REVENUE RULE 95-73

1995-2 C.B. 132, 1995-45 I.R.B. 6

Internal Revenue Service
Revenue Rule

FEDERAL RATES; ADJUSTED FEDERAL RATES; ADJUSTED FEDERAL LONG-TERM RATE, AND THE LONG-TERM EXEMPT RATE

Released: October 17, 1995
Published: November 6, 1995

§1274. - Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property

Federal rates, adjusted federal rates; adjusted federal long-term rate, and the long-term exempt rate. For purposes of sections 1274, 1288, 382, and other sections of the Code, tables set forth the rates for November 1995.

§ 42. - Low-Income Housing Credit
The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of November 1995.

§ 280G. - Golden Parachute Payments
Federal short-term, mid-term, and long-term rates are set forth for the month of November 1995

§ 382. - Limitation on Net Operating Loss Carryforwards and Certain Built- In Losses Following Ownership Change
The adjusted federal long-term rate is set forth for the month of November 1995.

§ 412. - Minimum Funding Standards
The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of November 1995.

§ 467. - Certain Payments for the Use of Property or Services
The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of November 1995.

§ 468. - Special Rules for Mining and Solid Waste Reclamation and Closing Costs
The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of November 1995.

§ 483. - Interest on Certain Deferred Payments
The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of November 1995.

§ 807. - Rules for Certain Reserves
The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of November 1995.

§ 846. - Discounted Unpaid Losses Defined
The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of November 1995.

§ 1288. - Treatment of Original Issue Discount on Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of November 1995.

§ 7520. - Valuation Tables
The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of November 1995.

§ 7872. - Treatment of Loans with Below-Market Interest Rates
The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of November 1995.

Federal rates, adjusted federal rates; adjusted federal long-term rate, and the long-term exempt rate. For purposes of sections 1274, 1288, 382, and other sections of the Code, tables set forth the rates for November 1995.

This revenue ruling provides various prescribed rates for federal income tax purposes for November 1995 (the current month.)

Table 1 contains the short- term, mid-term, and long-term applicable federal rates (AFR) for the current month for purposes of section 1274(d) of the Internal Revenue Code. Table 2 contains the short-term, mid-term, and long-term adjusted applicable federal rates (adjusted AFR) for the current month for purposes of § 1288(b). Table 3 sets forth the adjusted federal long-term rate and the long-term tax- exempt rate described in § 382(f). Table 4 contains the appropriate percentages for determining the low-income housing credit described in § 42(b)(2) for buildings placed in service during the current month. Finally, Table 5 contains the federal rate for determining the present value of an annuity, an interest for life or for a term of years, or a remainder or a reversionary interest for purposes of § 7520.


REV. RUL. 95-73 TABLE 1

Applicable Federal Rates (AFR) for November 1995
Period for Compounding

Short-Term

    Annual Semiannual Quarterly Monthly
  AFR 5.79% 5.71% 5.67% 5.64%
110% AFR 6.38% 6.28% 6.23% 6.20%
120% AFR 6.97% 6.85% 6.79% 6.75%

Mid-Term

    Annual Semiannual Quarterly Monthly
  AFR 6.11% 6.02% 5.98% 5.95%
110% AFR 6.73% 6.62% 6.57% 6.53%
120% AFR 7.35% 7.22% 7.16% 7.11%
150% AFR 9.23% 9.03% 8.93% 8.86%
175% AFR 10.82% 10.54% 10.40% 10.32%

Long-Term

    Annual Semiannual Quarterly Monthly
  AFR 6.55% 6.45% 6.40% 6.36%
110% AFR 7.23% 7.10% 7.04% 7.00%
120% AFR 7.89% 7.4% 7.67% 7.62%

REV. RUL. 95-73 TABLE 2

Adjusted AFR for November 1995
Period for Compounding

Short-term

    Annual Semiannual Quarterly Monthly
Adjusted AFR 3.97% 3.93% 3.91% 3.90%

Mid-term

    Annual Semiannual Quarterly Monthly
Adjusted AFR 4.49% 4.44% 4.42% 4.40%

Long-term

    Annual Semiannual Quarterly Monthly
Adjusted AFR 5.65% 5.57% 5.53% 5.51%

REV. RUL. 95-73 TABLE 3

Rates Under § 382 for November 1995
Adjusted federal long-term rate for the current month 5.65%
Long-term tax-exempt rate for ownership changes during the current month 5.75% (the highest of the adjusted federal long-term rates for the current month and the prior two months.)


REV. RUL. 95-73 TABLE 4

Appropriate Percentages Under § 42(b)(2) for November 1995
Appropriate percentage for the 70% present value low-income housing 8.48% credit
Appropriate percentage for the 30% present value low-income housing 3.64% credit


REV. RUL. 95-73 TABLE 5

Rate Under § 7520 for November 1995
Applicable federal rate for determining the present value of an annuity 7.4% an interest for life or a term of years, or a remainder or reversionary interest


Rev. Rul. 95-73, 1995-2 C.B. 132, 1995-45 I.R.B. 6