SEC. 3. CONDITIONS FOR
Internal Revenue Bulletin 1999-2 · 2026-10-03 edition · updated 2026-10-04 · United States
TREATMENT UNDER THIS REVENUE PROCEDURE.
A taxpayer shall qualify for the treatment provided in this revenue procedure only if it satisfies the conditions described in this section 3.
.01 The treatment provided in this revenue procedure is available if the taxable income of such taxpayer is adjusted by the Internal Revenue Service under section 482, or by the taxpayer pursuant to section 1.482–1(a)(3) of the regulations, and the taxpayer is not subject to a penalty under section 6662(e)(1)(B) or (h) of the Code by reason of the primary adjustment that is the basis for the treatment under this revenue procedure.
.02 A taxpayer shall not qualify under section 3.01, above, for the treatment provided in this revenue procedure if any part of any underpayment of tax by such taxpayer for the taxable year involved in the section 482 allocation is due to fraud.
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