How do I verify this is the current guidance?

Check for later IRS actions that amend, supersede, or withdraw guidance. If uncertainty exists, note reliance limitations and verify whether a later Revenue Procedure, Notice, or Treasury regulation modifies the Bulletin text.

Can a taxpayer rely on a Private Letter Ruling citation?

Private Letter Rulings bind only the requesting taxpayer and generally cannot be cited as precedent for unrelated taxpayers; use publicly issued items (e.g., an IRB or Revenue Ruling) for broad reliance.

What if the Bulletin conflicts with later guidance?

Later IRS publications, regulations, or court decisions can supersede earlier Bulletins. Document the date you checked and any subsequent IRS action in your workpapers.

Do Bulletins impose filing fees or penalties?

The Bulletin itself does not create filing fees; penalties arise from incorrect filings that fail to follow applicable IRS rules. Cite specific statutes or penalty provisions when advising clients.

When is a Bulletin treated as authoritative?

IRBs publish official IRS positions and administrative items; their authoritative weight depends on the type (e.g., Revenue Ruling vs. Announcement) and whether subsequent guidance confirms the position.

How should I store Bulletin citations?

Keep the Bulletin PDF or official text in your document repository, record the exact citation, and include it in client memoranda to support any positions taken.

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Internal Revenue Bulletin 2011-39

Internal Revenue Bulletin 2011-39

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What the Internal Revenue Bulletin 2011-39 Is and why it matters

Internal Revenue Bulletin 2011-39 is an official IRS publication that collects rulings, procedures, notices, and other administrative guidance issued for public distribution. The Bulletin serves as the IRS’s mechanism to publish formal guidance and announcements that affect tax administration, filing procedures, and taxpayer compliance. Readers consult an IRB entry to confirm the text of a ruling or notice, to identify effective dates and transition relief, and to determine whether a particular IRS position or administrative instruction applies to their facts and tax reporting obligations.

Why IRB 2011-39 is a useful reference for practitioners

IRB 2011-39 publishes authoritative IRS positions and administrative details that can affect filing obligations, timing, and taxpayer compliance. It helps practitioners confirm official language, effective dates, and any transitional relief announced by the IRS.

Who typically consults this Bulletin and how they use it

Tax professionals, corporate tax teams, payroll administrators, and attorneys use IRB entries to verify IRS guidance language, effective dates, and compliance instructions.

Tax advisors and CPAs who need source text and effective dates for advice and client filings.
Payroll and HR teams checking withholding, reporting, or procedural updates that affect W-2 or 1099 processing.
In-house counsel and compliance officers validating administrative procedures or transitional relief for corporate filings.

Using the Bulletin as a primary source avoids reliance on secondary summaries and helps document the authoritative IRS text relied upon in advice or filings.

How to consult and apply IRB 2011-39 in four steps

Follow this concise sequence to locate the Bulletin text, confirm its scope, and apply it to tax reporting or advice.

01

Locate text: Find the Bulletin entry and read the full language of the ruling or notice.
02

Confirm scope: Identify which taxpayers, periods, or transactions are covered by the entry.
03

Check effective date: Note effective and applicability dates and any transitional relief.
04

Document reliance: Record the Bulletin citation and include it in the workpapers or client memo.

Common questions about using IRB 2011-39

Answers to frequent issues when locating, interpreting, or relying on an IRS Bulletin entry.

Need help? Contact support

How do I verify this is the current guidance?
Check for later IRS actions that amend, supersede, or withdraw guidance. If uncertainty exists, note reliance limitations and verify whether a later Revenue Procedure, Notice, or Treasury regulation modifies the Bulletin text.
Can a taxpayer rely on a Private Letter Ruling citation?
Private Letter Rulings bind only the requesting taxpayer and generally cannot be cited as precedent for unrelated taxpayers; use publicly issued items (e.g., an IRB or Revenue Ruling) for broad reliance.
What if the Bulletin conflicts with later guidance?
Later IRS publications, regulations, or court decisions can supersede earlier Bulletins. Document the date you checked and any subsequent IRS action in your workpapers.
Do Bulletins impose filing fees or penalties?
The Bulletin itself does not create filing fees; penalties arise from incorrect filings that fail to follow applicable IRS rules. Cite specific statutes or penalty provisions when advising clients.
When is a Bulletin treated as authoritative?
IRBs publish official IRS positions and administrative items; their authoritative weight depends on the type (e.g., Revenue Ruling vs. Announcement) and whether subsequent guidance confirms the position.
How should I store Bulletin citations?
Keep the Bulletin PDF or official text in your document repository, record the exact citation, and include it in client memoranda to support any positions taken.

Essential administrative and security details to track

Document title: Internal Revenue Bulletin 2011-39

Publication type: IRS bulletin entry

Effective date: Date specified in the Bulletin

Storage format: PDF or archived text

Access control: Restricted to authorized staff

Audit logging: Record retrieval and citation actions

Principal risks from misreading or misapplying Bulletin guidance

Late information returns: Penalties $60–$330 per form (IRC §6721)

Intentional disregard: Penalty $660+ per form (IRC §6721)

I-9 paperwork errors: Violations $281–$2,789 per item (8 CFR)

HIPAA disclosure mistakes: Minimum 6-year retention obligation (45 CFR §164.530(j))

Reliance on outdated text: Potential incorrect tax positions

Improper citation: Weakens audit defense

Common preparation and interpretation pitfalls

Relying on an IRB excerpt without checking for later amendments or superseding rules can lead to incorrect filing positions and potential penalties.
Failing to record the exact Bulletin citation and effective date in client files makes it difficult to show contemporaneous reliance during audits or disputes.
Assuming a Private Letter Ruling cited in a Bulletin is precedent for other taxpayers when PLRs are limited to the requesting taxpayer.
Using a summary or secondary commentary instead of the primary Bulletin text risks missing qualifying language, exceptions, or transitional relief.

What to look for inside the Bulletin entry

IRB entries commonly include a title, the full text of the ruling or notice, effective date, citation information, cross-references, and any transitional or retroactive relief.

Title

Official heading that identifies the subject matter and provides the primary citation string for the entry.

Full text

Complete language of the ruling, notice, or announcement; always rely on this text rather than summaries.

Effective date

Date when the guidance takes effect and which tax years or periods are impacted.

Cross-references

Links to related revenue rulings, procedures, or notices providing administrative context or follow-up actions.

Transitional relief

Any temporary exceptions, safe harbors, or phased compliance schedules stated in the entry.

Citation

Formal reference string used in memoranda and workpapers to document reliance on the Bulletin.

Typical workflow when applying Bulletin guidance to a client issue

Use a consistent workflow to confirm applicability and to document your reliance on the Bulletin for tax positions or client advice.

Identify issue: Map client facts to topics covered in the Bulletin entry.
Locate entry: Retrieve the full IRB text and read qualifying language.
Assess impact: Determine affected returns, reporting, and potential relief.
Document action: Record citation, effective date, and recommended treatment in workpapers.

Recommended internal steps to integrate IRB guidance into workflow

A simple configuration table helps tax teams ensure consistent handling and traceability when Bulletin guidance affects filings.

Field	Configuration
Source	Store official PDF in document repository
Reviewer	Assign tax lead or counsel review
Retention	Keep citation in client workpapers for retention period
Notification	Alert affected client teams and update procedures

How an IRB entry differs from other IRS publications

A concise comparison helps you understand relative authority, public availability, and reliance implications for different IRS-issued documents.

Criteria	IRB entry	Private Letter Ruling
Public access
Binding on others	generally yes for published rulings
Typical use	broad guidance and announcements	taxpayer-specific advice
Citation for reliance	permitted in memoranda	limited to requesting taxpayer

Representative eSignature vendor pricing and feature snapshot

When you need to sign, archive, or share IRS documents or memos, compare vendor pricing and basic feature availability to match compliance needs.

	signNow	DocuSign	Adobe Sign	PandaDoc	HelloSign
Starting Price	$8/user/mo	$15/user/mo	$14/user/mo	$19/user/mo	$15/user/mo
Free Trial	7-day trial	Varies	Varies	Varies	Varies
Bulk Send	Yes	Yes	Yes	Yes	Varies
Audit Trail	Yes	Yes	Yes	Yes	Yes
HIPAA Compliant	Yes	Yes	Yes	No	No

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