Rev. Proc. 82-40

Section 1. Background

Rev. Proc. 82-22, 1982-1 C.B. 469, contains in section 4 a list of those areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (Technical) in which rulings or determination letters will not ordinarily be issued.

Sec. 2. Procedure

Rev. Proc. 82-22 is amplified by adding the following to section 4.01:

"Section 346.--Partial Liquidation.--Whether a distribution will qualify as a distribution in partial liquidation under section 346(a)(2) of the Code unless it results in a 20 percent or greater reduction in (1) gross revenue, (2) net fair market value of assets, and (3) employees."

Sec. 3. Effective Date

This revenue procedure will apply to all ruling requests on hand in the National Office on July 26, 1982, 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 Revenue Procedures

Section 4 of Rev. Proc. 82-22 is amplified.