SECTION 5. EFFECTIVE DATE

This revenue procedure is effective with respect to amended returns filed to comply with § 301.6501(c)–1(f)(2) after August 21, 2000. Submissions filed on or before this date to comply with the adequate disclosure requirements under the statute and regulations will be accepted by the Service as effective to commence the running of the period of limitations as of the date filed, provided the submission contains sufficient information to constitute adequate disclosure under § 301.6501(c)–1(f)(2). The taxpayer is not required to conform submissions filed on or before this date to the requirements of this revenue procedure.