Rev. Proc. 81-67

Rev. Proc. 81-10, 1981-1 C.B. 647, contains in section 5 a list of those areas of the Internal Revenue Code under the jurisdiction of the Assistant Commissioner (Technical) which are under extensive study and in which ruling 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 5 of Rev. Proc. 81-10 is amplified to include a new section as follows:

Section 368.--Definitions relating to Corporate Reorganizations.--The tax consequences of a transaction intended to qualify as a reorganization under section 368(a)(1)(E) of the Code when the plan of reorganization provides for the use of contingent or escrow stock arrangements, and where the share adjustment is triggered by an event the occurrence or non-occurrence of which is within the control of the shareholders or is triggered by a Service audit of the shareholders or the corporation.

EFFECT ON OTHER DOCUMENTS

Rev. Proc. 81-10 is amplified.

EFFECTIVE DATE

This revenue procedure will apply to all ruling requests on hand in the National Office on December 21, 1981, the date of publication of this revenue procedure in the Internal Revenue Bulletin, as well as to requests received thereafter.