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- **Document type:** Agency decision

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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 Unpublished rulings will not be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

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.
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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3Aabcfe3fa80c97835. Public record. Not legal advice.