Exceptions

OFFICE OF
CHIEF COUNSEL
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, DC 20224
December 28, 1999
CC:DOM:IT&A:2
Number: 200012080
Release Date: 3/24/2000
Index Nos: 6041.08-00 SPR-119779-99
6049.03-00
MEMORANDUM FOR BLAKE FERGUSON
ASSISTANT DISTRICT COUNSEL
NORTH - SOUTH CAROLINA DISTRICT
FROM: Lewis J. Fernandez
Deputy Assistant Chief Counsel
(Income Tax & Accounting)
SUBJECT: Information Reporting - Condemnation of Real Property
Our prior memorandum to you (October 4, 1999; CC;DOM:IT&A:2; SPR-110473-99,
199947029) concluded, in part, that the interest component of a condemnation award did not meet the definition of interest under § 6049 of the Internal Revenue Code.
Thus, our memorandum further concluded that a payment to a person of such interest of $600 or more in a taxable year should be reported under § 6041 on Form 1099-MISC.
However, under a special rule set forth in the instructions for Form 1099-INT, interest of
$600 or more paid to any person in a taxable year and not meeting the criteria of §
6049 is reported on Form 1099-INT. Accordingly, our prior memorandum is modified.
If we can be of further assistance, please contact CC:DOM:IT&A:2 at 202-622-4920.