Partnership mergers. This ruling describes the application of sections 704(c)(1)(B) and 737 of the Code to assets-over partnership mergers. The ruling holds that section 704(c)(1)(B) applies to newly created section 704(c) gain or loss in property contributed by the transferor partnership to the continuing partnership in an assets-over partnership merger, but does not apply to newly created reverse section 704(c) gain or loss resulting from a revaluation of property in the continuing partnership. The ruling also holds that for purposes of section 737(b), net precontribution gain includes newly created section 704(c) gain or loss in property contributed by the transferor partnership to the continuing partnership in an assets-over partnership merger, but does not include newly created reverse section 704(c) gain or loss resulting from a revaluation of property in the continuing partnership.

Proposed regulations under section 856 of the Code clarify that an entity that is disregarded as separate from its owner, a qualified REIT subsidiary, or a qualified subchapter S subsidiary is treated as an entity separate from its owner if the entity is liable for federal taxes. A public hearing is scheduled for July 22, 2004.

Weighted average interest rate update. The weighted average interest rate for April 2004 and the resulting permissible range of interest rates used to calculate current liability and to determine the required contribution are set forth.

Minimum funding standards; interest rates; section 101 of Pension Funding Equity Act. This notice describes the method for determining the permissible range of interest rates for current liability under section 412 of the Code as amended by section 101 of the Pension Funding Equity Act of 2004. In addition, comments are requested on this notice.

Employee Plans determination letter program; individually designed plans. This announcement describes the Service’s decisions resulting from its review of comments following the issuance of two white papers on the future of the Employee Plans determination letter program.

Pre-approved employee plans; proposed revenue procedure; request for comments. This announcement describes and contains a draft proposed revenue procedure pertaining to those employee plans (master and prototype (M&P) and volume submitter (VS)) that are pre-approved by the Service. Portions of the draft procedure are reserved pending comments.

Minimum funding standards; alternative deficit reduction election. This announcement describes how an election to make an alternative deficit reduction contribution under section 412(l) of the Code may be made and describes some of the background to that election.

A list is provided of organizations now classified as private foundations.

Kids Voting SD of Rapid City, SD, no longer qualifies as an organization to which contributions are deductible under section 170 of the Code.

Limited Liability Company. This ruling discusses the issue of whether the IRS can collect employment taxes owed by a multi-member domestic Limited Liability Company (LLC) from the members.

Proposed regulations under section 856 of the Code clarify that an entity that is disregarded as separate from its owner, a qualified REIT subsidiary, or a qualified subchapter S subsidiary is treated as an entity separate from its owner if the entity is liable for federal taxes. A public hearing is scheduled for July 22, 2004.

Credit for sales of fuel produced from a nonconventional source, inflation adjustment factor, and reference price. This notice publishes the nonconventional source fuel credit, the inflation adjustment factor, and the reference price under section 29 of the Code for calendar year 2003. This data is used to determine the credit allowable on sales of fuel produced from a nonconventional source.