Rev. Proc. 82-56

Section 1. Background

Rev. Proc. 82-22, 1982-1 C.B. 469, contains in section 5 a list of those areas of the Internal Revenue Code under the jurisdiction of the Associate Chief Counsel (Technical) which are under extensive study and 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. 82-22 is amplified to include the following under section 5:

"Section 351.--Transfer to Corporation Controlled by Transferor.--Whether section 351 applies to the transfer of widely-held developed or undeveloped real property or interests therein; widely held oil and gas properties or interests therein; or any similarly held properties or interests to a corporation in exchange for shares of stock of such corporation when (i) the transfer is the result of solicitation by promoters, brokers, or investment houses, or (ii) the transferee corporation's stock is issued in a form designed to render it readily tradable."

Sec. 3. Effects on Other Revenue Procedures

Section 5 of Rev. Proc. 82-22 is amplified.

Sec. 4. Effective Date

This revenue procedure will apply to all ruling requests on hand in the National Office on October 12, 1982, the date of publication of this revenue procedure in the Internal Revenue Bulletin, as well as the requests received thereafter.