SECTION 10. DRAFTING INFORMATION

The principal author of this revenue procedure is Grid Glyer of the Office of Associate Chief Counsel (Corporate). For further information regarding this revenue procedure, please contact Mr. Glyer at (202) 317-3181.

1 Unless otherwise specified, all “section” or “§” references are to sections of the of the Internal Revenue Code of 1986, as amended (Code) or the Income Tax Regulations (26 CFR part 1).