Rev. Proc. 83-64

SECTION 1. BACKGROUND

Rev. Proc. 83-22, 1983-1 C.B. 680, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 5 of Rev. Proc. 83-22 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. 83-22 is amplified to include the following under Section 5.

Section 103.-Interest on Certain Governmental Obligations.- With respect to requests made pursuant to Rev. Proc. 79-12, 1979-1 C.B. 492, whether municipal bonds will meet the "trade or business test" and the "security interest test" under sections 103(b)(2)(A) and (B) of the Code and section 1.103-7(b)(5) of the regulations when the proceeds are used to finance facilities such as electric energy, gas or water facilities and, pursuant to a contract to take, or to take or pay for, a nonexempt person purchases 75 percent or more of the actual output of the facility but less than 25 percent of the subparagraph (5) output of the facility as defined in section 1.103-7(b)(5)(ii)(b) of the regulations.

SEC. 3. EFFECTIVE DATE

This revenue procedure will apply to all ruling requests on hand in the National Office on September 6, 1983, 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. 83-22 is amplified.