SEC. 4. PROCEDURE

.01 If a taxpayer elects to be governed by the intragroup-customer election and the election results in the taxpayer being required to change its method of accounting, then the taxpayer must attach both

September 29, 1997 12 1997–39 I.R.B.

payer holds, or held, transition securities, which are subject to identification under Holding 15 of Rev. Rul. 97–39, the statement must describe the basis for concluding that the securities were or were not described in § 475(b)(1)(A), (B), or (C), including the date, content, and location of documents in the taxpayer’s books and records that support such conclusions. If there were no identifications, or if none of the taxpayer’s securities were transition securities, then the statement should convey this information.