These synopses are intended only as aids to the reader in

HIGHLIGHTS

OF THIS ISSUE

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

T.D. 10011, page 1177.

This Treasury Decision modernizes regulations regarding the

sale of a taxpayer’s property that the IRS seizes by levy. The

final regulations allow the IRS to maximize sale proceeds for

the benefit of the taxpayer whose property the IRS has seized

and the public fisc. The final regulations affect all sales of property the IRS seizes by levy.

Finding Lists begin on page ii.





Bulletin No. 2024–48

November 25, 2024

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 Unpublished rulings will not be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.

November 25, 2024 

Bulletin No. 2024–48

Part I

26 CFR 301.6335-1

T.D. 10011

DEPARTMENT OF THE

TREASURY

Internal Revenue Service

26 CFR Part 301

Modernizing Regulations

on Sales of Seized Property

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Final regulation.

SUMMARY: This document contains

final regulations regarding the sale of a

taxpayer’s property that the IRS seizes by

levy. The final regulations amend existing regulations to better allow the IRS to

maximize sale proceeds for the benefit of

the taxpayer whose property the IRS has

seized and the public fisc. The final regulations affect all sales of property the IRS

seizes by levy.

DATES: Effective date: These regulations

are effective November 5, 2024.

Applicability date: For date of applicability, see §301.6335-1(f).

FOR FURTHER INFORMATION

CONTACT: Micah A. Levy, (202) 3176832 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Authority

This document contains amendments

to the Procedure and Administration Regulations (26 CFR part 301) issued by the

Secretary of the Treasury or her delegate

(Secretary) under the authority granted

by sections 6335(e)(2) and 7805(a) of the

Internal Revenue Code regarding the sale

of property that is seized by levy by the

IRS (seized property).

Section 6335(e)(2) provides an

express delegation of authority, stating

Bulletin No. 2024–48

that the Secretary shall by regulations

prescribe the manner and other conditions of the sale of property seized by

levy. If one or more alternative methods

or conditions are permitted by regulations, the Secretary shall select the alternatives applicable to the sale. Sections

6335(e)(2)(A) through (F) expressly provide that such regulations shall provide:

(i) that the sale shall not be conducted

in any manner other than by public auction or by public sale under sealed bids;

(ii) in the case of the seizure of several

items of property, whether such items

shall be offered separately, in groups, or

in the aggregate and whether such property shall be offered both separately (or

in groups) and in the aggregate, and sold

under whichever method produces the

highest aggregate amount; (iii) whether

the announcement of the minimum price

determined by the Secretary may be

delayed until the receipt of the highest

bid; (iv) whether payment in full shall be

required at the time of acceptance of a

bid, or whether a part of such payment

may be deferred for such period (not to

exceed 1 month) as may be determined

by the Secretary to be appropriate; (v)

the extent to which methods (including

advertising) in addition to those prescribed in section 6335(b) may be used

in giving notice of the sale; and (vi)

under what circumstances the Secretary

may adjourn the sale from time to time

(but such adjournments shall not be for a

period to exceed in all 1 month).

Finally, section 7805(a) authorizes the

Secretary to “prescribe all needful rules

and regulations for the enforcement of

[the Code], including all rules and regulations as may be necessary by reason of

any alteration of law in relation to internal

revenue.”

Background

On October 16, 2023, the Department

of the Treasury (Treasury Department)

and the IRS published in the Federal

Register (88 FR 71323) a notice of proposed rulemaking (REG-127391-16) proposing amendments to regulations under

26 CFR part 301 (proposed regulations).

1177

The proposed regulations conformed the

prescribed manner and conditions of sales

of seized property with modern practices. The proposed amendments included

changes to facilitate online sales, give

greater flexibility in grouping property

and specifying terms of payment, and provide clarity to the IRS in making decisions

about which employees can be assigned to

conduct sales or perform related ministerial duties. See the Explanation of Provisions section of REG-127391-16 at 88

FR 71324 -71326 for a discussion of the

proposed regulations.

The Treasury Department and the IRS

received one comment in response to the

notice of proposed rulemaking, but the

comment did not address the proposed

regulations. The comment is available

at https://www.regulations.gov or upon

request. No public hearing was requested

or held on the proposed regulations. These

final regulations therefore adopt the text of

the proposed regulations with only minor,

nonsubstantive changes.

Special Analyses

I. Regulatory Planning and Review

Pursuant to the Memorandum of Agreement, Review of Treasury Regulations

under Executive Order 12866 (June 9,

2023), tax regulatory actions issued by the

IRS are not subject to the requirements of

section 6(b) of Executive Order 12866, as

amended. Therefore, a regulatory impact

assessment is not required.

II. Regulatory Flexibility Act

Pursuant to the Regulatory Flexibility

Act (5 U.S.C. chapter 6), it is hereby certified that this regulation will not have a significant economic impact on a substantial

number of small entities. This certification

is based on the fact that the regulations

solely conform the prescribed manner and

conditions of sales of seized property with

modern practices by making the sales process both more efficient and more likely to

produce higher sales prices.

Pursuant to section 7805(f) of the

Code, the notice of proposed rulemaking

November 25, 2024

preceding these regulations was submitted to the Chief Counsel for the Office of

Advocacy of the Small Business Administration for comment on its impact on

small business, and no comments were

received.

III. Unfunded Mandates Reform Act

Section 202 of the Unfunded Mandates

Reform Act of 1995 (UMRA) requires that

agencies assess anticipated costs and benefits and take certain other actions before

issuing a final rule that includes any Federal mandate that may result in expenditures in any one year by a State, local, or

Tribal government, in the aggregate, or by

the private sector, of $100 million in 1995

dollars, updated annually for inflation.

These final regulations do not include any

Federal mandate that may result in expenditures by State, local, or Tribal governments, or by the private sector in excess of

that threshold.

IV. Executive Order 13132: Federalism

Executive Order 13132 (Federalism)

prohibits an agency from publishing any

rule that has federalism implications if

the rule either imposes substantial, direct

compliance costs on State and local governments, and is not required by statute,

or preempts State law, unless the agency

meets the consultation and funding

requirements of section 6 of the Executive

Order. These final regulations do not have

federalism implications and do not impose

substantial direct compliance costs on

State and local governments or preempt

State law within the meaning of the Executive Order.

V. Congressional Review Act

Pursuant to the Congressional Review

Act (5 U.S.C. 801 et seq.), the Office of

Information and Regulatory Affairs designated this rule as not a major rule, as

defined by 5 U.S.C. 804(2).

Drafting Information

The principal author of these regulations is Micah A. Levy, Office of the

Associate Chief Counsel (Procedure and

Administration). However, other person-

November 25, 2024

nel from the Treasury Department and the

IRS participated in the development of the

regulations.

List of Subjects in 26 CFR Part 301

Employment taxes, Estate taxes,

Excise taxes, Gift taxes, Income taxes,

Penalties, Reporting and recordkeeping

requirements.

Adoption of Amendments to the

Regulations

Accordingly, the Treasury Department

and the IRS amend 26 CFR part 301 as

follows:

PART 301—PROCEDURE AND

ADMINISTRATION

Paragraph 1. The authority citation

for part 301 is amended by adding an

entry for §301.6335-1 in numerical order

to read in part as follows:

Authority: 26 U.S.C. 7805.

*****

Section 301.6335-1 also issued under

26 U.S.C. 6335(e)(2).

*****

Par. 2. Section 301.6335-1 is amended

by:

1. Redesignating paragraphs (a)

through (d) as paragraphs (b) through (e),

respectively;

2. Adding a new paragraph (a);

3. Revising newly designated paragraphs (b) and (c)(1) and (2);

4. Adding a subject heading to newly

redesignated paragraph (c)(3);

5. Revising newly redesignated paragraphs (d)(1) and (2) and (d)(3)(i) and (ii);

6. Removing newly redesignated paragraph (d)(3)(iii);

7. Revising newly redesignated paragraph (d)(4)(iii);

8. Removing newly redesignated paragraph (d)(4)(iv);

9. Revising newly redesignated paragraphs (d)(5)(i), (ii), and (iv) and (d)(6),

(7), and (9);

10. Adding paragraph (d)(11);

11. Revising newly redesignated paragraphs (e)(1) and (3); and

12. Adding paragraph (f).

The additions and revisions read as follows:

1178

§301.6335-1 Sale of seized property.

(a) In general. Section 6335 of the

Internal Revenue Code (Code) and this

section provide the rules under which the

Internal Revenue Service (IRS) conducts

sales of property seized by levy.

(b) Notice of seizure—(1) Issuance

and delivery. As soon as practicable after

seizure of property, the IRS must give

written notice to the property’s owner (or,

in the case of personal property, to the

property’s possessor). The written notice

must be delivered to the owner (or to the

possessor, in the case of personal property) or left at the owner’s usual place of

abode or business if there is such within

the internal revenue district in which

the seizure is made. If the owner cannot

be readily located or has no dwelling or

place of business within such district,

the notice may be mailed to the owner’s

last known address. For purposes of this

section, the term internal revenue district

means an internal revenue district within

the meaning of section 7621 of the Code

and includes an IRS field collection territory or other successor IRS subdivision or

office.

(2) Contents. The notice of seizure

must specify the sum demanded and contain, in the case of personal property, a list

sufficient to identify the property seized

and, in the case of real property, a description with reasonable certainty of the property seized.

(c) * * *

(1) In general. As soon as practicable after seizure of the property, the

IRS must give notice of sale in writing

to the owner. Such notice will be delivered to the owner or left at the owner’s usual place of abode or business if

located within the internal revenue district in which the seizure is made. If the

owner cannot be readily located or has

no dwelling or place of business within

such district, the notice may be mailed

to the owner’s last known address. For

further guidance regarding the definition

of last known address, see §301.6212–2.

The notice must specify the property to

be sold, and the time, place, manner, and

conditions of the sale thereof, and must

expressly state that only the right, title,

and interest of the delinquent taxpayer in

and to such property is to be offered for

Bulletin No. 2024–48

sale. The notice will also be published in

some newspaper published in the county

wherein the seizure is made or in a newspaper generally circulated in that county.

For example, if a newspaper of general

circulation in a county but not published

in that county will reach more potential

bidders for the property to be sold than a

newspaper published within the county,

or if there is a newspaper of general circulation within the county but no newspaper published within the county, the

IRS may publish the notice of sale in the

newspaper of general circulation within

the county. If there is no newspaper

published or generally circulated in the

county, the notice will be posted at the

post office nearest the place where the

seizure is made, to the extent authorized

under law, and in not less than two other

public places.

(2) Alternative methods. The IRS may

use other methods of giving notice of

sale and of advertising seized property, in

addition to those referred to in paragraph

(c)(1) of this section, if the IRS believes

that the nature of the seized property to be

sold is such that a wider or more specialized advertising coverage will enhance the

possibility of obtaining a higher price for

the seized property.

(3) Exception. * * *

(d) * * *

(1) Time and place of sale. The sale

will be held at the time and place stated

in the notice of sale. The time of sale will

not be less than 10 days nor more than 40

days from the time of giving public notice

under section 6335(b) of the Code and

paragraph (c) of this section. The place of

an in-person sale will be within the county

in which the property is seized, except

such sale may be held at a place outside

that county if the IRS determines, by special order of a delegated official, that substantially higher bids may be obtained for

the property by holding the sale in such

other county. The place of an online sale

will generally be the county in which the

property is seized. If, based on the facts

and circumstances, the IRS determines

that the place of an online sale is not

within the county in which the property is

seized, the sale may be conducted online

by special order when doing so would be

more efficient or would likely result in

more competitive bids.

Bulletin No. 2024–48

(2) Adjournment of sale. When it

appears that an adjournment of the sale

will best serve the interest of the United

States or that of the taxpayer, the IRS may

adjourn the sale from time to time, but the

date of the sale will not be later than one

month after the date fixed in the original

notice of sale.

(3) * * *

(i) Minimum price. Before the sale

of property seized by levy, the IRS will

determine a minimum price, taking into

account the expenses of levy and sale, for

which the property must be sold. The IRS

will either announce the minimum price

before the sale begins or defer announcement of the minimum price until after the

receipt of the highest bid, in which case,

if the highest bid is greater than the minimum price, no announcement of the minimum price will be made.

(ii) Purchase by the United States.

Before the sale of seized property, the

IRS will determine whether the purchase

of the property by the United States at

the minimum price would be in the best

interest of the United States. In determining whether the purchase of the property

would be in the best interest of the United

States, the IRS may consider all relevant

facts and circumstances including, for

example—

(A) Marketability of property;

(B) Cost of maintaining the property;

(C) Cost of repairing or restoring the

property;

(D) Cost of transporting the property;

(E) Cost of safeguarding the property;

(F) Cost of potential toxic waste

cleanup; and

(G) Other factors pertinent to the type

of property.

(4) * * *

(iii) Release to owner. If the property

is not declared to be sold under paragraph

(d)(4)(i) or (ii) of this section, the property

will be released to the owner of the property and the expense of the levy and sale

will be added to the amount of tax for the

collection of which the United States made

the levy. Any property released under this

paragraph (d)(4)(iii) will remain subject to

any lien imposed by subchapter C of chapter 64 of subtitle F of the Code.

(5) * * *

(i) Sale of indivisible property. If any

property levied upon is not divisible, so as

1179

to enable the IRS by sale of a part thereof

to raise the whole amount of the tax and

expenses of levy and sale, the whole of

such property will be sold. For application

of surplus proceeds of sale, see section

6342(b) of the Code.

(ii) Separately, in groups, or in the

aggregate. The IRS, in selecting how

seized property will be offered for sale,

will consider which method is likely to

produce the highest total sales price as

well as which method is most feasible.

The seized property may be offered for

sale—

(A) As separate items,

(B) As groups of items,

(C) In the aggregate, or

(D) Both as separate items (or in

groups) and in the aggregate, in which

case, the property will be sold under the

method that produces the highest aggregate amount.

*****

(iv) Terms of payment. The property

will be offered for sale in accordance with

whichever of the following terms is fixed

by the IRS in the public notice of sale:

(A) Payment in full upon acceptance of

the highest bid, or

(B) An initial payment upon acceptance of the highest bid if the payment is

in the amount (either the dollar amount

or the percentage of the purchase price)

specified in the notice of sale and followed

by payment of the balance (including all

costs incurred for the protection or preservation of the property subsequent to the

sale and prior to final payment) within a

specified period, not to exceed one month

from the date of the sale.

(6) Method of sale and sale procedures.

The IRS will sell the property either at a

public auction (at which open competitive

bids will be received) or at a public sale

under sealed bids.

(i) Invitation to bidders. Bids will be

solicited through a public notice of sale.

(ii) Form for use by bidders. A bid must

be submitted in the manner specified by

the IRS in the notice of sale or in instructions referenced by that notice.

(iii) Remittance with bid. The notice

of sale, or instructions referenced in the

notice, will specify the initial payment

amount, acceptable forms of the remittance (such as check, credit or debit card,

electronic payment, or other means), and

November 25, 2024

the address (physical or online) at which

the bid and remittance must be submitted.

(iv) Time for receiving bids. A bid will

not be considered unless it is received in

the manner and before the time specified

in the notice of sale, instructions referenced in the notice, or in the announcement of the adjournment of the sale.

(v) Consideration of bids. The public notice of sale will specify whether

the property is to be sold separately, by

groups, or in the aggregate, or by a combination of these methods, as provided in

paragraph (d)(5)(ii) of this section. If the

notice, or instructions referenced in the

notice, specifies an alternative method,

bidders may submit bids under one or

more of the alternatives. In case of error

in computing the total price of a group of

property in any bid, the unit price of each

piece of property will control. The IRS has

the right to waive any technical defects in

a bid. A technical defect in a bid is deemed

waived if the IRS treats it as the winning

bid. In the event two or more highest bids

are equal in amount, the IRS will reopen

the bidding until a high bid is submitted

without any ties. After the opening, examination, and consideration of all bids, the

IRS will announce the amount of the highest bid or bids and the name of the successful bidder or bidders. Any remittance

submitted in connection with an unsuccessful bid will be returned at the conclusion of the sale.

(vi) Withdrawal of bids. A bid may be

withdrawn only in the manner specified

in the notice of sale or in instructions referenced in the notice. A technical defect

in a bid confers no right on the bidder for

the withdrawal of the bid after it has been

opened or accepted.

(7) Payment of bid price. All payments

for property sold under this section must

be made in the form and manner (whether

by check, credit or debit card, electronic

November 25, 2024

payment, or other means) specified by

the IRS in the public notice of sale or in

instructions referenced in the notice. If

payment in full is required upon acceptance of the highest bid, the payment must

be made at the time and in accordance with

the terms specified in the notice of sale. If

deferred payment is permitted, the initial

payment must be made upon acceptance

of the bid at the time and in accordance

with the terms specified in the notice of

sale, and the balance must be paid on or

before the date fixed for payment thereof.

Any remittance submitted with a successful bid will be applied toward the purchase

price.

*****

(9) Default in payment. If payment in

full is required upon acceptance of the

bid and is not paid when due, the IRS will

proceed again to sell the property in the

manner provided in section 6335(e) of the

Code and this section. If the conditions

of the sale permit part of the payment to

be deferred, and if such part is not paid

within the prescribed period, suit may be

instituted against the purchaser for the

purchase price or such part thereof as

has not been paid, together with interest

at the rate of six percent per annum from

the date of the sale; or, in the discretion of

the IRS, the sale may be declared null and

void for failure to make full payment of

the purchase price and the property may

again be advertised and sold as provided

in section 6335(b), (c), and (e) of the Code

and this section. In the event of such readvertisement and sale, any new purchaser

will receive such property or rights to

property free and clear of any claim or

right of the former defaulting purchaser,

of any nature whatsoever, and the amount

paid upon the bid price by such defaulting

purchaser will be forfeited to the United

States.

*****

1180

(11) Participation in sale by revenue

officers. No revenue officer who seized

the property to be sold at a sale conducted

under section 6335 of the Code and this

section may participate in the sale of that

seized property. This restriction does not

apply to sales of perishable goods conducted under section 6336 of the Code.

(e) * * *

(1) In general. The owner of any property seized by levy may request that the

IRS sell such property within 60 days after

such request, or within any longer period

specified by the owner. The IRS must

comply with such a request unless it determines that compliance with the request is

not in its best interests. If the IRS decides

not to comply with the request, it must

notify the owner of the determination

within the 60-day period, or any longer

period specified by the owner.

*****

(3) Notification to owner. The IRS will

respond in writing to a request for sale

of seized property as soon as practicable

after receipt of such request and in no

event later than 60 days after receipt of

the request, or, if later, the date specified

by the owner for the sale.

(f) Applicability date. The rules of this

section apply to sales of property seized

on or after November 5, 2024.

Douglas W. O’Donnell,

Deputy Commissioner.

Approved: October 15, 2024.

Aviva R. Aron-Dine,

Deputy Assistant Secretary of the Treasury (Tax Policy).

(Filed by the Office of the Federal Register November 04, 2024, 8:45 a.m., and published in the issue

of the Federal Register for November 05, 2024, 89

FR 87784)

Bulletin No. 2024–48

Definition of Terms

Revenue rulings and revenue procedures

(hereinafter referred to as “rulings”) that

have an effect on previous rulings use the

following defined terms to describe the

­effect:

Amplified describes a situation where

no change is being made in a prior published position, but the prior position is

being extended to apply to a variation of

the fact situation set forth therein. Thus,

if an earlier ruling held that a principle

applied to A, and the new ruling holds that

the same principle also applies to B, the

earlier ruling is amplified. (Compare with

modified, below).

Clarified is used in those instances

where the language in a prior ruling is

being made clear because the language

has caused, or may cause, some confusion. It is not used where a position in a

prior ruling is being changed.

Distinguished describes a situation

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

difference between them.

Modified is used where the substance

of a previously published position is being

changed. Thus, if a prior ruling held that a

principle applied to A but not to B, and the

new ruling holds that it applies to both A

and B, the prior ruling is modified because

it corrects a published position. (Compare

with amplified and clarified, above).

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

This term is most commonly used in a ruling

that lists previously published rulings that

are obsoleted because of changes in laws or

regulations. A ruling may also be obsoleted

because the substance has been included in

regulations subsequently adopted.

Revoked describes situations where the

position in the previously published ruling

is not correct and the correct position is

being stated in a new ruling.

Superseded describes a situation where

the new ruling does nothing more than

restate the substance and situation of a

previously published ruling (or rulings).

Thus, the term is used to republish under

the 1986 Code and regulations the same

position published under the 1939 Code

and regulations. The term is also used

when it is desired to republish in a single

ruling a series of situations, names, etc.,

that were previously published over a

period of time in separate rulings. If the

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

terms is used. For example, modified and

superseded describes a situation where the

substance of a previously published ruling

is being changed in part and is continued

without change in part and it is desired to

restate the valid portion of the previously

published ruling in a new ruling that is

self contained. In this case, the previously

published ruling is first modified and then,

as modified, is superseded.

Supplemented is used in situations in

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

countries, is published in a ruling and that

list is expanded by adding further names

in subsequent rulings. After the original

ruling has been supplemented several

times, a new ruling may be published that

includes the list in the original ruling and

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

Suspended is used in rare situations

to show that the previous published rulings will not be applied pending some

future action such as the issuance of new

or amended regulations, the outcome of

cases in litigation, or the outcome of a

Service study.

Abbreviations

The following abbreviations in current

use and formerly used will appear in

material published in the Bulletin.

A—Individual.

Acq.—Acquiescence.

B—Individual.

BE—Beneficiary.

BK—Bank.

B.T.A.—Board of Tax Appeals.

C—Individual.

C.B.—Cumulative Bulletin.

CFR—Code of Federal Regulations.

CI—City.

COOP—Cooperative.

Ct.D.—Court Decision.

CY—County.

D—Decedent.

DC—Dummy Corporation.

DE—Donee.

Del. Order—Delegation Order.

DISC—Domestic International Sales Corporation.

DR—Donor.

E—Estate.

EE—Employee.

E.O.—Executive Order.

ER—Employer.

Bulletin No. 2024–48

ERISA—Employee Retirement Income Security Act.

EX—Executor.

F—Fiduciary.

FC—Foreign Country.

FICA—Federal Insurance Contributions Act.

FISC—Foreign International Sales Company.

FPH—Foreign Personal Holding Company.

F.R.—Federal Register.

FUTA—Federal Unemployment Tax Act.

FX—Foreign corporation.

G.C.M.—Chief Counsel’s Memorandum.

GE—Grantee.

GP—General Partner.

GR—Grantor.

IC—Insurance Company.

I.R.B.—Internal Revenue Bulletin.

LE—Lessee.

LP—Limited Partner.

LR—Lessor.

M—Minor.

Nonacq.—Nonacquiescence.

O—Organization.

P—Parent Corporation.

PHC—Personal Holding Company.

PO—Possession of the U.S.

PR—Partner.

PRS—Partnership.

i

PTE—Prohibited Transaction Exemption.

Pub. L.—Public Law.

REIT—Real Estate Investment Trust.

Rev. Proc.—Revenue Procedure.

Rev. Rul.—Revenue Ruling.

S—Subsidiary.

S.P.R.—Statement of Procedural Rules.

Stat.—Statutes at Large.

T—Target Corporation.

T.C.—Tax Court.

T.D.—Treasury Decision.

TFE—Transferee.

TFR—Transferor.

T.I.R.—Technical Information Release.

TP—Taxpayer.

TR—Trust.

TT—Trustee.

U.S.C.—United States Code.

X—Corporation.

Y—Corporation.

Z—Corporation.

November 25, 2024

Numerical Finding List1

Bulletin 2024–48

Announcements:

2024-26, 2024-27 I.R.B. 14

2024-27, 2024-27 I.R.B. 14

2024-28, 2024-28 I.R.B. 39

2024-29, 2024-29 I.R.B. 71

2024-31, 2024-34 I.R.B. 533

2024-32, 2024-35 I.R.B. 535

2024-30, 2024-36 I.R.B. 581

2024-39, 2024-39 I.R.B. 639

2024-34, 2024-41 I.R.B. 758

2024-35, 2024-43 I.R.B. 1013

2024-36, 2024-44 I.R.B. 1073

2024-37, 2024-47 I.R.B. 1124

Notices:

2024-47, 2024-27 I.R.B. 1

2024-52, 2024-27 I.R.B. 2

2024-53, 2024-27 I.R.B. 4

2024-54, 2024-28 I.R.B. 24

2024-55, 2024-28 I.R.B. 31

2024-56, 2024-29 I.R.B. 64

2024-57, 2024-29 I.R.B. 67

2024-58, 2024-30 I.R.B. 120

2024-59, 2024-32 I.R.B. 348

2024-60, 2024-34 I.R.B. 515

2024-61, 2024-34 I.R.B. 520

2024-62, 2024-36 I.R.B. 570

2024-63, 2024-36 I.R.B. 573

2024-64, 2024-39 I.R.B. 632

2024-65, 2024-39 I.R.B. 633

2024-66, 2024-40 I.R.B. 682

2024-67, 2024-41 I.R.B. 726

2024-68, 2024-41 I.R.B. 729

2024-69, 2024-41 I.R.B. 733

2024-70, 2024-43 I.R.B. 1001

2024-72, 2024-43 I.R.B. 1005

2024-73, 2024-43 I.R.B. 1007

2024-71, 2024-44 I.R.B. 1026

2024-75, 2024-44 I.R.B. 1026

2024-74, 2024-45 I.R.B. 1089

2024-76, 2024-45 I.R.B. 1089

2024-77, 2024-45 I.R.B. 1093

2024-78, 2024-46 I.R.B. 1111

2024-80, 2024-47 I.R.B. 1120

Proposed Regulations:

REG-124593-23, 2024-28 I.R.B. 40

REG-109032-23, 2024-31 I.R.B. 332

REG-120137-19, 2024-31 I.R.B. 336

REG-119283-23, 2024-32 I.R.B. 351

REG-102161-23 2024-33 I.R.B. 502

REG-103529-23, 2024-33 I.R.B. 512

REG-105128-23, 2024-35 I.R.B. 536

Proposed Regulations:—Continued

REG-108920-24, 2024-38 I.R.B. 607

REG-111629-23, 2024-39 I.R.B. 640

REG-106851-21, 2024-40 I.R.B. 684

REG-116787-23, 2024-40 I.R.B. 709

REG-119683-22, 2024-40 I.R.B. 716

REG-118269-23, 2024-41 I.R.B. 761

REG-112129-23, 2024-42 I.R.B. 787

REG-113628-21, 2024-44 I.R.B. 1074

REG-110878-24, 2024-47 I.R.B. 1125

Revenue Procedures:

2024-26, 2024-27 I.R.B. 7

2024-29, 2024-30 I.R.B. 121

2024-30, 2024-30 I.R.B. 183

2024-27, 2024-31 I.R.B. 300

2024-28, 2024-31 I.R.B. 326

2024-32, 2024-34 I.R.B. 523

2024-34, 2024-38 I.R.B. 604

2024-35, 2024-39 I.R.B. 638

2024-36, 2024-41 I.R.B. 737

2024-37, 2024-41 I.R.B. 755

2024-38, 2024-43 I.R.B. 1010

2024-33, 2024-44 I.R.B. 1030

2024-39, 2024-45 I.R.B. 1097

2024-40, 2024-45 I.R.B. 1100

2024-31, 2024-46 I.R.B. 1113

2024-41, 2024-47 I.R.B. 1122

Revenue Rulings:

2024-13, 2024-28 I.R.B. 18

2024-14, 2024-28 I.R.B. 18

2024-15, 2024-32 I.R.B. 340

2024-16, 2024-35 I.R.B. 534

2024-17, 2024-36 I.R.B. 568

2024-18, 2024-37 I.R.B. 584

2024-20, 2024-40 I.R.B. 646

2024-21, 2024-41 I.R.B. 724

2024-22, 2024-43 I.R.B. 980

2024-23, 2024-43 I.R.B. 981

2024-24, 2024-45 I.R.B. 1086

Treasury Decisions:

10002, 2024-29 I.R.B. 56

9999, 2024-30 I.R.B. 72

10000, 2024-31 I.R.B. 185

10003, 2024-32 I.R.B. 342

10001, 2024-33 I.R.B. 412

10004, 2024-33 I.R.B. 489

9998, 2024-34 I.R.B. 412

10005, 2024-34 I.R.B. 510

9991, 2024-40 I.R.B. 646

10007, 2024-43 I.R.B. 981

9994, 2024-44 I.R.B. 1014

10008, 2024-45 I.R.B. 1082

10011, 2024-48 I.R.B. 1177

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 30, 2024.

1

November 25, 2024

ii

Bulletin No. 2024–48

Finding List of Current Actions on

Previously Published Items1

Bulletin 2024–48

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 30, 2024.

1

Bulletin No. 2024–48

iii

November 25, 2024

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

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