SECTION 13. EFFECTIVE DATE

.01 In general . Except as provided in section 13.02(1) of this revenue procedure, this revenue procedure is effective for Forms 3115 filed on or after May 15, 1997. .02 Transition rules .

(1) Currently pending Forms 3115 . If a taxpayer filed a Form 3115 under Rev. Proc. 92–20 for a taxable year ending on or after May 15, 1997, and the Form 3115 is pending with the national office on May 15, 1997, the taxpayer may apply the terms and conditions (exclusive of the year of change) in this revenue procedure. However, the national office will apply the terms and conditions in Rev. Proc. 92–20, unless, prior to the later of June 15, 1997, or the issuance of the letter ruling granting or denying consent to the change, the taxpayer notifies the national office that it requests to apply the terms and conditions (exclusive of the year of change) in this revenue procedure.

(2) New Forms 3115 . Except as provided in section 13.02(3) of this revenue procedure, a taxpayer that files a Form 3115 under this revenue procedure on or before December 31, 1997, may apply the terms and conditions (exclusive of the year of change) in Rev. Proc. 92–20. The taxpayer must affirmatively state in an attachment to the Form 3115 (a) that it requests to apply the terms and conditions (exclusive of the

20

year of change) in Rev. Proc. 92–20, and (b) the applicable § 481(a) adjustment period and the authority therefor.

(3) Open window periods under Rev. Proc. 92–20 . If, on May 15, 1997, a taxpayer is within a window period provided in Rev. Proc. 92–20, the taxpayer may file a Form 3115 under this revenue procedure during the remainder of that window period and apply the terms and conditions in Rev. Proc. 92–20 for the applicable window period. The taxpayer must affirmatively state in an attachment to the Form 3115 (a) that it agrees to apply the terms and conditions of the applicable window period in Rev. Proc. 92–20, and (b) the applicable § 481(a) adjustment period and the authority therefor.