# Bulletin No. 2023–19

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URL: https://www.frixlaw.com/law-library/documents/agency%3Airs%3A883a30f103d9da92

## Record

- **Collection:** Agency decision
- **Document type:** Agency decision

## Text

HIGHLIGHTS
OF THIS ISSUE




Bulletin No. 2023–19
May 8, 2023

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
Rev. Proc. 2023-22, page 838.

This Revenue Procedure provides issuers of qualified mortgage bonds, as defined in section 143(a) of the Internal
Revenue Code, and issuers of mortgage credit certificates,
as defined in section 25(c), with (1) nationwide average purchase prices for residences located in the United States, and
(2) average area purchase price safe harbors for residences
located in statistical areas in each state, the District of
Columbia, Puerto Rico, the Northern Mariana Islands, American Samoa, the Virgin Islands, and Guam.

EXEMPT ORGANIZATIONS
Announcement 2023-14, page 853.

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).

INCOME TAX
Notice 2023-34, page 837.
The Notice updates the background section of Notice
2014-21 to reflect that certain foreign jurisdictions
have enacted laws that characterize Bitcoin as legal
tender. The Notice states that the change to the background section does not affect the answers to the FAQs
in section 4 of Notice 2014-21.

Finding Lists begin on page ii.

Rev. Proc. 2023-21, page 837.
Revenue Procedure 2023-21 provides domestic asset/
liability percentages and domestic investment yields
needed by foreign life insurance companies and foreign
property and liability insurance companies to compute
their minimum effectively connected net investment
income under section 842(b) of the Internal Revenue
Code for taxable years beginning after December 31,
2021.
Rev. Rul. 2023-9, page 835.

Federal rates; adjusted federal rates; adjusted federal longterm rate, and the long-term tax exempt rate. For purposes
of sections 382, 1274, 1288, 7872 and other sections of
the Code, tables set forth the rates for May 2023.

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 8, 2023 

Bulletin No. 2023–19

Part I
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,
1288, 7520, 7872.)

Rev. Rul. 2023-9
This revenue ruling provides various prescribed rates for federal income

Annual
AFR
110% AFR
120% AFR
130% AFR

4.30%
4.73%
5.17%
5.61%

AFR
110% AFR
120% AFR
130% AFR
150% AFR
175% AFR

3.57%
3.93%
4.30%
4.65%
5.38%
6.30%

AFR
110% AFR
120% AFR
130% AFR

3.72%
4.10%
4.48%
4.86%

Short-term adjusted AFR
Mid-term adjusted AFR
Long-term adjusted AFR

Bulletin No. 2023–19

tax purposes for May 2023 (the current
month). Table 1 contains the short-term,
mid-term, and long-term applicable
federal 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 section 1288(b).
Table 3 sets forth the adjusted federal long-term rate and the long-term
tax-exempt rate described in section
382(f). Table 4 contains the appropri-

ate percentages for determining the
low-income housing credit described
in section 42(b)(1) for buildings placed
in service during the current month.
However, 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%. Finally, 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
remainder or a reversionary interest for
purposes of section 7520.

REV. RUL. 2023-9 TABLE 1
Applicable Federal Rates (AFR) for May 2023
Period for Compounding
Semiannual
Quarterly
Short-term
4.25%
4.23%
4.68%
4.65%
5.10%
5.07%
5.53%
5.49%
Mid-term
3.54%
3.52%
3.89%
3.87%
4.25%
4.23%
4.60%
4.57%
5.31%
5.28%
6.20%
6.15%
Long-term
3.69%
3.67%
4.06%
4.04%
4.43%
4.41%
4.80%
4.77%

Annual
3.26%
2.71%
2.82%

REV. RUL. 2023-9 TABLE 2
Adjusted AFR for May 2023
Period for Compounding
Semiannual
3.23%
2.69%
2.80%

835

Quarterly
3.22%
2.68%
2.79%

Monthly
4.21%
4.64%
5.05%
5.47%
3.51%
3.86%
4.21%
4.56%
5.25%
6.12%
3.66%
4.03%
4.39%
4.75%

Monthly
3.21%
2.68%
2.78%

May 8, 2023

REV. RUL. 2023-9 TABLE 3
Rates Under Section 382 for May 2023
Adjusted federal long-term rate for the current month
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.)

2.82%
3.04%

REV. RUL. 2023-9 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for May 2023
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 credit
7.84%
Appropriate percentage for the 30% present value low-income housing credit
3.36%
REV. RUL. 2023-9 TABLE 5
Rate Under Section 7520 for May 2023
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

Section 42.—Low-Income
Housing Credit
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
May 2023. See Rev. Rul. 2023-9, page 835.

Section 280G.—Golden
Parachute Payments
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
May 2023. See Rev. Rul. 2023-9, page 835.

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 May 2023. See Rev.
Rul. 2023-9, page 835.

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
May 2023. See Rev. Rul. 2023-9, page 835.

Section 468.—Special
Rules for Mining and Solid
Waste Reclamation and
Closing Costs
The applicable federal short-term rates are set
forth for the month of May 2023. See Rev. Rul.
2023-9, page 835.

Section 482.—Allocation
of Income and Deductions
Among Taxpayers
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
May 2023. See Rev. Rul. 2023-9, page 835.

4.40%

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
May 2023. See Rev. Rul. 2023-9, page 835.

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 May 2023. See Rev. Rul. 2023-9, page
835.

Section 7520.—Valuation
Tables
The applicable federal mid-term rates are set
forth for the month of May 2023. See Rev. Rul.
2023-9, page 835.

Section 7872.—Treatment
of Loans With BelowMarket Interest Rates
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
May 2023. See Rev. Rul. 2023-9, page 835.

May 8, 2023

836

Bulletin No. 2023–19

Part III
Notice 2023-34
Modification of Notice 2014-21

SECTION 1. PURPOSE
Notice 2014-21, 2014-16 I.R.B. 938,
provides that convertible virtual currency is treated as property for federal
tax purposes and that general tax principles applicable to property transactions
apply to transactions using convertible
virtual currency. This Notice modifies
Notice 2014-21 by revising a sentence in
the Background section of that Notice to
remove the statement that virtual currency
does not have legal tender status in any
jurisdiction and to make other changes.
This Notice also explains that the revision to the Background section of Notice
2014-21 does not affect the answers to
the frequently asked questions (FAQs) set
forth in section 4 of Notice 2014-21.
SECTION 2. BACKGROUND
Notice 2014-21 describes how existing
general tax principles apply to transactions using convertible virtual currency.1
The Notice provides the guidance in the
form of FAQs.
Notice 2014-21 provides that convertible virtual currency is treated as property
for federal tax purposes and that general tax principles applicable to property
transactions apply to transactions using
convertible virtual currency. The Background section of Notice 2014-21 defines
virtual currency as a digital representation
of value that functions as a medium of
exchange, a unit of account, and/or a store
of value. The Background section also
states that virtual currency does not have
legal tender status in any jurisdiction. Rev.
Rul. 2019-24, 2019-44 I.R.B. 1004, subsequently clarified that virtual currency
does not include a representation of the
United States dollar or a foreign currency.

The Background section of Notice
2014-21 describes convertible virtual
currency as virtual currency that has an
equivalent value in real currency, or that
acts as a substitute for real currency. The
Background section of the Notice also
identifies Bitcoin as an example of a convertible virtual currency and explains that
Bitcoin can be digitally traded between
users and can be purchased for, or
exchanged into, U.S. dollars, Euros, and
other real or virtual currencies.

This change to the Background section of Notice 2014-21 does not affect
the answers to the FAQs set forth in
section 4 of Notice 2014-21, including
Q&A-2, which concludes that convertible virtual currency is not treated as
currency that could generate foreign
currency gain or loss for U.S. federal
tax purposes.

SECTION 3. MODIFICATION OF
NOTICE 2014-21

This Notice modifies Notice 2014-21
by revising its “Background” section.

The Department of the Treasury and
the Internal Revenue Service are aware
that certain foreign jurisdictions have
enacted laws that characterize Bitcoin
as legal tender. Thus, the sentence in
the Background section of Notice 201421 stating that virtual currency does not
have legal tender status in any jurisdiction is no longer accurate as to Bitcoin.
In addition, the Background section of
Notice 2014-21 may be misinterpreted
as overstating the similarity between
convertible virtual currency and “real”
currency because the use of convertible virtual currency, including Bitcoin,
to perform “real” currency functions is
limited.2 Accordingly, Notice 2014-21 is
modified by revising the third sentence
in the first paragraph of the Background
section to read as follows:

SECTION 5. DRAFTING
INFORMATION

In certain contexts, virtual currency
may serve one or more of the functions
of “real” currency – i.e., the coin and
paper money of the United States or of
any other country that is designated as
legal tender, circulates, and is customarily used and accepted as a medium
of exchange in the country of issuance – but the use of virtual currency
to perform “real” currency functions is
limited.

SECTION 4. EFFECT ON OTHER
DOCUMENTS

The principal author of this Notice is
Raphael J. Cohen of the Office of Associate Chief Counsel (International). For
further information regarding this Notice,
contact Raphael J. Cohen at (202) 3176938 (not a toll-free number).

26 CFR 601.105: Examination of returns and claims
for refund, credit or abatement; determination of tax
liability
(Also: 842(b))

Rev. Proc. 2023-21
SECTION 1. PURPOSE
This revenue procedure provides the
domestic asset/liability percentages and
domestic investment yields needed by foreign life insurance companies and foreign
property and liability insurance companies to compute their minimum effectively
connected net investment income under
section 842(b) of the Internal Revenue
Code for taxable years beginning after
December 31, 2021. Instructions are provided for computing foreign insurance

While the Background section of Notice 2014-21 describes both virtual currency and convertible virtual currency, Section 3 of Notice 2014-21 explains that the term “virtual currency” as
used in section 4 of the Notice refers only to convertible virtual currency.
2
See U.S. Department of the Treasury, Crypto-Assets: Implications for Consumers, Investors and Businesses at 1 and 20 (September 2022), available at https://home.treasury.gov/system/
files/136/CryptoAsset_EO5.pdf. See also OECD, Taxing Virtual Currencies: An Overview of Tax Treatments and Emerging Tax Policy Issues, at 20 (Oct. 12, 2020), available at https://www.
oecd.org/tax/tax-policy/taxing-virtual-currencies-an-overview-of-tax-treatments-and-emerging-tax-policy-issues.pdf.
1

Bulletin No. 2023–19

837

May 8, 2023

companies’ liabilities for the estimated tax
and installment payments of estimated tax
for taxable years beginning after December 31, 2021. For more specific guidance
regarding the computation of the amount
of net investment income to be included
by a foreign insurance company on its
U.S. income tax return, see Notice 89-96,
1989-2 C.B. 417. For the domestic asset/
liability percentage and domestic investment yield, as well as instructions for
computing foreign insurance companies’
liabilities for estimated tax and installment payments of estimated tax for
taxable years beginning after December
31, 2020, see Rev. Proc. 2022-36, 202240 I.R.B. 274.
SECTION 2. PERCENTAGES AND
YIELDS
.01 DOMESTIC ASSET/LIABILITY
PERCENTAGES FOR 2022. The Secretary determines the domestic asset/
liability percentage separately for life
insurance companies and property and
liability insurance companies. For the first
taxable year beginning after December 31,
2021, the relevant domestic asset/liability
percentages are:
1 27.7 percent for foreign life insurance
companies, and
199.7 percent for foreign property and
liability insurance companies.
.02 DOMESTIC INVESTMENT
YIELDS FOR 2022. The Secretary is
required to prescribe separate domestic
investment yields for foreign life insurance companies and for foreign property
and liability insurance companies. For
the first taxable year beginning after
December 31, 2021, the relevant domestic
investment yields are:
3 .0 percent for foreign life insurance
companies, and
2.4 percent for foreign property and

liability insurance companies.
.03 SOURCE OF DATA FOR 2022.
The section 842(b) percentages to be used
for the 2022 taxable year are based on tax
return data from the 2020 taxable year.

May 8, 2023

SECTION 3. ESTIMATED TAXES
To compute estimated tax and the
installment payments of estimated tax
due for taxable years beginning after
December 31, 2021, a foreign insurance
company must compute its estimated
tax payments by adding to its income
other than net investment income the
greater of (i) its net investment income
as determined under section 842(b)(5)
that is actually effectively connected
with the conduct of a trade or business
within the United States for the relevant
period, or (ii) the minimum effectively
connected net investment income under
section 842(b) that would result from
using the most recently available domestic asset/liability percentage and domestic
investment yield. Thus, for installment
payments due after the publication of this
revenue procedure, the domestic asset/
liability percentages and the domestic
investment yields provided in this revenue procedure must be used to compute
the minimum effectively connected net
investment income. However, if the due
date of an installment is less than 20 days
after the date this revenue procedure is
published in the Internal Revenue Bulletin, the asset/liability percentages and
domestic investment yields provided in
Rev. Proc. 2022-36 may be used to compute the minimum effectively connected
net investment income for such installment. For further guidance in computing
estimated tax, see Notice 89-96.
SECTION 4. EFFECTIVE DATE
This revenue procedure is effective for
taxable years beginning after December
31, 2021.
SECTION 5. DRAFTING
INFORMATION
The principal author of this revenue procedure is Sheila Ramaswamy of
the Office of Associate Chief Counsel
(International). For further information
regarding this revenue procedure contact
Sheila Ramaswamy at (202) 317-6938
(not a toll free number).

838

26 CFR 601.601: Rules and Regulations
(Also Part 1, §§ 25, 143, 6a.103A-1(b)(4), 6a.103A2(f)(5)).

Rev. Proc. 2023-22
SECTION 1. PURPOSE
This revenue procedure provides
issuers of qualified mortgage bonds, as
defined in § 143(a) of the Internal Revenue Code (Code), and issuers of mortgage
credit certificates, as defined in § 25(c),
with (1) the nationwide average purchase
price for residences located in the United
States, and (2) average area purchase price
safe harbors for residences located in statistical areas in each state, the District of
Columbia, Puerto Rico, the Northern Mariana Islands, American Samoa, the Virgin
Islands, and Guam. Section 7 of this revenue procedure requests comments on the
available data and method used for calculating the average area purchase price safe
harbors.
SECTION 2. BACKGROUND
.01 Section 103(a) provides that, except
as provided in § 103(b), gross income
does not include interest on any State or
local bond. Section 103(b)(1) provides
that § 103(a) shall not apply to any private activity bond that is not a “qualified
bond” within the meaning of § 141. Section 141(e) provides, in part, that the term
“qualified bond” means any private activity bond if such bond (1) is a qualified
mortgage bond under § 143, (2) meets
the volume cap requirements under § 146,
and (3) meets the applicable requirements
under § 147.
.02 Section 143(a)(1) provides that the
term “qualified mortgage bond” means a
bond that is issued as part of a qualified
mortgage issue. Section 143(a)(2)(A)
provides that the term “qualified mortgage issue” means an issue of one or more
bonds by a State or political subdivision
thereof, but only if: (i) all proceeds of the
issue (exclusive of issuance costs and a
reasonably required reserve) are to be used
to finance owner-occupied residences; (ii)
the issue meets the requirements of subsections (c), (d), (e), (f), (g), (h), (i), and (m)

Bulletin No. 2023–19

(7) of § 143; (iii) the issue does not meet
the private business tests of paragraphs (1)
and (2) of § 141(b); and (iv) with respect
to amounts received more than 10 years
after the date of issuance, repayments of
$250,000 or more of principal on mortgage
financing provided by the issue are used
by the close of the first semiannual period
beginning after the date the prepayment (or
complete repayment) is received to redeem
bonds that are part of the issue.
Average Area Purchase Price
.03 Section 143(e)(1) provides that an
issue of bonds meets the purchase price
requirements of § 143(e) if the acquisition cost of each residence financed by
the issue does not exceed 90 percent of
the average area purchase price applicable
to such residence. Section 143(e)(5) provides that, in the case of a targeted area
residence (as defined in § 143(j)), § 143(e)
(1) shall be applied by substituting 110
percent for 90 percent.
.04 Section 143(e)(2) provides that the
term “average area purchase price” means,
with respect to any residence, the average
purchase price of single-family residences
(in the statistical area in which the residence is located) that were purchased
during the most recent 12-month period
for which sufficient statistical information
is available. Under §§ 143(e)(3) and (4),
respectively, separate determinations of
average area purchase price are to be made
for new and existing residences, and for
two-, three-, and four-family residences.
.05 Section 143(e)(2) also provides that
the determination of the average area purchase price shall be made as of the date
on which the commitment to provide the
financing is made or, if earlier, the date of
the purchase of the residence.
.06 Section 143(k)(2)(A) provides that
the term “statistical area” means (i) a metropolitan statistical area (MSA), and (ii)
any county (or the portion thereof) that
is not within an MSA. Section 143(k)
(2)(C) further provides that if sufficient
recent statistical information with respect
to a county (or portion thereof) is unavailable, the Secretary may substitute another
area for which there is sufficient recent
statistical information for such county (or
portion thereof). In the case of any portion
of a State which is not within a county, §

Bulletin No. 2023–19

143(k)(2)(D) provides that the Secretary
may designate an area that is the equivalent of a county. Section 6a.103A-1(b)(4)
(i) of the Income Tax Regulations (issued
under § 103A of the Internal Revenue
Code of 1954, the predecessor of § 143 of
the Code) provides that the term “State”
includes a possession of the United States
and the District of Columbia.
.07 Section 6a.103A-2(f)(5)(i) provides
that an issuer may rely upon the average
area purchase price safe harbors published
by the Department of the Treasury (Treasury Department) for the statistical area
in which a residence is located. Section
6a.103A-2(f)(5)(i) further provides that
an issuer may use an average area purchase price limitation different from the
published safe harbor if the issuer has
more accurate and comprehensive data for
the statistical area.
Qualified Mortgage Credit Certificate
Program
.08 Section 25(c) permits a State or
political subdivision thereof to establish
a qualified mortgage credit certificate program. In general, a qualified mortgage
credit certificate program is a program
under which the issuing authority elects
not to issue an amount of private activity
bonds that it may otherwise issue during
the calendar year under § 146, and in its
place, issues mortgage credit certificates
to taxpayers in connection with the
acquisition of their principal residences.
Section 25(a)(1) provides, in general, that
the holder of a mortgage credit certificate
may claim a federal income tax credit
equal to the product of the credit rate
specified in the certificate and the interest
paid or accrued during the tax year on the
remaining principal of the indebtedness
incurred to acquire the residence. Section
25(c)(2)(A)(iii)(III) generally provides
that residences acquired in connection
with the issuance of mortgage credit certificates must meet the purchase price
requirements of § 143(e).
Income Limitations for Qualified
Mortgage Bonds and Mortgage Credit
Certificates
.09 Section 143(f) imposes limitations
on the income of mortgagors for whom

839

financing may be provided by qualified
mortgage bonds. In addition, § 25(c)
(2)(A)(iii)(IV) provides that holders of
mortgage credit certificates must meet
the income requirement of § 143(f). Generally, under §§ 143(f)(1) and 25(c)(2)(A)
(iii)(IV), the income requirement is met
only if all owner-financing under a qualified mortgage bond and all mortgage
credit certificates issued under a qualified
mortgage credit certificate program are
provided to mortgagors whose family
income is 115 percent or less of the applicable median family income. Section
143(f)(5), however, generally provides
for an upward adjustment to the percentage limitation in high housing cost areas.
High housing cost areas are defined in §
143(f)(5)(C) as any statistical area for
which the housing cost/income ratio is
greater than 1.2.
.10 Under § 143(f)(5)(D), the housing cost/income ratio with respect to any
statistical area is determined by dividing
(a) the applicable housing price ratio for
such area by (b) the ratio that the area
median gross income for such area bears
to the median gross income for the United
States. The applicable housing price ratio
is the new housing price ratio (new housing average area purchase price divided
by the new housing average purchase
price for the United States) or the existing housing price ratio (existing housing
average area purchase price divided by the
existing housing average purchase price
for the United States), whichever results
in the housing cost/income ratio being
closer to 1.
Average Area and Nationwide Purchase
Price Limitations
.11 Average area purchase price safe
harbors for each state, the District of
Columbia, Puerto Rico, the Northern Mariana Islands, American Samoa, the Virgin
Islands, and Guam were last published in
Rev. Proc. 2022-21, 2022-16 I.R.B. 1015.
.12 The nationwide average purchase
price was last published in section 4.02 of
Rev. Proc. 2022-21. Guidance with respect
to the United States and area median gross
income figures that are used in computing
the housing cost/income ratio described in
§ 143(f)(5) was published in Rev. Proc.
2021-19, 2021-15 I.R.B. 1008.

May 8, 2023

.13 This revenue procedure uses Federal Housing Administration (FHA) loan
limits for a given statistical area to calculate the average area purchase price
safe harbor for that area. FHA sets limits
on the dollar value of loans it will insure
based on median home prices and conforming loan limits established by the
Federal Home Loan Mortgage Corporation. In particular, FHA sets an area’s
loan limit at 95 percent of the median
home sales price for the area, subject to
certain floors and caps measured against
conforming loan limits.
.14 To calculate the average area
purchase price safe harbors in this revenue procedure, the FHA loan limits are
adjusted to take into account the differences between average and median
purchase prices. Because FHA loan limits
do not differentiate between new and existing residences, this revenue procedure
contains a single average area purchase
price safe harbor for both new and existing residences in a statistical area.
.15 The average area purchase price
safe harbors listed in section 4.01 of this
revenue procedure are based on FHA loan
limits released December 1, 2022. FHA
loan limits are available for statistical areas
in each state, the District of Columbia,
Puerto Rico, the Northern Mariana Islands,
American Samoa, the Virgin Islands, and
Guam. See section 3.03 of this revenue
procedure with respect to FHA loan limits
revised after December 1, 2022.
.16 OMB Bulletin No. 03-04, dated
and effective June 6, 2003, revised the
definitions of the nation’s metropolitan
areas and recognized 49 new metropolitan statistical areas. The OMB bulletin
no longer includes primary metropolitan
statistical areas.
SECTION 3. APPLICATION
Average Area Purchase Price Safe
Harbors
.01 Average area purchase price safe
harbors for statistical areas in each state,
the District of Columbia, Puerto Rico,
the Northern Mariana Islands, American
Samoa, the Virgin Islands, and Guam are
set forth in section 4.01 of this revenue
procedure. Average area purchase price
safe harbors are provided for single-fam-

May 8, 2023

ily and two to four-family residences. For
each type of residence, section 4.01 of this
revenue procedure contains a single safe
harbor that may be used for both new and
existing residences. Issuers of qualified
mortgage bonds and issuers of mortgage
credit certificates may rely on these safe
harbors to satisfy the requirements of §§
143(e) and (f). Section 4.01 of this revenue procedure provides safe harbors for
MSAs and for certain counties and county
equivalents. If no purchase price safe harbor is available for a statistical area, the
safe harbor for “ALL OTHER AREAS”
may be used for that statistical area.
.02 If a residence is in an MSA, the safe
harbor applicable to it is the limitation of
that MSA. If an MSA falls in more than
one state, the MSA is listed in section 4.01
of this revenue procedure under each state.
.03 If the FHA revises the FHA loan
limit for any statistical area after December 1, 2022, an issuer of qualified mortgage
bonds or mortgage credit certificates may
use the revised FHA loan limit for that
statistical area to compute (as provided in
the next sentence) a revised average area
purchase price safe harbor for the statistical area provided that the issuer maintains
records evidencing the revised FHA loan
limit. The revised average area purchase
price safe harbor for that statistical area
is computed by dividing the revised FHA
loan limit by 0.883.
.04 If, pursuant to § 6a.103A-2(f)(5)
(i), an issuer uses more accurate and comprehensive data to determine the average
area purchase price for a statistical area,
the issuer must make separate average area
purchase price determinations for new and
existing residences. Moreover, when computing the average area purchase price for a
statistical area that is an MSA, as defined in
OMB Bulletin No. 03-04, the issuer must
make the computation for the entire applicable MSA. When computing the average
area purchase price for a statistical area
that is not an MSA, the issuer must make
the computation for the entire statistical
area and may not combine statistical areas.
Thus, for example, the issuer may not combine two or more counties.
.05 If an issuer receives a ruling permitting it to rely on an average area
purchase price limitation that is higher
than the applicable safe harbor in this revenue procedure, the issuer may rely on

840

that higher limitation for the purpose of
satisfying the requirements of §§ 143(e)
and (f) for bonds sold, and mortgage
credit certificates issued, not more than 30
months following the termination date of
the 12-month period used by the issuer to
compute the limitation.
Nationwide Average Purchase Price
.06 Section 4.02 of this revenue procedure sets forth a single nationwide
average purchase price for purposes of
computing the housing cost/income ratio
under § 143(f)(5).
.07 Issuers must use the nationwide
average purchase price set forth in section 4.02 of this revenue procedure when
computing the housing cost/income ratio
under § 143(f)(5) regardless of whether
they are relying on the average area purchase price safe harbors contained in this
revenue procedure or using more accurate and comprehensive data to determine
average area purchase prices for new and
existing residences for a statistical area
that are different from the published safe
harbors in this revenue procedure.
.08 If, pursuant to section 6.02 of this
revenue procedure, an issuer relies on the
average area purchase price safe harbors
contained in Rev. Proc. 2022-21, the issuer
must use the nationwide average purchase
price set forth in section 4.02 of Rev. Proc.
2022-21 in computing the housing cost/
income ratio under § 143(f)(5). Likewise,
if, pursuant to section 6.04 of this revenue
procedure, an issuer relies on the nationwide average purchase price published in
Rev. Proc. 2022-21, the issuer must use
the average area purchase price safe harbors set forth in section 4.01 of Rev. Proc.
2022-21 in computing the housing cost/
income ratio under § 143(f)(5).
SECTION 4. AVERAGE AREA
AND NATIONWIDE AVERAGE
PURCHASE PRICES
.01 Average area purchase prices for
single-family and two to four-family
residences in MSAs, and for certain counties and county equivalents are set forth
below. The safe harbor for “ALL OTHER
AREAS” (found at the end of the table
below) may be used for a statistical area
that is not listed below.

Bulletin No. 2023–19

2023 Average Area Purchase Prices for Mortgage Revenue Bonds
State

One-Unit
Limit

Two-Unit
Limit

Three-Unit
Limit

Four-Unit
Limit

ALEUTIANS WEST

AK

$617,402

$790,356

$955,382

$1,187,347

HOONAH-ANGOON C

AK

$593,957

$760,341

$919,081

$1,142,211

JUNEAU CITY AND

AK

$604,377

$773,707

$935,221

$1,162,259

KETCHIKAN GATEW

AK

$549,670

$703,653

$850,556

$1,057,093

KODIAK ISLAND B

AK

$549,670

$703,653

$850,556

$1,057,093

SITKA CITY AND

AK

$664,293

$850,386

$1,027,928

$1,277,505

SKAGWAY MUNICIP

AK

$593,957

$760,341

$919,081

$1,142,211

COCONINO

AZ

$586,141

$750,374

$907,018

$1,127,204

MARICOPA

AZ

$600,469

$768,723

$929,161

$1,154,783

PINAL

AZ

$600,469

$768,723

$929,161

$1,154,783

ALAMEDA

CA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

County Name

ALPINE

CA

$563,998

$722,001

$872,756

$1,084,616

CONTRA COSTA

CA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

EL DORADO

CA

$864,884

$1,107,212

$1,338,384

$1,663,282

INYO

CA

$575,721

$737,009

$890,878

$1,107,156

LOS ANGELES

CA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

MARIN

CA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

MENDOCINO

CA

$618,705

$792,055

$957,421

$1,189,839

MONO

CA

$785,429

$1,005,501

$1,215,436

$1,510,489

MONTEREY

CA

$1,036,819

$1,327,341

$1,604,441

$1,993,900

NAPA

CA

$1,152,745

$1,475,717

$1,783,795

$2,216,860

NEVADA

CA

$729,420

$933,805

$1,128,733

$1,402,775

ORANGE

CA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

PLACER

CA

$864,884

$1,107,212

$1,338,384

$1,663,282

RIVERSIDE

CA

$729,420

$933,805

$1,128,733

$1,402,775

SACRAMENTO

CA

$864,884

$1,107,212

$1,338,384

$1,663,282

SAN BENITO

CA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SAN BERNARDINO

CA

$729,420

$933,805

$1,128,733

$1,402,775

SAN DIEGO

CA

$1,107,156

$1,417,386

$1,713,288

$2,129,194

SAN FRANCISCO

CA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SAN JOAQUIN

CA

$743,748

$952,154

$1,150,932

$1,430,298

SAN LUIS OBISPO

CA

$1,032,911

$1,322,301

$1,598,382

$1,986,424

SAN MATEO

CA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SANTA BARBARA

CA

$911,775

$1,167,242

$1,410,930

$1,753,440

SANTA CLARA

CA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SANTA CRUZ

CA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SOLANO

CA

$776,312

$993,835

$1,201,278

$1,492,933

SONOMA

CA

$975,600

$1,248,962

$1,509,696

$1,876,162

Bulletin No. 2023–19

841

May 8, 2023

State

One-Unit
Limit

Two-Unit
Limit

Three-Unit
Limit

Four-Unit
Limit

STANISLAUS

CA

$586,141

$750,374

$907,018

$1,127,204

SUTTER

CA

$553,578

$708,693

$856,616

$1,064,569

VENTURA

CA

$1,074,592

$1,375,705

$1,662,886

$2,066,559

YOLO

CA

$864,884

$1,107,212

$1,338,384

$1,663,282

YUBA

CA

$553,578

$708,693

$856,616

$1,064,569

ADAMS

CO

$892,237

$1,142,211

$1,380,688

$1,715,893

ARAPAHOE

CO

$892,237

$1,142,211

$1,380,688

$1,715,893

BOULDER

CO

$970,389

$1,242,280

$1,501,654

$1,866,195

BROOMFIELD

CO

$892,237

$1,142,211

$1,380,688

$1,715,893

CHAFFEE

CO

$679,924

$870,434

$1,052,166

$1,307,576

CLEAR CREEK

CO

$892,237

$1,142,211

$1,380,688

$1,715,893

DENVER

CO

$892,237

$1,142,211

$1,380,688

$1,715,893

DOUGLAS

CO

$892,237

$1,142,211

$1,380,688

$1,715,893

EAGLE

CO

$1,217,871

$1,559,136

$1,884,600

$2,342,130

EL PASO

CO

$586,141

$750,374

$907,018

$1,127,204

ELBERT

CO

$892,237

$1,142,211

$1,380,688

$1,715,893

GARFIELD

CO

$1,233,785

$1,579,778

$1,909,461

$2,373,108

GILPIN

CO

$892,237

$1,142,211

$1,380,688

$1,715,893

GRAND

CO

$758,076

$970,446

$1,173,075

$1,457,878

GUNNISON

CO

$588,746

$753,715

$911,039

$1,132,187

JEFFERSON

CO

$892,237

$1,142,211

$1,380,688

$1,715,893

LA PLATA

CO

$676,016

$865,394

$1,046,106

$1,300,044

LARIMER

CO

$695,554

$890,425

$1,076,348

$1,337,648

PARK

CO

$892,237

$1,142,211

$1,380,688

$1,715,893

PITKIN

CO

$1,233,785

$1,579,778

$1,909,461

$2,373,108

ROUTT

CO

$957,364

$1,225,630

$1,481,493

$1,841,107

SAN JUAN

CO

$573,116

$733,668

$886,857

$1,102,172

SAN MIGUEL

CO

$1,184,005

$1,515,756

$1,832,215

$2,277,003

SUMMIT

CO

$1,079,803

$1,382,331

$1,670,927

$2,076,583

TELLER

CO

$586,141

$750,374

$907,018

$1,127,204

WELD

CO

$629,125

$805,364

$973,504

$1,209,886

FAIRFIELD

CT

$801,060

$1,025,492

$1,239,618

$1,540,504

DISTRICT OF COL

DC

$1,233,785

$1,579,778

$1,909,461

$2,373,108

NEW CASTLE

DE

$599,167

$767,024

$927,179

$1,152,235

BAKER

FL

$596,562

$763,683

$923,158

$1,147,251

BROWARD

FL

$631,730

$808,705

$977,582

$1,214,870

CLAY

FL

$596,562

$763,683

$923,158

$1,147,251

County Name

May 8, 2023

842

Bulletin No. 2023–19

State

One-Unit
Limit

Two-Unit
Limit

Three-Unit
Limit

Four-Unit
Limit

COLLIER

FL

$761,984

$975,486

$1,179,135

$1,465,353

DUVAL

FL

$596,562

$763,683

$923,158

$1,147,251

County Name

MANATEE

FL

$573,116

$733,668

$886,857

$1,102,172

MARTIN

FL

$566,603

$725,343

$876,777

$1,089,657

MIAMI-DADE

FL

$631,730

$808,705

$977,582

$1,214,870

MONROE

FL

$989,928

$1,267,311

$1,531,839

$1,903,742

NASSAU

FL

$596,562

$763,683

$923,158

$1,147,251

OKALOOSA

FL

$683,832

$875,418

$1,058,169

$1,315,052

PALM BEACH

FL

$631,730

$808,705

$977,582

$1,214,870

SARASOTA

FL

$573,116

$733,668

$886,857

$1,102,172

ST. JOHNS

FL

$596,562

$763,683

$923,158

$1,147,251

ST. LUCIE

FL

$566,603

$725,343

$876,777

$1,089,657

WALTON

FL

$683,832

$875,418

$1,058,169

$1,315,052

BARROW

GA

$670,806

$858,768

$1,038,008

$1,290,021

BARTOW

GA

$670,806

$858,768

$1,038,008

$1,290,021

BUTTS

GA

$670,806

$858,768

$1,038,008

$1,290,021

CARROLL

GA

$670,806

$858,768

$1,038,008

$1,290,021

CHEROKEE

GA

$670,806

$858,768

$1,038,008

$1,290,021

CLARKE

GA

$584,839

$748,675

$904,980

$1,124,712

CLAYTON

GA

$670,806

$858,768

$1,038,008

$1,290,021

COBB

GA

$670,806

$858,768

$1,038,008

$1,290,021

COWETA

GA

$670,806

$858,768

$1,038,008

$1,290,021

DAWSON

GA

$670,806

$858,768

$1,038,008

$1,290,021

DEKALB

GA

$670,806

$858,768

$1,038,008

$1,290,021

DOUGLAS

GA

$670,806

$858,768

$1,038,008

$1,290,021

FAYETTE

GA

$670,806

$858,768

$1,038,008

$1,290,021

FORSYTH

GA

$670,806

$858,768

$1,038,008

$1,290,021

FULTON

GA

$670,806

$858,768

$1,038,008

$1,290,021

GREENE

GA

$583,536

$747,033

$902,997

$1,122,220

GWINNETT

GA

$670,806

$858,768

$1,038,008

$1,290,021

HARALSON

GA

$670,806

$858,768

$1,038,008

$1,290,021

HEARD

GA

$670,806

$858,768

$1,038,008

$1,290,021

HENRY

GA

$670,806

$858,768

$1,038,008

$1,290,021

JASPER

GA

$670,806

$858,768

$1,038,008

$1,290,021

LAMAR

GA

$670,806

$858,768

$1,038,008

$1,290,021

MADISON

GA

$584,839

$748,675

$904,980

$1,124,712

MERIWETHER

GA

$670,806

$858,768

$1,038,008

$1,290,021

MORGAN

GA

$670,806

$858,768

$1,038,008

$1,290,021

NEWTON

GA

$670,806

$858,768

$1,038,008

$1,290,021

OCONEE

GA

$584,839

$748,675

$904,980

$1,124,712

OGLETHORPE

GA

$584,839

$748,675

$904,980

$1,124,712

Bulletin No. 2023–19

843

May 8, 2023

State

One-Unit
Limit

Two-Unit
Limit

Three-Unit
Limit

Four-Unit
Limit

PAULDING

GA

$670,806

$858,768

$1,038,008

$1,290,021

PICKENS

GA

$670,806

$858,768

$1,038,008

$1,290,021

PIKE

GA

$670,806

$858,768

$1,038,008

$1,290,021

ROCKDALE

GA

$670,806

$858,768

$1,038,008

$1,290,021

SPALDING

GA

$670,806

$858,768

$1,038,008

$1,290,021

WALTON

GA

$670,806

$858,768

$1,038,008

$1,290,021

HAWAII

HI

$586,141

$750,374

$907,018

$1,127,204

HONOLULU

HI

$872,699

$1,117,236

$1,350,447

$1,678,290

KALAWAO

HI

$1,107,156

$1,417,386

$1,713,288

$2,129,194

KAUAI

HI

$1,107,156

$1,417,386

$1,713,288

$2,129,194

MAUI

HI

$1,107,156

$1,417,386

$1,713,288

$2,129,194

ADA

ID

$664,293

$850,386

$1,027,928

$1,277,505

BLAINE

ID

$838,833

$1,073,856

$1,298,062

$1,613,163

BOISE

ID

$664,293

$850,386

$1,027,928

$1,277,505

BONNER

ID

$592,654

$758,699

$917,099

$1,139,719

CAMAS

ID

$838,833

$1,073,856

$1,298,062

$1,613,163

CANYON

ID

$664,293

$850,386

$1,027,928

$1,277,505

FRANKLIN

ID

$557,486

$713,677

$862,675

$1,072,101

GEM

ID

$664,293

$850,386

$1,027,928

$1,277,505

KOOTENAI

ID

$648,663

$830,395

$1,003,746

$1,247,433

OWYHEE

ID

$664,293

$850,386

$1,027,928

$1,277,505

TETON

ID

$1,233,785

$1,579,778

$1,909,461

$2,373,108

VALLEY

ID

$649,966

$832,094

$1,005,784

$1,249,925

BARNSTABLE

MA

$794,547

$1,017,168

$1,229,538

$1,527,988

BRISTOL

MA

$748,958

$958,780

$1,158,974

$1,440,322

DUKES

MA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

ESSEX

MA

$937,826

$1,200,599

$1,451,252

$1,803,560

MIDDLESEX

MA

$937,826

$1,200,599

$1,451,252

$1,803,560

NANTUCKET

MA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

NORFOLK

MA

$937,826

$1,200,599

$1,451,252

$1,803,560

PLYMOUTH

MA

$937,826

$1,200,599

$1,451,252

$1,803,560

SUFFOLK

MA

$937,826

$1,200,599

$1,451,252

$1,803,560

ANNE ARUNDEL

MD

$716,395

$917,099

$1,108,572

$1,377,687

BALTIMORE

MD

$716,395

$917,099

$1,108,572

$1,377,687

BALTIMORE CITY

MD

$716,395

$917,099

$1,108,572

$1,377,687

CALVERT

MD

$1,233,785

$1,579,778

$1,909,461

$2,373,108

CARROLL

MD

$716,395

$917,099

$1,108,572

$1,377,687

CECIL

MD

$599,167

$767,024

$927,179

$1,152,235

County Name

May 8, 2023

844

Bulletin No. 2023–19

State

One-Unit
Limit

Two-Unit
Limit

Three-Unit
Limit

Four-Unit
Limit

CHARLES

MD

$1,233,785

$1,579,778

$1,909,461

$2,373,108

FREDERICK

MD

$1,233,785

$1,579,778

$1,909,461

$2,373,108

HARFORD

MD

$716,395

$917,099

$1,108,572

$1,377,687

HOWARD

MD

$716,395

$917,099

$1,108,572

$1,377,687

MONTGOMERY

MD

$1,233,785

$1,579,778

$1,909,461

$2,373,108

PRINCE GEORGE'S

MD

$1,233,785

$1,579,778

$1,909,461

$2,373,108

QUEEN ANNE'S

MD

$716,395

$917,099

$1,108,572

$1,377,687

CUMBERLAND

ME

$573,116

$733,668

$886,857

$1,102,172

SAGADAHOC

ME

$573,116

$733,668

$886,857

$1,102,172

YORK

ME

$573,116

$733,668

$886,857

$1,102,172

ANOKA

MN

$583,536

$747,033

$902,997

$1,122,220

CARVER

MN

$583,536

$747,033

$902,997

$1,122,220

CHISAGO

MN

$583,536

$747,033

$902,997

$1,122,220

DAKOTA

MN

$583,536

$747,033

$902,997

$1,122,220

HENNEPIN

MN

$583,536

$747,033

$902,997

$1,122,220

ISANTI

MN

$583,536

$747,033

$902,997

$1,122,220

LE SUEUR

MN

$583,536

$747,033

$902,997

$1,122,220

MILLE LACS

MN

$583,536

$747,033

$902,997

$1,122,220

RAMSEY

MN

$583,536

$747,033

$902,997

$1,122,220

SCOTT

MN

$583,536

$747,033

$902,997

$1,122,220

SHERBURNE

MN

$583,536

$747,033

$902,997

$1,122,220

WASHINGTON

MN

$583,536

$747,033

$902,997

$1,122,220

WRIGHT

MN

$583,536

$747,033

$902,997

$1,122,220

BROADWATER

MT

$565,301

$723,700

$874,738

$1,087,108

FLATHEAD

MT

$626,520

$802,079

$969,483

$1,204,846

GALLATIN

MT

$797,152

$1,020,509

$1,233,558

$1,533,029

MISSOULA

MT

$618,705

$792,055

$957,421

$1,189,839

PARK

MT

$610,889

$782,031

$945,302

$1,174,774

RAVALLI

MT

$571,813

$732,025

$884,819

$1,099,624

CAMDEN

NC

$574,418

$735,367

$888,896

$1,104,664

County Name

CHATHAM

NC

$682,529

$873,775

$1,056,187

$1,312,560

CURRITUCK

NC

$574,418

$735,367

$888,896

$1,104,664

DARE

NC

$683,832

$875,418

$1,058,169

$1,315,052

DURHAM

NC

$682,529

$873,775

$1,056,187

$1,312,560

FRANKLIN

NC

$569,208

$728,684

$880,798

$1,094,640

GATES

NC

$574,418

$735,367

$888,896

$1,104,664

GRANVILLE

NC

$682,529

$873,775

$1,056,187

$1,312,560

Bulletin No. 2023–19

845

May 8, 2023

State

One-Unit
Limit

Two-Unit
Limit

Three-Unit
Limit

Four-Unit
Limit

HYDE

NC

$547,065

$700,311

$846,535

$1,052,053

JOHNSTON

NC

$569,208

$728,684

$880,798

$1,094,640

ORANGE

NC

$682,529

$873,775

$1,056,187

$1,312,560

PASQUOTANK

NC

$911,775

$1,167,242

$1,410,930

$1,753,440

PERQUIMANS

NC

$911,775

$1,167,242

$1,410,930

$1,753,440

PERSON

NC

$682,529

$873,775

$1,056,187

$1,312,560

WAKE

NC

$569,208

$728,684

$880,798

$1,094,640

DAWSON

NE

$683,832

$875,418

$1,058,169

$1,315,052

GOSPER

NE

$683,832

$875,418

$1,058,169

$1,315,052

HILLSBOROUGH

NH

$540,553

$691,987

$836,455

$1,039,537

ROCKINGHAM

NH

$937,826

$1,200,599

$1,451,252

$1,803,560

STRAFFORD

NH

$937,826

$1,200,599

$1,451,252

$1,803,560

BERGEN

NJ

$1,233,785

$1,579,778

$1,909,461

$2,373,108

BURLINGTON

NJ

$599,167

$767,024

$927,179

$1,152,235

CAMDEN

NJ

$599,167

$767,024

$927,179

$1,152,235

CAPE MAY

NJ

$621,310

$795,397

$961,442

$1,194,822

ESSEX

NJ

$1,233,785

$1,579,778

$1,909,461

$2,373,108

GLOUCESTER

NJ

$599,167

$767,024

$927,179

$1,152,235

HUDSON

NJ

$1,233,785

$1,579,778

$1,909,461

$2,373,108

HUNTERDON

NJ

$1,233,785

$1,579,778

$1,909,461

$2,373,108

MIDDLESEX

NJ

$1,233,785

$1,579,778

$1,909,461

$2,373,108

MONMOUTH

NJ

$1,233,785

$1,579,778

$1,909,461

$2,373,108

MORRIS

NJ

$1,233,785

$1,579,778

$1,909,461

$2,373,108

OCEAN

NJ

$1,233,785

$1,579,778

$1,909,461

$2,373,108

PASSAIC

NJ

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SALEM

NJ

$599,167

$767,024

$927,179

$1,152,235

SOMERSET

NJ

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SUSSEX

NJ

$1,233,785

$1,579,778

$1,909,461

$2,373,108

UNION

NJ

$1,233,785

$1,579,778

$1,909,461

$2,373,108

LOS ALAMOS

NM

$660,386

$845,403

$1,021,925

$1,269,973

SANTA FE

NM

$570,511

$730,326

$882,836

$1,097,132

CARSON CITY

NV

$573,116

$733,668

$886,857

$1,102,172

CLARK

NV

$560,091

$717,018

$866,696

$1,077,084

DOUGLAS

NV

$745,051

$953,796

$1,152,914

$1,432,790

STOREY

NV

$703,370

$900,449

$1,088,411

$1,352,656

WASHOE

NV

$703,370

$900,449

$1,088,411

$1,352,656

County Name

May 8, 2023

846

Bulletin No. 2023–19

State

One-Unit
Limit

Two-Unit
Limit

Three-Unit
Limit

Four-Unit
Limit

BRONX

NY

$1,233,785

$1,579,778

$1,909,461

$2,373,108

KINGS

NY

$1,233,785

$1,579,778

$1,909,461

$2,373,108

NASSAU

NY

$1,233,785

$1,579,778

$1,909,461

$2,373,108

NEW YORK

NY

$1,233,785

$1,579,778

$1,909,461

$2,373,108

PUTNAM

NY

$1,233,785

$1,579,778

$1,909,461

$2,373,108

QUEENS

NY

$1,233,785

$1,579,778

$1,909,461

$2,373,108

RICHMOND

NY

$1,233,785

$1,579,778

$1,909,461

$2,373,108

ROCKLAND

NY

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SUFFOLK

NY

$1,233,785

$1,579,778

$1,909,461

$2,373,108

WESTCHESTER

NY

$1,233,785

$1,579,778

$1,909,461

$2,373,108

DELAWARE

OH

$553,578

$708,693

$856,616

$1,064,569

FAIRFIELD

OH

$553,578

$708,693

$856,616

$1,064,569

FRANKLIN

OH

$553,578

$708,693

$856,616

$1,064,569

HOCKING

OH

$553,578

$708,693

$856,616

$1,064,569

LICKING

OH

$553,578

$708,693

$856,616

$1,064,569

MADISON

OH

$553,578

$708,693

$856,616

$1,064,569

MORROW

OH

$553,578

$708,693

$856,616

$1,064,569

PERRY

OH

$553,578

$708,693

$856,616

$1,064,569

PICKAWAY

OH

$553,578

$708,693

$856,616

$1,064,569

UNION

OH

$553,578

$708,693

$856,616

$1,064,569

BENTON

OR

$634,335

$812,046

$981,603

$1,219,910

CLACKAMAS

OR

$761,984

$975,486

$1,179,135

$1,465,353

CLATSOP

OR

$599,167

$767,024

$927,179

$1,152,235

COLUMBIA

OR

$761,984

$975,486

$1,179,135

$1,465,353

DESCHUTES

OR

$781,522

$1,000,461

$1,209,377

$1,502,957

HOOD RIVER

OR

$760,681

$973,787

$1,177,096

$1,462,861

LANE

OR

$545,763

$698,669

$844,553

$1,049,561

MARION

OR

$547,065

$700,311

$846,535

$1,052,053

MULTNOMAH

OR

$761,984

$975,486

$1,179,135

$1,465,353

POLK

OR

$547,065

$700,311

$846,535

$1,052,053

WASHINGTON

OR

$761,984

$975,486

$1,179,135

$1,465,353

YAMHILL

OR

$761,984

$975,486

$1,179,135

$1,465,353

BUCKS

PA

$599,167

$767,024

$927,179

$1,152,235

CHESTER

PA

$599,167

$767,024

$927,179

$1,152,235

DELAWARE

PA

$599,167

$767,024

$927,179

$1,152,235

MONTGOMERY

PA

$599,167

$767,024

$927,179

$1,152,235

PHILADELPHIA

PA

$599,167

$767,024

$927,179

$1,152,235

PIKE

PA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

County Name

Bulletin No. 2023–19

847

May 8, 2023

State

One-Unit
Limit

Two-Unit
Limit

Three-Unit
Limit

Four-Unit
Limit

BRISTOL

RI

$748,958

$958,780

$1,158,974

$1,440,322

KENT

RI

$748,958

$958,780

$1,158,974

$1,440,322

County Name

NEWPORT

RI

$748,958

$958,780

$1,158,974

$1,440,322

PROVIDENCE

RI

$748,958

$958,780

$1,158,974

$1,440,322

WASHINGTON

RI

$748,958

$958,780

$1,158,974

$1,440,322

BEAUFORT

SC

$549,670

$703,653

$850,556

$1,057,093

BERKELEY

SC

$609,587

$780,389

$943,319

$1,172,283

CHARLESTON

SC

$609,587

$780,389

$943,319

$1,172,283

DORCHESTER

SC

$609,587

$780,389

$943,319

$1,172,283

JASPER

SC

$549,670

$703,653

$850,556

$1,057,093

CANNON

TN

$1,008,163

$1,290,644

$1,560,099

$1,938,797

CHEATHAM

TN

$1,008,163

$1,290,644

$1,560,099

$1,938,797

DAVIDSON

TN

$1,008,163

$1,290,644

$1,560,099

$1,938,797

DICKSON

TN

$1,008,163

$1,290,644

$1,560,099

$1,938,797

MACON

TN

$1,008,163

$1,290,644

$1,560,099

$1,938,797

MAURY

TN

$1,008,163

$1,290,644

$1,560,099

$1,938,797

ROBERTSON

TN

$1,008,163

$1,290,644

$1,560,099

$1,938,797

RUTHERFORD

TN

$1,008,163

$1,290,644

$1,560,099

$1,938,797

SMITH

TN

$1,008,163

$1,290,644

$1,560,099

$1,938,797

SUMNER

TN

$1,008,163

$1,290,644

$1,560,099

$1,938,797

TROUSDALE

TN

$1,008,163

$1,290,644

$1,560,099

$1,938,797

WILLIAMSON

TN

$1,008,163

$1,290,644

$1,560,099

$1,938,797

WILSON

TN

$1,008,163

$1,290,644

$1,560,099

$1,938,797

ATASCOSA

TX

$593,957

$760,341

$919,081

$1,142,211

BANDERA

TX

$593,957

$760,341

$919,081

$1,142,211

BASTROP

TX

$647,361

$828,753

$1,001,764

$1,244,941

BEXAR

TX

$593,957

$760,341

$919,081

$1,142,211

CALDWELL

TX

$647,361

$828,753

$1,001,764

$1,244,941

COLLIN

TX

$601,772

$770,365

$931,200

$1,157,275

COMAL

TX

$593,957

$760,341

$919,081

$1,142,211

DALLAS

TX

$601,772

$770,365

$931,200

$1,157,275

DENTON

TX

$601,772

$770,365

$931,200

$1,157,275

ELLIS

TX

$601,772

$770,365

$931,200

$1,157,275

GUADALUPE

TX

$593,957

$760,341

$919,081

$1,142,211

HAYS

TX

$647,361

$828,753

$1,001,764

$1,244,941

HUNT

TX

$601,772

$770,365

$931,200

$1,157,275

JOHNSON

TX

$601,772

$770,365

$931,200

$1,157,275

KAUFMAN

TX

$601,772

$770,365

$931,200

$1,157,275

May 8, 2023

848

Bulletin No. 2023–19

State

One-Unit
Limit

Two-Unit
Limit

Three-Unit
Limit

Four-Unit
Limit

KENDALL

TX

$593,957

$760,341

$919,081

$1,142,211

MEDINA

TX

$593,957

$760,341

$919,081

$1,142,211

PARKER

TX

$601,772

$770,365

$931,200

$1,157,275

ROCKWALL

TX

$601,772

$770,365

$931,200

$1,157,275

TARRANT

TX

$601,772

$770,365

$931,200

$1,157,275

TRAVIS

TX

$647,361

$828,753

$1,001,764

$1,244,941

WILLIAMSON

TX

$647,361

$828,753

$1,001,764

$1,244,941

WILSON

TX

$593,957

$760,341

$919,081

$1,142,211

WISE

TX

$601,772

$770,365

$931,200

$1,157,275

BOX ELDER

UT

$842,741

$1,078,840

$1,304,122

$1,620,695

CACHE

UT

$557,486

$713,677

$862,675

$1,072,101

DAVIS

UT

$842,741

$1,078,840

$1,304,122

$1,620,695

GRAND

UT

$616,100

$788,714

$953,400

$1,184,798

JUAB

UT

$681,226

$872,076

$1,054,148

$1,310,068

MORGAN

UT

$842,741

$1,078,840

$1,304,122

$1,620,695

RICH

UT

$601,772

$770,365

$931,200

$1,157,275

SALT LAKE

UT

$702,067

$898,750

$1,086,428

$1,350,164

SUMMIT

UT

$1,233,785

$1,579,778

$1,909,461

$2,373,108

TOOELE

UT

$702,067

$898,750

$1,086,428

$1,350,164

UTAH

UT

$681,226

$872,076

$1,054,148

$1,310,068

WASATCH

UT

$1,233,785

$1,579,778

$1,909,461

$2,373,108

WASHINGTON

UT

$672,109

$860,410

$1,040,047

$1,292,512

WEBER

UT

$842,741

$1,078,840

$1,304,122

$1,620,695

ALBEMARLE

VA

$574,418

$735,367

$888,896

$1,104,664

ALEXANDRIA CITY

VA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

AMELIA

VA

$618,705

$792,055

$957,421

$1,189,839

ARLINGTON

VA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

CHARLES CITY

VA

$618,705

$792,055

$957,421

$1,189,839

CHARLOTTESVILLE

VA

$574,418

$735,367

$888,896

$1,104,664

CHESAPEAKE CITY

VA

$574,418

$735,367

$888,896

$1,104,664

CHESTERFIELD

VA

$618,705

$792,055

$957,421

$1,189,839

CLARKE

VA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

COLONIAL HEIGHT

VA

$618,705

$792,055

$957,421

$1,189,839

CULPEPER

VA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

DINWIDDIE

VA

$618,705

$792,055

$957,421

$1,189,839

FAIRFAX

VA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

FAIRFAX CITY

VA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

FALLS CHURCH CI

VA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

FAUQUIER

VA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

County Name

Bulletin No. 2023–19

849

May 8, 2023

State

One-Unit
Limit

Two-Unit
Limit

Three-Unit
Limit

Four-Unit
Limit

FLUVANNA

VA

$574,418

$735,367

$888,896

$1,104,664

FRANKLIN CITY

VA

$574,418

$735,367

$888,896

$1,104,664

County Name

FREDERICKSBURG

VA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

GLOUCESTER

VA

$574,418

$735,367

$888,896

$1,104,664

GOOCHLAND

VA

$618,705

$792,055

$957,421

$1,189,839

GREENE

VA

$574,418

$735,367

$888,896

$1,104,664

HAMPTON CITY

VA

$574,418

$735,367

$888,896

$1,104,664

HANOVER

VA

$618,705

$792,055

$957,421

$1,189,839

HENRICO

VA

$618,705

$792,055

$957,421

$1,189,839

HOPEWELL CITY

VA

$618,705

$792,055

$957,421

$1,189,839

ISLE OF WIGHT

VA

$574,418

$735,367

$888,896

$1,104,664

JAMES CITY

VA

$574,418

$735,367

$888,896

$1,104,664

KING AND QUEEN

VA

$618,705

$792,055

$957,421

$1,189,839

KING WILLIAM

VA

$618,705

$792,055

$957,421

$1,189,839

LOUDOUN

VA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

MADISON

VA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

MANASSAS CITY

VA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

MANASSAS PARK C

VA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

MATHEWS

VA

$574,418

$735,367

$888,896

$1,104,664

NELSON

VA

$574,418

$735,367

$888,896

$1,104,664

NEW KENT

VA

$618,705

$792,055

$957,421

$1,189,839

NEWPORT NEWS CI

VA

$574,418

$735,367

$888,896

$1,104,664

NORFOLK CITY

VA

$574,418

$735,367

$888,896

$1,104,664

PETERSBURG CITY

VA

$618,705

$792,055

$957,421

$1,189,839

POQUOSON CITY

VA

$574,418

$735,367

$888,896

$1,104,664

PORTSMOUTH CITY

VA

$574,418

$735,367

$888,896

$1,104,664

POWHATAN

VA

$618,705

$792,055

$957,421

$1,189,839

PRINCE GEORGE

VA

$618,705

$792,055

$957,421

$1,189,839

PRINCE WILLIAM

VA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

RAPPAHANNOCK

VA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

RICHMOND CITY

VA

$618,705

$792,055

$957,421

$1,189,839

SOUTHAMPTON

VA

$574,418

$735,367

$888,896

$1,104,664

SPOTSYLVANIA

VA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

STAFFORD

VA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SUFFOLK CITY

VA

$574,418

$735,367

$888,896

$1,104,664

SUSSEX

VA

$618,705

$792,055

$957,421

$1,189,839

VIRGINIA BEACH

VA

$574,418

$735,367

$888,896

$1,104,664

WARREN

VA

$1,233,785

$1,579,778

$1,909,461

$2,373,108

WILLIAMSBURG CI

VA

$574,418

$735,367

$888,896

$1,104,664

YORK

VA

$574,418

$735,367

$888,896

$1,104,664

May 8, 2023

850

Bulletin No. 2023–19

State

One-Unit
Limit

Two-Unit
Limit

Three-Unit
Limit

Four-Unit
Limit

CHITTENDEN

VT

$557,486

$713,677

$862,675

$1,072,101

FRANKLIN

VT

$557,486

$713,677

$862,675

$1,072,101

GRAND ISLE

VT

$557,486

$713,677

$862,675

$1,072,101

CHELAN

WA

$573,116

$733,668

$886,857

$1,102,172

CLARK

WA

$761,984

$975,486

$1,179,135

$1,465,353

DOUGLAS

WA

$573,116

$733,668

$886,857

$1,102,172

ISLAND

WA

$651,268

$833,736

$1,007,823

$1,252,474

KING

WA

$1,107,156

$1,417,386

$1,713,288

$2,129,194

KITSAP

WA

$638,243

$817,087

$987,662

$1,227,386

KITTITAS

WA

$537,947

$688,645

$832,434

$1,034,497

PIERCE

WA

$1,107,156

$1,417,386

$1,713,288

$2,129,194

SAN JUAN

WA

$563,998

$722,001

$872,756

$1,084,616

SKAGIT

WA

$617,402

$790,356

$955,382

$1,187,347

SKAMANIA

WA

$761,984

$975,486

$1,179,135

$1,465,353

SNOHOMISH

WA

$1,107,156

$1,417,386

$1,713,288

$2,129,194

THURSTON

WA

$618,705

$792,055

$957,421

$1,189,839

WHATCOM

WA

$683,832

$875,418

$1,058,169

$1,315,052

PIERCE

WI

$583,536

$747,033

$902,997

$1,122,220

ST. CROIX

WI

$583,536

$747,033

$902,997

$1,122,220

JEFFERSON

WV

$1,233,785

$1,579,778

$1,909,461

$2,373,108

SHERIDAN

WY

$554,880

$710,335

$858,655

$1,067,060

TETON

WY

$1,233,785

$1,579,778

$1,909,461

$2,373,108

GUAM

GU

$638,243

$817,087

$987,662

$1,227,386

NORTHERN ISLAND

MP

$593,957

$760,341

$919,081

$1,142,211

SAIPAN

MP

$599,167

$767,024

$927,179

$1,152,235

TINIAN

MP

$603,074

$772,064

$933,239

$1,159,767

CULEBRA

PR

$603,074

$772,064

$933,239

$1,159,767

ST. JOHN ISLAND

VI

$1,090,223

$1,395,696

$1,687,068

$2,096,630

ST. THOMAS ISLA

VI

$659,083

$843,760

$1,019,886

$1,267,481

$534,640

$684,568

$827,422

$1,028,324

County Name

All other areas - 2823 counties (floor):

Bulletin No. 2023–19

851

May 8, 2023

.02 The nationwide average purchase
price (for use in the housing cost/income
ratio for new and existing residences) is
$503,300.
SECTION 5. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2022-21 is obsolete except
as provided in section 6 of this revenue
procedure.
SECTION 6. EFFECTIVE DATES
.01 Issuers may rely on this revenue
procedure to determine average area purchase price safe harbors for commitments
to provide financing or issue mortgage
credit certificates that are made, or (if
the purchase precedes the commitment)
for residences that are purchased, in the
period that begins on April 20, 2023,
and ends on the date as of which the safe
harbors contained in section 4.01 of this
revenue procedure are rendered obsolete
by a new revenue procedure.
.02 Notwithstanding section 5 of this
revenue procedure, issuers may continue to
rely on the average area purchase price safe
harbors contained in Rev. Proc. 2022-21,
with respect to bonds sold, or for mortgage credit certificates issued with respect
to bond authority exchanged, before May
20, 2023, if the commitments to provide
financing or issue mortgage credit certificates are made on or before June 19, 2023.
.03 Except as provided in section 6.04,
issuers must use the nationwide average
purchase price limitation contained in
this revenue procedure for commitments
to provide financing or issue mortgage
credit certificates that are made, or (if the
purchase precedes the commitment) for
residences that are purchased, in the period
that begins on April 20, 2023, and ends on
the date when the nationwide average purchase price limitation is rendered obsolete
by a new revenue procedure.
.04 Notwithstanding sections 5 and
6.03 of this revenue procedure, issuers
may continue to rely on the nationwide
average purchase price set forth in Rev.

May 8, 2023

Proc. 2022-21 with respect to bonds sold,
or for mortgage credit certificates issued
with respect to bond authority exchanged,
before May 20, 2023, if the commitments
to provide financing or issue mortgage
credit certificates are made on or before
June 19, 2023.
SECTION 7. REQUEST FOR
COMMENTS
.01 Comments Regarding Guidance in
this Revenue Procedure.
The Treasury Department and the IRS
request comments on whether there are
other sources of average purchase price
data, including data that differentiate
between new and existing residences, that
could provide a different method for calculating average area purchase price safe
harbors.
.02 Procedures for Submitting Comments.
(1) Deadline.
Written comments
should be submitted by June 19, 2023.
(2) Form and manner. The subject line
for the comments should include a reference to Revenue Procedure 2023-22. All
commenters are strongly encouraged to
submit comments electronically. However, comments may be submitted in one
of two ways:
(a) Electronically via the Federal
eRulemaking Portal at www.regulations.
gov (type IRS-2023-0018 in the search
field on the regulations.gov homepage to
find this notice and submit comments); or
(b) By mail to: Internal Revenue
Service, CC:PA:LPD:PR (Revenue Procedure 2023-22), Room 5203, P.O. Box
7604, Ben Franklin Station, Washington,
D.C., 20044.
(3) Publication of comments. The
Treasury Department and the IRS will
publish for public availability any comment submitted electronically or on paper
to its public docket on regulations.gov.
SECTION 8. PAPERWORK
REDUCTION ACT
The collection of information contained in this revenue procedure has been

852

reviewed and approved by the Office
of Management and Budget in accordance with the Paperwork Reduction Act
(44 U.S.C. 3507) under control number
1545-1877.
An agency may not conduct or sponsor,
and a person is not required to respond
to, a collection of information unless the
collection of information displays a valid
OMB control number.
This revenue procedure contains a
collection of information requirement
in section 3.03. The purpose of the collection of information is to verify the
applicable FHA loan limit that issuers of
qualified mortgage bonds and qualified
mortgage certificates have used to calculate the average area purchase price for
a given metropolitan statistical area for
purposes of §§ 143(e) and 25(c). The collection of information is required to obtain
the benefit of using revisions to FHA loan
limits to determine average area purchase
prices. The likely respondents are state
and local governments.
The estimated total annual report
ing and/or recordkeeping burden is:
15 hours.
The estimated annual burden per

respondent
and/or
recordkeeper:
15 minutes.
The estimated number of respondents
and/or recordkeepers: 60.
Books or records relating to a collection of information must be retained as
long as their contents may become material in the administration of any internal
revenue law. Generally, tax returns and
tax return information are confidential, as
required by 26 U.S.C. 6103.
SECTION 9. DRAFTING
INFORMATION
The principal authors of this revenue procedure are Zoran Stojanovic and
David White of the Office of Associate
Chief Counsel (Financial Institutions
& Products). For further information
regarding this revenue procedure contact
Mr. White at (202) 317-4562 (not a tollfree number).

Bulletin No. 2023–19

Part IV
Deletions From Cumulative
List of Organizations,
Contributions to Which are
Deductible Under Section
170 of the Code
Announcement 2023-14
The Internal Revenue Service has
revoked its determination that the
organizations listed below qualify as organizations 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

NAME OF ORGANIZATION
Sarah and Mary’s Helping Hands
Little People Christian Day Care
Foundation for Better Health
New Life Ministries, Inc.
Project Transition USA, Inc.

Bulletin No. 2023–19

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 precluded from disallowing a
deduction for any contributions made
after an organization ceases to qualify
under section 170(c)(2) if the organization has not timely filed a suit for
declaratory judgment under section
7428 and if the contributor (1) had
knowledge of the revocation of the
ruling or determination letter, (2) was
aware that such revocation was imminent, or (3) was in part responsible for
or was aware of the activities or omissions of the organization that brought
about this revocation.

Effective Date of
Revocation
01/01/ 2020
01/01/ 2020
01/01/2018
07/01/2020
01/01/2018

853

If on the other hand a suit for declaratory judgment has been timely filed,
contributions from individuals and organizations described in section 170(c)(2)
that are otherwise allowable will continue
to be deductible. Protection under section
7428(c) would begin on May 8, 2023 and
would end on the date the court first determines the organization is not described
in section 170(c)(2) as more particularly
set for in section 7428(c)(1). For individual contributors, the maximum deduction
protected is $1,000, with a husband and
wife treated as one contributor. This benefit is not extended to any individual, in
whole or in part, for the acts or omissions
of the organization that were the basis for
revocation.

LOCATION
Orland Park, IL
Maywood, IL
Costa Mesa, CA
San Marcos, CA
St. Petersburg, FL

May 8, 2023

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. 2023–19

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 8, 2023

Numerical Finding List1
Bulletin 2023–19

Announcements:
2023-2, 2023-2 I.R.B. 344
2023-1, 2023-3 I.R.B. 422
2023-3, 2023-5 I.R.B. 447
2023-4, 2023-7 I.R.B. 470
2023-5, 2023-9 I.R.B. 499
2023-6, 2023-9 I.R.B. 501
2023-8, 2023-14 I.R.B. 632
2023-9, 2023-15 I.R.B. 639
2023-10, 2023-16 I.R.B. 663
2023-7, 2023-17 I.R.B. 797
2023-11, 2023-17 I.R.B. 798
2023-12, 2023-17 I.R.B. 799
2023-13, 2023-18 I.R.B. 833
2023-14, 2023-19 I.R.B. 853

AOD:
2023-1, 2023-10 I.R.B. 502
2023-2, 2023-11 I.R.B. 529

Notices:
2023-4, 2023-2 I.R.B. 321
2023-5, 2023-2 I.R.B. 324
2023-6, 2023-2 I.R.B. 328
2023-8, 2023-2 I.R.B. 341
2023-1, 2023-3 I.R.B. 373
2023-2, 2023-3 I.R.B. 374
2023-3, 2023-3 I.R.B. 388
2023-7, 2023-3 I.R.B. 390
2023-9, 2023-3 I.R.B. 402
2023-10, 2023-3 I.R.B. 403
2023-11, 2023-3 I.R.B. 404
2023-12, 2023-6 I.R.B. 450
2023-13, 2023-6 I.R.B. 454
2023-16, 2023-8 I.R.B. 479
2023-17, 2023-10 I.R.B. 505
2023-18, 2023-10 I.R.B. 508
2023-20, 2023-10 I.R.B. 523
2023-19, 2023-11 I.R.B. 560
2023-21, 2023-11 I.R.B. 563
2023-22, 2023-12 I.R.B. 569
2023-23, 2023-13 I.R.B. 571
2023-24, 2023-13 I.R.B. 571
2023-26, 2023-13 I.R.B. 577
2023-25, 2023-14 I.R.B. 629
2023-27, 2023-15 I.R.B. 634
2023-28, 2023-15 I.R.B. 635
2023-31, 2023-16 I.R.B. 661
2023-30, 2023-17 I.R.B. 766
2023-33, 2023-18 I.R.B. 803
2023-34, 2023-19 I.R.B. 837

Proposed Regulations:
REG-100442-22, 2023-3 I.R.B. 423
REG-146537-06, 2023-3 I.R.B. 436
REG-114666-22, 2023-4 I.R.B. 437
REG 122286-18, 2023-11 I.R.B. 565
REG-120653-22, 2023-15 I.R.B. 640
REG-105954-22, 2023-16 I.R.B. 713
REG-120080-22, 2023-16 I.R.B. 746
REG 109309-22, 2023-17 I.R.B. 770
REG 121709-19, 2023-17 I.R.B. 789

Revenue Procedures:
2023-1, 2023-1 I.R.B. 1
2023-2, 2023-1 I.R.B. 120
2023-3, 2023-1 I.R.B. 144
2023-4, 2023-1 I.R.B. 162
2023-5, 2023-1 I.R.B. 265
2023-7, 2023-1 I.R.B. 305
2023-8, 2023-3 I.R.B. 407
2023-10, 2023-3 I.R.B. 411
2023-11, 2023-3 I.R.B. 417
2023-14, 2023-6 I.R.B. 466
2023-9, 2023-7 I.R.B. 471
2023-13, 2023-13 I.R.B. 581
2023-17, 2023-13 I.R.B. 604
2023-18, 2023-13 I.R.B. 605
2023-19, 2023-13 I.R.B. 626
2023-20, 2023-15 I.R.B. 636
2023-12, 2023-17 I.R.B. 768
2023-15, 2023-18 I.R.B. 806
2023-21, 2023-19 I.R.B. 837
2023-22, 2023-19 I.R.B. 838

Revenue Rulings:
2023-1, 2023-2 I.R.B. 309
2023-3, 2023-6 I.R.B. 448
2023-4, 2023-9 I.R.B. 480
2023-5, 2023-10 I.R.B. 503
2023-6, 2023-14 I.R.B. 627
2023-7, 2023-15 I.R.B. 633
2023-2, 2023-16 I.R.B. 658
2023-8, 2023-18 I.R.B. 801
2023-9, 2023-19 I.R.B. 835

Treasury Decisions:
9970, 2023-2 I.R.B. 311
9771, 2023-3 I.R.B. 346
9772, 2023-11 I.R.B. 530
9773, 2023-11 I.R.B. 557

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2022–27 through 2022–52 is in Internal Revenue Bulletin
2022–52, dated December 27, 2022.
1

May 8, 2023

ii

Bulletin No. 2023–19

Finding List of Current Actions on
Previously Published Items1
Bulletin 2023–19

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2022–27 through 2022–52 is in Internal Revenue Bulletin
2022–52, dated December 27, 2022.
1

Bulletin No. 2023–19

iii

May 8, 2023

Internal Revenue Service
Washington, DC 20224
Official Business
Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue
Bulletins are available at www.irs.gov/irb/.

We Welcome Comments About the Internal Revenue Bulletin

If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it,
we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page
www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave.
NW, IR-6230 Washington, DC 20224.

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3A883a30f103d9da92. Public record. Not legal advice.