Documenti di Didattica
Documenti di Professioni
Documenti di Cultura
2006-36
September 5, 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 sections 901 and 903 of the Code. A public hearing is sched-
uled for October 13, 2006.
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.
Mid-term
AFR 5.01% 4.95% 4.92% 4.90%
110% AFR 5.52% 5.45% 5.41% 5.39%
120% AFR 6.03% 5.94% 5.90% 5.87%
130% AFR 6.54% 6.44% 6.39% 6.36%
150% AFR 7.57% 7.43% 7.36% 7.32%
175% AFR 8.85% 8.66% 8.57% 8.51%
Long-term
AFR 5.21% 5.14% 5.11% 5.09%
110% AFR 5.73% 5.65% 5.61% 5.58%
120% AFR 6.27% 6.17% 6.12% 6.09%
130% AFR 6.79% 6.68% 6.63% 6.59%
Composite Corporate
For Plan Years Corporate Bond
Beginning in: Bond Weighted Permissible Range
Month Year Rate Average 90% 100%
December 2005 5.72
DRAFTING INFORMATION vision. For further information regarding 4:30 p.m. Eastern time, Monday through
this notice, please contact the Employee Friday. Mr. Montanaro may be reached at
The principal author of this notice is Plans’ taxpayer assistance telephone ser- 1–202–283–9714 (not a toll-free number).
Tony Montanaro of the Employee Plans, vice at 1–877–829–5500 (a toll-free num-
Tax Exempt and Government Entities Di- ber), between the hours of 8:30 a.m. and
Taxpayer:
Name:
Address:
City, State and Zip Code:
Taxpayer EIN Tax Years Involved
Corporate Officer: Title:
Telephone #: ( ) Fax #: ( )
Compliance:
Revenue Agent/SB/SE Group Manager Name: Group
Address:
City, State and Zip Code:
Telephone Number: ( ) Fax #: ( )
MFT Code Type of Tax
Name of Representative:
Taxpayer’s Representative (if applicable):
Name of Firm:
Address:
City, State and Zip Code:
Telephone #: ( ) Fax #: ( )
SIGNATURES
The undersigned request Appeals assistance in the SB/SE-Appeals Fast Track Settlement process. The issues for which this
assistance is requested are described in the Summary of Issues or Examination Re-Engineering Lead sheets and Taxpayer’s written
response thereto attached to this agreement. By signing the Application to Fast Track Settlement, the taxpayer consents, pursuant
to section 6103(c) of the Internal Revenue Code, to the disclosure of the taxpayer’s returns and return information pertaining to
the issues being considered in the FTS process to those persons named on the Agreement as participants in the process. IRS
employees, the taxpayer and persons invited to participate by the IRS or the taxpayer shall not voluntarily disclose information
regarding any communication made during the SB/SE Fast Track Settlement session, except as provided by statute, such as in
sections 6103 or 7214 (a) (8) of the Code, or 5 U.S.C. § 574. The prohibition against ex parte communications between Appeals
Officers and other Service employees provided by section 1001(a) of the Internal Revenue Service Restructuring and Reform Act
of 1998 does not apply to the communications arising in Fast Track Settlement because Appeals personnel, in facilitating an
agreement between the taxpayer and SB/SE, are not acting in their traditional Appeals settlement role.
Representative Date
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.
Proposed Regulations:
1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2006–1 through 2006–26 is in Internal Revenue Bulletin
2006–26, dated June 26, 2006.
Proposed Regulations:
REG-134317-05
Corrected by
Ann. 2006-47, 2006-28 I.R.B. 78
Revenue Procedures:
2002-9
Modified and amplified by
Notice 2006-67, 2006-33 I.R.B. 248
2005-41
Superseded by
Rev. Proc. 2006-29, 2006-27 I.R.B. 13
2005-49
Superseded by
Rev. Proc. 2006-33, 2006-32 I.R.B. 140
Revenue Rulings:
81-35
Amplified and modified by
Rev. Rul. 2006-43, 2006-35 I.R.B. 329
81-36
Amplified and modified by
Rev. Rul. 2006-43, 2006-35 I.R.B. 329
87-10
Amplified and modified by
Rev. Rul. 2006-43, 2006-35 I.R.B. 329
2002-41
Amplified by
Rev. Rul. 2006-36, 2006-36 I.R.B. 353
2003-43
Amplified by
Notice 2006-69, 2006-31 I.R.B. 107
1 A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2006–1 through 2006–26 is in Internal Revenue Bulletin 2006–26, dated June 26, 2006.
CUMULATIVE BULLETINS
The contents of this weekly Bulletin are consolidated semiannually into a permanent, indexed, Cumulative Bulletin. These are
sold on a single copy basis and are not included as part of the subscription to the Internal Revenue Bulletin. Subscribers to the weekly
Bulletin are notified when copies of the Cumulative Bulletin are available. Certain issues of Cumulative Bulletins are out of print
and are not available. Persons desiring available Cumulative Bulletins, which are listed on the reverse, may purchase them from the
Superintendent of Documents.
HOW TO ORDER
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