Definition of Terms Used by the IRS
in Official Documents
Revenue Rulings and Revenue Procedures
(hereinafter referred to as "rulings") that have an effect on previous rulings
use the following defined terms to describe the effect:
Amplified describes a situation where no change
is being made in a prior published position, but the prior position is being extended to
apply to a variation of the fact situation set forth therein. Thus, if an earlier ruling
held that a principle applied to A, and the new ruling holds that the same principle also
applies to B, the earlier ruling is amplified. (Compare with modified,
Clarified is used in those instances where the
language in a prior ruling is being made clear because the language has caused, or may
cause, some confusion. It is not used where a position in a prior ruling is being changed.
Distinguished describes a situation where a
ruling mentions a previously published ruling and points out an essential difference
Modified is used where the substance of a
previously published position is being changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the new ruling holds that it applies to both A
and B, the prior ruling is modified because it corrects a published position. (Compare
with amplified and clarified,
Obsoleted describes a previously published
ruling that is not considered determinative with respect to future transactions. This term
is most commonly used in a ruling that lists previously published rulings that are
obsoleted because of changes in law or regulations. A ruling may also be obsoleted because
the substance has been included in regulations subsequently adopted.
Revoked describes situations where the position
in the previously published ruling is not correct and the correct position is being stated
in the new ruling.
Superseded describes a situation where the new
ruling does nothing more than restate the substance and situation of a previously
published ruling (or rulings). Thus, the term is used to republish under the 1986 Code and
regulations the same position published under the 1939 Code and regulations. The term is
also used when it is desired to republish in a single ruling a series of situations,
names, etc., that were previously published over a period of time in separate rulings. If
the new ruling does more than restate the substance of a prior ruling, a combination of
terms is used. For example, modified and
superseded describes a situation where the substance of a
previously published ruling is being changed in part and is continued without change in
part and it is desired to restate the valid portion of the previously published ruling in
a new ruling that is self contained. In this case the previously published ruling is first
modified and then, as modified, is superseded.
Supplemented is used in situations in which a
list, such as a list of the names of countries, is published in a ruling and that list is
expanded by adding further names in subsequent rulings. After the original ruling has been
supplemented several times, a new ruling may be published that includes the list in the
original ruling and the additions, and supersedes all prior rulings in the series.
Suspended is used in rare situations to show
that the previous published rulings will not be applied pending some future action such as
the issuance of new or amended regulations, the outcome of cases in litigation, or the
outcome of a Service study.
The following abbreviations in current use and formerly used will appear in material
published in the Internal Revenue Bulletin.
A - Individual.
Acq. - Acquiescence.
B - Individual.
BE - Beneficiary.
BK - Bank.
B.T.A. - Board of Tax Appeals.
C. - Individual.
C.B. - Cumulative Bulletin.
CFR - Code of Federal Regulations.
CI - City.
COOP - Cooperative.
Ct.D. - Court Decision.
CY - County.
D - Decedent.
DC - Dummy Corporation.
DE - Donee.
Del. Order - Delegation Order.
DISC - Domestic International Sales Corporation.
DR - Donor.
E - Estate.
EE - Employee.
E.O. - Executive Order.
ER - Employer.
ERISA - Employee Retirement Income Security Act.
EX - Executor.
F - Fiduciary.
FC - Foreign Country.
FICA - Federal Insurance Contribution Act.
FISC - Foreign International Sales Company.
FPH - Foreign Personal Holding Company.
FR. - Federal Register.
FUTA - Federal Unemployment Tax Act.
FX - Foreign Corporation.
G.C.M. - Chief Counsel's Memorandum.
GE - Grantee.
GP - General Partner.
GR - Grantor.
IC - Insurance Company.
I.R.B. - Internal Revenue Bulletin.
LE - Lessee.
LP - Limited Partner.
LR - Lessor.
M - Minor.
Nonacq. - Nonacquiescence.
O - Organization.
P - Parent Corporation.
PHC - Personal Holding Company.
PO - Possession of the U.S.
PR - Partner.
PRS - Partnership.
PTE - Prohibited Transaction Exemption.
Pub. L. - Public Law.
REIT - Real Estate Investment Trust.
Rev. Proc. - Revenue Procedure.
Rev. Rul. - Revenue Ruling.
S - Subsidiary.
S.P.R. - Statements of Procedural Rules.
Stat. - Statutes at Large.
T - Target Corporation.
TC. - Tax Court.
TD. - Treasury Decision.
TFE - Transferee.
TFR - Transferor.
T.I.R. - Technical Information Release.
TP - Taxpayer.
TR - Trust.
TT - Trustee.
U.S.C. - United States Code.
X - Corporation.
Y - Corporation.
Z - Corporation.
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