Revocation before QSub election ef- fective. For purposes of Section 1361(b)(3)(D) and § 1.1361–5(c) (five-year prohibition on re-election), a revoca- tion effective on the first day the QSub election was to be effective will not be treated as a termination of a QSub election. [T.D. 8869, 65 FR 3850, Jan. 25, 2000]
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