This revenue procedure provides guidance regarding the public approval requirement under § 147(f) of the Internal Revenue Code for tax-exempt qualified private activity bonds. Specifically, this revenue procedure provides that hearings held by teleconference as described in section 4 of this revenue procedure will be treated as held in a location that, based on the facts and circumstances, is convenient for residents of the approving governmental unit for the purpose of § 1.147(f)-1(d)(2) of the Income Tax Regulations.

26 CFR 601.601: Rules and Regulations.

(Also: §§ 147, 1.147(f)-1)

This ruling updates Rev. Rul. 2004-53 in accordance with the Taxpayer First Act by explaining that all recipients of returns or return information pursuant to section 6103(c), including government employees, are subject to the disclosure restrictions of section 6103(a). Rev. Rul. 2004-53 modified and superseded.

26 CFR 301.6103: Confidentiality of returns.

Notice 2022-13 provides a waiver of the addition to tax under section 6654 for underpayment of estimated income tax by qualifying farmers and fishermen described in the notice. Under the notice, the addition to tax is waived for farmers and fishermen who, by April 18, 2022, or, for those taxpayers who reside in Maine or Massachusetts, by April 19, 2022, file their 2021 federal income tax return and pay in full any tax reported as due on the return.

This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for March 2022 used under § 417(e)(3)(D), the 24-month average segment rates applicable for March 2022, and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).

The notice provides an indexing factor for the qualifying payment amount for items and services furnished in 2022 for purposes of sections 9816 and 9817 of the Internal Revenue Code, as added by the No Surprise Act, in the case of a group health plan or group or individual health insurance issuer that does not have sufficient information as of January 31, 2019 to calculate the median of the contracted rates or for new items and services.

26 CFR 54.9816-6T Methodology for calculating qualifying payment amount in 2022

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 April 2022.

(Also Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.)

Whether Federal, State, and local government officers or employees (government employees) are subject to the disclosure restrictions of section 6103(a) of the Internal Revenue Code (Code) with regard to returns or return information received as a result of disclosure under:

Situation 1. A requests the assistance of a friend, B, with respect to a Federal tax matter. A also requests that the Internal Revenue Service (IRS) provide A’s returns and return information to B. B subsequently discloses to a third party return information obtained as a result of A’s request.

Situation 2. Same as Situation 1, above, except that B happens to be an employee in the office of a State agency.

Situation 3. C is an attorney employed by a law firm. The firm has a policy of taking disciplinary action against any of its attorneys who do not properly fulfill their tax obligations. The IRS serves a notice of levy with respect to C’s tax liability on the payroll department of the firm. D is a payroll department employee of the firm. D processes the notice of levy and informs the firm’s managing partners of C’s tax delinquency to enable the firm to take appropriate action consistent with firm policy.

Situation 4. E is an employee of a State agency. The agency has a policy of taking disciplinary action against employees who do not properly fulfill their tax obligations. The IRS serves a notice of levy with respect to E’s tax liability on the payroll department of the State agency. F is a payroll department employee of the State agency. F processes the notice of levy and informs the appropriate office of the State agency of E’s tax delinquency to enable the agency to take appropriate action consistent with agency policy.

Situation 5. Same as Situation 4, above, except that E and F are employees of a Federal agency.

Situation 6. G is the father of 5-year-old film star H. H’s mother signs H’s return as parent for a minor child and dies shortly thereafter. G is the guardian of H’s estate under applicable State law. G receives notice that H’s return is under examination by the IRS. G does not have a copy of H’s return, so G obtains the return and return information from the IRS. When subsequently asked by a news reporter how much income H reported on the return, G replies “three million dollars.”

Situation 7. Same as Situation 6, above, except that G happens to be an employee of a Federal agency.

Generally, section 6103 provides that returns (as defined in section 6103(b)(1)) and return information (as defined in section 6103(b)(2)) are confidential and may not be disclosed except as expressly authorized by the Code. Specifically, “except as authorized by this title” (that is, the Code), section 6103(a) prohibits the disclosure by officers or employees of the United States, of any State, or of specified local government agencies, or by certain other specified persons, of returns and return information obtained in connection with their service as such an officer or employee or otherwise or under the provisions of section 6103 (disclosure restrictions). See Girard v. Bentsen, 94-2 U.S.T.C. ¶ 50,625 (N.D. Cal. 1994) (“or otherwise” modifies “in connection with his service,” allowing the statute to cover those who are neither “officers” nor “employees,” namely certain other persons specified in section 6103(a)). For purposes of section 6103(a), the term “officer or employee” includes a former officer or employee.

There are, however, exceptions to the general rule of confidentiality. First, the taxpayer consent exception permits the disclosure of returns and return information to a designee of the taxpayer, pursuant to the taxpayer’s request or consent. To be valid, a consent must satisfy the requirements of section 6103(c) and § 301.6103(c)-1 of the Procedure and Administration Regulations. Second, the material interest exception permits the disclosure of returns and return information to specific persons with a material interest in the information. Third, the investigative disclosure exception, in conjunction with § 301.6103(k)(6)-1, authorizes the disclosure of return information (but not returns) to the extent that disclosure is necessary in obtaining information that is not otherwise reasonably available with respect to the correct determination of tax, liability for tax, or the amount to be collected, or with respect to the enforcement of any other provision of the Code.

Rev. Rul. 2004-53, 2004-1 C.B. 1026 (June 7, 2004) clarified the scope of section 6103(a) with respect to government employees and held that government employees who receive returns or return information pursuant to section 6103(c), (e), or (k)(6) are not subject to the disclosure restrictions of section 6103(a). Although not addressed by Rev. Rul. 2004-53, any shareholder of a corporation permitted to inspect or receive return information of the corporation or its subsidiaries under section 6103(e)(1)(D)(iii) is subject to the disclosure restrictions imposed by section 6103(a).

Section 2202 of the Taxpayer First Act (TFA), Public Law 116-25, 133 Stat. 981, 1012 (2019), amended section 6103(a)(3) and (c) to limit redisclosures and uses of return information received pursuant to the taxpayer consent exception. Section 6103(c), as amended by the TFA, explicitly prohibits designees from using return information for any reason other than the express purpose for which the taxpayer grants consent and from redisclosing return information without the taxpayer’s express permission or request. Section 6103(a)(3), as amended by the TFA, imposes disclosure restrictions on all recipients of return information under 6103(c). The TFA did not amend section 6103(e) or (k)(6), or section 6103(a) with respect to disclosures under section 6103(e) or (k)(6).

Under section 6103(c), as amended, the restrictions on redisclosure of returns or return information received pursuant to the taxpayer consent exception apply to all designees, including government employees. Therefore, in Situations 1 and 2, B is prohibited from redisclosing A’s return information, because A did not authorize B to further disclose A’s return information.

After the TFA, the analysis of the scope of disclosures under section 6103(e) and (k)(6) is materially unchanged from that in Rev. Rul. 2004-53. Section 6103(e) and (k)(6) contains no limitation or restriction on the redisclosure of returns or return information received pursuant to the material interest or investigative disclosure exceptions. Therefore, in Situations 3 and 6 there are no statutory or regulatory restrictions on the redisclosures of return information made by D or G.

In Situations 4, 5, and 7, however, the prohibition in section 6103(a) on redisclosure of returns or return information by government employees could be read to prohibit such redisclosures by F and G because they happen to be government employees. This reading would create a disparity in the application of section 6103(a) based on who the employer of the person receiving the disclosure of returns or return information happens to be.

By its terms, section 6103(a) does not regulate or control the use of returns and return information received under the material interest or investigative disclosure exceptions. Moreover, the requirements for accountings and safeguards that typically apply where redisclosure of returns or return information is limited do not apply to these exceptions.

There is no evidence that Congress intended to limit the redisclosure of return information received by government employees under section 6103(e) and (k)(6) merely because they happen to be government employees. On the contrary, there are compelling reasons for those government employees to be subject to the same rules as other recipients. For example, a private sector employer may take disciplinary action against employees who do not properly fulfill their tax obligations. If redisclosure of return information is not permitted because the employer happens to be the Federal government, the Federal employees who failed to fulfill their tax obligations would be in a significantly better position than their private sector counterparts. This inappropriate result only occurs if section 6103(a) is read to apply to individuals merely because they happen to be government employees.

Accordingly, persons are not barred because of their status as government employees from redisclosing returns and return information received pursuant to section 6103(e) or (k)(6). Therefore, in Situations 4, 5, and 7, there are no statutory or regulatory restrictions on the redisclosures of return information made by F or G.

Government employees who receive returns or return information pursuant to disclosures under section 6103(c), like all designees who receive returns or return information pursuant to taxpayer consent, are subject to the disclosure restrictions of section 6103(a). Government employees who receive returns or return information pursuant to disclosures under section 6103(k)(6) or (e), other than section 6103(e)(1)(D)(iii) (relating to certain shareholders), are not subject to the disclosure restrictions of section 6103(a) with regard to the returns or return information received.

Rev. Rul. 2004-53 is modified and superseded.

The principal author of this revenue ruling is Andrew C. Keaton of the Office of the Associate Chief Counsel (Procedure & Administration). For further information regarding this revenue ruling, contact Mr. Keaton at (202) 317-5404 (not a toll-free number).

This revenue ruling provides various prescribed rates for federal income tax purposes for April 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 applicable 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-income housing credit described in section 42(b)(1) for buildings placed in service during the current month. However, 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%. 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.

The applicable federal short-term, mid-term, and long-term rates are set forth for the month of April 2022. See Rev. Rul. 2022-8, page 936.

The applicable federal short-term, mid-term, and long-term rates are set forth for the month of April 2022. See Rev. Rul. 2022-8 page 936.

The adjusted applicable federal long-term rate is set forth for the month of April 2022. See Rev. Rul. 2022-8, page 936.

The applicable federal short-term, mid-term, and long-term rates are set forth for the month of April 2022. See Rev. Rul. 2022-8, page 936.

The applicable federal short-term rates are set forth for the month of April 2022. See Rev. Rul. 2022-8, page 936.

The applicable federal short-term, mid-term, and long-term rates are set forth for the month of April 2022. See Rev. Rul. 2022-8, page 936.

The applicable federal short-term, mid-term, and long-term rates are set forth for the month of April 2022. See Rev. Rul. 2022-8, page 936.

The adjusted applicable federal short-term, mid-term, and long-term rates are set forth for the month of April 2022. See Rev. Rul. 2022-8, page 936.

The applicable federal mid-term rates are set forth for the month of April 2022. See Rev. Rul. 2022-8, page 936.

The applicable federal short-term, mid-term, and long-term rates are set forth for the month of April 2022. See Rev. Rul. 2022-8, page 936.

This notice provides guidance for calculating the qualifying payment amount for items and services furnished in 2022 for purposes of sections 9816 and 9817 of the Internal Revenue Code (Code), sections 716 and 717 of the Employee Retirement Income Security Act of 1974 (ERISA), and sections 2799A-1 and 2799A-2 of the Public Health Service Act (PHS Act) in the case of a group health plan or group or individual health insurance issuer that does not have sufficient information to calculate the median of the contracted rates in 2019 (including for items and services not offered in 2019). This notice was drafted in consultation with the Departments of Labor and Health and Human Services.

Under Treas. Reg. § 54.9816-6T(c), 29 CFR 2590.716-6(c), and 45 CFR 149.140(c),¹ for an item or service furnished during 2022, a group health plan or group or individual health insurance issuer² must calculate the qualifying payment amount by increasing the median contracted rate (as determined in accordance with § 54.9816-6T(b), 29 CFR 2590.716-6(b), and 45 CFR 149.140(b)) for the same or similar item or service under such plan or coverage, on January 31, 2019, by the combined percentage increase as published by the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) to reflect the percentage increase in the consumer price index for all urban consumers (U.S. city average) (CPI-U) over 2019, such percentage increase over 2020, and such percentage increase over 2021. Per Rev. Proc. 2022-11, 2022-3 IRB 449, for items and services provided on or after January 1, 2022, and before January 1, 2023, the combined percentage increase to adjust the median contracted rate is 1.0648523983.

Pursuant to § 54.9816-6T(c)(3)(i), 29 CFR 2590.716-6(c)(3)(i), and 45 CFR 149.140(c)(3)(i), for an item or service furnished during 2022, a plan or issuer that does not have sufficient information to calculate the median of the contracted rates in 2019 for the same or similar item or service provided in a geographic region must calculate the qualifying payment amount by first identifying the rate that is equal to the median of the in-network allowed amounts for the same or similar item or service provided in the geographic region in 2021, determined by the plan or issuer through use of any eligible database, and then increasing that rate by the percentage increase in the CPI-U over 2021. Similarly, in the case of a newly covered item or service furnished during the first coverage year, when a plan or issuer does not have sufficient information to calculate the median of the contracted rates in the first coverage year for the item or service, the plan or issuer must calculate the qualifying payment amount by using an eligible database to determine the rate that is equal to the median of the in-network allowed amounts for the same or similar item or service provided in the geographic region in the year immediately preceding the first coverage year, and then increasing that rate by the percentage increase in the CPI-U over the preceding year.³

Under § 54.9816-6T(c)(3)(ii), 29 CFR 2590.716-6(c)(3)(ii), and 45 CFR 149.140(c)(3)(ii), for an item or service furnished in a subsequent year (before the first sufficient information year for the item or service with respect to the plan or coverage), the plan or issuer must calculate the qualifying payment amount by increasing the qualifying payment amount determined for the item or service for the year immediately preceding the subsequent year, by the percentage increase in the CPI-U over the preceding year.

The percentage increase in the CPI-U over a preceding year is calculated by dividing the average CPI-U for the preceding year by the average CPI-U for the year immediately prior to the preceding year. For this purpose, the average CPI-U for a year is the average of the monthly CPI-Us published by the Bureau of Labor Statistics of the Department of Labor for the 12-month period ending on August 31 of each year. The percentage increase in the CPI-U for items and services provided in 2022 over the preceding year is the average CPI-U for 2021 over the average CPI-U for 2020. Pursuant to this calculation, the percentage increase from 2021 to 2022 is 1.0299772040.

Therefore, for an item or service furnished in 2022 for which a plan or issuer does not have sufficient information to calculate the median of the contracted rates in 2019, the plan or issuer must calculate the qualifying payment amount by multiplying the median of the in-network allowed amounts for the same or similar item or service provided in the geographic region in 2021, drawn from any eligible database, by the percentage increase of 1.0299772040. Similarly, in the case of a newly covered item or service furnished in 2022, when 2022 is the first coverage year for the item or service with respect to the plan or coverage, the plan or issuer must calculate the qualifying payment amount by multiplying the median of the in-network allowed amounts for the same or similar item or service provided in the geographic region in 2021, drawn from any eligible database, by the percentage increase of 1.0299772040. Pursuant to this notice, plans and issuers may round any resulting qualifying payment amount to the nearest dollar.

The Treasury Department and the IRS anticipate issuing additional guidance regarding the calculation of the qualifying payment amount in these circumstances for subsequent years.

The effective date of this notice is January 1, 2022.

The principal author of this notice is Kari DiCecco of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes). For further information regarding this notice, contact Kari DiCecco at 202-317-5500 (not a toll-free number).

¹ These interim final rules were issued in July 2021 to implement sections 9816 and 9817 of the Code, sections 716 and 717 of ERISA, and sections 2799A-1 and 2799A-2 of the PHS Act. 86 FR 36872 (7/13/21).

² 5 CFR 890.114(b) provides that, for purposes of the No Surprises Act, “group health plan” means “a health benefits plan” offered by carriers under the Federal Employees Health Benefits (FEHB) Act. Accordingly, the guidance provided in this notice also applies to FEHB carriers. See 5 U.S.C. 8901(p).

³ In cases in which an eligible database is used to determine the qualifying payment amount with respect to an item or service furnished during a calendar year, the plan or issuer must use the same database for determining the qualifying payment amount for that item or service through the last day of the calendar year, and if a different database is selected for some items or services, the basis for that selection must be one or more factors not directly related to the rate of those items or services (such as sufficiency of data for those items or services).

This notice provides a waiver of the addition to tax under section 6654 of the Internal Revenue Code (Code) for underpayment of estimated income tax by qualifying farmers and fishermen described in this notice.

Generally, the Code requires taxpayers to pay federal income taxes as they earn income. To the extent these taxes are not withheld from wages or other sources, a taxpayer must pay estimated income tax on a quarterly basis.

Section 6654 provides that, in the case of an individual taxpayer, estimated income tax is required to be paid in four installments, each of which is 25 percent of the required annual payment. With some exceptions, section 6654(l)(2) provides that the provisions of section 6654 generally apply to certain trusts and estates.

An individual taxpayer who fails to make a sufficient and timely payment of estimated income tax generally is liable for an addition to tax under section 6654(a). However, special rules may apply in the case of an individual taxpayer who is a farmer or fisherman and satisfies the requirements of section 6654(i) for a taxable year (qualifying farmer or fisherman). Under section 6654(i)(1), a qualifying farmer or fisherman has only one required installment payment instead of four quarterly payments due on January 15 of the year following the taxable year if at least two-thirds of the taxpayer’s total gross income was from farming or fishing in either the taxable year or the preceding taxable year. For a qualifying farmer or fisherman who does not make the required estimated tax installment payment by January 15 of the year following the taxable year, section 6654(i)(1)(D) provides that the taxpayer is not subject to an addition to tax for failing to pay estimated income tax if the taxpayer files the return for the taxable year and pays the full amount of tax reported on the return by March 1 of the year following the taxable year.

The Secretary of the Treasury or her delegate is authorized under section 6654(e)(3)(A) to waive the section 6654 addition to tax for an underpayment of estimated tax in unusual circumstances to the extent its imposition would be against equity and good conscience.

The Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) understand that, for the 2021 taxable year, some qualifying farmers and fishermen have been unable to electronically file Form 7203, S Corporation Shareholder Stock and Debt Basis Limitations, which may be required to be included in their federal income tax returns for taxable year 2021 (2021 tax returns). Due to this inability, farmers and fishermen may have had difficulty filing their 2021 tax returns electronically by the March 1, 2022, due date provided by section 6654(i)(1). Accordingly, the Treasury Department and the IRS have determined it is appropriate to waive certain penalties for qualifying farmers and fishermen due to these unusual circumstances if the requirements set forth in section 3 of this notice are satisfied.

Under the authority granted by section 6654(e)(3)(A), the addition to tax under section 6654 for failure to make an estimated tax payment for the 2021 taxable year is waived for any qualifying farmer or fisherman who files a 2021 tax return and pays in full any tax due on the return by April 18, 2022, or, for those taxpayers who live in Maine or Massachusetts, by April 19, 2022. The waiver will apply to any taxpayer who is a qualifying farmer or fisherman for the 2021 taxable year and fulfills the conditions stated in the previous sentence.

The waiver will apply automatically to any taxpayer who qualifies for the waiver and does not report an addition to tax under section 6654 on the 2021 tax return. Taxpayers who otherwise satisfy the criteria for relief under this notice, but already filed a return and reported an addition to tax under section 6654, may request an abatement of the addition to tax by filing Form 843, Claim for Refund and Request for Abatement, in accordance with the Instructions for Form 843 and as follows:

The principal author of this notice is Alexander Wu of the Office of the Associate Chief Counsel (Procedure and Administration). For further information, please contact Mr. Wu at (202) 317-6845 (not a toll-free number).

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 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).

This revenue procedure provides guidance regarding the public approval requirement under § 147(f) of the Internal Revenue Code for tax-exempt qualified private activity bonds. Specifically, this revenue procedure provides that hearings held by teleconference as described in section 4 of this revenue procedure will be treated as held in a location that, based on the facts and circumstances, is convenient for residents of the approving governmental unit for the purpose of § 1.147(f)-1(d)(2) of the Income Tax Regulations.

.01 Pursuant to § 147(f), tax-exempt qualified private activity bonds are subject to a public approval requirement. Except for refunding bonds described in § 147(f)(2)(D), a bond issue must be approved by the governmental unit issuing the bonds (or on behalf of which such bonds are issued) and by the governmental unit having jurisdiction over the area in which any facility to be financed by the issue is located. Under § 147(f)(2)(B), an issue will be treated as having been approved by any governmental unit if the issue is approved by the applicable elected representative of the governmental unit after a public hearing following reasonable public notice, or by voter referendum of the governmental unit.

.02 Section 1.147(f)-1(d)(1) provides that “public hearing” means a forum providing a reasonable opportunity for interested individuals to express their views, orally or in writing, on the proposed issue of bonds and the location and nature of the proposed project to be financed. Section 1.147(f)-1(d)(2) provides that the public hearing must be held in a location that, based on the facts and circumstances, is convenient for residents of the approving governmental unit. The location is presumed convenient for residents of the approving governmental unit if the public hearing is located in the approving governmental unit’s capital or seat of government. Further, if more than one governmental unit is required to hold a public hearing, the hearings may be combined as long as the combined hearing affords the residents of all of the participating governmental units a reasonable opportunity to be heard. The location of any combined hearing is presumed convenient for residents of each participating governmental unit if it is no farther than 100 miles from the seat of government of each participating governmental unit beyond whose geographic jurisdiction the hearing is conducted.

.03 In light of the Coronavirus Disease 2019 (COVID-19) pandemic, state and local governmental units sought alternatives to in-person hearings held to meet the public approval requirement. In response to these concerns, Rev. Proc. 2020-21, 2020-22 I.R.B. 872, provides temporary guidance regarding the public approval requirement under § 147(f). Rev. Proc. 2020-21 provides that for the period beginning May 4, 2020, and ending on December 31, 2020 (time period limitation), hearings held by teleconference that are accessible to the residents of the approving governmental unit by calling a toll-free telephone number will be treated as held in a location that, based on the facts and circumstances, is convenient for residents of the approving governmental unit for purposes of § 1.147(f)-1(d)(2). Rev. Proc. 2020-49, 2020-48 I.R.B. 1121, modified section 4.02 of Rev. Proc. 2020-21 by extending the time period limitation until September 30, 2021, and the time period limitation was further extended until March 31, 2022, by Rev. Proc. 2021-39, 2021-38 I.R.B. 426, modifying sec. 4.02 of Rev. Proc. 2020-21, and modifying and superseding Rev. Proc. 2020-49.

.04 The Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) have received requests to permanently allow public hearings for qualified private activity bonds to be held telephonically. In the past, the Treasury Department and the IRS rejected suggestions that an effective public hearing for qualified private activity bonds may be held by teleconference or webinar. See TD 9845 (83 FR 67687 (Dec. 31, 2018)). The experience using telephonic hearings during the COVID-19 pandemic has shown that telephonic access has in fact made it easier for the public to express its views regarding a proposed private activity bond issue and thus furthers the purpose of the public approval requirement in § 147(f). Accordingly, this revenue procedure provides the requested guidance by eliminating the time period limitation on holding public hearings telephonically.

This revenue procedure applies to hearings held telephonically for the purpose of satisfying the public approval requirement under § 147(f).

A hearing that is held by teleconference accessible to the residents of the approving governmental unit by calling a toll-free telephone number will be treated as held in a location that, based on the facts and circumstances, is convenient for residents of the approving governmental unit for the purpose of § 1.147(f)-1(d)(2). Provided the requirements of the preceding sentence are satisfied, governmental units are not precluded from offering additional access to the hearing by other telephone numbers, internet-based meeting technology, or in-person attendance.

This revenue procedure modifies and supersedes Rev. Proc. 2020-21 and Rev. Proc. 2021-39.

This revenue procedure applies to public hearings held on or after March 18, 2022.

The principal authors of this revenue procedure are Johanna Som de Cerff and David White of the Office of Associate Chief Counsel (Financial Institutions & Products). For further information regarding this revenue procedure, contact Ms. Som de Cerff or Mr. White on (202) 317-6980 (not a toll-free number).