SERVICE WILL NOW ISSUE RULING AND DETERMINATION LETTERS REGARDING CLASSIFICATION OF LIMITED LIABILITY COMPANIES.

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 RULING 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 5.37 deals with the classification of limited liability companies for federal income tax purposes.

SEC. 2. PROCEDURE

Rev. Proc. 88-3 is modified by deleting section 5.37.r

SEC. 3. EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 88-3 is modified.

SEC. 4. EFFECTIVE DATE

This revenue procedure is effective as of September 19, 1988, the date of publication of this revenue procedure in the Internal Revenue Bulletin.

DRAFTING INFORMATION

The principal author of this revenue procedure is Ann Veninga of the Individual Tax Division. For further information regarding this revenue procedure, contact Ms. Veninga on (202) 566-5983 (not a toll- free call).