SECTION 6. AREAS NOT

COVERED BY THIS REVENUE PROCEDURE

The Secretary’s grant of automatic consent to revoke a taxpayer’s § 831(b) Election obtained under this revenue procedure does not constitute an opinion, express or implied, concerning the tax consequences of any aspect of taxpayer’s business, including, but not limited to, whether any part of taxpayer’s business constitutes insurance for Federal income tax purposes, whether taxpayer qualified as an insurance company for any taxable year, or whether taxpayer was properly taxed under § 831(b) for any taxable year.

Bulletin No. 2025–8 817 February 18, 2025