Internal Revenue Bulletin 2010-25 (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
0-25
June 21, 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.
SPECIAL ANNOUNCEMENT
Announcement 2010–41, page 767.
The IRS is announcing a change in procedures for individual
payees to follow to obtain validation of social security numbers
(SSNs) from the Social Security Administration (SSA) to prevent
or stop backup withholding under section 3406 of the Code
following receipt of a second “B notice” from a payor.
INCOME TAX
REG–106750–10, page 765.
Proposed regulations under section 1001 of the Code clarify
the extent to which the deterioration in an issuer’s financial
condition is taken into account to determine whether a modified
debt instrument will be recharacterized as an instrument that
is not debt. A public hearing is scheduled for September 8,
2010.
Rev. Proc. 2010–24, page 764.
Changes to cost-of-living adjustments for 2010.This pro-
cedure modifies the inflation adjusted amounts in Rev. Proc.
2009–50, 2009–45 I.R.B. 617, that apply to taxpayers who
elect to expense certain depreciable assets under section 179
of the Code. The modification reflects statutory amendments
enacted subsequent to the publication of Rev. Proc. 2009–50
made by the Hiring Incentives to Restore Employment Act of
2010 (the HIRE Act). Section 3.20 of Rev. Proc. 2009–50
modified and superseded.
EXEMPT ORGANIZATIONS
Announcement 2010–42, page 768.
The IRS has revoked its determination that Christian Credit
Counseling Center of San Antonio, TX; Gullahorn Family Sup-
porting Organization of Naples, FL; and Visual Credit Counsel-
ing, Inc., of Tucson, AZ, qualify as organizations described in
sections 501(c)(3) and 170(c)(2) of the Code.
ADMINISTRATIVE
Announcement 2010–41, page 767.
The IRS is announcing a change in procedures for individual
payees to follow to obtain validation of social security numbers
(SSNs) from the Social Security Administration (SSA) to prevent
or stop backup withholding under section 3406 of the Code
following receipt of a second “B notice” from a payor.
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.
June 21, 20102010–25 I.R.B.

Part III. Administrative, Procedural, and Miscellaneous
26 CFR 601.602: Tax forms and instructions.
(AlsoPartI,§179.)
Rev. Proc. 2010–24
SECTION 1. PURPOSE
This revenue procedure modifies the in-
flation adjusted amounts in Rev. Proc.
2009–50, 2009–45 I.R.B. 617, that apply
to taxpayers who elect to expense certain
depreciable assets under § 179 of the In-
ternal Revenue Code.This modification
reflects statutory changes enacted subse-
quent to the publication of Rev. Proc.
2009–50.
SECTION 2. BACKGROUND
Prior to the enactment of the Hiring
Incentives to Restore Employment Act
of 2010, Pub. L. No.111–147, 124 Stat.
71 (2010) (the HIRE Act), § 179(b)(1)
prescribed a $125,000 limitation (the
$125,000 amount) on the aggregate cost of
§ 179 property that could be treated as an
expense for taxable years beginning after
2006 and before 2011. For those same tax-
able years, § 179(b)(2) provided that the
$125,000 amount is reduced by the amount
by which the cost of § 179 property placed
in service during the taxable year exceeds
$500,000 (the $500,000 amount). Both
the $125,000 amount and the $500,000
amount were adjusted for inflation annu-
ally under § 179(b)(5). For taxable years
beginning in 2010, section 3.20 of Rev.
Proc. 2009–50 provides that the $125,000
amount and the $500,000 amount, adjusted
for inflation, are $134,000 and $530,000,
respectively.
Section 102 of the Economic Stimulus
Act of 2008, Pub. L. No.110–185, 122
Stat. 613 (2008), changed the $125,000
amount and the $500,000 amount to
$250,000 and $800,000, respectively, for
taxable years beginning in 2008 and 2009,
and also provided that these amounts will
not be adjusted for inflation.
Similarly, § 201 of the HIRE Act
changes the $125,000 amount and the
$500,000 amount to $250,000 and
$800,000, respectively, for taxable years
beginning in 2010. Section 201 of the Act
also provides that these amounts will not
be adjusted for inflation for taxable years
beginning in 2010.
SECTION 3. APPLICATION
To reflect the statutory changes made to
§ 179 by § 201 of the HIRE Act, section
3.20 of Rev. Proc. 2009–50 is modified to
read as follows:
.20Election to Expense Certain Depre-
ciable Assets.For taxable years begin-
ning in 2010, under § 179(b)(1) the aggre-
gate cost of any § 179 property a taxpayer
may elect to treat as an expense cannot
exceed $250,000. Under § 179(b)(2), the
$250,000 limitation is reduced (but not be-
low zero) by the amount by which the cost
of § 179 property placed in service during
the 2010 taxable year exceeds $800,000.
SECTION 4. EFFECT ON OTHER
DOCUMENTS
Section 3.20 of Rev. Proc. 2009–50 is
modified and superseded.
SECTION 5. EFFECTIVE DATE
This revenue procedure is effective for
taxable years beginning in 2010.
SECTION 6. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Patrick M. Clinton of the
Office of Associate Chief Counsel (In-
come Tax & Accounting). For further
information regarding this revenue proce-
dure, contact Patrick M. Clinton at (202)
622–4930 (not a toll-free call).
2010–25 I.R.B.764June 21, 2010

Part IV. Items o
fGeneralInterest
Notice of Prop
osed
Rulemaking an
dNoticeof
Public Hearin
g
Modification
sofDebt
Instruments
REG–106750–10
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of proposed rulemaking
and notice of public hearing.
SUMMARY: This document contains pro-
posed regulations relating to the modifica-
tion of debt instruments. The regulations
clarify the extent to which the deterioration
in the financial condition of the issuer is
taken into account to determine whether a
modified debt instrument will be recharac-
terized as an instrument or property right
that is not debt. The regulations provide
needed guidance to issuers and holders of
debt instruments. This document also pro-
vides notice of a public hearing on these
proposed regulations.
DATES: Written or electronic comments
must be received by August 3, 2010.
Outlines of topics to be discussed at the
public hearing scheduled for Wednesday,
September 8, 2010, at 10 a.m. must be
received by Wednesday, August 11, 2010.
ADDRESSES: Send submissions to:
CC:PA:LPD:PR (REG–106750–10), room
5205, Internal Revenue Service, PO Box
7604, Ben Franklin Station, Washing-
ton, DC 20044. Submissions may be
hand-delivered Monday through Friday
between the hours of 8 a.m. and 4 p.m.
to CC:PA:LPD:PR (REG–106750–10),
Courier’s Desk, Internal Revenue Ser-
vice, 1111 Constitution Avenue, N.W.,
Washington, DC, or sent electroni-
cally, via the Federal eRulemaking Por-
tal atwww.regulations.gov(IRS and
REG–106750–10).
FO
R FURTHER INFORMATION
CO
NTACT: Concerning the pro-
po
sed regulations, Diana Imholtz,
at
(202) 622–3930; concerning sub-
mi
ssion of comments, the hearing,
and/or to be pl
aced on the build-
ing access lis
t to attend the hearing,
Richard.A.Hu
rst@irscounsel.treas.gov,at
(202) 622–718
0 (not toll-free numbers).
SUPPLEMENTARY INFORMATION:
Background
Section 1.100
1–3 provides rules for
determining
when a modification of a
debt instrum
ent results in an exchange
for purposes
of §1.1001–1(a). In gen-
eral, §1.100
1–3 defines a modification
and provide
s that a modification that is
significan
t results in a deemed exchange
of the origi
nal debt instrument for a mod-
ified debt i
nstrument. Section 1.1001–3
also addres
ses alterations to the terms of
adebtinst
rument that result in a modi-
fied instr
ument that is not debt. Section
1.1001–3(
c)(2)(ii) generally provides that
a modifica
tion to a debt instrument occurs
if an alte
ration changes the instrument to
an instru
ment or property right that is not
debt for f
ederal income tax purposes, even
if the alt
eration occurs by operation of the
original
terms of the debt instrument. Sec-
tion 1.1
001–3(e)(5)(i) generally provides
that a mo
dification of a debt instrument
that res
ults in an instrument or property
right th
atisnotdebtforfederalincome
tax purp
oses is a significant modification.
For pur
poses of making the determination
prescr
ibed by §1.1001–3(e)(5)(i), the reg-
ulatio
ns state that any deterioration in the
financ
ial condition of the issuer between
the iss
ue date of the unmodified debt in-
strum
ent and the date of modification (as
it rel
ates to the issuer’s obligation to re-
pay th
e debt instrument) is not taken into
accou
nt, unless there is a substitution of a
new ob
ligor or the addition or deletion of
aco-
obligor.
In res
ponse to the proposed regulations
publ
ished on December 2, 1992 (FI-31-92,
1992
-2 C.B. 633 [57 FR 57034]), taxpay-
ers w
ere concerned that taking into ac-
coun
t the creditworthiness of a financially
trou
bled issuer when a debt instrument
is mo
dified would impose a significant
bar
rier to restructuring distressed debt in-
str
uments. The rule in §1.1001–3(e)(5)(i)
to d
isregard the financial condition of
the
issuer was intended to address this
con
cern. The preamble to the existing
regulations p
ublished on September 24,
1996 (T.D. 867
5, 1996–2 C.B. 5 [61 FR
32926]) expla
ins that “for purposes of this
regulation, u
nless there is a substitution
of a new obligo
r, any deterioration in
the financia
l condition of the issuer is
not consider
ed in determining whether
the modified
instrument is properly
characteriz
ed as debt.”
The language
in the preamble to the ex-
isting regul
ations suggests that forallpur-
poses of §1.
1001–3 the financial deteriora-
tion of the i
ssuer is generally not taken into
account. Is
suers and holders, however, are
concerned t
hat, as the existing regulations
are curren
tly drafted, a decline in the cred-
itworthin
ess of the issuer, under certain cir-
cumstance
s, may be taken into account un-
der §1.100
1–3. The uncertainty about the
proper int
erpretation of the existing regu-
lations h
as led taxpayers to request clari-
fication
on the circumstances in which the
credit qu
ality of the issuer should be con-
sidered i
n determining the nature of the
instrum
ent resulting from an alteration or
modific
ation of a debt instrument. Ac-
cording
ly, the IRS and the Treasury De-
partmen
t believe it is appropriate to pro-
pose ame
ndments to §1.1001–3 to clarify
this is
sue.
Explan
ation of Provisions
In gene
ral, the proposed regulations re-
quire a
n analysis of all of the factors rele-
vant to
a debt determination of the modi-
fied in
strument at the time of an alteration
or modi
fication. However, in making this
deter
mination for purposes of the regula-
tion,
any deterioration in the financial con-
ditio
n of the issuer between the issue date
of the
debt instrument and the date of the
alter
ation or modification (as it relates to
the i
ssuer’s ability to repay the debt in-
stru
ment) is not taken into account, unless
ther
e is a substitution of a new obligor or
the a
ddition or deletion of a co-obligor.
As no
ted in this preamble, the proposed
regu
lations clarify that any deterioration
in th
e financial condition of the issuer is
gene
rally not taken into account to deter-
min
e if the modified instrument is debt.
For
example, under the proposed regula-
tio
ns, any decrease in the fair market value
of a
debt instrument (whether or not pub-
lic
ly traded) between the issue date of the
June 21, 20107652010–25 I.R.B.

debt instrument and the date of the alter-
ation or modification is not taken into ac-
count to the extent that the decrease in fair
market value is attributable to the deterio-
ration in the financial condition of the is-
suer and not to a modification of the terms
of the instrument. Consistent with this rule
in the proposed regulations, if a debt in-
strument is significantly modified and the
issue price of the modified debt instru-
ment is determined under §1.1273–2(b) or
(c) (relating to a fair market value issue
price for publicly traded debt), then any in-
creased yield on the modified debt instru-
ment attributable to this issue price gener-
ally is not taken into account to determine
whether the modified debt instrument is
debt or some other property right for fed-
eral income tax purposes. However, any
portion of the increased yield that is not at-
tributable to a deterioration in the financial
condition of the issuer, such as a change in
market interest rates, is taken into account.
Proposed Effective Date
The regulations, as proposed, apply to
alterations of the terms of a debt instru-
ment on or after the date of publication of
the Treasury decision adopting these rules
as final regulation in theFederal Register.
A taxpayer, however, may rely on these
amendments for alterations of the terms
of a debt instrument occurring before that
date.
Special Analyses
It has been determined that this no-
tice of proposed rulemaking is not a
significant regulatory action as defined
in Executive Order12866. Therefore,
a regulatory assessment is not required.
It also has been determined that section
553(b) of the Administrative Procedure
Act (5 U.S.C. chapter 5) does not apply
to these regulations, and because the
regulation does not impose a collection
of information on small entities, the
Regulatory Flexibility Act (5 U.S.C.
chapter 6) does not apply. Pursuant to
section 7805(f) of the Internal Revenue
Code, this notice of proposed rulemaking
has been submitted to the Chief Counsel
for Advocacy of the Small Business
Administration for comment on its impact
on small business.
Comments and Public Hearing
Before these proposed regulations are
adopted as final regulations, consideration
will be given to any written comments
(a signed original and eight (8) copies)
or electronic comments that are submitted
timely to the IRS. The IRS and the Trea-
sury Department request comments on the
clarity of the proposed rules and how they
can be made easier to understand. All
comments will be available for public in-
spection and copying.
A public hearing has been scheduled for
Wednesday, September 8, 2010, beginning
at 10 a.m. in Auditorium, Internal Rev-
enue Building, 1111 Constitution Avenue,
NW, Washington, DC. Due to building se-
curity procedures, visitors must enter at the
Constitution Avenueentrance. In addition,
all visitors must present photo identifica-
tion to enter the building. Because of ac-
cess restrictions, visitors will not be ad-
mitted beyond the immediate entrance area
more than 30 minutes before the hearing
starts. For information about having your
name placed on the building access list to
attend the hearing, see the “FOR FUR-
THER INFORMATION CONTACT” sec-
tion of this preamble.
The rules of 26 CFR 601.601(a)(3) ap-
ply to the hearing. Persons who wish to
present oral comments at the hearing must
submit electronic or written comments and
an outline of the topics to be discussed
and the time to be devoted to each topic
(signed original and eight (8) copies) by
Wednesday, August 11, 2010. A period of
10 minutes will be allotted to each person
for making comments. An agenda show-
ing the scheduling of the speakers will be
prepared after the deadline for receiving
outlines has passed. Copies of the agenda
will be available free of charge at the hear-
ing.
Drafting Information
The principal author of these regula-
tions is Diana Imholtz, Office of Asso-
ciate Chief Counsel (Financial Institutions
& Products). However, other personnel
from the IRS and the Treasury Department
participated in their development.
*****
Proposed Amendments to the
Regulations
Accordingly, 26 CFR part 1 is proposed
to be amended as follows:
PART 1— INCOME TAXES
Paragraph 1. The authority citation for
part 1 continues to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 1.1001–3 is amended by
revising paragraphs (c)(2)(ii), (e)(5)(i) and
(h) and adding paragraph (f)(7) to read as
follows:
§1.1001–3 Modifications of debt
instruments.
*****
(c) * * *
(2) * * *
(ii)Property that is not debt.Analter-
ation that results in an instrument or prop-
erty right that is not debt for federal income
tax purposes is a modification unless the
alteration occurs pursuant to a holder’s op-
tion under the terms of the instrument to
convert the instrument into equity of the is-
suer (notwithstandingparagraph (c)(2)(iii)
of this section). The rules of paragraph
(f)(7) of this section apply to determine
whether an alteration or modification re-
sults in an instrument or property right that
is not debt.
*****
(e) * * *
(5)Changes in the nature of a debt in-
strument—(i)Property that is not debt.A
modification of a debt instrument that re-
sults in an instrument or property right that
is not debt for federal income tax purposes
is a significant modification. The rules of
paragraph (f)(7) of this section apply to de-
termine whether a modification results in
an instrument or property right that is not
debt.
*****
(f) * * *
(7)Rules for determining whether an
alteration or modification results in an
instrument or property right that is not
debt—(i)In general. Except as provided
in paragraph (f)(7)(ii) of this section, the
determination of whether an instrument re-
sulting from an alteration or modification
of a debt instrument will be recharacter-
ized as an instrument or property right that
2010–25 I.R.B.766June 21, 2010

is not debt for federal income tax purposes
shall take into account all of the factors
relevant to such a determination.
(ii)Financial condition of the
obligor—(A)Deterioration in financial
condition of the obligor generally disre-
garded. Except as provided in paragraph
(f)(7)(ii)(B) of this section, in making a
determination as to whether an instrument
resulting from an alteration or modifica-
tion of a debt instrument will be recharac-
terized as an instrument or property right
that is not debt under this section, any de-
terioration in the financial condition of the
obligor between the issue date of the debt
instrument and the date of the alteration or
modification (as it relates to the obligor’s
ability to repay the debt instrument) is
not taken into account. For example, any
decrease in the fair market value of a debt
instrument (whether or not the debt instru-
ment is publicly traded) between the issue
date of the debt instrument and the date of
the alteration or modification is not taken
into account to the extent that the decrease
in fair market value is attributable to the
deterioration in the financial condition of
the obligor and not to a modification of
thetermsoftheinstrument.
(B)Substitution of a new obligor; ad-
dition or deletion of co-obligor.Ifthereis
a substitution of a new obligor or the ad-
dition or deletion of a co-obligor, the rules
in paragraph (f)(7)(ii)(A) of this section do
not apply.
*****
(h)Effective/applicability date—(1)In
general. Except as otherwise provided in
paragraph (h)(2) of this section, this sec-
tion applies to alterations of the terms of a
debt instrument on or after September 24,
1996. Taxpayers, however, may rely on
this section for alterations of the terms of
a debt instrument after December 2, 1992,
and before September 24, 1996.
(2)Exception. Paragraph (f)(7) of this
section applies to an alteration of the terms
of a debt instrument on or after the date of
publication of the Treasury decision adopt-
ing these rules as final regulation in the
Federal Register.
A taxpayer, however, may rely on para-
graph (f)(7) of this section for alterations
of the terms of a debt instrument occurring
before that date.
Steven T. Miller,
Deputy Commissioner for
Services and Enforcement.
(Filed by the Office of the Federal Register on June 3, 2010,
8:45 a.m., and published in the issue of the Federal Register
for June 4, 2010, 73 F.R. 31736)
New Backup Withholding
Procedures: Social Security
Number Validation following
Receipt of Second B Notice
Announcement 2010–41
PURPOSE
The Internal Revenue Service (“IRS”)
is announcing a change in procedures
for individual payees to follow to ob-
tain validation of social security numbers
(“SSNs”) from the Social Security Ad-
ministration (“SSA”) to prevent or stop
backup withholding under section 3406 of
the Internal Revenue Code following re-
ceipt of a second “B notice” from a payor.
BACKGROUND
Pursuant to section 3406 and the reg-
ulations thereunder, a payor (such as a
bank) must send certain notices under sec-
tion 3406(a)(1)(B) (“B notices”) to a payee
after being notified by the IRS or a bro-
ker that the payee has provided an incor-
rect name and taxpayer identification num-
ber (“TIN”) combination with respect to
an account. Following the first notifica-
tion from the IRS or broker, the payor must
send a first B notice to a payee direct-
ing the payee to certify the TIN on Form
W–9 in order to stop or prevent backup
withholding on reportable payments by the
payor. If the payor receives a second no-
tice of incorrect TIN from the IRS or bro-
ker within three years, the payor must send
a second B notice to the payee requiring
the payee to provide TIN validation. After
the second B notice, the payor cannot ac-
cept a TIN certification on Form W–9 but
must receive validation of the payee’s TIN
from the SSA or the IRS. Absent receipt of
proper validation, the payor must backup
withhold from future reportable payments
it makes to the payee.
The rules concerning the form, content
and manner of delivery of B notices are set
forth in Rev. Proc. 93–37, 1993–2 C.B.
477. That revenue procedure sets forth
specific instructions regarding TIN valida-
tion, which must be included in the second
B notice sent to payees. Pursuant to the
instructions in Rev. Proc. 93–37, a payee
who needs to validate an SSN must contact
the local SSA office to inquire about SSN
validation, provide a copy of the B no-
tice to SSA, and request and authorize SSA
to send Form SSA–7028,Notice to Third
Party of Social Security Number Assign-
ment, to the payor to validate the payee’s
SSN.
Effective January 1, 2010, SSA discon-
tinued the availability of Form SSA–7028
for purposes of verifying SSNs to avoid
backup withholding. This announcement
updates the instructions for TIN validation
given that Form SSA–7028 is no longer
available.
INTERIM PROCEDURES
To obtain validation of the payee’s SSN
from the SSA for purposes of respond-
ing to a second B notice, each individual
payee should now contact the local SSA
office and request a Social Security Num-
ber Printout. The Social Security Number
Printout will validate the SSN of the indi-
vidual and will serve as acceptable valida-
tion of the individual’s TIN for purposes of
the requirements of section 3406. An in-
dividual may request one free copy of the
Social Security Number Printout, which
will verify the SSN assigned to that indi-
vidual. The individual should provide a
copy of the Social Security Number Print-
out to the payor who sent the second B
notice. A payor who receives a copy of
the Social Security Number Printout val-
idating the SSN of a payee will not be re-
quired to commence backup withholding,
and may stop backup withholding, on re-
portable payments made to that payee.
A payor sending a second B notice to an
individual payee should inform the payee
of this change in procedure. The following
language is acceptable:
Note that the Instructions for Incor-
rect Social Security Numbers have
changed and the SSA no longer uses
Form SSA–7028. You must request a
Social Security Number Printout from
SSA rather than Form SSA–7028. You
must send a copy of the Social Security
Number Printout directly to us, along
with a copy of this notice.
June 21, 20107672010–25 I.R.B.

These interim procedures may be used
until additional forthcoming guidance, in-
cluding a revision of Rev. Proc. 93–37, is
published.
DRAFTING INFORMATION
The principal author of this Announce-
ment is Nancy Rose of the Office of the
Associate Chief Counsel (Procedure and
Administration). For further informa-
tion regarding this announcement, con-
tact Ms. Rose at (202) 622–4940 (not a
toll-free call).
Deletions From Cumulative
List of Organizations
Contributions to Which
are Deductible Under Section
170 of the Code
Announcement 2010–42
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 June 21, 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.
Christian Credit Counseling Center
San Antonio, TX
Gullahorn Family Supporting
Organization
Naples, FL
Visual Credit Counseling Inc
Tucson, AZ
2010–25 I.R.B.768June 21, 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.
June 21, 2010i2010–25 I.R.B.

Numerical Finding List
1
Bulletins 2010–1 through 2010–25
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
2010-36, 2010-21 I.R.B.696
2010-37, 2010-20 I.R.B.685
2010-38, 2010-21 I.R.B.696
2010-39, 2010-22 I.R.B.724
2010-40, 2010-22 I.R.B.725
2010-41, 2010-25 I.R.B.767
2010-42, 2010-25 I.R.B.768
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
Notices— Continued:
2010-8, 2010-3 I.R.B.297
2010-9, 2010-3 I.R.B.298
2010-10, 2010-3 I.R.B.299
2010-11, 2010-4 I.R.B.326
2010-12, 2010-4 I.R.B.326
2010-13, 2010-4 I.R.B.327
2010-14, 2010-5 I.R.B.344
2010-15, 2010-6 I.R.B.390
2010-16, 2010-6 I.R.B.396
2010-17, 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
2010-39, 2010-24 I.R.B.756
2010-40, 2010-21 I.R.B.693
2010-41, 2010-22 I.R.B.715
2010-42, 2010-23 I.R.B.733
2010-43, 2010-22 I.R.B.716
2010-44, 2010-22 I.R.B.717
2010-45, 2010-23 I.R.B.734
2010-46, 2010-24 I.R.B.757
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
REG-114494-10, 2010-22 I.R.B.723
REG-106750-10, 2010-25 I.R.B.765
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
Revenue Procedures— Continued:
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
2010-20, 2010-14 I.R.B.528
2010-21, 2010-13 I.R.B.473
2010-22, 2010-23 I.R.B.747
2010-23, 2010-24 I.R.B.762
2010-24, 2010-25 I.R.B.764
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
2010-13, 2010-21 I.R.B.691
2010-15, 2010-23 I.R.B.730
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
9482, 2010-22 I.R.B.698
9483, 2010-23 I.R.B.726
9484, 2010-24 I.R.B.748
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.
2010–25 I.R.B.iiJune 21, 2010

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2010–1 through 2010–25
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:
97-66
Modified by
Notice 2010-46, 2010-24 I.R.B.757
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
Notices— Continued:
2008-113
Modified by
Notice 2010-6, 2010-3 I.R.B.275
2008-115
Modified by
Notice 2010-6, 2010-3 I.R.B.275
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
Revenue Procedures— Continued:
2009-2
Superseded by
Rev. Proc. 2010-2, 2010-1 I.R.B.90
2009-3
Superseded by
Rev. Proc. 2010-3, 2010-1 I.R.B.110
2009-4
Superseded by
Rev. Proc. 2010-4, 2010-1 I.R.B.122
2009-5
Superseded by
Rev. Proc. 2010-5, 2010-1 I.R.B.165
2009-6
Superseded by
Rev. Proc. 2010-6, 2010-1 I.R.B.193
2009-7
Superseded by
Rev. Proc. 2010-7, 2010-1 I.R.B.231
2009-8
Superseded by
Rev. Proc. 2010-8, 2010-1 I.R.B.234
2009-9
Superseded by
Rev. Proc. 2010-9, 2010-2 I.R.B.258
2009-15
Amplified and superseded by
Rev. Proc. 2010-12, 2010-3 I.R.B.302
2009-17
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
2009-27
Obsoleted by
Rev. Proc. 2010-23, 2010-24 I.R.B.762
2009-50
Section 3.20 modified and superseded by
Rev. Proc. 2010-24, 2010-25 I.R.B.764
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
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.
June 21, 2010iii2010–25 I.R.B.

Revenue Rulings— Continued:
92-19
Supplemented in part by
Rev. Rul. 2010-7, 2010-8 I.R.B.417
2008-52
Supplemented and superseded by
Rev. Rul. 2010-2, 2010-3 I.R.B.272
Treasury Decisions:
9350
Corrected by
Ann. 2010-38, 2010-21 I.R.B.696
Ann. 2010-39, 2010-22 I.R.B.724
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
2010–25 I.R.B.ivJune 21, 2010

June 21, 20102010–25 I.R.B.

2010–25 I.R.B.June 21, 2010

June 21, 20102010–25 I.R.B.

INTERNAL REVENUE BULLETIN
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Bulletin is sold on a yearly subscription basis by the Superintendent of Documents. Current subscribers are notified by the Superin-
tendent of Documents when their subscriptions must be renewed.
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