Rev. Proc. 82-60

Section 1. Background

Rev. Proc. 82-22, 1982-1 C.B. 469, contains in section 4 a list of those areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (Technical) in which rulings or determination letters will not ordinarily be issued.

Sec. 2. Procedure

Section 4.01-8 of Rev. Proc. 82-22 is modified and superseded to read as follows:

"Section 341.--Collapsible Corporations.--Whether a corporation will be considered to be a "collapsible corporation," that is, whether it was "formed or availed of" with the view of certain tax consequences. However, ruling requests will be considered on this matter when the enterprise (1) has been in existence for at least 20 years, (2) has had an aggregate change in the shareholders' interests of not more than 10 percent during that period (except for transfers among family members, as defined in section 267(c)(4)), and (3) has conducted substantially the same trade or business during that period."

Sec. 3. Effects on Other Revenue Procedures

Section 4.01-8 of Rev. Proc. 82-22 is modified and superseded.

Sec. 4. Effective Date

This revenue procedure will apply to all ruling requests on hand in the National Office on November 8, 1982, the date of publication of this revenue procedure in the Internal Revenue Bulletin, as well as to requests received thereafter.