These synopses are intended only as aids to the reader in

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2021–8

February 22, 2021

These synopses are intended only as aids to the reader in

identifying the subject matter covered. They may not be

relied upon as authoritative interpretations.

ADMINISTRATIVE

Announcement 2021-2, page 892.

This announcement notifies lenders who have filed or furnished Forms 1099-MISC, Miscellaneous Information, reporting certain payments on loans subsidized by the Administrator of the U.S. Small Business Administration as income of

the borrower, that the lenders must file and furnish corrected

Forms 1099-MISC that exclude these subsidized loan payments. This accords with section 278(e)(1) of the COVID-related Tax Relief Act, which provides that these payments

are not includible in the gross income of the borrowers; and

Notice 2021-6, waiving Form 1099-MISC reporting requirements for these payments.

Announcement 2021-3, page 892.

The Office of Professional Responsibility (OPR) announces recent disciplinary sanctions involving attorneys, certified public accountants, enrolled agents, enrolled actuaries, enrolled

retirement plan agents, and appraisers. These individuals are

subject to the regulations governing practice before the Inter-

Finding Lists begin on page ii.

nal Revenue Service (IRS), which are set out in Title 31, Code

of Federal Regulations, Part 10, and which are published in

pamphlet form as Treasury Department Circular No. 230.

The regulations prescribe the duties and restrictions relating

to such practice and prescribe the disciplinary sanctions for

violating the regulations.

Rev. Proc. 2021-15, page 891.

This revenue procedure provides a safe harbor for eligible educators, within the meaning of § 62(d)(1) of the

Internal Revenue Code, to treat unreimbursed expenses paid or incurred after March 12, 2020, for personal

protective equipment, disinfectant, and other supplies

used for the prevention of the spread of COVID–19

in the classroom, as expenses that are described in

§ 62(a)(2)(D)(ii) and allowable as a deduction under §

62(a)(2)(D) pursuant to section 275 of the COVID-related Tax Relief Act of 2020, which was enacted as part

of the Consolidated Appropriations Act, 2021, Pub. L.

No. 116-260, 134 Stat. 1182, 1978 (2020).

The IRS Mission

Provide America’s taxpayers top-quality service by helping

them understand and meet their tax responsibilities and enforce 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

Conventions, legislation, court decisions, and other items of

general interest. It is published weekly.

It is the policy of the Service to publish in the Bulletin all 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 otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of

internal practices and procedures that affect the rights and

duties of taxpayers are published.

Revenue rulings represent the conclusions of the Service

on the application of the law to the pivotal facts stated in

the revenue ruling. In those based on positions taken in 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.—1986 Code.

This part includes rulings and decisions based on provisions

of the Internal Revenue Code of 1986.

Part II.—Treaties and Tax Legislation.

This part is divided into two subparts as follows: Subpart A,

Tax Conventions and Other Related Items, and Subpart B,

Legislation and Related Committee Reports.

Part III.—Administrative, Procedural, and Miscellaneous.

To the extent practicable, pertinent cross references to these

subjects are contained in the other Parts and Subparts. Also

included in this part are Bank Secrecy Act Administrative

Rulings. Bank Secrecy Act Administrative Rulings are issued

by the Department of the Treasury’s Office of the Assistant

Secretary (Enforcement).

Part IV.—Items of General Interest.

This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.

The last Bulletin for each month includes a cumulative index

for the matters published during the preceding months. These

monthly indexes are cumulated on a semiannual basis, and are

published in the last Bulletin of each semiannual period.

The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.

February 22, 2021 

Bulletin No. 2021–8

Part I

26 CFR 601.105: Examination of returns and

claims for refund, credit, or abatement; determination of correct tax liability. (Also: Part I, §§ 62,

162)

Rev. Proc. 2021-15

SECTION 1. PURPOSE

This revenue procedure provides a safe

harbor for eligible educators, within the

meaning of § 62(d)(1) of the Internal Revenue Code (Code), to treat unreimbursed

expenses paid or incurred after March

12, 2020, for personal protective equipment, disinfectant, and other supplies

(COVID-19 Protective Items) used for the

prevention of the spread of COVID–19

in the classroom, as expenses that are described in § 62(a)(2)(D)(ii) and allowable

as a deduction under § 62(a)(2)(D) pursuant to section 275 of the COVID-related

Tax Relief Act of 2020 (COVID Tax Relief Act), which was enacted as part of the

Consolidated Appropriations Act, 2021,

Pub. L. No. 116-260, 134 Stat. 1182, 1978

(2020).

SECTION 2. BACKGROUND

.01 Section 62 of the Code sets forth

the deductions an individual may deduct

from gross income in arriving at adjusted

gross income. Section 62(a)(2)(D) provides, in part, that deductions allowed

under § 162 not in excess of $250 ($500

if married filing jointly and both spouses

are eligible educators, but not more than

$250 each) that consist of unreimbursed

expenses described in § 62(a)(2)(D)(ii)

that are paid or incurred by an eligible

educator may be deducted in arriving at

gross income. The unreimbursed expens-

Bulletin No. 2021–8

es described in § 62(a)(2)(D)(ii) are those

paid or incurred by an eligible educator

in connection with books, supplies (other

than nonathletic supplies for courses of instruction in health or physical education),

computer equipment (including related

software and services), other equipment,

and supplementary materials used by the

eligible educator in the classroom.

.02 Section 62(d)(1)(A) defines an “eligible educator” as any individual who is

a kindergarten through grade 12 teacher,

instructor, counselor, principal, or aide

in a school for at least 900 hours during

a school year. Section 62(d)(1)(B) defines

a “school” as any school which provides

elementary or secondary education, as determined under State law.

.03 For an unreimbursed expense to be

deducted from gross income in arriving at

adjusted gross income under § 62(a)(2)

(D), the expense must be allowed as a deduction under § 162(a) of the Code as an

ordinary and necessary expense paid or incurred during the taxable year in carrying

on the eligible educator’s trade or business

of performing services as an employee.

.04 Section 275 of the COVID Tax Relief Act requires the Secretary of the Treasury or the Secretary’s delegate to clarify

that COVID-19 Protective Items used for

the prevention of the spread of COVID-19

are treated as described in § 62(a)(2)(D)

(ii) if paid or incurred by an eligible educator after March 12, 2020.

SECTION 3. SAFE HARBOR FOR

COVID-19 PROTECTIVE ITEMS

UNDER § 62(a)(2)(D)

In accordance with section 275 of the

COVID Tax Relief Act, an eligible educator may treat unreimbursed expenses

891

paid or incurred after March 12, 2020, for

COVID-19 Protective Items that are, or

will be, used by that eligible educator for

the prevention of the spread of COVID-19

in the classroom, as expenses that are described in § 62(a)(2)(D)(ii) and allowable

as a deduction under § 62(a)(2)(D), subject to the aggregate dollar limitation provided in such provision. For purposes of

this revenue procedure, COVID-19 Protective Items include, but are not limited

to: face masks; disinfectant for use against

COVID-19; hand soap; hand sanitizer;

disposable gloves; tape, paint or chalk

used to guide social distancing; physical

barriers (for example, clear plexiglass);

air purifiers; and other items recommended by the Centers for Disease Control and

Prevention (CDC) to be used for the prevention of the spread of COVID-19.

SECTION 4. APPLICABILITY

This revenue procedure applies to unreimbursed expenses paid or incurred by an

eligible educator after March 12, 2020, for

COVID-19 Protective Items used for the

prevention of the spread of COVID–19 in

the classroom.

SECTION 5. CONTACT

INFORMATION

The principal authors of this revenue

procedure are Sharon Horn and Edward

Schwartz of the Office of the Associate

Chief Counsel (Income Tax and Accounting). For further information regarding

this revenue procedure contact Sharon

Horn at (202) 317-7003 (for questions relating to § 162), or Edward Schwartz at

(202) 317-7006 (for questions relating to

§ 62(a)(2)) (not a toll-free number).

February 22, 2021

Part IV

Correction of Forms 1099MISC for Certain CARES

Act Subsidized Loan

Payments

Announcement 2021-2

This announcement notifies lenders

who have filed with the Internal Revenue

Service (IRS), or furnished to a borrower,

a Form 1099-MISC, Miscellaneous Information, reporting certain payments on

loans subsidized by the Administrator of

the U.S. Small Business Administration

(Administrator) as income of the borrower that the lenders must file and furnish

corrected Forms 1099-MISC that exclude

these subsidized loan payments.

Section 1112(c) of the Coronavirus

Aid, Relief, and Economic Security Act,

Pub. L. No. 116-136, 134 Stat. 281, 309310 (March 27, 2020) (CARES Act), 15

U.S.C. 9011(c), authorizes the Administrator to subsidize certain payments of

principal, interest, and any associated fees

owed by a borrower on certain loans. Section 278(c)(1) of the COVID-related Tax

Relief Act of 2020 (COVID Relief Act),

enacted as Subtitle B of Title II of Division N of the Consolidated Appropriations

Act, 2021, Pub. L. 116-260, 134 Stat.1182

(December 27, 2020), retroactively provides that such a payment is not included in the gross income of the person on

whose behalf the payment is made. This

provision is effective for taxable years

ending after March 27, 2020, the date of

the enactment of the CARES Act. Section

278(e)(1) of the COVID Relief Act. Section 278(c)(2) provides that no deduction

shall be denied by reason of the exclusion

of the loan payments from gross income.

Section 279 of the COVID Relief Act

authorizes the Secretary of the Treasury

or the Secretary’s delegate to provide an

exception with respect to any amount

excluded from gross income by reason

of section 278 of the COVID Relief Act

from any requirement to file an information return otherwise required under

chapter 61 of the Internal Revenue Code

(Code), including information returns and

February 22, 2021

payee statements required to be filed or

furnished under section 6041 of the Code.

On January 19, 2021, the Department

of the Treasury and the IRS issued, pursuant to section 279 of the COVID Relief

Act, Notice 2021-6, 2021-06 I.R.B. 822,

to waive the requirement for lenders to file

with the IRS, or furnish to a borrower, a

Form 1099-MISC reporting the payment

of principal, interest, and any associated

fees subsidized by the Administrator under section 1112(c) of the CARES Act.

The filing of information returns that include these loan payments could result in

IRS correspondence to borrowers regarding underreported income, and the furnishing of payee statements that include

these loan payments to borrowers could

cause confusion.

If a lender has already furnished to

borrowers Forms 1099-MISC that report

these loan payments, whether before, on,

or after December 27, 2020, the lender

must furnish to the borrowers corrected Forms 1099-MISC that exclude these

loan payments. In addition, if a lender has

already filed with the IRS Forms 1099MISC that report these loan payments,

whether before, on, or after December 27,

2020, the lender must file with the IRS

corrected Forms 1099-MISC that exclude

these loan payments. Directions for how

to file corrected Forms 1099-MISC are included in the 2020 Instructions for Forms

1099-MISC and 1099-NEC and the 2020

General Instructions for Certain Information Returns. If a lender described in this

announcement furnishes corrected payee

statements within 30 days of the furnishing deadline, it will have reasonable cause

for any failure-to-furnish penalty imposed

under section 6722. A lender described in

this announcement must file corrected information returns by the filing deadline in

order to avoid section 6721 failure-to-file

penalties.

The principal author of this announcement is Isaac Brooks Fishman of the Office of the Associate Chief Counsel (Procedure & Administration). For further

information regarding this announcement,

contact Isaac Brooks Fishman at (202)

317-5436 (not a toll-free number).

892

Announcement of

Disciplinary Sanctions

From the Office of

Professional Responsibility

Announcement 2021-3

The Office of Professional Responsibility (OPR) announces recent disciplinary sanctions involving attorneys, certified 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 public accountants). Licensed or enrolled

practitioners are subject to the regulations

governing practice before the Internal

Revenue Service (IRS), which are set out

in Title 31, Code of Federal Regulations,

Subtitle A, Part 10, and which are released

as Treasury Department Circular No.

230. The regulations prescribe the duties

and restrictions relating to such practice

and prescribe the disciplinary sanctions

for violating the regulations. Unenrolled/

unlicensed return preparers are subject to

Revenue Procedure 81-38 and superseding guidance in Revenue Procedure 201442, which govern a preparer’s eligibility

to represent taxpayers before the IRS in

examinations of tax returns the preparer

both prepared for the taxpayer and signed

as the preparer. Additionally, unenrolled/

unlicensed return preparers who voluntarily participate in the Annual Filing Season Program under Revenue Procedure

2014-42 agree to be subject to the duties

and restrictions in Circular 230, including

the restrictions on incompetent or disreputable conduct.

The disciplinary sanctions to be imposed for violation of the applicable standards 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

Bulletin No. 2021–8

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. Unlike 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 penalty may be imposed on an individual who

engages in conduct subject to sanction,

or on an employer, firm, or entity if the

individual was acting on its behalf and it

knew, or reasonably should have known,

of the individual’s conduct.

Disqualification of appraiser—An

appraiser who is disqualified is barred

from presenting evidence or testimony in

any administrative proceeding before the

Department of the Treasury or the IRS.

Ineligible for limited practice—An

unenrolled/unlicensed return preparer

who fails to comply with the requirements

in Revenue Procedure 81-38 or to comply

with Circular 230 as required by Revenue

Procedure 2014-42 may be determined ineligible to engage in limited practice as a

representative of any taxpayer.

Under the regulations, individuals subject to Circular 230 may not assist, or accept assistance from, individuals who are

suspended or disbarred with respect to

matters constituting practice (i.e., representation) before the IRS, and they may

not aid or abet suspended or disbarred individuals to practice before the IRS.

Disciplinary sanctions are described in

these terms:

Disbarred by decision, Suspended by

decision, Censured by decision, Monetary penalty imposed by decision, and

Disqualified after hearing—An administrative 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) conducted an evidentiary hearing upon OPR’s

complaint alleging violation of the regulations. 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, Suspended by default decision, Censured

Bulletin No. 2021–8

by default decision, Monetary penalty

imposed by default decision, and Disqualified by default decision—An ALJ,

after finding that no answer to OPR’s

complaint was filed, granted OPR’s motion for a default judgment and issued

a decision imposing one of these sanctions.

Disbarment by decision on appeal,

Suspended by decision on appeal, Censured 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 delegate of the Secretary

of the Treasury, and the appeal authority

issued a decision imposing one of these

sanctions.

Disbarred by consent, Suspended by

consent, Censured by consent, Monetary penalty imposed by consent, and

Disqualified by consent—In lieu of a

disciplinary proceeding being instituted or

continued, an individual offered a consent

to one of these sanctions and OPR accepted the offer. Typically, an offer of consent

will provide for: suspension for an indefinite term; conditions that the individual

must observe during the suspension; and

the individual’s opportunity, after a stated number of months, to file with OPR a

petition for reinstatement affirming compliance with the terms of the consent and

affirming current fitness and eligibility

to practice (i.e., an active professional license or active enrollment status, with no

intervening violations of the regulations).

Suspended indefinitely by decision in

expedited proceeding, Suspended indefinitely by default decision in expedited

proceeding, Suspended by consent in

expedited proceeding—OPR instituted

an expedited proceeding for suspension

(based on certain limited grounds, including loss of a professional license for

cause, and criminal 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 taxpayer because the

preparer violated standards of conduct or

failed to comply with any of the requirements to act as a representative.

A practitioner who has been disbarred

or suspended under 31 C.F.R. § 10.60, or

893

suspended under § 10.82, or a disqualified appraiser may petition for reinstatement before the IRS after the expiration

of 5 years following such disbarment,

suspension, 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 petitioner is not likely to engage

thereafter in conduct contrary to Circular

230, and that granting such reinstatement

would not be contrary to the public 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 reinstatement has been granted. The

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

practice before the IRS---The individual’s petition for reinstatement has been

granted. The individual is an unenrolled/

unlicensed return preparer and eligible to

engage in limited practice before the IRS,

subject to requirements the IRS has prescribed for limited practice by tax return

preparers.

OPR has authority to disclose the

grounds for disciplinary sanctions in these

situations: (1) an ALJ or the Secretary’s

delegate on appeal has issued a final decision; (2) the individual has settled a disciplinary 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 admitted 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 sanctions appear in the Internal Revenue Bulletin at the earliest practicable date. The

sanctions announced below are alphabetized first by state and second by the last

names of the sanctioned individuals.

February 22, 2021

City & State

Name

Professional

Designation

Disciplinary Sanction

Effective Date(s)

Alabama

Huntsville

Cutter, Harvey F.

CPA

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

October 21, 2020

Bersch, Lance M.

CPA

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

November 24, 2020

California

Chico

Broiles, Gregory A.

CPA

Indefinite from

November 10, 2020

Irvine

Azavedo, Anthony J.

CPA

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Modesto

Waggle, Stephen L.

Unenrolled Tax

Return Preparer

Moraga

Rosso, Randolph J.

CPA

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Florida

Boca Raton

Williams, Jonathan C. CPA

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

November 10, 2020

Michigan

Royal Oak

Abraham, Phillip J.

CPA

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

December 2, 2020

North Carolina

Cornelius

Hanzel, John F.

Attorney

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

October 14, 2020

New York

New York

Miu, Christopher K.

CPA

Suspended by decision in

expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

December 10, 2020

Pennsylvania

Mountain Top

Kamor, Adam

CPA

Indefinite from

October 14, 2020

Windber

Thomas, George

CPA

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Suspended by decision in

expedited proceeding under

31 C.F.R. § 10.82(b)

Arizona

Lake Havasu

City

February 22, 2021

894

Indefinite from

December 2, 2020

Reinstated to practice before

the IRS, effective

November 24, 2020

Indefinite from

November 24, 2020

Indefinite from

November 24, 2020

Bulletin No. 2021–8

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:

Amplified describes a situation where

no change is being made in a prior published 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 applied to A, and the new ruling holds that

the same principle also applies to B, the

earlier ruling is amplified. (Compare with

modified, below).

Clarified is used in those instances

where the language in a prior ruling is being made clear because the language has

caused, or may cause, some confusion. It

is not used where a position in a prior ruling is being changed.

Distinguished describes a situation

where a ruling mentions a previously published ruling and points out an essential

difference between them.

Modified is used where the substance

of a previously published position is being

changed. Thus, if a prior ruling held that a

principle applied to A but not to B, and the

new ruling holds that it applies to both A

and B, the prior ruling is modified because

it corrects a published position. (Compare

with amplified and clarified, above).

Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions.

This term is most commonly used in a ruling

that lists previously published rulings that

are obsoleted because of changes in laws or

regulations. A ruling may also be obsoleted

because the substance has been included in

regulations subsequently adopted.

Revoked describes situations where the

position in the previously published ruling

is not correct and the correct position is

being stated in a new ruling.

Superseded describes a situation where

the new ruling does nothing more than

restate the substance and situation of a

previously published ruling (or rulings).

Thus, the term is used to republish under

the 1986 Code and regulations the same

position published under the 1939 Code

and regulations. The term is also used

when it is desired to republish in a single

ruling a series of situations, names, etc.,

that were previously published over a

period of time in separate rulings. If the

new ruling does more than restate the substance of a prior ruling, a combination of

terms is used. For example, modified and

superseded describes a situation where the

substance of a previously published ruling

is being changed in part and is continued

without change in part and it is desired to

restate the valid portion of the previously published ruling in a new ruling that is

self contained. In this case, the previously

published ruling is first modified and then,

as modified, is superseded.

Supplemented is used in situations in

which a list, such as a list of the names of

countries, is published in a ruling and that

list is expanded by adding further names

in subsequent rulings. After the original

ruling has been supplemented several

times, a new ruling may be published that

includes the list in the original ruling and

the additions, and supersedes all prior rulings in the series.

Suspended is used in rare situations to

show that the previous published rulings

will not be applied pending some future

action such as the issuance of new or

amended regulations, the outcome of cases in litigation, or the outcome of a Service study.

Abbreviations

The following abbreviations in current use

and formerly used will appear in material

published in the Bulletin.

A—Individual.

Acq.—Acquiescence.

B—Individual.

BE—Beneficiary.

BK—Bank.

B.T.A.—Board of Tax Appeals.

C—Individual.

C.B.—Cumulative Bulletin.

CFR—Code of Federal Regulations.

CI—City.

COOP—Cooperative.

Ct.D.—Court Decision.

CY—County.

D—Decedent.

DC—Dummy Corporation.

DE—Donee.

Del. Order—Delegation Order.

DISC—Domestic International Sales Corporation.

DR—Donor.

E—Estate.

EE—Employee.

E.O.—Executive Order.

ER—Employer.

Bulletin No. 2021–8

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.

i

PTE—Prohibited Transaction Exemption.

Pub. L.—Public Law.

REIT—Real Estate Investment Trust.

Rev. Proc.—Revenue Procedure.

Rev. Rul.—Revenue Ruling.

S—Subsidiary.

S.P.R.—Statement of Procedural Rules.

Stat.—Statutes at Large.

T—Target Corporation.

T.C.—Tax Court.

T.D.—Treasury Decision.

TFE—Transferee.

TFR—Transferor.

T.I.R.—Technical Information Release.

TP—Taxpayer.

TR—Trust.

TT—Trustee.

U.S.C.—United States Code.

X—Corporation.

Y—Corporation.

Z—Corporation.

February 22, 2021

Numerical Finding List1

Bulletin 2021–8

Announcements:

2021-01, 2021-04 I.R.B. 506

2021-02, 2021-08 I.R.B. 892

2021-03, 2021-08 I.R.B. 892

Notices:

2021-01, 2021-02 I.R.B. 315

2021-03, 2021-02 I.R.B. 316

2021-04, 2021-02 I.R.B. 319

2021-02, 2021-03 I.R.B. 478

2021-05, 2021-03 I.R.B. 479

2021-07, 2021-03 I.R.B. 482

2021-09, 2021-05 I.R.B. 678

2021-06, 2021-06 I.R.B. 822

2021-08, 2021-06 I.R.B. 823

2021-11, 2021-06 I.R.B. 827

2021-12, 2021-06 I.R.B. 828

2021-13, 2021-06 I.R.B. 832

2021-10, 2021-07 I.R.B. 888

Treasury Decisions:—Continued

9941, 2021-03 I.R.B. 396

9942, 2021-03 I.R.B. 450

9937, 2021-04 I.R.B. 495

9936, 2021-05 I.R.B. 508

9943, 2021-05 I.R.B. 577

9945, 2021-05 I.R.B. 627

9946, 2021-06 I.R.B. 726

9947, 2021-06 I.R.B. 748

9948, 2021-06 I.R.B. 801

9938, 2021-07 I.R.B. 838

Proposed Regulations:

REG-130081-19, 2021-02 I.R.B. 321

REG-114615-16, 2021-03 I.R.B. 489

REG-111950-20, 2021-05 I.R.B. 683

REG-115057-20, 2021-05 I.R.B. 714

Revenue Procedures:

2021-01, 2020-01 I.R.B. 1

2021-02, 2020-01 I.R.B. 116

2021-03, 2020-01 I.R.B. 140

2021-04, 2020-01 I.R.B. 157

2021-05, 2020-01 I.R.B. 250

2021-07, 2020-01 I.R.B. 290

2021-09, 2020-03 I.R.B. 485

2021-08, 2020-04 I.R.B. 502

2021-10, 2020-04 I.R.B. 503

2021-12, 2020-05 I.R.B. 681

2021-11, 2020-06 I.R.B. 833

2021-15, 2020-08 I.R.B. 891

Revenue Rulings:

2021-01, 2021-02 I.R.B. 294

2021-02, 2021-04 I.R.B. 495

2021-03, 2021-05 I.R.B. 674

2021-04, 2021-06 I.R.B. 724

Treasury Decisions:

9925, 2021-02 I.R.B. 296

9940, 2021-02 I.R.B. 311

9932, 2021-03 I.R.B. 345

9939, 2021-03 I.R.B. 376

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin

2020–52, dated December 27, 2020.

1

February 22, 2021

ii

Bulletin No. 2021–8

Finding List of Current Actions on

Previously Published Items1

Bulletin 2021–8

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin

2020–52, dated December 27, 2020.

1

Bulletin No. 2021–8

iii

February 22, 2021

Internal Revenue Service

Washington, DC 20224

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