ADVANCE RULINGS ON BUSINESS EXPENSES OF CERTAIN EXEMPT ORGANIZATIONS

Rev. Proc. 84-32

SECTION 1. BACKGROUND

Rev. Proc. 84-22, 1984-1 C.B. 680, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 5 of Rev. Proc. 84-22 is entitled, Areas Under Extensive Study in Which Rulings of Determination Letters Will Not Be Issued Until the Service Resolves the Issue Through Publication of a Revenue Ruling, Revenue Procedure, Regulations or Otherwise.

SECTION 2. PROCEDURE

Rev. Proc. 84-22 is amplified by adding the following to section 5:

Section 162. -Trade or Business Expenses.

Whether payments paid or accrued by a corporation to an exempt organization as described in section 501(c)(7), (c)(9), (c)(17) or (c)(20) of the Internal Revenue Code, are deductible under section 162.

SECTION 3. EFFECTIVE DATE

This revenue procedure will apply to all ruling requests on hand in the National Office on April 9, 1984, the date of publication of this revenue procedure in the Internal Revenue Bulletin, as well as to requests received thereafter.

SECTION 4. EFFECT ON OTHER REVENUE PROCEDURE

Rev. Proc. 84-22 is amplified.