SERVICE WILL NOT ISSUE ADVANCE RULINGS OR DETERMINATION LETTERS ON MEDICAL REIMBURSEMENT PLAN QUESTION.

Rev. Proc. 87-46

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 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. 87-3 is hereby amplified by adding to section 5 the following new section:

Section 105. -- Amounts Received Under Accident and Health Plans. -- Whether a medical reimbursement plan, funded by employer contributions, containing a provision allowing unused amounts to be carried over and accumulated in an employee's account qualifies as an accident and health plan under section 105 of the Code.

SEC. 3. EFFECTIVE DATE.

This revenue procedure will apply to all ruling requests on hand in the National Office on September 8, 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 amplified.