This notice applies to taxpayers making gifts in trust during 2010. Under section 2511(c) of the Code, a transfer of property to a non-wholly owned grantor trust is a transfer by gift of the entire interest in the property. To determine whether a transfer to a wholly owned grantor trust constitutes a gift, the gift tax provisions in effect prior to 2010 apply.

This procedure updates Rev. Proc. 2008-14, 2008-1 C.B. 435, and identifies circumstances under which the disclosure on a taxpayer’s income tax return with respect to an item or a position is adequate for purposes of reducing the understatement of income tax under section 6662(d) of the Code (relating to the substantial understatement aspect of the accuracy-related penalty), and for the purpose of avoiding the tax return preparer penalty under section 6694(a) (relating to understatements due to unreasonable positions) with respect to income tax returns.

This document contains a correction to final regulations (T.D. 9443, 2009-8 I.R.B. 564) relating to postponement of certain tax-related deadlines either due to service in a combat zone or due to a federally declared disaster. The regulations reflect changes in the law made by the Victims of Terrorism Tax Relief Act of 2001, the Tax Extenders and Alternative Minimum Tax Relief Act of 2008 (TEAMTRA), and current IRS practice.

This announcement explains the potential content of a schedule that will require certain business taxpayers to report uncertain tax positions on their tax returns and invites public comments on the Internal Revenue Service’s approach.

This document contains a correction to (Announcement 2010-4, 2010-5 I.R.B. 384) regarding Deletions From Cumulative List of Organizations Contributions to Which are Deductible Under Section 170 of the Code.