SERVICE MAKES ADDITION TO NO-RULING AREA.

Rev. Proc. 87-37

SECTION 1. BACKGROUND

Rev. Proc. 87-3, 1987-1 I.R.B. 27, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 5 of Rev. Proc. 87-3 is entitled, Areas Under Extensive Study in which Ruling 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. 87-3 amplified by adding the following to section 5:

Section 7701 -- Definitions -- the classification of separately tradeable instruments that are issued by a corporation as a unit, the components of which collectively contain the attributes of stock.

SEC. 3 EFFECTIVE DATE

This revenue procedure applies to all rulings on hand in the National Office on August 3, 1987, the date of publication of this revenue procedure in the Internal Revenue Bulletin, as well as to requests received thereafter.

SEC. 4 EFFECT ON OTHER DOCUMENTS

Rev. Proc. 87-3 is amplified.