Internal Revenue Bulletin 2022-22 (PDF rendition): IRS Announcements

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

Bulletin No. 2022–22
May 31, 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 2022-9, page 1153.
The Office of Professional Responsibility (OPR)
announces recent disciplinary sanctions involving attor-
neys, certified public accountants, enrolled agents,
enrolled actuaries, enrolled retirement plan agents, and
appraisers. These individuals are subject to the regu-
lations governing practice before the Internal 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 restric-
tions relating to such practice and prescribe the disci-
plinary sanctions for violating the regulations.
EMPLOYEE PLANS
Notice 2022-27, page 1151.
This notice is a 6-month extension of the relief provided
in Notice 2020-42, as extended by Notice 2021-3 and
Notice 2021-40. For the period from July 1, 2022,
through December 31, 2022, this notice extends two
types of relief from the physical presence requirement in
§ 1.401(a)-21(d)(6)(i) for participant elections required
to be witnessed by a plan representative or a notary
public: (1) temporary relief from the physical presence
requirement for any participant election witnessed by
a notary public in a state that permits remote notariza-
tion (either by law or through an executive order), and
(2) temporary relief from the physical presence require-
ment for any participant election witnessed by a plan
representative.
EXEMPT ORGANIZATIONS
Announcement 2022-10, page 1156.
Revocation of IRC 501(c)(3) Organizations for failure
to meet the code section requirements. Contributions
made to the organizations by individual donors are no
longer deductible under IRC 170(b)(1)(A).
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.
May 31, 2022 Bulletin No. 2022–22

Part III
Extension of Temporary
Relief from the Physical
Presence Requirement
Through December 31,
2022
Notice 2022-27
I. PURPOSE
This notice provides a 6‑month
extension, through December 31, 2022,
of the temporary relief provided in
Notice 2021‑40, 2021‑28 IRB 15, from the
requirement in § 1.401(a)‑21(d)(6)(i) that
certain participant elections be witnessed
in the physical presence of a plan repre‑
sentative or a notary public (the physical
presence requirement). This extension
of relief is provided in response to the
continuing Coronavirus Disease 2019
(COVID‑19) pandemic.
II. BACKGROUND
A. Temporary Relief from the Physical
Presence Requirement and Requests
for Comments
On March 13, 2020, the President
determined that the COVID‑19 pandemic
was of sufficient severity and magnitude
to warrant an emergency determina‑
tion beginning March 1, 2020, under the
Robert T. Stafford Disaster Relief and
Emergency Assistance Act, 42 U.S.C.
5121‑5207 (the national emergency). See
85 FR 15337.
In response to the national emergency
caused by the COVID‑19 pandemic and
related social distancing precautions,
Notice 2020‑42, 2020‑26 IRB 986, pro‑
vided temporary relief (through Decem‑
ber 31, 2020) from the physical presence
requirement for any participant election
that was witnessed by a notary public or
by a plan representative, using an elec‑
tronic system that satisfied the applicable
requirements specified in section III.A
and B, respectively, of Notice 2020‑42.
Notice 2021‑03, 2021‑2 IRB 316,
extended the temporary relief from the
physical presence requirement through
June 30, 2021, if the requirements specified
in section III.A and B of Notice 2021‑03
were satisfied (under terms that were iden‑
tical to the requirements in section III.A
and B of Notice 2020‑42). Notice 2021‑03
noted that, during the temporary relief
period, a participant would still be able
to have a participant election witnessed
in the physical presence of a notary pub‑
lic and have that participant election be
accepted by a plan in accordance with
§ 1.401(a)‑21(d)(6)(i). Notice 2021‑03
also requested comments on whether relief
from the physical presence requirement
should be made permanent and, if made
permanent, what, if any, procedural safe‑
guards would be necessary to reduce the
risk of fraud, spousal coercion, or other
abuse in the absence of the physical pres‑
ence requirement. Notice 2021‑03 further
stated that any permanent modification of
the physical presence requirement would
be made through the regulatory process,
thus providing an additional opportunity
for stakeholders to provide comments.
Notice 2021‑40 extended the tempo‑
rary relief from the physical presence
requirement through June 30, 2022, if the
applicable requirements specified in sec‑
tion III.A and B of Notice 2021‑03 are
satisfied. Notice 2021‑40 also requested
comments on specific matters relating
to the relief from the physical presence
requirement, including comments on
whether to propose modifications to the
physical presence requirement.
B. Stakeholder Comments and Agency
Review
Following the publication of
Notices 2020‑42, 2021‑03, and 2021‑40,
the Department of the Treasury (Treasury
Department) and the Internal Revenue Ser‑
vice (IRS) received comments from numer‑
ous stakeholders regarding the physical
presence requirement. Some stakeholders
requested permanent relief from the phys‑
ical presence requirement; other stakehold‑
ers stated that the existing physical pres‑
ence requirement should be retained.
The Treasury Department and the IRS
are currently reviewing the stakeholder
comments to determine whether to retain
the physical presence requirement without
modification or to propose to modify the
requirement. If the Treasury Department
and the IRS decide to propose to modify
the physical presence requirement, they
will do so only through the regulatory
process, which will include the opportu‑
nity for further comment.
C. Continuing COVID‑19 Pandemic
On February 18, 2022, the President
determined that the COVID‑19 pandemic
continued to cause a significant risk to
public health and safety and extended
the national emergency beyond March 1,
2022. See 87 FR 10289. Accordingly, sec‑
tion III of this notice provides an additional
6‑month extension, through December 31,
2022, of the temporary relief from the
physical presence requirement provided
in Notice 2021‑40. However, in light of
recent easing of public health precautions
relating to the COVID‑19 pandemic, a
further extension of temporary relief from
the physical presence requirement beyond
the end of 2022 is not expected to be
necessary.
III. EXTENSION OF TEMPORARY
RELIEF FROM THE PHYSICAL
PRESENCE REQUIREMENT
This notice extends, for the 6‑month
period from July 1, 2022, through
December 31, 2022, the temporary relief
from the physical presence requirement
provided in Notice 2021‑40, including
extension of the requirements to qual‑
ify for that relief. Accordingly, for this
6‑month period, a plan may qualify for
relief from the physical presence require‑
ment for any participant election wit‑
nessed by a notary public or a plan rep‑
resentative, using an electronic system
that satisfies the applicable requirements
specified in section III.A and B, respec‑
tively, of Notice 2021‑03.
IV. EFFECT ON OTHER
DOCUMENTS
Notice 2021‑40 is modified.
Bulletin No. 2022–22 1151 May 31, 2022

V. DRAFTING INFORMATION
The principal author of this notice
is Tyler Forni of the Office of Associ‑
ate Chief Counsel (Employee Benefits,
Exempt Organizations, and Employment
Taxes). For further information regard‑
ing this notice, contact Tyler Forni at
(202) 317‑4102 (not a toll‑free number).
May 31, 2022 1152 Bulletin No. 2022–22

Bulletin No. 2022–22 1153 May 31, 2022
Part IV
Announcement of
Disciplinary Sanctions
From the Office of
Professional Responsibility
Announcement 2022-9
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., representation) 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

May 31, 2022 1154 Bulletin No. 2022–22
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 disqualified
appraiser may petition for reinstatement
before the IRS after the expiration of 5
years following such disbarment, suspen‑
sion, or disqualification (or immediately
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 peti‑
tioner is not likely to engage thereafter in
conduct contrary to Circular 230, and that
granting such reinstatement 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
practice before the IRS—The individ‑
ual’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 pre‑
scribed 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
Bradford, Dwayne T.,
see Maine
Studio CityKrell, StevenC PAReinstated to practice
before the IRS, effective
March 10, 2022
StocktonLagorio, Kevin V.C PASuspended by decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
March 24, 2022
TurlockPuffer, Robert N.C PASuspended by default decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
March 24, 2022
Garden GroveLee, Michael H.Enrolled AgentSuspended by default decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
January 14, 2022
Colorado
SterlingMoter, Laverne C.C PASuspended by default decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
March 24, 2022
District of Columbia (DC)
Tantillo, Brent S., see Florida
Florida
JacksonvilleKaleel, K. MarkC PASuspended by default decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
March 24, 2022
Tantillo, Brent S.AttorneySuspended by decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
January 28, 2022

Bulletin No. 2022–22 1155 May 31, 2022
City & StateNameProfessional
Designation
Disciplinary SanctionEffective Date(s)
Georgia
MariettaGarner, Carl S.C PASuspended by default decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
February 10, 2022
Williams, Gary R., see
Tennessee
Louisiana
Jones, II, James G., see Texas
Maine
FalmouthBradford,
Dwayne T.
C PASuspended by decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
January 14, 2022
Missouri
LebanonRichardson, Douglas A.C PASuspended by default decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
March 24, 2022
New York
New YorkKlein, Mitchell L.C PASuspended by consent for
admitted violations of
31 C.F.R. §§ 10.51(a)(2) and
10.51(a)(3)
Indefinite from
January 21, 2022
Tennessee
HarrogateWilliams, Gary R.C PASuspended by default decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
January 14, 2022
Texas
DallasDavis, William P.AttorneySuspended by default decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
January 28, 2022
HoustonJones, II, James G.AttorneySuspended by default decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
January 14, 2022
Virginia
MidlothianWildes, Richard H.C PASuspended by default decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
February 10, 2022

May 31, 2022 1156 Bulletin No. 2022–22
Announcement 2022-10
Deletions From Cumulative
List of Organizations,
Contributions to Which are
Deductible Under Section
170 of the Code
Table of Contents
The Internal Revenue Service has
revoked its determination that the organi‑
zations listed below qualify as organiza‑
tions described in sections 501(c)(3) and
170(c)(2) of the Internal Revenue Code of
1986.
Generally, the IRS will not disallow
deductions for contributions made to a
listed organization on or before the date
of announcement in the Internal Revenue
Bulletin that an organization no longer
qualifies. However, the IRS is not pre‑
cluded from disallowing a deduction for
any contributions made after an organiza‑
tion ceases to qualify under section 170(c)
(2) if the organization has not timely filed
a suit for declaratory judgment under sec‑
tion 7428 and if the contributor (1) had
knowledge of the revocation of the ruling
or determination letter, (2) was aware that
such revocation was imminent, or (3) was
in part responsible for or was aware of the
activities or omissions of the organization
that brought about this revocation.
If on the other hand a suit for declar‑
atory judgment has been timely filed,
contributions from individuals and orga‑
nizations described in section 170(c)(2)
that are otherwise allowable will continue
to be deductible. Protection under section
7428(c) would begin on May 31, 2022 and
would end on the date the court first deter‑
mines the organization is not described
in section 170(c)(2) as more particularly
set for in section 7428(c)(1). For individ‑
ual contributors, the maximum deduction
protected is $1,000, with a husband and
wife treated as one contributor. This ben‑
efit is not extended to any individual, in
whole or in part, for the acts or omissions
of the organization that were the basis for
revocation.
NAME OF ORGANIZATION
Effective Date of
RevocationLOCATION
Charity Partners Network1/1/2015Sarasota, FL
Renewable Home Foundation, Inc.1/1/2017Temecula, CA
Safe Building Compliance and Technology1/1/2020Polk City, IA
Love Mia Foundation, Inc.1/1/2017Miami, FL
XC Foundation1/1/2016Pleasanton, CA
Hope Services, Inc.1/1/2017Castle Pines, CO
Arizona Horsemen’s Benevolent & Association1/1/2016Phoenix, AZ
Idance Academi1/1/2017Jackson, MS
New York Youth Club International, Inc.1/1/2017W. Hempstead, NY
Zhenguo Beijing Opera House5/1/2017Pennington, NJ
Their Last Best Place1/1/2017Livingston, MT
The Development Corporation of Baton Rouge3/1/2017Nashville, TN
Association League of Superfriends1/1/2017Harper Woods, MI
MCGUFFEY YOUTH FOOTBALL1/1/2018Claysville, PA

Bulletin No. 2022–22 i May 31, 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.

May 31, 2022 ii Bulletin No. 2022–22
Numerical Finding List
1
Bulletin 2022–22
Announcements:
2022‑3, 2022‑8 I.R.B. 788
2022‑4, 2022‑9 I.R.B. 789
2022‑5, 2022‑11 I.R.B. 825
2022‑6, 2022‑13 I.R.B. 934
2022‑7, 2022‑15 I.R.B. 946
2022‑8, 2022‑19 I.R.B. 1056
2022‑9, 2022‑22 I.R.B. 1153
2022‑10, 2022‑22 I.R.B. 1156
AOD:
2022‑1, 2022‑06 I.R.B. 466
2022‑2, 2022‑12 I.R.B. 903
Notices:
2022‑1, 2022‑02 I.R.B. 304
2022‑2, 2022‑02 I.R.B. 304
2022‑3, 2022‑02 I.R.B. 308
2022‑4, 2022‑02 I.R.B. 309
2022‑5, 2022‑05 I.R.B. 457
2022‑6, 2022‑05 I.R.B. 460
2022‑7, 2022‑06 I.R.B. 469
2022‑8, 2022‑07 I.R.B. 491
2022‑9, 2022‑10 I.R.B. 811
2022‑10, 2022‑10 I.R.B. 815
2022‑12, 2022‑12 I.R.B. 906
2022‑11, 2022‑14 I.R.B. 939
2022‑13, 2022‑14 I.R.B. 940
2022‑14, 2022‑14 I.R.B. 941
2022‑15, 2022‑18 I.R.B. 1043
2022‑16, 2022‑18 I.R.B. 1044
2022‑17, 2022‑18 I.R.B. 1048
2022‑18, 2022‑18 I.R.B. 1048
2022‑19, 2022‑18 I.R.B. 1050
2022‑21, 2022‑20 I.R.B. 1057
2022‑22, 2022‑20 I.R.B. 1057
2022‑23, 2022‑20 I.R.B. 1062
2022‑20, 2022‑21 I.R.B. 1095
2022‑24, 2022‑21 I.R.B. 1097
2022‑27, 2022‑22 I.R.B. 1151
Proposed Regulations:
REG‑118250‑20, 2022‑07 I.R.B. 753
REG‑105954‑20, 2022‑11 I.R.B. 828
REG‑114209‑21, 2022‑11 I.R.B. 898
REG‑114209‑21, 2022‑11 I.R.B. 898
REG‑121508‑18, 2022‑15 I.R.B. 996
REG‑114339‑21, 2022‑17 I.R.B. 1030
REG‑106384‑20, 2022‑20 I.R.B. 1076
REG‑118913‑21, 2022‑20 I.R.B. 1089
REG‑122770‑18, 2022‑21 I.R.B. 1104
Revenue Procedures:
2022‑1, 2022‑01 I.R.B. 1
2022‑2, 2022‑01 I.R.B. 120
2022‑3, 2022‑01 I.R.B. 144
2022‑4, 2022‑01 I.R.B. 161
2022‑5, 2022‑01 I.R.B. 256
2022‑7, 2022‑01 I.R.B. 297
2022‑9, 2022‑02 I.R.B. 310
2022‑11, 2022‑03 I.R.B. 449
2022‑8, 2022‑04 I.R.B. 451
2022‑10, 2022‑06 I.R.B. 473
2022‑13, 2022‑06 I.R.B. 477
2022‑12, 2022‑07 I.R.B. 494
2022‑14, 2022‑07 I.R.B. 502
2022‑15, 2022‑13 I.R.B. 908
2022‑17, 2022‑13 I.R.B. 930
2022‑17, 2022‑13 I.R.B. 933
2022‑20, 2022‑14 I.R.B. 945
2022‑21, 2022‑16 I.R.B. 1015
2022‑23, 2022‑18 I.R.B. 1052
2022‑24, 2022‑20 I.R.B. 1075
2022‑22, 2022‑21 I.R.B. 1098
Revenue Rulings:
2022‑1, 2022‑02 I.R.B. 301
2022‑2, 2022‑04 I.R.B. 451
2022‑3, 2022‑06 I.R.B. 467
2022‑4, 2022‑10 I.R.B. 790
2022‑5, 2022‑10 I.R.B. 792
2022‑6, 2022‑12 I.R.B. 904
2022‑7, 2022‑14 I.R.B. 935
2022‑8, 2022‑14 I.R.B. 936
2022‑9, 2022‑18 I.R.B. 1041
Treasury Decisions:
9959, 2022‑03 I.R.B. 328
9961, 2022‑03 I.R.B. 430
9960, 2022‑07 I.R.B. 481
9962, 2022‑11 I.R.B. 823
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin
2020–52, dated December 27, 2021.

Bulletin No. 2022–22 iii May 31, 2022
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2022–22
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin
2020–52, dated December 27, 2021.

Internal Revenue Service
Washington, DC 20224
Official Business
Penalty for Private Use, $300
INTERNAL REVENUE BULLETIN
The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue
Bulletins are available at www.irs.gov/irb/.
We Welcome Comments About the Internal Revenue Bulletin
If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it,
we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page
www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave.
NW, IR‑6230 Washington, DC 20224.