Rp 2003-84

RP2003-84.pdf

Revenue Procedure 2003-84, Optional Election to Make Monthly Sec. 706 Allocations

RP 2003-84

OMB: 1545-1768

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Part III. Administrative, Procedural, and Miscellaneous
Social Security Contribution and
Benefit Base for 2004

Domestic Employee Coverage
Threshold

Notice 2003–66

General

Under authority contained in the Social Security Act (“the Act”), the Commissioner, Social Security Administration, has
determined and announced (68 F.R. 60437,
dated October 22, 2003) that the contribution and benefit base for remuneration
paid in 2004, and self-employment income
earned in taxable years beginning in 2004
is $87,900.

The minimum amount a domestic
worker must earn so that such earnings are
covered under Social Security or Medicare
is the domestic employee coverage threshold. For 2004, this threshold is $1,400.
Section 3121(x) of the Internal Revenue
Code provides the formula for increasing
the threshold.

“Old-Law” Contribution and Benefit
Base
General
The “old-law” contribution and benefit base for 2004 is $65,100. This is the
base that would have been effective under
the Act without the enactment of the 1977
amendments. We compute the base under
section 230(b) of the Act as it read prior to
the 1977 amendments.
The “old-law” contribution and benefit
base is used by:
(a) The Railroad Retirement program
to determine certain tax liabilities and tier
II benefits payable under that program to
supplement the tier I payments which correspond to basic Social Security benefits,
(b) The Pension Benefit Guaranty
Corporation to determine the maximum
amount of pension guaranteed under the
Employee Retirement Income Security
Act (as stated in section 230(d) of the
Social Security Act),
(c) Social Security to determine a year
of coverage in computing the special minimum benefit, as described earlier, and
(d) Social Security to determine a year
of coverage (acquired whenever earnings
equal or exceed 25 percent of the “old-law”
base for this purpose only) in computing
benefits for persons who are also eligible
to receive pensions based on employment
not covered under section 210 of the Act.

Computation
Under the formula, the domestic employee coverage threshold amount for
2004 shall be equal to the 1995 amount
of $1,000 multiplied by the ratio of the
national average wage index for 2002 to
that for 1993. If the resulting amount is
not a multiple of $100, it shall be rounded
to the next lower multiple of $100.
Domestic Employee Coverage Threshold
Amount
Multiplying the 1995 domestic employee coverage threshold amount
($1,000) by the ratio of the national
average wage index for 2002 ($33,252.09)
to that for 1993 ($23,132.67) produces
the amount of $1,437.45. We then round
this amount to $1,400. Accordingly, the
domestic employee coverage threshold
amount is $1,400 for 2004.
(Filed by the Office of the Federal Register on October 21,
2003, 8:45 a.m., and published in the issue of the Federal
Register for October 22, 2003, 68 F.R. 60437)

26 CFR 601.105: Examination of returns and claims
for refund, credit or abatement; determination of
correct tax liability.
(Also: §§ 171, 702, 704, 706, 708, 851, 852,
1275, 6229, 6231, 6233, 6698, 6722; 1.706–1,
1.6001–1(a), 1.6031(a)–1T.)

Rev. Proc. 2003–84
SECTION 1. PURPOSE
This revenue procedure allows certain
partnerships that invest in tax-exempt obligations to make an election that enables
the partners to take into account monthly
the inclusions required under §§ 702 and

2003-48 I.R.B.

1159

707(c) of the Internal Revenue Code and
provides rules for partnership income tax
reporting under § 6031 for such partnerships.
SECTION 2. BACKGROUND
A partnership may be used to create the
economic equivalent of a variable-rate taxexempt bond. To create this instrument, a
sponsor purchases a tax-exempt obligation
and transfers the tax-exempt obligation to
an entity that qualifies as a partnership
for federal tax purposes (tax-exempt-bond
partnership). The tax-exempt-bond partnership issues two classes of equity interests: interests that are entitled to a preferred variable return on its capital (variable-rate interests) and interests that are
entitled to all of the remaining income of
the partnership (inverse interest). The variable return on the variable-rate interests
tracks current short-term exempt yields.
Under § 702(b), tax-exempt interest income received by a partnership retains its
character when the partnership allocates
the income to a partner.
Under § 706(a), a partner generally includes in income for a taxable year the
partner’s allocable share of items of partnership income, gain, loss, deduction, and
credit for the partnership’s taxable year
ending within or with the partner’s taxable
year. A partner must also include in income for a taxable year guaranteed payments under § 707(c) that are taken into account by the partnership under its method
of accounting in the partnership’s taxable
year ending within or with the partner’s
taxable year. Moreover, for each taxable
year in which a partnership has income, deductions, or credits, § 6031(a) and (b) requires the partnership to file a Form 1065,
U.S. Return of Partnership Income, and to
issue Schedules K–1 (Form 1065) to each
partner.
Annual inclusion of income under
§ 706(a) can be incompatible with the
needs of money market funds and of
medium- and long-term bond funds that
invest in obligations that produce interest
that is exempt from tax. For example, if a
regulated investment company’s (RIC’s)
taxable year does not correspond to the
taxable year of a tax-exempt-bond partnership in which it holds an interest, the RIC

December 1, 2003

may not be allocated sufficient tax-exempt
interest income from the partnership to
pay exempt-interest dividends quarterly.
See § 852.
To resolve this problem, many tax-exempt-bond partnerships attempted to make
an election under § 761(a) to be excluded
from the provisions of subchapter K. A
tax-exempt-bond partnership is not eligible to elect to be wholly or partially excluded from subchapter K, however, and
an attempted election has no effect. Two
of the requirements for eligibility to make
an election under § 761(a) are that the partners must own the partnership property as
co-owners and the partners must be able
to compute their income without the necessity of computing partnership taxable
income. See § 1.761–2(a)(1) and (2) of
the Income Tax Regulations. If a business
entity (classified as a partnership) owns
a tax-exempt bond and issues membership interests that apportion the benefits
and burdens of that bond to its members
in a manner that differs significantly from
direct investment in the bond, the holders of those membership interests do not
satisfy the requirement that they own the
partnership property as co-owners. Cf.
§ 301.7701–4(c) of the Procedure and Administration Regulations. Moreover, if one
class of partners has a right to partnership
income that is superior to the right of another class of partners, then the net partnership income or loss allocated to the partners with inferior rights to partnership income can be determined only by computing the net income or loss of the partnership and then by reducing that net income
by income allocable to partners with superior rights to partnership income. Such a
partnership does not meet the requirement
of § 1.761–2(a)(1) that the members of the
organization be able to compute their incomes without the necessity of computing
partnership income.
To assist tax-exempt-bond partnerships to meet the needs of the market for
tax-exempt obligations within the requirements of the Internal Revenue Code, the
Internal Revenue Service (Service) has
issued two revenue procedures. Rev. Proc.
2002–16, 2002–1 C.B. 572, was issued
to allow money market fund partners in
tax-exempt-bond partnerships to take into
account on a monthly basis their distributive shares of partnership items (monthly

December 1, 2003

closing) if the partnership made an effective election under that revenue procedure
(monthly closing election).
Rev. Proc. 2002–68, 2002–2 C.B.
753, modified and superseded Rev. Proc.
2002–16 to extend the monthly closing
election to all partners in tax-exempt-bond
partnerships and established a transition
rule. The transition rule provides that for
any taxable year beginning before January
1, 2004, the Service will not challenge a
partnership’s or a partner’s tax treatment
that is consistent with an election to be excluded from the provisions of subchapter K
under § 761(a), provided that the partnership would be an eligible partnership as defined in Rev. Proc. 2002–68 and the partners’ inclusion of income, gain, loss, deduction and credits is consistent with that
permitted under the revenue procedure.
In Rev. Proc. 2002–68, the Service
also requested comments on simplified income tax reporting procedures for some or
all of the eligible tax-exempt-bond partnerships. This revenue procedure is issued in
response to comments received.
SECTION 3. SUMMARY OF MAJOR
CHANGES
This revenue procedure modifies and
supersedes Rev. Proc. 2002–68 by making the following changes:
.01 Section 4 of this revenue procedure
expands the definition of tax-exempt-bond
partnerships that are eligible to make a
monthly closing election and provides that
all partners must consent to the election.
.02 Section 5.01 of this revenue procedure provides that a monthly closing election is made by including a binding provision to that effect in the partnership’s governing documents.
.03 Section 8 of this revenue procedure provides that a partnership that has a
monthly closing election in effect for the
partnership’s entire taxable year and that
meets the other requirements of section 8
of this revenue procedure is not required to
file a Form 1065 or to issue Schedules K–1
(Form 1065) to its partners for the taxable
year.
.04 Section 9.02(3) of this revenue procedure provides grandfathering rules.

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SECTION 4. SCOPE
This revenue procedure applies to eligible partnerships (described in section
4.01 of this revenue procedure) that make a
monthly closing election (described in section 5 of this revenue procedure).
.01 Eligible Partnership. An entity is an
eligible partnership for a calendar month if
all of the following conditions are met:
(1) As of the election test date and as of
every operational test date that occurs on or
before the end of such calendar month, the
partnership satisfies both the income test
and the expense test. The test dates are
described in section 4.05 of this revenue
procedure, and the income test and the expense test are described in section 4.02 and
section 4.03, respectively.
(2) The entity is a partnership for federal tax purposes;
(3) All allocations of income, gain, loss,
deduction, and credit of the partnership are
made in accordance with § 704(b); and
(4) A written partnership agreement
(or other governing document) provides
that —
(a) the entity is making the monthly
closing election under this revenue procedure; and,
(b) all partners consent to the election.
.02 Income test. At least 95 percent of
the partnership’s gross income (computed
without regard to items described in section 4.04 of this revenue procedure) is or is
reasonably expected to be from:
(1) interest on tax-exempt obligations as defined in § 1275(a)(3) and
§ 1.1275–1(e);
(2) exempt-interest dividends as defined in § 852(b)(5) that are paid by a RIC
as defined in § 851(a); and
(3) gain from the sale, redemption, or
other disposition of assets generating the
income described in section 4.02(1) and
(2) of this revenue procedure and income
from the temporary investment (for a period no greater than 7 months) of the proceeds of the disposition, but only if the assets that are sold, redeemed, or disposed
are original assets of the partnership. For
this purpose, an asset is an original asset
of the partnership if the asset is contributed
to the partnership or is acquired with capital contributed to the partnership (and not
with the proceeds of the sale, redemption,
or other disposition of a partnership asset).

2003-48 I.R.B.

.03 Expense test. Substantially all of
the partnership’s expenses and deductions (computed without regard to items
described in section 4.04 of this revenue
procedure) are properly allocable to:
(1) producing, collecting, managing,
protecting, and conserving the income
described in section 4.02(1), (2), or (3)
of this revenue procedure or the assets
generating the income;
(2) acquiring, managing, conserving,
maintaining, or disposing of property held
for the production of the income described
in section 4.02(1), (2), or (3) of this revenue procedure; and
(3) servicing the equity in the partnership.
.04 Exclusion. For the purposes of sections 4.02 and 4.03 of this revenue procedure, reasonable amounts charged to persons requesting information from the partnership under section 8.03 of this revenue
procedure and the costs of collecting, managing, computing, and supplying the information are not taken into account.
.05 Test Dates and Test Periods. The income test described in section 4.02 of this
revenue procedure and the expense test described in section 4.03 of this revenue procedure must be satisfied both as of the first
day of the first month for which the partnership’s monthly closing election is effective (the election test date) and, beginning
with the fourth month after the partnership’s monthly closing election becomes
effective, on the last day of each month (the
operational test date). The partnership determines whether the income test and the
expense test are satisfied as of the election test date by reference to the election
test period. The partnership determines
whether the income test and expense test
are satisfied as of each operational test date
by reference to the operational test period.
In applying the income and expense tests
for a test period, a termination of the partnership under § 708(b)(1)(B) during that
period is ignored.
(1) The Election Test Period. The election test period differs depending upon
how long the partnership has been in existence (determined from its start-up date).
A partnership’s start-up date is the later
of the date the entity had more than one
owner and the date the entity had more
than a de minimis amount of assets.
(a) If, on the election test date, the partnership has been in existence for at least 6

2003-48 I.R.B.

full calendar months, then the test period
is the longer of the 6 full calendar months
preceding the election test date and the
portion of the partnership’s taxable year
that precedes the election test date; and
(b) If, on the election test date, the partnership has not been in existence for at
least 6 full calendar months, then the election test period is the first 6 full calendar
months of the partnership’s existence.
(2) The Operational Test Period. The
operational test period is the 3-calendarmonth period consisting of the calendar
month within which the operational test
date falls and the preceding 2 calendar
months.
SECTION 5. MAKING THE MONTHLY
CLOSING ELECTION
.01 Manner of Making the Election. An
eligible partnership makes a monthly closing election by providing in the entity’s
governing documents that—
(a) the partnership is making a monthly
closing election that is effective as provided under section 5.02 of this revenue
procedure, and
(b) all partners consent to the election.
.02 Effective Date of the Election. The
monthly closing election is effective on the
later of:
(a) the start-up date of the partnership
(as defined in section 4.05(1) of this revenue procedure), or
(b) the first day of the month in which
the provision described in section 5.01 of
this revenue procedure is first included in
the entity’s governing documents.
.03 Terminations under § 708(b)(1)(B).
A termination of the partnership under
§ 708(b)(1)(B) does not terminate the
monthly closing election and does not
cause the partnership to close its books
under § 1.706–1(c) other than as described
in section 6 of this revenue procedure.
SECTION 6. MONTHLY CLOSING OF
THE BOOKS
If, at the end of any calendar month,
an eligible partnership has a monthly closing election in effect, then, with respect
to each partner, the partnership must close
its books as described in § 1.706–1(c)(2)
as if each partner had sold its entire interest in the partnership on the last day
of that month. Each partner must include

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in its taxable income for that month both
the partner’s distributive share of items described in § 702(a) with respect to the partner that were earned by the partnership
since either the last closing of the books
or the first day of the partnership’s taxable
year (whichever is later) and any guaranteed payments under § 707(c) to the partner that are taken into account by the partnership since the last closing of the books.
If a partner is on a 52–53 week taxable
year, then the provisions of § 1.441–2(e)
apply as if the last day of the month were
the last day of the partnership’s taxable
year.
SECTION 7. TERMINATION OF
MONTHLY CLOSING ELECTION AND
RE-ELECTION AFTER TERMINATION
.01 A partnership’s monthly closing
election terminates as of the first day of
the month during which a partnership
first fails to be an eligible partnership as
defined in section 4.01 of this revenue
procedure.
.02 If the partnership’s monthly closing
election terminates, the partnership may
not make another monthly closing election
without the consent of the Commissioner.
.03 A partnership’s monthly closing
election may be revoked only with the
consent of the Commissioner.
SECTION 8. REPORTING
REQUIREMENTS
.01 Initial Filing Requirement. A partnership must file an abbreviated Form
1065, U.S. Return of Partnership Income,
for the first taxable year during which the
monthly closing election was in effect.
The abbreviated Form 1065 must be filed
by the date that the partnership’s income
tax return for that taxable year would
ordinarily be due and must be signed by a
person with the authority to sign the partnership’s Form 1065. The words “Filed
in Accordance with Rev. Proc. 2003–84”
must be typed or printed across the top of
the form. The partnership is required to
provide only the following information on
the abbreviated Form 1065:
(1) A statement that the partnership has
made an election under this revenue procedure to which all present and future partners consent;

December 1, 2003

(2) Identification of the partnership by
name, address, and EIN;
(3) The name, title, address, and phone
number of the contact person from whom
partners, beneficial owners, middlemen,
and the Internal Revenue Service may request information about the partnership;
(4) The issue date of the partnership interests and the CUSIP (Committee on Uniform Securities Identification Procedures)
number or other identification of each class
of partnership interest;
(5) A statement that the entity’s governing documents expressly provide that the
entity is making a monthly closing election; and
(6) The effective month of the election
and the start-up date of the partnership.
See section 4.05(1) of this revenue procedure for a definition of the start-up date.
.02 Annual Filing Requirements.
(1) Elimination of Annual Filing Requirements. A partnership is not required
to file a Form 1065, U.S. Return of Partnership Income, or to issue Schedules K–1
(Form 1065) to its partners for any taxable
year if the following requirements are satisfied:
(a) The partnership’s monthly closing
election is effective for the partnership’s
entire taxable year;
(b) The partnership makes the initial filing described in section 8.01 of this revenue procedure;
(c) A written partnership agreement
(or other governing document) provides
that —
(i) the entity and its partners will comply with the reporting requirements of sections 8.02 and 8.03, and 8.04 of this revenue procedure in lieu of complying with
the requirements of § 6031(a) through (d),
and,
(ii) all partners consent to such reporting; and
(d) The partnership complies with the
requirements of sections 8.03 and 8.04 of
this revenue procedure.
(2) Effect of Elimination of Annual Filing Requirement. An entity that is not required to file a partnership return under this
revenue procedure is not required to file a
partnership return under § 6031(a) and, as
a result, is not a partnership as defined under § 6231(a)(1). Consequently, the entity
and its members will not be subject to the
provisions of subchapter C of chapter 63.
An abbreviated Form 1065 used to make

December 1, 2003

the initial filing described in section 8.01
of this revenue procedure is not considered
to be a partnership return for purposes of
§ 6233.
(3) Monthly Closing Election Effective
for Portion of Taxable Year. A partnership
that makes a monthly closing election that
is effective after the first day of its taxable
year must comply with the partnership reporting rules of § 6031(a) for that taxable
year (but is still permitted to close its books
on a monthly basis). If the partnership also
makes the initial filing described in section 8.01 of this revenue procedure by the
due date for its return for the first full taxable year during which the monthly closing election is in effect, then the partnership qualifies for elimination of annual filing requirements under section 8.01 of this
revenue procedure for subsequent taxable
years.
(4) Annual Reporting Required. Failure to qualify for the elimination of annual
filing requirements under section 8.02(1)
of this revenue procedure does not terminate the partnership’s monthly closing
election. However, a partnership that fails
to satisfy all of the requirements of section 8.02(1) of this revenue procedure is required to file a complete (not abbreviated)
Form 1065 and to issue Schedules K–1
(Form 1065) to its partners as required by
§ 6031(a). A partnership that fails to file a
Form 1065 or to issue Schedules K–1 as required is subject to the applicable penalties
under §§ 6698 and 6722 for failure to file
a partnership return and to furnish payee
statements, as well as any other applicable
penalties. Moreover, if a partnership is required to file a return under § 6031(a) but
fails to do so, the period of limitations on
assessment of tax attributable to items of
that partnership remains open indefinitely
under § 6229(a).
.03 Requests for Information. Within
45 days of a request by the Service or a
partner (or a beneficial owner or a nominee of a beneficial owner), the partnership
must make available all the information
necessary to compute a partner’s taxable
income, tax-exempt income, gain, loss, deduction, or credit, including sufficient information for a partner to determine the
portion of the tax-exempt interest that may
be subject to the alternative minimum tax
and information regarding each partner’s
share of any bond premium amortization

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under § 171, any market or original issue
discount, and capital gain or loss.
.04 Nominee and Beneficial Ownership
Reporting.
(1) If an eligible electing partnership
complies with the requirements of sections
8.02 and 8.03 of this revenue procedure,
the nominee reporting requirements of
§ 6031(c) and the regulations thereunder
do not apply. In place of those requirements, the partnership and the partners
must comply with this section 8.04. See
§ 1.6001–1(a) and (e) for rules that apply
to recordkeeping requirements.
(2) Any person on whose behalf another
person holds as a nominee an interest in an
eligible partnership (a beneficial owner),
other than a beneficial owner for which the
relevant advisor or manager agrees to comply with section 8.04(3) of this revenue
procedure, shall notify the partnership of
its beneficial ownership status and provide
the partnership with:
(a) its name, address, and taxpayer
identification number and the name, address, and taxpayer identification number
of its nominee; and
(b) the name of the partnership, its
CUSIP number or other information sufficient to identify the partnership interest,
and the amount of the partnership interest.
(3) In the case of a group of RICs that
is managed or advised by a common, or affiliated, manager or advisor (the manager),
the manager may elect to be responsible
for collecting, retaining, and providing the
Service upon demand the beneficial ownership information. To make such an election, the manager must provide each eligible partnership in which any of the RICs
has an equity interest a statement indicating that it is responsible for collecting, retaining, and providing the Service upon
demand the beneficial ownership information that otherwise would be required to
be provided directly to the eligible partnerships by the beneficial owners. In addition,
the manager must provide the partnership
with:
(a) its name, address, and taxpayer
identification number and contact information for the person from whom the
Service can request beneficial ownership
information; and
(b) the name of the partnership, its
CUSIP number or other information sufficient to identify the partnership interests,

2003-48 I.R.B.

and the amount of the partnership interests.
SECTION 9 EFFECTIVE DATE AND
TRANSITION RULES
.01 In General. This revenue procedure
is effective on November 5, 2003.
.02 Grandfathering Rules.
(1) If, prior to January 1, 2004, under
the provisions of Rev. Proc. 2002–16 or
Rev. Proc. 2002–68, a partnership made
an effective Monthly Closing election and
a partner consented to the election, then the
partnership and the partner may continue
to comply with either Rev. Proc. 2002–16
or Rev. Proc. 2002–68, as applicable, except that monthly statements are not required.
(2) Except as provided in section
9.02(4) of this revenue procedure, if,
prior to January 1, 2004, under the provisions of Rev. Proc. 2002–16 or Rev.
Proc. 2002–68, a partnership made an
effective Monthly Closing election and a
partner consented to the election and if
the partnership and partner consistently
report the transaction in a manner that is
consistent with an election to be excluded
from the provisions of subchapter K under
§ 761(a), then the Service will not challenge that treatment. If section 9.02(4) of
this revenue procedure causes this paragraph (2) to cease to apply, the partner and
partnership remain eligible for any relief
described in paragraph (1) above that they
are otherwise entitled to enjoy.
(3) Except as provided in section
9.02(4) of this revenue procedure, if
a partnership’s start-up date is before
January 1, 2004, the Service will not
challenge the partnership’s or its partners’
tax treatment that is consistent with an
election to be excluded from the provisions of subchapter K under § 761(a) for
any taxable year during all of which the
entity is an eligible partnership as defined
in section 4.01 of this revenue procedure
(without regard to section 4.01(4) of this
revenue procedure). See section 4.05(1) of

2003-48 I.R.B.

this revenue procedure for the definition
of a partnership’s start-up date.
(4) If, on or after January 1, 2005, a
partnership acquires new assets, then, as of
the first day of the month in which the new
assets are acquired, the partnership is no
longer eligible for the grandfathering rule
provided in section 9.02(2) or (3) of this
revenue procedure. For purposes of the
preceding sentence, none of the following
is treated as the acquisition of a new asset
by the partnership:
(a) The receipt of payment (including
temporary investment of that payment) on,
or in respect of, a sale, redemption, or other
disposition of an asset of the partnership;
(b) The receipt of a contribution in cash
(including temporary investment of that
cash) to fund expenses of the partnership
described in section 4.03 of this revenue
procedure or to fund distributions to partners in respect of accrued but unpaid taxexempt interest (including accrued but unpaid tax-exempt original issue discount);
or
(c) The acquisition of an asset pursuant
to a plan to keep the principal balance of
the assets in the partnership stable by reinvesting principal payments.
(5) For purposes of section 9.02(4) of
this revenue procedure)—
(a) An investment is temporary if it is
held for 7 months or less; and
(b) If an asset was acquired with reasonable certainty it would be a temporary investment but, due to unforeseeable circumstances, it is held for more than 7 months,
then, for purposes of section 9.02(4) of this
revenue procedure, it is treated as acquired
on the first day that it has been held for
more than 7 months.
SECTION 10 EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2002–68 is modified and
superseded.

1163

SECTION 11 PAPERWORK
REDUCTION ACT
The collection of information contained in this revenue procedure 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
1545–1768. 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 OMB control number.
The collection of information is in section 8 of this revenue procedure. The collection of information is required to obtain a benefit, and is required to inform the
Service which partnerships are making the
monthly closing election. The likely respondents are businesses.
The estimated total annual reporting
and recordkeeping burden is 500 hours.
The estimated annual burden per respondent/recordkeeper is 1/2 hour. The estimated number of respondents and recordkeepers is 1,000.
The estimated annual frequency of responses (used for reporting requirements
only) is once.
Books or records relating to a 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.
DRAFTING INFORMATION
The principal author of this revenue procedure is David A. Shulman
of the Office of Associate Chief Counsel
(Passthroughs and Special Industries). For
further information regarding this revenue
procedure, contact Mr. Shulman at (202)
622–3070 (not a toll-free call).

December 1, 2003


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