1997 Notices
A "Notice" is a public pronouncement that may contain guidance that involves substantive interpretations of the Code or other provisions of law. Notices may also be used for documents that would be appropriate for an "Announcement", but for the need to preserve the guidance in the Cumulative Bulletin, published twice a year. For example, "notices" can be used to relate what regulations will say in situations where the regulations may not be published in the immediate future. All notices published in the weekly IRB are also published in the Cumulative Bulletin.
Under Revenue Ruling 90-91, "for purposes of applying the substantial understatement portion of the accuracy-related penalty, ...all notices and announcements issued by the Service and published in the Internal Revenue Bulletin are considered authority and may be relied upon to the same extent as a revenue ruling or revenue procedure."
Notices are in the Adobe Acrobat PDF format.
Internal Revenue Bulletin Summary pages are in HTML format.
| Notices |
Bulletin |
Date of IRB |
 |
| Notice 97-77(PDF, 14K) |
IRB #1997-52(HTML) |
Dec. 29, 1997 |
| Partnership magnetic media filing requirement. Guidance is provided to partnerships having more than 100 partners regarding the requirement to file partnership tax returns on magnetic media. |
| Notice 97-75(PDF, 39K) |
IRB #1997-51(HTML) |
Dec. 22, 1997 |
| Minimum distributions; age 70�; SBJPA. This notice sets forth additional guidance with respect to the amendments to the minimum distribution rules of section 401 (a)(9) of the Code made by section 1404 of the Small Business Job Protection Act of 1996. |
| Notice 97-74(PDF, 13K) |
IRB #1997-51(HTML) |
Dec. 22, 1997 |
| Weighted average interest rate update. Guidelines are set for determining for December 1997, the weighted average interest rate and the resulting permissible range of interest rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code as amended by the Omnibus Budget Reconciliation Act of 1987 and by the Uruguay Round Agreements Act (GATT). |
| Notice 97-73(PDF, 22K) |
IRB #1997-51(HTML) |
Dec. 22, 1997 |
| Information reporting; Hope Scholarship Credit; Lifetime Learning Credit. Educational institutions are informed of the information reporting requirements for 1998 under section 6050S of the Code, as added by the Taxpayer Relief Act of 1997, in connection with the Hope Scholarship Credit and Lifetime Learning Credit. |
| Notice 97-72(PDF, 10K) |
IRB #1997-50(HTML) |
Dec. 15, 1997 |
| Leased property; substantial modification. Taxpayers are informed of certain conditions under which changes in rental payment terms resulting from a lessor's refinancing of its indebtedness will not be a substantial modification of the rental agreement for purposes of section 467 of the Code. |
| Notice 97-71(PDF, 15K) |
IRB #1997-49(HTML) |
Dec. 8, 1997 |
| This notice provides tables which show the amount of an individual's income that is exempt from a notice of levy used to collect delinquent tax in 1998. |
| Notice 97-70(PDF, 12K) |
IRB #1997-49(HTML) |
Dec. 8, 1997 |
| This notice modifies Notice 97-9, 1997-2 I.R.B. 35, to incorporate the amendment made to adoption credit rules regarding the year(s) in which the credit for certain qualified adoption expenses is allowed. |
| Notice 97-69(PDF, 10K) |
IRB #1997-48(HTML) |
Dec. 1, 1997 |
| Weighted average interest rate update. Guidelines are set forth for determining for November 1997 the weighted average interest rate and the resulting permissible range of interest rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code as amended by the Omnibus Budget Reconciliation Act of 1987 and by the Uruguay Round Agreements Act (GATT). |
| Notice 97-68(PDF, 18K) |
IRB #1997-48(HTML) |
Dec. 1, 1997 |
| This notice informs taxpayers that the rules in sections 1.664-2(a)(1)(i) and 1.664-3(a)(1)(i)(e) of the proposed Income Tax regulations, published in REG-209823-96, 1997-18 I.R.B. 47, will not be effective for certain charitable remainder trusts for the 1997 tax year. |
| Notice 97-67(PDF, 18K) |
IRB #1997-48(HTML) |
Dec. 1, 1997 |
| Accounting method requests for grace period interest. This notice informs taxpayers that the Service will issue guidance that provides the procedures for a taxpayer to automatically change its method of accounting to comply with section 1004 of the Taxpayer Relief Act of 1997 for the taxpayer's first taxable year beginning after August 5, 1997. The notice provides that the Service will not grant any requests filed on or after August 5, 1997, to change to a method of accounting for grace period interest other than the method required by section 1004 of the Act. |
| Notice 97-66(PDF, 23K) |
IRB #1997-48(HTML) |
Dec. 1, 1997 |
| Securities lending transaction notice. Guidance is provided to payors of substitute interest payments made after November 13, 1997, and before January 1, 1999, to comply with the statement requirement of section 871(h)(5) of the Code in order to qualify the payments as portfolio interest payments for purposes of the tax imposed under sections 871 and 881 of the Code. Guidance is also provided to determine the amount of tax imposed and withheld on substitute dividend payments made by one foreign person to another foreign person. |
| Notice 97-65(PDF, 16K) |
IRB #1997-51(HTML) |
Dec. 22, 1997 |
| Due diligence; paid preparers; earned income credit. Paid preparers of 1997 federal income tax returns and claims for refund that involve the Earned Income Tax Credit are informed of the due diligence requirements that apply for purposes of the penalty under section 6695(g) of the Code, as added by the Taxpayer Relief Act of 1997. |
| Notice 97-64(PDF, 28K) |
IRB #1997-47(HTML) |
Nov. 24, 1997 |
| Designation of classes of capital gain dividends by RICs or REITs. This notice describes temporary regulations that will be published permitting RICs and REITs to designate different classes of capital gain dividends in accordance with section 1(h) of the Code as amended by the Taxpayer Relief Act of 1997. |
| Notice 97-63(PDF, 19K) |
IRB #1997-47(HTML) |
Nov. 24, 1997 |
| This notice asks for public comment on the alternatives for proposed regulations under section 2056 of the Code in light of the opinion of the Supreme Court of the United States in commissioner v. Estate of Hubert. The proposed regulations would provide guidance on when there is a "material limitation" on the right to income when income is used to pay estate administration expenses. |
| Notice 97-62(PDF, 16K) |
IRB #1997-49(HTML) |
Dec. 8, 1997 |
| This notice provides up to a 90-day extension of time to perform any act described in section 7508(a)(1) of the Code for taxpayers located in Grand Forks County, North Dakota, and Polk County, Minnesota, including filing and paying federal income tax. |
| Notice 97-61(PDF, 12K) |
IRB #1997-48(HTML) |
Dec. 1, 1997 |
| This notice informs the public of the Service's Year 2000 Date Standard Policy. |
| Notice 97-60(PDF, 58K) |
IRB #1997-46(HTML) |
Nov. 17, 1997 |
| Education incentives; credits; interest deduction; individual retirement accounts. Questions and answers are provided about the Hope Scholarship and Lifetime Learning Credits, the deduction for student loan interest, Education Individual Retirement Accounts, and other higher education tax incentives recently enacted by the Taxpayer Relief Act of 1997. |
| Notice 97-59(PDF, 29K) |
IRB #1997-45(HTML) |
Nov. 10, 1997 |
| Capital gains and losses; rates. Taxpayers are informed of rules for netting capital gains and losses under recently amended section 1(h) of the Code (which provides new capital gains tax rates) and how Code section 1(h) coordinates with other provisions of the Code. |
| Notice 97-58(PDF, 14K) |
IRB #1997-45(HTML) |
Nov. 10, 1997 |
| Retirement plans; 1998 cost-of-living adjustments. Cost-of-living adjustments, effective January 1, 1998, applicable to the dollar limits on benefits under qualified defined benefit pension plans and to other provisions affecting certain plans of deferred compensation, are set forth. |
| Notice 97-57(PDF, 9K) |
IRB #1997-43(HTML) |
Oct. 27, 1997 |
| Education individual retirement accounts. This notice informs certain entities that they are approved to serve as non-bank trustees and custodians of Education individual retirement accounts. It also provides guidance on the procedures for being approved to be a non-bank trustee or custodian of an Education IRA. |
| Notice 97-56(PDF, 11K) |
IRB #1997-43(HTML) |
Oct. 27, 1997 |
| Weighted average interest rate update. Guidelines are set forth for determining for October 1997, the weighted average interest rate and the resulting permissible range of interest rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code as amended by the Omnibus Budget Reconciliation Act of 1987 and by the Uruguay Round Agreements Act (GATT). |
| Notice 97-55(PDF, 36K) |
IRB #1997-40(HTML) |
Oct. 6, 1997 |
| T.D. 8656, 1996-1 C.B. 329, relating to the imposition of the accuracy-related penalty, is corrected. |
| Notice 97-54(PDF, 26K) |
IRB #1997-41(HTML) |
Oct. 14, 1997 |
| The Work Opportunity Tax Credit (WOTC) under section 51 of the Code has been revised and expanded, effective October 1, 1997, and the Welfare-to-Work Tax Credit goes into effect on January 1, 1998. |
| Notice 97-53(PDF, 32K) |
IRB #1997-40(HTML) |
Oct. 6, 1997 |
| Individual retirement accounts. This notice provides guidance relating to penalty-free withdrawals from IRAs for higher education expenses. |
| Notice 97-52(PDF, 32K) |
IRB #1997-38(HTML) |
Sept. 22, 1997 |
| Qualified state tuition programs (QSTPs). This notice extends the relief for reporting requirements that apply to QSTPs. |
| Notice 97-51(PDF, 31K) |
IRB #1997-38(HTML) |
Sept. 22, 1997 |
| Weighted average interest rate update. Guidelines are set forth for determining for September 1997, the weighted average interest rate and the resulting permissible range of interest rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code as amended by the Omnibus Budget Reconciliation Act of 1987 and by the Uruguay Round Agreements Act (GATT). |
| Notice 97-50(PDF, 7K) |
IRB #1997-37(HTML) |
Sept. 15, 1997 |
| Timely filing or payment; private delivery services. Taxpayers are informed that the list of private delivery services designed under section 7502 of the Code in Notice 97-26, 1997-17 I.R.B. 6, will remain in effect until further notice. The rules for application periods and issuance of new designation lists by the Service are modified. |
| Notice 97-49(PDF, 33K) |
IRB #1997-36(HTML) |
Sept. 9, 1997 |
| Electing Small Business Trust (ESBT) and qualification and treatment of distributions. This notice clarifies the definitions of beneficiary and potential current beneficiary. It also clarifies the treatment of ESBT distributions. |
| Notice 97-48(PDF, 24K) |
IRB #1997-35(HTML) |
Aug. 2, 1997 |
| This notice sets forth the 1997 changes to Publication 1187, Specifications for Filing Form 1042-S, Foreign Persons U.S. Source Income Subject to Withholding, Magnetically or Electronically (Rev. Proc. 96-11,1996-1 C.B. 578). |
| Notice 97-47(PDF, 11K) |
IRB #1997-35(HTML) |
Aug. 2, 1997 |
| Guidelines are set forth for determining for August 1997 the weighted average interest rate and the resulting permissible range of interest rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code as amended by the Omnibus Budget Reconciliation Act of 1987 and by the Uruguay Round Agreements Act (GATT). |
| Notice 97-46(PDF, 11K) |
IRB #1997-34(HTML) |
Aug. 25, 1997 |
| T.D. 8145, 1987-2 C.B. 47, relating to the allocation of interest expense among a taxpayer's expenditures, is corrected. |
| Notice 97-45(PDF, 33K) |
IRB #1997-33(HTML) |
Aug. 18, 1997 |
| Highly compensated employee; definition. This notice sets forth the changes in determining who is a highly compensated employee within the meaning of section 414(q) of the Code as a result of section 1431 of the Small Business Job Protection Act of 1996. |
| Notice 97-44(PDF, 16K) |
IRB #1997-31(HTML) |
Aug. 4, 1997 |
| Weighted average interest rate update. Guidelines are set forth for determining for July 1997, the weighted average interest rate and the resulting permissible range of interest rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code as amended by the Omnibus Budget Reconciliation Act of 1987 and by the Uruguay Round Agreements Act (GATT). |
| Notice 97-43(PDF, 19K) |
IRB #1997-30(HTML) |
July 28, 1997 |
| This notice provides guidance relating to the waiver of the failure-to-deposit penalty for certain taxpayers required to begin using electronic funds transfer on or after July 1, 1997. |
| Notice 97-42(PDF, 30K) |
IRB #1997-29(HTML) |
July 21, 1997 |
| This notice modifies the guidance set forth in Notice 97-18, 1997-10 I.R.B. 35, regarding the time for reporting certain transfers under section 1491 of the Code. |
| Notice 97-41(PDF, 43K) |
IRB #1997-28(HTML) |
July 14, 1997 |
| T.D. 8716, 1997-19 I.R.B. 5, relating to group health plan portability, access, and renewability requirements added to section 9801 of the Code by the Health Insurance Portability and Accountability Act of 1996, is corrected. |
| Notice 97-40(PDF, 12K) |
IRB #1997-28(HTML) |
July 14, 1997 |
| This notice announces that for periods on or after July 1, 1997, when China resumes the exercise of sovereignty over Hong Kong, the Service will continue to treat Hong Kong and China as two separate countries for purposes of certain bilateral agreements, the Internal Revenue Code (including subpart F), and the Income Tax Regulations. |
| Notice 97-39(PDF, 16K) |
IRB #1997-27(HTML) |
July 7, 1997 |
| 1997 enhanced oil recovery credit. The enhanced oil recovery credit for taxable years beginning in the 1997 calendar year is determined without regard to the phase-out for crude oil price increases provided in section 43(b) of the Code. |
| Notice 97-38(PDF, 12K) |
IRB #1997-27(HTML) |
July 7, 1997 |
| 1997 marginal production rates. This notice announces the applicable percentage to be used in determining percentage depletion on marginal production in tax years beginning in the 1997 calendar year. |
| Notice 97-37(PDF, 12K) |
IRB #1997-27(HTML) |
July 7, 1997 |
| Elections into mark-to-market accounting. The Service will issue additional guidance on elections under section 1.475(c)-1 of the regulations. This notice also extends the deadline to make a customer paper election on a retroactive basis. |
| Notice 97-35(PDF, 12K) |
IRB #1997-25(HTML) |
June 23, 1997 |
| Weighted average interest rate update. Guidelines are set forth for determining for June 1997, the weighted average interest rate and the resulting permissible range of interest rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code as amended by the Omnibus Budget Reconciliation Act of 1987 and by the Uruguay Round Agreements Act (GATT). |
| Notice 97-34(PDF, 90K) |
IRB #1997-25(HTML) |
June 23, 1997 |
| This notice provides guidance regarding the new foreign trust and foreign gift reporting provisions contained in the Small Business Job Protection Act of 1996. |
| Notice 97-33(PDF, 5K) |
IRB #1997-22(HTML) |
June 2, 1997 |
| Weighted average interest rate update. Guidelines are set forth for determining for May 1997, the weighted average interest rate and the resulting permissible range of interest rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code as amended by the Omnibus Budget Reconciliation Act of 1987 and by the Uruguay Round Agreements Act (GATT). |
| Notice 97-32(PDF, 30K) |
IRB #1997-21(HTML) |
May 27, 1997 |
| This notice sets forth the interim rules regarding the rate of interest to be used by insurance companies to compute under Code sections 807(c)(3) or 807(d)(2) reserves for modified guaranteed contracts as defined in Code section 817A, and the determination of policy interest under Code section 812 with regard to these contracts. |
| Notice 97-31(PDF, 32K) |
IRB #1997-21(HTML) |
May 27, 1997 |
| Qualified long-term care. Interim guidance is provided on the definition of a "chronically ill individual" for purposes of the definitions of "qualified long-term care services" and a "qualified long-term care insurance contract" under Code section 213(d). |
| Notice 97-30(PDF, 24K) |
IRB #1997-20(HTML) |
May 19, 1997 |
| Electricity produced from certain renewable resources; calendar year 1997 inflation adjustment factor and reference prices. This notice announces the calendar year 1997 inflation adjustment factor and reference prices for the renewable electricity production credit under section 45 of the Code. |
| Notice 97-29(PDF, 16K) |
IRB #1997-20(HTML) |
May 19, 1997 |
| T.D. 7637, 1979-2 C.B. 311, relating to consolidated returns, is corrected. |
| Notice 97-28(PDF, 10K) |
IRB #1997-18(HTML) |
May 5, 1997 |
| Credit for producing fuel from a nonconventional source, section 29 inflation adjustment factor, and section 29 reference price. This notice publishes the section 29 inflation adjustment factor, the nonconventional source fuel credit, and the section 29 reference price for calendar year 1996. |
| Notice 97-27(PDF, 14K) |
IRB #1997-17(HTML) |
April 28, 1997 |
| Weighted average interest rate update. Guidelines are set forth for determining for April 1997, the weighted average interest rate and the resulting permissible range of interest rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code as amended by the Omnibus Budget Reconciliation Act of 1987 and the Uruguay Round Agreements Act (GATT). |
| Notice 97-26(PDF, 24K) |
IRB #1997-17(HTML) |
April 28, 1997 |
| Timely filing or payment; private delivery services. A list of designated private delivery services is provided for purposes of the "timely filing/paying" rules of section 7502 of the Code. |
| Notice 97-25(PDF, 38K) |
IRB #1997-16(HTML) |
April 21, 1997 |
| T.D. 8560, 1994-2 C.B. 200; T.D. 8597, 1995-2 C.B. 147; and T.D. 8660, 1996-1 C.B. 195, relating to the consolidated return investment adjustment provisions, intercompany transactions provisions, and the provisions limiting losses and deductions from transactions between members of a non-consolidated controlled group, are corrected. |
| Notice 97-24(PDF, 25K) |
IRB #1997-16(HTML) |
April 21, 1997 |
| Certain trust arrangements. This notice warns taxpayers about "trust" arrangements that purport to reduce or eliminate federal taxes in ways that are not permitted by the tax law. The notice describes some typical abusive trust arrangements and provides that, in appropriate circumstances, taxpayers and/or promoters in these trust arrangements may be subject to civil and/or criminal penalties. |
| Notice 97-23(PDF, 5K) |
IRB #1997-14(HTML) |
April 7, 1997 |
| Weighted average interest rate update. Guidelines are set forth for determining; for March 1997, the weighted average interest rate and the resulting permissible range of interest rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code as amended by the Omnibus Budget Reconciliation Act of 1987 and by the Uruguay Round Agreements Act (GATT). |
| Notice 97-22(PDF, 19K) |
IRB #1997-13(HTML) |
March 31, 1997 |
| A determination has been made to add diglycidyl ether of bisphenol-A to the list of taxable substances in section 4672(a)(3) of the Code. |
| Notice 97-21(PDF, 18K) |
IRB #1997-11(HTML) |
March 17, 1997 |
| Self-amortizing investments in conduit financing entities. The Service and Treasury expect to issue regulations under section 7701(1) of the Code in order to prevent tax avoidance. In cases where certain conduit financing entities issue "equity" interests that are economically self-amortizing, it is expected that the regulations will treat the owners of the conduits as having invested directly in the conduit's income-producing assets. |
| Notice 97-20(PDF, 29K) |
IRB #1997-10(HTML) |
March 10, 1997 |
| Accounting periods; small business corporations. Procedures are provided under which a taxpayer may automatically change its annual accounting period in order elect to be an S corporation effective for the taxable year beginning January 1, 1997. |
| Notice 97-19(PDF, 107K) |
IRB #1997-10(HTML) |
March 10, 1997 |
| This notice provides guidance under sections 877, 2107, 2501, and 6039F for expatriates who lose U.S. citizenship or cease to be taxed as long-term residents of the United States with a principal purpose to avoid U.S. taxes. This notice also provides guidance on the interaction of section 7701(b)(10) with section 877, as amended by the Health Insurance Portability and Accountability Act of 1996. |
| Notice 97-18(PDF, 41K) |
IRB #1997-10(HTML) |
March 10, 1997 |
| This notice provides guidance concerning the application of sections 1491 through 1494 of the Code to certain transfers of property by a U.S. person to a foreign corporation, partnership, trust, or estate. Pursuant to section 1902 of the Small Business Job Protection Act of 1996, failure to report such a transfer made after August 20, 1996, could result in a penalty equal to 35 percent of the value of the property transferred |
| Notice 97-17(PDF, 17K) |
IRB #1997-10(HTML) |
March 10, 1997 |
| The "differential earnings rate" under section 809 is tentatively determined for 1996 together with the "re-computed differential earnings rate" for 1995. |
| Notice 97-16(PDF, 18K) |
IRB #1997-9(HTML) |
March 3, 1997 |
| Weighted average interest rate update. Guidelines are set forth for determining for February 1997, the weighted average interest rate and the resulting permissible range of interest rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code as amended by the Omnibus Budget Reconciliation Act of 1987 and by the Uruguay Round Agreements Act (GATT). |
| Notice 97-15(PDF, 16K) |
IRB #1997-8(HTML) |
Feb. 24, 1997 |
| The Service intends to modify section 40.6302(c)1 (c)(2) of the Excise Tax Procedural Regulations to provide that the availability of the safe harbor deposit rule based on look-back quarter liability is limited in cases where a new excise tax is enacted or an expired excise tax is reinstated. |
| Notice 97-14(PDF, 17K) |
IRB #1997-8(HTML) |
Feb. 24, 1997 |
| Low-income housing tax credit. Resident populations of the various states, for determining the 1997 calendar year (1) state housing credit ceiling under section 42(h) of the Code, and (2) private activity bond volume cap under section 146, are reproduced. |
| Notice 97-13(PDF, 18K) |
IRB #1997-6(HTML) |
Feb. 10, 1997 |
| Change in accounting method; alternative minimum tax. Taxpayers are informed that the Service intends to provide approval for farmers to change their method of accounting for income from certain deferred payment sales contracts for purposes of computing their alternative minimum tax. |
| Notice 97-12(PDF, 10K) |
IRB #1997-3(HTML) |
Jan. 21, 1997 |
| Electing Small Business Trust (ESBT) election. This notice provides the time and manner for the trustee to elect to be treated as an ESBT. This notice also provides that only the trustee need consent to the S corporation election on Form 2553. |
| Notice 97-11(PDF, 58K) |
IRB #1997-2(HTML) |
Jan. 13, 1997 |
| Qualified domestic relations orders; sample language. The Service has developed sample language for qualified domestic relations orders within the meaning of section 414(p) of the Code in accordance with section 1457 of the Small Business Job Protection Act of 1996. |
| Notice 97-10(PDF, 82K) |
IRB #1997-2(HTML) |
Jan. 13, 1997 |
| Spousal consent; qualified joint and survivor annuities, etc.; sample language. The Service has developed sample language for inclusion in a form providing spousal consent to a participant's election to waive a qualified joint and survivor annuity or a qualified pre-retirement survivor annuity, in accordance with section 1457 of the Small Business Job Protection Act of 1996. |
| Notice 97-9(PDF, 78K) |
IRB #1997-2(HTML) |
Jan. 13, 1997 |
| Adoption assistance. This notice provides general guidance concerning the tax credit under section 23 for "qualified adoption expenses" paid or incurred by an individual and the exclusion from gross income under section 137 for amounts paid or expenses incurred by an employer for "qualified adoption expenses" under an adoption assistance program. |
| Notice 97-8(PDF, 17K) |
IRB #1997-4(HTML) |
Jan. 27, 1997 |
| Weighted average interest rate update. Guidelines are set forth for determining for January 1997 the weighted average interest rate and the resulting permissible range of interest rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code as amended by the Omnibus Budget Reconciliation Act of 1987 and by the Uruguay Round Agreements Act (GATT). |
| Notice 97-7(PDF, 40K) |
IRB #1997-1(HTML) |
Jan. 6, 1997 |
| Environmental cleanup costs; letter rulings. Comments are requested on a proposed revenue procedure that, when finalized, will provide special procedures for requesting written guidance on the tax treatment under sections 162 and 263 of the Code of environmental cleanup costs incurred in transactions that span past and future taxable years. |
| Notice 97-6(PDF, 74K) |
IRB #1997-2(HTML) |
Jan. 13, 1997 |
| Questions and answers; SIMPLE IRAs. A notice, in question and answer format, pertaining to simple IRAs described in section 408(p) of the Code as added by the Small Business Job Protection Act of 1996, is set forth. |
| Notice 97-5(PDF, 24K) |
IRB #1997-2(HTML) |
Jan. 13, 1997 |
| Electing small business corporations and banks. This notice provides guidance on the effect of the qualified subchapter S subsidiary (QSSS) election under section 1361(b)(3) on banks affiliated with non-banks; the application of the S corporation passive investment income rule of section 1362(d)(3); the application of the interest expense disallowance rules of section 265; and an automatic change in method of accounting for bad debts. |
| Notice 97-4(PDF, 33K) |
IRB #1997-2(HTML) |
Jan. 13, 1997 |
| S corporation subsidiaries. This notice requests comments concerning issues raised by section 1308 of the Small Business Job Protection Act of 1996 which permits an S corporation (1) to own 80 percent or more of the stock of a C corporation, and (2) to elect to own a qualified subchapter S subsidiary (QSSS). This notice also provides temporary guidance on the manner in which a QSSS election must be made and the effective date of the election. |
| Notice 97-3(PDF, 21K) |
IRB #1997-26(HTML) |
June 30, 1997 |
| Net operating losses; specified liability losses. Taxpayers are informed that the characterization of certain net operating losses as specified liability losses under Code section 172(f) is improper, and that the Service will closely scrutinize claims for refund and applications for tentative carryback adjustments that are attributed to specified liability losses. |
| Notice 97-3(PDF, 21K) |
IRB #1997-1(HTML) |
Jan. 6, 1997 |
| Accounting periods, small business corporations. Taxpayers are informed that the Service intends to waive certain limitations on a corporation's ability to expeditiously change its annual accounting period in order to elect to be an S corporation effective for the taxable year beginning January 1, 1997. |
| Notice 97-2(PDF, 33K) |
IRB #1997-2(HTML) |
Jan. 13, 1997 |
| Cash or deferred arrangements; nondiscrimination. With respect to cash or deferred arrangements, the notice gives transitional relief for certain nondiscrimination tests for the 1997 plan year and describes methods for the determination and distribution of excess contributions. |
| Notice 97-1(PDF, 21K) |
IRB #1997-2(HTML) |
Jan. 13, 1997 |
| Revenue rulings and revenue procedures under T.D. 8697 obsoleted. Revenue rulings and revenue procedures that use the prior classification regulations to differentiate between partnerships and associations are obsolete to the extent that they rely on those prior regulations. |
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