SECTION 2. BACKGROUND

In Rev. Proc. 94–76, 1994–2 C.B. 825, currently reflected in section 5.15 of Rev. Proc. 96–3, the IRS stated that while it was studying whether certain transactions qualifying as corporate reorganizations under § 368 circumvent the purposes of General Utilities repeal, the IRS would not issue advance rulings on the tax consequences of the transactions under study. In notice 96– 6, the IRS announced that this study is being closed.