Bulletin No. 2022–35

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HIGHLIGHTS

OF THIS ISSUE

Bulletin No. 2022–35

August 29, 2022

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 2022-17, page 179.

The Office of Professional Responsibility (OPR)

announces recent disciplinary sanctions involving

attorneys, certified public accountants, enrolled

agents, enrolled actuaries, enrolled retirement plan

agents, and appraisers. These individuals are subject

to the regulations governing practice before the Internal Revenue Service (IRS), which are set out in Title

31, Code of Federal Regulations, Part 10, and which

are published in pamphlet form 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.

Rev. Rul. 2022-15, page 152.

Interest rates: underpayments and overpayments. The

rates for interest determined under Section 6621 of

the code for the calendar quarter beginning October 1,

2022, will be 6 percent for overpayments (5 percent

in the case of a corporation), 6 percent for underpayments, and 8 percent for large corporate underpayments. The rate of interest paid on the portion of a

Finding Lists begin on page ii.

corporate overpayment exceeding $10,000 will be

3.5 percent.

ESTATE TAX

Rev. Rul. 2022-16, page 171.

Special Use Value: Farms: Interest Rates. The 2022

interest rates to be used in computing the special use

value of farm real property for which an election is

made under section 2032A of the Code are listed for

estate of decedents.

EXEMPT ORGANIZATIONS

T.D. 9964, page 172.

These regulations provide guidance to state officials

regarding the process by which they may obtain or

inspect certain returns and return information (including information about final and proposed denials and

revocations of tax-exempt status) for the purpose of

administering state laws governing certain tax-exempt

organizations and their activities. These regulations

indirectly affect tax-exempt charitable organizations,

applicants for exemption as charitable organizations,

and certain other tax-exempt organizations.

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.

August 29, 2022

Bulletin No. 2022–35

Part I

Section 6621.—

Determination of Rate of

Interest

26 CFR 301.6621-1: Interest rate.

Rev. Rul. 2022-15

Section 6621 of the Internal Revenue Code establishes the interest rates

on overpayments and underpayments of

tax. Under section 6621(a)(1), the overpayment rate is the sum of the federal

short-term rate plus 3 percentage points (2

percentage points in the case of a corporation), except the rate for the portion of

a corporate overpayment of tax exceeding

$10,000 for a taxable period is the sum

of the federal short-term rate plus 0.5 of

a percentage point. Under section 6621(a)

(2), the underpayment rate is the sum of

the federal short-term rate plus 3 percentage points.

Section 6621(c) provides that for purposes of interest payable under section

6601 on any large corporate underpayment, the underpayment rate under section

6621(a)(2) is determined by substituting

“5 percentage points” for “3 percentage

points.” See section 6621(c) and section

301.6621-3 of the Regulations on Procedure and Administration for the definition

of a large corporate underpayment and

for the rules for determining the applicable date. Section 6621(c) and section

301.6621-3 are generally effective for

periods after December 31, 1990.

Section 6621(b)(1) provides that the

Secretary will determine the federal

August 29, 2022

short-term rate for the first month in each

calendar quarter. Section 6621(b)(2)(A)

provides that the federal short-term rate

determined under section 6621(b)(1) for

any month applies during the first calendar quarter beginning after that month.

Section 6621(b)(3) provides that the federal short-term rate for any month is the

federal short-term rate determined during

that month by the Secretary in accordance

with section 1274(d), rounded to the nearest full percent (or, if a multiple of 1/2 of

1 percent, the rate is increased to the next

highest full percent).

Notice 88-59, 1988-1 C.B. 546,

announced that in determining the quarterly interest rates to be used for overpayments and underpayments of tax under

section 6621, the Internal Revenue Service will use the federal short-term rate

based on daily compounding because that

rate is most consistent with section 6621

which, pursuant to section 6622, is subject

to daily compounding.

The federal short-term rate determined

in accordance with section 1274(d) during

July 2022 is the rate published in Revenue

Ruling 2022-14, 2022-31 IRB 110, to take

effect beginning August 1, 2022. The federal short-term rate, rounded to the nearest

full percent, based on daily compounding

determined during the month of July 2022

is 3 percent. Accordingly, an overpayment

rate of 6 percent (5 percent in the case of a

corporation) and an underpayment rate of

6 percent are established for the calendar

quarter beginning October 1, 2022. The

overpayment rate for the portion of a corporate overpayment exceeding $10,000

for the calendar quarter beginning October

152

1, 2022, is 3.5 percent. The underpayment

rate for large corporate underpayments for

the calendar quarter beginning October 1,

2022, is 8 percent. These rates apply to

amounts bearing interest during that calendar quarter.

Sections 6654(a)(1) and 6655(a)

(1) provide that the underpayment rate

established under section 6621 applies

in determining the addition to tax under

sections 6654 and 6655 for failure to pay

estimated tax for any taxable year. Thus,

the 6 percent rate also applies to estimated

tax underpayments for the fourth calendar quarter beginning October 1, 2022.

In addition, pursuant to section 6603(d)

(4), the rate of interest on section 6603

deposits is 3 percent for the fourth calendar quarter in 2022.

Interest factors for daily compound

interest for annual rates of 3.5 percent, 5

percent, 6 percent and 8 percent are published in Tables 12, 15, 17 and 21 of Rev.

Proc. 95-17, 1995-1 C.B. 566, 569, 571,

and 575.

Annual interest rates to be compounded

daily pursuant to section 6622 that apply

for prior periods are set forth in the tables

accompanying this revenue ruling.

DRAFTING INFORMATION

The principal author of this revenue

ruling is Casey R. Conrad of the Office of

the Associate Chief Counsel (Procedure

and Administration). For further information regarding this revenue ruling, contact

Mr. Conrad at (202) 317-6844 (not a tollfree number).

Bulletin No. 2022–35

APPENDIX A

Days

Factor

0.000013699

0.000027397

0.000041096

0.000054796

0.000068495

0.000082195

0.000095894

0.000109594

0.000123294

0.000136995

0.000150695

0.000164396

0.000178097

0.000191798

0.000205499

0.000219201

0.000232902

0.000246604

0.000260306

0.000274008

0.000287711

365 Day Year

0.5% Compound Rate 184 Days

Days

Factor

0.000863380

0.000877091

0.000890801

0.000904512

0.000918223

0.000931934

0.000945646

0.000959357

0.000973069

0.000986781

0.001000493

0.001014206

0.001027918

0.001041631

0.001055344

0.001069057

0.001082770

0.001096484

0.001110197

0.001123911

0.001137625

0.000301413

0.000315116

0.000328819

0.000342522

0.000356225

0.000369929

0.000383633

0.000397336

0.000411041

0.000424745

0.000438449

0.000452154

0.000465859

0.000479564

0.000493269

0.000506974

0.000520680

0.000534386

0.000548092

0.000561798

100

101

102

103

Bulletin No. 2022–35

0.001151339

0.001165054

0.001178768

0.001192483

0.001206198

0.001219913

0.001233629

0.001247344

0.001261060

0.001274776

0.001288492

0.001302208

0.001315925

0.001329641

0.001343358

0.001357075

0.001370792

0.001384510

0.001398227

0.001411945

153

Days

125

126

127

128

129

130

131

132

133

134

135

136

137

138

139

140

141

142

143

144

145

Factor

0.001713784

0.001727506

0.001741228

0.001754951

0.001768673

0.001782396

0.001796119

0.001809843

0.001823566

0.001837290

0.001851013

0.001864737

0.001878462

0.001892186

0.001905910

0.001919635

0.001933360

0.001947085

0.001960811

0.001974536

0.001988262

146

147

148

149

150

151

152

153

154

155

156

157

158

159

160

161

162

163

164

165

0.002001988

0.002015714

0.002029440

0.002043166

0.002056893

0.002070620

0.002084347

0.002098074

0.002111801

0.002125529

0.002139257

0.002152985

0.002166713

0.002180441

0.002194169

0.002207898

0.002221627

0.002235356

0.002249085

0.002262815

August 29, 2022

0.000575504

0.000589211

0.000602917

0.000616624

0.000630331

0.000644039

0.000657746

0.000671454

0.000685161

0.000698869

0.000712578

0.000726286

0.000739995

0.000753703

0.000767412

0.000781121

0.000794831

0.000808540

0.000822250

0.000835960

0.000849670

104

105

106

107

108

109

110

111

112

113

114

115

116

117

118

119

120

121

122

123

124

0.001425663

0.001439381

0.001453100

0.001466818

0.001480537

0.001494256

0.001507975

0.001521694

0.001535414

0.001549133

0.001562853

0.001576573

0.001590293

0.001604014

0.001617734

0.001631455

0.001645176

0.001658897

0.001672619

0.001686340

0.001700062

154

166

167

168

169

170

171

172

173

174

175

176

177

178

179

180

181

182

183

184

0.002276544

0.002290274

0.002304004

0.002317734

0.002331465

0.002345195

0.002358926

0.002372657

0.002386388

0.002400120

0.002413851

0.002427583

0.002441315

0.002455047

0.002468779

0.002482511

0.002496244

0.002509977

0.002523710

Bulletin No. 2022–35

Days

Factor

0.000013661

0.000027323

0.000040984

0.000054646

0.000068308

0.000081970

0.000095632

0.000109295

0.000122958

0.000136620

0.000150283

0.000163947

0.000177610

0.000191274

0.000204938

0.000218602

0.000232266

0.000245930

0.000259595

0.000273260

0.000286924

0.000300590

0.000314255

0.000327920

0.000341586

0.000355252

0.000368918

0.000382584

0.000396251

0.000409917

0.000423584

0.000437251

0.000450918

0.000464586

0.000478253

0.000491921

0.000505589

0.000519257

0.000532925

0.000546594

0.000560262

0.000573931

Bulletin No. 2022–35

366 Day Year

0.5% Compound Rate 184 Days

Days

Factor

0.000861020

0.000874693

0.000888366

0.000902040

0.000915713

0.000929387

0.000943061

0.000956735

0.000970409

0.000984084

0.000997758

0.001011433

0.001025108

0.001038783

0.001052459

0.001066134

0.001079810

0.001093486

0.001107162

0.001120839

0.001134515

0.001148192

0.001161869

0.001175546

0.001189223

0.001202900

0.001216578

0.001230256

0.001243934

0.001257612

0.001271291

0.001284969

0.001298648

0.001312327

0.001326006

0.001339685

0.001353365

100

0.001367044

101

0.001380724

102

0.001394404

103

0.001408085

104

0.001421765

155

Days

125

126

127

128

129

130

131

132

133

134

135

136

137

138

139

140

141

142

143

144

145

146

147

148

149

150

151

152

153

154

155

156

157

158

159

160

161

162

163

164

165

166

Factor

0.001709097

0.001722782

0.001736467

0.001750152

0.001763837

0.001777522

0.001791208

0.001804893

0.001818579

0.001832265

0.001845951

0.001859638

0.001873324

0.001887011

0.001900698

0.001914385

0.001928073

0.001941760

0.001955448

0.001969136

0.001982824

0.001996512

0.002010201

0.002023889

0.002037578

0.002051267

0.002064957

0.002078646

0.002092336

0.002106025

0.002119715

0.002133405

0.002147096

0.002160786

0.002174477

0.002188168

0.002201859

0.002215550

0.002229242

0.002242933

0.002256625

0.002270317

August 29, 2022

0.000587600

0.000601269

0.000614939

0.000628608

0.000642278

0.000655948

0.000669618

0.000683289

0.000696959

0.000710630

0.000724301

0.000737972

0.000751643

0.000765315

0.000778986

0.000792658

0.000806330

0.000820003

0.000833675

0.000847348

105

106

107

108

109

110

111

112

113

114

115

116

117

118

119

120

121

122

123

124

0.001435446

0.001449127

0.001462808

0.001476489

0.001490170

0.001503852

0.001517533

0.001531215

0.001544897

0.001558580

0.001572262

0.001585945

0.001599628

0.001613311

0.001626994

0.001640678

0.001654361

0.001668045

0.001681729

0.001695413

156

167

168

169

170

171

172

173

174

175

176

177

178

179

180

181

182

183

184

0.002284010

0.002297702

0.002311395

0.002325087

0.002338780

0.002352473

0.002366167

0.002379860

0.002393554

0.002407248

0.002420942

0.002434636

0.002448331

0.002462025

0.002475720

0.002489415

0.002503110

0.002516806

Bulletin No. 2022–35

TABLE OF INTEREST RATES

PERIODS BEFORE JUL. 1, 1975 - PERIODS ENDING DEC. 31, 1986

OVERPAYMENTS AND UNDERPAYMENTS

PERIOD

RATE

Before Jul. 1, 1975

Jul. 1, 1975–Jan. 31, 1976

Feb. 1, 1976–Jan. 31, 1978

Feb. 1, 1978–Jan. 31, 1980

Feb. 1, 1980–Jan. 31, 1982

Feb. 1, 1982–Dec. 31, 1982

Jan. 1, 1983–Jun. 30, 1983

Jul. 1, 1983–Dec. 31, 1983

Jan. 1, 1984–Jun. 30, 1984

Jul. 1, 1984–Dec. 31, 1984

Jan. 1, 1985–Dec. 31, 1985

Jul. 1, 1985–Dec. 31, 1985

Jan. 1, 1986–Jun. 30, 1986

Jul. 1, 1986–Dec. 31, 1986

12%

20%

16%

11%

13%

11%

10%

Table

In 1995-1 C.B.

DAILY RATE TABLE

pg.

37,

pg.

27,

pg.

75,

pg.

75,

pg.

31,

pg.

27,

pg.

25,

pg.

23,

pg.

557

559

558

557

560

591

581

629

585

581

579

577

TABLE OF INTEREST RATES

FROM JAN. 1, 1987 – Dec. 31, 1998

Jan. 1, 1987–Mar. 31, 1987

Apr. 1, 1987–Jun. 30, 1987

Jul. 1, 1987–Sep. 30, 1987

Oct. 1, 1987–Dec. 31, 1987

Jan. 1, 1988–Mar. 31, 1988

Apr. 1, 1988–Jun. 30, 1988

Jul. 1, 1988–Sep. 30, 1988

Oct. 1, 1988–Dec. 31, 1988

Jan. 1, 1989–Mar. 31, 1989

Apr. 1, 1989–Jun. 30, 1989

Jul. 1, 1989–Sep. 30, 1989

Oct. 1, 1989–Dec. 31, 1989

Jan. 1, 1990–Mar. 31, 1990

Apr. 1, 1990–Jun. 30, 1990

Jul. 1, 1990–Sep. 30, 1990

Oct. 1, 1990–Dec. 31, 1990

Jan. 1, 1991–Mar. 31, 1991

Apr. 1, 1991–Jun. 30, 1991

Bulletin No. 2022–35

RATE

10%

11%

10%

OVERPAYMENTS

1995-1 C.B.

TABLE

575

577

627

625

627

579

581

579

577

157

UNDERPAYMENTS

1995-1 C.B. RATE

RATE

TABLE

577

10%

579

11%

629

10%

627

10%

627

11%

629

11%

581

12%

583

12%

583

11%

581

11%

581

11%

581

11%

581

11%

581

11%

581

10%

579

August 29, 2022

Jul. 1, 1991–Sep. 30, 1991

Oct. 1, 1991–Dec. 31, 1991

Jan. 1, 1992–Mar. 31, 1992

Apr. 1, 1992–Jun. 30, 1992

Jul. 1, 1992–Sep. 30, 1992

Oct. 1, 1992–Dec. 31, 1992

Jan. 1, 1993–Mar. 31, 1993

Apr. 1, 1993–Jun. 30, 1993

Jul. 1, 1993–Sep. 30, 1993

Oct. 1, 1993–Dec. 31, 1993

Jan. 1, 1994–Mar. 31, 1994

Apr. 1, 1994–Jun. 30, 1994

Jul. 1, 1994–Sep. 30, 1994

Oct. 1, 1994–Dec. 31, 1994

Jan. 1, 1995–Mar. 31, 1995

Apr. 1, 1995–Jun. 30, 1995

Jul. 1, 1995–Sep. 30, 1995

Oct. 1, 1995–Dec. 31, 1995

Jan. 1, 1996–Mar. 31, 1996

Apr. 1, 1996–Jun. 30, 1996

Jul. 1, 1996–Sep. 30, 1996

Oct. 1, 1996–Dec. 31, 1996

Jan. 1, 1997–Mar. 31, 1997

Apr. 1, 1997–Jun. 30, 1997

Jul. 1, 1997–Sep. 30, 1997

Oct. 1, 1997–Dec. 31, 1997

Jan. 1, 1998–Mar. 31, 1998

Apr. 1, 1998–Jun. 30, 1998

Jul. 1, 1998–Sep. 30, 1998

Oct. 1, 1998–Dec. 31, 1998

August 29, 2022

158

577

623

621

619

571

573

575

577

575

623

621

623

575

573

10%

579

625

623

621

573

575

577

579

577

625

623

625

577

575

Bulletin No. 2022–35

TABLE OF INTEREST RATES

FROM JANUARY 1, 1999 - PRESENT

NONCORPORATE OVERPAYMENTS AND UNDERPAYMENTS

1995-1 C.B.

Jan. 1, 1999–Mar. 31, 1999

Apr. 1, 1999–Jun. 30, 1999

Jul. 1, 1999–Sep. 30, 1999

Oct. 1, 1999–Dec.31, 1999

Jan. 1, 2000–Mar. 31, 2000

Apr. 1, 2000–Jun. 30, 2000

Jul. 1, 2000–Sep. 30, 2000

Oct. 1, 2000–Dec. 31, 2000

Jan. 1, 2001–Mar. 31, 2001

Apr. 1, 2001–Jun. 30, 2001

Jul. 1, 2001–Sep. 30, 2001

Oct. 1, 2001–Dec. 31, 2001

Jan. 1, 2002–Mar. 31, 2002

Apr. 1, 2002–Jun. 30, 2002

Jul. 1, 2002–Sep. 30, 2002

Oct. 1, 2002–Dec. 31, 2002

Jan. 1, 2003–Mar. 31, 2003

Apr. 1, 2003–Jun. 30, 2003

Jul. 1, 2003–Sep. 30, 2003

Oct. 1, 2003–Dec. 31, 2003

Jan. 1, 2004–Mar. 31, 2004

Apr. 1, 2004–Jun. 30, 2004

Jul. 1, 2004–Sep. 30, 2004

Oct. 1, 2004–Dec. 31, 2004

Jan. 1, 2005–Mar. 31, 2005

Apr. 1, 2005–Jun. 30, 2005

Jul. 1, 2005–Sep. 30, 2005

Oct. 1, 2005–Dec. 31, 2005

Jan. 1, 2006–Mar. 31, 2006

Apr. 1, 2006–Jun. 30, 2006

Jul. 1, 2006–Sep. 30, 2006

Oct. 1, 2006–Dec. 31, 2006

Jan. 1, 2007–Mar. 31, 2007

Apr. 1, 2007–Jun. 30, 2007

Jul. 1, 2007–Sep. 30, 2007

Oct. 1, 2007–Dec. 31, 2007

Jan. 1, 2008–Mar. 31, 2008

Apr. 1, 2008–Jun. 30, 2008

Jul. 1, 2008–Sep. 30, 2008

Oct. 1, 2008–Dec. 31, 2008

Bulletin No. 2022–35

RATE

159

TABLE

PAGE

573

575

623

625

577

575

573

571

569

567

615

617

615

617

569

571

573

575

621

619

617

619

August 29, 2022

Jan. 1, 2009–Mar. 31, 2009

Apr. 1, 2009–Jun. 30, 2009

Jul. 1, 2009–Sep. 30, 2009

Oct. 1, 2009–Dec. 31, 2009

Jan. 1, 2010–Mar. 31, 2010

Apr. 1, 2010–Jun. 30, 2010

Jul. 1, 2010–Sep. 30, 2010

Oct. 1, 2010–Dec. 31, 2010

Jan. 1, 2011–Mar. 31, 2011

Apr. 1, 2011–Jun. 30, 2011

Jul. 1, 2011–Sep. 30, 2011

Oct. 1, 2011–Dec. 31, 2011

Jan. 1, 2012–Mar. 31, 2012

Apr. 1, 2012–Jun. 30, 2012

Jul. 1, 2012–Sep. 30, 2012

Oct. 1, 2012–Dec. 31, 2012

Jan. 1, 2013–Mar. 31, 2013

Apr. 1, 2013–Jun. 30, 2013

Jul. 1, 2013–Sep. 30, 2013

Oct. 1, 2013–Dec. 31, 2013

Jan. 1, 2014–Mar. 31, 2014

Apr. 1, 2014–Jun. 30, 2014

Jul. 1, 2014–Sep. 30, 2014

Oct. 1, 2014–Dec. 31, 2014

Jan. 1, 2015–Mar. 31, 2015

Apr. 1, 2015–Jun. 30, 2015

Jul. 1, 2015–Sep. 30, 2015

Oct. 1, 2015–Dec. 31, 2015

Jan. 1, 2016–Mar. 31, 2016

Apr. 1, 2016–Jun. 30, 2016

Jul. 1, 2016–Sep. 30, 2016

Oct. 1, 2016–Dec. 31, 2016

Jan. 1, 2017–Mar. 31, 2017

Apr. 1, 2017–Jun. 30, 2017

Jul. 1, 2017–Sep. 30, 2017

Oct. 1, 2017–Dec. 31, 2017

Jan. 1, 2018–Mar. 31, 2018

Apr. 1, 2018–Jun. 30, 2018

Jul. 1, 2018–Sep. 30, 2018

Oct. 1, 2018–Dec. 31, 2018

Jan. 1, 2019–Mar. 31, 2019

Apr. 1, 2019–Jun. 30, 2019

Jul. 1, 2019–Sep. 30, 2019

Oct. 1, 2019–Dec. 31, 2019

Jan. 1, 2020–Mar. 31, 2020

August 29, 2022

160

569

567

565

567

565

613

565

613

615

567

569

571

569

617

Bulletin No. 2022–35

Apr. 1, 2020–Jun. 30, 2020

Jul. 1, 2020–Sep. 30, 2020

Oct. 1, 2020–Dec. 31, 2020

Jan. 1, 2021–Mar. 31, 2021

Apr. 1, 2021–Jun. 30, 2021

Jul. 1, 2021–Sep. 30, 2021

Oct. 1, 2021–Dec. 31, 2021

Jan. 1, 2022–Mar. 31, 2022

Apr. 1, 2022–Jun. 30, 2022

Jul. 1, 2022–Sep. 30, 2022

Oct. 1, 2022–Dec. 31, 2022

Bulletin No. 2022–35

161

617

613

565

567

569

571

August 29, 2022

TABLE OF INTEREST RATES

FROM JANUARY 1, 1999 - PRESENT

CORPORATE OVERPAYMENTS AND UNDERPAYMENTS

Jan. 1, 1999–Mar. 31, 1999

Apr. 1, 1999–Jun. 30, 1999

Jul. 1, 1999–Sep. 30, 1999

Oct. 1, 1999–Dec. 31, 1999

Jan. 1, 2000–Mar. 30, 2000

Apr. 1, 2000–Jun. 30, 2000

Jul. 1, 2000–Sep. 30, 2000

Oct. 1, 2000–Dec. 31, 2000

Jan. 1, 2001–Mar. 31, 2001

Apr. 1, 2001–Jun. 30, 2001

Jul. 1, 2001–Sep. 30, 2001

Oct. 1, 2001–Dec. 31, 2001

Jan. 1, 2002–Mar. 31, 2002

Apr. 1, 2002–Jun. 30, 2002

Jul. 1, 2002–Sep. 30, 2002

Oct. 1, 2002–Dec. 31, 2002

Jan. 1, 2003–Mar. 31, 2003

Apr. 1, 2003–Jun. 30, 2003

Jul. 1, 2003–Sep. 30, 2003

Oct. 1, 2003–Dec. 31, 2003

Jan. 1, 2004–Mar. 31, 2004

Apr. 1, 2004–Jun. 30, 2004

Jul. 1, 2004–Sep. 30, 2004

Oct. 1, 2004–Dec. 31, 2004

Jan. 1, 2005–Mar. 31, 2005

Apr. 1, 2005–Jun. 30, 2005

Jul. 1, 2005–Sep. 30, 2005

Oct. 1, 2005–Dec. 31, 2005

Jan. 1, 2006–Mar. 31, 2006

Apr. 1, 2006–Jun. 30, 2006

Jul. 1, 2006–Sep. 30, 2006

Oct. 1, 2006–Dec. 31, 2006

Jan. 1, 2007–Mar. 31, 2007

Apr. 1, 2007–Jun. 30, 2007

Jul. 1, 2007–Sep. 30, 2007

Oct. 1, 2007–Dec. 31, 2007

Jan. 1, 2008–Mar. 31, 2008

Apr. 1, 2008–Jun. 30, 2008

Jul. 1, 2008–Sep. 30, 2008

August 29, 2022

OVERPAYMENTS

1995-1 C.B.

RATE

TABLE

RATE

TABLE

162

571

573

621

623

575

573

571

569

567

565

613

615

613

615

567

569

571

573

619

617

615

UNDERPAYMENTS

1995-1 C.B.

RATE

TABLE

RATE

TABLE

573

575

623

625

577

575

573

571

569

567

615

617

615

617

569

571

573

575

621

619

617

Bulletin No. 2022–35

Oct. 1, 2008–Dec. 31, 2008

Jan 1, 2009–Mar. 31, 2009

Apr. 1, 2009–Jun. 30, 2009

Jul. 1, 2009–Sep. 30, 2009

Oct. 1, 2009–Dec. 31, 2009

Jan. 1, 2010–Mar. 31, 2010

Apr. 1, 2010–Jun. 30, 2010

Jul. 1, 2010–Sep. 30, 2010

Oct. 1, 2010–Dec. 31, 2010

Jan. 1, 2011–Mar. 31, 2011

Apr. 1, 2011–Jun. 30, 2011

Jul. 1, 2011–Sep. 30, 2011

Oct. 1, 2011–Dec. 31, 2011

Jan. 1, 2012–Mar. 31, 2012

Apr. 1, 2012–Jun. 30, 2012

Jul. 1, 2012–Sep. 30, 2012

Oct. 1, 2012–Dec. 31, 2012

Jan. 1, 2013–Mar. 31, 2013

Apr. 1, 2013–Jun. 30, 2013

Jul. 1, 2013–Sep. 30, 2013

Oct. 1, 2013–Dec. 31, 2013

Jan. 1, 2014–Mar. 31, 2014

Apr. 1, 2014–Jun. 30, 2014

Jul. 1, 2014–Sep. 30, 2014

Oct. 1, 2014–Dec. 31, 2014

Jan. 1, 2015–Mar. 31, 2015

Apr. 1, 2015–Jun. 30, 2015

Jul. 1, 2015–Sep. 30, 2015

Oct. 1, 2015–Dec. 31, 2015

Jan. 1, 2016–Mar. 31, 2016

Apr. 1, 2016–Jun. 30, 2016

Jul. 1, 2016–Sep. 30, 2016

Oct. 1, 2016–Dec. 31, 2016

Jan. 1, 2017–Mar. 31, 2017

Apr. 1, 2017–Jun. 30, 2017

Jul. 1, 2017–Sep. 30, 2017

Oct. 1, 2017–Dec. 31, 2017

Jan. 1, 2018–Mar. 31, 2018

Apr. 1, 2018–Jun. 30, 2018

Jul. 1, 2018–Sep. 30, 2018

Oct. 1, 2018–Dec. 31, 2018

Jan. 1, 2019–Mar. 31, 2019

Apr. 1, 2019–Jun. 30, 2019

Jul. 1, 2019–Sep. 30, 2019

Oct. 1, 2019–Dec. 31, 2019

Bulletin No. 2022–35

163

617

567

565

563

565

563

611

563

611

613

565

567

569

567

619

569

567

565

567

565

613

565

613

615

567

569

571

569

August 29, 2022

Jan. 1, 2020–Mar. 31, 2020

Apr. 1, 2020–Jun. 30, 2020

Jul. 1, 2020–Sep. 30, 2020

Oct. 1, 2020–Dec. 31, 2020

Jan. 1, 2021–Mar. 31, 2021

Apr. 1, 2021–Jun. 30, 2021

Jul. 1, 2021–Sep. 30, 2021

Oct. 1, 2021–Dec. 31, 2021

Jan. 1, 2022–Mar. 31, 2022

Apr. 1, 2022–Jun. 30, 2022

Jul. 1, 2022–Sep. 30, 2022

Oct. 1, 2022–Dec. 31, 2022

August 29, 2022

164

615

611

563

565

567

569

617

613

565

567

569

571

Bulletin No. 2022–35

TABLE OF INTEREST RATES

FOR LARGE CORPORATE UNDERPAYMENTS

FROM JANUARY 1, 1991 - PRESENT

Jan. 1, 1991–Mar. 31, 1991

Apr. 1, 1991–Jun. 30, 1991

Jul. 1, 1991–Sep. 30, 1991

Oct. 1, 1991–Dec. 31, 1991

Jan. 1, 1992–Mar. 31, 1992

Apr. 1, 1992–Jun. 30, 1992

Jul. 1, 1992–Sep. 30, 1992

Oct. 1, 1992–Dec. 31, 1992

Jan. 1, 1993–Mar. 31, 1993

Apr. 1, 1993–Jun. 30, 1993

Jul. 1, 1993–Sep. 30, 1993

Oct. 1, 1993–Dec. 31, 1993

Jan. 1, 1994–Mar. 31, 1994

Apr. 1, 1994–Jun. 30, 1994

Jul. 1, 1994–Sep. 30, 1994

Oct. 1, 1994–Dec. 31, 1994

Jan. 1, 1995–Jun. 30, 1995

Apr. 1, 1995–Jun. 30, 1995

Jul. 1, 1995–Sep. 30, 1995

Oct. 1, 1995–Dec. 31, 1995

Jan. 1, 1996–Mar. 31, 1996

Apr. 1, 1996–Jun. 30, 1996

Jul. 1, 1996–Sep. 30, 1996

Oct. 1, 1996–Dec. 31, 1996

Jan. 1, 1997–Mar. 31, 1997

Apr. 1, 1997–Jun. 30, 1997

Jul. 1, 1997–Sep. 30, 1997

Oct. 1, 1997–Dec. 31, 1997

Jan. 1, 1998–Mar. 31, 1998

Apr. 1, 1998–Jun. 30, 1998

Jul. 1, 1998–Sep. 30, 1998

Oct. 1, 1998–Dec. 31, 1998

Jan. 1, 1999–Mar. 31, 1999

Apr. 1, 1999–Jun. 30, 1999

Jul. 1, 1999–Sep. 30, 1999

Oct. 1, 1999–Dec. 31, 1999

Jan. 1, 2000–Mar. 31, 2000

Apr. 1, 2000–Jun. 30, 2000

Jul. 1, 2000–Sep. 30, 2000

Oct. 1, 2000–Dec. 31, 2000

Jan. 1, 2001–Mar. 31, 2001

Bulletin No. 2022–35

RATE

13%

12%

11%

10%

11%

12%

11%

10%

11%

10%

11%

165

1995-1 C.B.

TABLE

585

583

629

627

625

577

579

581

583

581

629

627

629

581

579

577

579

627

629

581

August 29, 2022

Apr. 1, 2001–Jun. 30, 2001

Jul. 1, 2001–Sep. 30, 2001

Oct. 1, 2001–Dec. 31, 2001

Jan. 1, 2002–Mar. 31, 2002

Apr. 1, 2002–Sep. 30, 2002

Jul. 1, 2002–Sep. 30, 2002

Oct. 1, 2002–Dec. 31, 2002

Jan. 1, 2003–Mar. 31, 2003

Apr. 1, 2003–Jun. 30, 2003

Jul. 1, 2003–Sep. 30, 2003

Oct. 1, 2003–Dec. 31, 2003

Jan. 1, 2004–Mar. 31, 2004

Apr. 1, 2004–Jun. 30, 2004

Jul. 1, 2004–Sep. 30, 2004

Oct. 1, 2004–Dec. 31, 2004

Jan. 1, 2005–Mar. 31, 2005

Apr. 1, 2005–Jun. 30, 2005

Jul. 1, 2005–Sep. 30, 2005

Oct. 1, 2005–Dec. 31, 2005

Jan. 1, 2006–Mar. 31, 2006

Apr. 1, 2006–Jun. 30, 2006

Jul. 1, 2006–Sep. 30, 2006

Oct. 1, 2006–Dec. 31, 2006

Jan. 1, 2007–Mar. 31, 2007

Apr. 1, 2007–Jun. 30, 2007

Jul. 1, 2007–Sep. 30, 2007

Oct. 1, 2007–Dec. 31, 2007

Jan. 1, 2008–Mar. 31, 2008

Apr. 1, 2008–Sep. 30, 2008

Jul. 1, 2008–Sep. 30, 2008

Oct. 1, 2008–Dec. 31, 2008

Jan. 1, 2009–Mar. 31, 2009

Apr. 1, 2009–Jun. 30, 2009

Jul. 1, 2009–Sep. 30, 2009

Oct. 1, 2009–Dec. 31, 2009

Jan. 1, 2010–Mar. 31, 2010

Apr. 1, 2010–Jun. 30, 2010

Jul. 1, 2010–Sep. 30, 2010

Oct. 1, 2010–Dec. 31, 2010

Jan. 1, 2011–Mar. 31, 2011

Apr. 1, 2011–Jun. 30, 2011

Jul. 1, 2011–Sep. 30, 2011

Oct. 1, 2011–Dec. 31, 2011

Jan. 1, 2012–Mar. 31, 2012

Apr. 1, 2012–Jun. 30, 2012

August 29, 2022

10%

166

579

577

575

573

571

619

621

619

621

573

575

577

579

625

623

621

623

573

571

569

571

569

617

Bulletin No. 2022–35

Jul. 1, 2012–Sep. 30, 2012

Oct. 1, 2012–Dec. 31, 2012

Jan. 1, 2013–Mar. 31, 2013

Apr. 1, 2013–Jun. 30, 2013

Jul. 1, 2013–Sep. 30, 2013

Oct. 1, 2013–Dec. 31, 2013

Jan. 1, 2014–Mar. 31, 2014

Apr. 1, 2014–Jun. 30, 2014

Jul. 1, 2014–Sep. 30, 2014

Oct. 1, 2014–Dec. 31, 2014

Jan. 1, 2015–Mar. 31, 2015

Apr. 1, 2015–Jun. 30, 2015

Jul. 1, 2015–Sep. 30, 2015

Oct. 1, 2015–Dec. 31, 2015

Jan. 1, 2016–Mar. 31, 2016

Apr. 1, 2016–Jun. 30, 2016

Jul. 1, 2016–Sep. 30, 2016

Oct. 1, 2016–Dec. 31, 2016

Jan. 1, 2017–Mar. 31, 2017

Apr. 1, 2017–Jun. 30, 2017

Jul. 1, 2017–Sep. 30, 2017

Oct. 1, 2017–Dec. 31, 2017

Jan. 1, 2018–Mar. 31, 2018

Apr. 1, 2018–Jun. 30, 2018

Jul. 1, 2018–Sep. 30, 2018

Oct. 1, 2018–Dec. 31, 2018

Jan. 1, 2019–Mar. 31, 2019

Apr. 1, 2019–Jun. 30, 2019

Jul. 1, 2019–Sep. 30, 2019

Oct. 1, 2019–Dec. 31, 2019

Jan. 1, 2020–Mar. 31, 2020

Apr. 1, 2020–Jun. 30, 2020

Jul. 1, 2020–Sep. 30, 2020

Oct. 1, 2020–Dec. 31, 2020

Jan. 1, 2021–Mar. 31, 2021

Apr. 1, 2021–Jun. 30, 2021

Jul. 1, 2021–Sep. 30, 2021

Oct. 1, 2021–Dec. 31, 2021

Jan. 1, 2022–Mar. 31, 2022

Apr. 1, 2022–Jun. 30, 2022

Jul. 1, 2022–Sep. 30, 2022

Oct. 1, 2022–Dec. 31, 2022

Bulletin No. 2022–35

167

617

569

617

619

571

573

575

573

621

617

569

571

573

575

August 29, 2022

TABLE OF INTEREST RATES FOR CORPORATE

OVERPAYMENTS EXCEEDING $10,000

FROM JANUARY 1, 1995 – PRESENT

1995-1 C.B.

RATE

TABLE

Jan. 1, 1995–Mar. 31, 1995

6.5%

572

Apr. 1, 1995–Jun. 30, 1995

7.5%

574

Jul. 1, 1995–Sep. 30, 1995

6.5%

572

Oct. 1, 1995–Dec. 31, 1995

6.5%

572

Jan. 1, 1996–Mar. 31, 1996

6.5%

620

Apr. 1, 1996–Jun. 30, 1996

5.5%

618

Jul. 1, 1996–Sep. 30, 1996

6.5%

620

Oct. 1, 1996–Dec. 31, 1996

6.5%

620

Jan. 1, 1997–Mar. 31, 1997

6.5%

572

Apr. 1, 1997–Jun. 30, 1997

6.5%

572

Jul. 1, 1997–Sep. 30, 1997

6.5%

572

Oct. 1, 1997–Dec. 31, 1997

6.5%

572

Jan. 1, 1998–Mar. 31, 1998

6.5%

572

Apr. 1, 1998–Jun. 30, 1998

5.5%

570

Jul. 1, 1998–Sep. 30, 1998

5.5%

570

Oct. 1, 1998–Dec. 31, 1998

5.5%

570

Jan. 1, 1999–Mar. 31, 1999

4.5%

568

Apr. 1, 1999–Sep. 30, 1999

5.5%

570

Jul. 1, 1999–Sep. 30, 1999

5.5%

570

Oct. 1, 1999–Dec. 31, 1999

5.5%

570

Jan. 1, 2000–Mar. 31, 2000

5.5%

618

Apr. 1, 2000–Jun. 30, 2000

6.5%

620

Jul. 1, 2000–Sep. 30, 2000

6.5%

620

Oct. 1, 2000–Dec. 31, 2000

6.5%

620

Jan. 1, 2001–Mar. 31, 2001

6.5%

572

Apr. 1, 2001–Jun. 30, 2001

5.5%

570

Jul. 1, 2001–Sep. 30, 2001

4.5%

568

Oct. 1, 2001–Dec. 31, 2001

4.5%

568

Jan. 1, 2002–Mar. 31, 2002

3.5%

566

Apr. 1, 2002–Jun. 30, 2002

3.5%

566

Jul. 1, 2002–Sep. 30, 2002

3.5%

566

Oct. 1, 2002–Dec. 31, 2002

3.5%

566

Jan. 1, 2003–Mar. 31, 2003

2.5%

564

Apr. 1, 2003–Jun. 30, 2003

2.5%

564

Jul. 1, 2003–Sep. 30, 2003

2.5%

564

Oct. 1, 2003–Dec. 31, 2003

1.5%

562

Jan. 1, 2004–Mar. 31, 2004

1.5%

610

Apr. 1, 2004–Jun. 30, 2004

2.5%

612

August 29, 2022

168

Bulletin No. 2022–35

Jul. 1, 2004–Sep. 30, 2004

1.5%

610

Oct. 1, 2004–Dec. 31, 2004

2.5%

612

Jan. 1, 2005–Mar. 31, 2005

2.5%

564

Apr. 1, 2005–Jun. 30, 2005

3.5%

566

Jul. 1, 2005–Sep. 30, 2005

3.5%

566

Oct. 1, 2005–Dec. 31, 2005

4.5%

568

Jan. 1, 2006–Mar. 31, 2006

4.5%

568

Apr. 1, 2006–Jun. 30, 2006

4.5%

568

Jul. 1, 2006–Sep. 30, 2006

5.5%

570

Oct. 1, 2006–Dec. 31, 2006

5.5%

570

Jan. 1, 2007–Mar. 31, 2007

5.5%

570

Apr. 1, 2007–Jun. 30, 2007

5.5%

570

Jul. 1, 2007–Sep. 30, 2007

5.5%

570

Oct. 1, 2007–Dec. 31, 2007

5.5%

570

Jan. 1, 2008–Mar. 31, 2008

4.5%

616

Apr. 1, 2008–Jun. 30, 2008

3.5%

614

Jul. 1, 2008–Sep. 30, 2008

2.5%

612

Oct. 1, 2008–Dec. 31, 2008

3.5%

614

Jan. 1, 2009–Mar. 31, 2009

2.5%

564

Apr. 1, 2009–Jun. 30, 2009

1.5%

562

Jul. 1, 2009–Sep. 30, 2009

1.5%

562

Oct. 1, 2009–Dec. 31, 2009

1.5%

562

Jan. 1, 2010–Mar. 31, 2010

1.5%

562

Apr. 1, 2010–Jun. 30, 2010

1.5%

562

Jul. 1, 2010–Sep. 30, 2010

1.5%

562

Oct. 1, 2010–Dec. 31, 2010

1.5%

562

Jan. 1, 2011–Mar. 31, 2011

0.5%*

Apr. 1, 2011–Jun. 30, 2011

1.5%

562

Jul. 1, 2011–Sep. 30, 2011

1.5%

562

Oct. 1, 2011–Dec. 31, 2011

0.5%*

Jan. 1, 2012–Mar. 31, 2012

0.5%*

Apr. 1, 2012–Jun. 30, 2012

0.5%*

Jul. 1, 2012–Sep. 30, 2012

0.5%*

Oct. 1, 2012–Dec. 31, 2012

0.5%*

Jan. 1, 2013–Mar. 31, 2013

0.5%*

Apr. 1, 2013–Jun. 30, 2013

0.5%*

Jul. 1, 2013–Sep. 30, 2013

0.5%*

Oct. 1, 2013–Dec. 31, 2013

0.5%*

Jan. 1, 2014–Mar. 31, 2014

0.5%*

Apr. 1, 2014–Jun. 30, 2014

0.5%*

Jul. 1, 2014–Sep. 30, 2014

0.5%*

Oct. 1, 2014–Dec. 31, 2014

0.5%*

Bulletin No. 2022–35

169

August 29, 2022

Jan. 1, 2015–Mar. 31, 2015

0.5%*

Apr. 1, 2015–Jun. 30, 2015

0.5%*

Jul. 1, 2015–Sep. 30, 2015

0.5%*

Oct. 1, 2015–Dec. 31, 2015

0.5%*

Jan. 1, 2016–Mar. 31, 2016

0.5%*

Apr. 1, 2016–Jun. 30, 2016

1.5%

610

Jul. 1, 2016–Sep. 30, 2016

1.5%

610

Oct. 1, 2016–Dec. 31, 2016

1.5%

610

Jan. 1, 2017–Mar. 31, 2017

1.5%

562

Apr. 1, 2017–Jun. 30, 2017

1.5%

562

Jul. 1, 2017–Sep. 30, 2017

1.5%

562

Oct. 1, 2017–Dec. 31, 2017

1.5%

562

Jan. 1, 2018–Mar. 31, 2018

1.5%

562

Apr. 1, 2018–Jun. 30, 2018

2.5%

564

Jul. 1, 2018–Sep. 30, 2018

2.5%

564

Oct. 1, 2018–Dec. 31, 2018

2.5%

564

Jan. 1, 2019–Mar. 31, 2019

3.5%

566

Apr. 1, 2019–Jun. 30, 2019

3.5%

566

Jul. 1, 2019–Sep. 30, 2019

2.5%

564

Oct. 1, 2019–Dec. 31, 2019

2.5%

564

Jan. 1, 2020–Mar. 31, 2020

2.5%

612

Apr. 1, 2020–Jun. 30, 2020

2.5%

612

Jul. 1, 2020–Sep. 30, 2020

0.5%*

Oct. 1, 2020–Dec. 31, 2020

0.5%*

Jan. 1, 2021–Mar. 31, 2021

0.5%*

Apr. 1, 2021–Jun. 30, 2021

0.5%*

Jul. 1, 2021–Sep. 30, 2021

0.5%*

Oct. 1, 2021–Dec. 31, 2021

0.5%*

Jan. 1, 2022–Mar. 31, 2022

0.5%*

Apr. 1, 2022–Jun. 30, 2022

1.5%

562

Jul. 1, 2022–Sep. 30, 2022

2.5%

564

Oct. 1, 2022–Dec. 31, 2022

3.5%

566

* The asterisk reflects the interest factors for daily compound interest for annual rates of 0.5 percent published in Appendix A of

this Revenue Ruling.

August 29, 2022

170

Bulletin No. 2022–35

Section 2032A.—Valuation

of Certain Farm, Etc., Real

Property

26 CFR 20.2032A-4: Method of valuing farm real

property.

Rev. Rul. 2022-16

This revenue ruling contains a list of

the average annual effective interest rates

on new loans under the Farm Credit System. This revenue ruling also contains a

list of the states within each Farm Credit

System Bank Territory.

Under § 2032A(e)(7)(A)(ii) of the

Internal Revenue Code, rates on new

Farm Credit System Bank loans are

used in computing the special use value

of real property used as a farm for which

an election is made under § 2032A. The

rates in Table 1 of this revenue ruling

may be used by estates that value farmland under § 2032A as of a date in 2022.

Average annual effective interest rates,

calculated in accordance with § 2032A(e)

(7)(A) and § 20.2032A-4(e) of the

Estate Tax Regulations, to be used under

§ 2032A(e)(7)(A)(ii), are set forth in the

accompanying Table of Interest Rates

(Table 1). The states within each Farm

Credit System Bank Territory are set forth

in the accompanying Table of Farm Credit

System Bank Territories (Table 2).

Rev. Rul. 81-170, 1981-1 C.B. 454,

contains an illustrative computation of

REV. RUL. 2022-16 TABLE 1

TABLE OF INTEREST RATES

(Year of Valuation 2022)

Farm Credit System Bank Servicing State in

Which Property is Located

AgFirst, FCB

AgriBank, FCB

CoBank, ACB

Texas, FCB

an average annual effective interest rate.

The rates applicable for valuation in 2021

are in Rev. Rul. 2021-15, 2021-35 I.R.B.

331. For rate information for years prior

to 2021, see Rev. Rul. 2020-17, 2020-37

I.R.B. 552, and other revenue rulings that

are referenced therein.

DRAFTING INFORMATION

The principal author of this revenue

ruling is Lane Damazo of the Office of the

Associate Chief Counsel (Passthroughs

and Special Industries). For further information regarding this revenue ruling, contact Lane Damazo at (202) 317-4628 (not

a toll-free number).

Rate

5.14

4.57

4.47

4.95

REV. RUL. 2022-16 TABLE 2

TABLE OF FARM CREDIT SYSTEM BANK TERRITORIES

Farm Credit System Bank

Location of Property

AgFirst, FCB. . . . . . . . . . . . . . . . . . . . . . . . . .

Delaware, District of Columbia, Florida, Georgia, Maryland, North Carolina,

Pennsylvania, South Carolina, Virginia, West Virginia.

AgriBank, FCB. . . . . . . . . . . . . . . . . . . . . . . .

Arkansas, Illinois, Indiana, Iowa, Kentucky, Michigan, Minnesota, Missouri,

Nebraska, North Dakota, Ohio, South Dakota, Tennessee, Wisconsin, Wyoming.

CoBank, ACB. . . . . . . . . . . . . . . . . . . . . . . . .

Alaska, Arizona, California, Colorado, Connecticut, Hawaii, Idaho, Kansas,

Maine, Massachusetts, Montana, New Hampshire, New Jersey, New Mexico,

New York, Nevada, Oklahoma, Oregon, Rhode Island, Utah, Vermont,

Washington.

Texas, FCB. . . . . . . . . . . . . . . . . . . . . . . . . . .

Alabama, Louisiana, Mississippi, Texas.

Bulletin No. 2022–35

171

August 29, 2022

26 CFR § 301.6104(c)-1

T.D. 9964

DEPARTMENT OF THE

TREASURY

Internal Revenue Service

26 CFR Part 301

Disclosure of Information

to State Officials Regarding

Tax-Exempt Organizations

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Final regulations.

SUMMARY: These final regulations

provide guidance to states regarding the

process by which they may obtain or

inspect certain returns and return information (including information about

final and proposed denials and revocations of tax-exempt status) for the purpose of administering State laws governing certain tax-exempt organizations

and their activities. The final regulations

amend existing regulations to reflect

changes to the Internal Revenue Code

(Code) made by the Pension Protection

Act of 2006 (PPA). The final regulations

will affect the states choosing to obtain

information from the IRS under these

rules, as well as the organizations and

taxable persons whose tax information

is disclosed.

DATES: Effective date: August 16, 2022.

Applicability date: For the date of

applicability, see §301.6104(c)-1(k).

FOR FURTHER INFORMATION

CONTACT: Seth Groman, (202) 3175640 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

1. Overview

This document contains amendments

to 26 CFR part 301 under section 6104(c),

which replace current §301.6104(c)-1,

August 29, 2022

which was issued in 1971, amended in

1973 and 1981, and redesignated in 1982,

in its entirety. Section 6104(c) was added

to the Code by section 101(e) of the Tax

Reform Act of 1969 (Pub. L. 91-172,

83 Stat. 523) and amended by section

1224(a) of the PPA of 2006 (Pub. L. 109280, 120 Stat. 1091). Section 6104(c),

as amended by the PPA, governs the circumstances under which the IRS may

disclose to State officials certain information about organizations described in

section 501(c)(3) of the Code, including

private foundations (charitable organizations), organizations that have applied for

recognition as organizations described in

section 501(c)(3) (applicants), certain

other exempt organizations, and taxable

persons.

On March 15, 2011, the Department of

the Treasury (Treasury Department) and

the IRS published a notice of proposed

rulemaking (NPRM) (REG-140108-08)

in the Federal Register (76 FR 13932).

No public hearing was requested or held.

One comment letter on the NPRM was

received. This Treasury decision adopts

the NPRM with certain changes explained

in the Summary of Comments and Explanation of Provisions.

2. PPA Amendments to Section 6104(c)

Prior to the passage of the PPA, the

IRS was authorized to share certain

information with appropriate State officers (ASOs). Section 6104(c)(1), which

is unchanged by the PPA, directs the IRS

to notify the ASO of (1) a refusal to recognize an entity as a charitable organization; (2) the operation of a charitable

organization in a manner not meeting, or

no longer meeting, the requirements of

its exemption; and (3) the mailing of a

notice of deficiency for any tax imposed

under section 507 or chapter 41 or 42

of the Code. The directive to notify the

ASO of an organization no longer meeting the requirements for exemption under

section 501(c)(3) includes not only providing the ASO notice of a revocation of

exemption, but also notice (when the IRS

is so informed) that a charitable organization is terminating or has dissolved

in accordance with its governing documents. In addition, an ASO, upon request,

may inspect and copy the returns, filed

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statements, records, reports, and other

information relating to a final determination as are relevant to any determination

under State law.

The PPA added section 6104(c)(2)

through (6) of the Code, which expanded

the IRS’s ability to disclose information to

an ASO. With respect to charitable organizations and applicants, the IRS now is

authorized under section 6104(c)(2) to

disclose information about certain proposed revocations and proposed denials

before an administrative appeal has been

made and a final revocation or denial has

been issued.

Specifically, section 6104(c)(2)(A)(i)

and (ii) provides that the IRS may disclose

to an ASO proposed refusals to recognize

organizations as charitable organizations,

proposed revocations of such recognition, and notices of proposed deficiency

of excise taxes imposed by section 507

or chapter 41 or 42 of the Code relating

to charitable organizations. Previously,

only final determinations of these kinds

(denials of recognition, revocations, and

notices of deficiency) could be disclosed

under section 6104(c).

Section 6104(c)(2)(A)(iii) provides

that the IRS may disclose to an ASO the

names, addresses, and taxpayer identification numbers of applicants. Previously,

information on applicants, other than

information relating to a final denial of

recognition, could not be disclosed under

section 6104(c).

Section 6104(c)(2)(B) provides that the

IRS may disclose to an ASO the returns

and return information of organizations

with respect to which information is disclosed under section 6104(c)(2)(A) (proposed determinations and applicant identifying information). Prior law allowed

for disclosure under section 6104(c) only

of returns and return information of organizations related to their receipt of final

determinations.

Section 6104(c)(2)(C) provides that

proposed determinations, applicant identifying information, and the related returns

and return information with respect to

charitable organizations and applicants

under sections 6104(c)(2)(A) or (B) may

be disclosed to an ASO only upon the

ASO’s written request and only as necessary to administer State laws regulating charitable organizations. Prior law

Bulletin No. 2022–35

provided for automatic disclosure – with

no requirement for a disclosure request –

but only of final determinations.

Under section 6104(c)(2)(D), the IRS

may disclose to an ASO, on its own initiative and without a written request,

returns and return information with

respect to charitable organizations and

applicants if the IRS determines that this

information may constitute evidence of

noncompliance with the laws under the

jurisdiction of the ASO. Thus, if the IRS

determines these conditions to be met,

it may, for example, disclose to an ASO

a proposed revocation of exemption for

a charitable organization that does not

have a determination letter. There was

no such provision under section 6104(c)

previously.

Section 6104(c)(3) provides that the

IRS may disclose returns and return information of organizations described in section 501(c), other than those described in

section 501(c)(1) or (3) (such as section

501(c)(4) social welfare organizations,

section 501(c)(5) labor organizations, and

section 501(c)(6) business leagues), to an

ASO upon the ASO’s written request, but

only for the purpose of, and to the extent

necessary in, administering State laws regulating the solicitation or administration

of charitable funds or charitable assets of

such organizations. Previously, only information relating to charitable organizations

or applicants was disclosed under section

6104(c).

Section 6104(c)(4) generally provides

that returns and return information of organizations and taxable persons disclosed

under section 6104(c) may be disclosed in

civil administrative and civil judicial proceedings pertaining to the enforcement of

State laws regulating such organizations,

under procedures prescribed by the IRS

similar to those under section 6103(h)(4).

There was no such provision under section 6104(c) previously.

Section 6104(c)(5) generally provides

that no return or return information may

be disclosed under section 6104(c) to the

extent the IRS determines that such disclosure would seriously impair Federal

tax administration. This disclosure prohibition, though new in the Code, was

provided previously by regulation. See

former §301.6104(c)-1(b)(3)(ii) (replaced

by these final regulations).

Bulletin No. 2022–35

Sections 6104(c)(2)(C) (flush language)

and (c)(3) provide that the IRS may

disclose returns and return information

under section 6104(c) to a State officer

or employee designated by the ASO to

receive such information on the ASO’s

behalf. Prior law did not provide for IRS

disclosures to persons other than ASOs.

Section 6104(c)(6)(B) defines an ASO

as the State attorney general, the State tax

officer, any State official charged with

overseeing charitable organizations (in

the case of charitable organizations and

applicants), and the head of the State

agency designated by the State attorney

general as having the primary responsibility for overseeing the solicitation of

funds for charitable purposes (in the case

of section 501(c) organizations other than

Federal instrumentalities and charitable

organizations). Before its amendment by

the PPA, section 6104(c)(2) defined ASO

as the State attorney general, the State

tax officer, or any State official charged

with overseeing organizations of the type

described in section 501(c)(3).

3. PPA Amendments to Related Code

Provisions

The PPA also amended section 6103 to

make section 6104(c), in its entirety, subject to its confidentiality and disclosure

provisions.

Section 6103(a)(2) provides the general rule that returns and return information are confidential and that an officer or

employee of a State who receives returns

or return information from the IRS under

section 6104(c) must not disclose such

information, except as authorized by Title

26 of the United States Code.

Section 6103(p)(3) requires the IRS to

maintain permanent standardized records

of all requests for inspection or disclosure

of returns or return information under section 6104(c) and of all such information

inspected or disclosed pursuant to those

requests.

Section 6103(p)(4) requires an ASO, as

a condition for receiving returns or return

information under section 6104(c), to

establish and maintain certain safeguards,

such as keeping permanent standardized

records of all requests and disclosures,

maintaining a secure information storage

area, restricting access to the information,

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and providing whatever other safeguards

the IRS deems necessary to protect the

confidentiality of the information. See

§301.6103(p)(4)-1 and IRS Publication

1075, “Tax Information Security Guidelines for Federal, State and Local Agencies”. Publication 1075 is available at

http://www.irs.gov/formspubs.

The PPA also amended sections 7213,

7213A, and 7431 to impose civil and

criminal penalties for the unauthorized

disclosure or inspection of section 6104(c)

information.

4. IRS Disclosure Procedures

Under section 6103(p)(4)(E), before

a Federal or State agency may receive

returns and return information from the

IRS under section 6103 or section 6104,

it must file with the IRS a report detailing

the physical, administrative, and technical

safeguards implemented by the agency

to protect this information from unauthorized inspection or disclosure. Only upon

approval of these safeguards by the IRS,

as well as satisfaction of any other statutory requirements (such as submission of

a written request), may an agency receive

the information to which it is entitled

under the Code, and then only for the use

specified by the relevant statute.

Under various disclosure programs,

the IRS and other Federal and State agencies often execute disclosure agreements

detailing the responsibilities of the parties and the terms and parameters of the

disclosure arrangement. For example,

under section 6103(d), the IRS executes

a disclosure agreement with each State

tax agency to which it discloses information. This agreement, which serves as

the written request required by section

6103(d), has been the foundation of the

State tax disclosure program under this

provision since the Tax Reform Act of

1976.

After the enactment of the PPA, the IRS

revised its disclosure procedures under

section 6104(c), as set forth in the Internal Revenue Manual, to model them after

the section 6103(d) program. Accordingly,

the section 6104(c) program uses a disclosure agreement patterned after the section

6103(d) agreement but tailored to the specific requirements and restrictions of section 6104(c).

August 29, 2022

Summary of Comments and

Explanation of Provisions

As noted in the Background, one commenter submitted a letter commenting on

the NPRM. After considering the comments in the letter, the NPRM is adopted by

this Treasury decision with one clarifying

substantive change to §301.6104(c)-1(h)

of the proposed regulations (proposed

§301.6104(c)-1(h)) and various non-substantive clarifying changes.

1. Security, Confidentiality, and Use

Restrictions

The commenter’s primary concern is

the requirement that all disclosures under

section 6104(c) must be made pursuant

to an agreement committing the ASO

to the security, confidentiality, and use

restrictions of section 6103(p)(4), which

the commenter characterizes as onerous.

The commenter acknowledges, however,

that the changes it seeks require legislative action by Congress. The Treasury

Department and the IRS agree that the

proposed regulations implement the statutory regime enacted by Congress. Thus,

these final regulations adopt the safeguard

requirements as proposed.

As a threshold matter, the commenter asserts that only a few states have

entered into disclosure agreements due

to what the commenter characterizes as

the cumbersome nature of the safeguard

requirements of section 6103(p) and the

resources needed to adhere to them. In

the commenter’s view, the reluctance

of states to commit themselves to the

safeguard requirements of section 6103

means that the PPA actually decreased

the disclosure of information to the states

because non-participating states no longer

receive the pre-PPA notifications of final

denials, revocations, and notices of tax

deficiencies.

The Treasury Department and the

IRS do not agree with the proposition

that few states are willing to participate

in IRS information-sharing programs

because of the safeguard requirements.

As noted in the Background, the section

6104(c) agreement, under which the IRS

discloses certain information to the ASO

who is charged with the administration

of the State’s laws regulating charitable

August 29, 2022

organizations or the solicitation or administration of charitable funds or assets, is

based on the section 6103(d) agreement,

under which the IRS discloses certain

information to the State office charged

with the responsibility for administering

the State’s tax laws. Under both section

6104(c) and section 6103(d), the receipt

of information from the IRS is conditioned on the recipient agency or official

implementing and adhering to the applicable provisions of section 6103(p), as

amended by the PPA, to protect the information from unauthorized inspection or

disclosure.

The IRS currently has a section 6103(d)

agreement in each of the 50 states and the

District of Columbia with the agency or

official responsible for administering that

jurisdiction’s tax laws. In addition, the

IRS currently has section 6104(c) agreements with 9 ASOs, all of whom are State

tax officers responsible for administering State tax laws. For sample disclosure

agreements, see Internal Revenue Manual Exhibit 7.28.2-2 (Sample Disclosure

Agreement under section 6104(c) for State

Tax Officer) and Exhibit 7.28.2-1 (Sample Disclosure Agreement under section

6104(c) for Attorney General’s Office).

In view of the current participation in the

section 6104(c) disclosure program, and

considering the potential for increased

participation by other ASOs, the Treasury

Department and the IRS consider the publication of these final regulations important in fulfilling the mandate under section

6104(c) to facilitate the enforcement of

State law regarding exempt organizations

consistent with statutory requirements.

2. Information Shared Without a

Disclosure Agreement

The commenter, citing proposed

§301.6104(c)-1(b), which provides that

the IRS may require an ASO to execute

a disclosure agreement or similar document, states that it is not clear what, if any

information – other than that available to

the general public – would be disclosed to

ASOs without an agreement.

Under section 6104(c) before its

amendment by the PPA, the IRS was

required to disclose to ASOs certain final

determinations, with no requirement

that the ASO request such disclosure in

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writing. The PPA changed this procedure,

making all of section 6104(c) subject to

the confidentiality provisions of section

6103. These final regulations provide that

the IRS may not disclose information

under section 6104(c) unless the State

receiving the information follows the

applicable disclosure, recordkeeping, and

safeguard procedures of section 6103(p)

(4). To give effect to the confidentiality

restrictions mandated by Congress, the

IRS’s disclosure program requires an ASO

to enter into a disclosure agreement with

the IRS stipulating the procedures for disclosure under section 6104(c), as well as

the restrictions on use and redisclosure.

Because of these statutory requirements,

without such an agreement, an ASO may

receive only information otherwise available to the public.

3. Use of Disclosed Information

The commenter objects to proposed

§301.6104(c)-1(h)(1), which requires

an ASO intending to use any disclosed

information in a State administrative or

judicial proceeding to notify the IRS of

this intention before such use. Under this

provision, an ASO may use the information as intended only in accordance with

any conditions the IRS might impose,

and only to the extent that the IRS determines that the disclosure would not seriously impair Federal tax administration.

The commenter states that by disclosing

taxpayer information initially to an ASO,

the IRS already has determined under proposed §301.6104(c)-1(e) that this information will not seriously impair Federal

tax administration and that requiring the

same determination again after the initial

disclosure would place an ASO at risk of

spending time and resources on developing a State law case, only to be told by

the IRS that the ASO cannot proceed. The

commenter asserts that, in an environment of scarce resources, this restriction

is likely to discourage ASOs from taking

that risk.

Section 6104(c)(5) prohibits the disclosure under section 6104(c)(1) through

(3) of returns and return information to an

ASO, or redisclosure of such information

by an ASO in a State proceeding described

in section 6104(c)(4), if the IRS determines that such disclosure or redisclosure

Bulletin No. 2022–35

would seriously impair Federal tax administration. Section 6104(c)(5) addresses

two separate actions or events, requiring

in most circumstances two separate determinations by the IRS. Because the facts

and circumstances surrounding a particular administrative or judicial proceeding

typically would not be known to the IRS

at the time of the initial disclosure of taxpayer information to an ASO, it would not

be possible during the initial disclosure to

the ASO for the IRS to determine whether

the use of that information in a subsequent State proceeding would seriously

impair Federal tax administration (such

as identifying a confidential informant

or compromising a civil or criminal tax

investigation). It is possible that the IRS

could determine that the disclosure to an

ASO would not seriously impair Federal

tax administration but that disclosure by

an ASO in a State proceeding would. To

fulfill its statutory duties, the IRS must

evaluate the effect of the use of disclosed

information in a State proceeding before

authorizing any such redisclosure.

4. Restrictions on Redisclosure

The commenter states that the prohibition in proposed §301.6104(c)-1(h)

(2) on the redisclosure of return information to an ASO’s agent or contractor

appears to include persons such as expert

witnesses, court reporters, and other litigation support service providers often

necessary to conduct civil and judicial

proceedings within the ambit of proposed §301.6104(c)-1(g)(2), as limited

by proposed §301.6104(c)-1(h)(1), which

is discussed in the prior section of this

Summary of Comments and Explanation

of Provisions. The commenter contends

that this restriction is “simply untenable”

and serves to “further undercut any rational basis” for ASOs to obtain returns and

return information under section 6104(c).

The

requirement

proposed

§301.6104(c)-1(h)(1) that an ASO notify

the IRS before using any disclosed information in a State proceeding is a limit on

the authority of the ASO under proposed

§301.6104(c)-1(g)(2) to make such use of

disclosed information under rules similar to

those in section 6103(h)(4), as provided in

section 6104(c)(4). With respect to section

6103(h)(4), the IRS construes “disclosure

Bulletin No. 2022–35

in judicial and administrative proceedings” to include the disclosure of returns

and return information in court during a

trial (whether or not some of those present might be considered an agent or contractor, such as a court reporter or expert

witness); in formal or informal discovery,

including depositions; in settlement negotiations; and in mediation or arbitration proceedings. Disclosure of returns and return

information is permitted to participants in,

or parties to, a judicial or administrative

proceeding (including expert witnesses)

under practices and procedures generally

applicable to the proceeding, and subject to

rules governing the proceeding. The prohibition in proposed §301.6104(c)-1(h)(2) on

the redisclosure of return information to an

ASO’s agent or contractor was not intended

to hinder a State’s ability to conduct investigations or civil litigation under its statutory authority.

In considering this comment regarding

the interaction of the two redisclosure limitations of proposed §301.6104(c)-1(h),

however, it became apparent that, by

identifying the agent-contractor disclosure prohibition as one of two limitations on the redisclosure of returns and

return information by an ASO, proposed

§301.6104(c)-1(h)(2) might be read as

limiting the application of such a restriction solely to redisclosures. The prohibition on disclosing to agents and contractors, however, is a broader rule, applying

both to initial disclosures by the IRS as

well as to subsequent redisclosures by an

ASO. With respect to disclosures by the

IRS, proposed §301.6104(c)-1(f)(1)(ii)

provides that the IRS may disclose return

information to someone other than the

ASO only if that person is a State officer

or employee designated by the ASO. With

respect to redisclosures by an ASO, proposed §301.6104(c)-1(g)(1) provides that

an ASO who receives information from

the IRS under section 6104(c) may redisclose that information for certain purposes

to another State officer or employee. The

legislative history of section 6104(c) provides that the term “officer or employee”

does not include agents and contractors, and the final regulations apply this

agent-contractor disclosure prohibition

equally to the IRS and the ASO.

Consequently, these final regulations clarify the proper application of

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the prohibition against disclosure to

agents and contractors by eliminating proposed §301.6104(c)-1(h)(2) and

adding definitional clauses to proposed

§301.6104(c)-1(f)(1)(ii) and (g)(1) and

(2) emphasizing that the agent-contractor

disclosure prohibition applies both to IRS

disclosures and to ASO redisclosures.

5. Application of Document Retention

and Freedom-of-Information Laws

The commenter notes that many

states have document retention and freedom-of-information laws that might be

implicated whenever an ASO receives or

acts upon tax return information acquired

from the IRS. According to the commenter, nothing in the PPA or regulations

addresses what portions of tax return

information may become a part of the

ASO’s own records or work product.

This issue, however, is addressed by

section 6103, made applicable to section

6104(c) by the PPA. Among the disclosure,

recordkeeping, and safeguard provisions of

section 6103, section 6103(p)(4) requires

an ASO, as a condition for receiving

returns or return information under section

6104(c), to establish and maintain certain

safeguards, such as keeping permanent

standardized records of all requests and

disclosures, maintaining a secure information storage area, restricting access to the

information, and providing whatever other

safeguards the IRS deems necessary to protect the confidentiality of the information.

Upon completion of the ASO’s use of the

returns or return information it receives

under section 6104(c), section 6103(p)(4)

(F) requires the ASO to return the information, along with any copies, to the IRS,

or to render it undisclosable and report to

the IRS how it was so rendered. Rendering

returns and return information undisclosable requires the ASO to physically destroy

the information. Thus, after its use, any

information an ASO receives from the IRS

under section 6104(c) should no longer be

in the ASO’s possession and, so, will not

become part of the ASO’s own records or

work product.

6. Designation by Attorney General

Referring to the definition of an ASO

in section 6104(c)(6)(B)(iv) (in the case

August 29, 2022

of tax-exempt entities other than charitable organizations or Federal instrumentalities), the commenter states that it is

not clear in what circumstances an attorney general would designate the agency

responsible for overseeing charitable

solicitation. If, for example, the authority to designate the head of the agency

responsible for overseeing charitable

solicitation is vested in the secretary of

state, the agency head referred to in the

statute and the regulations would not be

able to meet the definition of an ASO in

proposed §301.6104(c)-1(i)(1)(iv).

In light of the variations in State laws,

it is doubtful that Congress used the term

“designate” in section 6104(c)(6)(B)(iv)

to mean a delegation of legal authority

(and there is no indication in the legislative history of the PPA that such a meaning

was intended). In contrast to how the term

is used in section 6104(c)(2)(C) (dealing

with the procedures for disclosure), where

it does mean to delegate authority, the

term “designate” in section 6104(c)(6)(B)

(iv) is a generic one, meaning the ability

to specify, identify, or acknowledge the

head of the agency in a particular State

who is responsible for overseeing charitable solicitation. The attorney general,

as an ASO under §301.6104(c)-1(i)(1)(i),

should be able to identify such an agency

head, whether or not the attorney general

is able to confer the requisite authority on

any particular State official.

Special Analyses

This regulation is not subject to review

under section 6(b) of Executive Order

12866 pursuant to the Memorandum of

Agreement (April 11, 2018) between the

Department of the Treasury and the Office

of Management and Budget regarding

review of tax regulations.

Pursuant to the Regulatory Flexibility Act (RFA) (5 U.S.C. chapter 6), it is

hereby certified that these final regulations will not have a significant economic

impact on a substantial number of small

entities within the meaning of section

601(6) of the Regulatory Flexibility Act.

The analysis requirements of the RFA

do not apply because states are not considered small entities for purposes of the

RFA. Therefore, a regulatory flexibility

analysis is not required. Accordingly, the

August 29, 2022

Secretary of the Treasury’s delegate certifies that these regulations will not have a

significant economic impact on a substantial number of small entities.

Pursuant to section 7805(f) of the

Code, the notice of proposed rulemaking preceding these final 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. No comments were

received from the Chief Counsel for the

Office of Advocacy of the Small Business

Administration.

Drafting Information

The principal author of these regulations is Seth Groman of the Office of

Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes), though other persons in the

Treasury Department and the IRS participated in their development.

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, 26 CFR part 301 is

amended as follows:

PART 301—PROCEDURE AND

ADMINISTRATION

Paragraph 1. The authority citation for

part 301 is amended by adding an entry

for §301.6104(c)-1 in numerical order to

read in part as follows:

Authority: 26 U.S.C. 7805 * * *

*****

Section 301.6104(c)-1 also issued

under 26 U.S.C. 6104(c).

*****

Par. 2. Section 301.6104(c)-1 is revised

to read as follows:

§ 301.6104(c)-1 Disclosure of certain

information to State officials.

(a) In general—(1) Charitable organizations and applicants. Subject to the

176

disclosure, recordkeeping, and safeguard

provisions of section 6103 of the Internal

Revenue Code (Code), and only as necessary to administer State laws regulating

charitable organizations, upon written

request by an appropriate State officer

(ASO, as defined in paragraph (i)(1) of

this section), the Internal Revenue Service

(IRS) may, under section 6104(c)(1) and

(2), disclose or make available to the ASO

(or to a person designated by the ASO as

provided in paragraph (f)(1)(ii) of this

section) the returns and return information

described in paragraph (c) of this section

with respect to—

(i) Any organization described or formerly described in section 501(c)(3) and

exempt or formerly exempt from taxation

under section 501(a) (a charitable organization); or

(ii) Any organization that has applied for

recognition as an organization described

in section 501(c)(3) (an applicant).

(2) Section 501(c) organizations not

described in section 501(c)(1) or (3).

Subject to the disclosure, recordkeeping,

and safeguard provisions of section 6103,

and upon written request by an ASO, the

IRS may disclose or make available to the

ASO (or to a person designated by the

ASO as provided in paragraph (f)(1)(ii)

of this section) under section 6104(c)(3)

returns and return information regarding

any organization described or formerly

described in section 501(c) other than

section 501(c)(1) or (3). Such information

will be disclosed or made available only

as necessary to administer State laws regulating the solicitation or administration

of the charitable funds or charitable assets

of these organizations.

(b) Disclosure agreement. The IRS may

require an ASO to execute a disclosure

agreement or similar document specifying

the procedures, terms, and conditions for

the disclosure or inspection of information

under section 6104(c), including compliance with the safeguards prescribed by

section 6103(p)(4), as well as specifying

the information to be disclosed. Such an

agreement or similar document constitutes

the request for disclosure required by section 6104(c)(1)(C), as well as the written

request required by section 6104(c)(2)(C)

(i) and (c)(3).

organizations and applicants—(1) In

Bulletin No. 2022–35

general. With respect to any organization

described in paragraph (d) of this section,

the IRS may disclose or make available

for inspection under section 6104(c)(1)

and (2) and paragraph (a)(1) of this section to an ASO the following returns and

return information with respect to a charitable organization or applicant:

(i) A refusal or proposed refusal to

recognize an organization’s exemption as

a charitable organization (a final or proposed denial letter).

(ii) Return information regarding a

grant of exemption following a proposed

denial.

(iii) A revocation of exemption as a

charitable organization (a final revocation

letter), including a notice of termination or

dissolution.

(iv) A proposed revocation of recognition of exemption as a charitable organization (a proposed revocation letter).

(v) Return information regarding the

final disposition of a proposed revocation of recognition other than by final

revocation.

(vi) A notice of deficiency or proposed

notice of deficiency of tax imposed under

section 507 or chapter 41 or 42 of the

Code on the organization or on a taxable

person (as described in paragraph (i)(4) of

this section).

(vii) Returns and return information

regarding the final disposition of a proposed notice of deficiency of tax imposed

under section 507 or chapter 41 or 42 of

the Code on the organization other than by

issuance of a notice of deficiency.

(viii) The names, addresses, and taxpayer identification numbers of applicants for charitable status, provided on an

applicant-by-applicant basis or by periodic lists of applicants. Under this paragraph (c)(1)(viii), the IRS may respond

to inquiries from an ASO as to whether

a particular organization has applied for

recognition of exemption as a charitable

organization.

(ix) Return information regarding the

final disposition of an application for

recognition of exemption where no proposed denial letter is issued, including

whether the application was withdrawn or

whether the applicant failed to establish

its exemption.

(x) Returns and return information relating to the return information described in

Bulletin No. 2022–35

paragraph (c)(1) of this section, except for

returns and return information relating to

proposed notices of deficiency described

in paragraph (c)(1)(vi) of this section with

respect to taxable persons.

(2) Disclosure of evidence of noncompliance with certain State laws. With

respect to any organization described

in paragraph (d) of this section, the IRS

may disclose to the ASO or make available for the ASO’s inspection under section 6104(c)(1) and (2) and paragraph (a)

(1) of this section the returns and return

information of a charitable organization

or applicant, as listed in paragraph (c)

(1) of this section, if the IRS determines

that such information might constitute

evidence of noncompliance with the laws

under the jurisdiction of the ASO regulating charitable organizations and applicants. Such information may be disclosed

on the IRS’s own initiative, subject to the

disclosure, recordkeeping, and safeguard

provisions of section 6103. Disclosures

under this paragraph (c)(2) may be made

before the IRS issues a proposed determination (denial of recognition, revocation,

or notice of deficiency) or any other action

by the IRS described in this section.

(d) Organizations to which disclosure applies. Regarding the information

described in paragraphs (a)(1) and (2) of

this section, the IRS will disclose or make

available for inspection to an ASO such

information only with respect to—

(1) An organization formed under the

laws of the ASO’s State;

(2) An organization, the principal office

of which is located in the ASO’s State;

(3) An organization that, as determined

by the IRS, is or might be subject to the

laws of the ASO’s State regulating charitable organizations or the solicitation or

administration of charitable funds or charitable assets; or

(4) A private foundation required by

§1.6033-2(a)(iv) of this chapter to list the

ASO’s State on any of the foundation’s

returns filed for its last five taxable years.

(e) Disclosure limitations. Notwithstanding any other provision of this section, the IRS will not disclose or make

available for inspection under section

6104(c) any information, the disclosure

of which it determines would seriously

impair Federal tax administration, including, but not limited to—

177

(1) Identification of a confidential

informant or interference with a civil or

criminal tax investigation; and

(2) Information obtained pursuant to

a tax convention, as defined in section

6105(c)(2), between the United States and

a foreign government.

(f) Disclosure recipients—(1) In general. The IRS may disclose returns and

return information under section 6104(c)

to, or make it available for inspection by—

(i) An ASO, as defined in paragraph (i)

(1) of this section, or

(ii) A person other than an ASO, but

only if that person is a State officer or

employee (which excludes an agent or

contractor) designated by the ASO to

receive information under section 6104(c)

on behalf of the ASO, as specified in paragraph (f)(2) of this section.

(2) Designation by ASO. An ASO may

designate State officers or employees to

receive information under section 6104(c)

on the ASO’s behalf by specifying in writing each person’s name and job title, and

the name and address of the person’s office.

The ASO must promptly notify the IRS in

writing of any additions, deletions, or other

changes to the list of designated persons.

(g) Redisclosure—(1) In general. An

ASO to whom a return or return information has been disclosed may thereafter

disclose such information to another State

officer or employee (which excludes an

agent or contractor) only as necessary to

administer State laws governing charitable

organizations or State laws regulating the

solicitation or administration of charitable

funds or charitable assets of noncharitable

exempt organizations.

(2) Civil administrative or judicial

proceedings. Except as provided in paragraph (h) of this section, an ASO to whom

a return or return information has been

disclosed may thereafter disclose such

information to another State officer or

employee (which excludes an agent or

contractor) who is personally and directly

preparing for a civil proceeding before

a State administrative body or court in a

matter involving the enforcement of State

laws regulating organizations with respect

to which information can be disclosed

under this section, solely for use in such a

proceeding, but only if—

(i) The organization or a taxable person is a party to the proceeding, or the

August 29, 2022

proceeding arose out of, or in connection

with, determining the civil liability of the

organization or a taxable person, or collecting such civil liability, under State

laws governing organizations with respect

to which information can be disclosed

under this subsection;

(ii) The treatment of an item reflected

on such a return is directly related to the

resolution of an issue in the proceeding; or

(iii) The return or return information

directly relates to a transactional relationship between the organization or a taxable

person and a person who is a party to the

proceeding that directly affects the resolution of an issue in the proceeding.

(h) Redisclosure limitation. Before disclosing any return or return information

received under section 6104(c) in a proceeding described in paragraph (g)(2) of

this section, the ASO must notify the IRS

of the intention to make such a disclosure.

No State officer or employee may make

such a disclosure except in accordance

with any conditions the IRS might impose

in response to the ASO’s notice of intent.

No such disclosure may be made if the IRS

determines that the disclosure would seriously impair Federal tax administration.

(i) Definitions. For purposes of section

6104(c) and this section—

(1) Appropriate State officer or ASO

means—

(i) The State attorney general;

(ii) The State tax officer;

(iii) With respect to a charitable organization or applicant, any State officer

August 29, 2022

other than the attorney general or tax officer charged with overseeing charitable

organizations, provided that the officer

shows the IRS that the officer is an ASO

by presenting a letter from the State attorney general describing the functions and

authority of the officer under State law,

with sufficient facts for the IRS to determine that the officer is an ASO; and

(iv) With respect to a section 501(c)

organization that is not described in section 501(c)(1) or (c)(3), the head of the

agency designated by the State attorney

general as having primary responsibility

for overseeing the solicitation of funds

for charitable purposes, provided that the

officer shows the IRS that the officer is an

ASO by presenting a letter from the State

attorney general describing the functions

and authority of the officer under State

law, with sufficient facts for the IRS to

determine that the officer is an ASO.

(2) Return has the same meaning as in

section 6103(b)(1).

(3) Return information has the same

meaning as in section 6103(b)(2).

(4) Taxable person means any person who is liable or potentially liable for

excise taxes under chapter 41 or 42 of the

Code. Such a person includes—

(i) A disqualified person described in

section 4946(a)(1), 4951(e)(4), or 4958(f);

(ii) A foundation manager described in

section 4946(b);

(iii) An organization manager described

in section 4955(f)(2) or 4958(f)(2);

178

(iv) A person described in section

4958(c)(3)(B);

(v) An entity manager described in section 4965(d); and

(vi) A fund manager described in section 4966(d)(3).

(j) Failure to comply. Upon a determination that an ASO has failed to comply

with the requirements of section 6103(p)

(4), the IRS may take the actions it deems

necessary to ensure compliance, including

the refusal to disclose any further returns

or return information to the ASO until

the IRS determines that the requirements

of section 6103(p)(4) have been met. For

procedures for the administrative review

of a determination that an authorized

recipient has failed to safeguard returns

or return information, see §301.6103(p)

(7)-1.

(k) Applicability date. The rules of

this section apply on and after August 16,

2022.

Douglas W. O’Donnell,

Deputy Commissioner for Services

and Enforcement.

Approved: June 7, 2022.

Lily Batchelder,

Assistant Secretary of the Treasury

(Tax Policy).

(Filed by the Office of the Federal Register on August

15, 2022, 8:45 a.m., and published in the issue of the

Federal Register for August 16, 2022, 87 F.R. 50240)

Bulletin No. 2022–35

Part IV

Announcement of

Disciplinary Sanctions

From the Office of

Professional Responsibility

Announcement 2022-17

The Office of Professional Responsibility (OPR) announces recent disciplinary sanctions involving attorneys, certified public accountants, enrolled agents,

enrolled actuaries, enrolled retirement

plan agents, appraisers, and unenrolled/

unlicensed return preparers (individuals

who are not enrolled to practice and are

not licensed as attorneys or certified public accountants). Licensed or enrolled

practitioners are subject to the regulations

governing practice before the Internal

Revenue Service (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 are subject to

Revenue Procedure 81-38 and superseding guidance in Revenue Procedure 201442, which govern 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 voluntarily participate in the Annual Filing Season Program under Revenue Procedure

2014-42 agree to be subject to the duties

and restrictions in Circular 230, including

the restrictions on incompetent or disreputable conduct.

The disciplinary sanctions to be

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.

Suspended from practice before the

IRS—An individual who is suspended is

Bulletin No. 2022–35

not eligible to practice before the IRS as

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

the term of the suspension.

Censured in practice before the

IRS—Censure is a public reprimand.

Unlike disbarment or suspension, censure

does not affect an individual’s eligibility

to practice before the IRS, but 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 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.

Ineligible for limited practice—An

unenrolled/unlicensed return preparer

who fails to comply with the requirements

in Revenue Procedure 81-38 or to comply

with Circular 230 as required by Revenue

Procedure 2014-42 may be determined

ineligible to engage in limited practice as

a representative of any 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 after hearing—An administrative law judge (ALJ) issued a decision

imposing one of these sanctions after the

ALJ either (1) granted the government’s

summary judgment motion or (2) conducted an evidentiary hearing upon OPR’s

complaint alleging violation of the regulations. After 30 days from the issuance of

the decision, in the absence of an appeal,

179

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 OPR’s complaint was filed, granted OPR’s motion for

a default judgment and issued a decision

imposing one of these sanctions.

Disbarment 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 appeal authority,

acting as the delegate of the Secretary

of the Treasury, and the appeal 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 a consent to one of these sanctions and OPR

accepted the offer. 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 OPR a petition for reinstatement

affirming compliance with the terms of

the consent 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, Suspended by consent in

expedited proceeding—OPR instituted

an expedited proceeding for suspension

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

and criminal convictions).

Determined ineligible for limited

practice—There has been a final determination that an unenrolled/unlicensed

August 29, 2022

return preparer is not eligible for limited

representation of any taxpayer because the

preparer violated standards of conduct or

failed to comply with any of the requirements to act as a representative.

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 individual’s petition for reinstatement has been granted. The agent,

and eligible to practice before the IRS, or

in the case of an appraiser, the individual

is no longer disqualified.

Reinstated to engage in limited practice before the IRS—The individual’s

petition for reinstatement has been granted.

The individual is an unenrolled/unlicensed

return preparer and eligible to engage in

limited practice before the IRS, subject to

requirements the IRS has prescribed for

limited practice by tax return preparers.

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; (2) the individual has settled a

disciplinary case by signing 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, failure

to file Federal income tax returns, lack of

due diligence, conflict of interest, etc.); (3)

OPR has issued a decision in an expedited

proceeding for indefinite suspension; or

(4) OPR has made a final determination

(including any decision on appeal) that an

unenrolled/unlicensed return preparer is

ineligible to represent any taxpayer before

the IRS.

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

West

Hollywood

Godin, Randy

Attorney

Suspended by decision in

expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

June 7, 2022

Call, Ryan R.

Attorney

Suspended by default decision in

expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

June 21, 2022

Wechsler, Barry S.

CPA

Suspended by default decision in

expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

May 5, 2022

Howieson, Richard A.

Attorney

Suspended by default decision in

expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

May 5, 2022

Colorado

Denver

New Jersey

East

Brunswick

New Mexico

Costilla

August 29, 2022

180

Bulletin No. 2022–35

City & State

Name

Professional

Designation

Disciplinary Sanction

Effective Date(s)

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)

Indefinite from

June 14, 2022

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

June 7, 2022

New York

Donnelly, Sarah P. (aka Sarah

Maya Pillay), see Texas

Oregon

Albany

Perdue, Richard D.

CPA

Sherwood

Bopp, Carol A.

CPA

Texas

Dallas

Donnelly, Sarah P. (aka Sarah Attorney

Maya Pillay)

Houston

Eureste, Arthur R.

Attorney

Snyder

Fair, Jean M.

Attorney

Bulletin No. 2022–35

181

Indefinite from

June 21, 2022

Indefinite from

May 20, 2022

Indefinite from

June 14, 2022

August 29, 2022

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. 2022–35

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.

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.

August 29, 2022

Numerical Finding List1

Bulletin 2022–35

Announcements:

2022-14, 2022-31 I.R.B. 136

2022-15, 2022-31 I.R.B. 136

2022-16, 2022-33 I.R.B. 144

2022-17, 2022-35 I.R.B. 179

Notices:

2022-29, 2022-28 I.R.B. 66

2022-30, 2022-28 I.R.B. 70

2022-31, 2022-29 I.R.B. 85

2022-32, 2022-32 I.R.B. 137

2022-33, 2022-34 I.R.B. 147

2022-34, 2022-34 I.R.B. 150

Proposed Regulations:

REG-130975-08, 2022-28 I.R.B. 71

REG 130675-17, 2022-30 I.R.B. 104

Revenue Procedures:

2022-25, 2022-27 I.R.B. 3

2022-28, 2022-27 I.R.B. 65

2022-26, 2022-29 I.R.B. 90

2022-32, 2022-30 I.R.B. 101

2022-30, 2022-31 I.R.B. 112

2022-29, 2022-33 I.R.B. 141

2022-34, 2022-33 I.R.B. 143

Revenue Rulings:

2022-12, 2022-27 I.R.B. 1

2022-13, 2022-30 I.R.B. 99

2022-14, 2022-31 I.R.B. 110

2022-15, 2022-35 I.R.B. 152

2022-16, 2022-35 I.R.B. 171

Treasury Decisions:

9963, 2022-34 I.R.B. 145

9964, 2022-35 I.R.B. 172

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2021–27 through 2021–52 is in Internal Revenue Bulletin

2021–52, dated December 27, 2021.

August 29, 2022

Bulletin No. 2022–35

Finding List of Current Actions on

Previously Published Items1

Bulletin 2022–35

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2021–27 through 2021–52 is in Internal Revenue Bulletin

2021–52, dated December 27, 2021.

Bulletin No. 2022–35

iii

August 29, 2022

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

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