Rev. Proc. 82-28

SECTION 1. BACKGROUND

Rev. Proc. 82-22, page 469, this Bulletin, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 5 of Rev. Proc. 82-22 is entitled, Areas Under Extensive Study in Which Rulings or Determination Letters Will Not Be Issued Until the Service Resolves the Issue Through Publication of a Revenue Ruling, Revenue Procedure, Regulations or Otherwise.

SEC. 2. PROCEDURE

Rev. Proc. 82-22 is hereby amplified by adding to section 5:

Section 704(e)--Family Partnerships--Any matter relating to a family partnership in which, on formation of the partnership or other specified date, there is a special allocation of an item of income, gain, loss, deduction or credit for the purpose of fixing or freezing the value of a partner's partnership interest.

SEC. 3. EFFECTIVE DATE

This revenue procedure will apply to all ruling requests on hand in the National Office on April 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

Rev. Proc. 82-22 is amplified.