‘‘(10) make grants to nonprofit organizations to
disseminate information to rural municipalities,
small municipalities, and municipalities that meet
the affordability criteria established under section
603(i)(2) by the State in which the municipality is
located with respect to planning, design, construc-
tion, and operation of publicly owned treatment
works and decentralized wastewater treatment sys-
tems.’’.
(b) AUTHORIZATION OF APPROPRIATIONS.—Section
104(u) (33 U.S.C. 1254(u)) is amended—
(1) by striking ‘‘and (6)’’ and inserting ‘‘(6)’’;
and
(2) by inserting before the period at the end the
following: ‘‘(7) not to exceed $75,000,000 for each
of fiscal years 2003 through 2007 for carrying out
subsections (b)(3), (b)(8), (b)(9), and (b)(10), ex-
cept that not less than 20 percent of the amounts
appropriated pursuant to this paragraph in a fiscal
year shall be used for carrying out subsections
(b)(8), (b)(9), and (b)(10)’’.
(c) COMPETITIVE
PROCEDURES
FOR
AWARDING
GRANTS.—Section 104 (33 U.S.C. 1254(b)) is amended
by adding at the end the following:
‘‘(v) COMPETITIVE PROCEDURES
FOR AWARDING
GRANTS.—The Administrator shall establish procedures
that, to the maximum extent practicable, promote com-
petition and openness in the award of grants to nonprofit
private agencies, institutions, and organizations under this
section.’’.
SEC. 112. STATE MANAGEMENT ASSISTANCE.
Section 106(a) (33 U.S.C. 1256(a)) is amended—
(1) by striking ‘‘and’’ at the end of paragraph
(1);
(2) by striking the semicolon at the end of
paragraph (2) and inserting ‘‘; and’’; and
(3) by inserting after paragraph (2) the fol-
lowing:
‘‘(3) such sums as may be necessary for each
of 
fiscal 
years 
1991 
through 
2002, 
and
$250,000,000 for each of fiscal years 2003 through
2007;’’.
Subtitle B—State Water Pollution
Control Revolving Funds
SEC. 121. GENERAL AUTHORITY FOR CAPITALIZATION
GRANTS.
Section 601(a) (33 U.S.C. 1381(a)) is amended by
striking ‘‘for providing assistance’’ and all that follows
through the period at the end and inserting the following:
‘‘to accomplish the objectives, goals, and policies of this
Act by providing assistance for projects and activities
identified in section 603(c).’’.
SEC. 122. CAPITALIZATION GRANT AGREEMENTS.
(a) REQUIREMENTS FOR CONSTRUCTION OF TREAT-
MENT
WORKS.—Section 
602(b)(6) 
(33 
U.S.C.
1382(b)(6)) is amended—
(1) by striking ‘‘before fiscal year 1995’’; and
(2) by striking ‘‘201(b)’’ and all that follows
through ‘‘513’’ and inserting ‘‘211, 218, and
511(c)(1)’’.
(b) REPORTING INFRASTRUCTURE ASSETS.—Section
602(b)(9) (33 U.S.C. 1382(b)(9)) is amended by striking
‘‘standards’’ and inserting ‘‘standards, including stand-
ards relating to the reporting of infrastructure assets’’.
(c) ADDITIONAL REQUIREMENTS.—Section 602(b)
(33 U.S.C. 1382(b)) is amended—
(1) by striking ‘‘and’’ at the end of paragraph
(9);
(2) by striking the period at the end of para-
graph (10) and inserting a semicolon; and
(3) by adding at the end the following:
‘‘(11) the State will establish, maintain, invest,
and credit the fund with repayments, such that the
fund balance will be available in perpetuity for pro-
viding financial assistance in accordance with this
title;
‘‘(12) any fees charged by the State to recipi-
ents of assistance will be deposited in the fund for
the sole purpose of financing the cost of admin-
istering the fund;
‘‘(13) beginning in fiscal year 2004, the State
will include as a condition of providing assistance
under section 603(c)(1) that the recipient of such
assistance—
‘‘(A) conduct a physical and operational
analysis of any system proposed for repair, re-
placement, or expansion;
‘‘(B) study and evaluate the cost and effec-
tiveness of innovative and alternative processes,
materials, and techniques for carrying out
projects and activities eligible for such assist-
ance under section 603(c), and select, to the ex-
tent practicable, projects and activities that
more efficiently use energy and natural and fi-
nancial resources or provide greater environ-
mental benefits;
‘‘(C) analyze the cost and effectiveness of
alternative management and financing ap-
proaches (including rate structures, issuance of
bonds, restructuring, regional alternatives, con-
solidation, and public-private partnerships) for
carrying out a project or activity for which as-
sistance is provided under this title, taking into
account the cost of operating and maintaining
the project or activity over its life, as well as
the cost of constructing the project or activity;
and
‘‘(D) develop and implement a plan for
maintaining, repairing, and, as necessary, re-
placing any infrastructure to be constructed
with assistance under this title, and for funding
such maintenance, repair, and replacement;
‘‘(14) the State will not provide assistance
under this title for the construction of publicly
owned treatment works unless the recipient of such
assistance has adopted or will adopt a system of
charges or dedicated ad valorem taxes sufficient to
pay, at a minimum, the costs of operation and main-
tenance (including replacement) of any wastewater
service provided by the recipient, and will otherwise
comply with section 204(b)(1);
‘‘(15) the State will not provide assistance
under this title for the construction of publicly
owned treatment works unless the recipient of such
assistance has the legal, institutional, managerial,
and financial capability to ensure adequate construc-
tion, operation, and maintenance of treatment works
throughout the recipient’s jurisdiction; and
‘‘(16) the State will use at least 15 percent of
the amount of each capitalization grant received by
the State under this title after September 30, 2003,
to provide assistance to municipalities of fewer than
20,000 individuals that meet the affordability cri-
teria established by the State under section
603(i)(2) for activities included on the State’s pri-
ority list established under section 603(g), to the ex-
tent that there are sufficient applications for such
assistance.’’.
SEC. 123. WATER POLLUTION CONTROL REVOLVING LOAN
FUNDS.
(a) PROJECTS AND ACTIVITIES ELIGIBLE FOR AS-
SISTANCE.—Section 603(c) (33 U.S.C. 1383(c)) is amend-
ed to read as follows:
‘‘(c) PROJECTS AND ACTIVITIES ELIGIBLE FOR AS-
SISTANCE.—The amounts of funds available to each State
water pollution control revolving fund shall be used only
for providing financial assistance—
‘‘(1) to any municipality, intermunicipal, inter-
state, or State agency for construction of publicly
owned treatment works;
‘‘(2) for the implementation of a management
program established under section 319;
‘‘(3) for development and implementation of a
conservation and management plan under section
320;
‘‘(4) for the implementation of lake protection
programs and projects under section 314;
‘‘(5) for decentralized wastewater treatment
systems that treat domestic sewage;
‘‘(6) 
for 
measures 
to 
reduce 
municipal
stormwater runoff;
‘‘(7) for measures to reduce the demand for
publicly owned treatment works capacity through
water conservation;
‘‘(8) for measures to increase the security of
publicly owned treatment works; and
‘‘(9) for the development and implementation of
watershed projects meeting the criteria set forth in
section 121.’’.
(b) 
EXTENDED
REPAYMENT
PERIOD.—Section
603(d)(1) (33 U.S.C. 1383(d)(1)) is amended—
(1) in subparagraph (A) by inserting after ‘‘20
years’’ the following: ‘‘or, in the case of a munici-
pality that meets the affordability criteria estab-
lished under section 603(i)(2) by the State in which
the municipality is located, the lesser of 30 years or
the design life of the project to be financed with the
proceeds of the loan’’; and
(2) in subparagraph (B) by striking ‘‘not later
than 20 years after project completion’’ and insert-
ing ‘‘upon the expiration of the term of the loan’’.
(c) ADMINISTRATIVE EXPENSES.—Section 603(d)(7)
(33 U.S.C. 1383(d)(7)) is amended by inserting before the
period at the end the following: ‘‘, $400,000 per year, or
1⁄5 percent per year of the current valuation of the fund,
whichever amount is greatest, plus the amount of any fees
collected by the State for such purpose’’.
(d) TECHNICAL
AND PLANNING ASSISTANCE
FOR
SMALL SYSTEMS.—Section 603(d) (33 U.S.C. 1383(d)) is
amended—
(1) by striking ‘‘and’’ at the end of paragraph
(6);
(2) by striking the period at the end of para-
graph (7) and inserting ‘‘; and’’; and
(3) by adding at the end the following:
‘‘(8) to provide to small treatment works (as
defined in section 607) technical and planning as-
sistance and assistance in financial management,
user fee analysis, budgeting, capital improvement
planning, facility operation and maintenance, repair
schedules, and other activities to improve wastewater
treatment plant management and operations; except
that such amounts shall not exceed 2 percent of
grant awards to such fund under this title.’’.
(e) ADDITIONAL SUBSIDIZATION.—Section 603 (33
U.S.C. 1383) is amended by adding at the end the fol-
lowing:
‘‘(i) ADDITIONAL SUBSIDIZATION.—
‘‘(1) IN
GENERAL.—In any case in which a
State provides assistance under subsection (d), the
State may provide additional subsidization, including
forgiveness of principal and negative interest loans,
for projects and activities eligible for assistance
under section 603(c)(1)—
‘‘(A) to benefit a municipality that meets
the State’s affordability criteria established
under paragraph (2);
‘‘(B) to benefit a municipality that does
not meet the State’s affordability criteria if the
recipient—
‘‘(i) seeks additional subsidization to
benefit individual ratepayers in the resi-
dential user rate class;
‘‘(ii) demonstrates to the State that
such ratepayers will experience a signifi-
cant hardship from the increase in rates
necessary to finance the activity; and
‘‘(iii) ensures, as part of an assistance
agreement between the State and the re-
cipient, that the additional subsidization
provided under this paragraph is directed
through a user charge rate system (or
other appropriate method) to such rate-
payers; or
‘‘(C) to implement alternative processes,
materials, and techniques (including non-
structural protection of surface waters, new or
improved methods of waste treatment, and pol-
lutant trading) that may result in cost savings
or increased environmental benefit when com-
pared to standard processes, materials, and
techniques.
‘‘(2) AFFORDABILITY CRITERIA.—
‘‘(A) ESTABLISHMENT.—On or before Sep-
tember 30, 2003, and after providing notice
and an opportunity for public comment, a State
shall establish affordability criteria to assist in
identifying municipalities that would experience
a significant hardship raising the revenue nec-
essary to finance a project or activity eligible
for assistance under section 603(c)(1) if addi-
tional subsidization is not provided. Such cri-
teria shall be based on income data, population
trends, and other data determined relevant by
the State.
‘‘(B) EXISTING CRITERIA.—If a State has
previously established, after providing notice
and an opportunity for public comment, afford-
ability criteria that meet the requirements of
subparagraph (A), the State may use the cri-
teria for the purposes of this subsection. For
purposes of this Act, any such criteria shall be
treated as affordability criteria established
under this paragraph.
‘‘(C) INFORMATION TO ASSIST STATES.—
The Administrator may publish information to
assist States in establishing affordability cri-
teria under subparagraph (A).
‘‘(3) PRIORITY.—A State may give priority to a
recipient for a project or activity eligible for funding
under section 603(c)(1) if the recipient meets the
State’s affordability criteria.
‘‘(4) SET-ASIDE.—
‘‘(A) IN GENERAL.—In any fiscal year in
which the Administrator has available for obli-
gation more than $1,400,000,000 for the pur-
poses of this title, a State shall provide addi-
tional subsidization under this subsection in the
amount specified in subparagraph (B) to eligi-
ble entities described in paragraph (1) for
projects and activities identified in the State’s
intended use plan prepared under section
606(c) as projects and activities to be sup-
ported, to the extent that there are sufficient
applications for such assistance.
‘‘(B) AMOUNT.—In a fiscal year described
in subparagraph (A), a State shall set aside for
purposes of subparagraph (A) an amount not
less 
than 
percent 
of 
the 
difference
between—
‘‘(i) the total amount that would have
been allotted to the State under section
604 for such fiscal year if the amount
available to the Administrator for obliga-
tion under this title for such fiscal year
had been equal to $1,400,000,000; and
‘‘(ii) the total amount allotted to the
State under section 604 for such fiscal
year.
‘‘(5) LIMITATION.—The total amount of addi-
tional subsidization provided under this subsection
by a State may not exceed 30 percent of the total
amount of capitalization grants received by the State
under this title in fiscal years beginning after Sep-
tember 30, 2002.’’.
SEC. 124. ALLOTMENT OF FUNDS.
(a) IN
GENERAL.—Section 604(a) (33 U.S.C.
1384(a)) is amended to read as follows:
‘‘(a) ALLOTMENTS.—
‘‘(1) FISCAL YEARS 2002 AND 2003.—Sums ap-
propriated to carry out this title for each of fiscal
years 2002 and 2003 shall be allotted by the Admin-
istrator in accordance with section 205(c).
‘‘(2) FISCAL YEAR 2004 AND THEREAFTER.—
Sums appropriated to carry out this title for fiscal
year 2004 and each fiscal year thereafter shall be al-
lotted by the Administrator as follows:
‘‘(A) Amounts up to $1,350,000,000 shall
be allotted in accordance with section 205(c).
‘‘(B) Amounts that exceed $1,350,000,000
shall be allotted in accordance with the formula
developed by the Administrator under sub-
section (d).’’.
(b) FORMULA.—Section 604 (33 U.S.C. 1384) is
amended by adding at the end the following:
‘‘(d) 
FORMULA
BASED
ON
WATER
QUALITY
NEEDS.—Not later than September 30, 2003, and after
providing notice and an opportunity for public comment,
the Administrator shall publish an allotment formula
based on water quality needs in accordance with the most
recent survey of needs developed by the Administrator
under section 516(b).’’.
SEC. 125. INTENDED USE PLAN.
(a) INTEGRATED PRIORITY LIST.—Section 603(g)
(33 U.S.C. 1383(g)) is amended to read as follows:
‘‘(g) PRIORITY LIST.—
‘‘(1) IN GENERAL.—For fiscal year 2004 and
each fiscal year thereafter, a State shall establish or
update a list of projects and activities for which as-
sistance is sought from the State’s water pollution
control revolving fund. Such projects and activities
shall be listed in priority order based on the method-
ology established under paragraph (2). The State
may provide financial assistance from the State’s
water pollution control revolving fund only with re-
spect to a project or activity included on such list.
‘‘(2) METHODOLOGY.—
‘‘(A) IN GENERAL.—Not later than 1 year
after the date of enactment of this paragraph,
and after providing notice and opportunity for
public comment, each State (acting through the
State’s water quality management agency and
other appropriate agencies of the State) shall
establish a methodology for developing a pri-
ority list under paragraph (1).
‘‘(B) PRIORITY
FOR
PROJECTS
AND
AC-
TIVITIES
THAT
ACHIEVE
GREATEST
WATER
QUALITY
IMPROVEMENT.—In developing the
methodology, the State shall seek to achieve the
greatest degree of water quality improvement,
taking into consideration section 602(b)(5), sec-
tion 603(i)(3), and whether such water quality
improvements would be realized without assist-
ance under this title.
‘‘(C) 
CONSIDERATIONS
IN
SELECTING
PROJECTS
AND
ACTIVITIES.—In determining
which projects and activities will achieve the
greatest degree of water quality improvement,
the State shall consider—
‘‘(i) information developed by the
State under sections 303(d) and 305(b);
‘‘(ii) the State’s continuing planning
process developed under section 303(e);
and
‘‘(iii) the State’s management pro-
gram developed under section 319.
‘‘(D) EXISTING
METHODOLOGIES.—If a
State has previously developed, after providing
notice and an opportunity for public comment,
a methodology that meets the requirements of
this paragraph, the State may use the method-
ology for the purposes of this subsection.’’.
(b) INTENDED USE PLAN.—Section 606(c) (33
U.S.C. 1386(c)) is amended—
(1) in the matter preceding paragraph (1) by
striking ‘‘each State shall annually prepare’’ and in-
serting ‘‘each State (acting through the State’s
water quality management agency and other appro-
priate agencies of the State) shall annually prepare
and publish’’;
(2) by striking paragraph (1) and inserting the
following:
‘‘(1) the State’s priority list developed under
section 603(g);’’;
(3) by striking ‘‘and’’ at the end of paragraph
(4);
(4) by striking the period at the end of para-
graph (5) and inserting ‘‘; and’’; and
(5) by adding at the end the following:
‘‘(6) if the State does not fund projects and ac-
tivities in the order of the priority established under
section 603(g), an explanation of why such a change
in priority is appropriate.’’.
(c) TRANSITIONAL PROVISION.—Before completion
of a priority list based on a methodology established under
section 603(g) of the Federal Water Pollution Control Act
(as amended by this section), a State shall continue to
comply with the requirements of sections 603(g) and
606(c) of such Act, as in effect on the day before the date
of enactment of this Act.
SEC. 126. ANNUAL FEDERAL OVERSIGHT REVIEW.
Section 606(e) (33 U.S.C. 1386(e)) is amended by
adding at the end the following: ‘‘In carrying out an over-
sight review under this subsection, the Administrator may
allow a State to certify, with supporting documentation,
its compliance with the requirements of this title.’’.
SEC. 127. TECHNICAL ASSISTANCE.
Title VI (33 U.S.C. 1381 et seq.) is amended—
(1) by redesignating section 607 as section 608;
and
(2) by inserting after section 607 the following:
‘‘SEC. 607. TECHNICAL ASSISTANCE.
‘‘(a) 
ASSISTANCE
FOR
SMALL
TREATMENT
WORKS.—
‘‘(1) SIMPLIFIED PROCEDURES.—Not later than
1 year after the date of enactment of this section,
the Administrator shall assist the States in estab-
lishing simplified procedures for small treatment
works to obtain assistance under this title.
‘‘(2) PUBLICATION
OF
MANUAL.—Not later
than 2 years after the date of the enactment of this
section, and after providing notice and opportunity
for public comment, the Administrator shall publish
a manual to assist small treatment works in obtain-
ing assistance under this title and publish in the
Federal Register notice of the availability of the
manual.
‘‘(3) SMALL
TREATMENT
WORKS
DEFINED.—
For purposes of this title, the term ‘small treatment
works’ means a treatment works for which a munici-
pality or intermunicipal, interstate, or State agency
seeks assistance under this title and which serves a
population of 20,000 or fewer.
‘‘(b) ASSISTANCE
FOR IMPROVING
THE MANAGE-
MENT OF WATER QUALITY INFRASTRUCTURE AND IN-
CREASING COST-EFFECTIVENESS
OF INFRASTRUCTURE
IMPROVEMENTS.—At the request of any State, the Admin-
istrator shall assist in the development of criteria for a
State to determine compliance with the conditions of fund-
ing assistance established under section 602(b)(13).’’.
SEC. 128. AUTHORIZATION OF APPROPRIATIONS.
Section 608 (as redesignated by section 127 of this
Act) is amended by striking paragraphs (1) through (5)
and inserting the following:
‘‘(1) $2,000,000,000 for fiscal year 2003;
‘‘(2) $3,000,000,000 for fiscal year 2004;
‘‘(3) $4,000,000,000 for fiscal year 2005;
‘‘(4) $5,000,000,000 for fiscal year 2006; and
‘‘(5) $6,000,000,000 for fiscal year 2007.’’.
Subtitle C—General Provisions
SEC. 151. DEFINITION OF TREATMENT WORKS.
Section 502 (33 U.S.C. 1362) is amended by adding
at the end the following:
‘‘(21) The term ‘treatment works’ has the
meaning given that term in section 212.’’.
SEC. 152. FUNDING FOR INDIAN PROGRAMS.
Section 518 (33 U.S.C. 1377) is amended by striking
subsection (c) and inserting the following:
‘‘(c) RESERVATION OF FUNDS.—
‘‘(1) IN GENERAL.—For fiscal year 1987 and
each fiscal year thereafter, the Administrator shall
reserve, before allotments to the States under sec-
tion 604(a), not less than 0.5 percent and not more
than 1.5 percent of the funds made available under
section 207.
‘‘(2) USE OF FUNDS.—Funds reserved under
this subsection shall be available only for projects
and activities eligible for assistance under section
603(c) to serve—
‘‘(A) Indian tribes;
‘‘(B) former Indian reservations in Okla-
homa (as determined by the Secretary of the
Interior); and
‘‘(C) Native villages (as defined in section
3 of the Alaska Native Claims Settlement Act
(43 U.S.C. 1602)).’’.
TITLE II—PRESERVATION OF
REPORTING REQUIREMENTS
SEC. 201. PRESERVATION OF REPORTING REQUIREMENTS.
Section 3003(a)(1) of the Federal Reports Elimi-
nation and Sunset Act of 1995 (31 U.S.C. 1113 note)
does not apply to any report required to be submitted
under any of the following provisions of law:
(1) EXEMPTIONS
FROM
WATER
POLLUTION
CONTROL
REQUIREMENTS
FOR
EXECUTIVE
AGEN-
CIES.—Section 313(a) of the Federal Water Pollu-
tion Control Act (33 U.S.C. 1323(a)).
(2) GREAT LAKES RESOURCES ON WHICH RE-
SEARCH IS NEEDED.—Section 118(d)(2) of the Fed-
eral Water Pollution Control Act (33 U.S.C.
1268(d)(2)).
(3) NATIONAL
ESTUARY
PROGRAM
ACTIVI-
TIES.—Section 320(j)(2) of the Federal Water Pol-
lution Control Act (33 U.S.C. 1330(j)(2)).
(4) COMPREHENSIVE CONSERVATION AND MAN-
AGEMENT PLAN FOR LONG ISLAND SOUND.—Section
119(c)(7) of the Federal Water Pollution Control
Act (33 U.S.C. 1269(c)(7)).
(5) IMPLEMENTATION OF GREAT LAKES WATER
QUALITY AGREEMENT OF 1978.—Section 118(c)(10)
of the Federal Water Pollution Control Act (33
U.S.C. 1268(c)(10)).
(6) EFFECTS OF POLLUTION ON NATION’S ES-
TUARIES.—Section 104(n)(3) of the Federal Water
Pollution Control Act (33 U.S.C. 1254(n)(3)).
(7) NATIONAL REQUIREMENTS AND COSTS OF
WATER POLLUTION CONTROL.—Section 516 of the
Federal Water Pollution Control Act (33 U.S.C.
1375).
(8) STATUS
OF
WATER
QUALITY
IN
UNITED
STATES LAKES.—Section 314(a)(3) of the Federal
Water Pollution Control Act (33 U.S.C. 1324(a)(3)).
(9) STATE REPORTS ON WATER QUALITY OF
ALL
NAVIGABLE
WATERS.—Section 305(b) of the
Federal Water Pollution Control Act (33 U.S.C.
1315(b)).
(10) LEVEL B PLAN ON ALL RIVER BASINS.—
Section 209(b) of the Federal Water Pollution Con-
trol Act (33 U.S.C. 1289(b)).
(11) REPORTS ON CONTRACTS ENTERED INTO
RELATING TO PROCUREMENT FROM VIOLATORS OF
WATER QUALITY STANDARDS.—Section 508(e) of the
Federal Water Pollution Control Act (33 U.S.C.
1368(e)).
TITLE III—TAX PROVISIONS
SEC. 301. BONDS FOR WATER AND SEWAGE FACILITIES EX-
EMPT FROM VOLUME CAP ON PRIVATE AC-
TIVITY BONDS.
(a) IN GENERAL.—Paragraph (3) of section 146(g)
of the Internal Revenue Code of 1986 (relating to excep-
tion for certain bonds) is amended—
(1) by inserting ‘‘(4), (5),’’ after ‘‘(2),’’, and
(2) by inserting ‘‘facilities for the furnishing of
water, sewage facilities,’’ after ‘‘wharves,’’.
(b) EFFECTIVE DATE.—The amendment made by
this section shall apply to obligations issued after the date
of the enactment of this Act.
SEC. 302. AMOUNTS FROM CERTAIN FEDERAL REVOLVING
FUNDS NOT TREATED AS BOND PROCEEDS
OR REPLACEMENT FOR BOND PROCEEDS
FOR PURPOSES OF ARBITRAGE BOND RULES.
(a) IN GENERAL.—Subsection (a) of section 148 of
the Internal Revenue Code of 1986 (defining arbitrage
bond) is amended by adding at the end the following: ‘‘For
purposes of this section, proceeds of an issue, and
amounts used to replace proceeds of an issue, shall not
include any amount derived from a Federal grant or re-
lated State contribution made in connection with a revolv-
ing fund established in accordance with title VI of the
Federal Water Pollution Control Act or section 1452 of
the Safe Drinking Water Act.’’.
(b) EFFECTIVE DATE.—The amendment made by
this section shall apply to obligations issued or out-
standing after the date of the enactment of this Act, but
shall not apply for purposes of determining the amount
of any payment required to be made on or before such
date to the United States under section 148 of the Inter-
nal Revenue Code of 1986.
Æ