Internal Revenue Bulletin 2010-10 (PDF rendition): IRS Notices

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Bulletin No. 201
0-10
March 8, 2010
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
INCOME TAX
Rev. Rul. 2010–8, page 432.
Federal rates; adjusted federal rates; adjusted federal
long-termrateandthelong-termexemptrate.For pur-
poses of sections 382, 642, 1274, 1288, and other sections
of the Code, tables set forth the rates for March 2010.
Announcement 2010–11, page 438.
This document contains a correction to Revenue Procedure
2009–55, 2009–52 I.R.B. 982, unpaid loss discount factors
for 2009. The composite loss discount factor for Reinsurance
(nonproportional assumed property) provided in Revenue Pro-
cedure 2009–55 was incorrect.
EXEMPT ORGANIZATIONS
Announcement 2010–15, page 438.
The IRS has revoked its determination that the Remembrance
Foundation of Alpine, UT, qualifies as an organization described
in sections 501(c)(3) and 170(c)(2) of the Code.
ADMINISTRATIVE
Notice 2010–22, page 435.
This notice sets forth the maximum face amount of Qualified
Zone Academy Bonds (“QZABs”) that may be issued for each
state for the calendar year 2010 under section 54E(c)(2) of
the Code. For this purpose, “state” includes the District of
Columbia and the possessions of the United States.
Announcement 2010–11, page 438.
This document contains a correction to Revenue Procedure
2009–55, 2009–52 I.R.B. 982, unpaid loss discount factors
for 2009. The composite loss discount factor for Reinsurance
(nonproportional assumed property) provided in Revenue Pro-
cedure 2009–55 was incorrect.
Finding Lists begin on page ii.

The IRS Mission
Provide Americ
a’s taxpayers top quality service by helping them
understand an
d meet their tax responsibilities and by applying
the tax law with
integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, legislation, court decisions, and other items of general
interest. It is published weekly and may be obtained from the
Superintendent of Documents on a subscription basis. Bulletin
contents are compiled semiannually into Cumulative Bulletins,
which are sold on a single-copy basis.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application of
the tax laws, including all rulings that supersede, revoke, mod-
ify, or amend any of those previously published in the Bulletin.
All published rulings apply retroactively unless otherwise indi-
cated. Procedures relating solely to matters of internal man-
agement are not published; however, statements of internal
practices and procedures that affect the rights and duties of
taxpayers are published.
Revenue rulings represent the conclusions of the Service on the
application of the law to the pivotal facts stated in the revenue
ruling. In those based on positions taken in rulings to taxpayers
or technical advice to Service field offices, identifying details
and information of a confidential nature are deleted to prevent
unwarranted invasions of privacy and to comply with statutory
requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—19
86 Code.
This part i
ncludes rulings and decisions based on provisions of
the Intern
al Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B, Leg-
islation and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Secre-
tary (Enforcement).
Part IV
.—Items of General Interest.
This par
t includes notices of proposed rulemakings, disbar-
ment an
d suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index
for the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The c
ontents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
For sale by the Superintendent of Documents, U.S.Government Printing Office, Washington, DC 20402.
March 8, 20102010–10 I.R.B.

Part I. Rulings
and Decisions Under the Internal Revenue Code
of 1986
Section 42.—L
ow-Income
Housing Credi
t
The adjusted a
pplicable federal short-term, mid-
term, and long
-term rates are set forth for the month
of March 2010.
See Rev. Rul. 2010-8, page 432.
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term rates
are set forth for the month of March 2010. See Rev.
Rul. 2010-8, page 432.
Section 382.—Limitation
on Net Operating Loss
Carryforwa
rds and Certain
Built-In Losses Following
Ownership Change
The adjusted applicable federal long-term rate is
set forth for the month of March 2010. See Rev. Rul.
2010-8, page 432.
Section 412.—Minimum
Funding Standards
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of March 2010. See Rev. Rul. 2010-8, page 432.
Section 467.—Certain
Payments for the Use of
Property or Services
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of March 2010. See Rev. Rul. 2010-8, page 432.
Section 468.—Special
Rules for Mining and Solid
Waste
Reclamation and
Closi
ng Costs
The ad
justed applicable federal short-term, mid-
term,
and long-term rates are set forth for the month
of Mar
ch 2010. See Rev. Rul. 2010-8, page 432.
Section 482.—
Allocation
of Income and D
eductions
Among Taxpaye
rs
Federal short
-term, mid-term, and long-term rates
are set forth f
or the month of March 2010. See Rev.
Rul. 2010-8,
page 432.
Section 483.—Interest on
Certain Deferred Payments
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of March 2010. See Rev. Rul. 2010-8, page 432.
Section 642.—Special
Rules for Credits and
Deductions
Federal short-term, mid-term, and long-term rates
are set forth for the month of March 2010. See Rev.
Rul. 2010-8, page 432.
Section 807.—Rules for
Certain Reserves
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of March 2010. See Rev. Rul. 2010-8, page 432.
Section 846.—Discounted
Unpaid Losses Defined
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of March 2010. See Rev. Rul. 2010-8, page 432.
Section 1274.—Determi-
nation of Issue Price in the
Case of Certain Debt Instru-
ments Issued for Property
(Also Sections 42, 280G, 382, 412, 467, 468, 482,
483, 642, 807, 846, 1288, 7520, 7872.)
Federal rates; adjusted federal rates;
adjusted federal long-term rate and the
long-term exempt rate.For purposes of
sections 382,
642, 1274, 1288, and other
sections of th
e Code, tables set forth the
rates for Marc
h 2010.
Rev. Rul. 2010
–8
This revenue
ruling provides various
prescribed r
ates for federal income tax pur-
poses for Mar
ch 2010 (the current month).
Table 1 conta
ins the short-term, mid-term,
and long-ter
m applicable federal rates
(AFR) for th
e current month for purposes
of section 1
274(d) of the Internal Revenue
Code. Table
2 contains the short-term,
mid-term, a
nd long-term adjusted appli-
cable fede
ral rates (adjusted AFR) for
the curren
t month for purposes of section
1288(b). T
able 3 sets forth the adjusted
federal lo
ng-term rate and the long-term
tax-exem
pt rate described in section
382(f). T
able 4 contains the appropriate
percenta
ges for determining the low-in-
come hous
ing credit described in section
42(b)(1)
for buildings placed in service
during t
he current month. However, under
section
42(b)(2), the applicable percentage
for non-
federally subsidized new build-
ings pla
ced in service after July 30, 2008,
and befo
re December 31, 2013, shall not
be less
than 9%. Finally, Table 5 contains
the fed
eral rate for determining the present
value o
f an annuity, an interest for life
or for a
term of years, or a remainder or
a rever
sionary interest for purposes of
secti
on 7520.
2010–10 I.R.B.432March 8, 2010

REV. RUL. 2010–8 TABLE 1
Applicable Federal Rates (AFR) for March 2010
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
AFR.64%.64%.64%.64%
110% AFR.70%.70%.70%.70%
120% AFR.77%.77%.77%.77%
130% AFR.83%.83%.83%.83%
Mid-term
AFR2.69%2.67%2.66%2.66%
110% AFR2.96%2.94%2.93%2.92%
120% AFR3.23%3.20%3.19%3.18%
130% AFR
3.50%
3.47%3.46%
3.45%
150% AFR4.05%
4.01%3.99%3.98%
175% AFR
4.72%4.67%4.64%4.63%
Long-term
AFR
4.35%
4.30%4.28%4.26%
110% AFR4.79%4.73%4.70%4.68%
120% AFR
5.23%5.16%5.13%5.11%
130% AFR
5.67%5.59%5.55%5.53%
REV. RUL. 2010–8 TABLE 2
Adjusted AFR for March 2010
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term adjusted
AFR
.64%.64%.64%.64%
Mid-term adjusted AFR1.86%
1.85%1.85%
1.84%
Long-term adjusted
AFR
4.03%3.99%3.97%3.96%
REV. RUL. 2010–8 TABLE 3
Rates Under Section 382 for March 2010
Adjusted federal long-term rate for the current month4.03%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted
federal long-term rates for the current month and the prior two months.)4.03%
REV. RUL. 2010–8 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for March 2010
Note: Under Section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July
30, 2008, and before December 31, 2013, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit7.81%
Appropriate percentage for the 30% present value low-income housing credit3.35%
March 8, 20104332010–10 I.R.B.

REV. RUL. 2010–8 TABLE 5
Rate Under Section 7520 for March 2010
Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years,
or a remainder or reversionary interest3.2%
Section 1288.—Treatment
of Original Issue Discount
on Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of March 2010. See Rev. Rul. 2010-8, page 432.
Section 7520.—Valuation
Tables
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of March 2010. See Rev. Rul. 2010-8, page 432.
Section 7872.—Treatment
of Loans With Below-Market
Interest Rates
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of March 2010. See Rev. Rul. 2010-8, page 432.
2010–10 I.R.B.434March 8, 2010

Part III. Administrative, Procedural, and Miscellaneous
Qualified Zone Academy Bond
Allocations for 2010
Notice 2010–22
SECTION 1. PURPOSE
This notice sets forth the maximum
face amount of Qualified Zone Academy
Bonds (“QZABs”) that may be issued for
each State for the calendar year 2010 un-
der § 54E(c)(2) of the Internal Revenue
Code. Under § 54A(e)(3), the term State
includes the District of Columbia and any
possession of the United States. This no-
tice also provides certain interim guidance
for QZABs issued after October 3, 2008.
SECTION 2. BACKGROUND
.01 INTRODUCTION
Section 313 of the Tax Extenders and
Alternative Minimum Tax Relief Act of
2008, Div. C of Pub. L. No. 110–343,
122 Stat. 3765 (2008) (“Act”) added new
§ 54E, which provides revised program
provisions for QZABs in lieu of the ex-
isting provisions under § 1397E, effec-
tive for obligations issued after October 3,
2008. The Act amended § 54A(d)(1) to
provide that the term qualified tax credit
bond (“QTCB”) means, in part, a quali-
fied zone academy bond which is part of
an issue that meets the requirements of
§§ 54A(d)(2), (3), (4), (5), and (6) regard-
ing expenditures of bond proceeds, infor-
mation reporting, arbitrage, maturity lim-
itations, and prohibitions against financial
conflicts of interest. The Act also amended
§ 54A(d)(2)(C) to provide that, for pur-
poses of § 54A(d)(2), the term “qualified
purpose” for a QZAB means a purpose
specified in § 54E(a)(1), described below.
The Act added § 54E(c)(1) to provide a
national zone academy bond limitation au-
thorization for QZABs of $400 million for
each of calendar years 2008 and 2009. In
addition, section 1522 of Title I of Division
B of the American Recovery and Reinvest-
ment Act of 2009, Pub. L. No. 111–5,
123 Stat. 115 (2009) (“2009 Act”) fur-
ther amended § 54E(c)(1) to provide an in-
creased national zone academy bond limi-
tation authorization for QZABs of $1.4 bil-
lion for each of calendar years 2009 and
2010.
.02 QUALIFIED ZONE ACADEMY
BOND UNDER § 54E
Section 54E(d) defines “qualified zone
academy” as any public school (or aca-
demic program within a public school)
which is established by and operated un-
der the supervision of an eligible local
education agency to provide education
or training below thepostsecondary level
provided: (A) the public school or pro-
gram is designed in cooperation with
business to enhance the academic curricu-
lum, increase graduation and employment
rates and prepare students for college and
the workforce; (B) students will be sub-
ject to the same academic standards and
assessments as other students educated
by the eligible local education agency;
(C) the comprehensive education plan is
approved by the eligible local education
agency; and (D)(i)such public school
is located in an empowerment zone or
enterprise communityincluding such des-
ignated after October 3, 2008; or (ii) there
is a reasonable expectation (as of the date
of bond issuance) that at least 35 percent
of the students will be eligible for free
or reduced cost lunches under the school
lunch program established under the Na-
tional School Lunch Act.
Section 54E(a) provides that a “quali-
fied zone academy bond” or QZAB means
anybondissuedaspartofanissueif:(1)
100 percent of the available project pro-
ceeds of such issue are to be used for a
qualified purpose with respect to a quali-
fied zone academy established by an eli-
gible local education agency; (2) the bond
is issued by a State or local government
within the jurisdiction of which such acad-
emy is located, and (3) the issuer: (A) des-
ignates such bond for purposes of this sec-
tion; (B) certifies that it has written assur-
ances that the private business contribution
requirement of § 54E(b) will be met; and,
(C) certifies that it has the written approval
of the eligible local education agency for
such bond issuance.
Section 54E(d)(3) provides that a qual-
ified purpose with respect to each acad-
emy means: (A) rehabilitating or repair-
ing the public school facility; (B) provid-
ing equipment; (C) developing course ma-
terials; and, (D) training teachers and other
school personnel. The private business
contribution requirement of § 54E(b) is
met if the eligible local education agency
that established the qualified zone acad-
emy has written commitments from pri-
vate entities to make qualified contribu-
tions having a present value (as of the date
of issuance of the issue) of not less than
10 percent of the proceeds of the issue.
Section 54E(d)(4) defines “qualified con-
tributions” as any contribution (of a type
and quality acceptable to the eligible lo-
cal education agency) of: (A) equipment
for use in the qualified zone academy (in-
cluding state-of-the-art technology and vo-
cational equipment);(B) technical assis-
tance in developing curriculum or in train-
ing teachers to promote appropriate market
driven technology in the classroom; (C)
employees’ services as volunteer mentors;
(D) internships, field trips, or other educa-
tional opportunities outside the academy;
or (E) any other property or service speci-
fied by the eligible education agency. Sec-
tion 54E(d)(2) defines “eligible local ed-
ucation agency” as any local educational
agency as defined in § 9101 of the Elemen-
tary and Secondary Education Act of 1965.
Section 54E(c)(2) provides that the
Department of the Treasury shall allocate
the national zone academy bond limitation
among the States on the basis of their re-
spective populations of individuals below
the poverty line (as defined by the Office
of Management and Budget). The limi-
tation amount allocated to a State under
the preceding sentence shall be allocated
by the State education agency to qualified
zone academies within such State.
Under § 54E(c)(3), the maximum ag-
gregate face amount of bonds issued
during any calendar year which may be
designated as QZABs with respect to any
qualified zone academy shall not exceed
the limitation amount allocated to such
academy for such calendar year. However,
under § 54E(c)(4)(A), if for any calendar
year the limitation amount for any State
exceeds the amount ofbonds issued during
such year which are designated QZABs
with respect to qualified zone academies
within such State, the limitation amount
for such State for the following calendar
year shall be increased by the amount
of such excess. Under § 54E(c)(4)(B),
however, any carryforward of a limitation
March 8, 20104352010–10 I.R.B.

amount may be carried only to the first
2 years following the unused limitation
year. For these purposes, the limitation
amount shall be treated as used on a first-in
first-out basis.
Section 54E(c)(4)(C) applies the rules
under §§ 54E(c)(4)(A) and (B) to QZABs
issued after October 3, 2008, under a car-
ryforward of an unused limitation to calen-
dar years 2008 or 2009 that initially arose
in a prior year under § 1397E(e)(4). Any
such carryforward is treated as though it
were a carryforward that initially arose un-
der § 54E in that prior year.
Sections 1.1397–1 (the “Final Regula-
tions”) and 1.1397–1T (the “Temporary
Regulations”) set forth regulations that
were issued under § 1397E. Except as
provided in this notice, or to the extent
inconsistent with §§ 54A and 54E, the
Final Regulations and the Temporary Reg-
ulations apply to QZABs issued under
§§ 54A and 54E.
SECTION 3. INTERIM GUIDANCE
AND RELIANCE
.01 GENERALLY
Pending the promulgation and effec-
tive date of future administrative or regu-
latory guidance, taxpayers may rely on the
interim guidance provided in this notice
and, to the extent not inconsistent with this
notice and the provisions of §§ 54A and
54E, the existing regulations issued under
§ 1397E.
.02. CREDIT RATE
For QZABs issued under §§ 54A and
54E, the maximum maturity and the credit
rate are determined as of the date that there
is a binding, written contract for the sale
or exchange of the bond. The applicable
maximum maturity and the QZAB credit
rate are published for that date by the Bu-
reau of Public Debt on its Internet site for
State and Local Government Series securi-
ties at:http://www.treasurydirect.gov.For
further information regarding the method-
ology and procedures that the Treasury De-
partment uses to determine these credit
rates, see Notice 2009–15, 2009–6 I.R.B.
449 (February 9, 2009).
.03 SINKING FUND YIELD
Section 54A(d)(4)(C) provides that an
issue shall not be treated as failing to meet
the requirements of § 148 by reason of any
fund which is expected to be used to re-
pay the issue if: (i) the fund is funded at
a rate not more rapid than equal annual
installments; (ii) the fund is funded in a
manner reasonably expected to result in an
amount not greater than an amount neces-
sary to repay the issue; and (iii) the yield on
such fund is not greater than the discount
rate determined under § 54A(d)(5)(B) (the
“permitted sinking fund yield”).
The permitted sinking fund yield is
determined under § 54A(d)(5)(B) by us-
ing a rate equal to 110 percent of the
long-term adjusted, applicable federal
rate (“AFR”), compounded semiannually,
for the month in which the bond is sold.
The IRS publishes the long-term adjusted
AFR, compounded semiannually, each
month in a revenue ruling that is pub-
lished in the Internal Revenue Bulletin.
The Bureau of Public Debt publishes the
permitted sinking fund yield for each
month on its Internet site for State and
Local Government Series securities at
https://www.treasurydirect.gov.
SECTION 4. NATIONAL ZONE
ACADEMY BOND LIMITATION
FOR 2010
The national limitation for QZABs is-
sued under § 54E for calendar year 2010
is $1.4 billion. This amount is allocated
among the States as follows:
Qualified Zone Academy Bond Alloca-
tions by State or Territory, 2010
S
tateorTerritory
QZABAllocation(indollars)
Alabama24,649,000
Alaska2,113,000
Arizona
31,935,000
Arkansas16,361,000
California163,260,000
Colora
do
18,468
,000
Connecticut
10,533,000
Delaware3,004,000
DC
3,252,000
Florida
81,1
05,000
Georgia47,428,000
Hawa
ii
3,98
2,000
Idaho
6,352,000
Illinois
52,218,000
Indiana27,302,000
Iowa11,304,000
Kansas
10,510,000
Ke
ntucky
24
,481,000
Louisiana
25,786,000
Maine
5,503,000
Maryland
15,324,000
2010–10 I.R.B.436March 8, 2010

StateorTerritory
QZABAllocation(indollars)
Massachusetts
21,586,000
Michigan47,898,000
Minnesota16,722,000
Mississippi20,163,000
Missouri26,461,000
Montana
4,540,000
Nebraska6,368,000
Nevada9,846,000
New Hampshire3,413,000
New Jersey
25,271,000
New Mexico11,263,000
New York88,638,000
North Carolina
44,454,000
North Dak
ota
2,413,00
0
Ohio
50,855,000
Oklahoma
18,925,000
Oregon17,124,000
Pennsylvania
49,657
,000
Rhode Island4,172,000
South
Carolina
23,22
4,000
South Dakota
3,355,000
Tennessee
32,065,000
Texas
128,252,000
Utah8,931,000
Vermont2,134,000
Vir
ginia
26,185,000
Washington24,830,000
West Virginia
10,519,000
Wisconsin
19,585,000
Wyoming1,689,000
American Samoa
1
,351,000
Guam1,379,000
N
orthern Mariana Islands
8
68,000
Puerto Rico
59,775,000
Virgin Islands1,219,000
Total Allocation1,400,000,000
SECTION 5. EFFECTIVE DATE OF
NATIONAL ZONE ACADEMY BOND
LIMITATIONS
The national limitation allocated in sec-
tion4iseffectiveforQZABsissuedonor
after January 1, 2010.
SECTION 6. DRAFTING
INFORMATION
The principal authors of this notice are
Timothy L. Jones and David E. White of
the Office of Associate Chief Counsel (Fi-
nancial Institutions and Products). For fur-
ther information regarding this notice, con-
tact David E. White or Timothy L. Jones at
(202) 622–3980 (not a toll-free call).
March 8, 20104372010–10 I.R.B.

Part IV. Items o
fGeneralInterest
Correction to
Composite
Loss Discount
Factor for
Nonproportio
nal Assumed
Property Rei
nsurance in
Revenue Proc
edure 2009–55,
2009–52 I.R
.B. 982
Announceme
nt 2010–11
This docum
ent contains a correction
to Revenue
Procedure 2009–55, 2009–52
I.R.B. 982
. The composite loss discount
factor fo
r Reinsurance (Nonproportional
Assumed P
roperty) provided in Revenue
Procedur
e 2009–55 was incorrect.
The Reven
ue Procedure incorrectly
stated:
“Taxpaye
rs that use the composite
method of
Notice 88–100 should use
94.3133 p
ercent to discount unpaid losses
incurred
in this [the Reinsurance (Non-
proport
ional Assumed Property)] line of
busines
s in 2009 and prior years and that
are outs
tanding at the end of the 2019
taxable
year.”
The Reve
nue Procedure should have
stated:
“Taxpay
ers that use the composite
method o
f Notice 88–100 should use
96.313
3 percent to discount unpaid losses
incurr
ed in this [the Reinsurance (Non-
proportional
Assumed Property)] line of
business in 20
09 and prior years and that
are outstandi
ng at the end of the 2019
taxable year.
”
For further in
formation regarding this
announcement
,contactSarahE.Swanat
(202) 622–844
3 (not a toll-free call).
Deletions From Cumulative
List of Organizations
Contributions to Which
are Deductible Under Section
170 of the Code
Announcement 2010–15
The Inter
nal Revenue Service has re-
voked its
determination that the organi-
zations l
isted below qualify as organiza-
tions de
scribed in sections 501(c)(3) and
170(c)(
2) of the Internal Revenue Code of
1986.
General
ly, the Service will not disallow
deducti
ons for contributions made to a
listed o
rganization on or before the date
of anno
uncement in the Internal Revenue
Bullet
in that an organization no longer
qualif
ies. However, the Service is not
preclu
ded from disallowing a deduction
for any contri
butions made after an or-
ganization ce
ases to qualify under section
170(c)(2) if t
he organization has not timely
filed a suit fo
r declaratory judgment under
section7428a
nd if the contributor (1) had
knowledge of
the revocation of the ruling
or determina
tion letter, (2) was aware that
such revocat
ion was imminent, or (3) was
in part respo
nsible for or was aware of the
activities
or omissions of the organization
that brough
t about this revocation.
If on the oth
er hand a suit for declara-
tory judgme
nt has been timely filed, con-
tributions
from individuals and organiza-
tions descr
ibed in section 170(c)(2) that
are otherw
ise allowable will continue to
be deducti
ble. Protection under section
7428(c) wo
uld begin on March 8, 2010 and
would end o
n the date the court first deter-
mines that
the organization is not described
in sectio
n 170(c)(2) as more particularly
set forth
in section 7428(c)(1). For indi-
vidual co
ntributors, the maximum deduc-
tion prot
ected is $1,000, with a husband
and wife
treated as one contributor. This
benefit
is not extended to any individual, in
whole or
in part, for the acts or omissions
of the or
ganization that were the basis for
revocat
ion.
Remembr
ance Foundation
Alpine
,UT
2010–10 I.R.B.438March 8, 2010

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the ef-
fect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is be-
ingextendedtoapplytoavariationofthe
fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that the
same principle also applies to B, the earlier
ruling is amplified. (Compare withmodi-
fied,below).
Clarifiedis used in those instances
where the language in a prior ruling is be-
ing made clear because the language has
caused, or may cause, some confusion.
It is not used where a position in a prior
ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
withamplifiedandclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used in
a ruling that lists previously published rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
beingstatedinanewruling.
Supersededdescribes a situation where
the new ruling does nothing more than re-
state the substance and situation of a previ-
ously published ruling (or rulings). Thus,
the term is used to republish under the
1986 Code and regulations the same po-
sition published under the 1939 Code and
regulations. The term is also used when
it is desired to republish in a single rul-
ing a series of situations, names, etc., that
were previously published over a period of
time in separate rulings. If the new rul-
ing does more than restate the substance
of a prior ruling, a combination of terms
is used. For example,modifiedandsu-
persededdescribes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is self
contained. In this case, the previously pub-
lished ruling is first modified and then, as
modified, is superseded.
Supplementedis used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names in
subsequent rulings. After the original rul-
ing has been supplemented several times, a
new ruling may be published that includes
the list in the original ruling and the ad-
ditions, and supersedes all prior rulings in
the series.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of cases
in litigation, or the outcome of a Service
study.
Abbreviations
The fol
lowing abbreviations in current use
and for
merly used will appear in material
publis
hedintheBulletin.
A—Individual.
Acq.—A
cquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank
.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cu
mulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Coo
perative.
Ct.D.—Court Decision.
CY—County.
D—Decede
nt.
DC—Dummy Corporation.
DE—Donee.
Del. Order
—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Emp
loyer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduc
iary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Fo
reign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Fed
eral Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grante
e.
GP—General Partner.
GR—Grantor.
IC—Insura
nce Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited
Partner.
LR—Lessor.
M—Minor.
Nonacq.—No
nacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Persona
l Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Pa
rtnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Re
al Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsi
diary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target
Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Trans
feree.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpay
er.
TR—Trust.
TT—Trustee.
U.S.C.—Uni
ted States Code.
X—Corporation.
Y—Corporation.
Z—Corporat
ion.
March 8, 2010i2010–10 I.R.B.

Numerical Finding List
1
Bulletins 2010–1 through 2010–10
Announcements:
2010-1, 2010-4 I.R.B.333
2010-2, 2010-2 I.R.B.271
2010-3, 2010-4 I.R.B.333
2010-4, 2010-5 I.R.B.384
2010-5, 2010-6 I.R.B.402
2010-6, 2010-6 I.R.B.402
2010-7, 2010-6 I.R.B.403
2010-8, 2010-7 I.R.B.408
2010-9, 2010-7 I.R.B.408
2010-10, 2010-7 I.R.B.410
2010-11, 2010-10 I.R.B.438
2010-12, 2010-7 I.R.B.410
2010-13, 2010-8 I.R.B.426
2010-15, 2010-10 I.R.B.438
Notices:
2010-1, 2010-2 I.R.B.251
2010-2, 2010-2 I.R.B.251
2010-3, 2010-2 I.R.B.253
2010-4, 2010-2 I.R.B.253
2010-5, 2010-2 I.R.B.256
2010-6, 2010-3 I.R.B.275
2010-7, 2010-3 I.R.B.296
2010-8, 2010-3 I.R.B.297
2010-9, 2010-3 I.R.B.298
2010-10, 2010-3 I.R.B.299
2010-11, 2010-4 I.R.B.326
2010-12, 2010-4 I.R.B.326
2010-13, 2010-4 I.R.B.327
2010-14, 2010-5 I.R.B.344
2010-15, 2010-6 I.R.B.390
2010-16, 2010-6 I.R.B.396
2010-19, 2010-7 I.R.B.404
2010-20, 2010-8 I.R.B.422
2010-22, 2010-10 I.R.B.435
Proposed Regulations:
REG-132232-08, 2010-6 I.R.B.401
REG-137036-08, 2010-6 I.R.B.398
REG-101896-09, 2010-5 I.R.B.347
REG-131028-09, 2010-4 I.R.B.332
Revenue Procedures:
2010-1, 2010-1 I.R.B.1
2010-2, 2010-1 I.R.B.90
2010-3, 2010-1 I.R.B.110
2010-4, 2010-1 I.R.B.122
2010-5, 2010-1 I.R.B.165
2010-6, 2010-1 I.R.B.193
2010-7, 2010-1 I.R.B.231
2010-8, 2010-1 I.R.B.234
Revenue Procedures— Continued:
2010-9, 2010-2 I.R.B.258
2010-10, 2010-3 I.R.B.300
2010-11, 2010-2 I.R.B.269
2010-12, 2010-3 I.R.B.302
2010-13, 2010-4 I.R.B.329
2010-15, 2010-7 I.R.B.404
2010-17, 2010-8 I.R.B.425
2010-18, 2010-9 I.R.B.451
Revenue Rulings:
2010-1, 2010-2 I.R.B.248
2010-2, 2010-3 I.R.B.272
2010-3, 2010-3 I.R.B.272
2010-4, 2010-4 I.R.B.309
2010-5, 2010-4 I.R.B.312
2010-6, 2010-6 I.R.B.387
2010-7, 2010-8 I.R.B.417
2010-8, 2010-10 I.R.B.432
Treasury Decisions:
9474, 2010-4 I.R.B.322
9475, 2010-4 I.R.B.304
9476, 2010-5 I.R.B.336
9477, 2010-6 I.R.B.385
9478, 2010-4 I.R.B.315
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2009–27 through 2009–52 is in Internal Revenue Bulletin
2009–52, dated December 28, 2009.
2010–10 I.R.B.iiMarch 8, 2010

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2010–1 through 2010–10
Announcements:
2010-4
Corrected by
Ann. 2010-10, 2010-7 I.R.B.410
Notices:
2005-88
Superseded by
Notice 2010-13, 2010-4 I.R.B.327
2008-41
Modified by
Notice 2010-7, 2010-3 I.R.B.296
2008-55
Modified by
Notice 2010-3, 2010-2 I.R.B.253
2008-88
Modified by
Notice 2010-7, 2010-3 I.R.B.296
2008-113
Modified by
Notice 2010-6, 2010-3 I.R.B.275
2008-115
Modified by
Notice 2010-6, 2010-3 I.R.B.275
2009-11
Amplified by
Notice 2010-9, 2010-3 I.R.B.298
2009-13
Obsoleted by
T.D. 9478, 2010-4 I.R.B.315
REG-131028-09, 2010-4 I.R.B.332
2009-38
Amplified and superseded by
Notice 2010-2, 2010-2 I.R.B.251
Proposed Regulations:
REG-127270-06
Hearing scheduled by
Ann. 2010-6, 2010-6 I.R.B.402
Revenue Procedures:
80-59
Modified and superseded by
Rev. Proc. 2010-11, 2010-2 I.R.B.269
87-35
Obsoleted by
Rev. Proc. 2010-3, 2010-1 I.R.B.110
Revenue Procedures— Continued:
2008-14
Updated by
Rev. Proc. 2010-15, 2010-7 I.R.B.404
2008-33
Superseded by
Rev. Proc. 2010-16, 2010-9 I.R.B.427
2009-1
Superseded by
Rev. Proc. 2010-1, 2010-1 I.R.B.1
2009-2
Superseded by
Rev. Proc. 2010-2, 2010-1 I.R.B.90
2009-3
Superseded by
Rev. Proc. 2010-3, 2010-1 I.R.B.110
2009-4
Superseded by
Rev. Proc. 2010-4, 2010-1 I.R.B.122
2009-5
Superseded by
Rev. Proc. 2010-5, 2010-1 I.R.B.165
2009-6
Superseded by
Rev. Proc. 2010-6, 2010-1 I.R.B.193
2009-7
Superseded by
Rev. Proc. 2010-7, 2010-1 I.R.B.231
2009-8
Superseded by
Rev. Proc. 2010-8, 2010-1 I.R.B.234
2009-9
Superseded by
Rev. Proc. 2010-9, 2010-2 I.R.B.258
2009-15
Amplified and superseded by
Rev. Proc. 2010-12, 2010-3 I.R.B.302
2009-25
Superseded by
Rev. Proc. 2010-3, 2010-1 I.R.B.110
2009-55
Corrected by
Ann. 2010-11, 2010-10 I.R.B.438
2010-1
Corrected by
Ann. 2010-5, 2010-6 I.R.B.402
Revenue Rulings:
67-436
Obsoleted by
REG-101896-09, 2010-5 I.R.B.347
Revenue Rulings— Continued:
92-19
Supplemented in part by
Rev. Rul. 2010-7, 2010-8 I.R.B.417
2008-52
Supplemented and superseded by
Rev. Rul. 2010-2, 2010-3 I.R.B.272
Treasury Decisions:
9443
Corrected by
Ann. 2010-8, 2010-7 I.R.B.408
9458
Corrected by
Ann. 2010-7, 2010-6 I.R.B.403
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2009–27 through 2009–52 is in Internal Revenue Bulletin 2009–52, dated December 28,
2009.
March 8, 2010iii2010–10 I.R.B.

2010–10 I.R.B.March 8, 2010

March 8, 20102010–10 I.R.B.

INTERNAL REVENUE BULLETIN
The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue
Bulletin is sold on a yearly subscription basis by the Superintendent of Documents. Current subscribers are notified by the Superin-
tendent of Documents when their subscriptions must be renewed.
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