Rev. Rul. 77-178

The purpose of this Revenue Ruling is to modify Rev. Rul. 74-464, 1974-2 C.B. 47, and Rev. Rul. 74-620, 1974-2 C.B. 380. Rev. Rul. 74-464 revokes Rev. Rul. 69-377, 1969-2 C.B. 231; Rev. Rul. 69-501, 1969-2 C.B. 233, Rev. Rul. 70-645, 1970-2 C.B. 273, and Rev. Rul. 73-110, 1973-1 C.B. 454.

The final paragraph of Rev. Rul. 74-464 provides that, pursuant to the authority contained in section 7805(b) of the Internal Revenue Code of 1954, such revocation will not affect interest paid on debt obligations issued prior to the expiration of the interest equalization tax (IET) on June 30, 1974, under financing arrangements that met the requirements set forth in the revoked Revenue Rulings.

Rev. Rul. 74-620 amplifies Rev. Rul. 74-464 by revoking Rev. Rul. 72-337, 1972-2 C.B. 589, and Rev. Rul. 72-416, 1972-2 C.B. 591.

The final paragraph of Rev. Rul. 74-620 provides that pursuant to the authority contained in section 7805(b) of the Code, such revocation will not affect debt obligations or prefered stock issued prior to the expiration of the IET on June 30, 1974, under financing arrangements that met the requirements set forth in the Revenue Rulings revoked by Rev. Rul. 74-464 and Rev. Rul. 74-620.

Held, because Rev. Rul. 74-464 was not released until August 27, 1974, in Technical Information Release 1306, pursuant to section 7805(b) of the Code, the date August 27, 1974 is substituted for the phrase "the expiration of the IET on June 30, 1974" in the last paragraph of both Rev. Rul. 74-464 and Rev. Rul. 74-620.

Accordingly, the revocation of Rev. Rul. 69-377, Rev. Rul. 69-501, Rev. Rul. 70-645, Rev. Rul. 72-337, Rev. Rul. 72-416 and Rev. Rul. 73-110 will not affect debt obligations or preferred stock issued prior to August 27, 1974, under financing arrangements that met the requirements of such revoked Revenue Rulings.

Rev. Rul. 74-464 and Rev. Rul. 74-620 are modified.