Internal Revenue Bulletin 2015-38 (PDF rendition): IRS Revenue Procedures

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

# INTERNAL REVENUE BULLETIN

IRS

## 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

Announcement 2015-20, page 355.

The Office of Professional Responsibility (OPR) announces re-
cent disciplinary sanctions involving attorneys, certified public
accountants, enrolled agents, enrolled actuaries, enrolled re-
tirement 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 vio-
lating the regulations.

Bulletin No. 2015-38
September 21, 2015

### Rev. Rul. 2015-20, page 353.

Fringe benefits aircraft valuation formula. For purposes of
section 1.61-21(g) of the Income Tax Regulations, relating to
the rule for valuing non-commercial flights on employer-
provided aircraft, the Standard Industry Fare Level (SIFL) cents-
per-mile rates and terminal charge in effect for the second half
of 2015 are set forth.

## ADMINISTRATIVE

Rev. Proc. 2015-44, page 354.

This revenue procedure announces the elimination of the Ap-
peals arbitration program and obsoletes Revenue Procedure
2006-44, 2006-2 C.B. 800, which formally established the
Appeals arbitration program.

## 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 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.

It is the policy of the Service to publish in the Bulletin all
substantive 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 internal
management are not published; however, statements of inter-
nal 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, identify-
ing 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, Legisla-
tion 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 Sec-
retary (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.

# Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

## Section 61 .- Gross Income Defined

26 CFR 1.61-21: Taxation of fringe benefits.

## Rev. Rul. 2015-20

For purposes of the taxation of fringe
benefits under section 61 of the Internal
Revenue Code, section 1.61-21(g) of the

Income Tax Regulations provides a rule
for valuing noncommercial flights on
employer-provided aircraft. Section 1.61-
21(g)(5) provides an aircraft valuation
formula to determine the value of such
flights. The value of a flight is determined
under the base aircraft valuation formula
(also known as the Standard Industry Fare
Level formula or SIFL) by multiplying the
SIFL cents-per-mile rates applicable for

the period during which the flight was
taken by the appropriate aircraft multiple
provided in section 1.61-21(g)(7) and
then adding the applicable terminal
charge. The SIFL cents-per-mile rates in
the formula and the terminal charge are
calculated by the Department of Transpor-
tation and are reviewed semi-annually.

The following chart sets forth the ter-
minal charge and SIFL mileage rates:

Period During Which the Flight Is Taken

Terminal Charge

SIFL Mileage Rates

7/1/15-12/31/15

$42.79

Up to 500 miles = $.2341 per mile 501-1500 miles = $.1785 per mile Over 1500 miles = $.1716 per mile

## DRAFTING INFORMATION

The principal author of this revenue
ruling is Kathleen Edmondson of the Of-

fice of Associate Chief Counsel (Tax Ex-
empt/Government Entities). For further
information regarding this revenue ruling,

contact Ms. Edmondson at (202) 317-6798
(not a toll-free number).

# Part III. Administrative, Procedural, and Miscellaneous

26 CFR 601.106: Appeals Functions (Also: §§ 601.202,
601.203; and Part I, § 7123(b)

## Administrative, Procedural, and Miscellaneous

Rev. Proc. 2015-44

### SECTION 1. PURPOSE

This revenue procedure announces the
elimination of the Appeals arbitration pro-
gram and obsoletes Revenue Procedure
2006-44, 2006-2 C.B. 800, which for-
mally established the Appeals arbitration
program.

### SECTION 2. BACKGROUND

Section 7123(b)(2) of the Code re-
quires that the IRS establish a pilot pro-
gram under which a taxpayer and Appeals
may jointly request binding arbitration on
any issue unresolved at the conclusion of
appeals procedures or unsuccessful at-
tempts to enter into a closing agreement
under section 7121 or a compromise un-
der section 7122. To comply with section
7123(b), on January 18, 2000, Appeals
initiated a two-year pilot program offering
arbitration procedures. See Announce-
ment 2000-4, 2000-1 C.B. 317. On June
30, 2003, Appeals completed an addi-
tional one-year pilot of its arbitration pro-
cedures. See Announcement 2002-60,
2002-2 C.B. 28. During these pilot pro-
grams, Appeals offered an opportunity for
taxpayers to request arbitration for certain

factual issues that were already subject to
the Appeals administrative process. On
October 30, 2006, the IRS published Rev.
Proc. 2006-44, 2006-2 C.B. 800, which
formally established the Appeals arbitra-
tion program. Generally, arbitration has
been available under these procedures for
cases in which a limited number of factual
issues remain unresolved following settle-
ment discussions in Appeals.

In Announcement 2008-111, 2008-48
I.R.B. 1224, published December 1, 2008,
partially superseded by Rev. Proc. 2014-
63, 2014-53 I.R.B. 1014, Appeals estab-
lished a two-year pilot program to extend
arbitration to certain collection cases. Under
the pilot program, taxpayers in select cities
were eligible to use arbitration to resolve
certain offer in compromise and Trust Fund
Recovery Penalty issues. Announcement
2011-6, 2011-4 I.R.B. 433, published Jan-
uary 24, 2011, partially superseded by Rev.
Proc. 2014-63, 2014-53 I.R.B. 1014, ex-
tended the pilot without change through De-
cember 31, 2012.

# SECTION 3. ELIMINATION OF APPEALS ARBITRATION PROGRAM

This revenue procedure obsoletes Rev.
Proc. 2006-44 and eliminates the Ap-
peals arbitration program. During the
fourteen-year period in which arbitration
was available, only two cases were settled
using arbitration. Given the general lack
of demand for arbitration and the fact that
its use as a tool to settle disputes without

litigation has not proven successful, the
IRS is eliminating the arbitration program.
Although Appeals arbitration is being
eliminated, taxpayers may be eligible to
request mediation for unresolved issues
that remain after completion of settlement
discussions in Appeals. See Rev. Proc.
2014-63, 2014-53 I.R.B. 1014.

# SECTION 4. EFFECTIVE DATE

The elimination of the Appeals arbitra-
tion program is effective September 8,
2015.

# SECTION 5. EFFECT ON OTHER DOCUMENTS

Revenue Procedure 2006-44, An-
nouncement 2008-111, and Announce-
ment 2011-6 are obsoleted.

# DRAFTING INFORMATION

The principal authors of this revenue
procedure are Alicia Goldstein, Office of
Chief Counsel, Procedure and Adminis-
tration, Charmaine Osbin, Office of Ap-
peals, Tax Policy and Procedure for non-
collection cases, and John Gonzalez,
Office of Appeals, Tax Policy and Proce-
dure for offer in compromise and Trust
Fund Recovery Penalty cases. For further
information regarding this revenue proce-
dure, contact Ms. Goldstein at (202) 317-
3600, Ms. Osbin at (281) 721-7275, or
Mr. Gonzalez at (415) 281-7837 (not toll-
free calls).

# Part IV. Items of General Interest

## Announcement of Disciplinary Sanctions From the Office of Professional Responsibility Announcement 2015-20

The Office of Professional Responsi-
bility (OPR) announces recent disciplin-
ary sanctions involving attorneys, certi-
fied 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 vi-
olating the regulations. Unenrolled/unli-
censed return preparers are subject to
Revenue Procedure 81-38 and supersed-
ing guidance in Revenue Procedure
2014-42, which govern a preparer's eli-
gibility 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 voluntarily participate in the Annual
Filing Season Program under Revenue
Procedure 2014-42 agree to be subject to
the duties and restrictions in Circular 230,
including the restrictions on incompetent
or disreputable 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
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 in-
dividual 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 2014-42may be determined
ineligible to engage in limited practice as
a representative of any taxpayer.

Under the regulations, individuals sub-
ject to Circular 230 may not assist, or
accept 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
individuals 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 appeal,
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 sanctions.

Disbarment by decision on appeal,
Suspended by decision on appeal, Cen-
sured by decision on appeal, Monetary
penalty imposed by decision on appeal,
and Disqualified by decision on ap-
peal-The decision of the ALJ was ap-
pealed to the agency appeal authority, act-
ing as the delegate of the Secretary of the
Treasury, and the appeal authority issued
a decision imposing one of these sanc-
tions.

Disbarred by consent, Suspended by
consent, Censured by consent, Mone-
tary penalty imposed by consent, and
Disqualified by consent-In lieu of a dis-
ciplinary proceeding being instituted or
continued, an individual offered a consent
to one of these sanctions and OPR ac-
cepted the offer. Typically, an offer of
consent will provide for: suspension for
an indefinite term; conditions that the in-
dividual must observe during the suspen-
sion; and the individual's opportunity, af-
ter a stated number of months, to file with
OPR a petition for reinstatement affirming
compliance with the terms of the consent
and affirming current fitness and eligibil-
ity to practice (i.e., an active professional
license or active enrollment status, with
no intervening violations of the regula-
tions).

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, includ-
ing loss of a professional license for
cause, and criminal convictions).

Determined ineligible for limited
practice-There has been a final determi-
nation that an unenrolled/unlicensed re-
turn 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.

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.

City &amp; State

Name

Professional Designation

Disciplinary Sanction

Effective Date(s)

California

San Diego

Ewing, Anton A.

CPA

Suspended by decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Indefinite from May 5, 2015

Woodland Hills

Huberman, Murray J.

Enrolled Agent

Suspended by consent under 31 C.F.R. §§ 10.50 and 10.61(b)

Effective November 21, 2014

Lompoc

Martinez, Steven

CPA

Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Indefinite from April 10, 2015

Chino Hills

Padilla, Dwight A.

Enrolled Agent

Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Indefinite from April 28, 2015

Canyon Country

Shroff, Vispi B.

CPA

Suspended by decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Indefinite from April 10, 2015

Connecticut

Woodbridge

Gruenbaum, Jerry

Attorney

Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Indefinite from May 26, 2015

Wethersfield

Ziro, Kenneth A.

Enrolled Agent

Suspended by decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Indefinite from June 30, 2015

Massachusetts

Framingham

Gruenbaum, Jerry, see Connecticut Tracia, Douglas F.

Attorney

Suspended by decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Indefinite from May 6, 2015

Missouri Black Jack

Burns, Joseph L.

Enrolled Agent

Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Indefinite from May 15, 2015

St. Louis

Croft, Thomas C

Attorney

Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Indefinite from May 6, 2015

Saint Charles

Witt, Jeffrey M.

Attorney

Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Indefinite from May 26, 2015

Kansas City

Wirken, James C.

Attorney

Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Indefinite from May 5, 2015

City &amp; State

Name

Professional Designation

Disciplinary Sanction

Effective Date(s)

New York Bronxville

McGraw, Kevin J.

Attorney

Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Indefinite from April 30, 2015

Nevada

Indefinite from April 10, 2015

Ely

Hendrix, Bruce W.

CPA

Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

North Carolina

Summerfield

Callaway, Jr., Paul F.

Unenrolled Preparer

Reinstated to practice before the IRS April 8, 2015

Oregon

Indefinite from April 30, 2015

Beaverton

Cyr, Steven M.

Attorney

Suspended by default decision in ex- pedited proceeding under 31 C.F.R. § 10.82(b)

Pennsylvania

Northampton

Szerencsits, Jr, Joseph

CPA

Suspended by default decision in ex- pedited proceeding under 31 C.F.R. § 10.82(b)

Indefinite from April 30, 2015

Virginia

Falls Church

O'Connor, Michael F.

CPA

Suspended by decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Indefinite from April 30, 2015

Fairfax

Shin, Jenny

Attorney

Suspended by default decision in ex- pedited proceeding under 31 C.F.R. § 10.82(b)

Indefinite from May 5, 2015

# 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
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling 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 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.

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 pe-
riod 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 previously
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
cases in litigation, or the outcome of a
Service study.

# Abbreviations

The following abbreviations in current
use and formerly used will appear in ma-
terial published in the Bulletin.

A-Individual.

Acq .- Acquiescence.

B-Individual.

BE-Beneficiary.

F.R .- Federal Register.

FUTA-Federal Unemployment Tax Act.

FX-Foreign corporation.

G.C.M .- Chief Counsel's Memorandum.

GE-Grantee.

TFE-Transferee.

TFR-Transferor.

CI-City.

GR-Grantor.

IC-Insurance Company.

TP-Taxpayer.

Ct.D .- Court Decision.

I.R.B .- Internal Revenue Bulletin.

TR-Trust.

CY-County.

LE-Lessee.

TT-Trustee.

D-Decedent.

LP-Limited Partner.

DC-Dummy Corporation.

LR-Lessor.

M-Minor.

Nonacq .- Nonacquiescence.

O Organization.

DR-Donor.

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.

C-Individual.

T.D .- Treasury Decision.

C.B .- Cumulative Bulletin.

CFR-Code of Federal Regulations.

GP-General Partner.

T.I.R .- Technical Information Release.

U.S.C .- United States Code.

X-Corporation.

DE-Donee.

Del. Order-Delegation Order.

DISC-Domestic International Sales Corporation.

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.

BK-Bank.

B.T.A .- Board of Tax Appeals.

COOP-Cooperative.

Y-Corporation.

Z-Corporation.

## Numerical Finding List1

Bulletins 2015-27 through 2015-38

### Announcements:

2015-17, 2015-28 I.R.B. 67
2015-18, 2015-33 I.R.B. 198

2015-19, 2015-32 I.R.B. 157
2015-20, 2015-38 I.R.B. 355
2015-21, 2015-34 I.R.B. 220
2015-22, 2015-35 I.R.B. 288
2015-23, 2015-36 I.R.B. 311
2015-24, 2015-36 I.R.B. 313

### Notices:

2015-43, 2015-29 I.R.B. 73
2015-46, 2015-28 I.R.B. 64

2015-47, 2015-30 I.R.B. 76
2015-48, 2015-30 I.R.B. 77
2015-49, 2015-30 I.R.B. 79
2015-50, 2015-30 I.R.B. 81
2015-51, 2015-31 I.R.B. 133
2015-52, 2015-35 I.R.B. 227
2015-53, 2015-33 I.R.B. 190
2015-54, 2015-34 I.R.B. 210
2015-55, 2015-34 I.R.B. 217
2015-56, 2015-35 I.R.B. 235
2015-57, 2015-36 I.R.B. 294
2015-58, 2015-37 I.R.B. 322

### Proposed Regulations:

REG-136459-09, 2015-37 I.R.B. 332
REG-109370-10, 2015-33 I.R.B. 198
REG-103033-11, 2015-37 I.R.B. 325
REG-109813-11, 2015-37 I.R.B. 330
REG-115452-14, 2015-32 I.R.B. 158
REG-132075-14, 2015-35 I.R.B. 288
REG-138526-14, 2015-28 I.R.B. 67
REG-143800-14, 2015-37 I.R.B. 347
REG-102648-15, 2015-31 I.R.B. 134
REG-102837-15, 2015-27 I.R.B. 43
REG-123640-15, 2015-37 I.R.B. 350

### Revenue Procedures:

2015-34, 2015-27 I.R.B. 4

2015-36, 2015-27 I.R.B. 20

2015-38, 2015-36 I.R.B. 295
2015-39, 2015-33 I.R.B. 195
2015-40, 2015-35 I.R.B. 236
2015-41, 2015-35 I.R.B. 263
2015-42, 2015-36 I.R.B. 310
2015-44, 2015-38 I.R.B. 354

### Revenue Rulings:

2015-15, 2015-27 I.R.B. 1

2015-16, 2015-31 I.R.B. 130

2015-18, 2015-34 I.R.B. 209
2015-19, 2015-36 I.R.B. 291
2015-20, 2015-38 I.R.B. 353

### Treasury Decisions:

9723, 2015-31 I.R.B. 84
9726, 2015-31 I.R.B. 98

9727, 2015-32 I.R.B. 154
9728, 2015-33 I.R.B. 169
9729, 2015-35 I.R.B. 221
9730, 2015-35 I.R.B. 223
9731, 2015-37 I.R.B. 314
9735, 2015-37 I.R.B. 316

1A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2015-01 through 2015-26 is in Internal Revenue Bulletin
2015-26, dated June 29, 2015.

### Finding List of Current Actions on Previously Published Items1

Bulletins 2015-27 through 2015-38

Notices:

2014-4
Modified by
Notice 2015-51, 2015-31 I.R.B. 133

#### Revenue Procedures:

1992-75
Clarified by
Rev. Proc. 2015-40, 2015-35 I.R.B. 236

2003-40
Modified by
Rev. Proc. 2015-40, 2015-35 I.R.B. 236

2006-9
Modified by
Rev. Proc. 2015-41, 2015-35 I.R.B. 263

2006-9
Superseded by
Rev. Proc. 2015-41, 2015-35 I.R.B. 263

2006-54
Modified by
Rev. Proc. 2015-40, 2015-35 I.R.B. 236

2006-54
Superseded by
Rev. Proc. 2015-40, 2015-35 I.R.B. 236

2008-31
Modified by
Rev. Proc. 2015-41, 2015-35 I.R.B. 263

2008-31
Superseded by
Rev. Proc. 2015-41, 2015-35 I.R.B. 263

2011-49
Modified by
Rev. Proc. 2015-36, 2015-27 I.R.B. 20

2011-49
Superseded by
Rev. Proc. 2015-36, 2015-27 I.R.B. 20

2015-14
Modified by
Rev. Proc. 2015-39, 2015-33 I.R.B. 195

2015-40
Amplified by
Rev. Proc. 2015-41, 2015-35 I.R.B. 263

2015-41
Amplified by
Rev. Proc. 2015-40, 2015-35 I.R.B. 236

"A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2015-01 through 2015-26 is in Internal Revenue Bulletin
2015-26, dated June 29, 2015.

# Internal Revenue Service Washington, DC 20224

Official Business
Penalty for Private Use, $300

# INTERNAL REVENUE BULLETIN

The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue
Bulletins are available at www.irs.gov/irb/.

# We Welcome Comments About the Internal Revenue Bulletin

If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we
would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page
(www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave.
NW, IR-6230 Washington, DC 20224.

Internal Revenue Bulletin 2015-38 (PDF rendition): IRS Revenue Procedures

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