Rev. Proc. 84-67

SECTION 1. BACKGROUND

Rev. Proc. 84-22, 1984-13 I.R.B. 18, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 3 of Rev. Proc. 84-22 is entitled, Areas in Which Rulings or Determination Letters Will Not Be Issued.

SECTION 2. PROCEDURE

Rev. Proc. 84-22 is hereby amended by adding to section 3.01 the following new sections:

Section 7701.-Definitions.-Whether a limited partnership will be classified as a partnership if the partnership agreement does not provide that, notwithstanding anything to the contrary that may be expressed or implied in the agreement, the interests of all of the general partners, taken together, in each material item of partnership income, gain, loss, deduction, or credit is equal to at least one percent of each such item at all times during the existence of the partnership. In determining the general partners' interests in such items, limited partnership interests owned by the general partners shall not be taken into account.

Section 7701.-Definitions.-Whether a limited partnership will be classified as a partnership if the partnership agreement does not expressly provide that, upon the dissolution and termination of the partnership, the general partners will contribute to the partnership an amount equal to: (a) the deficit balances in their capital accounts; or (b) the excess of 1.01 percent of the total capital contributions of the limited partners over the capital previously contributed by the general partners; or (c) the lesser of (a) or (b).

SECTION 3. EFFECTIVE DATE

This revenue procedure will apply to all rulings requests filed in the National Office after September 24, 1984, the date of publication of this revenue procedure in the Internal Revenue Bulletin.

SECTION 4. EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 84-22 is amplified.