IRS WILL ISSUE ADVANCE RULING THAT AN ACQUISITION OR DISPOSITION OF STOCK UNDER SEC. 302(c)(2)(B) DID NOT HAVE TAX AVOIDANCE AS ITS PRINCIPAL PURPOSE

SECTION 1. BACKGROUND.

Rev. Proc. 84-22, 1984-1 C.B. 449, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 3 of Rev. Proc. 84-22 is entitled Areas in Which Rulings or Determination Letters Will Not Be Issued. Section 3.0119 of Rev. Proc. 84-22 is being modified to reflect a change in the no-rule area occasioned by the publication of Rev. Rul. 85-19, 1985-9 I.R.B. 7.

SEC. 2. PROCEDURE.

Section 3.0119 of Rev. Proc. 84-22 is modified to read in its entirety as follows:

19 Section 302.--Distributions in Redemption of Stock. Whether the acquisition or disposition of stock described in section 302(c)(2)(B) of the Code has, or did not have, as one of its principal purposes the avoidance of federal income taxes within the meaning of that section, unless the facts and circumstances are materially identical to those set forth in Rev. Rul. 56-556, 1956-2 C.B. 177, Rev. Rul. 56-584, 1956-2 C.B. 179, Rev. Rul. 57-387, 1957-2 C.B. 225, Rev. Rul. 77-293, 1977-2 C.B. 91, Rev. Rul. 79-67, 1979-1 C.B. 128, or Rev. Rul. 85-19, 1985-9 I.R.B. 7.

SEC. 3. EFFECTIVE DATE.

This revenue procedure will apply to all ruling requests on hand in the National Office on March 18, 1985, the date of publication of this revenue procedure in the Internal Revenue Bulletin, as well as to requests received thereafter.

SEC. 4. EFFECTS ON OTHER REVENUE PROCEDURES.

Section 3.0119 of Rev. Proc. 84-22 is modified.