Internal Revenue Bulletin 2017-27 (PDF rendition): IRS Revenue Rulings

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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
Action On Decision 2017– 05, page 1.
Nonacquiescence to the holding that a taxpayer whose filing
status is married filing separately is entitled to an earned
income tax credit.
Rev. Rul. 2017–14, page 2.
Federal rates; adjusted federal rates; adjusted federal long-
term rate and the long-term exempt rate. For purposes of
sections 382, 642, 1274, 1288, 7872, and other sections of
the Code, tables set forth the rates for July 2017.
ADMINISTRATIVE
Announcement 2017– 05, page 5.
The Office of Professional Responsibility (OPR) announces re-
cent disciplinary sanctions involving attorneys, certified public
accountants, enrolled agents, enrolled actuaries, enrolled re-
tirement plan agents, and appraisers. These individuals are
subject to the regulations governing practice before the Inter-
nal Revenue Service (IRS), which are set out in Title 31, Code
of Federal Regulations, Part 10, and which are published in
pamphlet form as Treasury Department Circular No. 230. The
regulations prescribe the duties and restrictions relating to
such practice and prescribe the disciplinary sanctions for vio-
lating the regulations.
Finding Lists begin on page ii.
Bulletin No. 2017–27
July 3, 2017

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.
July 3, 2017Bulletin No. 2017–27

Actions Relating to Court
Decisions
It is the policy of the Internal Revenue
Service to announce at an early date
whether it will follow the holdings in cer-
tain cases. An Action on Decision is the
document making such an announcement.
An Action on Decision will be issued at
the discretion of the Service only on un-
appealed issues decided adverse to the
government. Generally, an Action on De-
cision is issued where its guidance would
be helpful to Service personnel working
with the same or similar issues. Unlike a
Treasury Regulation or a Revenue Ruling,
an Action on Decision is not an affirma-
tive statement of Service position. It is not
intended to serve as public guidance and
may not be cited as precedent.
Actions on Decisions shall be relied
upon within the Service only as conclu-
sions applying the law to the facts in the
particular case at the time the Action on
Decision was issued. Caution should be
exercised in extending the recommenda-
tion of the Action on Decision to similar
cases where the facts are different. More-
over, the recommendation in the Action
on Decision may be superseded by new
legislation, regulations, rulings, cases, or
Actions on Decisions. Prior to 1991, the
Service published acquiescence or nonac-
quiescence only in certain regular Tax
Court opinions. The Service has expanded
its acquiescence program to include other
civil tax cases where guidance is deter-
mined to be helpful. Accordingly, the Ser-
vice now may acquiesce or nonacquiesce
in the holdings of memorandum Tax
Court opinions, as well as those of the
United States District Courts, Claims
Court, and Circuit Courts of Appeal. Re-
gardless of the court deciding the case, the
recommendation of any Action on Deci-
sion will be published in theInternal
Revenue Bulletin.
The recommendation in every Action
on Decision will be summarized as ac-
quiescence, acquiescence in result only,
or nonacquiescence. Both “acquiescence”
and “acquiescence in result only” mean
that the Service accepts the holding of the
court in a case and that the Service will
follow it in disposing of cases with the
same controlling facts. However, “acqui-
escence” indicates neither approval nor
disapproval of the reasons assigned by the
court for its conclusions; whereas, “acqui-
escence in result only” indicates disagree-
ment or concern with some or all of those
reasons. “Nonacquiescence” signifies that,
although no further review was sought,
the Service does not agree with the hold-
ing of the court and, generally, will not
follow the decision in disposing of cases
involving other taxpayers. In reference to
an opinion of a circuit court of appeals, a
“nonacquiescence” indicates that the Ser-
vice will not follow the holding on a na-
tionwide basis. However, the Service will
recognize the precedential impact of the
opinion on cases arising within the venue
of the deciding circuit.
The Commissioner does NOT ACQUI-
ESCE in the following decision:
Yosef A. Tsehay v. Commissioner,
T.C. Memo. 2016 –200.
1
1
Nonacquiescence to the holding that a taxpayer whose filing status is married filing separately is entitled to an earned income tax credit.
Bulletin No. 2017–27July 3, 2017
1

Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
Section 1274.—
Determination of Issue
Price in the Case of
Certain Debt Instruments
Issued for Property
(Also Sections 42, 280G, 382, 467, 468, 482, 483,
642, 1288, 7520, 7872.)
Rev. Rul. 2017–14
This revenue ruling provides various
prescribed rates for federal income tax
purposes for July 2017 (the current
month). Table 1 contains the short-term,
mid-term, and long-term applicable fed-
eral rates (AFR) for the current month for
purposes of section 1274(d) of the Internal
Revenue Code. Table 2 contains the short-
term, mid-term, and long-term adjusted
applicable federal rates (adjusted AFR)
for the current month for purposes of sec-
tion 1288(b). Table 3 sets forth the ad-
justed federal long-term rate and the long-
term tax-exempt rate described in section
382(f). Table 4 contains the appropriate
percentages for determining the low-
income housing credit described in sec-
tion 42(b)(1) for buildings placed in ser-
vice during the current month. However,
under section 42(b)(2), the applicable per-
centage for non-federally subsidized new
buildings placed in service after July 30,
2008, shall not be less than 9%. Table 5
contains the federal rate for determining
the present value of an annuity, an interest
for life or for a term of years, or a remain-
der or a reversionary interest for purposes
of section 7520. Finally, Table 6 contains
the blended annual rate for 2017 for pur-
poses of section 7872.
REV. RUL. 2017–14 TABLE 1
Applicable Federal Rates (AFR) for July 2017
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
AFR1.22%1.22%1.22%1.22%
110% AFR1.34%1.34%1.34%1.34%
120% AFR1.47%1.46%1.46%1.46%
130% AFR1.60%1.59%1.59%1.58%
Mid-term
AFR1.89%1.88%1.88%1.87%
110% AFR2.08%2.07%2.06%2.06%
120% AFR2.27%2.26%2.25%2.25%
130% AFR2.45%2.44%2.43%2.43%
150% AFR2.84%2.82%2.81%2.80%
175% AFR3.32%3.29%3.28%3.27%
Long-term
AFR2.60%2.58%2.57%2.57%
110% AFR2.86%2.84%2.83%2.82%
120% AFR3.12%3.10%3.09%3.08%
130% AFR3.38%3.35%3.34%3.33%
REV. RUL. 2017–14 TABLE 2
Adjusted AFR for July 2017
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term adjusted AFR.91%.91%.91%.91%
Mid-term adjusted AFR1.40%1.40%1.40%1.40%
Long-term adjusted AFR1.93%1.92%1.92%1.91%
July 3, 2017Bulletin No. 2017–27
2

REV. RUL. 2017–14 TABLE 3
Rates Under Section 382 for July 2017
Adjusted federal long-term rate for the current month1.93%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the
adjusted federal long-term rates for the current month and the prior two months.)
2.04%
REV. RUL. 2017–14 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for July 2017
Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after
July 30, 2008, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit7.52%
Appropriate percentage for the 30% present value low-income housing credit3.22%
REV. RUL. 2017–14 TABLE 5
Rate Under Section 7520 for July 2017
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 interest
2.2%
REV. RUL. 2017–14 TABLE 6
Blended Annual Rate for 2017
Section 7872(e)(2) blended annual rate for 20171.09%
Section 42.—Low-Income
Housing Credit
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of July
2017. See Rev. Rul. 2017–14, page 2.
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term
rates are set forth for the month of July 2017. See
Rev. Rul. 2017–14, page 2.
Section 382.—Limitation on
Net Operating Loss
Carryforwards and Certain
Built-In Losses Following
Ownership Change
The adjusted applicable federal long-term rate is set
forth for the month of July 2017. See Rev. Rul. 2017–14,
page 2.
Section 467.—Certain
Payments for the Use of
Property or Services
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of July
2017. See Rev. Rul. 2017–14, page 2.
Section 468.—Special
Rules for Mining and Solid
Waste Reclamation and
Closing Costs
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of July
2017. See Rev. Rul. 2017–14, page 2.
Section 482.—Allocation of
Income and Deductions
Among Taxpayers
Federal short-term, mid-term, and long-term
rates are set forth for the month of July 2017. See
Rev. Rul. 2017–14, page 2.
Section 483.—Interest on
Certain Deferred Payments
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of July
2017. See Rev. Rul. 2017–14, page 2.
Section 642.—Special
Rules for Credits and
Deductions
Federal short-term, mid-term, and long-term
rates are set forth for the month of July 2017. See
Rev. Rul. 2017–14, page 2.
Section 1288.—Treatment
of Original Issue Discount
on Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of July 2017. See Rev. Rul. 2017–14, page 2.
Bulletin No. 2017–27July 3, 2017
3

Section 7520.—Valuation
Tables
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of July
2017. See Rev. Rul. 2017–14, page 2.
Section 7872.—Treatment
of Loans With Below-
Market Interest Rates
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of July
2017. See Rev. Rul. 2017–14, page 2.
July 3, 2017Bulletin No. 2017–27
4

Part IV. Items of General Interest
Announcement of
Disciplinary Sanctions
From the Office of
Professional Responsibility
Announcement 2017– 05
The Office of Professional Responsi-
bility (OPR) announces recent disciplin-
ary sanctions involving attorneys, certi-
fied public accountants, enrolled agents,
enrolled actuaries, enrolled retirement
plan agents, appraisers, and unenrolled/
unlicensed return preparers (individuals
who are not enrolled to practice and are
not licensed as attorneys or certified pub-
lic accountants). Licensed or enrolled
practitioners are subject to the regulations
governing practice before the Internal
Revenue Service (IRS), which are set out
in Title 31, Code of Federal Regulations,
Subtitle A, Part 10, and which are released
as Treasury Department Circular No. 230.
The regulations prescribe the duties and re-
strictions relating to such practice and pre-
scribe the disciplinary sanctions for violat-
ing the regulations. Unenrolled/unlicensed
return preparers are subject to Revenue Pro-
cedure 81–38 and superseding guidance in
Revenue Procedure 2014–42, which gov-
ern a preparer’s eligibility to represent tax-
payers before the IRS in examinations of tax
returns the preparer both prepared for the
taxpayerandsigned as the preparer. Addi-
tionally, unenrolled/unlicensed return pre-
parers who voluntarily participate in the An-
nual Filing Season Program under Revenue
Procedure 2014–42 agree to be subject to
the duties and restrictions in Circular 230,
including the restrictions on incompetent or
disreputable conduct.
The disciplinary sanctions to be im-
posed for violation of the applicable stan-
dards are:
Disbarred from practice before the
IRS—An individual who is disbarred is
not eligible to practice before the IRS as
defined at 31 C.F.R. § 10.2(a)(4) for a
minimum period of five (5) years.
Suspended from practice before the
IRS—An individual who is suspended is
not eligible to practice before the IRS as
defined at 31 C.F.R. § 10.2(a)(4) during
the term of the suspension.
Censured in practice before the
IRS—Censure is a public reprimand. Un-
like disbarment or suspension, censure
does not affect an individual’s eligibility
to practice before the IRS, but OPR may
subject the individual’s future practice
rights to conditions designed to promote
high standards of conduct.
Monetary penalty—A monetary pen-
alty may be imposed on an individual who
engages in conduct subject to sanction, or
on an employer, firm, or entity if the in-
dividual was acting on its behalf and it
knew, or reasonably should have known,
of the individual’s conduct.
Disqualification of appraiser—An
appraiser who is disqualified is barred
from presenting evidence or testimony
in any administrative proceeding before
the Department of the Treasury or the
IRS.
Ineligible for limited practice—An
unenrolled/unlicensed return preparer
who fails to comply with the require-
ments in Revenue Procedure 81–38 or to
comply with Circular 230 as required by
Revenue Procedure 2014–42 may be
determined ineligible to engage in lim-
ited practice as a representative of any
taxpayer. Under the regulations, indi-
viduals subject to Circular 230 may not
assist, or accept assistance from, indi-
viduals who are suspended or disbarred
with respect to matters constituting
practice (i.e., representation) before the
IRS, and they may not aid or abet sus-
pended or disbarred individuals to prac-
tice before the IRS.
Disciplinary sanctions are described in
these terms:
Disbarred by decision, Suspended by
decision, Censured by decision, Mone-
tary penalty imposed by decision, and
Disqualified after hearing—An adminis-
trative law judge (ALJ) issued a decision
imposing one of these sanctions after the
ALJ either (1) granted the government’s
summary judgment motion or (2) con-
ducted an evidentiary hearing upon OPR’s
complaint alleging violation of the regu-
lations. After 30 days from the issuance of
the decision, in the absence of an appeal,
the ALJ’s decision becomes the final
agency decision.
Disbarred by default decision, Sus-
pended by default decision, Censured
by default decision, Monetary penalty
imposed by default decision, and Dis-
qualified by default decision—An ALJ,
after finding that no answer to OPR’s
complaint was filed, granted OPR’s mo-
tion for a default judgment and issued a
decision imposing one of these sanctions.
Disbarment by decision on appeal,
Suspended by decision on appeal, Cen-
sured by decision on appeal, Monetary
penalty imposed by decision on appeal,
and Disqualified by decision on appeal—
The decision of the ALJ was appealed to the
agency appeal authority, acting as the dele-
gate of the Secretary of the Treasury, and
the appeal authority issued a decision im-
posing one of these sanctions.
Disbarred by consent, Suspended by
consent, Censured by consent, Mone-
tary penalty imposed by consent, and
Disqualified by consent—In lieu of a dis-
ciplinary proceeding being instituted or
continued, an individual offered a consent
to one of these sanctions and OPR ac-
cepted the offer. Typically, an offer of
consent will provide for: suspension for
an indefinite term; conditions that the in-
dividual must observe during the suspen-
sion; and the individual’s opportunity, af-
ter a stated number of months, to file with
OPR a petition for reinstatement affirming
compliance with the terms of the con-
sent and affirming current fitness and
eligibility to practice (i.e., an active pro-
fessional license or active enrollment
status, with no intervening violations of
the regulations).
Suspended indefinitely by decision in
expedited proceeding, Suspended indef-
initely by default decision in expedited
proceeding, Suspended by consent in ex-
pedited proceeding—OPR instituted an
expedited proceeding for suspension (based
on certain limited grounds, including loss of
a professional license for cause, and crimi-
nal convictions).
Determined ineligible for limited
practice—There has been a final
determination that an unenrolled/unlicensed
return preparer is not eligible for limited
representation of any taxpayerbecause the
preparer violated standards of conduct
Bulletin No. 2017–27July 3, 2017
5

or failed to comply with any of the re-
quirements to act as a representative.
A practitioner who has been disbarred
or suspended under 31 C.F.R. § 10.60, or
suspended under § 10.82, or a disqualified
appraiser may petition for reinstatement
before the IRS after the expiration of 5
years following such disbarment, suspen-
sion, or disqualification (or immediately
following the expiration of the suspension
or disqualification period if shorter than 5
years). Reinstatement will not be granted
unless the IRS is satisfied that the peti-
tioner is not likely to engage thereafter in
conduct contrary to Circular 230, and that
granting such reinstatement would not be
contrary to the public interest.
Reinstatement decisions are published
at the individual’s request, and described
in these terms:
Reinstated to practice before the
IRS—The individual’s petition for rein-
statement has been granted. The individ-
ual is an attorney, certified public ac-
countant, enrolled agent, enrolled
actuary, or an enrolled retirement plan
agent, and eligible to practice before the
IRS, or in the case of an appraiser, the
individual is no longer disqualified.
Reinstated to engage in limited prac-
tice before the IRS—The individual’s pe-
tition for reinstatement has been granted.
The individual is an unenrolled/unlicensed
return preparer and eligible to engage in
limited practice before the IRS.
OPR has authority to disclose the
grounds for disciplinary sanctions in these
situations: (1) an ALJ or the Secretary’s
delegate on appeal has issued a final de-
cision; (2) the individual has settled a dis-
ciplinary case by signing OPR’s “consent
to sanction” agreement admitting to one
or more violations of the regulations and
consenting to the disclosure of the admit-
ted violations (for example, failure to file
Federal income tax returns, lack of due
diligence, conflict of interest, etc.); (3)
OPR has issued a decision in an expedited
proceeding for indefinite suspension; or
(4) OPR has made a final determination
(including any decision on appeal) that an
unenrolled/unlicensed return preparer is
ineligible to represent any taxpayer before
the IRS.
Announcements of disciplinary sanc-
tions appear in the Internal Revenue Bul-
letin at the earliest practicable date. The
sanctions announced below are alphabet-
ized first by state and second by the last
names of the sanctioned individuals.
City & StateName
Professional
DesignationDisciplinary SanctionEffective Date(s)
Arizona
ScottsdaleKlein, Eric M.CPASuspended by default decision
in expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
January 25, 2017
California
Mill ValleyMeyer, Christine N.CPASuspended by default decision
in expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
January 26, 2017
San DiegoMuscio, Richard J.CPAReinstated to practice
before the IRS, effective
February 23, 2017
Klein, Eric M., see
Arizona
Colorado
BrightonConradt, Thomas C.AttorneyNone. Eligible to practice
before the IRS. (Erroneously
listed in I.R.B. 2015–13 as
indefinitely suspended by
default decision in expedited
proceeding under 31 C.F.R.
§ 10.82(b), effective
October 27, 2014.)
Correction
retroactive to
October 27, 2014
CentennialKrech, Robert G.Unenrolled
Tax Return
Preparer
Reinstated to engage in
limited practice before
the IRS, effective
February 14, 2017
July 3, 2017Bulletin No. 2017–27
6

City & StateName
Professional
DesignationDisciplinary SanctionEffective Date(s)
Connecticut
SheltonRuchandani, NanditaAttorneySuspended by default decision
in expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
March 13, 2017
District of
Columbia (DC)
Udo, Enyinnaya, see
Maryland
Georgia
MiltonHays, Jr., Cecil D.CPASuspended by decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
February 2, 2017
GainesvilleStrickland, William M. CPACensured by consent for admitted
violations of §§ 10.34(b)(1)
(2011), 10.34(b)(2) (2011), and
10.51(a)(6) (2011)
May 19, 2016
Maryland
Glenn DaleUdo, EnyinnayaCPASuspended by decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
March 22, 2017
Conradt, Thomas C., see
Colorado
Massachusetts
Philip, George, see
Rhode Island
Michigan
PortageBrown, Andy J.CPASuspended by default decision
in expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
March 13, 2017
Minnesota
Theiler, Roland J., see
Wisconsin
New Hampshire
SalemJordan, Stephen B.Enrolled
Agent
Censured by consent for
admitted violations of
§§ 10.51(a) generally, and
10.51(a)(18)
March 20, 2016
Bulletin No. 2017–27July 3, 2017
7

City & StateName
Professional
DesignationDisciplinary SanctionEffective Date(s)
New Mexico
AlbuquerqueVaughn, James A.CPASuspended by consent for
admitted violation of
§ 10.51(a)(2)
Indefinite from
January 10, 2017
New York
Ruchandani, Nandita, see
Connecticut
Oregon
BeavertonAlyateem, Jiryis N.CPASuspended by decision in
expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
February 16, 2017
DetroitHagerman, Kurt L.CPASuspended by default decision
in expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
February 9, 2017
Pennsylvania
PhiladelphiaRuocchio, Raymond C. Unenrolled
Tax Return
Preparer
Reinstated to engage in
limited practice before
the IRS, effective
March 20, 2017
Wind GapSabatine, III, Nicholas R. AttorneyCensured by consent for
admitted violation of
§ 10.51(a)(1)
March 17, 2016
Rhode Island
ProvidencePhilip, GeorgeAttorneySuspended by default decision
in expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
March 13, 2017
Tennessee
MorristownOsborne, Edwin P.CPAReinstated to practice
before the IRS, effective
March 29, 2017
Wisconsin
WebsterTheiler, Roland J.AttorneySuspended by default decision
in expedited proceeding under
31 C.F.R. § 10.82(b)
Indefinite from
February 14, 2017
July 3, 2017Bulletin No. 2017–27
8

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
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
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,modifiedand
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. 2017–27July 3, 2017
i

Numerical Finding List
1
Bulletin 2017–27
Action on Decision:
2017-5, 2017-27 I.R.B.1
Announcements:
2017-05, 2017-27 I.R.B.5
Revenue Rulings:
2017-14, 2017-27 I.R.B.2
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2017–01 through 2017–26 is in Internal Revenue Bulletin
2017–26, dated June 27, 2017.
July 3, 2017Bulletin No. 2017–27
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2017–27
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2017–01 through 2017–26 is in Internal Revenue Bulletin
2017–26, dated June 27, 2017.
Bulletin No. 2017–27July 3, 2017
iii

INTERNAL REVENUE BULLETIN
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