Part III. Administrative, Procedural, and Miscellanous

and the relationships between the parties to such agreements and the promoter or organizer of the arrangement; (2) the terms of any agreements between the promoter or organizer of the arrangement and the holders of the fractional interests or among the holders of the fractional interests, including any contractual restrictions to which the fractional interests are subject, such as waivers of the right to partition, rights of first refusal, and options to put and/or call the fractional interests; and (3) the overall economics of the arrangements, including the sharing of profits and losses from operating the property as well as of appreciation and depreciation in the value of the property. An original and eight copies of written comments should be sent to:

Internal Revenue Service Attn: CC:MSP:R (Rev. Proc. 2000–46) Room 5228 (PSI:Br1) P.O. Box 7604 Ben Franklin Station Washington, D.C. 20044

or hand delivered between the hours of 8 a.m. and 5 p.m. to:

Courier’s Desk Internal Revenue Service Attn: CC:MSP:R (Rev. Proc. 2000–46) Room 5228 (PSI:Br1) 1111 Constitution Avenue, NW Washington, DC

Alternatively, taxpayers may submit comments electronically at: Joel.S.Rutstein@M1.IRSCounsel.treas.gov.

DRAFTING INFORMATION

The principal author of this revenue procedure is Jeanne Sullivan of the Office of the Associate Chief Counsel, Passthroughs & Special Industries. However, other personnel from the IRS and Treasury participated in its development. For further information, contact Jeanne Sullivan at (202) 622-3050 (not a toll-free number).

26 CFR 601.201: Rulings and determination letters.

Rev. Proc. 2000–46