SERVICE TO ACCEPT RULING REQUESTS ON ISSUES SURROUNDING PARTNERSHIP FREEZES.

Rev. Proc. 88-51

SECTION 1. BACKGROUND

Rev. Proc. 88-3, 1988-1 I.R.B. 29, sets forth areas in which the Internal Revenue Service will not issue advance rulings or determination letters. Section 5 of Rev. Proc. 88-3 is entitled "AREA 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 5.24 concerns any matter relating to a family partnership in which, on formation of the partnership or other specified date, there is a special allocation of an item of income, gain, loss, deduction or credit for the purpose of fixing or freezing the value of a partner's partnership interest.

SEC. 2. PROCEDURE

Rev. Proc. 88-3 is modified by deleting section 5.24.

SEC. 3. EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 88-3 is modified.

SEC. 4. EFFECTIVE DATE

This revenue procedure is effective as of October 24, 1988, the date of publication of this revenue procedure in the Internal Revenue Bulletin.

DRAFTING INFORMATION

The principal author of this revenue procedure is Marshall Feiring of the Passthroughs and Special Industries Division. For further information regarding this revenue procedure contact Mr. Feiring on (202) 566-6199 (not a toll-free call).