Rev. Proc. 82-63

SECTION 1. BACKGROUND

Rev. Proc. 82-22, 1982-1 C.B. 469, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Paragraph 39 of section 3.01 of Rev. Proc. 82-22 provides that the Service will not issue ruling or determination letters on the classification of arrangements formed as partnerships under local law where the members of such partnerships are professional corporations.

SEC. 2. PROCEDURE

Rev. Proc. 82-22 is hereby modified by deleting paragraph 39 from section 3.01.

SEC. 3. EFFECTIVE DATE

The revision set forth in this revenue procedure is effective as of December 6, 1982, the date of publication in the Internal Revenue Bulletin.

SEC. 4. EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 82-22 is modified.