Internal Revenue Bulletin 2011-13 (PDF rendition): IRS Revenue Rulings

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Bulletin No. 201
1-13
March 28, 2011
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. 2011–5, page 577.
Interest rates; underpayments and overpayments.The
rates for interest determined under section 6621 of the Code
for the calendar quarter beginning April 1, 2011, will be 4 per-
cent for overpayments (3 percent in the case of a corporation),
4 percent for underpayments, and 6 percent for large corpo-
rate underpayments. The rate of interest paid on the portion of
a corporate overpayment exceeding $10,000 will be 1.5 per-
cent.
EXEMPT ORGANIZATIONS
REG–140108–08, page 591.
Proposed regulations under section 6104(c) of the Code
amend existing regulations to reflect changes made by the
Pension Protection Act of 2006 (PPA) by providing guidance
to states regarding the process by which they may obtain
or inspect certain returns and return information (including
information about final and proposed denials and revocations
of tax-exempt status) for the purpose of administering state
laws governing certain tax-exempt organizations and their
activities.
Notice 2011–23, page 588.
This notice addresses the requirements for tax exemption for
qualified nonprofit health insurance issuers described in sec-
tion 501(c)(29) of the Code by providing guidance on the an-
nual filing requirement for organizations that intend to apply for
recognition of exempt status as well as on the effective date of
exempt status for certain applicants. The notice also includes
a request for public comments.
ADMINISTRATIVE
T.D. 9516, page 575.
Final regulations under section 6103 of the Code describe the
circumstances by which officers and employees of the Treasury
Department may disclose return information to whistleblowers
and, if applicable, their legal representatives in connection with
written contracts for services relating to the detection of vio-
lations of the internal revenue laws or related statutes by the
IRS.
Fi
nding Lists begin on page ii.
Index for January through March begins on page v.

The IRS Mission
Provide Americ
a’s taxpayers top-quality service by helping
them understa
nd and meet their tax responsibilities and en-
force the law wi
th 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.
March 28, 20112011–13 I.R.B.

Part I. Rulings
and Decisions Under the Internal Revenue Code
of 1986
Section 6103.
—Confi-
dentiality an
dDisclosure
of Returns and Return
Information
26 CFR 301.6103(n)–2: Disclosure of return infor-
mation in connection with written contracts among
the IRS, whistleblowers, and legal representatives of
whistleblowers.
T.D. 9516
DEPARTMENT OF THE
TREASURY
Internal Revenue Service
26 CFR Part 301
Disclosure of Return
InformationinConnection
with Written Contracts Among
the IRS, Whistleblowers, and
Legal Representatives of
Whistleblowers
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations and removal
of temporary regulations.
SUMMARY:
This document contains final
regulati
ons relating to the disclosure of re-
turn inf
ormation by an officer or employee
of the Tr
easury Department, to a whistle-
blower a
nd, if applicable, the legal repre-
sentati
ve of the whistleblower, to the ex-
tent nec
essary in connection with a writ-
ten con
tract among the IRS, the whistle-
blower
and, if applicable, the legal rep-
resent
ative of the whistleblower, for ser-
vices r
elating to the detection of viola-
tions o
f the internal revenue laws or re-
lated s
tatutes. The final regulations will
affec
t officers and employees of the Trea-
sury D
epartment who disclose return in-
forma
tion to whistleblowers or their legal
repre
sentatives in connection with written
contr
acts among the IRS, whistleblowers
and,
if applicable, their legal representa-
tive
s, for services relating to the detection
of vi
olations of the internal revenue laws
or re
lated statutes. The final regulations
will
also affect any whistleblower or le-
gal r
epresentative of a whistleblower who
receives retu
rn information in connection
with a written
contract among the IRS, the
whistleblowe
r and, if applicable, the le-
gal represen
tative of the whistleblower, for
services rel
ating to the detection of viola-
tions of the i
nternal revenue laws or related
statutes.
DATES:Effe
ctive Date:These final regu-
lations are
effective on March 15, 2011.
Applicabil
ity Date:For dates of appli-
cability, s
ee §301.6103(n)–2(f).
FOR FURTHE
R INFORMATION
CONTACT: H
elene R. Newsome,
202–622–7
950 (not a toll-free number).
SUPPLEMEN
TARY INFORMATION:
Backgrou
nd
This docu
ment contains final regula-
tions imp
lementing amendments to the
Procedu
re and Administration Regula-
tions (2
6 CFR part 301) under section
6103(n)
relating to the disclosure of return
informa
tion in connection with written
contra
cts among the IRS, whistleblowers
and, if
applicable, their legal representa-
tives.
The Tax
Relief and Health Care Act
of 2006
, Public Law 109–432 (120 Stat.
2958),
(the Act) was enacted on Decem-
ber 20,
2006. Section 406 of the Act
amend
s section 7623, concerning the pay-
ment o
f awards to whistleblowers, and es-
tabli
shes a Whistleblower Office within
the IR
S that has responsibility for the ad-
minis
tration of a whistleblower program.
In co
nnection with analyzing information
prov
ided by a whistleblower, or investigat-
ing a
matter, the IRS may determine that
it re
quires the assistance of the whistle-
blow
er, or the legal representative of the
whis
tleblower. The Joint Committee on
Tax
ation (the JCT) has noted that “[t]o the
ext
ent the disclosure of returns or return
inf
ormation is required [for the whistle-
blo
wer or his or her legal representative]
to r
ender such assistance, the disclosure
mu
st be pursuant to an IRS tax adminis-
tr
ation contract.” Joint Committee on Tax-
at
ion,Technical Explanation of H.R. 6408,
Th
e “Tax Relief and Health Care Act of
2006,”as Intr
oduced in the House on De-
cember 7, 2006
, at 89 (JCX–50–06), De-
cember 7, 2006
. The JCT has further noted
that “[i]t is
expected that such disclosures
will be infre
quent and will be made only
when the assi
gned task cannot be properly
or timely com
pleted without the return in-
formation t
o be disclosed.”Id.
Under sectio
n 6103(a), returns and re-
turn inform
ation are confidential unless
the Interna
l Revenue Code authorizes dis-
closure. Se
ction 6103(n) is the authority
by which ret
urns and return information
may be disc
losedpursuanttoataxad-
ministrat
ion contract. Section 6103(n)
authorize
s, pursuant to regulations pre-
scribed by
the Secretary, returns and return
informati
on to be disclosed to any per-
son, for p
urposes of tax administration, to
the exten
t necessary in connection with:
(1) the pr
ocessing, storage, transmission,
and repro
duction of returns and return
informat
ion; (2) the programming, main-
tenance
, repair, testing, and procurement
of equip
ment; and (3) the providing of
other se
rvices.
On March
25, 2008, temporary reg-
ulation
s (T.D. 9389, 2008–1 C.B. 863)
under se
ction 6103(n) were published in
theFed
eral Register(73 FR 15668) de-
scribi
ng the circumstances under which
office
rs and employees of the Treasury
Depart
ment may disclose return informa-
tion to
whistleblowers and, if applicable,
their
legal representatives, in connec-
tion w
ith written contracts for services
relat
ingtothedetectionofviolations
of the
internal revenue laws or related
statu
tes. A notice of proposed rulemak-
ing (
REG–114942–07, 2008–1 C.B. 901)
cros
s-referencing the temporary regula-
tion
s was published in theFederal Regis-
terf
or the same day (73 FR 15687).
One w
ritten comment responding to
the n
otice of proposed rulemaking was
rece
ived. No public hearing was requested
or he
ld. After consideration of the com-
men
t, the regulations are adopted as pro-
pos
ed with only minor technical changes
mad
e.
The
limitations applicable to section
610
3(n) contracts as outlined in these reg-
ula
tions are not a limitation on the use of
ret
urn information that may be disclosed
2011–13 I.R.B.575March 28, 2011

to a whistleblower or the legal represen-
tative of a whistleblower during an award
determination administrative proceeding
andinanawarddeterminationappealto
the U.S. Tax Court.
Summary of Comment
The commentator recommended that
§301.6103(n)–2(b)(3) of the proposed
regulations be revised to eliminate any
requirement that a written contract be in
place for a whistleblower to be provided
with basic status information about the
whistleblower’s claim for award under
section 7623. The commentator drew a
comparison with whistleblower claims
under the False Claims Act and argued
that the standard for the IRS to share status
information with a whistleblower should
not be the same as that required to share
information from the actual returns of tax-
payers. Unlike other statutory schemes,
however, information regarding the sta-
tus of a whistleblower’s claim with the
IRS is “return information” as defined in
section 6103(b)(2). Like returns (defined
in section 6103(b)(1)), return information
is confidential under section 6103(a) and
may only be disclosed if authorized by a
specific provision of the Code. In order
to disclose status information to a whistle-
blower, an exception to section 6103 must
be applicable. Section 6103(n) provides
authority for the IRS to make status in-
formation disclosures to a whistleblower.
Because disclosures pursuant to section
6103(n) require a written tax administra-
tion contract, the final regulations do not
adopt the commentator’s recommenda-
tion.
The commentator also recommended
that §301.6103(n)–2(d)(3) of the proposed
regulations be revised to eliminate the
inspection requirement. The commentator
asserted that, by contrast, §301.6103(n)–1,
“Disclosure of returnsand return informa-
tion in connection with written contracts
or agreements for the acquisition of prop-
erty or services for tax administration
purposes,” does not include such a re-
quirement and argued that the requirement
is unnecessary in that the regulations al-
ready provide for severe sanctions for
any failure to comply with the terms of
written contracts for services. In fact,
§301.6103(n)–1(e)(1) does indeed contain
an inspection requirement. The final regu-
lations retain the inspection requirement as
consistent with the longstanding safeguard
procedures that incorporate inspection as
an integral part of the contracting process
under section 6103(n).
Special Analyses
It has been determined that this Trea-
sury decision is not a significant regula-
tory action as defined in Executive Order
12866. Therefore, a regulatory assessment
is not required. It also has been deter-
mined that section 553(b) of the Admin-
istrative Procedure Act (5 U.S.C. chapter
5) does not apply to these regulations, and
because the regulations do not impose a
collection of information on small entities,
the Regulatory Flexibility Act (5 U.S.C.
chapter 6) does not apply. Pursuant to sec-
tion 7805(f) of the Code, the proposed reg-
ulations preceding these regulations were
submitted to the Chief Counsel for Advo-
cacy of the Small Business Administration
for comment on their impact on small busi-
ness.
Drafting Information
The principal author of these regula-
tions is Helene R. Newsome, Office of
the Associate Chief Counsel (Procedure &
Administration).
*****
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR part 301 is
amended as follows:
PART 301—PROCEDURE AND
ADMINISTRATION
Paragraph 1. The authority citation for
part 301 is amended by adding an entry in
numerical order to read as follows:
Authority: 26 U.S.C. 7805 * * *
Section 301.6103(n)–2 also issued un-
der 26 U.S.C. 6103(n). * * *
Section 301.6103(n)–2 also issued un-
der 26 U.S.C. 6103(q). * * *
Par. 2. Section 301.6103(n)–2 is added
to read as follows:
§301.6103(n)–2 Disclosure of return
information in connection with
written contracts among the IRS,
whistleblowers, and legal representatives
of whistleblowers.
(a)General rule. (1) Pursuant to the
provisions of sections 6103(n) and 7623
of the Internal Revenue Code and subject
to the conditions of this section, an offi-
cer or employee of the Treasury Depart-
ment is authorized to disclose return infor-
mation (as defined in section 6103(b)(2))
to a whistleblower and, if applicable, the
legal representative of the whistleblower,
to the extent necessary in connection with
a written contract among the Internal Rev-
enue Service (IRS), the whistleblower and,
if applicable, the legal representative of the
whistleblower, for services relating to the
detection of violations of the internal rev-
enue laws or related statutes.
(2) The IRS shall have the discretion
to determine whether to enter into a writ-
ten contract pursuant to section 7623 with
the whistleblower and, if applicable, the
legal representative of the whistleblower,
for services described in paragraph (a)(1)
of this section.
(b)Limitations. (1) Disclosure of re-
turn information in connection with a writ-
ten contract for services described in para-
graph (a)(1) of this section shall be made
only to the extent the IRS deems it neces-
sary in connection with the reasonable or
proper performance of the contract. Dis-
closures may include, but are not limited
to, disclosures to accomplish properly any
purpose or activity ofthe nature described
in section 6103(k)(6) and the regulations
thereunder.
(2) If the IRS determines that the ser-
vices of a whistleblower and, if applica-
ble, the legal representative of the whistle-
blower, as described in paragraph (a)(1) of
this section, can be performed reasonably
or properly by disclosure of only parts or
portions of return information, then only
the parts or portions of the return informa-
tion shall be disclosed.
(3) Upon written request by a whistle-
blower, or a legal representative of a
whistleblower, with whom the IRS has
entered into a written contract for ser-
vices as described in paragraph (a)(1) of
this section, the Director of the Whistle-
blower Office, or designee of the Director,
may inform the whistleblower and, if ap-
March 28, 20115762011–13 I.R.B.

plicable, the legal representative of the
whistleblower, of the status of the whistle-
blower’s claim for award under section
7623, including whether the claim is be-
ing evaluated for potential investigative
action, or is pending due to an ongoing
examination, appeal, collection action,
or litigation. The information may be
disclosed only if the IRS determines that
the disclosure would not seriously impair
Federal tax administration.
(4) Return information disclosed to a
whistleblower and, if applicable, a legal
representative of a whistleblower, under
this section, shall not be further disclosed
or otherwise used by the whistleblower or
a legal representative of a whistleblower,
except as expressly authorized in writing
by the IRS.
(c)Penalties. Any whistleblower, or le-
gal representative of a whistleblower, who
receives return information under this sec-
tion, is subject to the civil and criminal
penalty provisions of sections 7431, 7213,
and 7213A for the unauthorized inspection
or disclosure of the return information.
(d)Safeguards. (1) Any whistleblower,
or the legal representative of a whistle-
blower, who receives return information
under this section, shall comply with all
applicable conditions and requirements as
the IRS may prescribe from time to time
for the purposes of protecting the confi-
dentiality of the return information and
preventing any disclosure or inspection of
the return information in a manner not
authorized by this section (prescribed re-
quirements).
(2) Any written contract for services as
described in paragraph (a)(1) of this sec-
tion shall provide that any whistleblower
and, if applicable, the legal representative
of a whistleblower, who has access to re-
turn information under this section, shall
comply with the prescribed requirements.
(3) Any whistleblower, or the legal
representative of a whistleblower, who
may receive return information under
this section, shall agree in writing, be-
fore any disclosure of return information
is made, to permit an inspection of the
whistleblower’s or the legal representa-
tive’s premises by the IRS relative to the
maintenance of the return information dis-
closed under these regulations and, upon
completion of services as described in the
written contract with the IRS, to dispose
of all return information by returning the
return information, including any and all
copies or notes made, to the IRS, or to
the extent that it cannot be returned, by
destroying the information in a manner
consistent with prescribed requirements.
(4) If the IRS determines that any
whistleblower, or the legal representa-
tive of a whistleblower, who has access
to return information under this section,
has failed to, or does not, satisfy the pre-
scribed requirements, the IRS, using the
procedures described in the regulations
under section 6103(p)(7), may take any
action it deems necessary to ensure that
the prescribed requirements are or will be
satisfied, including—
(i) Suspension of further disclosures
of return information by the IRS to the
whistleblower and, if applicable, the legal
representative of the whistleblower, until
the IRS determines that the conditions and
requirements have been or will be satis-
fied; and
(ii) Suspension or termination of any
duty or obligation arising under the con-
tract with the IRS.
(e)Definitions. For purposes of this
section—
(1) The termTreasury Departmentin-
cludes the IRS and the Office of the Chief
Counsel for the IRS.
(2) The termwhistleblowermeans an
individual who provides information to the
IRS regarding violations of the tax laws or
related statutes and submits a claim for an
award under section 7623 with respect to
the information.
(3) The termlegal representativemeans
any individual who is a member in good
standing in the bar of the highest court of
any state, possession, territory, common-
wealth, or the District of Columbia, and
who has a written power of attorney exe-
cutedbythewhistleblower.
(f)Effective/applicability date.This
section is applicable on March 15, 2011.
Par. 3. Section 301.6103(n)–2T is re-
moved.
§301.6103(n)–2T [Removed].
Steven T. Miller,
Deputy Commissioner for
Services and Enforcement.
Approved March 9, 2011.
Michael F. Mundaca,
Assistant Secretary of
the Treasury for Tax Policy.
(Filed by the Office of the Federal Register on March 14,
2011, 8:45 a.m., and published in the issue of the Federal
Register for March 15, 2011, 76 F.R. 13880)
Section 6621.—Determina-
tion of Rate of Interest
26 CFR 301.6621–1: Interest rate.
Interest rates; underpayments and
overpayments.The rates for interest de-
termined under section 6621 of the Code
for the calendar quarter beginning April 1,
2011, will be 4 percent for overpayments
(3 percent in the case of a corporation), 4
percent for underpayments, and 6 percent
for large corporate underpayments. The
rate of interest paid on the portion of a
corporate overpayment exceeding $10,000
will be 1.5 percent.
Rev. Rul. 2011–5
Section 6621 of the Internal Revenue
Code establishes the rates for interest
on tax overpayments and tax underpay-
ments. Under section 6621(a)(1), the
overpayment rate is the sum of the federal
short-term rate plus 3 percentage points
(2 percentage points in the case of a cor-
poration), except the rate for the portion
of a corporate overpayment of tax exceed-
ing $10,000 for a taxable period is the
sum of the federal short-term rate plus
0.5 of a percentage point. Under section
6621(a)(2), the underpayment rate is the
sum of the federal short-term rate plus 3
percentage points.
Section 6621(c) provides that for pur-
poses of interest payable under section
6601 on any large corporate underpay-
ment, the underpayment rate under section
6621(a)(2) is determined by substituting
“5 percentage points” for “3 percentage
points.” See section 6621(c) and section
301.6621–3 of the Regulations on Proce-
dure and Administration for the definition
of a large corporate underpayment and
for the rules for determining the appli-
cable date. Section 6621(c) and section
301.6621–3 are generally effective for
periods after December 31, 1990.
Section 6621(b)(1) provides that the
Secretary will determine the federal
2011–13 I.R.B.577March 28, 2011

short-term rate for the first month in each
calendar quarter. Section 6621(b)(2)(A)
provides that the federal short-term rate
determined under section 6621(b)(1) for
any month applies during the first calen-
dar quarter beginning after that month.
Section 6621(b)(2)(B) provides that in de-
termining the addition to tax under section
6654 for failure to pay estimated tax for
any taxable year, the federal short-term
rate that applies during the third month
following the taxable year also applies
during the first 15 days of the fourth
month following the taxable year. Sec-
tion 6621(b)(3) provides that the federal
short-term rate for any month is the fed-
eral short-term rate determined during that
month by the Secretary in accordance with
section 1274(d), rounded to the nearest
full percent (or, if a multiple of 1/2 of 1
percent, the rate is increased to the next
highest full percent).
Notice 88–59, 1988–1 C.B. 546, an-
nounced that, in determining the quarterly
interest rates to be used for overpayments
and underpayments of tax under section
6621, the Internal Revenue Service will
use the federal short-term rate based on
daily compounding because that rate is
most consistent with section 6621 which,
pursuant to section 6622, is subject to daily
compounding.
The federal short-term rate determined
in accordance with section 1274(d) during
January 2011 is the rate published in Rev-
enue Ruling 2011–4, 2011–6 I.R.B. 448
to take effect beginning February 1, 2011.
The federal short-term rate, rounded to the
nearest full percent, based on daily com-
pounding determined during the month of
January 2011 is 1 percent. Accordingly, an
overpayment rate of 4 percent (3 percent
in the case of a corporation) and an under-
payment rate of 4 percent are established
for the calendar quarter beginning April 1,
2011. The overpayment rate for the por-
tion of a corporate overpayment exceeding
$10,000 for the calendar quarter beginning
April 1, 2011, is 1.5 percent. The under-
payment rate for large corporate underpay-
ments for the calendar quarter beginning
April 1, 2011, is 6 percent. These rates ap-
ply to amounts bearing interest during that
calendar quarter.
Under section 6621(b)(2)(B), the 4 per-
cent rate also applies to estimated tax un-
derpayments for the first calendar quarter
in 2011 and for the first 15 days in April
2011.
Interest factors for daily compound in-
terest for annual rates of 1.5 percent, 3 per-
cent, 4 percent and 6 percent are published
in Tables 8, 11, 13, and 17 of Rev. Proc.
95–17, 1995–1 C.B. 556, 562, 567, and
571. Interest factors for daily compound
interest for an annual rate of 0.5 percent are
published in Appendix A of Revenue Rul-
ing 2010–31, 2010–52 I.R.B. 898, 899.
Annual interest rates to be compounded
daily pursuant to section 6622 that apply
for prior periods are set forth in the tables
accompanying this revenue ruling.
DRAFTING INFORMATION
The principal author of this revenue rul-
ing is Deborah Colbert-James of the Office
of Associate Chief Counsel (Procedure &
Administration). For further information
regarding this revenue ruling, contact
Ms. Colbert-James at (202) 622–8143
(not a toll-free call).
March 28, 20115782011–13 I.R.B.

APPENDIX A
365 Day Year
0.5% Compound Ra
te 184 Days
DaysFactorDaysFactorDaysFactor
10.000013699630.000863380
125
0.001713784
20.000027397640.000877091126
0.001727506
30.000041096
65
0.0008908011270.001741228
4
0.000054796
66
0.000904512
128
0.001754951
50.000068495
670.0009182231290.001768673
6
0.000082195
680.0009319341300.001782396
7
0.000095894
69
0.000945646
1310.001796119
8
0.000109594
70
0.000959357
1320.001809843
90.000123294710.000973069133
0.001823566
10
0.000136995
720.0009867811340.001837290
11
0.000150695
730.001000493
1350.001851013
120.000164396740.0010142061360.001864737
130.00017809
7
75
0.00102791
8
1370.00187846
2
140.000191798760.0010416311380.001892186
150.0002054
99
77
0.0010553
44
139
0.0019059
10
160.0002192
01
78
0.001069057
140
0.001919635
170.000232902790.0010827701410.001933360
180.000246604800.001096484142
0.001947
085
190.000260
306
810.001110
197
1430.001960
811
200.000274008820.001123911144
0.001974536
210.00028771183
0.001137
625
145
0.001988262
220.000301
413
84
0.001151339
1460.002001
988
23
0.000315116850.001165054
147
0.002015714
240.000328819860.0011787681480.002029440
250.000342522
870.00119
2483
1490.00204
3166
26
0.000356225
880.001206198
1500.002056893
270.000369929890.001219913
151
0.002070620
280.0003
83633
900.0012
33629
152
0.0020
84347
290.000397336910.001247344
153
0.002098074
300.000411041920.001261060
154
0.002111801
31
0.000424745
930.001
274776
1550.002125529
320.000438449940.001288492
1560.002139257
33
0.00
0452154
95
0.001302208
1570.00
2152985
34
0.000465859
96
0.001315925158
0.00
2166713
350.000479564
970.001329641
159
0.002180441
360.00049326998
0.0
01343358
1600.002194169
37
0.000506974
99
0.001357075
1610.0
02207898
38
0.000520680
1000.0013707921620.002221627
39
0.0
00534386
101
0.0
01384510
163
0.0
02235356
40
0.000548092
10
2
0.
001398227
16
4
0.002249085
41
0.000561798
103
0.0014119451650.002262815
42
0.
000575504
104
0.
001425663
166
0.
002276544
43
0.000589211105
0.
001439381
16
7
0.
002290274
440.000602917106
0.001453100
1680.002304004
4
5
0.0006166241070.0014668181690.002317734
4
6
0
.000630331
1
08
0.001480537
1
70
0.002331465
470.000644039109
0.001494256
171
0.002345195
48
0.000657746
110
0.001507975
172
0.002358926
49
0.000671454
111
0.001521694
173
0.002372657
500.000685161
112
0.001535414
1740.002386388
51
0.000698869113
0.001549133175
0.002400120
520.000712578
114
0.001562853
176
0.002413851
53
0.000726286
1150.001576573
177
0.002427583
540.000739995
116
0.001590293
178
0.002441315
550.000753703
1170.001604014179
0.002455047
56
0.0007674121180.0016177341800.002468779
2011–13 I.R.B.579March 28, 2011

365 Day Year
0.5% Compound Rate 184 Days
DaysFactorDaysFactorDaysFactor
57
0.000781121119
0.001631455
181
0.002482511
58
0.000794831120
0.001645176
1820.002496244
590.000808540
121
0.001658897
183
0.002509977
60
0.000822250
1220.001672619184
0.002523710
61
0.000835960
1230.001686340
620.0008496701240.001700062
366 Day Year
0.5% Compound Rate 184 Days
DaysFactorDaysFactorDaysFactor
10.000013661630.000861020
125
0.001709097
20.000027323640.0008746931260.001722782
30.000040984
65
0.0008883661270.001736467
4
0.000054646
660.000902040128
0.001750152
5
0.00006830867
0.000915713
1290.001763837
60.000081970680.000929387130
0.001777522
7
0.000095632
690.0009430611310.001791208
8
0.000109295
70
0.000956735
1320.001804893
9
0.000122958
710.000970409133
0.001818579
100.000136620720.000984084134
0.001832265
11
0.000150283
73
0.0009977581350.001845951
120.000163947740.001011433136
0.001859638
130.000177610
750.001025108
1370.001873324
140.000191274760.0010387831380.001887011
15
0.00020493877
0.001052459
1390.001900698
160.000218602780.001066134140
0.001914385
170.000232266790.0010798101410.001928073
18
0.000245930
800.0010934861420.001941760
19
0.000259595
810.001107162143
0.001955448
200.000273260820.0011208391440.001969136
210.00028692483
0.001134515145
0.001982824
22
0.000300590
840.001148192146
0.001996512
23
0.00031425585
0.0011618691470.002010201
240.00032792086
0.001175546
1480.002023889
250.000341586
870.001189223149
0.002037578
26
0.000355252
880.001202900
1500.002051267
270.00036891889
0.0012165781510.002064957
28
0.000382584
90
0.001230256152
0.002078646
29
0.000396251
910.001243934
153
0.002092336
300.00040991792
0.0012576121540.002106025
31
0.000423584
930.001271291
1550.002119715
32
0.000437251
940.001284969
1560.002133405
33
0.00045091895
0.001298648
157
0.002147096
34
0.000464586
960.001312327
158
0.002160786
350.000478253
970.001326006
159
0.002174477
360.00049192198
0.001339685
1600.002188168
37
0.000505589
99
0.001353365
161
0.002201859
38
0.000519257
1000.001367044162
0.002215550
39
0.000532925
1010.0013807241630.002229242
40
0.000546594
1020.0013944041640.002242933
41
0.000560262
103
0.0014080851650.002256625
42
0.000573931
104
0.001421765
1660.002270317
43
0.0005876001050.001435446
1670.002284010
440.0006012691060.0014491271680.002297702
45
0.0006149391070.001462808169
0.002311395
March 28, 20115802011–13 I.R.B.

366 Day Year
0.5% Compound Rate 184 Days
DaysFactorDaysFactorDaysFactor
460.0006286081080.001476489170
0.002325087
470.0006422781090.0014901701710.002338780
48
0.000655948
110
0.001503852
172
0.002352473
490.000669618111
0.001517533
1730.002366167
50
0.000683289112
0.001531215
1740.002379860
510.000696959
113
0.0015448971750.002393554
52
0.000710630114
0.001558580
1760.002407248
53
0.000724301
1150.001572262
1770.002420942
54
0.000737972116
0.001585945
1780.002434636
550.000751643
117
0.001599628
1790.002448331
560.000765315
1180.001613311180
0.002462025
57
0.0007789861190.001626994181
0.002475720
580.000792658
1200.001640678182
0.002489415
59
0.000806330121
0.001654361
183
0.002503110
600.000820003122
0.001668045
184
0.002516806
61
0.000833675
1230.001681729
620.000847348124
0.001695413
TABLE OF INTEREST RATES
PERIODS BEFORE JUL. 1, 1975 — PERIODS ENDING DEC. 31, 1986
OVERPAYMENTS AND UNDERPAYMENTS
PERIODRATE
In 1995–1 C.B.
DAILY RATE TABLE
Before Jul. 1, 1975
6%
Table 2, pg. 557
Jul. 1, 1975—Jan. 31, 1976
9%
Table 4, pg. 559
Feb. 1, 1976—Jan. 31, 19787%
Table 3, pg. 558
Feb. 1, 1978—Jan. 31, 19806%
Table 2, pg. 557
Feb. 1, 1980—Jan. 31, 198212%
Table 5, pg. 560
Feb. 1, 1982—Dec. 31, 198220%
Table 6, pg. 560
Jan. 1, 1983—Jun. 30, 198316%
Table 37, pg. 591
Jul. 1, 1983—Dec. 31, 198311%
Table 27, pg. 581
Jan. 1, 1984—Jun. 30, 198411%
Table 75, pg. 629
Jul. 1, 1984—Dec. 31, 198411%
Table 75, pg. 629
Jan. 1, 1985—Jun. 30, 1985
13%
Table 31, pg. 585
Jul. 1, 1985—Dec. 31, 1985
11%
Table 27, pg. 581
Jan. 1, 1986—Jun. 30, 198610%
Table 25, pg. 579
Jul. 1, 1986—Dec. 31, 19869%
Table 23, pg. 577
TABLE OF INTEREST RATES
FROM JAN. 1, 1987 — DEC. 31, 1998
OVERPAYMENTSUNDERPAYMENTS
1995–1 C.B.1995–1 C.B.
RATE TABLEPGRATE TABLEPG
Jan. 1, 1987—Mar. 31, 19878%21
575
9%23
577
Apr. 1, 1987—Jun. 30, 19878%21
575
9%23
577
Jul. 1, 1987—Sep. 30, 19878%21
575
9%23
577
Oct. 1, 1987—Dec. 31, 19879%23
577
10%
25579
Jan. 1, 1988—Mar. 31, 198810%7362711%
75
629
Apr. 1, 1988—Jun. 30, 19889%71
625
10%73627
Jul. 1, 1988—Sep. 30, 19889%71
625
10%73627
Oct. 1, 1988—Dec. 31, 198810%7362711%
75
629
2011–13 I.R.B.581March 28, 2011

TABLE OF INTEREST RATES
FROM JAN. 1, 1987 — DEC. 31, 1998 – Continued
OVERPAYMENTSUNDERPAYMENTS
1995–1 C.B.1995–1 C.B.
RATE TABLEPGRATE TABLEPG
Jan. 1, 1989—Mar. 31, 198910%
25579
11%27
581
Apr. 1, 1989—Jun. 30, 198911%27
581
12%29
583
Jul. 1, 1989—Se
p. 30, 1989
11%27
581
12%29
583
Oct. 1, 1989—Dec. 31, 198910%
25579
11%27
581
Jan. 1, 1990—Mar. 31, 199010%
25579
11%27
581
Apr. 1, 1990—J
un. 30, 1990
10%
25579
11%27
581
Jul. 1, 1990—Sep. 30, 199010%
25579
11%27
581
Oct. 1, 1990—Dec. 31, 199010%
25579
11%27
581
Jan. 1, 1991—
Mar. 31, 1991
10%
25579
11%27
581
Apr. 1, 1991—Jun. 30, 19919%23
577
10%
25579
Jul. 1, 1991—Sep. 30, 19919%23
577
10%
25579
Oct. 1, 1991
—Dec. 31, 1991
9%23
577
10%
25579
Jan. 1, 1992—Mar. 31, 19928%696239%71
625
Apr. 1, 1992—Jun. 30, 19927%676218%69623
Jul. 1, 1992
—Sep. 30, 1992
7%676218%69623
Oct. 1, 1992—Dec. 31, 19926%
65
6197%67621
Jan. 1, 1993—Mar. 31, 19936%17
571
7%19
573
Apr. 1, 19
93—Jun. 30, 1993
6%17
571
7%19
573
Jul. 1, 1993—Sep. 30, 19936%17
571
7%19
573
Oct. 1, 1993—Dec. 31, 19936%17
571
7%19
573
Jan. 1, 19
94—Mar. 31, 1994
6%17
571
7%19
573
Apr. 1, 1994—Jun. 30, 19946%17
571
7%19
573
Jul. 1, 1994—Sep. 30, 19947%19
573
8%21
575
Oct. 1, 1
994—Dec. 31, 1994
8%21
575
9%23
577
Jan. 1, 1995—Mar. 31, 1995
8%21
575
9%23
577
Apr. 1,
1995—Jun. 30, 1995
9%23
577
10%
25579
Jul. 1, 1995—Sep. 30, 1995
8%21
575
9%23
577
Oct. 1, 1995—Dec. 31, 1995
8%21
575
9%23
577
Jan. 1, 1996—Mar. 31, 19968%696239%71
625
Apr. 1
, 1996—Jun. 30, 1996
7%676218%69623
Jul. 1, 1996—Sep. 30, 19968%696239%71
625
Oct. 1, 1996—Dec. 31, 19968%696239%71
625
Jan.
1, 1997—Mar. 31, 1997
8%21
575
9%23
577
Apr. 1, 1997—Jun. 30, 19978%21
575
9%23
577
Jul. 1, 1997—Sep. 30, 19978%21
575
9%23
577
Oct
. 1, 1997—Dec. 31, 1997
8%21
575
9%23
577
Jan. 1, 1998—Mar. 31, 19988%21
575
9%23
577
Apr. 1, 1998—Jun. 30, 19987%19
573
8%21
575
Jul
. 1, 1998—Sep. 30, 1998
7%19
573
8%21
575
Oct. 1, 1998—Dec. 31, 19987%19
573
8%21
575
TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 — PRESENT
NONCORPORATE OVERPAYMENTS AND UNDERPAYMENTS
1995–1 C.B.
RATETABLEPG
Jan. 1, 1999—Mar. 31, 19997%19
573
Apr
. 1, 1999—Jun. 30, 1999
8%21
575
Jul. 1, 1999—Sep. 30, 19998%21
575
Oct. 1, 1999—Dec. 31, 19998%21
57
5
Ja
n. 1, 2000—Mar. 31, 2000
8%6962
3
Apr. 1, 2000—Jun. 30, 20009%71
625
March 28, 20115822011–13 I.R.B.

TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 — PRESENT – Continued
NONCORPORATE OVERPAYMENTS AND UNDERPAYMENTS
1995–1 C.B.
RATETABLEPG
Jul. 1, 2000—Sep. 30, 20009%71
625
Oct. 1, 2000—Dec. 31, 20009%71
625
Jan. 1, 2001—Mar. 31, 20019%23
577
Apr. 1, 2001—Jun. 30, 20018%21
575
Jul. 1, 2001—Sep. 30, 20017%19
573
Oct. 1, 2001—Dec. 31, 20017%19
573
Jan. 1, 2002—Mar. 31, 20026%17
571
Apr. 1, 2002—Jun. 30, 20026%17
571
Jul. 1, 2002—Sep. 30, 20026%17
571
Oct. 1, 2002—Dec. 31, 20026%17
571
Jan. 1, 2003—Mar. 31, 2003
5%15569
Apr. 1, 2003—Jun. 30, 2003
5%15569
Jul. 1, 2003—Sep. 30, 2003
5%15569
Oct. 1, 2003—Dec. 31, 20034%13
567
Jan. 1, 2004—Mar. 31, 20044%61
615
Apr. 1, 2004—Jun. 30, 2004
5%
63617
Jul. 1, 2004—Sep. 30, 20044%61
615
Oct. 1, 2004—Dec. 31, 2004
5%
63617
Jan. 1, 2005—Mar. 31, 20055%15569
Apr. 1, 2005—Jun. 30, 2005
6%17
571
Jul. 1, 2005—Sep. 30, 2005
6%17
571
Oct. 1, 2005—Dec. 31, 2005
7%19
573
Jan. 1, 2006—Mar. 31, 20067%19
573
Apr. 1, 2006—Jun. 30, 20067%19
573
Jul. 1, 2006—Sep. 30, 20068%21
575
Oct. 1, 2006—Dec. 31, 20068%21
575
Jan. 1, 2007—Mar. 31, 20078%21
575
Apr. 1, 2007—Jun. 30, 20078%21
575
Jul. 1, 2007—Sep. 30, 20078%21
575
Oct. 1, 2007—Dec. 31, 20078%21
575
Jan. 1, 2008—Mar. 31, 20087%67621
Apr. 1, 2008—Jun. 30, 20086%
65
619
Jul. 1, 2008—Sep. 30, 2008
5%
63617
Oct. 1, 2008—Dec. 31, 20086%
65
619
Jan. 1, 2009—Mar. 31, 2009
5%15569
Apr. 1, 2009—Jun. 30, 20094%13
567
Jul. 1, 2009—Sep. 30, 20094%13
567
Oct. 1, 2009—Dec. 31, 20094%13
567
Jan. 1, 2010—Mar. 31, 20104%13
567
Apr. 1, 2010—Jun. 30, 20104%13
567
Jul. 1, 2010—Sep. 30, 20104%13
567
Oct. 1, 2010—Dec. 31, 20104%13
567
Jan. 1, 2011—Mar. 31, 20113%11
565
Apr. 1, 2011—June 30, 20114%13
567
2011–13 I.R.B.583March 28, 2011

TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 — PRESENT
CORPORATE OVERPAYMENTS AND UNDERPAYMENTS
OVERPAYMENTSUNDERPAYMENTS
1995–1 C.B.1995–1 C.B.
RATE TABLEPGRATE TABLEPG
Jan. 1, 1999—Mar. 31, 19996%17
571
7%19
573
Apr. 1, 1999—Jun
. 30, 1999
7%19
573
8%21
575
Jul. 1, 1999—Sep. 30, 19997%19
573
8%21
575
Oct. 1, 1999—Dec. 31, 19997%19
573
8%21
575
Jan. 1, 2000—Ma
r. 31, 2000
7%676218%69623
Apr. 1, 2000—Jun. 30, 20008%696239%71
625
Jul. 1, 2000—Sep. 30, 20008%696239%71
625
Oct. 1, 2000—D
ec. 31, 2000
8%696239%71
625
Jan. 1, 2001—Mar. 31, 20018%21
575
9%23
577
Apr. 1, 2001—Jun. 30, 20017%19
573
8%21
575
Jul. 1, 2001—
Sep. 30, 2001
6%17
571
7%19
573
Oct. 1, 2001—Dec. 31, 20016%17
571
7%19
573
Jan. 1, 2002—Mar. 31, 2002
5%15569
6%17
571
Apr. 1, 2002
—Jun. 30, 2002
5%15569
6%17
571
Jul. 1, 2002—Sep. 30, 2002
5%15569
6%17
571
Oct. 1, 2002—Dec. 31, 2002
5%15569
6%17
571
Jan. 1, 200
3—Mar. 31, 2003
4%13
5675%15569
Apr. 1, 2003—Jun. 30, 20034%13
5675%15569
Jul. 1, 2003—Sep. 30, 20034%13
5675%15569
Oct. 1, 20
03—Dec. 31, 2003
3%11
565
4%13
567
Jan. 1, 2004—Mar. 31, 20043%
59
6134%61
615
Apr. 1, 2004—Jun. 30, 20044%61
6155%
63617
Jul. 1, 2
004—Sep. 30, 2004
3%
59
6134%61
615
Oct. 1, 2004—Dec. 31, 20044%61
6155%
63617
Jan. 1, 2
005—Mar. 31, 2005
4%13
5675%15569
Apr. 1, 2005—Jun. 30, 20055%15569
6%17
571
Jul. 1, 2005—Sep. 30, 20055%15569
6%17
571
Oct. 1,
2005—Dec. 31, 2005
6%17
571
7%19
573
Jan. 1,
2006—Mar. 31, 2006
6%17
571
7%19
573
Apr. 1, 2006—Jun. 30, 20066%17
571
7%19
573
Jul. 1, 2006—Sep. 30, 20067%19
573
8%21
575
Oct. 1
, 2006—Dec. 31, 2006
7%19
573
8%21
575
Jan. 1, 2007—Mar. 31, 20077%19
573
8%21
575
Apr. 1, 2007—Jun. 30, 20077%19
573
8%21
575
Jul.
1, 2007—Sep. 30, 2007
7%19
573
8%21
575
Oct. 1, 2007—Dec. 31, 20077%19
573
8%21
575
Jan. 1, 2008—Mar. 31, 20086%
65
6197%67621
Apr
. 1, 2008—Jun. 30, 2008
5%
636176%
65
619
Jul. 1, 2008—Sep. 30, 20084%61
6155%
63617
Oct. 1, 2008—Dec. 31, 2008
5%
636176%
65
619
Jan
. 1, 2009—Mar. 31, 2009
4%13
5675%15569
Apr. 1, 2009—Jun. 30, 20093%11
565
4%13
567
Jul. 1, 2009—Sep. 30, 20093%11
56
5
4%13
56
7
Oc
t. 1, 2009—Dec. 31, 2009
3%11
565
4%13
567
Jan. 1, 2010—Mar. 31, 20103%11
565
4%13
567
Apr. 1, 2010—Jun. 30, 20103%11
5
65
4%13
5
67
J
ul. 1, 2010—Sep. 30, 2010
3
%
1
1
565
4
%
1
3
567
Oct. 1, 2010—Dec. 31, 20103%11
565
4%13
567
Jan. 1, 2011—Mar. 31, 20112%9
563
3%11
565
Apr. 1, 2011—June 30, 20113%11
565
4%13
567
March 28, 20115842011–13 I.R.B.

TABLE OF INTEREST RATES FOR
LARGE CORPORATE UNDERPAYMENTS
FROM JANUARY 1, 1991 — PRESENT
1995–1 C.B.
RATETABLEPG
Jan. 1, 1991—Mar. 31, 199113%31
585
Apr. 1, 1991—Jun. 30, 199112%29
583
Jul. 1, 1991—Sep. 30, 199112%29
583
Oct. 1, 1991—Dec. 31, 199112%29
583
Jan. 1, 1992—Mar. 31, 199211%
75
629
Apr. 1, 1992—Jun. 30, 199210%73627
Jul. 1, 1992—Sep. 30, 199210%73627
Oct. 1, 1992—Dec. 31, 19929%71
625
Jan. 1, 1993—Mar. 31, 19939%23
577
Apr. 1, 1993—Jun. 30, 19939%23
577
Jul. 1, 1993—Sep. 30, 19939%23
577
Oct. 1, 1993—Dec. 31, 19939%23
577
Jan. 1, 1994—Mar. 31, 19949%23
577
Apr. 1, 1994—Jun. 30, 19949%23
577
Jul. 1, 1994—Sep. 30, 199410%
25579
Oct. 1, 1994—Dec. 31, 199411%27
581
Jan. 1, 1995—Mar. 31, 1995
11%27
581
Apr. 1, 1995—Jun. 30, 1995
12%29
583
Jul. 1, 1995—Sep. 30, 1995
11%27
581
Oct. 1, 1995—Dec. 31, 1995
11%27
581
Jan. 1, 1996—Mar. 31, 199611%
75
629
Apr. 1, 1996—Jun. 30, 199610%73627
Jul. 1, 1996—Sep. 30, 199611%
75
629
Oct. 1, 1996—Dec. 31, 199611%
75
629
Jan. 1, 1997—Mar. 31, 199711%27
581
Apr. 1, 1997—Jun. 30, 199711%27
581
Jul. 1, 1997—Sep. 30, 199711%27
581
Oct. 1, 1997—Dec. 31, 199711%27
581
Jan. 1, 1998—Mar. 31, 199811%27
581
Apr. 1, 1998—Jun. 30, 199810%
25579
Jul. 1, 1998—Sep. 30, 199810%
25579
Oct. 1, 1998—Dec. 31, 199810%
25579
Jan. 1, 1999—Mar. 31, 19999%23
577
Apr. 1, 1999—Jun. 30, 199910%
25579
Jul. 1, 1999—Sep. 30, 199910%
25579
Oct. 1, 1999—Dec. 31, 199910%
25579
Jan. 1, 2000—Mar. 31, 200010%73627
Apr. 1, 2000—Jun. 30, 200011%
75
629
Jul. 1, 2000—Sep. 30, 200011%
75
629
Oct. 1, 2000—Dec. 31, 200011%
75
629
Jan. 1, 2001—Mar. 31, 200111%27
581
Apr. 1, 2001—Jun. 30, 200110%
25579
Jul. 1, 2001—Sep. 30, 20019%23
577
Oct. 1, 2001—Dec. 31, 20019%23
577
Jan. 1, 2002—Mar. 31, 20028%21
575
Apr. 1, 2002—Jun. 30, 20028%21
575
Jul. 1, 2002—Sep. 30, 20028%21
575
Oct. 1, 2002—Dec. 30, 20028%21
575
Jan. 1, 2003—Mar. 31, 20037%19
573
Apr. 1, 2003—Jun. 30, 20037%19
573
Jul. 1, 2003—Sep. 30, 20037%19
573
Oct. 1, 2003—Dec. 31, 20036%17
571
Jan. 1, 2004—Mar. 31, 20046%
65
619
Apr. 1, 2004—Jun. 30, 20047%67621
Jul. 1, 2004—Sep. 30, 20046%
65
619
Oct. 1, 2004—Dec. 31, 20047%67621
2011–13 I.R.B.585March 28, 2011

TABLE OF INTEREST RATES FOR
LARGE CORPORATE UNDERPAYMENTS
FROM JANUARY 1, 1991 — PRESENT – Continued
1995–1 C.B.
RATETABLEPG
Jan. 1, 2005—Mar. 31, 2005
7%19
573
Apr. 1, 2005—Jun. 30, 2005
8%21
575
Jul. 1, 2005—Sep. 30, 2005
8%21
575
Oct. 1, 2005—Dec. 31, 2005
9%23
577
Jan. 1, 2006—Mar. 31, 20069%23
577
Apr. 1, 2006—Jun. 30, 20069%23
577
Jul. 1, 2006—Sep. 30, 200610%
25579
Oct. 1, 2006—Dec. 31, 200610%
25579
Jan. 1, 2007—Mar. 31, 200710%
25579
Apr. 1, 2007—Jun. 30, 200710%
25579
Jul. 1, 2007—Sep. 30, 200710%
25579
Oct. 1, 2007—Dec. 31, 200710%
25579
Jan. 1, 2008—Mar. 31, 20089%71
625
Apr. 1, 2008—Jun. 30, 20088%69623
Jul. 1, 2008—Sep. 30, 20087%67621
Oct. 1, 2008—Dec. 31, 20088%69623
Jan. 1, 2009—Mar. 31, 20097%19
573
Apr. 1, 2009—Jun. 30, 20096%17
571
Jul. 1, 2009—Sep. 30, 20096%17
571
Oct. 1, 2009—Dec. 31, 20096%17
571
Jan. 1, 2010—Mar. 31, 20106%17
571
Apr. 1, 2010—Jun. 30, 20106%17
571
Jul. 1, 2010—Sep. 30, 20106%17
571
Oct. 1, 2010—Dec. 31, 20106%17
571
Jan. 1, 2011—Mar. 31, 2011
5%15569
Apr. 1, 2011—June 30, 20116%17
571
TABLE OF INTEREST RATES FOR CORPORATE
OVERP
AYMENTS EXCEEDING $10,000
FROM JANUARY 1, 1995 — PRESENT
1995–1 C.B.
RATETABLEPG
Jan. 1, 1995—Mar. 31, 19956.5%
18
572
Apr. 1, 1995—Jun. 30, 19957.5%
20
574
Jul. 1, 1995—Sep. 30, 19956.5%
18
572
Oct. 1, 1995—Dec. 31, 19956.5%
18
572
Jan. 1, 1996—Mar. 31, 1996
6.5%
66620
Apr. 1, 1996—Jun. 30, 1996
5.5%
64618
Jul. 1, 1996—Sep. 30, 1996
6.5%
66620
Oct. 1, 1996—Dec. 31, 1996
6.5%
66620
Jan. 1, 1997—Mar. 31, 1997
6.5%
18
572
Apr. 1, 1997—Jun. 30, 1997
6.5%
18
572
Jul. 1, 1997—Sep. 30, 1997
6.5%
18
572
Oct. 1, 1997—Dec. 31, 1997
6.5%
18
572
Jan. 1, 1998—Mar. 31, 1998
6.5%
18
572
Apr. 1, 1998—Jun. 30, 1998
5.5%
16
570
Jul. 1, 1998—Sep. 30, 1998
5.5%
16
570
Oct. 1, 1998—Dec. 31, 1998
5.5%
16
570
Jan. 1, 1999—Mar. 31, 1999
4.5%
14
568
Apr. 1, 1999—Jun. 30, 1999
5.5%
16
570
Jul. 1, 1999—Sep. 30, 1999
5.5%
16
570
Oct. 1, 1999—Dec. 31, 1999
5.5%
16
570
March 28, 20115862011–13 I.R.B.

TABLE OF INTEREST RATES FOR CORPORATE
OVERPAYMENTS E
XCEEDING $10,000
FROM JANUARY 1, 1995 — PRESENT – Continued
1995–1 C.B.
RATETABLEPG
Jan. 1, 2000—Mar. 31, 2000
5.5%
64618
Apr. 1, 2000—Jun. 30, 2000
6.5%
66620
Jul. 1, 2000—Sep. 30, 2000
6.5%
66620
Oct. 1, 2000—Dec. 31, 2000
6.5%
66620
Jan. 1, 2001—Mar. 31, 2001
6.5%
18
572
Apr. 1, 2001—Jun. 30, 2001
5.5%
16
570
Jul. 1, 2001—Sep. 30, 2001
4.5%
14
568
Oct. 1, 2001—Dec. 31, 2001
4.5%
14
568
Jan. 1, 2002—Mar. 31, 2002
3.5%
12
566
Apr. 1, 2002—Jun. 30, 2002
3.5%
12
566
Jul. 1, 2002—Sep. 30, 2002
3.5%
12
566
Oct. 1, 2002—Dec. 31, 2002
3.5%
12
566
Jan. 1, 2003—Mar. 31, 2003
2.5%
10
564
Apr. 1, 2003—Jun. 30, 2003
2.5%
10
564
Jul. 1, 2003—Sep. 30, 2003
2.5%
10
564
Oct. 1, 2003—Dec. 31, 2003
1.5%
8
562
Jan. 1, 2004—Mar. 31, 2004
1.5%56
610
Apr. 1, 2004—Jun. 30, 2004
2.5%58
612
Jul. 1, 2004—Sep. 30, 2004
1.5%56
610
Oct. 1, 2004—Dec. 31, 2004
2.5%58
612
Jan. 1, 2005—Mar. 31, 20052.5%
10
564
Apr. 1, 2005—Jun. 30, 20053.5%
12
566
Jul. 1, 2005—Sep. 30, 20053.5%
12
566
Oct. 1, 2005—Dec. 31, 20054.5%
14
568
Jan. 1, 2006—Mar. 31, 2006
4.5%
14
568
Apr. 1, 2006—Jun. 30, 2006
4.5%
14
568
Jul. 1, 2006—Sep. 30, 2006
5.5%
16
570
Oct. 1, 2006—Dec. 31, 2006
5.5%
16
570
Jan. 1, 2007—Mar. 31, 2007
5.5%
16
570
Apr. 1, 2007—Jun. 30, 2007
5.5%
16
570
Jul. 1, 2007—Sep. 30, 2007
5.5%
16
570
Oct. 1, 2007—Dec. 31, 2007
5.5%
16
570
Jan. 1, 2008—Mar. 31, 2008
4.5%
62616
Apr. 1, 2008—Jun. 30, 2008
3.5%
60614
Jul. 1, 2008—Sep. 30, 2008
2.5%58
612
Oct. 1, 2008—Dec. 31, 2008
3.5%
60614
Jan. 1, 2009—Mar. 31, 2009
2.5%
10
564
Apr. 1, 2009—Jun. 30, 2009
1.5%
8
562
Jul. 1, 2009—Sep. 30, 2009
1.5%
8
562
Oct. 1, 2009—Dec. 31, 2009
1.5%
8
562
Jan. 1, 2010—Mar. 31, 2010
1.5%
8
562
Apr. 1, 2010—Jun. 30, 2010
1.5%
8
562
Jul. 1, 2010—Sep. 30, 2010
1.5%
8
562
Oct. 1, 2010—Dec. 31, 2010
1.5%
8
562
Jan. 1, 2011—Mar. 31, 2011
0.5%*
Apr. 1, 2011—June 30, 2011
1.5%
8
562
2011–13 I.R.B.587March 28, 2011

Part III. Administrative, Procedural, and Miscellaneous
Request for Comments
Regarding Application of
§ 501(c)(29) of the Internal
Revenue Code
Notice 2011–23
SECTION 1. PURPOSE
This notice addresses the requirements
for tax exemption for qualified non-
profit health insurance issuers described
in new § 501(c)(29), added to the Inter-
nal Revenue Code (Code) by § 1322(h)
of the Patient Protection and Affordable
Care Act (Affordable Care Act), enacted
March 23, 2010, Pub. L. No. 111–148.
This notice provides guidance on the
annual filing requirement for qualified
nonprofit health insurance issuers that
intend to apply for recognition of exempt
status under § 501(c)(29), as well as
theeffectivedateofexemptstatusfor
certain applicants. The IRS intends to
issue a revenue procedure on how and
when qualified nonprofit health insurance
issuers described in § 501(c)(29) may
apply for recognition of exempt status.
This notice includesa request for public
comments.
SECTION 2. BACKGROUND
Section 1322 of the Affordable Care
Act requires the Department of Health
and Human Services (HHS) to establish
the Consumer Operated and Oriented Plan
program (CO-OP program). The purpose
of the CO-OP program is to foster the
creation of qualified nonprofit health in-
surance issuers to offer qualified health
plans in individual and small group mar-
kets. The CO-OP program will make
available to qualified nonprofit health in-
surance issuers loans to provide assistance
in meeting start-up costs and/or repayable
grants to provide assistance in meeting
any state solvency requirements. HHS has
published a request for comments regard-
ing the CO-OP program. See Planning and
Establishment of Consumer Operated and
Oriented Plan Program; Request for Com-
ments Regarding Provisions of Consumer
Operated and Oriented Plan Program,
76 Fed. Reg. 5774 (Feb. 2, 2011).
Section 1322(h) of the Affordable Care
Act added § 501(c)(29) to the Code. Sec-
tion 501(c)(29) sets out rules for tax-ex-
emption under § 501(a) of the Code for a
qualified nonprofit health insurance issuer
that has received a grant or loan under the
CO-OP program.
SECTION 3. QUALIFIED NONPROFIT
HEALTH INSURANCE ISSUERS
Section 1322(c)(1) of the Affordable
Care Act defines a qualified nonprofit
health insurance issuer (“Qualified Is-
suer”) as an organization (a) that is orga-
nized as a nonprofit, member corporation
under State law; (b) substantially all of the
activities of which consist of the issuance
of qualified health plans in the individual
and small group markets in each State in
which it is licensed to issue such plans;
and (c) that meets additional requirements
set forth in subsections (c)(2) through (6).
Section 1322(c)(2) of the Affordable
Care Act provides that an organization
shall not be treated as a Qualified Issuer
if (a) the organization, a related entity,
or a predecessor of either was a health
insurance issuer as of July 16, 2009; or (b)
the organization is sponsored by a State
or local government, any political subdi-
vision thereof, or any instrumentality of
such government or political subdivision.
Section 1322(c)(3) requires a Qualified
Issuer to satisfy certain governance re-
quirements. Section1322(c)(4) requires
a Qualified Issuer to use any profits that
it makes to lower premiums, to improve
benefits, or for other programs intended to
improve the quality of health care deliv-
ered to its members. Section 1322(c)(5)
requires a Qualified Issuer to meet all
state law requirements that other issuers
of qualified health plans are required to
meet in any state where the issuer offers a
qualified health plan. Section 1322(c)(6)
provides that a Qualified Issuer may not
offer a health plan in a state until that state
has in effect (or the Secretary of HHS has
implemented for the state) the market re-
forms required by part A of title XXVII of
the Public Health Service Act, as amended
by the Affordable Care Act.
Section 1322(b)(2)(C) of the Afford-
able Care Act requires a Qualified Issuer
receiving a grant or loan under the CO-OP
program to enter into an agreement with
HHS, which requires it to meet (and con-
tinue to meet) both the requirements under
§ 1322 to be treated as a Qualified Issuer,
and all requirements of the loan or grant
agreement. Such an agreement must in-
clude a requirement that no portion of the
funds made available by any loan or grant
under the CO-OP program may be used
for carrying on propaganda, or otherwise
attempting, to influence legislation, or for
marketing.
A Qualified Issuer that has received a
loan or grant under the CO-OP program
may apply to the IRS to be recognized as
an organization described in § 501(c)(29)
of the Code and exempt from taxation un-
der § 501(a) of the Code. The Qualified
Issuer will qualify for exempt status un-
der § 501(c)(29) only for periods that it
is in compliance with the requirements of
§ 1322 of the Affordable Care Act and any
loan or grant agreement with HHS. Un-
der § 1322(b)(2)(C)(iii) of the Affordable
Care Act, HHS must notify the Secretary
of the Treasury of any determination under
§ 1322 of a failure that results in the termi-
nation of a Qualified Issuer’s tax-exempt
status under § 501(c)(29) of the Code.
If a Qualified Issuer that has received
a loan or grant under the CO-OP pro-
gram does not apply for recognition of
exempt status as an organization described
in § 501(c)(29) or loses exempt status, it
may be subject to Federal income taxation
under appropriate provisions of the Code.
If a taxable Qualified Issuer qualifies as an
insurance company for Federal income tax
purposes, it will be subject to the special
tax rules of Subchapter L of the Code.
SECTION 4. CONDITIONS FOR TAX
EXEMPTION
An organization is described in
§ 501(c)(29) of the Code only if :
1. The organization is a Qualified Is-
suer that has received a loan or grant un-
der the CO-OP program and is in compli-
ance with all requirements of § 1322 and
any loan or grant agreement with HHS.
2. The organization has given notice to
the Secretary of the Treasury in the manner
prescribed by regulations that it is applying
for recognition of its exempt status as an
organization described in § 501(c)(29);
March 28, 20115882011–13 I.R.B.

3. No part of the organization’s net
earnings inure to the benefit of any pri-
vate shareholder or individual, except as
provided in § 1322(c)(4) of the Affordable
Care Act (which requires profits to be used
to lower premiums, improve benefits, or
for other programs intended to improve the
quality of health care delivered to the or-
ganization’s members);
4. No substantial part of the organiza-
tion’s activities consist of carrying on pro-
paganda, or otherwise attempting, to influ-
ence legislation; and
5. The organization does not participate
in, or intervene in (including the publish-
ing or distributing of statements), any po-
litical campaign on behalf of (or in oppo-
sition to) any candidate for public office.
SECTION 5. ADDITIONAL
INFORMATION REPORTING
REQUIRED
Section 6033 of the Code requires
a tax-exempt organization described in
§ 501(c)(29) to file an annual information
return. Section 1322(h)(2) of the Afford-
able Care Act amended § 6033 of the Code
to require an organization described in
§ 501(c)(29) to provide certain additional
information on its annual information re-
turn. In addition to the general information
required, it must report the amount of re-
serves required by each State in which the
organization is licensed to issue qualified
health plans, and the amount of reserves
on hand.
SECTION 6. APPLICATION
OF TAX ON EXCESS BENEFIT
TRANSACTIONS
Section 4958 of the Code imposes an
excise tax, payable by the disqualified
person, on each excess benefit transac-
tion between an applicable tax-exempt
organization and a disqualified person.
Section 4958 also imposes an excise tax
on organization managers who knowingly
participated in an excess benefit transac-
tion, unless participation was not willful
and was due to reasonable cause. Section
1322(h)(3) of the Affordable Care Act
amended § 4958(e)(1) to provide that an
organization described in § 501(c)(29) is
an “applicable tax-exempt organization”
subject to § 4958.
SECTION 7. APPLICATIONS FOR
RECOGNITION OF EXEMPTION
The IRS intends to publish a revenue
procedure describing how an organiza-
tion may apply for recognition of exempt
status as an organization described in
§ 501(c)(29). Until the revenue procedure
is published, the IRS will not accept ap-
plications. The revenue procedure will
provide that a Qualified Issuer may not
submit its request for recognition of ex-
emption under § 501(c)(29) until it has
entered into an agreement with HHS under
§ 1322(b)(2)(C) of the Affordable Care
Act.
The revenue procedure also will ad-
dress the effective date of a Qualified Is-
suer’s tax exemption. The Treasury De-
partment and the IRS intend to recognize
a Qualified Issuer that has received a loan
or grant under the CO-OP program as ex-
empt effective from the later of the date of
its formation or March 23, 2010, provided
that the Qualified Issuer’s purposes and ac-
tivities have been consistent with the re-
quirements for exemption since that date.
To be recognized as exempt from the date
of its formation, a Qualified Issuer must
have complied with the conditions of ex-
emption described in clauses (ii)-(iv) of
§ 501(c)(29)(B).
SECTION 8. ANNUAL FILING
REQUIREMENT PRIOR TO
RECOGNITION OF EXEMPT STATUS
A Qualified Issuer claiming exempt sta-
tus under § 501(c)(29) that has filed or in-
tends to file an application for exemption
should file Form 990,Return of Organiza-
tion Exempt from Income Tax, for taxable
years that end before it receives a determi-
nation letter. The Qualified Issuer must in-
dicate on its return that it is being filed in
the belief that the Qualified Issuer is ex-
empt under § 501(a), but the IRS has not
yet recognized its exemption.
SECTION 9. EFFECTIVE DATE
The provisions of § 1322 of the Afford-
able Care Act, including the addition to
the Code of § 501(c)(29) and the amend-
mentsto§§6033and4958oftheCodede-
scribed above, are effective beginning on
March 23, 2010, the date of enactment of
theAffordableCareAct.
SECTION 10. REQUEST FOR
COMMENTS
The Treasury Department and the IRS
request comments regarding the pro-
visions described above, including, in
particular, the need, if any, for guidance
regarding such provisions. Comments are
specifically requested regarding:
1. Any special factors the IRS should
consider when establishing the procedures
for applying for recognition of tax-exempt
status under § 501(c)(29);
2. The proposed effective date of a
Qualified Issuer’s tax exemption, as de-
scribed in section 7 of this notice; and
3. Any special considerations regard-
ing the application to Qualified Issuers
of the prohibition on private inurement
in § 501(c)(29)(B)(ii), the limitation on
lobbying activities in § 501(c)(29)(B)(iii),
the prohibition on political activities in
501(c)(29)(B)(iv), the taxation of excess
benefit transactions under § 4958, and
the taxation of unrelated business taxable
income under § 511.
Comments should be submitted in writ-
ing on or before May 27, 2011. Please in-
clude “Notice 2011–23” on the cover page.
Comments should be sent to the following
address:
Internal Revenue Service
CC:PA:LPD:PR (Notice 2011–23)
Room 5203
P.O. Box 7604
Ben Franklin Station
Washington, DC 20044
Submissions may be hand delivered
Monday through Friday between the hours
of 8 a.m. and 4 p.m. to:
Internal Revenue Service
Courier’s Desk
1111 Constitution Ave., N.W.
Washington, DC 20224
Attn: CC:PA:LPD:PR
(Notice 2011–23)
Submissions may also be sent electron-
ically to the following e-mail address:
Notice.Comments@irscounsel.treas.gov
Please include “Notice 2011–23” in the
subject line.
All comments will be available for pub-
lic inspection and copying.
2011–13 I.R.B.589March 28, 2011

SECTION 11. DRAFTING
INFORMATION
The principal author of this notice is
Justin Lowe of the Exempt Organizations,
Tax Exempt and Government Entities Di-
vision. For further information regarding
this notice, contact Mr. Lowe at (202)
283–9486 (not a toll-free call).
March 28, 20115902011–13 I.R.B.

Part IV. Items o
fGeneralInterest
Notice of Prop
osed
Rulemaking
Disclosure of
Information
to State Offic
ials Regarding
Tax-Exempt O
rganizations
REG–140108–08
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of proposed rulemaking.
SUMMARY: This document contains
proposed regulations that amend existing
regulations to reflect changes to section
6104(c) of the Internal Revenue Code
(Code) made by the Pension Protection
Act of 2006 (PPA). These rules provide
guidance to states regarding the process by
which they may obtain or inspect certain
returns and return information (includ-
ing information about final and proposed
denials and revocations of tax-exempt
status) for the purpose of administering
state laws governing certain tax-exempt
organizations and their activities. These
regulations will affect such exempt orga-
nizations, as well as those state agencies
choosing to obtain information from the
Internal Revenue Service (IRS) under sec-
tion 6104(c).
DATES: Written or electronic comments
and requests for a public hearing must be
received by June 13, 2011.
ADDRESSES: Send submissions to:
CC:PA:LPD:PR(REG–140108–08),
Room 5203, Internal Revenue Service,
P.O. Box 7604, Ben Franklin Station,
Washington, DC 20044. Submissions may
be hand-delivered Monday through Friday
between the hours of 8 a.m. and 4 p.m.
to CC:PA:LPD:PR (REG–140108–08),
Courier’s Desk, Internal Revenue
Service, 1111 Constitution Avenue, NW,
Washington, DC, or sent electronically
viatheFederaleRulemaking
Portal atwww.regulations.gov(IRS
REG–140108–08).
FO
R FURTHER INFORMATION
CO
NTACT: Concerning submission
of comments, O
luwafunmilayo Taylor,
(202) 622–718
0 (not a toll-free number);
concerning th
e proposed regulations,
Casey Lothame
r, (202) 622–6070 (not a
toll-free num
ber).
SUPPLEMENTAR
Y INFORMATION:
Background
I. In general
This documen
t contains proposed
amendments t
o 26 CFR part 301 under
section 6104
(c), which will replace current
§301.6104(c
)–1initsentirety. Section
6104(c) gov
erns when the IRS may dis-
close to sta
te officials certain information
about organ
izations described in section
501(c)(3) (
“charitable organizations”),
organizati
ons that have applied for recog-
nition as o
rganizations described in section
501(c)(3)
(“applicants”), and certain other
exempt org
anizations. Section 6104(c)
was added t
o the Code by section 101(e) of
the Tax Ref
orm Act of 1969 (Public Law
91–172, 8
3 Stat. 523) and significantly
amended b
y section 1224(a) of the PPA
(Public L
aw 109–280, 120 Stat. 1091).
Section 5
01(c)(3) organizations may
be affect
ed by the expanded disclosures to
state off
icials authorized under the statute
and prop
osed regulations. First, the IRS
is now au
thorized (under new section
6104(c)
(2), as added by the PPA) to dis-
close in
formation about certain proposed
revocat
ions and proposed denials before
an admi
nistrative appeal has been made
and a fi
nal revocation or denial has been
issued
. For those organizations that have
receiv
ed a determination letter stating that
they ar
e described in section 501(c)(3),
the IR
S may disclose a proposed revoca-
tion (
before any administrative appeal) to
an app
ropriate state officer (ASO). This
broad
er authority applies both where the
organ
ization was required under section
508 t
o apply for the determination let-
ter a
nd where the organization elected
to ap
ply for a determination letter even
thou
gh it was not required to do so. The
IRS c
ontinues to be authorized to disclose
fina
l revocations and final denials issued
aft
er any administrative appeal has been
con
cluded for any section 501(c)(3) or-
gan
ization.
Second, under
the authority of new sec-
tion 6104(c)(
2)(D), as added by the PPA,
the IRS may dis
close returns or return in-
formation of a
ny section 501(c)(3) organ-
ization to ASO
s on its own initiative, re-
gardless of w
hether it has initiated an ex-
amination, i
f it determines that the infor-
mation may be
evidence of noncompliance
with state la
ws under the jurisdiction of
the ASO. Thu
s, if the IRS believes these
conditions
are met, it may, for example,
disclose to
ASOs a proposed revocation
of exemptio
n for a section 501(c)(3) or-
ganizatio
n that does not have a determina-
tion lette
r. All disclosures authorized un-
der sectio
n 6104(c) may be made only if
the state r
eceiving the information is fol-
lowing app
licable disclosure, recordkeep-
ing and sa
feguard procedures.
The statut
e and proposed regulations
also perm
it disclosure of information to
state off
icials about all applicants for sec-
tion 501(
c)(3) status.
Exempt or
ganizations other than sec-
tion 501(
c)(3) organizations also may be
affected
by the disclosures to state offi-
cials au
thorized under the statute and pro-
posed re
gulations. The IRS is authorized
to discl
ose returns and return information
of these
organizations to ASOs upon writ-
ten requ
est, but only to the extent nec-
essary
to administer state laws regulating
the sol
icitation or administration of char-
itable
funds or charitable assets. Again,
all suc
h disclosures may be made only if
the sta
te receiving the information is fol-
lowin
g applicable disclosure, recordkeep-
ing an
d safeguard procedures.
Secti
on 6104(c)(1), which is unchanged
by the
PPA, directs the IRS to share certain
infor
mation with ASOs regarding charita-
ble or
ganizations and applicants. Specifi-
cally
, section 6104(c)(1) provides that the
IRS i
s to notify the ASO of the follow-
ing f
inal determinations: (1) a refusal to
reco
gnize an entity as an organization de-
scri
bedinsection501(c)(3);(2)theopera-
tion
of a section 501(c)(3) organization in
ama
nner not meeting, or no longer meet-
ing
, the requirements of its exemption; and
(3)
themailingofanoticeofdeficiency
for
any tax imposed under section 507,
cha
pter 41, or chapter 42. See section
610
4(c)(1)(A) and (c)(1)(B). The direc-
ti
ve under section 6104(c)(1)(A) to notify
2011–13 I.R.B.591March 28, 2011

ASOs of an organization no longer meet-
ing the requirements for exemption under
section 501(c)(3) includes not only notice
of a revocation of exemption, but also no-
tice (when the IRS is so informed) that
a charitable organization is terminating or
has dissolved in accordance with its gov-
erning documents. Upon request, an ASO
mayinspectandcopythereturns,filed
statements, records, reports, and other in-
formation relating to a final determination
as described in this paragraph, as are rele-
vant to any determination under state law.
See section 6104(c)(1)(C).
II. PPA changes to section 6104(c)
The PPA amended section 6104(c) by
striking paragraph (2) and inserting new
paragraphs (2) through (6) as follows.
(1) The IRS may disclose to an ASO
proposed refusals to recognize organi-
zations as charitable organizations, and
proposed revocations of such recognition.
The PPA also allows disclosure of no-
tices of proposed deficiencies of excise
taxes imposed by section 507 and chapters
41 and 42 relating to charitable orga-
nizations. See section 6104(c)(2)(A)(i)
and (c)(2)(A)(ii). Previously, only final
determinations of this kind (denials of
recognition, revocations, and notices of
deficiency) could be disclosed under sec-
tion 6104(c).
(2) The IRS may disclose to an ASO the
names, addresses, and taxpayer identifica-
tion numbers of applicants. See section
6104(c)(2)(A)(iii). Previously, informa-
tion on applicants, other than information
relating to a denial of recognition, could
not be disclosed under section 6104(c).
(3) The IRS may disclose to an ASO the
returns and return information of organi-
zations with respect to which information
is disclosed as described in paragraphs (1)
and (2) of this section II (proposed deter-
minations and applicant identifying infor-
mation). See section 6104(c)(2)(B). Prior
law allowed for disclosure under section
6104(c) only of returns and return informa-
tion related to final determinations.
(4) Proposed determinations, identify-
ing information, and the related returns and
return information with respect to chari-
table organizations and applicants may be
disclosed to an ASO only upon the ASO’s
written request and only as necessary to
administer state laws regulating charita-
ble organizations, such as laws governing
tax-exempt status, charitable trusts, char-
itable solicitation, and fraud. See section
6104(c)(2)(C). Prior law provided for au-
tomatic disclosure (without a request), but
only of final determinations and their re-
lated returns and return information.
(5) The IRS may disclose to an ASO
on its own initiative (without a written
request) returns and return information
with respect to charitable organizations
and applicants if the IRS determines that
this information might constitute evidence
of noncompliance with the laws under
the jurisdiction of the ASO. See section
6104(c)(2)(D). There was no such provi-
sion under section 6104(c) previously.
(6) The IRS may disclose returns and
return information of section 501(c) or-
ganizations other than those described
in section 501(c)(1) or (c)(3) to an ASO
upon the ASO’s written request, but only
to the extent necessary in administering
state laws relating to the solicitation or
administration of charitable funds or char-
itable assets of such organizations. See
section 6104(c)(3). Previously, only infor-
mation relating to charitable organizations
or applicants was disclosed under section
6104(c).
(7) Returns and return information of
organizations and taxable persons dis-
closed under section 6104(c) may be
disclosed in civil administrative and civil
judicial proceedings pertaining to the en-
forcement of state laws regulating such or-
ganizations, under procedures prescribed
by the IRS similar to those under sec-
tion 6103(h)(4). See section 6104(c)(4).
There was no such provision under section
6104(c) previously.
(8) No return or return information
may be disclosed under section 6104(c)
to the extent the IRS determines that
such disclosure would seriously impair
federal tax administration. See section
6104(c)(5). This disclosure prohibition,
though new in the PPA, was provided
previously by regulation. See current
§301.6104(c)–1(b)(3)(ii).
(9) The IRS may disclose returns and
return information under section 6104(c)
to a state officer or employee designated by
the ASO to receive such information on the
ASO’s behalf. See section 6104(c)(2)(C)
(flush language) and (c)(3). Prior law did
not provide for IRS disclosures to persons
other than ASOs.
(10) An ASO is defined as the state
attorney general, state tax officer, any state
official charged with overseeing charita-
ble organizations (in the case of charitable
organizations and applicants), and the
head of the state agency charged with
the primary responsibility for overseeing
the solicitation of funds for charitable
purposes (in the case of section 501(c)
organizations other than those described
in section 501(c)(1) or (c)(3)). See sec-
tion 6104(c)(6)(B). Before its amendment
by the PPA, section 6104(c)(2) defined
ASO as the state attorney general, state
tax officer, or any state official charged
with overseeing organizations of the type
described in section 501(c)(3).
III. Related PPA provisions
The PPA amended section 6103(p) to
make the disclosure of returns and return
information under section 6104(c) subject
to the disclosure, recordkeeping, and safe-
guard provisions of section 6103. These
provisions include—
(1) section 6103(a), which is the general
prohibition on the disclosure of returns and
return information,except as authorized by
Title 26 of the United States Code;
(2) section 6103(p)(3), which requires
the IRS to maintain permanent standard-
ized records of all requests for inspection
or disclosure of returns or return infor-
mation under section 6104(c) and of all
such information inspected or disclosed
pursuant to those requests; and
(3) section 6103(p)(4), which requires
an ASO, as a condition for receiving re-
turns or return information under section
6104(c), to establish and maintain certain
safeguards, such as keeping permanent
standardized records of all requests and
disclosures, maintaining a secure infor-
mation storage area, restricting access to
the information, and providing whatever
other safeguards the IRS deems neces-
sary to protect the confidentiality of the
information. See §301.6103(p)(4)–1 and
IRS Publication 1075,Tax Information
Security Guidelines for Federal, State and
Local Agencies. Publication 1075 can be
found atwww.irs.gov/formspubs.
The PPA also included amendments to
sections 7213, 7213A, and 7431 to impose
civil and criminal penalties for the unau-
thorized disclosure or inspection of section
6104(c) information.
March 28, 20115922011–13 I.R.B.

IV. IRS disclosure procedures
In general, before any federal or state
agency may receive returns and return in-
formation from the IRS under a particu-
lar Code provision, it must file with the
IRS a report detailing the physical, admin-
istrative, and technical safeguards imple-
mented by the agency to protect this in-
formation from unauthorized inspection or
disclosure. Only upon approval of these
safeguards by the IRS, as well as satis-
faction of any other statutory requirements
(such as submission of a written request),
may an agency receive the information to
which it is entitled under the Code, and
then only for the use specified by the rele-
vant statute. See section 6103(p)(4).
Under various disclosure programs,
the IRS and other federal and state agen-
cies often execute agreements detailing
the responsibilities of the parties and the
terms and parameters of the disclosure
arrangement. For example, under section
6103(d), the IRS executes a disclosure
agreement (the “Basic Agreement”) with
each state tax agency to which it discloses
information. The Basic Agreement, which
serves as the written request required by
section 6103(d), has been the foundation
of the state tax disclosure program un-
der this provision of the Code for over
30 years. See Internal Revenue Manual
Exhibit 11.3.32–1 (sample Basic Agree-
ment).
After the PPA, the IRS revised its dis-
closure procedures under section 6104(c)
to model them after the highly success-
ful section 6103(d) program. The section
6104(c) program uses a disclosure agree-
ment patterned after the Basic Agreement
but tailored to the specific requirements
and restrictions of section 6104(c).
Explanation of Provisions
These proposed regulations provide
guidance regarding disclosures under sec-
tion 6104(c), as amended by the PPA.
The PPA amendmentsto sections 6104(c)
and 6103 expand the scope of informa-
tion the IRS may disclose to an ASO, but
make such disclosures contingent on the
ASO adopting the safeguard standards
and procedures of section 6103 that apply
to federal and state agencies that receive
returns and return information under other
provisions of the Code. Accordingly,
these proposed regulations provide that,
without prior safeguard approval, the IRS
will not give automatic notification of any
determinations or other information that
may be disclosed under section 6104(c).
Under these proposed regulations, the
IRS may (and currently does) require an
ASO to enter into a disclosure agreement
with the IRS, which will stipulate the
procedures for disclosure under section
6104(c), as well as the restrictions on use
and redisclosure. These proposed regula-
tions provide that this agreement, or any
similar document, satisfies the require-
ment under section 6104(c) for a written
request for disclosure.
An ASO who meets the safeguard and
other procedural requirements of section
6103(p)(4) may receive information from
the IRS to be used in the administration
of state laws governing charitable orga-
nizations, as well as laws governing the
solicitation or administration of charitable
funds or charitable assets of certain non-
charitable exempt organizations. The in-
formation available to ASOs under these
proposed regulations not only is greater in
scope than what was available under sec-
tion 6104(c) before its amendment by the
PPA, but comes at an earlier stage in the
IRS administrative and enforcement pro-
cesses. Thus, the IRS may disclose such
information as whether an organization has
applied for recognition as a charitable or-
ganization and, if so, whether the IRS pro-
poses to deny such recognition, or the or-
ganization has withdrawn its application;
whether an organization’s charitable status
has terminated; whether the IRS proposes
to assess any chapter 42 excise taxes (for
example, the tax on excess benefit transac-
tions under section 4958); and whether the
IRS has revoked an organization’s exemp-
tion, or proposes to revoke the recognition
of its exemption.
Without a written request, but still
subject to the safeguard requirements of
section 6103(p)(4), the IRS has the au-
thority under section 6104(c)(2)(D) to
disclose returns and return information of
charitable organizations and applicants if
it determines that such information may
constitute evidence of noncompliance with
the laws under the ASO’s jurisdiction.
The IRS may make these disclosures on
its own initiative. These proposed regula-
tions clarify that the IRS’ authority under
section6104(c)(2)(D)isinadditiontoits
disclosure authority under other provisions
of section 6104(c)(1) and (c)(2), to the
effect that discretionary disclosures may
be made before the IRS issues a proposed
determination or takes other action. The
proposed regulations also make clear that
the determination required by the statute
concerns possible noncompliance with
state laws regulating charitable organiza-
tions and not just any state law violation.
The disclosure provisions of section
6104(c), as amended by the PPA, offer
significant advantages to states in their
enforcement efforts. The ability of the
IRS to disclose returns and return infor-
mation early in its own administrative and
enforcement processes, as well as the IRS’
authority under section 6104(c)(2)(D) to
disclose information on its own initiative,
greatly enhance the administration and
enforcement of state laws, both tax and
nontax, governing charitable activities,
funds, and assets.
These proposed regulations define cer-
tain key terms for purposes of section
6104(c), including “appropriate state offi-
cer”, “return”, “return information”, and
“taxable person.”
Special Analyses
It has been determined that this notice
of proposed rulemaking is not a signifi-
cant regulatory action as defined in Ex-
ecutive Order 12866; therefore, a regula-
tory assessment is not required. It also has
been determined that section 553(b) of the
Administrative Procedure Act (5 U.S.C.
chapter 5) and the Regulatory Flexibility
Act (5 U.S.C. chapter 6) do not apply to
the proposed regulations; therefore, a reg-
ulatory flexibility analysis is not required.
Pursuant to section 7805(f) of the Internal
Revenue Code, the proposed regulations
have been submitted to the Chief Counsel
for Advocacy of the Small Business Ad-
ministration for comments regarding their
impact on small businesses.
Comments and Requests for a Public
Hearing
Before these proposed regulations are
adopted as final, any written (signed orig-
inal and 8 copies) or electronic comments
timely submitted to the IRS will be consid-
ered. The IRS and Treasury Department
request comments on the clarity of these
proposed regulations and how they might
2011–13 I.R.B.593March 28, 2011

be made easier to understand. Of particu-
lar interest are comments on whether para-
graph (e) of these proposed regulations,
describing the organizations to which dis-
closure applies, lists all the organizations
with respect to which ASOs might legit-
imately need information. All comments
will be available for public inspection and
copying. A public hearing will be sched-
uled if requested in writing by any person
who timely submits written comments. If
a public hearing is scheduled, notice of the
date, time, and place for the public hearing
will be published in theFederal Register.
Drafting Information
The principal author of these regula-
tions is Casey Lothamer of the Office of
Division Counsel/Associate Chief Coun-
sel (Tax Exempt and Government Enti-
ties), though other persons in the IRS and
Treasury Department participated in their
development.
*****
Proposed Amendments to the
Regulations
Accordingly, 26 CFR part 301 is pro-
posedtobeamendedasfollows:
PART 301—PROCEDURE AND
ADMINISTRATION
Paragraph 1. The authority citation for
part 301 is amended by adding an entry in
numerical order to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Section 301.6104(c)–1 also issued un-
der 26 U.S.C. 6104(c). * * *
Par. 2. Section 301.6104(c)–1 is re-
vised to read as follows:
§301.6104(c)–1 Disclosure of certain
information to state officials.
(a)In general.—(1) Subject to the dis-
closure, recordkeeping, and safeguard pro-
visions of section 6103, and upon writ-
ten request by an appropriate state offi-
cer (ASO, as defined in paragraph (i)(1) of
this section), the IRS may disclose or make
available to the ASO the returns and return
information described in paragraph (c) of
this section with respect to—
(i) any organization described or for-
merly described in section 501(c)(3) and
exempt or formerly exempt from taxation
under section 501(a) (a charitable organi-
zation); or
(ii) any organization that has applied for
recognition as an organization described in
section 501(c)(3) (an applicant).
Such information shall be disclosed or
made available only as necessary to ad-
minister state laws regulating charitable
organizations.
(2) Subject to the disclosure, record-
keeping, and safeguard provisions of
section 6103, and upon written request by
an ASO, the IRS may disclose or make
available to the ASO returns and return
information regarding any organization
described or formerly described in sec-
tion 501(c) other than section 501(c)(1) or
(c)(3). Such information shall be disclosed
or made available only as necessary to
administer state laws regulating the solic-
itation or administration of the charitable
funds or charitable assets of these organi-
zations.
(b)Disclosure agreement.TheIRS
may require an ASO to execute a dis-
closure agreement or similar document
specifying the procedures, terms, and con-
ditions for the disclosure or inspection of
information under section 6104(c), includ-
ing compliance with the safeguards pre-
scribed by section 6103(p)(4), as well as
specifying the informationtobedisclosed.
Such an agreement or similar document
shall constitute the request for disclosure
required by section 6104(c)(1)(C), as well
as the written request required by section
6104(c)(2)(C)(i) and (c)(3). For security
guidelines and othersafeguards for pro-
tecting returns and return information, see
guidance published by the IRS. See, for
example, IRS Publication 1075, “Tax In-
formation Security Guidelines for Federal,
State and Local Agencies.”
(c)Disclosures regarding charitable
organizations and applicants.—(1) With
respect to any organization described in
paragraph (d) of this section, the IRS may
disclose or make available for inspection
under section 6104(c)(1) and (c)(2) to
an ASO the following returns and return
information with respect to a charitable
organization or applicant:
(i) A refusal or proposed refusal to rec-
ognize an organization’s exemption as a
charitable organization (a final or proposed
denial letter).
(ii) Information regarding a grant of ex-
emption following a proposed denial.
(iii) A revocation of exemption as a
charitable organization (a final revocation
letter), including a notice of termination or
dissolution.
(iv) A proposed revocation of recogni-
tion of exemption as acharitable organiza-
tion (a proposed revocation letter).
(v) Information regarding the final dis-
position of a proposed revocation of recog-
nition other than by final revocation.
(vi) A notice of deficiency or proposed
notice of deficiency of tax imposed un-
der section 507 or chapter 41 or 42 on the
organization or a taxable person (as de-
scribed in paragraph (i)(4) of this section).
(vii) Information regarding the final
disposition of a proposed notice of defi-
ciency of tax imposed under section 507
or chapter 41 or 42 on the organization
other than by issuance of a final notice of
deficiency.
(viii) The names, addresses, and tax-
payer identification numbers of applicants
for charitable status, provided on an ap-
plicant-by-applicant basis or by periodic
lists of applicants. Under this provision the
IRS may respond to inquiries from an ASO
as to whether a particular organization has
applied for recognition of exemption as a
charitable organization.
(ix) Information regarding the final dis-
position of an application for recognition
of exemption where no proposed denial
letter is issued, including whether the ap-
plication was withdrawn or whether the
applicant failed to establish its exemption.
(x) Returns and other return informa-
tion relating to the return information de-
scribed in this paragraph (c)(1), except for
returns and return information relating to
proposed notices of deficiency described
in paragraph (c)(1)(vi) of this section with
respect to taxable persons.
(2) The IRS may disclose or make avail-
able for inspection returns and return in-
formation of a charitable organization or
applicant, if the IRSdetermines that such
information might constitute evidence of
noncompliance with the laws under the ju-
risdiction of the ASO regulating charitable
organizations and applicants. Such infor-
mation may be disclosed on the IRS’ own
initiative. Disclosures under this para-
graph (c)(2) may be made before the IRS
issues a proposed determination (denial of
recognition, revocation, or notice of defi-
ciency) or any other action by the IRS de-
scribedinthissection.
March 28, 20115942011–13 I.R.B.

(d)Organizations to which disclosure
applies. Regarding the information de-
scribed in paragraphs (a)(2) and (c) of
this section, the IRS will disclose or make
available for inspection to an ASO such
information only with respect to—
(1) an organization formed under the
laws of the ASO’s state;
(2) an organization, the principal office
of which is located in the ASO’s state;
(3) an organization that, as determined
by the IRS, is or might be subject to the
laws of the ASO’s state regulating charita-
ble organizations or the solicitation or ad-
ministration of charitable funds or charita-
ble assets; or
(4) a private foundation required by
§1.6033–2(a)(iv) to list the ASO’s state on
any of the foundation’s returns filed for its
last five years.
(e)Disclosurelimita-
tions.—Notwithstanding any other
provision of this section, the IRS will not
disclose or make available for inspection
under section 6104(c) any information,
the disclosure of which it determines
would seriously impair federal tax admin-
istration, including, but not limited to—
(1) identification of a confidential infor-
mant or interference with a civil or crimi-
nal tax investigation; and
(2) information obtained pursuant to a
tax convention between the United States
and a foreign government (see section
6105(c)(2) for the definition oftax con-
vention).
(f)Disclosure recipients.—(1)In gen-
eral. The IRS may disclose returns and re-
turn information under section 6104(c) to,
or make it available for inspection by—
(i) an ASO, as defined in paragraph
(i)(1) of this section, or
(ii) a person other than an ASO, but
only if that person is a state officer or em-
ployee designated by the ASO to receive
information under section 6104(c) on be-
half of the ASO, as specified in paragraph
(f)(2) of this section.
(2)Designation by ASO.AnASOmay
designate state officers or employees to re-
ceive information under section 6104(c)
on the ASO’s behalf by specifying in writ-
ing each person’s name and job title, and
the name and address of the person’s of-
fice. The ASO must promptly notify the
IRS in writing of any additions, deletions,
or other changes to the list of designated
persons.
(g)Redisclosure. An ASO to whom a
return or return information has been dis-
closed may thereafter disclose such infor-
mation—
(1) to another state officer or employee
only as necessary to administer state laws
governing charitable organizations or state
laws regulating the solicitation or admin-
istration of charitable funds or charitable
assets of noncharitable exempt organiza-
tions; or
(2) except as provided in paragraph
(h)(1) of this section, to another state of-
ficer or employee who is personally and
directly preparing for a civil proceeding
before a state administrative body or court
in a matter involving the enforcement of
state laws regulating organizations with
respect to which information can be dis-
closed under this section, solely for use in
such a proceeding, but only if—
(i) the organization or a taxable person
is a party to the proceeding, or the proceed-
ing arose out of, or in connection with, de-
termining the civil liability of the organiza-
tion or a taxable person, or collecting such
civil liability, under state laws governing
organizations with respect to which infor-
mation can be disclosed under this section;
(ii) the treatment of an item reflected
on such a return is directly related to the
resolution of an issue in the proceeding; or
(iii) the return or return information di-
rectly relates to a transactional relationship
between the organization or a taxable per-
son and a person who is a party to the pro-
ceeding that directly affects the resolution
of an issue in the proceeding.
(h)Redisclosure limitations.—(1) Be-
fore disclosing in a state administrative
or judicial proceeding, or to any party as
provided by paragraph (g)(2) of this sec-
tion, any return or return information re-
ceived under section 6104(c), the ASO
shall notify the IRS of the intention to
make such a disclosure. No state officer
or employee shall make such a disclosure
except in accordance with any conditions
the IRS might impose in response to the
ASO’s notice of intent. No such disclo-
sure shall be made if the IRS determines
that the disclosure would seriously impair
federal tax administration.
(2) An ASO to whom a return or return
information has been disclosed shall not
disclose that information to an agent or
contractor.
(i)Definitions.—(1)Appropriate state
officermeans—
(i) the state attorney general;
(ii) the state tax officer;
(iii) with respect to a charitable organi-
zation or applicant, any state officer other
than the attorney general or tax officer
charged with overseeing charitable organi-
zations; and
(iv) with respect to a section 501(c) or-
ganization that is not described in section
501(c)(1) or (c)(3), the head of the agency
designated by the state attorney general as
having primary responsibility for oversee-
ing the solicitation of funds for charitable
purposes.
A state officer described in paragraph
(i)(1)(iii) or (i)(1)(iv) of this section must
show that the officer is an ASO by present-
ing a letter from the state attorney general
describing the functions and authority of
the officer under state law, with sufficient
facts for the IRS to determine that the offi-
cer is an ASO.
(2)Returnhas the same meaning as in
section 6103(b)(1).
(3)Return informationhas the same
meaning as in section 6103(b)(2).
(4)Taxable personmeans any person
who is liable or potentially liable for ex-
cise taxes under chapter 41 or 42. Such a
person includes—
(i) a disqualified person described in
section 4946(a)(1), 4951(e)(4), or 4958(f);
(ii) a foundation manager described in
section 4946(b);
(iii) an organization manager described
in section 4955(f)(2) or 4958(f)(2);
(iv) a person described in section
4958(c)(3)(B);
(v) an entity manager described in sec-
tion 4965(d); and
(vi) a fund manager described in section
4966(d)(3).
(j)Failure to comply. Upon a de-
termination that an ASO has failed to
comply with the requirements of section
6103(p)(4), the IRS may take the actions it
deems necessary to ensure compliance, in-
cluding the refusal to disclose any further
returns or return information to the ASO
until the IRS determines that the require-
ments have been met. For procedures for
the administrative review of a determina-
tion that an authorized recipient has failed
to safeguard returns or return information,
see §301.6103(p)(7)–1.
2011–13 I.R.B.595March 28, 2011

(k)Effective/applicability date.The
rules of this section apply to taxable years
beginning on or after the date of pub-
lication in theFederal Registerof the
Treasury decision adopting these rules as
final regulations.
Steven T. Miller,
Deputy Commissioner for
Services and Enforcement.
(Filed by the Office of the Federal Register on March 14,
2011, 8:45 a.m., and published in the issue of the Federal
Register for March 15, 2011, 76 F.R. 13932)
March 28, 20115962011–13 I.R.B.

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.
2011–13 I.R.B.iMarch 28, 2011

Numerical Finding List
1
Bulletin 2011–1 through 2011–13
Announcements:
2011-1, 2011-2 I.R.B.304
2011-2, 2011-3 I.R.B.324
2011-3, 2011-3 I.R.B.324
2011-4, 2011-4 I.R.B.424
2011-5, 2011-4 I.R.B.430
2011-6, 2011-4 I.R.B.433
2011-7, 2011-5 I.R.B.446
2011-8, 2011-5 I.R.B.446
2011-9, 2011-7 I.R.B.499
2011-10, 2011-7 I.R.B.499
2011-11, 2011-7 I.R.B.500
2011-12, 2011-9 I.R.B.532
2011-13, 2011-8 I.R.B.525
2011-14, 2011-9 I.R.B.532
2011-15, 2011-8 I.R.B.526
2011-16, 2011-7 I.R.B.500
2011-17, 2011-9 I.R.B.532
2011-18, 2011-12 I.R.B.567
2011-19, 2011-11 I.R.B.553
2011-20, 2011-10 I.R.B.542
2011-21, 2011-12 I.R.B.567
2011-23, 2011-12 I.R.B.568
2011-24, 2011-12 I.R.B.569
Notices:
2011-1, 2011-2 I.R.B.259
2011-2, 2011-2 I.R.B.260
2011-3, 2011-2 I.R.B.263
2011-4, 2011-2 I.R.B.282
2011-5, 2011-3 I.R.B.314
2011-6, 2011-3 I.R.B.315
2011-7, 2011-5 I.R.B.437
2011-8, 2011-8 I.R.B.503
2011-9, 2011-6 I.R.B.459
2011-10, 2011-6 I.R.B.463
2011-11, 2011-7 I.R.B.497
2011-12, 2011-8 I.R.B.514
2011-13, 2011-9 I.R.B.529
2011-14, 2011-11 I.R.B.544
2011-15, 2011-10 I.R.B.539
2011-17, 2011-10 I.R.B.540
2011-18, 2011-11 I.R.B.549
2011-19, 2011-11 I.R.B.550
2011-22, 2011-12 I.R.B.557
2011-23, 2011-13 I.R.B.588
Proposed Regulations:
REG-140108-08, 2011-13 I.R.B.591
REG-149335-08, 2011-6 I.R.B.468
REG-146097-09, 2011-8 I.R.B.516
REG-124018-10, 2011-2 I.R.B.301
Proposed Regulations— Continued:
REG-131151-10, 2011-8 I.R.B.519
REG-131947-10, 2011-8 I.R.B.521
REG-132724-10, 2011-7 I.R.B.498
Revenue Procedures:
2011-1, 2011-1 I.R.B.1
2011-2, 2011-1 I.R.B.90
2011-3, 2011-1 I.R.B.111
2011-4, 2011-1 I.R.B.123
2011-5, 2011-1 I.R.B.167
2011-6, 2011-1 I.R.B.195
2011-7, 2011-1 I.R.B.233
2011-8, 2011-1 I.R.B.237
2011-9, 2011-2 I.R.B.283
2011-10, 2011-2 I.R.B.294
2011-11, 2011-4 I.R.B.329
2011-12, 2011-2 I.R.B.297
2011-13, 2011-3 I.R.B.318
2011-14, 2011-4 I.R.B.330
2011-15, 2011-3 I.R.B.322
2011-16, 2011-5 I.R.B.440
2011-17, 2011-5 I.R.B.441
2011-18, 2011-5 I.R.B.443
2011-19, 2011-6 I.R.B.465
2011-20, 2011-11 I.R.B.551
2011-21, 2011-12 I.R.B.560
Revenue Rulings:
2011-1, 2011-2 I.R.B.251
2011-2, 2011-2 I.R.B.256
2011-3, 2011-4 I.R.B.326
2011-4, 2011-6 I.R.B.448
2011-5, 2011-13 I.R.B.577
2011-6, 2011-10 I.R.B.537
2011-7, 2011-10 I.R.B.534
2011-8, 2011-12 I.R.B.554
2011-9, 2011-12 I.R.B.554
Treasury Decisions:
9507, 2011-3 I.R.B.305
9508, 2011-7 I.R.B.495
9509, 2011-6 I.R.B.450
9510, 2011-6 I.R.B.453
9511, 2011-6 I.R.B.455
9512, 2011-7 I.R.B.473
9513, 2011-8 I.R.B.501
9514, 2011-9 I.R.B.527
9516, 2011-13 I.R.B.575
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2010–27 through 2010–52 is in Internal Revenue Bulletin
2010–52, dated December 27, 2010.
March 28, 2011ii2011–13 I.R.B.

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2011–1 through 2011–13
Announcements:
85-88
Obsoleted by
Rev. Proc. 2011-10, 2011-2 I.R.B.294
2008-11
Modified by
Ann. 2011-6, 2011-4 I.R.B.433
2009-62
Obsoleted by
Rev. Proc. 2011-10, 2011-2 I.R.B.294
Notices:
2006-87
Superseded by
Notice 2011-8, 2011-8 I.R.B.503
2007-25
Superseded by
Notice 2011-8, 2011-8 I.R.B.503
2007-77
Superseded by
Notice 2011-8, 2011-8 I.R.B.503
2008-107
Superseded by
Notice 2011-8, 2011-8 I.R.B.503
2010-27
Superseded by
Notice 2011-8, 2011-8 I.R.B.503
2010-59
Modified by
Notice 2011-5, 2011-3 I.R.B.314
2010-71
Modified and superseded by
Notice 2011-9, 2011-6 I.R.B.459
2010-79
Clarified and modified by
Notice 2011-4, 2011-2 I.R.B.282
Proposed Regulations:
REG-132554-08
Corrected by
Ann. 2011-11, 2011-7 I.R.B.500
Revenue Procedures:
72-50
Modified and superseded by
Rev. Proc. 2011-10, 2011-2 I.R.B.294
Revenue Procedures— Continued:
76-34
Modified and supersed by
Rev. Proc. 2011-10, 2011-2 I.R.B.294
83-23
Modified and superseded by
Rev. Proc. 2011-15, 2011-3 I.R.B.322
94-17
Modified and superseded by
Rev. Proc. 2011-15, 2011-3 I.R.B.322
97-27
Clarified and modified by
Rev. Proc. 2011-4, 2011-1 I.R.B.330
2001-10
Modified by
Rev. Proc. 2011-4, 2011-4 I.R.B.330
2002-28
Modified by
Rev. Proc. 2011-4, 2011-4 I.R.B.330
2003-21
Modified and superseded by
Rev. Proc. 2011-15, 2011-3 I.R.B.322
2004-34
Modified by
Rev. Proc. 2011-14, 2011-4 I.R.B.330
Modified and clarified by
Rev. Proc. 2011-18, 2011-5 I.R.B.443
2006-44
Modified by
Ann. 2011-6, 2011-4 I.R.B.433
2006-56
Modified by
Rev. Proc. 2011-14, 2011-4 I.R.B.330
2008-52
Modified by
Notice 2011-4, 2011-2 I.R.B.282
Rev. Proc. 2011-17, 2011-5 I.R.B.441
Superseded in part by
Rev. Proc. 2011-14, 2011-4 I.R.B.330
2009-39
Superseded in part by
Rev. Proc. 2011-14, 2011-4 I.R.B.330
2009-44
Modified by
Ann. 2011-6, 2011-4 I.R.B.433
2010-1
Superseded by
Rev. Proc. 2011-1, 2011-1 I.R.B.1
2010-2
Superseded by
Rev. Proc. 2011-2, 2011-1 I.R.B.283
Revenue Procedures— Continued:
2010-3
Superseded by
Rev. Proc. 2011-3, 2011-1 I.R.B.111
2010-4
Superseded by
Rev. Proc. 2011-4, 2011-1 I.R.B.123
2010-5
Superseded by
Rev. Proc. 2011-5, 2011-1 I.R.B.167
2010-6
Superseded by
Rev. Proc. 2011-6, 2011-1 I.R.B.195
2010-7
Superseded by
Rev. Proc. 2011-7, 2011-1 I.R.B.233
2010-8
Superseded by
Rev. Proc. 2011-8, 2011-1 I.R.B.237
2010-9
Superseded by
Rev. Proc. 2011-9, 2011-2 I.R.B.283
2010-15
Updated by
Rev. Proc. 2011-13, 2011-3 I.R.B.318
2010-18
Amplified and modified by
Rev. Proc. 2011-21, 2011-12 I.R.B.560
2011-1
Corrected by
Ann. 2011-7, 2011-5 I.R.B.446
2011-8
Corrected by
Ann. 2011-8, 2011-5 I.R.B.446
2011-11
Corrected by
Ann. 2011-9, 2011-7 I.R.B.499
Revenue Rulings:
81-100
Modified by
Rev. Rul. 2011-1, 2011-2 I.R.B.251
2004-67
Modified by
Rev. Rul. 2011-1, 2011-2 I.R.B.251
2008-40
Modified by
Rev. Rul. 2011-1, 2011-2 I.R.B.251
2011-3
Corrected by
Ann. 2011-16, 2011-7 I.R.B.500
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2010–27 through 2010–52 is in Internal Revenue Bulletin 2010–52, dated December 27,
2010.
2011–13 I.R.B.iiiMarch 28, 2011

Treasury Decisions:
9391
Corrected by
Ann. 2011-12, 2011-9 I.R.B.532
9505
Corrected by
Ann. 2011-10, 2011-7 I.R.B.499
March 28, 2011iv2011–13 I.R.B.

INDEX
Internal Revenue Bulletin 2011–1 through
2011–13
The abbreviation and number in parenthesis following the index entry
refer to the specific item; numbers in roman and italic type following
the parenthesis refers to the Internal Revenue Bulletin in which the item
may be found and the page number on which it appears.
Key to Abbreviations:
AnnAnnouncement
CDCourt Decision
DODelegation Order
EOExecutive Order
PLPublic Law
PTEProhibited Transaction Exemption
RPRevenue Procedure
RRRevenue Ruling
SPRStatement of Procedural Rules
TCTax Convention
TDTreasury Decision
TDOTreasury Department Order
EMPLOYEE PLANS
Affordable Care Act, nondiscrimination provisions applicable to
insured group health plans (Notice 1) 2,259
Cash balance plans and other hybrid defined benefit pension
plans, correction to TD 9505 (Ann 10) 7,499; correction to
REG–132554–08 (Ann 11) 7,500
Determination letters, issuing procedures (RP 6) 1,195
Full funding limitations, weighted average interest rates, seg-
ment rates for:
January 2011 (Notice 7) 5,437
February 2011 (Notice 13) 9,529
March 2011 (Notice 22) 12,557
Guidance under section 162(m)(6) (Notice 2) 2,260
Letter rulings:
403(b) plans, plan termination (RR 7) 10,534
And determination letters, areas which will not be issued
from:
Associates Chief Counsel and Division Counsel (TE/GE)
(RP 3) 1,111
Associate Chief Counsel (International) (RP 7) 1,233
And general information letters, procedures (RP 4) 1,123
User fees, request for letter rulings (RP 8) 1,237; correction
(Ann 8) 5,446
Proposed Regulations:
26 CFR 1.411(b)(5)–1, revised;hybrid retirement plans; cor-
rection to REG–132554–08 (Ann 11) 7,500
Qualified plans:
Covered compensation tables, permitted disparity (RR 3) 4,
326; correction (Ann 16) 7,500
Group trusts (RR 1) 2,251
Minimum funding requirements relief (Notice 3) 2,263
Readily tradable securities (Notice 19) 11,550
Reporting requirements, Form 8955-SSA (Ann 21) 12,567
EMPLOYEE PLANS—Cont.
Regulations:
26 CFR 1.411(b)(5)–1, revised; hybrid retirement plans; cor-
rection to TD 9505 (Ann 10) 7,499
Technical advice to IRS employees (RP 5) 1,167
EMPLOYMENT TAX
Electronic Funds Transfer (ETF) of depository taxes (TD 9507)
3,305
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions (RP
1) 1,1;correction(Ann7)5,446
Proposed Regulations:
26 CFR 301.7623–1, amended; rewards and awards for in-
formation relating to violations of internal revenue laws
(REG–131151–10) 8,519
Regulations:
26 CFR 1.1462–1, amended; 1.6302–1 thru –4, amended;
31.6071, amended; 31.6302–0 thru –2, –4, amended;
31.6302(c)–2A, removed; 31.6302(c)–3, amended;
40.6302(c)–1 thru –3, amended; 301.6302–1, amended;
301.6656–1, amended; 301.7502–2, removed; Electronic
Funds Transfer (ETF) of depository taxes (TD 9507) 3,305
Rewards and awards for information relating to violations of in-
ternal revenue laws (REG–131151–10) 8,519
Technical Advice Memoranda (TAMs) (RP 2) 1,90
Withholding on wages of nonresident alien employees perform-
ing services within the United States (Notice 12) 8,514
ESTATE TAX
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions (RP
1) 1,1;correction(Ann7)5,446
Proposed Regulations:
26 CFR 301.7623–1, amended; rewards and awards for in-
formation relating to violations of internal revenue laws
(REG–131151–10) 8,519
Rewards and awards for information relating to violations of in-
ternal revenue laws (REG–131151–10) 8,519
Technical Advice Memoranda (TAMs) (RP 2) 1,90
EXCISE TAX
Biodiesel and alternative fuels, claims for 2010 (Notice 10) 6,
463
Branded prescription drug sales (Notice 9) 6,459
Electronic Funds Transfer (ETF) of depository taxes (TD 9507)
3,305
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions (RP
1) 1,1;correction(Ann7)5,446
2011–13 I.R.B.vMarch 28, 2011

EXCISE TAX—Cont.
Proposed Regulations:
26 CFR 301.7623–1, amended; rewards and awards for in-
formation relating to violations of internal revenue laws
(REG–131151–10) 8,519
Regulations:
26 CFR 1.1462–1, amended; 1.6302–1 thru –4, amended;
31.6302–0 thru –2, –4, amended; 31.6071, amended;
31.6302(c)–2A, removed; 31.6302(c)–3, amended;
40.6302(c)–1 thru –3, amended; 301.6302–1, amended;
301.6656–1, amended; 301.7502–2, removed; Electronic
Funds Transfer (EFT) of depository taxes (TD 9507) 3,305
Rewards and awards for information relating to violations of in-
ternal revenue laws (REG–131151–10) 8,519
Technical Advice Memoranda (TAMs) (RP 2) 1,90
EXEMPT ORGANIZATIONS
Delayed filing season for certain tax-exempt hospitals (Ann 20)
10,542
Disclosure of information to stateofficials regarding tax-exempt
organizations (REG–140108–08) 13,591
Electronic Funds Transfer (EFT) of depository taxes (TD 9507)
3,305
Filing thresholds for Form 990 (RP 15) 3,322
Letter rulings:
And determination letters:
Areas which will not be issued from Associates Chief
Counsel and Division Counsel (TE/GE) (RP 3) 1,111
Exemption application determination letter rulings under
sections 501, 509, 4940, and 4942 (RP 10) 2,294
Exemption application determination letter rulings under
sections 501 and 521 (RP 9) 2,283
And general information letters, procedures (RP 4) 1,123
User fees, request for letter rulings (RP 8) 1,237; correction
(Ann 8) 5,446
List of organizations classified as private foundations (Ann 3) 3,
324; (Ann 13) 8,525
Notice requesting comments onsection 501(c)(29) (Notice 23)
13,588
Proposed regulations:
26 CFR 301.6104(c)–1, revised; disclosure of informa-
tion to state officials regarding tax-exempt organizations
(REG–140108–08) 13,591
Regulations:
26 CFR 1.1462–1, amended; 1.6302–1 thru –4, amended;
31.6071, amended; 31.6302–0 thru –2, –4, amended;
31.6302(c)–2A, removed; 31.6302(c)–3, amended;
40.6302(c)–1 thru –3, amended; 301.6302–1, amended;
301.6656–1, amended; 301.7502–2, removed; Electronic
Funds Transfer (EFT) of depository taxes (TD 9507) 3,305
Revocations (Ann 2) 3,324;(Ann15)8,526;(Ann17)9,532;
(Ann 23) 12,568
Technical advice to IRS employees (RP 5) 1,167
GIFT TAX
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions (RP
1) 1,1;correction(Ann7)5,446
Proposed Regulations:
26 CFR 301.7623–1, amended; rewards and awards for in-
formation relating to violations of internal revenue laws
(REG–131151–10) 8,519
Rewards and awards for information relating to violations of in-
ternal revenue laws (REG–131151–10) 8,519
Technical Advice Memoranda (TAMs) (RP 2) 1,90
INCOME TAX
Accounting methods, automatic consent for Blue Cross/Blue
Shield and certain other health organizations to change method
of accounting for unearned premiums (Notice 4) 2,282
Accrual of liabilities (RP 17) 5,441
Bonds:
Qualified Zone Academy Bond limitation for 2011 (RP 19) 6,
465
Capital assets, election for certain musical works (TD 9415) 9,
527
Cost-of-living adjustments for inflation for 2011 (RP 12) 2,297
Credits:
Low-income housing tax credit, 2011 population figures used
for calculation (Notice 15) 10,539
Debt instruments:
Deterioration in financial condition of issuer (TD 9513) 8,501
For publicly traded property, issue price (REG–131947–10)
8,521
Deductions for contributions toqualified nuclear decommission-
ing trusts (TD 9512) 7,473
Deductions for medical expenses (Ann 14) 9,532
Definition of omission from gross income (TD 9511) 6,455
Depreciation, 2011 limitationson depreciation deductions for
passenger automobiles (RP 21) 12,560
Disciplinary actionsinvolving attorneys,certified public accoun-
tants, enrolled agents, and enrolled actuaries (Ann 4) 4,424;
(Ann 24) 12,569
Disclosure of return information in connection with written con-
tracts among the IRS, whistleblowers, and legal representa-
tives of whistleblowers (TD 9516) 13,575
Electronic Funds Transfer (EFT) of depository taxes (TD 9507)
3,305
Emancipation day and tax filingand payment deadlines (Notice
17) 10,540
Employer-provided vehicles, cents-per-mile rule, maximum ve-
hicle values for 2011 (RP 11) 4,329;correction(Ann9)7,499
Extension of Fast Track Settlement (FTS) for SB/SE taxpayer
pilot program (Ann 5) 4,430
Farmer and fisherman income averaging (TD 9509) 6,450
Foreign earned income exclusion (RP 20) 11,551
Guidance under section 162(m)(6) (Notice 2) 2,260
Health FSA/HRA debit cards, purchase over-the-counter drug
purchases (Notice 5) 3,314
March 28, 2011vi2011–13 I.R.B.

INCOME TAX—Cont.
Housing cost amounts eligible for exclusion or deduction, 2011
(Notice 8) 8,503
Implementation of rules governing tax return preparers (Notice
6) 3,315
Income recognition for advance payments received from the sale
of gift cards (RP 18) 5,443
Information reporting:
Mortgage assistance programs (Notice 14) 11,544
Requirements for issuers of stock (Notice 18) 11,549
Insurance:
Tax-free exchange of life insurance contract that is excepted
from the pro rata interest disallowance rule of section 264(f)
(RR 9) 12,554
Interest:
Investment:
Federal short-term, mid-term, and long-term rates for:
January 2011 (RR 2) 2,256
February 2011 (RR 4) 6,448
March 2011 (RR 6) 10,537
Rates:
Underpayments and overpayments, quarter beginning
April 1, 2011 (RR 5) 13,577
Letter rulings:
And determination letters, areas which will not be issued
from:
Associate Chief Counsel andDivision Counsel (TE/GE)
(RP 3) 1,111
Associate Chief Counsel (International) (RP 7) 1,233
And information letters issued by Associate Offices, determi-
nation letters issued by Operating Divisions (RP 1) 1,1;
correction to Rev. Proc. 2011–1 (Ann 7) 5,446
Method of accounting, automatic and non-automatic changes
(RP 14) 4,330
Mortgage assistance programs, income exclusion, safe harbor
deduction method (Notice 14) 11,544
Penalties, substantial understatement, preparer penalty (RP 13)
3,318
Private foundations, organizations now classified as (Ann 3) 3,
324; (Ann 13) 8,525
Proposed Regulations:
26 CFR 1.263A–0 thru –3, amended; 1.471–3,
amended; sales-based royalties and vendor allowances
(REG–149335–08) 6,468
26 CFR 1.863–10, added; source of income from qualified
fails charges (REG–132724–10) 7,498
26 CFR 1.1273–1, –2, amended; 1.1274–3, amended;
1.1275–2, amended; property traded on an established
market (REG–131947–10) 8,521
26 CFR 1.6049–4, revised; 1.6049–5, –6, amended;
1.6049–8, revised; 31.3406(g)–1, revised; guid-
ance on reporting interest paid to nonresident aliens
(REG–146097–09) 8,516
26 CFR Part 300.0, .4, 5, .6, amended; Parts 300.9 thru
.11, added; user fees relative to retirement plan agents
(REG–124018–10) 2,301
INCOME TAX—Cont.
26 CFR 301.7623–1, amended; rewards and awards for in-
formation relating to violations of internal revenue laws
(REG–131151–10) 8,519
Publication:
1220, changes affecting tax year 2010 filing of information
returns (Ann 1) 2,304
Real Estate Investment Trust (REIT) distressed debt (RP 16) 5,
440
Regulations:
26 CFR 1.468A–0T thru –9T, removed; 1.468A–0 thru –9,
added; 602.101, amended; deductions for contributions to
qualified nuclear decommissioning trusts (TD 9512) 7,473
26 CFR 1.863–10T, added; source of income from qualified
fails charges (TD 9508) 7,495
26 CFR 1.932–1, amended; source rules involving U.S. pos-
sessions and other conforming changes, correction to TD
9391 (Ann 12) 9,532
26 CFR 1.1001–3, amended; modifications of debt instru-
ments (TD 9513) 8,501
26 CFR 1.1221–3; added; 1.221–1–3T, removed; time and
manner rules for electing capital asset treatment for certain
self-created musical works (TD 9514) 9,527
26 CFR 1.1301–1, amended; 1.1301–1T, removed; farmer
and fisherman income averaging (TD 9509) 6,450
26 CFR 1.1462–1, amended; 1.6302–1 thru –4, amended;
31.6302–0 thru –2, –4, amended; 31.6302(c)–2A, re-
moved; 31.6302(c)–3, amended; 40.6302–1T, amended;
40.6302(c)–3, amended; 301.6302–1, amended;
301.6656–1, amended; 301.7502–2, removed; electronic
funds transfer of depository taxes (TD 9507) 3,305
26 CFR 1.6012–2, amended; requirement of a statement dis-
closing uncertain tax positions (TD 9510) 6,453
26 CFR 301.6103(n)–2, added; 301.6103(n)–2T, removed;
disclosure of return information in connection with written
contracts among the IRS, whistleblowers, and legal repre-
sentatives of whistleblowers (TD 9516) 13,575
26 CFR 301.6229(c)(2)–1, added; 301.6229(c)(2)–1T, re-
moved; 301.6501(e)–1, added; 301.6501(e)–1T, removed;
definition of omission from gross income (TD 9511) 6,455
Relief for tax return preparers who have pending PTIN applica-
tions (Notice 11) 7,497
Reporting requirements for interest paid to nonresident alien in-
dividuals (REG–146097–09) 8,516
Requirement of a statement disclosing uncertain tax positions
(TD 9510) 6,453
Revocations, exempt organizations (Ann 2) 3,324;(Ann15)8,
526; (Ann 17) 9,532; (Ann 23) 12,568
Rewards and awards for information relating to violations of in-
ternal revenue laws (REG–131151–10) 8,519
Sales-based royalties and vendor allowances (REG–149335–08)
6,468
Source of income from qualified fails charges (TD 9508) 7,495;
(REG–132724–10) 7,498
Source rules involving U.S. possessions and other conforming
changes, correction to TD 9391 (Ann 12) 9,532
Standard Industry Fare Level (SIFL) formula (RR 8) 12,554
2011–13 I.R.B.viiMarch 28, 2011

INCOME TAX—Cont.
State and local government bonds, TEB VCAP (Ann 19) 11,553
Tax convention:
U.S.-China agreement with respect to professors and teachers
(Ann 18) 12,567
Technical Advice Memoranda (TAMs) (RP 2) 1,90
Test of procedures for mediation and arbitration for Offer in
Compromise (OIC) and Trust Fund Recovery Penalty (TFRP)
cases in appeals (Ann 6) 4,433
User fees relating to enrolled agents and enrolled retirement plan
agents (REG–124018–10) 2,301
SELF-EMPLOYMENT TAX
Electronic Funds Transfer (EFT) of depository taxes (TD 9507)
3,305
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions (RP
1) 1,1;correction(Ann7)5,446
Regulations:
26 CFR 1.1462–1, amended; 1.6302–1 thru –4, amended;
31.6071, amended; 31.6302–0 thru –2, –4, amended;
31.6302(c)–2A, removed; 31.6302(c)–3, amended;
40.6302(c)–1 thru –3, amended; 301.6302–1, amended;
301.6656–1, amended; 301.7502–2, removed; Electronic
Funds Transfer (ETF) of depository taxes (TD 9507) 3,305
Technical Advice Memoranda (TAMs) (RP 2) 1,90
March 28, 2011viii2011–13 I.R.B.

2011–13 I.R.B.March 28, 2011

March 28, 20112011–13 I.R.B.

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