Internal Revenue Bulletins  

March 30, 1992

Internal Revenue Bulletin No. 1992-13

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Rev. Rul. 92-19
Insurance companies; interest rate and mortality and morbidity tables. Prevailing state assumed interest rates and prevailing commissioners' standard tables of mortality and morbidity are provided for the determination of reserves under section 807 of the Code for contracts issued in taxable years beginning after December 31, 1983. Rev. Rul. 87-26 clarified and supplemented.

Rev. Rul. 92-20
Trusts; qualified subchapter S trusts. A provision in a trust agreement that authorizes the trustee to accumulate trust income in the event that the trust does not hold any shares of an S corporation does not preclude the trust's qualification as a "qualified subchapter S trust" (QSST).

Proposed regulations under section 6045 of the Code relate to information returns of brokers. A public hearing will be held on April 21, 1992.


Rev. Proc. 92-24
Employee plans determination letters; section 420. This procedure describes the issuance of determination letters by the EP/EO Division of key district offices pertaining to the application of section 420 of the Code relating to the transfer of excess assets to a health benefits account within the meaning of section 401(h). Rev. Proc. 92-6 modified.

Announcement 92-54
This announcement allows taxpayers to file the notification required by section 420 of the Code as described in the Omnibus Budget Reconciliation Act of 1990 exclusively with the Department of Labor.


Announcement 92-53
A list is given of organizations now classified as private foundations and an organization that is not a private operating foundation.


Rev. Rul. 92-22
Annuities; individual retirement accounts; transition rules. The proceeds of a decedent's individual retirement account that were rolled over from a qualified plan are includible in the gross estate of a decedent who died after December 31, 1984, if the decedent did not irrevocably elect the form of benefit before July 18, 1984, and was not in pay status on December 31, 1984.


Rev. Proc. 92-23
Penalties; substantial understatement. Guidance is provided concerning when information shown on a return in accordance with the applicable forms and instructions will be adequate disclosure for purposes of reducing an understatement of income tax under section 6662(d) of the Code.

Rev. Proc. 92-25
Treatment of variable contracts; closing agreements. This procedure provides the mechanism for entering into a closing agreement to obtain the relief described in section 1.817-5 of the regulations for the inadvertent failure of the assets in a segregated asset account to be adequately diversified. Rev. Rul. 91-17 and Rev. Proc. 92-1 amplified.

Rev. Proc. 92-26
Insurance companies; reporting requirements for certain tax-free exchanges. An insurance company is not required to report an exchange of contracts that is tax free under section 1035 of the COde if both the new and the old contracts are issued by the same company and no designated distribution results from the exchange.

Del. Order 67 (Rev. 20)
This order gives specific authorization to sign the name of, or on behalf of, Shirley D. Peterson, Commissioner of Internal Revenue. Del. Order 67 (Rev. 19) superseded.

Announcement 92-49
Errors in Publication 1212, List of Original Issue Discount Instruments (Rev. Oct. 91), are corrected.

Announcement 92-50
The Service solicits public comments on the federal income tax consequences of the sulfur dioxide emission allowances program of Title IV of the Clean Air Act of 1990.

Announcement 92-51
T.D. 8245, relating to dividend and other distributions after the sale of a subsidiary member of an affiliated group filing consolidated returns, published in 1989-1 C.B. 270, is corrected.

Announcement 92-52
CO-111-90, 1992-6 I.R.B. 12, relating to stock and asset consistency rules under section 338 of the Code, is corrected.

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