On 18 November 1997, the US Treasury Department issued Rev. Rul. 97- 48 and thereby revoked Rev. Rul. 75-7, stating that the Internal Revenue Service will follow the Tax Court decisions in the cases of Ashland Oil v. Commissioner and Vetco, Inc. v. Commissioner effective 18 December 1997. This article analyses the issues presented by Rev. Rul. 97-48.