Guidance Under Subpart F Relating to
Partnerships & Branches.

DEPARTMENT OF THE TREASURY
Internal Revenue Service 26 CFR Parts 1 and 301 [REG-104537-97] RIN
1545-AV11

TITLE: Guidance under Subpart F Relating to Partnerships and
Branches.

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking, notice of proposed rulemaking
by cross-reference to temporary regulations and notice of public
hearing.

SUMMARY: The IRS and Treasury Department are issuing temporary
regulations, published elsewhere in this issue of the Federal
Register, relating to the treatment under subpart F of certain
branches of a controlled foreign corporation (CFC) that are treated
as separate entities for foreign tax purposes . The text of the
temporary regulations also serves as the text of these proposed
regulations. In addition, this document contains proposed
regulations relating to the treatment of a CFC's distributive share
of partnership income. This document also provides notice of a
public hearing on these proposed regulations.

DATES: Written comments must be received by June 24, 1998.

Outlines of oral comments to be discussed at the public hearing
scheduled for July 15, 1998, must be received by June 24, 1998.

ADDRESSES: Send submissions to: CC:DOM:CORP:R (REG-104537-97), room
5226, Internal Revenue Service, POB 7604, Ben Franklin Station,
Washington DC 20044. Submissions may be hand delivered between the
hours of 8 a.m. and 5 p.m. to: CC:DOM:CORP:T:R (REG-104537- 97),
Courier's Desk, Internal Revenue Service, 1111 Constitution Avenue,
NW., Washington DC. Alternatively, taxpayers may submit comments
electronically via the Internet by selecting the "Tax Regs" option
on the IRS Home Page, or by submitting comments directly to the IRS
Internet site at
http://www.irs.ustreas.gov/prod/tax_regs/comments.html. The public
hearing will be held in room 2615, Internal Revenue Building, 1111
Constitution Avenue NW., Washington, DC 20224.

FOR FURTHER INFORMATION CONTACT: Concerning the regulations, Valerie
Mark, (202) 622-3840; concerning submissions and the hearing, Mike
Slaughter (202) 622-7190 (not toll-free numbers).

SUPPLEMENTARY INFORMATION:

Background

I. In General

In these proposed regulations, and in temporary regulations
published elsewhere in this issue of the Federal Register, the
Treasury and IRS set forth a framework for dealing with the issues
posed by the use of certain entities which are regarded as fiscally
transparent for the purposes of U.S. tax law, with regard to the
application of subpart F of the Internal Revenue Code.

Subpart F was enacted by Congress to limit the deferral of U.S.
taxation of certain income earned outside the United States by
foreign corporations controlled by U.S. persons. Limited deferral
was retained after the enactment of subpart F to protect the
competitiveness of controlled foreign corporations (CFCs) doing
business overseas. See S. Rep. No. 1881, 87th Cong., 2d Sess. 78-80
(1962). This limited deferral furthers the objective of allowing a
CFC engaged in an active business, and located in a foreign country
for appropriate economic reasons, to compete in a similar tax
environment with non-U.S. owned corporations located in the same
country.

Conversely, one of the purposes of subpart F is to prevent CFCs from
converting active income that is not easily moveable and is earned
in a jurisdiction in which a business is located for non-tax reasons
into passive, easily moveable income shifted to a lower tax
jurisdiction primarily for tax avoidance.

Moreover, when subpart F was first enacted it was realized that
related person transactions can be easily manipulated to reduce both
United States and foreign taxes. Consequently, in enacting subpart
F, Congress provided that transactions of CFCs that involve related
persons generally give rise to subpart F income with certain
enumerated exceptions.

Hybrid branches, by definition, are not regarded as fiscally
transparent under foreign law. Thus, they are particularly well
suited for the type of tax avoidance described above. In light of
the recent proliferation of hybrid branches, Treasury and the IRS
believe that it is appropriate to consider the issues related to
transactions involving hybrid branches, or other hybrid entities,
under subpart F.

The use of other organizations that are fiscally transparent for
U.S. tax purposes, including partnerships, raise additional issues.
These entities may or may not be fiscally transparent under foreign
law. In the context of subpart F, issues similar to those raised in
connection with hybrid branches are raised in connection with
partnerships. (Other fiscally-transparent entities, such as grantor
trusts, will be the subject of guidance issued in conjunction with
the finalization of regulations under section 672(f).) The entity
classification regulations of §§301.7701-1 through 301.7701-3 (the
check-the-box regulations) make entity classification generally
elective, in part so that taxpayers can choose a tax status
consistent with their business objectives.

This administrative provision, however, was not intended to change
substantive law. Particularly in the international area, however,
the ability to more easily achieve fiscal transparency can lead to
inappropriate results under certain substantive international
provisions of the Code. Thus, the Treasury and the IRS believe that
it is necessary to provide additional guidance regarding the use of
hybrid entities in the international context. See preamble to T.D.
8697, 61 Fed. Reg. 66585 (December 18, 1996).

II. Controlled Foreign Corporation's Distributive Share of
Partnership Income

In Brown Group, Inc. v. Commissioner, 77 F.3d 217 (8th Cir.

1996), vacating and remanding 104 T.C. 105 (1995), a Cayman Islands
partnership with a Cayman Islands CFC partner earned commission
income from selling footwear purchased in Brazil on behalf of the
CFC's U.S. parent. This commission income would have been subpart F
income, specifically foreign base company sales income under section
954(d), to the CFC if it had earned this commission income directly
and under the same circumstances in which the partnership earned
this income. The Tax Court held that the CFC's distributive share of
this commission income was subpart F income. The Eighth Circuit,
vacating and remanding the Tax Court's decision, held that the CFC's
distributive share of this commission income was not subpart F
income.

In response to the Eighth Circuit's opinion, the IRS announced that
it intended to issue regulations under subpart F to confirm its
position that whether a CFC partner's distributive share of
partnership income is subpart F income generally is determined at
the CFC partner level. See Notice 96-39 (1996-2 C.B. 209).

These proposed regulations would address the treatment of a CFC
partner's distributive share of partnership income under subpart F.
These regulations apply to all categories of subpart F income, not
only to foreign base company sales income, which was at issue in
Brown Group. These regulations would provide specific rules that
apply to determine a CFC partner's distributive share of foreign
personal holding company income, foreign base company sales income,
foreign base company services income, and earnings invested in
United States property.

The approach taken by these proposed regulations is based on the
provisions of subchapter K and subpart F and the policies underlying
those provisions. The legislative history of subchapter K indicates
that a partnership distributive share should be characterized by
using the approach that best serves the Code or regulations section
at issue. Subpart F limits deferral of U.S. income tax on common
types of passive income received by CFCs, as well as on certain
other types of easily moveable income. To allow a CFC to avoid
subpart F treatment for items of income by the simple expedient of
receiving them as distributive shares of partnership income, rather
than directly, is contrary to the intent of subpart F.

Explanation of Provisions

Under these proposed regulations, income and deductions would be
characterized at the partnership level. If any part of the
partnership's gross income would be subpart F income if received
directly by partners that are CFCs, it must be separately stated
under section 702. Comments are requested as to whether this rule
should not apply for ownership levels under certain thresholds. The
regulations under section 702 also would be clarified to expressly
provide that an item must be separately stated when, if separately
taken into account by any partner, the separately stated item would
affect the income tax liability of that partner or any other person.
This clarification incorporates in the regulations the position of
the IRS. See Rev. Rul. 86-138 (1986-2 C.B. 84) (holding that a
subsidiary partnership in a multi-tiered arrangement must separately
state items which, if separately taken into account by any partner
of any partnership in the multi-tiered arrangement, would affect the
income tax liability of that partner).

The regulations under section 952 would also be clarified to
expressly include within the definition of subpart F income a CFC's
distributive share of any item of gross income of a partnership to
the extent the income would have been subpart F income if received
by the CFC partner directly. The proposed regulations would further
provide that, generally, in determining whether a distributive share
of partnership income is subpart F income, whether an entity is a
related person and whether activity takes place in or outside the
CFC's country of incorporation is determined with respect to the CFC
partner and not the partnership. Thus, on the Brown Group facts, the
income in issue would retain its character as commission income from
the sale of shoes purchased in Brazil on behalf of a U.S. parent for
sale in the U.S. It would be determined at the CFC partner level
that the shoes were manufactured and sold for use outside of the
CFC's country of incorporation (Cayman Islands), and that the U.S.
parent was a related person with respect to the CFC. Thus, the
income would be foreign base company sales income.

The proposed and temporary regulations also address the question of
whether a CFC's distributive share of partnership income can qualify
for the exceptions from foreign personal holding company income
treatment. Some of these exceptions are based on whether the income
is earned in a transaction with a related person that is
incorporated, or uses property, in the CFC's country of
incorporation. The proposed and temporary regulations address the
application of those exceptions. Other exceptions are based on the
activities performed by the CFC in connection with the property
through which it earns the income.

The proposed regulations would provide that the exceptions requiring
activity will generally apply if the exception would have applied to
the income had the partnership itself been a CFC.

This requirement is not met if the partnership can qualify for the
exception only by taking into account the separate activities of its
partners (e.g., the partnership owns property and the CFC provides
the management services).

These proposed regulations would amend the rules regarding the
application of the manufacturing exception of §1.954-3(a)(4).

The regulations would clarify the Service's current position that,
in general, a controlled foreign corporation can apply the exception
only if it has performed the manufacturing activities itself. Thus,
manufacturing activities of a contract manufacturer will not be
taken into account.

Nevertheless, the manufacturing activities of a partnership may be
taken into account under the distributive share rules when the
partnership sells the property that it manufactures. These proposed
regulations would clarify how the manufacturing exception of
§1.954-3(a)(4) applies in the context of the distributive share
rules. As previously noted, the general rules would provide that
income that could be foreign base company sales income at the CFC
partner level is separately stated and that determinations as to
relatedness and the relevant country are made at the partner level.
Consistent with the framework outlined above, these regulations
would allow a CFC's distributive share of sales income to be
excluded, under the manufacturing exception of §1.954-3(a)(4), when
the partnership's activities with respect to the property it sells
(without regard to the CFC partner's activities) would be sufficient
to constitute manufacturing.

Treasury and the IRS are considering applying foreign base company
sales income rules in the context of manufacturing branches of
partnerships. Comments are requested as to the appropriate scope of
such rules.

Under the general rule for determining whether a CFC partner's
distributive share includes subpart F income, a CFC partner's
distributive share of partnership income earned from performing
services for or on behalf of a person that is a related person with
respect to the CFC partner will be foreign base company services
income. These proposed regulations also would describe how the
substantial assistance rule of §1.954- 4(b)(1)(iv) applies when the
CFC earns services income through a partnership. When the
partnership is performing services for a person unrelated to the CFC
partner but the CFC partner provides substantial assistance to the
partnership contributing to the performance of those services, the
partner and the partnership would be regarded as separate entities
and the substantial assistance provided from the CFC to the
partnership would cause the CFC's distributive share of the services
income to be treated as foreign base company services income.
Treasury and the IRS are considering applying similar principles to
branches.

Comments are requested on this issue.

Finally, consistent with Rev. Rul. 90-112 (1990-2 C.B. 186), the
regulations would provide that, for purposes of section 956, a CFC
partner's investment in U.S. property includes the U.S. property
held by a partnership to the extent of the CFC's ownership interest
in the partnership. Comments are requested on this issue.

III. Hybrid Branches

Temporary regulations, published elsewhere in this issue of the
Federal Register amend the Income Tax Regulations (26 CFR part 1)
relating to sections 952 and 954 by adding rules relating to the
treatment under subpart F of certain branches of a CFC or a
partnership in which a CFC is a partner that are treated as separate
entities for foreign tax purposes. The text of those temporary
regulations also serves as the text of the proposed regulations. The
preamble to the temporary regulations explains the reasons for the
addition.

IV. Proposed Effective Date

These regulations are proposed to apply for taxable years of a
controlled foreign corporation beginning on or after the date the
final regulations are published in the Federal Register. For prior
periods, the IRS will rely on principles and authorities under
subpart F and subchapter K to apply an aggregate approach, including
§1.701-2(e) and (f) of the regulations for periods for which it is
effective.

Special Analyses

It has been determined that this notice of proposed rulemaking is
not a significant regulatory action as defined in Executive Order
12866. Therefore, a regulatory assessment is not required. It has
also been determined that section 553(b) of the Administrative
Procedures Act (5 U.S.C. chapter 5) does not apply to these
regulations, and, because the regulation does not impose a
collection of information on small entities, the Regulatory
Flexibility Act (5 U.S.C. chapter 6) does not apply. Pursuant to
section 7805(f) of the Code, this notice of proposed rulemaking will
be submitted to the Chief Counsel for Advocacy of the Small Business
Administration for comment on its impact on small business.

Comments and Public Hearing

Before these proposed regulations are adopted as final regulations,
consideration will be given to any written comments (preferably a
signed original and eight (8) copies) that are timely submitted to
the IRS. All comments will be available for public inspection and
copying.

A public hearing has been scheduled for July 15, 1998, at 10 a.m.,
in room 2615, Internal Revenue Building, 1111 Constitution Avenue
NW., Washington DC. Because of access restrictions, visitors will
not be admitted beyond the building lobby more than 15 minutes
before the hearing starts.

The rules of 26 CFR 601.601(a)(3) apply to the hearing.

Persons that wish to present oral comments at the hearing must
submit written comments by June 24, 1998, and submit an outline of
topics to be discussed and time to be devoted to each topic (signed
original and eight (8) copies) by June 24, 1998.

A period of 10 minutes will be allotted to each person for making
comments.

An agenda showing the scheduling of the speakers will be prepared
after the deadline for receiving outlines has passed.

Copies of the agenda will be available free of charge at the
hearing.

Drafting Information

The principal author of these regulations is Valerie Mark of the
Office of the Associate Chief Counsel (International), IRS.

However, other personnel from the IRS and Treasury Department
participated in their development.

List of Subjects

26 CFR Part 1 Income taxes, Reporting and recordkeeping
requirements.

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

Proposed Amendments to the Regulations

Accordingly, 26 CFR part 1 is proposed to be amended as follows:

PART 1--INCOME TAXES

Paragraph 1. The authority citation for 26 CFR part 1 continues to
read in part as follows:

Authority: 26 U.S.C. 7805 * * * Par. 2 Section §1.702-1 is amended
as follows:

1. Paragraph (a)(8)(ii) is revised.

2. A new paragraph (c)(1)(v) is added.

The addition and revision read as follows:

§1.702-1 Income and credits of partner.

(a) * * *

(8) * * *

(ii) Each partner must also take into account separately the
partner's distributive share of any partnership item which, if
separately taken into account by any partner, would result in an
income tax liability for that partner, or for any other person,
different from that which would result if that partner did not take
the item into account separately. Thus, if any partner is a
controlled foreign corporation, as defined in section 957, items of
income that would be gross subpart F income if taken into account by
the controlled foreign corporation must be separately stated for all
partners. Under section 911(a), if any partner is a bona fide
resident of a foreign country who may exclude from gross income the
part of the partner's distributive share which qualifies as earned
income as defined in section 911(b), the earned income of the
partnership for all partners must be separately stated. Similarly,
all relevant items of income or deduction of the partnership must be
separately stated for all partners in determining the applicability
of section 183 (relating to activities not engaged in for profit)
and the recomputation of tax thereunder for any partner.

* * * * *

(c) * * *

(1) * * *

(v) In determining whether the de minimis or full inclusion rules of
section 954(b)(3) apply.

* * * * *

Par. 3. In §1.952-1, paragraphs (b) through (f) are redesignated as
paragraphs (c) through (g), respectively, and a new paragraph (b) is
added to read as follows:

§1.952-1 Subpart F income defined.

* * * * *

(b) Treatment of distributive share of partnership income--

(1) In general. A controlled foreign corporation's distributive
share of any item of income of a partnership is income that falls
within a category of subpart F income described in section 952(a) to
the extent the item of income would have been income in such
category if received by the controlled foreign corporation directly.
For specific rules regarding the treatment of a distributive share
of partnership income under certain provisions of subpart F, see
§§1.954-1(g); 1.954-2(a)(5); 1.954-3(a)(6); 1.954-4(b)(2)(iii); and
1.954-6(g).

(2) Example. The application of this paragraph (b) may be
illustrated by the following example.

Example. CFC, a controlled foreign corporation, is an 80- percent
partner in PRS, a foreign partnership. PRS earns $100 of interest
income that is not export financing interest, as defined in section
954(c)(2)(B), from a person unrelated to CFC. This interest income
would have been foreign personal holding company income to CFC,
under section 954(c), if it had received this income directly.
Accordingly, CFC's distributive share of this interest income, $80,
is foreign personal holding company income.

* * * * *

Par. 4. Section 1.954-1 is amended as follows:

1. Paragraphs (c)(1)(i)(A) through (D) are redesignated as (c)(1)(i)
(A)(1) through (4), respectively.

2. A new paragraph heading for newly designated paragraph (c)(1)(i)
(A) is added.

3. New paragraphs (c)(1)(i)(B) through (E) are added.

4. Paragraph (g) is added.

The additions read as follows:

§1.954-1 Foreign base company income.

* * * * *

(c) * * *

(1) * * *

(i) Deductions against gross foreign base company income--

(A) In general.* * *

* * * * *

(B) through (E) [The text of the proposed paragraphs (c)(1)(i)(B)
through (E) is the same as the text of §1.954- 1T(c)(1)(i)(B)
through (E) published elsewhere in this issue of the Federal
Register].

* * * * *

(g) Distributive share of partnership income--(1) Application of
related person and country of organization tests.

Unless otherwise provided, to determine the extent to which a
controlled foreign corporation's distributive share of any item of
gross income of a partnership would have been subpart F income if
received by it directly, under §1.952-1(b), if a provision of
subpart F requires a determination of whether an entity is a related
person, within the meaning of section 954(d)(3), or whether an
activity occurred within or outside the country under the laws of
which the controlled foreign corporation is created or organized,
this determination shall be made by reference to such controlled
foreign corporation and not by reference to the partnership.

(2) Example. The application of paragraph (g)(1) of this section is
illustrated by the following example:

Example. (i) CFC1, a controlled foreign corporation organized in
Country A, is an 80-percent partner in Partnership, a partnership
organized in Country B. CFC2, a controlled foreign corporation
organized in Country B, owns the remaining 20 percent interest in
Partnership. CFC1 and CFC2 are owned by a common U.S. parent, USP.
CFC2 manufactures Product A in Country B.

Partnership earns sales income from purchasing Product A from CFC2
and selling it to third parties located in Country B that are not
related persons with respect to CFC1 or CFC2. For purposes of
determining whether CFC1's distributive share of Partnership's sales
income is foreign base company sales income under section 954(d),
CFC1 is treated as if it purchased Product A from CFC2 and sold it
to third parties in Country B. Under section 954(d)(3), CFC2 is a
related person with respect to CFC1.

Thus, with respect to CFC1, the sales income is deemed to be derived
from the purchase of personal property from a related person.
Because the property purchased is both manufactured and sold for use
outside of Country A, CFC1's country of organization, CFC1's
distributive share of the sales income is foreign base company sales
income.

(ii) For purposes of determining whether CFC2's distributive share
of Partnership's sales income is foreign base company sales income,
CFC2 is treated as if it directly sold Product A to third parties
within Country B. Therefore, Product A is both manufactured and sold
for use within CFC2's country of organization. Thus, CFC2's
distributive share of Partnership's sales income is not foreign base
company sales income.

Par. 5. In §1.954-2, paragraph (a)(5) and (a)(6) are added to read
as follows:

§1.954-2 Foreign personal holding company income.

(a) * * *

(5) Special rules applicable to distributive share of partnership
income--(i) [The text of the proposed paragraph (a)(5)(i) is the
same as the text of §1.954-2T(a)(5) published elsewhere in this
issue of the Federal Register].

(ii) Certain other exceptions applicable to foreign personal holding
company income. To determine the extent to which a controlled
foreign corporation's distributive share of an item of income of a
partnership is foreign personal holding company income, the
exceptions contained in sections 954(c)(2) and §1.954-2(b)(2) and
(6), (e)(1)(ii), (f)(1)(ii), (g)(2)(ii), and (h)(3)(ii), shall apply
only if any such exception would have applied to exclude the income
from foreign personal holding company income if the controlled
foreign corporation had earned the income directly, determined by
taking into account only the activities of, and property owned by,
the partnership and not the separate activities or property of the
controlled foreign corporation or any other person.

(iii) [The text of the proposed paragraph (a)(5)(iii) is the same as
the text of §1.954-2T(a)(5)(iii) published elsewhere in this issue
of the Federal Register].

(6) Special rules applicable to exceptions from foreign personal
holding company income treatment in circumstances involving hybrid
branches--(i) [The text of the proposed paragraph (a)(6)(i) is the
same as the text of §1.954-2T(a)(6) published elsewhere in this
issue of the Federal Register].

* * * * *

Par. 6. Section 1.954-3 is amended as follows:

1. The second sentence of paragraph (a)(4)(i) is revised.

2. The first sentence of paragraph (a)(4)(ii) is revised.

3. Paragraph (a)(6) is added.

The revisions and addition read as follows:

§1.954-3 Foreign base company sales income.

(a) * * *

(4) * * *

(i) * * * A controlled foreign corporation (selling corporation)
will be considered, for purposes of this paragraph (a)(4), to have
manufactured, produced, or constructed personal property that it
sells if, as a result of the operations conducted by such selling
corporation in connection with the property that it purchased and
sold, the property sold is in effect not the property that it
purchased. * * *

(ii) * * * If, prior to its sale of property that it has purchased,
a selling corporation substantially transforms the property, the
selling corporation will be treated as having manufactured,
produced, or constructed such property. * * * * * * * *

(6) Special rule applicable to distributive share of partnership
income--(i) In general. To determine the extent to which a
controlled foreign corporation's distributive share of any item of
gross income of a partnership would have been foreign base company
sales income if received by it directly, under §1.952-1(b), the
property sold will be considered to be manufactured, produced or
constructed by the controlled foreign corporation within the meaning
of paragraph (a)(4) of this section only if the manufacturing
exception of paragraph (a)(4) of this section would have applied to
exclude the income from foreign base company sales income if the
controlled foreign corporation had earned the income directly,
determined by taking into account only the activities of, and
property owned by, the partnership and not the separate activities
or property of the controlled foreign corporation or any other
person.

* * * * *

Par. 7. In §1.954-4, paragraph (b)(2)(iii) is added to read as
follows:

§1.954-4 Foreign base company services income.

* * * * *

(b) * * *

(2) * * *

(iii) Special rule applicable to distributive share of partnership
income. A controlled foreign corporation's distributive share of a
partnership's services income will be deemed to be derived from
services performed for or on behalf of a related person, within the
meaning of section 954(e)(1)(A), if the partnership is a related
person with respect to the controlled foreign corporation, under
section 954(d)(3), and, in connection with the services performed by
the partnership, the controlled foreign corporation provided
assistance that would have constituted substantial assistance
contributing to the performance of such services, under paragraph
(b)(2)(ii) of this section, if furnished to the controlled foreign
corporation by a related person.

* * * * *

Par. 8. Section 1.954-9 is added to read as follows:

§1.954-9 Hybrid branches.

[The text of this proposed section is the same as the text of
§1.954-9T published elsewhere in this issue of the Federal
Register.] Par. 9. In §1.956-2, paragraph (a)(3) is added to read as
follows:

§1.956-2 Definition of United States property.

(a) * * *

(3) For purposes of section 956, if a controlled foreign corporation
is a partner in a partnership that owns property that would be
United States property, within the meaning of paragraph (a)(1) of
this section, if owned directly by the controlled foreign
corporation, the controlled foreign corporation will be treated as
holding an interest in the property equal to its ownership interest
in the partnership and such ownership interest will be treated as an
interest in United States property.

* * * * *

PART 301--PROCEDURE AND ADMINISTRATION

Par. 10. The authority citation for 26 CFR part 301 continues to
read in part as follows:

Authority: 26 U.S.C. 7805 * * * Par. 11. Section 301.7701-3 is
amended as follows:

1. Paragraph (a) is amended by adding a sentence at the end of the
paragraph.

2. Paragraph (c)(1)(iv) is amended by adding a sentence at the end
of the paragraph.

The additions read as follows:

§301.7701-3 Classification of certain business entities.

(a) [The text of the proposed paragraph (a) of this section is the
same as the text of §301.7701-3T(a) published elsewhere in this
issue of the Federal Register.]

* * * * *

(c) * * *

(1) * * *.(iv) [The text of the proposed paragraph (c)(1)(iv) of
this section is the same as the text of §301.7701-3T(c)(1)(iv)
published elsewhere in this issue of the Federal Register.]

* * * * *

Michael P. Dolan
Deputy Commissioner of Internal Revenue

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