Rev. Proc. 83-39

Section 1. Background

Rev. Proc. 83-22, page 680, this Bulletin, 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 hereby amended by adding to section 5 the following new section:

Sections 708 and 741--Issues arising under subchapter K of the Code and issues of disposition or recapture with respect to assets held by a partnership if a corporation that holds a partnership interest liquidates and distributes the partnership interest to shareholders.

Sec. 3. Effective Date

This revenue procedure will apply to all ruling requests on hand in the National Office on June 6, 1983, the date of publication of this revenue procedure in the Internal Revenue Bulletin, as well as the requests received thereafter.

Sec. 4. Effect on other Revenue Procedures

Rev. Proc. 83-22 is amplified.