Internal Revenue Bulletin 2010-14 (PDF rendition): IRS Announcements

Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.

Bulletin No. 201
0-14
April 5, 2010
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. 2010–11, page 516.
Federal rates; adjusted federal rates; adjusted federal
long-term rate and the long-term exempt rate.For pur-
poses of sections 382, 642, 1274, 1288, and other sections
of the Code, tables set forth the rates for April 2010.
Notice 2010–17, page 519.
This notice provides the face amount of qualified school con-
struction bonds (QSCBs) allocated by the Department of the
Treasury to each state and large local education agency for
2010 under section 54F(d) of the Code. This notice does not
contain any other guidance. Notice 2009–35 supplemented.
Notice 2010–18, page 525.
This notice provides guidance to assist state housing credit
agencies in determining how to reduce the state housing credit
ceiling under section 42(h)(3) of the Code when credits are ex-
changed for funds under section 1602 of the American Re-
covery and Reinvestment Tax Act of 2009, including guidance
concerning the effect of section 1602 funds on building basis
and taxpayer income.
Notice 2010–25, page 527.
This notice provides taxpayers with interim guidance on mea-
surement of continuity of interest of reorganizations during the
period between expiration of the current temporary regulations
and the issuance of new regulations.
Notice 2010–26, page 527.
Chile earthquake in 2010.This notice designates the Chile
earthquake occurring in February 2010 as a qualified disaster
for purposes of section 139 of the Code.
EXEMPT ORGANIZATIONS
Announcement 2010–19, page 529.
This announcement provides procedures that a charitable trust
may use to request a ruling that it was and continues to be a
Type III supporting organization described in section 509(a)(3)
of the Code and to obtain a refund of any section 4940 tax paid
with respect to its 2008 taxable year.
ADMINISTRATIVE
Rev. Proc. 2010–20, page 528.
Nonshareholder contribution to capital under section
118(a).This procedure provides that the Service will not
challenge a corporation’s treatment of a Smart Grid Investment
Grant made by the Department of Energy to the corporation as
a nonshareholder contribution to the capital of the corporation
under section 118(a) of the Code if the corporation properly
reduces the basis of its property under section 362(c)(2) and
the regulations thereunder.
Actions Relating to Court Decisions is on the page following the Introduction.
Finding Lists begin on page ii.

The IRS Mission
Provide Americ
a’s taxpayers top quality service by helping them
understand an
d meet their tax responsibilities and by applying
the tax law with
integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, legislation, court decisions, and other items of general
interest. It is published weekly and may be obtained from the
Superintendent of Documents on a subscription basis. Bulletin
contents are compiled semiannually into Cumulative Bulletins,
which are sold on a single-copy basis.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application of
the tax laws, including all rulings that supersede, revoke, mod-
ify, or amend any of those previously published in the Bulletin.
All published rulings apply retroactively unless otherwise indi-
cated. Procedures relating solely to matters of internal man-
agement are not published; however, statements of internal
practices and procedures that affect the rights and duties of
taxpayers are published.
Revenue rulings represent the conclusions of the Service on the
application of the law to the pivotal facts stated in the revenue
ruling. In those based on positions taken in rulings to taxpayers
or technical advice to Service field offices, identifying details
and information of a confidential nature are deleted to prevent
unwarranted invasions of privacy and to comply with statutory
requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—19
86 Code.
This part i
ncludes rulings and decisions based on provisions of
the Intern
al Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B, Leg-
islation and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Secre-
tary (Enforcement).
Part IV
.—Items of General Interest.
This par
t includes notices of proposed rulemakings, disbar-
ment an
d suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index
for the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The c
ontents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
For sale by the Superintendent of Documents, U.S.Government Printing Office, Washington, DC 20402.
April 5, 20102010–14 I.R.B.

Actions Relati
ng to Decisions of the Tax Court
It is the policy
of the Internal Rev-
enue Service t
o announce at an early date
whether it wil
l follow the holdings in cer-
tain cases. An
Action on Decision is the
document maki
ng such an announcement.
An Action on De
cision will be issued at
the discreti
on of the Service only on unap-
pealed issue
s decided adverse to the gov-
ernment. Gen
erally, an Action on Decision
is issued whe
re its guidance would be help-
ful to Servi
ce personnel working with the
same or simi
lar issues. Unlike a Treasury
Regulation
or a Revenue Ruling, an Action
on Decision
is not an affirmative statement
of Service
position. It is not intended to
serve as pu
blic guidance and may not be
cited as pr
ecedent.
Actions on
Decisions shall be relied
upon withi
n the Service only as conclu-
sions appl
ying the law to the facts in the
particul
ar case at the time the Action on
Decision
was issued. Caution should be
exercise
d in extending the recommenda-
tion of th
e Action on Decision to similar
cases whe
re the facts are different. More-
over, th
e recommendation in the Action on
Decisio
n may be superseded by new legis-
lation,
regulations, rulings, cases, or Ac-
tions on
Decisions.
Prior to 1991, t
he Service published
acquiescence
or nonacquiescence only in
certain regul
ar Tax Court opinions. The
Service has ex
panded its acquiescence
program to inc
lude other civil tax cases
where guidanc
e is determined to be help-
ful. Accordi
ngly, the Service now may
acquiesce or
nonacquiesce in the holdings
of memorandu
m Tax Court opinions, as
well as those
of the United States District
Courts, Cla
ims Court, and Circuit Courts
of Appeal. R
egardless of the court decid-
ing the case
, the recommendation of any
ActiononDe
cision will be published in
the Intern
al Revenue Bulletin.
The recomme
ndation in every Action
on Decisio
n will be summarized as ac-
quiescenc
e, acquiescence in result only,
or nonacqu
iescence. Both “acquiescence”
and “acqui
escence in result only” mean
that the S
ervice accepts the holding of
the court
in a case and that the Service
will foll
ow it in disposing of cases with
thesamec
ontrolling facts. However, “ac-
quiescen
ce” indicates neither approval
nor disa
pproval of the reasons assigned
by the co
urt for its conclusions; whereas,
“acquie
scence in result only” indicates
disagre
ement or concern with some or all
of those reason
s. “Nonacquiescence” sig-
nifies that, a
lthough no further review was
sought, the Se
rvice does not agree with
the holding of
the court and, generally,
will not follo
w the decision in disposing
of cases invol
ving other taxpayers. In
reference to
an opinion of a circuit court
of appeals, a
“nonacquiescence” indicates
that the Serv
ice will not follow the hold-
ingonanatio
nwide basis. However, the
Service wil
l recognize the precedential
impact of th
e opinion on cases arising
within the v
enue of the deciding circuit.
The Actions
on Decisions published in
the weekly I
nternal Revenue Bulletin are
consolidat
ed semiannually and appear in
the first B
ulletin for July and the Cumula-
tive Bulle
tin for the first half of the year. A
semiannua
l consolidation also appears in
the first B
ulletin for the following January
andinthe
Cumulative Bulletin for the last
half of th
e year.
The Commi
ssioner ACQUIECES in re-
sult only
in the following decision:
James R.
Thompson v.
United S
tates,
1
87 Fed. C
l. 728 (Fed. Cl. 2009)
1
Acquiesces in result only relating to whether an interest in a limited liability company (LLC) is a limited partnership interest as defined under section 1.469–5T(e)(3).
2010–14 I.R.B.April 5, 2010

April 5, 20102010–14 I.R.B.

Part I. Rulings
and Decisions Under the Internal Revenue Code
of 1986
Section 42.—L
ow-Income
Housing Credi
t
The adjusted a
pplicable federal short-term, mid-
term, and long
-term rates are set forth for the month
of April 2010.
See Rev. Rul. 2010-11, page 516.
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term rates
are set forth for the month of April 2010. See Rev.
Rul. 2010-11, page 516.
Section 382.—Limitation
on Net Operating Loss
Carryforwa
rds and Certain
Built-In Losses Following
Ownership Change
The adjusted applicable federal long-term rate is
set forth for the month of April 2010. See Rev. Rul.
2010-11, page 516.
Section 412.—Minimum
Funding Standards
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of April 2010. See Rev. Rul. 2010-11, page 516.
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 April 2010. See Rev. Rul. 2010-11, page 516.
Section 468.—Special
Rules for Mining and Solid
Waste
Reclamation and
Closi
ng Costs
The ad
justed applicable federal short-term, mid-
term,
and long-term rates are set forth for the month
of Apr
il 2010. See Rev. Rul. 2010-11, page 516.
Section 482.—
Allocation
of Income and D
eductions
Among Taxpaye
rs
Federal short
-term, mid-term, and long-term rates
are set forth f
or the month of April 2010. See Rev.
Rul. 2010-11
, page 516.
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 April 2010. See Rev. Rul. 2010-11, page 516.
Section 642.—Special
Rules for Credits and
Deductions
Federal short-term, mid-term, and long-term rates
are set forth for the month of April 2010. See Rev.
Rul. 2010-11, page 516.
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 April 2010. See Rev. Rul. 2010-11, page 516.
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 April 2010. See Rev. Rul. 2010-11, page 516.
Section 1274.—Determi-
nation of Issue Price in the
Case of Certain Debt Instru-
ments Issued for Property
(Also Sections 42, 280G, 382, 412, 467, 468, 482,
483, 642, 807, 846, 1288, 7520, 7872.)
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 th
e Code, tables set forth the
rates for Apri
l 2010.
Rev. Rul. 2010
–11
This revenue
ruling provides various
prescribed r
ates for federal income tax pur-
poses for Apr
il 2010 (the current month).
Table 1 conta
ins the short-term, mid-term,
and long-ter
m applicable federal rates
(AFR) for th
e current month for purposes
of section 1
274(d) of the Internal Revenue
Code. Table
2 contains the short-term,
mid-term, a
nd long-term adjusted appli-
cable fede
ral rates (adjusted AFR) for
the curren
t month for purposes of section
1288(b). T
able 3 sets forth the adjusted
federal lo
ng-term rate and the long-term
tax-exem
pt rate described in section
382(f). T
able 4 contains the appropriate
percenta
ges for determining the low-in-
come hous
ing credit described in section
42(b)(1)
for buildings placed in service
during t
he current month. However, under
section
42(b)(2), the applicable percentage
for non-
federally subsidized new build-
ings pla
ced in service after July 30, 2008,
and befo
re December 31, 2013, shall not
be less
than 9%. Finally, Table 5 contains
the fed
eral rate for determining the present
value o
f an annuity, an interest for life
or for a
term of years, or a remainder or
a rever
sionary interest for purposes of
secti
on 7520.
2010–14 I.R.B.516April 5, 2010

REV. RUL. 2010–11 TABLE 1
Applicable Federal Rates (AFR) for April 2010
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
AFR.67%.67%.67%.67%
110% AFR.74%.74%.74%.74%
120% AFR.80%.80%.80%.80%
130% AFR.87%.87%.87%.87%
Mid-term
AFR2.70%2.68%2.67%2.67%
110% AFR2.97%
2.95%
2.94%2.93%
120% AFR
3.25%
3.22%3.21%3.20%
130% AFR
3.51%
3.48%3.46%3.46%
150% AFR
4.06%4.02%4.00%3.99%
175% AFR
4.74%4.69%4.66%4.64%
Long-term
AFR4.40%
4.35%
4.33%4.31%
110% AFR
4.85%
4.79%4.76%4.74%
120% AFR
5.29%5.22%5.19%5.16%
130% AFR
5.74%5.66%5.62%5.59%
REV. RUL. 2010–11 TABLE 2
Adjusted AFR for April 2010
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term adjusted
AFR
.53%.53%.53%.53%
Mid-term adjusted AFR1.68%1.67%1.67%1.66%
Long-term adjusted
AFR
3.95%
3.91%3.89%3.88%
REV. RUL. 2010–11 TABLE 3
Rates Under Section 382 for April 2010
Adjusted federal long-term rate for the current month
3.95%
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.)4.03%
REV. RUL. 2010–11 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for April 2010
Note: Under Section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after
July 30, 2008, and before December 31, 2013, shall not be less than 9%.
Appropriate percentage for the 70%present value low-income hou
sing credit
7.82%
Appropriate percentage for the 30% present value low-income housing credit
3.35%
April 5, 20105172010–14 I.R.B.

REV. RUL. 2010–11 TABLE 5
Rate Under Section 7520 for April 2010
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 interest3.2%
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 April 2010. See Rev. Rul. 2010-11, page 516.
Section 7520.—Valuation
Tables
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of April 2010. See Rev. Rul. 2010-11, page 516.
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 April 2010. See Rev. Rul. 2010-11, page 516.
2010–14 I.R.B.518April 5, 2010

Part III. Administrative, Procedural, and Miscellaneous
Qualified School Construction
Bond Allocations for 2010
Notice 2010–17
SECTION 1. PURPOSE
This notice sets forth the maximum
face amount of qualified school construc-
tion bonds (“QSCBs”) allocated by the
Department of the Treasury (Treasury)
to each State and large local educational
agency for 2010 under § 54F(d) of the
Internal Revenue Code (Code). For this
purpose, § 54A(e)(3) provides that the
term “State” includes the District of Co-
lumbia and any possession of the United
States. This notice supplements Notice
2009–35, 2009–17 I.R.B. 876 (April 27,
2009).
SECTION 2. BACKGROUND
.01 INTRODUCTION
Section 1521(a) of Title I of Division B
of the American Recovery and Reinvest-
ment Act of 2009, Pub. L. No. 111–5, 123
Stat. 115 (2009) (“Act”) added new § 54F
to the Code, setting forth program provi-
sions for QSCBs.
Section 54F(a) defines a “qualified
school construction bond” to mean any
bond issued as part of an issue if —
(1) 100 percent of the available project
proceeds of such issue are to be used for
the construction, rehabilitation, or repair of
a public school facility or for the acquisi-
tion of land on which such a facility is to
be constructed with part of the proceeds of
such issue,
(2) the bond is issued by a State or lo-
cal government within the jurisdiction of
which such school is located, and
(3) the issuer designates such bond for
purposes of this section.
Section 54F(c) provides a national bond
limitation authorization for QSCBs of $11
billion for 2009 and $11 billion for 2010
(each, a “calendar year volume cap” and
together “volume cap”). Section 54F(c)(3)
provides that except for carryforwards pro-
vided for in § 54F(e), there is no calendar
year volume cap for calendar years after
2010.
Section 54F(b) provides that the maxi-
mum aggregate face amount of bonds is-
sued during any calendar year that may be
designated under § 54F(a) by any issuer
shall not exceed the portion of the calen-
dar year volume cap allocated to such is-
suer for the calendar year under § 54F(d).
Section 54F(d)(1) provides that, except
as provided in § 54F(d)(2)(C), the calendar
year volume cap shall be allocated by the
Treasury among the States in proportion to
the respective amounts each State is eligi-
ble to receive under § 1124 of the Elemen-
tary and Secondary Education Act of 1965
(20 U.S.C. 6333) (the “Education Act”) for
the most recent fiscal year ending before
the calendar year. Section 54F(d)(1) fur-
ther provides that the calendar year vol-
ume cap amount allocated to each State is
to be further allocated by the State to is-
suers within the State.
Section 54F(d)(2)(A) provides that 40
percent of the calendar year volume cap for
any calendar year is to be allocated under
§ 54F(d)(2)(B) by the Treasury among lo-
cal educational agencies that are large lo-
cal agencies for the calendar year. Sec-
tion 54F(d)(2)(B) provides that 40 percent
of the calendar year volume cap is to be
allocated among large local educational
agencies in proportion to the respective
amounts each such agency received under
§ 1124 of the Education Act for the most
recent fiscal year ending before the calen-
dar year.
Section 54F(d)(2)(C) provides that the
allocation of calendar year volume cap to
any State under § 54F(d)(1) is reduced by
the aggregate amount of allocations un-
der § 54F(d)(2) to large local educational
agencies within the State.
Section 54F(d)(2)(E) defines a large lo-
cal educational agency as any local educa-
tional agency if such agency is: (1) among
the one hundred local educational agencies
with the largest number of children aged 5
through 17 from families living below the
poverty level, as determined by the Trea-
sury using the most recent data available
from the Department of Commerce that are
satisfactory to the Treasury; or (2) one of
not more than twenty-five additional lo-
cal educational agencies that the Secre-
tary of Education determines (based on the
most recent data available satisfactory to
the Treasury) are in particular need of as-
sistance, based on a low level of resources
for school construction, a high level of en-
rollment growth, or such other factors as
the Treasury deems appropriate.
Section 54F(d)(3)provides that the
amount allocated under § 54F(d)(1) to any
United States possession other than Puerto
Rico is an amount that would have been
allocated to such possession if all alloca-
tions under § 54F(d)(1) were made on the
basis of respective populations of individ-
uals below the poverty line (as defined by
the Office of Management and Budget).
Section 54F(d)(3) further provides that in
making the other allocations, the amount
to be allocated under§ 54F(d)(1) to the
States is reduced by the aggregate amount
allocated under § 54F(d)(3) to the United
States possessions.
Section 54F(d)(4) provides for addi-
tional calendar year volume cap amounts
of $200 million for calendar year 2009
and $200 million for calendar year 2010
(each an “Indian tribal government cal-
endar year volume cap” and together the
“Indian tribal government volume cap”)
to be allocated by the Secretary of Interior
for purposes of the construction, rehabil-
itation, and repair of schools funded by
the Bureau of Indian Affairs. This $200
million Indian tribal government calendar
year volume cap allocated to the Indian
tribal governments does not reduce the $11
billion calendar year volume cap allocated
to the States and the large local educa-
tional agencies. Section 54F(d)(4) further
provides that, for amounts of Indian tribal
government volume cap allocated, In-
dian tribal governments (as defined in
§ 7701(a)(40)) are tobe treated as quali-
fied issuers.
SECTION 3. 2010 ALLOCATIONS
OF NATIONAL BOND VOLUME
CAP FOR QSCBs
The 2010 national bond volume cap for
QSCBs is $11 billion. This amount is allo-
cated among the States and large local edu-
cational agencies as set forth in this notice.
The 2010 allocations to 103 large local ed-
ucational agencies reflects the determina-
tion by the Secretary of Education to select
3 additional large local educational agen-
cies under § 54F(d)(2)(E)(ii) for such year.
The first chart below allocates $6.6 billion
of the $11 billion 2010 calendar year vol-
April 5, 20105192010–14 I.R.B.

ume cap for QSCBs to States to be issued
by such State or further allocated to the is-
suers within such State. The second chart
below allocates $4.4 billion of the $11 bil-
lion 2010 calendar year volume cap for
QSCBs to large local educational agencies.
2010 Allocations to States of Volume Cap for
Qualified School Construction Bonds
(Net of Allocations to Large Local Educational Agencies)
State/Territory
Total
Allocation by
State/ Territory
Alabama
140,453,000
Alaska28,163,000
Arizona
171,115,000
Arkansas124,197,000
California
720,058,000
Colorado
95,686,000
Connecticut98,431,000
Delaware29,797,000
District of Columbia0
Florida81,038,000
Georgia234,431,000
Hawaii0
Idaho39,379,000
Illinois
251,167,000
Indiana
182,583,000
Iowa66,422,000
Kansas82,984,000
Kentucky138,870,000
Louisiana
140,525,000
Maine41,368,000
Maryland
45,190,000
Massachusetts
157,361,000
Michigan297,611,000
Minnesota80,649,000
Mississippi134,610,000
Missouri146,348,000
Montana31,838,000
Nebraska
35,294,000
Nevada
5,157,000
New Hampshire29,797,000
New Jersey
215,904,000
New Mexico62,037,000
2010–14 I.R.B.520April 5, 2010

2010 Allocations to States of Volume Cap for
Qualified School Construction Bonds
(Net of Allocations to Large Local Educational Agencies)
State/Territory
Total
Allocation by
State/ Territory
New York178,782,000
North Carolina
188,591,000
North Dakota
25,974,000
Ohio293,763,000
Oklahoma91,217,000
Oregon109,096,000
Pennsylvania286,677,000
Rhode Island41,296,000
South Carolina
129,456,000
South Dakota29,797,000
Tennessee119,131,000
Texas
547,674,000
Utah
55,599,000
Vermont24,236,000
Virginia172,249,000
Washington162,837,000
West Virginia72,262,000
Wisconsin
100,459,000
Wyoming
24,589,000
American Samoa10,614,000
Guam10,838,000
Northern Marianas6,824,000
Puerto Rico0
Virgin Islands
9,576,000
Total6,600,000,000
2010 Allocations to Large Local Educational Agencies of Volume Cap for
Qualified School Construction Bonds
StateLarge Local Educational AgencyAllocation
AlabamaBirmingham City School District14,274,000
AlabamaMobile County School District
25,419,000
April 5, 20105212010–14 I.R.B.

2010 Allocations to Large Local Educational Agencies of Volume Cap for
Qualified School Construction Bonds
StateLarge Local Educational AgencyAllocation
ArizonaMesa Unified District19,466,000
ArizonaPhoenix Union High School District
12,514,000
ArizonaTucson Unified District20,018,000
CaliforniaBakersfield City Elementary
15,102,000
CaliforniaCompton Unified16,893,000
CaliforniaFresno Unified39,773,000
CaliforniaLong Beach Unified
34,501,000
CaliforniaLos Angeles Unified290,180,000
CaliforniaOakland Unified23,960,000
CaliforniaSacramento City Unified19,342,000
CaliforniaSan Bernardino City Unified
25,294,000
CaliforniaSan Diego City Unified36,093,000
CaliforniaSan Francisco Unified
12,957,000
CaliforniaSanta Ana Unified
17,539,000
CaliforniaStockton City Unified14,934,000
ColoradoDenver County 129,262,000
District of ColumbiaDistrict of Columbia Public Schools32,947,000
FloridaBrevard County School District12,271,000
FloridaBroward County School District
51,646,000
FloridaDade County School District
95,438,000
FloridaDuval County School District33,074,000
FloridaHillsborough County School District
37,935,000
FloridaLee County School District14,308,000
FloridaMarion County School District
11,253,000
FloridaOrange County School District36,229,000
FloridaPalm Beach County School District34,023,000
FloridaPasco County School District13,627,000
FloridaPinellas County School District
23,529,000
FloridaPolk County School District21,223,000
FloridaVolusia County School District17,796,000
GeorgiaAtlanta City School District
34,526,000
GeorgiaClayton County School District
15,166,000
GeorgiaDe Kalb County School District29,940,000
GeorgiaFulton County School District17,917,000
GeorgiaGwinnett County School District19,640,000
GeorgiaRichmond County School District
15,979,000
2010–14 I.R.B.522April 5, 2010

2010 Allocations to Large Local Educational Agencies of Volume Cap for
Qualified School Construction Bonds
StateLarge Local Educational AgencyAllocation
HawaiiHawaii Department of Education29,797,000
IllinoisCity of Chicago School District 299
257,127,000
IndianaIndianapolis Public Schools
31,534,000
KentuckyJefferson County School District
30,352,000
LouisianaCaddo Parish School Board20,707,000
LouisianaEast Baton Rouge Parish School Board
21,675,000
LouisianaJefferson Parish School Board21,891,000
LouisianaOrleans Parish School Board
40,055,000
MarylandBaltimore City Public School System
53,530,000
MarylandBaltimore County Public Schools
19,952,000
MarylandPrince George’s County Public Schools
25,803,000
MassachusettsBoston41,474,000
MichiganDetroit City School District127,644,000
MinnesotaMinneapolis19,787,000
MinnesotaSt. Paul
18,253,000
MississippiJackson Public School District
15,429,000
MissouriKansas City School District16,274,000
MissouriSt. Louis City28,481,000
NebraskaOmaha Public Schools18,922,000
NevadaClark County School District
58,833,000
New JerseyNewark City
25,753,000
New MexicoAlbuquerque Public Schools
25,025,000
New YorkBuffalo City School District
33,025,000
New YorkNew York City664,010,000
New YorkRochester City School District28,376,000
North CarolinaCharlotte-Mecklenburg Schools
25,051,000
North CarolinaCumberland County Schools
14,805,000
North CarolinaForsyth County Schools14,162,000
North CarolinaGuilford County Schools16,843,000
North CarolinaWake County Schools17,606,000
OhioCincinnati City School District
25,922,000
OhioCleveland Municipal School District
51,058,000
OhioColumbus City School District39,266,000
OhioToledo City School District20,962,000
OklahomaOklahoma City18,167,000
OklahomaTulsa
15,625,000
April 5, 20105232010–14 I.R.B.

2010 Allocations to Large Local Educational Agencies of Volume Cap for
Qualified School Construction Bonds
StateLarge Local Educational AgencyAllocation
PennsylvaniaPhiladelphia City School District
145,352,000
PennsylvaniaPittsburgh School District
19,520,000
Puerto RicoPuerto Rico Department of Education380,394,000
South CarolinaCharleston County School District
15,076,000
South CarolinaGreenville County School District14,302,000
TennesseeKnox County School District11,979,000
TennesseeMemphis City School District49,710,000
TennesseeNashville-Davidson County School District24,016,000
TexasAldine Independent School District19,022,000
TexasAlief Independent School District16,483,000
TexasArlington Independent School District
13,656,000
TexasAustin Independent School District24,078,000
TexasBrownsville Independent School District
25,901,000
TexasDallas Independent School District
69,599,000
TexasEdinburg Consolidated Independent School District13,967,000
TexasEl Paso Independent School District29,140,000
TexasFort Worth Independent School District28,764,000
TexasGarland Independent School District12,488,000
TexasHouston Independent School District
95,370,000
TexasLa Joya Independent School District
13,544,000
TexasLaredo Independent School District
14,165,000
TexasNorthside Independent School District14,641,000
TexasPasadena Independent School District14,609,000
TexasPharr-San Juan-Alamo Independent School District
13,453,000
TexasSan Antonio Independent School District30,730,000
TexasYsleta Independent School District17,869,000
VirginiaNorfolk City Public Schools
15,092,000
VirginiaRichmond City Public Schools14,983,000
WisconsinMilwaukee72,933,000
Total4,400,000,000
SECTION 4. EFFECTIVE DATE OF
2010 ALLOCATIONS OF NATIONAL
BOND VOLUME CAP
The allocations of the national bond
volume cap for QSCBs in Section 3 are ef-
fective for QSCBs issued, pursuant to an
allocation of 2010 calendar year volume
cap, after March 16, 2010.
SECTION 5. ALLOCATION OF THE
INDIAN TRIBAL GOVERNMENT
VOLUME CAP
The Department of the Interior is
exclusively responsible for making the
allocations of the Indian tribal govern-
2010–14 I.R.B.524April 5, 2010

ment volume cap and published a no-
tice in the Federal Register, 74 F.R.
56211–02 (October 30, 2009), solicit-
ing applications for allocations of such
volume cap. Interested parties may also
contact John Rever, Director, Office
of Facilities, Environment and Cultural
Resources, Bureau of Indian Affairs, at
(703) 390–6314 orJohn.Rever@bia.gov.
SECTION 6. DRAFTING
INFORMATION
The principal authors of this notice are
Aviva M. Roth and Johanna Som de Cerff
of the Office of Associate Chief Counsel
(Financial Institutions & Products). For
further information regarding this notice,
contact Johanna Som de Cerff at (202)
622–3980 (not a toll-free call).
American Recovery and
Reinvestment Tax Act of 2009
Clarifications
Notice 2010–18
This notice clarifies certain issues un-
der sections 1404 and 1602 of the Amer-
ican Recovery and Reinvestment Tax Act
of 2009 (Pub. L. 111–5) (the Act). Specifi-
cally, this notice provides guidance on how
to take into account the amount of a grant
under section 1602 of the Act in reduc-
ing the amount of a state’s housing credit
ceiling, on the exclusion of the amount of
grants from the recipients’ gross income,
and on the effect of such grants on the de-
preciable or eligible basis of property.
BACKGROUND
Section 42 of the Internal Revenue
Code allows a 10-year tax credit for invest-
ment in qualified low-income buildings
placed in service after December 31, 1986.
Section 42(h)(1) provides, generally, that
the amount of credit under § 42 for any tax-
able year for any building shall not exceed
the housing credit dollar amount allocated
to the building. Section 42(h)(3)(A) pro-
vides, in part, that the aggregate housing
credit dollar amount that a State housing
credit agency may allocate for any cal-
endar year is limited to that year’s State
housing credit ceiling (Ceiling).
Section 42(h)(3)(C) of the Code pro-
vides, in part, that the Ceiling applicable
to any State for any calendar year is an
amount equal to—
(i) the unused Ceiling, if any, of the
State for the preceding calendar year;
(ii) the greater of (I) $1.75 multiplied by
the State population, or (II) $2,000,000;
(iii) the amount of Ceiling returned in
the calendar year, and;
(iv) the amount, if any, allocated to the
State by the Secretary under § 42(h)(3)(D)
from a national pool (National Pool) of
unused credit.
Section 42(h)(3)(H) of the Code pro-
vides that for calendar years after 2002,
the $2,000,000 and $1.75 amounts in
§ 42(h)(3)(C)(ii) shall be increased by a
cost-of-living adjustment (COLA). Sec-
tion 42(h)(3)(I) increases the Ceiling for
2009 by adding (i) $0.20 for the dollar
amount in effect under § 42(h)(3)(C)(ii)(I)
after application of the § 42(h)(3)(H)
COLA, and (ii) an amount equal to 10 per-
cent for the dollar amount in effect under
§ 42(h)(3)(C)(ii)(II) (rounded to the next
lowest multiple of $5,000) after applica-
tion of the § 42(h)(3)(H) COLA. For the
2009 Ceiling, the § 42(h)(3)(C)(ii)(I) and
(II) amounts are $2.30 and $2,665,000, re-
spectively.SeeSection 3.07 of Rev. Proc.
2008–66, 2008–45 I.R.B. 1107, 1111.
Section 42(i)(9)(A) of the Code, as
addedbysection1404oftheAct,pro-
vides that the amounts described in
§ 42(h)(3)(C)(i) through (iv) with respect
to any State for 2009 shall each be reduced
by so much of the amount as is taken into
account in determining the amount of any
grant to the State under section 1602 of
the Act. Section 1602(a) of the Act pro-
vides that the Department of the Treasury
shall make a grant to the housing credit
agency of each State in an amount equal
to the State’s low-income housing grant
election amount. Section 1602(b) of the
Act provides that the term “low-income
housing grant election amount” means,
for any State, the amount as the State may
elect that does not exceed 85 percent of—
(1) the sum of—
(A) 100 percent of the State’s 2009
Ceiling that is attributable to amounts de-
scribed in § 42(h)(3)(C)(i) and (iii) of the
Code, and
(B) 40 percent of the State’s 2009
Ceiling that is attributable to amounts
described in § 42(h)(3)(C)(ii) and (iv),
multiplied by
(2) 10.
On May 4, 2009, the Department of the
Treasury released guidance in the form of
an application (Application) and grantee
terms and conditions (Terms and Condi-
tions) informing designated State housing
credit agencies (Designated Agencies)
how to exchange low-income housing tax
credits for amounts under section 1602 of
the Act. This guidance may be accessed
electronically at:http://www.treas.gov/re-
covery/docs/LIH_application-package.pdf
A list of the Designated Agencies is
provided, and background information
to the Application states, on page 3, that
a Designated Agency is one that files
Form 8610, “Annual Low-Income Housing
Credit Agencies Report,” for all agencies
within the State. Paragraph 2.a. of the
Terms and Conditions provides that the
grantee is the housing credit agency that
files Form 8610. Paragraph 7.a. of the
Terms and Conditions provides that the
grantee shall track (1) the credit equivalent
of all grant election amounts to ensure that
the 2009 Ceiling is appropriately reduced
as required by § 42(i)(9)(A) of the Code
and (2) total grant election amounts to
ensure that these amounts do not exceed
the amount authorizedby section 1602(b)
of the Act. Paragraph 7.b. provides that
the grantee shall track the total of credits
allocated under § 42(h)(1). Paragraph 7.c.
provides that the grantee shall ensure that
the credit equivalent of all elected grant
amounts through 2010, plus the credits
allocated under § 42(h)(1) during 2009,
do not exceed the 2009 Ceiling. The
Terms and Conditions do not explain how
the credit equivalent of a grant election
amount is determined.
Section 42(d)(1) of the Code provides
that the eligible basis of a new building
is its adjusted basis as of the close of the
first tax year of the credit period. Sec-
tion 42(d)(4)(A) provides that, except as
provided in § 42(d)(4)(B) and (C), the ad-
justed basis of any building is determined
without regard to the adjusted basis of any
property that is not residential rental prop-
erty. Section 42(d)(4)(B) provides that the
adjusted basis of any building includes the
adjusted basis of property of a character
subject to the allowance for depreciation
used in common areas or provided as com-
parable amenities to all residential rental
units in the building. Section 42(d)(5)(A)
provides that the eligible basis of a build-
ing shall not include any costs financed
April 5, 20105252010–14 I.R.B.

with the proceeds of a federally funded
grant. Section 42(i)(9)(B), as added by
section 1404 of the Act, provides that the
basis of a qualified building shall not be
reduced by the amount of any grant de-
scribed in § 42(i)(9)(A). The legislative
history to the Act provides that grants re-
ceived under this provision (i.e., cash as-
sistance received under section 1602 of the
Act) do not reduce [the] tax basis of a qual-
ified low-income building. The legisla-
tive history to the Act further provides that
grants under this provision are not taxable
income to recipients. See H.R. Conf. Rep.
No. 16, 111
th
Cong., 1
st
Sess. 532, 533
(2009).
CLARIFICATIONS
1.Credit Equivalent of Cash Assistance
andTrackingunder§42(i)(9)(A)
Section 42(i)(9)(A) of the Code, as
addedbysection1404oftheAct,re-
quires that the amounts in § 42(h)(3)(C)(i)
through (iv) shall each be reduced by so
much of such amount as is taken into ac-
count in determining the amount of any
grant (cash assistance) under section 1602
of the Act. Thus, similar to the way the
Designated Agency tracks allocations of
credit during the course of a calendar
year to ensure that total credits allocated
do not exceed the Ceiling for that year,
§ 42(i)(9)(A) implies a duty (and para-
graph 7 of the grant application Terms and
Conditions imposes a duty) by the Des-
ignated Agency to track credits allocated
and the credit equivalent of cash assis-
tance amounts to ensure that total credits
allocated from the 2009 Ceiling and the
credit equivalent of total cash assistance
amounts do not exceed the 2009 Ceil-
ing. A Designated Agency may determine
the credit equivalent of a cash assistance
amount by dividing the cash assistance
amount by 8.5 and rounding the result up
to the nearest dollar.
For example, in computing the reduc-
tion with respect to the § 42(h)(3)(C)(ii)
component of the Ceiling (and using
an actual figure published by the De-
partment of the Treasury in the List of
Designated Agencies attached to the Ap-
plication), assume that the maximum
cash assistance amount permissible from
the 2009 Ceiling for State X with re-
spect to that component is $9,061,000.
State X is a state whose population qual-
ifies for $2,665,000 in credits under
§ 42(h)(3)(C)(ii)(II), as adjusted for infla-
tion under § 42(h)(3)(H). The Department
of the Treasury determined the maximum
cash assistance amount of $9,061,000
available to State X by multiplying to-
tal available credits of $2,665,000 under
§ 42(h)(3)(C)(ii)(II) by the formula pre-
scribed by section 1602(b) of the Act for
credits under § 42(h)(3)(C)(ii)(II) (i.e.,
0.85 x ([$2,665,000 x 0.4] x 10)). Of this
amount, assume the Designated Agency
of State X elects under section 1602(b)
of the Act a cash assistance amount of
$5 million. The credit equivalent of $5
million is $588,236 (i.e., $5 million/8.5
= $588,235.29, rounded up to the nearest
dollar). For purposes of making the reduc-
tion required by § 42(i)(9)(A) to State X’s
2009 Ceiling, the $2,665,000 in credits
under § 42(h)(3)(C)(ii) must be reduced by
$588,236, the credit equivalent of the $5
million cash assistance amount, not by the
$5 million cash assistance amount. The
$2,076,764 (i.e., $2,665,000 - $588,236)
remaining in credit under § 42(h)(3)(C)(ii)
is available for use in making credit alloca-
tions by the Designated Agency. However,
for purposes of making any future cash
assistance election under section 1602 of
the Act from the § 42(h)(3)(C)(ii) portion
of State X’s 2009 Ceiling, the $9,061,000
maximum cash assistance amountisre-
duced by $5 million to $4,061,000.
The Department of the Treasury may
not, in view of the taxpayer privacy and
disclosure rules under § 6103 of the Code,
publish the maximum cash assistance
amounts from the other components of a
State’s 2009 Ceiling (unlike credits un-
der § 42(h)(3)(C)(ii)). To ensure that
credits allocated and the credit equivalent
of cash assistance amounts from any of
these components of the 2009 Ceiling do
not exceed credits available from those
components, a Designated Agency should
multiply the credit amount used to elect
a cash assistance amount by the percent-
age applicable to that credit amount under
section 1602(b)(1) of the Act, and then
reduce the 2009 Ceiling accordingly.
For example, in computing the reduc-
tion with respect to the § 42(h)(3)(C)(iv)
component of the Ceiling, assume that
the credit amount of that component from
State X’s 2009 Ceiling is $1 million. As-
sume further that in computing the reduc-
tion with respect to the § 42(h)(3)(C)(iii)
component, the credit amount of that com-
ponent from State X’s 2009 Ceiling is $2
million. Of the $1 million in credits under
§ 42(h)(3)(C)(iv), the Designated Agency
of State X elects under section 1602 of the
Act to use $800,000 for a cash assistance
amount. Of the $2 million in credits under
§ 42(h)(3)(C)(iii), the Designated Agency
elects under section 1602 of the Act to use
$1.5 million for a cash assistance amount.
Under section 1602(b)(1)(B) of the
Act, the percentage applicable to credit
amounts under § 42(h)(3)(C)(iv) is 40
percent. The product of $800,000 and
40 percent is $320,000. As required by
§ 42(i)(9)(A), the $1 million of credits
under § 42(h)(3)(C)(iv) is reduced by
$320,000, not $800,000. The remain-
ing $680,000 in credits (i.e., $1 million -
$320,000) under § 42(h)(3)(C)(iv) is avail-
able for use in making credit allocations by
the Designated Agency. However, the $1
million of credit under § 42(h)(3)(C)(iv)is
reduced by $800,000 for purposes of mak-
ing any future elections for cash assistance
under section 1602 of the Act.
Under section 1602(b)(1)(A) of the
Act, the percentage applicable to credit
amounts under § 42(h)(3)(C)(iii) is 100
percent. The product of $1.5 million and
100 percent is $1.5 million. As required
by § 42(i)(9)(A), the $2 million of credits
under § 42(h)(3)(C)(iii) is reduced by $1.5
million, the actual credit amount elected
by the Designated Agency to make a cash
assistance election under section 1602 of
the Act. The remaining $500,000 in cred-
its (i.e., $2 million - $1.5 million) under
§ 42(h)(3)(C)(iii) is available for use in
making credit allocations by the Desig-
nated Agency. Similarly, the $2 million in
credits under § 42(h)(3)(C)(iii)isreduced
by $1.5 million for purposes of making
any future elections for cash assistance
under section 1602 of the Act.
2.Income Tax Treatment of Subawards
Based on the legislative history of the
Act, subawards made pursuant to section
1602(c) of the Act are excluded from the
gross income of recipients and are exempt
from taxation.
3.Basis Treatment of Subawards
Section 42(i)(9)(B) of the Code, as
added by section 1404 of the Act, provides
2010–14 I.R.B.526April 5, 2010

that the basis of a qualified building shall
not be reduced by the amount of any grant
described in § 42(i)(9)(A). The legislative
history to the Act provides that grants
received under this provision (i.e., cash
assistance received under section 1602 of
the Act) do not reduce the tax basis of a
qualified low-income building. By ex-
tension, subawards under section 1602(c)
of the Act derived from cash assistance
under that section that are used in a qual-
ified low-income building are not federal
grants for purposes of § 42(d)(5)(A) and
do not otherwise reduce the depreciable or
eligible basis of the building.
DRAFTING INFORMATION
The principal author of this notice
is Christopher J. Wilson, Office of the
Associate Chief Counsel (Passthroughs
and Special Industries). For further
information concerning this notice, contact
Mr. Wilson at (202) 622–3040 (not a
toll-free call).
INTERIM GUIDANCE
ON MEASUREMENT OF
CONTINUITY OF INTEREST IN
REORGANIZATIONS
Notice 2010–25
This notice pertains to the continuity of
interest test generally applicable to reorga-
nizations described in section 368 of the
Internal Revenue Code.
I. PURPOSE
Under section 7805(e)(2) of the Internal
Revenue Code, temporary regulations ex-
pire three years after issuance, if not earlier
withdrawn. Section 1.368–1T(e)(2) of the
Income Tax Regulations will accordingly
expire on March 19, 2010. The purpose of
this notice is to provide taxpayers with in-
terim guidance applicable to the period be-
tween the expiration of the temporary reg-
ulations and the issuance of replacement
guidance.
II. BACKGROUND AND INTERIM
GUIDANCE
The Internal Revenue Code of 1986
(Code) generally provides nonrecognition
treatment for reorganizations described in
section 368 of the Code. Besides satisfy-
ing the statutory and other requirements,
in order to qualify as a reorganization, a
transaction generally must satisfy the con-
tinuity of interest (COI) requirement. COI
requires that, in substance, a substantial
part of the value of the proprietary inter-
ests in the target corporation be preserved
in the reorganization.
On March 20, 2007, the Internal Rev-
enue Service (Service) and the Treasury
Department (Treasury) published tempo-
rary regulations § 1.368–1T(e)(2) (T.D.
9316, 2007–1 C.B. 962) and proposed
regulations (REG–146247–06, 2007–1
C.B. 977) in the Federal Register (72 FR
12974 and 72 FR 13058, respectively).
The text of the temporary regulations and
the proposed regulations is the same. The
Service and the Treasury intend to issue
final regulations, but do not expect to issue
such regulations prior to the expiration of
the temporary regulations. The purpose
of this notice is to provide taxpayers with
interim guidance applicable to the period
between the expiration of the temporary
regulations and the issuance of new regu-
lations.
After expiration of the temporary reg-
ulations and prior to the issuance of new
regulations, taxpayers may apply the
rules set forth in the proposed regulations
notwithstanding that the temporary regu-
lations have expired. However, the target
corporation, the issuing corporation, the
controlling corporation of the acquiring
corporation if stock thereof is provided as
consideration in the transaction, and any
direct or indirect transferee of transferred
basis property from any of the foregoing,
may not apply the provisions of the pro-
posed regulations unless all such taxpayers
elect to apply the provisions of such regu-
lations. This requirement will be satisfied
if none of the specified parties adopts
treatment inconsistent with this election.
DRAFTING INFORMATION
The principal author of this notice is
Richard Starke of the Office of Associate
Chief Counsel (Corporate). For further
information regarding this notice, please
contact Richard Starke at (202) 622–7790
(not a toll-free call).
Chile Earthquake Occurring
in February 2010 Designated
as a Qualified Disaster Under
§ 139 of the Internal Revenue
Code
Notice 2010–26
This notice designates the Chile earth-
quake occurring in February 2010 as a
qualified disaster for purposes of § 139 of
the Internal Revenue Code in the affected
areas of Chile.
EARTHQUAKE DISASTER
On February 27, 2010, a magnitude 8.8
earthquake with numerous significant af-
tershocks and a tsunami affected southern
and central Chile (“Chile earthquake”).
The earthquake and resulting aftershocks
affected approximately 2 million individ-
uals, displaced thousands of individuals
from damaged and destroyed houses, and
resulted in 795 deaths. The earthquake
also caused major damage to buildings
and infrastructure near the epicenter, and
disrupted communications, electricity,
water, and gas services in the affected
areas. In addition, a tsunami caused sig-
nificant damage along parts of coastal
Chile.USAID Chile — Earthquake Fact
Sheet No. 1(March 1, 2010) andNo. 2
(March 2, 2010).
This notice enables employer-spon-
sored private foundations to assist certain
victims in areas affected by the Chile
earthquake and enables recipients to ex-
clude qualified disaster relief payments
from gross income.
QUALIFIED DISASTER RELIEF
PAYMENTS EXCLUDED FROM
RECIPIENT’S GROSS INCOME
Section 139(a) provides that gross in-
come shall not include any amount re-
ceived by an individual as a qualified dis-
aster relief payment.
Section 139(b) provides that a quali-
fied disaster relief payment includes any
amount paid to or for the benefit of an in-
dividual—
(1) to reimburse or pay reasonable
and necessary personal, family, living,
or funeral expenses (not otherwise com-
pensated for by insurance or otherwise)
April 5, 20105272010–14 I.R.B.

incurred as a result of a qualified disaster,
or
(2) to reimburse or pay reasonable and
necessary expenses (not otherwise com-
pensated for by insurance or otherwise) in-
curred for the repair or rehabilitation of
a personal residence or repair or replace-
ment of its contents to the extent that the
need for such repair, rehabilitation, or re-
placement is attributable to a qualified dis-
aster.
Under § 139(c)(3) the term “qualified
disaster” includes a disaster resulting from
an event that is determined by the Secre-
tary to be of a catastrophic nature.
DESIGNATION AS QUALIFIED
DISASTER
The Commissioner of Internal Rev-
enue, pursuant to delegation by the Sec-
retary, has determined that the Chile
earthquake occurring in February 2010 is
an event of a catastrophic nature under
§ 139(c)(3). Therefore, the Chile earth-
quake is designated as a qualified disaster
under § 139 in the affected areas of Chile.
SECTION 501(c)(3) ORGANIZATIONS
Employer-sponsored private founda-
tions may choose to provide disaster relief
to employee victims of the Chile earth-
quake. Like all organizations described
in § 501(c)(3), private foundations should
exercise due diligence when providing
disaster relief as set forth in Publication
3833,Disaster Relief: Providing Assis-
tance Through Charitable Organizations.
DRAFTING INFORMATION
The principal author of this notice is
Sheldon Iskow of the Office of Associate
Chief Counsel (Income Tax & Account-
ing). For further information regarding
this notice, contact Mr. Iskow at (202)
622–4920 (not a toll-free call).
26 CFR 601.105: Examination of returns and claims
for refund, credit, or abatement; determination of
correct tax liability.
(Also Part I, §§ 118, 362.)
Rev. Proc. 2010–20
SECTION 1. PURPOSE
This revenue procedure provides a safe
harbor under section 118(a) of the Inter-
nal Revenue Code for the treatment of a
Smart Grid Investment Grant (SGIG) un-
der 42 U.S.C. 17386 made by the United
States Department of Energy (DOE) to a
corporation for qualifying investments un-
der the Smart Grid Investment Matching
Grant Program as authorized by section
1306 of the Energy Independence and Se-
curity Act of 2007 (Pub. L. 110–140), as
amended by section 405, Division A of the
American Recovery and Reinvestment Act
of 2009 (Pub. L. 111–5).
SECTION 2. BACKGROUND
Section 118(a) of the Code provides
that in the case of a corporation, gross in-
come does not include a contribution to the
capital of the taxpayer.
Section 1.118–1 of the Income Tax
Regulations provides that section 118 ap-
plies to contributions to capital made by a
person other than a shareholder, for exam-
ple, property contributed to a corporation
by a governmental unit for the purpose
of enabling the corporation to expand its
operating facilities.
Section 362(c)(2) of the Code requires a
basis reduction in a corporation’s property
when the corporation receives money from
a nonshareholder as a contribution to its
capital.
42 U.S.C. 17386 provides that DOE
shall establish a Smart Grid Invest-
ment Matching Grant Program to make
grants for qualifying investments. Under
42 U.S.C. 17386, an SGIG may not be
used for ongoing or routine operating and
maintenance expenditures.
SECTION 3. SCOPE
This revenue procedure applies to cor-
porate taxpayers that receive an SGIG
under 42 U.S.C. 17386 from DOE. This
revenue procedure does not apply to
noncorporate taxpayers, or to grants
under 42 U.S.C. 17384 (Smart Grid
technology research, development, and
demonstration).
SECTION 4. PROCEDURE
The Internal Revenue Service will not
challenge a corporation’s treatment of an
SGIG made by DOE to the corporation as
a nonshareholder contribution to the capi-
tal of the corporation under section 118(a)
of the Code if the corporation properly re-
duces the basis of its property under sec-
tion 362(c)(2) and the regulations thereun-
der.
SECTION 5. EFFECTIVE DATE
This revenue procedure is effective
March 10, 2010.
SECTION 6. DRAFTING
INFORMATION
The principal author of this rev-
enue procedure is David McDonnell of
the Office of Associate Chief Counsel
(Passthroughs & Special Industries). For
further information regarding this revenue
procedure, contact Mr. McDonnell at
(202) 622–3040 (not a toll-free call).
2010–14 I.R.B.528April 5, 2010

Part IV. Items o
fGeneralInterest
PROCEDURES FO
RCERTAIN
TRUSTS THAT QU
ALIFY
AS TYPE III SUP
PORTING
ORGANIZATIO
NS
Announcement 2010–19
This announcement applies to any trust
that met the requirements to be classi-
fied as a Type III supporting organization
through the end of the 2008 taxable year
(including by meeting the significant voice
responsiveness test for periods after Au-
gust 16, 2007), but erroneously filed Form
990-PF and paid section 4940 tax for the
2008 taxable year. It provides procedures
that such a trust may use to request a rul-
ing that it was and continues to be a Type
III supporting organization described in
section 509(a)(3) and to obtain a refund of
any section 4940 tax paid with respect to
its 2008 taxable year.
This announcement also describes pro-
cedures for charitable trusts that became
private foundations after August 16, 2007,
andwishtoterminatetheir private founda-
tion status under section 507(b)(1)(B) by
operating as Type III supporting organiza-
tions.
Backgrou
nd
Treas. Reg. § 1.509(a)–4(i) sets forth
the requirements for an organization to
qualify as a section 509(a)(3) supporting
organization that is “operated in connec-
tion with” one or more publicly supported
organizations (i.e., a “Type III supporting
organization”). Type III supporting orga-
nizations are required to meet a “respon-
siveness test” and an “integral part test.”
See Treas. Reg. § 1.509(a)–4(i)(1)(i),
(i)(2).
Prior to passage of the Pension Protec-
tion Act of 2006, Pub. L. No. 109–280,
120 Stat. 780 (2006) (“PPA”), there were
two alternative ways for a Type III support-
ing organization to meet the responsive-
ness test.
1. The sign
ificant voice test. Treas. Reg.
§ 1.509(
a)–4(i)(2)(ii) provides that an
organi
zation meets the responsiveness
test if
, by virtue of certain governance
relati
onships between the supporting
organization
andthesupportedor-
ganization, o
r a close and continuous
working relat
ionship between the sup-
porting organ
ization and supported
organization
, the officers, directors,
or trustees o
f the publicly supported
organizatio
n have a significant voice
in the invest
ment policies of the sup-
porting orga
nization, the timing of
grants, the
manner of making them,
and the sele
ction of recipients of such
supporting
organization, and in other-
wise direct
ing the use of the income
or assets o
f the supporting organiza-
tion.
2. The charit
able trust test. Treas. Reg.
§ 1.509(a)
–4(i)(2)(iii) provides that an
organizat
ion meets the responsiveness
test if it i
s a charitable trust under state
law, each p
ublicly supported organi-
zation is
a named beneficiary under
the trust
’s governing instrument, and
each bene
ficiary organization has the
power to e
nforce the trust and compel
an accou
nting under state law.
Section 1
241(c) of the PPA elimi-
nated th
e charitable trust test, effective
August 1
7, 2007. Consequently, as of
August 1
7, 2007, a charitable trust can
no longe
r qualify as a Type III supporting
organiz
ation unless it meets the significant
voice t
est.
Notice 2
008–6, 2008–1 C.B. 275, pro-
vided t
hat any charitable trust that became
apriva
te foundation because of the PPA’s
elimin
ation of the charitable trust test
would n
ot be required to file an informa-
tion re
turn on Form 990-PF or pay excise
taxes
on investment income under section
4940 u
ntil its first taxable year beginning
on or a
fter January 1, 2008.
On Aug
ust 2, 2007, the Treasury De-
partm
ent (“Treasury”) and the Internal
Reven
ue Service (“IRS”) published an
advan
ce notice of proposed rulemaking
(“AN
PRM”) describing the rules Treasury
and t
he IRS anticipated proposing regard-
ing T
ype III supporting organizations.
The A
NPRM states that Treasury and the
IRS e
xpect that all Type III supporting
orga
nizations will be required to meet the
sig
nificant voice responsiveness test under
Tre
as. Reg. § 1.509(a)–4(i)(2)(ii).
On September 2
4, 2009, Treasury
and the IRS pub
lishedanoticeofpro-
posed rulemak
ingintheFederalRegister
(74 Fed. Reg. 4
8,672) addressing Type
III supportin
g organizations (“proposed
regulations
”). The proposed regulations
require that
all Type III supporting
organizatio
ns meet the significant voice
responsiven
ess test, and provide two new
examples il
lustrating the application of the
significan
t voice test to charitable trusts.
Scope
Atrustmayr
equest a ruling stating that
it is a Type I
II supporting organization and
obtain a ref
und of any tax paid under sec-
tion 4940 b
y following the procedures set
forth in th
is Announcement if it is either:
1. A charitab
le trust that:
a. received a
determination recog-
nizing its
tax-exempt status under
section 50
1(c)(3);
b. was classi
fied as a Type III sup-
porting or
ganization prior to en-
actment of
the PPA;
c. continued
to meet the require-
ments to be
classified as a
Type III s
upporting organiza-
tion thro
ugh the end of its 2008
taxable y
ear (including by meet-
ing the si
gnificant voice respon-
sivenes
s test for periods after
August 1
6, 2007); and
d. erroneo
usly filed Form 990-PF
for the 2
008 taxable year and paid
section
4940 tax for the 2008 tax-
able yea
r;
or
2. A non-ex
empt charitable trust de-
scribed
in section 4947(a)(1) that:
a. is treat
ed for certain purposes as
an organ
ization described in sec-
tion 501
(c)(3);
b. was clas
sified as a Type III sup-
porting
organization prior to en-
actment
of the PPA;
c. continu
ed to meet the require-
ments to
be classified as a
Type II
I supporting organiza-
tion th
rough the end of its 2008
taxabl
e year (including by meet-
ing the
significant voice respon-
sivene
ss test for periods after
Augus
t 16, 2007); and
April 5, 20105292010–14 I.R.B.

d. erroneously filed Form 990-PF
for the 2008 taxable year and paid
section 4940 tax for the 2008 tax-
able year.
Procedures
A. Ruling that trust qualifies as Type III
supporting organization for taxable years
beginning on or after January 1, 2008
A trust may request a ruling that it qual-
ified and continues to qualify as a Type III
supporting organization for taxable years
beginning on or after January 1, 2008, by
submitting a written request for a ruling
pursuant to Revenue Procedure 2010–4,
2010–1 I.R.B. 122.
The request for ruling should gener-
ally follow the format specified in Rev-
enue Procedure 2010–4 and must include
the following:
1. A subject line or other indicator on the
first page of the request in bold, un-
derlined, or all capitals font indicating
“REQUEST FOR RULING — TYPE
III SUPPORTING ORGANIZATION
STATUS OF TRUST.”
2. An explanation of how the trust sat-
isfied the requirements to be classi-
fied as a Type III supporting organi-
zation through the end of its 2008 tax-
able year (including by meeting the
significant voice responsiveness test
for periods after August 16, 2007),
and how it expects to continue to sat-
isfy such requirements for subsequent
years. For this purpose, the trust may
rely on the proposed regulations.
3. With respect to the significant voice
test, documentation that establishes
that the trust satisfied the require-
ments of the test. For example, such
documentation may include minutes
or other documentation of meetings,
telephone calls, conversations, e-mail
exchanges, and policies that demon-
strate a close and continuous working
relationship between the supported
organization(s) and the supporting
organization based upon which the
supported organization(s) has a sig-
nificant voice.
Like all requests for a ruling, the request
must be signed under penalties of perjury
by the trust’s officer, director, trustee, or
other authorized official. The complete
request should be mailed to:
Internal Revenue Service
Attention: EO Letter Rulings
P.O. Box 27720
McPherson Station
Washington, D.C. 20038
There is no user fee for this ruling
request. No deletions statement is re-
quired because determinations regarding
foundation status are public pursuant to
section 6104. The Checklist in Appendix
B of Revenue Procedure 2010–4 is not
required.
B. Claims for refunds of tax paid under
section 4940 for taxable years beginning
on or after January 1, 2008
A trust may request a refund of tax paid
under section 4940 for its first taxable year
beginning on or after January 1, 2008, by
filing a Form 843 that meets the following
requirements:
1. The Form 843 must be accompanied
by a copy of the ruling received from
the IRS under the procedures set forth
in this announcement.
2. The Form 843 must be submitted by
mail or delivered to:
Internal Revenue Service Center
P.O. Box 9941
MS: 6710
Ogden, Utah 84409–0074
3. The Form 843 must be completed as
follows:
a. Write “Announcement 2010–19
status change” at the top of Form
843,
b. On line 6, check the box for
“990-PF,” and
c. On line 7, write “Announcement
2010–19 status change by Type
III supporting organization.”
C. 2008 Form 990
Any trust that receives a ruling that it
is a Type III supporting organization under
the procedures set forth in this announce-
ment must file a Form 990 for its first tax-
able year beginning on or after January 1,
2008, within 120 days of the date of the
ruling letter. The top of page 1 of the
Form 990 should bear the following leg-
end in bold, underlined, or all capitals font:
“ANNOUNCEMENT 2010–19.”
D. Section 507 terminations of private
foundation status
Charitable trusts that became private
foundations after August 16, 2007, may
terminate their private foundation status
under section 507(b)(1)(B) by operating
as Type III supporting organizations. Un-
der existing law and procedures, a private
foundation may terminate its private foun-
dation status under section 507(b)(1)(B)
by: (1) operating as an organization de-
scribed in paragraph (1), (2), or (3) of sec-
tion 509(a) for a continuous period of at
least 60 calendar months beginning with
the first day of any taxable year that begins
after December 31, 1969; (2) notifying the
Secretary before the commencement of the
60-month period that it is terminating its
private foundation status; and (3) estab-
lishing that it in fact operated as an or-
ganization described insection 509(a)(1),
(2), or (3) to the satisfaction of the Secre-
tary immediately after the expiration of the
60-month period.
Notifications of termination should be
labeled “TERMINATION NOTIFICA-
TION” at the top of the first page of the
cover letter, and should be submitted to the
Determinations office in Cincinnati. The
letter and accompanying documentation
should be mailed to—
Internal Revenue Service
P.O. Box 2508
Rm. 4024
Cincinnati, OH 45201
For further information regarding this
announcement, contact Mike Repass of
the Exempt Organizations, Tax Exempt
and Government Entities Division at (202)
283–8924 (not a toll-free call).
2010–14 I.R.B.530April 5, 2010

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the ef-
fect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is be-
ingextendedtoapplytoavariationofthe
fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that the
same principle also applies to B, the earlier
ruling is amplified. (Compare withmodi-
fied,below).
Clarifiedis used in those instances
where the language in a prior ruling is be-
ing made clear because the language has
caused, or may cause, some confusion.
It is not used where a position in a prior
ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
withamplifiedandclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used in
a ruling that lists previously published rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
beingstatedinanewruling.
Supersededdescribes a situation where
the new ruling does nothing more than re-
state the substance and situation of a previ-
ously published ruling (or rulings). Thus,
the term is used to republish under the
1986 Code and regulations the same po-
sition published under the 1939 Code and
regulations. The term is also used when
it is desired to republish in a single rul-
ing a series of situations, names, etc., that
were previously published over a period of
time in separate rulings. If the new rul-
ing does more than restate the substance
of a prior ruling, a combination of terms
is used. For example,modifiedandsu-
persededdescribes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is self
contained. In this case, the previously pub-
lished ruling is first modified and then, as
modified, is superseded.
Supplementedis used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names in
subsequent rulings. After the original rul-
ing has been supplemented several times, a
new ruling may be published that includes
the list in the original ruling and the ad-
ditions, and supersedes all prior rulings in
the series.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of cases
in litigation, or the outcome of a Service
study.
Abbreviations
The fol
lowing abbreviations in current use
and for
merly used will appear in material
publis
hedintheBulletin.
A—Individual.
Acq.—A
cquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank
.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cu
mulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Coo
perative.
Ct.D.—Court Decision.
CY—County.
D—Decede
nt.
DC—Dummy Corporation.
DE—Donee.
Del. Order
—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Emp
loyer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduc
iary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Fo
reign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Fed
eral Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grante
e.
GP—General Partner.
GR—Grantor.
IC—Insura
nce Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited
Partner.
LR—Lessor.
M—Minor.
Nonacq.—No
nacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Persona
l Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Pa
rtnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Re
al Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsi
diary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target
Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Trans
feree.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpay
er.
TR—Trust.
TT—Trustee.
U.S.C.—Uni
ted States Code.
X—Corporation.
Y—Corporation.
Z—Corporat
ion.
April 5, 2010i2010–14 I.R.B.

Numerical Finding List
1
Bulletins 2010–1 through 2010–14
Announcements:
2010-1, 2010-4 I.R.B.333
2010-2, 2010-2 I.R.B.271
2010-3, 2010-4 I.R.B.333
2010-4, 2010-5 I.R.B.384
2010-5, 2010-6 I.R.B.402
2010-6, 2010-6 I.R.B.402
2010-7, 2010-6 I.R.B.403
2010-8, 2010-7 I.R.B.408
2010-9, 2010-7 I.R.B.408
2010-10, 2010-7 I.R.B.410
2010-11, 2010-10 I.R.B.438
2010-12, 2010-7 I.R.B.410
2010-13, 2010-8 I.R.B.426
2010-14, 2010-11 I.R.B.449
2010-15, 2010-10 I.R.B.438
2010-16, 2010-11 I.R.B.450
2010-17, 2010-13 I.R.B.515
2010-18, 2010-12 I.R.B.460
2010-19, 2010-14 I.R.B.529
Notices:
2010-1, 2010-2 I.R.B.251
2010-2, 2010-2 I.R.B.251
2010-3, 2010-2 I.R.B.253
2010-4, 2010-2 I.R.B.253
2010-5, 2010-2 I.R.B.256
2010-6, 2010-3 I.R.B.275
2010-7, 2010-3 I.R.B.296
2010-8, 2010-3 I.R.B.297
2010-9, 2010-3 I.R.B.298
2010-10, 2010-3 I.R.B.299
2010-11, 2010-4 I.R.B.326
2010-12, 2010-4 I.R.B.326
2010-13, 2010-4 I.R.B.327
2010-14, 2010-5 I.R.B.344
2010-15, 2010-6 I.R.B.390
2010-16, 2010-6 I.R.B.396
2010-17, 2010-14 I.R.B.519
2010-18, 2010-14 I.R.B.525
2010-19, 2010-7 I.R.B.404
2010-20, 2010-8 I.R.B.422
2010-21, 2010-12 I.R.B.451
2010-22, 2010-10 I.R.B.435
2010-23, 2010-11 I.R.B.441
2010-24, 2010-12 I.R.B.452
2010-25, 2010-14 I.R.B.527
2010-26, 2010-14 I.R.B.527
Proposed Regulations:
REG-132232-08, 2010-6 I.R.B.401
REG-137036-08, 2010-6 I.R.B.398
Proposed Regulations— Continued:
REG-101896-09, 2010-5 I.R.B.347
REG-117501-09, 2010-11 I.R.B.442
REG-131028-09, 2010-4 I.R.B.332
REG-148681-09, 2010-11 I.R.B.443
Revenue Procedures:
2010-1, 2010-1 I.R.B.1
2010-2, 2010-1 I.R.B.90
2010-3, 2010-1 I.R.B.110
2010-4, 2010-1 I.R.B.122
2010-5, 2010-1 I.R.B.165
2010-6, 2010-1 I.R.B.193
2010-7, 2010-1 I.R.B.231
2010-8, 2010-1 I.R.B.234
2010-9, 2010-2 I.R.B.258
2010-10, 2010-3 I.R.B.300
2010-11, 2010-2 I.R.B.269
2010-12, 2010-3 I.R.B.302
2010-13, 2010-4 I.R.B.329
2010-14, 2010-12 I.R.B.456
2010-15, 2010-7 I.R.B.404
2010-17, 2010-8 I.R.B.425
2010-18, 2010-9 I.R.B.451
2010-19, 2010-13 I.R.B.469
2010-20, 2010-14 I.R.B.528
2010-21, 2010-13 I.R.B.473
Revenue Rulings:
2010-1, 2010-2 I.R.B.248
2010-2, 2010-3 I.R.B.272
2010-3, 2010-3 I.R.B.272
2010-4, 2010-4 I.R.B.309
2010-5, 2010-4 I.R.B.312
2010-6, 2010-6 I.R.B.387
2010-7, 2010-8 I.R.B.417
2010-8, 2010-10 I.R.B.432
2010-9, 2010-13 I.R.B.461
2010-10, 2010-13 I.R.B.461
2010-11, 2010-14 I.R.B.516
Treasury Decisions:
9474, 2010-4 I.R.B.322
9475, 2010-4 I.R.B.304
9476, 2010-5 I.R.B.336
9477, 2010-6 I.R.B.385
9478, 2010-4 I.R.B.315
9480, 2010-11 I.R.B.439
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2009–27 through 2009–52 is in Internal Revenue Bulletin
2009–52, dated December 28, 2009.
2010–14 I.R.B.iiApril 5, 2010

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2010–1 through 2010–14
Announcements:
2009-51
Supplemented and superseded by
Ann. 2010-16, 2010-11 I.R.B.450
2010-4
Corrected by
Ann. 2010-10, 2010-7 I.R.B.410
Notices:
2005-88
Superseded by
Notice 2010-13, 2010-4 I.R.B.327
2008-41
Modified by
Notice 2010-7, 2010-3 I.R.B.296
2008-55
Modified by
Notice 2010-3, 2010-2 I.R.B.253
2008-88
Modified by
Notice 2010-7, 2010-3 I.R.B.296
2008-113
Modified by
Notice 2010-6, 2010-3 I.R.B.275
2008-115
Modified by
Notice 2010-6, 2010-3 I.R.B.275
2009-11
Amplified by
Notice 2010-9, 2010-3 I.R.B.298
2009-13
Obsoleted by
T.D. 9478, 2010-4 I.R.B.315
REG-131028-09, 2010-4 I.R.B.332
2009-35
Supplemented by
Notice 2010-17, 2010-14 I.R.B.519
2009-38
Amplified and superseded by
Notice 2010-2, 2010-2 I.R.B.251
2009-62
Modified and supplemented by
Notice 2010-23, 2010-11 I.R.B.441
Proposed Regulations:
REG-127270-06
Hearing scheduled by
Ann. 2010-6, 2010-6 I.R.B.402
Revenue Procedures:
80-59
Modified and superseded by
Rev. Proc. 2010-11, 2010-2 I.R.B.269
87-35
Obsoleted by
Rev. Proc. 2010-3, 2010-1 I.R.B.110
2008-14
Updated by
Rev. Proc. 2010-15, 2010-7 I.R.B.404
2009-1
Superseded by
Rev. Proc. 2010-1, 2010-1 I.R.B.1
2009-2
Superseded by
Rev. Proc. 2010-2, 2010-1 I.R.B.90
2009-3
Superseded by
Rev. Proc. 2010-3, 2010-1 I.R.B.110
2009-4
Superseded by
Rev. Proc. 2010-4, 2010-1 I.R.B.122
2009-5
Superseded by
Rev. Proc. 2010-5, 2010-1 I.R.B.165
2009-6
Superseded by
Rev. Proc. 2010-6, 2010-1 I.R.B.193
2009-7
Superseded by
Rev. Proc. 2010-7, 2010-1 I.R.B.231
2009-8
Superseded by
Rev. Proc. 2010-8, 2010-1 I.R.B.234
2009-9
Superseded by
Rev. Proc. 2010-9, 2010-2 I.R.B.258
2009-15
Amplified and superseded by
Rev. Proc. 2010-12, 2010-3 I.R.B.302
2009-17
Superseded by
Rev. Proc. 2010-21, 2010-13 I.R.B.473
2009-25
Superseded by
Rev. Proc. 2010-3, 2010-1 I.R.B.110
2009-55
Corrected by
Ann. 2010-11, 2010-10 I.R.B.438
Revenue Procedures— Continued:
2010-1
Corrected by
Ann. 2010-5, 2010-6 I.R.B.402
Revenue Rulings:
67-436
Obsoleted by
REG-101896-09, 2010-5 I.R.B.347
92-19
Supplemented in part by
Rev. Rul. 2010-7, 2010-8 I.R.B.417
2008-52
Supplemented and superseded by
Rev. Rul. 2010-2, 2010-3 I.R.B.272
Treasury Decisions:
9424
Corrected by
Ann. 2010-18, 2010-12 I.R.B.460
9443
Corrected by
Ann. 2010-8, 2010-7 I.R.B.408
9458
Corrected by
Ann. 2010-7, 2010-6 I.R.B.403
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2009–27 through 2009–52 is in Internal Revenue Bulletin 2009–52, dated December 28,
2009.
April 5, 2010iii2010–14 I.R.B.

INTERNAL REVENUE BULLETIN
The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue
Bulletin is sold on a yearly subscription basis by the Superintendent of Documents. Current subscribers are notified by the Superin-
tendent of Documents when their subscriptions must be renewed.
CUMULATIVE BULLETINS
The contents of this weekly Bulletin are consolidated semiannually into a permanent, indexed, Cumulative Bulletin. These are
sold on a single copy basis andare notincluded as part of the subscription to the Internal Revenue Bulletin. Subscribers to the weekly
Bulletin are notified when copies of the Cumulative Bulletin are available. Certain issues of Cumulative Bulletins are out of print
and are not available. Persons desiring available Cumulative Bulletins, which are listed on the reverse, may purchase them from the
Superintendent of Documents.
ACCESS THE INTERNAL REVENUE BULLETIN ON THE INTERNET
You may view the Internal Revenue Bulletin on the Internet at www.irs.gov. Select Businesses. Under Businesses Topics, select
More Topics. Then select Internal Revenue Bulletins.
INTERNAL REVENUE BULLETINS ON CD-ROM
Internal Revenue Bulletins are available annually as part ofPublication 1796 (Tax Products CD-ROM). The CD-ROM can be
purchased from National Technical Information Service (NTIS) on the Internet at www.irs.gov/cdorders (discount for online orders)
or by calling 1-877-233-6767. The first release is available in mid-December and the final release is available in late January.
HOW TO ORDER
Check the publications and/or subscription(s) desired on the reverse, complete the order blank, enclose the proper remittance,
detach entire page, and mail to the Superintendent of Documents, P.O. Box 371954, Pittsburgh PA, 15250–7954. Please allow two to
six weeks, plus mailing time, for delivery.
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 IRS Bulletin Unit, SE:W:CAR:MP:T:T:SP, Washington, DC 20224.
Internal Revenue Service
W
ashington,DC20224
Official Business
Penalty for Private Use, $300