I searched the internet, but could not find the source document. Is this ruling public to everyone to use?
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You can find the text of Revenue Ruling 84-53 on page 160 of the Internal Revenue Cumulative Bulletin 1984-1 (page 172 of the PDF). It's a large file (109 MB) and the download is slow, so it might take a minute or two for the download to complete after you click the link.
@rjs Thank you so much!
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