Rev. Rul. 64-279

Revenue Ruling 60-31, C.B. 1960-1, 174, discusses the application of the doctrine of constructive receipt to certain deferred compensation arrangements and states that, in each case involving a deferral of compensation, a determination must be made upon the basis of the specific factual situation involved.

The final paragraph of Revenue Ruling 60-31 states that advance rulings will not be issued in specific cases involving deferred compensation arrangements.

The Internal Revenue Service will now consider requests for advance rulings in regard to deferred compensation arrangements. Revenue Ruling 60-31 is modified to delete the final paragraph.