SECTION 2. BACKGROUND

Rev. Proc. 97–3, section 5, lists specific areas in which rulings or determination letters will not be issued because the areas are under extensive study. This revenue procedure adds a subparagraph for certain income exception charitable remainder unitrusts under § 664(d)(3) of the Internal Revenue Code. The Service and Treasury will study whether creating or using income exception charitable remainder unitrusts to control the timing

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ciary, or a person related or subordinate to a grantor, a trustee, or a beneficiary can control the timing of the trust’s receipt of trust income from a partnership or a deferred annuity contract to take advantage of the difference between trust income under § 643(b) and income for federal income tax purposes for the benefit of the unitrust recipient.