HIGHLIGHTS OF THIS ISSUE ADMINISTRATIVE EMPLOYEE PLANS EXEMPT ORGANIZATIONS The IRS Mission Introduction Part III Notice 2022-27 Part IV Announcement 2022-9 Announcement 2022-10 Definition of Terms Abbreviations Numerical Finding List1 Numerical Finding List Finding List of Current Actions on Previously Published Items1 How to get the Internal Revenue Bulletin INTERNAL REVENUE BULLETIN We Welcome Comments About the Internal Revenue Bulletin Internal Revenue Bulletin: 2022-22 May 31, 2022 HIGHLIGHTS OF THIS ISSUE These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations. ADMINISTRATIVE Announcement 2022-9, page 1153. 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. EMPLOYEE PLANS Notice 2022-27, page 1151. This notice is a 6-month extension of the relief provided in Notice 2020-42, as extended by Notice 2021-3 and Notice 2021-40. For the period from July 1, 2022, through December 31, 2022, this notice extends two types of relief from the physical presence requirement in § 1.401(a)-21(d)(6)(i) for participant elections required to be witnessed by a plan representative or a notary public: (1) temporary relief from the physical presence requirement for any participant election witnessed by a notary public in a state that permits remote notarization (either by law or through an executive order), and (2) temporary relief from the physical presence requirement for any participant election witnessed by a plan representative. EXEMPT ORGANIZATIONS Announcement 2022-10, page 1156. Revocation of IRC 501(c)(3) Organizations for failure to meet the code section requirements. Contributions made to the organizations by individual donors are no longer deductible under IRC 170(b)(1)(A). 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. Part III Extension of Temporary Relief from the Physical Presence Requirement Through December 31, 2022 Notice 2022-27 I. PURPOSE This notice provides a 6-month extension, through December 31, 2022, of the temporary relief provided in Notice 2021-40, 2021-28 IRB 15, from the requirement in § 1.401(a)-21(d)(6)(i) that certain participant elections be witnessed in the physical presence of a plan representative or a notary public (the physical presence requirement). This extension of relief is provided in response to the continuing Coronavirus Disease 2019 (COVID-19) pandemic. II. BACKGROUND A. Temporary Relief from the Physical Presence Requirement and Requests for Comments On March 13, 2020, the President determined that the COVID-19 pandemic was of sufficient severity and magnitude to warrant an emergency determination beginning March 1, 2020, under the Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. 5121-5207 (the national emergency). See 85 FR 15337. In response to the national emergency caused by the COVID-19 pandemic and related social distancing precautions, Notice 2020-42, 2020-26 IRB 986, provided temporary relief (through December 31, 2020) from the physical presence requirement for any participant election that was witnessed by a notary public or by a plan representative, using an electronic system that satisfied the applicable requirements specified in section III.A and B, respectively, of Notice 2020-42. Notice 2021-03, 2021-2 IRB 316, extended the temporary relief from the physical presence requirement through June 30, 2021, if the requirements specified in section III.A and B of Notice 2021-03 were satisfied (under terms that were identical to the requirements in section III.A and B of Notice 2020-42). Notice 2021-03 noted that, during the temporary relief period, a participant would still be able to have a participant election witnessed in the physical presence of a notary public and have that participant election be accepted by a plan in accordance with § 1.401(a)-21(d)(6)(i). Notice 2021-03 also requested comments on whether relief from the physical presence requirement should be made permanent and, if made permanent, what, if any, procedural safeguards would be necessary to reduce the risk of fraud, spousal coercion, or other abuse in the absence of the physical presence requirement. Notice 2021-03 further stated that any permanent modification of the physical presence requirement would be made through the regulatory process, thus providing an additional opportunity for stakeholders to provide comments. Notice 2021-40 extended the temporary relief from the physical presence requirement through June 30, 2022, if the applicable requirements specified in section III.A and B of Notice 2021-03 are satisfied. Notice 2021-40 also requested comments on specific matters relating to the relief from the physical presence requirement, including comments on whether to propose modifications to the physical presence requirement. B. Stakeholder Comments and Agency Review Following the publication of Notices 2020-42, 2021-03, and 2021-40, the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) received comments from numerous stakeholders regarding the physical presence requirement. Some stakeholders requested permanent relief from the physical presence requirement; other stakeholders stated that the existing physical presence requirement should be retained. The Treasury Department and the IRS are currently reviewing the stakeholder comments to determine whether to retain the physical presence requirement without modification or to propose to modify the requirement. If the Treasury Department and the IRS decide to propose to modify the physical presence requirement, they will do so only through the regulatory process, which will include the opportunity for further comment. C. Continuing COVID-19 Pandemic On February 18, 2022, the President determined that the COVID-19 pandemic continued to cause a significant risk to public health and safety and extended the national emergency beyond March 1, 2022. See 87 FR 10289. Accordingly, section III of this notice provides an additional 6-month extension, through December 31, 2022, of the temporary relief from the physical presence requirement provided in Notice 2021-40. However, in light of recent easing of public health precautions relating to the COVID-19 pandemic, a further extension of temporary relief from the physical presence requirement beyond the end of 2022 is not expected to be necessary. III. EXTENSION OF TEMPORARY RELIEF FROM THE PHYSICAL PRESENCE REQUIREMENT This notice extends, for the 6-month period from July 1, 2022, through December 31, 2022, the temporary relief from the physical presence requirement provided in Notice 2021-40, including extension of the requirements to qualify for that relief. Accordingly, for this 6-month period, a plan may qualify for relief from the physical presence requirement for any participant election witnessed by a notary public or a plan representative, using an electronic system that satisfies the applicable requirements specified in section III.A and B, respectively, of Notice 2021-03. IV. EFFECT ON OTHER DOCUMENTS Notice 2021-40 is modified. V. DRAFTING INFORMATION The principal author of this notice is Tyler Forni of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes). For further information regarding this notice, contact Tyler Forni at (202) 317-4102 (not a toll-free number). Part IV Announcement of Disciplinary Sanctions From the Office of Professional Responsibility Announcement 2022-9 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 2014-42, 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 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, 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 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 Bradford, Dwayne T., see Maine Studio City Krell, Steven CPA Reinstated to practice before the IRS, effective March 10, 2022 Stockton Lagorio, Kevin V. CPA Suspended by decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from March 24, 2022 Turlock Puffer, Robert N. CPA Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from March 24, 2022 Garden Grove Lee, Michael H. Enrolled Agent Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from January 14, 2022 Colorado Sterling Moter, Laverne C. CPA Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from March 24, 2022 District of Columbia (DC) Tantillo, Brent S., see Florida Florida Jacksonville Kaleel, K. Mark CPA Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from March 24, 2022 Tantillo, Brent S. Attorney Suspended by decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from January 28, 2022 City & State Name Professional Designation Disciplinary Sanction Effective Date(s) Georgia Marietta Garner, Carl S. CPA Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from February 10, 2022 Williams, Gary R., see Tennessee Louisiana Jones, II, James G., see Texas Maine Falmouth Bradford, Dwayne T. CPA Suspended by decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from January 14, 2022 Missouri Lebanon Richardson, Douglas A. CPA Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from March 24, 2022 New York New York Klein, Mitchell L. CPA Suspended by consent for admitted violations of 31 C.F.R. §§ 10.51(a)(2) and 10.51(a)(3) Indefinite from January 21, 2022 Tennessee Harrogate Williams, Gary R. CPA Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from January 14, 2022 Texas Dallas Davis, William P. Attorney Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from January 28, 2022 Houston Jones, II, James G. Attorney Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from January 14, 2022 Virginia Midlothian Wildes, Richard H. CPA Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from February 10, 2022 Announcement 2022-10 Deletions From Cumulative List of Organizations, Contributions to Which are Deductible Under Section 170 of the Code Table of Contents The Internal Revenue Service has revoked its determination that the organizations listed below qualify as organizations described in sections 501(c)(3) and 170(c)(2) of the Internal Revenue Code of 1986. Generally, the IRS will not disallow deductions for contributions made to a listed organization on or before the date of announcement in the Internal Revenue Bulletin that an organization no longer qualifies. However, the IRS is not precluded from disallowing a deduction for any contributions made after an organization ceases to qualify under section 170(c)(2) if the organization has not timely filed a suit for declaratory judgment under section 7428 and if the contributor (1) had knowledge of the revocation of the ruling or determination letter, (2) was aware that such revocation was imminent, or (3) was in part responsible for or was aware of the activities or omissions of the organization that brought about this revocation. If on the other hand a suit for declaratory judgment has been timely filed, contributions from individuals and organizations described in section 170(c)(2) that are otherwise allowable will continue to be deductible. Protection under section 7428(c) would begin on May 31, 2022 and would end on the date the court first determines the organization is not described in section 170(c)(2) as more particularly set for in section 7428(c)(1). For individual contributors, the maximum deduction protected is $1,000, with a husband and wife treated as one contributor. This benefit is not extended to any individual, in whole or in part, for the acts or omissions of the organization that were the basis for revocation. NAME OF ORGANIZATION Effective Date of Revocation LOCATION Charity Partners Network 1/1/2015 Sarasota, FL Renewable Home Foundation, Inc. 1/1/2017 Temecula, CA Safe Building Compliance and Technology 1/1/2020 Polk City, IA Love Mia Foundation, Inc. 1/1/2017 Miami, FL XC Foundation 1/1/2016 Pleasanton, CA Hope Services, Inc. 1/1/2017 Castle Pines, CO Arizona Horsemen’s Benevolent & Association 1/1/2016 Phoenix, AZ Idance Academi 1/1/2017 Jackson, MS New York Youth Club International, Inc. 1/1/2017 W. Hempstead, NY Zhenguo Beijing Opera House 5/1/2017 Pennington, NJ Their Last Best Place 1/1/2017 Livingston, MT The Development Corporation of Baton Rouge 3/1/2017 Nashville, TN Association League of Superfriends 1/1/2017 Harper Woods, MI MCGUFFEY YOUTH FOOTBALL 1/1/2018 Claysville, PA 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. 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. Numerical Finding List1 Numerical Finding List Bulletin 2022–22 Announcements: Article Issue Link Page 2022-3 2022-8 I.R.B. 2022-08 788 2022-4 2022-9 I.R.B. 2022-09 789 2022-5 2022-11 I.R.B. 2022-11 825 2022-6 2022-13 I.R.B. 2022-13 934 2022-7 2022-15 I.R.B. 2022-15 946 2022-8 2022-19 I.R.B. 2022-19 1056 2022-9 2022-22 I.R.B. 2022-22 1153 2022-10 2022-22 I.R.B. 2022-22 1156 AOD: Article Issue Link Page 2022-1 2022-06 I.R.B. 2022-06 466 2022-2 2022-12 I.R.B. 2022-12 903 Notices: Article Issue Link Page 2022-1 2022-02 I.R.B. 2022-02 304 2022-2 2022-02 I.R.B. 2022-02 304 2022-3 2022-02 I.R.B. 2022-02 308 2022-4 2022-02 I.R.B. 2022-02 309 2022-5 2022-05 I.R.B. 2022-05 457 2022-6 2022-05 I.R.B. 2022-05 460 2022-7 2022-06 I.R.B. 2022-06 469 2022-8 2022-07 I.R.B. 2022-07 491 2022-9 2022-10 I.R.B. 2022-10 811 2022-10 2022-10 I.R.B. 2022-10 815 2022-12 2022-12 I.R.B. 2022-12 906 2022-11 2022-14 I.R.B. 2022-14 939 2022-13 2022-14 I.R.B. 2022-14 940 2022-14 2022-14 I.R.B. 2022-14 941 2022-15 2022-18 I.R.B. 2022-18 1043 2022-16 2022-18 I.R.B. 2022-18 1044 2022-17 2022-18 I.R.B. 2022-18 1048 2022-18 2022-18 I.R.B. 2022-18 1048 2022-19 2022-18 I.R.B. 2022-18 1050 2022-21 2022-20 I.R.B. 2022-20 1057 2022-22 2022-20 I.R.B. 2022-20 1057 2022-23 2022-20 I.R.B. 2022-20 1062 2022-20 2022-21 I.R.B. 2022-21 1095 2022-24 2022-21 I.R.B. 2022-21 1097 2022-27 2022-22 I.R.B. 2022-22 1151 Proposed Regulations: Article Issue Link Page REG-118250-20 2022-07 I.R.B. 2022-07 753 REG-105954-20 2022-11 I.R.B. 2022-11 828 REG-114209-21 2022-11 I.R.B. 2022-11 898 REG-114209-21 2022-11 I.R.B. 2022-11 898 REG-121508-18 2022-15 I.R.B. 2022-15 996 REG-114339-21 2022-17 I.R.B. 2022-17 1030 REG-106384-20 2022-20 I.R.B. 2022-20 1076 REG-118913-21 2022-20 I.R.B. 2022-20 1089 REG-122770-18 2022-21 I.R.B. 2022-21 1104 Revenue Procedures: Article Issue Link Page 2022-1 2022-01 I.R.B. 2022-01 1 2022-2 2022-01 I.R.B. 2022-01 120 2022-3 2022-01 I.R.B. 2022-01 144 2022-4 2022-01 I.R.B. 2022-01 161 2022-5 2022-01 I.R.B. 2022-01 256 2022-7 2022-01 I.R.B. 2022-01 297 2022-9 2022-02 I.R.B. 2022-02 310 2022-11 2022-03 I.R.B. 2022-03 449 2022-8 2022-04 I.R.B. 2022-04 451 2022-10 2022-06 I.R.B. 2022-06 473 2022-13 2022-06 I.R.B. 2022-06 477 2022-12 2022-07 I.R.B. 2022-07 494 2022-14 2022-07 I.R.B. 2022-07 502 2022-15 2022-13 I.R.B. 2022-13 908 2022-17 2022-13 I.R.B. 2022-13 930 2022-17 2022-13 I.R.B. 2022-13 933 2022-20 2022-14 I.R.B. 2022-14 945 2022-21 2022-16 I.R.B. 2022-16 1015 2022-23 2022-18 I.R.B. 2022-18 1052 2022-24 2022-20 I.R.B. 2022-20 1075 2022-22 2022-21 I.R.B. 2022-21 1098 Revenue Rulings: Article Issue Link Page 2022-1 2022-02 I.R.B. 2022-02 301 2022-2 2022-04 I.R.B. 2022-04 451 2022-3 2022-06 I.R.B. 2022-06 467 2022-4 2022-10 I.R.B. 2022-10 790 2022-5 2022-10 I.R.B. 2022-10 792 2022-6 2022-12 I.R.B. 2022-12 904 2022-7 2022-14 I.R.B. 2022-14 935 2022-8 2022-14 I.R.B. 2022-14 936 2022-9 2022-18 I.R.B. 2022-18 1041 Treasury Decisions: Article Issue Link Page 9959 2022-03 I.R.B. 2022-03 328 9961 2022-03 I.R.B. 2022-03 430 9960 2022-07 I.R.B. 2022-07 481 9962 2022-11 I.R.B. 2022-11 823 1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin 2020–52, dated December 27, 2021. Finding List of Current Actions on Previously Published Items1 Bulletin 2022–22 How to get the Internal Revenue Bulletin INTERNAL REVENUE BULLETIN The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue Bulletins are available at www.irs.gov/irb/. We Welcome Comments About the Internal Revenue Bulletin If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave. NW, IR-6230 Washington, DC 20224.