Internal Revenue Bulletin 2011-14 (PDF rendition): IRS Announcements

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Bulletin No. 201
1-14
April 4, 2011
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. 2011–10, page 597.
Federal rates; adjusted federal rates; adjusted federal
long-termrateandthelong-termexemptrate.For pur-
poses of sections 382, 642, 1274, 1288, and other sections
of the Code, tables set forth the rates for April 2011.
T.D. 9515, page 599.
Final and temporary regulations under section 1502 of the
Code relate to the redetermination of intercompany gain as ex-
cluded from gross income. Temporary regulations under sec-
tion 1.1502–13T are reissued.
REG–153338–09, page 606.
Proposed regulations under section 6103(c) of the Code ex-
tends the period for submission to the IRS of taxpayer autho-
rizations permitting disclosure of returns and return informa-
tion to third-party designees. A public hearing is scheduled for
June 9, 2011.
Notice 2011–24, page 603.
Guidance for Phase II of the qualifying advanced coal
program under Section 48A and the qualifying gasifi-
cation program under Section 48B.This notice updates
the rules regarding the separation and sequestration of car-
bon dioxide emissions for Phase II of the qualifying advanced
coal program under section 48A of the Code and the qualify-
ing gasification program under section 48B. Specifically, the
notice provides for the annual measurement of separated and
sequestered carbon dioxide and applies the recapture rules of
section 50(a) in the event that a taxpayer fails to attain or main-
tain the carbon dioxide separation and sequestration require-
ments of section 48A or section 48B. Notices 2009–23 and
2009–24 modified.
Notice 2011–25, page 604.
Credit for carbon dioxide sequestration; modification of
Notice 2009–83.This notice modifies Notice 2009–83 by
removing section 4.07, which provided that for purposes of
section 45Q of the Code, qualified carbon dioxide (CO
2
)does
not include CO
2
that is captured and sequestered in a project
as required under the qualifying advanced coal project program
of section 48A or the qualifying gasification project program of
section 48B. Notice 2009–83 modified.
EXEMPT ORGANIZATIONS
Announcement 2011–25, page 608.
The IRS has revoked its determination that Bennafield En-
terprises, Inc., of Canton, OH; Challenge 2000, Inc., of
Clackamas, OR; Christ Temple Breaking Free Ministry of Itta
Bena, MS; Consumerwiz of Connecticut, Inc., of Groton, CT;
Dakota Academy Charter School of Burnsville, MN; Human
Shelter Innovation Institute, formerly Human Shelter Research
Institute, of St. Louis, MO; LBOH, Inc., of Gainesville, FL;
Larry T. Herrig Charitable Foundation of Dubuque, IA; National
Spending & Credit Counseling Center of Spring Valley, CA;
and S.H.O.C. Enterprise, Inc., of Corona, CA, qualify as
organizations described in sections 501(c)(3) and 170(c)(2) of
the Code.
(Continued on the next page)
Finding Lists begin on page ii.

ADMINISTRATIVE
Announcement 2011–26, page 608.
This document provides notice of a public hearing on proposed
regulations (REG–149335–08, 2011–6 I.R.B. 468) relating to
the capitalization and allocation of royalties that are incurred
only upon the sale of property produced or property acquired
for resale (sales-based royalties) and adjusting the cost of mer-
chandise inventory for an allowance, discount, or price rebated
based on merchandise sales (sales-based vendor allowances).
The regulations modify the simplified production method and
the simplified resale method. A public hearing is scheduled for
April 13, 2011.
April 4, 20112011–14 I.R.B.

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.
2011–14 I.R.B.April 4, 2011

April 4, 20112011–14 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 April 2011.
See Rev. Rul. 2011-10, page 597.
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term rates
are set forth for the month of April 2011. See Rev.
Rul. 2011-10, page 597.
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 April 2011. See Rev. Rul.
2011-10, page 597.
Section 412.—Minimum
Funding Standards
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of April 2011. See Rev. Rul. 2011-10, page 597.
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 April 2011. See Rev. Rul. 2011-10, page 597.
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 Apr
il 2011. See Rev. Rul. 2011-10, page 597.
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 April 2011. See Rev.
Rul. 2011-10
, page 597.
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 April 2011. See Rev. Rul. 2011-10, page 597.
Section 642.—Special
Rules for Credits and
Deductions
Federal short-term, mid-term, and long-term rates
are set forth for the month of April 2011. See Rev.
Rul. 2011-10, page 597.
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 April 2011. See Rev. Rul. 2011-10, page 597.
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 April 2011. See Rev. Rul. 2011-10, page 597.
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, 1288, and other
sections of th
e Code, tables set forth the
rates for Apri
l2011.
Rev. Rul. 2011
–10
This revenue
ruling provides various
prescribed r
ates for federal income tax pur-
poses for Apr
il 2011 (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%. Finally, Table 5 contains
the fed
eral 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.
2011–14 I.R.B.597April 4, 2011

REV. RUL. 2011–10 TABLE 1
Applicable Federal Rates (AFR) for April 2011
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
AFR
.55%.55%.55%.55%
110% AFR.61%.61%.61%.61%
120% AFR.66%.66%.66%.66%
130% AFR.72%.72%.72%.72%
Mid-term
AFR2.49%2.47%2.46%2.46%
110% AFR2.74%2.72%2.71%2.70%
120% AFR2.98%2.96%
2.95%
2.94%
130% AFR3.24%3.21%3.20%3.19%
150% AFR
3.74%3.71%3.69%3.68%
175% AFR
4.37%4.32%4.30%4.28%
Long-term
AFR
4.25%
4.21%4.19%4.17%
110% AFR4.68%4.63%4.60%
4.59%
120% AFR
5.11%5.05%5.02%5.00%
130% AFR
5.54%5.47%5.43%5.41%
REV. RUL. 2011–10 TABLE 2
Adjusted AFR for April 2011
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-ter
madjusted
AFR
.87%.87%.87%.87%
Mid-term adjusted AFR2.09%2.08%2.07%2.07%
Long-term adjusted
AFR
4.30%
4.25%
4.23%4.21%
REV. RUL.
2011–10 TABLE 3
Rates Und
er Section 382 for April 2011
Adjusted
federal long-term rate for the current month
4.30%
Long-ter
m tax-exempt rate for ownership changes during the current month (the highest of the adjusted
federal l
ong-term rates for the current month and the prior two months.)
4.55%
April 4, 20115982011–14 I.R.B.

REV. RUL. 2011–10 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for April 2011
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 credit7.78%
Appropriate percentage for the 30% present value low-income housing credit3.33%
REV. RUL. 2011–10 TABLE 5
Rate Under Section 7520 for April 2011
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 interest3.0%
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 April 2011. See Rev. Rul. 2011-10, page 597.
Section 1502.—Reg-
ulations.
26 CFR 1.1502–13: Intercompany transactions.
T.D. 9515
DEPARTMENT OF THE
TREASURY
Internal Revenue Service
26 CFR Part 1
Guidance Under Section 1502;
Amendment of Matching Rule
for Certain Gains on Member
Stock
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final and temporary regula-
tions.
SUMMARY: This document contains fi-
nal regulations concerning the treatment
of certain intercompany gain with respect
to stock owned by members of a consol-
idated group. These regulations provide
for the redetermination of intercompany
gain as excluded from gross income in
certain transactions involving stock trans-
fers between members of a consolidated
group. The temporary regulations con-
tained in this document are solely for the
purpose of retaining the portion of the ex-
isting temporary regulations that were in
the same temporary regulation section but
that are not being promulgated as final reg-
ulations at this time. These regulations
affect corporations filing consolidated re-
turns.
DATES:Effective Date:These regulations
are effective on March 4, 2011.
Applicability Date:Section
1.1502–13(c)(6)(ii)(C), (c)(6)(ii)(D), and
(c)(7)(ii),Examples 16and17apply with
respect to items taken into account on or
after March 4, 2011.
FOR FURTHER INFORMATION
CONTACT: John F. Tarrant (202)
622–7790 or Lawrence M. Axelrod, (202)
622–7713 (not toll-free numbers).
SUPPLEMENTARY INFORMATION:
Background
On March 7, 2008, the IRS and the
Treasury Department published tempo-
rary regulations §1.1502–13T. See T.D.
9383, 2008–1 C.B. 738 (73 FR 12265–01).
Also on March 7, 2008, the IRS and
the Treasury Department published a
notice of proposed rulemaking cross-ref-
erencing those temporary regulations.
See REG–137573–07, 2008–1 C.B. 750
(73 FR 12312–01).
The IRS and the Treasury Department
did not receive written comments from the
public during the prescribed comment pe-
riod and no public hearing was requested
or held. This Treasury decision adopts the
proposed regulation (REG–137573–07)
with the changes discussed in this pre-
amble. In addition, this Treasury deci-
sion revises the temporary regulation,
§1.1502–13T.
Su
mmary of Comments and
Ex
planation of Revisions
Finalization of 2008 temporary
regulations.
The 2008 temporary regulations con-
cern the treatment of certain intercompany
gain with respect to consolidated group
member stock. Section 1.1502–13 pro-
vides rules governing the timing and char-
acterization of items resulting from trans-
actions between consolidated group mem-
bers. Section 1.1502–13(c) provides gen-
eral rules under which the timing and char-
acter of those items can be deferred or
recharacterized to clearly reflect the tax-
able income (and tax liability) of the group
as a whole. These rules generally apply a
“matching” principle under which the tim-
ing of inclusion of gain on the sale of prop-
erty by the seller (S) is linked to the buyer’s
(B) recovery of its basis in the property and
S and B’s characterization are subject to re-
determination in order to treat S and B as
divisions of a single corporation.
The proposed regulations provide that
intercompany gain with respect to member
stock may be permanently excluded from
gross income following certain stock ba-
sis elimination transactions (for example,
2011–14 I.R.B.599April 4, 2011

tax-free spin-offs and liquidations). The
IRS and the Treasury Department have
reconsidered the requirement of the pro-
posed regulations that, immediately be-
fore intercompany gain would otherwise
be taken into account, the common par-
ent (P) must be the member that holds the
member stock with respect to which the
intercompany gain was realized, and that
the gain must be P’s intercompany item.
Given the other requirements of the reg-
ulation, namely that (i) the group has not
and will not deriveany Federal income
tax benefit from the intercompany trans-
action; and (ii) the excluded gain will not
be treated as tax-exempt income for pur-
poses of the investment adjustment regu-
lations–it is appropriate to provide relief
where a member other than the common
parent holds the subject stock. Accord-
ingly, these final regulations allow the ex-
clusion of gain where a member holds the
target member stock with respect to which
the intercompany gain was realized, and
the holding member is either (i) B or S, as a
successor to the other party (either B or S);
or (ii) a third member that is the successor
to both B and S.
The preamble to the proposed regula-
tions requested comments as to whether
the “Commissioner’s Discretionary Rule”
(§1.1502–13(c)(6)(ii)(D)) should be re-
tained. The preamble also stated that the
IRS and Treasury Department were con-
sidering eliminating the Commissioner’s
Discretionary Rule. Upon further con-
sideration, the IRS and Treasury Depart-
ment believe there may be circumstances
where application of such discretion is
warranted. Thus, for example, the final
regulations do not provide automatic relief
for transactions involving property other
than member stock (such as the stock of
non-members), but relief may be avail-
able after review by the IRS under the
Commissioner’s Discretionary Rule. Ac-
cordingly, the final regulations retain the
Commissioner’s Discretionary Rule in a
form revised to describe the conditions to
be satisfied for that discretion to be exer-
cised, and to indicate that relief is available
only through a request for a letter ruling.
Finally, the final regulations also ex-
pressly provide that the excluded gain is
not treated as tax exempt income for pur-
poses of §1.1502–32 and does not increase
earnings and profits.
Reordering of Regulation.
On September 4, 2009, amendments
to §1.1502–13T were published in the
Federal Registerto modify the election
under which a consolidated group can
avoid immediately taking into account an
intercompany item after the liquidation
of a target corporation (the 2009 tem-
porary regulations). A minor correction
to the 2009 temporary regulations con-
cerning the expiration date of the 2009
temporary regulations was published in
theFederal Registeron January 13, 2010.
The changes made by the 2009 tempo-
rary regulations inadvertently appear in
the wrong location in the officialFed-
eral Registerversion of §1.1502–13T.
Some tax services have these provisions
in their intended places. In order to take
into account the finalization of the 2008
temporary regulations, as described in this
preamble, and to avoidconfusion concern-
ing the location of the amendments made
by the 2009 temporary regulations, this
document revises §1.1502–13T and places
the 2009 temporary regulations in the
proper location. No substantive change is
intended by this revision.
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 has also been determined
that section 553(b) of the Administrative
Procedure Act (5 U.S.C. chapter 5) does
not apply to this regulation. Pursuant to the
Regulatory Flexibility Act (5 U.S.C. chap-
ter 6), it is hereby certified that this rule
will not have a significant economic im-
pact on a substantial number of small enti-
ties. This certification is based on the fact
that this regulation primarily affects mem-
bers of consolidated groups which tend to
be large corporations. Accordingly, a reg-
ulatory flexibility analysis is not required.
Pursuant to section 7805(f) of the Inter-
nal Revenue Code, the notice of proposed
rulemaking preceding this regulation was
submitted to the Chief Counsel for Advo-
cacy of the Small Business Administration
for comment on their impact on small busi-
ness.
Drafting Information
The principal author of this regulation is
John F. Tarrant, Office of Associate Chief
Counsel (Corporate). However, other per-
sonnel from the IRS and the Treasury De-
partment participated in its development.
*****
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR part 1 is amended
as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 continues to read in part as follows:
Authority: 26 U.S.C. 7805. * * *
Section 1.1502–13 isalso issued under
26 U.S.C. 1502.
Par. 2. Section 1.1502–13 is amended
as follows:
1. Entries forExamples 16and
17are added to the table of examples
for §1.1502–13(c)(7)(ii) in paragraph
(a)(6)(ii).
2.Paragraphs (c)(6)(ii)(C),
(c)(6)(ii)(D) are revised andExamples 16
and17are added to paragraph (c)(7)(ii).
3. Paragraph (c)(7)(iii) is added.
4. Paragraph (f)(7)(i)Examples 8and9
and paragraph (f)(7)(ii) are removed.
5. Paragraph (f)(7)(i) is redesignated as
(f)(7).
The revisions and additions read as fol-
lows:
§1.1502–13 Intercompany transactions.
(a) * * *
(6) * * *
(ii) * * *
Matching rule (§1.1502–13(c)(7)(ii))
*****
Example 16. Intercompany stock distri-
bution followed by section 332 liquidation.
Example 17. Intercompany stock sale
followed by section 355 distribution.
*****
(c) * * *
(6) * * *
(ii) * * *
(C)Certain intercompany gains on
stock—(1)In general. Notwithstanding
paragraph (c)(6)(ii)(A)(1) of this section,
April 4, 20116002011–14 I.R.B.

intercompany gain with respect to a mem-
ber’s stock that was created by reason of
an intercompany transfer of the stock, and
that would not otherwise be taken into
account upon a subsequent elimination of
the stock’s basis but for the transfer, is
redetermined to be excluded from gross
income if—
(i) B or S becomes a successor (as de-
fined in paragraph (j)(2) of this section) to
the other party (either B or S), or a third
member becomes a successor to both B
and S;
(ii) Immediately before the intercom-
pany gain would be taken into account,
the successor member holds the member’s
stockwithrespecttowhichtheintercom-
pany gain was realized;
(iii) The successor member’s basis in
the member’s stock that reflects the inter-
company gain that is taken into account is
eliminated without the recognition of gain
or loss (and such eliminated basis is not
further reflected in the basis of any succes-
sor asset);
(iv) The effects of the intercompany
transaction have not previously been
reflected, directly or indirectly, on the
group’s consolidated return; and
(v) The group has not derived, and no
taxpayer will derive, any Federal income
tax benefit from the intercompany transac-
tion that gave rise to the intercompany gain
or the redetermination of the intercompany
gain (including any adjustment to basis in
member stock under §1.1502–32). For this
purpose, the redetermination of the inter-
company gain is not itself considered a
Federal income tax benefit.
(2)Effect on earnings and profits and
investment adjustments. Any amount
excluded from gross income under para-
graph (c)(6)(ii)(C)(1) of this section shall
not be taken into account as earnings
and profits of any member and shall not
be treated as tax-exempt income under
§1.1502–32(b)(2)(ii).
(D)Other amounts.(1) The Commis-
sioner may determine that treating S’s in-
tercompany item as excluded from gross
income is consistent with the purposes of
this section and other applicable provi-
sions of the Internal Revenue Code, regu-
lations, and published guidance, if the fol-
lowing conditions are met, depending on
whether the intercompany item is an item
of income or an item of gain:
(i) In the case of an intercompany item
of income, the corresponding item is per-
manently disallowed; or
(ii) If the intercompany item con-
stitutes gain, the conditions described
in paragraphs (c)(6)(ii)(C)(1)(iv)and
(c)(6)(ii)(C)(1)(v)ofthissectionaresatis-
fied.
(2) A determination by the Commis-
sioner may be obtained only through a let-
ter ruling request.
(7) * * *
(ii) * * *
*****
Example 16.Intercompany stock distribution fol-
lowed by section 332 liquidation.(a)Facts. P owns
allofthestockofS,SownsallthestockofT,amem-
ber of the P group, and T owns all of the stock of
T1, also a member of the P group. On January 1
of Year 1, S distributes all of the T stock to P in a
distribution to which section 301 applies. At the time
of this distribution, the value of the T stock is $100
and S has a $40 basis in the T stock. Under section
311(b), the distribution creates $60 of intercompany
gain to S. Under section 301(d), P’s basis in the T
stock is $100. S will take its $60 intercompany gain
into account under the matching rule. On January 1
of Year 4, in an independent transaction, S distributes
all of its assets to P in a complete liquidation to which
section 332 applies, and, under paragraph (j)(2) of
this section, P succeeds to S’s $60 gain. On January 1
of Year 7, T distributes all of its T1 stock to P in a
transaction to which section 355 applies. At the time
of this distribution, P has a basis in the T stock of
$100, the value of the T stock (without regard to T1)
is $75, and the value of the T1 stock is $25. Under
section 358, P allocates $25 of its $100 basis in the T
stock to the T1 stock, and, under paragraph (j)(1) of
this section, the T1 stock becomes a successor asset to
the T stock. On January 1 of Year 9, in an independent
transaction, T distributes all of its assets to P in a
complete liquidation to which section 332 applies.
(b)Analysis. Under paragraphs (b)(1) and (f)(2)
of this section, S’s distribution in Year 1 of the T stock
to P is an intercompany transaction, S is the selling
member, and P is the buying member. In Year 9 when
T liquidates, P has no gain or loss under section 332.
Under paragraph (b)(3)(ii) of this section, P’s $0 gain
or loss with respect to the T stock under section 332 is
a corresponding item. P takes $45 (75/100 x $60) of
its intercompany gain into account under the match-
ing rule in Year 9 to reflect the difference between P’s
$0 of unrecognized gainand P’s $45 of recomputed
unrecognized gain. (If P and S were divisions of a
single corporation, P would have had a $40 basis in
the T stock, and, after the Year 7 distribution of the T1
stock, would have held the T stock with a $30 basis.)
However, paragraph (c)(6) of this section does not
prevent the redetermination of P’s intercompany gain
as excluded from gross income provided P succeeds
to S’s intercompany item; P and S are a single entity;
P’s basis in the T stock that reflects the $45 intercom-
pany gain taken into account is eliminated without the
recognition of gain or loss (and this eliminated basis
is not further reflected inthe basis of any successor
asset); the group has not derived and no taxpayer will
derive any Federal incometax benefit from the basis
in the T stock and will not derive any Federal income
tax benefit from a redetermination of this portion of
the gain; and the effects of the intercompany trans-
action have not previouslybeen reflected, directly or
indirectly, on the P group’s consolidated return. (See
paragraph (c)(6)(ii)(C) of this section.) Accordingly,
under paragraph (c)(6)(ii)(C) of this section, the $45
intercompany gain that P takes into account is rede-
termined to be excluded from gross income. P’s basis
in its T1 stock continues to reflect $15 of intercom-
pany gain.
Example 17.Intercompany stock sale followed
by section 355 distribution.(a)Facts. The facts are
thesameasExample 16, except that T does not dis-
tribute the stock of T1, instead, in Year 7, T makes
a distribution of $50 to P in a transaction to which
section 301 applies. Under §1.1502–32, P’s basis in
its T stock is reduced by $50 and, under paragraph
(f)(2)(ii) of this section, the intercompany distribu-
tion is excluded from P’s gross income. Further, in
Year 9, instead of liquidating T, P distributes the T
stock to its shareholders in a transaction to which sec-
tion 355 applies.
(b)Analysis. On the distribution of the T stock
in Year 9, P has $0 of unrecognized gain under sec-
tion 355(c). Under paragraph (b)(3)(ii) of this sec-
tion, P’s $0 of unrecognized gain or loss with respect
to the T stock under section 355(c) is a correspond-
ing item. P takes its $60 intercompany gain into ac-
count under the matching rule in Year 9 to reflect
the difference between P’s $0 of unrecognized gain
and P’s $60 of recomputedgain ($50 unrecognized
gain and $10 recognized gain). (If P and S were di-
visions of a single corporation, P would have had a
$40 basis in the T stock, and, after the Year 7 distri-
bution, would have held the T stock with a $10 ex-
cess loss account.) See paragraph (f)(7),Example2
of this section. Paragraph (c)(6) of this section does
not prevent the redetermination of P’s intercompany
gain as excluded from gross income provided P suc-
ceeds to S’s intercompany item; P and S are a single
entity; P’s basis in the T stock that reflects the $60
intercompany gain taken into account is eliminated
without the recognition of gain or loss (and this elim-
inated basis is not further reflected in any successor
asset); the group has not derived any Federal income
tax benefit from the basis in the T stock and will not
derive any Federal income tax benefit from a redeter-
mination of this portion of the gain; and the effects
of the intercompany transaction have not previously
been reflected, directly or indirectly, on the P group’s
consolidated return. (See paragraph (c)(6)(ii)(C) of
this section.) The intercompany transaction with re-
spect to the T stock resulted in an increase in the ba-
sis of the T stock, and this increase in the basis of the
T stock prevented P from holding the T stock with a
$10 excess loss account (as a result of the Year 7 dis-
tribution) at the time of the section 355 distribution.
Accordingly, the group derived a Federal income tax
benefit from the intercompany transaction to the ex-
tent of $10 and, under paragraph (c)(6)(ii)(C) of this
section, only $50 of the $60 intercompany gain that
P takes into account is redetermined to be excluded
from gross income.
(c)Application of section 355(e).If it were deter-
mined that section 355(e) applied to P’s distribution
of the T stock, P would recognize $0 of gain and de-
rive a Federal income tax benefit to the extent of the
2011–14 I.R.B.601April 4, 2011

full $60 increase in the basis of the T stock. There-
fore, no portion of P’s intercompany gain would be
redetermined to be excluded from gross income un-
der paragraph (c)(6)(ii)(C) of this section.
(iii)Effective/applicability date—(A)
In general. Paragraphs (c)(6)(ii)(C),
(c)(6)(ii)(D), and (c)(7)(ii)Examples 16
and17of this section apply with respect
to items taken into account on or after
April 4, 2011.
(B)Prior periods. For items taken
into account on or after March 7,
2008, and before April 4, 2011, see
§1.1502–13T(c)(6)(ii)(C) and (f)(7),Ex-
amples 7and8as contained in 26 CFR
part 1 in effect on April 1, 2009. For items
taken into account before March 7, 2008,
see §1.1502–13 as contained in 26 CFR
part 1 in effect on April 1, 2007.
*****
Par. 3. Section 1.1502–13T is revised
to read as follows:
§1.1502–13T Intercompany transactions
(temporary).
(a) through (f)(5)(ii)(A) [Reserved].
For further guidance, see §1.1502–13(a)
through (f)(5)(ii)(A).
(B)Section 332—(1)In general. If sec-
tion 332 would otherwise apply to T’s (old
T’s) liquidation into B, and B transfers sub-
stantially all of old T’s assets to a new
member (new T), and if a direct transfer
of substantially all of old T’s assets to new
T would qualify as a reorganization de-
scribed in section 368(a), then, for all Fed-
eral income tax purposes, T’s liquidation
into B and B’s transfer of substantially all
of old T’s assets to new T will be disre-
garded and instead, the transaction will be
treated as if old T transferred substantially
all of its assets to new T in exchange for
new T stock and the assumption of T’s li-
abilities in a reorganization described in
section 368(a). (Under §1.1502–13(j)(1),
B’s stock in new T would be a successor
assettoB’sstockinoldT,andS’sgain
would be taken into account based on the
new T stock.)
(2)Time limitation and adjustments.
The transfer of old T’s assets to new T
qualifies under paragraph (f)(5)(ii)(B)(1)
of this section only if B has entered into
a written plan, on or before the due date
of the group’s consolidated income tax
return (including extensions), to transfer
the T assets to new T, and the statement
described in paragraph (f)(5)(ii)(E) of this
section is included on or with a timely
filed consolidated tax return for the tax
year that includes the date of the liquida-
tion (including extensions). However, see
paragraph (f)(5)(ii)(F) of this section for
certain situations in which the plan may
be entered into after the due date of the
return and the statement described in para-
graph (f)(5)(ii)(E) of this section may be
included on either an original tax return or
an amended tax return filed after the due
date of the return. In either case, the trans-
fer of substantially all of T’s assets to new
T must be completed within 12 months
of the filing of the return. Appropriate
adjustments are made to reflect any events
occurring before the formation of new T
and to reflect any assets not transferred to
new T, or liabilities not assumed by new T.
Forexample,ifBretainsanassetofoldT,
the asset is treated under §1.1502–13(f)(3)
asacquiredbynewTbutdistributedtoB
immediately after the reorganization.
(f)(5)(ii)(B)(3) through (f)(5)(ii)(E)
[Reserved].For further guidance,
see §1.1502–13(f)(5)(ii)(B)(3) through
(f)(5)(ii)(E).
(F)Effective/Applicability dates—(1)
General rule. Paragraphs (f)(5)(ii)(B)(1)
and (f)(5)(ii)(B)(2) of this section apply to
transactions in which old T’s liquidation
into B occurs on or after October 25, 2007.
(2)Prior periods.For transac-
tions in which old T’s liquidation
into B occurs before October 25,
2007, see §1.1502–13(f)(5)(ii)(B)(1)
and (f)(5)(ii)(B)(2) in effect prior to
October 25, 2007 as contained in 26 CFR
part 1, revised April 1, 2009.
(3)Special rule for tax returns filed
before November 3, 2009. In the case of a
liquidation on or after October 25, 2007,
by a taxpayer whose original tax return
for the year of liquidation was filed on or
before November 3, 2009, then, notwith-
standing paragraph (f)(5)(ii)(B)(2)ofthis
section and §1.1502–13(f)(5)(ii)(E), the
election to apply paragraph (f)(5)(ii)(B) of
this section may be made by entering into
the written plan described in paragraph
(f)(5)(ii)(B) of this section on or before
November 3, 2009, including the state-
ment described in §1.1502–13(f)(5)(ii)(E)
on or with an original tax return or an
amended tax return for the tax year that
includes the liquidation filed on or before
November 3, 2009, and transferring sub-
stantially all of T’s assets to new T within
12 months of the filing of such original or
amended return.
(G)Expiration date.Thesetemporary
regulations will expire on September 3,
2012.
Steven T. Miller,
Deputy Commissioner for
Services and Enforcement.
Approved February 24, 2011.
Michael Mundaca,
Assistant Secretary of
theTreasury(TaxPolicy).
(Filed by the Office of the Federal Register on March 3, 2011,
8:45 a.m., and published in the issue of the Federal Register
for March 4, 2011, 76 F.R. 11956)
Section 7520.—Valuation
Tables
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of April 2011. See Rev. Rul. 2011-10, page 597.
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 April 2011. See Rev. Rul. 2011-10, page 597.
April 4, 20116022011–14 I.R.B.

Part III. Administrative, Procedural, and Miscellaneous
Guidance for Phase II of the
Qualifying Advanced Coal
Program Under Section 48A
and the Qualifying Gasification
Program Under Section 48B
Notice 2011–24
SECTION 1. PURPOSE
This notice updates the rules relating to
the qualifying advanced coal project pro-
gram under § 48A and the qualifying gasi-
fication project program under § 48B of
the Internal Revenue Code. Specifically,
this notice applies to any qualifying project
that includes equipment that separates and
sequesters such project’s total carbon diox-
ide emissions. Except as specifically pro-
vided in this notice, the qualifying ad-
vanced coal project program and the qual-
ifying gasification project program will be
conducted in the manner and under the
procedures provided in Notice 2009–24,
2009–16 I.R.B. 817, and Notice 2009–23,
2009–16 I.R.B. 802.
SECTION 2. BACKGROUND
.01 Section 46 provides that the amount
of the investment credit for any taxable
year is the sum of the credits listed in § 46.
That list includes the qualifying advanced
coal project credit under § 48A and the
qualifying gasification project credit under
§48B.
.02 Section 48A allows a qualifying
advanced coal project credit in an amount
equal to (1) 20 percent of the qualified in-
vestment (as defined in § 48A(b)) for that
taxable year in qualifying advanced coal
projects (as defined in § 48A(c)(1) and
(e)) described in § 48A(d)(3)(B)(i), (2) 15
percent of the qualified investment for that
taxable year in qualified advanced coal
projects described in § 48A(d)(3)(B)(ii),
and (3) 30 percent of the qualified in-
vestment for that taxable year in qualify-
ing advanced coal projects described in
§ 48A(d)(3)(B)(iii).
.03 Section 48A(d)(3)(B)(iii), as
added by section 111 of the Energy
Improvement and Extension Act of
2008, Pub. L. No. 110–343, 122 Stat.
3765 (October 3, 2008), provides for a
second phase of the qualifying advanced
coal project program and authorizes
the Secretary to certify $1.25 billion of
additional credits foradvanced coal-based
generation technology projects (“the Phase
II advanced coal program” and “the Phase
II advanced coal projects.”)
.04 Under § 48A(e)(1)(G), any project
the application for which is submitted un-
der the Phase II advanced coal program
must include equipment that separates and
sequesters—
(1) At least 65 percent of such project’s
total carbon dioxide (“CO
2
”) emissions in
the case of an application other than an
application for reallocated credits under
§ 48A(d)(4); and
(2) At least 70 percent of such project’s
total CO
2
emissions in the case of an
application for reallocated credits under
§ 48A(d)(4).
.05 On April 20, 2009, the Internal
Revenue Service (“Service”) issued No-
tice 2009–24 to announce procedures for
the allocation of credits under the Phase II
advanced coal program.
.06 Section 48B(a) allows a qualify-
ing gasification project credit for a taxable
year in an amount equal to 20 percent (30
percent in the case of projects for which
credits are allocatedunder § 48B(d)(1)(B))
of the qualified investment for such tax-
able year.
.07 Section 48B(d)(1)(B), as added by
section 112 of the Energy Improvement
and Extension Act of 2008 provides for
a second phase of the qualifying gasifi-
cation project program and authorizes the
Secretary to certify an additional $250
million of credits to qualifying projects
that include equipment that separates and
sequesters at least 75 percent of such
project’s total CO
2
emissions (“Phase II
gasification program” and “Phase II gasi-
fication projects.”)
.08 On April 20, 2009, the Service is-
sued Notice 2009–23 to announce proce-
dures for the allocation of credit under the
Phase II gasification program.
.09 On September 27, 2010, the Service
issued Announcement 2010–56, 2010–39
I.R.B. 398, setting forth the results of the
first round of allocations under the Phase
II advanced coal program and the Phase II
gasification program.
SECTION 3. RULE RELATED TO
SEPARATION AND SEQUESTRATION
OF CARBON DIOXIDE EMISSIONS.
.01In General. Section 48A(i) requires
a recapture of the qualifying advanced coal
project credit with respect to any project
that fails to attain or maintain the sepa-
ration and sequestration requirements of
§ 48A(e)(1)(G). Section 7.04 of Notice
2009–24 states that the § 48A credit allo-
cated to a Phase II advanced coal project
will be recaptured if, at any time during the
applicable recovery period (as defined in
§ 168(c)) for such project, the project fails
to attain or maintain the separation and se-
questration requirements for such project
under § 48A(e)(1)(G).
Similarly, § 48B(f) requires a recapture
of the qualifying gasification project credit
with respect to any project that fails to at-
tain or maintain the separation and seques-
tration requirements for such project un-
der § 48B(d)(1)(B). Section 6.04 of Notice
2009–23 provides that the § 48B credit al-
located to a Phase II gasification project
will be recaptured if, at any time during the
applicable recovery period (as defined in
§ 168(c)) for such project, the project fails
to attain or maintain the separation and se-
questration requirements for such project
under § 48B(d)(1)(B).
Additionally, credits allowed under
§ 48A and § 48B are subject to the re-
capture rules of § 50(a) as provided under
section 2.12 of Notice 2009–24 and sec-
tion 2.07 of Notice 2009–23, respectively.
Section 50(a)(1) provides, generally, for
recapture of the investment credit if, dur-
ing any taxable year, investment tax credit
property is disposed of or otherwise ceases
to be investment credit property with re-
spect to the taxpayer before the close of
the recapture period. The recapture period
under § 50(a) is the 5-year period begin-
ning on the date the property is placed in
service.
.02Applicability of the Recapture Rule
of § 50(a). The Service recognizes that
§ 168(c) provides a wide range of recovery
periods that apply to Phase II advanced
coal projects or Phase II gasification
projects. This may create uncertainty for
taxpayers regarding which recovery pe-
riod to use if a project fails to attain or
2011–14 I.R.B.603April 4, 2011

maintain the separation and sequestration
requirements of § 48A and § 48B.
Moreover, different recapture periods
provided under § 168(c) and § 50(a) may
create further confusion and difficulty to
taxpayers and to the Service. Therefore,
the Service has determined that the recap-
ture rules under § 50(a) will apply for all
events that trigger recapture of the cred-
its allowed under § 48A or § 48B, includ-
ing a failure to attain or maintain the sep-
aration and sequestration requirements of
§ 48A(e)(1)(G) or § 48B(d)(1)(B).
.03Annual Basis During Normal Plant
Operations. For purposes of determining
whether a project meets the requirements
of § 48A(e)(1)(G) or § 48B(d)(1)(B), the
amount of the project’s total CO
2
emis-
sions and the amount of CO
2
separated
and sequestered will be measured on an
annual basis during normal plant opera-
tions. An annual period other than the tax-
payer’s taxable year may be used for these
purposes if the same period is consistently
used. If a period other than the taxable year
is used, any failure to meet the require-
ments of § 48A(e)(1)(G) or § 48B(d)(1)(B)
will be treated as occurring in the taxable
year that includes the last day of the annual
period in which the failure occurs. The
term “normal plant operations” is defined
as operations other than during periods
of initial plant certification, plant startup,
plant shutdown, integrated gasifier shut-
down for gasification system maintenance,
or interruption of the coal supply to the
project resulting from an event of force
majeure (including an act of God, war,
strike, or other similar event beyond the
control of the taxpayer).
SECTION 4. EFFECT ON OTHER
DOCUMENTS
Notice 2009–23 and Notice 2009–24
are modified.
SECTION 5. EFFECTIVE DATE
This notice is effective for all projects
that receive either § 48A credits under the
Phase II advanced coal program or § 48B
credits under the Phase II gasification pro-
gram.
SECTION 6. DRAFTING
INFORMATION
The principal author of this notice is
Jennifer C. Bernardini of the Office of
Associate Chief Counsel (Passthroughs &
Special Industries). For further informa-
tion regarding this notice, contact Jennifer
C. Bernardini at (202) 622–3110 (not a
toll-free call).
Credit for Carbon Dioxide
Sequestration; Modification of
Notice 2009–83
Notice 2011–25
This notice modifies Notice 2009–83,
2009–44 I.R.B. 588, by removing section
4.07 of the Notice. Section 4.07 pro-
vided that for purposes of § 45Q of the
Internal Revenue Code, qualified carbon
dioxide (CO
2
) does not include CO
2
that
is captured and sequestered in a project
as required under an agreement entered
into in connection with the qualifying
advanced coal project program of § 48A
or the qualifying gasification project pro-
gram of § 48B.
SECTION 1. BACKGROUND
Section 45Q was enacted by § 115
of the Energy Improvement and Exten-
sion Act of 2008, Pub. L. No. 110–343,
122 Stat. 3829 (October 3, 2008), as
amended by section 1131 of the Ameri-
can Recovery and Reinvestment Tax Act
of 2009, Division B of Pub. L. 111–5,
123 Stat 115 (Feb. 17, 2009). Section
45Q(a) provides that a credit for CO
2
sequestration is generally available to
a taxpayer that captures qualified CO
2
at a qualified facility and disposes of
qualified CO
2
in secure geological storage
within the United States, effective for CO
2
captured after October 3, 2008.
Section 45Q(b)(1) defines qualified
CO
2
as CO
2
from an industrial source
which (A) would otherwise be released
into the atmosphere as industrial emission
of greenhouse gas, and (B) is measured at
the source of capture and verified at the
point of disposal or injection.
On November 2, 2009, the Internal
Revenue Service (Service) issued Notice
2009–83, providing guidance on determin-
ing eligibility for the credit and the amount
of the credit, as well as rules regarding
adequate security measures for secure ge-
ological storage of CO
2
. Section 4.07 of
Notice 2009–83 provides that “qualified
CO
2
for purposes of the § 45Q credit does
not include CO
2
that is captured and se-
questered in a project to the extent required
under an agreement executed with the Ser-
vice under the qualifying advanced coal
project program of § 48A or the qualifying
gasification project program of § 48B.”
Since the issuance of Notice 2009–83,
several commenters asserted that the in-
terpretation of § 45Q(b)(1) in section 4.07
is too restrictive and is inconsistent with
the tax and energy policy underlying the
§ 45Q credit, the § 48A program, and the
§ 48B program. According to these com-
menters, the intent of § 45Q(b)(1) is not to
exclude CO
2
that has been captured and se-
questered under the § 48A program or the
§ 48B program, but to ensure merely that
the § 45Q credit is limited to CO
2
captured
from an industrial source that, but for the
physical act of capture, would otherwise be
released into the atmosphere as an indus-
trial emission of greenhouse gas.
SECTION 2. MODIFICATION OF
NOTICE 2009–83
This notice removes section 4.07 of No-
tice 2009–83. Accordingly, qualified CO
2
,
as defined under § 45Q(b)(1), does not ex-
clude CO
2
that is required to be captured
and sequestered under the § 48A program
or the § 48B program.
SECTION 3. EFFECT ON OTHER
DOCUMENTS
Notice 2009–83 is modified as provided
in this notice. Except as explicitly pro-
vided, this notice does not otherwise affect
the guidance provided in Notice 2009–83.
SECTION 4. EFFECTIVE DATE
This notice is effective November 2,
2009, the effective date of Notice
2009–83.
SECTION 5. DRAFTING
INFORMATION
The principal author of this notice is
Jennifer C. Bernardini of the Office of
April 4, 20116042011–14 I.R.B.

Associate Chief Counsel (Passthroughs
& Special Industries). For further in-
formation regarding this notice, contact
Jennifer C. Bernardini at (202) 622–3110
(not a toll-free call).
2011–14 I.R.B.605April 4, 2011

Part IV. Items o
fGeneralInterest
Notice of Proposed
Rulemaking and Notice of
Public Hearing
Disclosure of Returns and
Return Information to
Designee of Taxpayer
REG–153338–09
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of proposed rulemaking
and notice of public hearing.
SUMMARY: This document contains a
proposed regulation pertaining to the pe-
riod for submission to the IRS of taxpayer
authorizations permitting disclosure of re-
turns and return information to third-party
designees. Specifically, the proposed
regulation extends from 60 days to 120
days the period within which a signed and
dated authorization must be received by
the IRS (or an agent or contractor of the
IRS) in order for it to be effective. The
proposed regulation extends the period
as some institutions charged with assist-
ing taxpayers in their financial dealings
have encountered difficulty in obtaining
written authorizations and submitting the
authorizations within the 60-day period
allowed by the existing regulations. The
proposed regulation will affect taxpayers
who submit authorizations permitting dis-
closure of returns and return information
to third-party designees. This document
also provides notice of a public hearing on
the proposed regulation.
DATES: Written or electronic comments
must be received by May 17, 2011. Out-
lines of topics to be discussed at the
public hearing scheduled for Thursday,
June 9, 2011 at 10 a.m. must be received
by Wednesday, May 18, 2011.
ADDRESSES: Send submissions to
CC:PA:LPD:PR(REG–153338–09),
room 5205, Internal Revenue Service,
P.O. Box 7604, Ben Franklin Station,
Washington, DC 20044. Submissions may
be hand delivered Monday through Friday
between the hours of 8 a.m. and 4 p.m.
to: CC:PA:LPD:PR (REG–153338–09),
Courier’s Desk, Internal Revenue
Service, 1111 Constitution Avenue, N.W.,
Washington, DC, or sent electronically
viatheFederaleRulemaking
Portal atwww.regulations.gov(IRS
REG–153338–09). The public hearing
will be held in Auditorium, Internal
Revenue Service, 1111 Constitution
Avenue, NW, Washington, DC.
FOR FURTHER INFORMATION
CONTACT: Concerning the proposed
regulation, contact Amy Mielke, (202)
622–4570; concerning submissions of
comments, the hearing, or to be placed
on the building access list to attend the
hearing, Oluwafunmilayo Taylor, (202)
622–7180 (not toll-free numbers).
SUPP
LEMENTARY INFORMATION:
Paperwork Reduction Act
The collection of information con-
tained in this proposed regulation has
been previously approved by the Office
of Management and Budget in accordance
with the Paperwork Reduction Act of 1995
(44 U.S.C. 3507(d)) under control number
1545–1816.
An agency may not conduct or sponsor,
and a person is not required to respond to, a
collection of information unless it displays
a valid control number assigned by the Of-
fice of Management and Budget.
Books and records relating to the col-
lection of information must be retained as
long as their contents may become mate-
rial in the administration of any internal
revenue law. Generally, tax returns and tax
return information are confidential, as re-
quired by section 6103.
B
ackground
This document contains proposed
amendments to the Procedure and Admin-
istration Regulations (26 CFR part 301).
Section 6103(c) of the Internal Revenue
Code (Code) authorizes the IRS (or an
agent or contractor of the IRS) to disclose
returns and return information to such
person or persons as the taxpayer may
designate in a request for or consent to dis-
closure. The proposed regulation amends
§301.6103(c)–1 by extending the period
for submission to the IRS of taxpayer
authorizations permitting disclosure of re-
turns and return information to designees
of a taxpayer. Specifically, the proposed
regulation extends from 60 days to 120
days the period within which a signed and
dated authorization must be received by
the IRS (or an agent or contractor of the
IRS) in order for it to be effective.
On December 18, 2009, the IRS pub-
lished Notice 2010–8, 2010–3 I.R.B. 297,
which announced an intention to amend
the regulation under §301.6103(c)–1 to ex-
pand the time frame for submission of sec-
tion 6103(c) authorizations. The notice
additionally announced interim rules ex-
tendingfrom60daysto120daysthepe-
riod within which section 6103(c) autho-
rizations must be received in order to be
effective. The interim rules apply to au-
thorizations signed and dated on or after
October 19, 2009. Per Notice 2010–8, the
interim rules remain in effect until promul-
gation of a final regulation under section
6103(c). See §601.601(d)(2)(ii)(d).
Explanation of Provisions
The IRS recognizes the importance of
limiting the effective period of authoriza-
tions provided pursuant to section 6103(c).
Reasonable limitation on the effective pe-
riod of written authorizations helps ensure
the currency of the authorization and pro-
tects taxpayer privacy. The 60-day period
allowed by the existing regulation, how-
ever, has proven problematic. Some in-
stitutions charged with assisting taxpay-
ers in their financial dealings have encoun-
tereddifficultyinobtainingwrittenau-
thorizations and submitting the authoriza-
tions to the IRS within the 60 days al-
lowed by the existing regulation. To re-
duce the burden on taxpayers and the in-
stitutions and professionals assisting them,
the IRS proposes amending the regulation
under section 6103(c) to extend from 60
days to 120 days the period within which
taxpayer-provided authorizations must be
received by the IRS (or an agent or con-
tractor of the IRS) in order to be effective.
Proposed Effective Date
This regulation, as proposed, will be
effective upon publication in theFederal
Registerof a Treasury decision adopting
April 4, 20116062011–14 I.R.B.

this rule as a final regulation. The regula-
tion, once effective,will apply to section
6103(c) authorizations signed on or after
October 19, 2009.
Effect on Other Documents
Notice 2010–8, 2010–3 I.R.B. 297,
will be obsolete upon publication in the
Federal Registerof a Treasury decision
adopting this rule as a final regulation.
Special Analyses
It has been determined that this pro-
posed regulation isnot a significant regu-
latory action as defined in Executive Order
12866. Therefore, a regulatory assessment
is not required. It has also been determined
that section 553(b) of the Administrative
Procedure Act (5 U.S.C. chapter 5) does
not apply to this regulation. Pursuant to
section 7805(f) of the Code, this notice of
proposed rulemaking has been submitted
to the Chief Counsel for Advocacy of the
Small Business Administration for com-
ment on its impact on small businesses.
When an agency issues a rulemak-
ing proposal, the Regulatory Flexibility
Act (5 U.S.C. chapter 6), requires the
agency to “prepare and make available
for public comment an initial regulatory
flexibility analysis” that will “describe
the impact of the proposed rule on small
entities.” (5 U.S.C. 603(a)). Section 605
of the RFA provides an exception to
this requirement if the agency certifies
that the proposed rulemaking will not
have a significant economic impact on a
substantial number of small entities. It
is hereby certified that the collection of
informationinthisregulationwillnot
have a significant economic impact on
a substantial number of small entities.
This certification is based upon the
fact that any burden on taxpayers is
minimal, since the regulation only applies
to taxpayers which request or consent
to the disclosure of returns or return
information, and since the information
collected is only that necessary to carry
out the disclosure of returns or return
information requested or consented to
by the taxpayer (such as the name and
taxpayer identification number of the
taxpayer, the return or return information
to be disclosed, and the identity of the
designee). Moreover, it is based upon
the fact that the regulation reduces the
burden imposed upon taxpayers by the
prior regulation by extending the period
in which consents may be received by the
IRS. Accordingly, a Regulatory Flexibility
Analysis is not required.
Comments and Public Hearing
Before this proposed regulation is
adopted as a final regulation, considera-
tion will be given to any written comments
(a signed original and eight (8) copies)
and electronic comments that are timely
submitted to the IRS. The IRS and the
Treasury Department request comments
on the clarity of the proposed rules and
how they can be made easier to under-
stand. All comments will be available for
public inspection and copying.
The public hearing is scheduled for
Thursday, June 9, 2011 at 10 a.m., and will
be held in Auditorium, Internal Revenue
Service, 1111 Constitution Avenue, NW,
Washington, DC. Due to building secu-
rity procedures, visitors must enter at the
Constitution Avenue entrance. All visitors
must present photo identification to enter
the building. Because of access restric-
tions, visitors will not be admitted beyond
the immediate entrance area more than 30
minutes before the hearing starts. For in-
formation about having your name placed
on the building access list to attend the
hearing, see the section of this preamble
titled “FOR FURTHER INFORMATION
CONTACT.”
The rules of 26 CFR 601.601(a)(3) ap-
ply to the hearing. Persons who wish to
present oral comments at the hearing must
submit electronic or written comments and
an outline of the topics to be discussed and
the time to be devoted to each topic (signed
original and eight (8) copies) by Wednes-
day, May 18, 2011. A period of 10 minutes
will be allotted to each person for the mak-
ing of comments. An agenda showing the
scheduling of the speakers will be prepared
after the deadline for receiving outlines has
passed. Copies of the agenda will be avail-
able free of charge at the hearing.
Drafting Information
The principal author of this proposed
regulation is Amy Mielke, Office of the
Associate Chief Counsel (Procedure and
Administration).
*****
Proposed Amendments to the
Regulations
Accordingly, 26 CFR part 301 is pro-
posed to be amended as follows:
PART 301—PROCEDURE AND
ADMINISTRATION
Paragraph 1. The authority citation for
part 301 continues to read as follows:
Authority: 26 U.S.C. 7805***
Par. 2. Section 301.6103(c)–1 is
amended by revising paragraphs (b)(2),
(f) and adding paragraph (g) to read as
follows:
§301.6103(c)–1 Disclosure of returns
and return information to designee of
taxpayer.
*****
(b) * * *
(2)Requirement that request or con-
sent be received within one hundred twenty
days of when signed and dated.The dis-
closure of a return or return information
authorized by a written request for or writ-
ten consent to the disclosure shall not be
made unless the request or consent is re-
ceived by the Internal Revenue Service (or
an agent or contractor of the Internal Rev-
enue Service) within 120 days following
the date upon which the request or consent
was signed and dated by the taxpayer.
*****
(f)Applicability date. This section is
applicable to section 6103(c) authoriza-
tions signed on or after October 19, 2009.
(g)Effective date. This section is effec-
tive on the date that the final regulations
are published in theFederal Register.
Steven T. Miller,
Deputy Commissioner for
Services and Enforcement.
(Filed by the Office of the Federal Register on March 17,
2011, 8:45 a.m., and published in the issue of the Federal
Register for March 18, 2011, 76 F.R. 14827)
2011–14 I.R.B.607April 4, 2011

Deletions From Cumulative
List of Organizations
Contributions to Which
are Deductible Under Section
170 of the Code
Announcement 2011–25
The Internal Revenue Service has re-
voked its determination that the organi-
zations listed below qualify as organiza-
tions described in sections 501(c)(3) and
170(c)(2) of the Internal Revenue Code of
1986.
Generally, the Service will not disallow
deductions for contributions made to a
listed organization on or before the date
of announcement in the Internal Revenue
Bulletin that an organization no longer
qualifies. However, the Service is not
precluded from disallowing a deduction
for any contributions made after an or-
ganization ceases to qualify under section
170(c)(2) if the organization has not timely
filed a suit for declaratory judgment under
section 7428 and if the contributor (1) had
knowledge of the revocation of the ruling
or determination letter, (2) was aware that
such revocation was imminent, or (3) was
in part responsible for or was aware of the
activities or omissions of the organization
that brought about this revocation.
If on the other hand a suit for declara-
tory judgment has been timely filed, con-
tributions from individuals and organiza-
tions described in section 170(c)(2) that
are otherwise allowable will continue to
be deductible. Protection under section
7428(c) would begin on April 4, 2011 and
would end on the date the court first deter-
mines that the organization is not described
in section 170(c)(2) as more particularly
set forth in section 7428(c)(1). For indi-
vidual contributors, the maximum deduc-
tion protected is $1,000, with a husband
and wife treated as one contributor. This
benefit is not extended to any individual, in
whole or in part, for the acts or omissions
of the organization that were the basis for
revocation.
Bennafield Enterprises, Inc.
Canton, OH
Challenge 2000, Inc.
Clackamas, OR
Christ Temple Breaking Free Ministry
Itta Bena, MS
Consumerwiz of Connecticut, Inc.
Groton, CT
Dakota Academy Charter School
Burnsville, MN
Human Shelter Innovation Institute
formerly Human Shelter Research
Institute
St. Louis, MO
LBOH, INC
Gainesville, FL
Larry T. Herrig Charitable Foundation
Dubuque, IA
National Spending & Credit Counseling
Center
Spring Valley, CA
S.H.O.C. Enterprise, Inc.
Corona, CA
Sales-Based Royalties and
Vendor Allowances; Hearing
Announcement 2011–26
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of public hearing on pro-
posed rulemaking.
SUMMARY: This document provides
notice of public hearing on a notice of
proposed rulemaking (REG–149335–08,
2011–6 I.R.B. 468) relating to the capi-
talization and allocation of royalties that
are incurred only upon the sale of property
produced or property acquired for resale
(sales-based royalties) and adjusting the
cost of merchandise inventory for an al-
lowance, discount, or price rebated based
on merchandise sales (sales-based ven-
dor allowances). The regulations modify
the simplified production method and the
simplified resale method of allocating cap-
italized costs between ending inventory
and cost of goods sold. The regulations
affect taxpayers that incur capitalizable
sales-based royalties and earn sales-based
vendor allowances.
DATES: The public hearing is being held
on Wednesday, April 13, 2011, at 10 a.m.
The IRS must receive outlines of the topics
to be discussed at the hearing by Monday,
March 28, 2011.
ADDRESSES: The public hearing is be-
ing held in the auditorium, Internal Rev-
enue Building, 1111 Constitution Avenue,
NW, Washington, DC. Send submissions
to: CC:PA:LPD:PR (REG–149335–08),
room 5203, Internal Revenue Service,
P.O. Box 7604, Ben Franklin Station,
Washington, DC 20044. Submissions may
be hand-delivered Monday through Friday
between the hours of 8 a.m. and 4 p.m.
to CC:PA:LPD:PR (REG–149335–08),
Courier’s Desk, Internal Revenue
Service, 1111 Constitution Avenue, NW,
Washington, DC. Alternatively, taxpayers
may submit electronic outlines of oral
comments via the Federal eRulemaking
Portal athttp://www.regulations.gov.
FOR FURTHER INFORMATION
CONTACT: Concerning the proposed
regulations, John Roman Faron at (202)
622–4930; concerning submissions of
comments, the hearing, and/or to be
placed on the building access list to at-
tend the hearing, Richard A. Hurst at
Richard.A.Hurst@irscounsel.treas.govor
(202) 622–7180 (not toll-free numbers).
SUPPLEMENTARY INFORMATION:
The subject of the public hearing is
the notice of proposed rulemaking
(REG–149335–08) that was published in
theFederal Registeron Friday, Decem-
ber 17, 2010 (75 FR 78940).
Persons,whowishtopresentoralcom-
ments at the hearing that submitted writ-
ten comments, must submit an outline of
the topics to be discussed and the amount
of time to be devoted to each topic (signed
original and eight (8) copies) by Monday,
March 28, 2011.
A period of 10 minutes is allotted to
each person for presenting oral comments.
After the deadline for receiving out-
lines has passed, the IRS will prepare an
agenda containing the schedule of speak-
ers. Copies of the agenda will be made
available, free of charge, at the hearing or
in the Freedom of Information Reading
Room (FOIA RR) (Room 1621) which
is located at the 11
th
and Pennsylvania
Avenue NW entrance, 1111 Constitution
Avenue, NW, Washington, DC.
Because of access restrictions, the IRS
will not admit visitors beyond the imme-
diateentranceareamorethan30minutes
before the hearing starts. For informa-
tion about having your name placed on the
building access list to attend the hearing,
see the FOR FURTHER INFORMATION
CONTACT section of this document.
April 4, 20116082011–14 I.R.B.

LaNita Van Dyke,
Chief, Publications and
Regulations Branch,
Legal Processing Division,
Associate Chief Counsel
(Procedure and Administration).
(Filed by the Office of the Federal Register on March 21,
2011, 8:45 a.m., and published in the issue of the Federal
Register for March 22, 2011, 76 F.R. 15887)
2011–14 I.R.B.609April 4, 2011

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.
April 4, 2011i2011–14 I.R.B.

Numerical Finding List
1
Bulletin 2011–1 through 2011–14
Announcements:
2011-1, 2011-2 I.R.B.304
2011-2, 2011-3 I.R.B.324
2011-3, 2011-3 I.R.B.324
2011-4, 2011-4 I.R.B.424
2011-5, 2011-4 I.R.B.430
2011-6, 2011-4 I.R.B.433
2011-7, 2011-5 I.R.B.446
2011-8, 2011-5 I.R.B.446
2011-9, 2011-7 I.R.B.499
2011-10, 2011-7 I.R.B.499
2011-11, 2011-7 I.R.B.500
2011-12, 2011-9 I.R.B.532
2011-13, 2011-8 I.R.B.525
2011-14, 2011-9 I.R.B.532
2011-15, 2011-8 I.R.B.526
2011-16, 2011-7 I.R.B.500
2011-17, 2011-9 I.R.B.532
2011-18, 2011-12 I.R.B.567
2011-19, 2011-11 I.R.B.553
2011-20, 2011-10 I.R.B.542
2011-21, 2011-12 I.R.B.567
2011-23, 2011-12 I.R.B.568
2011-24, 2011-12 I.R.B.569
2011-25, 2011-14 I.R.B.608
2011-26, 2011-14 I.R.B.608
Notices:
2011-1, 2011-2 I.R.B.259
2011-2, 2011-2 I.R.B.260
2011-3, 2011-2 I.R.B.263
2011-4, 2011-2 I.R.B.282
2011-5, 2011-3 I.R.B.314
2011-6, 2011-3 I.R.B.315
2011-7, 2011-5 I.R.B.437
2011-8, 2011-8 I.R.B.503
2011-9, 2011-6 I.R.B.459
2011-10, 2011-6 I.R.B.463
2011-11, 2011-7 I.R.B.497
2011-12, 2011-8 I.R.B.514
2011-13, 2011-9 I.R.B.529
2011-14, 2011-11 I.R.B.544
2011-15, 2011-10 I.R.B.539
2011-17, 2011-10 I.R.B.540
2011-18, 2011-11 I.R.B.549
2011-19, 2011-11 I.R.B.550
2011-22, 2011-12 I.R.B.557
2011-23, 2011-13 I.R.B.588
2011-24, 2011-14 I.R.B.603
2011-25, 2011-14 I.R.B.604
Proposed Regulations:
REG-140108-08, 2011-13 I.R.B.591
REG-149335-08, 2011-6 I.R.B.468
REG-146097-09, 2011-8 I.R.B.516
REG-153338-09, 2011-14 I.R.B.606
REG-124018-10, 2011-2 I.R.B.301
REG-131151-10, 2011-8 I.R.B.519
REG-131947-10, 2011-8 I.R.B.521
REG-132724-10, 2011-7 I.R.B.498
Revenue Procedures:
2011-1, 2011-1 I.R.B.1
2011-2, 2011-1 I.R.B.90
2011-3, 2011-1 I.R.B.111
2011-4, 2011-1 I.R.B.123
2011-5, 2011-1 I.R.B.167
2011-6, 2011-1 I.R.B.195
2011-7, 2011-1 I.R.B.233
2011-8, 2011-1 I.R.B.237
2011-9, 2011-2 I.R.B.283
2011-10, 2011-2 I.R.B.294
2011-11, 2011-4 I.R.B.329
2011-12, 2011-2 I.R.B.297
2011-13, 2011-3 I.R.B.318
2011-14, 2011-4 I.R.B.330
2011-15, 2011-3 I.R.B.322
2011-16, 2011-5 I.R.B.440
2011-17, 2011-5 I.R.B.441
2011-18, 2011-5 I.R.B.443
2011-19, 2011-6 I.R.B.465
2011-20, 2011-11 I.R.B.551
2011-21, 2011-12 I.R.B.560
Revenue Rulings:
2011-1, 2011-2 I.R.B.251
2011-2, 2011-2 I.R.B.256
2011-3, 2011-4 I.R.B.326
2011-4, 2011-6 I.R.B.448
2011-5, 2011-13 I.R.B.577
2011-6, 2011-10 I.R.B.537
2011-7, 2011-10 I.R.B.534
2011-8, 2011-12 I.R.B.554
2011-9, 2011-12 I.R.B.554
2011-10, 2011-14 I.R.B.597
Treasury Decisions:
9507, 2011-3 I.R.B.305
9508, 2011-7 I.R.B.495
9509, 2011-6 I.R.B.450
9510, 2011-6 I.R.B.453
9511, 2011-6 I.R.B.455
9512, 2011-7 I.R.B.473
9513, 2011-8 I.R.B.501
9514, 2011-9 I.R.B.527
9515, 2011-14 I.R.B.599
Treasury Decisions— Continued:
9516, 2011-13 I.R.B.575
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2010–27 through 2010–52 is in Internal Revenue Bulletin
2010–52, dated December 27, 2010.
2011–14 I.R.B.iiApril 4, 2011

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2011–1 through 2011–14
Announcements:
85-88
Obsoleted by
Rev. Proc. 2011-10, 2011-2 I.R.B.294
2008-11
Modified by
Ann. 2011-6, 2011-4 I.R.B.433
2009-62
Obsoleted by
Rev. Proc. 2011-10, 2011-2 I.R.B.294
Notices:
2006-87
Superseded by
Notice 2011-8, 2011-8 I.R.B.503
2007-25
Superseded by
Notice 2011-8, 2011-8 I.R.B.503
2007-77
Superseded by
Notice 2011-8, 2011-8 I.R.B.503
2008-107
Superseded by
Notice 2011-8, 2011-8 I.R.B.503
2009-23
Modified by
Notice 2011-24, 2011-14 I.R.B.603
2009-24
Modified by
Notice 2011-24, 2011-14 I.R.B.603
2009-83
Modified by
Notice 2011-25, 2011-14 I.R.B.604
2010-27
Superseded by
Notice 2011-8, 2011-8 I.R.B.503
2010-59
Modified by
Notice 2011-5, 2011-3 I.R.B.314
2010-71
Modified and superseded by
Notice 2011-9, 2011-6 I.R.B.459
2010-79
Clarified and modified by
Notice 2011-4, 2011-2 I.R.B.282
Proposed Regulations:
REG-132554-08
Corrected by
Ann. 2011-11, 2011-7 I.R.B.500
REG-149335-08
Hearing scheduled by
Ann. 2011-26, 2011-14 I.R.B.608
Revenue Procedures:
72-50
Modified and superseded by
Rev. Proc. 2011-10, 2011-2 I.R.B.294
76-34
Modified and supersed by
Rev. Proc. 2011-10, 2011-2 I.R.B.294
83-23
Modified and superseded by
Rev. Proc. 2011-15, 2011-3 I.R.B.322
94-17
Modified and superseded by
Rev. Proc. 2011-15, 2011-3 I.R.B.322
97-27
Clarified and modified by
Rev. Proc. 2011-4, 2011-1 I.R.B.330
2001-10
Modified by
Rev. Proc. 2011-4, 2011-4 I.R.B.330
2002-28
Modified by
Rev. Proc. 2011-4, 2011-4 I.R.B.330
2003-21
Modified and superseded by
Rev. Proc. 2011-15, 2011-3 I.R.B.322
2004-34
Modified by
Rev. Proc. 2011-14, 2011-4 I.R.B.330
Modified and clarified by
Rev. Proc. 2011-18, 2011-5 I.R.B.443
2006-44
Modified by
Ann. 2011-6, 2011-4 I.R.B.433
2006-56
Modified by
Rev. Proc. 2011-14, 2011-4 I.R.B.330
2008-52
Modified by
Notice 2011-4, 2011-2 I.R.B.282
Rev. Proc. 2011-17, 2011-5 I.R.B.441
Superseded in part by
Rev. Proc. 2011-14, 2011-4 I.R.B.330
Revenue Procedures— Continued:
2009-39
Superseded in part by
Rev. Proc. 2011-14, 2011-4 I.R.B.330
2009-44
Modified by
Ann. 2011-6, 2011-4 I.R.B.433
2010-1
Superseded by
Rev. Proc. 2011-1, 2011-1 I.R.B.1
2010-2
Superseded by
Rev. Proc. 2011-2, 2011-1 I.R.B.283
2010-3
Superseded by
Rev. Proc. 2011-3, 2011-1 I.R.B.111
2010-4
Superseded by
Rev. Proc. 2011-4, 2011-1 I.R.B.123
2010-5
Superseded by
Rev. Proc. 2011-5, 2011-1 I.R.B.167
2010-6
Superseded by
Rev. Proc. 2011-6, 2011-1 I.R.B.195
2010-7
Superseded by
Rev. Proc. 2011-7, 2011-1 I.R.B.233
2010-8
Superseded by
Rev. Proc. 2011-8, 2011-1 I.R.B.237
2010-9
Superseded by
Rev. Proc. 2011-9, 2011-2 I.R.B.283
2010-15
Updated by
Rev. Proc. 2011-13, 2011-3 I.R.B.318
2010-18
Amplified and modified by
Rev. Proc. 2011-21, 2011-12 I.R.B.560
2011-1
Corrected by
Ann. 2011-7, 2011-5 I.R.B.446
2011-8
Corrected by
Ann. 2011-8, 2011-5 I.R.B.446
2011-11
Corrected by
Ann. 2011-9, 2011-7 I.R.B.499
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2010–27 through 2010–52 is in Internal Revenue Bulletin 2010–52, dated December 27,
2010.
April 4, 2011iii2011–14 I.R.B.

Revenue Rulings:
81-100
Modified by
Rev. Rul. 2011-1, 2011-2 I.R.B.251
2004-67
Modified by
Rev. Rul. 2011-1, 2011-2 I.R.B.251
2008-40
Modified by
Rev. Rul. 2011-1, 2011-2 I.R.B.251
2011-3
Corrected by
Ann. 2011-16, 2011-7 I.R.B.500
Treasury Decisions:
9391
Corrected by
Ann. 2011-12, 2011-9 I.R.B.532
9505
Corrected by
Ann. 2011-10, 2011-7 I.R.B.499
2011–14 I.R.B.ivApril 4, 2011

April 4, 20112011–14 I.R.B.

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