SECTION 4. PROCEDURAL

INFORMATION AND RELIANCE ON INTERIM GUIDANCE

This notice serves as an “administrative pronouncement” as that term is used in § 1.6662–4(d)(3)(iii) of the Income Tax Regulations and may be relied upon to the same extent as a revenue ruling or revenue procedure. If, and to the extent, future published guidance differs from the interim guidance in this notice, the different provisions of that future guidance will be applied without adverse retroactive effect.