Introduction The Internal Revenue Bulletin is the authoritative other cases. In applying published rulings and proce- instrument of the Commissioner of Internal Revenue for dures, the effect of subsequent legislation, regulations, announcing official rulings and procedures of the court decisions, rulings, and procedures must be Internal Revenue Service and for publishing Treasury considered, and Service personnel and others con- Decisions, Executive Orders, Tax Conventions, legisla- cerned are cautioned against reaching the same tion, court decisions, and other items of general conclusions in other cases unless the facts and circumstances are substantially the same. interest. It is published weekly and may be obtained from the Superintendent of Documents on a subscrip- Cumulative Bulletin 1995�2 is a consolidation of all tion basis. Bulletin contents of a permanent nature are items of permanent nature published in the weekly consolidated semiannually into Cumulative Bulletins, Bulletins 1995�26 through 1995�52 for the period of which are sold on a single-copy basis. July 1 through December 31, 1995. It is the policy of the Service to publish in the Bulletin The Internal Revenue Cumulative Bulletin is divided all substantive rulings necessary to promote a uniform into four parts as follows: application of the tax laws, including all rulings that Part I.�1986 Code. supersede, revoke, modify, or amend any of those This part includes rulings and decisions based on previously published in the Bulletin. All published provisions of the Internal Revenue Code of 1986. rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal Part II.�Treaties and Tax Legislation. management are not published; however, statements of This part is divided into two subparts as follows: internal practices and procedures that affect the rights Subpart A, Tax Conventions, and Subpart B, Legislation and duties of taxpayers are published. and Related Committee Reports. Revenue rulings represent the conclusions of the Part III.�Administrative, Procedural, and Miscellaneous. Service on the application of the law to the pivotal facts To the extent practicable, pertinent cross references to stated in the revenue ruling. In those based on these subjects are contained in the other Parts and positions taken in rulings to taxpayers or technical Subparts. Also included in this part are Bank Secrecy advice to Service field offices, identifying details and Act Administrative Rulings. Bank Secrecy Act Admin- information of a confidential nature are deleted to istrative Rulings are issued by the Department of the prevent unwarranted invasions of privacy and to comply Treasury�s Office of the Assistant Secretary (Enforcement). with statutory requirements. Notice of Proposed Rulemaking. Rulings and procedures reported in the Bulletin do not The preambles and text of proposed regulations that have the force and effect of Treasury Department were published in the Federal Register during this six Regulations, but they may be used as precedents. month period are printed in this section. Included in Unpublished rulings will not be relied on, used, or cited this section is a list of person disbarred or suspended as precedents by Service personnel in the disposition of from practice before the Internal Revenue Service. 1995�2 C.B. iii