Internal Revenue Bulletin 2010-27 (PDF rendition): IRS Announcements

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Bulletin No. 201
0-27
July 6, 2010
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
INCOME TAX
Rev. Rul. 2010–18, page 1.
Federal rates; adjusted federal rates; adjusted federal
long-termrateandthelong-termexemptrate.For pur-
poses of sections 382, 642, 1274, and 1288, and other sec-
tions of the Code, tables set forth the rates for July 2010.
Notice 2010–49, page 10.
Section 382.This notice invites public comments relating to
possible modifications to the regulations under section 382 of
the Code regarding the treatment of shareholders who are not
5-percent shareholders (Small Shareholders).
Notice 2010–50, page 12.
Section 382.This notice provides guidance under section
382 of the Code for measuring owner shifts of loss corpora-
tions that have more than one class of stock outstanding, and,
in particular, regarding the effect of fluctuations in the value of
one class of stock relative to another class of stock.
EMPLOYEE PLANS
Notice 2010–48, page 9.
This notice provides relief to sponsors of defined contribu-
tion pre-approved plans (i.e., master and prototype (M&P) and
volume submitter (VS) plans) affected by recent federally de-
clared disasters. The relief providedbythisnoticeextendsthe
April 30, 2010, deadline for restating affected pre-approved
defined contribution plans and, if applicable, for submitting
determination letters to the Service to July 30, 2010. The
section 401(b) remedial amendment period with respect to
these plans is also extended to July 30, 2010. Rev. Proc.
2007–44 modified.
EXCISE TAX
T.D. 9486, page 3.
REG–112841–10, page 41.
Final, temporary, and proposed regulations provide guidance
on section 5000B of the Code– the indoor tanning services
excise tax imposed by the Patient Protection and Affordable
Care Act. The regulations affect persons that use, provide, or
pay for indoor tanning services.
ADMINISTRATIVE
Rev. Proc. 2010–25, page 16.
This procedure provides issuers of qualified mortgage bonds
(QMBs) and qualified mortgage credit certificates (MCCs) with
average area purchase price safe harbors for statistical areas
in the United States and with a nationwide average purchase
price for residences in the United States for purposes of the
QMB rules under section 143 of the Code and the MCC rules
under section 25. Rev. Proc. 2009–18 obsoleted in part.
Announcements of Disbarments and Suspensions begin on page 42.
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.
July 6, 20102010–27 I.R.B.

Part I. Rulings
and Decisions Under the Internal Revenue Code
of 1986
Section 42.—L
ow-Income
Housing Credi
t
The adjusted a
pplicable federal short-term, mid-
term, and long
-term rates are set forth for the month
of July 2010. S
ee Rev. Rul. 2010-18, page 1.
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term rates
are set forth for the month of July 2010. See Rev.
Rul. 2010-18, page 1.
Section 382.—Limitation
on Net Operating Loss
Carryforwa
rds and Certain
Built-In Losses Following
Ownership Change
The adjusted applicable federal long-term rate is
set forth for the month of July 2010. See Rev. Rul.
2010-18, page 1.
Section 412.—Minimum
Funding Standards
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of July 2010. See Rev. Rul. 2010-18, page 1.
Section 467.—Certain
Payments for the Use of
Property or Services
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of July 2010. See Rev. Rul. 2010-18, page 1.
Section 468.—Special
Rules for Mining and Solid
Waste
Reclamation and
Closi
ng Costs
The ad
justed applicable federal short-term, mid-
term,
and long-term rates are set forth for the month
of Jul
y 2010. See Rev. Rul. 2010-18, page 1.
Section 482.—
Allocation
of Income and D
eductions
Among Taxpaye
rs
Federal short
-term, mid-term, and long-term rates
are set forth f
or the month of July 2010. See Rev.
Rul. 2010-18
,page1.
Section 483.—Interest on
Certain Deferred Payments
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of July 2010. See Rev. Rul. 2010-18, page 1.
Section 642.—Special
Rules for Credits and
Deductions
Federal short-term, mid-term, and long-term rates
are set forth for the month of July 2010. See Rev.
Rul. 2010-18, page 1.
Section 807.—Rules for
Certain Reserves
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of July 2010. See Rev. Rul. 2010-18, page 1.
Section 846.—Discounted
Unpaid Losses Defined
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of July 2010. See Rev. Rul. 2010-18, page 1.
Section 1274.—Determi-
nation of Issue Price in the
Case of Certain Debt Instru-
ments Issued for Property
(Also Sections 42, 280G, 382, 412, 467, 468, 482,
483, 642, 807, 846, 1288, 7520, 7872.)
Federal rates; adjusted federal rates;
adjusted federal long-term rate and the
long-term exempt rate.For purposes of
sections 382,
642, 1274, and 1288, and
other section
s of the Code, tables set forth
the rates for J
uly 2010.
Rev. Rul. 2010
–18
This revenue
ruling provides various
prescribed r
ates for federal income tax pur-
poses for Jul
y 2010 (the current month).
Table 1 conta
ins the short-term, mid-term,
and long-ter
m applicable federal rates
(AFR) for th
e current month for purposes
of section 1
274(d) of the Internal Revenue
Code. Table
2 contains the short-term,
mid-term, a
nd long-term adjusted appli-
cable fede
ral rates (adjusted AFR) for
the curren
t month for purposes of section
1288(b). T
able 3 sets forth the adjusted
federal lo
ng-term rate and the long-term
tax-exem
pt rate described in section
382(f). T
able 4 contains the appropriate
percenta
ges for determining the low-in-
come hous
ing credit described in section
42(b)(1)
for buildings placed in service
during t
he current month. However, under
section
42(b)(2), the applicable percentage
for non-
federally subsidized new build-
ings pla
ced in service after July 30, 2008,
and befo
re December 31, 2013, shall not
be less
than 9%. Table 5 contains the
federa
l rate for determining the present
value o
f an annuity, an interest for life
or for a
term of years, or a remainder or
a rever
sionary interest for purposes of
secti
on 7520. Finally, Table 6 contains the
blend
ed annual rate for 2010 for purposes
of sec
tion 7872.
2010–27 I.R.B.1July 6, 2010

REV. RUL. 2010–18 TABLE 1
Applicable Federal Rates (AFR) for July 2010
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
AFR.61%.61%.61%.61%
110% AFR.67%.67%.67%.67%
120% AFR.73%.73%.73%.73%
130% AFR.79%.79%.79%.79%
Mid-term
AFR
2.35%
2.34%2.33%2.33%
110% AFR
2.59%2.57%2.56%2.56%
120% AFR2.83%2.81%2.80%2.79%
130% AFR3.06%3.04%3.03%3.02%
150% AFR3.54%3.51%
3.49%3.48%
175% AFR
4.14%4.10%4.08%4.07%
Long-term
AFR3.94%3.90%3.88%3.87%
110% AFR4.34%4.29%4.27%
4.25%
120% AFR4.73%4.68%
4.65%
4.64%
130% AFR
5.13%5.07%5.04%5.02%
REV. RUL. 2010–18 TABLE 2
Adjusted AFR for July 2010
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term adjusted
AFR
.63%.63%.63%.63%
Mid-term adjusted AFR1.97%1.96%1.96%
1.95%
Long-term adjusted
AFR
3.99%
3.95%
3.93%3.92%
REV. RUL. 2010–18 TABLE 3
Rates Under Section 382 for July 2010
Adjusted federal long-term rate for the current month3.99%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted
federal long-term rates for the current month and the prior two months.)4.01%
REV. RUL. 2010–18 TABLE 4
Appropriate Percentages UnderSection 42(b)(1) for July 2010
Note: Under Section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after
July 30, 2008, and before December 31, 2013, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit7.73%
Appropriate percentage for the 30% present value low-income housing credit3.31%
July 6, 201022010–27 I.R.B.

REV. RUL. 2010–18 TABLE 5
Rate Under Section 7520 for July 2010
Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years,
or a remainder or reversionary interest2.8%
REV. RUL. 2010–18 TABLE 6
Blended Annual Rate for 2010
Section 7872(
e)(2) blended annual rate for 2010
.59%
Section 1288.—Treatment
of Original Issue Discount
on Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of July 2010. See Rev. Rul. 2010-18, page 1.
Section 5000B.—Indoor
Tanning Services
26 CFR 49.5000B–1T: Indoor tanning services (tem-
porary).
T.D. 9486
DEPARTMENT OF THE
TREASURY
Internal Revenue Service
26 CFR Parts 40, 49, and 602
Indoor Tanning Services;
Cosmetic Services; Excise
Taxes
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final and temporary regula-
tions.
SUMMARY: This document contains fi-
nal and temporary regulations that provide
guidance on the indoor tanning services
excise tax imposed by the Patient Protec-
tion and Affordable Care Act. These final
and temporary regulations affect persons
that use, provide, or pay for indoor tanning
services. The text of these temporary reg-
ulations also serves as the text of the pro-
posed regulations (REG–112841–10) set
forth in the notice of proposed rulemaking
on this subject in this issue of the Bulletin.
DATES:Effective Date:These regulations
are effective on June 15, 2010.
Applicability Date:For dates of
applicability, see §§40.0–1T(e) and
49.5000B–1T(h).
FOR FURTHER INFORMATION
CONTACT: Taylor Cortright, (202)
622–3130 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Paperwork Reduction Act
The collection of information contained
in these regulations has been reviewed
and approved by the Office of Manage-
ment and Budget under control number
1545–2177. The information is required
to be maintained in order for the provider
of indoor tanning services to accurately
calculate the tax on indoor tanning ser-
vices when those services are offered with
other goods and services, as described
in §49.5000B–1T(d)(2). An agency may
not conduct or sponsor, and a person is
not required to respond to, a collection of
information unless the collection of infor-
mation displays a valid control number.
For further information concerning this
collection of information, and where to
submit comments on the collection of in-
formation and the accuracy of the esti-
mated burden, and suggestions for reduc-
ing this burden, please refer to the pream-
ble to the cross-reference notice of pro-
posed rulemaking on this subject in this is-
sue of the Bulletin.
Books or records relating to a collection
of information must be retained as long
as their contents may become material in
the administration of any internal revenue
law. Generally, tax returns and tax return
information are confidential, as required
by 26 U.S.C. 6103.
Background
This document amends the Excise Tax
Procedural Regulations (26 CFR part 40)
and the Facilities and Services Excise Tax
Regulations (26 CFR part 49) under sec-
tion 5000B of the Internal Revenue Code
(Code). Section 5000B was added to the
Code by section 10907 of the Patient Pro-
tection and Affordable Care Act, Public
Law 111–148 (124 Stat. 119 (2010)), to
impose an excise tax on indoor tanning ser-
vices.
Explanation of Provisions
Section 5000B(a) imposes on any in-
door tanning service a tax equal to 10 per-
cent of the amount paid for such service.
Indoor tanning service, as defined in sec-
tion 5000B(b), does not include any pho-
totherapy service provided by a licensed
medical professional. The regulations de-
fine phototherapy service and clarify that
such service must be performed by, and on
the premises of, a licensed medical profes-
sional.
The tax applies to amounts paid after
June 30, 2010, for indoor tanning services.
Liability for the tax arises at the time of
payment for the indoor tanning services.
In some cases (such as purchase of an un-
designated payment card, discussed later
in this preamble), it may not be possible to
determine whether there is a payment for
indoor tanning services. Thus, the regu-
lations provide in those cases that a pay-
ment is treated as made, and the tax is im-
posed, at the time it can reasonably be de-
termined that the payment is made specif-
ically for indoor tanning services. In the
2010–27 I.R.B.3July 6, 2010

case of membership fees paid to certain
physical fitness facilities that provide in-
door tanning services, the regulations pro-
vide a different rule, discussed later in this
preamble.
The regulations provide that the
“amount paid” for purposes of determin-
ing the tax base includes all amounts paid
to the provider for indoor tanning services,
including any amount paid by insurance.
Providers of indoor tanning services, how-
ever, often sell other goods and services
(such as protective eyewear, footwear,
towels, and tanning lotions; manicures,
pedicures and other cosmetic or spa treat-
ments; and access to sport or exercise
facilities) in addition to indoor tanning ser-
vices. Thus, the regulations provide rules
for determining the tax when the provider
charges for other goods and services in
addition to indoor tanning services.
Section 6001 requires taxpayers to
keep books and records sufficient to show
whether or not they are liable for tax. To
that end, the regulations allow the provider
to exclude charges for other goods and ser-
vices if the charges are separable, do not
exceed the fair market value of the other
goods and services, and are shown in the
exact amounts in the records pertaining to
the indoor tanning services charge.
If the charges are not separately stated,
but the total amount paid covers indoor
tanning services, then the tax is based on
the portion of the amount paid that is rea-
sonably attributable to the indoor tanning
services. For example, if the provider
sells bundled services in which the in-
door tanning service is bundled with other
goods and services, and the charge is not
separately stated, the tax applies to the
amount paid that is reasonably attributable
to the indoor tanning services. This is
consistent with the approach taken in Rev.
Rul. 63–155, 1963–2 C.B. 566 (relating
to the application of the section 4261 tax
on transportation by air to a package tour
sold by a hotel that includes airfare, hotel
accommodations, and other services not
subject to the section 4261 tax).
The regulations provide that a payment
for indoor tanning services is treated as
made, and liability for the tax is imposed,
at the time it can reasonably be determined
that the payment is made specifically for
indoor tanning services. If a payment is
made with a gift certificate, gift card or
similar device with a monetary value that
can be redeemed for goods or services
that may, but do not necessarily, include
indoor tanning services (an undesignated
payment card), it can reasonably be deter-
mined that a payment is made specifically
for indoor tanning services when the un-
designated payment card is redeemed, in
whole or in part, to pay specifically for in-
door tanning services (and not when a pay-
ment is made to purchase the undesignated
payment card). This is consistent with
the approach taken in Rev. Rul. 56–157,
1956–1 C.B. 523 (relating to the applica-
tion of the section 4261 tax on transporta-
tion by air to a gift certificate that could
be redeemed for air transportation or cash).
In these cases, the provider of the ser-
vices calculates the tax on the amount of
the undesignated payment card that is re-
deemed for indoor tanning services at the
time it is redeemed, and the rules of section
5000B(c) apply to determine the person li-
able for the tax.
If, however, the provider sells bundled
services in which access to indoor tan-
ning services (in a specified or unlimited
amount) over a period of time is bundled
with other goods and services, it can rea-
sonably be determined that the payment is
made specifically for indoor tanning ser-
vices at the time the bundled services are
purchased, because there is value attribut-
able to the access to indoor tanning ser-
vices. This is different than the example of
the gift certificate, because the gift certifi-
cate can be redeemed entirely for non-tax-
able services, but the purchase of bundled
services will always include access to in-
door tanning services in the “bundle”. In
addition, for purposes of these regulations,
payments for indoor tanning services are
subject to tax, regardless of actual usage.
Thus, the tax applies to the amount paid
that is reasonably attributable to the access
to indoor tanning services, and the rules
of section 5000B(c) apply to determine the
person liable for the tax.
On the other hand, in the case of a pay-
ment of a membership fee to a qualified
physical fitness facility (QPFF) (as defined
in the regulations) that includes access to
indoor tanning services, the IRS and Trea-
sury Department have determined that the
access is incidental to the QPFF’s predom-
inant business or activity and any amount
attributable to such access would be diffi-
cult to calculate and administer. Thus, an
amount paid to a QPFF is not a payment
for indoor tanning services and the tax is
not imposed on the amount paid. The reg-
ulations narrowly define QPFF to require,
among other things, that the predominant
business or activity of the facility is to
serve as a physical fitness facility, taking
into consideration all of the facts and cir-
cumstances. Thus, for example, a busi-
ness predominantly engaged in providing
indoor tanning or other cosmetic services
cannot become a QPFF by allowing users
access to exercise classes or pieces of ex-
ercise equipment. The regulations further
provide that a QPFF cannot charge sep-
arately for indoor tanning services, offer
such services to the public, or offer differ-
ent membership fee rates based on access
to indoor tanning services. Thus, a physi-
cal fitness facility that distinguishes mem-
berships based on access to indoor tanning
services is not a QPFF.
Section 5000B(c)(1) provides that the
person liable for the tax is the individual
on whom the indoor tanning service is per-
formed. In some cases, a person might pay
for services to be performed on someone
else, such as by purchasing a gift certifi-
cate for indoor tanning services. Because
the tax is calculated on the amount paid for
the indoor tanning services, and because
the statute contemplates that the tax will be
collected at the time payment is made, the
person who pays for the services (payor)
is deemed to be the person on whom the
services are performed for purposes of col-
lecting the tax. Thus, the payor is liable for
the tax on the services. If a person pays
for a gift certificate for indoor tanning ser-
vices (or for bundled services that includes
indoor tanning services), then the liability
for the tax arises at the time of payment.
However, if a person purchases an un-
designated payment card, then a payment
has not been made for indoor tanning ser-
vices until the undesignated payment card
is redeemed specifically to pay for indoor
tanning services. In that case, the liability
for the tax arises at the time the undesig-
nated payment card is redeemed. The per-
son who redeems the card for indoor tan-
ning services is deemed to be the person on
whom the services are performed for pur-
poses of collecting the tax, and that person
is liable for the tax on the services.
Section 5000B(c)(2) provides that the
person receiving the payment on which tax
is imposed (the provider) generally must
collect the tax from the payor and pay
July 6, 201042010–27 I.R.B.

the tax over quarterly to the government.
These regulations provide that the amount
paid by the payor to the provider is pre-
sumed to include the tax if the tax is not
separately stated.
In this issue of the Bulletin, the IRS
and Treasury Department are request-
ing comments regarding these tempo-
rary regulations, including comments on
whether the presumption relating to sec-
tion 5000B(c)(2) (that the amount paid
by the payor to the provider includes the
taxifthetaxisnotseparatelystated)
is consistent with the manner in which
providers maintain books and records and
specifically whether such a rule is useful
for purposes of minimizing recordkeeping
burdens of the providers.
If the payor does not pay the tax at
the time payment for the indoor tanning
services is made, section 5000B(c)(3)
provides that, to the extent the tax is not
collected, the provider must pay the tax.
Thus, the regulations provide that if the
provider of the indoor tanning services
fails to collect the tax from the payor at
thetimethepayormakesapaymentfor
indoor tanning services, the provider is
liable for the tax.
These regulations apply the existing ex-
cise tax procedural rules in 26 CFR part
40 to the tax on indoor tanning services.
Thus, the tax, whether paid by the payor or
the provider under section 5000B(c), is re-
ported by the provider on Form 720 “Quar-
terly Federal Excise Tax Return.”These
temporary part 40 regulations do not re-
quire semimonthly deposits of tax; rather,
full payment of the tax is due quarterly at
the time Form 720 is timely filed. The ex-
isting regulations also provide that once a
Form 720 is required to be filed for a cal-
endar quarter, a Form 720 must be filed for
each subsequent calendar quarter, whether
or not liability is incurred (or tax must be
collected and paid over) during that sub-
sequent quarter, until a final return under
§40.6011(a)–2 is filed.
Some providers of indoor tanning ser-
vices may operate more than one location
at which the services are provided. Each
business unit that has, or is required to
have, a separate employer identification
number is treated as a separate person that
must file a separate Form 720.
Collected taxes are held in special trust
for the United States pursuant to section
7501, and any person who willfully fails
to collect and pay over the tax may be
subject to the penalty in section 6672. The
IRS will generally administer the indoor
tanning services tax (in Chapter 49 of the
Code), the same way it administers the
other collected excise taxes in Chapter
33 of the Code (the communications and
transportation taxes). However, the re-
porting provisions in §49.4291–1 of the
regulations (relating to certain inabilities
to collect or refusals to pay tax) do not
apply to the tax on indoor tanning services
because section 4291 provides that these
rules apply only to the Chapter 33 taxes.
Availability of IRS documents
The IRS revenue rulings cited in this
preamble are published in the Internal
Revenue Cumulative Bulletin and are
available from the Superintendent of Doc-
uments, P.O. Box 371954, Pittsburgh PA,
15250–7954.
Special Analyses
It has been determined that this Trea-
sury decision is not a significant regula-
tory action as defined in Executive Order
12866. 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. For appli-
cability of the Regulatory Flexibility Act
(5 U.S.C. chapter 6), please refer to the
Special Analysis section in the preamble
to the cross-referenced notice of proposed
rulemaking in this issue of the Bulletin.
Pursuant to section 7805(f) of the Code,
these regulations have been submitted to
the Chief Counsel for Advocacy of the
Small Business Administration for com-
ment on their impact on small business.
Drafting Information
The principal author of these regula-
tions is Taylor Cortright, Office of the
Associate Chief Counsel (Passthroughs
and Special Industries).However,
other personnel from the IRS and the
Treasury Department participated in their
development.
*****
Amendments to the Regulations
Accordingly, 26 CFR parts 40, 49, and
602 are amended as follows:
PART 40—EXCISE TAX
PROCEDURAL REGULATIONS
Paragraph 1. The authority citation for
part 40 continues to read in part as follows:
Authority: 26 U.S.C. 7805. * * *
Par. 2. Section 40.0–1 is amended as
follows:
1. Paragraph (d) is redesignated as
paragraph (f) and new paragraphs (d) and
(e) are added.
2. The paragraph heading of redesig-
nated paragraph (f) is revised.
The addition and revision read as fol-
lows:
§40.0–1 Introduction.
*****
(d) [Reserved]. For further guidance,
see §40.0–1T(d).
(e) [Reserved]. For further guidance,
see §40.0–1T(e).
(f)Effective/applicability dates.***
Par. 3. Section 40.0–1T is added to read
as follows:
§40.0–1T Introduction (temporary).
(a) through (c) [Reserved]. For further
guidance, see §40.0–1(a) through (c).
(d)Indoor tanning services.Thereg-
ulations in this part 40 also set forth ad-
ministrative provisions relating to the ex-
cise taxes imposed by chapter 49, relating
to cosmetic services.
(e)Effective/applicability date. Para-
graph (d) of this section applies to returns
that relate to calendar quarters beginning
after June 30, 2010.
(f) [Reserved]. For further guidance,
see §40.0–1(f).
(g)Expiration date. Paragraph (d) of
this section expires on or before June 11,
2013.
Par. 4. Section 40.6302(c)–1 is
amended by:
1. In paragraph (a)(1), removing the
language “by statute” and adding “by
statute, by §40.6302(c)–1T(g),” in its
place.
2. Revising the paragraph heading in
paragraph (f).
3. Adding paragraph (g).
2010–27 I.R.B.5July 6, 2010

The revision and additions read as fol-
lows:
§40.6302(c)–1 Use of Government
depositories.
*****
(f)Effective/applicability date.***
(g) [Reserved]. For further guidance,
see §40.6302(c)–1T(g).
Par. 5. Section 40.6302(c)–1T is added
to read as follows:
§40.6302(c)–1T Use of government
depositaries (temporary).
(a) through (f) [Reserved]. For further
guidance, see §40.6302(c)–1(a) through
(f).
(g)Exception for indoor tanning ser-
vices. No deposit is required for the taxes
imposedbysection5000B(relatingtoin-
door tanning services) for any calendar
quarter beginning after June 30, 2010.
(h)Expiration date. This section ex-
pires on or before June 11, 2010.
PART 49—FACILITIES AND
SERVICES EXCISE TAX
Par. 6. The authority citation for part
49 continues to read in part as follows:
Authority: 26 U.S.C. 7805. * * *
Par. 7. Section 49.0–3T is added to read
as follows:
§49.0–3T Introduction; cosmetic services
(temporary).
On and after July 1, 2010, this part 49
also applies to taxes imposed by chapter
49 of the Internal Revenue Code, relating
to cosmetic services. See part 40 of this
chapter for regulations relating to returns
and payments of taxes imposed by chapter
49.
Par. 8. Subpart G is added to read as
follows:
Subpart G—Cosmetic Services
§49.5000B–1T Indoor tanning s
ervices
(temporary).
(a)Overview. This section provides
rules for the tax imposed by section 5000B
on any indoor tanning service.
(b)Imposition of tax—(1)General rule.
Tax is imposed by section 5000B at the
time of payment for any indoor tanning
service.
(2)Undesignated payment cards.In
the case of an undesignated payment card
(within the meaning of paragraph (c)(5) of
this section), payment for indoor tanning
services is made when it can reasonably be
determined that a payment is made specif-
ically for indoor tanning services. Thus,
when the undesignated payment card is re-
deemed, in whole or in part, to pay for in-
door tanning services (and not when a pay-
ment is made to purchase the undesignated
payment card), it can reasonably be deter-
mined that a payment for indoor tanning
services is made, and the tax is imposed.
(3)Payments to qualified physical fit-
ness facilities. No portion of a payment to
a qualified physical fitness facility (within
the meaning of paragraph (c)(4) of this sec-
tion) that includes access to indoor tanning
services is treated as a payment for indoor
tanning services.
(c)Definitions—(1)Indoor tanning
servicemeans a service employing any
electronic product designed to incorporate
one or more ultraviolet lamps and intended
for the irradiation of an individual by ul-
traviolet radiation, with wavelengths in
air between 200 and 400 nanometers, to
induce skin tanning. The term does not
include phototherapy service performed
by, and on the premises of, a licensed med-
ical professional (such as a dermatologist,
psychologist, or registered nurse).
(2)Other goods and servicesinclude,
but are not limited to, protective eyewear,
footwear, towels, and tanning lotions;
manicures, pedicures and other cosmetic
or spa treatments; and access to sport or
exercise facilities.
(3)Phototherapy servicemeans a ser-
vice that exposes an individual to specific
wavelengths of light for the treatment of—
(i) Dermatological conditions (such as
acne, psoriasis, and eczema);
(ii) Sleep disorders;
(iii) Seasonal affective disorder or other
psychiatric disorder;
(iv) Neonatal jaundice;
(v) Wound healing; or
(vi) Other medical condition deter-
mined by a licensed medical professional
to be treatable by exposing the individual
to specific wavelengths of light.
(4)Qualified physical fitness facility
means a facility—
(i) In which the predominant business
or activity is providingfacilities, equip-
ment, and services to its members for pur-
poses of exercise and physical fitness (de-
termined by taking into consideration all
of the facts and circumstances, such as the
cost of the equipment, variety of services
offered, actual usage of services by cus-
tomers, revenue generated by different ser-
vices, and how the entity holds itself out
to the public through advertising or other
means);
(ii) In which providing indoor tanning
services is not a substantial part of the busi-
ness or activity; and
(iii) That does not sell indoor tanning
services for a fee to the public or otherwise
offer different pricing options to its mem-
bers based in whole or in part on access to
indoor tanning services.
(5)
Undesignated payment cardmeans
a gift certificate, gift card, or similar item
that can be redeemed for goods or services
that may, but do not necessarily, include
indoor tanning services.
(d)Application of tax—(1)Tax on total
amount paid for indoor tanning services.
The tax is imposed on the total amount
paid for indoor tanning services, including
any amount paid by insurance.
(2)Charges for other goods and ser-
vices; tanning services separately stated.
If a payment covers charges for indoor tan-
ning services as well as other goods and
services, the charges for other goods and
services may be excluded in computing
the tax payable on the amount paid, if the
charges—
(i) Are separable (regardless of the
manner of invoicing the charges);
(ii) Do not exceed the fair market value
of such other goods and services; and
(iii) Are shown in the exact amounts in
the records pertaining to the indoor tanning
services charge.
(3)Charges for other goods and ser-
vices; tanning services bundled.This
paragraph (d)(3) applies if paragraph
(d)(2) of this section does not apply.
If a provider offers indoor tanning ser-
vices (whether of a specified or unlimited
amount, including “free” or reduced-rate
indoor tanning services) bundled with
other goods and services, the payment for
the bundled servicesincludes an amount
paid for indoor tanning services. The tax
applies to that portion of the amount paid
to the provider that is reasonably attrib-
July 6, 201062010–27 I.R.B.

utable to indoor tanning services. The
amount reasonably attributable to indoor
tanning services may be determined by
applying to the total amount paid a ratio
determined by comparing—
(i) The provider’s charge for indoor tan-
ning services not in bundled services or,
in the event the provider only charges for
other goods and services as part of bun-
dled services, the fair market value of sim-
ilar services (based on the amount charged
by comparable providers in the same geo-
graphic area); to
(ii) The charge determined in paragraph
(d)(3)(i) of this section plus the provider’s
charge for the other goods and services
in the bundled services or, in the event
the provider only charges for other goods
and services as part of bundled services,
the fair market value of similar goods and
services (based on the amount charged by
comparable providersinthesamegeo-
graphic area).
(e)Person liable for the tax—(1)Gen-
eral rule. The person who pays for the in-
door tanning service is deemed to be the
person on whom the service is performed
for purposes of collecting the tax. Thus,
the person paying for the indoor tanning
service is liable for the tax at the time of
payment.
(2)Undesignated payment cards.Inthe
case of a payment made with an undes-
ignated payment card (within the mean-
ing of paragraph (c)(5) of this section) de-
scribed in paragraph (b)(2) of this section,
the person who redeems the card, in whole
or in part, to pay specifically for indoor
tanning services is the person who pays
for the indoor tanning services. Thus, the
person who redeems an undesignated pay-
ment card, in whole or in part, to pay
specifically for indoor tanning services is
liable for the tax at the time such payment
is made.
(3)Tax not collected at time of payment.
If the person paying for the indoor tanning
services does not pay the tax to the person
receiving the payment for the services at
the time of payment for the services, the
person receiving the payment is liable for
the tax.
(f)Persons receiving payment must col-
lect tax. Every person receiving a payment
for indoor tanning services on which a tax
is imposed under this section shall collect
the amount of the tax from the person mak-
ing that payment. The total amount paid is
presumed to include the tax if the tax is not
separately stated.
(g)Examples. The following examples
illustrate the application of section 5000B
and this section.
Example 1. A is a provider of indoor tanning
services and other goods and services. On July 1,
2010, B, an individual, pays A for one 10-minute in-
door tanning service (as defined in paragraph (c)(1)
of this section) and one pair of protective eyewear.
A charges $15.00 for the 10-minute indoor tanning
service and $2.00 for a pair of protective eyewear.
The $2.00 charge for the protective eyewear does not
exceed its fair market value. The invoice from A
is $17.00 (exclusive of the tax imposed by section
5000B) and separately states the cost of the protective
eyewear. Because the cost of the protective eyewear
is separately stated, A calculates the section 5000B
tax on $15.00 as provided by paragraph (d)(2) of this
section. B is liable for the tax when B pays for the
services. If A does not collect the tax from B at the
time B pays for the services, A is liable for the tax.
Example 2. A, a provider of indoor tanning
services and other goods and services, periodically
offers bundled services to promote additional busi-
ness. On July 1, 2010, C, an individual, buys bundled
service from A that includes 10 swimming lessons,
the use of towels while on A’s premises, one pair of
protective eyewear, and 2 “free” 10-minute indoor
tanning services. A charges $252.00 (exclusive of
the tax imposed by section 5000B) for the bundled
services. If these services are purchased separately,
A charges (exclusive of the tax imposed by section
5000B) $25.00 per swimming lesson, $15.00 for
a 10-minute indoor tanning service, $2.00 for the
protective eyewear and does not charge for the use
of towels while on A’s premises. As determined
under paragraph (d)(3) of this section, the section
5000B tax applies to the amount reasonably attribut-
able to the indoor tanning service, which is $26.81
(($30/$282) x $252).
Example 3. On July 1, 2010, D buys bundled
services (described inExample 2) from A as a gift
for C. Under paragraph (e)(1) of this section, D is
deemed to be the person on whom the indoor tanning
services are performed for purposes of collecting the
tax. Therefore, under paragraph (b)(1) of this section,
D is liable for the tax when D pays for the services.
The tax will be computed under the rules of paragraph
(d)(3) of this section. If D does not pay the tax at the
time D pays for the services, A is liable for the tax.
Example 4. S operates a spa that provides a vari-
ety of cosmetic goods and services, including indoor
tanning services. On July 1, 2010, D buys a gift cer-
tificate in the amount of $100.00 from S as a gift for
C. The gift certificate may be redeemed by C for C’s
choice among several services offered by S, including
indoor tanning services. On July 15, 2010, C partially
redeems the gift certificate to pay for one 10-minute
indoor tanning service. Under paragraph (b)(2) of
this section, a payment for indoor tanning services is
made, and the tax under section 5000B is imposed, on
July 15, 2010, when C partially redeems the gift cer-
tificate to pay for one indoor tanning service. Under
paragraph (e)(2) of this section, C is the person who
pays for the indoor tanning services. Therefore, C is
liable for the tax, computed under the rules of para-
graph (d) of this section, and pays the tax by permit-
ting S to debit the amount of the tax from the balance
of the gift certificate or by paying the amount of the
tax to S in cash. If C does not pay the tax at the time
C partially redeems the gift certificate to pay for the
indoor tanning services, S is liable for the tax.
Example 5. On July 1, 2010, E pays $1000 (ex-
clusive of the tax imposed by section 5000B) to spa
S for the right to use the following equipment and
services during the month of July: up to four mas-
sages or facials, unlimited use of a sauna, steam room,
showers, and towel service, and unlimited indoor tan-
ning services. If the services are purchased sepa-
rately, S charges (exclusive of the tax imposed by sec-
tion 5000B) $150 for unlimited indoor tanning ser-
vices during the month of July, and $900 for the other
equipment and services during the month of July, not
including indoor tanning services. Under paragraph
(b) of this section, E has made a payment for indoor
tanning services and the tax will be computed under
the rules of paragraph (d)(3) of this section. As de-
termined under paragraph (d)(3) of this section, the
section 5000B tax applies to the amount reasonably
attributable to the indoor tanning services, which is
$142.86 (($150/$1050) x $1000). If E does not pay
the tax at the time E pays for the bundled services, S
is liable for the tax.
Example 6. G operates a full-service gym fa-
cility that offers fitness classes, multiple exercise
machines (such as treadmills, stationary bicycles,
weight training machines, and free weights), and
has as its predominant business providing these
facilities, equipment, and services to members for
purposes of exercise and physical fitness. G provides
its members with access to indoor tanning services,
comprised of two tanning beds that meet the defini-
tion of indoor tanning services under paragraph (c)(1)
of this section. G generally charges its members a
fee for monthly usage of its facilities, equipment,
and services, but also offers short-term or free trial
memberships and allows non-members to purchase
individual or a series of exercise classes. G does
not charge any fee for the indoor tanning services,
does not offer indoor tanning services separately
from its other services, and has no membership tier
or category that differs from others based on access
to the indoor tanning services. G holds itself out to
the public through advertising and marketing as pro-
viding equipment and services to improve physical
fitness. On July 1, 2010, F pays a membership fee to
G in return for use of G’s facility during the month
of July. Under paragraph (b)(3) of this section, no
portion of F’s membership fee payment is treated as
a payment made for indoor tanning services, because
G is a qualified physical fitness facility under para-
graph (c)(4) of this section. Therefore, no liability
for tax arises under section 5000B.
(h)Effective/applicability date.This
section applies to amounts paid after
June 30, 2010, for indoor tanning services.
(i)Expiration date. This section expires
on or before June 11, 2013.
2010–27 I.R.B.7July 6, 2010

PART 602—OMB CONTROL
NUMBERS UNDER THE PAPERWORK
REDUCTION ACT
Par. 9. The authority citation for part
602 continues to read as follows:
Authority: 26 U.S.C. 7805.
Par. 10. In §602.101, paragraph (b)
is amended by adding the following entry
in numerical order to the table to read as
follows:
§602.101 OMB Control numbers.
*****
(b) * * *
CFR part or section where
identified and described
Current OMB
control No.
*****
1.5000B–1
...........................................................
1545–2177
*****
Steven T. Miller,
Deputy Commissioner for
Services and Enforcement.
Approved June 9, 2010.
Michael Mundaca,
Assistant Secretary
oftheTreasury(TaxPolicy).
(Filed by the Office of the Federal Register on June 11, 2010,
11:15 a.m., a
nd published in the issue of the Federal Register
for June 15, 2010, 75 F.R. 33683)
Section 7520.—Valuation
Tables
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of July 2010. See Rev. Rul. 2010-18, page 1.
Section 7872.—Treatment
of Loans With Below-Market
Interest Rates
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of July 2010. See Rev. Rul. 2010-18, page 1.
July 6, 201082010–27 I.R.B.

Part III. Administrative, Procedural, and Miscellaneous
Notice Providing Disaster
Relief to Sponsors of
Pre-Approved Defined
Contribution Plans
Notice 2010–48
I. PURPOSE
This notice provides relief to sponsors
of defined contribution pre-approved plans
(i.e., master and prototype (“M&P”) and
volume submitter (“VS”) plans) affected
by recent federally declared disasters (as
defined in § 165(h)(3)(C)(i) of the Internal
Revenue Code (the “Code”)). The relief
provided by this notice extends to July 30,
2010, the April 30, 2010, deadline for re-
stating affected pre-approved defined con-
tribution plans and, if applicable, for sub-
mitting determination letters to the Ser-
vice. The § 401(b) remedial amendment
period with respect to these plans is also
extended to July 30, 2010. The relief pro-
videdbythisnoticeisinadditiontothere-
lief already provided by the Internal Rev-
enue Service (IRS) to those affected by
the federally declared disasters identified
in this notice.
II. BACKGROUND
A. Provisions Relating to Disaster Relief
Under § 7508A of the Code, relief
may be provided by the Secretary when
there has been a federally declared disaster
or a terroristic or military action (as de-
fined in § 692(c)(2)). Under Treas. Reg.
§ 301.7508A–1(a), affected taxpayers are
eligible for the postponement of certain
tax-related deadlines to file returns, pay
taxes, or perform other acts related to
income taxes administered by the IRS.
Pursuant to § 7508A, the IRS has provided
relief to certain counties in the following
states:
Connecticut victims of March 2010
severe storms and flooding. See,News
ReleaseCT–2010–35, June 1, 2010.
Tennessee victims of April-May
2010 severe storms and flooding.
See,News ReleaseAL/TN–2010–56T,
May 5, 2010.
Alabama victims of April 2010 se-
vere storms and flooding. See,News
ReleaseAL/TN–2010–55A, May 4,
2010.
Mississippi victims of April 2010 se-
vere storms, tornadoes and flooding.
See,News ReleaseLA/MS–2010–21,
April 30, 2010.
New Jersey victims of March 2010
storms and flooding. See,News Re-
leaseNJ–2010–32, April 5, 2010.
Massachusetts victims of March
storms and flooding. See,News Re-
leaseMA–2010–15, March 31, 2010.
Rhode Island victims of March
storms and flooding. See,News Re-
leaseRI–2010–11, March 31, 2010.
West Virginia victims of March
storms and flooding. See,News Re-
leaseWVA–2010–12, March 31, 2010.
B. Provisions Relating to Defined
Contribution Pre-approved Plan
Program Adoption Deadlines
Revenue Procedure 2007–44, 2007–2
C.B. 54 (as modified by Rev. Proc.
2008–56, 2008–2 C.B. 826; Rev. Proc.
2009–36, 2009–35 I.R.B. 304; and Notice
2009–97, 2009–52 I.R.B. 972) and Rev.
Proc. 2005–16, 2005–1 C.B. 674, describe
a staggered remedial amendment system
for plans that are qualified under § 401(a)
of the Code, with five-year amendment/ap-
proval cycles for individually designed
plans and six-year cycles for pre-approved
plans. The submission period for the
initial cycle for pre-approved defined con-
tribution plans was February 17, 2005,
through January 31, 2006. Plan sponsors
and practitioners were required to restate
their pre-approved defined contribution
plans for the Economic Growth and Tax
Relief Reconciliation Act of 2001, Pub. L.
107–16, (EGTRRA) and Notice 2004–84,
2004–2 C.B. 1030 (the “2004 Cumulative
List”) and apply for new opinion or advi-
sory letters during that submission period.
Section 16.03 of Rev. Proc. 2007–44
provides that when the review of a cycle
for pre-approved plans has neared com-
pletion, the IRS will publish an announce-
ment providing the date by which adopting
employers must adopt the newly approved
plans. This date is intended to give adopt-
ing employers a period of approximately
two years in which to adopt the plans.
Announcement 2008–23, 2008–1 C.B.
731, provides the deadline by which adopt-
ing employers must adopt EGTRRA-ap-
proved M&P and VS defined contribution
plans. The two-year window in which to
adopt a pre-approved defined contribution
plan ended on April 30, 2010, and the Ser-
vice accepted applications for determina-
tion letters from May 1, 2008, through
April 30, 2010. Thus, the end of the six-
year remedial amendment cycle for pre-
approved defined contribution plans was
April 30, 2010.
III. RELIEF
A. Provision of Disaster Relief
Due to damage caused by the feder-
ally declared disasters identified in section
II.A. of this notice, employers that main-
tain M&P or VS defined contribution plans
may have missed the April 30, 2010, dead-
line to adopt an EGTRRA-approved M&P
or VS defined contribution plan and/or to
submit, if applicable, a determination letter
application to the IRS. As a result, the IRS
believes that it is appropriate to provide
an administrative extension to adversely
affected employers. Thus, the deadline
by which an employer that maintains an
Affected Plan (as defined in III.B.) must
adopt an EGTRRA-approved M&P or VS
defined contribution plan and submit a de-
termination letter application, if applica-
ble, is extended to July 30, 2010. The re-
medial amendment period is also extended
to July 30, 2010.
B. Definition of Affected Plan
A plan is an Affected Plan only if any
of the following locations relating to the
plan were in the federally declared disas-
ter areas (identified in section II.A. of this
notice) at the time of the disasters:
1. The principal place of business
of the employer that maintains the plan
(in the case of a single-employer plan,
determined by disregarding the rules of
§ 414(b) and (c) of the Code);
2. The principal place of business of
the employer that employs more than
50% of the active participants covered
by the plan (in the case of a plan cov-
ering employees of more than one em-
2010–27 I.R.B.9July 6, 2010

ployer, determined by disregarding the
rules of § 414(b) and (c));
3. The office of the plan or the plan
administrator;
4. The office of the primary record-
keeper serving the plan; or
5. The office of any advisor that had
been retained by the plan or the em-
ployer at the time of the storms or other
severe weather that is directly involved
with the adoption of the EGTRRA-ap-
proved M&P or VS defined contribu-
tion plan or that is directly involved in
submitting a determination letter appli-
cationtotheIRSbytheduedateof
April 30, 2010.
For purposes of items 3, 4, and 5,
above, the term “office” includes only the
worksite of those individuals, and the lo-
cation of any records, necessary to adopt
the EGTRRA-approved M&P or VS de-
fined contribution plan or to submit the
plan’s determination letter application to
the IRS.
IV. SUBMISSION OF A
DETERMINATION LETTER
APPLICATION
In addition to the general requirements
for submitting a determination letter ap-
plication set forth in Rev. Proc. 2010–6,
2010–1 I.R.B. 193, an employer submit-
ting a determination letter application pur-
suant to this notice should write “Exten-
sion Relief per Notice 2010–48” in the up-
per margin of the cover letter (do not write
this on the determination letter application
form).
V. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2007–44 is modified.
DRAFTING INFORMATION
The principal author of this notice is
Angelique Carrington of the Employee
Plans, Tax Exempt and Government
Entities Division. For further information
regarding this notice, please contact
the Employee Plans taxpayer assistance
answering service at 1–877–829–5500 (a
toll-free number) or e-mail Ms. Carrington
atRetirementPlanQuestions@irs.gov.
Request for Comments:
Modification to the
Regulations Under § 382
Regarding the Treatment of
Shareholders who are not
5-Percent Shareholders
Notice 2010–49
This notice invites public comments
relating to possible modifications to the
regulations under § 382 of the Internal
Revenue Code regarding the treatment of
shareholders who are not 5-percent share-
holders (Small Shareholders).
I. PURPOSE
The Internal Revenue Service (Service)
and Treasury Department (Treasury) are
currently considering modifying the regu-
lations under § 382. In particular, the Ser-
vice and Treasury are studying the opera-
tion of the rules relating to Small Share-
holders, including the application of the
aggregation and segregation rules to public
groups. This notice sets forth policy con-
siderations underlying § 382 and requests
comments on what modifications would
better reflect those policy considerations.
II. BACKGROUND
Section 382 provides special rules
for Small Shareholders.Under
§ 382(g)(4)(A), Small Shareholders are
aggregated and treated as one 5-per-
cent shareholder. Section 382(g)(4)(B),
however, requires that this aggregation
rule must be applied separately to Small
Shareholders of parties to certain § 368
reorganizations. Section 382(g)(4)(C)
broadens the scope of the segregation rule
of § 382(g)(4)(B) and provides that, ex-
cept as provided in the regulations, similar
segregation rules shall apply in determin-
ing whether there has been an owner shift
involving a 5-percent shareholder and
whether such shift (or a subsequent trans-
action) results in an ownership change.
III. POLICY CONSIDERATIONS
UNDERLYING § 382
The proper treatment of Small Share-
holders under § 382(g)(4)(C) depends
upon a determination concerning the pol-
icy considerations underlying § 382. This
request for comments describes two gen-
eral approaches, the Ownership Tracking
Approach and the Purposive Approach,
and sets forth some of the policy consider-
ations underlying each. Both approaches
recognize that one of the primary abuses
§ 382 seeks to prevent involves an acquisi-
tion of loss corporation stock followed by
the contribution of income-producing as-
sets or the diversion of income-producing
opportunities to the corporation. The two
approaches differ, however, in the extent
they seek to identify and limit their effect
to circumstances in which that abuse is
most likely to occur.
A. OWNERSHIP TRACKING
APPROACH
Under the Ownership Tracking Ap-
proach, it generally is of no significance
whether the shareholders who increase
their ownership are Small Shareholders
or 5-percent shareholders. This approach
ensures that abusive transactions are ad-
dressedbytrackingallchangesinown-
ership without regard to their particular
circumstances. Thus, any transaction that
allows the corporation to track the in-
crease in ownership interests held by Small
Shareholders results in the segregation
of Small Shareholders into a new pub-
lic group, which is treated as a 5-percent
shareholder. See § 1.382–2T(j)(3)(i) of
the Income Tax Regulations. The creation
of the new, segregated public group results
in an increase in ownership for that public
group. For example, if a 5-percent share-
holder sells stock to Small Shareholders,
these Small Shareholders are segregated
into a separate public group because it is
not unduly burdensome for the corpora-
tion to know that a 5-percent shareholder
has reduced its ownership and that owner-
ship interest has been acquired by Small
Shareholders. However, the Ownership
Tracking Approach makes a concession to
administrative convenience and acknowl-
edges that “public trading,” which is the
purchase by one Small Shareholder of
stock from another Small Shareholder,
should not be taken into account because
it is unduly burdensome for a corporation
to take into account all such transactions.
See § 1.382–2T(e)(1)(ii).
July 6, 2010102010–27 I.R.B.

B. PURPOSIVE APPROACH
Consistent with the purpose of § 382,
the Purposive Approach seeks to iden-
tify more specifically the circumstances
in which abuses are likely to arise. This
approach reflects the view that it is un-
necessary to take into account all read-
ily-identifiable acquisitions of stock by
Small Shareholders, because Small Share-
holders are generally not in a position to
acquire loss corporation stock in order
to contribute income-producing assets
or divert income-producing opportuni-
ties. Instead, if the Purposive Approach
is adopted, special rules generally could
provide for a lesser percentage change
in ownership for acquisitions of stock by
Small Shareholders.
C. CURRENT REGULATIONS UNDER
§382
The current regulations primarily re-
flect the Ownership Tracking Approach.
Although certain provisions may seem
to follow the Purposive Approach, their
justification is nevertheless based upon
the Ownership Tracking Approach. For
example, the cash issuance exception of
§ 1.382–3(j)(3) reduces the segregation
effect of an issuance of stock to Small
Shareholders by treating existing direct
public groups as buying some of the stock
sold in the issuance. However, this rule
is justified on the grounds that there is
likely to be substantial overlap between
Small Shareholders who acquire stock in
such an issuance and the existing Small
Shareholder ownership base.
D. OWNERSHIP TRACKING
APPROACH VERSUS PURPOSIVE
APPROACH
The different consequences of the two
approaches may be illustrated by the treat-
ment of 5-percent shareholders that ac-
quire stock from Small Shareholders, and
then sell the acquired stock back to Small
Shareholders.
Example (1).
Facts. All the stock of loss corporation is owned
by a single public group, Original Public Group. The
following acquisitions and dispositions each occur
during the testing period. First, Investor A acquires
10 percent of the corporation’s stock from Small
Shareholders, and sells it to Small Shareholders a
few months later. Second, Investor B acquires 10
percent of the stock from Small Shareholders, and
sells it a few months later to Small Shareholders.
Third, Investor C does the same.
Analysis.(i)Ownership Tracking Approach.
The regulations reflect the Ownership Tracking
Approach, and require the creation of a new, seg-
regated public group when each of Investors A, B
and C sells its stock back to Small Shareholders.
As a result, the loss corporation has four 5-percent
shareholders, Original Public Group and three new,
segregated public groups (New Public Group 1, New
Public Group 2, and New Public Group 3). Each
investor is treated as acquiring the loss corporation
stock proportionately from the direct public groups
that exist immediately before the acquisition. See
§ 1.382–2T(j)(2)(vi). Accordingly, New Public
Group 1, New Public Group 2, and New Public
Group 3, the only 5-percent shareholders whose
interests in loss corporation have increased during
the testing period, have increased their respective
ownership interest by 27.1 percent, in the aggregate
— from zero to 8.1 percent for New Public Group
1, from zero to 9 percent for New Public Group 2,
and from zero to 10 percent for New Public Group
3. This is so even though the stock is now, and at the
beginning of the testing period was, held 100 percent
by Small Shareholders, and even though no actual
5-percent shareholder everheld more than 10 percent
of the corporation’s stock. This treatment is justified
on the grounds that the corporation is able to track
each time a 5-percent shareholder sells stock to new
shareholders, including Small Shareholders.
(ii)Purposive Approach. Under the Purposive
Approach, the amount of change in ownership is dif-
ferent from the amount under the Ownership Track-
ing Approach. When each investor sells its shares to
Small Shareholders, the shares could be treated as be-
ing re-acquired by Original Public Group rather than
the new, segregated public groups. As a result, the
aggregate effect on the change in ownership is signif-
icantly reduced. Accordingly, Original Public Group
is treated as increasing its ownership interest from 90
percent to 100 percent during the testing period.
A full embrace of the Purposive Ap-
proach could go further. For example,
when Original Public Group acquires
shares from each investor, Original Public
Group could be treated, for testing dates
on or after such an acquisition, as having
owned them during the period they were
owned by the seller. Under such a rule,
there would have been no increase in own-
ership of any 5-percent shareholder during
the testing period. Instead, Original Public
Group would be treated, for testing dates
on or after its reacquisition of the shares
from the investors, as owning 100 percent
of the corporation during the entire period.
Such a result would be justified on the
grounds that where Small Shareholders
owned the shares at the beginning of the
testing period and on the last testing date,
no shareholder has increased its ownership
interest in such a way that would allow
it to engage in any abuse that § 382 was
enacted to prevent.
Example (2).
Facts.ThefactsarethesameasExample (1),ex-
cept each acquisition by Investors A, B, and C pre-
cedes all dispositions by the investors to Small Share-
holders.
Analysis.(i)Ownership Tracking Approach.The
results are the same as inExample (1).
(ii)Purposive Approach. Under a limited appli-
cation of the Purposive Approach, Original Public
Group would be treated as increasing its ownership
interest from 70 percent to 100 percent for an in-
crease of 30 percentage points. However, under an
expanded application of this principle, Original Pub-
lic Group could be treated as always having owned
the stock owned by Investors A, B, and C for testing
dates on or after the sales to Small Shareholders. Un-
der this rule, for testing dates on or after the reacquisi-
tion of the shares by Original Public Group from the
investors, there would have been no increase in the
ownership interest of any 5-percent shareholder dur-
ing the testing period.
Other transactions would also receive
different treatment under the Purposive
Approach. For example, when stock is
issued by a loss corporation, the stock
could be treated as being acquired by the
existing public group or groups, instead
of by a new, segregated public group.
Some type of look-back rule could also be
employed in this context to mitigate the
change in ownership that results from an
issuance to Small Shareholders. The ef-
fect of redemptions of stock held by Small
Shareholders under a Purposive Approach
would also be different from the treatment
of such transactions under the existing
regulations.
The complete adoption of a Purposive
Approach to public groups would require
significant changes to the existing regula-
tions. Alternatively, it may be appropri-
ate to adopt new rules reflecting the Pur-
posive Approach only for certain trans-
actions. For example, stock issuances,
which allow the loss corporation to re-
ceive additional income-producing capi-
tal, present concerns that shareholder-to-
shareholder sales do not.
The Service and Treasury are also
studying more modest changes. For ex-
ample, the cash issuance exception is
currently limited, as the name implies, to
issuances of stock for cash. Under con-
sideration is the possible expansion of
this rule to issuances for other property,
including the debt of the loss corporation.
The Service and Treasury also are con-
sidering whether it would be appropriate
to expand the small issuance exception
2010–27 I.R.B.11July 6, 2010

to exempt larger share issuances from the
application of the segregation rules.
IV. REQUEST FOR COMMENTS
The Service and Treasury request com-
ments concerning what modifications, if
any, to the existing rules for public groups
are appropriate, and an analysis of whether
authority exists for any recommended
changes. Comments are requested con-
cerning whether the regulations under
§ 382 should follow the Ownership Track-
ing Approach, Purposive Approach, or
another approach. Additionally, consistent
with an application of a Purposive Ap-
proach, comments are requested regarding
whether the look-through treatment of
first-tier and higher-tier entities should
be limited in cases where these entities
have a relatively small direct or indirect
investment in the loss corporation. Due
to the complexity of the existing regula-
tions under § 382, modifications to the
treatment of public groups would likely
raise questions regarding how such modi-
fications should be harmonized with other
rules. The Service and Treasury also re-
quest comments on the consequences of
any recommended modifications on these
questions.
Comments should be submitted by
September 9, 2010, and include a refer-
ence to Notice 2010–49. Send submis-
sions to Internal Revenue Service, Attn:
CC:PA:LPD:PR (Notice 2010–49), Room
5203, P.O. Box 7604, Ben Franklin Sta-
tion, Washington, D.C. 20044 or hand-de-
liver Monday through Friday between
the hours of 8:00 a.m. and 4:00 p.m. to
Courier’s Desk, Internal Revenue Service,
Attn: CC:PA:LPD:PR (Notice 2010–49),
1111 Constitution Avenue, N.W.,
Washington, D.C. 20044. Alternatively,
comments may be submitted electronically
via the following e-mail address:
Notice.Comments@irscounsel.treas.gov.
Please include “Notice 2010–49” in
the subject line. All comments will
be available for public inspection and
copying.
DRAFTING INFORMATION
The principal author of this notice is
Rubin B. Ranat of the Office of Associate
Chief Counsel (Corporate). For further
information regarding this notice, contact
Rubin B. Ranat at (202) 622–7530 (not a
toll-free call).
Section 382(l)(3)(C)
Fluctuations in Values
Notice 2010–50
This notice provides guidance under
§ 382 of the Internal Revenue Code for
measuring owner shifts of loss corpora-
tions that have more than one class of
stock outstanding, and, in particular, re-
garding the effect of fluctuations in the
value of one class of stock relative to an-
other class of stock (fluctuations in value).
It provides interim guidance to the effect
that the Internal Revenue Service (IRS)
will accept certain methodologies for tak-
ing into account or not taking into account
fluctuations in value, and identifies one
methodology that the IRS views as incon-
sistent with § 382(l)(3)(C). It also requests
comments to assist in the development
of future guidance. Any terms and defi-
nitions used in this notice have the same
meaningastheydoin§382andthe§382
regulations unless otherwise provided in
this notice.
I. Background
A.Overview of § 382(l)(3)(C)
Many of the critical determinations
under § 382 depend upon the value of
the stock owned by a particular share-
holder. For example, whether an own-
ership change under § 382(g) occurs de-
pends upon whether one or more 5-percent
shareholders have increased their owner-
ship in the loss corporation by more than
50 percentage points. Such ownership
determinations are by reference to value;
i.e., the relative fair market value of the
stock owned to the total fair market value
of the corporation’s outstanding stock.
See§ 1.382–2(a)(3)(i) of the Income Tax
Regulations.
Section 382(l)(3)(C) provides that, ex-
cept as provided in regulations, any change
in proportionate ownership of the stock
of a loss corporation attributable solely
to fluctuations in the relative fair market
values of different classes of stock shall
not be taken into account. The regula-
tions under § 382 do not provide any spe-
cific guidance on § 382(l)(3)(C). Instead,
§1.382–2T(l)setsforthaheadinganda
reservation: “Changes in Percentage Own-
ership which are attributable to fluctua-
tions in value.—[Reserved.]”
The Treasury Department (Treasury)
and the IRS are aware that taxpayers
employ a number of different method-
ologies in interpreting and applying
§ 382(l)(3)(C). For example, some tax-
payers have interpreted more general
provisions of the regulations to require the
valuation of all outstanding shares of stock
of a corporation on every testing date.See
§§ 1.382–2(a)(3)(i) and 1.382–2T(c)(1).
Under this interpretation, the effect of
§ 382(l)(3)(C) is limited to ensuring that a
testing date does not occur solely by virtue
of a fluctuation in the relative values of
different share classes. For purposes of
this notice, such a valuation of all shares
on every testing date is referred to as a
“Full Value Methodology.” Other taxpay-
ers have interpreted § 382(l)(3)(C) more
broadly, factoring out fluctuations in value
on a testing date based upon relative value
ratios among different classes of stock
established at the time a particular share of
stock was acquired. There are variations in
the methods that apply this view, described
in more detail below, but the essential
principle upon which the broader interpre-
tation is based is that, as to a particular
share, value ratios between and among
various classes of stock are fixed, or “held
constant,” on the date a particular share
is acquired (hereafter, the “Hold Constant
Principle,” or “HCP”). The remainder of
this section describes the government’s
understanding of the Full Value Methodol-
ogy, the Hold Constant Principle, and two
methodologies that implement the HCP.
B.Full Value Methodology
Under a Full Value Methodology, the
determination of the percentage of stock
owned by any person is made on the ba-
sis of the relative fair market value of the
stock owned by such person to the total
fair market value of the outstanding stock
of the corporation. Thus, changes in per-
centage ownership as a result of fluctua-
tions in value are taken into account if a
testing date occurs, regardless of whether
a particular shareholder actively partici-
pates or is otherwise party to the transac-
tion that causes the testing date to occur;
July 6, 2010122010–27 I.R.B.

essentially, all shares are “marked to mar-
ket” on each testing date.
Example 1. Upon formation, corporation X is-
sues $20 of convertible preferred stock to A and
issues two shares of common stock to B for $80,
such that A and B own 20 percent and 80 per-
cent, respectively, of X. The fortunes of X dete-
riorate, and, two years later, when the common
stock has a value of $2.50 per share and the pre-
ferred stock has a value of $20, B sells one share
of common stock to C. At the time of B’s sale to
C, X is a loss corporation. On that testing date,
A will be treated as increasing its proportionate
interest from 20 percent to 80 percent ($20/$25)
under the Full Value Methodology as a result of
the upward fluctuation in value of the preferred
stock relative to the common stock.
As Example 1 illustrates, an owner-
ship change under § 382 would occur as
a consequence of the sale of stock worth
10% of the loss corporation’s value be-
cause a stake originally representing 20%
of the corporation’s value has fluctuated
upward to 80% on the testing date, for a
cumulative shift of 70 percentage points.
The Full Value Methodology is a narrow
interpretation of § 382(l)(3)(C), but it may
be viewed as giving effect to the statutory
language by not requiring value marks
more frequently than each testing date
(e.g., daily fluctuations in value between
various classes are ignored, where such
fluctuations occur between testing dates).
C.Hold Constant Principle
Broadly stated, under the Hold Con-
stant Principle, the value of a share, rela-
tive to the value of all other stock of the
corporation, is established on the date that
share is acquired by a particular share-
holder. On subsequent testing dates, the
percentage interest represented by that
share (the “tested share”) is then deter-
mined by factoring out fluctuations in the
relative values of the loss corporation’s
share classes that have occurred since
the acquisition date of the tested share.
Thus, as applied, the HCP is individual-
ized for each acquisition of stock by each
shareholder. Moreover, the ownership
interest represented by a tested share is
adjusted for the dilutive effects of subse-
quent issuances and the accretive effects
of subsequent redemptions following the
tested share’s acquisition date.
Example 2. Upon formation, corporation X is-
sues $20 of convertible preferred stock to A and
issues two shares of common stock to B for $80,
such that A and B own 20 percent and 80 percent,
respectively, of X. The fortunes of X deteriorate,
and, two years later, when the common stock has
a value of $2.50 per share and the preferred stock
has a value of $20, B sells one share of common
stock to C. At the time of B’s sale to C, X is a
loss corporation. On that testing date, although A
actually owns 80% of the value of X, A will be
treated as owning 20% of the value of X for pur-
poses of § 382(g), under the Hold Constant Prin-
ciple.
As Example 2 illustrates, A would still
be treated as owning 20 percent of X on the
testing date because the HCP hypothesizes
that (for purposes of determining A’s per-
centage ownership) the common stock and
the preferred stock maintain the relative
values that existed on the acquisition date
of the tested share (here, each share held
by A). The only share that is “marked” to
value is the one share acquired by C, repre-
senting only 10% of the corporation’s eq-
uity value on the date of acquisition. Thus,
no ownership change under § 382 would
occur as a consequence of the acquisition
of that share by C. The Hold Constant Prin-
ciple may thus be viewed as giving effect
to the statutory language of § 382(l)(3)(C)
by factoring out fluctuations in the value of
stock held by passive shareholders across
multiple testing dates. The “factoring out”
process generally continues for a particular
share until the holder is no longer treated as
owning the tested share for § 382 purposes
(e.g., the holder engages in affirmative ac-
tivity such as a taxable sale). What follows
is a description of two methodologies that
implement the HCP.
1.Alternative Methodology 1: Look Back
from Testing Date
One methodology for implementing
the Hold Constant Principle is to re-
calculate the hold constant percentage
represented by a tested share to factor
out changes in its relative value since
the share’s acquisition date (hereafter,
“Alternative 1”). This methodology was
described by a commentator in 2005.See
generallyMark R. Hoffenberg, Owner
Shifts and Fluctuations in Value: A
Theory of Relativity, 106 Tax Notes
1446 (March 21, 2005). Generally, this
methodology calculates the percentage
interest represented by a tested share on
a testing date, beginning with the value
of the tested share on the testing date,
andthenmakingadjustmentsbasedon
the changes in relative value of the tested
sharetothevalueofallthestockofthe
loss corporation that have occurred since
the tested share’s acquisition date.
2.Alternative Methodology 2: Ongoing
Adjustments from Acquisition Date
The second methodology for imple-
menting the HCP tracks the percentage
interest represented by a tested share from
the date of acquisition forward, adjust-
ing for subsequent dispositions and for
the subsequent issuance or redemption of
other stock (hereafter, “Alternative 2”).
Generally, the increase in percentage own-
ership represented by the acquisition of a
tested share during the testing period is
established on the date the tested share is
acquired. This increase is reduced (but not
below zero) for subsequent dispositions
of shares by the owner. To the extent the
particular shareholder is not engaging in
acquisitions or dispositions, the percent-
age ownership calculation “rolls over”
from one testing date to another. Whereas
under Alternative 1, the loss corporation
generally determines the relative value
of shares of its stock at the beginning of
the testing period, or an earlier date, this
may not be necessary under Alternative
2. Thus, Alternative 2 may involve fewer
calculations on a particular testing date
than Alternative 1.
3.Common Elements of Both HCP
Methodologies
a.Acquisitions
Under either Alternative 1 or Alterna-
tive 2, the loss corporation determines, on
each testing date during a testing period,
the value of a tested share acquired on that
testing date as compared to the value of all
the stock of the loss corporation on that
date (i.e., neither alternative factors out
value fluctuations for actual acquisitions).
b.Dispositions and sourcing
Under either of the HCP alternative
methodologies, a shareholder’s increase
in proportionate interest during a testing
period will be reduced by share disposi-
tions. The government is aware of at least
two methods to account for dispositions
in such cases. One method may account
for the effect of a share disposition based
upon the percentage ownership that the
sold share represents on the date of its
disposition (as opposed to the percentage
represented by that share on its acquisition
date) (a “fair market value approach”).
2010–27 I.R.B.13July 6, 2010

Another method may account for the ef-
fect of a share disposition based upon
the percentage ownership that the sold
share represented on another testing date
during the testing period upon which the
selling shareholder acquired shares. As
one example, if the shares disposed of are
being offset against shares of another class
acquired during the testing period, the
percentage offset could be determined as
of the date the other class was acquired (a
“share equivalent approach”). The results
obtained would be as if sold shares were
converted into a share-equivalent number
of shares of the acquired class.
Example 3. A purchases 10 shares of X’s com-
mon stock for $10 on testing date 1, when each
share of common stock represents one percent of
X. X is a loss corporation. On testing date 1,
A also holds 2 shares of participating preferred
stock, with each share valued at $2 and each pre-
ferred share representing 2 percent of X. On test-
ing date 2, A disposes of one share of the pre-
ferred stock. Under a share-equivalent approach,
A may be considered to have disposed of two
shares of common stock, which is the common
share equivalent of one share of preferred stock
as determined on the acquisition date of the com-
mon stock.
If a taxpayer determines the effect of a
share disposition based upon the percent-
age represented by the sold share on the
share’s acquisition date, under either of
the two methodologies, the taxpayer must
also determine the source of shares dis-
posed of where a 5-percent shareholder
has had multiple acquisitions and disposi-
tions of loss corporation stock. For exam-
ple, tested shares of a single class likely
will represent different percentages of a
loss corporation depending upon when the
tested shares were acquired. In these cases,
taxpayers may treat sold shares as being
sourcedpro ratafrom all acquisitions, as
being sourced first from the most recent
acquisition (“LIFO”), or as being sourced
first from the first acquisition (“FIFO”).
c.Redemptions and issuances
Section 382 takes into account not
only trading in loss corporation shares,
but also the redemptions and issuances of
shares, for purposes of tracking changes in
percentage ownership by 5-percent share-
holders. For this purpose, a redemption
may be analogized to apro-rataacqui-
sition by non-redeeming shareholders of
the redeemed shares, while an issuance
may be analogized to apro-ratasale of
shares by shareholders holding stock im-
mediately before the issuance to those
shareholders acquiring shares in the is-
suance. There are a variety of possible
approaches in applying the HCP to stock
redemptions and issuances.
In a redemption, § 382 views the re-
maining shareholders as having acquired
a greater interest in the corporation with
respect to their shares held immediately
after the redemption. Applying the HCP,
the size of this acquisition for each share-
holder could be determined either by ref-
erence to current values at the time of
the redemption or relative values in effect
when the non-redeemed shareholders es-
tablished their positions.
In an issuance, § 382 views the inter-
est in the corporation held by pre-existing
shareholders with respect to their preexist-
ing shares as being reduced. In applying
the HCP, the effect of the issuance on pre-
existing shares, could also be determined
by reference to current or relative histori-
cal values.
Whether current or historical values are
used in determining the effect of subse-
quent redemptions or issuances can make
a substantial difference in the amount of
the owner shifts determined for 5-percent
shareholders. Moreover, even if histori-
cal values are used, the use of one HCP
alternative versus another can produce
differing results.See generallyNYSBA
Tax Section, Report on the Treatment
of Fluctuations in Value under Section
382(l)(3)(C), Dec. 22, 2009, reprinted
in 2009 TNT 245–16 (Example 5 in the
report).
Finally, §§ 1.382–3(j)(3) and (5) con-
tain a special rule for determining the
effects of certain cash issuances. Sections
1.382–3(j)(2) and (5) contain a special
rule for determining the effect of certain
small issuances. The issues discussed in
this notice are relevant in determining the
amount of exempted stock under the cash
issuance rule, and the allocation of ex-
empted stock among direct public groups
under both rules.
d.Non-disposition transactions
For purposes of applying a method
based on the HCP, an owner of loss corpo-
ration stock is not treated as disposing of or
acquiring loss corporation stock to the ex-
tent the owner remains treated as an owner
of the loss corporation, or its successor,
under § 382 and the regulations there-
under. See generally § 1.382–2T(h)(2)
(relating to constructive stock ownership);
§ 1.382–2T(f)(18)(iv) (stock of the loss
corporation, as the context may require, in-
cludes any indirect interest in the loss cor-
poration); § 1.382–2T(j)(2)(iii)(B)(1)(i)
(relating to equity structure shifts). In
these cases, the original acquisition date
and other hold constant characteristics
are preserved. Thus, for example, if a
shareholder exchanges loss corporation
stock for other loss corporation stock in a
value-for-value recapitalization, the stock
received in the exchange would retain the
same hold-constant characteristics as the
surrendered shares. This principle also
applies to reorganizations described in
§ 1.382–2T(j)(2)(iii)(B)(1)(i) and holding
company formations.
II. Guidance
Because of the complexity of the is-
sues involved in measuring owner shifts of
loss corporation stock where fluctuations
in value are present, the IRS and Trea-
sury have determined that it is appropriate
to accept taxpayers’ reasonable attempts
to measure increases in ownership where
fluctuations in value are present. Accord-
ingly, the IRS will not challenge any rea-
sonable application of either a Full Value
Methodology or the HCP, provided that a
single methodology (as described below)
is applied consistently to the extent re-
quired in this notice. The IRS and Trea-
sury believe that each of the HCP alterna-
tive methodologies discussed in section I
above-including the common elements of
both for dealing with various transactions
such as issuances and redemptions-are rea-
sonable applications of the HCP.
Taxpayers may rely on the guidance
provided in this notice until such time as
the IRS and Treasury issue additional guid-
ance under § 382(l)(3)(C).
A.Acquisitions
All reasonable applications of either the
Full Value Methodology or the HCP must
determine the increase in ownership rep-
resented by the acquisition of a share of
stockbydividingthefairmarketvalueof
that share on the acquisition date by the
fair market value of all of the outstand-
ing stock of the loss corporation on that
date. For this purpose, an acquisition does
July 6, 2010142010–27 I.R.B.

not include a deemed acquisition of stock
by non-redeeming shareholders resulting
from a redemption. In addition, under a
HCP methodology, an acquisition is not
an event upon which the acquiring share-
holder marks to fair market value other
shares that it holds.
However, the IRS and Treasury view
any alternative treatment of an acquisi-
tion as inconsistent with § 382(l)(3)(C).
For example, the IRS intends to challenge
a methodology that fixes the relative fair
market value of a class of preferred stock
to common stock on the issue date of the
preferred stock, regardless of the actual
value of either class on the subsequent date
that a shareholder whose percentage own-
ership is being computed acquires a share
of either such class of stock.
B.Consistency
In general, a taxpayer may employ any
methodology that is a reasonable applica-
tion of either a Full Value Methodology or
the HCP in determining when an owner-
ship change has occurred. For prior years,
a taxpayer may change its methodology by
amending returns. However, a taxpayer
must generally employ a single method-
ology consistently to all testing dates in
a “consistency period.” With respect to a
particular testing date (the “current testing
date”), the consistency period includes all
prior testing dates, beginning with the lat-
est of—
(1) the first date on which the taxpayer
had more than one class of stock;
(2) the first day following an ownership
change; or
(3) the date six years before the current
testing date.
In some cases, a methodology imple-
menting the HCP may treat as the acqui-
sitiondateforatestedshareadatethat
is later than the date the share was actu-
ally acquired. The issuance of a second
class of stock generally establishes the ac-
quisition date for the preexisting class as
well as the second class. Moreover, tax-
payers may substitute certain other dates,
if later, for the date shares were acquired,
such as, if used consistently: May 6, 1986;
January 1, 1987; or the beginning of the
testing period.
C.Closed Years
Notwithstanding the foregoing, a tax-
payer may not employ a methodology in a
year not barred by the statute of limitations
(an “open year”) if using that methodology
would have changed the taxpayer’s Fed-
eral income tax liability for a year barred
by the statute of limitations (a “closed
year”) in the consistency period, unless
the position taken in the closed year is not
consistent with any reasonable method-
ology. A taxpayer taking a position in
a closed year that is not consistent with
any reasonable methodology may adopt
any single methodology that is a reason-
able application of either the Full Value
Methodology or the HCP, regardless of
whether use of that methodology would
have changed its liability in a closed year,
provided that the adopted methodology is
applied consistently tothe greatest extent
permitted by the statute of limitations.
The effect of the consistency period rule
is that a taxpayer generally is free to adopt
any reasonable methodology as long any
inconsistent returns in the consistency pe-
riod can be and are amended. In addition,
there is no necessary correlation between
the start of a consistency period, which
governs the taxpayer’s choice of method-
ology, and the acquisition date for shares of
stock, which is an element of HCP method-
ologies.
D.Single Methodology
For purposes of this notice, a “sin-
gle methodology” means a methodology
that applies a consistent treatment to a
given situation, even on different testing
dates (e.g., applying a LIFO convention
for all share disposition sourcing deter-
minations if using an HCP alternative).
A single HCP methodology might treat
the accretive effect of redemptions differ-
ently from other acquisitions but should
not treat the dilutive effect of issuances
differently from other dispositions. To
determine the amount of exempted stock
pursuant to the cash issuance exception of
§ 1.382–3(j)(3), a taxpayer using an HCP
methodology may either use the hold con-
stant percentages determined for its direct
public groups under its methodology or
the percentages determined based upon
current values. Allocations of exempted
stock under § 1.382–3(j)(5) (relating to
the small issuance and cash issuance ex-
ceptions) should be determined under that
same methodology.
III. Request for Comments
TheIRSandTreasuryplantoissuepro-
posed or temporary regulations on the ap-
plication of § 382(l)(3)(C) in fluctuation in
value situations, and request comments on
that subject, including the issues addressed
in this notice.
A.Threshold Question
The threshold question is whether
interpreting § 382(l)(3)(C) broadly to re-
quire rules for factoring out fluctuations
in value, such as may be done through
methodologies employing the HCP, is ap-
propriate in light of the purposes of § 382
and administratively viable.
The primary purpose of § 382’s loss
limitation rules is to preserve the integrity
of the carryover provisions. The carryover
provisions perform a needed averaging
function by reducing distortions caused
by the annual accounting system. If car-
ryovers can be transferred in a way that
permits a loss to offset unrelated income,
no legitimate averaging function is per-
formed. The loss limitation rules of § 382
generally apply when shareholders who
bore the economic burden of a corpora-
tion’s pre-change loss no longer hold a
controlling interest in the corporation. In
such a case, the possibility arises that new
shareholders will contribute income pro-
ducing assets (or divert income producing
opportunities) to the loss corporation,
resulting in a greater utilization of the
loss corporation’s pre-change losses than
would have been the case had there been
no ownership change.SeeStaffofthe
Joint Comm. on Taxation, 100th Cong.,
1st Sess.,GeneralExplanationoftheTax
Reform Act of 1986288 (Comm. Print
1987).
The application of the HCP could result
in the avoidance of an ownership change,
even though the shareholders who did not
bear the economic burden of the loss cor-
poration’s pre-change loss have assumed
a controlling interest in the loss corpora-
tion. Consider, for example, a case in
which the value of a loss corporation’s
common stock declines steeply in rela-
tion to the relative value of its voting pre-
ferred stock, permitting preferred share-
2010–27 I.R.B.15July 6, 2010

holders who bought in with a 10 percent
interest (by value) to obtain a 90 percent
interest (by value), while being “held con-
stant” at 10 percent. In such a case, ar-
guably, there is the heightened possibil-
ity that a pre-change loss could be offset
against unrelated income. For example,
the preferred shareholders could enhance
their controlling position by causing a re-
capitalization in which they obtain the ma-
jority of the common stock and, thereby,
a significantly greaterpotential to partici-
pate in the growth of the company. There-
after, they could contribute income pro-
ducing assets (or built-in gain assets) to the
loss corporation in order to offset result-
ing income (or gain recognized) against
the corporation’s loss attributes (provided
the value of the stock issued in exchange
for the contributed assets was insufficient
to cause an ownership change). A simi-
lar opportunity to avoid the application of
§ 382 could present itself to shareholders
who bought the common stock when it rep-
resented 10 percent of the value of the loss
corporation, followed by a large upward
fluctuation in its relative value.
On the other hand, arguably Congress
enacted § 382(l)(3)(C) because it did not
view owner shifts and possibly ownership
changes attributable to valuation changes
with as much policy concern as it viewed
acquisitions. By limiting the operation
of the statute to testing dates, Congress
may have expressed a greater tolerance for
shifts in corporate ownership that would
have occurred even in the absence of
events giving rise to a testing date. In a
period of broad-based economic growth,
where all other factors are equal, it can
be expected that common stock will in-
crease in value relative to preferred stock,
which effect alone could result in owner
shifts and possibly ownership changes.
The converse result can be expected in a
period of broad-based economic contrac-
tion. Arguably, in most of such cases, the
shareholders considered to have acquired
a greater percentage of the loss corpora-
tion’s stock do not thereby have a greater
incentive to contribute income producing
assets to the loss corporation. The IRS and
Treasury appreciate any comments on this
threshold question.
B.Possible Application of the HCP
Part II of this notice permits broad ap-
plication of the HCP until such time as fu-
ture guidance is provided. If application
of the HCP is to be required or permit-
ted in future guidance, comments are re-
quested as to whether to continue to permit
the use of a range of methodologies to im-
plement the HCP (and, if so, how broad a
range) or to require that a particular HCP
methodology (or methodologies) be used.
The IRS and Treasury would appreciate
any comments regarding which methodol-
ogy or methodologies best implement the
HCP from the standpoint of theory, practi-
cality, and administrability.
Under an alternative approach, the HCP
could be applied only in limited circum-
stances, such as to protect a loss corpora-
tion’s ability, in the event of bankruptcy,
to make use of the special provisions of
§§ 382(l)(5) and (6). The IRS and Treasury
request comments on whether it would be
appropriate to limit the HCP to special cir-
cumstances and how the HCP might be ap-
plied in those situations.
Comments are also requested as to
the appropriate methodologies for deal-
ing with—(i) the deemed acquisition by
non-redeeming shareholders occurring as
a result of a redemption, (ii) the deemed
disposition by preexisting shareholders
occurring as a result of the issuance of
other shares, (iii) the amount of stock ex-
empt under the cash issuance exception
of § 1.382–3(j)(3), and (iv) the allocation
of exempt stock to direct public groups
under the cash and small issuance excep-
tions of § 1.382–3(j)(5). Comments are
requested as to the extent to which appro-
priate methodologies applied to the above
enumerated items ought to be applied con-
sistentlytosaiditems.
C.Instructions
Comments should include a refer-
ence to Notice 2010–50. Send sub-
missions to Internal Revenue Service,
Attn: CC:PA:LPD:PR Room 5203 (No-
tice 2010–50), P.O. Box 7604, Ben
Franklin Station, Washington, D.C.
20044 or hand-deliver comments Mon-
day through Friday between the hours
of 8:00 a.m. and 4:00 p.m. to Courier’s
Desk, Attn: CC:PA:LPD:PR Room 5203
(Notice 2010–50), Internal Revenue
Service, 1111 Constitution Avenue, NW,
Washington, DC 20224. Alternatively,
comments may be sent electronically
via the following email address:
Notice.Comments@irscounsel.treas.gov.
Please include the notice number 2010–50
in the subject line of any electronic
communication. All materials submitted
will be available for public inspection and
copying.
The principal author of this notice is
Keith E. Stanley of the Office of Associate
Chief Counsel (Corporate). For further
information regarding this notice, contact
Mr. Stanley at 202–622–7700 (not a
toll-free number).
26 CFR 601.201: Rulings and determination letters.
(Also: Part I, §§ 25, 103, 143.)
Rev. Proc. 2010–25
SECTION 1. PURPOSE
This revenue procedure provides is-
suers of qualified mortgage bonds, as
defined in section 143(a) of the Internal
Revenue Code, and issuers of mortgage
credit certificates, as defined in section
25(c), with (1) the nationwide average
purchase price for residences located in
the United States, and (2) average area
purchase price safe harbors for residences
located in statistical areas in each state,
the District of Columbia, Puerto Rico,
the Northern Mariana Islands, American
Samoa, the Virgin Islands, and Guam.
SECTION 2. BACKGROUND
.01 Section 103(a) provides that, except
as provided in section 103(b), gross in-
come does not include interest on any state
or local bond. Section 103(b)(1) provides
that section 103(a) shall not apply to any
private activity bond that is not a “qualified
bond” within the meaning of section 141.
Section 141(e) provides, in part, that the
term “qualified bond” means any private
activitybondifsuchbond(1)isaquali-
fied mortgage bond under section 143, (2)
meets the volume cap requirements under
section 146, and (3) meets the applicable
requirements under section 147.
.02 Section 143(a)(1) provides that the
term “qualified mortgage bond” means a
bond that is issued as part of a qualified
July 6, 2010162010–27 I.R.B.

mortgage issue. Section 143(a)(2)(A) pro-
vides that the term “qualified mortgage is-
sue” means an issue of one or more bonds
by a state or political subdivision thereof,
but only if: (i) all proceeds of the issue (ex-
clusive of issuance costs and a reasonably
required reserve) are to be used to finance
owner-occupied residences; (ii) the issue
meets the requirements of subsections (c),
(d), (e), (f), (g), (h), (i), and (m)(7) of sec-
tion 143; (iii) the issue does not meet the
private business tests of paragraphs (1) and
(2) of section 141(b); and (iv) with respect
to amounts received more than 10 years
after the date of issuance, repayments of
$250,000 or more of principal on mortgage
financing provided by the issue are used by
the close of the first semiannual period be-
ginning after the date the prepayment (or
complete repayment) is received to redeem
bonds that are part of the issue.
Average Area Purchase Price
.03 Section 143(e)(1) provides that an
issue of bonds meets the purchase price
requirements of section 143(e) if the ac-
quisition cost of each residence financed
by the issue does not exceed 90 percent of
the average area purchase price applicable
to such residence. Section 143(e)(5) pro-
vides that, in the case of a targeted area res-
idence (as defined in section 143(j)), sec-
tion 143(e)(1) shall be applied by substi-
tuting 110 percent for 90 percent.
.04 Section 143(e)(2) provides that the
term “average area purchase price” means,
with respect to any residence, the average
purchase price of single-family residences
(in the statistical area in which the resi-
dence is located) that were purchased dur-
ing the most recent 12-month period for
which sufficient statistical information is
available. Under sections 143(e)(3) and
(4), respectively, separate determinations
are to be made for new and existing resi-
dences, and for two-, three-, and four-fam-
ily residences.
.05 Section 143(e)(2) provides that the
determination of the average area purchase
price for a statistical area shall be made as
ofthedateonwhichthecommitmentto
provide the financing is made or, if earlier,
the date of the purchase of the residence.
.06 Section 143(k)(2)(A) provides that
the term “statistical area” means (i) a
metropolitan statistical area (MSA), and
(ii) any county (or the portion thereof)
that is not within an MSA. Section
143(k)(2)(C) further provides that if suf-
ficient recent statistical information with
respect to a county (or portion thereof)
is unavailable, the Secretary may sub-
stitute another area for which there is
sufficient recent statistical information for
such county (or portion thereof). In the
case of any portion of a State which is
not within a county, section 143(k)(2)(D)
provides that the Secretary may designate
as a county any area that is the equivalent
of a county. Section 6a.103A–1(b)(4)(i)
of the Temporary Income Tax Regulations
(issued under section 103A of the Internal
Revenue Code of 1954, the predecessor of
section 143) provides that the term “State”
includes a possession of the United States
and the District of Columbia.
.07 Section 6a.103A–2(f)(5)(i) pro-
vides that an issuer may rely upon the aver-
age area purchase price safe harbors pub-
lished by the Department of the Treasury
for the statistical areain which a residence
is located. Section 6a.103A–2(f)(5)(i)
further provides that an issuer may use
an average area purchase price limitation
different from the published safe harbor if
the issuer has more accurate and compre-
hensive data for the statistical area.
Qualified Mortgage Credit Certificate
Program
.08 Section 25(c) permits a state or
political subdivision to establish a quali-
fied mortgage credit certificate program.
In general, a qualified mortgage credit
certificate program is a program under
which the issuing authority elects not to
issue an amount of private activity bonds
that it may otherwise issue during the
calendar year under section 146, and in
their place, issues mortgage credit certifi-
cates to taxpayers in connection with the
acquisition of their principal residences.
Section 25(a)(1) provides, in general, that
the holder of a mortgage credit certificate
may claim a federal income tax credit
equal to the product of the credit rate
specified in the certificate and the interest
paid or accrued during the tax year on the
remaining principal of the indebtedness
incurred to acquire the residence. Section
25(c)(2)(A)(iii)(III) generally provides
that residences acquired in connection
with the issuance of mortgage credit cer-
tificates must meet the purchase price
requirements of section 143(e).
Income Limitations for Qualified
Mortgage Bonds and Mortgage Credit
Certificates
.09 Section 143(f) imposes limitations
on the income of mortgagors for whom
financing may be provided by qualified
mortgage bonds. In addition, section
25(c)(2)(A)(iii)(IV) provides that holders
of mortgage credit certificates must meet
the income requirement of section 143(f).
Generally, under sections 143(f)(1) and
25(c)(2)(A)(iii)(IV), the income require-
ment is met only if all owner-financing
under a qualified mortgage bond and all
mortgage credit certificates issued under a
qualified mortgage credit certificate pro-
gram are provided to mortgagors whose
family income is 115 percent or less of the
applicable median family income. Section
143(f)(5), however, generally provides
for an upward adjustment to the percent-
age limitation in high housing cost areas.
High housing cost areas are defined in
section 143(f)(5)(C) as any statistical area
for which the housing cost/income ratio is
greater than 1.2.
.10 Under section 143(f)(5)(D), the
housing cost/income ratio with respect to
any statistical area is determined by divid-
ing (a) the applicable housing price ratio
for such area by (b) the ratio that the area
median gross income for such area bears
to the median gross income for the United
States. The applicable housing price ratio
is the new housing price ratio (new hous-
ing average area purchase price divided by
the new housing average purchase price
for the United States) or the existing hous-
ing price ratio (existing housing average
area purchase price divided by the existing
housing average purchase price for the
United States), whichever results in the
housing cost/income ratio being closer to
1.
Average Area and Nationwide Purchase
Price Limitations
.11 Average area purchase price safe
harbors for each state, the District of Co-
lumbia, Puerto Rico, the Northern Mari-
ana Islands, American Samoa, the Virgin
Islands, and Guam were last published in
Rev. Proc. 2009–18, 2009–11 I.R.B. 686.
2010–27 I.R.B.17July 6, 2010

.12 The nationwideaverage purchase
price limitation was last published in
section 4.02 of Rev. Proc. 2009–18.
Guidance with respect to the United States
and area median grossincome figures that
aretobeusedincomputingthehousing
cost/income ratio described in section
143(f)(5) was last published in Rev. Proc.
2010–23, 2010–24 I.R.B. 762.
.13 This revenue procedure uses FHA
loan limits for a given statistical area to
calculate the average area purchase price
safe harbor for that area. FHA sets lim-
its on the dollar value of loans it will in-
sure based on median home prices and
conforming loan limits established by the
Federal Home Loan Mortgage Corpora-
tion. In particular, FHA sets an area’s loan
limit at 95 percent of the median home
sales price for the area, subject to certain
floors and caps measured against conform-
ing loan limits.
.14 To calculate the average area pur-
chase price safe harbors in this revenue
procedure, the FHA loan limits are ad-
justed to take into account the differences
between average and median purchase
prices. Because FHA loan limits do not
differentiate between new and existing
residences, this revenue procedure con-
tains a single average area purchase price
safe harbor for both new and existing
residences in a statistical area. The Trea-
sury Department and the Internal Revenue
Service have determined that FHA loan
limits provide a reasonable basis for de-
termining average area purchase price
safe harbors. If the Treasury Department
and the Internal Revenue Service become
aware of other sources of average purchase
price data, including data that differentiate
between new and existing residences, con-
sideration will be given as to whether such
data provide a more accurate method for
calculating average area purchase price
safe harbors.
.15 The average area purchase price
safeharborslistedinsection4.01ofthis
revenue procedure are based on FHA loan
limits released November 25, 2009. FHA
loan limits are available for statistical ar-
eas in each state, the District of Columbia,
Puerto Rico, the Northern Mariana Islands,
American Samoa, the Virgin Islands, and
Guam. See section 3.03 of this revenue
procedure with respect to FHA loan lim-
its revised after November 25, 2009.
.16 OMB Bulletin No. 03–04, dated
and effective June 6, 2003, revised the def-
initions of the nation’s metropolitan areas
and recognized 49 new metropolitan sta-
tistical areas. The OMB bulletin no longer
includes primary metropolitan statistical
areas.
SECTION 3. APPLICATION
Average Area Purchase Price Safe
Harbors
.01 Average area purchase price safe
harbors for statistical areas in each state,
the District of Columbia, Puerto Rico,
the Northern Mariana Islands, American
Samoa, the Virgin Islands, and Guam are
set forth in section 4.01 of this revenue
procedure. Average area purchase price
safe harbors are provided for single-family
and two to four-family residences. For
each type of residence, section 4.01 of this
revenue procedure contains a single safe
harbor that may be used for both new and
existing residences. Issuers of qualified
mortgage bonds and issuers of mortgage
credit certificates may rely on these safe
harbors to satisfy the requirements of sec-
tions 143(e) and (f). Section 4.01 of this
revenue procedure provides safe harbors
for MSAs and for certain counties and
county equivalents. If no purchase price
safe harbor is available for a statistical
area, the safe harbor for “ALL OTHER
AREAS” may be used for that statistical
area.
.02IfaresidenceisinanMSA,thesafe
harbor applicable to it is the limitation of
that MSA. If an MSA falls in more than
one state, the MSA is listed in section 4.01
of this revenue procedure under each state.
.03 If the FHA revises the FHA loan
limit for any statistical area after Novem-
ber 25, 2009, an issuer of qualified mort-
gage bonds or mortgage credit certificates
may use the revised FHA loan limit for that
statistical area to compute (as provided in
the next sentence) a revised average area
purchase price safe harbor for the statisti-
cal area provided that the issuer maintains
records evidencing the revised FHA loan
limit. The revised average area purchase
price safe harbor for that statistical area
is computed by dividing the revised FHA
loan limit by 1.00.
.04 If, pursuant to section
6a.103A–2(f)(5)(i), an issuer uses more
accurate and comprehensive data to
determine the average area purchase price
for a statistical area, the issuer must make
separate average area purchase price
determinations for new and existing resi-
dences. Moreover, when computing the
average area purchase price for a statistical
area that is an MSA, as defined in OMB
Bulletin No. 03–04, the issuer must make
the computation for the entire applicable
MSA. When computing the average area
purchase price for a statistical area that
is not an MSA, the issuer must make the
computation for the entire statistical area
and may not combine statistical areas.
Thus, for example, the issuer may not
combine two or more counties.
.05 If an issuer receives a ruling permit-
ting it to rely on an average area purchase
price limitation that is higher than the
applicable safe harbor in this revenue
procedure, the issuer may rely on that
higher limitation for the purpose of satis-
fying the requirements of section 143(e)
and (f) for bonds sold, and mortgage
credit certificates issued, not more than 30
months following the termination date of
the12-monthperiodusedbytheissuerto
compute the limitation.
Nationwide Average Purchase Price
.06 Section 4.02 of this revenue proce-
dure sets forth a single nationwide average
purchase price for purposes of computing
the housing cost/income ratio under sec-
tion 143(f)(5).
.07 Issuers must use the nationwide av-
erage purchase price set forth in section
4.02 of this revenue procedure when com-
puting the housing cost/income ratio un-
der section 143(f)(5) regardless of whether
they are relying on the average area pur-
chase price safe harbors contained in this
revenue procedure or using more accurate
and comprehensive data to determine av-
erage area purchase prices for new and ex-
isting residences for a statistical area that
are different from the published safe har-
bors in this revenue procedure.
.08 If, pursuant to section 6.02 of this
revenue procedure, an issuer relies on the
average area purchase price safe harbors
contained in Rev. Proc. 2009–18, the is-
suer must use the nationwide average pur-
chase price set forth in section 4.02 of Rev.
Proc. 2009–18 in computing the housing
cost/income ratio under section 143(f)(5).
July 6, 2010182010–27 I.R.B.

Likewise, if, pursuant to section 6.05 of
this revenue procedure, an issuer relies
on the nationwide average purchase price
published in Rev. Proc. 2009–18, the is-
suer may not rely on the average area pur-
chase price safe harbors published in this
revenue procedure.
SECTION 4. AVERAGE AREA AND
NATIONWIDE AVERAGE PURCHASE
PRICES
.01 Average area purchase prices for
single-family and two to four-family res-
idences in MSAs, and for certain counties
and county equivalents are set forth below.
The safe harbor for “ALL OTHER AR-
EAS” (found at the end of the table below)
may be used for a statistical area that is not
listed below.
2010 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameStateOne-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
VALDEZ-CORDOVAAK
$271,400$347,450$419,950$521,900
NORTH SLOPEAK
$307,050$393,050$475,150$590,500
WRANGELL-PETERSAK
$307,050$393,050$475,150$590,500
VALDEZ-CORDOVAAK
$271,400$347,450$419,950$521,900
NORTH SLOPEAK
$307,050$393,050$475,150$590,500
WRANGELL-PETERSAK
$307,050$393,050$475,150$590,500
DENALIAK
$316,250$404,850$489,350$608,150
FAIRBANKS NORTHAK
$316,250$404,850$489,350$608,150
KETCHIKAN GATEWAK
$322,000$412,200$498,250$619,250
KODIAK ISLANDAK
$322,000$412,200$498,250$619,250
DILLINGHAMAK
$332,500$425,650$514,500$639,400
ANCHORAGEAK
$347,500$444,850$537,750$668,250
MATANUSKA-SUSITAK
$347,500$444,850$537,750$668,250
ALEUTIANS WESTAK
$356,500$456,350$551,650$685,550
YAKUTAT CITYAK
$388,700$497,600$601,500$747,500
JUNEAUAK
$398,750$510,450$617,050$766,850
SITKAAK
$431,250$552,050$667,350$829,350
BALDWINAL
$285,000$364,850$441,000$548,050
RUSSELLAL
$289,800$371,000$448,450$557,300
APACHEAZ
$281,250$360,050$435,200$540,850
NAVAJOAZ
$308,750$395,250$477,750$593,750
PIMAAZ
$316,250$404,850$489,350$608,150
MOHAVEAZ
$322,500$412,850$499,050$620,200
GILAAZ
$325,000$416,050$502,900$625,000
MARICOPAAZ
$346,250$443,250$535,800$665,850
PINALAZ
$346,250$443,250$535,800$665,850
YAVAPAIAZ
$390,000$499,250$603,500$750,000
COCONINOAZ
$450,000$576,050$696,350$865,400
2010–27 I.R.B.19July 6, 2010

LASSENCA
$285,000$364,850$441,000$548,050
GLENNCA
$287,500$368,050$444,900$552,900
SISKIYOUCA
$293,750$376,050$454,550$564,900
SIERRACA
$304,750$390,100$471,550$586,050
DEL NORTECA
$311,250$398,450$481,650$598,550
TEHAMACA
$312,500$400,050$483,550$600,950
IMPERIALCA
$325,000$416,050$502,900$625,000
KINGSCA
$325,000$416,050$502,900$625,000
TULARECA
$325,000$416,050$502,900$625,000
KERNCA
$368,750$472,050$570,600$709,150
FRESNOCA
$381,250$488,050$589,950$733,150
HUMBOLDTCA
$393,750$504,050$609,300$757,200
COLUSACA
$397,500$508,850$615,100$764,400
BUTTECA
$400,000$512,050$618,950$769,250
LAKECA
$401,250$513,650$620,900$771,650
PLUMASCA
$410,000$524,850$634,450$788,450
MARIPOSACA
$412,500$528,050$638,300$793,250
SHASTACA
$423,750$542,450$655,700$814,900
STANISLAUSCA
$423,750$542,450$655,700$814,900
MADERACA
$425,000$544,050$657,650$817,300
SUTTERCA
$425,000$544,050$657,650$817,300
YUBACA
$425,000$544,050$657,650$817,300
INYOCA
$437,500$560,050$677,000$841,350
TUOLUMNECA
$437,500$560,050$677,000$841,350
AMADORCA
$443,750$568,050$686,650$853,350
CALAVERASCA
$462,500$592,050$715,700$889,450
MERCEDCA
$472,500$604,900$731,150$908,650
SAN JOAQUINCA
$488,750$625,700$756,300$939,900
RIVERSIDECA
$500,000$640,100$773,700$961,550
SAN BERNARDINOCA
$500,000$640,100$773,700$961,550
MENDOCINOCA
$512,500$656,100$793,050$985,600
MONOCA
$529,000$677,200$818,600$1,017,300
ALPINECA
$547,500$700,900$847,200$1,052,900
SOLANOCA
$557,500$713,700$862,700$1,072,150
NEVADACA
$562,500$720,100$870,450$1,081,750
EL DORADOCA
$580,000$742,500$897,500$1,115,400
PLACERCA
$580,000$742,500$897,500$1,115,400
SACRAMENTOCA
$580,000$742,500$897,500$1,115,400
YOLOCA
$580,000$742,500$897,500$1,115,400
July 6, 2010202010–27 I.R.B.

SONOMACA
$662,500$848,100$1,025,200$1,274,050
SAN LUIS OBISPOCA
$687,500$880,100$1,063,850$1,322,150
SAN DIEGOCA
$697,500$892,950$1,079,350$1,341,350
ALAMEDACA
$729,750$934,200$1,129,250$1,403,400
CONTRA COSTACA
$729,750$934,200$1,129,250$1,403,400
LOS ANGELESCA
$729,750$934,200$1,129,250$1,403,400
MARINCA
$729,750$934,200$1,129,250$1,403,400
MONTEREYCA
$729,750$934,200$1,129,250$1,403,400
NAPACA
$729,750$934,200$1,129,250$1,403,400
ORANGECA
$729,750$934,200$1,129,250$1,403,400
SAN BENITOCA
$729,750$934,200$1,129,250$1,403,400
SAN FRANCISCOCA
$729,750$934,200$1,129,250$1,403,400
SAN MATEOCA
$729,750$934,200$1,129,250$1,403,400
SANTA BARBARACA
$729,750$934,200$1,129,250$1,403,400
SANTA CLARACA
$729,750$934,200$1,129,250$1,403,400
SANTA CRUZCA
$729,750$934,200$1,129,250$1,403,400
VENTURACA
$729,750$934,200$1,129,250$1,403,400
CHAFFEECO
$280,000$358,450$433,250$538,450
MINERALCO
$300,000$384,050$464,200$576,900
LARIMERCO
$312,500$400,050$483,550$600,950
ARCHULETACO
$317,500$406,450$491,300$610,550
EL PASOCO
$325,000$416,050$502,900$625,000
TELLERCO
$325,000$416,050$502,900$625,000
GRANDCO
$356,250$456,050$551,250$685,100
MESACO
$371,250$475,250$574,500$713,950
ADAMSCO
$406,250$520,050$628,650$781,250
ARAPAHOECO
$406,250$520,050$628,650$781,250
BROOMFIELDCO
$406,250$520,050$628,650$781,250
CLEAR CREEKCO
$406,250$520,050$628,650$781,250
DENVERCO
$406,250$520,050$628,650$781,250
DOUGLASCO
$406,250$520,050$628,650$781,250
ELBERTCO
$406,250$520,050$628,650$781,250
GILPINCO
$406,250$520,050$628,650$781,250
JEFFERSONCO
$406,250$520,050$628,650$781,250
PARKCO
$406,250$520,050$628,650$781,250
WELDCO
$417,500$534,450$646,050$802,900
GARFIELDCO
$425,000$544,050$657,650$817,300
SAN JUANCO
$425,000$544,050$657,650$817,300
2010–27 I.R.B.21July 6, 2010

GUNNISONCO
$433,750$555,250$671,200$834,150
LA PLATACO
$443,750$568,050$686,650$853,350
BOULDERCO
$460,000$588,850$711,800$884,600
OURAYCO
$482,500$617,700$746,650$927,900
HINSDALECO
$557,500$713,700$862,700$1,072,150
SAN MIGUELCO
$651,250$833,700$1,007,750$1,252,400
ROUTTCO
$675,000$864,100$1,044,550$1,298,100
EAGLECO
$729,750$934,200$1,129,250$1,403,400
LAKECO
$729,750$934,200$1,129,250$1,403,400
PITKINCO
$729,750$934,200$1,129,250$1,403,400
SUMMITCO
$729,750$934,200$1,129,250$1,403,400
WINDHAMCT
$272,500$348,850$421,650$524,050
LITCHFIELDCT
$375,000$480,050$580,300$721,150
NEW HAVENCT
$387,500$496,050$599,600$745,200
NEW LONDONCT
$398,750$510,450$617,050$766,850
HARTFORDCT
$440,000$563,250$680,850$846,150
MIDDLESEXCT
$440,000$563,250$680,850$846,150
TOLLANDCT
$440,000$563,250$680,850$846,150
FAIRFIELDCT
$708,750$907,350$1,096,750$1,363,000
DISTRICT OF COLDC
$729,750$934,200$1,129,250$1,403,400
SUSSEXDE
$375,000$480,050$580,300$721,150
KENTDE
$376,250$481,650$582,200$723,550
NEW CASTLEDE
$420,000$537,650$649,900$807,700
SUMTERFL
$278,750$356,850$431,350$536,050
INDIAN RIVERFL
$283,750$363,250$439,050$545,650
FLAGLERFL
$287,500$368,050$444,900$552,900
BREVARDFL
$291,250$372,850$450,700$560,100
HERNANDOFL
$292,500$374,450$452,600$562,500
HILLSBOROUGHFL
$292,500$374,450$452,600$562,500
PASCOFL
$292,500$374,450$452,600$562,500
PINELLASFL
$292,500$374,450$452,600$562,500
CHARLOTTEFL
$296,250$379,250$458,400$569,700
VOLUSIAFL
$303,750$388,850$470,000$584,150
FRANKLINFL
$305,000$390,450$471,950$586,550
OKALOOSAFL
$312,500$400,050$483,550$600,950
July 6, 2010222010–27 I.R.B.

LAKEFL
$353,750$452,850$547,400$680,300
ORANGEFL
$353,750$452,850$547,400$680,300
OSCEOLAFL
$353,750$452,850$547,400$680,300
SEMINOLEFL
$353,750$452,850$547,400$680,300
LEEFL
$356,250$456,050$551,250$685,100
WALTONFL
$362,790$464,400$561,400$697,650
MARTINFL
$375,000$480,050$580,300$721,150
ST. LUCIEFL
$375,000$480,050$580,300$721,150
BAKERFL
$387,500$496,050$599,600$745,200
CLAYFL
$387,500$496,050$599,600$745,200
DUVALFL
$387,500$496,050$599,600$745,200
NASSAUFL
$387,500$496,050$599,600$745,200
ST. JOHNSFL
$387,500$496,050$599,600$745,200
BAYFL
$396,250$507,250$613,150$762,000
BROWARDFL
$423,750$542,450$655,700$814,900
MIAMI-DADEFL
$423,750$542,450$655,700$814,900
PALM BEACHFL
$423,750$542,450$655,700$814,900
MANATEEFL
$442,500$566,450$684,750$850,950
SARASOTAFL
$442,500$566,450$684,750$850,950
COLLIERFL
$531,250$680,100$822,050$1,021,650
MONROEFL
$729,750$934,200$1,129,250$1,403,400
BRANTLEYGA
$276,250$353,650$427,450$531,250
GLYNNGA
$276,250$353,650$427,450$531,250
MCINTOSHGA
$276,250$353,650$427,450$531,250
CHATTAHOOCHEEGA
$289,800$371,000$448,450$557,300
HARRISGA
$289,800$371,000$448,450$557,300
MARIONGA
$289,800$371,000$448,450$557,300
MUSCOGEEGA
$289,800$371,000$448,450$557,300
CLARKEGA
$298,750$382,450$462,300$574,500
MADISONGA
$298,750$382,450$462,300$574,500
OCONEEGA
$298,750$382,450$462,300$574,500
OGLETHORPEGA
$298,750$382,450$462,300$574,500
BARROWGA
$346,250$443,250$535,800$665,850
BARTOWGA
$346,250$443,250$535,800$665,850
BUTTSGA
$346,250$443,250$535,800$665,850
CARROLLGA
$346,250$443,250$535,800$665,850
CHEROKEEGA
$346,250$443,250$535,800$665,850
CLAYTONGA
$346,250$443,250$535,800$665,850
2010–27 I.R.B.23July 6, 2010

COBBGA
$346,250$443,250$535,800$665,850
COWETAGA
$346,250$443,250$535,800$665,850
DAWSONGA
$346,250$443,250$535,800$665,850
DEKALBGA
$346,250$443,250$535,800$665,850
DOUGLASGA
$346,250$443,250$535,800$665,850
FAYETTEGA
$346,250$443,250$535,800$665,850
FORSYTHGA
$346,250$443,250$535,800$665,850
FULTONGA
$346,250$443,250$535,800$665,850
GWINNETTGA
$346,250$443,250$535,800$665,850
HARALSONGA
$346,250$443,250$535,800$665,850
HEARDGA
$346,250$443,250$535,800$665,850
HENRYGA
$346,250$443,250$535,800$665,850
JASPERGA
$346,250$443,250$535,800$665,850
LAMARGA
$346,250$443,250$535,800$665,850
MERIWETHERGA
$346,250$443,250$535,800$665,850
NEWTONGA
$346,250$443,250$535,800$665,850
PAULDINGGA
$346,250$443,250$535,800$665,850
PICKENSGA
$346,250$443,250$535,800$665,850
PIKEGA
$346,250$443,250$535,800$665,850
ROCKDALEGA
$346,250$443,250$535,800$665,850
SPALDINGGA
$346,250$443,250$535,800$665,850
WALTONGA
$346,250$443,250$535,800$665,850
GREENEGA
$662,500$848,100$1,025,200$1,274,050
HAWAIIHI
$618,750$792,100$957,500$1,189,900
KALAWAOHI
$716,250$916,950$1,108,350$1,377,450
HONOLULUHI
$793,750$1,016,150$1,228,300$1,526,450
MAUIHI
$790,000$1,011,350$1,222,500$1,519,250
KAUAIHI
$773,750$990,550$1,197,350$1,488,000
ADAMSID
$273,750$350,450$423,600$526,450
KOOTENAIID
$286,250$366,450$442,950$550,450
ADAID
$303,750$388,850$470,000$584,150
BOISEID
$303,750$388,850$470,000$584,150
CANYONID
$303,750$388,850$470,000$584,150
GEMID
$303,750$388,850$470,000$584,150
OWYHEEID
$303,750$388,850$470,000$584,150
VALLEYID
$462,500$592,050$715,700$889,450
TETONID
$693,750$888,100$1,073,550$1,334,150
July 6, 2010242010–27 I.R.B.

BLAINEID
$729,750$934,200$1,129,250$1,403,400
BONDIL
$281,250$360,050$435,200$540,850
CALHOUNIL
$281,250$360,050$435,200$540,850
CLINTONIL
$281,250$360,050$435,200$540,850
JERSEYIL
$281,250$360,050$435,200$540,850
MACOUPINIL
$281,250$360,050$435,200$540,850
MADISONIL
$281,250$360,050$435,200$540,850
MONROEIL
$281,250$360,050$435,200$540,850
ST. CLAIRIL
$281,250$360,050$435,200$540,850
BOONEIL
$339,250$434,300$524,950$652,400
WINNEBAGOIL
$339,250$434,300$524,950$652,400
COOKIL
$410,000$524,850$634,450$788,450
DEKALBIL
$410,000$524,850$634,450$788,450
DUPAGEIL
$410,000$524,850$634,450$788,450
GRUNDYIL
$410,000$524,850$634,450$788,450
KANEIL
$410,000$524,850$634,450$788,450
KENDALLIL
$410,000$524,850$634,450$788,450
LAKEIL
$410,000$524,850$634,450$788,450
MCHENRYIL
$410,000$524,850$634,450$788,450
WILLIL
$410,000$524,850$634,450$788,450
CLARKIN
$302,500$387,250$468,100$581,750
FLOYDIN
$302,500$387,250$468,100$581,750
HARRISONIN
$302,500$387,250$468,100$581,750
WASHINGTONIN
$302,500$387,250$468,100$581,750
DEARBORNIN
$337,500$432,050$522,250$649,050
FRANKLININ
$337,500$432,050$522,250$649,050
OHIOIN
$337,500$432,050$522,250$649,050
JASPERIN
$410,000$524,850$634,450$788,450
LAKEIN
$410,000$524,850$634,450$788,450
NEWTONIN
$410,000$524,850$634,450$788,450
PORTERIN
$410,000$524,850$634,450$788,450
BULLITTKY
$302,500$387,250$468,100$581,750
HENRYKY
$302,500$387,250$468,100$581,750
JEFFERSONKY
$302,500$387,250$468,100$581,750
MEADEKY
$302,500$387,250$468,100$581,750
NELSONKY
$302,500$387,250$468,100$581,750
2010–27 I.R.B.25July 6, 2010

OLDHAMKY
$302,500$387,250$468,100$581,750
SHELBYKY
$302,500$387,250$468,100$581,750
SPENCERKY
$302,500$387,250$468,100$581,750
TRIMBLEKY
$302,500$387,250$468,100$581,750
BOONEKY
$337,500$432,050$522,250$649,050
BRACKENKY
$337,500$432,050$522,250$649,050
CAMPBELLKY
$337,500$432,050$522,250$649,050
GALLATINKY
$337,500$432,050$522,250$649,050
GRANTKY
$337,500$432,050$522,250$649,050
KENTONKY
$337,500$432,050$522,250$649,050
PENDLETONKY
$337,500$432,050$522,250$649,050
ASCENSIONLA
$280,000$358,450$433,250$538,450
EAST BATON ROUGLA
$280,000$358,450$433,250$538,450
EAST FELICIANALA
$280,000$358,450$433,250$538,450
IBERVILLELA
$280,000$358,450$433,250$538,450
LIVINGSTONLA
$280,000$358,450$433,250$538,450
POINTE COUPEELA
$280,000$358,450$433,250$538,450
ST. HELENALA
$280,000$358,450$433,250$538,450
WEST BATON ROUGLA
$280,000$358,450$433,250$538,450
WEST FELICIANALA
$280,000$358,450$433,250$538,450
JEFFERSONLA
$287,500$368,050$444,900$552,900
ORLEANSLA
$287,500$368,050$444,900$552,900
PLAQUEMINESLA
$287,500$368,050$444,900$552,900
ST. BERNARDLA
$287,500$368,050$444,900$552,900
ST. CHARLESLA
$287,500$368,050$444,900$552,900
ST. JOHN THE BALA
$287,500$368,050$444,900$552,900
ST. TAMMANYLA
$287,500$368,050$444,900$552,900
FRANKLINMA
$318,750$408,050$493,250$613,000
HAMPDENMA
$318,750$408,050$493,250$613,000
HAMPSHIREMA
$318,750$408,050$493,250$613,000
WORCESTERMA
$385,000$492,850$595,750$740,400
BARNSTABLEMA
$462,500$592,050$715,700$889,450
BRISTOLMA
$475,000$608,100$735,050$913,450
ESSEXMA
$523,750$670,500$810,450$1,007,200
MIDDLESEXMA
$523,750$670,500$810,450$1,007,200
NORFOLKMA
$523,750$670,500$810,450$1,007,200
PLYMOUTHMA
$523,750$670,500$810,450$1,007,200
July 6, 2010262010–27 I.R.B.

SUFFOLKMA
$523,750$670,500$810,450$1,007,200
DUKESMA
$729,750$934,200$1,129,250$1,403,400
NANTUCKETMA
$729,750$934,200$1,129,250$1,403,400
SOMERSETMD
$328,750$420,850$508,700$632,200
WICOMICOMD
$328,750$420,850$508,700$632,200
KENTMD
$343,750$440,050$531,900$661,050
WASHINGTONMD
$377,500$483,250$584,150$725,950
ST. MARY’SMD
$400,000$512,050$618,950$769,250
CECILMD
$420,000$537,650$649,900$807,700
GARRETTMD
$437,500$560,050$677,000$841,350
WORCESTERMD
$437,500$560,050$677,000$841,350
TALBOTMD
$443,750$568,050$686,650$853,350
ANNE ARUNDELMD
$560,000$716,900$866,550$1,076,950
BALTIMOREMD
$560,000$716,900$866,550$1,076,950
BALTIMORE CITYMD
$560,000$716,900$866,550$1,076,950
CARROLLMD
$560,000$716,900$866,550$1,076,950
HARFORDMD
$560,000$716,900$866,550$1,076,950
HOWARDMD
$560,000$716,900$866,550$1,076,950
QUEEN ANNE’SMD
$560,000$716,900$866,550$1,076,950
CALVERTMD
$729,750$934,200$1,129,250$1,403,400
CHARLESMD
$729,750$934,200$1,129,250$1,403,400
FREDERICKMD
$729,750$934,200$1,129,250$1,403,400
MONTGOMERYMD
$729,750$934,200$1,129,250$1,403,400
PRINCE GEORGE’SMD
$729,750$934,200$1,129,250$1,403,400
HANCOCKME
$272,500$348,850$421,650$524,050
KNOXME
$279,450$357,750$432,400$537,400
LINCOLNME
$318,750$408,050$493,250$613,000
CUMBERLANDME
$337,500$432,050$522,250$649,050
SAGADAHOCME
$337,500$432,050$522,250$649,050
YORKME
$337,500$432,050$522,250$649,050
KALAMAZOOMI
$286,250$366,450$442,950$550,450
VAN BURENMI
$286,250$366,450$442,950$550,450
LAPEERMI
$297,500$380,850$460,350$572,100
LENAWEEMI
$297,500$380,850$460,350$572,100
LIVINGSTONMI
$297,500$380,850$460,350$572,100
MACOMBMI
$297,500$380,850$460,350$572,100
2010–27 I.R.B.27July 6, 2010

MONROEMI
$297,500$380,850$460,350$572,100
OAKLANDMI
$297,500$380,850$460,350$572,100
ST. CLAIRMI
$297,500$380,850$460,350$572,100
WAYNEMI
$297,500$380,850$460,350$572,100
BERRIENMI
$298,750$382,450$462,300$574,500
WASHTENAWMI
$345,000$441,650$533,850$663,450
COOKMN
$296,250$379,250$458,400$569,700
ANOKAMN
$365,000$467,250$564,800$701,900
CARVERMN
$365,000$467,250$564,800$701,900
CHISAGOMN
$365,000$467,250$564,800$701,900
DAKOTAMN
$365,000$467,250$564,800$701,900
HENNEPINMN
$365,000$467,250$564,800$701,900
ISANTIMN
$365,000$467,250$564,800$701,900
RAMSEYMN
$365,000$467,250$564,800$701,900
SCOTTMN
$365,000$467,250$564,800$701,900
SHERBURNEMN
$365,000$467,250$564,800$701,900
WASHINGTONMN
$365,000$467,250$564,800$701,900
WRIGHTMN
$365,000$467,250$564,800$701,900
CRAWFORDMO
$281,250$360,050$435,200$540,850
FRANKLINMO
$281,250$360,050$435,200$540,850
JEFFERSONMO
$281,250$360,050$435,200$540,850
LINCOLNMO
$281,250$360,050$435,200$540,850
ST. CHARLESMO
$281,250$360,050$435,200$540,850
ST. LOUISMO
$281,250$360,050$435,200$540,850
ST. LOUIS CITYMO
$281,250$360,050$435,200$540,850
WARRENMO
$281,250$360,050$435,200$540,850
WASHINGTONMO
$281,250$360,050$435,200$540,850
MADISONMT
$281,750$360,700$436,000$541,800
CARBONMT
$291,250$372,850$450,700$560,100
MISSOULAMT
$291,250$372,850$450,700$560,100
YELLOWSTONEMT
$291,250$372,850$450,700$560,100
LAKEMT
$301,250$385,650$466,150$579,300
FLATHEADMT
$301,300$385,700$466,250$579,400
RAVALLIMT
$303,750$388,850$470,000$584,150
JEFFERSONMT
$341,250$436,850$528,050$656,250
LEWIS AND CLARKMT
$341,250$436,850$528,050$656,250
July 6, 2010282010–27 I.R.B.

SWEET GRASSMT
$346,250$443,250$535,800$665,850
GALLATINMT
$386,250$494,450$597,700$742,800
WATAUGANC
$285,000$364,850$441,000$548,050
CARTERETNC
$287,500$368,050$444,900$552,900
TRANSYLVANIANC
$293,750$376,050$454,550$564,900
FRANKLINNC
$295,000$377,650$456,500$567,300
JOHNSTONNC
$295,000$377,650$456,500$567,300
WAKENC
$295,000$377,650$456,500$567,300
ANSONNC
$303,750$388,850$470,000$584,150
BRUNSWICKNC
$303,750$388,850$470,000$584,150
BUNCOMBENC
$303,750$388,850$470,000$584,150
CABARRUSNC
$303,750$388,850$470,000$584,150
GASTONNC
$303,750$388,850$470,000$584,150
HAYWOODNC
$303,750$388,850$470,000$584,150
HENDERSONNC
$303,750$388,850$470,000$584,150
MADISONNC
$303,750$388,850$470,000$584,150
MECKLENBURGNC
$303,750$388,850$470,000$584,150
NEW HANOVERNC
$303,750$388,850$470,000$584,150
PENDERNC
$303,750$388,850$470,000$584,150
UNIONNC
$303,750$388,850$470,000$584,150
ONSLOWNC
$306,250$392,050$473,900$588,950
CHATHAMNC
$334,650$428,400$517,850$643,550
DURHAMNC
$334,650$428,400$517,850$643,550
ORANGENC
$334,650$428,400$517,850$643,550
PERSONNC
$334,650$428,400$517,850$643,550
CURRITUCKNC
$458,850$587,400$710,050$882,400
DARENC
$460,000$588,850$711,800$884,600
HYDENC
$483,000$618,300$747,400$928,850
CAMDENNC
$729,750$934,200$1,129,250$1,403,400
PASQUOTANKNC
$729,750$934,200$1,129,250$1,403,400
PERQUIMANSNC
$729,750$934,200$1,129,250$1,403,400
BELKNAPNH
$281,250$360,050$435,200$540,850
GRAFTONNH
$281,250$360,050$435,200$540,850
MERRIMACKNH
$302,500$387,250$468,100$581,750
HILLSBOROUGHNH
$402,500$515,250$622,850$774,050
ROCKINGHAMNH
$523,750$670,500$810,450$1,007,200
STRAFFORDNH
$523,750$670,500$810,450$1,007,200
2010–27 I.R.B.29July 6, 2010

WARRENNJ
$402,500$515,250$622,850$774,050
CUMBERLANDNJ
$405,000$518,450$626,700$778,850
BURLINGTONNJ
$420,000$537,650$649,900$807,700
CAMDENNJ
$420,000$537,650$649,900$807,700
GLOUCESTERNJ
$420,000$537,650$649,900$807,700
SALEMNJ
$420,000$537,650$649,900$807,700
MERCERNJ
$440,000$563,250$680,850$846,150
ATLANTICNJ
$453,750$580,850$702,150$872,600
CAPE MAYNJ
$487,500$624,100$754,350$937,500
BERGENNJ
$729,750$934,200$1,129,250$1,403,400
ESSEXNJ
$729,750$934,200$1,129,250$1,403,400
HUDSONNJ
$729,750$934,200$1,129,250$1,403,400
HUNTERDONNJ
$729,750$934,200$1,129,250$1,403,400
MIDDLESEXNJ
$729,750$934,200$1,129,250$1,403,400
MONMOUTHNJ
$729,750$934,200$1,129,250$1,403,400
MORRISNJ
$729,750$934,200$1,129,250$1,403,400
OCEANNJ
$729,750$934,200$1,129,250$1,403,400
PASSAICNJ
$729,750$934,200$1,129,250$1,403,400
SOMERSETNJ
$729,750$934,200$1,129,250$1,403,400
SUSSEXNJ
$729,750$934,200$1,129,250$1,403,400
UNIONNJ
$729,750$934,200$1,129,250$1,403,400
SAN JUANNM
$281,250$360,050$435,200$540,850
LOS ALAMOSNM
$380,650$487,300$589,000$732,000
SANTA FENM
$427,500$547,250$661,500$822,100
ELKONV
$325,000$416,050$502,900$625,000
EUREKANV
$325,000$416,050$502,900$625,000
NYENV
$325,000$416,050$502,900$625,000
LYONNV
$331,250$424,050$512,600$637,000
CARSON CITYNV
$398,750$510,450$617,050$766,850
CLARKNV
$400,000$512,050$618,950$769,250
STOREYNV
$403,750$516,850$624,750$776,450
WASHOENV
$403,750$516,850$624,750$776,450
DOUGLASNV
$468,750$600,100$725,350$901,450
COLUMBIANY
$276,250$353,650$427,450$531,250
ERIENY
$276,250$353,650$427,450$531,250
NIAGARANY
$276,250$353,650$427,450$531,250
July 6, 2010302010–27 I.R.B.

MADISONNY
$281,250$360,050$435,200$540,850
ONONDAGANY
$281,250$360,050$435,200$540,850
OSWEGONY
$281,250$360,050$435,200$540,850
ALBANYNY
$312,500$400,050$483,550$600,950
RENSSELAERNY
$312,500$400,050$483,550$600,950
SARATOGANY
$312,500$400,050$483,550$600,950
SCHENECTADYNY
$312,500$400,050$483,550$600,950
SCHOHARIENY
$312,500$400,050$483,550$600,950
ULSTERNY
$406,250$520,050$628,650$781,250
DUTCHESSNY
$443,750$568,050$686,650$853,350
ORANGENY
$443,750$568,050$686,650$853,350
BRONXNY
$729,750$934,200$1,129,250$1,403,400
KINGSNY
$729,750$934,200$1,129,250$1,403,400
NASSAUNY
$729,750$934,200$1,129,250$1,403,400
NEW YORKNY
$729,750$934,200$1,129,250$1,403,400
PUTNAMNY
$729,750$934,200$1,129,250$1,403,400
QUEENSNY
$729,750$934,200$1,129,250$1,403,400
RICHMONDNY
$729,750$934,200$1,129,250$1,403,400
ROCKLANDNY
$729,750$934,200$1,129,250$1,403,400
SUFFOLKNY
$729,750$934,200$1,129,250$1,403,400
WESTCHESTERNY
$729,750$934,200$1,129,250$1,403,400
GREENEOH
$271,250$347,250$419,750$521,650
MIAMIOH
$271,250$347,250$419,750$521,650
MONTGOMERYOH
$271,250$347,250$419,750$521,650
PREBLEOH
$271,250$347,250$419,750$521,650
CARROLLOH
$277,500$355,250$429,400$533,650
STARKOH
$277,500$355,250$429,400$533,650
ASHTABULAOH
$291,250$372,850$450,700$560,100
MERCEROH
$292,500$374,450$452,600$562,500
CUYAHOGAOH
$298,750$382,450$462,300$574,500
GEAUGAOH
$298,750$382,450$462,300$574,500
LAKEOH
$298,750$382,450$462,300$574,500
LORAINOH
$298,750$382,450$462,300$574,500
MEDINAOH
$298,750$382,450$462,300$574,500
VAN WERTOH
$301,250$385,650$466,150$579,300
PORTAGEOH
$330,000$422,450$510,650$634,600
SUMMITOH
$330,000$422,450$510,650$634,600
BROWNOH
$337,500$432,050$522,250$649,050
2010–27 I.R.B.31July 6, 2010

BUTLEROH
$337,500$432,050$522,250$649,050
CLERMONTOH
$337,500$432,050$522,250$649,050
HAMILTONOH
$337,500$432,050$522,250$649,050
WARRENOH
$337,500$432,050$522,250$649,050
DELAWAREOH
$341,250$436,850$528,050$656,250
FAIRFIELDOH
$341,250$436,850$528,050$656,250
FRANKLINOH
$341,250$436,850$528,050$656,250
LICKINGOH
$341,250$436,850$528,050$656,250
MADISONOH
$341,250$436,850$528,050$656,250
MORROWOH
$341,250$436,850$528,050$656,250
PICKAWAYOH
$341,250$436,850$528,050$656,250
UNIONOH
$341,250$436,850$528,050$656,250
ATHENSOH
$432,500$553,650$669,250$831,750
MARIONOR
$295,000$377,650$456,500$567,300
POLKOR
$295,000$377,650$456,500$567,300
LINCOLNOR
$312,500$400,050$483,550$600,950
JOSEPHINEOR
$325,000$416,050$502,900$625,000
BENTONOR
$337,500$432,050$522,250$649,050
LANEOR
$343,750$440,050$531,900$661,050
TILLAMOOKOR
$343,750$440,050$531,900$661,050
CLATSOPOR
$347,500$444,850$537,750$668,250
CURRYOR
$351,250$449,650$543,550$675,500
HOOD RIVEROR
$393,750$504,050$609,300$757,200
CLACKAMASOR
$418,750$536,050$648,000$805,300
COLUMBIAOR
$418,750$536,050$648,000$805,300
MULTNOMAHOR
$418,750$536,050$648,000$805,300
WASHINGTONOR
$418,750$536,050$648,000$805,300
YAMHILLOR
$418,750$536,050$648,000$805,300
JACKSONOR
$422,500$540,850$653,800$812,500
DESCHUTESOR
$447,500$572,850$692,450$860,600
CENTREPA
$280,000$358,450$433,250$538,450
BERKSPA
$300,000$384,050$464,200$576,900
ALLEGHENYPA
$327,500$419,250$506,800$629,800
ARMSTRONGPA
$327,500$419,250$506,800$629,800
BEAVERPA
$327,500$419,250$506,800$629,800
BUTLERPA
$327,500$419,250$506,800$629,800
FAYETTEPA
$327,500$419,250$506,800$629,800
July 6, 2010322010–27 I.R.B.

WASHINGTONPA
$327,500$419,250$506,800$629,800
WESTMORELANDPA
$327,500$419,250$506,800$629,800
LANCASTERPA
$383,750$491,250$593,800$738,000
CARBONPA
$402,500$515,250$622,850$774,050
LEHIGHPA
$402,500$515,250$622,850$774,050
NORTHAMPTONPA
$402,500$515,250$622,850$774,050
BUCKSPA
$420,000$537,650$649,900$807,700
CHESTERPA
$420,000$537,650$649,900$807,700
DELAWAREPA
$420,000$537,650$649,900$807,700
MONTGOMERYPA
$420,000$537,650$649,900$807,700
PHILADELPHIAPA
$420,000$537,650$649,900$807,700
YORKPA
$425,000$544,050$657,650$817,300
PIKEPA
$729,750$934,200$1,129,250$1,403,400
BRISTOLRI
$475,000$608,100$735,050$913,450
KENTRI
$475,000$608,100$735,050$913,450
NEWPORTRI
$475,000$608,100$735,050$913,450
PROVIDENCERI
$475,000$608,100$735,050$913,450
WASHINGTONRI
$475,000$608,100$735,050$913,450
HORRYSC
$286,250$366,450$442,950$550,450
GREENVILLESC
$295,000$377,650$456,500$567,300
LAURENSSC
$295,000$377,650$456,500$567,300
PICKENSSC
$295,000$377,650$456,500$567,300
YORKSC
$303,750$388,850$470,000$584,150
BERKELEYSC
$335,000$428,850$518,400$644,250
CHARLESTONSC
$335,000$428,850$518,400$644,250
DORCHESTERSC
$335,000$428,850$518,400$644,250
BEAUFORTSC
$387,500$496,050$599,600$745,200
JASPERSC
$387,500$496,050$599,600$745,200
GEORGETOWNSC
$395,000$505,650$611,250$759,600
CANNONTN
$432,500$553,650$669,250$831,750
CHEATHAMTN
$432,500$553,650$669,250$831,750
DAVIDSONTN
$432,500$553,650$669,250$831,750
DICKSONTN
$432,500$553,650$669,250$831,750
HICKMANTN
$432,500$553,650$669,250$831,750
MACONTN
$432,500$553,650$669,250$831,750
ROBERTSONTN
$432,500$553,650$669,250$831,750
2010–27 I.R.B.33July 6, 2010

RUTHERFORDTN
$432,500$553,650$669,250$831,750
SMITHTN
$432,500$553,650$669,250$831,750
SUMNERTN
$432,500$553,650$669,250$831,750
TROUSDALETN
$432,500$553,650$669,250$831,750
WILLIAMSONTN
$432,500$553,650$669,250$831,750
WILSONTN
$432,500$553,650$669,250$831,750
JEFF DAVISTX
$271,250$347,250$419,750$521,650
BASTROPTX
$288,750$369,650$446,800$555,300
CALDWELLTX
$288,750$369,650$446,800$555,300
HAYSTX
$288,750$369,650$446,800$555,300
TRAVISTX
$288,750$369,650$446,800$555,300
WILLIAMSONTX
$288,750$369,650$446,800$555,300
ATASCOSATX
$332,500$425,650$514,500$639,400
BANDERATX
$332,500$425,650$514,500$639,400
BEXARTX
$332,500$425,650$514,500$639,400
COMALTX
$332,500$425,650$514,500$639,400
GUADALUPETX
$332,500$425,650$514,500$639,400
KENDALLTX
$332,500$425,650$514,500$639,400
MEDINATX
$332,500$425,650$514,500$639,400
WILSONTX
$332,500$425,650$514,500$639,400
RICHUT
$296,700$379,800$459,100$570,550
DAGGETTUT
$302,450$387,200$468,000$581,650
JUABUT
$323,750$414,450$500,950$622,600
UTAHUT
$323,750$414,450$500,950$622,600
WASHINGTONUT
$372,500$476,850$576,400$716,350
KANEUT
$383,750$491,250$593,800$738,000
DAVISUT
$397,500$508,850$615,100$764,400
MORGANUT
$397,500$508,850$615,100$764,400
WEBERUT
$397,500$508,850$615,100$764,400
WASATCHUT
$431,250$552,050$667,350$829,350
SALT LAKEUT
$729,750$934,200$1,129,250$1,403,400
SUMMITUT
$729,750$934,200$1,129,250$1,403,400
TOOELEUT
$729,750$934,200$1,129,250$1,403,400
HARRISONBURGVA
$277,150$354,800$428,850$532,950
ROCKINGHAMVA
$277,150$354,800$428,850$532,950
MADISONVA
$277,500$355,250$429,400$533,650
July 6, 2010342010–27 I.R.B.

BOTETOURTVA
$280,000$358,450$433,250$538,450
CRAIGVA
$280,000$358,450$433,250$538,450
FRANKLINVA
$280,000$358,450$433,250$538,450
ROANOKEVA
$280,000$358,450$433,250$538,450
ROANOKE INDVA
$280,000$358,450$433,250$538,450
SALEMVA
$280,000$358,450$433,250$538,450
HIGHLANDVA
$287,500$368,050$444,900$552,900
AMHERSTVA
$292,100$373,950$452,000$561,700
APPOMATTOXVA
$292,100$373,950$452,000$561,700
BEDFORDVA
$292,100$373,950$452,000$561,700
BEDFORD INDVA
$292,100$373,950$452,000$561,700
CAMPBELLVA
$292,100$373,950$452,000$561,700
GILESVA
$292,100$373,950$452,000$561,700
LYNCHBURGVA
$292,100$373,950$452,000$561,700
MONTGOMERYVA
$292,100$373,950$452,000$561,700
PULASKIVA
$292,100$373,950$452,000$561,700
RADFORDVA
$292,100$373,950$452,000$561,700
LEXINGTONVA
$296,250$379,250$458,400$569,700
RICHMONDVA
$300,000$384,050$464,200$576,900
MIDDLESEXVA
$330,000$422,450$510,650$634,600
ORANGEVA
$331,250$424,050$512,600$637,000
RAPPAHANNOCKVA
$359,950$460,800$557,000$692,200
ESSEXVA
$375,000$480,050$580,300$721,150
CULPEPERVA
$382,500$489,650$591,900$735,600
KING GEORGEVA
$386,250$494,450$597,700$742,800
NORTHUMBERLANDVA
$392,500$502,450$607,350$754,800
ALBEMARLEVA
$437,000$559,450$676,200$840,400
CHARLOTTESVILLEVA
$437,000$559,450$676,200$840,400
FLUVANNAVA
$437,000$559,450$676,200$840,400
GREENEVA
$437,000$559,450$676,200$840,400
NELSONVA
$437,000$559,450$676,200$840,400
CHESAPEAKEVA
$458,850$587,400$710,050$882,400
GLOUCESTERVA
$458,850$587,400$710,050$882,400
HAMPTONVA
$458,850$587,400$710,050$882,400
ISLE OF WIGHTVA
$458,850$587,400$710,050$882,400
JAMES CITYVA
$458,850$587,400$710,050$882,400
MATHEWSVA
$458,850$587,400$710,050$882,400
NEWPORT NEWSVA
$458,850$587,400$710,050$882,400
NORFOLKVA
$458,850$587,400$710,050$882,400
2010–27 I.R.B.35July 6, 2010

POQUOSONVA
$458,850$587,400$710,050$882,400
PORTSMOUTHVA
$458,850$587,400$710,050$882,400
SUFFOLKVA
$458,850$587,400$710,050$882,400
SURRYVA
$458,850$587,400$710,050$882,400
VIRGINIA BEACHVA
$458,850$587,400$710,050$882,400
WILLIAMSBURGVA
$458,850$587,400$710,050$882,400
YORKVA
$458,850$587,400$710,050$882,400
FREDERICKVA
$475,000$608,100$735,050$913,450
WINCHESTERVA
$475,000$608,100$735,050$913,450
AMELIAVA
$535,900$686,050$829,250$1,030,600
CAROLINEVA
$535,900$686,050$829,250$1,030,600
CHARLES CITYVA
$535,900$686,050$829,250$1,030,600
CHESTERFIELDVA
$535,900$686,050$829,250$1,030,600
COLONIAL HEIGHTVA
$535,900$686,050$829,250$1,030,600
CUMBERLANDVA
$535,900$686,050$829,250$1,030,600
DINWIDDIEVA
$535,900$686,050$829,250$1,030,600
GOOCHLANDVA
$535,900$686,050$829,250$1,030,600
HANOVERVA
$535,900$686,050$829,250$1,030,600
HENRICOVA
$535,900$686,050$829,250$1,030,600
HOPEWELLVA
$535,900$686,050$829,250$1,030,600
KING AND QUEENVA
$535,900$686,050$829,250$1,030,600
KING WILLIAMVA
$535,900$686,050$829,250$1,030,600
LOUISAVA
$535,900$686,050$829,250$1,030,600
NEW KENTVA
$535,900$686,050$829,250$1,030,600
PETERSBURGVA
$535,900$686,050$829,250$1,030,600
POWHATANVA
$535,900$686,050$829,250$1,030,600
PRINCE GEORGEVA
$535,900$686,050$829,250$1,030,600
RICHMOND INDVA
$535,900$686,050$829,250$1,030,600
SUSSEXVA
$535,900$686,050$829,250$1,030,600
LANCASTERVA
$545,000$697,700$843,350$1,048,100
ALEXANDRIAVA
$729,750$934,200$1,129,250$1,403,400
ARLINGTONVA
$729,750$934,200$1,129,250$1,403,400
CLARKEVA
$729,750$934,200$1,129,250$1,403,400
FAIRFAXVA
$729,750$934,200$1,129,250$1,403,400
FAIRFAX INDVA
$729,750$934,200$1,129,250$1,403,400
FALLS CHURCHVA
$729,750$934,200$1,129,250$1,403,400
FAUQUIERVA
$729,750$934,200$1,129,250$1,403,400
FREDERICKSBURGVA
$729,750$934,200$1,129,250$1,403,400
LOUDOUNVA
$729,750$934,200$1,129,250$1,403,400
July 6, 2010362010–27 I.R.B.

MANASSASVA
$729,750$934,200$1,129,250$1,403,400
MANASSAS PARKVA
$729,750$934,200$1,129,250$1,403,400
PRINCE WILLIAMVA
$729,750$934,200$1,129,250$1,403,400
SPOTSYLVANIAVA
$729,750$934,200$1,129,250$1,403,400
STAFFORDVA
$729,750$934,200$1,129,250$1,403,400
WARRENVA
$729,750$934,200$1,129,250$1,403,400
LAMOILLEVT
$276,000$353,300$427,100$530,750
BENNINGTONVT
$277,150$354,800$428,850$532,950
ORANGEVT
$281,250$360,050$435,200$540,850
WINDSORVT
$281,250$360,050$435,200$540,850
CHITTENDENVT
$318,750$408,050$493,250$613,000
FRANKLINVT
$318,750$408,050$493,250$613,000
GRAND ISLEVT
$318,750$408,050$493,250$613,000
BENTONWA
$275,000$352,050$425,550$528,850
FRANKLINWA
$275,000$352,050$425,550$528,850
MASONWA
$310,000$396,850$479,700$596,150
KITTITASWA
$328,750$420,850$508,700$632,200
CHELANWA
$342,700$438,700$530,300$659,050
DOUGLASWA
$342,700$438,700$530,300$659,050
THURSTONWA
$361,250$462,450$559,000$694,700
SKAGITWA
$373,750$478,450$578,350$718,750
WHATCOMWA
$375,000$480,050$580,300$721,150
ISLANDWA
$381,250$488,050$589,950$733,150
CLALLAMWA
$383,750$491,250$593,800$738,000
CLARKWA
$418,750$536,050$648,000$805,300
SKAMANIAWA
$418,750$536,050$648,000$805,300
JEFFERSONWA
$437,500$560,050$677,000$841,350
KITSAPWA
$475,000$608,100$735,050$913,450
KINGWA
$567,500$726,500$878,150$1,091,350
PIERCEWA
$567,500$726,500$878,150$1,091,350
SNOHOMISHWA
$567,500$726,500$878,150$1,091,350
SAN JUANWA
$593,750$760,100$918,800$1,141,850
WALWORTHWI
$278,750$356,850$431,350$536,050
COLUMBIAWI
$293,750$376,050$454,550$564,900
DANEWI
$293,750$376,050$454,550$564,900
IOWAWI
$293,750$376,050$454,550$564,900
2010–27 I.R.B.37July 6, 2010

MILWAUKEEWI
$315,000$403,250$487,450$605,750
OZAUKEEWI
$315,000$403,250$487,450$605,750
WASHINGTONWI
$315,000$403,250$487,450$605,750
WAUKESHAWI
$315,000$403,250$487,450$605,750
PIERCEWI
$365,000$467,250$564,800$701,900
ST. CROIXWI
$365,000$467,250$564,800$701,900
KENOSHAWI
$410,000$524,850$634,450$788,450
BERKELEYWV
$377,500$483,250$584,150$725,950
MORGANWV
$377,500$483,250$584,150$725,950
HAMPSHIREWV
$475,000$608,100$735,050$913,450
JEFFERSONWV
$729,750$934,200$1,129,250$1,403,400
SHERIDANWY
$272,500$348,850$421,650$524,050
SUBLETTEWY
$298,750$382,450$462,300$574,500
TETONWY
$693,750$888,100$1,073,550$1,334,150
MANUAAS
$305,000$390,450$471,950$586,550
GUAMGU
$651,250$833,700$1,007,750$1,252,400
ROTAMP
$473,750$606,500$733,100$911,050
NORTHERN ISLANDMP
$605,000$774,500$936,200$1,163,500
SAIPANMP
$610,000$780,900$943,950$1,173,100
TINIANMP
$613,750$785,700$949,750$1,180,300
AGUAS BUENASPR
$606,250$776,100$938,150$1,165,900
AIBONITOPR
$606,250$776,100$938,150$1,165,900
ARECIBOPR
$606,250$776,100$938,150$1,165,900
BARCELONETAPR
$606,250$776,100$938,150$1,165,900
BARRANQUITASPR
$606,250$776,100$938,150$1,165,900
BAYAMONPR
$606,250$776,100$938,150$1,165,900
CAGUASPR
$606,250$776,100$938,150$1,165,900
CAMUYPR
$606,250$776,100$938,150$1,165,900
CANOVANASPR
$606,250$776,100$938,150$1,165,900
CAROLINAPR
$606,250$776,100$938,150$1,165,900
CATANOPR
$606,250$776,100$938,150$1,165,900
CAYEYPR
$606,250$776,100$938,150$1,165,900
CEIBAPR
$325,000$416,050$502,900$625,000
CIALESPR
$606,250$776,100$938,150$1,165,900
July 6, 2010382010–27 I.R.B.

CIDRAPR
$606,250$776,100$938,150$1,165,900
COMERIOPR
$606,250$776,100$938,150$1,165,900
COROZALPR
$606,250$776,100$938,150$1,165,900
DORADOPR
$606,250$776,100$938,150$1,165,900
FAJARDOPR
$325,000$416,050$502,900$625,000
FLORIDAPR
$606,250$776,100$938,150$1,165,900
GUAYNABOPR
$606,250$776,100$938,150$1,165,900
GURABOPR
$606,250$776,100$938,150$1,165,900
HATILLOPR
$606,250$776,100$938,150$1,165,900
HUMACAOPR
$606,250$776,100$938,150$1,165,900
JUNCOSPR
$606,250$776,100$938,150$1,165,900
LAS PIEDRASPR
$606,250$776,100$938,150$1,165,900
LOIZAPR
$606,250$776,100$938,150$1,165,900
LUQUILLOPR
$325,000$416,050$502,900$625,000
MANATIPR
$606,250$776,100$938,150$1,165,900
MAUNABOPR
$606,250$776,100$938,150$1,165,900
MOROVISPR
$606,250$776,100$938,150$1,165,900
NAGUABOPR
$606,250$776,100$938,150$1,165,900
NARANJITOPR
$606,250$776,100$938,150$1,165,900
OROCOVISPR
$606,250$776,100$938,150$1,165,900
QUEBRADILLASPR
$606,250$776,100$938,150$1,165,900
RIO GRANDEPR
$606,250$776,100$938,150$1,165,900
SAN JUANPR
$606,250$776,100$938,150$1,165,900
SAN LORENZOPR
$606,250$776,100$938,150$1,165,900
TOA ALTAPR
$606,250$776,100$938,150$1,165,900
TOA BAJAPR
$606,250$776,100$938,150$1,165,900
TRUJILLO ALTOPR
$606,250$776,100$938,150$1,165,900
VEGA ALTAPR
$606,250$776,100$938,150$1,165,900
VEGA BAJAPR
$606,250$776,100$938,150$1,165,900
YABUCOAPR
$606,250$776,100$938,150$1,165,900
ST. CROIXVI
$327,750$419,550$507,150$630,300
ST. THOMASVI
$446,200$571,200$690,450$858,100
ST. JOHN,VIVI
$623,300$797,950$964,500$1,198,650
All other areas (floor):
$271,050$347,000$419,400$521,250
.02 The nationwideaverage purchase
price (for use in the housing cost/income
ratio for new and existing residences) is
$217,300.
2010–27 I.R.B.39July 6, 2010

SECTION 5. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2009–18 is obsolete except
as provided in section 6 of this revenue
procedure.
SECTION 6. EFFECTIVE DATES
.01 Issuers may rely on this revenue
procedure to determine average area pur-
chase price safe harbors for commitments
to provide financing or issue mortgage
credit certificates that are made, or (if the
purchase precedes the commitment) for
residences that are purchased, in the period
that begins on June 16, 2010, and ends
on the date as of which the safe harbors
contained in section 4.01 of this revenue
procedure are rendered obsolete by a new
revenue procedure.
.02 Notwithstanding section 5 of this
revenue procedure, issuers may continue
to rely on the average area purchase price
safe harbors contained in Rev. Proc.
2009–18, with respect to bonds sold, or
for mortgage credit certificates issued with
respect to bond authority exchanged, be-
fore July 16, 2010, if the commitments
to provide financing or issue mortgage
credit certificates aremadeonorbefore
August 15, 2010.
.03 Except as provided in section 6.04,
issuers must use the nationwide average
purchase price limitation contained in
this revenue procedure for commitments
to provide financing or issue mortgage
credit certificates that are made, or (if
the purchase precedes the commitment)
for residences that are purchased, in the
period that begins on June 16, 2010, and
ends on the date when the nationwide av-
erage purchase price limitation is rendered
obsolete by a new revenue procedure.
.04 Notwithstanding sections 5 and
6.03 of this revenue procedure, issuers
may continue to rely on the nationwide
average purchase price set forth in Rev.
Proc. 2009–18 with respect to bonds sold,
or for mortgage credit certificates issued
with respect to bond authority exchanged,
before July 16, 2010, if the commitments
to provide financing or issue mortgage
credit certificates are made on or before
August 15, 2010.
SECTION 7. REQUEST FOR
COMMENTS
The Treasury Department and the IRS
are reviewing the available data sources
and method used to determine the aver-
age area purchase price safe harbors listed
in section 4.01 of this revenue procedure
and are considering possible changes in
the data used to determine these safe har-
bors for future years. One possible alter-
native method under consideration would
involve the use of certain current avail-
able data from the Department of Hous-
ing and Urban Development (“HUD”) re-
garding county median housing purchase
prices. The Treasury Department and the
IRS solicit public comments generally on
whether the average area purchase price
safeharborslistedinsection4.01ofthis
revenue procedure should continue to be
based on FHA loan limits or whether the
data used to calculate these safe harbors
should be changed in any way, such as,
without limitation, a change to an alter-
native method using current HUD data on
county median housing purchase prices.
Comments should be submitted
in writing and can be e-mailed to
notice.comments@irscounsel.treas.gov
(include “Rev. Proc. 2010–25” in
the subject line) or mailed to Office
of Associate Chief Counsel (Financial
Institutions & Products), Re: Rev.
Proc. 2010–25, CC:FIP:B5, Room
3547, 1111 Constitution Avenue, NW,
Washington, DC 20224. The due date
for the public comments is September 6,
2010. Comments that are submitted will
be made available to the public.
SECTION 8. PAPERWORK
REDUCTION ACT
The collection of information con-
tained in this revenue procedure has been
reviewed and approved by the Office
of Management and Budget in accor-
dance with the Paperwork Reduction Act
(44 U.S.C. 3507) under control number
1545–1877.
An agency may not conduct or sponsor,
and a person is not required to respond
to, a collection of information unless the
collection of information displays a valid
OMB control number.
This revenue procedure contains a col-
lection of information requirement in sec-
tion 3.03. The purpose of the collection
of information is to verify the applica-
ble FHA loan limit that issuers of quali-
fied mortgage bonds and qualified mort-
gage certificates have used to calculate the
average area purchase price for a given
metropolitan statistical area for purposes
of section 143(e) and 25(c). The collec-
tion of information is required to obtain
the benefit of using revisions to FHA loan
limits to determine average area purchase
prices. The likely respondents are state
and local governments.
The estimated total annual reporting
and/or recordkeeping burden is: 15 hours.
The estimated annual burden per re-
spondent and/or recordkeeper: 15 minutes.
The estimated number of respondents
and/or recordkeepers: 60.
Books or records relating to a collection
of information must be retained as long
as their contents may become material in
the administration of any internal revenue
law. Generally tax returns and tax return
information are confidential, as required
by 26 U.S.C. 6103.
SECTION 9. DRAFTING
INFORMATION
The principal authors of this rev-
enue procedure are David E. White
and Timothy L. Jones of the Office
of Associate Chief Counsel (Financial
Institutions & Products). For further
information regarding this revenue
procedure, contact David E. White at
(202) 622–3980 (not a toll-free call).
July 6, 2010402010–27 I.R.B.

Part IV. Items o
fGeneralInterest
Notice of Prop
osed
Rulemaking by
Cross-Refere
nce to
Temporary Re
gulations
Indoor Tanni
ng Services;
Cosmetic Ser
vices; Excise
Taxes
REG–112841–10
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of Proposed Rulemaking
by Cross-Reference to Temporary Regula-
tions.
SUMMARY: In this issue of the Bulletin,
the IRS is issuing temporary regulations
(T.D. 9486) that provide guidance on the
indoor tanning services excise tax imposed
by the Patient Protection and Affordable
Care Act of 2010. These regulations af-
fect users and providers of indoor tanning
services. The text of the temporary regula-
tions also serves as the text of the proposed
regulations. These regulations affect users
and providers of indoor tanning services.
DATES: Written and electronic comments
and requests for a public hearing must be
received by September 13, 2010.
ADDRESSES: Send submissions to:
CC:PA:LPD:PR(REG–112841–10),
Room 5203, Internal Revenue Ser-
vice, PO Box 7604, Ben Franklin Sta-
tion, Washington, DC 20044. Sub-
missions may be hand-delivered to:
CC:PA:LPD:PR Monday through Friday
between the hours of 8 a.m. and 4 p.m.
to: CC:PA:LPD:PR (REG–112841–10),
Courier’s Desk, Internal Revenue
Service, 1111 Constitution Avenue, NW;
Washington, DC, or sent electronically
via the Federal eRulemaking Portal
athttp://www.regulations.gov(IRS
REG–112841–10).
FOR F
URTHER INFORMATION
CONT
ACT: Concerning the proposed
reg
ulations, Taylor Cortright, (202)
622
–3130; concerning submissions of
comments and r
equests for a public
hearing, Regi
na Johnson, (202) 622–7180
(not toll-fre
e numbers).
SUPPLEMENTAR
Y INFORMATION:
Paperwork Red
uction Act
The collectio
n of information contained
in this notic
e of proposed rulemaking
has been appr
oved by the Office of Man-
agement and B
udget in accordance with
the Paperwor
k Reduction Act of 1995
(44 U.S.C. 3
507(d)) and assigned control
number 1545
–2177. Comments on the
collection
of information should be sent
to the Offic
e of Management and Budget,
Attn: Desk O
fficer for the Department
of the Treas
ury, Office of Information
and Regula
tory Affairs, Washington, DC
20503, wit
h copies to the Internal Revenue
Service, A
ttn: IRS Reports Clearance
Officer, S
E:W:CAR:MP:T:T:SP, Wash-
ington, D
C 20224. Comments on the
collecti
on of information should be re-
ceived by
September 13, 2010. Comments
are speci
fically requested concerning:
Whether t
he proposed collection of in-
formatio
n is necessary for the proper per-
formanc
e of the functions of the Internal
Revenue
Service, including whether the
informa
tion will have practical utility;
The accu
racy of the estimated burden
associa
ted with the proposed collection of
informa
tion (see below);
How the q
uality, utility, and clarity of
the info
rmation to be collected may be en-
hanced;
How the b
urden of complying with the
propos
ed collections of information may
be mini
mized, including through the appli-
cation
of automated collection techniques
or othe
r forms of information technology;
and
Estima
tes of capital or start-up costs of
operat
ion, maintenance, and purchase of
servi
ce to provide information.
The col
lection of information in
this p
roposedregulationisinproposed
§49.5
000B–1(d)(2). This information is
requi
redbytheIRStoallowprovidersof
indoo
r tanning services to calculate the
tax on
indoor tanning services. The likely
recor
dkeepers are providers of indoor tan-
ning
services.
Estimated tot
al average annual record-
keeping burde
n: 10,000 hours.
Estimated ave
rage annual burden
hours per reco
rdkeeper:30minutes.
Estimated num
ber of recordkeepers:
20,000.
An agency may n
ot conduct or sponsor,
and a person is
not required to respond
to, a collecti
on of information unless the
collection o
f information displays a valid
control numb
er assigned by the Office of
Management a
nd Budget.
Books or reco
rds relating to a collection
of informati
on must be retained as long
as their cont
ents may become material in
the adminis
tration of any internal revenue
law. Genera
lly, tax returns and tax return
informatio
n are confidential, as required
by 26 U.S.C.
6103.
Background
This docume
nt contains proposed
amendments
to the Excise Tax Proce-
dural Regu
lations (26 CFR part 40) and
the Facili
ties and Services Excise Tax
Regulatio
ns (26 CFR part 49) under sec-
tion 5000B
of the Internal Revenue Code
(Code). S
ection 5000B of the Code was
enacted b
ysection10907ofthePatient
Protecti
on and Affordable Care Act of
2010, Pub
lic Law 111–148 (124 Stat. 119)
to impose
an excise tax on indoor tanning
service
s. The text of temporary regula-
tions pu
blished in this issue of the Bulletin
also ser
ves as the text of these proposed
regulat
ions. The preamble to the tempo-
rary reg
ulations explains the temporary
regulat
ions.
Specia
lAnalyses
It has b
een determined that this notice
of prop
osed rulemaking is not a significant
regula
tory action as defined in Executive
Order 1
2866. Therefore, a regulatory as-
sessme
nt is not required. It has been deter-
mined
that section 553(b) of the Admin-
istra
tive Procedure Act (5 U.S.C. chapter
5) doe
s not apply to these regulations. It
is her
eby certified thatthese regulations
will n
ot have a significant economic im-
pact o
n a substantial number of small en-
titi
es. This certification is based on the
fact
that these regulations are designed to
acco
mmodate the recordkeeping methods
2010–27 I.R.B.41July 6, 2010

currently used by small entities that pro-
vide indoor tanning services. The regula-
tions merely implement the tax imposed
by section 5000B of the Code, and sec-
tion 6001 of the Code already requires tax-
payers to keep books and records suffi-
cient to show whether or not they are li-
able for tax. The information necessary to
prepare these records is readily available
to providers, and this recordkeeping will
take little additional time to complete. Ac-
cordingly, a Regulatory Flexibility Anal-
ysis under the Regulatory Flexibility Act
(5 U.S.C. chapter 6) is not required. Pur-
suant to section 7805(f) of the Code, this
notice of proposed rulemaking has been
submitted to the Chief Counsel for Advo-
cacy of the Small Business Administration
for comment on its impact on small busi-
ness.
Comments and Requests for a 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 specifically request com-
ments on the clarity of the proposed regu-
lations and how they may be easier to un-
derstand. All comments will be available
for public inspection and copying. A pub-
lic hearing may be scheduled if requested
in writing by any person that timely sub-
mits written comments. If a public hearing
is scheduled, notice of the date, time, and
place for the hearing will be published in
theFederal Register.
Drafting Information
The principal author of these regula-
tions is Taylor Cortright, Office of the
Associate Chief Counsel (Passthroughs
and Special Industries).However,
other personnel from the IRS and the
Treasury Department participated in their
development.
*****
Proposed Amendments to the
Regulations
Accordingly, 26 CFR parts 40 and 49
are proposed to be amended as follows:
PART 40—EXCISE TAX
PROCEDURAL REGULATIONS
Paragraph 1. The authority citation for
part 40 is amended by adding an entry in
numerical order to read in part as follows:
Authority: 26 U.S.C. 7805.
Section 40.0–1 also issued under
26 U.S.C. 5000B(c). * * *
Par. 2. Section 40.0–1 is amended by
revising paragraphs (d) and (e) to read as
follows:
§40.0–1 Introduction.
*****
(d)[Thetextofthisproposed
§40.0–1(d) is the same as the text of
§40.0–1T(d) published elsewhere in this
issue of the Bulletin].
(e)[Thetextofthisproposed
§40.0–1(e) is the same as the text of
§40.0–1T(e) published elsewhere in this
issue of the Bulletin].
*****
Par. 3 . Section 40.6302(c)–1 is
amended by adding paragraph (g) to read
as follows:
§40.6302(c)–1 Use of government
depositaries.
*****
(g) [The text of this proposed
§40.6302(c)–1T(g) is the same as the text
of §40.6302(c)–1T(g) published elsewhere
in this issue of the Bulletin].
PART 49—FACILITIES AND
SERVICES EXCISE TAX
Par. 4. The authority citation for part
49isamendedbyaddinganentryinnu-
merical order to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Section 49.5000B–1 also issued under
26 U.S.C. 5000B.
Par. 5. Section 49.0–3 is added to read
as follows:
§49.0–3 Introduction; cosmetic services.
[The text of this proposed §49.0–3 is
the same as the text of §49.0–3T published
elsewhere in this issue of the Bulletin].
Par. 6. Subpart G is added to read as
follows:
Subpart G—Cosmetic Services
§49.5000B–1 Indoor Tanning Services.
[The text of this proposed §49.5000B–1
is the same as the text of §49.5000B–1T(a)
through (h) published elsewhere in this is-
sue of the Bulletin].
Steven Miller,
Deputy Commissioner for
Services and Enforcement.
(Filed by the Office of the Federal Register on June 11, 2010,
11:15 a.m., and published in the issue of the Federal Register
for June 15, 2010, 75 F.R. 33740)
Announcement of Disciplinary Sanctions From the Office
of Professional Responsibility
Announcement 2010-43
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:
July 6, 2010422010–27 I.R.B.

Disbarred from practice before the
IRS—An individual who is disbarred is
not eligible to represent taxpayers before
the IRS.
Suspended from practice before the
IRS—An individual who is suspended is
not eligible to represent taxpayers before
the IRS during the term of the suspension.
Censured in practice before the
IRS—Censure is a public reprimand. Un-
like disbarment or suspension, censure
does not affect an individual’s eligibility
to represent taxpayers before the IRS, but
OPR may subject the individual’s future
representations to conditions designed to
promote high standards of conduct.
Monetary penalty—A monetary
penalty may be imposed on an individual
who engages in conduct subject to sanc-
tion or on an employer, firm, or entity
if the individual was acting on its behalf
and if it knew, or reasonably should have
known, of the individual’s conduct.
Disqualification of appraiser—An
appraiser who is disqualified is barred
from presenting evidence or testimony in
any administrative proceeding before the
Department of the Treasury or the IRS.
Under the regulations, attorneys, cer-
tified public accountants, enrolled agents,
enrolled actuaries, and enrolled retirement
plan agents may not assist, or accept assis-
tance from, individuals who are suspended
or disbarred with respect to matters consti-
tuting practice (i.e., representation) before
the IRS, and they may not aid or abet sus-
pended or disbarred individuals to practice
before the IRS.
Disciplinary sanctions are described in
these terms:
Disbarred by decision after hearing,
Suspended by decision after hearing,
Censured by decision after hearing,
Monetary penalty imposed after hear-
ing, and Disqualified after hearing—An
administrative law judge (ALJ) conducted
an evidentiary hearing upon OPR’s com-
plaint alleging violation of the regulations
and issued a decision imposing one of
these sanctions. After 30 days from the
issuance of the decision, in the absence of
an appeal, the ALJ’s decision became the
final agency decision.
Disbarred by default decision, Sus-
pended by default decision, Censured by
default decision, Monetary penalty im-
posed by default decision, and Disqual-
ified by default decision—An ALJ, after
findingthatnoanswertoOPR’scomplaint
had been filed, granted OPR’s motion for a
default judgment and issued a decision im-
posing one of these sanctions.
Disbarment by decision on appeal,
Suspended by decision on appeal, Cen-
sured by decision on appeal, Monetary
penalty imposed by decision on ap-
peal, and Disqualified by decision on
appeal—The decision of the ALJ was
appealed to the agency appeal authority,
acting as the delegate of the Secretary
of the Treasury, and the appeal authority
issued a decision imposing one of these
sanctions.
Disbarred by consent, Suspended by
consent, Censured by consent, Mone-
tary penalty imposed by consent, and
Disqualified by consent—In lieu of a
disciplinary proceeding being instituted
or continued, an individual offered a con-
sent to one of these sanctions and OPR
accepted the offer. Typically, an offer
of consent will provide for: suspension
for an indefinite term; conditions that the
individual must observe during the sus-
pension; and the individual’s opportunity,
after a stated number of months, to file
with OPR a petition for reinstatement af-
firming compliance with the terms of the
consent and affirming current eligibility
to practice (i.e., an active professional
license or active enrollment status). An
enrolled agent or an enrolled retirement
plan agent may also offer to resign in order
to avoid a disciplinary proceeding.
Suspended by decision in expedited
proceeding, Suspended by default de-
cision in expedited proceeding, Sus-
pended by consent in expedited pro-
ceeding—OPR instituted an expedited
proceeding for suspension (based on cer-
tain limited grounds, including loss of a
professional license and criminal convic-
tions).
OPR has authority to disclose the
grounds for disciplinary sanctions in these
situations: (1) an ALJ or the Secretary’s
delegate on appeal has issued a decision
on or after September 26, 2007, which was
theeffectivedateofamendmentstothe
regulations that permit making such deci-
sions publicly available; (2) the individual
has settled a disciplinary case by signing
OPR’s “consent to sanction” form, which
requires consenting individuals to admit to
one or more violations of the regulations
and to consent to the disclosure of the in-
dividual’s own return information related
to the admitted violations (for example,
failure to file Federal income tax returns);
or (3) OPR has issued a decision in an
expedited proceeding for suspension.
Announcements of disciplinary sanc-
tions appear in the Internal Revenue Bul-
letin at the earliest practicable date. The
sanctions announced below are alphabet-
ized first by the names of states and sec-
ond by the last names of individuals. Un-
less otherwise indicated, section numbers
(e.g., § 10.51) refer to the regulations.
City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Alabama
BirminghamMoseley, ChristopherP. AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
April 15, 2010
2010–27 I.R.B.43July 6, 2010

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
California
FresnoFearnside, William L.AttorneySuspended by decision
in expedited proceeding
under § 10.82 (suspension
of attorney license)
Indefinite from
April 15, 2010
BurlingameKassel, Steven H.Enrolled AgentSuspended by consent
for violation of §§ 10.33
(1994), 10.51(a)(7), and
10.51(a)(13) (in that
practitioner made or
furnished, or caused
another person to make or
furnish, false statements
as to the allowability
of various types of
deductions and other
tax benefits which
practitioner knew, or
should have known, were
false.)
Indefinite from
April 1, 2009, but
at least 48 months
PasadenaRodriguez, Stephen A. AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
April 15, 2010
PlacervilleMarty, Teresa M.Enrolled AgentSuspended by default
decision in expedited
proceeding under § 10.82
(permanently enjoined
by U.S. District Court
from acting as a Federal
taxreturnpreparer,
promoting any abusive tax
shelter, and other Federal
tax-related activities)
Indefinite from
May 6, 2010
Monterey ParkMorinaka, GlenCPASuspended by decision
in expedited proceeding
under § 10.82 (revocation
of CPA license)
Indefinite from
April 26, 2010
Long BeachRachele, SusanCPASuspended by decision
in expedited proceeding
under § 10.82 (revocation
of CPA license)
Indefinite from
May 6, 2010
Louisiana
NatchitochesWhitehead, III,
Charles R.
AttorneySuspended by decision
in expedited proceeding
under § 10.82 (suspension
of attorney license)
Indefinite from
May 12, 2010
July 6, 2010442010–27 I.R.B.

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Maryland
BaltimoreDixon, III, IsaiahAttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
May 12, 2010
Massachusetts
East FreetownBarnes, Jr., Donald H. AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
May 12, 2010
BostonCorben, Gary S.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
May 12, 2010
North DartmouthSites, MichaelGAttorneySuspended by decision
in expedited proceeding
under § 10.82 (attorney
disbarment)
Indefinite from
May 12, 2010
Missouri
St. PetersGeiger, David J.Enrolled AgentSuspended by decision in
expedited proceeding
under § 10.82
(permanently enjoined by
U.S. District Court from
promoting the FNS (fuel
from nonconventional
sources) credit scheme or
any other unlawful tax
shelter, preparing Federal
tax returns asserting
frivolous or unrealistic
positions, representing
FNS customers in any
manner before the IRS
relatedtothecustomers’
participation in the
scheme, and other Federal
tax-related activities)
Indefinite from
March 9, 2010
2010–27 I.R.B.45July 6, 2010

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Missouri (Continued)
St. LouisNeel, William G.CPASuspended by decision in
expedited proceeding
under § 10.82
(permanently enjoined by
U.S. District Court from
promoting the FNS (fuel
from nonconventional
sources) credit scheme or
any other unlawful tax
shelter, preparing Federal
tax returns asserting
frivolous or unrealistic
positions, representing
FNS customers in any
manner before the IRS
relatedtothecustomers’
participation in the
scheme, and other Federal
tax-related activities)
Indefinite from
March 9, 2010
New Jersey
JacksonDavis, Richard B.CPASuspended by decision
in expedited proceeding
under § 10.82 (conviction
under 18 U.S.C. § 1001,
making false statements
to the Internal Revenue
Service)
Indefinite from
April 26, 2010
StewartsvilleRobinson, Loren K.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
May 12, 2010
New York
UticaKoziol, Leon R.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
May 12, 2010
BrooklynLewis, John D.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
May 12, 2010
BrooklynShweky, Alan J.AttorneySuspended by decision
in expedited proceeding
under § 10.82 (attorney’s
resignation from practice
of law)
Indefinite from
May 12, 2010
July 6, 2010462010–27 I.R.B.

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
North Carolina
TimberlakeFarless, James M.CPASuspended by default
decision in expedited
proceeding under § 10.82
(suspension of CPA
license)
Indefinite from
May 12, 2010
Four OaksHatch, Jonathan L.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
May 12, 2010
ElkinNeaves, William A.CPASuspended by default
decision in expedited
proceeding under § 10.82
(revocation of CPA
license)
Indefinite from
May 12, 2010
2010–27 I.R.B.47July 6, 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.
July 6, 2010i2010–27 I.R.B.

Numerical Finding List
1
Bulletin 2010–27
Announcements:
2010-43, 2010-27 I.R.B.42
Notices:
2010-48, 2010-27 I.R.B.9
2010-49, 2010-27 I.R.B.10
2010-50, 2010-27 I.R.B.12
Proposed Regulations:
REG-112841-10, 2010-27 I.R.B.41
Revenue Procedures:
2010-25, 2010-27 I.R.B.16
Revenue Rulings:
2010-18, 2010-27 I.R.B.1
Treasury Decisions:
9486, 2010-27 I.R.B.3
1
A cumulative list of all revenue rulings, revenueprocedures, Treasury decisions, etc., publishedin Internal Revenue Bulletins 2010–1 through 2010–26 is in Internal Revenue Bulletin
2010–26, dated June 28, 2010.
2010–27 I.R.B.iiJuly 6, 2010

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2010–27
Revenue Procedures:
2007-44
Modified by
Notice 2010-48, 2010-27 I.R.B.9
2009-18
Obsoleted in part by
Rev. Proc. 2010-25, 2010-27 I.R.B.16
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2010–1 through 2010–26 is in Internal Revenue Bulletin 2010–26, dated June 28, 2010.
July 6, 2010iii2010–27 I.R.B.

2010–27 I.R.B.July 6, 2010

July 6, 20102010–27 I.R.B.

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