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Internal Revenue Bulletin 2011-39

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Freedom of Access to Reproductive Health Services Intimidation or Injury of a Person

18 USC § 248(a)(1)

Title 18, United States Code, Section 248(a)(1), makes it a Federal crime or offense for anyone by using to intentionally a person reproductive health services.

The Defendant can be found guilty of that offense only if all of the following facts are proved beyond a reasonable doubt:

First: That the Defendant, by the use of intentionally the person named in the indictment, as charged; and

Second: That the Defendant did so knowingly and because such person was, or had been, reproductive health services; and

Third: That the Defendant's acts resulted in

[To "force" someone simply means to exert or apply physical compulsion or restraint against the person.]

[To "interfere with" simply means to restrict a person's freedom of movement.]

[To "intimidate" simply means to place a person in reasonable apprehension of bodily harm either to that person or to another.]

[To "physically obstruct" simply means to render impassable ingress to or egress from a facility that provides reproductive health services.]

The term "reproductive health services" simply means medical, surgical, counseling or referral services provided in a hospital, clinic, physician's office or other facility, relating to the human reproductive system including services relating to pregnancy or the termination of a pregnancy.

[The term "bodily injury" means a cut, abrasion, bruise or disfigurement; or physical pain or illness; or the impairment of the function of a bodily member, organ or mental faculty; or any other injury to the body no matter how temporary.]

ANNOTATIONS AND COMMENTS

18 USC § 248(a)(1) provides: Whoever -- (1) by force or threat of force or by physical obstruction, intentionally injures, intimidates or interferes with or attempts to injure, intimidate or interfere with any person because that person is or has been, or in order to intimidate such person or any other person or any class of persons from, obtaining or providing reproductive health services [shall be guilty of an offense against the United States].

Maximum Penalty: One (1) year imprisonment and applicable fine unless bodily injury results.

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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.

Why IRB 2011-39 is a useful reference for practitioners

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.


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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

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