SECTION 6. EFFECTIVE DATE

.01 In general . Section 4 of this revenue procedure applies to all contribu

tions of property as part of a QMFS on or after June 4, 2001. Section 5 of this revenue procedure applies to all ruling requests pending in the National Office on June 4, 2001, and to requests received thereafter.

.02 Transition rule for pending ruling requests. If a QMFS has filed a request for a ruling allowing it to aggregate contributed securities for purposes of making § 704(c) and reverse § 704(c) allocations and that ruling request is pending in the national office on June 4, 2001, the QMFS may withdraw that ruling request and receive a refund of its user fee. However, the national office will process ruling requests pending on June 4, 2001, unless, prior to the earlier of July 19, 2001, or the issuance of the letter ruling, the QMFS notifies the national office that it will withdraw its ruling request.

DRAFTING INFORMATION

The principal author of this revenue procedure is Horace Howells of the Office of Associate Chief Counsel (Passthroughs and Special Industries). For further information regarding this revenue procedure, contact Horace Howells at (202) 622-3050 (not a toll-free call).

26 CFR 601.105: Examination of returns and
claims for refund; determination of correct tax
liability.
(Also Part I, sections 942, 943.)

Rev. Proc. 2001–37