Internal Revenue Bulletin 2015-38

Official source: Internal Revenue Bulletin (https://www.irs.gov/pub/irs-irbs/irb15-38.pdf), retrieved 2026-10-03. U.S. Government work (17 U.S.C. § 105).

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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.

Announcement 2015–20, page 355. The Office of Professional Responsibility (OPR) announces recent disciplinary sanctions involving attorneys, certified public accountants, enrolled agents, enrolled actuaries, enrolled retirement plan agents, and appraisers. These individuals are subject to the regulations governing practice before the Internal Revenue Service (IRS), which are set out in Title 31, Code of Federal Regulations, Part 10, and which are published in pamphlet form as Treasury Department Circular No. 230. The regulations prescribe the duties and restrictions relating to such practice and prescribe the disciplinary sanctions for violating the regulations.

Finding Lists begin on page ii.

Rev. Rul. 2015–20, page 353. Fringe benefits aircraft valuation formula. For purposes of section 1.61–21(g) of the Income Tax Regulations, relating to the rule for valuing non-commercial flights on employerprovided aircraft, the Standard Industry Fare Level (SIFL) centsper-mile rates and terminal charge in effect for the second half of 2015 are set forth.

Rev. Proc. 2015–44, page 354. This revenue procedure announces the elimination of the Appeals arbitration program and obsoletes Revenue Procedure 2006–44, 2006–2 C.B. 800, which formally established the Appeals arbitration program.

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.

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 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 substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal 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 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.—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, disbarment 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 21, 2015 Bulletin No. 2015–38

Section 61.—Gross Income Defined

26 CFR 1.61–21: Taxation of fringe benefits.

Rev. Rul. 2015–20

For purposes of the taxation of fringe benefits under section 61 of the Internal Revenue Code, section 1.61–21(g) of the

Income Tax Regulations provides a rule for valuing noncommercial flights on employer-provided aircraft. Section 1.61– 21(g)(5) provides an aircraft valuation formula to determine the value of such flights. The value of a flight is determined under the base aircraft valuation formula (also known as the Standard Industry Fare Level formula or SIFL) by multiplying the SIFL cents-per-mile rates applicable for

the period during which the flight was taken by the appropriate aircraft multiple provided in section 1.61–21(g)(7) and then adding the applicable terminal charge. The SIFL cents-per-mile rates in the formula and the terminal charge are calculated by the Department of Transportation and are reviewed semi-annually.

The following chart sets forth the terminal charge and SIFL mileage rates:

Period During Which the Flight Is Taken Terminal Charge SIFL Mileage Rates 7/1/15–12/31/15 $42.79 Up to 500 miles - $.2341 per mile

501–1500 miles - $.1785 per mile Over 1500 miles - $.1716 per mile

DRAFTING INFORMATION

The principal author of this revenue ruling is Kathleen Edmondson of the Of

fice of Associate Chief Counsel (Tax Exempt/Government Entities). For further information regarding this revenue ruling,

contact Ms. Edmondson at (202) 317-6798 (not a toll-free number).

Bulletin No. 2015–38 353 September 21, 2015

26 CFR 601.106: Appeals Functions (Also: §§ 601.202, 601.203; and Part I, § 7123(b))

Administrative, Procedural, and Miscellaneous

Rev. Proc. 2015–44

This revenue procedure announces the elimination of the Appeals arbitration program and obsoletes Revenue Procedure 2006–44, 2006–2 C.B. 800, which formally established the Appeals arbitration program.

Section 7123(b)(2) of the Code requires that the IRS establish a pilot program under which a taxpayer and Appeals may jointly request binding arbitration on any issue unresolved at the conclusion of appeals procedures or unsuccessful attempts to enter into a closing agreement under section 7121 or a compromise under section 7122. To comply with section 7123(b), on January 18, 2000, Appeals initiated a two-year pilot program offering arbitration procedures. See Announcement 2000–4, 2000–1 C.B. 317. On June 30, 2003, Appeals completed an additional one-year pilot of its arbitration procedures. See Announcement 2002–60, 2002–2 C.B. 28. During these pilot programs, Appeals offered an opportunity for taxpayers to request arbitration for certain

factual issues that were already subject to the Appeals administrative process. On October 30, 2006, the IRS published Rev. Proc. 2006–44, 2006–2 C.B. 800, which formally established the Appeals arbitration program. Generally, arbitration has been available under these procedures for cases in which a limited number of factual issues remain unresolved following settlement discussions in Appeals.

In Announcement 2008–111, 2008–48 I.R.B. 1224, published December 1, 2008, partially superseded by Rev. Proc. 2014– 63, 2014–53 I.R.B. 1014, Appeals established a two-year pilot program to extend arbitration to certain collection cases. Under the pilot program, taxpayers in select cities were eligible to use arbitration to resolve certain offer in compromise and Trust Fund Recovery Penalty issues. Announcement 2011–6, 2011–4 I.R.B. 433, published January 24, 2011, partially superseded by Rev. Proc. 2014–63, 2014–53 I.R.B. 1014, extended the pilot without change through December 31, 2012.

APPEALS ARBITRATION PROGRAM

This revenue procedure obsoletes Rev. Proc. 2006–44 and eliminates the Appeals arbitration program. During the fourteen-year period in which arbitration was available, only two cases were settled using arbitration. Given the general lack of demand for arbitration and the fact that its use as a tool to settle disputes without

litigation has not proven successful, the IRS is eliminating the arbitration program. Although Appeals arbitration is being eliminated, taxpayers may be eligible to request mediation for unresolved issues that remain after completion of settlement discussions in Appeals. See Rev. Proc. 2014–63, 2014–53 I.R.B. 1014.

The elimination of the Appeals arbitration program is effective September 8, 2015.

DOCUMENTS

Revenue Procedure 2006–44, Announcement 2008–111, and Announcement 2011–6 are obsoleted.

DRAFTING INFORMATION

The principal authors of this revenue procedure are Alicia Goldstein, Office of Chief Counsel, Procedure and Administration, Charmaine Osbin, Office of Appeals, Tax Policy and Procedure for noncollection cases, and John Gonzalez, Office of Appeals, Tax Policy and Procedure for offer in compromise and Trust Fund Recovery Penalty cases. For further information regarding this revenue procedure, contact Ms. Goldstein at (202) 3173600, Ms. Osbin at (281) 721-7275, or Mr. Gonzalez at (415) 281-7837 (not tollfree calls).

September 21, 2015 354 Bulletin No. 2015–38

Announcement of Disciplinary Sanctions From the Office of Professional Responsibility

Announcement 2015–20

The Office of Professional Responsibility (OPR) announces recent disciplinary sanctions involving attorneys, certified public accountants, enrolled agents, enrolled actuaries, enrolled retirement plan agents, appraisers, and unenrolled/ unlicensed return preparers (individuals who are not enrolled to practice and are not licensed as attorneys or certified public accountants). Licensed or enrolled practitioners are subject to the regulations governing practice before the Internal Revenue Service (IRS), which are set out in Title 31, Code of Federal Regulations, Subtitle A, Part 10, and which are released as Treasury Department Circular No. 230. The regulations prescribe the duties and restrictions relating to such practice and prescribe the disciplinary sanctions for violating the regulations. Unenrolled/unlicensed return preparers are subject to Revenue Procedure 81–38 and superseding guidance in Revenue Procedure 2014–42, which govern a preparer’s eligibility to represent taxpayers before the IRS in examinations of tax returns the preparer both prepared for the taxpayer and signed as the preparer. Additionally, unenrolled/unlicensed return preparers who voluntarily participate in the Annual Filing Season Program under Revenue Procedure 2014–42 agree to be subject to the duties and restrictions in Circular 230, including the restrictions on incompetent or disreputable conduct.

The disciplinary sanctions to be imposed for violation of the applicable standards are:

Disbarred from practice before the IRS —An individual who is disbarred is not eligible to practice before the IRS as defined at 31 C.F.R. § 10.2(a)(4) for a minimum period of five (5) years.

Suspended from practice before the IRS —An individual who is suspended is not eligible to practice before the IRS as

defined at 31 C.F.R. § 10.2(a)(4) during the term of the suspension.

Censured in practice before the IRS —Censure is a public reprimand. Unlike disbarment or suspension, censure does not affect an individual’s eligibility to practice before the IRS, but OPR may subject the individual’s future practice rights to conditions designed to promote high standards of conduct.

Monetary penalty —A monetary penalty may be imposed on an individual who engages in conduct subject to sanction, or on an employer, firm, or entity if the individual was acting on its behalf and it knew, or reasonably should have known, of the individual’s conduct.

Disqualification of appraiser —An appraiser who is disqualified is barred from presenting evidence or testimony in any administrative proceeding before the Department of the Treasury or the IRS.

Ineligible for limited practice —An unenrolled/unlicensed return preparer who fails to comply with the requirements in Revenue Procedure 81–38 or to comply with Circular 230 as required by Revenue Procedure 2014–42may be determined ineligible to engage in limited practice as a representative of any taxpayer.

Under the regulations, individuals subject to Circular 230 may not assist, or accept assistance from, individuals who are suspended or disbarred with respect to matters constituting practice ( i.e ., representation) before the IRS, and they may not aid or abet suspended or disbarred individuals to practice before the IRS.

Disciplinary sanctions are described in these terms:

Disbarred by decision, Suspended by decision, Censured by decision, Mone- tary penalty imposed by decision, and Disqualified after hearing —An administrative law judge (ALJ) issued a decision imposing one of these sanctions after the ALJ either (1) granted the government’s summary judgment motion or (2) conducted an evidentiary hearing upon OPR’s complaint alleging violation of the regulations. After 30 days from the issuance of the decision, in the absence of an appeal, the ALJ’s decision becomes the final agency decision.

Disbarred by default decision, Sus- pended by default decision, Censured by default decision, Monetary penalty imposed by default decision, and Dis- qualified by default decision —An ALJ, after finding that no answer to OPR’s complaint was filed, granted OPR’s motion for a default judgment and issued a decision imposing one of these sanctions.

Disbarment by decision on appeal, Suspended by decision on appeal, Cen- sured by decision on appeal, Monetary penalty imposed by decision on appeal, and Disqualified by decision on ap- peal —The decision of the ALJ was appealed to the agency appeal authority, acting as the delegate of the Secretary of the Treasury, and the appeal authority issued a decision imposing one of these sanctions.

Disbarred by consent, Suspended by consent, Censured by consent, Mone- tary penalty imposed by consent, and Disqualified by consent —In lieu of a disciplinary proceeding being instituted or continued, an individual offered a consent to one of these sanctions and OPR accepted the offer. Typically, an offer of consent will provide for: suspension for an indefinite term; conditions that the individual must observe during the suspension; and the individual’s opportunity, after a stated number of months, to file with OPR a petition for reinstatement affirming compliance with the terms of the consent and affirming current fitness and eligibility to practice ( i.e ., an active professional license or active enrollment status, with no intervening violations of the regulations).

Suspended indefinitely by decision in expedited proceeding, Suspended indef- initely by default decision in expedited proceeding, Suspended by consent in expedited proceeding —OPR instituted an expedited proceeding for suspension (based on certain limited grounds, including loss of a professional license for cause, and criminal convictions).

Determined ineligible for limited practice —There has been a final determination that an unenrolled/unlicensed return preparer is not eligible for limited representation of any taxpayer because the preparer violated standards of conduct or

Bulletin No. 2015–38 355 September 21, 2015

failed to comply with any of the requirements to act as a representative.

OPR has authority to disclose the grounds for disciplinary sanctions in these situations: (1) an ALJ or the Secretary’s delegate on appeal has issued a final decision; (2) the individual has settled a disciplinary case by signing OPR’s “consent to sanction” agreement admitting to one

City & State Name

California

or more violations of the regulations and consenting to the disclosure of the admitted violations (for example, failure to file Federal income tax returns, lack of due diligence, conflict of interest, etc.); (3) OPR has issued a decision in an expedited proceeding for indefinite suspension; or (4) OPR has made a final determination (including any decision on appeal) that an

Professional

unenrolled/unlicensed return preparer is ineligible to represent any taxpayer before the IRS.

Announcements of disciplinary sanctions appear in the Internal Revenue Bulletin at the earliest practicable date. The sanctions announced below are alphabetized first by state and second by the last names of the sanctioned individuals.

Designation Disciplinary Sanction Effective Date(s)

San Diego Ewing, Anton A. CPA Suspended by decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Woodland Hills Huberman, Murray J. Enrolled Agent

Suspended by consent under 31 C.F.R. §§ 10.50 and 10.61(b)

Lompoc Martinez, Steven CPA Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Chino Hills Padilla, Dwight A. Enrolled Agent

Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Canyon Country Shroff, Vispi B. CPA Suspended by decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Connecticut

Woodbridge Gruenbaum, Jerry Attorney Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Wethersfield Ziro, Kenneth A. Enrolled Agent

Massachusetts

Suspended by decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Indefinite from May 5, 2015

Effective November 21, 2014

Indefinite from April 10, 2015

Indefinite from April 28, 2015

Indefinite from April 10, 2015

Indefinite from May 26, 2015

Indefinite from June 30, 2015

Indefinite from May 6, 2015

Indefinite from May 15, 2015

Indefinite from May 6, 2015

Indefinite from May 26, 2015

Indefinite from May 5, 2015

Gruenbaum, Jerry, see Connecticut

Framingham Tracia, Douglas F. Attorney Suspended by decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Missouri

Black Jack Burns, Joseph L. Enrolled Agent

Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

St. Louis Croft, Thomas C Attorney Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Saint Charles Witt, Jeffrey M. Attorney Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Kansas City Wirken, James C. Attorney Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

September 21, 2015 356 Bulletin No. 2015–38

City & State Name

New York

Professional

Designation Disciplinary Sanction Effective Date(s)

Bronxville McGraw, Kevin J. Attorney Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Nevada

Ely Hendrix, Bruce W. CPA Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

North Carolina

Indefinite from April 30, 2015

Indefinite from April 10, 2015

Summerfield Callaway, Jr., Paul F. Unenrolled Reinstated to practice Preparer before the IRS

April 8, 2015

Oregon

Beaverton Cyr, Steven M. Attorney Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Pennsylvania

Northampton Szerencsits, Jr, Joseph CPA Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Virginia

Falls Church O’Connor, Michael F. CPA Suspended by decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Fairfax Shin, Jenny Attorney Suspended by default decision in expedited proceeding under 31 C.F.R. § 10.82(b)

Indefinite from April 30, 2015

Indefinite from April 30, 2015

Indefinite from April 30, 2015

Indefinite from May 5, 2015

Bulletin No. 2015–38 357 September 21, 2015

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 published 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 confusion. It is not used where a position in a prior ruling is being changed.

Distinguished describes a situation where a ruling mentions a previously published 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

The following abbreviations in current use and formerly used will appear in ma- terial published in the Bulletin.

A —Individual. Acq. —Acquiescence. B —Individual. BE —Beneficiary. BK —Bank. B.T.A. —Board of Tax Appeals. C —Individual. C.B. —Cumulative Bulletin. CFR —Code of Federal Regulations. CI —City. COOP —Cooperative. Ct.D. —Court Decision. CY —County. D —Decedent. DC —Dummy Corporation. DE —Donee. Del. Order —Delegation Order. DISC —Domestic International Sales Corporation. DR —Donor. E —Estate. EE —Employee. E.O. —Executive Order. ER —Employer.

and B, the prior ruling is modified because it corrects a published position. (Compare with amplified and clarified, above).

Obsoleted describes a previously published ruling that is not considered determinative 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

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.

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 rulings in the series.

Suspended is used in rare situations to show that the previous published rulings will not be applied pending some future action such as the issuance of new or amended regulations, the outcome of cases in litigation, or the outcome of a Service study.

PTE —Prohibited Transaction Exemption. Pub. L. —Public Law. REIT —Real Estate Investment Trust. Rev. Proc. —Revenue Procedure. Rev. Rul. —Revenue Ruling. S —Subsidiary. S.P.R. —Statement of Procedural Rules. Stat. —Statutes at Large. T —Target Corporation. T.C. —Tax Court. T.D. —Treasury Decision. TFE —Transferee. TFR —Transferor. T.I.R. —Technical Information Release. TP —Taxpayer. TR —Trust. TT —Trustee. U.S.C. —United States Code. X —Corporation. Y —Corporation. Z —Corporation.

Bulletin No. 2015–38 i September 21, 2015

Numerical Finding List ¹

Bulletins 2015–27 through 2015–38

Announcements:

2015-17, 2015-28 I.R.B. 67 2015-18, 2015-33 I.R.B. 198 2015-19, 2015-32 I.R.B. 157 2015-20, 2015-38 I.R.B. 355 2015-21, 2015-34 I.R.B. 220 2015-22, 2015-35 I.R.B. 288 2015-23, 2015-36 I.R.B. 311 2015-24, 2015-36 I.R.B. 313

Notices:

2015-43, 2015-29 I.R.B. 73 2015-46, 2015-28 I.R.B. 64 2015-47, 2015-30 I.R.B. 76 2015-48, 2015-30 I.R.B. 77 2015-49, 2015-30 I.R.B. 79 2015-50, 2015-30 I.R.B. 81 2015-51, 2015-31 I.R.B. 133 2015-52, 2015-35 I.R.B. 227 2015-53, 2015-33 I.R.B. 190 2015-54, 2015-34 I.R.B. 210 2015-55, 2015-34 I.R.B. 217 2015-56, 2015-35 I.R.B. 235 2015-57, 2015-36 I.R.B. 294 2015-58, 2015-37 I.R.B. 322

Proposed Regulations:

REG-136459-09, 2015-37 I.R.B. 332 REG-109370-10, 2015-33 I.R.B. 198 REG-103033-11, 2015-37 I.R.B. 325 REG-109813-11, 2015-37 I.R.B. 330 REG-115452-14, 2015-32 I.R.B. 158 REG-132075-14, 2015-35 I.R.B. 288 REG-138526-14, 2015-28 I.R.B. 67 REG-143800-14, 2015-37 I.R.B. 347 REG-102648-15, 2015-31 I.R.B. 134 REG-102837-15, 2015-27 I.R.B. 43 REG-123640-15, 2015-37 I.R.B. 350

Revenue Procedures:

2015-34, 2015-27 I.R.B. 4 2015-36, 2015-27 I.R.B. 20 2015-38, 2015-36 I.R.B. 295 2015-39, 2015-33 I.R.B. 195 2015-40, 2015-35 I.R.B. 236 2015-41, 2015-35 I.R.B. 263 2015-42, 2015-36 I.R.B. 310 2015-44, 2015-38 I.R.B. 354

Revenue Rulings:

2015-15, 2015-27 I.R.B. 1 2015-16, 2015-31 I.R.B. 130 2015-18, 2015-34 I.R.B. 209 2015-19, 2015-36 I.R.B. 291 2015-20, 2015-38 I.R.B. 353

Treasury Decisions:

9723, 2015-31 I.R.B. 84 9726, 2015-31 I.R.B. 98 9727, 2015-32 I.R.B. 154 9728, 2015-33 I.R.B. 169 9729, 2015-35 I.R.B. 221 9730, 2015-35 I.R.B. 223 9731, 2015-37 I.R.B. 314 9735, 2015-37 I.R.B. 316

1A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2015–01 through 2015–26 is in Internal Revenue Bulletin 2015–26, dated June 29, 2015.

September 21, 2015 ii Bulletin No. 2015–38

Finding List of Current Actions on Previously Published Items ¹

Bulletins 2015–27 through 2015–38

Notices:

2014-4 Modified by Notice 2015-51, 2015-31 I.R.B. 133

Revenue Procedures:

1992-75 Clarified by Rev. Proc. 2015-40, 2015-35 I.R.B. 236

2003-40 Modified by Rev. Proc. 2015-40, 2015-35 I.R.B. 236

2006-9 Modified by Rev. Proc. 2015-41, 2015-35 I.R.B. 263

2006-9 Superseded by Rev. Proc. 2015-41, 2015-35 I.R.B. 263

2006-54 Modified by Rev. Proc. 2015-40, 2015-35 I.R.B. 236

2006-54 Superseded by Rev. Proc. 2015-40, 2015-35 I.R.B. 236

2008-31 Modified by Rev. Proc. 2015-41, 2015-35 I.R.B. 263

2008-31 Superseded by Rev. Proc. 2015-41, 2015-35 I.R.B. 263

2011-49 Modified by Rev. Proc. 2015-36, 2015-27 I.R.B. 20

2011-49 Superseded by Rev. Proc. 2015-36, 2015-27 I.R.B. 20

2015-14 Modified by Rev. Proc. 2015-39, 2015-33 I.R.B. 195

2015-40 Amplified by Rev. Proc. 2015-41, 2015-35 I.R.B. 263

2015-41 Amplified by Rev. Proc. 2015-40, 2015-35 I.R.B. 236

1A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2015–01 through 2015–26 is in Internal Revenue Bulletin 2015–26, dated June 29, 2015.

Bulletin No. 2015–38 iii September 21, 2015

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