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The use of liquidating trusts by corporations in order to distribute all their assets to their shareholders is not new to corporate advisers.' However, recent rulings2 by the Internal Revenue Service have introduced tax aspects to the practice by giving approval to the use of the trust device in order to meet the twelve month liquidation requirement of section 337 of the Internal Revenue Code of 1954.3 Although the rulings come as welcome relief to the management and shareholders of liquidating corporations holding intangible assets that are impractical to distribute in kind to shareholders, the language of the rulings contains serious ambiguities concerning the extent to which the trust device will be allowed as an alternative to sale or division of corporate assets. This comment suggests that a broad and expansive use of liquidating trusts is consistent with the purposes and rationale of section 337, and, therefore, that these rulings should be interpreted liberally.

The Use of Liquidating Trusts to Obtain the Benefits of Section 337 of the Internal Revenue Code of 1954