Rev. Proc. 80-37

Rev. Proc. 80-22, 1980-1 C.B. 654, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 4.018 of Rev. Proc. 80-22 states that rulings or determination letters will not ordinarily be issued on the tax effect of the transfer when part of the consideration received by the transferors consists of bonds, debentures, or any other evidences of indebtedness of the transferee. Section 4.018 is hereby amplified to read as follows:

8 Section 351 -- Transfers to Controlled Corporation. --

The tax effect of the transfer when part of the consideration received by the transferors consists of bonds, debentures, or any other evidence of indebtedness of the transferee and the term of the "indebtedness" is either less than ten years or a determination as to whether the "indebtedness" is properly classified as debt or equity is required in order to establish that the requirements of section 351 are met.

Rev. Proc. 80-22 is amplified.