Rev. Proc. 84-8

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 4 of Rev. Proc. 83-22 is entitled, Areas in Which Rulings or Determination Letters Will Not Ordinarily Be Issued.

SECTION 2. PROCEDURES

Rev. Proc. 83-22 is hereby amended by adding to section 4.01 the following:

Sections 38, 46, and 48 -- Investment Tax Credit-- Application of these sections where the formal ownership of property is in a party other than the titleholder, except when title is held merely as security.

Sections 167 and 168--Depreciation; Accelerated Cost Recovery System -- Application of these sections where the formal ownership of property is in a party other than the titleholder, except when title is held merely as security.

SECTION 3. EFFECTIVE DATE

This revenue procedure will apply to all the ruling requests currently on hand in the National Office on February 6, 1984, the date of publication of this revenue procedure in the Internal Revenue Bulletin, as well as to the requests received thereafter.

SECTION 4. EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 83-22 is amplified.