Rev. Proc. 81-51

SECTION 1. PURPOSE

The purpose of this revenue procedure is to clarify the Operating Rules of Section 4 of Rev. Proc. 80-54, 1980-2 C.B. 848, with regard to liquidating trusts making provision for unlocated shareholders.

SEC. 2. CHANGES

Section 4.03, Operating Rules, of Rev. Proc. 80-54 is amended to read as follows:

.03 In the case of a trust created incident to a corporate liquidation, (1) the trustee is selected by the shareholders of record or a court of competent jurisdiction, and (2) if the trust is to hold assets for unlocated shareholders, due notice has been given to such shareholders in accordance with local law. In this regard, see Rev. Rul. 80-177, 1980-2 C.B. 109, which holds that a shareholder who was notified was in constructive receipt of a liquidating distribution when the distribution first became payable.

SEC. 3. EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 80-54 is clarified.