Rev. Proc. 83-16

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.

Sec. 2. Procedure

Rev. Proc. 82-22 is hereby amended by adding to section 5 the following new section:

Section 721.--Nonrecognition of Gain or Loss on Contribution.--Whether section 721 applies to the contribution of widely-held developed or undeveloped real property or interests therein; widely held oil and gas properties or interests therein; or any similarly held properties or interests to a partnership in exchange for an interest in the partnership when (i) the contribution is the result of solicitation by promoters, brokers, or investment houses, or (ii) the interest in the transferee partnership is issued in a form designed to render it readily tradable.

Sec. 3. Effective Date

This revenue procedure will apply to all ruling requests on hand in the National Office on March 14, 1983, the date of publication of this revenue procedure in the Internal Revenue Bulletin, as well as the requests received thereafter.

Sec. 4. Effect on Other Revenue Procedures

Rev. Proc. 82-22 is amplified.