Rev. Proc. 83-75

SECTION 1. BACKGROUND

Rev. Proc. 83-22, 1983-1 C.B. 680, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 4.02 of Rev. Proc. 83-22 is entitled, Areas In Which Rulings Or Determination Letters Will Not Ordinarily Be Issued-General area.

SEC. 2. PROCEDURE

Rev. Proc. 83-22 is hereby amended by adding to section 4.02 the following new subsection:

The tax effect of a transaction if any part of the transaction is pending litigation among the parties affected by the transaction, except for transactions involving bankruptcy reorganizations.

SEC. 3. EFFECTIVE DATE

This revenue procedure will apply to all requests for rulings on hand in the National Office on the date of publication of this revenue procedure in the Internal Revenue Bulletin, as well as to requests received thereafter.

SEC. 4. EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 83-22 is amplified.