Internal Revenue Bulletin 2022-35 (PDF rendition): IRS Announcements

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Bulletin No. 2022–35
August 29, 2022
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.
ADMINISTRATIVE
Announcement 2022-17, page 179.
The Office of Professional Responsibility (OPR)
announces recent disciplinary sanctions involving
attorneys, certified public accountants, enrolled
agents, enrolled actuaries, enrolled retirement plan
agents, and appraisers. These individuals are subject
to the regulations governing practice before the Inter-
nal Revenue Service (IRS), which are set out in Title
31, Code of Federal Regulations, Part 10, and which
are published in pamphlet form as Treasury Depart-
ment Circular No. 230. The regulations prescribe the
duties and restrictions relating to such practice and
prescribe the disciplinary sanctions for violating the
regulations.
Rev. Rul. 2022-15, page 152.
Interest rates: underpayments and overpayments. The
rates for interest determined under Section 6621 of
the code for the calendar quarter beginning October 1,
2022, will be 6 percent for overpayments (5 percent
in the case of a corporation), 6 percent for underpay-
ments, and 8 percent for large corporate underpay-
ments. The rate of interest paid on the portion of a
corporate overpayment exceeding $10,000 will be
3.5 percent.
ESTATE TAX
Rev. Rul. 2022-16, page 171.
Special Use Value: Farms: Interest Rates. The 2022
interest rates to be used in computing the special use
value of farm real property for which an election is
made under section 2032A of the Code are listed for
estate of decedents.
EXEMPT ORGANIZATIONS
T.D. 9964, page 172.
These regulations provide guidance to state officials
regarding the process by which they may obtain or
inspect certain returns and return information (includ-
ing information about final and proposed denials and
revocations of tax-exempt status) for the purpose of
administering state laws governing certain tax-exempt
organizations and their activities. These regulations
indirectly affect tax-exempt charitable organizations,
applicants for exemption as charitable organizations,
and certain other tax-exempt organizations.
Finding Lists begin on page ii.

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and
enforce the law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing offi-
cial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
general interest. It is published weekly.
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,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of inter-
nal management 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 rul-
ings 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.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal 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,
Legislation 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
Rulings. Bank Secrecy Act Administrative Rulings are issued
by the Department of the Treasury’s Office of the Assistant
Secretary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and 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 contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
August 29, 2022 Bulletin No. 2022–35

Part I
Section 6621.—
Determination of Rate of
Interest
26 CFR 301.6621-1: Interest rate.
Rev. Rul. 2022-15
Section 6621 of the Internal Reve-
nue Code establishes the interest rates
on overpayments and underpayments of
tax. Under section 6621(a)(1), the over-
payment rate is the sum of the federal
short-term rate plus 3 percentage points (2
percentage points in the case of a corpo-
ration), except the rate for the portion of
a corporate overpayment of tax exceeding
$10,000 for a taxable period is the sum
of the federal short-term rate plus 0.5 of
a percentage point. Under section 6621(a)
(2), the underpayment rate is the sum of
the federal short-term rate plus 3 percent-
age points.
Section 6621(c) provides that for pur-
poses of interest payable under section
6601 on any large corporate underpay-
ment, the underpayment rate under section
6621(a)(2) is determined by substituting
“5 percentage points” for “3 percentage
points.” See section 6621(c) and section
301.6621-3 of the Regulations on Proce-
dure and Administration for the definition
of a large corporate underpayment and
for the rules for determining the appli-
cable date. Section 6621(c) and section
301.6621-3 are generally effective for
periods after December 31, 1990.
Section 6621(b)(1) provides that the
Secretary will determine the federal
short-term rate for the first month in each
calendar quarter. Section 6621(b)(2)(A)
provides that the federal short-term rate
determined under section 6621(b)(1) for
any month applies during the first calen-
dar quarter beginning after that month.
Section 6621(b)(3) provides that the fed-
eral short-term rate for any month is the
federal short-term rate determined during
that month by the Secretary in accordance
with section 1274(d), rounded to the near-
est full percent (or, if a multiple of 1/2 of
1 percent, the rate is increased to the next
highest full percent).
Notice 88-59, 1988-1 C.B. 546,
announced that in determining the quar-
terly interest rates to be used for overpay-
ments and underpayments of tax under
section 6621, the Internal Revenue Ser-
vice will use the federal short-term rate
based on daily compounding because that
rate is most consistent with section 6621
which, pursuant to section 6622, is subject
to daily compounding.
The federal short-term rate determined
in accordance with section 1274(d) during
July 2022 is the rate published in Revenue
Ruling 2022-14, 2022-31 IRB 110, to take
effect beginning August 1, 2022. The fed-
eral short-term rate, rounded to the nearest
full percent, based on daily compounding
determined during the month of July 2022
is 3 percent. Accordingly, an overpayment
rate of 6 percent (5 percent in the case of a
corporation) and an underpayment rate of
6 percent are established for the calendar
quarter beginning October 1, 2022. The
overpayment rate for the portion of a cor-
porate overpayment exceeding $10,000
for the calendar quarter beginning October
1, 2022, is 3.5 percent. The underpayment
rate for large corporate underpayments for
the calendar quarter beginning October 1,
2022, is 8 percent. These rates apply to
amounts bearing interest during that cal-
endar quarter.
Sections 6654(a)(1) and 6655(a)
(1) provide that the underpayment rate
established under section 6621 applies
in determining the addition to tax under
sections 6654 and 6655 for failure to pay
estimated tax for any taxable year. Thus,
the 6 percent rate also applies to estimated
tax underpayments for the fourth calen-
dar quarter beginning October 1, 2022.
In addition, pursuant to section 6603(d)
(4), the rate of interest on section 6603
deposits is 3 percent for the fourth calen-
dar quarter in 2022.
Interest factors for daily compound
interest for annual rates of 3.5 percent, 5
percent, 6 percent and 8 percent are pub-
lished in Tables 12, 15, 17 and 21 of Rev.
Proc. 95-17, 1995-1 C.B. 566, 569, 571,
and 575.
Annual interest rates to be compounded
daily pursuant to section 6622 that apply
for prior periods are set forth in the tables
accompanying this revenue ruling.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Casey R. Conrad of the Office of
the Associate Chief Counsel (Procedure
and Administration). For further informa-
tion regarding this revenue ruling, contact
Mr. Conrad at (202) 317-6844 (not a toll-
free number).
August 29, 2022 152 Bulletin No. 2022–35

APPENDIX A
365 Day Year
0.5% Compound Rate 184 Days
DaysFactorDaysFactorDaysFactor
10.000013699630.0008633801250.001713784
20.000027397640.0008770911260.001727506
30.000041096650.0008908011270.001741228
40.000054796660.0009045121280.001754951
50.000068495670.0009182231290.001768673
60.000082195680.0009319341300.001782396
70.000095894690.0009456461310.001796119
80.000109594700.0009593571320.001809843
90.000123294710.0009730691330.001823566
100.000136995720.0009867811340.001837290
110.000150695730.0010004931350.001851013
120.000164396740.0010142061360.001864737
130.000178097750.0010279181370.001878462
140.000191798760.0010416311380.001892186
150.000205499770.0010553441390.001905910
160.000219201780.0010690571400.001919635
170.000232902790.0010827701410.001933360
180.000246604800.0010964841420.001947085
190.000260306810.0011101971430.001960811
200.000274008820.0011239111440.001974536
210.000287711830.0011376251450.001988262
220.000301413840.0011513391460.002001988
230.000315116850.0011650541470.002015714
240.000328819860.0011787681480.002029440
250.000342522870.0011924831490.002043166
260.000356225880.0012061981500.002056893
270.000369929890.0012199131510.002070620
280.000383633900.0012336291520.002084347
290.000397336910.0012473441530.002098074
300.000411041920.0012610601540.002111801
310.000424745930.0012747761550.002125529
320.000438449940.0012884921560.002139257
330.000452154950.0013022081570.002152985
340.000465859960.0013159251580.002166713
350.000479564970.0013296411590.002180441
360.000493269980.0013433581600.002194169
370.000506974990.0013570751610.002207898
380.0005206801000.0013707921620.002221627
390.0005343861010.0013845101630.002235356
400.0005480921020.0013982271640.002249085
410.0005617981030.0014119451650.002262815
Bulletin No. 2022–35 153 August 29, 2022

August 29, 2022 154 Bulletin No. 2022–35
420.0005755041040.0014256631660.002276544
430.0005892111050.0014393811670.002290274
440.0006029171060.0014531001680.002304004
450.0006166241070.0014668181690.002317734
460.0006303311080.0014805371700.002331465
470.0006440391090.0014942561710.002345195
480.0006577461100.0015079751720.002358926
490.0006714541110.0015216941730.002372657
500.0006851611120.0015354141740.002386388
510.0006988691130.0015491331750.002400120
520.0007125781140.0015628531760.002413851
530.0007262861150.0015765731770.002427583
540.0007399951160.0015902931780.002441315
550.0007537031170.0016040141790.002455047
560.0007674121180.0016177341800.002468779
570.0007811211190.0016314551810.002482511
580.0007948311200.0016451761820.002496244
590.0008085401210.0016588971830.002509977
600.0008222501220.0016726191840.002523710
610.0008359601230.001686340
620.0008496701240.001700062

Bulletin No. 2022–35 155 August 29, 2022
366 Day Year
0.5% Compound Rate 184 Days
DaysFactorDaysFactorDaysFactor
10.000013661630.0008610201250.001709097
20.000027323640.0008746931260.001722782
30.000040984650.0008883661270.001736467
40.000054646660.0009020401280.001750152
50.000068308670.0009157131290.001763837
60.000081970680.0009293871300.001777522
70.000095632690.0009430611310.001791208
80.000109295700.0009567351320.001804893
90.000122958710.0009704091330.001818579
100.000136620720.0009840841340.001832265
110.000150283730.0009977581350.001845951
120.000163947740.0010114331360.001859638
130.000177610750.0010251081370.001873324
140.000191274760.0010387831380.001887011
150.000204938770.0010524591390.001900698
160.000218602780.0010661341400.001914385
170.000232266790.0010798101410.001928073
180.000245930800.0010934861420.001941760
190.000259595810.0011071621430.001955448
200.000273260820.0011208391440.001969136
210.000286924830.0011345151450.001982824
220.000300590840.0011481921460.001996512
230.000314255850.0011618691470.002010201
240.000327920860.0011755461480.002023889
250.000341586870.0011892231490.002037578
260.000355252880.0012029001500.002051267
270.000368918890.0012165781510.002064957
280.000382584900.0012302561520.002078646
290.000396251910.0012439341530.002092336
300.000409917920.0012576121540.002106025
310.000423584930.0012712911550.002119715
320.000437251940.0012849691560.002133405
330.000450918950.0012986481570.002147096
340.000464586960.0013123271580.002160786
350.000478253970.0013260061590.002174477
360.000491921980.0013396851600.002188168
370.000505589990.0013533651610.002201859
380.0005192571000.0013670441620.002215550
390.0005329251010.0013807241630.002229242
400.0005465941020.0013944041640.002242933
410.0005602621030.0014080851650.002256625
420.0005739311040.0014217651660.002270317

August 29, 2022 156 Bulletin No. 2022–35
430.0005876001050.0014354461670.002284010
440.0006012691060.0014491271680.002297702
450.0006149391070.0014628081690.002311395
460.0006286081080.0014764891700.002325087
470.0006422781090.0014901701710.002338780
480.0006559481100.0015038521720.002352473
490.0006696181110.0015175331730.002366167
500.0006832891120.0015312151740.002379860
510.0006969591130.0015448971750.002393554
520.0007106301140.0015585801760.002407248
530.0007243011150.0015722621770.002420942
540.0007379721160.0015859451780.002434636
550.0007516431170.0015996281790.002448331
560.0007653151180.0016133111800.002462025
570.0007789861190.0016269941810.002475720
580.0007926581200.0016406781820.002489415
590.0008063301210.0016543611830.002503110
600.0008200031220.0016680451840.002516806
610.0008336751230.001681729
620.0008473481240.001695413

Bulletin No. 2022–35 157 August 29, 2022
TABLE OF INTEREST RATES
PERIODS BEFORE JUL. 1, 1975 - PERIODS ENDING DEC. 31, 1986
OVERPAYMENTS AND UNDERPAYMENTS
PERIODRATEIn 1995-1 C.B.
DAILY RATE TABLE
Before Jul. 1, 19756%Table2,pg.557
Jul. 1, 1975–Jan. 31, 19769%Table4,pg.559
Feb. 1, 1976–Jan. 31, 19787%Table3,pg.558
Feb. 1, 1978–Jan. 31, 19806%Table2,pg.557
Feb. 1, 1980–Jan. 31, 198212%Table5,pg.560
Feb. 1, 1982–Dec. 31, 198220%Table6,pg.560
Jan. 1, 1983–Jun. 30, 198316%Table37,pg.591
Jul. 1, 1983–Dec. 31, 198311%Table27,pg.581
Jan. 1, 1984–Jun. 30, 198411%Table75,pg.629
Jul. 1, 1984–Dec. 31, 198411%Table75,pg.629
Jan. 1, 1985–Dec. 31, 198513%Table31,pg.585
Jul. 1, 1985–Dec. 31, 198511%Table27,pg.581
Jan. 1, 1986–Jun. 30, 198610%Table25,pg.579
Jul. 1, 1986–Dec. 31, 19869%Table23,pg.577
TABLE OF INTEREST RATES
FROM JAN. 1, 1987 – Dec. 31, 1998
OVERPAYMENTSUNDERPAYMENTS
1995-1 C.B.1995-1 C.B. RATE
RATETABLEPGRATETABLEPG
Jan. 1, 1987–Mar. 31, 19878%215759%23577
Apr. 1, 1987–Jun. 30, 19878%215759%23577
Jul. 1, 1987–Sep. 30, 19878%215759%23577
Oct. 1, 1987–Dec. 31, 19879%2357710%25579
Jan. 1, 1988–Mar. 31, 198810%7362711%75629
Apr. 1, 1988–Jun. 30, 19889%7162510%73627
Jul. 1, 1988–Sep. 30, 19889%7162510%73627
Oct. 1, 1988–Dec. 31, 198810%7362711%75629
Jan. 1, 1989–Mar. 31, 198910%2557911%27581
Apr. 1, 1989–Jun. 30, 198911%2758112%29583
Jul. 1, 1989–Sep. 30, 198911%2758112%29583
Oct. 1, 1989–Dec. 31, 198910%2557911%27581
Jan. 1, 1990–Mar. 31, 199010%2557911%27581
Apr. 1, 1990–Jun. 30, 199010%2557911%27581
Jul. 1, 1990–Sep. 30, 199010%2557911%27581
Oct. 1, 1990–Dec. 31, 199010%2557911%27581
Jan. 1, 1991–Mar. 31, 199110%2557911%27581
Apr. 1, 1991–Jun. 30, 19919%2357710%25579

August 29, 2022 158 Bulletin No. 2022–35
Jul. 1, 1991–Sep. 30, 19919%2357710%25579
Oct. 1, 1991–Dec. 31, 19919%2357710%25579
Jan. 1, 1992–Mar. 31, 19928%696239%71625
Apr. 1, 1992–Jun. 30, 19927%676218%69623
Jul. 1, 1992–Sep. 30, 19927%676218%69623
Oct. 1, 1992–Dec. 31, 19926%656197%67621
Jan. 1, 1993–Mar. 31, 19936%175717%19573
Apr. 1, 1993–Jun. 30, 19936%175717%19573
Jul. 1, 1993–Sep. 30, 19936%175717%19573
Oct. 1, 1993–Dec. 31, 19936%175717%19573
Jan. 1, 1994–Mar. 31, 19946%175717%19573
Apr. 1, 1994–Jun. 30, 19946%175717%19573
Jul. 1, 1994–Sep. 30, 19947%195738%21575
Oct. 1, 1994–Dec. 31, 19948%215759%23577
Jan. 1, 1995–Mar. 31, 19958%215759%23577
Apr. 1, 1995–Jun. 30, 19959%2357710%25579
Jul. 1, 1995–Sep. 30, 19958%215759%23577
Oct. 1, 1995–Dec. 31, 19958%215759%23577
Jan. 1, 1996–Mar. 31, 19968%696239%71625
Apr. 1, 1996–Jun. 30, 19967%676218%69623
Jul. 1, 1996–Sep. 30, 19968%696239%71625
Oct. 1, 1996–Dec. 31, 19968%696239%71625
Jan. 1, 1997–Mar. 31, 19978%215759%23577
Apr. 1, 1997–Jun. 30, 19978%215759%23577
Jul. 1, 1997–Sep. 30, 19978%215759%23577
Oct. 1, 1997–Dec. 31, 19978%215759%23577
Jan. 1, 1998–Mar. 31, 19988%215759%23577
Apr. 1, 1998–Jun. 30, 19987%195738%21575
Jul. 1, 1998–Sep. 30, 19987%195738%21575
Oct. 1, 1998–Dec. 31, 19987%195738%21575

Bulletin No. 2022–35 159 August 29, 2022
TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 - PRESENT
NONCORPORATE OVERPAYMENTS AND UNDERPAYMENTS
1995-1 C.B.
RATETABLEPAGE
Jan. 1, 1999–Mar. 31, 19997%19573
Apr. 1, 1999–Jun. 30, 19998%21575
Jul. 1, 1999–Sep. 30, 19998%21575
Oct. 1, 1999–Dec.31, 19998%21575
Jan. 1, 2000–Mar. 31, 20008%69623
Apr. 1, 2000–Jun. 30, 20009%71625
Jul. 1, 2000–Sep. 30, 20009%71625
Oct. 1, 2000–Dec. 31, 20009%71625
Jan. 1, 2001–Mar. 31, 20019%23577
Apr. 1, 2001–Jun. 30, 20018%21575
Jul. 1, 2001–Sep. 30, 20017%19573
Oct. 1, 2001–Dec. 31, 20017%19573
Jan. 1, 2002–Mar. 31, 20026%17571
Apr. 1, 2002–Jun. 30, 20026%17571
Jul. 1, 2002–Sep. 30, 20026%17571
Oct. 1, 2002–Dec. 31, 20026%17571
Jan. 1, 2003–Mar. 31, 20035%15569
Apr. 1, 2003–Jun. 30, 20035%15569
Jul. 1, 2003–Sep. 30, 20035%15569
Oct. 1, 2003–Dec. 31, 20034%13567
Jan. 1, 2004–Mar. 31, 20044%61615
Apr. 1, 2004–Jun. 30, 20045%63617
Jul. 1, 2004–Sep. 30, 20044%61615
Oct. 1, 2004–Dec. 31, 20045%63617
Jan. 1, 2005–Mar. 31, 20055%15569
Apr. 1, 2005–Jun. 30, 20056%17571
Jul. 1, 2005–Sep. 30, 20056%17571
Oct. 1, 2005–Dec. 31, 20057%19573
Jan. 1, 2006–Mar. 31, 20067%19573
Apr. 1, 2006–Jun. 30, 20067%19573
Jul. 1, 2006–Sep. 30, 20068%21575
Oct. 1, 2006–Dec. 31, 20068%21575
Jan. 1, 2007–Mar. 31, 20078%21575
Apr. 1, 2007–Jun. 30, 20078%21575
Jul. 1, 2007–Sep. 30, 20078%21575
Oct. 1, 2007–Dec. 31, 20078%21575
Jan. 1, 2008–Mar. 31, 20087%67621
Apr. 1, 2008–Jun. 30, 20086%65619
Jul. 1, 2008–Sep. 30, 20085%63617
Oct. 1, 2008–Dec. 31, 20086%65619

August 29, 2022 160 Bulletin No. 2022–35
Jan. 1, 2009–Mar. 31, 20095%15569
Apr. 1, 2009–Jun. 30, 20094%13567
Jul. 1, 2009–Sep. 30, 20094%13567
Oct. 1, 2009–Dec. 31, 20094%13567
Jan. 1, 2010–Mar. 31, 20104%13567
Apr. 1, 2010–Jun. 30, 20104%13567
Jul. 1, 2010–Sep. 30, 20104%13567
Oct. 1, 2010–Dec. 31, 20104%13567
Jan. 1, 2011–Mar. 31, 20113%11565
Apr. 1, 2011–Jun. 30, 20114%13567
Jul. 1, 2011–Sep. 30, 20114%13567
Oct. 1, 2011–Dec. 31, 20113%11565
Jan. 1, 2012–Mar. 31, 20123%59613
Apr. 1, 2012–Jun. 30, 20123%59613
Jul. 1, 2012–Sep. 30, 20123%59613
Oct. 1, 2012–Dec. 31, 20123%59613
Jan. 1, 2013–Mar. 31, 20133%11565
Apr. 1, 2013–Jun. 30, 20133%11565
Jul. 1, 2013–Sep. 30, 20133%11565
Oct. 1, 2013–Dec. 31, 20133%11565
Jan. 1, 2014–Mar. 31, 20143%11565
Apr. 1, 2014–Jun. 30, 20143%11565
Jul. 1, 2014–Sep. 30, 20143%11565
Oct. 1, 2014–Dec. 31, 20143%11565
Jan. 1, 2015–Mar. 31, 20153%11565
Apr. 1, 2015–Jun. 30, 20153%11565
Jul. 1, 2015–Sep. 30, 20153%11565
Oct. 1, 2015–Dec. 31, 20153%11565
Jan. 1, 2016–Mar. 31, 20163%59613
Apr. 1, 2016–Jun. 30, 20164%61615
Jul. 1, 2016–Sep. 30, 20164%61615
Oct. 1, 2016–Dec. 31, 20164%61615
Jan. 1, 2017–Mar. 31, 20174%13567
Apr. 1, 2017–Jun. 30, 20174%13567
Jul. 1, 2017–Sep. 30, 20174%13567
Oct. 1, 2017–Dec. 31, 20174%13567
Jan. 1, 2018–Mar. 31, 20184%13567
Apr. 1, 2018–Jun. 30, 20185%15569
Jul. 1, 2018–Sep. 30, 20185%15569
Oct. 1, 2018–Dec. 31, 20185%15569
Jan. 1, 2019–Mar. 31, 20196%17571
Apr. 1, 2019–Jun. 30, 20196%17571
Jul. 1, 2019–Sep. 30, 20195%15569
Oct. 1, 2019–Dec. 31, 20195%15569
Jan. 1, 2020–Mar. 31, 20205%63617

Bulletin No. 2022–35 161 August 29, 2022
Apr. 1, 2020–Jun. 30, 20205%63617
Jul. 1, 2020–Sep. 30, 20203%59613
Oct. 1, 2020–Dec. 31, 20203%59613
Jan. 1, 2021–Mar. 31, 20213%11565
Apr. 1, 2021–Jun. 30, 20213%11565
Jul. 1, 2021–Sep. 30, 20213%11565
Oct. 1, 2021–Dec. 31, 20213%11565
Jan. 1, 2022–Mar. 31, 20223%11565
Apr. 1, 2022–Jun. 30, 20224%13567
Jul. 1, 2022–Sep. 30, 20225%15569
Oct. 1, 2022–Dec. 31, 20226%17571

August 29, 2022 162 Bulletin No. 2022–35
TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 - PRESENT
CORPORATE OVERPAYMENTS AND UNDERPAYMENTS
OVERPAYMENTSUNDERPAYMENTS
1995-1 C.B.1995-1 C.B.
RATETABLEPGRATETABLEPG
RATETABLEPGRATETABLEPG
Jan. 1, 1999–Mar. 31, 19996%175717%19573
Apr. 1, 1999–Jun. 30, 19997%195738%21575
Jul. 1, 1999–Sep. 30, 19997%195738%21575
Oct. 1, 1999–Dec. 31, 19997%195738%21575
Jan. 1, 2000–Mar. 30, 20007%676218%69623
Apr. 1, 2000–Jun. 30, 20008%696239%71625
Jul. 1, 2000–Sep. 30, 20008%696239%71625
Oct. 1, 2000–Dec. 31, 20008%696239%71625
Jan. 1, 2001–Mar. 31, 20018%215759%23577
Apr. 1, 2001–Jun. 30, 20017%195738%21575
Jul. 1, 2001–Sep. 30, 20016%175717%19573
Oct. 1, 2001–Dec. 31, 20016%175717%19573
Jan. 1, 2002–Mar. 31, 20025%155696%17571
Apr. 1, 2002–Jun. 30, 20025%155696%17571
Jul. 1, 2002–Sep. 30, 20025%155696%17571
Oct. 1, 2002–Dec. 31, 20025%155696%17571
Jan. 1, 2003–Mar. 31, 20034%135675%15569
Apr. 1, 2003–Jun. 30, 20034%135675%15569
Jul. 1, 2003–Sep. 30, 20034%135675%15569
Oct. 1, 2003–Dec. 31, 20033%115654%13567
Jan. 1, 2004–Mar. 31, 20043%596134%61615
Apr. 1, 2004–Jun. 30, 20044%616155%63617
Jul. 1, 2004–Sep. 30, 20043%596134%61615
Oct. 1, 2004–Dec. 31, 20044%616155%63617
Jan. 1, 2005–Mar. 31, 20054%135675%15569
Apr. 1, 2005–Jun. 30, 20055%155696%17571
Jul. 1, 2005–Sep. 30, 20055%155696%17571
Oct. 1, 2005–Dec. 31, 20056%175717%19573
Jan. 1, 2006–Mar. 31, 20066%175717%19573
Apr. 1, 2006–Jun. 30, 20066%175717%19573
Jul. 1, 2006–Sep. 30, 20067%195738%21575
Oct. 1, 2006–Dec. 31, 20067%195738%21575
Jan. 1, 2007–Mar. 31, 20077%195738%21575
Apr. 1, 2007–Jun. 30, 20077%195738%21575
Jul. 1, 2007–Sep. 30, 20077%195738%21575
Oct. 1, 2007–Dec. 31, 20077%195738%21575
Jan. 1, 2008–Mar. 31, 20086%656197%67621
Apr. 1, 2008–Jun. 30, 20085%636176%65619
Jul. 1, 2008–Sep. 30, 20084%616155%63617

Bulletin No. 2022–35 163 August 29, 2022
Oct. 1, 2008–Dec. 31, 20085%636176%65619
Jan 1, 2009–Mar. 31, 20094%135675%15569
Apr. 1, 2009–Jun. 30, 20093%115654%13567
Jul. 1, 2009–Sep. 30, 20093%115654%13567
Oct. 1, 2009–Dec. 31, 20093%115654%13567
Jan. 1, 2010–Mar. 31, 20103%115654%13567
Apr. 1, 2010–Jun. 30, 20103%115654%13567
Jul. 1, 2010–Sep. 30, 20103%115654%13567
Oct. 1, 2010–Dec. 31, 20103%115654%13567
Jan. 1, 2011–Mar. 31, 20112%95633%11565
Apr. 1, 2011–Jun. 30, 20113%115654%13567
Jul. 1, 2011–Sep. 30, 20113%115654%13567
Oct. 1, 2011–Dec. 31, 20112%95633%11565
Jan. 1, 2012–Mar. 31, 20122%576113%59613
Apr. 1, 2012–Jun. 30, 20122%576113%59613
Jul. 1, 2012–Sep. 30, 20122%576113%59613
Oct. 1, 2012–Dec. 31, 20122%576113%59613
Jan. 1, 2013–Mar. 31, 20132%95633%11565
Apr. 1, 2013–Jun. 30, 20132%95633%11565
Jul. 1, 2013–Sep. 30, 20132%95633%11565
Oct. 1, 2013–Dec. 31, 20132%95633%11565
Jan. 1, 2014–Mar. 31, 20142%95633%11565
Apr. 1, 2014–Jun. 30, 20142%95633%11565
Jul. 1, 2014–Sep. 30, 20142%95633%11565
Oct. 1, 2014–Dec. 31, 20142%95633%11565
Jan. 1, 2015–Mar. 31, 20152%95633%11565
Apr. 1, 2015–Jun. 30, 20152%95633%11565
Jul. 1, 2015–Sep. 30, 20152%95633%11565
Oct. 1, 2015–Dec. 31, 20152%95633%11565
Jan. 1, 2016–Mar. 31, 20162%576113%59613
Apr. 1, 2016–Jun. 30, 20163%596134%61615
Jul. 1, 2016–Sep. 30, 20163%596134%61615
Oct. 1, 2016–Dec. 31, 20163%596134%61615
Jan. 1, 2017–Mar. 31, 20173%115654%13567
Apr. 1, 2017–Jun. 30, 20173%115654%13567
Jul. 1, 2017–Sep. 30, 20173%115654%13567
Oct. 1, 2017–Dec. 31, 20173%115654%13567
Jan. 1, 2018–Mar. 31, 20183%115654%13567
Apr. 1, 2018–Jun. 30, 20184%135675%15569
Jul. 1, 2018–Sep. 30, 20184%135675%15569
Oct. 1, 2018–Dec. 31, 20184%135675%15569
Jan. 1, 2019–Mar. 31, 20195%155696%17571
Apr. 1, 2019–Jun. 30, 20195%155696%17571
Jul. 1, 2019–Sep. 30, 20194%135675%15569
Oct. 1, 2019–Dec. 31, 20194%135675%15569

August 29, 2022 164 Bulletin No. 2022–35
Jan. 1, 2020–Mar. 31, 20204%616155%63617
Apr. 1, 2020–Jun. 30, 20204%616155%63617
Jul. 1, 2020–Sep. 30, 20202%576113%59613
Oct. 1, 2020–Dec. 31, 20202%576113%59613
Jan. 1, 2021–Mar. 31, 20212%95633%11565
Apr. 1, 2021–Jun. 30, 20212%95633%11565
Jul. 1, 2021–Sep. 30, 20212%95633%11565
Oct. 1, 2021–Dec. 31, 20212%95633%11565
Jan. 1, 2022–Mar. 31, 20222%95633%11565
Apr. 1, 2022–Jun. 30, 20223%115654%13567
Jul. 1, 2022–Sep. 30, 20224%135675%15569
Oct. 1, 2022–Dec. 31, 20225%155696%17571

Bulletin No. 2022–35 165 August 29, 2022
TABLE OF INTEREST RATES
FOR LARGE CORPORATE UNDERPAYMENTS
FROM JANUARY 1, 1991 - PRESENT
1995-1 C.B.
RATETABLEPG
Jan. 1, 1991–Mar. 31, 199113%31585
Apr. 1, 1991–Jun. 30, 199112%29583
Jul. 1, 1991–Sep. 30, 199112%29583
Oct. 1, 1991–Dec. 31, 199112%29583
Jan. 1, 1992–Mar. 31, 199211%75629
Apr. 1, 1992–Jun. 30, 199210%73627
Jul. 1, 1992–Sep. 30, 199210%73627
Oct. 1, 1992–Dec. 31, 19929%71625
Jan. 1, 1993–Mar. 31, 19939%23577
Apr. 1, 1993–Jun. 30, 19939%23577
Jul. 1, 1993–Sep. 30, 19939%23577
Oct. 1, 1993–Dec. 31, 19939%23577
Jan. 1, 1994–Mar. 31, 19949%23577
Apr. 1, 1994–Jun. 30, 19949%23577
Jul. 1, 1994–Sep. 30, 199410%25579
Oct. 1, 1994–Dec. 31, 199411%27581
Jan. 1, 1995–Jun. 30, 199511%27581
Apr. 1, 1995–Jun. 30, 199512%29583
Jul. 1, 1995–Sep. 30, 199511%27581
Oct. 1, 1995–Dec. 31, 199511%27581
Jan. 1, 1996–Mar. 31, 199611%75629
Apr. 1, 1996–Jun. 30, 199610%73627
Jul. 1, 1996–Sep. 30, 199611%75629
Oct. 1, 1996–Dec. 31, 199611%75629
Jan. 1, 1997–Mar. 31, 199711%27581
Apr. 1, 1997–Jun. 30, 199711%27581
Jul. 1, 1997–Sep. 30, 199711%27581
Oct. 1, 1997–Dec. 31, 199711%27581
Jan. 1, 1998–Mar. 31, 199811%27581
Apr. 1, 1998–Jun. 30, 199810%25579
Jul. 1, 1998–Sep. 30, 199810%25579
Oct. 1, 1998–Dec. 31, 199810%25579
Jan. 1, 1999–Mar. 31, 19999%23577
Apr. 1, 1999–Jun. 30, 199910%25579
Jul. 1, 1999–Sep. 30, 199910%25579
Oct. 1, 1999–Dec. 31, 199910%25579
Jan. 1, 2000–Mar. 31, 200010%73627
Apr. 1, 2000–Jun. 30, 200011%75629
Jul. 1, 2000–Sep. 30, 200011%75629
Oct. 1, 2000–Dec. 31, 200011%75629
Jan. 1, 2001–Mar. 31, 200111%27581

August 29, 2022 166 Bulletin No. 2022–35
Apr. 1, 2001–Jun. 30, 200110%25579
Jul. 1, 2001–Sep. 30, 20019%23577
Oct. 1, 2001–Dec. 31, 20019%23577
Jan. 1, 2002–Mar. 31, 20028%21575
Apr. 1, 2002–Sep. 30, 20028%21575
Jul. 1, 2002–Sep. 30, 20028%21575
Oct. 1, 2002–Dec. 31, 20028%21575
Jan. 1, 2003–Mar. 31, 20037%19573
Apr. 1, 2003–Jun. 30, 20037%19573
Jul. 1, 2003–Sep. 30, 20037%19573
Oct. 1, 2003–Dec. 31, 20036%17571
Jan. 1, 2004–Mar. 31, 20046%65619
Apr. 1, 2004–Jun. 30, 20047%67621
Jul. 1, 2004–Sep. 30, 20046%65619
Oct. 1, 2004–Dec. 31, 20047%67621
Jan. 1, 2005–Mar. 31, 20057%19573
Apr. 1, 2005–Jun. 30, 20058%21575
Jul. 1, 2005–Sep. 30, 20058%21575
Oct. 1, 2005–Dec. 31, 20059%23577
Jan. 1, 2006–Mar. 31, 20069%23577
Apr. 1, 2006–Jun. 30, 20069%23577
Jul. 1, 2006–Sep. 30, 200610%25579
Oct. 1, 2006–Dec. 31, 200610%25579
Jan. 1, 2007–Mar. 31, 200710%25579
Apr. 1, 2007–Jun. 30, 200710%25579
Jul. 1, 2007–Sep. 30, 200710%25579
Oct. 1, 2007–Dec. 31, 200710%25579
Jan. 1, 2008–Mar. 31, 20089%71625
Apr. 1, 2008–Sep. 30, 20088%69623
Jul. 1, 2008–Sep. 30, 20087%67621
Oct. 1, 2008–Dec. 31, 20088%69623
Jan. 1, 2009–Mar. 31, 20097%19573
Apr. 1, 2009–Jun. 30, 20096%17571
Jul. 1, 2009–Sep. 30, 20096%17571
Oct. 1, 2009–Dec. 31, 20096%17571
Jan. 1, 2010–Mar. 31, 20106%17571
Apr. 1, 2010–Jun. 30, 20106%17571
Jul. 1, 2010–Sep. 30, 20106%17571
Oct. 1, 2010–Dec. 31, 20106%17571
Jan. 1, 2011–Mar. 31, 20115%15569
Apr. 1, 2011–Jun. 30, 20116%17571
Jul. 1, 2011–Sep. 30, 20116%17571
Oct. 1, 2011–Dec. 31, 20115%15569
Jan. 1, 2012–Mar. 31, 20125%63617
Apr. 1, 2012–Jun. 30, 20125%63617

Bulletin No. 2022–35 167 August 29, 2022
Jul. 1, 2012–Sep. 30, 20125%63617
Oct. 1, 2012–Dec. 31, 20125%63617
Jan. 1, 2013–Mar. 31, 20135%15569
Apr. 1, 2013–Jun. 30, 20135%15569
Jul. 1, 2013–Sep. 30, 20135%15569
Oct. 1, 2013–Dec. 31, 20135%15569
Jan. 1, 2014–Mar. 31, 20145%15569
Apr. 1, 2014–Jun. 30, 20145%15569
Jul. 1, 2014–Sep. 30, 20145%15569
Oct. 1, 2014–Dec. 31, 20145%15569
Jan. 1, 2015–Mar. 31, 20155%15569
Apr. 1, 2015–Jun. 30, 20155%15569
Jul. 1, 2015–Sep. 30, 20155%15569
Oct. 1, 2015–Dec. 31, 20155%15569
Jan. 1, 2016–Mar. 31, 20165%63617
Apr. 1, 2016–Jun. 30, 20166%65619
Jul. 1, 2016–Sep. 30, 20166%65619
Oct. 1, 2016–Dec. 31, 20166%65619
Jan. 1, 2017–Mar. 31, 20176%17571
Apr. 1, 2017–Jun. 30, 20176%17571
Jul. 1, 2017–Sep. 30, 20176%17571
Oct. 1, 2017–Dec. 31, 20176%17571
Jan. 1, 2018–Mar. 31, 20186%17571
Apr. 1, 2018–Jun. 30, 20187%19573
Jul. 1, 2018–Sep. 30, 20187%19573
Oct. 1, 2018–Dec. 31, 20187%19573
Jan. 1, 2019–Mar. 31, 20198%21575
Apr. 1, 2019–Jun. 30, 20198%21575
Jul. 1, 2019–Sep. 30, 20197%19573
Oct. 1, 2019–Dec. 31, 20197%19573
Jan. 1, 2020–Mar. 31, 20207%67621
Apr. 1, 2020–Jun. 30, 20207%67621
Jul. 1, 2020–Sep. 30, 20205%63617
Oct. 1, 2020–Dec. 31, 20205%63617
Jan. 1, 2021–Mar. 31, 20215%15569
Apr. 1, 2021–Jun. 30, 20215%15569
Jul. 1, 2021–Sep. 30, 20215%15569
Oct. 1, 2021–Dec. 31, 20215%15569
Jan. 1, 2022–Mar. 31, 20225%15569
Apr. 1, 2022–Jun. 30, 20226%17571
Jul. 1, 2022–Sep. 30, 20227%19573
Oct. 1, 2022–Dec. 31, 20228%21575

August 29, 2022 168 Bulletin No. 2022–35
TABLE OF INTEREST RATES FOR CORPORATE
OVERPAYMENTS EXCEEDING $10,000
FROM JANUARY 1, 1995 – PRESENT
1995-1 C.B.
RATETABLEPG
Jan. 1, 1995–Mar. 31, 19956.5%18572
Apr. 1, 1995–Jun. 30, 19957.5%20574
Jul. 1, 1995–Sep. 30, 19956.5%18572
Oct. 1, 1995–Dec. 31, 19956.5%18572
Jan. 1, 1996–Mar. 31, 19966.5%66620
Apr. 1, 1996–Jun. 30, 19965.5%64618
Jul. 1, 1996–Sep. 30, 19966.5%66620
Oct. 1, 1996–Dec. 31, 19966.5%66620
Jan. 1, 1997–Mar. 31, 19976.5%18572
Apr. 1, 1997–Jun. 30, 19976.5%18572
Jul. 1, 1997–Sep. 30, 19976.5%18572
Oct. 1, 1997–Dec. 31, 19976.5%18572
Jan. 1, 1998–Mar. 31, 19986.5%18572
Apr. 1, 1998–Jun. 30, 19985.5%16570
Jul. 1, 1998–Sep. 30, 19985.5%16570
Oct. 1, 1998–Dec. 31, 19985.5%16570
Jan. 1, 1999–Mar. 31, 19994.5%14568
Apr. 1, 1999–Sep. 30, 19995.5%16570
Jul. 1, 1999–Sep. 30, 19995.5%16570
Oct. 1, 1999–Dec. 31, 19995.5%16570
Jan. 1, 2000–Mar. 31, 20005.5%64618
Apr. 1, 2000–Jun. 30, 20006.5%66620
Jul. 1, 2000–Sep. 30, 20006.5%66620
Oct. 1, 2000–Dec. 31, 20006.5%66620
Jan. 1, 2001–Mar. 31, 20016.5%18572
Apr. 1, 2001–Jun. 30, 20015.5%16570
Jul. 1, 2001–Sep. 30, 20014.5%14568
Oct. 1, 2001–Dec. 31, 20014.5%14568
Jan. 1, 2002–Mar. 31, 20023.5%12566
Apr. 1, 2002–Jun. 30, 20023.5%12566
Jul. 1, 2002–Sep. 30, 20023.5%12566
Oct. 1, 2002–Dec. 31, 20023.5%12566
Jan. 1, 2003–Mar. 31, 20032.5%10564
Apr. 1, 2003–Jun. 30, 20032.5%10564
Jul. 1, 2003–Sep. 30, 20032.5%10564
Oct. 1, 2003–Dec. 31, 20031.5%8562
Jan. 1, 2004–Mar. 31, 20041.5%56610
Apr. 1, 2004–Jun. 30, 20042.5%58612

Bulletin No. 2022–35 169 August 29, 2022
Jul. 1, 2004–Sep. 30, 20041.5%56610
Oct. 1, 2004–Dec. 31, 20042.5%58612
Jan. 1, 2005–Mar. 31, 20052.5%10564
Apr. 1, 2005–Jun. 30, 20053.5%12566
Jul. 1, 2005–Sep. 30, 20053.5%12566
Oct. 1, 2005–Dec. 31, 20054.5%14568
Jan. 1, 2006–Mar. 31, 20064.5%14568
Apr. 1, 2006–Jun. 30, 20064.5%14568
Jul. 1, 2006–Sep. 30, 20065.5%16570
Oct. 1, 2006–Dec. 31, 20065.5%16570
Jan. 1, 2007–Mar. 31, 20075.5%16570
Apr. 1, 2007–Jun. 30, 20075.5%16570
Jul. 1, 2007–Sep. 30, 20075.5%16570
Oct. 1, 2007–Dec. 31, 20075.5%16570
Jan. 1, 2008–Mar. 31, 20084.5%62616
Apr. 1, 2008–Jun. 30, 20083.5%60614
Jul. 1, 2008–Sep. 30, 20082.5%58612
Oct. 1, 2008–Dec. 31, 20083.5%60614
Jan. 1, 2009–Mar. 31, 20092.5%10564
Apr. 1, 2009–Jun. 30, 20091.5%8562
Jul. 1, 2009–Sep. 30, 20091.5%8562
Oct. 1, 2009–Dec. 31, 20091.5%8562
Jan. 1, 2010–Mar. 31, 20101.5%8562
Apr. 1, 2010–Jun. 30, 20101.5%8562
Jul. 1, 2010–Sep. 30, 20101.5%8562
Oct. 1, 2010–Dec. 31, 20101.5%8562
Jan. 1, 2011–Mar. 31, 20110.5%*
Apr. 1, 2011–Jun. 30, 20111.5%8562
Jul. 1, 2011–Sep. 30, 20111.5%8562
Oct. 1, 2011–Dec. 31, 20110.5%*
Jan. 1, 2012–Mar. 31, 20120.5%*
Apr. 1, 2012–Jun. 30, 20120.5%*
Jul. 1, 2012–Sep. 30, 20120.5%*
Oct. 1, 2012–Dec. 31, 20120.5%*
Jan. 1, 2013–Mar. 31, 20130.5%*
Apr. 1, 2013–Jun. 30, 20130.5%*
Jul. 1, 2013–Sep. 30, 20130.5%*
Oct. 1, 2013–Dec. 31, 20130.5%*
Jan. 1, 2014–Mar. 31, 20140.5%*
Apr. 1, 2014–Jun. 30, 20140.5%*
Jul. 1, 2014–Sep. 30, 20140.5%*
Oct. 1, 2014–Dec. 31, 20140.5%*

August 29, 2022 170 Bulletin No. 2022–35
Jan. 1, 2015–Mar. 31, 20150.5%*
Apr. 1, 2015–Jun. 30, 20150.5%*
Jul. 1, 2015–Sep. 30, 20150.5%*
Oct. 1, 2015–Dec. 31, 20150.5%*
Jan. 1, 2016–Mar. 31, 20160.5%*
Apr. 1, 2016–Jun. 30, 20161.5%56610
Jul. 1, 2016–Sep. 30, 20161.5%56610
Oct. 1, 2016–Dec. 31, 20161.5%56610
Jan. 1, 2017–Mar. 31, 20171.5%8562
Apr. 1, 2017–Jun. 30, 20171.5%8562
Jul. 1, 2017–Sep. 30, 20171.5%8562
Oct. 1, 2017–Dec. 31, 20171.5%8562
Jan. 1, 2018–Mar. 31, 20181.5%8562
Apr. 1, 2018–Jun. 30, 20182.5%10564
Jul. 1, 2018–Sep. 30, 20182.5%10564
Oct. 1, 2018–Dec. 31, 20182.5%10564
Jan. 1, 2019–Mar. 31, 20193.5%12566
Apr. 1, 2019–Jun. 30, 20193.5%12566
Jul. 1, 2019–Sep. 30, 20192.5%10564
Oct. 1, 2019–Dec. 31, 20192.5%10564
Jan. 1, 2020–Mar. 31, 20202.5%58612
Apr. 1, 2020–Jun. 30, 20202.5%58612
Jul. 1, 2020–Sep. 30, 20200.5%*
Oct. 1, 2020–Dec. 31, 20200.5%*
Jan. 1, 2021–Mar. 31, 20210.5%*
Apr. 1, 2021–Jun. 30, 20210.5%*
Jul. 1, 2021–Sep. 30, 20210.5%*
Oct. 1, 2021–Dec. 31, 20210.5%*
Jan. 1, 2022–Mar. 31, 20220.5%*
Apr. 1, 2022–Jun. 30, 20221.5%8562
Jul. 1, 2022–Sep. 30, 20222.5%10564
Oct. 1, 2022–Dec. 31, 20223.5%12566
* The asterisk reflects the interest factors for daily compound interest for annual rates of 0.5 percent published in Appendix A of
this Revenue Ruling.

Bulletin No. 2022–35 171 August 29, 2022
Section 2032A.—Valuation
of Certain Farm, Etc., Real
Property
26 CFR 20.2032A-4: Method of valuing farm real
property.
Rev. Rul. 2022-16
This revenue ruling contains a list of
the average annual effective interest rates
on new loans under the Farm Credit Sys-
tem. This revenue ruling also contains a
list of the states within each Farm Credit
System Bank Territory.
Under § 2032A(e)(7)(A)(ii) of the
Internal Revenue Code, rates on new
Farm Credit System Bank loans are
used in computing the special use value
of real property used as a farm for which
an election is made under § 2032A. The
rates in Table 1 of this revenue ruling
may be used by estates that value farm-
land under § 2032A as of a date in 2022.
Average annual effective interest rates,
calculated in accordance with § 2032A(e)
(7)(A) and § 20.2032A-4(e) of the
Estate Tax Regulations, to be used under
§ 2032A(e)(7)(A)(ii), are set forth in the
accompanying Table of Interest Rates
(Table 1). The states within each Farm
Credit System Bank Territory are set forth
in the accompanying Table of Farm Credit
System Bank Territories (Table 2).
Rev. Rul. 81-170, 1981-1 C.B. 454,
contains an illustrative computation of
an average annual effective interest rate.
The rates applicable for valuation in 2021
are in Rev. Rul. 2021-15, 2021-35 I.R.B.
331. For rate information for years prior
to 2021, see Rev. Rul. 2020-17, 2020-37
I.R.B. 552, and other revenue rulings that
are referenced therein.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Lane Damazo of the Office of the
Associate Chief Counsel (Passthroughs
and Special Industries). For further infor-
mation regarding this revenue ruling, con-
tact Lane Damazo at (202) 317-4628 (not
a toll-free number).
REV. RUL. 2022-16 TABLE 1
TABLE OF INTEREST RATES
(Year of Valuation 2022)
Farm Credit System Bank Servicing State in
Which Property is Located
Rate
AgFirst, FCB5.14
AgriBank, FCB4.57
CoBank, ACB4.47
Texas, FCB4.95
REV. RUL. 2022-16 TABLE 2
TABLE OF FARM CREDIT SYSTEM BANK TERRITORIES
Farm Credit System BankLocation of Property
AgFirst, FCB .........................Delaware, District of Columbia, Florida, Georgia, Maryland, North Carolina,
Pennsylvania, South Carolina, Virginia, West Virginia.
AgriBank, FCB .......................Arkansas, Illinois, Indiana, Iowa, Kentucky, Michigan, Minnesota, Missouri,
Nebraska, North Dakota, Ohio, South Dakota, Tennessee, Wisconsin, Wyoming.
CoBank, ACB ........................Alaska, Arizona, California, Colorado, Connecticut, Hawaii, Idaho, Kansas,
Maine, Massachusetts, Montana, New Hampshire, New Jersey, New Mexico,
New York, Nevada, Oklahoma, Oregon, Rhode Island, Utah, Vermont,
Washington.
Texas, FCB ..........................Alabama, Louisiana, Mississippi, Texas.

August 29, 2022 172 Bulletin No. 2022–35
26 CFR § 301.6104(c)-1
T.D. 9964
DEPARTMENT OF THE
TREASURY
Internal Revenue Service
26 CFR Part 301
Disclosure of Information
to State Officials Regarding
Tax-Exempt Organizations
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations.
SUMMARY: These final regulations
provide guidance to states regarding the
process by which they may obtain or
inspect certain returns and return infor-
mation (including information about
final and proposed denials and revoca-
tions of tax-exempt status) for the pur-
pose of administering State laws gov-
erning certain tax-exempt organizations
and their activities. The final regulations
amend existing regulations to reflect
changes to the Internal Revenue Code
(Code) made by the Pension Protection
Act of 2006 (PPA). The final regulations
will affect the states choosing to obtain
information from the IRS under these
rules, as well as the organizations and
taxable persons whose tax information
is disclosed.
DATES: Effective date: August 16, 2022.
Applicability date: For the date of
applicability, see §301.6104(c)-1(k).
FOR FURTHER INFORMATION
CONTACT: Seth Groman, (202) 317-
5640 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
1. Overview
This document contains amendments
to 26 CFR part 301 under section 6104(c),
which replace current §301.6104(c)-1,
which was issued in 1971, amended in
1973 and 1981, and redesignated in 1982,
in its entirety. Section 6104(c) was added
to the Code by section 101(e) of the Tax
Reform Act of 1969 (Pub. L. 91-172,
83 Stat. 523) and amended by section
1224(a) of the PPA of 2006 (Pub. L. 109-
280, 120 Stat. 1091). Section 6104(c),
as amended by the PPA, governs the cir-
cumstances under which the IRS may
disclose to State officials certain infor-
mation about organizations described in
section 501(c)(3) of the Code, including
private foundations (charitable organiza-
tions), organizations that have applied for
recognition as organizations described in
section 501(c)(3) (applicants), certain
other exempt organizations, and taxable
persons.
On March 15, 2011, the Department of
the Treasury (Treasury Department) and
the IRS published a notice of proposed
rulemaking (NPRM) (REG-140108-08)
in the Federal Register (76 FR 13932).
No public hearing was requested or held.
One comment letter on the NPRM was
received. This Treasury decision adopts
the NPRM with certain changes explained
in the Summary of Comments and Expla-
nation of Provisions.
2. PPA Amendments to Section 6104(c)
Prior to the passage of the PPA, the
IRS was authorized to share certain
information with appropriate State offi-
cers (ASOs). Section 6104(c)(1), which
is unchanged by the PPA, directs the IRS
to notify the ASO of (1) a refusal to rec-
ognize an entity as a charitable organi-
zation; (2) the operation of a charitable
organization in a manner not meeting, or
no longer meeting, the requirements of
its exemption; and (3) the mailing of a
notice of deficiency for any tax imposed
under section 507 or chapter 41 or 42
of the Code. The directive to notify the
ASO of an organization no longer meet-
ing the requirements for exemption under
section 501(c)(3) includes not only pro-
viding the ASO notice of a revocation of
exemption, but also notice (when the IRS
is so informed) that a charitable orga-
nization is terminating or has dissolved
in accordance with its governing docu-
ments. In addition, an ASO, upon request,
may inspect and copy the returns, filed
statements, records, reports, and other
information relating to a final determina-
tion as are relevant to any determination
under State law.
The PPA added section 6104(c)(2)
through (6) of the Code, which expanded
the IRS’s ability to disclose information to
an ASO. With respect to charitable orga-
nizations and applicants, the IRS now is
authorized under section 6104(c)(2) to
disclose information about certain pro-
posed revocations and proposed denials
before an administrative appeal has been
made and a final revocation or denial has
been issued.
Specifically, section 6104(c)(2)(A)(i)
and (ii) provides that the IRS may disclose
to an ASO proposed refusals to recognize
organizations as charitable organizations,
proposed revocations of such recogni-
tion, and notices of proposed deficiency
of excise taxes imposed by section 507
or chapter 41 or 42 of the Code relating
to charitable organizations. Previously,
only final determinations of these kinds
(denials of recognition, revocations, and
notices of deficiency) could be disclosed
under section 6104(c).
Section 6104(c)(2)(A)(iii) provides
that the IRS may disclose to an ASO the
names, addresses, and taxpayer identifi-
cation numbers of applicants. Previously,
information on applicants, other than
information relating to a final denial of
recognition, could not be disclosed under
section 6104(c).
Section 6104(c)(2)(B) provides that the
IRS may disclose to an ASO the returns
and return information of organizations
with respect to which information is dis-
closed under section 6104(c)(2)(A) (pro-
posed determinations and applicant iden-
tifying information). Prior law allowed
for disclosure under section 6104(c) only
of returns and return information of orga-
nizations related to their receipt of final
determinations.
Section 6104(c)(2)(C) provides that
proposed determinations, applicant identi-
fying information, and the related returns
and return information with respect to
charitable organizations and applicants
under sections 6104(c)(2)(A) or (B) may
be disclosed to an ASO only upon the
ASO’s written request and only as nec-
essary to administer State laws regulat-
ing charitable organizations. Prior law

Bulletin No. 2022–35 173 August 29, 2022
provided for automatic disclosure – with
no requirement for a disclosure request –
but only of final determinations.
Under section 6104(c)(2)(D), the IRS
may disclose to an ASO, on its own ini-
tiative and without a written request,
returns and return information with
respect to charitable organizations and
applicants if the IRS determines that this
information may constitute evidence of
noncompliance with the laws under the
jurisdiction of the ASO. Thus, if the IRS
determines these conditions to be met,
it may, for example, disclose to an ASO
a proposed revocation of exemption for
a charitable organization that does not
have a determination letter. There was
no such provision under section 6104(c)
previously.
Section 6104(c)(3) provides that the
IRS may disclose returns and return infor-
mation of organizations described in sec-
tion 501(c), other than those described in
section 501(c)(1) or (3) (such as section
501(c)(4) social welfare organizations,
section 501(c)(5) labor organizations, and
section 501(c)(6) business leagues), to an
ASO upon the ASO’s written request, but
only for the purpose of, and to the extent
necessary in, administering State laws reg-
ulating the solicitation or administration
of charitable funds or charitable assets of
such organizations. Previously, only infor-
mation relating to charitable organizations
or applicants was disclosed under section
6104(c).
Section 6104(c)(4) generally provides
that returns and return information of orga-
nizations and taxable persons disclosed
under section 6104(c) may be disclosed in
civil administrative and civil judicial pro-
ceedings pertaining to the enforcement of
State laws regulating such organizations,
under procedures prescribed by the IRS
similar to those under section 6103(h)(4).
There was no such provision under sec-
tion 6104(c) previously.
Section 6104(c)(5) generally provides
that no return or return information may
be disclosed under section 6104(c) to the
extent the IRS determines that such dis-
closure would seriously impair Federal
tax administration. This disclosure pro-
hibition, though new in the Code, was
provided previously by regulation. See
former §301.6104(c)-1(b)(3)(ii) (replaced
by these final regulations).
Sections 6104(c)(2)(C) (flush language)
and (c)(3) provide that the IRS may
disclose returns and return information
under section 6104(c) to a State officer
or employee designated by the ASO to
receive such information on the ASO’s
behalf. Prior law did not provide for IRS
disclosures to persons other than ASOs.
Section 6104(c)(6)(B) defines an ASO
as the State attorney general, the State tax
officer, any State official charged with
overseeing charitable organizations (in
the case of charitable organizations and
applicants), and the head of the State
agency designated by the State attorney
general as having the primary responsi-
bility for overseeing the solicitation of
funds for charitable purposes (in the case
of section 501(c) organizations other than
Federal instrumentalities and charitable
organizations). Before its amendment by
the PPA, section 6104(c)(2) defined ASO
as the State attorney general, the State
tax officer, or any State official charged
with overseeing organizations of the type
described in section 501(c)(3).
3. PPA Amendments to Related Code
Provisions
The PPA also amended section 6103 to
make section 6104(c), in its entirety, sub-
ject to its confidentiality and disclosure
provisions.
Section 6103(a)(2) provides the gen-
eral rule that returns and return informa-
tion are confidential and that an officer or
employee of a State who receives returns
or return information from the IRS under
section 6104(c) must not disclose such
information, except as authorized by Title
26 of the United States Code.
Section 6103(p)(3) requires the IRS to
maintain permanent standardized records
of all requests for inspection or disclosure
of returns or return information under sec-
tion 6104(c) and of all such information
inspected or disclosed pursuant to those
requests.
Section 6103(p)(4) requires an ASO, as
a condition for receiving returns or return
information under section 6104(c), to
establish and maintain certain safeguards,
such as keeping permanent standardized
records of all requests and disclosures,
maintaining a secure information storage
area, restricting access to the information,
and providing whatever other safeguards
the IRS deems necessary to protect the
confidentiality of the information. See
§301.6103(p)(4)-1 and IRS Publication
1075, “Tax Information Security Guide-
lines for Federal, State and Local Agen-
cies”. Publication 1075 is available at
http://www.irs.gov/formspubs.
The PPA also amended sections 7213,
7213A, and 7431 to impose civil and
criminal penalties for the unauthorized
disclosure or inspection of section 6104(c)
information.
4. IRS Disclosure Procedures
Under section 6103(p)(4)(E), before
a Federal or State agency may receive
returns and return information from the
IRS under section 6103 or section 6104,
it must file with the IRS a report detailing
the physical, administrative, and technical
safeguards implemented by the agency
to protect this information from unautho-
rized inspection or disclosure. Only upon
approval of these safeguards by the IRS,
as well as satisfaction of any other statu-
tory requirements (such as submission of
a written request), may an agency receive
the information to which it is entitled
under the Code, and then only for the use
specified by the relevant statute.
Under various disclosure programs,
the IRS and other Federal and State agen-
cies often execute disclosure agreements
detailing the responsibilities of the par-
ties and the terms and parameters of the
disclosure arrangement. For example,
under section 6103(d), the IRS executes
a disclosure agreement with each State
tax agency to which it discloses infor-
mation. This agreement, which serves as
the written request required by section
6103(d), has been the foundation of the
State tax disclosure program under this
provision since the Tax Reform Act of
1976.
After the enactment of the PPA, the IRS
revised its disclosure procedures under
section 6104(c), as set forth in the Inter-
nal Revenue Manual, to model them after
the section 6103(d) program. Accordingly,
the section 6104(c) program uses a disclo-
sure agreement patterned after the section
6103(d) agreement but tailored to the spe-
cific requirements and restrictions of sec-
tion 6104(c).

August 29, 2022 174 Bulletin No. 2022–35
Summary of Comments and
Explanation of Provisions
As noted in the Background, one com-
menter submitted a letter commenting on
the NPRM. After considering the com-
ments in the letter, the NPRM is adopted by
this Treasury decision with one clarifying
substantive change to §301.6104(c)-1(h)
of the proposed regulations (proposed
§301.6104(c)-1(h)) and various non-sub-
stantive clarifying changes.
1. Security, Confidentiality, and Use
Restrictions
The commenter’s primary concern is
the requirement that all disclosures under
section 6104(c) must be made pursuant
to an agreement committing the ASO
to the security, confidentiality, and use
restrictions of section 6103(p)(4), which
the commenter characterizes as onerous.
The commenter acknowledges, however,
that the changes it seeks require legisla-
tive action by Congress. The Treasury
Department and the IRS agree that the
proposed regulations implement the stat-
utory regime enacted by Congress. Thus,
these final regulations adopt the safeguard
requirements as proposed.
As a threshold matter, the com-
menter asserts that only a few states have
entered into disclosure agreements due
to what the commenter characterizes as
the cumbersome nature of the safeguard
requirements of section 6103(p) and the
resources needed to adhere to them. In
the commenter’s view, the reluctance
of states to commit themselves to the
safeguard requirements of section 6103
means that the PPA actually decreased
the disclosure of information to the states
because non-participating states no longer
receive the pre-PPA notifications of final
denials, revocations, and notices of tax
deficiencies.
The Treasury Department and the
IRS do not agree with the proposition
that few states are willing to participate
in IRS information-sharing programs
because of the safeguard requirements.
As noted in the Background, the section
6104(c) agreement, under which the IRS
discloses certain information to the ASO
who is charged with the administration
of the State’s laws regulating charitable
organizations or the solicitation or admin-
istration of charitable funds or assets, is
based on the section 6103(d) agreement,
under which the IRS discloses certain
information to the State office charged
with the responsibility for administering
the State’s tax laws. Under both section
6104(c) and section 6103(d), the receipt
of information from the IRS is condi-
tioned on the recipient agency or official
implementing and adhering to the appli-
cable provisions of section 6103(p), as
amended by the PPA, to protect the infor-
mation from unauthorized inspection or
disclosure.
The IRS currently has a section 6103(d)
agreement in each of the 50 states and the
District of Columbia with the agency or
official responsible for administering that
jurisdiction’s tax laws. In addition, the
IRS currently has section 6104(c) agree-
ments with 9 ASOs, all of whom are State
tax officers responsible for administer-
ing State tax laws. For sample disclosure
agreements, see Internal Revenue Man-
ual Exhibit 7.28.2-2 (Sample Disclosure
Agreement under section 6104(c) for State
Tax Officer) and Exhibit 7.28.2-1 (Sam-
ple Disclosure Agreement under section
6104(c) for Attorney General’s Office).
In view of the current participation in the
section 6104(c) disclosure program, and
considering the potential for increased
participation by other ASOs, the Treasury
Department and the IRS consider the pub-
lication of these final regulations import-
ant in fulfilling the mandate under section
6104(c) to facilitate the enforcement of
State law regarding exempt organizations
consistent with statutory requirements.
2. Information Shared Without a
Disclosure Agreement
The commenter, citing proposed
§301.6104(c)-1(b), which provides that
the IRS may require an ASO to execute
a disclosure agreement or similar docu-
ment, states that it is not clear what, if any
information – other than that available to
the general public – would be disclosed to
ASOs without an agreement.
Under section 6104(c) before its
amendment by the PPA, the IRS was
required to disclose to ASOs certain final
determinations, with no requirement
that the ASO request such disclosure in
writing. The PPA changed this procedure,
making all of section 6104(c) subject to
the confidentiality provisions of section
6103. These final regulations provide that
the IRS may not disclose information
under section 6104(c) unless the State
receiving the information follows the
applicable disclosure, recordkeeping, and
safeguard procedures of section 6103(p)
(4). To give effect to the confidentiality
restrictions mandated by Congress, the
IRS’s disclosure program requires an ASO
to enter into a disclosure agreement with
the IRS stipulating the procedures for dis-
closure under section 6104(c), as well as
the restrictions on use and redisclosure.
Because of these statutory requirements,
without such an agreement, an ASO may
receive only information otherwise avail-
able to the public.
3. Use of Disclosed Information
The commenter objects to proposed
§301.6104(c)-1(h)(1), which requires
an ASO intending to use any disclosed
information in a State administrative or
judicial proceeding to notify the IRS of
this intention before such use. Under this
provision, an ASO may use the informa-
tion as intended only in accordance with
any conditions the IRS might impose,
and only to the extent that the IRS deter-
mines that the disclosure would not seri-
ously impair Federal tax administration.
The commenter states that by disclosing
taxpayer information initially to an ASO,
the IRS already has determined under pro-
posed §301.6104(c)-1(e) that this infor-
mation will not seriously impair Federal
tax administration and that requiring the
same determination again after the initial
disclosure would place an ASO at risk of
spending time and resources on develop-
ing a State law case, only to be told by
the IRS that the ASO cannot proceed. The
commenter asserts that, in an environ-
ment of scarce resources, this restriction
is likely to discourage ASOs from taking
that risk.
Section 6104(c)(5) prohibits the dis-
closure under section 6104(c)(1) through
(3) of returns and return information to an
ASO, or redisclosure of such information
by an ASO in a State proceeding described
in section 6104(c)(4), if the IRS deter-
mines that such disclosure or redisclosure

Bulletin No. 2022–35 175 August 29, 2022
would seriously impair Federal tax admin-
istration. Section 6104(c)(5) addresses
two separate actions or events, requiring
in most circumstances two separate deter-
minations by the IRS. Because the facts
and circumstances surrounding a particu-
lar administrative or judicial proceeding
typically would not be known to the IRS
at the time of the initial disclosure of tax-
payer information to an ASO, it would not
be possible during the initial disclosure to
the ASO for the IRS to determine whether
the use of that information in a subse-
quent State proceeding would seriously
impair Federal tax administration (such
as identifying a confidential informant
or compromising a civil or criminal tax
investigation). It is possible that the IRS
could determine that the disclosure to an
ASO would not seriously impair Federal
tax administration but that disclosure by
an ASO in a State proceeding would. To
fulfill its statutory duties, the IRS must
evaluate the effect of the use of disclosed
information in a State proceeding before
authorizing any such redisclosure.
4. Restrictions on Redisclosure
The commenter states that the pro-
hibition in proposed §301.6104(c)-1(h)
(2) on the redisclosure of return infor-
mation to an ASO’s agent or contractor
appears to include persons such as expert
witnesses, court reporters, and other lit-
igation support service providers often
necessary to conduct civil and judicial
proceedings within the ambit of pro-
posed §301.6104(c)-1(g)(2), as limited
by proposed §301.6104(c)-1(h)(1), which
is discussed in the prior section of this
Summary of Comments and Explanation
of Provisions. The commenter contends
that this restriction is “simply untenable”
and serves to “further undercut any ratio-
nal basis” for ASOs to obtain returns and
return information under section 6104(c).
The requirement in proposed
§301.6104(c)-1(h)(1) that an ASO notify
the IRS before using any disclosed infor-
mation in a State proceeding is a limit on
the authority of the ASO under proposed
§301.6104(c)-1(g)(2) to make such use of
disclosed information under rules similar to
those in section 6103(h)(4), as provided in
section 6104(c)(4). With respect to section
6103(h)(4), the IRS construes “disclosure
in judicial and administrative proceed-
ings” to include the disclosure of returns
and return information in court during a
trial (whether or not some of those pres-
ent might be considered an agent or con-
tractor, such as a court reporter or expert
witness); in formal or informal discovery,
including depositions; in settlement negoti-
ations; and in mediation or arbitration pro-
ceedings. Disclosure of returns and return
information is permitted to participants in,
or parties to, a judicial or administrative
proceeding (including expert witnesses)
under practices and procedures generally
applicable to the proceeding, and subject to
rules governing the proceeding. The prohi-
bition in proposed §301.6104(c)-1(h)(2) on
the redisclosure of return information to an
ASO’s agent or contractor was not intended
to hinder a State’s ability to conduct inves-
tigations or civil litigation under its statu-
tory authority.
In considering this comment regarding
the interaction of the two redisclosure lim-
itations of proposed §301.6104(c)-1(h),
however, it became apparent that, by
identifying the agent-contractor disclo-
sure prohibition as one of two limita-
tions on the redisclosure of returns and
return information by an ASO, proposed
§301.6104(c)-1(h)(2) might be read as
limiting the application of such a restric-
tion solely to redisclosures. The prohibi-
tion on disclosing to agents and contrac-
tors, however, is a broader rule, applying
both to initial disclosures by the IRS as
well as to subsequent redisclosures by an
ASO. With respect to disclosures by the
IRS, proposed §301.6104(c)-1(f)(1)(ii)
provides that the IRS may disclose return
information to someone other than the
ASO only if that person is a State officer
or employee designated by the ASO. With
respect to redisclosures by an ASO, pro-
posed §301.6104(c)-1(g)(1) provides that
an ASO who receives information from
the IRS under section 6104(c) may redis-
close that information for certain purposes
to another State officer or employee. The
legislative history of section 6104(c) pro-
vides that the term “officer or employee”
does not include agents and contrac-
tors, and the final regulations apply this
agent-contractor disclosure prohibition
equally to the IRS and the ASO.
Consequently, these final regula-
tions clarify the proper application of
the prohibition against disclosure to
agents and contractors by eliminat-
ing proposed §301.6104(c)-1(h)(2) and
adding definitional clauses to proposed
§301.6104(c)-1(f)(1)(ii) and (g)(1) and
(2) emphasizing that the agent-contractor
disclosure prohibition applies both to IRS
disclosures and to ASO redisclosures.
5. Application of Document Retention
and Freedom-of-Information Laws
The commenter notes that many
states have document retention and free-
dom-of-information laws that might be
implicated whenever an ASO receives or
acts upon tax return information acquired
from the IRS. According to the com-
menter, nothing in the PPA or regulations
addresses what portions of tax return
information may become a part of the
ASO’s own records or work product.
This issue, however, is addressed by
section 6103, made applicable to section
6104(c) by the PPA. Among the disclosure,
recordkeeping, and safeguard provisions of
section 6103, section 6103(p)(4) requires
an ASO, as a condition for receiving
returns or return information under section
6104(c), to establish and maintain certain
safeguards, such as keeping permanent
standardized records of all requests and
disclosures, maintaining a secure informa-
tion storage area, restricting access to the
information, and providing whatever other
safeguards the IRS deems necessary to pro-
tect the confidentiality of the information.
Upon completion of the ASO’s use of the
returns or return information it receives
under section 6104(c), section 6103(p)(4)
(F) requires the ASO to return the infor-
mation, along with any copies, to the IRS,
or to render it undisclosable and report to
the IRS how it was so rendered. Rendering
returns and return information undisclos-
able requires the ASO to physically destroy
the information. Thus, after its use, any
information an ASO receives from the IRS
under section 6104(c) should no longer be
in the ASO’s possession and, so, will not
become part of the ASO’s own records or
work product.
6. Designation by Attorney General
Referring to the definition of an ASO
in section 6104(c)(6)(B)(iv) (in the case

August 29, 2022 176 Bulletin No. 2022–35
of tax-exempt entities other than charita-
ble organizations or Federal instrumen-
talities), the commenter states that it is
not clear in what circumstances an attor-
ney general would designate the agency
responsible for overseeing charitable
solicitation. If, for example, the author-
ity to designate the head of the agency
responsible for overseeing charitable
solicitation is vested in the secretary of
state, the agency head referred to in the
statute and the regulations would not be
able to meet the definition of an ASO in
proposed §301.6104(c)-1(i)(1)(iv).
In light of the variations in State laws,
it is doubtful that Congress used the term
“designate” in section 6104(c)(6)(B)(iv)
to mean a delegation of legal authority
(and there is no indication in the legisla-
tive history of the PPA that such a meaning
was intended). In contrast to how the term
is used in section 6104(c)(2)(C) (dealing
with the procedures for disclosure), where
it does mean to delegate authority, the
term “designate” in section 6104(c)(6)(B)
(iv) is a generic one, meaning the ability
to specify, identify, or acknowledge the
head of the agency in a particular State
who is responsible for overseeing char-
itable solicitation. The attorney general,
as an ASO under §301.6104(c)-1(i)(1)(i),
should be able to identify such an agency
head, whether or not the attorney general
is able to confer the requisite authority on
any particular State official.
Special Analyses
This regulation is not subject to review
under section 6(b) of Executive Order
12866 pursuant to the Memorandum of
Agreement (April 11, 2018) between the
Department of the Treasury and the Office
of Management and Budget regarding
review of tax regulations.
Pursuant to the Regulatory Flexibil-
ity Act (RFA) (5 U.S.C. chapter 6), it is
hereby certified that these final regula-
tions will not have a significant economic
impact on a substantial number of small
entities within the meaning of section
601(6) of the Regulatory Flexibility Act.
The analysis requirements of the RFA
do not apply because states are not con-
sidered small entities for purposes of the
RFA. Therefore, a regulatory flexibility
analysis is not required. Accordingly, the
Secretary of the Treasury’s delegate certi-
fies that these regulations will not have a
significant economic impact on a substan-
tial number of small entities.
Pursuant to section 7805(f) of the
Code, the notice of proposed rulemak-
ing preceding these final regulations was
submitted to the Chief Counsel for the
Office of Advocacy of the Small Business
Administration for comment on its impact
on small business. No comments were
received from the Chief Counsel for the
Office of Advocacy of the Small Business
Administration.
Drafting Information
The principal author of these regu-
lations is Seth Groman of the Office of
Associate Chief Counsel (Employee Ben-
efits, Exempt Organizations, and Employ-
ment Taxes), though other persons in the
Treasury Department and the IRS partici-
pated in their development.
List of Subjects in 26 CFR Part 301
Employment taxes, Estate taxes, Excise
taxes, Gift taxes, Income taxes, Penalties,
Reporting and recordkeeping requirements.
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR part 301 is
amended as follows:
PART 301—PROCEDURE AND
ADMINISTRATION
Paragraph 1. The authority citation for
part 301 is amended by adding an entry
for §301.6104(c)-1 in numerical order to
read in part as follows:
Authority: 26 U.S.C. 7805 * * *
* * * * *
Section 301.6104(c)-1 also issued
under 26 U.S.C. 6104(c).
* * * * *
Par. 2. Section 301.6104(c)-1 is revised
to read as follows:
§ 301.6104(c)-1 Disclosure of certain
information to State officials.
(a) In general—(1) Charitable orga-
nizations and applicants. Subject to the
disclosure, recordkeeping, and safeguard
provisions of section 6103 of the Internal
Revenue Code (Code), and only as nec-
essary to administer State laws regulating
charitable organizations, upon written
request by an appropriate State officer
(ASO, as defined in paragraph (i)(1) of
this section), the Internal Revenue Service
(IRS) may, under section 6104(c)(1) and
(2), disclose or make available to the ASO
(or to a person designated by the ASO as
provided in paragraph (f)(1)(ii) of this
section) the returns and return information
described in paragraph (c) of this section
with respect to—
(i) Any organization described or for-
merly described in section 501(c)(3) and
exempt or formerly exempt from taxation
under section 501(a) (a charitable organi-
zation); or
(ii) Any organization that has applied for
recognition as an organization described
in section 501(c)(3) (an applicant).
(2) Section 501(c) organizations not
described in section 501(c)(1) or (3).
Subject to the disclosure, recordkeeping,
and safeguard provisions of section 6103,
and upon written request by an ASO, the
IRS may disclose or make available to the
ASO (or to a person designated by the
ASO as provided in paragraph (f)(1)(ii)
of this section) under section 6104(c)(3)
returns and return information regarding
any organization described or formerly
described in section 501(c) other than
section 501(c)(1) or (3). Such information
will be disclosed or made available only
as necessary to administer State laws reg-
ulating the solicitation or administration
of the charitable funds or charitable assets
of these organizations.
(b) Disclosure agreement. The IRS may
require an ASO to execute a disclosure
agreement or similar document specifying
the procedures, terms, and conditions for
the disclosure or inspection of information
under section 6104(c), including compli-
ance with the safeguards prescribed by
section 6103(p)(4), as well as specifying
the information to be disclosed. Such an
agreement or similar document constitutes
the request for disclosure required by sec-
tion 6104(c)(1)(C), as well as the written
request required by section 6104(c)(2)(C)
(i) and (c)(3).
(c) Disclosures regarding charitable
organizations and applicants—(1) In

Bulletin No. 2022–35 177 August 29, 2022
general. With respect to any organization
described in paragraph (d) of this section,
the IRS may disclose or make available
for inspection under section 6104(c)(1)
and (2) and paragraph (a)(1) of this sec-
tion to an ASO the following returns and
return information with respect to a chari-
table organization or applicant:
(i) A refusal or proposed refusal to
recognize an organization’s exemption as
a charitable organization (a final or pro-
posed denial letter).
(ii) Return information regarding a
grant of exemption following a proposed
denial.
(iii) A revocation of exemption as a
charitable organization (a final revocation
letter), including a notice of termination or
dissolution.
(iv) A proposed revocation of recogni-
tion of exemption as a charitable organiza-
tion (a proposed revocation letter).
(v) Return information regarding the
final disposition of a proposed revoca-
tion of recognition other than by final
revocation.
(vi) A notice of deficiency or proposed
notice of deficiency of tax imposed under
section 507 or chapter 41 or 42 of the
Code on the organization or on a taxable
person (as described in paragraph (i)(4) of
this section).
(vii) Returns and return information
regarding the final disposition of a pro-
posed notice of deficiency of tax imposed
under section 507 or chapter 41 or 42 of
the Code on the organization other than by
issuance of a notice of deficiency.
(viii) The names, addresses, and tax-
payer identification numbers of appli-
cants for charitable status, provided on an
applicant-by-applicant basis or by peri-
odic lists of applicants. Under this para-
graph (c)(1)(viii), the IRS may respond
to inquiries from an ASO as to whether
a particular organization has applied for
recognition of exemption as a charitable
organization.
(ix) Return information regarding the
final disposition of an application for
recognition of exemption where no pro-
posed denial letter is issued, including
whether the application was withdrawn or
whether the applicant failed to establish
its exemption.
(x) Returns and return information relat-
ing to the return information described in
paragraph (c)(1) of this section, except for
returns and return information relating to
proposed notices of deficiency described
in paragraph (c)(1)(vi) of this section with
respect to taxable persons.
(2) Disclosure of evidence of non-
compliance with certain State laws. With
respect to any organization described
in paragraph (d) of this section, the IRS
may disclose to the ASO or make avail-
able for the ASO’s inspection under sec-
tion 6104(c)(1) and (2) and paragraph (a)
(1) of this section the returns and return
information of a charitable organization
or applicant, as listed in paragraph (c)
(1) of this section, if the IRS determines
that such information might constitute
evidence of noncompliance with the laws
under the jurisdiction of the ASO regu-
lating charitable organizations and appli-
cants. Such information may be disclosed
on the IRS’s own initiative, subject to the
disclosure, recordkeeping, and safeguard
provisions of section 6103. Disclosures
under this paragraph (c)(2) may be made
before the IRS issues a proposed determi-
nation (denial of recognition, revocation,
or notice of deficiency) or any other action
by the IRS described in this section.
(d) Organizations to which disclo-
sure applies. Regarding the information
described in paragraphs (a)(1) and (2) of
this section, the IRS will disclose or make
available for inspection to an ASO such
information only with respect to—
(1) An organization formed under the
laws of the ASO’s State;
(2) An organization, the principal office
of which is located in the ASO’s State;
(3) An organization that, as determined
by the IRS, is or might be subject to the
laws of the ASO’s State regulating char-
itable organizations or the solicitation or
administration of charitable funds or char-
itable assets; or
(4) A private foundation required by
§1.6033-2(a)(iv) of this chapter to list the
ASO’s State on any of the foundation’s
returns filed for its last five taxable years.
(e) Disclosure limitations. Notwith-
standing any other provision of this sec-
tion, the IRS will not disclose or make
available for inspection under section
6104(c) any information, the disclosure
of which it determines would seriously
impair Federal tax administration, includ-
ing, but not limited to—
(1) Identification of a confidential
informant or interference with a civil or
criminal tax investigation; and
(2) Information obtained pursuant to
a tax convention, as defined in section
6105(c)(2), between the United States and
a foreign government.
(f) Disclosure recipients—(1) In gen-
eral. The IRS may disclose returns and
return information under section 6104(c)
to, or make it available for inspection by—
(i) An ASO, as defined in paragraph (i)
(1) of this section, or
(ii) A person other than an ASO, but
only if that person is a State officer or
employee (which excludes an agent or
contractor) designated by the ASO to
receive information under section 6104(c)
on behalf of the ASO, as specified in para-
graph (f)(2) of this section.
(2) Designation by ASO. An ASO may
designate State officers or employees to
receive information under section 6104(c)
on the ASO’s behalf by specifying in writ-
ing each person’s name and job title, and
the name and address of the person’s office.
The ASO must promptly notify the IRS in
writing of any additions, deletions, or other
changes to the list of designated persons.
(g) Redisclosure—(1) In general. An
ASO to whom a return or return infor-
mation has been disclosed may thereafter
disclose such information to another State
officer or employee (which excludes an
agent or contractor) only as necessary to
administer State laws governing charitable
organizations or State laws regulating the
solicitation or administration of charitable
funds or charitable assets of noncharitable
exempt organizations.
(2) Civil administrative or judicial
proceedings. Except as provided in para-
graph (h) of this section, an ASO to whom
a return or return information has been
disclosed may thereafter disclose such
information to another State officer or
employee (which excludes an agent or
contractor) who is personally and directly
preparing for a civil proceeding before
a State administrative body or court in a
matter involving the enforcement of State
laws regulating organizations with respect
to which information can be disclosed
under this section, solely for use in such a
proceeding, but only if—
(i) The organization or a taxable per-
son is a party to the proceeding, or the

August 29, 2022 178 Bulletin No. 2022–35
proceeding arose out of, or in connection
with, determining the civil liability of the
organization or a taxable person, or col-
lecting such civil liability, under State
laws governing organizations with respect
to which information can be disclosed
under this subsection;
(ii) The treatment of an item reflected
on such a return is directly related to the
resolution of an issue in the proceeding; or
(iii) The return or return information
directly relates to a transactional relation-
ship between the organization or a taxable
person and a person who is a party to the
proceeding that directly affects the resolu-
tion of an issue in the proceeding.
(h) Redisclosure limitation. Before dis-
closing any return or return information
received under section 6104(c) in a pro-
ceeding described in paragraph (g)(2) of
this section, the ASO must notify the IRS
of the intention to make such a disclosure.
No State officer or employee may make
such a disclosure except in accordance
with any conditions the IRS might impose
in response to the ASO’s notice of intent.
No such disclosure may be made if the IRS
determines that the disclosure would seri-
ously impair Federal tax administration.
(i) Definitions. For purposes of section
6104(c) and this section—
(1) Appropriate State officer or ASO
means—
(i) The State attorney general;
(ii) The State tax officer;
(iii) With respect to a charitable orga-
nization or applicant, any State officer
other than the attorney general or tax offi-
cer charged with overseeing charitable
organizations, provided that the officer
shows the IRS that the officer is an ASO
by presenting a letter from the State attor-
ney general describing the functions and
authority of the officer under State law,
with sufficient facts for the IRS to deter-
mine that the officer is an ASO; and
(iv) With respect to a section 501(c)
organization that is not described in sec-
tion 501(c)(1) or (c)(3), the head of the
agency designated by the State attorney
general as having primary responsibility
for overseeing the solicitation of funds
for charitable purposes, provided that the
officer shows the IRS that the officer is an
ASO by presenting a letter from the State
attorney general describing the functions
and authority of the officer under State
law, with sufficient facts for the IRS to
determine that the officer is an ASO.
(2) Return has the same meaning as in
section 6103(b)(1).
(3) Return information has the same
meaning as in section 6103(b)(2).
(4) Taxable person means any per-
son who is liable or potentially liable for
excise taxes under chapter 41 or 42 of the
Code. Such a person includes—
(i) A disqualified person described in
section 4946(a)(1), 4951(e)(4), or 4958(f);
(ii) A foundation manager described in
section 4946(b);
(iii) An organization manager described
in section 4955(f)(2) or 4958(f)(2);
(iv) A person described in section
4958(c)(3)(B);
(v) An entity manager described in sec-
tion 4965(d); and
(vi) A fund manager described in sec-
tion 4966(d)(3).
(j) Failure to comply. Upon a determi-
nation that an ASO has failed to comply
with the requirements of section 6103(p)
(4), the IRS may take the actions it deems
necessary to ensure compliance, including
the refusal to disclose any further returns
or return information to the ASO until
the IRS determines that the requirements
of section 6103(p)(4) have been met. For
procedures for the administrative review
of a determination that an authorized
recipient has failed to safeguard returns
or return information, see §301.6103(p)
(7)-1.
(k) Applicability date. The rules of
this section apply on and after August 16,
2022.
Douglas W. O’Donnell,
Deputy Commissioner for Services
and Enforcement.
Approved: June 7, 2022.
Lily Batchelder,
Assistant Secretary of the Treasury
(Tax Policy).
(Filed by the Office of the Federal Register on August
15, 2022, 8:45 a.m., and published in the issue of the
Federal Register for August 16, 2022, 87 F.R. 50240)

Bulletin No. 2022–35 179 August 29, 2022
Part IV
Announcement of
Disciplinary Sanctions
From the Office of
Professional Responsibility
Announcement 2022-17
The Office of Professional Respon-
sibility (OPR) announces recent disci-
plinary sanctions involving attorneys, cer-
tified public accountants, enrolled agents,
enrolled actuaries, enrolled retirement
plan agents, appraisers, and unenrolled/
unlicensed return preparers (individuals
who are not enrolled to practice and are
not licensed as attorneys or certified pub-
lic accountants). Licensed or enrolled
practitioners are subject to the regulations
governing practice before the Internal
Revenue Service (IRS), which are set out
in Title 31, Code of Federal Regulations,
Subtitle A, Part 10, and which are released
as Treasury Department Circular No.
230. The regulations prescribe the duties
and restrictions relating to such practice
and prescribe the disciplinary sanctions
for violating the regulations. Unenrolled/
unlicensed return preparers are subject to
Revenue Procedure 81-38 and supersed-
ing guidance in Revenue Procedure 2014-
42, which govern a preparer’s eligibility
to represent taxpayers before the IRS in
examinations of tax returns the preparer
both prepared for the taxpayer and signed
as the preparer. Additionally, unenrolled/
unlicensed return preparers who volun-
tarily participate in the Annual Filing Sea-
son Program under Revenue Procedure
2014-42 agree to be subject to the duties
and restrictions in Circular 230, including
the restrictions on incompetent or disrep-
utable conduct.
The disciplinary sanctions to be
imposed for violation of the applicable
standards are:
Disbarred from practice before the
IRS—An individual who is disbarred
is not eligible to practice before the IRS
as defined at 31 C.F.R. § 10.2(a)(4) for a
minimum period of five (5) years.
Suspended from practice before the
IRS—An individual who is suspended is
not eligible to practice before the IRS as
defined at 31 C.F.R. § 10.2(a)(4) during
the term of the suspension.
Censured in practice before the
IRS—Censure is a public reprimand.
Unlike disbarment or suspension, censure
does not affect an individual’s eligibility
to practice before the IRS, but OPR may
subject the individual’s future practice
rights to conditions designed to promote
high standards of conduct.
Monetary penalty—A monetary pen-
alty may be imposed on an individual who
engages in conduct subject to sanction,
or on an employer, firm, or entity if the
individual was acting on its behalf and it
knew, or reasonably should have known,
of the individual’s conduct.
Disqualification of appraiser—An
appraiser who is disqualified is barred
from presenting evidence or testimony in
any administrative proceeding before the
Department of the Treasury or the IRS.
Ineligible for limited practice—An
unenrolled/unlicensed return preparer
who fails to comply with the requirements
in Revenue Procedure 81-38 or to comply
with Circular 230 as required by Revenue
Procedure 2014-42 may be determined
ineligible to engage in limited practice as
a representative of any taxpayer.
Under the regulations, individuals
subject to Circular 230 may not assist, or
accept assistance from, individuals who
are suspended or disbarred with respect
to matters constituting practice (i.e., rep-
resentation) before the IRS, and they may
not aid or abet suspended or disbarred
individuals to practice before the IRS.
Disciplinary sanctions are described in
these terms:
Disbarred by decision, Suspended by
decision, Censured by decision, Mone-
tary penalty imposed by decision, and
Disqualified after hearing—An adminis-
trative law judge (ALJ) issued a decision
imposing one of these sanctions after the
ALJ either (1) granted the government’s
summary judgment motion or (2) con-
ducted an evidentiary hearing upon OPR’s
complaint alleging violation of the regula-
tions. After 30 days from the issuance of
the decision, in the absence of an appeal,
the ALJ’s decision becomes the final
agency decision.
Disbarred by default decision, Sus-
pended by default decision, Censured
by default decision, Monetary penalty
imposed by default decision, and Dis-
qualified by default decision—An ALJ,
after finding that no answer to OPR’s com-
plaint was filed, granted OPR’s motion for
a default judgment and issued a decision
imposing one of these sanctions.
Disbarment by decision on appeal,
Suspended by decision on appeal, Cen-
sured by decision on appeal, Mone-
tary penalty imposed by decision on
appeal, and Disqualified by decision
on appeal—The decision of the ALJ was
appealed to the agency appeal authority,
acting as the delegate of the Secretary
of the Treasury, and the appeal authority
issued a decision imposing one of these
sanctions.
Disbarred by consent, Suspended by
consent, Censured by consent, Mone-
tary penalty imposed by consent, and
Disqualified by consent—In lieu of a
disciplinary proceeding being instituted
or continued, an individual offered a con-
sent to one of these sanctions and OPR
accepted the offer. Typically, an offer of
consent will provide for: suspension for
an indefinite term; conditions that the
individual must observe during the sus-
pension; and the individual’s opportu-
nity, after a stated number of months, to
file with OPR a petition for reinstatement
affirming compliance with the terms of
the consent and affirming current fitness
and eligibility to practice (i.e., an active
professional license or active enrollment
status, with no intervening violations of
the regulations).
Suspended indefinitely by decision in
expedited proceeding, Suspended indef-
initely by default decision in expedited
proceeding, Suspended by consent in
expedited proceeding—OPR instituted
an expedited proceeding for suspension
(based on certain limited grounds, includ-
ing loss of a professional license for cause,
and criminal convictions).
Determined ineligible for limited
practice—There has been a final deter-
mination that an unenrolled/unlicensed

August 29, 2022 180 Bulletin No. 2022–35
return preparer is not eligible for limited
representation of any taxpayer because the
preparer violated standards of conduct or
failed to comply with any of the require-
ments to act as a representative.
A practitioner who has been disbarred
or suspended under 31 C.F.R. § 10.60, or
suspended under § 10.82, or a disquali-
fied appraiser may petition for reinstate-
ment before the IRS after the expiration
of 5 years following such disbarment,
suspension, or disqualification (or imme-
diately following the expiration of the
suspension or disqualification period if
shorter than 5 years). Reinstatement will
not be granted unless the IRS is satisfied
that the petitioner is not likely to engage
thereafter in conduct contrary to Circu-
lar 230, and that granting such reinstate-
ment would not be contrary to the public
interest.
Reinstatement decisions are published
at the individual’s request, and described
in these terms:
Reinstated to practice before the
IRS—The individual’s petition for rein-
statement has been granted. The agent,
and eligible to practice before the IRS, or
in the case of an appraiser, the individual
is no longer disqualified.
Reinstated to engage in limited prac-
tice before the IRS—The individual’s
petition for reinstatement has been granted.
The individual is an unenrolled/unlicensed
return preparer and eligible to engage in
limited practice before the IRS, subject to
requirements the IRS has prescribed for
limited practice by tax return preparers.
OPR has authority to disclose the
grounds for disciplinary sanctions in
these situations: (1) an ALJ or the Secre-
tary’s delegate on appeal has issued a final
decision; (2) the individual has settled a
disciplinary case by signing OPR’s “con-
sent to sanction” agreement admitting to
one or more violations of the regulations
and consenting to the disclosure of the
admitted violations (for example, failure
to file Federal income tax returns, lack of
due diligence, conflict of interest, etc.); (3)
OPR has issued a decision in an expedited
proceeding for indefinite suspension; or
(4) OPR has made a final determination
(including any decision on appeal) that an
unenrolled/unlicensed return preparer is
ineligible to represent any taxpayer before
the IRS.
Announcements of disciplinary sanc-
tions appear in the Internal Revenue Bul-
letin at the earliest practicable date. The
sanctions announced below are alphabet-
ized first by state and second by the last
names of the sanctioned individuals.
City & StateNameProfessional
Designation
Disciplinary SanctionEffective Date(s)
California
West
Hollywood
Godin, RandyAttorneySuspended by decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
June 7, 2022
Colorado
DenverCall, Ryan R.AttorneySuspended by default decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
June 21, 2022
New Jersey
East
Brunswick
Wechsler, Barry S.C PASuspended by default decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
May 5, 2022
New Mexico
CostillaHowieson, Richard A.AttorneySuspended by default decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
May 5, 2022

Bulletin No. 2022–35 181 August 29, 2022
City & StateNameProfessional
Designation
Disciplinary SanctionEffective Date(s)
New York
Donnelly, Sarah P. (aka Sarah
Maya Pillay), see Texas
Oregon
AlbanyPerdue, Richard D.C PASuspended by decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
June 14, 2022
SherwoodBopp, Carol A.C PASuspended by default decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
June 21, 2022
Texas
DallasDonnelly, Sarah P. (aka Sarah
Maya Pillay)
AttorneySuspended by default decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
June 7, 2022
HoustonEureste, Arthur R.AttorneySuspended by default decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
May 20, 2022
SnyderFair, Jean M.AttorneySuspended by default decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
June 14, 2022

Bulletin No. 2022–35 i August 29, 2022
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
effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus,
if an earlier ruling held that a principle
applied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguished describes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modified is 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
with amplified and clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transactions.
This term is most commonly used in a ruling
that lists previously published rulings 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.
Revoked describes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a
period of time in separate rulings. If the
new ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example, modified and
superseded describes 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
published ruling is first modified and then,
as modified, is superseded.
Supplemented is 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
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspended is used in rare situations
to show that the previous published rul-
ings 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 following abbreviations in current
use and formerly used will appear in
material published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.
—Court Decision.
CY—County.
D—Decedent.
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—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.

August 29, 2022 ii Bulletin No. 2022–35
Numerical Finding List
1
Bulletin 2022–35
Announcements:
2022-14, 2022-31 I.R.B. 136
2022-15, 2022-31 I.R.B. 136
2022-16, 2022-33 I.R.B. 144
2022-17, 2022-35 I.R.B. 179
Notices:
2022-29, 2022-28 I.R.B. 66
2022-30, 2022-28 I.R.B. 70
2022-31, 2022-29 I.R.B. 85
2022-32, 2022-32 I.R.B. 137
2022-33, 2022-34 I.R.B. 147
2022-34, 2022-34 I.R.B. 150
Proposed Regulations:
REG-130975-08, 2022-28 I.R.B. 71
REG 130675-17, 2022-30 I.R.B. 104
Revenue Procedures:
2022-25, 2022-27 I.R.B. 3
2022-28, 2022-27 I.R.B. 65
2022-26, 2022-29 I.R.B. 90
2022-32, 2022-30 I.R.B. 101
2022-30, 2022-31 I.R.B. 112
2022-29, 2022-33 I.R.B. 141
2022-34, 2022-33 I.R.B. 143
Revenue Rulings:
2022-12, 2022-27 I.R.B. 1
2022-13, 2022-30 I.R.B. 99
2022-14, 2022-31 I.R.B. 110
2022-15, 2022-35 I.R.B. 152
2022-16, 2022-35 I.R.B. 171
Treasury Decisions:
9963, 2022-34 I.R.B. 145
9964, 2022-35 I.R.B. 172
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2021–27 through 2021–52 is in Internal Revenue Bulletin
2021–52, dated December 27, 2021.

Bulletin No. 2022–35 iii August 29, 2022
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2022–35
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2021–27 through 2021–52 is in Internal Revenue Bulletin
2021–52, dated December 27, 2021.

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INTERNAL REVENUE BULLETIN
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