Revenue Ruling 2005-1
Rev. Rul. 2005-1
Rev. Rul. 2005-1, 2005-2 I.R.B. 258
                      Internal Revenue Service (I.R.S.)
                                Revenue Ruling
    LOW-INCOME HOUSING CREDIT; SATISFACTORY BOND; “BOND FACTOR” AMOUNTS FOR
                    THE PERIOD JANUARY THROUGH MARCH 2005
                          Published: January 10, 2005
 Low-income housing credit; satisfactory bond; “bond factor” amounts for the period January through March 2005. This ruling announces the monthly bond factor amounts to be used by taxpayers who dispose of qualified low-income buildings or interests therein during the period January through March 2005.
 In Rev. Rul. 90-60, 1990-2 C.B. 3, the Internal Revenue Service provided guidance to taxpayers concerning the general methodology used by the Treasury Department in computing the bond factor amounts used in calculating the amount of bond considered satisfactory by the Secretary under s 42(j)(6) of the Internal Revenue Code. It further announced that the Secretary would publish in the Internal Revenue Bulletin a table of bond factor amounts for dispositions occurring during each calendar month.
 Rev. Proc. 99-11, 1999-1 C.B. 275, established a collateral program as an alternative to providing a surety bond for taxpayers to avoid or defer recapture of the low-income housing tax credits under s 42(j)(6). Under this program, taxpayers may establish a Treasury Direct Account and pledge certain United States Treasury securities to the Internal Revenue Service as security.
 This revenue ruling provides in Table 1 the bond factor amounts for calculating the amount of bond considered satisfactory under s 42(j)(6) or the amount of United States Treasury securities to pledge in a Treasury Direct Account under Rev. Proc. 99-11 for dispositions of qualified low-income buildings or interests therein during the period January through March 2005.
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————————————–
 Table 1 Rev. Rul. 2005-1 Monthly Bond
————————————–
        Calendar Year Building Placed
————————————–
 Month  1991 1992 1993 1994 1995
 of Disposition
————————————–
Jan ‘05Â 14.-Â 27.-Â 39.-Â 48.-Â 56.-
         99   92   03   55   77
Feb ‘05Â 14.-Â 27.-Â 39.-Â 48.-Â 56.-
         99   92   03   55   77
Mar ‘05Â 14.-Â 27.-Â 39.-Â 48.-Â 56.-
         99   92   03   55   77
————————————–
———————————————————–
 Factor Amounts for Dispositions Expressed As a Percentage
 of Total Credits
———————————————————–
 in Service or, if Section 42(f)(1) Election Was Made, the
  Succeeding Calendar Year
———————————————————–
 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005
———————————————————–
 56.- 56.- 57.- 57.- 58.- 58.- 59.- 61.- 62.- 62.-
 71   86   15   52   00   83   92   22   49   68
 56.- 56.- 57.- 57.- 57.- 58.- 59.- 61.- 62.- 62.-
 59   74   04   41   89   72   80   09   33   68
 56.- 56.- 56.- 57.- 57.- 58.- 59.- 60.- 62.- 62.-
 47   63   93   30   79   61   69   97   19   68
———————————————————–
 For a list of bond factor amounts applicable to dispositions occurring during other calendar years, see: Rev. Rul. 98-3, 1998-1 C.B. 248; Rev. Rul. 2001-2, 2001-1 C.B. 255; Rev. Rul. 2001-53, 2001-2 C.B. 488; Rev. Rul. 2002-72, 2002-2 C.B. 759; Rev. Rul. 2003-117, 2003-2 C.B. 1051; and Rev. Rul. 2004-100, 2004-44 I.R.B. 718.
 DRAFTING INFORMATION
 The principal author of this revenue ruling is David McDonnell of the Office of Associate Chief Counsel (Passthroughs and Special Industries). For further information regarding this revenue ruling, contact Mr. McDonnell at (202) 622- 3040 (not a toll-free call).
 Rev. Rul. 2005-1, 2005-2 I.R.B. 258
Revenue Ruling 2005-22
Rev. Rul. 2005-22
Rev. Rul. 2005-22, 2005-13 I.R.B. 787
                      Internal Revenue Service (I.R.S.)
                                Revenue Ruling
                    LIFO; PRICE INDEXES; DEPARTMENT STORES
                           Published: March 28, 2005
 Section 472.–Last-in, First-out Inventories
26 CFR 1.472-1: Last-in, first-out inventories.
 LIFO; price indexes; department stores. The January 2005 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with reference to, January 31, 2005.
 LIFO; price indexes; department stores. The January 2005 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with reference to, January 31, 2005.
 The following Department Store Inventory Price Indexes for January 2005 were issued by the Bureau of Labor Statistics. The indexes are accepted by the Internal Revenue Service, under s 1.472-1(k) of the Income Tax Regulations and Rev. Proc. 86-46, 1986-2 C.B. 739, for appropriate application to inventories of department stores employing the retail inventory and last-in, first-out inventory methods for tax years ended on, or with reference to, January 31, 2005.
 The Department Store Inventory Price Indexes are prepared on a national basis and include (a) 23 major groups of departments, (b) three special combinations of the major groups — soft goods, durable goods, and miscellaneous goods, and (c) a store total, which covers all departments, including some not listed separately, except for the following: candy, food, liquor, tobacco, and contract departments.
   BUREAU OF LABOR STATISTICS, DEPARTMENT STORE INVENTORY PRICE INDEXES BY
                              DEPARTMENT GROUPS
                (January 1941 = 100, unless otherwise noted)
                Groups                   Jan. 2004   Jan. 2005    Percent
                                                                     Change
                                                                    from Jan.
                                                                     2004 to
                                                                    Jan. 2005
                                                                      [FN1]
——————————————————————————-
1.         Piece Goods ………………….. 468.0       494.0         5.6
2.         Domestics and Draperies ……….. 543.5       536.5        -1.3
3.         Women’s and Children’s Shoes …… 599.6       643.3         7.3
4.         Men’s Shoes ………………….. 849.6       840.6        -1.1
5.         Infants’ Wear ………………… 578.1       578.4         0.1
6.         Women’s Underwear …………….. 504.8       515.2         2.1
7.         Women’s Hosiery ………………. 350.5       338.9        -3.3
8.         Women’s and Girls’
             Accessories ………………… 544.8       560.4         2.9
9.         Women’s Outerwear and Girls’
             Wear ………………………. 335.6       333.3        -0.7
10.        Men’s Clothing ……………….. 530.7       534.9         0.8
11.        Men’s Furnishings …………….. 574.2       561.9        -2.1
12.        Boys’ Clothing and
             Furnishings ………………… 416.3       414.9        -0.3
13.        Jewelry ……………………… 888.4       879.0        -1.1
14.        Notions ……………………… 788.2       784.4        -0.5
15.        Toilet Articles and Drugs ……… 981.0       994.7         1.4
16.        Furniture and Bedding …………. 617.5       604.9        -2.0
17.        Floor Coverings ………………. 595.4       598.2         0.5
18.        Housewares …………………… 710.7       711.8         0.2
19.        Major Appliances ……………… 205.5       202.6        -1.4
20.        Radio and Television …………… 43.5        40.0        -8.0
21.        Recreation and Education
             [FN2] ………………………. 81.3        78.3        -3.7
22.        Home Improvements [FN2] ……….. 127.7       135.6         6.2
23.        Automotive Accessories [FN2] …… 112.3       113.8         1.3
Groups 1-15: Soft Goods ………………….. 545.3Â Â Â Â Â Â Â 546.2Â Â Â Â Â Â Â Â Â 0.2
Groups 16-20: Durable Goods ………………. 386.5Â Â Â Â Â Â Â 380.7Â Â Â Â Â Â Â Â -1.5
Groups 21-23: Misc. Goods [FN2] ……………. 93.6Â Â Â Â Â Â Â Â 92.8Â Â Â Â Â Â Â Â -0.9
           Store Total [FN3] …………….. 488.6       487.2        -0.3
FN1. Absence of a minus sign before the percentage change in this column
 signifies a price increase.
FN2. Indexes on a January 1986 = 100 base.
FN3. The store total index covers all departments, including some not listed
 separately, except for the following: candy, food, liquor, tobacco and
 contract departments.
DRAFTING INFORMATION
 The principal author of this revenue ruling is Michael Burkom of the Office of Associate Chief Counsel (Income Tax and Accounting). For further information regarding this revenue ruling, contact Mr. Burkom at (202) 622- 7924 (not a toll-free call).
 Rev. Rul. 2005-22, 2005-13 I.R.B. 787
Revenue Ruling 2005-14
Rev. Rul. 2005-14
Rev. Rul. 2005-14, 2005-12 I.R.B. 749
                      Internal Revenue Service (I.R.S.)
                                Revenue Ruling
                  FRINGE BENEFITS AIRCRAFT VALUATION FORMULA
                           Published: March 21, 2005
 Section 61.–Gross Income Defined, 26 CFR 1.61-21: Taxation of fringe benefits.
 Fringe benefits aircraft valuation formula. The Standard Industry Fare Level (SIFL) cents-per-mile rates and terminal charges in effect for the first half of 2005 are set forth for purposes of determining the value of noncommercial flights on employer-provided aircraft under section 1.61-21(g) of the regulations.
 Fringe benefits aircraft valuation formula. The Standard Industry Fare Level (SIFL) cents-per-mile rates and terminal charges in effect for the first half of 2005 are set forth for purposes of determining the value of noncommercial flights on employer-provided aircraft under section 1.61-21(g) of the regulations.
 For purposes of the taxation of fringe benefits under section 61 of the Internal Revenue Code, section 1.61-21(g) of the Income Tax Regulations provides a rule for valuing noncommercial flights on employer-provided aircraft. Section 1.61-21(g)(5) provides an aircraft valuation formula to determine the value of such flights. The value of a flight is determined under the base aircraft valuation formula (also known as the Standard Industry Fare Level formula or SIFL) by multiplying the SIFL cents-per-mile rates applicable for the period during which the flight was taken by the appropriate aircraft multiple provided in section 1.61-21(g)(7) and then adding the applicable terminal charge. The SIFL cents-per-mile rates in the formula and the terminal charge are calculated by the Department of Transportation and are reviewed semi-annually.
 The following chart sets forth the terminal charges and SIFL mileage rates:
——————————————————————————-
Period During Which the       Terminal      SIFL Mileage Rates
 Flight Is Taken               Charge
1/1/05 - 6/30/05Â Â Â Â Â Â Â Â Â Â Â Â Â Â $35.49Â Â Â Â Â Â Â Â Up to 500 miles = $.1942 per mile
                                             501-1500 miles = $.1480 per mile
                                             Over 1500 miles = $.1423 per mile
——————————————————————————-
DRAFTING INFORMATION
 The principal author of this revenue ruling is Kathleen Edmondson of the Office of Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities). For further information regarding this revenue ruling, contact Ms. Edmondson at (202) 622-0047 (not a toll-free call).
 Rev. Rul. 2005-14, 2005-12 I.R.B. 749
Revenue Ruling 2005-11
Rev. Rul. 2005-11
Rev. Rul. 2005-11, 2005-14 I.R.B. 816
                      Internal Revenue Service (I.R.S.)
                                Revenue Ruling
             ALTERNATIVE MINIMUM TAX; REFINANCED MORTGAGE INTEREST
                           Released: March 17, 2005
                           Published: April 4, 2005
 Section 56.–Adjustments in Computing Alternative Minimum Taxable Income
 Is interest paid on a home mortgage that has been refinanced more than one time deductible as qualified housing interest for purposes of the alternative minimum tax?
Section 163.–Interest, 26 CFR 1.163-10T: Qualified residence interest (temporary).
 Is interest paid on a home mortgage that has been refinanced more than one time deductible as qualified housing interest for purposes of the alternative minimum tax?
Section 55.–Alternative Minimum Tax Imposed, 26 CFR 1.55-1: Alternative minimum taxable income.
 Alternative minimum tax; refinanced mortgage interest. Interest paid on a home mortgage that has been refinanced more than one time is deductible as qualified housing interest for purposes of the alternative minimum tax to the extent the interest on the mortgage that was refinanced is qualified housing interest and the amount of the mortgage indebtedness is not increased.
 Alternative minimum tax; refinanced mortgage interest. Interest paid on a home mortgage that has been refinanced more than one time is deductible as qualified housing interest for purposes of the alternative minimum tax to the extent the interest on the mortgage that was refinanced is qualified housing interest and the amount of the mortgage indebtedness is not increased.
ISSUE
 Is interest paid on a home mortgage that has been refinanced more than one time deductible as qualified housing interest for purposes of the alternative minimum tax?
FACTS
 In 1990, A borrowed $100x to purchase a principal residence (the 1990 mortgage). In 2000, the outstanding principal balance on the 1990 mortgage was $90x, and A refinanced the $90x balance of the 1990 mortgage (the 2000 mortgage). In 2004, the outstanding principal balance on the 2000 mortgage was $80x. A refinanced the $80x balance of the 2000 mortgage and borrowed an additional $30x. Thus, the total amount of A’s mortgage in 2004 was $110x (the 2004 mortgage). A did not use the $30x to acquire, construct, or substantially improve any property that was a principal residence or a qualified residence. At no time did A’s indebtedness to acquire his principal residence or a qualified residence exceed $1,000,000. A is not a married individual filing a separate return.
LAW AND ANALYSIS
 Section 55 of the Internal Revenue Code provides that the alternative minimum tax is a tax equal to the excess (if any) of the tentative minimum tax for the taxable year over the regular tax (defined in s 55(c)) for the taxable year.
 Tentative minimum tax is defined in s 55(b)(1)(A) for noncorporate taxpayers as the sum of 26 percent of so much of the taxable excess as does not exceed $175,000, plus 28 percent of so much of the taxable excess as exceeds $175,000.
 The term “taxable excess” is defined in s 55(b)(1)(ii) as so much of the alternative minimum taxable income for the taxable year as exceeds the exemption amount provided for in s 55(d).
 Alternative minimum taxable income is defined in s 55(b)(2) as the taxable income of the taxpayer for the taxable year determined with the adjustments provided in ss 56 and 58, and increased by the amount of the items of tax preference described in s 57.
 Section 56(b) contains the adjustments applicable to individuals, which include the adjustment for interest in s 56(b)(1)(C). Section 56(b)(1)(C) provides that, in determining the amount allowable as a deduction for interest, s 163(d), which provides limitations on investment interest, and s 163(h), which disallows deductions for personal interest, shall apply, except that in lieu of the exception under s 163(h)(2)(D) for qualified residence interest, the term “personal interest” shall not include any qualified housing interest.
 Qualified housing interest is defined in s 56(e)(1) as interest that is qualified residence interest (as defined in s 163(h)(3)) and is paid or accrued during the taxable year on indebtedness that is incurred in acquiring, constructing, or substantially improving any property that is the principal residence (within the meaning of s 121) of the taxpayer at the time such interest accrues, or is a qualified dwelling that is a qualified residence (within the meaning of s 163(h)(4)). In addition, the last sentence of s 56(e)(1) provides that qualified housing interest includes interest on any indebtedness resulting from the refinancing of indebtedness meeting the requirements of qualified housing interest, but only to the extent that the amount of the indebtedness resulting from such refinancing does not exceed the amount of the refinanced indebtedness immediately before the refinancing.
 The legislative history to the enactment of s 56 as part of the Tax Reform Act of 1986 states “It is clarified that, for minimum tax purposes, upon a refinancing of a loan that gives rise to qualified housing interest, interest paid on the loan is treated as qualified housing interest to the extent that (1) it so qualified under the prior loan, and (2) the amount of the loan was not increased.” H.R. Conf. Rep. No. 841, 99th Cong., 2d Sess., vol. II, at 259 (1986).
 Section 163(h) of the Code provides that, in the case of a taxpayer other than a corporation, no deduction shall be allowed for personal interest paid or accrued during the taxable year. Under s 163(h)(2)(D), personal interest does not include qualified residence interest.
 Qualified residence interest is defined in s 163(h)(3) as any interest that is paid or accrued during the taxable year on acquisition indebtedness or home equity indebtedness with respect to any qualified residence of the taxpayer. Section 163(h)(3)(B) defines acquisition indebtedness as any indebtedness that is incurred in acquiring, constructing, or substantially improving any
qualified residence of the taxpayer and is secured by such residence. Section 163(h)(3)(B) also provides that acquisition indebtedness includes any indebtedness secured by such residence resulting from the refinancing of indebtedness meeting the requirements of acquisition indebtedness, or refinancing of acquisition indebtedness, but only to the extent the amount of the indebtedness resulting from such refinancing does not exceed the amount of the refinanced indebtedness. Under s 163(h)(3)(B)(ii), the aggregate amount of acquisition indebtedness for any period cannot exceed $1,000,000 (or $500,000 in the case of a married individual filing a separate return).
 The term “qualified residence” is defined in s 163(h)(4)(A) as the principal residence (within the meaning of s 121) of the taxpayer and one other residence of the taxpayer that is selected by the taxpayer for the taxable year and that is used by the taxpayer as a residence (within the meaning of s 280A(d)(1)).
 The 1990 mortgage is indebtedness incurred in acquiring A’s principal residence. The interest paid or accrued on the 1990 mortgage meets the requirements of qualified residence interest under s 163(h)(3). Thus, the interest paid or accrued by A on the 1990 mortgage is qualified housing interest for purposes of the alternative minimum tax.
 The last sentence of s 56(e)(1), as clarified by the legislative history, indicates that when s 56(b)(1)(C) was enacted as part of the alternative minimum tax provisions, Congress intended that interest with respect to a refinancing of a loan that gives rise to qualified housing interest would be deductible for alternative minimum tax purposes to the extent the amount of the loan was not increased. When A refinanced the 1990 mortgage in 2000, the refinanced amount equaled the amount of the outstanding principal. Thus, the interest paid or accrued on the 2000 mortgage is deductible as qualified housing interest for purposes of the alternative minimum tax because the interest on the 1990 mortgage is qualified housing interest and the amount of the loan is not increased.
 Similarly, when A refinanced the 2000 mortgage in 2004, the interest on the 2004 mortgage is qualified housing interest to the extent of the outstanding principal balance of the 2000 mortgage at the time of the refinancing because the interest on the 2000 mortgage is qualified housing interest. However, as part of the 2004 refinancing A borrowed an additional $30x, and A did not use the $30x to acquire, construct, or substantially improve any property that was a principal residence or a qualified residence. Accordingly, for alternative minimum tax purposes A may deduct only the interest paid or incurred on $80x and not the interest attributable to the additional $30x of the $110x of the 2004 mortgage.
HOLDING
 Interest paid on a home mortgage that has been refinanced more than one time is deductible as qualified housing interest for purposes of the alternative minimum tax to the extent the interest on the mortgage that was refinanced is qualified housing interest and the amount of the mortgage indebtedness is not increased.
DRAFTING INFORMATION
 The principal author of this revenue ruling is Martin Scully, Jr. of the Office of Associate Chief Counsel (Income Tax & Accounting). For further information regarding this revenue ruling, contact Mr. Scully at (202) 622- 4960 (not a toll-free call).
 Rev. Rul. 2005-11, 2005-14 I.R.B. 816
Revenue Ruling 2005-23
Rev. Rul. 2005-23
Rev. Rul. 2005-23, 2005-15 I.R.B. 864
                      Internal Revenue Service (I.R.S.)
                                Revenue Ruling
     FEDERAL RATES; ADJUSTED FEDERAL RATES; ADJUSTED FEDERAL LONG-TERM RATE
                         AND THE LONG-TERM EXEMPT RATE
                           Released: March 17, 2005
                           Published: April 11, 2005
 Section 280G.–Golden Parachute Payments
 Federal short-term, mid-term, and long-term rates are set forth for the month of April 2005.
Section 382.–Limitation on Net Operating Loss Carryforwards and Certain Built-In Losses Following Ownership Change
 The adjusted applicable federal long-term rate is set forth for the month of April 2005.
Section 412.–Minimum Funding Standards
 The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of April 2005.
Section 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 April 2005.
Section 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 April 2005.
Section 482.–Allocation of Income and Deductions Among Taxpayers
 Federal short-term, mid-term, and long-term rates are set forth for the month of April 2005.
Section 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 April 2005.
Section 642.–Special Rules for Credits and Deductions
 Federal short-term, mid-term, and long-term rates are set forth for the month of April 2005.
Section 807.–Rules for Certain Reserves
 The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of April 2005.
Section 846.–Discounted Unpaid Losses Defined
 The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of April 2005.
Section 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 April 2005.
Section 7520.–Valuation Tables
 The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of April 2005.
Section 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 April 2005.
Section 1274.–Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property
(Also Section 42)
 Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for April 2005.
 Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for April 2005.
 This revenue ruling provides various prescribed rates for federal income tax purposes for April 2005 (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 section 1288(b). Table 3 sets forth the adjusted federal long-term rate and the long-term tax-exempt rate described in section 382(f). Table 4 contains the appropriate percentages for determining the low-income housing credit described in section 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 section 7520.
—————————————————–
             REV. RUL. 2005-23 TABLE 1
   Applicable Federal Rates (AFR) for April 2005
              Period for Compounding
           Annual   Semiannual Quarterly Monthly
Short-term
      AFR 3.35%    3.32%      3.31%     3.30%
 110% AFR 3.68%    3.65%      3.63%     3.62%
 120% AFR 4.02%    3.98%      3.96%     3.95%
 130% AFR 4.37%    4.32%      4.30%     4.28%
—————————————————–
——————————————————————
                   REV. RUL. 2005-23 TABLE 1
   Applicable Federal Rates (AFR) for April 2005 — Continued
                     Period for Compounding
             Annual       Semiannual   Quarterly   Monthly
   Mid-term
        AFR 4.09%        4.05%        4.03%       4.02%
   110% AFR 4.51%        4.46%        4.44%       4.42%
   120% AFR 4.92%        4.86%        4.83%       4.81%
   130% AFR 5.34%        5.27%        5.24%       5.21%
   150% AFR 6.17%        6.08%        6.03%       6.00%
   175% AFR 7.22%        7.09%        7.03%       6.99%
  Long-term
        AFR 4.68%        4.63%        4.60%       4.59%
   110% AFR 5.15%        5.09%        5.06%       5.04%
   120% AFR 5.64%        5.56%        5.52%       5.50%
   130% AFR 6.11%        6.02%        5.98%       5.95%
——————————————————————
————————————————————-
                 REV. RUL. 2005-23 TABLE 2
                Adjusted AFR for April 2005
                  Period for Compounding
                      Annual Semiannual Quarterly Monthly
Short-term adjusted
AFRÂ Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â 2.40%Â Â 2.39%Â Â Â Â Â Â 2.38%Â Â Â Â Â 2.38%
Mid-term adjusted AFRÂ 3.03%Â Â 3.01%Â Â Â Â Â Â 3.00%Â Â Â Â Â 2.99%
Long-term adjusted
AFRÂ Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â 4.19%Â Â 4.15%Â Â Â Â Â Â 4.13%Â Â Â Â Â 4.11%
————————————————————-
——————————————————————————-
                          REV. RUL. 2005-23 TABLE 3
                   Rates Under Section 382 for April 2005
Adjusted federal long-term rate for the current month                    4.19%
Long-term tax-exempt rate for ownership changes during the current month 4.20%
 (the highest of the adjusted federal long-term rates for the current
 month and the prior two months.)
——————————————————————————-
——————————————————————————-
                          REV. RUL. 2005-23 TABLE 4
        Appropriate Percentages Under Section 42(b)(2) for April 2005
Appropriate percentage for the 70% present value low-income housing      8.02%
 credit
Appropriate percentage for the 30% present value low-income housing      3.44%
 credit
——————————————————————————-
——————————————————————————-
                          REV. RUL. 2005-23 TABLE 5
                   Rate Under Section 7520 for April 2005
Applicable federal rate for determining the present value of an annuity, 5.00%
 an interest for life or a term of years, or a remainder or
 reversionary interest
——————————————————————————-
 Rev. Rul. 2005-23, 2005-15 I.R.B. 864