us-irs-revenue-rulings-rr-98-44•rr-98-44.pdf
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# Part I Section 355. -- Distribution of Stock and Securities of a Controlled Corporation 26 CFR 1.355-2: Limitations. (Also § 7805; 301.7805-1.) Rev. Rul. 98-44 Rev. Rul. 70-225, 1970-1 C.B. 80, modified by Rev. Rul. 98-27, 1998-22 I.R.B. 4, addresses a distribution of the stock of a newly formed controlled corporation followed by an acquisition of the stock of the controlled corporation. Rev. Rul. 70-225 is no longer determinative following enactment of § 1012 of the Taxpayer Relief Act of 1997, Pub. L. No. 105-34, 111 Stat. 788, 914-18 (the "Act"), as amended in $ 6010 (c) of the Tax Technical Corrections Act of 1998, Pub. L. No. 105-206, 112 Stat. 790, 813- 14, which modified certain provisions in $$ 351, 355, and 368 of the Internal Revenue Code. Subject to certain transition rules, § 1012 (c) of the Act is effective for transfers after August 5, 1997. Accordingly, Rev. Rul. 70-225 is declared obsolete as of the effective date of § 1012 (c) of the Act. <!-- PageBreak --> # DRAFTING INFORMATION The principal author of this revenue ruling is Phoebe Bennett of the Office of Assistant Chief Counsel (Corporate) . For further information regarding this revenue ruling, contact Ms. Bennett at (202) 622-7750 or Brendan P. O'Hara at (202) 622-7530 (not toll-free calls) .
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