us-irs-revenue-rulings-irb-2015-22-pdf•Internal Revenue Bulletin 2015-22 (PDF rendition): IRS Revenue Rulings
Internal Revenue Bulletin 2015-22 (PDF rendition): IRS Revenue Rulings
us-irs-revenue-rulings-irb-2015-22-pdfInternal Revenue Bulletin 2015-22 (PDF rendition): IRS Revenue RulingsGuidance
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HIGHLIGHTS OF THIS ISSUE These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations. INCOME TAX Rev. Rul. 2015–14, page 1012. Federal rates; adjusted federal rates; adjusted federal long- term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for June 2015. Announcement 2015–15, page 1014. The Office of Professional Responsibility (OPR) announces re- cent disciplinary sanctions involving attorneys, certified public accountants, enrolled agents, enrolled actuaries, enrolled re- tirement plan agents, and appraisers. These individuals are subject to the regulations governing practice before the Inter- nal Revenue Service (IRS), which are set out in Title 31, Code of Federal Regulations, Part 10, and which are published in pamphlet form as Treasury Department Circular No. 230. The regulations prescribe the duties and restrictions relating to such practice and prescribe the disciplinary sanctions for vio- lating the regulations. EMPLOYEE PLANS Notice 2015–39, page 1008. This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for May 2015 used under § 417(e)(3)(D), the 24-month average seg- ment rates applicable for May 2015, and the 30-year Treasury rates. These rates reflect the application of § 430(h)(2)(C)(iv), which was added by the Moving Ahead for Progress in the 21st Century Act, Public Law 112–141 (MAP–21) and amended by section 2003 of the Highway and Transportation Funding Act of 2014 (HATFA). ADMINISTRATIVE Rev. Rul. 2015–13, page 1011. This Revenue Ruling provides guidances needed to update RR90–5 dealing with Sat., Sun., and Holiday rules for filing. Finding Lists begin on page ii. Bulletin No. 2015–22 June 1, 2015 The IRS Mission Provide America’s taxpayers top-quality service by helping them understand and meet their tax responsibilities and en- force the law with integrity and fairness to all. Introduction The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conven- tions, legislation, court decisions, and other items of general interest. It is published weekly. It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless other- wise indicated. Procedures relating solely to matters of internal management are not published; however, statements of inter- nal 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, identify- ing details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements. Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and procedures must be considered, and Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same. The Bulletin is divided into four parts as follows: Part I.—1986 Code. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1986. Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions and Other Related Items, and Subpart B, Legisla- tion 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 Sec- retary (Enforcement). Part IV.—Items of General Interest. This part includes notices of proposed rulemakings, disbar- ment and suspension lists, and announcements. The last Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the last Bulletin of each semiannual period. The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate. June 1, 2015Bulletin No. 2015–22 Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 Section 42.—Low-Income Housing Credit The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of June 2015. See Rev. Rul. 2015–14, page 1012. Section 280G.—Golden Parachute Payments Federal short-term, mid-term, and long-term rates are set forth for the month of June 2015. See Rev. Rul. 2015–14, page 1012. Section 382.—Limitation on Net Operating Loss Carryforwards and Certain Built-In Losses Following Ownership Change The adjusted applicable federal long-term rate is set forth for the month of June 2015. See Rev. Rul. 2015–14, page 1012. Section 412.—Minimum Funding Standards The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of June 2015. See Rev. Rul. 2015–14, page 1012. Section 467.—Certain Payments for the Use of Property or Services The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of June 2015. See Rev. Rul. 2015–14, page 1012. Section 468.—Special Rules for Mining and Solid Waste Reclamation and Closing Costs The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of June 2015. See Rev. Rul. 2015–14, page 1012. Section 482.—Allocation of Income and Deductions Among Taxpayers Federal short-term, mid-term, and long-term rates are set forth for the month of June 2015. See Rev. Rul. 2015–14, page 1012. Section 483.—Interest on Certain Deferred Payments The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of June 2015. See Rev. Rul. 2015–14, page 1012. Section 642.—Special Rules for Credits and Deductions Federal short-term, mid-term, and long-term rates are set forth for the month of June 2015. See Rev. Rul. 2015–14, page 1012. Section 807.—Rules for Certain Reserves The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of June 2015. See Rev. Rul. 2015–14, page 1012. Section 846.—Discounted Unpaid Losses Defined The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of June 2015. See Rev. Rul. 2015–14, page 1012. Section 1288.—Treatment of Original Issue Discount on Tax-Exempt Obligations The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of June 2015. See Rev. Rul. 2015–14, page 1012. Section 7520.—Valuation Tables The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of June 2015. See Rev. Rul. 2015–14, page 1012. Section 7872.—Treatment of Loans With Below- Market Interest Rates The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of June 2015. See Rev. Rul. 2015–14, page 1012. Bulletin No. 2015–22June 1, 2015 1007 Part III. Administrative, Procedural, and Miscellaneous Weighted Average Interest Rates Updates Notice 2015–39 This notice provides guidance on the corporate bond monthly yield curve, the corresponding spot segment rates used un- der § 417(e)(3), and the 24-month average segment rates under § 430(h)(2) of the Internal Revenue Code. In addition, this notice provides guidance as to the interest rate on 30-year Treasury securities under § 417(e)(3)(A)(ii)(II) as in effect for plan years beginning before 2008 and the 30- year Treasury weighted average rate under § 431(c)(6)(E)(ii)(I). The rates in this notice reflect the application of § 430(h)(2)(C)(iv), which was added by the Moving Ahead for Progress in the 21st Century Act, Pub- lic Law 112–141 (MAP–21) and amended by section 2003 of the Highway and Transportation Funding Act of 2014, Pub- lic Law 113–159 (HATFA). YIELD CURVE AND SEGMENT RATES Generally, except for certain plans un- der sections 104 and 105 of the Pension Protection Act of 2006 and CSEC plans under § 414(y), § 430 of the Code speci- fies the minimum funding requirements that apply to single-employer plans pursu- ant to § 412. Section 430(h)(2) specifies the interest rates that must be used to determine a plan’s target normal cost and funding target. Under this provision, pres- ent value is generally determined using three 24-month average interest rates (“segment rates”), each of which applies to cash flows during specified periods. To the extent provided under § 430(h)(2)(C)(iv), these segment rates are adjusted by the applicable percentage of the 25-year aver- age segment rates for the period ending September 30 of the year preceding the calendar year in which the plan year be- gins. However, an election may be made under § 430(h)(2)(D)(ii) to use the monthly yield curve in place of the seg- ment rates. Notice 2007– 81, 2007– 44 I.R.B. 899, provides guidelines for determining the monthly corporate bond yield curve, and the 24-month average corporate bond seg- ment rates used to compute the target nor- mal cost and the funding target. Consis- tent with the methodology specified in Notice 2007– 81, the monthly corporate bond yield curve derived from April 2015 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of April 2015 are, respectively, 1.27, 3.52, and 4.47. The 24-month average segment rates de- termined under § 430(h)(2)(C)(i)through (iii) must be adjusted pursuant to § 430(h)(2)(C)(iv) by the applicable per- centage of the corresponding 25-year av- erage segment rates. Section 2003(a) of HATFA amended the applicable percent- ages under § 430(h)(2)(C)(iv). This change generally applies to plan years be- ginning on or after January 1, 2013. How- ever, pursuant to section 2003(e)(2) of HATFA, a plan sponsor can elect not to have the amendments made to the appli- cable percentages by section 2003 of HATFA apply to any plan year beginning in 2013. These elections can be made ei- ther for all purposes or, alternatively, for purposes of determining the adjusted funding target attainment percentage un- der § 436. The 25-year average segment rates for plan years beginning in 2012, 2013, 2014 and 2015 were published in Notice 2012–55, 2012–36 I.R.B. 332, No- tice 2013–11, 2013–11 I.R.B. 610, Notice 2013–58, 2013– 40 I.R.B. 294, and Notice 2014 –50, 2014 – 40 I.R.B. 590, respec- tively. For plan years beginning in years 2012 through 2017, pursuant to the changes made by HATFA, the applicable mini- mum percentage is 90% and the applica- ble maximum percentage is 110%. These applicable percentages are referred to as HATFA applicable percentages. As de- scribed in the preceding paragraph, a spe- cial election is available for any plan year beginning in 2013 under which this change made by HATFA can be disre- garded for all purposes or for limited pur- poses. To the extent such an election is made, the applicable minimum percentage for a plan year beginning in 2013 is 85% and the applicable maximum percentage for that plan year is 115%. These applica- ble percentages are referred to as MAP–21 applicable percentages. 24-MONTH AVERAGE CORPORATE BOND SEGMENT RATES The three 24-month average corporate bond segment rates applicable for May 2015 without adjustment for the 25-year average segment rate limits are as follows: Applicable Month First Segment Second Segment Third Segment May 20151.284.075.11 Basedon§430(h)(2)(C)(iv)as amended by section 2003 of HATFA, the 24-month averages applicable for May 2015 adjusted for the HATFA applicable percentages of the corresponding 25-year average segment rates, are as follows: June 1, 2015Bulletin No. 2015–22 1008 For Plan Years Beginning In Adjusted 24-Month Average Segment Rates, Based on the HATFA Applicable Percentage of 25-Year Average Rates Applicable Month First Segment Second Segment Third Segment 2014May20154.996.326.99 2015May20154.726.116.81 30-YEAR TREASURY SECURITIES INTEREST RATES Generally for plan years beginning after 2007, § 431 specifies the minimum funding requirements that apply to multiemployer planspursuantto§412.Section 431(c)(6)(B) specifies a minimum amount for the full-funding limitation described in § 431(c)(6)(A),based on the plan’s current liability. Section 431(c)(6)(E)(ii)(I) pro- vides that the interest rate used to calcu- late current liability for this purpose must be no more than 5 percent above and no more than 10 percent below the weighted average of the rates of interest on 30-year Treasury securities during the four-year period ending on the last day before the beginning of the plan year. Notice 88 –73, 1988 –2 C.B. 383, provides guidelines for determining the weighted average interest rate. The rate of interest on 30-year Trea- sury securities for April 2015 is 2.59 per- cent. The Service determined this rate as the average of the daily determinations of yield on the 30-year Treasury bond ma- turing in February 2045. For plan years beginning in the month shown below, the weighted average of the rates of interest on 30-year Treasury securities and the permissible range of rate used to calculate current liability are as follows: For Plan Years Beginning in 30-Year Treasury Weighted Average Permissible Range MonthYear90%to105% May20153.212.893.37 MINIMUM PRESENT VALUE SEGMENT RATES In general, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month average. Notice 2007– 81 provides guide- lines for determining the minimum pres- ent value segment rates. Pursuant to that notice, the minimum present value seg- ment rates determined for April 2015 are as follows: First Segment Second Segment Third Segment 1.273.524.47 DRAFTING INFORMATION The principal author of this notice is Tom Morgan of the Office of the Associ- ate Chief Counsel (Tax Exempt and Gov- ernment Entities). However, other person- nel from the IRS participated in the development of this guidance. For further information regarding this notice, contact Mr. Morgan at 202-317-8719 or Tony Montanaro at 202-317-8698 (not a toll- free number). Bulletin No. 2015–22June 1, 2015 1009 Table I Monthly Yield Curve for April 2015 Derived from April 2015 Data MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield 0.50.3020.54.1940.54.5060.54.6180.54.66 1.00.5821.04.2141.04.5061.04.6181.04.66 1.50.8421.54.2241.54.5161.54.6181.54.66 2.01.0722.04.2342.04.5162.04.6182.04.66 2.51.2622.54.2542.54.5162.54.6182.54.67 3.01.4323.04.2643.04.5263.04.6283.04.67 3.51.5823.54.2743.54.5263.54.6283.54.67 4.01.7224.04.2844.04.5264.04.6284.04.67 4.51.8624.54.2944.54.5364.54.6284.54.67 5.02.0125.04.3045.04.5365.04.6285.04.67 5.52.1525.54.3145.54.5365.54.6285.54.67 6.02.3026.04.3246.04.5466.04.6386.04.67 6.52.4426.54.3346.54.5466.54.6386.54.67 7.02.5827.04.3447.04.5467.04.6387.04.67 7.52.7227.54.3447.54.5567.54.6387.54.67 8.02.8528.04.3548.04.5568.04.6388.04.68 8.52.9728.54.3648.54.5568.54.6388.54.68 9.03.0929.04.3749.04.5669.04.6389.04.68 9.53.2029.54.3849.54.5669.54.6489.54.68 10.03.3030.04.3850.04.5670.04.6490.04.68 10.53.3930.54.3950.54.5670.54.6490.54.68 11.03.4831.04.4051.04.5771.04.6491.04.68 11.53.5631.54.4051.54.5771.54.6491.54.68 12.03.6332.04.4152.04.5772.04.6492.04.68 12.53.7032.54.4252.54.5772.54.6492.54.68 13.03.7633.04.4253.04.5873.04.6493.04.68 13.53.8133.54.4353.54.5873.54.6593.54.68 14.03.8634.04.4454.04.5874.04.6594.04.69 14.53.9034.54.4454.54.5874.54.6594.54.69 15.03.9435.04.4555.04.5975.04.6595.04.69 15.53.9835.54.4555.54.5975.54.6595.54.69 16.04.0136.04.4656.04.5976.04.6596.04.69 16.54.0436.54.4656.54.5976.54.6596.54.69 17.04.0637.04.4757.04.5977.04.6597.04.69 17.54.0937.54.4757.54.6077.54.6697.54.69 18.04.1138.04.4858.04.6078.04.6698.04.69 18.54.1338.54.4858.54.6078.54.6698.54.69 19.04.1539.04.4959.04.6079.04.6699.04.69 19.54.1639.54.4959.54.6079.54.6699.54.69 20.04.1840.04.4960.04.6180.04.66100.04.69 June 1, 2015Bulletin No. 2015–22 1010 Section 7503.—Time for the Performance of Acts Where Last Day Falls on Saturday, Sunday, or Legal Holiday 26 CFR 301.7503–1(b): Time for Performance of Acts Where Last Day Falls on Saturday, Sunday, or Legal Holiday. (Also: Secs. 6072, 6151, 6654, 301.6091–2, Notice 2011–17) Rev. Rul. 2015–13 ISSUE Under the facts described below, by what date must the specified act be per- formed if the due date for A’s income tax return and estimated tax payment falls on a Saturday, Sunday, or legal holiday? FACTS A, an individual who is a resident of Massachusetts, files A’s federal income tax return on a calendar year basis. As an indi- vidual resident of Massachusetts, A is re- quired by Internal Revenue Service (IRS) forms and instructions to file A’s return at the Kansas City, MO, Internal Revenue Ser- vice Campus. A also makes installment pay- ments of estimated income tax for the cal- endar year. As a resident of Massachusetts, A is required by IRS forms and instructions to send A’s estimated income tax payments to Hartford, CT. In this situation, April 15 falls on the third Friday in April. Emancipation Day, April 16, is a legal holiday in the District of Columbia. The following Monday, April 18, is Patriots’ Day, a legal holiday in Massachusetts and Maine but not in any other state. LAW AND ANALYSIS Section 6151(a) of the Internal Revenue Code (Code) provides that when a return of tax is required, the person required to make the return shall pay the tax at the time and place fixed for filing the return. Section 6072(a) of the Code provides that individual income tax returns made on the basis of the calendar year shall be filed on or before the 15th day of April following the close of the calendar year. Section 6654(c) of the Code provides that the due date for the first required installment payment of estimated income tax is April 15. Section 7503 of the Code provides that, when April 15 falls on a Saturday, Sunday, or legal holiday, a return is considered timely filed if it is filed on the next succeed- ing day that is not a Saturday, Sunday, or legal holiday. The term “legal holiday” in- cludes a legal holiday observed in the Dis- trict of Columbia. A tax calendar that lists the legal holidays is annually made avail- able through IRS Publication 509. Emanci- pation Day, April 16, is a legal holiday in the District of Columbia.D.C. Code § 28 – 2701 (2010). When April 16 is a Saturday, the preceding day is the observed holiday, and when it is a Sunday, the succeeding day is the observed holiday.Id. Section 7503 also provides that, in the case of any return required to be filed at any office of the Secretary, or at any other office of the United States or any agency thereof, located outside the District of Co- lumbia but within an IRS district, the term “legal holiday” includes a statewide legal holiday in the state where the office is located. Patriots’ Day, the third Monday in April, is a statewide legal holiday in Massachusetts and Maine.Mass. Ann. Laws. ch. 4, § 7(18) (Law. Coop. 1988); Me. Rev. Stat. Ann. tit. 4, § 1051 (1988). Treasury Regulation § 1.6091–2(c) provides that “whenever instructions ap- plicable to income tax returns provide that the returns be filed with a service center, the returns must be so filed . . .” Individ- uals who make their income tax returns on a calendar year basis generally must file their returns at the IRS service center (now known as campuses) designated in the applicable instructions. However, Treasury Regulation § 1.6091–2(d)(1) provides that, notwithstanding Treasury Regulation § 1.6091–2(c), income tax re- turns of persons other than corporations that are hand carried shall be filed with any individual assigned the responsibility to receive such returns in the local IRS office serving the legal residence or prin- cipal place of business of the person re- quired to make the return. Revenue Ruling 90 –5 addressed the due date for filing income tax returns and paying the first installment of estimated income tax for individuals who were re- quired to file their returns at the Andover, Massachusetts Service Center, including residents from Massachusetts and Con- necticut. However, the IRS no longer re- quires taxpayers to file returns at the In- ternal Revenue Center in Andover, Massachusetts. Section 7503 of the Code extends the time for performing an act required by the internal revenue laws when the last day for performing the act would be a Saturday, Sunday, or legal holiday. Pursuant to Trea- sury Regulation § 1.6091–2(d)(1), individu- als who reside in Massachusetts and Maine may elect to file their returns by hand at their local IRS Office located in Massachu- setts or Maine. When the last day for resi- dents of those states to file their returns by hand falls on a Saturday, Sunday or legal holiday, section 7503 extends the due date to the next succeeding day which is not a Saturday, Sunday or legal holiday. We in- terpret this rule to extend the due date for filing income tax returns for all residents of Massachusetts and Maine pursuant to sec- tion 7503, including those who do not elect to file by hand. Accordingly, the statewide observance of Patriots’ Day in Massachu- setts or Maine affects the due date for in- come tax returns of individuals who reside in Massachusetts and Maine, but it does not affect the due date of income tax returns for individuals who do not reside in Massachu- setts or Maine. Revenue Ruling 90 –5 addresses the due date for filing income tax returns and paying the first installment of estimated income tax where April 15 falls on a Sat- urday, Sunday, or legal holiday. Revenue Ruling 90 –5 applies to individuals who are required to file their returns at the Andover, Massachusetts Service Center, including residents from Massachusetts and Connecticut, and who are required to send their estimated income tax payments to a depository in Pittsburgh, Pennsylva- nia. Revenue Ruling 90 –5 concludes that residents of Massachusetts and Connecti- cut receive the benefit of the Massachu- setts state holiday since their federal in- come tax returns may be filed in Andover, Massachusetts. The estimated tax pay- ments on the other hand, required to be sent to Pittsburgh, Pennsylvania, a state that does not observe Patriots’ Day, are due on April 15, notwithstanding this was a statewide holiday in Massachusetts. Notice 2002–12 addressed the filing requirements for individual taxpayers Bulletin No. 2015–22June 1, 2015 1011 from several states who were filing their income tax returns in Massachusetts in a year when Patriots’ Day fell on April 15. Notice 2002–12 provides: “for filing sea- son 2002 (tax year 2001) individual in- come taxpayers in Massachusetts, Michi- gan, New York (all counties except for Nassau, Rockland, Suffolk, Westchester, and New York City), Rhode Island, and Maine have until Tuesday, April 16, 2002, to file their Federal income tax returns and make their payments. This includes the payment of the first installment of esti- mated tax for 2002.” Notice 2011–17 describes the impact of Emancipation Day on the filing dead- line for certain tax forms and payments. Specifically, it provides that Emancipa- tion Day, an official public holiday in the District of Columbia, is a legal holiday described in section 7503. Previously, there was no guidance cov- ering the impact that both Emancipation Day and Patriot’s Day could have on the time for filing an individual income tax return or making an estimated payment of tax when the due date for the income tax return and estimated tax payment falls on a Saturday, Sunday, or legal holiday. HOLDING The District of Columbia observes Emancipation Day on Friday, April 15 when April 16 is a Saturday. This makes Monday, April 18, the ordinary due date for filing income tax returns. However, in this situation, Monday, April 18, is the third Monday in April, the date that Mas- sachusetts and Maine observe Patriots’ Day. Because residents of Massachusetts and Maine may elect to hand carry their income tax returns to their local IRS of- fices, A has until the next succeeding day that is not a Saturday, Sunday, or legal holiday to file A’s income tax return. Thus, A has until Tuesday, April 19, to file A’s income tax return. A is required to make installment pay- ments of estimated income tax to a deposi- tory in Hartford, Connecticut, a state in which the third Monday in April is not a statewide legal holiday. Accordingly, A must make the first installment payment of estimated tax on or before the ordinary due date for income tax returns for the act to be timely. The fact that A is a resident of Mas- sachusetts, a state in which the third Mon- day in April is a statewide legal holiday, has no effect on A’s due date for payment of A’s first installment of estimated tax. Thus, A must pay A’s first installment of esti- mated income tax on or before April 18. EFFECT ON OTHER PUBLISHED GUIDANCE Revenue Ruling 90 –5, 1990 –1 C.B. 189 is clarified and superseded. Notice 2002–12, 2002–1 C.B. 526 is clarified and superseded. Notice 2011–17, 2011–10 I.R.B. 540 is clarified and amplified. DRAFTING INFORMATION The principal author of this revenue rul- ing is Michael A. Franklin of the Office of Associate Chief Counsel (Procedure & Ad- ministration). For further information re- garding this revenue ruling, contact Mr. Franklin at (202) 317-6833 (not a toll-free number). Section 1274.— Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also Sections 42, 280G, 382, 412, 467, 468, 482, 483, 642, 807, 846, 1288, 7520, 7872.) Rev. Rul. 2015–14 This revenue ruling provides various pre- scribed rates for federal income tax pur- poses for June 2015 (the current month). Table 1 contains the short-term, mid-term, and long-term applicable federal rates (AFR) for the current month for purposes of section 1274(d) of the Internal Revenue Code. Table 2 contains the short-term, mid- term, and long-term adjusted applicable fed- eral rates (adjusted AFR) for the current month for purposes of section 1288(b). Ta- ble 3 sets forth the adjusted federal long- term rate and the long-term tax-exempt rate described in section 382(f). Table 4 contains the appropriate percentages for determining the low-income housing credit described in section 42(b)(1) for buildings placed in ser- vice during the current month. However, under section 42(b)(2), the applicable per- centage for non-federally subsidized new buildings placed in service after July 30, 2008, with respect to housing credit dollar amount allocations made before January 1, 2015 shall not be less than 9%. Finally- ,Table 5 contains the federal rate for deter- mining the present value of an annuity, an interest for life or for a term of years, or a remainder or a reversionary interest for pur- poses of section 7520. REV. RUL. 2015–14 TABLE 1 Applicable Federal Rates (AFR) for June 2015 Period for Compounding AnnualSemiannualQuarterlyMonthly Short-term AFR.43%.43%.43%.43% 110% AFR.47%.47%.47%.47% 120% AFR.52%.52%.52%.52% 130% AFR.56%.56%.56%.56% Table 1 is continued on the following page 1013 June 1, 2015Bulletin No. 2015–22 1012 REV. RUL. 2015–14 TABLE 1 Applicable Federal Rates (AFR) for June 2015 Period for Compounding AnnualSemiannualQuarterlyMonthly Mid-term AFR1.60%1.59%1.59%1.58% 110% AFR1.76%1.75%1.75%1.74% 120% AFR1.92%1.91%1.91%1.90% 130% AFR2.08%2.07%2.06%2.06% 150% AFR2.40%2.39%2.38%2.38% 175% AFR2.80%2.78%2.77%2.76% Long-term AFR2.50%2.48%2.47%2.47% 110% AFR2.75%2.73%2.72%2.71% 120% AFR3.00%2.98%2.97%2.96% 130% AFR3.25%3.22%3.21%3.20% REV. RUL. 2015–14 TABLE 2 Adjusted AFR for June 2015 Period for Compounding AnnualSemiannualQuarterlyMonthly Short-term adjusted AFR.43%.43%.43%.43% Mid-term adjusted AFR1.52%1.51%1.51%1.51% Long-term adjusted AFR2.50%2.48%2.47%2.47% REV. RUL. 2015–4 TABLE 3 Rates Under Section 382 for June 2015 Adjusted federal long-term rate for the current month2.50% Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal long-term rates for the current month and the prior two months.) 2.50% REV. RUL. 2015–14 TABLE 4 Appropriate Percentages Under Section 42(b)(1) for June 2015 Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July 30, 2008, with respect to housing credit dollar amount allocations made before January 1, 2015, shall not be less than 9%. Appropriate percentage for the 70% present value low-income housing credit7.47% Appropriate percentage for the 30% present value low-income housing credit3.20% REV. RUL. 2015–14 TABLE 5 Rate Under Section 7520 for June 2015 Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years, or a remainder or reversionary interest 2.0% Bulletin No. 2015–22June 1, 2015 1013 Part IV. Items of General Interest Announcement of Disciplinary Sanctions From the Office of Professional Responsibility Announcement 2015–15 The Office of Professional Responsi- bility (OPR) announces recent disciplin- ary sanctions involving attorneys, certi- fied public accountants, enrolled agents, enrolled actuaries, enrolled retirement plan agents, and appraisers. These indi- viduals are subject to the regulations gov- erning practice before the Internal Reve- nue Service (IRS), which are set out in Title 31, Code of Federal Regulations, Part 10, and which are published in pam- phlet form as Treasury Department Circu- lar 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 practice before the IRS as defined at 31 C.F.R. § 10.2(a)(4). Suspended from practice before the IRS—An individual who is suspended is not eligible to practice before the IRS as defined at 31 C.F.R. § 10.2(a)(4) during the term of the suspension. Censured in practice before the IRS—Censure is a public reprimand. Un- like disbarment or suspension, censure does not affect an individual’s eligibility to practice before the IRS, but OPR may subject the individual’s future practice rights to conditions designed to promote high standards of conduct. Monetary penalty—A monetary pen- alty may be imposed on an individual who engages in conduct subject to sanction or on an employer, firm, or entity if the in- dividual 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, certi- fied public accountants, enrolled agents, en- rolled 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, Suspended by decision, Censured by decision, Mone- tary penalty imposed, and Disqualified after hearing—An administrative law judge (ALJ) either 1) granted the govern- ment’s summary judgment motion or 2) conducted an evidentiary hearing upon OPR’s complaint alleging violation of the regulations; and 3) issued a decision im- posing one of these sanctions. After 30 days from the issuance of the decision, in the absence of an appeal, the ALJ’s deci- sion became the final agency decision. Disbarred by default decision, Sus- pended by default decision, Censured by default decision, Monetary penalty imposed by default decision, and Dis- qualified 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 imposing one of these sanc- tions. Disbarment by decision on appeal, Suspended by decision on appeal, Cen- sured by decision on appeal, Monetary penalty imposed by decision on appeal, and Disqualified by decision on ap- peal—The decision of the ALJ was ap- pealed to the agency appeal authority, act- ing as the delegate of the Secretary of the Treasury, and the appeal authority issued a decision imposing one of these sanc- tions. Disbarred by consent, Suspended by consent, Censured by consent, Mone- tary penalty imposed by consent, and Disqualified by consent—In lieu of a dis- ciplinary proceeding being instituted or continued, an individual offered a consent to one of these sanctions and OPR ac- cepted the offer. Typically, an offer of consent will provide for: suspension for an indefinite term; conditions that the in- dividual must observe during the suspen- sion; and the individual’s opportunity, af- ter a stated number of months, to file with OPR a petition for reinstatement affirming compliance with the terms of the consent and affirming current eligibility to prac- tice (i.e., an active professional license or active enrollment status). Suspended indefinitely by decision in expedited proceeding, Suspended indef- initely by default decision in expedited proceeding, Suspended by consent in expedited proceeding—OPR instituted an expedited proceeding for suspension (based on certain limited grounds, includ- ing loss of a professional license for cause, and criminal convictions). 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 the effective date of amendments to the regulations that permit making such decisions publicly available; (2) the indi- vidual has settled a disciplinary case by signing OPR’s “consent to sanction” form, which requires consenting individ- uals to admit to one or more violations of the regulations and to consent to the dis- closure of the individual’s own return in- formation related to the admitted viola- tions (for example, failure to file Federal income tax returns); or (3) OPR has issued a decision in an expedited proceeding for indefinite 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. June 1, 2015Bulletin No. 2015–22 1014 City & StateName Professional Designation Disciplinary SanctionEffective Date(s) Arizona AnthemDoherty, Brian G.AttorneySuspended by decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from February 11, 2015 California San JoseBoitano, Steven F.CPASuspended by decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from February 5, 2015 Palm DesertLevine, Marc R.AttorneySuspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from March 5, 2015 Los AngelesLavu, HermanCPASuspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from November 17, 2014 Lake ElsinoreProspero, Raymond C. AttorneySuspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from March 5, 2015 Florida MiamiTodd, Mayumi O.CPAReinstated to practice before the IRS February 14, 2014 Illinois ChicagoGreene, James P.AttorneySuspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from March 11, 2015 Vernon HillsTravis, Jeffrey B.CPASuspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from February 19, 2015 Louisiana Bossier CityPhillips, II, Charles T. AttorneySuspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from February 2, 2015 Maryland LisbonDewan, Kiran M.AttorneySuspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from February 5, 2015 Massachusetts Doherty, Brian G., see Arizona Minnesota Vadnais Heights Holt, Mark D.AttorneySuspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from January 15, 2015 WalkerSmith, Victor H.AttorneySuspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from January 15, 2015 New Jersey CliftonVan Siclen, Todd D.AttorneySuspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from March 26, 2015 New York BrooklynBronstein, DianaAttorneySuspended by decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from March 12, 2015 New YorkPolidi, RichardAttorneySuspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from February 3, 2015 Van Siclen, Todd D., see New Jersey Bulletin No. 2015–22June 1, 2015 1015 City & StateName Professional Designation Disciplinary SanctionEffective Date(s) North Carolina RaleighGlenn, Lori M.AttorneySuspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from January 15, 2015 RaleighGray, Robert M.CPASuspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from October 8, 2014 Polidi, Richard, see New Jersey CharlotteWidis, Larry E.CPASuspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from January 15, 2015 Ohio MarysvilleDenoewer, Michael F. CPASuspended by decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from February 5, 2015 Pennsylvania DoylestownLoStracco, MichaelCPASuspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from February 5, 2015 Tennessee HohenwaldHinson, Jeffrey L.Enrolled Agent Suspended by decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from March 11, 2015 MemphisJohnson, David J.AttorneySuspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from March 5, 2015 Texas HoustonMcClain, James L.CPADisbarred by consent under 31 C.F.R. §§ 10.51(a)(6), 10.51(a)(17), and § 10.22 Indefinite from February 6, 2015 Virginia Dewan, Kiran M., see Maryland MechanicsvilleHoare, David J.CPASuspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from March 3, 2015 BerryvilleSoonthornchal, Boonlomp CPASuspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from March 3, 2015 West Virginia ParkersburgPostlewait, Jr., Philip R. CPASuspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b) Indefinite from February 19, 2015 June 1, 2015Bulletin No. 2015–22 1016 Definition of Terms Revenue rulings and revenue procedures (hereinafter referred to as “rulings”) that have an effect on previous rulings use the following defined terms to describe the effect: Amplifieddescribes a situation where no change is being made in a prior pub- lished position, but the prior position is being extended to apply to a variation of the fact situation set forth therein. Thus, if an earlier ruling held that a principle ap- plied to A, and the new ruling holds that the same principle also applies to B, the earlier ruling is amplified. (Compare with modified, below). Clarifiedis used in those instances where the language in a prior ruling is being made clear because the language has caused, or may cause, some confu- sion. 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 with amplified andclarified, 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 being stated in a new ruling. Supersededdescribes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings). Thus, the term is used to republish under the 1986 Code and regulations the same position published under the 1939 Code and regulations. The term is also used when it is desired to republish in a single ruling a series of situations, names, etc., that were previously published over a pe- riod of time in separate rulings. If the new ruling does more than restate the sub- stance of a prior ruling, a combination of terms is used. For example, modified and supersededdescribes a situation where the substance of a previously published ruling is being changed in part and is continued without change in part and it is desired to restate the valid portion of the previously published ruling in a new ruling that is self contained. In this case, the previously published ruling is first modified and then, as modified, is superseded. 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 ruling has been supplemented several times, a new ruling may be published that includes the list in the original ruling and the additions, and supersedes all prior rul- ings 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 following abbreviations in current use and formerly used will appear in ma- terial published in the Bulletin. A—Individual. Acq.—Acquiescence. B—Individual. BE—Beneficiary. BK—Bank. B.T.A.—Board of Tax Appeals. C—Individual. C.B.—Cumulative Bulletin. CFR—Code of Federal Regulations. CI—City. COOP—Cooperative. Ct.D.—Court Decision. CY—County. D—Decedent. DC—Dummy Corporation. DE—Donee. Del. Order—Delegation Order. DISC—Domestic International Sales Corporation. DR—Donor. E—Estate. EE—Employee. E.O.—Executive Order. ER—Employer. ERISA—Employee Retirement Income Security Act. EX—Executor. F—Fiduciary. FC—Foreign Country. FICA—Federal Insurance Contributions Act. FISC—Foreign International Sales Company. FPH—Foreign Personal Holding Company. F.R.—Federal Register. FUTA—Federal Unemployment Tax Act. FX—Foreign corporation. G.C.M.—Chief Counsel’s Memorandum. GE—Grantee. GP—General Partner. GR—Grantor. IC—Insurance Company. I.R.B.—Internal Revenue Bulletin. LE—Lessee. LP—Limited Partner. LR—Lessor. M—Minor. Nonacq.—Nonacquiescence. O—Organization. P—Parent Corporation. PHC—Personal Holding Company. PO—Possession of the U.S. PR—Partner. PRS—Partnership. PTE —Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Real Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul.—Revenue Ruling. S—Subsidiary. S.P.R.—Statement of Procedural Rules. Stat.—Statutes at Large. T—Target Corporation. T.C.—Tax Court. T.D.—Treasury Decision. TFE—Transferee. TFR—Transferor. T.I.R.—Technical Information Release. TP—Taxpayer. TR—Trust. TT—Trustee. U.S.C.—United States Code. X—Corporation. Y—Corporation. Z—Corporation. Bulletin No. 2015–22June 1, 2015 i Numerical Finding List 1 Bulletin 2015–1 through 2015–22 Announcements: 2015-1, 2015-11 I.R.B.758 2015-2, 2015-3 I.R.B.324 2015-3, 2015-3 I.R.B.328 2015-4, 2015-5 I.R.B.565 2015-5, 2015-7 I.R.B.602 2015-6, 2015-8 I.R.B.685 2015-7, 2015-13 I.R.B.823 2015-8, 2015-9 I.R.B.698 2015-10, 2015-11 I.R.B.758 2015-11, 2015-15 I.R.B.883 2015-12, 2015-12 I.R.B.770 2015-13, 2015-15 I.R.B.908 2015-14, 2015-20 I.R.B.971 2015-15, 2015-22 I.R.B.1014 Proposed Regulations: REG-109187-11, 2015-2 I.R.B.277 REG-132751-14, 2015-2 I.R.B.279 REG-145878-14, 2015-2 I.R.B.290 REG-153656-3, 2015-5 I.R.B.566 REG-102648-15, 2015-10 I.R.B.745 REG-136018-13, 2015-11 I.R.B.759 REG-143416-14, 2015-11 I.R.B.757 REG-100400-14, 2015-12 I.R.B.779 REG-132253-11, 2015-12 I.R.B.771 REG-143040-11, 2015-13 I.R.B.827 REG-133489-13, 2015-16 I.R.B.926 REG-103281-11, 2015-19 I.R.B.948 REG-107595-11, 2015-21 I.R.B.986 REG-132634-14, 2015-21 I.R.B.997 REG-102656-15, 2015-21 I.R.B.1005 Notices: 2015-1, 2015-2 I.R.B.249 2015-2, 2015-4 I.R.B.334 2015-3, 2015-6 I.R.B.583 2015-4, 2015-5 I.R.B.407 2015-5, 2015-5 I.R.B.408 2015-6, 2015-5 I.R.B.412 2015-7, 2015-6 I.R.B.585 2015-8, 2015-6 I.R.B.589 2015-9, 2015-6 I.R.B.590 2015-10, 2015-20 I.R.B.965 2015-11, 2015-8 I.R.B.618 2015-15, 2015-9 I.R.B.687 2015-12, 2015-8 I.R.B.700 2015-13, 2015-10 I.R.B.722 2015-14, 2015-10 I.R.B.722 2015-16, 2015-10 I.R.B.732 2015-17, 2015-14 I.R.B.845 2015-19, 2015-9 I.R.B.690 2015-20, 2015-11 I.R.B.754 2015-18, 2015-12 I.R.B.765 Notices:—Continued 2015-21, 2015-12 I.R.B.765 2015-22, 2015-12 I.R.B.768 2015-23, 2015-12 I.R.B.769 2015-24, 2015-13 I.R.B.811 2015-25, 2015-13 I.R.B.814 2015-26, 2015-13 I.R.B.814 2015-27, 2015-13 I.R.B.816 2015-28, 2015-14 I.R.B.848 2015-29, 2015-15 I.R.B.873 2015-30, 2015-17 I.R.B.928 2015-31, 2015-17 I.R.B.929 2015-32, 2015-20 I.R.B.967 2015-33, 2015-18 I.R.B.934 2015-34, 2015-18 I.R.B.942 2015-35, 2015-18 I.R.B.943 2015-37, 2015-19 I.R.B.947 2015-38, 2015-21 I.R.B.984 2015-39, 2015-22 I.R.B.1008 Revenue Procedures: 2015-1, 2015-1 I.R.B.1 2015-2, 2015-1 I.R.B.105 2015-3, 2015-1 I.R.B.129 2015-4, 2015-1 I.R.B.144 2015-5, 2015-1 I.R.B.186 2015-6, 2015-1 I.R.B.194 2015-7, 2015-1 I.R.B.231 2015-8, 2015-1 I.R.B.235 2015-9, 2015-2 I.R.B.249 2015-10, 2015-2 I.R.B.261 2015-12, 2015-2 I.R.B.265 2015-13, 2015-5 I.R.B.419 2015-14, 2015-5 I.R.B.450 2015-15, 2015-5 I.R.B.564 2015-16, 2015-7 I.R.B.596 2015-17, 2015-7 I.R.B.599 2015-18, 2015-8 I.R.B.642 2015-19, 2015-8 I.R.B.678 2015-20, 2015-9 I.R.B.694 2015-21, 2015-13 I.R.B.817 2015-22, 2015-11 I.R.B.754 2015-23, 2015-13 I.R.B.820 2015-24, 2015-13 I.R.B.822 2015-25, 2015-14 I.R.B.848 2015-26, 2015-15 I.R.B.875 2015-27, 2015-16 I.R.B.914 2015-28, 2015-16 I.R.B.920 2015-29, 2015-15 I.R.B.882 2015-30, 2015-20 I.R.B.970 Revenue Rulings: 2015-1, 2015-4 I.R.B.331 2015-2, 2015-3 I.R.B.321 2015-3, 2015-6 I.R.B.580 2015-4, 2015-10 I.R.B.743 2015-5, 2015-13 I.R.B.788 2015-6, 2015-13 I.R.B.801 Revenue Rulings:—Continued 2015-7, 2015-14 I.R.B.849 2015-8, 2015-18 I.R.B.945 2015-9, 2015-21 I.R.B.972 2015-10, 2015-21 I.R.B.973 2015-11, 2015-21 I.R.B.975 2015-13, 2015-22 I.R.B.1011 2015-14, 2015-22 I.R.B.1012 Treasury Decisions: 9707, 2015-2 I.R.B.247 9708, 2015-5 I.R.B.337 9709, 2015-7 I.R.B.593 9710, 2015-8 I.R.B.603 9711, 2015-11 I.R.B.748 9712, 2015-11 I.R.B.750 9713, 2015-13 I.R.B.802 9714, 2015-14 I.R.B.831 9715, 2015-15 I.R.B.851 9716, 2015-15 I.R.B.863 9717, 2015-16 I.R.B.910 9718, 2015-15 I.R.B.866 9719, 2015-21 I.R.B.977 1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2014 –27 through 2014 –52 is in Internal Revenue Bulletin 2014 –52, dated December 28, 2014. June 1, 2015Bulletin No. 2015–22 ii Finding List of Current Actions on Previously Published Items 1 Bulletin 2015–1 through 2015–22 Announcements: 2010-3 Amplified by Ann. 2015-3, 2015-3 I.R.B.328 Revenue Procedures: 2014-01 Superseded by Rev. Proc. 2015-01, 2015-01 I.R.B.1 2014-02 Superseded by Rev. Proc. 2015-02, 2015-01 I.R.B.105 2014-03 Superseded by Rev. Proc. 2015-03, 2015-01 I.R.B.129 2014-04 Superseded by Rev. Proc. 2015-04, 2015-01 I.R.B.144 2014-05 Superseded by Rev. Proc. 2015-05, 2015-01 I.R.B.186 2014-06 Superseded by Rev. Proc. 2015-06, 2015-01 I.R.B.194 2014-07 Superseded by Rev. Proc. 2015-07, 2015-01 I.R.B.231 2014-08 Superseded by Rev. Proc. 2015-08, 2015-01 I.R.B.235 2014-10 Superseded by Rev. Proc. 2015-10, 2015-2 I.R.B.261 2003-63 Superseded by Rev. Proc. 2015-12, 2015-2 I.R.B.265 2011-14 Modified by Rev. Proc. 2015-12, 2015-2 I.R.B.265 2011-14 Modified by Rev. Proc. 2015-13, 2015-5 I.R.B.419 Revenue Procedures:—Continued 2011-14 Amplified by Rev. Proc. 2015-13, 2015-5 I.R.B.419 2011-14 Clarified by Rev. Proc. 2015-13, 2015-5 I.R.B.419 1997-27 Clarified by Rev. Proc. 2015-13, 2015-5 I.R.B.419 1997-27 Modified by Rev. Proc. 2015-13, 2015-5 I.R.B.419 2012-11 Superseded by Rev. Proc. 2015-17, 2015-7 I.R.B.599 2015-9 Modified by Rev. Proc. 2015-17, 2015-7 I.R.B.599 2015-14 Modified by Rev. Proc. 2015-20, 2015-9 I.R.B.694 2013-22 Modified by Rev. Proc. 2015-22, 2015-11 I.R.B.754 2015-8 Modified by Rev. Proc. 2015-22, 2015-11 I.R.B.754 2014-59 Modified by Rev. Proc. 2015-24, 2015-13 I.R.B.822 2002-43 Modified by Rev. Proc. 2015-26, 2015-15 I.R.B.875 2002-43 Obsoleted by Rev. Proc. 2015-26, 2015-15 I.R.B.875 Revenue Rulings: 92-19 Supplemented by Rev. Rul. 2015-02, 2015-3 I.R.B.321 1978-130 Revoked by Rev. Rul. 2015-9, 2015-21 I.R.B.972 Revenue Rulings:—Continued 1975-491 Revoked by Rev. Rul. 2015-11, 2015-21 I.R.B.975 1990-65 Revoked by Rev. Rul. 2015-11, 2015-21 I.R.B.975 90-5 Superseded by Rev. Rul. 2015-13, 2015-22 I.R.B.1011 2002-12 Superseded by Rev. Rul. 2015-13, 2015-22 I.R.B.1011 2011-17 Amplified by Rev. Rul. 2015-13, 2015-22 I.R.B.1011 Notices: 2013-01 Modified by Notice 2015-20, 2015-11 I.R.B.754 2013-01 Superseded by Notice 2015-20, 2015-11 I.R.B.754 2014-24 Obsoleted by Notice 2015-29, 2015-15 I.R.B.882 1997-19 Modified by Notice 2015-38, 2015-21 I.R.B.984 1997-26 Superseded by Notice 2015-38, 2015-21 I.R.B.984 2001-62 Superseded by Notice 2015-38, 2015-21 I.R.B.984 2002-62 Superseded by Notice 2015-38, 2015-21 I.R.B.984 2004-83 Superseded by Notice 2015-38, 2015-21 I.R.B.984 1 A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2014 –27 through 2014 –52 is in Internal Revenue Bulletin 2014 –52, dated December 28, 2014. Bulletin No. 2015–22June 1, 2015 iii INTERNAL REVENUE BULLETIN The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue Bulletins are available atwww.irs.gov/irb/. We Welcome Comments About the Internal Revenue Bulletin If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page (www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave. NW, IR-6230 Washington, DC 20224. Internal Revenue Service Washington, DC 20224 Official Business Penalty for Private Use, $300
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