SERVICE WILL NOW RULE ON THE CLASSIFICATION OF EQUIPMENT LEASING TRUSTS.

Rev. Proc. 89-26

SECTION 1. BACKGROUND

Rev. Proc. 89-3, 1989-1 I.R.B. 29, sets forth areas in which the Internal Revenue Service will not issue advance rulings or determination letters. Section 5 of Rev. Proc. 89-3 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." Section 5.27 concerns the classification of equipment leasing trusts for federal income tax purposes.

SECTION. 2. PROCEDURE

Rev. Proc. 89-3 is modified by deleting section 5.27.

SECTION. 3. EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 89-3 is modified.

SECTION. 4. EFFECTIVE DATE.

This revenue procedure is effective as of April 3, 1989, the date of publication of this revenue procedure in the Internal Revenue Bulletin.

DRAFTING INFORMATION

The principal author of this revenue procedure is Eileen Shatz of the Office of Assistant Chief Counsel (Passthroughs and Special Industries). For further information regarding this revenue procedure contact Ms. Shatz on (202) 343-8459 (not a toll-free call).