SECTION 2. PROCEDURE

Rev. Proc. 96–3 is amplified by adding to section 5 the following: Sections 101, 761 and 7701.— Definitions.—Whether, in connection with the transfer of a life insurance policy to an unincorporated organization, (i) the organization will be treated as a partnership under §§ 761 and 7701 of the Internal Revenue Code, or (ii) the transfer of the life insurance policy to the organization will be exempt from the transfer for value rules of § 101, when substantially all of the organization’s assets consist or will consist of life insurance policies on the lives of the members.