Bulletin No. 2025–25

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2025–25

June 16, 2025

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 2025-14, page 1605.

The OPR announces recent disciplinary sanctions imposed

on attorneys, certified public accountants, enrolled agents,

enrolled actuaries, enrolled retirement plan agents, and

appraisers. The OPR also announces when certain unenrolled, unlicensed tax return preparers (individuals who are

not enrolled to practice before the Internal Revenue Service

(IRS) and are not licensed as attorneys or certified public

accountants) have been disciplined. Licensed or enrolled

practitioners are subject to the regulations governing practice before the 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 who choose

to participate in the IRS’s voluntary AFSP are subject to the

guidance in Revenue Procedure 2014-42, which governs 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 participate in

the AFSP agree to be subject to the duties and restrictions in

Circular 230, including the restrictions on incompetence or

disreputable conduct.

EXEMPT ORGANIZATIONS

Announcement 2025-7, page 1600.

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).

Finding Lists begin on page ii.

Announcement 2025-9, page 1601.

The Internal Revenue Service has revoked its determination

that Ballerina Girl qualifies as an organization described in

sections 501(c)(3) and 170(c)(2) of the Internal Revenue

Code of 1986. The revocation is effective July 19, 2019.

Announcement 2025-10, page 1602.

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).

Announcement 2025-11, page 1603.

The Internal Revenue Service has revoked its determination

that AFA Grad Inc. qualifies as an organization described

in sections 501(c)(3) and 170(c)(2) of the Internal Revenue

Code of 1986. The revocation is effective November 7,

2019.

Announcement 2025-12, page 1604.

Golconda Foundation Inc. TIN: 73-1552729 has agreed to

the revocation of its IRC Section 501(c)(3) status effective

January 1, 2020.

TAX CONVENTIONS

Announcement 2025-16, page 1609.

The Competent Authorities of the United States of America

and Denmark entered into a Competent Authority Arrangement under paragraph 3 of Article 25 (Mutual Agreement

Procedure) listing the types of pension entities or arrangements established in either Contracting State that will be

treated as a “pension fund” for purposes of paragraph 3(c)

of Article 10 (Dividends), as well as the application of Article

22 (Limitation on Benefits).

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.

June 16, 2025 

Bulletin No. 2025–25

Part IV

Deletions From Cumulative List of Organizations, Contributions to Which are

Deductible Under Section 170 of the Code

Announcement 2025-7

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 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.

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

February 03, 2025, 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.

Name of Organization

Dove Communications, Inc.

Dove Communications, Inc.

Whomentorsdotcom, Inc.

Whomentorsdotcom, Inc.

Center of New Life Philosophy Church & Education

June 16, 2025

Effective Date of Revocation

1/1/2020

1/1/2020

11/7/2019

11/7/2019

1/1/2020

1600

Location

Cuyahoga Falls, OH

Marion, IL

San Jose, CA

San Francisco, CA

Akron, OH

Bulletin No. 2025–25

Deletions From Cumulative List of Organizations, Contributions to Which are

Deductible Under Section 170 of the Code

Announcement 2025-9

The Internal Revenue Service has revoked its determination that the organization listed below qualifies as an organization 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 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.

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

January 1, 2018 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.

The Following organization is no longer qualified as an organization exempt from income tax under Internal Revenue Code (the

“Code”) Section 501(a) as an organization described in Section 501(c)(3) of the Code:

Name of Organization

Ballerina Girl Inc.

Bulletin No. 2025–25

Effective Date of Revocation

7/29/2019

1601

Location

San Jose CA

June 16, 2025

Deletions From Cumulative List of Organizations, Contributions to Which are

Deductible Under Section 170 of the Code

Announcement 2025-10

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 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.

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

February 18, 2025, 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.

Name of Organization

Effective Date of Revocation

1/01/2020

1/01/2017

1/01/2021

9/01/2019

1/01/2017

1/01/2019

1/01/2021

Praise Place

Live Ministries

Adjusting to Change Lives

Breathing Project Inc.

CA All America Team Inc

Pushmataha County Town of Antlers Hospital Authority

Academy of Fine Art Foundation Inc

June 16, 2025

1602

Location

Kentwood, MI

Rocklin, CA

Pearland, TX

New York, NY

Rocklin, CA

Antler, OK

Anaheim, CA

Bulletin No. 2025–25

Deletions From Cumulative List of Organizations, Contributions to Which are

Deductible Under Section 170 of the Code

Announcement 2025-11

The Internal Revenue Service has revoked its determination that the organization listed below qualifies as an organization 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 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.

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

January 1, 2018 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.

The Following organization is no longer qualified as an organization exempt from income tax under Internal Revenue Code (the

“Code”) Section 501(a) as an organization described in Section 501(c)(3) of the Code:

Name of Organization

AFA Grad Inc.

Bulletin No. 2025–25

Effective Date of Revocation

11/7/2019

1603

Location

San Jose CA

June 16, 2025

Deletions From Cumulative List of Organizations, Contributions to Which are

Deductible Under Section 170 of the Code

Announcement 2025-12

The Internal Revenue Service has revoked its determination that the organization listed below qualifies as an organization 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 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.

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

January 1, 2018, 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.

The Following organization is no longer qualified as an organization exempt from income tax under Internal Revenue Code (the

“Code”) Section 501(a) as an organization described in Section 501(c)(3) of the Code:

Name of Organization

GOLCONDA FOUNDATION INC.

Effective Date of Revocation

1/1/2020

June 16, 2025

1604

Location

JONES, OK

Bulletin No. 2025–25

Announcement of

Disciplinary Sanctions

From the Office of

Professional Responsibility

Announcement 2025-14

The Office of Professional Responsibility (OPR) announces recent disciplinary

sanctions imposed on attorneys, certified public accountants, enrolled agents,

enrolled actuaries, enrolled retirement

plan agents, and appraisers. The OPR also

announces when certain unenrolled, unlicensed tax return preparers (individuals

who are not enrolled to practice before

the Internal Revenue Service (IRS) and

are not licensed as attorneys or certified

public accountants) have been disciplined.

Licensed or enrolled practitioners are subject to the regulations governing practice

before the 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 who choose to

participate in the IRS’s voluntary Annual

Filing Season Program (AFSP) are subject to the guidance in Revenue Procedure

2014-42, which governs 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 participate in the AFSP agree to be

subject to the duties and restrictions in

Circular 230, including the restrictions on

incompetence or disreputable conduct.

The disciplinary sanctions 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 and until

reinstated to practice.

Suspended from practice before the

IRS—An individual who is suspended is

not eligible to practice before the IRS as

defined at 31 C.F.R. § 10.2(a)(4) during

Bulletin No. 2025–25

the term of the suspension and until reinstated to practice.

Censured—Censure is a public reprimand. Unlike disbarment or suspension,

censure does not affect an individual’s eligibility to practice before the IRS, but the

OPR may subject the individual’s future

practice rights to conditions designed to

promote high standards of conduct.

Monetary penalty—A monetary penalty may be imposed on an individual who

engages in conduct subject to sanction, or

on an employer, firm, or other 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.

Additionally, any appraisal made by the

disqualified appraiser after the effective

date of disqualification will not have any

probative effect in any administrative proceeding before the Treasury Department

or the IRS.

Ineligible for limited practice—An

unenrolled/unlicensed tax return preparer

who participates in the AFSP and who fails

to comply with Circular 230 as required

by Revenue Procedure 2014-42 may have

their AFSP credential revoked and may be

determined ineligible to engage in future

limited practice under the program as a

representative of a taxpayer.

Under the regulations, individuals

subject to Circular 230 may not assist, or

accept assistance from, individuals who

are suspended or disbarred with respect

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

not aid or abet suspended or disbarred

individuals to practice before the IRS.

Disciplinary sanctions are described in

these terms:

Disbarred by decision, Suspended by

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

Disqualified by decision (including after

a hearing)—An administrative law judge

(ALJ), upon the OPR’s complaint alleging violation of the regulations, issued a

decision imposing one of these sanctions

after the ALJ either (1) granted the government’s motion for summary adjudication or (2) after conducting an evidentiary

1605

hearing. After 30 days from the issuance

of the decision, in the absence of an

appeal, the ALJ’s decision becomes the

final agency decision.

Disbarred by default decision, Suspended by default decision, Censured

by default decision, Monetary penalty imposed by default decision, and

Disqualified by default decision—An

ALJ, after finding that no answer to the

OPR’s complaint was filed or timely filed,

granted the OPR’s motion for a default

judgment and issued a decision imposing

one of these sanctions.

Disbarred by decision on appeal,

Suspended by decision on appeal, Censured by decision on appeal, Monetary penalty imposed by decision on

appeal, and Disqualified by decision

on appeal—The decision of the ALJ was

appealed to the agency’s appellate authority, acting as the delegate of the Secretary

of the Treasury, and the appellate authority issued a decision imposing one of these

sanctions.

Disbarred by consent, Suspended by

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

Disqualified by consent—In lieu of a

disciplinary proceeding being instituted or

continued, an individual offered their consent to one of these sanctions (or a firm or

other entity offered to consent to a monetary penalty) and the OPR accepted the

offer and the parties entered into a consent

agreement. Typically, an offer of consent

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

must observe during the suspension; and

the individual’s opportunity, after a stated

number of months, to file with the OPR

a petition for reinstatement affirming

compliance with the terms of the consent

agreement and affirming current fitness

and eligibility to practice (i.e., an active

professional license or active enrollment

status, with no intervening violations of

the regulations).

Suspended indefinitely by decision

in expedited proceeding, Suspended

indefinitely by default decision in expedited proceeding—The OPR instituted

an expedited proceeding for suspension

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

and criminal convictions) that resulted in

suspension.

June 16, 2025

Determined ineligible for limited

practice—There has been a final determination under Revenue Procedure 2014-42

that an unenrolled/unlicensed tax return

preparer is not eligible for continued limited representation of taxpayers because

the preparer violated standards of conduct prescribed in Circular 230 or failed

to comply with any of the requirements

described in the revenue procedure.

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, suspension, or disqualification (or immediately

following the expiration of the suspension

or disqualification period if shorter than 5

years). Reinstatement will not be granted

unless the IRS is satisfied that the petitioner is not likely to engage thereafter in

conduct contrary to Circular 230, and that

granting such reinstatement would not be

contrary to the public interest.

Reinstatement decisions are published

at the individual’s request, and described

in these terms:

Reinstated to practice before the

IRS—The OPR granted the individual’s

petition for reinstatement. The individual

is eligible to practice before the IRS, or in

the case of an appraiser, the individual is

no longer disqualified.

The OPR has authority to disclose the

grounds for disciplinary sanctions in these

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

delegate on appeal has issued a final decision imposing a sanction; (2) the individual

has settled a disciplinary case by signing

the OPR’s consent-to-sanction agreement

admitting to one or more violations of the

regulations and consenting to the disclosure of the admitted violations (for example, willful failure to file Federal income

tax returns, lack of due diligence, conflict

of interest, etc.); (3) that the OPR has

issued a decision in an expedited proceeding for indefinite suspension; or (4) upon a

final determination (including any decision

on appeal) that an unenrolled/unlicensed

return preparer is no longer eligible to represent taxpayers before the IRS under Revenue Procedure 2014-42.

Announcements of disciplinary sanctions appear in the Internal Revenue Bulletin at the earliest practicable date. The

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

names of the sanctioned individuals.

City & State

Name

Professional

Designation

Disciplinary Sanction

Effective Date(s)

California

Agoura Hills

Fulton, William E.

Enrolled Agent

Indefinite from

March 18, 2025

Westlake Village

Englander, Mark L.

CPA

Westlake Village

Knauss III, Walter W.

CPA

Suspended by consent for

admitted violations of

31 C.F.R. § 10.82(b)(2)

Suspended by consent for

admitted violations of

31 C.F.R. § 10.51(a)(6)

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Connecticut

Berlin

Schwartz, Scott M.

Attorney

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

March 18, 2025

Tampa

Kalish, William

Attorney

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

October 21, 2024

Georgia

Duluth

Tuggle, Nevada M.

Attorney

Indefinite from

March 18, 2025

Forest Park

Tomasello, William B.

CPA

Woodstock

Smith, Victor C.

CPA

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

October 1, 2024

Indefinite from

December 4, 2024

Florida

June 16, 2025

1606

Indefinite from

January 21, 2025

Indefinite from

January 21, 2025

Bulletin No. 2025–25

City & State

Name

Professional

Designation

Disciplinary Sanction

Effective Date(s)

Hawaii

Hilo

Slone, Michele K.

Enrolled Agent

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

March 18, 2025

Illinois

Champaign

Peek, Matthew E.

Attorney

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

March 18, 2025

Indiana

Modoc

Harman, Michael M.

CPA

Indefinite from

November 20, 2024

Seymour

Smith, Jason M.

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)

Massachusetts

Burlington

Kim, Christine K.

Enrolled Agent

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

November 20, 2024

Mississippi

Raymond

Gordon, Charisse C.

Attorney

Suspended by decision in

expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

February 18, 2025

Missouri

Saint Joseph

Tillmon III, William R.

CPA

Indefinite from

November 10, 2024

Saint Louis

Chollet, Catherine E.

Attorney

Suspended by consent for

admitted violations of

31 C.F.R. § 10.82(b)

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

New York

Bronx

Johnson, Kimberly

CPA

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

November 14, 2024

New City

Klein, Mitchell L.

CPA

Scarsdale

Sanossian, George O.

CPA

North Carolina

Fayetteville

Cooper Jr., Willie

CPA

Bulletin No. 2025–25

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

October 21, 2024

Indefinite from

March 27, 2025

Reinstated to

practice before the

IRS, effective July

22, 2024

Indefinite from

March 11, 2025

Reinstated to

practice before

the IRS, effective

January 8, 2025

1607

June 16, 2025

City & State

Name

Professional

Designation

Disciplinary Sanction

Effective Date(s)

Oregon

Portland

Magee, Peter J.

CPA

Suspended by decision in

expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

January 21, 2025

Pennsylvania

Punxsutawney

Stello, Michael A.

CPA

Suspended by consent for

admitted violations of

31 C.F.R. § 10.51(a)(6)

Indefinite from

February 28, 2025

Texas

Dallas, TX

Malphurs, Robert A.

CPA

Indefinite from

December 4, 2024

Mansfield

Castro, John A.

Enrolled Agent

San Antonio

Schmitz, Keith M.

Enrolled Agent

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)

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

West Virginia

Harpers Ferry, WV

Jordan, George W.

CPA

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

December 4, 2024

June 16, 2025

1608

Indefinite from

March 27, 2025

Indefinite from

March 11, 2025

Bulletin No. 2025–25

U.S.-Denmark Competent Authority Arrangement

Announcement 2025-16

The following is a copy of the Competent Authority Arrangement entered into by the competent authorities of the United States of

America and the Kingdom of Denmark under paragraph 3 of Article 25 (Mutual Agreement Procedure) of the Convention between

the Government of the United States of America and the Government of the Kingdom of Denmark for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income signed at Washington on August 19, 1999, as amended

by the protocol signed at Copenhagen on May 2, 2006, with respect to the types of pension entities or arrangements established in

either Contracting State that will be treated as a “pension fund” for purposes of paragraph 3(c) of Article 10 (Dividends), as well as

the application of Article 22 (Limitation on Benefits).

The text of the Competent Authority Arrangement is as follows:

COMPETENT AUTHORITY ARRANGEMENT

The competent authorities of the United States and Denmark hereby enter into the following arrangement (the “Arrangement”)

regarding the types of pension entities or arrangements established in either Contracting State that will be treated as a “pension fund”

for purposes of paragraph 3(c) of Article 10 (Dividends), as well as the application of Article 22 (Limitation on Benefits) of the Convention between the Government of the United States of America and the Government of the Kingdom of Denmark for the Avoidance

of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income signed at Washington on August 19, 1999

(the “Treaty”), as amended by the protocol signed at Copenhagen on May 2, 2006 to those entities or arrangements. This Arrangement

is entered into under paragraph 3 of Article 25 (Mutual Agreement Procedure).

It is understood for purposes of this Arrangement that the term “Article” refers to an Article of the Treaty.

Qualification for benefits under Article 10(3)

Article 10(3)(c) provides that dividends shall not be taxed in the Contracting State of which the company paying the dividends is

a resident if the beneficial owner is a pension fund, which is described in subparagraph e) of paragraph 2 of Article 22 (Limitation

of Benefits), that is a resident of the other Contracting State, provided that such dividends are not derived from the carrying on of a

business by the pension fund or through an associated enterprise.

Article 22(2)(e) provides that a resident of a Contracting State shall be entitled to all the benefits of this Convention only if such

resident is a legal person, whether or not exempt from tax, organized under the laws of a Contracting State to provide a pension or

other similar benefits to employees, including self-employed individuals, pursuant to a plan, provided that more than 50 percent of

the person’s beneficiaries, members or participants are individuals resident in either Contracting State.

The competent authorities agree the term “pension fund” as defined in paragraph 3(c) of Article 10 (Dividends) by reference to legal

persons described in paragraph 2(e) of Article 22 (Limitation on Benefits) includes the following, for the purposes of both paragraphs:

1. Danish pension funds:

Provided that, with the exception of pension entities or arrangements described in paragraph (b) below, more than 50 percent of the

person’s beneficiaries, members or participants are individuals resident in either Denmark or the United States:

a)

Pension institutions liable to taxation under Section 1 (2), of the Danish Pension Investment Return Tax Act.

b) Account Holding Investment Funds under Section 2 in the Account Holding Investments Funds tax act provided that it is operated exclusively or almost exclusively to earn income for the benefit of persons described in paragraph 1. (a) above that are

themselves entitled to benefits under the Treaty as a resident of Denmark.

2. U.S pension funds:

Provided that, with the exception of pension entities or arrangements described in paragraph (j) below, more than 50 percent of the

person’s beneficiaries, members or participants are individuals resident in either the United States or Denmark:

Bulletin No. 2025–25

1609

June 16, 2025

a)

b)

c)

d)

e)

f)

g)

h)

i)

j)

A trust providing pension or retirement benefits under an Internal Revenue Code (“Code”) section 401(a) qualified pension plan

(which includes a Code section 401(k) plan) and a profit sharing or stock bonus plan;

A Code section 403(a) qualified annuity plan;

A Code section 403(b) plan,

A trust that is an individual retirement account under Code section 408;

A Roth individual retirement account under Code section 408A;

A simple retirement account under Code section 408(p);

A trust providing pension or retirement benefits under a simplified employee pension plan under Code section 408(k);

A trust described in Code section 457(g) providing pension or retirement benefits under a Code section 457(b) plan;

The Thrift Savings Fund (Code section 7701(j)); and

A group trust described in Revenue Ruling 81-100, as amended by Revenue Ruling 2014-24 and Revenue Ruling 2011-1, but

only if it is operated exclusively or almost exclusively to earn income for the benefit of persons described in paragraphs 2.(a)

through 2.(i) that are themselves entitled to benefits under the Treaty as a resident of the United States.

Any U.S. or Danish pension entity or arrangement of a type not mentioned above, including any type of pension entity or arrangement

established pursuant to legislation enacted after the date of signature of this Arrangement, or any participant in a type of plan not

mentioned above, may present its case to the U.S. and Danish Competent Authorities pursuant to paragraph 3 of Article 25 (Mutual

Agreement Procedure) for a determination of whether the pension entity or arrangement is considered a pension fund eligible for

benefits under paragraph 3(c) of Article 10, provided it has also satisfied all additional applicable requirements set forth in the Treaty.

Effective Date

Upon signature by the U.S. and Danish competent authorities, this Arrangement is effective for dividends paid on or after February

1, 2008.

Signed by the undersigned competent authorities:

/s/ Holly O. Paz

Holly O. Paz

United States Competent Authority

/s/ Helene Holmen

Helene Holmen

Head of Office,

Danish Competent Authority in non-TP cases

Date: March 18, 2025

Date: March 25, 2025

June 16, 2025

1610

Bulletin No. 2025–25

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.

Bulletin No. 2025–25

ER—Employer.

ERISA—Employee Retirement Income Security Act.

EX—Executor.

F—Fiduciary.

FC—Foreign Country.

FICA—Federal Insurance Contributions Act.

FISC—Foreign International Sales Company.

FPH—Foreign Personal Holding Company.

F.R.—Federal Register.

FUTA—Federal Unemployment Tax Act.

FX—Foreign corporation.

G.C.M.—Chief Counsel’s Memorandum.

GE—Grantee.

GP—General Partner.

GR—Grantor.

IC—Insurance Company.

I.R.B.—Internal Revenue Bulletin.

LE—Lessee.

LP—Limited Partner.

LR—Lessor.

M—Minor.

Nonacq.—Nonacquiescence.

O—Organization.

P—Parent Corporation.

PHC—Personal Holding Company.

PO—Possession of the U.S.

PR—Partner.

i

PRS—Partnership.

PTE—Prohibited Transaction Exemption.

Pub. L.—Public Law.

REIT—Real Estate Investment Trust.

Rev. Proc.—Revenue Procedure.

Rev. Rul.—Revenue Ruling.

S—Subsidiary.

S.P.R.—Statement of Procedural Rules.

Stat.—Statutes at Large.

T—Target Corporation.

T.C.—Tax Court.

T.D.—Treasury Decision.

TFE—Transferee.

TFR—Transferor.

T.I.R.—Technical Information Release.

TP—Taxpayer.

TR—Trust.

TT—Trustee.

U.S.C.—United States Code.

X—Corporation.

Y—Corporation.

Z—Corporation.

June 16, 2025

Numerical Finding List1

Bulletin 2025–25

Announcements:

2025-2, 2025-2 I.R.B. 305

2025-3, 2025-2 I.R.B. 306

2025-4, 2025-2 I.R.B. 306

2025-1, 2025-3 I.R.B. 431

2025-5, 2025-3 I.R.B. 433

2025-6, 2025-5 I.R.B. 526

2025-8, 2025-13 I.R.B. 1384

2025-13, 2025-15 I.R.B. 1392

2025-15, 2025-18 I.R.B. 1420

2025-7, 2025-25 I.R.B. 1600

2025-9, 2025-25 I.R.B. 1601

2025-10, 2025-25 I.R.B. 1602

2025-11, 2025-25 I.R.B. 1603

2025-12, 2025-25 I.R.B. 1604

2025-14, 2025-25 I.R.B. 1605

2025-16, 2025-25 I.R.B. 1609

Notices:

2025-1, 2025-3 I.R.B. 415

2025-2, 2025-3 I.R.B. 418

2025-4, 2025-3 I.R.B. 419

2025-5, 2025-3 I.R.B. 426

2025-3, 2025-4 I.R.B. 488

2025-7, 2025-5 I.R.B. 524

2025-9, 2025-6 I.R.B. 681

2025-10, 2025-6 I.R.B. 682

2025-11, 2025-6 I.R.B. 704

2025-13, 2025-6 I.R.B. 710

2025-6, 2025-8 I.R.B. 799

2025-8, 2025-8 I.R.B. 800

2025-12, 2025-8 I.R.B. 813

2025-14, 2025-10 I.R.B. 980

2025-15, 2025-11 I.R.B. 1089

2025-16, 2025-13 I.R.B. 1378

2025-17, 2025-14 I.R.B. 1387

2025-18, 2025-16 I.R.B. 1416

2025-19, 2025-17 I.R.B. 1418

2025-20, 2025-19 I.R.B. 1423

2025-21, 2025-19 I.R.B. 1424

2025-22, 2025-19 I.R.B. 1427

2025-23, 2025-19 I.R.B. 1428

2025-24, 2025-19 I.R.B. 1429

2025-25, 2025-20 I.R.B. 1445

2025-26, 2025-20 I.R.B. 1445

2025-29, 2025-20 I.R.B. 1445

Proposed Regulations:

REG-117213-24, 2025-3 I.R.B. 433

REG-134420-10, 2025-4 I.R.B. 513

REG-105479-18, 2025-5 I.R.B. 527

REG-116610-20, 2025-5 I.R.B. 638

REG-115560-23, 2025-6 I.R.B. 716

Proposed Regulations:—Continued

REG-123525-23, 2025-6 I.R.B. 726

REG-124930-21, 2025-7 I.R.B. 772

REG‑100669‑24, 2025-8 I.R.B. 819

REG-101268-24, 2025-8 I.R.B. 836

REG-107420-24, 2025-8 I.R.B. 854

REG-116085-23, 2025-8 I.R.B. 865

REG-118988-22, 2025-8 I.R.B. 869

REG-107895-24, 2025-9 I.R.B. 972

REG-110878-24, 2025-9 I.R.B. 979

REG-112261-24, 2025-10 I.R.B. 983

10022, 2025-8 I.R.B. 773

10026, 2025-9 I.R.B. 878

10027, 2025-9 I.R.B. 897

10029, 2025-9 I.R.B. 936

10030, 2025-11 I.R.B. 1066

10024, 2025-12 I.R.B. 1104

10023, 2025-13 I.R.B. 1259

Revenue Procedures:

2025-1, 2025-1 I.R.B. 1

2025-2, 2025-1 I.R.B. 118

2025-3, 2025-1 I.R.B. 142

2025-4, 2025-1 I.R.B. 158

2025-5, 2025-1 I.R.B. 260

2025-7, 2025-1 I.R.B. 301

2025-8, 2025-3 I.R.B. 427

2025-9, 2025-4 I.R.B. 491

2025-10, 2025-4 I.R.B. 492

2025-11, 2025-4 I.R.B. 501

2025-12, 2025-4 I.R.B. 512

2025-6, 2025-6 I.R.B. 713

2025-14, 2025-7 I.R.B. 770

2025-13, 2025-8 I.R.B. 816

2025-15, 2025-11 I.R.B. 1090

2025-16, 2025-11 I.R.B. 1100

2025-17, 2025-13 I.R.B. 1382

2025-18, 2025-19 I.R.B. 1430

2025-19, 2025-21 I.R.B. 1447

2025-20, 2025-22 I.R.B. 1448

2025-21, 2025-22 I.R.B. 1448

2025-23, 2025-24 I.R.B. 1476

Revenue Rulings:

2025-1, 2025-3 I.R.B. 307

2025-2, 2025-3 I.R.B. 309

2025-3, 2025-4 I.R.B. 443

2025-4, 2025-7 I.R.B. 758

2025-5, 2025-7 I.R.B. 767

2025-6, 2025-11 I.R.B. 1064

2025-7, 2025-13 I.R.B. 1239

2025-8, 2025-15 I.R.B. 1390

2025-9, 2025-16 I.R.B. 1415

2025-10, 2025-19 I.R.B. 1421

2025-11, 2025-23 I.R.B. 1451

2025-12, 2025-23 I.R.B. 1471

Treasury Decisions:

10016, 2025-3 I.R.B. 313

10020, 2025-3 I.R.B. 408

10018, 2025-4 I.R.B. 446

10019, 2025-4 I.R.B. 482

10017, 2025-5 I.R.B. 517

10028, 2025-6 I.R.B. 660

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2024–27 through 2024–52 is in Internal Revenue Bulletin

2024–52, dated December 23, 2024.

1

June 16, 2025

ii

Bulletin No. 2025–25

Finding List of Current Actions on

Previously Published Items1

Bulletin 2025–25

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2024–27 through 2024–52 is in Internal Revenue Bulletin

2024–52, dated December 23, 2024.

1

Bulletin No. 2025–25

iii

June 16, 2025

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.