SECTION 9. REVIEW BY DISTRICT

DIRECTOR

.01 In general. The district director must apply a change in method of accounting made in compliance with all the applicable provisions of this revenue procedure in determining the taxpayer’s liability, unless the district director recommends that the change in method of accounting should be modified or revoked. (See section 6.06 of this revenue procedure if a change in method of accounting is made without complying with

August 18, 1997 26 1997–33 I.R.B.

ter) previously authorized by an automatic consent procedure listed in section 14.01 of this revenue procedure, before August 18, 1997, to make a change in method of accounting authorized by this revenue procedure, the taxpayer may make the change under this revenue procedure. However, the national office will process the application in accordance with the automatic consent procedure under which the application was filed, unless prior to September 30, 1997, the taxpayer notifies the national office in writing (at the address provided in section 6.02(6) of this revenue procedure) that it wants to make the change under this revenue procedure. If the taxpayer timely notifies the national office that it wants to make the method change under this revenue procedure, the national office will require the taxpayer to make appropriate modifications to the application to comply with the applicable provisions of this revenue procedure.

(2) New applications.

mation are made. An extension of the 21day period to furnish information, not to exceed 15 days, may be granted to a taxpayer. A request for an extension of the 21-day period must be made in writing and submitted within the 21-day period. If the extension request is denied, there is no right of appeal.

.03 Conference in the national office. If the national office tentatively determines that the taxpayer has changed its method of accounting without complying with all the applicable provisions of this revenue procedure (for example, the taxpayer changed to a method of accounting that varies from the applicable accounting method described in this revenue procedure or the taxpayer is outside the scope of this revenue procedure), the national office will notify the taxpayer of its tentative adverse determination and will offer the taxpayer a conference of right, if the taxpayer has requested a conference. For conference procedures for taxpayers other than exempt organizations, see section 11 of Rev. Proc. 97–1 (or any successor). For conference procedures for exempt organizations, see section 12 of Rev. Proc. 97–4, 1997–1 I.R.B. 96 (or any successor).

.04 National office determination. If the national office determines that the taxpayer has changed its method of accounting without complying with all the applicable provisions of this revenue procedure, the national office will notify the taxpayer that consent to make the change in method of accounting either (1) is not granted, or (2) is granted, provided the taxpayer makes appropriate adjustments to conform its change in method of accounting to the applicable provisions of this revenue procedure. Any adjustments so made must be accompanied by conforming amendments to any federal income tax returns filed for the year of change and subsequent taxable years.