Internal Revenue Bulletin 2009-26 (PDF rendition): IRS Revenue Rulings

us-irs-revenue-rulings-irb-2009-26-pdfInternal Revenue Bulletin 2009-26 (PDF rendition): IRS Revenue RulingsGuidance

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Bulletin No. 200
9-26
June 29, 2009
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.
INCOME TAX
Rev. Rul. 2009–17, page 1111.
Interest rates; underpayments and overpayments.The
rates for interest determined under section 6621 of the Code
for the calendar quarter beginning July 1, 2009, will be 4 per-
cent for overpayments (3 percent in the case of a corporation),
4 percent for underpayments, and 6 percent for large corpo-
rate underpayments. The rate of interest paid on the portion of
a corporate overpayment exceeding $10,000 will be 1.5 per-
cent.
Notice 2009–50, page 1118.
This notice provides guidance on the maximum face amount
of recovery zone economic development bonds and recovery
zone facility bonds that may be issued by each state and
the counties and large municipalities in such state before
January 1, 2011 under sections 1400U–2 and 1400U–3 of
the Code as provided in section 1400U–1.
Notice 2009–54, page 1124.
This notice sets forth a process that allows manufacturers to
certify to the Service that a particular vehicle meets the require-
ments of section 30D of the Code. Taxpayers purchasing such
vehicles can rely on the domestic manufacturer (or, in the case
of a foreign manufacturer, its domestic distributor) to certify
that a particular make, model, and model year of vehicle quali-
fies as a plug-in electric drive motor vehicle under section 30D,
and to certify the amount of the credit allowable with respect
to the vehicle.
EXEMPT ORGANIZATIONS
Announcement 2009–54, page 1128.
The IRS has revoked its determination that Home Ownership
Providers, Inc., of Marietta, GA; and Wasatch Homes Charitable
Foundation of Draper, UT, qualify as organizations described in
sections 501(c)(3) and 170(c)(2) of the Code.
Announcements of Disbarments and Suspensions begin on page 1128.
Fi
nding Lists begin on page ii.
Index for January through June begins on page vi.

The IRS Mission
Provide Americ
a’s taxpayers top quality service by helping them
understand an
d meet their tax responsibilities and by applying
the tax 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 Conven-
tions, legislation, court decisions, and other items of general
interest. It is published weekly and may be obtained from the
Superintendent of Documents on a subscription basis. Bulletin
contents are compiled semiannually into Cumulative Bulletins,
which are sold on a single-copy basis.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application of
the tax laws, including all rulings that supersede, revoke, mod-
ify, or amend any of those previously published in the Bulletin.
All published rulings apply retroactively unless otherwise indi-
cated. Procedures relating solely to matters of internal man-
agement 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.—19
86 Code.
This part i
ncludes rulings and decisions based on provisions of
the Intern
al 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, Leg-
islation 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 Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Secre-
tary (Enforcement).
Part IV
.—Items of General Interest.
This par
t includes notices of proposed rulemakings, disbar-
ment an
d 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 c
ontents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
For sale by the Superintendent of Documents, U.S.Government Printing Office, Washington, DC 20402.
June 29, 20092009–26 I.R.B.

Part I. Rulings
and Decisions Under the Internal Revenue Code
of 1986
Section 1400U
–1.—Alloca-
tion of Recove
ry Zone Bonds
A notice that p
rovides guidance regarding the
maximum face a
mount of recovery zone economic
development b
onds and recovery zone facility bonds,
that may be is
sued by each State and counties and
large munici
palities within each State before January
1, 2011 under
sections 1400U–2 and 1400U–3, re-
spectively,
of the Internal Revenue Code (“Code”),
as provided
in section 1400U–1 of the Code. See
Notice 2009
-50, page 1118.
Section 6621.—Determina-
tion of Rate of Interest
26 CFR 301.6621–1: Interest rate.
Interest rates; underpayments and
overpayments.The rates for interest de-
termined under section 6621 of the Code
for the calendar quarter beginning July 1,
2009, will be 4 percent for overpayments
(3 percent in the case of a corporation), 4
percent for underpayments, and 6 percent
for large corporate underpayments. The
rate of interest paid on the portion of a
corporate overpayment exceeding $10,000
will be 1.5 percent.
Rev. Rul. 2009–17
Section 6621 of the Internal Revenue
Code establishes the rates for interest
on tax overpayments and tax underpay-
ments. 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 cor-
poration), except the rate for the portion
of a corporate overpayment of tax exceed-
ing $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 pur-
poses of inter
est payable under section
6601 on any lar
ge corporate underpay-
ment, the und
erpayment rate under section
6621(a)(2) i
s determined by substituting
“5 percentag
e points” for “3 percentage
points.” See
section 6621(c) and section
301.6621–3
of the Regulations on Proce-
dure and Adm
inistration for the definition
of a large co
rporate underpayment and
for the rule
s for determining the appli-
cable date.
Section 6621(c) and section
301.6621–
3 are generally effective for
periods af
ter December 31, 1990.
Section 66
21(b)(1) provides that the
Secretary
will determine the federal
short-ter
m rate for the first month in each
calendar q
uarter. Section 6621(b)(2)(A)
provides
that the federal short-term rate
determin
ed under section 6621(b)(1) for
any month
applies during the first calen-
dar quart
er beginning after that month.
Section 6
621(b)(3) provides that the fed-
eral sho
rt-term rate for any month is the
federal
short-term rate determined during
that mon
th by the Secretary in accordance
with sec
tion 1274(d), rounded to the near-
est ful
l percent (or, if a multiple of
1
/2of
1 perce
nt, the rate is increased to the next
highes
t full percent).
Notice
88–59, 1988–1 C.B. 546, an-
nounce
d that, in determining the quarterly
intere
st rates to be used for overpayments
and und
erpayments of tax under section
6621,
the Internal Revenue Service will
use th
e federal short-term rate based on
daily
compounding because that rate is
most c
onsistent with section 6621 which,
pursu
ant to section 6622, is subject to daily
comp
ounding.
The fe
deral short-term rate determined
in ac
cordance with section 1274(d) during
Apri
l 2009 is the rate published in Rev-
enue
Rule 2009–12 to take effect begin-
ning
May 1, 2009. The federal short-term
rate, rounded
to the nearest full percent, the
federal short
-term rate based on daily com-
pounding dete
rmined during the month of
April 2009 is
1 percent. Accordingly, an
overpayment
rate of 4 percent (3 percent
in the case of
a corporation) and an under-
payment rate
of 4 percent are established
for the cale
ndar quarter beginning July 1,
2009. The ov
erpayment rate for the por-
tion of a cor
porate overpayment exceeding
$10,000 for
the calendar quarter beginning
July 1, 2009
, is 1.5 percent. The under-
payment ra
te for large corporate underpay-
ments for t
he calendar quarter beginning
July 1, 200
9, is 6 percent. These rates ap-
plytoamou
nts bearing interest during that
calendar
quarter.
Interest f
actors for daily compound in-
terest fo
r annual rates of 1.5 percent, 3 per-
cent, 4 pe
rcent, and 6 percent are published
in Tables
8, 11, 13, and 17 of Rev. Proc.
95–17, 19
95–1 C.B. 556, 562, 565, 567,
and 571.
Annual in
terest rates to be compounded
daily pur
suant to section 6622 that apply
for prio
r periods are set forth in the tables
accompa
nying this revenue ruling.
DRAFTIN
G INFORMATION
The prin
cipal author of this revenue rul-
ing is De
borah Colbert-James of the Of-
fice of A
ssociate Chief Counsel (Proce-
dure & A
dministration). For further infor-
mation
regarding this revenue ruling, con-
tact Ms
. Colbert-James at (202) 622–8143
(not a t
oll-free call).
2009–26 I.R.B.1111June 29, 2009

TABLE OF INTEREST RATES
PERIODS BEFORE JUL. 1, 1975 — PERIODS ENDING DEC. 31, 1986
OVERPAYMENTS AND UNDERPAYMENTS
PERIODRATE
In 1995–1 C.B.
DAILY RATE TABLE
Before Jul. 1, 1975
6%
Table 2, pg. 557
Jul. 1, 1975—Jan. 31, 1976
9%
Table 4, pg. 559
Feb. 1, 1976—Jan. 31, 19787%
Table 3, pg. 558
Feb. 1, 1978—Jan. 31, 19806%
Table 2, pg. 557
Feb. 1, 1980—Jan. 31, 198212%
Table 5, pg. 560
Feb. 1, 1982—Dec. 31, 198220%
Table 6, pg. 560
Jan. 1, 1983—Jun. 30, 198316%
Table 37, pg. 591
Jul. 1, 1983—Dec. 31, 198311%
Table 27, pg. 581
Jan. 1, 1984—Jun. 30, 198411%
Table 75, pg. 629
Jul. 1, 1984—Dec. 31, 198411%
Table 75, pg. 629
Jan. 1, 1985—Jun. 30, 1985
13%
Table 31, pg. 585
Jul. 1, 1985—Dec. 31, 1985
11%
Table 27, pg. 581
Jan. 1, 1986—Jun. 30, 198610%
Table 25, pg. 579
Jul. 1, 1986—Dec. 31, 19869%
Table 23, pg. 577
TABLE OF INTEREST RATES
FROM JAN. 1, 1987 — DEC. 31, 1998
OVERPAYMENTSUNDERPAYMENTS
1995–1 C.B.1995–1 C.B.
RATE TABLEPGRATE TABLEPG
Jan. 1, 1987—Mar. 31, 19878%21
575
9%23
577
Apr. 1, 1987
—Jun. 30, 1987
8%21
575
9%23
577
Jul. 1, 1987—Sep. 30, 19878%21
575
9%23
577
Oct. 1, 1987—Dec. 31, 19879%23
577
10%
25579
Jan. 1, 198
8—Mar. 31, 1988
10%7362711%
75
629
Apr. 1, 1988—Jun. 30, 19889%71
625
10%73627
Jul. 1, 1988—Sep. 30, 19889%71
625
10%73627
Oct. 1, 19
88—Dec. 31, 1988
10%7362711%
75
629
Jan. 1, 1989—Mar. 31, 198910%
25579
11%27
581
Apr. 1, 1989—Jun. 30, 198911%27
581
12%29
583
Jul. 1, 1
989—Sep. 30, 1989
11%27
581
12%29
583
Oct. 1, 1989—Dec. 31, 198910%
25579
11%27
581
Jan. 1, 1990—Mar. 31, 199010%
25579
11%27
581
Apr. 1,
1990—Jun. 30, 1990
10%
25579
11%27
581
Jul. 1, 1990—Sep. 30, 199010%
25579
11%27
581
Oct. 1, 1990—Dec. 31, 199010%
25579
11%27
581
Jan. 1,
1991—Mar. 31, 1991
10%
25579
11%27
581
Apr. 1, 1991—Jun. 30, 19919%23
577
10%
25579
Jul. 1, 1991—Sep. 30, 19919%23
577
10%
25579
Oct. 1
, 1991—Dec. 31, 1991
9%23
577
10%
25579
Jan. 1, 1992—Mar. 31, 19928%696239%71
625
Apr. 1, 1992—Jun. 30, 19927%676218%69623
Jul.
1, 1992—Sep. 30, 1992
7%676218%69623
Oct. 1, 1992—Dec. 31, 19926%
65
6197%67621
Jan. 1, 1993—Mar. 31, 19936%17
571
7%19
573
Apr
. 1, 1993—Jun. 30, 1993
6%17
571
7%19
573
Jul. 1, 1993—Sep. 30, 19936%17
571
7%19
573
Oct. 1, 1993—Dec. 31, 19936%17
571
7%19
573
Ja
n. 1, 1994—Mar. 31, 1994
6%17
571
7%19
573
Apr. 1, 1994—Jun. 30, 19946%17
571
7%19
573
Jul. 1, 1994—Sep. 30, 19947%19
57
3
8%21
57
5
June 29, 200911122009–26 I.R.B.

TABLE OF INTEREST RATES
FROM JAN. 1, 1987 — DEC. 31, 1998 – Continued
OVERPAYMENTSUNDERPAYMENTS
1995–1 C.B.1995–1 C.B.
RATE TABLEPGRATE TABLEPG
Oct. 1, 1994—Dec. 31, 19948%21
575
9%23
577
Jan. 1, 1995—Ma
r. 31, 1995
8%21
575
9%23
577
Apr. 1, 1995—Jun. 30, 1995
9%23
577
10%
25579
Jul. 1, 1995—Sep. 30, 1995
8%21
575
9%23
577
Oct. 1, 1995—D
ec. 31, 1995
8%21
575
9%23
577
Jan. 1, 1996—M
ar. 31, 1996
8%696239%71
625
Apr. 1, 1996—Jun. 30, 19967%676218%69623
Jul. 1, 1996—Sep. 30, 19968%696239%71
625
Oct. 1, 1996—
Dec. 31, 1996
8%696239%71
625
Jan. 1, 1997—Mar. 31, 19978%21
575
9%23
577
Apr. 1, 1997—Jun. 30, 19978%21
575
9%23
577
Jul. 1, 1997
—Sep. 30, 1997
8%21
575
9%23
577
Oct. 1, 1997—Dec. 31, 19978%21
575
9%23
577
Jan. 1, 1998—Mar. 31, 19988%21
575
9%23
577
Apr. 1, 1998
—Jun. 30, 1998
7%19
573
8%21
575
Jul. 1, 1998—Sep. 30, 19987%19
573
8%21
575
Oct. 1, 1998—Dec. 31, 19987%19
573
8%21
575
TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 — PRESENT
NONCORPORATE OVERPAYMENTS AND UNDERPAYMENTS
1995–1 C.B
.
RATETABLEPG
Jan. 1, 199
9—Mar. 31, 1999
7%19
573
Apr. 1, 1999—Jun. 30, 19998%21
575
Jul. 1, 1999—Sep. 30, 19998%21
575
Oct. 1, 19
99—Dec. 31, 1999
8%21
575
Jan. 1, 2000—Mar. 31, 20008%69623
Apr. 1, 2000—Jun. 30, 20009%71
625
Jul. 1, 2
000—Sep. 30, 2000
9%71
625
Oct. 1, 2000—Dec. 31, 20009%71
625
Jan. 1, 2001—Mar. 31, 20019%23
577
Apr. 1, 2
001—Jun. 30, 2001
8%21
575
Jul. 1, 2001—Sep. 30, 20017%19
573
Oct. 1, 2001—Dec. 31, 20017%19
573
Jan. 1,
2002—Mar. 31, 2002
6%17
571
Apr. 1, 2002—Jun. 30, 20026%17
571
Jul. 1, 2002—Sep. 30, 20026%17
571
Oct. 1
, 2002—Dec. 31, 2002
6%17
571
Jan. 1, 2003—Mar. 31, 2003
5%15569
Apr. 1, 2003—Jun. 30, 2003
5%15569
Jul.
1, 2003—Sep. 30, 2003
5%15569
Oct. 1, 2003—Dec. 31, 20034%13
567
Jan. 1, 2004—Mar. 31, 20044%61
615
Apr
. 1, 2004—Jun. 30, 2004
5%
63617
Jul. 1, 2004—Sep. 30, 20044%61
615
Oct. 1, 2004—Dec. 31, 2004
5%
63617
Jan. 1, 2005—Mar. 31, 20055%15569
Apr. 1, 2005—Jun. 30, 2005
6%17
571
Ju
l. 1, 2005—Sep. 30, 2005
6%17
57
1
Oct. 1, 2005—Dec. 31, 2005
7%19
573
Jan. 1, 2006—Mar. 31, 20067%19
573
2009–26 I.R.B.1113June 29, 2009

TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 — PRESENT – Continued
NONCORPORATE OVERPAYMENTS AND UNDERPAYMENTS
1995–1 C.B.
RATETABLEPG
Apr. 1, 2006—Jun. 30, 20067%19
573
Jul. 1, 2006—Sep. 30, 20068%21
575
Oct. 1, 2006—Dec. 31, 20068%21
575
Jan. 1, 2007—Mar. 31, 20078%21
575
Apr. 1, 2007—Jun. 30, 20078%21
575
Jul. 1, 2007—Sep. 30, 20078%21
575
Oct. 1, 2007—Dec. 31, 20078%21
575
Jan. 1, 2008—Mar. 31, 20087%67621
Apr. 1, 2008—Jun. 30, 20086%
65
619
Jul. 1, 2008—Sep. 30, 2008
5%
63617
Oct. 1, 2008—Dec. 31, 20086%
65
619
Jan. 1, 2009—Mar. 31, 2009
5%15569
Apr. 1, 2009—Jun. 30, 20094%13
567
Jul. 1, 2009—Sep. 30, 20094%13
567
TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 — PRESENT
CORPORATE OVERPAYMENTS AND UNDERPAYMENTS
OVERPAYMENTSUNDERPAYMENTS
1995–1 C.B.1995–1 C.B.
RATE TABLEPGRATE TABLEPG
Jan. 1, 1999
—Mar. 31, 1999
6%17
571
7%19
573
Apr. 1, 1999—Jun. 30, 19997%19
573
8%21
575
Jul. 1, 1999—Sep. 30, 19997%19
573
8%21
575
Oct. 1, 199
9—Dec. 31, 1999
7%19
573
8%21
575
Jan. 1, 2000—Mar. 31, 20007%676218%69623
Apr. 1, 2000—Jun. 30, 20008%696239%71
625
Jul. 1, 20
00—Sep. 30, 2000
8%696239%71
625
Oct. 1, 2000—Dec. 31, 20008%696239%71
625
Jan. 1, 2001—Mar. 31, 20018%21
575
9%23
577
Apr. 1, 2
001—Jun. 30, 2001
7%19
573
8%21
575
Jul. 1, 2001—Sep. 30, 20016%17
571
7%19
573
Oct. 1, 2001—Dec. 31, 20016%17
571
7%19
573
Jan. 1, 2
002—Mar. 31, 2002
5%15569
6%17
571
Apr. 1, 2002—Jun. 30, 2002
5%15569
6%17
571
Jul. 1, 2002—Sep. 30, 2002
5%15569
6%17
571
Oct. 1,
2002—Dec. 31, 2002
5%15569
6%17
571
Jan. 1, 2003—Mar. 31, 20034%13
5675%15569
Apr. 1, 2003—Jun. 30, 20034%13
5675%15569
Jul. 1
, 2003—Sep. 30, 2003
4%13
5675%15569
Oct. 1, 2003—Dec. 31, 20033%11
565
4%13
567
Jan. 1, 2004—Mar. 31, 20043%
59
6134%61
615
Apr.
1, 2004—Jun. 30, 2004
4%61
6155%
63617
Jul. 1, 2004—Sep. 30, 20043%
59
6134%61
615
Oct. 1, 2004—Dec. 31, 20044%61
6155%
63617
Jan. 1, 2005—Mar. 31, 2005
4%13
5675%15569
Apr. 1, 2005—Jun. 30, 20055%15569
6%17
571
Jul
. 1, 2005—Sep. 30, 2005
5%15569
6%17
571
Oct. 1, 2005—Dec. 31, 2005
6%17
571
7%19
573
Jan. 1, 2006—Mar. 31, 20066%17
571
7%19
573
Apr. 1, 2006—Jun. 30, 20066%17
57
1
7%19
57
3
June 29, 200911142009–26 I.R.B.

TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 — PRESENT – Continued
CORPORATE OVERPAYMENTS AND UNDERPAYMENTS
OVERPAYMENTSUNDERPAYMENTS
1995–1 C.B.1995–1 C.B.
RATE TABLEPGRATE TABLEPG
Jul. 1, 2006—Sep. 30, 20067%19
573
8%21
575
Oct. 1, 2006—Dec. 31, 20067%19
573
8%21
575
Jan. 1, 2007—Ma
r. 31, 2007
7%19
573
8%21
575
Apr. 1, 2007—Jun. 30, 20077%19
573
8%21
575
Jul. 1, 2007—Sep. 30, 20077%19
573
8%21
575
Oct. 1, 2007—D
ec. 31, 2007
7%19
573
8%21
575
Jan. 1, 2008—Mar. 31, 20086%
65
6197%67621
Apr. 1, 2008—Jun. 30, 2008
5%
636176%
65
619
Jul. 1, 2008—
Sep. 30, 2008
4%61
6155%
63617
Oct. 1, 2008—Dec. 31, 2008
5%
636176%
65
619
Jan. 1, 2009—Mar. 31, 20094%13
5675%15569
Apr. 1, 2009—
Jun. 30, 2009
3%11
565
4%13
567
Jul. 1, 2009—Sep. 30, 20093%11
565
4%13
567
TABLE OF INTEREST RATES FOR
LARGE CORPORATE UNDERPAYMENTS
FROM JANUARY 1, 1991 — PRESENT
1995–1 C.B.
RATETABLEPG
Jan. 1, 1991
—Mar. 31, 1991
13%31
585
Apr. 1, 1991—Jun. 30, 199112%29
583
Jul. 1, 1991—Sep. 30, 199112%29
583
Oct. 1, 199
1—Dec. 31, 1991
12%29
583
Jan. 1, 1992—Mar. 31, 199211%
75
629
Apr. 1, 1992—Jun. 30, 199210%73627
Jul. 1, 19
92—Sep. 30, 1992
10%73627
Oct. 1, 1992—Dec. 31, 19929%71
625
Jan. 1, 1993—Mar. 31, 19939%23
577
Apr. 1, 1
993—Jun. 30, 1993
9%23
577
Jul. 1, 1993—Sep. 30, 19939%23
577
Oct. 1, 1993—Dec. 31, 19939%23
577
Jan. 1, 1
994—Mar. 31, 1994
9%23
577
Apr. 1, 1994—Jun. 30, 19949%23
577
Jul. 1, 1994—Sep. 30, 199410%
25579
Oct. 1,
1994—Dec. 31, 1994
11%27
581
Jan. 1, 1995—Mar. 31, 1995
11%27
581
Apr. 1
, 1995—Jun. 30, 1995
12%29
583
Jul. 1, 1995—Sep. 30, 1995
11%27
581
Oct. 1, 1995—Dec. 31, 1995
11%27
581
Jan. 1, 1996—Mar. 31, 199611%
75
629
Apr.
1, 1996—Jun. 30, 1996
10%73627
Jul. 1, 1996—Sep. 30, 199611%
75
629
Oct. 1, 1996—Dec. 31, 199611%
75
629
Jan
. 1, 1997—Mar. 31, 1997
11%27
581
Apr. 1, 1997—Jun. 30, 199711%27
581
Jul. 1, 1997—Sep. 30, 199711%27
581
Oct
. 1, 1997—Dec. 31, 1997
11%27
581
Jan. 1, 1998—Mar. 31, 199811%27
581
Apr. 1, 1998—Jun. 30, 199810%
2557
9
Ju
l. 1, 1998—Sep. 30, 1998
10%
25579
Oct. 1, 1998—Dec. 31, 199810%
25579
2009–26 I.R.B.1115June 29, 2009

TABLE OF INTEREST RATES FOR
LARGE CORPORATE UNDERPAYMENTS
FROM JANUARY 1, 1991 — PRESENT – Continued
1995–1 C.B.
RATETABLEPG
Jan. 1, 1999—Mar. 31, 19999%23
577
Apr. 1, 1999—Jun. 30, 199910%
25579
Jul. 1, 1999—Sep. 30, 199910%
25579
Oct. 1, 1999—Dec. 31, 199910%
25579
Jan. 1, 2000—Mar. 31, 200010%73627
Apr. 1, 2000—Jun. 30, 200011%
75
629
Jul. 1, 2000—Sep. 30, 200011%
75
629
Oct. 1, 2000—Dec. 31, 200011%
75
629
Jan. 1, 2001—Mar. 31, 200111%27
581
Apr. 1, 2001—Jun. 30, 200110%
25579
Jul. 1, 2001—Sep. 30, 20019%23
577
Oct. 1, 2001—Dec. 31, 20019%23
577
Jan. 1, 2002—Mar. 31, 20028%21
575
Apr. 1, 2002—Jun. 30, 20028%21
575
Jul. 1, 2002—Sep. 30, 20028%21
575
Oct. 1, 2002—Dec. 30, 20028%21
575
Jan. 1, 2003—Mar. 31, 20037%19
573
Apr. 1, 2003—Jun. 30, 20037%19
573
Jul. 1, 2003—Sep. 30, 20037%19
573
Oct. 1, 2003—Dec. 31, 20036%17
571
Jan. 1, 2004—Mar. 31, 20046%
65
619
Apr. 1, 2004—Jun. 30, 20047%67621
Jul. 1, 2004—Sep. 30, 20046%
65
619
Oct. 1, 2004—Dec. 31, 20047%67621
Jan. 1, 2005—Mar. 31, 2005
7%19
573
Apr. 1, 2005—Jun. 30, 2005
8%21
575
Jul. 1, 2005—Sep. 30, 2005
8%21
575
Oct. 1, 2005—Dec. 31, 2005
9%23
577
Jan. 1, 2006—Mar. 31, 20069%23
577
Apr. 1, 2006—Jun. 30, 20069%23
577
Jul. 1, 2006—Sep. 30, 200610%
25579
Oct. 1, 2006—Dec. 31, 200610%
25579
Jan. 1, 2007—Mar. 31, 200710%
25579
Apr. 1, 2007—Jun. 30, 200710%
25579
Jul. 1, 2007—Sep. 30, 200710%
25579
Oct. 1, 2007—Dec. 31, 200710%
25579
Jan. 1, 2008—Mar. 31, 20089%71
625
Apr. 1, 2008—Jun. 30, 20088%69623
Jul. 1, 2008—Sep. 30, 20087%67621
Oct. 1, 2008—Dec. 31, 20088%69623
Jan. 1, 2009—Mar. 31, 20097%19
573
Apr. 1, 2009—Jun. 30, 20096%17
571
Jul. 1, 2009—Sep. 30, 20096%17
571
TABLE OF INTEREST RATES FOR CORPORATE
OVERPAYMENTS EXCEEDING $10,000
F
ROM JANUARY 1, 1995 — PRESENT
1995–1 C.B.
RATETABLEPG
Jan. 1, 1995—Mar. 31, 19956.5%
18
572
Apr. 1, 1995—Jun. 30, 19957.5%
20
574
Jul. 1, 1995—Sep. 30, 19956.5%
18
572
June 29, 200911162009–26 I.R.B.

TABLE OF INTEREST RATES FOR CORPORATE
OVERPAYMENTS E
XCEEDING $10,000
FROM JANUARY 1, 1995 — PRESENT – Continued
1995–1 C.B.
RATETABLEPG
Oct. 1, 1995—Dec. 31, 19956.5%
18
572
Jan. 1, 1996—Mar. 31, 1996
6.5%
66620
Apr. 1, 1996—Jun. 30, 1996
5.5%
64618
Jul. 1, 1996—Sep. 30, 1996
6.5%
66620
Oct. 1, 1996—Dec. 31, 1996
6.5%
66620
Jan. 1, 1997—Mar. 31, 1997
6.5%
18
572
Apr. 1, 1997—Jun. 30, 1997
6.5%
18
572
Jul. 1, 1997—Sep. 30, 1997
6.5%
18
572
Oct. 1, 1997—Dec. 31, 1997
6.5%
18
572
Jan. 1, 1998—Mar. 31, 1998
6.5%
18
572
Apr. 1, 1998—Jun. 30, 1998
5.5%
16
570
Jul. 1, 1998—Sep. 30, 1998
5.5%
16
570
Oct. 1, 1998—Dec. 31, 1998
5.5%
16
570
Jan. 1, 1999—Mar. 31, 1999
4.5%
14
568
Apr. 1, 1999—Jun. 30, 1999
5.5%
16
570
Jul. 1, 1999—Sep. 30, 1999
5.5%
16
570
Oct. 1, 1999—Dec. 31, 1999
5.5%
16
570
Jan. 1, 2000—Mar. 31, 2000
5.5%
64618
Apr. 1, 2000—Jun. 30, 2000
6.5%
66620
Jul. 1, 2000—Sep. 30, 2000
6.5%
66620
Oct. 1, 2000—Dec. 31, 2000
6.5%
66620
Jan. 1, 2001—Mar. 31, 2001
6.5%
18
572
Apr. 1, 2001—Jun. 30, 2001
5.5%
16
570
Jul. 1, 2001—Sep. 30, 2001
4.5%
14
568
Oct. 1, 2001—Dec. 31, 2001
4.5%
14
568
Jan. 1, 2002—Mar. 31, 2002
3.5%
12
566
Apr. 1, 2002—Jun. 30, 2002
3.5%
12
566
Jul. 1, 2002—Sep. 30, 2002
3.5%
12
566
Oct. 1, 2002—Dec. 31, 2002
3.5%
12
566
Jan. 1, 2003—Mar. 31, 2003
2.5%
10
564
Apr. 1, 2003—Jun. 30, 2003
2.5%
10
564
Jul. 1, 2003—Sep. 30, 2003
2.5%
10
564
Oct. 1, 2003—Dec. 31, 2003
1.5%
8
562
Jan. 1, 2004—Mar. 31, 2004
1.5%56
610
Apr. 1, 2004—Jun. 30, 2004
2.5%58
612
Jul. 1, 2004—Sep. 30, 2004
1.5%56
610
Oct. 1, 2004—Dec. 31, 2004
2.5%58
612
Jan. 1, 2005—Mar. 31, 20052.5%
10
564
Apr. 1, 2005—Jun. 30, 20053.5%
12
566
Jul. 1, 2005—Sep. 30, 20053.5%
12
566
Oct. 1, 2005—Dec. 31, 20054.5%
14
568
Jan. 1, 2006—Mar. 31, 2006
4.5%
14
568
Apr. 1, 2006—Jun. 30, 2006
4.5%
14
568
Jul. 1, 2006—Sep. 30, 2006
5.5%
16
570
Oct. 1, 2006—Dec. 31, 2006
5.5%
16
570
Jan. 1, 2007—Mar. 31, 2007
5.5%
16
570
Apr. 1, 2007—Jun. 30, 2007
5.5%
16
570
Jul. 1, 2007—Sep. 30, 2007
5.5%
16
570
Oct. 1, 2007—Dec. 31, 2007
5.5%
16
570
Jan. 1, 2008—Mar. 31, 2008
4.5%
62616
Apr. 1, 2008—Jun. 30, 2008
3.5%
60614
Jul. 1, 2008—Sep. 30, 2008
2.5%58
612
Oct. 1, 2008—Dec. 31, 2008
3.5%
60614
Jan. 1, 2009—Mar. 31, 2009
2.5%
10
564
Apr. 1, 2009—Jun. 30, 2009
1.5%
8
562
Jul. 1, 2009—Sep. 30, 2009
1.5%
8
562
2009–26 I.R.B.1117June 29, 2009

Part III. Administrative, Procedural, and Miscellaneous
Recovery Zone Bond Volume
Cap Allocations
Notice 2009–50
SECTION 1. PURPOSE
This notice provides guidance regard-
ing the maximum face amount of recovery
zone economic development bonds (“Re-
covery Zone Economic Development
Bonds”) and recovery zone facility bonds
(“Recovery Zone Facility Bonds”) (to-
gether, “Recovery Zone Bonds”), that may
be issued by each State and counties and
large municipalities within each State be-
fore January 1, 2011 under §§ 1400U–2
and 1400U–3, respectively, of the Inter-
nal Revenue Code (“Code”), as provided
in § 1400U–1 of the Code. As appli-
cable to §§ 1400U–1 through 1400U–3,
§ 103(c)(2) provides that the term “State”
includes the District of Columbia and any
possession of the United States. This no-
tice also provides certain interim guidance
for Recovery Zone Bonds. In general, Re-
covery Zone Bonds provide tax incentives
for State and local governmental borrow-
ing at lower borrowing costs to promote
job creation and economic recovery that is
targeted to areas particularly affected by
employment declines.
SECTION 2. BACKGROUND
.01 INTRODUCTION
Section 1401 of Title I of Division B of
the American Recovery and Reinvestment
Act of 2009, Pub. L. No. 111–5, 123 Stat.
115 (2009) (“ARRA”), added §§ 1400U–1
through 1400U–3 to the Code authorizing
State and local governments to issue Re-
covery Zone Bonds. Section 1400U–1 im-
poses a national bond volume limitation
(“volume cap”) of $10 billion for Recov-
ery Zone Economic Development Bonds
and $15 billion for Recovery Zone Facil-
ity Bonds. The volume cap for Recov-
ery Zone Bonds is allocated among the
States and counties and large municipali-
ties within the States based on relative de-
clines in employment in 2008.
In general, Recovery Zone Economic
Development Bonds may be used to fi-
nance certain “qualified economic devel-
opment purposes” and Recovery Zone
Facility Bonds may be used to finance
certain “recovery zone property,” both
as described further herein, generally for
use within designated “recovery zones,”
as described below. Section 1400U–1(b)
provides that, for purposes of §§ 1400U–1
through 1400U–3, the term “recovery
zone” means: (1) any area designated by
the issuer as having significant poverty,
unemployment, rate of home foreclosures,
or general distress; (2) any area designated
by the issuer as economically distressed
by reason of the closure or realignment
of a military installation pursuant to the
Defense Base Closure and Realignment
Act of 1990; and (3) any area for which a
designation as an empowerment zone or
renewal community is in effect as of the
effective date of ARRA, which effective
date is February 17, 2009.
.02 BACKGROUND ON BUILD
AMERICA BONDS
Section 1531 of ARRA added § 54AA
to the Code, authorizing State and local
governments, at their option, to issue two
general types of Build America Bonds
(“Build America Bonds”) as taxable gov-
ernmental bonds with Federal subsidies
for a portion of their borrowing costs. Sec-
tion 54AA(d) of the Code defines the term
“Build America Bond” generally to mean
any taxable State or local governmental
bond (excluding a private activity bond
under § 141) that meets the following re-
quirements: (1) the interest on such bond
would (but for § 54AA) be excludable
from gross income under § 103; (2) the
bond is issued before January 1, 2011; and
(3) the issuer makes an irrevocable elec-
tion to have § 54AA apply. The Federal
subsidies for a portion of the borrowing
costs on Build America Bonds take the
form of either tax credits provided to hold-
ers of the bonds or refundable tax credits
paid to State and local governmental is-
suers of the bonds. Build America Bonds
have different levels of Federal subsidies
and different program requirements with
respect to uses of proceeds depending on
the particular type of Build America Bond.
The first type of Build America Bond
provides a Federal subsidy through Fed-
eral tax credits to investors in the bonds in
an amount equal to 35 percent of the to-
tal coupon interest payable by the issuer
on taxable governmental bonds (net of the
tax credit), which represents a Federal sub-
sidy to the State or local governmental is-
suer equal to approximately 25 percent of
the total return to the investor (including
the coupon interest paid by the issuer and
the tax credit). This type of Build Amer-
icaBondwillbereferredtointhisnotice
as “Build America Bonds (Tax Credit).”
This type of Build America Bond gener-
ally may be used to finance any govern-
mental purpose for which tax-exempt gov-
ernmental bonds (excluding private activ-
ity bonds under § 141) could be issued
under § 103 (“tax-exempt governmental
bonds”) and must comply with all require-
ments applicable to the issuance of tax-ex-
empt governmental bonds.
The second type of Build America
Bond provides a Federal subsidy through a
refundable tax credit paid to State or local
governmental issuers by the Treasury De-
partment and the Internal Revenue Service
(“IRS”) in an amount equal to 35 percent
of the total coupon interest payable to
investors in these taxable bonds. This type
of Build America Bond will be referred
to in this notice as “Build America Bonds
(Direct Payment).” This type of Build
America Bond generally may be used
to finance only capital expenditures and
certain issuance costs and reasonably
required reserve funds.
Recovery Zone Economic Develop-
ment Bonds under § 1400U–2 represent a
third type of Build America Bond. Recov-
ery Zone Economic Development Bonds
are comparable to Build America Bonds
(Direct Payment), except that they pro-
vide for a deeper Federal subsidy through
a refundable tax credit paid to State or
local governmental issuers in an amount
equal to 45 percent (rather than 35 per-
cent) of the total coupon interest payable
to investors in these taxable bonds and
they have different program requirements
regarding eligible uses of proceeds for
qualified economic development purposes
within recovery zones, as described fur-
ther herein.
For additional information regard-
ing Build America Bonds generally, see
§ 54AA and the initial implementation
guidance on Build America Bonds set
June 29, 200911182009–26 I.R.B.

forth in Notice 2009–26, 2009–16 I.R.B
833 (April 20, 2009).
SECTION3. RECOVERYZONE
ECONOMIC DEVELOPMENT
BONDS
.01 RECOVERY ZONE ECONOMIC
DEVELOPMENT BONDS TREATED
AS QUALIFIED BONDS UNDER
§ 6431
Section 1400U–2(a) provides that a
Recovery Zone Economic Development
Bond shall be treated as a “qualified bond”
for purposes of § 6431 (relating to the
refundable credit for qualified bonds al-
lowed and payable to the issuer in the
case of Build America Bonds (Direct
Payment)). Section 1400U–2(a) further
provides that, for purposes of § 6431(b)
(relating to the amount of the refundable
credit allowed and payable to the issuer
of qualified bonds), the amount of the
refundable credit shall be 45 percent of
the coupon interest payable on the bonds
rather than 35 percent of such interest as
is the case with Build America Bonds (Di-
rect Payment). In determining the amount
of coupon interest payable on the bonds
for purposes of calculating the refund-
able credit, original issue discount is not
treated as a payment of interest.SeeH.R.
Conf. Rep. 111–16, 111
th
Cong., 1
st
Sess.
(February 12, 2009).
.02 DEFINITION OF RECOVERY
ZONE ECONOMIC DEVELOPMENT
BOND
Section 1400U–2(b)(1) defines the term
“Recovery Zone Economic Development
Bond” to mean any bond that is issued
as part of an issue that meets the follow-
ing requirements: (1) the bond is a Build
America Bond (as defined in § 54AA(d));
(2) the bond is issued before January 1,
2011; (3) 100 percent of the excess of (i)
the available project proceeds (as defined
in § 54A to mean sale proceeds of such
issue less not more than 2 percent of such
proceeds used to pay issuance costs, plus
investment proceeds thereon), over (ii) the
amounts in a reasonably required reserve
(within the meaning of § 150(a)(3)) with
respect to such issue, are to be used for one
or more qualified economic development
purposes, and (4) the issuer designates
such bond for purposes of § 1400U–2.
.03 DEFINITION OF QUALIFIED
ECONOMIC DEVELOPMENT
PURPOSE
Section 1400U–2(c) defines the term
“qualified economic development pur-
pose” for purposes of § 1400U–2 to mean
any expenditures for purposes of pro-
moting development or other economic
activity in a recovery zone, including
(1) capital expenditures paid or incurred
with respect to property located in the
recovery zone, (2) expenditures for public
infrastructure and construction of public
facilities, and (3) expenditures for job
training and educational programs. This
broad definition of qualified economic
development purpose includes capital ex-
penditures (as defined in § 1.150–1(b) of
the Income Tax Regulations) and working
capital expenditures to promote devel-
opment or other economic activity in a
recovery zone. For this purpose, an eli-
gible financing of qualified expenditures
includes a reimbursement of those ex-
penditures under the reimbursement rules
contained in § 1.150–2. By contrast,
Recovery Zone Economic Development
Bonds generally may not be issued to refi-
nance expenditures in “refunding issues”
(as defined in § 1.150–1). Further, for
this purpose, Recovery Zone Economic
Development Bonds may be used to re-
imburse otherwise-eligible expenditures
under § 1.150–2 that were paid or in-
curred after the effective date of ARRA
and that were financed originally with
temporary short-term financing issued af-
ter the effective date of ARRA, and such
reimbursement will not be treated as a
refunding issue under §§ 1.150–1(d) or
1.150–2(g).
.04 CERTAIN OTHER APPLICABLE
RULES
Section 6431(c) provides that for pur-
poses of applying the arbitrage investment
restrictions under § 148, the yield on a
qualified bond (including, for this purpose,
a Recovery Zone Economic Development
Bond), shall be reduced by the refund-
able credit allowed under § 6431. Sec-
tion 6431(d) provides that, for purposes
of § 6431, “interest payment date” means
each date on which interest is payable by
the issuer under the terms of the bond.
Section 54AA(d)(2)(A) provides that, for
purposes of the restrictions against Fed-
eral guarantees of tax-exempt bonds un-
der § 149(b), a Build America Bond (in-
cluding, for this purpose, a Recovery Zone
Economic Development Bond) shall not
be treated as federally guaranteed by rea-
son of the refundable credit allowed un-
der § 6431. Section 54AA(d)(2)(C) pro-
vides that a bond (including, for this pur-
pose, a Recovery Zone Economic Devel-
opment Bond) shall not be treated as a
Build America Bond under § 54AA(d)(1)
if the issue price has more than ade min-
imisamount (determined under rules sim-
ilar to the rules of § 1273(a)(3)) of pre-
mium over the stated principal amount of
the bond.
SECTION 4. RECOVERY ZONE
FACILITY BONDS
.01 RECOVERY ZONE FACILITY
BONDS TREATED AS EXEMPT
FACILITY BONDS
Section 103(a) provides that, except as
otherwise provided in § 103(b), interest
on State or local bonds is excludable from
gross income for Federal income tax pur-
poses. Under § 103(b), interest on a State
and local bond that is a “private activ-
ity bond” under § 141(a) generally is not
excludable from gross income unless the
bond meets the requirements for a quali-
fied private activity bond under § 141(e).
Section 141(e) provides that an “exempt
facility bond” under § 142 is one type of
qualified private activity bond that may
be issued with interest thereon excludable
from gross income under § 103(a). Sec-
tion 1400U–3(a) provides that, for pur-
poses of §§ 141 through 150, the term “ex-
empt facility bond” includes any Recovery
Zone Facility Bond. Section 1400U–3(b)
defines the term “Recovery Zone Facility
Bond” to mean any bond issued as part of
an issue if: (A) 95 percent or more of the
net proceeds (as defined in § 150(a)(3))
of such issue are to be used for recov-
ery zone property; (B) such bond is issued
before January 1, 2011; and (C) the is-
suer designates such bond for purposes of
§ 1400U–3.
.02 RECOVERY ZONE PROPERTY
Section 1400U–3(c)(1) defines the term
“recovery zone property” to mean any
property to which § 168 (relating to the
2009–26 I.R.B.1119June 29, 2009

accelerated cost recovery system) applies
(or would apply but for § 179 (relating
to electing to expense certain depreciable
business assets)) if: (A) such property
was constructed, reconstructed, renovated,
or acquired by purchase (as defined in
§ 179(d)(2)) by the taxpayer after the date
on which the designation of the recovery
zone took effect; (B) the original use of
which in the recovery zone commences
with the taxpayer; and (C) substantially all
of the use of which is in the recovery zone
and is in the active conduct of a qualified
business (as defined in § 1400U–3(c)(2))
by the taxpayer in the recovery zone.
For purposes of § 1400U–3(c)(1), which
provides that the term “recovery zone
property” means, in part, any property to
which § 168 applies (or would apply but
for § 179), any property of a character
generally subject to the allowance for de-
preciation under § 168 (or that would be
generally subject to such allowance but for
§ 179) will be treated as “recovery zone
property,” without regard to whether the
particular property is owned by any State
or local governmental entity that is not
subject to Federal income taxation, pro-
vided that such property otherwise meets
the requirements under § 1400U–3(c)(1).
.03 USE OF RECOVERY ZONE
PROPERTY IN QUALIFIED
BUSINESSES
Section 1400U–3(c)(1)(C) requires that
substantially all of the use of recovery
zone property involve the active conduct
of a qualified business (as defined in
§ 1400U–3(c)(2)) by the taxpayer in the
recovery zone. Section 1400U–3(c)(2)
defines the term “qualified business” to
mean any trade or business except that
(A) the rental to others of real property
located in a recovery zone shall be treated
as a qualified business only if the prop-
erty is not residential rental property (as
defined in § 168(e)(2)), and (B) such term
shall not include any trade or business
consisting of the operation of any facility
described in § 144(c)(6)(B) (relating to
the prohibition on the use of proceeds of
a qualified redevelopment bond for any
private or commercial golf course, country
club, massage parlor, hot tub facility, sun-
tan facility, racetrack or other facility used
for gambling, or any store the principal
business of which is the sale of alcoholic
beverages for consumption off premises).
.04 OTHER APPLICABLE RULES
Section 1400U–3(c)(3) provides that
rules similar to rules of § 1397D(a)(2) and
(b) (relating to substantial renovations and
sale-leasebacks) shall apply for purposes
of § 1400U–3(c). Section 1400U–3(d)
provides that § 146 (relatingtotheprivate
activity bond volume cap) and § 147(d)
(relating to limitations on acquisition of
existing property) shall not apply to any
Recovery Zone Facility Bond. Except as
otherwise provided in this notice or in fu-
ture administrative or regulatory guidance,
rules applicable to exempt facility bonds
under § 142 apply to Recovery Zone Fa-
cility Bonds.
SECTION 5. INTERIM GUIDANCE
AND RELIANCE
.01 IN GENERAL
Pending the promulgation and effective
date of future administrative or regulatory
guidance, taxpayers may rely on the in-
terim guidance provided in this notice.
.02 REASONABLY REQUIRED
RESERVE OR REPLACEMENT FUND
Section 1400U–2(b)(1)(A) requires
that 100 percent of the excess of (i) the
available project proceeds (as defined in
§ 54A to mean sale proceeds of such is-
sue less not more than 2 percent of such
proceeds used to pay issuance costs, plus
investment proceeds thereon), over (ii)
the amounts in a reasonable required re-
serve (within the meaning of § 150(a)(3))
for an issue of Recovery Zone Economic
Development Bonds be used for qualified
economic development purposes. Section
1400U–3(b)(1)(a) requires that 95 percent
or more of the “net proceeds” (as defined
in § 150(a)(3)) of an issue of Recovery
Zone Facility Bonds be used for recovery
zone property. Section 150(a)(3) defines
the term “net proceeds” to mean, with
respect to any issue, the proceeds of such
issue reduced by amounts in a “reasonably
required reserve or replacement fund.” For
these purposes, § 148(d) provides rules for
a reasonably required reserve or replace-
ment fund.
Section 148(d)(1) generally provides
that a bond shall not be treated as an ar-
bitrage bond solely by reason of the fact
that an amount of the proceeds of the is-
sue of which such bond is a part may be
invested in higher yielding investments
which are part of a reasonably required
reserve or replacement fund. The amount
of such proceeds shall not exceed 10 per-
cent of the proceeds of such issue unless
the issuer establishes to the satisfaction
of the Secretary that a higher amount is
necessary. Section 148(d)(2) provides that
a bond issued as part of an issue shall be
treated as an arbitrage bond if the amount
of the proceeds from the sale of such issue
which is part of any reserve or replacement
fund exceeds 10 percent of the proceeds
of the issue (or such higher amount which
the issuer establishes is necessary to the
satisfaction of the Secretary). Section
1.148–2(f) of the Income Tax Regulations
provides additional rules regarding rea-
sonably required reserve or replacement
funds.
.03 INFORMATION REPORTING FOR
RECOVERY ZONE BONDS
(i)Recovery Zone Economic Develop-
ment Bonds.For information relating to
information reporting and direct payments
of refundable credits to issuers of Recov-
ery Zone Economic Development Bonds,
rules similar to those applicable for infor-
mation reporting and payment of credit to
issuers of qualified bonds under § 6431
shall apply.SeeNotice 2009–26, 2009–16
I.R.B. 833 (April 20, 2009).
(ii)Recovery Zone Facility Bonds.The
information reporting requirement for
tax-exempt bonds under § 149(e) applies
to Recovery Zone Facility Bonds under
§ 1400U–3(a). Information reporting re-
turns for Recovery Zone Facility Bonds
arerequiredtobesubmittedatthesame
time and in the same manner as those re-
quired under § 149(e) for exempt facility
bonds on such forms as shall be prescribed
by the IRS for such purpose. Pending
further guidance from the IRS regarding
the applicable forms to be used for such
information reporting for Recovery Zone
Facility Bonds, in the case of an issue of
Recovery Zone Facility Bonds, the issuer
must submit to the IRS an information
return on Form 8038,Information Return
for Tax-Exempt Private Activity Bond Is-
June 29, 200911202009–26 I.R.B.

sues, at the same time and in the same
manner as required under § 149(e), with
modifications as described below. Issuers
of Recovery Zone Facility Bonds should
complete Part II of Form 8038 by check-
ing the box on Line 11q (Other), writing
“Recovery Zone Facility Bonds” in the
space provided for the bond description,
and entering the issue price of the Re-
covery Zone Facility Bonds in the Issue
Price column. For purposes of this notice,
the term “issue” has the meaning used for
tax-exempt bond purposes in § 1.150–1(c).
.04 ELIGIBLE ISSUERS IN GENERAL
AND ALLOCATIONS OF VOLUME
CAP TO ULTIMATE BENEFICIARIES
Eligible issuers of Recovery Zone
Bonds include States, political subdivi-
sions as defined for purposes of § 103,
and entities empowered to issue bonds
on behalf of any such entity under rules
similar to those for determining whether a
bond issued on behalf of a State or polit-
ical subdivision constitutes an obligation
of that State or political subdivision for
purposes of § 103 and § 1.103–1(b) of the
Income Tax Regulations. Further, eligible
issuers include otherwise-eligible issuers
in conduit financing issues (as defined
in § 1.150–1(b)). An eligible issuer may
issue Recovery Zone Bonds based on a
volume cap allocation received by the eli-
gible issuer itself or by a conduit borrower
or other ultimate beneficiary of the issue
of the bonds. In all events, the eligible
costs for qualified economic development
purposes or recovery zone property, as
applicable, financed with the proceeds of
an issue of Recovery Zone Bonds under
§§ 1400U–2 or 1400U–3, respectively,
must relate to any such purpose or prop-
erty that is located within, or attributable
to, both the jurisdiction of the issuer of
the bonds and the jurisdiction of the entity
authorized to allocate volume cap to an
issue of bonds for the financing of such
purpose or property.
Entities authorized to allocate volume
cap to ultimate beneficiaries consist of
States (with respect to allocations waived
or deemed waived by any county or large
municipality), counties, and large munici-
palities (as defined in § 1400U–1(a)(3)(B))
that receive volume cap allocations under
§ 1400U–1(a)(3)(A). Such States, coun-
ties, and large municipalities may use such
volume cap themselves for eligible costs
or may allocate such volume cap received
to ultimate beneficiaries in any reasonable
manner as they shall determine in good
faith in their discretion for use for eligible
costs for qualified economic development
purposes or recovery zone property, as ap-
plicable. In the event that a county or large
municipality that receives an allocation
of volume cap under § 1400U–1(a)(3)(A)
of Recovery Zone Economic Develop-
ment Bonds or Recovery Zone Facility
Bonds does not possess substantial taxing,
eminent domain,andpolice powers, any
entity the jurisdiction of which includes
such county or large municipality may
issue bonds and designate such bonds as
Recovery Zone Economic Development
Bonds or Recovery Zone Facility Bonds,
as applicable, on behalf of, and for the
benefit of, such county or municipality,
subject to the applicable volume cap lim-
itations for those Recovery Zone Bonds
allocated to such county or large munic-
ipality. In such case, the proceeds of an
issue of Recovery Zone Economic Devel-
opment Bonds or Recovery Zone Facility
Bonds under §§ 1400U–2 or 1400U–3,
respectively, must be allocated to eligible
costs for qualified economic development
purposes or recovery zone property, as
applicable, that is located within, or at-
tributable to, both the jurisdiction of the
issuer of the bonds and the jurisdiction
of the county or large municipality that
received the volume cap allocation under
§ 1400U–1(a)(3)(A). Thus, for exam-
ple, a county or large municipality that
received a volume cap allocation under
§ 1400U–1(a)(3)(A) may issue bonds and
designate them as Recovery Zone Eco-
nomic Development Bonds or Recovery
Zone Facility Bonds, as applicable, for
use of that volume cap by an ultimate ben-
eficiary (including such county or large
municipality itself or another entity) or
another eligible issuer may issue bonds
and designate themas Recovery Zone
Economic Development Bonds or Recov-
ery Zone Facility Bonds, as applicable,
for use of that volume cap by an ultimate
beneficiary (including such county or mu-
nicipality or another entity), based on an
allocation by such county or large munic-
ipality of that volume cap to an ultimate
beneficiary. In all events, the proceeds of
the issue must be used to finance eligible
costs for qualified economic development
purposes or recovery zone property, as
applicable, that is located within, or at-
tributable to, both the jurisdiction of the
issuer of the bonds and the jurisdiction of
the county or large municipality autho-
rized to allocate volume cap to an ultimate
beneficiary of the issue of Recovery Zone
Bonds for the financing of those purposes
or property.
.05 WAIVERS OF VOLUME CAP
ALLOCATIONS
Section 1400U–1(a)(3)(A) provides
that a county or large municipality may
waive any portion of a volume cap alloca-
tion received for Recovery Zone Bonds.
Upon any such waiver, the State in which
such county or large municipality is lo-
cated shall be authorized to reallocate
the waived volume cap in any reasonable
manner as it shall determine in good faith
in its discretion.
.06 DESIGNATIONS OF RECOVERY
ZONES
As further described in Section 2.01 of
this notice, § 1400U–1(b) requires, in part,
that issuers “designate” eligible recovery
zones based on certain specified criteria.
For this purpose, any State, county, or
large municipality that receives a volume
cap allocation for Recovery Zone Bonds
may make these designations of recovery
zones in any reasonable manner as it shall
determine in good faith in its discretion.
SECTION 6. ALLOCATIONS OF
RECOVERY ZONE BOND VOLUME
CAP
.01 VOLUME CAP DESIGNATIONS IN
GENERAL
Sections1400U–2(b)(2)and
1400U–3(b)(2) provide generally that the
maximum face amount of the applicable
type of Recovery Zone Bonds designated
for issuance by an issuer cannot exceed the
amounts of volume capfor the applicable
Recovery Zone Bonds allocated to such
issuer under § 1400U–1. For this purpose,
these designations, including associated
determinations of qualified economic
development purposes, may be made
by an issuer in any reasonable manner
as it shall determine in good faith in its
discretion, taking into account the special
2009–26 I.R.B.1121June 29, 2009

rules for eligible issuers under Section
5.04 of this notice.
.02 VOLUME CAP ALLOCATIONS IN
GENERAL
Section 1400U–1(a)(1)(A) provides
that, subject to § 1400U–1(a)(1)(B) (re-
lating to minimum allocations), generally,
the Secretary shall allocate the $10 billion
national volume cap for Recovery Zone
Economic Development Bonds and the
$15 billion national volume cap for Re-
covery Zone Facility Bonds among the
States in the proportion that each State’s
2008 State employment decline bears to
the aggregate of the 2008 State employ-
ment declines for all of the States. Section
1400U–1(a)(1)(B) provides that the Sec-
retary shall adjust the allocations under
§ 1400U–1(a)(1)(A) for any calendar year
for each State to the extent necessary to
ensure that no State receives less than 0.9
percent of the national volume cap for
Recovery Zone Economic Development
Bonds and 0.9 percent of the national
volume cap for Recovery Zone Facility
Bonds.
Section 1400U–1(a)(2) provides that
for purposes of § 1400U–1(a), the term
“2008 State employment decline” means,
with respect to any State, the excess (if
any) of (A) the number of individuals
employed in such State determined for
December 2007, over (B) the number
of individuals employed in such State
determined for December 2008. The
volume cap allocations provided pur-
suant to this notice are based on Local
Area Unemployment Statistics (“LAUS”)
data for December 2007 and December
2008 released by the United States Bu-
reau of Labor Statistics.See generally
http://www.bls.gov/lau/home.htm.
Section 1400U–1(a)(3)(A) provides
generally that each State with respect
to which an allocation is made under
1400U–1(a)(1) is required, without discre-
tion, to reallocate such allocation among
the counties and large municipalities in
such State in the proportion that each
county’s or municipality’s 2008 employ-
ment decline bears to the aggregate of
the 2008 employment declines for all the
counties and municipalities in such State.
For purposes of § 1400U–1(a)(3)(A),
the term “large municipality” means a
municipality with a population of more
than 100,000. For purposes of determin-
ing the local employment decline under
§ 1400U–1(a)(3), the employment de-
cline of any county or large municipality
is determined in the same manner as the
determination of the State employment
decline under 1400U–1(a)(2), except that
in the case of a municipality any portion
of which is in a county, such portion is
treated as part of such municipality and
not as part of such county.
.03 STATE ALLOCATIONS OF
RECOVERY ZONE BOND VOLUME
CAP
Pursuant to § 1400U–1(a), the $10
billion national volume cap for Recov-
ery Zone Economic Development Bonds
and the $15 billion national volume cap
for Recovery Zone Facility Bonds under
§§ 1400U–2 and 1400U–3, respectively,
are allocated among the States as follows:
StateRecovery Zone Economic
Development Bond
Allocations (in dollars)
Recovery Zone Facility Bond
Allocations (in dollars)
Alabama244,676,000367,014,000
Alaska90,000,000
135,000,000
Arizona90,000,000
135,000,000
Arkansas90,000,000
135,000,000
California
806,225,000
1,209,338,000
Colorado99,018,000
148,527,000
Connecticut90,000,000
135,000,000
Delaware90,000,000
135,000,000
District of Columbia90,000,000
135,000,000
Florida
538,485,000
807,727,000
Georgia
355,785,000533,677,000
Hawaii90,000,000
135,000,000
Idaho90,000,000
135,000,000
Illinois666,972,000
1,000,457,000
Indiana313,081,000469,621,000
Iowa90,000,000
135,000,000
Kansas90,000,000
135,000,000
Kentucky97,120,000
145,681,000
Louisiana90,000,000
135,000,000
Maine90,000,000
135,000,000
Maryland208,860,000313,291,000
Massachusetts222,676,000334,013,000
Michigan
773,050,0001,159,575,000
Minnesota
132,154,000
198,231,000
Mississippi90,000,000
135,000,000
Missouri229,143,000
343,715,000
June 29, 200911222009–26 I.R.B.

StateRecovery Zone Economic
Development Bond
Allocations (in dollars)
Recovery Zone Facility Bond
Allocations (in dollars)
Montana90,000,000
135,000,000
Nebraska90,000,000
135,000,000
Nevada90,000,000
135,000,000
New Hampshire90,000,000
135,000,000
New Jersey
251,104,000376,655,000
New Mexico90,000,000
135,000,000
New York370,098,000
555,147,000
North Caroline
418,154,000
627,231,000
North Dakota90,000,000
135,000,000
Ohio422,637,000
633,955,000
Oklahoma90,000,000
135,000,000
Oregon
103,450,000155,175,000
Pennsylvania
154,008,000
231,012,000
Rhode Island100,882,000
151,322,000
South Carolina
115,041,000172,562,000
South Dakota90,000,000
135,000,000
Tennessee231,417,000347,126,000
Texas90,000,000
135,000,000
Utah90,000,000
135,000,000
Vermont90,000,000
135,000,000
Virginia104,396,000
156,595,000
Washington90,000,000
135,000,000
West Virginia90,000,000
135,000,000
Wisconsin
158,811,000
238,217,000
Wyoming90,000,000
135,000,000
American Samoa90,000,000
135,000,000
Guam90,000,000
135,000,000
Northern Marianas90,000,000
135,000,000
Puerto Rico
92,757,000
139,136,000
US Virgin Islands90,000,000
135,000,000
Total10,000,000,000
15,000,000,000
.04 LOCAL SUBALLOCATIONS OF
RECOVERY ZONE BOND VOLUME
CAP AMONG COUNTIES AND
LARGE MUNICIPALITIES
The Treasury Department and the IRS
recognize that the required local suballo-
cations of the national volume cap for Re-
covery Zone Bonds among counties and
large municipalities impose administrative
burdens for the States and involve manda-
tory local suballocations without State dis-
cretion. Accordingly, the Treasury De-
partment and the IRS undertook to deter-
mine these required local suballocations.
For purposes of these local suballocations
among counties and large municipalities,
certain county-equivalent entities (includ-
ing independent cities that are not oth-
erwise located within counties, parishes,
boroughs, and similar entities) are treated
as counties in the same manner that the
Bureau of Labor Statistics treats such en-
tities as county-equivalent entities in its
employment data. This undertaking to
provide local suballocations is intended to
facilitate prompt availability of Recovery
Zone Bonds as a source for State and lo-
cal governmental borrowing at lower bor-
rowingcoststopromotejobcreationand
economic recovery in areas particularly af-
fected by employment declines.
Pursuant to § 1400U–1(a)(3), the State
volume caps of the $10 billion national
volume cap for Recovery Zone Economic
Development Bonds and the $15 billion
national volume cap for Recovery Zone
Facility Bonds under §§ 1400U–2 and
1400U–3, respectively, are reallocated lo-
cally among the counties and large munic-
ipalities within the States (except that no
such local reallocations are being provided
for the Possessions of the United States
(see Section 6.05 of this notice below)) in
a document regarding the Recovery Zone
Bond volume cap allocations being posted
on the IRS’s website at the following web
address:http://www.irs.gov/taxexempt-
bond/index.htmlunder the heading in the
index entitled “IRS Releases Guidance on
ARRA Bond Provisions,” to be available
on the same date that this notice is released
publicly. Stated differently, these local
suballocations will be accessible by going
to the IRS website athttp://ww.irs.gov,
then clicking on the heading “Tax-exempt
Bond Community” in the top right cor-
ner, then clicking on the heading in the
index entitled “IRS Releases Guidance
on ARRA Bond Provisions,” and then
clicking on the subheading regarding the
Recovery Zone Bondvolume cap alloca-
tions, starting on the same date that this
notice is released publicly.
2009–26 I.R.B.1123June 29, 2009

.05 SPECIAL RULES FOR VOLUME
CAP ALLOCATIONS RECEIVED BY
THE POSSESSIONS
In recognition of the disparate local
governmental organizational structures
and disparate availability of employment
data for the Possessions of the United
States, the Possessions may allocate lo-
cally, reallocate locally, or use directly
their respective State allocations of vol-
ume cap for Recovery Zone Bonds in any
reasonable manner as they may determine
in good faith in their discretion.
SECTION 7. EFFECTIVE DATE OF
VOLUME CAP ALLOCATIONS
The allocations of national volume cap
for Recovery Zone Bonds in Section 6 of
this notice are effective for bonds issued on
or after February 17, 2009.
SECTION 8. DRAFTING
INFORMATION
The principal authors of this notice are
Zoran Stojanovic and Timothy L. Jones
of the Office of Associate Chief Counsel
(Financial Institutions and Products). For
further information regarding this notice,
contact Mr. Stojanovic or Mr. Jones at
(202) 622–3980 (not a toll-free call).
Qualified Plug-in Electric
Vehicle Credit
Notice 2009–54
Section 1. PURPOSE
This notice sets forth interim guidance,
pending the issuance of regulations, relat-
ing to the new qualified plug-in electric
drive motor vehicle credit under § 30D of
the Internal Revenue Code. Specifically,
this notice provides procedures for a ve-
hicle manufacturer (or, in the case of a
foreign vehicle manufacturer, its domestic
distributor) to certify to the Internal Rev-
enue Service (“Service”) both:
(1) That a motor vehicle of a particu-
lar make, model, and model year meets
certain requirements that must be satisfied
to claim the new qualified plug-in electric
drive motor vehicle credit under § 30D;
and
(2) The amount of the credit allowable
with respect to that motor vehicle.
This notice also provides guidance to
taxpayers who purchase motor vehicles re-
garding the conditions under which they
may rely on the vehicle manufacturer’s (or,
in the case of a foreign vehicle manufac-
turer, its domestic distributor’s) certifica-
tion in determining whether a credit is al-
lowable with respect to the vehicle and the
amount of the credit. The Service and the
Treasury Department expect that the regu-
lations will incorporate the rules set forth
in this notice.
Section 30D originally was enacted in
the Energy Improvement and Extension
Act of 2008, Pub. L. 110–343, 122 Stat.
3765. The American Recovery and Rein-
vestment Act of 2009, Pub. L. 111–5, 123
Stat. 115, amended § 30D in certain re-
spects, and those amendments are effective
for vehicles acquired after December 31,
2009. The Service and Treasury Depart-
ment will issue subsequent guidance relat-
ing to those amendments. All references to
§ 30D in this notice are to the provision as
in effect before its amendment.
Section 2. BACKGROUND
Section 30D provides for a credit for
certain new qualified plug-in electric drive
motor vehicles. The credit is equal to the
sum of: (1) $2,500, plus (2) $417 for each
kilowatt hour of traction battery capacity
in excess of 4 kilowatt hours. Section
30D(b)(1) limits the amount of the credit
allowed for a vehicle to amounts ranging
from $7,500 to $15,000, depending on the
gross vehicle weight rating of the vehicle.
The new qualified plug-in electric drive
motor vehicle credit phases out over the
period beginning with the second calendar
quarter after the calendar quarter in which
at least 250,000 qualifying vehicles have
been sold for use in the United States (de-
termined on a cumulative basis for sales
after December 31, 2008) (phase-out pe-
riod”). Qualifying vehicles purchased in
the first two calendar quarters of the phase-
out period are eligible for 50 percent of
the credit. Qualifying vehicles purchased
in the third and fourth calendar quarters of
the phase-out period are eligible for 25 per-
cent of the credit. Vehicles purchased after
the last day of the fourth calendar quarter
of the phase-out period are not eligible for
a credit. If a vehicle qualifies for a credit
under both § 30B and § 30D, the amount
of the credit allowed under § 30B is the
amount of the otherwise allowable credit
under that section reduced (but not below
zero) by the amount of the credit allowed
under § 30D. In addition, if a vehicle qual-
ifies for a credit under § 30D, no credit is
allowed for that vehicle under § 30.
Section 3. SCOPE OF NOTICE
The new qualified plug-in electric drive
motor vehicle credit applies to plug-in
electric drive motor vehicles, including
low speed vehicles as defined in section
4(6) of this notice, that—
(1) Are placed in service by the tax-
payer in a taxable year beginning after De-
cember 31, 2008;
(2) Are acquired by the taxpayer on or
before December 31, 2009; and
(3) Otherwise meet the requirements of
§30D.
Section 4. MEANING OF TERMS
The following definitions apply for pur-
poses of this notice:
.01In General. Terms used in this no-
tice and not defined in this section 4 have
thesamemeaningaswhenusedin§30D.
.02 Clean Air Act Regulations. The
Clean Air Act regulations are the regula-
tions prescribed by the Administrator of
the Environmental Protection Agency for
purposes of the administration of title II of
the Clean Air Act (42 U.S.C. §§ 7521,et.
seq.).
.03Traction Battery Capacity. Traction
battery capacity is measured in kilowatt
hours from a 100 percent state of charge
to a zero percent state of charge.
.04Motor Vehicle. The term “motor
vehicle” has the meaning given that term
by§30(c)(2).
.05Manufacturer. The term “manufac-
turer” has the meaning given that term in
the Clean Air Act regulations.
.06Passenger Vehicle and Light Truck.
The terms “passenger vehicle” and “light
truck” do not include (1) any vehicle that
has a gross vehicle weight of more than
8,500 pounds and (2) any vehicle that is
not treated as a motor vehicle in the Clean
Air Act regulations. A low speed vehicle,
as defined in section 4.07 of this notice, is
not treated as a motor vehicle in the Clean
Air Act regulations. Accordingly, a low
June 29, 200911242009–26 I.R.B.

speed vehicle is not a passenger vehicle or
light truck and is not required to receive a
certificate of conformity under the Clean
Air Act to qualify for the credit.
.07Low Speed Vehicle.The term “low
speed vehicle” means a vehicle:
(1) That has at least four wheels;
(2) That is manufactured primarily for
use on public streets, roads and highways
(not including a vehicle operated exclu-
sively on a rail or rails);
(3) That is not manufactured primarily
for off-road use, such as primarily for use
on a golf course;
(4) Whose speed attainable in one mile
is more than 20 miles per hour and not
more than 25 miles per hour on a paved
level surface; and
(5) Whose gross vehicle weight rating
is less than 3,000 pounds.
.08Model Year. The term “model year”
means the model year determined under
the Clean Air Act regulations (see 40 CFR
§ 86–082–2).
Section 5. MANUFACTURER’S
CERTIFICATION AND QUARTERLY
REPORTS
.01When Certification Permitted.A
vehicle manufacturer (or, in the case of a
foreign vehicle manufacturer, its domes-
tic distributor) may certify to purchasers
that a motor vehicle of a particular make,
model, and model year meets all require-
ments (other than those listed in section
5.02 of this notice) that must be satisfied
to claim the new qualified plug-in electric
drive motor vehicle credit allowable under
§ 30D with respect to the vehicle, if the fol-
lowing requirements are met:
(1) The manufacturer (or, in the case of
a foreign vehicle manufacturer, its domes-
tic distributor) has submitted to the Ser-
vice, in accordance with this section 5 of
this notice, a certification with respect to
the vehicle and the certification satisfies
the requirements of section 5.03 of this no-
tice;
(2) The manufacturer (or, in the case of
a foreign vehicle manufacturer, its domes-
tic distributor) hasreceived an acknowl-
edgment of the certification from the Ser-
vice.
.02Purchaser’s Reliance. Except as
provided in section 5.07 of this notice, a
purchaserofamotorvehiclemayrelyon
the manufacturer’s (or, in the case of a
foreign vehicle manufacturer, its domestic
distributor’s) certification concerning the
vehicle and the amount of the credit allow-
able with respect to the vehicle (including
in cases in which the certification is re-
ceived after the purchase of the vehicle).
The purchaser may claim a credit in the
certified amount with respect to the vehi-
cle if the following requirements are satis-
fied:
(1) The vehicle is placed in service by
the taxpayer in a taxable year beginning
after December 31, 2008, and is purchased
by the taxpayer on or before December 31,
2009;
(2) The original use of the vehicle com-
mences with the taxpayer;
(3) The vehicle is acquired for use or
lease by the taxpayer, and not for resale;
and
(4) The vehicle is used predominantly
in the United States.
.03Content of Certification. The cer-
tification must contain the information re-
quired in section 5.03(1) of this notice and
any applicable additional information re-
quired in section 5.03(2) or (3) of this no-
tice.
(1)All Vehicles. For all vehicles, the
certification must contain the following:
(a) The name, address, and taxpayer
identification number of the certifying en-
tity.
(b) The make, model, model year, and
any other appropriate identifiers of the mo-
tor vehicle.
(c) A statement that the vehicle is made
by a manufacturer.
(d) A statement that the vehicle is a mo-
tor vehicle within the meaning of section
4.03 of this notice.
(e) The amount of the credit for the ve-
hicle (showing computations).
(f) The gross vehicle weight rating of
the vehicle.
(g) A statement that the motor vehicle
draws propulsion using a traction battery
with at least 4 kilowatt hours of capacity.
(h) The number of kilowatt hours, if
any, in excess of 4 kilowatt hours.
(i) A statement that the vehicle uses an
offboard source of energy to recharge the
battery.
(j) A statement that the vehicle com-
plies with the applicable provisions of the
Clean Air Act.
(k) A statement that the vehicle com-
plies with the applicable air quality pro-
visions of state law of each state that has
adopted the provisions under a waiver un-
der § 209(b) of the Clean Air Act or a list
identifying each state that has adopted ap-
plicable air quality provisions with which
the vehicle does not comply.
(l) A description of the motor vehicle
safety provisions of 49 U.S.C. §§ 30101
through 30169 applicable to the vehicle
and a statement that the vehicle complies
with those provisions.
(m) A declaration, applicable to the cer-
tification, statements, and any accompa-
nying documents, signed by a person cur-
rently authorized tobind the manufacturer
(or, in the case of a foreign vehicle manu-
facturer, its domesticdistributor) in these
matters, in the following form: “Under
penalties of perjury, I declare that I have
examined this certification, including ac-
companying documents, and to the best of
my knowledge and belief, the facts pre-
sented in support of this certification are
true, correct, and complete.”
(2)Passenger Vehicles and Light
Trucks. If the vehicle is a passenger
vehicle or light truck (determined after
application of the limitations in section
4.06 of this notice), the certification must
also contain the following:
(a) A copy of the certificate of confor-
mity under the Clean Air Act.
(b) Documents demonstrating that the
vehicle meets or exceeds the equivalent
qualifying California low emission vehi-
cle standard under section 243(e)(2) of the
Clean Air Act for that make and model
year.
(c) In the case of a vehicle having
a gross vehicle weight rating of 6,000
pounds or less, documents showing that
the vehicle meets or exceeds the Bin 5 Tier
II emission standard established in reg-
ulations prescribed by the Administrator
of the Environmental Protection Agency
under section 202(i) of the Clean Air Act
for that make and model year vehicle.
(d) In the case of a vehicle having a
gross vehicle weight rating of more than
6,000 pounds, but not more than 8,500
pounds, documents showing the vehicle
meets or exceeds the Bin 8 Tier II emis-
sion standard which is so established.
(3)Low Speed Vehicles. A certification
with respect to a low speed vehicle as de-
finedinsection4.07ofthisnoticemust
also contain the following:
2009–26 I.R.B.1125June 29, 2009

(a) A statement that the vehicle has at
least four wheels.
(b) A statement that the vehicle is
manufactured primarily for use on public
streets, roads and highways.
(c) A statement that the vehicle is not
manufactured primarily for off-road use,
such as primarily for use on a golf course.
(d) Evidence that the speed attainable
bythevehicleinonemileismorethan20
miles per hour and not more than 25 miles
per hour on a paved level surface.
.04Acknowledgement of Certification.
The Service will review the original signed
certification and issue an acknowledgment
letter to the vehicle manufacturer (or, in
the case of a foreign vehicle manufacturer,
its domestic distributor) within 30 days of
receipt of the request for certification. This
acknowledgment letter will state whether
purchasers may rely on the certification.
.05Quarterly Reporting of Sales of
Qualified Vehicles. A manufacturer (or, in
the case of a foreign vehicle manufacturer,
its domestic distributor) that has received
an acknowledgment of its certification
from the Service must submit to the Ser-
vice, in accordance with section 6 of this
notice, a report of the number of qualified
plug-in electric drive motor vehicles sold
by the manufacturer (or, in the case of a
foreign vehicle manufacturer, its domestic
distributor) to consumers or retail dealers
during the calendar quarter. The quarterly
report must contain the following infor-
mation:
(1) The name, address, and taxpayer
identification number of the reporting en-
tity.
(2) The number of qualified vehicles
sold by the reporting entity to consumers
or retail dealers during the calendar quar-
ter.
(3) The make, model, model year, and
any other appropriateidentifiers of the
qualified vehicles sold during the calendar
quarter.
(4) A declaration, applicable to the
quarterly report and any accompanying
documents, signed by a person currently
authorized to bind the manufacturer (or, in
the case of a foreign vehicle manufacturer,
its domestic distributor) in these matters,
in the following form: “Under penalties
of perjury, I declare that I have examined
this report, including accompanying doc-
uments, and to the best of my knowledge
and belief, the facts presented in support
of this report are true, correct, and com-
plete.”
.06Acknowledgment of Quarterly Re-
port. The Service will review the orig-
inal signed quarterly report and issue
an acknowledgment letter to the vehicle
manufacturer (or, inthe case of a foreign
vehicle manufacturer, its domestic dis-
tributor) within 30 days of receipt of the
report. This acknowledgment letter will
state whether purchasers may continue to
rely on the certification.
.07Effect of Erroneous Certification,
Erroneous Quarterly Reports, or Failure
to Make Timely Quarterly Reports.
(1)Erroneous Certification or Quar-
terly Report. The acknowledgment that
the Service provides for a certification is
not a determination that a vehicle quali-
fies for the credit, or that the amount of
the credit is correct. The Service may,
upon examination (and after any appro-
priate consultation with the Department of
Transportation or the Environmental Pro-
tection Agency), determine that the vehi-
cle is not a new qualified plug-in electric
drive motor vehicle or that the amount of
the credit determined by the manufacturer
(or, in the case of a foreign vehicle manu-
facturer, its domestic distributor) to be al-
lowable with respect to the vehicle is in-
correct. In either event, or in the event
that the manufacturer (or, in the case of a
foreign vehicle manufacturer, its domestic
distributor) makes an erroneous quarterly
report, the manufacturer’s (or, in the case
of a foreign vehicle manufacturer, its do-
mestic distributor’s) right to provide a cer-
tification to future purchasers of the new
qualified plug-in electric drive motor ve-
hicles will be withdrawn, and purchasers
who acquire a vehicle after the date on
which the Service publishes an announce-
ment of the withdrawal may not rely on the
certification. Purchasers may continue to
rely on the certification for vehicles they
acquired on or before the date on which the
announcement of the withdrawal is pub-
lished (including in cases in which the ve-
hicle is not placed in service and the credit
is not claimed until after that date), and
the Service will not attempt to collect any
understatement of tax liability attributable
to such reliance. Manufacturers (or, in
the case of foreign vehicle manufacturers,
their domestic distributors) are reminded
that an erroneous certification or an erro-
neous quarterly report may result in the
imposition of penalties, including, but not
limited to, the penalties:
(a) Under § 7206 for fraud and making
false statements; and
(b) Under § 6701 for aiding and abetting
an understatement of tax liability in the
amount of $1,000 ($10,000 in the case of
understatements by corporations) per re-
turn on which a credit is claimed in re-
liance on the certification.
(2)Failure to Make Timely Quarterly
Report. If a manufacturer (or, in the case
of a foreign vehicle manufacturer, its do-
mestic distributor) fails to make a quar-
terly report in accordance with section 5.05
of this notice and at the time specified in
section 6.02 of this notice, the acknowl-
edgment letter issued under section 5.04
of this notice may be withdrawn, and pur-
chasers will not be entitled to rely on the
related certification for quarters beginning
after the date on which the Service pub-
lishes an announcement of the withdrawal
(generally, quarters beginning after the due
date of the report). If the quarterly report
is filed subsequently, the Service may reis-
sue the acknowledgment letter and retract
the withdrawal announcement.
Section 6. TIME AND ADDRESS
FOR FILING CERTIFICATION AND
QUARTERLY REPORTS
.01Time for Filing Certification.Inor-
der for a certification under section 5 of
this notice to be effective for new quali-
fied plug-in electric drive motor vehicles
placed in service during a calendar year,
the certification must be received by the
Service not later than December 31 of that
calendar year.
.02Time for Filing Quarterly Reports.
A report of sales of qualified vehicles dur-
ing a quarter must be filed with the Service
at the address specified in section 6.03 of
this notice not later than the last day of the
first calendar month following the quarter
to which the report relates.
.03Address for Filing. Certifications
and quarterly reports under section 5 of
this notice must be sent to:
Internal Revenue Service
Industry Director, LMSB, Heavy
Manufacturing & Transportation
MetroParkOfficeComplex—LMSB
111 Wood Avenue, South
Iselin, New Jersey 08830
June 29, 200911262009–26 I.R.B.

Section 7. PAPERWORK REDUCTION
ACT
The collection of information contained
in this notice has been reviewed and ap-
proved by the Office of Management and
Budget in accordance with the Paperwork
Reduction Act (44 U.S.C. 3507) under
control number 1545–2137.
An agency may not conduct or sponsor,
and a person is not required to respond
to, a collection of information unless the
collection of information displays a valid
OMB control number.
The collections of information in this
notice are in sections 5 and 6. This infor-
mation is collected and retained in order
to ensure that vehicles meet the require-
ments for the new qualified plug-in elec-
tric drive motor vehicle credit under § 30D.
This information will be used to determine
whether the vehicle for which the credit
is claimed by a taxpayer is property that
qualifies for the credit. The collection of
information is voluntary to obtain a ben-
efit. The likely respondents are corpora-
tions and partnerships.
The estimated total annual reporting
burden is 280 hours.
The estimated annual burden per re-
spondent varies from 20 hours to 35 hours,
depending on individual circumstances,
with an estimated average burden of 24
hours to complete the certification re-
quired under this notice. The estimated
number of respondents is 12.
The estimated annual frequency of re-
sponses is on occasion.
Books or records relating to a collection
of information must be retained as long
as their contents may become material in
the administration of any internal revenue
law. Generally, tax returns and tax return
information are confidential, as required
by 26 U.S.C. 6103.
SECTION 8. DRAFTING
INFORMATION
The principal author of this notice is
Patrick S. Kirwan of the Office of Asso-
ciate Chief Counsel (Passthroughs & Spe-
cial Industries). For further information
regarding this notice, contact Mr. Kirwan
at (202) 622–3110 (not a toll-free call).
2009–26 I.R.B.1127June 29, 2009

Part IV. Items o
fGeneralInterest
Deletions From Cumulative
List of Organizations
Contributions to Which
are Deductible Under Section
170 of the Code
Announcement 2009–54
The Internal Revenue Service has re-
voked its determination that the organi-
zations listed below qualify as organiza-
tions described in sections 501(c)(3) and
170(c)(2) of the Internal Revenue Code of
1986.
Generally, the Service 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 Service is not
precluded from disallowing a deduction
for any contributions made after an or-
ganization 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 declara-
tory judgment has been timely filed, con-
tributions from individuals and organiza-
tions described in section 170(c)(2) that
are otherwise allowable will continue to
be deductible. Protection under section
7428(c) would begin on June 29, 2009, and
would end on the date the court first deter-
mines that the organization is not described
in section 170(c)(2) as more particularly
set forth in section 7428(c)(1). For indi-
vidual contributors, the maximum deduc-
tion protected is $1,000, with a husband
and wife treated as one contributor. This
benefit is not extended to any individual, in
wholeorinpart,fortheactsoromissions
of the organization that were the basis for
revocation.
Home Ownership Providers, Inc
Marietta, GA
Wasatch Homes Charitable Foundation
Draper, UT
Announcement of Disciplinary Sanctions From the Office
of Professional Responsibility
Announcement 2009-55
TheOfficeofProfessionalResponsi-
bility (OPR) announcesrecent disciplinary
sanctions involving attorneys, certified
public accountants, enrolled agents, en-
rolled actuaries, enrolled retirement plan
agents, and appraisers. These individuals
are subject to the regulations governing
practice before the Internal Revenue Ser-
vice (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.
The disciplinary sanctions to be im-
posed for violation of the regulations are:
Disbarred from practice before the
IRS—An individual who is disbarred is
not eligible to represent taxpayers before
the IRS.
Suspended from practice before the
IRS—An individual who is suspended is
not eligible to represent taxpayers before
the IRS during the term of the suspension.
Censured in practice before the
IRS—Censure is a public reprimand. Un-
like disbarment or suspension, censure
does not affect an individual’s eligibility
to represent taxpayers before the IRS, but
OPR may subject the individual’s future
representations 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 sanc-
tion or on an employer, firm, or entity
if the individual was acting on its behalf
and if 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.
Under the regulations, attorneys, cer-
tified public accountants, enrolled agents,
enrolled actuaries, and enrolled retirement
plan agents may not assist, or accept assis-
tance from, individuals who are suspended
or disbarred with respect to matters consti-
tuting practice (i.e., representation) before
the IRS, and they may not aid or abet sus-
pended or disbarred individuals to practice
before the IRS.
Disciplinary sanctions are described in
these terms:
Disbarred by decision after hearing,
Suspended by decision after hearing,
Censured by decision after hearing,
Monetary penalty imposed after hear-
ing, and Disqualified after hearing—An
administrative law judge (ALJ) conducted
an evidentiary hearing upon OPR’s com-
plaint alleging violation of the regulations
and issued a decision imposing one of
these sanctions. After 30 days from the
issuance of the decision, in the absence of
an appeal, the ALJ’s decision became the
final agency decision.
Disbarred by default decision, Sus-
pended by default decision, Censured by
default decision, Monetary penalty im-
posed by default decision, and Disqual-
ified by default decision—An ALJ, after
finding that no answer to OPR’s complaint
had been filed, granted OPR’s motion for a
default judgment and issued a decision im-
posing one of these sanctions.
Disbarment by decision on appeal,
Suspended by decision on appeal, Cen-
sured by decision on appeal, Monetary
penalty imposed by decision on ap-
peal, and Disqualified by decision on
appeal—The decision of the ALJ was
appealed to the agency appeal authority,
June 29, 200911282009–26 I.R.B.

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, Mone-
tary penalty imposed by consent, and
Disqualified by consent—In lieu of a
disciplinary proceeding being instituted
or continued, an individual offered a con-
sent 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 sus-
pension; and the individual’s opportunity,
after a stated number of months, to file
with OPR a petition for reinstatement af-
firming compliance with the terms of the
consent and affirming current eligibility
to practice (i.e., an active professional
license or active enrollment status). An
enrolled agent or an enrolled retirement
plan agent may also offer to resign in order
to avoid a disciplinary proceeding.
Suspended by decision in expedited
proceeding, Suspended by default de-
cision in expedited proceeding, Sus-
pended by consent in expedited pro-
ceeding—OPR instituted an expedited
proceeding for suspension (based on cer-
tain limited grounds, including loss of a
professional licenseand criminal convic-
tions).
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 decision
on or after September 26, 2007, which was
theeffectivedateofamendmentstothe
regulations that permit making such deci-
sions publicly available; (2) the individual
has settled a disciplinary case by signing
OPR’s “consent to sanction” form, which
requires consenting individuals to admit to
one or more violations of the regulations
and to consent to the disclosure of the in-
dividual’s own return information related
to the admitted violations (for example,
failure to file Federal income tax returns);
or (3) OPR has issued a decision in an
expedited proceeding for suspension.
Announcements of disciplinary sanc-
tions appear in the Internal Revenue Bul-
letin at the earliest practicable date. The
sanctions announced below are alphabet-
ized first by the names of states and sec-
ond by the last names of individuals. Un-
less otherwise indicated, section numbers
(e.g., §10.51) refer to the regulations.
City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Arizona
ScottsdaleAinsworth, Brent L.Enrolled AgentSuspended by default
decision in expedited
proceeding under § 10.82
(conviction under
18 U.S.C. § 287, false
fictitious and fraudulent
claims)
Indefinite from
June 8, 2009
Illinois
Long GroveNeubauer, David K.Enrolled AgentDisbarred by ALJ default
decision for violation of
§ 10.51 (willful failure
to timely file Forms
941 and for failure to
make required deposits of
employment taxes)
Indefinite from
April 14, 2009
Kansas
OlatheDowell, Douglas W.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license in Missouri)
Indefinite from
June 8, 2009
Arkansas CityParman, Jon P.CPASuspended by consent
for violation of § 10.51
(failure to timely file
several Form 1040)
Indefinite from
April 1, 2009
2009–26 I.R.B.1129June 29, 2009

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Kentucky
SalyersvilleHoward, VickieAttorneySuspended by decision
in expedited proceeding
under § 10.82 (suspension
of attorney license)
Indefinite from
June 8, 2009
Massachusetts
LynnSacher, Bruce N.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
June 8, 2009
Skouras, Jr., Peter G.,
See New Hampshire
Minnesota
MinneapolisTaber, Daniel P.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
June 8, 2009
Missouri
Dowell, Douglas W.,
See Kansas
New Hampshire
ExeterSkouras, Jr., Peter G.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment in
Massachusetts)
Indefinite from
June 8, 2009
New York
BaysideKatz, Benjamin Z.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
June 8, 2009
North Carolina
WaxhawSmith, Troy A.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
June 8, 2009
Ohio
DublinCole, Michael D.CPASuspended by default
decision in expedited
proceeding under § 10.82
(revocation of CPA
license)
Indefinite from
June 4, 2009
June 29, 200911302009–26 I.R.B.

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Texas
WeatherfordVickers, Brenda J.AttorneySuspended by default
decision in expedited
proceeding under
§ 10.82 (conviction
under 26 U.S.C. § 7203,
intentional failure to file
personal tax return)
Indefinite from
June 4, 2009
2009–26 I.R.B.1131June 29, 2009

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 ef-
fect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is be-
ingextendedtoapplytoavariationofthe
fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that the
same principle also applies to B, the earlier
ruling is amplified. (Compare withmodi-
fied,below).
Clarifiedis used in those instances
where the language in a prior ruling is be-
ing 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.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis 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
withamplifiedandclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used in
a ruling that lists previously published rul-
ings 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.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
beingstatedinanewruling.
Supersededdescribes a situation where
the new ruling does nothing more than re-
state the substance and situation of a previ-
ously published ruling (or rulings). Thus,
the term is used to republish under the
1986 Code and regulations the same po-
sition published under the 1939 Code and
regulations. The term is also used when
it is desired to republish in a single rul-
ing a series of situations, names, etc., that
were previously published over a period of
time in separate rulings. If the new rul-
ing does more than restate the substance
of a prior ruling, a combination of terms
is used. For example,modifiedandsu-
persededdescribes 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 pub-
lished ruling is first modified and then, as
modified, is superseded.
Supplementedis 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 rul-
ing has been supplemented several times, a
new ruling may be published that includes
the list in the original ruling and the ad-
ditions, and supersedes all prior rulings in
the series.
Suspendedis 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 fol
lowing abbreviations in current use
and for
merly used will appear in material
publis
hedintheBulletin.
A—Individual.
Acq.—A
cquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank
.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cu
mulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Coo
perative.
Ct.D.—Court Decision.
CY—County.
D—Decede
nt.
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—Emp
loyer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduc
iary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Fo
reign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Fed
eral Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grante
e.
GP—General Partner.
GR—Grantor.
IC—Insura
nce Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited
Partner.
LR—Lessor.
M—Minor.
Nonacq.—No
nacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Persona
l Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Pa
rtnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Re
al Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsi
diary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target
Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Trans
feree.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpay
er.
TR—Trust.
TT—Trustee.
U.S.C.—Uni
ted States Code.
X—Corporation.
Y—Corporation.
Z—Corporat
ion.
June 29, 2009i2009–26 I.R.B.

Numerical Finding List
1
Bulletins 2009–1 through 2009–26
Announcements:
2009-1, 2009-1 I.R.B.242
2009-2, 2009-5 I.R.B.424
2009-3, 2009-6 I.R.B.459
2009-4, 2009-8 I.R.B.597
2009-5, 2009-8 I.R.B.569
2009-6, 2009-9 I.R.B.643
2009-7, 2009-10 I.R.B.663
2009-8, 2009-8 I.R.B.598
2009-9, 2009-9 I.R.B.643
2009-10, 2009-9 I.R.B.644
2009-11, 2009-10 I.R.B.663
2009-12, 2009-11 I.R.B.686
2009-13, 2009-11 I.R.B.686
2009-14, 2009-11 I.R.B.687
2009-15, 2009-11 I.R.B.687
2009-16, 2009-11 I.R.B.691
2009-17, 2009-12 I.R.B.714
2009-18, 2009-12 I.R.B.714
2009-19, 2009-12 I.R.B.715
2009-20, 2009-12 I.R.B.716
2009-21, 2009-13 I.R.B.730
2009-22, 2009-13 I.R.B.731
2009-23, 2009-13 I.R.B.731
2009-24, 2009-13 I.R.B.732
2009-25, 2009-14 I.R.B.755
2009-26, 2009-14 I.R.B.755
2009-27, 2009-14 I.R.B.756
2009-28, 2009-15 I.R.B.760
2009-29, 2009-14 I.R.B.757
2009-30, 2009-15 I.R.B.794
2009-31, 2009-15 I.R.B.798
2009-32, 2009-15 I.R.B.799
2009-33, 2009-15 I.R.B.799
2009-34, 2009-18 I.R.B.916
2009-35, 2009-17 I.R.B.892
2009-36, 2009-18 I.R.B.927
2009-37, 2009-19 I.R.B.940
2009-38, 2009-19 I.R.B.940
2009-39, 2009-20 I.R.B.1022
2009-40, 2009-20 I.R.B.1023
2009-41, 2009-20 I.R.B.1026
2009-42, 2009-20 I.R.B.1027
2009-43, 2009-24 I.R.B.1075
2009-44, 2009-24 I.R.B.1079
2009-45, 2009-21 I.R.B.1040
2009-46, 2009-21 I.R.B.1040
2009-47, 2009-23 I.R.B.1071
2009-48, 2009-23 I.R.B.1071
2009-49, 2009-24 I.R.B.1092
2009-50, 2009-25 I.R.B.1105
2009-51, 2009-25 I.R.B.
1105
2009-52, 2009-25 I.R.B.1106
Announcements— Continued:
2009-53, 2009-25 I.R.B.1107
2009-54, 2009-26 I.R.B.1128
2009-55, 2009-26 I.R.B.1128
Notices:
2009-1, 2009-2 I.R.B.250
2009-2, 2009-4 I.R.B.344
2009-3, 2009-2 I.R.B.250
2009-4, 2009-2 I.R.B.251
2009-5, 2009-3 I.R.B.309
2009-6, 2009-3 I.R.B.311
2009-7, 2009-3 I.R.B.312
2009-8, 2009-4 I.R.B.347
2009-9, 2009-5 I.R.B.419
2009-10, 2009-5 I.R.B.419
2009-11, 2009-5 I.R.B.420
2009-12, 2009-6 I.R.B.446
2009-13, 2009-6 I.R.B.447
2009-14, 2009-7 I.R.B.516
2009-15, 2009-6 I.R.B.449
2009-16, 2009-8 I.R.B.572
2009-17, 2009-8 I.R.B.575
2009-18, 2009-10 I.R.B.648
2009-19, 2009-10 I.R.B.660
2009-20, 2009-12 I.R.B.711
2009-21, 2009-13 I.R.B.724
2009-22, 2009-14 I.R.B.741
2009-23, 2009-16 I.R.B.802
2009-24, 2009-16 I.R.B.817
2009-25, 2009-15 I.R.B.758
2009-26, 2009-16 I.R.B.833
2009-27, 2009-16 I.R.B.838
2009-28, 2009-24 I.R.B.1082
2009-29, 2009-16 I.R.B.849
2009-30, 2009-16 I.R.B.852
2009-31, 2009-16 I.R.B.856
2009-32, 2009-17 I.R.B.865
2009-33, 2009-17 I.R.B.865
2009-34, 2009-17 I.R.B.876
2009-35, 2009-17 I.R.B.876
2009-36, 2009-17 I.R.B.883
2009-37, 2009-18 I.R.B.898
2009-38, 2009-18 I.R.B.901
2009-39, 2009-18 I.R.B.902
2009-40, 2009-19 I.R.B.931
2009-41, 2009-19 I.R.B.933
2009-42, 2009-20 I.R.B.1011
2009-43, 2009-21 I.R.B.1037
2009-44, 2009-21 I.R.B.1037
2009-45, 2009-22 I.R.B.1047
2009-46, 2009-23 I.R.B.1068
2009-47, 2009-24 I.R.B.1083
2009-48, 2009-24 I.R.B.1085
2009-49, 2009-25 I.R.B.1093
2009-50, 2009-26 I.R.B.1118
Notices— Continued:
2009-52, 2009-25 I.R.B.1094
2009-53, 2009-25 I.R.B.1095
2009-54, 2009-26 I.R.B.1124
2009-56, 2009-25 I.R.B.1100
Proposed Regulations:
REG-144615-02, 2009-7 I.R.B.561
REG-144689-04, 2009-18 I.R.B.906
REG-148568-04, 2009-5 I.R.B.421
REG-160872-04, 2009-4 I.R.B.358
REG-158747-06, 2009-4 I.R.B.362
REG-116699-07, 2009-13 I.R.B.727
REG-138326-07, 2009-9 I.R.B.638
REG-143686-07, 2009-8 I.R.B.579
REG-150670-07, 2009-4 I.R.B.378
REG-107271-08, 2009-22 I.R.B.1051
REG-107845-08, 2009-20 I.R.B.1014
REG-113462-08, 2009-4 I.R.B.379
REG-119532-08, 2009-20 I.R.B.1017
REG-147636-08, 2009-9 I.R.B.641
REG-150066-08, 2009-5 I.R.B.423
REG-115699-09, 2009-22 I.R.B.1052
Revenue Procedures:
2009-1, 2009-1 I.R.B.1
2009-2, 2009-1 I.R.B.87
2009-3, 2009-1 I.R.B.107
2009-4, 2009-1 I.R.B.118
2009-5, 2009-1 I.R.B.161
2009-6, 2009-1 I.R.B.189
2009-7, 2009-1 I.R.B.226
2009-8, 2009-1 I.R.B.229
2009-9, 2009-2 I.R.B.256
2009-10, 2009-2 I.R.B.267
2009-11, 2009-3 I.R.B.313
2009-12, 2009-3 I.R.B.321
2009-13, 2009-3 I.R.B.323
2009-14, 2009-3 I.R.B.324
2009-15, 2009-4 I.R.B.356
2009-16, 2009-6 I.R.B.449
2009-17, 2009-7 I.R.B.517
2009-18, 2009-11 I.R.B.670
2009-19, 2009-14 I.R.B.747
2009-20, 2009-14 I.R.B.749
2009-21, 2009-16 I.R.B.860
2009-22, 2009-16 I.R.B.862
2009-23, 2009-17 I.R.B.884
2009-24, 2009-17 I.R.B.885
2009-25, 2009-24 I.R.B.1088
2009-26, 2009-19 I.R.B.935
2009-27, 2009-19 I.R.B.938
2009-28, 2009-20 I.R.B.1011
2009-29, 2009-22 I.R.B.1050
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2008–27 through 2008–52 is in Internal Revenue Bulletin
2008–52, dated December 29, 2008.
2009–26 I.R.B.iiJune 29, 2009

Revenue Rulings:
2009-1, 2009-2 I.R.B.248
2009-2, 2009-2 I.R.B.245
2009-3, 2009-5 I.R.B.382
2009-4, 2009-5 I.R.B.408
2009-5, 2009-6 I.R.B.432
2009-6, 2009-12 I.R.B.694
2009-7, 2009-13 I.R.B.717
2009-8, 2009-10 I.R.B.645
2009-9, 2009-14 I.R.B.735
2009-10, 2009-14 I.R.B.738
2009-11, 2009-18 I.R.B.896
2009-12, 2009-19 I.R.B.928
2009-13, 2009-21 I.R.B.1029
2009-14, 2009-21 I.R.B.1031
2009-15, 2009-21 I.R.B.1035
2009-16, 2009-23 I.R.B.1058
2009-17, 2009-26 I.R.B.1111
Tax Conventions:
2009-5, 2009-8 I.R.B.569
2009-43, 2009-24 I.R.B.1075
2009-44, 2009-24 I.R.B.1079
Treasury Decisions:
9434, 2009-4 I.R.B.339
9435, 2009-4 I.R.B.333
9436, 2009-3 I.R.B.268
9437, 2009-4 I.R.B.341
9438, 2009-5 I.R.B.387
9439, 2009-5 I.R.B.416
9440, 2009-5 I.R.B.409
9441, 2009-7 I.R.B.460
9442, 2009-6 I.R.B.434
9443, 2009-8 I.R.B.564
9444, 2009-9 I.R.B.603
9445, 2009-9 I.R.B.635
9446, 2009-9 I.R.B.607
9447, 2009-12 I.R.B.694
9448, 2009-20 I.R.B.942
9449, 2009-22 I.R.B.1044
9450, 2009-24 I.R.B.1073
9451, 2009-23 I.R.B.1060
June 29, 2009iii2009–26 I.R.B.

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2009–1 through 2009–26
Notices:
99-35
Obsoleted by
Notice 2009-15, 2009-6 I.R.B.449
2001-55
Modified by
Notice 2009-1, 2009-2 I.R.B.250
2002-27
Modified by
Notice 2009-9, 2009-5 I.R.B.419
2005-74
Obsoleted by
T.D. 9446, 2009-9 I.R.B.607
2006-26
Superseded by
Notice 2009-53, 2009-25 I.R.B.1095
2007-26
Modified by
Notice 2009-15, 2009-6 I.R.B.449
2007-52
Clarified, modified, and amplified by
Notice 2009-24, 2009-16 I.R.B.817
2007-53
Clarified, modified, and ampilfied by
Notice 2009-23, 2009-16 I.R.B.802
2007-54
Obsoleted by
T.D. 9436, 2009-3 I.R.B.268
2008-11
Obsoleted by
T.D. 9436, 2009-3 I.R.B.268
2008-12
Obsoleted by
T.D. 9436, 2009-3 I.R.B.268
Rev. Proc. 2009-11, 2009-3 I.R.B.313
2008-13
Obsoleted by
T.D. 9436, 2009-3 I.R.B.268
List of forms modified and superseded by
Rev. Proc. 2009-11, 2009-3 I.R.B.313
Modified and clarified by
Notice 2009-5, 2009-3 I.R.B.309
2008-46
Obsoleted by
T.D. 9436, 2009-3 I.R.B.268
Rev. Proc. 2009-11, 2009-3 I.R.B.313
Notices— Continued:
2008-100
Amplified and superseded by
Notice 2009-14, 2009-7 I.R.B.516
2008-110
Modified by
Notice 2009-34, 2009-17 I.R.B.876
2009-31
Modified by
Notice 2009-42, 2009-20 I.R.B.1011
Proposed Regulations:
REG-144615-02
Corrected by
Ann. 2009-19, 2009-12 I.R.B.715
REG-149519-03
Withdrawn by
Ann. 2009-4, 2009-8 I.R.B.597
REG-148326-05
Corrected by
Ann. 2009-14, 2009-11 I.R.B.687
REG-158747-06
Hearing scheduled by
Ann. 2009-29, 2009-14 I.R.B.757
REG-138326-07
Hearing cancelled by
Ann. 2009-49, 2009-24 I.R.B.1092
REG-143686-07
Corrected by
Ann. 2009-40, 2009-20 I.R.B.1023
REG-119532-08
Corrected by
Ann. 2009-50, 2009-25 I.R.B.1105
REG-150066-08
Corrected by
Ann. 2009-31, 2009-15 I.R.B.798
Hearing cancelled by
Ann. 2009-36, 2009-18 I.R.B.927
Revenue Procedures:
2007-17
Superseded by
Rev. Proc. 2009-14, 2009-3 I.R.B.324
2007-66
Modified and superseded by
Rev. Proc. 2009-21, 2009-16 I.R.B.860
2007-68
Superseded by
Rev. Proc. 2009-17, 2009-7 I.R.B.517
2007-71
Modified by
Notice 2009-3, 2009-2 I.R.B.250
Revenue Procedures— Continued:
2008-1
Superseded by
Rev. Proc. 2009-1, 2009-1 I.R.B.1
2008-2
Superseded by
Rev. Proc. 2009-2, 2009-1 I.R.B.87
2008-3
Superseded by
Rev. Proc. 2009-3, 2009-1 I.R.B.107
2008-4
Superseded by
Rev. Proc. 2009-4, 2009-1 I.R.B.118
2008-5
Superseded by
Rev. Proc. 2009-5, 2009-1 I.R.B.161
2008-6
Superseded by
Rev. Proc. 2009-6, 2009-1 I.R.B.189
2008-7
Superseded by
Rev. Proc. 2009-7, 2009-1 I.R.B.226
2008-8
Superseded by
Rev. Proc. 2009-8, 2009-1 I.R.B.229
2008-9
Superseded by
Rev. Proc. 2009-9, 2009-2 I.R.B.256
2008-17
Obsoleted in part by
Rev. Proc. 2009-18, 2009-11 I.R.B.670
2008-19
Obsoleted in part by
Rev. Proc. 2009-27, 2009-19 I.R.B.938
2008-61
Superseded by
Rev. Proc. 2009-3, 2009-1 I.R.B.107
2008-65
Amplified and supplemented by
Rev. Proc. 2009-16, 2009-6 I.R.B.449
2008-66
Modified and superseded by
Rev. Proc. 2009-21, 2009-16 I.R.B.860
2008-68
Amplified and superseded by
Rev. Proc. 2009-15, 2009-4 I.R.B.356
2009-1
Amplified by
Rev. Proc. 2009-25, 2009-24 I.R.B.1088
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2008–27 through 2008–52 is in Internal Revenue Bulletin 2008–52, dated December 29,
2008.
2009–26 I.R.B.ivJune 29, 2009

Revenue Procedures— Continued:
2009-3
Amplified by
Rev. Proc. 2009-25, 2009-24 I.R.B.1088
2009-19
Modified and superseded by
Rev. Proc. 2009-26, 2009-19 I.R.B.935
Revenue Rulings:
65-286
Obsoleted by
T.D. 9435, 2009-4 I.R.B.333
71-381
Obsoleted in part by
Rev. Rul. 2009-9, 2009-14 I.R.B.735
76-54
Obsoleted by
T.D. 9435, 2009-4 I.R.B.333
92-19
Supplemented by
Rev. Rul. 2009-3, 2009-5 I.R.B.382
2008-19
Modified by
Rev. Rul. 2009-3, 2009-5 I.R.B.382
Treasury Decisions:
9394
Corrected by
Ann. 2009-42, 2009-20 I.R.B.1027
9436
Corrected by
Ann. 2009-15, 2009-11 I.R.B.687
9438
Corrected by
Ann. 2009-30, 2009-15 I.R.B.794
9439
Corrected by
Ann. 2009-12, 2009-11 I.R.B.686
9441
Corrected by
Ann. 2009-18, 2009-12 I.R.B.714
Ann. 2009-39, 2009-20 I.R.B.1022
9442
Corrected by
Ann. 2009-13, 2009-11 I.R.B.686
Ann. 2009-20, 2009-12 I.R.B.716
9446
Corrected by
Ann. 2009-23, 2009-13 I.R.B.731
Ann. 2009-45, 2009-21 I.R.B.1040
9448
Corrected by
Ann. 2009-52, 2009-25 I.R.B.1106
June 29, 2009v2009–26 I.R.B.

INDEX
Internal Revenue Bulletins 2009–1 through
2009–26
The abbreviation and number in parenthesis following the index entry
refer to the specific item; numbers in roman and italic type following
the parenthesis refers to the Internal Revenue Bulletin in which the item
may be found and the page number on which it appears.
Key to Abbreviations:
AnnAnnouncement
CDCourt Decision
DODelegation Order
EOExecutive Order
PLPublic Law
PTEProhibited Transaction Exemption
RPRevenue Procedure
RRRevenue Ruling
SPRStatement of Procedural Rules
TCTax Convention
TDTreasury Decision
TDOTreasury Department Order
EMPLOYEE PLANS
Asset valuation, funding (Notice 22) 14,741
Calculation of amount includible in income under section 409A,
correction to REG–148326–05 (Ann 14) 11,687
COBRA continuation coverage (Notice 27) 16,838
Contributions, automatic contribution arrangements (TD 9447)
12,694
Definition of “Change of control” under section 409A (Notice
49) 25,1093
Determination letters, issuing procedures (RP 6) 1,189
Full funding limitations, weighted average interest rates, seg-
ment rates for:
January 2009 (Notice 2) 4,344
February 2009 (Notice 16) 8,572
March 2009 (Notice 20) 12,711
April 2009 (Notice 39) 18,902
May 2009 (Notice 45) 22,1047
June 2009 (Notice 56) 25,1100
Interim guidance under section 457A relating to deferred com-
pensation of nonqualified entities (Notice 8) 4,347
Letter rulings:
And determination letters, areas which will not be issued
from:
Associates Chief Counsel and Division Counsel (TE/GE)
(RP 3) 1,107
Associate Chief Counsel (International) (RP 7) 1,226
And general information letters, procedures (RP 4) 1,118
User fees, request for letter rulings (RP 8) 1,229
Multiemployer plans:
Funding (Notice 31) 16,856
WRERA, funding (Notice 42) 20,1011
EMPLOYEE PLANS—Cont.
Penalties:
Categories of tax returns and claims for refund, tax return
preparer penalty under section 6694 (RP 11) 3,313
Tax return preparer (TD 9436) 3,268;correction(Ann15)11,
687
Proposed Regulations:
26 CFR 1.401(k)–0, –3, amended; 1.401(m)–0, –3, amended;
suspension or reduction of safe harbor nonelective contri-
butions (REG–115699–09) 22,1052
Prototype program, 403(b) plans, request for comments (Ann 34)
18,916
Qualified retirement plans:
Covered compensation tables, permitted disparity (RR 2) 2,
245
Required minimum distributions (RMDs) (Notice 9) 5,419
Section 403(b) plans, writtenplan requirement (Notice 3) 2,
250
Regulations:
26 CFR 1.401(k)–0 thru –3, –6, amended; 1.401(m)–0 thru
–3, amended; 1.402(c)–2, amended; 1.411(a)–4, amended;
1.414(w)–1, added; 54.4979–1, revised; automatic contri-
bution arrangements (TD 9447) 12,694
26 CFR 1.6060–1, amended; 1.6107–1, revised; 1.6109–2,
amended; 1.6694–0 thru –4, revised; 1.6695–1, –2, revised;
1.6696–1, revised; 54.6060–1, added; 54.6107–1, added;
54.6109–1, added; 54.6694–1 thru –4, added; 54.6695–1,
added; 54.6696–1, added; 54.7701–1, added; tax return pre-
parer penalties under sections 6694 and 6695 (TD 9436) 3,
268; correction (Ann 15) 11,687
Suspension or reduction of safe harbor nonelective contributions
(REG–115699–09) 22,1052
Technical advice to IRS employees (RP 5) 1,161
EMPLOYMENT TAX
COBRA continuation coverage (Notice 27) 16,838
Differential wage payments to active duty members of the uni-
formed services (RR 11) 18,896
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions (RP
1) 1,1
Penalties:
Categories of tax returns and claims for refund, tax return
preparer penalty under section 6694 (RP 11) 3,313
Tax return preparer (TD 9436) 3,268;correction(Ann15)11,
687
Postponement of certain tax-related deadlines by reason of a fed-
erally declared disaster or terroristic or military action (TD
9443) 8,564
Proposed Regulations:
26 CFR 31.3402(t)–0 thru –6, added and reserved;
31.3402(t)–7, added;31.3406(g)–2, amended;
31.6011(a)–4, amended; 31.6051–5, added; 31.6071(a)–1,
amended; 31.6302–1, –4, amended; withholding under
2009–26 I.R.B.viJune 29, 2009

EMPLOYMENT TAX—Cont.
section 3402(t) (REG–158747–06) 4,362; hearing (Ann
29) 14,757
26 CFR 31.6011(a)–1, -4, amended; 31.6302–0, –1, amended;
employer’s annual federal tax return and modifications to
the deposit rules (REG–148568–04) 5,421
Qualification to file Form 944, Employer’s ANNUAL Federal
Tax Return, or request to file Form 941, Employer’s QUAR-
TERLY Federal Tax Return (RP 13) 3,323
Regulations:
26 CFR 31.6011(a)–1, –4, amended; 31.6011(a)–1T, –4T,
revised; 31.6302–0, –1, amended; 31.6302–0T, added;
31.6302–1T, revised; employer’s annual federal tax return
and modifications to the deposit rules (TD 9440) 5,409
26 CFR 31.6060–1, added; 31.6107–1, added; 31.6109–2,
added; 31.6694–1 thru –4, added; 31.6695–1, added;
31.6696–1, added; 31.7701–1, added; tax return preparer
penalties under sections 6694 and 6695 (TD 9436) 3,268;
correction (Ann 15) 11,687
26 CFR 301.7508A–1, amended; postponement of certain
tax-related deadlines by reason of a federally declared dis-
aster or terroristic or military action (TD 9443) 8,564
Technical Advice Memoranda (TAMs) (RP 2) 1,87
Time for filing employment tax returns and modifications to de-
posit rules (TD 9440) 5,409; (REG–148568–04) 5,421
Withholding on payments by government entities for property
and services (REG–158747–06) 4,362;hearing(Ann29)14,
757
ESTATE TAX
Actuarial tables for valuing annuities, interests for life or terms
of years and remainder or reversionary interests (TD 9448) 20,
942; (REG–107845–08) 20,1014
Actuarial tables under section 7520, update (Notice 18) 10,648
Graduated retained interest (REG–119532–08) 20,1017; correc-
tion (Ann 50) 25,1105
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions (RP
1) 1,1
Penalties:
Categories of tax returns and claims for refund, tax return
preparer penalty under section 6694 (RP 11) 3,313
Tax return preparer (TD 9436) 3,268; correction (Ann 15) 11,
687
Postponement of certain tax-related deadlines by reason of a fed-
erally declared disaster or terroristic or military action (TD
9443) 8,564
Proposed Regulations:
26 CFR 20.2031–7, amended; 20.2032–1, amended;
20.2055–2, amended; 20.2056A–4, amended; 20.7520–1,
amended; use of actuarial tables for valuing annuities,
interests for life or terms of years, and remainder or rever-
sionary interests (REG–107845–08) 20,1014
26 CFR 20.2036–1, amended; grantor retained interest
(REG–119532–08) 20,1017; correction (Ann 50) 25,1105
ESTATE TAX—Cont.
Regulations:
25 CFR 20.2031–0, revised; 20.2031–7, amended;
20.2031–7A, amended; 20.2031–7T, added; 20.2032–1,
amended; 20.2032–1T, added; 20.2055–2, amended;
20.2055–2T, added; 20.2056A–4, amended; 20.2056A-4T,
added; 20.7520–1, amended; 20.7520–1T, added; actuarial
tables in valuing annuities, interests for life or terms of
years and remainder or reversionary interests (TD 9448)
20,942
26 CFR 20.6060–1, added; 20.6107–1, added; 20.6109–1,
added; 20.6694–1 thru –4, added; 20.6695–1, added;
20.6696–1, added; 20.7701–1, added; 26.6060–1, added;
26.6107–1, added; 26.6109–1, added; 26.6694–1 thru –4,
added; 26.6695–1, added; 26.6696–1, added; 26.7701–1,
added; tax return preparer penalties under sections 6694
and 6695 (TD 9436) 3,268; correction (Ann 15) 11,687
26 CFR 301.7508A–1, amended; postponement of certain
tax-related deadlines by reason of a federally declared dis-
aster or terroristic or military action (TD 9443) 8,564
Technical Advice Memoranda (TAMs) (RP 2) 1,87
EXCISE TAX
Credits:
Biodiesal and renewable diesel fuels credit, extension of the
old ASTM D6751 standard until September 30, 2009 (No-
tice 34) 17,876
Calculation of volume of denaturants in alcohol for fuel cred-
its (Notice 6) 3,311
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions (RP
1) 1,1
Mandatory electronic filing of certain excise tax returns, impo-
sition and computation of tax, credits and refunds for certain
uses and sales of vehicles (REG–116699–07) 13,727
Penalties:
Categories of tax returns and claims for refund, tax return
preparer penalty under section 6694 (RP 11) 3,313
Tax return preparer (TD 9436) 3,268;correction(Ann15)11,
687
Postponement of certain tax-related deadlines by reason of a fed-
erally declared disaster or terroristic or military action (TD
9443) 8,564
Proposed Regulations:
26 CFR 41.4481–1, –2, amended; 41.4483–3, amended;
41.4483–7, removed; 41.6001–1, –2, amended;
41.6011(a)–1, amended; 41.6071(a)–1, amended;
41.6156–1, removed; highway use tax; sold vehicles and
electronic filing (REG–116699–07) 13,727
Regulations:
26 CFR 40.6060–1, added; 40.6107–1, added; 40.6109–1,
added; 40.6694–1 thru –4, added; 40.6695–1, added;
40.6696–1, added; 40.7701–1, added; 41.6060–1,
added; 41.6107–1, added; 41.6109–2, added; 41.6694–1
thru –4, added; 41.6695–1, added; 41.6696–1, added;
June 29, 2009vii2009–26 I.R.B.

EXCISE TAX—Cont.
41.7701–1, added; 44.6060–1, added; 44.6107–1,
added; 44.6109–1, added; 44.6694–1 thru –4, added;
44.6695–1, added; 44.6696–1, added; 44.7701–1,
added; 55.6060–1, added; 55.6107–1, added; 55.6109–1,
added; 55.6694–1 thru –4, added; 55.6695–1, added;
55.6696–1, added; 55.7701–1, added; 156.6060–1, added;
156.6107–1, added; 156.6109–1, added; 156.6694–1
thru –4, added; 156.6695–1, added; 156.6696–1, added;
156.7701–1, added; 157.6060–1, added; 157.6107–1,
added; 157.6109–1, added; 157.6694–1 thru –4, added;
157.6695–1, added; 157.6696–1, added; 157.7701–1,
added; 301.7701–15, amended; tax return preparer penal-
ties under sections 6694 and 6695 (TD 9436) 3,268;
correction (Ann 15) 11,687
26 CFR 301.7508A–1, amended; postponement of certain
tax-related deadlines by reason of a federally declared dis-
aster or terroristic or military action (TD 9443) 8,564
Technical Advice Memoranda (TAMs) (RP 2) 1,87
EXEMPT ORGANIZATIONS
Academic institution initiative, comments (Ann 26) 14,755
Annual notice to donors regarding pending and settled declara-
tory judgment suits (Ann 1) 1,242
Declaratory judgment suits (Ann 33) 15,799
Division web site address, request (Ann 25) 14,755
Letter rulings:
And determination letters:
Areas which will not be issued from Associates Chief
Counsel and Division Counsel (TE/GE) (RP 3) 1,107
Exemption application determination letter rulings under
sections 501 and 521 (RP 9) 2,256
And general information letters, procedures (RP 4) 1,118
User fees, request for letter rulings (RP 8) 1,229
List of organizations classified as private foundations (Ann 9) 9,
643;(Ann22)13,731;(Ann38)19,940;(Ann48)23,1071
Penalties:
Categories of tax returns and claims for refund, tax return
preparer penalty under section 6694 (RP 11) 3,313
Tax return preparer (TD 9436) 3,268; correction (Ann 15) 11,
687
Regulations:
26 CFR 1.6060–1, amended; 1.6107–1, revised; 1.6109–2,
amended; 1.6694–0 thru –4, revised; 1.6695–1, –2, revised;
1.6696–1, revised; 53.6060–1, added; 53.6107–1, added;
53.6109–1, added; 53.6694–1 thru –4, added; 53.6695–1,
added; 53.6696–1, added; 53.7701–1, added; 56.6060–1,
added; 56.6107–1, added; 56.6109–1, added; 56.6694–1
thru –4, added; 56.6695–1, added; 56.6696–1, added;
56.7701–1, added; tax return preparer penalties under
sections 6694 and 6695 (TD 9436) 3,268; correction (Ann
15) 11,687
Revocations (Ann 3) 6,459;(Ann10)9,644; (Ann 21) 13,730;
(Ann 27) 14,756; (Ann 32) 15,799; (Ann 37) 19,940;(Ann
41) 20,1026; (Ann 47) 23,1071; (Ann 54) 26,1128
EXEMPT ORGANIZATIONS—Cont.
Suspension of tax-exempt statusof terrorist organization (Ann
17) 12,714
Technical advice to IRS employees (RP 5) 1,161
Tuition programs, modification to Notice 2001-55 (Notice 1) 2,
250
GIFT TAX
Actuarial tables for valuing annuities, interests for life or terms
of years and remainder or reversionary interests (TD 9448) 20,
942; (REG–107845–08) 20,1014
Actuarial tables under section 7520, update (Notice 18) 10,648
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions (RP
1) 1,1
Penalties:
Categories of tax returns and claims for refund, tax return
preparer penalty under section 6694 (RP 11) 3,313
Tax return preparer (TD 9436) 3,268;correction(Ann15)11,
687
Postponement of certain tax-related deadlines by reason of a fed-
erally declared disaster or terroristic or military action (TD
9443) 8,564
Proposed Regulations:
26 CFR 25.2512–5, amended; 25.2522(c)–3, amended;
25.7520–1, –3, amended; 25.2512–5A, amended;
25.2512–5T, added;25.2522–(c)–3, amended;
25.2522(c)–3T, added; 25.7520–1, amended; 25.7520–1T,
added; 25.7520–3, amended; 25.7520–3T, added; use of
actuarial tables in valuing annuities, interests for life or
terms of years, and remainder or reversionary interests
(REG–107845–08) 20,1014
Regulations:
26 CFR 25.2512–0, revised; 25.2512–5, amended; use of ac-
tuarial tables in valuing annuities, interests for life or terms
of years and remainder or reversionary interests (TD 9448)
20,942
26 CFR 25.6060–1, added; 25.6107–1, added; 25.6109–1,
added; 25.6694–1 thru –4, added; 25.6695–1, added;
25.6696–1, added; 25.7701–1, added; tax return preparer
penalties under sections 6694 and 6695 (TD 9436) 3,268;
correction (Ann 15) 11,687
26 CFR 301.7508A–1, amended; postponement of certain
tax-related deadlines by reason of a federally declared dis-
aster or terroristic or military action (TD 9443) 8,564
Technical Advice Memoranda (TAMs) (RP 2) 1,87
INCOME TAX
Actuarial tables for valuing annuities, interests for life or terms
of years, and remainder or reversionary interests (TD 9448)
20,942; corrections (Ann 52) 25,1106; (REG–107845–08)
20,1014
Actuarial tables under section 7520, update (Notice 18) 10,648
2009–26 I.R.B.viiiJune 29, 2009

INCOME TAX—Cont.
Advance Pricing Agreement (APA) Program, annual report to the
public, 2008 (Ann 28) 15,760
Allocation of consideration and allocation and recovery of
basis in transactions involving corporate stock or securities
(REG–143686–07) 8,579; correction (Ann 40) 20,1023
Anonymous tax return information, disclosure by tax return pre-
parer (Notice 13) 6,447
Annual notice to donors regarding pending and settled declara-
tory judgment suits (Ann 1) 1,242
Bonds:
Allocation of qualified school construction bond (QSCB) na-
tional limitation for 2009 (Notice 35) 17,876
Build America Bonds, Recovery Zone Economic Develop-
ment Bonds (Notice 26) 16,833
National and area median gross income figures, guidance for
2009 (RP 27) 19,938
Qualified energy conservation bonds, allocations for 2009
(Notice 29) 16,849
Qualified zone academy bond limitation (Notice 30) 16,852
Recovery zone economic development bonds, recovery zone
facility bonds (Notice 50) 26,1118
Business use of employer-provided cell phones (Notice 46) 23,
1068
Calculation of amount includible in income under section 409A,
correction to REG–148326–05 (Ann 14) 11,687
Conduit financing arrangements (REG–113462–08) 4,379
Consolidated returns, intercompany transactions (TD 9442) 6,
434; correction (Ann 13) 11,686; correction (Ann 20) 12,716
Corporations:
Creditor continuity of interest (TD 9434) 4,339
Foreign base company sales income (TD 9438) 5,387;cor-
rection(Ann30)15,794; (REG–150066–08) 5,423;cor-
rection (Ann 31) 15,798; hearing cancelled (Ann 36) 18,
927
Formless conversion of partnership to S corporation (RR 15)
21,1035
Guidance necessary to facilitate business election filing, fi-
nalization of controlled group qualification rules (TD 9451)
23,1060
Transaction of interest, controlled foreign corporation (CFC),
subpart F income partnership blocker (Notice 7) 3,312
Transfers by U.S. persons of stock or securities to foreign
corporations (TD 9446) 9,607; correction (Ann 23) 13,
731; additional corrections (Ann 45) 21,1040
Transfers of stock or securitiesto foreign corporations under
section 304 (TD 9444) 9,603; (REG–147636–08) 9,641
Treatment of stock of a controlled corporation under section
355(a)(3)(B) (TD 9435) 4,333; (REG–150670–07) 4,378
Cost of living adjustments for inflation, recent statutory changes
(RP 21) 16,860
Credits:
Alternative motor vehicle credit, phase-out (Notice 37) 18,
898
Election of the investment tax credit in lieu of the production
tax credit (Notice 52) 25,1094
INCOME TAX—Cont.
First-time homebuyer credit, allocation between unmarried
co-purchasers (Notice 12) 6,446
Low-income housing credit:
Private activity bonds (Notice 21) 13,724
Utility allowances for sub-metered low-income units (No-
tice 44) 21,1037
New clean renewable energy bonds (Notice 33) 17,865
Nonbusiness energy property credit (Notice 53) 25,1095
Nonconventional source fuel credit, inflation adjustment fac-
tor and phase-out amount for CY 2008 (Notice 32) 17,865
Qualified plug-in electric vehicle credit (Notice 54) 26,1124
Qualifying advanced coal project credit (Notice 24) 16,817
Qualifying gasification project credit (Notice 23) 16,802
Rates for tax credit bonds (Notice 15) 6,449
Renewable electricity, refinedcoal, and Indian coal produc-
tion credit, 2009 inflation adjustment (Notice 40) 19,931
Residential energy efficient property credit (Notice 41) 19,
933
Work opportunity credit, unemployed veterans and discon-
nected youth, targeted groups (Notice 28) 24,1082
Declaratory judgment suits (Ann 33) 15,799
Definition of “Change of control” under section 409A (Notice
49) 25,1093
Depreciation:
2009, limitation on depreciation deductions for passenger au-
tomobiles (RP 24) 17,885
Election to forgo additional first year depreciation deduction
(RP 16) 6,449
Disciplinary actionsinvolving attorneys,certified public accoun-
tants, enrolled agents, and enrolled actuaries (Ann 2) 5,424;
(Ann 8) 8,598; (Ann 11) 10,663; (Ann 16) 11,691; (Ann 24)
13,732; (Ann 35) 17,892; (Ann 46) 21,1040; (Ann 53) 25,
1107; (Ann 55) 26,1128
Disclosure:
Of return information to the Bureau of Economic Analysis
(TD 9439) 5,416; correction (Ann 12) 11,686
Or use of information by preparers of returns (TD 9437) 4,
341
Disguised sales, section 707, REG–149519–03 withdrawn (Ann
4) 8,597
Employer-provided vehicles, cents-per-mile valuation rule, max-
imum vehicle values, 2009 (RP 12) 3,321
FBAR filing requirements (Ann 51) 25,1105
Foreign earned income exclusion (RP 22) 16,862
Guidance priority list, recommendations for 2009–2010 (Notice
43) 21,1037
Guidance regarding treatment of certain obligations under sec-
tion 956(c) (Notice 10) 5,419
Health savings accounts (HSAs), cost of living adjustments for
inflation for 2010 (RP 29) 22,
1050
Home Affordable Modification Program (HAMP); payments
made to a REMIC (Notice 36) 17,883
Information reporting:
Deadline for brokers to furnish payee statements (Notice 11)
5,420
June 29, 2009ix2009–26 I.R.B.

INCOME TAX—Cont.
Payments made in settlement of payment card and third party
network transactions under section 6050W, request for
comments (Notice 19) 10,660
Requirements for brokers for sales and transfers of securities
and issuers of securities for corporation actions affecting
basis, request for comments (Notice 17) 8,575
Sales or exchanges of standing timber for lump-sum payments
(TD 9450) 24,1073
Insurance companies, prevailing state assumed interest rate ta-
bles, 2009 (RR 3) 5,382
Insurance contracts:
Investors who purchase life insurance contracts (RR 14) 21,
1031
Safe harbor under sections 7702 and 7702A for contracts with
a maturity age of 100, life insurance (Notice 47) 24,1083
Sale or surrender (RR 13) 21,1029
Treatment of certain employer-owned life insurance contracts
(Notice 48) 24,1085
Interest:
Investment:
Federal short-term, mid-term, and long-term rates for:
January 2009 (RR 1) 2,248
February 2009 (RR 5) 6,432
March 2009 (RR 8) 10,645
April 2009 (RR 10) 14,738
May 2009 (RR 12) 19,928
June 2009 (RR 16) 23,1058
Rates, underpayments and overpayments, quarter beginning:
April 1, 2009 (RR 7) 13,717
July 1, 2009 (RR 17) 26,1111
Interim guidance under section 457A relating to deferred com-
pensation of nonqualified entities (Notice 8) 4,347
Interim standards under section 6694(a) (Notice 5) 3,309
Letter rulings:
And determination letters, areas which will not be issued
from:
Associates Chief Counsel and Division Counsel (TE/GE)
(RP 3) 1,107
Associate Chief Counsel (International) (RP 7) 1,226
And information letters issued by Associate Offices, determi-
nation letters issued by Operating Divisions (RP 1) 1,1
Losses:
Modification to 5-year carryback of net operating losses of
small businesses (RP 26) 19,935
Net operating losses (RP 19) 14,747
Tax treatment of losses from criminally fraudulent investment
arrangements (RR 9) 14,735
Theft losses deductions from a criminally fraudulent invest-
ment arrangements (RP 20) 14,749
Modifications for mortgage loans held by certain securitization
vehicles (RP 23) 17,884
Money market fund, certain payments received from its invest-
ment advisor to maintain per share net asset value of $1.00 (RP
10) 2,267
INCOME TAX—Cont.
Mortgage insurance premiums, information reporting, deducting
prepaid premiums (TD 9449) 22,1044; (REG–107271–08) 22,
1051
Partnerships:
Conversion of partnership items with respect to tax avoidance
transactions (REG–138326–07) 9,638; hearing cancelled
(Ann 49) 24,1092
Determination of distributive share when a partner’s interest
changes (REG–144689–04) 18,906
Partner-level items in determining withholding tax, effec-
tively connected U.S. trade or business income allocated to
foreign partners, correction to TD 9394 (Ann 42) 20,1027
Penalties:
Categories of tax returns and claims for refund, tax return
preparer penalty under section 6694 (RP 11) 3,313
Tax return preparer (TD 9436) 3,268;correction(Ann15)11,
687
Postponement of certain tax-related deadlines by reason of a fed-
erally declared disaster or terroristic or military action (TD
9443) 8,564
Pre-Filing Agreement (PFA) program, extended (RP 14) 3,324
Private foundations, organizations now classified as (Ann 9) 9,
643;(Ann22)13,731;(Ann38)19,940;(Ann48)23,1071
Procedures for administrative review of a determination that an
authorized recipient has failedto safeguard tax returns or re-
turn information (TD 9445) 9,635
Proposed Regulations:
26 CFR 1.163–11, added; 1.6050H-3, added; alloca-
tion and reporting of mortgage insurance premiums
(REG–107271–08) 22,1051
26 CFR 1.170A–12, amended; 1.642(c)–6, amended;
1.664–4, amended; 1.7520–1, amended; use of actuarial ta-
bles in valuing annuities, interests for life or terms of years,
and remainder or reversionary interests (REG–107845–08)
20,1014
26 CFR 1.301–2, added; 1.302–2(c), removed; 1.302–5,
added; 1.304–1, revised; 1.304–2, –3, –5, amended;
1.351–2, amended; 1.354–1, amended; 1.355–1, amended;
1.356–1, amended; 1.358–1, –2, revised; 1.358–6,
amended; 1.368–1, amended; 1.861–12, added; 1.1002–1,
redesignated as 1.1001–6, and amended; 1.1016–2,
amended; 1.1374–10, revised; the allocation of consider-
ation and allocation and recovery of basis in transactions
involving corporate stock or securities (REG–143686–07)
8,579; correction (Ann 40) 20,1023
26 CFR 1.355–2, amended; guidance regarding the treat-
ment of stock of a controlledcorporation under section
355(a)(3)(B) (REG–150670–07) 4,378
26 CFR 1.367(a), revised; 1.482–0, –1, –2, –4, –8, amended;
1.482–7, revised; 1.482–9, added; section 482, methods to
determine taxable income in connection with a cost sharing
arrangement (CSA) (REG–144615–02) 7,561; correction
(Ann 19) 12,715
26 CFR 1.367(a)–9, added; 1.367(b)–4, amended; 1.1248–1,
amended; application of section 367 to section 351 ex-
change resulting from a transaction described in section
2009–26 I.R.B.xJune 29, 2009

INCOME TAX—Cont.
304(a)(1); treatment of gain recognized under section
301(c)(3) for purposes of section 1248 (REG–147636–08)
9,641
26 CFR 1.706–0, –2 thru –5, added; 1.706–1, amended; de-
termination of distributive share when a partner’s interest
changes (REG–144689–04) 18,906
26 CFR 1.707–0, –3, –5, thru –9, amended; 1.752–3,
amended; section 707 regarding disguised sales, generally,
REG–149519–03 withdrawn (Ann 4) 8,597
26 CFR 1.881–3, amended; conduit financing arrangements
(REG–113462–08) 4,379
26 CFR 1.954–3, amended; guidance regarding foreign base
company sales income(REG–150066–08) 5,423; correc-
tions (Ann 31) 15,798; hearing cancelled (Ann 36) 18,927
26 CFR 301.6231(c)–3, amended; 301.6231(c)–9, added; tax
avoidance transactions (REG–138326–07) 9,638; hearing
cancelled (Ann 49) 24,1092
26 CFR 301.6707–1, added; section 6707 and the failure
to furnish information regarding reportable transactions
(REG–160872–04) 4,358
Publications:
1167, General Rules and Specifications for Substitute Forms
and Schedules (RP 17) 7,517
1220, additional changes affecting tax year 2008 filing of in-
formation returns (Ann 7) 10,663
Qualified board or exchange under section 1256(g)(7)(C), Dubai
Mercantile Exchange (RR 4) 5,408
Qualified mortgage bonds (QMBs) and mortgage credit certifi-
cates (MCCs), average area housing purchase prices for 2009
(RP 18) 11,670
Regulated investment companies (RICs) and real estate invest-
ment trusts (REITs), self-determination of deficiency dividend
under section 860(e)(4) (RP 28) 20,1011
Regulations:
26 CFR 1.163–11T, added; 1.6050–3T, added; allocation and
reporting of mortgage insurance premiums (TD 9449) 22,
1044
26 CFR 1.170A–12, amended; 1.170A–12T, added; 1.642(c),
amended; 1.664–2, –4, amended; 1.664–4T, added;
1.664–4A, amended; 1.7520–1T, added; 1.7520–1,
amended; use of actuarial tables in valuaing annuities,
interests for life or terms of years and remainder or rever-
sionary interests (TD 9448) 20,942; corrections (Ann 52)
25,1106
26 CFR 1.338–1, amended; 1.367(a)–3, amended;
1.367(a)–3T, –8T, removed; 1.367(a)–8, revised; 602.101,
amended; transfers by U.S. persons of stock or securities
to foreign corporations (TD 9446) 9,607; correction (Ann
23) 13,731; additional corrections (Ann 45) 21,1040
26 CFR 1.355–0 thru –2, amended; 1.355–0T, –2T, added;
guidance regarding the treatment of stock of a controlled
corporation under section 355(a)(3)(B) (TD 9435) 4,333
26 CFR 1.367(a)–1, added; 1.367(a)–1T, amended; 1.482–0,
–0T, –1, –1T, –2T. –4T, –5, amended; 1.482–7, redes-
ignated as 1.482–7A; 1.482–7T, added, 1.482–8, –8T,
–9T, amended; 1.861–17, amended; 1.6662–6, amended;
INCOME TAX—Cont.
301.7701–1, amended; 602.101, amended; section 482,
methods to determine taxable income in connection with
a cost sharing arrangement (CSA) (TD 9441) 7,460;cor-
rection (Ann 18) 12,714; additional corrections (Ann 39)
20,1022
26 CFR 1.367(a)–(3), amended; 1.367(a)–9T, added
1.367(b)–4, amended; 1.367(b)–4T, added; 1.1248–1,
amended; 1.248–1T, added; application of section 367
to section 351 exchange resulting from a transaction de-
scribedinsection304(a)(1);treatment of gain recognized
under section 301(c)(3) for purposes of section 1248 (TD
9444) 9,603
26 CFR 1.368–1, amended; creditor continuity of interest (TD
9434) 4,339
26 CFR 1.954–3, amended; 1.954–3T, added; guidance re-
garding foreign base company sales income (TD 9438) 5,
387; corrections (Ann 30) 15,794
26 CFR 1.1446–6, amended; 1.1464–1, amended; 1.6151–1,
amended; special rules to reduce section 1446 withholding,
correction to TD 9394 (Ann 42) 20,1027
26 CFR 1.1502–13, –28, amended; consolidated returns, in-
tercompany obligations (TD 9442) 6,434; correction (Ann
13) 11,686;correction(Ann20)12,716
26 CFR 1.1563–1, added; 1.1563–1T, removed;
1.1563–3(d)(3), amended; 602.101, amended; guidance
necessary to facilitate business election filing; finalization
of controlled group qualification rules (TD 9451) 23,1060
26 CFR 1.6060–1, amended; 1.6107–1, revised; 1.6109–2,
amended; 1.6694–0 thru –4, revised; 1.6695–1, –2, re-
vised; 1.6696–1, revised; 301.7701–15, amended; 602.101,
amended; tax return preparer penalties under sections 6694
and 6695 (TD 9436) 3,268; correction (Ann 15) 11,687
26 CFR 301.6045–4, amended; information reporting for
lump-sum timber sales (TD 9450) 24,1073
26 CFR 301.6103(j)(1)–1, amended; 301.6103(j)(1)–1T, re-
moved; disclosure of return information to the Bureau of
Economic Analysis (TD 9439) 5,416; correction (Ann 12)
11,686
26 CFR 301.6103(j)(1)–1T, added; disclosure of return infor-
mation to the Bureau of Economic Analysis, correction to
TD 9439 (Ann 12) 11,686
26 CFR 301.6103(p)(4)–1, added; 301.6103(p)(4)–1T, re-
moved; 301.6103(p)(7)–1, added; 301.6103(p)(7)–1T,
removed; procedures for administrative review of a deter-
mination that an authorized recipient has failed to safeguard
tax returns or return information (TD 9445) 9,635
26 CFR 301.7216–3, amended; 301.7216–3T, removed;
amendments to the section 7216 regulations - disclosure or
use of information by preparers of returns (TD 9437) 4,341
26 CFR 301.7508A–1, amended; postponement of certain
tax-related deadlines by reason of a federally declared dis-
aster or terroristic or military action (TD 9443) 8,564
Revocations, exempt organizations (Ann 3) 6,459;(Ann10)9,
644; (Ann 21) 13,730; (Ann 27) 14,756; (Ann 32) 15,799;
(Ann 37) 19,940; (Ann 41) 20,1026; (Ann 47) 23,1071;(Ann
54) 26,1128
June 29, 2009xi2009–26 I.R.B.

INCOME TAX—Cont.
Section 355, letter rulings (RP 25) 24,1088
Section 382:
Emergency Economic Stabilization Act of 2008 (EESA), ad-
ditional guidance (Notice 38) 18,901
Limitation, ownership changes, pre-change losses (Notice 14)
7,516
Section 482, methods to determine taxable income in connection
with a cost sharing arrangement (CSA) (TD 9441) 7,460;cor-
rection (Ann 18) 12,714; additional corrections (Ann 39) 20,
1022; (REG–144615–02) 7,561;correction(Ann19)12,715
Section 6707 and the failure to furnish information regarding re-
portable transactions (REG–160872–04) 4,358
Standard Industry Fare Level (SIFL) formula (RR 6) 12,694
Stocks:
Section 305 REIT distributions of stock (RP 15) 4,356
Treatment of stock of a controlled corporation under section
355(a)(3)(B) (TD 9435) 4,333; (REG–150670–07) 4,378
Substitute forms and schedules, general rules and specifications
(RP 17) 7,517
Tax conventions:
Arbitration Board guidelinesunder the United States–Bel-
gium Income Tax Treaty (Ann 44) 24,1079
Memorandum of Understanding Between the United States
and the Kingdom of Belgium (Ann 43) 24,1075
Publication 515, Withholding of Tax on Nonresident Aliens
and Foreign Entities (For Withholding in 2008), and Publi-
cation 901, U.S. Tax Treaties (Rev. April 2008), changes in
tables 1 and 2 for Bulgaria, Canada, and Iceland (Ann 5) 8,
569
Taxpayer identification number (TIN), matching program and
new section 6050W (Ann 6) 9,643
Technical Advice Memoranda (TAMs) (RP 2) 1,87
Transferred basis, reorganization acquisition (Notice 4) 2,251
Update to Publication 1220, additional changes affecting tax year
2008 filing of information returns (Ann 7) 10,663
Uniform capitalization regulations under section 263A, property
acquired for resale, request for public comments (Notice 25)
15,758
SELF-EMPLOYMENT TAX
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions (RP
1) 1,1
Technical Advice Memoranda (TAMs) (RP 2) 1,87
2009–26 I.R.B.xiiJune 29, 2009

June 29, 20092009–26 I.R.B.

2009–26 I.R.B.June 29, 2009

June 29, 20092009–26 I.R.B.

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