Rev. Proc. 74-22

Rev. Proc. 72-9, 1972-1 C.B. 719, lists those areas of the Internal Revenue Code of 1954 in which the Internal Revenue Service will not issue advance rulings or determination letters. Sec. 3.01 of Rev. Proc. 72-9, which lists specific areas with regard to which rulings or determination letters will not be issued, is hereby amplified to include the following area:

Section 704(b)(2).--Partner's Distributive Share Determined.--Whether the principal purpose of any provision in the partnership agreement, with respect to a partner's distributive share of any item of income, gain, loss, deduction, or credit, is the avoidance or evasion of Federal income tax.