Internal Revenue Bulletin 2010-20 (PDF rendition): IRS Announcements

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

Bulletin No. 201
0-20
May 17, 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
Notice 2010–38, page 682.
This notice provides guidance on the exclusion from employ-
ees’ gross income for employer-provided accident and health
plan coverage for employees’ children under age 27, on the
employment tax treatment of these benefits, and on the paral-
lel amendments to section 401(h) for retiree health accounts
in pension plans, section 501(c)(9) (voluntary employees’ ben-
eficiary associations (VEBAs)), and the deductions by self-em-
ployed individuals under section 162(1).
EMPLOYEE PLANS
Notice 2010–38, page 682.
This notice provides guidance on the exclusion from employ-
ees’ gross income for employer-provided accident and health
plan coverage for employees’ children under age 27, on the
employment tax treatment of these benefits, and on the paral-
lel amendments to section 401(h) for retiree health accounts
in pension plans, section 501(c)(9) (voluntary employees’ ben-
eficiary associations (VEBAs)), and the deductions by self-em-
ployed individuals under section 162(1).
EXEMPT ORGANIZATIONS
Announcement 2010–35, page 685.
TheIRShasrevokeditsdeterminationthattheAnnArborSpark
of Ann Arbor, MI, and the Indigenous Nations Federal Charter
Association Buffalo Reserve Charitable Trust of Norman, OK,
qualify as organizations described in sections 501(c)(3) and
170(c)(2) of the Code.
EMPLOYMENT TAX
Notice 2010–38, page 682.
This notice provides guidance on the exclusion from employ-
ees’ gross income for employer-provided accident and health
plan coverage for employees’ children under age 27, on the
employment tax treatment of these benefits, and on the paral-
lel amendments to section 401(h) for retiree health accounts
in pension plans, section 501(c)(9) (voluntary employees’ ben-
eficiary associations (VEBAs)), and the deductions by self-em-
ployed individuals under section 162(1).
ADMINISTRATIVE
Announcement 2010–34, page 685.
This document contains a correction to Announcement
2010–22, 2010–16 I.R.B. 602, regarding implementation of
FATCA and request for comments. The Federal e-Rulemaking
Portal was incorrect.
Announcements of Disbarments and Suspensions begin on page 685.
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.
May 17, 20102010–20 I.R.B.

Part III. Administrative, Procedural, and Miscellaneous
Tax Treatment of Health
Care Benefits Provided With
Respect to Children Under
Age 27
Notice 2010–38
I. PURPOSE
This notice provides guidance on the
tax treatment of health coverage for chil-
dren up to age 27 under the Affordable
Care Act. (In this notice, the “Affordable
Care Act” refers to the Patient Protec-
tion and Affordable Care Act, Public
Law No. 111–148 (PPACA), and the
Health Care and Education Reconciliation
Act of 2010, Public Law No. 111–152
(HCERA), signed into law by the President
on March 23 and 30, 2010, respectively.)
The Affordable Care Act requires group
health plans and health insurance issuers
that provide dependent coverage of chil-
dren to continue to make such coverage
available for an adult child until age 26.
The Affordable Care Act also amends the
Internal Revenue Code (Code) to give cer-
tain favorable tax treatment to coverage
for adult children. This notice addresses
a number of questions regarding the tax
treatment of such coverage.
Specifically, this notice provides guid-
ance on the Affordable Care Act’s amend-
ment of § 105(b) of the Code, effective
March 30, 2010, to extend the general
exclusion from gross income for reim-
bursements for medical care under an
employer-provided accident or health
plan to any employee’s child who has not
attained age 27 as of the end of the tax-
able year. (See § 1004(d) of HCERA.)
The Affordable Care Act also makes par-
allel amendments, effective March 30,
2010, to § 401(h) for retiree health ac-
counts in pension plans, to § 501(c)(9)
for voluntary employees’ beneficiary as-
sociations (VEBAs), and to § 162(l) for
deductions by self-employed individuals
for medical care insurance. (See § 1004(d)
of HCERA.)
The Affordable Care Act amended the
Public Health Service Act (PHS Act) to
add § 2714, which requires group health
plans and health insurance issuers that pro-
vide dependent coverage of children to
continue to make such coverage available
for an adult child until age 26. (See § 1001
of PPACA.) Section 2714 of the PHS Act
is incorporated into § 9815 of the Code by
§ 1562(f) of PPACA. In certain respects,
the rules of § 2714 of the PHS Act extend-
ing coverage to an adult child do not par-
allel the gross income exclusion rules pro-
vided by the Affordable Care Act’s amend-
ments of §§ 105(b), 401(h), 501(c)(9), and
162(l) of the Code. For example, § 2714 of
the PHS Act applies to children under age
26 and is effective for the first plan year
beginning on or after September 23, 2010,
while, as noted above, the amendments to
the Code addressed in this notice apply to
children who have not attained age 27 as
of the end of the taxable year and are ef-
fective March 30, 2010.
II. EXCLUSION OF
EMPLOYER-PROVIDED MEDICAL
CARE REIMBURSEMENTS FOR
EMPLOYEE’S CHILD UNDER AGE 27
Section 105(b) generally excludes
from an employee’s gross income em-
ployer-provided reimbursements made
directly or indirectly to the employee for
the medical care of the employee, em-
ployee’s spouse or employee’s dependents
(as defined in § 152 (determined without
regard to § 152(b)(1), (b)(2) or (d)(1)(B)).
As amended by the Affordable Care Act,
the exclusion from gross income under
§ 105(b) is extended to employer-provided
reimbursements for expenses incurred by
the employee for the medical care of the
employee’s child (within the meaning of
§ 152(f)(1)) who has not attained age 27
as of the end of the taxable year. (The
Affordable Care Act does not alter the
existing definitions of spouse or depen-
dent for purposes of § 105(b).) Under
§ 152(f)(1), a child is an individual who is
the son, daughter, stepson, or stepdaughter
of the employee, and a child includes both
a legally adopted individual of the em-
ployee and an individual who is lawfully
placed with the employee for legal adop-
tion by the employee. Under § 152(f)(1),
a child also includes an “eligible foster
child,” defined as an individual who is
placed with the employee by an authorized
placement agency or by judgment, decree,
or other order of any court of competent
jurisdiction.
As amended by the Affordable Care
Act, the exclusion from gross income un-
der § 105(b) applies with respect to an em-
ployee’s child who has not attained age 27
as of the end of the taxable year, includ-
ing a child of the employee who is not the
employee’s dependent within the meaning
of § 152(a). Thus, the age limit, resi-
dency, support, and other tests described in
§152(c)donotapplywithrespecttosuch
a child for purposes of § 105(b).
The exclusion applies only for reim-
bursements for medical care of individu-
als who are not age 27 or older at any
time during the taxable year. For purposes
of §§ 105(b) and 106, the taxable year
is the employee’s taxable year; employ-
ers may assume that an employee’s taxable
year is the calendar year; a child attains
age27onthe27
th
anniversary of the date
the child was born (for example, a child
born on April 10, 1983 attained age 27 on
April 10, 2010); and employers may rely
on the employee’s representation as to the
child’s date of birth.
III. EXCLUSION OF
EMPLOYER-PROVIDED ACCIDENT
OR HEALTH COVERAGE FOR
EMPLOYEE’S CHILD UNDER AGE 27
Section 106 excludes from an em-
ployee’s gross income coverage under
an employer-provided accident or health
plan. The regulations under § 106 provide
that the exclusion applies to employer-pro-
vided coverage for an employee and the
employee’s spouse or dependents (as de-
fined in § 152, determined without regard
to § 152(b)(1), (b)(2) or (d)(1)(B)). See
Prop.Treas.Reg.§1.106–1.Priorto
theAffordableCareAct,theexclusionfor
employer-provided accident or health plan
coverage under § 106 paralleled the exclu-
sion for reimbursements under § 105(b).
There is no indication that Congress in-
tended to provide a broader exclusion in
§ 105(b) than in § 106. Accordingly, IRS
and Treasury intend to amend the regula-
tions under § 106, retroactively to March
30, 2010, to provide that coverage for an
employee’s child under age 27 is excluded
from gross income. Thus, on and after
March 30, 2010, both coverage under an
2010–20 I.R.B.682May 17, 2010

employer-provided accident or health plan
and amounts paid or reimbursed under
such a plan for medical care expenses of an
employee, an employee’s spouse, an em-
ployee’s dependents (as defined in § 152,
determined without regard to § 152(b)(1),
(b)(2) or (d)(1)(B)), or an employee’s child
(as defined in § 152(f)(1)) who has not
attained age 27 as of the end of the em-
ployee’s taxable yearare excluded from
the employee’s gross income.
The following examples illustrate this
rule. In these examples, any reference to
a “dependent” means a dependent as de-
fined in § 152, determined without regard
to § 152(b)(1), (b)(2) or (d)(1)(B). Also, in
these examples, it is assumed that none of
the individuals are disabled.
Example (1). (i) Employer X provides health care
coverage for its employees and their spouses and de-
pendents and for any employee’s child (as defined in
§ 152(f)(1)) who has not attained age 26. For the 2010
taxable year, Employer X provides coverage to Em-
ployee A and to A’s son, C. C will attain age 26 on
November 15, 2010. During the 2010 taxable year,
C is not a full-time student. C has never worked for
Employer X. C is not a dependent of A because prior
to the close of the 2010 taxable year C had attained
age 19 (and was also not a student who had not at-
tained age 24).
(ii) C is a child of A within the meaning of
§ 152(f)(1). Accordingly, and because C will not
attain age 27 during the 2010 taxable year, the health
care coverage and reimbursements provided to him
under the terms of Employer X’s plan are excludible
from A’s gross income under §§ 106 and 105(b)
for the period on and after March 30, 2010 through
November 15, 2010 (when C attains age 26 and loses
coverage under the terms of the plan).
Example (2). (i) Employer Y provides health care
coverage for its employees and their spouses and de-
pendents and for any employee’s child (as defined in
§ 152(f)(1)) who has not attained age 27 as of the end
of the taxable year. For the 2010 taxable year, Em-
ployer Y provides health care coverage to Employee
E and to E’s son, G. G will not attain age 27 until af-
ter the end of the 2010 taxable year. During the 2010
taxable year, G earns $50,000 per year, and does not
live with E. G has never worked for Employer Y. G
is not eligible for health care coverage from his own
employer. G is not a dependent of E because G does
not live with E and E does not provide more than one
half of his support.
(ii) G is a child of E within the meaning of
§ 152(f)(1). Accordingly, and because G will not
attain age 27 during the 2010 taxable year, the health
care coverage and reimbursements for G under Em-
ployer Y’s plan are excludible from E’s gross income
under §§ 106 and 105(b) for the period on and after
March 30, 2010 through the end of the 2010 taxable
year.
Example (3).(i)SamefactsasExample (2),ex-
cept that G’s employer offers health care coverage,
but G has decided not to participate in his employer’s
plan.
(ii) G is a child of E within the meaning of
§ 152(f)(1). Accordingly, and because G will not
attain age 27 during the 2010 taxable year, the health
care coverage and reimbursements for G under Em-
ployer Y’s plan are excludible from E’s gross income
under §§ 106 and 105(b) for the period on and after
March 30, 2010 through the end of the 2010 taxable
year.
Example (4). (i) Same facts asExample (3),ex-
cept that G is married to H, and neither G nor H is a
dependent of E. G and H have decided not to partic-
ipate in the health care coverage offered by G’s em-
ployer, and Employer Y provides health care cover-
agetoGandH.
(ii) G is a child of E within the meaning of
§ 152(f)(1). Accordingly, and because G will not
attain age 27 during the 2010 taxable year, the health
care coverage and reimbursements for G under Em-
ployer Y’s plan are excludible from E’s gross income
under §§ 106 and 105(b) for the period on and after
March 30, 2010 through the end of the 2010 taxable
year. The fair market value of the coverage for H is
includible in E’s gross income for the 2010 taxable
year.
Example (5). (i) Employer Z provides health
care coverage for its employees and their spouses
and dependents. Effective May 1, 2010, Employer
Z amends the health plan to provide coverage for
any employee’s child (as defined in § 152(f)(1))
who has not attained age 26. Employer Z provides
coverage to Employee F and to F’s son, K, for the
2010 taxable year. K will attain age 22 in 2010.
During the 2010 taxable year, F provides more than
one half of K’s support. K lives with F and graduates
from college on May 15, 2010 and thereafter is not a
student. K has never worked for Employer Z. Prior
to K’s graduation from college, K is a dependent of
F. Following graduation from college, K is no longer
a dependent of F.
(ii) For the 2010 taxable year, the health care cov-
erage and reimbursements provided to K under the
terms of Employer Z’s plan are excludible from F’s
gross income under §§ 106 and 105(b). For the period
through May 15, 2010, the reimbursements and cov-
erage are excludible because K was a dependent of F.
For the period on and after March 30, 2010, the cov-
erage is excludible because K is a child of F within the
meaning of § 152(f)(1) and because K will not attain
age 27 during the 2010 taxable year. (Thus, for the
period from March 30 through May 15, 2010, there
are two bases for the exclusion.)
IV. CAFETERIA PLANS, FLEXIBLE
SPENDING ARRANGEMENTS,
ANDHEALTHREIMBURSEMENT
ARRANGEMENTS
Section 125 allows employees to elect
between cash and certain qualified bene-
fits, including accident or health plans (de-
scribed in § 106) and health flexible spend-
ing arrangements (health FSAs) (described
in § 105(b)). Section 125(f) defines “qual-
ified benefit” as any benefit which, with
the application of § 125(a), is not includi-
ble in the gross income of the employee
by reason of an express provision of chap-
ter 1 of the Code (other than §§ 106(b)
(which applies to Archer MSAs), 117, 127,
or 132). Accordingly, the exclusion of
coverage and reimbursements from an em-
ployee’s gross income under §§ 106 and
105(b) for an employee’s child who has not
attained age 27 as of the end of the em-
ployee’s taxable year carries forward au-
tomatically to the definition of qualified
benefits for § 125 cafeteria plans, includ-
ing health FSAs. Thus, a benefit will not
fail to be a qualified benefit under a cafe-
teria plan (including a health FSA) merely
because it provides coverage or reimburse-
ments that are excludible under §§ 106 and
105(b) for a child who has not attained age
27 as of the end of the employee’s taxable
year.
A cafeteria plan may permit an em-
ployee to revoke an election during a pe-
riod of coverage and to make a new elec-
tion only in limited circumstances, such
as a change in status event. See Treas.
Reg. § 1.125–4(c). A change in status
event includes changes in the number of
an employee’s dependents. The regula-
tions under § 1.125–4(c) currently do not
permit election changes for children under
age 27 who are not the employee’s depen-
dents. IRS and Treasury intend to amend
the regulations under§ 1.125–4, effective
retroactively to March 30, 2010, to include
change in status events affecting nonde-
pendent children under age 27, including
becoming newly eligible for coverage or
eligible for coverage beyond the date on
which the child otherwise would have lost
coverage.
In general, a health reimbursement ar-
rangement (HRA) is an arrangement that
ispaidforsolelybyanemployer(andnot
through a § 125 cafeteria plan) which re-
imburses an employeefor medical care ex-
penses up to a maximum dollar amount
for a coverage period. Notice 2002–45,
2002–2 C.B. 93. The same rules that ap-
ply to an employee’s child under age 27 for
purposes of §§ 106 and 105(b) apply to an
HRA.
V. FICA, FUTA, RRTA, AND INCOME
TAX WITHHOLDING TREATMENT
Coverage and reimbursements un-
der an employer-provided accident and
health plan for employees generally and
their dependents (or a class or classes
May 17, 20106832010–20 I.R.B.

of employees and their dependents) are
excluded from wages for Federal In-
surance Contributions Act (FICA) and
FederalUnemploymentTaxAct(FUTA)
tax purposes under §§ 3121(a)(2) and
3306(b)(2), respectively. For these pur-
poses, a child of the employee is a depen-
dent. Treas. Reg. §§ 31.3121(a)(2)–1(c)
and 31.3306(b)(2)–1(c). No age limit,
residency, support, or other test applies
for these purposes. Thus, coverage and
reimbursements under a plan for employ-
ees and their dependents that are provided
for an employee’s child under age 27 are
not wages for FICA or FUTA purposes.
For this purpose, child has the same mean-
ingasin§152(f)(1),asdiscussedinthe
first paragraph in Section II of this notice.
A similar exclusion applies for Railroad
Retirement Tax Act (RRTA) tax purposes
under § 3231(e)(1)(i) and Treas. Reg.
§ 31.3231(e)–1(a)(1).
Such coverage and reimbursements are
also exempt from income tax withholding.
See Rev. Rul. 56–632, 1956–2 C.B. 101.
VI. VEBAS, SECTION 401(h)
ACCOUNTS, AND SECTION 162(l)
DEDUCTIONS
A VEBA is a tax-exempt entity de-
scribed in § 501(c)(9) providing for the
payment of life, sick, accident, or other
benefits to members of the VEBA or their
dependents or designated beneficiaries.
The regulations provide that, for purposes
of § 501(c)(9), “dependent” means the
member’s spouse; any child of the member
or the member’s spouse who is a minor or a
student (within the meaning of § 151(e)(4)
(now § 152(f)(2)); any other minor child
residing with the member; and any other
individual who an association, relying on
information furnished to it by a member,
in good faith believes is a person described
in § 152(a). Treas. Reg. § 1.501(c)(9)–3.
As amended by the Affordable Care Act,
§ 501(c)(9) provides that, for purposes of
providing for the payment of sick and ac-
cident benefits to members of the VEBA
and their dependents, the term dependent
includes any individual who is a member’s
child (as defined in § 152(f)(1)) and who
has not attained age 27 as of the end of the
calendar year.
Section 401(h) provides that a pension
or annuity plan can establish and main-
tain a separate account to provide for the
payment of benefits for sickness, accident,
hospitalization, and medical expenses of
retired employees, their spouses and their
dependents if certain enumerated condi-
tions are met (“401(h) Account”). The
regulations provide that, for purposes of
§ 401(h) and § 1.401–14, the term “de-
pendent” shall have the same meaning as
that assigned to it by § 152. Treas. Reg.
§ 1.401–14(b)(4)(i). As amended by the
Affordable Care Act, § 401(h) provides
that the term dependent includes any in-
dividual who is a retired employee’s child
(within the meaning of § 152(f)(1)) and
who has not attained age 27 as of the end
of the calendar year.
Section 162(l) generally allows a
self-employed individual to deduct,
in computing adjusted gross income,
amounts paid during the taxable year for
insurance that constitutes medical care for
the taxpayer, his or her spouse, and depen-
dents, if certain requirements are satisfied.
As amended by the Affordable Care Act,
§ 162(l) covers medical insurance for any
child (within the meaning of § 152(f)(1))
who has not attained age 27 as of the end
of the taxable year.
VII. TRANSITION RULE FOR
CAFETERIA PLAN AMENDMENTS
Cafeteria plans may need to be
amended to include employees’ chil-
dren who have not attained age 27 as
of the end of the taxable year. Pursuant
to § 1.125–1(c) of the proposed regula-
tions, cafeteria plan amendments may be
effective only prospectively. Notwith-
standing this general rule, as of March 30,
2010, employers may permit employees
to immediately make pre-tax salary reduc-
tion contributions for accident or health
benefits under a cafeteria plan (includ-
ing a health FSA) for children under age
27, even if the cafeteria plan has not yet
been amended to cover these individu-
als. However, a retroactive amendment
to a cafeteria plan to cover children under
age 27 must be made no later than De-
cember 31, 2010, and must be effective
retroactively to the first date in 2010 when
employees are permitted to make pre-tax
salary reduction contributions to cover
children under age 27 (but in no event
before March 30, 2010).
VIII. EFFECT ON OTHER
DOCUMENTS
IRS and Treasury intend to amend
the regulations at §§ 1.105–1, 1.105–2,
1.106–1, 1.125–1, 1.125–4, 1.125–5, and
1.401–14 to include children (as defined in
§ 152(f)(1)) who are under age 27. Addi-
tionally, IRS and Treasury intend to amend
the regulations at § 1.501(c)(9)–3 to in-
clude children (as defined in § 152(f)(1))
who are under age 27, with respect to sick
and accident benefits. Taxpayers may rely
on this notice pending the issuance of the
amended regulations.
IX. EFFECTIVE DATES
Thechangesrelatingto§§105(b),106,
501(c)(9), 401(h) and 162(l) are effective
on March 30, 2010.
DRAFTING INFORMATION
The principal author of this notice is
Karen Levin of the Office of Division
Counsel/Associate Chief Counsel (Tax
Exempt and Government Entities). For
further information regarding this notice,
contact Ms. Levin at (202) 622–6080 (not
a toll-free call).
2010–20 I.R.B.684May 17, 2010

Part IV. Items o
fGeneralInterest
Correction to Announcement
Regarding Implementation
of FATCA and Request for
Comments
Announcement 2010–34
This document contains a correction to
Announcement 2010–22, 2010–16 I.R.B.
602. The Federal e-Rulemaking Portal
was incorrect.
The Announcement incorrectly stated:
“Submissions may be hand-deliv-
ered Monday through Friday between
the hours of 8 a.m. and 4 p.m. to:
CC:PA:LPD:PR (NOT–112379–10),
Courier’s Desk, Internal Revenue
Service, 1111 Constitution Avenue,
NW, Washington, DC 20224 or sent
electronically via the Federal eRule-
making Portal atwww.regulations.gov
(NOT–112379–10).”
The Announcement should have stated:
“Submissions may be hand-deliv-
ered Monday through Friday between
the hours of 8 a.m. and 4 p.m. to:
CC:PA:LPD:PR (NOT–112379–10),
Courier’s Desk, Internal Revenue Ser-
vice, 1111 Constitution Avenue, NW,
Washington, DC 20224 or sent elec-
tronically via the Federal eRulemaking
Portal atNotice.Comments@irscoun-
sel.treas.gov(NOT–112379–10).”
For further information regard-
ing this announcement, contact
Kathryn T. Holman at (202) 622–8556
(not a toll-free call).
Deletions From Cumulative
List of Organizations
Contributions to Which
are Deductible Under Section
170 of the Code
Announcement 2010–35
The Internal Revenue Service has re-
voked its determination that the organi-
zations listed below qualify as organiza-
tions described in sections 501(c)(3) and
170(c)(2) of the Internal Revenue Code of
1986.
Generally, the Service will not disallow
deductions for contributions made to a
listed organization on or before the date
of announcement in the Internal Revenue
Bulletin that an organization no longer
qualifies. However, the Service is not
precluded from disallowing a deduction
for any contributions made after an or-
ganization ceases to qualify under section
170(c)(2) if the organization has not timely
filed a suit for declaratory judgment under
section 7428 and if the contributor (1) had
knowledge of the revocation of the ruling
or determination letter, (2) was aware that
such revocation was imminent, or (3) was
in part responsible for or was aware of the
activities or omissions of the organization
that brought about this revocation.
If on the other hand a suit for declara-
tory judgment has been timely filed, con-
tributions from individuals and organiza-
tions described in section 170(c)(2) that
are otherwise allowable will continue to
be deductible. Protection under section
7428(c) would begin on May 17, 2010 and
would end on the date the court first deter-
mines that the organization is not described
in section 170(c)(2) as more particularly
set forth in section 7428(c)(1). For indi-
vidual contributors, the maximum deduc-
tion protected is $1,000, with a husband
and wife treated as one contributor. This
benefit is not extended to any individual, in
wholeorinpart,fortheactsoromissions
of the organization that were the basis for
revocation.
Ann Arbor Spark
Ann Arbor, MI
Indigenous Nations Federal Charter
Association Buffalo Reserve Charitable
Trust
Norman, OK
Announcement of Disciplinary Sanctions From the Office
of Professional Responsibility
Announcement 2010-37
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.
May 17, 20106852010–20 I.R.B.

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.
City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Arizona
MesaHillerman, Marjorie J. Enrolled AgentDisbarred by ALJ default
decision for violation of
§ 10.51 (willful failure to
timely file several Federal
income tax returns)
Indefinite from
January 26, 2010
California
Hacienda HeightsAbrams, Gary R.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
April 14, 2010
2010–20 I.R.B.686May 17, 2010

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
California (Continued)
Elk GroveAppelblatt, Gary M.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license and convictions
under state law, sexual
battery, and attempted
sexual battery)
Indefinite from
March 15, 2010
Gong, Gloria M.,
See Texas
Aliso ViejoGrant, Gary D.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
March 9, 2010
Yorba LindaJohnston, Dennis H.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
April 14, 2010
TarzanaKamarian, GarabedAttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
March 9, 2010
Studio CityKrell, StevenCPASuspended by decision
in expedited proceeding
under § 10.82 (revocation
of CPA license)
Indefinite from
April 5, 2010
ArcadiaSun, Alexander F.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license and conviction
under state law, insurance
fraud)
Indefinite from
March 9, 2010
Florida
Bonita SpringsBryan, Clyde C.Enrolled AgentSuspended by decision
in expedited proceeding
under § 10.82 (conviction
under 18 U.S.C. § 1512,
destroying documents to
impair the integrity and
availability for use in an
official proceeding, and
18 U.S.C. § 1519, altering
documents to impede,
obstruct, and influence an
agency of the U.S.)
Indefinite from
March 3, 2010
May 17, 20106872010–20 I.R.B.

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Maryland
BaltimoreAlivizatos, Constandin AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
March 12, 2010
BaltimoreKwarteng, Charles O.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
March 12, 2010
Missouri
Kansas CityDay, Neysa L.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
March 12, 2010
New York
New YorkHolzer, Eric A.AttorneySuspended by default
decision in expedited
proceeding under
§ 10.82 (conviction
under 18 U.S.C. § 371,
conspiracy to commit
securities fraud, 15 U.S.C.
§§ 78j(b), 78ff, securities
fraud; and stricken from
attorney rolls)
Indefinite from
March 12, 2010
RidgewoodIgnacio, David G.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
March 12, 2010
BuffaloParker, David E.AttorneySuspended by default
decision in expedited
proceeding under
§ 10.82 (conviction
under 18 U.S.C. § 371,
conspiracy to defraud the
U.S.)
Indefinite from
March 12, 2010
East BerneSpargo, Thomas J.AttorneySuspended by default
decision in expedited
proceeding under
§ 10.82 (conviction under
18 U.S.C. §§ 1951 and 2,
attempted extortion, and
18 U.S.C. §§ 666 and 2,
attempted bribery)
Indefinite from
March 12, 2010
2010–20 I.R.B.688May 17, 2010

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
North Carolina
ConcordGipson, Frederick M.CPASuspended by decision
in expedited proceeding
under § 10.82 (revocation
of CPA license)
Indefinite from
April 14, 2010
WilmingtonMitchell, Hilton S.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
March 12, 2010
Ohio
MentorZgoznik, AntonCPASuspended by default
decision in expedited
proceeding under
§ 10.82 (conviction
under18U.S.C.§§371
and 1349, conspiracy
to commit mail fraud,
18 U.S.C. §§ 1341 and
1346,mailfraud,18
U.S.C. § 371, conspiracy
to defraud the IRS,
26 U.S.C. § 7712(a),
corruptly endeavoring
to obstruct and impede,
and 26 U.S.C. § 7206(2),
aiding and assisting
preparation of false
document)
Indefinite from
April 5, 2010
Pennsylvania
WrightsvilleButler, Michael S.AttorneySuspended by decision
in expedited proceeding
under § 10.82 (suspension
of attorney license)
Indefinite from
April 5, 2010
ErieDeSantis, Joseph J.AttorneySuspended by decision
in expedited proceeding
under § 10.82 (suspension
of attorney license)
Indefinite from
April 5, 2010
Bryn MawrJames, Janeane M.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
April 5, 2010
May 17, 20106892010–20 I.R.B.

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Tennessee
SpringfieldSingleton, Jamie E.CPASuspended by consent
for admitted violations of
§ 10.51 (failure to timely
file Federal individual
income tax return,
failure to file employer’s
quarterly Federal tax
return for number of
quarters, failure to file
U.S. corporation income
tax returns, and failure
to file employer’s annual
federal unemployment tax
return)
Indefinite from
March 16, 2010,
butatleast48
months
Texas
RichmondGong, Gloria M.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment in
California)
Indefinite from
April 14, 2010
2010–20 I.R.B.690May 17, 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.
May 17, 2010i2010–20 I.R.B.

Numerical Finding List
1
Bulletins 2010–1 through 2010–20
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
2010-14, 2010-11 I.R.B.449
2010-15, 2010-10 I.R.B.438
2010-16, 2010-11 I.R.B.450
2010-17, 2010-13 I.R.B.515
2010-18, 2010-12 I.R.B.460
2010-19, 2010-14 I.R.B.529
2010-20, 2010-15 I.R.B.551
2010-21, 2010-15 I.R.B.551
2010-22, 2010-16 I.R.B.602
2010-23, 2010-16 I.R.B.602
2010-24, 2010-15 I.R.B.587
2010-25, 2010-15 I.R.B.588
2010-26, 2010-16 I.R.B.604
2010-27, 2010-18 I.R.B.657
2010-28, 2010-17 I.R.B.616
2010-29, 2010-17 I.R.B.616
2010-30, 2010-19 I.R.B.668
2010-31, 2010-19 I.R.B.681
2010-32, 2010-19 I.R.B.681
2010-33, 2010-18 I.R.B.658
2010-34, 2010-20 I.R.B.685
2010-35, 2010-20 I.R.B.685
2010-37, 2010-20 I.R.B.685
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
Notices— Continued:
2010-14, 2010-5 I.R.B.344
2010-15, 2010-6 I.R.B.390
2010-16, 2010-6 I.R.B.396
2010-17, 2010-14 I.R.B.519
2010-18, 2010-14 I.R.B.525
2010-19, 2010-7 I.R.B.404
2010-20, 2010-8 I.R.B.422
2010-21, 2010-12 I.R.B.451
2010-22, 2010-10 I.R.B.435
2010-23, 2010-11 I.R.B.441
2010-24, 2010-12 I.R.B.452
2010-25, 2010-14 I.R.B.527
2010-26, 2010-14 I.R.B.527
2010-27, 2010-15 I.R.B.531
2010-28, 2010-15 I.R.B.541
2010-29, 2010-15 I.R.B.547
2010-30, 2010-18 I.R.B.650
2010-31, 2010-16 I.R.B.594
2010-32, 2010-16 I.R.B.594
2010-33, 2010-17 I.R.B.609
2010-34, 2010-17 I.R.B.612
2010-35, 2010-19 I.R.B.660
2010-36, 2010-17 I.R.B.612
2010-37, 2010-18 I.R.B.654
2010-38, 2010-20 I.R.B.682
Proposed Regulations:
REG-132232-08, 2010-6 I.R.B.401
REG-134235-08, 2010-16 I.R.B.596
REG-137036-08, 2010-6 I.R.B.398
REG-101896-09, 2010-5 I.R.B.347
REG-117501-09, 2010-11 I.R.B.442
REG-131028-09, 2010-4 I.R.B.332
REG-148681-09, 2010-11 I.R.B.443
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
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
2010-14, 2010-12 I.R.B.456
2010-15, 2010-7 I.R.B.404
2010-16, 2010-19 I.R.B.664
2010-17, 2010-8 I.R.B.425
2010-18, 2010-9 I.R.B.427
2010-19, 2010-13 I.R.B.469
Revenue Procedures— Continued:
2010-20, 2010-14 I.R.B.528
2010-21, 2010-13 I.R.B.473
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
2010-9, 2010-13 I.R.B.461
2010-10, 2010-13 I.R.B.461
2010-11, 2010-14 I.R.B.516
2010-12, 2010-18 I.R.B.617
Tax Conventions:
2010-2, 2010-2 I.R.B.271
2010-26, 2010-16 I.R.B.604
2010-27, 2010-18 I.R.B.657
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
9479, 2010-18 I.R.B.618
9480, 2010-11 I.R.B.439
9481, 2010-17 I.R.B.605
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.
2010–20 I.R.B.iiMay 17, 2010

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2010–1 through 2010–20
Announcements:
2009-23
Corrected by
Ann. 2010-29, 2010-17 I.R.B.616
2009-51
Supplemented and superseded by
Ann. 2010-16, 2010-11 I.R.B.450
2010-4
Corrected by
Ann. 2010-10, 2010-7 I.R.B.410
2010-22
Corrected by
Ann. 2010-34, 2010-20 I.R.B.685
Notices:
2005-88
Superseded by
Notice 2010-13, 2010-4 I.R.B.327
2006-87
Superseded by
Notice 2010-27, 2010-15 I.R.B.531
2007-25
Superseded by
Notice 2010-27, 2010-15 I.R.B.531
2007-77
Superseded by
Notice 2010-27, 2010-15 I.R.B.531
2008-14
Modified and superseded by
Notice 2010-33, 2010-17 I.R.B.609
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
2008-107
Superseded by
Notice 2010-27, 2010-15 I.R.B.531
2008-113
Modified by
Notice 2010-6, 2010-3 I.R.B.275
Notices— Continued:
2008-115
Modified by
Notice 2010-6, 2010-3 I.R.B.275
2008-116
Modified and superseded by
Notice 2010-32, 2010-16 I.R.B.594
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
2009-35
Supplemented by
Notice 2010-17, 2010-14 I.R.B.519
2009-38
Amplified and superseded by
Notice 2010-2, 2010-2 I.R.B.251
2009-62
Modified and supplemented by
Notice 2010-23, 2010-11 I.R.B.441
Proposed Regulations:
REG-127270-06
Hearing scheduled by
Ann. 2010-6, 2010-6 I.R.B.402
REG-134235-08
Hearing scheduled by
Ann. 2010-33, 2010-18 I.R.B.658
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
2001-18
Superseded by
Rev. Proc. 2010-16, 2010-19 I.R.B.664
2008-14
Updated by
Rev. Proc. 2010-15, 2010-7 I.R.B.404
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
Revenue Procedures— Continued:
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
2009-17
Superseded by
Rev. Proc. 2010-21, 2010-13 I.R.B.473
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
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
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.
May 17, 2010iii2010–20 I.R.B.

Treasury Decisions:
9424
Corrected by
Ann. 2010-18, 2010-12 I.R.B.460
9443
Corrected by
Ann. 2010-8, 2010-7 I.R.B.408
9458
Corrected by
Ann. 2010-7, 2010-6 I.R.B.403
2010–20 I.R.B.ivMay 17, 2010

May 17, 20102010–20 I.R.B.

2010–20 I.R.B.May 17, 2010

May 17, 20102010–20 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.
CUMULATIVE BULLETINS
The contents of this weekly Bulletin are consolidated semiannually into a permanent, indexed, Cumulative Bulletin. These are
sold on a single copy basis andare notincluded as part of the subscription to the Internal Revenue Bulletin. Subscribers to the weekly
Bulletin are notified when copies of the Cumulative Bulletin are available. Certain issues of Cumulative Bulletins are out of print
and are not available. Persons desiring available Cumulative Bulletins, which are listed on the reverse, may purchase them from the
Superintendent of Documents.
ACCESS THE INTERNAL REVENUE BULLETIN ON THE INTERNET
You may view the Internal Revenue Bulletin on the Internet at www.irs.gov. Select Businesses. Under Businesses Topics, select
More Topics. Then select Internal Revenue Bulletins.
INTERNAL REVENUE BULLETINS ON CD-ROM
Internal Revenue Bulletins are available annually as part ofPublication 1796 (Tax Products CD-ROM). The CD-ROM can be
purchased from National Technical Information Service (NTIS) on the Internet at www.irs.gov/cdorders (discount for online orders)
or by calling 1-877-233-6767. The first release is available in mid-December and the final release is available in late January.
HOW TO ORDER
Check the publications and/or subscription(s) desired on the reverse, complete the order blank, enclose the proper remittance,
detach entire page, and mail to the Superintendent of Documents, P.O. Box 371954, Pittsburgh PA, 15250–7954. Please allow two to
six weeks, plus mailing time, for delivery.
WE WELCOME COMMENTS ABOUT THE INTERNAL
REVENUE BULLETIN
If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we
would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page (www.irs.gov)
or write to the IRS Bulletin Unit, SE:W:CAR:MP:T:T:SP, Washington, DC 20224.
Internal Revenue Service
W
ashington,DC20224
Official Business
Penalty for Private Use, $300