Internal Revenue Bulletin 2022-36 (PDF rendition): IRS Revenue Rulings

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Bulletin No. 2022–36
September 6, 2022
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.
ADMINISTRATIVE, INCOME TAX
Notice 2022-36, page 188.
This notice provides systemic penalty relief to taxpay-
ers for certain civil penalties with respect to 2019 and
2020 returns. The relevant penalties will be waived or,
to the extent previously assessed, abated, refunded, or
credited, as appropriate.
EMPLOYEE PLANS
Notice 2022-35, page 184.
Notice 2022-35 provides guidance on the corporate
bond monthly yield curve, the corresponding spot seg-
ment rates used under §417(e)(3), and the 24-month
average segment rates under §430(h)(2) of the Inter-
nal Revenue Code. In addition, this notice provides
guidance as to the interest rate on 30-year Treasury
securities under §417(e)(3)(A)(ii)(II) as in effect for plan
years beginning before 2008 and the 30-year Treasury
weighted average rate under §431(c)(6)(E)(ii)(I).
EXEMPT ORGANIZATIONS
Announcement 2022-18, page 190.
Revocation of IRC 501(c)(3) Organizations for failure
to meet the code section requirements. Contributions
made to the organizations by individual donors are no
longer deductible under IRC 170(b)(1)(A).
Announcement 2022-19, page 191.
Serves notice to potential donors of a stipulated deci-
sion by the United States Tax Court in declaratory judg-
ment proceedings under Section 7428.
INCOME TAX
Rev. Rul. 2022-17, page 182.
Federal rates; adjusted federal rates; adjusted federal
long-term rate, and the long-term tax exempt rate. For
purposes of sections 382, 1274, 1288, 7872 and
other sections of the Code, tables set forth the rates
for September 2022.
Finding Lists begin on page ii.

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and
enforce the law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing offi-
cial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
general interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of inter-
nal management are not published; however, statements of
internal practices and procedures that affect the rights and
duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service
on the application of the law to the pivotal facts stated in
the revenue ruling. In those based on positions taken in rul-
ings to taxpayers or technical advice to Service field offices,
identifying details and information of a confidential nature are
deleted to prevent unwarranted invasions of privacy and to
comply with statutory requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B,
Legislation 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
Rulings. Bank Secrecy Act Administrative Rulings are issued
by the Department of the Treasury’s Office of the Assistant
Secretary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index
for the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
September 6, 2022 Bulletin No. 2022–36

Part I
Section 1274.—
Determination of Issue
Price in the Case of Certain
Debt Instruments Issued for
Property
(Also Sections 42, 280G, 382, 467, 468, 482, 483,
1288, 7520, 7872.)
Rev. Rul. 2022-17
This revenue ruling provides vari-
ous prescribed rates for federal income
tax purposes for September 2022 (the
current month). Table 1 contains the
short-term, mid-term, and long-term
applicable federal rates (AFR) for the
current month for purposes of section
1274(d) of the Internal Revenue Code.
Table 2 contains the short-term, mid-
term, and long-term adjusted applica-
ble federal rates (adjusted AFR) for the
current month for purposes of section
1288(b). Table 3 sets forth the adjusted
federal long-term rate and the long-term
tax-exempt rate described in section
382(f). Table 4 contains the appropriate
percentages for determining the low-in-
come housing credit described in sec-
tion 42(b)(1) for buildings placed in
service during the current month. How-
ever, under section 42(b)(2), the appli-
cable percentage for non-federally sub-
sidized new buildings placed in service
after July 30, 2008, shall not be less
than 9%. Finally, Table 5 contains the
federal rate for determining the present
value of an annuity, an interest for life
or for a term of years, or a remainder or
a reversionary interest for purposes of
section 7520.
REV. RUL. 2022-17 TABLE 1
Applicable Federal Rates (AFR) for September 2022
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
AFR3.05%3.03%3.02%3.01%
110% AFR3.36%3.33%3.32%3.31%
120% AFR3.67%3.64%3.62%3.61%
130% AFR3.98%3.94%3.92%3.91%
Mid-term
AFR2.93%2.91%2.90%2.89%
110% AFR3.23%3.20%3.19%3.18%
120% AFR3.52%3.49%3.47%3.46%
130% AFR3.82%3.78%3.76%3.75%
150% AFR4.42%4.37%4.35%4.33%
175% AFR5.15%5.09%5.06%5.04%
Long-term
AFR3.14%3.12%3.11%3.10%
110% AFR3.46%3.43%3.42%3.41%
120% AFR3.77%3.74%3.72%3.71%
130% AFR4.10%4.06%4.04%4.03%
REV. RUL. 2022-17 TABLE 2
Adjusted AFR for September 2022
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term adjusted AFR2.31%2.30%2.29%2.29%
Mid-term adjusted AFR2.22%2.21%2.20%2.20%
Long-term adjusted AFR2.38%2.37%2.36%2.36%
September 6, 2022 182 Bulletin No. 2022–36

REV. RUL. 2022-17 TABLE 3
Rates Under Section 382 for September 2022
Adjusted federal long-term rate for the current month2.38%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal
long-term rates for the current month and the prior two months.)
2.54%
REV. RUL. 2022-17 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for September 2022
Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July
30, 2008, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit7.70%
Appropriate percentage for the 30% present value low-income housing credit 3.30%
REV. RUL. 2022-17 TABLE 5
Rate Under Section 7520 for September 2022
Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years, or a
remainder or reversionary interest
3.60%
Section 42.—Low-Income
Housing Credit
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
September 2022. See Rev. Rul. 2022-17, page 182.
Section 280G.—Golden
Parachute Payments
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
September 2022. See Rev. Rul. 2022-17, page 182.
Section 382.—Limitation
on Net Operating Loss
Carryforwards and
Certain Built-In Losses
Following Ownership
Change
The adjusted applicable federal long-term rate
is set forth for the month of September 2022. See
Rev. Rul. 2022-17, page 182.
Section 467.—Certain
Payments for the Use of
Property or Services
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
September 2022. See Rev. Rul. 2022-17, page 182.
Section 468.—Special
Rules for Mining and Solid
Waste Reclamation and
Closing Costs
The applicable federal short-term rates are set
forth for the month of September 2022. See Rev.
Rul. 2022-17, page 182.
Section 482.—Allocation
of Income and Deductions
Among Taxpayers
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
September 2022. See Rev. Rul. 2022-17, page 182.
Section 483.—Interest on
Certain Deferred Payments
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
September 2022. See Rev. Rul. 2022-17, page 182.
Section 1288.—Treatment
of Original Issue Discount
on Tax-Exempt Obligations
The adjusted applicable federal short-term,
mid-term, and long-term rates are set forth for the
month of September 2022. See Rev. Rul. 2022-17,
page 182.
Section 7520.—Valuation
Tables
The applicable federal mid-term rates are set
forth for the month of September 2022. See Rev.
Rul. 2022-17, page 182.
Section 7872.—Treatment
of Loans With Below-
Market Interest Rates
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
September 2022. See Rev. Rul. 2022-17, page 182.

Bulletin No. 2022–36 183 September 6, 2022

September 6, 2022 184 Bulletin No. 2022–36
Part III
Update for Weighted
Average Interest Rates,
Yield Curves, and Segment
Rates
Notice 2022-35
This notice provides guidance on the
corporate bond monthly yield curve, the
corresponding spot segment rates used
under § 417(e)(3), and the 24-month
average segment rates under § 430(h)
(2) of the Internal Revenue Code. In
addition, this notice provides guid-
ance as to the interest rate on 30-year
Treasury securities under § 417(e)(3)
(A)(ii)(II) as in effect for plan years
beginning before 2008 and the 30-year
Treasury weighted average rate under
§ 431(c)(6)(E)(ii)(I).
YIELD CURVE AND SEGMENT
RATES
Section 430 specifies the minimum
funding requirements that apply to
single-employer plans (except for CSEC
plans under § 414(y)) pursuant to § 412.
Section 430(h)(2) specifies the inter-
est rates that must be used to determine
a plan’s target normal cost and funding
target. Under this provision, present
value is generally determined using three
24-month average interest rates (“seg-
ment rates”), each of which applies to
cash flows during specified periods. To
the extent provided under § 430(h)(2)(C)
(iv), these segment rates are adjusted by
the applicable percentage of the 25-year
average segment rates for the period end-
ing September 30 of the year preceding
the calendar year in which the plan year
begins.
1
However, an election may be
made under § 430(h)(2)(D)(ii) to use the
monthly yield curve in place of the seg-
ment rates.
Notice 2007-81, 2007-44 I.R.B. 899,
provides guidelines for determining the
monthly corporate bond yield curve, and
the 24-month average corporate bond
segment rates used to compute the target
normal cost and the funding target. Con-
sistent with the methodology specified in
Notice 2007-81, the monthly corporate
bond yield curve derived from July 2022
data is in Table 2022-7 at the end of this
notice. The spot first, second, and third
segment rates for the month of July 2022
are, respectively, 3.67, 4.67, and 4.73
The 24-month average segment rates
determined under § 430(h)(2)(C)(i)
through (iii) must be adjusted pursuant
to § 430(h)(2)(C)(iv) to be within the
applicable minimum and maximum per-
centages of the corresponding 25-year
average segment rates. The 25-year aver-
age segment rates for plan years begin-
ning in 2021 and 2022 were published
in Notice 2020-72, 2020-40 I.R.B. 789,
and Notice 2021-54, 2021-41 I.R.B. 457,
respectively.
24-MONTH AVERAGE CORPORATE
BOND SEGMENT RATES
The three 24-month average corpo-
rate bond segment rates applicable for
August 2022 without adjustment for the
25-year average segment rate limits are
as follows:
24-Month Average Segment Rates Without 25-Year Average Adjustment
Applicable Month First Segment Second Segment Third Segment
August 2022 1.27 2.99 3.51
25-YEAR AVERAGE SEGMENT
RATES
Section 9706(a) of the American Res-
cue Plan Act of 2021, Pub. L. 117-2 (the
ARP), which was enacted on March 11,
2021, changed the 25-year average seg-
ment rates and the applicable minimum
and maximum percentages used under
§ 430(h)(2)(C)(iv) of the Code to adjust
the 24-month average segment rates.
2
Prior
to this change, the applicable minimum
and maximum percentages were 85%
and 115% for a plan year beginning in
2021, and 80% and 120% for a plan year
beginning in 2022, respectively. After this
change, the applicable minimum and max-
imum percentages are 95% and 105% for
a plan year beginning in 2021 or 2022.
In addition, pursuant to this change, any
25-year average segment rate that is less
than 5% is deemed to be 5%.
3
Pursuant to § 9706(c)(1) of the ARP,
these changes apply with respect to plan
years beginning on or after January 1,
2020. However, § 9706(c)(2) of the ARP
provides that a plan sponsor may elect not
to have these changes apply to any plan
year beginning before January 1, 2022.
4
The adjusted 24-month average seg-
ment rates set forth in the chart below
reflect § 430(h)(2)(C)(iv) of the Code
as amended by § 9706(a) of the ARP.
These adjusted 24-month average seg-
ment rates apply only for plan years for
which an election under § 9706(c)(2) of
1
Pursuant to § 433(h)(3)(A), the third segment rate determined under § 430(h)(2)(C) is used to determine the current liability of a CSEC plan (which is used to calculate the minimum amount
of the full funding limitation under § 433(c)(7)(C)).
2
Section 80602 of the Infrastructure Investment and Jobs Act, Pub. L. 117-58, makes further changes to the time periods for which specified applicable minimum and maximum percentages
apply.
3
Pursuant to this change, the 25-year averages of the first segment rate for 2021 and 2022 are increased to 5.00% because those 25-year averages as originally published are below 5.00%.
4
This election may be made either for all purposes for which the amendments under § 9706 of the ARP apply or solely for purposes of determining the adjusted funding target attainment
percentage under § 436 of the Code for the plan year.

Bulletin No. 2022–36 185 September 6, 2022
the ARP is not in effect. For a plan year for
which such an election does not apply, the
24-month averages applicable for August
2022, adjusted to be within the applica-
ble minimum and maximum percentages
of the corresponding 25-year average
segment rates in accordance with § 430(h)
(2)(C)(iv) of the Code, are as follows:
Adjusted 24-Month Average Segment Rates
For Plan Years
Beginning InApplicable MonthFirst SegmentSecond SegmentThird Segment
2021August 20224.755.366.11
2022August 20224.755.185.92
The adjusted 24-month average seg-
ment rates set forth in the chart below do
not reflect the changes to § 430(h)(2)(C)
(iv) of the Code made by § 9706(a) of the
ARP. These adjusted 24-month average
segment rates apply only for plan years
for which an election under § 9706(c)(2)
of the ARP is in effect. For a plan year
for which such an election applies, the
24-month averages applicable for July
2022, adjusted to be within the applicable
minimum and maximum percentages of
the corresponding 25-year average seg-
ment rates in accordance with § 430(h)(2)
(C)(iv) of the Code, are as follows:
Pre-ARP Adjusted 24-Month Average Segment Rates
For Plan Years
Beginning InApplicable MonthFirst SegmentSecond SegmentThird Segment
2021August 20223.324.795.47
30-YEAR TREASURY SECURITIES
INTEREST RATES
Section 431 specifies the minimum
funding requirements that apply to mul-
tiemployer plans pursuant to § 412. Sec-
tion 431(c)(6)(B) specifies a minimum
amount for the full-funding limitation
described in § 431(c)(6)(A), based on the
plan’s current liability. Section 431(c)(6)
(E)(ii)(I) provides that the interest rate
used to calculate current liability for this
purpose must be no more than 5 percent
above and no more than 10 percent below
the weighted average of the rates of inter-
est on 30-year Treasury securities during
the four-year period ending on the last
day before the beginning of the plan year.
Notice 88-73, 1988-2 C.B. 383, provides
guidelines for determining the weighted
average interest rate. The rate of interest
on 30-year Treasury securities for July
2022 is 3.10 percent. The Service deter-
mined this rate as the average of the daily
determinations of yield on the 30-year
Treasury bond maturing in May 2052. For
plan years beginning in August 2022, the
weighted average of the rates of interest
on 30-year Treasury securities and the
permissible range of rates used to calcu-
late current liability are as follows:
Treasury Weighted Average Rates
For Plan Years Beginning In30-Year Treasury Weighted AveragePermissible Range 90% to 105%
August 20222.191.97 to 2.30
MINIMUM PRESENT VALUE
SEGMENT RATES
In general, the applicable interest rates
under § 417(e)(3)(D) are segment rates
computed without regard to a 24-month
average. Notice 2007-81 provides guide-
lines for determining the minimum
present value segment rates. Pursuant to
that notice, the minimum present value
segment rates determined for July 2022
are as follows:
Minimum Present Value Segment Rates
Month First Segment Second Segment Third Segment
July 2022 3.67 4.67 4.73

September 6, 2022 186 Bulletin No. 2022–36
DRAFTING INFORMATION
The principal author of this notice is
Tom Morgan of the Office of Associate
Chief Counsel (Employee Benefits,
Exempt Organizations, and Employment
Taxes). However, other personnel from
the IRS participated in the development
of this guidance. For further information
regarding this notice, contact Mr. Morgan
at 202-317-6700 or Osmundo Bernabe at
626-927-1344 (not a toll-free number).

Bulletin No. 2022–36 187 September 6, 2022
Table 2022-7
Monthly Yield Curve for July 2022
Derived from June 2022 Data
MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield
0.52.9820.54.8440.54.7260.54.6980.54.67
1.03.2621.04.8341.04.7261.04.6881.04.67
1.53.5021.54.8341.54.7261.54.6881.54.67
2.03.6722.04.8242.04.7162.04.6882.04.67
2.53.7822.54.8142.54.7162.54.6882.54.67
3.03.8323.04.8143.04.7163.04.6883.04.67
3.53.8623.54.8043.54.7163.54.6883.54.67
4.03.8924.04.7944.04.7164.04.6884.04.67
4.53.9224.54.7944.54.7164.54.6884.54.67
5.03.9725.04.7845.04.7165.04.6885.04.67
5.54.0225.54.7845.54.7165.54.6885.54.67
6.04.0826.04.7846.04.7166.04.6886.04.67
6.54.1526.54.7746.54.7066.54.6886.54.67
7.04.2227.04.7747.04.7067.04.6887.04.66
7.54.2927.54.7747.54.7067.54.6887.54.66
8.04.3728.04.7648.04.7068.04.6888.04.66
8.54.4428.54.7648.54.7068.54.6888.54.66
9.04.5029.04.7649.04.7069.04.6889.04.66
9.54.5729.54.7549.54.7069.54.6889.54.66
10.04.6230.04.7550.04.7070.04.6890.04.66
10.54.6730.54.7550.54.7070.54.6890.54.66
11.04.7231.04.7551.04.7071.04.6891.04.66
11.54.7631.54.7551.54.7071.54.6791.54.66
12.04.7932.04.7452.04.7072.04.6792.04.66
12.54.8232.54.7452.54.7072.54.6792.54.66
13.04.8433.04.7453.04.6973.04.6793.04.66
13.54.8633.54.7453.54.6973.54.6793.54.66
14.04.8734.04.7454.04.6974.04.6794.04.66
14.54.8834.54.7354.54.6974.54.6794.54.66
15.04.8935.04.7355.04.6975.04.6795.04.66
15.54.8935.54.7355.54.6975.54.6795.54.66
16.04.8936.04.7356.04.6976.04.6796.04.66
16.54.8936.54.7356.54.6976.54.6796.54.66
17.04.8837.04.7357.04.6977.04.6797.04.66
17.54.8837.54.7357.54.6977.54.6797.54.66
18.04.8738.04.7258.04.6978.04.6798.04.66
18.54.8738.54.7258.54.6978.54.6798.54.66
19.04.8639.04.7259.04.6979.04.6799.04.66
19.54.8539.54.7259.54.6979.54.6799.54.66
20.04.8540.04.7260.04.6980.04.67100.04.66

September 6, 2022 188 Bulletin No. 2022–36
Penalty Relief for Certain
Taxpayers Filing Returns
for Taxable Years 2019
and 2020
Notice 2022-36
SECTION 1. PURPOSE
This notice provides relief for certain
taxpayers from certain failure to file pen-
alties and certain international informa-
tion return (IIR) penalties with respect
to tax returns for taxable years 2019 and
2020 that are filed on or before September
30, 2022. This notice also provides relief
from certain information return penalties
with respect to taxable year 2019 returns
that were filed on or before August 1,
2020, and with respect to taxable year
2020 returns that were filed on or before
August 1, 2021. The relevant penalties
will be waived or, to the extent previously
assessed, abated, refunded, or credited,
as described in section 3.A of this notice.
Situations where penalty relief does not
apply are described in section 3.B of this
notice.
SECTION 2. BACKGROUND
Section 6651(a)(1) of the Internal Rev-
enue Code (Code) generally imposes an
addition to tax for a failure to file (on or
before the date prescribed) a tax return
that is required under the authority of
subchapter A of chapter 61 (other than
part III regarding information returns) of
the Code, including certain income tax
returns.
1
Section 6038 generally imposes a
penalty for the failure of certain United
States persons to furnish (on or before the
date prescribed) certain information with
respect to a controlled foreign corporation
or a controlled foreign partnership that the
person owns.
Section 6038A(d) imposes a penalty on
a “25-percent foreign-owned” domestic
corporation or wholly foreign-owned
domestic disregarded entity for the fail-
ure to furnish (on or before the date pre-
scribed) certain information or the failure
to maintain certain records.
Section 6038C(c) imposes a penalty on
a foreign corporation engaged in a U.S.
trade or business for the failure to furnish
(on or before the date prescribed) certain
information or the failure to maintain cer-
tain records.
Section 6039F(c) imposes a penalty on
a United States person for the failure to
furnish (on or before the date prescribed)
certain information with respect to the
receipt of large gifts or bequests from for-
eign persons.
Section 6677 generally imposes a
penalty on a United States person for the
failure to file (on or before the date pre-
scribed) a notice or return required by
section 6048 with respect to transactions
with, or ownership of, a foreign trust.
Section 6698(a)(1) generally imposes a
penalty for the failure of any partnership
to file (on or before the date prescribed)
the return required under section 6031.
Section 6698(a)(2) generally imposes
a penalty for filing a return that fails to
show the information required under sec-
tion 6031.
Section 6699(a)(1) generally imposes
a penalty for the failure of any S corpo-
ration (as defined in section 1361(a)(1))
to file (on or before the date prescribed) a
return required under section 6037. Sec-
tion 6699(a)(2) generally imposes a pen-
alty for filing a return that fails to show the
information required under section 6037.
Section 6721(a)(2)(A) generally
imposes a penalty for the failure to file an
information return (as defined in section
6724(d)(1)) on or before the required fil-
ing date.
The foregoing penalties do not apply
if the taxpayer can show that the fail-
ure to timely file the return or to furnish
the required information or to provide
the required notice, as applicable, is due
to reasonable cause. See §§ 6651(a)(1),
6038(c)(4)(B), 6038A(d)(3), 6038C(c),
6039F(c)(2), 6677(d), 6698(a) flush
language, 6699(a) flush language, and
6724(a).
On March 13, 2020, the President of
the United States issued an emergency
declaration under the Robert T. Stafford
Disaster Relief and Emergency Assistance
Act, 42 U.S.C. 5121 et seq., in response
to the ongoing Coronavirus Disease 2019
(COVID-19) pandemic (Emergency Dec-
laration).
2
The Emergency Declaration
instructed the Secretary of the Treasury “to
provide relief from tax deadlines to Amer-
icans who have been adversely affected
by the COVID-19 emergency, as appro-
priate, pursuant to 26 U.S.C. 7508A(a).”
In response, the Department of the Trea-
sury (Treasury Department) and the Inter-
nal Revenue Service (IRS) issued a series
of notices and other guidance to provide
relief to affected taxpayers. In particu-
lar, Notice 2020-17, 2020-15 I.R.B. 590,
postponed the due date for certain Federal
income tax payments from April 15, 2020,
until July 15, 2020. Notice 2020-18, 2020-
15 I.R.B. 590, superseded Notice 2020-17
and provided expanded relief postponing
the due date for filing Federal income tax
returns that were originally due on April
15, 2020, to July 15, 2020, among other
things. Notice 2021-21, 2021-15 I.R.B.
986, postponed the due date for filing Fed-
eral income tax returns in the Form 1040
series and making certain Federal income
tax payments that were originally due on
April 15, 2021, to May 17, 2021.
Additions to tax or penalties for failure
to timely file returns continued to accrue
for taxpayers who did not file by the post-
poned due dates.
The COVID-19 pandemic has also had
an unprecedented effect on the IRS’s per-
sonnel and operations. The agency was
called upon to support emergency relief
for taxpayers, such as distributing eco-
nomic impact payments,
3
while sustaining
its regular operations in a pandemic envi-
ronment with limited resources, where
employees were sometimes unable to be
physically present to process tax returns
and correspondence. In response to these
1
Unless otherwise stated, all “section” references are to provisions of the Code.
2
https://trumpwhitehouse.archives.gov/briefings-statements/letter-president-donald-j-trump-emergency-determination-stafford-act/.
3
The IRS, in coordination with the Bureau of the Fiscal Service, issued more than 476.1 million payments through three rounds of economic impact payments, totaling more than $814.4
billion during 2020 and 2021. IRS Data Book, 2021, Publication 55-B.

Bulletin No. 2022–36 189 September 6, 2022
challenges, the IRS has been work-
ing aggressively to process backlogged
returns and taxpayer correspondence to
return to normal operations for the 2023
filing season. The Treasury Department
and the IRS have determined that the
penalty relief described in this notice
will allow the IRS to focus its resources
more effectively, as well as provide relief
to taxpayers affected by the COVID-19
pandemic.
SECTION 3. GRANT OF RELIEF
A. Waiver and Abatement of Certain
Penalties for Taxpayers
The IRS will not impose the penalties
listed in section 3.A.(1) through (4) of this
notice with respect to the specified tax
returns for taxable years 2019 and 2020
that are filed on or before September 30,
2022. The penalties listed in this section
3.A of this notice will be automatically
abated, refunded, or credited, as appro-
priate without any need for taxpayers to
request this relief.
(1) Additions to tax under section
6651(a)(1) for failure to file the following
income tax returns:
• Form 1040, U.S. Individual Income
Tax Return; Form 1040-C, U.S.
Departing Alien Income Tax Return;
Form 1040-NR, U.S. Nonresident
Alien Income Tax Return; Form 1040-
NR-EZ, U.S. Income Tax Return for
Certain Nonresident Aliens With No
Dependents; Form 1040 (PR), Fed-
eral Self-Employment Contribution
Statement for Residents of Puerto
Rico; Form 1040-SR, U.S. Tax Return
for Seniors; and Form 1040-SS, U.S.
Self-Employment Tax Return (Includ-
ing the Additional Child Tax Credit
for Bona Fide Residents of Puerto
Rico);
• Form 1041, U.S. Income Tax Return
for Estates and Trusts; Form 1041-
N, U.S. Income Tax Return for Elect-
ing Alaska Native Settlement Trusts;
and Form 1041-QFT, U.S. Income
Tax Return for Qualified Funeral
Trusts;
• Form 1120, U.S. Corporation
Income Tax Return; Form 1120-C,
U.S. Income Tax Return for Coop-
erative Associations; Form 1120-F,
U.S. Income Tax Return of a Foreign
Corporation; Form 1120-FSC, U.S.
Income Tax Return of a Foreign
Sales Corporation; Form 1120-H,
U.S. Income Tax Return for Home-
owners Associations; Form 1120-
L, U.S. Life Insurance Company
Income Tax Return; Form 1120-ND,
Return for Nuclear Decommission-
ing Funds and Certain Related Per-
sons; Form 1120-PC, U.S. Property
and Casualty Insurance Company
Income Tax Return; Form 1120-POL,
U.S. Income Tax Return for Certain
Political Organizations; Form 1120-
REIT, U.S. Income Tax Return for
Real Estate Investment Trusts; Form
1120-RIC, U.S. Income Tax Return
for Regulated Investment Companies;
and Form 1120-SF, U.S. Income Tax
Return for Settlement Funds (Under
Section 468B);
• Form 1066, U.S. Real Estate Mort-
gage Investment Conduit (REMIC)
Income Tax Return; and
• Form 990-PF, Return of Private
Foundation or Section 4947(a)(1)
Trust Treated as Private Foundation;
and Form 990-T, Exempt Organiza-
tion Business Income Tax Return (and
Proxy Tax Under Section 6033(e)).
(2) Certain penalties under sections
6038, 6038A, 6038C, 6039F and 6677 for
failure to timely file the following IIRs:
• Penalties systematically assessed
when a Form 5471, Information
Return of U.S. Persons With Respect
To Certain Foreign Corporations,
and/or Form 5472, Information
Return of a 25% Foreign-Owned U.S.
Corporation or a Foreign Corpora-
tion Engaged in a U.S. Trade or Busi-
ness, is attached to a late-filed Form
1120 or Form 1065; and
• Penalties assessed by the campus
assessment program with respect to
filings on Form 3520, Annual Return
To Report Transactions With Foreign
Trusts and Receipt of Certain Foreign
Gifts, and on Form 3520-A, Annual
Information Return of Foreign Trust
With a U.S. Owner (Under section
6048(b)).
(3) Penalties under section 6698(a)(1)
for failure to timely file and under section
6698(a)(2) for failure to show the required
information on a Form 1065, U.S. Return
of Partnership Income.
(4) Penalties under section 6699(a)(1)
for failure to timely file and under section
6699(a)(2) for failure to show the required
information on a Form 1120-S, U.S.
Income Tax Return for an S corporation.
In addition, the IRS will not impose
the penalties under section 6721(a)(2)(A)
for failure to timely file any information
return (as defined in section 6724(d)(1))
that meets the following criteria:
• 2019 returns that were filed on or
before August 1, 2020, with an orig-
inal due date of January 31, 2020;
February 28, 2020 (if filed on paper)
or March 31, 2020 (if filed electroni-
cally); or March 15, 2020; or
• 2020 returns that were filed on or
before August 1, 2021, with an orig-
inal due date of January 31, 2021;
February 28, 2021 (if filed on paper)
or March 31, 2021 (if filed electroni-
cally); or March 15, 2021.
B. Exceptions
The penalty relief described in this
notice does not apply to any penalties that
are not specifically listed in the grant of
relief under section 3.A of this notice. In
addition, the penalty relief described in
section 3.A of this notice is not available
with respect to any return to which the
penalty for fraudulent failure to file under
section 6651(f) or the penalty for fraud
under section 6663 applies. The penalty
relief described in this notice also does
not apply to any penalties in an accepted
offer in compromise under section 7122
because acceptance of the offer conclu-
sively settled all of the liabilities in the
offer under § 301.7122-1(e)(5) of the
Procedure and Administration Regula-
tions. The penalty relief described in this
notice does not apply to any penalty set-
tled in a closing agreement under section
7121 or finally determined in a judicial
proceeding.
SECTION 4. DRAFTING
INFORMATION
The principal author of this notice is
Han Huang of the Office of the Associate
Chief Counsel (Procedure and Adminis-
tration). For further information regarding
this notice, contact Ms. Huang at (202)
317-6844 (not a toll-free number).

September 6, 2022 190 Bulletin No. 2022–36
Part IV
Deletions From Cumulative
List of Organizations,
Contributions to Which
are Deductible Under
Section 170 of the Code
Announcement 2022-18
Table of Contents
The Internal Revenue Service has
revoked its determination that the organi-
zations listed below qualify as organiza-
tions described in sections 501(c)(3) and
170(c)(2) of the Internal Revenue Code of
1986.
Generally, the IRS will not disallow
deductions for contributions made to a
listed organization on or before the date
of announcement in the Internal Revenue
Bulletin that an organization no longer
qualifies. However, the IRS is not pre-
cluded from disallowing a deduction for
any contributions made after an organiza-
tion ceases to qualify under section 170(c)
(2) if the organization has not timely filed
a suit for declaratory judgment under sec-
tion 7428 and if the contributor (1) had
knowledge of the revocation of the ruling
or determination letter, (2) was aware that
such revocation was imminent, or (3) was
in part responsible for or was aware of the
activities or omissions of the organization
that brought about this revocation.
If on the other hand a suit for declar-
atory judgment has been timely filed,
contributions from individuals and orga-
nizations described in section 170(c)(2)
that are otherwise allowable will continue
to be deductible. Protection under sec-
tion 7428(c) would begin on September
6, 2022 and would end on the date the
court first determines the organization is
not described in section 170(c)(2) as more
particularly set for in section 7428(c)(1).
For individual contributors, the maximum
deduction protected is $1,000, with a hus-
band and wife treated as one contributor.
This benefit is not extended to any indi-
vidual, in whole or in part, for the acts or
omissions of the organization that were
the basis for revocation.
NAME OF ORGANIZATION
Effective Date of
Revocation
LOCATION
Concord High School Band Boosters Club8/1/2016Concord, CA
Amazing Gospel Souls, Inc.1/1/2017Washington, DC
R Peter and Barbara Fishman Supporting Foundation Inc.7/1/2018Atlanta, GA
AMERICAN FUNDRAISING FOUNDATION INC.9/1/2017MAITLAND, FL
NEW HORIZONS YOUTH RANCH INC.1/1/2017SEELEY LAKE, MT
Raindancer Foundation1/1/2018San Ramon, CA
Development Disabilities Associates, Inc.7/1/2016Waterford, CT
Milk Saving Starving Children7/1/2017Scranton, PA
CHARACTER EDUCATION AND THE ARTS1/1/2019SAYVILLE, NY
Asset Trader1/1/2012Raleigh, NC
MIAMIS RIVER OF LIFE INC1/1/2018OPA LOCKA, FL
SPANGENBERG FAMILY FOUNDATION TO BENEFIT CHILDRENS
EDUCATION & HEALTHCARE
1/1/2018DALLAS, TX
A Human Project1/1/2017Clark Fork, ID
Chevy Chase University, Ltd1/1/2018Chevy Chase, MD
Open Hearts And Spiritual Mind Foundation Inc.1/1/2019Hillside, NJ
Service to Servants Inc.1/1/2019Homosassa, FL
American Friends of Yeshivat Haraayon1/1/2017Lincolnwood, IL
Susan B Krevoy Eating Disorders Program Inc.1/1/2018Beverly Hills, CA
International Hunger And Homeless Charity1/1/2017North Las Vegas, NV
United States of America Arabian and Half Arabian National Championship1/1/2018Gilbert, AZ
Uphill Media Inc.1/1/2018Corvallis, OR
Plattduetsche Volksfest Verein1/1/2018Franklin SQ, NY

Bulletin No. 2022–36 191 September 6, 2022
Section 7428(c) Validation
of Certain Contributions
Made During Pendency
of Declaratory Judgment
Proceedings
Announcement 2022-19
This announcement serves notice to
potential donors that the organization
listed below has recently filed a timely
declaratory judgment suit under section
7428 of the Code, challenging revocation
of its status as an eligible donee under sec-
tion 170(c)(2).
Protection under section 7428(c) of the
Code begins on the date that the notice
of revocation is published in the Internal
Revenue Bulletin and ends on the date
on which a court first determines that an
organization is not described in section
170(c)(2), as more particularly set forth in
section 7428(c)(1).
In the case of individual contributors,
the maximum amount of contributions
protected during this period is limited to
$1,000.00, with a husband and wife being
treated as one contributor. This protection
is not extended to any individual who was
responsible, in whole or in part, for the acts
or omissions of the organization that were
the basis for the revocation. This protec-
tion also applies (but without limitation as
to amount) to organizations described in
section 170(c)(2) which are exempt from
tax under section 501(a). If the organiza-
tion ultimately prevails in its declaratory
judgment suit, deductibility of contribu-
tions would be subject to the normal lim-
itations set forth under section 170.
Name of OrganizationDate Suit Filed
Effective Date of
Revocation
Location
Goodcity, NFP4/29/20227/1/2017Payson, AZ

Bulletin No. 2022–36 i September 6, 2022
Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus,
if an earlier ruling held that a principle
applied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguished describes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modified is used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified and clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transactions.
This term is most commonly used in a ruling
that lists previously published rulings that
are obsoleted because of changes in laws or
regulations. A ruling may also be obsoleted
because the substance has been included in
regulations subsequently adopted.
Revoked describes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a
period of time in separate rulings. If the
new ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example, modified and
superseded describes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspended is used in rare situations
to show that the previous published rul-
ings will not be applied pending some
future action such as the issuance of new
or amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in
material published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.
—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.

September 6, 2022 ii Bulletin No. 2022–36
Numerical Finding List
1
Bulletin 2022–36
Announcements:
2022-14, 2022-31 I.R.B. 136
2022-15, 2022-31 I.R.B. 136
2022-16, 2022-33 I.R.B. 144
2022-17, 2022-35 I.R.B. 179
2022-18, 2022-36 I.R.B. 190
2022-19, 2022-36 I.R.B. 191
Notices:
2022-29, 2022-28 I.R.B. 66
2022-30, 2022-28 I.R.B. 70
2022-31, 2022-29 I.R.B. 85
2022-32, 2022-32 I.R.B. 137
2022-33, 2022-34 I.R.B. 147
2022-34, 2022-34 I.R.B. 150
2022-35, 2022-36 I.R.B. 184
2022-36, 2022-36 I.R.B. 188
Proposed Regulations:
REG-130975-08, 2022-28 I.R.B. 71
REG 130675-17, 2022-30 I.R.B. 104
Revenue Procedures:
2022-25, 2022-27 I.R.B. 3
2022-28, 2022-27 I.R.B. 65
2022-26, 2022-29 I.R.B. 90
2022-32, 2022-30 I.R.B. 101
2022-30, 2022-31 I.R.B. 112
2022-29, 2022-33 I.R.B. 141
2022-34, 2022-33 I.R.B. 143
Revenue Rulings:
2022-12, 2022-27 I.R.B. 1
2022-13, 2022-30 I.R.B. 99
2022-14, 2022-31 I.R.B. 110
2022-15, 2022-35 I.R.B. 152
2022-17, 2022-36 I.R.B. 182
Treasury Decisions:
9963, 2022-34 I.R.B. 145
9964, 2022-35 I.R.B. 172
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2021–27 through 2021–52 is in Internal Revenue Bulletin
2021–52, dated December 27, 2021.

Bulletin No. 2022–36 iii September 6, 2022
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2022–36
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2021–27 through 2021–52 is in Internal Revenue Bulletin
2021–52, dated December 27, 2021.

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