Rev. Proc. 81-50

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 Determinations Letters Will Not Be Issued Until the Service Resolves the Issue Through Publication of Revenue Ruling, Revenue Procedure, Regulations or Otherwise.

SEC. 2. PROCEDURE

Rev. Proc. 81-10 is hereby amplified by adding to section 5:

Section 7701 - Definitions - The classification of arrangements formed as trusts under local law, in which the trust borrows money to purchase equipment or property and leases it to third parties, and in which the grantor or grantors have a beneficial interest in the trust and the power to manage the activities of the trust.

SEC. 3. EFFECTIVE DATE

This revenue procedure will apply to all ruling requests on hand in the National Office on October 26, 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.