Rev. Proc. 65-4

Section 3.01 of Revenue Procedure 64-31, C.B. 1964-2, 947, which sets forth the areas of the Internal Revenue Code of 1954 in which the Internal Revenue Service generally will not issue advance rulings, is hereby supplemented by adding the following:

Section 170.--Charitable Contributions and Gifts.--Whether a taxpayer who advances funds to a charitable organization and receives therefor a promissory note may deduct as contributions, in one taxable year or in each of several years, amounts forgiven by the taxpayer in each of several years by endorsements on the note.

The service will not issue rulings in this area inasmuch as it is impossible to determine in advance of the consummation of the transaction whether, in substance, it constitutes a gift of all of the funds in 1 taxable year.