SERVICE ADDS NEW NO RULE AREA; WILL NOT RULE ON DETERMINING STATUS AS AN EIGHTY PERCENT DISTRIBUTEE UNDER SECTION 337.

Rev. Proc. 87-23

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, Areas Under Executive 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 supplemented by adding the following to section 5:

Section 337 -- Nonrecognition for Property Distributed to Parent in Complete Liquidation of Subsidiary -- Whether section 1.1502-34 of the Income Tax Regulations is applicable in determining status as an 80-percent distributee as referred to in section 337(c). See also section 332.

SEC. 3. EFFECTIVE DATE

This revenue procedure applies to all ruling requests on hand in the National Office on May 26, 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 supplemented.