Rev. Rul. 84-172

Rev. Proc. 67-6, 1967-1 C.B. 576, announced a program for the review of rulings published before 1953 with the immediate objective of identifying and publishing lists of those rulings that, although not specifically revoked or superseded, are not considered determinative with respect to future transactions.

Consistent with the objectives of that program, the Internal Revenue Service has undertaken a review of certain rulings that were published in the Internal Revenue Bulletin after 1952. The purpose of this revenue ruling is to publish a list of post-1952 rulings dealing with foreign tax credit matters that, although not specifically revoked or superseded, are not considered determinative with respect to future transactions because (1) the applicable statutory provisions have been changed or repealed; (2) the ruling position is specifically covered by statute, regulations, or a subsequent published position; or (3) the facts set forth no longer exist or are not sufficient to permit application of the current statute.

Accordingly, the rulings listed below are declared obsolete.

 Rev. Rul. No.                  C.B. Citation

Other rulings published after 1952 relating to foreign tax credit matters will continue to be reviewed to ascertain those that are inapplicable to future transactions. Therefore, failure to include any particular ruling in the above list should not be construed as an indication that the ruling necessarily is determinative with respect to future transactions.