SECTION 9. MAKING THE

ELECTION FOR AFFECTED YEARS THAT CLOSE BEFORE JULY 1, 1996

The Commissioner hereby allows a group to select a particular year as the election year even if the resulting affected years will include one or more years that are not still open for assessment under section 6501 on July 1, 1996. This permission is granted

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only if, in addition to meeting the other requirements and filing deadlines of this revenue procedure, the group files the statement of election before the statute of limitations expires for any affected year and, for each affected year that is not still open for assessment on July 1, 1996, the group meets all requirements with respect to that year before the statute of limitations expires for that year.