Internal Revenue Bulletin 2015-51 (PDF rendition): IRS Revenue Procedures

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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 2015–35, page 865.
This document contains corrections to Revenue Procedure
2015–55, as published on Monday, December 7, 2015 (I.R.B.
2015– 49, 788). In particular, this announcement corrects
certain administrative items.
Rev. Proc. 2015–57, page 863.
Rev. Proc. 2015–57 provides that the IRS will not assert that
a taxpayer who took out Federal student loans to finance
attendance at a school owned by Corinthian Colleges, Inc. that
are discharged under the Department of Education’s (ED) De-
fense to Repayment discharge process must recognize gross
income as a result of this discharge process. This revenue
procedure also identifies the statutory basis under which tax-
payers whose Federal student loans are discharged under ED’s
Closed School discharge process may exclude the discharged
amount from gross income. In addition, this revenue procedure
provides that the IRS will not assert that taxpayers within the
scope of this revenue procedure must increase their taxes
owed in the year of a discharge as a result of either discharge
process if in a prior taxable year they received an education
credit under section 25A or took a deduction under section
221 or 222.
Notice 2015–83, page 861.
This Notice modifies Notice 2012– 48, 2012–31 I.R.B. 102,
regarding the process for allocation of the available amount of
national volume cap for tax-exempt tribal economic develop-
ment bonds under § 7871(f) of the Internal Revenue Code,
provides special rules for bonds issued under a “draw-down”
loan structure in which the lender advances funds for the loan
on different dates (Draw-down Bonds), and allows additional
time to use allocated volume cap for issuance of Draw-down
Bonds if an issuer meets certain requirements.
EXEMPT ORGANIZATIONS
Announcement 2015–34, page 865.
Serves notice to potential donors of organizations that have
recently filed a timely declaratory judgment suit under section
7428 of the Code, challenging revocation of its status as an
eligible donee under section 170(c)(2).
ADMINISTRATIVE
Announcement 2015–35, page 865.
This document contains corrections to Revenue Procedure
2015–55, as published on Monday, December 7, 2015 (I.R.B.
2015– 49, 788). In particular, this announcement corrects
certain administrative items.
Finding Lists begin on page ii.
Bulletin No. 2015–51
December 21, 2015

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.
December 21, 2015Bulletin No. 2015–51

Part III. Administrative, Procedural, and Miscellaneous
Tribal Economic
Development Bonds: Use of
Volume Cap for Draw-down
Loans
Notice 2015–83
SECTION 1. PURPOSE
This Notice modifies Notice 2012–48,
2012–31 I.R.B. 102, regarding the process
for allocation of the available amount of
national bond volume limitation authority
(volume cap) for tax-exempt tribal eco-
nomic development bonds under
§ 7871(f) of the Internal Revenue Code
(Tribal Economic Development Bonds).
This Notice provides special rules for
bonds issued under a “draw-down” loan
structure in which the lender advances
funds for the loan on different dates
(Draw-down Bonds). This Notice allows
additional time to use allocated volume
cap for issuance of Draw-down Bonds if
an issuer meets certain requirements.
SECTION 2. BACKGROUND
Notice 2012–48 solicited applications
for allocation of volume cap for Tribal
Economic Development Bonds, and pro-
vided guidance on the application require-
ments, the application forms, the alloca-
tion method, and the time period for
issuance before forfeiture of allocated vol-
ume cap. For previous guidance on this
process, see Notice 2009–51, 2009–28
I.R.B. 128; Announcement 2010–88,
2010–47 I.R.B. 753; and Announcement
2011–71, 2011–46 I.R.B. 770.
Generally, under section 4.g. of Notice
2012–48, an applicant seeking an alloca-
tion of volume cap (Applicant) must dem-
onstrate a readiness to issue the bonds.
Once an Applicant is allocated volume
cap, the Applicant has 180 days from the
date of the allocation letter to issue the
bonds (the 180-day period). Volume cap
allocated for those bonds that are not is-
sued within such 180-day period is for-
feited and available for reallocation. Also,
an Applicant is required to send the Inter-
nal Revenue Service (IRS) notice of issu-
ance of Tribal Economic Development
Bonds not later than 15 days after issu-
ance.
Questions have arisen regarding when
Tribal Economic Development Bonds are
considered “issued” for purposes of the
180-day period for issuance pursuant to an
allocation of volume cap. Under the stat-
utory framework, the general rules for
State and local bonds issued by States and
political subdivisions under § 103 apply
with modifications to Tribal Economic
Development Bonds issued by Indian
tribal governments under § 7871(f). In
general, Notice 2010–81, 2010–50 I.R.B.
825, provides that a State or local bond is
considered issued on the “issue date” of
the “bond” under § 1.150–1(b) of the
Treasury Regulations. Section 1.150–1(b)
defines the “issue date” of a “bond” to
mean the date on which the issuer receives
the purchase price in exchange for that
bond, provided that in no event is the issue
date of a bond earlier than the first day on
which interest begins to accrue on such
bond for Federal income tax purposes. For
bonds issued under a “draw-down” loan
structure under § 1.150–1(c)(4)(i) in
which draws of funds occur on different
dates, while the “issue” has a single issue
date, each draw or bond within the issue
may have a separate issue date. Specifi-
cally, when the issuer draws down under
the loan, it receives the purchase price and
interest begins to accrue on the draw, re-
sulting in the date of the draw constituting
the issue date of the bond associated with
the draw. Therefore, under the general
rules for State and local bonds in Notice
2010–81, for Draw-down Bonds, only
amounts that are drawn (and for which
interest begins to accrue for Federal in-
come tax purposes) within the 180-day
period meet the timing requirement for
issuance under section 4.g. of Notice
2012–48. Applicants have informed the
IRS that this general rule for issuance has
created administrative difficulties which
have precluded the use of Draw-down
Bonds.
In Notice 2011–63, 2011–34 I.R.B
172, the IRS provided certain special rules
for determining issuance of State or local
bonds in draw-down loan structures for
purposes of allocation and administration
of private activity bond volume cap under
§ 146. Similarly, this Notice provides spe-
cial rules regarding the issuance of Tribal
Economic Development Bonds for pur-
poses of allocation and administration of
bond volume cap under § 7871(f) in the
context of Draw-down Bonds.
SECTION 3. MODIFICATION TO
NOTICE 2012–48
Notice 2012–48 is modified by adding
section 10 to Notice 2012–48 to read as
follows:
SECTION 10. SPECIAL RULES FOR
TRIBAL ECONOMIC DEVELOPMENT
BONDS ISSUED AS DRAW-DOWN
BONDS
a.In general. In addition to the general
provisions of this Notice and notwith-
standing any provision of this Notice to
the contrary, if an Applicant expects to
use any part of its allocation of volume
cap to issue Tribal Economic Develop-
ment Bonds under a “draw-down” loan
structure in which the lender advances
funds for the loan on different dates ex-
pected to occur both within 180 days from
the date of the allocation letter (the 180-
day period) and after the 180 day period
(together, for purposes of this section, the
Draw-down Bonds), the special rules of
this section 10 shall apply.
b.Plan of financing. For purposes of
section 3.g. of this Notice, an Applicant
that expects to use any part of its Tribal
Economic Development Bond volume cap
allocation to issue Draw-down Bonds af-
ter the 180-day period will meet the re-
quirement of item (3) of section 3.g. of
this Notice (regarding documentation
from an independent third party about the
marketability of the bonds) if the Appli-
cant submits a commitment letter from a
financial institution stating that the insti-
tution reasonably expects to advance the
total principal amount of the Draw-down
Bonds no later than three years after the
date of the allocation letter.
c.Expiration of allocation. For pur-
poses of section 4.g. of this Notice (re-
garding expiration of allocations), if the
proposed bonds associated with the allo-
cation are Draw-down Bonds and the Ap-
plicant has submitted the commitment let-
ter required by section 10.b. of this
Bulletin No. 2015–51December 21, 2015
861

Notice, the rules in section 10.c.1 and
10.c.2 of this Notice, as applicable, apply
for purposes of determining the time pe-
riod for issuing the proposed bonds pur-
suant to the volume cap allocation. A vol-
ume cap allocation for Draw-down Bonds
is forfeited to the extent of any Draw-
down Bonds that are not issued within the
allowable time period for issuance under
the allocation.
1. Except as provided in section 10.c.2
of this Notice, if the Applicant issues
Draw-down Bonds in an amount equal to
at least 10 percent of its volume cap allo-
cation within the 180-day period, the un-
used portion of the allocation amount will
remain valid for two years from the date
of the allocation letter (the 2-year period)
to issue Draw-down Bonds under that al-
location.
2. If the Applicant meets the require-
ments in section 10.c.1 of this Notice and
also issues Draw-down Bonds in an
amount equal in the aggregate to at least
50 percent of its volume cap allocation
within the 2-year period, the unused por-
tion of the allocation amount will remain
valid for three years from the date of the
allocation letter (the 3-year period) to is-
sue the Draw-down Bonds under that al-
location.
d.Notice of issuance.1.In general. For
purposes of section 7.a. of this Notice
(regarding notice of issuance), if the pro-
posed bonds are Draw-down Bonds, an
Applicant must submit to the IRS one or
more notices of issuance (Notice of Issu-
ance) under the rules set forth in sections
10.d.2. and 10.d.3 of this Notice, as appli-
cable, to the address set forth in section
3.d. of this Notice. All Notices of Issuance
shall include the following information:
(1) the Applicant’s name and taxpayer
identification number; (2) the issue price
of the bonds issued; (3) the issue date of
the bonds; (4) a description of the project
financed with the bonds; and (5) the
amount of allocation that is being for-
feited. Any Notice of Issuance that pro-
vides for an amount of allocation that is
being forfeited will serve as a notice of
voluntary forfeiture under section 4.i. of
this Notice with respect to that allocation
amount.
2.Notice of final draw. The Applicant
must submit a Notice of Issuance not later
than 15 days after the final draw for the
Draw-down Bonds (the Notice of Final
Draw).
3.Additional notices of issuance. The
Applicant must submit additional Notices
of Issuance using the following rules, as
applicable.
A. Unless the Applicant has submitted
the Notice of Final Draw as provided in
section 10.d.2. of this Notice, the Appli-
cant shall submit a Notice of Issuance
within 15 days after the 180-day period.
This Notice of Issuance shall state at the
top that it is a “180-Day Draw-down No-
tice” and include the percentage of the
allocation used to issue Draw-down
Bonds under that allocation within the
180-day period.
B. Unless the Applicant has submitted
a Notice of Final Draw as provided in
section 10.d.2. of this Notice, for Draw-
down Bonds issued after the 180-day pe-
riod, Applicant shall submit a Notice of
Issuance within 15 days after the end of
the 2-year period following the date of the
allocation letter. This Notice of Issuance
shall state at the top that it is the “2-year
Draw-down Notice” and include the total
percentages of the allocation used to issue
Draw-down Bonds under that allocation
within both the 180-day period and the
2-year period.
C. Unless the Applicant has submitted
a Notice of Final Draw as provided in
section 10.d.2. of this Notice, for Draw-
down Bonds issued after the 2-year pe-
riod, the Applicant shall submit a Notice
of Issuance within 15 days after the end of
the 3-year period. This Notice of Issuance
shall state at the top that it is the “Final
Draw-down Notice” and include the total
percentages of the allocation used to issue
Draw-down Bonds under that allocation
within each of the following periods: the
180-day period, the 2-year period, and the
3-year period.
SECTION 4. REQUEST FOR
COMMENTS ON RULES ON
ISSUING NEW CLEAN
RENEWABLE ENERGY BONDS AS
DRAW-DOWN BONDS
The Department of the Treasury and
the IRS seek comments regarding whether
to consider providing special volume cap
allocation rules for New Clean Renewable
Energy Bonds issued as Draw-down
Bonds similar to the rules in this Notice.
Comments should be submitted in writing
and can be e-mailed tonotice.comments@
irscounsel.treas.gov(include “Notice 2015–
83” in the subject line) or mailed to Office
of Associate Chief Counsel (Financial In-
stitutions and Products), Re: Notice 2015–
83, CC:FIP:Branch 5, Room 3547, 1111
Constitution Avenue, NW, Washington,
DC 20224. Comments that are submitted
will be made available to the public.
SECTION 5. EFFECT ON OTHER
DOCUMENTS
Notice 2012–48 is modified.
SECTION 6.
EFFECTIVE/APPLICABILITY
DATE
This Notice is effective for an applica-
tion for allocation of Tribal Economic
Development Bond volume cap that is
submitted on or after December 4, 2015.
In addition, an Applicant that has re-
ceived an allocation that has not expired
before December 4, 2015, may rely on
this Notice, provided that such Appli-
cant meets the applicable requirements
of Notice 2012–48, as modified by this
Notice, on or before the expiration date
of the allocation.
SECTION 7. PAPERWORK
REDUCTION ACT
The information collection contained
in Notice 2012–48 has been approved by
the Office of Management and Budget
(OMB) in accordance with the Paperwork
Reduction Act (44 U.S.C. chapter 35) un-
der control number 1545–2233. Under the
Paperwork Reduction Act, an agency may
not conduct or sponsor and a person is not
required to respond to a collection of in-
formation unless it displays a valid OMB
control number.
This Notice modifies Notice 2012–48.
Certain modifications to Notice 2012–48
change the collection of information re-
quirements contained in Notice 2012–48,
as approved under control number 1545-
2233. The modified collection of informa-
tion requirements are contained in section
3 of this Notice. The information is re-
quired in order to inform the IRS of an
Applicant’s readiness to receive an allo-
cation of volume cap for Tribal Economic
Development Bonds as Draw-down
December 21, 2015Bulletin No. 2015–51
862

Bonds, the Applicant’s timely use of such
allocation, and the amount of such volume
cap that may be allocated to each Appli-
cant. The collections of information are
required for any Applicant that wishes to
receive an allocation of volume cap for
Tribal Economic Development Bonds as
Draw-down Bonds. The likely respon-
dents will be eligible issuers of Tribal
Economic Development Bonds.
We estimate the total number of re-
spondents to be 143 and the total annual
responses to be 143. We estimate it will
take 8 hours to comply. Estimates of the
annualized cost to respondents for the
hour burdens shown are not available at
this time.
Books or records relating to a collec-
tion 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
return information are confidential, as re-
quired by § 6103.
SECTION 8. DRAFTING
INFORMATION
The principal authors of this Notice are
Darrell Smelcer and Marie Sullivan of the
IRS Office of Tax Exempt Bonds and
Zoran Stojanovic of the Office of the As-
sociate Chief Counsel (Financial Institu-
tions and Products). For further informa-
tion regarding this Notice, contact Ms.
Sullivan at 225-923-4168 or Mr. Sto-
janovic at 202-317-6980 (not toll-free
numbers).
Rev. Proc. 2015–57
SECTION 1. PURPOSE
This revenue procedure provides that
the Internal Revenue Service (IRS) will
not assert that certain taxpayers, whose
Federal student loans are discharged un-
der the Department of Education’s “De-
fense to Repayment” discharge process,
must recognize gross income as a result of
this discharge process. This revenue pro-
cedure also identifies the statutory provi-
sions under which taxpayers whose Fed-
eral student loans are discharged under the
Department of Education’s “Closed
School” discharge process may exclude
the discharged amount from gross income.
In addition, this revenue procedure pro-
vides that the IRS will not assert that these
taxpayers must increase their taxes owed
in the year of a discharge as a result of
either discharge process if in a prior tax-
able year they received an education
credit under section 25A (Hope and Life-
time Learning Credits) or took a deduc-
tion under section 221 (interest on educa-
tion loans) or section 222 (qualified
tuition and related expenses) of the Inter-
nal Revenue Code (Code).
SECTION 2. BACKGROUND
.01In general.
The Treasury Department and the IRS
are aware that the Department of Educa-
tion (ED) has begun a process for settling
and discharging Federal student loans
taken out to finance attendance at schools
owned by Corinthian Colleges, Inc. ED
has estimated that over 50,000 Corinthian
borrowers may be eligible for discharges
under this program. The discharges con-
templated by ED for these loans are to be
made under one of the following process-
es: (i) the Closed School discharge pro-
cess, or (ii) the Defense to Repayment
discharge process based on misrepresen-
tations made by the colleges. For more
information, seePress Release,Dep’t of
Education, Fact Sheet: Protecting Stu-
dents from Abusive Career Colleges(June
8, 2015), available athttp://www.ed.gov/
news/press-release.
In general, under the Higher Education
Act of 1965 (HEA), the Closed School dis-
charge process allows ED to discharge a
Federal student loan obtained by a student,
or by a parent on behalf of a student, who
was attending a school at the time it closed
or who withdrew from the school within a
certain period prior to the closing date.See
generally20 U.S.C. § 1087(c) (Federal
Family Education Loan (FFEL)); 20 U.S.C.
§ 1087dd(g) (Federal Perkins Loan); and 20
U.S.C. § 1087e(a)(1) (Federal Direct Loan).
Under the HEA, theDefense to Repayment
process requires ED to discharge a Fed-
eral Direct Loan if a student loan bor-
rower establishes, as a defense against
repayment, that a school’s actions would
give rise to a cause of action against the
school under applicable state law.See
generally20 U.S.C. § 1087e(h) and 34
C.F.R. § 685.206(c). FFEL loans may also
be discharged under this process if certain
additional requirements are met.See34
C.F.R. § 682.209(g).
Section 61(a)(12) of the Code provides
that gross income includes income from
the discharge of indebtedness. There are,
however, exceptions under which a tax-
payer may not be required to include in-
come from the discharge of indebtedness
in gross income. The availability of these
exceptions depends on a variety of factors,
such as the circumstances of the loan’s
origination and the borrower’s financial
situation at the time of the loan’s dis-
charge. In some cases, a discharge may
result in an increase in gross income under
the tax benefit rule, or an increase in tax
liability due to a recapture of credits.
.02Borrowers participating in Closed
School discharge process.
The HEA provides statutory exclusions
from gross income for Federal student
loans discharged under the Closed School
discharge process.See generally20 U.S.C.
§ 1087ee(a)(5); 20 U.S.C. § 1087(c)(4)
(FFEL); 20 U.S.C. § 1087dd(g)(4) (Federal
Perkins Loan); and 20 U.S.C. § 1087e(a)(1)
(Federal Direct Loan). Accordingly, a tax-
payer whose Federal student loan is dis-
charged under the Closed School discharge
process will not recognize gross income as a
result of the discharge, and the taxpayer
should not report the amount of the dis-
charged loan in gross income on his or her
Federal income tax return.
.03Borrowers participating in Defense
to Repayment discharge process.
The HEA does not provide a statutory
exclusion from gross income for Federal
student loans discharged under the De-
fense to Repayment discharge process.
However, a taxpayer may be able to ex-
clude amounts discharged under this pro-
cess from gross income under a provision
of the Code or other tax law authorities.
For example, a borrower that has a
liability reduced because of a legal infir-
mity that relates back to the original sale
transaction (for example, fraud) may not
have gross income to the extent of the
debt reduction. This requires a case-by-
case analysis of each transaction.
In addition, section 108(a)(1)(B) of the
Code provides that a taxpayer may ex-
Bulletin No. 2015–51December 21, 2015
863

clude from gross income a discharge of
indebtedness that occurs when the tax-
payer is insolvent (the “insolvency exclu-
sion”). A taxpayer is insolvent if all of the
taxpayer’s liabilities exceed all of the tax-
payer’s assets immediately before the dis-
charge. Under the insolvency exclusion, a
taxpayer is able to exclude the amount of
discharged debt from gross income to the
extent that the taxpayer’s liabilities ex-
ceed the fair market value of his or her
assets.
The Treasury Department and the IRS
believe that most borrowers whose Corin-
thian student loans are discharged under
the Defense to Repayment discharge pro-
cess would be able to exclude from gross
income all or substantially all of the dis-
charged amounts based on fraudulent mis-
representations made by the colleges to
the students, the insolvency exclusion, or
another tax law authority. However, de-
termining whether one or more of these
exceptions is available to each affected
borrower would require a fact intensive
analysis of the particular borrower’s situ-
ation to determine the extent to which the
discharged amount is eligible for exclu-
sion under each of the potentially avail-
able exceptions. The Treasury Department
and the IRS are concerned that such an
analysis would impose a compliance bur-
den on taxpayers, as well as an adminis-
trative burden on the IRS, that is excessive
in relation to the amount of taxable in-
come that would result. Accordingly, the
IRS will not assert that a taxpayer within
the scope of this revenue procedure rec-
ognizes gross income as a result of the
Defense to Repayment discharge process.
SECTION 3. SCOPE
The treatment provided in section 4 of
this revenue procedure applies to any tax-
payer who took out Federal student loans
to finance attendance at a school owned
by Corinthian Colleges, Inc. that are dis-
charged under the Closed School dis-
charge process or the Defense to Repay-
ment discharge process.
SECTION 4. APPLICATION
.01Discharge of indebtedness income.
The IRS will not assert that a taxpayer
within the scope of this revenue procedure
must recognize gross income as a result of
the Defense to Repayment discharge pro-
cess for discharged student loans that
were taken out to finance attendance at a
school owned by Corinthian Colleges,
Inc. See section 2.02 of this revenue pro-
cedure for a general discussion regarding
the exclusion from gross income for bor-
rowers participating in the Closed School
discharge process.
.02Recapture of tax credits and tax
benefit rule. The IRS will not assert that a
taxpayer within the scope of this revenue
procedure must increase his or her taxes
owed in the year of a discharge, or in a
prior year, as a result of either discharge
process if in a prior year he or she re-
ceived an education credit under section
25A attributable to payments made with
proceeds of the discharged loan. In addi-
tion, the IRS also will not assert that a
taxpayer within the scope of this revenue
procedure must increase his or her income
in the year of the discharge if he or she
took a deduction under section 221 in a
prior year attributable to interest paid on a
discharged loan or a deduction under sec-
tion 222 in a prior taxable year attribut-
able to payments of qualified tuition and
related expenses made with proceeds of
the discharged loan.
SECTION 5. EFFECTIVE DATE
This revenue procedure is effective for
taxable years beginning on or after Janu-
ary 1, 2015, for Federal student loans dis-
charged under ED’s Closed School and
Defense to Repayment discharge pro-
cesses.
SECTION 6. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Craig Wojay of the Office of
Associate Chief Counsel (Income Tax &
Accounting). For further information re-
garding this revenue procedure, contact
Mr. Wojay at (202) 317-4718 (not a toll-
free number).
December 21, 2015Bulletin No. 2015–51
864

Part IV. Items of General Interest
Section 7428(c) Validation
of Certain Contributions
Made During Pendency of
Declaratory Judgment
Proceedings
Announcement 2015–34
This announcement serves notice to
potential donors that the organization
listed below has recently filed a timely
declaratory judgment suit under section
7428 of the Code, challenging revocation
of its status as an eligible donee under
section 170(c)(2).
Protection under section 7428(c) of the
Code begins on the date that the notice of
revocation is published in the Internal
Revenue Bulletin and ends on the date on
which a court first determines that an or-
ganization is not described in section
170(c)(2), as more particularly set forth in
section 7428(c)(1).
In the case of individual contributors,
the maximum amount of contributions
protected during this period is limited to
$1,000.00, with a husband and wife being
treated as one contributor. This protection
is not extended to any individual who was
responsible, in whole or in part, for the
acts or omissions of the organization that
were the basis for the revocation. This
protection also applies (but without limi-
tation as to amount) to organizations de-
scribed in section 170(c)(2) which are ex-
empt from tax under section 501(a). If the
organization ultimately prevails in its de-
claratory judgment suit, deductibility of
contributions would be subject to the nor-
mal limitations set forth under section
170.
Name of OrganizationDate Suit FiledEffective Date of RevocationLocation
Community Education Foundation1/15/20141/1/2008Baltimore, MD
Corrections to Revenue
Procedure 2015–55, as
published on Monday,
December 7, 2015 (I.R.B.
2015–49, 788). In
particular, this
announcement corrects
certain administrative items.
Announcement 2015–35
Correction 1:
InSection 1.1.5 Forms Not Covered
by This Revenue Procedure, under the
4
th
bullet we deleted the reference to Form
8935, as the form is now obsolete.
Correction 2:
InSection 1.2.1 Where To Send Sub-
stitute Forms,the 2
nd
bullet incorrectly
referred to form “S–3c”. The correct ref-
erence is “W–3c.”
Correction 3:
InSection 1.2.1 Where To Send Sub-
stitute Forms,the 4
th
bullet incorrectly
referred to form “3022”. The correct ref-
erence is “3922.”
Correction 4:
InSection 4.1.1 General,the 2
nd
bul
-
let has an incorrect title for Pub. 1179.
The correct title for Pub. 1179 is “General
Rules and Specifications for Substitute
Forms 1096, 1098, 1099, 5498, and Cer-
tain Other Information Returns.”
Bulletin No. 2015–51December 21, 2015
865

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:
Amplifieddescribes 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).
Clarifiedis 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.
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
with amplified andclarified, 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
being stated in a new ruling.
Supersededdescribes 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
supersededdescribes 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.
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
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.
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 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.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE
—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Bulletin No. 2015–51December 21, 2015
i

Numerical Finding List
1
Bulletins 2015–27 through 2015–51
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
2015-25, 2015-39 I.R.B.422
2015-26, 2015-47 I.R.B.677
2015-27, 2015-48 I.R.B.694
2015-28, 2015-46 I.R.B.673
2015-29, 2015-46 I.R.B.673
2015-30, 2015-46 I.R.B.673
2015-31, 2015-49 I.R.B.841
2015-32, 2015-49 I.R.B.841
2015-33, 2015-49 I.R.B.842
2015-34, 2015-51 I.R.B.865
2015-35, 2015-51 I.R.B.865
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
2015-59, 2015-40 I.R.B.459
2015-60, 2015-43 I.R.B.604
2015-61, 2015-39 I.R.B.408
2015-62, 2015-39 I.R.B.411
2015-63, 2015-40 I.R.B.461
2015-64, 2015-40 I.R.B.464
2015-65, 2015-40 I.R.B.466
2015-66, 2015-41 I.R.B.541
2015-67, 2015-41 I.R.B.546
2015-68, 2015-41 I.R.B.547
2015-69, 2015-41 I.R.B.550
2015-70, 2015-43 I.R.B.604
2015-71, 2015-43 I.R.B.606
2015-72, 2015-44 I.R.B.613
2015-73, 2015-46 I.R.B.660
2015-74, 2015-46 I.R.B.663
2015-75, 2015-46 I.R.B.668
2015-76, 2015-46 I.R.B.669
Notices:—Continued
2015-77, 2015-47 I.R.B.676
2015-78, 2015-48 I.R.B.690
2015-79, 2015-49 I.R.B.775
2015-80, 2015-48 I.R.B.691
2015-81, 2015-49 I.R.B.784
2015-82, 2015-50 I.R.B.859
2015-83, 2015-51 I.R.B.861
Proposed Regulations:
REG-140379-02, 2015-45 I.R.B.653
REG-134219-08, 2015-49 I.R.B.842
REG-136459-09, 2015-37 I.R.B.332
REG-155164-09, 2015-41 I.R.B.560
REG-109370-10, 2015-33 I.R.B.198
REG-112997-10, 2015-39 I.R.B.422
REG-103033-11, 2015-37 I.R.B.325
REG-109813-11, 2015-37 I.R.B.330
REG-138344-13, 2015-41 I.R.B.557
REG-139483-13, 2015-40 I.R.B.475
REG-148998-13, 2015-45 I.R.B.653
REG-115452-14, 2015-32 I.R.B.158
REG-127895-14, 2015-41 I.R.B.556
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-121496-15, 2015-46 I.R.B.674
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
2015-43, 2015-40 I.R.B.467
2015-44, 2015-38 I.R.B.354
2015-45, 2015-39 I.R.B.412
2015-46, 2015-39 I.R.B.414
2015-47, 2015-39 I.R.B.419
2015-48, 2015-40 I.R.B.469
2015-49, 2015-41 I.R.B.555
2015-50, 2015-42 I.R.B.583
2015-51, 2015-42 I.R.B.583
2015-52, 2015-45 I.R.B.638
2015-53, 2015-44 I.R.B.615
2015-54, 2015-45 I.R.B.648
2015-55, 2015-49 I.R.B.788
2015-56, 2015-49 I.R.B.827
2015-57, 2015-51 I.R.B.863
Revenue Rulings:
2015-15, 2015-27 I.R.B.1
2015-16, 2015-31 I.R.B.130
2015-17, 2015-39 I.R.B.358
2015-18, 2015-34 I.R.B.209
2015-19, 2015-36 I.R.B.291
2015-20, 2015-38 I.R.B.353
2015-21, 2015-40 I.R.B.447
2015-22, 2015-44 I.R.B.610
2015-24, 2015-48 I.R.B.687
2015-25, 2015-49 I.R.B.695
2015-26, 2015-49 I.R.B.696
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
9732, 2015-39 I.R.B.371
9733, 2015-41 I.R.B.494
9734, 2015-41 I.R.B.500
9735, 2015-37 I.R.B.316
9736, 2015-39 I.R.B.402
9737, 2015-40 I.R.B.449
9738, 2015-40 I.R.B.453
9739, 2015-41 I.R.B.528
9740, 2015-42 I.R.B.573
9741, 2015-45 I.R.B.628
9742, 2015-46 I.R.B.657
9743, 2015-48 I.R.B.679
9744, 2015-49 I.R.B.700
1
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.
December 21, 2015Bulletin No. 2015–51
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2015–27 through 2015–51
Notices:
2011-55
Amplified by
Notice 2015-77, 2015-47 I.R.B.676
2012-48
Modified by
Notice 2015-83, 2015-51 I.R.B.861
2013-7
Amplified by
Notice 2015-77, 2015-47 I.R.B.676
2014-4
Modified by
Notice 2015-51, 2015-31 I.R.B.133
2014-17
Superseded by
Notice 2015-67, 2015-41 I.R.B.546
Proposed Regulations:
2009-57
Obsoleted by
REG-112997-10 2015-39 I.R.B.422
2013-17
Obsoleted by
REG-148998-13 2015-45 I.R.B.653
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
2003-78
Modified by
Rev. Proc. 2015-46, 2015-39 I.R.B.414
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
Revenue Procedures:—Continued
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
2015-8
Superseded by
Rev. Proc. 2015-55, 2015-49 I.R.B.788
2015-14
Modified by
Rev. Proc. 2015-39, 2015-33 I.R.B.195
2015-14
Modified by
Rev. Proc. 2015-56, 2015-49 I.R.B.827
2015-18
Superseded by
Rev. Proc. 2015-55, 2015-49 I.R.B.788
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
Revenue Rulings:
2014-30
Supplemented by
Rev. Rul. 2015-24, 2015-48 I.R.B.687
2014-30
Superseded by
Rev. Rul. 2015-24, 2015-48 I.R.B.687
Treasury Decisions:
58-422
Obsoleted by
T.D. 9739 2015-41 I.R.B.528
Treasury Decisions:—Continued
66-284
Obsoleted by
T.D. 9739 2015-41 I.R.B.528
79-250
Obsoleted by
T.D. 9739 2015-41 I.R.B.528
79-289
Obsoleted by
T.D. 9739 2015-41 I.R.B.528
96-29
Obsoleted by
T.D. 9739 2015-41 I.R.B.528
1
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.
Bulletin No. 2015–51December 21, 2015
iii

INTERNAL REVENUE BULLETIN
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