SERVICE TO ACCEPT RULING REQUESTS ON 'MIRROR-SUBSIDIARY' TRANSACTIONS.

Rev. Proc. 88-34

SECTION 1. PURPOSE

Section 5 of Rev. Proc. 88-3, 1988-1 I.R.B. 29, 34, contains a list of those areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (Technical and International) in which advance rulings or determination letters will not be issued because the matter is under extensive study. This revenue procedure modifies Rev. Proc. 88-3 by deleting section 5.14, relating to status as an 80-percent distributee as referred to in section 337(c).

SEC. 2. BACKGROUND

Under section 5.14 of Rev. Proc. 88-3, the Internal Revenue Service will not issue a ruling or determination letter as to whether section 1.1502-34 of the Income Tax Regulations (dealing with aggregation of stockholdings under consolidated return rules) is applicable in determining a corporate shareholder's status as an 80- percent distributee as referred to in section 337(c) of the Code.

This matter is no longer under study, and the Service will now rule on this question of the applicability of section 1.1502-34 in determining 80-percent distributee status for purposes of section 337(c) of the Code.

SEC. 3. PROCEDURE

Rev. Proc. 88-3 is modified by deleting section 5.14 in its entirety.

SEC. 4. COMMENTS OR INQUIRIES

Comments or inquiries regarding this revenue procedure should be addressed to the Associate Chief Counsel (Technical and International), Attention: CC:C:3, Internal Revenue Service, 1111 Constitution Ave., N.W., Washington, D.C. 20224.

SEC. 5. EFFECT ON OTHER DOCUMENTS

Rev. Proc. 88-3 is modified.

SEC. 6. EFFECTIVE DATE

This revenue procedure is effective June 27, 1988, the date of its publication in the Internal Revenue Bulletin.

DRAFTING INFORMATION

For further information regarding this revenue procedure, contact Mr. Barry Isaacs on (202) 566-6407 (not a toll-free call).