Rev. Proc. 68-32

Revenue Procedure 66-34, C.B. 1966-2, 1232, sets forth operating rules that must be satisfied before a ruling will be issued in certain types of transactions. Section 3 thereof is amended by adding new subsection .05 to read as follows:

In determining stock ownership to be attributed to a trust or from a trust under the rules of sections 318(a)(2)(B)(i) and 318(a)(3)(B)(i) of the Internal Revenue Code of 1954 in those cases where a surviving spouse is entitled to all the income for life from the trust and also holds a power of appointment over the corpus of the trust, and in default of the exercise of the power the property held by the trust is to pass to the children of the surviving spouse, attribution will be computed as if the surviving spouse has exercised the power in favor of his or her children, so that they will be considered beneficiaries in the absence of evidence that the power has been differently exercised.