503.27 Applying Revenue Ruling 70-604 to Nonresidential Associations The issue of whether Revenue Ruling 70-604
applies to nonresidential associations has not been settled by the IRS.
Through recent audit activity of nonresidential associations, the IRS
asserted, in a 1994 District Office technical advice letter, the
position that Revenue Ruling 70-604 only applies to
residential associations. However, in a June 1995 technical advice memorandum (TAM 9539001) (HTL—Appendix 10A), the National Office of the IRS ruled that Revenue Ruling 70-604 did not apply to a nonresidential association (a timeshare development)