Rev. Proc. 66-27

Revenue Procedure 64-24, C.B. 1964-1 (Part 1), 693, provides, in part, that any taxpayer who opened a deposit or account in certain financial institutions prior to November 15, 1962, will be allowed to enter into a closing agreement, as authorized under section 7121 of the Internal Revenue Code of 1954, if he agrees that the full amount of earnings on the deposit or account shall constitute gross income in the year the plan matures, is assigned, or is terminated, whichever occurs first, in accordance with prior rulings of the Service.

Revenue Procedure 64-24 is supplemented to the following extent:

Closing agreements shall be entered into only with those taxpayers who have not reported such earnings currently, and closing agreements shall not be entered into with those taxpayers reporting earnings currently in accordance with sections 1.61-7 and 1.451-2 of the Income Tax Regulations.

¹ Based on Technical Information Release 582, dated Apr. 23, 1964.