LIMITED PARTNERSHIP QUESTION ADDED TO 'NO-RULE' LISTING.

Rev. Proc. 93-3A

Rev. Proc. 93-3, page 370, this Bulletin, lists areas in which the Internal Revenue Service will not issue rulings or determination letters. Inadvertently omitted from that revenue procedure was the no-rule provision regarding section 7701 of the Internal Revenue Code that was announced in Rev. Proc. 92-87, 1992-42 I.R.B. 38. This revenue procedure revises Rev. Proc. 93-3 by adding this no-rule provision to Section 4 and by adding a reference to this in the changes section.

1. Section 1.02

Section 1.02, dealing with changes, is supplemented by adding a new section 1.02(6A) to read as follows:

(6A) New section 4.01(49) deals with section 7701 of the Code. See Rev. Proc. 92-87, 1992-2 C.B. 496.

2. Section 4.01

Section 4.01, dealing with areas in which rulings or determination letters will not ordinarily be issued, is supplemented by adding a new section 4.01(49) to read as follows:

(49) Section 7701. -- Definitions. -- Whether a limited partnership lacks the corporate characteristics of limited liability and continuity of life if the limited partnership (1) is formed pursuant to a state limited partnership act that the Service has determined in a revenue ruling is a statute that corresponds to the Uniform Limited Partnership Act, and (2) meets the other requirements contained in Rev. Proc. 92-88, 1992-2 C.B. 496.

EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 93-3 is supplemented. Rev. Proc. 92-87 is superseded. The changes set forth in this revenue procedure will be reflected in Rev. Proc. 93-3 when it is reprinted in 1993-1 C.B.