Internal Revenue Service
Revenue Ruling

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 Rev. Rul. 72-93

1972-1 C.B. 408

Sec. 7805

IRS Headnote

Additional pre-1953 obsolete rulings relating primarily to pension trust issues are listed.

Full Text

Rev. Rul. 72-93

Revenue Procedure 67-6, C.B. 1967-1, 576, announced a program for the review of rulings published before 1953 with the immediate objective of identifying and publishing lists of those rulings which, although not specifically revoked or superseded, are not considered to be determinative with respect to future transactions.

In accordance with that program those rulings relating primarily to the pension trust area have been under review. Certain rulings have been found that are not determinative with respect to future transactions. Revenue Ruling 67-467, C.B. 1967-2, 432, and Revenue Ruling 70-278, C.B. 1970-1, 281, have been published declaring those rulings obsolete.

Upon further review of rulings dealing primarily with the pension trust area, the additional rulings listed below have been found to be not determinative with respect to future transactions because (1) the applicable statutory provisions or regulations have been changed, (2) the ruling position is specifically covered by statute, regulations, or a subsequent published position, or (3) the facts set forth are not sufficient to permit application of the current statute and regulations. They are hereby declared obsolete.

  General (or Chief) Counsel's Memorandum (G.C.M.) Ruling Series

     G.C.M.

     4875, C.B. VII-2, 137
     24061, C.B. 1944, 133

Income Tax (I.T.) Ruling Series

     I.T.

     3744, C.B. 1945, 192

Mimeograph (Mim. or M.) Ruling Series

     Mim. (or M.)
     6477, C.B. 1950-1, 16

Pension Trust Division Information Service (PS) Ruling Series PS No.

      5, dated July 29, 1944
     34, dated September 23, 1944
     45, dated January 26, 1945
     65, dated November 10, 1950

The purpose of this declaration of obsolescence is to make it clear to all concerned that the above-listed rulings are not determinative with respect to future transactions. It is not the purpose of this Revenue Ruling to determine the applicability of any of the listed rulings to past transactions.

Other rulings published prior to 1953 relating to the pension trust area will continue to be reviewed to ascertain those that are inapplicable to future transactions. Therefore, failure to include any particular ruling in the above list should not be construed as an indication that the ruling necessarily is determinative with respect to future transactions.