Rev. Proc. 80-41

Rev. Proc. 80-22, 1980-1 C.B. 654, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 5 of Rev. Proc. 80-22 lists 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. Section 5 is amplified to include the following:

Section 820. -- Optional Treatment of Policies Reinsured Under Modified Coinsurance Contracts. The tax consequences of modified coinsurance contracts to which section 820 of the Code may apply, including whether taxpayers who have entered into a modified coinsurance contract may allocate between the reinsured and reinsurer certain items to which section 820(c) applies.

Rev. Proc. 80-22 is amplified.