SECTION 1. PURPOSE

This revenue procedure provides methods that taxpayers may use to value certain stock received by a target corporation’s shareholders in a potential reorganization for purposes of determining whether the continuity of interest (COI) requirement under § 1.368–1(e) of the Income Tax Regulations is satisfied. In the circumstances described in this revenue procedure, the Internal Revenue Service (IRS) will not challenge a taxpayer’s use of one of these methods to determine the value of such stock, in lieu of using the stock’s actual trading price on a particular day.