Rev. Proc. 81-72

SECTION 1. BACKGROUND

Rev. Proc. 81-10, 1981-1 C.B. 647, as amplified by subsequent revenue procedures, 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.

SEC. 2. PROCEDURE

Rev. Proc. 81-10 is hereby amended by adding the following to Section 5.

Section 168(f)(8)-Special rule for leases-The tax consequences in certain areas specifically reserved in the Temporary Income Tax Regulations under the Economic Recovery Tax Act of 1981, relating to special rules for leases. The areas specifically reserved are:

section 5c.168(f)(8)-8(b)(9) on retirements and casualties; section 5c. 168(f)(8)-9 on the transfer of investment tax credit by section 168(f)(8) leases; section 5c.168(f)(8)-10 on leases between related parties; and section 5c.168(f)(8)-11 on consolidated returns.

SEC. 3. EFFECTIVE DATE

This revenue procedure will apply to all ruling requests on hand in the National Office on December 28, 1981, 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.