SECTION 12. ORIGINAL ISSUE

DISCOUNT (§ 1273)

.01 De minimis original issue discount (OID).

(1) Description of change and scope.

district director that old and new loans have been adequately segregated.

(3) Additional requirements. On a statement attached to the application, the taxpayer must:

(a) identify the categories of loans to which the new method will apply; and

(b) describe any “additional categories” permitted under section 4.03 of Rev. Proc. 97–39.

(4) No audit protection. A taxpayer does not receive audit protection under section 7 of this revenue procedure in connection with this change.

.02 Reserved.