Bulletin No. 2022–22

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2022–22

May 31, 2022

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 2022-9, page 1153.

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 Internal 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.

EMPLOYEE PLANS

Notice 2022-27, page 1151.

This notice is a 6-month extension of the relief provided

in Notice 2020-42, as extended by Notice 2021-3 and

Finding Lists begin on page ii.

Notice 2021-40. For the period from July 1, 2022,

through December 31, 2022, this notice extends two

types of relief from the physical presence requirement in

§ 1.401(a)-21(d)(6)(i) for participant elections required

to be witnessed by a plan representative or a notary

public: (1) temporary relief from the physical presence

requirement for any participant election witnessed by

a notary public in a state that permits remote notarization (either by law or through an executive order), and

(2) temporary relief from the physical presence requirement for any participant election witnessed by a plan

representative.

EXEMPT ORGANIZATIONS

Announcement 2022-10, page 1156.

Revocation of IRC 501(c)(3) Organizations for failure

to meet the code section requirements. Contributions

made to the organizations by individual donors are no

longer deductible under IRC 170(b)(1)(A).

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.

May 31, 2022 

Bulletin No. 2022–22

Part III

Extension of Temporary

Relief from the Physical

Presence Requirement

Through December 31,

2022

Notice 2022‑27

I. PURPOSE

This notice provides a 6‑month

extension, through December 31, 2022,

of the temporary relief provided in

Notice 2021‑40, 2021‑28 IRB 15, from the

requirement in § 1.401(a)‑21(d)(6)(i) that

certain participant elections be witnessed

in the physical presence of a plan repre‑

sentative or a notary public (the physical

presence requirement). This extension

of relief is provided in response to the

continuing Coronavirus Disease 2019

(COVID‑19) pandemic.

II. BACKGROUND

A. Temporary Relief from the Physical

Presence Requirement and Requests

for Comments

On March 13, 2020, the President

determined that the COVID‑19 pandemic

was of sufficient severity and magnitude

to warrant an emergency determina‑

tion beginning March 1, 2020, under the

Robert T. Stafford Disaster Relief and

Emergency Assistance Act, 42 U.S.C.

5121‑5207 (the national emergency). See

85 FR 15337.

In response to the national emergency

caused by the COVID‑19 pandemic and

related social distancing precautions,

Notice 2020‑42, 2020‑26 IRB 986, pro‑

vided temporary relief (through Decem‑

ber 31, 2020) from the physical presence

requirement for any participant election

that was witnessed by a notary public or

by a plan representative, using an elec‑

tronic system that satisfied the applicable

requirements specified in section III.A

and B, respectively, of Notice 2020‑42.

Notice 2021‑03, 2021‑2 IRB 316,

extended the temporary relief from the

Bulletin No. 2022–22

physical presence requirement through

June 30, 2021, if the requirements specified

in section III.A and B of Notice 2021‑03

were satisfied (under terms that were iden‑

tical to the requirements in section III.A

and B of Notice 2020‑42). Notice 2021‑03

noted that, during the temporary relief

period, a participant would still be able

to have a participant election witnessed

in the physical presence of a notary pub‑

lic and have that participant election be

accepted by a plan in accordance with

§ 1.401(a)‑21(d)(6)(i). Notice 2021‑03

also requested comments on whether relief

from the physical presence requirement

should be made permanent and, if made

permanent, what, if any, procedural safe‑

guards would be necessary to reduce the

risk of fraud, spousal coercion, or other

abuse in the absence of the physical pres‑

ence requirement. Notice 2021‑03 further

stated that any permanent modification of

the physical presence requirement would

be made through the regulatory process,

thus providing an additional opportunity

for stakeholders to provide comments.

Notice 2021‑40 extended the tempo‑

rary relief from the physical presence

requirement through June 30, 2022, if the

applicable requirements specified in sec‑

tion III.A and B of Notice 2021‑03 are

satisfied. Notice 2021‑40 also requested

comments on specific matters relating

to the relief from the physical presence

requirement, including comments on

whether to propose modifications to the

physical presence requirement.

B. Stakeholder Comments and Agency

Review

Following

the

publication

of

Notices 2020‑42, 2021‑03, and 2021‑40,

the Department of the Treasury (Treasury

Department) and the Internal Revenue Ser‑

vice (IRS) received comments from numer‑

ous stakeholders regarding the physical

presence requirement. Some stakeholders

requested permanent relief from the phys‑

ical presence requirement; other stakehold‑

ers stated that the existing physical pres‑

ence requirement should be retained.

The Treasury Department and the IRS

are currently reviewing the stakeholder

1151

comments to determine whether to retain

the physical presence requirement without

modification or to propose to modify the

requirement. If the Treasury Department

and the IRS decide to propose to modify

the physical presence requirement, they

will do so only through the regulatory

process, which will include the opportu‑

nity for further comment.

C. Continuing COVID‑19 Pandemic

On February 18, 2022, the President

determined that the COVID‑19 pandemic

continued to cause a significant risk to

public health and safety and extended

the national emergency beyond March 1,

2022. See 87 FR 10289. Accordingly, sec‑

tion III of this notice provides an additional

6‑month extension, through December 31,

2022, of the temporary relief from the

physical presence requirement provided

in Notice 2021‑40. However, in light of

recent easing of public health precautions

relating to the COVID‑19 pandemic, a

further extension of temporary relief from

the physical presence requirement beyond

the end of 2022 is not expected to be

necessary.

III. EXTENSION OF TEMPORARY

RELIEF FROM THE PHYSICAL

PRESENCE REQUIREMENT

This notice extends, for the 6‑month

period from July 1, 2022, through

December 31, 2022, the temporary relief

from the physical presence requirement

provided in Notice 2021‑40, including

extension of the requirements to qual‑

ify for that relief. Accordingly, for this

6‑month period, a plan may qualify for

relief from the physical presence require‑

ment for any participant election wit‑

nessed by a notary public or a plan rep‑

resentative, using an electronic system

that satisfies the applicable requirements

specified in section III.A and B, respec‑

tively, of Notice 2021‑03.

IV. EFFECT ON OTHER

DOCUMENTS

Notice 2021‑40 is modified.

May 31, 2022

V. DRAFTING INFORMATION

The principal author of this notice

May 31, 2022

is Tyler Forni of the Office of Associ‑

ate Chief Counsel (Employee Benefits,

Exempt Organizations, and Employment

1152

Taxes). For further information regard‑

ing this notice, contact Tyler Forni at

(202) 317‑4102 (not a toll‑free number).

Bulletin No. 2022–22

Part IV

Announcement of

Disciplinary Sanctions

From the Office of

Professional Responsibility

Announcement 2022-9

The Office of Professional Respon‑

sibility (OPR) announces recent disci‑

plinary sanctions involving attorneys, cer‑

tified public accountants, enrolled agents,

enrolled actuaries, enrolled retirement

plan agents, appraisers, and unenrolled/

unlicensed return preparers (individuals

who are not enrolled to practice and are

not licensed as attorneys or certified pub‑

lic accountants). Licensed or enrolled

practitioners are subject to the regulations

governing practice before the Internal

Revenue Service (IRS), which are set out

in Title 31, Code of Federal Regulations,

Subtitle A, Part 10, and which are released

as Treasury Department Circular No.

230. The regulations prescribe the duties

and restrictions relating to such practice

and prescribe the disciplinary sanctions

for violating the regulations. Unenrolled/

unlicensed return preparers are subject to

Revenue Procedure 81-38 and supersed‑

ing 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 volun‑

tarily participate in the Annual Filing Sea‑

son Program under Revenue Procedure

2014-42 agree to be subject to the duties

and restrictions in Circular 230, including

the restrictions on incompetent or disrep‑

utable 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. 2022–22

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 pen‑

alty 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, 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 regula‑

tions. After 30 days from the issuance of

the decision, in the absence of an appeal,

1153

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 com‑

plaint 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, Cen‑

sured by decision on appeal, Mone‑

tary 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, Mone‑

tary penalty imposed by consent, and

Disqualified by consent—In lieu of a

disciplinary proceeding being instituted

or continued, an individual offered a con‑

sent 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 sus‑

pension; and the individual’s opportu‑

nity, 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 indef‑

initely by default decision in expedited

proceeding, Suspended by consent in

expedited proceeding—OPR instituted

an expedited proceeding for suspension

(based on certain limited grounds, includ‑

ing loss of a professional license for cause,

and criminal convictions).

Determined ineligible for limited

practice—There has been a final deter‑

mination that an unenrolled/unlicensed

May 31, 2022

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 require‑

ments 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.

City & State

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 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 individ‑

ual’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 pre‑

scribed 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 Secre‑

tary’s delegate on appeal has issued a final

Name

Professional

Designation

decision; (2) the individual has settled a

disciplinary case by signing OPR’s “con‑

sent 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 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.

Disciplinary Sanction

Effective Date(s)

California

Studio City

Bradford, Dwayne T.,

see Maine

Krell, Steven

CPA

Stockton

Lagorio, Kevin V.

CPA

Turlock

Puffer, Robert N.

CPA

Garden Grove

Lee, Michael H.

Enrolled Agent

Colorado

Sterling

Moter, Laverne C.

CPA

Suspended by default decision in

expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

March 24, 2022

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)

Indefinite from

March 24, 2022

District of Columbia (DC)

Tantillo, Brent S., see Florida

Florida

Jacksonville

Kaleel, K. Mark

Tantillo, Brent S.

May 31, 2022

Attorney

Suspended by 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)

Suspended by default decision in

expedited proceeding under

31 C.F.R. § 10.82(b)

1154

Reinstated to practice

before the IRS, effective

March 10, 2022

Indefinite from

March 24, 2022

Indefinite from

March 24, 2022

Indefinite from

January 14, 2022

Indefinite from

January 28, 2022

Bulletin No. 2022–22

City & State

Name

Professional

Designation

Disciplinary Sanction

Effective Date(s)

Georgia

Marietta

Garner, Carl S.

CPA

Suspended by default decision in

expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

February 10, 2022

Bradford,

Dwayne T.

CPA

Suspended by decision in

expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

January 14, 2022

Missouri

Lebanon

Richardson, Douglas A.

CPA

Suspended by default decision in

expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

March 24, 2022

New York

New York

Klein, Mitchell L.

CPA

Suspended by consent for

admitted violations of

31 C.F.R. §§ 10.51(a)(2) and

10.51(a)(3)

Indefinite from

January 21, 2022

Tennessee

Harrogate

Williams, Gary R.

CPA

Suspended by default decision in

expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

January 14, 2022

Texas

Dallas

Davis, William P.

Attorney

Indefinite from

January 28, 2022

Houston

Jones, II, James G.

Attorney

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)

Virginia

Midlothian

Wildes, Richard H.

CPA

Suspended by default decision in

expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

February 10, 2022

Williams, Gary R., see

Tennessee

Louisiana

Jones, II, James G., see Texas

Maine

Falmouth

Bulletin No. 2022–22

1155

Indefinite from

January 14, 2022

May 31, 2022

Announcement 2022-10

Deletions From Cumulative

List of Organizations,

Contributions to Which are

Deductible Under Section

170 of the Code

Table of Contents

The Internal Revenue Service has

revoked its determination that the organi‑

zations listed below qualify as organiza‑

tions described in sections 501(c)(3) and

170(c)(2) of the Internal Revenue Code of

1986.

Generally, the IRS will not disallow

deductions for contributions made to a

listed organization on or before the date

of announcement in the Internal Revenue

Bulletin that an organization no longer

qualifies. However, the IRS is not pre‑

cluded from disallowing a deduction for

any contributions made after an organiza‑

tion ceases to qualify under section 170(c)

(2) if the organization has not timely filed

a suit for declaratory judgment under sec‑

tion 7428 and if the contributor (1) had

knowledge of the revocation of the ruling

or determination letter, (2) was aware that

such revocation was imminent, or (3) was

in part responsible for or was aware of the

activities or omissions of the organization

that brought about this revocation.

Effective Date of

Revocation

NAME OF ORGANIZATION

Charity Partners Network

Renewable Home Foundation, Inc.

Safe Building Compliance and Technology

Love Mia Foundation, Inc.

XC Foundation

Hope Services, Inc.

Arizona Horsemen’s Benevolent & Association

Idance Academi

New York Youth Club International, Inc.

Zhenguo Beijing Opera House

Their Last Best Place

The Development Corporation of Baton Rouge

Association League of Superfriends

MCGUFFEY YOUTH FOOTBALL

May 31, 2022

If on the other hand a suit for declar‑

atory judgment has been timely filed,

contributions from individuals and orga‑

nizations described in section 170(c)(2)

that are otherwise allowable will continue

to be deductible. Protection under section

7428(c) would begin on May 31, 2022 and

would end on the date the court first deter‑

mines the organization is not described

in section 170(c)(2) as more particularly

set for in section 7428(c)(1). For individ‑

ual contributors, the maximum deduction

protected is $1,000, with a husband and

wife treated as one contributor. This ben‑

efit is not extended to any individual, in

whole or in part, for the acts or omissions

of the organization that were the basis for

revocation.

1/1/2015

1/1/2017

1/1/2020

1/1/2017

1/1/2016

1/1/2017

1/1/2016

1/1/2017

1/1/2017

5/1/2017

1/1/2017

3/1/2017

1/1/2017

1/1/2018

1156

LOCATION

Sarasota, FL

Temecula, CA

Polk City, IA

Miami, FL

Pleasanton, CA

Castle Pines, CO

Phoenix, AZ

Jackson, MS

W. Hempstead, NY

Pennington, NJ

Livingston, MT

Nashville, TN

Harper Woods, MI

Claysville, PA

Bulletin No. 2022–22

Definition of Terms

Revenue rulings and revenue procedures

(hereinafter referred to as “rulings”) that

have an effect on previous rulings use the

following defined terms to describe the

­effect:

Amplified describes a situation where

no change is being made in a prior pub‑

lished position, but the prior position is

being extended to apply to a variation of

the fact situation set forth therein. Thus,

if an earlier ruling held that a principle

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 confu‑

sion. It is not used where a position in a

prior ruling is being changed.

Distinguished describes a situation

where a ruling mentions a previously pub‑

lished ruling and points out an essential

difference between them.

Modified is used where the substance

of a previously published position is being

changed. Thus, if a prior ruling held that a

principle applied to A but not to B, and the

new ruling holds that it applies to both A

and B, the prior ruling is modified because

it corrects a published position. (Compare

with amplified and clarified, above).

Obsoleted describes a previously pub‑

lished ruling that is not considered deter‑

minative with respect to future 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 sub‑

stance of a prior ruling, a combination of

terms is used. For example, modified and

superseded describes a situation where the

substance of a previously published ruling

is being changed in part and is continued

without change in part and it is desired to

restate the valid portion of the previously

published ruling in a new ruling that is

self contained. In this case, the previously

published ruling is first modified and then,

as modified, is superseded.

Supplemented is used in situations in

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

countries, is published in a ruling and that

list is expanded by adding further names

in subsequent rulings. After the original

ruling has been supplemented several

times, a new ruling may be published that

includes the list in the original ruling and

the additions, and supersedes all prior rul‑

ings in the series.

Suspended is used in rare situations

to show that the previous published rul‑

ings 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. 2022–22

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.

May 31, 2022

Numerical Finding List1

Bulletin 2022–22

Announcements:

2022-3, 2022-8 I.R.B. 788

2022-4, 2022-9 I.R.B. 789

2022-5, 2022-11 I.R.B. 825

2022-6, 2022-13 I.R.B. 934

2022-7, 2022-15 I.R.B. 946

2022-8, 2022-19 I.R.B. 1056

2022-9, 2022-22 I.R.B. 1153

2022-10, 2022-22 I.R.B. 1156

AOD:

2022-1, 2022-06 I.R.B. 466

2022-2, 2022-12 I.R.B. 903

Notices:

2022-1, 2022-02 I.R.B. 304

2022-2, 2022-02 I.R.B. 304

2022-3, 2022-02 I.R.B. 308

2022-4, 2022-02 I.R.B. 309

2022-5, 2022-05 I.R.B. 457

2022-6, 2022-05 I.R.B. 460

2022-7, 2022-06 I.R.B. 469

2022-8, 2022-07 I.R.B. 491

2022-9, 2022-10 I.R.B. 811

2022-10, 2022-10 I.R.B. 815

2022-12, 2022-12 I.R.B. 906

2022-11, 2022-14 I.R.B. 939

2022-13, 2022-14 I.R.B. 940

2022-14, 2022-14 I.R.B. 941

2022-15, 2022-18 I.R.B. 1043

2022-16, 2022-18 I.R.B. 1044

2022-17, 2022-18 I.R.B. 1048

2022-18, 2022-18 I.R.B. 1048

2022-19, 2022-18 I.R.B. 1050

2022-21, 2022-20 I.R.B. 1057

2022-22, 2022-20 I.R.B. 1057

2022-23, 2022-20 I.R.B. 1062

2022-20, 2022-21 I.R.B. 1095

2022-24, 2022-21 I.R.B. 1097

2022-27, 2022-22 I.R.B. 1151

Revenue Procedures:

2022-1, 2022-01 I.R.B. 1

2022-2, 2022-01 I.R.B. 120

2022-3, 2022-01 I.R.B. 144

2022-4, 2022-01 I.R.B. 161

2022-5, 2022-01 I.R.B. 256

2022-7, 2022-01 I.R.B. 297

2022-9, 2022-02 I.R.B. 310

2022-11, 2022-03 I.R.B. 449

2022-8, 2022-04 I.R.B. 451

2022-10, 2022-06 I.R.B. 473

2022-13, 2022-06 I.R.B. 477

2022-12, 2022-07 I.R.B. 494

2022-14, 2022-07 I.R.B. 502

2022-15, 2022-13 I.R.B. 908

2022-17, 2022-13 I.R.B. 930

2022-17, 2022-13 I.R.B. 933

2022-20, 2022-14 I.R.B. 945

2022-21, 2022-16 I.R.B. 1015

2022-23, 2022-18 I.R.B. 1052

2022-24, 2022-20 I.R.B. 1075

2022-22, 2022-21 I.R.B. 1098

Revenue Rulings:

2022-1, 2022-02 I.R.B. 301

2022-2, 2022-04 I.R.B. 451

2022-3, 2022-06 I.R.B. 467

2022-4, 2022-10 I.R.B. 790

2022-5, 2022-10 I.R.B. 792

2022-6, 2022-12 I.R.B. 904

2022-7, 2022-14 I.R.B. 935

2022-8, 2022-14 I.R.B. 936

2022-9, 2022-18 I.R.B. 1041

Treasury Decisions:

9959, 2022-03 I.R.B. 328

9961, 2022-03 I.R.B. 430

9960, 2022-07 I.R.B. 481

9962, 2022-11 I.R.B. 823

Proposed Regulations:

REG-118250-20, 2022-07 I.R.B. 753

REG-105954-20, 2022-11 I.R.B. 828

REG-114209-21, 2022-11 I.R.B. 898

REG-114209-21, 2022-11 I.R.B. 898

REG-121508-18, 2022-15 I.R.B. 996

REG-114339-21, 2022-17 I.R.B. 1030

REG-106384-20, 2022-20 I.R.B. 1076

REG-118913-21, 2022-20 I.R.B. 1089

REG-122770-18, 2022-21 I.R.B. 1104

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, 2021.

1

May 31, 2022

ii

Bulletin No. 2022–22

Finding List of Current Actions on

Previously Published Items1

Bulletin 2022–22

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, 2021.

1

Bulletin No. 2022–22

iii

May 31, 2022

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

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