Private Foundation Disclosure Rules

DEPARTMENT OF THE TREASURY
Internal Revenue Service 26 CFR Parts 301 and 602 [TD 8861] RIN
1545-AW96

TITLE: Private Foundation Disclosure Rules

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final regulations.

SUMMARY: This document contains final regulations that amend the
regulations relating to the public disclosure requirements described
in section 6104(d) of the Internal Revenue Code. These final
regulations implement changes made by the Tax and Trade Relief
Extension Act of 1998, which extended to private foundations the
same rules regarding public disclosure of annual information returns
that apply to other tax-exempt organizations. These final
regulations provide guidance for private foundations required to
make copies of applications for recognition of exemption and annual
information returns available for public inspection and to comply
with requests for copies of those documents.

DATES: Effective Date: These regulations are effective March 13,
2000. Applicability date. Except as provided below, these
regulations are applicable to private foundations on or after March
13, 2000. These regulations are not applicable to any private
foundation annual information return the due date for which
(determined with regard to any extension of time for filing) is
before March 13, 2000.

FOR FURTHER INFORMATION CONTACT: Michael B. Blumenfeld, (202)
622-6070 (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 of 1995 (44
U.S.C. 3507) under control number 1545- 1655. 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 it displays a
valid control number assigned by the Office of Management and Budget
.

The estimated average annual burden per respondent/recordkeeper is
30 minutes.

Comments on the accuracy of this burden estimate 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 this collection 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

This document amends ��301.6104(d)-1 through 301.6104(d)-5 of the
Procedure and Administration Regulations (26 CFR Part 301) relating
to the section 6104(d) public disclosure rules applicable to tax-
exempt organizations (organizations described in section 501(c) or
(d) and exempt from taxation under section 501(a)) and certain
nonexempt charitable trusts and nonexempt private foundations
referenced in section 6033(d). The amendments remove existing
�301.6104(d)-1 (relating to public inspection of private foundation
annual information returns). The amendments also revise
��301.6104(d)-2 through 301.6104(d)-5 to apply the provisions to all
tax-exempt organizations, nonexempt charitable trusts described in
section 4947(a)(1) and nonexempt private foundations. In addition,
the amendments redesignate existing ��301.6104(d)-2 through
301.6104(d)-5 as ��301.6104(d)-0 through 301.6104(d)-3,
respectively.

Description of Current Law Disclosure Requirements Applicable to
Private Foundations Section 6104(d), as in effect prior to the
effective date of the Tax and Trade Relief Extension Act of 1998
(Division J of H.R. 4328, the Omnibus Consolidated and Emergency
Supplemental Appropriations Act, 1999)(Public Law 105-277, 112 Stat
2681) (with respect to private foundations), requires a private
foundation to make its annual information returns available for
public inspection at its principal office during regular business
hours for a period of 180 days after the foundation publishes notice
of the availability of its return. A private foundation must publish
the notice not later than the due date of the return (determined
with regard to any extension of time for filing) in a newspaper
having general circulation in the county in which the principal
office of the foundation is located. Section 6104(e), as in effect
prior to the effective date of the Tax and Trade Relief Extension
Act of 1998 (with respect to private foundations), requires a
private foundation to allow public inspection of the foundation's
application for recognition of exemption at the foundation's
principal office (and certain regional or district offices). Section
6104(e) also requires a private foundation to provide copies of its
exemption application upon request. The requirement to provide
copies of an exemption application upon request becomes effective,
however, only after the Secretary of the Treasury issues final
regulations applicable to private foundations that describe how the
requirement is inapplicable if the private foundation makes its
exemption application widely available or obtains an IRS
determination that a particular request is part of a harassment
campaign.

Amendments Made by the Tax and Trade Relief Extension Act of 1998

The Tax and Trade Relief Extension Act of 1998 was enacted on
October 21, 1998. Among its provisions, it amended section 6104(e)
of the Code to apply to private foundations the same rules regarding
public disclosure of annual information returns that apply to other
tax-exempt organizations. In addition, the Tax and Trade Relief
Extension Act of 1998 repealed existing section 6104(d), and
redesignated section 6104(e), as amended, as new section 6104(d).
Section 6104(d), as amended by the Tax and Trade Relief Extension
Act of 1998, requires each tax-exempt organization, including one
that is a private foundation, to allow public inspection at its
principal office (and at certain regional or district offices) and
to comply with requests, made either in person or in writing, for
copies of the organization's application for recognition of
exemption and the organization's three most recent annual
information returns.

Congress also intended that nonexempt charitable trusts described in
section 4947(a)(1) and nonexempt private foundations comply with the
expanded public disclosure requirements, just as the information
reporting requirements of section 6033, pursuant to section 6033(d),
apply to these entities. See Joint Committee on Taxation, General
Explanation of Tax Legislation Enacted in 1998 (JCS-6-98), November
24, 1998, at 242, fn. 102.

The Tax and Trade Relief Extension Act of 1998 amendments apply to
requests made after the later of December 31, 1998, or the 60 day
after the Secretary of the th Treasury issues final regulations
referred to in section 6104(d)(4) (relating to when documents are
made widely available and when a particular request is considered
part of a harassment campaign). On April 9, 1999, the IRS published
in the Federal Register (64 FR 17279) final regulations under
section 6104(d) applicable to tax-exempt organizations other than
private foundations. Accordingly, section 6104(d), as amended by the
Tax and Trade Relief Extension Act of 1998, became effective with
respect to tax-exempt organizations other than private foundations
on June 8, 1999.

On August 10, 1999, the IRS published a notice of proposed
rulemaking under section 6104(d) in the Federal Register (64 FR
43324) that extends the recently-published final regulations under
section 6104(d) to apply to private foundations and modifies those
final regulations in several respects. The IRS received a few
comments on the proposed regulations. No public hearing on the
regulations was requested or held. After consideration of all the
comments, the proposed regulations are adopted with minor clarifying
modifications by this Treasury Decision. The provisions and
significant comments are discussed below.

Explanation of the Provisions

These final regulations amend the final regulations under section
6104(d) that were published in the Federal Register (64 FR 17279) on
April 9, 1999 (the April 9, 1999 final regulations). The amendments
clarify that the term annual information return includes any return
that is required to be filed under section 6033. For a private
foundation, these returns include Form 990-PF and Form 4720. The
amendments clarify that, unlike other tax-exempt organizations, a
private foundation must disclose to the general public the names and
addresses of its contributors, consistent with section 6104(d)(3).
The amendments also clarify that, for purposes of section 6104(d),
the terms tax-exempt organization and private foundation include
nonexempt private foundations and nonexempt charitable trusts
described in section 4947(a)(1) that are subject to the information
reporting requirements of section 6033. Finally, the amendments
remove existing �301.6104(d)-1 and redesignate existing ��301.6104-2
through 301.6104(d)-5, as ��301.6104(d)-0 through 301.6104(d)-3,
respectively.

Until March 13, 2000, private foundations remain subject to section
6104(d) and section 6104(e), as in effect prior to the Tax and Trade
Relief Extension Act of 1998, and existing �301.6104(d)-1.
Thereafter, private foundations are subject to the public inspection
requirements of section 6104(d), as in effect prior to the Tax and
Trade Relief Extension Act of 1998, and existing �301.6104(d)-1 with
respect to any annual information return the due date (determined
with regard to any extension of time for filing) for which is prior
to March 13, 2000.

Summary of Comments

One commenter suggested another method to satisfy the widely
available exception to the requirement that a private foundation
provide a copy of its applicable documents upon request. The
commenter would permit a private foundation to satisfy the widely
available exception by (1) filing copies of its documents with a
state agency that, in turn, makes the documents available for public
inspection, and (2) publishing a notice in a newspaper of general
circulation stating where the documents are available.

The Tax and Trade Relief Extension Act of 1998 repealed the
requirement (in former section 6104(d)) that private foundations
publish notice of the availability of their annual information
returns with respect to annual information returns due after the
effective date of these final regulations. The Act extended the same
public disclosure requirements that apply to all other tax-exempt
organizations to private foundations, including the widely available
exception. The proposed regulations specify that a private
foundation satisfies the widely available exception by posting its
documents on the World Wide Web as described in the April 9, 1999
final regulations. After carefully considering this comment, the IRS
and the Treasury Department have concluded that providing copies of
the applicable documents to a state agency and publishing notice
would not make those documents widely available. We reached our
conclusion because the method suggested by the commenter could
impose a substantial inconvenience to members of the public.
Therefore, the IRS and the Treasury Department did not adopt this
suggestion.

A few commenters asked that these final regulations not require
private foundations to disclose to the general public the identities
of their contributors. Section 6104(d) requires public disclosure of
all the information contained on an exemption application and an
annual information return filed with the IRS, unless the information
is specifically excepted from disclosure. Section 6104(d)(3)
specifically excepts from disclosure the names and addresses of any
contributor to an organization which is not a private foundation. By
its terms, this exception does not apply to private foundations. The
IRS and the Treasury Department believe the rule of the proposed
regulation is consistent with the statute and Congressional intent
and, therefore, did not change this provision.

One commenter asked that these final regulations clarify how the
disclosure requirements apply to a supporting organization described
in section 509(a)(3). Section 509(a) provides that an organization
described in section 501(c)(3) is a private foundation if it does
not meet the requirements of section 509(a)(1), (2), (3), or (4).

Therefore, an organization that is described in section 501(c)(3)
and classified as a supporting organization under section 509(a)(3)
is not a private foundation. The disclosure requirements under
section 6104(d) apply to supporting organizations described in
section 509(a)(3) in the same manner as they apply to all other tax-
exempt organizations that are not private foundations. The proposed
regulations define the terms tax-exempt organization and private
foundation consistent with the applicable statutory provisions, and
the IRS and the Treasury Department have determined that further
regulatory clarification is not necessary in this regard.

Another commenter expressed concern that some private foundations
may not have copies of their exemption applications. This commenter
suggested that these final regulations only require private
foundations formed after 1990 to disclose their exemption
applications. Since July 15, 1987, a tax-exempt organization,
including one that is a private foundation, has been required under
section 6104 to make its exemption application available for public
inspection. See section 10702(b) of the Omnibus Budget
Reconciliation Act of 1987 (Public Law 100-203) and Notice 88-120
(1988-2 C.B. 454). Under the proposed regulations, a private
foundation that filed its exemption application before July 15, 1987
is required to make available for public inspection a copy of its
application only if it had a copy of its application on July 15,
1987. Thus, these final regulations do not change this provision of
the proposed regulations. One commenter stated that the applicable
date in the proposed regulations, which would eliminate the
requirement that private foundations publish notice of the
availability of their annual information returns, is inconsistent
with the effective date specified in the House Committee Report to
the Tax and Trade Relief Extension Act of 1998 (H.R. Rep. No.
105-817). This commenter requested that the final regulations add a
rule that prevents the IRS from asserting a late filing penalty
against a private foundation whose return is rejected by the IRS
because the foundation filed the return on or after June 8, 1999
(the effective date of the April 9, 1999 final regulations) without
proof that it satisfied the publication of notice requirement.
Section 6104(d), as in effect prior to the effective date of the Tax
and Trade Relief Extension Act of 1998, provides that a private
foundation must publish a notice of the availability of its return
not later than the due date of the return (determined with regard to
any extension of time for filing). Section 1.6033-3(b) of the
regulations requires a private foundation to attach a copy of the
notice to its return.

The Tax and Trade Relief Extension Act of 1998 repealed the
publication of notice requirement of section 6104(d) effective for
private foundation annual information returns due after the later of
December 31, 1998 or 60 days after the Treasury Department issues
final regulations that explain how requested documents may be made
widely available or when requests for documents are part of a
harassment campaign. The April 9, 1999 final regulations do not
apply to private foundations and, therefore, the issuance of those
regulations did not trigger the repeal of the publication of notice
requirement. Indeed, the April 9, 1999 final regulations stated
explicitly that, until the IRS issues final regulations under
section 6104(d) applicable to private foundations, private
foundations continue to be governed by the existing � 301.6104(d)-1
requirements relating to public disclosure of private foundation
annual information returns

The IRS and the Treasury Department believe the effective date of
the repeal of the publication of notice requirement stated in the
proposed regulations is consistent with both the statute and the
legislative history. Further, the IRS and the Treasury Department
believe it is important to retain one public disclosure standard for
private foundations until another is finally adopted. Accordingly,
the IRS and the Treasury Department did not modify these final
regulations as suggested.

Finally, one commenter expressed concern that disclosure in some
instances could adversely affect the charitable operations of some
small operating private foundations that advance unpopular causes or
desire to maintain a low profile. This commenter suggested that the
final regulations should authorize the Secretary to grant a waiver
from some or all of the disclosure requirements if a small operating
foundation establishes that, without the waiver, its charitable
operations could be adversely affected and it provides alternative
methods of disclosure that enhance oversight and public
accountability. Section 6104(d), however, does not authorize the
Secretary to grant waivers except in the case of a harassment
campaign determination. Moreover, all tax-exempt organizations have
the option under the regulations of avoiding having to comply with
requests for copies of documents by making such documents widely
available on the Internet. Therefore, the IRS and the Treasury
Department did not adopt this suggestion.

Effective Date

These final regulations are applicable to private foundations on
March 13, 2000.

Special Analyses

It is hereby certified that the collections of information in these
regulations will not have a significant economic impact on a
substantial number of small entities. This certification is based on
the fact that the average time required to maintain and disclose the
information required under these regulations is estimated to be 30
minutes for each private foundation. This estimate is based on the
assumption that, on average, a private foundation will receive one
request per year to inspect or provide copies of its application for
tax exemption and its annual information returns. Approximately 0.1
percent of the private foundations affected by these regulations
will be subject to the reporting requirements contained in the
regulations. It is estimated that annually, approximately 65 private
foundations will make their documents widely available by posting
them on the Internet. In addition, it is estimated that annually,
approximately 3 private foundations will file an application for a
determination that they are the subject of a harassment campaign
such that a waiver of the obligation to provide copies of their
applications for tax exemption and their annual information returns
is in the public interest. The average time required to complete,
assemble and file an application describing a harassment campaign is
expected to be 5 hours. Because applications for a harassment
campaign determination will be filed so infrequently, they will have
no effect on the average time needed to comply with the requirements
in these regulations. In addition, a private foundation is allowed
in these regulations to charge a reasonable fee for providing copies
to requesters. Therefore, it is estimated that it will cost a
private foundation less than $10 per year to comply with these
regulations, which is not a significant economic impact. Therefore,
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 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 author of these regulations is Michael B. Blumenfeld,
Office of Associate Chief Counsel (Employee Benefits and Exempt
Organizations), IRS. Other personnel from the IRS and Treasury
Department also participated in their development.

List of Subjects

26 CFR Part 301 Employment taxes, Estate taxes, Excise taxes, Gift
taxes, Income taxes, Penalties, Reporting and recordkeeping
requirements.

26 CFR Part 602 Reporting and recordkeeping requirements. Adoption
of Amendments to the Regulations Accordingly, 26 CFR parts 301 and
602 are amended as follows:

PART 301-PROCEDURE AND ADMINISTRATION

Paragraph 1. The authority citation for part 301 is amended by
adding entries in numerical order to read in part as follows:
Authority: 26 U.S.C. 7805 * * *

Section 301.6104(d)-2 also issued under 26 U.S.C. 6104(d)(3);
Section 301.6104(d)-3 also issued under 26 U.S.C. 6104(d)(3); * * *

�301.6104(d)-1 [Removed ] Par. 2. Section 301.6104(d)-1 is removed.

�301.6104(d)-2 [Redesignated as �301.6104(d)-0 ] Par. 3. Section
301.6104(d)-2 is redesignated as �301.6104(d)-0. Par. 4. Newly
designated �301.6104(d)-0 is revised to read as follows:

�301.6104(d)-0 Table of contents. This section lists the major
captions contained in ��301.6104(d)-1 through 301.6104(d)-3 as
follows:

�301.6104(d)-1 Public inspection and distribution of applications
for tax exemption and annual information returns of tax-exempt
organizations.

(a) In general.

(b) Definitions.

(1) Tax-exempt organization.

(2) Private foundation.

(3) Application for tax exemption.

(i) In general.

(ii) No prescribed application form.

(iii) Exceptions.

(iv) Local or subordinate organizations.

(4) Annual information return.

(i) In general.

(ii) Exceptions.

(iii) Returns more than 3 years old.

(iv) Local or subordinate organizations.

(5) Regional or district offices.

(i) In general.

(ii) Site not considered a regional or district office.

(c) Special rules relating to public inspection.

(1) Permissible conditions on public inspection.

(2) Organizations that do not maintain permanent offices.

(d) Special rules relating to copies.

(1) Time and place for providing copies in response to requests made
in person.

(i) In general.

(ii) Unusual circumstances.

(iii) Agents for providing copies.

(2) Request for copies in writing.

(i) In general.

(ii) Time and manner of fulfilling written requests.

(A) In general.

(B) Request for a copy of parts of document.

(C) Agents for providing copies.

(3) Fees for copies.

(i) In general.

(ii) Form of payment.

(A) Request made in person.

(B) Request made in writing.

(iii) Avoidance of unexpected fees.

(iv) Responding to inquiries of fees charged.

(e) Documents to be provided by regional and district offices.

(f) Documents to be provided by local and subordinate organizations.

(1) Applications for tax exemption.

(2) Annual information returns.

(3) Failure to comply.

(g) Failure to comply with public inspection or copying
requirements.

(h) Effective date.

(1) In general.

(2) Private foundation annual information returns. �301.6104(d)-2
Making applications and returns widely available.

(a) In general.

(b) Widely available.

(1) In general.

(2) Internet posting.

(i) In general.

(ii) Transition rule.

(iii) Reliability and accuracy.

(c) Discretion to prescribe other methods for making documents
widely available.

(d) Notice requirement.

(e) Effective date. �301.6104(d)-3 Tax-exempt organization subject
to harassment campaign.

(a) In general.

(b) Harassment.

(c) Special rule for multiple requests from a single individual or
address.

(d) Harassment determination procedure.

(e) Effect of a harassment determination.

(f) Examples.

(g) Effective date.

�301.6104(d)-3 [Redesignated as �301.6104(d)-1 ]

Par. 5. Section 301.6104(d)-3 is redesignated as �301.6104(d)-1.

Par. 6. Newly designated �301.6104(d)-1 is amended as follows:

1. Revise the section heading.

1a. Paragraph (a) is amended as follows:

a. Remove the language ", other than a private foundation (as
defined in paragraph (b)(2) of this section)," from the first
sentence.

b. Remove the language ", other than a private foundation," from the
second sentence.

c. Remove the language "��301.6104(d)-4 and 301.6104(d)-5" from the
fourth sentence and add "��301.6104(d)-2 and 301.6104(d)-3" in its
place.

2. In paragraph (b) introductory text, remove the language
"��301.6104(d)-4 and 301.6104(d)-5" and add "��301.6104(d)-2 and
301.6104(d)-3" in its place.

3. In paragraph (b)(1), add a sentence at the end of the paragraph.

4. In paragraph (b)(2), add the language "or a nonexempt charitable
trust described in section 4947(a)(1) or a nonexempt private
foundation subject to the information reporting requirements of
section 6033 pursuant to section 6033(d)" at the end of the
sentence.

5. In paragraph (b)(3)(iii)(B), remove the word "or" at the end of
the paragraph.

6. Redesignate paragraph (b)(3)(iii)(C) as paragraph (b)(3)(iii)(D)
and add a new paragraph (b)(3)(iii)(C).

7. In paragraph (b)(4)(i), remove the last two sentences and add
three sentences in their place.

8. Paragraph (b)(4)(ii) is amended as follows:

a. Remove the language ", and the return of a private foundation"
from the first sentence.

b. Revise the last sentence.

9. Revise paragraph (h). The revisions and additions read as
follows: �301.6104(d)-1 Public inspection and distribution of
applications for tax exemption and annual information returns of
tax-exempt organizations.

* * * * *

(b) * * *

(1) * * * The term tax-exempt organization also includes any
nonexempt charitable trust described in section 4947(a)(1) or
nonexempt private foundation that is subject to the reporting
requirements of section 6033 pursuant to section 6033(d).

* * * * *

(3)* * *

(iii) * * *

(C) In the case of a tax-exempt organization other than a private
foundation, the name and address of any contributor to the
organization; or

* * * * *

(4) * * * (i) * * * Returns filed pursuant to section 6033 include
Form 990, Return of Organization Exempt From Income Tax, Form 990-
PF, Return of Private Foundation, or any other version of Form 990
(such as Forms 990-EZ or 990-BL, except Form 990-T) and Form 1065.
Each copy of a return must include all information furnished to the
Internal Revenue Service on the return, as well as all schedules,
attachments and.18 supporting documents. For example, in the case of
a Form 990, the copy must include Schedule A of Form 990 (containing
supplementary information on section 501(c)(3) organizations), and
those parts of the return that show compensation paid to specific
persons (currently, Part V of Form 990 and Parts I and II of
Schedule A of Form 990).

(ii) * * * In the case of a tax-exempt organization other than a
private foundation, the term annual information return does not
include the name and address of any contributor to the organization.

* * * * *

(h) Effective date-(1) In general. For a tax-exempt organization,
other than a private foundation, this section is applicable June 8,
1999. For a private foundation, this section is applicable (except
as provided in paragraph (h)(2) of this section) beginning March 13,
2000.

(2) Private foundation annual information returns. This section does
not apply to any private foundation return the due date for which
(determined with regard to any extension of time for filing) is
before the applicable date for private foundations specified in
paragraph (h)(1) of this section. �301.6104(d)-4 [Redesignated as
�301.6104(d)-2 ] Par. 7. Section 301.6104(d)-4 is redesignated as
�301.6104(d)-2. Par. 8. Newly designated �301.6104(d)-2 is amended
as follows:

1. In paragraph (a), remove the language "�301.6104(d)-3(a)" from
each place it appears and add "�301.6104(d)-1(a)" in each place,
respectively.

2. Revise paragraph (e). The revision reads as follows:
�301.6104(d)-2 Making applications and returns widely available.

* * * * *

(e) Effective date. For a tax-exempt organization, other than a
private foundation, this section is applicable June 8, 1999. For a
private foundation, this section is applicable beginning March 13,
2000. �301.6104(d)-5 [Redesignated as �301.6104(d)-3 ] Par. 9.
Section 301.6104(d)-5 is redesignated as �301.6104(d)-3. Par. 10.
Newly designated �301.6104(d)-3 is amended as follows:

1. In paragraph (a), remove the language "�301.6104(d)-3(a)" and add
"�301.6104(d)-1(a)" in its place.

2. Revise paragraph (g). The revision reads as follows:
�301.6104(d)-3 Tax-exempt organization subject to harassment
campaign.

* * * * *

(g) Effective date. For a tax-exempt organization, other than a
private foundation, this section is applicable June 8, 1999. For a
private foundation, this section is applicable beginning March 13,
2000. .PART 602-OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION
ACT

Par. 11. The authority citation for part 602 continues to read as
follows: Authority: 26 U.S.C. 7805..20 Par. 12. In �602.101,
paragraph (b) is amended by removing the entries for 301.6104(d)-4
and 301.6104(d)-5, by revising the entries for 301.6104(d)-1 and
301.6104(d)-3, and adding a new entry for 301.6104(d)-2 in numerical
order to the table to read as follows:.�602.101 OMB Control numbers.

* * * * *

(b) * * *
___________________________________________________________________

CFR part or section where Current OMB
identified and described control No.

* * * * *

301.6104(d)-1.........................................1545 -1655
301.6104(d)-2.........................................1545 -1655
301.6104(d)-3.........................................1545 -1655

******
___________________________________________________________________

Robert E. Wenzel
Deputy Commissioner of Internal Revenue
Approved: 12-23-99
Jonathan Talisman
Acting Assistant Secretary of the Treasury
(Tax Policy)

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