Internal Revenue Bulletin 2012-7 (PDF rendition): IRS Revenue Procedures

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Bulletin No. 201
2-7
February 13, 201
2
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.
EXEMPT ORGANIZATIONS
Rev. Proc. 2012–11, page 368.
This procedure sets forth procedures for issuing determination
letters and rulings on the exempt status of qualified nonprofit
health insurance issuers described in section 501(c)(29) of the
Code.
ADMINISTRATIVE
Rev. Proc. 2012–15, page 369.
This procedure updates Rev. Proc. 2011–13, 2011–3 I.R.B.
318, and identifies circumstances under which the disclosure
on a taxpayer’s income tax return with respect to an item or
a position is adequate for the purpose of reducing the under-
statement of income tax under section 6662(d) of the Code
and the purpose of avoiding the tax return preparer penalty un-
der section 6694(a).
Announcement 2012–9, page 377.
This document contains a correction to Announcement
2011–63, 2011–41 I.R.B. 503, which contained an incorrect
name in the Deletions From Cumulative List of Organizations
Contributions to Which are Deductible Under Section 170 of
the Code.
Announcements of Disbarments and Suspensions begin on page 373.
Finding Lists begin on page ii.

The IRS Mission
Provide Americ
a’s taxpayers top-quality service by helping
them understa
nd and meet their tax responsibilities and en-
force the law wi
th 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.
February 13, 20122012–7 I.R.B.

Part III. Administrative, Procedural, and Miscellaneous
26 CFR 1.501(c)(29)–1T: CO-OP health insurance
issuers (temporary).
Rev. Proc. 2012–11
SECTION 1. PURPOSE
This revenue procedure sets forth pro-
cedures for issuing determination letters
and rulings on the exempt status of qual-
ified nonprofit health insurance issuers
(QNHIIs) described in § 501(c)(29) of the
Internal Revenue Code (Code).
SECTION 2. BACKGROUND
Section 501(c)(29) of the Code pro-
vides requirements for tax-exemption
under § 501(a) for QNHIIs. Section
501(c)(29) was added to the Code by
§ 1322(h)(1) of the Patient Protection and
Affordable Care Act, Public Law 111–148
(March 23, 2010) (Affordable Care Act).
Section 1322 of the Affordable Care
Act directs the Centers for Medicare and
Medicaid Services (CMS) to establish the
Consumer Operated and Oriented Plan
program (CO-OP program). The purpose
of the CO-OP program is to foster the cre-
ation of member-governed QNHIIs that
will operate with a strong consumer focus
and offer qualified health plans in the indi-
vidual and small group markets. CMS will
provide loans and repayable grants (col-
lectively loans) to organizations applying
to become QNHIIs to help cover start-up
costs and meet any solvency requirements
in States in which the organization is li-
censed to issue qualified health plans.
A Funding Opportunity Announcement
for the CO-OP program (CFDA Number
93.545), published by CMS on July 28,
2011 (and amended on September 16,
2011), provides that for each loan, the
appropriate CMS official will issue a No-
tice of Award and Loan Agreement to the
QNHII. In addition, the Chief Executive
Officer of the QNHII, or an officer of the
QNHII’s Board of Directors, must sign
and return the Loan Agreement to CMS.
On December 13, 2011, CMS issued final
regulations implementing the CO-OP pro-
gram at 76 FR 77392.
The CMS final regulations define a
QNHII as an entity that, within specified
time frames, satisfies or can reasonably
be expected to satisfy the standards in
§ 1322(c) of the Affordable Care Act and
in the CMS final regulations. The entity
will constitute a QNHII until such time as
CMS determines that the entity does not
satisfy or cannot reasonably be expected
to satisfy these standards.
Section 501(c)(29)(A) provides that a
QNHII (within the meaning of § 1322(c)
of the Affordable Care Act) which has
received a loan or grant under the CO-OP
program may be recognized as exempt
from taxation under § 501(a), but only
for periods for which the organization is
in compliance with the requirements of
§ 1322 of the Affordable Care Act and
of any loan agreement with the Secretary
of Health and Human Services. Section
501(c)(29)(B) provides that a QNHII will
not qualify for tax-exemption unless it
meets four additional requirements, the
first of which is that the organization must
give notice to the Secretary of the Trea-
sury, in such manner as the Secretary may
by regulations prescribe, that it is apply-
ing for recognition of exemption as an
organization described in § 501(c)(29).
On February 7, 2012, the Treasury De-
partment and the IRS issued temporary
regulations at 77 FR 6005 authorizing
the IRS to prescribe the procedures by
which QNHIIs may apply to the IRS for
recognition of exemption from Federal
income tax. The temporary regulations
also authorize the IRS to recognize a
QNHII as exempt effective as of the later
ofthedateoftheQNHII’sformationor
March 23, 2010 (the date of enactment of
the Affordable Care Act), provided that the
application is submitted in the manner and
within the time prescribed by the IRS and
the QNHII’s prior purposes and activities
were consistent with the requirements for
exempt status under § 501(c)(29).
SECTION 3. RELATED REVENUE
PROCEDURES
QNHIIs seeking recognition of exemp-
tion under § 501(c)(29) should follow this
revenue procedure and, to the extent not
inconsistent with this revenue procedure,
Rev. Proc. 2012–9, 2012–2 I.R.B. 261,
or its successor revenue procedure. User
fees for requests for a determination let-
ter or ruling are set forth in Rev. Proc.
2012–8, 2012–1 I.R.B. 235, or its succes-
sor revenue procedure.
SECTION 4. WHAT ARE THE
PROCEDURES FOR REQUESTING
RECOGNITION OF EXEMPT STATUS
UNDER § 501(c)(29)
.01 Letter application.
A QNHII seeking recognition of ex-
emption under § 501(c)(29) must submit a
letter application (rather than a form) with
Form 8718,User Fee for Exempt Organ-
ization Determination Letter Request,and
include the appropriate user fee. For more
information on the user fee, see Rev. Proc.
2012–8, 2012–1 I.R.B. 235, or its succes-
sor revenue procedure. The request should
be mailed to:
IRS-TEGE
P.O. Box 2508
Cincinnati, OH 45201
.02 Requirements for a substantially
completed letter application.
A QNHII seeking recognition of ex-
emption under § 501(c)(29) must comply
with the requirements for a substantially
completed letter application set forth in
this section rather than the requirements
set forth in § 3.08 of Rev. Proc. 2012–9,
2012–2 I.R.B. 261, or its successor rev-
enue procedure.
A substantially completed letter appli-
cation for recognition of exemption un-
der § 501(c)(29) must be signed by an au-
thorized individual and must be accompa-
nied by the following declaration: “Under
penalties of perjury, I declare that I have
examined this request, including accompa-
nying documents, and, to the best of my
knowledge and belief, the request contains
all the relevant facts relating to the request,
and such facts are true, correct, and com-
plete.”
A substantially completed letter appli-
cation also must include:
(1) the QNHII’s Employer Identifica-
tion Number (EIN).
(2) a statement of receipts and expen-
ditures and a balance sheet for the cur-
rent year and the three preceding years (or
the years the QNHII was in existence, if
less than four years). If the QNHII has
2012–7 I.R.B.368February 13, 2012

not yet commenced operations, or has not
completed one accounting period, a sub-
stantially completed application generally
must include a proposed budget for two
full accounting periods and a current state-
ment of assets and liabilities.
(3) a detailed narrative statement of the
QNHII’s past and proposed activities and a
narrative descriptionof the QNHII’s actual
and anticipated receipts and contemplated
expenditures.
(4) a copy of the QNHII’s organizing or
enabling document that has been filed with
and certified by an appropriate official of
a State authority (e.g., stamped “Filed”
and dated by the Secretary of State). Al-
ternatively, if the QNHII is not required
to file its organizing or enabling docu-
ments with a State authority, the organiza-
tion may submit a copy of the organizing or
enabling document that meets the require-
ments of a “conformed copy” as outlined
in Rev. Proc. 68–14, 1968–1 C.B. 768.
(5) a current copy of the QNHII’s
by-laws, if applicable, or any similar gov-
erning documents.
(6) a copy of both the Notice of Award
issued by CMS and the fully executed
Loan Agreement with CMS.
(7) the following representations re-
garding the QNHII:
•Except to the extent allowed by
§ 1322(c)(4) of the Patient Protection
and Affordable Care Act, no part of
its net earnings inures to the benefit of
any private shareholder or individual,
or has so inured since the later of the
date of formation or March 23, 2010;
•No substantial part of its activi-
ties constitutes, or has constituted
since the later of the date of forma-
tion or March 23, 2010, carrying on
propaganda, or otherwise attempting,
to influence legislation; and
•It does not participate in, or intervene
in (including the publishing or dis-
tributing of statements), any political
campaign on behalf of (or in opposi-
tion to) any candidate for public office,
nor has it so participated or intervened
since the later of the date of formation
or March 23, 2010.
(8) a subject line or other indicator
on the first page of the request in bold,
underlined, and/or all capitals font indi-
cating “SECTION 501(c)(29) CO-OP
HEALTH INSURANCE ISSUER.”
(9) the correct user fee and Form 8718.
SECTION 5. EFFECT OF
DETERMINATION LETTER OR
RULING RECOGNIZING EXEMPTION
A determination letter or ruling recog-
nizing exemption under § 501(c)(29) is
usually effective as of the later of the date
of the QNHII’s formation or March 23,
2010 (the date of enactment of the Afford-
able Care Act) if:
•The QNHII’s purposes and activities
prior to the date of issuance of the de-
termination letter or ruling were con-
sistent with the requirements for ex-
emption; and
•The QNHII submits a substantially
completed letter application within 15
months of the date of its fully executed
Loan Agreement with CMS.
If the Service requires the QNHII to
alter its activities or make substantive
amendments to its enabling instrument,
exemption will be recognized effective as
of the date specified in the determination
letter or ruling. If the Service requires
the QNHII to make a nonsubstantive
amendment, exemption will ordinarily be
recognized as of the later of the date of the
QNHII’s formation or March 23, 2010.
If a QNHII does not submit a substan-
tially completed letter application within
15 months of the date of its fully executed
Loan Agreement with CMS, it may not
qualify for exempt status before the post-
mark date of the letter application.
SECTION 6. EFFECTIVE DATE
This revenue procedure is effective
February 7, 2012.
SECTION 7. PAPERWORK
REDUCTION ACT
The collection of information for a let-
ter application under § 3.01 of this rev-
enue procedure has been approved under
OMB control number 1545–2080. See
Rev. Proc. 2012–9, § 15.
DRAFTING INFORMATION
The principal author of this Revenue
Procedure is Justin Lowe of the Exempt
Organizations, Tax Exempt and Govern-
ment Entities Division. For further infor-
mation regarding this revenue procedure,
contact Mr. Lowe at 202–283–9486 (not a
toll-free call).
26 CFR 601.105: Examination of returns and claims
for refund, credit or abatement; determination of cor-
rect tax liability.
(Also: Part 1, §§ 6662, 6694, 1.6662–4, 1.6694–2.)
Rev. Proc. 2012–15
SECTION 1. PURPOSE
This revenue procedure updates Rev.
Proc. 2011–13, 2011–3 I.R.B. 318, and
identifies circumstances under which the
disclosure on a taxpayer’s income tax re-
turn with respect to an item or a position
is adequate for the purpose of reducing
the understatement of income tax under
section 6662(d) of the Internal Revenue
Code (relating to the substantial under-
statement aspect of the accuracy-related
penalty), and for the purpose of avoiding
the tax return preparer penalty under sec-
tion 6694(a) (relating to understatements
due to unreasonable positions) with re-
spect to income tax returns. This rev-
enue procedure does not apply with re-
spect to any other penalty provisions (in-
cluding the disregard provisions of the sec-
tion 6662(b)(1) accuracy-related penalty,
the section 6662(i) increased accuracy-re-
lated penalty in the case of nondisclosed
noneconomic substance transactions, and
the section 6662(j) increased accuracy-re-
lated penalty in the case of undisclosed for-
eign financial asset understatements).
This revenue procedure applies to
any income tax return filed on 2011
tax forms for a taxable year beginning
in 2011, and to any income tax return
filed on 2011 tax forms in 2012 for short
taxable years beginning in 2012.
SECTION 2. CHANGES FROM REV.
PROC. 2011–13
.01 This revenue procedure has been
updated to include reference to: (i) a cor-
rectiontothereferencetoScheduleM–3
February 13, 20123692012–7 I.R.B.

(Form 1120), Part III, and (ii) the em-
ployee-remuneration limitations under the
amended section 162(m).
SECTION 3. BACKGROUND
.01 If section 6662 applies to any por-
tion of an underpayment of tax required
to be shown on a return, an amount equal
to 20 percent of the portion of the under-
payment to which the section applies is
added to the tax (the penalty rate is 40 per-
cent in the case of gross valuation misstate-
ments under section 6662(h), nondisclosed
noneconomic substance transactions under
section 6662(i), or undisclosed foreign fi-
nancial asset understatements under sec-
tion 6662(j)). Section 6662(b)(2) applies
to the portion of an underpayment of tax
that is attributable to a substantial under-
statement of income tax.
.02 Section 6662(d)(1) provides that
there is a substantial understatement of
income tax if the amount of the understate-
ment exceeds the greater of 10 percent of
the amount of tax required to be shown on
the return for the taxable year or $5,000.
Section 6662(d)(1)(B) provides a special
rule for corporations. A corporation (other
than an S corporation or a personal holding
company) has a substantial understate-
ment of income tax if the amount of the
understatement exceeds the lesser of (i) 10
percent of the tax required to be shown on
the return for a taxable year (or, if greater,
$10,000) or (ii) $10,000,000. Section
6662(d)(2) defines an understatement as
the excess of the amount of tax required to
be shown on the return for the taxable year
over the amount of the tax that is shown
on the return reduced by any rebate.
.03 In the case of an item not at-
tributable to a tax shelter, section
6662(d)(2)(B)(ii) provides that, if there is
a reasonable basis for the tax treatment of
the item by taxpayer, the amount of the
understatement is reduced by the portion
of the understatement attributable to any
item with respect to which the relevant
facts affecting the item’s tax treatment are
adequately disclosed in the return or in a
statement attached to the return.
.04 Section 6694(a) imposes a penalty
on a tax return preparer who prepares a re-
turn or claim for refund reflecting an un-
derstatement of liability due to an “unrea-
sonable position” if the tax return preparer
knew (or reasonably should have known)
of the position. A position (other than a
position with respect to a tax shelter or
a reportable transaction to which section
6662A applies) is generally treated as un-
reasonable unless (i) there is or was sub-
stantial authority for the position, or (ii)
the position was properly disclosed in ac-
cordance with section6662(d)(2)(B)(ii)(I)
and had a reasonable basis. If the position
is with respect to a tax shelter (as defined in
section 6662(d)(2)(C)(ii)) or a reportable
transaction to which section 6662A ap-
plies, the position is treated as unreason-
able unless it is reasonable to believe that
the position would more likely than not
be sustained on the merits.SeeNotice
2009–5, 2009–3 I.R.B. 309 (January 21,
2009) for interim penalty compliance rules
for tax shelter transactions.
.05 In general, this revenue procedure
provides guidance for determining when
disclosure by return is adequate for pur-
poses of section 6662(d)(2)(B)(ii) and sec-
tion 6694(a)(2)(B). For purposes of this
revenue procedure, the taxpayer must fur-
nish all required information in accordance
with the applicable forms and instructions,
andthemoneyamountsenteredonthese
forms must be verifiable.
.06 Fiscal and short tax year returns. (a)
In general. This revenue procedure may
apply to a return for a fiscal tax year that
begins in 2011 and ends in 2012. This rev-
enue procedure may also apply to a short
year return for a period beginning in 2012
if the return is to be filed before the 2012
forms are available. (Note that individu-
als are generally not put in this position
as a decedent’s final return for a fractional
part of a year is due the fifteenth day of
the fourth month following the close of
the 12-month period which began with the
first day of such fractional part of the year.
SeeTreas. Reg. § 1.6072–1(b).) In the
case of fiscal year and short year returns,
the taxpayer must take into account any tax
law changes that are effective for tax years
beginning after December 31, 2011, even
though these changes are not reflected on
the form.
(b) Tax law changes effective after De-
cember 31, 2011. This document does
not take into account the effect of tax law
changes effective for tax years beginning
after December 31, 2011. If a line ref-
erenced in this revenue procedure is af-
fected by such a change and requires ad-
ditional reporting, a taxpayer may have
to file Form 8275,Disclosure Statement,
or Form 8275–R,Regulation Disclosure
Statement, until the Service prescribes cri-
teria for complying with the requirement.
.07 A complete and accurate disclo-
sure of a tax position on the appropriate
year’s Schedule UTP,Uncertain Tax Po-
sition Statement, will be treated as if the
corporation filed a Form 8275 or Form
8275–R regarding the tax position. The fil-
ing of a Form 8275 or Form 8275–R, how-
ever, will not be treated as if the corpora-
tion filed a Schedule UTP.
SECTION 4. PROCEDURE
.01 General
(1) Additional disclosure of facts rel-
evant to, or positions taken with respect
to, issues involving any of the items set
forth below is unnecessary for purposes
of reducing any understatement of income
tax under section 6662(d) (except as other-
wise provided in section 4.02(3) concern-
ing Schedules M–1 and M–3), provided
that the forms and attachments are com-
pleted in a clear manner and in accordance
with their instructions.
(2) The money amounts entered on the
forms must be verifiable, and the informa-
tion on the return must be disclosed in the
manner described below. For purposes of
this revenue procedure, a number is veri-
fiable if, on audit, the taxpayer can prove
the origin of the amount (even if that num-
ber is not ultimately accepted by the Inter-
nal Revenue Service) and the taxpayer can
show good faith in entering that number on
the applicable form.
(3) The disclosure of an amount as pro-
videdinsection4.02belowisnotade-
quate when the understatement arises from
a transaction between related parties. If an
entry may present a legal issue or contro-
versy because of a related-party transac-
tion, then that transaction and the relation-
ship must be disclosed on a Form 8275 or
Form 8275–R.
(4) When the amount of an item is
shown on a line that does not have a
preprinted description identifying that
item (such as on an unnamed line under an
“Other Expense” category), the taxpayer
must clearly identify the item by including
the description on that line. For example,
to disclose a bad debt for a sole propri-
etorship, the words “bad debt” must be
written or typed on the line of Schedule
2012–7 I.R.B.370February 13, 2012

C that shows the amount of the bad debt.
Also, for Schedule M–3 (Form 1120),
Part II, line 25, Other income (loss) items
with differences, or Part III, line 37, Other
expense/deduction items with differences,
the entry must provide descriptive lan-
guage; for example, “Cost of non-compete
agreement deductible not capitalizable.”
If space limitations on a form do not allow
for an adequate description, the descrip-
tion must be continued on an attachment.
(5) Although a taxpayer may literally
meet the disclosure requirements of this
revenue procedure, the disclosure will
have no effect for purposes of the section
6662 accuracy-related penalty if the item
or position on the return: (1) does not have
a reasonable basis as defined in Treas.
Reg. § 1.6662–3(b)(3); (2) is attributable
to a tax shelter item as defined in section
6662(d)(2); or (3) is not properly sub-
stantiated or the taxpayer failed to keep
adequate books and records with respect
to the item or position.
(6) Disclosure also will have no effect
for purposes of the section 6694(a) penalty
as applicable to tax return preparers if the
position is with respect to a tax shelter
(as defined in section 6662(d)(2)(C)(ii)) or
a reportable transaction to which section
6662A applies.
.02 Items
(1) Form 1040, Schedule A,Itemized
Deductions:
(a) Medical and Dental Expenses:
Complete lines 1 through 4, supplying all
required information.
(b) Taxes: Complete lines 5 through 9,
supplying all required information. Line 8
must list each type of tax and the amount
paid.
(c) Interest Expenses: Complete lines
10 through 15, supplying all required in-
formation. This section 4.02(1)(c) does
not apply to (i) amounts disallowed under
section 163(d) unless Form 4952,Invest-
ment Interest Expense Deduction,iscom-
pleted, or (ii) amounts disallowed under
section 265.
(d) Contributions: Complete lines 16
through 19, supplying all required infor-
mation. Enter the amount of the contribu-
tion reduced by the value of any substan-
tial benefit (goods or services) provided by
the donee organization in consideration, in
whole or in part. Entering the value of
the contribution unreduced by the value
of the benefit received will not constitute
adequate disclosure. If a contribution of
$250 or more is made, this section will
not apply unless a contemporaneous writ-
ten acknowledgment, as required by sec-
tion 170(f)(8), is obtained from the donee
organization. If a contribution of cash of
less than $250 is made, this section will
not apply unless a bank record or writ-
ten communication from the donee, as re-
quired by section 170(f)(17), is obtained
from the donee organization. If a contri-
bution of property other than cash is made
and the amount claimed as a deduction ex-
ceeds $500, attach a properly completed
Form 8283,Noncash Charitable Contri-
butions, to the return. In addition to the
Form 8283, if a contribution of a quali-
fied motor vehicle, boat, or airplane has a
value of more than $500, this section will
not apply unless a contemporaneous writ-
ten acknowledgment, as required by sec-
tion 170(f)(12), is obtained from the donee
organization and attached to the return. An
acknowledgment under section 170(f)(8)
is not required if an acknowledgment un-
der section 170(f)(12) is required.
(e) Casualty and Theft Losses: Com-
plete Form 4684,Casualties and Thefts,
and attach to the return. Each item or ar-
ticle for which a casualty or theft loss is
claimed must be listed on Form 4684.
(2) Certain Trade or Business Expenses
(including, for purposes of this section, the
following six expenses as they relate to the
rental of property):
(a) Casualty and Theft Losses: The pro-
cedure outlined in section 4.02(1)(e) must
be followed.
(b) Legal Expenses: The amount
claimed must be stated. This section does
not apply, however, to amounts prop-
erly characterized as capital expenditures,
personal expenses, or non-deductible lob-
bying or political expenditures, including
amounts that are required to be (or that
are) amortized over a period of years.
(c) Specific Bad Debt Charge-off: The
amount written off must be stated.
(d) Reasonableness of Officers’ Com-
pensation: Form 1120, Schedule E,Com-
pensation of Officers, must be completed
when required by its instructions. The time
devoted to business must be expressed as
a percentage as opposed to “part” or “as
needed.” This section does not apply to
“golden parachute” payments, as defined
under section 280G. This section will not
apply to the extent that remuneration paid
or incurred exceeds the employee-remu-
neration limitations under section 162(m),
if applicable.
(e) Repair Expenses: The amount
claimed must be stated. This section does
not apply, however, to any repair expenses
properly characterized as capital expendi-
tures or personal expenses.
(f) Taxes (other than foreign taxes): The
amount claimed must be stated.
(3) Differences in book and income tax
reporting.
For Schedule M–1 and all Schedules
M–3, including those listed in (a)–(f) be-
low, the information provided must rea-
sonably apprise the Service of the poten-
tial controversy concerning the tax treat-
ment of the item. If the information pro-
vided does not so apprise the Service, a
Form 8275 or Form 8275–R must be used
to adequately disclose the item (see Part II
of the instructions for those forms).
Note: Anitemreportedonalinewith
a pre-printed description, shown on
an attached schedule or “itemized” on
Schedule M–1, may represent the ag-
gregate amount of several transactions
producing that item (i.e.,agroupof
similar items, such as amounts paid or
incurred for supplies by a taxpayer en-
gaged in business). In some instances,
a potentially controversial item may in-
volve a portion of the aggregate amount
disclosed on the schedule. The Service
will not be reasonably apprised of a
potential controversy by the aggregate
amount disclosed. In these instances,
the taxpayer must use Form 8275 or
Form 8275–R regarding that portion of
the item.
Combining unlike items, whether on
Schedule M–1 or Schedule M–3 (or on an
attachment when directed by the instruc-
tions), will not constitute an adequate dis-
closure.
Additionally, for taxpayers that file
the Schedule M–3 (Form 1120), the new
Schedule B,Additional Information for
Schedule M–3 Filers,must also be com-
pleted. For taxpayers that file the Schedule
M–3 (Form 1065), the new Schedule C,
Additional Information for Schedule M–3
Filers, must also be completed. When re-
quired, these new Schedules are necessary
to constitute adequate disclosure.
(a) Form 1065. Schedule M–3 (Form
1065),Net Income (Loss) Reconciliation
for Certain Partnerships:Column(a),
February 13, 20123712012–7 I.R.B.

Income (Loss) per Income Statement,of
Part II (reconciliation of income (loss)
items) and Column (a),Expense per In-
come Statement, of Part III (reconciliation
of expense/deduction items); Column (b),
Temporary Difference,andColumn(c),
Permanent Difference, of Part II (recon-
ciliation of income (loss) items) and Part
III (reconciliation of expense/deduction
items); and Column (d),Income (Loss)
per Tax Return, of Part II (reconciliation
of income (loss) items) and Column (d),
Deduction per Tax Return, of Part III (rec-
onciliation of expense/deduction items).
(b) Form 1120. (i) Schedule M–1,Rec-
onciliation of Income (Loss) per Books
With Income per Return.
(ii) Schedule M–3 (Form 1120),Net
Income (Loss) Reconciliation for Corpo-
rations with Total Assets of $10 Million
or More:Column(a),Income (Loss) per
Income Statement, of Part II (reconcilia-
tion of income (loss) items) and Column
(a),Expense per Income Statement,of
Part III (reconciliation of expense/de-
duction items); Column (b),Temporary
Difference,andColumn(c),Permanent
Difference, of Part II (reconciliation of
income (loss) items) and Part III (recon-
ciliation of expense/deduction items) and
Column (d),Income (Loss) per Tax Re-
turn, of Part II (reconciliation of income
(loss) items); and Column (d),Deduction
per Tax Return, of Part III (reconciliation
of expense/deduction items).
(c) Form 1120–L. Schedule M–3 (Form
1120–L),Net Income (Loss) Reconcilia-
tion for U.S. Life Insurance Companies
With Total Assets of $10 Million or More:
Column (a),Income (Loss) per Income
Statement, of Part II (reconciliation of
income (loss) items) and Column (a),
Expense per Income Statement,ofPart
III (reconciliation of expense/deduction
items); Column (b),Temporary Differ-
ence,andColumn(c),Permanent Differ-
ence, of Part II (reconciliation of income
(loss) items) and Part III (reconciliation
of expense/deduction items); and Col-
umn (d),Income (Loss) per Tax Return,
of Part II (reconciliation of income (loss)
items) and Column (d),Deduction per
Tax Return, of Part III (reconciliation of
expense/deduction items).
(d) Form 1120–PC. Schedule M–3
(Form 1120–PC),Net Income (Loss) Rec-
onciliation for U.S. Property and Casualty
Insurance Companies With Total Assets
of $10 Million or More:Column(a),In-
come (Loss) per Income Statement,of
Part II (reconciliation of income (loss)
items) and Column (a),Expense per In-
come Statement, of Part III (reconciliation
of expense/deduction items); Column (b),
Temporary Difference,andColumn(c),
Permanent Difference, of Part II (recon-
ciliation of income (loss) items) and Part
III (reconciliation of expense/deduction
items); and Column (d),Income (Loss)
per Tax Return, of Part II (reconciliation
of income (loss) items) and Column (d),
Deduction per Tax Return, of Part III (rec-
onciliation of expense/deduction items).
(e) Form 1120S. Schedule M–3 (Form
1120S),Net Income (Loss) Reconciliation
for S Corporations With Total Assets of
$10 Million or More:Column(a),
Income
(Loss) per Income Statement,ofPartII
(reconciliation of income (loss) items)
and Column (a),Expense per Income
Statement, of Part III (reconciliation of
expense/deduction items); Column (b),
Temporary Difference,andColumn(c),
Permanent Difference, of Part II (recon-
ciliation of income (loss) items) and Part
III (reconciliation of expense/deduction
items); and Column (d),Income (Loss)
per Tax Return, of Part II (reconciliation
of income (loss) items) and Column (d),
Deduction per Tax Return, of Part III (rec-
onciliation of expense/deduction items).
(f) Form 1120–F. Schedule M–3 (Form
1120–F),Net Income (Loss) Reconcilia-
tion for Foreign Corporations With Total
Assets of $10 Million or More: Column
(b),Temporary Difference,Column(c),
Permanent Difference,andColumn(d),
Other Permanent Differences for Allo-
cations to Non-ECI and ECI,of Part II
(reconciliation of income (loss) items) and
Part III (reconciliation of expense/deduc-
tion items).
(4) Foreign Tax Items:
(a) International Boycott Transactions:
Transactions disclosed on Form 5713,
International Boycott Report; Schedule
A,International Boycott Factor (Sec-
tion 999(c)(1)); Schedule B,Specifically
Attributable Taxes and Income (Section
999(c)(2)); and Schedule C,Tax Effect
of the International Boycott Provisions,
must be completed when required by their
instructions.
(b) Treaty-Based Return Position:
Transactions and amounts under section
6114 or section 7701(b) as disclosed on
Form 8833,Treaty-Based Return Posi-
tion Disclosure Under Section 6114 or
7701(b), must be completed when required
by its instructions.
(5) Other:
(a) Moving Expenses: Complete Form
3903,Moving Expenses, and attach to the
return.
(b) Employee Business Expenses:
Complete Form 2106,Employee Business
Expenses, or Form 2106–EZ,Unreim-
bursed Employee Business Expenses,and
attach to the return. This section does not
apply to club dues, or to travel expenses
for any non-employee accompanying the
taxpayer on the trip.
(c) Fuels Credit: Complete Form 4136,
Credit for Federal Tax Paid on Fuels,and
attach to the return.
(d) Investment Credit: Complete Form
3468,Investment Credit, and attach to the
return.
SECTION 5. EFFECTIVE DATE
This revenue procedure applies to any
incometaxreturnfiledona2011taxform
for a taxable year beginning in 2011, and
to any income tax return filed on a 2011
taxformin2012forashorttaxableyear
beginning in 2012.
SECTION 6. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Thomas W. Curteman, Jr.
of the Office of Associate Chief Counsel
(Procedure & Administration). For further
information regarding this revenue proce-
dure, contact Branch 2 of Procedure and
Administration at (202) 622–4940 (not a
toll-free call).
2012–7 I.R.B.372February 13, 2012

Part IV. Items o
fGeneralInterest
Announcement of Disciplinary Sanctions From the Office
of Professional Responsibility
Announcement 2012-8
TheOfficeofProfessionalResponsi-
bility (OPR) announcesrecent disciplinary
sanctions involving attorneys, certified
public accountants, enrolled agents, en-
rolled actuaries, enrolled retirement plan
agents, and appraisers. These individuals
are subject to the regulations governing
practice before the Internal Revenue Ser-
vice (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
violating the regulations.
The disciplinary sanctions to be im-
posed for violation of the regulations are:
Disbarred from practice before the
IRS—An individual who is disbarred is
not eligible to represent taxpayers before
the IRS.
Suspended from practice before the
IRS—An individual who is suspended is
not eligible to represent taxpayers before
the IRS 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 represent taxpayers before the IRS, but
OPR may subject the individual’s future
representations to conditions designed to
promote high standards of conduct.
Monetary penalty—A monetary
penalty may be imposed on an individual
who engages in conduct subject to sanc-
tion or on an employer, firm, or entity
if the individual was acting on its behalf
and if 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.
Under the regulations, attorneys, cer-
tified public accountants, enrolled agents,
enrolled actuaries, and enrolled retirement
plan agents may not assist, or accept assis-
tance from, individuals who are suspended
or disbarred with respect to matters consti-
tuting practice (i.e., representation) before
the IRS, and they may not aid or abet sus-
pended or disbarred individuals to practice
before the IRS.
Disciplinary sanctions are described in
these terms:
Disbarred by decision after hearing,
Suspended by decision after hearing,
Censured by decision after hearing,
Monetary penalty imposed after hear-
ing, and Disqualified after hearing—An
administrative law judge (ALJ) conducted
an evidentiary hearing upon OPR’s com-
plaint alleging violation of the regulations
and issued a decision imposing one of
these sanctions. After 30 days from the
issuance of the decision, in the absence of
an appeal, the ALJ’s decision became the
final agency decision.
Disbarred by default decision, Sus-
pended by default decision, Censured by
default decision, Monetary penalty im-
posed by default decision, and Disqual-
ified by default decision—An ALJ, after
findingthatnoanswertoOPR’scomplaint
had been filed, granted OPR’s motion for a
default judgment and issued a decision im-
posing 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 ap-
peal, 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 opportunity,
after a stated number of months, to file
with OPR a petition for reinstatement af-
firming compliance with the terms of the
consent and affirming current eligibility
to practice (i.e., an active professional
license or active enrollment status). An
enrolled agent or an enrolled retirement
plan agent may also offer to resign in order
to avoid a disciplinary proceeding.
Suspended by decision in expedited
proceeding, Suspended by default de-
cision in expedited proceeding, Sus-
pended by consent in expedited pro-
ceeding—OPR instituted an expedited
proceeding for suspension (based on cer-
tain limited grounds, including loss of a
professional license and criminal convic-
tions).
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 decision
on or after September 26, 2007, which was
theeffectivedateofamendmentstothe
regulations that permit making such deci-
sions publicly available; (2) the individual
has settled a disciplinary case by signing
OPR’s “consent to sanction” form, which
requires consenting individuals to admit to
one or more violations of the regulations
and to consent to the disclosure of the in-
dividual’s own return information related
to the admitted violations (for example,
failure to file Federal income tax returns);
or (3) OPR has issued a decision in an
expedited proceeding for suspension.
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 the names of states and sec-
ond by the last names of individuals. Un-
less otherwise indicated, section numbers
(e.g., §10.51) refer to the regulations.
February 13, 20123732012–7 I.R.B.

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Arizona
Fountain HillsHeck, Donald O.AttorneySuspended by default
decision in expedited
proceeding under §10.82
(attorney disbarment)
Indefinite from
November 8, 2011
California
W. HollywoodCurcio, GregoryAttorneySuspended for breach of
Deferred Disciplinary
Agreement, which
required timely filing
of all required tax returns
Indefinite from
August 30, 2011
but not less than
48 months
Mountain ViewGeorge, Robert D.AttorneySuspended by default
decision in expedited
proceeding under §10.82
(attorney disbarment)
Indefinite from
November 8, 2011
N. HollywoodGlicker, Brian I.AttorneySuspended by default
decision in expedited
proceeding under §10.82
(attorney disbarment)
Indefinite from
November 8, 2011
Granada HillsHoover, Steven G.AttorneySuspended by default
decision in expedited
proceeding under §10.82
(attorney disbarment)
Indefinite from
November 8, 2011
NewarkReplogle, David K.AttorneySuspended by default
decision in expedited
proceeding under §10.82
(suspension of attorney
license)
Indefinite from
November 8, 2011
Idaho
BoiseSandifer, MarthaCPASuspended by consent
for admitted violation
of §10.51 (failure to file
Federal individual income
taxreturnfortaxyears
2005, 2006, 2007, and
2008, failure to timely file
U.S. Income Tax Returns
for an S Corporation for
tax years 2005, 2006,
2007 and 2008, failure
to timely file a Quarterly
Federal Employment Tax
Returns for tax quarter
2005–09, and failure to
timely pay employment
tax balances for that
quarter) and violation
of §10.20 (failure to
Indefinite from
October 25, 2011
but not less than
48 months
2012–7 I.R.B.374February 13, 2012

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
respond to OPR’s proper
and lawful requests for
information)
Illinois
Sugar GroveMoscarello,
Catherine A.
AttorneySuspended by default
decision in expedited
proceeding under §10.82
(suspension of attorney
license)
Indefinite from
November 8, 2011
Iowa
CliveMusin, Howard A.Enrolled AgentSuspended by decision
in expedited proceeding
under §10.82 (enjoined
from acting as a tax
preparer)
Indefinite from
November 8, 2011
Ohio
ColumbianaKauffman, George B.CPASuspended by default
decision in expedited
proceeding under §10.82
(revocation of CPA
license)
Indefinite from
November 14, 2011
BlacklickLeither, Leon N.CPASuspended by default
decision in expedited
proceeding under §10.82
(revocation of CPA
license)
Indefinite from
November 14, 2011
ColumbusMerrelli, Joseph J.CPASuspended by default
decision in expedited
proceeding under §10.82
(revocation of CPA
license)
Indefinite from
November 14, 2011
TrentonMoon, Bryan
M.
CPASuspended b
y default
decision i
n expedited
proceedin
g under §10.82
(revocati
on of CPA
license)
Indefinite
from
November 1
4, 2011
ChardonNavatsyk, Donald A.AttorneyDisbarred by ALJ
decision for violation of
10.20 (failure to provide
information requested
by OPR) and 10.51
(submission or false or
misleading information
to OPR; failure to file
income tax returns and
pay the underlying taxes
due thereon for five
consecutive years)
Indefinite from
November 5, 2010
February 13, 20123752012–7 I.R.B.

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Ohio (Continued)
DaytonQuatman, John J.CPASuspended by default
decision in expedited
proceeding under §10.82
(revocation of CPA
license)
Indefinite from
November 14, 2011
Rossi, Philip D.,
See West Virginia
AvonSmith, Joseph H.CPASuspended by default
decision in expedited
proceeding under §10.82
(revocation of CPA
license)
Indefinite from
October 11, 2011
Texas
San AntonioArocha, Robert T.CPASuspended by decision
in expedited proceeding
under §10.82 (revocation
of CPA license)
Indefinite from
October 11, 2011
DallasBragg, Jeffrey M.AttorneySuspended by default
decision in expedited
proceeding under §10.82
(attorney disbarment)
Indefinite from
October 11, 2011
New BraunfelsClark, Mark A.AttorneySuspended by default
decision in expedited
proceeding under §10.82
(suspension of attorney
license)
Indefinite from
October 11, 2011
LongviewGardner, William J.AttorneySuspended by default
decision in expedited
proceeding under §10.82
(suspension of attorney
license)
Indefinite from
October 11, 2011
San AntonioGoains, Michael D.AttorneySuspended by default
decision in expedited
proceeding under §10.82
(suspension of attorney
license)
Indefinite from
October 11, 2011
HoustonMurff, David L.AttorneySuspended by default
decision in expedited
proceeding under §10.82
(suspension of attorney
license)
Indefinite from
October 11, 2011
2012–7 I.R.B.376February 13, 2012

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Texas (Continued)
Fort WorthSmith, Donald T.AttorneySuspended by default
decision in expedited
proceeding under §10.82
(suspension of attorney
license)
Indefinite from
November 14, 2011
Washington
RichlandPreszler, Terry J.AttorneySuspended by default
decision in expedited
proceeding under §10.82
(suspension of attorney
license)
Indefinite from
November 14, 2011
WestVirginia
BeaverRossi, Philip D.Public AccountantSuspended by default
decision in expedited
proceeding under
§10.82 (conviction
under 18 U.S.C. §1341,
mail fraud; revocation
of public accountant
registration in Ohio)
Indefinite from
November 14, 2011
Deletions From Cumulative
List of Organizations
Contributions to Which
are Deductible Under Section
170 of the Code; Correction
Announcement 2012–9
This document contains a correction
to Announcement 2011–63, 2011–41
I.R.B. 503, which contained an incorrect
name. The taxpayer name incorrectly
read: “Allied Veterans Allied Veterans of
the World Inc. & Affiliates.”
The taxpayer name should have read:
“Allied Veterans of the World Inc. &
Affiliates Post #24 Inc.”
FOR FURTHER INFORMATION
CONTACT:
Flora J. McClain
MS 4920 DAL
1100 Commerce Street
Dallas, TX 75247
February 13, 20123772012–7 I.R.B.

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.
2012–7 I.R.B.iFebruary 13, 2012

Numerical Finding List
1
Bulletins 2012–1 through 2012–7
Announcements:
2012-1, 2012-1 I.R.B.249
2012-2, 2012-2 I.R.B.285
2012-3, 2012-4 I.R.B.335
2012-4, 2012-4 I.R.B.335
2012-5, 2012-5 I.R.B.348
2012-6, 2012-6 I.R.B.366
2012-7, 2012-6 I.R.B.367
2012-8, 2012-7 I.R.B.373
2012-9, 2012-7 I.R.B.377
Notices:
2012-1, 2012-2 I.R.B.260
2012-3, 2012-3 I.R.B.289
2012-4, 2012-3 I.R.B.290
2012-5, 2012-3 I.R.B.291
2012-6, 2012-3 I.R.B.293
2012-7, 2012-4 I.R.B.308
2012-8, 2012-4 I.R.B.309
2012-9, 2012-4 I.R.B.315
2012-10, 2012-5 I.R.B.343
2012-11, 2012-5 I.R.B.346
2012-12, 2012-6 I.R.B.365
Proposed Regulations:
REG-149625-10, 2012-2 I.R.B.279
REG-102988-11, 2012-4 I.R.B.326
REG-130777-11, 2012-5 I.R.B.347
Revenue Procedures:
2012-1, 2012-1 I.R.B.1
2012-2, 2012-1 I.R.B.92
2012-3, 2012-1 I.R.B.113
2012-4, 2012-1 I.R.B.125
2012-5, 2012-1 I.R.B.169
2012-6, 2012-1 I.R.B.197
2012-7, 2012-1 I.R.B.232
2012-8, 2012-1 I.R.B.235
2012-9, 2012-2 I.R.B.261
2012-10, 2012-2 I.R.B.273
2012-11, 2012-7 I.R.B.368
2012-12, 2012-2 I.R.B.275
2012-13, 2012-3 I.R.B.295
2012-14, 2012-3 I.R.B.296
2012-15, 2012-7 I.R.B.369
Revenue Rulings:
2012-1, 2012-2 I.R.B.255
2012-2, 2012-3 I.R.B.286
2012-5, 2012-5 I.R.B.337
2012-6, 2012-6 I.R.B.349
2012-7, 2012-6 I.R.B.362
Treasury Decisions:
9559, 2012-2 I.R.B.252
9560, 2012-4 I.R.B.299
9561, 2012-5 I.R.B.341
9562, 2012-5 I.R.B.339
9563, 2012-6 I.R.B.354
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2011–27 through 2011–52 is in Internal Revenue Bulletin
2011–52, dated December 27, 2011.
February 13, 2012ii2012–7 I.R.B.

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2012–1 through 2012–7
Announcements:
2011-63
Corrected by
Ann. 2012-9, 2012-7 I.R.B.377
Notices:
2010-88
As modified by Ann. 2011-40, is superseded by
Notice 2012-1, 2012-2 I.R.B.260
2011-28
Superseded by
Notice 2012-9, 2012-4 I.R.B.315
Revenue Procedures:
2003-61
Superseded by
Notice 2012-8, 2012-4 I.R.B.309
2007-44
Modified by
Ann. 2012-3, 2012-4 I.R.B.335
2011-1
Superseded by
Rev. Proc. 2012-1, 2012-1 I.R.B.1
2011-2
Superseded by
Rev. Proc. 2012-2, 2012-1 I.R.B.92
2011-3
Superseded by
Rev. Proc. 2012-3, 2012-1 I.R.B.113
2011-4
Superseded by
Rev. Proc. 2012-4, 2012-1 I.R.B.125
2011-5
Superseded by
Rev. Proc. 2012-5, 2012-1 I.R.B.169
2011-6
Superseded by
Rev. Proc. 2012-6, 2012-1 I.R.B.197
2011-7
Superseded by
Rev. Proc. 2012-7, 2012-1 I.R.B.232
2011-8
Superseded by
Rev. Proc. 2012-8, 2012-1 I.R.B.235
2011-9
Superseded by
Rev. Proc. 2012-9, 2012-2 I.R.B.261
Revenue Procedures— Continued:
2011-10
Superseded by
Rev. Proc. 2012-10, 2012-2 I.R.B.273
2011-40
Corrected by
Ann. 2012-6, 2012-6 I.R.B.366
2011-49
Modified by
Ann. 2012-3, 2012-4 I.R.B.335
2011-50
Corrected by
Ann. 2012-6, 2012-6 I.R.B.366
2011-51
Corrected by
Ann. 2012-6, 2012-6 I.R.B.366
2012-8
Corrected by
Ann. 2012-7, 2012-6 I.R.B.367
Revenue Rulings:
92-19
Supplemented in part by
Rev. Rul. 2012-6, 2012-6 I.R.B.349
2008-40
Modified by
Notice 2012-6, 2012-3 I.R.B.293
2011-1
Modified by
Notice 2012-6, 2012-3 I.R.B.293
Treasury Decision:
9517
Corrected by
Ann. 2012-4, 2012-4 I.R.B.335
Ann. 2012-5, 2012-5 I.R.B.348
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2011–27 through 2011–52 is in Internal Revenue Bulletin 2011–52, dated December 27,
2011.
2012–7 I.R.B.iiiFebruary 13, 2012

February 13, 20122012–7 I.R.B.

2012–7 I.R.B.February 13, 2012

February 13, 20122012–7 I.R.B.

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