Rev. Proc. 82-6

This revenue procedure clarifies Rev. Proc. 72-38, 1972-2 C.B. 813, which prescribes conditions under which the Internal Revenue Service will accept one properly executed Form 872, Consent to Extend the Time to Assess Tax, Form 872-B, Consent to Extend the Time to Assess Miscellaneous Excise Taxes, or Form SS-10, Consent to Extend the Time to Assess Employment Taxes, covering a parent corporation and any or all of its subsidiary corporations.

Section 3.01 of Rev. Proc. 72-38 is amended by adding the following new subsection immediately after subsection 3:

4 No fixed percentage of ownership by the parent corporation is mandated. The subsidiaries included on the rider and covered by the consent may be less than wholly owned by the parent corporation provided that all the conditions prescribed in this revenue procedure are met.

Rev. Proc. 72-38 is clarified. This clarification also applies to consents executed on Form 872-A, Special Consent to Extend the Time to Assess Tax, under section 3.04 of Rev. Proc. 79-22, 1979-1 C.B. 563.