Internal Revenue Bulletin 2022-25

Official source: Internal Revenue Bulletin (https://www.irs.gov/pub/irs-irbs/irb22-25.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.

Revocation of IRC Section 501(c)(3) organization for failure to meet the code section requirements. Contributions made to the organization by individual donors are no longer deductible under IRC Section 170(b)(1)(A).

Finding Lists begin on page ii.

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 Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases.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.

June 21, 2022 Bulletin No. 2022–25

The Following organization is no longer qualified as an organization exempt from income tax under Internal Revenue Code (the “Code”) Section 501(a) as an organization described in Section 501(c)(3) of the Code effective January 1, 2017:

ANAMBRA STATE ASSOCIATION OF NORTH CAROLINA 1405 GREEN EDGE TRAIL WAKE FOREST NC 27587

Employer ID number: 32-0261403.

June 21, 2022 1184 Bulletin No. 2022–25

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.

new ruling does more than restate the substance 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.

where a ruling mentions a previously pub- the 1986 Code and regulations the same Suspended is used in rare situations lished ruling and points out an essential position published under the 1939 Code to show that the previous published ruldifference between them. and regulations. The term is also used ings will not be applied pending some

Modified is used where the substance when it is desired to republish in a single future action such as the issuance of new of a previously published position is being ruling a series of situations, names, etc., or amended regulations, the outcome of changed. Thus, if a prior ruling held that a that were previously published over a cases in litigation, or the outcome of a principle applied to A but not to B, and the period of time in separate rulings. If the Service study.

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 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

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.

Bulletin No. 2022–25 i June 21, 2022

Numerical Finding List ¹

Bulletin 2022–25

Announcements:

2022-3, 2022-8 I.R.B. 788 2022-4, 2022-9 I.R.B. 789 2022-5, 2022-11 I.R.B. 825 2022-6, 2022-13 I.R.B. 934 2022-7, 2022-15 I.R.B. 946 2022-8, 2022-19 I.R.B. 1056 2022-9, 2022-22 I.R.B. 1153 2022-10, 2022-22 I.R.B. 1156 2022-11, 2022-24 I.R.B. 1183 2022-12, 2022-25 I.R.B. 1184

AOD:

2022-1, 2022-06 I.R.B. 466 2022-2, 2022-12 I.R.B. 903

Notices:

2022-1, 2022-02 I.R.B. 304 2022-2, 2022-02 I.R.B. 304 2022-3, 2022-02 I.R.B. 308 2022-4, 2022-02 I.R.B. 309 2022-5, 2022-05 I.R.B. 457 2022-6, 2022-05 I.R.B. 460 2022-7, 2022-06 I.R.B. 469 2022-8, 2022-07 I.R.B. 491 2022-9, 2022-10 I.R.B. 811 2022-10, 2022-10 I.R.B. 815 2022-12, 2022-12 I.R.B. 906 2022-11, 2022-14 I.R.B. 939 2022-13, 2022-14 I.R.B. 940 2022-14, 2022-14 I.R.B. 941 2022-15, 2022-18 I.R.B. 1043 2022-16, 2022-18 I.R.B. 1044 2022-17, 2022-18 I.R.B. 1048 2022-18, 2022-18 I.R.B. 1048 2022-19, 2022-18 I.R.B. 1050 2022-21, 2022-20 I.R.B. 1057 2022-22, 2022-20 I.R.B. 1057 2022-23, 2022-20 I.R.B. 1062 2022-20, 2022-21 I.R.B. 1095 2022-24, 2022-21 I.R.B. 1097 2022-27, 2022-22 I.R.B. 1151 2022-25, 2022-23 I.R.B. 1178 2022-28, 2022-28 I.R.B. 1182

Proposed Regulations:

REG-118250-20, 2022-07 I.R.B. 753 REG-105954-20, 2022-11 I.R.B. 828 REG-114209-21, 2022-11 I.R.B. 898 REG-114209-21, 2022-11 I.R.B. 898 REG-121508-18, 2022-15 I.R.B. 996 REG-114339-21, 2022-17 I.R.B. 1030 REG-106384-20, 2022-20 I.R.B. 1076

Proposed Regulations:—Continued

REG-118913-21, 2022-20 I.R.B. 1089 REG-122770-18, 2022-21 I.R.B. 1104

Revenue Procedures:

2022-1, 2022-01 I.R.B. 1 2022-2, 2022-01 I.R.B. 120 2022-3, 2022-01 I.R.B. 144 2022-4, 2022-01 I.R.B. 161 2022-5, 2022-01 I.R.B. 256 2022-7, 2022-01 I.R.B. 297 2022-9, 2022-02 I.R.B. 310 2022-11, 2022-03 I.R.B. 449 2022-8, 2022-04 I.R.B. 451 2022-10, 2022-06 I.R.B. 473 2022-13, 2022-06 I.R.B. 477 2022-12, 2022-07 I.R.B. 494 2022-14, 2022-07 I.R.B. 502 2022-15, 2022-13 I.R.B. 908 2022-17, 2022-13 I.R.B. 930 2022-17, 2022-13 I.R.B. 933 2022-20, 2022-14 I.R.B. 945 2022-21, 2022-16 I.R.B. 1015 2022-23, 2022-18 I.R.B. 1052 2022-24, 2022-20 I.R.B. 1075 2022-22, 2022-21 I.R.B. 1098

Revenue Rulings:

2022-1, 2022-02 I.R.B. 301 2022-2, 2022-04 I.R.B. 451 2022-3, 2022-06 I.R.B. 467 2022-4, 2022-10 I.R.B. 790 2022-5, 2022-10 I.R.B. 792 2022-6, 2022-12 I.R.B. 904 2022-7, 2022-14 I.R.B. 935 2022-8, 2022-14 I.R.B. 936 2022-9, 2022-18 I.R.B. 1041 2022-10, 2022-23 I.R.B. 1157 2022-11, 2022-23 I.R.B. 1159

Treasury Decisions:

9959, 2022-03 I.R.B. 328 9961, 2022-03 I.R.B. 430 9960, 2022-07 I.R.B. 481 9962, 2022-11 I.R.B. 823

1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin 2020–52, dated December 27, 2021.

June 21, 2022 ii Bulletin No. 2022–25

Finding List of Current Actions on Previously Published Items ¹

Bulletin 2022–25

1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin 2020–52, dated December 27, 2021.

Bulletin No. 2022–25 iii June 21, 2022

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