[Federal Register Volume 59, Number 246 (Friday, December 23, 1994)]
[Unknown Section]
[Page 0]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 94-31426]


[[Page Unknown]]

[Federal Register: December 23, 1994]


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DEPARTMENT OF THE TREASURY
26 CFR Part 31

[TD 8582]
RIN 1545-AR08

 

Update of Railroad Retirement Tax Act Regulations

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final regulations.

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SUMMARY: This document contains final regulations relating to the 
Railroad Retirement Tax Act (RRTA). These regulations update the 
existing RRTA regulations by removing obsolete provisions and adding 
new provisions to reflect the statutory changes that have occurred 
since the publication in 1964 of the existing RRTA regulations. In 
addition, because Tier 1 of the RRTA mirrors the Federal Insurance 
Contributions Act (FICA), these regulations generally cross-reference 
the definition of compensation under the RRTA to the definition of 
wages under the FICA. The regulations provide both railroad employers 
and IRS personnel with the guidance necessary to comply with the law.

DATES: These regulations are effective December 23, 1994. These 
regulations apply for calendar years beginning after December 31, 1992.

FOR FURTHER INFORMATION CONTACT: Jean Whalen Casey at (202) 622-6040.

SUPPLEMENTARY INFORMATION:

Background

    On May 13, 1993, the IRS published in the Federal Register (58 FR 
28366) proposed amendments to the Employment Tax Regulations (26 CFR 
part 31) under sections 3201 through 3231 of the Internal Revenue Code 
(Code).
    Written comments were received from the public on the proposed 
regulations, and a public hearing was held on August 30, 1993. After 
consideration of all of the written comments received and the 
statements made at the public hearing, the proposed regulations are 
adopted as revised by this Treasury decision.

Explanation of Revisions and Summary of Comments

    The comments received focused on the definition of ``employer'' in 
Sec. 31.3231(a)-1 and the definition of compensation in 
Sec. 31.3231(e)-1.
    Proposed Regulation Sec. 31.3231(a)-1(c) describes the term 
``casual'' as used in the phrase ``casual service and the casual 
operation of equipment or facilities.'' Under the proposed regulations, 
the term ``casual'' applies, in part, whenever such service or 
operation is insubstantial. One commentator suggested the IRS adopt a 
bright line test in defining insubstantial. Specifically, the 
commentator suggested that service or operation of equipment or 
facilities in connection with the transportation of passengers or 
property by railroad be presumed to be insubstantial whenever less than 
10% of any company's revenues, work force, or payroll are derived from, 
devoted to, or provided to the carrier or carriers affiliated with the 
company. Situations can arise where one of the factors is less than 10% 
while the remaining factors are greater than 10%. It is not clear that 
the service or operation of equipment or facilities would be 
insubstantial in those situations. Therefore, this suggestion was not 
adopted.
    The proposed regulations define ``compensation'' under the RRTA by 
referencing the definition of ``wages'' under the FICA. One commentator 
suggested that this reference be deleted because the statutory language 
of the two statutes differs. This suggestion was not adopted. The 
definition of wages under the FICA refers to ``all remuneration for 
employment'' while the definition of compensation under the RRTA refers 
to ``any money remuneration paid to an individual.'' The commentator 
stated that Congress had the opportunity to conform the language of the 
two definitions and has not done so. While there are historical 
differences between the two statutes, there are significant 
similarities between the RRTA and the FICA. Legislation enacted since 
the adoption of the existing regulations has made the RRTA Tier 1 tax 
identical to the FICA tax as well as conforming the Tier 1 wage ceiling 
to the FICA wage ceiling. Along with conforming the structure of the 
RRTA to parallel that of the FICA, the exclusions from the definition 
of compensation under the RRTA, with few exceptions, mirror the 
exclusions from the definition of wages under the FICA. These 
exclusions from compensation include non-monetary benefits such as 
fringe benefits, meals and lodging excludable under section 119 of the 
Internal Revenue Code, and employer-paid life insurance premiums for 
group-term life insurance under $50,000. In amending RRTA, Congress 
often indicated the purpose was to provide conformity to FICA. Congress 
has added references to FICA provisions in the RRTA definition of 
successor employer (section 3231(e)(2)(C)) and the rules for 
nonqualified deferred compensation (section 3231(e)(8)). In addition, 
Tier 1 benefits are designed to be equivalent to social security 
benefits and are subject to federal income taxation in the same manner 
as social security benefits. Because the two statutes are not 
completely identical, the language of the regulation indicates that the 
term compensation has the same meaning as the term wages, except as 
specifically limited by the Railroad Retirement Tax Act.
    One commentator suggested that the presumption in Sec. 31.3231(e)-
1(a)(2) that payments made to an individual through the employer's 
payroll are compensation should be deleted. This is based on the 
removal of this language from the Internal Revenue Code in 1983. The 
commentator also suggested that Sec. 31.3231(e)-1(a)(4) providing that 
compensation includes payments for time lost should be deleted. These 
provisions are included in the existing regulations. The Railroad 
Retirement Solvency Act of 1983 significantly amended the definition of 
compensation, changing the inclusion of items to a ``paid basis'' from 
an ``earned basis'' and providing the present two tiered structure. 
Prior to the 1983 Act, statutory language specifically provided for the 
presumption and the inclusion of payments for time lost. In amending 
the definition of compensation, the 1983 Act did not reenact the 
statutory language. The legislative history does not indicate that 
Congress intended to exclude payments for time lost from compensation 
or negate the presumption that payments made through an employer's 
payroll are compensation. Therefore, these suggestions were not 
adopted.
    A suggestion was also made to delete the reference to ``earned'' in 
proposed Sec. 31.3231(e)-1(a)(3). Because section 3231 was amended to 
shift the focus from when compensation was earned to when compensation 
was paid, this suggestion has been adopted.
    Finally, one commentator suggested adding a reference that 
compensation does not include supplemental unemployment compensation 
benefits (SUB-pay). There is no specific statutory exception from 
compensation for SUB-pay. Rather, a series of revenue rulings provides 
a limited exception from the definition of wages for purposes of FICA 
and FUTA for certain payments made upon an employee's involuntary 
separation from the employer's service, but only if the payments are 
designed to supplement the receipt of unemployment compensation. Rev. 
Rul. 56-249, 1956-1 C.B. 488, the first of many rulings in this area, 
summarized eight features of a SUB-pay plan whose payments qualified 
for exclusion from wage treatment. Rev. Rul. 90-72, 1990-2 C.B. 211, 
specifically provides that because the definition of compensation for 
RRTA purposes is similar to the definition of wages for FICA purposes, 
the same conclusions with respect to SUB-pay plans applies to RRTA. 
Rev. Rul. 90-72 revoked in part an earlier revenue ruling which held 
that SUB-pay does not have to be tied to state unemployment benefits in 
order to be excluded from treatment as wages. Because payments from a 
SUB-pay plan are not automatically excluded from the definition of 
compensation this suggestion was not adopted.

Special Analyses

    It has been determined that this Treasury decision is not a 
significant regulatory action as defined in EO 12866. Therefore, a 
regulatory assessment is not required. It also has been determined that 
section 553(b) of the Administrative Procedure Act (5 U.S.C. chapter 5) 
and the Regulatory Flexibility Act (5 U.S.C. chapter 6) do not apply to 
these regulations, and, therefore, a Regulatory Flexibility Analysis 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 Jean Whalen Casey of 
the Office of the Associate Chief Counsel (Employee Benefits and Exempt 
Organizations), IRS. However, other personnel from the IRS and Treasury 
Department participated in their development.

List of Subjects in 26 CFR Part 31

    Employment taxes, Income taxes, Penalties, Pensions, Railroad 
retirement, Reporting and recordkeeping requirements, Social security, 
Unemployment compensation.

Adoption of Amendments to the Regulations

    Accordingly, 26 CFR part 31 is amended as follows:

PART 31--EMPLOYMENT TAXES AND COLLECTION OF INCOME TAX AT SOURCE

    Paragraph 1. The authority citation for part 31 continues to read 
in part as follows:

    Authority: 26 U.S.C. 7805 * * *

    Par. 2. Section 31.3121(a)-1 is amended as follows:
    1. Paragraph (a) is redesignated as (a)(1).
    2. Paragraph (a)(2) is added to read as follows:


Sec. 31.3121(a)-1  Wages.

    (a) * * *
    (2) The term compensation as used in section 3231(e) of the 
Internal Revenue Code has the same meaning as the term wages as used in 
this section, determined without regard to section 3121(b)(9), except 
as specifically limited by the Railroad Retirement Tax Act (chapter 22 
of the Internal Revenue Code) or regulation. The Commissioner may 
provide any additional guidance that may be necessary or appropriate in 
applying the definitions of sections 3121(a) and 3231(e).
* * * * *
    Par. 3. Sections 31.3201-1 and 31.3201-2 are revised to read as 
follows:


Sec. 31.3201-1  Measure of employee tax.

    The employee tax is measured by the amount of compensation received 
for services rendered as an employee. For provisions relating to 
compensation, see Sec. 31.3231(e)-1. For provisions relating to the 
circumstances under which certain compensation is to be disregarded for 
the purpose of determining the employee tax, see paragraphs (b)(1) and 
(2) of Sec. 31.3231(e)-1.


Sec. 31.3201-2  Rates and computation of employee tax.

    (a) Rates--(1)(i) Tier 1 tax. The Tier 1 employee tax rate equals 
the sum of the tax rates in effect under section 3101(a) relating to 
old-age, survivors, and disability insurance, and section 3101(b), 
relating to hospital insurance. The Tier 1 employee tax rate is applied 
to compensation up to the contribution base described in section 
3231(e)(2)(B)(i). The contribution base is determined under section 230 
of the Social Security Act and is identical to the old-age, survivors, 
and disability insurance wage base and the hospital insurance wage 
base, respectively, under the Federal Insurance Contributions Act.
    (ii) Example. The rule in paragraph (a)(1)(i) of this section is 
illustrated by the following example.

    Example. A received compensation of $60,000 in 1992. The section 
3101(a) rate of 6.2 percent would be applied to A's compensation up 
to $55,500, the applicable contribution base for 1992. The section 
3101(b) rate of 1.45 percent would be applied to the entire $60,000 
of A's compensation because the applicable contribution base for 
1992 is $130,200.

    (2)(i) Tier 2 tax. The Tier 2 employee tax rate equals the 
percentage set forth in section 3201(b) of the Code. This rate is 
applied to compensation up to the contribution base described in 
section 3231(e)(2)(B)(ii).
    (ii) Example. The rule in paragraph (a)(2)(i) of this section is 
illustrated by the following example.

    Example. A received compensation of $60,000 in 1992. The section 
3201(b) rate of 4.90 percent would be applied to A's compensation up 
to $41,400, the applicable contribution base for 1992.

    (b)(1) Computation. The employee tax is computed by multiplying the 
amount of the employee's compensation with respect to which the 
employee tax is imposed by the rate applicable to such compensation, as 
determined under paragraph (a) of this section. The applicable rate is 
the rate in effect when the compensation is received by the employee. 
For rules relating to the time of receipt, see Sec. 31.3121(a)-2 (a) 
and (b).
    (2) Example. The rule in paragraph (b)(1) of this section is 
illustrated by the following example.

    Example. In 1990, employee A received compensation of $1,000 as 
remuneration for services performed for employer R in 1989. The 
employee tax is payable at the rate of 12.55 percent (7.65 percent 
plus 4.90 percent) in effect for 1990 (the year the compensation was 
received), and not the 12.41 percent rate (7.51 percent plus 4.90 
percent) in effect for 1989 (the year the services were performed).

    Par. 4. Section 31.3202-1 is amended by revising paragraphs (b) and 
(f) to read as follows:


Sec. 31.3202-1  Collection of, and liability for, employee tax.

* * * * *
    (b) Collection; payments by two or more employers in excess of 
annual compensation limitation. For rules relating to payments by two 
or more employers in excess of the annual compensation limitation see 
Sec. 31.3121(a)(1)-1.
* * * * *
    (f) Concurrent employment. If two or more related corporations who 
are rail employers concurrently employ the same individual and 
compensate that individual through a common paymaster, which is one of 
the related corporations employing the individual, see Sec. 31.3121(s)-
1.
    Par. 5. Sections 31.3211-1 and 31.3211-2 are revised to read as 
follows:


Sec. 31.3211-1  Measure of employee representative tax.

    The employee representative tax is measured by the amount of 
compensation received for services rendered as an employee 
representative. For provisions relating to compensation, see 
Sec. 31.3231(e)-1.


Sec. 31.3211-2  Rates and computation of employee representative tax.

    (a) Rates--(1)(i) Tier 1 tax. The Tier 1 employee representative 
tax rate equals the sum of the tax rates in effect under sections 
3101(a) and 3111(a), relating to the employee and the employer tax for 
old-age, survivors, and disability insurance, and sections 3101(b) and 
3111(b), relating to the employee and the employer tax for hospital 
insurance. The Tier 1 employee representative tax rate is applied to 
compensation up to the contribution base described in section 
3231(e)(2)(B)(i). The contribution base is determined under section 230 
of the Social Security Act, and is identical to the old-age, survivors, 
and disability insurance wage base and the hospital insurance wage 
base, respectively, under the Federal Insurance Contributions Act.
    (ii) Example. The rule in paragraph (a)(1)(i) of this section is 
illustrated by the following example.

    Example. B, an employee representative received compensation of 
$60,000 in 1992. The sections 3101(a) and 3111(a) rates of 12.4 
percent (6.2 percent plus 6.2 percent) would be applied to B's 
compensation up to $55,500, the applicable contribution base for 
1992. The sections 3101(b) and 3111(b) rates of 2.9 percent (1.45 
percent plus 1.45 percent) would be applied to the entire $60,000 of 
B's compensation because the applicable contribution base for 1992 
is $130,200.

    (2) (i) Tier 2 tax. The Tier 2 employee representative tax rate 
equals the percentage set forth in section 3211(a)(2) of the Code. This 
rate is applied up to the contribution base described in section 
3231(e)(2)(B)(ii).
    (ii) Example. The rule in paragraph (a)(2)(i) of this section is 
illustrated by the following example.

    Example. B received compensation of $60,000 in 1992. The section 
3211(a)(2) rate of 14.75 percent would be applied to B's 
compensation up to $41,400, the applicable contribution base for 
1992.

    (3) Supplemental Annuity Tax. The supplemental annuity tax for each 
work-hour for which compensation is paid to an employee representative 
for services rendered as an employee representative is imposed at the 
same rate as the excise tax imposed on every employer under section 
3221(c). See also Sec. 31.3211-3.
    (b) (1) Computation. The employee representative tax is computed by 
multiplying the amount of the employee representative's compensation 
with respect to which the employee representative tax is imposed by the 
rate applicable to such compensation, as determined under paragraph (a) 
of this section. The applicable rate is the rate in effect when the 
compensation is received by the employee representative. For rules 
relating to the time of receipt, see Sec. 31.3121(a)-2 (a) and (b).
    (2) Example. The rule in paragraph (b)(1) of this section is 
illustrated by the following example.

    Example. In 1990, employee representative B received $1,000 as 
remuneration for services performed for employer R in 1989. The 
employee representative tax is payable at the rate of 30.05 percent 
(15.30 percent plus 14.75 percent) in effect for 1990 (the year the 
compensation was received), and not the 29.77 percent rate (15.02 
percent plus 14.75 percent) in effect for 1989 (the year the 
services were performed).

    (c) (1) Rule where compensation is received both as an employee 
representative and employee. The following rule applies to an 
individual who renders service both as an employee representative and 
as an employee. The employee representative tax is imposed on 
compensation received as an employee representative under the rules 
described in Sec. 31.3211-2. The employee tax is imposed on 
compensation received as an employee under the rules described in 
Sec. 31.3201-2. However, if the total compensation received is greater 
than the applicable contribution base, the employee representative tax 
is imposed on the amount equal to the contribution base less the amount 
received for services rendered as an employee.
    (2) Example. The rule in paragraph (c)(1) of this section is 
illustrated by the following example.

    Example. C performed services both as an employee and an 
employee representative in 1992. C received compensation of $40,000 
as an employee and $20,000 as an employee representative. C's entire 
compensation of $40,000 is subject to tax under the rules described 
in Sec. 31.3201-2. The amount of employee representative 
compensation subject to the section 3101(a) and the section 3111(a) 
rate is $15,500 ($55,500-$40,000). The entire $20,000 is subject to 
the sections 3101(b) and 3111(b) rates since the combined 
compensation is less than $130,200, the applicable contribution base 
for 1992. The amount of the employee representative compensation 
subject to the section 3211(a)(2) rate is $1,400 ($41,400-$40,000).

    Par. 6. Section 31.3221-1 is amended as follows:
    1. Paragraphs (a) and (b) are revised.
    2. Paragraph (d) is removed.
    3. The revisions read as follows:


Sec. 31.3221-1  Measure of employer tax.

    (a) General Rule--The employer tax is measured by the amount of 
compensation paid by an employer to its employees. For provisions 
relating to compensation, see Sec. 31.3231(e)-1. For provisions 
relating to the circumstances under which certain compensation is to be 
disregarded for purposes of determining the employer tax, see 
paragraphs (b) (1) and (2) of Sec. 31.3231(e)-1.
    (b) Payments by two or more employers in excess of annual 
compensation limitation. For rules relating to payments by two or more 
employers in excess of the annual compensation limitation, see 
Sec. 31.3121(a)(1)-1.
* * * * *
    Par. 7. Section 31.3221-2 is revised to read as follows:


Sec. 31.3221-2  Rates and computation of employer tax.

    (a) Rates--(1)(i) Tier 1 tax. The Tier 1 employer tax rate equals 
the sum of the tax rates in effect under section 3111(a), relating to 
old-age, survivors, and disability insurance, and section 3111(b) 
relating to hospital insurance. The Tier 1 employer tax rate is applied 
to compensation up to the contribution base described in section 
3231(e)(2)(B)(i). The contribution base is determined under section 230 
of the Social Security Act and is identical to the old-age, survivors, 
and disability insurance wage base and the hospital insurance wage 
base, respectively, under the Federal Insurance Contributions Act.
    (ii) Example. The rule in paragraph (a)(1)(i) of this section is 
illustrated by the following example.

    Example. R's employee, A, received compensation of $60,000 in 
1992. The section 3111(a) rate of 6.2 percent would be applied to 
A's compensation up to $55,500, the applicable contribution base for 
1992. The section 3111(b) rate of 1.45 percent would be applied to 
the entire $60,000 of A's compensation because the applicable 
contribution base for 1992 is $130,200.

    (2)(i) Tier 2 tax. The Tier 2 employer tax rate equals the 
percentage set forth in section 3221(b) of the Internal Revenue Code. 
This rate is applied up to the contribution base described in section 
3231(e)(2)(B)(ii).
    (ii) Example. The rule in paragraph (a)(2)(i) of this section is 
illustrated by the following example.

    Example. R's employee, A, received compensation of $60,000 in 
1992. The section 3221(b) rate of 16.10 percent would be applied to 
A's compensation up to $41,400, the applicable contribution base for 
1992.

    (3) Supplemental Annuity Tax. The supplemental annuity tax for each 
work-hour for which compensation is paid by an employer for services 
rendered during any calendar quarter by employees is imposed at the tax 
rate determined each calendar quarter by the Railroad Retirement Board. 
See also Sec. 31.3221-3.
    (b)(1) Computation. The employer tax is computed by multiplying the 
amount of the compensation with respect to which the employer tax is 
imposed by the rate applicable to such compensation, as determined 
under paragraph (a) of this section. The applicable rate is the rate in 
effect at the time the compensation is paid. For rules relating to the 
time of payment, see Sec. 31.3121(a)-2(a) and (b).
    (2) Example. The rule in paragraph (b)(1) of this section is 
illustrated by the following example.

    Example. In 1990, R's employee A received $1,000 as remuneration 
for services performed for R in 1989. The employer tax is payable at 
the rate of 23.75 percent (7.65 percent plus 16.10 percent) in 
effect for 1990 (the year the compensation was received) and not the 
23.61 percent rate (7.51 percent plus 16.10 percent) in effect for 
1989 (the year the services were performed).

    Par. 8. Section 31.3231(a)-1 is amended as follows:
    1. Paragraph (a)(1) is revised.
    2. Paragraphs (c) and (d) are redesignated as (d) and (e).
    3. Paragraphs (c) and (f) are added.
    4. The revisions and additions read as follows:


Sec. 31.3231(a)-1  Who are employers.

    (a) * * *
    (1) Any carrier, that is, any express carrier, sleeping car 
carrier, or rail carrier providing transportation subject to subchapter 
I of chapter 105 of title 49;
* * * * *
    (c) As used in paragraph (a)(2) of this section, the term casual 
applies when the service rendered or the operation of equipment or 
facilities by a controlled company or person in connection with the 
transportation of passengers or property by railroad is so irregular or 
infrequent as to afford no substantial basis for an inference that such 
service or operation will be repeated, or whenever such service or 
operation is insubstantial.
* * * * *
    (f) Any company that is described in paragraph (a)(2) of this 
section is an employer under section 3231. In certain cases, based on 
all the facts and circumstances, it may be appropriate to segregate 
those businesses engaged in rail services and therefore subject to the 
Railroad Retirement Tax Act from those businesses engaged exclusively 
in nonrail services and therefore not subject to the Railroad 
Retirement Tax Act. The factors considered are set forth in guidance 
published by the Internal Revenue Service.
    Par. 9. Section 31.3231(e)-1 is revised to read as follows:


Sec. 31.3231(e)-1  Compensation.

    (a) Definition--(1) The term compensation has the same meaning as 
the term wages in section 3121(a), determined without regard to section 
3121(b)(9), except as specifically limited by the Railroad Retirement 
Tax Act (chapter 22 of the Internal Revenue Code) or regulation. The 
Commissioner may provide any additional guidance that may be necessary 
or appropriate in applying the definitions of sections 3121(a) and 
3231(e).
    (2) A payment made by an employer to an individual through the 
employer's payroll is presumed, in the absence of evidence to the 
contrary, to be compensation for services rendered as an employee of 
the employer. Likewise, a payment made by an employee organization to 
an employee representative through the organization's payroll is 
presumed, in the absence of evidence to the contrary, to be 
compensation for services rendered by the employee representative as 
such. For rules regarding the treatment of deductions by an employer 
from remuneration of an employee, see Sec. 31.3123-1.
    (3) The term compensation is not confined to amounts paid for 
active service, but includes amounts paid for an identifiable period 
during which the employee is absent from the active service of the 
employer and, in the case of an employee representative, amounts paid 
for an identifiable period during which the employee representative is 
absent from the active service of the employee organization.
    (4) Compensation includes amounts paid to an employee for loss of 
earnings during an identifiable period as the result of the 
displacement of the employee to a less remunerative position or 
occupation as well as pay for time lost.
    (5) For rules regarding the treatment of reimbursement and other 
expense allowance amounts, see Sec. 31.3121(a)-3. For rules regarding 
the inclusion of fringe benefits in compensation, see Sec. 31.3121(a)-
1T.
    (b) Special Rules. (1) If the amount of compensation earned in any 
calendar month by an individual as an employee in the service of a 
local lodge or division of a railway-labor-organization employer is 
less than $25, the amount is disregarded for purposes of determining 
the employee tax under section 3201 and the employer tax under section 
3221.
    (2) Compensation for service as a delegate to a national or 
international convention of a railway-labor-organization employer is 
disregarded for purposes of determining the employee tax under section 
3201 and the employer tax under section 3221 if the individual 
rendering the service has not previously rendered service, other than 
as a delegate, which may be included in the individual's years of 
service for purposes of the Railroad Retirement Act.
    (3) For special provisions relating to the compensation of certain 
general chairs or assistant general chairs of a general committee of a 
railway-labor-organization employer, see paragraph (c)(3) of 
Sec. 31.3231(b)-1.
    Par. 10. Section 31.3231(e)-2 is added to read as follows:


Sec. 31.3231(e)-2  Contribution base.

    The term compensation does not include any remuneration paid during 
any calendar year by an employer to an employee for services rendered 
in excess of the applicable contribution base. For rules applying this 
provision, see Sec. 31.3121(a)(1)-1.


Secs. 31.3231(e)-2T and 31.3231(e)-3  [Removed]

    Par. 11. Sections 31.3231(e)-2T and 31.3231(e)-3 are [Removed].
Margaret Milner Richardson,
Commissioner of Internal Revenue.

    Approved: November 28, 1994
Leslie Samuels,
Assistant Secretary of the Treasury.
[FR Doc. 94-31426 Filed 12-22-94; 8:45 am]
BILLING CODE 4830-01-U