Rev. Proc. 76-4

Rev. Proc. 75-29, 1975-1 C.B. 754, sets forth the changes to the closing agreement that the Internal Revenue Service will generally enter into in certain transactions as a condition to issuing favorable rulings pursuant to section 367 of the Internal Revenue Code of 1954.

Section 6 of Rev. Proc. 75-29 provides, in part, that at the option of the taxpayer, a taxpayer whose ruling request has been received by the National Office on or before July 31, 1975, may enter into either the closing agreement described in section 2 of Rev. Proc. 75-29 or the new closing agreement described in section 3 of Rev. Proc. 75-29. Taxpayers submitting ruling requests after July 31, 1975, however, do not have this option. The new closing agreement is their only alternative to including in gross income in the year of the exchange the amount specified in section 3.03(1)(c) of Rev. Proc. 68-23, 1968-1 C.B. 821.

Section 6 of Rev. Proc. 75-29 is modified by extending the July 31, 1975 cut-off date for the closing agreement described in section 2 of Rev. Proc. 75-29 to December 31, 1976.

Rev. Proc. 75-29 is modified.

¹ Also released as TIR-1429, dated December 23, 1975.