SERVICE OPENS RULING AREAS ON COMMUTING EXPENSES, COOPERATIVE HOUSING CORPORATIONS, AND WHETHER MUNICIPAL BONDS MEET SECURITY INTEREST TEST.

Rev. Proc. 88-45

SECTION 1. BACKGROUND

Rev. Proc. 88-3, 1988-1 I.R.B. 29, sets forth areas of the Internal Revenue Code under this jurisdiction of the Associate Chief Counsel (Technical and International) relating to non-international issues in which the Internal Revenue Service will not issue advance rulings or determination letters.

Section 4 of Rev. Proc. 88-3 is entitled "AREAS IN WHICH RULINGS OR DETERMINATION LETTERS WILL NOT ORDINARILY BE ISSUED."

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."

SEC. 2. PROCEDURE

Rev. Proc. 88-3 is modified by deleting section 5.08 (relating to whether expenses are nondeductible commuting expenses) and is amplified by adding to section 4.01 the following paragraph:

Sections 162 and 262. -- Commuting Expenses. -- Whether expenses are nondeductible commuting expenses.

SEC. 3. EFFECTS ON OTHER REVENUE PROCEDURES

Section 4 of Rev. Proc. 88-3 is amplified and section 5.08 of Rev. Proc. 88-3 is deleted.

SEC. 4 EFFECTIVE DATE

This revenue procedure will apply to all ruling requests as of September 19, 1988, the date of publication of this revenue procedure in the Internal Revenue Bulletin, as well as requests received thereafter.

DRAFTING INFORMATION

The principal author of this revenue procedure is Leonard H. Friedman of the Individual Tax Division. For further information regarding this revenue procedure contact Mr. Friedman on (202) 343- 8556 (not a toll-free call).