SECTION 4. PROCEDURE

The Internal Revenue Service will not challenge a corporate taxpayer’s treatment of grant amounts received by the corporation under any TIGER Discretionary Grants for capital investments in surface transportation infrastructure as a nonshareholder contribution to the capital of the corporation under § 118(a) if the cor

poration properly reduces the basis of its property under § 362(c)(2) and the regulations thereunder. For purposes of this revenue procedure, TIGER Discretionary Grants include those TIGER Discretionary Grants authorized in each year following those described in Rev. Proc. 2010–46 as well as any to be authorized in the future.