Rev. Proc. 83-11

Section 1. Background

Rev. Proc. 82-22, 1982-1 C.B. 469 sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 5 of Rev. Proc. 82-22 is entitled, Areas Under Extensive Study in Which Rulings or Determination Letters Will Not Be Issued Until the Service Resolves the Issue Through Publication of a Revenue Ruling, Revenue Procedure, Regulations or Otherwise.

Section 5.11 provides:

Section 7701.--Definitions.--Whether a trust that is beneficially owned by the shareholders of the settlor corporation is a trust for federal income tax purposes if the corporation remains in existence after the transfer in trust, and if the corporation retains working interests in oil, gas, or mineral properties, the royalty interests of which properties are transferred to the trust.

Sec. 2. Procedure

Rev. Proc. 82-22 is hereby modified by deleting Section 5.11. The Service will now consider requests for rulings in this area. See Rev. Proc. 82-37, 1982-1 C.B. 491, with regard to obtaining a ruling or determination letter from the Service.

Sec. 3. Effective Date

This revenue procedure is effective February 22, 1983, the date of its publication.

Sec. 4. Effect on Other Revenue Procedures

Rev. Proc. 82-22 is modified