Rev. Proc. 83-55

SECTION 1. BACKGROUND

Section 4.01 of Rev, Proc. 83-22, 1983-1 C.B. 680, sets forth areas in which advance rulings and determination letters will not ordinarily be issued by the Internal Revenue Service.

SEC. 2. PROCEDURE

Rev. Proc. 83-22 is amplified to include the following under section 4.01:

Section 61.-Gross Income Defined.-Determination as to who is the true owner of property in cases involving the sale of securities, or participation interests therein, where the purchaser has the contractual right to cause the security, or participation interest therein, to be purchased by either the seller or a third party.

SEC. 3. EFFECTIVE DATE

This revenue procedure will apply to all ruling requests on hand in the National Office on July 25, 1983 as well as to requests received thereafter.

SEC. 4. EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 83-22 is amplified.