Rev. Proc. 82-27

SECTION 1. BACKGROUND

Rev. Proc. 82-22, page 469, this Bulletin, provides a list of those areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (Technical) which are under extensive study and in which ruling or determination letters will not be issued until the Service resolves the issue through publication of a revenue ruling, revenue procedure, regulations, or otherwise. A list of those areas is set forth in section 5 of the Rev. Proc.

SEC. 2. PROCEDURE

Rev. Proc. 82-22 is amplified to include the following under section 5:

Section 306. -- Dispositions of Certain Stock. -- Whether preferred stock received by an exchanging shareholder who either actually owns some common stock or actually owns no common stock after the exchange is "section 306 stock" in those cases where utilization of the principles of section 318 of the Code in applying the "cash in lieu of" test of section 1.306-3(d) of the Income Tax Regulations would result in such shareholder's receipt of a dividend pursuant to section 302(d).

SEC. 3. EFFECTIVE DATE

This revenue procedure will apply to all ruling requests on hand in the National Office on April 19, 1982 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 DOCUMENTS

Rev. Proc. 82-22 is amplified.