Rev. Proc. 81-32

SECTION 1. BACKGROUND

Rev. Proc. 81-10, 1981-1 C.B. 647, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 5 of Rev. Proc. 81-10 is entitled, Areas Under Extensive 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.

SECTION 2. PROCEDURE

Rev. Proc. 81-10 is hereby modified by deleting the language "or aircraft rental businesses" in section 5.04. After the deletion section 5.04 should read:

.04 Section 1372. - Election by Small Business Corporation. Whether trailer or mobile home parks qualify as electing small business corporations.

SECTION 3. EFFECTIVE DATE

This revenue procedure will apply to all ruling requests on hand in the National Office August 10, 1981, the date of publication of this revenue procedure in the Internal Revenue Bulletin, as well as to requests received thereafter.

SECTION 4. EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 81-10 is modified.