Section references are to the Internal Revenue Code unless otherwise noted.

All references to Rev. Proc. 97-27 refer to Rev. Proc. 97-27, 1997-21 I.R.B. 10 (as modified and amplified by Rev. Proc. 2002-19, 2002-13 I.R.B. 696, as amplified and clarified by Rev. Proc. 2002-54, 2002-35 I.R.B. 432), or its successor.

All references to Rev. Proc. 2002-9 refer to Rev. Proc. 2002-9, 2002-3 I.R.B. 327, (as modified and clarified by Announcement 2002-17, 2002-8 I.R.B. 561, modified and amplified by Rev. Proc. 2002-19, 2002-13 I.R.B. 696, and amplified, clarified and modified by Rev. Proc. 2002-54, 2002-35 I.R.B. 432), or its successor.

All references to Rev. Proc. 2004-1 refer to Rev. Proc. 2004-1, 2004-1 I.R.B. 1, as modified by Announcement 2004-8, 2004-6 I.R.B. 441, or its successor.