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.

This revenue procedure provides a safe harbor method of accounting that taxpayers may use to determine whether expenses to repair, maintain, replace, or improve natural gas transmission and distribution property must be capitalized. To apply this safe harbor method, a taxpayer must first classify its natural gas transmission and distribution property as either linear property (for example, pipe, fittings, and valves) or non-linear property (for example, compressors, regulators, and meters). This revenue procedure then provides methods of accounting for each type of property, specifically, a safe harbor method used for the taxpayer’s linear transmission and distribution property and an optional safe harbor method that the taxpayer may choose to use for its non-linear transmission and distribution property. The revenue procedure also provides procedures for obtaining automatic consent to change to the safe harbor method for linear property and the safe harbor method for non-linear property.

26 CFR 1.263(a)-3: Amounts paid to improve tangible property.

(Also Part I, §§ 162, 165, 167, 168, 263(a), 263A, and 446; 1.165-7(a)(2), 1.167(a)-11, 1.168(i)-1, 1.446-1.)

This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2023 used under § 417(e)(3)(D), the 24-month average segment rates applicable for April 2023, and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).

This revenue ruling obsoletes Revenue Ruling 58-74, 1958-1 C.B. 148, relating to the deductibility of research or experimental expenditures for prior taxable years to which the expense method is applicable, because there are insufficient facts in Revenue Ruling 58-74 to properly analyze whether the taxpayer’s failure to deduct certain research or experimental expenditures, when it deducted other research or experimental expenditures, constituted a method of accounting or an error.

26 CFR 1.174-1: Research and experimental expenditures; in general.

(Also §§ 446, 7805(b)(8); 1.174-3, 1.446-1, 301.7805-1).