Rev. Rul. 64-132

Revenue Ruling 62-10, C.B. 1962-1, 305, holds that the filing of an information return on Form 990, Form 990-A, or Form 990-P, by an organization exempt from income tax under section 501(a) of the Internal Revenue Code of 1954 does not start the running of the statute of limitations for purposes of assessment of the unrelated business income tax imposed by section 511 of the Code and required to be reported on Form 990-T. The Revenue Ruling was silent as to its effective date.

In order to facilitate compliance with the Revenue Ruling and the administration thereof, the retroactive application of Revenue Ruling 62-10 is hereby limited, by authority of section 7805(b) of the Code, to January 22, 1962, the date on which the Revenue Ruling was published.

Accordingly, the holding in Revenue Ruling 62-10 will not be applied to any taxable year which would have been barred as of the date the Revenue Ruling was published (January 22, 1962), had the filing of an information return on Form 990, Form 990-A, or Form 990-P, in good faith, been regarded as the filing of a `return' for purposes of starting the period of limitations on assessment and collection of the unrelated business income tax imposed by section 511 of the Code.

Revenue Ruling 62-10 is amended accordingly.

¹ Also released as Technical Information Release 567, dated April 8, 1964.