Internal Revenue Bulletin 2010-19 (PDF rendition): IRS Revenue Procedures

Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.

Bulletin No. 201
0-19
May 10, 2010
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
INCOME TAX
Notice 2010–35, page 660.
This notice addresses the new federal refundable tax credit
subsidy option under section 6431(f) of the Code for specified
tax credit bonds under section 54A. The notice provides guid-
ance on the refundable tax credit payment procedures for this
option, required elections, and information reporting. The no-
tice also provides certain interim guidance applicable to speci-
fied tax credit bonds and to Build America Bonds under section
54AA(g).
EXEMPT ORGANIZATIONS
Announcement 2010–31, page 681.
A list is provided of organizations now classified as private foun-
dations.
ADMINISTRATIVE
Rev. Proc. 2010–16, page 664.
This procedure explains how the Service is informed of a
change of address. Rev. Proc. 2001–18 superseded.
Announcement 2010–30, page 668.
This announcement releases the draft of Schedule UTP, accom-
panied by draft instructions, that provides a further explanation
of the Service’s proposal requiring reporting of uncertain tax
positions. The announcement also invites public comment on
the draft schedule and instructions.
Announcement 2010–32, page 681.
This announcement informs taxpayers and practitioners that
the IRS has revised Form 3115,Application for Change in Ac-
counting Method, and its instructions. The Form 3115 (Rev.
December 2009) replaces the December 2003 version. The
announcement also provides a transition period and transition
guidance.
Finding Lists begin on page ii.

The IRS Mission
Provide Americ
a’s taxpayers top quality service by helping them
understand an
d meet their tax responsibilities and by applying
the tax law with
integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, legislation, court decisions, and other items of general
interest. It is published weekly and may be obtained from the
Superintendent of Documents on a subscription basis. Bulletin
contents are compiled semiannually into Cumulative Bulletins,
which are sold on a single-copy basis.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application of
the tax laws, including all rulings that supersede, revoke, mod-
ify, or amend any of those previously published in the Bulletin.
All published rulings apply retroactively unless otherwise indi-
cated. Procedures relating solely to matters of internal man-
agement are not published; however, statements of internal
practices and procedures that affect the rights and duties of
taxpayers are published.
Revenue rulings represent the conclusions of the Service on the
application of the law to the pivotal facts stated in the revenue
ruling. In those based on positions taken in rulings to taxpayers
or technical advice to Service field offices, identifying details
and information of a confidential nature are deleted to prevent
unwarranted invasions of privacy and to comply with statutory
requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—19
86 Code.
This part i
ncludes rulings and decisions based on provisions of
the Intern
al Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B, Leg-
islation and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Secre-
tary (Enforcement).
Part IV
.—Items of General Interest.
This par
t includes notices of proposed rulemakings, disbar-
ment an
d suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index
for the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The c
ontents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
For sale by the Superintendent of Documents, U.S.Government Printing Office, Washington, DC 20402.
May 10, 20102010–19 I.R.B.

Part I. Rulings
and Decisions Under the Internal Revenue Code
of 1986
Section 54AA.
—Build
America Bonds
Anoticethata
ddresses the new Federal refund-
able tax credi
t subsidy option under section 6431(f)
of the Interna
l Revenue Code for specified tax credit
bonds under s
ection 54A. This notice provides guid-
ance on the re
fundable tax credit payment procedures
for this opti
on, required elections, and information
reporting. T
his notice also provides certain interim
guidance ap
plicable to specified tax credit bonds and
to build Ame
rica bonds under section 54AA(g). See
Notice 2010
-35, page 660.
Section 54C.—New Clean
Renewable Energy Bonds
A notice that addresses the new Federal refund-
able tax credit subsidy option under section 6431(f)
of the Internal Revenue Code for specified tax credit
bonds under section 54A. This notice provides guid-
ance on the refundable tax credit payment procedures
for this option, required elections, and information
reporting. This notice also provides certain interim
guidance appl
icable to specified tax credit bonds and
to build Ameri
ca bonds under section 54AA(g). See
Notice 2010-3
5, page 660.
Section 54D.—Qualified
Energy Conservation Bonds
A notice that addresses the new Federal refund-
able tax credit subsidy option under section 6431(f)
of the Internal Revenue Code for specified tax credit
bonds under section 54A. This notice provides guid-
ance on the refundable tax credit payment procedures
for this option, required elections, and information
reporting. This notice also provides certain interim
guidance applicable to specified tax credit bonds and
to build America bonds under section 54AA(g). See
Notice 2010-35, page 660.
Section 54E.—Qualified
Zone Academy Bonds
A notice that addresses the new Federal refund-
able tax credit subsidy option under section 6431(f)
of the Interna
l Revenue Code for specified tax credit
bonds under se
ction 54A. This notice provides guid-
ance on the ref
undable tax credit payment procedures
for this optio
n, required elections, and information
reporting. T
his notice also provides certain interim
guidance app
licable to specified tax credit bonds and
to build Amer
ica bonds under section 54AA(g). See
Notice 2010-
35, page 660.
Section 54F.—Qualified
School Construction Bonds
A notice that addresses the new Federal refund-
able tax credit subsidy option under section 6431(f)
of the Internal Revenue Code for specified tax credit
bonds under section 54A. This notice provides guid-
ance on the refundable tax credit payment procedures
for this option, required elections, and information
reporting. This notice also provides certain interim
guidance applicable to specified tax credit bonds and
to build America bonds under section 54AA(g). See
Notice 2010-35, page 660.
2010–19 I.R.B.659May 10, 2010

Part III. Administrative, Procedural, and Miscellaneous
Direct Payment Subsidy
Option for Certain Qualified
Tax Credit Bonds and Build
America Bonds
Notice 2010–35
SECTION 1. PURPOSE
This notice addresses the new Federal
refundable tax credit subsidy option (also
referred to hereafter as the direct payment
subsidy option) under § 6431(f) of the In-
ternal Revenue Code (the “Code”) for cer-
tain qualified tax credit bonds under § 54A.
This notice provides guidance on the re-
fundable tax credit payment procedures for
this option, required elections, information
reporting, and certain other interim guid-
ance. This notice describes regulations
that the Treasury Department and the IRS
expect to issue. Pending the promulga-
tion and effective date of future adminis-
trative or regulatory guidance, this notice
provides certain interim guidance applica-
ble to these qualified tax credit bonds un-
der § 54A and also to build America bonds
under § 54AA(g) (Build America Bonds)
on which taxpayers may rely. This notice
is intended to facilitate prompt implemen-
tation of this borrowing option and to en-
able issuers to begin issuing these bonds
for qualified purposes.
SECTION 2. BACKGROUND
2.1.Introduction
Section 301 of the Hiring Incentives
to Restore Employment Act, Pub. L. No.
111–147, 124 Stat. 71 (2010) (the “HIRE
Act”)addedsubsection(f)to§6431of
the Code, which authorizes issuers to elect
irrevocably to receive Federal direct pay-
ments of allowances of refundable tax
credits to subsidize a prescribed portion
of their borrowing costs instead of the
Federal tax credits that otherwise would
be allowed to holders of certain qualified
tax credit bonds under § 54A.
In particular, the direct payment sub-
sidy option applies to the following speci-
fied tax credit bonds that meet the require-
ments to be qualified tax credit bonds un-
der § 54A: (1) new clean renewable en-
ergy bonds (as defined in § 54C); (2) qual-
ified energy conservation bonds (as de-
fined in § 54D); (3) qualified zone acad-
emybonds(asdefinedin§54E);and(4)
qualified school construction bonds (as de-
fined in § 54F). The direct payment sub-
sidy option applies to the specified tax
credit bonds only if the bonds are issued
after the date of enactment of the HIRE
Act (March 18, 2010) and the issuer makes
an irrevocable election to apply this op-
tion under § 6431(f). (The specified tax
credit bonds that meet the requirements for
the direct payment subsidy option under
§ 6431(f) are referred to in this notice as
“Direct Pay Tax Credit Bonds.”)
In general, under § 6431(f)(1)(C), Di-
rect Pay Tax Credit Bonds provide a Fed-
eral borrowing subsidy through a refund-
able tax credit paid directly to issuers with
respect to each interest payment due un-
der the bonds in an amount equal to the
lesser of: (i) the amount of interest payable
under such bonds on such interest pay-
ment date, or (ii) the amount of interest
(100 percent of the amount of such interest
on qualified school construction bonds and
qualified zone academy bonds and 70 per-
cent of the amount of such interest on new
clean renewable energy bonds and qual-
ified energy conservation bonds, respec-
tively) which would have been payable
under such bonds on such interest pay-
ment date if the interest were determined at
the tax credit bond rate determined under
§ 54A(b)(3) for qualified tax credit bonds.
2.2.Direct Pay Tax Credit Bond
Requirements
Direct Pay Tax Credit Bonds have dif-
ferent program requirements and different
levels of Federal borrowing subsidies de-
pending on the type of qualified tax credit
bond. Section 54A imposes specific pro-
gram requirements for each defined type
of qualified tax credit bond (e.g.,quali-
fied purposes to finance public school or
energy projects). In addition, § 54A(d)
imposes general program requirements
on all qualified tax credit bonds, partic-
ularly requirementsin § 54A(d)(2), (3),
(4), (5), and (6) relating to expenditures,
information reporting, arbitrage invest-
ment restrictions, maturity limitations, and
prohibitions against financial conflicts of
interest, respectively.
Section 54C(a) provides that the term
“new clean renewable energy bond” means
any bond issued as part of an issue if: (1)
100 percent of the available project pro-
ceeds of such issue are to be used for capi-
tal expenditures incurred by governmental
bodies, public power providers, or cooper-
ative electric companies for one or more
qualified renewable energy facilities; (2)
the bond is issued by a qualified issuer;
and (3) the issuer designates such bond
for purposes of § 54C. For more informa-
tion on new clean renewable energy bonds,
see § 54C and Notice 2009–33, 2009–17
I.R.B. 865 (April 27, 2009).
Section 54D(a) provides that the term
“qualified energy conservation bond”
means any bond issued as part of an issue
if: (1) 100 percent of the available project
proceeds of such issue are to be used for
one or more qualified conservation pur-
poses; (2) the bond is issued by a State or
local government; and (3) the issuer des-
ignates such bond for purposes of § 54D.
For more information on qualified energy
conservation bonds, see § 54D and Notice
2009–29, 2009–16 I.R.B. 849 (April 20,
2009).
Section 54E(a) provides that the term
“qualified zone academy bond” means any
bond issued as part of any issue if: (1) 100
percent of the available project proceeds of
such issue are to be used for a qualified
purpose with respect to a qualified zone
academy established by an eligible local
education agency; (2) the bond is issued
by a State or local government within the
jurisdiction of which such academy is lo-
cated; and (3) the issuer designates such
bond for purposes of § 54E and makes cer-
tain certifications with respect to receiv-
ing written assurances for meeting the pri-
vate business contribution requirement of
§ 54E(b) and receiving written approval of
the eligible local education agency for the
bond issue. For more information on qual-
ified zone academy bonds, see § 54E, No-
tice 2009–30, 2009–16 I.R.B. 852 (April
20, 2009), and Notice 2010–22, 2010–10
I.R.B. 435 (March 8, 2010).
Section 54F(a) provides that the term
“qualified school construction bond”
means any bond issued as part of an issue
if: (1) 100 percent of the available project
proceeds of such issue are to be used for
May 10, 20106602010–19 I.R.B.

the construction, rehabilitation, or repair
of a public school facility or for the acqui-
sition of land on which such a facility is to
be constructed with part of the proceeds of
such issue; (2) the bond is issued by a State
or local government within the jurisdiction
of which such school is located; and (3)
the issuer designates such bond for pur-
poses of § 54F. For more information on
qualified school construction bonds, see
§ 54F, Notice 2009–35, 2009–17 I.R.B.
876 (April 27, 2009), and Notice 2010–17,
2010–14 I.R.B. 519 (April 5, 2010).
2.3.Amount of Refundable Credit
Payment
Section 6431(f)(1)(A) provides that, in
applying the refundable credit payment
provisions of § 6431, a Direct Pay Tax
Credit Bond is treated as a qualified bond.
Section 6431(b) provides generally that
with respect to each interest payment date
on a qualified bond the Treasury Depart-
ment shall pay to the issuer of such bond
(or to any person who makes such inter-
est payments on behalf of the issuer) an
amount equal to the amount of the refund-
able credit allowed under § 6431(b).
Section 6431(f)(1)(C) provides that, for
a Direct Pay Tax Credit Bond that is a qual-
ified zone academy bond or a qualified
school construction bond, the amount of
the refundable credit payment determined
under § 6431(b) with respect to any inter-
est payment date under the bond is equal
to the lesser of: (i) 100 percent of the
amount of interest payable under the bond
on such date; or (ii) 100 percent of the
amount of interest which would have been
payable under such bond on such date if
such interest were determined at the appli-
cable tax credit bond rate determined un-
der § 54A(b)(3).
Section 6431(f)(2) provides for a re-
duced amount of refundable credit pay-
ment for a Direct Pay Tax Credit Bond
that is a new clean renewable energy bond
or a qualified energy conservation bond.
For these bonds, the amount of the pay-
ment determined under § 6431(b) with re-
spect to any interest payment date under
the bond is equal to the lesser of: (i) 100
percent of the amount of interest payable
under the bond on such date; or (ii) 70
percent of the amount of interest which
would have been payable under such bond
on such date if such interest were deter-
mined at the applicable credit rate deter-
mined under § 54A(b)(3).
2.4.Applicable Credit Rate
For purposes of determining the amount
of a refundable credit payment to an is-
suer under § 6431(f)(1)(C)(ii), the appli-
cable credit rate for a qualified tax credit
bond, including a Direct Pay Tax Credit
Bond, is determined under § 54A(b)(3).
Section 54A(b)(3) provides that the appli-
cable credit rate is the rate which the Trea-
sury Department estimates will permit the
issuance of qualified tax credit bonds with
a specified maturity or redemption date
without discount and without interest cost
to the qualified issuer.
1
Under § 54A(b)(3), the applicable
credit rate for a qualified tax credit bond,
including a Direct Pay Tax Credit Bond,
is determined as of the first day on which
there is a binding, written contract for the
sale or exchange of the bond. The appli-
cable credit rate for any such bond is the
tax credit bond rate applicable for quali-
fied tax credit bonds under § 54A that is
published for that date by the Bureau of
Public Debt on its Internet site for State
and Local Government Series securities
at:https://www.treasurydirect.gov.For
more information on applicable tax credit
bond rate determinations by the Treasury
Department, see Notice 2009–15, 2009–6
I.R.B. 449 (February 9, 2009).
2.5.Maximum Maturity
The maximum term of a qualified tax
credit bond, including a Direct Pay Tax
Credit Bond, is the maximum term de-
termined by the Treasury Department
under § 54A(d)(5) for purposes of qual-
ified tax credit bonds generally. Section
54A(d)(5)(B) provides that during each
calendar month, the Treasury Department
shall determine the maximum term per-
mitted under § 54A(d)(5) for bonds issued
during the following calendar month. The
maximum term is the term which the Trea-
sury Department estimates will result in
the present value of the obligation to repay
the principal on the bond being equal to
50 percent of the face amount of the bond.
The maximum term is determined under
§ 54A(d)(5) by using a discount rate equal
to 110 percent of the long-term adjusted
AFR, compounded semi-annually, for the
month in which the bond is sold. For this
purpose, a bond is “sold” on the first day
on which there is a binding, written con-
tract for the sale or exchange of the bond.
The maximum term for a qualified tax
credit bond, including a Direct Pay Tax
Credit Bond, is published daily by the Bu-
reau of Public Debt on its Internet site for
State and Local Government Series secu-
rities at:https://www.treasurydirect.gov.
2.6.Sinking Fund Yield
Section 54A(d)(4)(C) provides that an
issue of qualified tax credit bonds, includ-
ing bonds that meet the additional require-
ments for Direct Pay Tax Credit Bonds,
shall not be treated as failing to meet the
arbitrage requirementsof§148byreason
of any fund which is expected to be used
to repay the issue if: (i) the fund is funded
at a rate not more rapid than equal annual
installments; (ii) the fund is funded in a
manner reasonably expected to result in an
amount not greater than an amount neces-
sary to repay the issue; and (iii) the yield on
such fund is not greater than the discount
rate determined under § 54A(d)(5)(B) (the
“permitted sinking fund yield”).
The permitted sinking fund yield is
determined under § 54A(d)(5)(B) by us-
ing a rate equal to 110 percent of the
long-term adjusted AFR, compounded
semi-annually, for the month in which
the bond is sold. The IRS publishes the
long-term adjusted AFR, compounded
semi-annually, each month in a revenue
ruling published in the Internal Revenue
Bulletin. The Bureau of Public Debt pub-
lishes the permitted sinking fund yield for
each month on its Internet site for State
and Local Government Series securities
at:https://www.treasurydirect.gov.
1
The Conference Report to the American Recovery and Reinvestment Act of 2009 (“ARRA”) states the following regarding credit rate determinations under § 54A: “Given the differences in
credit quality and other characteristics of individual issuers, the Secretary cannot set credit rates in a manner that will allow each issuer to issuetax credit bonds at par.” H.R. Conf. Rep. No,
111–16 (“ARRA Conf. Rep.”) at 592, n. 145 (Feb. 12, 2009). The ARRA Conf. Rep. further states: “The Secretary determines credit rates for tax credit bonds based on general assumptions
about credit quality of the class of potential eligible issuers and such other factors as the Secretarydeems appropriate. The Secretary may determine credit rates based on general credit market
yield indexes and credit ratings.”Id.at 592.
2010–19 I.R.B.661May 10, 2010

2.7.Certain Other Applicable Rules for
Refundable Credit Payments
Section 6431(c) provides that, in ap-
plying the arbitrage investment restric-
tions under § 148 to a Direct Pay Tax
Credit Bond, the yield on the bond is re-
duced by the amount of the refundable
credit allowed under § 6431(a). Section
6431(f)(1)(D) provides that, in the case of
a Direct Pay Tax Credit Bond, interest on
any such bond shall be includible in gross
income. Section 6431(f)(1)(E) provides
that, in the case of a Direct Pay Tax Credit
Bond, no credit shall be allowed under
§ 54A with respect to the bond. Section
6431(f)(1)(F) provides that, in the case of a
Direct Pay Tax Credit Bond, any payment
made under § 6431(b) shall not be includi-
ble as income for purposes of the Code.
Section § 6431(f)(1)(G) provides that the
deduction otherwise allowed under the
Code to the issuer of a Direct Pay Tax
Credit Bond with respect to interest paid
under the bond shall be reduced by the
amount of the payment made under § 6431
with respect to that interest. For further
information regarding the tax character
and procedural framework for refundable
credit payments under § 6431, see Section
3.2 of Notice 2009–26, 2009–16 I.R.B.
833 (April 20, 2009), regarding build
America bonds.
2.8.General Application of Provisions
of § 54A
Except as expressly modified by
§ 6431(f) in disallowing the credit un-
der § 54A and in providing the payment
terms of refundable credit payments, the
requirements for qualified tax credit bonds
under § 54A apply to Direct Pay Tax
Credit Bonds, including, without limita-
tion, provisions relating to expenditures
under § 54A(d)(2), information reporting
under § 54A(d)(3), arbitrage investment
restrictions under § 54A(d)(4), maturity
limitations under § 54A(d)(5), prohibi-
tion against financialconflicts of interest
under § 54A(d)(6), and definitions under
§ 54A(e)(2)-(4).
SECTION 3. REFUNDABLE CREDIT
PAYMENT PROCEDURES FOR
DIRECT PAY TAX CREDIT BONDS
3.1.In General
The IRS and the Treasury Department
plan to implement the refundable credit
payment procedures for Direct Pay Tax
Credit Bonds in order to be able to process
requests for refundable credit payments
with respect to interest payments due on or
after September 1, 2010, to enable issuers
to begin issuing these bonds for quali-
fied purposes. The IRS and the Treasury
Department expect that Form 8038–CP,
Return for Credit Payments to Issuers of
Qualified Bonds, revised to take into ac-
count payment of the refundable credit
payments with respect to Direct Pay Tax
Credit Bonds, will be available on the IRS
web site athttp://www.irs.gov/app/pick-
list/list/formsInstructions.htmlon or be-
fore June 25, 2010. Effective on its
release, issuers of build America bonds,
recovery zone economic development
bonds, and Direct Pay Tax Credit Bonds
arerequiredtosubmittotheIRSthere-
vised Form 8038–CP to request payment
of a refundable credit. Revised Form
8038–CP will be processed on receipt for
build America bonds and recovery zone
economic development bonds. The IRS
will be prepared to process the revised
Form 8038–CP for Direct Pay Tax Credit
Bonds no later than July 12, 2010, and to
make timely refundable credit payments
with respect to bond interest payment dates
on Direct Pay Tax Credit Bonds that are
on or after September 1, 2010. Issuers of
Direct Pay Tax Credit Bonds with interest
payment dates prior to September 1, 2010,
may submit a single Form 8038–CP for the
full amount of the refundable credit pay-
ment with respect to interest paid on those
dates subject to the following: for pur-
poses of the due date and the processing of
Form 8038–CP, all such interest shall be
deemed to have been paid on, and the first
date treated as an interest payment date for
such bonds shall be, September 1, 2010. A
Form 8038–CP must be filed with respect
to each issue of Direct Pay Tax Credit
Bonds. Form 8038–CP may be filed only
if the Direct Pay Tax Credit Bonds with
respect to which the form is filed meet all
the requirements for the allowance of the
refundable credit under § 6431(a). For
more information on refundable credit
payment procedures, see the revised In-
structions for Form 8038–CP.
3.2.Fixed Rate Bonds
In general, for fixed rate bonds, upon
receipt of a timely filed Form 8038–CP
requesting payment of the credit, such
amount will be paid contemporaneously
with the applicable interest payment date.
For fixed rate bonds, the due date for an
issuer to file a Form 8038–CP is the 45
th
day before the applicable interest payment
date with respect to the bonds. This return,
however, may not be filed earlier than
the 90
th
day before the relevant interest
payment date.
3.3.Variable Rate Bonds.
In general, for variable rate bonds, upon
receipt of a timely filed Form 8038–CP
requesting payment of the credit, such
amount will be paid quarterly on a re-
imbursement basis for interest paid by
the issuer during the quarter that includes
the interest payment date with respect to
which the return requesting payment re-
lates. For variable rate bonds, the due date
for an issuer to file Form 8038–CP is the
45
th
day after the last interest payment
date within the quarterly period for which
reimbursement is requested. If, however,
the issuer knows the interest payment
amount at least 45 days prior to the inter-
est payment date, Form 8038–CP may be
filed within the same timeframe as that
for fixed rate bonds (i.e., no later than 45
days before the interest payment date and
no earlier than 90 daysbefore the interest
payment date). If an issuer of variable
rate bonds files the Form 8038–CP under
the timeframe for fixed rate bonds, the
form will be processed, and the refundable
credit payment will be made, in the same
manner as for fixed rate bonds.
SECTION 4. ELECTIONS TO ISSUE
DIRECT PAY TAX CREDIT BONDS
Subject to updated IRS procedures, an
issuer of Direct Pay Tax Credit Bonds must
make the irrevocable election required by
§ 6431(f)(3)(B) to issue the bonds on its
books and records on or before the issue
date of the bonds.
May 10, 20106622010–19 I.R.B.

SECTION 5. INFORMATION
REPORTING FOR DIRECT PAY TAX
CREDIT BONDS
Section 54A(d)(3) provides that an
issue shall be treated as meeting the re-
quirements of § 54A(d)(3) if the issuer
of Direct Pay Tax Credit Bonds submits
reports similar to the reports required
under § 149(e). The IRS and the Trea-
sury Department expect that an IRS form
for reporting tax credit bonds and Direct
Pay Tax Credit Bonds, new IRS “Form
8038–TC,Information Return for Tax
Credit Bonds and Specified Tax Credit
Bonds,” will be available on the IRS
web site athttp://www.irs.gov/app/pick-
list/list/formsInstructions.htmlon or be-
fore June 25, 2010. Subject to updated
IRS procedures, the IRS expects that, as
ofthedateofpublicreleaseofIRSForm
8038–TC and its Instructions, issuers of
tax credit bonds, including Direct Pay
Tax Credit Bonds, will be required to re-
port the issuance of those bonds on Form
8038–TC in the time and manner con-
templated by this notice, § 149(e), and
Form 8038–TC. The IRS will be prepared
to accept Form 8038–TC for processing
immediately upon its public release.
Generally, Form 8038–TC with respect
to an issue of Direct Pay Tax Credit Bonds
must be filed with the IRS at least 30 days
before the first Form 8038–CP is filed to
request the refundable credit payment for
an interest payment date for that issue. For
Direct Pay Tax Credit Bonds with inter-
est payment dates prior to September 1,
2010, Form 8038–TC may be filed less
than 30 days before filing the first Form
8038–CP provided Form 8038–TC is filed
separately from and prior to the filing of
Form 8038–CP. Issuers should not attach
Form 8038–TC to Form 8038–CP.
Issuers of Direct Pay Tax Credit Bonds
must attach a schedule to Form 8038–TC
which contains the information described
below with respect to the bond issue:
(1) For fixed-rate bonds, attach a com-
plete debt service schedule entitled “Fixed
Rate Bond—Debt Service Schedule,” that
provides a list of each interest payment
date, the total interest payable on each such
date, the total principal amount of bonds
expected to be outstanding on each such
date, the refundable credit payment ex-
pected to be requested from the IRS as al-
lowed under section 2.3 of this Notice with
respect to each such date, and the earliest
the bonds can be called.
(2) For variable rate bonds, attach a debt
service schedule entitled “Variable Rate
Bond—Debt Service Schedule,” that pro-
vides a list of each interest payment date,
the total principal amount of bonds ex-
pected to be outstanding on each such date,
and a description of how interest on the
bond is computed. If, however, the issuer
knows the interest payment amount for a
certain period, the issuer should include
the refundable credit payment expected to
be requested from the IRS, as allowed un-
der section 2.3 of this Notice, with respect
to such period.
SECTION 6. OTHER INTERIM
GUIDANCE AND RELIANCE
6.1.In General
Pending the promulgation and effective
date of future administrative or regulatory
guidance, this notice provides certain in-
terim guidance applicable to Direct Pay
Tax Credit Bonds and to Build America
Bonds on which issuers may rely.
6.2.Limitation on Bond Premium
For purposes of determining refund-
able credit paymentsunder § 6431(f) on a
Direct Pay Tax Credit Bond, a rule simi-
lar to the prohibition in § 54AA(d)(2)(C)
against the issuance of a Build America
Bond with more than ade minimisamount
(determined under rules similar to the
rulesof§1273(a)(3))ofpremiuminthe
issue price of the bond over the stated
principal amount of the bond shall apply
to Direct Pay Tax Credit Bonds. For pur-
poses of applying this limitation on bond
premium to Direct Pay Tax Credit Bonds
and to Build America Bonds generally
under § 54AA(d)(2)(C), the following
rules apply. The definition of “issue price”
applicable to tax-exempt bonds under
§ 1.148–1(b) applies. Section 1273(a)(3)
and § 1.1273–1(d) provide rules for deter-
mining ade minimisamount for a bond,
which generally means .25 percent of the
stated redemption price at maturity of the
bond multiplied by the number of com-
plete years from the bond’s issue date to
its maturity date. For purposes of apply-
ing section 1273(a)(3) and § 1.1273–1(d)
to a bond, the rules in § 1.163–13(e)(3)
(relating to an issuer’s determination of
bond issuance premium in certain cir-
cumstances) will apply to determine a
bond’s payment schedule and maturity
date. Under § 1.163–13(e)(3)(i), in the
case of a bond subject to certain con-
tingencies, the rules in § 1.1272–1(c)
(other than § 1.1272–1(c)(3) (relating to
mandatory sinking funds)) will apply to
determine the bond’s payment schedule
and maturity date. For example, under
§ 1.1272–1(c)(5), an issuer is presumed
to exercise a call option or combina-
tion of call options if the exercise would
minimize the yield on the bond. Under
§ 1.163–13(e)(3)(ii), the issuer must deter-
mine the payment schedule by assuming
that apro rataportion of the bond will
be called under a sinking fund provision.
In addition, the rules in § 1.1275–2(h)
(relating to remote and incidental contin-
gencies) will apply to determine a bond’s
payment schedule and maturity date.
Thus, for example, if a 17-year bond
issued at a premium is callable by the is-
suer at par after 10 years, the issuer will
be treated as if it called the bond on the
first call date if calling the bond on the first
call date would produce the lowest yield
on the bond. If so, then for purposes of
section 6431, the issuer would determine
if the premium isde minimisbasedona
10-year maturity date rather than a 17-year
maturity date. By comparison, for exam-
ple, if a bond is callable by an issuer only
under a “make whole” call option which
requires the issuer to pay a call premium in
an amount that preserves the bond’s origi-
nal yield to maturity, the issuer’s exercise
of that call option generally will not pro-
duce a lower yield and the call option will
be disregarded in determining whether the
bond premium isde minimis.
The Treasury Department and the
IRS are reviewing the definition of issue
price in this area and also are considering
whether further limitations or special rules
may be necessary or appropriate with re-
spect to the allowability and treatment of
bond issuance premium on Direct Pay Tax
Credit Bonds and Build America Bonds
in various circumstances in light of the
particular purposes of the limitations on
bond issuance premium in this area. The
Treasury Department and the IRS expect
to address any such further limitations or
special rules in future prospective admin-
istrative or regulatory guidance.
2010–19 I.R.B.663May 10, 2010

6.3.OID Not Treated as Interest for
Purposes of Refundable Credit Payments
For purposes of determining refundable
credit payments under § 6431(b), as mod-
ifiedby§6431(f),onaDirectPayTax
Credit Bond or a Build America Bond,
original issue discount (OID) (whether
paid upon accrual, bond redemption, at
maturity, or otherwise) is not treated as a
payment of interest. OID is the excess of a
bond’s stated redemption price at maturity
over the bond’s issue price. See ARRA
Conf. Rep. at 593, n. 146.
6.4.Original Expenditures, Short-Term
Interim Refinancing, and Reimbursements
Section 54A(d)(2) generally provides in
part that an issue of qualified tax credit
bonds meets the expenditure requirements
if, as of the issue date, the issuer reason-
ably expects (i) to spend 100 percent of
the available project proceeds (as defined
in § 54A(e)(4)), on qualified purposes (as
definedin§54A(d)(2)(C))within3years,
and (ii) a binding commitment with a third
party to spend at least 10 percent of such
available project proceeds will be incurred
within the 6-month period beginning on
such date of issuance. Proceeds of Di-
rect Pay Tax Credit Bonds generally may
not be used to refinance eligible expendi-
tures for qualified purposes in “refunding
issues” (as defined in § 1.150–1). For this
purpose, however, Direct Pay Tax Credit
Bonds issued to reimburse otherwise eli-
gible expenditures for qualified purposes
under § 1.150–2 that were paid or incurred
after the date of enactment of the HIRE
Act and that were financed originally with
temporary short-term financing issued af-
ter the date of enactment of the HIRE Act
will not be treated as a refunding issue un-
der §§ 1.150–1(d) or 1.150–2(g).
In addition, under § 54A(d)(2)(D), is-
suers may use proceeds of Direct Pay Tax
Credit Bonds to reimburse otherwise eli-
gible expenditures for qualified purposes,
regardless of whether such expenses were
paid or incurred before or after the date
of enactment of the HIRE Act. In apply-
ing§54A(d)(2)(D)relatingtoreimburse-
ment of eligible expenditures for qualified
purposes, rules under § 1.150–2 generally
shall apply.
6.5.Preissuance Accrued Interest
For purposes of determining refundable
credit payments under § 6431(b), as mod-
ified by § 6431(f), on a Direct Pay Tax
Credit Bond or a Build America Bond,
preissuance accrued interest is not taken
into account. For this purpose, the term
“preissuance accrued interest” means the
portion of the stated interest on the bond
paid by the issuer that is allocable to in-
terest accrued prior to the issue date of the
bond (as defined in § 1.150–1(b)).
SECTION 7. EFFECTIVE DATE
Theeffectivedateofthisnoticeis
April 26, 2010. This notice applies to
bonds issued after March 18, 2010.
SECTION 8. DRAFTING
INFORMATION
The principal author of this no-
tice is Zoran Stojanovic of the Office
of Associate Chief Counsel (Financial
Institutions and Products). For further
information regarding this notice, contact
Zoran Stojanovic at (202) 622–3980 (not
a toll-free call).
26 CFR 301.6212–2: Definition of Last Known Ad-
dress.
Rev. Proc. 2010–16
SECTION 1. PURPOSE
.01 This revenue procedure explains
how the Internal Revenue Service is in-
formed of a change of address. When
so informed, the Service will update the
taxpayer’s address of record to the new
address. The Service uses the taxpayer’s
address of record for the various docu-
ments that are required to be sent to a
taxpayer’s “last known address” under the
Internal Revenue Code and for refunds of
overpayments of tax. Rev. Proc. 2001–18,
2001–1 C.B. 708, is superseded by this
Revenue Procedure.
SECTION 2. BACKGROUND
.01 The Code sections listed in sec-
tion 3.01 of this revenue procedure use the
phrase “last known address.” The mean-
ing of the phrase “last known address” is
important, and taxpayers should be aware
of their need to update their address with
the Service in order to receive refunds of
tax as well as the notices and documents
listed in section 3.01 of this revenue pro-
cedure. When a notice or document is sent
to a taxpayer’s “last known address,” it is
legally effective even if the taxpayer never
receives it.
.02 A taxpayer’s “last known address”
is defined in Treas. Reg. § 301.6212–2(a)
as the address on the taxpayer’s most re-
cently filed and properly processed return,
unless the Service has been given clear and
concise notification of a different address.
.03 A taxpayer should take appropriate
steps to ensure that his or her address is
correct in accordance with the addressing
standards of the United States Postal Ser-
vice (USPS) and, when providing the Ser-
vice with an address, should include all re-
quired addressing information, including
apartment/suite number, street name and
number, city, state, and zip code.
SECTION 3. SCOPE
.01 This revenue procedure applies to
notices and documents that are required
to be sent to a taxpayer’s “last known ad-
dress” including the following sections of
the Code:
Section 982(c)(1) (formal document re-
quest for the production of foreign-based
documentation);
Section 6015(e) (notice of final deter-
mination regarding spousal relief);
Section 6110(f)(3)(B) (notification of
disclosure proceedings);
Section 6110(f)(4)(B) (notification of
disclosure proceedings);
Section 6212(b) (notice of deficiency);
Section 6245(b)(1) (notice of partner-
ship adjustment for electing large partner-
ships);
Section 6303(a) (notice and demand for
tax);
Section 6320(a)(2)(C) (notice and op-
portunity for hearing upon filing of notice
of lien);
Section 6325(f)(2)(A) (notice of revo-
cation of certificate of release or nonat-
tachment of a lien);
Section 6330(a)(2)(C) (notice and op-
portunity for hearing before levy);
May 10, 20106642010–19 I.R.B.

Section 6331(d)(2)(C) (notice of inten-
tion to levy);
Section 6332(b)(1) (copy of notice of
levy with respect to a life insurance or en-
dowment contract);
Section 6335(a) and (b) (notices of
seizure and sale);
Section 6404(h) (notice with respect to
interest abatement);
Section 6901(g) (notice of liability in
transferee cases);
Section 7430(f)(2) (action for reason-
able administrative costs);
Section 7436 (employment status deter-
minations);
Section 7603(b)(1) (summons by mail
to third-party record keeper);
Section 7609(a)(2) (notice of
third-party summons); and
Section 7623(b)(4) (Whistleblower
award determinations).
.02 The Service generally will use the
address on the most recently filed and
properly processed return as the address
of record for all the notices and docu-
ments set forth in section 3.01 above.
The Service will, however, automatically
update a taxpayer’s address of record
based on a new address that the tax-
payer provides the USPS that is retained
in USPS’s National Change of Address
database (NCOA database). See Treas.
Reg. § 301.6212–2(b)(2). If a taxpayer
wishes to change the address of record,
the taxpayer must give clear and concise
notification as provided by this revenue
procedure. The terms “return,” “properly
processed,” “address on return,” and “clear
and concise notification” are defined in
section 5 below.
SECTION 4. PROCEDURES FOR
CHANGE OF ADDRESS
.01 If a taxpayer files a return with new
address information, the proper processing
of the return will update the taxpayer’s ad-
dress of record. With the exception of the
returns listed in section 4.04, a taxpayer’s
address of record will be updated for the
name and taxpayer identification number
(the employer identification number, indi-
vidual taxpayer identification number, or
social security number) under which the
return is filed.
.02 If a taxpayer no longer wishes the
address of record to be the one shown on
the most recently filed return (for example,
because the taxpayer moved after the re-
turn was filed), clear and concise notifica-
tion of a change of address as defined in
section 5.04 below should be provided to
the Service.
.03 If, after a joint return is filed, ei-
ther taxpayer establishes a separate resi-
dence, each taxpayer should provide clear
and concise notification of a current ad-
dress to the Service as provided in section
4.02 above.
.04 The Service maintains address
records for gift, estate, and genera-
tion-skipping transfer tax returns (Forms
706, 706–A, 706–NA, 709, and 709–A)
separate from the address records for in-
dividual income tax returns (Forms 1040,
1040–A, 1040–EZ, 1040 (NR), 1040 (PR),
1040–SS, and 1040–X). Thus, an individ-
ual taxpayer’s notification of a change of
address should identify whether any gift,
estate, or generation-skipping transfer tax
returns are affected by the notification.
.05 A taxpayer should notify the USPS
facility serving the taxpayer’s old address
of the taxpayer’s new address so that mail
from the Service can be forwarded to
the new address. The Service will also
automatically update a taxpayer’s ad-
dress of record based on a new address
that the taxpayer provides to the USPS
and that the USPS retains in its National
Change of Address database. See Treas.
Reg. § 301.6212–2(b)(2). Taxpayers are
nonetheless advised to notify the Service
directly of a change of address to ensure a
timely and accurate update of the Service’s
address of record for the taxpayer.
.06 If the taxpayer’s last known ad-
dress is altered due to address reorganiza-
tion or standardization measures taken by
the USPS or a legislative body, the Service
will treat the altered address as the tax-
payer’s new address of record. Examples
of an address reorganization or standard-
ization measures include the redesignation
of rural route addresses as street addresses
or changes to zip code boundaries. Any
clear and concise notification of a differ-
ent address provided by the taxpayer to the
Service subsequent to an address standard-
ization or reorganization shall control over
any address changes made pursuant to this
section 4.06.
SECTION 5. DEFINITIONS
.01 Return. For purposes of updating
a taxpayer’s address of record, the term
“return” includes the following federal tax
or information forms:
(1) Returns filed under a social security
number or an individualtaxpayer identifi-
cation number:
(a) Individual income tax returns:
Form 1040U.S. Individual Income Tax
Return;
Form 1040 (Schedule H)Household
Employment Taxes;
Form 1040–AU.S. Individual Income
Tax Return;
Form 1040–EZIncome Tax Return for
Single and Joint Filers With No Depen-
dents;
Form 1040 (NR)U.S. Nonresident
Alien Income Tax Return;
Form 1040–EZ (NR)U.S. Income Tax
Return for Certain Nonresident Aliens
With No Dependents;
Form 1040 (PR)PlanillaParaLa
Declaracion De La Contribución Federal
Sobre El Trabajo Por Cuenta Propia —
Puerto Rico;
Form 1040–SSU.S. Self-Employment
Tax Return (Including the Additional
Child Tax Credit for Bonafide Residents
of Puerto Rico), Virgin Islands, Guam,
American Samoa, the Commonwealth of
the Northern Mariana Islands (CNMI), or
Puerto Rico;
Form 1040–XAmended U.S. Individual
Income Tax Return;
(b) Gift, estate, and generation-skip-
ping transfer tax returns:
Form 706United States Estate (and
Generation-Skipping Transfer) Tax Re-
turn;
Form 706–AUnited States Additional
Estate Tax Return;
Form 706–NAUnited States Estate
(and Generation-Skipping Transfer) Tax
Return, Estate of Nonresident not a citizen
of the United States;and
Form 709United States Gift (and Gen-
eration-Skipping Transfer) Tax Return;
(2) Returns filed under an employer
identification number:
Form CT–1Employer’s Annual Rail-
road Retirement Tax Return;
Form 720Quarterly Federal Excise Tax
Return;
Form 720–XAmended Quarterly Fed-
eral Excise Tax Return;
2010–19 I.R.B.665May 10, 2010

Form 730Monthly Tax on Wagering
(Section 4401 of the Internal Revenue
Code);
Form 940Employer’s Annual Federal
Unemployment (FUTA) Tax Return;
Form 940(PR) Planilla Para La
Declaración Anual Del Patrono — La
Contribución Federal Para El Desempleo
(FUTA);
Form 941Employer’s Quarterly Fed-
eral Tax Return;
Form 941–MEmployer’s Monthly Fed-
eral Tax Return;
Form 941 (PR)Planilla Para La
Declaración Federal Trimestral Del Pa-
trono — La Contribución Federal A1
Seguro Social Y A1 Seguro Medicare;
Form 941–SSEmployer’s Quarterly
Federal Tax Return;
Form 943Employer’s Annual Tax Re-
turn for Agricultural Employees;
Form 943 (PR)Planilla Para La
Declaración Anual De La Contribución
Federal Del Patrono De Empleados Agrí-
colas;
Form 944Employer’s Annual Federal
Tax Return;
Form 944 (PR)Employer’s Annual Fed-
eral Tax Return;
Form 944–SSEmployer’s Annual Fed-
eral Tax Return;
Form 945Annual Return of Withheld
Federal Income Tax;
Form 990Return of Organization Ex-
empt from Income Tax — Under section
501(c) of the Internal Revenue Code (ex-
cept Black Lung Benefit Trust or Private
Foundation
Form 990–CFarmers’ Cooperative As-
sociation Income Tax Return;
Form 990–EZShort Form Return of
Organization Exempt From Income Tax
— Under section 501(c) of the Internal
Revenue Code (except Black Lung Benefit
Trust or Private Foundation
Form 990–PFReturn of Private Foun-
dation or Section 4947(a)(1) Nonexempt
Charitable Trust Treated as a Private
Foundation;
Form 990–TExempt Organization
Business Income Tax Return (and proxy
tax under section 6033(e));
Form 1041U.S. Income Tax Return for
Estates and Trusts;
Form 1041–N,U.S. Income Tax Re-
turn for Electing Alaska Native Settlement
Trusts;
Form 1041–QFT,U.S. Income Tax Re-
turn for Qualified Funeral Trusts;
Form 1042Annual Withholding Tax Re-
turn for U.S. Source Income of Foreign
Persons;
Form 1045Application for Tentative
Refund;
Form 1065U.S. Return of Partnership
Income;
Form 1065–BU.S. Return of Income for
Electing Large Partnerships;
Form 1066U.S. Real Estate Mortgage
Investment Conduit (REMIC) Income Tax
Return;
Form 1120U.S. Corporation Income
Tax Return;
Form 1120–AU.S. Corporation Short-
Form Income Tax Return;
Form 1120–CU.S. Income Tax Return
for Cooperative Associations;
Form 1120–FU.S. Income Tax Return
of a Foreign Corporation;
Form 1120–FSCU.S. Income Tax Re-
turn of a Foreign Sales Corporation;
Form 1120–H U.S. Income Tax Return
for Homeowners Associations;
Form 1120–LU.S. Life Insurance Com-
pany Income Tax Return;
Form 1120–NDReturn for Nuclear De-
commissioning Funds and Certain Related
Persons;
Form 1120–PCU.S. Property and Ca-
sualty Insurance Company Income Tax Re-
turn;
Form 1120–POLU.S. Income Tax Re-
turn for Certain Political Organizations;
Form 1120–REITU.S. Income Tax Re-
turn for Real Estate Investment Trusts;
Form 1120–RICU.S. Income Tax Re-
turn for Regulated Investment Companies;
Form 1120–SU.S. Income Tax Return
for an S Corporation;
Form 1120–SFU.S. Income Tax Re-
turn for Settlement Funds (Under Section
468B);
Form 1120–XAmended U.S. Corpora-
tion Income Tax Return;
Form 1139Corporation Application for
Tentative Refund;
Form 2290Heavy Highway Vehicle Use
Tax Return;and
Form 5227Split-Interest Trust Informa-
tion Return.
(3) The term “return” includes sub-
stitute forms (as defined in Rev. Proc.
2003–73, 2003–2 C.B. 647, or as defined
in other current revenue procedures con-
cerning the requirements for substitute
forms) for those forms listed in section
5.01 (1) and (2) above as well as any form
listed in section 5.01 (1) and (2) above that
is provided by the Service in a language
other than English.
(4) The term “return” does not include
applications for extension of time to file
a return or powers of attorney. Thus, for
example, a new address listed on Form
4868,Application for Automatic Extension
of Time to File U.S. Individual Income Tax
Return,or on a Form 2848,Power of At-
torney and Declaration of Representative,
will not be used by the Service to update
the taxpayer’s address of record.
.02 Properly processed.
(1) Except as otherwise provided by the
exceptions below, a return will be consid-
ered properly processed after a 45-day pro-
cessing period which begins the day after
the date of receipt of the return by the Inter-
nal Revenue Submission Processing Cam-
pus. If a return is received prior to the due
date for the return, however, the 45-day
processing period will begin the day after
the due date of the return. Returns that are
not filed in a processible form may require
additional processingtime. If additional
processing time is required, the 45-day
processing period for address changes will
begin the day after the error that caused the
return to be unprocessible is corrected.
(2) Due to the high volume of returns
received during the filing season, if a tax-
payer provides new address information
on a Form 1040, 1040–A, 1040–EZ, 1040
(NR), 1040 (PR), 1040–SS, or 1040–X that
is received in processible form by the Ser-
vice after February 14 and before June 1,
the return will be considered properly pro-
cessedonJuly16.
(3) A clear and concise written notifi-
cation of a change of address will be con-
sideredproperlyprocessedaftera45-day
processing period which begins the day af-
ter the date of receipt by:
(a) the Internal Revenue Service Sub-
mission Processing Campus serving the
taxpayer’s old address;
(b) the Customer Service Division in
the local area office; or
(c) the Service employee who contacted
the taxpayer in connection with the filing
of a return or an adjustment in the tax-
payer’s account.
(4) Clear and concise electronic notifi-
cation of a change of address will be con-
sideredproperlyprocessedaftera45-day
May 10, 20106662010–19 I.R.B.

processing period which begins the day af-
ter the date on which the taxpayer sub-
mits a new address as described in section
5.04(2) below.
(5) Clear and concise oral notification
of a change of address will be considered
properly processed after a 45-day process-
ing period which begins the day after the
date of the communication to the Service
employee.
(6) When the processing of address
change information on a particular return
will require a processing time in excess of
45days,suchasinsection5.02(2),the
taxpayer may provide clear and concise
written, electronic, ororal notification of
a change of address to the Service in ac-
cordance with sections 5.02 (3), 5.02 (4),
or 5.02 (5) above.
.03 Address on Return.
The “address on return” is the address
information shown in the upper portion of
the front page of the return. When a tax-
payer files an electronic return, the address
information entered by the taxpayer as part
of the return will be used to update the tax-
payer’s address of record.
.04 Clear and Concise Notification.
Clear and concise notification may be
written, electronic, or oral as defined be-
low.
(1) Clear and Concise Written Notifica-
tion.
(a) Clear and concise written notifica-
tion is a written statement signed by the
taxpayer and mailed to an appropriate Ser-
vice address informing the Service that
the taxpayer wishes the address of record
changed to a new address. In addition
to the new address, this notification must
contain the taxpayer’s full name and old
address as well as the taxpayer’s social se-
curity number, individual taxpayer iden-
tification number, or employer identifica-
tion number. Filers of a joint return should
provide both names, social security num-
bers, and signatures. Individuals who have
changed their last name should provide the
last name shown on the most recently filed
return and the new last name. In all cases,
clear and concise written notification must
be specific as to a change of address. Thus,
a new address reflected in the letterhead
of taxpayer correspondence will not by it-
self serve to change a taxpayer’s address of
record.
(b) Correspondence sent by the Service
that solicits or requires a response by the
taxpayer that is returned to the Service
by the taxpayer with corrections marked
on the taxpayer’s address information will
constitute clear and concise written notifi-
cation of a change of address.
(c) Additionally, Form 8822,Change of
Address, can be used by taxpayers to pro-
vide clear and concise written notification
of a change of address pursuant to this rev-
enue procedure.
(2) Clear and Concise Electronic Noti-
fication.
(a) Clear and conciseelectronic notifi-
cation is new address information submit-
ted by the taxpayer through one of the se-
cure applications found on the Service’s
website, located atwww.irs.gov. A “se-
cure application” is one that requires the
taxpayer to verify the taxpayer’s identity
before accessing the application. Other
forms of electronic notification, such as
electronic mail sent to a Service email ad-
dress, donotmeet the definition of clear
and concise notification.
(b) In addition to the new address, the
taxpayer’s social security number, individ-
ual taxpayer identification number, or em-
ployer identification number must be pro-
vided, as well as any additional informa-
tion requested by the specific application.
(c) The information must be entered
on the Service’s secure application in the
space provided and electronically submit-
tedtotheService.
(3) Clear and Concise Oral Notifica-
tion.
Clear and concise oral notification is a
statement made by a taxpayer in person
or directly via telephone to a Service em-
ployee who has access to the Service Mas-
ter File informing the Service employee of
the address change. In addition to the new
address, the taxpayer must provide the tax-
payer’s full name and old address as well
as the taxpayer’s social security number,
individual taxpayer identification number,
or employer identification number. The
Service employee must follow established
procedures to verify the taxpayer’s iden-
tity. The Service employee also will in-
form the taxpayer that the new address, and
not the former address, will be used by the
Service for all purposes.
SECTION 6. AREAS NOT COVERED
BY THIS REVENUE PROCEDURE
.01 This revenue procedure does not ap-
ply to the notice requirements under sec-
tions 6221 through 6234, and 6037(c) con-
cerning the tax treatment of partnership
and subchapter S items.
.02 This revenue procedure does not
apply to the following returns because of
their unique processing requirements:
Form 5330Return of Excise Taxes Re-
lated to Employee Benefits Plans (Under
sections 4971, 4972, 4973(a)(3), 4975,
4976, 4977, 4978, 4978A, 4978B, 4979A,
4980 and 4980F of the Internal Revenue
Code);and
Form 5500 SeriesAnnual Return/Re-
port of Employee Benefit Plan.
.03 Except for notices required by law
to be sent to a taxpayer’s last known ad-
dress, this revenue procedure does not re-
quire the Service to continue to send no-
tices to an address furnished by the tax-
payer when it is determined after a deliv-
ery attempt that the taxpayer cannot actu-
ally be contacted or located at that address.
SECTION 7. EFFECT ON OTHER
DOCUMENTS (when applicable)
This revenue procedure supersedes
Rev. Proc. 2001–18, 2001–1 C.B. 708.
SECTION 8. EFFECTIVE DATE
This revenue procedure is effective
June 1, 2010.
SECTION 9. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Meghan Mahaney of the
Office of Associate Chief Counsel (Pro-
cedure & Administration). For further
information regarding this revenue proce-
dure, contact Meghan Mahaney at (202)
622–7950 (not a toll-free call).
2010–19 I.R.B.667May 10, 2010

Part IV. Items o
fGeneralInterest
Draft Schedul
eand
Instructions
for Uncertain
Tax Positions
Proposal
Announcemen
t 2010–30
In Announcem
ent 2010–9, 2010–7
I.R.B. 408, a
nd Announcement 2010–17,
2010–13 I.R.
B. 515, the Internal Rev-
enue Service
announced it is developing
a schedule r
equiring certain taxpayers to
report unce
rtain tax positions on their tax
returns. Th
e Service is now releasing the
draft sched
ule, Schedule UTP, accompa-
nied by dra
ft instructions that provide a
further ex
planation of the Service’s pro-
posal. The
Service invites public comment
on the draf
t schedule and instructions.
The schedu
le and instructions will be fi-
nalized a
fter the Service has received and
consider
ed all of the comments regarding
the overa
ll proposal and the draft schedule
and instr
uctions.
The draft
schedule and instructions pro-
vide that
, beginning with the 2010 tax year,
the foll
owing taxpayers with both uncer-
tain tax
positions and assets equal to or ex-
ceeding
$10 million will be required to file
Schedul
e UTP if they or a related party is-
sued aud
ited financial statements:
•Corpora
tions who are required to file a
Form 112
0,U.S. Corporation Income
Tax Ret
urn;
•Insurance com
panies who are required
tofileaForm1
120 L,U.S. Life Insur-
ance Company I
ncome Tax Returnor
Form 1120 PC,U
.S. Property and Ca-
sualty Insura
nce Company Income Tax
Return;and
•Foreign corpo
rations who are required
to file Form 1
120 F,U.S. Income Tax
Return of a Fo
reign Corporation.
The draft sch
edule and instructions also
provide that
, for 2010 tax years, the Ser-
vice will not
requireaScheduleUTPfrom
Form 1120 se
ries filers other than those
identified
above (such as real estate invest-
ment trusts
or regulated investment com-
panies), pa
ss-through entities, or tax-ex-
empt organi
zations. The Service will de-
termine the
timing of the requirement to
file Sched
ule UTP for these entities after
comments h
ave been received and consid-
ered.
The Servic
e is reviewing the extent to
which the p
roposed Schedule UTP dupli-
cates othe
r reporting requirements, such as
Form 8275
,Disclosure Statement;Form
8275–R,R
egulation Disclosure Statement;
Form 8886
,Reportable Transaction Dis-
closure S
tatement; and the Schedule M–3,
Net Inco
me (Loss) Reconciliation for Cor-
poratio
ns With Total Assets of $10 Mil-
lion or M
ore. The draft instructions pro-
vide tha
t a taxpayer will be treated as hav-
ing file
d a Form 8275 or Form 8275–R for
tax pos
itions that are properly reported on
Schedule UTP.
The Service isconsidering
other circums
tances under which a tax po-
sition report
ed on Schedule UTP need not
be separately
reported elsewhere on the tax
return or anot
her disclosure statement.
Comments on An
nouncement 2010–9,
Announcement
2010–17, the draft sched-
ule, and the d
raft instructions should be
submitted by
June 1, 2010.
Comments sho
uld be submitted to: In-
ternal Reven
ue Service, CC:PA:LPD:PR
(Announceme
nt 2010–9), Room 5203,
P.O. Box 7604
, Ben Franklin Station,
N.W., Washi
ngton, D.C. 20044. Alter-
natively, c
omments may be hand deliv-
ered betwee
n the hours of 8:00 a.m. and
4:00 p.m., M
onday through Friday, to
CC:PA:LPD
:PR (Announcement 2010–9),
Courier’s
Desk, Internal Revenue Ser-
vice, 1111
Constitution Avenue, N.W.,
Washingto
n, D.C. Comments may also be
transmit
ted electronically via the follow-
ing e-mai
l address:Announcement.Com-
ments@ir
scounsel.treas.gov. Please in-
clude “An
nouncement 2010–9” in the
subject l
ine of any electronic communica-
tions. A
ll comments will be available for
public i
nspection and copying.
The prin
cipal author of this announce-
ment is K
athryn A. Zuba of the Office
of Assoc
iate Chief Counsel (Procedure
&Admini
stration). For further informa-
tion re
garding this announcement, contact
Kathry
n A. Zuba at (202) 622–7583 (not a
toll-f
ree call).
May 10, 20106682010–19 I.R.B.

2010–19 I.R.B.669May 10, 2010

May 10, 20106702010–19 I.R.B.

2010–19 I.R.B.671May 10, 2010

May 10, 20106722010–19 I.R.B.

2010–19 I.R.B.673May 10, 2010

May 10, 20106742010–19 I.R.B.

2010–19 I.R.B.675May 10, 2010

May 10, 20106762010–19 I.R.B.

2010–19 I.R.B.677May 10, 2010

May 10, 20106782010–19 I.R.B.

2010–19 I.R.B.679May 10, 2010

May 10, 20106802010–19 I.R.B.

Foundations Status of Certain
Organizations
Announcement 2010–31
The following organizations have failed
to establish or have been unable to main-
tain their status as public charities or as op-
erating foundations. Accordingly, grantors
and contributors may not, after this date,
rely on previous rulings or designations
in the Cumulative List of Organizations
(Publication 78), or on the presumption
arising from the filing of notices under sec-
tion 508(b) of the Code. This listing does
notindicate that the organizations have lost
their status as organizations described in
section 501(c)(3), eligible to receive de-
ductible contributions.
Former Public Charities. The follow-
ing organizations (which have been treated
as organizations thatare not private foun-
dations described in section 509(a) of the
Code) are now classified as private foun-
dations:
Brown Star, Inc., Culver City, CA
Center for Productive Worklife, Inc.,
Aldan, PA
Chosen to Change Enterprise, Inc.,
Sacramento, CA
Cover to Cover Ministries, Inc.,
Euless, TX
Family Empowerment Zone, Inc.,
Saint Charles, MO
Foundation of Daycare Providers,
Phoenix, AZ
Fountain of Hope Foundation,
Yakima, WA
Global Community Development
Corporation, League City, TX
Harmony Cultural Development
Corporation, Lakeland, FL
James Thomas & Associates, Inc.,
Morrow, GA
Leonard E. Hicks Multi Purpose
Community Center Incorporation,
Baltimore, MD
Nazareth Ministries, New Orleans, LA
New Generation International Community
Service, Miami Gardens, FL
New Life Community Development
Center, Atlanta, GA
New Life Youth Development
Corporation, Gary, IN
Radicand Foundation, Pleasant Grove, AL
Redeemed International Outreach Center,
Palatka, FL
Solid Rock Community Development
Corporation, Hanover, MD
Soulja Boyz and Girlz Academy,
North Las Vegas, NV
South Mansfield Community Association,
South Mansfield, LA
Starlite Williams Ministries, Inc.,
Katy, TX
St. Clair Shores Lions Charities, Inc.,
St. Clair Shores, MI
Tri-Centric Foundation, Inc.,
Brooklyn, NY
If an organization listed above submits
information that warrants the renewal of
its classification as a public charity or as
a private operating foundation, the Inter-
nal Revenue Service will issue a ruling or
determination letter with the revised clas-
sification as to foundation status. Grantors
and contributors may thereafter rely upon
such ruling or determination letter as pro-
vided in section 1.509(a)–7 of the Income
Tax Regulations. It is not the practice of
the Service to announce such revised clas-
sification of foundation status in the Inter-
nal Revenue Bulletin.
Revision of Form 3115
Announcement 2010–32
DECEMBER 2009 REVISION OF
FORM 3115
The Internal Revenue Service has re-
vised Form 3115,Application for Change
in Accounting Method, and its instructions.
The Form 3115 (Rev. December 2009) is
thecurrentForm 3115 and replaces the De-
cember 2003 version of the Form 3115.
Ordinarily, a taxpayer applies for con-
sent to change a method of accounting for
federal income tax purposes by complet-
ing and filing acurrentForm 3115. For
automatic change requests procedures, see
section 6.02(1)(a) of Rev. Proc. 2008–52,
2008–36 I.R.B. 587 (as amplified, clari-
fied, and modified by Rev Proc. 2009–39,
2009–38 I.R.B. 371). For non-automatic
change request procedures, see section
8.06 of Rev. Proc. 97–27, 1997–1 C.B.
680 (as modified and amplified by Rev.
Proc. 2002–19, 2002–1 C.B. 696, as
amplified and clarified by Rev. Proc.
2002–54, 2002–2 C.B. 432, as modified
by Rev. Proc. 2007–67, 2007–2 C.B.
1072, and as clarified and modified by
Rev. Proc. 2009–39, 2009–38 I.R.B. 371).
To allow a reasonable transition to the
December 2009 Form 3115, the IRS will
accept either the December 2009 Form
3115 or the December 2003 Form 3115
through May 31, 2010, except where the
use of the December 2009 Form 3115
is specifically required in guidance pub-
lished in the Internal Revenue Bulletin.
Taxpayers filing Forms 3115 after May 31,
2010, must use the December 2009 Form
3115. The IRS encourages taxpayers to
use the December 2009 Form 3115 prior
to June 1, 2010.
Section 6.02(3) of Rev. Proc. 2008–52
requires a taxpayer filing a request for an
automatic change to file its original Form
3115 with its return and a duplicate of
that Form 3115 with the national office.
If prior to June 1, 2010, a taxpayer filed
its duplicate copy of Form 3115 with the
national office using the December 2003
Form 3115, the taxpayer may file its origi-
nal Form 3115 with its return on either the
December 2003 Form 3115 or the Decem-
ber 2009 Form 3115.
Taxpayers may download the Decem-
ber 2009 Form 3115 and its instructions
from the IRS website,www.irs.gov,oror-
der them by calling 1–800–TAX FORM
(1–800–829–3676).
For further information regarding this
announcement, contact Karla Meola at
(202) 622–4930 or Brenda Wilson at (202)
622–4800 (not toll-free calls).
2010–19 I.R.B.681May 10, 2010

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the ef-
fect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is be-
ingextendedtoapplytoavariationofthe
fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that the
same principle also applies to B, the earlier
ruling is amplified. (Compare withmodi-
fied,below).
Clarifiedis used in those instances
where the language in a prior ruling is be-
ing made clear because the language has
caused, or may cause, some confusion.
It is not used where a position in a prior
ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
withamplifiedandclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used in
a ruling that lists previously published rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
beingstatedinanewruling.
Supersededdescribes a situation where
the new ruling does nothing more than re-
state the substance and situation of a previ-
ously published ruling (or rulings). Thus,
the term is used to republish under the
1986 Code and regulations the same po-
sition published under the 1939 Code and
regulations. The term is also used when
it is desired to republish in a single rul-
ing a series of situations, names, etc., that
were previously published over a period of
time in separate rulings. If the new rul-
ing does more than restate the substance
of a prior ruling, a combination of terms
is used. For example,modifiedandsu-
persededdescribes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is self
contained. In this case, the previously pub-
lished ruling is first modified and then, as
modified, is superseded.
Supplementedis used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names in
subsequent rulings. After the original rul-
ing has been supplemented several times, a
new ruling may be published that includes
the list in the original ruling and the ad-
ditions, and supersedes all prior rulings in
the series.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of cases
in litigation, or the outcome of a Service
study.
Abbreviations
The fol
lowing abbreviations in current use
and for
merly used will appear in material
publis
hedintheBulletin.
A—Individual.
Acq.—A
cquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank
.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cu
mulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Coo
perative.
Ct.D.—Court Decision.
CY—County.
D—Decede
nt.
DC—Dummy Corporation.
DE—Donee.
Del. Order
—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Emp
loyer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduc
iary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Fo
reign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Fed
eral Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grante
e.
GP—General Partner.
GR—Grantor.
IC—Insura
nce Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited
Partner.
LR—Lessor.
M—Minor.
Nonacq.—No
nacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Persona
l Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Pa
rtnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Re
al Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsi
diary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target
Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Trans
feree.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpay
er.
TR—Trust.
TT—Trustee.
U.S.C.—Uni
ted States Code.
X—Corporation.
Y—Corporation.
Z—Corporat
ion.
May 10, 2010i2010–19 I.R.B.

Numerical Finding List
1
Bulletins 2010–1 through 2010–19
Announcements:
2010-1, 2010-4 I.R.B.333
2010-2, 2010-2 I.R.B.271
2010-3, 2010-4 I.R.B.333
2010-4, 2010-5 I.R.B.384
2010-5, 2010-6 I.R.B.402
2010-6, 2010-6 I.R.B.402
2010-7, 2010-6 I.R.B.403
2010-8, 2010-7 I.R.B.408
2010-9, 2010-7 I.R.B.408
2010-10, 2010-7 I.R.B.410
2010-11, 2010-10 I.R.B.438
2010-12, 2010-7 I.R.B.410
2010-13, 2010-8 I.R.B.426
2010-14, 2010-11 I.R.B.449
2010-15, 2010-10 I.R.B.438
2010-16, 2010-11 I.R.B.450
2010-17, 2010-13 I.R.B.515
2010-18, 2010-12 I.R.B.460
2010-19, 2010-14 I.R.B.529
2010-20, 2010-15 I.R.B.551
2010-21, 2010-15 I.R.B.551
2010-22, 2010-16 I.R.B.602
2010-23, 2010-16 I.R.B.602
2010-24, 2010-15 I.R.B.587
2010-25, 2010-15 I.R.B.588
2010-26, 2010-16 I.R.B.604
2010-27, 2010-18 I.R.B.657
2010-28, 2010-17 I.R.B.616
2010-29, 2010-17 I.R.B.616
2010-30, 2010-19 I.R.B.668
2010-31, 2010-19 I.R.B.681
2010-32, 2010-19 I.R.B.681
2010-33, 2010-18 I.R.B.658
Notices:
2010-1, 2010-2 I.R.B.251
2010-2, 2010-2 I.R.B.251
2010-3, 2010-2 I.R.B.253
2010-4, 2010-2 I.R.B.253
2010-5, 2010-2 I.R.B.256
2010-6, 2010-3 I.R.B.275
2010-7, 2010-3 I.R.B.296
2010-8, 2010-3 I.R.B.297
2010-9, 2010-3 I.R.B.298
2010-10, 2010-3 I.R.B.299
2010-11, 2010-4 I.R.B.326
2010-12, 2010-4 I.R.B.326
2010-13, 2010-4 I.R.B.327
2010-14, 2010-5 I.R.B.344
2010-15, 2010-6 I.R.B.390
2010-16, 2010-6 I.R.B.396
Notices— Continued:
2010-17, 2010-14 I.R.B.519
2010-18, 2010-14 I.R.B.525
2010-19, 2010-7 I.R.B.404
2010-20, 2010-8 I.R.B.422
2010-21, 2010-12 I.R.B.451
2010-22, 2010-10 I.R.B.435
2010-23, 2010-11 I.R.B.441
2010-24, 2010-12 I.R.B.452
2010-25, 2010-14 I.R.B.527
2010-26, 2010-14 I.R.B.527
2010-27, 2010-15 I.R.B.531
2010-28, 2010-15 I.R.B.541
2010-29, 2010-15 I.R.B.547
2010-30, 2010-18 I.R.B.650
2010-31, 2010-16 I.R.B.594
2010-32, 2010-16 I.R.B.594
2010-33, 2010-17 I.R.B.609
2010-34, 2010-17 I.R.B.612
2010-35, 2010-19 I.R.B.660
2010-36, 2010-17 I.R.B.612
2010-37, 2010-18 I.R.B.654
Proposed Regulations:
REG-132232-08, 2010-6 I.R.B.401
REG-134235-08, 2010-16 I.R.B.596
REG-137036-08, 2010-6 I.R.B.398
REG-101896-09, 2010-5 I.R.B.347
REG-117501-09, 2010-11 I.R.B.442
REG-131028-09, 2010-4 I.R.B.332
REG-148681-09, 2010-11 I.R.B.443
Revenue Procedures:
2010-1, 2010-1 I.R.B.1
2010-2, 2010-1 I.R.B.90
2010-3, 2010-1 I.R.B.110
2010-4, 2010-1 I.R.B.122
2010-5, 2010-1 I.R.B.165
2010-6, 2010-1 I.R.B.193
2010-7, 2010-1 I.R.B.231
2010-8, 2010-1 I.R.B.234
2010-9, 2010-2 I.R.B.258
2010-10, 2010-3 I.R.B.300
2010-11, 2010-2 I.R.B.269
2010-12, 2010-3 I.R.B.302
2010-13, 2010-4 I.R.B.329
2010-14, 2010-12 I.R.B.456
2010-15, 2010-7 I.R.B.404
2010-16, 2010-19 I.R.B.664
2010-17, 2010-8 I.R.B.425
2010-18, 2010-9 I.R.B.427
2010-19, 2010-13 I.R.B.469
2010-20, 2010-14 I.R.B.528
2010-21, 2010-13 I.R.B.473
Revenue Rulings:
2010-1, 2010-2 I.R.B.248
2010-2, 2010-3 I.R.B.272
2010-3, 2010-3 I.R.B.272
2010-4, 2010-4 I.R.B.309
2010-5, 2010-4 I.R.B.312
2010-6, 2010-6 I.R.B.387
2010-7, 2010-8 I.R.B.417
2010-8, 2010-10 I.R.B.432
2010-9, 2010-13 I.R.B.461
2010-10, 2010-13 I.R.B.461
2010-11, 2010-14 I.R.B.516
2010-12, 2010-18 I.R.B.617
Tax Conventions:
2010-2, 2010-2 I.R.B.271
2010-26, 2010-16 I.R.B.604
2010-27, 2010-18 I.R.B.657
Treasury Decisions:
9474, 2010-4 I.R.B.322
9475, 2010-4 I.R.B.304
9476, 2010-5 I.R.B.336
9477, 2010-6 I.R.B.385
9478, 2010-4 I.R.B.315
9479, 2010-18 I.R.B.618
9480, 2010-11 I.R.B.439
9481, 2010-17 I.R.B.605
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2009–27 through 2009–52 is in Internal Revenue Bulletin
2009–52, dated December 28, 2009.
2010–19 I.R.B.iiMay 10, 2010

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2010–1 through 2010–19
Announcements:
2009-23
Corrected by
Ann. 2010-29, 2010-17 I.R.B.616
2009-51
Supplemented and superseded by
Ann. 2010-16, 2010-11 I.R.B.450
2010-4
Corrected by
Ann. 2010-10, 2010-7 I.R.B.410
Notices:
2005-88
Superseded by
Notice 2010-13, 2010-4 I.R.B.327
2006-87
Superseded by
Notice 2010-27, 2010-15 I.R.B.531
2007-25
Superseded by
Notice 2010-27, 2010-15 I.R.B.531
2007-77
Superseded by
Notice 2010-27, 2010-15 I.R.B.531
2008-14
Modified and superseded by
Notice 2010-33, 2010-17 I.R.B.609
2008-41
Modified by
Notice 2010-7, 2010-3 I.R.B.296
2008-55
Modified by
Notice 2010-3, 2010-2 I.R.B.253
2008-88
Modified by
Notice 2010-7, 2010-3 I.R.B.296
2008-107
Superseded by
Notice 2010-27, 2010-15 I.R.B.531
2008-113
Modified by
Notice 2010-6, 2010-3 I.R.B.275
2008-115
Modified by
Notice 2010-6, 2010-3 I.R.B.275
Notices— Continued:
2008-116
Modified and superseded by
Notice 2010-32, 2010-16 I.R.B.594
2009-11
Amplified by
Notice 2010-9, 2010-3 I.R.B.298
2009-13
Obsoleted by
T.D. 9478, 2010-4 I.R.B.315
REG-131028-09, 2010-4 I.R.B.332
2009-35
Supplemented by
Notice 2010-17, 2010-14 I.R.B.519
2009-38
Amplified and superseded by
Notice 2010-2, 2010-2 I.R.B.251
2009-62
Modified and supplemented by
Notice 2010-23, 2010-11 I.R.B.441
Proposed Regulations:
REG-127270-06
Hearing scheduled by
Ann. 2010-6, 2010-6 I.R.B.402
REG-134235-08
Hearing scheduled by
Ann. 2010-33, 2010-18 I.R.B.658
Revenue Procedures:
80-59
Modified and superseded by
Rev. Proc. 2010-11, 2010-2 I.R.B.269
87-35
Obsoleted by
Rev. Proc. 2010-3, 2010-1 I.R.B.110
2001-18
Superseded by
Rev. Proc. 2010-16, 2010-19 I.R.B.664
2008-14
Updated by
Rev. Proc. 2010-15, 2010-7 I.R.B.404
2009-1
Superseded by
Rev. Proc. 2010-1, 2010-1 I.R.B.1
2009-2
Superseded by
Rev. Proc. 2010-2, 2010-1 I.R.B.90
2009-3
Superseded by
Rev. Proc. 2010-3, 2010-1 I.R.B.110
Revenue Procedures— Continued:
2009-4
Superseded by
Rev. Proc. 2010-4, 2010-1 I.R.B.122
2009-5
Superseded by
Rev. Proc. 2010-5, 2010-1 I.R.B.165
2009-6
Superseded by
Rev. Proc. 2010-6, 2010-1 I.R.B.193
2009-7
Superseded by
Rev. Proc. 2010-7, 2010-1 I.R.B.231
2009-8
Superseded by
Rev. Proc. 2010-8, 2010-1 I.R.B.234
2009-9
Superseded by
Rev. Proc. 2010-9, 2010-2 I.R.B.258
2009-15
Amplified and superseded by
Rev. Proc. 2010-12, 2010-3 I.R.B.302
2009-17
Superseded by
Rev. Proc. 2010-21, 2010-13 I.R.B.473
2009-25
Superseded by
Rev. Proc. 2010-3, 2010-1 I.R.B.110
2009-55
Corrected by
Ann. 2010-11, 2010-10 I.R.B.438
2010-1
Corrected by
Ann. 2010-5, 2010-6 I.R.B.402
Revenue Rulings:
67-436
Obsoleted by
REG-101896-09, 2010-5 I.R.B.347
92-19
Supplemented in part by
Rev. Rul. 2010-7, 2010-8 I.R.B.417
2008-52
Supplemented and superseded by
Rev. Rul. 2010-2, 2010-3 I.R.B.272
Treasury Decisions:
9424
Corrected by
Ann. 2010-18, 2010-12 I.R.B.460
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2009–27 through 2009–52 is in Internal Revenue Bulletin 2009–52, dated December 28,
2009.
May 10, 2010iii2010–19 I.R.B.

Treasury Decisions— Continued:
9443
Corrected by
Ann. 2010-8, 2010-7 I.R.B.408
9458
Corrected by
Ann. 2010-7, 2010-6 I.R.B.403
2010–19 I.R.B.ivMay 10, 2010

May 10, 20102010–19 I.R.B.

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