SECTION 12. ORIGINAL ISSUE

DISCOUNT (§§ 1272; 1273)

(b) The taxpayer must maintain

.01 De minimis original issue discount (OID).

(1) Description of change and scope.

(2) Additional Requirements.

(a) On a statement attached to the application, the taxpayer must describe all items that were marked to market and that will no longer be marked to market.

(b) When complying with section 6.02(3) of this revenue procedure, the taxpayer should indicate whether the taxpayer is changing under section 10A.01(1)(a)(i) or sections 10A.01(1)a)(i) and (ii) of this APPENDIX.

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

.02 Reserved.