Internal Revenue Bulletin 2020-9 (PDF rendition): IRS Revenue Rulings

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Bulletin No. 2020–9
February 24, 2020
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.
ADJUSTMENT TO BASIS
Rev Rul. 2020-5, page 454.
Rev. Rul. 2020-5 modifies Rev. Rul. 2009-13 and Rev.
Rul. 2009-14 to reflect § 1016(a)(1)(B) of the Internal Rev-
enue Code, which was added by section 13521 of the
2017 Tax Cuts and Jobs Act. Under §1016(a)(1)(B), the
adjusted basis of an insurance contract is not reduced by
the cost of insurance. Section 1016(a)(1)(B) reversed the
position in Rev. Rul. 2009-13 and Rev. Rul. 2009-14 that
the basis of an insurance contract is reduced by the cost
of insurance.
INCOME TAX
T.D. 9893, page 449.
These regulations set forth the procedures for employers
who choose to use special valuation rules to determine
the amount to include in an employee’s gross income for
personal use of an employer-provided vehicle. To align
with changes made by the Tax Cuts and Jobs Act, these
final regulations update the procedures for determining the
maximum vehicle values for use with the special valuation
rules and describe how employers may adopt the special
valuation rules for years 2018 and 2019.
Finding Lists begin on page ii.

The IRS Mission
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Introduction
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing of-
ficial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
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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,
modify, or amend any of those previously published in the
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wise indicated. Procedures relating solely to matters of inter-
nal management are not published; however, statements of
internal practices and procedures that affect the rights and
duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service
on the application of the law to the pivotal facts stated in
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ings 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
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procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B,
Legislation and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
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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.
February 24, 2020 Bulletin No. 2020–9

Part I
26 CFR 1.61-21 Taxation of Fringe Benefits
T.D. 9893
DEPARTMENT OF THE
TREASURY
Internal Revenue Service
26 CFR Part 1
Determination of the
Maximum Value of a
Vehicle for Use with the
Fleet-Average and Vehicle
Cents-Per-Mile Valuation
Rules
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulation.
SUMMARY: This document sets forth fi-
nal regulations regarding special valuation
rules for employers and employees to use
in determining the amount to include in
an employee’s gross income for personal
use of an employer-provided vehicle. The
final regulations reflect changes made by
the Tax Cuts and Jobs Act (TCJA).
DATES: Effective Date: These regulations
are effective February 5, 2020.
Applicability Date: For dates of appli-
cability, see §1.61-21(d)(5)(v)(H) and
§1.61-21(e)(6).
FOR FURTHER INFORMATION CON-
TACT: Stephanie Caden at (202) 317-
4774 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
If an employer provides an employee
with a vehicle that is available to the em-
ployee for personal use, the value of the
personal use must generally be included in
the employee’s income under section 61 of
the Internal Revenue Code (the Code). In
addition, benefits paid as remuneration for
employment, including the personal use of
employer-provided vehicles, generally are
wages for purposes of the Federal Insur-
ance Contributions Act (FICA), the Fed-
eral Unemployment Tax Act (FUTA) and
the Collection of Income Tax at Source on
Wages (federal income tax withholding).
Sections 3121(a), 3306(b), and 3401(a).
The amount that must be included in
the employee’s income and wages for the
personal use of an employer-provided ve-
hicle generally is determined by reference
to the vehicle’s fair market value (FMV).
However, for many years, §1.61-21 has
provided special valuation rules for em-
ployer-provided vehicles (the prior final
regulations).
1
If an employer chooses to
use a special valuation rule, the special
value is treated as the FMV of the benefit
for income tax and employment tax pur-
poses. §1.61-21(b)(4). As discussed fur-
ther in this Background section of this pre-
amble, two such special valuation rules,
the fleet-average valuation rule and the
vehicle cents-per-mile valuation rule, are
set forth in §1.61-21(d)(5)(v) and §1.61-
21(e), respectively. These two special
valuation rules are subject to limitations,
including that they may be used only in
connection with vehicles having values
that do not exceed a maximum amount set
forth in the regulations.
Section 1.61-21(e)(1)(iii)(A) of the pri-
or final regulations provided that the ve-
hicle cents-per-mile valuation rule could
be used only to value the personal use of
a vehicle having a value no greater than
$12,800 (the sum of the maximum recov-
ery deductions allowable under section
280F(a)(2) for the recovery period of the
vehicle). Section 1.61-21(d)(5)(v)(D) of
the prior final regulations provided that
the fleet-average valuation rule could be
used only to value the personal use of
vehicles having values no greater than
$16,500. (The fleet-average valuation rule
uses the term “automobile” rather than
“vehicle.” For convenience, this preamble
uses the term “vehicle” except in specif-
ic discussions of the fleet-average valua-
tion rule or the section 280F depreciation
limitations.) Sections 1.61-21(d)(5)(v)(D)
and 1.61-21(e)(1)(iii)(A) of the prior final
regulations provided that each of these
maximum values was adjusted annually
pursuant to section 280F(d)(7).
1. The Fleet-Average Valuation Rule
The fleet-average valuation rule is an
optional component of a special valuation
rule called the automobile lease valuation
rule set forth in §1.61-21(d). Under the au-
tomobile lease valuation rule, the value of
the personal use of an employer-provided
automobile available to an employee for
an entire year is the portion of the annual
lease value determined under the regula-
tions (Annual Lease Value) relating to the
availability of the automobile for personal
use. Furthermore, provided the FMV of
the automobile does not exceed the max-
imum value permitted under §1.61-21(d)
(5)(v), an employer with a fleet of 20 or
more automobiles may use a fleet-average
value for purposes of calculating the An-
nual Lease Value of any automobile in the
fleet.
The fleet-average value is the average
of the fair market values of all the auto-
mobiles in the fleet. However, §1.61-21(d)
(5)(v)(D) of the prior final regulations
provided that the value of an employee’s
personal use of an automobile could not
be determined under the fleet-average
valuation rule for a calendar year if the
FMV of the automobile on the first date
the automobile was made available to
the employee exceeded the base value of
$16,500, as adjusted annually pursuant to
section 280F(d)(7). Section 1.61-21(d)(5)
(v)(D) provided that the first such adjust-
ment would be for calendar year 1989,
subject to minor modifications to the sec-
tion 280F(d)(7) formula specified in the
regulations. In other words, under the pri-
or final regulations, the maximum value
for use of the fleet-average valuation rule
<?>
T.D. 8256, 54 FR 28576, July 6, 1989, as amended by T.D. 8389, 57 FR 1868, Jan. 16, 1992; T.D. 8457, 57 FR 62192, Dec. 30, 1992; T.D. 9597, 77 FR 45480, Aug. 1, 2012; T.D. 9849,
84 FR 9231, March 14, 2019.
Bulletin No. 2020–9 449 February 24, 2020

was the base value of $16,500, as adjusted
annually under section 280F(d)(7) every
year since 1989.
Prior to enactment of TCJA, the auto-
mobile price inflation adjustment of sec-
tion 280F(d)(7)(B) was calculated using
the “new car” component of the Consum-
er Price Index (CPI) “automobile compo-
nent.” Beginning in 2005, the IRS began
to calculate the price inflation adjustment
for trucks and vans separately from cars
using the “new truck” component of the
CPI, and continued using the “new car”
component of the CPI for automobiles
other than trucks and vans. See Rev. Proc.
2005-48, 2005-32 I.R.B. 271. For 2017,
the year of the enactment of TCJA, the
maximum value for use of this rule was
$21,100 for a passenger automobile and
$23,300 for a truck or van. See Notice
2017-03, 2017-2 I.R.B. 368.
Section 1.61-21(d)(5)(v)(B) provides
that the fleet-average valuation rule may
be used by an employer as of January 1
of any calendar year following the calen-
dar year in which the employer acquires
a sufficient number of automobiles to to-
tal a fleet of 20 or more, each one satis-
fying the maximum value requirement of
§1.61-21(d)(5)(v)(D). The Annual Lease
Value calculated for automobiles in the
fleet, based on the fleet-average value,
must remain in effect for the period that
begins with the first January 1 the fleet-av-
erage valuation rule is applied by the em-
ployer to the automobiles in the fleet and
ends on December 31 of the subsequent
calendar year. The Annual Lease Value for
each subsequent two-year period is cal-
culated by determining the fleet average
value of the automobiles in the fleet as of
the first January 1 of such period. An em-
ployer may cease using the fleet-average
valuation rule as of any January 1.
2. The Vehicle Cents-Per-Mile Valuation
Rule
Another special valuation rule is the
vehicle cents-per-mile rule in §1.61-21(e).
Under §1.61-21(e), if an employer pro-
vides an employee with the use of a vehi-
cle that the employer reasonably expects
will be regularly used in the employer’s
trade or business throughout the calendar
year (or such shorter period as the vehicle
may be owned or leased by the employ-
er), or that satisfies the requirements of
§1.61-21(e)(1)(ii) (i.e., the vehicle is ac-
tually driven at least 10,000 miles in the
year and use of the vehicle during the year
is primarily by employees), the value of
the personal use may be determined based
on the applicable standard mileage rate
multiplied by the total number of miles
the vehicle is driven by the employee for
personal purposes.
Section 1.61-21(e)(1)(iii)(A) provides
that the value of the personal use may not
be determined under the vehicle cents-
per-mile valuation rule for a calendar year
if the fair market value of the vehicle on
the first date the vehicle is made available
to the employee exceeds the sum of the
maximum recovery deductions allowable
under section 280F(a) for a five-year pe-
riod for an automobile first placed in ser-
vice during that calendar year (whether or
not the automobile is actually placed in
service during that year), as adjusted by
section 280F(d)(7). The prior final reg-
ulations provided that, under this rule,
with respect to a vehicle placed in service
in or after 1989, the limitation on value
was $12,800, as adjusted under section
280F(d)(7). In other words, under the pri-
or final regulations, the maximum value
of a vehicle for use of the vehicle cents-
per-mile valuation rule was the base val-
ue of $12,800, as adjusted annually under
section 280F(d)(7) since 1989. As with the
fleet-average valuation rule, beginning in
2005, the IRS calculated the price infla-
tion adjustment for trucks and vans sepa-
rately from cars. See Rev. Proc. 2005-48.
For 2017, the maximum value for use of
the vehicle cents-per-mile valuation rule
was $15,900 for a passenger automobile
and $17,800 for a truck or van. See Notice
2017-03.
Section 1.61-21(e)(5)(i) states that an
employer must adopt the vehicle cents-
per-mile valuation rule for a vehicle to
take effect by the first day on which the
vehicle is used by an employee of the em-
ployer for personal use (or, if another spe-
cial valuation rule called the commuting
valuation rule of §1.61-21(f) is used when
the vehicle is first used by an employee
of the employer for personal use, the first
day on which the commuting valuation
rule is not used). Section 1.61-21(e)(5)(ii)
also provides, in part, that once the vehi-
cle cents-per-mile valuation rule has been
adopted for a vehicle by an employer, the
rule must be used by the employer for all
subsequent years in which the vehicle
qualifies for use of the rule, except that the
employer may, for any year during which
use of the vehicle qualifies for the com-
muting valuation rule of §1.61-21(f), use
the commuting valuation rule with respect
to the vehicle.
3. TCJA Changes and the Maximum
Vehicle Values for 2018 and 2019
TCJA made the following amendments
to the Code:
(1) For owners of passenger automo-
biles, section 280F(a), as modified by sec-
tion 13202(a)(1) of TCJA, imposes dollar
limitations on the depreciation deduction
for the year the taxpayer places the pas-
senger automobile in service and for each
succeeding year. The amendments made
by TCJA substantially increase the max-
imum annual dollar limitations on the
depreciation deductions for passenger
automobiles. The new dollar limitations
are based on the depreciation, over a five-
year recovery period, of a passenger auto-
mobile with a cost of $50,000 (formerly
$12,800, as adjusted).
(2) Section 11002(d)(8) of TCJA
amended section 280F(d)(7)(B) effective
for tax years beginning after December
31, 2017. Pursuant to these amendments,
the price inflation amount for automobiles
(including trucks and vans) is calculated
using both the CPI automobile component
and the Chained Consumer Price Index
for All Urban Consumers (C-CPI-U) au-
tomobile component.
a. Notice 2019-08 – The Maximum Value
for 2018
To implement the changes described
above, Notice 2019-08, 2019-3 I.R.B.
354, provides interim guidance for 2018
on new procedures for calculating the
price inflation adjustments to the maxi-
mum vehicle values for use with the spe-
cial valuation rules under §1.61-21(d) and
(e) using section 280F(d)(7), as modified
by sections 11002 and 13202 of the TCJA.
Notice 2019-08 states that the Treasury
Department and the IRS anticipate that
further guidance will be issued in the form
of proposed regulations and expect that
February 24, 2020 450 Bulletin No. 2020–9

Bulletin No. 2020–9 451 February 24, 2020
the regulations will be consistent with the
rules set forth in Notice 2019-08.
Notice 2019-08 provides that, consis-
tent with the substantial increase in the
dollar limitations on depreciation deduc-
tions under section 280F(a), as modified
by section 13202(a)(1) of TCJA, the Trea-
sury Department and the IRS intend to
amend §1.61-21(d) and (e) to incorporate
a higher base value of $50,000 as the max-
imum value for use of the vehicle cents-
per-mile and fleet-average valuation rules
effective for the 2018 calendar year. No-
tice 2019-08 further states that the Trea-
sury Department and the IRS intend that
the regulations will be modified to provide
that this $50,000 base value will be adjust-
ed annually using section 280F(d)(7) for
2019 and subsequent years. Accordingly,
Notice 2019-08 provides that, for 2018,
the maximum value for use of the vehicle
cents-per-mile and fleet-average valuation
rules is $50,000.
Finally, for 2018 and 2019, Notice
2019-08 provides that the Treasury De-
partment and the IRS will not publish sep-
arate maximum values for trucks and vans
for use with the fleet-average and vehicle
cents-per-mile valuation rules. As noted
above, TCJA amended section 280F(d)(7)
(B) to make inflation adjustments based
on the CPI and C-CPI-U automobile com-
ponent. The C-CPI-U automobile com-
ponent does not currently have separate
components for new cars and new trucks.
Accordingly, due to the lack of data, the
Treasury Department and the IRS will
publish only one maximum value of a
vehicle for use with the vehicle cents-per-
mile and fleet-average valuation rules be-
ginning in 2019.
b. Notice 2019-34 - The Maximum
Vehicle Value for 2019
Notice 2019-34, 2019-22 I.R.B. 1257,
provides that the inflation-adjusted maxi-
mum value of an employer-provided vehi-
cle (including cars, vans, and trucks) first
made available to employees for personal
use in calendar year 2019 for which the
vehicle cents-per-mile valuation rule pro-
vided under §1.61-21(e), or the fleet-aver-
age valuation rule provided under §1.61-
21(d), may be used, is $50,400. Notice
2019-34 also provides information about
the manner in which the Treasury Depart-
ment and the IRS intend to publish this
maximum vehicle value in the future.
As noted in Notice 2019-34, Rev. Proc.
2010-51, 2010-51 I.R.B. 883, as modified
by Rev. Proc. 2019-46, 2019-49 I.R.B.
1301, provides rules for using optional
standard mileage rates in computing the
deductible costs of operating an automo-
bile for business, charitable, medical, or
moving expense purposes. Section 2.12(1)
of Rev. Proc. 2010-51 provides that the
IRS publishes both the standard mileage
rates for the use of an automobile for
business, charitable, medical, and mov-
ing expense purposes, and the maximum
standard automobile cost that may be used
in computing the allowance under a fixed
and variable rate (FAVR) plan, in a sepa-
rate annual notice. See, e.g., Notice 2019-
02, 2019-02 I.R.B. 281.
Notice 2019-34 indicates that, in
amending §1.61-21(d) and (e) to incorpo-
rate a higher base value of $50,000 as the
maximum value for use with the vehicle
cents-per-mile and the fleet-average valu-
ation rules, the IRS and Treasury Depart-
ment expect that the maximum value for
use of those rules for 2019 and subsequent
years will be the same as the maximum
standard automobile cost that may be used
in computing the allowance under a FAVR
plan. Accordingly, Notice 2019-34 pro-
vides that the maximum value for use with
the fleet-average and vehicle cents-per-
mile valuation rules will be published in
the annual notice providing the standard
mileage rates for use of an automobile for
business, charitable, medical, and moving
expense purposes and the maximum stan-
dard automobile cost that may be used in
computing the allowance under a FAVR
plan.
Notice 2019-34 also provides that the
Treasury Department and the IRS intend
to revise §1.61-21(d) to include a tran-
sition rule for any employer that did not
qualify to use the fleet-average valuation
rule prior to January 1, 2018 because the
inflation-adjusted maximum value re-
quirement of §1.61-21(d)(5)(v)(D), as
published by the IRS in a notice or rev-
enue procedure applicable to the year the
automobile was first made available to any
employee of the employer, was not met. In
such a case, under the transition rule, the
employer may adopt the fleet-average val-
uation rule for 2018 or 2019, provided the
requirements of §1.61-21(d)(5)(v) are met
for that year using the maximum values
set forth in Notice 2019-08 ($50,000) or
Notice 2019-34 ($50,400), respectively.
In addition, Notice 2019-34 states that
the Treasury Department and the IRS in-
tend to revise §1.61-21(e) to provide a
transition rule for vehicles first made avail-
able to employees for personal use before
calendar year 2018, if the employer did
not qualify under §1.61-21(e)(5) to adopt
the vehicle cents-per-mile valuation rule
for the vehicle on the first day on which
the vehicle was used by the employee
for personal use because the fair market
value of the vehicle exceeded the infla-
tion-adjusted limitation of §1.61-21(e)(1)
(iii) as published by the IRS in a notice or
revenue procedure applicable to the year
the vehicle was first used by the employ-
ee for personal use. In such a case, under
the transition rule, the employer may first
adopt the vehicle cents-per-mile valuation
rule for the 2018 or 2019 taxable year
based on the maximum fair market value
of a vehicle for purposes of the vehicle
cents-per-mile valuation rule set forth in
Notice 2019-08 ($50,000) or Notice 2019-
34 ($50,400), respectively.
Similarly, Notice 2019-34 also pro-
vides that the Treasury Department and
the IRS intend to amend §1.61-21(e) to
provide a transition rule for a vehicle first
placed in service before calendar year
2018 if the commuting valuation rule of
§1.61-21(f) was used when the vehicle
was first used by an employee of the em-
ployer for personal use, and the employ-
er did not qualify to switch to the vehicle
cents-per-mile valuation rule on the first
day on which the commuting valuation
rule was not used because the vehicle
had a fair market value in excess of the
inflation-adjusted maximum permitted
under §1.61-21(e)(1)(iii) as published by
the IRS in a notice or revenue procedure
applicable to the year the commuting val-
uation rule was first not used. Under the
transition rule, the employer may adopt
the vehicle cents-per-mile valuation rule
for the 2018 or 2019 taxable year based
on the maximum fair market value of the
vehicle for purposes of the vehicle cents-
per-mile valuation rule set forth in Notice
2019-08 or Notice 2019-34, respectively.
With respect to the transition rules
described above, Notice 2019-34 adds

February 24, 2020 452 Bulletin No. 2020–9
that, consistent with §1.61-21(e)(5), an
employer that adopts the vehicle cents-
per-mile valuation rule must continue to
use the rule for all subsequent years in
which the vehicle qualifies for use of the
rule, except that the employer may, for
any year during which use of the vehi-
cle qualifies for the commuting valuation
rule of §1.61-21(f), use the commuting
valuation rule with respect to the vehi-
cle.
4. Notice of Proposed Rulemaking
On August 23, 2019, a notice of pro-
posed rulemaking was published in the
Federal Register (84 FR 44258) that was
consistent with Notice 2019-08 and No-
tice 2019-34 and reflected changes made
by TCJA to the depreciation limitations
in section 280F. The notice of proposed
rulemaking proposed revisions to §1.61-
21(d) and §1.61-21(e) to increase, effec-
tive for the 2018 calendar year, the max-
imum base fair market value of a vehicle
for use of the fleet-average and vehicle
cents-per-mile valuation rules to $50,000.
The proposed regulations further provided
that the maximum fair market value of a
vehicle for use of the fleet-average and ve-
hicle cents-per-mile valuation rules will be
adjusted annually under section 280F(d)
(7), as amended by TCJA, and the adjust-
ed maximum fair market value will be
included in the annual notice published
by the IRS providing the standard mile-
age rates for the use of an automobile for
business, charitable, medical, and moving
expense purposes and the maximum stan-
dard automobile cost for purposes of an
allowance under a FAVR plan. See, e.g.,
Notice 2019-02. Additionally, the pro-
posed regulations provide transition rules
that permit employers that could not adopt
the fleet-average or vehicle cents-per-mile
valuation rules prior to 2018 (because a
vehicle had a fair market value in excess
of the maximum permitted under the prior
final regulations), to use the special val-
uation rules for the first time in 2018 or
2019.
No public hearing on the proposed
regulations was requested or held. No
comments responding to the proposed
regulations were received. Therefore, the
proposed regulations are adopted as final
regulations without substantive change.
Explanation of Provisions
These final regulations update the
fleet-average and vehicle cents-per-mile
valuation rules described in §1.61-21(d)
and (e), respectively, to align the limita-
tions on the maximum vehicle fair market
values for use of these special valuation
rules with the changes made by the TCJA
to the depreciation limitations in section
280F. Specifically, consistent with the
substantial increase in the dollar limita-
tions on depreciation deductions under
section 280F(a), these final regulations
increase, effective for the 2018 calendar
year, the maximum base fair market val-
ue of a vehicle for use of the fleet-average
or vehicle cents-per-mile valuation rule to
$50,000. Consistent with §§ 1.61-21(d)(5)
(v)(D) and 1.61-21(e)(1)(iii)(A) of prior
final regulations, the maximum fair mar-
ket value of a vehicle for purposes of the
fleet-average and vehicle cents-per-mile
valuation rules is adjusted annually under
section 280F(d)(7). This annual adjust-
ment will be calculated in accordance with
section 280F(d)(7) as amended by TCJA.
Consistent with the expectation ex-
pressed in Notice 2019-34 and in the
notice of proposed rulemaking, the infla-
tion-adjusted maximum fair market value
for a vehicle for purposes of the fleet-av-
erage and vehicle cents-per-mile valua-
tion rules will be included in the annual
notice published by the IRS providing the
standard mileage rates for the use of an
automobile for business, charitable, medi-
cal, and moving expense purposes and the
maximum standard automobile cost for
purposes of an allowance under a FAVR
plan. See, e.g., Notice 2019-02.
Furthermore, consistent with Notice
2019-34 and the proposed regulations, the
following transition rules are included in
these final regulations:
(1) With respect to the fleet-average
valuation rule, if an employer did not
qualify to use the fleet-average valuation
rule prior to January 1, 2018, with respect
to an automobile because the fair market
value of the automobile exceeded the in-
flation-adjusted maximum value require-
ment of §1.61-21(d)(5)(v)(D), as pub-
lished by the IRS in a notice or revenue
procedure applicable to the year the au-
tomobile was first made available to any
employee of the employer, the employer
may adopt the fleet-average valuation rule
for 2018 or 2019, provided the fair market
value of the automobile does not exceed
$50,000 on January 1, 2018, or $50,400
on January 1, 2019, respectively.
(2) With respect to the vehicle cents-
per-mile valuation rule, for a vehicle first
made available to any employee of the
employer for personal use before cal-
endar year 2018, if an employer did not
qualify under §1.61-21(e)(5) to adopt the
vehicle cents-per-mile valuation rule on
the first day on which the vehicle was
used by the employee for personal use be-
cause the fair market value of the vehicle
exceeded the inflation-adjusted limitation
of §1.61-21(e)(1)(iii), as published by the
IRS in a notice or revenue procedure ap-
plicable to the year the vehicle was first
used by the employee for personal use,
the employer may first adopt the vehicle
cents-per-mile valuation rule for the 2018
or 2019 taxable year with respect to the
vehicle, provided the fair market value of
the vehicle does not exceed $50,000 on
January 1, 2018, or $50,400 on January
1, 2019, respectively. Similarly, if the
commuting valuation rule of §1.61-21(f)
was utilized when the vehicle was first
used by an employee of the employer for
personal use, and the employer did not
qualify to switch to the vehicle cents-
per-mile valuation rule on the first day
on which the commuting valuation rule
was not used because the vehicle had a
fair market value in excess of the infla-
tion-adjusted limitation of §1.61-21(e)(1)
(iii), as published by the IRS in a notice
or revenue procedure applicable to the
year the commuting valuation rule was
first not used, the employer may adopt the
vehicle cents-per-mile valuation rule for
the 2018 or 2019 taxable year, provided
the fair market value of the vehicle does
not exceed $50,000 on January 1, 2018,
or $50,400 on January 1, 2019, respec-
tively. However, consistent with §1.61-
21(e)(5), an employer that adopts the ve-
hicle cents-per-mile valuation rule must
continue to use the rule for all subsequent
years in which the vehicle qualifies for
use of the rule, except that the employer
may, for any year during which use of the
vehicle qualifies for the commuting val-
uation rule of §1.61-21(f), use the com-
muting valuation rule with respect to the
vehicle.

Bulletin No. 2020–9 453 February 24, 2020
Special Analyses
These final regulations are not subject
to review under section 6(b) of Execu-
tive Order 12866 pursuant to the Mem-
orandum of Agreement (April 11, 2018)
between the Department of the Treasury
and the Office of Management and Budget
regarding review of tax regulations.
It is hereby certified that these final
regulations will not have a significant eco-
nomic impact on a substantial number of
small entities pursuant to the Regulatory
Flexibility Act (5 U.S.C. chapter 6). This
certification is based on the fact that the
final regulations update existing regula-
tions to comport with the statutory chang-
es to section 280F made by the TCJA. Al-
though the final regulations might affect
a substantial number of small entities, the
economic impact of the final regulations is
not expected to be significant.
Since the current vehicle valuation
rules in the regulations are tied to infla-
tion adjustments under section 280F, the
statutory changes to section 280F neces-
sitate modifications to the procedures
for calculating annual inflation adjust-
ments to the maximum fair market value
of a vehicle permitted for use with the
fleet-average and vehicle cents-per-mile
special valuation rules. These revised
special valuation rules are consistent
with the base values and methodology
used for section 280F purposes and sim-
plify the determination of the amount
employers must include in employees’
income and wages for income and em-
ployment tax purposes for the personal
use of employer-provided vehicles. The
modifications made by these final regu-
lations to the maximum fair market value
of a vehicle permitted for use with the
fleet-average and vehicle cents-per-mile
special valuation rules, and the transition
rules provided in connection with these
final regulations, increase the number of
employers and employees that may take
advantage of the special valuation rules,
without increasing costs to the employer.
Pursuant to section 7805(f), the pro-
posed regulations preceding these final
regulations was submitted to the Chief
Counsel for Advocacy of the Small Busi-
ness Administration for comment on its
impact on small business. No comments
were received.
Drafting Information
The principal author of these regula-
tions is Stephanie Caden of the Office of
the Associate Chief Counsel (Employee
Benefits, Exempt Organizations, and Em-
ployment Tax). However, other personnel
from the IRS and the Treasury Department
participated in their development.
Statement of Availability
The IRS Notices, Revenue Procedures
and the Notice of Proposed Rulemaking
cited in this preamble are published in the
Internal Revenue Bulletin (or Cumulative
Bulletin) and are available from the Su-
perintendent of Documents, U.S. Govern-
ment Publishing Office, Washington, DC
20402, or by visiting the IRS website at
http://www.irs.gov.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and record-
keeping requirements.
Accordingly, 26 CFR part 1 is amend-
ed as follows:
PART 1-INCOME TAXES
Paragraph 1. The authority citation for
part 1 continues to read in part as follows:
Authority: 26 U.S.C. 7805***
Par. 2. Section 1.61-21 is amended by
revising paragraph (d)(5)(v)(D), adding
paragraphs (d)(5)(v)(G) and (H), revising
paragraph (e)(1)(iii)(A), revising para-
graph (e)(5)(i), and adding paragraphs (e)
(5)(vi) and (e)(6), to read as follows:
§1.61-21 Taxation of fringe benefits.
*****
(d) ***
(5) ***
(v) ***
(D) Limitations on use of fleet-aver-
age rule. The rule provided in this para-
graph (d)(5)(v) may not be used for any
automobile the fair market value of which
(determined pursuant to paragraphs (d)
(5)(i) through (iv) of this section as of the
first date on which the automobile is made
available to any employee of the employ-
er for personal use) exceeds $50,000, as
adjusted by section 280F(d)(7). The first
such adjustment shall be for calendar year
2019. In addition, the rule provided in this
paragraph (d)(5)(v) may only be used for
automobiles that the employer reasonably
expects will regularly be used in the em-
ployer’s trade or business. For rules con-
cerning when an automobile is regularly
used in the employer’s business, see para-
graph (e)(1)(iv) of this section.
*****
(G) Transition rule for 2018 and 2019.
Notwithstanding paragraph (d)(5)(v)(B)
of this section, an employer that did not
qualify to use the fleet-average valuation
rule prior to January 1, 2018, with respect
to any automobile (including a truck or
van) because the fair market value of the
vehicle exceeded the inflation-adjusted
maximum value requirement of paragraph
(d)(5)(v)(D) of this section, as published
by the IRS in a notice or revenue proce-
dure applicable to the year the vehicle was
first made available to any employee of
the employer, may adopt the fleet-average
valuation rule for 2018 or 2019 with re-
spect to the vehicle, provided the fair mar-
ket value of the vehicle does not exceed
$50,000 on January 1, 2018, or $50,400
on January 1, 2019, respectively.
(H) Applicability date. Paragraphs (d)
(5)(v)(D), and (G) of this section apply to
taxable years beginning on or after Febru-
ary 5, 2020. Notwithstanding the first sen-
tence of this paragraph (d)(5)(v)(H), any
taxpayer may choose to apply paragraph
(d)(5)(v)(G) of this section beginning on
or after January 1, 2018.
*****
(e) ***
(1) ***
(iii) ***
(A) In general. The value of the use of
an automobile (as defined in paragraph (d)
(1)(ii) of this section) may not be deter-
mined under the vehicle cents-per-mile
valuation rule of this paragraph (e) for a
calendar year if the fair market value of
the automobile (determined pursuant to
paragraphs (d)(5)(i) through (iv) of this
section as of the first date on which the
automobile is made available to any em-
ployee of the employer for personal use)
exceeds $50,000, as adjusted by section
280F(d)(7). The first such adjustment
shall be for calendar year 2019.
* * * * *
(5) ***
(i) Use of the vehicle cents-per-mile
valuation rule by an employer. An em-

February 24, 2020 454 Bulletin No. 2020–9
ployer must adopt the vehicle cents-per-
mile valuation rule of this paragraph (e)
for a vehicle to take effect by the first day
on which the vehicle is used by an em-
ployee of the employer for personal use
(or, if the commuting valuation rule of
paragraph (f) of this section is used when
the vehicle is first used by an employee of
the employer for personal use, the first day
on which the commuting valuation rule is
not used).
*****
(vi) Transition rule for 2018 and
2019. For a vehicle first made available
to any employee of an employer for
personal use before calendar year 2018,
an employer that did not qualify under
this paragraph (e)(5) to adopt the vehi-
cle cents-per-mile valuation rule on the
first day on which the vehicle is used by
the employee for personal use because
the fair market value of the vehicle ex-
ceeded the inflation-adjusted limitation
of paragraph (e)(1)(iii) of this section, as
published by the IRS in a notice or reve-
nue procedure applicable to the year the
vehicle was first used by the employee
for personal use, may first adopt the ve-
hicle cents-per-mile valuation rule for the
2018 or 2019 taxable year, provided the
fair market value of the vehicle does not
exceed $50,000 on January 1, 2018, or
$50,400 on January 1, 2019, respectively.
Similarly, for a vehicle first made avail-
able to any employee of the employer for
personal use before calendar year 2018,
if the commuting valuation rule of para-
graph (f) of this section was used when
the vehicle was first used by the employ-
ee for personal use, and the employer
did not qualify to switch to the vehicle
cents-per-mile valuation rule of this para-
graph (e) on the first day on which the
commuting valuation rule of paragraph
(f) of this section was not used because
the vehicle had a fair market value in ex-
cess of the inflation-adjusted limitation
of paragraph (e)(1)(iii) of this section, as
published by the IRS in a notice or reve-
nue procedure applicable to the year the
commuting valuation rule was first not
used, the employer may adopt the vehi-
cle cents-per-mile valuation rule for the
2018 or 2019 taxable year, provided the
fair market value of the vehicle does not
exceed $50,000 on January 1, 2018, or
$50,400 on January 1, 2019, respectively.
However, in accordance with paragraph
(e)(5)(ii) of this section, an employer that
adopts the vehicle cents-per-mile valu-
ation rule pursuant to this paragraph (e)
(5)(vi) must continue to use the rule for
all subsequent years in which the vehicle
qualifies for use of the rule, except that
the employer may, for any year during
which use of the vehicle qualifies for the
commuting valuation rule of paragraph
(f) of this section, use the commuting
valuation rule with regard to the vehicle.
(6) Applicability date. Paragraphs (e)
(1)(iii)(A) and (e)(5)(i) and (vi) of this
section apply to taxable years beginning
on or after February 5, 2020. Notwith-
standing the first sentence of this para-
graph (e)(6), any taxpayer may choose to
apply paragraph (e)(5)(vi) of this section
beginning on or after January 1, 2018.
* * * * *
Sunita Lough,
Deputy Commissioner for Services
and Enforcement.
Approved: January 17, 2020.
David J. Kautter,
Assistant Secretary of the Treasury
(Tax Policy).
(Filed by the Office of the Federal Register on Feb-
ruary 04, 2020, 8:45 a.m., and published in the issue
of the Federal Register for February 05, 2020, 85 FR
6424)
Section 1016.—
Adjustments to basis
Rev. Rul. 2020-05
ISSUE
After the amendment of § 1016(a) of
the Internal Revenue Code (Code) by sec-
tion 13521 of Public Law No. 115-97, 131
Stat. 2054 (December 22, 2017), com-
monly referred to as the Tax Cuts and Jobs
Act (TCJA), what is the amount of A’s and
B’s income recognized upon the sale of
the life insurance contracts described in
Situation 2 of Rev. Rul. 2009-13, 2009-
21 I.R.B. 1029; Situation 3 of Rev. Rul.
2009-13; and Situation 2 of Rev. Rul.
2009-14, 2009-21 I.R.B. 1031?
LAW AND ANALYSIS
Sections 1011 and 1012 of the Code
provide that the adjusted basis for deter-
mining gain or loss is generally the cost of
property adjusted as provided in § 1016,
except as otherwise provided in subchap-
ters O (§§ 1011 through 1092), C (§§ 301
through 386), K (§§ 701 through 777), and
P (§§ 1201 through 1298) of chapter 1 of
the Code.
Section 1016(a) provides that proper
adjustment must be made for expendi-
tures, receipts, losses, or other items prop-
erly chargeable to capital account. Section
13521 of the TCJA amended § 1016(a) to
provide that, in determining the basis of a
life insurance contract or an annuity con-
tract, no adjustment is made for mortality,
expense, or other reasonable charges in-
curred under the contract. See § 1016(a)
(1)(B). This amendment is effective for
transactions entered into on or after Au-
gust 26, 2009 (the effective date of Rev.
Rul. 2009-13 with respect to Situations 2
and 3).
Rev. Rul. 2009-13 and Rev. Rul. 2009-
14 apply § 1016 (prior to its amendment
by the TCJA) to determine the adjusted
basis of life insurance contracts under
§§ 1011 and 1012 in several factual sit-
uations.
In Situation 2 of Rev. Rul. 2009-13, A,
an individual, entered into a life insurance
contract with cash value on January 1 of
Year 1. Under the contract, A was the in-
sured, and the named beneficiary was a
member of A’s family. On June 15 of Year
8, A sold the contract to B, an unrelated
person who would suffer no economic loss
upon A’s death, for $80,000. Prior to the
sale of the contract, A had paid $64,000 in
premiums. The cost of insurance charges
collected by the issuer was $10,000 as of
the date of the sale. Situation 2 of Rev.
Rul. 2009-13 provides that if a taxpayer
holds a life insurance contract for purpos-
es of insurance protection, it is necessary
to reduce the taxpayer’s basis in the con-
tract by that portion of the premium paid
for the contract that was expended for the
provision of insurance before the sale in
order to measure the taxpayer’s gain upon
the sale of the contract. Therefore, Situa-
tion 2 of Rev. Rul. 2009-13 provides that
A must reduce A’s basis in the contract
by the cost of insurance. As a result, A’s

Bulletin No. 2020–9 455 February 24, 2020
adjusted basis as of the date of the sale
was $54,000 ($64,000 premiums paid less
$10,000 expended as cost of insurance).
Because A sold the contract for $80,000,
Rev. Rul. 2009-13 holds with respect to
Situation 2 that A must recognize $26,000
of income on the sale of the contract
($80,000 amount realized less $54,000
adjusted basis of the contract).
In Situation 3 of Rev. Rul. 2009-13, the
contract was a level premium fifteen-year
term life insurance contract without cash
surrender value. The monthly premium
for the term life insurance contract was
$500, A held the contract for 89.5 months,
and A paid premiums totaling $45,000 as
of the date of the sale. A sold the contract
for $20,000 to B, an unrelated person
who would suffer no economic loss upon
A’s death. Situation 3 of Rev. Rul. 2009-
13 provides that A must reduce A’s basis
in the contract by the cost of insurance,
which is presumed to equal the monthly
premiums under the contract. A’s adjust-
ed basis in the contract as of the date of
the sale was therefore $250 ($45,000 total
premiums paid less $44,750 cost of insur-
ance protection). Because A sold the con-
tract for $20,000, Rev. Rul. 2009-13 holds
with respect to Situation 3 that A must rec-
ognize $19,750 of income on the sale of
the term life insurance contract ($20,000
amount realized on the sale less $250 ad-
justed basis of the contract).
In Situation 2 of Rev. Rul. 2009-14, the
facts are the same as in Situation 3 of Rev.
Rul. 2009-13, except that B purchased the
contract for $20,000 from A and then, at
the end of the following year, sold the con-
tract to C, a person unrelated to either A or
B, for $30,000. Before selling the contract,
B paid a total of $9,000 in premiums. In
Situation 2 of Rev. Rul. 2009-14, B, un-
like A in Situation 3 of Rev. Rul. 2009-13,
was not required to reduce B’s basis by the
cost of insurance because B was wholly
unrelated to the insured, did not purchase
the life insurance contract for protection
against economic loss upon the insured’s
death, purchased the contract solely with
a view to profit, and enjoyed no insurance
protection from the contract. B’s cost ba-
sis was $29,000, the sum of what B paid
for the contract and the premiums B paid
to keep the contract in force ($20,000 pur-
chase price plus $9,000 in premiums). B’s
adjusted basis was $29,000 ($29,000 cost
basis with no adjustment for cost of insur-
ance), and B recognized $1,000 of income
on the sale of the contract to C ($30,000
amount realized on sale less $29,000 ad-
justed basis of the contract).
The analysis and holdings relating to
A’s adjusted basis in the contract in Sit-
uations 2 and 3 in Rev. Rul. 2009-13 and
the analysis relating to B’s adjusted ba-
sis in the contract in Situation 2 in Rev.
Rul. 2009-14 are inconsistent with the
language of § 1016(a)(1)(B), added to
the Code by the TCJA. Under § 1016(a)
(1)(B), the cost basis of a life insurance
contract is not reduced by the cost of in-
surance, regardless of why the contract is
purchased. Rev. Rul. 2009-13 and Rev.
Rul. 2009-14 are therefore modified to the
extent they are inconsistent with the rule
set forth in § 1016(a)(1)(B).
In Situations 2 and 3 in Rev. Rul. 2009-
13, under § 1016(a)(1)(B), as added by the
TCJA, A is not required to reduce A’s ba-
sis in the contract by the cost of insurance.
Accordingly, in Situation 2 of Rev. Rul.
2009-13, A’s adjusted basis in the contract
equals the premiums paid. A must recog-
nize $16,000 of income on the sale of the
contract ($80,000 amount realized on sale
less $64,000 adjusted basis). In Situation
3 of Rev. Rul. 2009-13, A’s adjusted basis
in the contract equals the premiums paid.
A will recognize a $25,000 loss on the sale
of the contract ($20,000 amount realized
on the sale less $45,000 adjusted basis).
A will not be permitted to deduct the loss
unless the loss is incurred under § 165(c)
(1) or (2).
In Situation 2 of Rev. Rul. 2009-14, B
is not required to reduce B’s basis in the
contract by the cost of insurance because
B was wholly unrelated to the insured,
did not purchase the life insurance con-
tract for protection against economic loss
upon the insured’s death, purchased the
contract solely with a view to profit, and
enjoyed no insurance protection from
the contract. Under § 1016(a)(1)(B), as
added by the TCJA, B is not required to
reduce B’s basis in the contract by the
cost of insurance, regardless of why the
insurance contract is purchased. Accord-
ingly, the outcome for B in Situation 2 of
Rev. Rul. 2009-14 does not change, but
B’s situation is no longer distinguishable
from that of A in Situation 3 of Rev. Rul.
2009-13 with regards to the treatment of
cost of insurance charges.
HOLDINGS
1. In Situation 2 of Rev. Rul. 2009-13,
A recognizes $16,000 of income upon
the sale of the life insurance contract, of
which $14,000 is ordinary income, and
$2,000 is long-term capital gain.
2
2. In Situation 3 of Rev. Rul. 2009-13,
A recognizes a long-term capital loss of
$25,000 upon the sale of the life insurance
contract.
3. In Situation 2 of Rev. Rul. 2009-14,
B recognizes $1,000 of long-term capital
gain upon the sale of the life insurance
contract.
EFFECT ON OTHER DOCUMENTS
This revenue ruling modifies Rev. Rul.
2009-13 and Rev. Rul. 2009-14.
EFFECTIVE DATE
Consistent with the effective date of
the TCJA amendment to § 1016(a), this
revenue ruling is effective for transactions
entered into on or after August 26, 2009.
See § 7805(b)(8). A change in the internal
revenue laws that is made retroactive to
earlier taxable years does not automatical-
ly permit a claim for a refund for such a
year when the claim is barred by the pe-
riod of limitations. See United States v.
Zacks, 375 U.S. 59 (1963). Congress did
not amend the statute of limitations set
forth in § 6511 or otherwise express an in-
tent to waive or extend the period of lim-
itations for the retroactive change made to
§ 1016(a) by section 13521 of the TCJA.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Megan McGuire of the Office of
the Associate Chief Counsel (Financial
Institutions and Products). For further in-
formation regarding this revenue ruling,
contact Ms. McGuire at (202) 317-6995
(not a toll-free number).
2
Section 13521 of the TCJA only applies to determine a taxpayer’s adjusted basis in a life insurance contract under § 1016. Section 13521 of the TCJA does not affect the analysis in Situa-
tions 2 and 3 of Rev. Rul. 2009-13 and Situation 2 of Rev. Rul. 2009-14 with respect to the character of any income or loss recognized by a taxpayer on the sale of a life insurance contract.

Bulletin No. 2020–9 i February 24, 2020
Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior 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).
Clarified is 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 rul-
ing is being changed.
Distinguished describes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modified is used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified and clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transactions.
This term is most commonly used in a ruling
that lists previously published rulings that
are obsoleted because of changes in laws or
regulations. A ruling may also be obsoleted
because the substance has been included in
regulations subsequently adopted.
Revoked describes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a
period of time in separate rulings. If the
new ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example, modified and
superseded describes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previous-
ly published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspended is used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of cas-
es in litigation, or the outcome of a Ser-
vice study.
Abbreviations
The following abbreviations in current use
and formerly used will appear in material
published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.

February 24, 2020 ii Bulletin No. 2020–9
Numerical Finding List
1
Bulletin 2020–9
Announcements:
2020-1, 2020-5 I.R.B. 552
Notices:
2020-1, 2020-2 I.R.B. 290
2020-2, 2020-3 I.R.B. 327
2020-3, 2020-3 I.R.B. 330
2020-4, 2020-4 I.R.B. 380
2020-5, 2020-4 I.R.B. 380
2020-6, 2020-7 I.R.B. 411
2020-7, 2020-7 I.R.B. 411
2020-8, 2020-7 I.R.B. 415
2020-9, 2020-7 I.R.B. 417
Proposed Regulations:
REG-107431-19, 2020-3 I.R.B. 332
REG-122180-18, 2020-3 I.R.B. 342
REG-100956-19, 2020-4 I.R.B. 383
REG-125710-18, 2020-5 I.R.B. 554
Revenue Procedures:
2020-1, 2020-01 I.R.B. 1
2020-2, 2020-01 I.R.B. 107
2020-3, 2020-01 I.R.B. 131
2020-4, 2020-01 I.R.B. 148
2020-5, 2020-01 I.R.B. 241
2020-7, 2020-01 I.R.B. 281
2020-9, 2020-02 I.R.B. 294
2020-10, 2020-02 I.R.B. 295
2020-11, 2020-06 I.R.B. 406
2020-8, 2020-08 I.R.B. 447
Revenue Rulings:
2020-1, 2020-3 I.R.B. 296
2020-2, 2020-3 I.R.B. 298
2020-3, 2020-3 I.R.B. 409
2020-4, 2020-4 I.R.B. 444
2020-5, 2020-5 I.R.B. 454
Treasury Decisions:
9886, 2020-2 I.R.B. 285
9887, 2020-3 I.R.B. 302
9888, 2020-3 I.R.B. 306
9891, 2020-8 I.R.B. 419
9892, 2020-8 I.R.B. 439
9893, 2020-9 I.R.B. 449
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2018–27 through 2018–52 is in Internal Revenue Bulletin
2018–52, dated December 27, 2018.

Bulletin No. 2020–9 iii February 24, 2020
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2020–9
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2018–27 through 2018–52 is in Internal Revenue Bulletin
2018–52, dated December 27, 2018.

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