Rev. Proc. 76-19

Rev. Proc. 72-9, 1972-1 C.B. 718, sets forth areas in which advance rulings or determination letters generally will not be issued by the Internal Revenue Service. Section 4.021 of Rev. Proc. 72-9 states that rulings or determination letters will not ordinarily be issued on any matter where the determination requested is primarily one of fact, e.g., market value of property. Section 4.021 of Rev. Proc. 72-9 is hereby amplified to read as follows:

1. Any matter where the determination requested is primarily one of fact, e.g., market value of property, or whether an interest in a corporation is to be treated as stock or indebtedness.

Section 4.011 states that rulings or determination letters will not ordinarily be issued for purposes of section 163 of the Internal Revenue Code of 1954 (deduction for interest) concerning whether advances to thin corporations constitute loans or are equity investments. Section 4.011 of Rev. Proc. 72-9 is deleted since this matter is now specifically covered by the amplification of section 4.021.