SECTION 1. PURPOSE

This revenue procedure provides alternative 50-percent settlement options to settle cases in which taxpayers accelerated deductions for accrued employee benefits secured by a letter of credit, bond, or other similar financial instrument. The purpose of this settlement initiative is to provide options for taxpayers and the Service to expeditiously resolve these cases, particularly in light of the recent legislative change that specifically precludes taxpayers from using these types of financial instruments to accelerate deductions for accrued employee benefits in the future. Settlement of these cases will relieve both taxpayers and the Service from the burdens associated with further development or litigation of the cases in the future.