SECTION 6. AREAS COVERED BY

AUTOMATIC APPROVAL PROCEDURES IN WHICH RULINGS WILL NOT ORDINARILY BE ISSUED

.01 Section 442.—Change of Annual Accounting Period.—All situations where the Service has provided an administrative procedure for obtaining a change in annual accounting period. See Rev. Procs. 92–13, 1992–1 C.B. 665 (as modified by Rev. Proc. 94–12, 1994–1 C.B. 565, and as modified and amplified by Rev. Proc. 92–13A, 1992–1 C.B. 668) (certain corporations that have not changed their accounting period within the prior 6 calendar years or other specified time); 87–32, 1987–2 C.B. 396, as modified by § 301.9100–3T (partnership, S corporation, or personal service corporation seeking a natural business year or an ownership taxable year); 68–41, 1968– 2 C.B. 943 (as modified by Rev. Proc. 81–40, 1981–2 C.B. 604) (trusts held by certain fiduciaries needing a workload spread); and 66–50, 1966–2 C.B. 1260 (as modified by Rev. Proc. 81–40) (individual seeking a calendar year).

.02 Section 446.—General Rule for Methods of Accounting.—All situations where the Service has provided an administrative procedure for obtaining a change in method of accounting. See Rev. Procs. 97–43, 1997–39 I.R.B. 12 (certain taxpayers required to change their method of accounting to comply with elections out of certain exemptions from dealer status for purposes of § 475); 97–37, 1997–33

I.R.B. 18 (applies to the changes in methods of accounting that are described in the Appendix of Rev. Proc. 97–37 involving §§ 162, 167, 168, 197, 263, 263A, 446, 454, 455, 461, 471, 472, 585, 1273, and 1281); 97–30, 1997–1 C.B. 702 (taxpayers seeking to elect general asset accounts under § 168(i)(4) for depreciable property placed in service in prior years, election available only for a taxpayer’s taxable year ending in 1996 or 1997); Rev. Proc. 97–18, 1997–1 C.B. 642 (certain banks seeking to change from the § 585 reserve method to the § 166 specific charge off method for bad debts so as to be able to elect S corporation status for the first taxable year beginning after December 31, 1996); Rev. Proc. 97–10, 1997-1 C.B. 628 (taxpayers seeking to change the classification under § 168 of a retail motor fuel outlet placed in service before August 20, 1996, procedures available only for a taxpayer’s taxable year that includes August 20, 1996; Rev. Proc. 92–67, 1992–2 C.B. 429 (certain taxpayers with one or more market discount bonds seeking to make a § 1278(b) election or a constant interest rate election).

.03 Section 461.—General Rule for Taxable Year of Deduction.—All situations where the Service has provided an administrative procedure for making or revoking an election under § 461. See Rev. Procs. 92–29, 1992–1 C.B. 748 (dealing with the use of an alternative method for including in basis the estimated cost of certain common improvements in a real estate development); and 92–28, 1992–1 C.B. 745, as amplified by Rev. Proc. 94–32, 1994–1 C.B. 627 (dealing with ratable accrual of real property taxes).

.04 Section 1362.—Election; Revocation; Termination.—All situations in which an S corporation qualifies for automatic inadvertent termination relief under Rev. Proc. 94–23, 1994–1 C.B. 609, and all situations in which a corporation qualifies for automatic late S corporation election relief under Rev. Proc. 97–48, 1997–43 I.R.B. 19. .05 Sections 1502, 1504, and 1552.— Regulations; Definitions; Earnings and Profits.—All situations where the Service has provided an administrative procedure for obtaining waivers or consents on consolidated return issues. See Rev. Procs. 90–53, 1990–2 C.B. 636 (certain corpora

1998–1 I.R.B. 111 January 5, 1998

long as their contents may become material in the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by § 6103.

DRAFTING INFORMATION

The principal author of this revenue procedure is Michael Danbury of the Office of Assistant Chief Counsel (Corpo

rate). For further information about this revenue procedure, please contact Mr. Danbury at (202) 622-7750 (not a tollfree call).

January 5, 1998 112 1998–1 I.R.B.

26 CFR 601.201: Rulings and determination letters.

Rev. Proc. 98–4