 2003-73, 2003-39 I.R.B. 647
REG-107618-02, 2003-27 I.R.B. 13
2003-45, 2003-28 I.R.B. 73 Revenue Rulings:
REG-122917-02, 2003-27 I.R.B. 15
2003-46, 2003-30 I.R.B. 222
REG-128203-02, 2003-41 I.R.B. 828 2003-70, 2003-27 I.R.B. 3
2003-47, 2003-29 I.R.B. 124
REG-131997-02, 2003-33 I.R.B. 366 2003-71, 2003-27 I.R.B. 1
2003-48, 2003-28 I.R.B. 73
REG-133791-02, 2003-35 I.R.B. 493 2003-72, 2003-33 I.R.B. 346
2003-49, 2003-32 I.R.B. 339
REG-138495-02, 2003-37 I.R.B. 541 2003-73, 2003-28 I.R.B. 44
2003-50, 2003-30 I.R.B. 222
REG-138499-02, 2003-37 I.R.B. 541 2003-74, 2003-29 I.R.B. 77
2003-51, 2003-37 I.R.B. 555
REG-140808-02, 2003-38 I.R.B. 582 2003-75, 2003-29 I.R.B. 79
2003-52, 2003-32 I.R.B. 345
REG-140930-02, 2003-38 I.R.B. 583 2003-76, 2003-33 I.R.B. 355
2003-53, 2003-32 I.R.B. 345
REG-141669-02, 2003-34 I.R.B. 408 2003-77, 2003-29 I.R.B. 75
2003-54, 2003-40 I.R.B. 762
REG-142538-02, 2003-38 I.R.B. 590 2003-78, 2003-29 I.R.B. 76
2003-55, 2003-38 I.R.B. 597
REG-143679-02, 2003-38 I.R.B. 592 2003-79, 2003-29 I.R.B. 80
2003-56, 2003-39 I.R.B. 694
REG-144908-02, 2003-38 I.R.B. 593 2003-80, 2003-29 I.R.B. 83
2003-57, 2003-37 I.R.B. 555
REG-162625-02, 2003-35 I.R.B. 500 2003-81, 2003-30 I.R.B. 126
2003-58, 2003-40 I.R.B. 746
REG-163974-02, 2003-38 I.R.B. 595 2003-82, 2003-30 I.R.B. 125
2003-59, 2003-40 I.R.B. 746
REG-108676-03, 2003-36 I.R.B. 523 2003-83, 2003-30 I.R.B. 128
2003-62, 2003-41 I.R.B. 821
REG-112039-03, 2003-35 I.R.B. 504 2003-84, 2003-32 I.R.B. 289
Notices: REG-113112-03, 2003-40 I.R.B. 761 2003-85, 2003-32 I.R.B. 291
REG-116914-03, 2003-32 I.R.B. 338 2003-86, 2003-32 I.R.B. 290
2003-38, 2003-27 I.R.B. 9
REG-121122-03, 2003-37 I.R.B. 550 2003-87, 2003-29 I.R.B. 82
2003-39, 2003-27 I.R.B. 10
REG-129709-03, 2003-35 I.R.B. 506 2003-88, 2003-32 I.R.B. 292
2003-40, 2003-27 I.R.B. 10
REG-130262-03, 2003-37 I.R.B. 553 2003-89, 2003-37 I.R.B. 525
2003-41, 2003-28 I.R.B. 49
REG-132483-03, 2003-34 I.R.B. 410 2003-90, 2003-33 I.R.B. 353
2003-42, 2003-28 I.R.B. 49
Revenue Procedures: 2003-91, 2003-33 I.R.B. 347
2003-43, 2003-28 I.R.B. 50
2003-92, 2003-33 I.R.B. 350
2003-44, 2003-28 I.R.B. 52
2003-45, 2003-27 I.R.B. 11 2003-93, 2003-33 I.R.B. 346
2003-45, 2003-29 I.R.B. 86
2003-46, 2003-28 I.R.B. 54 2003-94, 2003-33 I.R.B. 357
2003-46, 2003-28 I.R.B. 53
2003-47, 2003-28 I.R.B. 55 2003-95, 2003-33 I.R.B. 358
2003-47, 2003-30 I.R.B. 132
2003-48, 2003-29 I.R.B. 86 2003-96, 2003-34 I.R.B. 386
2003-48, 2003-30 I.R.B. 133
2003-49, 2003-29 I.R.B. 89 2003-97, 2003-34 I.R.B. 380
2003-49, 2003-32 I.R.B. 294
2003-50, 2003-29 I.R.B. 119 2003-98, 2003-34 I.R.B. 378
2003-50, 2003-32 I.R.B. 295
2003-51, 2003-29 I.R.B. 121 2003-99, 2003-34 I.R.B. 388
2003-51, 2003-33 I.R.B. 361
2003-52, 2003-30 I.R.B. 134 2003-100, 2003-34 I.R.B. 385
2003-52, 2003-32 I.R.B. 296
2003-53, 2003-31 I.R.B. 230 2003-101, 2003-36 I.R.B. 513
2003-53, 2003-33 I.R.B. 362
2003-54, 2003-31 I.R.B. 236 2003-102, 2003-38 I.R.B. 559
2003-54, 2003-33 I.R.B. 363
2003-55, 2003-31 I.R.B. 242 2003-103, 2003-38 I.R.B. 568
2003-55, 2003-34 I.R.B. 395
2003-56, 2003-31 I.R.B. 249 2003-104, 2003-39 I.R.B. 636
2003-56, 2003-34 I.R.B. 396
2003-57, 2003-31 I.R.B. 257 2003-105, 2003-40 I.R.B. 696
2003-57, 2003-34 I.R.B. 397
2003-58, 2003-31 I.R.B. 262 2003-107, 2003-41 I.R.B. 815
2003-58, 2003-35 I.R.B. 429
2003-59, 2003-31 I.R.B. 268
2003-59, 2003-35 I.R.B. 429 Tax Conventions:
2003-60, 2003-31 I.R.B. 274
2003-60, 2003-39 I.R.B. 643
2003-61, 2003-32 I.R.B. 296 2003-58, 2003-40 I.R.B. 746
2003-62, 2003-38 I.R.B. 576
2003-62, 2003-32 I.R.B. 299 2003-59, 2003-40 I.R.B. 746
2003-63, 2003-38 I.R.B. 577
2003-63, 2003-32 I.R.B. 304 2003-62, 2003-41 I.R.B. 821
2003-64, 2003-39 I.R.B. 646
2003-64, 2003-32 I.R.B. 306
2003-65, 2003-40 I.R.B. 748 Treasury Decisions:
2003-65, 2003-32 I.R.B. 336
2003-67, 2003-40 I.R.B. 753
2003-66, 2003-33 I.R.B. 364 9061, 2003-27 I.R.B. 5
2003-68, 2003-41 I.R.B. 824
2003-67, 2003-34 I.R.B. 397 9062, 2003-28 I.R.B. 46
Proposed Regulations: 2003-68, 2003-34 I.R.B. 398 9063, 2003-36 I.R.B. 510
2003-69, 2003-34 I.R.B. 403 9064, 2003-36 I.R.B. 508
REG-209377-89, 2003-36 I.R.B. 521
2003-70, 2003-34 I.R.B. 406 9065, 2003-36 I.R.B. 515
REG-208199-91, 2003-40 I.R.B. 757
1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2003-1 through 2003-26 is in Internal Revenue Bulletin 2003-27,
dated July 7, 2003.
1 A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2003-1 through 2003-26 is in Internal Revenue Bulletin 2003-27, dated July 7, 2003.
78-441 81-225
Obsoleted by Clarified and amplified by
Rev. Rul. 2003-99, 2003-34 I.R.B. 388 Rev. Rul. 2003-92, 2003-33 I.R.B. 350
79-29 81-247
Obsoleted by Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B. 388 Rev. Rul. 2003-99, 2003-34 I.R.B. 388
79-50 82-164
Obsoleted by Obsoleted by
Rev. Rul. 2003-105, 2003-40 I.R.B. 696 Rev. Rul. 2003-99, 2003-34 I.R.B. 388
79-71 82-226
Obsoleted by Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B. 388 Rev. Rul. 2003-99, 2003-34 I.R.B. 388
79-82 83-101
Obsoleted by Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B. 388 Rev. Rul. 2003-99, 2003-34 I.R.B. 388
79-104 83-119
Obsoleted by Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B. 388 Rev. Rul. 2003-99, 2003-34 I.R.B. 388
79-116 84-28
Obsoleted by Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B. 388 Rev. Rul. 2003-99, 2003-34 I.R.B. 388
79-314 84-30
Obsoleted by Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B. 388 Rev. Rul. 2003-99, 2003-34 I.R.B. 388
79-410 85-55
Amplified by Obsoleted by
Rev. Rul. 2003-90, 2003-33 I.R.B. 353 Rev. Rul. 2003-99, 2003-34 I.R.B. 388
79-424 85-136
Obsoleted by Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B. 388 Rev. Rul. 2003-99, 2003-34 I.R.B. 388
80-78 86-52
Obsoleted by Obsoleted by
Rev. Rul. 2003-99, 2003-34 I.R.B. 388 Rev. Rul. 2003-99, 2003-34 I.R.B. 388
October 14, 2003 viii *U.S. Government Printing Office: 2003—496–919/60104 2003-41 I.R.B.