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 § 301.9100–3 (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.—Except as otherwise provided in the listed revenue procedures, all situations where the Service has provided an administrative procedure for obtaining a change in method of accounting. See Rev. Procs. 99–49, 1999–52 I.R.B. 725 (accounting method changes described in the Appendix to Rev. Proc. 99–49 involving §§ 56, 162, 167, 168, 171, 174, 197, 263, 263A, 404, 446, 451, 454, 455, 461, 467, 471, 472, 475, 585, 1272, 1273, 1278, and 1281, and former § 168); 98–58, 1998–2 C.B. 712 (certain taxpayers required to change to the installment method for purposes of computing alternative minimum taxable income (AMTI) with regard to income from the disposition of § 1221(1) property); 97–43, 1997–2 C.B. 494 (certain

taxpayers required to change their method of accounting as a result of making elections out of certain exemptions from dealer status for purposes of § 475); 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); 92–29, 1992–1 C.B. 748 (certain taxpayers seeking to use an alternative method under § 461(h) for including common improvement costs in basis); and 91–51, 1991–2 C.B. 779 (certain taxpayers seeking to change their method of accounting for sales of mortgage loans from a method that does not comply with § 1286).

.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 late S corporation relief under Rev. Proc. 97–48, 1997–2 C.B. 521, or for automatic inadvertent termination or inadvertent invalid election relief under section 6 of Rev. Proc. 98–55.

.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 corporations seeking reconsolidation within the 5-year period specified in § 1504(a)(3)(A)); 90–39, 1990–2 C.B. 365 (certain affiliated groups of corporations seeking, for earnings and profits determinations, to make an election or a change in their method of allocating the group’s consolidated federal income tax liability); and 89–56, 1989–2 C.B. 643 (certain affiliated groups of corporations seeking to file a consolidated return where member(s) of the group use a 52–53 week taxable year).