# Bulletin No. 2025–25 > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/agency%3Airs%3A9fedc1a82e568a74 ## Record - **Collection:** Agency decision - **Document type:** Agency decision ## Text 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. --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3A9fedc1a82e568a74. Public record. Not legal advice.