Rev. Proc. 82-30

SECTION 1. BACKGROUND

Rev. Proc. 82-22, page 469, this Bulletin, contains in section 3 a list of those areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (Technical) in which ruling or determination letters will not be issued. In order to facilitate more efficient utilization of personnel resources, a new subsection concerning section 368(a)(1)(E) of the Code is being added. There are no current plans to include other sections of the Code as no ruling area for this stated purpose.

SEC. 2. PROCEDURE

Rev. Proc. 82-22 is amplified to include the following under section 3:

Section 368(a)(1)(E).--Definitions relating to Corporate Reorganizations.--Whether a transaction constitutes a corporate recapitalization within the meaning of section 368(a)(1)(E) of the Code (or a transaction that also qualifies under section 1036) except when the recapitalization is an integral part of a larger transaction and it is impossible to determine the tax consequences of the larger transaction without making a determination with regard to the recapitalization.

SEC. 3. EFFECTIVE DATE

This revenue procedure is effective with regard to all ruling requests postmarked after April 30, 1982.

SEC. 4. EFFECT ON OTHER DOCUMENTS

Rev. Proc. 82-22 is amplified.

¹ Also released as News Release IR-82-48, dated April 28, 1982.