Final_CO-26-96

Federal Register / Vol. 64, No. 127 / Friday, July 2, 1999 / Rules and Regulations
due date of the income tax return
(without extensions) is after June 25,
1999.
(ii) Expiration of 5-year period.
Section 1.1502–95(d)(2)(iii) applies with
respect to the day after the last day of
any 5 consecutive year period described
in that section that ends in a taxable
year for which the due date of the
income tax return (without extensions)
is after June 25, 1999.
(4) Reattribution of net operating loss
carryovers under § 1.1502–20(g). Section
1.1502–96(d) applies to reattributions of
net operating loss carryovers (or capital
loss carryovers) in taxable years for
which the due date of the income tax
return (without extensions) is after June
25, 1999; except that the election under
§ 1.1502–96(d)(5) (relating to an election
to reattribute section 382 limitation) can
be made with any election under
§ 1.1502–20(g)(4) to reattribute to the
common parent a net operating loss or
net capital loss that is timely filed on or
after June 25, 1999.
(5) Election to apportion net
unrealized built-in gain. In the case of
corporations that cease to be members of
a loss group (or loss subgroup) before
June 25, 1999 in a taxable year for
which the due date of the income tax
return (without extensions) is after June
25, 1999, § 1.1502–95(a), (b), (c), and (f)
apply to those corporations if the
common parent makes the election
described in the second sentence of
paragraph (c)(1) of § 1.1502–95 in the
time and manner prescribed in
paragraph (f) of § 1.1502–95.
(c) Testing period may include a
period beginning before June 25, 1999—
(1) In general. A testing period for
purposes of §§ 1.1502–91 through
1.1502–96 and 1.1502–98 may include a
period beginning before June 25, 1999.
Thus, for example, in applying
§ 1.1502–92(b)(1)(i)(relating to the
determination of an ownership change
of a loss group), the determination of the
lowest percentage of ownership interest
of any 5-percent shareholder of the
common parent during a testing period
ending on a testing date occurring on or
after June 25, 1999 takes into account
the period beginning before June 25,
1999, except to the extent that the
period is more than 3 years before the
testing date or is otherwise before the
beginning of the testing period. See
§ 1.1502–92(b)(1).
(2) Transition rule for net unrealized
built-in loss. A loss group (or loss
subgroup) that has a net unrealized
built-in loss on a testing date on or after
June 25, 1999 may apply § 1.1502–
91A(g) (and § 1.1502–96A(a) as it relates
to § 1.1502–91A(g)) for the period
ending on the day before June 25, 1999

to determine under § 1.382–2T(d)(ii)(A)
the earliest date that its testing period
begins (treating the day before June 25,
1999 as the end of a taxable year.) Thus,
for example, if a consolidated group
with no net operating losses has a net
unrealized built-in loss determined
under § 1.1502–91(g) on a testing date
after June 25, 1999, but, under § 1.1502–
91A(g), does not have a net unrealized
built-in loss for the period ending on the
day before June 25, 1999, the group’s
testing period begins no earlier than
June 25, 1999.
PART 602—OMB CONTROL NUMBERS
UNDER THE PAPERWORK
REDUCTION ACT

36175

DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Parts 1 and 602
[TD 8825]
RIN 1545–AU33

Regulations Under Section 382 of the
Internal Revenue Code of 1986;
Application of Section 382 in Short
Taxable Years and With Respect to
Controlled Groups
Internal Revenue Service (IRS),
Treasury.
ACTION: Final and temporary
regulations.
AGENCY:

This document contains final
regulations relating to limitations on net
operating loss carryovers and certain
Authority: 26 U.S.C. 7805.
built-in losses following an ownership
change of a corporation. The regulations
Par. 15. In § 602.101, paragraph (b) is
implement the statutory authority under
amended by removing the entry for
section 382(m) of the Internal Revenue
§ 1.1502–95T, revising the entry for
Code to prescribe regulations
§ 1.1502–20, and adding entries in
concerning short taxable years and
numerical order to the table to read as
controlled groups of corporations.
follows:
Additional rules are adopted relating
principally to corporations that cease to
§ 602.101 OMB Control numbers.
exist following a merger (or similar
*
*
*
*
*
transaction) or that have two or more
ownership changes. These final
(b) * * *
regulations replace temporary
regulations that provided guidance on
Current
CFR part or section where
OMB
control
these topics.
identified and described
No.
DATES: Effective Dates: These
regulations are effective June 25, 1999.
Applicability Dates: For dates of
*
*
*
*
*
1.1502–20 .................................
1545–1160 application and special transition rules,
1545–1218 see Effective Dates under
SUPPLEMENTARY INFORMATION.
FOR FURTHER INFORMATION CONTACT: Lee
*
*
*
*
*
1.1502–95 .................................
1545–1218 A. Kelley at 202–622–7550 (not a toll1.1502–96 .................................
1545–1218 free number).
1.1502–95A ..............................
1545–1218 SUPPLEMENTARY INFORMATION:
Par. 14. The authority citation for part
602 continues to read as follows:

*

*

*

*

*

John M. Dalrymple,
Acting Deputy Commissioner of Internal
Revenue.
Approved: June 18, 1999.
Donald C. Lubick,
Assistant Secretary of the Treasury.
[FR Doc. 99–16162 Filed 6–25–99; 1:27 pm]
BILLING CODE 4830–01–U

SUMMARY:

Paperwork Reduction Act
The collection of information
contained in these final regulations has
been reviewed and approved by the
Office of Management and Budget in
accordance with the Paperwork
Reduction Act (44 U.S.C. 3507) under
control number 1545–1434. Responses
to this collection of information are
required to obtain a benefit relating to
the value of a controlled group member.
An agency may not conduct or
sponsor, and a person is not required to
respond to, a collection of information
unless the collection of information
displays a valid control number.
The estimated annual burden per
respondent is one quarter hour.
Comments concerning the accuracy of
this burden estimate and suggestions for

36176

Federal Register / Vol. 64, No. 127 / Friday, July 2, 1999 / Rules and Regulations

reducing this burden should be sent to
the Internal Revenue Service, Attn: IRS
Reports Clearance Officer, OP:FS:FP,
Washington, DC 20224, and to the
Office of Management and Budget, Attn:
Desk Officer for the Department of the
Treasury, Office of Information and
Regulatory Affairs, Washington, DC,
20503.
Books and records relating to this
collection of information must be
retained as long as their contents may
become material in the administration
of any internal revenue law. Generally,
tax returns and tax return information
are confidential, as required by 26
U.S.C. 6103.
Background and Explanation of
Provisions
On February 4, 1991, the IRS and
Treasury issued a notice of proposed
rulemaking, CO–077–90 (56 FR 4183)
(the 1991 controlled group proposed
regulations), setting forth rules
regarding the application of section 382
to controlled groups of corporations and
to corporations that undergo a merger or
similar transaction. The 1991 controlled
group proposed regulations also related
to the determination of the section 382
limitation following an ownership
change in the case of short taxable year,
and to the valuation of the stock of a
loss corporation for purposes of
determining the amount of the section
382 limitation. On the same day, the IRS
and Treasury also issued proposed
regulations relating to the application of
section 382 to affiliated groups of
corporations filing consolidated returns
(CO–132–87, 56 FR 4194), and to the
use of built-in deductions and net
operating losses and capital losses,
including the carryover and carryback of
separate return year (SRLY) losses, of
members of consolidated groups (CO–
078–90, 56 FR 4228). A public hearing
regarding the three sets of proposed
regulations was held on April 8, 1991.
On June 27, 1996, the IRS and
Treasury published temporary
regulations (TD 8679, 61 FR 33313) (the
1996 controlled group temporary
regulations) relating to section 382.
Except for the addition of a provision
relating to the effects of successive
ownership changes, these regulations
were substantially identical to the 1991
controlled group proposed regulations.
A notice of proposed rulemaking crossreferencing the temporary regulations
was published in the Federal Register
on the same day (CO–026–96, 61 FR
33391) (the 1996 controlled group
proposed regulations) and the 1991
controlled group proposed regulations
were withdrawn. No written comments
were received on the 1996 controlled

group proposed regulations and no
public hearing was held. Also on June
27, 1996, the IRS and Treasury
published temporary regulations
relating to the application of section 382
to affiliated groups of corporations filing
consolidated returns (TD 8678, 61 FR
33335) and the SRLY limitation (TD
8677, 61 FR 33321). Notices of proposed
rulemaking cross-referencing these
temporary regulations were published
on the same day (CO–025–96, 61 FR
33395 and CO–024–96, 61 FR 33393),
and the corresponding proposed
regulations published in 1991 were
withdrawn.
The 1996 controlled group proposed
regulations are adopted as revised by
this Treasury decision and the
corresponding temporary regulations are
removed. The final regulations are
substantially the same as the 1996
controlled group proposed regulations,
with one significant change relating to
built-in losses of a member of a
controlled group of corporations. This
change is discussed below.
Under section 382, if an ownership
change occurs with respect to a loss
corporation (as defined in section 382
and the regulations thereunder), the
amount of the loss corporation’s taxable
income for a post-change year that may
be offset by the net operating loss
carryovers arising before the ownership
change are subject to a limitation known
as the section 382 limitation. The
section 382 limitation for a post-change
taxable year of the loss corporation
generally equals the fair market value of
the stock of the corporation immediately
before the ownership change multiplied
by the long-term tax exempt rate (a rate
of return published periodically in the
Internal Revenue Bulletin).
In addition to net operating loss
carryovers, the recognized built-in
losses of corporations that have a net
unrealized built-in loss on the
ownership change date are also subject
to the section 382 limitation. In general,
a corporation has a net unrealized builtin loss on its ownership change date if
the adjusted basis of its assets exceeds
their fair market value, and such excess
is greater than the threshold amount
under section 382(h)(3)(B). In general,
recognized built-in losses are losses
with respect to assets held on the
change date that are recognized within
the 5-year period beginning on the
ownership change date. The recognized
built-in loss on an asset, however, is
limited to the lesser of the loss
recognized on its disposition or the
amount by which the adjusted basis of
the asset exceeded its fair market value
on the change date.

Consistent with the proposed
regulations, the final regulations require
appropriate adjustments to the value of
a loss corporation that is a member of
a controlled group of corporations so
that the same value is not included
more than once in computing the
section 382 limitations for the loss
corporations that are members of the
controlled group. In general,
adjustments are required only when
corporations are members of the same
controlled group both when a prechange loss arises and on the date of the
ownership change. Thus, adjustments
are required if a loss corporation is a
component member of the same
controlled group as another member (i)
on December 31 of the taxable year in
which a pre-change loss arises (or the
change date, if earlier) and (ii) on the
date that the loss corporation has an
ownership change. If a loss corporation
has pre-change losses that arise in
different taxable years, the component
members of the controlled group with
respect to losses arising in each taxable
year may differ. Therefore, as in the
1996 controlled group proposed
regulations, the final regulations are
applied by determining a controlled
group with respect to each year’s prechange loss of the corporation (a
controlled group loss).
To avoid duplication of value in
connection with a controlled group loss,
the value of the stock of each
corporation that is a component member
of the controlled group with respect to
a controlled group loss is reduced by the
value of the stock of other component
members that it directly owns
immediately before the ownership
change. A second adjustment (more
fully explained in the preamble to the
1991 controlled group proposed
regulations) permits a lower tier
member to elect to restore some or all
of the previously reduced value to a
member that directly owns its stock.
In identifying controlled group losses,
the determination of the taxable year to
which a net operating loss carryover is
attributable usually presents no
difficulty. The determination of the
taxable year in which a net unrealized
built-in loss accrues, however, is more
problematic. To address some concerns
in this area, the final regulations include
an irrebutable presumption that certain
built-in losses are attributable to the
period before a particular taxable year.
The presumption applies to a loss
corporation that had an ownership
change prior to the first day of the
taxable year in question, and whose net
unrealized built-in losses became
subject to a section 382 limitation as a
result of that ownership change. Under

Federal Register / Vol. 64, No. 127 / Friday, July 2, 1999 / Rules and Regulations
the presumption, any built-in loss in
such an asset is considered to be
attributable to a period prior to the
taxable year in question to the extent of
the built-in loss in that asset on the
previous change date.
Effective Dates
Section 1.382–5 (relating to the
section 382 limitation) generally applies
to a loss corporation that has an
ownership change to which section
382(a), as amended by the Tax Reform
Act of 1986, applies. The rules in that
section relating to successive ownership
changes, however, apply to taxable
years of a loss corporation beginning on
or after January 1, 1997. Section 1.382–
8 (relating to controlled groups of
corporations) generally applies to a loss
corporation that has an ownership
change with respect to a controlled
group loss on or after January 1, 1997.
Transition rules are provided for
members of controlled groups that have
ownership changes before that date. The
rules in § 1.382–1(a)(iv) (relating to
separate tracking of certain loss
corporations) apply to testing dates on
or after January 29, 1991. The rules in
§ 1.382–2 (a) (4) and (a) (5) relating to
successor or predecessor corporations in
other than corporate reorganizations
apply to testing dates on or after January
1, 1997.
Special Analysis
It has been determined that this
Treasury decision is not a significant
regulatory action as defined in EO
12866. It has also been determined that
section 553 of the Administrative
Procedure Act (5 U.S.C. chapter 5) does
not apply to these regulations. It is
hereby certified that these regulations
do not have a significant economic
impact on a substantial number of small
entities. This certification is based on
the fact that the collection of
information in this regulation is a
statement of election that it is estimated
will take less than one hour to prepare.
The statement will be filed by electing
corporations that are members of a
controlled group of corporations
(determined by applying a 50%
common control requirement) both (1)
when a net operating loss carryover (or
certain other tax attributes ) arises and
(2) a member of the controlled group has
an ownership change under section 382
of the Internal Revenue Code with
respect to that net operating loss
carryover (or other attribute). (An
affiliated group of corporations that files
a consolidated return is treated as a
single corporation for this purpose,
which reduces the number of potential
filers.) Because the election is only filed

with respect to an ownership change, it
is unlikely that a corporation will file
the election frequently. Therefore, a
Regulatory Flexibility Analysis under
the Regulatory Flexibility Act (5 U.S.C.
chapter 6) is not required. Pursuant to
section 7805(f) of the Internal Revenue
Code, the notice of proposed rulemaking
preceding these regulations was
submitted to the Small Business
Administration for comment on its
impact on small business.
Drafting information. The principal
author of these regulations is Lee A.
Kelley of the Office of Assistant Chief
Counsel (Corporate). Other personnel
from the IRS and Treasury participated
in their development.

The revision and additions read as
follows:
§ 1.382–1

*

*

*

*

*

*

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

*

PART 1—INCOME TAXES
Paragraph 1. The authority citation
for part 1 is amended by removing
entries for sections 1.382–5T and 1.382–
8T and by adding entries in numerical
order to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Section 1.382–5 also issued under 26
U.S.C. 382(m). * * *
Section 1.382–8 also issued under 26
U.S.C. 382(m). * * *

Par. 2. Section 382–1 is amended by:
1. Revising the entry for § 1.382–2,
paragraph (a)(1)(iv).
2. Adding an entry for § 1.382–2,
paragraph (a)(1)(v).
3. Adding entries for § 1.382–2,
paragraphs (a)(5) and (a)(6).
4. Removing the entries for § 1.382–
2T, paragraphs (f)(1)(i), (f)(1)(ii), and
(f)(1)(iii).
5. The entry for § 1.382–4 is amended
as follows:
a. The entry for paragraph (b) is
revised.
b. Entries for paragraphs (b)(1) and
(b)(2) are added.
6. Removing the entry for § 1.382–5.
7. Redesignating the entry for § 1.382–
5T as § 1.382–5 and revising the section
heading.
8. Removing the entry for § 1.382–8.
9. Redesignating the entry for § 1.382–
8T as § 1.382–8, revising the section
heading, and adding entries for
paragraphs (b) (1) and (b) (2).

*

*

*

*

*

*

(5) Successor corporation.
(6) Predecessor corporation.
§ 1.382–4

Adoption of Amendments to the
Regulations
Accordingly, 26 CFR parts 1 and 602
are amended as follows:

Table of contents.

§ 1.382–2 General rules for ownership
change.
(a) * * *
(1) * * *
(iv) End of separate accounting for losses
and credits of distributor or transferor
corporation.
(v) Application to other successor
corporations.

List of Subjects

26 CFR Part 602
Reporting and recordkeeping
requirements.

36177

*

*

*

*

Constructive ownership of stock.

*

*

*

(b) Attribution from corporations,
partnerships, estates and trusts.
(1) [Reserved].
(2) Limitation.

*

*

§ 1.382–5

*

*

§ 1.382–8

*

*

*

*

*

Section 382 limitation.

*

*

*

Controlled groups.

*

*

*

(b) * * *
(1) In general.
(2) Presumption regarding net unrealized
built-in loss.

*

*

§ 1.1382–2

*

*

*

[Amended]

Par. 2a. Section 1.382–2 is amended
by removing paragraph (a)(1)(iv).
Par. 3. Section 1.382–2T is amended
as follows:
1. In paragraph (e)(2)(iv) Example
(2)(ii), remove the reference ‘‘paragraph
(f)(1)(ii)’’ and add ‘‘§ 1.382–2(a)(1)(iv)’’
in its place.
2. Paragraph (f)(1)(ii) is redesignated
as paragraph (a)(1)(iv) of § 1.382–2.
3. Paragraph (f)(1) is revised.
4. Paragraphs (f)(4) and (f)(5) are
redesignated as paragraphs (a)(5) and
(a)(6) of § 1.382–2, respectively.
5. New paragraphs (f)(4) and (f)(5) are
added.
6. In paragraph (h)(2)(i)(A), remove
the language ‘‘and solely for purposes of
determining whether a loss corporation
has an ownership change’’.
The revision and additions read as
follows:
§ 1.382–2T Definition of ownership change
under section 382, as amended by the Tax
Reform Act of 1986 (temporary).

*

*
*
*
*
(f) Definitions. * * *
(1) Loss corporation. See section 382
and § 1.382–2(a)(1) for the definition of
a loss corporation.
*
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Federal Register / Vol. 64, No. 127 / Friday, July 2, 1999 / Rules and Regulations

(4) Successor corporation. See
§ 1.382–2(a)(5) for the definition of
successor corporation.
(5) Predecessor corporation. See
§ 1.382–2(a)(6) for the definitions of
predecessor corporation.
*
*
*
*
*
Par. 4. Section 1.382–2 is amended as
follows:
1. In the first sentence of paragraph
(a)(1)(iii), remove the reference
‘‘§ 1.382–2T(f)(1)(ii)’’ and add
‘‘paragraph (a)(1)(iv) of this section’’ in
its place.
2. In the first sentence of newly
designated paragraph (a)(1)(iv), remove
the reference ‘‘§ 1.382–2(a)(1)(iii)’’ and
add ‘‘ paragraph (a)(1)(iii) of this
section’’ in its place.
3. In the first sentence of newly
designated paragraph (a)(1)(iv), remove
the reference ‘‘§ 1.382–2(a)(1)(ii)’’ and
add ‘‘paragraph (a)(1)(ii) of this section’’
in its place.
4. In the last sentence of newly
designated paragraph (a)(1)(iv), remove
the reference ‘‘paragraph (f)(1)(ii)’’ and
add ‘‘paragraph (a)(1)(iv)’’ in its place.
5. Paragraph (a)(1)(v) is added.
6. In the first sentence of paragraph
(a)(3)(i), remove the reference
‘‘paragraph (f)(18)’’ and add ‘‘paragraph
(a)(3)(i) and § 1.382–2T(f)(18)(ii) and
(iii)’’ in its place.
7. In the last sentence of newly
designated paragraph (a)(5), remove the
reference ‘‘paragraph (f)(4)’’ and add
‘‘paragraph (a)(5)’’ in its place.
8. In the last sentence of newly
designated paragraph (a)(6), remove the
reference ‘‘paragraph (f)(5)’’ and add
‘‘paragraph (a)(6)’’ in its place.
The addition reads as follows:
§ 1.382–2
change.

General rules for ownership

(a) * * *
(1) * * *
(v) Application to other successor
corporations. This paragraph (a)(1) also
applies, as the context may require, to
successor corporations other than
successors in section 381(a)
transactions. For example, if a
corporation receives assets from the loss
corporation that have basis in excess of
value, the recipient corporation’s basis
for the assets is determined, directly or
indirectly, in whole or in part, by
reference to the loss corporation’s basis,
and the amount by which basis exceeds
value is material, the recipient
corporation is a successor corporation
subject to this paragraph (a)(1). This
paragraph (a)(1)(v) applies to any testing

date occurring on or after January 1,
1997.
*
*
*
*
*
Par. 5. Section 1.382–4 is amended by
revising paragraph (b) to read as follows:
§ 1.382–4
stock.

Constructive ownership of

*

*
*
*
*
(b) Attribution from corporations,
partnerships, estates and trusts. (1)
[Reserved].
(2) Limitation. Section 1.382–
2T(h)(2)(i)(A) applies solely for
purposes of determining whether a loss
corporation has an ownership change.
*
*
*
*
*
§ 1.382–5

[Removed]

Par. 6. Section 1.382–5 is removed.
Par. 7. Section 1.382–5T is
redesignated as § 1.382–5 and amended
as follows:
1. The section heading is revised.
2. In paragraph (e), the reference
‘‘§ 1.382–8T’’ is removed and ‘‘§ 1.382–
8’’ is added in its place.
The revision reads as follows:
§ 1.382–5

*

*

§ 1.382–8

Section 382 limitation.

*

*

*

[Removed]

Par. 8. Section 1.382–8 is removed.
Par. 9. Section 1.382–8T is
redesignated as § 1.382–8 and amended
as follows:
1. The section heading is revised.
2. Redesignate paragraphs (b)
introductory text, (b)(1) and (b)(2) as
paragraphs (b)(1) introductory text,
(b)(1)(i) and (b)(1)(ii), respectively.
3. A paragraph heading for newly
designated paragraph (b)(1) is added.
4. Paragraph (b)(2) is added.
5. The first three sentences of
paragraph (f) are revised.
6. The graphics of paragraph (g)
Example 1(a) are revised.
7. The graphics of paragraph (g)
Example 2(a) are revised.
8. Paragraph (g) Example 4 is
amended as follows:
a. In the last sentence of paragraph (a),
remove the reference ‘‘§ 1.1502–
92T(b)(1)(i)’’ and add ‘‘§ 1.1502–
92(b)(1(i)’’ in its place.
b. In paragraph (b)(2), remove the
reference ‘‘§ 1.1502–91T(c)’’ and add
‘‘§ 1.1502–91(c)’’ in its place.
c. In paragraph (c), remove the
reference ‘‘§ 1.1502–93T’’ and add
‘‘§ 1.1502–93’’ in its place.
9. In the fifth sentence of paragraph
(h)(1), remove the reference ‘‘§ 1.382–
8T’’ and add ‘‘§ 1.382–8’’ in its place.

10. Paragraph (i) is added.
The additions and revisions read as
follows:
§ 1.382–8

*

*

Controlled groups.

*

*

*

(b) Controlled group loss and
controlled group with respect to a
controlled group loss—(1) In general.
* * *
(2) Presumption regarding net
unrealized built-in loss. For purposes of
determining whether a net unrealized
built-in loss of a loss corporation is
attributable to a taxable year (the
determination year) with respect to
which the corporation is a component
member of a controlled group, the builtin loss in a prior change date asset is
deemed to be attributable to a period
ending before the determination year. A
prior change date asset is any asset held
by the loss corporation at all times
during the period beginning on the
change date of its most recent
ownership change after 1986 (the first
change date), and ending on the first
day of the determination year. The builtin loss in a prior change date asset is the
amount by which the adjusted basis of
the asset on the first change date
exceeds the fair market value of the
asset on that date. The principles of this
paragraph (b)(2) also apply to items
described in section 382(h)(6)(B).
*
*
*
*
*
(f) Coordination between consolidated
groups and controlled groups. Some or
all of the component members of a
controlled group may also be members
of a consolidated group, and a
controlled group loss may be subject to
a consolidated section 382 limitation or
subgroup section 382 limitation
determined under § 1.1502–93. Except
as otherwise provided in this paragraph
(f) and §§ 1.1502–91 through 1.1502–99,
§ 1.1502–93 applies instead of this
section when both sections, by their
terms, are otherwise applicable. This
section is applicable and may require an
adjustment to value if a member of a
consolidated group, a loss group, or loss
subgroup (as those terms are defined in
§§ 1.1502–1(h) and 1.1502–91) is also a
component member of a controlled
group with respect to a controlled group
loss. * * *
(g) * * *
Example 1. * * * (a) * * *
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Example 2. * * * (a) * * *

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(i) References to former temporary
regulations. As the context requires, a
reference in this section to § 1.382–8
includes a reference to § 1.382–8T in
effect prior to June 25, 1999, as
contained in 26 CFR part 1 revised as of
April 1, 1999, a reference to §§ 1.1502–
91, 1.1502–92, 1.1502–93, and
§§ 1.1502–91 through 1.1502–99
includes a reference to §§ 1.1502–91A,
1.1502–92A, 1.1502–93A and
§§ 1.1502–91A through 1.1502–99A.
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PART 602—OMB CONTROL NUMBERS
UNDER THE PAPERWORK
REDUCTION ACT

CFR part or section where
identified and described

Par. 10. The authority citation for part
602 continues to read as follows:

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1.382–8 .................................

Authority: 26 U.S.C. 7805.

Par. 11. In § 602.101, paragraph (b) is
amended in the table by removing the
entry for 1.382–8T and adding an entry
in numerical order to read as follows:
§ 602.101

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OMB Control numbers.

*
*
(b) * * *

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*

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Current OMB
control No.
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*

*
1545–1434
*

John M. Dalrymple,
Acting Deputy Commissioner of Internal
Revenue.
Approved: June 18, 1999.
Donald C. Lubick,
Assistant Secretary of the Treasury.
[FR Doc. 99–16163 Filed 6–25–99; 1:27 pm]
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