Internal Revenue Bulletin 2015-47 (PDF rendition): IRS Notices

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

HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
INCOME TAX
Announcement 2015–26, page 677.
The Office of Professional Responsibility (OPR) announces re-
cent disciplinary sanctions involving attorneys, certified public
accountants, enrolled agents, enrolled actuaries, enrolled re-
tirement 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 Department Circular No. 230. The
regulations prescribe the duties and restrictions relating to
such practice and prescribe the disciplinary sanctions for vio-
lating the regulations.
Notice 2015–77, page 676.
This notice amplifies Notice 2013–7, 2013–6 I.R.B. 477, with
respect to the Treasury Department’s Housing Finance Agency
Innovation Fund for the Hardest-Hit Housing Markets (HFA Hard-
est Hit Fund) by extending through taxable year 2017 the safe
harbor method for computing a homeowner’s deduction for
payments made on a home mortgage and the relief for mort-
gage servicers and state housing finance agencies (State
HFAs) from penalties relating to information reporting. In addi-
tion, this notice amplifies Rev. Proc. 2011–55, 2011–47 I.R.B.
793, by extending its scope and effective date through calen-
dar year 2017 for the HFA Hardest Hit Fund.
Finding Lists begin on page ii.
Bulletin No. 2015– 47
November 23, 2015

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and en-
force 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 official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, legislation, court decisions, and other items of general
interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all
substantive 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 internal
management are not published; however, statements of inter-
nal practices and procedures that affect the rights and duties
of taxpayers are published.
Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the
revenue ruling. In those based on positions taken in rulings to
taxpayers or technical advice to Service field offices, identify-
ing 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, Legisla-
tion and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Sec-
retary (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.
November 23, 2015Bulletin No. 2015– 47

Part III. Administrative, Procedural, and Miscellaneous
Extension of Guidance in
Notice 2013–7 for
Participants in the HFA
Hardest Hit Fund
Notice 2015–77
PURPOSE
This notice amplifies Notice 2013–7,
2013–6 I.R.B. 477, with respect to the
Treasury Department’s Housing Finance
Agency Innovation Fund for the Hardest-
Hit Housing Markets (HFA Hardest Hit
Fund) by extending through taxable year
2017 the safe harbor method for comput-
ing a homeowner’s deduction for pay-
ments made on a home mortgage and the
relief for mortgage servicers and state
housing finance agencies (State HFAs)
from penalties relating to information re-
porting. In addition, this notice amplifies
Rev. Proc. 2011–55, 2011–47 I.R.B. 793,
by extending its scope and effective date
through calendar year 2017 for the HFA
Hardest Hit Fund.
BACKGROUND
Notice 2013–7 provides guidance on
the federal income tax consequences of,
and information reporting obligations for,
payments made to or on behalf of finan-
cially distressed homeowners under pro-
grams designed by State HFAs (State Pro-
grams) with funds allocated from the HFA
Hardest Hit Fund. An updated list of State
Programs for which the Treasury Depart-
ment approves funding is available at
www.treasury.gov/HHF. All of these pro-
grams are covered by Rev. Proc. 2011–55
and this notice.
Rev. Proc. 2011–55, as amplified by
Notice 2013–7, specifies the IRS office to
which State HFAs should send the state-
ment required by Notice 2013–7, and pro-
vides that State HFAs may, at their option,
use Form 1098–MA,Mortgage Assis-
tance Payments, to provide the informa-
tion required by that notice. Rev. Proc.
2011–55 applies to State HFAs that make
payments to mortgage servicers under a
State Program. Notice 2013–7 extends the
effective date of Rev. Proc. 2011–55
through 2015.
APPLICATION
Income Tax Consequences
to Homeowners
For taxable years 2010 through 2017, a
homeowner may deduct on his or her Fed-
eral income tax return the lesser of—
•The sum of all payments on the home
mortgage that the homeowner actually
makes during a taxable year to the
mortgage servicer or the State HFA;
and
•the sum of amounts shown on Form
1098,Mortgage Interest Statement, for
mortgage interest received, real prop-
erty taxes, and mortgage insurance
premiums (if deductible for the taxable
year under § 163(h)(3)(E)).
This safe harbor method of comput-
ing the homeowner’s deduction applies
for a taxable year if (1) the homeowner
meets the requirements of §§ 163 and
164 to deduct all of the mortgage inter-
est on the loan and all of the real prop-
erty taxes on the principal residence,
and (2) the homeowner participates in a
State Program in which the program
payments could be used to pay interest
on the home mortgage.
Information Reporting Obligations
The Service will not assert penalties
under §§ 6721 and 6722 against a mort-
gage servicer that reports on Forms 1098
payments received under a State Program
during calendar years 2011 through 2017
if the servicer notifies homeowners that
the amounts reported on the Form 1098
are overstated because they include gov-
ernment subsidy payments.
The Service will not assert penalties
under §§ 6721 and 6722 against any State
HFA for failing to file and furnish Forms
1098 for calendar years 2011 through
2017 if the State HFA provides each ho-
meowner and the IRS a statement setting
forth (1) the homeowner’s name and tax-
payer identification number (TIN), and (2)
the amount of payments the State HFA
made to the mortgage servicer under the
State Program during that year (separately
stating the amount the State HFA paid and
the amount the homeowner paid). Except
as provided in Rev. Proc. 2011–55 regard-
ing use of Form 1098–MA, the statement
the State HFA provides to the IRS must be
a single statement that separately lists the
names, TINs, and relevant payment
amounts for each homeowner.
For calendar years 2011 through 2017,
State HFAs may, at their option, use Form
1098–MA in accordance with Rev. Proc.
2011–55 to provide the information de-
scribed in Notice 2013–7 instead of filing
a single statement for the calendar year.
EFFECT ON OTHER DOCUMENTS
(1) Notice 2013–7 is amplified with
respect to the HFA Hardest Hit Fund by
extending the guidance relating to (a) the
safe harbor method for computing a hom-
eowner’s deduction for payments made on
a home mortgage through taxable year
2017, and (b) information reporting for
those payments through calendar year
2017.
(2) Rev. Proc. 2011–55 is amplified by
extending its scope and effective date
through calendar year 2017 for the HFA
Hardest Hit Fund.
DRAFTING INFORMATION
The principal author of this notice is
Shareen S. Pflanz of the Office of Asso-
ciate Chief Counsel (Income Tax & Ac-
counting). For further information regard-
ing this notice, contact Ms. Pflanz at (202)
317-4718 (not a toll-free number).
November 23, 2015Bulletin No. 2015– 47
676

Part IV. Items of General Interest
Announcement of
Disciplinary Sanctions
From the Office of
Professional Responsibility
Announcement 2015–26
The Office of Professional Responsi-
bility (OPR) announces recent disciplin-
ary sanctions involving attorneys, certi-
fied 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 vi-
olating the regulations. Unenrolled/unli-
censed return preparers are subject to
Revenue Procedure 81–38 and supersed-
ing guidance in Revenue Procedure
2014–42, which govern a preparer’s eli-
gibility to represent taxpayers before the
IRS in examinations of tax returns the
preparer both prepared for the taxpayer
andsigned as the preparer. Additionally,
unenrolled/unlicensed return preparers
who voluntarily participate in the Annual
Filing Season Program under Revenue
Procedure 2014–42 agree to be subject to
the duties and restrictions in Circular 230,
including the restrictions on incompetent
or disreputable conduct.
The disciplinary sanctions to be im-
posed for violation of the applicable stan-
dards 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. Un-
like 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 in-
dividual 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 sub-
ject to Circular 230 may not assist, or
accept assistance from, individuals who
are suspended or disbarred with respect to
matters constituting practice (i.e., repre-
sentation) 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 regu-
lations. 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
complaint was filed, granted OPR’s mo-
tion 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, Monetary
penalty imposed by decision on appeal,
and Disqualified by decision on ap-
peal—The decision of the ALJ was ap-
pealed to the agency appeal authority, acting
as the delegate of the Secretary of the Trea-
sury, and the appeal authority issued a de-
cision 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 dis-
ciplinary proceeding being instituted or
continued, an individual offered a consent
to one of these sanctions and OPR ac-
cepted the offer.Typically, an offer of con-
sent will provide for: suspension for an in-
definite term; conditions that the individual
must observe during the suspension; and the
individual’s opportunity, after a stated num-
ber of months, to file with OPR a petition
for reinstatement affirming compliance with
the terms of the consent and affirming cur-
rent fitness and eligibility to practice (i.e., an
active professional license or active enroll-
ment 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 determi-
nation that an unenrolled/unlicensed re-
turn 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.
Bulletin No. 2015– 47November 23, 2015
677

OPR has authority to disclose the
grounds for disciplinary sanctions in these
situations: (1) an ALJ or the Secretary’s
delegate on appeal has issued a final de-
cision; (2) the individual has settled a dis-
ciplinary case by signing OPR’s “consent
to sanction” agreement admitting to one
or more violations of the regulations and
consenting to the disclosure of the admit-
ted 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 & StateName
Professional
DesignationDisciplinary SanctionEffective Date(s)
California
Santa RosaJovel, EfrainEnrolled Agent Suspended by default decision
in expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
July 30, 2015
Florida
Coral GablesForman, Terry J.Attorney/CPA Suspended by decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
July 9, 2015
Maryland
Gwynn OakAgbaje, Taiwo A.AttorneySuspended by default decision
in expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
July 30, 2015
New Jersey
MetuchenFrey, Thomas G.AttorneySuspended by decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
July 30, 2015
RidgefieldGriffin, Timothy G.AttorneySuspended by decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
August 27, 2015
New York
Griffin, Timothy G.,
see New Jersey
Ohio
DaytonCouchot, Larry E.CPASuspended by decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
July 30, 2015
East LakeZelenkofske, Andrew B. CPASuspended by default decision
in expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
August 18, 2015
Pennsylvania
PhiladelphiaMiller, Larry C.AttorneyReinstated to
practice before the
IRS August 8, 2015
Zelenkofske, Andres B., see
Ohio
November 23, 2015Bulletin No. 2015– 47
678

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:
Amplifieddescribes 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 ap-
plied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarifiedis 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.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified andclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used in
a ruling that lists previously published rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Supersededdescribes 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 pe-
riod 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
supersededdescribes 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.
Supplementedis used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
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.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in ma-
terial 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.
Bulletin No. 2015– 47November 23, 2015
i

Numerical Finding List
1
Bulletins 2015–27 through 2015–47
Announcements:
2015-17, 2015-28 I.R.B.67
2015-18, 2015-33 I.R.B.198
2015-19, 2015-32 I.R.B.157
2015-20, 2015-38 I.R.B.355
2015-21, 2015-34 I.R.B.220
2015-22, 2015-35 I.R.B.288
2015-23, 2015-36 I.R.B.311
2015-24, 2015-36 I.R.B.313
2015-25, 2015-39 I.R.B.422
2015-26, 2015-47 I.R.B.677
2015-28, 2015-46 I.R.B.673
2015-29, 2015-46 I.R.B.673
2015-30, 2015-46 I.R.B.673
Notices:
2015-43, 2015-29 I.R.B.73
2015-46, 2015-28 I.R.B.64
2015-47, 2015-30 I.R.B.76
2015-48, 2015-30 I.R.B.77
2015-49, 2015-30 I.R.B.79
2015-50, 2015-30 I.R.B.81
2015-51, 2015-31 I.R.B.133
2015-52, 2015-35 I.R.B.227
2015-53, 2015-33 I.R.B.190
2015-54, 2015-34 I.R.B.210
2015-55, 2015-34 I.R.B.217
2015-56, 2015-35 I.R.B.235
2015-57, 2015-36 I.R.B.294
2015-58, 2015-37 I.R.B.322
2015-59, 2015-40 I.R.B.459
2015-60, 2015-43 I.R.B.604
2015-61, 2015-39 I.R.B.408
2015-62, 2015-39 I.R.B.411
2015-63, 2015-40 I.R.B.461
2015-64, 2015-40 I.R.B.464
2015-65, 2015-40 I.R.B.466
2015-66, 2015-41 I.R.B.541
2015-67, 2015-41 I.R.B.546
2015-68, 2015-41 I.R.B.547
2015-69, 2015-41 I.R.B.550
2015-70, 2015-43 I.R.B.604
2015-71, 2015-43 I.R.B.606
2015-72, 2015-44 I.R.B.613
2015-73, 2015-46 I.R.B.660
2015-74, 2015-46 I.R.B.663
2015-75, 2015-46 I.R.B.668
2015-76, 2015-46 I.R.B.669
2015-77, 2015-47 I.R.B.676
Proposed Regulations:
REG-140379-02, 2015-45 I.R.B.653
REG-136459-09, 2015-37 I.R.B.332
REG-155164-09, 2015-41 I.R.B.560
Proposed Regulations:—Continued
REG-109370-10, 2015-33 I.R.B.198
REG-112997-10, 2015-39 I.R.B.422
REG-103033-11, 2015-37 I.R.B.325
REG-109813-11, 2015-37 I.R.B.330
REG-138344-13, 2015-41 I.R.B.557
REG-139483-13, 2015-40 I.R.B.475
REG-148998-13, 2015-45 I.R.B.653
REG-115452-14, 2015-32 I.R.B.158
REG-127895-14, 2015-41 I.R.B.556
REG-132075-14, 2015-35 I.R.B.288
REG-138526-14, 2015-28 I.R.B.67
REG-143800-14, 2015-37 I.R.B.347
REG-102648-15, 2015-31 I.R.B.134
REG-102837-15, 2015-27 I.R.B.43
REG-121496-15, 2015-46 I.R.B.674
REG-123640-15, 2015-37 I.R.B.350
Revenue Procedures:
2015-34, 2015-27 I.R.B.4
2015-36, 2015-27 I.R.B.20
2015-38, 2015-36 I.R.B.295
2015-39, 2015-33 I.R.B.195
2015-40, 2015-35 I.R.B.236
2015-41, 2015-35 I.R.B.263
2015-42, 2015-36 I.R.B.310
2015-43, 2015-40 I.R.B.467
2015-44, 2015-38 I.R.B.354
2015-45, 2015-39 I.R.B.412
2015-46, 2015-39 I.R.B.414
2015-47, 2015-39 I.R.B.419
2015-48, 2015-40 I.R.B.469
2015-49, 2015-41 I.R.B.555
2015-50, 2015-42 I.R.B.583
2015-51, 2015-42 I.R.B.583
2015-52, 2015-45 I.R.B.638
2015-53, 2015-44 I.R.B.615
2015-54, 2015-45 I.R.B.648
Revenue Rulings:
2015-15, 2015-27 I.R.B.1
2015-16, 2015-31 I.R.B.130
2015-17, 2015-39 I.R.B.358
2015-18, 2015-34 I.R.B.209
2015-19, 2015-36 I.R.B.291
2015-20, 2015-38 I.R.B.353
2015-21, 2015-40 I.R.B.447
2015-22, 2015-44 I.R.B.610
Treasury Decisions:
9723, 2015-31 I.R.B.84
9726, 2015-31 I.R.B.98
9727, 2015-32 I.R.B.154
9728, 2015-33 I.R.B.169
9729, 2015-35 I.R.B.221
9730, 2015-35 I.R.B.223
9731, 2015-37 I.R.B.314
Treasury Decisions:—Continued
9732, 2015-39 I.R.B.371
9733, 2015-41 I.R.B.494
9734, 2015-41 I.R.B.500
9735, 2015-37 I.R.B.316
9736, 2015-39 I.R.B.402
9737, 2015-40 I.R.B.449
9738, 2015-40 I.R.B.453
9739, 2015-41 I.R.B.528
9740, 2015-42 I.R.B.573
9741, 2015-45 I.R.B.628
9742, 2015-46 I.R.B.657
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2015–01 through 2015–26 is in Internal Revenue Bulletin
2015–26, dated June 29, 2015.
November 23, 2015Bulletin No. 2015– 47
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2015–27 through 2015–47
Notices:
2011-55
Amplified by
Notice 2015-77, 2015-47 I.R.B.676
2013-7
Amplified by
Notice 2015-77, 2015-47 I.R.B.676
2014-4
Modified by
Notice 2015-51, 2015-31 I.R.B.133
2014-17
Superseded by
Notice 2015-67, 2015-41 I.R.B.546
Proposed Regulations:
2009-57
Obsoleted by
REG-112997-10 2015-39 I.R.B.422
2013-17
Obsoleted by
REG-148998-13 2015-45 I.R.B.653
Revenue Procedures:
1992-75
Clarified by
Rev. Proc. 2015-40, 2015-35 I.R.B.236
2003-40
Modified by
Rev. Proc. 2015-40, 2015-35 I.R.B.236
2003-78
Modified by
Rev. Proc. 2015-46, 2015-39 I.R.B.414
2006-9
Modified by
Rev. Proc. 2015-41, 2015-35 I.R.B.263
2006-9
Superseded by
Rev. Proc. 2015-41, 2015-35 I.R.B.263
2006-54
Modified by
Rev. Proc. 2015-40, 2015-35 I.R.B.236
2006-54
Superseded by
Rev. Proc. 2015-40, 2015-35 I.R.B.236
Revenue Procedures:—Continued
2008-31
Modified by
Rev. Proc. 2015-41, 2015-35 I.R.B.263
2008-31
Superseded by
Rev. Proc. 2015-41, 2015-35 I.R.B.263
2011-49
Modified by
Rev. Proc. 2015-36, 2015-27 I.R.B.20
2011-49
Superseded by
Rev. Proc. 2015-36, 2015-27 I.R.B.20
2015-14
Modified by
Rev. Proc. 2015-39, 2015-33 I.R.B.195
2015-40
Amplified by
Rev. Proc. 2015-41, 2015-35 I.R.B.263
2015-41
Amplified by
Rev. Proc. 2015-40, 2015-35 I.R.B.236
Treasury Decisions:
58-422
Obsoleted by
T.D. 9739 2015-41 I.R.B.528
66-284
Obsoleted by
T.D. 9739 2015-41 I.R.B.528
79-250
Obsoleted by
T.D. 9739 2015-41 I.R.B.528
79-289
Obsoleted by
T.D. 9739 2015-41 I.R.B.528
96-29
Obsoleted by
T.D. 9739 2015-41 I.R.B.528
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2015–01 through 2015–26 is in Internal Revenue Bulletin
2015–26, dated June 29, 2015.
Bulletin No. 2015– 47November 23, 2015
iii

INTERNAL REVENUE BULLETIN
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