Small Business into an entity known as SpinCo. could be at risk. Shares fell more than 7% on Tuesday, closing at $40.98, their lowest level since October 2014. Yahoo! said that the comments from Zimbalist weren't applicable to it, and the spinoff of the assets remained on track to happen by the end of the year, as Yahoo! previously indicated. "An IRS representative stated Tuesday that the IRS plans to study its rules for issuing private letter rulings regarding the active trade or business requirement in spin-off transactions and will hold off processing new ruling requests," said a Yahoo! representative in an email statement. "Yahoo understands that the IRS's statement is not specific to Yahoo's planned Q4 2015 spin-off of its remaining stake in Alibaba Group and Yahoo Small Business, reflects no change in applicable law, and does not affect previously filed ruling requests. Yahoo filed its pending ruling request with the IRS in Q1 2015."