Rev. Rul. 83-173

Periodically, the Internal Revenue Service has obsoleted rulings that, although not specifically revoked or superseded, are not considered determinative with respect to future transactions because (1) the applicable statutory provisions have been changed or repealed; (2) the ruling position is specifically covered by statute, regulations or a subsequent published position; or (3) the facts set forth no longer exist or are not sufficient to permit application of the current statute.

The purpose of this revenue ruling is to specify a post-1952 ruling having primary application in the income tax area that, although not specifically revoked or superseded, is not considered determinative with respect to future transactions because the facts set forth no longer exist or are not sufficient to permit application of the current statute.

Accordingly, the following revenue ruling is declared obsolete:

Revenue Ruling 57-560, 1957-2 C.B. 108.

The purpose of this declaration of obsolescence is to make it clear to all concerned that the above ruling in the income tax area is not determinative with respect to future transactions. It is not the purpose of this revenue ruling to determine its applicability to past transactions.