Title 61--REVENUE DEPARTMENT OF REVENUE [61 PA. CODE CHS. 103, 108, 117 AND 125] Personal Income Tax; Exempt and Nonexempt Income [26 Pa.B. 887] The Department of Revenue (Department) by this order amends §§ 103.13, 103.16 and 117.18 (relating to net gains or income from disposition of property; interest; and return of information as to payment in excess of $10), adds Chapter 108 (relating to distributions) and deletes Chapter 125 (relating to personal income tax pronouncements--statement of policy).
These amendments implement the act of December 3, 1993 (P. L. 473, No. 68) (Act 68) which makes taxable gains derived from dispositions of Federal, State and local obligations issued on or after February 1, 1994, and exempts from taxation exempt-interest dividends of investment companies. It also details the circumstances under which information returns would be required from investment companies, Subchapter S corporations and certain other organizations.
Section 103.13 has been amended by adding a new subsection (i) which details the determination of net gain or income with respect to obligations issued on or after February 1, 1994. A new subsection (j) has been added which details adjustments to basis. Paragraph (1) describes adjustments to the basis of a debt instrument in the hands of the holder for taxable years beginning on or after January 1, 1993. Paragraph (2) describes adjustments to the basis for an obligation issued by the Commonwealth, a public authority, commission, board or other agency created by the Commonwealth, a political subdivision of the Commonwealth or a public authority created by the political subdivision or an obligation exempt from tax under the laws of the United States in the hands of the holder.
Section 103.16(a) has been amended to provide that interest includes any charge for the use or detention of money or for a forbearance from enforcement of a debt that is due, whether or not payable as such or as principal. In addition, for taxable years beginning on or after January 1, 1993, interest shall also include any excess of a publicly offered obligation's stated redemption price at maturity over the first price at which a substantial amount of the obligations included in the issue is sold to the public. A new subsection (f) has been added which details unstated or imputed interest for taxable years beginning on or after January 1, 1993.
The Department has also added a new Chapter 108. The chapter is divided into three sections, each detailing rules relating to distributions for different entities. Section 108.1 relates to distributions by corporations, § 108.2 relates to distributions by business trusts and § 108.3 relates to distributions by investment companies.
Section 117.18 has been amended by adding a subsection (b) which provides that a Pennsylvania information return for recipients of dividends and other taxable or nontaxable distributions on shares of stock or beneficial interests shall be made by certain entities. A new subsection (c) sets forth the various ways in which a Pennsylvania information return can be made. A new subsection (d) provides that, unless an extension is granted by the Department on or before February 29 of each calendar year beginning on or after January 1, 1997, an information return shall be furnished to each recipient of distributions who makes a written request or who is a resident individual, estate or trust or other taxpayer, or an investment company. A new subsection (e) provides that an investment company, corporation, association, business trust or personal holding company may rely on its business records in determining the identity and place of residence of recipients.
On May 6, 1994, the Department published a statement of policy relating to exempt and nonexempt income. This statement of policy was codified at §§ 125.11--125.15. With the adoption of these subject amendments, this statement of policy will no longer be necessary and is therefore being deleted.
Notice and Comments
Notice of proposed rulemaking was published at 24 Pa.B. 3538 (July 23, 1994). This proposal is being adopted with changes as set forth in Annex A.
The Department received four comments from the public during the public comment period. In addition, the Department received comments from the Independent Regulatory Review Commission (IRRC). No comments were received from the House and Senate Finance Committees.
Generally, the comments expressed concerns in the following two areas:
(1) The proposed § 117.18(c) provided that a Pennsylvania information return shall be made on Federal Form 1099-DIV, ''U. S. Information Return for Recipients of Dividends and Distributions'' containing the statement ''FOR PA TAX PURPOSES ONLY'' or other form acceptable to the Department. Paragraphs (1)--(3) set forth those items of information that the return shall show. Those who commented on the proposed amendments generally felt that this requirement would impose an undue administrative burden and cost on investment companies and others. The suggestion was made to amend § 117.18(c)( 3) to permit those who are required to provide a Pennsylvania information return to provide taxpayers with simple instructions on how to calculate the information required under subsection (c)(3) from year-end reports when appropriate.
One comment raised the concern of whether the Department could require that changes be made to a Federal form in light of the fact that only the Federal government may authorize changes to its forms. In addition, a comment also stated that Federal Form 1099-DIV statements are not issued to investors whose dividend distributions were derived solely from state and local governments and public financing authorities.
(2) Those who commented on the proposal also felt that the proposal should be amended to clarify that Pennsylvania information returns will only be required to be sent to taxpayers utilizing a Pennsylvania mailing address.
In addition, IRRC also suggested that the Department set forth an effective date which would give everyone at least 90 days from the effective date of this rulemaking to develop and distribute the information forms. IRRC also recommended that a compliance deadline be set forth in the regulation.
In response to the comments received as well as a further review of the proposal, the following revisions have been made:
(1) Section 117.18(b) has been amended by adding the phrase ''or beneficial interests'' and deleting the phrase ''one or more'' and replacing it with the word ''any.'' These amendments have been made for the purpose of clarifying who must actually file a Pennsylvania information return.
(2) Paragraph (2) under § 117.18(b) has been amended by deleting the phrase ''Federal Internal Revenue Code Subchapter S'' and adding the phrase ''that has an election in effect pursuant to 26 U.S.C.A. § 1362 (relating to election; revocation; termination).'' This statutory citation is the section which provides the authority for corporations to elect Federal Subchapter S treatment.
(3) Section 117.18(c) has been amended by dividing the proposed language, as well as amending it, into paragraph (1) and subparagraphs (i)--(iii) and by adding language at paragraphs (2) and (3).
In response to the comments received, language relating to making the Pennsylvania information return on the Federal Form 1099 DIV has been deleted from § 117.18(c)(1) and replaced with a new Pennsylvania Form 99-DIV entitled ''Information Return for Recipients of Dividends and Distributions.'' A Pennsylvania information return could also be made on a form other than the Pennsylvania Form 99-DIV if the form shows the following:
1. The payer's name, address and Federal identification number.
2. The recipient's name, address and Federal identification number.
3. The amount of dividends, nontaxable distributions and Pennsylvania exempt-interest dividends paid.
Consistent with suggestions set forth in comments received, the new paragraph (2) under § 117.18(c) clarifies that when a regulated investment company furnishes Federal Form 1099-DIV to a recipient in compliance with Federal income tax requirements, a Pennsylvania information return may be made by attaching a separate statement showing the ratio of Pennsylvania exempt-interest dividends paid to total ordinary dividends reported on the Federal form.
Also consistent with suggestions made in comments the Department received, a new paragraph (3) under § 117.18(c) provides that when a regulated investment company is not required to furnish Federal Form 1099-DIV, a Pennsylvania information return may be made by separate statement showing the amount of dividends, nontaxable distributions and Pennsylvania exempt-interest dividends paid.
A new subsection (d) has been added to § 117.18 which provides that, unless an extension is granted by the Department on or before February 28 of each calendar year beginning on or after January 1, 1997, an information return shall be furnished to each recipient of distributions who makes a written request therefor or who is a resident individual, estate or trust or other taxpayer, or an investment company. This new subsection answers questions regarding who must be furnished an information return.
In response to comments received, a new subsection (e) has been added to § 117.18 which provides that an investment company, corporation, association, business trust or personal holding company may rely on its business records in determining the identity and place of residence of recipients.
When appropriate throughout § 117.18, the term ''investment'' was added to modify the term ''company.'' This addition merely clarifies the Department's proposed language.
Finally, the Department is deleting Chapter 125, §§ 125.11--125.15. Upon adoption, these amendments will supersede the statement of policy; therefore, the statement of policy should be deleted. The statement of policy provided guidance with regard to the Department's interpretation of Act 68 until a regulatory package could be adopted.
Fiscal Impact
The Department has determined that the amendments will have no significant fiscal impact on the Commonwealth.
Paperwork
The amendments will generate additional paperwork for certain organizations. These organizations are ones whose shareholders, because of differences between the Federal Income Tax and the Pennsylvania Personal Income Tax, need additional information to accurately report their personal income. These organizations include Subchapter S corporations that are not PA S corporations, personal holding companies, foreign corporations and some investment companies. The additional paperwork will enable their investors to comply with their own reporting requirements.
In addition, there will be additional paperwork costs for the Commonwealth in providing the Pennsylvania Form 99-DIV ''Information Return for Recipients of Dividends and Distributions'' to Pennsylvania taxpayers.
Effectiveness/Sunset Date
The amendments will become effective upon final publication in the Pennsylvania Bulletin. The regulations will be monitored annually. A sunset date has not been assigned.
Contact Person
The contact person for an explanation of the amendments is Anita M. Doucette, Office of Chief Counsel, PA Department of Revenue, Dept. 281061, Harrisburg, PA 17128-1061.
Authority
The amendments are adopted under section 354 of the Tax Reform Code of 1971 (code) (71 P. S. § 7354). Section 354 of the code specifically authorizes and empowers the Department to prescribe, adopt, promulgate and enforce rules and regulations relating to any matter or thing pertaining to the administration and enforcement of the provisions of and the collection of taxes imposed by Article III of the code (71 P. S. §§ 7301--7361).
Regulatory Review
Under section 5(a) of the Regulatory Review Act (71 P. S. § 745.5(a)), on July 13, 1994, the Department submitted a copy of the notice of proposed rulemaking, published at 24 Pa.B. 3538, to IRRC and the Chairpersons of the House Committee on Finance and the Senate Committee on Finance, for review and comment. In compliance with section 5(b.1) of the Regulatory Review Act, the Department also provided IRRC and the Committees with copies of the comments received, as well as other documentation.
In preparing these final-form regulations, the Department has considered the comments received from IRRC, the Committees and the public.
These final-form regulations were deemed approved by the Committees on January 9, 1996, and were approved by IRRC on January 18, 1996, in accordance with section 5(c) of the Regulatory Review Act.
Findings
The Department finds that:
(1) Public notice of intention to amend the regulations has been given under sections 201 and 202 of the act of July 31, 1968 (P. L. 769, No. 240) (45 P. S. §§ 1201 and 1202) and the regulations thereunder, 1 Pa. Code § 7.1 and 7.2.
(2) The amendments are necessary and appropriate for the administration and enforcement of the authorizing statute.
Order
The Department, acting under the authorizing statute, orders that:
(a) The regulations of the Department, 61 Pa. Code Chapters 103, 117, 108 and 125, are amended by amending §§ 103.13, 103.16 and 117.18; by adding §§ 108.1--108.3; and by deleting §§ 125.11--125.15 to read as set forth in Annex A, with ellipses referring to the existing text of the regulations.
(b) The Secretary of the Department shall submit this order and Annex A to the Office of General Counsel and the Office of Attorney General for approval as to form and legality as required by law.
(c) The Secretary of the Department shall certify this order and Annex A and deposit them with the Legislative Reference Bureau as required by law.
(d) This order shall take effect upon publication in the Pennsylvania Bulletin.
ROBERT A. JUDGE, Sr.,
Secretary(Editor's Note: The deletion of §§ 125.11--125.15 was not included in the proposal at 24 Pa.B. 3538.)
(Editor's Note: For the text of the order of the Independent Regulatory Review Commission relating to this document, see 26 Pa.B. 548 (February 3, 1996).)
Fiscal Note: Fiscal Note 15-346 remains valid for the final adoption of the subject regulations.
Annex A TITLE 61. REVENUE PART I. DEPARTMENT OF REVENUE Subpart B. GENERAL FUND REVENUES ARTICLE V. PERSONAL INCOME TAX CHAPTER 103. IMPOSITION AND DETERMINATION OF TAX Subchapter B. DETERMINATION OF TAX § 103.13. Net gains or income from disposition of property.
* * * * * (i) Determination of net gain or income. For purpose of determining net gains or income from the disposition of property, gain or loss shall be recognized on the sale, exchange or other disposition of obligations issued by the Commonwealth, a public authority, commission, board or other agency created by the Commonwealth, a political subdivision of the Commonwealth or a public authority created by the political subdivision or exempt from State taxation under the laws of the United States only with respect to obligations issued on or after February 1, 1994. Regardless of the obligation's date of issuance, gain or loss shall be recognized on the sale, exchange or other disposition of obligations issued by the Commonwealth, a public authority, commission, board or other agency created by the Commonwealth, a political subdivision of the Commonwealth or a public authority created by the political subdivision or exempt from State taxation under the laws of the United States for one or more of the following purposes:
(1) Computing earnings and profits.
(2) Adjusting basis.
(3) Determining an individual's poverty income.
(j) Adjustments to basis.
(1) For taxable years beginning on or after January 1, 1993, the basis of a debt instrument in the hands of the holder shall be adjusted upward by the amount of unstated or imputed interest includible in the income of the holder and shall be adjusted downward, but not below zero, by the amount of any payment under the debt instrument other than a payment of stated interest.
(2) The basis of an obligation issued by the Commonwealth, a public authority, commission, board or other agency created by the Commonwealth, a political subdivision of the Commonwealth or a public authority created by the political subdivision or an obligation exempt from tax under the laws of the United States in the hands of the holder shall be adjusted upward by the amount of unstated or imputed interest that would have been includible in income but for its statutory exemption and shall be adjusted downward, but not below zero, by the amount of any payment under the debt instrument other than a payment of stated interest.
§ 103.16. Interest.
(a) Generally. Interest includes any charge for the use or detention of money or for a forbearance from enforcement of a debt that is due, whether or not payable as such or as principal, including, for taxable years beginning on or after January 1, 1993, any excess of a publicly offered obligation's stated redemption price at maturity over the first price at which a substantial amount of the obligations included in the issue is sold to the public. For this purpose, the public does not include bond houses, brokers or other persons or organizations acting in the capacity of underwriters or wholesalers. As a general rule, interest received by or credited to the taxpayer constitutes gross income and is fully taxable. Interest income includes interest on savings or other bank deposits; interest on coupon bonds; interest on an open account, promissory note, mortgage or corporate bond or debenture; the interest portion of a condemnation award, usurious interest (unless by state law it is automatically converted to a payment on the principal); interest on legacies and life insurance proceeds held under an agreement to pay interest thereon; and interest on refunds of taxes.
(b) Bonds bought when interest defaulted or accrued. If a taxpayer purchases bonds where interest has accrued but has not been paid, interest which is in arrears but has accrued at the time of purchase is not income and may not be taxable as interest if subsequently paid. The payments are returns of capital which reduce the remaining cost basis. Interest which accrued after the date of purchase is taxable interest income for the year in which received or accrued, depending on the method of accounting used by the taxpayer.
(c) Bonds sold between interest dates. If bonds are sold between interest dates, part of the sale price represents interest accrued to the date of the sale and shall be reported as interest income.
(d) Annuities. Interest does not include amounts received under an annuity contract.
(e) Government obligations. Interest derived from obligations which are not statutorily free from state or local taxation under any other act of the General Assembly or under the laws of the United States is taxable under this section. Interest on obligations issued by or on behalf of the United States Government is not taxable under this section. Interest on obligations issued by the Commonwealth, a public authority, commission, board or other agency created by the Commonwealth, a political subdivision of the Commonwealth, or a public authority created by a political subdivision which is for the performance of essential governmental functions and which is in all respects for the benefit of the people of this Commonwealth, for the increase of their commerce and prosperity and for the improvement of their health and living conditions is not taxable under this subsection. Interest on obligations issued by other states and territories, their political subdivisions and instrumentalities is taxable under this section.
(f) Unstated or imputed interest. Unstated or imputed interest for a taxable year beginning on or after January 1, 1993, including interest derived from government obligations, shall be computed in the same manner as it is required to be computed for Federal Income Tax purposes.
CHAPTER 108. DISTRIBUTIONS Sec.
108.1. Distributions by corporations. 108.2. Distributions by business trusts. 108.3. Distributions by investment companies. § 108.1. Distributions by corporations.
(a) That portion of a distribution paid or credited out of earnings and profits by a corporation to a taxpayer in his capacity as a stockholder shall be taxed as a dividend. The remaining portion shall be applied against, and reduce, the adjusted basis of the taxpayer's stock and, to the extent that it exceeds the adjusted basis of the stock, shall be taxed as a net gain from the disposition of intangible personal property.
(b) The amount of a distribution shall be the amount of money, and the fair market value of property determined as of the date of the distribution, received, reduced, but not below zero, by the amount of any liability of the corporation assumed by the stockholder in connection with the distribution and the amount of any liability to which the property received by the stockholder is subject immediately before, and immediately after, the distribution.
(c) The portion of a distribution that is paid or credited out of earnings and profits shall be determined in accordance with the following:
(1) Every distribution shall be deemed to be made out of earnings and profits to the extent thereof and from the most recently accumulated earnings and profits.
(2) If the current taxable year's earnings and profits equal or exceed the amount of distributions made on stock during the year, each distribution is wholly a dividend paid out of current earnings and profits.
(3) If the amount of distributions made on stock during the current taxable year exceeds the year's earnings and profits, the following apply:
(i) The year's earnings and profits shall be allocated proportionately to each distribution.
(ii) The remaining portion of each distribution is a dividend only to the extent of accumulated earnings and profits at the time the distribution is made.
(4) Income or gain that is taxable under, as well as income or gain that is exempt from, or not taxable under, this article shall be included in computing earnings and profits.
§ 108.2. Distributions by business trusts.
A distribution paid or credited to a taxpayer in its capacity as an interest holder by a business trust is treated in the same manner as a distribution by a corporation to its stockholders.
§ 108.3. Distributions by investment companies.
(a) Investment company. For purposes of this section, the term ''investment company'' includes the following:
(1) A regulated investment company, as defined in 26 U.S.C.A. § 851 (relating to the definition of regulated investment company).
(2) An incorporated or unincorporated enterprise registered with the Securities and Exchange Commission under the Investment Company Act of 1940 (15 U.S.C.A. §§ 80a-1--80b-21).
(3) An investment company which has no or only limited powers under its governing instruments to vary its investments.
(b) Dividends and other distributions. Except as provided in subsection (c), distributions paid or credited to their shareholders with respect to their shares by investment companies are taxed in the same manner as distributions by corporations to their stockholders.
(c) Pennsylvania exempt-interest dividends. If, for any taxable year beginning on or after January 1, 1993, the total amount of the distributions that, but for this subsection, would otherwise constitute taxable dividends exceeds the accumulated income account of the investment company, the excess shall constitute excludible Pennsylvania exempt-interest dividends and shall be allocated proportionately to each distribution.
(d) Accumulated income account. Each investment company shall establish and maintain an accumulated income account and shall cumulatively adjust the account at the close of each taxable year beginning on or after January 1, 1993, as follows:
(1) By increasing the account for the sum of the following:
(i) The amount of the investment company's current earnings and profits determined without taking into account the following:
(A) The investment company's capital gain net income, as defined in 26 U.S.C.A. § 1222(9) (relating to other terms relating to capital gains and losses), if any.
(B) Items of interest derived by the investment company from an obligation that is statutorily free from taxation by the Commonwealth.
(C) Items of Pennsylvania exempt-interest dividend paid or credited to the investment company as a shareholder by another investment company.
(D) A distributive share of an item described in clause (B) or (C).
(E) That proportion of an amount otherwise allowable as a deduction in computing the earnings and profits which the total of the items described in clauses (B)--(D) bears to the sum of the total and other gross income of the investment company--exclusive of its capital gain net income.
(ii) The amount of the investment company's capital gain net income.
(iii) The aggregate amount, if any, of Pennsylvania exempt-interest dividend distributions paid or credited to shareholders for the immediately preceding taxable year.
(2) By reducing, but not below zero, the account for the aggregate amount, if any, of distributions paid or credited out of earnings and profits for the immediately preceding taxable year.
(e) Special rule.
(1) For purposes of subsection (d), the amount of an investment company's accumulated income account as of the beginning of its 1993 taxable year, the aggregate amount of Pennsylvania exempt-interest dividend distributions paid or credited to shareholders for the 1992 taxable year, and the aggregate amount of distributions paid or credited out of earnings and profits for the 1992 taxable year shall be deemed to be zero, if, at the close of its 1992 taxable year, one of the following applies:
(i) The investment company was unincorporated and had no power under its governing instruments to vary its investments except to eliminate unsafe investments and investments not consistent with the preservation of the capital or tax status of the investments of the fund, honor redemption orders, meet anticipated redemption requirements, negate gains from discount purchases, maintain a constant net asset value per unit under, and in compliance with, an order or rule of the United States Securities and Exchange Commission, or defray normal administrative expenses.
(ii) The investment company was a partnership.
(iii) The investment company had no undistributed earnings and profits.
(2) Otherwise, the amount of an investment company's accumulated income account as of the beginning of its 1993 taxable year shall be the amount that would have been standing to the account at the close of the investment company's 1992 taxable year had the investment company always maintained such an account in accordance with this section.
CHAPTER 117. RETURN AND PAYMENT OF TAX § 117.18. Return of information as to payment in excess of $10.
(a) A person making a distribution, to a taxpayer, out of a pension or profit sharing plan, other than by reason of death, disability or retirement, shall make an annual information return, to the Department of Revenue, Bureau of Personal Income Tax, with respect to the distribution, to the extent that the distribution exceeds that portion contributed to the plan by the taxpayer.
(1) Information returns shall be filed on or before February 28 of each year for distributions made to a taxpayer in the preceding calendar year.
(2) Separate information returns shall be prepared for each taxpayer receiving a distribution, and the return shall substantially conform to Internal Revenue Service Form 1099R.
(i) The returns shall show the following:
(A) The name, address and identification number of the person making the distribution.
(B) The name, address and Social Security number of the taxpayer receiving the distribution.
(C) The amount or value of the distribution made and the amounts contributed by the employer and by the employe, respectively.
(ii) A copy of the return shall be supplied to the employe.
(3) With prior approval of the Director of the Pennsylvania Personal Income Tax Bureau, a person required to make information returns may be permitted to submit a magnetic tape or computer printed listing in lieu of copies of Form 1099R.
(b) On or before February 28 of each year, a Pennsylvania information return for recipients of dividends and other taxable or nontaxable distributions on shares of stock or beneficial interests shall be made by any of the following:
(1) An investment company making a distribution exceeding $10 to a taxpayer or other investment company if the investment company making payment received interest exempt from tax under the laws of the Commonwealth but is not a regulated investment company, as defined at 26 U.S.C.A. § 851 (relating to definition of regulated investment company).
(2) A corporation that has an election in effect under 26 U.S.C.A. § 1362 (relating to election; revocation; termination) making a distribution exceeding $10 to a taxpayer if the corporation is not required to make an information return on REV Form 20-S, ''Pennsylvania S Corporation Information Return.''
(3) An investment company making a distribution exceeding $10 to a taxpayer or other investment company if the investment company making payment received interest exempt from State taxation under the laws of the United States.
(4) A regulated investment company, as defined in paragraph (1), making a distribution exceeding $10 to a taxpayer or other investment company if the regulated investment company making payment received interest on State or local bonds that is taxable under this article.
(5) A corporation, association, business trust or investment company making a distribution exceeding $10 to a taxpayer if it is not required to make an information return on Federal Form 1099-DIV.
(6) A personal holding company or foreign corporation, each as defined at 26 U.S.C.A. § 7701 (relating to definitions), making a distribution exceeding $10 to a taxpayer.
(c) Pennsylvania information return. The Pennsylvania information return shall be made in one of the following ways:
(1) The Pennsylvania information return may be made on a Pennsylvania Form 99-DIV ''Information Return for Recipients of Dividends and Distributions'' or other form acceptable to the Department and shall show the following:
(i) The payer's name, address and Federal identification number.
(ii) The recipient's name, address and Federal identification number.
(iii) The amount of dividends, nontaxable distributions, and, in the case of investment companies, Pennsylvania exempt-interest dividends paid.
(2) If a regulated investment company furnishes Federal Form 1099-DIV to a recipient in compliance with Federal Income Tax requirements, the Pennsylvania information return may be made by attaching a separate statement showing the ratio of Pennsylvania exempt-interest dividends paid to total ordinary dividends reported on the Federal form.
(3) If a regulated investment company is not required to furnish Federal Form 1099-DIV, the Pennsylvania information return may be made by separate statement showing the amount of dividends, nontaxable distributions and Pennsylvania exempt-interest dividends paid.
(d) Unless an extension is granted by the Department, on or before February 28 of each calendar year beginning on or after January 1, 1997, an information return shall be furnished to each recipient of distributions who makes a written request therefor or who is one of the following:
(1) A resident individual, estate or trust or other taxpayer.
(2) An investment company.
(e) An investment company, corporation, association, business trust or personal holding company may rely on its business records in determining the identity and place of residence of recipients.
CHAPTER 125. (RESERVED) § 125.11. (Reserved).
§ 125.12. (Reserved).
§ 125.13. (Reserved).
§ 125.14. (Reserved).
§ 125.15. (Reserved).
[Pa.B. Doc. No. 96-289. Filed for public inspection March 1, 1996, 9:00 a.m.]
