SECTION 6. AREAS COVERED BY

AUTOMATIC APPROVAL PROCEDURES IN WHICH RULINGS WILL NOT ORDINARILY BE ISSUED

.01 Section 442.—Change of Annual Accounting Period.—All situations where the Service has provided an administrative procedure for obtaining a change in annual accounting period. See Rev. Procs. 92–13, 1992–1 C.B. 665 (as modified by Rev. Proc. 94–12, 1994–1 C.B. 565, and as modified and amplified by Rev. Proc. 92–13A, 1992– 1 C.B. 668) (certain corporations that have not changed their accounting period within the prior 6 calendar years or other specified time); 87–32, 1987–2 C.B. 396, as modified by Rev. Proc. 92–85, 1992–2 C.B. 490 (partnership, S corporation, or personal service corporation seeking a natural business year or an ownership taxable year); 68–41, 1968–2 C.B. 943 (as modified by Rev. Proc. 81–40, 1981–2 C.B. 604) (trusts held by certain fiduciaries needing a workload spread); and 66–50, 1966–2 C.B. 1260 (as modified by Rev. Proc. 81–40) (individual seeking a calendar year).

.02 Section 446.—General Rule for Methods of Accounting.—All situations where the Service has provided an administrative procedure for obtaining a change in method of accounting. See Notice 95–57, 1995–45 I.R.B. 12 (cash method banks in the Eighth Circuit seeking to change to the cash method of accounting for stated interest on short-term loans made in the ordinary course of business; and Rev. Procs. 95– 33, 1995–28 I.R.B. 7 (certain small resellers, formerly small resellers, or reseller-producers changing their method of accounting for costs subject to § 263A); 95–25, 1995–1 C.B. 701 (certain taxpayers on a simplified production or simplified resale method of accounting for fewer than 3 taxable years electing an historic absorption ratio under § 263A); 95–19, 1995–1 C.B. 664 (certain taxpayers changing their method of accounting for interest costs subject to § 263A(f)); 94–49, 1994–2 C.B. 705, as modified by Rev. Proc. 95–33 (certain taxpayers changing their method of accounting for costs subject to § 263A); 94-30, 1994– 1 C.B. 621 (certain taxpayers changing their method of accounting for de minimis original issue discount (OID) on loans acquired before a specified cut-off date); 94–29, 1994–1 C.B. 616 (certain taxpayers seeking to use the

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principal-reduction method for de min- imis OID on certain loans originated by the taxpayer); 94–28, 1994–1 C.B. 614 (certain taxpayers changing their method of accounting for debt instruments issued on or after a specified cut-off date in order to comply with regulations dealing with OID and other related matters); 93–48, 1993–2 C.B. 580 (certain taxpayers required to change their method of accounting for notional principal contracts entered into after December 12, 1993); 93–13, 1993–1 C.B. 482 (certain domestic taxpayers required to change their method of accounting to comply with § 267(a)(3) for deducting amounts owed to related foreign persons); 92– 98, 1992–2 C.B. 512 (certain accrual method taxpayers selling multi-year service warranty contracts seeking to elect the service warranty income method); 92–75, 1992–2 C.B. 448 (certain taxpayers, other than those required to use inventories, seeking to change to an accrual method); 92–74, 1992–2 C.B. 442 (certain taxpayers, required to use inventories, seeking to change to an accrual method); 92–67, 1992–2 C.B. 429 (certain taxpayers with one or more market discount bonds seeking to make a constant interest rate election or seeking to make or revoke an election under § 1278(b)); 92–29, 1992–1 C.B. 748 (certain taxpayers seeking to use an alternative method under § 461(h) for the inclusion of common improvement costs in basis) this no-rule provision, however, does not apply to those situations where Rev. Proc. 92–29 requires the taxpayer to file a ruling request; 91–51, 1991–2 C.B. 779 (certain taxpayers that sell mortgages and retain rights to service the mortgages); 91–49, 1991–2 C.B. 777 (holders of certain mortgages that are stripped bonds); 91–31, 1991–1 C.B. 566, 568, 569 (certain utilities holding customer deposits); 90–63, 1990–2 C.B. 664 (certain taxpayers changing their accounting treatment of package design costs); 90–37, 1990–2 C.B. 361 (certain taxpayers with interest income from short-term loans); 89–46, 1989–2 C.B. 597 (cash basis taxpayers with certain United States savings bonds); 88–15, 1988–1 C.B. 683 (certain taxpayers seeking to discontinue LIFO inventory); 85–8, 1985–1 C.B. 495 (certain taxpayers seeking to change from specific charge-off method to reserve method for bad debts); 84–76, 1984–2

C.B. 751 (taxpayers seeking to treat prepaid subscription income under the provisions of § 455); 84–30, 1984–1 C.B. 482 (taxpayers who used the Rule of 78’s for interest on consumer loans); 84–29, 1984–1 C.B. 480 (individual borrowers who reported interest deductions in accordance with the Rule of 78’s); and 74–11, 1974–1 C.B. 420 (taxpayers seeking to change their method of depreciation accounting).

.03 Section 461.—General Rule for Taxable Year of Deduction.—All situations where the Service has provided an administrative procedure for making or revoking an election under § 461. See Rev. Procs. 92–29, 1992–1 C.B. 748 (dealing with the use of an alternative method for including in basis the estimated cost of certain common improvements in a real estate development); and 92–28, 1992–1 C.B.

745, as amplified by Rev. Proc. 94–32, 1994–1 C.B. 627 (dealing with ratable accrual of real property taxes).

.04 Section 1362.—Election; Revocation; Termination.—All situations in which an S corporation qualifies for automatic inadvertent termination relief under Rev. Proc. 94–23, 1994–1 C.B. 609. .05 Sections 1502, 1504, and 1552.—Regulations; Definitions; Earnings and Profits.—All situations where the Service has provided an administrative procedure for obtaining waivers or consents on consolidated return issues. See Rev. Procs. 90–53, 1990–2 C.B. 636 (certain corporations seeking reconsolidation within the 5-year period specified in § 1504(a)(3)(A)); 90–39, 1990–2 C.B. 365 (certain affiliated groups of corporations seeking, for earnings and profits determinations, to

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make an election or a change in their method of allocating the group’s consolidated federal income tax liability); and 89–56, 1989–2 C.B. 643 (certain affiliated groups of corporations seeking to file a consolidated return where member(s) of the group use a 52–53 week taxable year).