Rev. Proc. 83-12

Section 1. Background

Rev. Proc. 82-22, 1982-1 C.B. 469, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 4 of Rev. Proc. 82-22 is entitled, Areas in Which Rulings or Determination Letters Will Not Ordinarily be Issued.

Sec. 2. Procedure

Rev. Proc. 82-22 is amplified to include the following under section 4.01:

Section 103.--Interest On Certain Governmental Obligations.--Whether municipal bonds will meet the "security interest test" under section 103(b)(2)(B) of the Code and section 1.103-7(b)(2)(B) of the Code and section 1.103-7(b)(4) of the regulations because an underlying arrangement is inferred, as illustrated in Rev. Rul. 80-251, 1980-2 C.B. 40, and Rev. Rul. 80-339, 1980-2 C.B. 42, when payments not pledged as security for the bonds are received in respect of the bond-financed property used in the trade or business of nonexempt persons in an amount equal to more than 25 percent of the principal or interest payments on the bonds.

Sec. 3. Effective Date

This revenue procedure will apply to all ruling requests on hand in the National Office on February 22, 1983, 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. 82-22 is amplified.