IRS WILL NOT ISSUE ADVANCE RULINGS ON GENERAL MOTORS' E STOCK.

Rev. Proc. 87-59

SECTION 1. BACKGROUND

Rev. Proc. 87-3, 1987-1 I.R.B. 27, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 5 of Rev. Proc. 87-3 is titled "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. 87-3 is supplemented by adding the following to section 5:

Section 7701 -- Definitions -- The classification of an instrument that has certain voting and liquidation rights in an issuing corporation but whose dividend rights are determined by reference to the earnings of a segregated portion of the issuing corporation's assets, including assets held by a subsidiary.

SEC. 3. EFFECTIVE DATE

This revenue procedure applies to all rulings on hand in the National Office on October 26, 1987, the date of publication of this revenue procedure in the Internal Revenue Bulletin, as well as to requests received thereafter.

SEC. 4. EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 87-3 is supplemented.

DRAFTING INFORMATION

The principal author of this revenue procedure is Jerilynn Chapman of the Corporation Tax Division. For further information regarding this revenue procedure contact Mr. Mark W. Boyer on (202) 566-3825 (not a toll-free call).