Rev. Proc. 82-11

SECTION 1. BACKGROUND

Rev. Proc. 81-10, 1981-1 C.B. 647, sets forth areas in which rulings and determination letters will not be issued by the Internal Revenue Service. Section 3 of Rev. Proc. 81-10 lists areas in which rulings or determination letters will not be issued under any circumstances.

SEC. 2. PROCEDURE

Rev. Proc. 81-10 is amplified by adding to section 3 the following:

Section 2055--Transfers for Public, Charitable and Religious Uses.--Whether a charitable lead interest qualifies as a guaranteed annuity interest for purposes of section 2055(e)(2)(B) of the Code if that interest may be prepaid before the expiration of the specified term of that interest or before the death of the life or lives used to measure the term of such interest.

Section 2522--Charitable and Similar Gifts.--Whether a charitable lead interest qualifies as a guaranteed annuity interest for purposes of section 2522(c)(2)(B) of the Code if that interest may be prepaid before the expiration of the specified term of that interest or before the death of the life or lives used to measure the term of such interest.

Section 170--Charitable, Etc., Contributions and Gifts.--Whether a charitable lead interest qualifies as a guaranteed annuity interest for purposes of section 170(f)(2)(B) of the Code if that interest may be prepaid before the expiration of the specified term of that interest or before the death of the life or lives used to measure the term of such interest.

SEC. 3. EFFECTIVE DATE

This revenue procedure will apply to all ruling requests on hand in the National Office on February 22, 1982, 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. 81-10 is amplified.