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Introduction›Part III. Administrative, Procedural, and Miscellaneous

SECTION 6. AUDIT PROTECTION

Internal Revenue Bulletin 1997-10 · 2026-10-03 edition · updated 2026-10-04 · United States

FOR CHANGE IN METHOD OF ACCOUNTING

.01 A bank within the scope of this revenue procedure that timely complies with all of the terms and conditions of this revenue procedure will have audit protection (that is, the district director may not propose that the bank change the same method of accounting as the method that the bank is changing under this revenue procedure) for tax years before 1997 unless (1) the bank has received written notification from an examining agent (for example, by examination plan, information document request, notification of proposed adjustments or income tax examination changes) before February 19, 1997, specifically citing as an issue under consid

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eration the bank’s reserve method of accounting for bad debts, or (2) the bank’s reserve method of accounting for bad debts was an issue under consideration by an appeals office or a federal court before February 19, 1997.

.02 The district director, however, will verify the amount of the § 481(a) adjustment and the § 481 adjustment period, and otherwise determine that the bank has fully complied with this revenue procedure.

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