Académique Documents
Professionnel Documents
Culture Documents
2006-26
June 26, 2006
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 specifically and primarily designed to reduce heat loss or gain
of a dwelling. Notice 2006–26 clarified.
ADMINISTRATIVE
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. Bulletin
contents are compiled 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
It is the policy of the Service to publish in the Bulletin all sub- the Internal Revenue Code of 1986.
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
taxpayers are published. 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
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 Treasury’s 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
requirements. Part IV.—Items of General Interest.
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
may be used as precedents. Unpublished rulings will not be The last Bulletin for each month includes a cumulative index
relied on, used, or cited as precedents by Service personnel in for the matters published during the preceding months. These
the disposition of other cases. In applying published rulings and monthly indexes are cumulated on a semiannual basis, and are
procedures, the effect of subsequent legislation, regulations, published in the last Bulletin of each semiannual period.
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.
1 Nonacquiescence relating to whether the statute of limitations barred the Service from recovering erroneously paid overpayment interest by offsetting against a subsequent refund of tax and
interest determined to be due to the taxpayer for the same taxable year.
1
Absence of a minus sign before the percentage change in this column signifies a price increase.
2
Indexes on a January 1986 = 100 base.
3The store total index covers all departments, including some not listed separately, except for the following: candy, food, liquor,
The first sentence of §1.382–8(g), paragraph (c)(2) of this section paragraph (c)(2) of §1.382–8T
Example (2)(e)
§1.382–8(g), Example (3)(b) paragraph (c)(2) of this section paragraph (c)(2) of §1.382–8T
§1.382–8(g), Example (3)(c)(1)(B) paragraphs (c)(1) and (2) of this section paragraph (c)(1) of this section and
paragraph (c)(2) of §1.382–8T
The second sentence of §1.382–8(g), paragraph (c)(2) of this section paragraph (c)(2) of §1.382–8T
Example (4)(c)
PART 602—OMB CONTROL Authority: 26 U.S.C. 7805. §602.101 OMB Control numbers.
NUMBERS UNDER THE PAPERWORK Par. 55. In §602.101, paragraph (b) is
REDUCTION ACT amended to read as follows: *****
1. The following entries to the table are (b) * * *
Par. 54. The authority citation for part removed:
602 continues to read as follows:
2. The following entries are added in §602.101 OMB Control numbers. (b) * * *
numerical order to the table:
*****
Mark E. Matthews, They also eliminate regulatory impediments to the Rev. Rul. 2006–32
Deputy Commissioner for electronic filing of certain statements that taxpayers
Services and Enforcement. are required to include on or with their Federal in- This revenue ruling contains a list of the
come tax returns. See T.D. 9264, page 1150. See average annual effective interest rates on
REG-134317-05, page 1184. new loans under the Farm Credit System.
Approved May 19, 2006.
This revenue ruling also contains a list of
Eric Solomon, the states within each Farm Credit System
Section 2032A.—Valuation Bank Chartered Territory.
Acting Deputy Assistant Secretary of Certain Farm, etc.,
of the Treasury (Tax Policy). Under § 2032A(e)(7)(A)(ii) of the In-
Real Property ternal Revenue Code, rates on new Farm
(Filed by the Office of the Federal Register on May 26, 2006,
26 CFR 20.2032A–4: Method of valuing farm real Credit System Bank loans are used in com-
8:45 a.m., and published in the issue of the Federal Register
for May 30, 2006, 71 F.R. 30591) property. puting the special use value of real prop-
erty used as a farm for which an election
Special use value; farms; interest is made under § 2032A. The rates in this
rates. The 2006 interest rates to be used revenue ruling may be used by estates that
Section 1563.—Definitions in computing the special use value of farm value farmland under § 2032A as of a date
and Special Rules real property for which an election is made in 2006.
Temporary and proposed regulations simplify, under section 2032A of the Code are listed Average annual effective interest
clarify, or eliminate taxpayer reporting burdens. for estates of decedents. rates, calculated in accordance with
come tax returns. See T.D. 9264, page 1150. See Section 6166.—Extension
REG-134317-05, page 1184. of Time for Payment of
Section 6012.—Persons Estate Tax Where Estate
Required to Make Returns Consists Largely of Interest
of Income in Closely Held Business
Temporary and proposed regulations simplify, 26 CFR 20.6166–2: Definition of an interest in a
clarify, or eliminate taxpayer reporting burdens. closely held business.
They also eliminate regulatory impediments to the
electronic filing of certain statements that taxpayers Real property interests; closely held
are required to include on or with their Federal in- business. This ruling updates the guidance
provided by Rev. Ruls. 75–365, 75–366,
Abbreviations
The following abbreviations in current use ER—Employer. PRS—Partnership.
and formerly used will appear in material ERISA—Employee Retirement Income Security Act. PTE—Prohibited Transaction Exemption.
EX—Executor. Pub. L.—Public Law.
published in the Bulletin.
F—Fiduciary. REIT—Real Estate Investment Trust.
FC—Foreign Country. Rev. Proc.—Revenue Procedure.
A—Individual.
FICA—Federal Insurance Contributions Act. Rev. Rul.—Revenue Ruling.
Acq.—Acquiescence.
B—Individual. FISC—Foreign International Sales Company. S—Subsidiary.
FPH—Foreign Personal Holding Company. S.P.R.—Statement of Procedural Rules.
BE—Beneficiary.
F.R.—Federal Register. Stat.—Statutes at Large.
BK—Bank.
B.T.A.—Board of Tax Appeals. FUTA—Federal Unemployment Tax Act. T—Target Corporation.
FX—Foreign corporation. T.C.—Tax Court.
C—Individual.
G.C.M.—Chief Counsel’s Memorandum. T.D. —Treasury Decision.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations. GE—Grantee. TFE—Transferee.
GP—General Partner. TFR—Transferor.
CI—City.
GR—Grantor. T.I.R.—Technical Information Release.
COOP—Cooperative.
Ct.D.—Court Decision. IC—Insurance Company. TP—Taxpayer.
I.R.B.—Internal Revenue Bulletin. TR—Trust.
CY—County.
LE—Lessee. TT—Trustee.
D—Decedent.
DC—Dummy Corporation. LP—Limited Partner. U.S.C.—United States Code.
LR—Lessor. X—Corporation.
DE—Donee.
M—Minor. Y—Corporation.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation. Nonacq.—Nonacquiescence. Z —Corporation.
O—Organization.
DR—Donor.
P—Parent Corporation.
E—Estate.
PHC—Personal Holding Company.
EE—Employee.
PO—Possession of the U.S.
E.O.—Executive Order.
PR—Partner.
1A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2005–27 through 2005–52 is in Internal Revenue Bulletin
2005–52, dated December 27, 2005.
Tax Conventions:
Treasury Decisions:
1 A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2005–27 through 2005–52 is in Internal Revenue Bulletin 2005–52, dated December 27,
2005.
2005-7 92-19
Superseded by Supplemented in part by
Rev. Proc. 2006-7, 2006-1 I.R.B. 242 Rev. Rul. 2006-25, 2006-20 I.R.B. 882
2005-8 92-86
Superseded by Modified by
Rev. Proc. 2006-8, 2006-1 I.R.B. 245 T.D. 9250, 2006-11 I.R.B. 588
2005-9 2000-2
Superseded for certain taxable years by Modified and superseded by
Rev. Proc. 2006-12, 2006-3 I.R.B. 310 Rev. Rul. 2006-26, 2006-22 I.R.B. 939
2005-12 2006-1
Section 10 modified and superseded by Modified and clarified by
Rev. Proc. 2006-1, 2006-1 I.R.B. 1 Rev. Rul. 2006-31, 2006-25 I.R.B. 1133
2005-15 2006-25
Obsoleted in part by Corrected by
Rev. Proc. 2006-17, 2006-14 I.R.B. 709 Ann. 2006-35, 2006-24 I.R.B. 1061
74-503
Revoked by
Rev. Rul. 2006-2, 2006-2 I.R.B. 261
75-365
Revoked by
Rev. Rul. 2006-34, 2006-26 I.R.B. 1171
75-367
Revoked in part by
Rev. Rul. 2006-34, 2006-26 I.R.B. 1171
77-230
Obsoleted by
T.D. 9249, 2006-10 I.R.B. 546