HIGHLIGHTS OF THIS ISSUE ADMINISTRATIVE, INCOME TAX The IRS Mission Introduction Part III Rev. Proc. 2022-41 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: 2022-50 December 12, 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, INCOME TAX Rev. Proc. 2022-41, page 527. This revenue procedure specifies when information shown on a return in accordance with the applicable forms and instructions will be an adequate disclosure for purposes of reducing an understatement of income tax under section 6662(d) and for purposes of avoiding the section 6694(a) preparer penalty. This revenue procedure updates Rev. Proc. 2021-52, 2021-51 I.R.B. 883, and applies to any income tax return filed on 2022 tax forms for a taxable year beginning in 2022, and to any income tax return filed in 2023 on 2022 tax forms for short taxable years beginning in 2023. 26 CFR 601.105: Examination of returns and claims for refund, credit or abatement; determination of correct tax liability. (Also: Part 1, §§ 6662, 6694, 1.6662-4, 1.6694-2) 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 Adequate Disclosure Revenue Procedure Renewal Rev. Proc. 2022-41 SECTION 1. PURPOSE This revenue procedure updates Rev. Proc. 2021-52, 2021-51 I.R.B. 883, and identifies circumstances under which the disclosure on a taxpayer’s income tax return with respect to an item or position is adequate for the purpose of reducing the understatement of income tax under section 6662(d) of the Internal Revenue Code (relating to the substantial understatement aspect of the accuracy-related penalty), and for the purpose of avoiding the tax return preparer penalty under section 6694(a) (relating to understatements due to unreasonable positions) with respect to income tax returns. This revenue procedure does not apply with respect to any other penalty provisions (including but not limited to the disregard provisions of the section 6662(b)(1) accuracy-related penalty, the section 6662(i) increased accuracy-related penalty in the case of nondisclosed noneconomic substance transactions, and the section 6662(b)(7) and (j) increased accuracy-related penalty in the case of undisclosed foreign financial asset understatements). If this revenue procedure does not include an item or position, disclosure is adequate with respect to that item or position only if made on a properly completed Form 8275 or 8275-R, as appropriate, attached to the return for the year or to a qualified amended return. See Treas. Reg. § 1.6664-2(c) for information about qualified amended returns. This revenue procedure applies to any income tax return filed on 2022 tax forms for a taxable year beginning in 2022, and to any income tax return filed in 2023 on 2022 tax forms for short taxable years beginning in 2023. SECTION 2. CHANGES FROM REV. PROC. 2021-52 Changes have been made in order to update the taxable years to which this revenue procedure applies. No substantive changes have been made. SECTION 3. BACKGROUND .01 If section 6662 applies to any portion of an underpayment of tax required to be shown on a return, an amount generally equal to 20 percent of the portion of the underpayment is added to the tax. Under section 6662(b)(2), the penalty applies to the portion of any underpayment of tax that is attributable to a substantial understatement of income tax. The penalty rate increases to 40 percent in the case of gross valuation misstatements under section 6662(h), nondisclosed noneconomic substance transactions under section 6662(i), or undisclosed foreign financial asset understatements under section 6662(j). .02 Generally, there is a substantial understatement of income tax if the amount of the understatement exceeds the greater of (i) 10 percent of the amount of tax required to be shown on the return for the taxable year or (ii) $5,000. Section 6662(d)(1). Section 6662(d)(1)(C) provides a special rule for taxpayers claiming a section 199A deduction. In the case of any taxpayer who claims any deduction allowed under section 199A for the taxable year, there is a substantial understatement of income tax if the amount of the understatement exceeds the greater of (i) 5 percent of the amount of tax required to be shown on the return for the taxable year or (ii) $5,000. Section 6662(d)(1)(B) provides a special rule for corporations. A corporation (other than an S corporation or a personal holding company) has a substantial understatement of income tax if the amount of the understatement exceeds the lesser of (i) 10 percent of the tax required to be shown on the return for a taxable year (or, if greater, $10,000) or (ii) $10,000,000. Generally, an understatement is the excess of the amount of tax required to be shown on the return for the taxable year over the amount of the tax that is shown on the return reduced by any rebate, where the excess is determined without regard to items to which the reportable transaction understatement penalty under section 6662A applies. Section 6662(d)(2)(A). For purposes of determining whether an understatement is substantial, the understatement determined under the general rule is increased by the aggregate amount of any reportable transaction understatements relating to the return. Section 6662A(e)(1)(A). .03 In the case of an item not attributable to a tax shelter, if the taxpayer has a reasonable basis for the tax treatment of the item, the amount of the understatement is reduced by the portion of the understatement attributable to the item with respect to which the relevant facts affecting the item’s tax treatment are adequately disclosed in the return or in a statement attached to the return. Section 6662(d)(2)(B)(ii). .04 Section 6694(a) imposes a penalty on a tax return preparer who prepares a return or claim for refund reflecting an understatement of liability due to an “unreasonable position” if the tax return preparer knew (or reasonably should have known) of the position. A position (other than a position with respect to a tax shelter or a reportable transaction to which section 6662A applies) is generally treated as unreasonable unless (i) there is or was substantial authority for the position, or (ii) the position was properly disclosed in accordance with section 6662(d)(2)(B)(ii)(I) and had a reasonable basis. If the position is with respect to a tax shelter (as defined in section 6662(d)(2)(C)(ii)) or a reportable transaction to which section 6662A applies, the position is treated as unreasonable unless it is reasonable to believe that the position would more likely than not be sustained on the merits. See Notice 2009-5, 2009-3 I.R.B. 309, for interim penalty compliance rules for tax shelter transactions. .05 In general, this revenue procedure provides guidance for determining when disclosure by return is adequate for purposes of section 6662(d)(2)(B)(ii) and section 6694(a)(2)(B). For purposes of this revenue procedure, the taxpayer must furnish all required information in accordance with the applicable forms and instructions, and the money amounts entered on these forms must be verifiable. .06 This revenue procedure may apply to a return for a fiscal tax year that begins in 2022 and ends in 2023. This revenue procedure may also apply to a short year return for a period beginning in 2023 if the return is to be filed before the 2023 forms are available. (Note that individuals are generally not put in this position.) The most frequent situation in which a short year arises is when filing a decedent’s final return for a fractional part of a year. In that situation, the 2023 form will be available because the final return is due the fifteenth day of the fourth month following the close of the 12-month period that began with the first day of such fractional part of the year (meaning the due date is not accelerated). See Treas. Reg. § 1.6072-1(b). In the case of fiscal year and short year returns, the taxpayer must take into account any tax law changes that are effective for tax years beginning after December 31, 2022, even though these changes are not reflected on the form or instructions. .07 This document does not take into account the effect of tax law changes effective for tax years beginning after December 31, 2022. If a line referenced in this revenue procedure is affected by such a change and requires additional reporting, a taxpayer may have to file Form 8275, Disclosure Statement, or Form 8275-R, Regulation Disclosure Statement, until the Service prescribes criteria for complying with the requirement. .08 A complete and accurate disclosure of a tax position on the appropriate year’s Schedule UTP, Uncertain Tax Position Statement, will be treated as if the corporation filed a Form 8275 or Form 8275-R regarding the tax position. The filing of a Form 8275 or Form 8275-R, however, will not be treated as if the corporation filed a Schedule UTP. SECTION 4. PROCEDURE .01 General (1) Additional disclosure of facts relevant to, or positions taken with respect to, issues involving any of the items set forth below is unnecessary for purposes of reducing any understatement of income tax under section 6662(d) (except as otherwise provided in section 4.02(3) concerning Schedules M-1 and M-3), provided that the forms and attachments are completed in a clear manner and in accordance with their instructions. (2) The money amounts entered on the forms must be verifiable, and the information on the return must be disclosed in the manner described below. For purposes of this revenue procedure, a number is verifiable if, on audit, the taxpayer can prove the origin of the amount (even if that number is not ultimately accepted by the Service) and the taxpayer can show good faith in entering that number on the applicable form. (3) The disclosure of an amount as provided in section 4.02 below is not adequate when the understatement arises from a transaction between parties who are related within the meaning of section 267(b). If an entry may present a legal issue or controversy because of a related-party transaction, then that transaction and the relationship must be disclosed on a Form 8275 or Form 8275-R. (4) When the amount of an item is shown on a line that does not have a preprinted description identifying that item (such as on an unnamed line under an “Other Expense” category), the taxpayer must clearly identify the item by including the description on that line. For example, to disclose a bad debt for a sole proprietorship, the words “bad debt” must be written or typed on the line of Schedule C (Form 1040 or 1040SR) that shows the amount of the bad debt. Also, for Schedule M-3 (Form 1120), Part II, line 25, Other income (loss) items with differences, or Part III, line 38, Other expense/deduction items with differences, the entry must provide descriptive language; for example, “Cost of non-compete agreement deductible not capitalizable,” and the description must be provided on an attachment. Similarly, for other forms, if space limitations on a form do not allow for an adequate description, the description must be continued on an attachment. (5) Although a taxpayer may literally meet the disclosure requirements of this revenue procedure, the disclosure will have no effect for purposes of the section 6662 accuracy-related penalty if the item or position on the return (1) does not have a reasonable basis as defined in Treas. Reg. § 1.6662-3(b)(3); (2) is attributable to a tax shelter item as defined in section 6662(d)(2)(C)(ii); or (3) is not properly substantiated or the taxpayer failed to keep adequate books and records with respect to the item or position. (6) Disclosure also will have no effect for purposes of the section 6694(a) penalty as applicable to tax return preparers if the position is with respect to a tax shelter (as defined in section 6662(d)(2)(C)(ii)) or a reportable transaction to which section 6662A applies. .02 Items (1) Form 1040, Schedule A, Itemized Deductions: (a) Medical and Dental Expenses: Complete lines 1 through 4, supplying all required information. (b) Taxes: Complete lines 5 through 7, supplying all required information. Line 6 must list each type of tax and the amount paid. (c) Interest Expenses: Complete lines 8 through 10, supplying all required information. This section 4.02(1)(c) does not apply to (i) amounts disallowed under section 163(d) unless Form 4952, Investment Interest Expense Deduction, is completed, or (ii) amounts disallowed under section 265. (d) Charitable Contributions: Complete lines 11 through 14, supplying all required information and attaching all related forms required pursuant to statute or regulation. (e) Casualty and Theft Losses: Complete Form 4684, Casualties and Thefts, and attach to the return. Each item or article for which a casualty or theft loss is claimed must be listed on Form 4684. (2) Certain Trade or Business Expenses (including, for purposes of this section, the following six expenses as they relate to the rental of property): (a) Casualty and Theft Losses: The procedure outlined in section 4.02(1)(e) must be followed. (b) Legal Expenses: The amount claimed must be stated. This section does not apply, however, to amounts properly characterized as capital expenditures, personal expenses, or non-deductible lobbying or political expenditures, including amounts that are required to be (or that are) amortized over a period of years. (c) Specific Bad Debt Charge-off: The amount written off must be stated. (d) Officers’ Compensation: Complete Form 1125-E, Compensation of Officers, when its instructions require completion. You must express the “percent of time devoted to business” as a numerical percentage, rather than as a non-numerical description such as “part” or “as needed.” This section does not apply to “excess parachute payments,” as defined in section 280G. This section does not apply to the extent that remuneration paid or incurred exceeds an applicable employee-remuneration deduction limitation under section 162(m). (e) Repair Expenses: The amount claimed must be stated. This section does not apply, however, to any amount properly characterized as capital expenditures or personal expenses. (f) Taxes (other than foreign taxes): The amount claimed must be stated. (3) Differences in book and income tax reporting: For Schedule M-1 and all Schedules M-3, including those listed in (a)-(f) below, the information provided must reasonably apprise the Service of the potential controversy concerning the tax treatment of the item. If the information provided does not so apprise the Service, a Form 8275 or Form 8275-R must be used to adequately disclose the item (see Part II of the instructions for those forms). Note: An item reported on a line with a pre-printed description, shown on an attached schedule or “itemized” on Schedule M-1, may represent the aggregate amount of several transactions producing that item (i.e., a group of similar items, such as amounts paid or incurred for supplies by a taxpayer engaged in business). In some instances, a potentially controversial item may involve a portion of the aggregate amount disclosed on the schedule. The Service will not be reasonably apprised of a potential controversy by the aggregate amount disclosed. In these instances, the taxpayer must use Form 8275 or Form 8275-R regarding that portion of the item. Combining unlike items, whether on Schedule M-1 or Schedule M-3 (or on an attachment when directed by the instructions), will not constitute an adequate disclosure. Additionally, taxpayers that file the Schedule M-3 (Form 1120), Net Income (Loss) Reconciliation for Corporations With Total Assets of $10 Million or More, may be required to complete Schedule B (Form 1120), Additional Information for Schedule M-3 Filers. For further information, see Who Must File in the General Instructions for Schedule B (Form 1120). Taxpayers that file the Schedule M-3 (Form 1065), Net Income (Loss) Reconciliation for Certain Partnerships, may be required to complete Schedule C (Form 1065), Additional Information for Schedule M-3 Filers. For further information, see Who Must File in the General Instructions for Schedule C (Form 1065). When required, these schedules are necessary to constitute adequate disclosure: (a) Form 1065. Schedule M-3 (Form 1065), Net Income (Loss) Reconciliation for Certain Partnerships: Part II (reconciliation of income (loss) items) Column (a), Income (Loss) per Income Statement; Column (b), Temporary Difference; Column (c), Permanent Difference; and Column (d), Income (Loss) per Tax Return Part III (reconciliation of expense/deduction items) Column (a), Expense per Income Statement; Column (b), Temporary Difference; Column (c), Permanent Difference; and Column (d), Deduction per Tax Return (b) Form 1120. (i) Schedule M-1, Reconciliation of Income (Loss) per Books With Income per Return. (ii) Schedule M-3 (Form 1120), Net Income (Loss) Reconciliation for Corporations With Total Assets of $10 Million or More: Part II (reconciliation of income (loss) items) Column (a), Income (Loss) per Income Statement; Column (b), Temporary Difference; Column (c), Permanent Difference; and Column (d), Income (Loss) per Tax Return Part III (reconciliation of expense/deduction items) Column (a), Expense per Income Statement; Column (b), Temporary Difference; Column (c), Permanent Difference; and Column (d), Deduction per Tax Return (c) Form 1120-L. Schedule M-3 (Form 1120-L), Net Income (Loss) Reconciliation for U.S. Life Insurance Companies With Total Assets of $10 Million or More: Part II (reconciliation of income (loss) items) Column (a), Income (Loss) per Income Statement; Column (b), Temporary Difference; Column (c), Permanent Difference; and Column (d), Income (Loss) per Tax Return Part III (reconciliation of expense/deduction items) Column (a), Expense per Income Statement; Column (b), Temporary Difference; Column (c), Permanent Difference; and Column (d), Deduction per Tax Return (d) Form 1120-PC. Schedule M-3 (Form 1120-PC), Net Income (Loss) Reconciliation for U.S. Property and Casualty Insurance Companies With Total Assets of $10 Million or More: Part II (reconciliation of income (loss) items) Column (a), Income (Loss) per Income Statement; Column (b), Temporary Difference; Column (c), Permanent Difference; and Column (d), Income (Loss) per Tax Return Part III (reconciliation of expense/deduction items) Column (a), Expense per Income Statement; Column (b), Temporary Difference; Column (c), Permanent Difference; and Column (d), Deduction per Tax Return (e) Form 1120-S. Schedule M-3 (Form 1120-S), Net Income (Loss) Reconciliation for S Corporations With Total Assets of $10 Million or More: Part II (reconciliation of income (loss) items) Column (a), Income (Loss) per Income Statement; Column (b), Temporary Difference; Column (c), Permanent Difference; and Column (d), Income (Loss) per Tax Return Part III (reconciliation of expense/deduction items) Column (a), Expense per Income Statement; Column (b), Temporary Difference; Column (c), Permanent Difference; and Column (d), Deduction per Tax Return (f) Form 1120-F. Schedule M-3 (Form 1120-F), Net Income (Loss) Reconciliation for Foreign Corporations With Reportable Assets of $10 Million or More: Part II (reconciliation of income (loss) items) Column (b), Temporary Differences; Column (c), Permanent Differences; and Column (d), Other Permanent Differences for Allocations to Non-ECI and ECI Part III (reconciliation of expense/deduction items) Column (b), Temporary Differences; Column (c), Permanent Differences; and Column (d), Other Permanent Differences for Allocations to Non-ECI and ECI (4) Foreign Tax Items: (a) International Boycott Transactions: Transactions disclosed on Form 5713, International Boycott Report; Schedule A, International Boycott Factor (Section 999(c)(1)); Schedule B, Specifically Attributable Taxes and Income (Section 999(c)(2)); and Schedule C, Tax Effect of the International Boycott Provisions, must be completed when required by their instructions. (b) Treaty-Based Return Position: Transactions and amounts under section 6114 or section 7701(b) as disclosed on Form 8833, Treaty-Based Return Position Disclosure Under Section 6114 or 7701(b), must be completed when required by its instructions. (5) Other: (a) Moving Expenses: Complete Form 3903, Moving Expenses, and attach to the return. (b) Employee Business Expenses: Complete Form 2106, Employee Business Expenses (for use only by Armed Forces reservists, qualified performing artists, fee-basis state or local government officials, and employees with impairment-related work expenses), and attach to the return. This section does not apply to club dues or to travel expenses for any non-employee accompanying the taxpayer on the trip. (c) Fuels Credit: Complete Form 4136, Credit for Federal Tax Paid on Fuels, and attach to the return. (d) Investment Credit: Complete Form 3468, Investment Credit, and attach to the return. SECTION 5. EFFECTIVE DATE This revenue procedure applies to any income tax return filed on a 2022 tax form for a taxable year beginning in 2022 and to any income tax return filed on a 2022 tax form in 2023 for a short taxable year beginning in 2023. SECTION 6. DRAFTING INFORMATION The principal author of this revenue procedure is Jesse Hubbard of the Office of the Associate Chief Counsel (Procedure & Administration). For further information regarding this revenue procedure, contact Branch 2 of Procedure and Administration at (202) 317-6844 (not a toll free number). 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 2022–50 Announcements: Article Issue Link Page 2022-14 2022-31 I.R.B. 2022-31 136 2022-15 2022-31 I.R.B. 2022-31 136 2022-16 2022-33 I.R.B. 2022-33 144 2022-17 2022-35 I.R.B. 2022-35 179 2022-18 2022-36 I.R.B. 2022-36 190 2022-19 2022-36 I.R.B. 2022-36 191 2022-20 2022-38 I.R.B. 2022-38 238 2022-21 2022-46 I.R.B. 2022-46 464 2022-22 2022-47 I.R.B. 2022-47 497 2022-23 2022-48 I.R.B. 2022-48 499 Notices: Article Issue Link Page 2022-29 2022-28 I.R.B. 2022-28 66 2022-30 2022-28 I.R.B. 2022-28 70 2022-31 2022-29 I.R.B. 2022-29 85 2022-32 2022-32 I.R.B. 2022-32 137 2022-33 2022-34 I.R.B. 2022-34 147 2022-34 2022-34 I.R.B. 2022-34 150 2022-35 2022-36 I.R.B. 2022-36 184 2022-36 2022-36 I.R.B. 2022-36 188 2022-37 2022-37 I.R.B. 2022-37 234 2022-38 2022-39 I.R.B. 2022-39 239 2022-39 2022-40 I.R.B. 2022-40 264 2022-40 2022-40 I.R.B. 2022-40 266 2022-42 2022-41 I.R.B. 2022-41 276 2022-44 2022-41 I.R.B. 2022-41 277 2022-43 2022-42 I.R.B. 2022-42 303 2022-45 2022-42 I.R.B. 2022-42 307 2022-41 2022-43 I.R.B. 2022-43 304 2022-46 2022-43 I.R.B. 2022-43 306 2022-47 2022-43 I.R.B. 2022-43 312 2022-48 2022-43 I.R.B. 2022-43 316 2022-49 2022-43 I.R.B. 2022-43 321 2022-50 2022-43 I.R.B. 2022-43 325 2022-51 2022-43 I.R.B. 2022-43 331 2022-52 2022-43 I.R.B. 2022-43 337 2022-53 2022-45 I.R.B. 2022-45 437 2022-54 2022-45 I.R.B. 2022-45 439 2022-55 2022-45 I.R.B. 2022-45 443 2022-56 2022-47 I.R.B. 2022-47 480 2022-57 2022-47 I.R.B. 2022-47 482 2022-58 2022-47 I.R.B. 2022-47 483 2022-59 2022-48 I.R.B. 2022-48 498 2022-60 2022-49 I.R.B. 2022-49 502 2022-62 2022-49 I.R.B. 2022-49 506 Proposed Regulations: Article Issue Link Page REG-130975-08 2022-28 I.R.B. 2022-28 71 REG 130675-17 2022-30 I.R.B. 2022-30 104 REG-125693-19 2022-39 I.R.B. 2022-39 241 REG-110368-22 2022-44 I.R.B. 2022-44 405 Proposed Regulations:—Continued Article Issue Link Page REG-100719-21 2022-45 I.R.B. 2022-45 457 REG-121509-00 2022-45 I.R.B. 2022-45 463 REG-112096-22 2022-49 I.R.B. 2022-49 511 Revenue Procedures: Article Issue Link Page 2022-25 2022-27 I.R.B. 2022-27 3 2022-28 2022-27 I.R.B. 2022-27 65 2022-26 2022-29 I.R.B. 2022-29 90 2022-32 2022-30 I.R.B. 2022-30 101 2022-30 2022-31 I.R.B. 2022-31 112 2022-29 2022-33 I.R.B. 2022-33 141 2022-34 2022-33 I.R.B. 2022-33 143 2022-35 2022-40 I.R.B. 2022-40 270 2022-36 2022-40 I.R.B. 2022-40 274 2022-19 2022-41 I.R.B. 2022-41 282 2022-31 2022-43 I.R.B. 2022-43 339 2022-37 2022-43 I.R.B. 2022-43 377 2022-38 2022-45 I.R.B. 2022-45 445 2022-40 2022-47 I.R.B. 2022-47 487 2022-39 2022-49 I.R.B. 2022-49 507 2022-41 2022-50 I.R.B. 2022-50 527 Revenue Rulings: Article Issue Link Page 2022-12 2022-27 I.R.B. 2022-27 1 2022-13 2022-30 I.R.B. 2022-30 99 2022-14 2022-31 I.R.B. 2022-31 110 2022-15 2022-35 I.R.B. 2022-35 152 2022-17 2022-36 I.R.B. 2022-36 182 2022-18 2022-40 I.R.B. 2022-40 262 2022-19 2022-44 I.R.B. 2022-44 379 2022-20 2022-45 I.R.B. 2022-45 407 2022-21 2022-47 I.R.B. 2022-47 468 2022-22 2022-49 I.R.B. 2022-49 500 Treasury Decisions: Article Issue Link Page 9963 2022-34 I.R.B. 2022-34 145 9964 2022-35 I.R.B. 2022-35 172 9965 2022-37 I.R.B. 2022-37 192 9966 2022-44 I.R.B. 2022-44 380 9967 2022-44 I.R.B. 2022-44 385 9968 2022-45 I.R.B. 2022-45 409 1 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. Finding List of Current Actions on Previously Published Items1 Bulletin 2022–50 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.