Rev. Proc. 81-61

SECTION 1. BACKGROUND

Rev. Proc. 81-10, 1981-1 C.B. 647, provides 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. A list of those areas is set forth in section 5 of the Rev. Proc.

SEC. 2. PROCEDURE

Rev. Proc. 81-10 is amplified to include the following under section 5:

"Section 304.--Redemption Through Use of Related Corporations.--Whether section 304, 351(a), or 351(b) of the Code applies to the transferors' receipt of property from an existing or newly formed transferee corporation in a transaction described in both sections 304 and 351. Property, for this purpose, is defined in section 317(a) and, in general, includes securities and short-term debt instruments of the transferee, and the assumption of liabilities, but excludes stock of the transferee."

SEC. 3. EFFECTIVE DATE

This revenue procedure will apply to all ruling requests on hand in the National Office on November 30, 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 DOCUMENTS

Rev. Proc. 81-10 is amplified.