PLR 9935004: Correction to a prior internal reorganization ruling

Plain-English summary

The IRS corrected one step in a ruling it had issued in 1997 about a proposed internal reorganization. The corrected text says that a company contributed another company's stock to a new corporation in exchange for voting common and nonvoting preferred stock. The short letter gives no new tax conclusion and does not reproduce the rest of the earlier ruling.

Ruling snapshot

• Question: How should step (iv) of ruling (49) in the earlier letter read?
• Outcome: Other: the IRS corrected its earlier description of the stock contribution.
• Key authorities: Rev. Rul. 77-191.

Full text (IRS public release)

Internal Revenue Service
Department of the Treasury

Index Number: 368.04-00
Washington, DC 20224

Number: 199935004
Person to Contact:
Release Date: 9/3/1999
Telephone Number:

Refer Reply To:
CC:DOM:CORP:4 PLR-109493-99
Date:

March 26, 1999

Dear
:

This letter is in reference to our letter dated November 12, 1997 in which a ruling was issued regarding a proposed internal reorganization of .
It has since been discovered that ruling (49) step (iv) should have read as follows: P
had contributed the JF1 stock to Newco in exchange for voting common stock and
nonvoting preferred stock of Newco (Rev. Rul. 77-191).

Thank you for your cooperation in this matter.

Sincerely,

Assistant Chief Counsel (Corporate)

By:
Wayne T. Murray
Senior Technician/Reviewer
Branch 4

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