SECTION 7. EFFECT ON OTHER

DOCUMENTS

Rev. Procs. 88–32 and 88–33 are obsolete after January 31, 1996.

DRAFTING INFORMATION

The principal author of this revenue procedure is Timothy L. Jones of the Office of Assistant Chief Counsel (Financial Institutions & Products). For further information regarding this revenue procedure contact Mr. Jones on (202) 622-3980 (not a toll-free call).

Appendix A

ACKNOWLEDGEMENT OF A REQUEST FOR A REVIEWABLE

RULING

The undersigned acknowledges that the request for a ruling submitted by

48

{ insert name of issuer } to the Internal Revenue Service on { insert date of the request for a ruling} is governed by section 4 of Rev. Proc. 96–16 . Section 4 of Rev. Proc. 96–16 sets forth procedures that must be followed to obtain a ruling that may be reviewed by the United States Tax Court under § 7478 of the Internal Revenue Code.

Name of the Issuer Date

Appendix B

ACKNOWLEDGEMENT OF A

REQUEST FOR A NONREVIEWABLE RULING

The undersigned acknowledges that the request for a ruling submitted by { insert name of holder or issuer } to the Internal Revenue Service on { insert date of the request for a ruling } is governed by section 5 of Rev. Proc. 96–16. Section 5 of Rev. Proc. 96–16 sets forth procedures that must be followed to obtain a nonreviewable ruling. Therefore, the request for a ruling does not comply with the requirements of section 4 of Rev. Proc. 96–16 which sets forth the procedures that must be satisfied to obtain a ruling that is reviewable by the United States Tax Court under § 7478 of the Internal Revenue Code.

Name of issuer or holder Date