7-912061
SUBJECT: 24(1)
We are writing in response to your telephone call of July 15, 1991, when you advised us of certain factual changes to be made to our prior memorandum to you (file number 7-910742, dated June 28, 1991) concerning the above-noted taxpayer.
We acknowledge that the third and fourth paragraphs of our prior memorandum should be deleted and replaced with the following:
24(1)
These changes do not alter the position outlined in our prior memorandum to you dated June 28, 1991.
If you have any further questions on this matter, please contact the writer.
for ChiefLeasing and Financing SectionFinancial Industries DivisionRulings Directorate