Internal Revenue Bulletin 2021-8 (PDF rendition): IRS Announcements

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Bulletin No. 2021–8
February 22, 2021
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.
ADMINISTRATIVE
Announcement 2021-2, page 892.
This announcement notifies lenders who have filed or fur-
nished Forms 1099-MISC, Miscellaneous Information, report-
ing certain payments on loans subsidized by the Administra-
tor of the U.S. Small Business Administration as income of
the borrower, that the lenders must file and furnish corrected
Forms 1099-MISC that exclude these subsidized loan pay-
ments. This accords with section 278(e)(1) of the COVID-re-
lated Tax Relief Act, which provides that these payments
are not includible in the gross income of the borrowers; and
Notice 2021-6, waiving Form 1099-MISC reporting require-
ments for these payments.
Announcement 2021-3, page 892.
The Office of Professional Responsibility (OPR) announces re-
cent disciplinary sanctions involving attorneys, certified pub-
lic accountants, enrolled agents, enrolled actuaries, enrolled
retirement plan agents, and appraisers. These individuals are
subject to the regulations governing practice before the Inter-
nal Revenue Service (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.
Rev. Proc. 2021-15, page 891.
This revenue procedure provides a safe harbor for eli-
gible educators, within the meaning of § 62(d)(1) of the
Internal Revenue Code, to treat unreimbursed expens-
es paid or incurred after March 12, 2020, for personal
protective equipment, disinfectant, and other supplies
used for the prevention of the spread of COVID–19
in the classroom, as expenses that are described in
§ 62(a)(2)(D)(ii) and allowable as a deduction under §
62(a)(2)(D) pursuant to section 275 of the COVID-relat-
ed Tax Relief Act of 2020, which was enacted as part
of the Consolidated Appropriations Act, 2021, Pub. L.
No. 116-260, 134 Stat. 1182, 1978 (2020).
Finding Lists begin on page ii.

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and en-
force the law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing of-
ficial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
general interest. It is published weekly.
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,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of inter-
nal management 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 rul-
ings 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.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal 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,
Legislation 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
Rulings. Bank Secrecy Act Administrative Rulings are issued
by the Department of the Treasury’s Office of the Assistant
Secretary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and 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 contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
February 22, 2021 Bulletin No. 2021–8

Part I
26 CFR 601.105: Examination of returns and
claims for refund, credit, or abatement; determi-
nation of correct tax liability. (Also: Part I, §§ 62,
162)
Rev. Proc. 2021-15
SECTION 1. PURPOSE
This revenue procedure provides a safe
harbor for eligible educators, within the
meaning of § 62(d)(1) of the Internal Rev-
enue Code (Code), to treat unreimbursed
expenses paid or incurred after March
12, 2020, for personal protective equip-
ment, disinfectant, and other supplies
(COVID-19 Protective Items) used for the
prevention of the spread of COVID–19
in the classroom, as expenses that are de-
scribed in § 62(a)(2)(D)(ii) and allowable
as a deduction under § 62(a)(2)(D) pursu-
ant to section 275 of the COVID-related
Tax Relief Act of 2020 (COVID Tax Re-
lief Act), which was enacted as part of the
Consolidated Appropriations Act, 2021,
Pub. L. No. 116-260, 134 Stat. 1182, 1978
(2020).
SECTION 2. BACKGROUND
.01 Section 62 of the Code sets forth
the deductions an individual may deduct
from gross income in arriving at adjusted
gross income. Section 62(a)(2)(D) pro-
vides, in part, that deductions allowed
under § 162 not in excess of $250 ($500
if married filing jointly and both spouses
are eligible educators, but not more than
$250 each) that consist of unreimbursed
expenses described in § 62(a)(2)(D)(ii)
that are paid or incurred by an eligible
educator may be deducted in arriving at
gross income. The unreimbursed expens-
es described in § 62(a)(2)(D)(ii) are those
paid or incurred by an eligible educator
in connection with books, supplies (other
than nonathletic supplies for courses of in-
struction in health or physical education),
computer equipment (including related
software and services), other equipment,
and supplementary materials used by the
eligible educator in the classroom.
.02 Section 62(d)(1)(A) defines an “el-
igible educator” as any individual who is
a kindergarten through grade 12 teacher,
instructor, counselor, principal, or aide
in a school for at least 900 hours during
a school year. Section 62(d)(1)(B) defines
a “school” as any school which provides
elementary or secondary education, as de-
termined under State law.
.03 For an unreimbursed expense to be
deducted from gross income in arriving at
adjusted gross income under § 62(a)(2)
(D), the expense must be allowed as a de-
duction under § 162(a) of the Code as an
ordinary and necessary expense paid or in-
curred during the taxable year in carrying
on the eligible educator’s trade or business
of performing services as an employee.
.04 Section 275 of the COVID Tax Re-
lief Act requires the Secretary of the Trea-
sury or the Secretary’s delegate to clarify
that COVID-19 Protective Items used for
the prevention of the spread of COVID-19
are treated as described in § 62(a)(2)(D)
(ii) if paid or incurred by an eligible edu-
cator after March 12, 2020.
SECTION 3. SAFE HARBOR FOR
COVID-19 PROTECTIVE ITEMS
UNDER § 62(a)(2)(D)
In accordance with section 275 of the
COVID Tax Relief Act, an eligible edu-
cator may treat unreimbursed expenses
paid or incurred after March 12, 2020, for
COVID-19 Protective Items that are, or
will be, used by that eligible educator for
the prevention of the spread of COVID-19
in the classroom, as expenses that are de-
scribed in § 62(a)(2)(D)(ii) and allowable
as a deduction under § 62(a)(2)(D), sub-
ject to the aggregate dollar limitation pro-
vided in such provision. For purposes of
this revenue procedure, COVID-19 Pro-
tective Items include, but are not limited
to: face masks; disinfectant for use against
COVID-19; hand soap; hand sanitizer;
disposable gloves; tape, paint or chalk
used to guide social distancing; physical
barriers (for example, clear plexiglass);
air purifiers; and other items recommend-
ed by the Centers for Disease Control and
Prevention (CDC) to be used for the pre-
vention of the spread of COVID-19.
SECTION 4. APPLICABILITY
This revenue procedure applies to unre-
imbursed expenses paid or incurred by an
eligible educator after March 12, 2020, for
COVID-19 Protective Items used for the
prevention of the spread of COVID–19 in
the classroom.
SECTION 5. CONTACT
INFORMATION
The principal authors of this revenue
procedure are Sharon Horn and Edward
Schwartz of the Office of the Associate
Chief Counsel (Income Tax and Account-
ing). For further information regarding
this revenue procedure contact Sharon
Horn at (202) 317-7003 (for questions re-
lating to § 162), or Edward Schwartz at
(202) 317-7006 (for questions relating to
§ 62(a)(2)) (not a toll-free number).
Bulletin No. 2021–8 891 February 22, 2021

Part IV
Correction of Forms 1099-
MISC for Certain CARES
Act Subsidized Loan
Payments
Announcement 2021-2
This announcement notifies lenders
who have filed with the Internal Revenue
Service (IRS), or furnished to a borrower,
a Form 1099-MISC, Miscellaneous In-
formation, reporting certain payments on
loans subsidized by the Administrator of
the U.S. Small Business Administration
(Administrator) as income of the borrow-
er that the lenders must file and furnish
corrected Forms 1099-MISC that exclude
these subsidized loan payments.
Section 1112(c) of the Coronavirus
Aid, Relief, and Economic Security Act,
Pub. L. No. 116-136, 134 Stat. 281, 309-
310 (March 27, 2020) (CARES Act), 15
U.S.C. 9011(c), authorizes the Admin-
istrator to subsidize certain payments of
principal, interest, and any associated fees
owed by a borrower on certain loans. Sec-
tion 278(c)(1) of the COVID-related Tax
Relief Act of 2020 (COVID Relief Act),
enacted as Subtitle B of Title II of Divi-
sion N of the Consolidated Appropriations
Act, 2021, Pub. L. 116-260, 134 Stat.1182
(December 27, 2020), retroactively pro-
vides that such a payment is not includ-
ed in the gross income of the person on
whose behalf the payment is made. This
provision is effective for taxable years
ending after March 27, 2020, the date of
the enactment of the CARES Act. Section
278(e)(1) of the COVID Relief Act. Sec-
tion 278(c)(2) provides that no deduction
shall be denied by reason of the exclusion
of the loan payments from gross income.
Section 279 of the COVID Relief Act
authorizes the Secretary of the Treasury
or the Secretary’s delegate to provide an
exception with respect to any amount
excluded from gross income by reason
of section 278 of the COVID Relief Act
from any requirement to file an infor-
mation return otherwise required under
chapter 61 of the Internal Revenue Code
(Code), including information returns and
payee statements required to be filed or
furnished under section 6041 of the Code.
On January 19, 2021, the Department
of the Treasury and the IRS issued, pur-
suant to section 279 of the COVID Relief
Act, Notice 2021-6, 2021-06 I.R.B. 822,
to waive the requirement for lenders to file
with the IRS, or furnish to a borrower, a
Form 1099-MISC reporting the payment
of principal, interest, and any associated
fees subsidized by the Administrator un-
der section 1112(c) of the CARES Act.
The filing of information returns that in-
clude these loan payments could result in
IRS correspondence to borrowers regard-
ing underreported income, and the fur-
nishing of payee statements that include
these loan payments to borrowers could
cause confusion.
If a lender has already furnished to
borrowers Forms 1099-MISC that report
these loan payments, whether before, on,
or after December 27, 2020, the lender
must furnish to the borrowers correct-
ed Forms 1099-MISC that exclude these
loan payments. In addition, if a lender has
already filed with the IRS Forms 1099-
MISC that report these loan payments,
whether before, on, or after December 27,
2020, the lender must file with the IRS
corrected Forms 1099-MISC that exclude
these loan payments. Directions for how
to file corrected Forms 1099-MISC are in-
cluded in the 2020 Instructions for Forms
1099-MISC and 1099-NEC and the 2020
General Instructions for Certain Informa-
tion Returns. If a lender described in this
announcement furnishes corrected payee
statements within 30 days of the furnish-
ing deadline, it will have reasonable cause
for any failure-to-furnish penalty imposed
under section 6722. A lender described in
this announcement must file corrected in-
formation returns by the filing deadline in
order to avoid section 6721 failure-to-file
penalties.
The principal author of this announce-
ment is Isaac Brooks Fishman of the Of-
fice of the Associate Chief Counsel (Pro-
cedure & Administration). For further
information regarding this announcement,
contact Isaac Brooks Fishman at (202)
317-5436 (not a toll-free number).

Announcement of
Disciplinary Sanctions
From the Office of
Professional Responsibility
Announcement 2021-3
The Office of Professional Respon-
sibility (OPR) announces recent disci-
plinary sanctions involving attorneys, cer-
tified public accountants, enrolled agents,
enrolled actuaries, enrolled retirement
plan agents, appraisers, and unenrolled/
unlicensed return preparers (individuals
who are not enrolled to practice and are
not licensed as attorneys or certified pub-
lic accountants). Licensed or enrolled
practitioners are subject to the regulations
governing practice before the Internal
Revenue Service (IRS), which are set out
in Title 31, Code of Federal Regulations,
Subtitle A, Part 10, and which are released
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. Unenrolled/
unlicensed return preparers are subject to
Revenue Procedure 81-38 and supersed-
ing guidance in Revenue Procedure 2014-
42, which govern a preparer’s eligibility
to represent taxpayers before the IRS in
examinations of tax returns the preparer
both prepared for the taxpayer and signed
as the preparer. Additionally, unenrolled/
unlicensed return preparers who volun-
tarily participate in the Annual Filing Sea-
son Program under Revenue Procedure
2014-42 agree to be subject to the duties
and restrictions in Circular 230, including
the restrictions on incompetent or disrep-
utable conduct.
The disciplinary sanctions to be im-
posed for violation of the applicable stan-
dards are:
Disbarred from practice before the
IRS—An individual who is disbarred
is not eligible to practice before the IRS
as defined at 31 C.F.R. § 10.2(a)(4) for a
minimum period of five (5) years.
Suspended from practice before the
IRS—An individual who is suspended is
February 22, 2021 892 Bulletin No. 2021–8

Bulletin No. 2021–8 893 February 22, 2021
not eligible to practice before the IRS as
defined at 31 C.F.R. § 10.2(a)(4) 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 practice before the IRS, but OPR may
subject the individual’s future practice
rights to conditions designed to promote
high standards of conduct.
Monetary penalty—A monetary pen-
alty may be imposed on an individual who
engages in conduct subject to sanction,
or on an employer, firm, or entity if the
individual was acting on its behalf and 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.
Ineligible for limited practice—An
unenrolled/unlicensed return preparer
who fails to comply with the requirements
in Revenue Procedure 81-38 or to comply
with Circular 230 as required by Revenue
Procedure 2014-42 may be determined in-
eligible to engage in limited practice as a
representative of any taxpayer.
Under the regulations, individuals sub-
ject to Circular 230 may not assist, or ac-
cept assistance from, individuals who are
suspended or disbarred with respect to
matters constituting practice (i.e., repre-
sentation) before the IRS, and they may
not aid or abet suspended or disbarred in-
dividuals to practice before the IRS.
Disciplinary sanctions are described in
these terms:
Disbarred by decision, Suspended by
decision, Censured by decision, Mone-
tary penalty imposed by decision, and
Disqualified after hearing—An adminis-
trative law judge (ALJ) issued a decision
imposing one of these sanctions after the
ALJ either (1) granted the government’s
summary judgment motion or (2) con-
ducted an evidentiary hearing upon OPR’s
complaint alleging violation of the regu-
lations. After 30 days from the issuance
of the decision, in the absence of an ap-
peal, the ALJ’s decision becomes the final
agency decision.
Disbarred by default decision, Sus-
pended by default decision, Censured
by default decision, Monetary penalty
imposed by default decision, and Dis-
qualified by default decision—An ALJ,
after finding that no answer to OPR’s
complaint was filed, granted OPR’s mo-
tion for a default judgment and issued
a decision imposing one of these sanc-
tions.
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 consent
to one of these sanctions and OPR accept-
ed the offer. Typically, an offer of consent
will provide for: suspension for an indef-
inite term; conditions that the individual
must observe during the suspension; and
the individual’s opportunity, after a stat-
ed number of months, to file with OPR a
petition for reinstatement affirming com-
pliance with the terms of the consent and
affirming current fitness and eligibility
to practice (i.e., an active professional li-
cense or active enrollment status, with no
intervening violations of the regulations).
Suspended indefinitely by decision in
expedited proceeding, Suspended indef-
initely by default decision in expedited
proceeding, Suspended by consent in
expedited proceeding—OPR instituted
an expedited proceeding for suspension
(based on certain limited grounds, in-
cluding loss of a professional license for
cause, and criminal convictions).
Determined ineligible for limited
practice---There has been a final deter-
mination that an unenrolled/unlicensed
return preparer is not eligible for limited
representation of any taxpayer because the
preparer violated standards of conduct or
failed to comply with any of the require-
ments to act as a representative.
A practitioner who has been disbarred
or suspended under 31 C.F.R. § 10.60, or
suspended under § 10.82, or a disquali-
fied appraiser may petition for reinstate-
ment before the IRS after the expiration
of 5 years following such disbarment,
suspension, or disqualification (or im-
mediately following the expiration of the
suspension or disqualification period if
shorter than 5 years). Reinstatement will
not be granted unless the IRS is satisfied
that the petitioner is not likely to engage
thereafter in conduct contrary to Circular
230, and that granting such reinstatement
would not be contrary to the public in-
terest.
Reinstatement decisions are published
at the individual’s request, and described
in these terms:
Reinstated to practice before the
IRS---The individual’s petition for re-
instatement has been granted. The
agent, and eligible to practice before the
IRS, or in the case of an appraiser, the in-
dividual is no longer disqualified.
Reinstated to engage in limited
practice before the IRS---The individ-
ual’s petition for reinstatement has been
granted. The individual is an unenrolled/
unlicensed return preparer and eligible to
engage in limited practice before the IRS,
subject to requirements the IRS has pre-
scribed for limited practice by tax return
preparers.
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 final de-
cision; (2) the individual has settled a dis-
ciplinary case by signing OPR’s “consent
to sanction” agreement admitting to one
or more violations of the regulations and
consenting to the disclosure of the admit-
ted violations (for example, failure to file
Federal income tax returns, lack of due
diligence, conflict of interest, etc.); (3)
OPR has issued a decision in an expedited
proceeding for indefinite suspension; or
(4) OPR has made a final determination
(including any decision on appeal) that an
unenrolled/unlicensed return preparer is
ineligible to represent any taxpayer before
the IRS.
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 state and second by the last
names of the sanctioned individuals.

February 22, 2021 894 Bulletin No. 2021–8
City & State
NameProfessional
Designation
Disciplinary SanctionEffective Date(s)
Alabama
HuntsvilleCutter, Harvey F.C PASuspended by default decision
in expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
October 21, 2020
Arizona
Lake Havasu
City
Bersch, Lance M.C PASuspended by default decision
in expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
November 24, 2020
California
ChicoBroiles, Gregory A.C PASuspended by default decision
in expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
November 10, 2020
Irvine Azavedo, Anthony J.C PASuspended by default decision
in expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
December 2, 2020
ModestoWaggle, Stephen L.Unenrolled Tax
Return Preparer
Reinstated to practice before
the IRS, effective
November 24, 2020
MoragaRosso, Randolph J.C PASuspended by default decision
in expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
November 24, 2020
Florida
Boca RatonWilliams, Jonathan C.C PASuspended by default decision
in expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
November 10, 2020
Michigan
Royal OakAbraham, Phillip J.C PASuspended by default decision
in expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
December 2, 2020
North Carolina
CorneliusHanzel, John F.AttorneySuspended by default decision
in expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
October 14, 2020
New York
New YorkMiu, Christopher K.C PASuspended by decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
December 10, 2020
Pennsylvania
Mountain TopKamor, AdamC PASuspended by default decision
in expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
October 14, 2020
WindberThomas, GeorgeC PASuspended by decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
November 24, 2020

Bulletin No. 2021–8 i February 22, 2021
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
effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the 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 with
modified, below).
Clarified is 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 rul-
ing is being changed.
Distinguished describes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modified is 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
with amplified and clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transactions.
This term is most commonly used in a ruling
that lists previously published rulings 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.
Revoked describes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a
period of time in separate rulings. If the
new ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example, modified and
superseded describes 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 previous-
ly published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplemented is 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
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspended is 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 cas-
es in litigation, or the outcome of a Ser-
vice study.
Abbreviations
The following abbreviations in current use
and formerly used will appear in material
published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
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—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.

February 22, 2021 ii Bulletin No. 2021–8
Numerical Finding List
1
Bulletin 2021–8
Announcements:
2021-01, 2021-04 I.R.B. 506
2021-02, 2021-08 I.R.B. 892
2021-03, 2021-08 I.R.B. 892
Notices:
2021-01, 2021-02 I.R.B. 315
2021-03, 2021-02 I.R.B. 316
2021-04, 2021-02 I.R.B. 319
2021-02, 2021-03 I.R.B. 478
2021-05, 2021-03 I.R.B. 479
2021-07, 2021-03 I.R.B. 482
2021-09, 2021-05 I.R.B. 678
2021-06, 2021-06 I.R.B. 822
2021-08, 2021-06 I.R.B. 823
2021-11, 2021-06 I.R.B. 827
2021-12, 2021-06 I.R.B. 828
2021-13, 2021-06 I.R.B. 832
2021-10, 2021-07 I.R.B. 888
Proposed Regulations:
REG-130081-19, 2021-02 I.R.B. 321
REG-114615-16, 2021-03 I.R.B. 489
REG-111950-20, 2021-05 I.R.B. 683
REG-115057-20, 2021-05 I.R.B. 714
Revenue Procedures:
2021-01, 2020-01 I.R.B. 1
2021-02, 2020-01 I.R.B. 116
2021-03, 2020-01 I.R.B. 140
2021-04, 2020-01 I.R.B. 157
2021-05, 2020-01 I.R.B. 250
2021-07, 2020-01 I.R.B. 290
2021-09, 2020-03 I.R.B. 485
2021-08, 2020-04 I.R.B. 502
2021-10, 2020-04 I.R.B. 503
2021-12, 2020-05 I.R.B. 681
2021-11, 2020-06 I.R.B. 833
2021-15, 2020-08 I.R.B. 891
Revenue Rulings:
2021-01, 2021-02 I.R.B. 294
2021-02, 2021-04 I.R.B. 495
2021-03, 2021-05 I.R.B. 674
2021-04, 2021-06 I.R.B. 724
Treasury Decisions:
9925, 2021-02 I.R.B. 296
9940, 2021-02 I.R.B. 311
9932, 2021-03 I.R.B. 345
9939, 2021-03 I.R.B. 376
Treasury Decisions:—Continued
9941, 2021-03 I.R.B. 396
9942, 2021-03 I.R.B. 450
9937, 2021-04 I.R.B. 495
9936, 2021-05 I.R.B. 508
9943, 2021-05 I.R.B. 577
9945, 2021-05 I.R.B. 627
9946, 2021-06 I.R.B. 726
9947, 2021-06 I.R.B. 748
9948, 2021-06 I.R.B. 801
9938, 2021-07 I.R.B. 838
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin
2020–52, dated December 27, 2020.

Bulletin No. 2021–8 iii February 22, 2021
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2021–8
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin
2020–52, dated December 27, 2020.

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Washington, DC 20224
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