Rev. Rul. 78-231

Consistent with the program for the review of rulings published in the Internal Revenue Bulletin before 1953 (announced by Rev. Proc. 67-6, 1967-1 C.B. 576), the Internal Revenue Service has undertaken a review of rulings that were published in the Bulletin after 1952. As a result of this post-1952 review, the Service published Rev. Rul. 69-227, 1969-1 C.B. 315, Rev. Rul. 72-622, 1972-2 C.B. 652, Rev. Rul. 74-624, 1974-2 C.B. 406 and Rev. Rul. 76-315, 1976-2 C.B. 449, which declared obsolete numerous rulings having primary application in the excise tax area.

Upon further review of rulings in the excise tax area, the additional rulings listed below, although not specifically revoked or superseded, have been found to be not determinative with respect to future transactions because (1) the applicable statutory provisions or regulations have been changed; (2) the ruling position is specifically covered by statute, regulations, or a subsequent published position; or (3) the factual situation no longer exists or is not sufficiently described to permit clear application of the current statute and regulations. Accordingly, the rulings listed below are hereby declared to be obsolete.

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Other rulings published after 1952 relating to excise tax matters will continue to be reviewed to ascertain those that are inapplicable to future transactions.