Rev. Proc. 82-66

Section 1. Background

Rev. Proc. 82-22, 1982-1 C.B. 469, provides a list of those areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (Technical) which are under extensive study and 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. A list of those areas is set forth in section 5 of that Rev. Proc. This list has been amplified by Rev. Proc. 82-27, 1982-1, C.B. 480, among others.

Sec. 2. Procedure

Rev. Proc. 82-22, as amplified by Rev. Proc. 82-27, is hereby modified by deleting from section 5 the following subsection:

"Section 306.--Dispositions of Certain Stock.--Whether preferred stock received by an exchanging shareholder who either actually owns some common stock or actually owns no common stock after the exchange is "section 306 stock" in those cases where utilization of the principles of section 318 of the Code in applying the 'cash in lieu of' test of section 1.306-3(d) of the Income Tax Regulations would result in such shareholder's receipt of a dividend pursuant to section 302(d)."

Sec. 3. Effective Date

For transactions described in Rev. Proc. 82-27, this revenue procedure will apply to all ruling requests that pertain to stock received or to be received after August 31, 1982, in taxable years ending after that date. The tax treatment of preferred stock so received is governed by section 306 of the Code as amended by section 227(a) of the Tax Equity and Fiscal Responsibility Act of 1982, which has the same effective date.

Sec. 4. Effect on Other Revenue Procedures

Rev. Proc. 82-22, as amplified by Rev. Proc. 82-27, is modified.